ML20141M544
| ML20141M544 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 08/26/1992 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9209010112 | |
| Download: ML20141M544 (4) | |
Text
-..
Commonwealth Erilson--
,~
L-1400 Opus Place
[
'Uf Dow.iers Grove, Illinvis 60515 August 26,1992 1
2 I
L U.S. Nuclear Regulatory Commission l
Washington, DC 20555 l
Atention: Document Control Desk v
l
Subject:
Quad Cities Nuclear Power Station Units 1 and 2 -
l Response to Notice of Violation and Open item i
Inspection Report Nos. 50-254/92016; 50-265/92016 1
NRC Docket Nos,50 254 and 50-265 ordell Reed dated July 27,1992
~
Reference:
B. Clayton le n
transmitting h *
.i spection Report 50-254/92016; 50-265/92016 I
l Enclosed is the Commonwealth Edison Company (CECO) response to the l
Notice of Violation (NOV) which was transmitted with the reference letter and Inspection Report. The NOV concerned the failure to incorporate into the safe -
shutdown procedures, measures to ensure isolation of a 480 VAC bus from associated i
non-safety circuits in the event of a disabling firs :n the auxillary equipment room. Also, an Open item was issued associated with the ~ June 1,1992 inadvertent loss of the instrument air compressors. CECO's response to the above items is provided in the l
attachment.-
I' If your staff has any questions or comments concerning this transmittal, please refer them to Jim Watson, Compliance Engineer at (708) 515-7205.
l Sincerely, -
- h. /hwubV i
- T.J. Kovach Nuclear Licensing Manager i
i Attachment cc: A.B. Davis, Regional Administrator - Region lil L Ols_han, Project Manager, NRR T. Taylor, Senior Resident inspector F
9209010112 920826 PDR. ADOCK 05000Fi'94 G.
PDR XED/:
i' ZNLD/2096/1 f
/
i.
//
J i
l RESPONSE TO NOTICE OF VIOLATION 1
NRC INSPECTION REPORT 50-254/92016;50-265/92016 VIOLATION:(254/(265)/92016-01) i Section Ill.L. of Appendix R to 10CFR50 requires that proceduras be in effect to Lnplement safe shutdown capability whether offsite power is available or not. Section i1.L. further requires that safe shutdown equipment and systems for each fire area be-known to be isolated from associated non-safety circuits in the fire area so that hot shorts, open circuits, or shorts to ground in the associated circuits will not prevent operation of the safe shutdown equipment.
Contrary to the above, on July 7,1992, the inspector identified that the licensee failed to adequately incorporate into the safe shutdo vn procedures, measurss to positively ensure isolation of of the 480 VAC bus 18 from associated non-safety circuits in the event of a disabling fire within the auxiliary equipment room.
This is a Severity Level IV Violation (Supplement 1).
BEASOMEOfLVIOLAILON:
GECo acknowledges the violation. Four safe shu'.down procedures did not adequstely incorporate positive measures to er.sure isolation of the 480 VAC bus 18 from the associated non-safety circuits. Due to an inadvertent oversight, these measures were not incorporated into the procedures.
4 During a drill on July 8,1992, it was discovered that procedures OARP 600-1,700-1, 800-1 and 1200-1 did not provide adequate measures to ensure isolation of saf a shutdown equipment. The safety significance of this issue was reduced because of the operator's performance during the dri!'.
COBBECTIVE STEPS TAKEN_AND RESULTS ACHIEVED:
Althougn the procedures did rot address the isolation of bus 18 prior to cross connecting from bus 19, interlocks prevent the closure of tne bus 18 to bus 19 tie r
breakers unicss the normal feed breakers for bus 18 are open. This interlock would prevent the potential for damage to equipment by preventing out of phase power sources. As demonstrated during the drill, the operator's knowledge of this interlock is sufficient to ensure establishnient of the necessary power sources to safe shutdown equipment within the allowable time limits.
ROBBECTIVEE_ TEE _T11AT_WILLEE_IAXENIO_AVRIDIUBIBEB_ VIOLATIONS:
l Procedures OARP 600-1,700-1,800-1 and 1200-1 will be revised to include specific 3rovisions for opening the 480 VAC bus 18 normal feed breakers prior to closing the aus 18 to bus 19 tie breakers. The procedure revisions will be completed by Novembar 30,1992.
RAIE_WHEIEULL_COMELIANCE_WILLRE A0111EVER:
I Full compliance will be achieved with revisions being made to the safe shutdown procedures by November 30,1992.
I ZNLD/2096/2
RESPONSE TO OPEN ITEM NRC INSPECTION REPORT 50 254/02016;50-265/92016 OEEN ITEM:
On June 1,1992, during an out of service activity for the domestic water system, an inadvertent loss of the instrument air compressors occurred. Isolation of the domestic water system, which was supplying cooling water for the instrument air compressors, 4
caused the compressors to inp on high temperature. The normal cooling medium, service water (SW) system was isolated from the instrument air compressor heat exchangers due to plugging problems. A temporary alteration was installed using domestic water.
Contributing factors to the event included:
The domestic water Piping and Instrumentation Diagram (P&lD) wan :llegible.
(This is the second recent event associated with P&lD diagram configuration 1
control.)
No identification tags were on the system isolation valves.
Operations personnel lack of domestic water system kr.owledge.
The temporary alteration (TA) procedure has TA's grouped by area. (The valizes to isolate the individual compressors and identified in the TA are in the turbine building and the system isolation is in the service building.)
Controlled critical P&lD's are used by the operation communication center to prepare OOS tagouts. The domestic water P&lD is not with tiie controlled critical P&lD's nor was the instrument air controlled critical P&lD update i to reflect the TA.
A permanent modification for the compressor's cooling water supply has not been resolved in over a year.
The systems involved were balance of plant. There is a concern that process weaknesses exhibited during this event could be carried over to safety related systems. This is considered an cpen item (254/92016 03(DRP).
BESEONSE:
Piping and Instrumentation Diagrams (P&lD's) have been identified as a weakness at Quad Cities Station. In 1989 AIR 4-89-08 was initiated to address configuration control of plant systems. This AIR requested a walkdown be performed of P&lD's and equipment name plate data. The final 3roduct will a revised P&lD, Master Equipment List (MEl.), Total Job Management (TJ VI) data base and Vendor Equipment Technical Information (VETI) manuals.
Engineering is currently walking down systems per a priority schedule. Twenty-eight safety related systems were listed on the priarity schedule. Walkdowns started with HPCI, RCiC, EDGS, CS and RPS. Twenty Unit One systems and seventeen Unit Two systems have been walked down to date. Drawing Change Requests (DCRs) have been issued and 102 drawings revised with 198 !n process.
Operating Memo (92-4), " Policy for it - Performance of OOS's and Knowing What the Results Will Be" dated June 25,1992, has been issued and communicate:i to all shift management personnel concerning the instrument air compressor cooling water isolation event. Discussion of the policy stressed not proceeding with an activity unless the result of the activity is known.
ZNLD/2092/3
RESPONSE TO OPEN ITEM NRC INSPECTION REPORT 50-254/92016;50-265/92016 (CONT'D) i OAP 300-14, " Equipment Out-Of-Service", will be revised to include guidance that when inadequate documentation exists, for proper OOS preparation, the situation will be referred to upper management (Operating Engineer) for determination of what' additional measures ('s. walkdown, compensatory measures) are required.
1 i
i E
l t
L I
l i
4 ZNLD/2096/4
.