ML20147F879
| ML20147F879 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 03/23/1997 |
| From: | Kraft E COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ESK-97-065, ESK-97-65, NUDOCS 9703270259 | |
| Download: ML20147F879 (7) | |
Text
Osmmonwcalth I.dmn Company Quad Cines Generating $tation 227IO 206th Avenue North Ostdosa. IL 6l 2 42-9740 Tcl St9ML22il ESK-97-065 March 23,1997 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention:
Document Control Desk
Subject:
Quad Cities Station Units 1 and 2; NRC Docket Numbers 50-254 and 50-265:
NRC Inspection Report Numbers 50-254/96-020 and 50-265/96-020
Reference:
J. Grobe to E. S. Kran, Jr. Letter dated February 20,1997 Concerning Two Notices of Violation.
Enclosed is Commonweahh Edison's (Comed's) response to the two Notices of Violation transmitted with the referenced letter. The first violation concerned failure to follow procedures with three examples, the second violation concerned the failure to verify the automatic isolation of the Control Room isolation dampers.
This letter contains the following commitments:
- 1. Awareness training at Engineering meeting (s) will be conducted to ensure that the System Engineers undcistand that surveillances must satisfy the literal interpretation of the technical specifications. This will be completed by March 31,1997.
(NTS # 254-201-96-341303)
- 2. A training request (TR) and an accounting of the control room HVAC damper event has been submitted to the Curriculum Review Committee (CRC). The CRC will evaluate the event and root cause, determine if additional training is needed, and provide training as required. This will be completed by November 21,1997.
(NTS # 254-100-96-02003.01)
- 3. An evaluation of the control room HVAC Technical Specifications has been performed. The issues identified in this review are being tracked to completion.
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9703270259 970323 PDR ADOcK 05000254 G
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.N.I A Iinicum Osmpany
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If there are any questions concerning this response, please contact Mr. Charles Peterson,
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Regulatory Affairs Manager, at (309) 654-2241 extension 3609.
j Resp i lly, b.
Ma Ei S. Kraft, Jr.
Site Vice President Quad Cities Station i
Attachment (A), Quad Cities' Response to An Apparent Violation cc: A. B. Beach, Regional Administrator - RIII C. G. Miller, Senior Resident Inspector - Quad Cities R. M. Pulsifer, Project Manager - NRR '
i W. D. Leech, MidAmerican Energy Company D. C. Tubbs, MidAmerican Energy Company i
M. E. Wagner, Licensing, Comed
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DCD License (both electronic and hard copy)
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ATTACHMENT A ESK-97-065 (Page 1 of 5)
NOTICE OF VIOLATION (254-100-96-02002)
. Technical Specification (TS) 6.8.A.1 required applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, Febmay 1978 be implemented.
Regulatory Guide 1.33, Appendix A, lists procedures governing the operation of the control rod drive system and the standby gas treatment system. The appendix also listed administrative procedures, such as shift and relief turnover.
a) Quad Cities Operating Procedure (QCOP) 7500-2, " Standby Gas Treatment (SBGT)
System Shutdown," steps G.3.A.6 and G.3.A.7, required the operator to place the "B" train control switch to the "Primag" pasition and to verify that all SBGT annunciators were clear.
b) Quad Cities Administrative Procedure (QCAP) 0210-4, " Shift Turnover Panel Check for Common Panels," required the operator to check and record the status of the control switches for the SBGT system.
c) Quad Cities Operating Surveillance (QCOS) 0301-01, "CRD Exercise," step 4.a.(2),
required the operator to use single notch withdraw to return the control rod to the original position afler exercising.
Contrary to the above, a.l. On December 16,1996, an operator left the SBGT "B" train control switch in "Ofl" and did not verify that all annunciators were clear.
b.l. On December 16,1996, an operator recorded that the SBGT "B" train control switch was in the " Primary" position and it was actually in the "Ofl" position.
c.l. On Januay 18,1997, an operator used the notch override switch instead of the single notch withdraw to return the control rod to the original position afler exercising.
This is a Severity Level IV violation (Supplement I).
REASON FOR VIOLATION:
The cause of these siolations was a lack of procedure adherence.
ATTACHMENT A ESK-97-065 (Page 2 of 5)
ACTIONS TAKEN:
The immediate actions taken were to place the components in the correct position.
Job performance counseling was administered for the individuals involved in each instance.
A Quality Independent Verification (QIV) for all Control Rod Drive movement during the weekly exercises was implemented. Root Cause Investigations were conducted for both the Standby Gas Treatment (SBGT) and Control Rod Drive mispositioning events. In addition, a separate Root Cause Investigation was conducted on the r. p;ive trend in Control Room performance identified by the Operations tp
.4 e Mmg program.
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i ACTIONS TO PREVENT FURTIIER OCCURRENCE:
A new emphasis was placed on the operating overview program for all of operations management. The emphasis is on identifying and correcting behaviors which can lead to events rather than waiting for events to occur prior to taking aggressive actions. The i
information gathered from the overview program will be used as a real time indicator to i
manage operations implementation of standards. This information will be acted upon j
whenever a change in implementation of the operating standards is noticed. This will also be used as a feedback mechanism to the crews.
DATE WHEN FULL COMPLIANCE WILL BE MET:
Full compliance was met when the components were placed in the correct position on 4
12/17/96 for the SBGT control switch and 1/18/97 for the control rod.
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1 ATTACIIMENT A
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ESK-97-065 (Page 3 of 5)
STATEMENT OF VIOLATION (NRC IR 96-020-03):
Technical Specification 4.8.D.5.b.2 required verifying the control room isolation dampers
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close following a simulated automatic isolation signal.
Contrary to the above, from April 16,1985, to December 14,1996, the licensee did not l
verify the automatic closure of the control room ventilation dampers as required by TS l
4.8.D.5.b.2.
1' This is a Severity Level IV violation (Supplement I).
REASON FOR VIOLATION:
i The root cause of this event was a cognitive personnel error in that credit was taken for a technical specification (TS) requirement by a procedure that did not contain steps to satisfy the technical specification requirement. Procedures QCOS 1600-13, " Refueling Outage PCI Group 2 and 3 Isolation Test," and QOS 5750-03, " Manual Isolation of the Control Room Ventilation Systems," test a majority of the relays associated with the Control room isolation dampers. There was no surveillance that verified that relay CR4 operated upon actuation of relays 1-7541-51,1-7541-52, 2-7541-53, or 2-7541-54.
Technical Specification 4.8.D.5.b.2, which requires verification that the control room HVAC isolation dampers close on a simulated automatic isolation signal, was implemented on September 23,1996, as part of the Technical Specification Upgrade program. The Quad Cities Nuclear Power Station (QCNPS) concurs with the violation from the implementation date of the upgraded Technical Specifications, September 23, 1996, until the date of relay testing, December 14,1996.
Prior to September 23,1996, the TS did not require verification that the control room HVAC isolation dampers close on a simulated automatic isolation signal, and did not require a system functional test. QCNPS does not believe that there was a violation of Technical Specification requirements prior to the implementation of the upgraded Technical Specifications on September 23,1996.
ATTACHMENT A ESK-97-065 (Page 4 of 5)
ACTIONS TAKEN:
Interim Procedure 96-0194, " Control Room HVAC Isolation Logic Test," was initiated and performed to verify that the CR4 relay and the Control Room HVAC isolation dampers operated correctly. This procedure was successfully performed on December 14,
- 1996, t
QCOS 1600-13 was revised to test the logic circuit to verify closure of the CR HVAC isolation dampers upon receipt of a Primary Containment Isolation (PCI) signal. This was completed on February 19,1997.
A review of all new or modified surveillances conducted prior to the implementation of the upgraded Technical Specifications was performed. This review was completed on January 22,1997.
A review of the upgraded Technical Specification changes that would require a change in surveillance performance methods was performed. This review was completed on January 22,1997.
ACTIONS TO PREVENT FURTHER OCCURRENCE:
The following corrective actions are scheduled to be implemented as a result of the investigation of this event, as documented on Problem Identification Forms (PIF) 96-3413 and 96-3441:
- 1. Awareness training at Engineering meeting (s) will be conducted to ensure that the System Engineers understand that surveillances must satisfy the literal interpretation of the technical specifications. This will be completed by March 31,1997.
(NTS # 254-201-96-341303)
- 2. A training request (TR) and an accounting of the control room HVAC damper event has been submitted to the Curriculum Review Committee (CRC). The CRC will evaluate the event and root cause, determine if additional training is needed, and provide training as required. This will be completed by November 21,1997.
(NTS # 254-100-96-02003.01)
ATTACHMENT A ESK-97-065
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-(Page 5 of 5)
- 3. An evaluation of the control room HVAC Technical Specifications has been performed. The issues identified in this review are being tracked to completion. The l
Problem Identification Form (PIF) and Nuclear Tracking System (NTS) numbers are as follows:
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PIF 97-0557 j
PIF 97-0558 l
PIF 97-0560 l
NTS 254-201-96-344101 i
NTS 254-201-96-344102 l
NTS 254-201-96-344103 l
NTS 254-201-96-344104 i
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DATE WHEN FULL COMPLIANCE WILL BE MET:
. Full compliance was met with the completion of the revision of QCOS 1600-13 on Febmary 19,1997.
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