ML20148Q837
| ML20148Q837 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 03/29/1988 |
| From: | Turbak M COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 4422K, NUDOCS 8804140004 | |
| Download: ML20148Q837 (10) | |
Text
c '^ x Commonwealth Edison I
) One Fir 1 Natonal Ran CNcago. IRinc:s hL e.
(
7 A~ddress Reply to. Post OffETBox 7C Chicago, litnois 60690 0767 j
March 29, 1988 Mr. A. Bert Davis Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Quad Cities Station Units 1 and 2 Response to IE Inspection Report Nos. 50-254/87033 and 50-265/87033 NRC Docket Nos. 50-254 and 50-265 Reference (a): Letter from V.L. Forney to Cordell Reed dated February 25, 1988.
Dear Mr. Davis:
This letter is in response to the inspection conducted by your staff during the period December 6, 1987 through February 6, 1988, of certain activi-ties at Quad Cities Station. The referenced letter indicated that certain activities appeared to be in noncompliance with NRC requirements and required a written responre. Commonwealth Edison verbally requested and received a one-Jay extension from Mr. M. Ring of your staff on March 28, 1988. The ccem nwealth Edison Company's response to the Notice of Violation is provided in Attachment A.
Your staff also identified deviations from past licensee commitments.
The commonwealth Edison Company's response to the Notice of Deviation is provided in Attachment B to this letter.
If you have any further questions regarding this matter, please contact this affice.
Very truly yours, H. S. Turbak Assistant Nuclear Licensing Manager 1m Attachment A:
Response to Notice of Violation B:
Response to Notice of Deviation i
ec: NRC Resident Inspector - Quad Cities UMSOW3 F904140004 000329 PDR ADOCK 05000254 O
d a
6.
E i
ATTACHMENT A COMMONWEALTH RDISON COMpAFY RBSPONSE TO NOTICE OF VIOLATION As a result of the inspection conducted on December 6, 1987, through February 6, 1988, the following violation was identified.
j ITEM OF VIOLATION 4
~
Technical Specification 6.2 requires that procedures he adhered to during preventive and corrective maintenance operations.
i j
contrary to the above, station procedure QIp 5700-2, "Filling procedure for the chlorine Analyzer probe," which cautions that a control room isolation will occur during this procedure and that the control room should be notified, was not followed on February 1, 1988, resulting in an unexpected ESF actuation.
This is a Severity Level V violation.
Discussing 4
i i
License Event Report (LER) 254/88-005, Revision 00, provides details l
of this event. A brief description of the event scenario is provided below:
On February 1, 1988 Unit One and Unit Two were in the RUN mode at 95 j
percent and 100 percent of rated core thermal power respectively. At 0739 hours0.00855 days <br />0.205 hours <br />0.00122 weeks <br />2.811895e-4 months <br />, the control room ventilation isolated (changed to 100 percent l
recirculation) as indicated by alarms received in the control room.
An l
Equipment Operator (EO) was immediately dispatched to the standby ventilation room to investigate.
Upon arrival, the Eo found an Instrument Mechanic (IM) adding electrolyte solution to the control room toxic gas analyzer chlorine t
i probe. Operating Department personnel were not aware that this activity was being performed.
I i
I I
THE REASON FOR THE VIOLATIOW
]
Filling the chlorine analyzer probe is addressed by procedure QIp 3
5700-2, "Fillines Procedure for the chlorine Analyzer probe." This procedure l
precautions that filling the probe will result in e control room ventilation isolation and has a precaution to notify the control room of the intent to perform this procedure. The mechanic was not using the procedura l
i
)
i l
. The violation was due to inadequate communication and work
. instruction during the job assignment.
The mechanic performing the work was not aware of procedure QIP 5700-2.
The foreman assumed the mechanic was familiar with the procedure and did not discuss it with hla. As a result, the procedure was not followed and the Operating Department was not informed of the work.
If the Operating Department had been aware of this work, the Lntrol Room Ventilation isolation would have been a preplanned event.
THE CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The Instrument Mechanic (IM) and the IM Poreman involved in this event are now aware of the existence and the requirements of station procedure Q1P 5700-2, "Filling Procedure for the Chlorine Analyzer Probe." This event along with the requirements of QIP 5700-2 are scheduled to be discussed at the Parch 31, 1988 Instrument Maintenance Tailgate Meeting. This training will be documented and all Instrumert Mechanics and all IM roremen will participate.
THE CORRECTIVE STEPS VHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The Training Department will incorporate specific training on this event and the requirements of QIP 5700-2 into their Continuing Instrument Maintenance Training Program. This ongoing training, once established, should prevent recurrence.
THE DATE WHEN FULL COMPLIANCE WILb BE ACHI M The tailgate meeting training will be performed on March 31, 1988.
The Trainino Department will incorporate the new training material into the Continuing Instrument Maintenance Program by May 30, 1988. Once the Training Depertment has completed this, full compliance will be achieved.
44?tK
ATTACHMENT B COMMONVE.4LTH EDISON COMPANY RESPONSE TO NOTICE OF DEVIATION As a result of the inspection conducted on December 6, 1987 through February 6, 1988, the following deviations were identified:
ITEM OF DEVIATION 1.
As stated in 10 CFR 50.55 a(g)(6)(ii), "the Commission may require the licensee to follow an augmented inservice inspection program for systems and components for which the commission deems that added assurance of structural reliability is necessary." IE Bullatin 85-03 (IEB) required that licensees develop and implement a program by November 15, 1987, to casure that valve operator switches are selected, set and maintained prop /rly for motor-operated valves in the HPCI, Core Spray acA RCIC systems that are required to be tested for operational readiness in accordance with 10 CFR 50.55 a(g).
In responses to IE Bulletin 85-03 dated May 15, 1986, and April 24, 1987, the licensee described a program and schedule to satisfy IEB 85-03 by November 15, 1987.
Contrary to the above, the licensee did not notify the NRC until November 24, 1987, that Quad Cities had not complied with the requirements of IE Bulletin 85-03 and would not be in compliance until the April 1988 refueling outage. The failure to comply with the requirements of IE Bulletin 85-03 within the specified time frame and the failure to inform the NRC af this fact prior to the required compliance date are together considered a Deviation from the licensee's commitment.
REASON FOR DEVIATION AND DISCUSSION On November 15, 1987, Quad Cities station was to have developed and implemented a program to ensure that valve operator switches are selected, set and maintained properly for certain motor-operated valves in accordance with the requirments of IE Bulletin 85-03.
Commonwealth Edison deviated from this schedular commitment and did not inform the NRC in a timely manner.
Commonwealth Edison submitted the supplemental response and revised schedule for the Bulletin on November 24, 1987. The delay of Commonwealth Edison's response was detailed in a W. E. Morgan to A. B. Davis letter dated December 23, ?>87.
The letter described the status of Commonwealth Edison's progress towards fulfilling the requirements of IE Bulletin 85-03.
The supplemental response stated that:
"the ti:aliness of the supplemental response was questioned.
Commonwealth Edison believes that this is a unique situation.
The large scope of this Bulletin coupled with the number of plants has resulted in a large undertaking. We apologize for arf inconvenience this may have caused."
j
.. The first item of deviation pertains to the fact that the NRC was not notified regarding the schedule change till November 24, 1987 (approximately nine days after the originally committed completion date for procedure development and implementation).
It is commonwealth Edison's belief that this deviation from a licensee commitment was due to a misjudgement on the part of the Nuclear Licensing Administrator regarding the treatment of internal versus external commitments.
IB Bulletin 85-03 has a large scope of worP nd detailed activities associated with its completion.
In the course of ei! lts to comply with the Bulletin, there have been several schedule chrages associated wJth certain IE Bulletin 85-03 activities. These changes, however, did not impact the overall schedule for completion and hence, were not necessarily reported to the NRC prior to the originally projected dates. These internal changes in sched'J1e were documented in a [[letter::05000254/LER-1987-006-08, :on 870403,HPCI Sys Inoperable.Caused by Loose Soldered Connection on Solenoid Valve Coil SV-8.Solenoid Coil Replaced & HPCI Turbine Remote Reset Verified.Solenoid Valves SV-8 & SV-12 Replacement Planned|April 24, 1987 letter]] from M.S. Turbak to A.B. Davis which was transmitted to the NRC for information.
Commonwealth Edison was cognizant of the November 15, 1987 commitment date, however, the Nuclear Licensing Administrator did not recognize that internal schedule changes could be treated differently than external commit-ments to such organizations as the NRC.
It is believed that the importance of this commitment date was overshadowed by an attempt to have a coordinated, complete response for all Ceco stations on IE Bulletin 85-03.
All energies went into this effort and focus was lost of the importance of external commitments and keeping the NRC informed of potential schedule changes.
The second itt.N of deviation pertained to failure to comply with the requirements of IE Bulletin 85-03.
Commonwealth Edison experienced schedular difficulties due to a number of factors.
The most recent Unit 2 refuel outage started in October 1986. The first three months of this particular refuel outage were utilized in getting MOVATS on the Approved Bidders List (ABL) so IE Bulletin 85-03 commitments could be met.
In January, 1987, MOVATS was placed on the A.B.L.
The Unit 2 outage enabled Quad Cities to MOVATS test 7 out of the 12 total Unit 2 Bulletin valves. Due to the lack of guidelines from Corporate Engineering, adjustments to torque switch and open torque switch bypass limits were not made during this particular refuel outage.
These guidelines were issued prior to an unplanned Unit 2 extended maintenance outage. This maintenanc? outage allowed five valves not originally MOVATS tested to be tested. Three of the original seven valves MOVATS tested were retested before Unit 2 was brought back on-line.
Four of the seven valves originally MOVATS tested need torque switch and bypass switch adjustments before the Unit 2 IE Bulletin 85-03 commitments can be met. The Unit 2 IE Bulletin 85-03 valves will meet all commitments before Unit 2 comes back on-line, after the next Unit 2 refuel outage (scheduled to start in April, 1988).
l
o
.. Unit 1 is currently in a refuel outage scheduled to end in December, 1987. This particular refuel outage is the first Unit 1 outage since MOVATS has been on the ABL.
MOVATS testing of nine (9) Unit 1 vasves has been completed. These nine valves tested meet I.E.Bulletin 85-03 commitments.
Three Unit i valves need maintenance before testing can resume. The mainten-ance and testing of these three valves will be completed by December 10, 1987.
All of the Unit 1 Bulletin valves will meet commitments before the Unit 1 outage ends in December, 1987.
The procedure for setting thermal overloads can be implemented onsite. The procedures for setting torque switch, limit switch and limit bypass switches have not yet been implemented.
The Station has contracted out MOVATS to perform their MOV "Insights" program, which includes a thoroujh review of the stations existing procedures and solicits comments and recommen-dations for improvements. A copy of tne "Insights" final document has been distributed to station personnel for review.
Due to the current Unit I refuel outage, personnel will be unable to complete this review until the end of the Unit 1 refuel outage. The procedures for retting torque switch, limit dwitch and limit bypass switches will be implemented by March 31, 1988.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED With respect to the first item of deviation, Units 1 and 2 were able to complete actions required by of the IE Bulletin 85-03 by the NRC formal summary report committent date on January 15, 1988 due to an unscheduled Unit 2 maintenance outage. The procedure revisions that were required to be done were completed by January 31, 1988 which was accepted by the NRC (Reference W.E. Morgan to A. B. Davis letter dated December 23, 1987).
hith regards to the notification issue, the Commonwealth Edison Licensinc Departnent informed the NRC of the slipped commitment date once the significance of the external commitment was recognized (Letter from W.E.
Morgan to A.B. Davis dated November 24 1987).
CORRECTIVE ACTION TAKEN TO AVOID FURTH.A DEVIATIONS In response to the first item of deviation, the Quad Cities valve maintenance and testing program is now established. The emphasis will now be on improving and developing new techniques for better evaluating the Motor Operated Valve program that is currently used.
In order to stress the importance of external commitment dates and prompt notification to NRC regarding commitments, the Nuclear Licensing Manager will issue a memo to All Department personnel tugarding the circum-stances surrounding this deviation. The memo will explain the need to keep the NKC informed of any potential licensing commitment deviations. This shoulu preclude repetition of such deviations in the future. The memo will be issued by May 1, 1988.
.. DATE WHEN PULL COMPLIANCE VILL BE ACHIEVED Quad Cities Station had met the revised schedular requirements of the IB 85-03 Bulletin on January 31, 1988. The revision of procedures was implemented by this NRC commitment date. Therefore, Quad Cities is no longer in deviation of this commitment.
Procedure revisions and valve testing has been completed and it is believed that the intent of the Bulletin has been met.
The station is awaiting final NRC approval of the Quad Cities specific program.
Full compliance on the notification issue will be achieved on May 1, 1988 with the issuance of the Nuclear Licensing Manager memo.
l 1
4422K
.. ITEM OF DEVIATION 2.
In the FSAR the licensee commits to the ASMS code which requires that supports for safety system components adhere to seismic criteria.
Contrary to the above, on December 19, 1987, commonwealth Edison's BWR Engineering concluded that the ATWS (Anticipated Transient Without Saram) support hangers for *.he reactor vessel instrument racks on Unit 1 (racks 2201-5 and 6) and Unit 2 (racks 2202-5 and 6) did not meet ASME code requirements for seismic support, though they did meet operability requirements. This problem was discovered on December 1, 1>87, by the Senior Resident Inspector.
This is considered a Deviation from the licensee commitment.
DISCUSSION License Event Report (LER) 254/87-030, Revision CO, provides details of this event. A brief description of the event scenario is provided below:
On December 19, 1987 Quad Cities Unit I was in the SHUTDOWN mode at 0 percent power and Unit 2 was in the RUN mode at 100 percent power. At 1950 hours0.0226 days <br />0.542 hours <br />0.00322 weeks <br />7.41975e-4 months <br />, it was determined that the Units 1 and 2 Anticipated Transient Without Scram (ATWS) instrument sensing line supports were inadequate and did not meet Final Safety Analysis Report (FSAR) design criteria. The Unit 1 ATWS piping supports were modified prior to restart from its refuel outage.
Unit 2 ATWS piping supports were evaluated to meet operability requirements and continued operation was justified.
THE REASON FOR THE DEVIATION The cause for this event can be attributed to cognizant personnel error and inadequate design. Modification M 4-1(2)-79-002 was initiated to electrically and mechanically install the ATWS recirculation pump trip (RPT) j and the alternate rod insertion (ARI) systems. The modification included the installation of Rosemount pressure and level transmitters and associated piping, valves and tubing; analog trip system and units; and recirculation motor-generator field breaker trip coils.
The modifiaction also included installation of hangers to support the instrument piping near the 2201(2)-5 and 6 racks. The original design was to support the lines from the ceiling using a simple rod and clamp configuration, taking only dead weight load into consideration as shown on drawings M-953, 954, 956 & 957. However, after further evaluation, it was determined by the Station (in a letter dated August 4,1981) that the preferred means cf restraint would be to use floor and/or wall mounted supports, because of easier installation.
Since the original hanger support design was inadequate, temporary supports were installed unti.1 the design problem was resolved. However due to a personnel error, the modification test was signed off withcut having the supports installed. As a result, a new design was not issued and the proper supports were not installed prior to declaring the modifications operational.
o THE CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Immediately after it was discovered that the ATWS sensing lines required the installation of supports in order to make the system meet FSAR requirements, Modification M 4-1(2)-87-72 was initiated. On December 22, 1987, Modification M-4-1-87-72 installation was completed and made operational prior to Unit I startup from the refuel outage. Completion of this modification brings the Unit 1 ATWS piping in compliance with the FSAR design requirements.
Engineering has been performed to determine what repairs are needed to ensure the Unit 2 ATWS sensing lines are within FSAR design limits.
Modification M-4-2-87-72 will then be completed during the Spring 1988 Unit 2 refuel outage.
As an additional corrective action, Technical Staff personnel will be performing a walkdown of the following modifications that deal with hanger installation as a measure to assure that other systems are not operating without the proper hanger supports installed.
Modificaticn Description M 4-1(2)-76-023 Atmospheric Containment Atmosphere Dilution (ACAD)/ Continuous Air Monitor (CAM)
M 4-1-80-003 Installation of seismic supports for Target Rock safety relief valve air line M 4-2-80-004 Modification of Moisture separator Drain Tank drain line hangers 2-3510-H25 and 2-3511-H35 M 4-1(2)-80-012 High Radiation Sample System M 4-1(2)-80-022 Installation and upgrade of supports for various safety related motor control centers (MCC),
instrument racks and switchgear i
M 4-1-81-017 Installation of additional supports on the Control Rod Drive (CRD) insert and withdraw lines M 4-2-82-001 Modification of the Reactor Water Cleanup (RWCU) system pipe hanger 2-1202-H7 M 4-1-82-043 Addition of RWCU valve (1-1201-173)
M 4-1-82-048 Suppression Chamber level sensing lines This effort by the Technical Staff will be tracked with Nuclear Tracking System (NTS) number 2542008711601.
4 w
..- THE CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER DEVIATIONS To prevent recurrence of deviations of this nature, BWR Engineering now requires a dimensional verification be performed by a certified quality control inspector for all Safety Related modifications involving the instal-lation or modification of Safety Related load carrying members. Resolution of deficiencies will be accoiaplished before the modification test may be signed off as completed. This is part of the new modification program which was implemented in April 1987.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The Unit 1 ATWS piping support modification was completed on December 22, 1987. The Unit 2 ATWS piping support modification will be completed by prior to the Unit 2 restart.
The walkdown of past modifications that dealt with hanger installation will be completed by the end of the next Unit I refuel outage. The next Unit I refuel outage is scheduled to be completed by September 30, 1989. At this time, full compliance will be achieved.
4422K