ML20149E593

Responds to NRC Re Violations Noted in Insp Repts 50-254/87-25 & 50-265/87-25

ML20149E593
Person / Time
Site:	Quad Cities
Issue date:	12/22/1987
From:	Turbak M COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8801130397
Download: ML20149E593 (3)

Text

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. T' Commonrealth Edison

' ' ' * ) One First Nateal Plaza, Chicago, litinois f _> N Address Reply to; Post Office Box 767 Chicago, IDinois 60690 - 0767 December 22, 1987 ,

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 I.E. Inspection Report Nos. 50-254/8725 snd 50-265/87025 NRC Dock,et Nos.80-254 and 50-265 Reference (a): Letter from J. J. Harrison to Cordell Reed dated November 23, 1987

Dear Mr. Davis:

This letter is in response to the inspection conducted by your office during the period September 22, 1987 through November 5, 1987, of certain activities at Quad Cities Station. The referenced letter indicated that certain activities appeared to be in violation of NRC requirements.

The Comonwealth Edison Company's response to the Notice of Violation is provided in Attachment A.

If you have any further questions regarding this matter, please contact this office.

Very truly yours, I N I l  %

M. S. Turbak Assistant Nuclear Licensing Manager df Attachment cc: NRC Resident Inspector - Quad 4016K ('M i '8801130397 871222

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"ATTACHMENT A" COMMONWEALTH EDISON COMPANY RESPONSE TO NOTICE OF VIOLATION As a result of the inspection conducted on September 22 through November 5, 1987, the following violation was identified:

ITEM OF VIOLATION 10 CFR 50, Appendix B, criterion V, as implemented by the Commonwealth Edison Operational QA program, requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances, and be accomplished in accordance with these instructions, procedures, or drawings.

Contrary to the above, Procedure No. QOP 6500-4, which is used in racking-out 4160 volt manually operated air circuit breakers, was inadequate because of the following:

1. The precaution statement in the procedure which stated that opening the racking screw shutter on a closed circuit breaker would trip the breaker was incorrect.

2. The procedure did not caution the operator to verify the position of the open/close indicator prior to proceeding to rack-out the breaker.

3. The procedure did not caution the operator to actuate the manual trip button prior to rack-out of the breaker.

This is considered a Severity Level IV violation.

DISCUSSION:

License Event Report (LER) 265/87-013, Hevision 00, provides details of this event. A brief description of the event scenario is provided below:

On October 19, 1987, Quad Cities Unit Two was in the RUN mode at approximately 90 percent of reactor thermal power. At 1959 hours0.0227 days <br />0.544 hours <br />0.00324 weeks <br />7.453995e-4 months <br />, an Equipment Operator (EO) incorrectly attempted to rack out of service an energized 4 kV circuit breaker on Bus 23. As the breaker was withdrawn, the shutter in the breaker cubicle, which was lowered in the racking out process, came in close contact with the energized breaker stabs causing them to flash to ground. Bus 23 tripped on overcurrent. As a result, a reactor scram and Emergency Core Cooling System (ECCS) initiations and related actuations occurred at 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br />. Reactor water level dropped to approximately -60 inches but was quickly restored. A normal scram l recovery then followed.

.l This violation is a result of a procedural deficiency and this response will specifically address the deficiency. License Event Report (LEH) 265/87-013 documents all corrective actions taken and all corrective actions that are being taken as a result of this event. ,

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1. CORRECTIVE ACTION TAKEN AND RESULTS_ ACHIEVED:

A procedure change request was submitted for QOP 6500-4..the procedure for racking out 4KV horizontal circuit breakers. The revision was '

implemented on October 30, 1987. This revision corrected the precaution statement which stated that opening the racking screw shutter on a l closed circuit breaker would trip the breaker. This statement now reads: "The racking screw shutter on a closed circuit breaker should not open. If difficulty is encountered in opening the shutter, contact a foreman immediately. DO NOT use this as an indication that the breaker is in the cpen position." Also, this revision added a caution and a procedure step for the operator to verify that the breaker indicates OPEN by the light indication and the mechanical indication on i the breaker. After the breaker position has been verified to be OPEN, the procedure instructs the operator to press the trip button at the l bottom of the breaker.

In addition to revising procedure QOP 6500-4, the station has incorporated the use of a magnetic operator aid. In the first atep of procedure QOP 6500-4 the operator is instructed to attach the magnetic i operator aid to the surface of the breaker, but not to the door of the upper cabinet. The magnetic operator aid provides the operator '

step-by-step instructions on how to properly rack out a horizontal 4KV circuit breaker. The magnetic operator aid gives the operator the ability to easily reference the proper steps while wearing the 1 protective clothing used when racking out circuit breakers. Also, this t devise will aid in preventing breaker identifiention errors. l

2. CORRECTIVE ACTIOtLTO BE TA](EN TO AVOID FURTHER VIOLATIONS A similar procedure revision was incorporated into QOP 6500-2, the l procedure for racking out a 4KV vertical circuit breaker. This revision i was also implemented on October 30, 1987. {

This event has been discussed with members of the Operating Department. j specific emphasis was placed on ensuring the correct equipment is

- identified prior to taking any actions. Also, all Equipment Operators ,

i and Shift Foremen have received documented special 4KV breaker training as a result of this event.

3. DATE WHEN FULL COMPLIANCE WILL BE ACHILV]LD, Full compliance was achieved as of the date the procedure changes were implemented, on October 30, 1987. j l

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