ML20206J518
| ML20206J518 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 11/21/1988 |
| From: | Bliss H COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 5364K, NUDOCS 8811290014 | |
| Download: ML20206J518 (5) | |
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( - ). Commonwealth Edison One Firij Haa>nal Ptars Ch
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Address Reply to: Post OMc3 T76 F e
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0767 November 21, 1988 U.S. Nuclear Regulatory Commission Attn:
Document Control Desk g
i Washin,Jton, DC 20555
Subject:
Quad Cities Station Units 1 and 2
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"Reply to a Hotice of Vlolation NRC l
Inspection Report Nos. 50-254/88015
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and 50-265/88015" 7
N RC Do c k e t N o gd(L-2 54. and _$n-165..
Referedee (a): Letter from A.B. Davis to Cordell Reed dated October 21, 1988.
I Gentlemen i
Reference (a) transmitted an Inspection hvA rt and Notice of Violation f
(NOV) pertaining to an event where the automatic transfer function of a Motor Control Center was not present due to an original construction wiring erra,,r.
Commonwealth Edison is pleased that the NRC acknowledged the entensive corrective actions taken, prior good performsnce in this area, and the prompt l
reportability of this selt' identified Isolated event. As a resu1*,, the Staff has r.ut imposed a civil penalty.
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Attached is a copy of Edison's "Reply to a Notice c. Violation" which
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van prepared in accordance with the instructions in the NOV.
Pleas 9 direct any questions regarding this matter to this office.
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Very truly yours, f
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nry P'.
Blisa I
l 9uclear Licensintj Manager 1m Attachment
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cci A.B. Davis - RIII Administrator
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l T. RoJs - NRR
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Quad Cities Resident Inspector I
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As a res. ult of ths inspection conducted on June 5 through August 6, 1988, the following violation was identified IIEM_Or VIOLATION Technical Specification (TS) 3.5.A.3 requires that the LPCI mode of the RHR system be operable whenever Arradiated fuel is in the reactor vessel and prior to reactor startup from a cold shutdown condition.
From and after the date the LPCI mode of the RHR system is made or found to be inoperable for any reason, TS 3.5.A.5 permits continued reactor operation only during the succeeding seven days (provided other related equipment designated in TS 3.5.A.5 is operable).
If the requirements of TS 3.5.A.5 cannot be met, l
TS 3.:.4.6 requires an orderly shutdown to be initiated and the reactor to be in the cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
i Contrary to the above, as a result of the Motor Control Center's (MCC/28-29-5) Inability to provide automatic transfer for certain situations (large break LOCA concurrent t'ith LOOP and failure of the Unit 2 Diesel i
Generator), the LPCI mode of the RHR system was inoperable from October 1971
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(the time when irradiated fuel was in the Unit I reactor) to June 22, 1988 (the time when the MCC'
- wiring problem was discovered).
During this period the reactor was oper '. > without complying with the ACTICH requirements as describet. in TS 3.5.
and TS 3.5.A.6.
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j DISCUESIDN l
f This event was described in Licensee Event Report (LER) 265/88-023, L
Revision 06 It was also the subject of an enforcement conference held on August 26, 1988. Briefly, on June 22, 1988, Quad Cities Unit 2 was in the SHUTDOWN uode at 0 percent thermal power. While performing a modification test for Modif.lcation M4-4-84-06A, it war discovered that Motor Control Center (MCC) 28/29-5 would not automatically transfer from the Bus 29 feed to the l
Bus 28 feed. Troubleshooting of this problem revealed that a wire was not 4
landed per the approved electrical drawing.
It appeared that the wite was not landed during original construction of Quad Cities Unit 2.
The white I
conductor of cable 12237? did not show any indication of oeing lugged.
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the white conductor was taped to the green conductor of cable 522373. The l'
bundle was labeled as being spare.
The green conductor is a spare per the electrical drawings.
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d After the wire was landed per Work Request 067675, the modification test was completed without discrepancy. NRC notification of this event was completed at 1950 hours0.0226 days <br />0.542 hours <br />0.00322 weeks <br />7.41975e-4 months <br /> to comply with the requirements of 10CFR50.72.
REASONS roR_THE VIOLATION The reasons for the violation aret Ineffective post installation testing at the time of the origina'.
Installation; Inadequate periodic testing of the circuit.
The routine testing performed on this circuit was designed to ensure comp 1)ence with the Technical Specifications and was not intended to test the auxillary power system as a wholw. Therefore, the automatic transfer aspect was not addressed.
t CORRECTIVE _ACTIOllS__TllALilAVE BEEtLTAKEN_AND_. TEE _RESULTS_ACHIEVlD The wire was landed per the drawings and the modification test for Hodification M4-2-88 -06A was successfully completed.
In addition, a visual inspection of similar wiring on Quad Cities Unit 1 and Dresden Units 2 and 3 was performed. No discrepancies were found.
CORRECT 1YE_ACT10 tis _THALMILL_BE_TAKEN TO AYDID_fURTHER_YIOLATIONS To avoid further violation, the operability of the automatic transfer circuit for the LPCI swing MCC will be verified during each refueling outage Existing station procedures QTS 110-1, "Unit 1 Emergency Core Cooling System Simulated Automatic Actuation and Djesel Generators Auto-Start Surveillance,"
and QTS 110-3, "Unit 2 Emergency Core Cooling System Simulated Automatic Actuation and Diesel Generators Auto-Start Surveillance," will be revised to accommodate the testing of the LPCI swing MCC or a new surveillance procedure will be developed.
In action plan has been developed to address issues raised by this event. The action plan is divided into three phases. The flrst phase of the action plan was to review all equipment with auto transfer capabilitled. The review has determined that 27 automatic throwover devices exist, and it has been determined that 18 of these devices are already periodically test 6u.
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circuit integrity for the remaining 9 has been verified.
A formal report war performed by our Architect Er%.neer (A/E) under the direction of our BWR Engineering Department which was submitted to the Station on October 7, 1988.
The surveillance recommendations in the report are summarised belows 4kV Bus 13(23) Main Feed Circuit Breaker 4kV Bus 13(23) Resetve Teed Circuit Breaker 4kV Bus 14(24) Haln reed Circuit Breaker 4kV Bus 14(24) Reserve reed Circuit Breaker Instrument Bus Auto-Transfer Circuit i
The above devices have functioned in the past.
Iloweve r, no documented surveillance tests eslat ldertifying how these circuit were j
tested. Therefore, a one-time test was recommended.
Special tests will be developed to perform this testing.
In addition, the A/E has r0 commended and the Station plans on performing periodic testing of the auto transfer devices for the 1/2 Diesel Generator Vent ran and Tuel Oil Transfer Pump.
Procedures will be developed to require periodic testing of this equipment's auto transfer devices.
The second phase of this plan is being performed to provide additional assurances that all safety related equipeent is being adequately tested under the current surveillance program. The second phase involves listing safety related equipment with parallel start, stop, and control i
features. The A/E is reviewing esisting station surveillances to determine which devices are adequately covered.
A report is expected by the end of November, 1988.
7.ie third phase of this plan is to provide "lessons learned" to all other Edisen nuclear sites.
As already noted, this condition was discovered as a result of a modification test which was developed under the guidance provided in the modification program. This demonstrates the effectiveness of the modification program.
4 DATE WilEN_f1)LL_CaiPLI ANCILMILL_DE.ACil!KVID The rpecial tests identified in Phase 1 of the plan will be developed so that the testing can be completed during each unit's next refueling outage.
The Unit I refuellng outage is currently scheduled for June 1989 and Unit 2 is scheduled for March 1990.
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-4 The procedures ldentified in Phase I as needing to be revised or developed will be completed prior t.o the next refueling outages on each unit.
Any additional surveillance procedure enhancements required by Phase II of the plan will also be completed prlor to the next refueling outages on each unlt.
Phase III (lessons learned) will be completed by December 31, 1988.
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