ML20236M083
| ML20236M083 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 07/02/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20236M004 | List: |
| References | |
| 50-254-98-09, 50-254-98-9, 50-265-98-09, 50-265-98-9, EA-98-272, EA-98-328, NUDOCS 9807130290 | |
| Download: ML20236M083 (4) | |
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l NOTICE OF VIOLATION Commonwealth Edison Company Docket Nos.: 50-254;50-265 Quad Cities Station, Units 1 and 2 License Nos.: DPR-29; DPR-30 EA 98-272; EA 98-328 During an NRC inspection conducted April 1 through May 29,1998, six violations of NRC l
requirements were identified. In accordance with the " General Statement of Policy and j
Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
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1.
Technical Specification 6.8.A.1 required that procedures recommended in Appendix A of
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Regulatory Guide 1.33, Revision 2, February 1978 be established, implemented and malt?ained.
Regulatory Guide 1.33, Revision 2, February 1978, Appendix A, item 1.c, recommended administrative controls for equipment control (locking and tagging).
Interim Procedure Number 98-0035 " Station Equipment Out-Of-Service," Step 5.2.8, required that all out-of-service sequence changes must be reviewed and approved by two qualified individuals. Step 6.5.1 required that if an out-of-service checklist cannot be competed as written, "The hard copy of the checklist shall then be marked by pen / ink changes with the required isolation point changes, positions and sequences. These changes shall be reviewed and approved by a second qualified individual and both shall sign the checklist."
Contrary to the above, on May 1,1998, Interim Procedure 98-0035 was not implemented l
I when a change was made to Personnel Out-Of-Service Number 98-512 which was not reviewed and approved by a second qualified individual. A step to place " caution rings" on residual heat removal service water pump control switches was deleted with a single line through and initiated.
This is a Severity Level IV violation (Supplement 1). (50-254/98009-01; 50-265/98009-01) 2.
Technical Specification 6.8.A.1 required that procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978 be established, implemented and maintained.
Regulatory Guide 1.33, Revision 2, February 1978, Appendix A, item 1.c, recommended administrative controls for equipment control (locking and tagging).
Quad Cities Administrative Procedure 230-04, " Equipment Out-Of-Service," Revision 20, Section D.2.b.(3), states " Components shall never be operated while an OUT-OF-SERVICE Card is attached."
Contrary to the above, on April 4,1998, Quad Cities Administrative Procedure 230-04 was not implemented when the Unit 1 Refuel Bridge Monorail Hoist Pendant was operated with an out-of-service card for Out-of-Service Namber 980003552 attached.
This is a Severity Level IV violation (Supplement 1). (50-254/98009-02) 9807130290 980702 PDR ADOCK 05000254 G
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' Technical Specification 6.8.A.1 stated ' in part, that written procedures shall be established, implemented and maintained covenng the applicable procedures i
recommended in Appendix A of Regulatory Guide 1.33 Revision 2, February 1978.
j' Regulatory Guide 1.33, Appendix A, item 1.d. " Administrative Procedures," recommended l
that procedures be established which address procedure adherence and temporary change methods.
- Quad Cities Administrative Procedure 1100-12," Procedure Use and Adherence,"
Revision 14, Step D.2.a.(8)(b)(2), stated, in part, that " situations may arise where a l'
. procedure may be perceived as inadequate to perform a given task or evolution. In such j-situations, the supervisor shall resolve the discrepancy in the procedure by submitting a procedure change, either Procedure Field Change, Interim Procedure or permanent, depending on the actual situation. No further procedural steps shall be accomplished until the procedure change is approved."
Quad Cities Electrical Preventive Maintenance Procedure 0200-16, " Inspection and Maintenance of 480 V AK-25 Breakers," Revision 15, Step I.7.b., required workers to L
" apply a light film of Mobil 28 grease to the primary contacts."
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Contrary to the above, on April 16,1998, Quad Cities Administrative Procedure 1100-12,
" Procedure Use and Adherence," Revision 14, was not implemented when licensee personnel did not follow or obtain a change to Quad Cities Electrical Preventive Maintenance Procedure 0200-16, Revision 15, instructions to apply a light film of Mobil 28 grease to the primary contacts. A procedure change request to resolve the procedure.
requirements was not approved before further procedural steps were accomplished.
This is a Severity Level IV violation (Supplement 1). (50-254/98009-03; 50-265/98009-03) 4.
Technical Specification 6.8.A.1 states, in part, that written procedures shall be established, implemented and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Revision 2, Appendix A, Item 1.c. " Administrative Procedures,"
recommends that procedures be established which address equipment control (e.g., locking and tagging).
Quad Cities Administrative Procedure 0230-04," Equipment Out-of-service," Revision 20, Step D.10.b, states, in part, that "before starting work on equipment, the supervisor in ~
charge of the work shall be satisfied that the.... OUT-OF-SERVICE Cards have been placed. In addition, the supervisorin charge of work shall have the responsibility to assure an inspection has been made to see the OUT-OF-SERVICE Cards have been placed correctly and the equipment is safe to perform the work activity."
Quad Cities Administrative Procedure 0230-04, " Equipment Out-Of-Service," Revision 20, Step D.10.c., stated, in part, that "a member of the work crew shall have the responsibility
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of confirming the equipment has been properly isolated and is safe to work on, an L---'_____.__-__..
s n Notice of Violation inspection has verified the OUT-OF-SERVICE Cards have been placed correctly, and their supervisor is logged onto the OUT-OF-SERVICE."
Quad' Cities Administrative Procedure 0230-04, " Equipment Out-Of-Service " Revision 20, Step D.10.d, stated, in part, that "once hung, personnel protection cards may be left hanging for the duration of the job. Prior to beginning of each working shift, however, a member of the work crew shall verify the personal protection card is still in place on the master OUT-OF-SERVICE Card."
Contrary to the above, from April 27 - 29,1998, Quad Cities Administrative Procedure 0230-04, " Equipment Out-Of-Service," Revision 20, was not implemented when, prior to starting work on the traversing incore probe system, the supervisor in charge of the work did not ensure that an out-of-service card had been placed and an j
inspection had been conducted; no worker from the work crew ensured that out-of-
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service cards had been correctly placed; and personnel protection cards were not hung and were not verified to be in place on the master out-of-service card.
This is a Severity Level IV violation (Supplement 1). (50-265/98009-04) 5.
Criterion XVI " Corrective Action" of 10 CFR Part 50, Appendix B, required conditions
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adverse to quality to be promptly identified and corrected.
Calculation Number NED-I-EIC-0038, Revision 0,' dated August 27,1991, identified a condition adverse to quality, specifically, that the combination of errors for scram discharge volume instrumentation could result in exceeding Technical Specification setpoint requirements.
I Contrary to the above, from August 27,1991, until March 1998, the scram discharge 4
volume setpoints were not corrected to account for the combination of errors identified in calculation NED 1-EIC-0038. As a result, the scram discharge volume instrument setpoints ev.ceeded specified Technical Specification values on at least five occasions from 1991 to 1998.
This is a Severity Level IV violation (Supplement I). (50-254/98009-05; 50-265/98009-05).
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Title 10 CFR 50.59(b)(1) requires, in part, that the licensee maintain records of changes to the facility to the extent that these changes constitute changes in the facility as described in the safety analysis report. These records must include a written safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety question.
The Updated Final Safety Analysis Report, Section 9.4.1.2, stated, "The control room area HVAC (heating, ventilation and air conditioning) system for normal conditions includes the following equipment:. A steam humidifier.."
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'i Notice of Violation ;
Contrary to the above, from May 11,1995,. until May 6,1998, a written safety evaluation was not completed which provided the bases for tne determination that a change in the
. facility did not involve an unreviewed safety question. Specifically, the control room steam humidifier had stopped working, was not repaired, and was not planned to be -
restored.
This is a Severity Level IV violation (Supplement I). (50-254/98009-06; 50-265/98009-06)
I Pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
l Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region lil, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each
.. violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level; (2) the corrective steps that have been taken and the results achieved; (3) the corrective steps that will be taken to avoid further violations; and (4) the date when full
. compliance will be achieved. Your response may reference or include previous docketed correspondence,if the correspondence adequately addresses the required response if an -
adequate reply is not received within the time specified in this Notice, an order or a Demand for information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consid9 ration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, 1
DC 20555-0001.
Because your response will be placed in the NRC Public Document Room, to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the NRC Pui)lic Document Room without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and
. provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of
- information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or
. financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
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. Dated at Lisle, Illinois this 2nd day of July 1998 1
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