ML20236Y174

Responds to NRC Ltr Re Violations Noted in Safety Insp Repts 50-254/87-13 & 50-265/87-13.Corrective Actions:Cable Spreading Room Fire Suppression Sys Enhancement Mods Completed & Abnormal Operating Procedures Changed

ML20236Y174
Person / Time
Site:	Quad Cities
Issue date:	09/29/1987
From:	Turbak M COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20236Y176	List: ML20236Y174
References
3625K, NUDOCS 8712110156
Download: ML20236Y174 (7)

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,' . Ccmmonwsalth Edison

n. One First National Plaza. Chicago, Illinois go V Address Reply to: Post Office Box 767 Chicago, Illinois 60690 0767 O l September 29, 1987 l

Mr. A. Bert t Regional Administrator U.S. Nuclear Regulatory Commission Region III l 799 Roosevelt Road (

Glen Ellyn, IL 60137

Subject:

Quad cities Units 1 and 2 Response to Inspection Report Nos. i 50-254/87013 and 50-265/87013 l NRC Docket Nos. 50-254 and 50-265

Reference:

Letter from W. L. Forney to Cordell Reed dated August 25, 1987.

Dear Mr. Davis:

The referenced letter documents the results of a routine safety inspection conducted by Messrs. R. L. Higgins and A. D. Morrongiello on your office on June 7 through August 1, 1987, of activities at Dresden Nuclear Power Station Units 2 and 3.

During the course of that inspection, certain activities appeared to be in noncompliance with NRC requirements. Attachment A to this letter contains our response to the violation.

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

Very truly yours,

\.i 9 W ku &.6 M. S. Turbak Assistant Licensing Manager 1m Attachment cc: NRC Resident Inspector - Quad Cities {I k

3625K 8712110156 870929 PDR ADOCK 05000254 G PDR

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" ATTACHMENT A" j

)i COMMONWEALTH EDISON COMPANY RESPONSE TO NOTICE OF VIOLATION As a result of the inspection conducted on June 7, 1987, through August 1, 1987, the following violations were identified:

ITEM OF VIOLATION

1. Technical Specification 3.12.C.3 requires the establishment of a twice per shift fire inspection when the cable spreading room sprinkler system is inoperable.

Contrary to the above, these fire inspections were not established and no dedicated area inspection occurred from June 12, 1987, at 0000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> to June 16, 1987, at 160S hours with said sprinkler system inoperable.

This is a Severity Level IV violation (254/87-013-01(DRP)). ,

DISCUSSION On June 16, 1987 at 1605 hours0.0186 days <br />0.446 hours <br />0.00265 weeks <br />6.107025e-4 months <br />, Unit One was in the RUN mode at 97 percent power, and Unit Two was in the RUN mode at 100 percent power. The Station Fire Protection Engineer learned that the contractor personnel that had been performing a continuous fire watch in the cable spreading room were dismissed on June 12, 1987 at 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br />. The cable spreading room fire suppression system had been out of service since May 11, 1987 to install suppression system enhancement modifications based on Appendix R concerns. This is reported in Licensee Event Report 254/87-009, Revision O. The contractor personnel had been inspecting the cable spreading room as part of a continuous plant fire watch every 20 minutes. This satisfied Technical Specification 3.12.C.2 which requires inspections twice per shift with an inopersble suppression system. Immediately upon learning that the contractor personnel had been dismissed, the Station Fire Protection Engineer notified the Shift Engineer and the Shift Overview Superintendent that the contracted fire watch had been discontinued sinca June 12, 1987. The Shift Engineer, Shift overview Superintendent and the Fire Protection Engineer then contacted the Shift Foreman who was maintaining the list of operator fire watches. The Shift Foreman identified that the operators were not performing an official fire watch in the cable spreading room. The Shift Foreman immediately went to the cable spreading room to inspect the area for fire and to verify that the backup fire protection was available. The Shift Engineer started a twice per shift fire watch in the cable spreading room by initiating QOS 4100-03 SPRINKLER SYSTEM OUTAGE REPORT.

l During the investigation of this event a computer listing of all entries into the cable spreading room over the twelve shifts between the release of the contractor personnel and the initiation of the operator fire watch was reviewed. It was found that at a minimum, an entry was made into the area every four hours and twice per shift by operators or security personnel on their normal rounds. This meets the requirements of Technical Specification 3.12.C.2 for a "twice per shift" inspection of the area with the sprinkler system inoperable. Numerous other entries were also made by Substation construction and Technical Staff personnel. In  ;

addition, the fire detection system in this area was operational, and backup fire protection for the sprinkler system was still available.

1) Reason For the Violation:

The root cause of this event was insufficient procedural controls over contractor fire watch when they were performing Technical Specification surveillance. Although the cable tunnel fire watch was completely delegated to the contractors, who performed and documented their duties per QAP 1900-16, no mechanism was instituted for the Operating Department to monitor the performance of the surveillance.

Procedures normally used by operating management to monitor and verify the performance of " Operator performed" fire watches did not lend themselves to the contractor fire rounds which took place every 20 minutes. The QOS 4100-03, Sprinkler System Outage Report was partially utilized where it could be applied in tracking the Technical Specification requirement to notify the NRC if the system was inoperable for greater than 14 days. This sheet did have a handwritten message stating, "For Tracking Only - Red Hats (contractors) inspect every 20 minutes", but this was apparently not explanatory enough to flag the contractor's firewatch of the cable spreading room. Of the three Shift Engineers questioned about this outage sheet, two of them understood this sheet was being used to track the 14-day outage reporting requirements only, which had been previously initiated. Therefore, if the original intent of the outage sheet was to close the loop on the cable spreading room firewatch, its purpose had become unclear over the almost five weeks of fire suppression system outage prior to this event.

A contributing cause was poor communications between the fire '

protection and operating personnel.

2) Corrective Steps Which Have Been Taken And The Results Achieved _:

The following actions were taken at the time of detection of this event:

a. A QOS 4100-03, Sprinkler System Outage Report, and a subsequent twice per shift operator performed cable spreading room fire watch were initiated.

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b. The Shift Foreman immediately went to the cable spreading room to perform a fire inspection and to verify backup fire protection was available,

c. The Fire Marshall was contacted to verify that backup fire protection equipment found was adequate.

d. Notifications were made to the Shift Overview Superintendent (Operating Engineer), the Assistant Superintendent of Operating and the Station Manager. Since the NRC Resident Inspector could not be immediately reached, a "for information only" ENS phone call was made.

The cable spreading room fire suppression system enhancement modifications were completed and the outage report and fire watch were terminated on July 7, 1987.

3) The Corrective Steps which Will Be Taken to Avoid Further Violations QOS 4100-16, Fire watch for Non-Technical Specification Systems, is being revised to provide procedural guidance for fire watches to also be performed in accordance with Technical Specification requirements.

There is currently no procedure directing the use of outage reports for Technical Specification fire detection or suppression systems.

The procedure will require that all Technical Specification related fire protection systems outage surveillance be tracked by the Operating Department regardless of who is performing the inspection.

In addition, the outage sheets used to document the required inspections will be revised to clarify what equipment is protected by Technical Specification related systems.

4) Date When Full Compliance Will Be Achieved  !

The revision to QOS 4100-16 and the associated outage sheets has been cubmitted. Following appropriate reviews and approvals, the revised procedure will be implemented. This should be complete by November 1, 1987.

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ITEM OF VIOLATION:

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2. Appendix B of 10 CFR 50 requires that measures be established that control the issuance of documents (e.g. procedures and drawings) and changes thereto. Station procedure QAP 1270-1, Modification Program, requires that procedures and drawings be updated prior to placing the modified equipment back in service.

l l Contrary to the above, station electrical drawings and station procedure l QoA 6900-3, 24/48 VDC System Fail'are for Unit 2 did not reflect the Scram l Discharge Modifications, which were completed and approved for operation l on May 1, 1985.

This is a Severity Level IV violation (265/87013-01 (DRP)).

DISCUSSION:

The scram disebarge volume (SDV), instrument volume, and the instruments for the detection of high level in the instrument volume were modified on each unit. The modification for Unit one was M-4-1-81-21 and was installed and declared operable in May of 1984. The modification for Unit Two was M-4-2-81-21 and was installed and declared operable in May of 1985.

As a result of an NRC inspection conducted from June 7, 1987 through l August 1, 1987 two deficiencies were noted in tea processing of the Unit l Two modification. The station abnormal operating procedure QoA 6900-3, Rev. 5 titled "24/48 VDC System Failure (one or Both Buses)" had been updated to reflect the Unit one modification, but had not been updated for the Unit Two modification. In addition, the key diagram for the Unit Two 24/48 VDC system, 4E-2319, had not been updated to reflect the Unit Two modification.

1) Reason For The Violation:

There were two errors made that resulted in this violation. At the time of the modification installation, the cognizant Technical Staff engineer is responsible for updating station procedures to reflect the modification. While the Technical Staff engineer responsible for this modification did submit procedure changes to twenty-six (26) individual plant procedures and twenty (20) procedure checklists and tables, the abnormal operating procedures for loss of the buses feeding the SDV instruments were not updated. The second error was a failure of the Architect Engineer (AE) to update all of the drawings affected by the modification. The AB, under the direction of the corporate BWR Engineering group (formerly Station Nuclear Engineering Department), has the primary responsibility to update all station drawings to reflect the modification. In this case the AE failed to update the key diagrams for the modification on both units. The Unit one key diagram had been changed under a station drawing change request (DCR), but the Unit Two key diagram for the 24/48 VDC system had not been updated.

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2) Corrective Stepr Which Have Been Taken And The Results Achieved:

A review of the procedures changed as a result of the modifications to the SDvs on each unit was performed. As a result of this review the following abnorm 61 operating procedures were changed to reflect the modification to both units:

QOA 6900-3 24/48 VDC System Failure (One of Both Buses);

QOA C300-1 120/240 VAC Instrument Bus Failure; QOA 7000-1 120 VAC Reactor Protection Bus Failure (On or Both Buses),

i These procedure changes have been implemented as Temporary Procedure (

Changes with permanent changes required.

The drawing identified by this violation (4E-2319) and the associated wiring diagram (4E-2687) have been submitted for a drawing change (DCR) to reflect the modification. In addition, the key diagram (4E-2319) is considered a Critical Drawing at Quad Cities and the hard copy available in the Communications Center was updated to reflect the change.

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3) The Corrective Steps Which Will Be Taken To Avoid Further Violations:

PROCEDURE PROBLEM The error (a failure to perform all required procedure changes), the importance of the abnormal operating procedures, and the consequences  !

l of failing to perform with professionalism and attention to detail I will be discussed at the next Technical Staff training meeting.

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The modification program at all Commonwealth Edison stations has ,

undergone a major revision since May, 1987. Part of that change was a j change to Quad Cities procedures to require a Station Modification checklist, QAP 1270-S10, for every modification and every partial modification. The checklist is divided into 3 parts. In section 6 of part 1 of the checklist, the Technical Staff engineer must list all of I

the procedures affected by the modification. Procedure types such as maintenance, operating, annunciator, and abnormal procedures are listed for consideration. This section of the checklist requires a review and approval by an Operating Engineer. In addition, part 1 of the checklist must be completed prior to the on-site review of the modification prior to installation. The completed part 1 of the Station Modification Checklist is included in the Modification Package e _ . _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ a

at the time of on-site review. This step of listing all affected procedures in the modification documentation prior to installation (including the Operating Engineer's specific approval of the list) should make it much easier to verify that all required procedures are updated at the time of installation. The actual procedure changes are documented as complete in part 2 of the checklist, which must be completed prior to modification testing and on the Modification Installation Record (QP 3.51-7). 4 DRAWING PROBLEM '

A letter has been transmitted from the Station Manager to the BWR Engineering Manager, who is responsible for managing the Architect j Engineers (AE) performing the design work for all engineering assisted i modifications at Quad Cities. The letter transmits a copy of the J violation and explains the role of the AE in assuring that all drawings affected by a modification are updated. In response to the letter from the Station Manager, BWR Engineering is requesting the AE i to review all functional drawings that have been affected by the SDV modification. Special emphasis will be given to the Quad Cities key diagrams. These activities will be completed by October 31, 1987. q Additionally, BWR Engineering will contact the remaining AE's by letter and request them to review and or revise all functional drawings that are affected by a particular modification. This activity will be completed by November 15, 1987.

The new modification program implemented in May, 1987 requires that a project plan be developed for all modifications. During the conceptual design (Project Plan II) the Architect Engineer is required to list all drawings affected by the modification. This document may be discussed at a Conceptual Design Review Meeting at the station and must be reviewed and approved by the station prior to performing the detailed design. This process of listing in the modification documentation all of the affected drawings and requiring a station review and approval will make it easier for the station and BWR Engineering to assure that all necessary drawing changes are completed.

4) Date When Full Compliance Will Be Achieved:

The actions identified above Section 2 bring the station into full compliance with the deficiencies identified in the violation. Some of the actions identified in the Section 3 require follow-up by both station and off-site personnel. It is anticipated that all follow-up actions would be complete by March 31, 1988.

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