ML20012A955

Responds to Violations Noted in Insp Repts 50-254/89-26 & 50-265/89-26.Corrective Action:Procedure Qis 47-1 Revised to Include Requirement That Equalizing Valve Be Open During Isolation of Transmitter

ML20012A955
Person / Time
Site:	Quad Cities
Issue date:	02/08/1990
From:	Kovach T COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 9003130093
Download: ML20012A955 (5)

Text

" ' '

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. . / N Cesnmemmeelth Edison

• j

) 1400 Opus Place '

f c t . s ) Downers Crove, Illinois 60515  !

L' \ j j February 8, 1990 l L  !

Mr. A. Bert Davis j Regional Administrat9r  ;

U.S. Nuclear Regulato y Commission  ?

799 Roosevelt Road Region III .

j Glen Ellyn, IL 60137 l J

Subject:

Quad Cities Station Units 1 and 2 f Response to Notice of Violation ,

Contained in Inspection Report l 3

50-254/89026 and 50-265/89026

• L NRC Docket No. 50-254 and 50-25.5  !

i

Reference:

Letter from W.D. Schafer to Cordell Reed dated January 8, 1990 i Mr. Davist  !

The referenced letter transmitted Inspection Report 50-254/89026 and

.50-265/89026 which contained one Notice of Violation (NOV) which cited two .

examples of inadequate procedures. The attached provides Commonwealth Edison  ;

Company's (CECO) response to the NOV. Ceco understands the significance of  !

'the issues involved and the need for effective corrective actions to prevent recurrence.

l Quad Cities Station acknowledges that the Quad Cities Station

. Procedures are in need of improvement. In response to the NRC as well as our .

internal asses 6ments, Quad Cities Station is. currently in the process'of a major procedure upgrade program. The program entails upgrading approximately i 4300 Station Procedures to improve the technical as well as human factor

l. aspects of the procedures. The program will be completed by 1996 and Quad

~'

l. Cities Station believes that this substantial economic and hunian resource commitment will provide substantial benefits to all aspects of plant operation..

l Please direct any questions or comments on this response to R. Stols -

at extension 7283.

Yours very truly, l'

( ,

. J. ,ovach 9003130093 900208 Nuclear Li nsing Manager ADOCK 050002p4

{DR pdc Attachment @ 0\

cet L. 01shan J. Hind (Region III) h l

Senior Resident Inspector gg g 0658T i

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. ATTACMENT A CECO RESPONSE TO NOTICE OF VI01ATION l I.R. 50-254/89026; 50-265/89026 l

1. 10 CFR Part 50 Appendix B, Criterion V, states that activities affecting ,

quality shall be prescribed by documented instructions, procedures, or '

drawings of a type appropriate to the circumstances. '

Contrary to the above,

]

A. An activity affecting quality was not adequately prescribed by  ;

documented procedure in that the Excess Flow Check Valve Surveillance -

procedure. QIS 47-1, did not specify the valving sequence for '

returning a level trcnsmitter to service. Consequently, on November 5, 1989, an ESF actuation was generated while returning the 1-263-58B .

reactor vessel level transmitter to service (254/89026-01a).

B. An activity affecting quality was not adequately prescribed by  !

documented procedure in that the out of service procedure for preparing the 1A 24/48 volt battery discharge test did not properly sequence the realignment of the batteries. Consequently, on November

'17, 1989, the A and B neutron monitoring instrumentation panels were  ;

simultaneously de-energized, resulting in the loss of power to both divisions of the intermediate range monitors and a reactor scram

( 254/89026-Olb ) . t Together these are considered a Severity Level IV Violation.

EXAMPLE (A)

An activity affecting quality was not adequately prescribed by documented procedure in.that the Excess Flow Check Valve turve111ance procedure. QIS <

47-1, did not specify the valving sequence for returning a level transmitter +

to service. Consequently, on November 5, 1989, an ESF actuation was generated while returning the 1-263-58B reactor vessel level transmitter to service (254/89026-01a).

DISCUSfi10N On November 5, 1989. Unit One was SHUTDOWN for the Refueling Outage.

Activities in progress included the Reactor Vessel Hydrostatic Test and QIS l

47-1, Excess Flow Check Valve Surveillance. During the performance of QIS 47-1, the Control Room Operators received several Half Group II and III isolations, which were reset immediately. At 1745, a Half Group II and III isolation was received; however, the Operators were unable to reset this Half Group II and III isolation. The Operators attempted to contact the Instrument Mechanic performing QIS 47-1, but, were unable to contact the Instrument j Mechanic prior to the receipt of the full isolation signal. Procedure QIS 47-1 does not require that a direct communication link be established during the conduct of this surveillance.

• m f .4 The cause of the Half Group II and III isolation is suspected to be due to a

-leaky isolation valve on the'l-263-5BA transmitter. The Full Group II and;III-isolation signal occurred due to the pressure drop which was sensed as a differential _ pressure by the 1-263-58A level transmitter. The transmitter was initially isolated at a higher reactor pressure and during the course of the hydrostatic test, reactor pressure was subsequently reduced. When the 1-263-58B level transmitter isolation valves were opened to return the transmitter to service, the reduction in reactor pressure was sensed by the transmitter.which subsequently spiked downscale. The full isolation could <

have been avoided if the instrument was returned to actual reactor pressure prior to returning the instrument back in service.

. Training for the Instrument Maintenance Department includes the process of valving in and out various types of transmitters. Procedure QIP 100-1 Opening

- Of Process Instrument Lines gives instructions for the valv!ng of transmitters. The instructions are included in the specifiu procedure used in a system-test that requires an instrument calibration. The purpose of QIS )-

47-1 however is not to calibrate the transmitters but to test the excess flow check valves. .This requires that the instrumentation be valved out only to the extent needed to test the excess flow check valves. Because of the suspected problem with the leaky isolations valve on the 1-263-5BA transmitter and the subsequent half Group II and III isolation, Quad Cities Station agrees that adequate. caution was not provided in procedure QIS 47-1.

ACIl0ER_IAKE TO CORRECT THE DEFICIENCI ,

The Group II and III isolations were subsequently reset. The conduct of QIS 47-1 was stopped. At 1855 hours0.0215 days <br />0.515 hours <br />0.00307 weeks <br />7.058275e-4 months <br />, the system was returned to normal operating -

status.

CDERECTIVE ACTIONS TAKEN TO PREVENT FURTHER NON COMPLIANCE

1. Work Request Q79747 was initiated to perform a static pressure test on

-level-transmitter 1-263-58A to determine if the isolation valve is leaking. This will be performed during an outage of sufficient duration to allow for this static pressure test to be performed.

2. Proceduro QIS 47-1 will be revised to include the requirement that the equalizing valve be open during the isolation of the transmitter. This will ensure that a differential pressure is not created. This will be completed by March 1, 1990.

3. A comprehensive review of the Reactor Vessel Hydrostatic Test and QIS 47-1 will be performed to determine if sufficient guidance to prevent such a recurrence is provided. This review will include the requirements for communication. This will be completed by March 1, 1990.

4. Training will be conducted with the Instreuent Mechanics on the revisions to QIS 47-1 and the Reactor Vessel Hydrostatic Test by April 1, 1990.

DATE_WHEN FULL C0tiELIANCE WILL BE_ACHIEEED

. Full. compliance was achieved on November 5, 1989 at 1855 hours0.0215 days <br />0.515 hours <br />0.00307 weeks <br />7.058275e-4 months <br /> when the affected systems were returned to normal operating status.

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e EKAMPLE (11-s:

,i. An activity affecting quality was not adequately prescribed by documented procedure in that the out of service procedure for preparing the 1A 24/48 volt battery.for its discharge test at the conclusion of the IB 24/48 volt battery discharge test did not properly sequence the realignment'of the batteries.

Consequently, on November 17, 1989, the A and B neutron monitoring instrumentation panels were simultaneously de-energized, resulting in the loss of power to both divisions of the intermediate range monitors and a reactor i scram ' (254/89026-Olb ) .

D_lSC11SRION -

On November 17, 1989, Unit One.was in the REFUEL mode. The 24/48-volt direct current battery discharge test for the "1B" battery had been completed. The 24/48 VDC distribution center was configured such that the 1A and 1B l distribution panels, which power the neutron monitoring systems, were powered by the:"1A" battery charger.-

m An out of- service request was initiated to configure the system to provide for charging the 1A Battery and allow the battery to be charged with the loads

disconnected. The Out'of Service sequence was developed by the Test Director utilizing'the appropriate electrical 4E print. The Out of Service Sequence was then reviewed and approved by the Operations Department.

i During the implementation of the Out of Service Sequence, the 1A main feed to othe 1A and IB distribution panels was tripped prior to restoring power to the ,

1B' distribution panel utilizing the 1B main feed. This resulted in the de-energization of the A and B neutron monitoring instruments which resulted

.in aL full scram at 1324 hours0.0153 days <br />0.368 hours <br />0.00219 weeks <br />5.03782e-4 months <br />. -

The root cause of the event was personnel error in that the out-of-service

~

sequence wae not properly prepared and reviewed. A contributing cause was the

i use of the Out of Service procedure in place of a temporary procedure change to the IB battery discharge test procedure. The personnel involved with the preparation and validation of the Out-of-Service did not perform an adequate review of the system configuration.

. ACTIONS TAKEN TO CORRECT THE DEEICIENCY l I

Power to the IA and 1B distribution panel was restored at 1326 hours0.0153 days <br />0.368 hours <br />0.00219 weeks <br />5.04543e-4 months <br /> and the I scram signal was subsequently reset.

i CQRRECTIVE ACTIONS TAKEN TO PREVENT FURIHER NON COMPLIANCE

1. A tailgate session will be conducted with Operating personnel to review this event and on the use of a temporary procedure to cover this  ;

realignment of the batteries instead of an Out of Service request. In addition, this event will be discussed in modification / lessons learned training which will be completed by March 31, 1990.

2. A tailgate session discussing this event will conducted with the Technical Staff. The tailgate will be conducted by February 2, 1990.

'3. The battery diacharge test will be reviewed for adequacy by March 2, 1990.

o y

%( ',0j . b 4-4.- The RPS andl essential service bus procedures will be reviewed to ensure -

their adequacy'in 116 h t of this event. The review will be completed by q- April 15, 1990.-

DATE WHEN FULL _CQtiELIANCE WILL BE ACHIEVED Full compliance was achieved on November 17, 1989 at 1326 hours0.0153 days <br />0.368 hours <br />0.00219 weeks <br />5.04543e-4 months <br /> when the scram signal was reset.

GENERAL DISCUSSION OF INADEOUATE PROCEDURES Quad Cities Station has recognized that the Station procedures currently in use are not' consistent with current industry practices. In 1987, Quad Cities initiated a Maintenance Procedure Upgrade Program which was later expanded to-include,all Station Procedures.

In June, 1989, Quad Cities Station issued a Procedure Writer's Guide which is a key. element to the effective implementation of the Procedures Upgrade Program. The guide was developed utilizing the criteria contained in INPO 85-026, Writing Guidelines for Maintenance and Calibration Procedures Used in Nuclear Power Plants.

Administrative Procedures have also been developed delineating the criteria for the review',~ verification and validation of the upgraded procedures. QCAP 1100-6 Procedure Validation, and QCAP 1100-4, Procedure Revision, Review and Approval, are currently being reviewed. Seventy-five (75)' procedures have been written under the new program and will undergo review following the approval of the two administrative procedures.

The 1990 Goals for the Procedure Upgrade Program have been established and includes an upgrade of the following procedures:

.fs

a. ECCS Operations Procedures

b. . Equipment Loop Surveillance Procedures

c. VETIP Procedures

d. Personnel Exposure Program Procedures

e. Turbine Building Sample Panel Procedures f.- Local and Integrated Leak Rate Testing

g. Organization / Position Description Procedures In addition to these procedures, personnel writing new Station Procedures will be encouraged to develop-these procedures utilizing the new format and criteria. The current goal for the completion of approximately 4300 Station procedures in 1996 is based on an estimate for required resources of 222,000

. manhours. This estimate does not include the manhours needed to review and validate these procedures.

Quad Cities Station believes that the completion of the program will provide substantial improvements to the overall operation of the plant.

'0658T

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