ML20212F944

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-254/97-10 & 50-265/97-10

ML20212F944
Person / Time
Site:	Quad Cities
Issue date:	10/31/1997
From:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Pearce L COMMONWEALTH EDISON CO.
References
50-254-97-10, 50-265-97-10, NUDOCS 9711050177
Download: ML20212F944 (3)

See also: IR 05000254/1997010

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_ 0dtober 31. !997

Mr. L. W. Pearce

- Site Vice President

- Quad Cities Station

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Commonwealth Edison Company

22710 206th Avenue North

Cordova,IL 61242

SUBJECT:

NOTICE OF VIOLATION (NRC INSPECTION REPORT NO.

50-254/97010(DRS); 50-265/97010(DRS))

- Dear Mr. Pearce:

,

This will acknowledge receipt of your September 22,1997 letter in response to our August 22,

L1997 letter transmitting a Notice of Violation associated with the above mentioned inspection

report. We have reviewed your corrective actions and have no further questionr, at this time.

These conective actions may be examined auring future inspections.

We find the actions to the violations described in your response to be acceptable. However, the

. dates, listed in your response, under "Date when full compliance will be met" for violat'on -

- 50-254/265/97010-03a(DRS) and 50-254/265/97010-03b(DRS), are June 17,1997 and April

15,1997 respectively. Since the violation involved a lack of appropriate corrective action to -

prevent recurrence, full compliance can not be achieved until the corrective action changes and

training have been completed on March 31,1998. During a telephone conversation on

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October 8,1997, your personnel agreed that March 31,1998, was the appropriate date. No

additional response will be necessary.

Sincerely,

original signed by J.M. Jacobson/for

John A. Grobe, Director

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Division of Reactor Safety

Docket No. 50-254

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- Docket No. 50-265

Enclosure:

Ltr 9/22/97, L. . W. Pearce,

Comed, to US NRC

See Attached Distribution -

DOCUMENT NAME: ~ G:DRS\\QUA97010.TY

(SEE PREVIOUS CONCURRENCE)

_

To receive a co py of thee document. Indicate in the box 'C' = Copy w/o attach /enci *E' = Co)y w/ attach /enci"N*,= No copy

I OFFICE

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OFFICIAL RECORD COPY

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Mr.' L. W. Pearce

Site Vice President

Guad Cities Station

Commonwealth Edison Company

22710 206th Avenue North

Cordova,IL 61242

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SUBJECT:

NOTICE OF VIOLATION (NRC INSPECTION REPORT NO.

50 254/97010(DRS); 50-265/97010(DRS))

Dear Mr. Pearce:

This will acknowledge receipt of your September 22,1997 letter in response to our

August 22,1997 letter transmitting a Notice of Violation asdociated with the above

mentioned inspection report. We hava reviewod your corrective actions and have no

further questions at this time. These corrective actions may be examined during future

inspections.

We find the actions to the violations addressed in your response to be accepteble;

however, tne dates when full compliance will be met which are provided for violation

50-245/265/97010-03a(DRS) and 50-245/265/97010-03b(DRS) are inaccurate. Since this

violation involved lack of appropriate corrective action, full compliance will r.ot be achieved

until changes and training in the revised corrective action methods have been completed.

The completion date stated in the " actions to prevent recurrence" for violation

50-245/265/97010 03a(DRS) and 50 245/265/97010-03b(DRS), is March 31,1998.

During discussions by telephone on October 8,1997, licentee personnel agreed that

March 31,1998, was the appropriate date. No additional response will be necessary.

"

SMeerely,

John A. Grobe, Director

Division of Peactor Safety

Docket No. 50-254

Docket No. 50 265

Enclosure:

Ltr 9/22/97, L. W. Pearce,

Comed, to US NRC

See Attached Distribution

DOCUMENT NAME: G:QUA97010.TY

to receiv e co py of this oocum nt. ino. cat. in in. box c = copy wie attaentend E" = Copy wl.#.ach/end *N' = No copy

OFFICE

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OI FICIAL RECORD COPY

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L. W. Pearce

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october 31, 1997

t cc w/o encl:

R. J. Manning, Executive Vice President,

Generation

M. Wallace, Senior Vice President,-

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Corporate Services

E. Kraft, Vice President, BWR Operations -

Liaison Officer, NOC-BOD

D. A. Sager, Vice Presloent,

Generation Support

D. Farrar, Nuclear Regulatory

Services Manager

1. Johnson, Licensing Operations Manager

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Document Control Desk - Licensing

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Quad Cities Station Manager

C. C. Peterson, Regulatory Affairs Manager

Richard Hubbard

Nathan Schloss, Economist,

Office of the Attomey General

State Liaison Officer

Chairman, Illinois Commerce Commission

J. R. Bull, Vice President, General &

Transmission, MidAmerican Energy Company

Distribution:

' Docket File w/enci -

SRI, Quad Cities w/enci

TSS w/ encl

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PUBLIC IE-01 w/enci

- LPM, NRR w/enci

CAA1 w/enci

OC/LFDCB wlencl

A. B. Beach, Rlli w/ enc!

DOCDESK w/enci

DRP w/enci

J. L. Caldwell, Rill w/enci

DRS w/enci

Rlli Enf. Coordinator w/enct

Rlll PRR w/enci

R. A. Capra, NRR w/enci

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SVP-97 205

September 22,1997

U. S. Nuclear Regulatory Commission

Washington, D. C. 20555

Attention:

Document Control Desk

Subject:

Quad Cities Station Units 1 and 2;

NRC Docket Numbers 50-254 and 50-265:

NRC Inspection Report Numbers 50-254/97010

and 50-265/97010 and Notice of Viola: ions.

. Reference:

(a) J. Grobe to E. S. Kraft, Jr. Letter dated At. gust 22, 1997.

Enclosed is Commonwealth Edison's (Comed's) response to the Notice of Violations

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(NOVs) transmitted with the referenced letter. The report cited three Severity Level

IV violations concerning (a) two (xamples of failure to adhere to design control

requirements (b) one example of failure to perform adequate testing, and (c) two

examples of inadequate correctivo actions.

Responses to the EDG air start motor (ASM) issues are based on an extensive

independent investigation. The station is pursuing a root cause investigation. 'Ihis

respor.se will be supplemented if necessary upon completion of the stations root

cause investigation.

This letter contains commitments. These are identified at the end of each response

se etion.

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SVP-97-205

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September 22,1997

If there are any questions or comments conceming this letter, please refer them to

Mr. Charles Peterson, Regulatory Affairs Manager, at (309) 654-2241, extension

3609.

Respectfully,

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L! W. Pearce

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Site Vice Pres! dent

Quad Cities Station

Attachment A, Response to Notice of Violation

ec:

A. B. Beach, NRC Regional Administrator, Region III

R. M. Pulsifer, NRC Pmject Manager, NRR

C. G. Miller, Senior Resident Inspector, Quad Cities

W. D Izech, MidAmerican Energy Company

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D. C. Tubbs, MidAmerican Energy Company

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F. A. Spangenberg, Regulatory Affairs Manager, Dresden

INPO Records Center

Office of Nuclear Facility Safety, IDNS

DCD - License (Both electronic and hard copy)

M. E. Wagner, Licensing, Comed

SVP Lett:r File

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ATTACHMENT A

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Response to Notice cf Violation -

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STATEMENT OF VIOLATION (NRC IR 97-010);

NOTICE OF VIOLATION 1

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10 CFR 50, Appendix B, Criterion III, " Design Control," requires that measures be

established for the selection and review for suitability of application of pans,

equipment and processes that are essential to the safety related functions of thec

- structures, systems and components.

Contrary to the above, adequate design control mersures were not used for the

following design changes:

a.-

Alternate parts evaluation Q-1997-0023-00, issued April 15, 1997, authorized

the replacement of inodel 150BMPDR89 (model 89) air stan motors on the

Unit 2 (U 2) emergency diesel generator (EDG) with model 150BMPDR88

(model 88) motors as a like-for-like replacement. However, the new model 88

air start motors contained significant dimensional differences from the model

89 motors, thus resulting in a design change. As a result, the U-2 EDG failed

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to start during maintenance verification testir:g on May 8,1997

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(254/265/97010-Ola(DRS)).

b.

Alternate pans evaluation M930030008, issued May 23,1994, authorized the

replacement of residual heat removal beat exchanger relief valve 2-1001-165A,

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Type 1910MC-1-XMC324 (vapor trim), with a Type 1910MC-IXLS324 (liquid

trirn) valve. . The replacement valve type contained documental functional

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differences, including re-closing pressure, from the original valve @, thus

resulting in a design change. As a result, two replacement uives of the vapor

trim type failed to re-close during testing (254/265/97010-Olb(DRS)).

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'Ihis is a Severity Level IV violation (Supplement 1).

REASON FOR VIOLATION:

254/265/97010-Ola

Comed accepts the violt. tion. Alternate parts evaluation Q-1997-0023-00, issued

April 15,1997, was perfonned to evaluate the differences discovered between the original

model 150BMPDR89 air stan motors (ASMs) and the model 150BMPDR88 ASM.' Station

_ personnel did not recognize this as a design chang and failed to correctly implement the

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design control program; In addition, the procedures did not clearly differentiate between

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alternate parts and replacement parts and design changes.

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ATTACHMENT A

Response to Notice cf Violati:n

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ACTIONd TAKEN:

1.

'Ihe model 88 ASMs were removed and vendor supplied rebuilt model 89 ASMs were

installed on June 17,1997 on the Shared EDG and on June 18,1997 for Unit Two

EDG. Following installation of the model 89 ASM, the Monthly Emergency Diesel

Generator Operability Surveillance Test, QCOS 6600-01, was completed satisfactory

for both EDG's.

2.

Other Comed sites were notified of the issue. (NON #Q297-012 062497)

3.

'Ihis event and a clari0 cation of design change definition were provided to

Engineering personnel.

ACTIONS TO PREVENT FURTIIER OCCURRENCE:

Correctiva actions to be completed include the following:

1.

Quad Cities Station will implement Parts Evaluatien Procedure changes by

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November 15,1997. (NTS #25418097SCAQ0000501.01)

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Quad Cities Station will develop a Lessons Larned training package and present it to

Station Engineering personnel and Maintenance supervision by March 31,1998.

(NTS #25418097SCAQ0000501.02)

3.

Quad Cities Station will develop a policy for vendor information evaluatioa by

December 15,1997. (NTS #25418097SCAQ0000501.03)

4.

A Root Cause Investigation on the EDG ASM issue will be completed by

October 31,1997. (NTS #25418097SCAQ0000501)

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DATE WHEN FULL COMPLIANCE WILL BE' MET:

Full compliaxe was met when the model 88 air start motors were removed and vendor

supplied rebuilt model 89 ASMs were installed and tested on June 17,1997 for the Shared

EDG and June 18,1997 for Unit Tv/o EDG.

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REASON FOR VIOLATION:

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254/265/9701401b

Comed accepts the vio!stion. De Station personnel did not adequately evaluate blowdown-

reset ncr identify it as a critical chameteristic as part of the Like for Like parts rr. placement

evaluation CE-89-0725. Station personnel did not recognize that this represented a change in

function and should have been evaluated as a design change.

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ACTIONS TAKFE:

1.-

The original relief valve S/N TH78257 was repaired. - The valve was reinstalled and

tested satisfactorily using the Quarterly RHR Service Water Pump Operability Test,

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QCOS 1000-04.

2.

The Stores Item Number SI 782A29 was removed from the approved list of parts to

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prevent future use of this relief valve in the RHR Heat Exchanger Tbbe Side Relief

Valve application,

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3.

Parts evaluation M930030008 (dated January 13,1993) and M930008-01 (dated

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May 23,1994) were reviewed and marked VOID.

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4.

This event was presented to engineering personnel and a set of design change criteria

was dik:ussed. An interim review group of senior engineering personnel was

established to verify that the criterion are understood and design changes are not

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being performed by Engineering Requests.

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ACTIONS TO PREVENT FURTHER OCCURRENCE:

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Procedure NEP 11-01, " Procurement and Use of Items for Repair and Replacement of

Safety Related and Regulatory Related Equipment" will be revised to include the need

to evaluate blowdown reset pressure wnen specifying relief valves by

Decembsr 15,1997; (NTS #25418097SCAQ0000501.04)

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DATE WHEN FULL COMPLIANCE WILL BE MET:

Full compliance was met on April 15, 1997, when or' in-1 relief valve was repaired and the

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surveillance test QCOS 1000-04 was successfully performed.

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Response to Notice cf Violation

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NOTICE OF VIOLATION 2

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Criterion XI of 10 CFR 50, Appendix B, " Test Control," requires that testing be

' performed to demonstrate that structures, systems and components will perform

satisfactory in service and that the testing be performed in accordance with r/ritten

test procedures which incorporate requirements and acceptance limits. Test results

shall be documented and evaluated to assure that test requirements have been

satisfied.

Contiary to the above:

On May 16,1997, after installation of model 150BMPDR88 air start motors with

mounting shims on EDGs U-2 and U-1/2, the licensee failed to perfomi adequate

testing to ensum that the EDGs would start as required (254/265/97010-02 (DRS)).

This is a Severity Level IV violation (Supplement 1).

REASON FOR VIOLATION:

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254/263/97010-02

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Comed accepts the violation. W new model 150BMPDR88 air start motors were installed

on the Unit 2 atxi the Shared Emergency Diesel Generators. Station pe sonnel used the

alternate parts replacement versus the design change pmcess. Station personnel did not

recognize that installation of Qc new model 150BMPDR88 air start motors was a design

change and required post modification testing in addition to the normal surveillance testing.

ACTIDNS TAKEN:

1.

The model 88 ASMs were removed and vendor supplied rebuilt model 89 ASMs were

installed on June 17,1997 on the Shared EDG and on June 18,1997 for Unit Two

EDO.- Following installation of the model 89 ASM the Monthly Emergency Diesel

Generator Operability Surveillance Test, QCOS 6600-01, was completed satisfactory

for both EDG's.

2.

Other Comed sites were notified of the issue. (NON #Q297-012 062497)

3.

This event was presented to engineering personnel and a set of design change criteria

was discussed. An interim review group of senior engineering personnel was

established to ve."y that the criterien are understood and design changes are not

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being performui by Engineering Requests.

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ATTACHMENT A.

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Response to Notice cf V!olation-

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ACTIONS TO PREVENT FURTHER OCCURRENCE:

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Quad Ci:les Station will clarify the Dedgn Engineering Role in the Parts Evalunion

Process by December 15, 1997. (NTS f'3418097SCAQ0000501.05)

2.

Quad Cities Station will evaluate the requirements for testing in the Altes nate Parts

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Evaluation Process tiy December 15,1997. (NTS #25418097SCAQOMX)S01.06)

3.

Quad Cities Station Root Cause will evaluate the process for Post

Modirnation/ Maintenance testing by December 15, 1997.

(NTS #254180975CAQ0000501.07)

DATE WHEN FULL COMPLIANCE WILL BE MET:

Full compliance wat met when the model 88 air stan motors were removed and vendor

supplied rebuilt model 89 ASMs were installed and tested on June 17,1997 for the Shared

EDG and Jur.e 18,1997 for Unit Two EDG.

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Response to Notice cf Viol ti:n

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NOTICE OF VIGLATION 3

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'10 CFR 50, App:ndix B, Criterion XVI, " Corrective Ahtions," requires that _

conditions adverse to quality be promptly identified and corrected and that for

signd", cant conditions adverse to quality the cause of the condition be determined and

correcti e action be taken to preclude repetition.

Contrary to the above:

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a.

Because of the ' continuing reliance on an inadequate alt:rnate pants evaluation

and inadcquate testing, sufficient action was not promptly completed to _

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- identify and conect the cause of the May 8,1997 failure to sta.t of the U 2

EDG following installation of the model 88 air start motors. As a result,

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model 88 air start motors were installed on the U-1/2 EDG on May 17,1997.

T14 model 88 air statt motors were subsequently determined to be

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unacceptable and the U 2 and U-1/2 EDGs were declared inoperable on

June 12,1997 (254/265/97010-03a(DRS)).

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b.

Inadequate alternate parts evaluations, a condition adverse to quality, was not

identified as a cause of the failures during testing of two liqui? trim type

- replacement relief valves following the April 5,1997 failure or~ the residual-

- heat removal heat exchanger relief valve. As a result, actions to correct

inadequate alternate parts evaluations had not been taken as of the stant of the

inspection on June 9,19971254/265/97010-03b(DRS)).

'Ihis is a Severity I.evel IV violation (Supplement 1).

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REASON FOR VIOLATION:

254/265/97010-03a

Condid accepts the violation. Timely conective action was not taken in this instance because

the Station did not recognize the new model ASM as a design change and did not evaluate

their acceptability.

REASON FOR VIOLATION:

254/265/9701H3b

ComBd accepts the violation. The root cause evaluation performed in April,1997, did not

identify why the design change process was not being implemented properly.

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In _both cases the Station did not recognize that the alternate parts evaluations process was not

the conect design control process and that the design change process should have been used.

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.-Response to Notice cf Violation

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ACTIONS TAKEN:

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254/265/97010-03a

L 254/265/9701043b

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_ "Ihe a:Tected alternate parts evaluations, for both the relief valves and the ASM have

been voided to assure that the parts that were apprt ved could not be installed in the

plant in the wrong application.

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The deficient equipment was replaced with original design equ!pment.

3.

The event was presented and clarification of procedure and design change defm' ition

were provided to Engineering personnel.

'4.

A PIF was written to re-evaluate the Root Cause fer the relief valve.

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ACTIONS 'ID PREVENT FURTHER OCCURRENCE:

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254/265/9701003a

254/255/9701H3b

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1.

Quad Cities Station will implement Parts Evaluation Procedure changes by

November 15,1997. (NTS #25418097SCAQ0000501.01)

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2.

_ Quad Cities Station will develop a Lessons Learned training package and present it to

Station Engineering personnel and Maintenance supervision by March 31,1998.

(NTS #25418097SCAQ0000501.02)

- 3.

Quad Cities Station will develop a policy for vendor information evaluation by

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December 15,1997. (NTS #25418097SCAQ0000501.03)

'4.

A Root Cause Investigation on the EDG ASM issue will be completed by

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October 31, .1997. (NTS #25418097SCAQ0000501)

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5.

Quad Cities Station will take steps to ensure that significant issues are owned by a-

~ ingle individual by. October 30,1997. (N'I3 # OM-200-97-QRC01-19 )

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ATTACHMENT A

Response to Notice cf VI:lati:n

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DATE WIIEN FULL COMPLIANCE WILL BE MET:

254/265/97010 03a

254/265/97010-03b

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Full compliance for the EDGs was met when the model 88 air start motors were removed

and vendor supplied rebuilt model 89 ASMs were installed on June 17,1997 for the Shared

EDO and June 18,1997 for Unit Two EDO.

Full compliance for the RHRSW relief valve was met on April 15, 1997, when the original.

relief valve was repaired and the Surveillance Test QCOS 1000-04 was successfully

perfonned.

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