IR 05000254/1998005: Difference between revisions

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{{Adams
{{Adams
| number = ML20217G248
| number = ML20249A022
| issue date = 04/23/1998
| issue date = 06/10/1998
| title = Insp Repts 50-254/98-05 & 50-265/98-05 on 980216-0326. Violations Noted.Major Areas Inspected:Engineering,Including Allowances for Development of Emergency & Immediate Mods
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-254/98-05 & 50-265/98-05 on 980423
| author name =  
| author name = Grobe J
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
| addressee name =  
| addressee name = Kingsley O
| addressee affiliation =  
| addressee affiliation = COMMONWEALTH EDISON CO.
| docket = 05000254, 05000265
| docket = 05000254, 05000265
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-254-98-05, 50-254-98-5, 50-265-98-05, 50-265-98-5, NUDOCS 9804290097
| document report number = 50-254-98-05, 50-254-98-5, 50-265-98-05, 50-265-98-5, NUDOCS 9806150326
| package number = ML20217G186
| title reference date = 06-01-1998
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| page count = 11
| page count = 3
}}
}}


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{{#Wiki_filter:June 10, 1998
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U. S. NUCLEAR REGULATORY COMMISSION REGION 111 Docket Nos: 50-254;50-265 License Nos: DPR-29; DPR-30 Report No: 50-254/98005(DRS); 50-265/98005(DRS)
Licensee: Commonwealth Edison Company (Comed)
Facility: Quad Cities Nuclear Power Station, Units 1 and 2 Location: 22710 206th Avenue North'
Cordova, IL 61242 Dates: February 16,1998 - March 26,1998 Inspector: J. Guzman, Reactor inspector l  Approved by: John Jacobson, Chief l  Lead Engineers Branch l
9804290097 900423 PDR ADOCK 05000254 G  PDR


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==SUBJECT:==
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NOTICE OF VIOLATION (NRC 'NSPECTION REPORT NOS.
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EXECUTIVE SUMMARY Quad Cities Nuclear Power Station, Units 1 & 2 NRC Inspection Report No. 50-254/98005(DRS); 50-265/98005(DRS)
Enaineerina
. Allowances, with precautions, for development of emergency and immediate modifications were adequately accounted for in the Quad Cities QA Program and in corporate and station procedures. Use of these types of modifications was not common and, when used, adequate controls existed to ensure minimum prerequisites, limitations, and operational restrictions were considered, including completion of 10 CFR 50.59 screenings or safety evaluation . Adequate controls were in place to ensure that at-risk work packages developed in parallel with the design package would assure cornponents would not be declared operable until completion of all design documentation. Use of the at-risk process was not routine and work completed appeared well-coordinated between the work analyst, design and construction staff. While generation of at-risk work packages was allowed by the Work Request initiation procedure, at-risk work was contrary to the Plant Design Change Process procedure. This was considered a procedural adherence violation.


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50-254/98005(DRS); 50-265/9u005(DRS)


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==Dear Mr. Kingsley:==
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This will acknowledge receipt of your letter dated June 1,1998, in response to our letter dated April 23,1998, transmitting a Notice of Violation associated with a failure to follow procedures when performing a design change at the Quad Cities Nuclear Power Station. We have reviewed your corrective actions and have no further questions at this time. These corrective actions will be examined during future inspections.
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Report Details lli. Engineering E1 Conduct of Engineering E Review of Emergency Modifications and At-Risk Work Process Inspection Scoce The inspector reviewed the Quad Cities engineering modification and at-risk work processes to ascertain compliance to the Quad Cities OA manual, as well as to corporate and site procedures. The inspector focused on three vehicles used for expediting design work at Quad Cities, namely (1) emergency modifications, (2) at-risk work requests and (3) immediate modification l The inspector reviewed a sample of modifications developed as emergency modifications and work packages completed using the at-risk work process. Associated problem identification forms (PIFs) were also reviewed as were NRC commitments related to design modifications. The inspector interviewed licensee staff cognizant with the development of design modifications, work package preparation and work package installation. Corporate and site procedures and other documents related to the design change process were also reviewed including:
. " Preparation and Control of Work Packages," QCAP 2200-04, Rev.17
. " Action Request / Work Request Initiation," QCAP 2200-02, Rev.12
. " Plant Design Change Process," QCAP 0460-01, Rev. 6
. " Emergency Modification to Support Appendix R," Letter dated October 28,1998 Doc. ID: Q-ECDS-97-0613
. " Engineering Requests," QCAP 0440-01, Rev.10
. " Comed QA Program Topical Report CE-1-A," Dated January 23,1998 j
- " Plant Modifications," NEP-04-01, Rev. 5  i Observations and Findinos b.1. Review of OA Manual and Corocrate Procedures The inspector reviewed licensee commitments and requirements of corporate procedures as well as the QA manual to verify allowances related to use of (1)
emergency modifications, (2) at-risk work requests and (3) immediate modification . Section 3.3 of the Comed Quality Assurance Manual Quad Cities (Topical Report CE-1-A, dated January 23,1998) required that " design verification for the '
l  stage of design activity accomplished shall be performed prior to release for procurement, manufacture, construction or release to another organization for i
use in other design activities provided sufficient data exists." The QA Manual also added:"Any unverified portion of the design shall be identified and controlled."


Sincerely, i
s/J.A. Grobe John A. Grobe, Director
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Division of Reactor Safety Docket Nos.: 50-254;50-265 License Nos.: DPR-29; DPR-30
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Enclosure: Ltr dtd 5/21/98 from J. P. Dimmette, Jr.


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Comed to USNRC See Attached Distribution:
DOCUMENT NAME: G:QUA-LTR.NOV To receive a copy of this documet, indigsfo in th ~ or *C" = Copy w/o attach /end *E" = Copy w/ attach /enci"N" = No copy j
OFFICE Rlli:DRS/
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Rill:taaS,\\ l n,. Rill:DRP l
Rill:DRS_.
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Ir4 NAME Guzrgn
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Jacobspfit' K Ring
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DATE 6///98
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. Comed corporate procedure NEP-04-01, " Plant Modifications," Revision 5 provided guidance on use of emergency modifications. Section 5.2.5 of this procedure specified that "if an emergency modification is required and authorized by Management, advanced approval may be given to start installation work. The design supervisor shall determine the documents required to start emergency installation work." This procedure provided minimum requirements which included:
6Ab/98 \\ j (\\ / l 640/98 6/)t/9ff '
  . the specific work being authorized,
OFFICIAL' RECORD COPY 9eo61so321. 98061o f
  . prerequisites and limitations for the work being authorized,
ADOCK O
  . operating restrictions on the system pending completion of the modification, and    ;
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  . a completed 50.59 evaluation for the scope of work authorized by the
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advanced approva i Per the procedure, "the package approved by the design supervisor shall be issued when the modification design is completed. Minimum requirements are the design documents, the Design Change Approval and Closecut Form, and the 50.59 Safety Evaluation."


. Comed corporate procedure NEP-04-01, " Plant Modifications," Revision 5, Section 5.2.1.21 states "If authorized by Management, at-risk changes may be installed prior to full regulatory approval; however, the change shall not be retumed to operation until complete and formal regulatory approval is required."
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. Using the Nuclear Documents (NUDOCS) system and references from the Comed Nuclear Tracking system, the inspector also reviewed Comed commitments to the NRC. This review was made to determine whether use of emergency modifications or at-risk work was contrary to any commitments that Comed had made to the NRC such as corrective actions for past design and design control problems. None were identifie The inspector concluded that adequate allowances and controlling limitations for development of emergency and immediate modifications were accounted for in the Quad Cities QA Program and in corporate procedures, i b.2. Quad Cities Use of Exoedited Design Process and Review of Site Procedures
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; The three vehicles used at Quad Cities that could potentially bypass the design process i were (1) emergency modifications, (2) at-risk work requests and (3) immediate
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, modification Emergency Modifications Emergency modifications at Quad Cities were developed using the guidance of Corporate Procedure NEP 04-01, " Plant Modifications," The inspector observed that the word " emergency" was not defined and use of emergency modifications was at the discretion of plant management. However, emergency modifications were infrequently used and their use to expedite the schedule during the Fall 1997 recent Appendix R compliance issues was not considered unreasonable. The inspector did not review the I
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. cc w/o encl:
M. Wallace, Senior Vice President D. Helwig, Senior Vics President G. Stanley, PWR Vice President J. Perry, BWR Vice President D. Farrar, Regulatory Services Manager-1. Johncn, Licensing Director DCD - Licensing J. Dimmette, Jr., Site Vice President W. Pearce, Quad Cities Station Manager C. Peterson, Regulatory Affairs Manager cc w/enci:
R. Hubbard N. Schloss, Economist Office of the Attorney General State Liaison Officer Chairman, lilinois Commerce Commission W. Leech, Manager of Nuclear MidAmerican Energy Company


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overall Appendix R effort or other aspects related to the safe shutdown analysis, but did review a sample of design packages for content, hold points and other limitations and did not identify any design process deviations for emergency modification At-Risk Work At Quad Cities, development of at-risk work packages was done under the auspices of procedure QCAP 2200-02," Action Request / Work Request Initiation." The licensee defined at-risk work as work completed at " commercial risk" prior to all work control documents being approved. The work can be performed at the Plant Manager's discretion after analyzing the risk. Per the procedure, the work would be done only on components that are inoperable and the design documentation must be completed pnot to returning the component to service. The PlF process would be used as an available mechanism to control at-risk work to ensure that the inoperable compor ants were not declared operable prior to completion of all design documentation. Adctionally, l Attachment C of the procedure would be completed to describe the wock description, l justification for the work, and discussion of the commercial risk involved The inspector determined that implementation of the at-risk work package option had been infrequent. Based on interviews, the inspector also noted that the licensee wrestled with whether to use at-risk work requests during the Appendix R modifications and ultimately decided to use the at-risk option for fabrication and procurement only and not for installation. This decision stemmed from the Appendix R modification that routed cable trays along the power block. Installation of anchor bolts on concrete walls on an at-risk basis was contemplated since the design package was not completed. Internal debate among licensee staff resulted in a decision to wait for the modification package i to be complete in lieu commencing installation. This was due to the fact that the concrete wall was not conducive to being declared inoperable. The licensee concluded that the at-risk process could not readily be used on walls or other components or systems that were not readily isolatable or could not be readily declared inoperabl Subsequently, for Appendix R related components or structures, use of at-risk work packages was confined to at-risk fabrication and at-risk procurement and not installation A sample review of these packages and interviews with licensee staff indicated that for at-risk work packages, the work analyst, the design engineer and the construction staff worked in unison and the at-risk work packages were not generated or installed in a
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" vacuum " The inspector noted that for at-risk work completed, there was minimal likelihood the installation work would not be approved or qualified or would change during the approval process. For example, the inspector reviewed in detail Work Package 970104149-03 which replaced the 3/4" recirculation loop sample valve, AO-2-0220-44, under at-risk conditions. Primarily due to lack of vendor seismic report information, the package was generated and installed between October 6 through 10, 1997 in parallel with development of the design modification package, DCN 001581M, which was approved on October 14,199 The inspector observed that the details for preparation and control of at-risk work packages did not change from regular work packages. The work analysts continued to use the precautions and limitations of procedure QCAP 2200-04," Preparation and Control of Work Packages," during development of the at-risk work package .
Distribution:
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Project Mgr., NRR w/enci -
C. Paperiello, Rlli w/enci J. Caldwell, Rill w/ encl B. Clayton, Rlll w/enct SRI Quad Cities w/enci DRP w/enci TSS w/enct DRS (2)w/enct Rlli PRR w/enci PUBLIC IE-01 w/enci Docket File w/enci GREENS LEO (E-Mail)
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DOCDESK (E-Mail)


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Additionally, precautions and limitations, design considerations, QC hold points, test requirements, technical reviews and structures, systems and component boundaries were appropriately handled.
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Use of at-risk work packages was first allowed in 1996 by Revision 8 of QCAP 2200-02, l " Action Request / Work Request Initiation." As discussed above, with the components declared inoperable, at-risk work was not considered contrary to Comed QA requirements. The inspector noted that upon implementation of the at-risk option at Quad Cities, the licensee did not revise all applicable design change procedure Specifically, QCAP 0460-01, " Plant Design Change Process," Step D.4.a continued to require that the installer receive an aooroved design change package prior to work package preparation. Development of at-risk work was, therefore, contrary to QCAP 0460-01. The at-risk work package reviewed in detail, Work Package
! 970104149-03, was considered a procedural adherence violation contrary to 10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings" (VIO 50-254/98005-01; 50-265/98005-01(DRS)).
Immediate Modifications Designation of a modification as an "immediate" modification was a third vehicle used to expedite design changes. These modifications were not " emergency" modifications but rather full modifications that would not be presented to the Technical Review Board (TRB)/ Site Planning Group (SPG) until up to one month after initiation instead of prior to the start of the modification development. This bypass required approval by the Site Vice President and was primarily an administrative bypass since "immediate" modifications would still get an On-Site review prior to issuance of the MAL. Use of the
"immediate" modification option was also not common and use was limited to instances where the normal TRB/SPG approval process would create unacceptable delay in processing the change. "Immediate" modifications appeared adequately controlled and proceduralized including a requirement for generation of a PIF as a mechanism for documenting the urgency and to ensure TRB/SPG review occurs within one month. The inspector did not identify any regulatory commitment or requirement specifying that the TRB/SPG review occur prior to modification developmen c. Conclusion Allowances, with precautions, for development of emergency and immediate modifications were adequately accounted for in the Quad Cities QA Program and in corporate and station procedures. Use of these types of modifications was not common and, when used, adequate controls existed to ensure minimum prerequisites, limitations, and operational restrictions were considered, including cornpletion of 10 CFR 50.59 screenings or safety evaluation Adequate controls were in place to ensure that components would not be declared i
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operable until completion of the all design documentation when at-risk work packages were developed in parallel with the design packages. Use of the at-risk process was not routine and work completed appeared well-coordinated between the work analyst, design and construction staff. While generation of at-risk work packages was allowed by the Work Request Initiation procedure, at-risk work was contrary to the Plant Design Change Process procedure. This was considered a procedural adherence violatio l
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Comed SVP-98-196 May 21,1998 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention:
Document Control Desk Subject:
Quad Cities Station Units 1 and 2:
NRC Inspection Report Numbers 50-254/98005 and 50-265/98005; e
NRC Docket Numbers 50-254 and 50-265:
Facility Operating Licenses DPR-29 and DPR-30.
 
Reference:
J. A. Grobe (NRC) to O. (Comed) letter dated April 23, 1998," Notice of Violation and NRC Inspection Report" Enclosed is Commonwealth Edison's (Comed's) response to the Notice of Violation
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(NOV) transmitted with the referenced letter. The report contained one Level IV violation:
Violation 98-005-01 cited a failure to follow procedure when an isolation valve on the 2A' Recirculation Loop Sample Primary Containment was installed prior to approval of the design work package.


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l This letter contains the following new commitments:
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For Violation 93-005-01:
! E8 Miscellaneous Engineering issues l E (Closed) Unresolved item (URI 50-254/94004-16: 50-265/94004-16): Review of I
1. Revise and issue QCAP 0460-01 to include requirements for "k. Risk" work asso;iated with plant modifications and include clarifying requirements that align
evaluations of piping with potential to leak over safety related switchgear. The inspector verified that the licensee completed a series of walkdowns of susceptible switchgear and verified that susceptible floor slab piping penetrations were adequately sealed. The licensee walkdowns also revealed heating lines that appeared to require additional supports. To address this, the licensee added supports in one case and, in another case, a stress analysis was generated to demonstrate that additional supports were not needed. This item is close E8.2 (Closed) Insoection Followuo item (IFl 50-254/94004-29: 50-265/94004-29): High Emergency Diesel Generator Cooling Water (EDGCW) pump flow evaluation did not consider negative effects on EDGCW Heat Exchangers. In response, the licensee i contacted the EDG vendor and satisfactorily evaluated the higher flow conditions to conclude that the observed higher flows (1680 gpm vs. a baseline of 1500 gpm) were acceptable. High flows were noted again in January 1995 when the Unit 1 EDGCW pump quarterly flow rate test indicated that the pump was performing in a region beyond the analyzed pump curve. These high flows were attributed to a throttle valve that was incorrectly positioned as wide open. The inspector reviewed licensee procedure changes to ensure positive controls on the throttle valve position were implemente Also reviewed were the last four Unit 1 quarterly flow rate tests that confirmed that the pump was consistently operating within the acceptance criteria. This item is closed.
"At Risk" work to the Emergency Modification requirements of NEP 04-01.


(NTS 254-100-98-00501.01, due June 15,1998)
2. Revise and issue QCAP 2200-02 to include QCAP 0460-01 in the procedure's
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references and align the requirements for proceeding with "At Risk" work on a i
E8.3 (Closed) Unresolved item (URI 50-254/94004-32: 50-265/94004-321: RHR Containment Isolation Valve not seat leak tested. The inspector reviewed the licensee scope and test acceptance criteria for the IST and Appendix J programs. IST acceptance criteria for stroke time and position indication and recent test data was satisfactory. The inspector confirmed that the RHR 1(2)-1001-28 A, B valves were sealed with a qualified seal water system. The inspector also confirmed that the RHR 1(2) 1001-07 A, B, C, D pump suction valves were located on a line below the minimum suppression pool level ensuring a potential pathway would be water-filled post-accident. Thus it was acceptable to exclude the valves from LLRT testing. This item is close E8.4 (Closed) Insoection Followuo item (IFl 50-254/94004-44: 50-265/94004-44):
modification to the requirements of an Emergency Modification.
Inadequate Prioritization, Trending and Status Control of the Site Engineering Service Requests (SESR) Process. The inspector noted that SESRs are now part of the Integrated Quality Report (lOE). lOE monthly performance review reports were reviewed by the inspector who confirmed that on a monthly basis, the site satisfactorily tracks and trends open, overdue, and the average age of open SESRs. Weekly reports of overdue SESRs were printed with IQE color coded windows highlighting the number of overdue SESRs. Prioritization was appropriately addressed via the Engineering Request screening committee. This item is closed.
 
(NTS 254-100-98-00501.02, due June 15,1998)
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j E8.6 (Closed) Insoection Followuo item (IFl 50-254/94004-49: 50-265/94004-49): Corporate Engineering Support Weaknesses. The licensee had initiated several improvement efforts and management changes to address corporate engineering support weaknesses, such as peer group reviews, Integrated Strategic Planning and development of the Management Review Board. Improvements had occurred in the interface between corporate and site personnel, with a primary example being the
SVP-98-196


May 21,1998 i
l if there are any questions or comments concerning this letter, please contact Mr. Charles Peterson, Regulatory Affairs Manager, at (309) 654-2241, ext. 3609.
l Sin ercly,
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~ O oel P. Dimmette, Jr.
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Site Vice President Quad Cities Station Attachment A: " Response to Notice of Violation"
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A. B. Beach, Regional Administrator, Region III R. M. Pulsifer, Project Manager, NRR C. G. Miller, Senior Resident Inspector, Quad Cities W. D. Leech, MidAmerican Energy Company D. C. Tubbs, MidAmerican Energy Company F. A. Spangenberg, Regulatory Affairs Manager, Dresden INPO Records Center Office of Nuclear Facility Safety, IDNS DCD License (both electronic and hard copies)
M. E. Wagner, Licensing, Comed SVP Letter File l
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ongoing effort expended in resolution of the Appendix R issue. However, comprehensive and effective resolution of deficiencies identified by the Vulnerability Assessment Team, the Diagnostic Evaluation Team, and the QC Course of Action (COA) continued to be a concern. These deficiencies were discussed in the Licensee's letter to the NRC dated January 2,1998 (SVP 98-002). Efforts to determine why actions taken were not fully effective in providing a framework for longer term continuous improvements were under licensee review. These efforts will be evaluated as part of the core program using inspection Procedure 37550. This item is close E8.7a (Closed) Violation (VIO 50-254/94020-03a: 50-265/94020-03a): Failure to correct RHR 2B minimum flow check valve after failed IST test. The inspector confirmed that, after check valve refurbishment, the subsequent IST and operability tests were successfu Further the inspector confirmed that the licensee's Restart Checklist was implemented to ensure that open corrective maintenance work requests were reviewed for potential impact on unit startup and power operations. This item is close ,
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E8.7b (Closed) Violation (VIO 50-254/94020-03b: 50-265/94020-03b): Inadequate corrective actions with Stand By Liquid Control (SBLC) system relief valves'setpoint drift proble The inspector reviewed actions taken to minimize setpoint drift including: cessation of system flushing prior to checking the setpoint, installation of heat tracing on the relief valves to address crystallization in the valve internals, trending of test results and failure events, and bench testing of the relief valves in lieu of testing on the system. Based on the testing and trending data, other actions to further minimize setpoint drift were still contemplated. However, the inspector concluded that actions taken were satisfactorily addressing and minimizing the setpoint drift. This item is close E8.7c (Closed) Violation (VIO 50-254/94020-03c: 50-265/94020-03c): Administrative closure of PlF resulting in failure to evaluate and correct RCIC rupture disc flange and seating surface . The inspector reviewed the actions taken in response to the violation and noted that since the 1994 violation an siectronic PlF system had been implemented j which should facilitate communication of PlFs' status to all departments and minimize l similar administrative closures. The inspector also observed that for this violation, the j administrative closure of the Level IV PlF did not prevent the implementation of corrective actions. An evaluation was completed to address the potential condensate accumulation on the RCIC turbine and rupture disc which satisfactorily concluded that the condensate collected would not significantly impact the turbine or rupture disc functionality. The RCIC rupture disks and pipe flanges were replaced for both unit l Additionally, the Unit 1 RCIC steam exhaust piping was inspected and a similar concern was not identified. This item is closed E8.8 (Closed) Violation (VIO 50-254/94020-04a. b: 50-265/94020-04a.b): Two examples of 10 CFR 50.55a(f)(4)(ii) violations (ASME IST Requirements). In the first example, the licensee's failure to adequately test the SBLC system pumps' 1 A and 28 discharge check valve was satisfactorily addressed by disassembling and inspecting the valve The check valves were replaced with a spring-loaded check valve design. The inspector observed that the closed function test method of the check valves had been revised and the test procedures had also been satisfactorily revised. The valves were no v tested by establishing a vent path upstream of the applicable check valve while operating the
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ATTACHMENT A
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RESPONSE TO NOTICE OF VIOLATION SVP LETTER 98-196 (Page 1 of 2)
NOTICE OF VIOLATION (50-254(265)/98005-01)
10CFR50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," requires i
that activities affecting quality shall be prescribed by documented instruction, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.


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Quad Cities Administrative Procedure QCAP 0460-01, " Plant Design Change Process,"
i Step D.4.a Work Package Preparation, states that the work package shall be prepared,
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approved, and controlled in accordance with the " Preparation and Control of Work Packages Procedure" when the installer receives an approved design change package.


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Contrary to the above, between October 6 and 10,1997, work package 970104149-03 I
other loop's pump and monitoring the change in its flow rate. Further, the inspector confirmed that the last surveillance tests for each unit were satisfactory. This item is close In the second example of this violation, the licensee had failed to adequately exercise the core spray minimum flow check valves to the full stroke position required to fulfill their safety function. The inspector noted that the initial test method had been reclassified as a partial open test and the IST program revision of May 15,1995, satisfactorily addressed the full flow test disassembly and inspection. The inspector observed that testing and inspection to date was acceptable. This item is close V. Management Meetings X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on March 26,1998. The licensee acknowledged the findings presente l l
which replaced the 2A Recirculation Loop Sample Primary Containment Isolation Valve AO-2-0220-44, an activity affecting quality, was prepared and installed prior to
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the October 14,1997 approval of the design work package, DCN 001581M.-
This is a Severity Level IV violation (Supplement 1).


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REASON FOR TIIE VIOLATION Comed accepts the violation. The cause of this event was cognitive error.
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I  PARTIAL LIST OF PERSONS CONTACTED
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Licensee


l C. Peterson Regulatory Assurance Manager l M. Fiumadore Design Engineering l B. Weaver Work Analyst- Mechanical R. Bozarth Modification Coordinator M. Sullivan Construction Supervisor i
INSPECTION PROCEDURES USED l IP 37550 Engineering l IP 37651 On-Site Engineering IP 37700 Design, Design Changes, and Modifications l
IP 37701 Facility Modifications IP 37702 Design Changes and Modification Program IP 92903 Follow-up - Engineering
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QCAP 0460-01, Revision 6, Paragraph D.4.a. states, "When (underline added) the
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ITEMS OPENED, CLOSED, AND DISCUSSED
installer receives an approved design change package, the work package shall be prepared, approved, and controlled IAW QCAP 2200-04, Preparation and Control of Work Packages". QCAP 2200-04, Preparation and Control of Work Packages states,
"The purpose of this procedure is to describe the control process and responsibilities for Work Package preparation and approval." The direction in paragraph D.4.a informs the procedure user of how to get an approved design package implemented and does not apply to work being performed at risk before an approved design package is available.
 
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QCAP 2200-02, Revision 13, Work Control Process states, "The purpose of this procedure is to describe the process for initiating action requests and work requests not created from action requests." At Risk Work is dermed in this procedure as," work that is done at commercial risk prior to nll work control documents being approved" (i.e., mods). This work can be performed at the Plant Manager's discretion after analyzing the risk. A Problem Identification Form (PIF) must be generated prior to performing the work. QCAP 2200-02, Attachment C, must be completed with required signatures prior to starting at risk work. QCAP 2200-02 includes NEP 04-01, the Nuclear Operations Division procedure for Plant Modifications as a reference, but does not address the Quad Cities Nuclear Station Plant Design Change Process Procedure QCAP 0460-01. Consequently, when the procedure was revised to allow at risk werk,
 
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ATTACHMENT A
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RESPONSE TO NOTICE OF VIOLATION (
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SVP LETTER 98-196 (Page 2 of 2)
50-254/98005-01 VIO proc violation work package prepared prior to design ;
QCAP 0460-01 was not identified as an affected document. The Emergency
i  approval Closed 50-254/94004-16 URI pipe leaks over switchgear evaluation program 50-265/94004-10 50-254/94004-29 IFl EDGCW pump flow not evaluated 50-265/94004-29 50-254/94004-32 URI RHR valves not seat leak tested 50-265/94004-32 50-254/94004-44 IFl SESR process inadequately statused 50-265/94004-44 50-254/94004-49 IFl corp engineering support weaknesses  i
}
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Modification requirements of the NEP, the at risk work requirements of QCAP 2200-02, and the documentation package requirements of QCAP 0460-01 are not clearly aligned.
50-265/94004-49 50-254/94020-03a,b,c; VIO 3 examples of corrective action violation
 
! 50-265/94020-03a,b,c l 50-254/94020-04a,b VIO 2 examples of 50.55a (ASME IST) requirements violation 50-265/94020-04a,b I
This was an oversight when the procedures were revised.
 
Quad Cities procedure QCAP 1100-04," Procedure Revision, Review And Approval" directs that the originator of a procedure revision identify affected procedures that should be revised concurrently with the procedure for which a revision is being requested. The originator and subsequent reviewers missed the application to the
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modifiestion procedure, QCAP 0460-01.
 
CORRECTIVE ACTIONS TAKEN / RESULTS ACHIEVED The Design Change Package, (DCP) 9700341 was issued on October 15,1997.


L____
CORRECTIVE ACTIONS TO PREVENT RECURRENCE Revise and issue QCAP 0460-01 to include requirements for "At Risk" work associated with plant modifications and include clarifying requirements that align "At Risk" work to the Emergency Modification requirements of NEP 04-01. (NTS 254-100-98-00501.01, due June 15,1998)
Revise and issue QCAP 2200-02 to include QCAP 0460-01 in the procedure's references and align the requirements for proceeding with "At Risk" work on a modification to the requirements of an Emergency Modification.


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(NTS 254-100-98-00501.02, due June 15, 1998)
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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
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Full compliance will be achieved when the revisions to QCAP 2200-02 and QCAP 0460-01 are completed on June 15,1998.
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LIST OF ACRONYMS AND INITIALISMS USED ASME American Society of Mechanical Engineers CFR Code of Federal Regulations Comed Commonwealth Edison Company COA Course of Action DCN Design Change Notice DG Diesel Generator DRS Division of Reactor Safety EDGCWP Diesel Generator Cooling Water Pump EDG Emergency Diesel Generator IFl Inspection Follow-up Item lOE Integrated Quality Report IST In-Service Testing LLRT Local Leak Rate Test MAL Modification Approval Letter NTS Nuclear Tracking System PDR Public Document Room PlF Problem Identification Form QA Quality Assurance OCAP Quad Cities Administrative Procedure RCIC Reactor Core isolation Cooling RHR Residual Heat Removal SBLC Standby Liquid Control SESR Site Engineering Service Request TRB/SPG Technical Review Board / Site Planning Group URI Unresolved item VIO Violation


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Latest revision as of 12:46, 16 March 2025

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-254/98-05 & 50-265/98-05 on 980423
ML20249A022
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 06/10/1998
From: Grobe J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Kingsley O
COMMONWEALTH EDISON CO.
References
50-254-98-05, 50-254-98-5, 50-265-98-05, 50-265-98-5, NUDOCS 9806150326
Download: ML20249A022 (3)
v • d • e


Text

June 10, 1998

SUBJECT:

NOTICE OF VIOLATION (NRC 'NSPECTION REPORT NOS.

50-254/98005(DRS); 50-265/9u005(DRS)

Dear Mr. Kingsley:

This will acknowledge receipt of your letter dated June 1,1998, in response to our letter dated April 23,1998, transmitting a Notice of Violation associated with a failure to follow procedures when performing a design change at the Quad Cities Nuclear Power Station. We have reviewed your corrective actions and have no further questions at this time. These corrective actions will be examined during future inspections.

Sincerely, i

s/J.A. Grobe John A. Grobe, Director

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Division of Reactor Safety Docket Nos.: 50-254;50-265 License Nos.: DPR-29; DPR-30

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Enclosure: Ltr dtd 5/21/98 from J. P. Dimmette, Jr.

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Comed to USNRC See Attached Distribution:

DOCUMENT NAME: G:QUA-LTR.NOV To receive a copy of this documet, indigsfo in th ~ or *C" = Copy w/o attach /end *E" = Copy w/ attach /enci"N" = No copy j

OFFICE Rlli:DRS/

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DATE 6///98

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OFFICIAL' RECORD COPY 9eo61so321. 98061o f

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. cc w/o encl:

M. Wallace, Senior Vice President D. Helwig, Senior Vics President G. Stanley, PWR Vice President J. Perry, BWR Vice President D. Farrar, Regulatory Services Manager-1. Johncn, Licensing Director DCD - Licensing J. Dimmette, Jr., Site Vice President W. Pearce, Quad Cities Station Manager C. Peterson, Regulatory Affairs Manager cc w/enci:

R. Hubbard N. Schloss, Economist Office of the Attorney General State Liaison Officer Chairman, lilinois Commerce Commission W. Leech, Manager of Nuclear MidAmerican Energy Company

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Distribution:

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SAR (E-Mail)

Project Mgr., NRR w/enci -

C. Paperiello, Rlli w/enci J. Caldwell, Rill w/ encl B. Clayton, Rlll w/enct SRI Quad Cities w/enci DRP w/enci TSS w/enct DRS (2)w/enct Rlli PRR w/enci PUBLIC IE-01 w/enci Docket File w/enci GREENS LEO (E-Mail)

DOCDESK (E-Mail)

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Comed SVP-98-196 May 21,1998 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention:

Document Control Desk Subject:

Quad Cities Station Units 1 and 2:

NRC Inspection Report Numbers 50-254/98005 and 50-265/98005; e

NRC Docket Numbers 50-254 and 50-265:

Facility Operating Licenses DPR-29 and DPR-30.

Reference:

J. A. Grobe (NRC) to O. (Comed) letter dated April 23, 1998," Notice of Violation and NRC Inspection Report" Enclosed is Commonwealth Edison's (Comed's) response to the Notice of Violation

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(NOV) transmitted with the referenced letter. The report contained one Level IV violation:

Violation 98-005-01 cited a failure to follow procedure when an isolation valve on the 2A' Recirculation Loop Sample Primary Containment was installed prior to approval of the design work package.

l This letter contains the following new commitments:

For Violation 93-005-01:

1. Revise and issue QCAP 0460-01 to include requirements for "k. Risk" work asso;iated with plant modifications and include clarifying requirements that align

"At Risk" work to the Emergency Modification requirements of NEP 04-01.

(NTS 254-100-98-00501.01, due June 15,1998)

2. Revise and issue QCAP 2200-02 to include QCAP 0460-01 in the procedure's

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references and align the requirements for proceeding with "At Risk" work on a i

modification to the requirements of an Emergency Modification.

(NTS 254-100-98-00501.02, due June 15,1998)

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SVP-98-196

May 21,1998 i

l if there are any questions or comments concerning this letter, please contact Mr. Charles Peterson, Regulatory Affairs Manager, at (309) 654-2241, ext. 3609.

l Sin ercly,

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~ O oel P. Dimmette, Jr.

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Site Vice President Quad Cities Station Attachment A: " Response to Notice of Violation"

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cc:

A. B. Beach, Regional Administrator, Region III R. M. Pulsifer, Project Manager, NRR C. G. Miller, Senior Resident Inspector, Quad Cities W. D. Leech, MidAmerican Energy Company D. C. Tubbs, MidAmerican Energy Company F. A. Spangenberg, Regulatory Affairs Manager, Dresden INPO Records Center Office of Nuclear Facility Safety, IDNS DCD License (both electronic and hard copies)

M. E. Wagner, Licensing, Comed SVP Letter File l

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ATTACHMENT A

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RESPONSE TO NOTICE OF VIOLATION SVP LETTER 98-196 (Page 1 of 2)

NOTICE OF VIOLATION (50-254(265)/98005-01)

10CFR50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," requires i

that activities affecting quality shall be prescribed by documented instruction, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Quad Cities Administrative Procedure QCAP 0460-01, " Plant Design Change Process,"

i Step D.4.a Work Package Preparation, states that the work package shall be prepared,

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approved, and controlled in accordance with the " Preparation and Control of Work Packages Procedure" when the installer receives an approved design change package.

Contrary to the above, between October 6 and 10,1997, work package 970104149-03 I

which replaced the 2A Recirculation Loop Sample Primary Containment Isolation Valve AO-2-0220-44, an activity affecting quality, was prepared and installed prior to

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the October 14,1997 approval of the design work package, DCN 001581M.-

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

REASON FOR TIIE VIOLATION Comed accepts the violation. The cause of this event was cognitive error.

QCAP 0460-01, Revision 6, Paragraph D.4.a. states, "When (underline added) the

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installer receives an approved design change package, the work package shall be prepared, approved, and controlled IAW QCAP 2200-04, Preparation and Control of Work Packages". QCAP 2200-04, Preparation and Control of Work Packages states,

"The purpose of this procedure is to describe the control process and responsibilities for Work Package preparation and approval." The direction in paragraph D.4.a informs the procedure user of how to get an approved design package implemented and does not apply to work being performed at risk before an approved design package is available.

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QCAP 2200-02, Revision 13, Work Control Process states, "The purpose of this procedure is to describe the process for initiating action requests and work requests not created from action requests." At Risk Work is dermed in this procedure as," work that is done at commercial risk prior to nll work control documents being approved" (i.e., mods). This work can be performed at the Plant Manager's discretion after analyzing the risk. A Problem Identification Form (PIF) must be generated prior to performing the work. QCAP 2200-02, Attachment C, must be completed with required signatures prior to starting at risk work. QCAP 2200-02 includes NEP 04-01, the Nuclear Operations Division procedure for Plant Modifications as a reference, but does not address the Quad Cities Nuclear Station Plant Design Change Process Procedure QCAP 0460-01. Consequently, when the procedure was revised to allow at risk werk,

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ATTACHMENT A

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RESPONSE TO NOTICE OF VIOLATION (

SVP LETTER 98-196 (Page 2 of 2)

QCAP 0460-01 was not identified as an affected document. The Emergency

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Modification requirements of the NEP, the at risk work requirements of QCAP 2200-02, and the documentation package requirements of QCAP 0460-01 are not clearly aligned.

This was an oversight when the procedures were revised.

Quad Cities procedure QCAP 1100-04," Procedure Revision, Review And Approval" directs that the originator of a procedure revision identify affected procedures that should be revised concurrently with the procedure for which a revision is being requested. The originator and subsequent reviewers missed the application to the

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modifiestion procedure, QCAP 0460-01.

CORRECTIVE ACTIONS TAKEN / RESULTS ACHIEVED The Design Change Package, (DCP) 9700341 was issued on October 15,1997.

CORRECTIVE ACTIONS TO PREVENT RECURRENCE Revise and issue QCAP 0460-01 to include requirements for "At Risk" work associated with plant modifications and include clarifying requirements that align "At Risk" work to the Emergency Modification requirements of NEP 04-01. (NTS 254-100-98-00501.01, due June 15,1998)

Revise and issue QCAP 2200-02 to include QCAP 0460-01 in the procedure's references and align the requirements for proceeding with "At Risk" work on a modification to the requirements of an Emergency Modification.

(NTS 254-100-98-00501.02, due June 15, 1998)

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED

Full compliance will be achieved when the revisions to QCAP 2200-02 and QCAP 0460-01 are completed on June 15,1998.

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