IR 05000254/1997027

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-254/97-27 & 50-265/97-27 on 971223

ML20202A844
Person / Time
Site:	Quad Cities
Issue date:	02/03/1998
From:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Kingsley O COMMONWEALTH EDISON CO.
References
50-254-97-27, 50-265-97-27, NUDOCS 9802100189
Download: ML20202A844 (3)

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Februa_y 3, 1998 Mr. Oliver President, Nuclear Generation Group Commonwealth Edison Company ATTN: Regulatory Services Executive Towers West lll 1400 Opus Place, Suite 500 Downers Grove,IL 60515 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NOS.

50 254/97027(DRS); 50-265/97027(DRS)

Dear Mr. Kingsley:

This will acknowledge receipt of your letter dated January 21,1908, in rasponse to our letter dated December 23,1997, transmitting a Notico of Vloiatloa associated with the subject inspection report at the Quad Cities Nuclear Power Station. We have reviewed your corrective actions and have no further questions at this time. These ccrective actions will be examined during future inspections.

Sincerely,

/s/ M. Leach for John A. Grobe, Director Division of Reactor Safety Docket No. 50-254 Docket No. 50-265 See Attached Distribution DOCUMENT NAME: G:DRS\QUA02028.DRS (See Previous Concurrence)

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EA 97 591 Mr. Oliver D. Itingsley President, Nuclear Generation Group Commonwealth Edison Company ATTN: Regulatory Services Executive Towers West lli 1400 Opus Place, Sulie 500 Downers Grove,IL 60515

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SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NOS.

50 254/97027(DRS); 50-265/97027(DRS)

Dear Mr. Kingsley:

This will acknowledge receipt of your letter dated January 21,1998, in response to our letter dated December 23,1997, transmitting a Notice of Violation associated with the subject inspection report 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, John A. G obe, Director Division of Reactor Safety Docket No. 50-254 Docket No. 50-265 See Attached Distribution DOCUMENT NAME: G:DRS\QUA02028.drs

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OFRCIAL RECORD COPY I

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{ - O. .2 . Februar1 3,1998 cc: M. Wallace, Chief of Sta#

D. Helwig, Senior Vice President f 'G. Stanley, PWR Vice President

J. Perry, BWR Vice President ':

D. Farrar, Regylatory .

Services Manager .

I. Johnson, Lice %1ng Director f) '

. DCD - Licensing E. Kraft, Jr., Site Vice President D. Cook, Quad Cities Station Manager C. C. Peterson, Regulatory Affairs Manager Richard Hubbard Nathan Sch!oss, Economist OfSce of the Attorney General State Liaison Officer

- Chairman, Illinois Commerce _  :

Corrmission W. D. Leech, Managerof Nuclear MidAmerican Energy Company Distribution Docket File Rlli PRR Rlli Enf. Coordinator PUBLIC IE-01 SRI, Quad Cities TSS LPM,' NRR J. L. Caldwell, R!ll DR;' A. B. Beach, Rlli c .DRS DOCDEEM

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w , :: o l SVP-98-010 January 21,1998 U, S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Document Co itrol De k Subject: Quad Cities Nuclear Power Station Units I and 2 NRC Docket Numbers 50 254 and 50-265 NRC Inspection Report Numbers 50-254/97027 and 50-265/97027 Ref2rence: (a) G. E. Grant to L. W. Pearce Letter dated December 23,1%7 Enclosed is Commonwealth Edi:on's (Comed's) response to the Notices of Violation (NOV) transmitted with the referenced letter. Level IV violation 97-027-04 cited that, the license ( was unable to retrieve records ofins:rsice inspection leakage tests of the Class I system, completed during the Unit I and Unit 21995 refueling outages, that were required by the American Society of Mechanical Er gineers Code (A5ME) Code Section XI. Level IV violation 97-027-05 cited a failure to generate a problem

' identification form following e.n alarm indicating the reactor vessel head inner 0-ring had failed. i This letter contains the following new commitment:

p Violation 97-027-04:

There are no new commitments for this violation.

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t. Violation 97-027-05:

1. QCOP 0220-01, REACTOR VESSEL HEAD LEAK DETECTION SYSTEM, will be revised by March 1,1998 to ensure a PIF or Action Request is generated when the alarm condition is validated indicating an 0-ring failure.

(NTS#254100970270501)

_Ojo O DD D' JAN 2 61996

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USNRC SVP.98 010 2 January 21,1998 If you have any questions conceining this letter, please cor. tact Mr. Charles Peterson,

'. Regulatory Affairs hianager, at (309) 654-2241, extension 3609 Respectfully, S

E. S. Kraft, J (, .

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Site Vice Presiderit

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Quad Cities Station Attachment A," Response to Notice of Violation" cc: A. B. Beach, Regiont.1 Administrator, Region ill R. h1. Fulsifer, Project hianager, NRR

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

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W. D. Leech, hiidAmerican Energy Company D. C. Tubbs, hiidAmerican Energy Company F. A. Spangenberg, Regulatory Affairs hianager, Dre: den '

INPO Records Center Office of Nuclear Facility Safety, IDNS s DCD License (both electronic and hard copies)

- h1. E. Wagner, Licensing, Comed SVP Letter File

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e s ATTACilMENT A

RESPONSE TO NOTICE OF VIOLATION SVP 98-010 (Page 1 of 3)

NOTICE OF VIOLATION (50-254(265)/97027-04)

10 CFR 50, Appendix B, Criterion XVII states,in part, that suflicient records shall be maintained to furnish evidence of activities afTeeting quality. These records include records of tests, which shall be identifiable and retrievable. <

Contrary to the above:

As of December 4,1997, the licensee was unable to retrieve records ofinsenice inspection leakage tests of the Class I system, completed during the Unit I and Unit 21995 refueling (

outages, that were required by the American Society of Mechanical Engineers Code (ASME)

Code Section XI.

This is a Severity Level IV Violation (Supplement 1) (VIO 50-254/97027-04(DRS);

50-265/97027-04(DRS)).

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REASON FOR TIIE VIOLATION:

Comed accepts the violation. The cause of this event was personnel error.

The original request to Central File for the information was made asking for QCOS 201-08, which wt.s the incorrect procedure number at the time in question. Due to this error, the records were not found. The Document Control Clerk in Central File then seerched all indexes by the name of the test procedure without regard for a tert number and was able to determine that the correct procedure number at the time of the test was QCOS 201-04 (OCOS 020108 replaced QCOS 0201-04 on 2/20/97). Once this was determined the Unit I report was rettmved 1/2/98.

The documentation for Q2R13, QCOS 201-04 insenice inspection lea'. age tests were not submitted by the Operations Department to Central File for permanen; retention. The originalis presumed lost, however a copy of the procedure attachments QCOS 201-04 Attachment F, 7 ages 1-9 were located in Engineering.

CORRECTIVE STEPS TAl EB. AND RESULTS ACillEVED A copy of QCOS 201-04, revision 3, Attachment F," Unit 2 Class 1 System Pressure h t Visual Walkdown Checklist" pages 1-9 were located and submitted to Central File for document retention. Records in storage were manually searched for the original Q2R13 inservice inspection leakage test documentation, QCOS 201-04, with negative results. Complete January 13, 1998.

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ATTACllMENT A

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RESPONSE TO NOTICE OF VIOLATION SVP 98-010 -

(Page 2 of 3)

h CORRECTIVE STEPS TAKEN TO AVOID FURTilER VIOLATIONS

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A previous Noti:e ofviolation 254/265/97 006-03 identified documant controlissues. The following corrective actions are comn.c.; to NOV 254/265/97-006-03 and NOV 254/265/97027 as both violations occurred prior to the implementation of these conective actions.

1. Fach department established a departmental Records Custodiaa.' Completed December 1996.

2. Procedure change to QCAP 1200-01, Station Records" was made to reflect Record Custodian responsibilities. Completed November 1996.

3. Training of the Records Custodians was completed DecemHr 1996.

4. Each department reviewed their retention schedule to include 4dentification ofquality records.

Completed November 1997.

5. QCAP 1200-01," Station Records" was revised to require a semi annual review of the retention schedule. Completed November 1997.

DATE WIIEN FULL col .PLIANCE WAS ACIllEVED Full- compliance was met on Januay 13.1998 when QCOS 201-04, revision 3, Attachment F,

" Unit 2 Class 1 System Pressure Test Visual Walkdown Checklist" pages 1-9 were loc 4ted and submitted to Central File for document retention.

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p";c ATTACil.\ LENT A i RESPONSE TO NOTICE OF VIOLATION I

SVP 98-010 (Page 3 of 3)

NOTICE OF VIOLATION (50-254;265/97027-05)

10 CFR 50 Appendix B, Criterion XVI states in part that " measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions...are promptly identified and corrected."

Contrary to the above, as of November 5,1997, the license 2 had fai:ed to implement the corrective action process for the failed Unit I reactor vessel flange inner 0-ring seal. Specifically, a continuous alarm condition indicative of an inner 0 .ing seal failure had existed since August 31,1996 and the licensee had not initiated a problem identification form.

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

Reason for violation:

Comed accepts this viciation.

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The cause of the failure to initiate a problem identification iorm (PIF) on August 31,1996 was a historical lack of Station seasitivity to this alarm condition and the inner 0-ring failure it represented.

Corrective Actions ta!:-n:

PIF Q1997-04261 was initiated on November 6,1997 to document the deficient inner O-ring 3 condition identified on August 31,1996.

Corrective Actions to prevent further occurrence:

.QCOP 0220-01, REACTOR VESSEL HEAD LEAK DETff_ TION SYSTEM, will be revised by March 1,1998 to ensure a PIF tr Action Request is generated when the alarm condition is validated indicating an 0-ring failure. (NTS#254100970270301; Operations)

Date When Full Compliance will be met:

Full compliance was met on November 6,1997, with the PlF initiation described above.

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