IR 05000254/1998005

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
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)

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o e June 10, 1998

Mr. Oliver President, Nuclear Generation Group

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Commonwealth Edison Company ATTN: Regulatory Services Executive Towers West ll1 1400 Opus Place, Suite 500 l Downers Grove, IL 60515 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 l

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John A. Grobe, Director Division of Reactor Safety Docket Nos.: 50-254;50-265 License Nos.: DPR-29; DPR-30  !

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

Comed to USNRC See Attached Distribution: l

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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/ / Rill:taaS ,\ l n ,. Rill:DRP l Rill:DRS_ . , Ir4

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NAME Guzrgn / Jacobspfit' K Ring .'yW_. GrobeM DATE 6///98 / 6Ab/98 \ j (\ / l 640/98 6/)t/9ff '

OFFICIAL' RECORD COPY 9eo61so321. 98061o f ADOCK O 4 ,p[

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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:

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) 1

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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 ,

references and align the requirements for proceeding with "At Risk" work on a i modification to the requirements of an Emergency Modification. 1 (NTS 254-100-98-00501.02, due June 15,1998) i l

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't JSNRC SVP-98-196 2 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,  !

l (A/Lte ~O

. oel P. Dimmette, Jr.

Site Vice President

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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 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, ,

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

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Valve AO-2-0220-44, an activity affecting quality, was prepared and installed prior to '

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 i

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

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

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 '

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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