ML19273A214

Responds to NRC 830812 Ltr Re Violation Noted in IE Insp Repts 50-254/83-19 & 50-265/83-17.Corrective Actions: Program Devised to Upgrade Review Pocess for Installation of Mods

ML19273A214
Person / Time
Site:	Quad Cities
Issue date:	09/06/1983
From:	Farrar D COMMONWEALTH EDISON CO.
To:	Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19273A213	List: ML19273A214
References
7245N, NUDOCS 8309200334
Download: ML19273A214 (3)

Text

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Commonwealth Edison

. ou Igrst, National Plata Chic 8.p0. tilinois Address Repty to: Post Office Box 767 Chicago, lihnois 60690 September 6, 1983 Mr. R. L. Spessard, Director Division of Engineering - Region III U.S. Nuclear RegulatoIy Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Quad Cities Station Units 1 and 2 Response to Inspection Report Nos.

50-254/83-19 and 50-265/83-17 NRC Docket Nos. 50-254 and 50-265 Reference (a): R. L. Spessard letter to Cordell F..ed dated August 12, 1983

Dear Mr. Spessard:

This letter is in response to the inspection conducted by Messrs. N. Choules, J. Kish, and D. Hunter (July 22 only) on June 28 through July 1, and July 22, 1983, of activities at Quad Cities Station.

Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements. The Commonwealth Edison Company response to the Notice of Violation is provided in the enclosure.

In response to your request on the actions planned by Commonwealth Edison to evaluate the applicability of these issues at our other opera. units we have implemented the following actions. 1.)

Review by Je' cy 15, 1984 these events against existing procedures to determine th_ r edequacy. 2.) Implement any changes, if necessary, by March 15, 1984.

To the best of ny knowledge and belief the statements contained herein and in the attachment are true and correct. In some respects thrse statements are not based upon my personal knowledge but upon information furnished by other Commonwealth Edison employees. Such information has been reviewed in accordance with Company practice and I believe it to be reliable.

If you have any further questions on this matter, please direct them to this office.

Very ruly yopx4 ud , Wn D. L. Farrar Director of Nuclear Licensing Attachment cc: NRC Resident Inspector - Quad Cities SEP 81883 B309200334 830914 7245N $DRADOCK 050002g '

Commonwealth Edison Company ATTACHMENT Response to Notice of Violation NRC Docket Numbers 50-254 and 50-265 The following is the response to the item of noncompliance identified in the Appendix to the NRC letter dated August 12, 1983.

1. The Quality Assurance Topical Report CE-1-A, Revision 15, Section 3.1 (Paragraph 4) states, in part, that " Review and evaluation by the Architect Engineer, the Nuclear Steam Supply System Vendor and/or Project Engineering or the Station Nuclear Engineering Deoartment will assure that designs . . . will conform to the . . . regulatory requirements,'

SAR commitments and appropriate quality standards, as applicabl .

Contrary to the above, the review and evaluation of RFC Number Ql-399 was inadequate in that the drawings and instructions associated with that modification incorrectly identified the soare Torus penetration X-215 as a trunnion. The mistake resulted from an inadequate considelation of an existing Torus drawing.

Corrective Action Taken and Resultc Achieved ,

A meeting was held involving the Station Construction Department and Station personnel to discuss the possibility of enhancing the modification review process.

As a result of this meeting a program was devised to upgrade the review process for the installation of modifications. This program will implement a special checksheet which will be completed and signed by a technical station individual who presently holds a Senior Reactor Operator's license. This checksheet is titled, " Operational Evaluation Checklist". The modification work packages, which can comprise of a complete modification or only a specific work segment, will be reviewed prior to the commencement of installation and the checklist completed ano signed. The completion of the checklist will require a consideration of operating plant interfaces; such as, a unit outage or Technical Soecification requirements. In addition, any special operating requirements will be written on the checklist.

To initiate the use of the new checklist for modifications, a letter will be included in the mooification approval documents which instructs the Station Construction Department to utilize the checklist.

The decision to implement this letter will be made by the Technical Staff Supervisor or his designee, all of whom hold Senior Reactor Operator licenses. This decision will be necessary since not all modifications will require the new checklist.

n

-2 Corrective Action to Avoid Further Noncompliance The implementation of the aforementioned program should prevent a recurrence of this and similar incidents. To further formalize this program, Station procedure QTP 500-11, Safety Related, Code Related, and Engineering Assisted Modifications, will be revised to reflect the enhanced review process prior to the installation of modifications.

Date When Full Compliance Will be Achieved The new modification review program has been implemented and has been in effect since August 18. Station procedure QTP 500-11 will be revised and implemented by October 24, 1983.

Finally Item 2 c. of this inspection report identified two additional concerns regarding this event.

The first concern is in regards to the fact that "The Station Operating organization was not notified of the event until 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> after it happened." To correct this situation, Morrison Construction Company has discussed at a recent safety meeting with its personnel that any questionable items shall be reported to their immediate supervisor, who shall immediately report these items to CECO's Station Construction Department.

Quad-Cities Station provides the following concents regarding the unresolved item in this inspection report involving the NRC's concern that Station personnel possessing adequate plant operational knowledge were not involved in the review of these work packages for the operating plant interfeces.

The new modification review process to be completed prior to the start of any work will adequately provide actions to prevent a similar occurrence.

In addition to the operational evaluation performed, the checksheet provides a review of the work to be performed te ensure this portion of the modification falls within the scope of the original 10 CFR 50.59 safety evaluation.