ML20032B833
| ML20032B833 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 04/28/1981 |
| From: | Abel J COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20004F062 | List: |
| References | |
| NUDOCS 8111060423 | |
| Download: ML20032B833 (6) | |
Text
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JUN 1 1981 Commonwealth Edison Company Sheet - Unit 1 Equipment Attendant," and QOS 005-S14, " Operator Surveil-lance Turnover Sheet - Unit 2 Equipment Attendant," will be revised:to include inspection of all equipment and personnel batches into the i
Unit I and 2 Cabi'e Tunnels from the Auxiliary Electric Equipment Room and the Turbine _ Building 595' Level once each shift.
This will provide verification that these hatches remain closed. The equipment hatch in the cable riser area from the Unit 2 Cable Tunnel (Turbine Building 595' Level, area F-G/12-13) has been locked closed.
These actions and those delineated in your letter are acceptable to mitigate the occurrence of the hatches being left open. However, they do not adequately demonstrate that your safe shutdown analysis, as 1
documented in your letters to the NRC dated July 31, 1978, October 1, 1979 and January 23, February 29, and March 4, 1980, is not compro-mised by the unrated hatches between the Cable Tunnels and the Turbine Building 595' Level. Therefore, you agreed to provide an additional i
response addressing this concern.
Specifically, 10 CFR 50, Appendix R, i
Section III.G., is to be utilized as the criteria for determining which i
equipment and cabling necessary for safe shutdown could be affected by a fire that spreads from a Cable Tunnel to the Turbine Building 595' Level through the unrated personnel and equipment batches.
We will examine these matters during a subsequent inspection.
With respect to your response regarding. Unresolved Item No. 3 in Attach-ment B to your letter, our position on these issues has not changed and they are being evaluated by IE Headquarters. No action by you is presently required on these items.
Your cooperation with us is appreciated.
l Sincerely, pgggigt signed by C.E. Morellm" C. E Norelius, Acting Director l
Division of Engince' ring and l
T chnical Inspection i
cc:
J. S. Abel, Director of Nuclear Licensing i
N. Kalivianakis,
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Plant Superintendent ec w/1tr dtd 4/28/81:
DMB/ Document Control Desk'(RIDS)
Resident Inspector, RIII Mary Jo Murray, Office of j.
Assistant Attorney General
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C:mmanw cith Edison O
One First National Plaza. Chicago. tilinois -
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O' Address Reply to: Post Office Box 767 Chicago, Illinois 60690 A
April 28, 1981 Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Quad Ci+ies Station Units 1 and 2 Response to IF Inspection Report Nos. 50-254/81-04 and 50-265/81-04 NRC Docket Nos. 50-254/265 Reference (a):
C. E. Norelius letter to C. Reed dated April 3, 1981
Dear Mr. Keppler:
Reference (a) transmitted the results of an inspection conducted by Messrs J. A. Grobe and K. R. Baker of your office on February 23-27, 1981, of activities at Quad Cis 4es Units 1 and 2.
Appendix A to that report identified four apparent items of noncompliance with NRC requirements.
Our responses to the items of noncompliance are provided in Attachment A to this letter.
Our response to two additional concerns identified in Reference (a) are provided in Attachment B.
We have also taken this opportunity to provide our responses to two unresolved items identified in Reference (a), which also appear in Attachment B.
As indicated in Attachment A, full compliance has already been achieved for all items of noncompliance except Item 1, which will be complete by July 1, 1981.
Please address any questions concerning this matter to this Very truly yours,
,;t og J. S. Abel 7
$1 Director of
' -,7 Nuclear Licensing cc: RIII Inspector, Quad Cit es eps Attachment
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NRC DOCKET NO. 50-254 NRC DOCKET N0 50-265 ATTACHMENT A Commonwealth Edison A
A t tachmen t
, Response to Notice of Violation items of noncompliance identified in Appendix A to the NRC letter dated April 3,1981, are responded to in the following paragraphs:
1.
Contrary to QMP 100-3, Fire Prevention for Welding and Cutting, the inspector observed a contractor welder on February 26, 1981 in the Unit 2 Cable Tunnel performing welding operations above safety related cabling without a fire watch in the immediate area.
Trays of safety related cabling were not covered with suitable noncombus-tible materials and were being exposed to potential damage or Ignition and combustible materials (wood, cardboard, paper, and plastic) had accumulated in the immediate area of the welding operations.
Unit 2 was operating at 100% at the time of this observation.
Corrective Action and Results Achieved When the Station was made aware of the welding operations in the Unit 2 Cable Tunnel, the work was stopped. The contractor firm involved was informed of the Station procedures that are required to be followed for welding in safety-related areas. The Unit 2 Cable Tunnel was cleaned and the proper administrative controls taken before work was allowed to In addition, all cables in the Unit 2 Cable Tunnel were inspected resume.
for damage that could have resulted from exposure to ignition sources.
The results of this inspection showed no damage.
Corrective Action Taken to Avoid Further Noncompilance Maintenance Procedure QMP 100-3, Fire Prevention for Welding and Cutting, has been reviewed and is deemed adequate for use in preventing fires.
However, QMP 100-SI, Working and Cutting Permit, which is used to implement QMP 100-3 is being revised. The revision will consist of additional approval sign-offs which include:
1)
Fire Watch Present During Work; 2)
Fire Extinguisher at Job Location, and in Working Order;
- 3) Area Cleaned and inspected Before Starting Work; 4)
Equipment Protected Before Starting Work; 5) Operating Engineer's authorization before welding in the Auxiliary Electrical Equipment Room, Control Room and Cable Spreading Room. Additional information for Area Preparation,
Environmental Preparations, and Fire Frevention inspection has also been taken from QMP 100-3 and will be included in the Welding and Cutting Permit revision.
A Date bhen Full Compliance Will be Achieved QMP 100-S1, Welding and Cutting Perm 1P, will be revised by July 1, 1981.
The Contractors and Station personnel have been instructed, and are following proccdure QMP 100-3 at this time.
2.
Contrary to Technical Specification 3.12.F.1 and 3.12.F.2 the inspector observed an open fire barrier penetration above the fire door between the Unit I and Unit 2 Reactor Buildings on the 595' level with no j
apparent fire watch.
Corrective Action and Results Ach!:;cu Upon discovery of the four inch penetration which had been core-bored in the wall between Unit I and Unit 2 Reactor Building a fire watch wa; established in accordance with Technical Specification 312.F.2.
Tne penetration was sealed and the fire watch terminated on the same day.
Corrective Action Taken to Avoid Further Noncompliance Subsequent meetings with Contractors and Commonwealth Edison Company personnel resulted in a review of the requirements of Technical Specifications 312.F.1 and 3.12.F.2, and Station Procedures. A policy was established which requires notification of cognizant Station management whenever a fire pecetration barrier must be opened.
This will allow management to verify that compliance to Technical Specifications is maintained.
Date When Full Compliance Will be Achieved Full compliance is achieved as of this date.
3 Contrary to QAP 200-13, Station Housekeeping Organization, the inspector observed accumulations of combustible material in safety related areas including the Auxiliary Electric Equipment Room, the Cable Tunnels and the 1/2 Diesel Generator Room which were Indicative of failure to adhere i
to the above procedure.
Corrective Action Taken and Results Achieved The accumulation of combustibles in the Auxiliary Electrical Equipment Room, the Cable Tunnels, and the 1/2 Diesel Generator Room have been removed.
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addition, the other safety-related areas mentioned in the Inspection Report have been cleaned.
Corrective Action Taken to Avoid Further Noncompliance A clean up crew consisting of approximately nine people from various Station departments has been assigned to clean the plant. This crew will have no other responsibilities until such time that the cleanliness of the plant is satisfactory. Assistance in accomplishing the necessary inspections to assure that the plant remains in a state of adequate cleanliness has been assigned by the Assistant Superintendent of Maintenance.
Date Wher. Full Compliance Will be Achieved Full compliance is achieved as of this date.
4.
Contrary to QRP 100-1, Radiation Control Standards which states, "Do not eat, smoke, drink, or chew in controlled areas", the inspector observed many cigarette butts scattered throughout the Unit I and Unit 2 Cable Tunnels and an empty beer can in the Unit 1 Cable Tunnel.
Corrective Action Taken and Results Achieved A review of the posting of the Cable Tunnels has been done and have been found to be adequately posted as controlled areas. Enforcement of t%c Radiation Control Standards is an on going and continuous effort.
The time and date when this violation occurred is not known. Thus, personnel were not seen drinking and smoking in the Cable Tunnels.
if personnel are observed not conforming to any established Radiation Control Standard, appropriate action is taken.
Corrective Action to be Taken to Avoid Further Noncompliance The Station will continue the policy of training and instru: tion for all personnel in the Rad:ation Control Standards.
Observed non-conformances of the Standards will be dealt with promptly.
Date When Full Compliance Will be Achieved Full compliance is achieved as of this date.
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NRC DOCKET NO. 50-254 NRC DOCKET NO. 50-265 ATTACHMENT B A
Commonwealth Edison Attachment
' Response to Additional Concerns Response to Unresolved items items of additional concern identified in the NRC letter dated April 3, 1981 and unresolved items in the Inspection Repnrt are responded to in the following paragraphs:
1.
Tne inspector observed open hatches in the three hour rated fire barrier separating the Cable Tunnels from the Auxillary Electric Equipment Room and the Turbine Building 595' level. There is a possibility that these open fire barrier penetrations could create degraded safe shutdown capability if a fire occurred in an adjacent zone.
On January 29, 1981, the Station contacted the NRC for a resolution en I
all the hatches that enter the Cable Tunnels.
l After this resolution was obtained on January 29, 1981, signs were 1
ordered to control access through the Cable Tunnel hatches. The signs were received on March 3,1981, and installed the same week.
Since that time, the hatches have remained cicsed when the Cable Tunnels are unoccepied.
The hatches entering the Cable Tunnels from the Auxiliary Electrical Equipment Room were coated with fire retardant in the Fall of 1980 to up-grade their fire ratin9 to three hours in accordance with Section 5 3.6 of the Fire Protection Safety Evaluation Report.
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2.
The inspector identified fire hoses in the Radwt.ste Building, Of f-Gas Filter Building, Resin Solidification Building, and Naximum Recycle area that have not been hydrostatically tested in five to twelve years. There is no equipment located in these areas which is i
required for safe shutdown of the plant, but an uncontrolled fire in these areas coujd result in the release of airborne radioactive materials.
Please provide any comments or plans you have to upgrade the fire protection af these areas considering the questionable pressure boundry integrity of these hoses.
The fire hoses identified by the inspector have been upgraded with hoses that have been hydrostatically tested. These hose stations were added to the three year surveillance schedule in 1978 and were scheduled for testing in 1981.
It is our firm belief that these hoses had been tested in 1978, but records are not available to confirm this.
3 Unresolved items (50-254/81-04-04; 50-265/81-04-04) fire fighting strategies and procedures, and (50-254/81-04-08; 50-265/81-04-08) fire brigade drills.
The inspection report stated that fire fighting. strategies and procedures, and fire drills do not meet the guidelines of " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls, and Quality Assurance".
The basis for our position involves fornel submittals and meetings with the NRC which extended for a period of almost two years.
The first submittal dated April 27, 1978, specifically addresses fire fighting strategies and procedures, and fire drills in response to the Staff guidelines "Huclear Plant Fire Protection Functional Responsibilities, Administrative Controls, and Quality Assurance".
The second submittal dated July 27, 1978, also addresses fire fighting strategies and procedures.
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