ML20042G350
| ML20042G350 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 05/02/1990 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 9005140131 | |
| Download: ML20042G350 (4) | |
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\\ Commonwealth Edison j
1400 Opus Pisco QLO
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Downers Grove, Illinois 60515
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b May 2, 1990 i
Mr. A. Bert Davis Regional Administrator Nuclear Regulatory Connission Region III 779 Roosevelt Road Glen Ellyn IL 60137 i
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Subject:
Quad Cities Nuclear Power Station Unita 1 and 2 Response to Notice of Violation Associated with 50-254(265)/90002 NROAckeLRau50-25Al10_2M Reference Letter dated April 4,1990 f rom II.D. Shafer to Cordell Reed.
Mr. Davis The referenced letter transmitted Inspection Report 50-254/90002 and
'50-265/90002 which contained one Notice of Violation (NOV) which cited a failure to y.eet tht reauirements of the ifro protection progrtim. The attached provides Cmwnoqwealth Edison Compeny's (Ceco) temponse to the NOV.
Plence direct any qaestions or coraments 'on thh. tranonse to P., Stols at extuncion 72C3.
Very truly yo. irs.
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Kovach Nuclear ceising Manager Attacinent cc L. Olshan - Project Manger NRR J. Ilinds - Section Chief. RIII Senior Resident Inspector. QC (M
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0959T 9005140131 900502 PDR ADOCK 05000254 Q
PDC MAY 41930
e-ATIACIBtlMT 1
RESPONSE TO NOTICE OF VIOLATION I.R. 50-254/90002; 50-265/90002 i
10 CFR Part 50 Appendix B, criterion V, states that activities af fecting quality shall be accomplished in accordance with documented procedures.
Technical Specification 6.2.A.11 states that Fire Protection Program implementation procedures shall be adhered to.
The Transient Combustible and Water Protection Surveillance Procedure. QOS 4100-15, Revision 9, Step 1, states that at the beginning and the middle of each shift, an inspection shall be conducted of each red floor area listed in this procedure to verify that no transient combustibles are present in the area without a continuous fire watch.
i The Transient Combustible and Water Protection Surveillance Procedure, QOS 4100-15, Revision 9, Step 4 defines " transient combustibles" as being such items as wood (treated and untreated), hoses, cloth, paper, flammable and combustible liquids, and compressed gas cylinders.
The Transient Combustible and Water Protection Surveillance Procedure, Q0S 4100-15, Revision 9, Step 6, lists the Unit 2 South CRD Bank on the 595 foot elevation as being red floor area 0.
Contrary to the above, on February 13, 1990, the Senior Resident Inspector tound paper and hoses in red floor area b without a continuous fire watch being present.
This is considered a Severity Level IV violatlen.
DIECUSh10N On February 2,1990, the Senior Resident Jnspector (SRI) conducted a plant i
tour.
During this tour, transient combustible materiale were identified in the Unit 2 South CRD Bank on the 595 foot elevatico tred floor area 6).
As a result of the combustible transient materials, a continuous fire watch is required. The Senior Resident inspector notified the Assistant Superintendent for Operations about the presence of combustible material in the red floct l
area. The Assistant Superintendent for Operations ordered a continuous fire watch for this area immediately.
Quad Cities Operating Surveillance, QOS 4100-15. " Transient Combustibles and Water Protection Surveillance" is conducted twice per shift. The purpose of this surveillance is to verify that no transient materials are present in specific areas without continuous fire watches.
The procedure requires that all discrepancies identified as a result of the surveillance be reported to the Fire Marshall or Shift Foreman, in the event the Fire Marshall is not on site.
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t On F;bruary 2,1990, QOS 4100-15 w:s performed twice per shift cs required. The first inspection performed during Shift 2 (days) identified the area in question as unacceptable.
It could not be positively identified when the' Fire Marshall was notified of the condition; however, Quad Cities Station has concluded that the resolution of the unsatisfsetory condition was not timely.
The cause of the transient materials being present in the Unit 2 CRD Bank (Red Floor Area 6) was due tot (a) The Administrative Procedure in place on February 2, 1990 did not require that the Fire Marshall approve the introduction of the transient material into the plant, and, (b) Procedure QOS 4100-5 does not communicate the expectation for timely resolution of the condition, i.e., the establishment of a continuous fire watch within one hour following the identification of the unsatisfactory condition.
In response to Notice of Violation, 50-265/89023-01 dated December 21, 1989, Commonwealth Edison committed to revise QAP 1700-1, Flammable and Combustible Material Control by February 5, 1990.
The response indicated that the procedure would be revised to require that the Fire Marshall approve the introduction of transient materials into the plant and that transients would be tracked via computer program. On February 2, 1990, the implementation of the corrective actions to require the Fire Marshall's approval of transient materials was not complete. Some difficulty was encountered with the implementation of the computer program and the associated Administrative Procedure; however, the problems have been subsequently resolved.
The Admfuistrative Procedure and the associated computer program was fully implemented on March 29, 1990.
l 14UQEilAUJUoLC0AET Pa_DEELCIENCY An indstatej !s the Discussion, a continuous fire watch vae initiated by the Aosistant Superintenderat for Operations following the discussion with the SRI.
l C01EC21HJCT10'IS 1AKFJLTO PREYENI_EUElllER_ lion 0.0tiF11ANME 1.
As pre"fously discussed, the revision to QAP 1700-1 has been implemented and requires the Fire Marshall to approve the introduction of transient materials into the plant.
2.
Quad Cities Operating Surveillance, QOS 4100-15 will be revised to L
require that in the event transient materials are found in a restricted area without a continuous fire watch, a continuous fire watch will be initiated within one hour. The revision will be impicmented by July 31, 1990.
3.
Training will conducted for the Operations Department on the procedure revision by August 15, 1990.
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As an. int ria measure pri:r ta revicion cf the proc:duro rcvision, th2 As.sistant. Superintendent for Operations will assure that Operating crews are aware.that if a red floor area contains combustible materials without a continuous fire watch, a continuous fire watch will be established within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or the transient combustibles will be removed.
l DATE.WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on February 2, 1990 when the continuous fire watch was instituted.
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