ML20043A574
| ML20043A574 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 12/21/1989 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 0291T:1, 291T:1, NUDOCS 9005220261 | |
| Download: ML20043A574 (5) | |
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I Commonwealth Edson O~
One First National Plaza, ChicaLo. Illirds 4ddress Feply to Fost 6ffEe Box 76F Chicago, llhnos 60690 0767 December 21, 1989 Mr. A. Bert Davis Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn IL 60137
Subject:
Quad Cities Station Units 1 and 2 Response to Notice of Violation-Contained in Inspection Report No.
50-254/89023 and 50-265/89023 NRClacktL}1ca. 50-254 and 50-215 Reference Letter f rom H.J. Miller to Cordell Reed dated November 24, 1989 transmitting IR No. 50-254/89023 and 50-265/89023 Mr. Davis Enclosed is the Commonwealth Edisou response to the subject Notice of
-Violation (NOV) which was transmitted with the referenced letter and Inspection Report. The NOV cited various examples which were not in compliance with the fire protection program, as described in the Station. Procedures.
Commonwealth Edison understands the significance of the issues involved and the need for effective corrective actions to prevent recurrence, commonwealth Edison also appreciates the recognition of our self-assessment activities in identifying weaknesses in'the control of transient combustible in the plant.
Quad Cities Station is aggressively pursuing the implementation of the recommendations provided by the internal assessment team.
Very truly yours.
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A T.J. K vach Nuclear Licensing Manager im
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Attachment 4
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cc:
T.M. Ross - Project Manager, NRR l
R.M. Lerch - Region III
.i R.L. Higgins - Senior Resident Insp, ator, Quad Of ties
.j 9005220261 891221 PDR ADOCK 05000254 Ogg *o I N 0291T11-G!
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ATTACIEENT A l
EESf_QNSE TO NOTICE OF VIOLATION 50-254/89023; 50-265/89023-j 1101AT10N Technical Specification'6.2.A.11 requires adherence to fire protection program implementing procedures.
l As specified below, Flammable and Combustible Materials Control.
Procedure QAP 1700-1, and Station Housekeeping Procedure-QAP 1700-5 require the following:'
1.
Step C.4.k of QAP 1700-1 and Steps 0.1.o, p and q'of QAP-1700-5-require, in areas containing safety-related equipment, that1 excess combustible materials (e.g.-scrap and unused material) resulting from a work activity ~
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j be removed following completion of.the activity or at the end of the work shift, whichever comes first'.- Eacess combustible materials required for I
continuation of the work activity may remain in the area provided the' area is not left unattended.
'i 2.
Step C.4.j of QAP 1700-1 requires thai all desks,. tables, etc., used inside any Station structures be of suitable non-combustible' construction unless prior npproval was' obtained from the Fire Marshal or his designee.
q 3.- Step C.S.a of QAP 1700-1 requires that compressed gas cylinders be firmly secured by means of a chain or other approved device attached'to a-permanent cylinder rack, cylinder truck, welding cart rack or cylindor i
lifting rig.
4.
Step C.5.h(10) of QAP 1700-1 requires that compressed gas cylinders not.be p
secured to conduit and implies that mounts not. intended for securing gas.
l cylinders not be used.
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Step C.S.b of QAP 1700-1 requires that compressed gas cylinder valve 5
protection caps be occurely in place except when-a cylinder is in use or connected for use.
p 6.
Step C.5.f(12) of QAP 1700-1 requires that compressed gas cylinders not be stored within twenty feet of flammable or combustible liquids unless separated by an appreved non-combustible wall.
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7.
Step C.8.b(4) of QAP 1700-5 requires that common. combustible material not E
be stored in safety related-areas.
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o Contrary to the above, the fire protection program implementing l
procedures were not being adhered to as detailed in the examples listed below.
The inspector made the following observations during one or more plant tours conducted both during day shift and off-shift hours on October 16, 17, 18 and
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l 19, 19891 1.
a.
Several stacks of excess unused combustible mater.lels (rolled and' I
rectangular absorbant materials) were found left unattended in the Unit 2 Diesel Generator Room while no work activity was evident.
b.
Three yellow bags containing plastic hoses were found left unattended (lying adjacent to an Appendix R designated fire barrier) in the Unit i
2 Reactor Building, 647' elevation while no work activity was evident.
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c.
A plastic bag of combustible rags was found (adjacent to a
" combustible f ree zone") lef t unattended in the Unit 2 Turbino Building, 639' elevation while not work activity was evident.
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2.
A wooden table, chair and electronic equipment with plastic housing (each i
having inherent combustible characteristic) that were not approved by the Station Fire Marshal or his designee were found in-the Unit 1/2 Auxiliary l
Electric Equipment-Room.
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3.
Several individual oxygen and acetylene compressed gas cylinders were L
found not in use and in an unsecured condition (a loose metal chain was in place but dangling around the lower portion of the_ cylinders) in the Unit 2 Turbine Building, turbine deck level.
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An argon cylinder was found improperly chained to an instrument air line support in the Unit 2 Reactor Building, ground floor, at the south wall
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across from the south bank of control rod driver.
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An oxygen / acetylene unit which was not in use and not: connected for use l
was found unattended in the Unit 2 Turbine Building, 615' 6" elevation a
without the gas cylinder's valve protection caps in place.
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An oxygen / acetylene unit which was not in use and not connected for use was found immediately adjacent to an unattended 55 gallon drum of lube oil l
in the Unit 2 Turbine Building, 611' 6" elevation.
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Two (per unit) pan configured cardboard boxes were placed in and on cable trays marked as ESS 11 type trays with a plastic hose running'into red plastic buckets to catch the oil leakageLin the Unit 1/2 Turbine Building, ground floor, outside the main steamline isolation valve room and the "D" Heater Bay area.
l This is a Severity Level IV Violation (Supplement 1).
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I DISC 11SS10E i
Quad Cities Station concurs that the items identified by the NRC-Inspector are not consistent with the requirements of the Station Administrative Procedures. As discussed in the transmittal letter, Commonwealth Edison's l
self-assessment team identified similar weaknesses in the control of transient l
combustibics. Quad Cities Station is currently developing a computer program L
for tracking of transient. combustibles, as recommended by the internal self-assessment. The use of the computer program, in addition to the training and-tailgate sessions, should prevent reccurence.
j Commonwealth Edison has recognized the need for more effective
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controls associated with non-station personnel and is currently developing a i
Nuclear Operations Directive on the control of non-station personnel. The issue of non-station personnel awareness of transient combustible control-requirements is addressed in the draft direct!ve currently under review by the Stations.
ACTIONS TAKEN TO CORRECLTHE DEFICIENCIES Item 1.
The rolled and rectangular absorbent material, yellow bags-l containing plastic hoses and plastic bags ce'ntaining rags were removed since the work activities hsd been completed.
Item 2.
The wooden table, chair and electronic equipraent with plastic -
housing were removed from the Unit 1/2 Auxiliary Electric Room.
l The responsible. individual was counseled on the need for Station Fire Marshall approval of transient combustibles in the plant.
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Items 3-5.
The compressed gas cylinder bottles were correctly secured with a chain.
Protection caps were installed for the cylinder bottles not being used.
l Item 6.
The 55 gallon drum of' lube oil was removed from the plant.
The oxygen / acetylene unit had been properly secured and capped and therefore, no corrective actions were required.
Item 7.
The plastic hose and the plastic buckets have been removed; however, the pans remain in place. The pans described as
" configured cardboard boxes" placed in and on acable trays marked -
as ESS type trays are made of fire-proof insu)-ted metal. The insulated material which covers the metal surface on the outside L
provides the appearance of cardboard.
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. CORRECTIVE ACTIONS' TAKEN TO AVOID FURTHER RQNQQt1ELJAl(CES 1.
Quad Cities is currently in the process of implementing a new computer program which will track transient combustible material in the plant. The computer program will allow for the identification of transient combustible matcrial quantity, location-and BTU content to ensure effective controls of transient combustible materials. The. procedure on flammable and combustible control. Quad Cities Administrative Procedure QAP 1700-1, will be revised to require that transient' combustible information be entered into the. computer prior to approval of transient combustible material in the plant.
The implementation of the computer program and revision to QAP 1700-1 will be completed by February 5,1990.
2.
A tnilgate session'will be held with Station personnel to emphasize the proper storage methods for combustible material while work is in progress and the removal of transient combustibles following the completion of a f
job. The proper methods 'or securing compressed gas cylinders will also be discussed. The tailgate sessions will be completed by February 5,-1990.
3.
The Station procedure on flammable and combustible material was included in the Contractor training program on October 13, 1989.- The inclusion of this Station procedure in the training program will ensure that contractors are cognizant of Station requirements for the introduction of transient combustible in the plant as well as disposition following the completion of work. The revised training program requirements will be implemented during the upcoming Unit 2 Refueling Outage.
4.
The Fire Marshall and Assistant Fire Marshall will increase their tours of the plant prior to the implementation of the computer program for' transient combustible materials. The increased tours will be returned to normal-frequency when the Fire Marshall is arscred that the implementation of.the computer program and tailgate sessions are effective in preventing recurrence of the items' identified by ;he NRC-Inspector.
5.
During periods of high contractor activity, typically during Refueling Outages, the Fire Marshall and Assistant Fire Marshall will augment their plant tours to ensure that the enhancements to the contractor training program are effective in preventing recurrence of contractor-related
.noncompliances with the Station flammable and combustible material program.
E DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED a
Full compliance was achieved during the course of the NRC. Inspection when the corrective actions were completed for the items identified.
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