ML20054H921
| ML20054H921 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 05/27/1982 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20054H920 | List: |
| References | |
| 4224N, NUDOCS 8206250198 | |
| Download: ML20054H921 (5) | |
Text
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30 A Commonwealth Edison f
) one First National Plan, Chicago. Illinois
=
Addr:ss Reply ty Post Office Box 767 v
Chicago, Illinois 60690 May 27, 1982 Mr. James G. Keppler, Regional Administrator Directorate o f Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Quad Cities Station Units 1 and 2 Response to I.E.
Inspection Report Nos. 50-254/82-07 and 50-265/82-08 NRC Docke t Nos. 50-254 and 50-265 References (a):
W. S. Little letter to Cordell Reed dated April 15, 1982.
(b):
C. E. Norelius letter to Cordell Reed dated May 1,1981.
i (c):
J. S. Abel letter to J. G. Keppler dated May 26, 1981.
(d):
J. S. Abel letter to J. G. Keppler dated June 15, 1981.
(e):
L. DelGeorge letter to J. G. Keppler dated August 12, 1981.
(f):
L. De1 George letter to J. G. Keppler dated September 28, 1981.
I
Dear Mr. Keppler:
Reference (a) transmitted the results o f an inspection conducted by Mr. M.
Holzmer on March 1,1982 of activities at the Quad Cities Nuclear Power Station.
The attachment to this letter provides the Commonwealth Edison Company response to the item of noncompliance identified in the subject inspection report.
The required response date was extended to May 28, 198 2 i n a Ma y 10, 1982 telephone discussion with Mr.
W. Little o f your staf f.
As indicated and explained in the attachment, we feel that a non-compliance is not warranted.
Further, the citation of the items as being a repetitive non-compliance as well as assigning a Severity Level IV to the item, are not believed to be correct.
B206250198 820622 PDR ADOCK 05000254 O
PDR 33 3g
J. G. Keppler May 27, 1982 Non-compliance Item No.1 (Severity Level V) identified in the Reference (b) Inspection Report No. 50-254/81-03; 50-265/81-03 involved an apparent lack o f implementation o f ANSI N18.7-1976.
During subsequent discussions and correspondence (see References (c)
- (f)), it was concluded that ANSI N18.7-1972 was the applicable document to Quad Cities Station, and it was our understanding that not only was this non-compliance resolved, it was never an actual item o f non-compliance to begin with.
Since we had complied with the standard in effect at the time the operating license was issued for the plant, we felt that no violation had actually taken place.
Therefore, bringing up the Reference (b) item related to plant records as a repetitive item of non-compliance in the subject Inspection Report is not appropriate.
In the NRC Enforcement Policy, 47 FR 9987 (March 9, 1982),
the following statements are made concerning a Severity Level IV Violation:
A.
Section III
" Severity Level IV violations are less serious but are of more than minor concern; i.e., if left uncorrected, they could lead to a more serious concern.
Severity Level V violations are of minor safety or environmental concern."
8.
Supplement 1 (the category referenced by the subject Inspection Report)
" Severity IV - Violations involving:
1.
10 CFR 50.59 that do not result in a Severity Level I, II, or III violation.
2.
Failure to meet regulatory requirements that have more than minor safety or environmental significance; or 3.
Failure to make a required Licensee Event Report when the reported matter does not constitute a violation."
C.
Supplement II
" Severity IV - Violation involving failure to meet regulatory requirements including one or more Quality Assurance Criteria not amounting to Severity Level I, II, or III violations that have more than minor safety or environmental significance."
Further,Section III of the Enforcement Policy states that "The severity level of a violation may be increased if the circumstances surrounding the matter involve careless disregard of requirements, deception, or other indications o f willfulness."
J. G. Kepple r May 27, 1982 The apparent item of noncompliance in the subject Inspection Report does not in any way constitute an item of "more than minor concern", or o f "more than minor safety significance."
It is our firm conclusion that the severity level should not be increased in this case, since no " careless disregard, deception, or willfulness" was ever intended or involved.
Please address any questions you may have concerning this matter to this office.
Very truly yours, L. O. DelGeorge Director of Nuclear Licensing TJR/lm Region III Inspector - Quad Cities SUBSCRIBED and SWORN to before me this $7 day of wa/
i, 1982 l
'unda$A1 A-Notary Public 4224N l
COMMONWEALTH EDIS0N COMPANY Attachment Response to Notice of Violation NRC Docket Numbers 50-254 and 50-265 The item of Non-compliance identified in the Appendix to the NRC Ictter dated April 15, 1982 is responded to in the following paragraphs:
Commonwealth Edison Company had committed to the requirements of ANSI N45.2.9 1974 and to ANSI N18.7-1972 through Regulatory Guide 1 33 (Safety Guide 33-November 1972) as stated in the Quality Assurance Program Topical Report, CE-1-A, Revision 19 1.
ANSI N45.2.9 states " Permanent and temporary record storage facilities shall be constructed or located as to protect contents from possible j
destruction..." and "A satisfactory alternative to the establishing of a record storage facility is maintenance of duplicate records stored in a separate storage location."
Contrary to the above, the following completed records were not stored in two or more locations or stored so as to be protected from possibic destruction:
(1)
Completed Work Requests.
(2) Completed Work Packages.
2.
ANSI N18.7-1972 states in Paragraph 5.1.2, " Procedures shall be followed..."
Commonwealth Edison Quality Assurance Procedure Q.P. 17-51 stated that lifetime station generated Quality Assurance records are to be transferred to the Of fice Supervisor.
QDM-6 states " Active files are purged of lifetime retainable QA records by the Central File Supervisor according to the QDM proce-dures, retention schedule, and R3 system."
Contrary to the above, lifetime QA records were retained in the active files in excess of one year as specified in the Master Retention Schedule.
Examples include completed surveillance data sheets and completed Work Requests.
Discussion:
With regard to item 1 above, Quad-Cities Station feels that it is presently implementing ANSI N45.2.9-1974 (Draf t 15, Revision 0, April 1974) as committed in the Quality Assurance Program Topical Report, CE-1-A, Revision 19, in the required manner. The Inspection Report states that the Station felt it did not have a commitment to ANSI N45.2 9, since ANSI N18.7-1976 committed auto-matically to ANSI N45.2.9, and ANSI N18.7-1972 did not.
Contrary to this,
t Quad-Cities Station has been and still is of the position that it is commi.tted to ANSI N45.2 9-1974. The Station's Record-Retention-Retrieval (R3) System and the associated implementing procedures are developed to implement this Standard.
The Station further feels that the storage capabilities provided for its active files are in full compliance with ANSI N45.2.9-1974.
Sections 5.4. and 5.6. of the Standard give requirements pursuant to preservation and storage of records.
In particular, Section 5.4(1) and 5.4(2) address prevention of damage from condensation and not storing records in a loose fashion. The items mentioned in the inspection report,, completed work requests and work packages, are stored so as to meet these Criteria.
Section 5.4(2) goes so far as to say that " steel file cabinets are preferred." Per this sentence, steel file cabi-nets are not even required.
Yet, our records are stored in steel file cabinets so thus exceed the guidelines of the Standard.
The Station is of the position that compliance with Section 5.6 of ANSI N.45.2 9-1974 is achieved.
Records are protected from possible destruction by fire by the following means:
1.
Records are kept in steel file cabinets. Wooden cabinets are not used.
2.
The Service Building and the new addition are both fire-resistive, as described in NFPA 232-1975 Fire hoses and extinguishers are available and located for use should a fire occur.
3 The office areas are those with a minimum amount of combustibles present.
Congestion of files is minimal.
4.
The plant is occupied 24-hours a day. Security guards patrol the service building routinely during off-shifts, and any fire would be detected and extinguished in a manner to minimize any damage.
Section 5.6 goes on to state that records "should be afforded the equivalent protection of a NFPA Class A, four hour minimum rated facility." Since the word "should" is specified, there is no requirement for a four-hour rated facility for record storage. The Station does, however, have a permanent record storage facility that meets the requirements of Section 5.6 of ANSI N45.2 9-1974.
This building was completed in 1976, and houses those records set aside for permanent, lifetime storage at the facility.
With respect to the retention of records in active files addressed in item 2 above, the Inspection Report Indicates that surveillance data sheets are life-time records. Per the Technical Specifications and the Master Retention Schedule, these records are to be retained for only five years. The purging of active files per QDM-6 has been reviewed.
Surveillance records will be addressed in a revision to QDM-6 so as to allow the oldest document in the active files to be two years. Active files involving completed work requests will be purged every six months to assure compliance with the Master Retention Schedule. The Schedule itself will be reviewed for possible changes to facili-tate more efficient operation of the Central File. Microfilming of records has been prioritized such that the more frequent purging of active files may be accomplished.
The revision to QDM-6 will be implemented by July 1,
1982.
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