ML20062N860
| ML20062N860 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 01/10/1994 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9401240141 | |
| Download: ML20062N860 (3) | |
Text
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N Comm2nwstith EdlIcn C /
1400 Opus Place
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C Downers Grove, lilinois 60515 January 10,1994 U. S. Nuclear Regulatory Commission Washington, D. C. 20555.
Attn: Document Control Desk
Subject:
Quad Cities Power Station Units 1 and 2; NRC Docket Number 50-254 and 50-265; NRC inspection Report Numbers 50-254(265)/93026
Reference:
Edward G. Greenman letter to R. Pleniewicz dated December 9,1993, transmitting Notice of Violation with Insoection Reoort 50-254/93026: 50-265/93026 f
Enclosed is the Commonwealth Edison response to the Notice of Violation (NOV) transmitted with the referenced letter. The NOV cited one Severity Level IV violation for l
inadequate corrective actions in reference to the halon actuation on October 4,1993.
t if there are any questions or comments concerning this letter, please refer them to Marcia Jackson, Regulatory Performance Administrator at (708) 663-7287.
Respectfully, i
h D. L. Farrar, Manager Nuclear Regulatory Services Attachment i
cc: J. Martin, Regional Administrator, Rlli C. Patel, Project Manager, NRR T. Taylor, Senior Resident inspector, Quad Cities
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Response to Notice of Violation NRC Inspection Report 50-254/93026;50-265/93026 VIOLATION: 254(265)/93026-01 10 CFR 50, Appendix B, Criteria XVI requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, j
deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
i Contrary to the above, corrective actions taken to ensure that appropriate documentation was in place prior to performance of plant activities, in response to a December 1992 unauthorized installation of a tygon tubing, were inadequate. On October 4,1993, the licensee performed an unauthorized test of the computer room heating, ventilation, and air conditioning (HVAC) in-line duct heaters.
This is a Severity Level IV violation (Supplement 1).
REASON FOR THE VIOLATION:
CECO acknowledges the violation. Work was being performed to verify suitable operation of the computer room HVAC system heaters in anticipation of impending winter temperatures. Work control procedure QCAP 307-14, " Initiation and Control of Blanket Work requests" provides the definition for blanket work requests used for minor miscellaneous activities which do not require work instructions. Due to a personnel error in interpretation of the definition, this work was being performed via the blanket work i
request program and therefore, was without specific instruction or guidance as allowed i
by the procedure.
4 During performance of the pre-winterizing check of the in-line duct heater, personnel did not anticipate actuation of the fire detection system via accumulation of dust on the heater elements' surface from the previous 6 years of idle operation. Upon actuation of the heaters, the accumulated dust subsequently free floated into the control room HVAC duct work space and came into contact with the dust sensitive ionization fire detectors resulting in the halon discharge into the computer room, CECO agrees that interpretations and instructions provided for this activity did not include the appropriate criteria for determining that the activities were satisfactorily controlled and completed.
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OORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
The system engineer discontinued any further pre-winterizing tests on non-power block HVAC heating coil systems until suitable proceduralinstructions have been developed to control the evolution.
CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATION:
Work control procedure QCAP 307-14 will be revised to further define limitations of blanket work requests applicability to work activities. OCAP 307-14 will also be revised to clarify what constitutes adequate work instructions / precautions for miscellaneous equipment with alarm / actuation functions.
Additionally, the system engineer is reviewing the design and location of dust sensitive detectors to identify inadvertent actuation potential during normal heating season.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
The proceduralinstructions for non-power block HVAC heating coil equipment and the revisions to QCAP 307-14, " Initiation and Control of Blanket Work Requests", will be completed by March 31,1994.
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