ML20079C908

Suppls 900817 Response to Violations Noted in Insp Repts 50-254/89-24 & 50-265/89-24.Corrective Actions:Individual Leakage Limits Established,Use of Problem Analysis Data Sheets Will Be Required & Leakages Will Be Trended

ML20079C908
Person / Time
Site:	Quad Cities
Issue date:	06/19/1991
From:	Stols R COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 9106260303
Download: ML20079C908 (2)

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June 19,1991 Mr. A. Bert Davis Regional Administration U.S. Nuclear Regulatory Commission

- 799 Roosevelt Road -

Glen Ellyn,IL 60137

Subject:

Quad Cities Nuclear Power Station Ur$its 1 and 2 Response to Notice of Violation Contained in Inspection Report 50-254/89024 and 50 265/89024 .

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References:

(a) T.J. Kovach to A.B. Davis letter dated August 17,1990 (b)- H.J. Miller to Cordell Reed letter dated October 25,1990 Mr. Davis, in the reference (a) letter, Commonwealth Edison provided a response to a Notice of Violation which cited ineffective corrective actions in res aonse to component failures during the conduct of 10 CFR 50 Appendix J local leak race testing. In that res aonse, Commonwealth Edison committed to develop a preventative / predictive ma ntenance program based on the review of the maintenance and test history for all containment components, which maintain containment integrity.-

Following the issuance of our response, members of Commonwealth Edison's and NRC s staffs met on September 25,1990 to discuss our corrective actions. Reference (b) transmitted the summary of the meeting. Based on NRC

_ comments during that meeting, Commonwealth Edison reassessed the methodology

. for the development of the predictive / preventative maintenance program to identify a-more timely, yet effective, method.

The primary objective of the p maintenance actions for components pn,rogram was to identify for theand initiate r or to failure. Our initial methodology

' development of the program included a review of all maintenance and test history of each component, which is'very resource-intensive. As such, Guad Cities Station personnel developed component " action" leakage limits at which maintenance would be required. The limits were defined based on readily available information and therefore maintenance history research is no longer required.

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Mr. A.B. Davis June 19,1991 The predictive / preventative containment component maintenance program has been developed and consists of the following elements:

(a) Individual leakage limits, which impose maintenance requirements based on valve size or component type, have been established; (b) an administrative as-left maximum pathway leakage limit (75% of the 0.6 La leakage requirement) has been established to create additional margin for the overall containment leakage; (c) the use of problem analysis data sheets (PADS), which are a tracking and resolution mechanism for recurring pro'olems, will be required; (d) the individual component leakages will be trended on a refueling cycle basis; (e) the trends for the individual components leakage rates will be reviewed to assess the 3erformance of each component and to identify and recommenc additional corrective actions to be implemented during the next refueling outage.

The above program was developed for use during the November,1990 Unit 1 Refueling Outage. The implementation of the program was determined to be effective.

The as-left maximum pathway leakage of the containment following the implementation of this program was 59% of the 0.6 La leakage limit requirement.

Finally, the post outage review of component performance will be conducted by Corporate and Station test engineers (including at least one test engineer from personnel. The results of the review and the another CECO facility)be recommendations will provided to various departments within the CECoand maintenance organization, including Quality Programs and Assessment.

If there are any questions or comments regarding this topic, please contact R. Stols at (708) 515-7283, Very Truly Yours, f $<h Rita Stols Nuclear Licensing Administrative cc: L.N. Olshan, Project Manager, NRR F.A. Maura, inspector, Region 111 T.E. Taylor, Senior Resident inspector Document Control Desk I

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