ML20091C358

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Responds to NRC Re Open Item Noted in Insp Repts 50-254/92-02 & 50-265/92-02.Corrective Actions:Document Developed to Provide Tracking of Each Step from BWR Owners Group Guidelines to Actual Flowchart Implementation
ML20091C358
Person / Time
Site: Quad Cities  
Issue date: 03/30/1992
From: Kovach T
COMMONWEALTH EDISON CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9204030195
Download: ML20091C358 (2)


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C:mmtnwealth Edistn

..1400 opus Place Downers Grove. Illinois 605151 March 30,1992 U.S. Nuclear Regulatory Commission

. Washington, DC 20555

. Attn: Document Control Desk

Subject:

Quad Cities Nuclear Power Station Units 1 and 2

. Response to Open item

Inspection Repori Nos.- 50 254/92002; 50 205/92002 NBC_DacketNoL50a54.ani50 265

Reference:

.. G.C. Wright letter to Cordell Reed dated March 9,199P. transmitting NRC Inspection Report _50 254/92002; 50 265/92002 _

Enclosed is Commonwealth Edison Company's (CECO) response to the Open.

Item which was transmitted with the reference letter and Inspection Report.,The Open item concerned the completion, a aproval, and control of the Emergency Operating.

Procedures (EOP) development c ocument which describes the differences between plant

-specific guidelines and the EOPs. CECO's response is provided in the attachment.

.. lf your staff has any_ questions concerning this transmittal, please refer them to

--James Watsons Compliance Engineer at (708) 515 7205.

Sincerely, Y$

&.hy T.J. Kovach Nuclear Licensing Manager-Attachment o

cc:

A.B. Davis, Regional Administrator - Region Ill L.N. Olshan, Project Manager, NRR-

_T. Taylor,' Senior Resident Inspector -

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AIIACBMENIA RESPONSE TO.OPEN IIEM NR0_INSPECIlONBEEDBI 50 251/92002L50 265z92002 1

OpeniteffL25d(265)/9200201

-The inspector noted numerous differences between the Plant Specific Technical Guidelines (PSTG) and the EOP flowcharts which were not documented and were not

IdentiN +"'-ihe licensee's Verification and Valldation of the EOPs. These differences 1 Gen trahy,*i >. ': M sequence, changes in logic, and relocation of s invole anges in EOP structure appeared to enhance the useability of the

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these differences were not reflected in the EOP/PSTG Comparison.

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9 of the uncontrolled nature of these changes, the potential exists for in c -

J the operational strategy. intended by the PSTG. From a procedure vision standpoint, the differences between the PSTG and "lowcharts mai a

shot lied and lustified. The licensee had reco0nized the need for this docu.,

and had init ated an effort to document all differences between the PSTG 1

- and EOrs - i ne inspectors reviewed the draft " Development Document" for the three EOP flowcharts, which had nearly completed documentation, and found the level of detail was :

acceptable.- Licensee completion, approval, and control of the development document will ibe tracked as an Open item.-

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BESPONSE L

Development of the.."OGA Development Tracking" document began in September of 1991 Tnis document will provide for the tracking of each step from the BWR Owners

. Group Guidelines to the actual OGA flowchart implementation. Identified differences will

<be discussed, documented, and justified as necessary, Currently 6 of 19 Owners Group

> Guidelines have been completec.

The draft "OGA Development Tracking" document should be developed by August 31,

=1992. Allowing adequate time for_ a On-Site Review, applicable document revisions, and p

emerging Unit 1 refuel outage work, the document is expected to be implemented and

controlled by. December 31,- 1992.

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