ML20093B521

Responds to NRC Re Violations Noted in Insp Repts 50-254/84-08 & 50-265/84-07.Corrective Actions:Type a Test Procedures Changed During Pressurization & Stabilization Phases to Estimate Leaks

ML20093B521
Person / Time
Site:	Quad Cities
Issue date:	09/06/1984
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20093B517	List: ML20093B521
References
9135N, NUDOCS 8410100113
Download: ML20093B521 (4)

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September 6, 1984 Mr." James G. Keppler Regional Administrator U.S. Nuolear Regulatory Commission Region III 199 R.oosevelt Road Glen Erlyn, IL 60137 i

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Subject:

Quad Cities Station Units 1 and 2

.1 Response to Inspection Report

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Hos. 50-254/84-08'and 50-265/84-07 NRC Occket Nos. 50-254 and 50-265

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Reference (a):

C. E. Norelius letter to Cordell Reed dated. August 3, 1784

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Dear Mr. Xeppler:

2 This letter is in response to the inspection conducted by l.

Messrs. A. L. Madison, A. D. Morrangiello, J. C. Bjorgen, S. Hare and F.

Maura on May 20 through June 23, 1984, of activities at Quad Cities Station.

Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements.

The Commonwealth Edison Company j

response to the Notice of Violation is provided in the enclosure.

If you have any further questions on this matter, please direct them to this offico.

Very truly yours, J

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O. L. Farrar Director of Nuclear Licensing im Attachment CC:

NRC Resident Inspector - Quad Cities-8410100113 e41094

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COMMONNEALTH EDISON COMPANY I

ATTACHMENT l

Response to Notice.cf Violation Tne following is the response to the items of noncompliance identified in the Appendix to the NRC letter dated August 3, 1984, from

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C. E. Norolius to Cordell Reed.

ITEM l l

10 CFR 50, Apoendix J,Section III.A.1(a) required that if during a Type A test potentially excessive leakage paths are identified which will ' interfere with satisfactory completion of the test or which will result in a Type A test not meeting the acceptance criteria, the Type i

A test shall be te) ;inated and the leakage through such paths shall

- ge measured using local leakage testing methods.

Repairs and/or

-adjustments to equipment shall ne made and a Type A test shall be performed.

contrary to the above, during the performance of Type A tes~t in February 1984 a leaking flange on a 1/2 inch torus level instrument line was repaired without first measuring its leakage rate.

CORRECTIVE ACTION TAXEN AND RESULTS ACHIEVED The corrective action taken was to change the Quad Cities procedures for the Type A test, QTS 150-1 and 150-6.

The procedure used for the Unit 2 test included references to estimating localized leaks discovered during the pressurization and stabilization phases of the test.

These Cections were removed and replaced with words stating that the leaks must be measured prior to repairs.

CORRECTIVE ACTION TO AVOIO FURTHER NONCOMPLIANCE All Technical Starr personnel involved in conducting the Typ1 A test cere given training in test metnods and regulatory requirements prior to performing the Unit i test,on July 25-26, 1984.

All procedure changes, including the ones mandated by this noncompliance, were discussed.

Strict adherence to the revised procedure was verified by the NRC inspector for the Unit 1 test.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The corrective actions described above have been implemented and full compliance achieved.

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ITEM 2 10 CFR 50, Appendix J, Section II.G defines Type B tests as those tests intended to detect local leaks and measure leakages across each pressure-containing or leakage-limiting coundary for containment penetrations whose design incorporates gaskets,among others.

Section 111 & describes the Type B test acceptable methods,- test pressure,

.and acceptance. criteria.

Section III.O.2 prescribes the scheoule and

!freqpency of _ Type B test to be at every refueling outage but in no case at intesvals exceeding 2 years.

Contrary to the'above a Type B local leak rate test has not been performed on a 1/2 inch torus-level instrument line flange since it was origina,1y declared operable on February 1981.

1 CORRECTIVE ACTION TAXEN AND RESULTS ACHIEVED This item of noncompliance was the result of a modification to the

' instrument lines when the level transmitters were installed and subsequently relocated without including a Type B test as part of the codification test.

Tne immediate corrective action to this noncompliance was to write a local leak rate test procedure, QTS 100-40, for the instrument volumes with the flange gaskets.

This proceduru was implemented in July, 1984.

Local leak rate tests will be performed on l

both units for each instrument of this type on each subsequent refueling cutage.

The instrument lines were Type 8 tested with no detectable leakage on Unit 1 prior to its startup in August, 1984.

CORRECTIVE ACTION TAXEN TO AVOIO FURTHER NONCOMPLIANCE For this item of noncompliance, the following additional actions have been taken to avoid further noncompliance:

1.

The noncompliances issued to the Quad Cities Station have been placed on the agenda for discussion at the next Commonwealth Edison ILRT Committee meeting to make all Commonwealth Edison nuclear stations aware of the circumstances involved.

2.

Since the prim'ary responsibility for modification test criteria rests with the' cognizant person in the station Technical Staff, additional training concerning the definition of the primary containment boundary and testing requirements following any modification to that boundary was provided to all Technical Staff personnel.

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An engin?.ering review of the Quad Cities piping and instrument drawings was conduct'ed to identify ~ the presence of any other pipe flanges with gaskets that might be present without being LLRT'd.

No other gaskets like the ones in question were identified.

e DATE WHEN FULL COMPLIAMCE WILL' BE ACHLEVED l

i The corrective actions listed aboy.e have been implemente'd and full

.I compliance is achieved at this time.

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