ML20093D831

Responds to NRC Re Violations Noted in IE Insp Repts 50-254/83-31 & 50-265/83-30.Corrective Actions:New Procedure Providing Instructions & Precautions to Properly Change Conditions of MSIV Written

ML20093D831
Person / Time
Site:	Quad Cities
Issue date:	06/18/1984
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20093D827	List: ML20093D831
References
8780N, NUDOCS 8407170241
Download: ML20093D831 (4)

Text

/^N Commonwealth Edison fO ) Ons First Natiortti PL7za Chicigo. lihnois

( 7 ~) Address Reply to: Post Offico Box 767 (j Chicago, Illinois 60690 June 18, 1984 l

Mr. James G. Keppler Regional Administrator

.U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Quad Cities Station Units 1 and 2 Response to Inspection Report Nos.

50-254/83-31 and 50-265/83-30 NRC Docket Nos. 50-254 and 50-265 Reference (a): C. E. Norelius letter to Cordell Reed

-May 17, 1984.

(b): Bide Thomas letter to J. G. Keppler dated February 24,.1984.

Dear Mr. Keppler:

This letter is in response to the inspection conducted by Messrs. N. J. Chrissotimos and A. D. Morrongiello on November 17, 1933 thru January 24, 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 response to the Notice of Violation is provided in the enclosure.

In addition to the corrective actions stated in the enclosure, per Reference (b), Commonwealth Edison has committed to a specific

" Regulatory Improvement Program for Quad Cities Station". The actions initiated in that' program supplement the corrective actions detailed herein and will further reduce the possibility of a similar event from recurring.

If you have any_further questions on this matter, please direct them to this office.

Very truly yours, s

9'- a .

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D. L. Farr r G Director of Nuclear Licensing im Attachment JUN 191984 cc: NRC' Resident Inspector - Quad Cities

.8780N

ATTACHMENT COMMONWEALTH EDISON COMPANY RESPONSE TO NOTICE OF VIOLATION The

• tems of noncompliance identified in the appendix of the NRC letter dated May 17, 1984 are responded to in the following paragraphs:

A. Technical Specification 3.7.C.1 requires that secondary containment integrity shall be maintained during all modes of plant operation except when all of the following conditions are met: (a) The reactors are suberitical and Technical Specification 3.3.A is met; (b) The reactor water temperature is below 212 degrees F and the reactor coolant systems are vented; (c) No activity is being performed which can reduce the shutdown margin below that specified in Technical Specification 3.3.A; and (d) The fuel cask or irradiated fuel is not being moved in the reactor building.

Section 1.0.X of the Technical Specifications defines secondary containment integrity and specifies as one of its conditions that at least one door in each access opening is closed.

Contrary to the above, from 7:45 a.m. on November 10, 1983, until 1:15 p.m. on November 15, 1983, secondary containment integrity was not maintained in Unit I when two interlock doors in an access opening to the reactor building were improperly positioned open. During this period Unit 1 was operating at full power.

Discussion At 1:30 p.m. on November 15, 1983, while performing routine plant inspections, both interlock doors to the Unit 2 Main Steam Isolation Valve (MSIV) room were found to be open while the room at the time was part of the Secondary Containment. This situation resulted in Secondary Containment integrity being in a degraded mode delineated by Technical Specification 3.7.C.1. Both ventilation penetrations and floor drain penetration were isolated immediately; thus, making the MSIV room part of the Turbine Building and restoring Secondary Containment integrity. Unit 2 was shutdown for refueling and no fuel was in the reactor vessel. Unit 1 was operating at approximately 99 percent of rated thermal power.

On November 9, 1983, the MSIV room was changed to part of the Reactor Building so the water could be drained from piping located in -

the room. On November 15, Maintenance personnel were found working in the room with both interlock doors propped open. These individuals had been told on November 10 that the room was part of the Turbine Building by a Shift Engineer. The Shift Engineer had missed the log .

entry which explained the change in status.

There were no procedures which explained the necessary actions to make the MSIV room part of the Reactor Building or Turbine Building.

Also, there was no definite mechanism set-un to alert personnel at the HSIV room of the status of the room.

1. Corrective Action Taken and Results Achieved On November 15, 1983, the shift foreman recognized that the MSIV room was open to the turbine building, the ventilation and floor drain penetrations were isolated immediately.

This made the MSIV room part of the Turbine Building and restored Secondary Containment integrity.

2. Correction Action Taken to Avoid Further Noncompliance A new procedure, QOP-020-2, " Maintaining Secondary Containment Integrity with the MSIV Room Part of the Turbine Building," was written. This procedure provides instructions and precautions to properly change the condition of the MSIV room. New signs declaring the status of the MSIV room were obtained. This sign system provides better administrative controls of the MSIV room status.

3. Date When Full Compliance Will Be Achieved Full compliance is achieved at this time.

B. Technical Specification 6.2.A.1 requires that detailed written procedures shall be prepared and approved covering normal e startup, operation, and shutdown of the reactor, and other -

systems and components involving nuclear safety of the facility.  :

Contrary to the above, the licensee did not have an operating -

procedures that addressed the actions to be taken to change the configurations of the main steam isolation valve to or from its secondary containment status.

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'l. Correction Action Taken and Results Achieved

'As discussed in the corrective action for Item A, an operatingEprocedure was written detailing the actions

. required to. change the configuration of the MSIV room.

2. Correction' Action Taken to Avoid Further Noncompliance An investigation was performed of possible problem areas

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which could result in the loss of Secondary Containment.

Work! requests are now screened.to evaluate their possible ,

impact.on Secondary' Containment.

3. Date When Full Compliance Will-Be Achieved

-Full compliance is achieved at the present time.

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