ML20116N811
| ML20116N811 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 11/17/1992 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9211240149 | |
| Download: ML20116N811 (3) | |
Text
_____--_ _
[
N Crmm:n";;alth Edis:n l'
) 1400 Opus PI:ce
.\\ C Downers Grove, 'nois 60515 November 17,1992 A
U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Dr:cument Control Desk
Subject:
Quad Cities Nuclear Power Station Units 1 and 2 Response to Notice of Violation Inspection Report Nos. 50-254/92022; 50-265/92022 NELC Docket Nos. 50-254 and 50-265
Reference:
B. Clayton letter to Cordell Reed dated October 21,1992 transmitting NRC Inspection Report Nos. 50-254/92022; 50-285/92022.
Enclosed is the Commonwealth Edison Company (CECO) response to the Notice of Violation (NOV) which was transmitted with the re ference letter. The NOV ched two examples of surveillance procedures where the prerequisites were not adecuate to ensure pro:)er performance of the surveillance CECO's response to the above items is providec in the attachment.
If your staff he Tuestions or comments concerning this Wnsmittal, please 9
refer them to Jim Watson, w., snce Engineer at (708) 515-7205.
Sincerely,
((hw-T.J. Kovach Nuclear Licensing Manager Attachment cc: A.B. Davis, Regional Aciministrator - Region ill L. Olshan, Project Manager, NRR T. Taylor, Senior Resident inspector
, c, m n -
9211240149 921117 PDR ADOCK 0500o254 l
G PDR
/-
ZNLD/2307/1
/
y I
RESPONSti TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-254/92022;50-265/92022
.)
YlOLKDONL(254/92022-01aLO_1b) 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings", requires, in part, that activities affecting quality be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances.
Contrary to the above:
a.
On September 2,1992, the technical specification rea%c, survelliance for turbine control valve fast closure was not performed in oordance with a documented procedure. Specifically, OOS 5600-1 "Turl51ne Control Valve Fast Closure Scram Instrumentation Functional Test" did not address adjusting the electro-hydraulic control load set at low power levels, an activity affecting quality since reactivity changes can occur from an improper adjustment.
b.
On September 4 and 5,1992,.the technical specification required surveillance for drywell air sampling, an activity affecting quality,ically, on was not performed in 1ccordance with a documented procedure. Specif September 4,1992, following completion of the sample; the sample inlet and discharge valves were closed, although this activity was not documented in surveillance procedure as OCP 1300-1 "Drywell and Suppression Chamber Venting and Purging". Or September 5,1992, the sample inlet valve was opened but the discharge valve position was not i
verified. Verification of correct valve lineup prior to taking the sample was I
not discussed in OCP 1300-1.
This is a Sev.rity Level IV violation (Supplement 1).
BEASONf_OR VIOLATICel: (Example A)
CECO acknowledges that the test procedure did not contain guidance on the proper adjustment of the load set to ensure that the bypass valves would not open during performanco of the test.
COBBECJ1VE_SIEP_S_TAKENAND_BES_ULISJACHIEVED: (Example A) l OOS 5600-1, " Turbine Control Valve Fast Closure Scram Instrumentation Functional Test", has been revised to include two additional steps. First, a precaution has been added to advise the Nuclear Station Operator of the reactor pressure and power increase which will result from the closure of the control valves. Second, a limitation and action statement has been added to ensure that the load set is approximately 20% above actual turbine-generator load prior to performance of the surveillance.
COBBEC31VE_SIEPAIHAT_WILLBE_TAKEN_IO_ AVOID _EURIHEB_VIOtATION:
(Example A)
No further corrective steps are required.
l ZNLD/23v7/2
RESPONSE TO NOTICE OF VIOLATIOr4 NRC INSPECTION REPORT -
50-254/92022;50-265/92022 s
(Continued) i DATE WHO4 FULL COMELIANCEWILLREACHIEYED: (Example A)
Full compilance was achieved on October 14,1992 when the procedure change i
to OOS 5600-1 was implemented.
BEASON FCR VIOULTION: (Example B)
CECO acknowledges that the surveillance procedure did not address verification of valve positions prior to taking the sample. Because the valves are normally in an open msition is.cocedure assumed the valves to be open. Flow was seen due to a oose hose ti, the Containment Air Monitor (CAM) providing a flow path for the September 5,1992 samples.
CORRECTIVE STEPS TAKEN AND_BESULTS ACillEVED: (Example B)
OCP 1300-1, "Drywell and Suppression Chamber Venting and Purging", has
~
been revised. A arerequisite of sampling the drywell requires the air sample and sample return va ves to be in the c. pen position or to contact operm. 's to see if the sample can be obtained. OCP 1300 S1, "Drywell and Torus Venting and l
Purging Calculation Sheet", was also revised to verify that the air samale and return valves are in the open position. The drywell air sample event o" September 5,1992 was discussed at a weekly tallgate meeting with Chemistry personnel.
I CQBBECT1VE STEPS THAT WILL BE TAKEN TO AVQlDIUBIliER VIOUL' DON:
(ExampktB)
No further corrective steps are required.
4 DATE W::04 FULL COMPLIANCE WILL BEACHIEVED: (Example B)
Full compliance was achieved on October 6,1992 when procedure OCP 1300-1 was revised and implemented.
4 l
4 e
4 t
ZNLD/2307/3
_