ML20149E606

Responds to NRC Re Violations Noted in Insp Repts 50-254/87-11 & 50-265/87-11.Corrective Actions:Addl Documentation That Established Qualification of Solenoid & Parker Super-O-Lube Lubricant Obtained

ML20149E606
Person / Time
Site:	Quad Cities
Issue date:	10/01/1987
From:	Turbak M COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
3660K, NUDOCS 8801130407
Download: ML20149E606 (3)

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.D N Commonwealth Edison

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. . ~ ) One First National Plaza, Chicago, Illinois k Cl ') Address Reply to: Post Office Box 767 Nj Chicago,linnois 60690 0767 October 1, 1987 Mr. A. Bert Davis Regional Administrator U.S. Nuclear Regulatory Commission Region III 199 Roosevelt Road

. Glen Ellyn, IL 60137

Subject:

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

50-254/87-011 and 50-265/87-011 NRC Docket Nos. 50-254 and 50-265

Reference:

Letter from J. Harrison to Cordell Reed dated September 1, 1987

Dear Mr. Davis:

The referenced letter documents the results of a special safety inspection conducted by Messr. A. Gautam and other NRC representatives on your office on June 8 through 28, 1987, of activities at Quad Cities power Station Units 1 and 2.

During_the course of that inspection, certain activities appeared to be in noncompliance with NRC requirements. Attachment A to this letter contains our response to the violation.

Comonwealth Edison plans on providing you with a another response by November 15, 1987 which would address the remaining potentially enforceable items in the inspection report. Although a response was not required for these remaining items by your staff, we will be transmitting this information in an attempt to close them out.

If there are any further questions regarding this matter, please contact this office.

Very truly yours,

/ s

o. Turbak As stant Licensing Manager es i

Attachment cc: T. Ross - NRR NRC Resident Inspector - Quad Cities 3660K 00T 2 1987

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ATTACHMENT A COMMONWEALTH EDISON COMPANY RESPONSE TO NOTICE OF VIOLATION As a result of the inspection conducted on June 8 through July 28, 1987, and in'accordance with 10 CFR Part 2, Appendix C - General Statement of policy and Procedure for NRC Enforcement Actions (1985), the following violations were identified:

1. 10 CFR 50.49, Paragraph (f) requires equipment important to safety to be qualified by testing and analysis.

Contrary'to the above, the environmental qualification (EQ) files on AVCO solenoid valves did not contain adequate documentation to qualify these valves for excessive air leakage exhibited during the LOCA test, and for usage of the Super Parker 0-Lube Lubricant. Subsequent to the finding the licensee procured qualification tests and performed additional evaluations to qualify the installed valves, however, the equipment was unqualified due to inadequate documentation past the EQ deadline of November 30, 1985. This is a Severity Level IV Violation.

Discussion Rev 0 of the Target Rock /AVCO Safety Relief Valve (SRV) Equipment Qualification Binder was completed on July 6, 1984. The qualification was based on General Electric Co.'s Report No. 126-62 dated January 15, 1975. This report has shown that no significant air leakage occurred for radiation levels expected to be seen by the SRV during an6 after a postulated accident. With regard to the lubricant our report did not contain adequate documentation to establish qualification.

Corrective Action Taken and Results Achieved The initial corrective action was to obtain additional documentation that established the qualification of the solenoid as well as the Parker l Super-o-Lube Lubricant. Furthermore, we discussed the matter with the consultants that prepared the binder and re-confirmed that evidence of j qualification has to be included in every equipment binder issued.

I Corrective Action Taken To Avoid Further Violation

! The equipment binder was revised and re-submitted to the NRC RIII for review.

f Date when Full Compliance Will Be Achieved Full compliance was achieved as of the date of issue of the new equipment binder which was June 22, 1987 l

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• ITEM OF VIOLATION

2. 10 CFR 50.49, paragraph (j), states that a record of qualification, including documentation, must be maintained in an auditable form for the entire period during which the covered item is installed in the plant to permit verification that the equipment is qualified for its application and meets its performance requirements during an accident.

Contrary to the above, the environmental qualification files of BIW and OKONITE cables did not contain supporting information (such as test data, evidence of the test profile being maintained during the test, list and calibration of instruments) to permit verification that the equipment was qualified for its application. The license subsequently procured additional qualification documents to supplement their file, however, these files were not in an auditable form past the EQ deadline of November 30, 1985. This is a Severity Level IV Violation.

Discussion For OKONITE cables, extensive supporting documentation was available in the EQ File but not in the binder at the station. With regard to the .

BIW cable file the information sought by the NRC was not present in the EQ file.

j Correctivt Action Taken and Results Achieved l

l The corrective action taken was to include the EQ file information in our OKONITE EQ Binder for station use. The BIW cable additionJ1 data was obtained from the vendor.

1 Corrective Action Taken to Avoid Further Violation Additional data was submitted to the NRC Region III for review.

Furthermore, this matter was discussed with the consultants that prepared the binders, and re-confirmed that evidence of qualification has to be included in every equipment binder issued.

Date When Full Compliance Will Be Achieved l Full compliance was achieved as of the date that the information was

( submitted to NRC Region III, on July 17, 1987.

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