ML20151R398
| ML20151R398 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 08/01/1988 |
| From: | Bliss H COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8808120154 | |
| Download: ML20151R398 (3) | |
Text
CN Commonwealth Edison -
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One Fird National Plan Chicago, Illinois
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Adoress Reply to: Post Office Box 767
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Chicago, IUinois 60690 - 0767 August 1, 1988 Mr. A. Bert Davis 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.
50-254/88016 and 50-265/88016" URC Docket Hot, 50-254 and 50-203_.
Reference (a):
Letter from H.J. Miller to Cordell Reed dated Tuly 1, 1988.
Dear Mr. Davis This letter is in response to the inspection conducted by Mr.11.
Mendez of your staff during the period June 7, through June 15, 1988 of certain activities at Quad Cities Station. The referenced letter indicated that certain activities appeared to be in noncompliance with NRC requirements and required a written response. The Commonwealth Edison Company's response tc the Notice of Violation is provided in Attachment A.
If you have any further questions regarding this matter, please direct them to this office.
Very truly yours, t
ma h.S.s H. E. Bliss uclear Licensing Manager 1m Attachment At Response to Notice of Violation cci NRC Resident Inspector - Quad Cities i
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' ATIACIMENT A COMMONWEALTH EDISON COMPANY RESPONSE TO NOTICE OF VIOLATION As a result of the inspection conducted on June 7-15, 1988, the following violation was identified:
ITEM OF VIOLATIOH1 10 CFR Part 50, Appendix B, Criterion V, as implemented by Commoawealth Edison Quality Assurance Manual, states that activities affecting quality shall be prescribed by documented procedures or instructions and shall be accomplished in accordance with those procedures or instructions. Quad Cities Equipment Out-of-Service Procedure QAP 300-14 requires that all safety related equipment out-of-services and temporary lifts shall be independently field verified. Contrary to the above, on June 12, 1988, the operator in charge of performing the temporary lif t on the 2A Containment Atmospheric Monitoring (CAM) Post-Accident H /02 system did not field verify the status 2
of the monitors. Consequently, the monitor which was disconnected caused the drywell to leak excessively into the Reactor Building prior to the start of the integrated leak rate test.
This is a Severity Level IV.
DISCUSSION:
On June 12, 1988, at 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br />, Unit Two was in the SHUTDOWN mode at zero percent thermal power. Technical Staff Personnel were performing QTS 150-1 (Integrated Primary Containment Leak Rate Test). While performing the surveillance, test instrumontation Jrdicated a leakage of approximately 1.3 wt
%/ day.
Efforts at this time were made to locate the source of leakage. On June 13, 1988, at 0225 hours0.0026 days <br />0.0625 hours <br />3.720238e-4 weeks <br />8.56125e-5 months <br />, the leakage path was identified to be a Contain-ment Atmospheric Monitoring (CAM) % inch line (which had its isolation valve (2-2499-20A) temporarily lifted and opened to satisfy the requirements of the Containment Leak Rate Test procedure).
The 2A CAM is located in a locked cabinet on the north wall of the Unit Two Reactor Building. The 2-2499-20A valve is located approximately one foot above the locked cabinet. The temporary lift involved opening the 2-2499-20A so that tha Containment Leak Rate Test valve lineup could be satisfied. The field verification of the temporary lift only involved verifying the valve position.
Field verification is defined in QAP 300-14 as
..a first-hand check of valve positions..."
The problem was as a result of inadequate communication of system status when the temporary lift required for the Containment Leak Rate Test was requested and granted. This resulted in the opening of a leakage path from the drywell to the Reactor Building.
e s
s CORRECTIVE ACT1QHS TAKEN AND THE RESULTS ACHIEVED _;.
The immediate corrective action taken was to issue _ Temporary Procedure No. 5547.
Per the temporary procedure, valve 2-2499-20A was closed and a penalty for not venting the penetration was assessed. The Integrated Leak Rate Test began at approximately 0405 hours0.00469 days <br />0.113 hours <br />6.696429e-4 weeks <br />1.541025e-4 months <br />.
A six-hour short duration BN-TOP-1, Revision 1, was successfully completed on June 13, 1988.
CQRBECTIVE ACTIONS TO BE TAKEN TO AVOID FURTHER ACTIONS _t.
In an effort to prevent recurrence, the following corrections are to be taken:
- 1) Quad Cities Procedure, QAP 300-14 (Equipment Out-of-Service) will be revised to provide enhancements to the process of temporary lifting equipment to service. A checklist will be developed to identify why the temporary lift is needed, and will document that the equipment status has been formally evaluated to assure proper equipment configuration for that purpose;
- 2) This violation and the Commonwealth Edison response to the Notice of Violation will be included in both Licensed Operator and Non-Licensed operator required reading material;
- 3) This event will be discussed at Operating, Maintenance, and Technical Staff weekly tailgate meetings and will include a description of the new checklist described in item number 1 above;
- 4) A valve discrepancy checklist for the Integrated Leak Rate Test will be developed to ensure a potential leak path may not be opened due to a temporary lift. The procedure will require the test director or his designee to verify sy tem integrity prior to the temporary lifting of a valve.
DATE WHEN FULL C_QMELIANCE WILL BE ACHIEVED 1 Item number 1 will be completed by October 31, 1988.
Item number 2 will be completed by October 31, 1988.
Item number 3 will be completed by November 30, 1988.
Item number 4 will be completed prior to the next IPCLRT scheduled for Unit 1 in the summer of 1989.
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