ML20198E892
| ML20198E892 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 08/04/1997 |
| From: | Kraft E COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-254-97-06, 50-254-97-6, 50-265-97-06, 50-265-97-6, ESK-97-160, NUDOCS 9708110070 | |
| Download: ML20198E892 (9) | |
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August 4,1997 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attemion:
Document Control Desk
Subject:
Quad Cities Station Units I and 2; NRC DockcLNumbris 50 254 and 50 265:
NRC Inspection Report Numbers 50 254/97006 and 50 265/97006.
Reference:
G. E. Grant letter to E. S. Krall, Jr. dated July 7,1997 Enclosed is Commonwealth Edison's (Comed's) responses to three Notices of Violation (NOV) transmitted with the referenced letter. The first violation concerned a failure to implement a test procedure. The second violation concerned the failure by the station to update the master retention schedule to include new quality records. The third violation concerned a failure to take prompt corrective action to address periodic high differential pressure readings on the 2B Core Spray Room Cooler.
This letter contains the following new commitments:
- 1. Each department will review their retention schedule to include identification of
,6 quality records by November 15,1997. (NTS 254100 97 00603.01)
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- 2. QCAP 1200-01, " Station Records" will be revised to require a semi-annual review of the retention schedule by November 15,1997. (NTS 254100-97 00603.02) 1, 3' Od min 5iHE'HJlll 9700110070 970004 PDR ADOCK 05000254 G
PDR s i ns om c omp on
(J. S. NRC ESK 97160 2
August 4,1997 If you have any questions concerning this letter, please contact Mr. Charles Peterson, Regulatory Affairs Manager, at (309) 654 2241, extension 3609.
Respectfbily, Q NA W N
D. S. Krall, Jr.
Site Vice President--
Quad Cities Station Attachment A, " Response to Notice of Violation" cc:
A. H. Heach, Regional Administrator, Region 111 R. M, Pulsifer, Project Manager, NRR l
C. G. Miller, Senior Resident inspector, Quad Cities W. D. Leech, MidAmerican Energy Company D. C. Tubbs, MidAmerican Energy Company F. A. Spangenberg, Regulatory Affairs Manager, Dresden INPO Records Center Of1 ice of Nuclear Facility Safety, IDNS DCD License (both electronic and hard copies)
M. E. Wagner, l.icensing, Comed
ATTACilMENT A
" Response to Notice of Violation" ESK-97-160 Page 1 of 7 STATEMENT OF VIOLATION (NRC IR 50 254/97006 01):
NOTICE OF VIOLATION Title 10 CFR Part 50, Appendix B, Criterion VI, Document Control, requires,in part,
" Measures shall be established to control the issuance of procedures, including changes These measures shall assure that procedures including changes are distributed to and used at the location where the prescribed activity is performed.
Quad Cities Administrative Procedure (QCAP) 1100 12, Procedure Use and Adherence, Revision 12, Step D.4.c.) requires using the most current revision of the procedure.
Contrary to the above, a.
On April 9,1997, Quad Cities Operations Surveillance Procedure (QOP) 690016, Return of 250 VDC BUS 18 and BUS 2A to MCC 2, Revision 9, was not i
distributed to the control room where operators were performing the surveillance.
b.
On April 9,1997, QOP 690016, Return of 250 VDC BUS 18 and BUS 2A to MCC 2, Revision 8, was used by a control room operator when the most recent 4
revision was Revision 9.
This is a Severity Level IV violation (Supplement 1).
REASON FOR VIOLATION:
Comed acknewledges this violation. The reason for the event was lack of attention to detail by the clerk, inexperience in the processes and a large volume of procedures being distributed. The error by the clerk of not updating the Real Time procedure books caused the operator to have the incorrect procedure revision.
ACTIONS TAKEN:
- i. Correct revision was placed in the Control Room procedure book on 4/9/97.
2, The Real Time Procedure sets were verified correct.
- 3. The procedure group was tailgated on the process of procedure distribution.
4 To address the large vo:ume of procedures being distributed, the distribution responsibilities were spread out among the procedure group.
4 A'ITACilMENT A
" Response to Notice of Violation" ESK-97160 Page 2 of 7 ACTIONS TO PREVENT FURTilER OCCURRENCE:
A desk top instruction was developed to provide more instructions on the distribution process.
- 1) ATE WilEN FULL COMPLIANCE WILL HE MET:
Full compliance was met on 4/09/97, wiien the correct revision was placed in the control room procedure books.
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NITACilMENT A j
" Response to Notice of Violation" l
ESK-97-160 Page 3 of 7 l
Notlee of Violations (254/265 97 006 03)
Title 10 CFR Pan 50, Appendix B, Criterion XVil," Quality Assurance Records,"
requires, in part, that sumcient records shall be maintained to furnish evidence of activities afTecting quality. Records shall be identifiable and retrievable. Consistent with applicable regulatcry requirements, the licensee shall establish requirements concerning record retention, such as duration, location, and assigned responsibility.
Commonwealth Edison Company Quality Assurance Program Topical Report CE l A, Revision 6Sb, Section 17. " Quality Assurance Records," states, in part, that the quality records program includes those record types, controls, and provisions for storage and preservation contained in Nuclear Quality Assurance (NQA)-1, Supplement 1751.
Records are administered through a system, which includes an index of record type, retention period, and storage location. Record retention periods are established to meet regulatory requirements.
American National Standards Institute /American Society of Mechanical Engineers (ANSI /ASME) NQA 1," Quality Assurance Program Requirements for Nuclear Facilities," Supplement 17S 1 states, in part, that a records receipt control system shall include a method for identifying records received.
Quad Cities Administrative Procedure 1200 01, Revision 1," Station Records,"
Step D.2; states that the responsible department records custodian shall update the master retention schedule when a new record is created. Step D.2.a stated that the record custodian determined if the new record was a quality or non-quality record.
Contrary to the above, on March 31,1997, the inspectors identified that the master retention schedule had not been updated to include new quality records. The licensee failed to identify required quality assurance records and failed to establish requirements for record retention, including duration and assigned responsibility for quality records. The following procedures contain required quality records (operability determinations and surveillance resuhs) not listed on the retention schedule:
Quad Cities Administrative Procedure (QCAP) 0230 07," Operability Determination" Quad Cities Chemistry Procedure (QCCP) 1200 2, " Post LOCA (loss of coolant accident] Ilydrogen and Oxygen Monitoring System" l
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NITACllMENT A
" Response to Notice of Violation" ESK-97-160 Page 4 of 7 Quad Cities Instrument Surveillance Procedure (QCIS) 24001,"Diywell Radiation e
Monitor Calibration and Functional Test" Quad Cities Operating Surveillance Procedure (QCOS) 1600-4, " Weekly Primary Containment Oxygen Concentration" This is a Severity Level IV violation (Supplement 1). (50 254;265/97006 03)
REASON FOR VIOLATION:
Comtid acknowledges the violation. The violation is due to the lack ofin-house expertise, adequate training on record retention requirements and assigned departmental records custodians.
ACTIONS TAKEN:
Lack of in-ll'ouse Emertise:
Experienced individuals were contracted to provide training.
Review and disposition of Central File backlog to properly identify those records requiring lifetime retention.
Reviewed Master Record Retention Schedule for compliance to applicable codes and standards, Inadeaunte Training on Records Retention Reauirements:
Created Records Custodian Training Reference Manual contalaing applicable codes and e
standards pertaining to record retention Created Record Retention Schedule Users Guide to provide guidance in updating depanmental schedules to new format.
Records Custodian training was provided in December of 1996.
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ATI'ACilMENT A
" Response to Notice of Violation" ESK-97-160 Page 5 of 7 Clear Ownershin of Records Retention Responsibilities:
Record Custodians were selected for each station department.
Updated station procedure QCAP 1200 01," Station Records" to reflect Records Custodian responsibilities. In addition, QCAP 1100 04," Procedure Revision, Review and Approval" was updated to identify the custodian's responsibilities in the procedure review process for record retention requirements.
ACTIONS TO PREVENT FURTilER OCCURRENCE:
- 1. Each department will review their retention schedule to include identification of quality records by November 15,19971 (NTS 254100 97 00603.01)
- 2. QCAP 1200-01," Station Records" will be revised to require a semi annual review of the retention schedule by November 15,1997, (NTS 254100 97-00603.02)
DATE WilEN FULL COMPLIANCE WILL HE MET:
Full compliance will be met with the completion orindividual departmental review and update of their retention schedule. The actions are scheduled to be completed by November 13,1997.
ATTACilMENT A
" Response to Notice of Violation" ESK-97-160 Page60f7 STATEMENT OF VIOLATION (NRC lR 50 254/97006 07);
NOTICE OF VIOLATION Title 10 CFR Part 50, Appendix B, Criterion XVI," Corrective Action," required, in part, that measures shall be established to assure that conditions adverse to quality, such as malfunctions, are promptly identitled and corrected.
Contrary to the above, from June 1996 until March 1997, the licensee failed to take prompt corrective action to address periodic high differential pressure readings that clearly indicated that the 2B Core Spray Room Cooler was significantly clogged. During this time, Quad Cities continued to operate with one train of Core Spray significantly degraded and its effect on safe operation went unevaluated.
This is a Severity Level IV violation (Supplement IV).
REASON FOR VIOLATION:
Comed acknowledges this violation. The reason for the violation was untimely of the corrective actions taken in response to a previously identified failure of engineering to trend or analyze room cooler water dilTerential pressures for a period of time (Deviation 50-254/265 96015 01). As a result, site engineering did not formall; ;lentify, document, and analyze the condition of the 2B Core Spray room cooler through the use of QCAP 2300-06, " Problem Identification."
ACTIONS TAKEN:
The 2B Core Spray Room Cooler was cleaned during refueling outage Q2R14. In addition, the remaining Unit 2 Emergency Core Cooling System (ECCS) Room Coolers (2A Core Spray,2A and 2B Residual lleat Removal, and liigh Pressure Coolant injection) were also inspected and cleaned during refueling outage Q2R14.
Administrative procedure QCTP 1110-12, "ECCS Room Cooler Trending Program" was developed for the trending and analysis of cooling water differential pressure data from the ECCS room coolers.
Electronic Work Control System Predefme (tirne tracking) was created to ensure trendag and analysis of cooling water differential pressure data from the ECCS room coolers is perft rmed per QCTP 1110-12,"ECCS Room Cooler Trending Program."
QCOS 5750-09, "ECCS Room and Diesel Generator Cooling Water Pump Cubicle Cooler Monthly Surveillance" was revised to include cooling water difTerential pressure and flow acceptance and PIF criteria for the initiation of timely review of possible degraded conditions.
NITACIIMENT A l
" Response to Notice of Violation" ESK-97-160 Page 7 of 7 ACTIONS TO PREVENT FURTilER OCCURRENCE:
4 There are no further actions required for this event.
DATE WilEN FULL COMPLIANCE WILL HE MET:
i Full compliance was achieved on July 31,1997 when site procedures QCTP 1110-12 and QCOP 5750-09 were implemented.
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