ML20205Q189
| ML20205Q189 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 02/07/1986 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1207K, NUDOCS 8605280204 | |
| Download: ML20205Q189 (5) | |
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) One FirIt NihonIl Ptua. Chictgo. Ilknois i O 7 Addr:ss R: ply to: Post Offica Box 767
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/ Chicago, Illinois 60690 February 7, 1986 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Comnission Region III 799 Roosevelt. Road Glen Ellyn, IL 60137
Subject:
Quad Cities Station Units 1 and 2 Response to Inspection Report Nos.
50-254/85-027 and 50-265/85-030 NRC Docket Nos. 50-254 and 50-265 Reference (a):
Letter from N. J. Chrissotimos to Cordell Reed dated January 2, 1986.
Dear Mr. Keppler:
This letter is in response to the inspection conducted by Messes.
A. L. Madison and A. D. Morrongiello and Ms. N. A. Nicholson of your staff on October 1 through December 7, 1985, of certain activities at Quad Cities Station. The referenced letter indicated that certain activities appeared to be in noncompliance with NRC requirements. The Commonwealth Edison response to the Notice of Violation is provided in the enclosure. This response is provided consistent with a one week extension granted during a telecon with D. Boyd of your staff on January 28, 1986.
Although we acknowledge and have taken action with respect to the first noncompliance regarding smoke detectors on the refuel floor, we feel the second item of noncompliance regarding Ruskin fire dampers is inappro-priate. As described in the enclosed response, we maintain that the action we took in response to the Ruskin Part 21 notification was sufficient and consistent with our fire protection program strategy.
If you have any further questions regarding this matter, please direct them to this office.
Very truly yours,
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ym D. L. Farrar Director of Nuclear Licensing im Attachment cc: NRC Resident Inspector - Quad Cities 1207K 8605280204 860207 FEB 10 B86 PDR ADOCK 05000254 G
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COMMONWEALTH EDISON COMPANY RESPONSE TO NOTICE OF VIOLATION As a result of the inspection conducted from October 1 through December 7, 1985, at Quad-Cities Station, the following violations were identified.
ITEM OF VIOLATION 1.
_ Appendix A Section 3.F. to Operating license No. DPR-29 and No. DPR-30 required that modifications identified in Paragraphs 3.1.1 through 3.1.13 of NRC's Fire Protection Safety Evaluation (SE), dated July 27, 1979, be completed according to the schedule in Table 3.1 of the SE and supplements thereto.
Specifically, Item No. 5 in Paragraph 3.1.1 required the installation of refuel floor fire detection monitors by December 30, 1979.
Contrary to the abovo, said fire detection monitors were never installed.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED The immediate corrective action was to implement a fire watch surveil-lance for the refueling floor. At the beginning and middle of each shift, an inspection is conducted of the refueling floor to verify there are no fires or obvious fire hazards. Record of inspections are documented per procedure QOS 4100-15 (Interim Fire Watch Surveillance).
Quad Cities Station has requested relief from the commitment to provide early warning fire detection monitors on the refueling floor *. This relief request is based on an evaluation which concludes that fire detection on the refueling floor will not increase fire protection I
safety since there is no safe shutdown equipment or cabling on the refueling floor, and the fire loading in the area is minimal.
The station will continue-the twice per shift surveillance of the refueling floor until the exemption request is accepted or the issue is otherwise resolved.
-* Refer to letter from D. L. Farrar to H. R. Denton dated December 2, 1985.
. CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE The commitment tracking system has been significantly improved since the time period when this violation occurred. New methods are being used to follow commitments including the hiring of a contractor to track fire protection commitments.
In addition, the communication channels between the Nuclear Licensing Administrator and the NRC have been improved.
It is felt that these actions will prevent further noncompliance.
Dresden Station has received an identical non-compliance in this area which was addressed during an enforcement conference on November 19, 1985. The discussion of the occurrence and corrective actions provided during the enforcement conference also apply to Quad Cities. As documented in the December 26, 1985 letter from J. G. Keppler to Cordell Reed transmitting the Dresden Notice of Violation, the corrective actions taken were found to be satisfactory.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The stated interim measures are currently in effect and will continue until the Commission accepts or otherwise resolves the exemption request.
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ITEM OF VIOLATION 2.
Criterion XVI of Appendix B to 10 CFR Part 50 states:
" Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. The identification of the signficant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management."
Contrary to the above, the licensee failed to properly and accurately evaluate the concerns raised by the Ruskin Manufacturing Company's 10 CFR Part 21 report submitted to the licensee on November 6, 1984. The 10 CFR Part 21 report indicated that test methods originally employed by Ruskin may not have accurately depicted actual field conditions for dampers installed inside ducting and may also fail to open under normal flow conditions. The inspectors identified one damper (No. CEC.
1/2-9472-01) which was required to close under flow conditions as dicussed in the Ruskin report which had not been identified by the Licensee and therefore no corrective actions had been taken.
DENIAL OF NONCOMPLIANCE It is Commonwealth Edison's belief that the concerns raised by Ruskin Manufacturing's 10 CFR Part 21 report were properly and accurately evaluated. Part 21 reviews are performed on safety-related equipment where potential defects are analyzed to determine whether substantial safety hazards exist. Only dampers installed in safety-related HVAC systems would fall within this review. Additionally, the onl/ safety-related function of such dampers is to remain open in order that the HVAC system can continue to perform its function. Therefore, from a 10 CFR Part 21 perspective, the Ruskin Manufacturing's report did not apply to Quad Cities since no concerns were identified with respect to this safety-related function.
Commonwealth Edison did address & evaluate the concern raised by Ruskin Manufacturing from a fire protection perspective when in January 1985 the Station Nuclear Engineering Department requested the Stations to review and modify their pre-fire plans for the potential need to shutdown HVAC systems to ensure fire damper closure. These pre-fire plans (fire fighting strategies) have been developed for safety-related plant areas and identify basic hazards, fire fighting tactics and supporting data to aid the fire brigade in a fire situation. Quad Cities's prefire plans now contain a caution statement regarding shutdown of the HVAC system. As a result, fire dampers would no longer (by procedure) need to close under flow conditions.
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- Quad Cities HVAC system Fire Damper 1/2 9472-01 is not interlocked with the area smoke detectors and the control room air supply system. The presence of two electro-thermal links as means of restraint for the Fire damper curtains may have led the NRC inspector to assume that this damper's closure was triggered by the presence of smoke in the control room or in the duct. However, these electro-thermal links are not, by design, electrically connected to any triggering device. They are used only as fusible links.
They would melt and allow damper 1/2 9472-01 to close if the temperature were to reach approximately 165 degrees F. inside the HVAC supply duct to the control room. To avoid any future confusion, steps are being taken at tiie Station to replace damper 1/2 9472-01 electro-thermal links with fusible links of similar rating.
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