ML20209E925
| ML20209E925 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 07/02/1985 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 0322K, 322K, NUDOCS 8507120350 | |
| Download: ML20209E925 (3) | |
Text
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- 7M Commonwealth Edison one Fir:t Nabonal Plaz?, Chicago. Illinois a
Address Reply to: Post Office Box 767 Chicago, Illinois 60690 July 2, 1985 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Quad Cities Station Units 1 and 2 Amended Response to I.E. Inspection Report Nos. 50-254/85-009 and 50-265/85-010 NRC Docket Nos. 50-254 and 50-265 References (a):
W. S. Little letter to Cordell Reed dated April 1, 1985.
(b):
D. L. Farrar letter to J. G. Keppler dated May 1, 1985.
Dear Mr. Keppler:
Upon further consideration Commonwealth Edison has revised its response to the inspection conducted by Mr. P. R. Wohld on March 18 thru March 22, 1985 on Inservice testing activities at Quad Cities station.
The principal change is in regard to the corrective action for valve testing required during cold shutdown. The revised corrective action will include an evaluation of valve operability by the Operating Engineer (instead of the Station Control Room Er.gineer), and will be completed prior to start-up if a valve is evaluated to be inoperative, and the Technical Specifications' Limiting Conditions for Operation cannot be met.
The only other change is to update the response to reflect the designation of an IST coordinator at the station. The revised response is attached, with the changes underlined.
If you have any further questions regarding this matter, please direct them to this office.
Very truly yours, hhk b0 0
D. L. Farrar Director of Nuclear Licensing 1m Attachment cc: NRC Resident Inspector - Quad Cities JUL 3 G85 8/
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ATTACHENT COMMONWEALTH EDISON COWANY RESPONSE TO NOTICE OF VIOLATION As a result of the inspection conducted from March 18 through March 22, 1985, at Quad-Cities Station, the following violation was identified:
Item of Noncompliance 1.
10 CFR 50, Appendix B, Criterion V, as implemented by Commonwealth Edison Corporate Quality Assurance Manual, Chapter 5, states that measures to assure that activities affecting quality shall be prescribed by documented instructions.
Contrary to the above:
a.
The licensee did not have administrative instructions assigning responsibility for implementation of the pump and valve inservice test program under Section XI of the ASE code.
b.
Instructions prescribing test program technical details were not adequate in specifying requirements to meet the ASME Code.
c.
The use of pump and valve inservice test data (such as for trending analysis and evaluation) was not prescribed by instruction to assure the prompt identification and correction of conditions adverse to quality.
Corrective Actions Taken and Results Achieved The QAP 350 series of inservice testing program administrative procedures which provide program technical instruction are being revised.
Changes to these administrative procedures include the following:
1.
Assign the overall responsibility for the Inservice Testing Program to the IST Coordinator, which includes maintaining a program of trending appropriate test data.
2.
Assign the responsibilities of initial operability determination and initiating corrective actions as appropriate to the Station Control Room Engineer.
3.
Specify that the first valve stroke will be used as the survell-lance test stroke time for the record, for initial operability determination, and for trending.
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Specify that the corrective action for valve testing required at cold shutdown will include an evaluation by the Operating Engineer.
If the evaluation indicates a valve to be inoperative, and the Technical Specifications' Limiting Conditions for Operation are not met, the condition will be corrected before startup. A retest showing acceptable operation shall be run following any required corrective action before the valve is returned to service.
5.
Revise the procedure valve lists, QAP 350-S3 and 54, to include all applicable valves that are in the IST program.
The Station Modification Checklist, QTP 500-S8, is to be revised to identify the requirement for IST review for adding or modifying testing as a result of plant design changes and modifications.
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTKR NONCOM'LIANCE A station IST Coordinator was designated. He will ensure the long term viability of the Inservice Testing Program.
Date When Full Compliance Will Be Achieved Partial compliance was achieved, when a station IST Coordinator was designated.
Full compliance will be achieved by August 1, 1985, when all necessary procedural changes are implemented.
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