ML20212H028

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-254/97-13 & 50-265/97-13

ML20212H028
Person / Time
Site:	Quad Cities
Issue date:	11/04/1997
From:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Pearce L COMMONWEALTH EDISON CO.
References
50-254-97-13, 50-265-97-13, NUDOCS 9711100005
Download: ML20212H028 (2)

See also: IR 05000254/1997013

Text

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November 4,1997

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h Mr. L. W. Pearce

Site Vice President

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Quad Cities Station

Commonwealth Edison Company

22710 206th Avenue North

Cordova, IL- 61242

SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-254/97013(DRS);

50-265/97013(DRS)

Dear Mr. Pearce:

This will acknowledge receipt of your letter dated October 8,1997, in response to our

letter dated September 12,1907, transmitting a Notice of Violation associated with Residual

Heat Removal Service Water pumps. We have reviewed your corrective actions and have no

further questions at this time. These corrective actions will be examined during future

inspections.

Sincerely,

Original Signed by John A. Grobe

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John A. Grobe,' Director

Division of Reactor Safety

Docket No. 50-254 4

Docket No. 50-265

Enclosure: L. W. Pearce letter to NRC

dated Oc ober 8,1997

See Attached Distribution:

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DOCUMENT NAME: G:DRS\QUA97013.TY

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To receive a co py of this document. Indicate in the box "C's Copy w/o attach /enci'E' = Copy w/ attach /enci "N" = No copy

OFFICE Rill:DRS lV Rlli:DRS N Rill:DRJ, a . l l

NAME Burrows /l@ b Lougheeo%) QA Grob6-/R'1

DATE 11bl/97 11/o1/97 11/4/7/

OFFICIAL RECORD COPY

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L. Pearce 2 November 4. 1997

cc w/o encl: R. J. Manning, Executive Vice President,

Generation

M. Wallace, Senior Vice President, '

Corporate Services

E. Kraft, Vice President, BWR Operations

Liaison Officer, NOC-BOD

D. A. Sager, V!ce President,

Generation Support

D. Farrar, Nuclear Regulatory

Services Manager

1. Johnson, Licensing Operations Manager

Document Control Desk - Licensing

Quad Cities Station Manager

C. C. Peterson, Regulatory Affairs Manager

cc w/enet: Richard Hubbard

Nathan Schloss, Economist,

Office of the Attomey General

State Liaison Officer

Chairman, Illinois Commerce Commission

W. D. Leech, Manager of Nuclear,

MidAmerican Energy Company

- Distribution:

Docket File w/ encl SRI, Quad Cities w/enci TSS w/enct

PUBLIC IE-01 w/enci LPM, NRR w/enci CAA1 w/enci

OCFO/LFARB w/enct A. B. Beach, Rlll w/enci DOCDESK w/enci

DRP w/enci J. L. Caldwell, Rill w/enct

DRS w/enct Rlli Enf. Coordinator w/enci

Rlll PRR w/enci R. A. Capra, NRR w/enci

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SVP-97- 222

October 8,1997

U. S. Nuclear Regulatory Commission

Washington, D. C. 20555

Attention: Document Control Desk

Subject: Quad Cities Station Units I and 2;

NRC Docket Numbers 50-254 and 50-265;

NRC Inspection Report Numbers 50-254/97013

and 50-265/97013.

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Reference: (a) J. A. Grobe letter to E. S. Kraft, Jr., dated September 12,1997.

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Enclosed is Commonwealth Edison's (Comed's) response to the Notice of Violation

(NOV) transmitted with the referenced letter. The report cited a Severity Level IV

violation concerning the requirements and acceptance limits contained in design

documents for the Residual Heat Removal Senice Water (RHRSW) pumps that were

not incorporated into the written test procedures.

This letter contains the following new commitments:

• The affected RHR Senice Water Design Basis Parameters will be evaluated and

clarified by November 14,1997.

This NOV will be addressed in Lessons Learned training by December 31,1997 for

licensed operators and engineering personnel who perform 50.59 screenings.

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. SVP 97 222- 2 October 8,1997

If you have any questions concerning this letter, please contact Mr. Charles Peterson,

Regulatory Affairs Manager, at (309) 654-2241, extension 3609.

Respectfully,

f.

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(ALLL.

' Pearce

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Site Vice President

Quad Cities Station

Attachment A, Response to Notice of Violation

cc: ' A. B. Beach, Regional Administrator, Region III

R. M. Pulsifer, Project Manager, NRR

., C. G. Miller, Senior Resident Inspector, Quhd Cities

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W. D. Leech, MidAmerican Energy Company

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D. C. Tubbs, MidAmerican Energy Company ~

F. A. Spangenberg, Regulatoiy Affairs Manager, Dresden

INPO Records Center

Office of Nuclear Facility Safety, IDNS

c DCD License (both electronic and hard copies)

- M. E. Wagner, Licensing, Comed

SVP Letter File

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ATTACilMENT A ,

!* RESPONSE TO NOTICE OF VIOLATION

SVP 97-222

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NOTICE OF VIOLATION (50-254;265/97013-01)

Appendix B of 10 CFR Part 50, Criterion XI, " Test Control," requires, in part, "A test program

shall be established . . . and performed in accordance with written test procedures which incorporate

the requirements and acceptance limits contained in applicable design documents."

Technical Specification 4.5.B.I.b, the residual heat removal senice water pump surveillance

requirement to produce 3500 gpm against a pressure of 198 psig, was relocated to the licensee's

inser ice testing program as part of the licensee's technical specification upgrade program.

Contrary to the above, as of August 6,1997, the requirements and acceptance limits contained in

design documents for the residual heat removal service water pumps were not incorporated into the

written test procedures. Specifically, procedure QCOS 1000-04, Quarterly RHR Seaice Water

Pump Operability Test, Revision 12, dated April 7,1997, did not include the requirement to measure

the pump flow of 3500 gpm against a pressure of 198 psig with appropriate ecceptance limits.

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This is a Severity Level IV violation (Supplement 1).

Root Cause Analysis:

Comed accepts this violation. The root causes for this event have been attributed to inadequate

change management during the Technical Specification Upgrade (TSUP) implementation regarding

relocation of reonirements to the In Service Testing (IST) program and a deficient 50.59 screening

for a procedure resision.

During TSUP implementation the IST Coordinator was not made cognizant of the decision to

relocate the Residual Heat Removal Service Water (RHRSW) pump acceptance criteria into the IST

program as stated in the Safety Evaluation Report (SER).

In a 50.59 screening of a TSUP procedure change, Operations focused on and misinterpreted the

SER description of the relocation of the acceptance criteria. As a result, the flow and pressure

requirements were removed from the IST Quarterly surveillance, QCOS 1000-04, as these were not

-in TSUP. Operations and the IST Coordinator erroneously assumed that RHRSW design basis limit

numbers were being eliminated in lieu of the existing IST methodology.

Corrective Actions taken:

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All TSUP/IST relocation procedure changes were reviewed and no other problems were found.

QCOS 1000-04 was revised to reinstate the verification of the RHR Service Water pump flow

parameters.

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ATTACHMENT A

RESPONSE TO NOTICE OF VIOLATION

SVP 97-222

(Page 2 of 2)

Corrective Actions to prevent further occurrence:

The atTected RHR Senice Water Design Basis Parameters will be evaluated and clarified by

November 14,1997. (NTS 25420197CAQD0286901, Design Engineering)

This NOV will be addressed in Lessons Learned training by December 31,1997 for licensed

operators and engineering personnel who perform 50.59 screenings.

(NTS 254 P09701301.01, Training)

Date When Full Compliance will be met:

Full compliance was met with the revision to QCOS 1000-04.

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