ML20244D874

Responds to NRC Re Violations Noted in Insp Repts 50-254/88-11 & 50-265/88-12.Corrective Actions:Lubricant on Auxiliary Contact Plunger Guides Accomplished During Next Two Refuel Cycles on Each Unit

ML20244D874
Person / Time
Site:	Quad Cities
Issue date:	05/26/1989
From:	Stols R COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20244D873	List: IR 05000254/1988011 ML20244D874
References
EA-88-161, NUDOCS 8906200029
Download: ML20244D874 (5)

Text

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.. [ 4 y:): Commonwealth Reply to: Post Office Box 761 Edison 72 West Adams Street, Chiergo, Illinois

.(L/ L Chicago, Illinois 60690 - 0767

" ' Address

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j May.26, 1989 l

l M' r . A '. Bert Davis Regional Administrator U.S. Nuclear Regulatory Commission Region III

.799 Roosevelt Road Glen Ellyn, IL 60137

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Subject:

Quad Cities Station Units l'and 2 j 1

Response.to Notice of Violation (NOV)

Associated with Inspection Report l Nos. 50-254/88011 and 50-265/88012 NRC Docket Nos. 50-254 and 50-265 l

References-- October 17, 1988 letter from L.O. De1 George i to J.Lieberman transmitting Response to j Notice of Violation Associated with Inspection lj Report Nos. 50-254/88011 and 50-265/88012 .j Enforcement Action EA-88-161 l

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Dear Mr,

Davist i

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In the referenced letter, Commonwealth Edison transmitted the. response '

to the Notice of Violations identified in Inspection Report 50-254/88011 and' j

E0-265/86012. Several corrective ections to the vio10tions identified were committed to begin and/or to be completed during upcoming' refuel outages. l Commonwealth Edison has recently revised the Refuel Outage schedules and as a

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l result, the corrective action commitment dates require revision. l In addition, as indicated in the referenced response, Commonwealth Edison has undertaken a review of drawing accuracy. The intent of this review in to identify the type of design information and level of detail that should be shown on various types of drawings, and to identify information that may require reverification. Due in part to the the greater ,than expecterl 4

magnitude and complexity of the tasks, the expected completion riate has been '

revised. .,[.

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A.B. Davis May 26, 1989 Attachment A provides further detail to the revised corrective action implementation dates.

Please direct any questions you may have regarding this matter to this office.

Very truly yours, R. Stols Nuclear Licensing Administrator Im Attachment A: Pevision to Corrective Action Implementation Dates cci Quad Cities Resident Inspector T.M. Ross - NRR 1

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ATTACIDH:NT A

,.g l- REVISION TO CORRECTIVE ACTION IMPLEMENTATION DATES II.A Level IV Violation Concernino Desion Basis Transintion to Drawings Commonwealth Edisca has undertaken a review of the issue of drawing accuracy. The intent of this review is to identify the type of design.

Information and level of detail that should be shown on various types of drawings and to identify the information that may require reverification.

A similar review had previously been undertaken, specifically for LaSalle Station, as a result of concerns identified by Commonwealth Edison's SSFI program. An outilne of the methodology of the LaSalle review was provided to the NRC at the March 23, 1989 meeting regarding Commonwealth Edison's self-assessment programs. This methodology includes the following tasks:

1) Identify design information and parameters for which the drawing-is the primary source of information and governing document.

2) Identify design information and parameters for which the drawing is nat the primary source, and consider removing such information from the drawings (e.g>, setpoints).

3). Identify those parameters in Item (1) which are perceived to have a low level of correctness.

4) Perform a sample review of various types of drawings to verify the correctness of the paraneters identified in Item (3).

5) Based on the results of the above items, det. ermine the priority, scope, and schedule for further drawing correction efforts.

The first three tasks have been essentially completed. What remains to be done is to complete the sample review for LaSalle and to generalize and validate the results for the other Commonwenith Edison stations. (Because of substantial differences in drawing format and presentation of design information, the results may not be immediately transferrable between stations.) Following'these activities, a more specific list of actions and l schedules can be developed for each station.

Due in part to the greater than expected magnitude and complexity of the tasks as well as the significant reorganization in the Company's engineering and technical support areas, the expected completion date for this effort has been revised. Development of action plans and schedules is now expected to be completed by September 3 0, "~19 8 9.

As stated in our previous response, Commonwealth Edison believes that a phased approach to this issue is appropriate for several reasons. First, the plants have been subjected to extensive surveillance programs over the years that have been effective in identifying drawing discrepancies of functional importance. Second, a feature of the modification program is that as-built verification is performed as a pre-requisite to a new modification design for those portions of existina drawings affected by the modification.

These programs will continue to provide increased confidence in drawing accuracy until final plans for verification effects have been completed.

II.B.1 Level TV Violation Associated with Preventive Maintenance Activities Procedures to Limitorque Actuators Commonwealth Edison has initiated a two phase program to inspect and refurbish motor-cperated valves, including Limitorques. Phase II of the program involves integration of the results of recently upgraded maintenance procedures, diagnostic testing, periodic inspections and training into a comprehensive maintenance program. Phase II of the MOV maintenance program will identify preventive maintenance activities and {

frequencies based on an evaluation for each velve. N

,7" Implementation of the Phase II program is anticipated t begin with the nextUnit2refueloutagewhichiscurrentlyscheduled(forFebrubry 1990, qj f.'/y g f,.(jf 7

II.B.2 Level IV Violation Associated _ylth 4KV Breakers Preventive maintenance for the remaining 43 breakers which have not received maintenance will be completed on each unit by the end of their ,-

next refueling outage, currently scheduled for corpletion in November, 1989 for Unit 1 and May, 1990 for Unit 2.

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II.C Level IV Violation for Failure to Promptly Identify or Correct Canditions Adverse to Ouality In the response to this Violation, Commonwealth Edison committed to confirm that all safety-related butterfly valves are properly orientated. The completion of the butterfly valves orientation for the. Valves 1-1301-56, Reactor Core Injection Coolant Suppression Chamber Alternate Suction valve and 1-2301-56, High Pressure Coolant Injection Suppression Chamber Alternate Suction Valve will be -

completed by the end of the. upcoming Unit I refueling outage currently scheduled to begin September, 1989. ,

The lubricant on the auxiliary contact plunger guides in environmentally qualified and safety-related motor control' centers wl31 be accomplished during the next two refuel cycles on each unit. &,-

The maintenance will be completed during the refuel outages scheduled to begin in October,1990 and September,1991 for Units 1 and 2, respectively.

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