ML20117G580

Responds to NRC Re Violations Noted in Insp Repts 50-254/96-06 & 50-265/96-06.Corrective Actions:Safety Evaluation Performed to Analyze Work Package for Unreviewed Safety Question

ML20117G580
Person / Time
Site:	Quad Cities
Issue date:	08/30/1996
From:	Kraft E COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ESK-96-166, NUDOCS 9609050249
Download: ML20117G580 (4)

Text

I Q>mmonwealth Edivan O>mpany l

QuJd Cities Gencrating Station l

22710 2(6th Avenue Nonh j

Cordova, 113 1212-97-10 l

Tel Mr>M1-22 61 l

ESK-96-166 August 30, 1996 U.S Nuclear Regulatory Commission Washington, D.C.

20555 Attention:

Document Control Desk

Subject:

Quad Cities Station Units 1 and 2; NRC Docket Numbers 50-254 and 50-265; NRC Inspection Report Numbers 50-254/96006 and 50-265/96006.

Reference:

W.

L. Axelson Letter to E.

S.

Kraft, Jr.,

Dated July 31, 1996, Transmitting Notice of Violation.

Enclosed is Commonwealth Edison's (Comed's) response to the Notice of Violation (NOV) transmitted with the referenced letter.

The NOV cited one Severity Level IV violation concerning the failure of the Instrument Maintenance Department to have written procedures reviewed by appropriate station management prior to implementation.

This letter contains the following commitments:

1.

The Work Analyst Department and all Maintenance Job i

Supervisors will receive training on the following items:

a.

The necessity and applicability of performing i

safety evaluations on work packages.

i i

b.

Proper verification of a qualified independent technical reviewer.

j (NTS # 254-100-96-00602.01, Due October 31, 1996) l 2.

The Work Analyst Department will revise QCAP 2200-04, l

" Preparation and Control of Work Packages", to add more detail to aid in the determination of the necessity of j

a safety evaluation for the work package. Also, the procedure will be changed to include a step to verify an individual is qualified to perform an independent technical review prior to submitting work packages for approvals.

(NTS # 254-100-96-00602.02, Due October 31, 1996) ph cuojs 9609050249 960830 PDR ADOCK 05000254 G

PDR

\\

A ( ~nn om Osmpan)

ESK-96-166 August 30, 1996 3.

The Maintenance Department will document all individuals capable of performing an independent technical review for work packages.

(NTS # 254-100-96-00602.03, Due October 31, 1996)

If there are any questions or comments concerning this letter, please refer them to Mr. Charles Peterson,

)

Regulatory Affairs Manager, at (309) 654-2241, extension 3602.

1 Respectfd)ly, 24 LL 61.)

. S. Kraft, Jr.

i Site Vice President

{

Attachment (A), Response to Notice of Violation cc:

A.

Beach, NRC Regional Administrator, RIII j

R.

Pulsifer, NRC Project Manager, NRR C. Miller, Senior Resident Inspector, Quad Cities D.

C. Tubbs, Mid-American Energy Company' R. Singer, Mid-American Energy Company

)

i

e ATTACHMENT A (Page 1 of 2)

ESK 96-166 STATEMENT OF VIOLATION (254/265-96-006-02):

During an NRC inspection conducted on April 17 through May 20, 1996, a violation of NRC requirements was identified.

In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violation is listed below:

Technical Specification 6.2.C requires written procedures, identified in Regulatory Guide 1.33, Rev.

2, Appendix A, be reviewed by station management prior to implementation, including determining, based on a written safety evaluation, if an unreviewed safety question is involved.

Regulatory Guide 1.33, Revision 2, Appendix A, Paragraph 8.b.2.1, includes React:or Protective System Tests and Calibration procedures.

Contrary to the above, on or about April 18, 1996, Instrument Maintenance technicians performed testing of the source range monitor trip function of the Unit 1 reactor protection system using a work procedure which was not reviewed by appropriate station management.

In addition, there was no written safety evaluation for the activity.

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

REASON FOR VIOLATION:

This violation occurred due to an inadequate review performed by i

the work package preparer and reviewer. The personnel who prepared, reviewed, and approved the work package failed to recognize the need to perform a safety evaluation.

Technical Specification 6.2.C.1 requires "Each procedure or procedure change shall be independently reviewed by a qualified individual knowledgeable in the area affected other than the individual who prepared the procedure or procedure change". The individual who performed the independent technical review for the work package was not qualified to perform the review by station manager signature. This violation occurred due to the misinterpretation by the individual who performed the independent technical review and because of the lack of a questioning attitude by the work package preparer. The individual, a first line supervisor, believed he was qualified to perform an independent technical review and was unaware of the procedural requirements to document ANSI 18.1 Section 4.4 qualification (Professional-Technical)with station manager approval. The work analyst did not verify the first line supervisor was approved to perform independent technical reviews.

The work package was subsequently approved by the Instrument Maintenance Department Head who is qualified in accordance with ANSI 18.1, Section 4.2 (Maintenance Manager).

ATTACHMENT A (Page 2 of 2)

ESK %-166 CORRECTIVE ACTIONS TAKEN:

1.

A safety evaluation (SE-96-100) was performed in accordance with 10 CFR 50.59 to analyze the work package for an unreviewed safety question. The evaluation concluded that an unreviewed safety question did not exist for the scope of the work package.

2.

The first line supervisor was verified to meet the independent technical review requirements of QCAP 1000-05 Attachment A, "Onsite/ Technical Review Participant Qualification".

ACTIONS TO PREVENT FURTHER RECURRENCE:

1.

The Work Analyst Department and all Maintenance Job Supervisors will receive training on the following items:

a.

The necessity and applicability of performing safety evaluations on work packages.

b.

Proper verification of a qualified independent technical reviewer.

(NTS 254-100-96-00602.01, October 31, 1996) 2.

The Work Analyst Department will revise QCAP 2200-04,

" Preparation and Control of Work Packages", to add more detail to aid in the determination of the necessity of a safety evaluation for the work package. Also, the procedure will be changed to include a step to verify an individual is qualified to perform an independent technical review prior to submitting work packages for approvals.

(NTS 254-100-96-00602.02, October 31, 1996) 3.

The Maintenance Department will document all individuals capable of performing an independent technical review for work package.

(NTS 254-100-96-00602.03, October 31, 1996)

DATE WHEN FULL COMPLIANCE WILL BE MET:

Full compliance will be met with the completion of all items by October 31, 1996.

.