ML20078C608

Forwards Final Level 2 Investigation Rept Addressing Adequacy of Quad-Cities Foreign Matl Exclusion (FME) Program,In Response to CAL-RIII-94-06 in Regard to FME Problems at Quad-Cites Station Unit 1

ML20078C608
Person / Time
Site:	Quad Cities
Issue date:	10/21/1994
From:	Kraft E COMMONWEALTH EDISON CO.
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20078C612	List: ML20078C608 ML20078C613
References
CAL-RIII-94-06, CAL-RIII-94-6, ESK-94-060, ESK-94-60, NUDOCS 9411010121
Download: ML20078C608 (2)

Text

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Comm:nwealth Edison Quad Cities Nuclear Power Station 22710 206 Avenue North Cordova, Illinois 61242 Telephone 309/654-2241 ESK-94-060 October 21,1994 Mr. J. B. Martin Regional III Administrator U. S. Nuclear Regulatory Commission Region III 801 Warrenville Road Lisle, IL 60532-4351

SUBJECT:

Quad Cities Nuclear Power Station Unit i Response to Confirmatory Action Letter (CAL) RIII-94-006 Resolution of Foreign Material Exclusion Events NRC Docket Number 50-254

REFERENCES:

(1) J. B. Martin to M. J. Wallace letter dated July 26, 1994;-

Confirmatory Action Letter - CAL No. RIII-94-006 (2) Meeting /Telecoriference between Comed (E. S. Kraft, Jr.,et al) and NRC Region 111 (P. Hiland, et al) on August 2,1994 (3) E. S. Kraft, Jr. to J. B. Martin letter dated August 5,1994 r

Dear Mr. Martin,

In the reference (1) letter, the Nuclear Regulatory Commission (NRC) issued a Confirmatory Action Letter (CAL) to Commonwealth Edison (Comed) in regards to two foreign material exclusion (FME) events at the Quad Cities Station. As part of that CAL, the NRC required Comed to submit a written report within 30 days of the completion of the investigation into the foreign material problems at Quad Cities Station Unit 1.

In response to these events at Quad Cities Station in July 1994, site management implemented a four-part integrated strategy to achieve the objectives described above. This strategy consisted of two Level 3 Root Cause investigations of the FME events; a Level 2 evaluation of the Quad Cities Station FME program; a systematic evaluation of Unit I and Unit 2 equipment and systems to ensure that all systems with a potential for contacting the Reactor Vessel are free of foreign material; and development of a phased program to ensure that appropriate FME controls are implemented for all current and future work evolutions.

'i 9411010121 941021 PDR ADOCK 05000254 P PDR / k

ESK-94-060 October 21,1994 Page 2 of 2 During the reference (2) meeting and teleconference between Comed and the NRC, Comed described the four-part integrated strategy and approach for: 1) determining the root causes of the events; 2) evaluating the integrity and operability of equipment and systems on Unit I and Unit 2; 3) evaluating the adequacy of the Quad Cities FME program; and 4) ensuring that appropriate FME controls are implemented for all current and future work evolutions. Comed provided a written summary of this information in reference (3). Comed also indicated that the results of the Level 2 Investigation, as well as the Phase 2 and 3 FME controls (including an implementation schedule) would be provided within 30 days of the completion of the investigation.

In accordance with the requirements of the reference (1) CAL, this letter transmits, as enclosure A, the final Level 2 Investigation Report, which evaluated the adequacy of the Quad Cities FME Program.

Enclosure B of this letter contains the long term corrective actions associated with the phased FME program (including implementation schedule). In addition, a description of the Phase 2 and 3 FME program controls is provided as enclosure C.

The Level 2 Investigation of the adequacy of the Quad Cities FME program identified weaknesses in defming, communicating, and reinforcing expectations for FME practices, as well as monitoring the performance of work to determine if expectations are understood. These weaknesses lead to the ineffective implementation of the FME program.

The long term corrective actions associated with the phased FME program includes a station policy that supports upper management expectations regarding FME, a new FME procedure, training lesson plans based on FME task analysis, increased material inventory of commonly used FME devices. FME program assessment by maintenance, establishment of an FME program manager, and continued efforts to present awareness of foreign material exclusion throughout the station, if there are any further questions, please contact Mr. Nick Chrissotimos at (309)654-2241 extension 3100.

Sincerely, E. S. Kraft, /r' Site Vice President Quad Cities Station Enclosure A: Final Level 2 Investigation - Adequacy of the Quad Cities FME Program Enclosure B: Long Term Corrective Actions Associated With The Phased FME Program Enclosure C: A Description Of The Phase 2 and Phase 3 FME Program Controls cc: ument Control Desk P. Ililand, Section Chief - Dresden/ Quad Cities C. Miller, Senior Resident inspector - Quad Cities Station R. Pulsifer, Project Manager - NRR Office of Nuclear Facility Safety -IDNS