ML17195A832
| ML17195A832 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 05/28/1985 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML17195A831 | List: |
| References | |
| 0165K, 165K, NUDOCS 8506210255 | |
| Download: ML17195A832 (5) | |
Text
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'***.';'ti Commonwealth Edison One First National Plaza. Chicago, Illinois Address Reply to: Post Office Box 767 Chicago. Illinois 60690 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 May 28, 1985
Subject:
Dresden Station Unit 2 Response to Inspection Report No. 50-237/85-14 NRC Docket-No; 50-237*
0 Reference (a):
R. L. Spessard letter to Cordell Reed dated May 28, 1985.
Dear Mr. K~ppler:
This *letter: is in response to the __ inspection, condu¢ted by Mr. A
- S. Gautam on March 20-23.and April* _4, 1985, :or* activities at Dresden Station.
- Reference {a) indicated that __ cert.a1o activities appear:ed-to be in noncompliance with NRC requirements. -rhe Commonwealth Edison Company response to the Notice of Violation is.provided in the enclosure.
With regards to the accuracy of future submittals, our actions are described as part of our response to the second item of noncompliance.
r-,
If you have any further questions on this matter, please direct them to this office.
Very truly yours,
. ~~cS.
~tt,; D. L. Farrar 0
v
~ Director of Nuclear Licensing lm Attachment cc:
NRC Resident Inspector - Dresden
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MAY 2 9 *1985
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APPENDIX RESPONSE *TO**NOTICE OF *VIOLATION As a result of the inspection conducted on March 20-23 and April 4, 1985, in accordance with the General Policy and Procedures for NRC Enforcement Actions, the following violations are identified:
ITEM NO. 1 10 CFR 50, Appendix B, Criterion V, as implemented by CECo QA Manual, Section 5, states, in part, "Activities affecting quality shall be prescribed by documented instructions, procedures or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings~"*
Contrary to the above:
- a.
The licensee performed six splices on Class lE safety shutdown cables without prescribed instructions, standards, or specifications.
- b.
The licensee installed six Class lE l/C 500 KCMIL, 600V safety shutdown cables without instructions or procedures.
DISCUSSION The item of non-compliance refers to the lack of instructions or procedures to perform cable splices and installation. During the preparation of the original traveller these tasks were not covered in detail because it was believed that they were within the craft capability of the Commonwealth Edison Maintenance personnel.
The splice kits were purchased, as safety-related equipment, from a manufacturer which had been previously used by Commonwealth Edison.
Specifications for the splice kits were sufficient to withstand an environment more demanding than would exist at the installed location.
Additionally, the Master Electrician, who was present during the fabrication of one splice, determined the methods used were sound.
The traveller for cable installation was believed to be sufficient since :
the length installed was short enough to do by hand. Because of existing cable, it is believed that the lack of appropriateJnstruction was an isolated case
- CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED Upon discussing the NRC Inspector's views on the above items a complete review of the modification was conducted by the station. The Maintenance Staff Engineer then added specific work instructions covering cable splicing and installation of the modification~ In parallel a complete training prog~am on specific cable splicing instructions will be given to every available Maintenance Electrician
. - by the. Master Electrician.
CORRECTION ACTION TO* AVOID *FURTHER *NONCOWLIANCE Personnel involyed in cable splicing will be trained and certified
- before any field work is started. Cable installation and splicing work i~structions will accompany the modification.
DATE WHEN FULL*COtvPLIANCE*WILL*BE*ACHIEVED Full compliance will be achieved when 'the modification is completed.
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ITEM NO~ 2 10 CFR 50, Appendix B, Criterion III, as implemented by CECo QA Section 3-1, states, in part, "Measures shall be established to that design basis requirements are correctly translated into specifications, drawings, procedures and instructions.
- Manual, assure.
Contrary to the above, the licensee's Engineering Change Notice, ECN D-85E-Ol dated February 28, 1985, and Work Request 042720, Rev~ O, did not translate the requirement to place out of service those cables installed in the same tray with cables having field splices in accordance with the licensee's field modification safety evaluation dated March 13, 1985.
DISCUSSION The item in question was contained in a synopsis of the engineering design and project history. This was intended for information only and was not to be construed as a part of the safety evaluation.
The design of any modification is subject to change during the project for many reasons. "This particular project was changed extensively as a result of the meeting held at the Region III offices on March 8, 1985.
Note that this was after the date of the Engineering Change Notice in question.
One of the concerns raised during this meeting was the suitability of splices made in cable pans. Commonwealth Edison was told that Regulatory Guide 1.89 does not allow cable splices to be made in cable pans.
The project was then reviewed as a result of this meeting.
The only reference to splices in Regulatory Guide 1.89 found was the need for splices to be environmentally qualified to the accident condition of the area where the splices are located. Unsure of the reasons why splicing in a cable pan would be unacceptable and due to time constraints, a conservative approach was taken. All equipment in the area was reviewed to determine which items needed to be in service and where the cables for this equipment are located.
The consulting engineering firm informed Commonwealth Edison that the cables in this area appeared not to be required and should not have been in service. The consultant was instructed by CECo to provide the required design documents necessary to disconnect or isolate any cables in the cable pan found to be in service following a more thorough review.
The above information was transferred entirely by telephone.
No formal letters or other documentation were exchanged.
The design summary dated March 13 was written based on this information.
4 -
Subsequently~ Dresden Station personnel expressed a preference for locating the splices in metal enclosures. After an inspectio.n of the locations where these "splice boxes" were to be located on March 19, 1985, another Engineering Change Notice was prepared, ECN D-85E-02 dated April 2, 1985.
The NRC was not notified of this change as the March 13 letter was intended for information only and as an overview of the design concept.
The use of splice boxes was a more conservative approach but did not change the intent of the modification.
CORRECTIVE ACTION TAKEN-AND RESULTS*ACHIEVED Corrective action to mitigate the above noncompliance is by means of this letter. This letter shall correct the false statement contained in the March 13 design summary.
The requirement to have all other cables placed out of service has been eliminated. The requirement for
_ placing the splices in a metal enclosure have been translated to proper design documents by means of ECN D-85E-02 dated April 2, 1985.
CECo believes the original design was adequate. Splicing the cables in the cable pan would not have been a noncompliance. Regulatory Guide 1.75 states, in part, "Cable splices in raceways should be prohibited" (a criteria set forth in--IEEE Std. 384) and gives as a basis that cable splices may initiate a fire, which can affect cables in redundant divisions. The only equipment in the Unit 1 HPCI building important to safety is the lC battery and the accessory equipment required for this battery. Therefore, a failure of these splices would not cause any further degradation of equipment_ important to safety.
CORRECTIVE ACTION-TAKEN TO-AVOID FURTHER-NONCOMPLIANCE The personnel involved in this project as well as all other engineers in the Dresden/Quad Cities project group have been reminded of the need to provide the NRC with accurate information. Also, the personnel.
involved in this project have been.further reminded of the need for proper documentation as required for projects affecting safety related equipment, whether or not the project is classified as being safety related. This should be sufficient to prevent further noncompliance.
DATE*WHEN*FULL*COMPLIANCE WAS-ACHIEVED Full compliance has been achieved at this date.
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