ML19208D800

Responds to NRC 790719 Ltr Re Violations Noted in IE Insp Repts 50-373/79-24 & 50-374/79-17.Corrective Actions:Review of Info in Design Certification Block on Form N-5 & Sned Procedure Q-34.Orientation of Personnel Conducted

ML19208D800
Person / Time
Site:	LaSalle
Issue date:	08/10/1979
From:	Reed C COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19208D798	List: ML19208D800
References
NUDOCS 7909290571
Download: ML19208D800 (6)

Text

.-

. Commonwealth Edison

- One First Nationat Plaza. Chicago. lilinois Address Reply to. Post Office Box 767

' Chicago, lihnois 60690 August 10, 1979 Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Cc7 mission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Subject:

LaSalle County Station Units 1 and 2 Response to IE Inspection Report Nos. 50-373/79-24 and 50-374/79-17 NBC Docket Nos. 50-373 and 10-374 Reference (a): J. G. Keppler letter to B. Lee, Jr.

dated July 19, 1979

Dear Mr. Keppler:

The following is in response to the investigation conducted by Mr. C. C. Williams on May 30 and 31; and June 4, 1979 of activities at LaSalle County Units 1 and 2.

Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements. These activities are addressed in the enclosure to this letter.

Please refer any additional questions you ray 'have on this matter to this office.

Very truly yours, ow -

b/ Cordell Reed Assistant Vice-President enclosure 7"oosee g77 1055 010 A"P131979

'. Commonwealth Edison NRC Docket Nos. 50-373/374

. ENCLOSURE RESPONSE TO NOTICE OF VIOLATION The response to the item of apparent noncompliance identified in Appendix A of the NRC letter dated July 19, 1979 (IE Report Nos. 50-373/79-~24 and 50-374/79-17) is provided in the following paragraphs.

1. 10 CFR Part 50, Appendix B, Criterion XVI, states ir. part that " measures shall be established to assure that conditions adverse to quality such as ... deficiencies ... and non-conformances are promptly identified and corrected. Further, the CECO. Topical Report CE-1A dated January, 1976 and CECO.

QA Manual Quality Requirement 16 commits to the establishment of measures for identification and corrective action regarding nonconformances.

The applicable CECO. Station Nuclear Engineering Department Procedure No. Q-34 issued Decemoer 1, 1977 (" . . . method for processing Data Report Form N-5 ...") among other requirements, specifies in Paragraph No. 3.2.3, that the Project Engineer

" reviews N-5 form with supporting documents for correctness..."

Contrary to the above, on March 14, 1979, the licensee's representatives established a Certificate of Compliane) (N-5 Data Report) which indicated that a Ccrtified Stress ) qalysis Report had been established by the Architec't Enginuer (Sargent and Lundy) for Unit 1 Feedwater System, whereas, on . Tone 4, 1979, it was confirmed that a certified Stress Analysis Report for the Unit 1 feedwater system had not been established. The control systems apparently were not implemented.

A. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED It is acknowledged that Commonwealth Edison certified the subject N-5 Forms without prior review of all supporting documents (specifically, the Certified Stress Report) and that this was in apparent noncompliance with the cited Station Nuclear Engineering Department (SNED) procedure (0-34). Although action has been taken to both correct this occurrence and prevent its recurrence, it is relevant to note the following:

1055 011

.- Commonwealth Edison NRC Docket Nos. 50-373/374 (1) The certification was made in the belief that the Certified Stress Report, as distinguished from the Stress Ar.alysis Report completed prior to certification based on as-built drawings, was not required. Therefore, the existence of the certified Stress Report was not verified prior to certification.

(2) The N-5 Forms in question had not previously been pr'scessed at the LaSalle county site by either the authorized installer (Morrison) or the certificate of authorization holder (Commonwealth Edison) . This is due in part tc the fact that LaSalle County is one of the earliest plants at which ASME Section III rules are being applied for piping systems.

Although,in the judgement of Commonwealth Edison, the appropriateness of the subject noncompliance may be subject to question, corrective _ action to resolve the apparent violation was undertaken, as summarized in Paragraph 4 in the Region lII Investigation Report.

First, an inquiry was directed to the ASME Boiler and Pressure Vessel Committee to clarify the apparent ambiguities relative to completion of the N-5 Form. A copy of the response to this inquiry is attached. (See Attachment I) On the basis of this response, it is verified that the NA Certificate Holder (Morrison) can certify the N-5 Form prior to verification of the existence of a certified ~ Stress Report because that certific;.c ion applies only to the completeness of the piping system installa-tion, not its design.

Second, upon identification of a potential misinterpretation of the certification requirements for the N-5 Form, Commonwealth Edison haulted the signing of any more of these forms for piping systems requiring a certified Stress Report. The SNED procedure (Q-34) is being revised to clarify the Commonwealth Edison responsibl'.ty with regard to the N-5 Form.

Third, a stop work order was given for any Section XI work on piping systems for which there was any question on the need for a certified Stress Report. Upon the receipt and review of documentation from General Electric, the stop work was lifted

]

W 1055 012

- . Commonwealth Edison NRC Docket Nos. 50-373/374

- t on the recirculation system but. remains in effect on the feewater system. It is worth noting here that it is the judgement of Commonwealth Edison that Section XI work can proceed on systems on which the NA Stamp has been applied and that such stamping is authorized by the Code at such time as the Authorized Installer certifies the completion of the piping installation. Therefore, completion of the N-5 Form is not required. This position has been reviewed with the LaSalle County Authorized Inspector and meets with his agreement. A formal inquiry to ASME has not been made.

Fourth a complete review of N-5 Forms submitted to SNED was conducted. In those instances for which there was any reason to believe ASME Section III requirements had not been met, the signature of Mr. W. L. Stiede nas been retracted. It will not be re-af fixed until the existence of all required documentation has been veritied.

In addition, the int callation contractor has been directed to cease entering design informa' i.on on the N-5 Form.

We acknowledged that the portion of the form ent'itled, " Stress Analysis (Design) Reports" is the responsibility of Commonwealth Edison. This responsibility will be clarified in a revision to the applicable SNED Procedure Q-34 which is currently in progress.

B. CORRECTIVE ACTION TAK3N TO AVOID FURTHER NONCOMPLIANCE Commonwealth. Edison recognizes the importance of resolving the concern identified in thc Region III investigation report and has undertaken corrective action to assure the necessary compliance with ASME Code rules.

1. In the future, Commonwealth Edison personnel will review the information in the Design Certification block on the N-5 Form to assure that it is correct.

This review will be completed prior to certification of the N-5 Form by Commonwealth Fdison.

2. A comprehensive review and clarification of SNED Procedure Q-34 will be made. Orientation of s personnel in the application of that procedure will be conducted.

1055 013

Commonwealth Edison NRC' Docket Nos. 50-373/374

3. A procedure delineating the steps required to complete the N-5 Data Reports will be prepared by the installation contractor.

C. D.'sTE OF FULL COMPLIANCE Corrective actions to resolve the item of nnncompliance as describ2d in Paragraph A are complete.

Corrcctive action to prevent future recurrence of the subject noncompliance is in progress. Instructions have been given to assure the implementation of Item 1 in Paragraph B.

The revision to SNFD Procedure Q-34 will be implemented by October, 1979. An N-5 Form Procedure will be bmplemented by the installation contractor by c:tober, 1979.

?

1055 014

ATTACHMEN'l I The American Society of Mechanical Eng:neers I

{ C @-S }I Uruted Engineering Ce ver

• 345 E 47th St.. New York. N.Y. 10017

• 212-644-7722

• TWX-710-581-5267 THE BOILE3 AND PRESSURE VESSEL COMMITTEE July 30,1979 P. M. BRIST ER vice-ct:ahman W. L. H ARDING COC3onWealth Edison P. O Box 767 h.#" M. E SENBERG Chicago, IL 60690 B.W.BACE Att: W. L. Stiedc.

R.D.BONNER R. J. BOSN AK

Subject:

Section III, Division 1 N-5 Data Report Form CFP UCH Certification of Design Information L. J. CHoCKIE W. E. COOPE R W.o.coTY

Reference:

Your letter of June 8,1979 B. G. E ARN HE ART ASME File #NI 79-176 R. M. GiB50N R. C. GRIF FIN S. F. H ARRISON Gentlemen:

E. J. H EMZY E. L. K E MM L ER In response to your letter, it is our understi 'ing that yOU are y,k asking the following question:

J. LeC'O F F J. R. MACK AY QUESTION:

H. S. MAUK W. R. MIK E SE L L Is it required by ASME. Code .Section III that the NA Certificate Holder

" ELLER T.' "' O R g p be responsible for Certification of design information for a. piping C. E. R AWLINS system on the N-5 Data Report Form?

R. F. R E E DY W. R. SMITH, SR. REP LY ,

W. E. SOME RS No. The N Certificate Holder with overall responsibility for the piping system shall be responsible for the design of the piping system.

Yours truly,

/ b.

• Robert E. Glazier Assistant Secret ary (212) 644-8048 REG:cv .

1055 015

. e r r i R UNCIL FOR PROFESSIONAL DEVELOPMENT AND ENGINEERS JOINT COUNCIL