ML19242A287
| ML19242A287 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 06/21/1979 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Brian Lee COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML19242A288 | List: |
| References | |
| NUDOCS 7908010304 | |
| Download: ML19242A287 (4) | |
See also: IR 05000373/1979006
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UNITED STATES
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GLTN ELLYN. ILLINOIS 60137
JUN 211979
Docket No. 50-373
Commonwealth Edison Company
ATTN:
Mr. Byron Lee, Jr.
Vice President
Post Office Box 767
Cnicago, IL 60600
Gentlemen:
We reviewed your response dated April 17, 1979, to our Notice of
Violation letter dated March 19, 1979.
As requested in your response,
a meeting was conducted between Mr. C. Reed and othe members of
your staff and Messrs. J. Streeter and F. Maura of this office on
May 15, 1979, at the La Salle County Station to resolve the areas of
disagreement. As a result of that meeting and subsequent teleplone
conversations between Mr. C. Reed of your staff and Messrs. J. St reeter
and R. Heishman of our office, we feel our positions have been
clarified and no further response froa) you is required.
The items
you questioned and our resolution of these questions are discussed
in the following paragraphs in the arder in which they appeared in
our Notice of Violation.
Item 1.a
As we have discussed with Mr. Reed and other members cf
your staff, our position on adherence to preoperational
test procedures is as follows:
If a preoperational test procedure directs personnel to
take specific actions (e.g.,
start a pump, turn a valve,
jump a battery cell, etc.) and those actions are not
taken, the failure to take those actions constitutes a
procedure chang.e which must be authorized in accordance
with administrative contcols for procedure changes.
If a
preoperational test procedure directs personnel to con-
tinue a test or test step (s) until certain results are
achieved or verified and those results are not and cannot
be achieved or verified without equipment maintenance or
adjustment, the failure to achieve the expected results
due to the unexpected equipment performance constitutes a
test deficiency and not a procedure change.
Similarly, if
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JUN 211979
Commonwealth Edison
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a test deficiency renders a subsequent test step (s) inappli-
cable, the failure to perform the inapplicable step (s)
constitutes a test deficieacy and not a protadure change.
Continuation f a test after test deficiencies are encountered
does not cons;itute a procedure change.
The DC Distribution Preoperational Test, PT-AP-102, directed
personnel to continue the acceptance test until the battery
terminal voltage reached 210 volts. The test procedure
also instructed pecennnel to continue the test even if it
was necessary to jumper cells which approached the point
of polarity reversal.
The STE elected to not take the
specified actions and did not obtain approval for the
procedure change. Therefore, it is our position that the
apparent item of noncompliance as originally stated in our
March 19, 1979, letter remains unchanged.
Item 2
We were aware of your initial flush procedures and do not
question their adequacy.
However, our concern was and
continues to be that you did not have adequate procedures
to assure reflushing after maintenance or modification of
a system or component which had been previously flushed.
We understand that your plans are to:
Review all MRD's issued prior to the initiation of
a.
the practice of stamping for flushing review to
determine if a reflush is necessary.
b.
Control all future maintenance work through the use
of the MRD's system.
c.
Use the MRD system to cover the installation and
removal of all temporary iastallations such as spool
pieces, connections, etc.
d.
Use the MRD system or develop a new system to cover
items required under the original contract but which
may have been missed at the shop and cow must be
performed at the field.
It is our position that this item remains an iter. of
noncompliance.
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JUN 211979
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Commonwealth Edison
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During the meeting on May 15, 1979, representatives of
your staff indicated they had clearly understood our
concern (i.e., lack of reflush controls for maintenance or
modifications performed subsequent to the initial flush)
discussed during the inspection and at the exit interview,
but vere later confused when the report and apparent item
of noncompliance were received.
While we agree that our
report and related Notice of Viulation could have more
clearly stated our concern, we believe it would expedite
resolution of questions if your staff would contact our
inspector for clarification when your staff believes a
report does not clearly represent discussions at the site.
Item 3
Information contained in your Apri) 17, 1973 letter and
discussions on May 15, 1979, with personnel involved in
the development of DC Distribution Preoperational Test
PT-AP-102, indicates that during development of the pro-
cedure you evaluated the need for correcting specific
gravity for electrolyte level as suggested in the battery
manual.
This information was not made available to our
inspectors during previous inspections in this area.
We
understand that your evaluation determined the adjustment
sptional and not a design requirement or acceptance
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Based on this information, we no longer consider
this item to be an item of noncompliance.
.M owev e r , it is our position, as stated at the meeting of
May 15, 1979, that corrections of specific gravity for
electrolyte level changes are required after the Lattery
has been placed on float for a minimum of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> fol-
lowing completion of an equalizing charge.
This is nec-
essary to determine the true specific gravity of the
cells. The true specific gravity reading is needed to
dete rmine if there has beer. a decrease in cell capacity.
We have discussed this subject with a representative of
your battery vendor, Mr. W. F. Hurley, Applicati-
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Specialist for the Gould, Inc. Industrual Batte
Division,
Langhorne, Pennsylvania, and he is in agreement with our
pisition.
Mr. Hurley stated that Mr. M. A. Todd of Gould,
Inc. (Chicago) has been asked to relay this information to
your staff. We plan to review your surveillance pro-
cedures covering this subject to ensure that true specific
gravity readings are monitored.
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JUN 211979
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Commonwealth Edison
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We .1i11 examine your corrective actions identified in tais letter
and your April 17, 1979, letter during a future inspection.
Your
cooperation with us is appreciated.
Sincerely,
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a {9 k "'Lll g '~
ames G. Kepp
er
Director
cc:
M:- L. J. Burke, Site
Project Superintendent
Mr. T. E. Quaka, Quality
Assurance Supervisor
Mr. R. H. Holyoak, Station
Superintendent
Mr. C. Reed, Assistant
Vice President
cc w/1tr dtd 4/17/79:
Central Files
Reproduction Unit NRC 20b
Local PDR
Mr. Dean Hansell, Office of
Assistant Attorney General
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