ML19246C267
| ML19246C267 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 06/29/1979 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Brian Lee COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 7907240064 | |
| Download: ML19246C267 (3) | |
See also: IR 05000373/1979013
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UNITED ST ATES
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M 2 S IS/S
Docket No. 50-373
Docket No. 50-374
Commonwealth Edison Company
ATTN:
Mr. Byron Lee, Jr.
Vice President
P. O. Box 767
Chicago, IL 60690
Gentlemen:
This is in response to your letter dated June 1, 1979, informing us of
the steps you have taken to correct the noncompliance identified in our
letter dated May 1, 1979.
Regarding Item 1.A, the CECO response addressed Section 7.5.2.2.b.1 of
the La Salle FSAR. According to NRR, the exception identified in this
section does not exclude associated components (i.e., transmitters,
cables, etc.) from being classified as safety related. The exception
pertains to tue malfunction of recorders and indicators during a seismic
activity but not afterwards. The recorders and indicators must withstand
the seismic activity.
If you feel that the " safety related" aspects of
this matter as opposed to the seismic qualifications are still matters of
discussion with NRR, we will reconsider the appropriateness of our enforcement
action. We currently consider the noncompliance as valid.
Therefore,
submit to this office within thirty days of your receipt of this notice a
written statement or explanation in reply:
(1) corrective action taken
and the results achieved; (2) corrective action to be taken to avoid
further noncompliance; and (3) the date when full compliance will be
achieved.
Regarding Item 1.B, your response for corrective action to avoid further
noncompliance identified a review of all safety-related HVAC systems. We
will assume that yoar actions will encompass t.he identification and
control of similar situations for all safety-related components regardless
of systems.
With respect to item number 4, aur enforcement conclusion remains unchanged
based on the following observations:
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79072400M
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Commenwealth Edison Company
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JUN 2 91979
1.
Your audit program is intended to ensure that timely inspections are
performed on ongoing activities and thereby assure the QA program
effectiveness.
Our inspection identified an area where timely
inspections were not performed and documented in a sequence compatible
with the work i.1 progress.
This inadequacy which involved the
installation of the various seismic category 1 nuclear steam supply
system panels, specifically identified that:
The projected lengths of embeded bolts, which hold down the
a.
NSSS panels and prevent them from being damaged in case a
seismic event takes place, were less than the specified
3".
b.
The clearance between some panel frames and the floor were
either less than the specified 1 1/2" or more than 2"
A reactor equipment drain line was installed through a seismic
c.
category 1 NSSS panel No. 1HP22P074.
d.
The storage condition of panel 1H22P009 installed at approximate
elevation 710' on the south side of the containment was not
protected after installation as were the other installed panels.
What's more, we feel the identified problems went undetected because
the activity war neither audited nor surveyed.
Therefore, we believe
that a mechanism to detect and correct inadequacies in a timely
manner was rendered ineffective in this case.
2.
Surveillances are included in the scope of your QA program.
Effective
surveillance of ongoing activities should have identified that the
Morrison Construction Company (MCC) inspection procedure PC-10 could
not be properly implemented for the following reasons:
Manufacturer's Instruction Manuals and or Special Instructions
a.
were not obtained and distributed to the installation / inspection
personnel as stipulated in Paragraph 2.1 of the procedure
PC-10.
b.
Verification, that the equipment base and the foundations are
compatible, was not performed as required in Paragraph 4.1 of
procedure PC-10.
As acknowledged in your response, no installation tolerances
c.
were specified for the panels, consequently, acceptance / rejection
criteria were absent for adequate inspections.
Records indicate
that the base mat was poured in October 1974.
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Commonwealth Edison Company
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JUN 2 9 E73
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3.
Even though the sequence of the installation of the NSSS panels
includes work performed by Walsh Company who installed the foundation
bolts and poured the base mat in 1974, your proposed audit is being
limited to MCC's procedure PC-10.
The above discussion is presented as the basis for our concern that your
audit program which relies on surveillances and audits may not focus
sufficiently on interface activities whcre more than one contractor is
involved in the installation of equipment.
In addition to the above, we do not feel that you have addressed the
concerns expressed in our May 1, 1979, letter in which we requested your
planned efforts to inspect and ve:ify the adequacy of the installations
identified in noncompliance Items 1.C and 2.
We request that additional
information be forwarded to this office within 20 days.
If you have any questions concerning this matter, please contact this
office.
Sincerely,
%a..b ,Y
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6 James G. Kep
er
Director
cc:
Mr. L. J. Burke, Site
Project Superintendent
Mr. T. E. Quaka, QA
Supervisor
Mr. R. H. Holyoak, Station
Superintendent
cc w/ltr dtd 6/1/79;
Cent.21 Files
Reproduction Unit NRC 20b
Local PDR
LTIC
Mr. Dean Hansell, Office of
Assistant Attorney General
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