ML19289F358
| ML19289F358 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 04/18/1979 |
| From: | Reed C COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19289F351 | List: |
| References | |
| NUDOCS 7906070273 | |
| Download: ML19289F358 (9) | |
Text
.
CommonweO th Edison l
One Firs' Nr.u
. Plaza Ch ca r lH.nois y Address Reply to Post 0" ce Bon 767 Chicago. I:hnois 60693 April 18, 1979 Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
LaSalle County Station Units 1 and 2 Response to IE Inspection Report Nos.
T 373/7,9-1 @ d 50-374/79-08 NRC Docket Nos. 50-373 and 50-374 Referenee (a) :
G. Fiorelli letter to B. Lee, Jr.
dated March 15, 1979
Dear Mr. Keppler:
The following is in response to the inspection conducted by Messrs. P. A. Barnett and F. T. Daniels on February 21-23, 1979 and by Mr. J. H. Neisler on February 22-23, 1979 of activities at LaSalle County Units 1 and 2.
Reference (a) indicated that certain activities appeared to be in nonecxnpliance with NRC requirements.
These activities are addressed in the enlosure to this letter.
Please refer any additional questions you may have on this matter to this office.
Very truly yours, S
Cordell Reed Assistant Vice-President enclosure 2232 146
?R 2 01979 79060707 7 3 h
Conunonwealth Edison NRC Docket Nos. 50-373/374 ENCLOSURE RESPONSE TO NOTICE OF VIOLATION Items of apparent noncompliance identified in Appendix A of the NRC letter dated March 15, 1979 are responded to in the following paragraphs.
1.
10CFR50, Appendix B, Criterion XVI states, in part, measures shall assure that the cause of the condition (adverse to cuality) is determined and corrective action taken to pre-cluc e repetition."
Commonwealth Edison Company Top'A corrective action system.
ical Report CE-1-A, Revision 5, Section 16.0 states, in part, will provide follow-up to assure that corrective measures are effectively implemented."
Contrary to the above, on February 22, 1979, the inspector identified over 30 cables trays containing debris which could be hazardous to installed cables or cables to be installed.
The licensee had previously identified these conditions as corrected on Corrective Action Report No. 676, dated October 6, 1978.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED On February 22, 1979, the RIII in'spectors observed more than 30 cable trays which contained debris which could be detrimental to cable installed and cable to be installed.
The cable trays are as follows: 1021A-1BP, 1020A-1BP, 1019A-1BP, 1310A-1YP, 1310B-1YC, 1310C-1YK, 1311A-1YP, 1311B-1YC, 1311C-1YK, 1305A-1YP, 1306A-1YP, 1307A-1YP, 1320A-1YP, 13203-1YC, 1320C-1YK, 1321A-1YP, 1321B-1YC, 1321C-1YK, 1322A-1YP, 1322B-1YC, 1322C-1YK, 1030A-1BP, 1030B-1BC, 1331A-1YP, 1365A-1YP, 1365E-1YK, 1358A-1YP, 1359B-1YP, 1049A-1BP, 1062C-1BK, all of the top trays in the cable spreading room, and all of the trays in diesel rooms No. O, 1A, and 1B.
The licensee has documented, on Corrective Action Report No. 676, dated October 6,1978, approximately 250 locations in which '
trays contain debris.
A letter from the H. P. Foley Company QC Manager to the CECO QA Manager, dated October 6, 1978, identified the Corrective Action Report to be the result of an October 4, 1978 meeting.
The meeting was part of the cor-rective action identified on LaSalle QA Surveillance Report No.78-476 initially dated October 3, 1978.
The Meeting Notes, dated October 4, 197Ee documented that two cables had been pulled through cable tray contained debris (e.g. bricks, mortar, pieces of pipe, and angle iron); that a welder was observed welding above cabic tray contained cable with no protection provided for the cable and that the welding machine was placed in the cable tray itself (over cable) with no protection pro-vided to the cable.
The Meeting Notes also addressed a discussion that ".
concerned the apparent lack of involvement of Foley 2232 147
Commonwealth Edison NRC Docket Nos. 50-373/374 QC inspectors during all aspects of the cabic pulling operation Surveillance Report No.78-476 was closed on October 13, 1978.
Corrective Action Report No. 676 was closed on December 1, 1978.
The more than 30 trays observed during this inspection contained the following:
Constructed scaffolding, nails, cans, light bulbs, glass bottles, wood, pieces of steel and conduit, buckets, and paper trash.
Failure to take adequate corrective action is contrary to the requirements of 10CFR50, Appendix B, Criterion XVI, and CECO Topical Report CE-1-A, Revision 5, Section 16.0, and is an item of noncompliance as identified in Appendix A of the report transmittal letter.
(373/79-11-02)
During a phone conversation on February 27, 1979, subsequent to the inspection, the Director of Quality Assurance indicated that an extensive effort had been implemented to clean the raceway and that measures would be taken to preclude recurrence.
On February 24th and 25th, approximately 150 electricians were used to clean out miscellaneous debris from cable pan.
A check on the adequacy of this major clean up was made by site Quality Assurance on Monday, February 26.
The areas inspected were greatly improved and, in general, acceptable.
' CORRECTIVE ACTION TO AVOID FURTHER NONCOMPLIANCE Full time cable pan clean up crews have been assigned to con-tinually monitor cabic pan cleanliness.
In addition, a housekeeping plan has been implemented for the control of work activities m~
conditions that can affect the quality of work at LaSalle County Station during the pre-operational phase.
Site QA has added two inspectors to the staff from Conam Inspection (site independent testing agency).
These inspectors are working first and second shifts and are primarily responsibl'e for identifying cleanliness problems, as well as, contractor adherence to Work Instructions.
In addition, Station Construction ;.as been responsive to the tray cleanliness surveillances being performed by CECO site QA and Conam Inspectors.
This is demonstrated by the 70 electricians that were brought in on Sunday, March 18, to clean up pan after a report on March 16.
2232 148 DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has now been achieved.
Commonwealth Edison NRC Docket Nos. 50-373/374 2.
10CFR50, Appendix B, Criterion XV states, in part, " Measures shall be established to control materials which do not conform to requirements.
, parts, or components Commonwealth Edison Company Top"ical Report CE-1-A, Revision 5, Section 15.0 states, in part, Items involving construction.
which are non, conforming.
their inadvertent use or installation.". will be controlled to prevent Contrary to the above, on February 23, 1979, the inspector identified nine cables which had been burned and a partially disassembled cable raceway hanger which were not controlled in accordance with the established QA program.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED On February 23, 1979, the RIII inspector observed nine cables (Nos. 1RH150, 1RH022, ILP022, ILP010, IRIO71, 1RF010, ILPO46, 11P011, and both conductors of No. 1DC078) which had been burned.
The burned cables were located in Tray No. 1363A-1YP in the Unit 1 Reactor Building, northeast quadrant at Elevation '/10'.
The severity of the burned cable insulation appeared to range from heat bubbles to severely charred.
The licensee had not identified these cable burns.
The installation contractor indicated that after repeated cable inspections which was notthe burned cable may have the contractor normal practice.
This condition (i.e. failure to identify damaged and nonconforming cables) is contrary to the requirements of 10CFR50, Appendix B, Criterion XV, and CECO Topical Report CE-1-A, Revision 5, Section 15, and is an item of noncompliance as identified in Appendix A of the report transmittal letter.
(373/79-11-03)
The burned cables were documented on Nonconformance Report No.
120, dated February 23, 1979, subsequent to the NRC finding.
During a phone conversation on March 1, 1979, subsequent to the inspection, the CECO Site QA Manager indicated that represen-tatives, from both cable manufacturers involved, had been on-site to assess the damage to the cables.
The assessment is to be documented and forwarded to CECO engineering for review.
On February 23, 1979, the RIII inspectors observed a disassembled and uncontrolled crossbrace member of cable raceway hanger no.
116-3HS, which supported cable no. 1369B-1YP.
The hanger was
' located in Unit 1 Reactor Building at Elevation 710'.
The hanger brace, which had been accepted as complete, was apparently disassembled to allow room for an installed snubber.
Failure to document this condition to assure future corrective action, is contrary to the requirements of 10CFR50, Appendix B, Criterion SV, and CECO Topical Report CE-1-A, Revision 5, Section 15. and is an item of noncompliance as identified in Appendix A of the report transmittal letter. (373/79-11-04) 2232 149
Commonwealtn Edison NRC Docket Nos. 50-373/374 CECO Nonconformance Report Number 287 documenting the damaged cables has been returned from CECO engineering to the site.
Corrective action approved by Enginecting was to replace damaged cable ILP022 (1LP022 was mistakenly reported as 1RH022 in contractor nonconformance report).
In addition, Okonite Nuclear grade splice tapes have been applied over the jackets of cables 1RH150 and 1RF010 in the area where residue was found on the cable.
The tapes were applied in accordance with the Okonite instruction sheets.
The cables identified are now in compliance.
Immediate cetion taken on the disassembled cable raceway hanger is as follows:
The Station Construction Project Superintendent, Mr. Leo J. Burke, issued a memo to all on site contractors requiring them to notify the responsible contractor prior to disassembling or removing any equipment that is interfering with the progress of work.
The brace found during/25/79.the NRC inspection was identified on H. P.
Foley NCR 125, dated 3 CORRECTIVE ACTION TO AVOID FURTHER NONCO.PLIANCE The space above the damaged cable has been covered and additional crews have been assigned to pan clean up, thus keeping combustible material out of th,e tray.
Concerning the hanger removed because of an interference:
Normally such interferences are discussed between the responsible contractors and the removing contractors personnel.
The inter-ferences are then coordinated by the CECO FCR procedure.
In addition to the notification by Mr. Burke's memo, the site Quality Assurance Department has arranged for Conam inspectors to do area surveillances.
Their principal function is to check house-keeping but have also been instructed to identify any dismantled equipment.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has now been achieved.
2232 150
Commonwealth Edison NRC Docket Nos. 50-373/374 3
10CFR50, Appendix B, Criterion V, states in part, " Activities affecting quality.... shall be accomplished in accordance with.... instructions...."
Commonwealth Edison Company Topical Report CE-1-A, Revision 5, Section 5 states, in part, instructions.... will also reference applicable acceptance criteria which must be satisfied to assure that the quality related activity has been properly carried out."
Contrary to the above, on' February 21-22, 1979, the inspectors observed more than sixteen cables for which the minimum bend radius was not maintained as specified in instruction HPFCo-WI-400, Revision 4 CORRECTIVE ACTION TAKEN AND RESULTS 7.CHIEVED On February 21-22, 1979, the RIII inspectors observed more than 16 cables for which the minimum bend radius was not maintained as specified in instruction HPFCo-WI-400, Revision 4 The cables are as follows:
Na, 1RI-073 and No. 1RI-074 at motor control center MCC-121Y; No 1RH-122, No. 1RH-130, No. LLC-084, No. 1RH-430, No. 1RH-433, and No. 1RH-411 at MCC-136Y; No. lHP-174, No. lHP-163 and No. 1HP-166 at switchgear bus lh3; No. 1HP-139 and No. 1HPO80 at MCC-143-1; No. 1RH-193 at switchgear 135X-3; No. 1FC-031 at switchgear 135Y; No. 1N3-064 at switchgear ll2Y; No. 1HG-023 and No. 1FR-163 at tray 3953-13C; and the majority of the cables going into cabinets 1H13-F631, 1H13-F618 and 1H13-P622 This condition (i.e. failure to follow instructions) is contrary to the requirements of 10CFR50, Appendix B, Criterion V, and CECO Topical Report CE-1-A, Revision 5, Section 5, and is an item of noncompliance as identified in Appendix A of the report transmittal letter.
(373/79-11-05)
During a phone conversation on February 27, 1979, subsequent to the inspection, the Director of Quality Assurance indicated that approximately 31 cables, in total, had been identified where minimum bend radius had not been maintained.
The Director indicated that these cables would be replaced.
On February 27, 28, and March 1, four H. P. Foley Cuality
- Control Inspectors made a thorough inspection of the Auxiliary and Reactor buildings to identify any possible violations of cable minimum bending radius.
This inspection disclosed that there are 22 cables not in compliance with the minimum bend radius.
The 22 cables are documented on H. P. Foley NCR's # 122 and # 123 and H.P. Foley Hold Cards were hung on each cable.
2232 151
Commonwealth Edison NRC Docket Nos. 50-373/374 CECO Station Construction personnel verified each of these 22 possibic violations and it was found all violations occurred where the cables were being trained for terminations.
The contractors termination people train the cable into the gear from the cable pan and it is at this time, after cable pulling is complete, that the violations occured.
Station Construction contacted the manufacturer of the cables and the manufacturer indicated the present minimum bending requirements were based on cables when under tension.
The manufacturer stated that there is a different minimum bend radius requirement when the cable is not under tension, but being trained into place.
CECO NCR #290 identifies the proposed minimum bend radius require-ments for cables not under tension and requests direction in cor-recting the 22 cables not in compliance with the present require-ments.
This NCR is now under review by the 4E, if the suggested corrective action is approved (i.e. new bend radius criteria) 20 of the 22 cables will be in compliance.
The cables in violation will be repulled.
CORRECTIVE ACTIO.'T TO AVOID FUETHER UO:!CC:!PLIANCE H. P. Fcley personnel have been reinstructed as to installation procedures.
Minimum bend radius requirements will be included in the H. P. Foley termination procedure (WI 500) upon disposition of NCR #290.
DATE WHEN FULL CCGPLIANCE WILL BE ACHIEVED Pull compliance is expected by May 30, 1979.
2232 152 6
Commonwealth Edison NRC Docket Nos. 50-373/374 4.
10CFR50, Appendix B Criterion X states in part, "A program for inspection of activities affecting quality shall be established and executed.
. to verify conformance with the documented instructions.
. Commonwealth Edison Company Topical Report CE-1-A, Revision 5, Section 10, states in part, " Inspection and test control points will be established as required to assure quality of items.
Contrary to the above, on February 22, 1979, the inspector identified that no measures were being taken to assure that the maximum cable pull tensions, specified in instruction HPFCo-WI-400, Revision 4, were not being exceeded.
CORRECTIVE ACTION TAKEN AND RPSUITS ACHTEVED On February 22, 1979, the RIII inspector identified that no measures were being taken to assure that the maximum cable pull tensions were not being exceeded.
The tensions were speci-fied in instruction HPFCo-WI-400, Revision 4 Failure to provide adequate inspections te assure maximum cable tensions are not exceeded is contrary to the requirements of 100FR50, Appendix B, Criterion X, and CECO Topical Report CE-1-A, Revision 5, Section 10, and is an item of noncompliance as identified in Appendix A o_f the report transmittal letter.
(373/79-11-06)
The licensee indicated, both during and after the inspection, that appropriate measures (design calculations and/or monitoring) would be taken to assure that maximum cable pull tensions are not exceeded.
As indicated, design calculations have been made on conduit installations.
Each floor of the Auxiliary and Reactor buildings were canvassed.
Conduits having mulitple bends and significant lengths were sketched and the estimated pull tensions were calculated.
In all, 84 calculations were completed and the results tabulated.
In only five cases did the calculated pull tension exceed 50% of the maximum allowable; and in only one case exceeded 100% (this happened to be non-safety related cables in a seismically supported conduit).
Three things should be noted about the calculations 1
Maximum allowable tension is computed by taking the number o;f c) ables in a conduit times the maximum pull tension of the ucakest cable.
A less conservative and probably more common method is to take the sum of the individual max pulling tensions.
g;Y$
223215%
Commonwealth Edison NRC Docket No. 50-373/374 2)
A friction factor of.4 was used in the calculations.
Sample pulls were made and actual pull friction factors were from.4 to slightly more than.5.
More sampic pulls will bc made to verify friction factors.
- 3) The tensions were cal-culated assuming that the cables were pulled from the end of the conduits which would have resulted in greatest tension.
Therefore, it appears that maximum pull tensions have not been exceeded but more study is still necessary.
It should be stressed that the contractors procedures require pull tension measurements be taken whenever a cable is not pulled by hand.
The area of concern was that of monitoring maximum cable tensions during the hand pulling of cables through conduit.
The NRC inspector did not see any evidence that the maximum pulling tensions were exceeded.
CORRECTIVE ACTION TO AVOID FURTHER MONCOMPLTANCE Of the 84 calculations made none of the cables whose conduits, with total bends dding to less than 300, exceeded 50% of maximum tension.
The contractor will add to their conduit checklist procedure a checkpoint to verify whether cogduit bends exceed 270.
If the number of degrees does exceed 270, the cable pull tensions will be measured or a calculation made to assure max pull tension will not be exceeded.
This will be done even though cable may be hand pulled.
DATE WHEN FULL C0"PLIANCE WILL BE ACHIEVED The implementation of the contractors revised procedures and the completion of the study on previous pulls is expected to be complete by June 30 at which time Full Compliance will be attained.
2232 154