ML20039F348
| ML20039F348 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 12/04/1981 |
| From: | Reed C COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20039F341 | List: |
| References | |
| NUDOCS 8201120368 | |
| Download: ML20039F348 (4) | |
Text
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- O s Commonwealth Edison ons First Natiorcl Plua. ChiCCgo. tilinots j/ Address Reply to: Post Office Box 767 v
sg' Chicago. Illinois 60690 December 4, 1981 Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137.
Subject:
LaSalle County Station Unit 1 Response to Inspection Report No. 50-373/81-36 NRC Docket No. 373 Reference (a):
R. L. Spessard letter to Cordell Reed dated November 3, 1981
Dear Mr. Keppler:
The following is in response to the inspection conducted by Messrs. R. D. Walker and S. E. Shepley on. August 31 through October 2,
1981 of activities on LaSalle County Station Unit 1.
Re ference (a) indicated that certain activities appeared to be in noncompliance with NRC Requirements.
The Commonwealth Edison response to this notice of violation is provided in the enclosure.
In recognition of the potentially serious consequences of construction-test performed without adequate procedures, measures have been taken to assure the appropriate procedure development and review for such tests prior to performance.
A program has been implemented to imarove communication between the operating and-construction statfs to preclude recurrence of problems of the type discussed in this report.
To the best of my knowledge and belief the statements contained herein and'in the attachment are true and correct..
In some respects these statements are not based on my personal knowledge but upon information furnished by other Commonwealth-Edison employees. -Such information has been reviewed in accordance with Company. practice and I believe it to be reliable.
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DEC 819R
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l J. G..-Keppler December 4, 1981-Please address any questions you-may have concerning this matter to the office of Nuclear Licensing.
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~Very truly yours, 3-b' Re 1:.-.
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Cordell Reed j.
Vice President Enclosure
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NRC Resident Inspector - LSCS i
- SUBSCRIBED and SWORN to
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. Notary Public 2938N 4
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Enclosure Response to Notice _o f Violation The response to the item of apparent noncompliance i.dentified in Inspection Reoort No.. 50-373/81-36 is provided in the following paragraphs.
10 CFR 50, Appendix B, Criterion XI, requires that a test program shall be established to assure that all testing required to demonstrate that. structures, systems,- and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the. requirements and acceptance limits contained in applicable design documents.
The QA Manual, Quality Requireme.t 11-.0, Section ll.2,s tates that
- construction testing consists. of.onsite component testing such as hydrostatic testing,--pressure proof testing, pump and valve testing, actuation to verify proper installation and electrical continuity verification.
Written procedures or. checklists..will be employed and the status-of equipment both before and after testing will be documented. -Section ll.1 states that. construction. tests will be reviewed by the Site Construction Superintendent or Project Engineer and Site. Quality. Assurance._ Superintendent before,being approved by the Project Manager or Manager of Site Construction.
Contrary to the above, the inspector determined that pressure proof testing of the Secondary Containment was conducted during the weekend of.. September 26-27,.1981 without.an approved procedure as-required. _The test results_ indicated that the test will have to be repeated.
CORRECTIVE AClION TAKEN AND RESULTS ACHIEVED Following the first Secondary. Containment _ Leak Rate Test conducted during the weekend o f July 18, 1981, LaSalle County Station Startup Coordinator issued a -letter to the Startup Engineers stating "If a system'is run with interlocks out and.not within design tolerances a procedure would be required."
However, it was not his understanding at that, time that procedural approvals.per Quality Requirement 11.0 were required.
On that basis the September 28, 1981 test was conducted with a procedure approved _by the Startup Coordinator.
Commonwealth Edison Company management commitments were made. prior to the Second Test which were ultimately included in the response to the IE Inspection Report 50-373/81-30-10 on October 10, 1981.
The Second Test on September 28, 1981 was conducted by the Startup Test Engineer prior to learning of the commitment and the receipt of IE Inspection 50-373/81-30 on October 5, 1981.
. As specified in the October 30, 1981 response, all pressure proof tests will be conducted with properly approved procedures.
The construction test procedure for the Secondary Containment Test conducted during the weekend of November 7,1981 had all the approvals required.
In addition, noncompliance 373/80-24-09, specifically referred to lack of control of extra work resulting from a Nonconformance Report and'did not pertain to a construction test.
The proper changes have been incorporated in the Reactor Controls, Inc. program to control this type of work in the future.
CORRECTIVE ACTION TO AVOID FURTHER NONCOMPLIANCE It is felt that the timing between the September 28~ test and the October 30, 1981 response to the item of noncompliance which resulted in the performance of the proof test with a prceedure that was approved by the Startup Coordinator was an isolated case.
However, management has placed increased emphasis on inauring commitments are promptly relayed to the responsibile test personnel.
Any construction activities on Units 1 and 2 systems which can be construed to be " construction tests", as defined below, will be conducted in accordance with an approved procedure.
The approved procedure will be implemented only after review and concurrence by a senior member of the Station Operating Staff, and a shif t briefing by the individual in charge of conducting the test.
The construction tests being addressed herein are major evolutions such as Secondary Containment leak testing; and other evolutions wherein equipment is required to be operated outside the limitations of normal operating procedures and/or interlocks or other protective devices are to be defeated.
DATE OF FULL COMPLIANCE Full compliance has been achieved.
2938N
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