ML20053E346
| ML20053E346 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 05/13/1982 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20053E339 | List: |
| References | |
| 4060N, NUDOCS 8206070816 | |
| Download: ML20053E346 (5) | |
Text
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>O Commonwealth Edison
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$ O7 Address Reply to: Post Office Box 767 (j Chicago, Illinois 60690 May 13, 1982 Mr. James G. Keppler, Regional Administrator 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 NRC Inspection Report No. 50-373/82-11 NRC Docket No. 50-373 Reference (a):
C. E.
Norelius letter to Cordell Reed dated April 13, 1982.
Dear Mr. Keppler:
This letter is in response to the inspection conducted by Messra.
C.
C. Williams,
H. M. Wescott, J.
H.
Neisler, and other s ta f f members on February 9-12, 16-19, 23, 24 and March 5, 1982 o f activities at LaSalle County Station Unit 1.
Reference (a) indica-ted that certain activities appeared to be in non-compliance with NRC requirements.
The Commonwealth Edison Company response to the notice of violation is provided in the enclosure.
To the best o f my knowledge and belie f the statements contained herein and in the enclosure are true and correct.
In some respects, these statements are not based upon my personal knowledge i
but _ upon information furnished by other Commonwealth Edison and con-tractor employees.
Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
If you have any further questions on this matter, please direct them to this o f fice.
I Very truly
- ours, L.O. DelGeo rg e Director o f Nuclear Licensing 1m Enclosure cc:
NRC Resident Inspector - LSCS SUBSCRIBED and SWORN Jo be fore me this
/3 A day of Omd 1982 SJa. h I
Notary Poblic M 1 4 Ggg 8206070016 h h 3 PDR ADOCK PDR G
ENCLOSURE Apparent Item o f Noncompliance (50-373/82-11-01) 1.
10 CFR 50, Appendix B, Criterion V s tates, in part, " Activities affecting quality shall be prescribed by documented....
procedures.... o f a t ype appropriate to the circumstances...."
Commonwealth Edison Company Topical Report No. CE A, Revision 15, Section 5 s tates, in part, "The quality assurance actions carried out for.... construction, testing.... activities will be described in documented.... procedures....
These documents will assist personnel in assuring that important activities have been performed."
Contrary to the above, appropriate procedures had not been developed to prescribe Motor Control Center (MCC) breaker setting activities.
As a result, o f the.two safety related MCC's inspected, nine breaker settings were observed which did not conform to MCC breaker setting requirements.
Response
Corrective Action:
The CECO LaSalle OAD has generated site specific breaker setting guidelines for Klockner-Moeller and GE 480V.
Motor Control Centers (MCC).
These site specific guidelines were added to the LaSalle OAD Electrical Construction Test Procedures (ECTP)
Manuals in the following sections:
ECTP #1 - Motors ECTP #7 - Misc 480V Contactors/ Breakers ECTP #8 - Non-Motor Devices The appropriate procedure data forms (#1A, 7A & 8A) were also revised to record consistent data and to be more explicit as to what exact values on the S&L MCC Settings Sheet (ES0-199) the breakers are being set.
The guidelines state specifically that if a breaker cannot be set at the value indicated on the S&L MCC Setting Sheet, then the OAD Engineer shall submit a MCC Change Request form via CECO FCR procedure QCP 3-2.
CECO OAl, in conjunction with CECO Q.A. (Q. A. Sor aillance Report 'lo.82-210) reinspected all safety related MCC's to assure that the field settings are in accordance with the MCC Setting Sheet and MCC Change Requests, as appropriate.
l i
I
, Action Taken ~to Prevent Recurrence:
The revised DAD ECTP's and data forms will be used to set all future K/M or GE 480V breakers during' the construction phase of LSCS.
The LSCS Maintenance Department has also issued breaker setting guidelines, which are consistent with the OAD guidelines, to be used to set breakers that are under their-responsibility.
Date of Full Compliance:
Full compliance has been achieved.
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. Apparent Item o f Noncompliance (50-373/82-ll-03a, b & c) 2.
10 CFR 50, Appendix B, Criterion XVI states, in part, " Measures shall be established to assure that conditions adverse to quality, such as....de ficiencies, deviations....and nonconfor-mances are promptly identified and corrected."
Commonwealth Edison Company Topical Report CE-1-A, Revision 15, Section 16 states, in part, " A corrective action system will be used to assure that such items as.... deficiencies, deviations...
and nonconformances which are adverse to quality and might affect the safe operation of a nuclear generating station are promptly identified and corrected."
Contrary to the above, the following instances of f ailure to promptly identify and correct deficiencies, deviations or nonconformances were identified:
a.
Measures were not established to assue that the use of unapproved MCC breaker settings was promptly identified and corrected.
This is exemplified by the continued use of 3pproved MCC breaker settings pertaining to MCC 143-1.
ao nonconformance report had been initiated to identify and control this nonconforming condition and the licensee had not submitted data pertaining to these settings to Sargent and Lundy for approval.
b.
Measures were not established'to assure that deviations from MCC nameplate data requirements were promptly identified and corrected.
This is exemplified by the three incorrect namenlates installed on MCC 135X-1 and the one incorrect nameplate installed on MCC 143-1.
c.
Measures were not established to assure that deviations from DC Distribution Panel breaker requirements were promptly identified and corrected.
This is exemplified by the 60 amp breaker installed in lieu of the required 15 amp breaker in position 20 on DC Distribution Panel ll2Y.
Response
Corrective Action:
a)
CECO issued NCR #585 which s tated that a MCC Setting Sheet (ES0-199) has not been issued for the HPCS MCC 143-1 even though the breakers have been put in-service by CECO OAD.
Engineering issued a MCC Setting Sheet (ES0-199) for the HPCS MCC 143-1 on 4/16/82 and NCR #585 has been closed.
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. b)
The MCC compartment nameplates were verified to be in conformance with the MCC Setting Sheets during the rein-spection performed by CECO OAD and CECO Q. A. Indicated in Item 50-373/82-11-01 above.
New nameplates were installed as required.
c)
A 15 amp breaker has been installed in position 20 o f DC Distribution Panel ll2Y.
Action Taken to Prevent Recurrence:
a)
The breaker setting guidelines which have been incorporated into the LaSalle site ECTP's specifically state that the breakers are to be set in accordance with the applicable MCC Setting Sheet and the installed values are to be recorded on the appropriate data fo m.
A MCC Setting Sheet for the Unit 2 HPCS MCC (243-1) is being used.
b)
Paragraph 3 of the breaker setting guidelines specifically states that the OAD Engineer shall verify that the MCC compartment door nameplate is in accordance with the MCC Setting Sheet.
c)
All o f the safety-related DC Distribution Panels (lllX, 112X, Illy, ll2Y) were inspected during this NRC Inspec-tion.
The only breaker found to be the incorrect size was
- 20 on panel ll2Y.
The change to the breaker size was inadvertently missed when the breaker was put into service (Rev. N to IE-1-4442A A dated 2/22/80).
There is no indication that this was not a unique occurrence.
On 10/03/80, HPF issued WIl03, HPFCo Responsibilities for performing Wiring Revisions, so better control Wiring Diagram revisions.
WI 103 requires that wiring diagram revisions are logged in when received and the log entry signed of f when the revision is incorporated.
Da te o f Full Compliance:
Full Compliance has been achieved.
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- .=.. Appa ren t Item o f Noncompliance (50-373/82-11-06) 3.
10 CFR 50, Appendix B, Criterion X s tates, in part, " A program for inspection o f activities af fecting quality shall be estab-11shed and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and orawings.for accomplishing the activity.
Commonweath Edison Company Topical Report No. CE-1-A, Revision 15, Section 10 s tates, in part, " Quality assurance inspection
....will be conducted....during construction....to verify conformance to applicable drawings, instructions, and procedures as necessary to verify quality."
Contrary to the above, the Q.C. inspections o f instrument sensing line on February 17 and October 7, 1981, failed to verify conformance to the " Fabrication Requirement" on Morrison isometric drawings which states, in part, " Slope shall be 1/2" per foot (min)...." and Amendment 4 to Sargent and Lundy Specification J-2530 which states, in part, "Under no circum-stances should a slope o f less than 1/4" per foot of run be applied without approval from Consulting Engineers."
As a result, three instances were observed in which the violation o f
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the instrument sensing line slope requirements were not identified.
Response
Corrective Action:
The bent area in instrument line INB088-3/4" near item 5 of the bill of materials on isometric drawing NB-33 has been moved so no trap exists.
Ten (10) additional instrument lines in Unit 1 were inspected and determined to meet the applicable requirements of an average slope of 1/4" per foot over the entire run with no level areas, rises, or traps.
Clarification o f Specification J-2530, Article 403.4, which serves as a guide to maintain continuous slpe along the entire run, is included in a Sargent' and Lundy letter dated February 26, 1982.
Action Taken to Prevent Recurrence:
The fabrication requirements note on Morrison Construction Company's instrument isometric drawings not yet issued to the field in Unit II, have been changed to more clearly reflect the slope requirements.
Date o f Full Compliance:
Full Compliance has been achieved as o f April 1,1982.
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