ML20055G463
| ML20055G463 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 07/13/1990 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 9007230209 | |
| Download: ML20055G463 (3) | |
Text
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- Cammonimalth Edia
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,1400 Opus Place
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Downcrs Grove, Illinois 60515
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-July-13, 1990
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~ Mr'. A. ' Be r t Davis '
Regional Administrator U._ S.- Nuclear Regulatory Commission
' Region III
- 799 Roosevelt Road Glen Ellyn, IL 60137 s
Subject:
Braidwood Station Units 1 & 2
-Response to Inspection Report Nos. 50-456/90-008 and'50-457/90-008 NRC Docket Nos. 50-456 and 50-457
Reference:
(a)
H. J. Miller's Letter to Cordell Reed dated June 15, 1990
Dear Mr. Davis:
Reference (a) provided the results of the Maintenance Team Inspectiot.
conducted by Mr. H. A. Walker and others f rom April 16 though 20, and April 30 through May 4, 1990 at Braidwood Station.
Reference (a) indicated that certain activities appeared to be in violation of NRC requirements. The Commonwealth Edison Company response to the Notice of Violation is provided in the Enclosute.
'If you have any questions regarding this response, please direct them to-this office.
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Very truly yours,
/-
T. J.
'ovach Nuclear Licensing Manager cc: NRC Resident Inspector - Braidwood
'NRC Document Control Desk 1
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ENCLOSURE COMMONWEALTH EDISON COMPANY'S RESPONSE TO INSPECTION REPORT Nos. 456/90008 and 457/90008 VIOLATION:
10 CFR 50, Appendix B, Criterion V, as described in Topical Report CE-1A, Revision III, and as implemented by the Braidwood Quality Assurance Manual Section 5 requires that activities affecting quality be prescribed by documented lustructions, procedures, and drawings, and that those activities e accomplished in accordance with those instructions, procedures and urawings.
Procedure ENC-QE-42, " Environmental Qualification Documentation Preparation, Control, and Acceptance," Revision 6, requires that the environmental qualification documentation packages shall, as a minimum, include a qualification report with the specific station evaluation and be approved by the Corporate Nuclear Station Engineering Department / Project Engineering.
Contrary to tbe above:
On April 30, 1990, the inspector determined that the control cable to be attached to a hydraulic actuator control solenoid of main steam isolation valve 2MS001D did not have a specific station evaluation nor the approval of the corporate Nuclear Station Engineering Department / Project Engineering.
RESPONSE
Commonwealth Edison Company (Edison) acknowledges that the control cable being prepared for installation on the hydraulic actuator control solenoid of main steam isolation valve 2MS001D failed to have the proper evaluation as required by NSED/PSD procedure ENC-QE-42.
The unevaluated cable was discovered by Edison personnel during a station walkdown with HRC personnel in conjunction with the Maintenance Inspection. However, it should be noted that the cable was being prepared in the electrical maintenance shop and the solenoid had not been released for installation.
The solenoid was never installed in the plant with the unevaluated cable.
At stated in the inspection report, "The Licensee culckly determined that the cable had not been used elsewhere in a safety related function." Edison concurs with the NRC statement that this was "an isolated instance of personnel error caused by a failure to read and understand ENC-QE-42."
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Edison understnads that the inspection team reviewed station procedures
- relating to-the maintenance area and found them satisfactory. One of the-
. more significant strengths in the implementation of the maintenance program as stated in the cover letter for the inspection report was " personnel committed to compliance with procedures that are well written."
A review of this event has determined there was no negative impact on the public health and safety.
t CORRECTIVE' ACTION TAKEN AND RESULTS ACHIEVED:
Upon identification of the unevaluated cable, the work on the cable T
installation for the solenoid was stopped by the station's master electrician.
In order to ensure that the unevaluated cable received the proper evaluation before any further use of the cable for a safety related function, a discrepancy record for the cable was generated by the station's technical staff parts group. Cable that had been previously approved for use on the solenoid was obtained, verified to be acceptable and installed on the l
solenoid.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION:
This violation will be discussed with appropriate station personnel during a tailgate train!ng session emphasizing the importance of following procedure ENC-QE-42.
Also, as an added measure, to ensure cable received at Braidwood Station receives the proper technical evaluation before installation, the Commonwealth Edison Stores Inventory System Computer Program will be enhanced. This enhancement will provide a statement requiring that upon receipt a technical evaluation 'De performed for each cable stores item number received and stocked at Braidwood Station.
DATE OF FULL COMPLIANCE:
The tailgate training sessica is expected to be completoi. 3v August 1, 1990.
The computer program is expected to be enhanced by Sep?:ober 14. 1990.
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