ML20062N052

Responds to NRC Violations Noted in IE Insp Repts 50-454/81-16 & 50-455/81-12.Corrective Actions: Program Implemented to Assure That Noncompliances Are Promptly Corrected

ML20062N052
Person / Time
Site:	Byron
Issue date:	11/23/1981
From:	Delgeorge L COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20062N005	List: ML20062N052
References
NUDOCS 8112180358
Download: ML20062N052 (4)

Text

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- V N Commonwealth Edison

[ ^ ) Ora First Nationii Plaza, Chicago, libnois

( 7 ~) Address Reply to: Post Office Box 767

\ ,/ Chicago, Illinois 60690 November 23, 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:

Byron Station Units 1 and 2 IE Inspection Report Nos. 50-154/81-16 a nd 50-455/81-12 Reference (a): October 23, 1981 letter from C. E. Norelius to C. Reed

Dear Mr. Keppler:

Reference (a) contained the results o f an inspection conducted by Mr. R. S. Love on September 22-25, 1981 at Byron Generating Station. During that inspection it was determined that certain activities were not in compliance with NRC requirements.

Attachment A to this letter coritains Commonwealth Edison's response to the Notice of Violation which was appended to reference (a).

To the best of my knowledge and belief, the statements contained in Attachment A are true and correct. In some respects these statements are not based upon my personal knowledge but upon information furnished by other Commonwealth Edison employees and contractors. Such informaticn has been reviewed in accordance with Company practice and I believe it to be reliable.

Please address questions regarding this matter to this office.

Very truly yours, L.O. DelGeorge Director o f Nuclear Licensing Attachment SUBSCRIBED and SWORN o day of h ,9 1981 before me this c/

Os.La. OA Notary Pu611c 2931N ,

811218o358 811210._

DR ADOCK c500o NOV 2 7 1981'

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Attachment A Response to Notice of Violation Violation 10 CFR 50, Appendix B, Criterion XVI, states in part,

" Measures shall be established to assure that conditions adverse to quality ... are promptly identified and corrected."

Commonwealth Edison Company Topical Report No. CE l- A, Revision 9, Section 16, states in part, " A corrective action system will be used to assure that such items... which are adverse to quality end might af fect the safe operation of a nuclear generating station are promptly identified and corrected."

Contrary to the above, the licensee had not taken the necessary actions to assure that an identified item of noncompliance, concerning the separation criteria between safety-related and non-safety-related cables, was promptly corrected. This is exemplified by the f act that the appropriate Hatfield procedure addressed in the licensee's correspondence, was not being implemented as of September 24, 1981. The licensee committed to have the procedure implemented by June 1, 1981.

(Reference CECO. letter dated May 7, 1981, from Cordell Reed to James G. Kepple r. )

Corrective Action and Results Achieved As stated in the details of the NRC inspection report, Commonwealth Edison issued a letter to Hatfield on September 24, 1981, directing them to implement Procedure Number 10, Class lE Cable Installation, Revision 10, Issue 2, dated June 8, 1981 with S&L comments immediately.

In reference to the commitment of having the procedure implemented by June 1, 1981, the following sequence of events transpired:

March 24, 1981: Commonwealth Edison transmitted a letter to Hatfield stating that good construction practices are not to bundle Safety Related and Non-Safety Related cables together. It was further stated that if there were instances in which safety related and non-safety related cables were in contact with each other, that Hatfield should notify Commonwealth Edison.

May 5, 1981: Commonwealth Edison transmitted a letter to Hatfield requiring them to revise their procedure (s) to incorporate the requirements of Commonwealth Edison's letter dated March 24, 1981 as expeditiously as possible.

June 8, 1981: Hatfield transmitted their Procedure No. 10, Class 1E Calbe Installation, Revison 10, Issue 2, dated June 8, 1981 to Commonwealth Edison f or review and approval. The procedure had been revised to incorporate specific cable separation criterion for the inst 611ation and inspection of Class IE cables.

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l June 9, 1981: Commonwealth Edison's Project Construction Department received letter No. BY6521 from Commonwealth Edison Site Quality Assurance stating that Hatfield Procedure No.10, Revision 10, Issue 2, dated June 8, 1981 had been reviewed by CECO. Q A and by S&L and that " Interim" approval for use was granted. Final approval would be subject to further review by S&L.

June 10, 1981: Commonwealth Edison transmitted to Hatfield their Procecure No. 10, Revision 10, Issue 2, dated June 8,1981 with the intent that it would be immediately implemented. However, the wrong standard form letter was used to transmit the procedure to Hatfield. Consequently, instead of implementing the procedure, Hatfield intended to revise and resubmit the procedure for approval.

August 7, 1981: S&L transmitted to Commonwealth Edison Hatfield's Procedure No. 10, Revision 10, Issue 2, dated June 8, 1981 with their comments attached, indicating specific cable separation criteria to be followed. S&L indicated that the procedure should be revised as noted and resubmitted, however the contractor could proceed on making revisions as noted.

August 13, 1981: Commonwealth Edison t;ansmitted to Hatfield their Procedure No. 10, Revision 10, Issue 2, dated June 8, 1981 with the S&L procedure review report attached, indicating the specific cable separation criterion to be added to the procedure. The transmittal directed Hatfield to incorporate this criterion into the procedure and resubmit for review and approval.

September 24, 1981: As a result of discussions with Hatfield and tne NRC inspector, it was discovered that the wrong t'ransmittal form letter was used on June 10, 1981 and as a result Hatfield nevsr implemented their Procedure 10, Revision 10, Issue 2, dated June 8, 1981.

In view of the above sequence of events, although Commonwealth Edison failed to meet its commitment of having the procedure implemented by June 1, 1981, the failure to meet the commitment was an error caused by using an incorrect standard transmittal form.

The March 24, 1981 letter transmitted to Hatfield clearly indicates immediate action taken by Commonwealth Edison. This is exemplified by the fact that as a result of this letter all previous items of non-compliance identifying the bundling together of safety related and non-safety related cables were corrected and that Hatfield no longer bundled together safety related and non-safety related cables. Prior to June, 1981, no specific cable separation criterion in free air had been addressed.

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Hatfield has submitteo for review and approval their Procedure No. 10, Revision 11, which incorporates the S&L comments o f August 7, 1981 concerning the specific installation and inspection criterion to be used for cable separation. They are currently implementing Procedure No. 10 Revision 10, Issue 2 with these S&L cable separation criterion comments attached, per Commonwealth Edison's transmittal letter of September 24, 1981.

Corrective Action to Avoid Further Noncompliance A log has been established in the site construction office to facilitate tracking of commitments made to the NRC as a result of I&E Inspections. Use of this log will help detect errors such as the one which resulted in this noncompliance.

Date When Full Compliance Will Be Achieved Based on the new separation installation and inspection criterion in Hatfield's Procedure No. 10, we intend to have all o f the cable separation problems fer installed Unit 1, cable, identified by the end of March 1982 and to have corrective action completed for these items by the end of December 1982.

For Unit 2 we intend to have all the cable separation problems for installed cable identified by the end of June 1982 and to have the corrective action completed for these- items by the end of March 1983.

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