ML20062N214
| ML20062N214 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 10/28/1981 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20062N212 | List: |
| References | |
| NUDOCS 8112180449 | |
| Download: ML20062N214 (5) | |
Text
_-_.
/,
,N Commonwealth Edison.
) one First National Plaza. Chicago, Ithnoes
\\
] Address Reply to: Post Office Box 767 d
\\
,/ Chicago, Illinois 60690 October 28, 1981 i
Mr. James G.
Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Com'isu ion 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
LaSalle County Station Units 1 and 2 Response to NRC Inspection Report No. 50-373/81-30 NRC Docket No. 50-373 Reference (a):
R.
L.
Spessard letter to Cordell Reed dated October 2, 1981.
Dear Mr. Keppler:
1 The following is in response to the inspection conducted by l
Messrs. R.
D. Walker, S.
E.
- Shepley, N.
J.
Chrissotimos, S. DuPont and P. Byron on June 29 through August 28, 1981, of activities on LaSalle County Station.
Reference (a) indicated that certain acti-vities appeared to be in noncompliance with NRC requirements.
The l
i Commonwealth Edison Company response to Appendix "A" of Reference (a) is enclosed.
Appendix "B" did not require a response and as a result, none is provided.
To the best of my knowledge and belief, the statements i
l contained herein and in the enclosure are true and correct.
In some respects these statements are not based upon my personal knowledge but upon information furnished by other Commonealth Edison and con-tractor employees.
Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
ZEol 8112180449 811209 NOV 3 1930' PDR ADOCK 05000373 O
J.
G.
Keppler October 28, 1981 If you have any questions in this regara, please direct them to this office.
Very truly yours, L. O. DelGeorge Director of Nuclear Licensing Enclosure cc:
NRC Resident Inspector - LSCS 1m SU8 SCRIBED AND SWORN to befora me this 80 day of dh 1981.
Odd.0h Notary Public 2758N
8 ENCLOSURE RESPONSE TO NOTICE OF VIOLATION The response to the items of apparent noncompliance identi-fled in Appendix A of Reference (a) is provided in the following paragraphs.
ITEM 1 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 ioentified and performed in accordance w3*h written test procedures which incorporate the requirer..ents and accep-tance limits contained in applicable design documents.
The Q.A. Manual, Quality Requirement 11.0, Section 11.2 states that construction testing consists of on-site 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.
Contrary to the above, the inspector determined that pressure proof testing of the Secondary Containment was conoucted during the weekend of July 18-19, 1981, without an approved procedure as required.
The failure to have and follow procedures as required resulted in damage to the Secondary Containment roof structure.
This is a Severity Level IV violation (Supplement II).
Response
Correction Action Taken and Results Achieved A construction test procedure for the Secondary Containment Leak Rate Test will be written to meet the requirement of Q.P. 11-1.
Specific measures will be included to prevent overpressurization and damage to the Reactor Building composition roofing and insulation.
Corrective Acion Taken to Avoid Further Non-Compliance All further pressure proof testing will be conducted in accordance with written procedures.
Date of Full Compliance:
The Secondary Containment Leak Rate Test construction procedure will be completed prior to the next test which is presently scheduled for November 7, 1981.
i i
- ITEM 2 10 CFR 50, Appendix B, Criterion XIII requires, in part, that measures be established to control the storage and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration.
The Quality Assurance Program, Quality Requirement Q.R.
2.0, contains a Commonwealth Edison Company commitment to the regulatory positions of the Regulatory Guide 1.38, Revision 2, and Regulatory Guide 1.39, Revision 2.
The regulatory positions of Regulatory Guides 1.38, Revision 2 2
and 1.39, Revision 2, endorses the requirements of ANSI N45.2.2-1972 and N45.2.3-1973 respectively.
ANSI N45.2.2-1972, Section 6.2, states, in part, that ".
. good housekeeping practices shall be enforced at all times in the storage areas."
Section 6,5 states, in part, that, " Items released from storage and placed in their final locations within the power plant, shall be.
. cared for in accordance with the requirements o f Section 6 o f this standard."
ANSI N45.2.3-1973 requires in part that control of all tools, equipment, materials and supplies be maintained to prevent the inadvertant inclusions of deleterious materials or objects in critical systems.
Commonwealth Edison Company, LaSalle Station, Housekeeping Procedure, Project Procedure 18-2, Part 6.3.7 states:
" Equipment and systems in areas where construction activities are performed shall be properly protected."
Contrary to the above, the licensee did not adequately protect equipment as evidenced by the following items noted during plant tours:
a.
A welding power supply (energized) setting in an ESF divisional open cable tray, noted on July 13, 1981.
b.
Men welding and grinding above and in the vicinity i
of ESF divisional open cable trays without protection for the cables, noted on July 13, 1981, and on July 29, 1981.
This is a Severity Level VI violation (Supplement II).
Response
Corrective Action Taken and Results Achieved The specific items mentioned in the above non-compliance have been corrected, or in the case of certain scaf folding, determined not to be detrimental to the cable trays involved.
No damage to the associated equipment, as a result of the housekeeping problems was noted.
2758N
, Corrective Action Taken to Avoid Further tJon-Compliance Project Construction personnel doing housekeeping surveillance will be reinstructed in the following areas:
1.
Impartance of protecting cable from the effects of welding, cutting and grinding.
2.
Cable tray and electrical equipment cleanliness.
3.
Damage potential to cable trays.
In addition, housekeeping inspections of the above areas will be periodically documented on Housekeeping Inspection Form AB 12.1.
Date of Full Compliance Compliance with be achieved by November 02, 1981.
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1 2758N i
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