ML20063C769

Forwards Response to NRC Re Violations Noted in IE Insp Rept 50-373/82-28.Corrective Actions:Paint Cans, Rags,Cigarette Butts & Tape Removed on 820511 & Contractors Informed of Housekeeping Rules

ML20063C769
Person / Time
Site:	LaSalle
Issue date:	08/09/1982
From:	Delgeorge L COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20063C760	List: ML20063C769
References
4696N, NUDOCS 8208270368
Download: ML20063C769 (4)

Text

s' l Commonw:cith Edison g

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{ N)~J Address One First National Plaza. Chicago, Ilhnois Reply to: Post Office Box 767

/ Chicago, liknois 60690 Augus t 9, 1982 Mr. James G. Keppler, Regional Administrator Directorate o f 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. 50-373/82-28 NRC Docket No. 50-373

Reference (a)

R. L. Spessard letter to Cordell l Reed da ted July 1, 1982.

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Dear Mr. Keppler:

This letter is in response to the inspection conducted by Messrs. W. G. Guldemand and R. D. Walker on Ma y 3-28, 1982 o f activi-ties at LaSalle County Station Unit 1. Reference (a) indicated that certain activities appeared to be in noncompliance with NRC require-ments. On July 23, 1982, Mr. R. D. Walker granted a 10-day extension for the response to Reference (a), until August 10, 1982. The Cownoneca) th Edison Company response to the Notice of Violation is provided in the enclosurc.

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 and contractor

. employees. Such information has been reviewed in accordance with I Company practice and I believe it to be reliable.

If you have further questions on this matter, please direct them to this office.

Very truly yours,

,b.

f L. O. De George Director of toclear Licensing im I

Attachment cc: NRC Resident Inspector SUBSCRIBED and SWORN,to 4/meuthis befo;C6 h N@M day l o f/L , 1982

- .M E6d AUG 10 1982 j Rotary PUblic 8208270368 3 4696N PDR ADOCK 0 PDR G

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.1 ATTACHMENT RESPONSE TO INSPECTION REPORT 50-373/82-28 Item of Noncompliance As a result of the inspection conducted on May 3-28, 1982, and in accordance with the NRC Enforcement Policy , 45 FR 66754 (March 9, 1982), the following violation was identified:

10 CFR 50, Appendix B, Criterion II, requires in part, tha t activi-ties affecting quality be accomplished under suitable controlled conditions, such as adequate cleanliness. 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 QR2.0, contains a Commonwealth Edison Company commitment to the regulatory positions of Regulatory Guide 1.38, Revision 2, and Regulatory 1.39, Revision 2, endorses the requirements o f ANSI N45.2.2-1972 and N45.2.3-1973, respectively. ANSI N4 5. 2.2-19 72, Section 6.2, states, in part, that,

" Cleanliness and good housekeeping practices shall be enforced at all times in the storage areas. The storage areas shall be cleaned as required to to avoid the accumulation of trash, discarded packaging materials and other detrimental soll: The use or storage of food, drinks.....in any storage area shall not be permitted..... Periodic inspections shall be performed to assure that storage areas are being maintained." 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 of Section 6 o f this standard." ANSI N4 5.2.3-1973 requires in part that control of all tools, equipment, materials and supplies be maintained to prevent the inadvertent inclusion of deleterious materials or objects in critical systems.

Technical Specification 3/4.7.6 " Fire Rated Assemblies", requires in part, " All fire rated assemblies (walls, floor / ceilings, cable tray enclosures and other fire barriers) separating safety related fire areas or separating portions of redundant systems important to safe shutdown within a fire area, and all sealing devices in fire rated assembly penetrations (fire doors, fire windows, fire dampers, cable and piping penetration seals and ventilation seals) shall be OPERABLE."

Contrary to the above requirements, on May 11, 1982 the following were observed:

1. Two open cans of paint and paint soaked rags were left unattended for an extended period of time behind the Unit 2 control boards which are loacted in the common Unit 1/ Unit 2 Control Room.

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2. Numerous cigarette butts were found in the Unit 2 control boards, which are located in the common Unit 1/ Unit 2 control room, an area posted as "No Smoking".

3. Two fire doors (296, 298) were observed to have been rendered inoperable by taping their latches open.

Corrective Action and Results Achieved In response to Item 1, 2, and 3 referenced above, the paint cans and paint soaked rags along with the cigarette butts and tape on the door latches were removed and disposed of properly on May 11, 1982. Once the areas af fected were cleaned, a complete inspection of the affected areas was conducted by the Station Fire Marbsal to insure requirements stated above were adhered to. As a result of the inspection, it was determined that further administrative controls would have to be implemented.

Corrective Action to Avoid Further Noncompliance For Item #1 above:

To ensure that adequate administrative control is maintained over contractors' materials, a meeting was held with cognizant contractors, the Station Construction Fire Marshal and the Station Fire Marshal. The contractors were informed that housekeeping rules will be adhered to by all personnel on site.

For Item #2 above:

To make No Smoking rules more evident to personnel, additional new "No Smoking" signs were installed in the Control Panel area. Also, more frequent inspections are being conducted by the Fire Marshal in addition to housekeeping surveillances already being performed in these areas. Control Room personnel have also been instructed to periodically inspect the above stated area for deleterious material.

The Station Construction Fire Marshal was also notified of this occurrence.

Fore Item #3 above:

The personnel involved in the taping of door latches were notified not to tape latches. In accordance with Technical Specification 3.7.6, if fire doors are to be rendered inoperable, a fire watch patrol must be implemented for the affected door. This occurrence prompted a letter dated July 9, 1982. In part, it s tated, "since the fire doors are considered fire barriers and are included in the Tech Spec it was necessary to avoid taping latches or blocking open fire doors." The letter was distributed to all Management Department Heads in order to inform their personnel.

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Daily and weekly fire door checks are being performed in accordance with Technical Specification 4.7.6.2. Any deficiencies found are rioted and brought to the attention of the Station Fire Marshal.

Date of Full Compliance For all items stated above, full compliance has been achieved.

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