ML20076H130
| ML20076H130 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 05/27/1983 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20076H072 | List: |
| References | |
| 6590N, NUDOCS 8306160435 | |
| Download: ML20076H130 (8) | |
Text
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x Commonwealth Edison
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) one Firit Nitiornt Plaza. Chicago, Illino.s
- ( C Address Reply to: Post Office Box 767
-x Chicago, Illinois 60690 May 27, 1983 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 Units 1 and 2 Response to Inspection Report Nos.
50-373/82-54 and 50-374/82-22 NRC Docket Nos. 50-373 and 50-374 Reference (a):
R. L. Spessard letter to Cordell Reed dated April 28, 1983.
Dear Mr. Keppler:
This letter is in response to the inspection conducted by Messrs. C. Ramsey, R. Hasse, and J. Ulle on November 24, 26, and 29, December 1 and 14, 1982, and April 14, 1983, of activities at LaSalle County Station.
Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements.
The Commonwealth Edison Company response to the Notice of Violation is provided in the enclosure.
Your concerns regarding the fire endurance of firestops will be addressed in a later submittal.
l To the best of my knowledge and belief the statements contained l
herein and in the attachment are true and correct.
In some respects l
these statements are not based upon my personal knowledge but upon l
information furnished by other Commonwealth Edison employees.
Such i
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 l
them to this office.
Very ruly you B306160435 830610
_ _ _ f_
PDR ADDCK 05000373
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~ ~,
O PDR D. L.
Farrar Director of Nuclear Licensing CWS/1m Attachment 1
cc:
NRC Resident Inspector - LSCS JUN 11983 i
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ATTACHMENT Response to Inspection Report Nos.
50-373/82-54 and-50-374/82-22 Item of Noncompliance 1.
10 CFR 50, Appendix B, Crition V, requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and be accomplished in accordance with these instructions, procedures or drawings.
Contrary to.the above:
(a)
Nonconformance reports were not written for five installations with wrong collar sizes which had been identified by the Transco QC Manager and documented in " Report of Alleged Transco Quality Violations," dated October 22, 1981, as required by Transco Firestop Quality Assurance Procedure (FSQAP) 9.1 and 15.0.
(b)
The acceptance criteria listed in FSQAP 9.1, "Special Processes Firecode CT Gypsum," does not address mechanical integrity (cracking, shrinkage, etc.) or conformance to installation drawing details during. final inspection.
(c)
A procedure was not developed to control the mix proportion or density of the Firecode CT Gypsum as specified in the tests performed to qualify the material as a 3-hour fire barrier.
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Response
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Discussion The NRC Inspection Report should be clarified regarding applica-bility of the Commonwealth Edison Company Quality Assurance Program to construction installation of Firecode CT Gypsum ~ penetration seals.
As stated in the Final Safety Analysis Report (FSAR), Fire Protection System (includig cable penetration firestops) are Level II, non-safety related (10 CFR 50, Appendix B does not apply).
FSAR Questions / Responses 421.1 l
l and 421.2 further delineate the following.
l l
1.
Fire Protection Systems are" classified as non-safety related.
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2.
Quality requirements for fire protection systems and equipment, will be specified in the equipment and installation specifications.
This...
3.
The CECO Standard-Quality Articles for Non-Safety or Non-Code Related Equipment and Materials will be used to transmit the quality assurance requirements....
. 4.
CECO Company Corporate Quality Assurance Program will be applicable, as appropriate,.... (emphasis added).
5.
The normal on-site quality control applies during construction through systems turnover to the station operating. staff....
Normal on-site quality control does not commit Commonwealth Edison Company to apply all 18 criteria in 10 CFR 50, Appendix B.
The intent is to apply during the construction phase a quality program commensurate with that necessary for a non-safety related system with some importance to safety.
The quality. program applied to the installation of cable penetra-tion firestops essentially. complies with NRC Branch Technical Position Paper 9.5-1.
This document was utilized as the basis for review and approval of the subcontractor Transco Firestop Quality Program.
Given the above, any third party evaluation / review of the Transco Firestop Quality Program must be conducted against the original evaluation / review basis, not 10 CFR 50, Appendix B.
The below responses are consistant with the application of normal on-site quality control.
Corrective Actions Taken and Results Achieved OlA - Inadequate Procedure Transco Procedure FSQAP 9.1, Revision 3, in effect at the time of NRC Region III review, did specify acceptance criteria for fire seals.
In response to NRC concerns, U.S. Gypsum Company, Sargent &
Lundy Engineers, and Commonwealth Edison Company have identified additional specific quantitative inspection criteria to be used when judging the integrity of fire seals.
These criteria were incorporated into FSQAP 9.1 in January 1983.
These revised criteria were utilized during a reinspection of Unit 1 cable penetration firestops and during initial installation activities at Unit 2.
018 - Failure to Follow Procedures l
The installations in question totaled four penetrations rather than five as stated in the inspection report.
The penetrations involved are 1838 and 2141E in Unit 1, and 1764A and 1764B in Unit 2.
Transco NCR #7, Walsh Construction Company NCR #264, and CECO NCR #641 covering the four (4) listed in the October 22, 1981, report have been l
submitted to CECO Engineering.
The requested disposition is " accept i
as is".
01C - Failure To Develop Procedures Clarified mixing prccedures have been developed.
Input to these mixing procedures was received from the product manufacturer.
The product manufacturer is formally reviewing revised mixing procedures.
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l Corrective-Action-Taken to-Prevent-Recurrence OlA - Inadequate Procedure Transco's procedure FSQAP 9.1 has been revised to include the additional acceptance criteria.
The revised procedure was approved in March 1983.
Upon resolution of pending engineering questions, any necessary revised acceptance criteria will be implemented.
OlB
-Failure-to Follow Procedures Transco procedures FSQAP 9.0 and FSQAP 9.1 have been revised to clarify under what circumstances nonconformance reports are to be issued.
Procedure revisions were approved in March 1983.
OlC - Failure-to-Develop Procedures Transco procedure FSQAP 9.1 has been revised to include the clarified mixing procedures.
Upon resolution of pending engineering questions, any necessary revised mixing procedures will be implemented.
Date When Full-Compliance Will Be Achieved OiA - Inadequate Procedure A revised inspection procedure is currently in place.
As stated above, any necessary revisions will be implemented upon resolution of
.pending engineering questions.
018 - Failure to Follow Procedures A revised nonconformance procedure is currently in place.
OlC - Failure to Develop Procedures Clarified mixing procedures are currently in place.
The product manufacturer is formally reviewing the revised procedure.
This review will be completed prior to June 10, 1983.
Additionally, any necessary revisions will be implemented upon resolution of pending engineering questions.
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l Item of Noncompliance 2,
10 CFR 50, Appendix B, Criterion'II requires, in part, that activities
-affecting quality be accomplished under suitable controlled conditions, such as adequate cleanliness.. The: Quality. Assurance Program, Quality
- Requirement QR 2.0 contains a Commonwealth Edison Company commitment l
to the regulatory position of Regulatory Guides 1.38, Revision 2 and 1.39,- Revision 2, which endorse the requirements of ANSI N45.2.2-1972 L
and N45.2.3-1973,. respectively.
t ANSI N45.2.3-1973, Section 1.2, ' states in part, "The requirements of the standard are intended to assure that only proper materials, equipment, processes, and procedures are utilized in the maintenance i
of housekeeping during the construction of power plants and that the quality of items is not degraded as a. result of housekeeping practices and techniques during construction processing."
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Contrary to the above, a rag,. paper wrappers, a wooden tape measure and other miscellaneous: dirt was found at cable penetration R-406 on December 1, 1982.
Minor dirt and miscellaneous debris was also found in penetrations W-485F, W-565F, W565E, W581-E, R-153, R-154, R-210, and R-212.
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Response
Discussion Commonwealth Edison Company has' reviewed this Item of
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Noncompliance.
Although we are not officially. protesting the classifi-
. cation of this item as a noncompliance, we feel that the following points 1
must-be made.
Specifically, the Introduction to 10 CFR, Appendix B, states, "As 4
used in this appendix, " quality assurance", comprises-all those planned and systematic actions necessary to provide adeauate confidence that a structure, system, or component will perform satisfactoilly in service..."
(emphasis added).
Additionally, Criteria II states, "The quality t
assurance' program shall provide control over activities affecting the quality of the identified structures, systems, and components, to an extent consistent with their"importance to safety..." (emphasis added).
CECO does not believe that few minor cleanliness items identified 1
i during inspection of firestops represent an-inadequate. housekeeping P
inspection program.
This is reinforced because a review of our meeting /
inspection notes revealed that the few minor' cleanliness items were not expressed as a NRC concern until 4 1/2 months after the field inspection.
It was at the-April.14, 1983 exit meeting.that CECO management was first 4
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. informed that the NRC considered that the current cable pan cleanliness program was inadequate.
We objected to the item of noncompliance at the
.~.
. exit meeting and this response documents our objection.
The cable pan cleanliness inspection program conducted on Units 1 and 2 of the cable penetrations did provide adequate confidence that the system would perform satisfactorily in service.
Additionally, the program extent is consistant with its importance to safety.
If it were not,- it would seem reasonable that NRC concerns in this area would have been immediately braught to CECO management attention for necessary corrective action.
Corrective Action Taken-and Results Achieved The debris noted by the inspectors was removed.
Corrective Action Taken to-Prevent Recurrence Commonwealth Edison Company has in place a cable pan cleanliness program.
Date When Full-Compliance Will Be-Achieved Full compliance.has been achieved.
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Item-of Noncompliance
.3.
Technical Specification:3.7.6. requires that all fire rated assemblies separating safety related fire areas...and all? sealing devices in.fi're.
rated assembly' penetrations (cable and piping penetrations seals)...
shall be operable at all times.
With' one or more of the above required fire rated assemblies and/or sealing devices. inoperable, within one. hour either. establish a continuous. fire watch on at least
- one side of the affected ' assembly (s) and/or sealing device (s) or verify the ' OPERABILITY of fire detectors on at least one side of the inoperable assembly (s) an'd or sealing. device (s) and establish an hourly fire watch patrol.
Restore the inoperable fire rated assembly (s) and/or sealing device (s) to OPERABLE status within 7 days or, in lieu of any other report required by Specification 6.6.B, prepare and submit a Special Report to the Commission pursuant to Specification
-6.6.C within the next 30 days outlining the action taken, the cause of the inoperable fire rated assembly (s) and/or sealing device (s) and plans and schedule for restoring the fire rated assembly (s) and/or sealing device (s)-to OPERABLE status.
ContraryEto the above, on November 29, 1982, an NRC inspector identified ~four penetrations (R-213, R-148, R-155, and 485F) each having a breakthrough (penetration opening to add additional cabling)
.approximately one inch in diameter.
These breakthroughs had been made since the final inspection of fire stop penetrations required prior to initial fuel loading in April,'1982.
However, the-exact date the breakthroughs were made could not be determined.
As a result, it could not be established that the requirements for:
(a)
A continuous fire watch had been met within one hour; or (b)
The operability of fire detectors on at least one side of the affected fire rated assemblies had been verified and an hourly fire watch patrol initiated.
.In addition, the fire rated assemblies had not been repaired within seven days, or a special report submitted to the Commission pursuant to Specification 6.6.C.
Response
Corrective Action Taken and-Results Achieved After the December.14, 1982 exit meeting, it was verified that a fire watch existed in areas of the four breakthroughs and Deviation Report-1-1-82-367 was. issued.
The four breakthroughs were repaired by Project Construction.
Using Acceptance Criteria provided in H. K. Stolt's (SNED) letter, dated January 7, 1983, the LaSalle Technical Staff performed LST-83-04 to inspect the 32. locations, which included the four breakthrough repairs', identified by the NRC during the December 14, 1982 exit
-meeting.
The NRC was informed by a Special Report to Region III dated January 13, 1983.
.. Project Construction conducted a survey of Unit 1 and Unit 2 areas required for Unit 1 operation to identify and repair any addi-tional damaged firestops which were not being tracked in the repair control program.
This survey was completed on January 20, 1983.
Corrective Action Taken to Avoid Further Noncompliance The Site Electrical Contractor revised Work Instruction 400, Cable Pulling (Revision 12) on December 29, 1982 to provide more control over firestop breakthroughs.
Date When Full Compliance Will-Be Achieved Corrective Action was accomplished with the completion of the Project Construction survey on January 20, 1983.
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