ML20076K246

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Responds to NRC Re Violations Noted in IE Insp Rept 50-374/83-11.Corrective Actions:Nonconformance Rept 626 Initiated to Record & Resolve Improper Cable Segregation & Drawing for Internal Panel Wiring Will Be Developed
ML20076K246
Person / Time
Site: LaSalle Constellation icon.png
Issue date: 05/23/1983
From: Farrar D
COMMONWEALTH EDISON CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20076K242 List:
References
6588N, NUDOCS 8307080334
Download: ML20076K246 (3)


Text

,

Commonw:dth Edison

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One First National Plaza. Chicago. Ilknois

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O-Address Reply to: Post Office Box 767

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Chicago, tiliriois 60690 May 23, 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 Unit 2 Response to Inspection Report No. 50-374/83-11 NRC Docket No. 50-374 Reference (a):

W.

S. Little letter to Cordell Reed dated April 26, 1983.

Dear Mr. Keppler:

This letter is in response to the inspection conducted by Messrs. K. R. Naidu and I. Ahlmed on March 22-25, 29, and 30, 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.

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 upon my personal knowledge but upon in fo rma tion'(surnished by other Commonwealth Edison employees.

Such information hab'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 them to this office.

Very uly yougs t h

D. L.

Farrar l

Director of Nuclear Licensing CWS/1m Attachment cc:

NRC Resident Inspector - LSCS gg33 8307080334 830630 6588N PDR ADOCK 05000374 G

PDR

ATTACHMENT A Response to Inspection Report No. 50-374/83-11 Item of Noncompliance 1.

10 CFR 50, Appendix B, Criterion III, states, in part, " Measures shall be established to assure that applicable regulatory requirements and the design basis, as specified in the license application...are correctly translated into specifications, drawings, procedures and instructions."

Commonwealth Edison Company Quality Assurance Program CE-1-A Topical Report, Revision 9, Section 3-1, states, in part, "... designs and material will conform to... standards, regulatory requirements, SAR commitments and appropriate quality standards as applicable.

Contrary to the above, the requirement on page 7.2-29 of the LaSalle County Station Final Safety Analysis Report which states, in part, "the eight trip channels are physically separated and electrically isolated to meet channel independence" has not been translated into procedures, instructions and drawings to maintain cable separation in junction boxes.

Note N1 on cable segregation chart lE-0-3333 shows the minimum vertical and horizontal segregation codes; however, junction boxes.were not included in the raceways.

Consequently, our inspectors observed in the junction box adjacent to the Main Steam Isolation Valve (MSIV) 2821 F022A, cables with different segregation codes were intermingled without separation.

Furthermore, there was no Deficiency Report (DR) outstanding in the MSIV turnover packages documenting that the installation would be corrected.

Response

Corrective Action Taken and Results Achieved Commonwealth Edison Company initiated Non-Conformance Report No. 626 to record and resolve the improper cable segregation.

Deficiency Reports PT-MS-2108-051 thru 90 were written to track installation status of individual environmentally qualified seal assemblies for the eight (8) Main Steam Isolation Valves (MSIVs).

After installa-tion, the MSIV junction boxes will be eliminated and the proper cable separation will be maintained per the Final Safety Analysis Report (FSAR) and Sargent & Lundy design drawings.

Additionally, H.P. Foley Company completed special surveillances of the Unit 2 Main Control Room and Auxiliary Electric Equipment Room panels.

These surveillances encompassed cable identification and violations of fire barrier and cable separation criteria.

There were no adverse findings.

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. Project Construction Department /H.P. Foley Company engineers completed a comprehensive review to identify any further unrecorded temporary installation.

The necessary Deficiency Reports have been initiated.

Lastly, Project Construction Department requested Sargent & Lundy Engineers to participate in a Unit 2 cable separation field audit.

This audit will be similar to that performed on Unit 1 prior to fuel load.

Emphasis will be put on those areas of concern identified in this inspection report.

Corrective Action Taken to Avoid Recurrence An Addendum to H.P. Foley procedure WI-300, 302, 400 and 500 has been written and approved to provide guidance to installation / quality control personnel regarding cable segregation requirements.

A training session on this Addendum was held on April 14, 1983.

Sargent & Lundy Engineers will review Drawing lE-0-3333 to clearly state the applicability to panels and S&L numbered junction boxes.

Additionally, Sargent & Lundy Engineers will develop a drawing similar to 1E-0-3333 for internal panel wiring.

The above Addendums will be re-reviewed against the revised drawings and necessary procedural adjustments made and training conducted.

Date of Full Compliance The MSIV junction boxes eliminations and proper cable separation will be completed prior to July 1, 1983.

The cable separation field audit will be completed prior to August 1, 1983.

Sargent & Lundy Engineers drawing revisions and any further procedural revisions will be completed prior to June 15, 1983.

6588N i