ML20076K715

Responds to NRC Re Violations Noted in IE Insp Repts 50-373/82-54 & 50-374/82-22.Corrective Actions:Cable Pan Cleanliness Surveillance Frequency Increased

ML20076K715
Person / Time
Site:	LaSalle
Issue date:	07/06/1983
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20076K714	List: ML20076K715 ML20076K718 ML20076K722 ML20076K726 ML20076K730
References
6892N, NUDOCS 8307180063
Download: ML20076K715 (6)

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') Commonwealth

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(' x- Address Reply to: Post Office Box 767 Chicago. tilinois 60690 July 6, 1983 Mr. James G. Keppler, Regional Administrator

- Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

LaSalle County Station Units 1 and 2 NRC Inspection Report Nos. 50-373/82-54 and 50-374/82-22/ Supplementary Information NRC Docket Nos. 50-373 and 50-374 References (a): R. L. Spessard letter to Cordell Reed dated April 28, 1983.

(b): D. L. Farrar letter to J. G. Keppler dated May 27, 1983. ,

(c): R. L. Spessard letter to Cordell Reed dated June 10, 1983.

(d): D. L. Farrar letter to J. G. Keppler dated June 10, 1983.

(e): D. L. Farrar letter to J. G. Keppler dated June 24, 1983.

(f): D. L. Farrar letter to J. G. Keppler dated June 22, 1983, " Response to Inspection Report 50-373/83-16 and 50-374/83-14."

Dear Mr. Keppler:

References (a), (b), (c), (d), and (e) relate to various corre-spondence regarding the subject inspection report, the noncompliances and response thereto, and supplemental information requested by the NRC.

Enclosed please find:

1. A revised response to Item of Noncompliance 2. The original was provided in Reference (b). This revised response clarifies the Corrective Action Taken to Prevent Recurrence section of our response on this item and revises the Date When Full Compliance Will Be Achieved. .This revised response is consistent with Reference (f).

JUL 7 1983 8307180063 830711 i

PDR ADOCK 05000373 O PDR

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J. G. Keppler July 6, 1983

2. A copy of Reference (e). Discussions on June 30, 1983, between C. W. Schroeder of Commonwealth Edison and Messrs. Maura and Ramsey of your staff indicated that you may not have received all of the enclosures which are listed in Attachment 1 of Reference (e).

Commonwealth Edison Company still expects to provide you with the Unit 1 cable density information by August 5, 1982, as previously indicated in Reference (d). Messrs. Maura and Ramsey also indicated on June 30, 1983 that additional input was desired on the coefficient of expansion for the gypsum material. It is our intention to also provide that input to you by August 5, 1983.

To the best of my knowledge and belief the statements contained herein and in the attachments are true and correct. In some respects these statements are not based on my personal knowledge but upon infor-mation furnished by other Commonwealth Edison and contractor employees.

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

If there are any further questions in this matter, please contact this office.

Very t ly your

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D. L. Farrar g Director of Nuclear Licensing CWS/1m cc: NRC Resident Inspector - LSCS 1/0 Mr. F. Maura / Eyes only - Region III 6892N i

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1 REVISED RESPONSE- I INSPECTION REPORT Nos. 50-373/82-54 and 50-374/82-22 Item of Noncompliance

2. 10 CFR 51, 0 Appendix B, Criterion II requires,.in part, that activi-ties affecting quality be accomplished under suitable controlled conditions, such as adequate cleanliness. -The Quality Assurance c Program, Quality Requirement QR 2.0 contains a Commonwealth Edison Company commitment 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 and N45.2.3-1973, respectively.

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 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."

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.

Response

Discussion Commonwealth Edison Company has reviewed this~ Item of Noncompliance. Although we are not officially protesting the classifi-cation of this item as a noncompliance, we feel that the following points must be made.

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. Specifically, the Introduction to 10 CFR, Appendix B, states, "As used in this appendix, " quality assurance", comprises all those planned and systematic actions necessary to provide adeauste confidence l that a structure, system, or component will perform satisfactorily in service..." (emphasis added). JAdditionally, Criteria II states, "The quality' assurance program shall provide control over activities affecting-

-tha quality.of the identified structures, systems, and components, to an

extent consistent with their importance to safety..." (emphasis added).

I L ~ CECO does not'believe that few minor cleanliness items

!, ' identified-during inspectionLof firestops represent an inadequate-i housekeeping inspection program.. This is reinforced because a review of l

.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 l-

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(Cont'd) field inspection. It was at the April 14, 1983 exit meeting that CECO management was first informed that the NRC considered that the current cable pan cleanliness program was inadequate. We objected to the item of

-noncompliance at theexit 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 brought 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 Avoid Further Noncompliance Commonwealth Edison Company /Howard P. Foley Company have increased.the cable pan cleanliness surveillance frequency-in Unit 2.

' Additionally, Unit 2 Area Walkdown activities include cable pan cleanliness as one of the inspection aspects. . Station Maintenance Department operating procedures are being reviewed to identify any  !

additional actions necessary to ensure Unit 1 and future Unit 2 cable-pan cleanliness. Lastly, the Site Project Construction Superintendent ,

. issued a. letter (DSL #536) to Commonwealth Edison and contractor employees regarding plant cleanliness.

Date When Full Complicace~Will Be Achieved The Units 1 and'2 cable pan inspection / cleaning operations are on-going. Unit'2 area walkdowns and turnovers will be complete prior to Unit 2 fuel load. Station Maintenance Department programmatic reviews and corrective actions will be complete by September 17, 1983.

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• NORMAN L. SCOTT PE.SE

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• g ' ARMAND H. GUSTMERHO PE.SE i . LESLIE D. MART 95 PE.SE GEHALD E. GCETTSCHE FE. OE THE CONSULTlNG 1701 E. Lake Avenue '

• Glenv:ew,ENGlNEERS GROUP iNC.

Illinois (Chicago Suburb) G0025 3i2 729-004C March Ill,1980

~ UNITED STATES GYPSUM COMPANY 1000 East Northwest Highway Des Plaines, IL G001G Gentlemen:

Attached is a report, "CONeRETE FLOOR FIRE-STOP TEST OF NONQUALIFIED IEEE 303 CABLE PENETRATIONS PROTECTED WITH FIRECODE CT GYPSU THERMAFIBER CT FELT", by D. L. Orals and P. S. Quigg. The report describes a fire test of a floor assembly which incorporated several cable penetrations.

Power and centrol cables used in the assembly did not conform to the requirements of IEEE 303 and had cable coverings which were considered to be highly combus-tible. ,

Protection in eight of the openings consisted of a layer of THERMAFIBER CT FELT at the bottom of the opening covered with FIRECODE CT GYPSUM. The other eight openings were evaluated for retrofit installations, assuming the original protection to be ineffective.

For the retrofit protection, no protective material was placed around the cables within the depth of the floor slab. Instead, FIRECODE CT GYPSUM was poured around the cables on removable forms at floor level and ex-tending 5 or 8 in, above floor level.

No flaming of the cable coverings occurred above the unexposed surface of the opening protections throughout the 3-hr test. Of the sixty thermocouples placed on cable coverings at the tcp of the FIRECODE CT GYPSUM, 55 recorded tempera-tures below 700 F throughout the test.

Following the fire test, the specimen withstood a hose stream test.

The test was conducted on January 9,1980 at the United States Gypsum Company Research Center. Mr. Kenneth Kowall, Structural Engineer with The Consulting Engineers Group, Inc., witnessed the test.

A month before the test some of the cables in the assembly were removed and some were installed to determine if the FIRECODE CT GYPSUM could be readily removed and replaced if needed. I wit-nessed that operation and noted that no problems were encountered. Mr. Kowall G

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TH3 CONSUL. TING CNftfNCCRU GROUP m c.

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. was present when the specimen was disassembled. I edited the report and.com-pared the information presented with the recorded data. It is my opinion that the report presents the data accurately.

Respectfully submitted,

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Armand H. Gustaferro

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