ML20080M434

Responds to NRC Re Violations Noted in IE Insp Repts 50-456/83-08 & 50-457/83-08.Corrective Actions:Motor Control Ctr Cleaned,Injector Pump Covers Tightened & Mud Between Bottom of Accumulator Tanks & Support Skirt Removed

ML20080M434
Person / Time
Site:	Braidwood
Issue date:	09/22/1983
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20080M424	List: ML20080M434
References
7323N, NUDOCS 8310040162
Download: ML20080M434 (4)

Text

.

["' N Commonwealth Edison

[ ) One First National Plaza, Chicago, Illinois

\ T.? 7 Addrzss R; ply to: Post Office Box 767

\ j Chicago, Illinois 60690 September 22, 1983 Mr. James G. Keppler, Regional Administrator

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

Subject:

Braidwood Station Units 1 and 2 Response to IE Inspection Report Nos. 50-456/83-08 and 50-457/83-08 NRC Docket Nos. 50-456/457 Reference (a): R. C. Knop letter to Cordell Reed dated August 23, 1983

Dear Mr. Keppler:

Reference (a) provided the results of an inspection conducted by Mr. L. G. McGregor of your of fice during the period of June 16 through August 5, 1983, of activities at our Braidwood Station. During that inspection, certain activities appeared to be in noncompliance with NRC requirements. The Attachment to this letter provides the Commonwealth Edison Company response to the Notice of Violation as apronded to Reference (a).

To the best of ay knowledge and belief, the statements contained 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 employees. Such information has been reviewed in accordance with Company practice and I believe it to be reliable.

Please address any questions that you or your staff may

'have concerning this matter to this office.

Very truly yours,

^

Dennis L. Farrar Director of Nuclear Licensing Attachment cc: RIII Inspector - Braidwood 7323N G310040162 830929 10 PDR ADOCK 05000456 G

cJ y 7'3 JS3 PDR

ATTACHMENT Response to Notice of Violation VIOLATION-NO.'l

-10 CFR 50, Appendix B, Criterion XIII, states in part, " Measures shall be established to control the handling, storage, shipping, cleaning and preservation of material and equipment...to prevent damage or' deterioration."

'The CECO. QAM commits to comply with Regulatory Guide 1.39, Revision 2 which in turn endorses ANSI Standard N45.2.3-1973

" Housekeeping During the Construction Phase of Nuclear Power Plants".

ANSI N45.2.3 states in part, "The control of all tools, equipment, materials _and supplies that are used shall be maintained to prevent the inadvertent inclusion of deleterious material or objects in critical systems. Materials and equipment-shall be so positioned that it will not be damaged by

- construction activities. The use, location and deployment of construction. tools, supplies, and equipment shall be regulated to keep access and work areas clear and prevent conditions that will adversely af fect quality."

Contrary to the above, the licensee failed to protect Motor Control Center No. 233X 2AP14E, 480 volt located on elevation

- 401 near the elevator, auxiliary building Unit No. 1,-from dirt, dust, and foreign material.

?

In Unit 1, auxiliary building, the licensee failed to protect Emergency Diesel Generators 1DG0lKA and 10G0lKB and essential service water piping and used-this safety related equipment to support scaffolding and scaffolding planks.

Unit 1 accumulator tanks (1SIO4TA, ISIDATB, 1SIO4TC and 1SIO4TD) contain caked mud and dirt in the lower support skirt.

RESPONSE TO VIOLATION NO. 1 CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED, AND CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE MOTOR CONTROL CENTER

. Immediate corrective action.was taken by the Project

. Construction. Department to clean the Motor Control Center.

However, it should be. pointed out that Motor Control Center No.

1-

- 233X, 2AP14E is non safety-related and is not energized.

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In order to assure that safety-related equipment is being maintained, and to preclude damage and deterioration, Project Construction Site Procedure BE-310, Revision 0 dated March 15, 1983-will~ continue to be implemented to assure the preservation of electrical. equipment.

' EMERGENCY DIESEL GENERATORS It is our normal practice not to use equipment to support scaffolding. However, in order to gain access to the area above the Diesel Generators, it was necessary to build scaffolding over the diesels with portions of the Diesel-Generators and ESW piping used to support the scaffolding. In our judgement, the support of the^ scaffolding off this equipment.has not been detrimental, and need not be removed at this time. The scaffolding will be removed upon completion of work in the area.

Due to the high level of construction activity in the Diesel

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Generator Rooms,_ construction debris has accumulated. G. K.

Newberg will continue to provide housekeeping activities on a scheduled basis to minimize the accumulation of debris, and_has subsequently cleaned the Diesel Generators. The injector pump covers were found to be loose and resting on the valve control air lines. 'These covers have since been tightened. The air lines were inspected by the Cooper Bessimer, service representative and found to be acceptable.

In our. judgement, no further action is required at this time.

ACCUMULATOR' TANKS The-mud between the bottom of the tank and the support skirt has subsequently been removed on all Accumulator Tanks.

l The Accumulator Tanks were stored outside prior to their installation in the building. We believe that the accumulated L mud that-was allowed to remain for some time on the Accumulator Tanks was an isolated occurrence.

I A gas purge was used- to- protect the internals cf the Accumulator Tanks and to maintain the internal cleanliness during their storage, until the time.when the piping was attached to the tanks.' ;The presence of the. mud did-not affect the internal

cleanliness. However,Jif the mud had remained undetected, the mud might have caused. additional external surface rusting.

L 'DATE WHEN FULL COMPLIANCE'WILL BE ACHIEVED Comolete.

F

<W~

s

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VIOLATION NO. 2 Criterion IX of Appendix B to'10 CFR 50, " Control of Special Processes", states in part: " Measures shall be established to assure and that special testing nondestructive processes, are controllded including welding, heat treating and...". The American Boiler and Pressure Vessel Code, Division 1, Subsection NB Class 1 Components,. Article 4000 " Fabrication and Installation Requirement", Subarticle 4411 " Identification, Storage and Handling of Welding Materials" states in part:

" Suitable identification, storage and handling of electrodes, flux and.other welding material shall be maintained .

-Precautions shall be taken to minimize absorption of moisture by electrodes and flux."

Commonwealth Edison Quality Assurance Procedure 9-1 states in part:

"This procedure establishes the methods for assuring that special processes are accomplished under controlled conditions '

and by qualified personnel using qualified procedures in accordance with the requirements of applicable codes, standards and specifications".

Construction Welding Procedure Section 9 Paragraph 9.2.1.1 states in part:

hour supply of welding "A welder shall not rod unless. draw more a portable rodthan ovenfour is (4) issued.- Welders shall return any unused welding rod at the end

.of eightfour hours hours if no with theweld userod of aoven weldwas rod issued oven." or at the end of Contrary to the above requirement and the installation procedures, the installation contractors were conducting safety related welding without assurance that welding materials were being properly controlled.

RESPONSE TO VIOLATION NO 2 i

-CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED i

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All suspect weld rod was discarded and craft personnel in the field were -re-instructed in the proper method of controlling weld rod.

CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE The Project Construction Department has issued a site directive to all Contractors. The directive required each Contractor to re-instruct their personnel on the proper control of weld rod.

1 DATE WHEN FULL COMPLIANCE WAS ACHIEVED September'19, 1983.

-7323N '

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