ML20081A412
| ML20081A412 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 01/20/1984 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20081A408 | List: |
| References | |
| 7874N, NUDOCS 8403050171 | |
| Download: ML20081A412 (3) | |
Text
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- N Commonwe:lth Edison
) One First National Plaza. Chicago. Illinois O
O"-
Address Reply to: Post Office Box 767
(
Chicago. Illinois 60690 January 20, 1984 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
LaSalle County Station Units 1 and 2 Response to Inspection Report Nos.
50-373/83-41 and 50-374/83-42 NRC Docket Nos. 50-373 and 50-374 Reference (a):
J. F. Streeter letter to Cordell Reed dated December 7, 1983.
Dear Mr. Keppler:
This letter is in response to the inspection conducted by Messrs. N.
C.
- Choules, W.
J. Kropp, and J. N. Kish on September 8, 28-29, October 20, and November 10, 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 information furnished by other Commonwealth Edison employees.
Such 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 them to this of fice.
Very truly yours, MN
- 0. L.
Farrar Director of Nuclear Licensing lm 8403G50171 840227 PDR ADOCK 05000373 G
PDR Attachment cc:
NRC Resident Inspector - LSCS g '5 @
7874N
,o RESPONSE TO INSPECTION REPORT NOS.
50-373/83-41 and 50-374/83-42 Item of Noncompliance 10 CFR 50, Appendix B, Criterion V, states, in part, that " Activities af fecting quality shall be prescribed by documented instructions, procedures...and shall be accomplished in accordance with these instructions, procedures...".
The licensee's Quality Assurance Topical Report, CE-1-A, Revision 15, Section 3.1, requires, in part, that design evaluations of modificatiors will be commensurate with those applied to the original design and than evidence of design evaluations and reviews and use of alternative calculated methods used to assure verification or checking of desigt, adequacy will be documented and retained by Project Engineering.
Contrary to the above:
a)
Design control measures were not fully implemented for the design change made to the discs for Units 1 and 2 inboard feedwater check valves 1821/F010A/B and 2821-F010A/B, in that documented evidence was inadequate to substantiate that a comprehensive design evaluation and review was conducted regarding the modification of the valve disc for addition of the sof t seat seal material.
Specifically, there was no evidence to verify the structural adequacy of the modified valve discs and the environmental qualifications of the soft seat seal material.
b)
Design control measures were not implemented when the molded seals were replaced with extruded / vulcanized seals on the Unit 1 inboard feedwater check valves 1821-F0101A/B in September 1983, in that no design analysis and evaluation of the change was performed.
This is a Severity Level IV violation (Supplement I).
Response
Item A Corrective Action Taken and Results Achieved The Design Change for the Inboard Feedwater Check Valves was initiated by Project Engineering during the construction phase following QA Procedure QP 3-1 and therefore is not considered a modification.
Anchor / Darling Valve Co., the original e: aipment manufacturer, was asked to solve the problem of these valves not being able to pass an Appendix J Type Air Leakage Test.
Engineering believes that the design, material selection and structural adequacy of these valves is A/DV's responsibili ty.
l l
. i l
This design change was implemented by the issuance of a safety-i related change order to A/DV which also referenced the original i
Puchase Specification J-2938.
I Structural adequacy of the modified disk is also a A/DV responsibility as the preparer of the ASME Class 1 Stress Report.
A/DV has stated, during the October 23, 1983 meeting, that the stress report was reviewed and required no revision.
As no changes were made, no record of the review was made.
Engineering also believes that the responsibility for material selection and qualification is the valve designers, A/DV.
Also, the soft seat is considered a secondary sealing surface.
The primary sealing surface is the hard faced seat, which provides control of gross leakage.
This is consistent with the ANSI 56.2, 1980 Drs' interpretation of the SRP for this valve configuration.
Corrective Action Taken to Avoid Further Noncompliance Engineering believes that no corrective action is required since design review procedure QP 3-1 had been followed.
However, since LaSalle is now considered an operating station, future changes to these valves would be done by Q.P. 3-51 design control for operation.
A/DV demonstrated during the October 20, 1983 Meeting, that their present procedures require documentation of stress report reviews, whether a revision is required or not.
Date When Full Compliance Will Be Achieved As noted above, the appropriate procedures are in place, both at CECO and A/DV, and full compliance has been achieved at this time.
Item B Corrective Action Taken and Results Achieved The selection of the extruded seals was made by A/DV to meet Commonwealth Edison's request for replacemeat parts.
Since this material was recommended and supplied by the original valve manufacturer as spare parts, engineering did not perform a detailed l
review.
A/DV provided the parts as acceptable replacements under our safety related purchase order.
l During the November 1983 outage, the failed extruded seals were replaced by molded seals manufactured by Sargent Industries.
1
. Corrective Action Taken to Prevent Recurrence The molded seal will be the standard replacement part used in the future.
Our confirmatory action letter response dated December 14, 1983, addresses future seal qualification efforts.
Date-When Full Compliance Will-Be Achieved Full-compliance was achieved with the replacement of the extruded seals with nolded seals.
Future replacements, if any, will be based on the results of our Qualification Program.
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