ML20082F827
| ML20082F827 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 07/08/1983 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20082F761 | List: |
| References | |
| 6914N, NUDOCS 8311290255 | |
| Download: ML20082F827 (6) | |
Text
.
[ ^~ N Commonwealth Edison
/ On3 First Nationd Plaza, Chicago, lihnois
. k U,
] Address Reply to: Post Office Box 767 NQ Chicago Illinois 60690 July 8, 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 Supplemental Response to IE Inspection Nos.
50-456/83-02 and 50-457/83-02 NRC Docket Nos. 50-456/457 References (a):
D.L. Farrar letter to J. G. Keppler dated April 29, 1983 (b):
C. E. Norelius letter to Cordell Reed dated March 23, 1983 (c):
E. D. Swartz letter to J. G. Keppler dated May 26, 1983.
Dear Mr. Keppler:
Reference (a) provided the Commonwealth Edison Company thirty (30) day response to the Reference (b) Inspection Report.
Subsequent discussions were held with members of your staff to address their continuing concerns with our response.
The purpose of this letter is to provide a revised response to the Notice of Violation Items 1 and 3 as appended to Reference (b).
To the best of my 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 and consultants.
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 ly yours, A
8311290255 831123 Dennis L. Farrar PDR ADOCK 05000456 Director of Nuclear Licensing G
PDR Attachment cc:
RIII Inspector - Braidwood Jg 6914N
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ATTACHMENT Revised Response to Notice of Violation 3
Violation 1 10 CFR 50,' Appendix B, Criterion III, Design Control, states in part:
" Measures shall be established to assure that applicable regulatory requirements and the design bases for those structures, systems,_and components to which this appendix
. applies are correctly translated into specifications, drawings, procedures and instructions.
These measures shall include provisions to assure that appropriate quality standards are specified and included in 4
design documents and that deviations from such standards are i
controlled.
Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design and approved by..."
The Braidwood FSAR, Appendix A, page A1.64-1 commits to i
compliance with Regulatory Guide 1.64 which endorses ANSI N45.2.ll-1974.
ANSI-45.2.11 states in part:
" Documented procedures shall provide for effecting design changes to approved design documents, including field changes, which assure that the Limpact of the change is carefully considered, required actions documented and information concerning the change is transmitted to all affected persons and organizations.
4 CECO. Quality. Assurance Program for Nuclear Generating Stations, Commonwealth Edison Company Tonical Report CE-1-A, Section 3.0, F
-Quality Requirement, QR 3.3 states in part:
"The Station Nuclear Engineering Department assigns an organization to verify installation of modifications in accordance with-design and F
quality. assurance requirements."
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Contrary to the above requirement the licensee has failed to perform a design'as built review or an Engineering Change Notice (BCN) to assure that the field modifications completed during initial placement of the Safety Injection System Accumulators
-were commensurate with those applied to the original design.
Revised Response to Item 1 l
CORRECTIVE ACTION.TAKEN AND THE RESULTS ACHIEVED j
Phillips Getschow prepared-grout releases #1553-1556 on March 2, 1983, which precipitated the issuance of FCR Nos. #L-7617 dated
-March 10, 1983 and #L-7909 dated March-17, 1983 to clarify the type of grout to be used, floor surface conditions required, and allowing _the equipment shims to be left in place after grouting.
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w f, CORRECTIVE ACTION TO BE TAKEN TO AVOID'FURTHER NONCOMPLIANCE Reference (a) provided our 30 day response to this item of noncompliance as we understood it.
Subsequent dicussions were held between CECO. and members of Region III staf f to discuss our apparent misunderstanding of this violation.
The following was agreed to during a June 6,_1983 meeting between CECO. and Messrs. R. C. Knop, D. W. Hayes, and L. McGregor of your staff.
l On June 6, 1983, Commonwealth Edison requested our AE (Sargent &
Lundy) to clarify the seismic design analysis for the as-installed condition of the Safety Injection Accumulator Tanks through the review and acceptance of the requisite FCRs.
We expect Sargent & Lundy's response to our request on or about September 1, 1983, at which time it will be made available for Region III's review.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED September 1, 1983 l
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34 i Violation 3 10 CFR 50, Appendix B, Criterion III, Design Control states in part:
" Measures shall be established for the identification and control of design interface and for coordination among participating design organizations.
These measures shall
' include the establishment of procedures among participating design organizations for the review, approval, release, distribution, and revision of documents involving design interfaces.
The design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews....
The verifying or checking process shall be performed by individuals or groups other than those who performed the original design, but who may be from the same organization.
The ASME Bofler and Pressure Vessel Code, Nuclear Power Plant Components,Section III, Subsection NCA
" General Requirements for Division I and II," subparagraph 4134.3 Design Control states in part:
Design changes, including field changes, shall be accepted by the organization that performed the original design unless the Owner specifically designates another responsible organization.
Procedures shall be established among participating design organizations for the review, approval, release, distribution, and revision of documents involving design interface.
Commonwealth Edison Quality Assurance Manual, Section "ASME CODE INTERFACE," Paragraph 2.0, Drawing and Specification Control, states in part:
" Drawing as specification control is maintained by Project Engineering and Station Nuclear Engineering Department (SNED), as applicable, to assure that only the latest approved drawings and specifications are utilized in the procurement, fabrication, construction, maintenance and modification of nuclear power plant facilities."
Quality Assurance Requirement 3.0, Design Control, Paragraph 3.1, states in part:
" Design evaluation of modifications will be commensurate with those applied to the original design.
Review and evaluation by the Architect Engineer, the Nuclear Steam Supply System Vendor, and/or the Project Engineer, or the Station Nuclear Engineering Department, as well as by other CECO. organizations, and specially qualified people, such as level III's for NDE and for concrete inspections and tests, will assure that designs, specifications and procedures will conform to the ASME and other applicable codes, standards, regulatory requirements, SAR commitments and appropriate quality standards, as applicable."
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. Quality Assurance Requirement 3.0, Design Control, Paragraph 3.2, Documentation states in part:
" Evidence of design evaluation and reviews and use of alternative calculational methods used to assure verification or checking design adequacy will be documented and retained by Project Engineerino and, Contrary to the above commitments Commonwealth Edison Company is presently installing an extensive plant modification at Byron and Braidwood which has'not been properly reviewed and approved by Project Engineering.or Station Nuclear Engineering Department.
The entire: modification, which involves structural steel bolting, was issued the Architect Engineer as a drawing revision and has not been properly reviewed, evaluated, approved or verified by the Owner as required.
Revised Response to Item 3 CORRECTIVE ACTION TAKEN/TO BE TAKEN AND THE RESULTS ACHIEVED On April 29, 1983, the Commonwealth Edison Company Project Engineering Department notified Mr. Julian M. Hinds of your office of a deficiency No. 83-04 reportable pursuant to 10 CFR 50.55(e) regarding structural steel connection rework at Braidwood Station.
Reference (c) subsequently provided the final 30 day report concerning this matter and defined our corrective actions to resolve the jam nut installation.
The initial installation requirements on the American Bridge Division Erection Drawings stated the burring of bolt threads.
The requirement to burr the bolt thread was to ensure that the nut would not loosen over time.
However, original design requirements failed to provide adequate guidance to ensure a uniform and acceptable method to burr the bolt threads, thus necessitating the addition of a jam nut for slotted structural steel connections.
Commonwealth Edison Company authorized the revision for the installation of Jam nuts for all sliding connections as an added precaution to prevent the occurrence of the first nut becoming loose and disengaging from the connection.
Jam nuts are being installed on structural steel connections in the Containment Buildings where a sliding connection is provided.
This includes structural steel used as floor framing and miscellaneous steel used for component supports.
The requirements for installing jam nuts are specified on the following design drawings:
S-1097 - Revision U, dated October 15, 1982.
S-960
- Revision N, dated March 18, 1983.
ENC-3270 - Dated January 4, 1983.
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. The design drawing requirement to provide jam nuts on structural steel-will be implemented at Braidwood Station in the same manner as any other Sargent & Lundy drawing revision.
The installation contractors' approved Q.A./Q.C. procedure will ensure proper installation.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Braidwood Station is expected to complete jam nut installation for Unit 1 Containment by July 25, 1983, and Unit 2 Containment by November 25, 1983.
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