ML20107E183

Forwards Addl Info Re 840702 Response to Noncompliance Noted in Insp Repts 50-456/84-09 & 50-457/84-09.Corrective Actions:Improved Installation Clearance Guidelines Implemented by Contractors

ML20107E183
Person / Time
Site:	Braidwood
Issue date:	02/13/1985
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
9760N, NUDOCS 8502250415
Download: ML20107E183 (3)

Text

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Commonwealth Edison Ons First National Pl?ra. Chiergo, lilinois Address Reply to: Post Office Box 767 Chicago Illinois 60690 February 13, 1985 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Braidwood Station Units 1 and 2 Response to Inspection Reports Nos.

50-456/84-09 and 50-457/84-09 NRC Docket Nos. 50-456 and 50-457 References (a): R. F. Warnick letter to Cordell Reed dated July 2, 1984 (b): D. L. Farrar letter to J. G. Keppler dated July 31, 1984 (c): R. F. Warnick letter to Cordell Reed dated August 15, 1984 (d): D. L. Farrar letter to J. G. Keppler dated October 22, 1984 (e): D. L. Farrar letter to J. G. Keppler dated November 7, 1984

Dear Mr. Keppler:

The enclosure to this letter provides additional information regarding our response to Item of Noncompliance #1 identified in Reference (a). Our response to this item was provided in References (b), (d) and (e).

Should you or your staff have any questions regarding this matter please contact this office.

Very ruly your D. L. Farrar Director of Nuclear Licensing cc: NRC Resident Inspector - Braidwood FEB 15 B8 l 8502250415 850213 '

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ENCLOSURE

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ADDITIONAL INFORMATION FOR INSPECTION REPORT 50-456/84-09 AND 50-457/84-09 im ITEM 456/84-09-01 AND 457/84-09-01 4-5

1. The ECN's adding improved installation clearance guidelines to the 95 Contractor's Specifications have been implemented by'each eg contractor. The specification guidelines require that each 3.

contractor establish a program to ensure the listed installation =.

clearance guidelines are met. j These guidelines require the contractor to follow good workmanship and practical practices when installing or modifying components 95 and/or materials and to consider whether reasonable clearance exists between items when installation is completed. Reasonable clearance ))

_m shall be construed to mean that clearance has been provided (except Ja where otherwise allowed for in the design documents) for items such R!

as inspection access, maintenance access, equipment removal, repair ;7 access, functional operability of valves and equipment, and thermal J expansion.

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J Installation of any component in direct contact with any other -

unassociated component (except where called for in the design i documents) is not acceptable unless approved by the Consulting g Engineer. This stipulation includes installation of components in direct interference with installed insulation. Instances of _i installation of items in direct contact with other items will be j brought to the attention of the Consulting Engineer for disposition.

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2. Braidwood Station Procedure BWAP 1205-11, System Turnover for Operation, was implemented January 31, 1985. This procedure -

provides an instruction for the station to perform a review of ai systems to determine acceptability for operation. [

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Applicable systems are reviewed by the Station Technical Staff, #

Maintenance Department Operating Department and Rad / Chem Department in accordance with their review checklists. Some of the items --

included in these Checklists are: j Walkdown performed to determine if any scaffolding or d construction material hindering system safe operation. Si Walkdown performed to determine condition of housekeeping. .

Possible equipment removal evaluated. i Impact on operability of other systems due to turned over =

condition of the system reviewed. '"!

Overhead attachments for lifting reviewed. "l System control cabinet door opening access checked.  ;

Component accessibility for maintenance walkdown performed. 2 Component accessibility for operation walkdown performed. -

Sample point accessibility walkdown.

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ENCLOSURE ADDITIONAL INFORMATION FOR INSPECTION REPORT 50-456/84-09-AND 50-457/84-09 ITEM 456/84-09-01 AND 457/84-09-01 Implementation of this procedure should insure accessibility of system components for maintenance, repair and operation.

3. Braidwood's Pre-Service Inspection (PSI) Program is intended to meet the requirements of the applicable ASME Section XI Code and 10 CFR 50.55a. The scope of the PSI Program includes all components and items ultimately to be included in the In-Service Inspection Program. This provides confidence that all required items for ISI are inspectable (because they were inspected for the

' PSI) or that they have been dispositioned in accordance with the provisions of 10 CFR 50.55a.

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