ML20113D204
| ML20113D204 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 02/27/1985 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 9813N, NUDOCS 8504150105 | |
| Download: ML20113D204 (3) | |
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@ one First Nation 1 Pl*za. Chicago, lihnois Commonwealth Edison Address Reply to: Post Office Box 767 Chicago Illinois 60690 February 27, 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.
50-456/84-21 and 50-457/84-20 NRC Docket Nos. 50-456 and 50-457 Reference (a):
R. F. Warnick letter to Cordell Reed dated November 20, 1984 (b):
D. L. Farrar letter to James G. Keppler dated January 31, 1985
Dear Mr. Keppler:
Reference (b) provided, in part, a response to Item 3 of the Notice of Violation transmitted with reference (a).
The enclosure to this letter amends that response to provide additional clarification of our position on the issue involved.
Very truly yours, huU-;
C Dennis L.
Farrar Director of Nuclear Licensing 4
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NRC Resident Inspector 9813N MAR 4 1985 0504150105 850227 PDR ADOCK 05000456 gg G
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ENCLOSURE COMMONWEALTH EDISON COMPANY SUPPLEMENTAL RESPONSE 50-456/84-21 AND 50-457/84-20 ITEM 456/84-21-07-AND-457/84-20-07 ITEM OF NONCOMPLIANCE 3.
10 CFR 50, Appendix B, Criterion XVI, Corrective Action, states in part, " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected".
The Braidwood FSAR, Amendment 43 and the Commonwealth Edison Company Quality Assurance Manual commit to Regulatory Guide 1.116, June 1976 which endorses ANSI N45 2.8, 1975, Supplementary Quality Assurance Requirements for Installation, Inspection and Testing of Mechanical Equipment and Systems for The Construction Phase of Nuclear Power Plants.
ANSI N45-2.8, states in part in Section 3, Pre-Installation Verification, that inspections or checks shall be performed and include verifications such as removal of packaging, conditioning, and cleaning.
Section 4, Control During Installation Process, statas in part that inspection of the work areas and'the work in progress shall be performed for mechanical items and shall include cleanliness inspections and inspections to assure that items will not be contaminated as a result of adjacent construction activities.
ANSI N45 2.8 states in part in Section 2.4, Cleaning, that cleaning shall be performed in accordance with ANSI N45 2.1, 1973.
ANSI N45 2.1 states in part in Section 2, General Requirements,
'that the work and quality assurance requirements for the cleaning of items and systems to be incorporated in the Nuclear Power Plant and control of cleanliness thereof shall be established in order to (1) ensure the removal of any deleterious contaminants, (2) minimize recontamination of cleaning surfaces, and (3) minimize the cleaning required after installation.
Section 4, Pre-Installation Cleanness, states in part that inspections, examinations, and tests as appropriate shall be performed immediately prior to installation to determine the cleanliness of the item.
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p SUPPLEMENTAL RESPONSE ITEM 456/84-21-07 AND 457/84-20-07 ITEM OF NONCOMPLIANCE (cont'd)
Contrary to the above after an NRC inspection (82-05) identified that the licensee failed to implement a quality assurance program for the erection of mechanical safety-related equipment, the piping / mechanical equipment contractor identified numerous pieces of mechanical equipment that had been installed without quality control verification of internal cleanliness.
Although these nonconforming conditions were reported to the licensee, the licensee failed to adequately evaluate or take corrective action.
The common evaluation of these nonconforming conditions was to waive the cleanliness inspection and " flush it clean".
Quality control inspections of internal cleanliness had not been formulated during the installation process to assure the absence of corrosion, pitting and contaminants including foreign objects that may affect the safe and reliable operation of safety-related equipment.
COMMONWs2LTH EDISON COMPANY POSITION CLARIFICATION Although no response to this Item of Noncomplicnce was required, Commonwealth Edison wishes to clarify our position with respect to it.
As stated in the Item of Noncompliance, during the mechanical equipment retro-inspection resulting from NRC inspection 82-05, some pieces of equipment had no documentation showing that cleanliness inspecticas were performed during initial installation activities.
This lack of documentation does not imply cleanliness inspections were not performed at the time of initial installation activities.
Commonwealth Edison Company had sufficient confidence in system cleanliness during initial installation activities to warrant their disposition of waiving equipment disassembly and using the piping system flushing program to demonstrate system cleanliness.
In retrospect, the piping system Flushing program may not revea_
any large solid objects lef t in ' ie system and not caught by cleanliness inspections or lack f cleanliness inspections.
To date eleven (11) pieces of mechanical equipment on systems that had beer flushed have been opened.
The mechanical equipment was clean.
.he program established under Commonwealth Edison NCR 614 will result in equipment with adequate internal equipment cleanliness.
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