ML20128G951

Forwards Util 850621 Response to Insp Repts 50-456/85-15 & 50-457/85-16.Ltr Relevant to Issues 3.B & 12.C of Amended Contention Admitted by ASLB 850621 Order.Certificate of Svc Encl.Related Correspondence

ML20128G951
Person / Time
Site:	Braidwood
Issue date:	07/03/1985
From:	Gallo J COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE
To:	Brenner L, Callihan A, Cole R Atomic Safety and Licensing Board Panel
References
CON-#385-710 OL, NUDOCS 8507090367
Download: ML20128G951 (9)

Text

$6 ISHAM, LINCOLN & BEALE

COUNSELORS AT LAW

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Lawrener. Brenner, Esq. BRANCH Chairman Administrative Law Judge Atomic Safety and Licensing Board United States Nuclear Regulatory Commission Washington, DC 20555 Dr. Richard F. Cole Dr. A. Dixon Callihan Administrative Law Judge Administrative Law Judge Atomic Safety and Licensing 102 Oak Lane Board Oak Ridge, TN 37830 United States Nuclear Regulatory Commission Washington, DC 20555 Re: In the Matter Of: Commonwealth Edison Company (Braidwood Nuclear Power Station, Units 1 and 2), Docket Nos. 50-456, 50-457 0L

Dear Administrative Judges:

In accordance with the reporting and disclosure obligations set forth in Duke Power Company (William B.

McGuire Nuclear Station, Units 1 and 2), ALAB-143, 6 AEC 623 (1973), I have enclosed a copy of a June 21, 1985 letter from D. L. Farrar, Commonwealth Edison Company Director cf Nuclear Licensing, to James Keppler, NRC Regional Adminis-

, trator. The letter provides Commonwealth Edison's response to Inspection Report 85-015/016, dated May 16, 1985, and it is directly relevant to issues 3.B. at page 27, 10.F. at page 39, and 12.C. at page 43 of the amended contention, as admitted by the Board in its Order of June 21, 1985.

Respectf'ully ,

8507]O PDR hh p Joseph Gallo 0

One of the Attorneys For COMMONWEALTH EDISON COMPANY cc: Service List b

3 50

Commonwealth Edison One First National Plaza Cnicago Illinois Address Reply to. Post Office Box 767 Chicago, lihnois 60690 June 21, 1985 ,

Mr.' James G. Keppler Regional Administrator Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, 11 60137

SUBJECT:

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

50-456/85-015 and 50-457/85-016 NRC Docket Nos. 50-456 and 50-457 Reference (a): W. S. Little letter to Cordell Reed dated May 16, 1985.

Dear Mr. Keppler:

This letter is in response to the inspection conducteo by Messrs. R.D. Schulz, W.J. Kropp and R.N. Gardner on March 25 through May 3, 1985 of activities at Braidwood Station. Reference (a) indicated that certain activities appeared to be in noncompliance wii.i. C D . w ir = nts,= 15e. Commonwealth Edison CompanyBaseo response on to the Notice of Violation is provioed in the enclosure.

actions taken to correct and to prevent recurrence of the noncompliance identified in Item 4, no response to this item of l noncompliance was required.

1 The delay in submitting this response was discussed with

i. Mr. W. S. Little on June 13, 1985. If you have any further questions on this matter, please direct them to this office.

Very truly yours, f)r2h YtN'-'

D. Lf Farrar

' Director of Nuclear Licensing i

bs Enclosure cc: NRC Resident Inspector - Braidwood 0297K

s a

Response to Inspection Report 456/85-015 and 457/85-016 .

Item 456/85-015-01 and 457/85-016-01 -

Item of Noncompliance

1. 10 CFR 50, Appendix B, Criterion II states, in part, that the quality assurance program shall provide control over activities affecting the quality of the identified structures anc shall take into account the need for special controls, processes, and training to attain the required quality, ano the need for verification of quality by inspection and test.

The Commonwealth Edison Company Quality Assurance Manual states in Section Q.R. No. 1.0, " Edison has prime responsibility for controlling the quality of onsite work by field contractors."

Contrary to the above, the licensee had not established an inspection program for safety-related structural beams that were modified during nonsafety-related piping installations, and had not established an adequate craft training program with regard to nonsafety-related piping installation activities resulting in field design modifications to safety-related structural steel. Three safety-related structural beams had openings cut into them to allow the routing of 4" diameter

- uunsaie;y-telaire pipe through" the web of the -beam.

Five inch diameter openings cut in the web areas of beams 8AB794 and 8AB799N were not permitted by any instruction, procedure, or drawing and had not been identified by the licensee or contractors through a field design change request or quality control inspection. A 6" diameter opening in the web of beam 6AB145 was stipulated on Drawing 5-1293; however, a 5 1/2" X 13" oval opening was cut in the web ano this nonconforming condition had not been identified by the licensee or contractors througn a field design change request or quality control inspection.

Response

Commonwealth Edison Company agrees there were unauthorized mooifications of structural beams for pipe penetrating them.

We believe these types of. situations were isolated to the building floor drain piping' systems which are class D non-safety related piping systems. Additionally, these unauthorized modifications were performed some years ago, prior to the implementation of interface controls in place today.

- . - . . _ _ _ - .. Y

Corrective Action Taken and Results Achieveo Sargent and Lundy has walked down the Unit 1 & 2 floor drain systemc during their review for hanger designs. There are 49 affected beams ~.' Some of the holes are not shown on the design drawings and others were cut different than drawing requirements. We plan no additional actions to determine whether further cases of this type. exist in piping systems other than the floor drain system. Our action is based on the fact that there have been other structural steel review programs looking at these work practices such as Quality Control Structural Steel Review Program (QCSSR), Unit Concept inspections and the Instrument Retrofit Verification Program (IRV). We have no knowledge of similar situations being identified through these programs and have concluded the problem is isolated to the floor drain system.

Commonwealth Edison Nonconformance Report (NCR) No. 740 has been initiated to address the identified beams.

Corrective Action Taken to Avoid Further Noncompliance More stringent procedural controls have been put in place since the work which resulted in these deficiencies was completed.

Current procedures ensure that work is completed in a

__ controlled manner._ _Therefore, furth.er corrective action is not requireo.

Date of Full Compliance Corrective actions required by NCR 740 are expected to be complete by December 1985.

0297K

Response to -

Inspection Report 456/85-015 and 457/85-016

• Item 456/85-015-08 Item of Noncompliance that a

2. 10 CFR 50, Appendix B, Criterion X states, in part, program for inspection of activities affecting quality snali be executed to verify conformance with the documented drawings for accomplishing the activity.

The Commonwealth Quality Assurance Manual states in Section Q.R. No. Edison 10.0 that quality assurance inspections will be conducted at the site during construction to verify conformance to applicable drawings.

Contrary to the above, the electrical contractor inspected and accepted a junction box which was later determined to have deficiencies in the location of the anchors used for the mounting of the junction box. These anchors were accepted by the electrical contractor's inspector even though they were up to 3" from the required location specified by Sargent & Lundy drawing 20E-1-3571.

i

Response

K.

A reinspection of junction box 1]B217R confirmed that L.

Comstock's inspector 16borrectly accepted the anchor locations.

Corrective Actions Taken and Results Achieved L. K. Comstock Nonconformance Report (NCR) No. 4139 was initiated to document and track this deficiency.

' All inspection activity in the area of junction box / equipment inspection for the inspector involved was halted until anSince the insp evaluation he could beamade.

had inspected total of~seven (7) safety-related junction boxes.

Another inspector was assigned to reinspect all seven junction boxes.

No additional discrepancies were noted.

Corrective Action Taken to Avoid Further Noncompliance Based on the results of the reinspection it has been determined that this was an isolated case and the inspector involved has

?

performed junction box / equipment inspections in a competent manner. The inspector involved has been made aware of his mistake in this case. No further corrective action is required.

Date of Full Compliance Completion of L. K. Comstock NCR 4139 is expected by July 1985. m

s Response to Inspection Report 456/85-015 and 457/85-016  :

Item 456/85-015-06 Item of Noncompliance

3. 10CFR50, Appendix B, Criterion XVI, and the Commonwealth Edison Quality Assurance Manual Q.R. 16.0 require, in part, that conditiors adverse to quality be promptly identified and corrected.

Contrary to the above, the licensee's Site Q.A. organization

~ ~~ ~1nappropriately'cl~ose~d Non-Conforman~ce Report No. 600 and as a result did not assure that conditions adverse to quality were corrected. The non-conformance report stated there was no traceability of material for twenty piping supports to a certified material test report and the non-destructive examination for some of the welds was not performed as required by the ASME Boiler and Pressure Vessel Code. Site Quality Assurance closed the non-conformance report without verifying that the supports were corrected or re-designed with regara to material traceability and non-destructive examination ASME Cooe requirements; and did not adequately perform reviews to assure that supports not detailed on Non-Conformance Report No. 600 did not have similar material and non-destructive examination deficiencies. The inspector subsequently identified two supports, (1CV0603V and 1RH02020R), detaileo on Non-Conformance Repo_r_t_No. 600 and one support, (15I030465), not detailed on Non-Conformance Report,,No. 600 which were not procurea and non-destructively examined in accordance with ASME Section III, Section NF.

Response

Commonwealth Edison Report (NCR) No. 600 initiated 3-13-84 identified ASME Section III Class A supports with incorrectly classified hardware and related attachments.

The disposition of NCR No. 500 was to assure that primary linear members were correctly identified on the design dra,ings for the listed supports. As a result of the Sargent & Lundy (S & L) review, design document changes were issued that corrected, as necessary, bills of material for listed supports. Since installation of the supports in question had not been completed, Site Quality Assurance close-out of NCR No.

600 was based on review of selected drawing changes initiated

, by S & L, including all drawing changes identified to have added primary linear members.

_ _ _ ._ _ . . _ _ _ _ . __ _ - _ . . . - , _ , _ . . - _ _ _ _ _ _ _ _ _ - . . _ _ . , _ _ _ _ _ _ _ _ _ _ . _ , _ _ _ , _ _ , . _ _.._2

Response to e Inspection Report 456/85-015 and 457/85-016 -

1

' Item 456/85-015-06 Commonwealth Edison acknowledges that, in this case, verification of corrective actions would have been more effective if the NCR had not been closed until work had progressed further on the subject supports.

Corrective Action Taken and Results Achieved The NCR has been re-opened and a letter sent to Project Engineering requesting that the design status of all supports j associated with NCR No. 600 be updated. NCR No. 600 will not be closed until proper installation of the subject hangers has been verified by Site Q.A. Completion is expected by 9-30-85.

To confirm that this was in fact an isolated case, Site Quality Assurance will review ten (10) additional Commonwealth Edison NCRs closed in the September, 1984 time frame. The review will be performed by someone other than the person who performea the initial review.

Material traceability and installation of ASME Class 1 supports were the subject of a Special Audit by Phillips Getschow (PGCo)

Quality _ Assurance. This special audit was requested by Commonwealth Edison, and was conducted between 3-12-85 and 4-24-85. The resulting concerns identified are being addressed by corrective actions related to the PGCo Special Auoit, PGCo NCR's, and Commonwealth Edison NCR 744.

Corrective Action To Avoid Further Non-Compliance i

Commonwealth Edison believes this is an isolated case, j However, to highlight the importance of the issue a training session will be presented to Site Q.A. personnel Involved with j NCR corrective action verifications. NCR No. 600 will be

discussed to stress the importance of not closing NCRs until corrective action is complete anc the effectiveness of programmatic controls is verified.

Date of Full Compliance -

Completion of corrective action and closure of NCR 744 is i

expected by December 1985. Completion of corrective action and l closure of NCR 600 is expected by September 30, 1985.

Completion of the review of the ten (10) additional NCR's is I expected by August 15, 1985. Completion of training is l expected by July 1, 1985.

L

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00LKETED BEFORE THE ATOMIC SAFETY AND LICENSING BOARD USMC In the Matter Of. ) '85 J1 -8 P12 :17

)

l -COMMONWEALTH EDISON COMPANY ) 0FFICE OF StChtIA:

) Docket Nos. 50-456 00CXETING & SEPylCL (Braidwood Nuclear Power ) 50-457 BRANCH Station, Units 1 and 2) )

CERTIFICATE OF SERVICE I, Rebecca J. Lauer, one of the attorneys for Commonwealth Edison Company, certify that copies of the letter, dated July 3, 1985, from Joseph Gallo to the Ad-ministrative Judges, together with copies of the enclosure thereto, have been served in the above-captioned matter on those persons listed in the attached Service List by United States mail, postage prepaid, this 3rd day of July, 1985.

&~ w-Rebecca 4. Lauer ISHAM, LINCOLN & BEALE Three First National Plaza suite 5200 Chicago, Illinois 60602 (312) 558-7500 DATED: July 3, 1985

1 O

SERVICE LIST Lawrence Brenner, Esq. Mr. William L. Clements Chairman Chief, Docketing and Services Administrative Law Judge Un'ited States Nuclear Regulatory Atomic Safety and Licensing Commission Board Office of the Secretary United States Nuclear Regulatory Washington, DC 20555 Commission Washington, DC 20555 C. Allen Bock, Esq.

P.O. Box 342 Dr. Richard F. Cole Urbana, IL 61801 Administrative Law Judge Atomic Safety and Licensing Board Ms. Bridget Little Rorem United States Nuclear Regulatory 117 North Linden Street Commission P.O. Box 208 Washington, DC 20555 Essex, IL 60935 Dr. A. Dixon Callihan Robert Guild Administrative Law Judge Douglass W. Cassel, Jr.

102 Oak Lane Timothy W. Wright, III Oak Ridge, TN 37830 BPI 109 North Dearborn Street Suite 1300 Myron Karman, Esq. Chicago, IL 60602 Elaine I. Chan, Esq.

Office of the Executive Legal Director Ms. Lorraine Creek United States Nuclear Regulatory Route 1 Commission Box 182 Washington, DC 20555 Manteno, IL 60950 Atomic Safety and Licensing Charles Jones, Director Board Panel Illinois Emergency Services United States Nuclear Regulatory and Disaster Agency Commission 110 East Adams Washington, DC 20555 Springfield, IL 62705 Atomic Safety and Licensing Appeal Board Panel United States Nuclear Regulatory Commission Washington, DC 20555