ML20138B643
| ML20138B643 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 03/11/1986 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1400K, NUDOCS 8603250122 | |
| Download: ML20138B643 (5) | |
Text
_ N Commonwe:lth Edison
/
) One First National Plaza. Chicago, Ilknots
(
7 Address Reply to. Post Office Box 767
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,/ Chicago Illinois 60690 March 11, 1986 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 Response to Inspection Reports Nos.
50-456/85-048 and 50-457/85-047 NRC Docket Nos. 50-456 and 50-457
REFERENCE:
(a)
J.J.
Harrison letter to C.
Reed dated January 27, 1986
Dear Mr. Keppler:
This letter is in response to the inspection conducted by Messrs.
R. Mendez and Z.
Falevits on October 9 through November 5, 1985 of activities at Braidwood Station.
Reference (a) indicated that certain activities appeared to be in violation of NRC requirements.
As identified in Reference (a), no response was required to Violation 2.
The Commonwealth Edison Company response to the Notice of Violation is provided in the enclosure.
Our delay in submittal of this response was discussed with Mr. W.S. Little on February 26, 1986.
If you have any further questions on this matter, please direct them to this office.
Very truly yours, h,
Yl 4 D.
L.
Farrar
- ' Director of Nuclear Licensing
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DLF/pav Enclosure cc:
NRC Resident Inspector Braidwood 1400K B603250122 860311 PDR ADOCK 05000456 O
/ll MAR 131986 ZECf
COMMONWEALTH EDISON COMPANY Response to Inspection Report 456/85-048 457/85-047 Violation 10 CFR 50, Appendix B, Criterion III. as implemented by Commonwealth Edison Company (CECO) Quality Assurance Manual, Nuclear Generating Stations, Section 3, requires that measures be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures and instructions, and that deviations from such standards are controlled.
Contrary to the above, torque switch settings on safety related motor operated valves 1CV8355B, 1SI8807B and 1SI8814 were set in the field either below or above the vendor or engineering required set point values.
Also, limit switch rotors number 2 and 4 on valve 1SI8807B did not operate when the valve was positioned in the fully closed position.
Response (456/85-048-01; 457/85-047-01)
At issue in this violation is failure to assure that design basis information for systems and components are correctly translated into the appropriate procedures, instructions, etc.
based on the observance of improper torque switch settings for certain safety related motor operated valves.
Commonwealth Edison believes the design basis for safety related motor operated valves has been properly translated, to the extent possible, into design documents such as specifications and drawings.
In the design phase, it is not possible to predict the settings for all the geared. limit switches in'the valve operator when taking into account valve specific variables such as packing tightness.
- However, Commonwealth Edison believes the general guidance provided in the design documents is adequate for field setting the geared limit switches when used in conjunction with field procedures that supplement the design information.
Commonwealth Edison agrees that certain torque switch settings on safety related motor operator valves (lCV8355B, 1SI8807B, 1SI8814) were not in accordance with vendor or engineering required setpoint valves.
However, Braidwood Operations Analysis Department (OAD) was aware of this situation as OAD set certain valve torque switches to a lower than required setting as a means of protecting installed equipment during construction tests.
This was done with the understanding that these valves would be reset to the engineering setting at a later date.
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Also, at the time of the inspection, it appears that some confusion existed in the "as found" settings of ISI8807B torque switch.
Subsequent verification by OAD indicated the valve was indeed set in agreement with the applicable Motor Form 1 data sheet.
Hand cranking of the valve using the valve hand wheel did not cause rotors two and four to actuate but subsequent stroking of the valve electrically, produced switch motor operation.
The number two and four rotors were re-adjusted at that time to allow increased stem travel after limit switch operation.
Corrective Action Taken and Results Achieved To insure accurate settings for all motor operated valve limit switches, a review of the Braidwood motor operated valve settings is being undertaken at Sargent & Lundy to provide a comprehensive listing of the approved settings for each installation.
Upon receipt of this listing, it will be transmitted to OAD for verification that "as set" values comply with engineering supplied values.
Any discrepancies will be
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corrected and documented by OAD field personnel.
Certain valves in the RHR, CVCS and SI systems will be functionally tested and baseline data recorded during preoperational testing.
This testing and data is to be taken while the valves are being tested under full system flow and pressure.
Corrective Action Taken to Avoid Further Violation A list of attributes used for the initial set up of valve limit switches has been established and incorporated into the OAD work practices and training instructions.
The incorporation of these attributes will assure consistency in the technique used by personnel involved with the initial set up of valve motor operators.
1 Date when Full Compliance will be Achieved The approved settings for motor operated valves from the Architect Engineer, Sargent & Lundy, is expected by May 15, 1986.
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1 Violation 10 CFR 50, Appendix B, Criterion V as implemented by Commonwealth Edison Company (CECO) Quality Assurance Manual, i
Nuclear Generating Stations, Section 5 requires that the activities affecting quality be performed in accordance with documented instructions, procedures, and drawings of a type appropriate to the circumstances.
4 Contrary to the above, wiring diagram 20E-1-4663C, Revisions "J" and "M",
and Revision Work Request (RWR) No. 789, dated l
October 27, 1981, indicated that the internal connections to relays CRVQlAX and PSVQlAX in compartment C-3 of Motor Control 4
Center (MCC) 131X2 was implemented and verified to be completed.
Field inspection by NRC revealed that the same internal connections were determinated and placed in the MCC's wireway.
In addition, a jumper not shown on drawing a
20E-1-4663C Revision "M",
compartment C3, was found terminated in the field between points 3 and 3A.
i Response (456/85-048-03; 457/85-047-03)
Commonwealth Edison agrees that wires at terminal points 1, 3A X2, 9,
15, 16, 17 and 18 were found to be determinated while L.K. Comstock documentation [ wiring diagram 20E-1-4663C, Revisions "J" and "M" and Revision work Request (RWR) No. 789]
indicated that the work had been complete in August 1983.
However, jumper on Point 3 to 3A was found to be in accordance with internal Wiring Diagram 20E-1-4659A, Figure 2, which was referenced on 20E-1-4663C.
Corrective Action Taken and Results Achieved 4
i This deficiency was documented on L.K. Comstock Inspection Correction Report (ICR) #12,253.
This ICR will be dispositioned to terminate the wiring in Compartment C3 of MCC 3
131X2 in accordance with Wiring Diagram 20E-1-4663C, Rev. N (current drawing).
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Jumper on Point 3 to 3A is in accordance with Wiring Diagram 20E-1-4659A, Figure 2, which is referenced as the internal wiring diagram on 20E-1-4663C.
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.s Corrective Action Taken to Avoid Further Violation The journeyman and inspector responsible for erroneously signing off RWR #789 as. complete are no longer involved in RWR work.
Quality program enhancements through L.K.
Comstock Procedure 4.3.16 Revisions A through F and personnel training since August 1983 when this deficiency occurred have resulted in minimizing these type of human errors.
Two primary examples of these enhancements incorporated in Rev. D were the addition of the RWR Daily Worksheet (Form #232) and the proceduralizing of the color code highlighting of the wiring diagrams.
These changes require the journeyman to describe the work he specifically performed on the worksheet, and highlight the drawings to a prescribed code reflecting past work, present i
work, and items deleted.
These actions result in a more concise record and minimizes potential inspection errors and erroneous documentation similar to that found in this case.
l In addition, construction testing by OAD and system testing by Start-Up assures that installations are in accordance with the applicable design drawings, and that these type of errors are identified and corrected prior to plant operation.
No further corrective action is required.
l Date of Full Compliance ICR #12.253 was completed and closed March 5, 1986.
Full compliance has been achieved.
1400K j
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