ML20153E933
| ML20153E933 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 11/27/1985 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20153E889 | List: |
| References | |
| 0947K, 947K, NUDOCS 8602250207 | |
| Download: ML20153E933 (3) | |
Text
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/D ';Commonwe:lth Edison
) One First Nabonal Plaza. Chicago. Ilhnois -
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-( CJ ' Address Reply to: Post Office Box 767 x
Chicago, Illinois 60690 November 27,.1985 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.
50-456/85-041 and 50-457/85-040 NRC Docket Nos. 50-456 and 50-457
REFERENCE:
(a) J.J.-Harrison letter to C. Reed dated November 1, 1985
Dear Mr. Keppler:
This letter is in response to the inspection conducted by Mr. P.D. Kaufman on August 19 through October 17, 1985, of activities at Braidwood Station.
Reference (a) indicated'that certain activities appeared to be in noncompliance with NRC.
requirements.
The Commonwealth Edison Company response to the Notice of Violatier. is provided in the enclosure.
If you have any further questions on this matter, please direct them to this office.
Very truly yours, D. L. F rrar Director of Nuclear Licensing Enclosure cc:
NRC Resident Inspector Braidwood 0947K G
DEC 2 1985 w as
s COMMONWEALTH EDISON COMPANY Response to Inspection Report 456/85-041; 457/85-040 VIOLATION 10 CFR, Appendix B, Criterion III, as implemented by CECO's Quality Assurance Manual, QR No.
3.0, require, in part, that design changes, including field changes to design documents be controlled and approved by the organization that performed the original design, unless the applicant designates an other responsible organization.
Contrary to the above, the piping contractor, Phillips, Getschow Company performed a design function by modifying several safety-related riser clamps on Main Steam lines inside the Containment for pipe supports 1MSO5007S, IMS06007S, IMS07006S, and 1MS08007S without being directed by or receiving the approval of the responsible design organization prior to implementation of the work.
RESPONSE (456/85-041-01: 457/85-040-01)
The Sargent & Lundy design drawings for component supports 1MS05007S, 1MS06007S, IMS07006S and 1MS08007S required an ITT Grinnell Fig. 40 type B clamp.
It was discovered during installation by Phillips Getschow that ITT Grinnell had supplied Fig. 40 type A clamps instead of the required Fig. 40 type B clamps.
A telephone conversation with ITT Grinnell revealed that 3
the Fig. 40 type 2 clamps were no 1cnger being manufactured and therefore not available.
Verbal conversation with Sargent & Lundy confirmed that the Fig. 40 type B clamps were required for these l
four component supports.
In order to satisfy the requirements of the component support design drawings, Phillips Getschow had to modify a Fig. 40 type A clamp by adding stiffener plates to it thus creating a Fig. 40 type B clamp.
Phillips Getschow created a drawing detai'.ing the addition of the stiffener plates.
The design information sich as weld size, stiffener plate size and location was taken from a ITT Grinnell Load Capacity Data (LCD) Sheet for a Fig.
40 type B clamp which Phillips Getschow had in its possession.
Phillips Gttschow did not submit their drawing detailing the stiffener addition to Sargent & Lundy for review and approval prior to issuing the drawing to the field for the modification of the clamps.
The physical work involved in modifying the clamps was controlled in accordance with Phillips Getschow's approved procedures and properly documented.
i I
s Commonwealth Edison does not believe that the transferring of detailed dimensions from the ITT Grinnell LCD to the Phillips Getschow detail drawing constitutes a design function.
- However, Commonwealth Edison.does agree that in this instance, since the ITT Grinnell'LCD was not a. controlled design document issued by.Sargent
& Lundy to Phillips Getschow for their use, Phillips Getschow should have had their detail drawing reviewed by Sargent & Lundy prior to performing the modification to the clamps.
Subsequent to the NRC Inspector identifying this concern, Phillips Getschow has submitted their drawings to Sargent & Lundy for approval.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Phillips, Getschow initiated Nonconformance Report (NCR) 5973 to resolve this issue.
Commonwealth Edison Project Construction has processed this NCR through the Project Engineering Department.- NCR 5973-was dispositioned " accept-as-is" based on Sargent & Lundy correspondence with ITT Grinnell approving this modification.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION Commonwealth Edison believes this to be an isolated occurrence.
To the knowledge of the Phillips Getschow Engineering Department Supervision, there are-no other cases where Phillips Getschow has modified component supports to fabricate items normally supplied by ITT Grinnell or other hanger material suppliers without prior Sargent & Lundy approvals.
The responsible Phillips Getschow Engineering Supervisor has been made aware of the requirements violated.
No further corrective action is planned.
DATE OF FULL COMPLIANCE Closure of Phillips Getschow NCR 5973 is expected by December, 1985.
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