ML20203F905
| ML20203F905 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 04/11/1986 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20203F877 | List: |
| References | |
| 1546K, NUDOCS 8604280180 | |
| Download: ML20203F905 (4) | |
Text
(-
/^'N Commonwealth Edison
-[*(
~
'.) One First Nitional Plaza. Chicago, Illinois 1
Address R: ply to: Post Office Box 767 t-Chicago. Illinois 60690 s
April 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 SALP 5 Board Report 50-456/86-001 and 50-457/86-001 NRC Docket Nos. 50-456 and 50-457 Reference (a):
J.G.
Keppler letter to Cordell Reed dated February 26, 1986
Dear Mr. Keppler:
On March 14, 1986, representatives of Commonwealth Edison Company met with you and members of your staff to discuss the SALP 5 Board Report, as transmitted by Reference (a).
Commonwealth Edison Company appreciated the opportunity to discuss this report with you.
We acknowledge your conclusions in Reference (a) that our " regulatory performance at the Braidwood Station was considered to be acceptable during this assessment period" and that our improving " trend continued resulting in improved performance particularly in the three important areas in which you had been rated Category 3" during SALP 4.
Overall, we believe that this is a fair assessment of our performance.
We have reviewed the SALP 5 Board Report in detail and identified certain areas where we felt it appropriate that clarifying comments be entered on the record.
In general, we note that the Commonwealth Edison Company positions regarding each of the violations referred to in the SALP Report have been docketed previously and are not repeated here.
Our previous submittals on those violations include discussion of areas of disagreement between the NRC Staff and Commonwealth Edison.
In the SALP 5 Report, the j
NRC identified one Category 3 in the area of Housekeeping.
Our l
discussion of actions being implemented in that area is included in l
the enclosure.
(
l i
fg D
e o 56 a
l r
--r.
-i,-r g
p,
,.9-9- _ _ _ -_y-s,_-
--_.-.p-e.y-
,7-y
7
~
. We appreciate the NRC Region III Staff's effort toward providing a meaningful characterization of the overall safety performance for the Braidwood Station.
Very truly yours, M cy).
L.O. DelGeorge Assistant Vice President LOD /pav Enclosure cc:
NRC Resident Inspector - Braidwood i.
L COMMONWEALTH EDISON COMPANY' COMMENTS ON BRAIDWOOD SALP 5 BOARD REPORT HOUSEKEEPING AND EQUIPMENT PROTECTION AREA Commonwealth Edison Company has taken various actions over the past two (2) years with respect to housekeeping and equipment protection matters.
These actions include upgrading of Commonwealth Edison Company and Contractor housekeeping and equipment protection procedures, addition of contractor housekeeping personnel as construction conditions change, increased quality control surveillances of specific plant areas where housekeeping and equipment protection is more critical, change out of non-fire retardant lumber to fire retardant lumber and sending numerous correspondence and directives to site contractors outlining specific actions for housekeeping and equipment protection issues.
- Overall, Commonwealth Edison Company considers our housekeeping and equipment protection programs effective for the construction phase of a nuclear project.
Several NRC inspectors have provided positive feedback on the adequacy and improvements in our housekeeping and equipment-protection programs over the last two (2) years.
These improvements in our housekeeping and equipment protection programs have been further acknowledged by independent outside personnel knowledgeable in industrial practices.
While the're have been certain specific violations for inadequate housekeeping and equipment protection issued, we believe these are isolated instances and do not represent a trend.
We continue to believe our construction housekeeping and equipment protection programs are adequate and will continue to improve them as we change the plant status from a construction phase to a test / operational status.
We acknowledge, in light of this transition from a construction phase to a test / operational status, the NRC SALP Board recommendation to increase Commonwealth Edison Company management attention in the housekeeping and equipment protection area.
We believe that the actions taken to prepare for fuel receipt in December, 1985 and to prepare for Integrated Hot Functional Testing in February, 1986 evidence the kind of increased attention-which we had planned as we make this transition.
Commonwealth Edison Company has implemented a plan addressing Braidwood housekeeping and equipment protection transition to operation.
The elements of this plan include the following:
1.
Thorough cleaning and painting of certain plant l
areas and limiting access to those areas.
2.
Removal of excess scaffold, tool boxes, and scrap materials.
j 3.
Bans on eating, newspapers, and cans in specific l
Plant areas.
1 l
,, 4.
Periodic welding lead, drop cord and hose roll-ups.
5.
Implementation of operational plant housekeeping and equipment protection procedures.
6.
Increasing worker awareness of operational plant housekeeping and equipment protection requirements.
Commonwealth Edison believes this plan will achieve the levels of. cleanliness and equipment protection necessary to move from construction to operation.
1546K
-