ML20204F513

Responds to NRC Re Violations Noted in IE Insp Repts 50-456/82-08 & 50-457/82-08.Corrective Actions: Grounding Connection Removed,Floor Drains Cleaned & Foreign Matl Removed from Cable Pans

ML20204F513
Person / Time
Site:	Braidwood
Issue date:	03/16/1983
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20204F496	List: IR 05000456/1982008 ML20204F513
References
6201N, NUDOCS 8305020115
Download: ML20204F513 (9)

Text

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Commonwealth

/ One First National Plaza, Chicago. Edison Address Reply to: Post Office Box 767 Illinois Chicago, lifinois 60690 March 16, 1983 Mr. James G. Keppler, Regional Administrator Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 l

Subject:

Braidwood Station Units 1 and 2 Response to IE Inspection Report Nos.

50-456/82-08 and 50-457/82-08 NRC Docket Nos. 50-456/457 Reference (a): C. E. Norelius letter to Cordell Reed dated February 14, 1983

Dear Mr. Keppler:

f Reference (a) provided the results of an inspection conducted by Mr. L. G. McGregor of your of fice during the period between September 10 and December 31, 1982, of activities at our Braidwood Station. During that inspection, certain activities appeared to be in noncompliance with NRC requirements. The 3 Attachment to this letter provides the Commonwealth Edison Company response to the Notice of Violation as appended to Reference (a).

To the best of my knowledge and belief, the statements contained in the Attachment are true and correct. In some respects

these statements are not based on my personal knowledge but upon information furnished by other Commonwealth Edison employees and consultants. Such information has been reviewed in accordance with Company practice and I believe it to be reliable.

l Please address any questions that you or your staff may l

have concerning this matter to this of fice.

i l Very truly yours,

_, ,7 7 -

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Dennis L. Farrar Director of Nuclear Licensing EDS/ rap Attachment cc: .RIII Inspector - Braidwood 620lN MAR 171983 830502011b 830425 ___

PDR ADOCK 05000456 G PDR

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ATTACHMENT Response to Notice of Violation Violation 1 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants states in part:

" Criterion XIII, Handling, Storage, and Shipping... Measures shall be established to control... cleaning and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration."

ANSI N45.2.3 states, in part: "The control of all tools, equipment, materials, and supplies that are used shall be maintained to prevent the inadvertent inclusions of deleterious material or objects in critical systems".

Commonwealth Edison Quclity Assurance Program Section 13 states, in part: " Written instructions for handling, preservation, storage, and shipping will be used to specify protective conditions necessary to prevent damage or degradation of material and equipment. The Project Construction or Station Construction Department Field Engineer, as applicable, provides surveillance of the field activities of assigned contractors to verify the application of instructions to the equipment.

Inspections and audits are conducted to verify compliance with the plan or procedures and other requirements by Edison Quality Assurance."

Contrary to the above, the licensee failed to provide surveillance for field activities and permitted the following violations:

a. Welding operations of an assigned contractor was utilizing safety related equipment, accumulator 2SIO4TC, as the grounding connection for a welding machine (Miller Welding Model SRH 333, Serial No. HJ 125830).

Response 1.a Corrective Action Taken and Results Achieved The grounding connection was removed by the area general foreman as soon as he was notified about the connection.

Corrective Action Taken to Prevent Further Noncompliance The welding machine that was grounded to the tank was used by the electrical contractor. It could not be determined who the individual was that connected the ground; therefore the electrical contractor will instruct all of his people that equipment shall not be used for welder ground connections.

Date When Full Compliance Will Be Achieved March 18, 1983.

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b. Wood scaffolding planks (2"x8"x8") are being stored in safety related electrical cable trays (1889A-P2E and 1888Q C'18) located in the auxiliary building.

Response 1.b Corrective Action Taken and Results Achieved The wood scaf folding planks have been removed.

Corrective Action Taken to Prevent-Further Noncompliance Housekeeping procedures have been initiated to keep cable pans clean from all foreign material.

Date When full Compliance will be Achieved Completed

c. Rain water was permitted to leak through into safety related electrical cable trays (1515 BCIE and 1515 APlE) and on the Residual Heat Removal Pump, IRH0lPA.

Response 1.c Corrective Action Taken and Results Achieved The water that was leaking througn a deck cover above the pump was due to a plugged floor drain in the elevation above the pump. The floor drain has been cleaned.

Corrective Action Taken to-Prevent Further Noncompliance A housekeeping procedure has been initiated and it is expected that this will assure that floor drains are kept clean.

Date When Full Compliance will Be Achieved Completed.

1 3-1 . .

. Violation 2 I 10 CFR 50, Appendix B, Criterion III, Design Control, states, in I part: " Measures shall be established to assure that applicable regulatory requirements and the design bases for those structures, systems, and componets.to which.this appendix applies are correctly translated into specifications, drawings, procedures,.and instructions. These measures shall include provisions to assure that appropriate quality standards are 1 specified and included in design documents and that deviations from such standards are controlled. Design. changes, including field changes, shall be subject to design control measures commensurate with,those applied to the original design and  ;

approved by..."

The Braidwood FSAR, Appendix A, page Al.64-1 commits to compliance with-Regulatory Guide 1.64 which endorses ANSI ,

N45.2.ll-1974. ANSI 45.2.11 states, in part

" Documented procedures shall provide for affecting design changes to '

approved design documents,: including field changes, which assure

, that the impact of the change is carefully considered, required actions documented and information concerning the change is

transmitted to all affected persons and organizations.

I 1

CECO. Quality Assurance Program for Nuclear Generating Stations, Commonwealth Edison Company Topical Report CE-1-A, Section 3.0, Quality Requirement, QR 3.3 states, in part: "

The Station Nuclear Engineering Department assigns an organization to verify installation of modifications in accordance with design and quality assurance requirements."

Contrary to the above, the licensee failed to perform a design "as-built" review:or establish an inspection of an Engineering Change Notice (ECN) No. 1879, to assure that these design control measures were commensurate with those applied to the

original design.. The NRC inspector observed a Swing Check

- Valve, No. 1CV 8466A, rotated approximately twenty-five degrees

from its horizontal position. The operability of this 1500 psia safety related swing check valve was compromised by actions resulting from work accomplished under this ECN. I f Response l

Corrective Action Taken and Results Achieved The check valve.1CV8466A will be put in the horizontal position.

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Corrective Action Taken to Prevent Further Noncompliance In our. judgement, this was an isolated incident. ECN 1879 required that valve 1CV8467A be rotated from the horizontal position. The general foreman in charge of the work did not observe that the check valve 1CV8466A was rotated at the same time. The general foreman was also instructed to review completed work more carefully.

Date When Full Compliance Will be Achieved March 18, 1983.

Violation 3 10 CFR 50, Appendix B, Criterion VI, Document Control states, in part:

" Measures shall be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting quality".

ANSI N45.2-1977 states, in part: "Those participating in an activitly shall be made aware of and use proper and current instructions, procedures, drawings, and engineering requirements for performing the activity. Document control measures shall provide for identifying the proper documents to be used in performing the activity, coordination and control of interface documents and ascertaining that proper documents are being used."

Commonwealth Edison Quality Assurance Procedure No. 3-2, Section 4.6 states, in part: "The Site Quality Assurance Superintendent or Station Quality Assurance Engineer / Inspector monitors site or station generated requests for changes in design, assures satisfactory disposition of FCR's, assures that the latest design documents are being used by the site or station organizations and contractors and assures that resultant design changes are incorporated into the project drawings and documents, as appropriate".

Contrary to the above requirements, the NRC inspector noted discrepancies between copies of the field drawings used for construction of the chemical volume control system and copies of the same drawings located at the licensee's construction office. Review of sixteen of the twenty drawings disclosed serious inconsistencies between the same drawing.

Response

We havn reviewed the specific details of this violation. The following are the results of our review and reference is provided to the same sheet numbers of Drawing M-546 as were noted in the details of the Inspection Report.

Sheet No. 1 ECN 1964 does not apply to Sheet I. Need not be stamped on Rev. S. ECN 1731 was superseded by ECN 1787 incorporated on Rev. M. Need not be stamped on Rev. S. Rev. T was received on 11/17/82, the approximate time of the audit by NRC.

Comment The inspector cited the Construction Field Drawing as being outdated. The new revision had just been received in the Licensee's office but was not out in the field yet. Some time must be allowed to distribute drawings to the field.

Rev. T should not have been stamped with the ECNs noted.

In our judgement, the reverse was true. The stamps did not need to appear on the field drawings. We believe that this does not affect the quality of the installation. Doing so could needlessly consume time by referencing documents that no longer apply.

Sheet No. 2 FCR 1669 was superseded by FCR 1899 incorporated in Rev. S. Meed not be stamped on field drawing. See comment on Sheet 1.

Sheet No. 3 No problem identified.

Sheet No. 4 IR's are Information Requests asking S&L for information and need not be stamped on Licensee's drawings.

Rev. T has been superseded and is no longer in the Licensee's office. Therefore, we cannot check for lack of FCR 5616 stamp.

Sheet No. 5 FCR 2698 stamp was inadvertently omitted from Licensee's

! drawing. It is now affixed.

Sheet No. 6 l No problem identified.

l Sheet No. 7 l

l DRN's (Drawing Revisions) are not quality control documents l and are not used for installation. They are strictly administrative, providing notification in advance of changes to be made so that work can be scheduled to avoid rework. There is no need to stamp them on Licensee's drawings.

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1 Sheet-No. 8 ECN 1972 does not apply ~to Sheet 8. No need to be stamped.. ENC 1964 was incorporated on Rev..N. Need not be stamped.on Rev. P. See comment on. Sheet 1.

Sheet No. 9 j No need to stamp DRN. See comment on Sheet 7. ECN 3685 i does not apply to this sheet. Need not be stamped.. See  ;

comment on Sheet 1.

Sheet No. 10 ECN 1858 incorporated on Rev. N. No need to stamp Rev. S.

See comment on Sheet 1.

Sheet No. 11-No need to stamp DRN's. See comment on Sheet 7. ECN 1999 does not apply.to Sheet 11. No need to stamp on field drawing. See comment on Sheet 1. FCR 3633 - Stamp inadvertently omitted from Licensee's. drawing. It is now affixed.

I Sheet-No. 12' l No problem identified. ,

Sheet No. 13 f j DRN's need not be stamped. See comment on Sheet 7. FCR

, incorporated on Rev. L. No need to stamp. See comment on Sheet 1.

Sheet No. 14 ECN 1828 incorporated in ECN 1805 which was incorporated on Rev. R. No need to stamp Rev. U. See comment on Sheet 1.

Rev. V. was issued 10/27/82, about the time of the NRC audit. See comment on Sheet No. 1.

Sheet No. 15 No problem identified.

t Sheet No. 16 l DRN's need not be stamped. See comment on Sheet 7.

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Sheet No. 17 FCR 4214 incorporated in Rev. R. No need to stamp Rev. R.

See comment on Sheet No. 1.

Sheet No. 18 DRN 994-The Licensee does not use such a stamp. See Comment on Sheet 7. DRN 875 - Licensee does not stamp.

See comment on Sheet 7. FCR 3629 - incorporated in Rev.

P. No need to stamp on Rev. R. See comment on Sheet No. 1.

Sheet No. 19 No need to stamp DRN on Licensee drawing. See comment on Sheet 7. Rev. M is not outdated as cited. See comment on Sheet 1.

Sheet No. 20 "CRN" - Probably means DRN. No need to stamp DRN's. See comment on Sheet 7. Rev. P not outdated. See comment on Sheet No. 1.

The results of our detailed sheet-by-sheet review indicate that only two (2) of the 32 discrepancies cited appear to be valid, i.e. FCR 2698 on Sheet 5 and FCR 3633 on Sheet 11. In our judgement, the results of our review do not support the conclusions reached by Region III concerning this item, nor Region III's characterization of this item, i.e. that " serious deviations and inconsistencies" exist in these drawings and that " construction personnel are using outdated prints". We further believe that this violation is unwarranted.

Based upon our conclusions reached above, the following corrective action is so documented.

Corrective Action Taken and Results Achieved We have stamped Sheets 5 and 11 with FCR 2698 and 3633, respectively.

Corrective Action Taken to Avoid Further Noncompliance Continued surveillance of document control activity.

Date When Full Compliance Will Be Achieved Completed.

620lN A