ML20207L581

Responds to Notice of Violation from Insp Rept 50-456/86-15. Corrective Actions:Procedure 4.3.16 Being Revised in Order to Provide Positive Tracking of Revs to External Field Cables

ML20207L581
Person / Time
Site:	Braidwood
Issue date:	06/06/1986
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
1505L, NUDOCS 8701120246
Download: ML20207L581 (5)

Text

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June 6, 1986 Mr. James G. Keppler Regional Administrator Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Braidwood Station Unit 1 50-456/86-015 NRC Docket No. 50-456

References:

(a) J.J. Harrison letter to C. Reed dated May 2, 1986

Dear Mr. Keppir.r:

This letter is in response to the inspection conducted by Messrs. Z.

Falevits and R. Mendez on March 5 through 21, 1986, 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 Violation is provided in the enclosure. A 5 day extension to the response due date was requested from and granted by Mr. J. Muffett of your office.

If you have any further questions on this matter, please direct them to this office.

Very truly yours, Qh I M D.L. rar I/ ~ Director of Nuclear Licensing

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DLF/ pay Enclosure cc: NRC Resident Inspector - Braidwood 4 o ~7 15051 lg

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i 00fet0NWEALTH EDISON COMPANY RESPONSE TO VIOLATION 456/86015-01 t

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1. 10 CFR 50, Appendix B, Criterion X as implemented by en==artwealth Edison company (Ceco) Quality Assurance Manual, Nuclear Generating Station, Section 10, requires that a program for inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings.

Contrary to the above, NRC inspection revealed that the configuiation of the electrical wiring of Limit Switch 14-14C of valve ICS001A was not in conformance with the applicable drawings, while the Quality control inspection checklist indicated that the wiring was in conformance with the >

i applicable drawing.

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Response

en==arnwealth Edison company (Ceco) agrees that L. K. Comstock (LKC) had not implemented an adequate enough system to tracN outstanding revisions on field cables. The existing system was dependent upon Operational Analysis Department (OAD) testing personnel initiating a specific request to perform the external cr.ble revision in order to gerform testing. The inspection report also indicates a concern that subcequent QC inspections of cables ICSO46 and ICSO47 were performed inadequately. The L.K.

Comstock QC Inspectior Checklist of Electrical Terminations for Cable ICSO46, dated October 18, 1985, and for Cable ICSO47, dated December 23, 1985, as well as the cable Retermination Card QC Inspection for Cable ICSO46, dated October 3, 1985 and the Cable Retermination Card QC Inspection for cable ICSO47, dated December 20, 1985, were specifically

for conductors not related to those which terminate at Terminal Points 21 and 22 of ESF MCC 131XI Compartment B4. The existing (in file) QC inspections for conductors of Cables ICSO46 and ICSO47 which terminate at Terminal Points 21 and 22 dated December 15, 1982 and February 12, 1982, respectively are correct. Quality Control inspections were not performed inadequately.

Corrective Action Taken and Results Achieved J

The conductors at Terminal Points 21 and 22 have been lifted and spared in MCC 131X1 (IAP21E) compartment B4. The conductor for ICSO46 were also

, determinated and spared at valve ICS001A limit switch. This was completed 1 Merch 7, 1986.

External field cable revisions are routinely implemented by OAD to

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facilitate functional testing of a component prior to releasing a system for start-up testing. The unique case of Cables ICSO46 and ICSO47 was the elimination of a limit switch contact from a circuit. This was physically accomplished by the determination of Cable ICSO47 at Panel IPM06J. The 15051

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4 remaining determination (sparing) of the conductors for Cables ICSO46 and ICSO47 would not affect the electrical functioning of the circuit. To assure that field cables are in accordance with the latest wiring diagram revision a review of cable termination documentation is performed prior to System Release to Operations per LKC Procedure 4.13.2. This review would have identified the conditions that existed for cables JCSO46 and ICSO47.

Therefore due to the functional testing by OAD and the documentation review prior to System Turnover to operation no additional corrective action for ccepleted installations is required.  ;

Corrective Action Taken To Avoid Further Violation projsct Construction has requested IEC tb revise procedure 4.3.16 in order to provide a positive tracking of revisions to external field cables.

This procedure will require LKC Engineering to initiate and track e determ/reterm request to OAD for revision to external cables identified on '

wiring diagram revisions. This addition will provide a positive accountability of pending revisions to external field cables.

Date of Full Completion The revision to LKC Procedure 4.3.16 will be complete by June 16, 1986.

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C0fW90NWBALTH EDISON COMPANY RESPONSE TO VIOLATION 456/86r15-02

2. 10 CPP,50, Appendix B, Criterion V as implemented by Commonwealth Edison Company (Ceco) Quality Assurance Manual Nuclear Generating Station, Section 5, requires that the activities affecting quality be accomplished in accordance with documented instructions, procedures, and drawings of a type appropriate to the circumstances.

Contrary to the above, an activity affecting quality was not performed in accordance with documented procedures in that no Revision / Work Request (as called for by LKC Procedure 4.3.16) was written for Revision H of Drawing

, 208-1-4687H.

Response

commonwealth Edison agrees that no Revision / Work Request (RWR) was written for the above identified drawing.

Corrective Action Taken and Results Achieved 1

RWR 813495 was initiated and implemented on 5-9-86 to connect the wiring to relays CRVQ1BX and CRVQ2BX, points 9 and 10, per wiring diagram 205-1-4687H.

L.K. Comstock (LKC) procedure 4.3.16. Revision / Work Request of All Electrical Equipment, utilizes a system of hi-liting the wiring diagram to reflect the status of the equipment wiring. When a new revision to a wiring diagram is sent to the field for work, the hi-liting is transferred from the old wiring diagram to the later revision. In this case cited by the NRC inspector, the individual transferring the hi-liting inadvertently hi-lited the subject wires which had been added by Rev. H. Consequently, a RWR was not issued to perform the connections because the drawing mark ups indicated this wiring was completed.

L.K. Comstock Site Quality Assurance is performing a surveillance on a sample of the wiring diagrams to determine the magnitude of any mis-marking problem. Commonwealth Edison and LKC will evaluate the surveillance results to determine whether the cited instance is an isolated case, or if a generic program will be required to establish the credibility of the hi-liting system. It should be noted that the incomplete wiring of relays CRVQlBX and CRVQ2BX would not have gone undetected, as the circuit would not have passed circuit or system testing performed by construction and Start-Up personnel.

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Corrective Action Taken to Avoid Further Violation i

The past practice of allowing revisions to accumulate prior to initiating a RWR was not in accordance with procedure and has been stopped. A RWR is now issu1d immediately upon receipt of a revised wiring dias, ram requiring construction work. In addition, LKC Procedure 4.3.16 Revision G, Revision / Work Request of All Electrical Equipment, will require an independent review of the marked up drawings to enhance the accuracy of that process. This step should eliminate the type of error that caused this anamoly. The procedure also requires LKC Engineering to maintain a log to keep track of wiring diagram status which supplements the marked up drawings to assure revision incorporation.

Date of Full Compliance The surveillance to determine the adequacy of hi-lited drawings is expected to be completed by June 16, 1986.

The Revision G to L.K. Comstock Procedure 4.3.16 is expected to be submitted for approval by June 16, 1986.

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