ML20214E059

Responds to Violations Noted in Insp Repts 50-373/85-34 & 50-374/85-35.Corrective Actions:Junction Box Covers Reinstalled & Broken Flexible Conduits & Insulation Panels Repaired.Items 2 & 3 Should Be Withdrawn

ML20214E059
Person / Time
Site:	LaSalle
Issue date:	02/14/1986
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20214E057	List: IR 05000373/1985034 ML20214E059
References
1290K, NUDOCS 8603070025
Download: ML20214E059 (6)

Text

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. 'N Commonwealth

=

Edison

) One First National Plaza. Chiccgo, lihnois O Address Riply to. Post Office Box 767 Chicago, Illinois 60690

-February 14, 1986 Mr. James G. Keppler Regional Administrator  :

i U.S. Nuclear Regulatory Consission l Region III 799 Roosevelt Road l Glen Ellyn. IL 60137 i

Subject:

LaSalle County Station Units 1 and 2 j Response to Inspection Report Nos.  ;

50-373/85-034 and 50-374/85-035 '

NRC Docket Mos. 50-373 and 50-374 I t

i Reference (a): C. J. Paperiello letter to Cordell Reed  !

4 dated December 6, 1985. l 4

r

Dear Mr. Keppler:

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

Z. Falevits, P. Wohld and R. Smeenge on October 21-23, 30-31 and November 1,

1985, of activities at LaSalle County Station. Reference (a) indicated that  !

certain activities appeared to be in noncompliance with NRC requirements.  !

j The Connonwealth Edison Company response to the Notice of Violation is provided in Attachment A.

,I

! Conunonwealth Edison disagrees with the basis for the Notice of Violation on items numbered IR 373/85-034-02 and IR 50-373/85-034-06/

j 50-374/85-033-05. We request you review your conclusions in light of the

additional information provided in this report.

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

4 l

Very t ly yours, j

/ i D. L. Farrar l

Director of Nuclear Licensing j 1m Attachment i

j cc: NRC Resident Inspector - LSCS 1290K 8603070025 86030333 PDR ADOCK 050 O

FEB 18 1936

ATTACHMENT ITEM OF NONCOMPLIANCE 10 CFR 50, Appendix B, Criteria XVI, as implemented by Commonwealth Edison Company Quality Assurance Manual Nuclear Generating Stations, Section 16, requires that measures shall be established to assure that conditions adverse to quality such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.

Contrary to the above, during the drywell inspection of Units 1 and 2 the following examples of conditions adversed to quality were identified,

s. Nine damaged flexible conduits

b. Damaged and loose mirror insulation panels with gaps in the joints, a condition that could cause localized hot spots.

c. Missing covers on two right angle pull boxes.

d. Missing protective connector caps on spare solenoids of the Safety Relief Valves (SRVs)

e. Opening in zipper tubing and loose hose clamps at the SRVs

f. Missing and loose cover bolts on various limitorque valve operators-

g. Metallic grinding products on a limitorque valve stem screw

h. Loose materials found in limitorque valve switch compartment.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED As a result of the drywell inspections which were conducted, extensive corrective actions were identified and implemented. Junction box covers were reinstalled, broken flexible conduits were repaired and the insulation panels were inspected and repaired. All the limitorque valves were inspected as part of another' inspection effort. During this inspection the valves were cleaned and all the covers reinstalled.

4 CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE The work request procedure, LAP-1300-1 was reviewed to determine if the post-completion inspection guidance was adequate. While this procedure does provide for an inspection after the work is completed, additional guidance will be provided to ensure that the area around where the work is performed and which may not have been part of the scope of work in the work package is included in the inspection.

DATE OF FULL COMPLIANCE LAP-1300-1 will be revised by March 31, 1986.

t f

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APPARENT ITEM OF NONCOMPLIANCE 10 CFR 50, Appendix B, Criteria V, as implemented by Commonwealth Edison Company Quality Assurance Manual, Nuclear Generating Stations, Section 5 requires that activities affecting quality be performed in accordance with documented instructions and procedures of a type appropriate to the circumstances.

Contrary to the above, the following example of failure to follow Ceco Wiring Standard, C-2325 were identified:

Note 12 of C-2325 states that not more than two wires shall be connected to any one stud. Limitorque operators on valves 1E12-F052B, IVQO34, 2E22-F004, 2VP114A, 2WR029, and 2WR040 were found to have three wires connected to one stud.

DISCUSSION AND ADDITIONAL INFORMATION Commonwealth Edison believes this is not a violation based on the following information.

LaSalle County Station contacted the Station Nuclear Engineering Department (SNED) and the Station Electrical Engineering Department (SEED) l to determine the basis for Edison Standard C-2325. Their investigation revealed that the specification restricts the number of wires connected to a stud or terminal for shop wired equipment to two. This restriction does not 4 apply to field installs.tions. The restriction for shop wired equipment was made to ensure that the vendor did not make more than two connections to any l given stud or terminal so that additional connections could be made in the field after the equipment had been received.

In addition, SEED determined that this specification was originally developed to apply to switchboard panel installations where connections are made to terminal blocks. In these cases, it would be difficult to connect a large number of wires to a particular terminal and still maintain good electrical connections. In the case of the identified limitorque operators, limit switch finger subassemblies are used which contain studs widely separated from each other. Lug connectors are attached to a stud and then secured by a nut. The lug connectors can be attached to the stud at different angles, thereby allowing good electrical contact.

Through additional discussions with the Region, an additional inspection concern was identified. The inspector had a concern that, with three terminals on a given lug, the nut could not be tightened down sufficiently to ensure a good electrical connection.

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In discussions with the foremen in the shop that had done actual' field inspections, none of them could recall any circumstances where there was any doubt as to the tightness of the nut on top of the lugs. Their recollection was that all lugs were down tight with the top of the lug protruding through the nut. Although this was not an attribute that was included on the checklist, we feel confident that all field wiring is adequate.

Based on this additional information, we believe Appendix B, Criterion V, was met in these instances and we request the apparent item of noncompliance be withdrawn.

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APPARENT ITEM OF NONCOMPLIANCE 10 CFR 50, Appendix B, Criteria VIII, as implemented by Commonwealth Edison Company Quality Assurance Manual, Nuclear Generating Stations, Section 8, requires measures to be established for the  ;

identification and control of materials, parts and components.

Contrary to the above, the Unit 1 SRV adjacent to 1B21-F013J has no identification markings. The remaining Unit 1 SRVs did not have permanent identification marking such as metal stamping or tags.

]

DISCUSSION AND ADDITIONAL INFORMATION

commonwealth Edison believes this is not a violation based on the

! following additional information.

1 All SRVs at LaSalle County Station have original name tags

, containing the manufacturers identification number. SRVs utilized l at the station will be in a given location for a cycle. They will generally be removed for testing following that cycle and then reinstalled. The solenoids for any of those SRVs that are removed, i are then returned to the original location from which they have been taken. The solenoids thus remain in one given location to maintain

! environmental qualification tracking separately from the SRVs.

Commonwealth Edison does not desire to place the same type of valve t tags on these SRVs that are placed on other equipment, primarily for ease of operator identification of valves which can be manually operated. It is felt that a potential hazsed could exist if a valve was installed in another location with its original tag remaining on it, e

, thereby confusing an operator. Also, if a tag was not removed from a valve when the valve was removed from the system and the valve was

< subsequently reinstalled in another location with a second tag attached to it, considerable confusion could exist. Since the valves have no means of being capable of being operated manually by an operator, we do

! not feel that putting valve number tags on them would serve any operating purpose. In fact, it could create a problem if control were lost of the tags which could cause confusion of people in the drywell, possibly resulting in increased radiation exposure or disabling of an incorrect component.

For removal and replacement of the SRVs or any type of maintenance work done on them, the mechanic is provided with a drawing that shows the specific location of the valve that he is to work on in relation to other components located in the immediate vicinity. Using this drawing, referencing the other components in the area and by having the manufacturers identification number which can be read off the installed

nameplate, the mechanic can be sure that he is working on the 1 appropriate valve before doing any maintenance or removal. We believe j this meets the requirements of Appendix B, Criteria VIII, for measures to identify and control these valves, and we request the apparent item j of noncompliance be withdrawn.

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