ML20214E125
| ML20214E125 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 02/19/1986 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1324K, NUDOCS 8603070131 | |
| Download: ML20214E125 (4) | |
Text
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x Commonwe:lth Edison
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) One First Nrtional Plaza. Chicago. Illinois
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': ~2 Address R: ply to Post Office Box 767 Chicago,. Illinois 60690 February 19, 1986 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Cottunission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
LaSalle County Station Units 1 and 2 Response to Inspection Report Nos.
50-373/85-039 and 50-374/85-040 Amended Response NRC Docket Nos. 50-373 and 50-374 References (a):
J. J. Harrison letter to Cordell Reed dated January 10, 1986.
(b):
D. L. Farrar letter to J. G. Keppler dated February 10, 1986.
Dear Mr. Keppler:
This letter is in response to the inspection conducted by Messrs.
Z. Falevits and R. Mendez, on November 20 through December 20, 1985 of activities at LaSalle County Station. Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements. The original Commonwealth Edison Company response to the item of noncompliance was provided in reference (b).
It has come to our attention that the initial response did not contain sufficient detail and included an inaccurate statement. A complete, amended response is provided in the attachment to this letter. This transmittal supersedes the earlier response in its entirety.
If you have any further questions on this matter, please direct them to this office.
Very truly yours, 8603070131 860219 PDR ADOCK 05000373 O
PDR D. L. Farrar Director of Nuclear Licensing im Attachment cc:
NRC Resident Inspector - LSCS 1324K sQ FEB 0 01986 V dcy
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ATTACHMENT ITEM OF WONCOMPLIANCE 10 CFR 50, Appendix B, Criterion V, as implemented by Commonwealth Edison Company (CECO) Quality Assurance Manual. Nuclear Generating Station, Section 5, requires that activities affecting quality be performed in accordance with documented instructions and procedures of a type appropriate to the circumstances.
The Maintenance / Modification procedure for LaSalle generic Work Request (WR) 52489, states in part, "Describa work to be performed, and identify by revision and or date, the applicable procedures / drawings /
traveler... to be used.... complete all documentation requirements requested by this Work Request."
Contrary to the above, the following examples of failure to follow procedures were identified.
a.
Inspections of internal wiring inside approximately 70 motor operated valves (MOV's) limit switch compartments were performed.
However, the inspection records of the valves that were reinspected failed to reference a schematic drawing or connection diagram and revision and/or date.
b.
The licensee failed to document correctly or omitted documenting jumpers on terminations which were shown on schematic and connection diagrams. For example, jumpers which were shown on the latest design drawings were noted By CECO inspectors on the work request documents as not applicable (N/A) or they were not documented.
The following examples were identified:
The jumper on valve 2E12-F004C between limit switch points 7 to 17 were shown as being connected on schematic diagram 1E-2-4220AX and on wiring diagram 1E-2-4392AA. This was documented as "N/A" on the station traveler. Consequently, it was not appropriately identified and inspected.
On valve 2E21-F005, Connection points 13 to 17 were shown on schematic diagram 1E-2-4221AB and wiring diagram 1E-2-4389AD.
The station traveler for this valve was marked "N/A".
Consequently, they were not appropriately identified and inspected.
The jumper on valve 2E12-F004B between points 17 to 7 was shown on connection diagram 1E-2-4391AA and schematic diagram 1E-2-4220AZ but was not documented as being verified on the station traveler. Consequently, they were not appropriately l
identified and inspected.
.l e'.
The jumper on velve 2B21-F067C, between points 17 and 14 was shown on connection diagram 1E-2-4387AL and schematic diagram 1E-2-4387AL.
This was documented as "N/A" on the station traveler and consequently was not appropriately identified and inspected (for additional details see Section 2.a.).
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED A review of all records generated during the initial stages of the a.
limitorque inspection was conducted by individuals other than those i
performing the inspection.
During this review all discrepancies in the inspection packages were identified and corrected. An actual reinspection of the valves in the field was performed only to resolve a discrepancy noted during this review. The discrepancies identified were incomplete drawing references, lack of documentated jumper inspection, and reference prints which were not in the package. The inspection packages include all reference drawings, 6
the revision, and revision date.
b.
The review of the inspection packages identified some valves which required reinspection due to lack of documentation of all jumper wire installations.
Further guidance was developed to document all jumper inspections. The valves which were identified as having discrepancies in the inspection records for jumper installation were then reinspected.
During this inspection no jumpers were found to be unacceptable.
During a revisw of the records to verify all examples of improper documentation had been addressed, it was noted that valve 2E51-F008 was indicated as having a discrepancy in the inspection report.
During the review of the documentation package this discrepancy was not detected and no further reinspec-tions performed at that time. After this discrepancy was noted a work request was written to perform a reinspection to verify a qualified jumper was in place. This inspection verified that the jumpers installed were of qualified material.
The jumper was subsequently replaced during the inspection as a preventive maintenance action when it was noted that the wire has some broken strands. These broken strands did not effect the operability or the qualification of the valve operator.
Two other jumper wires were replaced which were not clearly identified to the satisfaction of the new inspection team. These jumpers were verified to be a qualified wire type however, after removal. All inspection records of the valves which did not require reinspection have been audited to verify no further discrepancies exist. This audit resulted in no further corrective actions. All Unit 2 valves are satisfactory.
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,. CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE The Maintenance Department has instructed electrical maintenance personnel in adequate documentation of work activities.
DATE OF FULL COMPLTANCE All inspections performed or scheduled to be performed have utilized or will utilize the revised documentation requirements. Full compliance has been achieved.
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