ML20214U413
| ML20214U413 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 09/12/1986 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20214U003 | List: |
| References | |
| 2095K, NUDOCS 8609300605 | |
| Download: ML20214U413 (5) | |
Text
__
[}
I One Frat Nabonel Plaza. CNcago, Illinois k "- / Address Reply to: Poet Omco Box 767 V Chcago,lHinois 60600 0767 September 12, 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 Response to Inspection Report No. 50-456/86-025 NRC Docket No. 50-456 Reference (a):
J. J. Harrison letter to Cordell Reed dated July 31, 1986
Dear Mr. Keppler:
This letter is in response to the inspection conducted by Messrs.
T. E. Vandel and T. E. Taylor on May 19-22, 27-30, June 2-13 and July 10-11, 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.
The two week delay in submitting this response was requested from and granted by Mr. W. Little of your staff.
If you have any further questions on this matter, please direct them to this office.
Very truly yours, k D. L. Farr Director of Nuclear Licensing Enclosure cc: NRC Resident Inspector - Braidwood 2095K
$93Sfo@k$bbp SEP 151998 p
G
COMONWEALTH EDISON COMPANY RESPONSE TO INSPECTION REPORT 456/86/025 Violation (456/86025-01) 10 CFR Part 50, Appendix B, Criterion XV, " Nonconforming Materials Parts or Components," as implemented by the Commonwealth Edison Company's QA Program Manual, requires measures to control materials, parts, or components which do not conform to requirements. These measures shall include the identification, documentation and disnositioning of nonconforming conditions.
Contrary to the above, the licensee failed to control some nonconformances between March 1985 and March 1986 during preoperational testing activities and neither identified nor dispositioned nonconforming conditions observed during-this inspection.
Response
The Ceco program for " Test Control" which assures that design and performance criteria have been satisfied is described in Q.R. 11.0.
The method for implementing the test control program for construction tests is covered in Q.P. 11-1 and for pre-operational tests in Q.P. 11-2.
These three (3) documents, together, give guidance on how deficiencies identified during tests should be documented and processed for resolution.
It should be noted that both construction type deficiencies and test deficiencies can be identified during the testing activity and the method for processing construction type deficiencies is different than the method for processing test deficiencies. Also, test deficiencies identified during construction tests are processed in a different manner than test deficiencies identified during pre-operational testing.
For construction type deficiencies such as equipment failures and malfunctions of equipment, Q.R. 11.0 requires nonconformance reports to be written. In addition, for work which has been completed, Q.C. inspected and accepted, and then found deficient, it is required that these deficiencies also be documented on nonconformance reports. Also, construction type deficiencies are processed in the same manner whether they are identified during a construction test or a pre-operational test.
For test deficiencies which result because test data does not meet requirements, Q.R. 11.0 states that, if necessary, the deficiency will be reported as a nonconformance. This statement is referring to two (2) different methods for processing test deficiencies.
The first method occurs during construction tests which is described in Q.P. 11-1.
This procedure provides for the construction Field Engineer to evaluate the test results and, if necessary, initiate t
a nonconformance report.
t i
i l
l
. The second method occurs during pre-operational tests which is described in Q.P. 11-2.
This procedure requires test deficiencies to be identified, documented and classified by the Start-Up Group. The deficiencies are included in the Test Report which is evaluated by the Start-Up Group. The Test Report is then reviewed by the Test Review Board, Start-Up Superintendent, and ultimately Project Engineering. If the test is unacceptable, Project Engineering is responsible for initiating actions necessary for resolution.
The deficiencies identified in this response are required to be processed within the context of this program.
Commonwealth Edison has reviewed the six Startup Deficiency Reports (SDR's) documented in the subject Inspection Report. Based on this review CBCo has determined the following:
Deficiency No.
DG-10-091 We believe this item was properly dispositioned. When the PCD Field Engineer determined that the system was installed per design and a maintenance problem did not exist, the problem was given to Engineering for their review. The problem was finally resolved by relocating the tie in point for an overflow line. Project Engineering resolved this problem by issuing a routing change for the overflow line. A nonconformance report was not required to obtain an 4
engineering review of the problem.
DG-11-092 Same as DG-10-091.
DG-10-102 Same as DG-10-091, i
DG-10-136 This deficiency was issued to document unacceptable initial test results achieved by the System Test Engineer. The Test Engineer reran the test and achieved correct results. The deficiency was used to track the requirement for a retest.
Based on this, we believe this deficiency does not identify a nonconformance.
1 AF-10-338 This deficiency identifies a malfunctioning pressure switch in the AF system. The disposition, which has not been completed at this time, is to replace the pressure switch.
Based on the information known to date and a like for like l
component replacement planned, we believe this is a mdintenance type item, not a nonconformance, f
CC-10-416 We agree that a contractor NCR should have been issued to i
cover this deficiency. Upon identification of this condition, Phillips-Getschow generated deficiency report DR-D4462 which documents that valve ICC9493D was installed backwards. Phillips-Getschow DR-D4462 has been dispositioned and closed. Based on adequate resolution of this issue, we believe that no further action is required.
1
.. In summary, we agree with the NRC inspectors that SDR CC-10-416 was a nonconforming condition. The other SDR's do not reflect nonconforming conditions.
In addition, we reviewed deficiency number CX-10-231. We agree that the engineering review was not complete in that the System Test Engineer misinterpreted the response by Westinghouse and the Test Review Board did not review the results. The sequence of events was as follows:
In 1982 the initial pump run was made. Flow was 26,200 gpe, approximately 2,200 gym over pump maximum flow. The motor current was 171 amps, over the motor current maximum of 150 amps.
In 1984, the test for SX-10 was begun and on one motor start current was reported over 157 amps and the pump was tripped. Site Westinghouse NOD was apparently asked if running the pump at greater than 157 amps would damage the motor. Westinghouse responded that the service factor was 1.15 and that "you may run the motor with current 1.15 times the full load" (approximately 180 amps). A warning was attached concerning use of winding temperature detectors and a statement that winding temperature was the limiting condition. The System Test Engineer evidently took this to mean that the motor could be run continously at 180 amps. In early 1985, Site Quality Assurance reviewed the initial run documentation and issued deficiency SX-10-231.
The System Test Engineer closed the deficiency, attaching the Westinghouse response, apparently in the belief that the question had been previously answered in this response and no second asking of the question was necessary.
It is our position that the Westinghouse response, in its entirety is sufficient for the few, separate instances in which the pump was operated above 157 amps, and that no pump damage occurred. The pump is presently operating at about 130 amps.
Because of this no non-conforming condition exists, either in design or material. This particular deficiency was not reviewed by the Test Review Board because it was closed. The corrective action described should prevent such an oversight in the future.
It is CBCo's opinion the vast majority of SDR's reflect maintenance type items, incomplete construction and minor construction damage rather than nonconforming conditions which warrant the processing of an NCR. CBCo Quality Assurance has performed Surveillance #5866 to determine if SDR's are being properly identified as NCR's when appropriate.
The surveillance reviewed 1,960 SDR's.
From the 1,960 SDR's thirty-five (35) SDR's were identified that could possibly warrant an NCR. A detailed review of each of the thirty-five (35) SDR's verified that they had been properly handlel and a NCR had been utilized when the circumstances warranted. Based on the results of this surveillance no further retrospective review will be performed.
)
f
.. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The Project Start-Up Superintendent has directed the Test Review Board to review for nonconforming conditione, safety-related Test Results which have already been approved. The scope of this includes all deficiencies (open and closed) that had not been routed to Project Construction Electrical or Mechanical groups. This review is expected to be completed by September 30, 1986.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION l
The Project Construction Field Engineers resolve the majority of the SDR's.
A training session was held with these groups to reaffirm their responsibility to include identification of nonconforming conditions as part of their SDR review.
In addition, the training matrix for the Project Construction Field Engineers will be revised to require annual training to cover the review of SDR's for nonconforming conditions.
Effective August 20, 1986, the Project Startup Superintendent has directed the Test Review Board to review all deficiencies (open and closed) not routed to Project Construction Electrical or Mechanical groups for non conforming conditions. This review is to occur as part of the Test Results review by the Test Review Board and be documented in the Test Results evaluation.
DATE OF FULL COMPLIANCE Full compliance should be achieved by September 30, 1986, 2095K i
-.. _..,, _.,,., - _.. _ _ _ _ _ _ _ _, ~ _, _., _ _ _. _. _ _ _
. - _.