ML20215L701

Responds to NRC Re Violations Noted in Insp Rept 50-456/87-52.Corrective Actions:Test Review Board Training Completed & Second Independent Project Engineering Review Process Implemented

ML20215L701
Person / Time
Site:	Braidwood
Issue date:	06/03/1987
From:	Farrar D COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8706260150
Download: ML20215L701 (3)

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') Commonwealth Edison One First Nation 11 Plaza, Chicago, Illincis

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' T <2 Address Reply to: Post Offic) Box 767 N._ / Chicago, Illinois 60690 0767 I

i June 3, 1987 Mr. A. B. Davis Regional Administrator U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road j Glen Ellyn, IL 60137 1 l

Subject:

Braidwood Station Unit 1 Response to Inspection Report l No. 50-456/86-052 i NRC Docket Nos. 50-456 l Reference (a): C. J. Paperiello letter to C. Reed dated November 12, 1986 (b): D. L. Farrar letter to J. G. Keppler dated December 11, 1986 (c): N. J. Chrissotimos letter to C. Reed j dated May 7, 1987 I i

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Dear Mr. Davis:

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This letter is in response to the inspection conducted by Messrs. l A. Dunlop, et. al. on September 15 through October 23, 1986, of activities j at Braidwood Station. Reference (a) indicated that certain activities appeared to be in violation of NRC requirements. Reference (b) responded to f the Notice of Violation requesting that the bases for the violation be j reviewed. Reference (c) documented your staff's review of the violation. j The violation was downgraded to a Severity Level V and a response requested j i

to address the generic concern of inadequate corrective actions in evaluating deficiencies. Our response is contained in the enclosure.

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

1 Very ly yours, I i

8706260150 870603 6 .

gDR ADOCK 0500 *wm D. L. Farrar Director of Nuclear Licensing

)i Enclosure cc: NRC Resident Inspector - Braidwood g i

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Commonwealth Edison Company {

I Response to Inspection Report 456/86-052 i Violation (456/86-052-011 l l

10CFR50, Appendix B, Criterion XVI, " Corrective Action", as implemented by the Commonwealth Edison Quality Assurance Manual, Quality Requirement 16.0 and the Braidwood Startup Manual states, in part, " Measures ,

shall be established to assure conditions adverse to quality such as ... l deficiencies ... are promptly identified and corrected". '

Contrary to the above, the corrective actions taken to resolve deficient conditions were not adequate to correct the following deficiencies:

(a) For EF-ll-12 which was closed on May 28, 1986, there was no documented support for reviewing how this condition affected drawings, procedures, operator training, FSAR/SER commitments, and applicability to other units (Braidwood Unit 2 and Byron Units 1 and 2);

(b) EF-ll-K and EF-ll-AI which were closed on May 27, 1986 and June 2, 1986 respectively, were incorrectly closed by the l addition of eductor flow to measured flow for the 1B containment spray pump.

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Response

l We have reviewed your staff's letter dated May 7, 1987 and note i that they have concluded that the technical issues associated with the l

deficiencies identified in Inspection Reports 456/86052 and 456/86060 had )

been resolved. Only the concern with evaluating deficiencies remains at issue. However, Commonwealth Edison still disagrees that the deficiencies cited constitute a violation based on the generic concern of inadequate I corrective actions in evaluating deficiencies. Although the words closing I

the deficiencies may have been marginal, we believe that the evaluations I conducted by the Test Review Board and project Engineering in the post-test review were adequate. The only apparent problem is that the basis for resolution could have been more clearly described in the documentation associated with the deficiencies. Since it is unlikely that further discussionc will alter these differing views, we have implemented the following corrective action.

(52982)

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Corrective Action Taken and Results Achieved I

The Test Review Board (TRB) Supervisor reviewed the NRC concern at a weekly System Test Engineer Staff Meeting to increase their awareness of the importance for accurate documentation of ali corrective actions. A specialized training / discussion session was conducted to increase the TRB members' sensitivity to the completeness and technical accuracy of the corrective action documentation.

Corrective Action Taken To Avoid Further Violation Project Engineering had previously_ instituted a second independent review of executed Unit 2 preoperational test results (including deficiencies). This review also includes an independent overview of test .

results by the Corporate Nuclear Safety Department to assess regulatory j compliance. ,

Date of Full Compliance TRB training has been completed. The second independent Project Engineering review process has been implemented. Full compliance has.been achieved.

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(52982) i