ML20215M119

Responds to NRC Re Violation Noted in Insp Rept 50-456/86-52.Review of Subj Violation Based on Encl Summary of Info Presented to NRC at 861118 Requested

ML20215M119
Person / Time
Site:	Braidwood
Issue date:	12/11/1986
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20215M092	List: IR 05000456/1986060 ML20215M119
References
2506K, NUDOCS 8705130094
Download: ML20215M119 (3)

Text

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• hommomwealth Edloon Address Reply to: Poet Omco Box 767 Chcago,IEnos 60690 0767

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December 11, 1986 Mr. James G. Keppler Regional Administrator U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

SUBJECT:

Braidwood Station Unit 1 Response to Inspection Report No. 50-456/86-052 NRC Docket Nos. 50-456 REFERENCE (a): C. J. Paperiello letter to Cordell Reed dated November 12, 1986

Dear Mr. Keppler:

This letter is in response to the inspection conducted by Messr. A. Dunlop, et. al. on September 15 through October 23, 1986, of activities at Braidwood Station. Reference (a) inoicated that

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

Subsequent to the issuance of Reference (a), additional information became available and was presented to the NRC on November 18, 1986. A summary of this information is included in the enclosure. Based on this information Commonwealth Edison requests that the basis for the subject violation be reviewed by your office.

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

Very ruly you

~e D. L. Farrar Director of Nuclear Licensing

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l Enclosure cc: NRC Resident Inspector - Braidwood O 2506r 8705130094 870507 gDR ADOCK 0500 6 gg g l

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Commonwealth Edison Company Response to Inspection Report 456/86-052 l Violation (456/86-052-01) 10CFR50, Appendix B, Criterion XVI, " Corrective Action", as l implemented by the Commonwealth Edison Quality Assurance manual, l Quality Requirement 16.0 and the Braidwood Startup Manual states, in '

part, " Measures shall be established to assure conditions adverse to quality such as ... 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 addition of eductor flow to measured flow for the 1B containment spray pump.

Response

In reviewing this item, additional information became available that was presented to the NRC in a meeting at Braidwood on November 18, 1986. The following is a brief summary of that information. ,

Deficiency EF-ll-12 was submitted to Project Engineering and from Engineering to Sargent & Lundy for review. Their review concluded that no safety-related function was served by the equipment powered from the alternate train; consequently, the design was adequate and would not be changed. Based on the fact that the design was not to be changed, it was considered unnecessary to review the information on the design documents and operator

, procedures and training. Subsequent review of this information has l revealed:

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• The abnormal operating procedure, 1BwOA Elect-2, correctly

, identifies all equipment fed from each instrument panel,

! including those items in the alternate channel.

• Operators are trained on this procedure three different i- times in the training program.

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• The simulator is properly wired.

• The wiring schematics, which would normally be used to i determine sources of power, were correct.

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• That of the 32 instrument feeds which did not comply with l

the usual connection, six had informational notations on the C& ids which were initially viewed as being incorrect.

Subsequent review showed all notations to be correct.

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• These results support the initial determination that a ,

review of all associated documentation for a "use as is" piece of equipment is not required.

Deficiencies EF-ll-K and EF-11-AI were closed stating that the acceptance criteria was 3795 gpm and then calculating total flow. The words closing the deficiency are at least unclear, and may be incorrect. However, the action taken by the Test Review Board and Project Engineering in the post-test review was proper.

First, it is noted, (as it was in the notes in the test) that no acceptance criteria apply for flow from the recirculation sump.

Secondly, the flows and heads are calculated for each point and these points are compared to the required head curve. The pump met the required flow. (This calculation was further complicated by a post-test calibration zero shift on one flow indicator.) The conclusion drawn was that the flow was acceptable with or without the zero shift.

Commonwealth Edison believes that the corrective actions '

taken to resolve the related deficiencies were adequate, although .

the basis for resolution could have been more clearly described in the documentation associated with the deficiencies. No additional action is planned.

In light of this information, it is requested that the basis for the subject violation be reviewed by NRC.

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