ML20236U716
| ML20236U716 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/30/1987 |
| From: | Butterfield L COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8712030310 | |
| Download: ML20236U716 (5) | |
Text
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j ^CN Comm:nw;cith Edison
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Address Riply to: Post Office Box 767 Chicago, Ilknois 60690 - 0767 October 30, 1987 Mr. A. Bert Davis Regional Administrator U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
SUBJECT:
Braidwood Station Units 1 and 2 Response to Inspection Reports Nos.
50-456/87-030 and 50-457/87-029 NRC Docket Nos. 50-456 and 50-457 REFERENCE (a):
J. J. Harrison letter to C. Reed dated September 30, 1987
Dear Mr. Davis:
This letter is in response to the inspection conducted by Messrs.
S. A. Reynolds, R. N. Sutphin and T. Tella on August 25 through September 4, 1987 of activities at Braidwood Station. Reference (a) indicated that certain activities appeared to be in violation of NRC requirements. The Commonwealth Edison Company response to the Notice of Violation is provided in the enclosure.
If you have any further questions on this matter, please direct them to this office.
Very truly yours, L. D. Butterfield Nuclear Licensing Manager 1m Enclosure cc: NRC Resident Inspector - Braidwood NRC Document Control Desk 8712030310 871030' l
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ENCLOSURE COMMONWEALTH EDISON COMPANY RESPONSE TO INSPECTION REPORT 456/87030 AND 457/87029 l
l VIOLATION: (456/87030-01; 457/87029-01) 10 CFR Part 50, Appendix B, Criterion VII, as implemented by the Commonwealth Edison Company Topical Report CE-1-A requires that material and equipment conform to procurement requirements and that documentary evidence be available prior to installation or use. Criterion VII also requires that the documentary evidence be sufficient to identify the specific requirements, s
such as codes, standards, or specifications which were met.
Contrary to the above, the permanent record for the purchase of Plate, Valve, Metal Seat (Stores Item 763DO2) indicated that the part was fabricated from material different from that specified in the purchase order.
RESPONSE
Commonwealth Edison agrees with the violation against the receipt of Stores Item #763DO2 (plate, Valve, Metal Seat), for failure to provide complete and adequate documentation (including appropriate engineering evaluation or disposition), to verify that the purchased item met specific material grade requirements (i.e., SA-515-70).
Upon reviewing this matter, we found that a misunderstanding of the technical evaluation, included in the purchase order, led the receipt inspectors to believe that the purchased item material (SA-516-70) met the specific material grade requirements.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED Upon discovery, the discrepant item was placed on hold and another engineering evaluation was requested. The station issued Discrepancy Record 20-87-H365 to document and track the resolution of this discrepancy. These actions were taken to prevent inadvertent use of the nonconforming items.
Upon completion of the engineering evaluation, the item's two-part red tags will be updated to reflect the actual SA-516-70 material supplied. There is no safety significance to this violation since the parts were never installed.
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.. CORRECTIVE ACTIONS TO AVOID PURTHER VIOLATION The-Quality Assurance and Quality Control departments will provide training to QA/QC inspectors concerning this issue. This training is.
expected to prevent recurrence of this item by heightening inspector awareness to technical evaluations and how they are.used in the receiving process.
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'DATE WHEN FULL COMPLIANCE WILL BE ACliTEVED The Quality Assurance and Quality control inspector training is expected to be completed by November 17, 1987.
Resolution and closeout of Discrepancy Record 20-87-H365 is expected to be completed by November 17, 1987.
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. VIOLATION (456/87030-03; 457/87-29-03) 10 CFR Part 50, Appendix B, Criterion XII, as implemented by the commonwealth Edison Company Topical Report CE-1-A requires that measures be established to assure tools, gauges, instruments, and other measuring and I
test devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits.
Contrary to the above, the licensee did not establish measures to adequately control the use of out of calibration measuring equipment; and evaluate the effects on operating equipment.
RESPONSE
In reviewing this program, commonwealth Edison has determined that adequate evaluations have been and are being performed related to out of calibration measuring and test equipment at Braidwood Station. However, commonwealth Edison acknowledges there has been a lack of documentation supporting these evaluations. The following provides a description of the program at Braidwood Station.
When portable measuring and test equipment (M&TE) has been determined to be out of calibration, the equipment is dispositioned per Quality Procedure 12-51 " Control of Measuring And Test Equipment For Operations - Portable Test Equipment"; Quality Procedure 15-51 " Nonconforming Materials, Parts and Components For Operations - Spare Parts and Materials";
Station Procedure BwAP 400-4 " Control Of Portable Measurement And Test Equipment"; and Station Procedure BwAP 400-4T2 " Certified Test Equipment Evaluation".
When a calibration related concern is raised, a search is made of the M&TE's usage since its last calibration certification. A determination is made as to whether the M&TE out-of-tolerance (OOT) functions / ranges were used within the last certification period.
If they were used, it is determined whether the OOT values have caused an instrument to be left out of calibration (OOC). This is done by either checking the last calibration in that function / range or by a mathematical analysis.
If the OOT condition is not sufficient to cause any instrument to be left OOC, no further action is required.
If an instrument is determined to be in an OOC condition it would be recalibrates. These evaluation methods, used at Braidwood Station, are considered to be consistent with acceptable industry practices.
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.,.. CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED Procedure BwAP 40024T2 was revised on September 10, 1987 to specify how evaluations of M&TE are to be performed and documented.
CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOIATION The revision to Procedure BwAP 400-4T2 should ensure accurate, well documented evaluations of M&TE as described above.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Pull compliance has been achieved.
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