ML20080S728

Responds to NRC 830830 & 1021 Ltrs Re Violations Noted in IE Insp Rept 50-374/83-36.Corrective Actions:Sblc Sys Terminations on Terminal Blocks in Main Control Room & Local Panel Will Be Reviewed

ML20080S728
Person / Time
Site:	LaSalle
Issue date:	12/30/1983
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20080S684	List: ML20080S713 ML20080S728
References
7838N, NUDOCS 8402290232
Download: ML20080S728 (5)

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'N Commonwealth Edison

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) One First National Plaza. Chicago, Ilknoes t(?

J Address Reply to. Post Office Box 767 Chicago, Illinois 60690 j

December 30, 1983 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

LaSalle County Station Unit 2 Response to Inspection Report No. 50-374/83-36 NRC Docket No. 50-374 Reference (a):

W.

S. Little letter to Cordell Reed dated December 1, 1983.

Dear Mr. Keppler:

This letter is in response to the inspection conducted by Messrs. I. Ahmed, R. Mendez, Z. Falevits, and K. R. Naidu on August 30 through October 21, 1983, of activities at LaSalle County 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.

To the best of my knowledge and belief the statements contained herein and in the attachment are true and correct.

In some respects these statements are not based upon my personal knowledge but upon information furnished by other Commonwealth Edison employees.

Such information has been reviewed in accordance with Company practice and I believe it to be r '.lable.

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

Very uly yours, e

mr D. L. Farrar Director of Nuclear Licensing 8402290232 840223 PDR ADOCK 05000374 CWS/lm G

PDR Attachment cc:

NRC Resident Inspector - LSCS 3

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RESPONSE TO INSPECTION REPORT e

No. 50-374/83-36 Item of Non-Compliance 1.

10 CFR 50, Appendix B, Criterion III, states in part, " Measures shall be established to assure that applicable regulatory requirements and the. design basis, as specified in t5e license application...are correctly translated into specifications, drawings, procedures and instructions".

Commonwealth' Edison Company Quality Assurance Program CE-1-A Topical

-Report,' Revision 15, dated January 2, 1981, Section 3-1, states in part, "... designs and materials will conform to... standards, regula-tory requirements, SAR commitments and appropriate quality standards as applicable."

Table 3.2-1 on page'3.2-5,Section V of the FSAR " Standby Liquid Control System" requires Quality Assurance Level I requirements on Item 9 electical and instrument modules and Item 10, cable.

Contrary to the above, the inspectors determineu that Quality Assurance Level I requirements were not implemented for the installation of cables of the standby 11guld control motor and auxiliary control switches.

Consequently, required QC inspections were not performed.

This is a Severity Level V violation (Supplement II).

Response

Corrective Action Taken and Results Achieved As discussed with the NRR staff and Region III inspectors in Bethesda on November 14, 1983, it is Commonwealth Edison's position that, as stated in Table 3.2-1 on page 3.2-5,Section V of the FSAR, the SBLC equipment referenced in the inspection report was purchased with safety-related requirements for fabrication.and documentation.

This equipment was' installed as a non safety-related system.

This distinction is referenced in notes 4b and 4c for Table 3.2-1.

NRR was in concurrence with this interpretation.

Commonwealth Edison made a commitment to review SBLC system terminations.

Edison's commitment on this subject is:

For the SBLC system, terminations on terminal blocks in the main control room and local panels shall be reviewed.

In those cases for those terminal where electrical feeds are from different divisions, those terminations shall be separated (either on the same or different terminal blocks) by at least six inches and uniquely. identified by division per FSAR commitments.

2-Corrective Action to Prevent R'ecurrence The~ commitment as stated above should satisfy the concerns relative to the.SBLC system.

D_ ate of Full Compliance This shall be accomplished before initial critical on Unit 2, and prior to startup following the first refueling outage on Unit 1.

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3-Item of Noncompliance 2.

10 CFR 50, Appendix B, Criterion XVII, states in part, " Sufficient records shall be maintained to furnish evidence of activities affecting quality.

The records shall include at least-the.following:

...the'results of reviews, inspections, test, audits... inspection and test records shall, as.a-minimum, identify...the type of observation, the results,-the acceptability, and tne' action taken in connection with any deficiencies noted.

-Commonwealth' Edison Topical Report No. CE-1-A, Revision 2,Section XVII,. states in part, " Fabrication and Construction documentation is generated by contractors,

...for Commonwealth Edison Company and will be available at the construction site... Records generated during site construction, testing...will be available at the Station.

Files shall be maintained current, complete and available for audit...".

Contrary to the above, the final inspection data sheets PS-74-32 dated August.15, 1978,-for_ battery chargers with serial numbers 12265-101A'(1DC09E) an'd 12265-102A (2DC09E) were incomplete and did i

not indicate that dielectric tests prescribed in paragraph 205.2 of

'the design specification J-2555 dated December 9, 1975 were oDCtcgroundtestvo:.tagesappiggtdocument-theACtoground, Thetestcert1Picatesdig ggr{ormed.

This is a Severity Level V violation (Supplement II).

Response

Corrective Action Taken and Results Achieved

~ Commonwealth Edison Company Nonconformance Report #658 was initiated.on.0ctober~17, 1983 concerning omissions in the subject documentation.

An engineering review has formed the following conclusions:

a)

Dielectric tests are performed on cables (wire) to ascertain

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their. insulation integrity.

The subject equipment has been energized in excess of two years with no' wire insulation failures indicating.the insulation is good and no additional

. testing is required.

b)

As outlined in the vendor letter concerning the subject, these tests were probably performed at the factory as a common safety practice prior to any other testing.

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e Corrective Action Taken to Prevent Recurrence Sargent & Lundy Quality Control Division personnel have rereviewed-all LaSalle County Station procured battery charger documentation for similar omissions.

All the battery chargers had dielectric tests included.

Based on the review, this item is considered an isolated case.

Date-of Full Compliance Full compliance has been achieved as of December 13, 1983.

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