ML20077J358

Revised Response to NRC Re Violations Noted in IE Insp Repts 50-454/83-17 & 50-455/83-14.Corrective Actions:Garbage,Trash,Scrap & Litter Collected & Removed on or Before 830408 & 0510

ML20077J358
Person / Time
Site:	Byron
Issue date:	08/08/1983
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20077J352	List: ML20077J356 ML20077J358
References
7086N, NUDOCS 8308160294
Download: ML20077J358 (3)

Text

, _ _____--_ _- ________-__________--. _ _ _ __ _ __ -

• 1. V

, /N Commonwealth Edison

). One First Nition:1 Plua, Chicago, Illinois O 'J Address Reply to: Post Offica Box 767 Q Chicago, Illinois 60690 August 8, 1983 Mr. James G.-Keppler, Regional Administrator

- Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road-Glen Ellyn, IL 60137

Subject:

Byron Station Units 1 and 2 I.E. Inspection Report Nos.

50-454/83-17 and 50-455/83-14 NRC Docket Nos. 50-454 and 50-455 References (a): J. F. Streeter letter to Cordell Reed dated May 24, 1983.

(b): D. L. Farrar letter to J. G. Keppler dated June 21, 1983.

Dear Mr. Keppler:

This letter provides a revised response to a violation identified by Mr. M. A. Ring regarding housekeeping during construction of Byron Station.

Reference (b) transmitted Commonwealth Edison's original response to Violation 2 identified in reference (a). That response was reviewed with the inspector at the site on July 7, 1983.

The revised response contained in Attachment A to this letter is respon-sive to the concerns discussed at that meeting.

Please direct further questions regarding this matter to this Very truly yours, NW w

i D. L. Farrar Director of Nuclear Licensing TRT/1m 7086N 0308160294 830812 PDR ADOCK 05000454 G PDR M10

ATTACHMENT A REVISED AND SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION VIOLATION 2 10 CFR 50, Appendix B, Criterion XIII states, in part, that " Measures shall be established to control the handling, storage, shipping, cleaning and preservation of material and equipment...to prevent damage or deterioration."

The Commonwealth Edison Company Quality Assurance Program contains in Quality Requirement QR 2.0 a commitment to the regulatory position of Regulatory Guide 1.39, Revision 2 which endorses the requirements of ANSI N45.2.3-1973. Section 3.2.1 of ANSI N45.2.3 states, "The work areas shall be kept sufficiently clean and orderly that construction activity can proceed in an efficier.t manner that will produce and maintain quality in conformance with specified requirements. Where large accumulations of materials occur on a nonroutine basis, such as the stripping of concrete forms, the material shall be promptly removed or stored neatly. Garbage, trash, scrap, litter, and other excess materials shall be collected, removed from the job site, or disposed of in accordance with specified requirements or planned practices. Such excess material shall not be allowed to accumulate and create conditions that will adversely affect quality."

Contrary to the above, the applicant's program for maintaining cleanliness and housekeeping was not being adequately implemented as evidenced by the following examples:

a. On April 6 and 7, 1983, the inspector noted many loose pieces of lagging and considerable garbage and trash strewn about the MSIV rooms, and a coating of lagging dust covered almost everything in the B and C MSIV rooms. The A and D MSIV rooms had staging built such that instrument valves could not be operated and loose boards were leaning against valve handwheels and generally strewn about.

b. On April 20 and 28, 1983, the inspector noted considerable food stuffs (soda cans, banana peels, orange peels, candy bar wrappers and small food tins), loose boards, and cigarette packs in the area of the Unit 2 Diesel and Motor Driven Auxiliary Feed Pumps.

c. On April 28, 1983, the inspector noted that the SG "C" cubicle walkway had numerous pieces of rags, pop cans, cigarette butts, flexitallic gasket and general construction material.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The garbage, trash, scrap, and litter specifically identified in b examples a, b, and c above were collected and removed on or before April 8, 1983, May 10, 1983, and May 10, 1983, respectively as demonstrated by surveillances performed in accordance with Byron Site Instruction #23, Rev. 3 dated June 3, 1982; copies of which were provided with our response dated June 21, 1983, reference (b).

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Y, CORRECTIVE ACTION TAKEN TO PREVENT RECURRENCE:

In order to minimize exposure to conditions of housekeeping which can be perceived as creating potential conditions which could degrade the requisite quality of items being constructed or installed the following actions have been or will be undertaken:

1) A Project Construction Department (PCD) Field Engineer has been assigned responsibility for overall co-ordination of housekeeping activities, this is a change from the previous assignment to various field engineers in each construction discipline.

2) Refuse and trash containers will be painted and stenciled in such a manner as to make them more visible for purpose and use.

3) Signs will be posted in areas, when deemed appropriate, to heighten visibility to housekeeping crews of the cleaning frequency, and more specific route sheets will be created to identify more clearly the scope of housecleaning and frequency of cleaning to the housekeeping crews.

4) For_those construction disciplines which by the nature of their work create large accumulations of materials on a nonroutine basis (i.e. piping insulators, brick masons, structural steel fireproofing) a memo reinforcing the need to keep materials orderly will be directed to the various supervisors, and this memo will be re-directed to supervisors when future conditions appear to warrant the need.

5) For those construction disciplines which by the nature of their work create large accumulations of materials on a nonroutine basis a documented vehicle of communication will be established to the PCD Field Engineer who has been assigned responsibility for overall co-ordination of housekeeping, such that the established frequency of cleanup of housekeeping crews can be adjusted as needed.

6) The periodic documented surveillance of areas will continue to be performed nominally on a one month frequency. The effect of the foregoing actions will be used to determine need for increasing or decreasing t' e frequency of documented surveillance activities.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Various levels of the foregoing corrective actions will be achieved beginning in August, implementation of all features should be complete by November 1, 1983.

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