ML20002C435

Responds to NRC 801023 Ltr Re Violations Noted in IE Insp Repts 50-456/80-12 & 50-457/80-11.Corrective Actions: Cables W/Open Ends Sealed & Surveillance Performed

ML20002C435
Person / Time
Site:	Braidwood
Issue date:	12/04/1980
From:	Abel J COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20002C431	List: ML20002C435
References
NUDOCS 8101100301
Download: ML20002C435 (5)

Text

N, d >- ' s Commonwaalth Edison

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) 7 Addreh Reppio Post Cffice Box 767 s/. ', / CNcago. llhnois 00690 December 4, 1980 Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Braidwood Station Units 1 and 2 Response to IE Inspection Reports 50-456/80-12 and 50-457/80-11 NRC Docket Nos. 50-456 and 50-457 Reference (a): October 23, 1980, letter from G. Fiorelli to C. Reed

Dear Mr. Keppler:

Reference (a) contained the results of an inspection of activities at Braidwood Station which was conducted on September 22-25, 1980, by Messrs. K. R. Naidu and J. Schapker of your of fice.

During this inspection, certain activities appeared to be in noncompliance with NRC requirements. Commonwealth Edison Company's responses are contained in Attachment A to this letter Please address any additional questions that you may have to this office.

Very truly yours,

/

J. S. Abel Director of Nuclear Licensing Attachment 8424A CEC, a

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NRC Docket Nos. 50-456

$0-457 Attach.nent A Response to Notice of Violation Infraction 1:

10 CFR 50, Appendix B, Criterion XVI, states in part, that

" Measures shall be established to assure conditions adverse to quality such as ... and nonconformance are properly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition".

Paragraph 4 in Section 16 of Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program", Revision 9, dated July 16, 1979, states in part, " Implementation of corrective action will be accomplished at the source of deficiency by contractor personnel as directed by cognizant Edison engineers."

Contrary to the above, it was determined that even though the ends of several cables were found to be open during various surveillances over a period of tv a months, the cause ,of the condition was not determined and corrective action was not taken to preclude repetition. On September 22, 1980, it was identified that several cables were supplied by the vendor with one end open, which was contrary to the purchase specifications for cables; no attempt was made to remove the wrappers on the cable reels to investigate the cause of recurring nonconforming conditions. Furthermore, the corrective action taken to seal those cable ends which were open was not documented in the Inspection Correction Reports. The cables in question are stored outdoors and may not be used for an extended period; the moisture, absorption, when the ends of cables are open during inclement weather conditions, could deteriorate the insua3 tion over an extended period.

• Corrective Action Taken and Results Achieved All wrappers were removed from the reels of instrument cable and those cables with open ends were sealed. Surveillances have been performed and cable ends are sealed on all cables in the cable yard. Corrective action has been documented in the Inspection Correction Reports.

Corrective Action Taken to Avoid Further Noncomoliance The cable manufacturer will be contacted with regard to the lack of cable end seals. Until we receive some assurance that this manufacturing deficiency has been corrected, all cable ends will be checked as part of the site receiving inspection.

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Date When Full Compliance Will Be Achieved September 25, 1980.

Infraction 2:

10 CFR 50, Appendix B, Criterion VII, states in part,

" Measures shall be established to assure that purchased material, equipment, and services, whether purchased directly or through contractor or subcontractor, conform to the procurement documents.

These measures shall include provisions, as appropriate, for

.... examination of products upon delivery".

Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Stations", Revision 9, dated July 16, 1979, states in paragraph 7.4, " Materials and Articles received from vendors will be inspected upon receipt to assure physical integrity and identity plus documentation compliance with procurement requirements."

The following examples were contrary to the above:

a. The inspector determined that even though safety related HVAC ducts supplied by Pullman Construction Industries did not meet the Specification and American Welding Society (AWS) D.l.l.

criteria, the components were released for shipment by the vendor as acceptable equipment and receipt inspection at the site accepted the same,

b. Main Control Board panels were receipt inspected and accepted even though the welds inside them do not meet the acceptance criteria specified in the specification and AWS D.l.l. Code.

c. Supports for Hanger H-81, which were supplied by Systems Control, were received, accepted by receipt inspection, and installed even though the support had 1/8" size welds instead of the 1/4" size welds speci fied.

Corrective Action Taken and Results Achieved Inspection of shop welds generally takes place at the manufacturer's inspection.

shop and is not repeated during the site receiving The deficiencies identified by the inspector there fore relate more to the manufacturer's weld acceptance than to the receiving inspection.

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3 _3-The weld acceptance criteria are being modified and a weld inspection and repair program will be initiated for the welds described in parts a, b and c of this infraction. The suppliers of the equipment discussed in parts a, b and c are being requested to perform an engineering analysis to determine the minimum weld criteria.

Corrective Action Taken to Avoid Further Noncomoliance Further weld inspections will be performed to the modified criteria.

Date When Full Compliance Will Be Achieved The engineering analyses are expected to be completed by February 1, 1981 and the modified criteria finalized shortly thereafter. The weld inspection and repair program is expected to be completed by June 1, 1981.

Infraction 3:

10 CFR 50, f .x B, Criterion XIII, states in part, "t/easures shall be ess _. dished to control the handling, storage, shipping, cleaning, and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration".

BM-103, " Site Storage Instructions", under pargraph

" Responsibilities", states that "QA supervisor is responsible for assuring that surveillance of storage,is performed by Field Engineer and tnat storage is in acetrdance with procedures and intent of ANSI N45.2.2".

Contrary to the above, it was determined that safety related HVAC ducts were being stored off cribbing on the ground, and were immersed in a pool of accumulated rainwater.

Corrective Action Taken and Results Achieved All six items of ductwork were placed on cribbing.

Accumulated water was drained and the ducts were placed in positions such that water would not accumulate.

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. , , . . o Corrective Action Taken to Avoid F urther Noncompliance The contractor's supervisory personnel have been admonished and reminded even if the storage periodthat strict adherence to storage procedures is required is expected to be short.

Engineer's surveillance checklists are being revised The to Field include outdoor storage areas other than predesignated laydown areas.

Date When Full Compliance Will Be Achieved December 15, 1980.

8424A W

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