IR 05000456/1984005
| ML20140D397 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 12/13/1984 |
| From: | Warnick R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20140D403 | List: |
| References | |
| NUDOCS 8412180471 | |
| Download: ML20140D397 (3) | |
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December 13, 1984 Docket No. 50-456 Docket No. 50-457 Comonwealth Edison Company ATTN:. Mr. Cordell Reed j
Vice President l
Post Office Box 767 l
Chicago, IL 60690 Gentlemen:
This will acknowledge receipt of your letters dated August 10, 1984, September 11, 1984, and November 2 and 19, 1984, and a telephone conference call between Mr. Schroeder, et al, of your staff and Messrs. W. Forney, L. McGregor and J. Durr of the NRC staff on September 11, 1984, informing us of the steps you
have taken to correct the NDE matters which we brought to your attention in our
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letter dated July 2,1984.
Except for your response to Item Nos. A(1), A(2), A(3), C(2) and D, we have no further questions or comments. Your responses to all items will be reviewed
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during subsequent inspections.
In your letter dated August 10, 1984, you take issue with the NRC characterization
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that "An NRC inspector made a random selection of weldments....". We acknowledge that the weld selection was not " random" in the pure statistical sense; however,
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the instructions were to select welds from the various categories stated implying i
a random, representative sample. We do encourage the Resident Inspector to include potential or perceived problem welds when appropriate.
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Regarding Item A to our letter dated July 2,1984:
(1) The NRC NDE Van personnel were not, and could not be expected to be, aware of the Byron inspection findings regarding penetrameter placement in the weld nor of the proposed code case. These facts were also not disclosed by your staff during the inspection. However, the NRC has accepted the use of Code Case No.1914 for use at Byron and Braidwood by internal memo-randum, dated July 11, 1984, subsequent to the inspection, thus permitting the cited condition.
We have reviewed our records relating to spoel No. Q6056-CV-23-6, Weld No.
6, and have decided a transcriptional error has been made. Again, this is an example of the previously discussed problem of penetrameters in welds and is resolved with the code case No. 1914 acceptance.
8412180471 841213 PDR ADOCK 05000456 G
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l Consonwealth Edison Company
December 13, 1984 (2) The production of radiographic film with mechanical, chemical, or other blemishes poses more than one question. The first and foremost is do these blemishes obscure flaws. Unless radiographic films are produced without these blemishes, it cannot be positively established that true flaws are not present. Secondly, film artifacts indicate deficiencies in the work-manship and production quality standards which are being implemented for nondestructive examinations. Serious or repeated breakdowns.in film quality-should be cause for concern. Management should determine the underlying
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causes and initiate corrective actions.
(3) We recognize that the reader sheets indicate "Due to configuration."
However, our examination of the actual configuration revealed that the code provision had been abused. This particular violation is another example of the "penetrameter in the weld" problem and is also resolved with the Code Case No. 1914 issue.
With respect to Item C(2), your corrective action for the weld drop-through problem appears to be reradiography of the area until acceptable densities are achieved. Depending on the applicable code, ASME III-1975, ND/NC/ND 4426,-your corrective actions must also consider how you satisfy the internal reinforcement requirements.
With respect to Item D, the expressed purpose of the NRC inspection program is to determine that nuclear facilities under construction meet regulatory require-ments and licensee commitments. This can only be accomplished by providing our inspectors with the most accurate information available to make our inspections effective. Further, a document control program that permits the issuance of obsolete or incomplete construction drawings is unacceptable. We have reaffirmed through our resident and regional staff that the drawings were issued without the appropriate design changes attached or referenced and, therefore, the violation is valid. Nonetheless, your corrective actions appear to be appropriate for this violation.
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Comonwealth Edison Company
December 13, 1984 lShould you have any questions concerning these matters, we will be glad to discuss them with you.
Sincerely,
"Ortsfnal signed Ly.R, F. Warnick" R. F. Warnick, Chief Reactor Projects Branch I cc:
D. L. Farrar, Director of Nuclear Licensing M. Wallace, Project Manager D. Shamblin, Construction Superintendent J. F. Gudac, Station Superintendent C. W. Schroeder, Licensing and Compliance Superintendent DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII Braidwood Resident Inspector, RIII Byron J. Durr, RI Phyllis Dunton, Attorney General's Office, Environmental
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Control Division D. W. Cassel, Jr., Esq.
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RI RIII Fo
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