ML19209A456
| ML19209A456 | |
| Person / Time | |
|---|---|
| Site: | Byron, Comanche Peak  |
| Issue date: | 09/13/1979 |
| From: | Peoples D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19209A453 | List: |
| References | |
| TASK-MP-536-1, TASK-OS NUDOCS 7910040080 | |
| Download: ML19209A456 (4) | |
Text
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(,ommonwealth Edison One First National Plaza. Chicago, Illinois
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Address Reply to: Post Office Box 767 Chicago, Illinois 60690 September 13, 1979 Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
Byron Station Units 1 and 2 Response to IE Inspection Report Nos. 50-454/79-12 and 50-455/79-12 NRC Docket Nos. 50-454/455 R2ference (a) :
August 18, 1979 letter from G. Fiorelli to Byron Lee, Jr. transmitting IE Inspection Report Nos. 50-454/79-17 and 50-455/79-12
Dear Mr. Keppler:
Reference (a) transmitted an inspection report regarding an inspection conducted on July 23-26, 1979 by Mr. E. W. K. Lee of your office of activities at Byron Station.
That report identified two apparent items of noncompliance with NRC requirements -- one infraction and one deficiency.
Attachment A to this letter contains Commonwealth Edison Company's response to these items.
Please address any additional quescions that you might have to this office.
Very truly yours, h $
f4cy m l
D. L. Peoples Director of Nuclear Licensing attachment 1009 707 7910040O N N/>y77 k
Commonwealth Edison NRC Docket Nos. 50-454/455 ATTACHMENT A ITEM 1 - INFRACTION 10 CFR 50, Appendix B, Criterion VI states, in part, that " Measures shall be established to control the issuance of documents, These measures shall assure that documen.ts, including changes, are reviewed... and are distributed to and used at the location where the prescribed activity is performed."
Commonwealth Edison Company Topical Report No. CE-1-A, Revision 7, Section 6, states, in part, that "A document control system will be used to assure that documents Such documents will be distributed to and used at the locations where the pre-scribed activity is performed..."
Hunter Corporation Site Implementing Procedure No. 2.101, Revision 2, Paragraph 7.2.a.2.iii states that " Design specification piping line lists, equipment lists, instruction manuals, or other controlled instructions, when distributed to the Document Stations, shall be on a one copy basis.
Design drawings shall be distributed in a controlled manner on an " Internal Transmittal" (Form HC-7).
Other design documents will be by controlled distribution and record on the " Document Distribution Status (Form HC-52)."
Contrary to the above, on July 24 and 25, 1979 the inspector established that four (4) Hunter Corporation (Hunter) inter-company correspondences No. HC-QA-05, No. HC-QA-07, No.
HC-QA-13 and No. HC-QA-31 issued as supplements to. Site Implementing Procedures (SIP) and/or Welding Procedure Specifications (WPS) were not distributed to all SIP and WPS manual holders.
Furthermore, three (3) of the correspondences No. HC-QA-05, No.
HC-QA-07 and No. HC-QA-13 were not inserted in the copy of the SIP or WPS manuals located in the Containment and Auxiliary Building document station as required by the correspondence.
CORRECTIVE ACTION TAKEN AND'RESULTS ACHIEVED:
The procedura supplements indicated in the noncompliance havs been redistributed t o the document stations under a more con-trolled format.
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4 Commonwealth Edison NRC Docket Nos. 50-454/455 CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE:
The Site Implementation Procedure (SIP) has been revised to provide a more positive method for identification and distribution of procedure supplements.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance will be achieved by September 14, 19.9.
ITEM 2 - DEFICIENCY 10 CFR 50, Appendix B, Criterion V, states, in part, 2
that " Activities affecting quality shall be prescribed by documented instructions,... and shall be accomplished in accordance with these instructions, Commonwealth Edison Company Topical Report No. CE-1-A, Rmrision 7, Section 5, states, in part, that "The quality assurance eccians carried out for design, construction, testing, and operation activities will be described in documented instructions, procedures,
+ awings, specifications, or checklists.
These documents will assist personnel in assuring that important activities have been performed.
These documents will also reference applicable acceptance criteria which must be satisified to assure that the quality related activity has been properly carried out."
Hunter Corporation Site Implementing Procedure No. 4.001, Revision 2, Paragraph 4-10, states, in part, that "The Quality Control / Welding Inspector is responsible for the as-built Quality Assurance Records and must update them at each inspection point.
The inspector will only use the " Construction Copy" of the Process Sheets and Drawing (s) for inspection.
His initials on the process sheet in the space marked " Inspected by" will signify his acceptance of that step in the sequence."
Contrary to the above, on July 25, 1979 the inspector established that a QC hold point ca weld data sheet for Unit 1 field Weld No. FW299A onfIsometric Drawing No. CV-6 was not signed off.
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Commonwealth Edison NRC Docket Nos. 50-454/455
. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED:
A Non-Conformance Report (NCR) has been generated to identify the deficiency, i.e., lack of notation on process sheet by inspector.
That report also indicates that the hold point for I
witnessing closure of windows on consumable inserts was not applicable since the weld joint configuration and accessibility did not require windows.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE:
Memorandums have been issued to all area superintendents and quality control inspectors stating that the quality control inspectors should invalidate hold points of this nature.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance will be achieved by September 14, 1979.
I 1089 2lg