ML19247A035
| ML19247A035 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 05/17/1979 |
| From: | Reed C COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19247A030 | List: |
| References | |
| NUDOCS 7907270115 | |
| Download: ML19247A035 (3) | |
Text
Commonwealth Edison One First Nationat Plaza Chicago I;ieno,s F Address Reply to Post Office Box 767 Chicago, (thnois 60690
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May 17, lVi9 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:
Zion Station Unit 2 Response to IE Inspection Report No. 50-304/79-04 NRC Docket No. 50-304 Reference (a):
April 18, 1979 letter from G. Fiorelli tc Byron Lee, Jr. transmitting IE Inspection Report No. 50-304/79-04
Dear Mr. Keppler:
An inspection was conducted by Mr. W. J. Key of your office on March 12-13 and April 3-4, 1979 of activities at Zion Station Unit 2.
As indicated in Reference (a), during this inspection certain activities appeared to be in non-compliance with NRC requirements.
Commonwealth Edison Company 's response to the apparent item of noncompliance is contained in Attachment A to this letter.
Based on the information contained in this response, Commonwealth Edison respectfully requests the NRC inspector to change the infraction to an observation.
Please add:cs, any questions that you might have on this matter to this office.
Very truly yours, 0.
Dm ch Cordell Reed Assistant Vice-President attachment 790727oUS
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Commonwealth Edison NRC Docket No. 50-304 ATTACHMENT A
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10 CFR 50, Appendix B, Criterion XII, s t r. t e s, in part that " Measures shall be# established to assure that tools, gauges, instrument a... are properly controlled, calibrated and adjusted..."
The ASME Boiler and Pressure Vessel Code,Section XI, incorporates ASME,Section III, Subparagraph NA 4610 which states, in part that " Calibration shall be against certified measurement standards which have known relationships to national standards..."
Commonwealth Edison Company (CECO.) QA Manual, Quality Regirement QR No. 12.0, Section 12.2, states in part that
" Inspection, measuring and test equipment will be adjusted and calibrated using documented procedures at scheduled intervals against certified standards having known valid relationships to recognized standards."
I Contrary to the above mentioned requirements, on April 4, 1979, the NRC inspector observed that the calibration step wedge I
being used to calibrate the X-Rite Model 301 densit'ometer, S/N 2699, located in the CONAM portable radiographic facility, was not certified to a known recognized standard as required by paragraph T-234.2 of ASME Section V.
RESPONSE
CONAM was employed by the licensee to perform radiographic weld construction examinations for plant modifica-tion work.
This non-destructive examination (NDE) was not related to the licensee's Inservice Inspection Program.
NDE contractors who perform construction examinations conduct non-destructive examinations in accordance with licensee procedures pursuant to Commonwealth Edison Company (CECO) QA Manual, which is in accordance with 10 CFR 50, Appendix B and ASME Sections III and V.
In the course of performing radiography and ascociated interpretations in accordance with the licensee's procedures, CONAM did not use the X-Rite Mode 301 densitometer or the calibration step vedge located in the CONAM owned portable radiographic facility.
All radiographic interpretation performed by CONAM for this modification work, which included the inspection periods in March and April,1979, was done by using a licensee owned and controlled Macbeth Model TD-501 densitometer, S/N 1108.
Calibration of this der.sitometer was performed usin; a
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Commonwealth Edison NRC Docket No. 50-304 licensee owned and controlled photographic step tablet, I.D. No.
117810, certified by National Bureau Of Standards on November 15, 1978 Additionally, all radiographs are reviewed and interpreted by qualified licensee personnel using the same licensee owned equipment.
Since the inspector did not inspect nor review records of activities performed by CONAM or the licensee using non-certified equipment and since no ISI activities were performed by other contractors or the licensee using non-certified equipment, Commonwealth Edison has concluded that the basis for the item of noncompliance does not exist.
Therefore, Commonwealth Edison requests the NRC inspector to reevaluate the apparent item of noncompliance and change it to an observation.
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