ML19274E605
| ML19274E605 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 03/14/1979 |
| From: | Reed C COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19274E601 | List: |
| References | |
| NUDOCS 7904090252 | |
| Download: ML19274E605 (3) | |
Text
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Commonwealth Edison g
one First NaSona Plata CNcap flhno's Address Reply to Post Office box 767 Chicago. tilinois 60690 March 14, 1979 Mr. James G.
Ecppler, 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 I.E.
Inspection Report Nos. 50-454/79-01 and 50-455/79-01 NRC Jocket Nos. 50-454 and 50-455 Reference (a) :
February 12, 1979 letter from R.
F.
Heishman to Byron Lee, Jr.
Dear Mr. Kepplcr:
Reference (a) transr.itted an inspection rcport regarding an inspection conducted on January 9-11, 1979 by Messrs.
J.
E. Fonklin, K.
R. Naidu, P. A.
Barrett and J.
F.
Suermann of your office of activities at Byron Station.
Thtt report identified an apparent item of noncompliance.
Attachment A to this letter discusses our response to this item.
Please address any additionel questions that you might have to this office.
Very truly yours, G-Cordell Reed Assistant Vice-President attacnment
- ;1379 79 04 00 ty>S;>
Commonwealth Edison NRC Dochet Nos. 50-454/455 ATTACHMENT A INFRACTION
^
10 CFR 50, Appendix B, Criterion V states, in part:
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances...
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that Unportant activities have been satisfactorily accomplished."
Commonwealth Edison Company Topical Taport CE-1-A, Revision 5, Section 5 states, in part:
"The quality assurance actions carried out for design, construction,... will be described in documented instructions, procedures, drawings, specifications, or checklists.
These documents will assist personnel in assuring that important
~
activities have been performed."
Contrary to the above, on January 9, 1979, the inspector determined that documented instructions or procedures had not been established to assure that all design changes would be accomplished.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Hatfield Electric Company was not able to demonstrate to the NRC inspector that they had acceptable controls to assure that all design changes would be incorporated and inspected.
In addition to Hatfield Electric Company, other site contractors considered susceptible to this deficiency were Blount Brothers Construction and the Hunter Corporation.
The contractural arrangements with all other site contractors are essentially fixed price,and design changes receive sufficient visibility to assure accomplishment.
Further investigation by Commonwealth Edison disclosed that Blount Brothers Con.=truction and Hunter Corporation have adequate systems to assure the incorporation and inspection of design changes.
Therefore, commonwealth Edison considers the scope of this infraction to be limited to the Hatfield Electric Company.
Commonwealth Edison NRC Docket Nos. 50-454/455 During the inspection, a proposed system of control for the incorporation and inspection of design changes affecting the Hatfield Electric Company was presented to the ins pector.
This system utilizes forms and drawings ac the basic control mechanisms to assure that new work is completed and inspected.
The Hatfield field foreman signs off on the drawings when the work is completed.
Hatficia Engineering controls these drawings and turns the completed drawings over to Hatfield QA for inspection of the work.
Hatfield Electric Company is using this system at the present time.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE Hatfield Electric Campany has been informed to evise their procedures to incorporate the controls previously discussed for the accomplishment and inspection of design changes.
Hatfield Electric Company has reviewed past QC inspection reports and found several drawing areas which werc revised af ter being inspected.
These areas will be reworked and inspected per Hatfield's revised procedures.
Hatfield Electric Company's implementation of these procedures will be verified through surveillance and audit by Commonwealth Edison.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Hatfield Electric Company will have an operational and documented system to assure that all design changes are accomplished and inspected by April 15, 1979.
.