ML20041F676

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Responds to NRC 820127 Ltr Re Violations Noted in IE Insp Repts 50-454/82-01 & 50-455/82-03.Corrective Actions: Discontinued NDE (Radiographic) Technique Utilized by Southwest Fabricating & Welding Co
ML20041F676
Person / Time
Site: Byron  Constellation icon.png
Issue date: 02/26/1982
From: Delgeorge L
COMMONWEALTH EDISON CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20041F648 List:
References
3550N, NUDOCS 8203170290
Download: ML20041F676 (2)


Text

. _.

. . ** . ' ~ g/7' ~ ) one. Commonwealth Edison Fir;t National Plaza, Chicag~o, Ilhnois

. $ O "J Address Reply 12 Post 6fiE2 Box 767 (y Chicago Illinois 60690 February 26, 1982 Mr. James G. Keppler, Regional Administrator Directorate o f Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Byron Station Units 1 and 2 Interim Response to I.E.

Inspection Report Nos.

50-454/82-01 and 50-455/82 NRC Docket Nos. 50-454 and 455 Reference (a): C. Norelius letter to Cordell Reed dated January 27, 1982.

(b): E. E. Po tter letter to K. Ward dated January 27, 1982.

Dear Mr. Keppler:

Reference (a) provided the Commonwealth Edison Company with the results of the routine safety inspection conducted by Mr. K. D.

Ward of-your o ffice on January 12 and 14, 1982, o f activities at our Byron Station, Units 1 and 2. Reference (a) indicated that certain activities appeared to be in non-compliance with NRC requirements.

The following is provided as an interim response to this notice of vinlation.

The non-compliance alleges that NDE (radiographic) techniques utilized by Southwest Fabricating and Welding Company were not performed in accordance with ASME Section V Code requirements. It is our judgment that we are not in violation of the intent of the Code as it applies to the placement and numbers of penetrameters utilized by Southwest.

As explained in our Reference (b) letter, the Code is ambiguous on this matter. In order to resolve our divergent interpretations o f the Code words, we proposed to make a Code Inquiry to Subcommittee V of the ASME Boiler and Pressure Vessel Code for interpretation. This inquiry was submitted on February 2, 1982.

8203170290 B20312 PDR ADOCK 05000454 i

o PDR MAR 1 EB2

J. G. Keppler February 26, 1982 We respectfully request that the NRC hold this item in abeyance until July 1,1982, in order to allow Commonwealth Edison time to obtain the requested Code opinion from Subcommittee V. At that time we will provide our final response. May we please receive your concurrence with this interim approach.

Please be advised that Commonwealth Edison requested Southwest to discontinue this particular technique which they did on January 22, 1979. Our Byron Station on-site Q.A. Department performed a surveillance of Southwest radiographs which concluded that this technique was in fact discontinued.

Please address any further questions that you or your staff may have concerning this matter to this office.

Very truly yours,

/ L. O. DelGeorge Director of Nuclear Licensing Im 3550N c?.