ML20072E590

Suppls Response to NRC Re Violations Noted in IE Insp Repts 50-456/82-08 & 50-457/82-08.Corrective Action: Date of Issuance for Fcr L-8344 on Drawing M537 Located in Area III of Auxiliary Bldg Corrected

ML20072E590
Person / Time
Site:	Braidwood
Issue date:	05/24/1983
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20072E578	List: ML20072E590
References
6644N, NUDOCS 8306270071
Download: ML20072E590 (3)

Text

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'N Commonwealth Edison

'[.

) ons First National Plaza, Chicago, Illinois j

g} Address Reply to: Post Office Box 767 O

Chicago Illinois 60690 5

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May 24, 1983 s

i Mr. James G. Keppler, Regional Administrator Directorate of Inspection and i

Enforcement - Region III U.S. Nuclear Regulatory Commission j

799 Roosevelt Road Glen Ellyn, IL 60137 l'

Subject:

Braidwood Station Units 1 and 2 Supplemental Response to IE f

Inspection Report Nos.

50-456/82-08 and 50-457/82-08 NRC Docket Nos.- 50-456/457 References (a):

D. L. Farrar letter to J. G. Keppler dated March 16, 1983 l

j (b):

C. E. Norelius letter to Cordell Reed j

dated February 14, 1983 (c):

C. E. Norelius letter to Cordell Reed dated April 25, 1983-

Dear Mr. Keppler:

I Reference (a) provided the Commonwealth Edison Company thirty (30) day response to the Reference (b) Inspection Report.

Reference (c) took issue with our response to Violation No. 3 and T

requested a supplemental response to this item within thirty (30) i days of our Reference (c) receipt.

The purpose of this letter is to i

provide our response to Reference (c) as requested.

To the best of my knowledge and belief, the statements contained in the Attachment are true and correct.

In some respects, these statements are not based on my personal knowledge but upon information furnished by other Commonwealth Edison employees and consultants.

Such information has been reviewed in accordance with Company practice and I believe it to be reliable.

g6EMPaoo'o[g MAY 26 G83 G

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Please address any further questions that you or your staff l

may have concerning this matter to this office.

Very truly yours, I

, sp Dennis L. Farrar l

Director of Nuclear Licensing l-Attachment l

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RIII Inspector - Braidwood l

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ATTACHMENT Supplemental Response to Violation No. 3 We have reviewed the drawing used as an example (M537, Auxiliary Building el. 364, sheet 9, revision V) in Reference (c) and offer the following explanation:

Drawing (M537) was received by CECO. Construction and P.G.

Co.

on the respective dates identified (January 10 and 11, 1983).

FCR L-8944 was initiated on March 11, 1983 and was " Advance Verbal Concurred" for use on March 14, 1983.

This date coincides with the dates stamped on the CECO. and P.G. Co.

Construction office drawings (March 21 and March 17, 1983).

P.G. Co. inadvertantly recorded January 15, 1983 on a field copy as the date affixing the FCR instead of March 15, 1983.

The annual audit performed by CECO. Construction revealed 196 discrepancies between the S&L Status List and the current drawings on the racks in the Construction Office.

Upon further follow-up, it was found from S&L that over 100 of these drawings should nut have been received by CECO. for various reasons, i.e.

they were not yet issued, were void, were for bid or information only, etc.

The remaining drawings (approximately 84, or less than 0.3% of the total S&L drawings) were subsequently sent by S&L and inserted in the drawing racks as current revisions.

This accomplished the intended purpose of the audit.

We believe that Region III's concern that " drawings are being stamped with ECN's and FCR's which are not applicable to that drawing or which have been superseded but remain on the construction drawing" has no adverse affect on the quality of the installation.

However, we have taken corrective actions to minimize this practice.

Corrective Action Taken and Results Achieved In addition to the actions discussed in Reference (a), we have corrected the date of issuance for FCR L-8944 on drawing M537 located in area III-auxiliary building.

Corrective Action Taken to Avoid Further Noncompliance P.G. Co. has assigned responsibility of affixing applicable FCR's and ECN's on drawings to a document control clerk instead of the field Foreman.

Procedure PGCP-1.1, Rev. A has been revised to reflect this change.

Date When Full Compliance Will Be Achieved Full compliance will be achieved upon S&L's final approval of Procedure PGCP-1.1, Rev. 4.

The expected approval date is May 27, 1983.

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