ML20073B045

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Responds to NRC Re Violations Noted in IE Insp Repts 50-454/82-01 & 50-455/82-01.Disagrees W/Violation Re NDE Techniques Utilized by Southwest Fabricating.Requests Item of Noncompliance Be Rescinded
ML20073B045
Person / Time
Site: Byron  Constellation icon.png
Issue date: 03/16/1983
From: Farrar D
COMMONWEALTH EDISON CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20073B008 List:
References
6203N, NUDOCS 8304110932
Download: ML20073B045 (5)


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[N Commonwealth Edison

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( C J Addrrss 3rply to: Post Office Box 767 Q Chicago, Illinois 60690 March 16, 1983 4

Mr. James G. Keppler, Regional Administrator Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Byron Station Units 1 and 2.

Final Response to Inspection Report Nos. 50-454/82-01 and 50-455/82-01 NRC Docket Nos. 50-454 and 50-455 References (a):

C. E. Norelius letter to Cordell Reed dated January 27, 1982.

(b):

E. E. Potter letter to K. Ward dated January 27, 1982.

(c):

L. O. DelGeorge letter to J. G. Keppler dated February 26, 1982.

(d):

M. E. Sheehan letter to E. E. Potter dated June 7, 1982.

(e):

P. D. Stumpf letter to E. E. Potter dated March 1, 1983.

Dear Mr. Keppler:

This letter is the final response to the inspection conducted by Mr. K. D. Ward on January 12 and 14, 1982, of activities at Byron Station.

Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements.

Specifically, the item of. non-compliance alleged that Non-Destructive Examination (radiographic) techniques utilized by Southwest Fabricating and Welding Company were not performed'in accordance with ASME Section V Code requirements.

As explained in References-(b) and (c), it is Commonwealth Edison Company's 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.

In order to resolve the divergent interpretations of the Code words,. Commonwealth Edison Company submitted a Code Inquiry to Subcommittee V of the ASME Boiler and Pressure Vessel Code on February 2, 1982.

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- J. G'.Keppler March 16, 1983 References (d) and (e) provide the ASME responses to our Code inquiry.

These interpretations, which are enclosed for your review, support the practices which were utilized are in accordance with the intent of -the Code.

The re fo re, it is respectfully requested that this item 'of non-compliance.be rescinded.

To the best of my knowledge and belief the statements. contained herein and in the attachment are true and correct.

In some respects.

these statements are not based upon my personal knowledge but upon information furnished by other Commonwealth Edison employees.- Sucn information has been reviewed in accordance with' Company practice and I believe it to be reliable.

If you have any further questions.on this matter, please direct them to this office.

-Very truly yours, 3!#

E3 D. L. Farrar Director of. Nuclear Licensing CWS/1m Attachment

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The American Society of Mechanical Engineers

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June 7, 1982 Mr. E.E. Potter Commonwealth Edison 1319 South First Avenue Maywood, IL 60153

SUBJECT:

Interpretation of Section V, Article 2, Para. T-262.3 (a) and (b)

ITFM:

BC-82-113

REFERENCE:

Your letter dated February 2, 1982

Dear Mr. Potter:

Our understanding of the question in your inquiry, and our reply, are as follows:

Question:

Is it permissible to use tnot e than one penetraneter in accordance with Section V Article 2, Par. T-262.3 (a), 1974 Ed., 1075 Summer Addenda?

Reply:

Yes, Par. T-262. 3 ( a) does not prohibit more than one pene-trameter.

Very truly yours,

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s Mark E.'Sheehan Assistant Secretary, Boiler and Pressure Vessel Committee (212) 705-7819 l

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l4 ASME procedures provide for reconsideration of this interpretation when or if additional information is available which the inquiref t ehavet might affect the interpretation. Further, persons aggrieved by this interpretation may appeal to the cognitant ASM E committee or subcommittee. As stated in the f oreword of the code documents. ASM E cfoes not " approve l"' certify,""cata " or " endorse" any item construction, proprietary device or activity.

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March 1, 1983 ve cn s.~on r t.ra v vte n. e,s s.e m en Mr. E. Potter I,[in'd5//,'.7' ""

Commonwealth Edison Co.

Maywood Technical Center 1319 South First Avenue Maywood, IL 60153

Subject:

Section V; Code Case 1914 for Alternate Pentrameter Placement Item:

F,C82-113

Reference:

Your letter of February 2,1982

Dear Mr. Potter:

The Connittee at its meeting of September 17, 1982 approved a proposed Code Case which will be of interest to you.

The Case is attached for your Information.

The Code Case, as approved by Council, wt11 become effective ns of February 7,1983.

Very truly yours, LJL b Swg Paul D. Stumpf Assistant Secretary /floiler and Pressure Vessel Connittee (212) 705-7096 PDS/ky Memtser. Arnerican Association of Engineering Societies. Accred tation Board for Engineering and Technorogy

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i Code case 1914 for Aternative Penetrameter Placement,- Section V i)

Inquiry:

Is it permissible to place penetrameters on the. weld in lieu of; or;

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in addition to, the penetrameters placed adjacent'to,'the weld, as requircdby T-263.1(a) of Section V7 Reply:

It is the opinion of the Coranittee that, for Section V applications, the penetraceter placement described in the Inquiry is: permitted,-

provided the penetrameter identifying numbers:and-skim (s) (if used) are not placed on the weld s.etal, i

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