ML20079K046
| ML20079K046 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 11/05/1982 |
| From: | Stiede W COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20079K025 | List: |
| References | |
| 5381N, NUDOCS 8212280448 | |
| Download: ML20079K046 (3) | |
Text
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,e N Commonwealth Edison
(
) one First National Plan, Chicago, lihnois
(
' 7 Address Reply tr Post Offica Box 767 g
\\
,/ Chicago, Illinois 60690 November 5, 1982 Mr. James G. Keppler, Regional Administrator Directorate o f Inspection e d Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Byron Station Units 1 and 2 I&E Inspection Report Nos.
50-454/82-0 5 a nd 50-455/82-04 Re ferences (a):
Ju ne 24, 1982 letter from C. E. Norelius to Cordell Reed.
(b):
July 30, 1982 letter from W. L.
Stiede to J. G. Kepple r.
(c):
September 22, 1982 letter from C.
E. Norelius to Cordell Reed.
(d):
Au gust 17, 1981 letter from L. O. De1 George to D.
G.
Eisenhut.
Dear Mr. Keppler:
This is to provide additional information regarding corrective actions taken in response to violations at Byron Station identified in reference (a).
This information supplements the responses provided in reference (b) and addresses the NRC comments contained in reference (c).
Our response to Violation 2 indicated that we would review the training / qualification / certification records o f quality control inspec-tors including those o f contractors who have completed their scope o f work and no longer have personnel on site.
This review is being undertaken for contractors performing safety-related work a fter March 16, 1981, the date on which Revision 16 was issued for the Commonwealth Edison CE A topical report " Quality Assurance Program for Nu lear Generating Stations. "
As indicated in reference (d), that was the date on which we established ANSI N4 5.2.6-19 78 as the basis for the qualifi-cation of our QA/QC personnel.
The minimum features and methodologies to be verified in our review at Byron were established in a June 9, 1982 directive.
The objective of the review is to determine if the records demonstrate deficiencies in the inspector certification process employed.
If the review establishes that records demonstrate compatibility with the minimum features and methodologies, the review report will document 8212280448 821221 gDRADOCK05000 g gg
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J. G. Keppler Novembe r 4, 1982 ccceptablity.
If the review establishes that a deficiency exists which is one of format (i.e., the individual inspector's certification records lack documentation of education, experience, and training) the deficiency uill be classified as insignificant, documentation will be established, and the review report will document acceptability.
If the review establishes that a deficiency exists which is one of substance and essence (i.e., previous related experience indadequate, on-the-job training process, and capability demonstration process do not meet the presently established minimum features and methodologies), the deficiency will be classified as significant, and the review report will document unacceptability.
If the inspector is still performing inspection functions he will be retrained /requalified/ recertified to present procedures.
When the review process establishes inspector certification is unacceptable a reinspection of the features inspected by the subject inspector for the first month a f ter certification will be performed to establish acceptability o f inspection.
When inspections are found to have been performed unacceptably, additional sampling will be used to establish the scope of work needed to be reinspected.
Reinspections for other causes will be considered when establishing the scope of further inspections.
If the features inspected are no longer accessible for rein-spection a review will be performed to detemine if overview inspections performed by the independent inspection contractor or the Commonwealh Edison Quality Assurance Department establish the acceptability o f inspections.
If no overview inspections establish the acceptability o f inspections, an evaluation of testing performed or an evaluation of the inspection elements and attributes will be performed to determine if further corrective action is required.
Our review of qualification records is expected to be complete by December 31, 1982.
Any required retraining /requalification/recertifi-cation is to be complete by February 1, 1983.
The reinspections or additional review and evaluation of inspectors determined to be inade-quately qualified and certified should be complete by March 1, 1983.
Also in responding to Violation 2 we indicated that the procedures of the various contractors were being review and revised as necessary to incorporate the minimum features and methodologies o f ANSI N45.2.6-1978.
That work was completed as of September 30, 1982.
Additionally, all contractors performing safety-related work on-site are being requested to revise their quality assurance manuals to include a commitment to ANSI N45.2.6-1978.
This is expected to be completed by Februa ry 15, 1983.
In response to Violation 3.c.a we indicated that the cable side-wall pressures were adequately considered in establishing the maximum cable pulling tensions.
We have rereviewed the documents relating to cable pulling which were being used at the time o f the inspection and now concur with the conclusion that sidewall pressure was not adequately l
addressed.
i
- =ig J
J. G. Keppler Novembe r 4, 1982 Subsequent to the inspection the architect-engineer specified allowable pulling tensions for cables in conduit which consider both tensile strength of the conductors and the sidewall pressure exerted on the cable.
Methods were also established to determine the allowable pulling tension for multiple cable pulls in conduit and for cable pulls in conduit with non-standard radius bends.
To verify that the sidewall pressure was not exceeded for cable installed prior to these revisions the cable pull reports are being reviewed.
If it is found that the allowable sidewall pressure has been exceeded appropriate corrective action will be specified with the advice of the cable manufacturer.
This review is expected to be complete by January 31, 1983.
To assure correct pulling tension limits are used in the future the electrical contractor's procedure will be revised to specify the manner in which the allowable pulling tnesion is to be determined for all cable pulled through conduit.
The revised procedure is to be fully implemented by December 17, 1982.
In responding to Violation 7 we described our practices for control of documents specifying and documenting welding activities.
These specific construction activities have undergone the survey for implementation requirements of the ASME Boiler and Pressure Vessel Code Section III and Certificates of Authorization have been granted.
We believe that the welding is being adequately controlled in a manner which satisfies the Code.
By letter dated October 4, 1982 we have submitted to ASME a formal inquiry which should resolve this matter.
A response is expected by March 1, 1983.
Please direct further questions regarding these matters to this office.
Very truly yours, Wayne L. Stiede Assistant Vice-Presiden t lm 5381N