ML20098G856

Forwards Listed Correspondence Between Util & Natl Board of Boiler & Pressure Vessel Inspectors Re Intervernors 840801 Motion That Certain Allegations Concerning Authorized Nuclear Inspector Be Added as Issue in Proceeding

ML20098G856
Person / Time
Site:	Byron
Issue date:	10/03/1984
From:	Mark Miller COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE
To:	Callihan A, Cole R, Smith I Atomic Safety and Licensing Board Panel
References
CON-#484-296 OL, NUDOCS 8410050608
Download: ML20098G856 (93)

Text

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a o su.m October 3, 1984 Ivan W. Smith, Chairman Dr. A. Dixon Callihan Administrative Judge Administrative Judge Atomic Safety and Licensing Board Union Carbide Corporation U. S. Nuclear Regulatory Com-P. O. Box Y mission Oak Ridge, Tennessee 37830 Washington, D. C. 20555 Dr. Richard F. Cole Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Re: In the Matter of Commonwealth Edison Company (Byron Nuclear Power Station, Units 1 and 2) Docket Nos. 50-454 and 50-455 c7/ Der" Administrative Judges: At the evidentiary hearings on August 1, 1984, the intervenors moved that certain allegations relating to the Authorized Nuclear Inspector at Byron be added as an issue in the proceeding. Certain documents were supplied to the Board and the parties by me in connection with that motion. There_has now been additional correspondence between Commonwealth Edison and The National Board of Boiler and Pressure Vessel Inspectors (" National Boiler Board") which deals in part with the subject matter of the intervenors' motion. In accordance with our obligations under the McGuire case, Duke Power Company (William B. McGuire Nuclear Station, Units 1 &

2) ALAB143,.6 AEC 623 (1973), enclosed are the following documents:

1. Letter dated September 6, 1984 from V. I. Schlosser of Commonwealth Edison to D. J. Mcdonald, Director of Inspections, National Boiler Board. 2. Letter dated September 10, 1984 from D. Elias of Commonwealth Edison to J. Blackburn of the Illinois Department of Nuclear Safety. 8410050608 841003 PDR ADOCK 05000454 Q PDR b e

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'i-JAdministrative Judges October 3, 1984 Page 2 3.

Letter dated September 10, 1984 from V. I. Schlosser of Commonwealth Edison to D. J. Mcdonald with ' exhibits. 4. Letter dated September 21, 1984 from The National Board of Boiler and Pressure Vessel Inspectors to Cordell Reed, Vice-President of Commonwealth Edison. l Yours very truly, l* bgz i MIM:es Michael I. Miller One of the Attorneys for Commonwealth Edison Company enc. . cc Service List w/ enclosures . m

z ME-1N 3' Comm:nw::lth Edis:n Byron Nuctear Station 4450 North Gerrnan Church R0ad Byron, Illinois 61010 September 6, 1984 LTR: PM-84-63 Mr. D. J. Mcdonald Director of Inspections National Board of Boiler and Pressure Vessel Inspectors 1044 Crupper Avenue Columbus, Ohio 43220

SUBJECT:

National Board Audit of the Byron Nuclear Station Units 1&2

REFERENCE:

National Board of Boiler and Pressure Vessel Inspectors (D.J. Mcdonald) Letter Dated August 17, 1984 to Commonwealth Edison (C. Reed)

Dear Mr. Mcdonald:

As a result of ceviewing the above referenced report, it has been determined that additional information and clarification of the responses to Hartford Steam Boiler Inspection and Insurance Company findings and concern are required. This additional information is identif.ied to the article number presented in the above referenced report. Article 6.1 provides Hartford Steam Boiler's statement that 100% reviews have been made of component support and 2" and under piping traveler packages as part of their N-5 Data Report review. This review of all traveler packages is considered to be the corrective action for this finding. Article 6.2 contains the forms that will be used by Hartford Steam Boiler Authorized Nuclear Inspectors to document their visual inspection of welds during pressure tests. Page 1 of 2 is the form that 4111 be used to document inspections prior to July 31, 1984 and pagu 2 of. 2 the form that will be used starting August 1, 1984. These form 1 vill be included as part of the installer's pressure test documentation package.

o. Director of Inspectors September 6 1984 _Page Two Article 6.3 is a copy of the audit performed by Hartford Steam Boiler of the use of a red star by Authorized Nuclear Inspectors as a status indicator. The audit concluded that the red star had not been used in lieu of a signature and date when the code, procedures, or documents required a signature and date. We believe that this additional information should resolve the audit teams questions with the Hartford Steam Boiler portion of the audit. V. I. Schlosser Project Manager Byron Station 'd q f. elS VIS/ML/jl:0031) cc: V. Schlosser 4 G. Sorensen R. Tuetken M. Lohmann K. Hansing W. Shewski B. Shelton J. Hinds NRC C. Allison NBB M. Sullivan NBB R. Holt NBB D. Stewart HSB B. Rainey HSB M. Somsag Hunter

A rrAcgMm7 / page 1 of 2 9/5/84 To: National Board Audit Team From: J.L. Hendricks, ANI - HSB

Subject:

National Board Audit Report, August 17, 1984 Article 6.1: - Authorized Nuclear Inspectors at the Byron Site waived review of process sheets for' ASME Section III, Class 2 & 3 pipe hangers and component supports from a period starting in November of 1979 un-til May of 1984. Finding 6.1.1: The National Board Audit Team is of the opinion that review of process sheets prior to issuance to production is a Code require-ment and that the Authorized Nuclear Inspectors and their super-visors deviated from the requirements of ASME Code Section III and the Hartford Steam Boiler SIS Inspection Handbook requirements by pemitting this practice. This is considered a finding. Opinion 6.1.2: The Audit Team has considered your response as stated in reference iii, paragraph 6.1.1. We also are aware that these practices have not been used since May 1984. The Audit _ Team, however, remains of the opinion that your response does not provide corrective action for the-items previously insta11ec Corrective Action: Due to the 100% review of all component support drawings and process control sheets as of 5/17/84 by the ANI and 100% final review of com. ponent support job traveler packages prior to N-5 data report sign-ing, we feel no corrective action is necessary on the items pre-viously installed. 3 Lk_ _

j-Page 2 of 2 e Article 6.1. : The HSB's ANI's ~ also waived review of process sheets for small bore piping from May of 1980 to Septerrber of 1980. Finding 6.1.1. : The National Board Audit Team is of the opinion that review of pro-cess sheets prior to issuance to production is a Code requirement and that the ANI's and their supervisors deviated from the require-ments of ASME. Code Section III and the HSB SIS Inspection Handbook requirements by pennitting this practice. This is considered a finding. Response 6.1 : (Refer to the second paragraph of 6.1) The concern is that the ANI did not review isometric drawings and process sheets for 2" and under Code piping during the period be-tween 5/1/80 and 9/23/80. In lieu of the above noted, the ANI was specifically involved in the following: A) 100% review of Code related Welding Procedure Specifications B) 100% review of Welder Perfonnance Qualification Records C) 100% review of Certified Material Test Reports D) 100% review of NDE Reports E) 100% Visual Weld Inspection during Hydro / Pneumatic Tests F) 100% of Final Job Traveler Package Review It should also be noted that the ANI was making in-process inspections during the indicated time period. (See Attached) Corrective Action .The review of all'2" and under process sheets was resumed on 9/23/80. Due to the fact that all job traveler packages were reviewed, signed off as accepted in accordance with the requirements of the Installers accepted ASME Section III program, prior to the certification of N-5 Data Reports, no other corrective action on previously installed items is necessary. A VV'* J. y HM k &N Pk/W

ATTACHMENT 2 Page 1 of 2 ANI PRESSURE TEST WITNESS FORM In response to National Board Audit finding 6.2 in audit report of 8-17-84, this form will be added to the applicable Pressure Test Directive & Report Forms prior to 7-31-84. Date of Test: Witnessed Pressure Test #: Class: Design Pressure: Gages: Test Pressure Min.: Range: Test Pressure Max.: Weld Exam Pressure: Due: Cal: P & ID #: Hunter SIP #: 4.405 R/2 Test Results: Welds involved in this test are listed in iso drawings that are traceable from the P & ID (Piping & Iden. Dwgs.) listed on the Pressure Test Directive. The ANI involvement in this test included a final visual examination of welds for leakage & final acceptance. The ANI is assured that all welds were inspected by the Certificate Holder as required by ASME Section III Par. HA 5280. ANI Signature and Date

Pn &c 2 of 2 i l DOCUMENTATION OF PRESSURE TEST subsequent To 7-31-84

1. 6 The A.N.f. shall document his inspection activities during the test on the conwents section of the Pressure Test Directive. When there is insufficient space in this area, the remaining information will be added on the back of the white copy of the Pressure Test Directfve.

Individual weld inspections shall consist of a check for leakage and an inspection for Code compliance. The inspections shall be documented in one or more of the following manners, as appropriate. 100% inspection of all welds involved in the Pressure Test - "A.N I. inspection of all welds within Pressure Test boundaries." Sign & Date 100% inspection of all welds listed on an Iso or several Iso's "A.N.I. inspection of all welds listed on the following Iso's:" XxxxXxxxXxxXxxxxxxXx XXXXXXXXXXXXXXXXXXXX XXXXXXXXXXXXXXXXXXXX Sion & Date here niether of the above situations are applicable the individual welds will be listed : A.N.I. Inspection of Welds: Iso # XXXXXXxxXXXXxxxxX FW # XxXXxx XXXXXXXXXXXXXXXXy XXXXXX Stan & Date l-f $,Mc$W r/nfe4 1

kTTAC H H E UT b DATE: August 3, 1984 TO: National Board Audit Team FROM: J.L. Hendricks - ANI - HSB

SUBJECT:

Response to Audit Concern 6.3.1 (Audit dated 7/16/84) This audit was conducted as agreed to in our response #6.3.1. It has been accomplished by the random selection and re-review of job traveler packages (JTP's) to assure that the red star was not improperly used. Four JTP's have been selected from each of the following code systems and ro-reviewed per the checklist attached (Checklist also used by ANI's during final review). AB, AF, BR, CC, CS, CV, 00, FC, FP, FW, GW, IA, MS, h', OG, PC, PR, PS, RC, RE, RF, RH, RY, SA, SD, SI, SX, VQ, WE, WM and WO. Included in the JTP's selected are an assortment of large and samil bore piping. component supports, carbon and stainless steel material, and Class 1, 2, and 3 systems. The total of 126 JTP's that were reviewed showed no signs of improper usage of the red star. l During the audit, no problem areas were identified tnat called for further invostigation. The Red Star was never at any time used in lieu of a signature and date whcre a signature and date were called for by code, procedures or the individual document. NOTE: audit checklist and results available in ANI l files. p wh +M Le 18-19' l l

i JTP REVIEW l Final Review Check List of Piping Travelers 1. Process Sheet - Travelers A) Preliminar, review of traveler - signed and dated by Eng., QA, and ANI. B) All hold and witness points satisfied QA and ANI. C) NDE performed and final acept (green copy) attached to traveler. D) Material mark number or heat numbers (if applicable) are entered on traveler. E) WMSR's are attached and information from them entered on back of traveler. 2. Field Orders A) Must be initialed and dated by foreman accepting the material.. B) The Class of material must be entered (Class A,B,C, etc.). C) Heat mark number must be entered and traceable to the traveler and the material. 3. Rework Requests A) Handled in the same manner travelers are. B) ANI to initial and date at the bottom to show final acceptance. 4. T.A.R. - (lemporary Attachment Reports) A) QC_signoff for location of T.A.R. and blending in. B) the appropriate NDE performed. 5. RND's and NR's A) Come thru the ANI on an ongoing basis and are reviewed at that time, signed and dated. At the time of final review, they will not be in the JTP, but will be entered prior to record turnover to the Owner. J

6. Discrepancy Reports A) Review and either accept or reject. B) QA resolution and signoff. - 7. Items 1,2,3,4 and 6 will be stamped with a red star to show ANI acceptance, also initial and date FIR (Final Insp. Report) form under appropriate items. ANI signoff on the latest rev. of the FIR form will also indicate ANI review of the entire package. Use of red star discontinued 7/17/84. Use below listed stamp for ANI review. A. N. l. REVIEV/ PAT 2 ] ACCEPT ]SEEC0:ifi.L:eT PRELIMINARY FINAL 8. ANI shall review any other documentation he deems necessary to complete his review of the applicable JTP. 9. A new FIR form initiated by Hunter Corp. is now in effect. ANI need only sign at the bottom, not the individual items as listed'in #7 of this procedure (check list). r

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• orn Ferst N1tional Plaza Chicago Hhnois Sh s C,'/' Addrzss RIply to Post Office Box 767 Chicago, lihnois 60690 September 10, 1984 Mr. J. Blackburn Illinois: Department of' Nuclear Safety 3150 Executive Park Drive Springfield,-Illinois 62706

Subject:

Byron Station Units 1 & 2 ASME Code Case N-302

Dear Mr. Blackburn:

Commonwealth Edison Company, at its Byron Nuclear Station is using ASME Division 1 Section III Code Case N-302 " Tack Welding". This Code Case has been accepted with no clarification by the NP.C in Reg. Guide 1.84, revision 22 dated July, 1984. Very truly yours, . S! ^ D. Elias ] Project Engineer BA/sb/4977b B. Annis B.R.Shelton/ cc: 'M. Lohmann Mr. Don Mcdonald - The National Board of B&PV Inspectors 1055 Crupper Avenue Columbus, Ohio 43229 I l j

C:mmonw: lth Edis:n (. Byron Nuclear Station 4450 North Gerrnan Church Road Byror, Ilknots 61010 September 10, 1984 LTR: PM-84-64 Mr. D. J. Mcdonald Director of Inspections National Board of Boiler and Pressure Vessel Inspectors 1044 Crupper Avenue Columbus, Ohio 43220

SUBJECT:

National Board Audit of the Byron Nuclear Station Units 1 & 2

REFERENCE:

(i) National Board of Boiler and Pressute Vessel Inspectors (D.J. Mcdonald) Letter Dated Augurr. 17, 1984 to Commonwealth Edison (C. Reed) (ii) Commonwealth Edison (V. Schlosrar) Letter Dated September 6, 1984 to National Board of Boiler and Pressure Vessel Inspectors (T/. J. Mcdonald)

Dear Mr. Mcdonald:

Following a review of reference (#,), it was determined that additional information and clarification of certain responses should be provided to the National Beard. Reference (ii) provided this information for those items :elati'.g to the Hartford Steam Boilet Inspection and Insurance Company. This letter contains clarif'. cation on the remainder of the items and a revised response to the finding in Article 3.4. 3.0 Hunter Corporation Article 3.1 Site Specific Addende to Sections 2 and 4 of the Hu';ter Corporation Quality Assurance M9aual have been approved which fequire Authorized Nuclear Inspector (A.N.I.) review of Continuation Process Sheets. These revisions e.re contained in Exhibits 3.1.1.A and 3.1.1.B with a revised copy o' the Table of Contents for Byroa Station Site Addenda in Exhibit 3.i.l.E. Exhibit 3.1.1.C contains the amendment to Site Implementat ion Procedure 4.000 which requires A.N.I. review of Continuation Process Sheets. An audit was performed on 40 job traveller packages to ' determine if Continuation Process Sheets had been used properly. The audit found no loss of accountability for work or non-compliance with code installation and inspection requirer 2nts. The audit report is contained in Exhibit 3.1.1.D.

[. Mr. D. J. Mcdonald September 10, 1984 LTR: PM-84-64 Page Two Article 3.2 Hunter Corporation Site Implementation Procedure 6.501 has been amended per. Exhibit 3.2.1.A to require Hunter's Level III to approve N.D.E. technician qualification records. Exhibit 3.2.1.B contains the records of Hunter's Level III re-evaluation of N.D.E. technician qualifications. A review was also performed by Hunter's Level III of the qualifications of N.D.E. Technicians who previously have performed work at Byron Station. The results of tis review and the responses from the N.D.E. sub-contractor are contained in Exhibits 3.2.1.C and '3.2.1.D, respectively. Article 3.3 'The revised interface agreement between Hunter Corporation.and Pittsburgh Testing Laboratories, the Byron Site N.D.E. Contractor, is provided in Exhibit 3.3.1.A. This revised agreement eliminates the arbitration clause. Exhibit 3.3.1.B summarizes the review performed by Hunter's Level III of radiographic film that had been accepted under the arbitration clause without Hunter Level III involvement. Article 3.4 The National Board audit team noted that Hunter Corporation did not document visual examinations of tack welds on small bore piping or component supports. Finding 3.4.1 The National Board audit team is of the opinion that tack welds which are to be incorporated into the final weld shall be prepared and examined in accordance with the requirements of the appropriate subsection of ASME Section III. The team is further of the opinion that these examinations must be documented. This is considered a finding. Discussion 3.4 Our understanding of Paragraph NX-4231.1 was that the required examination of the tack welds was to be made by the qualified welder using qualified procedures. This rationale was derived from the words in that paragraph addressing incorporation of tack welding after fit-up, the weld will be completed and that the qualified welder is capable of examining the weld to assure that proper quality is attained or that defective tack welds are removed. Further to this point, we believe this position is reinforced by Code Case N-302 which is stated as an alternative to NX-4231.1. Neither paragraph NX-4231.1 or Code Case N-302 require the examination to be documented.

e Mr. D. J. Mcdonald September 10, 1984 LTR: PM-84-64 Page Three In order to meet the above understanding, contractor welding procedures were written with requirements for the examination of tack welds and the removal or repair of tack welds that are defective prior to incorporation into the final weld. Welders were trained in this and other procedure requirements prior to being certified to perform welding. Contractor Q.C./Q.A. Personnel also performed surveillances and audits to verify that welders are complying with weld procedure requirements.- All completed welds received documented final visual inspections by Q.C. Welding Inspectors. Response 3.4.1 Since the requirements of paragraph NX-4231.1, as modified by Code Case N-302,.have been met during installation work at Byron Station, we have been in compliance with the ASME Code and, therefore, no corrective action regarding hardware is required. The use of Code Case N-302 has been adopted and limited to tack welds on small bore piping socket welds and component support welds. The appropriate design specifications and N-5 Code Data Reports will be revised to reflect the use of Code Case N-302. The Regulatory Agency has approved the use of this Code Case per Regulatory Guide 1.84. The Jurisdictional Authority will be notified of the adoption and use of Code Case N-302. These ections will be completed by October 15, 1984. Article 3.5 This item should be resolved based on additional information supplied for Article 6.2 of Reference'(i). 4.0 Nuclear Installation Services Company (NISCo) The response for NISco is the same as included in Article 3.4. 5.0 Powers-Azco-Pope (PAP) The response for P.A.P. is the same as included in Article 3.4. Summary Additional responses and clarifications have been provided in this and our September 6, 1984 letter to D. J. Mcdonald following our review of reference (i) and discussions with the audit team. As a result of these communications, we believe that acceptable responses have been provided for all findings and concerns. The revised response to Paragraph 3.4 indicates that the treatment of tack welds has complied with Code requirements and, therefore, has no impact on the quality of hardware at Byron Station.

i e Mr. D. J. Mcdonald September 10, 1984 LTR: PM-84-64 Page Four The responses other than Paragraph 3.4 described audits, reviews, or procedural revisions to be accomplished. The audits and reviews were intended to assure proper completion of past work associated with Unit 1. The procedure revisions are being made to correct minor programmatic deficiencies and preclude the possibility of A.S.M.E. Code Violations on future work. On this basis we believe that the corrective actions have been completed for Unit 1. The remaining procedure revisions will be approved, implemented, and ready for closeout by the audit team by October 15, 1984. We trust that the information provided in this response and directly to the audit team members during their site visits has been responsive, and will allow a prompt written closeout to be provided by the National Board for Unit 1. ff 4^""" V. I. Schlosser Project Manager Byron Station IS/ML/sg:0031j -cc: V. Schlosser G. Sorensen R. Tuetken M. Lohmann K. Hansing W. Shewski B. Shelton E. Hemzy J. Hinds, NRC C. Allison, NBB M. Sullivan, NBB R. Holt, NBB D. Stewart, HSB B. Rainey, HSB M. Somsag, Hunter R. Larkin, P.A.P. D. Stringer, NISCo

F Se-t, No. 2 QUALITY ASSUR ANCE PROGRAM ,/ Page 2-5 FOR ASME BOILER AND PRESSURE i VESSEL CODE, SECTION. III - sm ) g,,, i NUCLEAR POWER PLANT COMPONENTS Date 8/30/84 HUNTER CORPOR ATION BYRON STATION SITE ADDENDA Subarticle 2.3.a is revised as follows: 2.3 Field Changes a. When the need for a Design Change is recognized during the course of fabrication or installation and it is necessary to proceed with the change quickly, a Customer or Owner adopted Design Change docunent is obtained to authorize the change. The generation of Design Change documents is in accordance with the Customer or Owner's Quality Assurance Program. o n, - g rg {, nr vJnt \\ n J E. ) 'sb ) PREPARED BY DATE ff AUTHORIZED NUCLEAR REVIEWED BY mhO INSPECTOR DATE 9-6 -E'/ ~ REVIEWED BY PROJECT MANAGER DATE N f'# I REVIEWED BY I I N PROJECT ENGINEER DATE 9/S[ff / QUALITY ASSURANCE // APPROVED BY M A n a r f a m > MANAGER DATE 9/p/// AUTHORIZED MUCLEAR lau,0h. f,/p/W ACCEPTED BY INSPECTION SPECIALIST DATE

t Esnoeur 3.1.t A PA c-E E of ? Sdet. N3. 2 QUALITY ASSURANCE PROGRAM P2ge 2-6 FOR ASME BOILEli AND PRESSURE Rev. 1 VESSEL CODE, SECTION Ill - 3 N. Date 8/30/B4 NUCLEAR POWER PLANT COMPONENTS HUNTER CORPOR ATION BYRON STATION SITE ADDENDA Revise Article 2.3.b as follows and delete article 2.3.c. b. Once doctanented approval of the Design Change is received, the Field Engineer initiates Job Traveler' Package revisions, or the Craft Supervisors mark up the changes in the Job Traveler Package. The Field Engineer logs all changes in the Customer Doctanent Index (Figure 4). m n e -- n nn ~ i1 V-- J V dj w i PREPARED BY - 9; AUTHORIZED NUCLEAR DATE /' f. / -= REVIEWED BY 7 INSPECTOR DATE 9 -(o -F 4 REVIEWED BY PROJECT MANAGER DATE [-7'N REVIEWED BY T I PROJECT ENGINEER DATE9/4k4 QUALITY ASSURANCE APPROVDBYpo[ rer r r fa m a MANAGER DATE #/7d'r AUTHORIZED flVCLEAR ACCEPTED BY INSPECTION SPECIALIST DATE 9/7/F'/

] cr nues, s..v e noe se r L _. - a 1

i. No.

4 QUALITY ASSURANCE PROGRAM 4-6 FOR ASME BOILER AND PRESSURE .1".._ _ ge VESSEL CODE, SECTION 111 -

• L-1 gy, i

NUCLEAR POWER PLANT COMPONENTS Date 8/29/84 HUNTER CORPOR ATION Sheet 1 of 2 BYRON STATION SITE ADDENDA Revise Article 4.3.a and previously added 4.3.5 as'follows and add.4.3.c. 4.3 Work Change System a. Changes from the originaT design are approved by the customer or Nner and incorporated'into the Job Traveler Package by the Field Engineer or the Craft Supervisors (for additional details, refer to Section 2, Drawing and Specification Control). b. New Process Sheets are prepared, existing Process Sheets are revised, or Continuation Process Sheets are added to the Job Traveler Package. New Field Orders, Weld Records and NDE Requests are prepared accordingly. The Quality Assurance Supervisor directs review and approval of new or revised Job Traveler Packages issued by the Field Engineer and submits them to the Authorized Nuclear Inspector for review and acceptance prior to release for construction.. Continuation Process Sheets for Code Jurisdic, tion work are presented to the Authorized Nuclear Inspector l for review and acceptance prior to their implementation in the construction operation. c. The Craft Supervisors may direct the addition or deletion of l welds or bends in 2" and under piping. The additions or deletions are j docurnented on the Construction Drawings by the Craft Supervisors and Continuation Process Sheets are added to the Job Traveler Package. Design Changes initiated by the Craft Supervisors on Component Supports may 8 l t v Ji t ,k a s# J

E w eBer 3 I. I. 8 PA s-E 2 or 2. Sset. No. 4 QUALITY ASSURANCE PROGRAM = Page 4-6 FOR ASME BOILER AND PRESSURE VESSEL CODE, SECTION 111 - sm

g3y, 3

NUCLEAR POWER PLANT COMPONENTS Date 8/29/84 HUNTER CORPORATION Sheet 2 of 2 BYRON STATION SITE' ADDENDA add or delete welds so these Construction Drawings are also marked up to docunent additions or deletions and Continuation Process Sheets are added to the Job Traveler Package as necessary. (For additional details, refer to Section 4, Control cf Construction Processes.) ( l l \\ vuii L _ U v u,,y n nn 5 q q a. I PREPARED BY DATE 8. f. / / AUTHORIZED NUCLEAR REVIEWED BY O INSPECTOR DATE 9-6 -8'/ k PROJECT MANAGER DATE ['7-8 REVIEWED BY REVIEWED BY N. [ PROJECT ENGINEER DATE9/5d# / QUALITY ASSURANCE '/ APPROVED BYMA nurSn,,JtANAGER DATE f///// / 2C/ a ---AUTHOR 17FD HUCLEAR a

Ex tnBtr 3.l.l.C PA H lc f I ~ HUNTER CORPORATION =H PROCEDURE AMENDMENT AUTHORIZATION Procedure Page Article Type /No. 4.000 Rev 14 DU.e 6/12/84 Affected 5 of ol Affected 4.2 Add new Article 4.2.3.A as follows: Any time continuation process sheets are initiated by Production (as addressed in Section 8 for piping and Section 10 for component supports), the continuation pro-cess sheets shall be presented to the ANI for his review prior to any work being perfonned on additional NF welds on camponent supports or additional welds or bends on 4 2" piping. 'q j~ ~ n 9 qnm ji,,) 'N. j 1 J-- J J v l l Prepared by/Date Approved by/D e / ?'b-S V7) $N//f Quality %ssiar ce 5'perv(sof l Concurre e by/Da Q g,y ql7l,]tj pp Owrier Station Constructior( Project Manager / g, j,',, p g gj,,,/ /

'j,,,,.,

Qg 9/ gyp OwnErfaTityAssurancy l Project Engineer '/ Accepted by f ht4 f///$f

9. X & sided y/7k 4 l

Welcing Supervisof-duthorized Nuclear Inspec(or/ l l Corrected to procedure - Form HC-147 R/1 3/31/84

Exhibit 3.1.1.D Page 1 of 6 [ musumummer 4-m. HUNTER CORPOR ATION p c. 97% 5 = 5 s -2........ .,:w.A em 39 94 e000 m. P scoo AUDIT REPORT AUDIT NUMBER 102-3 SPECIAL AUDIT AUDIT DATES: August 27, 1984 to August 30, 1984 INTRODUCTION: This cudit was conducted to verify that continuation work performed on ASME Section III, Class 2 (B) and 3 (C) small bore (6 2") piping has been performed utilizing correct materials, special processes, examinations and inspections. This audit is entitled a Special Audit as it is an unscheduled audit and responds to requirements set forth in Commonwealth Edison Company letter PM-84-49, dated August 1, 1984 The Audit Checklist was comprised of four crons of concern dealing with small bore continuation work, and each area will b3 discussed in this report. ENTRANCE MEETING: An entrance meeting was held on August 27, 1984. Persons in attendance for the .m30 ting were as follows: R. Fry Lead Auditor K. Plumb Auditor J. Fox Auditor / Training Coordinator J.L. Woldridge CECO QA Supervisor E. Briette CECO QA L. Hadick QC Supervisor SAMPLE BASE: 4 scmple base of 40 Job Traveler Packages (JTPs) was randomly selected for

-oview purposes for this audit.

An effort was made to select JTPs that evidsnced a large share of continuation work (mare than one or two

ontinuation process sheets), covering the time period from 5-8-80 to present

tho date of approval of the QA Manual addenda which allowed field

ontinuation.) Beyond this, no other review took place prior to JfP selection.

~ho 40 JTPs are as follows: S-CV-100-136 S-CC-100-10A S-CV-100-97 S-AB-100-107 S-CV-100-104 S-CC-100-108 S-CV-100-107 S-CC-100-14 S-CV-100-109 S-CC-100-41 S-CV-100-119 S-CC-100-45 S-CV-100-124 S-CC-100-46 S-SI-100-30 S-FW-001-51 S-SX-100-65 S-SI-001-28 ~. y, I J J l -I

Exhibit 3.1.1.0 Page 2 of 6 ( S-Sx-100-66 S-SI-001-33 .S-SX-100-70 S-SI-001-38 S-CV-100-1C S-SI-001-44 S-CV-100-4 S-SI-001-78 S-CV-100-SD S-SI-001-79 S-CV-100-18 S-SI-001-80 S-CV-100-23 S-SI-001-81 S-CV-100-32 S-SI-001-84 S-CV-100-34 S-SI-001-86 S-CV-100-35 S-SI-100-21 S-CV-100-36 S-SI-001-24 Tha-40 'JTPs and the continuation work contained therein were reviewed for matorial utilization and design criteria conformance, weld procedure utilization and applicability, examination of Class 2 welds and inspections of work performed. -DISCUSSION OF THE CHECKLIST QUESTIONS: 'Tho first area of concern for small bore continuation work was the utilization of material and _ that said material was used in accordance with the applicable dGsign criteria- (design table) set forth for the system's construction by sp9cification F2739. In ceder to verify compliance to the materials question, all material added to - th2 ' sys tem through continuation work was reviewed against the design table roquirements. Two JTPs out of the 40 reviewed did not utilize the pipe schsdule called for in the applicable design table. JTPs S-CV-100-124 and -S-CV-100-136, design tables 1408B and 34088, respectively, called for Schedule .40 for the pipe whereas Schedule 160 was installed. Research indicated that Hunter Engineering made the change from Schedule 40 to 160. initially, and the Production forces correctly requisitioned Schedule 160 pipe for the continuation work, due to the approval of FCR 13129 in February 1982. This FCR 011ows upgrading pipe'of schedule other than 160 to 160 for test connections, sample lines and root valves as ~ directed by the Owner. Therefore, the two JTP's had prior approval to upgrade the pipe schedules through an FCR. A - total of 11 J1 Ps with 14 welds had a non-dash weld number added to the -continuation process sheet by Production after obtaining the number from the Engineering Department. In other words, Production was forced to reroute the pipo.but had no downs tream weld to continue from. A number was obtained from Engineering, entered on the continuation process sheet and then Production centinued on from this number. Even though Engineering should have issued a Process Sheet for these non-dash welds, review of the 11 JTPs involved has d;manstrated Production requisitioned material that conformed to the desigr. criteria. Additionally, the other three areas of concern addressed in this cudit report (welding, examinations and inspections) were acceptable for these 14 welds.

5. r3 '9 T{i s'

\\ I i j h, n ; p-l3 i i U L L " "j

Exhibit 3.1.1.D Page 3 of 6 i Regardless, the intent of the procedure was violated in these cases and the practice shall discontinue. As agreed upon in the exit

meeting, Hunter Corporation QA letter number 738 has been written, approved and distributed that states when 'no downstream field weld exists, Production shall contact Engineering of the situation and Engineering shall revise the drawing to reflect the new field weld and Engineering shall issue a process sheet for the new weld.

The assigning of a weld number via telephone shall no longer be ellcwed. With-this discussion in mind, there were no deficiencies in the material used for continuation work in regard to conformance to design criteria for the 40 JTP's reviewed. The second area of concern dealt with welding and questioned if the welding performed on continuation work was done utilizing procedures qualified i r, cccordance with ASME Section IX for the specific application. All 40 JIPs reviewed indicated the Production forces utilized the weld procedure specifiec for the rest of the system, as initially dictated on the Process Sheets by Hunter Engineering and approved by QA and the Authorized Nuclear Inspector. All welds performed for the continuation work were socket welds and the WP5 utilized in each case was qualified to the socket weld application. Therefore. no deficiencies existed in the 40 JTPs for the weld procedures utilized anc their specific application. The third area of concern dealt with examinations performed on Class 2 (B) walds and weld repairs in order to verify the required examinations were parformed in accordance with Subsection NC 5261. A total of 23 JTPs (from the overall sample base of 40 selected) had continuation work performed that involved Class 2 welds, and therefore required examinations. A total of 207 wolds were examined in those JTPs with one rejected weld that required an RNC (Roport of Non Destructive Examination Defect). This weld, 1415-10 on cysten S-SI-001-80, had linear indications on the valve close to the weld show up or the PT examination. No welding was required--only buffing and blending and ar ecceptable PT examination was acquired as an RS-1 (re-examination). All other 206

welds, plus this re-examined

weld, had acceptable Non Destructive Excminations, be it MT on the Carbon steel continuation work or PT on the Stainless steel continuation work.

l l All 207 welds were reviewed for an acceptable report number in the J1P anc reviewed for the acceptable report filed in the QA Vault. All 207 had the ccceptable reports. The criteria entered on the report by the independent testing laboratory showing conformance and acceptance in all 207 cases was ASME Section III, Class B. Even though this is all that was entered on the ropcrt showing acceptance, this is acceptable due to the fact that the intorface agreement in effect at the time (and.in effect for all the JIPs rcviewed for this audit) Stated that the acceptance criteria was to the ASME Ceda, 1974 Edition. wi th Addenda through the Summer of 1975, unless otherwise spocified. Nothing else was specified, so per the interface agreement-al: occeptance criteria was to the 1974/75 Code. Therefore, no deficiencies were identified after a review of 23 JTPs containing 207 Class 2 welds. r~ n % i j 3,hjMd

i. Exhibit 3.1.1.D Page 4 of 6 1-Ths fourth' and final area of concern for this audit dealt with inspections and ' questioned if the inspections required by ' NC 4000 and ND 4000 have been

satisfied with respect to socket welded connections utilized on continuation

' work. For the time frame involved on these 40 JTPs as well as all small bore inspsetions, three procedures have been historically used. Up to March of 1981, Site Implementation Procedure (SIP) 5.502 was in effect and it covered visual inspections, including the use of qualified inspectors, inspection aids ond acceptable and unacceptable conditions to be evaluated at inspection. Inspsetion Instruction (II) #5 was in effect.until January of 1982 and it -contcined the same information as SIP 5.502 in' regard to visual inspections. In between the voiding of SIP 5.502 and the creation of II #5, the inspectors .clso utilized the criteria of the weld procedures. Finally, SIP 6.001, Visual Excmination and Verification, went in effect in January of 1982 and is currently in effect. Once again, the inspection criteria has remained the same for visual inspections and has been performed in accordance with the . procedures noted herein which are in compliance with the ASME Code, 1974 Edition with Addenda through the Summer of 1975. .Therefore, the final visual ~ inspections performed on continuation Class 2 and 3 walds has been and is per the criteria of approved procedures which correspond to the ASME Code. To further accentuate inspection of Class 2 and 3 walds to established criteria, beginning in August of 1982, QC inspectors sign c-stamp on the process sheets for Class 3 welds that states they have inspected and accepted the welds to the established criteria of SIP 6.001. Continuation welds also received fit-up and gap inspections as verified in the -AO JTPs. With the exception of 11 welds in two JTPs that had the fit-up waived por HC-QA-108, all welds received a fit-up and gap inspection. Note: The HC-QA-108 letter was utilized on co..tinuation and regular socket welds. No 'further discussion will be addressed as this is a previously identified topic between the National Board of Boiler and Pressure Vessel Inspectors and Hunter Corporation. f In regard to the fit-up and gap inspections performed, SIP 4.000 (Control of Construction - Process) states that verificatio1 of fit-up on socket welds is accomplished by backing the fitting off a minimum of 1/16", tacked and the gap verified by QC ' prior to the first pass. This is all done as one inspection and signsd off by QC on he Continuation Process Sheet. All welds, except for the 11 previously noted, had as acceptable inspection sign-off by QC for fit-up -and gap. inspection. Therefore, inspections performed (fit-up and gap and final visual weld inspection) on the sample base of 40 JTPs indicated compliance .with' established' criteria and no deficiencies were identified. a MW o \\ \\\\U 6 U.UU i !r J

Exhibit 3.1.1.0 Page 5 of 6 ( EXIT MEETING! An exit meeting was held on September 05, 1984. The persons in attendance were: R. Fry QA Lead Auditor K. Plumb QA Auditor A.T. Simon QA Administration Supervisor R. Lindsay Project Manager R. Morrison Project Engineer D. Cerasani Piping Engineer L. Hadick QC Supervisor E. Briette CECO QA PERSONS CONTACTED DURING THE AUDIT: K. Frey Small Bore Lead Draftsman L. Hadick QC Supervisor ' SCOPE OF ASSOCIATE AUDITORS INUOLUEMENT: -Carol Boehm and Patty Hesser, Associate Auditors, assisted K. Plumb and J. Fox in - reviewing the 40 JTPs and compiling documentation on all four areas of concern addressed in this report. AUDIT

SUMMARY

The purpose of this audit was to review field continuation work for compliance with Code requirements, with specific review of four areas of concern. This audit has demonstrated said compliance for the four areas. The lons deficiency identified in this report dealt with the assigning of a weld number when no downstream weld existed, and steps and specific directions have bien taken to eradicate this procedural violation. This audit is therefore considered closed and no follow-up action is required. -Tha audit team consisted of: C. Boehm QA Associate Auditor P. Hesser QA Associate Auditor K. Plumb QA Auditor J. Fox QA Auditor R. Fry QA Lead Auditor &~&,,r;gplt.L D

Exhibit 3.1.1.D Page 6 of 6 L' Roport' Prepared by: Y ~$ -l J. Fox, QA Auditor / Training Coordinator

Raport Reviewed by:

f-d ~lY R. Fry,.QA Le Additor Report App oved by: W//)'Y M.L. Somsag,-QA Supervisor -cc: K. Selman R. Lindsay A.T. Simon L. Hadick ~ R. Morrison M. L. Somsag K. Plumb J. Fox J. Hendricks E. Briette, CECO QA qi 1 FO flO )k [.3y u d J V L i 1

l* G m8:T

3. I.I. E PA &-E ld 3

.3'V Sect. No. QUALITY ASSURANCE PROGRAM 'i Page FOR ASME BOILER AND PRESSURE 3 VESSEL CODE, SECTION III, DIVISION 1 ~ Rev. 9/6/84 NUCLEAR POWER PLANT COMPONENTS Date HUNTER CORPORATION BYRON STATION SITE ADDENDA TABLE OF CONTENTS Corporate Manual Addenoa Page Revision Page Revision Nurr.bers Table of Contents 6 1,11.111 1 1,11,111 Statement of Policy, Authority and Responsibility iv SECTION 1. GENERAL 6 1-1 1.1 Responsibility of the Quality Assurance Organization 1.2 Organization Charts and Responsibilities of Other Personnel 1-3 1.3 Manual Control 1-4 1.4 Corporate Manual Changes 1-5 1.5 Delegation of Duties / Functions 1-7 1.6 Program Implementation 1-7 1.7 Training Program 1-8 1.8 Glossary 1-10 0 1-10,11 Corporate Organization Chart 1-12 Field Organization Chart 1-13 0 1-13 DRAWING AND SPECIFICATION CONTROL 6 2-1 [ 2. 2.1 Control of Design Documents 2-1 2.2 Customer Initiate:d Changes 2-4 2.3 Field Changes 2-5 1 2-5,6 2.4 Supplier Requested Changes 2-6 2.5 Preparation, Review, Approval and Distri-bution of Site Implementation Procedures 2-7 2.6 Description and Use of Forms 2-8 0 2-8 3. PROCUREMENT CONTROL 6 3-1 0 3-1 thru 3.1 Supplier Qualification 3-1 3-11 3.2 Processing Purchase Documents for Welding Procedure Qualification Specimen Exam-ination and Testing 3-3 3.3 Preparation and Approval of Requisition Documents 3-3 3.4 Receiving Inspection 'of Hunter Corporation Requisitioned Items 3-5 3.5 Receiving Inspection of Customer Requisitioned Items 3-7 3.6 Deficient or Nonconfonning Items 3-8 3-9 3.7 Item Storage and Disbursement 3.8 Description and Use of Fonns 3-11 s

Ex 9,orr I /. /5 PA6E 2o'-3 Y sect. No. QUALITY ASSURANCE PROGRAM il FOR ASME BOILER AND PRESSURE Page ~, 3 VESSEL CODE, SECTION III, DIVISION 1 Rev. 9/6/84 NUCLEAR POWER PLANT COMPONENTS HUNTER CORPORATION BYRON STATION SITE ADDENDA TABLE OF CONTENTS continued Corporate Manual Addenda Pace Revision _Page Revision Nu5bers 4. CONTROL OF CONSTRUCTION PROCESSES 6 4-1 / 4.1 Job Traveller Package System 4-1 4.2 Rework and Repair During the Construction Operation 4-5 4.3 Work Change System 4-6 1 4-6 Sht.1 4.4 The Completed Job Traveller Package 4-7 of 2 and 4.5 Description and Use of Foms 4-8 Sht. 2 of 2 5. WELDING QUALITY ASSURANCE 6 5-1 5.1 Qualification of Welding Procedure Specifications 5-1 5.2 Qualification of Welders 5-2 5.3 Welding Material Control 5-4 5.4 Description and Use of Foms 5-5 6. NONDESTRUCTIVE EXAMINATION (NDE) 6 6-1 2 6-1 thru 6.1 Selection of the Hunter Corporation 6-5 / Level III Examiner 6-1 6.2 Approval of the Customer Furnished NDE Organization 6-2 6.3 Approval of Subcontractor NDE Procedures 6-2 6.4 Approval of NDE Subcontractor Personnel Qualifications 6-3 6.5 Peports of NDE Results 6-3 6.6 Description and Use of Forms 6-4 7. CONTROL OF MEASURING AND TEST EQUIPMENT 6 7-1 0 7-O'added 7.1 Procurement of Peasuring and Test Equipment and Entry into the Control System 7-1 7.2 Equipment Recall and Calibration 7-3 7.5 Description and Use of Foms 7-5 8. POST WELD HEAT TREATMENT (PWHT) 6 8-1 8.1 Description of System Used 8-1 8.2 Record System 8-3 8.3 Description and Use of Foms 8-3 9. QUALITY ASSURANCE RECORDS 6 9-1 0 9-1 9.1 Receipt, Filing, and Control of Records 9-1 9.2 Preparation of Code Data Reports and Contract Compliance Certifications 9-3 9.3 Turnover of Records to the Customer or Owner 9-5 0 9-5 9.4 Description and Use of Foms 9-6 s

.nn... QUALITY ASSURANCE PROGRAM Sect. No. FOR ASME BOILER AND PRESSURE iii l% VESSEL CODE, SECTION III, DIVISION 1 Page _ 3 g,y, _ NUCLEAR POWER PLANT COMPONENTSHUNTER CORP 9/6/84 Date BYRON STATION SITE ADDENDA TABLE OF CONTENTS continued Corporate Manual Addenda Page Revision Pace Revision Numbers _ SECTION 6 10-1 AUTHORIZED NUCLEAR INSPECTOR Hunter Corporation Relationship with 10-1 10. 10.1 the Authorized Nuclear Inspector Provisions for Authorized Inspection 10-1 10.2 Agency Audits Designation of Authorized Nuclear 10-2 10.3 Inspector Inspection Hold Points NoTdestructive Examination and the 10-2 10.4 Authorized Nuclear Inspector Checklist of Final Documentation and 10-3 10.5 Code Data Reports 10-3 10.6 Description and Use of Forms 6 11-1 NONCONFORMANCES AND CORRECTIVE ACTION 11-1 Identifying and Reporting Nonconfomances 11-3 11. 11.1 Dispositioning of Nonconfomances 11-7 11.2 Corrective Action and Close Out 11-9 11.3 11.4 Description and Use of Foms 6 12-1

12. AUDITS 12-1 12.1 Planning and Scheduling 12-2 12-3 Audit System 12.2 Audit Reports and Corrective Action 12-4 12.3

12.4 Description and Use of Foms 13-1

13. APPENDIX 13-1 13.1 Exhibits of Referenced Forms

^ AUTHORIZED NUCLEAR REYTEWED BY S. g 4 6 M INSPECTOR DATE v///#4 7 PROJECT MANAGER DATE 7//f' REVIEWED BY DATE <?/6/84 REVIEUED BY T N D E PROJECT ENGINEER QUALITY ASSURANCE 7/ / DATE #/ r/N ~ APPROVED BY M / h m a f s,J MANAGER P A IST DATE 7/7 PV jo f, ACCEPTED BY,

~ Ex ossT 32lA Poe Ie2 ~ '[t HUNTER CORPORATION PROCEDURE AMENDMENT AUTHORIZATION Procedure Page Article Type /No. 6.5D1 Rev 9 Date 7/3/81 Affected 6 of13 Affected 6.4.2 Revise Articles 6.4.2 and 6.4.2.A on page 6 as follows: (This P.A.A. supercedes P.A.A. dated 8/2/84.) 6.4.2 The NDE Records Clerk shall verify that the NDE Technician who performed / interpreted the enmination is listed on the qualified NDE Technicians list for the esamination type (i.e. MT, PT, RT, UT) being reported. .A The qualified NDE Technicians List shall identify each individual currently certified by the NDE Sub-Contractor and accepted by a Hunter Corporation Level III Esminer, the discipline or type of exmination they are certified in, the Level of certification, the Hunter Corporation Level III Esminer acceptance date, the A.N.I. acceptance date the certification empiration date, and the eye esamination empiration date. The Quality Assurance Aeninistration Supervisor shall direct the preparation and update of the quallfled NDE Technicians List. Preparation and update shall be based upon correspondence from the NDE Sub-Contractor and a Hunter Corporation level III Emminer. The Quality Assurance Aeninistration Supervisor shall dirc:t a monthly review to determine which Technicians will require re-certification or eye examinations during the following month and advise the NDE Sub-Contractor and a Hunter Corporation level III Esminer so that the flow of work ulli not be interrupted. The quallfled NDE Technicians List shall be updated as re-certification occurs, eye exminations are passed', or new Technicians are added. Of b'~~ } ~ } hF g d dE ll \\ ,,,, l,, J gj g w Prepared by/Da e Approved by/Da 4h//f 42 .m Ob/7Y .n Quality %ssur uperth s6r Concu ence e g 9j?/fp ,,[ ,,y p 7./p Owner Station Construction Project Manager Q,[p}[y 0),,f-ll 2.k M_g 9[([ff Owntr plitf Assuran~cef 7 Project Engineer // Accepted by lO & f///J%f [t. Y$db V// W Weloing Supervisor Kuthorized Nuclear inspectet / Corrected to procedure - Form HC-147 R/13/31/84

Ex n g 6er S. 2. l B VA &E d of 2. [)' HUNTER CORPOR ATION PROCEDURE AMENDMENT AUTHORIZATION I Procedure Page Article Type /No. 6.501 Rev 9 Date 7/3/81 Affected 7 of 13 Affected 6.4.2.B..C and.D Revise Articles 6.4.2.B and C and add Article.0 as follows: (This P.A. A. supercedes the P.A. A. dated 8/2/84.) 6.4.2.8 If an NDE Technician is found to not appear on the current list, the NDE Records Clerk shall segregate the suspect NDE reports and retain them until the Technician is listed. The NDE Records Clerk shall also notify the Quality Control Supervisor and the QAAS of the condition. 6.4.2.C The QAAS shall investigate the condition and contact a HC Level III to determine qualification of the suspect Technician. Upon approval of the Technician by a HC Level III, the QAAS shall direct the addition of the Technician to the NDE Technician Qualification List. 6.4.2.0 Any NDE performed / interpreted by a Technician who is not qualified (in the judgement of the HC Level III) shall be reperformed/ reinterpreted by a qualified Technician. 1 Y i., f L L _ s] O F } ll ~~ ivJa A v Prepared by/Da e Approved by/D e 'l?2 hh/7Y f llN .xr n i /// Quality Tssuragpervisof Concurr3nceb. e,

p. 7' %g.

. 9/7/g4- [- f p-/e/ Owner Station Construction Project Manager gg['((.,./ G/J/j"//. g, g gg Owner 4Fality Assur4 ce Froject Engineer // Accepted by f///// DX klNt$ b 9 bY kelcing Supervisoi-Atithorizec Nuclear Inspectof / Corrected to procedure - Form HC-147 R/1 3/31/84

V Exhibi t 3.2.1.B Page 1 of 21 e H me HUNTER CORPOR ATION 3800 1797H STAEET HAVVO*,0 eiDtAN A 46323 r2196 845 9000 r312i 7318000 Date 71784 APPROVAL OF PERSONNEL RECORDS FOR NONDESTRUCTIVE EXAMINATION PROJECT: Commonwealth Edison Company s Byron Nuclear Generating Station, Byron. Illinois SUBCONTRACTOR: Pittsburgh Testing Laboratory 360 222067 Name William U. Adachi Social Security No. Penetrant Testing (PT) [t!an'oNic g [ N' es Method Radiographic Testing (RT) Level til /! ~ // ~ Date of Certification or Recertification // ~ //- 85 Due Date of Recertification Date of Eye Examination /0 - /i-[7 Due Date /8-/9 .PY The personnel records of the above candidate have been found acceptable, therefore this becomes a valid approval for the above activity. Hunter Corporate Level 11 Mf /[f John H. R'otartsofi Dan / go,itit:1<:.l] W ,L 1

r Exhibit 3.2.1.B Page 2 of 21 mesammmum H m. HUNTER CORPORATION 3800 t?97M STAEET WAWCNC INDIANA d6323 f2191845 8000 13?2> ?3180C0 Date 71684 APPROVAL OF PERSONNEL RECORDS FOR NONDESTRUCTIVE EXAMINATION PROJECT: Commonwealth Edison Company s Byron Nuclear Generating Station, Byron, Illinois SUBCONTRACTOR: Pittsburgh Testing Laboratory Name Deve A.Gamhart Social Security No. 3414 6-6706 Method Penetrant Testing (PT) (,ygg 11 Date of Certification or Recertification M-2 7-83 Due Date of Recertification 9 BG l Date of Eye Examination //- /f-83 Due Date W-/f-84 i Tlie personnel records of the above candidate have been found acceptable, therefore l this becomes a valid approval for the above activity. 1 Hunter Corporate Level 111 /_ 4

1. 4 l

John H. Robertson ' Dpe / I i 1 VVi1 1\\J___.J sul 1 g gen mm

j 6 Exhibit 3.2.1.B Page 3 of 21 H ummuumani - HUNTER CORPOR ATION 3800 179TM STQEET HAMMOND INDIANA d6323 s219e 845-8000 8312 731 8000 l Date 7 16-84 APPROVAL OF PERSONNEL RECORDS FOR NONDESTRUCTIVE EXAMINATION PROJECT: Commonwealth Edison Company's Byron Nuclear Generating Station, Byron, Illinois SUBCONTRACTOR: Pittsburgh Testing Laboratory 341'488708 Name Dave A.Gamhart Social Security No. Method Magnetic Particle (MT) Level Il Date of Certification or Recertification 9'- 2 7' 6 3 Due Date of Recertification 4'-27-66 Date of Eye Examination

1. -/f-8.3 Due Date Y-/8 ~8 Y The personnel records of the above car'didate have been found acceptable, therefore this becomes a valid approval for the auove activity.

Hunter Corporate Level i /# M Joh'n d.dobErtson Dge / 'O O ] 9 1]1h1l'VS.,qivVii,',\\d s I j ' )1 l W y

r i Exhib M 3.2.1.B Page 4 of 21 MH M. HUNTER CORPOR ATION 3800 1797H STREET HAYMOND INDIANA 26223 12?91845 8000 a3'12i 731-8000 Date 71684 APPROVAL OF PERSONNEL RECORDS FOR NONDESTRUCTIVE EXAMINATION PROJECT: Commonwealth Edison Company s Byron Nuclear Generating Station, Byron, Illinois SUBCONTRACTOR: Pittsburgh Testing Laboratory Name John D. Green Social Security No. 18M24390 Il Method M89netic Particle Testing (MT) g,y,g Date of Certification or Recertification Y-2 8 - [3 Due Date of Recertification k~29~85 Date of Eye Examination 6 - /h^~[I Due Date [-/['[Y The personnel records of the above candidate have been found acceptable, therefore this becomes a valid approval for the above activity. Hunter Corporate Level i 1 / 8 John H. sobert'on Ddte / s g, Qb{t 3 i,IV L _ b ] O f ) y 'yq^,f'D n l I i JV. I

Exhibit 3.2.1.B Page 5 of 21 mH m. HUNTER CORPOR ATION 3800 1797H STAEET HAvvCN3 INDIANA 46323 s2t9: 845 8000 #3t2s 73t 8300 Date 71684 APPROVAL OF PERSONNEL RECORDS FOR NONDESTRUCTIVE EXAMINATION PROJECT: Commonwealth Edison Company : Byron Nuclear Generating Station, Byron, filinois SUBCONTRACTOR: Pittsburgh Testing Laboratory Name John D. Green Social Security No. 18N2 6390 II Method Radiographic Testing (RT) Level b ~ /[~ [8 Date of Certification or Recertificatien 5-/7~ N Due Date of Recertification d- /f'I8 Due Date [ ~/f-f Y Date of Eye Examination The personnel records of the above candidate have been found acceptable,therefore this becomes a valid approval for the above activity. 7// fY Hunter Corporate Level 11 / d4 Joh'n H. F(obertson' Dan / l .\\ V V 1Y i i1 L 'gh v ~

c...u... :..

Exhibit 3.2.1.B Page 6 of 21 H HUNTER CORPOR ATION 3800 1797H STAEET MAMMO*eO INDIANA 46323 #2'9'845-8000 r3'2i '318000 71684 Date APPROVAL OF PERSONNEL RECORDS FOR NONDESTRUCTIVE EXAMINATION PROJECT: Commonwealth Edison Company : Byron Nuclear Generating Station, Byron, Illinois SUBCONTRACTOR: Pittsburgh Testing Laboratory Name John D. Green Social Security No. 1W24390 Method Penetrant Testing (PT) Level 11 Date of Certification or Recertification / ~ /2 ~ E8 Due Date of Recertification /- /2 -85 l Date of Eye Examination 6 - //~ 82 Due Date [ ~ M ~I7 The personnel records of the above candidate have been found acceptable, therefore this becomes a valid approval for the above &ctivity. l Hunter Corporate Level ill

1. /

~' John H. Robertson fate / it O L 7 1 m 33< u uu I

Exhibit 3.2.1.B Page 7 of 21 ammmmmmes H am HUNTER CORPORATION 3800 - 1797H STAEET HAvvCND INOiANA 45323 2'9i845-8300 f 312' 73 t 8000 Date 71684 APPROVAL OF PERSONNEL RECORDS FOR NONDESTRUCTIVE EXAMINATION PROJECT: Commonwealth Edison Company s Byron Nuclear Generating Station, Byron, Illinois SUBCONTRACTOR: Pittsburgh Testing Laboratory Name R bort W. Hachmeiste' Social Security No. 352 6 0 Method Radiographic Testing (RT) Level 11 Date of Certification or Recertification Y~/'83 Due Date of Recertification 7 '! ~ Date of Eye Examination 8 ~ 2I~82 Due Date 8-2f~ff The personnel records of the above candidate have been found acceptable, therefore this becomes a valid approval for the above activity. Hunter Corporate Level 4f/ ~ John H.'Rdbdtson D' ate / b YT b J i_v s m ,{

l Exhibit 3.2.1.B Page 8 of 21 M H HUNTER CORPOR ATION 3800 179TH STAEET HAMMOND 'NOiANA 46323 a2'9i 8J$ 6000 (312? ?3f 8000 Date 7 ts 84 APPROVAL OF PERSONNEL RECORDS FOR NONDESTRUCTIVE EXAMINATION PROJECT: Commonwealth Edison Company's Byron Nuclear Generating Station, Byron, Illinois SUBCONTRACTOR: Pittsburgh Testing Laboratory Name Charles H. Kessel Socia! Security No. 204-34 7154 Method Magnetic Particle Testing (MTl Level 13 Date of Certification or Recertification 2 FY 2~22~87 Due Date of Recertification Date of Eye Examination f-M-0) Due Date f #/ - 6 '/ The personnel records of the above candidate have been found acceptable, therefore this becomes a valid approval for the above activity. Hunter Corporate Level ill / 4 [ ~ John H. sobe/ts'trn Dyfe' / X 0 m nCC iG I ?Y

Exhibi t ',.2.1.B Page 9 of 21 -n m' HUNTER CORPOR ATION 3eM.1797H S' AEET HAMMONO INDIANA 46323 *219i 845 80c0 3t2t 7319000 Date 71684 APPROVAL OF PERSONNEL RECORDS FOR NONDESTRUCTIVE EXAMINATION PROJECT: Commonwealth Edison Company's Byron Nuclear Generating Station, Byron, Illinois SUBCONTRACTOR: Pittsburgh Testing Laboratory Name Charles H. Kessel Social Security No. 204 34 7154 Method Ultrasonic Testing (UTl (AWS Only) Level 38 Date of Certification or Recertification Y-8-82 i~2-Of Due Date of Recertification Date of Eye Examination 8-14-82 Due Date f-l#/-FI The personnel records of the above candidate have been found acceptable, therefore this becomes a valid approval for the above activity. Hunter Corporate Level 111 /# ' John H. Ffob4rtion (( ate / i 'k

LXn1Di t J.4. A.D VG9e AU v. 41 m H m* HUNTER CORPOR ATION 3830 179T* S'*EET HAVP.'O'.D it.0!ANA 46323 2191845 4003 i3 t2i 7318C00 Date 7 16-84 APPROVAL OF PERSONNEL RECORDS FOR NONDESTRUCTIVE EXAMINATION PROJECT: Commonwealth Edison Company's Byron Nuclear Generating Station, Byron, Illinois SUBCONTRACTOR: Pittsburgh Testing Laboratory W 3 H219 Name L. J. Klink Social Security No. Method Radiographic Testing (RT) (,ygg 11 Date of Certification or Recertification 6-3-fI Due Date of Recertification 6 - 2 ~85 .Date of Eye Examination / ~ M-87 Due Date / ~ M'~ f 9 The personnel records of the above candidate have been found acceptable, therefore this becomes a valid approval for the above activity. Hunter Corporate Level ill //# d 7 Jo'hn H. hobertson D/te' / I 'p A ] l_)

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l l V i g c, c.co v. w s e so..s. c..... u... 3 ~..

Exhibit 3.2.1.8 Page 11 of 21 1 I ma HUNTER CORPOR ATION 3800- 1797H STREET MAMVONO INDIANA 4(323 12196 $45 8003 #3 92, 73 9 30C0 Date 71684 ' APPROVAL OF PERSONNEL RECORDS FOR NONDESTRUCTIVE EXAMINATION PROJECT: Commonwealth Edison Company's Byron Nuclear Generating Station, Byron, Illinois SUBCONTRACTOR: Pittsburgh Testing Laboratory Name 1.wis A. Morales Social Security No. 33648 1371 Method Radiographic Testing (RT) Level ll Date of Certification or Recertification k ~22 ~ N Due Date of Recertification b~ 2 2 ~ b Date of Eye Examination [.78 eI I Due Date 8 ' // ' f'/ The personnel records of the above candidate have been found acceptable, therefore this becomes a valid approval for the above activity. Hunter Corporate Level in

1. 4'/

M John H. sob'er6on fate / X 0! G 0 di0 003y [

r Exhibit 3.2.1.B Page 12 of 21 -g M* HUNTER CORPORATION 3800 1797H STAEET HAvv0ND INOIANA J6323 f 219: 34$.8000 t3!2i 318000 ? Date 71784 APPROVAL OF PERSONNEL RECORDS FOR NONDESTRUCTIVE EXAMINATION PROJECT: Commonwealth Edison Company's Byron Nuclear Generating Station, Byron, Illinois SUBCONTRACTOR: Pittsburgh Testing Laboratory Name Donald E. Rhodes Social Security No. 329-78 9506 Method Magnetic Particle Testing (MT) (,ygg ll Date of Certification or Recertification 2 - / /

• O 9' Due Date of Recertification 2 -/ 7-B 7 Date of Eye Examination 9-2 /~88 Due Date 9-2 /- E V The personnel records of the above candidate have been found acceptable, therefore this becomes a valid approval for the above activity.

Hunter Corporate Level til A 7 7/ k John'H. Rohrtson ~ D/te'[~' h$ h )

Exhibit 3.2.1.B Page 13 of 21 m H me HUNTER CORPOR ATION 3800 179TH STAEET HAVVCNO INDIANA 46323 *2995845 8000 3't 21 '318000 Date 71784 APPROVAL OF FERSONNEL RECORDS FOR NONDESTRUCTIVE EXAMINATION PROJECT: Commonwealth Edison Company's Byron Nuclear Generating Station, Byron, Illinois SUBCONTRACTOR: Pittsburgh Testing Laboratory Name Donald E. Rhodes Social Security No. 329 78 9506 Method Penetrant Testing (PT) Level 13 Date of Certification or Recertification k'/O-h3 Due Date of Recertification k - /8 - 8[ Date of Eye Examination 9-2/- 82 Due Date @-2 /- 03 I The personnel records of the above candidate have been found acceptable, therefore this becomes a valid approval for the above activity. N Hunter Corporate Level l A/A' l fohn H. Rotarbo'n ' D/te /' l = 1 p w i I J use i me I am I hi 1 ~

Exhibit 3.2.1.B Page 14 of 21 m H M* HUNTER CORPOR ATION 3800 179Tm STAEE? HAwot,0 ;NDIAr.A 463 3 i2'9e 845 8000 i3'2 73' 8000 Date 71784 d APPROVAL OF PERSONNEL RECORDS FOR NONDESTRUCTIVE EXAMINATION PROJECT: Commonwealth Edison Company's Byron Nuclear Generating Station, Byron, Illinois SUBCONTRACTOR: Pittsburgh Testing Laboratory Name Brian R. Riedl Social Security No. 359 52-6960 Method Radiographic Testing (RT) Level ll Date of Certification or Recertification /8"f/-83 Due Date of Recertification /8 - 7/- 85 Date of Eye Examination 0 - J#- 88 Due Date 8'/8~89 l The personnel records of the above candidate have been found acceptable, therefore this becomes a valid approval for the above activity. /// / Hunter Corporate Level 111 h>f. ~ John H. flo6er(sori (late [ o _ _u vu y l ~. 1

r ExhibM 3.2.1.B Page 15 of 21 sammmuns H summuumns - HUNTER CORPOR ATION 3800 1797H STREET HAWOP,3 NolANA 46323,2'9i845-6000 #3121 73' 8000 Date 7'17 # ' APPROVAL OF PERSONNEL RECORDS FOR NONDESTRUCTIVE EXAMINATION PROJECT: Commonwealth Edison Company s Byron Nuclear Generating Station, Byron, Illinois SUBCONTRACTOR: Pittsburgh Testing Laboratory 116-30-5889 Fred C. Schlut Social Security No. Name Method Radiographic Testing (RT) Level II Date of Certification or Recertification f ~M ~8 Y Due Date of Recertification k' M *[5 1 Date of Eye Examination //~ /2 - 82 Due Date //- /2 - E'I The personnel records of the above candidate have been found acceptab!e, therefore this becomes a valid approval for the above activity. I 7h# MI Hunter Corporate Level 111

1. A John H. Robert' sod ' ~ '

Date/ / f, l w i\\'Jbh\\ s ~_. u\\ w) Y ~ 1

Exhibit 3.2.1.B Page 16 of 21 m H me HUNTER CORPOR ATION 3600 1797H STAEET HAP.NOND iNDI AN A 4E323,219t B45 8000 r 3'2i '31 9300 Date 71784 APPROVAL OF PERSONNEL RECORDS FOR NONDESTRUCTIVE EXAMINATION PROJECT: Commonwealth Edison Company : Byron Nuclear Generatirig Station, Byron, Illinois SUBCONTRACTOR: Pittsburgh Testing Laboratory Name Fred c. seMute' 1 6 5889 Social Security No. Method Magnetic Particle Testing (MT) L,ygg H Date of Certification or Recertification f-22-83 Due Dete of Recertification b ~ 22 d5 Date of Eye Examination //-/2'P2-Due Date 8-/2 - 8.3 The personnel records of the above candidate have been found acceptable, therefore this becomes a valid approval for the above activity. Hunter Corporate Level il

1. /

• /

M ' John d. Ffobe/tson %te' / / J-J-lj.J V Q; m . m,. a e e. n..

Exhibit 3.2.1.B Page 17 of 21 m H ma HUNTER CORPOR ATION 3800 1797H STREET HAMMO*.D INDIANA 46323 7191845 8000 (3121731 2000 Date 7'17~84 APPROVAL OF PERSONNEL RECORDS FOR NONDESTRUCTIVE EXAMINATION PROJECT: Commonwealth Edison Company's Byron Nuclear Generating Station, Byron, Illinois SUBCONTRACTOR: Pittsburgh Testing Laboratory Name Fred c. schluter Social Security No. 116 30 5889 Method Penetrant Testing (PT) Level II Date of Certification or Recertification E' Due Date of Recertification [~22-85 Date of Eye Examination //- /2-92 Due Date //- /2 - 77 The personnel records of the above candidate have been found acceptable, therefore this becomes a valid approval for the above activity. / Hunter Corporate Level ill </# John H. Robertson Daie / 'I) 3 t u ,/ -> u

Exhibit 3.2.1.B Page 18 of 21 m H m= HUNTER CORPORATION 3800 179TH STAEET HAMMOND INDIANA 46323 1219i845-8000 d12i ?318000 Date 7 17-84 APPROVAL OF PERSONNEL RECORDS FOR NONDESTRUCTIVE EXAMINATION PROJECT: Commonwealth Edison Company's Byron Nuclear Generating Station, Byron, Illinois SUBCONTRACTOR: Pittsburgh Testing Laboratory Name Fred C. Schluter Social Security No. 116-30-5889 Method Ultrasonic Testing (UT) Leveg Date of Certification or Recertification /~/9-84' Due Date of Recertification /-/f-87 Date of Eye Examination //-M, -83 //- k, - 8 Y Due Date l l The personnel records of the above candidate have been found acceptable, therefore this becomes a valid approval for the above activity. M7 N Hunter Corporate Level. A4 John H. Robertson Wate '~ r 1 .- ; n (~\\ p,"f r n e n . n tm l l uiL UdlA)U__ a su}Y i

Exhibit 3.2.1.B Page 19 of 21 ammmmmmmme H ~ m.. HUNTER CORPORATION l 3800 179TH STREET MAYMOND INDIANA 46323 (2'96845-8000 s312: 731 8000 Date 71684 APPROVAL OF PERSONNEL RECORDS FOR NONDESTRUCTIVE EXAMINATION PROJECT: Commonwealth Edison Company s Byron Nuclear Generating Station, Byron. lilinois SUBCONTRACTOR: Pittsburgh Testing Laboratory Name Ralph L. Turner Social Security No. 563-36-5322 Method Radiographic Testing (RT) t,y,g H Date of Certification or Recertification [-Y~[Y Due Dats of Recertification /-8~II Date of Eye Examination Due Date The personnel records of the above candidate have been found acceptable, therefore this becomes a valid approval for the above activity. /(( Hunter Corporate Level lli /M Ste / Jo'hii H. Roberts 6n ~~ n

Exhibit 3.2.1.B Page 20 of 21 m H HUNTER CORPOR ATION 3800- 179TH STREET. HAVVOND INDIANA 46323 '2191845-3000 i312i ?39 8000 Date 71684 APPROVAL OF PERSONNEL RECORDS FOR NONDESTRUCTIVE EXAMINATION PROJECT: Commonwealth Edison Company s Byron Nuclear Generating Station, Byron, Illinois SUBCONTRACTOR: Pittsburgh Testing Laboratory Name Refph L. Turner Social Security No. 563 36 5322 Method Magnetic Particle (MT) Level 18 Date of Certification or Recertification / -T* f Y Due Date of Recertification /~T'I7 Date of Eye Examination Due Date The personnel records of the above candidate have been found acceptable, therefore this becomes a valid approval for the above activity. Hunter Corporate Level 1 M John H. Robertson Da/r / .,, n. ~. ,(. ,.3 p bI Jh i w

Exhibit 3.2.1.B Page 21 of 21 H ~ -= HUNTER CORPOR ATION 3800 179TH STAEET HAMMONO INOf ANA 46r3 2191845-8000 '3121731 8000 Date 71684 APPROVAL OF PERSONNEL RECORDS FOR NONDESTRUCTIVE EXAMINATION PROJECT: Commonwealth Edison Company s Byron Nuclear Generating Station, Byron, Illinois SUBCONTRACTOR: Pittsburgh Testing Laboratory Name Ralph L. Turner Social Security No. 563 36-5322 Method.. Penetrant Testing (PT) Level Il Date of Certification or Recertification // - 5 ~ Il Due Date of Recertification // -8 ' 8Y Date of Eye Examination 2- / 7 -8/ Due Date 2-M-M .) The personnel records of the above candidate have been found acceptable, therefore this becomes a valid approval for the above activity. e Hunter Corporate Level llL /64 / (( k John'H.'notierdon Dde / 1 i k, kbuh n ku u-vl vut ~

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(.,t g..e a 4 \\ i ' ] {,, L L.1. a m===== ,e-q. Q m' HUNTER CORPOR ATION 3900 179TH STAEET SAYVOND INDIANA 46323 219 845-8000 i312> 7318000 p neering Report No, HCB 1251 6p August 1,1984 g Ef A e'",q.4 /j# G Mr. Richard C. Lindsay f Hunter Corporation s Byron Nuclear Station Post Office Box 674 Byron, Illinois 61010

SUBJECT:

Audit Findirgs of Pittsburgh Testing Laboratory's Maintenance of Physical Qualification for Nondestructive Examination (NDE) Personnel. Attention: R.C. Lindsay Hunter Corporation's Level lil Examiner's audit of Pittsburgh Testing Laboratory's (PTL) NDE Personnel Qualification Records revealed the following discrepancies with regard to maintaining rnords of a current (yearly) physical qualification (visual acuity examination). Pittsburgh Testing Laboratory's records on the following individuals indicate that the length of time between visual examinations were in excess cf one (1) year. Record of Eye Examination Present Name Social Security No. Not Current Status B. Adachi 360-22 8067 12 days from 6 3-78 to 6-15-78 Current D. Garnhart 341 46 6706 1 days from 414-83 to 415-83 Current J. Green 180-42 6390 4 days from 61183 to 6-15-83 Current R. Hachmeister 352-46-0440 3 days from 3 24-81 to 3 27-81 8 days from 3 25-84 to 4 3 84 Current L. Klink 064 36 6219 6 days from 18-80 to 1 14-80 2 days from 18 83 to 110-83 2 days from 110-84 to 112-84 Current L. Morales 326-48-1371 2 days from 3 22-80 to 3 24-80 1 days from 3 24-81 to 3 25-81 Current D. Rhodes 329-78 9506 4 days from 9-17 81 to 9-21-81 Current I }h i tq l\\ I"[ [] [)y 1

g i\\V s

VV I g Cw<aGO wNO'S -*WCND 'ND' ANa caAssao CU0aN'a

Exhibit 3.2.1.C Page 2 of 6 HUNTER CORPOR ATION ~ ..I ij! I l' f : q (* ;f g r, g / Y >v1 ~ * * ' ~. ~ ; c' ', ; ' ~ U \\ /./ ) l Engineering Report No. HCB 1251 Page 2 F. Schulter 116-30-5889 1 days from 11-4 79 to 11-5-79 7 days from 115 80 to 11 12-80 Current R Toops 344 40 2098 9 days from 4-1181 to 4 20 81 2 days from 4 20-82 tc 4 22-82 3 days from 4 22 83 to 4 25-83 1 days from 4-25-84 to 4 26 84 Current R. Turner 563-36-5322 1 days from 3-5-80 to 3-6 80 11 months and 6 days from 2-5-83 to 1 11-84 Current M. Anderson 393 60-6803 3 months and 15 days from 9-23-78 to 1 15-79 Inactive J. Gratza 332-42-3614 2 days from 2-26-83 to 2 28-83 Inactive T. George 345-62-3413 23 days from 5-23-78 to 615-78 Inactive D. Duda 208-36-8567 1 month and 10 daus from 410-76 to 6-20-76 2 months and 17 days from 5-20-77 to 812 77 Inactive A. Corrado 395-50-6798 4 days from 11-8-80 to 11-12-80 Inactive N. Nelson 348 50-9443 1 day from 410-80 to 411-80 Inactive G. Reardon 516-64-9132 7 days from 8 5 81 to 8-12 81 4 days from 8-12 82 to 816 82 2 months and 1 day from 8-16-83 to 10-17 83 Inactive H.Sunok 097 14-1335 11 days from 9-29-78 to 10-10 78 Inactive J. ~:'utman 403 58-1765 1 month and 11 days from 7 6 80 to 7-17-80 3 days from 7-17 81 to 7 20-81 Inactive G. Yerk 160-46 8127 2 months and 18 days from 10 27-82 to 1 14-83 Inactive D. Stefka 330 22-3641 There was no date on the eye examination report in PTL's file inactive G. Loftis 235-66-5508 1 day from 5-17-83 to 5-18-83 Inactive . WG D OPY

Exhibit 3.2.1.C eage 3 of 6 HUNTER CORPORATION I l f., ! 0 .. /~ ! l "l - *. U "' ' ', '} }I i 'N !" L V' b ' '\\/ .qn l Engineering Report No. HCB 1251 Page 3 The codes, standards and specifications applicable to the Byron project, as well as Hunter Corporations's and PTL's approved Quality Assurance programs require the personnel per. forming Nondestructive Examination be qualified in accordance with the requirement of ASNT.TC.1A. NDE Personnel are required to pan a physical examination (eye test) administered on an annual basis in order te maintain their physical qualification. All of the personnel listed above had a current physcial examination (eye test) at the time of certification and/or recertification. The lapses in time between the expiration (one year) of one physical examination and the time the new examination was administered are listed above. Pittsburgh Testing Laboratory as Hunter Corporation's NDE subcontractor is responsible for I maintaining and using only Qualified and Certified individuals to perform Nondestructive Examinations. Pittsburgh Testing Laboratory is required to submit documented evidence that the above individuals had valid physical qualifications during the periods listed above or written verification that the above individuals did not perform any Nondestructive Exam-ination functions for Hunter Corporation durin the periods in which their physical qualif-ication had lapsed. The above is required to be submitted to Hunter Corporation's Level til Examiner for Review and Acceptance by September 10,1984. A copy of the accepted resolution shall be maintained in Hunter and PTL's/NDE personnel file for that individual to document that valid qualification of the individual was maintained for the NDE activities which were performed. Sincerely, HUNTER CORPORATION l f r 'f John H. Robertson Corporate Level it! Examiner JHR/dm l .cc: ' D. Dunn, Pittsburgh Testing Laboratory M.L. Somsag, Site Q.A. Manager l K. Selman, Q.A. Manager / Hunter Corporation l K. Kranz, Site Welding Supervisory / Hunter Corporation K. Hansing, Q.A. Superintendent / Commonwealth Edison Company j R. Holt, National Board Representative su i u,av11;% ___s

T-Exhibit 3.2.1.C Page 4 of 6 ~ 1 umummmme

• * ~* V *

,, - ! ) ;u,).J I-(' m. HUNTER CORPOR ATION 3800 179TH STAEET%AMMOND INDIANA 16323 121918t5 8000 13121 731 8000 f Engineering Report No.1254 e August 1,1984 Q C %g.,j % * / Mr. Richard C. Lindsay Site Project Manager d s 4[2.. $[d ,I Hunter Corporation 1 S Byron Nuclear Station Post Office Box 674 k'k Byron, Illinois 61010

Subject:

Audit Findings of Pittsburgh Testing Laboratory's Maintenance of Records for Recertification of Nondestructive Examination Personnel

Dear Mr. Lindsay:

Hunter Corporation's Level 111 Examiner's Audit of Pittsburgh Testing Laboratory's (PTL) Non-destructive Examination (NDE) personnel records revealed the following discrepancies with regard to the maintenance of the Certification and Recertification records of the following personnel: Name: William U. Adachi Social Security No.: 360 22-8067 Method: Magnetic Particle Testing (MT), Penetrant Testing (PT), Radiographic Testing (RT) and Ultrasonic Testing (UT) Level: lli Status: Current approved Discrepancy: The due date for Mr. Adachi's recertification was 10-24-83 and he was not re-certified until 11-11-83. There was no record of certification or explanation available for the period from 10 24-83 to 11-1183. Name: David A. Dunn Social Security No.: 342 34 5323 Method: Magnetic Particle Testing (MT), Penetrant Testing (PT), Radiographic Testing (RT) and Ultrasonic Testing (UT) Level: 111 Status: Current approved Discrepancy: Mr. Dunn's current records were not available on site for audit, there were no records of Qualification, Certification and/or Recertification available from the l period of 31-79 to the present. Name: Ghaus Mohammad Social Security No.: 265-21 2718 Method: Penetrant Testing (PT) Level: ll Status: Inactive 3 l Discrepancy: The due date for Mr. Mohammad's Recertification was 3-2 82 and there was no 1 i record of recertificetion, however he had a Physical (eye examination) Qualifica-f tion performed on 3 5 82. There was no Record of Recertification or explanation available from the period of '3 2 82 until his termination from the project. y ( '"\\ A l\\ O ~ c_3in;M{ }\\u___s 1 vu 1

Exhibit 3.2.1.C ,.Page 5. of 6~ I s.'. 8 HUNTER CORPORATION l J '... j . g' ' ' L L., L g} l,l I,L. \\, ~'- - s

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'\\'l j Engineering Report No.1254 Mr. Richard C. Lindsay Hunter Corporftion August 1,1984 Page 2 Name: Fred C. Schluter Social Security No.: 116-30 5889 Method: Ultrasonic Testing (UT) Level: 11 Status: Currently approved Discrepancy: The due date for Mr. Schluter's recertification was 10-20-80 and he was not re-certified until 119-81. There was no record of Recertification or explanation available for the period from 10-20 80 to 1 19-81. Name: Carroll L. Tardy Social Security No.: 230-56-2753 Method: Penetrant Testing (PT) Level: 11 Status: Intetive Discrepancy: The date Mr. Tardy was certified was 9-10-79 however, his physical qualification (eye examination) was not performed until 9-1179. Certification was issued prior to completion of qualification. Name: William M. Whalen Social Securit/ No.: 341 50 1977 Method: Penetrant Testing (PT) Level: lli Status: Inactive Discrepancy: The record file on Mr. Whalen was incomplete, missing his Practical Test, Quali-fication and certification records from 81178 until his termination from the project. Pittsburgh Testing Laboratory as Hunter Corporation's NDE subcontractor is responsible for maintaining and using only Qualified and Certified individuals to perform Nondestructive Examination's. Pittsburgh Testing Laboratory is required to review their personnel records of each of the above individuals and provide a documented explanation of the lapses in maintenance of Certification Records dated above. Activity records for the above individuals shall also be reviewed to assure that NDE functions were not performed during the periods that the individuals did not have a current certification. Pittsburgh Testing Laboratory is required to resolve the above discrepancies and submit the resolution to Hunter Corporation's Level ill Examiner for review and acceptance by September 10,1984. I I i 1 i l l 9' ( l Q d 8 i V.i/ ld d I ~.....

Exhibit 3.2.1.C HUNTER CORPORATION 1 1* , Page 6_of 6.. { I 5' g, 7.. 1 j {.; g,,.,,, i Dj k L I ! - 'i V8 Engineering Report No.1254 Mr. Richard C.lindsay Hunter Corporation August 1,1984 Page 3 A copy of the accepted resolution shall be maintained in Hunter and PTL's NDE personnel file for that individual to document that valid certification of the individual was maintained for the NDE activities which were performed. Sincerely, HUNTER CORPORATION l, j','l M w Je7N ' l John H. Robe tson Corporate Level til Examiner JHR/rn ec: D. Dunn, Manager /Pittsburgh Testing Laboratory M.L. Somsag, Site QA Manager / Hunter Corporation K. Selman, QA Manager / Hunter Corporation K. Kranz, Site Welding Supervisory / Hunter Corporation K. Hansing, QA Superintendent / Commonwealth Edison Company R. Holt, National Board Representative l l l I iJ1W} q \\ S u' s I~~' i 1 r vu, i

o, Exhibit 3.2.1.D Page 1 of 5 9 Pittsburgh i Q Testing m e,c-ao S.22.V " Laboratorg CH-3850 August 29. 1984 Letter No. 70-84-189 Mr. Richard C. Lindsay Site Project Manager Hunter Corporation Byron Nuclear Station Post Office Box 674 Byron. Illinois 61010

SUBJECT:

Response to Audit Findings Hunter Engineering Report No. 1254

Dear Mr. Lindsay:

The following comments are offered in response to Hunter Engineering Report No.1254, generated by Mr. J. H. Robertson. Hunter Corporate Level III Examiner. NAME: William Adachi Finding: " Level III Recertification lapse period of 18 days." PTL Corporate Office has instituted a recall system on PTL Level III representatives to prevent reoccurrence of this situation. W. Adachi did not perform any specific NDE functions during the time frame of 10/24/83 to 11/11/83. A further review, however, found that W. Adachi had on 10/31/83 certified B. Riedl to a Level II RT Technician. Adachi was recertified on 11/11/83 based on continued satisfactory performance in administering Level III functions, therefore no further action is required. B. Riedl was working as a certified i Level I Radiographer up to his Level II certification on 10/31/84. j B. Riedl does not interpret radiographs. Corrective action is not required. I NAME David Dunn Finding: " Current Records Level III Status Not On Site." L D. Dunn will not be performing any Level III NDE administration i functions at the Byron Station. D. Dunn's records will be placed in the inactive file. NAME: Ghaus Mohammad Finding: "PT Recertification" l As of 5/79 Ghaus Mohamn.ad became a QA Auditor and has not performed any NDE inspections since 5/79. A letter will be incorporated in G. Mohamad's PQ package to clarify why recertification was not updated. i NAME: Fred Schluter finding: "Recertification (UT) Expired 10/20/80 l recertified 1/19/81" UT Report Numbers 719 thru 863 which covers the t period from 10/20/80 to 1/19/81 were reviewed and it was found Fred l Schluter did not perform any UT inspections during this period. F. Schluter was recertified to Level II UT Technician on 1/19/81. A recall system for recertification has been established to prevent i reoccurrence, l mmnuTDOLIIn fnDV-

Exhibit 3.2.1.D Pa9e 2 of 5 I l i NAME: Carol Tardy Finding: " Certified PT on 9/10/79. Eye Exam performed i 9/11/79" The date on qualification letter is in error. The NDE qualification data record appendix 9.4.2.B is the certifying document signed by the Level III whom administered the examination. This document is reported as certifying C. Tardy on 9/11/79 and date of eye exam is recorded as 9/11/79. No corrective action required. NAME William Whalen Finding: "PT Practical Exam Missing." W. Whalen did not take the PT Practical. PTL certification data record 9.4.2.B does not have W. Whalen certified as a Level II technician and he did not perform any PT inspections. The experience resume has W. Whalen being certified as a Level II technician in PT and MT. The resume is in error. W. Wnalen was certified as a Level II MT technician only. Corrective action will be to change W. Whalen's resume to reflect MT certification only. I trust the above information resolves the issues identified in the referenced report. D. A. Dunn, P.E. Lite Manager ach/0964P cc: M. L. Somsag, Site QA Manager / Hunter Corporation K. Selman, QA Manager / Hunter Corporation K. Krantz, Site Welding supervisory / Hunter Corporation / K. Hansing. QA Superintendent / Commonwealth Edison Company R. Holt, National Bcard Representative I ' 139 \\ ~~3]v v 3 , h _ ] ]v u] )\\/ ~ I i l

Exhibi t 3.2.1.D Page 3 of 5 4 p Pittsburgh Testing m ev,ea.o

• LT" Laboratory CH-3850 August 31, 1984 Letter No. 70-84 192 Mr. Richard C. Lindsay HUNTER CORPORATION Byron Nuclear Station Post Office Box 674 Byron Illinois 61010

SUBJECT:

Response to Audit Findings Hunter Engineering Dept. No. HCB-1251

Dear Mr. Lindsay:

The following comments are offered in response to the individual items addressed in Hunter Engineering Report No. HCB-1251. J. ADACHI (Period 6/3/78 to 6/15/78): Time records were checked and B. Adachi did not perform any NDE during this period. D. GARNHART (Period 4/14/83 to 4/15/83): On 4/14/83, Garnhart worked six (6) hours on MT and two (2) hours on WI. Previous and current eye exam was passed with corrective vision. J. GREEN (Period 6/11/83 to 6/15/83): 6/11 and 6/12 no work was performed. 6/13 and 6/14 Radiographic work was performed. Film interpretation was not conducted by J. Green. Previous and current eye exams passed with uncorrected vision. R. HACHMEISTER (Period 3/24/84 to 4/3/84): 3/25 Sunday. no work, 3/26 thru 4/1, sick days, 4/2, eight (8) hours RT. R. Hachmeister did not interpret radiographs. Both previous and current eye exams were passed with corrected vision. (Period 3/24/81 to 3/27/81): Also worked as a radiographer, with no film interpretation performed by him. L. KLINK (Period 1/8/80 to 1/14/80): 1/8 thru 1/11, interpreted film, 1/12 .and 1/13 weekend, no work, (Period 1/8/83 thru 1/10/83): 1/8, no work, 1/9. interpreted film. (Period 1/10/84 to 1/12/84): 1/10 and 1/11 interpreted film. Both previous and current eye exam passed without corrective vision. L. MORALES (Period 3/22/80 to 3/24/80): 3/22 and 3/23, weekend, no work performed. (Period 3/24/81 to 3/25/81): 3/24 radiographic work, Morales did not interpret radiographs. Current and previous eye exams passed with uncorrected vision. 1 . !,9 n } n

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4 5 D. RHODES (Period 9/17/81 to 9/21/81): Reported work 9/17 of four (4) hours MT,,four (4) hours PT, 9/18, eight (8) hours PT. 9/19 and 9/20, weekend work, no work performed. Both current and previous eye exams were passed with corrective vision. F. SCHLUTER (Period 11/4/79 to 11/5/79): No work performed on 11/4/79, (Period 11/5/80 to 11/12/80): 11/5 and 11/6 reviewed reports 11/7 thru 11/11/80, vacation. 11/12/80 eye eram administered current and previous eye exams passed with uncorrected vision. I R. TOOPS (Period 4/11/81 thru 4/20/81): 4/11 and 4/12 we 4 .1, no work, 4/13 thru 4/17, off Site. 4/18 and 4/19 weekend, no work peti-, :J. (Period 4/20 to 4/22/82): 4/20 and 4/21, injury, no work performed, 4/22, eye exam administered. (Period 4/22/83 to 4/25/83): 4/23 and 4/24 weekend, no work performed. (Period 4/25/84 to 4/26/84): No work performed. Current and previous eye exam's were passed with uncorrected vision. R. TURNER (Period 3/5/80 to 3/6/80): Worked as a radiographer. R. Turner did not interpret film. (Period 2/5/83 to 1/11/84): Assigned to PTL, Portland office from 1/83 thru 11/83. Performed radiographic work on the following dates 12/13, 14, 15, 12/19, thru 12/21. Performed PT examinations on 12/22, 1/9/84, 1/10, and 1/11/84. Ueekend 12/17 and 12/18 No work performed. Vacation 12/23/83 thru 1/8/84. R. Turner's current and previous eye examinations were passed with corrective vision. J. GRAT~A (Period 2.'26/83 to 2/28/83): Weekend, no work performed. M. ANDERSON (Period 9/23/78 to 1/15/79): M. Anderson was transferred to PTL Milwaukee. Last working day on Site was 6/19/78. T. GEORGE (Period 5/23/78 to 6/15/78) T. George did not perform any NDE [ examinations during this period. D. DUDA (Period 4/10/76 to 5/20/76): No work performed at Byron. (Period 5/20/77 to 8/12/77): No work p dformed at Byron. PTL came on Site in November 1977. A.-CORRADO (Period 11/8/80 to 11/12/80): No NDE work performed during this i period. N. NELSON (Period 4/10/80 to 4/11/80): Worked as a Radiographer, no film interpretation performed by N. Nelson. G. REARDON (Period 8/5/81 to 8/12/81): Worked two (2) hours UT, six (6) hours PT on 8/5/81. 8/6 and 8/7, vacation. 8/8 and 8/9 weekend, no work performed. 8/10/81, four (4) hours WI, four (4) hours Ur. 8/11/81, eight (8) hours MT. 8/12/81, eye exam. (Period 8/12 to 8/16/82): 8/12 and 8/13. Vacation, 8/14 and 8/15, weekend, no work performed. 8/16/82, eye exam administered. (Period 8/16/83 to 10/17/83): Left Site 7/7/83 (injury) returned to work 10/17/83. Eye exams on 8/12/81 and 8/16/82 passed near acuity with uncorrected vision. i nr p -~ Pd OO )

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f l a...w.. w. ...w ..p o. e L. H. SUNOK (Period 9/29/78 to 10/10/78) Worked six (6) days as a radiographer. H. Sunok did not interpret radiographs. Eye examinations on 9/29/77 and 10/10/78 were passed with corrected vision. J. TROUTMAN (Periods 7/6/80 to 7/17/80 and 7/17/81 to 7/20/81): J. Troutman was Site Manager and did not perform NDE inspections during the above periods. G. YERK (Period 10/27/82 to 1/14/83): G. Yerk worked 34 days as a radiographer and three (3) days on CEA inspection. This technician did not interpret film, and eye examinations on 10/27/82 and 1/14/83 were both passed l with uncorrective vision. D. STEFKA (Finding: No date on eye examination) The eye examinations for D. Stefka were obtained from PTL Chicago office and incorporated into Stefka's PQ package. G. LOFTIS (Period 5/17/83 to 5/18/83): No work performed on 5/17/83. ( Disposition: A review was conducted on eye examinations on the above j technicians prior to and after the lapse periods. Based on the fact that no l ' change in visual acuity from uncorrected to corrected vision had occurred, no l further action is deemed necessary. i Corrective Action: An eye examination recall system has been incorporated to prevent reoccurrence.

3. A. Dunn, P.E.

Site Manager ach/0977P cc: M. L. Somsag, Q.A. Manager / K. Selman, Q.A. Manager / Hunter Corporation K. Kranz. Site Welding Supervisory / Hunter Co @ ration K. Hansing, Q.A. Superintendent / Commonwealth Edison Company R. Holt, National Board of Representatives Page 3 n r. W l1 -lmi j

'T Exhibit 3.3.1.A Page 1 of 8 .? v Page 1 of 7 Hunter Corporation Byron Station a August 07, 1984 NONDESTRUCTIVE EXAMINATION SUBCONTRACTURAL INTERFACE AGREEMENT [1.0 GENERAL 1.1 This Interface Agreement replaces and supercedes the previous Interface Agreement dated September 27, 1978. 1.2 Corrections and revisions to this Interface Agreement will be evidenced by a, virgule (/) in the left margin next to the corrected or revised section, article or paragraph. [2.0 SCOPE OF INTERFACE AGREEMENT 2.1 This Interface Agreement shall establish the controls of operations and activities to be exercised by Hunter Corporation (hereaf ter referred to as the Installer) on Pittsburgh Testing Laboratory (hereaf ter referred to as the NDE Sub-contractor) as agreed to by Commonwealth Edison Company (hereaf ter referred.to as the Owner) and the Installer's Authorized Inspection Agency (hereafter referred to as the A.I.A/A.N.I.). [ Y hi j j p q u _ m _] - 1 i

m l Exhibit 3.3.1. A Page 2 of 8 Page 2 of 7 2.2 The controls to be exercised by the Installer are limited to Nondestructive Examination (heteafter referred to as NDE) activities performed under the scope and jurisdiction of the following codes. .1 The American Society of Mechanical Engineers Boiler and Pressure Vessel Code (hereafter referred to as ASME B & PV Code), all sections, 1974 Edition with addenda thru the sumtrer of 1975 unless otherwise stated on requests to perform NDE. .2 The American National Standards Institute Code for Power Piping B:31.1 (hereafter referred to as 8:31.1), 1973 Edition with addenda thru the summer of 1975 unless otherwise stated on requests to perform NDE. .3 The American Society for Nondestructive Testing Recommended Practice SNT-TC-1A (hereafter referred to as SNT-TC-IA) 1975 Edition. !3.0 INSTALLER ACCEPTANCE OF NDE SUB-CONTRACTOR QUALITY ASSURANCE /OUALITY C PROGRAM AND NDE PROCEDURES 3.1 The NDc Sub-contractor shall submit to the Installer, for review, approval and retention, controlled copies of the following documents, including corrections or revisions thereto. I I a J

Exhibit 3.3.1.A Page 3 of 8 Page 3 of 7 .1 The Quality Assurance / Quality Control Program Manual that describes the management'and administrative controls to be applied to the NDE procedures and technicians which the NDE Sub-contractor intends to use on the Installer's work. .2 The SNT-TC-1 A required written practice for training, qualification and certification of NDE technicians which the NDE Sub-contractor intends to use on the Installer's work. .3 The operational procedures specifying the detailed methods to be used to assure compliance with the Quality Assurance / Quality Control Manual and the codes and standards identified in Section 2 of this agreement, which the NDE Sub-contractor intends to use in processing the Installer's work. The NDE procedures, which the NDE Sub-contractor intends to use on the .4 Installer's work and the qualification records supporting those procedures for the examinations as defined in the ASME B & PV Code Section V and as follows. ~~ nm) nn n 1 1 1 \\ dV d--! Jdi .A Radiographic Examination w .B Liquid Penetrant Examination .C Magnetic Particle Examination .D' Ultrasonic Examination Other examination methods, as required by the Installer .E Gauge and instrument calibretion procedures that are associated to the .5 examination methods identified in the foregoing.

r d Page 4 of 7 .6 The training, experience, qualification, eye examination and certification documentatfon for each NDE technician which the NDE Sub-contractor intends to use on the Installer's work. 3.2 The NDE Sub-contractor will not implement any program or procedure on Installer's work (which is within the scope of this section), nor correction or revision thereto without the Installer's approval. 3.3 Wherever the phrase ' Installer's approval' appears in this agreement, it shall be interpreted to mean - endorsement of the program, procedure, or results shall be the responsibility of the Hunter Corporation's Corporate Level 1[I. The Hunter Corporation's Corporate Level III shall also be responsible for the resolution of disputes between the NDE Sub-contractor and Hunter Corporation personnel in relation to NDE activities. )4.0 ASSIGNMENT OF NDE TECHNICIANS 4.1 The NDE Sub-contractor shall immediately withdraw assignment of NDE technicians from the Installer's work when the Installer considers them to not be technically qualified. lY f

Exhibit 3.3.1.A Page 5 of 8 t. / 5.0 REQUESTING NDE AND REPORTING RESULTS e 5.1 The NDE Sub-contractor shall utilize the Installer's NDE Request Form (HN-17) for requested Nondestructive Examination services. The NDE Contractor and the Installer shall mutually establish a program of identification of the items or assemblies that require the examinations. 5.2 The N.D.E. Sub-contractor shall submit to the Hunter Corporation, attention Quality Control Supervisor (or a designee), all NDE Reports, or other reports as agreed upon, for Hunter Corporation Quality Control review and processing. The following reports shall be submitted at a time agreed upon by the Installer's Quality Control and the NDE Sub-contractors Site organization, and shall be complete and correct at the time of submittal: .1 Magnetic Particle N t m TU ~ i, J J,J ' D a VJH r

• /

6 I .2 Liquid Penetrant .3 Ultrasonic .4 Radiography (including overlays (skins) of rejected areas) .5 Reports of other examination methods as required by the Installer / 6.0 INSTALLER, AUTHORIZED INSPECTILN ACENCY AND AUTHORIZED NUCLEAR INSPECTOR RIGHTS OF REVIEW AND ACCESS 6.1 The NDE Sub-contractor shall demonstrate the qualifications and effectiveness of Nondestructive Examination procedures when required by, and to the satisfaction of, the Installer's A.I.A./A.N.I. ~.

Exhibit 3.3.1.A Page 6 of 8 Page 6 of 7 6.2 The NDE Sub-contractor shall make available, when requested, all applicable reports, radiostaphic film, records, material certificates and other documentation to the Installer or the Installer's A.I.A./A.N.I. 6.3 The NDE Sub-contractor agrees to allow the Installer / Installer's A.I. A./A.N.I. to implement those Audits, inspections and reviews required by him in accordance with the applicable code. 6.4 The NDE Sub-contractor shall requalify any procedure or NDE technician when so requested by the Installer or the Installer's A.I.A./A.N.I. [7.0 RADIATION SAFETY 7.1 The NDE Sub-contractor agrees to maintain and comply with the requirements of " Standards for Protection Against Radiation" 10CFR20, and other applicable Federal and State regulations governing the use and control of a radioactive source applicable to the Project Site. 7.2 The NDE Sub-contractor agrees to supply the Installer with instructional material relating to the use and meaning of Signs, Lights, Colored Ropes or Tapes or other material used to indicate restricted personnel access areas related to the use, handling and storage of a radioactive source. The Installer agrees to make such instructional material available to its personnel in order to assure their knowledge of the safety requirements. \\dV f & '(O ^. M ? 1 V _ ' _. ' / i s., j l w

Exhibit 3.3.1.A Page 7 of 8 t [8.0 INSTALLER AUDITS 8.1 The NDE Sub-contractor agrees to allow the Installer to perform those Audits and surveillances necessary to assure compliance to the governing code, and Specification F/L-2739 as it applies to those codes. On the completion of an Audit, the NDE Sub-contractor agrees to attend a Post Audit meeting with the Installer to discuss the results and possible resolution. A copy of the Audit report shall be tra smitted by the Installer to the NDE Sub-contractor.

• Prspared by Date f 7/f 9

/ M.L. Somsag Byron Site Q rvisor [j Approvals: l 2 Date 8b'0lfff K. R'. Se'Iman Corporate Quality Assurance Manager Hunter rat 7 Y Date R. Lindsay Project Manager Hunter Corporation V'$ Date f ~ f ~ SY K. Kranz Weldi g Department Supervisor cW Er/vW Date Pittsburgh Testin Laboratory Title M . 0 der-o. Dates /she K'.J'. Hansing QuslityAssuranc(eSuperintendent / Commonwealth Edison Company ~7tf7 h - - T!fb Date M.E. Lohmann Ass't. Project Superintendent Commonwealth Ed so Compa

• Prepared by

[d pDate[/7/[ ynn s. robertson, suntes corpor4tionforporate Level III Examiner

[ Exhibit 3.3.1.A Page 8 of 8 m H m-i l HUNTER CORPORATION 3800 1797H STAEED HAMMONO INTANA 46323 i2'9' 945 9000 #3'231 8000 HC-QA-731 TO: Mr. D. Dunn, PTL Project Manager FROM: Mr. A.T. Simon, Hunter Corporation DATE: August 24, 1984

SUBJECT:

NDE Subcontractural Interface Agreement Mr. Dunn: Please find attached the original draft titled " Nondestructive Examination Subcontractural Interface Agreement" dated ~ August 7, 1984. Please review this document and, if in agreement with it, please sign for your approval on page 7. Also add your job title in the space provided. Once you have reviewed and approved this interface agreement, please return it to A.T. Simon, QA Administration Supervisor, at Hunter Corporation. If you have any problems or questions with this document, feel free to contact me Thank-you for your cooperation. Sincerely yours, HUNTER CORPORATION N\\ 6-2fW n [ A.T. Simon QAAS {q ,,,,.l (h,- j 1LM I

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-_H HUNTER CORPORATION 3800 179TH STAEET HAMMOND INDIANA 46323 (2196845 8000 (312)731 8000 Engineering Report No. HCB 1260 August 16,1984 Mr. Richard C. Lindsay Hunter Corporation Byron Nuclear Station Post Office Box 674 Byron, Illinois 61010

SUBJECT:

Potential finding by the National Board of Boiler and Pressure Vessel inspectors regarding the interface agreement between Hunter Corporation and Pittsburgh Testing Laboratory which did not specifically require that disputes be subrnitt-ed to Hunter's Corporate Level lli for resolution.

Dear Mr. Lindsay:

This engineering report documents the above potential finding, its resolution and action required to prevent reoccurance. POTENTIAL FINDING BY THE NATIONAL BOARD During the site review conducted by the National Board of Boiler and Pressure Vessel Inspectors, they noted that some Radiographs had been submitted directly to the customer, Commonwealth Edison Company (CECO) for resolution of evaluations in which there was a disagreement between Hunter Corporation and the NDE Subcontractor, Pittsburgh Test-ing Laboratory (PTL). Hunter Corporation's Quality Assurance Program requires that Radiographic evaluations that are in question be resolved by Hunter Corporation's Corpor-ate Level lli Examiner. The interface agreement between Hunter Corporation and PTL did not specifically require that disputes be submitted to Hunter's Level 111 for resolution. The following is a listing of Radiographs in which there was a dispute with the Subcontractor's evaluation, resolution of the dispute may or may not have been performed by Hunter's Level til prior to submittal to the customer. RESOLUTION OF THE POTENTIAL FINDING To resolve the potential finding Hunter Corporation's Corporate Level 111 Examiner reviewed all of the following Radiographs to verify that the Radiographic Film and weld quality met the applicable specified requirements for the weldments involved. Based on Hunter's Level 111 review of the Radiographs, Hunter Corporation is in concurrence with the evaluations as documented on the Weld Radiographic inspection Reports. The Radiographs and the welds are acceptable and no additional examination is required to be performed.

HUNTER CORPOR ATION Y Engineering Report No. HCB.1260 Page 2 w.m n.ei..a. Scies.stee. ii.., u. g w.w

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w. R T-501 12478 FW 10 H$H 241 unacceptable unconsumed Reve=ed by PTL Levelill and accepted 12 11-78 insert 41 RT 503 12478 FW 12 HSH-241 unasseptable vaconsumed Reviewed by PTL Level lit and accepted 12 11 78 insert at 2 RT 544 12 1&78 FW444 CV53 Report was revised to indicate acceptance by P TL Level sil 12 22 78 RT 545 121578 ' FW447 CV 5 3 Report was revised to indicate acceptance by PTL Level til 12 22 78 RT 1130 6 1S79 FW 22 1HCAE 2 unacceptable. incomplete Rev.ewed by PTL Levei lli and accepted &2179 fusion 4043 RT 1390 S1S79 FW 1443 SX45 unacceptable in complete Rwwwed by PTL LevelIII and accep ad 141479 fusion 2422 RT 1391 2280 N O. 60 2H48E4 unacceptable. Lmear Reve*ed and accepted by Hunter & CECO Level Indeten 360' 111 S2SSG RT 1487 12 2&79 FW444 CC42 unacceptab4 Tungsten Rev ewed and accepted by Hunter & CECO Level (R1) (R1) inclusen at 9% 111 1 11 80 RT 1559 10-2S79 FW 1360 SX-35 unacceptable incornplete Reviewed and accepted by Hunter & CECO Levet fus.on and porosity til 1-2580 RT 1566 143S79 FW 163 $1-9 unacceptable slag inclusion Reviewed and accepted by Hunter Levet lil 7 to 8 11179. CECO Levet all 1-2580 RT 1945 21350 FW 200 2H4 AE-2 unacceptable Base metal Base metal indication reviewed and accepted indication at 9% Hunter Level ill 21680 and CECO Level til 42280 I m w-y m --q yy --w-9iey 9-- ,-4,,ig --yy

HUNTER CORPORATION Q. Engineering Report No. HCB-1260 Page 3 w.i. .........n.e I,i.e.. ..e...w.. n ..i... v.... o..e... i......... RT.1982 2 18-80 No.144 RC 9 unacesotable. stag inclusion Report revised to show accepted 13180 at 23. ancomplete fusion at28 RT 2000 22580 No. 220A SI-4 unacceptable incomplete Report revised to show accepted 3 3180 fusion at 10,11 and 16 RT 2749 42580 FW 192 2H48E2 Unacceptable. Linear Reviewed and accepted ty Hunter and CECO Level Ill E29 80 RT 2993 8-2500 FW.184 2H48E.1 unacceouble. incompfete Re rad.ographed fusion 212.12 24,24-36 Tungsten inclusion 36 48 RT.2993 52780 FW 184 2H-C8E 1 Unaccepted Linear Revewed and scoopied by Hunter and CECO (RS1) (RS1) Indicat.on 100% Level 1118 29-80 RT 2994 E27-80 FW 195 2H48E2 unnacceptable. incomplete Reviewed and accepted Hunter and CECO (RS1) (RL1) fusion 104 106 Leveilli 8 29-80 RT 2995 E2540 FW 183 2H48E.1 unecesotable. Linear Re radiograr%d indications 10C% RT 2995 E27 80 FW 183 2H-C8E 1 unaccostable Linear Reviewed end acces.ed by Hunter and CECO (RS1) indations 100% Level til 8 29 83 RT 3082 S18 80 FW 231 RC3 5 unacceptable. incompleta Review and accepted by PTL Levelill12 580 fus on 14 to 19 e ,~ ,y n-n- a -ea,c.-- ,,w--, ,--n ,en- + - -, -

HUNTER CORPORATION e N Engineering Report No. HCB.1260 Page 4 werd ha y.ene insessmen m.o.n % g w.se k svn.a. or,. wit a.e a mu AT 3581 112&SO FW423 FW 13 7 unenceptehle. incomplete Reviewed and accepted try PTL Levet til 12 580 (R$1) (RS.1) fus.on et 5 RT4441 S 17 82 FW-293 AF 27 unenceptatie porosity Reviewed and accooted try PTL Level 11162&S2 (R-23 (R 2) at 44 AT 9255 42&B3 83 C&15 unacceptabas. incomplete Reviewed and accepted try Hunter and PTL Level (R 11 (R 1) fusion 2%.8 and 2&O lit's $483 RT-9880 5-17-83 FW 7328 CV 31 unneceptable. Tunpten Reviewed and accepted try Hunter and PTL Level inclusion lli : 6-6-83 RT.9937 52&S3 FW-3020 5-CV 100-unacceptaNo. incomplete Reviewed and eccepted try Hunter and P TL Level 218 A ,,,,,n gig.: 6483 RT.10688 to28 83 FW4C3 CS241 unaamptable. porosity Reveewed and accepted try PTL Levellit 11-583 et 1/2. I and Hunter Level til 11-8 83 RT 10699 11483 3306 SCV401 unacceptable. incomplete Revee=ed and accepted by Hunter and PTL Level 286 fus.on n 11432 I e n, -,y.._.--,-. ,,,r.

HUNTGR CORPORATION N Engineering Report No. HCB-1260 Page 5 ACTION TAKEN TO PREVENT REOCCURENCE The interface agreement between Hunter Corporation and Pittsburgh Testing Laboratory has been revised to require that all disputed Nondestructive Examinations shall be resolved by Hunter Corporation's Corporate Level 111 Examiner. Sincerely, HUNTER CORPORATION .WI John H. Robertson Corporate Level lli Examiner JHR/dm cc: M. L. Somsag K. Selman K. Kranz K. Hansing D. Dunn R. Holt / -.n,, n. w.. w., ,,,m,--.,., ..,n-., ,-.e-.

v.p( i -. o A E1 c National illaarb of illoiler unb IJressure liessel 3nspectors 7 f.[ 5 F. HARRISON Esecutive Director Y,. BOARD oF TRUSTEES tm avt wt wway cmo COLUv8VS OHrc C229 u S A Sta*e of Coloraoo T EY. Coa.emaa - 8 L WM "'* '[h8[2 L Ra e gm Norim CaroMa ,,y, B W COLE -C Provante of Bhidh Colu*t & b et BL?$Cri tst V<e Cnm 4 e - j j pyppy sui ta e C.er uran 1919 6 5 d' 19Bk - S'* * *' *

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c w watites 2no v.ce Cnm AN NIVE RS ARY Pomana oregoa J T CaO,SBY Pm Cn ea-a y,,, noen 4,,,,,,, September 21, 1984 JCordell Reed, Vice President Commonwealth Edison Company PO Box 767 Chicago, Illinois 60690

SUBJECT:

National Board Audit - Byron Nuclear Station Units 1 and 2; Byron, Illinois

REFERENCE:

1) C. Reed letter dated April 25, 1984 to The National Board of Boiler and Pressure Vessel Inspectors (S. F. Harrison) 11) The National Board of Boiler and Pressure Vessel Inspectors,D. J. Mcdonald letter-interim report dated July 16, 1984 to Commonwealth Edison Company (C. Reed) iii) Coc=onwealth Edison Company (V. Schlosser) letter dated August 1, 1984 to The National Board of Boiler and Pressure Vessel Inspectors (D. J. Mcdonald) iiii) The National Board of Boiler and Pressure Vessel Inspectors letter (D. J. Mcdonald)-interim report dated August 17,_1984 to Commonwealth Edison Company (C. Reed)

Dear Mr. Reed:

The National Board audit team returned to the Byron Station on September 4-7, 1984. The purpose was to review with Commonwealth Edison Company and their sub-contractors the contents of the National Board's August 17, 1984 letter (iiii) -cnd to follow-up on corrective actions taken in response to the findings and con- . cerns stated in that report. This letter is to apprise you of the current status of those ite=s. During the week, Commonwealth Edison Company management presented to the National Board audit team their proposal for corrective action.to address the National Board findings. This letter will refer to those items by report paragraph number and give a brief summary of the status of each.

.W /

3.,.

L o'rdell-Reed. C

September 21, 1984 p' age ? 2 -

i3.0 ; Hunter Corporation. .3.1 The National Board au'dit team has reviewed the addenda revision to the Hunter Corporation's Quality Assurance Manual, Sections 2 and 4'and the draft revision #14 to their Site Implementation Procedure -(SIP) 4.0 and find _them acceptable. This item will be closed upon completion of the review and approval cycle and transmittal of those items through Commonwealth Edison Company to the National ' Board-audit team, and verification of. implementation on the National -Board audit team's return to the Byron Station. 3.2 The National Board audit ~ team has reviewed the amendments to Hunter - Corporation's Site Implementation Procedure 6.501 and find them acceptable. This item will be closed upon receipt by the audit team from Commonwealth Edison Company copies of the approved SIP 6.501' amendment and verification of acceptable implementation on 'the National Board audit team's return to the Byron Station. 3.3 -The National Board audit team has reviewed the " interface agreement" between Commonwealth Edison Company, Hunter Corporation and Pittsburgh 1 Testing Laboratories (revised to exclude the arbitration clause) and find'it acceptable to preclude reoccurance of the deficiency. This item will be closed.upon receipt by the National Board audit team from Commonwealth Edison Company of a formal record copy of1this agreement. f3.4'1The National Board audit team discussed with Commonwealth Edison Company and Hunter Corporation personnel the possibility of adoption of 'the' provisions of Code Case N-302 as an acceptable alternative to the requirements of NX-4231.1. It was agreed that Conmonwealth Edison . Company's subcontractors, have in the past and-presently, do meet the alternative provisions of Code Case N-302, even though it had not been previously-adopted. Code Case N-302 has previously been accepted for . use by the Nuclear. Regulatory Commission under Regulatory Guide 1.84. To adequately adopt _and implement the provisions of Code Case N-302, the.following. activities remain to be completed: 1) . Notification of the jurisdictional authority (State of Illinois) and' receipt of their acceptance'of the adoption of the provisions - of ' Code Case N-302. ' ~ 2) Revisions of the appropriate portions of the design specifications applicable to eachlof the Commonwealth Edison Company's subcon-tractors.to' include reference to the use of Code Case N-302. 3)- Nctification of the Nuclear Regulatory Commission of the adoption of Code Case N-302. d . E E m m

-/ _ Cordell Reed # ? September 21, 1984 page 3; 4)- Identification and revision of the appropriate N-5 Data Reports to reference the use of Code Case N-302. Upon verification of the corrective action as proposed in the above listed items, the National Board audit team will consider this finding as closed with no adverse impact on the hardware at the Byron Station. 3.5 The National Board audit team has received and reviewed the necessary documentation and consider this item <as closed. ' 4.0 Nuclear Installation Services Company (NISCO) The National Board audit team will consider this finding as closed (reference paragraph 3.4). 5.0 Power Azco Pope JV (PAP) The National Board audit team will consider this finding as closed (reference paragraph 3.4). 6.0 Hartford Steam Boiler Inspection and Insurance Company (HSB) 6.1 The National Board audit team has received the documentation for cor-rective action via Com=onwealth Edison Company letter PM84-63, dated September 6, 1984. The team has reviewed this documentation and find the statements of corrective action as acceptable and thereby consider this item as closed. 6.2' The National Board audit team has received and reviewed the necessary documentation and consider this item as closed. 6.3 -The National Board audit team has received and reviewed the necessary corrective action documentation via Commonwealth Edison Company letter PM-84-63, dated September 6,1984, and find those corrective action statements acceptable. The National Board audit team considers this item as closed. 7.0 ' Westinghouse Electric Corporation The National Board ~ audit team reviewed t'he Westinghouse Electric Corpora-tion documentation relative to the modifications made to the Unit #1 steam generators. This documentation was acceptable and the National Board audit team's concern is closed. 8.0 Contracting Materials Corporation The National Board audit team has no findings or concerns (iiii). e I

N t Cord 211-Reed 3 September 21, 1984 ) v page 4 1 3 9.0 McCartin McAuliffe Mechancial Centractors, Inc. The National Board audit team has no findings or. concerns (iiii). -Summag It was agreed.that Commonvealth Edison Company would advise the National Board audit team of a date the audit team could return to the Byron Station for ver- ~ 'ification of corrective action to close out all items. The tentative date dis-cussed was October 15, 1984 or later.< (- The National. Board audit. team awaits notification by Co monwealth Edison Company of the date they may return to~the Byr'on Station for follow-up and closure of the remaining ite=s. .I The National Board audit team expresses their' appreciation to all personnel con-tacted during this audit and for thein cooperation and the professionalism they .have'shown. Respectfully submitted, /vik D'. Mcdonald, Director of Inspections uc.h-O y [ Charles W. Allison, Tea Leader' Michael F. Sullivan, Team Member ).. Robert P. Holt, Team Member /jd . S. F. Harrison, National Board of Boiler and Pressure Vessel Inspectors cc: J. F. Streeter, USNRC J. C. Keppler, USNRC ^ 'D. Callup, State of Illinois =-}}