ML20140B739
| ML20140B739 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 12/20/1985 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1036K, NUDOCS 8601270115 | |
| Download: ML20140B739 (3) | |
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Commonweehh Edison
/ One Fast National Plata Chgogno's i
O 7 Address Reply to Post Office Box 767
'Q Chicago. Ilknois 60690 i
December 20, 1985 l
Mr. James G. Keppler Regional Administrator Region III
(
U.
S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, 11 60137 I
SUBJECT:
Braidwood Station Units 1 and 2 Response to Inspection Reports Nos.
50-456/85-009 and 50-457/85-009 NRC Docket Nos. 50-456 and 50-457 l
REFERENCE:
(a): J.J. Harrison letter to C. Reed dated November 21, 1985
Dear Mr. Keppler:
This letter is in response to the inspection conducted by i
Mr. J.F. Schapker on March 5 through November 7, 1985 of activities l
at Braidwood Station.
Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements.
The Commonwealth Edison Company response to the Notice of Violation is provided in the enclosure.
If you have any further questions on this matter, please direct them to this office.
Very truly yours, t
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D.
L. Farrar Director of Nuclear Licensing Enclosure cc:
NRC Resident Inspector Braidwood-1036K i
8601270115 951220 mc PDR ADOCK 05000456 uLL.231985 o
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COMMONWEALTH EDISON COMPANY RESPONSE TO INSPECTION REPORT 456/85-009; 457/85-009 Violation (456/85-009-01; 457/85-009-01) 10 CFR 50, Appendix B, Criterion V, states in part that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, and shall be accomplished in accordance with these instructions, procedures, or drawings.
L.K. Comstock Welder Qualification Procedure 4.7.1, Revision 07-18-80, states in part in Section 3.10 that the QC inspector shall have in his possession the Welder Qualification Test Record, Form 88, and the record is to be completed during the period the welder is performing the weld process, and that upon completion of the testino of the weld coupons by the independent testing company the Form 80 is to be signed and dated.
Contrary to the above:
a.
A Wolder qualification record was signed and dated prior to the testing of the welder's coupons by the independent testing company, b.
The welder qualifications records exhibited numerous clerical errors and omissions.
Hosponse Commonwealth Edison acknowledges that a welder qualification record was apparently signed and dated prior to testing by the independent testing company and that some welder qualification records contained minor clerical errors.
Corrective Action Taken_and Results Achieved The L.K. Comstock (LKC) Level III weld inspector participated in the sample review of welder certification packages performed during the NRC inspection.
The packages reviewed were from the earlier years of the project, i.e.
1979-1981.
LKC issued Nonconformance Report (NCH) No. 4795 to address the welder qualification record which was apparently signed and dated prior to the testing of the welder's couponc by the indcpondant testing company and NCR'u #4549 through
- 4656 to address clerical errors found on other welder qualification records.
As stated in the NRC report, the problems were clerical errors and/or inconsictencies in completing the Form 88, Welder and Welding Operator Qualification Test Hocord and, as such, do not make the welder's qualifications indeterminate.
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Since the 1979-1981 period LKC Procedure 4.7.1 has been enhanced to i
prevent such occurrences.
A weld history record has been established for each welder.
A Welder Qualification Card is issued to each welder upon review and signature of the forn 88 by a certified Level III.
The qualification of welders has been assigned I
to specific inspectors who have been trained in the qualification of Welders step by step.
l Recent audits by LKC and Ceco have found that the program in place has resolved these type of problems.
Corrective Action Taken to Avoid Further Violation 1
LKC will review the remaining welder qualification packages.
This review will be done in accordance with LKC procedure 4.13.1.1, l
Turnover Documentation Review, with the exception that the review will be performed by a certified Level II or III weld inspector, f
I Date of Full conDliance i
NCR's 4649 through 4656 have been closed.
NCR 4795 is expected to j
be completed by January 31, 1986.
The review of LKC welder qualification packages is expected to be completed by March 31, 1986.
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