ML20140D533
| ML20140D533 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 01/07/1986 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1102K, NUDOCS 8602030052 | |
| Download: ML20140D533 (3) | |
Text
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0*O Commonwealth Ediscri O
One Fust Nationst Plaza, Chicago, ilhnois C
Address Rzply to: Post Office Box 767
.g Chicago, Illinois 60690 January 7, 1986 Mr. James G. Keppler Regional Administrator Region III U. S. Nuclear Regulatory Ccmmission 799 Roosevelt Road Glen Ellyn, Il 60137 SU!!iECT:
Braidwood Station Units 1 and 2 Response to Inspection Reports Nos.
50-456/85-038 and 50-457/85-037 NRC Docket Nos. 50-456 and 50-457 REFERENCE (a):
W.S. Little letter to C. Reed dated November 27, 1985
Dear Mr. Keppler:
This letter is in response to the inspection conducted by Messrs. R.D. Schulz and W.J. Kropp on September 9 through October 18, 1985, of activities 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 t ly yours, m
I 1
D. L. Farrar Director of Nuclear Licensing Enclosure cc: NRC Resident Inspector - Braidwood 1102K B602030052 860107 PDR ADOCK 05000456 O
'JAN 101986 zaoi o, e
COMMONWEALTH EDISON COMPANY RESPONSE TO INSPECTION REPORT 456/85-038: 457/85-037 Violation (456/85-038-07: 457/85-037-05 and 456/85-038-08: 457/85-037-06) 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.
Commonwealth Edison's Quality Assurance Program Manual, Quality Procedure (QP) 15-2, Revision 6 " Reporting Significant Deficiencies That Occur During construction and Tests", Section 5.1 states in part that immediately upon observance or discovery of a potential significant deficiency the individual shall notify the Project Construction Superintendent or Cognizant Engineering Project Manager.
Section 5.15 further states in part that an evaluation shall be conducted of the factors involving each identified outside organization reported deficiency to determine if it constitutes a reportable deficiency.
The evaluation must be documented by the cognizant Engineer.
Pullman Sheet Metal Works Procedure B16.2.F. Revision 0, January 18, 1985,
" Corrective Action," states in part in Section 6.3.B. " CAR Closure," that the Quality Engineer shall assure the corrective action identified has in fact been implemented and is effective.
Contrary to the above:
- a. Pullman Corrective Action Requests (CARS) 002 and 005 were closed by Pullman Quality Assurance prior to verifying that all the corrective actions stated in CARS 002 and 005 were implemented and effective.
- b. Pullman Procedure B16.1.F. "Nonconformances," Revision 7. June 17, 1985, does not require deficiencies identified as potentially reportable to be identified to the licensee.
Response
Commonwealth Edison acknowledges that Pullman CARS 002 and 005 were closed by Pullman Quality Assurance prior to verifying that all the corrective actions stated in the CARS were implemented and effective. Also, Pullman Procedure B16.1.F. "Nonconformances", Revision 7, did not require deficiencies identified as potentially reportable to be identified to Commonwealth Edison.
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p.
Corrective Action Taken and Results Achieved a.
Pullman Sheet Metal's (PSM) Quality Assurance organization performed surveillances to verify that all corrective actions required by CARS 002 and 005 were properly implemented and effective. These surveillances were documented by PSM on Survey #'s QA-S-85-111, QA-S-85-092 and QA-S-85-093.
These surveillances showed the corrective actions for CARS 002 and 005 had been properly implemented and effective.
b.
Unrelated to this issue, commonwealth Edison Project Construction conducted a review of all PSM NCRs issued prior to December 5,1984 for reportability under the provisions of 10 CFR 50.55(e).
This review resulted in no NCRs, that had not been previously reported, being considered reportable. On December 5, 1984, Commonwealth Edison Project Construction enhanced the method for documenting the review for reportability of contractor NCRs. Until December 23, 1984, PSM Procedure B16.1.F required all PSM NCRs to be submitted to Commonwealth Edison for review. Revision 4 of this procedure changed the submittal requirements such that NCRs dispositioned " Rework" or " Reject" were not submitted to Commonwealth Edison. PSM will perform a review of all NCRs issued after December 5,1984 to determine if Commonwealth Edison has been notified of all NCRs that were considered potentially reportable by PSM.
Currently, PSM NCRs that are dispositioned "Use-As-Is" or " Repair" are submitted to Commonwealth Edison for approval. This population of NCRs is considered the population most likely to contain a reportable condition.
Commonwealth Edison believes that no further action is warranted.
Corrective Action Taken to Avoid Further Violation a.
PSM Procedure B16.2.F, was revised to enhance the requirements for verification of the completion and effectiveness of corrective actions prior to closure of a CAR.
The revised procedure was approved by Commonwealth Edison on January 2, 1986. Procedure B16.2.F. Revision 2, will be implemented after PSM conducts the necessary training, b.
Based on previous direction from Commonwealth Edisca, PSM revised Procedure B16.1.F to include a documented review by PSM of all NCRs for reportability under the provisions of 10 CFR 50.55(e) and 10 CFR Part 21 and to notify Commonwealth Edison of any NCR deemed potentially reportable. Procedure B16.1.F. Revision 8, was approved by Commonwealth Edison on October 7, 1985, and implemented by PSM on October 21, 1985.
Date of Full Compliance a.
Training to and implementation of PSM Procedure B16.2.F, Revision 2, will be completed by January 10, 1986.
b.
Full compliance will be achieved by January 31, 1986.
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