ML20147B108

Response to 780807 NRC Ltr Re Deviation Noted in Inspec Rept 50-456/78-06 & 50-457/78-06.Util Contends That Items Result from Misinterpretation of Observations & of Standards & Requests Infractions Be Downgraded or Held in Abeyance

ML20147B108
Person / Time
Site:	Braidwood
Issue date:	09/07/1978
From:	Reed C COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 7810050061
Download: ML20147B108 (7)

Text

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• Commonwealth Edison

/ "j%'3y Q one rnu Nancnal Plaza Chr.ago. jn.nois Add'ess Reply to. Post Othcc Box 767

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Chicago, lilinois 60690 September 7, 1978 Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Subject:

Braidwood Station Units 1 a'nd 2 Response to IE Inspection. Report Nos. 50-456/78-06 and 50-457/78-06 NRC Docket Nos. 50-456 and 50-457 Reference (a) : R. F. Heishman letter to Byron Lee, Jr.

dated August 7, 1978 l NRC Docket Nos. 50-456 and 50-457 l

Dear Mr. Keppler:

The following is in response to an inspection conducted-by Messrs. C. M. Erb, K. D. Ward and E. J. Gallagher l

of your office on June 13-15, 1978 of activities at Braidwood '

Station. FN. Heishman's letter, Reference (a), indicated that certain of our activities appeared to be in noncompliance with NRC requirements. The attachment to this letter discusses these items and, based on the additional information presented, requests your consideration in changing the first two items from infractions to observations. The attachment also requests that the third item of apparent noncompliance be placed in abeyance until Commonwealth Edison Company receives a response on the code inquiry which Commonwealth Edison has submitted to the American Society of Mechanical Engineers (ASME) Committee.

Please address any additional questions that you might have to this office.

Very truly yours,

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ccL /Cordell Reed

-} { j 00jr 00 G/. . Assistant Vice-President attachment . 't ECO c

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, Common.wcalth Edison- SRC.Dochet Nos. 150--456/457-ATTACRMENT r .

LITEM A.1 i

Contrary to 10 CFR 50,. Appendix B, Criterion XII, the Braidwood Station PSAR, Chapter-17, and the Commonwealth Edison QA Manual, Quality Requirement QR-12, on June 13-15, 1978, the inspector determined that Pittsburgh Testing Laboratory (PTL) was using. standard sieves for acceptance of materials affecting quality, such as aggregate and soils gradation tests, that did not' meet the requirements of ASTM E-ll, " Standard Specification for Wire-Cloth Sieves used for Testing Purposes", in that the #8,

1. 50, and #100 sieves had " punctures or other obvious defects in  !

i the cloth". Furthermore, the PTL procedure QC-cal-3, Tools, Gauges,'and Instrument Control did not-include,these or any of the standard -sieves in the inspection and calibration frequency or control requirements.

RESPONSE

The apparent noncompliance involved the use of defective and "uncalibrate'd" sieves. The guidance which our testing laboratory is and has been using for. testing is the appropriate ASTM standards. Many standards relating to this area exist. By various ASTM. standards (C-136, 134, etc.) , Commonucalth Edison is l recuired to use . sieves manuf actured in accordance with ASTM E-ll.

ASTM.E-ll in tu'rn clearly _ states with a footdate to the scope section that " complete instructions.and procedures on the use of test si' eves are contained in ASTM STP~447". This cascading of standards forms the basis for applying the guidance of ASTM STP 447 for instructions on the use of test sieves as discussed below.

The NRC inspector observed four "obviously" defective sieves (one #8, two #50's, and one #100). Two of the sieves, one

1. 8 and one #50, did indeed have punctured screens at the time of the NRC Audit. . The PTL Lab Supervisor acknowledged the fact that the two screens were now defective but stated that the two sieves were not damaged the previous day when he inspected them prior to their use ' in accordance with PTL . Procedure QC-LT-1. Further,-

ASTM STPc447A as. referenced' in ASTM E-ll states in part " holes or breaks; are sometimes --indicated -by very noticeable irregularities -

in the end-point weighings". N,o such irregularities have been observed. : In view lof ~ this, Codmonwealth Edison' is very confident that_no defective or punctured. sieves were used to perform any stests! In addition,Edue to the nature of the equipment, the physical:

condition'of-all^ sieves is examined prior to each test to assure that:no~defectiveLsieves.are used.

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Commonwealth Edison URC Docket Nos. 50-456/457 The physical condition of the two punctured sieves would have been observed and found unacceptable by PTL technicians during their routine pre-test equipment inspection. Upon observance of the defective nature of the sieves, they would have been immediately removed from use and replaced, as was the case.

The fact that the NRC inspector examined the two sieves prior to our required inspection should not be used as a basis for questioning the quality of future inspections. Furthermore, since time had elapsed since the last test was performed with these sieves, the NRC inspect'or should not assume that the physical condition found when examined also existed during previous tests. Rather, the fact that the sieves had not been placed in a protected storage area is a more plausible explanation for the condition of the sieves when observed by the NRC inspector. As a result, a special storage rock has been constructed for protection of sieves.

The inspector also observed two' additional defective sieves (one #50 and , one #10,0) . However, the inspection report did not clearly indicate the form of the defects in these sieves.

Although based on observations while accompanying the inspector during his examination and subsequent visual examinations, Commonwealth Edison personnel concluded that the referenced

" defects" were as follows: .

1. The #50 sieve was discolored due to use of a zine-chloride solution to perform the ASTM-Cl23 test for lightweight pieces in aggregate. ASTM-C123 specifics the use of sieves manufactured in accordance with ASTM E-ll.

However, neither ASTM-Cl23 nor ASTM STP 447 warns, or even cautions against the normal discoloration of brass sieves when used with zinc-chloride.

Therefore, Commonwealth Edison has concluded that discoloration is an expected condition and not a defect.

2. The.only observable discontinuity on the #100 sieve was an area which had been repaired by soldering. ASTM STP 447A " Manual on Test Sieving Methods" establishes and allows for this type of repair by stating in part "small holes can be repaired by soldering".

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' .' Commonwealth Edison "NRC Docket 5os.150-456/457 q If;the discontinuities, as discussed above, were not 3 the cause of the apparent noncompliance, Commonwealth Edison 'l 7

would ' appreciate a prompt disclosure of their exact. nature. ]

if'the " defects" were as previously-described, l

However, C'ommonwealth Edison requests - that the NRC reconside r it s j j

findings since no physical requirements appear to have baen v iola,t e d . . In~ addition, ' Commonwealth Edison is concerned that - ,

the aesthetics of the sieves-in a field laboratory environment-may have had~an undue influence on the inspector's observations.

The discolored #50 sieve and the solder repaired #100 sieve along with the two previously menti'oned defective sieves were removed from use immediately after the inspection. However, based on the above considerations, there appears'to be no reason why. the

1. 50 and #100 sieves cannot,be returned to service.

The secondary portion of the apparent noncompliance deals- with the lack of a program for calibrating sieves to j

. ASTM'E-ll. Pittsburgh Testing Laboratory '(PTL) does not include the calibration of sieves in' its calibration procedures, QC-CAL-3,.because no calibration of sieves is required. ' ASTM E-ll Standard Specification for Wire-Cloth Sieves for Testing Purposes is a manufacturing standard. ASTM STP 447A, " Manual on~ Test l Sieving Methods", states that " ASTM Specifications E-ll specify ]

.certain~ manufacturing tolerances". Upon receipt of the sieves l PTL verifies that certification to ASTM E-11 accompanies each sieve.

According to ASTM STP 447A "a test sieve should retain the accuracy of.its openings throughout the lifs of the sieve, I since ordinary wear is on the top of the knuckles of the wire l cloth and no' measurable wear occurs in the openings".

Furthermore,. ANSI N45.2, Section 13 dealing with calibration states "This requirement. (for calibration) is'not intended to bmply a need for special calibration and control measures on rulers, tape measures, levels and such other devices if normal oractices provide adeauate accuracy". Commonwealth Edison feels that sieves are covered by this category since ASTM E-ll requires a permane'nt label stating certification be affixed to'the sieve by the sieve manufacturer and since the-previous quote from' ASTM 447A clearly implies that this is the case!'

The fact that ASTM E,ll:is a manufacturing standard ~

is- additionally reinforced by the following. statement on sieve y

. ' skirts '" . . . the: bottom of the frame or sieve skirt shall' be- ,

so constructed:as to have an easy sliding fit in any. sieve".

~

- . Thel NRC ' Inspection 1 Report references the aforementioned statement

.and continues with'"The inspector-observed thatLnone of the sieves;being used met this requirement". The. sieves in use are

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Commonwealth Edison NRC Docket Nos. 50-456/457 t

certified to be manufactured (constructed) to fit easily together, however, it is inconceivable that the slight  !

tolerance dimension of +.03 in, referenced in ASTM E-ll is intended for' verification of test sieves being used in a field laboratory. The ASTM standard for " Test Sieving Methods" does I not appear to be concerned with the fit of the sieve skirts as l it does not even deign to mention this fact when describing the l effects of wear on the accuracy of the sieves. l At the time of the inspection, ASTM STP 447A " Manual on Test Sieving Methods" was not used as a basis for the NRC inspector's determination. By various ASTM standards (C-136, 134, etc.) Commonwealth Edison is recuired to use sieves  !

manufactured in accordance with ASTM E-ll which states " Complete instructions and procedures on the use of test sieves are con- l tained in ASTM STP 447". ASTM STP 447 in turn refers to E-ll f to "specify certain manufacturers tolerances". Commonwealth j Edison is concerned that the requirements applicable to h manuf acturing and manuf acturer 's responsibilities were in- l correctly imposed on sieves being used in its field testing i laboratories. Therefore, based on this additional information which identifies a more appropriate baseline for interpretation ]

of the inspector's field observations, Commonwealth Edison recuests that the NRC reexamine this apparent item of noncompliance and consider changing this infraction to an ,

observation.

ITEM A.2 .

I Contrary to 10 CFR 50, Appendix B, Criterion XIII, and the Commonwealth Edison QA Manual Quality Requirement OR-13 which requires cleaning and preservation of materials in accordance with work and insp'ection procedures to prevent damage and deterioration, on June 13-15, 1978 the inspector determined that the Unit 1 & 2 tendon bearing plates and trumplets were not being maintained in accordance with specification L-2721, Section 2-303(d). This states, "the interior surfaces on all trumplets and funnels shall be protected from corrosion prior 3 to tendon and greasing installation by coating and inside surface with a film of . . . the contractor shall maintain this  ;

coating protection during the entire course of work until tendons are in place and grease is installed" (emphacis {

included in spec.) The inspector observed 162 vertical tendon l bearing plates and trumplets in both Units 1 and 2 noted ,

surface corrosion in every instance.

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• l Commonwealth Edison ~ NRC Docket Nos. 50-456/457 l 5-  ;

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RESPONSE

Commonwea".th Edison disagrees with the finding that there was surface corrosion in every instance. The inspector was informed that the great majority of the surface rusting was actually a coating of rust particles which had been washed down from the vertical sheathing. This was confirmed in the presence of the inspector by scraping some of this rust coating off the bearing plates, revealing that the plate surface coating was still intact.

Based on this information, Commonwealth Edison requests that the NRC reexamine this apparent item of noncompliance and consider changing this infraction to an observaItion.

As a further measure of protection, immediately after this inspection the coating of rust particles was removed from the vertical tendon bearing plates and trumplets in both Units 1 and 2 and an additional protective grea'e s coating was applied to minimize corrosion potential. This grease coating will be maintained on the bearing plates and trumplets with no further maintenance being conducted until just prior to the tendon installation at which time the surfaces of the beering plates ,

will be cleaned. In addition, monthly surveillanges of the  !

tendon tunnel will be performed by the contractor in order to maintian this grease coating and minimize any corrosion potential.

ITEM A.3 Contrary to 10 CFR 50, Appendix B, Criterion IX; the Lraidwood PSAR, Table 3.2-2, which lists ASME Section III as'the applicable code for class 1,'2 and 3 components and piping systems; the S&L Specification No. L/F 2739 which specifies safety related piping shall be in accordance with ASME Section III, 1974 Edition; and subarticle NB5100, ASME Section III, which states in part that radiographic examination shall be in accordance with ASME Section V, Article 2, the inspector observed during review of radiographs of three welds that an Iridium 192 source had been used on material less than 0.75 inches without a special procedure being prepared and proven satisfactory by actual demonstration as require $ by ASME Section V.

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, ,. Commonwealth Edison NRC Docket Sc3 50-456/457

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RESPONSE

ASME Section V, Article.2, 1974 Edition states in part "A special procedure shall be prepared and proved ,

satisfactory by actual demonstration of penetrameter resolution." l It is Commonwealth Edison Company's interpretation that an additional "special" procedure is not intended by the code.

when an existing procedure produces radiographs of acceptable sensitivity. It is Commonwealth Edison's contention that the procedure is p'roven satisf actory with each radiograph shot "by actual demonstration of penetrameter resolution."

In order to clarify this position, Commonwealth Edison has submitted a code inquiry to the appropriate committee of the American Society of Mechanical Engineers. A written reply is anticipated from the committee byithe end of October 1978.

Therefore, Commonwealth Edison Company requests that this item of apparent noncompliance be placed in abeyance until Commonwealth Edison receiver a response on this code inquiry.

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Commonwealth Edison

', y ] ow ras! Nax.nai Piara Crr.ago pno's Acc ess Reply lo Post O!!+ce Box 767

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Chicago. libnois 60690 Septem'oer 7, 1978 Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Subject:

Braidwood Station Units 1 a'nd 2 Response to IE Inspection Report -

Nos. 50-456/78-06 and 50-457/78-06 NRC Docket Nos. 50-456 and 50-457 Reference (a) : R. F. Heishman letter to Byron Lee, Jr.

dated August 7, 1978 NRC Docket Nos. 50-456 and 50-457

Dear Mr. Keppler:

The following is in response to an inspection conducted by Messrs. C. M. Erb, K. D. Ward and E. J. Gallagher of your office on June 13-15, 1978 of activities.at Braidwood Station. Mr. Heishman's letter, Reference (a), indicated that certain of our activities appeared to be in noncompliance with NRC requirements. The attachment to this letter discusses these items and, based on the additional information presented, requests your consideration in changing the first two items from infractions to observntions. The attachment also requests that the third item of apparent noncompliance be placed in abeyance until Commonwealth Edison Company receives a response on the code inquiry which Commonwealth Edison has submitted to the American Society of Mechanical Engineers (ASME) C omraitt e e .

Please address any additional questions thct you might have to this office.

Very trulv vours, LPD1L -

~78 / 0 0 5'00 6 / )) ~ .da u'L "Cordell Reed Assistant Vice-President PDK A M c-k- os v- yrs 9 76%9 xy .p'

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Commonwealth Edison NRC Docket Nos. 50-456/457 ATTACHMENT

_I_ TEM A.1 l

Contrary to 10 CFR 50, Appendix B, criterion XII, the Braidwood Station PSAR, Chapter 17, and the Commonwealth Edison l

QA Manual, Quality Requirement QR-12, on June 13-15, 1978, the l inspector determined that Pittsburgh Testing Laboratory (PTL) was I using standard sieves for acceptance of materials affecting quality, such as aggregate and soils gradation tests, that did not meet the requirements of ASTM E-11, " Standard Specification for Wire-Cloth Sieves used for Testing Purposes", in that the #8,

1. 50, and #100 sieves had " punctures or other obvious defects in the cloth". Furthermore, the PTL procedure QC-cal-3, Tools, Gauges, and Instrument Control did not include,these or any of the standard sieves in the inspection and calibration frequency <

or control requirements.

RESPONSE

The apparent noncompliance involved the use of defective and "uncalibrated" sieves. The guidance which our testing laboratory is and has been using for testing is the appropriate ASTM standards. Many standards relating to this area exist. By various ASTM standards (C-136, 134, etc.), Commonwealth Edison is recuired to use sieves manuf actured in accordance with ASTM E-ll.

~

ASTM E-ll in tu'rn clearly states with a footdote to the scope section that " complete instructions and procedures on the use of test si' eves are contained in ASTM STP 447". This cascading of standards forms the basis for applying the guidance of ASTM STP 447 for instructions on the use of test sieves as discussed below.

The NRC inspector observed four "obviously" defective j sieves (one #8, two #50's, and one #100). Two of the sieves, one  :

1. 8 and one #50, did indeed have punctured screens at the time of the NRC Audit. The PTL Lab Supervisor acknowledged the fact that the two screens were now defective but stated that the two sieves were not damaged the previous day when he inspected them prior to their use in accordance with PTL Procedure oc-LT-1. Further, ASTM STP 447A as referenced in ASTM E-ll states in part " holes or breaks are somet ime s indicated by verv noticeable irregularities in the end-point weighings". No such irregularities have been observed. In view of this, Cochonwealth Edison is very confident that no defective or punctured sieves were used to perform any tests! In addition, due to the nature of the equic=ent, the physica!

condition of all sieves is examined prior to each test tc assure that no defective sieves are used.

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', Commonwealth Edison NRC Docket Nos. 50-456/457

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The physical condition of the two punctured sieves would have been observed and found unacceptable by PTL technicians during their routine pre-test equipment inspection. Upon obser'vance of the defective nature of the sieves, they would have been immediately removed from use and replaced, as was the case.

The fact that the NRC inspector examined the two sieves prior to our required inspection should not be used as a basis for questioning the quality of future inspections. Furthermore, since time had elapsed since the last test was performed with these sieves, the NRC inspect'or should not assume that the physical condition found when examined also existed during previous tests. Rather, the fact that the sieves had not been placed in a procected storage area is a nore plausible explanation for the cordition of the sieves when observed by the NRC inspector. As a result, a special storage rack has been constructed for protection of sieves.

The inspector also observed two additional defective sieves (one #50 and one #10,0) . However, the inspection report did not clearly indicate the form of the defects in these sieves.

Although based on observations while accompanying the inspector during his examination and subsequent visual examinations, Commonwealth Edison personnel concluded that the referenced

" defects" were as follows: .

1. The #50 sieve was discolored due to use of a zinc-chloride solution to perform the ASTM-Cl23 test for lightweight pieces in aggregate. ASTM-C123 specifies the use of sieves manufactured in accordance with ASTM E-ll.

However, neither ASTM-Cl23 nor ASTM STP 447 warns.

or even cautions against the normal discoloration of brass sieves when used with zinc-chloride.

Therefore, commonwealth Edison has concluded that discoloration is an expected condition and not a defect.

2. The only observable discontinuity on the #100 sieve was an area which had been repaired by soldering. ASTM STP 447A " Manual on Test i Sieving Methods" establishes and allows for this type of repair by stating in part "small holes can be repaired by soldering".

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- Commonwealth Edison NRC Docket Nos. 50-456/457 If the discontinuities, as discussed above, were not the.cause of the apparent noncompliance, Commonwealth Edison would appreciate a prompt disclosure of their exact nature.

However, if the " defects" were as previously described,

! C'ommonwealth Edison requests that the NRC reconsider its findings since no physical requirements appear to have been violated. In addition, Commonwealth Edison is concerned that the aesthetics of the sieves in a field laboratory environment may have had an undue influence on the insoector's observations.

The discolored #50 sieve and the solder repaired #100 sieve along  ;

with the two previously menti ^oned defective sieves were removed from use immediately after the inspection. However, based on the '

the above considerations, there appears to be no reason why

1. 50 and #100 sieves cannot be returned to service.

The secondary portion of the apparent noncompliance 9 deals with the lack of a program for calibrating sieves to ASTM E-ll. Pittsburgh Testing Laboratory (PTL) does not include the calibration of sieves in its calibration procedures, QC-CAL-3, because no calibration of sieves is required. ASTM E-11 standard Specification for Wire-Cloth Sieves for Testing Purposes is a manufacturing standard. ASTM STP 447A, " Manual on Test Sieving Methods" , states that " ASTM Specifications E-ll specify

.certain manufacturing tolerances". Upon receipt of the sieves PTL verifies that certification to ASTM E-ll accompanies each sieve.

According to ASTM STP 447A "a test sieve should retain the accuracy of its openings throughout the lif6 of the sieve, since ordinary wear is on the top of the knuckles of the wire cloth and no measurable wear occurs in the openings".

Furthermore, ANSI N45.2, Section 13 dealing with calibration states "This requirement (for calibration) is not intended to i imply a need for special calibration and control measures on rulers, tape measures, levels and such other devices if normal cractices erovide adequate accuraev". Commonwealth Edison feels that sieves are covered by this category since ASTM E-ll requires a permanent label stating certification be affixed to the sieve by the sieve manufacturer and since the previous quote from ASTM 447A clearly implies that this is the case!

The f act that ASTM E ,ll is a manuf acturing standard is additionally reinforced by t'he following statement on sieve skirts "... the bottom of the frame or sieve skirt shall be so constructed as to have an easy sliding fit in any sieve".

The NRC Inspection Report references the aforementioned statement and continues with "The inspector observed The that none of the sieres in use are sieves being used met this requirement".

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. Cornmonwealth Edison- PRC Docket Nos. 50-456/457-certified to be manufactured (constructed) to fit easily together, however, it is inconceivable that the slight

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tolerance dimension of +.03 in. referenced in ASTM E-ll is

{ intended for' verification of test sieves being used in a field laboratory. The ASTM standard for " Test Sieving Methods" does not appear to be concerned with the fit of the sieve skirts as it does not even deign to mention this fact when describing the j effects of wear on the accuracy of the sieves.

At the time of the inspection, ASTM.STP 447A " Manual on Test Sieving Methods" was not used as a basis for the NRC inspector's determination. By various ASTM standards (C-136, 134, etc.) Commonwealth Edison is required to use sieves manufactured in accordance with ASTM E-ll which states " Complete instructions and procedures on the use of test sieves are con- ,

tained in ASTM STP 447". ASTM STP 447 in turn refers to E-ll to "specify certain manufacturers tolerances". Commonwealth Edison is concerned that the requirements applicable to manuf acturing and manuf acturer's responsibilities were in-correctly imposed on sieves being used in its field testing laboratories. Therefore, based on this additional information which identifies a more appropriate baseline for interpretation of the inspector's field observations, Commonwealth Edison requests that the NRC reexamine this apparent item of ,

noncompliance and consider changing this infraction to an observation.

ITEM A.2 Contrary to 10 CFR 50, Appendix B, Criterion XIII, and the Commonwealth Edison QA Manual Quality Requirement QR-13 which requires cleaning and preservation of materials in accordance with work and insp'ection procedures to prevent damage and deterioration, on June 13-15, 1978 the inspector determined that the Unit 1 & 2 tendon bearing plates and trumplets were not being maintained in accordance with specification L-2721, Section 2-303(d). This states, "the interior surf aces on all trumplets and funnels shall be protected from corrosion prior to tendon and greasing installation by coating and inside '

surf ace with a film of . . . the contractor shall maintain this coating orotection durina the entire course of work until tendons are in olace and arease is installed" (emphasis included in spec.) The inspector observed 162 vertical tendon -

bearing platec and trumplets in both Units 1 and 2 noted surface corrosion in every instance'.  !

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' Commonwealth Edison ~NRC Docket Nos,._ 50-456/457

,.- .. 5-RESPONSE __

Commonwealth Edison disagrees with the finding that therewas surface corrosion in every instance. The inspector was informed'that the great majority of the surface rusting was actually a coating of rust particles which had been washed dow'n from the vertical sheathing. This was confirmed in the presence of the-inspector by scraping some of this rust coating off the bearing plates, revealing that the plate surface coating was still intact.

Based on this information, Commonwealth Edison. recuests that the NRC reexamine this apparent item of noncompliance and consider changing this infraction to an observa' tion. I ;

As a further measure of protection, immediately after-this inspection the coating of rust particles was removed from the vertical tendon bearing plates and trumplets in both Units 1

-and 2 and an additional protective grea'se coating was applied to minimize corrosion potential. This grease coating will be maintained on the bearing plates and trumplets with no further maintenance being conducted until just prior to the tendon installation at which time the surf aces of the bearing plates t will be. cleaned. In addition, monthly surveillances of the tendon tunnel will be performed by the contractor in order to maintian this grease coating and minimize any corrosion potential.

ITEM A.3 contrary to 10 CFR 50, Appendix B, Criterion IX; the Braidwood PSAR, Table 3.2-2, which lists ASME Section III as'the applicable code for class 1, 2 and 3 components and piping 1' systems; the S&L Specification No. L/F 2739 which specifies safety related piping shall be in accordance with ASME Section III, 1974 Edition; and subarticle NB5100, ASME Section III, which I states . in part that radiographic examination shall be :bs i accordance with ASME Section V, Article 2, the inspector observed during review of radiographs of three welds that an Iridium 192 source had been used on material less than 0.75 inches without a special procedure being' prepared and proven satisfactory by actual demonstration as required by ASME Section V.

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Commonwealth Edison tmC-Docket Nos. 50-456/457 i

RESPONSE

ASME Section V, Article 2, 1974 Edition states in

. 7' part "A special procedure shall be prepared and proved satisfactory by actual demonstration of penetrameter resolution,"

• It is Commonwealth Edison Company's interpretation that an additional "special" procedure is not intended by the code when an existing procedure produces radiographs of acceptable sensitivity. It is Commonwealth Edison's contention that the procedure is p'roven satisf actory with each radiograph shot "by actual demonstration of penetrameter resolution."

In order to clarify this position, commonwealth Edison has submitted a code inquiry to the appropriate committee of the ,

i American Society of Mechanical Engineers. A written reply is anticipated from thefcommittee by the end of October 1978.

Therefore, Commonwealth Edison Company requests that this item of apparent noncompliance be placed in abeyance until Commonwealth Edison receive,s a response on this code inquiry.

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