ML20153E565

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Interprets ANSI 45.2.6 Insp Requirements Per 850627 Commitment to Review Util Position in 850506 Response to Violation 1 of 850308 Notice of Violation.Subj Violation Valid
ML20153E565
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 02/20/1986
From: Norelius C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Reed C
COMMONWEALTH EDISON CO.
References
NUDOCS 8602250064
Download: ML20153E565 (2)


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.%$ February 20, 1986 Docket No. 50-456 Docket No. 50-457 Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Reference (a) R. F. Warnick letter to ';. Reed dated March 8,1985 (b) D. L. Farrar letter to J. G. Keppler dated May 6,1985 (c) C. E. Norelius letter to C. Reed dated June 27, 1985 Gentlemen: In our letter to you dated June 27, 1985, we advised you that we were reviewing your position stated in your letter dated May 6, 1985 responding to Violation 1 of the Notice of Violation (N0V) transmitted to you by our letter dated March 8, 1985. Our review of your position versus the requirements of ANSI 45.2.6 for Level I and II inspectors included seeking guidance from NRC Headquarters, and evaluating industry practice and discussing the matter with past and present members of the ANSI 45.2.6 Committee. We have concluded that the correct interpretation of ANSI 45.2.6 inspection requirements is as follows: A Level I inspector may perform inspections to an approved procedure, record the inspection results and accept the results as provided by the procedure. A Level II or III inspector is required to evaluate the Level I inspector's inspection results for validity and acceptability. The evaluation for validity and acceptability shall include reviewing the inspection data sheets and reports, and a periodic observation of the Level I work performance in the field. We have reviewed our NOV and the related inspection report details (Inspection Report 50-456/85-006; 50-457/85-006, Details Section 3). We have concluded that the NOV did not clearly express our inspector's primary concern as stated on page 3 of the Report Details, "...the thrust of this issue concerns the acceptability of inspections performed and accepted solely by Level I QC inspectors." Our NOV should have been written citing the failure of the Level II inspectors to review the Level I inspection results for validity and acceptability. Recent inspections in which we interviewed those who were the Level II inspectors during the period of concern have indicated that the Level II review was directed toward confirming that the inspection records were properly filled ct t, not directed toward assuring the validity and acceptability of the inspection data. This additional information will be documented in the next inspection report written by John Jacobson. 8602250064 e60220 PDR ADOCK 05000456 1 G PDR i0 2Zo/

U V . Commonwealth Edison 2 February 20, 1986 Company Based on the above we have concluded that the subject violation is valid. The corrective action described in your May 6,1985 letter appears to be adequate. We will review your corrective actions during future inspections. Your cooperation with us is appreciated. Sincerely, Charles E. Norelius, Director . Division of Reactor Projects cc: D. L. Faerar, Director of Nuclear Licensing M. Wallace, Project Manager D. Shamblin, Construction Superintendent E. E. Fitzpatrick, Station 4 Superintendent P. L. Barnes, Regulatory Assurance Supervisor DCS/RSB (RIDS)

!                Licensing Fee Management Branch Resident Inspector, RIII Braidwood Resident Inspector, RIII Byron Phyllis Dunton, Attorney General's Office, Environmental Control Division O. W. Cassel, Jr. , Esq.

J. W. McCaffrey, Chief, Public Utilities Division H. S. Taylor, Quality Assurance Division E. Chan, ELD J. Moore, ELD G. Berry, ELD

J. Stevens, NRR The Honorable Herbert Grossman, ASLB The Honorable A. Dixon Callihan, ASLB

- The Honorable Richard F. Cole, ASLB RIIIQg RIII M RIIIhM R Mf RIII #/2UM RIII /f/7//gv Gardner/qg Harr1 Ton Jacohson " L tle Greenman Norelius 2/13/86 </// t// / [ i

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