ML20234D191
| ML20234D191 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 09/10/1987 |
| From: | Butterfield L COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 3528K, NUDOCS 8709220004 | |
| Download: ML20234D191 (3) | |
Text
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g' Commonwealth Edison..
f One Fir:t NT'Jonal Plaza Chicago, Illinois V
- Address Reply to: Post Offica Box 767
. Chicago, Illinois 60690 0767-September 10,'1987 Mr. A. Bert Davis-Regional Administrator U.S. Nuclear Regulatory Commission Region III i
799 Roosevelt Road
~
clen Ellyn, IL -'60137-0
Subject:
.Braidwood Station Unit 1 I
' Response to Inspection Report No. 50-456/87-015 NRC Docket No. 50-456 3
Reference (a):
J.J. Harrison letter to C. Reed dated August 11, 1987
Dear Mr. Davis:
This letter is in response to the inspection conducted by Mr. J.M.
Jacobson,-et, al. during periods.from April through July 1987 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 tho' 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,
. {.
z L. D. Butterfield Nuclear Licensing Manager im Enclosure cc: NRC Resident Inspector - Braidwood' B709220004'870910
$DR ADOCK 0500 6
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ENCLOSURE COMMONWRAL'!H EDISON COMPANY RESPONSE TO INSFECTION REPORT 456/87-015 I
l VIOLATION:
10 CFR 50 Appendix B, Cri'.erion XVI, as implemented by CECO Topical
[
Report CE-1-A, " Quality Assurance PI'ogram for Nuclear Generating Stations,"
1 and CECO Corporate Quality Assurance Manual, Nuclear Generating Stations, I
j
" Quality Requirements," requires that measures shall be established to assure 1
l that conditions adverse to quality are promptly identified and corrected.
l Contrary to the above, certain activities were not accomplished in l
l accordance with these requirements in that two NCRs were issued for one welder I
and one NCR for another, each identifying improperly installed wolds. These three NCRs were treated as isolated instances and consequently the full extent of the nonconforming conditions were not identified.
As a result, inadequate l
corrective action was taken.
RESPONSE
Commonwealth Edison Company acknowledges that upon a retrospective review, the corrective action associated with Phillips, Getschow Company Nonconformance Report (NCR) No. 4259, disclosing downhill welding by welder No. 204 did not identify the full extent of the adverse condition. However, when this concern was identified, Commonwealth Edison Company took prompt and
- l thorough corrective action to identify the full extent of this welder's work and to verify the quality of work or ability to meet design requirements.
Additionally, wo expanded our corrective action investigation to ensure there l
were no other unaddressed Phillips, Getschow Company welders who had performed downhill welding.
Our aggressive actions to address this issue were j
recognized by NRC inspection personnel during our June 24, 1987 meeting, at l
which we presented the results of our investigation.
I In June, 1985, the basis for determining that Phillips, Getschow Company NCR No. 4259 required no further sampling had a strong foundation in the multiple quality confirmation and retrospective inspections programs results that were ongoing at Braidwood Station at that time. We believe the 1
personnel involved with dispositioning, reviewing and approving NCR No, 4259 3
had knowledge of the multiple program results and the fact that these multiple j
reinspection programs had identified no instances of downhill welding by l
Phillips, Getschow company welders. The involved personnel gave recognition d
that this was the second non-conformance generated for downhill welding on f
welder No. 204.
However, based on the fact that wolder No. 204 had his I
employment terminated, the lack of other occurrences with additional welders, and the overall multiple reinspection program results of no design significant discrepancies, they concluded further sampling was unnecessary.
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lu' t CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Commonwealth Edison Company NCR No. 914 has been initiated to predisposition and track the piping supports where downhill welding has been identified or conservatively assumed to exist.
The corrective action required by NCR No. 914 is to replace downhill welds in order to restore margin or to leave the existing condition as is based on design calculations.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION The issues surrounding this violation have served to further heighten awareness among Commonwealth Edison Company and Phillips, cetschow Company personnel of the need to review NCR's from a retrospective viewpoint. Along with our existing nonconformance review system and using this violation as a training aide, we believe our nonconformance review systems have been further strengthened.
Consequently, we believe no additional corrective action is required.
In order to preclude the possibility of any Phillips, Getschow Company welding inspector accepting a vertical downhill weld in the future, Phillips, cetschow Company conducted training in this area for all welding inspectors. This training was completed in July, 1987.
DATE WHEN FULL COMPLIANCE WILL BE ACHTEVED Commonwealth Edison Company NCR No. 914 is expected to be be closed by October 30, 1987.
Full compliance has been achieved in all other areas.
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