ML20093M891

Advises That Explanation of Reinsp Procedures Contained in Encl LO Delgeorge 840822 Ltr Is Accurate.Statements Made by French Should Be Construed Accordingly.Related Correspondence

ML20093M891
Person / Time
Site:	Byron
Issue date:	10/19/1984
From:	Gallo J COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE
To:	Callihan A, Cole R, Smith I Atomic Safety and Licensing Board Panel
References
CON-#484-628 OL, NUDOCS 8410230355
Download: ML20093M891 (4)

Text

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ISHAM, LINCOLN & BEALE COUNSELORS AT LAW THatt FinST NATIONAL PLAZA cHicAso.itumois emne r . h nt N,N w wassiw Tonge sus October 19, 1984 '84 0CT 22 PI:15 Um CE . t cit ,

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Ivan W. Smith, Esquire Dr. Richard F.SiCole Administrative Judge and Administrative Judge Chairman Atomic Safety and Atomic Safety and Licensing Licensing Board Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D. C. 20555 Washington, D. C. 20555 Dr. A. Dixon Callihan Administrative Judge Union carbide Corporation P.O. Box Y Oak Ridge, Tennessee 37830 Ret In the Matter of Commonwealth Edison Company (Byron Nuclear Power Station, Units 1 and 2)

. Docket Nos. 50-454*and 50-455dK-

Dear Administrative Judges:

In accordance with the Commission's disclosure requirements, I am enclosing a letter dated August 22, 1984 from Mr. DelGeorge of Commonwealth Edison Company to Mr.

Keppler of the NRC. The letter, which was sent at Region III's request, provided information regarding data obtained under the Byron Reinspection Program and reported in the June Supplement to the final report. Specifically, the letter explains the nature and results of the reinspection of two attributes under that Program, namely, equipment setting and equipment modification.

8410230355 841019 CI' PDR ADOCK 05000454 0

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p a Mr. French, Partner and Manager of the Electrical Department at Sargent & Lundy, correctly testified that the reinspections for equipment setting and equipment modification were each performed on 50 pieces of safety-related equipment.

(French, prepared testimony at 9,10, ff. Tr. 9044.) However,

- with respect to equipment modification, Mr. French's prepared testimony refers to inspection of "1850 elements". (French, prepared testimony at 10, ff. Tr. 9044.) Moreover, at the hearing on July 27, 1984, Mr. French was asked by Mr. Lewis, NRC Staff Counsel, if with respect to equipment setting there were "34 individual identified discrepancies" or "34 pieces of equipment out of the 50 which had some discrepancy." (Tr.

9237.) In answering this question, Mr. French stated that it represented "34 items that were inspected in these 50 pieces of equipment." (Tr. 9240.) The Board relied on Mr. French's tes'imony in its finding 153 in the Supplemental Initial Dec sion.

BecTuse the potential for confusion exists based on~the terminology used by Mr. French, we.wish to point out that the explanation of the reinspection procedures contained

'in the August 22 letter is accurate.

- The data for equipment setting _and equipment modification refer to the number of total

" inspections" (each including one or more inspection points) and the number of discrepant " inspections" (each of which contained one or more discrepant inspection points) performed on the 50 pieces of equipment that were inspected. The state-ments made by Mr. French should be construed accordingly.

Very truly yours, Joseph Gallo One of the Attorneys for Commonwealth Edison Company JG:es enc.

cc: See Attached Service List

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C:mm:n=Calth Edison

,- o*.9 F e'S' N 8'40h81 D373 CM C8QD Ro3 8 i Aceress Rep:y tc; Pop Occe 80x 767 Crucago. ICmois 60690 August 22, 1984 4/E Mr. James G. Keppler:' .u. . ,,;

,p/ Regional Administrator +

U.S. Nuclear Regulatory Commission -

799 Roosevelt Road Glen Ellyn, Illinois 60137 Byron Generating Stations Units 1 and 2

Subject:

Bryon QC Inspector Reinspection Program I&E Inspection Report Nos. 50-454/B2-05

~

and 50-455/82-04 References (a): L.O. DelGeorge Letter to J.G. Keppler dated February 24; 198,4 (b): L.O. DelGeorge Letter to J.G. Keppler dated July 3,1984

Dear Mr. Keppler:

This letter provides clarifying information regarding come of the date presented in reference (b) regarding the results of the Byron QC inspector reinspection program.

This information is provided at the suggestion of a Region III inspector who has been involved in the detailed review of the June 1984 Supplement to the report on that reinspection program.

Chapter III of the June Supplement summarizes the results of supplemental inspections and evaluations for objective Hatfield inspection attributes. Sections III.B and III.C contain data on reinspections of equipment setting and equipment modification, respectively, which could be misinterpreted.

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' ' Relative to equipnent setting, the report states '

• A total of 778 items were inspected and 34. discrepancies were identified". The number Each of 778 refers to the number of these inspections may J. inspections performed.

consist of one or more elements. For example, the inspection of an equipment anchoring detail may consist of the objective examination of a welded holddown to assure that each of six welds is present.. An entire inspection was termed discrepant.

m . . if . any element..of ..that inspect;i.o.n. contained. a. discrep,ap,cy.. . .. .

iA':@,5'Uhl'ngYthenprevious. example:."if one' o'f Mher sixrwelds'werev $g;.,m:;f.<.' v 3, f.h j!!Mihrepanti itihe'fentire':,.inspei.on r,wese. cop'sidefedVdish Wpan, 3%i'J i

e I.

5; If two welds of..the six.were.discrepent, the entire inspection was still concidered as a single discrepancy. The total nunber of inspection elements was considerably larger than the total number of inspections (778). Similarly, the total namber of. discrepant elements was greater than the total number of discrepant inspections (34) . The results are precented in terms of inspection performed and inspections

, found discrepant because.of ,the difficulty in counting. all .. .

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.of the individual elements.;,For inspections containing..more; c. .

?:" .. than.:ene element, the number' of discrepant elements...was .nuch .

smaller than the number of inspection elements for each inspection. This representation conservatively represents the quality of the work since the ratio of discrepant elaments to elements inspected is analler than the ratio of discrepant

. inspections to the number of inspections.

Relative to equipment modification, the report states "A total of 1,850 items covering a considerably larger number of inspection points were inspected and 44 discrepancies were identified". Similar to equipment setting, the number 1,850 refers to the number of inspections that were performed. An inspection of termination locations in a particular section of a panel was considered as one inspection.

This inspection may include examination of approximately 250 terminal locations, each of which is considered an inspection point. If any of these inspection points was found to be

,_ discrepant, the inspection is considerad +o be discrepant.  !

f The 44 discrepancies stated in the report represent 44 g discrepant inspections. The number of discrepant inspection points is larger than the 44 discrepant inspections. However,

, the number of discrepant inspection points was much smaller

. than the nunber of inspection points for each inspection.

, As with eouip. ment setting, thisThe represents ratio of discrepant a' conservative inspection presentation of the results.

points to the total number of, inspection points is considerably smaller than the ratio of discrepant inspections to the

, total number of inspections. As with equipment setting, the l

l j ,,results were presented in terms of inspections rather than inspection points because of the difficulty in. determining i f the exact number of inspection points. -

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~

" .Please address further. questions.regarding.this 1 -

, matter to this office. ,

Very,truly.yours , /

j I

/

.c ,/ dyt, L.O. De1 George

' Assistant Vice-President

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