ML20153E160

Responds to NRC Re Noncompliance Noted in Insp Repts 50-456/85-21 & 50-457/85-22.Licensee Disagrees W/Part a of Violation Since No Programmatic Violation Occurred

ML20153E160
Person / Time
Site:	Braidwood
Issue date:	12/04/1985
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20153E154	List: ML20153E151 ML20153E160
References
0961K, 961K, NUDOCS 8602240426
Download: ML20153E160 (6)

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'[D Commonwealth Edison .

'[ ) One First National Ptria. Chic:go. littnoo 3 O 7 Address Reply to: Post Ottice Box 767 I

-(j Chicago, lilinois 60690.

, . December 4, 1985 Mr.. James G. Keppler Regional Administrator Region III U. S. Nuclear Regulatory Commission 799 Roo'sevelt Road Glen Ellyn, Il 60137 i

SUBJECT:

Braidwood Station Units 1 and 2 ~

Response to Inspection Reports Nos.

50-456/85-021 and 50-457/85-022 NRC Docket Nos. 50-456 and 50-457

REFERENCE:

(a) J.J. Harrison Letter to C. Reed dated November 4, 1985

Dear Mr. Keppler:

4 This letter is in response to the inspection conducted by Messrs. J. Neisler and R. Mendez on April 30 through September 5, 1985, of activities at Braidwood Station. Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements. Commonwealth Edison does not agree that Part a of Violation is an example of violation, in that no programmatic violation occurred. Our basis for this and the Commonwealth Edison Company response to the Notice of Vic1ation is provided in the enclosure.

If you have any forther questions on this matter, please

! direct them to this office.

i Very~truly yours, l

l hYnf g D. L. Farrar e

Director of. Nuclear Licensing a Enclosure cc: NRC Resident Inspector -

Braidwood 0961K i

DEC 5 1985 8 ~

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COISIONNEALTH EDISON COMPANY RESPONSE TO INSPECTION REPORT 456/85-021; 457/85-022- ,

Violation-(456/85-021-01: 457/85-022-01) .

1. .10 CFR Part 50,' Appendix B, Criterion V, as implemented by the Ceco Quality Assurance Manual, Quality Requirement Section 5 requires that Quality Assurance carried out for construction activities be described by instructions and procedures.

Commonwealth Edison -in its Quality Assurance Manual, Section 10 and L.K. Comstock in its Procedure 4.1.3,

" Qualification Classification and Training of QC ,

Personnel",-commit to ANSI N45.2.6-1978. ANSI ~ ,

N45.2.6-1978,- Paragraph'4, states, in part,. " Personnel i who are assigned the responsibilityLand authority to j perform functions covered by this Standard shall have, as a minimum the level of capability shown.in Table 1." Table 1 requires that evaluating the validity and acceptability of inspection, examination and testing results be at least a Level II. L.K. Comstock-(LKC)

Procedure 4.1.2, Revision B, Paragraph 3.30, " Position Delineation," states, in part, " Quality Control Lead Inspectors...must be certified Level II in designated areas...." LKC's " Master Qualification List by Discipline for Level II Inspectors," classifies 11 3 functional areas for Level II' capability,' two o'f-which are calibration and concrete expansion-anchors](CEAs). '

Contrary to the above, the following instances of, failure to qualify personnel in accordance with '

procedures were identified:

a. On May-25, 1984, a LKC QC inspector signed the Level II review column on two-LKC inspection checklists, form 23A, " Variable' Instrument ,

Calibration," for torque wrenches A-531 and l A-828, although the inspactor was not:a certified Level II inspector in calibration.

b. From August 1984 to March 1985Lthe same QC inspector identified above was designated by LKC to be a Quality Control Lead Inspector in calibration and CEAs, although the inspector had no certification in those areas.

c. From March 1985 to May 1985 a second QC inspector was designated-lead in calibration but was not certified as a' Level II in that-area.

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Response

1.a The form 23A's for torque wrench A-531 and A-828 show that calibrations were performed on May 21, 1984 and May 23, 1984 respectively. The QC inspector performing these calibrations was originally certified ,

as a Level II in calibration on May 25, 1983. _The L.K. Comstock (LKC) QC program requires a review of all completed inspection checklists. For both of these checklists, the review was performed by another Level II inspector on May 25, 1984.

Prior to September 1984, the LKC program required the reviewer only to be a certified Level II. That is, the reviewer could be certified in any inspection area, not necessarily in the one in which the inspection was performed. Under the LKC program, when a Level II inspector reviews documentation of another '

Level II, the review is for format and completeness.

In September 1984, the requirement that the reviewer also be certified in the inspection area of the inspection was added to the LKC program.

At the time of the May 25, 1984 review, the second QC inspector was certified Level II in receiving.

Therefore, no programmatic violation occurred. This part of the violation is not an example of failure to use certified personnel performing inspections.

Commonwealth Edison requests that this part of the violation be withdrawn.

1.b/1.c L.K. Comstock procedure 4.1.2 requires that QC Inspectors ' e ' certified in the areas for which they are designated as Lead Inspector. Items lb and Ic are two cases where this procedure requirement was not adhered to. Review of these violations indicates that while the reasons for each is unique, they are both administrative problems. The performance of QC inspections would not be affected by these violations.

Actions Taken and Results Achieved 1.b/1.c L.K. Comstock issued NCR 4527 to address these violations. In addition, L.K. Comstock QC Manager performed a review of past/present Lead Inspectors and their respective area (s)/ certification (s). No additional violations were identified. Based'on this review, NCR 4527 is expected to be dispositioned with no additional actions required.

Action Taken to Prevent Further Violation 1.b/1.c The QC Manager assigns Lead Inspectors. The_QC.

Manager who made the initial Lead Inspector assignements.also performed the above identified review of assigned area (s)/certificiation(s) for past/present Lead Inspectors. Therefore, no additional training is required.

Date of Full Compliance L.K. Comstock NCR 4527 is expected to be dispositioned complete by January, 1986.

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'ViolaElon1456/85-021-04: 457/85-022-04) ,

2. 10-CFR Partl50,-Appendix ~B, Criterion XVII, as

-implemented'by the CECO' Quality Assurance Manual ~,.

. Quality Requirement.Section 17: requires that records be retained and maintained to furnish evidence of

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4 activities affecting quality..

ContraryLto the above, the licensee could not provide documented evidence that welds rejected by Pittsburg Testing Laboratory (PTL) on. hangers CC-23,.CC-36, CC-87 and CC-34 were reworked, repaired, used-as-is, or reinspected.

i l Response i

Commonwealth Edison agrees that documentat4on did not exist

, showing the identified hangers rework, repair or reinspection.

l &clions Taken and Results Achieved i

2. On November 12, 1980, L.K. Comstock (LKC) submitted weld request #111280A to Pittsburg-Testing Laboratory. "

for over-inspection.- PTL-performed-the weld over-inspections and issued Report #761VW dated November 19, 1980. ' '-

The PTL Report identified 16 weld discrepancies on 10 hangers. At the time of the NRC inspection,' the status of these hangers were:

1) 5 hangers - needed rework / reinspection but was y not performed.

2) 2 hangers - have been deleted.

3) 3 hangers - have been rework and reinspected.

i LKC has issued Inspection-Correction Reports'(ICR) 11,777 through 11,781 to repair the welds <nt the above  :

5 hangers. Upon completion, the repaired welds will- I be submitted to PTL for reinspection. l c

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Action Tat;en to Prevent Further Violation'-

.PTL-currently tracks-their'open' inspecti on on the PTL Non-Conforming-Inspection Reports-List. PTL has-performed a

-review to identify additional reports not currently identified on the PTL Non-Conforming Inspection Reports List and is'- -

currently updating _this-: list.

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This list has been issued to appropriate site contractors to. '

track close-out of'the open reports.

s Date of Full Compliance Closure of'ICR's 11,777 through 11,781 and submittal of the welds to PTL for reinspection is expected by February, 1986.

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