ML19250E118
| ML19250E118 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 03/09/1981 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Ahearne J, Gilinsky V, Hendrie J NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8103190819 | |
| Download: ML19250E118 (5) | |
Text
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MEMORANDUM FOR:
Chairman Hendrie l1m t
Commissioner Gilinsky M
b ^u [ N ' ]9 WW Commissioner Bradford Commissioner Ahearne k.
William J. Dircks, Executive Director for Operati%nC.:: '[
FROM:
SUBJECT:
BYRON STATION UNITS 1 AND 2 QUALITY ASSURANCE PROGRAM (SECY 31-56)
On November 21, 1980, the Rockford League of Women Voters filed a request pursuant to 10 CFR 2.206 and 2.202 (petition) seeking that the Director, Office of NRR, take certair actions with respect to the Byron Nuclear Power Station.
On December 22, 1980, the Director partially denied that portion of the petition seeking an immediate halt to construction.
The Commission, during its review under 10 CFR 2.206 of this partial denial by the Director, determined that the Director had failed to set forth his evaluation of one of the claims in the petition.
The claim not addressed was that the Quality Assurance / Quality Control (QA/QC) program at Byron is not being effectively implemented.
The Commission also noted the recent issuance by the Director, Region III, of an Immediate Action Letter confirming suspension of work on electrical cable installation.
The Commission directed that the staff provide "its reasoned evaluation of the petitioner's allegations" on the effectiveness of the licensee's QA/QC program at Byron.
Attached is an assessment by Region III of the status and effective-ness of the QA/QC program currently in effect at the Byron site.
In summary, the assessment states that from mid-1979 to date, the Byron QA/QC program generally nds been effective, and that the recent Immediate Action Letter represents a specific action with respect to a limited scope of work (electrical cable and cable support installation) by a single contractor.
The limited scope of the problem makes limited stop-work the most appropriate technique to achieve corrective action.
In the opinion of the staff, there is no necessity for and no value to a total suspension of work at the Byron site.
It should be noted that the licensee has already met its commitments under the Immediate Action Letter, and that constraint has now been lifted.
The staff has also examined the affidavit accompanying the League's petition which claimed that the Byron QA/QC program was not effective.
Section 2 of the evaluation addrerses the affidavit.
In the staff's judgmtnt, the infor-mation presented does not support the allegation made.
CONTACT:
E.B. Blackwood, IE 49-28180 A
8103190819
The Commission In summary, the various individual violations referred to in the affidavit represent relatively minor offenses against a QA/QC program which is basically sound.
The situation addressed in the Immediate Action Letter dated January 13, 1981 does represent a brealJown in the QA/QC program fo; a single construction contractor and the associated inspection contractor.
This can and should be addressed specifically without requiring suspension of unrelated work, and a halt to all construction at the site is not called for under the criteria set forth in the Interim Enforcement Policy (Section IV.C.2).
Although the Immediate Action Letter constraint has now been lifted, further enforcement action is being considered by the staff consistent with the Interim Enforcement Policy, to emphasize to the licensee the need to take lasting corrective action.
i.,
William J. Dircks Executive Director for Operations
Enclosure:
Evaluation of Byron Nuclear Power Station OA/QC Program cc:
OGC OPE SECY Commission Staff Officers Director, Nuclear Reactor Regulation Executive Legal Director Public Document Room Chief, Docketing & Service Branch (SECY) (S 81 -56)
Distribution:
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Stello, IE IE Reading R. C. DeYoung, IE IE Files J. H. Sniezek, IE Central Files E. B. Blackwood, IE DRRRI Reading J. B. Henderson, IE PPS Reading W. J. Dircks, EDD
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Enclos re EVALUATION OF StRCN NUCLEAP FCWER STATICN CA/CC PROGRAM 1.
Past and Current Performance a.
The Licensee's Quality Assu"ance Program was assetsea in a Region III mid-term QA intpection of Byron in late 1979.
This involved a thorough evaluation of the QA Program in the areas of site quality assurance, including auditing, trendir.g, surTeillance activities, and the control of nonconformances; corporate quality assurance, including auditing, trending, and interfaces; design and cesign change control; procurement, including procecures, purchasirg, cod auditing of suppliers; and control of purchased materials, includirg procedures, receipt inspection, storage and maintenance; and sur-veillance of site contractcrs.
Thot evaluation did r.ot produce an3 evidence of a breakdoon of the QA Program in the above areas.
b.
The Licensee's overall regulatory performance was recently revie ed in the Systematic Assessment of Licensee Performa..ce (SALP) appraisal (mid-1979 - mid-1950).
The assessment included a re,iew cf the Byron QA/QC program implecentation.
While sore deficiencies hase been identified with QA/QC, the number and nature of these problems were not viewed to be significant from a regulatory standpoint.
- 7. n this regard, it should be noted that the number of ncnccepliances at Eyron were fewer than at rost construction projects.ithin Region III.
Furthermore, those deficiencies that have been identified were, for the most part, isolated deficiencies and not symptcmatic of a broar prcblem c.
In addition to the above, the Quality Assurance Prograc is contin-ually assessed during the performance of the constructica inspectic, program.
Occasionally during such inspections, quality assurance problems in limited areas ave found which are not indicitive of an overall Quality Assurance Program breakdoon, but are irportant enough to cause issuance of a stop work order in the rea(s) involved.
Although these cases are vides'rable, thc., Jo not represent a breakdown in the overall Quality Asst ance Program.
A recent example of such a case involved electrical work at Byron.
Inspection indicated a problem with the QA/QC program in the electrical area.
'ne concludcd that it was necessary to stop work in this area, reexamine work perforred to date, correct identified problems, and upgrade the QA/QC program for this work.
We discu: sed The our concerns with the licensee, Cor.nonwealth Edison Company.
licensee agreed to suspend safety-related electrical work pending resolution of the problems.
This agreement was confirmed by Region III's Immediate Action Letter.
Mcre examples of this kind may occur before construction at Byren is ccnplete; appropriate action -ill be taken.
e 2.
C:mments cn CA/CC Corcerrs Ccriaire: in the League c' acrer Vcte* s Fetitien 01 Neverter 21. 19:0 a.
The affidavit attached to the League's petition notes at ?.
6' trat IE inspettors expressed concern o.er " excessive re.ork" at Eyr:n ir mic-1950.
It sh ula be noted inat extensive re.or( in itself 1s n:t a citable offense, as icng as effectise c;ntrol of the re ora is maintainec by tne
- ensee.
Region III's cor: err was trat esters;.e rework increases tre cifficulty of maintainirg effective : ntrcl of the construction activities.
Tne in -cepth evaluaticn perfor ed cy Commen ealin Ecisen in resocnse to the Regien III insce: tion fi cings n
indicates that the extensive rework nas not resulted in (cr frc:) a breakcc.n in the site QA Program b.
Unresclved items are referred to as "prcoleT areas" at p.
62 of t"e subject affidavit.
The staff does not necessarily consider ther as such.
Unresolved items are matters atout anich Ore informatics ic requirec to determire whether tney have possible safety iralicatiers or are acceptable.
In the case of Byron, unresciwed iters nave tee-pursued by the staf' and none of the iters, eitner singularly cr collectively, would ' arrant an order to stcp all ork at the Syrcn site.
c.
Tne affidavit states at p. 62 that "inade;uate welcing has teen a continuing proble " and refers to seven IE inspection reports during the August 1978 to June 1930 time period.
Our revies snows inat three of the seven reports do not contain non cr liances related to welding, and that the other four reports contain a total of five noncompliances and one deviation which are welcing-related.
The fivs noncompliances involved procedure and record ciscreparcies, and the deviation involved an interpretation of A5ME Code requirerents regarding prccecure qualification.
No evidence of actual inaceouste welding was noted.
In vie. of the nutter and nature of tne -eicing-related noncompliances cited, we do not consider that welding has been a significant prcolem at Byron.
d.
The affidavit decurent refers at p. 62 to a May 1979 IE inspection report which cited as a " recurrent item" the inadecuate protection of "important equipment..wnich has caused damage to e;uiprent."
Neither the non:cepliance cited in May 1979, nor the previcus non-ccmpliance in April 1979 which made the sec.onc one a " recurrent item," involved actual carage to equipment, but ratner the oossi-bility of damage if the conditions were not corrected.
Ecth ncn-compliances.ere closed cut in subsequent IE inspection reports baoes on corrective actions taken by the licensee ard the site conn r
'v-d.
A later IE inspection at Byron in March 1950 (Reference 211 of the af fidavit) did find installed mecnanical snutber asse:Dlies wni:n had been caraged because of inade uate protecticn.
The licensee at
3-that time removed the damaged snuDrers, voluntarily Stcpped the installation of safety-related snubber assemblies, and agreed to not reinitiate installation until the construction environment is such that the snubber assemblies can be adequately protected.
In view of the small number of noncompliances cited in this area, and the licensee's positive and prompt corrective actions, the staff does not consider that storage, cleaning and preservation of equiprent has been a significant problem at Byron.
In conclusion, the information provided in the affidavit accompanying the League's petition presents nothina new.
The staff is closely monitoring the construction activities at the Byron site and continues to be of the view that a halt in construction is not warranted.
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The Coarission has decided not to issw a formal order directing further staff action.
This remorandum, which will be served on the parties and placed in the I'uhlic Docuront Rocm, au being issued in lieu thereof.
2.
The.netiticner cuestioned the adec.uacy of the licensee's CA/OC progrc-at Syron.
In this regard, the Commission notes that the staff recently forwarded an immediate action letter (dated Januar.v 12r 1982) to Ccr=onwealth Edison rec:uiring a suspension of electrical cable i n s '. l ' a t i c n p.? n d i n e-comp'o+4cn of specific installation
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As a result, tne Con.ission is unable to dete=ine whether, as to the Byron OA/OC
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' c c o r d i n c. i.v., the staff is directed to provide the Carrission its reasoned evaluation of the petitioner's a 1e p tiens concernine. the c.uality. of the E.vron CA/OC program.
3.
Ur.ca recei.ot of the additional information fro.m the staffo the Cornission will determine whether Corrission review is warranted.
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