ML19260C525

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Responds to NRC 791025 Ltr Re Violations Noted in IE Insp Repts 50-454/79-14 & 50-455/79-14.Corrective Actions:Util & Contractor Personnel Performing Insp & Testing Activities Being Evaluated as to Qualifications
ML19260C525
Person / Time
Site: Byron  Constellation icon.png
Issue date: 11/26/1979
From: Peoples D
COMMONWEALTH EDISON CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19260C520 List:
References
NUDOCS 8001070342
Download: ML19260C525 (4)


Text

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Commonwealth Edison

, One First National Plaza. Chicago. Illinois Address Reply to: Post Offica Box 767 Chicago, Illinois 60690 November 26, 1979 Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - Region 111 U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Subject:

Byron Station Units 1 and 2 Response to IE inspection Report Nos. 50-454/79-14 and 50-455/79-14 NRC Docket Nos. 50-454 and 50-455 Reference (a): October 25, 1979 letter from G. Fiore111 to Cordell Reed transmitting IE Inspection Report Nos. 50-454/79-14 and 50-455/79-14

Dear fir. Keppler:

Reference (a) transmitted an inspection report regarding an inspection conducted on September 11-28, 1979 by Messrs. J. E. Konklin, G. F. Maxwell and J. F. Suermann of your office of activities at Byron Station. That report identified two apparent items of noncompliance with NRC requirements. Attachment A to this letter contains Commonwealth Edison Company's response to these items.

Please address any additional questions that you might have to this office.

Very truly yours, N# D. L. Peoples Director of Nuclear Licensing WFN:mae attachment

)h94 ]9)

NOV 271878 8001070b

. Commonwealth Edison NRC Docket Nos. 50-454/455 ATTACHMENT A ITEM 1 - INFRACTION 10 CFR 50, Appendix B, Criterion V, states, in part, that

" Activities affecting quality shall be prescribed by documented in-structions, procedures, or drawings ... and shall be accomplished in accordance with these instructions, procedures, or drawings." Byron Topical Report CE-1-A and the Connonwealth Edison quality Assurance Manual, Quality Requirement QR No. 2.0, commit Commonwealth Edison to the requirements of Regulatory Guide 1.58/ ANSI N45.2.6.

Contrary to the above, on September 11-28, 1973, the inspectors observed the following:

a. Commonwealth Edison Station Construction field engineers who performed material receipt inspec-tions were not certified in accordance with the requirements of' ANSI N45.2.6 for inspection personnel.
b. The procedures for Hunter Corporation, Blount Brothers Corporation and Hatfleid Electric Corporation were found to contain inadequate require-ments for the qualification and certification of Inspection personnel in accordance with ANSI N45.2.6.
c. The Hatfield Electric Corporation personnel qualifica-tion files did not provide adequate documentation and Justification in accordance with ANSI N45.2.6 for the certifications of QA inspection personnel.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Commonwealth Edison Company Station Construction Department and contractor personnel performing examination, inspection and testing activities are being evaluated against the requirements of ANSI N45.2.6, 1978 to verify that these activities are being accomplished by qualified in-dividuals. On June 29, 1979 all Station Construction Department field engineers assigned to the Byron site attended a training session devoted to material receipt inspections. Attendance at this activity was documented.

All Hunter, Blount Brothers and Hatfield Electric personnel performing examination, inspection, and testing activities are also receiving a performance evaluation to Ossure that th'ey possess the proficiency and knowledge necessary to perform these functions. Any unsatisfactory evaluations will be brought to the attention of the contractor and Commonwealth Edison management. As of November 20, 1979, eight of nine Hunter Corporation, all Blount Brothers Corporation and five of six Hatfleid Electric Corporation inspection personnel have received field evaluations by Commonwealth Edison. All have demonstrated satisfactory proficiency in the performance of their duties.

1694 I94

Commonwealih Edison NRC Docket Nos. 50-454/455 t

The site contractors' procedures for qualification and certification of inspection personnel are being reviewed by Commonwealth Edison against the requirements of ANSI N45.2.6-1978. Deficiencies are being identified and the appropriate contractors are being directed to revise these procedures accord i r.g l y . Particular emphasis is being given to documenting the basis for certification, especially in cases where the candidate for certification does not appear to meet the education and experience requirements. Training programs utilized to qualify individuals will also be specified in greater de-tall, including quantitative criteria for qualification.

The certifications of all site contractor personnel performing examination, inspection, and testing activities are being reviewed by Commonwealth Edison to verify that these certifications adequately document the individual's qualifications and the basis for certification. Contractors are being directed to correct any deficiencies discovered during this review.

As of November 20, 1979, six of nine Hunter Corporation, six of nine Blount Brothers Corporation and all six Hatfield Electric Corporation inspection personnel certifications have been reviewed by Commonwaalth Edison.

CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE The Station Construction Department is deweloping a procedure for certification of personnel engaged in examination, inspection and testing activities. This certification procedure meet's the requirements of ANSI N45.2.6-1978.

Contractor procedures for qualification and certification of personnel engaged in examination, inspection and testing activities will be evaluated by Commonwealth Edison for compilance with ANSI N45.2.6 during the procedure review process. Any deficiencies will be corrected prior to site approval.

The certifications of all contractor personnel engaged in examination, inspection and testing activities will be reviewed by Commonwealth Edison within one month of the individual's certification.

The indididual's performance will also be evaluated during this period.

All contractor inspection personnel will receive a periodic performance evaluation by Commonwealth Edison.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED January 15, 1980 1694 195

Commonwealth Edison NRC Docket Nos. 50-454/455 3_

ITEM 2 - DEFICIENCY 10 CFR 50, Appendix B, Criterion VI, states, in part, that " Measures shall be established to control the issuance of documents ... Including the changes thereto, which prescribe all activities affecting quality. These measures shall aroure that documents, including changes, are reviewed ...

and approved ... by authorized personnel and are distributed to and used at the location where the prescribed activity is performed."

Contrary to the above, on September 11-28, 1979, the inspectors observed that:

a. Fourteen CECO. surveillance check sheets involving calibration of instruments used by Hunter Corporation, and eleven surveillance check sheets involving cor. crete and grout pour preparation by Blount Brothers Corporation were not properly reviewed and approved by CECO. QA, as required by CECO. Quality Procedure QP No. 18-2.
b. Three Field Change Requests, FCRs 605, 775 and 780 involving Hunter Corporation activities, were not properly logged and coordinated by CECO. Station Construction, as required by CECO. Quality Procedure QP No. 3-2.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED

a. All CECO. surveillance check sheets have been properly reviewed an'd approved by Ceco. QA.
b. The FCR Log is presently undergoing review by the Station Construction Department to determine the current status and the accuracy of the information available. The log status of FCRs 605, 775 and 780 have been corrected.

CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE

a. CECO. QA will periodically monitor the status of the surveillance check sheets to assure that the proper review and required approval has been attained.
b. The FCR Log wi11 be reviewed monthly by the Station Construction Departmeat management personnel to determine which additional information is required to maintain the current status of the FCR Log.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED November 30, 1979 1694 196

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