ML19319B569
| ML19319B569 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 03/26/1975 |
| From: | Roe L TOLEDO EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19319B553 | List: |
| References | |
| NUDOCS 8001270096 | |
| Download: ML19319B569 (6) | |
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TOLEDO EDISON March 26, 1975 LOWELL E. ROE v.c. p m.a.nt
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Docket No. 50-346 I4191 259-5242 Mr. James G. Keppler Regional Director - Region III Directorate of Regulatory Operations Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
Toledo Edison acknowledges receipt of your February 19, 1975 letter and report enclosure referencing apparent noncompliance with NRC requirements, listed as " Infractions," under the heading, " Enforcement Action." The items resulted from a site inspection conducted by your office on January 22-24, 1975 and the subsequent NRC exit interview held at the
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Edison Plaza.
Your letter expresses concern regarding Toledo Edison's system for management control of NRC licensed activities.
Since the NRC-Region III site inspection, Toledo Edison has instituted both internal arl external actions to further reinforce and assure a more effective QA/QC management system of controls over safety related items and activities.
The ongoing Toledo Edison actions include, but are not limited to the following:
1.
QC engineers will be utilized to perform day-to-day surveillance of site contractor quality activities, commencing April 28, 1975.
2.
Positive independence exists for agent QC and QA activities as related to project management groups.
3.
Toledo Edison has hired one additional QA engineer, starting employment on March 31, 1975. Toledo Edison will hire another QA engineer by June 1, 1975.
4.
The review of identified safety related items (Q-list) will be completed by May 1, 1975.
5.
Increased Toledo Edison QA audits of site contractor and agent safety related activities commenced in January, 1975.
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6.[ The recently revised Toledo Edison Nuclear Quality Assurance Manual is in effect with clear applicability as to Davis-Besse Unit #1.
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i 8 0 01 MN THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. OHIO 43652
., March 26, 1975
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J Following a thorough examination of the items of concern, Toledo Edison herein of fers information regarding the apparent noncompliances, including corrective actions and steps taken to avoid further repetition, as well as the dates for compliance.
t INFRACTIONS Item A Installation / fabrication olanners had not been procerly approved Criterion VI Johnson Service Co. (JSC) Procedure #QAS-615 is currently being revised to identify those personnel authorized to sign for quality af fecting documents, such as, installation / fabrication (I/F) planners.
JSC has issued letters informing their personnel of these responsibilities.
TECo/Bechtel-approved JSC procedures will be complete by April 1,1975.
The Bechtel Construction Manager (BCM) will provide a Field Engineering Instruction (FEI), which will include instructions for reviewing and approval of JSC I/F planner packages.
The FEI will be complete April 1, 1975.
Item A-2a - Fabrication and installation of mountine structures for safety related instrumentation, without the benefit of aporoved inspection orocedures and instructions - Criterion V.
Measures have been taken by JSC to provide procedures and inspection instructions for the fabrication of mounting structures for safety related instrumentation.
All I/F planners are written to include any Q-listed instrument stands in the system. Previous I/F planner forms have been revised and reflect all necessary
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requirements.
BCM will provide an FEI for processing the review and approval of the I/F planners by April 1,1975 as listed in Item A-1, above.
Item A-2-b - Improper storage of safety related pioine components - Criterion V Corrective steps are completed for ITT Grinnell to control the stcrage of safety related material by the issuance of ITT Grinnell instructions further I
amplifying the specification regarding on-site storage of components and
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material.
ITT Grinnell held documented meetings with their on-site craft supervisors reemphasizing the instructional requirements for proper storage l
protection.
A required ITT Grinnell Field Specification Supplement revision will include storage requirements explicitly spelled out, before its resubmission for the required TECo/Bechtel approvals, anticipated to be complete by April 18, 1975.
BCM continues to perform surveillance of this activity as required by the D-B Field Inspection Manual (FIM) Procedure G-3.
The documented results of this surveillance / inspection activity appear on appropriate BCM Field Inspection Reports.
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March 26, 1975 pb Item A-2-c - Procedures or instructions to be initiated for recortine total weight of zinc coating per 7749-M-328, Section 5.6 - Criterion V JSC has prepared a Log Sheet on which their responsible engineers will record the footage and type of zine-coated material for raceways and supporting materials including all stands used in the containment vessel.
This information will be reported to the BCM for forwarding to the Bechtel nuclear engineer.
BCM commenced on March 20, 1975 performing inspection / surveillance in accordance with D-B FIM, Procedure G-8, verifying proper log entries and Log Sheet usage.
Item A-2-d - Approved procedures were not followed relative to documentation and identification of eauiument known to be incorrectly installed - Criterion V Inadequate and informal BCM communications and QC surveillance resulted first in mislocation of two service water pumps and secondly, also caused the lack of compliance with approved procedures to document nonconforming items.
Corrective action is presently underway to clear the following items:
1.
Fischbach and Moore (FOI) initially documented the pump interchange, to the BCM on a 10-21-74 memorandum, followed by a 1-22-75 FMI NCR #B-094.
2.
The pump interchange was reported on a 1-20-75 Bechtel Project Quality Assurance log entry.
3.
ITT Grinnell issued a 1-30-75 Deviation Report #F-218 regarding pump interchange.
4.
On 2/11/75 BCM issued their NCR #642 and placed QC hold tags.
The pump specification and physical design clearly indicates the two pumps are functionally interchangeable.
The disposition to re-mark the equipment number only on the name plates to coincide with the related design drawings and appropriate QA/QC documentation, was approved by the Project Engineers.
BCM and QA/QC personnel will assure by proper compliance with existing procedures that other installation activities involving safety related equipment is in accordance with the latest approved design / erection drawings and specifications.
Increased emphasis on:the need for adequate, positive, formal communication between the BCM, contractors, and QC/QA will provide for proper surveillance /
Q inspection by QA/QC.
This is being implemented to prevent recurrence and strengthen the oy m il QA/QC activities.
March 26, 1975 Item A Mounting structures for safety related instrumentation were being installed prior to the receipt of material certifications - Criterion VII Measures have been established to assure all JSC purchase orders currently being processed will identify Q-listed materials requiring a Certificate of Compliance.
All Q-listed material without a Certificate of Compliance are presently segregated and tagged, in accordance with the JSC nonconformance procedure.
BCM will perform inspection / surveillance and document both BCM's end JSC's activities in accordance with the D-B FIM Procedure G-8, te assure JSC compliance.
Fabrication and installation of these items are currently under a stop work order.
Item A Installation inspection documents for safety related instrumentation were stamped indicatina installation correct and co=olete.
The installation was found incomplete - Criterion XIV JSC scheduled and held Quality Assurance / Quality Control orientation
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sessions with their inspectors and QC personnel based on the JSC QA Manual.
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JSC indoctrination and familiarization sessions were conducted and documented by the JSC Director of Quality Assurance.
Emphasis was placed on the impor-tance of accuracy and timeliness of written verification of inspection activi-ties or QC hold points. JSC Procedure #QAS 615 is being revised to further define the JSC In-Process Inspector (IPI) responsibilities and duties.
Item A Establish measures that tools used in activities affectine cuality are properly controlled.
JSC revised their tool issuance control procedures to maintain more positive control.
All JSC Q-lic.ed wire termination crimping tools are calibrated and issue-controlled for use.
BCM continues to verify JSC compliance to the JSC procedure in accordance with the D-B FIM Procedure G-8 and documented on Field Inspection Reports.
Item A Mounting structures for safety related instrumentation were not properly stored or identified.
JSC provided written instructions to their craftsmen requiring protection of l
open ends of tubing and instrument components when not in the process of fabrication.
JSC In-Process Inspectors are required and have been instructed to check for proper sealed tubing ends and instrument connections.
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JSC signs will be made and displayed in the work areas to emphasize this t
protection requirement.
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March 26, 1975 O
Item A-6 continued JSC corrective steps have been taken to prevent Q-listed instrument mountings and stands from being stored directly on the ground.
Grading and dunnage has been provided for storage areas.
Presently stored material has been tagged and will be maintained in accordance with the JSC Material Control Procedure.
Revision of Specification M-329 is being made to reflect proper storage re-quirements. Date of full compliance will be April 1, 1975.
BQi and QA will inspect and monitor JSC compliance to the above requirements.
This compliance verification will be documented on the Bechtel FIR's, QC Monthly Storage Report and QA audits.
Item A Timelv issuance of Stoo Work Order Since the inception of the Davis-Eesse project and site activities, Toledo Edison has granted stop work authority to QA, QC, and BQ1.
Bechtel QA alerted the 301 of JSC QA/QC noncompliances following a Bechtel QA systems audit of JSC, performed in November and December, 1974 No actual Q-listed work was underway during these Bechtel QA system audits.
Numerous Bechtel QA Audit Finding Reports resulted from their QA systems audit and p
still remained open at the time of the NRC site inspection in January, 1975.
JSC commenced Q-list work in mid-January, 1975.
BCM's failure of timely response for implementing corrective action required by the Bechtel QA Audit Finding Reports prior to actual start of Q-list work at JSC was contrary to Toledo Edison's authority granted to BC1 for the prevention cf the contractor's work to proceed when it is evident that it is not in compliance with contract documents.
Proper evaluation of the real significance of the JSC nonco=pliances coincide with the time of the NRC site inspection, which then resulted in the present stop work order which is still in existence, except for electrical terminations only.
In addition to those Toledo Edison actions outlined on page one of this letter, additional corrective action has been instituted to prevent recurrence of untimely stop work action, as follows:
Toledo Edison and Bechtel QA management has initiated a weekly joint TECo/Bechtel QA/QC/BC1 meeting, including when necessary, a representative of the contractor's quality organization.
The purpose of these meetings is as follows:
Satisfactorily resolve quality findings, such as AFR's, MCAR's, a.
NCR's, or other QA/QC documentation that needs timely responses.
b.
Identify additional quality problems or trends.that could lead
,to more significant conditions.
c.
Establish coordinated communication system between all those who have key responsibilities in implementing their respective QA/QC programs.
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J March 26, 1975 l
i The Toledo Edison quality assurance activity has closly monitored and l
participated in all items involved within this response letter.
If you have any questions concerning our reply or desire further discussion j
on these matters, we will be glad to meet with you at your convenience.
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Yours very truly, i
Lowell E. Roe Vice President Facilities Development I
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