ML19320D371
| ML19320D371 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 06/06/1980 |
| From: | Peoples D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19320D363 | List: |
| References | |
| NUDOCS 8007210292 | |
| Download: ML19320D371 (6) | |
Text
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'N Commonwealth Efson
(
) one First National Pliza, Chicago, Illinois
(
7 'J AddrIss Riply to: P:st Offica Box 767 (f ' Chicago, Illinois 60690
\\
June 6, 1980 n
v Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 Jbject:
LaSalle County Station Units 1 and 2 Response to IE Inspection Report Nos. 50-373/80-20 and 50-374/80-13 NRC Docket Nos. 50-373 and 50-374
. Reference (a):
G. Florelli letter to C. Reed dated April 26, 1980
Dear Mr. Keppler:
The following is in response to the inspection conducted by Mr.
I.
T. Yin on April 1-2, 1980, at Reactor Controls, Inc., and April 3, 1980, at Earthquake Engineering Systems, Inc., of activities at the LaSalle County Station, Units 1 and 2.
Reference (a) indicated that certain activities appeared to be in non-compliance with NRC requirements.
These activities are addressed in the enclosure to this letter.
In the case of Item 3 of the Notice of Violation, it is judged after thorough review of the audit program in question that appropriate measures had already been taken which address the concerns of your staff.
Commonwealth Edison has a comprehensive system of audits of all contractors and has performed comprehensive and meaningful audits of Reactor Controls, Inc., the contractor in question.
A detailed discussion of this specific program is enclosed, and was discussed with Mr. D. Danielson of your staff on May 28, 1980.
Accordingly, it is requested that the basis for this infraction be reconsidered.
The time period for response to the subject inspection reports was extended to June 6, 1980, by Mr. D. Danielson.
Please address any additional questions you may have on these matters to this office.
Very truly yours, D. L. Peop es Director of Nuclear Licensing Enclosure JLIN 9 1980
'4376A.
800721OSAb
b Enclosure Response to Notice of Violation The items of apparent non-compliance identified in Appendix A of the NRC letter dated April 26, 1980, are responded to in the following paragraphs.
1.
10 CFR 50, Appendix B, Criterion III, states, in part, that
" Measures shall be established to assure that applicable.
design basis.
for those structures, systems, and components are correctly translated into specifications, drawings, procedures, and instructions."
Commonwealth Edison Company Topical Report CE-1-A, Quality Assurance Program for Nuclear Generating Stations", Revision 9, dated July 16, 1979, states in Section 3 that "The fundamental vehicle for design control involves multi-level review and/or evaluation of design documents by individuals or groups other than the original designer or designer's immediate supervisor whose authority and responsibility are identified and controlled by written procedures.
The design documents include, but are not limited to, system flow diagrams, design and construction specifications, load capacity data sheets, design reports, equipment specifications, process drawings."
Contrary to the above, design and acceptance criteria of CRD suspension systems had not been established for accomplishing calculations, completed calculations had not been reviewed by RCI, and design changes were not being interfaced between RCI and EES.
Corrective Action Taken and Results Achieved Deficiencies in the design control program of RCI that were noted are undergoing corrective action.
Reactor Controls will submit a request for the use of ASME Code Case 1644 to S&L.
The various design parameters that were questioned have been reviewed and approved by S&L and CECO.
Loading combinations for OBE, SSE, SRV and other transient conditions had been transmitted to RCI from S&L by cover letter and RCI had transmitted them to Earthquake Engineering System (5ES) informally.
Past and future transmittals of design informati n from S&L to RCI will be covered by Engineering Change Notice (ECN).
Transmittal of information from RCI to EES will be by Engineering Control Check List (ECCL) as outlined in RCI's Q.A. Manual.
All changes made either in the field or in San Jose will be recorded on an ECN or made by a drawing change.
These documente will be transmitted to EES on RCI's ECCL.
EES will indicate an the calculation sheets the ECNs and latest drawing revisions incorporated into the analysis.
>p.-
.o _y The cale"lations performed by EES had not been reviewed and accepted by RCI ause they were never finished.
For over 18 months,_additj loads have been pending, so the system as-builts and stress report are not complete.
RCI's Q.A. Manual requires the Project Engineer to review the stress report to see that it reflects the as-built condition of the system and meets the requirements of 4
the certified design specification.
However, the unfinished stress report was reviewed (by Mr. Hill, RCI) for correct methodology.
J Corrective Action Taken to Avoid Further Noncompliance Reactor Controls will review their scope of wor' for other possible application of ASME Code Cases.
If there are o ers, they will be submitted to S&L for review.
The use of engineering design change or transmittal documents, S&L's ECN and RCI's ECCL, will assure current design change information is available.
The follow-up action of CECO. audit #1-80-21 will be used to verify the ECN and ECCL systems are being implemented.
Date When Full Compliance Will Be Achieved Full compliance was achieved on May 30, 1980, of the program to assure control of design change information.
Final review by RCI of the stress report addressed in the inspection report will be completed after incorporation of the final load definition.
2.
10 CFR 50, Appendix B, Criterion V, states, in part, that
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings.
. and shall be accomplished in accordance with these instructions, procedures, or drawings."
Commonwealth Edison Company Topical Report CE-1-A,." Quality Assurance Program for Nuclear Generating Stations", Revision 9, dated July 16, 1979, states in Section 5 that "The. quality assurance actions carried out for design, construction, testing, and operation activities will be described in documented instructions, procedures, drawings, specifications, or checklists.
These documents will assist personnel in assuring that important activities have been performed.
These documents will also reference applicable acceptance criteria which must be satisfied to assure that the quality related activity has been properly carried out."
Contrary'to the above, procedures did not include provisions for formal revie' and approval of calculations, design information exchange, and designation of organizational authorities and responsibilities.
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Corrective Action Taken and Results Achieved Reactor Controls will use the ECCL described in their Q.A.
Manual to transmit design information and changes to EES and to document changes from EES.. SM will transmit design information either by drawing, transmittal or an ECN.
The Reactor Controls Q.A.
Manual gives the Project Engineer the responsibility for review of subcontractor calculations and control of the ECCL, and the Q.A.
Manager the responsibility to accept the document control system.
Corrective Action Taken to Avoid Further Noncompliance The system of using the ECCL and ECN is in place and being used.
This will assure the transmittal of current design information.
Responsibilities are outlined in RCI's Q.A. Manual.
Date When Full Compliance Will Be Achieved Full Compliance has been achieved.
i 3.
10 CFR 50, Appendix B, Criterion XVII'I, states, in part, that "A comprehe;.sive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program."
Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Stations", Revision 9, dated July 16, 1979, states in Section 18 that " Audits will be performed by Commonwealth Edison Company and/or its contractors, subcontractors and vendors to verify the implementation and effectiveness of quality programs under their cognizance."
Contrary to the above, the licensee's audits of RCI were not comprehensive in that the fundamental design control deficiencies disclosed above had not been identified.
Response
The Commonwealth Eaison Company Quality Assurance Department implements a comprehensive audit program to assure that suppliers, manufacturers, consultants, and architect-engineers are performing safety-related work in accordance with approved quality programs and procedures.
In regards to specific audits of Reactor Controls Inc., who 4
is performing work for LaSalle County Station per Specification J-2922, a series of audits has been conducted according to an approved schedule as required by the Commonwealth Edison Corporate Quality Assurance Program.
O I On May 23 and 24, 1977, a Commonwealth Edison audit team conducted an audit of the Reactor Controls Fabrication Shop in Waterford, Connecticut.
The audit covered organization, departmental interfaces, design document control, storage, QA records, audits, welding, procedures, weld rod control, nonconformances, welder qualification, NDE activities, and personnel qualifications, traceability of manufactured products to heats, material certification and calibration of measuring and test equipment.
Two items of non-compliance were identified and these items were satisfactorily resolved and closed out by Commonwealth Edison on June 23, 1977.
On March 26 and 27, 1979, Commonwealth Edison audited Reactor Controls Inc. Offices in San Jose, California.
Areas covered in the audit included:
reporting requirements per 10 CFR 21, organization, design document changes, vendor surveys, audits, training, processing of Hold Cards, NDE personnel qualifications, calibration, design document changes and processing of field changes for CRD Hydraulic Piping Hanger systems at LaSalle.
Two items of non-compliance were identified.
One item concerned auditing and the other item was an error in a material certification report.
Both of these items were satisfactorily resolved and closed out by Commonwealth Edison on June 18, 1979.
On January 2, 1980, the official Commonwealth Edison Company. Audit Schedule of Of f-Site Vendors was issued.
Included in the Schedule was the requirement to audit Reactor Controls, Inc. in San Jose, California, during the first quarter of 1980.
On March 25, 26, and 27, 1980, the responsible Quality Assurance Engineer at LaSalle and a cognizant Mechanical Engineer from Sargent & Lundy, conducted the scheduled audit at the RCI Office and Earthquake Engineerirg Systems (EES) Office in San Jose, California.
The purpose of the audit was to review the RCI design, design control and desir,n personnel qualifications for the Control Rod Drive piping hangers.
Four items of noncompliance were identified.
First, ECN's for the CRD hanger system were not controlled per the specified procedure; second, RCI failed to transmit to.EES all the required current engineering document; third, appropriate documented quality standards were not specified in the design calculations done by EES; and fourth, RCI could not produce documentary evidence to show that the computer program used by EES for design analysis was properly validated.
In regards to the specific details outlined in the NRC non-compliance (373/80-20-06; 374/80-13-06), RCI does not submit any equipment drawings relative to the CRD system to S&L.
Construction
- drawings of the hanger location and details are the only drawings submitted to S&L.
Per form 275-C para. 3.7.1 of the S&L Specification J-2922, S&L does not necessarily have to check the RCI design and details given on the construction drawings.
However, per j
form 350-B, para 3.5, SeL is required to review and accept the final j
as-built drawings, test results, and analytical calculations (RCI 9
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will meet the seismic requirements of form 350-B by analytical calculations).
The present status is that the as-built drawings and final calculations are incomplete.
Consequently, the final review of this requirement by CECO audits is not possible at this time.
On the other hand, the preliminary design criteria and calculations review is a requirement of the RCI audit program.
Presently, a CECO scheduled RCI audit of EES will be conducted on or before June 4, 1980, in which the design criteria and calculations will be covered.
In addition, CECO Audit 1-80-21 of RCI San Jose Office will not be closed until Edison verifies by sufficient follow-up action that RCI has assured that acceptable design criteria and calculations have been implemented in the CRD suspension design.
Furthermore, Commonwealth Edison Site Q.A. has performed 20 formal audits of RCI at LaSalle Station during the period November, 1976, through April, 1980.
Items of non-compliance identified in these audits have been resolved or are actively being pursued to resolution by CECO Q.A.
Based on the facts delineated above, we request that this item of infraction be reconsidered.
Although it is acknowledged that the scope of our March 24, 1980, audit was modified to accommodate informal comments by the Region III inspector (Mr. Yin),
it has always been and will continue to be our practice to respond to meaningful guidance from the NRC.
In this specific case, the issues for which we have been cited were identified by Commonwealth Edison prior to the NRC audit of RCI.
The fact that the same findings were made by the NRC does not of itself justify this citation.
1 As has been indicated, Commonwealth Edison has and will continue to reflect meaningful comments from all Region III inspectors in our QA audit plans.
In addition, a program has been implemented under which inspection reports for plants in Region III including but not limited to Commonwealth Edison facilities are reviewed to identify appropriate issues to be addressed in both on-site and off-site audits conducted by Commonwealth Edison.
It is judged that this continuing program, which will affect the audit plans-for all Edison facilities, addresses the underlying concern expressed in this item of infraction.
Further corrective action at this point in time is judged to be unnecessary.
We would be happy to discuss with the Region III staff the basis upon which future audit plans will be developed, to provide you with adequate assurance that our program continues to be effective, and to eliminate citations of this type in the future.
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