ML19338F267
| ML19338F267 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Byron, Braidwood, Vermont Yankee, Quad Cities, Zion  |
| Issue date: | 10/25/1973 |
| From: | Reinmuth G US ATOMIC ENERGY COMMISSION (AEC) |
| To: | Vetter W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19338F268 | List: |
| References | |
| NUDOCS 8010140664 | |
| Download: ML19338F267 (23) | |
Text
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OCT 2 5 h
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-]'/ h Ed W. Vetter, Chief Reactor Construction Branch, RO:III
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C01EONWEALT3 EDISON COMPANY - DRESDEN UNITS 1, 2 AND 3, ZION UNITS 1 AND DOCKET NOS. 50-10, 237, 249, 295 Alm 304 The attached report of the inspection of the Comonwealth Edison Company's (CE) QA program for nuclear fuel procurement is forwarded for issuance 25-27, 1973 The inspection was conducted on September
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by your office.
by Messrs. Pomeroy and Tripp of RO Headquarters and generally followed the proposed inspection plan.1 This plan was based on the CE Fuel QA program which has been found acceptable by DL.2 The inspection plan
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was applied to fuel 4.outrar 's as outlined below:
]Dresden1-GUNFC-tworeloadcores.Eachcoreconsistsoffive
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The fourth reload batch is to be supplied by reload batches.
GUNFC for the fall of 1973 D-1 refueling.
(Four reload fuel assemblies were fabricated in Japan by Sunitomo Electric
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Industries, Ltd., a licensee of GUNFC.)
Dresden 2 and 3, Quad Cities 1 and 2 - General Electric initial core
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and one reload core for each of these units.
=5 Zion 1 and 2_- Westinghouse - first three cores of each of these units.
LaSalle 1 and 2 - General Electric - initial core plus 1 reload batch
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GUNFC - four reload batches for each unit.
for each core.
Bryon 1 and 2, Braidwood 1 and 2 - Vestinghouse - initial cores plus eight reload batches for each of these plants.
We are referencing only the Dresden and Zion Dockets rather than all of the above, since most of the material reviewed applied to these units.
Our overall reaction to the CE program was that they appear to be conducting
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some QC checks on their fuel suppliers but that they were not conducting Considering their corporate comitment a QA program for fuel procurement.
to nuclear power and the poor fuel performnce they have experienced to date, we would expect a much higher degrea of management interest and Hemo to Crier from Reinmuth, dated September 7,1973, " Planned 1
Irmeetion of Cormonwealth Edison's Fuel OA orogram._"__
-2 nttur"D'.- 1;-Skovhwir,- t to-Jr-Sr-At ci,--CE-dated-Septensber-1-7, 19735 omct >
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j ees--se-stes.: so4rs Form AEC-3ts (Rev.9-53) AECM 0240 3
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W. Vetter C E 5 $3 3
involvement in fuel procure =arit than we found. Although the CE policy
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of using " strong economic incentives" in fuel contracts to assure
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. production of " sound, long life fuel" has proved largely ineffective, there appears to be no plan to strengthen their own capabilities to provide an independent assessment of the adequacy of fuel. Enclosure number 2 is a draft enforcement letter requesting a 20 day response s:::
to the apparent violations and program weaknesses.
Based on the results of this inspection, we recommend a RO:III directed reinspection in about six months. A likely subject, based on current CE refueling plans," would be Quad Cities 1 and 2 reloads 6f GE 8x8 fuel. We would like to be kept informed of any action you plan in this area, and would like to assist in a reinspection if it can be arranged to our mutual benefit.
Not discussed in this report are the inspection findings relative to the analysis of the Dresden 3 spring 1973 refueling. These findings are documented in enclosure 3.
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{ s.W.I'258 G. W. Reinmuth, Chief Technical Assistance Branch, RO
Enclosure:
1.
RO Inspection Report 2.
Draft Enforcement Letter 3.
Memo, Tripp to Reinmuth, dated 10/9/73 cc w/encls:
bec w/encls:
D. F. Knuth A. Herdt, RO:II J. G. Davis J. Tillou, RO:I B. H. Grier W. Hayward, RO:I
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J. B. Henderson U. Potapovs RO Regional Directors L. Tripp D. Pomeroy G. Bidinger 3CE QA Program for Nuclear Fuel submitted to DL dated May 16, 1973.
4 Letter, J. S. Abel, CE to D. L. Ziemann, DL. Dated September 25, 1973, "Dresden 2-3 and Quad Cities 1-2 Refueling Plans."
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Forra AEC.H8 (Rev. 9-53) AECM 0240 n u n. conewaar samtme omes te n-no -an
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- e ENCLOSURE 1 - INSPECTION REPORT (COVER SHEET TO BE ADDED BY RO:III)
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A.
Background
The Directorate of Regulatory Operations conducted a special inspection of the quality assurance (Q/A) system employed by Commonwealth Edison
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Company (CE) in the procurement of nuclear fuel. The primary objective
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of this inspection was to obtain information which would permit an
- Ijidg appraisal of the implementation and effectiveness of the Q/A controls i
employed by CE in the procurement of nuclear fuel to assure compliance 575;f.J with the 18 Q/A criteria for Nuclear Power Plants (Appendix B, 10 CFR
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Part 50). The inspection findings are based on review of pertinent documents such as the CE Q/A Manual, Q/A procedures, supplier evaluation
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reports, purchase orders and reports of inspections of fuel fabricators
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as supplemented by interviews with CE personnel.
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B.
Enforcement Actions The following items of noncompliance were identified during the inspection.
1.
10 CFR 50, Appendix B, Criterion V states in part:
" Activities affecting quality shall be prescribed by documented... procedures,
_ _,y appropriate to the circumstances and shall be accomplished in accordance
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vith these.
, procedures,
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Contrary to the above:
a.
A procedure (Q.P. No. 10-2) has been prepared for use in inspection
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at the fuel contractor.
However, the procedure does not include 77.;7 requirements to 1) provide for the assignments of qualified inspectors; ii) prepare documented results of the inspections; iii) provide for management review of inspection results; iv) reinspect deficient areas; and v) prepare inspection plans or check-lists for each inspection or inspection type.
(See Details, Section 3)'.
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b.
Procedure Q.P. No. 10-2 requires that during the pre-manufacturing phase a schedule of audits will be established. However, a schedule of audits of fuel contractors has not been prepared.
(See Details,
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Section 8.1) c.
Procedure Q.P. No. 10-2 requires that the Quality Assurance Administrator verify completion of corrective action (taken by the fuel manufacturer on areas found deficient by the Nuclear Fuel Inspector).
However, no systematic method has been developed for following up on deficiencies and thereby allow the Quality
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Assurance Administrator to verify completion of corrective actions.
(See Details, Section 8.4).
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10 CFR 50, Appendix B, Criterion VII states in part:
" Measures shall be established to assure that purchased material,.
conform to the procurement documents. These measures shall include evidence of quality furnished by the contractor, inspection at the contractor source, and examination of products upon delivery.
The effectiveness of the control of quality by contractors shall be assessed by the applicant or designee at intervals consistent with 5 -a the importance, complexity; and quantity of the product or services."
Also, Criterion IV requires that contractors provide a quality assurance program consistent with the Appendix B criteria.
Contrary to the above, inspections of fuel contractors were incomplete in that these inspections were not conducted against each of the Appendix B Criteria.
For example:
a.
Criterion I-Organizction.
Inspections of fuel contractors do not include a determination that the fuel contractors' organization provides that: i) the authority and duties of persons performing quality assurance function are clearly established and delineated in writing; and 11) such persons have sufficient authority, organizational freedom and independence to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions.
(See Details, Section 8.2) b.
Criterion III-Design Control. Although the responsibility for fuel design contractor,7nddesignreviewisdelegatedtothenucelarfuel 1
the inspections did not determine the establishment or effectiveness of the design control measures applied by the fuel contractor.
(See Details, Section 8.2)
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c.
Criterion IV and VII-Control of Procurement Documents and
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Purc?ased Fbterial.
Inspections of fuel contractors did not include a determination that the fuel contractor is assuring that adequate requirements are included in his procurement documents. These inspections did not include a determination that material purchased by the fuel contractor conforms to the procurement documents.
(See Details, Section 8.2) d.
Criterion IX-Control of Special Processes.
Inspections of fuel contractors did not include a determination that the special processes used in the manufacturer of nuclear fuel are accomplished by qualified personnel using qualified procedures.
(See Details, Section 8.2) e.
Criterion XVI-Corrective Action.
Inspections of fuel contractors did not include a finding that 1) the fuel contractor determines the causes of conditions adverse to quality; ii) takes corrective action to preclude repetition; iii) documents causes and corrective actions; l
and iv) reports these to appropriate levels of his management.
(See Details, Section 8.2) 1/ " Responses to AEC Inquiry Concerning Com=onwealth Edison's Q'uality Assurance l
Program for Nuclear Fuel," dated Merch 22, 1973, submitted to Licensing on May 16, 1973, Docket No. 50-10.
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10 CFR 50, Appendix B, Criterion XVI states in part:
" Measures Fi?5@
shall be established to assure that conditions adverse to quality,
"=M such as deficiencies, deviations, defective material, and non-
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conformances are promptly identified and corrected.
The identifi-
"TII cation of the significant, condition adverse to quality, the cause
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Contrary to the above, a) identification of significant conditions adverse to quality from the fuel inspector's inspections were not reported to appropriate levels of management and b) corrective actions were not documented and reported to appropriate levels of management.
(See Details, Section 8.2)
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4.
10 CFR 50, Appendix B, Criterion XVIII states:
"A comprehensive
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system of planned and periodic audits shall be carried out to verify
_E5 compliance with all aspects of the quality assurance program and to
.,_ jfj determine the effectiveness of the program.
The audits shall be
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performed in accordance with the written procedures or checklists by appropriately trained personnel not having direct responsibilities in the areas being audited. Audit results shall be documented and reviewed by management h'aving responsibility in the area audited.
, 3=r Follow-up action, including reaudit of deficient areas, shall be taken where indicated."
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Contrary to the above, no internal audits had been performed to verify compliance with, nor determine the effectiveness of the quality assurance program for the purchase of nuclear fuel.
(See Details, Section 4)
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C.
Significant Findings 1.
A review of the records of CE inspections conducted at three fuel fabricators indicated that some 40 inspections had been made, lasting 2-3 days each.
The inspection reports indicated that substantive deficiencies with the fabricators Q/A program were often found, however, 3=
follow-up actions were found to be inconsistent.
(See Details, Section 8)
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2.
CE is reorganizing their Q/A functions and has recently established
.. 2" a " Manager of Q/A" position reporting to an Executive Vice President.
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(See Details, Section 2) jh.g;;
3.
A review of nuclear-fuel purchasing documents indicated that Q/A
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(See Details, Section 6) y==
4.
CE has utilized outside laboratories for independent analyses of production fuel quality.
(See Decails, Section 9) u
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5.
CE fuel failure experience is being analyzed and there is feed-back from this experience into the fuel QA program.
(See Details,
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Section 10)
D.
Management Interview
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At the conclusion of the inspection Messrs. Pomeroy and Tripp met
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with the following CE personnel:
Name Title J. H. Ellis Section Engineer - M&S Engr.-CECO W. M. Kiefer Director, Nuclear Fuel Services R. J. Squires QA Coordinator (Production) 7 W. J. Shewski Manager of QA G. F. Marcus Fuel Agent 5
E. J. Hemzy QA Administrator (Engrg. & Constr.)
L. W. Duchek Nuclear Fuel Inspector
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The meeting was opened with comments from Mr. Pomeroy regarding the purpose of the inspection and its relationship to the direct inspections by
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Regulatory Operations at fuel fabricator facilities.
It was explained that the presentation of fin'ings would include, in d
addition to deficiencies identified, the personal observations and
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conclusion made by the inspectors for whatever benefit the licensee might derive.
The introductory remarks were concluded with an explanation of the method by which the inspection findings would be documented and the subsequent release of these documents to the Public Document Room.
Following these comments, the detailed results of the inspection were discussed, as described in Paragraph B and C above. Comments by the licensee are outlined below:
1)
Internal Audits The licensee questioned the inspectors regarding the need to conduct audits of their fuel Q/A program. Were they to " audit" the " auditor"?
The inspectors replied that the type of program that CE had outlined in their Quality Procedures No. 18-1, General Office Audit of Total Quality Assurance Program, was what they had in mind.
The inspectors also stated that the implementation of this type of procedure to the fuel Q/A program would appear necessary to meet the requirements of the CE Q/A policy manual which states in part (Q.R. 18.0 Internal Audits):
" Audits will be performed by CE Co.
to verify the adequacy and effectiveness of quality programs under their cognizance.
These audits are to be conducted to assist the organization being audited and assure that required corrective action or improvements are accomplished."
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- 2) Qualification of Fuel Contractors Eil -
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The inspectors discussed the commitments made in the CE submittal to Regulatory Licensing on their fuel Q/A program regarding the evaluation ME=
of contractors. The inspectors stated that these commitments did
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not appear to have been implemented.
CE personnel stated that c
- .g procedure had been prepared to implement this commitment, that it would be used in the future and that it was now being used as an aid
?ti in their contractor inspection program.
- 3) Contractor Inspections The inspectors stated that based on the experience of RO inspectors with inspections of this type, many of the CE fuel QA inspections
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should have been conducted by a team (2 or 3) of inspectors rather
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than by one person due to the complexity of typical nuclear fuel
. _ "Z fabrication operations. This would permit the utilization of
~~~ E inspection personnel with different (but complimentary) backgrounds and technical expertise and would avoid the situation in which one
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inspector confronts several vendor personnel by himself. CE responded that they believed " man days" of inspection time was a better criteria for gaging the scope of an inspection program.
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DETAILS f.
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Persons Contacted ej g=:
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J. A. Abel, Nuclear Licensing J. Dolter, Nuclear Fuel Services
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L. W. Duchek, Nuclear Fuel Inspector 3GE2n I
E.'J. Hemzy, QA Administrator (Engineering and Construction)
W. M. Kiefer, Director, Nuclear Fuel Services mi=in G. F. Marcus, Fuel Agent, Purchasing 9:
l W. Shewski, Manager of Quality Assurance R. J. Squires, QA Coordinator (Production)
A. Veras, Nuclear Fuel Services
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Fuel QA Organization
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The Commonwealth Edison Company (CE) responsibility for nuclear fuel
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quality assurance is as follows:
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President - Overall responsibility for CE Nuclear fuel quality assurance
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program.
Manager of Quality Assurance - Responsible for development, implementation, 1..-
and execution of nuclear fuel quality assurance program.
Mr. Shevski has just recently been appointed to this position as a part of the reorganization currently in progress at CE.
Until his appointment,
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P., Engineering and Construction and the Manager of Production.
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Fuel Agent - Responsible for coordinating design control and procurement
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document control as well as ontrolling the distribution of documents.
Nuclear Fue? Inspector - Responsible for evaluation of contractor's fuel I
QA program; surveys of the fuel contractor for implementation of special process procedures, assurance that procedures are established and 7#
executed, assurance that test controls are established and executed, assurance that procedures and records for calibration of test equipment are established and executed, assurance that instructions for handling,
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preservation, storage,and shipping are established, and disposition of non-conforming items including identification and correction; determination that the contractor's QA program includes procedures for identification
=i-of items and traceability of documentation; and for audits of the fuel contractor's procedures.
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Quality Assurance Adminstrator - Responsible for implementation of the bUbk fuel vendor's QA program surveillance inspections.
This also includes pp verifying completion of corrective action. Audits are under his
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ME4E Technical Staff Engineers - Establishment and execution of procedures for inspection of the fuel at the station and for surveying the fuel contractor's procedures for disposition of non-conforming items.
Specialists in Engineering, Quality Control and Reactor Analysis - Review
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procurement documents as needed, audit fuel inspections and repair during
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on fuel matters, and evaluation of fuel failure mechanisms and failure r===
experience.
Other Departments - Prepare, review and approve quality procedures as applicable pertaining to nucicar fuel.
3.
Fuel QA Program Procedures Those portions of the CE quality assurance manual applicable to the fuel QA program were reviewed. Those Quality Procedures (Q.P.) which appeared to be applicable to nuclear fuel were as follows:
Q.P. No. 3-1 (Design Control) - This procedure establishes the
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method for the review, evaluation, approval, control and release of design documents.
Q.P. No. 4-2 (Evaluation of Contractor's Quality Assurance Progrom and Procedures) - The purpose of this procedure is to assure that contractor progra=med activities provide the required quality requirements for delivered and installed material, equipment, and systems.
Q.P. No. 10-2 (Surveillance of Nucicar Fuel Fabrication)- The quality assurance programs of nuclear fuel fabricators are to be inspected by CE in accordance with this procedure.
Q.P. No. 10-52 (Station Operation and Fuel Handling) - The purpose of
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this procedure is to provide instructions and describe responsibilities for the inspection of nuclear generating station operational activities.
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P.P. No. 10-52 (General Office Audit of Total Quality Assurance ~
'h= 55 Program - This procedure states that, "the quality assurance programs of Commonwealth Edison Company and its' contractors shall be audited
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by personnel from the Mechanical and Structural Engineering Department and the Station Electrical Engineering Department, in accordance with this procedure."
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i In this review, particular c'mphasis was placed on Q.P. 10-2 since this procedure was the most applicable to the fuel QA program.
This procedure has no requirements for assignment of qualified inspectors to the fuel surveillance program.
Although the general areas to be inspected during the fabrication surveillance program are outlined, this procedure cannot be used as an inspection plan or checklist.
In the procedure, there are no requirements to prepare inspection reports or* documented results of inspections, for management review of inspection resuits, for reinspection in area found deficient, or to conduct the inspections in accordance with written procedures or checklista for each inspection or inspection type.
4.
Audits The CE QA policy manual, in Section 18.0 on Internal Audits, states in part that, " Audits will be performed by CE Co.
. to verify the adequacy and effectiveness of quality programs under their cognizance.
These audits are to be conducted to assist the organization being audited and assure that corrective action or improvements are accomplished."
Organizationally, these audits appear to be the responsibility of the Mechanical and Structural Engineering Department and the Station Electrical Engineering Department.
The RO inspectors asked CE representa-tives if any internal audit of their fuel QA progrrm had ever been done to determine its effectiveness and were told that no internal audits had ever been performed of the fuel QA function.
5.
Qualification of Fuel Contractors The CE submittal to Licensing dated March 22, 1973, states in part that, " Qualified contractors are selected on the basis of evaluated or demonstrated capability to provide a product, process, or service.
An overall review of the contractor's quality assurance program is performed as necessary. Where valid records of contractor capability and quality performance are not available to Commonwealth Edison Company, a survey of the contractor's facilities, capabilities, and quality assurance systems has been made by Commonwealth Ediscn Company or its designated representatives.
Such surveys include, as applicable, a review of facilities, organization, quality assurance experience, existing controls, knowledge of special processes, and an understanding of, and a willingaess to meet, contract or purchase order requirements."
Since 1970, Jersey Nuclear (now Exxon Nuclear) has been considered as an approved potential supplier of reload fuel.
The inspectors reviewed the qualification procedure for Jersey Nuclear. According-to Mr. Marcus, Jersey Nuclear made one or more technical presentations to CE representa-tives, Mr. Veras made a visit to their fabrication facilities, and a detailed written proposal to another utility which included a description of Jersey Nuclear qualifications was made available for CE review.
CE conducted a search of their records and was unable to find any documentation to indicate that an evaluation of Jersey Nuclear was made or that demonstrated capability had been evaluated.
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.J rm -". The CE Quality Assurance Manual now has a procedure (Q.P. 4-2) for evaluation of contractor's quality assurance program and another
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procedure now in preparation has requirements for evaluation of the vendor's
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quality program prior to award of contract.
Such procedures, if aqss implemented, would appear to be an adequate method to assure that only as qualified suppliers were considered for nuclear fuel orders.
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6.
Procurement Document Control The methods for assuring that procurement documents contain the necessary QA requirements were covered by the inspectors. The method for getting these requirements into contracts is an informal approach and no written procedure has been prepared.
The fuel agent consults with the QA staff to get their input as to what was required to handle QA/QC audits, inspections, surveillance, etc.
Portions of fuel contracts from the late 1950's thru 1972 were examined with one of the most recent examined in detail.
This recent contract requires the fuel supplier to establish a program
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such that CE can satisfy applicable USAEC requirementa as to fuel quality.
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It requires the fuel vendor to submit his quality assurance program in
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writing to CE for review and comment prior to fuel manufacture.
It also applies to the fabricator's subvendors.
Finally, it requires the fabricator to make applicable records, procedures and data available to CE for inspection and it establishes the right of access of CE representatives to vendor and subvendors shops for necessary inspections.
.7.
CE Review of Fuel Design and Fabrication Changes The CE March 22, 3973, submittal states that, "in areas of special concern the contractor requests review and comment bafore modification
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started." As a result of PWR fuel experience, changes were made to the Zion 1 and Zion 2 initial cores after fabrication had started. To
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observe the CE implementation of the above commitment, the RO inspectors asked
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to review the CE actions relative to these changes.
CE representatives followed applicable PWR experience closely including 3;s <
direct contacts with the station staff.
After review and discussions with Westinghouse of their recommendations, it was agreed on October 25, 1972, to use the original Zion 2 fuel (Regions 2 and 3) in Zion 1 after increasing the fuel density and the internal pressurization pressure. The original Region 3 fuel of Zion Unit 1 was refabricated (the contained uranium ".==="
was reconverted to UF and subsequently reconverted-to UO,) to be used 6
in Region 3 of Zion Unit 2.
The original Region 2 fuel of Unit I was repres-
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surrized at a higher pressure for utilization in Region 2 of Unit 2.
..ge sj The CE documentation of the above modifications indicated that CE ihe personnel had reviewed other utility experience with Westinghouse fuel, reviewed the proposed modifications, commented as appropriate, and concurred with the actual modifications.
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8.
Inspections of Fuel Vendors
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The CE fuel fabricato'r inspection program is described below.
8.1 General g :3_.
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The CE Nuclear Fuel Inspector (NFI) was hired upon graduation from college approximately three years ago. According to Mr. Henzy, he conducts curveillance inspections, not audits.
In his early inspections, he was accompanied by Mr. Squires and/or by representatives of a CE consultant, NATCO.
NATCO also assisted CE in the fuel QA program by making an evaluation of the Westinghouse fuel QA program during late 1971 - early 1972.
Since the initial inspections, the Nuclear
_...fs Fuel Inspector has been conducting vendor inspections by himself.
- "'T The NFI writes a report describing these inspections to the QA Administrator. The NFI attempts to get deficiencies noted in his
.3 inspections corrected at the time of the inspection, at the exit meeting Es at the vendor, or thru the participation of appropriate CE management.
The NFI has no pre-planned schedule for inspections. His inspection trips to the vendor are based on when CE fuel is to be manufactured.
According to the NFI, he regularly talks by phone to the fabricator's representatives to determine when CE fuel will be in manufacture and schedules his. trips accordf:. gly.
This is not in agreement with Q.P.
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No. 10-2 which requires that a schedule of audits will be establi,shed during the pre-manufacturing phase.
Inspections are not conducted in accordance with written procedures. The NFI may submit a list of items or creas to be looked at to the QA Administrator for his concurrence
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prior to visiting the vendor.- From the RO inspectors conservations with
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the NFI, it was apparent that inspections are not conducted on a j
planned or systematic basis and lit +.le use is made of written procedures of checklists.
8.2 Reports of Inspections The CE surveillance trips to Westinghouse, GUNFC and General Electric
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are summarized in Table 1.
Most of the reports covering these inspections were reviewed in this inspection.
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NUCLEAR FUEL FABRICATION INSPECTIONS 56===
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E: es Year Company No. of Inspections and Location No. of Days of Inspections
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1971 G. E.
Wilmington (5) 14
~=..1l GUNFC Heratite (1) 1 New Haven (1) 2
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W Cheswick (2) 9 Columbia (2) 5
==5 Pittsburgh (1) 1
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- . I.,f 1972 GE (0) 0 GUNFC Hematite (3) 7
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New Haven (2) 5 l
Elmsford (1) 2
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Cheswick (4) 8 Monroeville (1) 1
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Columbia (7) 20 1973 GE Wilmington (2) 6
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GUNFC New Haven (1) 2 Elmsford (1) 2
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W Columbia (4) 8 E-ui
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The NFI's reports showed a lack of organization and cover the
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details of these surveillance inspections in a rambling manner.
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Significant findings were not highlighted or summarized in these
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reports. Outstanding or unresolved items were not listed or
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highlighted for management attention and followup in subsequent
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inspection for resolution.
Except for the NFI's memory, there was
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during the inspection and no procedure for assuring closeout or
=u resolution of outstanding items.
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Correspondence to and from the vendors was reviewed which indicated that some problems were being resolved in this manner.
In this correspondence, there was no evidence that these letters were being cross checked with the items and issues raised in the inspection
':g:2 reports so that all problems could be resolved.
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The NFI's reports were reviewed to determine if they established pr.
that the fuel fabricator contractor's quality assurance program meets n=
the requirements of the 18 Criteria of 10 CFR Appendix B.
In several areas, it was found that the NFI had not established that the fuel contractors' programs were in compliance with these criteria.
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general the surveillance inspections were QC, not QA inspections.
Specific examples where the UFI had failed to establish contractor compliance included the following:
The NFI's reports did act include evidence of critical
~~'
cvaluation or inspes?9.n of the vendor's QA organization.
Design, design review, and design control responsibilities are assigned to the vendor. However, CE had the g
responsibility for auditing these areas to insure that they are being properly accomplished. No audits of design, design review, and design control activities at G.E.,
GUNFC or Westinghouse have been performed.
Inspections at the fuel contractors did not cover in sufficient detail procurement documents and incoming or receiving QC inspections.
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Inspections at the fuel contractors did not establish that special manufacturing processes and procedures are qualified or that persons performing activities affecting quality are
[.',f" properly trained and qualified.
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The NFI's verification of the fuel vendor's initiation of
- 5II corrective actions is only accomplished to the point of verifying that deficiencies in CE fuel are corrected or repaired and not to assure that deficiencies will not be "7".7".
repeated.
9 ::
In reviewing the NFI's inspection reports, the RO inspectors fot d
.;gs indications that the NFI had encountered problems in obtaining access to necessary records, procedures, and data to assess the effectiveness of the vendor's fuel QA program. However, by the time of this inspection, most of the access problems had been resolved satisfactorily.
Another item of interest found in the NFI's reports was the fact that four Dresden I Batch 9 fuel assemblics were fabricated in Japan using 5,5...
AEC enriched UF material by Sumitomo Electric Industries, Ltd. (SEI),
g a licensee of GUNFC. These assemblies were fabricated in accordance with GUNFC drawings and specifications and under GUNFC's supervision.
SEI was not required to have a quality system manual for fuel
~
fabrication. The QA manager at CUNFC identified, through discussions with SEI, that adequate plans for inspection, etc. existed.
These discussions were documented in an internal GUNFC memo PM-667 dated July 10, 1972.
8.3 NATCO Assistance CE together with Consolidated Edison and Vepco, hired an outside*
consultant (NATCO) to assist them in the fuel QA area with respect to the Zion 1 and 2 fuel manufacture by Westinghouse.
Phase 1 of this effort was initiated on August 16, 1971, and covered a five-month period.
Phase 1 was comprised of an overall detailed review, analysis,
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and evaluation for the participating utilities of specifications for
==
purchased and Westinghouse-manufactured materials, the operations and processes, and the associated quality assurance and quality control programs used by Westinghouse to fabricate nuclear fuel assemblies.
Phase 2 consisted of audit-inspections of Westinghouse operations during the fabrication of the Zion fuel for CE.
During this inspection, the RO inspectors reviewed some of the reports submitted by NATCO. These reports raised what would appear to be several valid concerns about Westinghouse QA/QC programs and procedures.
However, many of these concerns were not resolved by CE, and were g=
never pursued.
In their last report of May 18, 1972, NATCO states that, "NATCO and Commonwealth Edison representatives requested that Westinghouse formally reply to the utility on each of the statements and
.g suggestions listed in Section 2.0 of this report. --- NATCO suggests
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that Commonwealth Edison follow up with Westinghouse on each issue and consider meeting with Westinghouse representatives at a higher management level to obtain their concurrence on some of the requests which the utilit'y deems critical to the quality assurance program." Howeve?9i-most of the unresolved items listed in this report were never resolved
=9:
or closed out and no meeting of the type suggested by NATCO was ever held between CE and Westinghouse. The NFI did go through the
!=E" issues raised by NATCO item-by-item and write down (in long hand) his thoughts-and opinions which included some items which he considered satisfactorily resolved but there was no evidence that his comments were ever formally transmitted to management.
8.4 Management Participation Management participation in the surveillance inspection program appeared to be minimal.
CE mancgement did not participate directly in inspec-
"j tions and had little participation in followup actions to resolve
]
problems identified in the NFI's reports.
For example, at the
'E conclusion of the NATCO assistance program, a meeting was held in Monroeville, Pa., on May 1-2, 1972, to discuss all remaining unresolved concerns of NATCO and the CE NFI regarding the Westinghouse fuel QA program. There was no management participation by CE in this meeting (only the NFI represented CE).
The NFI writes his inspection reports to the QA Administrator for Engineering and Conctruction with copies to other departments within 28 CE that have an interest in his inspections.
The QA Administrator does not comply with the requirements of Q.P. No. 10-2 which require him to verify the completion of corrective actions.
There is no documented listing to the QA Administrator of unresolved deficiencies in the fuel vendors' QA/QC programs in the NFI's reports.
The QA Administrator's participation in followup on outstanding items with the fuel T?
fabrication vendors appears unorganized and undocumented.
Closecut actions on deficiencies are generally transmitted verbally or in the text of the inspection reports to the QA Administrator.
In one case, after the fuel fabrication was nearly completed, the NFI went back through the inspection reports for that vendor and indicated in a written manner on a report-by-report basis to the QA Administrator what had happened with respect to the deficiencies in the vendor's program discussed in those reports.
gg CE management has not directed the NFI co develop inspection plans and schedules, to highlight deficiencies found at the vendors, or write his reports in a more systematic or organized manner, however,
=E4 he has been instructed to make his reports more brief and to the point.
^W Although CE management was responsible for hiring an outside consultant to assist.in their fuel QA program, this consultant's work appeared ineffective due to inadequate CE manage =ent participation and followup.
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Independen't Analyses of Production, Fuel Quality ESE-CE has utilized.outside assistance in specialized areas. On occasion, 5:," [.
.they have utilized two outside laboratories for checks o.n. pellet moisture
==i and chemical impurity content.
Some veld samples have been taken for metallographic examination. This is not*done on a routine basis but rather
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as'a spot check.
When one vendor proposed to utilize a special type of E
g cladding material in some test rods in one of their reactors, CE hired an outside consultant to evaluate the proposal before acceptance.
- 10. Fuel Performance Feedback into the Fuel QA Program
- =-
CE fuel failure experience was reviewed to determine how this experience was factored into measures to prevent further or future fuel failures.
The Nuclear Fuel Services department analyzes fuel failure mechanisms and failure experience in detail.vorking jointly with the vendors.
(They
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are currently attempting to hire a fuel technologist with expertise in fuel design and fabrication.) These fuel failures are discussed informally with the fuel QA people (NFI and QA Administrator) and~the Nuclear Fuel Services department receives copies of all of the NFI's reports.
The Nuclear Fuel Services department utilizes the NFI to get the necessary records for attempts to correlate fuel failures with specific fuel
~
manufacturing activities. CE has not looked into detailed specifications related to items such as moisture or hydrogenous material content of the fuel. The leave such matters to the vendor but utilize fuel contracts which provide strong economic incentives to the vendors to produce sound, long life fuel.
In several cases CE has required the vendor to replace failed or defective fuel including a complete core replacement for Dresden 2.
- 25
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ENCLOSURE 2 Q.
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UNITED STATES Q.
ATOMIC ENERGY COMMISSION b
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DRAFT onn e TO BE RETYPED ON RO:III LETTERHEAD I.. 7..f Docket No. 50-10
. =g 50-237
- E,2 50-249 50-295
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Commonwealth Edison Company y'-
ATTN: W. Beneke, Executive Vice President-P. O. Box 767 Chicago, Illinois 60690 J~
Gentlemen:
This refers to the AEC inspection conducted on September 25-27, 1973 T.5}
at Commonwealth Edison Company offices in Chicago, Illinois and to
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discussions of our findings held with Mr. Skeuski and others of your
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staff at the conclusion of the inspection.
This inspection was an Hi..
e:: amination of activities related to the procurement of fuel for several iir of your nuclear power plants and a comparison of these activities
- i=4 with the Commission's Quality Assurance Criteria.
The inspection was conducted by Mr. Pomeroy and Mr. Tripp of our Regulatory Operations Headquarters office and. it consisted of selective examinations of pro-cedures and representative records, interviews with personnel, and observations by the inspectors.
Based on the results of this inspection, it appears that certain of your activities are in violation of AEC requirements.
These items are listed in attachment A to this letter and in the enclosed report.
1 This notice is sent to you pursuant to the provisions of Section 2.201 of the AEC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.
Section 2.201 requires you to submit to this office with twenty (20) days of your receipt of this notice a written statement or explanation in reply including: (1) corrective steps which have been taken by you and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance vill be achieved.
In additon to the need for corrective action regarding these specific deficiencies, we are concerned about the implementation of your quality assurance program that permitted these deficiencies to occur.
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Consequently, in your reply, you should describe in particular, those W
l actions taken or P anned to improve the effectiveness of your quality assurance program for procurement of nuclear fuel.
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In accordance with Section 2.790 of the AEC's " Rules of Practice,"
'ZE Part 2, Title 10, Code of Federal Regulation, a copy of this letter, the enclosed 1.spection report and your response to this letter will
. da:y:
be placed in the AEC's Public Document Room.
If this report contains
=MiI any informatic.a that you (or your suppliers) believe to be prcyrietary,
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it is necessary that you make a written application within 20 days to
- 71.._
this office to withhold such information from public disclosure.
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Any such application must include a full statement on the base of which
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it is claimed that the information is proprietary, and should be pre-
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pared so the proprietary information identified in the application is
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contained in a. separate part of the document.
If we do not hear from you in this regard the report will be placed in the Public Document Room with your response.
Should you have any questions concerning this inspection, we will be glad to discuss them with you.
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Sincerely,
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a9 J. G. Keppler, Director Region III
Enclosure:
As Stated i
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DESCRIPTION OF VIOLATIONS
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25255 Commonwealth Edison Company 5 -55 E
Certain activities under your license identified below appear to be in l',(';];
violation of Regulatory requirements. These are considered to be of
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Category II severity:
1.
10 CFR 50, Appendix B, Criterion V states in Part: " Activities
~~=di affecting quality shall be prescribed by documented...
procedures,... appropriate to the circumstances and shs11 be accomplished in accordance with these.
., procedures,...."
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Contrary to the above:
a.
A procedure (Q.P. No.10-2) has been prepared for use in u=:
inspection at the fuel contractor.
However, the procedure
- rt does,not include requirecents to i) provide for the assign-EE:
ments of qualified inspectors; ii) prepare documented results
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of the inspections; iii) provide for management review of inspection results; iv) reinspect deficient areas; v) prepare inspection plans or check lists for each inspection or inspec-tion type.
b.
Procedure Q.P. No. 10-2 requires that during the pre-manufacturing i
phase a schedule of audits will be established.
However a schedule of audits of fuel contractors has not been prepared.
c.
Procedure Q.P. No. 10-2 requires that the Quality Assurance
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Administrator verify completion of corrective action (taken by the fuel manufacturer on areas found deficient by the Nuclear
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Vuel Inspector).
However no systematic. methods has been developed for following
. R up on deficiencies and thereby allow the Quality Assurance Administrator to verify completion of corrective actions.
2.
10 CFR-50, Appendix B, Criterion VII states in part: " Measures shall be. established to assure that purchased material,...
conform to the procurement documents. These measures shall include evidence of quality furnished by the contractor, inspec-r9}q tion at the contractor source, and examination of products upon delivery.
The effectiveness of the control of quality by
- q f contractors shall be assessed by the applicant or designee at
~E intervals consistent with the importance, complexity, and quantity
):5c qq of the product or services." Also Criterion IV requires that
.a contractors provide a quality assurance program consistent with
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the Appendix B criteria.
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Attachment A,
Ti Contrary to the above, inspections of fuel contractors were incomplete Efi i:t in that these inspections were not conducted against each of the Appendix B
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Criteria.
For example:
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a.
Criterion I - Organization.
Inspections of fuel contractors d
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do not include a determination that the fuel contractors
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1 organization provides that: 1) the authority and duties of persons performing quality assurance function are clearly
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established and delineated in writing; and 11) such persons
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have sufficient authority, organizational freedom and independence to identify quality problens; to initiate, recommend, or provide solutions; and to verify implementation z.=
of solutions.
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1 b.
Criterion III - Design Control. Although the respon,sibility for fuel design and design review is delegated to the nuclear fuel contractor / the inspections did not determine the l
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j establishment or effectiveness of the design control measures applied by the fuel contractor.
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c.
CriterionIV and VII - Control of Procurement Documents and Purchased Material.
Inspections of fuel contractors did not include a determination that the fuel contractor is assuring that adequate requirements are included in his procurement documents.
These inspections did not include a determination that material purchased by the fuel contractor conforms to
- r the procurement documents.
- =-
d.
Criterion IX - Control of Special Processes.
Inspections of
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fuel contractors did not include a determination that the special processes used in the manufacture of nuclear fuel are accomplished by qualified personnel using qualified procedures.
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e.
Criterion XVI - Corrective Action.
Inspections of the fuel contractors did not include a finding that 1) the fuel contractor determines the causes of conditions adverse to qualicy; ii) takes corrective action to preclude repetition;
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iii) documents causes and corrective actions; and iv) reports these to appropriate levels of his management.
- = ": \\0 1/"Reponses to AEC Inquiry Concerning Commonwealth Edison's Quality
- ._.d Assurance Program for Nuclear Fuel," dated March 22, 1973, submitted to
- .s,,.v; Licensing on May 16, 1973, Docket No. 50-1.
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Attachment A -
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3.
10 CFR 50, Appendix B, Criterion XVI states in part: " Measures shall be established to assure that conditions adverse to quality,
- 4EJ such as deficiencies, deviations, defective material, and non-F9 "_
conformances are promptly identified and corrected.
The identi-22g fication of the.significant condition adverse to quality, the
- =;
cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management."
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Contrary to the above, a) identification of significant conditions adverse to quality from the fuel inspector's inspections were not reported to appropriate levels of management and b) corrective actions were not documented and reported to appropriate icvels of management.
4.
10 CFR 50, Appendix B, Criterion XVIII states:
'A comprehensive Ei system of planned and periodic audits shall be carried out to "u
verify compliance with all aspects of the quality assurance program and to determinethe effectiveness of the program. The audits shall be performed in accordance with the written procedures
- =
or check lists by appropriately trained personnel not having direct responsibilities in the arcas being auditied.
Audit results shall be docucented and reviewed by management having responsibility in the area audited. Follow-up action, including reaudit of deficient
~
areas, shall be taken where indicated."
Contrary to the above, no internal audits had been performed to verify compliance with, nor detern'nc the erfectiveness of the quality assurance
.. program for the~ purchase of nuclear fuel.
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