ML19338G397

Responds to NRC 800827 Ltr Re Violations Noted in IE Insp Repts 50-373/80-32 & 50-374/80-20.Corrective Actions: Contractor Organization Charts Revised to Delineate Job Classifications & Util Conducted Audits

ML19338G397
Person / Time
Site:	LaSalle
Issue date:	09/26/1980
From:	Abel J COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19338G389	List: ML19338G397
References
NUDOCS 8010290192
Download: ML19338G397 (9)

Text

m Commonwe;lth Edison  !

O one hrst Nabonal Plaza. Chicago tlhnois i Address Reply to- Post Othce Box 767

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- Chicago, lihnois 60390 September 26, 1980 Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

LaSalle County Station Units 1 and 2 Response to IE Inspection Report Nos.

SD-373/80-32; 50-374/80-20

! NRC Docket Nos. 50-373 ano 50-374 References (a): J. G. Keppler letter to C. Reed dated August 27, 1980.

(b): J. G. Keppler letter to C. Reed dated August 14, 1980.

Dear Mr. Keppler:

Tne fo. awing is in response to the inspection conducted by Mr. I. T. Yin on August 6-8, 1980, of activit.t.es on LaSalle County Station Unit 1. 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.

The Immediate Action Letter (IAL) transmitted by Reference (b) documented the Commonwealth Edison Company decision to temporarily suspend LaSalle County Station small bore pipe hanger and restraint design and installation activities. Subsequently, comprehensive audits were conducted by our Quality Assurance (QA) organization to determine the status of conformance with design and QA criteria.

In the August 29, 1980, management meeting at Region III,

. Commonwealth Edison presented the changes in small bore pipe design and installation provisions initiated in response to issues raised during the suuject inspection. The status and current findings of the Quality Assurance audits initiated in accordance with the IAL were also presented.

On September 2-4, 1980, Mr. I. T. Yin reviewed, in detail, i the aforementioned changes-and audits / responses during inspections conducted at the site and at Sargent & Lundy. In the subsequent i September 5, 1980, management meeting at Region III it was agreed that LaSalle County Station Unit 1 small bore piping design and installation work could be resumed.

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Please refer any questions you may have in this regard to this office.

Very truly yours, 7 g A-J. S. Abel

/ Director of Nuclear Licensing Enclosure cc: NRC RTII Resident Inspector, LaSalle 6960A

O s

, Enclosure Response to Notice of Violation The items of apparrent non-compliance identified in Appendix A of the NRC letter dated August 27, 1980, are responded to in the

following paragraphs.

j 1. 10 CFR 50, Appendix E, Criterion V, states, in part, that i

" Activities affecting quality shall be prescrlDed by docume..teo

instructions, procedures, or drawings . . . and shall be accomplished in accordance with these instructions, procedures,

, or drawings."

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Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Stations," Revision 9, dateo 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 muct De r satisfied to assure that the quality related activity had Deen properly carried out."

Contrary to the above, the MCCo small bore hanger inspection and preliminary design work was being conducted without approved procedures. Furthermore, the MCCo organizational structure and the personnel responsibility were not formally estaolished.

Response

1 Corrective Action Taken and Results Achieved The Morrison Construction Co. (MCCo) has written procedure EC-7, Rev. O, dated August, 1980, entitled, "Small Bore Piping

. Support-Restraint Selection Guidelines and Instructions." This i procedure has been reviewed and approved by CECO and implemented 4 Dy MCCo.

MCCo has revised their' organization chart to delineate the job classifications and assigned tasks of all personnel in the small bore work force.

This chart has been reviewed and approved by Morrison Management.

terrison Engineering Instruction EC-124B lists each job cAassification and the responsibilities associated with this

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cltssification (including contractor personnel). In addition,  ;

Mtr-ison Engineering Instruction'EC-124A lists the criteria '

against which drafting / design personnel are reviewed prior to employment.

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i Corrective Action Taken to Avoid Future Non-compliance 4

The new MCCo procedure EC-7 will ensure that small bore nanger inspection and design work will be conducted using approved procedures.

i Morrison Engineering Instructions EC-124A and EC-1248 are now referenced by procedure EC-7, providing assurance that the MCCc personnel responsibilities remain formally established.

i Date of Full Compliance

Full compliance has been achieved.

2. 10 CFR 50, Appendix B, Criterion II, states, in Dart, that "Tne applicant shall establish at the earliest practicable time, I

consistent with the schedule for accomplishing the activities, a quality assurance program . . . The program shall provide for

] indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained."

t Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Stations", Revision 9, j dated July 16, 1979, states in Section 2 that " Training will be i conducted in a time fram= adequate to prepare personnel for their joo responsibilitias" and " Retraining sessions will be scheduled to assure that adequate. skills are maintained for 3

qualified and/or certified personnel." ,

1 Contrary to the above, contractor personnel hireo by MCCo to perform small bore hanger preliminary design activities had not oeen formally indoctrinated and trained.

, Response Corrective Action Taken and Results Achieved Morrison Construction has added the contract engineering personnel to the Engineering Department Training Matrix, MCCo Form PC-124 The training matrix requires training in MCCo Procedure EC-7 and S&L document PI-LS-16. The training in l these documents has been completed. Completion of training is documented on MCCo Form titled " Job Site Training".

Corrective Action Taken to Avoid Future Non-compliance Adding contractor personnel to the training matrix ensures that these personnel receive the same training as MCCo personnel.

No further action is necessary.

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3-i Date of Full Compliance Full compliance has been achieved.

3. 10 CFR 50 Appendix B, Criterion VI requires, in part, that

" Measures shall be established to control the issuance of documents such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting quality."

1 Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Stations," Revision 9, I dated July 16, 1979, states in Section 6 that "A document

! control system will be used to assure that occuments such as specifications, procedures, and drawings are reviewed for 1

adequacy and approved for release by authorized personnel, i

Such documents will be distributed to and used at the locations l where the prescribed activity is performed. Changes to these j

j documents will be handled similarly and will be reviewed and approved by the same organization that performed tne original j

review ano approval, unless delegated oy the originating i

i organization to another responsible organization."

Contrary to the above, MCCo and S&L Department Correspondence and Inter-Office Memorandums were being issued in lieu of approved procedures for small bore pipe hanger work activities. These documents had not been issued, reviewed, and approved in accordance with QA requirements. Several MCCo calculations had not been documented and MCCo Form System did not conform with QA program requirements.

. Response

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Correctise Action Taken and Results Achieved j

! As stated li, the response to item 1 above, MCCo has replaced their guideline covering small bore pipe hanger work activities l with MCCo Procedure EC-7, Rev. O. This document has been j issued, reviewed and approved in accordance with QA i

requirements. Furthermore, regarding inspection details item 3.c., the instructions in MCCo Department Correspondence F0PE-594 (" Notes, comments, and directions for use of j _ECN-M-208LS . . . " etc.) are now part of Procedure EC-7.

i S&L has reissued PI-LS-16, Revision 3, " Selection and ,

Calculation Requirements for Piping Support Assembly Components;" dated August 18, 1980, together with all appendices. This Project Instruction with the attached t

appendices incorporate the design directives that had been issued informally by means of inter-office memos. It has been issued as a controlled document in accordance with the LaSalle County Project Distribution List.

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Regarding documentation of MCCo calculations, MCCo has written i NCR #623 tracking the fact that calculations were not maintained for the loads and locations of the instrument hangers in Re?ctor Building Unit #1 elevation 739' and below.

Ceco has written NCR #454 to cover MCCo NCR #623 and has j

transmitted it to CECO engineering for disposition. In order j to verify the adequacy of the hangers in question, S&L will review each hanger and perform calculations as required.

Morrison Form PC-124A has been changed to Form EC-1244. This form is part of MCCo Procedure EC-7, Rev. O. MCCo has also l 1 oeveloped a matrix which cross references their process control checklists, PC forms, and the MCCo procedure which governs tne use of the checklist.

Corrective Action Taken to Avoid Future Non-compliance i'

As described in the response to item 1, the new MCCo Procedure EC-7 will ensure that MCCo small bore pipe hanger work activities will be conducted using approved procedures. ,

In the case of S&L, they have committed that any future design directives will be done in accordance with controlled procedures and not issued as interoffice memos. l f

MCCo procedure EC-7 requires that MCCo maintain any future calculations made. It also requires that the hanger designs ce  ;

submitted to S&L for review and acceptance prior to issuance to the field for installation.

The MCCo form cross reference matrix provides a controlled system to assure that the proper interaction of process control l Checklists, PC forms, and procedures is maintained.

Date of Full Compliance Full compliance has been achieved for all items except the S&L

, review of hangers with missing documented calculations. Tr is

! review will proceed as discussed with NRC RIII in the Septeauer 5, 1980, CECO-NRC RIII management meeting.

4. 10 CFR 50, Appendix B, Criterion III, states, in part, that

! " Measures shall be established to assure that applicable . . .

desig's basis . . . for those structures, systems, and components . . . are correctly translated into specifications, l

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-levsl review and/or  ;

evaluation of design documents by individuals or groups other l 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, and process drawings."

4 Contrary to the above, the S&L staff at the site was using i non-safety related criteria for the design of safety related

small bore hangers. Design parameters, including bending ano i torsional movements, support weight, and overall structural

deflections were not being taken into consideration.

Response

Corrective Action Taken and Results Achieved In reference to the use of non-safety related criteria for the design of safety related small bore hangers, the package of documents shown the inspector consisted of the following, bound under a single set of brass clips:

1. S&L Interoffice Memorandum dated April 22, 1980, from Mr.

T. G. Longlais -

Subject:

Design Criteria for Non-Safety Related Piping in Both Safety and Non-Safety Related Areas.

2. S&L Interoffice Memorandum originally dated March 20, 1

1980, Revised May 1, 1980, from Mr. T. G. Longlais -

Subject:

Safety Related Mechanical Component Support Design Criteria.

In adcition to the above memos, the package also consisteo of numerous pages of design information issued for the project.

It is true that the information was not issued, reviewed, and approved in accordance with document control requirements; however, the package of documents did constitute bona fide design information which the designer had bound for his own convenience.

b&L has formally issued copies of PI-LS-16, Rev. 3. to the design personnel in the field. PI-LS-16 contains the design information necessary for review of the field hanger designs.

Personal accumulated copies of design information have been disposed of.

An S&L memo from Mr. T. G. Longlais (revised May 1, 1980) had covered criteria being used in designing hangers, but this revision had not been in PI-LS-16. PI-LS-16, Rev. 3, (issued August 18, 1980) now contains the support selection guidelines for different types of support members (Z bars, wide flange, etc.). .

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6-In the case of Hanger No. 10 (S&L drawing No. M-1302-25),

re ferred to in inspection details item 4.c., the reactions on the connecting structure have been determined by the group designing the main connecting structure. They accounted for the self-weight excitation, moment, and shear as transferred by the hanger members. The requirement of maximum 1/8" deflection at the component support point in the direction of the applied load had been observed and has been stated in the procedure.

Corrective Action Taken to Avoid Future Non-Compliance Project Instruction PI-LS-16, Rev. 3, now contains complete instructions for the design of complex hanger supports. Also, to clarify the interface between the different S&L design groups involved with the design of 2" and under supports, PI-LS-22, Rev. 1, "Sargent & Lundy Divisional Interfaces for Review and Preparation of Calculations of Piping and Supports for 2" and Smaller Seismic Process and Instrumentation Piping" has Deen issuec.

Date of Full Compliance Full compliance has been acnieved.

5. 10 CFR 50, Appendix B, Criterion XVIII, states, in part, that "A comprehensive system of planned 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 ef fectiveness of quall' y programs under their cognizance."

Contrary to the above, the licensee's audit and surveillance of small bore pipe hanger activities was not being carried out to verify compliance with the QA program.

Response

Corrective Action Taken and Results Achieved Commonwealth Edison Site QA conducted audits of S&L and Nuclear Services Corp. (NSC) on August 13-18, 1980. Thesa audits covered small bore piping hanger design at the LaSalle site.

The CECO QA audit of MCCo, which was completed on August 11, 1980, covered small bore piping hanger selection and installation.

Commonwealth Edison QA audits of MCCo and Reactor Controls Inc.

(RCI) on site design, installation and inspection of pipe supports were completed on August 11, 1980, and July ll, 1980, respectively. The other scheduled audits which were deferred were completed as of August 28, 1980.

Corrective Action Taken to Avoid Future Non-compliance To prevent recurrence of the problems noted, all site groups participating in the design of 2 1/2" and under piping have been put on the site QA audit schedule. In addition, the site QA frequency surveillance schedule has been revised to include S&L, NSC and MCCO hanger design ano/or installation. This became effective August 12, 1980.

To assure that audits are completed and reports issueo on time, a meeting / training session was held on August 14, 1980, between the Manager of QA, Director of QA and QA supervisors of the nuclear construction sites and operating stations. Added direction and training was includeo to assure that audits are completed and audit reports are issued in a timely manner in accordance with the audit schedule. In addition, special of f-site audits of the other Commonwealth Edison construction sites have recently been conducted to determine if any hanger support design or installation problems exist.

Date of Full Compliance Full compliance has been achieved.