ML19339C056

Responds to NRC 800904 Ltr Re Followup Requirements for Resumption of Use of Tech-Sil,Inc Fire Stop matl.Tech-Sil Has Provided Assurance That Const Matls Have Traceable Certifications

ML19339C056
Person / Time
Site:	LaSalle
Issue date:	10/28/1980
From:	Delgeorge L COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8011170286
Download: ML19339C056 (5)

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[] 1 Commonwealth Edison 3 one First National Plaza. Chicago Illinois l U

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October 28, 1980 [' S h r

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us M*s Ed Mr. James G. Keppler, Director xmo

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22 2-en Es Directorate of Inspection and $ u4 "5 Enforcement - Region III _

O n3 su U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

LaSalle County Station Units 1 and 2 F*re Stop Material (Tech. Sil. Inc.) Assessment NRC Docket Nos. 50-373 and 50-374 Reference (a): J. G. Keppler letter to C. Reed dated September 4, 1980

Dear Mr. Keppler:

This letter addresses the follow-up action required by the NRC prior to the resumption of use of Tech-Sil, Inc. leaded elastomer and high density gel penetrations at LaSalle County Station. The following materials have been reviewed with Mr. J.

Niesler of your staff during the week of October 20, 1980. We are prepared on the basis of the corrective action discussed in this letter to resume work at LaSalle County Station involving the subject material. It is our understanding from Mr. Niesler that authorization to resume that work is conditioned upon your receipt of this formal documentation. Your expedited review and confirmation of authorization to proceed is requested.

I. Response to NRC Item "a" A comprehensive audit (Q.A. audit #1-80-77 dated 9/19/80) was conducted on Tuesday, September 16, 1980 and on Wednesday, September 17, 1980, at the Tech-Sil home office at 1800 Elmhurst,. Elk Grove Village, Illinois. The purpose of the audit was to review and determine the adequacy of the Tech-Sil internal design and product control and to address the following concerns:

A. Organization /QA Independence B. Validity of the Certificate of Conformance C. Verification of Design Procedures and the Approval of Deviations from such procedures.

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- Mr. James.G. Keppler, Director October 28, 1980 l l

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-D. Verification that materials used for CECO. projects have been t,ested.

E. Verify the validity of calibrated instruments F. Verify the qualifications of QC/QA personnel G. Verify the performance of audits by independent personnel The audit checklist consisted of (11) questions. From these questions, (4) findings and (1) observation were identified and are detailed below:

Finding #1 (Question #2): Tech-Sil did not establish measures to assure that applicable design basis for penetration seals were translated into specifications, procedures or instructions.

and that deviations from such standards were controlled by.the use of internal procedures. Tech-Sil does not have an internal written procedure identifying the review approval, release and distribution of the design mix or revisions to the formula.

Tech-Sil has provided such procedure. It has been reviewed and accepted by CECO./S&L.

Finding #2 (Question #3): Contrary to Tech-Sil's Quality Procedure #105 Item 6.0, Tech-Sil's Project Specifications and Revisions have not been reviewed and approved by CECO./S&L.

Tech-Sil made Corporate in-house changes to the design mix without revising their on-site procedures or notifying S&L.

Tech-Sil has submitted revised on-site procedures that reference all formulas used at LaSalle. These procedures have been reviewed and approved for construction by CECO./S&L.

Finding #3 (Question #7): Contrary to Tech-Sil's Quality Proceoure #103 Item 2.2.1; there appears to be concern regarding the traceability of Mfg. Certifications to class ( A) Materials.

Tech-Sil has rectified this deficiency and has provided assurance that materials used for construction which are identified in the system log have certifications which are traceable to the material used.

-s o Mr. James G. Keppler, Director October 26,. 1980 Page 3 Observation #1 (Question #9): Are personnel performing QC inspections trained and qualified in accordance with QAP - 113?

It's required per Tech-Sil's Certification of Qualificatio Form Q-014 dated 1-1-79 that evaluating the validity and acceptability of inspection, examination and testing results are to be performed by a Level II inspector.

Tech-Sil has verified that any inspector performing the above mentioned work is a Level II inspector.

Finding #4 (Question #10 & #11): Contrary to Tech-Sil's QA Manual no in-house audits have been performed as scheduled.

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A complete in-house audit was performed on. September.29, 1980. This audit covered design control and the certification of material. All items of QA audit #1-80-77 dated 9/19/80 are closed.

II. Response to NRC Item "b" Nonconformance reports were completed by Tech-Sil (NRC's 9, 10, 3A, 4B) to identify all lot numbers or penetrations for any material that had not been fire tested prior to its installation. Station Construction has written corresponding NCR's (#458, 460, 461) complete with corrective action requirements set forth. As a result of an audit of their QC records Tech-Sil determined that five different lead elastomer formulas, and three different high density gel formulas have been used at LaSalle. A summary of the formulas is listed below:

LEAD ELASTOMER FORMULA DATES USED FIRE TEST # DATE TS-MS-0060-F Jan. 1979 to June 1979 #TS-TP-0050-B 8-29-80 TS-MS-0060-G June 1979 to Sept. 1979 #TS-TP-0050-C 8-29-80 TS-MS-0060-C Sept. 1979 to Present #TS-TP-0048-A 8 29-80 TS-MS-0060-D Dec. 1979 to Feb. 1980 #TS-TP-0048-B 8-29-80 TS-MS-0060-E May 1980 to June 1980 #TS-TP-0050-A 8-29-80

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Mr. James G. Keppler, Director-

' October 28, 1980 Page 4 HIGH DENSITY GEL FORMUL DATES USED FIRE TEST # DATE TS-MS-0080-E June 1980 to Present #TS-TP-0051-B 9-2-80 TS-MS-0080-B April 1980 to May 1980 #TS-TP-0051-A 9-2-80 TS-MS-0080-G May 1980 #TS-TP-0056-A 10-10-80 Sargent & Lundy has reviewed all of the above mentioned -fire tests except for High Density Gel formula TS-MS-0080-G which was tested on 10/10/80 and has found them to be in accordance with the requirements established by the LaSalle FSAR Appendix H, Section H.l.l.E. Tech-Sil has proposed to use a High Density Gel formula TS-MS-0080-F. This formula has been fire tested and will be submitted with the TS-MS-0080-G formula to Sargent &

Lundy for approval. Commonwealth Edison will inform Mr. J.

Niesler as socq As the Sargent & Lundy-approval has been received. In s.'dition, Tech-Sil has submitted an internal work procedure (#0005, Material Identification for formulated silicone materials, Rev. 0) to S&L for approval. This procedure defines Tech-Sil's responsibility to submit fire test reports (where fire endurance is required by the clients specification) for approval for any formulas used in their installation procedures.

This procedure has been reviewed and approved by Sargent & Lundy.

III. The following is the Commonwealth Edison Quality Assurance Department response to Item "C" of the NRC's Immediate Action Letter dated September 4, 1980.

The Commonwealth Edison Quality Assurance Department monitors the activities of on-site and of f-site contractors by audit and surveillance to assure that work conforms to quality assurance program requirements.

In addition to the scheduled Commonwealth Edison Company audits, an Inspection Point Program is provided for in specifications and allows CECO. or its agent access to each contractor's shop for purposes of reviewing the quality of work and/or progress. In the case of Tech-Sil, because of the nature of the product developed by Tech-Sil and their acceptance of the product through tests, it was decided to not establish witness points at this off-site facility.

On August 24, 1)79, CECO.'s Station Nuclear Engineering Department's Quality' Control personnel conducted an audit of the Tech-Sil corporate office in Elk Grove Village. The audit

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a i Mr. James G.Keppler, Director October 28, 1980 Page 5 covered organization, QA Manual Control, auditor control verification that QA reviewes P.O. requirements, traceability of material, balibration ,

verification of QC acceptance of tests and verification that the person who signs the Certificate of Conformance is responsible for quality. .Only one deficiency was-identified during the audit. The deficiency was the failure of Tech-Sil to perform follow-up audits when a deficiency is identified. Subsequent to the audit this deficiency was closed.

At'the LaSalle site,-Commonwealth Edison Site Quality Assurance has performed nine formal audits of Tech-Sil since March of 1979. Items of noncompliance identifi;d in these audits have been resolved or are actively being pursued to resolution by CECO. QA. As part of the CECO. site audits, Tech-Sil site receiving activities were audited. No discrepancies relating to thesa inspections were noted during the audits.

In view of the above audit results, there was no apparent reason to suspect the adequacy of Tech-Sil's program, or more specifically, the adequacy of their process control procedures.

Nonetheless, CECO.'s Quality Assurance auditors have been alerted to be more cognizant of process control quality aspects and requirements when performing audits of vendor facilities.

If you have any further questions in this regard, please direct them to this office. As has been stated, resumption of work shall take place after confirmation by Region III of authorization to proceed.

Very truly yours, L. O. De1 George Nuclear Licensing Administrator cc: RIII Resident Inspector - LSCS 7721A l

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