ML20008F365

Responds to NRC 801230 Ltr Re Violations Noted in IE Insp Repts 50-454/80-04 & 50-455/80-04.Corrective Actions: Identified & Documented Deviations from Specified Technical Requirements in Sys Control Corp Components

ML20008F365
Person / Time
Site:	Byron, Braidwood
Issue date:	01/26/1981
From:	Reed C COMMONWEALTH EDISON CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20008F361	List: ML20008F365
References
NUDOCS 8103130089
Download: ML20008F365 (6)

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Commonwealth ECson

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• One First National Plaza ChjcaJo Ill.ncis Address Reply to Post Off4ce Box 767 Chicago. Ilhnois 60690 January 26, 1981 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:

Byron Station Units 1 and 2 Response to IE Inspection Reports No. 50-454/80-04 and 50-455/80-05 Reference (a): De cember 30, 1980 letter from J. G. Keppler to B. Lee

Dear Mr. Keppler:

Reference (a) contained the report of an investigation conducted by Messrs. J. B. McCarten and J. E. Konklin of your of fice and Mr. L. E. Ellershaw of Region IV regarding activities at Systems Control Corporation and at Byron Station. During that investigation it was determined that certain activities were in noncompliance with NRC requirements. Attachment A to this letter contains Commonwealth Edison Company's response to the Notice of Violation which was appended to Refelence (a). The corrective action discussed in Attachment A also addresses your request for discussion of contributing management f actors relative to the violation.

Attachment B to this letter contains the requested additional information regarding resolution of the item from Commonwealth Edison Audit No. 6-80-238.

Attachment C to this letter contains the results of the requested inspection of instrument lines.

Please address further questions regarding matters to this o f fi ce .

Very truly yours,

, e C. Reed Vice President Atta chment 00488

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NRC Docket Nos. 50-454/455 ATTACHMENT A Response to Notice of Violation INFRACTION Criterion XVI of 10 CFR 50, Appendix B, states, in part, that

" Measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. . .and corre ctive action taken to preclude repetition."

The Commonwealth Edison Company Quality Assurance Manual in Quality Requirement QR No. 16.0, Section 16.1, states, in part, that "A corrective action system will be used to assure that such items as

. . . defective material and equipment. . .are promptly identified and corrected. ..this system will provide follow up to assure that corrective measures are effectively implemented."

Contrary to the above, during the period from May 1977 to February

.1980, the licensee failed to take effective and timely actions to assure that deficiencies in the System Control Corporation (SCC)

Quality Assurance Program and equipment fabrication activities were co rre cted , as evidenced by continued receipt and acceptance on site of defective safety-related equipment from SCC.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED During the period in question, May 1977 to February 1980, Systems Control Corporation supplied various components under the scope of the following procurement specf fications:

Main Control Boards - Spe cification F/L-2788 Local . Instrument Panels - Specification F/L-2809 Cable Pans and Hanger Assemblies - Specification F/L-2815 Systems Control Corporation in the course of fabricating components assemblies under the scope of each specification has deviated from certain specified technical requirements. In each case of deviation, the items of nonconformance have been identified and documented on a Nonconformance Report (NCR).

Corrective action has been completed for the Local Instrument Panels. Nonconformance Reports F-474 and F-484 covering this were closed on 10/21/80.

For the Main Control Boards, engineering analysis to determine cisposition has been initiated under NCR F-544 dated 8/8/80.

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For cable pan stiffener problems, NRC F-529 was issued on 7/9/80 and Sargent & Lundy has determined the stiffeners satisfied specification requirements. However, final disposition of this NCR is dependent on a re-survey of equipment in the field which is currently under way.

The waiver of inspection points without QA concurrence resulted from failure to recognize that QA approval of waivers was mandatory.

Also, the site receipt inspection performed by the Project Construction Department was primarily an inspection for shipping damage. Subsequently, as identified in the NRC inspection report, detailed inspections were perform 2d by Commonwealth Edison which idenfified deviations on components supplied by Systems Control.

The deficiencies identified have been controlled via NCR's. In addition, the Commonwealth Edison Site Quality Assurance Department has established requirements for performing significantly more detailed inspections for all equipment received on site generally using the independent testing contractor. These inspections are in addition to those performed by Project Construction.

MANAGEMENT FACTORS WHICH LED TO CONTINUED RECEIPT OF NONCONFORMING MATERIAL AND ACTION TAKEN TO PREVENT RECURRENCE With regard to the management factors contributing to the continued receipt and acceptance of defective equipment shipped by Systems Control, the previously established method of handling notification of inspection points was not sufficiently controlled to assure that all established mandatory inspection points were properly executed or properly waived. As a result, processing the notification of inspection points has been revised to ensure that all notifications are processed through a designated Project Construction coordinator who is responsible for: (1) assigning a Project Construction engineer to conduct the inspection point or, (2) obtaining documented waiver from Quality Assurance for all mandatory inspection points which are not to be conducted. Project Construction and Quality Assurance personnel who are involved in the processing of vendor inspection points have been retrained. In addition, all project specifications for the Byron Site have been reviewed to assure that mandatory inspection points are established.

As described in the preceding corrective actions, receiving inspections will be upgraded to provide significantly more detailed inspections for all safety related equipment.

For Systems Control Corporation, source inspection has been conducted for all safety-related equipment shipped since February 1980 and source inspection will be conducted on all future shipments involving Systems Control. These inspections have been conducted by t

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L .'. "ittsburgh Testing Laboratory under the direction of the Byron Quality Assurance Department. The inspections cover welding, equipment identification, sealing of instrumentation lines and other specification requirements.

Furthermore, since January 1978 Commonwealth Edison has not made any purchases from Systems Control. As a result of the NRC verification of allegations against Systems Control, as reported to Commonwealth l Edison on December 30, 1980, Systems Control has been barred from procurement activity involving safety-related purchases for an indefinite period.

DATE WHEN FULL COMPLIANCE WILL BE A,CHIEVED We are in full compliance at this time.

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> NRC Docket Nos. 50-454 50-455 ATTACHMENT B RESPONSE TO REQUEST FOR STATUS OF UNRESOLVED ITEM ON Commonwealth Eoison AUDIT No. 6-80-238 As of 8/4/80, finding #3 of Commonwealth Edison Audit No. 6-80-238 has been closed. this was based on a comparison of Mr. Pezzullo's education, experience and training to ANSI N45.2.6-1978 re comme nda tions .

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NRC Docket Nos. 50-454 50-455 ATTACHMENT C RESULTS OF INSPECTION OF INSTRUMENT LINES ON LOCAL INSTRUMENT PANELS PROVIDED BY SYSTEMS CONTROL CORPORATION Through a combination of direct visual examinstion on two 12 inch sections of instrument lines removed from two panels of the suspect population, and by examination of flush cloths drawn through the instrument lines of other panels of the suspect population, we have found no evidence of corrosion products contained within the lines in question. Additional samples are being taken. These examinations are ceing conducted at this time to ascertain if rust particles were introduced into the lines during the course of the manufacturing process. Regardless of the foregoing findings, the lines will be flushed prior to being placed into an operating status.

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