ML20010A304
| ML20010A304 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 07/28/1981 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20010A301 | List: |
| References | |
| NUDOCS 8108110297 | |
| Download: ML20010A304 (5) | |
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N Commonwealth Edison
) One First National Plaza Chicigo. Illinois O " 7 Address Reply to: Post Office Box 767 CRago, Illir ois 60690 4
July 28, 1981 Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - Region-III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 6C137 r
Subject:
LaSalle County Station Units 1 and 2 Response to NRC Inspection Report 50-373/81-17 and 50-374/81-11 NRC Docket Nos. 50-373/374 Reference (a):
C. E. Norelius letter to Cordell Reed dated June 16,.1981.
(b):
L. O. DelGeorge letter to J. G. Keppler dated July 13, 1981.
Dear Mr. Keppler:
Reference (a) indicated that certain activities appeared to be in ncn-compliance with specified NRC requirements and requested a written response vithin twenty-five (25) days.
Reference (b) documented your acceptance of the Commonwealth Edison Company request for an extension of the response due date until August 14, 1981.
The enclosure to this letter provides the Commonwealth Edison Company response to this matter.
The apparent item of i
noncompliance was raised during the special safety inspection co., ducted by Mr.
I.
- i. Yin of your office on May 6, 1981, at the General Electric Company facilities concerning activities that pertain to LaSalle County Station Units 1 and 2.
To the best of my knowledge and belief, the statements contained herein and in the enclosure are true and correct.
In some respects these statements are not based upon my personal knowledge but upon information furnished by other Commonwealth Edison and contractor employees.
Such'information has been reviewed in 3
accordance with Company practice and I believe it to be reliable.
8108110297 810806 PDR ADOCK 05000373 M 3g Jggy O
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J. G. Keppler July 28, 1981 Please address any further questions that you may have concerning this matter to this office.
Very truly yours, L.O.
DelGeorge Director of Nuclear Licensing cc:
Regior. III Resident Inspector - LaSalle im SUBSCRIBE 0 AND SWORN to before me this JfeIday of
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1981.
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Notary Public Enclosure 2342N
ENCLOSURE COMMONWEALTH EDISON COMPANY LASALLE COUNTY STATION UNITS 1 and 2 RESPONSE TO NOTICE OF VIOLATION The item of apparent non-compliance identified in Appendix A of the Reference (a) NRC letter is presented here and responded to' t
in the following paragraphs:
't 10 CFR 50, Appendix B, Criterion VI, states, in part, that
" Measures shall be established to control the issuance of documents
...... including the changes thereto, which prescribe all activities affecting quality.
These measures shall assure that documents, including changes, are reviewed....and approved....by authorized personnel and are distributed to and used at the location where the 4
prescribed activity is performed."
Commonwealth Edison Company Topical Report CE-1A,." Quality Assurance Program for Nuclear Generating Stations", Revision 9, dated July 16, 1979, states in Section 6, that "A document control system will be used to assure that documents such as specifications, procedures and drawings are reviewed for adequacy and approved for release by authorized personnel.
Such documents will be distributed to and used at the locations where the prescribed activity is performed.
Changes to these documents will be handled similarly and will be reviewed and approved by the same organization that performed the original review and approval, unless delegated by the originating organization to another responsible organization."
Contrary to the above, during an inspection.at GE in San Jose on May 6, 1981, it was identified that there was an apparent lack of measures to control the use of outdated design information at work locations.
This lack of control resulted in outdated design drawings being used by a design engineer and also being referenced in the stress report.
1)
DISCUSSION OF THE APPARENT NON-COMPLIANCE As was discussed with the NRC Inspector during and subsequent to the audit in question, and according to the written i
General Electric Company response to Commonwealth Edison Company j
addressing this matter, the General Electric Company design control l
system accounts for, maintains and distributes all new or changed documents through a computerized system called the Engineering Information-System (EIS).
The EIS contains a listing of the latest approved document for any specific application.
The Engineering l
Procedures System requires that the EIS be interrogated regarding l
the reported doCuF.ent status, project, system or component application.
Tn the above circumstance, the EIS system.was in fact, I
accurete and up to date.
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' Before a document is used for engineering purposes, the EIS is interrogated to ascertain the correct revision.
The EIS is used to verify document effectivity and application before' issue, distribution or use.
After entry into-the EIS, the latest documents are placed on film, maintained and distributed through the Document Release and Control System.
During the NRC inspection, the. responsible engineer used a copy of the drawing from his working design. record file in discussion with the NRC Inspector, instead of. interrogating.the EIS as the Engineering Procedures System requires to obtain the latest revision.
Specifically, the NRC-Inspector asked for a steam pipe suspension drawing.
The responsible engineer pulled drawing number 767E106, Revision 8, from his working design record file and gave it to the NRC Inspector instead of obtaining Revision.9 from the EIS.
Therefore, the responsible engineer failed to follow establ.ished procedures.
On the other hand, the Revision 8 drawing had an outstanding Engineering Change Notice (ECN) NHll317 against it which was in the possession of the engineer.
In addition, the General Electric document control system has been reviewed by-the ASME and found acceptable as evidenced by the fact that an N-Stamp was issued and has been maintained by the General Electric Company.
Furthermore, the Commonwealth Edison Company periodically performs audits at this General Electric facility and we have not found evidence of a lack of adequate document control.
Based on the above, the Commonwealth Edison Company does not believe that the problem necessarily exists in the General Electric Company document control system itself.
Rather, the l
apparent item of non-compliance leads us to believe that this is an i
isolated case and that there may be a lack of emphasis by the l
General Electric Company on the correct usage of the existing system.
f If the NRC perceives that further corrective action over and above Item 2 below is still warranted, we respectfully request that the NRC pursue this matter directly with the General Electric
. Company as part of their generic manufacturer inspection program, rather than through the LaSalle County Station Docket.
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. 2)
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED To preclude any future misunderstanding on the part of the
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General Electric Company engineers, the-General Electric Company will issue a Quality Assurance newsletter.
This will re-emphasize the need to follow: procedures covering document control and the correct use of only those documents formally-issued through the Document Release & Control System and whose application and status is up to date with the EIS.
Also, this matter will be emphasized in the General Electric Company Q.A. training for engineers.
.The Commonwealth Edison Quality Assurance Department will audit the General Electric facility to insure that such emphasis is placed on the correct usage of up to date documents issued through the Document Release and Control System.
3)
CORRECTIVE ACTION TO PREVENT RECURRENCE See Item 2 above.
4)
DATE OF FULL COMPLIANCE The issuance of the General Electric Quality Assurance Newsletter and such emphasis in the General Electric Q.A. training of engineers will be initiated by August 1, 1981.
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