ML20024B659
| ML20024B659 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 06/27/1983 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20024B654 | List: |
| References | |
| 6766N, NUDOCS 8307110146 | |
| Download: ML20024B659 (3) | |
Text
'
^ 'N Commonwealth Edison
) One First Nation 51 Pina. Chicago, lilinois O
') Addr:ss R: ply to: Post Offica Box 767 gj/ Chicago, Illinois 60690 June 27, 1983 Mr. James G. Keppler, Regional Administrator U.S. Nuclear Regulatory Commission - Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Byron Generating Station Unit 1 Inspection Report No. 50-454/83-16 NRC Docket No. 50-454 Reference (a):
S. Little to Cordell Reed.
2
Dear Mr. Keppler:
This letter is in response to the inspection conducted by Mr. R.
S. Love on March 21-25, and April 4-8, 1983, of activities at Byron Station.
During that inspection certain activities were found to be in noncor.pliance with NRC requirements.
Commonwealth Edison's response to the Notice of Violation attached to reference (a) is provided in Attachment A to this letter.
To the best of my knowledge and belief the statements contained herein and in the attachment are true and correct.
In some respects these statements are not based upon my personal knowledge but upon information furnished by other Commonwealth Edison employees.
Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
If you have any further questions on this matter, please direct them to this office.
Very truly yours,
==,
M D. L. Farrar Director of Nuclear Licensing TRT/lm 6766N JUN 2 8 1983 8307110146 830706 i
PDR ADOCK 05000454 G
pm
,'e, e 5-b ATTACHMENT A-RESPONSE TO NOTICE-OF VIOLATION VIOLATION 10'CFR 50, Append'ix B, Criterion II, states, in part, "The program shall provide for in'doctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained."
l Commonwealth' Edison Company (CECO) letter, L. O. DelGeorge to D. G.
Eisenhut, U.S. NRC,. Director, Division of Licensing, dated August 17, L
1981,~ affirmed CECO commitment to Regulatory Guide 1.146, August 1980 and ANSI N45.7.23-1978 as required by Generic Letter 81-01.
ANSI N45.2.23-1978, paragraph 2.3, states, "An individual shall meet the requirements of paragraphs 2.3.1 through 2.3.5 prior to being designated a lehd-auditor."
ANSI.N45.2.23-1978, paragraph 2.3.1, states, in part, " Education and Experience.
The prospective lead auditor shall have verifiable evidence that.a minimum of_ ten _(10) credits under the following scoring system have'been accumulated.
Education (4 credit maximum).
Experience (9
. points maximum).
Other credentials of professional competence (2 credit maximum).
Rights of Management (2 points maximum).
Contrary to'the above, the Commonwealth Edison, Company Quality. Assurance Lead Auditor performing the Power-Azco-Pope audit >was not adequately qualified and/or trained-to perform lead auditor functions.
Details of apparent noncompliance.to the above requirements are delineated in paragraph 3.A.(1) of-the' attached report.
Response
i-
[
The lead auditor's certification as an Interim Lead Auditor was carefully and selectively established on the basis of demonstrated capabilities in the ~ performance of his work, technical competence and 4
-mature judgement, audits as an auditor, satisfactory completion of
_ training _in< auditing and non-destructive testing involving MT/PT, RT, UT l
Lend Visual' Inspection,; satisfactory participation in an ASME Survey, j
serving _as a knowledgeable instructor involving several welding and codes and standards training classes and proficient performance in eight audits i
' including six as an auditor (ANSI N45.2.23 requires a minimum of five (5)
- for Lead Auditor.)
This individual had eight points of the ten required for certification.
The only area in which the individual did not p
specifically meet ANSI N45.2.23 was the' two year experience in Quality
.?
.s m.
i '
i i
Assurance requirement.. He had'approximately eighteen months of Quality
_ Assurance experience.
This person is a graduate Welding Engineer and for this reason was recruited and. hired.to provide expertise in welding and in codes.and standards.... Because he performed: exceptionally well.in carrying.out.this type of assigned. work,.because he had expertise in welding plus codes and standards and was a graduate Welding Engineer, because he had more than adequately met all the technical requirements and because he was required to carry out his auditing activities.directly i-under the supervision of a cuality Assurance Supervisor who was a Lead Auditor, it was deemed acceptable to establish'him as an Interim Lead Auditor-because it could'be clearly demonstrated that the person had 1
experience, could perform the audit acceptably and did perform the vari-j
,~
ous interim lead. auditor functions under the supervision of a qualified Quality Assurance Supervisor.
Under the role of Interim Lead Auditor, i
audit checklists and reports are' required to be formulated under the
~
supervision of at least a supervisor as.well as be reviewed and approved i
by a. supervisor.
\\-
I' As a result of this required supervisory involvement in the formula-tion and approval of the ~ audit checklist,. the review and acceptance of i-the checklist objective evidence and the approval of the audit reports by Quality Assurance Supervision,1we are confident that the audits were performed and reported. acceptably and that proper corrective action was achieved.
Also,, subsequent and repeated coverage by surveillances and i
i other audits by other people adds to our confidence that the audits
- performed under a designated Interim Lead Auditor are acceptable.
It has not been standard practice to establishLInterim Lead Auditors, i
. On:the contrary, only on rare occasions,.after careful evaluation and t
where there was. dire need, and the person had more.than a year of Quality Assurance experience, and had. demonstrated technical competence, mature
-judgement, and lead auditor attributes, was an-Interim Lead Auditor established.
In all cases, such appointees worked directly under the
[
supervision of at least a. supervisory level' person as described above.
ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE:
L The Interim' Lead Auditor concept has been discontinued and a request l
has been submitted to ASME/ ANSI requesting that other-provisions be I
provided in the Standard for giving points for experience.
h DATE WHEN FULL COMPLIANCE SHALL BE ACHIEVED:
June 15, 1983.
. 6766N
- l. '
b r
r.
-..-u..
... _. - -, _. _.. _. _,, _... _..,,. _,. _._._.....,.._..._..._,..____.._: