ML20028G681
| ML20028G681 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 01/20/1983 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20028G675 | List: |
| References | |
| 5818N, NUDOCS 8302170297 | |
| Download: ML20028G681 (5) | |
Text
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Commonwealth Edison j# , . 9 one First National Plaza. ChicJigo, libnois l C./ '7 Addrsss Rrply to: Pcst OfficiBox 7@
i . (j Chicago, Illinois 60690
)
January 20,-1983 r
Mr. James G. Keppler, Regional Administrator 1 Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Eli ia, f IL 60137
Subject:
LaSalle County Station Units l'and 2 Response to Inspection Report Nos.
l 50-373/82-51 and 50-374/82-18 NRC-Docket-Nos.-50-373-and 50-374-i
- Reference (a): J. G. Keppler letter to Cordell Reed '
dated December 22, 1982.
2
Dear Mr. Keppler:
This letter is in response to the inspection conducted by .
! Messrs. R. D. Lanksbury and H. M. Wescott.on July 21 December 4,
! 1982, of activities at LaSalle County Station. . Reference (a) 3 indicated that certain activities appeared to be in non-compliance i with NRC requirements. The Commonwealth Edison Company response to
- . the Notice of Violation is provided in the enclosure.
i l To the best of my knowledge and belief the statements con-j tained herein and in the attachment are true and correct. In some i 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 j- direct them to this office.
i
- j. Very truly yours, 1
l- L. O. DelGeorg Director of Nuclear Licensing
/ CWS/1m
) Attachment cc: NRC Resident Inspector - LSCS ,
8302170297 830209 i PDR ADOCK 05000373
!O
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i' o ATTACHMENT
- 1. Apparent Item-of Noncompliance 10 CFR 50, Appendix B, Criterion XVI, states in part,
... conditions adverse to quality...are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is l determined and corrective action taken to preclude repetition".
The LaSalle County Station FSAR, Chapter 17.0, Section 16.0.,-
page 16-1, states in part, "A corrective action system will be used l to assure that such items as... deficiencies, deviations, ...and
. nonconformances which are adverse to quality and migh affect the safe
- operation...are promptly identified anC corrected."
Contrary to the above, conditions adverse to quality were not .
promptly corrected nor were corrective actions sufficient to preclude repetition of similar items. For example on August 25, 1980, a CECO i audit identified documentation problems and actions were not taken to
! prevent recurrences of the same type of problems with other documentation.
Discussion Commonwealth Edison has reconstructed chronologically the series i of events associated with the Zack Company documentation deficiencies.
(See Attachment I) The purpose of this reconstruction is to demon-strate that in August 1980 CECO QA identified the problem of missing material certifications. As a result, Zack performed a complete records review to obtain the missing material certification documents and in the process of' obtaining the missing documentation alterations
- of documents were identified.
L CECO Site QA surveillances in May and July of 1980 (Prior to the ,
CECO Audit 1-80-62) had examined weld rod certifications on a sample basis and found them to be available and acceptable. Thus at the time e of audit 1-80-62, a problem with weld rod certifications was not felt l to exist. Zack site personnel issued NCR 2095 to expand the documentation review effort to inc1"Je obtaining documentation-for weld rod that was delivered directly to the site rather than being processed through the Zack Cicero office.
Corrective Action Taken and Results Achieved The reccrds review conducted by Zack and monitored by CECO QA has resolved the noted documentation problems. It is acknowledged that the record would have been clearer if Observation #1 of CECO audit 1-80-62 had not been officially closed until corrective action was complete. In this regard the policy on close out of audit items has been changed. Audit items which require e"en long term corrective actions are not closed until all coirective action is complete. This approach provides for better tracking the corrective action and should assure more prompt completion of any required actions.
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Corrective-Action-Taken to Prevent-Recurrence In regard to alterations of records, CECO Lead Auditors have under gone training to make them more aware of how to detect possible record alterations.
The Zack review for missing certifications All Unit 2 has addressed Zack material has been records for all purchased material.
received at the site and final records turnover will begin shortly.
A final check of records completeness will be performed as part of the turnover process.
Date of Full Compliance The records review conducted by Zack and monitored by CECO Q.A.
has been completed. The CECO Q.A. policy The for long term closure of additional trrining for corrective actions has been changed. Thus, full compl:ance has CECO Lead auditors has been conducted.
been achieved.
In addition a final check of records and completeness will be conducted as part of the turnover process and is expected to be completed by June 1, 1983.
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- 2. Apparent Item of Non-Compliance 10 CFR 50, Appendix B, Criterion VII, states in part, " Measures shall be established to assure that purchased material... conform to the procurement documents".
10 CFR 50, Appendix B, Criterion XV, states in part,
" Nonconforming items shall be reviewed and accepted, rejected, repaired or reworked in accordance with documented procedures".
Commonwealth Edison Quality Assurance Manual, Quality Requirement QR No. 15.0, paragraph 15.2, states in part, " Technical evaluation will be performed by qualified personnel to determine whether a nonconforming items may be accepted "as is", repaired to an acceptable condition, or whether the item must be rejected,... When items are accepted "as is", technical evaluation will be performed to assure that the final condition of nonconforming items will not adversely affect Code requirements, safety, operability or maintain .
ability of the items, or of the component or system in which it is installed."
Contrary to the above, LaSalle NCR No. 557 was closed by CECO after Zack submitted a letter stating that the material met the Sargent & Lundy specification but with two attachments from the supplier stating that the material complied with a different standard than required.
Response
Corrective Action Taken and Results Achieved Commonwealth Edison Company Nonconformance Report 611 accepted the subject materials "as is" on October 29, 1982. This acceptance was based on "the proximity of typical mechanical and chemical properties of the material substitution to the specified material."
Corrective Action Taken to Prevent-Recurrence The error in the closure of NCR 557 is considered an isolated occurrence which did not result in the use of unacceptable material.
The Project Construction Department engineer involved has been reinstructed to more thoroughly review applicable documentation prior to completing dispositions on nonconformance reports.
Date - of Full Compliance Full Compliance has been achieved.
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O-Attachment I DATE DOCUMENT EVENT 5-28-80 Surv. #80-294 CECO Surveillance verifying.
Weld Rod Certs 7-14-80 Surv. #80-366 CECO Sury. Verifying Weld Rod Certs 8-26-80 CECO Audit 1-80-62 18 PO's were reviewed during this audit for material certs.
9 of these P.O.'s contained missing certs.
9-4-80 Zack Response to 5 of the 9 missing certs were Audit 1-80-62 provided by the Cicero office.
Zack committed to do a complete records review back to 1976 and locate or obtain the missing documents and determine what additional documents were missing.
1-14-81 Zack Site NCR 1242 This NCR committed the site to review their records for missing documentation.
4-14-81 Surv. #80-472 This surveillance closed the audit deficiency of 1-80-62 by obtaining or dispositioning the remaining 4 audit identified missing certs. Also 8 additional P.O.'s were checked for proper certs and an l additional JJ) receiving loads were checked for proper l documentation. Zack was tracking all missing documentation by issuing NCR's and continuing review thru NCR 1242.
Spring 81 None A Zack Midland employee identified certain CMTR's as I being questionable.
8-21-81 NCR 2095 Zack QC Manager became aware of weld rod missing certs and issued an NCR 9-30-81 Telephone Notification Zack notified CECO of a from Zack to CECO reportble defluiency (50.55(e)
- 81-08) due to material certs being incomplete inaccurate or altered.
Progress beyond this point is well documented as corrective action to 50.55(e) #81-08.
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