ML20055B410

Notice of Violation from Insp on 820329-0511

ML20055B410
Person / Time
Site:	Byron
Issue date:	06/24/1982
From:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20055B409	List: ML20055B408 ML20055B410 ML20055B411
References
50-454-82-05, 50-454-82-5, 50-455-82-04, 50-455-82-4, NUDOCS 8207220167
Download: ML20055B410 (7)

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Appendix NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-454 Docket No. 50-455 As a result of the inspection conducted on March 29-31, April 1-2, 5-9, '

12-14, and May 11, 1982, and in accordance with the NRC Enforcement Policy, 47 FR 9987 (March 9, 1982), the following violations were identified:

1. 10 CFR 50, Appendix B, Criterion I, states in part, "The authority j and duties of persons and organizations performing activities affect-ing the safety-related functions of structures, systems, and com-ponents shall be clearly established and delineated in writing" and "Such persons and organizations performing quality assurance functions shall report to a management level such that this required authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations, are provided."

The Licensee's Topical Report, CE-1-A, Revision 20, Section 1.A states

" Edison has prime responsibility for controlling the quality of on-site work by field contractors,"... "The Commonwealth Edison Company Quality Assurance Program for Nuclear Generating Stations covers the organiza-tion arrangement whereby the Quality Assurance Department is a separate-and independent organization."

Contrary to the above:

a. On March 30, 1982, it was identified that the Quality Assurance Manager for Hatfield Electric Company, as shown in the Quality-Assurance Manual, reports to the Vice-President, who is located on site and has direct responsibility for cost and schedule.

. b. On April 2, 1982, it was identified that the Quality Assurance Manager for Powers-Azco-Pope, as shown in the Quality Assurance i

Manual, reports to the Project Manager, who has direct respons-ibility for cost and schedule.

c. On April 8, 1982, it was identified that the Project Construction i Department of the licensee is part of the approval chain regarding the hiring and promoting of contractor's quality assurance personnel.

i d. On March 30, 1982, it was identified that the Hatfield Electric Company has been operating with a Quality Assurance Organization other than that described in their Quality Assurance Manual.

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8207220167 820624 PDR ADOCK 05000454 O PDR

Appendix 2

c. On April 4, 1982, it was identified that Johnson Controls, Inc.

has been operating with a Quality Assurance Organization other than that described in their Quality Assurance Manual.

This is a Severity Level IV violation (Supplement II).

2. 10 CFR 50, Appendix B, Criterion II - Quality Assurance Program states in part, "The program shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained."

Commonwealth Edison Company (CECO) letter, L. O. DelGeorge to D. G. Eisenhut, U.S. NRC, Director, Division of Licensing, dated August 17, 1981, affirmed CECO commitment to Regulatory Guide 1.58, ANSI N45.2.6-1978 as required by Generic Letter 81-01.

ANSI N45.2.6-1978 - Paragraph 1.1 states in part, "This Standard delineates the requirements for the qualification of personnel who perform inspection, examination and testing to verify conformance to specified requirements of nuclear power plant items (structures, systems and components of nuclear power plants) where satisfactory performance is reouired to prevent postulated accidents which could cause undue risk to the health and safety of the public, or to mitigate the consequences of such accidents if they were to occur."

ANSI N45.2.6-1978 - Paragraph 1.2 states in part, "1he requirements of this Standard apply to personnel who perform inspections, examina-tions, and tests during fabrication prior to and during receipt of items at the construction site, during construction, during peropera-tional and startup test...." The requirements apply to personnel of the owners..., plant designers and plant constructors...."

ANSI N45.2.6-1978 - Paragraph 2.2 states, "The capabilities of a candidate for certification shall be initially determined by a suit-able evaluation of the candidate's education, experience, training, test results, or capability demonstration."

ANSI N45.2.6-1978 - Section 3.1 states, "The requirements contained within this section define the minimum capabilities that qualify personnel to perform inspections, examinations, and tests which are within the scope of this standard."

ANSI N45.2.6-1978 - Sections 3.2, 3.3, and 3.4 specify the personnel capabilities of Level I, II, and III inspectors respectively. Sections 3.5, 3.5.1, 3.5.2, 3.5.3 provide education and experience recommenda-tions for Level 1, II, and III inspectors.

Appendix 3 J

ANSI N45.2.6-1978 - Section 4 states in part, " Personnel who are assigned the responsibility and authority to perform functions covered by this Standard shall have, as a minimum, the level of capability shown in Table 1...."

Contrary to the above, certain contractor QA/QC supervisors and inspectors were not adequately qualified and/or trained to perform safety-related inspection functions. Examples of apparent noncom-l pliance are ide..tified in paragraph h.(2) of the attached report.

This is a Severity Level IV violation (Supplement II).

. 3. 10 CFR 50, Appendix B, Criterion V states in part, " Activities affect-ing quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances ..."

The licensee's Topical Report, CE-1-A, Revision 20, Section 5 states, 1 "The quality assurance actions carried out for design, construction, testing, and operation activities will be described in documented i

instructions, procedures, drawings, specifications, or checklists."

" Activities affecting quality are required by the Edison quality program to be prescribed by documented instructions, procedures or drawings."

i Contrary to the above; the following activities were not controlled by procedures or instructions:

a. On March 30, 1982, it was identified that Hatfield Electric

Company was utilizing a Discrepancy Report System, which was

not referenced or controlled by a procedure, to track and correct discrepancies and nonconforming conditions discovered

during inspections of safety-related equipment.

b. On April 2, 1982, it was identified that Powers-Azco-Pope was utilizing a Fabrication Installation Surveillance System, which was not controlled by a procedure, to track and correct dis-crepancies and nonconforming conditions discovered during in-spections of safety-related equipment.

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Appendix 4

c. On April 9, 1982, it was identified that Hatfield Electric Company procedures did not contain an electrical cable rework

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procedure nor the requirements to calculate electrical cable sidewall pressures prior to pulling cable,

d. On April 7, 1982, it was identified that the Hatfield Electric Company's NCR form contained a section titled " Action to Prevent Recurrence" but there was no direction in the body of Procedure Number 6 for actions to be taken to satisfy this requirement nor does the procedure assign responsibility for this section of the l NCR. l l

This is a Severity Level IV violation (Supplement II). l

4. 10 CFR 50, Appendix B, Criterion XV, states in part, " Measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation."

The licensee's Topical Report, CE-1-A, Revision 20, dated February 17, 1982, Section 15, states in part, " Items involving construction, main-tenance, and modifications which are found nonconforming...will be controlled to prevent their inadverent use or installation."

Contrary to the above:

a. On March 31, 1982, it was identified that three (3) CECO noncon-formance reports (F-634, F-645, and F-682) had been voided rather than closed, with reference to corrective action taken to resolve the nonconformance. By voiding the subject NCRs, the tracking system to verify that the approved disposition has been completed and corrective action to prevent recurrence is negated. Also, the voided NCRs are removed from the trend analysis system.

b. On April 7, 1982, it was identified that three (3) nonconformance reports (98, 99, and 100) had been voided by the Hatfield Electric Company rather than closed, with reference to corrective action taken to resolve the nonconformance. The subject NCRs were voided because an FCR was or would be issued to accept the items as installed. At the time the NCRs were voided, there was no assurance that all the FCRs would be approved. By voiding the NCRs, the tracking system to verify that the proposed disposition was accepted, was negated and the NCRs were removed from the trend analysis system.

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Appendix 5

c. On April 7, 1982, it was identified that the Hatfield Electric Company had improperly closed NCR 168, in that after CECO 4

engineering dispositioned the subject NCR to replace the item, 4 the Hatfield Electric Company closed the NCR without accomplish-i ing the approved disposition. At the present time, there is a nonconforming cable installed, and the tracking system to replace the cable, has been negated.

This is a Severity Level IV violation (Supplement II).

5. 10 CFR 50, Appendix B, Criterion V states, " Activities affecting.

quality shall be prescribed...and shall be accomplished in accordance with these instructions, procedures or drawings."

The licensee's Topical Report, CE-1-A, Revision 20, Section 2.2 commits to comply with the Regulatory Position of Regulatory Guide 1.38, Revision 2, which endorses ANSI N45.2.2-1972. Also Section 5 states, "The quality assurance actions carried out for design, con-struction, testing, and operation activities will be described in documented instructions, procedures, drawings, specifications, or checklists."... " Activities affecting quality are required b-J the Edison quality program to be prescribed by documented instructions, procedures or drawings."

Contrary to the above; the following activities were not accomplished according to procedures or instructions:

a. On April 2, 1982, it was identified that Powers-Azco-Pope was storing rejected material among accepted material in Warehouse No. 4. This is contrary to their Procedure No. FP-3.

b. On April 2, 1982, it was identified that Powers-Azco-Pope had i not tagged a defective torque wrench with a Reject Tag. This is contrary to their Procedure No. FP-11.

c. On March 30, 1982, it was identified that Hatfield Electric i

Company did not tag torque wrenches which were past their cali-

) bration duc date. This is contrary to their Procedure No. 24.

d. On April 5, 1982, of 13 reports reviewed it was identified that 12 nonconformance reports prepared by Powers-Azco-Pope did not address corrective action to prevent recurrence. This is contrary to their Quality Assurance Manual, Section B-8, paragraph B-8.8.2.

e. On April 7, 1982, it was identified that the conditions main-tained by the licensee in Warehouse No. 1 and No. 5 were contrary to CECO Quality Procedure 13-1 and to the requirements of ANSI N45.2.2-1972.

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Appendix 6 This is a Severity Level V violation (Supplement II).

6. 10 CFR 50, Appendix B, Criterion VI, states, " Measures shall be established to control the issuance of documents, such as instruc-tions, procedures, and drawings, including changes thereto, which prescribe all activities affecting quality."

The licensee's Topical Report, CE-1-A, Revision 20, Section 6 states, "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."... "Each receiving of fice or area shall have a controlled method for checking receipt of new or revised documents and assuring that the latest revised document is in use."

Contrary to the above:

a. On April 4, 1982, of 12 drawings reviewed it was identified that one drawing located in the Johnson Controls Incorporated on-site office drawing file was not of the proper revision.

b. On April 7, 1982, of 10 drawings reviewed it was identified that l two drawings located in the Hunter Corporation document station 1-H were not of the proper revision.

This is a Severity Level V violation (Supplement II).

7. 10 CFR 50, Appendix B, Criterion IX, states in part, " Measures shall be established to assure that special processes, including welding...,

are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes,...."

The licensee's Topical Report, CE-1-A, Revision 20, dated February 17, 1982, page 9-1, Revision 15, dated January 2, 1981, Section 9, " Control of Special Processes," third paragraph, states in part, that, " Process control procedures will be used as required by specifications, codes or standards, as applicable...."

The ASME B&PV Code Section III, 1974 Edition, Summer 1974 Addenda, Article NA-4000, Subarticle NA-4411, states in part, that "The program shall include measures to control the issuance and disposi-tion of documents, such as..., instructions, procedures,..., includ-ing changes thereto, which prescribe the activities affecting quality.

These measures shall assure that documents including changes..., and distributed to and used at the location where the prescribed activity is performed."

Appendix 7 Contrary to the above, on April 13, 1982, it was identifed that welding was not being accomplished in accordance with applicable codes, in that, controlled welding procedure specifications with the associated welding parameter sheets were not located at the prescribed activity (welding) in 3 out of 4 locations checked.

This is a Severity Level V violation (Supplement II).

8. 10 CFR 50, Appendix B, Criterion XVII states, " Sufficient records shall be maintained to furnish evidence of activities affecting quality. Consistent with applicable regulatory requirements, the applicant shall establish requirements concerning record retention, such as duration, location, and assigned responsibility."

The licensee's Topical Report, CE-1-A, Revision 20, Section 2.2, commits to the Regulatory Position of Regulatory Guide 1.88, Revision 2, which endorses ANSI N45.2.9-1974.

1 Contrary to the above, on April 7, 1982, it was identified that Midway Industrial Contractors did not provide the security standards established by ANSI N45.2.9-1974, to preclude the entry of unauthorized personnel into the storage area and to guard against larceny and vandalism.

This is a Severity Level V violation (Supplement II).

9. 10 CFR 50, Appendix B, Criterion XVIII states, "A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program.

The licensee's Topical Report CE-1-A, Revision 20, Section 2.2 commits to comply with the Regulatory Position of Regulatory Guide 1.144, Revision 1, which endorses ANSI N45.1.12-1977.

Contrary to the above, on March 29, 1982, it was identified that the audit reports of Commonwealth Edisor. Company, Powers-Azco-Pope, Pittsburgh Testing Laboratory, Johnson Controls, Incorporated, Hunter Corporation, and llatfield Electric Company failed to include the criteria, established in ANSI N45.2.12-1977, regarding persons con-tacted in the audit and a summary of audi; results including an evaluation statement regarding the effectiveness of the quality assurance program elements which were audited.

This is a Severity Level V violation (Supplement II).

Appendix 8 Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written state-ment or explanation in reply, including for each item of noncompliance:

(1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.

Date C. E. Norelius, Director Division of Engineering and Technical l'rograms