ML20062H112
| ML20062H112 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 08/02/1982 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | Gilinsky V NRC COMMISSION (OCM) |
| Shared Package | |
| ML20062H110 | List: |
| References | |
| 4637N, NUDOCS 8208130307 | |
| Download: ML20062H112 (49) | |
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Commonwe:lth Edison
+7 Y) One First National Plaza. Chicago, Illinois y ' Address Rep'y to: Post Othee Box 767 Chicago, Illinois 60690 August 2, 1982 Tne Honorable Victor Gilinsky Commissioner U.S. Nuclear Regulatory Commission Wasnington, DC 20555
Dear Commissioner G111nsky:
The purpose of this submittal is to respond to an inquiry made by you through Mr. James G. Keppler, Regional Administrator (Region III) on July 29, 1982 to Mr. Cordell Reed of Commonwealth Edison.
That inquiry solicited a response to four specific questions related to the LaSalle County Station Hearing, Ventilating and Air Conditioning (HVAC contractor Zack Company.
The Commonwealth Edison respons)es to those questions are contained in the enclosures to this letter.
Snould you have any further questions in this regard, we will resp.ond to them expeditiously.
Very trul your,
L. O. De1 George Director of Nuclear !.icensing Enclosures 4637N T,
8208130307 820811 PDR ADOCK 05000373 P
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RESPONSE TO QUESTION fl REQUESTED BY Commissioner Victor Gilinsky QUESTION:
Why did Commonwealth Edison continue to employ the Zack company after deciding in 1979 to have all of their weld work verified by an outside company?
The primary reasons for continued employment of the Zack Company in 1979 after deciding to have all their weld work verified by an independent insaection company were (1) the necessary quality confidence in the Zac'c welding and welding inspection work could be gained at less coct by utilizing an independent inspection company to verify the acceptability of welding and welding inspection work under the Zack contract while the Zack Company program was being upgraded; and (2) the contractural and financial impacts of rcplacing Zack Company at that time.
A Commonwealth Edison Company (CECO.) Quality Assurance audit which started June 7, 1979, identified three (3) findings.
Two (2) findings related to the welding and welding inspection area.
These specific findings were:
Finding 2.
Zack failed to properly inspect installed work which resulted in acceptance of deficient work.
Finding 3.
Zack failed to maintain a qualified procedure in accordance with AWS Welding code.
At the same time an NRC Region III inspector during a routine I&E inspection, noted deficiencies in the Zack Company welding inspection program and requested additional inspection of Zack field work.
I Specific corrective actions taken in response to the Quality Assurance audit and the I&E inspection were the following:
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- 1) ConAm Inspection Agency was directed to perform a 100%
l welding inspection of all shop and field welds on all j
previously and newly installed HVAC hangers.
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.2) Five (5) Zack Company shop and field weld inspections were retrained and requalified in welding inspection activities.
This retraining and requalification was completed by August 3, 1979.
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- 3) Zack Company was directed to reinspect all hanger shop and field welding previously completed and all non-installed HVAC duct welding.
This work would be done by the Zack QA Department.
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- 4) The one (1) welding procedure not qualified was qualified in accordance with AWS Code.
No work was completed with the procedure until qualification completion.
It was judged in 1979 that the above corrective actions would be sufficient to ensure quality welding and welding inspection performance.
The intent was to force the contractor into establishing an acceptable QC inspection program while continuing productive work.
It should be noted that most of the welding for HVAC work is the most basic structural welding (i.e. fillet welds).
The welding defects found which necessitated corrective actions were not indicative of poor quality welding affecting the structural integrity of a connection but were minor defect" related to lack of attention to detail.(i.e. profile) and in many casas the cosmetic appearance of the welds.
It was eventually found that many of the weld defect problems originated from the type of weld rod being utilized on galvanized steel.
Utilization of a different rod prevented future problems.
Compounding the problem and stating the real reason for overinspection was the discovery that welding inspectors were not finding the defects during their inspections.
Consequently by retraining and requalification of welding inspectors and by providing an overview inspection activity, welding defects could be discovered and repaired.
Additionally, during the reinspection program, when cases resulted where inspectors from Zack Company and ConAm Inspection disagreed on the weld quality, the more conservative approach was always taken and the weld repaired.
Regarding the contractural and financial impacts of replacing Zack Company, our reviews at that time showed that other HVAC contractors having a better QA program might not be available.
Consideration of the cost exp)osure from claims and lawsuits from the then current contractor (Zack as well as the cost of another contractor to perform remedial work; and the probability of ending up with a contractor no better than the one currently on-site, led to the judgment to continue to upgrade Zack while also employing an extensive over-inspection program.
Given the corrective actions and judgments made in 1979, plus the cost impact of replacing a contractor, the decision to retain and upgrade Zack Company was purdent.
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s August 1, 1982 RESPONSE TO QUESTION #2 Requested By Commissioner Victor Gilinsky QUESTION:
Why didn' t Commonwealth Edison monitor the Zack Company's program more closely after they identified serious problems with the Company?
Commonwealth Edison did monitor the Zack Company more closely af ter it identified serious problems with the Zack Comp any.
Moreover, Zack site activities have been closely monitored since mid 1977 because of various indications of inadequate implementation of the Quality Assurance Program plus work performance problems.
As a result many deficienies and problems were identified and, in turn, corrected.
In addition, on four separate occasions Zack site work activities were stopped in the specific areas where deficiencies were detected.
Table 1 identifies those periods during which "Stop Work" orders were in effect for Zsck.
Table 2 details the total number of QA audits and surveillances of' Zack work activities performed since 1976 by Commonwealth Edison.
These audits and surveillances reviewed and/or observed field work and quality control activities for those specific activity areas addressed in the stop work orders, as well as activities controlled by other aspects of the
~The deficiencies identified by the CECO on-site Zack QA Program.
audits of Zack totaled 124 while there were eleven deficiencies identified in the CECO audits of Zack Corporate activities.
4 In addition to Commonwealth Edison Company QA surveillance and audit involvement with Zack Company, specific surveillance and inspection tasks involving Zack construction were assigned to the Conam Inspection Agency at the direction of LaSalle Site Quality Assurance.
Conam performs inspection and testing directly for CECO QA at LaSalle.
The intent of these inspections or re-inspections of Zack, as well as other contractors, is to independently assure that contractor field activities are properly performed in accordance with applicable procedures, standards and design requirements.
The basic approach is that each site contractor has a total entity in that each
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contract includes responsibility for installation, quality control inspection and quality assurance with quality control over -
inspections and quality assurance checks, surveillances and audits i
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2 being done by Commonwealth Edison Company.
For most cases, an over - inspection of from 5 to 10% of the various contractor activities requiring inspection is performed.
Where problems are identified, corrective actions are required of the contractor and the re-inspection activities by Commonwealth Edison are increased to as much as a complete re-inspection where the circumstances warrant.
After it is confirmed that the contractor has undertaken the necessary corrective steps such as developing and implementing procedures, training and qualifying involved personnel and verifying the Quality Control inspection functions are performed acceptably, then the re-inspections performed by the Independent Testing Agency is reduced in step fashion as the results of the re-inspection justify as was done with Conam involving the 100%
re-inspection of Zack' In the case of Zack, the quality control inspections for accepting Zack welding at the site between June 1979 and June 1981 were performed by Conam no matter whether Zack was or was not released to perform its own Quality Control inspections under its contract.
Also, duct work was required to be inspected by Conam prior to being released for installation in i
the building between April 1980 and May 1982.
Deficiencie s identified through inspections were covered by non-conformance i
reports (NCR) for each affected hanger and otherwise for each other deficient case.
All seismic and safety-related hangers were treated as suspect and were inspected.
Zack Quality Control (QC) inspected each hanger and after Zack QC's acceptance, Conam
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repeated the complete inspection for acceptability which included inspection of all welds of the hangers.
Any deficient welds identified by Conam were reported to Zack, corrected by Zack, inspected by Zack QC and then inspected by Conam.
Conam's 100%
re-inspection included inspection of welds for placement and quality and for location of the hanger.
Also, configuration checks on a random basis were made.
In this period, most of the control room HVAC system was inspected by Conam after being inspected by Zack.
Finally, system walkdown inspections were initiated by Zack in early 1982 to check final acceptability.
As for other HVAC equipment supplied by Commonwealth Edison, it was receipt inspected by Commonwealth Edison and again receipt inspected by Zack when issued to them.
Table 3 is included to detail, in a summary fashion, Conam coverage of the Zack on-site installation activitie s.
Upon notification by the Zack Company on September 25, 1981 of the possible 50.55(e) report issue with respect to surveillance and monitoring supplier material certification,(CECO) were intensifLed and l
activities by Quality Assurance directed toward this
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ecific concern at the Zack corporate headquarters.
Between sp/25/S1 and 4/15/82 three surveillances and two audits were 9
performed by CECO Quality Assurance to assess the nature and scope of the problem.
In February 1982, at the direction of the Commonwealth Edison Quality Assurance Manager, a Special Audit was performed to investigate the conditions verbally reported to him by phone by Ron Perry, a Zack employee, as well ss other aspects of the Zack Program.
In summary, the record shows that Commonwealth Edison Company has had continuous and comprehensive involvement with the Zack work activitie s and the implementation of its Quality Assurance Program to ensure the work was being done correctly for the LaSalle Site.
This is further demonstrated by the use of Conam Quality Control Inspectors to augment on-site Edison Quality Assurance activitie s.
Also, after identification of problems at the Zack corporate headquarters in late 1981, additional monitoring of Zack was performed to search for any other possible problems and to ensure corrective actions were completed.
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Table 1 "Stop Work" Actions Imposed on Zack Company LaSalle County Station Date Initiated Date Removed Program Deficiency 7/22/77 9/27/77 (all activities Welder-Qualification, Q.C.
except Welding) training 10/11/77 (Welding)
Program design control, Q.C.
inspection & inspection documentation, and misc.
program deficiencies.
6/25/79 7/25/79 (Partial)
Unaccepteble Q.C. inspection 8/06/79 at LaSalle 4/02/80 6/21/80 Unqualified Q.C. inspectors at Fab Shop in Chicago.
On-site hold point established for receipt inspection of HVAC assemblies.
8/06/80 10/20/80 Design Control, Q.C.
Inspections, and
" Safety-Related Welding l
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Table 2 Commonwealth Edison Company Q. A. Audits and Surveillances of the Zack Company Surveillances Year Audits Performed Performed 1976 1
1 1977 4
17 1978 5
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1979 8
35 1980 9
82 1981 6
83 1982 (6 months) 4 57
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l TABLE 3 CONAM INSPECTION AGENCY COVERAGE OF ZACK COMPANY INSTALLATION ACTIVITIES AT THE LASALLE SITE ACTIVITY DURATION General Inspection of Zack Field 2/24/78 - 6/24/79 Activities (17 reports on file) 100% Re-inspection of future 6/25/79 - 6/07/81 and past Zack " Safety-Related welding on-site. (Hangers) 50% re-inspection of Zack 6/08/81 - 6/21/81 on-site welding.
25% re-inspection of Zack 6/22/81 - 7/05/81 on-site welding 10% re-inspection of Zack 7/06/81 - Present on-site welding 100% inspection of Zack 4/02/80 - 5/10/82 ductwork entering the building and being erected at LaSalle l
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RESPONSE TO QUESTION #3 Requested By Commissioner Victor Gilinsky QUESTION:
What was the exact basis for closing out Zack-related items of nonconformance including the 2400 nonconformance reports in 1979 and the 50.55e letter?
The exact basis for closing out Zack-telated items of nonconformance (NCRs) and the reportable construction deficiency (50.55(e)) is the same basis utilized for all nuclear work vendors, contractors and utilities.
Appendix B, 10 CFR 50, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, Criterion XV and XVI establish the basic programatic requirements for resolving items of nonconformance.
In the case of Zack Company, NCRs were dispositioned by either review and acceptance rejection, repair or rework of the nonconforming condition.
Zack Company has generated approximately 2400 field NCRs related to the two LaSalle County units since the start of HVAC work in 1976.
The majority of these NCRs have been generated since 1979 as the method of recording the Zack reinspection effort (described in response to Question (2)) for all previously installed safety related HVAC work.
This reinspection effort was uncertaken as a response to inadequate quality control inspection by Zack.
The reinspection effort encompassed weld accepability and adherence to design details per applicable Sargent & Lundy Engineers drawings.
In the case of newly installed work after 1979, Zack NCRs were utilized to document and disposition certain quality control inspections.
The above reasons would account for what may seem to be a large number of NCRs.
Once an NCR was written describing the nonconforming condition, it required dispositioning.
Many of the Zack NCRs were dispositioned.by repairing and/or reworking the HVAC work to its specification and drawing requirements.
Repairs and rework were done on welding, configuration of members and orientation of members.
Thus, the basis for closing the NCR was completion of work in compliance with specifications and drawings.
The balance of the NCRs were dispositioned by CECO./Sargent & Lundy Engineers acceptance of the work as built.
For these NCRs, Sargent & Lundy Engineers established a special procedure to review the as-built HVAC work and accept the as-built HVAC work after doing engineering calculations and/or exercising engineering judgment.
Thus, the bases for closing the NCR was an engineering review against the Final Safety Analysis Report requirements.
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. B. Establishment that materials were not used in safety related areas or applications.
C. Establishment that a certificate of conformance for the material is acceptable in lieu of a certified material test report for the specific material application.
Most of the materials required for this HVAC work are commercial grade.
D. Review of intent of specification requirements to ascertain whether Zack was being overly conservative in interpreting specification material documentation requirements.
Where necessary engineering calculations were performed to establish the engineering judgements utilized in dispositioning the CECO. NCRs.
In summary, correct procedures were followed to disposition all Zack-related items of nonconformance.
The basis utilized is in compliance with the necessary regulatory standards.
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RESPONSE TO QUESTIONS #4, PART 1 Requested By Commissioner Victor Gilinsky QUESTION:
Were these closed out on the basis of documents which are now known to be falsified or otherwise thought to be invalid?
1 The 2400 field generated NCRs were not related to material (documen-tation) deficiencies, and as such potentially falsified or invalid records related to those NRCs are not in question.
With regard to the 50.55(e) report, the September 25, 1981 Zack letter which initially notified CECO of material documentation inconsistencies categorized the inconsistencies into four areas.
1.
Material certifications with incomplete information.
2.
Material certifications with technical inaccuracies.
3.
. Material certifications with possible unauthorized and improper modifications.
4.
Possible person / persons improperly modifying material certifications.
Categories 3 and 4 deal with possible falsification of records.
Zack Company committed as part of the corrective action for test reports suspected of being modified to verify them with the respective suppliers and to investigate those individual (s) implicated or suspected of imporperly modifying supplier's test reports with any evidence obtained to be forwarded to the Zack Company President for appropriate disciplinary action.
The Zack Company interim report of October 9, 1981 stated that 374 l
of 445 LaSalle County purchase orders had been reviewed.
In this l
October 9, 1981 report, the number of purchase orders involving possible falsification was reported as follows:
Possible Falsification Category Description No. Packages Alteration - Apparent alteration of certification 11 by typed or handwritten additions.
Stickers - Gummed labels applied to certification 6
cover sheets.
These typed and signed to indicate compliance with ASTM standards authenticity of the signatures is questionable.
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. Attachment 1 details the specific possible falsification purchase orders.. On October 23, 1981, in an updated interim report Zack Company transmitted a tabulation of purchase orders reviewed and categorization of discrepancies found.
(Attachment 2)
The number of possible falsification purchase orders had been reduced to 11 alterations and 3 stickers.
Zack Company stated the problem of the purchase orders with stickers on them was given an extensive investigation.
This investigation determined that person (s) within the Zack Company orgianization were responsible for the addition of gummed labels to the material certifications.
Zack took into consideration in their evaluation of this item that individual (s) involved did not believe that the addition of information (i.e., ASTM designated number and year) misrepresented the actual condition of the material.
The action, while misguided, was done to expedite the release of material that had acceptable chemical and physical properties while the corrected material certifications were being obtained.
The Zack Company also assumed part of the responsibility for allowing the responsible person (s) to be put in a situation that may have appeared to encourage this type of action or at least did not have the necessary checks and balances which would have prevented the occurrence.
The responsible individual (s) were identified and given demotions in position and documented letters to their personnel files.
They were also advised that any further action of this type would result in immediate dismissal.
Of the six (6) certifications originally identified to have had stickers added, a follow-up by the same individual (s) involved had resulted in corrected certifications for all but three (3) of the purchase orders.
A continued effort was being made to obtain corrected certifications for the remaining purchase orders.
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Zack Company also stated that material certifications observed with more than one type-face used, white out, or handwritten modifica-tions had been categorized as altered.
Their investigation had not determined yet where or when all of these alterations occurred, though enough information was obtained to indicate that person (s) from the Zack Company were involved.
The responsible individual (s) were subsequently identified and dealt with as stated above for stickers.
The actual alterations while serious from a programatic view, did not effect the structural integrity of the materials and corrected copies would be obtained from the respective suppliers.
On February 12, 1982, Mr. Albert T. Howard, a principal in the GAP letter to Chairman Palladino, provided an updated report to CECO.
Attachment #3 is the cover letter to this report.
Included in this report is a revised Purchase Order Review and Categorization Summary l
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, 2 (Attachment #4) and a Definitions of Summary Listing (Attachment
$5).
Tne information included in the February 12, 1982, submittal indicated that all the possible falsification purchase orders were not in the packages were correct and acceptable.
Attachments #6 and
- 7 are listings of the open discrepant packages as of January 15, 1982.
Only 4 purchase orders of the original possible falsification purchase orders remained on the open discrepant listing.
Thus, 13 of the original questionable purchase orders were deemed acceptable by obtaining corrected suppliers certifications.
Additional detailed information included in the February 12, 1982 submittal on the 4 remaining possible purchase orders taakes no mention of possible. falsification.
It would appear the shadow of falsification had been removed from the original questionable purchase orders, as atteste,d by Mr. Howard himself.
Thus, the evidence estabilishes that Zack NCRs and CECO NCRs were not closed out on the basis of documents which were known to be falsified or otherwise thought to be invalid.
Zack Company investigated the possible falsification and took disciplinary actions.
They obtained corrected documents from their suppliers prior to closing out a NCR.
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QUESTION #4 - ATTACHMENT 1 Possible Falsification Purchase Orders Alterations P.O. No.
Description of Discrepancy 641 ASTM year has different type 855 North Star Steel - handwritten in information 743 Cert altered to indicate ASTM to year 914 ASTM year had different type 643 ASTM year had different type 1274 Jones & Laughlin Steel - ASTM year altered-604 Youngstown Steel - handwritten in information 679 Reliable Galvanizing - P.O. i altered
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947 U.S. Steel - handwritten in information 1029' Alterations on galvanizing cert 1241 ASTM year added to cert initialed RSW Stickers P.O. No.
Description of Discrepancy 739 Sticker added to cert 795 Additional cert in package has sticker 742 Sticker added to cert 796 Additional cert in package has sticker 738 Sticker added to cert 740 Additional cert in package has sticker l
Only three (3) C-739, 742 and 738 require resolution 4636N l
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QUESTION #4 - ATTACHMENT 2 PURCHASE ORDER REVIEW AND CATEGORIZATION
SUMMARY
CATEGORY No. P.O.
PURCHASE ORDER /CMTR PKGS REVIEWED
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405 PACKAGES CORRECT & ACCEPTABLE
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109 CLERICAL ERRORS 152 SIGNATURE MISSING 9
SIGNATURE ERRORS-3
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CHEM / MECH TEST DATA 10 U.S. STEEL LETTER 6
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14 NOT GOOD FOR LASALLE 10 VRONG STANDARD REFERENCED 5
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40 ALTERATIONS 11 STICKERS 3
MISCELLANEOUS 7
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4401 WESTERN e FLINT MICHIGAN CC506
- 313/736 2040
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'4 OUESTION #4 - Attachment #3 e
Albert T. Howard Letter to CECO CUSTOM METAL FAB.RICATION February 12, 1982 HVAC Contract 6J-2590 "Conunonwealth Edison Co.
LaSalle County Nuclear Station Rural Route $1, Box 240 Marseilles, IL 61341 Attn:
Mr. Richard Cosaro Project Manager Ref:
The Zack Company letter dated October 23, 1981
Subject:
Potential 10CFR50.55(e)
Material Deficiency Report Gentlemen; Attached is an updated (3anuary 15, 1982) report on the status of the material certifications identified in the above referenced letter. As indicated by the report, a si:;nificant increase in the number of corrected purchase order packages has been accomplished and a number of the remaining purchase orders indicated as still dise,repant have only one or two items to be corrected. Therefore, the number of actual material certifications acceptable is in excess of the percent indicated in the report.
It is The Zack Company's opinion at this time that all problems still existing could be corrected with further vendor / subcontractor persuance and those items not resolved through this. same endeavor might be resolve'd with engineering disposition.
f With this interim report The Zack Company'would likp to assure you of its con-f l-tinued e(forts in the above direction.
Should you have any questions or, problems, please contact me.
l Most sincerely, I
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ert T. Howard l,
ality Assurance Documentation Supervisor ATH/dm
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- FOUNDED TO SOLVE THE UNIQUE METAL FABRIOATION NEE *DS OF INDUSTRY *
- DEDICA.TED TO CLEANING AND CUSTOMIZING. THE AIR OF THE WORLD.
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QUESTION 44 - ATTACHMENT 4 Albert T. Howard Revised Purchase Order Review and Categorization Summary 1.
Packages reviead............................ 405 2.
Iackages correct ard acceptable.............. 237 3.
Discrepant packages.......................... 168 4.
No material certs......................'......
33 S.
No phys / chem test data..,.................... 27
- 6. Wrong standard referenced....................
19 7.
No stardard referenced....................... 10
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Material does not meet spec...................,3 9.
Clerical errors.............................. 67
- 10. Listed by site - not located.................. 9 l
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QUESTION 84 - ATTACHMENT #5_
Albert T. Howard DEFINITIONS OF SLEM USTING 1.
Packages Reviewed
'D11s item lists the total nunber of packages that were reviewed for this regi. only. Iti.inclu5es the
.,nunber of purchase orders that the site have. It does not however, include t}nse purchase orders generated after. November 10, 1981.
2'.
Packages wuwt and acceptable
'Riis includes the total ntnbar of P.O./
O!rRs that the Doctnant Team deem correct / acceptable through January 15, 1982.
3.
Discr@ ant Packages - Includes the total nunber of P.O./CMTRs not acceptable I for the reasons listed in nunbers four (4) through nine (9).
4.
No 15terial Certs
'Ihis includes those packages that have no certification data, i.e., certified test material / certificate of con-fozmance (eqTliance).
5.
Ib phys / chem test data - 2his ntuber indicates the total of packages that are missing part or all of O!rR data.
6.
Wrcng standard ret'erenced
'Ihis includes the ntuber of packages dereI the standard referenced in the certification is contra _y to the contract specification / procurement document'.
7.
No standard referenced - This includes the number of packages in dich there was no standard referenced in the procurstent and docu-i ment / material certification.
8.
12terial does not meet Spec. - This includes those P.O. packages that material does not meet the standard r= 4Fied.
9.
Clerical errors - This group includes a variety of discrepancies (minor) that are clerical in rature; i.e., no AssM, no ASWyr., No AS W yr. designa' tion, typographical errors, etc.
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QUESTION $4 - ATTACHMENT #6 LASALLECOUNTYDISCREPANTTURCHASEORDEkS (Open)
P.O. No. C-451 668 4205 9417
'17103
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452 683 4216 9419 454 696 4268 9420 455 704 4270 9421' Sbtal: 103 -
,465 714 4285 9422 472 722 4286 9427 508 736 4289 9429 519 764 4294 9442 520 798 4312 9444
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522 804 4340 9450 542 852 5759 9455 549 893 5776 9501 560 SD9 6813 9505 567 954 9242 9506 572.
956 9244 9762 597 1329 9251 9636.
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9401 10784
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599 G3111 602 4004 9402 11237 603 4023 9403 11271,
616 4048 9411 11544 617 4052 9412 12206
'627 4080 9413 12285 6'30 4081 9414 13246 639 4105 9415 13912 651 4137 9416 16429 652 4157 g
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. QUESTION #4
'AtticchmInt 97 ALL SITES - DISCREPANT PURCHASE ORDERS (9 Pen)
P.O. No. C-456 762 1255
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,797 4055 464
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468 802 9247 586 803 11503 601
- 806 12281 h
820 12303 606 821 12304 609 822 12434 611 823 13238-632 827 13255 633 830 13268 64'i 839 13293 644 851 h
'Ibtal: 65 662 663 888 665 912 684 917
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l August 1, 1982 RESPONSE TO QUESTION #4, PART 2
' Requested By Commissioner Victor Gilinsky QUESTION:
Please describe what inspections were made by Commonwealth Edison of the Zack Company's actual material certification.
Commonwealth Edison inspected actual material certification of HVAC equipment and materials in two ways.
First, documentation associated with the certification of materials supplied by Zack and
~
used in the fabrication and installation of HVAC systems was inspected by CECO site Q.A. during audits and surveillances of the Zack site and corporate office activities.
Second, major components and equipment installed in the HVAC system were purchased by Edison directly from equipment manufacturers other than Zack.
Documentation supporting the equipment certification is sent directly to the A/E, Sargent & Lundy, for a review.
Af ter review and acceptance by Sargent and Lundy, the documentation is forwarded to CECO sitelQ.A. for further review and final acceptance.
1)
Audits and Surveillances of Zack Documentation During the period January,19P"> thru July 1982, Commonwealth Edison Q.A. conducted eleven audits and four surveillances which included questions which were directed specifically at inspecting material certifications to ensure acceptability..The following tables show the audits and surveillances which were conducted and the number of mater'ial certification documents which were reviewed.
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. C.E.Co. Audits No. of Questions Number of Closure dates asked concerning Certifications of all items Audit No.
Material Certs.
Reviewed found deficient 1980-6 (on-site) 1 5
6-17-80 1980-19 1
10 10-08-80 1980-62 4
18 4-04-81 1980-85 1
6 1-06-81 1980-101 3
11 2-05-81 Total:
3U 1981-18 (off-site) 4 80 4-29-81 1981-32 (on-site) 1 13 7-02-81 1981-53 1
9 11-28-81 1981-64 1
9 3-11-82 Total:
1TT 1982-45 (off-site) 1 28 6-10-82 1982-49 3
17 7-16-82 Total:
45
~-
C.E.Co. Surveillances The following tabulation is of the various certifications that were documented as part of the objective evidence taken.during these surveillances:
Surveillance Number of Certifications Reviewed Date of Closure Report Number (Documented in Surveillances) for Deficient Items 1-81-661 15 10-19-81 1-82-50 8
3-15-82 1-82-69 1
2-09-82 1-82-225 Certificates associated 4-27-82 with 45NCR's.
2)
Architect Engineer Review of HVAC Documentation The following table lists the major equipment and components which CECO purchased directly from manufacturers.
Sargent and Lundy conducted a 100% review of material certification documentation for these specifications as to being acceptable.
-3 HVAC Equipment Type of Equipment Specification Equipment Supplied J-2581 Unit Heaters J-2582 Heat Exchanger Coils & Cabinets J-2483 Atmospheric Clean-up Filters J-2584 Isolation Dampers J-2585 Ventilation Fans J-2586 Air Handling Units J-2587 Evaporative Coolers J-2588 Refrigeration Units
- J-2590 (Zack)
Ductwork (Misc. Hardware)
- J-2591 (MCC Powers).
Hvac Controls J-2960 Electrical Heaters J-2975 Vent Stack Air Flow Monitors
- Receiving inspection and document review responsibility by' contractor on-site 0419Q
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.O Q.P. FORM 16-1 4
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~DATE 8-4-81 h
. A J T C 0S ED QUALITY AGGURANCE MANUAL 3
l AUDIT REPORT W..
j 1-82-49 QA SUPERVISOR 7[ g,/,t DATE i
/
Type Audit:
/ X / Program Audit
/
/ Product Inspection roinT.
/
/ Records
/
/Specini Mr. Martin Skates, Quality Assurance Manager To:
Visit Date 3/22-23/82 Report.Date 3-29-82 Project _LaSalle System HVAC
_ Component Identification N/A Material Description N/A Vendor Zack Co.
Location Cicero, IL Subcontractor N/A Location N/A Contacts' Martin Skates, Rav Basiaga I,i
(
P.O. No.
Spec. No.
J-2590 Recommended Inspections:
6 mos 3.mos 1 mo' Other: As scheduled Please respond to the deficiencies identified in Exhibit A Notes:
by May 5, 1982.
Exhibit'B has a list of the personnel in attendance for the entrance and exit meeting.
The response must include action takin to correct.the deficiencies, action taken to prevent reoccurrence, and date corrective action will be implemented.
Please direct response to George Marcus, Director.
of Quality Assurance and a copy to Robert E. Waninski.
Auditor M / E Date 3 - M-S'i _
Reviewed N 'Date bb cc:
Manager of QA Director of OA (Engr-Constr)
Site Constr. Supt. My;e3 a
%ffhn2 Si uality Assurance (i
Project Manager gqTMiUC4pr:ep3;g.
Pro.tect Engineering Mgr.
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i AUDIT OF ZACK CO. CORPORATE BY COMM0 WEALTH EDISON QUALITY ASSURANCE i
AUDIT # 1-82-49 The Commonwealth Edison ' Quality Assurance Department conducted it's scheduled off-site audit.of Zack Company - Corporate Office - on March 22nd and 23rd, 1982.
The purpose of the audit was to. determine if Zack Company had been implementing the requirements of their approved Quality Assurance Program, latest revision dated 3-31-80.
The audit checklist consisted of 17 questions, of which-it was determined that two. deficiencies existed.
The first deficiency, The second-Finding #1, involves control of revised documentation.
deficiency, observation $1, address protection of quality assurance records.
It should be noted that of the other areas'udited material a
3 traceability and material control activities appear to be managed -
Another area worthy of being mentioned, is the prepardtior quite wel,l.
of documentation such that the Certificate of Conformance may be, #
Although two deficiencies have been noted, Zack Company's issued.
overall Quality Assurance Program s.ppears to be adequately implemented.
Zack Company'is requested to respond to the deficiency by Mak In the response, please. indicate the actions taken to 5, 1982.
prevent reocurrence and the date these steps will be. implemented,
.in addition to the actions' taken to correct the deficiencies.
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AUDIT #1-82-49 EXHIBIT A 8,LO, SED,PER,
+ g c,c g g NO lt.2.&v tr FINDING #1 g
7 tt I' Contrary to Zack's Quality Assurance Manual, Section 4, the distfibut.
control system does not reclaim and destroy, obsolete documents,
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drawings, and specifications.
i, 1
Discussion It was determined that superceded drawings are not reclaimed from the field group when revised drawings are issued.
The' field representative signs a Transmittal Notice for Engineering Documents, thereby assuring receipt, and supposedly files the superceded do.cumen at the site.
This activity is also contrary to procedure IpF-12 para. 4.2, which supports the Quality Assurance Manual's commitment to reclaim and destroy void documents.
I OBSERVATION #1 Zack Company record storage facilities do not protect contents from possible destruction by causes such as fire, etc.
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Discus'sion
~
It was noted that only a portion of Quality Asgurance records are maintained in fire-proof cabinets rated at 350 F for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
These records include items such as CMTR's, Certificates of Conformartce, and welder qualifications.
Drawings and shop travellers are kept in non-fireproof cabinets.
No' sprinkler systems were noted in any of the storage areas.
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CLOSED PER
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EXHIBIT 3 Zack Audi.t 3-22,23 Entrance Meeting Lead kuditor CECO R. E. Waninski Zack QA Manager Martin Skates Zack QA Eng.
Ray Basiaga
~Zack VP/Proj. Manager Carl L. Eichstaedt Jr.
Exit Meeting PresLdent/0wner
'Zack Christine DeZutel Lead Auditor i;
CECO R. E.'Waninski Zack QA Manager Martin Skates Zack QA Eng.
Ray Basiaga VP/Proj. Mgr.
Zack Carl. L. Eichstaedt Jr.
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2601 N. 21st Rd.
Maneilles. Illinois 61341 815 357 6761 May 13, 1982 M# 5809 Mr. M. L. Skates-The Zack Company 4600 W. 12th Place Chicago, IL 60650 SU3 JECT:
CECO Audit # 1-82-49
Dear Sir:
~
Upon review of your response to the above indicated audit (Zack Transmittal #345), we find your corrective action acceptable to the indicated deficiencies.
Your cooperation throughout the course of the audit has been very appreciated.
I.'
R. E. Vaninski Lead Auditor LaSal e. County Station N.
s G.'F. Marcus Director of Eng./Const.
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T. E. Quaka/Q.A. File
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Hemo to File Action taken to correct. deficiencies and prevent recurrence is deemed This statement sufficient such that this audit may be considered closed.
is based on the following:
OBSERVATION #1 are sufficient record protection until the proposed s installed.
FINDING # 1 y /
The QA General Office has reviewed and accepted the manual change.
The audit of this area noted that the activity was in conformance except This for the requirement to' reclaim 5 destroy obsolete documents.
requirement has ben eliminated in the manual revision.
ka-h*IIaninski g-l,*
R. E.
Lead Auditor f? cc R.~m 6 /c/r,.
R. A. Braun Q. A. Supervisor LaSalle County Station REh'/ccc
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T. E. Quaka/Q A. File cc:
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Commonncaith, hy Edl..n Cempany QUALITY ADOURANCE MANUAL oA i
og 10 SED AUDIT REPORT
..#1.8'
,45 l
9 SUPERVLSOR Type Audit:
O Program Audit
/
/Prodt cgnsp igPgnt j_
C Records
/ ^/Special To:
Project _ LaSalle Visit Date 2/18-19/82 Report Date 2-26-82 HVAC
__ Component Identification N/A System N/A Material Description Zack Company Location Cicero, Illinois Vendor N/A Location N/A Subcontractor Contcets M. L. Skates - 0.A. Manaear J-2590
(
P.O. No.
186466 Spec. No.
,}
Recommended Inspections:
6 mos 3.mos 1 mo As Scheduled Other:
Please respond co the deficiencies noted in Exhibit A Notes:
by 3/19/82.
Response must include corrective action taken and action taken to prevent recurrence.
M A (3e
_Date 2./tt./e~L Lead Auditor Este # 47(o -$ h Auditor M u.c, h Revieue W(
EL._Date :3/.M/h-Director of QA (Engr-Constr) cc:
Manager of QA Site Constr. Supt. ermProft x
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ngihFeMhg Site Quality Assurance J.-2.m ' W Q D b M T i n n i;)
34aHa'geW6 w tatFC6ns1di?.V Project Manager Project Engineering Mgr.
Manager of Projects
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AUDIT d 1-82-45 7
- ACK COMPANY Z
. CONDUCTED BY COMMONWEALTH EDISON QUALITY ASSURANCE' On February 18th thru 19th, ~ 1982, the Commonwealth Edison Quality Assurance Department conducted a Special Audit of the Zack Company located in Cicero Illinois.
The intent and purpose of this Special Audit was to investigate quality related concerns that were brought to CECO Q.A.'s attention I
during the second week of February 1982.
These concerns-were in the areas of:
(1)
Lead Auditor Qualifications (2)
Material Traceability (3)
Zack Procurement (4)
NCR Issuance (5)
Records Storage & Filing (6)
Documentation Alteration By Zack Company g
The audit checklist consisted of 7 questions with the checklist scope covering the above six areas.
The audit resulted in 2 findings.
Die first finding is in the area of Q.A. Manager annual auditor evaluation and Auditor / Lead Auditor The second deficiency involves n.aterial traceability records keeping.
for a section of HVAC duct.
Details concerning these findings are contained in Exhibit A of this report.-
Exhibit B identifies those individuals who were in attendance at the entrance and exit meetings.
Prior to the exit meeting, the individual who initially raised the quality concerns was contacted and interviewed by the Lead He was provided with the opportunity to review the checklist Auditor.
and the audit results.
Additionally he was asked if he had any concerns to add to those covered by'this audit.
He indicated'that he had no He was invited to attend the exit by both additional concerns.
Zack and CECO but chost not to attend, Based on the results of the audit and the interview conducted f
during the course of the audit, it is the opinion of the audit team L
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e 2-that no new serious concerns exist with respect to the implementation of the Zack Company Quality Assurance Program within the scope of the audit checklist.
The serious deficiencies that do exist have been adequately identified and are the subject of the 50.55E (#81-08) condition reported to the NRC on September 28, 1981.
Zack is actively engaged in resolving this matter by appropriate corrective i
action.
With respect to the 2 deficiencies noted in Exhibit A, Zack Company is requested to respond on or before March 19, 1982 indicating the corrective actions taken and actions taken to prevent recurrence.
Please direct your response to Mr. T. E. Quaka, Quali.ty Assurance Superintendent, LaSalle County Station.
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E_XUIBIT A
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ZACK COMPANY AUDIT #1-82-45 ctObED PER_
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~~
FINDING #1 (Question 1) (QAM - Section 19)
W J /toftt Contrary to Zack procedure PQCP-17, Rev. 0 (7-25-80), AuG1 tor / Lead.
Auditor Qualification and certification records are not adequately maintained at their Cicero facility.
This deficiency manifests itself in several ways as indicated below:
Discussion:
Item A - Zack procedure requires annaal evaluation of Auditor and Lead Auditor Certification (para. 6.5.1).
Review of the current status of Zack auditors / lead auditors indicates that H. Geyer was certified as Lead Auditor on 8-4-80.
Paragraph 6.4.4 states that certification is valid for a period of one year.'
Evaluation of Mr. Ceyer's Lead Auditor status by the Zack Q.A. Manager should have occurred on or before 8-4-81 and PQCP-17 requires documentation of this evaluation on form ZQF-37.
No evidence of this evaluation was available for review.
Item B - Zack procedure recuires auditor candidates to perform a 1,-
minimum of one aucit as an acting auditor under the supervision of a certified lead auditor per paragraph 6.3.1.2 and this l
participation is to be documented on form ZQF-37.
Additionally, auditors candidates are required to demonstrate a minimum of six points based on education, experience, professional competance, and the rights of Management (para. 6.2.2T Additionally the auditors training record is requiret be documented on form ZQF-22.
Review of Zack's Auditor / Lead Auditor records indicates that E. J. Bodley performed an audit on 2-15-82.
No documented l
evidence was available at the time of the audit to indicate that Mr. Bodley receied his required training and that he l
will score the six point minimum.
It is fully realized that only several days had passed between the 2-15-82 audit and audit #1-82-45 but Mr. Bodley's auditor qualification record folder is empty.
Zack is therefore requested to submit copies of form ZQF-22, l
ZQF-37 and ZQF-36 for E. J. Bodley after auditor certification occurs.
Item C - The audit team's overall impression of the Zack Auditor / Lead t
Auditor Qualification records is that of confusion.
Presently there are but 6 individuals certified at Auditor or 1
Lead Auditor.
There is a lack of consistancy in maintenance of these documents and the documents themselves are in some ways redundant in their content.
Some information unnecessarily appears several times on different forms while
s,
(
Item C - Con't:
j j
other information must be inferred by review of all auditor / lead auditor activities.
It would be in Auditor /pany's best interest that their procedure for Zack Com Lead Auditor qualification be reviewed in an attempt to streamline the documentation recuirements.
FINDING #2 - Question #2 Contrary to Zack's Quality Assurance Manual Section 9, Zack's material control program failed to provide sufficient traceability a1 E6fd) FBa tr e fabrication of HVAC components in all to the materi C
Cases.
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Discussion:
No.JA9ct
$W..Yt.0b L It was found unac in un p articular case, Traveler #F-515 identified the fact that fitting No. 4 was voided and replaced by fitting No. 4A on Traveler #F-1904 per Zack's Minor Modification form M/M #104 A
review of this traveler #F-1904 showed the section of ductwork but failed to provide any indication of'the material used.
Upon investigatin this matter further in the field, it was determined that the fitting was not fabricated.
Field verification showed another piece next to it had been changed instead.
4 Most of the problems which resulted in this case, were the results of
^
some confusion which existed due to numbering errors.
The M/M #104 identified the required change to involve piece No. 4 on drawing M-1361-2 by requested a new piece 4A.
In reality, the M/M should have addressed fitting No. 22 which was eventually changed.
Zack's drafting department changed piece No. 4 to 4A but should have revised piece No. 22 to 22A, To further confuse the issue, piece 22A was field fabricated without an apparent traveler to identify the material used.
Per Zack's site Project Manager, the fitting in question was made from all stock material.
Fitting No. 4 on traveler #F-515 was verified to be in the field and found acceptable as is.
Zack's practice of field fabricating components without the required documentation is unacceptable.
Zack should investigate the matter further to determine if this was an isolated instance.
For all cases found, nonconformances should be written to properly disposition the matter.
Finally, Zack's segmented drawings should be revised to show the following:
Drawing #
Fitting Involved 1361-2 4A should be changed ba.ck to 4 1361-2 22 should be changed to 22A with the proper notation concerning M/M 104 placed on the correct traveler.
Zack's site QC and Project Managers were informed of this finding and were in agreement with its results.
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'f LaSalle County Nuclear Stati:n Rural Route #1 ^ Box 220 2601 N. 21st Rd.
Marseilles, Illinois 61341
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815 357 6761 i
April 12, 1982 QAL #5742 Mr. Martin L. Skates The Zack Company 4600 W. 12th Place Cicero, IL 60650
SUBJECT:
CECO Audit 1-82-45 Response Dated 3-25-82 Mr. Skates:
Response to our Audit 1-82-45 was received 3-30-82 and based on review of the information submitted, the following items must be clarified prior to closure of this audit:
FINDING #1 The documents submitted adequately address those items particular to Messrs. Geyer and Bodley bot no indication j ac' tion ta_k_en to prevent recurrence was included in the Zack recponse.
Review of the information included in the response FINDING #2~
is sufficient to explain the specific case discovered k_'
during the course of the audit, but the question of whether this was an isolated case was not addressed.
In addition, no actions taken to prevent recurrence are indicated in your response.
l Please submit the above information and/or clarifications on or before 4/26/82.
If you have any questions concerning this matter please contact me (815) 357-6761, extension 573.
f A.B _ +/,/n
- 3. A. Braun Q. A.. Supervisor RAB/ccc LaSalle County Station ec:
.F. Marcus
. E. Quaka/Q. A. File 7
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> j welder #34. Traveler F515 Traveler 1564 will be mod 5 instead of PC #22. 6.
- 4 instead of PC #4A.
th 7. 9 traveler F1904 will be voided. Traveler F515, PC #22 shall be voided. %.O h s developed to replace R1104 and to reflect above c ange. 3% m PC #22A. 8 '7 j QAL. 5889 Fage 2 QA Review: Finding # 1 The documents submitted adequately address those items particular to Messrs. Geyer and Bodley but no indication of action taken to prevent recurrence was included in the Zack response. Finding #2 the information included in the response is sufficient to Review of explain the specific case discovered during the course of the audit, but the question of whether this was an isolated case was not addressed. In addition, no actions taken to prevent recurrence are indicated in your ~' response. Contractor Response (Second): Finding #1 In order to prevent recurrence of the deficiency noted during the above referenced audit, the Q.A. department is developing a personnel matrix. This matrix will include all pertinent information needed to maintain qualifications and also provide an easy reference of,an personnel individual's current qualifications and necessary additional requirements to upgrade qualifications. Contractor Response (Second): Finding #2 A review of Travelers 'was conducted in. conjunction with pre,paration of Travelers for turnover documentation. No other evidence of this type of found. The likelihood of recurrence of this type of deficiency was problem is minimized by the small amount of work remaining at LaSalle. The Zack Company site Q.C. Manager has been instructed to review all We feel that Travelers used by field fabrication to verify completeness. under the circumstances this is sufficient to prevent recurrence. QA Review (Second): Finding #1 Mr. Skates was contacted by phone and requested to send a copy of referenced personnel matrix. Contractor Response (Third): Finding #1 Flease find' attached a copy of Auditor and Q.C.I. Matrix per your request in response to CECO Audit 1-82-45. Final QA Review (Third): Finding #1 Based on the above action to prevent recurrence, the Auditor and QCI Matrix, and the monthly review committed to in said matrix, CECO feels that Zack has adequately addressed this Finding and that recurrences will be eliminated if this system is adequately implemented. This finding is closed. e e e p. 3 -= ..e.4e = = - me ge-my e c -e me. mapeg weee g-w en. mee.-* ( i QAL. 5889 Page 3 Final QA Review (Third): Finding #2 The above corrective action and action to prevent recurrence is adequate. We feel that Zack's comitment to review all Travelers used by the field fabrication unit is proper. This Finding may be closed. This audit is closed. 11 m S'. f.'ReutgAe Q.A..Engin%er $0S W R. A. Braun Q.A. Supervisor LaSalle County Station SJR/p cc: . E. Quaka/Q.A. File G. F. Marcus 0059A e D ~ .e=aw**~wwww........w,,...,,. $1000 4.12TH PLACE e CHICAGOCERO)ILL 60650 e 312/242 3434 4401 WECTERN FLINT MICHIGAN 48506 e 313/736 2040 the 4 M@Ki co. CUSTOM METAL FABRICATION June ~2, 1982 Mr. R.A. Braun, Q.A. Supervisor, LaSalle County Nuclear Station RR il, Box 220 2601 North 21st Rd., Marseilles, Illinois 61341
Dear Mr. Braun:
Please find attached a copy of Auditor and Q.C.I.
Matrix per your request in response to CECO Audit 1-82-45.
If I can be of further assistance, please do not hesitate to call me.
Yours truly, L-Martin Skates MS/lf Q.A. Manager ggCN
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Surveillonce Octo:
October 9, 1981 File No. J-2590.26
~~
LASALL3 Q./.. SURVEILLANCT. REPORT NO.81-661 Contractor /Organi.70 tion Observed:
7.ach Company Category:
(1,2,3,5)
Item Observed:
On October 9, 1991, a surveillance uns performed at Zach's Corporate Office to evaluate the step (e)tahcn to date concerning Zack's notificatio; s
of a possible 10CFR 50.55 relating to documentation discrepancies.
Upon arrival, Mr. D. C. Calhins, Zach's I!anager of Quality.'.ssurance presented en interim report dated October 9 1981 ~(See' Attached), on Zach's review so far.
This surveillance is based on a reviee of Sach's activities in progress and the above report dated 10-?-81.
Zach is currently re-revicuing ell purchese orders and associated documentation.
This doccuentation is being reviewed in detail, specifienlly for nissing ccrts, missing, signaturcs, any alterations, proper physical.s and chemicals and compliance rith purchase order and specification renui.rements.
A log is being maintained on each purchase order. shcwing results of this review cnd any corrective action requirc?.
For certs that are missing, found deff a.ient or appear to have been altercd, Fach is notifyinr, the Supplier and requesting new certifications.
These ccnversations ar( followed up by letters, to assure a response.
To date, numerous. revised certs have been hopefully'but many more arc required.
- received,
~
The personncl Zach has acquired to perform this indepth review were found to be adecuately qualified end properly trained.
The group leader was founi to be a Consumer Tower employee with 15 years of documentation cuperience.
Thrce Quan-tech personnel were also hired to assist the Group Leeder.. Finally, two additional Zach personnel were brought in to be trei.ned and to eventually take over the documentation revicu once this initial evaluation is complete.
'During this initiel re-review, all necessary standards a,d specification were found being used.
Some questions did exist concerning LaSalle's
~~
S pecification due to vngueness in nctual documentation requirements.
T1cse questions will be addressed in Zach's Final Report scheduled for J
completion on Octohcr 26, 1981.
The follouing information was checked during this surveillance to assure the quality of roch's reviev.
All comments and questions raised bv 2ach were being entered in their 11 aster Log as required.
Some of 'the comments found by Zach ucy not be concerns for LaSalle Start-Up of Unit 71 based on my understanding of Specification J-2590 requirements.
The follouing Certifications ucre reviewed:
.m am J AkO AO2 ne ih JDF%h t M t f M *gy)p 9NW 9(*, % N 9 #,""*g1*aW M P"*47
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_2-001-561 A)
Certs containing clerical errors and' missing signatures:
P.O. 0624 - Inland Steel Co. (Coils) P.O. required certifications, houever, certs failed to identify which year of ASTM -
A527 uns used.
P.O. 6831 - U.S. Stc.cl Supply (HR Bars) P.O. required certifications, but the Northuestern Steel Cor.t failed to identifv "ASTil" A-3G.
The C. of C. from U.S. Steel Supply did'howcycr show hcot 1 and ASTM-A36.
P.O. 0947 - Hetional !!ctal Fabricators (Anric rinas) P.O. required Certs.
Some of the hoots roccive'd did not state
" ASTM" only A36-77.
Other heats failed to identify either 1.STil or A3G desianation.
P.O. 63094 "d;c-comb metals (Plate) P.O. required corts.
The cetuel CMTR ecs missing o legible siancture.
The cover sheet was however signed and accepta$1e.
B)
Missing Certificctions P.O. 0503 - P.O. was written for A-325 bolts. Certifications were required, however, only a Ccrt of Compliance was received which failed to reference " ASTM".
P.O. 0572 - Mc certs vere ovailable, could not be located.
P.O. 0586 - P.O. uns for duct scalant end required a Product Spcc. sheet which was received.
Zach is now requesting certs for the shipment.
Lain 11e spec is not clear on if corts are recuired.
P.O. 0565 - Brock Tool Co. (Phillips, Redhead 'c? edge anchor) letter of certificat*.on only, no cctual CMTR's received.
P.O. rcouired corts.
P.O. #4105 Key Creit Inc. (Nuts & Bolts).P.O. rec,uired certs, however, only C of Compliance receivec..
~
C)
Altered reports P.O. #914 - P.O. required certs, howcVer, the CMT7's received contained an ASTM date idiich had a different type setting.
P.O. $947 - P.O. required certs.
One CMTR was of poor quality.
As a result, the heet f was highlighted by someone.
It should be noted'that there was another acceptable heat 0 shotm on the CilTR.
D)
Chemical and physical results not per specification P.O. #826 - Calunct Steel (HR Angle) P.O. requirdd ASTl! -A36 steel, tihich was received.
Although, LaSalle's Spec. for this type of steel required ASTM A575 Grade M-1020.
P.O. f630 - Reliable Galvanizing (?!R An[ ale) P.O. required A36'which uns received, houcver, LaSa lc required AST!! A575 Grade M-1020.
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P.O. 01094 "dge-comb lietals (Plate Steel) P.O. required ASTif-A36, however, LaSalle Spec. required ASThi-A284 Gro1c A.
P.O. 11102 "dge-comb ?!ctnin (Plate) Same as P.O. (1094 Based on these results,."ach's revicu appear.s sufficient to identify any inconsistencies within Zach's procurement documentation.
Various Sacc. deviations have been identified which should have been accepted by Common 1calth lIdison 'Ingineering prior to use.
These will still need to be resolved.-
Snrgent A Lundy uill also be contacted to clarify actur.1 record rec,.2irements for certain materials.
Pending "ach's submittal of their. Final Ecport on 10-26-81, revised certs, no odditionn1'neering and ",ach's success in obtaining disposition from Project 7nai prob 1 cms can be foreseen.
Site QA will review the records to substantiato acceptable disposition of identified concerns at c.later date.
Corrective Action Taken:
N/A Follow Up Action:
N/A
_ _7_ _ _ _ _ _ _ _ _ _ _ _
Date: fo
,16/
P.cported.by:
_ w Auproved by:
b f3e Date: /o[/er
/
FU Action Verified: MA5 Date:
% nng./ Insp.
FU Actien Approved:
A k@ h Date: /0/ g
'M Supervisor
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.~. J. Shoeshi/G. F. Ifarcus L. J. Burhe/'..'. 11. Donaldson T. E. Quaha/Q. A. File Contractor e
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- LaSalle County Nuclear Station
- Q7 Rural Route 81 Box 220 2601 N. 21st Rd.
Marseilles. lilinois 61341 815 357 6761 January 29, 1982 QAL v5361 i
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Zach Company 4600 W. 12th Place
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Cicero, IL 60650 ATTENTION:
Mr. M. Skates Quality Ass.urance Manager
REFERENCE:
LaSalle'QA Surveillance Report No.81-661
SUBJECT:
Follow-Up Review Dear Mr. Skates -
As provided for in the attached copy of LaSalle QA's Surveillance Report No.81-661, a follow-up surveillance was performed on 1-21-82.' This surveillance showed that a majority of the identified CMTR's have been corrected.
These corrections involved clarificat, ions received from vendors, receipt of revised certs and subsequent re-evaluation performed by Zack.
As a whole, these corrections appear to resolve many of the problems identified.
The subsequent re-evaluations which were performed, however, L
failed to adequately disposition the certifi' cations which were.
originally nonconforming.
That is, no objective evidence was being "provided to justify the corrective action, " accept as is.
L' It appears the Zack Company has been accepting these certifications without properly recording the results of subsequent reviews, therefore, not allowing closure of.the NCR's.
Commonwealth Edison requires a,
f disposition for every item originally identified, along with those which are added in the future.
Presently, the status of those pur' chase orders identified wihin CECO. Surveillance No.81-661 is as follows:
A.
1)
P.O. 6624 Clarification letter from Inlan'd Steel j
Company adequately dispositions the certification.
In the letter, it was stated that supplying the ASTM year was not a company policy before 1979, l
l therefore, the cert was accepted as is.
2)
P.O. #831
" Accepted as is " based on the acceotable cert. received from U.S. Steel.with whom the P.D. was 1
j written.
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P.O. #947 - Letter _ received from vendor correcting errors. - Acceptable 4)
P.O. #1094 - A revised certification was received..
Acceptable B. 1 P.O. #508 - Open.
2 P.O. #572 - Open 3
P.O. #586 - Open 4
P.O. #565 - Based on J-2590 Specific'ation requirements '
only a C. of C. is acceptable.
As a result, the letter of certification from t:2e vendor was acceptable as is.
5)
P.O. #4105 - Open P.
C. 1)
P.O. #914 - Was identified as acceptable, but the cert. package failed to provide any indication of its corrective action or of any subsequent reviews which-were performed that accepted the certification as is.
Open 2)
P.O. #947 - Same as'#914 - Open D.'1)
P.O. #826, 630, 1094 and 1102 - S&L's Specification J-2590 Amendment fl,. accepted A-36 as a substitute for the material identified.
As a result, each.of the above P.O.'s were accepted as is.
Pending Zack's final response which is expected in early Februa n,
and Zack's corrective action concerning subsequent evaluations and the proper disposition of all items identified no additional surveillances will be required at this time.
Woodat(815)357-6Y61onextension.565.pleasecontactBruceL.
~
If you have an further' questions, kt (LaSalle)
Yours truly, L
IL I
T. E. Quaka Q. A. Superintendent LaSalleCounty Station BLW/ccc ec:
. J. Shewski/G. F. Marcus
. E. Watts T. E. Quaka/Q. A. File t
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Janun.r'* 2 G. 1.09 2 Filc Pe. J-2590.20
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I..0.u.L".1. A. SUTnIL12'C. P.F. POP.T FO. 32-50 T
Tontra:itor/Or-ri'Br.ction Oh:: ors e?:
- 'ach Construct 4.on Co:.m.nus - - -( 2)- - - -
.------------------- s Iten Observ.cd:
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follo.ing Deficiency Bes d on this record revic ', the tatus of th.:
i T'.: ports is as rot:0 belote:
Closed FT "r..1.01-179 PT-VC-301-411
. Clos:d Clo::d TT-73-101 1.28 Clcs:d PT-V7.-301-120 Closed F T 1. C.- 1 0 1 - 2 0 ')
Clored TT-VT-100-l
Close.d FT-V".-101-87
';1o. sed PT-V :-101-0 0 Clossa F
"T-V.':- 101-1 M On 1-?1.-P2, it :cs verified that Cer the itcas sho6n in t'ic above dr.ficicncies, sufficient records c::ist to satisfy the precurement requirements at.ach': Corgorate Office.
It vcs further shown that these records h..f. been rer'. ved and accepted by.~.ach's '!A for use at Lc0n110.
C&L's ECH I G24, deletid the rdquircm:nts for cuh:ittin; on-site centre.cto-docua ntatien ( mch as P.ach's) to ",6L fn: revice.
This k
ravic is no: the resnonsibilit" of ".nch Comoc.n" nn? i:: being veri.fied b" the 0..iic:r, throm'b,h the cudit'hn ' serveillime:
Trogram.
Desed'on thic cnangc,.? E's utcr eccept'.n;
,c.c':': cocumci.itation i: no lonr,cr required.
This curveillance assured that th:_ follo"in, documentntion t:ns e.vailable for turnoVcr:
t 1fccting notes dated. 5-10-75 hett:cen 5&L cnd.3ach Company
[i clarified the Spec. 's 'docum::ntation requirements and T
supplied the follouinr,deterninatienc:
1.)
0 fety relcted items (such c..; she t steel,.
' stiff ner and support stcol.) actual CliTP.'s are requirrd.
2)
All oth:: snicty related h.,rd' arc only -
Certificate of Conform nce i n:cessary.
3)
All non-nnfr:ty relat::d itene. only a Certificate of Conforence is reqsired.
t- )
- ach's P.O. CC-9503 to /aerican.:armin.. cnd Vcntilatin; Co.
i rce to furnich and delivcr :.11 Camper: in cecordance rit-Spec. 1.~590.
For cach item shotm on the. deficienci:-: :s dampers (such
- 1.""30Y or OVC0fND), a C. of C.
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..ach's P.O. %-9503 to in:rican /.ir Filter Cystems ecs to fucnish and deliver all filters in accordance "itli Spec. J-2590.
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' For each ite:
she'.'n on the (cficiencies ns filters (suc'.i as IV.~01F), a C. of C..:ss verified i
to bc on file.
C)
"ach's P.O. 0C-9501 to Titus Manufacturius Company was
.to furnich aM deliver cil nrilles, renisters, diffu:crs cnd terminal mi::in-bones in accordance uith Spec. J-2WO.
.. C. et C. icr c.J.1 cupplieri untarie:1.7nr. verified as bsing on f!.1e.
D)
.~.ach ' s P. O.
C-9506 to Air Filt'cr & Couip, nt Corp. ras to furnish and deli :r all cir cilencern in ccco'd.e.nc.c r
vith Onc. J-2500.
For cdch iten sho.n on the d-fs.cien:i:s'as silcuccr.=-(such nf C. could not be located, therefc ns OTIO?X er IVX01X)$fn'q _
~(FT-VF.-?01Melft and I
a the deficiencies rr:
onen.
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- ach's P.O. 'C-9505 6 C-12$ >. to /ir Filter and ".r;uipment Corp.1.as to fu'rnish anel del.iv
- .: cl1. nir :1onitors in cecordence
.4ith Spec. J-2590.
For cach iten shocen'on the deficiencies es c.ir monitors ' '
(such as OFE-V~.003), c.C of C. uns verified to be en file.
F)
- ach's P. O.."C-951.1 to /.rm trong Company was to furnish and deliver all humidifiers in recordance tith 5pcc. J-2590.
For ecch iten sho.m on th' deficiencies as humidifiers (such as OVE0lH/.) a C. of C. ens verified to h: on file.
G)
.-*.ach's T.O. 'C-9509 to RNC 'ms to furhish deliver all r.ir conditionin:: cecessories in accordance with Spec. J-2570-For each item sho.m on' the deficicncies as AC accessories (such cs OnG051 or on056B), c'C. of C. could not bc lorm nd th:refore, the defici:ncy r mn it open-PT rT.-101 5fW-)
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11 ) Hany of the C. of C. 's.... died cho : ucre found to be
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- encric for all the items supplied a sinst a particular f
P.O..
These C. of C. 's cre acceptabl:, houcver, et turnm cr '.e.ch must state all cpplicable equipment.piccc t
j numb:rs uhich apuly, to assure tracecbility.
This item remains onen unti.1 2ch's tritt:n..ccent:.nce is.receiv:d.
Corrective Action Taken:
..nc'.:'s lir. C. Tich:toodt uns infmer::.d nf thes; items requiri.n ;.
corrective action, in p rticis1..: i+..m-n, G
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e-m -30 Follo.? 1.1p Action:
Tne critte, responce and all correcti.vc acticn uill be revicded '
.nd c.cccptc0 by C?.Oc "...'...
Due to the nultipic listing of itens on som: Ceficiencies, the originci de"iciency has b.cn cler.ed rid c nce deficiency critten to trach only-the open items.
l TT-V'.-101-128,120 and 303 :ere ccmbined r.nh a uc.a deficic,cy FT-VT-1012
.c.s
- ritte.n to identify thd op n ite.1 enly.
ET-V'-101-87 er.s clos?d en/. a nor Ocficiercy TT-V.:-101.T uns written tn identi"y the opvi itor.s enly.
On March 1, 1982, Zack responded to this. surveillance by submitting thei final stmnary report of all open purchase orders.
Within the
- report, Zack attached 99 nonconformances for which 30 had been dispositioned by Zack internally.
The remaining NCR's were subsequently returned to Zack for further evaluation on Zack s part.
(C ont_ine_d _a g _Mgt qm _o f _ggd _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
- b. port:d by:M -
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FU Action i.pproved: /2.GL Date:,7 6 E
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';J. Cupervisor cc:-
i/G. F. Mat k
[. JCosaro
'g 'h T. ~.. ~\\tchc/Q. it. Tile L. H. Lautcrbach/P. H. Ber:.'r F. Jar.urda/ Start-Up In reviewing the.results submitted to date, both Zack P.O.'s C-9504 and 9506 have been satisfactory resolved from Commonwealth Edison's point of view by obt_rining the necessary Certificate _of Conformances.
Based on t~
s action, deficiencies n-VE-101-706 and FT-VX-I0t=-388 can now be considered closed.
Finally, Zack's Project Manager, C. Eichstaedt, was contacted concerning traceability for Zack's final turnover records.
He indicated that the necessary equipment piece numbers would be provided, as required by S&L ECN-624, therefore, this surveillance is considered closed.
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LaSalle Ctumy N:/
Station Rural R,;;ute o)
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2501 N.21st Rd.
Marseillet. filinois 6134i 815 357 6761 February 3, 1982 QAL #5 376 '
Zack Company
~
4600 W. 12th..
Cicero, IL 60650 ATTENTION:
Mr. C. Eichstaedt
REFERENCE:
LaSalle Qi Surveillance Report No. 82-50
Dear Mr. Eichstaedt:
Attached, please find the above referenced surveillance for which a response is requested by 2-17.-82.
It appears that the following three (3) items require resolution:
Item D identified Zack's P.O. #C-9504 for which a 1) required Certific' ate of Conformance could not be produced as required.
Item G identified Zacn's P.O. #C-9509 for which'a 2) required Certificate of Conformance could not bc
~
A produced as required.
- 3) ~ Item H identified the fact that trac'eability to specific Zack should equipment piece numbers could not be verified.
l suoply a traceability system acceptable to CECO. upon su':xnittal of final turnover records.
It should be noted that Zack's QC was in the process of reviewing.
The particular l
all purchase orders generated for use at LaSalle.P.O. s identifie A-f serious effort should be made to complete this review so tht t all i
problem areas are known.
Any questions regarding the information contained within this' surveillance should be directed to Bruce L. Wood on (815) 357-6761 i
extension 565.
i C
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=.l3hl-T. E Quaka BLW/ccc Q. A. Superintendent r-LaSalle County Station
)W. J; Shewski/G. F. Marcus*
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,fT. E, Quaka/Q. A. File
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- Letter Only
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t2) 8 Item Observed:
A follow-up surveillance was performed at Zack's Corporate office on April 15, 1982 to assure adequate disposition of nonconformance reports resultina from Zack's efforts to close the open 50.55E.
This 50.55E identifie8 to the NRC concerns relating to Zack's missing and insufficient receiving inspections records and man deficient purchase orders and associated records. y other cases of Several Zack nonconformances reports were submitted to Commonwealth Edison for Engineering disposition.
Those reports were not part of this review.
The last such submittal became part of CECO. NCR #594 The subject of this surveillance was those Zack nonconformances which i
were finally dispositioned by Zack internally and, therefore, never reviewed by CECO.
4 The results of the actual NCR's reviewed are detailed below.
It became apparent that the nonconformances dispositiuns by Zack were actually not safety related in nature and in many cases involved non-safety related material.
inadecuacy or improper review was found.It should be noted that no cases of The NCR's reviewed can be consicercd closed, as a resuJt of this surveillance.
Reviewed the following Zack NCR's in detail:
NCR's #205, 206, 207, 208, 209, 212, 213, 216, 217, 218, 219, 220, 221, 222, 223, 224, 226, 227,2228, 229, 230, 231, 232, 235, 236, 237, 238, 239, 244, 245, 246, 247, 248, 249, 250, 251, 252, 255, 256, 257, 258, 259, 260, 261, 262.
R'eviewed the following Zack NCR's for proper signatures only.
i E-NCR's #263 thru 305.
Corrective Action Taken:
N/A Follow Up Action:
N/A Reported by.: $ e f
/
cc:
W. J. Shewski/
. F. Marcus
. Approved by: /2 CL O%.
Date:
_4,/n /n i l j
. Cosaro
- 4. Skates (Zack)
FU Action Verified:
Date:
[ *87-NT. E. Qualm /
Eng. / Insp.
}
Q. A. File h.
FU Action Approved: N/A-M Date: 4[t1/ht.
QE Supe rvisor i
- M/
Mr. A. Schwencer Augus t 12, 1982 ENCLOSURE 2 Sub'mittal from Commonwealth Edison a
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