ML20070H984

Responds to NRC Re Violations Noted in IE Insp Repts 50-237/82-21,50-249/82-22,50-254/82-17 & 50-265/82-19. Corrective Actions:Annual Audits of All Active Ae Firms Performing safety-related Work Required

ML20070H984
Person / Time
Site:	Dresden, Quad Cities, 05000000
Issue date:	11/24/1982
From:	Delgeorge L COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20070H978	List: ML20070H984 ML20070H995 ML20070J007
References
5482N, NUDOCS 8212270303
Download: ML20070H984 (4)

Text

L .

g' ,'~N Commonwealth Edison l / one First National Plaza. Chic 7go. Ilknots

. \ / Address Reply to: P;st Offica Box 767

\ / Chicago, lilinois 60690 November 24, 1982 Mr. James G. Keppler, Regional Administrator Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Dresden Station Units 2 and 3 Quad Cities Station Units 1 and 2 Response to IE Inspection Report No s . 50-237/82-21, 5 0-249/82-2 2, 50-254/82-17, and 50-237/82-19 NRC Docket Nos. 50-237, 50-249, 50-254, and 50-265 Re ferences (a): W. S. Little letter to Cordell Reed dated October 26, 1982.

(b): C. E. Norelius letter to Cordell Reed dated July 1, 1982.

(c): L. DelGeorge letter to J. G. Keppler dated July 30, 1982.

Dear Mr. Keppler:

Reference (a) provided results of the special inspection conducted by Messrs. D. H. Danielson and I. T. Yin of your of fice on August 25, 1982, at NUTECH Engineers, San Jose, California, and on Augus t 26-2 7, 1982 at EDS Nuclear Inc. , Walnut Creek, California , o f activities concerning Dresden Station Units 2 and 3 and Quad Cities Station Units 1 and 2. The Commonwealth Edison Company response to the item of noncompliance identified in Reference (a) is provided in Attachment 1. Provided in Attachment 2 is a copy of the approved NUTECH/EDS design interface provadures as requested.

In Inspection Report Nos. 50-237/82-08, 50-249/82-09, 50-254/82-09, and 50-265/82-10 (Reference (b)), Commonwealtn Edison received an item of noncompliance which was virtually identical to the nonccmpliance identified in Re ference (a) . We were cited as having a deficient Q. A./ design audit program to ensure contractor Q. A. program implementation because we had not performed any imple-mentation Q. A. audits or surveillances from CY 1980 to CY 1982 at EDS Nuclear, Inc. In our Re ference (c) response, we described the measures we have taken to ensure that annual audits will be made of all architect-engineering firms actively performing safety-related work.

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f~PDR ADDCK8512270'303 l

' 05000237  : 821216 i

NOV 2 61884

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4 J. G. Keppler November 24, 1982 Because this previous inspection report and our response directly and adequately addressed this issue, it is our belief that the current non-compliance is not warranted, and should be withdrawn.

To the best of my knowledge and belief the statements con-tained herein and in the attachment are true and correct. In some respects these statements are not based on my personal knowledge but upon information furnished by other Commonwealth Edison employees and contractor employees. Such information has been reviewed in accordance with Company practice and I believe it to be reliable.

Please address questions you may have concerning this matter to this o f fice.

Very truly yours, A $

L . O . De l Geo rg e Director of FOclear Licensing TJR/lm cc: Region III Inspector - Dresden Region III Inspector - Quad Citie s At ta chmen t a .-

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• .6 ATTACHMENT #

I Commonwealth Edison Company Response to NRC Notice of Violation

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10.CFR 50, Appendix B, Criterion XVIII, states, in part, that "A  :

comprehensive system of planned and periodic audits shall be carried (

out to verify compliance with all aspects of the quality assurance t program and to determine the effectiveness of the program." i Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Station," Revision 20, dated February j

17, 1982, states in Section 18 that,~" Audits will be performed by l Commonwealth Edison Company and/or its contractors, subcontractors i and vendors to verify the implementation and effectiveness of quality  ;

programs under their cognizance." j Commonwealth Edison Company Q.A. Manual, Quality Procedure No. 18-1, h

" Quality Program Audits," Revision 8, dated July 10, 1981, states in j Section 5.2 that, "The selection of off-site facilities to be i

atdited and the frequency of audits will be based on Contractor j

, Capability Evaluation, CECO Construction Surveillance Reports or l findings from previous audit reports. Audits may be performed on i off-site contractors that are selected on an irregular basis without [

regard to previous Capability Evaluation or audit reports. The  ;

frequency will be based on the nature and safety significance of the '

work being performed. Generally, audits will be scheduled where  :

practical to coincide with plant visits involving witnessing inspec- l tion notification points. Audits of the Nuclear Steam Supply vendor, l the Architect-Engineer and Station Nuclear Engineering Department  ;

will be conducted in approximate annual basis."

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f Contrary to the above, the Q.A./aesign audit program to ensure *

contractor program implementation was deficient, in that

(1) there i

had been no implementation Q.A. audits or surveillances conducted  ;

from CY 1977 to CY 1979 at NUTECH; and (2) deficiencies existed in -

the NUTECH Q. A. audit program that had gone undetected.

Discussion Commonwealth Edison Company has an extensive program for  !

auditing off-site vendors and architect-engineers. During the i years, 19 79, 19 80, and 19 81, audits have been conducted at 68, l 4

74, and 105 off-site facilities, respectively. For 1982 the Off-Site Vendor Audit Schedule, which was issued on January 20, [

r 1982, required that audits be performed at 90 off-site locations.  ;

In addition, the General Office Quality Assurance Department l Audit Schedule dated December 15, 1981 included five audits of  :

NSSS Vendors or A/Es for 1982 bringing the total original l commitment for audits of off-site facilities to 95 for 1982. j I

1 l

I

Corrective Action Taken and Results Achieved In reference to NUTECH, Inc. ,. San Jose , California , Commonwealth Edison acknowledges that a Q. A. audit of these activities was not conducted during the period 1977-1979. However, as described in the above inspection report, Commonwealth Edison Quality Assurance Department conducted audits of NUTECH, San Jose ,

California o f fices on August 19-20, 1980 and July 14-15, 1982.

The CECO audits included a review of the NUTECH internal Q. A.

audit program. In the 1980 audit, one deficiency was identified and in the 1982 audit, two deficiencies were identified. Thes e deficiencies were adequately resolved and subsequently closed on September 30, 1980 and August 26, 1982, respectively. Corrective Action for this non-compliance is complete.

Action to Prevent Recurrence In the preparation of o f f-site vendor audit scheduls, special care will be made to require annual audits of all active architect-engineer firms performing safety-related work. In addition, on June 8, 1982 a review o f the 1982 of f-site vendor audit schedule was completed to assure that appropriate vendors are being audited during the current program. This action to prevent recurrence is identical to that previously provided in Reference (c).

Date of Full Compliance Full compliance has been achieved.

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