ML20071M343

Responds to NRC Re Violations Noted in IE Insp Repts 50-237/82-08,50-249/82-09,50-254/82-09 & 50-265/82-10. Corrective Actions:Qa Audits Conducted at EDA

ML20071M343
Person / Time
Site:	Dresden, Quad Cities, 05000000
Issue date:	07/30/1982
From:	Delgeorge L COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20071M330	List: ML20071M336 ML20071M343
References
4622N, NUDOCS 8209270083
Download: ML20071M343 (6)

Text

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Commonwealth Edison O ') One First Nitional Plaza. J Ch Cago. Illin_ois v~ Address Reply to: Post Office Box 767 Chicago, filinois 60690 July 30, 1982 Mr. Jame s G. Kepple r , Regional Administrator Directorate o f Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road i

Glen Ellyn, IL 60137 i

Subject:

Dresden Station Units 2 and 3 Quad Cities Station Units 1 and 2 Response to I.E. Inspection Report Nos . 50-237/82-08, 50-249/82-09, 4-50-254/82-09, a nd 50-265/82-10 NRC Docket Nos. 50-237/249 and 50-254/265 l Reference (a): C. E. Norelius letter to Cordell Reed dated July 1,1982.

Dear Mr. Keppler:

Reference (a) provided the results of the special inspection conducted by Mr. I. T. Yin of your of fice on May 3-6, 1982, a t EDS Nuclear Inc. , Walnut Creek, California, o f activities concerning our Dresden Station Units 2 and 3 and Quad Cities Station Units 1 and 2.- During that inspection, certain activities appeared to be in non-compliance with NRC requirements.

The Appendix to Reference (a) identified three (3) items or no n-compliance . The Attachment to this letter provides the Commonwealth Edison Company response to Items 2 and 3. Our response to Item 1 is being deferred until August 16, 1982, as discussed with Mr. C. E. Norelius during a telephone conversation on July 23, 1982.

To the best of my knowledge and belief, the statements

' contained herein _and in the At tachment are true and correct. In some respects these statements are not based upon my personal knowledge but upon information furnished by other Commonwealth Edison employees. Such information has been reviewed in accordance with Company practice and I believe it to be reliable.

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J. G. Keppler Jul y 30, 1982 Please address any questions that you or your staf f may have concerning this matter to this office.

Very truly yours,

/ L L. O. DelGeo rg e Director o f tOclear Licensing EDS/lm Attachment cc: Region III Inspector - Dresaen Region III Inspecto r - Qua d Citie s SUBSCRIBED and SWOHN to before me this derida y of Ozc//<- , 1982 tv n_l L k. x t n IKJ Notary Public 4622N 1 M

q ATTACHMENT COMMONWEALTH EDISON COMPANY RESPONSE TO NOTICE OF VIOLATION ITEM OF NON-COMPLI ANCE

2. 10 CFR 50, Appendix B, Criterion V, states in part that,

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

Commonwealth Edison Company Topical Report CE A, " Quality Assurance Program for Nuclear Generating Stations," Revision 15, dated January 2, 1981, states in Section 5 that, " Th e quality assurance actions carried out for design, construction, testing, and operation activities will be described in documented instructions, procedures, drawings, specifications or checklists. These documents will assist personnel in assuring that important activities have been performed. These documents will also reference applicable acceptance criteria which must be satisfied to assure that the quality related activity has been properly carried out."

Contrary to the above, the EDS procedure for designing new piping support base plate and concrete anchor bolts was considered to be inadequate in that: (1) the Project Instruction (PI) No. 28.0 did not provide detailed design instructions, and (2) there was a lack of instructions to determine when to perform a simplified calculation as required in the PI No. 28.0, and when to perform comprehensive analyses as contained in EDS Technical Procedure No . 2.6.1.

Corrective Action Taken and Results Achieved EDS believes that Project Instruction No. 28 together with the technical procedure 2.6.1 are adequate for the scope of baseplate and concrete bolt design as required by Criterion V which states in part " Ac tivities a f fecting quality shall be prescribed by documented instructions, procedures, or drawings, or a' type appropriate to the circumstances..." It must be recognized that Procedures / Instructions are an integral part of the EDS program which includes training ,

design verifications, personnel qualification and many other planned activities to provide adequate confidence in work quality.

To. ensure a complete resolution of the inspection concern, 'EDS has developed and issued Project Instruction No. 39, " Gene ral Base Plate Design" and has reviewed all project instructions prepared for CECO projects in July , 1982. Additional detailed design instructions and references have been incorporated into Projec t Ins truction PI No . 28.0. Reference P.I. No . 2 8, Rev.

3 dated July 12, 1982.

Corrective Action Taken to Avoid Further Noncompliance To avoid further noncompliance, a CECO Q. A./ Technical audit was performed at EDS Nuclear in Walnut Creek on July 12 and 13, 1982. The following areas of documentation were reviewed:

Instructions, Procedures and Drawings; Design Control; and Document Control . In addition, annual Q A audits will be l performed by Ceco QA o f all- active architect firms performing safety related work. Reference CECO response to noncompliance Item 3 contained in this Attachment.

Date when full compliance will be achieved Full compliance has been achieved.

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4 ITEM OF NON-COMPLIANCE

3. 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 program and to determine the effectiveness o f the program."

Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Stations," Revision 20, dated February 17, 1982, states in Section 18 that, i " Audits will be performed by Commonwealth Edison Company and/or its contractors, subcontractors and vendors to verify the implementation and ef fectiveness of quality programs under their cognizance."

Commonwealth Edison Company Q. A. Manual, Quality Procedure No.

18-1, " Quality Program Audits," Revision 8, dated July 10, 1981, states in Section 5.2 that, "The selection o f o ff-site facilities to be audited and the frequency of audits will be based on Contractor Capability Evaluation, CECO Construction Surveillance Reports or findings from previous audit reports.

Audits may be performed Go o ffsite contractors that are selected on an irregular basis without regard to previous Capability Evaluation or audit reports. The frequency will ba 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 inspection notification points. Audits o f the Nuclear Steam Supply vendor, the Architect-Engineer and Station Nuclear Engineering Department will be conducted on an approximate annual basis."

Contrary to the above, the licensee Q. A./ design audit program to ensure the contractor program implementation was deficient, in that: (1) there had not been any implementation Q.A.

audits or surveillances from CY 1980 to CY 1982 at EDS, (2) the various NRC identified design deficiencies had not been reviewed or disclosed by either licensee SNED or EDS design reviews.

DISCUSSION Commonwealth Edison Company has an extensive program for auditing of f-site vendors and architect engineers. During the years 1979, 1980 and 1981, audits have been conducted at 68, 74, and 105 of f-site facilities, respectively . For 1982 the Of f-Site Vendor Audit Schedule, which was issued on January 20, 1982, required tnat audits be performed at 90 of f-site locations. In addition, the General Office Quality Assurance Department Audit Schedule dated December 15, 1981 included five audits of NSSS Vendors or A/E's for 1982 bringing the total original commitment for audits of of f-site facilities to 95 for 1982.

--A-In the case vf EDS Nuclear, Commonwealth Edison performed an audit of the Walnut Creek, California Office on February 20-21, 1980. The audit identified two deficiencies-which were closed on April 14, 1980. In addition, SNED engineers have actively been involved in overseeing EDS design work through the review of EDS drawings, stress reports and design reports. Also, numerous meetings have been held between EDS and SNED to discuss design concerns. For the scope of work involved, it was felt that the EDS design activity was being adequately covered. Also, Quality Assurance performs regular audits and surveillance of the Project Engineering and Station Nuclear Engineering Departments to assure engineering involvement and coverage o f A-E contracts.

Corrective Action Taken and Results Achieved On July 12-13, 1982 Quality Assurance and Station Nuclear Engineering jointly conducted an audit of the EDS Walnut Creek, California Of fice . The ten areas which were covered in the audit were as follows: (1) Organization, (2) Pe rsonnel Orientation and Training, (3) Design Control, (4) Document j Control, (5) Instructions, Procedures and Drawings, (6)

No n-con fo rmances , (7) Corrective Action , (8) Au di t s , (9)

Personnel' Qualifications and (10) Q.A. "ecord Retention. Six items were identified as deficient. These items were in the areas of personnel orientation, design review, audits, document control and personnel qualifications. A response from EDS has been requested by August 18, 1982.

Corrective Action Taken to Avoid Further Non-Compliance In the preparation of of f-site vendor audit schedules, 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 o f f-site vendor

audit schedule was completed to assure that appropriate vendors are being audited during the current program.

Date When Full Compliance Will Be Achieved A response from EDS has been requested by August 18, 1982.

The deficient items ~will be tracked by CECO Quality Assurance until each is properly disposed. Upon satisfactory resolution of the items found deficient in the Commonwealth Edison audit, corrective action for this non-compliance will be complete.

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