ML20076L372

Responds to NRC Re Violations Noted in IE Insp Repts 50-454/83-09 & 50-455/83-07.Corrective Actions:Level III QA Manager Appointed on 830324 & All Contractors Requested to Notify Util of Changes in QC Inspectors

ML20076L372
Person / Time
Site:	Byron
Issue date:	05/06/1983
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20076L368	List: ML20076L372
References
6513N, NUDOCS 8307190147
Download: ML20076L372 (10)

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.V* .- ' Commonwealth Edison

['/^N) On:s First Nitional Ptin; Chicago, lilinois

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\ C 7 Address Reply to: Post Office Box 767

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j - Chicago, Illinois 60690 May 6, 1983 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:

Byron Generating Station Units 1 and 2 NRC.I.E. Inspection Report Nos.

50-454/83-09-and 50-455/83-07 References (a): April 4, 1983, letter from C. E.

Norelius to Cordell Reed.

(b): December 23, 1982 letter from L. O.

DelGeorge to J. G. Keppler.

Dear Mr. Keppler:

Reference (a) provided the results of an inspection conducted by Messrs. W. L. Forney and K. A. Connaughton on February 28, 1983 at Byron Generating Station. During that inspection it was determined that certain activities appeared not to be in compliance with NRC requirements.

Attachment A to this letter contains Commonwealth Edison's response to the Notice of Violation appended to reference (a).

As described in Attachment A it appears that two of the four Violations do not involve noncompliance with NRC requirements. On the basis of the cinformation presented here it is respectfully requested that Violations 2 and 4 be reviewed and withdrawn. We would be pleased to meet with Region III management-to discuss these matters further.

To the best of my knowledge and belief the statements contained herein 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, contractor employees, and consultants.

Such information has been reviewed in accordance with Company practice

'and I believe it to be reliable.

Please direct any. questions regarding this matter to this. office.

uly yours Very/

i 8307190147 830713 /

DR ADOCK 05000 ,_,'_

l D. L. Farrar i l' Director of Nuclear Licensing l 1m l Attachment 1

6513N, MAY 91983 .

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ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION Violation 1:

10 CFR 50, Appendix B, Criterion XIII states, in part, that " Measures shall be established to control the handling, storage, shipping, cleaning and preservation of material and equipment...to prevent damage or deterioration".

The Commonwealth Edison Company Quality Assurance Program contains, in quality Requirement QR 2.0 a commitment to the regulatory position of

- Regulatory Guide 1.38, Revision 2 which endorses the requirements of ANSI N45.2.2-1972. Section 6.5 of ANSI N45.2.2 states, in part, that, " Items released from storage and placed in their final locations within the power plant, shall be... cared for in accordance with the requirements of Section 6 of this standard." Section 6 of ANSI N45.2.2 states in part that, "(6.1.1) Levels and methods of storage necessary are defined to minimize the possibility of damage or lowering quality due to corrosion contamination, deterioration, or physical damage. (6.2.2) Cleanliness and good housekeeping practices shall be enforced at all times in the storage areas. (6.4.2) Items...shall have all covers, caps, plugs or other closures intact... covers removed for internal access at any time for any reason shall be immediately replaced and resealed after completion of the purpose for removal."

Contrary to the above, the Applicant does not have an adequate plugs or other closures intact... covers removed for internal access at any time for any reason shall be immediately replaced and resealed after completion of the purpose for removal."

Contrary to the above, the Applicant does not have an adequate program to ensure proper care and preservation of safety related equipment as evidenced by numerous instances of missing or damaged penetration covers and piping end caps identified during tours of Units 1 and 2 containments and the auxiliary building between January 1 and February 28, 1983. This is a repetitive item of noncompliance identified in Inspection Report Nos. 50-454/82-02; 50-454/82-22, 50-455/82-16.

Corrective Action Taken And Results Achieved:

The actions taken in response to Violations 454/82-22-05 and 455/82-16-03 included an increase in the frequency of contractor Q.C. surveillances of preservation of equipment and components to decrease the number of deviations from storage and preservation requirements. Procedures were also.to Je revised to require the use of metal, plastic, or other durable material for end covers. The procedure was to be revised by January 15, 1983.

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The-majority of specific valves and piping identified in this item of noncompliance were protected with-tape to prevent the entrance of foreign materials. .The valves and piping were not protected with " proper l materials" as defined by the revised procedure which was not fully 0 -Timplemented by January 17, 1983 when the inspector toured the plant.

1 The normal period for-implementation of a major procedure revision is 60 i days. This amount of time-is needed to properly train production and

.Q.C. personnel, purchase acceptable end caps, and replace tape on openings with an acceptable material per the revised procedure. During

.this period of-implementation Q.C. Surveillances were performed to identify openings that had no protection. During this period of implementation Q.C. Surveillances were performed to identify openings that had no protection. Numerous production personnel were assigned full

~ time to the task of replacing tape on openings with acceptable materials available on site'and'with plastic caps as they were received from vendors.

' Corrective Action Taken To Avoid Further Noncompliance:

ProductionLandHQ.C. personnel.have been trained in the revised procedure, proper materials for the protection of openings have.been purchased, and

numerous production personnel were assigned for a period of time to upgrade equipment and components to the requirements of the revised procedure. The Q.C. surveillances will be ongoing to minimize the number of instances where equipment and components are not-properly protected.

Future responses to Notices of Violation will indicate explicitly the date when full compliance was or will be achieved. In no case will the

. commitment to.a date for procedure revision imply full compliance on that

.date.

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Date When Full : Compliance Will Be Achieved:

The revised. procedure addressing equipment preservation =was fully

-implemented on March 15, 1983.

d Violat' ion'2:

110 CRFf50,. Appendix B,-Criterion XVI, " Corrective Action" states, in

part:: Measures:shall be established to assure that conditions adverse to Equality, such,as failures,. malfunctions, deficiencies, deviations,

' defective material'and~ equipment and nonconformances are promptly -

. identified and corrected. Commonwealth Edison Company Topical Report

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CE-1-A, Revision 21, dated June 6, 1983, section 16.0 states, _ in part: A corrective. action system will be used to assure that such items as

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failures, malfunctions, deficiencies, deviations, defective material and equipment.and nonconformances which are. adverse to quality and might j; affect'the safe operation.of a nuclear generating station are promptly

identified and corrected.

Contrary to the above, the Applicant's response, CECO L. O. DelGeorge to NRC Keppler of December 23, 1982, to NRC items of noncompliance 4: 50-454/82-22-05; 50-455/82-16-03 stated at page 6, of Attachment A, j Violation 3 for Corrective Action Take'n And Results -Achieved that "The 4 covers referenced by the violation have been replaced and resealed" and p 'for Corrective-Action Taken To Avoid Further Noncompliance that "Preserva-j tion procedures will be revised..." and for Date When Full Compliance i Will Be-Achieved that " Preservation procedures will be revised by January F 15, 1983". As of January 17, 1983 the Applicant had not replaced and

. resealed end' covers on. pipes through Unit 2 containment penetrations.

The Applicant has failed to institute an effective program to ensure proper care and preservation of safety-related equipment i n either Unit 1 or'2~although similar conditions adverse to quality were identified in NRC inspection reports: 454/82-02; 454/82-22; 455/82-16; 454/82-24,

{ ~455/82-18.

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Response

l This-violation does not represent a breakdown in any corrective action ,

i . system. Rather, Lit involves a' misunderstanding of.the corrective action l

documented in-reference (b) in response to Violation 3 from I&E Inspection l Report Nos~.'50-454/82-22 and 50-455/82-16. In response to the findings of that, inspection, Commonwealth Edison acknowledged that previous preser-

.vation' procedures-inadequately specified acceptable types of durable pipe and: penetration end covers. Tape closures were-permissible according'to-those procedures. - In the response we indicated that the covers l

creferenced.in the Violation had~been replaced and resealed. We also indicated thatethe preservation procedures would be revised to upgrade 1the end cover requirements =by January 15, 1983. - We did not mean to indicate that the:' subject covers had already.been' replaced to! comply with L thennew procedures;that would not be in place until' January 15, 1983.

The openings 1h ad-been resealed with tape subsequent tofthe'second' tour identified:in report-50-454/82-22 and 50-455/82-16 and prior to: December 123;~1982.. That was an acceptable method of piping protecti'on and preser-vation at the. time it was installed. It is worth noting that the subject-

- l piping; flanges"are for the non-safety related component-cooling coils at-soveralfcontainmentDpenetrations.-

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. As ' described in _the _ response to Violation 1, i mplementation of the revised

' procedure was _ begun' on Monday, _ January 17,-1983. Construction personnel were notified by the NRC inspector on January-17, 1983 that the-subject

' flanges were not yet been protected with a durable material according to-

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the revised. procedure. Construction personnel were sent out immediately to: investigate. They found Hunter personnel in the process of replacing the tape _with a wooden cover.

.This item does not involve noncompliance'with NRC requirements because

.the activities cited were in compliance with existing procedures.

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Violation 3:

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

Byron FSAR, Appendix A, Regulatory Guide 1.58, states in part, "The Applicant complies with the position of this Regulatory Guide with the following exception: Regulatory Guide 1.58, Revision 1, Position 6 requires that a candidate for Levels I, II, or III Inspector for inspection activities be a high school graduate... In the Applicant's judgement, this is an unnecessary and unfair restriction." The Applicant did not take any other exceptions.

Regulatory Guide 1.58, B. Discussion, states in part, "Where conformance to this Regulatory Guide is indicated in an application without further qualification, this means that the requirements of ANSI N45.2.6-1978, as supplemented or modified by the regulatory positions of this guide will be followed."

Regulatory Guide 1.58, C. Regulatory Position states, in part, at Paragraph 6, "Since only one set of recommendations is provided for the... experience of personnel, a. commitment to comply with the regulatory position of this guide in lieu of providing an alternative to the recommendations of the standard means the specified... experience recommendations of the standard will be followed."

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

-the health and safety of the public, or to mitigate the consequences of such accidents if they were to occur."

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

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

Contrary to the above, a Hatfield Electric Company, Level III, Quality Assurance Manager was not adeyuately qualified to perform safety-related inspection functions for which he was certified.

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Carrective Action Taken and Results Achieved

'A new Level III Quality Assurance Manager was appointed on March 24, 1983. This new Q.A. Manager, T. Hill, had initially met ANSI Level III

- requirements as' determined by Hatfield Electric President and Q.A. Manager on May 15,_1981=and most recently by Commonwealth Edison Project Construc-tion Department and Quality Assurance Department on March 23, 1983.

Corrective Action Taken to Avoid Further Noncompliance All contractors ha've been_ requested to notify CECO on a weekly basis of any changes _inHQ.C. inspectors who have been qualified or expanded the limits of their qualification during week prior. On April 22, 1983 all contractors were required to qualify Level III candidates'to the strict education and experience requirement of Paragraph 3.5 of ANSI N45.2.6-1978.

Date When-Full Compliance Will Be Achieved April 22, 1983.

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Violation 4:

10 CFR 50, Appendix B, Criterion XI " Test Control" states, in part, "A test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.

Commonwealth Edison Company (CECO) Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Stations", Chapter II, " Test Control" states, in part, " Quality Assurance shall monitor such tests (pre-operational tests) to assure they are performed properly..."

Contrary to the above:

a. A Quality Assurance policy memo from the corporate Quality Assurance Manager to the site Quality Assurance Superintendent dated June 18, 1981, encourages but does not require witnessing of test performance to verify proper performance.

b. Of fourteen safety-related or reliability-related preoperational tests performed between June 1, 1982, and December 31, 1982, approximately 4 tests were not witnessed by Quality Assurance to verify proper performance.

.c. Quality Assurance records indicate that of the total pre-operational test steps performed for tests conducted between June 1, 1982, and December 31, 1982, Quality Assurance witnessing of test performance covered only approximately one to two percent of the test steps

. performed.

Response

None of the examples cited involves noncompliance with the NRC requirement for performance of testes in accordance with written test procedures.

Similarly, none of the examples cited demonstrates noncompliance in CE-1-A to the monitoring of pre-operational testing activities.

Example a:

The June 18, 1981, Quality Assurance policy memo does not require witnessing test activities by Q.A. personnel. Conversely, it does i

not restrict Q.A.'s monitoring of preoperational testing to only witnessing of tests.

All pre-operational audits verify various aspects in the field. Most l Of them, but not necessarily all, involve actual observations of test l activity. Our experience'shows that other aspects of the preparation and conduct of the test are also important. These aspects impact the validity of the test as well as the safety of the workers and.testors working on the system. Among these items are completion of the prerequisites for the tests, verification of instrument calibration, observation of housekeeping in the area, pre-op tagging and the re-entry controls'for systems under test, and conformance of the test l to the FSAR requirements _and acceptance criteria.

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Example b:

Paragraph 4b of-the-Violation identifies four tests conducted between June-1, 1982 and December 31, 1982 which were not found to have been

. witnessed by Quality Assurance. As described previously, witnessing of tests is.not reuqired. Our review indicaes that Q.A. is properly

' monitoring these test activities. From our contact with the NRC inspector, the procedures listed below are concluded to be the ones referenced. The status of Q.A. monitoring is discussed.

RC 63.11 - Air-operated Valves and Motor Operated Valves.

The test is complete. QA's involvement is a surveillance and an audit report. Both were conducted with testing in-progress. A total of 58 steps were observed out of 638 steps in section 9.0.

RH 67.10 - Residual Heat Removal The test is complete for Revision 3. QA witnessed field testing activities conducted in accordance with Revision 2 of the

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preoperational test and documented this with a surveillance. A post test audit of Revision 2 was completed also. A Post Test Audit was done for the Revision 3 of this test.

WO 115.10 - Chiller (Control Room)

The test is still in progress with train A testing complete.

Train B of the system is to be witnessed by operating QA when this portion is conducted in June 1983 (under the present schedule).

BR ;B.10 - Boron Thermal Regeneration This test is complete. The Operating QA Department covered activity. associated with this Pre-Op test but did not witness test steps in the field. A post test audit of' documentation was completed.

Example q.-

The cmount of' testing which should be observed by QA in the field in Jorder to determine the validity of the test is not specified.- The criteria for Commonwealth' Edison Quality Assurance coverage of Pre-0perational tests is that they must be involved'in each.one as well as~the system demonstrations. This involvement will include-the

' activities previously identified and will be documented by audit and surveillance. Also, the Quality Procedure has been revised to. provide additional ~ clarity'as to the Quality Assurance Pre-Op coverage. This Vi! _ _ _

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.s will be documented by audit and surveillances. Direct observation of testing activity is part of virtually all of the Pre-Operational test covered by Quality Assurance. Observations depend upon the length and complexity of the tests. Because of the varying lengtns of time needed to conduct the tests, and the varying complexity, it is not possible to establish a criteria in terms of time or terms of steps such that after the time has elapsed or the steps have been counted, it may be concluded that testing is acceptable.

The obligation of the Quality Assurance Department to cover the testing program and to observe field testing activities as identified in the June 18, 1981, letter from the Manager of Quality Assurance to the Operating:and Construction QA supervisors is clear to all con-cerned. It is the responsibility of the Site Operating QA supervisor to determine when he has adequately covered the test activities for a particular test based on conditions observed in the field.

After a meeting with the site QA organization in late 1982, QA Management directed an upgrading of the audit reports to more clearly

-describe our coverage of the testing program. These changes were noted in the inspection report in paragraph 7 even as the inspection was in progress. Members of the QA group at LaSalle visited Byron station to provide training in lessons learned during pre-op test coverage at LaSalle Station. Furthermore, a member of LaSalle QA Group spent several weeks at Byron to confirm that pre-op test coverage was consistent with LaSalle. Additionally, a member of the QA group, at Quad Cities station with a strong operating background, spent nearly two weeks at the station to be certain that our auditors were sensitive to good operating practices as they affected the test program.

It is concluded that no additional measures are needed.

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