ML20093L115

Responds to NRC Re Violations Noted in Insp Repts 50-454/84-32 & 50-455/84-25.Corrective Actions:Nonconforming Matls Evaluated,Records of Receipt Documentation Established & Welding Deficiencies Corrected

ML20093L115
Person / Time
Site:	Byron
Issue date:	09/18/1984
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20093L106	List: ML20093L115
References
9131N, NUDOCS 8410180315
Download: ML20093L115 (8)

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- Commonwealth Edison 1 One First Nationti Plaza. Chicago. Illinois

] Address Reply to Post Office Box 767 (1. Chicago. Illinois 60690 -

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September 18,-1984 L

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Mr. James G. Keppler Regional-Administrator

-U.S. Nuclear Regulatory Commission Region III

.799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

' Byron Generating Station Units 1 and 2 I&E Inspection Report Nos. 50-454/84-32 and 50-455/84-25 Reference (a)': July 30, 1984 letter from J. F. Streeter to Cordell Reed.

Dear Mr. Keppler:

Reference (a) provided the results of an inspection at Byron by Messrs. D. Hayes and K. Connaughton from April 26 th. rough July 17, 1984.

During.that inspection it was found that certain activities were not in compliance with NRC requirements.-- Attachment A to this letter contains

. Commonwealth Edison's response to the Notice of Violation which was appended to reference.(a).

As requested, the response to Violation 3 addresses the effectiveness of-previous actions taken to correct deficiencies in components supplied by Systems Control Corporation.-

Please address any further questions you may have regarding this matter to this office.

Very truly yours, T k TM "

W D. L. Farrar

- Director of Nuclear Licensing

.Im Attachment

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' ATTACHENT! A '

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. Response to-Notice of Violation

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VIOLATION'l,

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?Ap'pendix'B'.to'10 CFR Part 50, Criterion XV states, in part,

. Measures lshall.be established to control' material, parts or components which 9

'do not conform to requirements in order to prevent their inadvertent use or linstallation." lThe Byron" Safety Analysis Report, Chapter 17 and the:

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- Commonwealth' Edison Topical.' Report CE-1-AL provide the basis for the Quality

.' Assurance Program at the Byron Station. Section 15, " Nonconforming Material,

? Parts or. Components and Operations," of CE-1-A~ requires that' items or iconditions whichLare found nonconforming to requirements.or which.are lacking f

required inadvertent use'or. installation..It further requires that

nonconforming items.be identified and documented and,'if accepted."as-is" or

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reworked to an acceptable condition, be identified through documentation irecords in a manner that will establish the condition as installed. Quality

, Procedure QP No.'15-1 implements the above requirements.

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Contrary to the above:?

Ta. :The licensee-failed to establish and.maint'ain documentation of material receipt' inspection, -identified conditions, and _ final disposition for

-nonconforming equipment included in Shipment No.195 from Systems Control

-Corporation

.u l b.' - Hatfield Electric Company (HECo) failed to ~ establish and maintain idccumentation for nonconforming conditions identified and corrective action' taken as a result of inspections' performed pursuant to HECo QA/QC ma -

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' Memorandum No.'345..

CORRECTIVE ACTION TAKEN 1a. 'The nonconforming materials identified in Shipment #195 have been

' y' evaluated' and records of receipt documentation have been reestablished.

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'b'.; 6 As established in the program identified in QA/QC Memroandum No. 345, the

. welding deficiencies identified were corrected and reinspected. This

' program was concluded in approximately April, 1983 and inspections'are on

file.in the contractor's.QA vault. The.repaireo components have been

" installed.

CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCONPLIANCE 7

a.;:All site contractors performing'wcre notified of this occurrence and it-safety related work and applicable iCommonwealth Edison Departments

wasre-emphasizedtothemthatlnonconformingmaterials,itemsor components must'be properly identified and dispositioned and all safety related materials,-items or components must be properly receipt inspected

'and released for use prior to initiation of fabrication or installation.

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' b.

This item'has been discussed with tne responsible. personnel-involved.

Should deficiencies-be found in offsite vendor supplied material /.

equipment which. require the licensee to utilize.its onsite contractor inspectors to execute a reinspection program a CECO NCR shall be

. initiated delineating program-requirements.

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0 ATE WHEN FULL'COWLIANCE WILL-BE ACHIEVED All actions are complete as of September.5,1984.

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FVIOLATION 2.

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iAppendix~B to 10'CFR Part 50,. Criterion VII states,~1n'part, t" Measures shall be' established to assure that purchased material, equipment, Vand. services,1whether purchased.directly or through contractors and subcontractors,Econform to the procurement h aants. These measures shall

include' provisions,L as appropriate. for source. evaluation and, selection,'...."

?Cc9aonwealth Edison Topical ReportLCE-1-A, Section 4." Procurement. Document GControl," requires that prospective bidders.for each specification be on the Approved Bidders List.(AEL) and that where bids are obtained from prospective s

bidders from other than thoseLlisted on the ABL the bidders be evaluated and W

. approved as. acceptable-prior-to award. Edison Purchasing, based upon its evaluation ofithe bids and the purchase requisition and based upon review and

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,.. approval.of. the' bids by the Project Engineer and Quality l Assurance, shall' gz ccanduct necessary: negotiations'and clarifications ~and make the. award to a

bidder on the ABL.

l Con'rary to-the above:

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Th'e[ licensee purchased localLinstrument panels and main control boards

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land vertical panels /from Systems: Control Corporation 1(SCC) but SCC was

,not on the ABL.as a_supp)ier.of that' equipment.

b. ; Safety-related_ equipment was, procured from~ SCC after it had been removed-from the AEL.i '

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1 La. CORRECTIVE ACTION TAKEN:

'Althou p theLABL' listed SCCLas an approved vendor for only cable pans

'and hangers, appropriate reviews had been conducted for each type of

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equipment prior to issuance of each of the. Byron /Braidwood purchase w'

- orders. ; Recurring quality control problems with SCC equipment eventually

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11ed ta suspension-of the' approval for all types of equipment purchases from SCC.-

.For the' Byron Station, Systems Control, Corporation was awarded contracts k'

- 1to supply cable pans and hangers, main control boards, and instrument

< racks. The specification,' purchase order and date of award for each contract is as follows:~

Cable Pans and' Hangers

.F-2815-P.O. 200038 July 14, 1976 Main Control Boards F-2788 P.O. 207534 February 9, 1977 Local: Instrument Racks F-2809

.P.O. 219596 January 5, 1978 Prior to the award _ of 'each 'ofL the above purchase orders, the Commonwealth l

Edison engineering' department performed (or had Sargent & Lundy perform)

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' a technical evaluation to establish the technical acceptability of the product line. Also,-prior' to the' award of each of the above purchase R:

? orders, Commonwealth Edison Quality Assurance performed a documented

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- < review to~ verify that the: Systems Control Corporation Quality Assurance Manual..was acceptable'and applicable for the product line to be purchased.

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~In' addition,1early.'in'1975,:in connection with bidding on LaSalle m

fSpecification J-2560;for. cable. pans and hangers,.the: Systems. Control.

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Corporation. Quality; Assurance Manual was submitted to Commonwealth Edison

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for review and approval.,The-Quality Assurance program was. reviewed and -

found to~be acceptable and a letter dated-July 16,c1975, signed by

QualityTAssurance'and-Station.NuclearLEngineering was sent to1the Purchasing Department recommending that

Systems Control Corporation be-added to the' Approved Bidders; List' for. cab 1'e pans and hangers. However, f

? each time. an. additional product line Lwas approved for purchase from.

Systems Control Corporation,-an' additional letter from Engineering / Quality-

Assurance was not sent.to the Purchasing, Department-identifying the.

approval of'the new product line..It should be noted that the required engineering land quality' assurance reviews were properly performed and sdocumented prior to the award of. the three referenced-purchase orders to.

Systems Control. Corporation.L; Furthermore,' Purchasing issted each purchase order based:on a documented Quality Assurance Department!

. sign-off; indicating ~ that the technical'and quality requirements' for the 3

. purchase were complete'and acceptable.

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1a~.,

CORRECTIVE ACTION TAKEN TO AVOID FURTER NONCODPLIAPCE'

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( As,a result of the incomplete listing o.f approved product-lines on the

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- AEL.for Systems Control Corporation,: the following corrective actions have been taken:

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'1); ' Vendors which were. reviewed and approved to supply safety-related 7s'

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equipment or services for a single specification and not for generic types of= services or. equipment have not,'in.the past, been placed on

- the AEL. : These vendors were " Approved for Spec Only". It is now

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required that these vendors be added to the ABL and be identified as

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being approved only for the -specification.for which review and approval'had beeniobtained.'

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A review has been' conducted tol assure that product lines ~for~which a vendor has been approved are_ properly. listed on1the Aet.

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Quality Procedure Q.P. 4-1 was' revised on June 26,'1984 to emphasize

that safety-related purchase requisitions are~to be reviewed, prior

~to placing the' purchase order, to verify that the vendor is on the

AEL for the procurement being processed.

)a.G DATE-MIEN FtLL COPPLIANCE WILLEE ACHIEVED l Corrective actions were complete as of. August 10, 1984.

b. s CORRECTIVE ACTION TAKEN N

. The:eicpt' combination indicator -light / control switches which were

. procured per Change Order AN to P.O. 207534 from Systems Control s

Corporation will be: returned to the vendor, even though they were not

. manufactured by SCC.

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b. -CORRECTIVE ACTION TAKEN TO AVOID FURTER NONCOWLIAICE

^ Commonwealth Edison' Company Quality Procedures.Q.P. 4-2, Attachment A,

. Paragraph 4.10,.Rev. 2 and Q.P.'4-51, Attachment A,. Paragraph 8.0, Rev. 0

have.been revised...These procedures address vendors removed from the ABL for work performance reasons and now state that " change orders shall not:

be' issued:which add to the original procurement order".

b.'.:DATE WHEN FULL COWLIANCE:WILL BE ACHIEVED

The eight. switches were rejected on June 14, 1984.The Quality Procedures'were revised on June 26,-1984.

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. 1 VIOLATION 3 Appendix B to 10 CFR Part 50, Criterion XVI states, in part,

_ " Measures shall be established to assure that conditions adverse to quality...are promptly.. identified and corrected." Commonwealth Edison JTopical Report CE-1-A, Section 16, " Corrective Action," requires that a corrective action system be used to assure that defective material and equipment.are promptly: identified and corrected and to provide followup to assure corrective measures are effective. Quality Procedure QP No. 16-1 iimplementssthe above requirements..

Contrary to the above, the licensee failed to take-timely and effective actions to ensure deficiencies during the period May 1977 to February-1981 on cable pan hangers supplied by Systems Control Corporation were identified and corrected as evidenced by:

a.' The identification of deficiencies on at least 30 hangers in August 1982 and on at least 60-in August 1983.

b.. The identification of_ deficiencies in licensee audits, inspections by the electrical contractor,' and a~ previous item of noncompliance issued by NRC Region _III in December 1980.

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The resolution of NCRs F-850/F-885 failing to consider the possible affect of observed deficiencies (discrepant and/or missing welds)_ on the adequacy of the most highly stressed hanger connections in the plant.

RESPONSE' In 1980 the tEC found that Commonwealth Edison has not taken effective and.. timely corrective actions to assure that deficiencies in Systems Control's

' fabrication activities were corrected.- Inspection Report Nos. 50-454/80-04 and 50-455/80-04 referred to a number. of audits, surveillances, and inspections; several dealt with welding on cable pans and hangers. Because the NRC's 1980

' inspection disclosed deficiencies on local instrument panels which were similar to deficiencies identified in 1977 on cable pan hangers, a Notice of Violation was issued..

In response, Commonwealth Edison indicated that source inspections Lwould be performed under the direction of the CECO Q.A. Department on all

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future shipments _of safety-related equipment from Systems Control and that source inspections had been conducted since February 1980. For cable psn

- hangers shipped to Byron, this commitment was fulfilled with the exception of one hanger which was included in a shipment of cable pans. Improved site receiving inspections were also instituted by the Project Construction Deparment..

The addition of source inspections was intended to assure the general

? quality of components accepted at the site. Such inspections, performed on a sample basis,.were not expected to provide an independent demonstration that there were no deficient items in a shipment. They were, however, expected to assure that significant-deficiencies would be identified and dispositioned.

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... ~As1 described in the inspection report,-a relatively'small number of J

_ iweld deficiencies were identified on cable pan hangers.over the ensuing months

andtyears. Some of these. deficiencies probably existed on hangers which were linstalled.or in storagefon site in January,1981. Some may have escaped u

idetection'in the subsequent ~ receiving inspections because not every item was checked.J The corrective actions taken were~not. intended to. identify.and correctiall deficiencies. Rather, they were. intended to. check the general

quality-.of future shipments. The NRC accepted this approach.- This was.

acceptable because it was then believed that there were only isolated weld

. deficiencies in SCC supplied cable pan hangers which did not pose a safety concern.

In January 1981 the need for the extensive reinspections which have

_ irecentlyltaken place was not apparent.

CORRECTIVE ACTION TAKEN a) As identified in the inspection' report, all of the deficient cable pan hangers.were either repaired or analyzed and found acceptable.

b) f All' cable pan and cable-pan hanger ' deficiencies identified in-licensee audits'or inspections by the electrical contractor have.been reviewed and

".dispositioned appropriately.

c): :The disposition of PCR's,- F-850 and F-885 required examination of 358 SCC shop-welded connections. This sample covered all commonly used connection-

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types'and included.40 connections which were highly stressed. The MC requested _that a more conservative. approach.be taken. -Through analysis, it was'shown that the most highly stressed connections could safely accommodate.

significant weld quality reductions..

-CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOWLIANCE Commonwealth Edison has stopped buying equipment from SCC. As

. described in the testimony of K. T.L Kostal~ and L.. Johnson to the ASLB,

. extensive reinspections and reanalysis provides assurance of the acceptability _

of each type of. equipment supplied by SCC..

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-DATE WHEN FtLL COWLIANCE'WILL EE ACHIEVED.

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-September 18, 1984..

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