ML20112C622

Responds to NRC Re Violations & Proposed Imposition of Civil Penalty Noted in Insp Repts 50-454/84-32 & 50-455/84-25.Corrective Actions:Qa Audit Re Equipment Insp & Weld & Stress Evaluations Conducted

ML20112C622
Person / Time
Site:	Byron
Issue date:	01/04/1985
From:	Reed C COMMONWEALTH EDISON CO.
To:	Sniezek J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
9527N, NUDOCS 8501110283
Download: ML20112C622 (6)

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[ N Commonwealth Edison

- ) one First Nitionit Plaza. Chiccgo, Ill: nod k3 'l Adoress R; ply to: Post Office Box 767 (j/ Chicago, Illinois 60690 January 4, 1985 Mr. James Sniezek, Deputy Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Byron Generating Station Units 1 & 2 Civil Penalty I&E Inspection Report Nos. 40-454/84-32 and 50-455/84-25 Reference (a): December 4, 1984 letter from J. G. Keppler to Cordell Reed.

Dear Mr. Sniezek:

. This letter contains Commonwealth Edison's reply to the Notice of Violation and Proposed Imposition of Civil Penalty which was issued by the NRC in reference (a). Our check for $40,000 is also enclosed.

The Company does not contest the facts set forth in the Notice of Violati;n on which the imposition of the civil penalty was based. However, the-Company does not admit or deny that the violation occurred. The circumstances surrounding this matter have been thoroughly explored in the remanded operating license hearing before the Byron ASLB. One of the most significant issues underlying this matter is the adequacy of the equipment supplied by Systems Control Corporation. An extensive inspection and analytical effort has confirmed the adequacy of equipment supplied by Systems Control Corporation in its as-built condition to the satisfaction of the Staff.

Commonwealth Edison communicates on an almost daily basis with the M C Staff. We are well aware of the necessity for accuracy and completeness

'in those communications so that the P C is fully apprised in all matters within its regulatory responsibilities. We have undertaken programs described in Attachment A, the detailed response to the Notice of Violation, which deal with both the specifics underlying the Notice of Violation, the

_other ambiguous statements referred to in reference (a) and the general issue of accuracy and completeness in written communications to the EC. As set forth in Attachment A, we have satisfied ourselves that the events giving rise to the Notice of Violation represent an isolated occurrence.

Very truly yours, 85011h0283850104 PDR A x 05000454 PDR Cordell Reed G_

Vice President Attachments y cc: J. G. Keppler 9527N

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.s Attachment A Response to Notice lf o Violation and Civil Penalty

, Viol'ation

$ In thc Commonwealth Edison January 26, 1981 response to the Noticelof Violation-issued December-30, 1980 for Noncompliance Items ,

No. 454/80-04-01; 455/80-04-01, the licensee stated, in part, "For Systems' Control Corporation, source inspection has been conducted for all safety-related equipment shipoed since February'1980 and source-inspection will be conducted on all future shipments involving Systems Control. These inspections have been conducted by Pittsburgh Testing Laboratory (PTL) under the direction of the Byron Quality Assurance Department. The inspections cover welding, equipment identification, sealing of instrumentation lines and other '

. specification _ requirements."

' Contrary to the above statement, all safety-related equipment shipped since February-1980 had not been source inspected for welding by PTL or any other non-SCC organization as of January 26, 1981. Equipment not source inspected for welding during the period February.1980 through January 26, 1981 included two main control boards, four DC fuse panels, a cable pan hanger and numerous wclded items covered by Material Receiving Reports 8453, 8773, 8907, 8964 and 9283.

Response

The statements in the above citation correctly reflect the ,

facts to the best of our knowledge with one exception: there were three control boards'which were not source ~ inspected rather than two (2PM04J, 2PMllJ and 2PM12J).

In order to determine why the Commonwealth Edison Company response of January 26, 1981 inaccurately stated the extent of source inspections performed by Pittsburg Testing Labs at the 4- Systems Control Corporation plant in Iron Mountain, Michigan, during-the period February 1980 and. January 1981, a > review of the events i L which;took place at that time was conducted. This review examined related. documentation, including shipping documents from Systems Control and inspection reports from PTL. In addition, knowledgeable individuals from CECO and PTL who were at the Byron Site at-tF1 time C + thelevents took place were interviewed.by the CECO Director of Quality Assurance. After conducting the interviews, reviewing documentation and examiningLthe process by which the_ January 26, 1981 response to.the NRC Staff was prepared, it was possible to' draw certain conclusions as to the reasons why source-inspection:was not performed on all SCC equipment shipped after February 15, 1980 and prior.to: January 26, 1981.

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.,FirstFa:significant source. inspection program was

_% :initiatediby Commonwealth Edison in February, 1980 which continued y' ;on1throughd1981 and.was.actually being performed at the time the J- _ Commonwealth Edison Company response,was being prepared in January, 41981'.,iDuringithissildmonth period source inspections were performed 9 -everyinonth._ -This< included 21 trips 1by PTL inspectors traveling W- from; Byron to the SCC plant in Iron Mountain, Michigan. (We

~ previously indicated 5that there were 27 source inspection trips by q PTL;;that4 number" erroneously included six4PTL inspections of Systems y , Control equipment at the Byron site.) The inspection trips lasted

~from?two to-five days.'As a result, Commonwealth Edison Byron Site

" Quality 1 Assurance and Project Construction Department personnel-who

were. working,with electrical equipment were aware that PTL was

regularlyiperforming source-inspections at SCC. During the f interview's, it appeared that'the-overall impression with M ciCommonwealth Edison Company site personnel was that PTL was at the SCC-plant regularly in~. order to inspect all shipments.

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Second,- the Jan'uary 2'6, 1981-Commonwealth Edison response ytf f to theiNRC; Staff .was prepared :and processed 'in the proper manner-

,$ Itfappearsathatsthe Project Construction Department. prepared the

, ,lfirstJdraftiof the response'with possibly some input from Site d

_, EQualityiAssurance. The; draft.was then reviewed and' commented on by r

n 1 .; General ~0ffice. Quality Assurance. -Therefore' two departments'and at~

Y f-Lleas't.five..and possibly;six. people wereJinvolved with preparing, kfcommenting on -or.' reviewing thecresponse before it was sent to our

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"l g^ : Nuclear Licensing Department. SItEshould be noted that on January 5, '

'1981 the, then current,fsite Quality Assurance Superintendent was

' 7 promoted,toda Enew ' position .which was- not..at the - Byron site. The new g _ 'jQuality! Assurance. Superintendent'.had-been previously working at~our.

~: '- 'Dresdensplant; It"was during this time =that the response was being s

prepared <at thensite. ~During'the transition between~ Quality 3.. -

y yp g_ Assurance wording:in'the. $ Superintendents response;may not have.taken the Tverification place. of the" accuracy .ofj the.

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!N - ' Third, it?wasLperceived that the NRC' citation

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. '50.-454/80-04-01] to which Commonwealth Edison was responding, was V

tissued:because Commonwealth Edison Yroject-Construction Department cwaive;d?fina1LsourceLinspection on 20 safety-related' instrument racks

TinTthefperiod10.ecember,fl979.to February, 1980.; Thu.s, site. o

_p Lpersonnel maylhaverbeen preoccupied with the issues associated with-elocal% instrument :panelsY - On February '15, 1980,: Site' Quality a M Assurancefissuedialletter to PTLodirecting'them to performfa final N , 'sourcelinspectionion safety-relatedJinstrumenttracks. There is no

^ +n Icom' parable 71etter.with respect-to other: SCC supplied equipment, even

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.thoughf somelsource Einspections of' cable; pans took place ~between

1. February?l5,01980iand January 126, 1981. .A combination:of these

'Myfactorsmost'likelyEresulted-ininaccurate.wordingintheresponse, -

p Butvin';theffinalianalysis!it cannot.be" determined exactly'why the cresponss did"not accurately reflect what~had taken place over the 11 lmonthsib5 tween February,E1980 and_ January,'1981'..

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As described in the testimony of Mr. George Marcus before the Atomic. Safety and-Licensing Board, extensive source inspections

,t .were-performed by PTL on equipment shipped from SCC after February,

'1980'.';TheseJsource inspections, which were acceptab2e to the NRC

" Staff as corrective action, provided assurance that the equipment

' inspected met regulatory requirements. Table 1 attached describes the source ir.spections which took place subsequent-to February, 1980.

Corrective Action Taken-

.  ; 1 There is no specific corrective action feasible in g- connection with this matter. The individuals involved in determining i _ _the scope'of the PTL source inspections for the January 26, 1981

' written ~ response to.the NRC Staff no longer have any responsibility for:such-communications. In order to determine whether other written

D representations to the Staff may have been inaccurate, the Quality yp . Assurance Department. conducted a special audit. That audit report

dated July-24,,1984 established that Commonwealth Edison is properly

-  ;  ! implementing all other commitments made to the NRC Staff arising'out of!NRC items of noncompliance.

'The failure to conduct source inspections of SCC equipment

. led the Company and the NRC Staff to question the adequacy of the F +' equipment sucplied by SCC. Extensive weld reinspections and stress evaluations have been conducted to assure the adequacy of the installed ~ SCC equipment and components. 'These efforts were described -

in detail'in the testimony of--Kenneth T. Kostal and Bradley.Maurer .

during thetremanded Byron operating license hearing. All categories qs Kof equipment have been found to be acceptable including those for.

• -which source inspections were not conducted in g l980; -i

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' Random" samples of.various-types of._ cable-pan' hangers have_been

- ' subjected to detailed weld inspection.and engineering. evaluation at. ,

Evarious times...All accessible hanger connections'have been inspected

'for# missing welds.

s Selected types of vinaccessible connections have -

,- been inspected for. missing welds. No significant discrepancies _were detected. This fact, combined with.the load-bearing redundancies ii . >

which exist;in'the; cable tray hanger system'and the conservative

• • design /andLanalytical criteria utilized.by S&L provide assurance'of the adequacy-of. cable pan hangers.

Similarly,. random; samples of.various types of cable pan weld' connections have-been.rei.nspected'in the plant. No design

, , isignificant deficiencies have been found and various design '

conservatisms have been identified though additional engineering ,

evaluations. The adequacy oflthe installed cable pans have been L_.  ? demonstrated.

'q]l. [The:structuralwelds.inthemaincontrolboardshavebeen completely! reevaluated using detailed finite element modeling

itechniques to compute-local stress loadings. Field inspections have

confirmed the structural adequacy of all of those control boards.

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Table 1 BYR0N STATION Source Inspection at System Control Corporation (Safety-Related Shipments)

Shipping Number of Items Equipment Date Shipped Inspected Instrument' Racks 4/22/80 8 8 F/L-2809 4/29/80 10 10

'5/12/80 9 9 5/14/80 1- 1

'6/05/80 10 10 6/23/80 9 9 7/29/80 6 6 Hangers 3/10/80 1 -

-F/L-2815 -5/20/81 39 34 10/28/81 168 57 Cable ~ Pans 3/10/80 277- -

, - F/L-2815 5/30/80 227 -

6/30/80 328 -

7/16/80 68 -

9/26/80 487 100 1/08/81 23 15 1/30/81 136 35

- 5/20/81 201 113 8/05/81 1671 1571

, ~10/28/81 139 99 Control Boards' 3/06/80 2 -

F/L-2788 3/27/80 1 -

5/14/80 2 -

6/26/80 2 -

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Actions Taken to Avoid Further Noncompliance Special efforts will be made to improve communications among the individuals involved in the preparation of responses to NRC

- noncompliances to. avoid future inadvertent misrepresentations.-

Individuals responsible for preparing responses will be reminded of their. personal responsibility for the accuracy of information provided to the NRC.- Seminars for key individuals will be held for

.this purpose at Eyron, Braidwood and the General Office during January, 1985. Similar seminars will be held at the other nuclear stations during.the first quarter.of 1985. A lawyer will attend each.

of these seminars.to discuss the aspects of the NRC's Enforcement

. Policy relating to material false statements and satisfy any aj .

questions'which may exist. The circumstances which led to this civil penalty will also--be reviewed with these individuals.

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