ML20207L781
| ML20207L781 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 12/15/1986 |
| From: | Williams J TOLEDO EDISON CO. |
| To: | Paperiello C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1-686, NUDOCS 8701120344 | |
| Download: ML20207L781 (3) | |
Text
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TOLEDO Docket No. 50-346 License No. NPF-3 JOE VVituAMs. JR
% v e m ru.,
(419) 243 PE Serial No. 1-686 H ei 243 5r3 December 15, 1986 Mr. C. J. Paperiello, Director Division of Reactor Safety United States Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Dear Mr. Paperiello:
Toledo Edison has received Inspection Report No. 50-346/86028 (Log No.
1-1496) and provides the following response.
Violation:
10 CFR 50, Appendix B, Criterion V, as implemented by the Toledo Edison Quality Assurance Program for Station Operation, Section 17.2.5, requires that activities affecting quality be prescribed by documented proce-dures or instructions.
Contrary to the above, activities affecting quality were not accomplished in accordance with documented procedures or instructions in that verbal direction was used to resolve dimensional problems associated with installation of Raychem insulation materials on Class IE electrical splices.
Response
Acceptance or Denial of the Alleged Violation t-Toledo Edison acknowledges the alleged violation.
I Reason for the Violation oe n:
nna The root cause of this nonconformance is the interpreta-got tion of the existing Quality Control Instructions (QCI) to o
permit the QC inspectors to allow work to continue based on engineering's verbal acceptance of Raychem dimensional
,g eu deviations.
no
/
OO
,,4 This condition (acceptance of verbal direction by QC) is N
considered an isolated case applicable to the Raychem gjj installation.
It resulted from the unique, high level
C10 interaction required between Engineering and field install-ation personnel to ensure as-built splices met Raychem speci-fications.
mE TOLEDO EO; SON COMPANY EO. SON I'LAZA 300 MAUGON AVENUE TCL EDO, OHO O'?
IEC/
l Dockst No. 50-346
- License No. NPF Serial No. 1-686 December 15,'1986 Page'2 The Raychem insulation installation specifications, including dimensions, were identified on an engineering sketch included in each MWO package.. Installation was accomplished in accordance with Maintenance-Procedure (MP)'
1410.24, Installation and Termination of Electrical Cables.
Toledo Edison Quality Control (QC) inspected each Raychem installation in accordance with the guidance given in QCI 3103, Maintenance. QCI 3103 establishes the system and-defines the methods by which QC provides quality verifi-cation of maintenance activities. The QC inspectors utilized a checklist (QCI 3142, QC Checklists) as a tool for implementing and documenting the quality verification of each individual repair.
During installation, some minor dimensional deviations (e.g. tang width, connection length) were observed that exceeded the conservative acceptance criteria of the engineering sketch provided in the MWO package. A manage-ment decision was made to permit work to continue if the engineering department verbally accepted the dimensional deviation as being within Raychem specifications. Revised sketches would subsequently be issued by engineering reflecting revised acceptance criteria still within Raychem specifications.
The minor dimensional deviations were identified by the QC inspector on the checklist and signed off as unsatisfactory.
The QC inspectors, based on the previously made decision, allowed work to proceed. When the engineering sketch was 4
revised and received, the checklist item was revised from unsatisfactory to satisfactory.
It should be noted that, although the work was allowed to proceed, in no cases were the actual MW0s signed off by the QC inspector as accepting unsatisfactory work. Section 6.3 of QCI 3103 states, " Prior to accepting the work authorized by the MWO, the QC inspector shall perform a paperwork review of the completed MWO. This paperwork review shall confirm the following... QC checklists, Inspection Plans, or Hold / Witness Points applicable to the MWO work have been completed and are satisfactory...".
The unsatisfactory checklists would preclude the MWO from being approved until the revised sketch had been received.
Docket No. 50-346 License No. NPF-3 Serial No. 1-686 December 15, 1986 Page 3 Corrective Actions Taken and Results Achieved On October 2, 1986, the QC Supervisor issued a written
- directive and orally instructed the QC Inspectors assoc-isted with the Raychem effort that any in-progress Raychem/ taped terminations for which unsatisfactory condi-tions~are identified (i.e., conductor diameter, tang width, connection length, etc.) would require written instructions /
sketch revision prior to continuing work. The results achieved were full compliance to the above directive in that for dimensional deviations identified, work was discontinued until the appropriate engineering instructions /
sketches were revised to reflect the correct dimension.
QC has performed a review of the Raychem associated check-lists, completed on November 18, 1986. Of these checklists, a small percentage (less than 2 percent), were found to have been initially identified by the QC inspector as having a dimensional deviation. In all cases, the dimen-sional deviations were resolved prior to final acceptance of the work and in no case was the quality of the work degraded.
Additionally, QC inspectors have been directed that, in accordance with the Nuclear Quality Assurance Manual, Section 5.4, oral instructions contrary to established instructions, procedures, or drawings are unacceptable.
Date When Full Compliance Will Be Achieved Full complainee has been achieved with the resolution of the affected items and the directive provided to the QC inspectors that they are not to utilize oral instructions in lieu of approved written instructions.
Very truly yours, ht
- :A
- JCS:plf cc: DB-1 NRC Resident Inspector