ML20210U188
| ML20210U188 | |
| Person / Time | |
|---|---|
| Issue date: | 01/30/1987 |
| From: | Baker E, Conway J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20210U108 | List: |
| References | |
| REF-QA-99901072 99901072-86-01, 99901072-86-1, NUDOCS 8702180409 | |
| Download: ML20210U188 (17) | |
Text
ORGANIZATION: JOHNSON CONTROLS BENSENVILLE, ILLIN0IS REPORT INSPECTION INSPECTION N0.: 99901072/86-01 DATES: 12/15-17/86 ON-SITE HOURS: ?4 CORRESPONDENCE ADDRESS: Johnson Controls System Engineering & Construction Division - Midwest ATTN: Mr. George M. Danko .
Operations Manager 720 Industrial Drive Bensenville, Illinois 60106 ORGANIZATIONAL CONTACT: Martin R. Cohen, OA Manager TELEPHONE NUMBER: (312) 595-5650 NUCLEAR INDUSTRY ACTIVITY: Supply, install, and test instrumentation for ,
heating, ventilation, and air conditioning (HVAC) systems.
/
ASSIGNED INSPECTOR: _
5 4hrgu _ /-2/.87
. T. Conway, Reacti Inspection Section (RIS) Date OTHER INSPECTOR (S): T. Tinkle, Censultant
,. /
AoPPOVED BY: , - 7 $0 [N 87 E. T. Baker, Acting Chief, RIS, Vendor Progran Branch Date INSPECTION BASES AND SCOPE:
A. BASES: 10 CFR Part 50, Appendix B and 10 CFR Part 21.
B. SCOPE: This inspection was made as a result of an allegation pertaining to instruments supplied fer HVAC systems at the Byron and Braidwood nuclear facilities.
PLANT SITE APPLICABILITY: Allegation - Byron 1/2 (50 454/455) and Braidwood 1/2(50-456/457).
8702180409 870213 PDR GA999 EMVJOHC 99901072 PDR
ORGANIZATION: JOHNSON CONTROLS BENSENVILLE, ILLIN0IS REPORT INSPECTION NO.: 99901072/86-01 RESULTS: PAGE 2 of 11 A. VIOLATIONS:
None.
B. NONCONFORMANCES:
- 1. Contra'ry to Criterion V of Appendix B to 10 CFR Part 50, Section 1 of the System Engineering and Construction Division (SECD) Quality Assurance Prngram Manual (QAPM), and Section 3 of ANSI N45.2, the responsibilities of QA personnel and Organizational charts No. I and No. 2 described in Section 3 of the QAPM do not reflect the present QA organization for Johnson Controls (JC) SECD in affect since May 1986. (86-01-01)
- 2. Contrary to Criteria II and V of, Appendix B to 10 CFR Part 50 and Paragraphs 3.2 and 3.2.1 of Section 3 of the QAPM, the SECD could not provide documentation that the Project Manager (PM) for the Byron and Braidwood Projects had been indoctrinated and trained for acti-vities affecting quality. (86 01-02)
- 3. Contrary to Criterior V of Appendix B to 10 CFR Part 50 and Paragraph 5.3 of Section 3 of the QAPM, Audit Report No. 60101 for the internal audit conducted on January 24, 1986 was rot reviewed by the Director of Quality Assurance (DQA) for closecut. (86-01-03)
C. UNRESOLVED ITEMS:
None.
D. STATUS OF PREVIOUS INSPECTION FINDINGS:
Nore. This was the first NRC inspection at this facility.
E. OTHER FINDINGS AND COMMENTS:
- 1. Allegation Beginning in July 1986 and continuing through December 1986, the Office of Inspecticn and Enforcement - Region III was contacted on several occasions by an unidentified alleger. The allegations addressed the following subjects: corrective action followup to internal audit findings, independence of the QA systems, qualifica-tion of persorrel, inspection surveillance reports, sign offs on purchase orders (PO) by non QA personnel, and supplyinc Westinghouse equipment that was not properly environmentally cualified. The
- ORGANIZATION: JOHNSON CONTROLS BENSENVILLE, ILLIN0IS REPORT INSPECTION N0.: 99901072/86-01 RESULTS: PAGE 3 of 11 allegations pertained to the QA progran in effect when JC-SECD supplied and installed instrumentation in seven safety-rela.ted and 15 nonsafety-related HVAC systems at the Byron and Braidwood facilities. The scope of work also included supplying personnel for the " testing and balancing" of each system.
The inspector evaluated various areas of SECD's QA program performed at JC's Bensenville facility for the HVAC systems for Commonwealth Edison Company's (CECO) Byron and Braidwood nuclear power plants.
Based on the results of a review of the implementation of QA/QC activities in specific areas, (e.g., training, internal audits, procurement document control, testing, inspection, and control of purchased material / services) of JC's QA program, which are documented in the following subsections of this report, the allegation could not be substant,iated.
- 2. Organization The following overview was obtained during discussions with the Quality Assurance Manager (QAM) for SECD-East and the PM for the Byron and Braidwood contracts. SECD became involved with the Braidwood Project in 1979 and ceased involvement with construction activity in 1981. Since that time SECD has provided replacement items for safety and non-safety systems and has supplied personnel to CEC 0 in support of test and balance work. Braidwood work was administered by the SECD-Midwest office in Bensenville until May 1986.
SECD became involved with the Byron Project in 1979 and ceased involvement with construction activity in the summer of 1984.
Since that time SECD has provided replacement items for safety and non-safety systems and has supplied personnel to Reliable Sheet Metal (a CEC 0 contractor) for test and balance work. Byron work was administered by the SECD-Midwest office in Bensenville until May 1986.
As a result of a declining nuclear business, SECD started relaasing and/or reassiening SECD QA personnel about June 1984. On-site OA inspectors at Byron were released between June and September 198d.
An on-site QA engineer was released in about Jaruary 1985. A senior QA engineer working under the DQA at SECD headquarters (Milwaukee) was released in 1985. In May 1986, a reorganization of SECD occurred to effect transfer of nuclear and associated QA activity from SECD-Midwest (Bensenville) to SECD-East (Philadelphia). As
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- ORGANIZATION: JOHNSON CONTROLS BENSENVILLE, ILLIN0IS REPORT INSPECTION N0.: 99901072/86-01 RESULTS: PAGE 4 of 11 part of this reorganization, the DQA at SECD headquarters was reassigned to another division. The Manager of QA at SECD-Midwest was released. The responsibilities of these two QA individuals were I transferred to the QA Manager SECD-East.
A review of SECD memo dated April 30, 1986 indicated that the SECD DQA was transferred to another division and the QA department was being reorganized. As part of the reorganization all nuclear related QA/QC activities were assigned to the QAM SECD-East. This individual is the Director of Record for all QA/QC programs and responsible for all aspects of the QA/QC program, including main-tenanca of Approved Vendor Lists (AVL), vendor audits, internal audits, control and distribution of manuals and procedures, personnel certification and training records, etc. All future nuclear industry work that requires a quality program will be the responsibility of SECD-East.
A review of SECD memo dated May 1, 1986 indicated that all quality responsibilities will be handled by the Philadelphia office, all nuclear project material sales contracts will be administered in the Philadelphia office, and Test and Balance contracts will be administered in the Midwest office. Another nemo dated May 13, 19P6 stated that the Philadelphia office needs to be placed on CEC 0's AVL prior to transferring nuclear contracts, the QA PM will be maintained ir the Philadelphia office; and until the transfer, procurement activities and receipt inspection will centinue to be performed in the Misest office.
The organizational charges outlined in the SECD memos cited above have not been incorporated into the QAPM (i.e., creanizational charts show the PM for Byron and Braidwood reporting to the Midwest Operations Manager, whn reports to National Manager, who in turn reports to the General Manager; and the Project 0AM located at Bensenville for Byron and Braidwood reports te the DQA who reports to the General Manager). (See Nanconformance 86-01-01)
- 3. 10 CFR Part 21 Compliance The inspe-tor reviewed Procedure QAS-1600-MIL, Revision 3 dated Jure 28, 19b:, This procedure outlires the requirements of 10 CFR Part ?1 acd the responsibility cf SECD personnel for compliance. The Panager of QA, SECD-East stated that potential or actual 10 CFR Part 21 items brve not been evaluated or reported by SECD-Bensenville. Thus, other documentatier en 10 CFR Part 21 activity was not available for review.
, a
- ORGANIZATION: JOHNSON CONTROLS BENSENVILLE, ILLIN0IS REPORT INSPECTICN NO.: 99901072/86-01 RESULTS: PAGE 5 of 11 A review of P0s indicated nany items are purchased by SECD as
" commercial grade-safety related." In some cases the P0 in.vokes 10 CFR Part 21 (e.g., P0 11993 to Validyne dated February 7, 1986).
In others, 10 CFR Part 21 is specifically not invoked by a note nn the P0 that states: "These items are safety related (commercial grade) and 10 CFR Part 21 is not applicable" (e.g.,
P0 122164 to Pyrotronics dated June 24,1986). This matter was discussed with the PM and the QA Manager, SECD-East. They indicated this practice is consistent with requirements issued by CEC 0, (ref.
CEC 0 letter dated March 15,1985). This letter was reviewed and contained the following. Many CECO P0s begin with a statement:
"These items are Safety Related-Commercial Grade and 10 CFR Part 21 is not applicable." On this type of order the vendor is not required 4
to have a Quality Assurance Program approved by CEC 0. This category i
3 includes equipment, parts, and material manufactured and sold as standard commercial grade produc~ts that do not have to meet any addi-tional requirements beyond those detailed in the vendor catalog.
CEC 0 uses this category to ensure that proper receiving inspections are performed on receipt. Prior to issuing a " Safety Related Commercial Grade" order CEC 0 engineering determines whether the specific commercial grade item can be used in a safety related application based on technical information in the vendor catalog.
One additional recuirement invoked by CEC 0 when purchasing a comIrercial grade safety related item is that the vendor is required to supply a certificate of conformance.
- 4. Training The inspector reviewed Section 3 " Organization" of the QAPM, and it was noted that the qualification requirements for the DQA, QAM and other key personnel who nanage and direct quality-related activities are documented in SECD job descriptions. Procedure QAS-211-BY, Revisien 9 dated April 5,1983 which addresses training and indoctri-nation of 0A and testing personnel vas also reviewed along with the training files for selected individuals. These files contained copies of resumes, qualification certifications, training documentation, and eye examination reports. The individuals included four QA Inspectors, DQA, QAM, and a QA Engineer. It was noted that the most recent eye exam in the file of the 00A was March 16, 1983. The QAM SECD-East stated that the Bensenville training file for this individual was incomplete, and the file is maintained in the Philadelphia offices.
With this one exception, the remaining files were complete and met the requirements of the QA progran.
' ORGANIZATION: JOHNSON CONTROLS BENSENVILLE, ILLINOIS REPORT INSPECTION NO.: 99901072/86-01 RESULTS: PAGE 6 of 11 According to the QAM SECD-East, he and a Level II Engineer from the Philadelphia office have been travelling to Bensenville si#ce May ;
1986 to perform QA functions such as P0 review and receipt inspection for safety-related items. The inspector was informed that the training files for both these individuals are maintained in the Philadelphia office of JC. Section 3 of the QAM PM indicates that !
the PM is responsible for setting required quality objectives within i the area of furctional responsibility and for attaining these objectives. The inspector requested the training documentation for the current PM, but documentation could not be provided.
The training files for individuals assigned as lead auditors for audits 20801, 30504, 50701, ar.d 60101 were reviewed. Documentation in the files for these individuals indicated they were certified lead auditors at the time the audits were performed.
- 5. Internal Audits The inspector reviewed Sections 3 and Section 19 " Audits" of the QAPM. It was noted that the DQA is responsible for an annual quality system audit of each site and project to measure overall effectiveness of the QA Program. Audits are to be performed with written procedures or checklists and a documented audit plan by trained personnel with the lead audito qualified in accordance with ANSI M45.2.23. A copy of the a:. report is sent to the PM for action, if required; and a copy cf the completed audit report is sent to the DQA and PM for review and to become part of the permanent record.
Nine audit reports dated from August 1982 throuah February 1986 were reviewed. Audit Report 20801 dated August 9,1982 resulted in five findings. Documentation indicates the findings were reviewed, resolved, and closed out. Audit Report 30504 dated May 26, 1983 resulted in four findings. Documentation ir.dicates the findings were reviewed, resolved, and closed out. Finding 30504-1 addressed a cor.cern about the adequacy of certification for items that need to meet the requirements of IEEE 323 and are purchased as commercial grade items frcm suppliers who do not bave a 10 CFR 50, Apper. dix B, quality program. Finding 30504-1 was resolved with the following documented response: "Because subsequent items purchased from conmercial grade suppliers cannot automatically be assured to be the same as a previously purchased item that has been qualified, additional requiremerts are imposed to dedicate the item. These reouirements include:
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' ORGANIZATION: JOHNSON CONTROLS BENSENVILLE, ILLIN0IS REPORT INSPECTION N0.: 99901072/86-01 RESULTS: PAGE 7 of 11
- 1. A certified statement from the verdor's authorized quality assurance representative that the item shipped is the'sare as the previous tested item.
- 2. 100% receiving inspection is performed upon receipt.
- 3. Bench test or verification of suppliers' test results is performed.
- 4. Devices are subsequently required to perform during panel functional test and/or system loop tests to their specified criteria.
- 5. Customer performs calibration every six months on instruments.
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- 6. Customer performs pre-operational tests prior to placing in service.
All safety related purchase orders have been reviewed to verify conformance to the above requirements which are the respersibility of JCI. (Suppliers statement, receiving inspection, bench test verification, and panel functional tests.)"
Audit Report 50701 dated August 9, 1985 resulted in one finding.
Documentation indicates the finding was reviewed, resolved, and closed out. Audit Report 60101 dated January 24, 1986 resulted in five findings. Documentation indicates that corrective action was initiated and/or is no longer required. However, final close out of the findings by the JC's quality organization had not been ccmpleted (i.e., completion of blocks 34, 35, and 36 on the Quality Notice Form) (see Nonconformance 86-01-03). This iten was brought to the attention of the QAM, SECD-East.
- 6. Procurement Document control The inspector reviewed Section 5 " Procurement Document Control" of the QAPM. In addition, 24 P0s to manufacturers / suppliers of rn arial and services for safety-related HVAC systems were reviewed to assure that applicable technical and QA program requirements were included or referenced in the P0s. A surmary includes the fellcwing:
' ORGANIZATION: JOHNSON CONTROLS BENSENVILLE, ILLIN0IS REPORT INSPECTION N0.: 99901072/86-01 RESULTS: PAGE 8 of II Vendor P0 (date) Iten United Electric Controls 23594(9-9-82) Temperature switch module Validyne Engineering 109197 (7-18-84) Differential Corporation 103115(6-6-83) pressure 23592 (9-8-82) transmitter Love Controls 112466(11-27-84) Flow 109269 (8-16-84) controller 109208 (6-7-84)
Milton Roy Company 23381(6-30-82) Differential Hays Republic Division ,
pressure transmitter Pyrotronics 103119 (6-8-83) Smoke detector Dwyer Instruments 112151(5-8-85) Static pressure tip Moore Industries 112459 (12-5-84) Air flow device Solon Manufacturing 112327 (12-17-84) Differential 109139 (7-23-84) pressure 106300 (9-26-83) switches 106128 (8-1-83)
WESCO 74004 (5-18-79) Control l
17576 (3-5-81) switches Relays Fuses ,
Action Environmental 106389 (10-25-83) Equipment Testing Corporation (AETC) 23596 (8-30-82) qualification 17532 (4-1-81) testing Engineering Analysis & 112408 (9-7-84) Equipment Test Company (EATC) 109142 (3-26-8a) qualification t
106326 (10 a-83) testing I 100502 (12-6-82) l
ORGANIZATION: JOHNSON CONTROLS BENSENVILLE, ILLIN0IS REPORT INSPECTION NO.: 99901072/86-01 RESULTS: PAGE 9 of 11 All the P0s were identified as " nuclear safety-related" and initialed by a CA representative. JC uses an attachment " Quality Assurance Requirements for Purchased Materials Services and Equipment" which contains 15 items which are separately checked when the vendor is required to comply and supply certified documentation. It was noted that a revision dated June 3, 1981 to this document initially incorporated the requirements of 10 CFR Part 21. The seven P0s to AETC and EATC for equipment qualification testing contained QA (Appendix B to 10 CFR Part 50) and engineering (IEEE 373 and 344) requirements as well as 10 CFR Part 21. Of the remaining 17 P0s, ten did not reference 10 CFR Part 21, but the items were ordered to catalogue numbers, and the documentation to JC from the vendors included certification that each item was calibrated and passed a functional test.
The FM and QAM SECD-East stated "that, except for a few instances, P0 placement and receipt inspection of safety-related items have been handled by SECD-East since the QAM position was eliminated at Bensenville in May 1986. They further stated that the noted excep-tiens were handled by either the OAM SECD-East or a Level II engineer who travelled from Philadelphia to Bensenville to accomplish these quality functions.
A review of activities for safety-related material performed at Bensenville since nuclear work was transferred to SECD-East in May 1986 included P0 P119931 dated February 2,1986 for a flow transnitter for Braidwood and P0 P122164 dated June 24, 1986 for ionization detectors for Byron. P0 P119931 was initialed by the QAM-SECD Midwest on February 7, 1986, and the receipt inspection was sigrod by the OAM SECD-East on May 8, 1986. The P0 and receipt inspection report for the ionizatico detectors were signed by the OAM, SECD-East on July 22, and August 22, 1986, respectively
- 7. Control of Purcnased Material The inspector reviewed Section 8 " Control of Purchased Material, Equipment and Services" of the CAPM. It was noted that the maintenance of the AVL is currently the responsibility of the QAM, SECD-East. Six P0s were selected to determine whether vendors were on the AVL at the tire of order placement. All six safety-related orders were placed with approved vendors.
t ORGANIZATION: JOHNSON CONTROLS BENSENVILLE, ILLINDIS REPORT INSPECTION N0.: 99901072/86-01 RESULTS: PAGE 10 of 11 Receipt inspection is the responsibility of the QAM. The inspection activity is documented on "SECD-Ouality Control Receiving Inspection Report (RIP)." The RIP contains a checklist of nine categories 3 (e.g., dimensional, cleanliness) and a documentation checklist to assure thatofother Certificates documents Ccmpliance, etc. (e.g).,
have Certified MaterialATest been received. Reports, review of RIPS for safety-related items purchased from WESCO (P0 74004),
Milton Roy (P0 23381), United Electric Controls (P0 23594), Validyne (P0 103115), Pyrotronics (P0 103119), Dwyer (P0 112151), and Moore (P0 112459) indicated that the items had satisfactorily passed receipt inspection at SECD-Midwest.
- 8. Equipment Cualification The inspector reviewed P0 13491 dated November 7. 1979 to AETC to develop an environmental and seismic testing plan for instruments and devices supplied by JC to CEC 0 for the Byron and Braidwood facilities. AETC Test Report Nc. 15281 "IEEE 323 and 324 Qualificatien of Equipment Furnished by JC for Byron /Braidwood" P.evision 3 dated September 13, 1984 was also reviewed. Revision 4 dated August 27, 1985 is currently at Sargent & Lurdy (S&L) awaiting approval for modifications made to a Wallace & Tiernan chlorine detector. It was noted that AETC qualified the following items:
AMP terminal ring legs, spade lugs, and butt splices; Bussmann fuses; General Electric terminal board and wire; Gould ITE fusible pull-out; Love temperature controller: Moore amplitude discriminator nodule; direct current alarn, and sigr.al converter; Pyrotronics CA-4 smoke detector; Solon pressure switch; United Electric temperature contrcliers; Wallace & Tienar chlorine detector; Weed RTD; Westinghouse (W) OT-2 switch, W-2 switch, AR relays; and EZC lights; and Seismic Class 1 devices. EATC also performed seismic qualifi-cation by analysis in accordance with IEEE 344 on four P0s datire from December 1982 through Septamber 1984.
The inspector reviewed a file of correspondence pertaining to the qualification cf safety-related }l components (e.g. , OT-2 switch, W-2 switch, AR releys, and EZC lights) purchased fren WESCO for the Byron /Braidwood projects. The file consisted cf approximately 16 documents dating ' rom August 1979 thru Ncvember 1985 and pertaired to correspondance between JC, CECO, and S&L. A JC Project Engineer /
CECO letter "Vestinghouse Quality Assurance Documentation Byron /
Braidwood Contract No. 7121-0001/7121-000a" dated January 8, 1980 irdicated that [ was not supplying certificates to show that the four components had been tested to guidelinee set forth in IEEE-323
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2 ORGANIZATION: JOHNSON CONTROLS BENSENVILLE, ILLINOIS REPORT INSPECTION N0.: 99901072/86-01 RESULTS: PAGE 11 of 11 and -344. Furthermore, JC proposed to test the components independ-ently, but W informed JC that they would not comply with a.JC request to certify that W components supplied on safety-related P0s f are the same as tested samples.
A JC Project Engineer /W - T. Creech letter dated February 14, 1980 requested W to comply with JC's QA requirements to certify that items on a particular safety-related P0 are similar to those previously shipped and which JC had independently tested. Letters dated May 2 and 5, 1984 from JC to CEC 0 listed the W equipment furnished by JC on safaty-related HVAC systems designated as VA, VE, and VX. A November 1,1985 letter from JC-QAM to S&L-Kosik stated that JC had " tested the W products for IEEE 323 reouirements per S&L specification F/L 2783,' but thet "Wdoes not provide traceability between the sample, tested and the product supolied."
The QA Records Transmittal Package to CECO contains a " System Turnover" document which identifies the status of a particular system when it is turned over to the customer. The inspecter was told by the PM that the following statement "IEEE 323 certification for Westinghouse devices cannot be provided" is contained in Section H " Uncompleted / Unresolved Items" of this document. A review of " System Turnover" documents for the VA, VD, VE and VX safety-related HVAC systems verified this statement is incorporated in the package to CECO.
In addition, it bas been determined by S&L and CEC 0 that the HVAC systems provided by JC at the Byron and Braidwood facilities are located in a mild environment and therefore not subject to 10 CFR 50.49. The NRC inspector was told by the PM and 0AM that S&L is in the process of amending Specificetion F-2783/L-2783 "HVAC Controls - Byron Station, Units 1 and 2/Braidwood Station, Units 1 and 2 - Commonwealth Edison Company to reflect this change.
F. PERSONNEL CONTACTED:
- G. M. Danko - Operations Manager
- J. D. Bashar - Project Manager
- M. R. Cohen - QA Manager
- Attended exit neeting.
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D Johnson Controls February 13, 1987 System Engineering & Construction Division - Midwest l Should you have any questions concerning this inspection, we will be pleased f to discuss them with you.
Siricerely, EllisW.berschoff,ActingChief Vendor Program Branch Division of Quality Assurance, Vendor and Technical Training Center Programs Office of Inspection and Enforcement ,
Enclosures:
1.. Appendix A-Notice of Nonconformance
- 2. Appendix B-Inspection Report No. 99901072/86-01
- 3. Appendix C-Inspection Data Sheets (4 pages)
DISTRIBUTION:
- s 008:IE:09 < '-
VPB Reading DQAVT Reading RStarostecki BGrimes HMiller EMerschoff JStone JConway (2)
LParker E.T. % m Egr C- f4. A ce s. %t.K
- E. U a re. e e. n pg VP 1AVT .ASC/VPB:DQAVT /VPB:DQAVT JCc ty:tt EBaker erschoff l/
87
) /Jd/87 2 / R/87
I 6,
- Johnson Controls February 13, 1987 System Engineering & Construction Division - Midwest Should you have any questions concerning this inspection, we will be pleased to discuss them with you. ,
Sincerely,
\$
Ellis W. Merschoff, Acting Chief Vendor Program Branch Division of Quality Assurance, Vendor and Technical Training Center Programs Office of Inspection and Enforcement
Enclosures:
- 1. Appendix A-Notice of Nonconformance -
- 2. Appendix B-Inspection Report No. 99901072/86-01
- 3. Appendix C-Inspection Data Sheets (4 pages)
DISTRIBUTION:
DMB:1E:09 VPB Reading DQAVT Reading RStarostecki BGrimes HMiller EMerschcff JStone JConway (2)
LParker E.T. N g 23T
- C H . M r. Rg c.c. O =,c,,, gg i
L l
t
- r. . , -
VP AVT Ks'C/VPB:DQAVT /VPB:DQAVT JCc y:tt EBaker 4erschoff ll 87 l lJ6 /87 & l Ill87 J
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