IR 05000454/1982005
| ML20055B411 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 06/16/1982 |
| From: | Danielson D, Forney W, Keshishian P, Love R, Nightingale E, Peschel J, Wescott H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20055B409 | List: |
| References | |
| 50-454-82-05, 50-454-82-5, 50-455-82-04, 50-455-82-4, NUDOCS 8207220171 | |
| Preceding documents: |
|
| Download: ML20055B411 (74) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
i Report Nos. 50-454/82-05(DETP); 50-455/82-04(DETP)
Docket Nos. 50-454; 50-455 License Nos. CPPR-130; CPPR-131 Licensee: Commonwealth Edison Company P. O. Box 767 Chicago, IL 60690
Facility Name: Byron Station, Unit 1 and 2 Inspection At: Byron Site, Byron, IL Inspection Conducted: March 29-31, April 1-2, 5-9, 12-14, and May 11, 1982.
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Inspectors:
D. H. D ielson l/
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//@. M. Peschel d[/4/PL
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R. S. Love W47176baf H. M. Wescott d
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I,dE.H. Nightingale
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(SRI Byron)
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Approved By:
D.
Danielson, Chief Materials and Processes Section Inspection Summary Inspection on March 29-31, April 1-2, 5-9, 12-14, and May 11, 1982 (Reports No. 50-454/82-05(DETP); 50-455/82-04(DETP))
8207220171 820624 PDR ADOCK 05000454 O
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Areas Inspected: QA Program interfaces and overview; corrective action systems; design change control; material traceability of installed struc-tures and components; electrical cable installation; inprocess inspections; QC inspector ef fectiveness. The inspection involved a total of 662 in-spector-hours onsite by seven NRC inspectors.
Results: Of the areas inspected nine apparent violations were identified (failure to assure contractors are operating with a QA organization as described in their QA manual and to assure that QA is sufficiently inde-pendent from cost and schedule - paragraphs b.(6).(b), b.(8).(b), and b.(10).(b); failure of site contractors to control the issuance of docu-ments - b.(10).(b); failure of site contractors to follow their procedures paragraphs b.(10).(b), and c.(2),(d).2; failure of site contractors to accomplish activities in accordance with procedures paragraphs b.(10).(b),
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i c.(2).(e).1, and f.(2).(a); failure to include certain ANSI N45.2.12 criteria in CECO audit reports of contractors - paragraph b.(10).(b);
failure of a site contractor to meet certain security standards established l
by ANSI N45.2.9 for storage of records - paragraph b.(10).(b); failure to I
meet ANSI N45.2.6 qualification, certification and training requirements for contractor QC inspectors - paragraph h.(2); failure to specify complete and adequate corrective actions on nonconformance reports - paragraph c.(2).(a).4; failure to accomplish welding in accordance with applicable codes paragraph g.(2).(d).
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DETAILS 1.
Persons Contacted Commonwealth Edison Company (CECO)
- W.
Stiede, Assistant Vice President
- L. DelGeorge, Director of Nuclear Licensing
- V. I. Schlosser, Project Manager
- W. J. Shewski, Quality Assurance Manager
- G.
Sorensen, Project Superintendent
- R. Tuotken, Assistant Project Superintendent
- M. A. Stanish, QA Superintendent, Byron R. J. Farr, QA Supervisor K. J. Hansing, QA Supervisor T. R. Sommerfield, QA Superintendent, Braidwood J. J. Mihovilovich, Structural Supervisor, PCD R. B. Klingler, QA Qupervisor, PCD G. F. Marcus, Director of QA, Engineering / Construction J. O. Binder, Electrical Supervisor, PCD M. E. Lohmann, Mechanical Supervisor, PCD C. J. Tomashek, Startup Coordinator H. J. Kaczmarek, QA Engineer A. A. Jaras, Project Operations Analysis Supervisor
- T. Tramm, Nuclear License Administrator P. Donavin, Project Engineering Department R. E. Querio, Startup Superintendent
- J. T. Westermeier, Project Engineer R. Gruber, QA Engineer J. Klink, QA Inspector P. Nodzenski, QA Engineer J. Toney, Engineering Assistant P. Macuiba, QA Engineer K. Key, Senior Buyer L. Channell, Material Coordinator R. Schwartz, QA Engineer Sargent and Lundy Engineers (S&L)
R. Rabin, Senior QA Coordinator D. Demoss, Engineer, PMD
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B. Thorsell, Senior Electrical Project Engineer V. Crisci, Project Leader J. Kelnosky, Electrical Project Leader Westinghouse (W)
D. R. Fraser, Manager, SAMU S. Stahl, QA Engineer, NTD Y. Kau, Associate Engineer, PIDG
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Hatfield Electric Company (HECo)
G. Vanderhei, Project Manager J. Buchanan, QA Hanager A. Koca, QC Supervisor R. Barzeloski, QA Supervisor D. Stoner, QC Foreman L. Broege, QC Inspector J. Mulrene, QC Inspector Powers-Azco-Pope (PAP)
R. Larkin, QA Manager M. Donahoe, Engineering Manager C. Cremer, QC Supervisor A. Limia, QC Inspector Blount Brothers Corporation (BBC)
R. H. Bay, QA/QC Manager W. Wills, QC Inspector Ebasco Services, Inc.
R. Detommaso, NDE Supervisor Johnson Controls, Inc.
B. Shah, QA Manager S. Pearson, QC Inspector Pittsburgh Testing Laboratory (PTL)
J. Troutman, Site Manager J. Chasm, Calibration Technician G. Mohammad, Site Auditor Mi_dway Industries Contractor, Inc.
M. Windsor, Site Manager Nuclear Installation Services Company (NISCo)
J. Pruitt, QA/QC Manager Nuclear Power Services (NPS)
W. Whitaker, Project QA Engineer Relleable Sheet Metal Works, Inc.
A. M. Schlegel, QA Supervisor
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a Hunter Corporation M. Somsag, QA Supervisor L. Haddick, QC Inspector D. Corasani, Piping Engineer L. Hill, Auxiliary Building Superintendent W. Evertt, Containment Building Superintendent D. Askland, Warehouseman J. Morrison, Project Engineer J. Young, Hanger Engineer A. Simon, Administrative Supervisor, QA R. Irish, Administrative Assistant, QA H. Lundquist, Material Control Supervisor U.__S.
Nuclear Regulatory Commission (Region III)
- C. E. Norelius, Director, Division of Engineering & Technical Programs W. S. Little, Chief, Engineering Inspection Branch L. McGregor, Senior Resident Inspector, Braidwood L. Cox, Secretary
- Denotes those presonnel attending the exit meeting held at the USNRC Region III office on May 7, 1982. During the inspection at the Byron Station exit meetings were held on a daily basis in order to keep the licensee informed of any findings.
The inspectors also contacted and interviewed other licensee and contractor personnel during this inspection.
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Function or Program Areas Inspected a.
General Background The purpose of this special team inspection was to determine if there are indications of existing or potential construction problems similar to some of those identified at a number of other plants under construction. The scope of the assessments included quality assurance program interfaces and overviews, corrective action systems, design change control, material traceability of installed structures and components, electrical cable installa-tion, inprocess inspections, and effectiveness of quality control inspectors.
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o Prepared By:
J. M. Peschel P. Keshishian b.
QA Program Interfaces and Overview (1) Quality Assurance Manuals Reviewed Pittsburgh Testing Laboratory Quality Assurance Manual
- QA-M-1, Revision 4, September 21, 1979 Powers-Azco-Pope Quality Assurance Manual, Revision 3,
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December 7, 1981 l
Commonwealth Edison Topical Report, Revision 20, February 17, 1982 Johnson Controls, Inc., SECD Quality Assurance Program, Revision 0, June 29, 1978 Hatfield Electric Company Quality Assurance Manual, Revision 9, August 13, 1979 Ebasco Nuclear Quality Assurance Program Manual, Revision 10, September 30, 1981 Hunter Corporation Quality Assurance Manual, Revision 5, August 1, 1981 Nuclear Power Services, Inc., Quality Assurance Manual, Fevision 1, January 13, 1981 Reliable Sheet Metal k'orks, Inc., Quality Assurance Manual, July 21, 1981 (2) Procedures Reviewed (a) Commonwealth Edison Company Byron Quality Instruction (BQI)
BQI-1, Revision 2, March 22, 1982 Generating On-Site Quality Instructions BQI-7.1, Revision 2, March 22, 1982 On-Site Contractor Non-Conformance Reports BQI-7.2, Revision 5, March 22, 1982 QA Handling of CECO Non-Conformances BQI-9, Revision 4, March 22, 1982 QA Handling of Field Change Requests BQI-10, Revision 4, February 25, 1982 Site QA Handling and Review of On-Site Contractor Procedures
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BQI-11.1, Revision 4, March 22, 1982 Byron Site QA Audits BQI-12.1, Revision 1, March 22, 1982 Installed Equipment Surveillance Instructions BQI-24, Revision 1, March 22, 1982
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Byron QA Training Program Byron Site Instruction (BSI)
BSI-5, Revision 5, October 20, 1980 Material and Equipment Receiving, Receiving Inspection Storage, and Removal from Storage Instruction
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Quality Procedure (QP)
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QP, 2-1, Procedure for the Revision of the Quality Assurance Manual - Engineering, Construction and Operation, Revision 63, February 24, 1982 QP, 2-2 Training of Personnel to meet Quality Assurance Requirements, Revision 63, February 24, 1982 QP, 3-3, Classification of System, Components, Parts
and Materials, Revision 63, February 24, 1982 QP, 4-2, Evaluation of Contractor's Quality Assurance
Program, Revision 63, February 24, 1982 QP, 5 - 1, Quality Instruction and Procedures, Revision 63, February 24, 1982 i
QP, 7 - 1, Control of Procured Material and Equipment,
Receiving and Inspection, Revision 63, February 24, 1982 QP, 12-1, Calibration Control of Commonwealth Edison Test and Measurement Equipment, Revision 63,
February 24, 1982 QP, 15-1, Reporting Quality Nonconformance during Construction and Test, Revision 63, February 24, 1982 I
QP, 15-2, Reporting Incidents and Deficiencies that
occur during Construction and Test, Revision 63, February 24, 1982 QP, 16-1, Corrective action for Reportable Deficiencies and Quality Nonconformances that occur during Construction and Tests, Revision 63,
-February 24, 1982 QP, 17-1, Quality Assurance Records, Revision 63, February 24, 1982 QP, 4-1, Request for Bid, Proposed Evaluation, and Recommendation, Revision 63 February 24, 1982 QP, 18-1, Quality Program Audits, Revision 63, February 24, 1982 QP, 18-2, Surveillance of Contractor Quality Assurance Control Activities, Revision 63, February 24, 1982
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General Procedure General Procedure No. 738, Site Buying, February 2, 1981 (b) Hatfield Electric Company Procedures Procedure #6, Revision 6, January 15, 1982 Reporting of Damaged or Nonconforming Material or Equipment Procedure #8, Revision 2, Issue 1, July 6, 1981 Audits Procedure #9E, Revision 6, Issue 1, January 23, 1981
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Class I Cable Pan Identification Procedure #11, Revision 12, February 2, 1982 Class I Cable Termination and Splicing Procedure #17, Revision 2, October 10, 1981 Qualification of Inspection and Audit Personnel Procedure #19, Revision 4, Issue 1, January 24, 1981 Equipment Turnover Reporting Procedure #20, Revision 8, November 20, 1981 Class I Exposed Conduit System Identification Procedure #23, Revision 8, Issue 1, January 22, 1981 Concrete Expansion Anchor Installation Procedure #24, Revision 1, Issue 2, January 28, 1980 Control and Calibration of Meters and l
Instruments
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Procedure #29, Revision 5, November 20, 1981 Field Initiated Request for Design Changes (c) Hunter Corporation Site Implementation Procedures 4.201 Revision 4, January 19, 1982
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Installation Verification 7.502 Revision 7, Augast 20, 1981 Control of Measuring and Testing Equipment 11.101 Revision 4, April 28, 1981 Nonconformance Processing 12.301 Revision 5. March 19, 1981 Internal and External Site Quality Assurance Audits i
20.513 Revision 9 June 8, 1981 Installation of Concrete Expansion Anchors (d) Powers-Azco-Pope Procedures QC-4 Revision 7, September 30, 1981 Nonconformance Control QC-5 Revision 5, December 17, 1981 Site Audit
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FP-3 Revision 9, December 22, 1981 Material Receiving-Inspection Controls
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FP-4 Revision 5, September 30, 1981
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Material Storage
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FP-11 Revision 7, January 21, 1982 e "
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Calibration and Control of Measuring,and Test
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Equipment (M&TE)
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(e) Pittsburgh Testing Laboratory-Procedure
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Resident Internal Quality Assurance Audit, I'lan,
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Revision 4, November 17, 1981 i
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(f) Johnson Controls Inc., Procedures
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QAS-210-BY Revision 2, January 28, 1980
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Auditor Training and Qualification,
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QAS-211-BY Revision 2, February 5, 1980
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Training and Indoctrination, Procedure
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QAS-710-BY Revision 1, September 19, 1979
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QAS-1011-BY Revision 3, January 10;- 1980.
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Weld Rod Control
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QAS-1310-BY Revision 1,'Ocotober 30, 1979,
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Calibration Cctitrol 9f, Measuring and Test Equipment
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Status Tag Usage Procedure
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.f QAS-1610-BY Revision 0, February 13,,1979
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Nonconformance Control Procedure j
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QAS-1710-BY Revision 0, September 16,. 1,9/9,,
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Corrective Action
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QAS-1910-BY-Revision 1, November 8, 1979
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Audit Procedure
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Field Change Control Procedure
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(3) Audits and Miscellar.cous Documentation Reviewed M (r.) Commonwealth Edison Comp'any re
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- 6-81-344
- 6-81-354
- 6-81-357
- 6-81-360
General Office Audit of Byron Construction Site,
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General Office Audit of Byron Construction Site,
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November 8, 1981.
General Office Quality Assurance Audit of Byron Station, April 30, 1981.
Gene ~ral Office Quality Assurance Audit of Byron
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Management Audit at LaSalle, Byron, and Braidwood Construction Sites and the LaSalle Operating Station, April, 1981, by Energy Incorporated.
Miscellaneous Documentation c.
Site Mechanical Organization Chart, March 16, 1982.
L Site Electrical Organization Chart, March 16, 1982.
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Site Structural Organization Chart, March 16, 1982.
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Site Project Construction Organization Chart, March 16, 1982.
1981 Byron Site QA Audit Schedule, Revision 0 and
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Revision 9.
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198'l-Byron Site QA Survie11ance Schedule.
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Byron Quality Assurance Organization Chart, March 22,
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Byron Quality Assurance Status Reports, January 5, 1982 and February 4, 1982.
Byron Site Quality Assurance Semi-Monthly Report for
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December 1981.
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1982 Byron Site Quality Assurance QP Training Schedule.
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(b) Hatfield Electric Company
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- 81-20
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Audit Report of Byron Site Procedure 5, 6 and 22 by
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Energy Incorporated, September 21, 1981.
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E Follow-up' Management Audit Report by Energy Incorporated,
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Trend Analysis Reports
- 2, July 24, 1981, 2nd Quarter of 1981
- 3, November 6, 1981, 3rd Quarter of 1981
- 4, 4th Quarter of 1981
- 1, March 25, 1982, 1st Quarter of 1982
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Miscellaneous Documentation Discrepancy Reports, " Trouble Letters" No.'s 640 - 670, 680 - 720.
1981 Audit Schedule 1982 Audit Schedule Quality Assurance Audit Log Memorandum from C. Van Lyssel to W. Brock concerning Quality Assurance Organization, March 17, 1982.
(c) Hunter Corporation Audit Report No. 084-4 l
l Miscellaneous Documentation
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Audit Summary Fourth Quarter Audit Report Follow-up Audit #1 Hunter Audit Summary Report for Fourth Quarter, 1981.
Hunter Corporation, Byron Site Quality Assurance Audit, June 3, 1981.
Hunter Corporation Quarterly Nonconformance Report (NR)
I Summary and Trend Analysis, December 29, 1981.
(d) Powers-Azco-Pope Audit Reports
- 52 September 29, 1981
- 53 October 1, 1981
- 54 November 12, 1981
- 55 November 12, 1981
- 56 November 16, 1981
- 57 November 15, 1981.
- 58 November 25, 1981
- 59 December 3, 1981
- 60 December 29, 1981
- 61 January 27, 1982 Management Review Audit, Byron, March 17, 1982
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Miscellaneous Documentation Weekly Storage Surveillance Report, March 10, 1982 Weekly Storage Surveillance Report, March 17, 1982 Weekly Storage Surveillance Report, March 24, 1982 Weekly Storage Surveillance Report, March 30, 1982 (e) Pittsburgh Testing Laboratory
Audit Reports
- 81-21
- 81-22
- 81-23
- 81-24
- 81-25
- 81-26
- 81-27
- 81-28
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Miscellaneous Documentation Pittsburgh Testing Laboratory Organization Chart Pittsburgh Testing Laboratory Inspectors Eye Examination Records (f) Jchnson Controls, Incorporated Audit Reports Yearly QA Program Audit No. 00501, May 16, 1980 Yearly QA Program Audit No. 10801, August 5, 1981 Audit Report, Bensenville Office, September 15, 1981 Nonconformance Reports
- 001BY November 14, 1980
- 002BY November 14, 1980
- 003BY December 4, 1980
- 004BY August 19, 1981
- 005BY February 23, 1982
- 006BY March 25, 1982
- 007BY April 2, 1982 (4) Interviews with Site Personnel Interviews were conducted with sixteen personnel from Common-wealth Edison Company, six personnel from Hunter Corporation, three personnel from Powers-Azco-Pope, three personnel from
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Hatfield Electric Company, two personnel from Pittsburgh Testing Laboratory and one person from Johnson Controls, Incorporated.
(5) Licensee's Quality Assurance Program (a) Objective The objectives of this assessment were to determine:
that the licensee's Quality Assurance Program,
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including all amendments, has been approved by NRR.
if the licensee has control of changes to the
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submitted Quality Assurance Program.
if the Quality Assurance Manual is consistent with
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the approved Qualit: Assurance Program.
(b) Discussion The inspectors reviewed:
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the licensee's Topical Report, CE-1-A, Revision 20, and determined that the original program and all subsequent revisions have been approved by NRR.
The licensee submits all changes to NRR and includes minor or typographical changes at the same time as substantive changes are submitted.
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the licensee's Quality Requirements and Quality Procedures and determined that the licensee initiated and controlled changes to the program through QP-2-1.
The procedure requires the same level of review for a QA Program change as the original program received. The program has pro-visions to input a change due to feedback of experience, regulatory requireLents, codes and standards, audits, and reviews.
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the licensee's Quality Assurance Manual and referenced documents to determine whether adequate QA plans and procedures have been established (written, reviewed, approved, and issued) to implement the docketed QA program. The reivew indicated that the 18 Criteria of 10 CFR 50, Appendix B were addressed by the Quality Procedures of the Quality Assurance Manual.
The inspectors reviewed 6 of the 25 Quality Assurance Manuals assigned to Byron Station to determine they were of the latest revisions. The following manuals were reviewed and no problems were detected.
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Assigned To 111 Project Construction Superintendent
208 Byron Station Superintendent 177 CECO OAD Supervisor 191 Byron Station Maintenance Supervisor
Byron Station Technical Staff Supervisor 115 Byron Station Quality Assurance Super-intendent
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(6) Quality Assurance Program of Contractors (a) Objectives The objectives of this assessment were to determine if the licensee has approved and routinely audits the Quality Assurance Programs of contractors for consistency with 10 CFR 50, Appendix B, and to determine the current status and effectiveness of licensee management of the on-site Quality Assurance Programs.
(b) Discussion The inspectors reviewed documentation, conducted extensive interviews with licensee and site contractor personnel, and reviewed portions of the licensee's and contractor's QA manuals to determine levels of staffing, organizational independence from cost and schedule, position descriptions, and to determine if the status and adequacy of the QA Programs were_ regularly reviewed by the licensee and contractor's management.
At the time of inspection the licensee had 13 contractors on site and each was performing safety related work under their own specific Quality Assurance Programs (QAPs).
These QAPs had been submitted to the licensee for review and approval. The licensee had reviewed and approved j
the QAPs prior to the contractors start of work. The
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licensee was fully aware of its ultimate responsibility i
for site Quality Assurance and had its own QA organiza-tion on site to monitor the activities of the various site contractors through the mechanisms of surveillances-and audits.
Table 1 is a matrix of licensee and on-site contractors performing safety-related work indicating the areas checked and compliance with these areas.
Noncompliance (454/82-05-01a; 455/82-04-01a)
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10 CFR 50, Appendix B, Criterion I, requires that "Such persons and organizations performing quality assurance functions shall report to a management. level such that
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this required authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations, are provided."
Contrary to this requirement, the inspectors found that the QA Managers of both Hatfield Electric Company and Powers-Azco-Pope (PAP) reported directly to on-site managers who had direct responsibilities for cost and schedule for their respective contracts. The Hatfield QA Manager reported to the Vice-President and the PAP QA Manager reported to the Project Manager.
Unresolved Item (454/82-05-02; 455/82-04-02)
In addition to the foregoing, it appeared that the QA Representative for Johnson Controls had production responsibilities that also conflicted with organizational independence. A review of the activities of Pittsburgh Testing Laboratories (PTL) indicates that there is no PTL on-site QA organization other than a site auditor and that for a substantial period of time each week PTL activities are not under surveillance. This condition occurs because there are two shifts for PTL inspectors and only one auditor.
The questions regarding Johnson Controls and PTL could not be resolved during the current inspection and are an unresolved item.
(7) Licensee Management Assessment of the Quality Assurance Program (a) Objective The osjective of this assessment was to determine if a periodic assessment of the licensee's Quality Assurance Program is conducted by Commonwealth Edison Company upper level management.
(b) Discussion The inspectors reviewed audits of the Byron Construction site conducted by a General Office Audit Team. These semi-annual audits are supplemented'by a biennial audit conducted by an independent auditing organization. The audits cover the entire scope of the Quality Assurance Program and are reviewed by upper level management.
The licensee's Quality Assurance organization is headed by a site QA Superintendent.
He is assisted by two Supervisor's who direct the activities of thirteen QA Engineers and Inspectors in monitoring and auditing the activities of the site contractors.
In addition four Pittsburgh Testing Laboratory personnel are assigned to the organization for specific documentation related assignments.
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Each engineer and inspector is assigned a specific list of responsibilities so that all contractor activites and other QA monitoring systems are fully covered. This type of organization should be able to effectively monitor site QA activities.
However, the execution of the program is not satisfactory, as evidenced by the many problems uncovered by the inspectors. One factor affecting the execution is the stability of service for
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the QA personnel.
A key individual in a QA Program is the on-site super-intendent. He has the direct responsibility for the QA performance of the contractors and other plant related activities.
It is he who anticipates problem areas, sees to the training of his staff, directs the activities of his staff and is instrumental in producing a quality product.
Since January 1976 there have been five QA Superintendents at the Byron Site:
J. Pizzica January 1976 to May 1976 D. Jeritz May 1976 to August 1977 R. Gousden Augu.t 1977 to May 1978 T. McIntere May 1978 to January 1981 M. Stanish January 1981 to Present In addition to this undesirable condition, the QA Engineers and Inspectors have an average on-site s rvice time of approximately fourteen months and have limited prior QA experience. Part of this on-site time was spent in training and qualifying for various QA duties.
In addition to this problem, manpower is currently being sent to other sites so that the QA effort is substantially weakened. Out of a staff of sixteen, three men have been, and currently are at other assignments:
R. J. Schwartz La Salle Station 12/7/81 to 2/19/82; 3/19/81 to Present J. S. Hale La Salle Station 1/8/81 to 2/26/8?;
3/19/82 to Present P. J. Nodgenski Quad-Cities Station 9/14/81 to 9/25/81; l
Byron Pre-op Testing 4/5/82 to Present The constant change over of personnel resulting in a minimum experience level and transfer of personnel could hinder the QA organization in meeting its obligation of effectively implementing a QA program.
In contrast to the experience level of the QA organ-ization the inspectors made a review of the stability of the supervisory and engineering personnel in the construction organization. The key individuals and service time at the Byron Station are:
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Title Name On Site Since Project Superintendent G. Sorensen 1976 Assistant Project R. Tuetken 1977 Superintendent Lead Civil Engineer J. Mihovilovich 1975 Lead Mechanical Engineer M. Lohmann
- 1981 Lead Electrical Engineer J. Binder 1978
- Six years prior experience as a Mechanical Engineer at La Salle County Station.
The pronounced difference in site time and experience level indicates there is the potential for a problem with QA personnel continually being transferred.
In an effort to determine the cause of this potential problem a meeting was held with the Corporate Manager of Quality Assurance, W. J. Shewski, on April 16, 1982.
His explanation was the the transfer of the QA Superin-tendents was for promotional opportunities in four cases and a death in the case of one superintendent.
His explanation for the large turnover and inexperience level of the QA Engineers and Inspectors was that he desired to seed the licensee departments with QA experienced personnel and also not deny them promotional opportunities.
This constant change over of QA personnel as contrasted to the stable and experienced work force of the construc-tion group indicates the need to create greater promo-tional opportunities in the QA organization, or the need to have some sort of system instituted to require QA personnel to acquire minimum service time at nuclear sites.
The inspectors reviewed the training that was given to CECO QA personnel after they had completed corporate quality assurance training. The Byron QA training is an on-the-job type training and is intended to supple-ment the corporate training and enhance the development
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of new QA personnel.
A review of BQI-24. Revision 1, Byron QA Training Program, revealed that although the stated purpose of the instruction was to provide the necessary training to appropriate personnel as quickly as possible, there was no specified length of time in which the training was to be completed. A lack of prompt training was a finding annotated by the General Office Audit of November 1981. A review of on-the-job training records revealed that prompt training was still not being accomplished and that the corrective action to prevent
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recurrance, stated in the audit response, was not being effectively implemented. The on-the-job training system had no provision to alert supervisory personnel when a new employee's training was lagging.
BQI-24 also states, "It is the new employees respons-ibility to obtain and maintain the required training."
It is our belief that the training of new employees is a management responsibility and cannot be delegated to the new employee.
- Attachment A to BQI-24 lists fourteen areas of training, and specific individuals are designated as authorized trainers in each area. There are no lesson plans or other types of written guidance for the required train-ing. The lack of a formalized training program is not conducive to the maintenance of a skilled, trained, and competent Quality Assurance Department. With some of the more experienced personnel assigned to duties at other locations the training of the QA department suffers.
Open Item (454/82-05-03; 455/82-04-03)
The inability of the licensee to dedicate resources to the Quality Assurance organization to see that their experience base is equivalent to other organizations, leads the inspectors to question the licensee's effectiveness in staffing the Quality Assurance Program Organization.
In addition, there is no evidence of a Management Policy Statement emphasising the dedication of the Company to Quality Assurance and quality in general. The licensee's position is that the Company policy is stated in the Quality Requirements of the Quality Assurance Manual.
It is our belief that these are an explanation of the Quality Assurance Manual and not a statement of policy.
(8) Licensee Quality Assurance Organization (a) Objective l
The objective of this assessment was to determine if the Quality Assurance Program provides sufficient independence from cost and schedule.
l (b) Discussion The inspectors reviewed the organization charts in the licensee's Topical Report and they indicate adequate independence for the CECO Quality Assurance Organization.
Further inspection resulted in concern regarding the activities of the Project Construction Department that
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appear to be centrary to 10 CFR 50, Appendix B, Criterion-I, regarding the independence of the Quality Assurance effortWfrom production.
The licensee's site-Project Construction Department is organized with a Manager, Technical Staff, Project Engineers and Field Engineers. The inspectors inter-viewed four supervisors and the assistant superin-tendent of the construction group and found each of them to be knowledgeable and experienced engineers fully capable of meeting their respective respons-ibilities. They all fully recognized the importance of quality assurance and control and were determined to build a quality plant.
The responsibilities of this group include:
Advisor to Engineering for design suitability for
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constructability.
Coordinate requests for field revisions.
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Receipt and storage of materials.
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Assist Project Engineering in development of
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overall schedule.
Verify conformance and completeness of contractor's
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installation to specification requirements.
Supervise and approve mechanical and structural
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construction tests.
Coordinate and provif essistance for electrical
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construction tests.
Coordinate preoperation tests.
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The Project Construction QC Supervisor and Project Construction Electrical Supervisor have engaged in Quality Assurance activities independent of the Byron Superintendent of Quality Assurance and the offsite Manager of Quality Assurance. The licensee could not produce a position description for the areas of responsibilities and the duties of the Project Construction QC Supervisor. An example of specific QA activities engaged in by these supervisors is:
Letter of November 13, 1981 from the Electrical
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and QC Supervisors to the on-site Vice President
of Hatfield Electric Company suggesting duties
and responsibilities of the QA/QC Manager and a
suggested organization chart.
The activities of the two supervisors in QA activities i
appears to be contrary to 10 CFR 50, Appendix B, Criter-ion 1, that requires independence of QA supervisors from
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cost and schedule.
In addition, it seriously undermines the effectiveness of the incumbent QA Superintendent r
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to monitor the activities of the site QA organizations.
The activities of these two supervisors resulted in a reorganization of the Hatfield Electric Company QA/QC Department that was not described in the QA Manual.
We believe that CECO QA should, at a minimum, be in-volved in a review and concurrence capacity when such suggestions are made to contractors.
In addition to the foregoing, a further problem with QA independence from cost and schedule arises in that the site Project Superintendent has final contractual approval for some contractor QA organizations concerning salary increases, promotions, and hires for QA non-manual personnel increases. The requests for such action from Hatfield Electric Company and Powers-Azco-Pope do not have a concurrence from the contractors Quality Assurance Department and come from the project construction manage-ment.
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The following list indicate salary changes or promotions of QA inspectors for site contractors that were approved by the site Project Superintendent.
Date Contractor Position 2/24/82 Powers-Azco-Pope QA Specialist 12/8/81 Hunter Corporation QA Inspector 11/23/81 Hunter Corporation QA Inspector 11/3/81 Hunter Corporation QA Inspector 11/5/81 Hunter Corporation QA Inspector The inspectors recognize that the Project Superintendents'
responsibility for contract administration requires his final approval for contractors staff size and changes in compensation, however, a question of satisfying the re-quirements of 10 CFR 50, Appendix B, Criteria I relative to QA independence arises. Mechanisms are currently now in effect for such independence in that the Pittsburgh Testing Laboratory contract is administered by the Corporate Quality Assurance Manager who is independent of cost and schedule.
Noncompliance (454/82-05-01b; 455/82-04-01b)
The lack of independence between the Quality Assurance Department and the Project Construction Department is in violation of 10 CFR 50, Appendix B, which states in part, "Such persons and organizations performing quality assurance functions shall report to a manage-ment level such that this required authority and organizational freedom, including sufficient inde-pendence from cost and schedule when opposed to safety considerations, are provided.
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Open Item (454/82-05-04; 455/82-04-04)
The involvement of the Project Construction Department in Quality Assurance Activities indicates the need for an Interface Document or Interface Procedure to explain the interaction of the licensee's Quality Assurance Organization with the Contractor's Quality Assurance Organizations, and the relation of the Project Con-struction Department to all on-site Quality Assurance Organizations.
(9) Quality Assurance Responsibility (a) Objective The objective of this assessment was to determine if the licensee has the prime responsibility for establish-ing and executing the Quality Assurance Program.
(b) Discussion The inspectors reviewed the Topical Report and the Quality Assurance Manual and interviewed the licensee's Corporate and Site Quality Assurance Managers and the Quality Assurance Manager of selected contractors.
The documentction review and the interviews showed that the responsibility of the licensee was established, documented and understood by responsible personnel in both the }1censee's and contactor's organizations.
The inspectors were concerned about the lack of a policy statement from upper management that went beyond the explanation provided in Quality Requirement 1.0 and pro-vided assurance that upper management of CECO supported the Quality Assurance Program and it objectives.
i (10) Licensee Oversight of Contractor Activities l
(a) Objective The objectives of this assessment were to determine t
l if the licensee has effective oversight of contractor l
activities and has detailed knowledge of those
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activities.
(b) Discussion The inspectors conducted interviews with Quality Assurance
personnel from the licensee, Hatfield Electric Company,
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Hunter Corporation, Powers-Azco-Pope, Johnson Controls,
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Inc., and Pittsburgh Testing Laboratory. These interviews were supplemented by the review of related quality assur-ance procedures, audits and documentations; tour of work
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areas, warehouses and field offices; and discussions with licensee and contractor personnel. -As a result of the above the inspectors determined that the licensee has a program that should provide an effective oversight of
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contractor activities. The ability of the licensee to provide this oversight is questionable due to the man-power limitation discussed in the " Licensee Assessment of the Quality Assurance Program" section of this report and the findings noted below.
Contractor QA Manuals A review of the operating organization of two contractors, Hatfield Electric Company and Johnson Controls,.Inc.,
revealed that the present organizations were not described in the latest Quality Assurance Manual revisions.
Johnson Controls, Inc., changed the title of the Senior QA Representative associated with Byron from the Quality Assurance Representative to the Quality Assurance Manager and did not update their Quality Assurance Manual.
Johnson Controls operated for approximately five months with this discrepancy, and Commonwealth Edison Company Quality Assurance was not aware of the discrepancy.
Hatfield Electric Company was operating with a Quality Control Supervisor and a Quality Assurance Supervisor, both of whom report to the Quality Assurance Manager and who are not reflected in the Quality Assurance Manual. The reason for this disparity is a letter from the licensee's Project Construction Department to the Hatfield Electric Company Vice-President suggesting an organization change.
Noncompliance (454/82-05-01c; 455/82-04-01c)
10 CFR 50, Appendix B, Criterion I states, "The authority and duties of persons and organizations l
performing activities affecting the safety-related I
functions of structures, systems, and components shall be clearly established and delineated in writing."
The failure of Hatfield Electric Company to have its I
Quality Assurance Manual reflect the actual Quality
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Assurance Organization is contrary to the above and is
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an item of noncompliance.
The failure of Johnson Controls, Inc., to have its Quality Assurance Manual reflect the actual Quality
Assurance Organization is contrary to the above and is an item of noncompliance.
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The licensee has indicated that the above conditions have been corrected. These items will be examined during future inspections.
Safekeeping of Quality Records A tour was made of the combined vault used by Johnson Controls, Westinghouse-SAMU, Midway Industrial Con-tractors, Ebasco Services, Inc., and Reliable Sheet Metal. The safes of Westinghouse SAMU and Midway Industrial Contractors were found unlocked and with no attendant at the door of the vault. The Westinghouse safe contained computer tapes which were described to be non-safety-related and the Midway safe contained quality records.
Noncompliance (454/82-05-05; 455/82-04-05)
10 CFR 50, Appendix B, Criterion XVII states, " Sufficient records shall be maintained to furnish evidence of act-ivities affecting quality." ANSI N45.2.9-1974 states,
"A full time security system shall be established to preclude the entry of unauthorized personnel into the storage area. This system shall guard against larceny and vandalism."
The failure of Midway Industrial Contractors to lock a safe containing quality records is contrary to the above and is an item of noncompliance.
The licensee has indicated that this situation and the condition of the Westinghouse-SAMU safe have been corrected. This item will be examined during a future inspection.
During tours of the combined vault, the Powers-Azco-Pope vault, the Hatfield Electric Company vault and the li-
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censee's vault, the inspectors noted that entrance holes for conduit and other such piping had not been sealed and possible air paths from the exterior existed.
Unresolved Item (454/82-05-06: 455/82-04-06)
ANSI N45.2.9-1974 states that permanent and temporary
l records storage facilities shall be constructed to protect the contents from possible destruction by fire.
The inspectors are concerned that with the possible air paths around conduits and pipes that the Halon System may not be able to extinguish a fire.
The 'icensee has indicated that action has been taken to correct this condition. This item will be examined during a future inspection.
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Surveillances The inspectors reviewed the licensee's Quality Assurance Department 1981 surveillance schedule and noted that approximately seven percent of the scheduled surveil-lances were not conducted and there was no documented reason for their omission. The licensee did conduct approximately 800 more surveilla_ces than were scheduled with an increase being made in some areas due to problems discovered or to follow up on audit findings. We recognize that such increased attention is necessary, but are concerned about the omission of surveillances without substantiating documentation, as surveillances are one of the intergal methods by which the Quality Assurance Organization provides an oversight of con-tractor activities.
Open Item (454/82-05-7; 455/82-04-7)
The inspectors are concerned about the omission of scheduled surveillances without substantiating docu-mentation.
The licensee indicated that this item will be corrected.
This item will be examined during a future inspection.
Drawing Control The inspectors reviewed selected drawings in the on-site office of Johnson Controls, Inc., and at Hunter Corpora-tion's Document Station 1-H, at the 426 level in the containment.
Twelve drawings were chosed at Johnson Controls, and of those chosen one was not the latest revision as indicated on the Sargent and Lundy master drawing list located in the CECO Quality Assurance office. Drawing M3393, Page 4 of 12, was Revision B and should have been Revision C, which was issued February 12, 1982. The M3393 drawing series is not marked to indicate how many drawings are in the series but are annotated as 1 of " blank".
Ten drawings were reviewed at Hunter Corporation's Document Station 1-H, at the 426 level in the contain-ment, and of these two drawings, CS-58 and RH-15, were not the proper revisions according to the Hunter Engineering Department master list. Hunter Corporation personnel explanined that the drawings in question were for work on the Unit 2 containment, which had been stopped, and all related drawings were supposed to have been recalled to document control. Hunter instituted an immediate recall of these drawings.
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Noncompliance (454/82-05-08; 455/82-04-08)
10 CFR 50, Appendix B, Criterion VI states, " Measures shall be established to control the issuance of docu-ments, such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting quality." The failure of Johnson Controls, Inc.,
and Hunter Corporation to control the issuance of drawings is contrary to the above and an item of noncompliance.
The licensee indicated that the condition has been corrected. This item will be examined durfug a future
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inspection.
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Process Traceability The inspectors accompanied two CECO Quality Engineers, one electrical and one welding, on inspections in the containment, auxiliary building and the turbine building to determine if they could trace the installation and inspection process on welds, conduit hanger installation, and cable pan installation. No problems were identified.
Quality Assurance Procedures Inspection identified that two on-site contractors per-forming safety related work were using forms which were not controlled by procedures.
Hatfield Electric Company is utilizing a Discrepancy Letter, also known as a Trouble Letter, for documenting incomplete construction, non-conforming contruction, requirements for Field Change Requests and other dis-crepant items found during quality control inspections.
These Trouble Letters have been in use for approximately the last 18 months and about 800 have been generated in this time frame. The Trouble Letters are used as an intermediate document during inspections prior to corrective work or preparation of FCRs and NCRs and do not become part of the quality records. Trouble Letters numbers 640 thru 670 and 680 thru 720 were examined and l
It was found that in the inspectors opinion Trouble Letters 658, 662, 664, 669, 679, 696, 697, 700 and 721 should have been documented as non-conformance reports.
As an example, in Trouble Letter 679, a Hatfield Electric Company QC Inspector reports a conduit strap backing j
plate that is not welded to a hangar. The failure to have a procedure for this Trouble Letter is contrary
i to Appendix B.
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A similar condition exists with the instrumentation piping installer, Powers-Azco-Pope.
k' hen making Quality i
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Control inspections a Fabrication Installation Surveil-lance form, for which there is no prescribed procedure is used for purposes identical to the Hatfield Trouble Letter.
The inspectors examined FIS numbers 180 through 216 and in their opinion a number of the FIS's should have resulted in NCRs. As an example, FIS 186 reported items that were installed but did not have the required heat numbers.
We are not against the use of trouble letters or speed letters to expidite some contractor functions, however, when these documents are used to document inspection discrepancies they must be procedurally controlled.
Noncompliance (454/82-05-09a; 455/82-04-09a)
10 CFR 50, Appendix B, Criterion V states, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appro-priate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."
The failure of Hatfield Electric Company to utilize a procedure to control their Discrepancy Records is contrary to the above and is an item of noncompliance.
The failure of Powers-Azco-Pope to control their Fabrication Installation Surveillances is contrary to the above and is an item of noncompliance.
The licensee has indicated that these conditions have been corrected. These items will be examined during a future inspection.
Audits The inspectors reviewed audits that were conducted by the corporate and site quality assurance organizations of Commonwealth Edison Company, Hatfield Electric Company, Hunter Corporation, Powers-Azco-Pope, Johnson Controls, Incorporated, and Pittsburgh Testing Laboratory.
The audits were conducted according to an audit schedule and the scope and content of the audits was acceptable.
The audit reports consistently failed to include a list of persons contacted during the conduct of the audit and a summary of audit results, including an evaluation statement regarding the effectiveness of the quality assurance program elements which were audited, as required by ANSI N45.2.12.
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Noncompliance (454/82-05-10; 455/82-04-10)
10 CFR 50, Appendix B, Criterion XVIII states tha; a comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to deter-mine the effectiveness of the program.
ANSI N45.2.12-1977 states that audit reports shall pro--
vide a list of persons contacted during audit activities and shall have a summary including an evaluation statement regarding the effectiveness of the quality assurance pro-gram elements which were audited.
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Contrary to the above, the audit reports of the licensee, Hatfield Electric Company, Hunter Corporation, Powers-Azco-Pope, Johnson Controls, Inc., and Pittsburgh Testing Laboratory consistently failed to include persons con-tacted during the audit and an evaluation statement re-garding effectiveness of the program elements as indicated in the examples listed below:
List of Evaluation Auditor Audit #
Persons Contacted Statement CECO 6-81-330 Yes No CECO 6-81-308 Yes No CECO 6-81-336 No No CECO 6-81-357 Yes Yes CECO 6-81-309 Yes No CECO 6-81-344 Yes No CECO 6-81-340 Yes No CECO 6-81-300 No No CECO 6-82-08 No No Hatfield 81-02 No No Hatfield 81-18 No No Hatfield 81-19 No No Hunter 84-4 No No Hunter None July 9, 1981 No No Johnson 00501 No Yes Johnson 10801 No Yes PAP
No No PAP
No No-PAP
No No
PTL 81-21 No No PTL 81-23 No No PTL 81-25 No No The licensee has indicated that action has been taken to correct this situation in future audits. This item.
will be examined during a future inspection.
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Measuring and Test Equipment The inspectors reviewed the procedure and methods for control of Measuring and Test Equipment used by Hunter Corporation, Hatfield Electric Company, Powers-Azco-Pope, Johnson Controls, Inc., and Pittsburgh Testing Laboratory and inspected various instruments in office and field locations.
The inspectors identified no problems with Hunter Corporation, Johnson Controls, Inc., and Pittsburgh Testing Laboratory (PTL).
During a review of torque wrenches in the Hatfield Electric Company Quality Assurance office and the Powers-Azco-Pope Quality Assurance office the following items were identified.
Hatfield Electric Company: The storage of torque
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wrenches was not according to Hatfield Procedure
- 24 as the wrenches that were past the calibration date were not red tagged and they were stored on the same shelf as wrenches currently in calibration.
HE-151, HE-142, and HE-135 are some of the untagged, uncalibrated torque wrenches stored with calibrated wrenches.
Powers-Azco-Pope: One torque wrench, TW-4, was
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marked as defective, but did not have a Reject Tag as required by Section 5.15 of Powers-Azco Pope Procedure FP-11, Calibration and Control of Measuring and Test Equipment (M&TE).
Noncompliance (454/82-05-11a; 455/82-04-11a)
10 CFR 50, Appendix B, Criterion V states, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomp-lished in accordance with these instructions, procedures, or drawings."
The failure of Hatfield Electric Company to follow its procedure #24, with regard to tagging torque wrenches, is contrary to the above and is an item of noncompliance.
The failure of Powers-Azco-Pope to follow its procedure No. FP-11, with regard to tagging torque wrenches, is contrary to the above and is an item of noncompliance.
The licensee has indicated that these conditions have been corrected. These items will be examined during a future inspection.
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Purchasing, Receiving and Storage The inspectors reviewed the process used to obtain safety related material starting with a material request gen-erated by a contractor and culminating with storage in
a warehouse. The inspectors noted no discrepancies in the requesting, purchasing and receiving portions of the project, but during tours of warehouse areas the following items were noted:
In Warehouse No. 1, safety-related equipment was
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stored on shelves that also contained lumber, boxes of paper, scraps of rubbish and food in a housekeeping atmosphere that did not meet the requirements of Section 6.2 of ANSI N45.2.2.
In Warehouse No. 5, a pallet of bags containing
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charcoal type compound was stored above safety related valves. One of the bags had broken and the material had spilled onto the valves, shelving-and floor, and the housekeeping was not in accord-ance with Section 6.2 of ANSI N45.2.2.
Noncompliance (454/82-05-11b; 455/82-04-11b)
10 CFR 50, Appendix B, Criterion V states, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomp-lished in accordance with.these instructions, procedures, or drawings."
The conditions maintained by the licensee in Warehouses No. I and No. 5 were contrary to Quality Procedure 13-1 and to the requirements of ANSI N45.2.2-19?2, and are
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an item of noncompliance.
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The licensee has indicated that action has been taken to correct the warehouse conditions. This item will be examined during a future inspection.
In Warehouse No. 4, Powers-Azco-Pope is storing
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material that is tagged Rejected next to Accept and Hold material and is not segregated as re-quired by Section 5.6 of Powers-Azco-Pope Pro-cedure No. FP-3, Material Receiving Inspection Control.
Powers-Azco-Pope is attaching a red tag that says
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" Safety-Related" to material that has also been tagged with PAP's Accept Tag. The red tag is not referenced in any PAP or CECO procedure.
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Noncompliance (454/82-05-11c; 454/82-04-11c)
10 CFR 50, Appendix B, Criterion V states, " Activities affecting quality shall be prescribed by documented in-structions, procedures, or drawings, of a type appro-priate to the circumstances and shall be accomplished in accc.-dance with these instructions, procedures, or drawfu4s."
The failure of Powers-Azco-Pope to store rejected material in accordance with their procedure No. FP-3 is an item of noncompliance.
The licensee has indicated that this condition has been corrected. This item will be examined during a future inspection.
(11) Quality Assurance Staffing (a) Objective The objective of this assessment was to determine if the Quality Assurance Organizations of the licensee and contractors are adequately staffed.
(b) Discussion The inspectors interviewed personnel involved in the management of the licensee's and selected contractor's Quality Assurance Organizations; and approximately 14 percent of the Quality Control inspectors employed by the contractors. Based on the interviews and a review of scheduled and completed audits and surveillance the inspectors were able to conclude that the Quality Assurance Organizations were supplied with sufficient manpower. The auditors of the selected organizations were found to be adequately qualified. Qualifications of Quality Control inspectors are discussed in detail in the "QC Inspector Effectiveness" section of this report.
The inspectors do not believe that the Quality Control Supervisor for Powers-Azco-Pope was qualified to be a Level II Supervisor on the day she was appointed to the position, as she did not have the one year of Level I experience as required by ANSI N45.2.6-1978.
This is discussed in greater detail in section h., QC Inspector Effectiveness.
The CECO Quality Assurance Organization at Byron is fully staffed with 16 personnel, but the effectiveness of Quality Assurance section is being weakened by the
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deployment of Byron Quality Assurance personnel at La Salle and Quad-Cities. This is discussed in more
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detail in pargarph b.(7), Licensee Assessment of Quality Assurance Program.
In addition to the above, one Quality Engineer was transferred to the Operations Quality Assurance section during our inspection and a replacement is not scheduled to arrive until June 1982.
The transfer of the Quality Assurance personnel to sup-i port other programs is an area of concern.
(12) Trend Analysis Program (a) Object f.ve The objective of this assessment was to determine if the licensee has an effective trend analysis program.
(b) Discussion The inspectors reviewed the trend analysis reports of the licensee and Hatfield Electric Company.
Licensee trending of NCR's is discussed in detail in section c.,
Corrective Action Systems. The licensee publishes an annual Trend Analysis Report which is s summary of NCR's by problem area for each contractot during the previous year, and the Corrective Action System is scheduled to be audited semi-annually.
(13) Compliance History (a) Objective The objectives of this assessment were to review the licensee's compliance history and the effectiveness of the associated corrective action.
(b) Discussion The inspectors reviewed the licensee's history of noncompliances, unresolved items, 10 CFR 50.55(e)
Reports, NCR's, IE Bulletins, IE Circulars, and IE Information Notices and reviewed the systems used to assign responsibility and to track the resolution of the problem. A review of all 10 CFR 50.55(e) reports and 30% of the noncompliances showed that the corrective action was appropriate, with the cause identified and
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action taken to prevent recurrence. NCR's and their resolution are discussed in detail in section c.,
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Corrective Action Systems.
Except as noted, within the areas inspected, no items of non-compliance or deviations were identified.
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Prepared By:
R. S. Love c.
Corrective Action Systems (1) Objective The objective of this assessment was to determine if:
(a) corrective action procedures are adequate.
(b) responsibilities have been adequately defined and that the affected personnel have been trained and understand the procedures.
(c) procedures are being effectively implemented. This includes the areas of tracking and closeout, trending of nonconformances, and upper management's involvement.
(2) Discussion (a) Commonwealth Edison Company (CECO)
1.
Procedure Review A review of CECO Quality Procedures QP No. 15-1, Revision 5, dated January 20, 1981, and QP No. 16-1, Revision 5, dated December 29, 1980, indicates that
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they appear to be adequate as relating to Corrective Action.
Adverse trends and problem areas are brought to the attention of the Vice President (Nuclear Operations),
Manager of Projects, Project Manager and Manager cf Quality Assurance.
Review of NCR Log The inspector reviewed CECO's Nonconformance Report (NCR) log for the years 1979, 1980, and 1981.
It was observed that for the year 1981, 101 NCRs were prepared and Hold Tags were applied in 96 instances.
In the 5 instances where Hold Tags were not applied, the item was controlled by a Subcontractors tag or the NCR was generic in nature.
3.
Review of Open NCRs
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The inspector reviewed eleven open NRCs that were prepared during 1980. The following.is a status of these NCRs.
a.
F-491, dated April 7, 1980. There is an open 50.55(e) report on this item.
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b.
F-488, dated March 27, 1980. This NCR was sent to Project Construction Department (PCD)
on May 15, 1980, for implementation of the disposition.
c.
F-526, dated June 27, 1980. This NCR is still at Station Nuclear Engineering Depart-ment (SNED) undergoing evaluation.
d.
F-539 dated July 22, 1980. This NCR is still at SNED undergoing evaluation, but, from infor-mation received by the NRC inspector, the subject cables have been terminated and energized based on a " Work can Proceed" notation on the NCR.
e.
F-544, dated August 8, 1980. This NCR is still at SNED undergoing evaluation.
f.
F-546, dated August 11, 1980. There is an open 50.55(e) report on this item.
g.
F-563, dated October 22, 1980. This NCR was sent to PCD on August 27, 1981, for implementa-tion of the disposition.
h.
F-565, dated November 5, 1980. This NCR is still at SNED undergoing evaluation.
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F-575, dated November 26, 1980. This NCR was sent to PCD on January 28, 1981, for impicmentation of the disposition.
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F-577, dated December 8, 1980. This NCR was sent to PCD on February 13, 1981, for implementation of the disposition.
k.
F-582, dated December 12, 1980. This NCR was sent to PCD on July 14, 1981, for imple-mentation of the disposition.
Open Item (454/82-05-12: 455/82-04-12)
The NRC is concerned about NCRs that remain open for an extended period of time in that as the fuel-load date approaches, there may be a tendency to accept items without proper engineering evalua-tion, including back-up data, or to accept items that should be reworked or repaired.
Pending review of the action taken to close the NCRs listed above, this is an open item.
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4.
Review of Voided NCRs The inspector selected six voided NCRs for review.
The subject procedures do not address voiding NCRs but this is an accepted practice in the industry,
,
when the-NCR is voided for just cause.
a.
NCR F-597 was missing from the QA Records Vault. The NCR log indicated that the NCR was prepared on January 27, 1981 to document that Pump Motor OCC01P terminations were leaking. The log indicates this NCR was
'
voided on April 13, 1981.
b.
NCR F-600 was missing from the QA Records Vault. The NCR log indicated that the NCR was prepared on February 6, 1981 to document some damaged cables. The log indicates this NCR was voided on April 3, 1981.
c.
NCR F-634, dated March 23, 1981, was prepared to document a minimum bend radius violation on cable IRH119 and to point out that the cause of the bend radius violation was that the weight of the cable pulled the loop out of cable tray. ECN 1992 was issued to add a device to prevent cable slippage. The NCR was voided on July 24, 1981, without an evaluation of the subject cable. The licensee had an inspection / evaluation performed on the cable on April 7, 1982. Cable was acceptable, d.
NCR F-645, dated May 7, 1981, was prepared to document that Westinghouse furnished watt-meters installed on various panels supplied by Systems Control did not meet the 1% toler-ance requirements.
The NCR was voided on June 3, 1981.
Systems Control letter to Commonwealth Edison Company, dated August 19, 1981, stated in part, "The wattmeters will be returned to Westinghouse for repair at their expense."
e.
NCR F-650, dated May 18, 1981, was prepared to document certain nonconforming hangers.
This NCR was voided on June 3, 1981, because it was being tracked on Hatfield NCR #298.
f.
NCR F-682, dated October 28, 1981, was pre-pared to document that concrete had been placed next to a pipe, resulting in a weld on the pipe becoming unaccessible for inspec-i
.
.
tion under ASME Section XI.
ECN 2336, dated December 8, 1981, was issued to enlarge the opening around the pipe so the weld would be accessible for inspection. The NCR was voided on December 16, 1981, because the ECN resolved the problem.
Noncompliance (454/82-05-13a; 455/82-04-13a)
The items listed in peragraph c d and f above 1 i
are exempics of improperly voided nonconformance.
For item c the issuance of the ECN 1992 was a
good corrective action to prevent recurrence but did not resolve the bend radius violation.
For item d the return of the instruments to Westing-
house for repair was a good resolution to the problem, net reasoning for voiding. Again, the issuance of the ECN 2336 was satisfactory resolution to the problem identified in item f not a reason
to void the NCR.
Improper voiding of the NCRs.is an item of noncompliance with Criterion XV of 10 CFR 50, Appendix B.
5.
Review of Closed NCRs On April 1, 1982, the Region III inspector reviewed the following NCRs for proper closure and for cor-rective action to prevent recurrence:
F-562, dated October 14, 1980, closed January 6, 1982 F-627, dated March 24, 1981, closed January 6, 1982 F-635, dated March 24, 1981, closed June 22, 1981 F-656, dated June 12, 1981, closed July 21, 1981 F-673, dated August 17, 1981, closed January 19, 1982 F-687, dated January 8, 1982, closed February 16, 1982 F-683, dated October 2, 1981, closed February 11, 1982 6.
Review of Trend Analysis On April 1, 1982, the Region III inspector reviewed the trend analysis of NCRs prepared by CECO. This'
trend analysis is prepared by the Projects Engineer -
ing Department (off-site). Reports dated January 8, 1981, March 19, 1981, September 17, 1981, October 21, 1981, November 12, 1981, December 17, 1981, January 12, 1982, January 20, 1982, and February 17, 1982 were reviewed during this inspection. All of the aforementioned reports had the notation, "No trends are evident" or "No trends could be identified."
CECO QA (on site) does perform a trend analysis on contractor's nonconformances. On the trend anhlysis reviewed, they agreed with the analysis being per-s formed by the individual contactors.
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7.
Interviews with Personnel Interviews with Ceco personnel indicate that they appeared to be knowledgeable in their own procedures on Corrective Action as well as their contractor's procedures.
(b) Blount Brothers Corporation (Blount)
1.
Procedure Review Blount utilizes a Deviation Report (DR) System versus an NRC system.
If a DR requires CECO Project Engineering approval, CECO transcribes the information from Blount's DR onto a CECO NCR which is then forwarded to Project Engineering for approval.
A review of Blount's procedure number 4, Inspection Nonconformances and Corrective Action, Revision 8, Issue 9, dated February 12, 1981, indicates that it appears to be adequate as relating to correction action.
2.
2w of NCRs The inspector selected several DRs from the DR log for a detailed review for proper closure and corrective action to prevent recurrence. Following is a status of these DRs:
a.
Q3-485, dated July 7, 1980. Closed October 14, 1980.
b.
Q3-508, dated November 22, 1980. Closed January 22, 1981.
c.
Q3-505, dated December 1, 1980. Closed February 23, 1981.
d.
Q3-494, dated August 25, 1980. Closed June 2, 1981.
e.
Q3-545, dated October 19, 1981. As of April 2, 1982, this DR was at CECO for final approval for closure.
On all DRs reviewed, for years 1980, 1981, and 1982, che action to resolve the nonconformance and the steps taken to prevent recurrence appeared to be adequate.
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3.
Review of Trend An41ysis / o
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Per Blount's procedure, tread smalysis are desu-
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mented annually but a runni'ngf9 unt of DRs 'is made
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in each deviation area wb16h rese.Its in a continuous f
trend analysis. The tredds'nuted by the inspector...
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had been documented on Blount's trend analysis'.
report. These reports appear -to be given side "'
distributica.and includes a copy to CECO.
4,
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4.
Interviews wit _h Persor.hel
"
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Interviews =with Blount personnel indicate that the QA Manager was relatively new on the project /
but appeared to have an adequate knowledge of
'W the procedures. The inspector was inpressed by the knowledge displayed by the QC Inspector as _
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pertaining to the DRs reviewed and the corrective
,...
action system in general.
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(c) Hunter Corporation (Hunter)
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Procedure Reviews
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1.
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A review of Hunters S'ite Impler'neitt'ation/ Procedures
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Number 11.101, Nonconfec$ance Processing,NRevision
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4, dated April 28, 1981, indicates tha~t it; appears
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to be adequate as relating to correct,1vp,ections.
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2.
Review of NCRs t
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The inspector made a genaral review of approximately
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30 NRs and a detailed review of 10 hTis for proper closure and for corrective action to prevent *rsturr-ence. Following is a status.of the NCRs that were reviewed in detail:
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a.
NR-099, dated May 5, 1980. Closed Septebber"16,
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1980.
b.
NR-132, dated July 22, 1980. This NR' was pro-perly voided on August 4, 1980.
""
c.
NR-119, drited July 15, 1980. Closed on December 15, 1980.
d.
NR-193, dated January 28, 1981. Closed on March 18, 1981.
NR-263, dated September 17, 1981. Closed on e.
October 14, 1981.
L NR-151, dated August 4, 1980. Closed on f
February 26, 1981.
E NR-159, dated July 3, 1980. This NR was pro-perly voided on December 2, 1980.
L NR-204, dated March 17, 1981. Closed on April 15, 1981.
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NR-231, dated June 5, 1981. Closed on August 21, 1981.
NR-262, dated September 11, 1981. Closed on
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November 24, 1981.
3.
Review of Trend Analysis
,
The inspector reviewed the nonconformance (NR)1og for the years 1980, 1981 and 1982.
It was observed that with the way the NR log was prepared, a trend would be observed. The inspector selected two
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attributes (unqualified welders and hold points bypassed) and performed a trend analysis for the
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years 1980 and 1981. A review of Hunters trend analysis for the same period of time indicated that the two analysis (Hunter's and the inspector's)
'
were compatable for the two attributes selected.
'i Through training, unqualified weld NRs dropped from
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11 in 1980 to 2 in 1981 and bypassing of hold points
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sf dropped from 23 in 1980 to 11 in 1981. Hunter
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recognizes that they still have problems with hold
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points.
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4.
Interviews with Personnel Interviews with Hunter personnel indicate that they appeared to have a good working knowledge of their
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system and procedures. Their system and applicable procedures appear to be adequate.
(d) Powers-Azco-Pope (PAP)
1.
Procedure Review A review of PAP Field Operating Procedure Number QC-4, Nonconformance Control, Revision 7, dated September 30, 1981 and PAP Quality Assurance j
Manual, Section B-8, Nonconforming Material and Parts, Revision 1, dated October 22, 1981, indicates that they appear to be adequate as relating to Corrective Action.
2.
Review of NCRs The inspector performed a general review of approx-imately 30 NCRs and a detailed review of 13 NCRs and 11 Corrective Actions Requests (CARS). The following is the status of the NCRs reviewed in detail:
.
.
a.
NCR 14, dated July 25, 1980. Closed August 1, 1980 b.
NCR 19, dated September 18, 1980. NCR was un-acceptable, with the note - see NCR 20.
c.
NCR 20, dated September 30, 1980. Closed October 1, 1980.
d.
NCR 23, dated September 21, 1980. Closed June 24, 1981.
f.
NCR 44, dated April 3, 1981. Closed April 24, 1981.
g.
NCR 39, dated February 27, 1981. Closed March 4, 1982.
h.
NCR 55, dated June 1, 1981. Closed August 13, 1981.
i.
NCR 71, dated February 13, 1981. Closed November 16, 1981.
J.
NCR 73, dated July 15, 1981. Closed July 24, 1981.
k.
NCR 81, dated July 31, 1981. Closed November 9, 1981.
Re-instruction was required as part of corrective action.
1.
NCR 90, dated September 10, 1981. Closed January 6, 1982.
m.
NCR 117, dated November 20, 1981. Closed December 28, 1981.
Noncompliance (454/82-05-11d; 455/82-04-11d)
Of the 13 Powers-Azco-Pope NCRs reviewed in detail, 12 of the NCRs did not contain any corrective action to prevent recurrence which is in violation of PAP's Quality Assurance Manual, Section B-8, Revision 1, dated October 7, 1981, Paragraph 13-8.8.2.
The li-censee was informed that this was an item of non-compliance with Criterion V of 10 CFR 50, Appendix B.
3.
Review of CARS and Trend Analysis Of the 11 CARS generated by PAP as a result of their trend analysis, the corrective action appeared to be adequate.
4.
Interviews with Personnel Interviews with PAP personnel indicate that they appeared knowledgeable in their system and procedures.
(e) Hatfield Electric Company (HECol j
1.
Procedure Review l
l The inspector reviewed HECo Procedure #6, Reporting i
of Damaged or Nonconforming Material or Equipment, i
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Revision 6, dated January 15, 1982, and Section XVI, Corrective Action, Revision 5, of the QA Manual.
During review the following observation was made.
Noncompliance (454/82-05-09b; 455/82-04-09b)
The only reference to corrective action to prevent recurrence in the above mentioned procedures is in Section XVI, Paragraph 2.4, of the QA Manual. This paragraph discusses corrective action for adverse audit findings. The NCR form in use at the Byron Station, as contained in procedure 6 has a section titled " Action to Prevent Recurrence" but there is no directions in the body of the procedure for this section.
Failure to assure that applicable regulatory require-ments are correctly translated into procedures and instructions is an item of noncompliance with Criter-ion V of 10 CFR 50, Appendix B.
2.
Review of NCRs The inspector reviewed approximately 180 NCRs for proper closure and for corrective action to prevent recurrence. The NCR log in use when most of the NCRs were prepared did not provide a description of the nonconformance, resulting in a larger number of NCRs reviewed. The following observations were made, a.
NCRs 98, 99, and 100 were prepared to docu-ment a violation of concrete expansion anchor (CEA) edge distance. The NCRs were voided on February 25, 1980, because an FCR was or will be issued to accept the CEAs as installed.
One FCR (2500) was not issued until July 16, 1980. By voiding the NCRs, they were removed from the trending system. After this was pointed out by the NRC, the contractor pre-pared NCR 432, dated April 9, 1982, to docu-ment the items originally contained in NCRs 98, 99, and 100, b.
NCR 168, dated March 2, 1981, documented that a cable was deformed at routing point 1899B.
CECO engineering evaluated the cable and dis-positioned the NCR as " Remove, Damaged Cable" and pull a nec cable.
Hatfield made the decision, without CECO's concurrence, that the subject cable did not need to be replaced.
The NCR was closed on August 22, 1981.
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i c.
NCR 154, dated February 24, 1981, documents that cables 1FW441, 1FW482, and 1DC198 were damaged and the disposition was to replace the cables. Review of records indicate that cable IDC197 was pulled out and scrapped on June 4, 1981 instead of cable IDC198. The NCR was closed on June 4, 1981. A review of cable pull cards for cables IDC197 and 1DC198 indicated that IDC197 had been pulled and scrapped on June 4, 1981, and that 1DC198 was initially pulled on July 24, 1981. On April 6, 1982, the HECo QA Manager corrected the subject NCR and the attached documentation.
d.
NCR 107, dated March 21, 1980.
Closed November 21, 1980.
e.
NCR 97, dated February 20, 1980. Closed August 21, 1981.
f.
NCR 152, dated February 23, 1981. Closed June 24, 1981.
g.
NCR 164, dated March 2, 1981. Closed August 15, 1981.
h.
NCR 160, dated February 16, 1981. Closed September 3, 1981.
i.
NCR 103, dated March 6, 1980. Closed January 8, 1981.
NCR 184, dated March 4, 1981. Closed June 8,
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1981.
k.
NCR 177, dated March 4, 1981. Closed March 23, 1981.
The inspector reviewed 42 NCRs generated between
September 15, 1981 and February 15, 1982. The following is a status of the disposition of the
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subject NCRs:
J 23 - Use-as-is, FCR issued I
4 - Repair the item 4 - Open as of April 7, 1982 3 - Voided 2 - Replace the item 1 - FCR issued to add side rails 1 - Reject the item 1 - Reorder replacement item 1 - Retrain the cables
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1 - Closed - Being tracked by CECO NCR
- Clean the item
Noncomplainee (454/82-05-13b; 455/82-04-13b The licensee was informed that items a and b above are additional examples where NCRs were improperly closed / voided and is an item of non-compliance with Criterion XV of 10 CFR 50, Appendix B.
3.
Review of Trend Analysis A review of Hatfields trend analysis.for 1981 and 1982 indicates that it was adequate.
4.
Interviews with Personnel Interviews with HECo personnel indicate that they appeared knowledgeable in theie procedures and system.
Except as noted, within the areas inspected, no items of noncompliance or deviations were identified.
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Prepared by:
H. M. Wescott d.
Design Change Control (1) Objectives The objectives of this assessment were to ascertain that, site design change interfaces are clearly defined and im-plemented, design change control is adequate, personnel understand and use appropriate procedures, and that the procedures are being implemented to assure the timely revising and distribution of drawings.
(2) Discussion (a) Review of QA Manuals and Procedures The inspector examined QA Manuals and Implementing Procedures as follows:
1.
Nuclear Power Services, Section No. 3, Revision 1, dated December 30, 1980, " Design Control".
2.
Powers-Azco-Pope QA Manual, Section B.1, Revision 1, dated October 7, 1981, " Design and Document Control".
3.
Hunter Corporation QA Manual, Section 2, Revision 5, dated August 1, 1981, " Drawing and Specification Control".
4.
CECO QA Manual, Quality Requirement, QR No. 30, Revisions 1, 3, 13, and 18, dated December 29, 1980, December 29, 1980, September 9, 1980, and December 29, 1980 respectively, " Design Control".
5.
CECO QA Manual, Quality Procedure, QP No. 3-2 thru Revision 13, dated November 12, 1981, " Design Change Control".
l 6.
Johnson Controls, Inc., QA Manual, Section 4, Revision 0, dated June 29, 1978, " Design Control".
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7.
Byron Site Instruction No. 20, Revision 8, dated December 17, 1981, " Instruction for Site Design Document Receipt, Distribution and Control".
8.
Byron Site Instruction No. 21, Revision 0, dated July 13, 1978, "ECN Routing".
i 9.
Westinghouse Policy / Procedure, WRD-OPR 3.0, Revision 2, dated March 20, 1981, " Design Control".
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10.
Westinghouse WRD-OFR 3.1 " Reactor Coolant System Design Definition (Power Capability Working Group)"
Revision 3, dated March 22, 1981.
11.
Westinghouse Instruction / Guidance SMD 1.4, Revision 4, dated January 18, 1982, " Byron Unit 1 Engineering Change Notice".
12.
Westinghouse Instruction / Guidance SMD 1.5, Revision 0, dated October 31,^1980, Byron Unit " Field Change Requests".
13.
AZCO Field Procedure FP-9, Revision 6, dated December 21, 1981, " Design Change Control".
(b) Review of Audits of Site Contractors The inspector reviewed CECO's audits of site contractors concerning design change control as follows:
1.
Sargent and Lundy Nos. 6-81-301, 6-81-314, 6-81-339 and 6-28-07.
2.
Westinghouse SAMU No. 6-81-317.
3.
Powers-Azco-Pope Nos. 6-81-326, 6-80-247 and 6-82-10, 4.
Nuclear Installation Service Company Nos. 6-81-311 and 6-80-281.
5.
Hatfield Electric Company Nos. 6-80-254 and 6-81-331.
6.
Hunter Corporation Nos. 6-82-09 and 6-81-350.
7.
Blount Brothers Corporation Nos. 6-80-248, 6-81-294 and 6-82-02.
8.
Johnson Control, Inc.
No. 6-80-250.
9.
Hunter Corporation, Hatfield Electric Company, Reliable Sheet Metal Works, Inc., Powers-Azco-Pope Services, Inc., Blount Brothers Corporation, Westinghouse SAMU, Pittsburgh Testing Laboratory, and Nuclear Installation Services Company No. 3/8-10/82.
(c) Review of Design Specifications The inspector reviewed design specifications as follows:
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Certified piping design specification for the
" Outdoor Essential Water System" dated February 19, 1982.
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2.
Certified piping design specification for the
" Indoor Essential Water System" dated December 14, 1981.
3.
Certified design specification for the " Reactor Vessel" dated May 15, 1972.
4.
Design Criteria for Category 1 Cable Tray, Cable
.
Tray Supports, Bus Duct Supports, HVAC Duct Supports, Conduit and Conduit Supports, DC-51-03 BY/BR.
It is noted that item 2.
above did not have the Pro-fessional Engineer's Seal for Certification. Sargent and Lundy further researched ten piping design specifi-cations and found threa that did not have the required seal. These were to be revised to include the seal by
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April 23, 1982.
(d) Review of Control of Field Change Requests (FCR's) and Engineering Change Notices (ECN's)
The inspector randomly selected fifteen (15) FCR's and three (3) ECN's at Powers-Azco-Pope, seven (7) FCR's at Hatfield Electric Company, and three (3) ECN's at Westinghouse SAMU. They were verified to be under CECO control. Additionally five (5) traveller packages for in-process welding were verified to have the correct drawing revisions in place.
The following are the totals of FCR's and ECN's issued
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as of this inspection:
Electrical FCR's 4,492 Mechanical FCR's 13,702 Structural FCR-s 101
- Mixed FCR's 4,999 ECN's 2,454 TOTAL 25,746
- Mixed FCR's contain all disciplines prior to separation by discipline.
(e) Review Site Design Change Interface i
The inspector reviewed the following:
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1.
Interface Control Agreement, Westinghouse Piping and Structural Evaluation Program for the Byron
Station Unit 1, dated October 13, 1980. Paragraph 4.3 states that, "The Byron Project Engineering
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Organization,-as the Owner, has overall responsi-
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bility for the activities described in this agreement."
2.
Flow Chart for routing CECO Field Change Request, Byron Site Instruction No. 10, Revision 5, dated March 25, 1982.
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(f) Personnel Interviewed The inspector interviewed personnel from CECO, Westing-house, Powers-Azco-Pope, Sargent & Lundy, Hatfield Electric Company, and Hunter Corporation.
Within the areas inspected no items of noncompliance or i
l deviations were identified.
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d
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e
46
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Prepared By:
E. H. Nightingale
c.
Material Traceability of Installed Structures and Components (1) Objective The objective of this assessment was to determine that material traceability was maintained from procurement through installation for structural beams, small bore piping and welding materials.
(2) Discussion The following contractors were involved and their areas of responsibility are as indicated:
Hatfield Electric Company: Cable Trays Hunter Corporation: Small Bore Pipe Systems Powers-Azco-Pope:
Small Bore Piping Systems Blount Brother Corporation: Structural
,
(a) Hatfield Electric Company 1.
Review of Procedures
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The following site procedures were reviewed:
- 5, Class I Materials and Equipment, Receiving and Inspection
- 13AA, Class I Shielded Metal Arc Field Welding (S.M.A.F.W.)
- 13AB, Class I S.M.A.F.W. (Procedure Qualifica-tion)
- 13AC, Qualification of Welders i
- 13AD, Arc Welding Electrode Control
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2.
Review of Records The documents reviewed for material traceability
were as follows:
Weld Material Request
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Material Certification
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Weld Rod Request
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Weld Data Sheet
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Weld Material Issue Tag
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3.
Review of Welder Qualification The review of welder qualification records consisted of reviewing the original qualification records as well as the supportive documents pertaining to their "up-date" qualification records. Hatfield Electric Company welding efforts are to AWS Code
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which requires six (6) month re-qualification periods.
The following welders had their certification and qualification records reviewed:
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Name Welder ID#
N. Larrabee WW C. W. Werner W
J. A. Dickson-MM Greene CG R. S. Glenny CF C. Stagg CS W. McVay BM D. Gavin DG T. Whitcomb TV F. Plegge FP These ten (10) welders are representatives of the sixty (60) welders qualified by Hatfield and are presently on site.
4.
Review of Weld Material Control
!
The review of weld material control procedures and direct observation of in process activities indicate that sufficient efforts are being im-plemented to assure material traceability and control.
,
Open Item (454/82-05-14; 455/82-04-14)
The Hatfield daily weld rod issue log did not indicate the actual time weld rod was issued and returned. The log only noted "a.m." or "p.m.".
The licensee has provided information to indicate that Hatfield form HP-13AD-1 has been revised to include provisions for the actual rod issue and i
return times. This item will be reviewed during j
a future inspection.
(b) Hunter Corporation-e 1.
Review of Procedures
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The following site implementation procedures were reviewed:
1.601, QA Procedures and Instructions 3.102, Material and Services Procurement 3.602, Material Received and Inspected 5.101, Weld Filler Material Control 5.201, Welding Procedure Qualification Control 5.301, Welding Qualification 5.501, Weld Material Issuance 6.002, Visual Exaaaaation and Verification 6.501, NDE 2.
Review of Records The inspector selected three (3) safety related small bore piping systems for review of material traceability. The review of the data packages consisted of documentation from the purchase order to installation of the item.
The systems involved were as follows:
Safety Injection (3)
.
Reactor Coolant (2)
Chemical Volume (4)
.
The documents reviewed were as follows:
.
Material / Services Request Material Receiving Report
.
.
Receipt Inspection Checklist QA Documentation Requirements List
.
Material List
.
Requisition
.
Shipping Order / Packing Slip
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Material Certificate
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NDE Request
.
Process Sheet
.
Weld Record
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Material List
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Material Certification
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Weld Material Issue Report The inspector reviewed data packages for the following small bore piping systems:
SYSTEM SPOOL PC ITEM HT #
MATERIAL REPORT 1016-S-CV-001
2" sch/160 462460 MSR 4967 1016-S-RC-001
2" sch/160 462460 MSR 4967 CECO-S-RC-001 105 3/4" sch/160 483245 MRR 9575 1016-S-SI-001
2" sch/160 462460 MSR 4967 1016-S-SI-001 16-5 2" sch/160 462460 MSR 4967
.
.
SYSTEM SPOOL PC ITEM HT #
MATERIAL REPORT 1018-S-CV-100 1-5 3/4" sch/40 462224 MSR 4967 1016-S-CV-100 8-7A 2" sch/160 462460 MSR 4967 1016-S-CV-100 9-8 2: sch/160 462717 MSR 4967-1065-S-SI-100 29-10 1" sch/160 HD7123 MSR 4967 The total footage involved consisted of 19,884'.
An expanded study of small bore piping was made to include valves and fittings. Data packages for the following items were reviewed:
NAME LOCATION SYSTEM SPOOL MRR Globe Valve IRC8039B S-RC-001-51
10084 M.O.V.
IRC8037B S-RC-001-51
10062 M.O.V.
1-SI-8871 S-SI-001
10144 NAME TYPE HT #
SPOOL MRR CPLG Fitting 2.0" 6000# S.S.-S.W.
TL
496h CPLG Fitting 3/4" 6000# S.S.-S.W.
EGJ
5338 3.
Review of Welder Qualification The review of welder qualification records consisted of reviewing the original qualification record as well as the supportive documents pertaining to their
"up-date" qualification record. Hunter Corporation welding efforts are conducted to the ASME Code which requires three (3) month re-qualification periods.
Hunter Corporation routinely re-certifies their wolders in two (2) month periods to preclude any loss of certifications due to vacations, illness, etc.
The following welders had their certification and qualification records reviewed:
NAME WELDER ID #
R. Sturm D40 l
B. Strom B17 D. Colby E52
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R. Decker A38
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D. Upstone F19 E. Baker E56
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B. Burns E82
R. Bilyeu B91
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NAME WELDER ID #
A. Arnold E48 V. Burdene C19 l
D. Radke A12 l
L. Anderson F3 These twelve (12) welders are representative of the 237 welders qualified by Hunter Corporation and are presently on site.
4.
Review of Weld Material Control The review of weld material control procedures and direct observation of in-process activities indicate that sufficient efforts are being implemented to assure material traceability and control.
The documents reviewed for material traceability are as follows:
Weld Material Stores Requisition
.
Purchase Requisition
.
Materials / Services Request
.
Material Receiving Report
.
Receipt and Inspection Checklist
.
Material Certificate
.
(c) Powers-Azco-Pope 1.
Review of Procedures The following procedures were reviewed:
QC-4, Nonconformance Control
.
FP-2, Control of Procurement and Requisitioning
.
of Material and Services FP-3, Material Receiving, Inspection Control
.
FP-5, Weld Filler Material Control
.
FP-6, Material Handling
.
FP-7, Transfer Package and Weld Record Control
.
WE-2, Welders Performance Qualification and
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Control 2.
Review of Records The inspector selected three (3) safety related small bore piping systems for material traceability review. The review of the data packages consisted of documentation from the purchase order to in-sta11ation of the item involved. The systems selected were as follows:
.
.
.
.
.
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The documents involved for review were as follows:
Weld Filler Material Requisition
.
Receiving Inspection Check List
.
Final As-Built Isometric (Supplement Weld and
.
Inspection Record)
Material Certification
.
Weld Rod Issue Tag
.
P.O. (CECO Responsibility)
.
NDE Records
.
A study of the data packages, for the systems selected, consisted of the following items:
SYSTEM PIPE SIZE HT #
REC. & INSP.
ISO #
Report #
RX Coolant 0.50" 462,444 MRR# 7074 IF1S-418B Feed Water 0.50" M81,577 RIR# 040 ILT-542 Feed Water 0.50" D85,772 RIR# 040 1LT-542 Feed Water 0.50" E89,871 RIR# 040 ILT-542 Containment 0.50" 744-783 MRR# 7074 IFT-CS011 Spray Total footage of piping involved consisted of 27,900'.
The suppliers of weld material for the Byron facility is Hunter Corporation. The pipe materials are supplied to the small bore piping contractors by CECO. Therefore, purchase orders are originated from these two (2) sources. This system of pur-chasing in large quantities by one contractor /
l licensee enhances material traceability.
An expanded study of small bore piping was made to include valves and fittings.
Data packages for the following items were reviewed:
FIELD REC & INSP.
i ITEM HT#
WELD #
REPORT #
ISO #
<
Coupling EGJ
057 IPT-RC009
,
90 Elbow OZ
131 1PT-403 Valve 1RV048 N/A 20049 11J-461 S/N N11591 Valve IRC025E N/A 230 1FT-415 S/N N11526
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3.
Revieu of Welder Qualification
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The review of welder qualification records con-sisted of reviewing the original qualification record as well as the sLpportive documents per-taining to their "up date" qualificiation record.
PAP welding efforts are conducted to the ASME Code which requires three (3) month re qualifica-tion periods.
The following welders had their certification and qualification records reviewed:
Name Welder ID#
B. Strom CS R. Sutherland AF H. Arteaga DU L. Flynn DX D. Tucker BH H. Mitchell AJ R. Boyle BM D. Shurely CE P. Meyers DE W. Meyers DG These ten (10) welders are representative of the 46 welders qualified by PAP and are presently on site.
4.
Review of Wold Material Control The review of weld material control procedures and direct observation of in process activities indicate that sufficient efforts are being impli-mented to assure material traceability and control.
,
The documents reviewed for material traceability are as follows:
Weld Filler Material Requisition
.
i Receiving Inspection Check List
.
Material Certification
.
l Weld Rod Issue Tag
.
Weld and Inspection Record
.
(d) Blount Brothers Corporation 1.
Review of Procedures The following procedures were reviewed:
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QC 3385 #1, Document Control
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QC 828 #2, Procurement Control
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QC 3012 #4, Inspection (Nonconformance
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and Corrective Action)
QC 3262 #7, Calibration of Tools, G@uges
.
and Instruments Concrete)
QC 835 #10, Receiving, Storage and Handling
.
QC 3333 #11, Welding - (AWS D1.1) 1974
.
i QC 845 #21, Structural Steel Erection
.
QC 1992 #33, Personnel Qualification and
.
Certification 2.
Review of Records The inspector selected nine (9) structural beams for material traceability. Beams selected were three from Unit #1 containment building and three beams from Unit #1 auxiliary building. Three more beams were selected from Unit #2 containment
'
building.
Beams selected were as follows:
Beam I.D.
Building Unit #
Drawing #
a A220B2 Containment
E-205 A230BB3 Containment
E-205 A240BB1 Containment
E-205 A132B5 Containment
E-102 B111BB2-Containment
E-102 B104BB1 Containment
E-102
333B3 Auxiliary
E-201 326G1 Auxiliary
E-201 603B1 Auxiliary
E-201 The inspector reviewed the data packages for the following structural steel for material traceability.
Beam # 326G1
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Film Roll 3 Dr. #326
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Index #
Heat #
S&L Letter Date 440 2R6969 12-28-76 j
435 J-31694 11-30-76 464 96266 12-28-76 474 96723 11-29-76 461 63062 11-08-76 i
Mill B8 L511159 02-28-77 Beam # 333B3 Film Roll 3 Dr. #333
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Index #
Heat #
S&L Letter Date 351 K-24080 11-10-76 474 96723 11-19-76 Beam #B104BB1 Film Roll 1 Dr. #B104
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Index #
Heat #
S&L Letter Dale 11133 69C076 06-29-77 11127 69C050 07-01-77 90126 66C242 07-01-77 90127 69C167 08-10-77-80123 63729 05-26-77 Beam #A230BB3 Film Roll 1 - Dr. #A230 - 80230
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Index #
Heat #
S&L Letter Date
70C576 02-07-78
K58219 02-06-78'
K58377 02-06-78 573 T47512 06-26-78 S-22 87495 06-27-78 Beam #B111BB2 Film Roll 1 Dr. #B111B
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Index #
Heat #
S&L Letter Date 11113 VY4703 07-01-77 11106 70C266 07-01-77 90126 66C242 07-01-77 90127 69C167 08-10-77 80123 63729 05-26-77 Film Roll 1 Beam #A220B2 Dr. #A220
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Index #
Heat #
S&L Letter Date B-9 J-51717 12-13-77 S-43 44B489 07-19-78 B-1 A-325 Bolts 09-12-78 B-2 A-325 Bolts 06-09-78 Beam #A132B5
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Film Roll 1 Dr. #A132
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Index #
Heat #
S&L Letter Date 80135 24456 05-26-77 C-80119 W35079 07-11-77 A-80190 B-34009 08-10-77
.
.
Beam #603B1 Film Roll 3 Dr. #603
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Index #
Heat #
S&L Letter Date l
1407 10005 03-04-77 287 18216 10-12-76 Beam #A240BB1 - Revised to Beam #E144-1 S&L Drawing S-1001, Revision H., Dated 3-16-78, Note 10.
Fabricated by Midcity Architectural Iron Company (on-site contractor).
Heat # K62702 and #83833 A-325 Bolts - C6810; 4048
,
3.
Review of Welder Qualifications The review of welder qualification records consisted of reviewing the original qualification reccrd as well as the supportive documents pertaining to their "up-date" qualification records. Blount Brothers Corporation welding efforts are to AWS Code which require six.(6) month re qualification periods.
The following welders had their certification and qualification records reviews:
Name Welder ID #
j K. Knaub K-5 R. Long K-4 P. Fadness P-4
R. Sullivan B-4 D. Lower L-4 W. Thompson V-4 K. Flosi W-3 R. Schusler V-18 K. Todo Y-4 D. S. Wielan D-5 The ten (10) welders are representative of the fifteen (15) welders qualified by Blount Brothers Corporation and are presently on site.
4.
Review of Weld Material Control The review of weld material control procedures and direct observation of in process activities indicate
that sufficient efforts are being implemented to
assure material traceability and control.
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The documents reviewed for material traceability are as follows:
Material Requisition
.
Receiving Inspection Report
.
Material Certification
.
Weld Material Issue Sheet
.
Weld Data Report
.
Within the areas inspected, no items of noncompliance or deviations were identified.
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Prepared By:
R. S. Love f.
Electrical Cable Installation
(1) Objective The objectives of this assessment were to determine if:
cable installation procedures are in accordance with
.
FSAR commitments and that they are adequate for con-trolling cabic installation activities.
the cable installation personnel and QC inspectors have
.
been adequately trained in this activity.
safety related cables are routed, separated, and loaded
.
in accordance with procedure requirements.
(2) Discussion (a) Review of Electrical Procedures The inspector reviewed the following Hatfield Electrical Company procedures:
1.
Procedure No. 5, Class I Material and Equipment Receiving and Inspection, Revision 4, Issue 1, dated January 26, 1981. This procedure was
l reviewed and accepted by Sargent and Lundy on l
January 27, 1981.
2.
Procedure No. 6, Reporting of Damaged and Noncon-forming Material or Equipment, Revision 6, dated January 15, 1982. This procedure was reviewed and accepted by Sargent and Lundy on February 11, 1982.
3.
Procedure No. 9-A, Class I, Cable Pan Hanger Instal-lation, Revision 11, dated November 20, 1982. This procedure was reviewed and approved by Sargent and Lundy on December 23, 1981.
i 4.
Procedure No. 9-B, Class I, Cable Pan Installation, Revision 9, dated November 20, 1981. This procedure was reviewed and approved by Sargent and Lundy on l
December 23, 1981.
5.
Procedure No. 9-E, Class I, Cable Pan Identification, Revision G, Issue 1, dated January 23, 1981. This procedure was reviewed and approved by Sargent and
,
'
Lundy on January 26, 1981.
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6.
Procedure No. 10, Class I, Cable Installation, Revision 14, dated February 8, 1982. This proce-dure was reviewed and approved by Sargent and Lundy on February 18, 1982.
Open Item (454/82-05-15; 455/82-04-15)
Procedure No. 9-B, Class I, Coble Pan Installation, Revision 9, dated November 20, 1981, did not address the installation of cable pan and riser covers. The inspector was informed that Procedure No. 9-C would address the installation of covers as required by the Byron /Braidwood FSAR. This is an open item.
Unresolved Item (454/82-05-16; 455/82-04-16)
During review of Procedure 9-E, Class I, Cable Pan Identification, Revision G, Issue 1, dated January 23, 1981, the inspector observed that paragraph S.3.1 of the subject procedures states in effect that the requirements to apply segregation identification to raceway at a minimum of every 15' does not apply to risers. This is contrary to the requirements stated in paragraph 5.1.2 of IEEE 384-1974. Pending a review of installed riser identification markings for compli-ance to requirements, this item is an unresolved item.
Noncompliance (454/82-05-09c; 455/82-04-09c)
During review of Procedure No. 10, Class I, Cable Installation, Revision 14, dated February 8, 1982, the inspector observed that the subject procedure does not address:
a.
the requirements to calculate electrical cable sidewall pressure. Maximum cable sidewall pres-sures are specified by the cable manufacturers, b.
electrical cable rework. Example - An electrical cable has been installed per Revision A of the cable pull card and Revision B of the pull card requires that the cable be " pulled back" to a given point in the raceway system and re-routed to a different landing point. What precautions are taken to prevent damage to the cable being
" pulled back" and to the cables remaining in the raceway. This would be especially important when the cable was installed in conduit or duct banks. Another example would be that as a result of an NCR, a cable had to be removed (Ref.
Hatfield NCR's 164, 154, 107).
Failure to provide adequate instructions or procedures to accomplish activities affecting quality in accord-ance with Quality Assurance Program provisions is an
1
.
.
item of noncompliance with Criterion V of 10 CFR 50, Appendix B.
(b) Review of Storage Facilities - Cable Yard The inspector toured the Hatfield Electric Company cable reel yard to verify proper storage and to select several cable reel numbers for follow-up review of material receiving reports and vendor documentation.
The cable reels were stored on dunnage (plywood),
identified, and separated as to cable type. Electrical cable reel numbers 02146-409, 04146-215, 03367-7, and 01135-43 were selected for records review.
(c) Review of Electrical k'ork Activities 1.
During a tour of the power block the inspector observed that the weld heat affected zone inside cable tray 11774J-C2E, located at the 439' eleva-tion of the cable spreading room, had not been touched-up with zinc rich paint in accordance with Hatfield Electric Company Procedure No. 9-B, Class I, Cable Pan Installation, Revision 9, dated November 20, 1981.- The licensee took immediate action to have the subject area cleaned and galva-noxed. This was the only area identified where the weld or heat affected zone had not been touched-up.
2.
The inspector observed that non-safety related pipe number FP-41-4-10" was installed 3 1/2" from safety related cable tray number 11461J-C2E.
These items are located in the Auxiliary Building between column lines 17 and P at the 426' eleva-tion. Further investigation indicates that the fire protection (FP) system is classified as moderate energy piping and is seismically supported in the area observed. This appears to meet the intent of Regulatory Guide 1.29, Seismic Design Classification.
3.
The inspector verified that electrical cable i
number IVX105 was routed in accordance with the cable pull card, Revision A.
The subject cable is a 12c/14, 600V and was pulled from cable reel 12146-201. The cable extends from 1AP32E (MCC j
132X5) to IVX02J (Vent System Local Control Panel).
l The cable was physically verified in routine points 11461J-C2E, 1R369-C2E, 1910F-C2E, IR353-C2E, 11375M-C2E, and verified that the cable entered the conduit to the equipment,
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The raceway was accepted on January 18, 1982, and cable pulled on January 19, 1982.
!
4.
During discussions with an electrical foreman and one electrical craftspersor., the inspector observed that, with respect to cable pulling, they were very knowledgeable and proud of their work. The subject craftsperson assisted the inspector in verifying the routing of electrical cable IVS105 (Ref. Para-graph (c)3 above).
(d) Review of Procurement Documentation - Class IE Cable The inspector reviewed the procurement documentation relative to 600V and SKV electrical cable. The inspector reviewed the cable specifications, Material and Equip-ment Receiving and Inspection Reports (MRR), and vendor documentation. The following observations were made:
1.
The licensee purchased the following electrical cable from Okonite Company to Sargent and Lundy specification F-2823.
a.
Cable reel number 02146-409 containted 2500 feet of 2c/14, 600V cable and was received May 11, 1981 on MRR 50217.
I b.
Cable reel number 04146-216 contained 3124 feet of 4c/14, 600V cable and was received April 22, 1980 on MRR 8569.
c.
Cable reel number 03356-7 contained 2060 feet of 3c/350 MCM, 600V cable and was received October 4, 1978 on MRR 4187.
The following data was included in the on-site i
documentation packages for the above listed cables:
Certificate of Compliance
.
Certificate of Conformance
.
Certified Test Report
.
Results of Water Absorption Test
.
Results of Ozone Resistance Test
.
Results of High Potential Voltage Test
.
Sargent and Lundy letter, dated June 20, 1980,
.
that accepted the results of Flame Tests and Tests for Design Basic Events.
2.
The licensee purchased electrical cable, reel number 01115-43 from Okonite Company to Sargent and Lundy specification F2851. This reel contained 1094 feet of Ic/1000 MCM, SKV cable and was received
1
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July 11, 1979 on MRR 7032. The following data was included in the on-site documentation package for this cable:
Certificate of Compliance
.
Certificate of Conformance
.
Certified Test Report
<
.
Results of Water Absorption Test
.
Results of Ozone Resistance Test
.
Results of High Potential Voltage Test
.
Sargent and Lundy letter, dated June 20, 1980,
.
that accepted the result of Flame Tests and
'
Tests for Design Basic Events.
(c) Review of Class 1E Cable Pull Cards The inspector reviewed 20 completed cable pull cards to verify that correct cable type was installed, raceway was inspected prior to pulling cable, and that QC accepted the cable pull. The following typical observations were made:
1.
Cable IVX105 was pulled on January 19, 1982 from Cable Reel 12146-201. Revision A to the cable pull card indicates the cable type code as 12146 which is 12/c-14, 600 volt cable. The raceway was accepted on January 18, 1982, and the cable pull was accepted January 19, 1982. This was a complete pull.
2.
Cable IRC223 was pulled on April 9, 1981 from Cable Reel 02166-41. Revision A to the cable pull card indicates the cable type code as 02166 which is one twisted pair, #16 (shielded), 600 volt cable. The raceway was accepted on
!
March 27, 1981, and the cable pull was accepted April 9, 1981. This was a complete pull.
3.
Cable IVC 019 was pulled on June 23, 1981 from Cable Reel 09146-84. Revision A to the cable pull card indicates the cable type code as 09146 which is 9/c-14, 600 volt cable.
The raceway was accepted on June 22, 1981 and the cable pull was accepted on June 23, 1981. This was a j
complete pull.
Except as noted, within the areas inspected, no items of noncompliance or deviations were identified.
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Prepared By:
H. H. Wescott
'
i j
g.
In-Process Inspection
,
j (1) Objectives (3l The objective of this assessment was'to ascertain that
,
in-process inspection procedures are adequate and properly
,
implemented.
,
(2) Discussion
.
.
j (a) Review of Procedures
The inspector reviewed procedures concerning in-process
.i" inspection as follows:
,
1.
Powers-Azco-Pope Quality Control Field Procedure j
FP-7, Revision 6, dated October 16, 1981, " Traveller j
Package and Weld Record Control PAP Isometric and j
Installation Control".
i 2.
Powers-Azco-Pope QC-6, Revision 6, dated i
September 30, 1981, " Quality Assurance Documen-tation".
,
3.
Hatfield Electric Company Procedure 9-A, Revision 11, dated November 20, 1981, " Class I, Cable Pan Hanger Installation".
!
Hatfield Electric Company Procedure 9-B, Revision 9, dated November 20, 1981, " Class I, Cable Pan Installation".
i i-5.
Hatfield Electric Company Procedure 20, Revision 8, dated November 20, 1981, " Class I, Exposed
Conduit System Installation".
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6.
Hunter Corporation, Site Implementation Procedure SIP No. 1.601, Revision 1, dated March.3, 1981,
,
j
" Quality Assurance Procedures and Instructions".
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7.
Hunter Corporation, SIP No. 4.201, Revision 4, i
dated January 19,.1982, " Installation Verification".
I (b) Observation of Work Activities
!
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j The inspector accompanied two Hatfield Electric i
Company QC inspectors and observed their inspection
{
of conduit hangers located in the control room.
i f.
The inspector also observed the inspection and torquing m,
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of four concrete expansion anchors.
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_ _, _ _ _ _ _ _. _ _,.... _ -.
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(c) Review of Records The inspector reviewed records as follows:
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1.
Hunter Corporation completed traveller packages t
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for welds Numbered 45, Part No. 1-SA-76-AD-3;
565, Part No. 1-CC-50-B-4"; Numbr.r 571, Part No.
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1-CC-50-C-6"; Number 1608, Part No. 1-CC-50-C-6"
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rework; Number 1171 and 1178, Line No. 1-D-0-33-CA-3l4".
t 2.
idunter Corporation Field Order JTP No 's 5-PS-100-i 78, 5-PS-10-77, HOG-72-1, S-NT-100-2-15-A, and
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i OG-61-7.
3.
Hatfield Electric Company QA Process Sheet File No. 13.09B.1, Class I, Cable Pan Inspection
'
Checklists (approximately 33 checklists).
4.
Hatfield Electric Company Concrete Expansion Ancnor File No. 13.25.02, Travellers 1901 thru
.<
i 1950'.
.,
5.
Hatfield Electric Company Conduit Inspection Reports; File No. 13.20.01, 766 thru 850.
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(d) Personnel Int'rviewed e
'
The inspector interviewed two QC inspectors from j
Hatfield Electric Company.
- i Noncompliance (454/82-05-17; 455/82-04-17)
'
The inspector interviewed four welders performing in-process safety related welding (two from Hunter J
Corporation and two from Powers-Azco-Pope). Three
)
of the welders did not have the welding procedure 1 specification (WPS) with the traveller packages.
,
When the inspector asked where the WPS was, two welders did not appear to know what a WPS was and i
I one-stated that he knew the WPS should be in the j
weld materia 1' issue point but stated that he had l
not seen it.
r This item is considered to be in noncompliance with the requirements of' 10 CFR 50, Appendix B, Criterion IX.
l l
Except as noted, within the areas inspected, no items of noncompliance or deviations were identified.
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Prepared By:
W. Forney h.
QC Inspector Effectiveness (1) Objective The objectives of this assessment were to determine if:
(a) any problems exist that inhibit an inspector from properly executing his assigned functions.
(b) the training, qualifications, and certification of QA/QC personnel working for contracting organizations to the licensee are in compliance with 10 CFR 50, Appendix B, ANSI N45.2.6-1978; ANST SNT-TC-1A, USNRC Regulatory Guides 1.58, USNRC Generic Letter 81-01; CECO Quality Assurance Program Manual; CECO Response to Generic Letter 81-01 (L. O. De1 George to D. G. Eisenhut-August 17, 1981); and Contractor Quality Assurance Manuals.
(2) Discussion Individuals selected for interview were chosen at random by the NRC inspector. All contractors utilizing QA/QC personnel to monitor and accept production activities at the site were selected. The organizations selected, pro-duction function monitored by the inspectors, number of inspectors in the organization, number of inspectors inter-viewed and percentages are identified in Table 2.
Each inspector interviewed was asked a standard set of questions.
The answers provided were summarized and are provided as Table 3.
Individuals selected for QA/QC inspector interview were requested to provide the record of their training, qualifi-cation and certification to the inspector. Tne inspector reviewed each of the training, qualifications and certi-fication records to verify compliance with applicable regulatory requirements, standards and commitments.
In
,
verifying the implementation of the approved requirements
'
emphasis was placed on (1) determination of initial cap-ability by suitable evaluation (2) evaluation of perform-ance/ reevaluation (3) written certification in appropriate form (4) physical requirements identified and examined yearly, and (5) qualification criteria followed and (6) records of qualification established and maintained.
Table 3 is provided as a summary of inspector answers to the standard set of interview questions. Answers to questions 1, 2, 4, 5 are self evident and do not require further definitions. However, the answers to remaining questions
require further clarification and conclusions.
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Question 3 - relates to the number of inspectors that in-dicated during their answer to Question 2 that they had prior inspection experience. Of the 30 inspectors inter-viewed 47% indicated prior inspection experience; however, only 27% had prior inspection experience in nuclear work related activities.
Question 6 - of the 19 inspectors interviewed that regularly worked frequent or excessive overtime one worked less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> weekly, fourteen worked from 8 to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> weekly, and four work greater than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> weekly. The two inspectors that provided qualified answers _ indicated the overtime was intense at times based upon fluctuations of production activities. All of the inspectors that answered yes or qualified their answer were asked if the frequent or excessive overtime caused the accuracy of their inspections to be deminished. Without exception, none of the inspectors felt the accuracy of their inspections were affected.
Question 7 and 8 - the inspectors that provided a qualified answer to these questions indicated that the lack of adequate staff and/or failure to conduct inspections promptly were a result of fluctuations in production activities.
Open Item (454/82-05-18; 455/82-04-18)
Question 9 - indicates that inspectors generally do not feel they have the authority to stop an activity in their contractor's work that is not being properly performed, nor have they been provided written management policy in this area. The inspectors that provided qualified answers-indicated that they would inform the area supervisor.
The inspectors were also asked if they felt they could immediately stop the work activity of another contractor worker who was performing work that was hazardous to safety related equipment. The majority of inspectors indicated they did not have that authority.
The licensee management committed to take actions to re-emphasize to all inspectors their responsibility to stop an activity which does not conform to applicable quality requirements. This item will be examined during a future inspection.
Question 10 - the majority of inspectors interviewed indicated that the training they received was adequate for the work activity they are required to perform. One inspector did not feel his training was adequate and the remaining inspectors felt that although their training was not the best, that if they needed additional guidance or clarification that management would provide the infor-mation immediately.
O
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i Question 11 - indicates that inspectors do not feel that a lack of inspection personnel is the cause for construction activities to come to a stop and is consistent with the answers provided in Question 8.
Question 12 - the inspectors that qualified their answer gener-ally indicated that their activity did not require a check list but was normally accomplished utilizing a combination of in-sta11ation plans and/or procedures.
Question 13 - the inspectors that qualified their answer indi-cated that they would have to follow the chain-of-command which could be untimely.
When asked to discuss their opinion of how their management portrays the relationship of quality to production the majority of inspectors stated that quality was first and production second, a number of inspectors stated that quality and produc-tion were on an equal basis, and a few of the inspectros (pre-dominately from one contractor) stated that production was first and quality second.
When asked to discuss their opinion of the overall finished product of their contractors activities the majority of in-spectors stated that the work generally exceeded minimum acceptable standards, a few stated the work generally met minimum standards, and no inspectors felt that the work did not meet minimum acceptable standards.
Noncompliance (454/82-05-19; 455/82-04-19)
Based on a review of training qualification and certification records of a minimum of ten percent of the QA/QC personnel working for contractors performing safety-related work it is apparcat that an effective program does not exist to ensure that a suitable evaluation of initial capabilities is performed, that written certification is provided in an appropriate form, and that qualification criteria is established.
Certain contractor QA/QC supervisors and inspectors were not adequately qualified and/or trained to perform safety-related inspection functions. The following examples of apparent non-compliance were identified:
a.
Contractor - Reliable Sheet Metal Works, Inc.
(1) The contractor Quality Assurance Manual did not require inspection personnel to be trained and certified to ANSI N45.2.6-1978.
(2) The certification record for the QA/QC supervisor did not contain a satisfactory basis for certification.
(3) The certification record for the QA/QC supervisor did not contain the level of capability.
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b.
Contractor - Johnson Controls, Inc.
(1) The certification records reviewed did not contain a determination of initial capability.
(2) The certificaticn records reviewed did not contain a copy of the individuals high school diploma or veri-fication of prior work history.
.
(3) The certification records reviewed did not support adequate testing prior to certification.
It is noted that testing was accomplished by oral examination consisting of 25 questions to determine the individuals knowledge of 26 procedures. The oral examination noted the individual was weak in ability to work with draw-ings. However, there is no record to indicate addi-tional training was provided or that the individual was subsequently tested and found to be proficient in his ability to work with drawings.
c.
Contractor - Powers-Azco-Pope (1) The certification records for the QC Supervisor did not provide an adequate determination of initial capability.
(2) The certification records for the QC Supervisor did not contain a high school diploma, or verification of pre-vious employment.
(3) The certification records for the QC Supervisor did not contain adequate evaluation and justification for certi-fication to Level I or subsequent certification to Level II Supervisor.
(4) The certification records for three (3) QC inspectors did not contain a high school diploma.
(5) The certification folder for three (3) QC inspectors did not contain verifications of prior employment.
(6) The certification records for the QC Supervisor and three (3) QC inspectors contain open book examinations that do not provide an adequate icvel of knowledge prior to certification. The records did not contain results of a capability demonstration to support certi-fication.
(7) The certification records for three (3) QC inspectors did not contain adequate evaluation and justification for certification to Level I and subsequent certifica-tion to Level II inspector.
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d.
Contractor - Hunter Corporation (1) The certification records for two (2) of the seven (7)
QC inspector qualifications reviewed did not provide determination of equivalent inspection experience to support the level of certification.
e.
Contractor - Hatfield Electric Company (1) The certification records for three (3) of the nine (9) inspector qualifications reviewed did not contain c Certification Evaluation Sheet.
(2) The certification record for one (1) of the nine (9)
QC inspector qualifications reviewed did not have records of examinations or work samples.
(3) The certification records for two (2) of the nine (9)
QC inspector qualifications reviewed did not provide complete evaluation and justification for certification to perform the level of inspection identified.
f.
Contractor - Blount Brothers Corporation (1) The certification record for one (1) of the two (2)
QC inspector qualifications reviewed did not indicate the expiration date of certification as a Level I lead auditor.
g.
Contractor - Midway Industrial Contractor, Inc.
(1) The certification record for the QC inspector quali-
-
fications reviewed did not indicate the activities certified to perform.
h.
Contractor - Pittsburgh Testing Laboratory
,
(1) The certification record for one of the three (3)
QC/QA inspector qualification records reviewed did not have an evaluation of prior work experience.
Based on a sample review of CECO audits conducted in the area of training Tsalification and certification for the period 1979-19Fa i+. 2 determined that a program exists to routinely review the acceptability of QA/QC personnel.
It was noted that many audit findings were identified and resulted in notable improvements of contractor adherence to ANSI N45.2.6-1978.
During the meeting conducted April 9, 1982, CECO management committed to develop an alternate plan for certification of contractor QC inspectors when the recommendations of ANSI N45.2.6.-1978, Section 3.5 are not complied with. Additionally, a commitment was made to require each contractor to verify inspectors education and experience.
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TABLE 1 Licensee and On-site Contractors QA/QC Periodic QA/QC Services
- Cract QA/QC Organ.
Review of Supv.
Organization Performed Workers Staff Indep.
QA Program Pos. Des.
Commonwealth Licensee N/A
Yes Yes Yes Edison Blount Brothers Plant 220
Yes Yes Yes Structures Ebasco Services Inservice
2 Yes Yes Yes Inspection Hatfield Electric Electrical 555
No Yes No l
Company Installation l
Hunter Corp.
Piping 944
Yes Yes Yes Systems Johnson Controls HVAC
2 (2)
Yes Yes Controls
.
Midway Indust.
Field Finish 10
Yes Yes Yes NISCO Mechanical
2 Yes Yes Yes Erector Nuclear P.S.
Mechanical
- 96
Yes Yes Yes Design Pittsburgh Testing
- 28
Yes Yes Yes Test Lab Powers-Azco-iope Instrumenta-135
No Yes Yes tion Reliable Sheet HVAC
2 Yes Yes Yes Metal Sargent & Lundy A. E. Firld *72
(1)
Yes (1)
Group Westinghouse Mechanical
- 47
(1)
Yes (1)
SAMU Design
- - Testers
- - Engineers (1) - Not reviewed (2) - Unresolved item
70
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TABLE 2
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QA/QC INSPECTCR INTERVIEW SUMMARY Total Inspectors Organization Function Inspectors Interviewed 1 EBASCO Services Inservice Inspection
1
NISCO Erect miscellaneous
1
mechanical equipment, final setting and erection of NSSS equipnent.
Reliable Sheetmetal HVAC
1
Johnson Controls HVAC Controls
1
Powers Azco Pope Instrumentation 11'
36.36
,
(PAP)
Hunter Corporation Piping System
7 9.86 Hatfield Electrical Installation
9 10.84 Blount Brothers Plant Structures
2
Pldway Field Finish Coating
1
Pittsburgh Testing Lab Onsite NDT
3 10.71
,
TCrrALS 208
14.42
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y
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TABLE 3
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SUMMARY OF QUESTIONS ASKED QC/QA INSPECTORS DURING INTERVIEWS 1.
How long employed as an inspector 3 mo.
6 mo.
6 no.-l yr.
onsite?
4
1-2 yr. 2-3 yr.
4 yr.
4
Yes pi,g 2.
Prior inspection experience?
16 Nuclear Non-Nuclear 3.
What discipline (s)?
6 Implemented Qualified Yes pict Qualified Answer 4.
Is there a sense of intimidation
1 based upon the neeo/ requirement
.
to keep up with construction?
5.
Is there a reluctance to make
1 adverse findings if they will impact on the construction or audit schedule?
6.
Is it routine for QC inspectors
9
to be working frequent and/or excessive overtime?
7.
Do the inspectors feel that their
2
particular section is adequately staffed?
8.
Do they feel the required inspections
2
are being conducted promptly?
9.
Do the QC inspectors have stop work
3
.
and/or stop process authority?
Have they ever used this authority?
9
If so do they feel they were supported
1
7 or will heve the support of manage-ment in the event of a stop work?
v
.
"
o Implemented Qualified Yes N_o Qualified Answer o
10.
Do the inspectors feel the
1
training they have been provided is adequate?
11.
Do situations arise where the
27
lack of a QC inspector causes construction activities to come to a stop?
12.
Are the QC inspectors provided
15 adequate check lists for all activities they are inspecting or are they sometimrs using vague guidelines?
13.
Do they feel that they have an
2 avenue to management if they come across a problem?
Do they feel management will get
3 involved or just pay lip service?
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