IR 05000454/1986031
| ML20214V930 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 12/05/1986 |
| From: | Love R, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20214V927 | List: |
| References | |
| 50-454-86-31, 50-455-86-17, NUDOCS 8612100011 | |
| Preceding documents: |
|
| Download: ML20214V930 (83) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-454/86031(DRS); 50-455/86017(DRS)
Docket Nos. 50-454; 50-455 Licenses No. NPF-23; CPPR-131 l
Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL.60690 Facility Name: Byron Station, Units 1 and 2
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Inspection At: Byron Site, Byron, Illinois
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Inspection Conducted: May 27 through October 22, 1986 N f4 Ray S. Tove M
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Inspector:
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Approved By: Monte P. Phillips, Chief
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Operational Programs Section Date/ '
Inspection Summary Inspection on May 27 through October 22, 1986 (Report No. 50-454/86031(DRS);
50-455/86017(DRS)
Areas Inspected:
Unannounced special inspection of licensee's action on previous inspection findings, IE Bulletins, and 10 CFR 50.55(e) reports.
Also, an NRC review was initiated following receipt of allegations and concerns from numerous sources relating to safety-related electrical work.
The inspection consisted of an examination of pertinent procedures, records, and specifications, observations, and interviews of personnel. During this inspection, Inspection Procedures 92701, 92703, 099014 and 099020 were used.
Results:
In the area of allegations reviewed, one example of a violation of 10 CFR Part 21 and 21 examples of violations of ten of the eighteen criteria of 10 CFR Part 50, Appendix B, were identified. See the Attachment for a cross reference between the violations and report details.
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8612100011 861205 i;
PDR ADOCK 05000454 G
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DETAILS 1.
Persons Contacted Commonwealth Edison Company (CECO)
- +T. J. Maiman, Vice President, Projects
- +E. L. Martin, QA Superintendent
- +K. J. Hansing, Director of QA
- W. J. Shewski, Manager of QA
- G. E. Peterson, Section Engineer
- J. O. Binder, Project Electrical Supervisor
- G. E. Groth, Assistant Construction Superintendent
- B. R. Shelton, Project Engineering Manager
- K. A. Ainger, Nuclear Licensing Administrator
- D. Farrar, Nuclear Licensing
+R. B. Klingler, Project QC Supervisor E. Briette, QA Engineer
- L. E. Bihlman, QA Engineer
- V. Schlosser, Project Manager
- G. Sorensen, Project Construction Manager
- J. L. Woldridge, QA Supervisor
- T. L. Lamb, PCD Electrical Field Engineer
- E. M. Zittle, Regulatory Assurance Staff Sargent and Lundy (S&L)
T. E. Thorsell, Senior Electrical Project Engineer
- J. D. Regan, Electrical Project Engineer
- R. J. Netzel, Senior Structural Project Engineer Hatfield Electric Company (HEco)
G. Vanderhet, Project Manager R. P. Larkin, QA/QC Manager (Present)
A. Smith, QA/QC Manager (Past)
J. T. Hill, QC Superivsor (Present)
R. Farra11, QC Supervisor (Past)
D. Griggs, QA Supervisor (Past)
D. McCarty, Assistant QC Supervisor S. Bindenagel, Electrical QC Group Leader
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K. Higgins, Assistant Office Supervisor E. Tovo, Project Engineer U.S. Nuclear Regulatory Commission, Region III (NRC)
- A. B. Davis, Deputy Regional Administrator
- C. W. Hehl, Branch Chief, DRS
- +J. J. Harrison, Branch Chief, DRS
- R. F. Warnick, Branch Chief, DRP
- B. Berson, Regional Counsel
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- D. H. Danielson, Section Chief, DRS
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- W. -L. Forney, Section Chief, DRP
- +R. S. Love, Reactor Inspector, DRS
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- J. M. Jacobson, Reactor Inspector, DRS
- J. M. Hinds, Jr., Senior Resident Inspector, Byron
- K. D. Ward, Reactor Inspector, DRS
- T. Vandel, Reactor Inspector, DRS
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- R..M. Lerch, Project Inspector, DRP
- C. H. Weil, Investigation and Compliance Specialist i
The' inspector also contacted and. interviewed other Itcensee and contractor j
. personnel during this inspection.
- Denotes those present at the meeting in Region III Office on July 2,1986.
+ Denotes those present at the meeting in Region III Office on October 1, 1986.
- Denotes those present at the exit interview on October 22, 1986.
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Licensee Action on Previous Inspection Findings (Closed) Open Item (455/83000-15; 455/85047-02): As part of the Safety Evaluation Report (SER), Paragraph 8.2.4, the licensee committed to perform
verification testing to determine the adequacy of station electric
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distribution system voltages in accordance with guidelines in Part 4 of
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Branch Technical Position (BTP) PSB-1. To perform this test, the licensee prepared and implemented Procedure AP-61. The Region III inspector reviewed
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Procedure AP-61; witnessed the test; reviewed the test data collected; and determined that the voltages were within the guidelines established in the
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BTP.
Based on the inspector's observations as noted above, this item is
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closed, f
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Licensee Action on IE Bulletin 85-02 (Closed) IE Bulletin (454/85002-BB; 455/85002-BB):
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was issued to inform all power reactor licensees and applicants of
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reliability problems with Westinghouse 08-50 type ci cuit breakers
utilized in the reactor trip system.
Byron Station uses DS-416 type circuit breakers rather than DB-50 breakers in the reactor trip system i
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(RTS). However, to prevent the same type of problems with the 05-416
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circuit breakers, Westinghouse issued Field Change Notices (FCN)
(CAEM 10749, CAEM 10807, and CAEM 10808 for Unit 1 and CBEM 10685, CBEM 10707, and CBEM 10709 for Unit 2) to replace the under voltage (UV)
trip assemblies and to modify the RTS to add an automatic shunt trip feature P
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on the Main and Bypass Circuit Breakers. The inspector reviewed the Westinghouse FCNs, the Material Receiving Reports, vendor documentation, Work Releases to incorporate the various FCNs, QC inspection reports, and the OAD test reports for the Unit I and 2 RTS main and bypass circuit breakers.
Based on the inspector's observations as noted above, this item is closed.
4.
Licensee Action on 50.55(e) Report (Closed) 50.55(e) Inspection Report (454/83009-EE; 455/83009-EE): On July 6,1983, the licensee notified Region III of a deficiency reportable pursuant to 10 CFR 50.55(e) regarding the Westinghouse 7300 process protection. system at Byron station. The first deficiency involved the adhesive bond in the heat sink assembly on loop power supply (NLP) cards was subject to failure.
Failure of the bond could cause the separation of the metal heat sink plate from the thermal links such that it falls off of the printed circuit board. Under certain conditions, this plate could cause shorting of the low-level signal if it became wedged between cards in the card frame.
For corrective action, the heat sinks on the NLP cards were replaced. The second deficiency involved contact bounce as experienced in seismic testing of the temperature channel test (NTC)
card. This would result in signal saturation of the RTD Amplifier (NRA)
card in the T U ) and T N ) circuits. This deficiency could hot h
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delay initiation of the over temperature - delta temperature (OT-AT) and overpower - delta temperature (OP-AT) trips. Westinghouse issued FCN No. CAEM-10756 to provide a temporary bypass of the input test relays pending a final resolution of the contact bounce deficiency.
For final corrective action, Westinghouse issued FCN No. CAEM-10832A for Unit 1 and FCN No. CBEM-10730 for Unit 2.
These FCNs installed modified NTC printed circuit cards (8 per unit) to resolve the mercury wetted relay contact bounce problem during a seismic event. These modified daughter boards have reed relay contacts wired in parallel with the mercury wetted relay contacts on the printed circuit boards. The inspector verified corrective action by reviewing the following: the above referenced Westinghouse FCNs; the revised drawings that ir corporated these FCNs; S&L Post Fuel Load ECN l
No. P-374 that incorporated the Westinghouse FCNs; the Work Requests that installed the modified circuit cards; the Westinghouse safety evaluation; and the test data that verified the proper operation of the modified NTC printed circuit cards.
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Followup on Allegation RIII-86-A-0090 a.
Background: On May 7,1986, the NRC Senior Resident Inspector (SRI)
at Byron Station received an allegation involving alleged harassment and intimidation of HECo Quality Control (QC) inspectors at the Byron Station. On May 9, 1986, the SRI and Chief, Projects Section t
1A (Region III) met with 16 Level II HECo QC inspectors onsite at Byron Station. On May 28, 1986, the NRC's Division of Reactor Safety (Region III) was assigned the responsibility for followup on the HECo QC inspector's concerns.
In most cases, these concerns were so general i
in nature that it would be impossible for the NRC to perform a meaningful followup inspection on the expressed concerns.
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Due to the large number of concerned QC inspectors, the NRC inspector elected to contact all QA/QC personnel employed by HECo from February 1, 1986, through the start of this inspection, May 27, 1986.
The purpose of this contact was to provide each individual an opportunity to identify and discuss their concerns, if any, with an NRC inspector one-on-one off-site. A review of organizational charts indicated that 94 persons had been/were employed during the time frame selected. The NRC inspector telephonically interviewed 75 of the 94 HECo QA/QC personnel. At the discretion of the interviewee, the NRC inspector took the individuals concern over the phone or met with the individual to receive their concerns.
For the 19 individuals the inspector was unable to contact, they were sent registered letters, inviting them to contact the NRC inspector if they had concerns with the safety-related equipment and/or applicable documentation at Byron Station. The registered letter receipts were returned from all 19 individuals, however, no additional concerns were identified.
Summary: As a result of the special NRC inspection conducted at the Byron Station, multiple examples of apparent violations of 10 CFR Part 21 and 10 CFR Part 50, Appendix B, were identified. These proposed violations demonstrate Commonwealth Edison Company's failure to exercise adequate oversight and control of their principal electric contractor, Hatfield Electric Company, to whom they had delegated the establishment and execution of a quality assurance program in the electrical area.
During the inspection _it was revealed that (1) Commonwealth Edison Company (CECO) failed to incorporate the requirements of 10 CFR Part 21 into their contract with Hatfield Electric Company; (2) Ceco failed to resolve (repair / rework / reject /use-as-is) identified hardware deficiencies in Unit 18 emergency diesel generator system.
Some of these deficiencies had been identified as early as 1983; (3) CECO and HEC 0 had dispositioned NCRs, DRs, and inspection reports "use-as-is" without the design organization's approval or without a clear basis for the inspection elements acceptability; (4) CECO did not have a procedure for CECO construction to notify CECO operations of deficiencies that could affect the safe operation of Unit 1 or a procedure to ensure that items are reassembled after fireproofing activities had been completed; (5) CECO was deleting inspection attributes by memorandum and HECo was deleting inspection attributes by verbal directions; (6) by verbal directions from a CECO field engineer, the modification of 11 items of Unit I safety-related equipment were not QC inspected; (7) HECo failed to accurately status Unit 1 inspection reports which resulted in 57 required inspections not being performed; (8) two HECo QA Lead ' Auditors and 16 HECo QC inspectors were improperly certified; (9) HECo failed to include all NCRs and DRs in their trend analysis (i.e., 98 of 104 NCRs and 199 of 236 DRs prepared during the trending period were not included in the trending analysis),
and (10) HECo had closed NCRs (approximately 38 identified) before the corrective action to prevent recurrence had been implemented.
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(1) Concern: Temporary hangers were installed by using an unsigned Field Change Request (FCR). These hangers are welded to Category 1 steel and are located inside the secondary shield wall next to each steam generator (S/G) in Unit 2.
They have weld travelers but the welds have never been inspected.
NRC Review: The NRC inspector performed a physical inspection of the area identified by the alleger. The inspector identified 12 temporary hangers (three per S/G) that were welded to Category 1 (safety-related) box beams. During personnel interviews, the inspector was informed that these hangers were installed per the verbal direction of CECO Project Construction Department (PCD) to protect the electrical wiring associated with the " Loose Parts Monitor" for each S/G. Through the review of the applicable weld travelers, the inspector determined that these hangers were installed during the February 24-28, 1986, time frame. The inspector was also informed that these temporary hangers are scheduled for removal prior Unit 2 fuel load. The HECo Level III welding inspector was maintaining the applicable weld travelers in his " work pending" file.
In accordance with HECo procedures and site instructions on temporary attachments, an inspection of the attachment weld is not required. However, when these temporary attachments are removed, an inspection of the base metal will be required per CECO direction.
In this instance, the box beams are scheduled for a visual and magnetic particle (MT) inspection when the 12 temporary hangers are removed.
Conclusions:
It was substantiated that 12 temporary hangers were installed in the area of Unit 2 S/Gs and that these hangers were attached to Category 1 steel (box beams). Additionally, it was established that these hanger attachment welds were not QC inspected.
However, there is no requirement for the inspection of temporary attachment welds. The base metal is scheduled for visual and MT inspections when the temporary hangers are removed.
No violations or deviations were identified.
(2) Concern: HECo QA/QC management instructs QC inspectors to stay out of Unit 1 areas. If an inspector identifies a deficiency in Unit I area, he " catches hell".
Examples of defective wd ds in Unit 1 are hangers WCP1-1 and WCP1-5.
NRC Review:
During personnel interviews, (CECO PCD, Ceco QA and HECo QA/QC), the NRC inspector was informed that when Unit 1 was declared operational, CECO informed all contractors to keep their personnel out of Unit I areas unless they had a specific job to perform in those areas.
In addition, as part of CECO's Nuclear General Employee Training (NGET) personnel are informed that the security program required controlled access for certain areas. Due to their job requirements, most HECo QC inspectors have a photo badge and a key card that allows them access to
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'both Unit 1 and Unit 2' areas.
If an' inspector was inspecting Unit 2 work operations, he/she would have free access to Unit 1 equipment. Therefore, the only way to control access to Unit 1 items is through verbal or written direction.
If an inspector was'in the Unit 1 area without a specific job assignment, that meant they were not performing their required job functions in Unit 2.
However, if the inspector observed a deficiency while passing through the Unit 1 area, the inspector is expected to notify CECO of the deficiency by the use of a meno. With:
respect to hangers WCP1-1 and WCP1-5, the inspector was unable to' locate those hangers with defective welds. Without a speci-fic drawing number, it is impossible to identify the hangers that the alleger was alluding to in that most all drawings reviewed had these hanger numbers assigned, i.e., each building, and each elevation of the building, and if different drawings, each area of a given elevation could have hangers WCP1-1 and WCP1-5. When queried, the alleger could not remember the building, elevation, area, or drawing. As stated above, the inspector could not identify any WCP1-1 or WCP1-5 hangers with defective welds.
Conclusions:. It was substantiated that HECo QC inspectors were directed to stay out of Unit I areas. However, this direction
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was given so as to limit the personnel in the vital areas of an operating plant (Unit 1) and was at the direction of the licensee.
If an inspector identified deficiencies in Unit I while his job assignment was for Unit 2 work activities, he/she may " catch hell" for being in Unit 1, but not for reporting a discrepancy. With respect to hangers WCP1-1 and WCP1-5, the inspector could not identify any WCP1-1 or WCP1-5 hangers with defective welds. No violations or deviations were identified.
(3) Concern: Weld traveler cards are missing on approximately 20%
of the Unit 2 J-Box' attachment welds.
NRC Review: During interviews of HEco QC and engineering personnel and the review of Discrepancy Reports (DR) and Nonconformance Reports (NCR) it was apparent that HECo had an extensive problem with missing weld travelers (lost or never prepared). DR 8512 identified 37 Category 1 J-Boxes that were missing weld traveler (WT) cards. After research, it was found that 11 J-Boxes did not require WT cards in that the J-Boxes were installed with concrete expansion anchors (CEA) or by bolts to tube steel.
For the remaining 26 J-Boxes, new WT cards were generated and the welds inspected and repaired as necessary.
If some of the data required on the WT was not recreatable from other records, the DR number was entered in that space.
For example if the actual date of installation could not be determined from the foreman's construction reports, DR 8512 would be entered as the installation date.
In addition, Ceco QA Surveillance Reports 6941, dated February 11, 1985; 3780, dated July 25, 1985; and 7948, dated March 5, 1986, also addressed the fact that HEco was missing WT cards.
Concern (4) below also
addresses alleged missing WT cards.
The NRC inspector verified l
that DR8512 and CECO QA Surveillance Reports 6941, 7380, and 7948 were properly closed.
In addition, the inspector randomly selected
- 24 Category I and II J-Boxes from the 6E-2-3600 series drawing for review of WT cards. One or more WT cards were reviewed for each J-Box selected and were found acceptable.
Conclusions: HECo had problems with missing WT cards for Unit 2 J-Boxes, however, the missing WTs had been documented and resolved by HECo on DR8512 and on Ceco QA Surveillance Reports No. 6941, 7380, and 7948.
In addition, the NRC inspector selected 24 J-Boxes at random and did not identify any missing WT cards. No violations or deviations were identified.
(4) Concern: There are no WT cards for Category II welds.
Example provided was cabinet / panel attachment welds.
NRC Review: The NRC inspector reviewed approximately 125 non-safety related (Category II) Equipment Installation Reports where attachment welds were required.
In all cases, WT cards had been prepared for these attachment welds. Also, see Concern (1) above for additional examples of WT cards being prepared for the installation of non-safety related items.
Conclusions:
In that weld travelers were prepared for the approximately 125 non-safety-relatea items reviewed, this concern could not be substantiated.
No violations or deviations were identified.
(5) Concern:
If a hot item (item required to support testing and/or turnover) was rejected by one inspector, another inspector was directed to reinspect the item and accept it.
For example, approximately four months ago (February 1986) an inspector rejected some welds on Category I cabinet attachments in Area 7 and HECo QC inspector (by name) accepted the welds.
NRC Review: All WT cards are entered into the HEco computer system by WT number, drawing number, area number, hanger / equipment number, welder, and QC inspector that accepted the weld (s) associated with that WT. The NRC inspector requested and was provided a printout of all WT cards inspected by the named individual in Area 7 between November 1985 and June 1986.
A review of the WT cards indicated that the named individual had not inspected any weld in Area 7 (between November 1985 and June 1986) that had been previously inspected by another inspector.
It should be noted that the QC inspector documents his/her inspections on the original WT card.
This included rejections and reinspections. As part of CECO's ongoing overinspection program, Pittsburgh Testing Laboratory (PTL)
selects, at random, 10% of each inspectors work for reinspection.
PTL's 10% sample of the named individual's work resulted in a 50% reinspection of his work in Area 7 between November 1985 and June 1986, with no rejections.
Conclusions:
Based on the NRC-inspector's review of the named individuals work in the area specified this concern could not be substantiated.
This concern was also refuted based on PTL's overinspection of his work. No violations or deviations were identified.
(6) Concern: The HECo QA supervisor restricted access to vaulted records. The following examples were provided: (a) QC inspectors were not allowed to look at old (vaulted) WT cards and could only use the WANG to verify acceptability; (b) if a QA inspector wanted to look at any vaulted records, the inspector must have the QA supervisors written approval, i.e., the supervisor initials the records sign-out card;-(c) the QA supervisor would look at the records requested and inform the inspector that "You don't need to see the record, it was inspected and accepted -
Trust me."
NRC Review: To establish the need for QC inspectors to review vaulted records, the NRC inspector reviewed several of HECo procedures. The following are typical examples where the inspector needs to verify vaulted records (completed QC records stored in a records vault):
(a) Procedure 20
" Class I Exposed Conduit System Installation." When the QC inspector is performing a conduit inspection per Form HP-201, Item 3 on the checklist requires verification that the supports (hangers) were installed per drawing. This task is performed by verifying support inspection checklist, Form HP-203, was complete and acceptable.
Form HP-203 is completed by a welding inspector.
(b) Procedure 20 - When the QC inspector is completing a J-Box installation report, Form HP-206, the inspector has to verify that a complete and acceptable WT or CEA traveler is on file.
(c) Procedure 19
" Equipment Turnover Reporting" and Procedure 19A
" Electrical Panel Turnover Reporting."
These procedures require QC to verify that numerous inspection reports are complete, acceptable, and on file.
If there are any exceptions, these exceptions must be noted on the turnover report.
Based on the NRC inspector's review of HECo procedures, it was determined that the QC inspector must have free access to the vaulted records to perform his/her job related functions.
During personnel interviews, the inspector was informed by the vault clerk that the QA Supervisor must initial the " Records Checkout Card" before she could provide the QC inspector with the requested records. The inspector also observed various QC inspectors obtaining the QA Supervisors initials on checkout cards. Also during interviews of computer operators and QC
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personnel, the NRC inspector was informed that the general guidance provided was to utilize the computer to determine item acceptance. This was enforced more if the records were in Vault No. 2.
Vault No. 2 is under the control of CECO and contains HECo Unit I records, some Unit 2 records, and
' certification records for former HECo QA/QC personnel. With respect to the third example provided (Concern c. above), this appeared to be a statement taken out of context.
In order to resolve this problem, meetings were held with Ceco and HEco personnel and HECo was directed to "open the vault" to all QA/QC personnel; i.e., allow personnel to checkout documents without the QA supervisors approval. The subject QA supervisor was terminated July 2, 1986.
Conclusions: Based on the inspector's observations and personnel interviews, examples (a) and (b) of this concern were substantiated and it was also determined that the QC inspector needed free access to the vaulted records in order to perform his/her job related functions as described in the HECo procedures.
The licensee was informed that failure to assure that QC inspectors had the authority and organizational freedom to verify inspections of safety-related _ functions is an example of failure to implement 10 CFR 50, Appendix B, Criterion I (454/86031-01; 455/86017-01).
(7) Concern: Temporary Ticket Holders are afraid to reject anything for fear of being fired.
HEco QC inspector (by name) is a good
example. Temporary Ticket Holder was defined as a craft i
journeyman that was working as a QC inspector (Red Hat) and -
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took a pay cut under the new union agreement to work as a QC
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inspector (White Hat).
CECO Project Electrical Supervisor (by name) directed HECo to get rid of Red Hat QC inspectors.
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Hat QC inspectors that went "back to the tools" (working as craft journeymen) were better' qualified than many present QC inspectors.
NRC Review: To fill a void in the HECo QC Department, journeymen electricians and welders were transferred on.a
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temporary basis to the QC department. These personnel were trained, tested, and certified as QC inspectors. At a point in time, the HEco QC department was made up with non-union QC inspectors and union journeymen QC inspectors (Red Hats). Due to the large difference in pay, the non-union inspectors organized and a union contract was negotiated for HECo QC inspectors. At that time, " Red Hats" were afforded the t
opportunity to change over to " White Hat" QC inspectors at a reduced pay.
In accordance with the QC union contract,-the Red Hats were the "first to go" on a reduction in force (RIF). At the present time, there are no Red Hats in the HEco QA/QC department.
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With respect to qualification of QC inspectors, the NRC
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established the minitrum requirement that would be acceptable ~
for certification with the issuance of Regulatory Guide 1.58 h; '
previously employed HEco QC inspector's qualification records.
and Generic Letter 81-01. A sample review of present and
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indicated that all 0C inspectors met.the minimum requirements'
s for certification.
In fact, some'of these Red Hat and White Hat inspectors exceeded the minimum requiremeKts for certificattorJ
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The inspector reviewed the last eight.nonths 'of welding
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-inspections (area certified) performed by the named QC
.s inspector and the inspections of eigat additional 16spectors.
The reject rate on initial inspections wis higher for the named inspector than for the.other eight inspectors.
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Conclusions: Basedon'theNRCinspector'srevkewofinspection reports, certification records, and union contra:ts, the s
allegers conc ^rns could not be substantiated. All QC e
inspectortwere qualified and properly certified.- There wts no evidence thaii the " Red Hats" were treated it, a discriminatory
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manner. Na VI'olations or deviations were identified.
(8) Concern:.The Assistant QC Supervisor (by 1narne) was fired. 'He was the one lha.t lied about his education. 011y Leads and a
fanagement.oro allowed to reips,%ct his work after he was
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terminated.
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NRC Review: 7 Threugh the review of records relate'd to this
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concern, it war donfirmed that the named individe,41 had falsiYied g
a Diplo.n of Graduation from North Cee. tral Collega, School of Technology. The individual resigned from HEco on tierch 21, 1986. A reinspection of the indisicual's hori wa3 nerformed
.under the guidance of CECc. At the time of tin reiaspec'. ion of
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stud welding, thesonly 19dividual certified inithis ares \\was the Level JII inspector., Thu, required " Management" to. p'nspect the in:lividuals stud weldirq inspections. The rainsphtton of
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the individual's visual weld lnspections were perforr.ed by a HEco QC Lead Ir.spector..Further,research by the NRC inspector
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indicated that'the indivicarl's Neld ingections had been ;
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previously reinspected under the Byron Reinspection Prcgram.
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should also"ce noted that the NRC SRI at Byron Station had been
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previously informed of the falsified education, reinspection program, and resbits of the reinspection.
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Conclusion:' This concern v a.substantikted in that Management (
D.evel DT) uid reinspect the individuals stud weld inspections,
.however, tha Level III was the only inspector certified in<this
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Additionally, the individual's visual weld inspections had been previously reinspected under the Byron Reinwetion Program.
No violations or deviations were identified
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(9) Concern: A QC inspector questioned an engineering design on a Detail J-(type of conduit hanger attachment). At.a special-meeting, the Level III Welding Inspector (by name) informed the QC inspectors that they do not perform engineering design j
reviews. The. Level III also stated that if an engineer said to put bubble gum on a hanger, QC's job was to inspect the bubble gum.
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NRC Review: During an interview of the named Level III, the i
Level III confirmed his meeting with the inspectors.
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small faction of the welding QC inspect' ors wanted to " redesign
the plant", the Level III deemed the meeting to be justified.
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With respect to the bubble gum, the Level III stated that the allegers statement was not correct. The Level III informed the 3 -
NRC inspector that what he actually said was, "If engineering
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said to put bubble gum on a hanger, it was QC's job to inspect
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.i the bubble gum and to make damn sure it was the brand specified."
Conclusion:
The Level III welding. inspector made a valid point, in that QC inspectors are to verify compliance with instructions, procedures, and drawings, not to conduct engineering reviews, The Level III's analogy was taken out of context. No violations
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or deviations were identified.
(10) Concern: HEco QC Department has gone to hell since Energy Incorporated (EI) came in.
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i NRC Review:
EI is a company that supplies QA/QC personnel
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under a contract with HECo. These personnel were assigned positions as QA engineers and cs QA/QC Management /Supervisers.
During personnel interviews, it was perceived by the Region III
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inspector that an anomic condition exists within the HEco QA/QC
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Department. This appeared to stem from the fact that outside
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personnel (EI) were brought in and placed in management and I
supervisory positions and the lack of communications between Managment/ Supervisors and the QA/QC staff. However, this anomic i _
condition did not affect the inspection effort and integrity of j.
the QC inspectors. As part of. Ceco's QA program, PTL does a 10%
overinspection of the HECo work.
From September 27, 1985
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l through July 10, 1986 (inspector's sample period), PTL performed approximately 800 overinspections and identified only two (2)
rejectable attributes that had been previously accepted by
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HEco QC inspectors.
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Conclusions: Although it was evident that some high level'of
animosity had developed between HECo QC staff ara the EI staff.
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and significant communication probelms existed, a high level of
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l quality inspections was maintained. This is based on the fact that PTL performed approximately 800 overinspections and found
two rejectable attributes. Therefore, thfs concern was not substaptiated. No violations or deviations were identified.
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(11) Concern: ' QC identified deficiencies on inspection reports are being dispositioned "use-as-is" by CECO and HECo. HEco engineering prepares a separate report (OIR) to accept the items as installed.
Some of their engineering reports were not numbered, or after the QC inspection report is closed,
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the engineering backup documentation (0IR) was destroyed.
i NRC Review:
Based on a review of Paragraph 5.1 of HECo Procedure 6, " Reporting of Damage or Nonconforming Material or
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Equipment," and personnel interviews, the following is a summary of how the Open Inspection Report (OIR) system should work:
(a) Deficiencies identified during routine surveillance or inspection activities are identified on the appropriate inspection checklist (IR) by the QC inspector.
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(b) OIRs (reports that indicate deficient checklist items found during QC inspections) are filed in a " work pending" file.
(c) Copies of OIRs,'along with the associated installation report, are provided to the Assistant Project Manager for resolution of the deficiencies, i.e., construction corrects the deficiencies.
(d) Corrected installation reports are returned to QC for verification of the corrected deficiencies.
(e) QC verifies the resolution and documents their acceptance on the OIR from the work pending file.
The NRC inspector identified the following examples of deficiencies within the HEco OIR program:
(a) Conduit inspection checklist, (Form HP-201) No. 4902, identified that conduit C2A7429 contained 370 of bends (maximum is 270 per specification). This nonconforming condition was dispositioned "use-as-is" by HECo engineering without licensee and S&L approval on an
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uncontrolled HECo engineering document (No form number)
identified as 0IR No. 4902-19?.
(b) Equipment modification inspection checklist (Form HP-12A-1) No. 5101, identified exposed copper at a termination lug on Terminal 13. This nonconforming condition was found acceptable as installed per a " Speed Letter" from T. Lamb, CECO PCD, to S. Bindernagel (Bindenagel), HEco' QC.
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(c) Conduit inspection checklist (Form HP-201), No. 4788, identified that the "0" ring was missing on conduit C2A1209.
"0" rin'gs are required per S&L specifications,
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Standard EB-146. This nonconforming condition was found acceptable as installed per a " Speed L:.cter" from S.
Vovos, CECO PCD, to E. Tovo, HECo engineering.
(d) Conduit inspection checklist (Form HP-201), No. 4736, identified that conduit C0A62F9 was installed outside the elevation tolerance. The inspection report indicated that during a reinspection, the Detail J connections had been cut off of a previously accepted hanger (SCC-1) and reinstalled without any documentation, i.e., Discrepancy Report (DR), Nonconformance Report (NCR), or Form 7A, Rework Request. During a review of this inspection checklist, the NRC inspector was informed that HECo engineering had prepared an 0IR to rework the hanger to correct the conduit elevation, however, no OIR could be found.
(e) Equipment modification checklist (Form HP-12A-1), No.14217, required a 100% inspection of panel 2PA11J prior to turnover to CECO. The inspector identified two potential problems:
(1) "Cannot determine if wire size is per print" (2) "Cannot inspect lugs landed up-side down" Both of these items were marked " acceptable" on the HEco inspection report by a CECO PCD engineer.
As a result of a management meeting in NRC's Region III office on July 2,1986, CECO QA initiated Audit 6-86-201 to address NRC concerns expressed during the management meeting. The lack of control of OIRs, as noted above, was one of these NRC concerns.
The CECO QA audit was performed by seven CECO auditors with assistance from PTL certified QC inspectors. This audit was initiated on July 7,1986, and concluded on August 4,1986. As a result of Ceco QA review of the HECo 0IR program, Ceco QA issued two findings against HECo and one finding against the CECO PCD electrical group.
Conclusions:
Based on the five examples of violations identified by the NRC inspector and the three findings identified by the licensee in Audit 6-86-201, this concern was substantiated.
The licensee was informed that failure to assure that design changes were approved by the organization (S&L and/or Westinghouse) that performed the original design was an example of failure to implement Criterion III of 10 CFR 50, Appendix B
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(Reference: Paragraph 5.a.(11)(a), (b), (c), and (e) above)
(50-455/86017-02).
The licensee was further informed that failure to assure that nonconforming conduit C0A62F9 (Reference: Paragraph 5.a.(11).(d)
above) was reworked or repaired in accordance with documented instructions (NCR or DR) or procedures is an example of a failure to implement Criterion XV of 10 CFR 50, Appendix B (50-455/86017-03).
(12) Concern: HECo material is not traceable. There are no heat numbers on any of the material.
If CECO accepted the material, HECo QC is not to question its acceptability.
NRC Review: Criterion VIII of 10 CFR 50, Appendix B, requires that the identification of an item be maintained in some manner throughout fabrication, erection, and use of the item. This identification and control is designed to prevent the use of incorrect or defective material, parts, and components. Based on an interpretation by the NRC, it is not necessary to provide unique traceability for items such as hanger material (A36),
unistrut, conduit, cable tray, etc. that are used in the electrical area (non-coded applications) provided:
The material is ordered safety-related,
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During receipt inspection, it is verified that the material meets the applicable specification requirements, including documentation,
Safety-related material is not comingled with non-safety-related material, and
The issue of the material for use or installation is controlled.
At the Byron Station, Ceco procures all material for all site contractors. With respect to electrical raceway material, these items are procured and received as safety-related.
In accordance with HECo Procedure 5, " Class I Material and Equipment Receiving and Inspection", HECo QC performs receipt inspection of CECO procured material, upon request, to Ceco requirements as stated on the Material and Equipment Receiving and Inspection Report (MRR).
In addition, for CECO Station Nuclear Engineering Department (SNED) procured items (permanent plant material items), CECO PCD and Ceco QA also performs a receipt inspection and/or documentation review. The release of the items or material for installation or use is performed by CECO QA after the material and documentation has been inspected / reviewed and accepted.
In general, when CECO issues items / material to HEco for installation or use, an additional receipt inspection by HECO QC is not required to determine its acceptability.
In that the vendor documentation is controlled by S&L or Ceco,
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HECo QC can not determine the acceptability of an item. However, t
if a damaged or defective item is observed by the HECo QC inspector, this deficiency must be documented and reported in accordance I
with HEco Procedure 6, " Reporting of Damaged or Nonconforming Material or Equipment."
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Conclusions: This concern was substantiated, however, the tracking of an item by part or heat number is not required for non-coded applications in the electrical area. HECo and/or CECO performs the required receipt inspections. HECo can however identify nonconforming hardware problems.
In that HEco QC does not have access to the vendor documentation, they cannot determine an items software acceptability. No violations or l
deviations were identified.
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(13) Concern: HECo QC was instructed not to look at vendor welds.
HECo QC rejected better welds than most of the vendor welds,
however, CECO bought-off all of the vendor welds. Think the i
vendor was Systems Control.
NRC Review: A review of the history on Systems Control revealed that welding problems had been identified and documented by HECo, CECO, and the NRC. As documented by CECO and the NRC, there were instances where undersized welds and missing welds were evaluated by S&L and found acceptable as installed.
The following are examples of NCRs and reports that address
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problems, corrective actions, and acceptance of welding by Systems Control: HECo NCRs 461,1062, 1065, 1066 and 1067; CECO NCR 885; Ceco 50.55(e) Reports No. 454/82008 and No. 455/82008; CECO QA Audit Report No. 6-84-309; and NRC Inspection Reports
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454/83039, 455/83029, 454/84C31, 455/84024, and 454/84050, 455/84034.
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Conclusions:
It was substantiated that Ceco experienced
problems with Systems Control welding and based on an analysis by S&L, many of these welds were accepted in the as-found l
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However, these welding problems had been documented and resolved by the licensee with followup inspections and
acceptance by the NRC.
No violations or deviations were identified.
(14) Concern: The HECo QC Supervisor (by name) does not have any certifications to any of the procedures at Byron Station.
HECo
wanted to make the named individual a Level III inspector but the present Level III (by name) would not sign his name to any
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certifications for the named QC Supervisor.
It was also stated that this same QC Supervisor misplaces / destroys NCRs and DRs.
A QC inspector (by name) told the alleger that the Supervisor
destroyed three of his NCRs/DRs. The named QC Supervisor managed by intimidation and was interested in quantity, not quality.
NRC Review: The NRC inspector reviewed the training,
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qualification and certification file for the named QC Supervisor.
Except for a resume, this individual's file folder was blank.
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HECo Procedure 17, " Qualification and Training of Inspection and i
Audit Personnel", Paragraph 5.3, requires that all QA/QC personnel
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complete the "QA/QC Personnel Indoctrination Checklist",
Form 172. This indoctrination includes but is not limited to:
reading electrical specifications; knowing Byron alarm signals, i
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emergency phone location and procedure; reading the HECo QA Manual and QC procedures; and becoming familiar with the S&L i
drawings and standards.
This named QC Supervisor started his employment with HEco at the Byron Station on October 7,1985, and as of June 13, 1986, he had not started his basic
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indoctrination as indicated by his file.
In addition, the HECo QA/QC Manager (Employment date of August 6,1984) and the QA
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Supervisor (employment date of February 25,1985) had not
l completed their basic indoctrination as of June 13, 1986. The i
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QA Supervisor inform d the NRC inspector that none of his QA engineers had completed this training. During an interview of the named Level III inspector, the NRC inspector was informed that the Level III had no confidence in the named QC Supervisor and that he would not certify him to any procedures.
On August 6, 1986, a physical search was made of the named QC Supervisors office and no open NCRs, DRs or 0 irs were found.
During an interview of the named OC inspector, he did not identify any concerns pertaining to any specific documents that the named QC Supervisor may have destroyed. As stated in Paragraph 5.a.(10) above, there was a lack of communications between Supervision and the QC inspectors, however, based on the small rejection rate (0.25%) of HECo QC inspection activities by PTL's overinspection, this lack of communication did not affect quality.
Conclusions:
It was verified that the named QC Supervisor was not certified and the named Level III would not certify him, however, there is no requirement for a supervisor to be certified if he/she does not perform QC acceptance inspections.
It could not be verified that this supervisor destroyed or misplaced any quality related documentation. Based on the results of PTL's overinspection program, this supervisor's management techniques did not affect the quality of the project. However, the licensee was informed that failure to assure that indoctrination and training was provided to QA/QC personnel in accordance with approved procedures is and example of failure to implement Criterion II of 10 CFR 50, Appendix B (454/86031-14A; 455/86017-14A).
(15) Concern: The QA/QC Manager told a QC Group Leader (by name)
to hold a stack of Unit 1 inspection reports. These reports identified deficiencies that were never corrected and items that were never reinspected. The Unit 1 turnover logs are not accurate.
NRC Review: On July 18, 1986, while conducting personnel interviews related to this concern, the NRC inspector was provided a printout that listed 44 Unit 1 and 11 Unit 2 open inspection reports. The NRC inspector provided a copy of this printout to the CECO QA Site Superintendent for information and corrective action.
In that Unit I was shutdown for other maintenarce activities, immediate action was taken to resolve the 44 Unit 1 open inspection reports. The reinspection identified some deficiencies which resulted in 15 nuclear work requests (NWR) being issued to rework and reinspect the identified deficiencies. Upon returning to Byron Station on Monday, July 21, 1986, the NRC inspector was informed that all corrective actions had been completed to resolve the deficiencies.
The inspector reviewed all the NWRs and selected 12 for physical inspection of the reworked items. All corrective actions reviewed were found to be adequate.
Following are examples of the deficiencies identified:
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NWR 6DG049 - Class IE Equipment Modification Inspection Report No. 4377, dated August 15, 1983, identified that all the bolts.on a buss bar insulator support were loose (i.e.,
less than finger tight). This deficiency was located in Unit 1 4160V diesel generator panel IDG01KB.
- NWRs 6DG046 and 6DG047 identified improperly installed
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heat shrink tubing.
- Six NWRs identified conductor insulation damage.
In several cases, the copper. conductor was also damaged.
In these cases, damaged conductors were cut off and new conductors butt spliced onto the cable.
- Five NWRs required the replacement of termination lugs due to improper installation or damage.
To determine the root cause for Unit 1 inspection reports still being open approximately 17 months after the unit went into operation, additional interviews were conducted. During these interviews, the NRC inspector was informed that a HECo QC Group Leader was made aware of the existence of an unknown quantity of Unit 1 inspection reports in HECo's possession that had not been processed. With HEco management approval, a physical search of the HEco premises was conducted on April 12, 1986.
This search uncovered 360 Unit I and 13 Unit 2 inspection
reports in a tool box controlled by the QC Group Leader named in the concern. This named Group Leader was permitted to resign, effective April 22, 1986, indicating that he was not holding these reports at the direction of the QA/QC Manager.
HECo QA took possession of these 373 reports and-initiated a review to determine acceptability. In that Unit I had been turned-over to CECO, the HECo Quality Program had no means to
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formally transmit a Unit 1 deficiency to CECO except when they are performing work activities under the licensee's nuclear
work request (NWR) program. A review of the HECo QA Manual and Specifications F-2790 indicated that the requirements of 10 CFR 21 had not been imposed on HECo.
In addition, a Commonwealth Edison Company Vice President stated during a meeting i.
in the NRC's Region III Office on July 2, 1986, that Commonwealth Edison Company does not impose the requirements of 10 CFR Part 21 on any of their onsite contractors. On approximately June 10, 1986, a HEC 0 QC Group Leader informally informed the CECO PCD Project Electrical Supervisor and a PCD Electrical Engineer of the 44 Unit 1 open inspection reports that had been identified by
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HECo QA.
In that the HECo QA/QC Manager and QA Supervisor had
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baen terminated approximately July 2,1986, the NRC inspector
could not determine why CECO was not notified sooner. When cuestioned as to why he (QC Group Leader) decided to inform CECO of the open inspection reports, he responded, "I knew that sooner
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or later you would ask the right question and I thought they (CECO) should know about it before I had to tell you."
Although CECO PCD became aware of the Unit 1 open inspection reports on approximately June 10, 1986, this fact was not documented in any CECO corrective action system as of July 18, 1986.
Based on this latest information, the inspector queried several QA engineers to determine the location and status of the 360 Unit 1 inspection reports. Upon request, the NRC inspector was provided a stack of Unit 1 inspection reports. Again, this information was shared with the CECO QA Site Superintendent.
During a review of these reports, it was observed that there were 28 unnumbered inspection reports r.nd an additional 13 reports where the status of the item was indetcrminate.
An immediate reinspection of these items was initiated by the licensee. This reinspection verified that five of the inspection reports were acceptable and eight reports required rework and reinspection. The rework and reinspection was completed in approximately 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />.
The NRC inspector performed in process inspections of these work activities and found them to be adequate.
In addition to the 360 Unit 1 inspection reports discussed above, HECo QA had an additional 81 closed Unit 1 inspection reports for work activities directed by the licensee. On approximately July 24, 1986, these 441 (360 plus 81) Unit 1 inspection reports were transmitted to the licensee on transmittals 293, 294, 323, and 314.
With respect to the concern regarding Unit 1 turnover logs, the concern was substantiated by the fact that neither the turnover reports or turnover log identified the 360 inspection reports discussed above.
In addition, HECo failed to establish a system to accurately status inspection reports (i.e., open, closed) to preclude inadvertent bypassing required inspections and tests and assurance of final acceptance.
The NRC inspector also established during the review of this concern that CECO does not have a proceduralized system for Byron Construction to notify Byron Operations of construction deficiencies which could potentially impact the safe operation of Unit 1.
Also, it was apparent that CECO does not have an effective system to determine if the site contractors have turned-over all required documentation prior to accepting an item / system from the contractors (HECo).
Also, as of July 17, 1986, the deficiencies identified with Unit 1 items, as identified above, were not evaluated for reportability per the requirements of 10 CFR 21. An evaluation for reportability would have been initiated per procedure if CECO PCD had prepared an NCR when they learned of the open Unit 1 inspection reports.
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Conclusions:
It was established that HECo was holding 360 Unit 1 inspection reports (with an indeterminate status) and that CECO was not aware of this problem until approximately June 10, 1986. Of these 360 reports, 28 were not numbered and 57 required reinspection or rework and reinspection.
It was also verified that the HECo turnover log / reports were not accurate in that these 360 Unit I reports were not listed.
The licensee was informed that:
(a) Failure to incorporate the provisions of 10 CFR 21 intc the HECo contract is an example of a failure to implement Paragraph 21.31, " Procurement Documents", of 10 CFR 21.
This violation is generic for all CECO site contractors (454/86031-02; 455/86017-04).
(b)
Failure to assure that conditions adverse to quality were promptly identified and corrected is an example of a failure to implement Criterion XVI of 10 CFR 50, Appendix B (454/86031-04).
(c) Failure of the electrical contractor (HECo) to ensure that all required documentation (inspection reports) were contained in the Unit I turnover packages in accordance with HECo Procedure 22A is an example of a failure to implement Criterion V of 10 CFR 50, Appendix B (454/86031-05).
(d) Failure of the electrical contractor (HECo) to establish a system to accurately status inspection reports to preclude inadvertent bypassing required inspections and tests is an example of a failure to implement Criterion XIV of 10 CFR 50, Appendix B (454/86031-06; 455/86017-05).
(e) Failure of CECO to have a proceduralized system for Byron Construction to notify Byron Operations of deficiencies which could potentially impact the safe operation of Unit 1 is an example of a failure to implement Criterion V of 10 CFR 50, Appendix B (454/86031-07).
(16) Concern: HECo received an FCR for a TYK connection, (this.is a tube steel to tube steel weld). HECo was to qualify this joint but they never prepared a WPS or anything. AWS does not have a pre qualified procedure for a flared V weld.
NRC Review: During interviews of QC personnel regarding this concern, the NRC inspector was provided a copy of Discrepancy Report (DR) 8311.
The DR stated, " Weld detail DV-315 and DV-316 on drawing 1-3366F, Revision E, requires a flare V groove weld.
Hatfield has no welding procedure for this joint configuration."
The resolution to this problem was to revise the joint configuration so that a flare V groove weld was no longer required. This was accomplished by S&L's approval of Field Change Request (FCR) No. F-26801 and FCR No. F-26803.
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Conclusion: Based on the NRC inspector's review, it'was established that HECo did not have a qualified weld procedure for flared V groove welds. However, the requirements for this type weld was deleted by issuing FCRs F-26801 and F-26803. No violations or deviations were identified.
(17) Concern: Welding QC inspectors were denied overtime (OT)
because their number of inspections were not up to par. Also,
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the Level III Welding Inspector (by name) stated at a safety meeting on May 7,1986, that there was a planned lay-off in August and the inspectors with the most acceptable inspections would stay. Quantity not Quality.
NRC Review: With respect to the concern that welding QC
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l inspectors were denied 0T because their number of inspections were not up to par, this concern was refuted. During personnel
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interviews, the NRC inspector was informed of OT problems in January 1986 and was provided copies of letters on this subject.
Overtime had been scheduled for numerous welding and conduit inspectors on Saturday, January 25, 1986, however, 11
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inspectors (including the alleger) failed to show up for the scheduled overtime. The following week, when the OT schedule i'
-was being prepared, these 11 inspectors were not asked to work due-to their refusal to work the previous week. The QC Supervisor had a change of. heart after some of the inspectors apologized for their actions the previous week at about 4:00 p.m. January 31, 1986.
In that the alleger had left the site at approximately 2:30 p.m. that day, he could not be contacted i.
to work on Saturday, February 1,1986.
With respect to the scheduled lay-off, as a result of personnel interviews and observing the reduction in force (RIF) schedule,
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this concern could not be substantiated. As part of this I
inspection, the NRC inspector obtained the HECo RIF schedule from l
CECO. This schedule was prepared by HECo and submitted to CECO for information. This RIF schedule has been generally adhered
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to.
The exceptions to this schedule are as follows:
four inspectors were terminated due to positive tests for drugs
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(Reference Paragraph 5.b of this report); termination of the QA/QC Manager, QA Supervisor, and QC Supervisor; and the extension of employment of several inspectors. The named Level III welding inspector stated that he had informed his inspectors of the pending RIF, and that the RIF schedule was
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determined by their Lead Inspector's evaluation of their performance and attendance. This statement was confirmed during
.1 interviews of other QC personnel. The safety meeting was not limited to welding inspectors in that the named Level III is also the Assistant QC Supervisor. See Paragraph 5.a.(10) on quality of inspections.
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Conclusion: Based on personnel interviews, review of HECo letters, and the comparison of the RIF schedule with termination dates, these concerns could not be substantiated.
See Paragraph 5.a.(10) on quality of inspections. No violations or deviations were identified.
(18) Concern: HEco engineering sent out a clarification letter on Detail J installations. An inspector rejected an installation based on this letter and a discussion with an S&L engineer.
Engineering reversed their decision after thousands of Detail Js were installed and the inspector got hell for going to S&L.
NRC Review: During personnel interviews, the NRC inspector was provided a copy of the subject letters and Discrepancy Report (DR) 8320. The first letter, dated March 8, 1985, provided two examples of acceptable Detail J (type of raceway support)
configurations and one example that wcs unacceptable. A QC inspector contacted an S&L engineer for an interpretation on a hanger being inspected.
In accordance with the S&L engineer, the QC inspector described the unacceptable Detail J configuration. The S&L engineer informed the QC inspector that the configuration described was unacceptable. Based on his discussion with the S&L engineer and HECo engineering letter of March 8,1985, the QC inspector prepared DR 8320 on February 20, 1986. The DR was dispositioned "No Discrepancy as Written" with justification.
It appears that the QC inspector confused a CS type connection (actually installed) with an unacceptable Detail J type connection. These two types of connections are similar in appearance except, the CS connection is welded at the four coraers only and the unacceptable Detail J is welded on two sides of the plate.
DR 8320 was closed on March 3, 1986.
The second HECo letter on Detail J connections, dated April 22, 1986, states, in part, "The acceptable configurations for a Detail J are shown on the attached sketch. Notice that the configuration that was disallowed in the March 8, 1985, letter has been re-analyzed by S&L structural as being acceptable."
From a safety stand point, the 1986 letter did not disallow any configurations that were allowed in the 1985 letter. Also, the design change was made by S&L, not HECo engineering, and is shown on S&L drawing 6E-0-3393F.
In accordance with HECo policy, HECo engineering interfaces with S&L engineering.
If a HECo QC inspector has an engineering type problem, they are to take their problem, through their Lead, to HECo engineering for re:,ol u tion. This policy meets the intent of Criterion III of 10 CFR 50, Appendix B, which states, in part, " Measures shall be established for the identification and control of design interfaces...."
Conclusions: HECo engineering did in fact issue two clarification letters on Detail J configurations. The second letter, based on an S&L analysis, allows the installation of a previously disallowed configuration. The use of these two HECo
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engineering letters would not permit the installation of an unacceptable Detail J configuration. DR 8320 was properly closed. HECo interface policy with S&L is acceptable. No violations or deviations were identified.
(19) Concern: A QC inspector (by name) prepared an NCR approximately one year ago for cross-flange welds, blow hole (burn thru) in the J-Box, no welding pre-heat, and welded with 6010 rod. This J-Box is located in the cable spread room, 451' elevation, and the cables entering this J-Box came from the screenhouse. The NCR was dispositioned use-as-is and it shouldn't have been.
NRC Review: During a review of NCRs issued in the timeframe specified above and interviews of QC personnel, NCR 1537, dated June 10, 1985, was identified as the NCR of concern. This NCR documented four cross-flange welds, use of 6010 rod and lack of pre-heat during the installation of J-Box 704A. The J-Box was located in the cable spread room at columns 21 and P at the 473' elevation. The S&L approved disposition stated, " Abandon the four cross-flange welds and add new welds per FCR 70050."
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NCR 1537 was properly closed on July 29, 1985, by the alleger.
Conclusions: This concern was not substantiated in that NCR 1537 was reworked in accordance with an S&L approved disposition and the NCR was properly closed by the alleger.
(20) Concern: The HECo QA/QC Manager (by name) is " bird-dogging" a QC inspector (by name). Every time the named QC inspector came to the office to review drawings or documentation, the named QA/QC manager would call the inspector's Lead and/or the Assistant QC Supervisor or the QC Supervisor and inquire as to why the named inspector was in the office again.
NRC Review: As part of the followup on this concern, the NRC inspector reviewed the Byron SRI's notes of his interviews of the named QC inspector and named QA/QC Manager on the
" bird-dogging" issue. The NRC inspector was unable to interview the named QA/QC Manager, the involved QC Supervisor, and one of the involved Lead Inspectors because they were no longer employed by HECo. The NRC inspector interviewed co-workers and previous supervisors of the named QC inspector and also reviewed performance evaluations of this QC inspector. The named QC inspector was assigned to work out of a field office some distance from the HECo main office. All the QC inspectors and supervisors working out of the field office had a need to go to the main office to review " vaulted" documents. During personnel interviews, the NRC inspector was informed that the named QC inspector was noted for his socializing when he had to go to the main office.
During an interview with the NRC SRI, the named QA/QC Manager stated that he did in fact call the inspector's superv,isor one time to verify that the inspector had a need to be in the main office.
The QA/QC Manager also stated that he made the call to the supervisor only after cbserving the named P
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QC inspector in the main office every day for a week. During an interview of the involved supervisor, he stated that the QA/QC Manager called him several times about the named QC inspector being in the main office.
The supervisor also stated that in general, the inspector had a need to be in the main office and the inspector's Lead knew the task being worked on.
The supervisor said that at times he felt that the QC inspector would invent reasons to go to the main office just to antagonize the QA/QC Manager. However, from a review of performance evaluations and additional interviews, it would appear that undue restrictions were placed on the named inspector in that he was the only inspector that required specific approval from his Lead Inspector to go to the main office.
Following is part of a written statement (one of four) made by one of the named inspector's Leads, "During the period from January 6 to April 28, 1986 (named inspector) was assigned to the Welding QC Department under my supervision.
During this period I was directed by (name) (QC Supervisor) and (name) (Asst. QC Supervisor) to insure that (name) did not make unnecessary visits to the Hatfield Main Office.
(Name) was to inform me of his reasons for such visits to the main office.
I understand the reason for this policy being implemented was that (name) had previously been observed spending unnecessary time in the main office."
This written statement is typical of the four statements provided to the inspector.
Conclusions: Based on interviews of QA/QC personnel and the review of written statements, it appears that undue restrictions (bird-dogging) were placed on the named inspector in that he was the only inspector that required specific approval to go to the HECo Main Office. However, a contributing factor appears to be his (named inspector) excessive socializing while in the main office and attitude toward QA/QC management.
No violations or deviations were identified.
(21) Concern: Construction worked through a Hold Tag (NCR 1860).
The inspector could not write an NCR, instead QA wrote Corrective Action Reports (CAR) 002 and 003.
NRC Review: During an interview with the alleger, the NRC inspector was provided a copy of a draft NCR (NCR without a report number assigned) and CARS 002 and 003. The draft NCR stated that Hold Tag 1860 was attached to J-Box 2JB683A and that construction installed conduit and cable in the J-Box in violation of the Hold Tag. The inspector reviewed the NCRs prepared in the same timeframe (February 1986) to verify that the draft NCR had not been placed in the system without the alleger's knowledge. No NCR was observed for working through Hold Tag 1860. CAR 002 was prepared on February 17, 1986 to document the violation of Hold Tags, with a sequence of events attached. On February 21, 1986, CAR 002 was voided due to an incorrect description of the concern and CAR 003 was prepared.
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CAR 003 not only described the violation of Hold Tag 1860 (NCR 1860), it also describes the violation of Hold Tag 1825 (NCR 1825).
CAR 003 was properly closed on March 11, 1986.
For this type of nonconformance, working through Hold Tags, the CAR would be the most effective document in that it receives a higher level of management review.
Conclusions:
This concern was substantiated, however, for this type of nonconformance the CAR would be the most effective document to identfy and resolve these violation. No violations or deviations were identified.
(22) Concern: HECo was working through Hold Tags per direction from CECO PCD.
NRC Review: The NRC inspector was provided a copy of a memo to the HECo QA/QC Manager, dated January 16, 1985.
Following is a sequence of events as described in the above referenced memo:
(a) Roughneck (Ceco's core holing contractor) was coring a 3" hole for HEco when a rebar was hit. The HECo QC inspector verbally stopped work and prepared NCR 1281 to document the rebar hit.
(b) A HECo QC supervisor informed the PCD engineer that work could not continue on the coring until HECo received a disposition on the NCR.
(c) A Ceco PCD engineer (by name) instructed Roughneck to continue coring the hole and that an FCR would be prepared to allow the rebar hit.
(d) When the inspector went back to the area to attach the Hold Tag, he observed that the core hole had been completed.
(e) S&L issued FCR F-25836 after NCR 1281 was prepared _ without referencing the NCR, indicating that the FCR was being used to document a nonconforming condition.
Based on the above memo, the NRC inspector performed an indepth i
review of HECo core drilling activities.
Even though the
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actual core drilling is performed by a different contractor, HECo is responsible for the inspection and documentation of the cering when tbc hele is being used for electrical installations.
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HECo Procedure 21, " Cored Hole Installation and Inspections,"
states, in part, " Paragraph 5.1.13 - No items may be installed in a cored hole until Hatfield Electric Company receives a completed CHR (Cored Hole Report) signed off by CECO PCD.
Paragraph 5.3.3.3 - Only cored holes in Category I structures
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where rebar has been cut and/or hit and which are in areas
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where rebar cuts are not allowed, shall have the cut / hit documented on a HECo NCR. The NCR number shall be referenced on f
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l the CHR." Paragraph 5.3.5.3 of HECo Procedure 6, " Reporting of
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Damaged or Nonconforming Material or Equipment," states, " Items
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identified as nonconforming, if not yet installed, may not be i
used or if installed, may not have additional work performed on them unless it is authorized by the owner."
A review of HECo's NCR form indicates that the owner's authorization to work on a nonconforming item prior to corrective action being completed (work may proceed) requires approval by CECO PCD with concurrence by CECO QA. During an interview with the CECO QA Superintendent, he stated that the NRC inspector's understanding of the HECo NCR form was correct in that " Work May Proceed" must be approved by CECO PCD and receive concurrence from Ceco QA. During a review of HECo NCRs, the NRC inspector observed that when HECo prepares an NCR to document the fact that HECo construction installed conduit in a cored hole in violation of a " Hold Tag", the NCR would be forwarded to CECO PCD for disposition. A typical disposition by CECO's Project Electrical Supervisor for this type NCR is "This is not an NCR, therefore, no C/A (Corrective Action) is required." With the explanation that "The completed CHR, signed off by CECO PCD is the owner's authorization to proceed with installation work."
NCRs 2056 and 1627 are two examples with the above disposition.
In addition, the inspector was provided several " draft" NCRs (i.e., no number assigned) that were voided by the HECo QA/QC Manager with the disposition for UCR 1627 attached.
During an interview of the CECO PCD structural engineer (engineer that reviews and approves CHRs), the NRC inspector received the impression that this Engineer did not realize that his signature was the Owner's authorization (per NCR dispositions) for HECo to proceed with installation work when there was an open NCR on the subject cored hole.
During a review of NCRs on cored holes versus conduit installation reports, approximately ten instances were identified where " Hold Tags" were violated. However these violations were not documented based on PCD's interpretation of Owner's authorization.
Conclusions:
Based on the NRC inspector's review as noted above, it was established that CECO PCD (Project Electrical Supervisor) directed HECo to violate their Procedure 6 with respect to Owner's authorization for continued work on a nonconforming item.
This violation appeared to be for cored holes only.
The licensee was informed that failure to control nonconforming item to prevent their inadvertent use is an example of failure to implement Criterion XV of 10 CFR 50, Appendix B (455/86017-06).
(23) Concern: HECo Project Engineer (by name) threatened to void NCR on procedure violation.
The alleger told the Project Engineer that he would take the NCR to the NRC if it was voided.
The Project Engineer signed the NCR.
Example was not provided.
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NRC Review: The NRC inspector reviewed HECo Procedure 6,
" Reporting of Damaged or Nonconforming Material or Equipment,"
to determine the duties and responsibilities of the Project Engineer with respect to NCRs.
Paragraph 5.3.3 assigns the responsibility for preparing NCRs to HECo QA and Engineering.
During the review of NCRs, it was noted that both QA and Engineering did, in fact, prepare NCRs.
Paragraph 5.3.4 assigns the responsibility for the completion of the deficiency description on the Construction Deficiency Evaluation (CDE) form and attaching this form to the NCR. Utilizing this form, the licensee evaluates the deficiency for reportability per the requirements of 10 CFR 50.55(e). A completed CDE form was attached to all NCRs reviewed during this inspection.
Paragraph 5.3.6.1 assigns HECo engineer the responsibility for completion of Part II (Corrective Action and Action to Prevent Recurrence) of the NCR, when appropriate, prior to review by the HECo QA/QC Manager. This is a recommended disposition only.
The final disposition is made by the licensee and/or S&L. When the NCR comes back from the licensee, HECo engineering is responsible for notifying the appropriate personnel of the required " corrective action" and " action to prevent recurrence" to be implemented. The only time the Project Engineer signs an NCR is when he is the preparer of the NCR. During the NRC inspector's review of hundreds of NCRs, it was observed that all voided NCRs had been voided by the HECo QA/QC Manager.
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Conclusions: Based on the NRC inspector's review of Procedure 6 and hundreds of NCRs, this concern could not be substantiated.
No violations or deviations were identified.
(24) Concern:
Procedure 20, " Class I Exposed Conduit System Installation," Paragraph 5.6.5, states that final inspection of conduit terminations would be made during cable termination inspections. This is not addressed in Procedure 11, " Class I Cable Termination and Splicing."
NRC Review:
Paragraph 5.6.5 of Procedure 20 states, in effect, that final inspection of conduit terminations to equipment, except J-Boxes and Pull-Boxes, would be made during cable termination inspections when the equipment was not installed at
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time of the conduit inspection, per Procedure 11.
Paragraph
5.1.24.1 of HECo Procedure 11 states, in part, "If a short run of Sealtite or conduit is required to bring the cable into a gear, Hatfield QC must be notified so that any required
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inspections can be picked up."
This attribute is inspected and documented on Form HP-118, " Cable Termination Inspection Report," item 14. The NRC inspector reviewed HP118 Reports 21601 through 21850 and verified that item 14 was being inspected by the QC inspector.
No deficiencies were
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Conclusions: Based on the NRC inspector's review of HECo Procedures 11 and 20, and the review of 250 Cable Termination Inspection Reports, this concern was not substantiated.
No violations or deviations were identified.
(25) Concern:
For Battery Rack 2DC01EA and 2EC02EA, the minimum embed depth for CEAs (concrete expansion anchors) is four inches.
PTL (Pittsburgh Testing Laboratory) Reports 23821 and 23820 indicated embed depths of 3 1/2" and 3 1/8". A HECo QC inspector (by name) could not write an NCR on these two nonconforming conditions.
NRC Review: During interviews of HECo QC and engineering personnel and CECO QA and engineering personnel, the NRC inspector was informed that Blount Brothers Corporation (BBC) installed the CEAs for Battery Racks 2DC01EA and 20C02EA.
During the CAT Inspection on August 19 through September 20, 1985 (Reference:
IE Report No. 50-455/85027), an inspector identified one CEA on each of the subject battery racks that did not appear to meet the minimum embed depth. As a result of this observation, PTL was directed to inspect the CEAs for these two racks. Using the ultrasonic test (UT) method, PTL identified one of ten CEAs on battery rack 2DC01EA with an embed depth of 31/2". The other nine CEAs exceeded the minimum 4" embed depth (Reference:
PTL Report 23821, dated September 10,1985). Based on this PTL report, BBC prepared Deviation Report (DR) Q3-955 to document the deficiency. This deficient CEA was evaluated by S&L and DR
- Q3-955 was dispositioned "use-as-is" and FCR F44367 was issued to document the as-built conditions.
PTL also identified one of ten CEAs on battery rack 2DC02EA with an embed depth of 31/8".
The other nine CEAs exceeded the minimum 4" embed depth (Reference: PTL Report 23820, dated September 10,1985). This deficiency had been previously identified on September 15, 1983, as documented on BBC's OR Q3-725.
S&L issued FCR F-43535, dated May 29, 1984, to accept the CEA (DR Q3-725) in the as-found condition. Based on the licensee's actions, this item was closed in the CAT Report 455/85027, Paragraph II.B.3.b.(5).
Based on the CAT report and the NRC inspector's review of the PTL reports, BBC DRs, and S&L FCRs discussed above, the NRC inspector determined that there was no need for HECo to prepare an NCR to identify the same nonconforming issues.
Conciustoas: Based on the NRC CAT inspection report and the NRC inspector's review of the applicable documents referenced above, it was concluded that there was no need for HECo to prepare an NCR or tne two CEAs that did not meet the minimum embed depth. No violations or deviations were identified.
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(26) Concern: There are no weld travelers listed for conduit hanger WP2-1 on hanger inspection report (Form HP-203) number 1021.
Two Detail J's are not welded to the hanger and the AP attachment is no good.
NRC Review: Utilizing the WANG (computerized tracking system),
it was determined that no weld travelers were listed for hanger WP2-1.
During a review of inspection report 1021, the NRC inspector observed that hangers TS-1, WP2-1, SWCP3-3, and SWCP3-4 had been inspected to drawing 0-3302A and were found acceptable on May 4, 1982. A review of the applicable drawing indicated that these hangers were located in the Auxiliary Building, Columns 15 and L, 346' elevation. During a physical inspection of conduit hanger WP2-1, the NRC inspector observed that the two Detail J's (steel plates) were not attached (welded)
to the hanger and tbc AP connection was not installed per the design drawing and that hanger WP2-1 supports conduits C0A0203 and C0A0204.
In that hangers / supports are also verified during conduit inspections, the inspector reviewed Conduit (C0A0203)
Inspection Checklist 928, dated May 5,1982 and Conduit (C0A0204)
Inspection Checklist 929, dated May 5,1982. During the review, both of these checklists (928 and 929), the supports were checked as acceptable and hanger inspection Report 1021 was referenced, and both reports were signed off as being acceptable.
During electrical cable installation, a pre pull inspection is performed on the applicable raceway and this inspection is documented in Part 1 of the Cable Installation Inspection Checklist (Form HP-105) (Reference: HECo Procedure 10).
From applicable records, the NRC inspector determined that cable 2SX031-P1E was installed in conduit C0A0204 and cable 2SX032-CIE was installed in conduit C0A0203. A review of Cable Installation Inspection Checklist for cable 2SX032 indicated that the raceway was acceptable, and the cable was released for pull on October 13, 1982. Cable 2SX032 was installed on November 8, 1982. A review of Cable Installation Checklist for cable 2SX031 has conduit (Part 1, Item B) marked as "N/A", however, Page 3 of 3
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of this checklist listed conduits C0A09E5 and C0A0204 for cable routing points. The checklist for cable 2SX031 indicated that the cable was released for installation and installed on April 27, 1984. On July 30, 1986, the licensee prepared NCR 2059 on hanger WP2-1 to document the as-found condition. The issuance of this NCR should result in the correction of the problems found with hanger WP2-1.
Corclusions: This concern was substantiated in that a physical inspection of hanger WP2-1 revealed two detail J connections were not welded and the AP attachment was not in its designed location.
Also, using the WANG, it was determined that a weld traveler had not been prepared for hanger WP2-1, listed on drawing 0-3302A.
The licensee was informed that failure to assure that measures
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were established to promptly identify and correct conditicns adverse to quality is an example of a failure to implement Criterion XVI of 10 CFR 50, Appendix B (455/86017-07A).
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(27) Concern: There are no conduit inspection reports (Form HP-201)
for conduits C0A32K8-C2E, C0A2265-K2E, C0A0282-P2E and C0A0283-C2E.
NRC Review:
During interviews of HECo QC and engineering personnel and review of applicable records, the NRC inspector established that the conduits noted above were installed in Byron Unit 1.
Utilizing the WANG system, it was also established that conduit inspection reports (Form HP-201) for the subject conduits did not exist. The licensee determined that the subject conduits did not need to be reinspected to HECo's routine inspection program (Procedure 20) in that they had been inspected and accepted under the licensee's as-built inspection program.
Conclusions: The HP201 forms had not been prepared to document the inspection and acceptance of conduit C0A32K8, C0A2265, C0A0282 and C0A0283, however, these conduits had been subsequently inspected and accepted under the licensee's as-built inspection program. No violations or deviations were identified.
(28) Concern: Nonconformance reports (NCR) are typically dispositioned "use-as-is."
Think there should be more rework or repeir dispositions.
Corrective action to prevent recurrence is not effective or not adequate (Reference: HEco memo 1866)).
Poor disposition on NCR 1581.
NRC Review: The NRC inspector reviewed all HECo NCRs prepared between June 1,1985 and June 8,1986. The NRC inspector also reviewed HECo Procedure 6, " Reporting of Damaged or Nonconforming Material or Equipment." In that most of the items requiring rework / repair are documented on Inspection Reports (IR) or Discrepancy Reports (DR), the NCR is generally reserved for deficiencies that HECo is requesting an analysis for a "use-as-is" disposition. The NRC inspector reviewed the NCRs for proper closure with respect to corrective action and action to prevent recurrence. During the review, the NRC inspector selected approximately 30 NCRs for review of analyses at the S&L onsite facilities. All analyses reviewed at S&L were found to be adequate.
During the review of NCR 1990, it was observed that Pin Connector Termination Tool W-002 had been sent to Burndy for repair and calibration. Tool W-002 was received back onsite in calibration, however, Burndy failed to record the as-found condition, thus making the quality of the termination crimps made since the previous acceptable calibration indeterminate. During the review of the tool checkout log and inspection reports, HECo determined that Tool W-002 had been utilized on 16 plug connectors since the previous calibration. The NCR (1990) was dispositioned
" Accept crimps as is. The last 16 inspections were done in proces; and the crim;. tool's calibration date had not been reached when the tool was in use."
This disposition was approved by a CECO PCD engineer without considering that all documentation from Burndy indicated that the tool had been repaired. After l
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the NRC inspector expressed a concern with the disposition of NCR 1990, the licensee obtained the tool acceptance criteria from Burndy.
From the HECo inspection reports, the last usage of the tool was identified. Using the information from Burndy, the licensee measured the termination crimp indents and found them acceptable. This reinspection resolved the inspector's concern with the acceptability of the crimps made with Tool W-002.
HECo NCR 1581 and CECO NCR F-997 documented the improper use of Kellem type cable grips (Detail G) that was specified for use in the Auxiliary Electrical Equipment Room only and was used in other areas of the plant.
S&L issued FCR F-6665 to allow the use of Detail G cable grips in all areas of the plant. S&L drawing 6E-0-3393P was revised to incorporate this FCR.
CECO NCR F-997 was properly closed on November 22, 1985, based on the issucce of FCR F-6665 and the training of HECo crt.f t personnel. 3ECo NCR 1581 was properly closed on December 3, 1985, based on the closure of CECO NCR F-997.
On May 23, 1985, a training session with craft personnel was conducted due to the number of nonconformances being identified by HECo QC inspectors. Topics covered included installation requirements; drawings; S&L standards; HECo procedures; and the requirement to obtain prior written approval before making any deviations. HECo QA/QC Memorandum 1866 was prepared to document this training and states, in part, "This training session covers training required per ' Action to Prevent
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Recurrence' for any NCR's written on work completed prior to May 23, 1985." During the review of NCRs, Memorandum 1866 was referenced on numerous NCRs, however, no misuse of the memorandum was observed.
With respect to " Action to Prevent Recurrence," during the review of NCRs, the inspector observed 12 instances where NCRs were improperly closed before action to prevent recurrence had
been completed.
(Reference: NCRs 1772, 1758, 1754, 1798, 1787,
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1783, 1825, 1822, 1818, 1816, 1815, and 1802) Based on the NRC inspector's concern, HECo QA performed a review of NCRs and identified 38 NCRs that were improperly closed before action to prevent recurrence had been completed.
In addition, CECO QA Audit 6-86-201 identified that the instruction / retraining required as part of the action to prevent recurrence had not taken place until, in some cases, nine months after the NCR was prepared.
This resulted in additional NCRs being prepared on the same type problems involving the same personnel.
Conclusions: A review of NCR 1581 indicated that the disposition
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was adequate based on S&L analysis and the issuance of FCR F-6665.
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For the NCRs reviewed, with one exception, the NRC inspector found the "use-as-is" disposition acceptable.
For NCR 1990, it was identified that there was inadequate justification for the
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_ "use-as-is" disposition until additional tests were performed.
During the review of Action to Prevent Recurrence, the NRC inspector identified 12 NCRs that were closed before action to prevent recurrence was completed. The licensee also identified that in many cases the action to prevent recurrence was not effective due to the time interval between the preparation of the NCR and the implementation of the required retraining.
The licensee was informed that failure to assure that corrective action to prevent recurrence was completed prior to closing the NCR was an example of a failure to implement Criterion XVI of 10 CFR 50, Appendix B (455/86017-078).
(29) Concern: The trend analysis as performed by HECo QA does not prove anything.
NRC Review: During a review of NCRs discussed in. Paragraph 5.a(28) above, the NRC inspector performed a " bean count" of the NCRs prepared during the fourth quarter 1985 for comparison to the trend analysis performed by HECo QA. The NRC inspector determined that 104 NCRs were prepared and 12 of these NCRs were written on concrete expansion anchor (CEA) installation problems.
A review of the HECo trend analysis indicated that none of the 12 NCRs on CEAs were trended and only 6 of 104 total NCRs prepared during the fourth quarter were trended.
A review of DRs for the fourth quarter 1985 revealed that '!36 DRs had been prepared. When compared to the HECo trend analysis, only 37 of the 236 total DRs prepared during the fourth quarter were trended.
During interviews of the HECo QA personnel responsible for the trend analysis, the NRC inspector was informed that if the physical work activity was not performed during the subject quarter, the NCR/DR was not counted for trending purposes in that quarter.
The NRC inspector was also informed that HECo does not perform a running (complete) trend analysis; i.e., include two or more i
l quarters in the trend analysis performed each quarter.
During
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interviews with the HECo QA/QC Manager, the NRC inspector was l
informed that during the fourth quarter of 1985, HECo QC had a
60-90 day backlog of inspections and presently (June 1986), the backlog was down to 30 days and for practical purposes this is considered current with work activities. When the QA personnel were asked if the previous quarter trend analysis was revised to reflect the additional NCRs/DRs identified, their reply was no.
In summary, when HECo QA performed the fourth quarter trend analysis, 94% of the NCRs and 84% of the DRs were discarded from the trending population. Under ideal conditions (30 day backlog),
approximately 33% of the pertinent data would not be included in the trend analysis.
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Conclusions: This concern was substantiated in that prior to performing the trend analysis, HECo QA discarded up to 95% of the pertinent data needed to perform the analysis.
(30) Concern: We had problems with the welds on DV88 and DV89 type connections. There are 456 in Unit I and 542 in Unit 2.
CECO QA Audit 6-84-309 caused the reinspection of 58 DV88 and DV89 connectors that had been reworked by HECo. Why wasn't a larger sample taken? Also, Page 2 of 2 of HECo's response to Audit 6-84-309 is missing from Ceco's file copy of this audit. A copy of HEco QA/QC Memorandum 1405 was provided.
NRC Review:
HECo QC inspectors identified undersized welds on electrical raceway hangers as supplied by Systems Control.
These undersized welds were documented on HECo NCR 461. The NCR disposition directed HEco to add additional welds to 58 DV88 and DV89 connectors with undersized welds. During CECO QA Audit 6-84-309, a cracked weld was identified on one of the hangers repaired by HECo. HECo was directed to visually reinspect the 58 hangers and identify any welds that had crack indications. The reinspection identified ten potentially cracked welds, six were accepted by PTL using the magnetic particle (MT) method of nondestructive examination (NDE). The remaining four welds were repaired by HECo per NCRs 1062, 1065, 1066, and 1067 and subsequently accepted by PTL, using the MT method. CECO NCR F885 was prepared to document potential undersized welds on DV88 and DV89 type connectors supplied by Systems Control.
Based on statistical guidelines, an additional 60 hangers were inspected and weld maps prepared. Based on worst case analysis, S&L was able to accept these hangers with undersized welds. The weld deficiencies identified by CECO on items supplied by Systems Control were closely monitored by the NRC (see NRC Inspection Reports 454/84031, 455/84024, 454/84032, 455/84025, 454/84050, 455/84034, 454/84071, and 455/84049).
The NRC inspector's review of QA Audit 6-84-309 revealed that the corrective actions and corrective action to prevent recurrence were agreed to during the audit and were documented in the audit report.
Therefore, no HEco response to the audit was required. Memorandum 1405, dated July 18, 1984, is from a HECo Level II welding inspector to the HEco QA/QC Manager. This memorandum documents, in summary form, the results of HECo's and PTL's reinspection of the DV-88 and DV-89 hanger connections.
The inspector could not find any evidence that the HECo QA/QC Manager had ever transmitted this memcrandum to CECO. Hcwever,
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Memorandum 1405 was found in the HECo vaulted records file.
In that the applicable QA/QC Manager was no longer employed by HECo, he was not interviewed in reference to this memo.
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._ _ Conclusions: This concern could not be substantiated in that-additional hangers were reinspected per CECO'NCR F885~and an analysis was performed by S&L. -In addition, the welding problems. identified on items supplied by Systems Control were closely monitored by NRC inspectors. No HECo response to Ceco QA Audit 6-84-309 was required and the inspector could find no' evidence that HEco QA/QC Memorandum 1405 was ever transmitted to CECO. Therefore, there was no requirement for HEco QA/QC Memorandum 1405 to be placed in the CECO audit file.
No violations or deviations were identified.
(31) Concern:
In Unit 1 on the west face of Q wall, 426'
elevation, Area 5, a DR was prepared for a cover being left off of a J-Box. Was the cover replaced and the DR closed?
NRC Review: Using the applicable Unit 1 drawing, it was determined that the concern could apply to.any one of three J-Boxes that are installed in the area described..Using the WANG system, it was identified that DR3282 had been written against J-Box IJB1737A. A review of DR3282 indicated that it had been prepared on October 5, 1983, for a missing J-Box cover.~ The cover was replaced and DR 3282 was closed on October 18, 1983.
Conclusions: DR 3282 documented the missing cover on J-Box 1JB1737A. The J-Box cover was replaced and the DR closed. No violations or deviations were identified.
.(32) Concern:
Rebars were cut in a non-safety-related man-hole-(MH)
during the cutting of a cored hole.
The FCR stated that no rebar.was to be cut. HECo could not write an NCR on these cut rebars.
For non-safety-related walls, HECo has no way to report cut. rebar. This happened in approximately January 1986.
NRC Review: The NRC inspector reviewed all Cored Hole Reports
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prepared between January 1 and March 31, 1986. No reports were identified for a non-safety-related MH. The inspector reviewed
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Cored Hole Reports prepared between October 1 and December 31,
1985. This review found that Report 85-10-26, dated October 24,
1985, documented rebar cuts in MH 2B. This report also referenced HECo NCR 1738. A review of the NCR revealed that two vertical
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rebars vere cut on the south face of MH 2B and FCR 26571 only
t permitted one rebcr to be cut.
The information contained in (
the NCR was analyzed by S&L and the NCR was dispositioned
"use-as-is."
During interviews with CECO and S&L personnel, the
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NRC inspector was informed that ali Cored Hole Reports are
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routed to S&L. "Rebar cuts" or "no rebar cuts" are documented L
on the cored hole reports, so that even though a rebar is cut in a non-safety-related wall / floor and e.n NCR is not prepared
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(which is typical) S&L would be aware of any/no rebar cuts.
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installations, therefore, NCRs are not normally prepared on non-safety-related items. During the review of Cored Hole Reports, non-safety-related MH 28 Report 85-10-26 was the only report identified that fits the description of the concern.
Conclusions: This concern was refuted in that NCR 1738 had been prepared to document cut rebars, in MH 28, even though an NCR was not required. No violations or deviations were identified.
(33) Concern:
PTL rejected concrete expansion anchor (CEA)
installations for Category II (non-safety-related) equipment inside Containment 2 for spacing and edge distance. NCR 2017 was preparea to document the rejected CEAs however, it was cancelled.
NRC Review: A review of HECo NCR 2017, dated May 9, 1986, indicated that this NCR had been cancelled. The description of the nonconforming condition indicated a CEA edge distance violation only. A review of PTL CEA Inspection Report 24673,
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on the same installation, found that the violation was for edge distance only and S&L had dispositioned the PTL report "use-as-is" on March 28, 1986 (Approximately 42 days before NCR 2017 had been prepared).
In that the edge distance violations had been previously addressed by S&L, the NRC inspector concurs with the
cancelling of NCR 2017.
Conclusions: The CEA edge distance violation identified on PTL Report 24673 had been satisfactorily addressed by S&L, therefore, a HECo NCR was not required. No violations or deviations were identified.
(34) Concern: The ceiling is leaking in the feedwater tunnel, causing pitting of the conduits. Conduit segregation code is K2R (safety-related instrumentation conduit).
See conduit inspection reports (Form 201) 5780 and 5978.
In accordance with the HECo Project Engineer, this deficiency is not within HECo's scope of work.
NRC Review: The NRC inspector performed a physical inspection of the feedwater tunnel.
During this insoection it was observed that at some point in time, the ceiling had, in fact, been leaking. However, the licensee had taken appropriate action to seal the leaking ceiling. An inspection of the conduit in the
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area of the leaks snowed a deposit that appeared to be calcite.
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Upon removal of the deposit, no pitting of ti e conduit was observed.
In that the ceiling had been repaired (sealed), it was apparent that CECO was aware of the leak, therefore, no HECo NCR/DR was required.
Conclusions: A physical inspection of the feedwater tunnel indicated that the ceiling leak had been repaired and the leakage caused no detrimertal effects on the conduit. No violations or deviations were identified.
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(35) Concern: White out was used on NCR 1759. also changes were made on NCRs 1759, 1766, 1775, 1802, and 1825 that were initialed but not dated.
NRC Review: HEco NCRs are typed by the clerks and during the preparation of NCR 1759, it appears that the letter "S" on one word was retyped. A correction fluid had not been used. When reviewing a copy of this NCR, it appears that a correction fluid (white out) may have been used, which, in the NRC inspector's opinion, resulted in this concern. With respect to the changes on NCRs 1759, 1766, 1776, 1802, and 1825, they were made by an individual with the intitials "R.A.B." and was not dated.
These NCRs were corrected during this inspection and from the number of NCRs reviewed during this inspection, it appeared that these were isolated instances.
Conclusions: Correction fluid had not been used on NCR 1759, however, it appears that the clerk typed over/ retyped the letter "S" in one word. Changes had been made, initialed but not dated on NCRs 1759, 1766, 1775, 1802 and 1825. These NCRs were corrected during the inspection. Based on the number of NCRs reviewed during this inspection, these errors are considered isolated instances and no further action is required.
(36) Concern: Wrong FCR numbers are referenced on core hole inspection reports 26884, 26887, 26890 and 26891.
NRC Review: During the review of core hole reports, the NCR inspector could not identify any reports with the numbers provided by the alleger. The NRC inspector was informed that the series of numbers provided appeared to be FCR numbers.
Using the FCR log, it was confirmed that the numbers provided were, in fact, FCRs issued for cored holes.
The log also provided a cross-index to the Core Hole Inspection Report (CHIR) number.
During a review of the FCRs and the inspection reports, the following observations were made:
CHIR 86-04-02 referenced FCR F26984 and on June 15, 1986, this FCR number was corrected to read F26884.
- CHIR 86-04-03 referenced FCR F26897 and on June 15, 1986, this FCR number was corrected to read F26887.
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FCR F26884 was superseded by FCR F26890 (after the hold was cored) which abandoned the hole because it was not needed.
FCR F26884 was identified as being superseded.
- FCR F26891 deleted one 3" hole and added two 3" holes.
This FCR was correctly listed on CDRs 2052 and 2054.
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' Conclusions: CHIRs 86-04-02 and 86-04-03 referenced an incorrect FCR number, however, they had been corrected prior to the NRC inspector's review.
FCRs F26890 and F26891 were listed correctly on the applicable reports. No violations or deviations were identified.
(37) Concern:
Cable installation Report 9877 incorporated an FCR before it was issued.
NRC Review: A review of cable installation report 9877, revealed that the cables were released for pull on February 17, 1986, and that FCR F26763 was referenced on the report. This FCR was issued on February 14, 1986, to change the cable from type 01599 to type 01646. This cable type change affected cables 2AR189, 191, 193, 195, 252, 253, 258, 259, 266, and 267. A comparison of the cables listed on the FCR and on Report 9877 indicated that there were one or more additional cable installation reports affected by the FCR. Additional research revealed that Report 9878 was the other report within the scope of the FCR.
A review of cable installation report 9878 indicated that the cables were also released for pull on February 17, 1986.
Conclusions:
FCR F26763 was issued three days before the affected cables were released for pull as indicated on cable installation reports 9877 and 9878. This concern was therefore not substantiated.
No violations or deviations were identified.
(38) Concern: We only inspect for minimum torque valves (Note 5,
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Drawing 0-3000L, Sheet 1, Revision L). During operations the vibration could pop the boltheads off if they were overtorqued.
NRC Review:
Bolt torque valves are specified in order to preload the bolts for high cycle fatigue, shear connection or locking considerations. Of these three reasons, only high cycle fatigue has critical requirements for minimum and maximum bolt preload values. The other two considerations, which are basically static load cases, really only have a minimum preload requirement.
For most static bolting applications, if the bolt does not break during the initial torque-down, then it should not break during service. This is because during installation the bolt must withstand the induced tensile force as well as the applied torque. The tensile and shear stresses resulting from these two forces are approximately the same under normal conditions.
Since the ultimate shear stresses are about half of the ultimate stresses, the biaxial state of stress will be overall one of the most highly stressed conditions for the bolt. Once the bolt is installed, the residual torsional stresses disappear due to slight frictional slippages after the torque is removed. Once this torsional stress component is
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removed, the available tensile capacity above the preload value increases significantly. As long as the applied load is less than the bolt preload, the increased tensile stress should be less than the bolt capacity and therefore, never fail.
(Reference: Mechanical Engineering Design, Shigley, J. E. c 1977, Third Edition.)
Conclusions: Although dynamic loads are considered for this bolting application, there are no high cyclic fatigue
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concerns. On this basic, maximum torque valves need not be considered during installation.
The concern in therefore unsubstantiated.
(39) Concern: There are no weld traveler cards for Units 1 and 2 riser collars.
c NRC Review: A riser collar is a type of raceway support used to support vertically mounted cable tray (risers) and is shaped like a collar. Riser collars are installed at floor penetrations.
Weld travelers (WT) had been prepared for riser collar welds, however, due to the lack of unique identification, WTs could not be traced to a given weld or series of weld on a given riser collar.
On January 26, 1986, HECo QC prepared DR 8314 to document that WTs for 17 safety-related and non-safety-related Unit 2 welded riser collars could not be found.
New WTs were prepared, the welds were inspected, and the DR was closed on March 17, 1986.
On February 28, 1986, DR 8444 was prepared to document additional i
missing WTs for Unit 2 riser collars having welded connections.
As a result of this DR, 136 WTs were prepared and the welds were inspected. As a result 96 were rejected for various deficiencies.
These deficiencies were transferred to NCR 2073, dated September 9, 1986, and DR 8444 was closed on September 15, 1986, based on the preparation of the NCR. With respect to Unit 2, HECo identified the problem of missing WTs and corrective action was in process before the allegers concern was received.
With respect to the missing Unit I riser collar WTs, it appears that the licensee was aware of the problem in the same time frame that HECo DR 8314 was prepared, on January 29, 1986. On February 14, 1986, CECO QA performed Surveillance No. 7898 on missing WTs for Unit 2 riser collar welds which resulted in l
HECo DR 8444 being issed on February 28, 1986.
From interviews
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of CECO QA and engineering personnel and review of records, the NRC inspector could not identify any actions taken by HECo or the licensee to identify and document (NCR, DR, etc.) the missing WTs for Unit I riser collar welds. On June 9, 1986, while investigating this concern on the missing WTs, the NRC inspector expressed a concern regarding the lack of licensee action to document the missing WTs on Unit I riser collar welds.
On June 20, 1986, Project Instruction (PI)-BB-106 was issued for
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the inspection of Unit I riser collar welds.
Gom June 23 to
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June 25,' 1986, a S&L Level III weld inspector inspect.ed 50 of
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the! approximate'ly 150 Unit 1 and common riser collar welds. Per
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an S&L (R. J. Netzel) to CECO (R. E. Querio) letter dated
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July 29, 1986, an engineering evaluation was performe.1 o, Unit i s
riser collar walds based on results from the S&L inspecb!cn.
S&L's evaluation of the discrepancies based onja worse mase
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i analysis, determined that the riser collar welds are within
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the allowable stress limits., However, one case was identified
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s where the as-found yeld condition was less than the detign
V drawing requirements.4 This riser collar is located on~ elevation 439, l'5" south of column line 10 and 10'9" west of column line
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L, as shown on drawing.6E-1-3061. These riser collar welds were repaired and accepted by HECo on September 16, 1986, as documented
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on Nuclear Work Request (NWR) 6EG018.
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Conclusions: This concern was substantiated. However, for-Unit 2, HECo had identified the problem of missing WTs for
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riser collar welds on DR 8314 and DR 8444 and corrective action was in-process before this coacern was identified to the NRC.
With respect to missiag WTs for Unit I riser collar welds, it i
.appears that the licensee became sware of the missing Unit 1 WTs in the January to February 1986. However, th? licensee
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failed to take any corrective actioris until the NRC inspector expressed his concern on June 9, 1986.
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The licensee was inforced that:
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r (a) Failure to assure'~that conditions adverse to quality were
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promptly identified and corrected is an exanple of a failure :to implement Criterion XVI of 10 CFR 50, Appendix B (454/86031-04B).
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(40) Concern:.The disposition on DR 8350 is not correct. An HP-7A (Rewat Requast) should have been inithted.
v NRC Review: A review of DR 8350 identifled the discrepancy as
" cable 2FW216 was determinated to terminate cable 2FW230 on the same terminals without an HP7A form being prepared. This is in s
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violation to Procedures 7 and 7A."
The disposition on the OR stated, in effect, "that procedures were not violated and the DR was written in error." The DR referenced various paragraphs s.
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from HEco Procedures 7, " Electrical Design Changes" and 7A, y
" Rework Control."' The NRC inspector reviewed HECo Procedures 7 and 7A.
Procedure 7' describes the actions to be taken by HECo 1'
when a desiqn change is received.
In that the discrepancy noted
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j was not a design change, crocedure 7 was listed in error on the l
DR.
Procedure 7A, Paragraph 2 d, states, in part, "The scope of this procedure includes the revisions to installed work
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required by design change or removal and reinstallatica of-previously installed work...." Paragraph 2.4 of j
Procedure 7A states, in part, "The scope does not include i
the remaval of wire or cable conductor terminations in order
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to terminate additional wires or cable conductors on the same point...." During the review of Cable Termination Inspection Report 21586 fcr cable 2FW230, it was noted.that the termination inspection was performed "in process", indicating that a QC inspector had observed the determination an'd re-termination of cable 2FW216. Based on the NRC inspector's review of Procedures 7 and 7A, DR 8350, and inspection report 22586, the NRC inspector concurs with the HECo engineer that the DR did not describe any violation of procedures.
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Conclusions: DR 8350, as writtenp did not describe a procedure violation.
In addition, a certified HECo QC inspector did in fact perform an in process _ inspection of cable terminations..No violations or deviations were fdentified.
(41) Concern: There are bad resolutions on DRs 8339 and 8426.
In addition, "use-as-is" DRs should have been documented on NCRs.
NRC Review: The NRC inspector reviewed approximately 300 prs, including DRs 8339 and 8426, for proper closure.
Following are the results of this review:
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DR 8339 - Documented screws and terminal points have corrosion on them and 3" sealtite outer jacket is pulled out of the connector in panel 2VA-04J. A CECO PCD engineer dispositioned this DR "use-as-is" with an explanation, however, "use-as-is" dispositions require design engineer's approval; i.e., S&L or Westinahouse.
During a physical inspection of Panel 2VA-04J, the NRC inspector determined that the observed corrosion was not detrimental to the operation of the equipment. No discrepancies were observed with the sealtite jacket.
- DR 8426 - Documented 2 1/2 pages of discrepancies or potential discrepancies that were identified during a 100%
inspection of Panel 2PS47J prior to turnover to the licensee. All discrepancies identified on this DR were
" accepted-as-is" by a Ceco PCD engineer. A typical disposition was "ok" or "all ok."
Several of the potential discrepancies were " terminal lugs landed backwards - Can't check." To verify the acceptance of these lugs, the lugs
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would have to be determinated for inspection. When questioned by the NRC inspector, the PCD engineer stated that the lugs were not determinated for inspection but were accepted ("use-as-is") based on his knowledge of like terminations.
From the interview, the inspector determined that no physical corrective actions were taken before the discrepancies were' accepted; 1.e., dispostioned
"use-as-is".
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DR 8501 - Documented that Class I (safety-related) cables 2RC437, 2RC422, 2RC419, and 2RC440 were pulled without QC
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being present. NCR 1992, dated April 17, 1986, was prepared to document this procedure violation. This NCR was dispositioned "use-as-is" by a CECO PCD engineer without design engineer's approval. DR 8501 was closed based on " Resolution Implementation Documented on: (HECo QA) Special Surveillance #13-86 and NCR 1992." During a.
review of HECo QA vaulted Surveillance Reports, the NRC irspector could not locate Special Surveillance #13-86.
During personnel interviews, the NRC inspector was informed by a HECo QA engineer that Special Surveillance #13-86 had not been issued.
- DR 8504 - Documented that cable installation inspection report 8790 was issued for the removal and reinsta11ation of safety-related cable 2MS518.
Report 8790 only documented the removal of the cable.
There is no documentation for the reinstalls. tion of the cable. This DR was dispositioned
"use-as-is" by.the HECo QA Supervisor and final reviewed and accepted by the same Supervisor on May 20, 1986. This disposition was not approved by the design engineer.
- DR 8534 - Documents miscellaneous discrepancies, (including lack of cable tension data during the pull), with two cable cable installatior, inspection reports (9991 and 9992). The inspector who originally witnessed the cable pull was no longer employed in HECo QC. The inspection reports could not be closed because no one knowns the circumstances of each cable installation. This DR was dispositioned
"use-as-is" by HEco engineering.
The "use-as-is" disposition i
was not approved by the design engineer.
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DR 8049 - Documented that conouit fittings are loose at 2PSL-DG0878 and 2PS-DG094B. These conduits were acceptable as installed, based on a memorandum from a CECO PCD engineer.
This memorandum stated, "Above installations are acceptable as installed. HECo should close their DR. Conduit cannot become looser. Byron Station can tighten connector during a future calibration." This disposition was not approved by a design engineer.
CECO QA Audit 6-86-201, that was conducted as a result of NRC concerns, also reviewed the HECo DR program.
This audit states, in part, "A review of 356 DR's which were closed during the aforementioned period verified that HECo Engineering / Production had properly dispositioned the identified concerns in 205
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instances. An additional 50 DR's were elevated to NCR's for resolution by the Owner. However, 101 DR's were either dispo-sitioned by PCD as acceptable per an attached speed memo or were d,ispositioned as acceptable per PCD without a clear basis for the inspection Llements acceptability.
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During the course of the audit, minor concerns were identified which related to the processing and/or closecut of DR's.
However, the instances were unrelated and were submitted to HECo QA for resolution.
In general, the HECo DR program was found to be acceptably implemented with the exception of its trending process."
Conclusions: The NRC inspector's review of HECo's DR program revealed that DRs were being dispositioned "use-as-is" by HECo QA, HECo Engineering, and CECO PCD Engineers without the con-currence of the design engineer and/or without a clearly documented basis for the closure of the DR.
The licensee was informed that:
(a) Failure to assure that design changes were subject to design control measures commensurate with those applied to the original design is an example of a failure to implement Criterion III of 10 CFR 50, Appendix B (455/86017-028).
(b) Failure to assure that conditions adverse to quality are identified and corrected and the cause of the condition is determined and corrective action taken to preclude repetition is an example of a failure to implement Criterion XVI of 10 CFR 50, Appendix B (455/86017-07C).
(42) Concern: Cables were pulled with a " mares tail" (non-metallic basket weave cable pulling device) in the steam tunnel at twice the maximum allowable cable pulling tension. This happened 9-12 months ago and no NCR was prepared.
NRC Review: A review of cable pull records and interviews of HECo QC and engineering personnel revealed that the concern related to a bulk cable pull involving 16 cables. These cables were being pulled from J-Box 2JB101A through conduits C2A-4115, C2A-0141, C2A-0104, C2A-0501 and C2A-0595 to J-Box 2JB031A. These 16 cables were being pulled with a " mares tail" and a pulling tension of 1600 pounds was recorded.
S&L Standard EA-121 limits the maxinum pulling tension to 1000 pounds when using a basket weave cable pulling device. This violation was documented on DR 7884 which was subsequently up graded to HECo NCR 1682 on September 5, 1985. To transmit this information to S&L for analysis, CECO prepared NCR F-1011, dated September 13, 1985.
In an S&L letter dated September 18, 1985, S&L transmitted Ceco NCR F-1011 to the Okonite Company (cable manufacture) for their review and analysis. On October 7, 1985, S&L transmitted additional information to Okonite per their request. The Okonite Company responded in a letter to S&L on October 9, stating that, " based on their evaluation of the information provided, the cables in question are acceptable for
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use in their intended application."
In an S&L to CECO letter on November 5, 1985, S&L provided their concurrence with an " accept as-is" disposition on CECO NCR F-1011.
Personnel involved were re-trained in the 1000 pound pulling tension limitation when using a basket weave cable pulling device.
CECO NCR F-1011 was closed on November 26, 1985 and HECo NCR 1682 was closed on December 3, 1985.
Conclusions: This concern was not substantiated in that both HECo and CECO prepared NCRs on the over tensioning of cables being pulled with a " mares tail". These NCRs were properly analyzed, dispositioned, and closed. No violations or deviations were identified.
(43) Concern: The cable pull training requirements for QC inspector (by name) were lowered so he could be certified. He never observed a Class IE (safety-related) cable pull before he was certified.
NRC Review: ANSI N45.2.6-1978, " Qualification of Inspection, Examination, and Testing Personnel for Nuclear Power Plants,"
Subsection 2.2 states, "The capabilities of a candidate for certification shall be initially determined by a suitable evaluation of the candidate's education, experience, training, test results, or capability demonstration."
In accordance with Table 1 of N45.2.6, the discipline Level III inspector is responsible for evaluating each candidate for certification and determining the minimum training, if any, required prior to certification. This training may consist of formal training (classroom) or on-the-job training (0JT) or a combination of both. HECo Procedure 17, " Qualification and Training of Inspection and Audit Personnel," basically reiterated N45.2.6 for evaluation and training of QC inspectors. The NRC inspector reviewed the training and certification records package for the named individual.
For cable pull and terminations, the Level III evaluation indicated that the individual required nine hours of formal training and 40 hc9rs of OJT. A review of the documented training (cable pull and tenninations) indicated that the named individual had received 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of formal training and 45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> of OJT.
In that HECo utilized the same procedures for safety-related and non-safety-related work activities (for QC inspections are not performed on non-safety-related work), therefore it is acceptable to train and test QC personnel on non-safety-related work activities.
In the case of the named individual, his 0JT was on four safety-related and two non-safety-related cable pulls.
Due to the lack of safety-related cable pulls, the named individual's practical test was given on a non-safety-related cable pull. The NRC inspector reviewed the written test (closed book) taken by the named individual for Level II certification.
A minimum of 80% is required on the written tests and the named individual had a passing grade of 84.5%.
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Conclusions:
In that the named QC inspector had been evaluated by HECo's Level III inspector, and minimum training requirements established, the individual met the qualification and certifica-tion requirements of ANSI N45.2.6 and HEco's Procedure 17, this concern was not substantiated. No violations or deviations were identified.
(44) Concern:
In electrical panels 2PA09 and 2PA10, there is bare vendor wire showing and this has been accepted.
NRC Review: The NRC inspector and a CECO QA electrical engineer performed independent inspections of panels 2PA09 and 2PA10 located in the Auxiliary Electrical Equipment Room. No discre-pancies were identified with vendor or HECo installations.
Conclusions: Based on a physical inspection of panels 2PA09 and 2PA10, this concern was not substantiated. No violations or deviations were identified.
(45) Concern:
The CECO PCD Project Electrical Supervisor directed HECo on how to perform QC inspections. This occurred during a training session prior to the butt splice reinspection. QC was directed to accept exposed copeer beyond the lug insulation.
NRC Review: As a result of a 1984 NRC concern (see IE Inspection Reports 454/84027; 455/84019), the licensee performed a reinspection of accessible butt splices in Units 1 ar.d 2.
This reinspection program, including the training session
alluded to by the alleger, was closely monitored by two NRC inspectors (See NRC Inspection Reports 455/84029; 455/84021).
The subject training session was conducted by the Project Electrical Supervisor on May 24, 1984 and was attended by NRC inspectors.
For butt splices that were to be covered with
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Raychem heat-shrink tubing or tape, it was permissible to have
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exposed copper beyond the lug insulation in that the exposed copper would be covered in the final product. This action was acceptable to the NRC.
In addition, the licensee had notified the NRC of this problem via a 10 CFR 50.55(e) report (455/84003-EE; 455/84003-EE). This 50.55(e) report was addressed in IE Inspection Reports 454/84055; 455/84038. An open item pertaining to the butt splice reinspection program is also addressed in IE Inspection Report 454/84072; 455/84050.
Conclusions: This concern was substantiated, however, the exposed copper that extended beyond the lug insulation was being appropriately covered with heat-shrink tubing or tape.
The entire butt splice reinspection program was monitored and accepted by NRC inspectors. No violations or deviations were identified.
(46) Concern: The HEco QA/QC Manager (by name) pre-dated and back-dated inspection reports, also, QC inspector (by name)
back-dated equipment modification reports (Form 12A).
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NRC Review: -The NRC inspector reviewed several hundred
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inspection report and did not observe the named QA/QC Manager's
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name on any reports. -A review of personnel qualification files revealed that this individual was not certified in any area by HECo. During interviews'of HECo QA/QC personnel, the NRC inspector was informed that. they (the interviewees) were not aware of.the named QA/QC Manager pre-dating or back-dating any documents and were not aware of him approving / signing any inspection reports. The inspector was unable to interview this individual in that his employment with HECo was terminated July 2, 1986.
With respect to the named QC inspector, it was established through personnel interviews and review of records that this QC inspector back-dated his " review" of Class 1 Equipment Modification Inspection Requests (Form HP-12A-1).
In accordance with HECo procedures and inspection report forms, the QC inspector that performed the inspection, signs, dates and enters his/her certification level (Level I,'II or III) at the bottom of the report. This report is then " reviewed" by an additional QC inspector certified Level II or III. When inspection reports reach the QC office from the field, they are given to the QC
clerks. The QC clerks then formally transmit these reports to
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the appropriate Lead QC inspector for their review. After the reports have been reviewed, they are returned to the clerks for filing. At the time of filing, the clerk enters the inspection
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date and the date filed in a permanent log.
Modification inspection reports 6132 through 6137 were received
by the QC clerk from the field on August 10 or 11, 1984, and
transmitted to the Lead Inspector on August 13, 1984. When these reports were received for filing, all had a " review" date
of March 21, 1984. All the QC inspectors and the lead inspector
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involved with these inspection reports have not been employed by I~
HEco for some time.
In that the involved personnel are no longer employed by HECo and the " review" function did not change
or modify the inspection results, no additional followup is planned.
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j Conclusions: The named QA/QC Manager had not signed any
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inspection reports and none of the QA/QC personnel interviewed
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were aware of any documents that he pre-dated or back-dated.
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Records indicated that the named QC inspector back-dated his review of modification reports 6132 through 6137. The review function did not change or modify the inspection results and l
does not have any impact on quality of the item inspected.
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(47) Concern: Certification and records packages were missing from
the vault. Craft personnel need to be recertified every six
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months on cable terminations.
Some of the craft were i
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NRC Review: A review of HECo Procedure 11, " Class 1 Cable Termination and Splicing," revealed that Paragraph 5.9.2
" requires an in process QC inspection of each terminator's work at least once every six months for the terminator to maintain his/her qualifications." A log is maintained for each terminator and lists the QC inspector's name that performed the in process inspection, termination report number and date.
The NRC inspector selected five terminators for a review of their maintenance of qualifications.
During this review, the
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following observations were made:
Terminator 4069 (individual's Brass Number) - Two reports were listed as in process inspections when in fact they were not.
If an inspection was performed in process, it is so noted on the inspection report. During a review of termination inspection report 14610, it was noted that the termination was made on December 3, 1984, and the inspection was conducted on December 19, 1984. Also, termination inspection report 22757, dated March 7, 1986, was not identified as being an in process inspection. These errors did not affect the terminator's qualifications in that valid in process inspections were on file for the applicable six month periods.
- Terminator 4193 - Termination inspection report 2165 was also listed in error in the log for this terminator in that the termination was made on December 10, 1985 and inspected December 11, 1985; not in process inspected.
Valid in process inspections for November 1985 and January 1986 were also on file and this error did not affect the termi-nator's qualifications.
- Terminator 3320 - Termination Report 15278 was listed in the log for this terminator, however, the report was missing from the HEC 0 Records Vault. A review of the Termintaion Report Log reve led that reports 15270 through 15275 and 15277 through 15285 had been " thrown away by DG 5/16/86."
During interviews of HECo QA/QC personnel, the NRC inspector was informed that for terminators to maintain their qualifications, they were permitted to make " test booth" terminations with a QC inspector present.
These " test booth" termination inspections were documented on termination reports 15270 through 15275 and 15277 through 15285. Under current HECo procedures, all documents are reviewed by HEco QA prior to being vaulted. When these reports were transmitted to QA for their review, a QA engineer showed the reports to a QA/QC clerk and informed her that the QA Supervisor said that these reports were not needed and threw them in the clerk's trash can. After the QA engineer left the area, the clerk retrieved the reports from the trash can and stored them in her desk. The clerk could not " vault" these records because they had not been reviewed by HECo QA. To
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account for the termination report numbers, the clerk noted in the Termination Report Log that these reports had been " thrown away by DG."
After the NRC inspector expressed his concern with the discarded reports they were retrieved by the clerk and were again transmitted to HECo QA for review. After QA completed their review, termination inspection reports 15270 through 15275 and 15277 through 15285 were returned to the QA/QC clerks and properly filed in the HEco Records Vault.
During interviews of QA/QC personnel, the NRC inspector was informed that during the 1982-1983 time frame, a named QA Supervisor removed certain QC inspector's (by name) certification records from the inspector's vaulted files. These missing certifications were discovered after this QA Supervisor terminated his employment with HECo on November 14, 1983. The named individual's records were subsequently corrected by using the master list of personnel certifications and copies of records retained by the individual QC inspectors. On August 5, 1986, the NRC inspector reviewed approximately ten inspector's files and compared the certifications with the master list.
In addition, the NRC inspector queried the named inspectors still employed by HECo as to their area of certifications and compared their responses with the master list of their certifications.
No discrepancies were identified.
Conclusians: Through personnel interviews, the NRC inspector determined that certification records had been removed from personnel files by a QA Supervisor during the 1982-1983 time frame.
However, the inspectors' certification record files had been corrected prior to the NRC involvement in this concern.
The review of termination inspection records that support the recertification of craft terminators revealed that several inspection reports were missing from the HECo records vault.
The termination inspection report log indicated that reports 15270 through 15275 and 15277 through 15285 had been " thrown away" by the HECo QA Supervisor on May 16, 1986. This was verified by a QA/QC clerk and a QA engineer. However, the clerk had removed the termination reports from the trash can and stored them in her desk. After the NRC expressed concerns in this matter, the termination reports were retrieved from the clerks desk, reviewed by HECo QA and subsequently filed in the HECo records vault.
The licensee was informed that failure to assure that sufficient records are maintained to furnish evidence of qualification of personnel (craft terminators) is an example of a failure to implement Criterion XVII of 10 CFR 50, Appendix B (454/86031-08; 455/86017-08).
(48) Concern: When HECo craft personnel perform work activities under the direction of CECO OAD, this work was not always inspected by HECo QC.
NRC Review: A review of Unit 1 Cable Termination Inspection Reports (Paragraph 5.a. (47) above) revealed that several inspection reports associated with NWR 6EG006 were marked N/A (not applicable) for all inspection attributes. A note on these reports stated, " Work performed under 0AD direction. No inspection required per XXXXX (named CECO PCD electrical engineer). The following are examples identified during this review:
Report 21105, dated November 25, 1985, Class 1E equipment 1FWO6JB. All inspection attributes were marked N/A with the above listed note.
Rework Request (Form HP-7A-1) 7963 was referenced on termination report 21105. The work description on this Rework Request stated, "F1d, to replace existing SIS wire W/Rockbestos SIS wire as required in 1FWO6JA, JB and JC per PCD."
SIS wire is a type of single conductor wire used in switchgear, motor control centers, panels, and valve operators. The NRC inspector was informed that the existing SIS wire was not qualified and it was being replaced with qualified Rockbestos SIS wire.
Reports 21106, 21113, 21114, 21119, 21120, 21115, 21116, 21102, 21103 and 21117 were all similar to termination inspection report 21105, except they applied to different items of equipment and rework request numbers. The work description on the rework request were similar to Rework Request 7963, except they applied to different items of equipment.
During interviews of QA/QC personnel, the NRC inspector was provided a copy of open HEco Cable Termination Inspection Report 19980, dated July 3, 1986. This report documented that the red conductor on cable 2RH033-P2E was butt spliced and the splice covered with heat-shrink tubing. This butt splice work activity was inspected in process by a CECO 0AD engineer and was documented on HECo termination report 19980. However, this OAD engineer was not certified to HECo's termination and splicing procedure. This discrepancy had been previously identified by HECo QC and is being corrected under HECo's open inspection report (0IR) program.
In that the butt splice is covered with heat-shrink tubing and cannot be inspected, the butt splice must be replaced with HECo QC performing an in process inspection of the work activity.
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Conclusions: During a review of cable termination inspection reports, the NRC inspector identified 11 reports where no inspections were conducted during the replacement of unqualified SIS type wire. This wire was replaced in various Unit 1 items of Class 1E (safety-related) equipment. The required QC inspections were not conducted per the directions of a CECO PCD electrical engineer.
00e instance was identified where an in process termination / splice inapection was performed by an un-certified CECO OAD engineer.
However, this discrepancy had been previously identified by I!ECo QC and corrective action was being implemented.
The licensee was informed that failure to assure that inspection activities are executed to verify conformance to documented instructions (NWR 6EG006) is an example of a failure to implement Criterion X of 10 CFR 50, Appendix B (454/86031-09).
(49) Concern: DR 8160 was prepared for a Procedure 7A violation.
The DR was rejected about two months ago. The same type of situation arose with an NWR and the HECo Project Engineer stated at that time that a Rework Request (Form 7A-1) was required.
Both these situations involved 8' flex conduit. NWR log in the conduit trailer (remote office) should indicate the 7A number.
NRC Review: DR 8160, dated January 7, 1986, identified the following, discrepancy " Conduit C2A4201 has 7' 8 1/2" of flex installed per FCR 26570.
This work was accomplished after the
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original 6' 0" flex was installed per CIR (conduit inspection
report) 8534. The above mentioned work was accomplished without initiating a 7A-1 (Form 7A-1, Rework Request) and in violation of Procedure 7A, Revision 1."
The resolution on this DR states, in part, "This item is not in the scope of 7A per section 2.3.
The CIR 8534 stated the sealtite was not connected to the equipment at the time it was turned in."
The NRC inspector verified that the flex conduit had not been inspected and accepted on Conduit Installation Report 8534, dated February 21, 1985. After instrument 2PT-0937 was installed (termination point for conduit C2A4201 flex), S&L authorized the
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installation of a 8' maximum flex conduit by issuing FCR 26579 on September 11, 1985. A 7' 81/2" flex was installed, terminated, inspected and accepted on September 17, 1985, as documented on Inspection Report 19604.
OR 8160 was properly closed on March 11, 1986.
In addition, Paragraph 2.3 of Procedure 7A, " Rework Control,"
states, "The scope does not include reinspection of reworked appurtenances. This shall be construed as installation work and shall be inspected in accordance with the appropriate installation procedure."
A review of the NWR log indicated that the alleger was alluding to NWR-6VC092, dated February 17, 1985, and Rework Request i
(Form 7A-1) 5412, dated March 18, 1985. A review of these documents indicated that PECN P-40 was issued on January 21,
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-W 1985 to install HVAC " Bubble Tight" dampers. This required a conduit modification. An NWR (6VC092) was issued in February to repair the flex conduit.
In that a Rework Request was required to complete the conduit modification per the PECN, the flex repair was included on Rework Request 5412.
Conclusions: DR 8160 and Rework Request 5412 described two different situations. DR 8160 discussed the replacement of flex conduit per an FCR prior to the inspection and acceptance of the originally installed flex conduit.
Rework Request 5412 discussed the modification of a previously accepted conduit system per an PECN and the repair of the attached flex conduit per an NWR.
In both instances, the work activity was properly performed, inspected and accepted.
No violations or deviations were identified.
(50) Concern: A Detail J connection was installed and accepted on WT (weld traveler) 79929. Conduit Inspection Checklist 4736 rejected the detail. The Detail J was cut down and reinstalled without a rework request. DR 8485 was prepared, however, this DR was rejected.
NRC Review: A review of HECo Procedure 6, " Reporting of Damaged or Nonconforming Material or Equipment" and Procedure 7A, " Rework Control" revealed the following:
Procedure 7A states, in part, "The scope (of this procedure) does not include any rework required as a result of initial quality control inspections. The scope includes the revisions to installed work required by design change or removal and reinstallation of previously installed work when directed by HECo engineering and/or the owner."
- Procedure 6 states, in part, " Items discovered to be deficient during routine surveillance or inspection activities shall not be considered a nonconformance.
These deficiencies shall be tracked thru the use of open inspection reports provided, the deficiency does not affect any work previously accepted. Deficient items which are not identified for correction and tracked thru the use of open inspection reports, will be brought to the attention of the appropriate supervisor for evaluation.
Supervisors shall write DRs (Discrepancy Reports) as appropriate. based upon their evaluation."
A review of WT 79929 revealed that the welding on hanger SCC-1 had been inspected and accepted. Also, Conduit Inspection Checklist 4736, dated October 21, 1985, rejected the Detail J connection on initial inspection because of incorrect location.
DR 8485, dated April 28, 1986, was prepared to document the removal and reinsta11ation of the Detail J without a Rework Request. The resolution on DR 8485 states, "that the discrepancy is not within the scope of Procedure 7A and can be
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l repaired / reworked under HECo's 0IR program". A stated in the various procedure paragraphs above, the discrepancy was not within the scope of Procedure 7A in that the-location violation
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was identified during initial conduit inspection. Also, the Detail J could not be reworked / repaired under the OIR program in that the welding had been accepted on a weld traveler.
In-accordance with-HEco procedures, the appropriate document to rework / repair the Detail J connections on. hanger SCC-1 would be a DR or an NCR (DRs can be upgraded to an NCR). During the rework of hanger SCC-1, a new WT (81221) was generated for the-new welds which were inspected and accepted, and attributes including configuration and location were reinspected and accepted on Conduit Inspection Checklist 4736.
In summary, it would appear that there was an in adequate understanding of procedure requirements prior to preparing the DR and the engineer provided a partially correct resolution. As documented throughout this report, the inspector reviewed numerous DRs and inspection reports and this was the only violation of this type identified.
Conclusions: A-hanger was reworked under the OIR program when a DR/NCR should have been prepared. DR 8485 was written without an adequate understanding of the nonconformance/ rework process. The resolution on DR 8485 was partially correct in that the rework was not in the scope of Procedure 7A. However, the resolution incorrectly implies that the hanger could be reworked under the OIR program.
This is considered an isolated programmatic deficiency with no hardware impact.
(51) Concern: Rework requests, at times, lack clarity of work to be performed and work performed.
Rework Request 07510'is a good example. Cables and flex conduit were determinated, what authorized their reinstallation? Also, why wasn't a 201 form (conduit inspection checklist) issued to inspect the re-terminated conduit?
NRC Review: The rework description on Rework Request 07510 states, "Determ cables and seal tites (flex conduit) a valve 10G-057A." This rework was completed on November 1, 1985. There were no work instructions on this rework request to indicate that the cables and flex conduit were to be re-terminated.
However, Rework Request 07510 documents the re-termination of cables 10G093, 10G092 and 10G123, and their associated flex conduits on November 5, 1985. The re-termination of the flex conduits is documented on Cable Termination Inspection Reports 20766, 20767, and 20768 (Attribute 14), therefore, a separate Form 201 would not be required for the flex conduit termination.
Rework Request 8854, dated February 18, 1986,- is another example of an inadequate work description.
In this case, the rework-was to determinate cable 2FW870 and pull the cable back to a defined point.
Rework Request 8854 also indicated that cable 2FW870 was re pulled, re-terminated, and re-inspected, which was outside the scope of the rework description. The NRC
inspector selected one file folder of rework requests from 1985 and one from 1986 for review. As a result of this review, Rework Requests 6957, 6967, 9006, 9017, 9018 and 9055 were also identified as having an inadequate work description which resulted in work being performed that was outside the scope of the work request. -All HECo rework requests are approved by CECO PCD engineers and in some cases, the request is initiated by a CECO PCD engineer. The NRC inspector's concerns with these rework requests were discussed with HEco and CECO PCD engineers.
Following the NRC inspector's meeting with these engineers, they have made a concentrated effort to ensure that the work description adequately defines the work activities that need to be performed. The NRC inspector reviewed the September 1986 rework requests and did not identify any additional violations, indicating that corrective action was adequate.
Conclusions: The NRC inspector confirmed that there were inadequate work descriptions on rework requests (eight examples were identified) which resulted in work being performed without adequate instructions. A review of cable termination inspection report associated with rework request 97510 revealed that attribute 14 documents the inspection of the reterminated flex conduits and a separate conduit inspection was not
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required.
The licensee was informed that failure to assure that activities affecting quality are prescribed by documented instructions and accomplished in accordance with these instructions is an example of a failure to implement of Criterion V of 10 CFR 50, Appendix B (455/86017-09A).
(52) Concern: Do not think CECO's audit of HECo on cored holes was properly closed.
This audit was performed mid-1985 by a (named)
CECO QA engineer.
NRC Review: The NRC inspector reviewed all audits of HECo performed by this CECO QA engineer and determined that this concern related to CECO QA Audit 6-85-150 or Audit 6-85-152.
CECO QA Audit Report 6-85-150, dated May 26, 1986, documented that Concrete Core Drilling Requests were reviewed to verify
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that the cored holes were inspected by HECo QC prior to conduit installation. HECo QC had indicated that there had been a
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problem in the field with conduit being installed prior to the QC inspection of the cored hole. The audit also revealed that HECo had identified this deficiency on Special Surveillance 85-15, an additional review was deferred to allow HECo time to implement corrective action. A review of CECO QA Audit Report 6-85-152, dated October 11, 1985, indicated that CECO QA verified that HEco
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had implemented corrective action and action to prevent recurrence for the deficiencies identified in HECo's Special Surveillance 85-15.
This verification was made by CECO QA's review of NCRs, cored hole reports, training records and procedure implementation dates. The NRC inspector's review of Audit Report 6-85-152, including audit backup data, indicated that the audit was adequate to close the concern on cored holes.
Conclusions: The NRC inspector reviewed CECO QA Audit Reports No. 6-85-150 and 6-85-152 and determined that these audit reports were properly closed.
No violations or deviations were identified.
(53) Concern: No one is preparing a rework request for fire proofing when items such as pull sleeves, tray covers, and J-Box covers are removed or disassembled so Transco can install fireproofing material. Without a rework request, HECo QC does not know when to reverify reinsta11ation of pull sleeves, covers, etc.
NRC Review: A review of rework requests (Form HP-7A-1),
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determined that 7A-1 forms were prepared if the fireproofing was identified on a Nuclear Work Request (NWR); required the removal of cable tray siderails; and required the removal of a raceway hanger.
Rework requests were not being prepared for removal / replacement
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of items such as J-Box and cable tray covers, and pull sleeves.
During interviews with HECo and Transco QC personnel, the NRC inspector was informed that neither ccmpany was verifying the reinstallation of these items after fireproofing. During the inspection, the licensee initiated an interface agreement
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between HECo and Transco to assure that all items were returned to their designed conditions upon completion of fireproofing work activities.
To verify past work activities, CECO QA initiated a surveillance program. As of October 2, 1986, CECO QA identified several discrepancies with the installation of flex conduit.
However, it could not be deternined if these discrepancies were the result of fireproofing or construction activities.
Conclusions: The NRC inspector verified that when a rework request was not prepared for fireproofing activities (For
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examples; removal of J-Box and cable tray covers, disassembly of pull sleeves and flex conduit), these items were not reinspected by HECo or Transco after the fireproofing was completed. During the inspection, the licensee initiated an interface agreement between HECo and Transco to ensure that all future items would be reinspected after fireproofing work activities had been completed. CECO QA has initiated a surveillance program on past work activities to ensure that affected items were returned to their designed condition after fireproofing was completed.
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The licensee was informed that failure to assure that activities affecting quality are prescribed by documented instructions and
. accomplished in accordance with these instructions is an example of a failure to implement Criterion V of 10 CFR 50, Appendix B (455/86017-098).
(54) Concern: HECo does~not have a Level III Electrical QC Inspector. Who certifies QC inspectors?
NRC Review: The NRC inspector reviewed HECo's list of QA/QC personnel _ certifications and observed that a qualified individual (by name) had been properly certified Level III in all HECo QC procedures on August 3, 1984.
In order to verify that HECo QA/QC personnel were qualified and properly certified, the NRC inspector selected 16 individuals for review.
Following are the results of this review:
The QA/QC Manager and QC Supervisor not certified to any HECo procedures.
In that these two individuals were not performing any inspections, there is no requirement that they be certified.
In reviewing this individuals certification (Form HP-177), the NRC inspector noted that the audit participation (five audits within last three years prior to certification) did not meet the requirements of HEco Procedure 17, " Qualification and Training of Inspection and Audit Personnel," Paragraph 5.5.8.3.
- A review of the remaining individuals records revealed that in several cases, the individual was certified without or before the Level III inspector's approval.
As a result of the inspector's concern, HEco QA performed several Special Surveillances in this area.
Following are the results of the Special Surveillances performed by HECo QA:
Special Surveillance Report (SSR) 16-86 identified a QA engineer that was certified as a Lead Auditor that did not meet the requirements of Paragraph 5.5.8.3 of Procedure 17.
This was in addition to the QA Supervisor identified by the NRC. Corrective action was to withdraw the individuals lead auditor certification.
- As a result of SSRs 21-86 and 22-86, NCR 2057, dated July 25, 1986, was prepared to document that 16 individuals were certified without prior approval of the Level III inspector as required by Paragraph 4.2 of Procedure 17.
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c A review of HECo Procedure 17 determined that this procedure
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met ANSI N45.2.6-1978, " Qualification of Inspection, Examination, and Testing Personnel for Nuclear Power Plants," for qualifica-
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tion and certification of QC inspectors and ANSI N454.2.23-1978,
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" Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants," for qualification and certification of Auditor and Lead Auditor personnel.
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Conclusions: The NRC inspector verified that HECo has a
qualified and certified Level III Electrical QC Inspector on staff. This individual was certified Level III in all HECo 2-
- procedures on August 3, 1984. However, a review of QA/QC certifications by the NRC inspector and HECo QA identified that L
18 individuals (16 QC and 2 QA) were not qualified and/or l
certified in accordance with HECo Procedure 17.
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The licensee was informed that failure to assure that QA/QC i:
personnel were properly qualified and certified is an example j-of failure to-implement of Criterion II of 10 CFR 50, Appendix B
(454/86031-14B; 455/86017-14B).
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l (55) Concern:
Cable pulling and rework was done on the back shift.
Least experienced QC inspectors were assigned to the back shift j
with no supervision.
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.NRC Review:
From interviews of QC personnel and review of records, it was established that the increase in second shift (back-shift)
i QC personnel occurred in approximately February 1985. The second shift nucleus consisted of a foreman (QC Lead Inspector)
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and four QC inspectors. This QC nucleus was supplemented by
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additional inspectors on an as-needed basis. A review of the
experience level of the four QC inspectors assigned to second i
shift indicates that inspector "A" was initially certified on i
October 15, 1982; inspector "B" on December 18, 1981; inspector I
"C" on June 24, 1982; and inspector "D" on December 18, 1981.
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All four inspectors were qualified and certified in four or more i
areas, and in addition,~they were all journeymen electricians.
The foreman was certified in six areas of inspection. The
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i foreman was not certified in cable pulling, cable termination, i
Class 1 equipment installation, and cable pan and pan hanger
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installation although the personnel he was supervising were certified in these areas of inspection. However, ther is no l
requirement that a supervisor be certified'in all areas of
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inspection. Also see Paragraph 5.a(14) above for another
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example where a supervisor was not certified in the areas he was i
supervising.
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Conclusions: The experience of the QC inspectors on second shift exceeded two years per inspector, in addition, all the i
inspectors were journeymen electricians. The QC foreman on
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however, there are no requirements for a supervisor to be
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certified in all areas that he is supervising.
No violations
or' deviations were ioentified.
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(56) Concern:
During the spring of 1983, Energy Incorporated audited HEco on Procedures 9A, 99, and 9C. This has been referred to as the " Black Book Audit." During this audit, approximately 70 of approximately 1200 hangers were hand picked for review. The sample was too small and 80-90 QC identified discrepancies went away as a result of this audit.
NRC Review: A review of HEco procedures indicated that Procedure 9A is for " Class 1 Cable Pan Hanger Installation";
Procedure 98 is for " Class 1 Cable Pan Installation"; and Procedure 9C is for " Class 1 Cable Pan Cover Installation."
Energy Incorporated (EI) is under contract to HECo to perform periodic management audits of HECo at the Byron Station and to supply a limited number of QA/QC personnel to supplement the HECo QA/QC Department. The NRC inspector reviewed EI audits of HEco.
The NRC inspector was unable to identify an audit that fits the description of this concern. The only audit, that the inspector could identify, that approached the alleger's concern was CECO QA 6-84-309. This CECO QA Audit is discussed in Paragraph 5.a(30) above. The alleger stated that 80-90 deficiencies went away as a result of the alleged audit. With this concern in mind, the NRC inspector reviewed the NCR and DR logs and selected NCRs and DRs (HECo DR system was implemented May 1982).
The NRC inspector was unable to identify any group of NCRs and DRs relating to pan hangers that were closed in a relatively short time frame. There were several major HEco and CECO NCRs prepared that caused a large reinspection effort of cable pan hangers (HECo NCRs 407, 407R, 540, and 1235 and CECO NCRs F-786 and F-961). These reinspection efforts were monitored by NRC inspectors, (Inspection Report numbers are listed below). As a result of an NRC team inspection at the Byron Station (See NRC Inspection Report 454/82005; 455/82004) a major reinspection was initiated.
In the case of HECo, the NRC SRI selected 20%
of HECo's QC inspectors (by name) for a reinspection of their inspections performed during the first 90 days after their certification.
Due to the construction effort in that time frame, a large percentage of the reinspection activity was concentrated on cable tray hangers.
The following is a partial listing of NRC Inspection Reports that documents NRC's review of the CECO reinspection program (This list is not complete in that the inspector did not perform a 100% review of all 1982, 1983, 1984, and 1985 reports for Byron Station):
Unit 1 Unit 2 454/82017 455/82012 454/83037 455/83029 454/83048 455/83037 454/84013 455/83048 454/84027 455/84009 454/84047 455/84019 454/85,069 455/84041 455/84047
The above listed NRC Inspection Reports provide a status and a final acceptance of the CECO Reinspection Program, which included cable tray hangers and appeared to be the allegers prime concern.
Conclusions: This concern could not be substantiated in that the NRC inspector could not identify any audits that came close to the allegers description that were preformed by Energy Incorporated. A major reinspection program had been conducted at Byron Station by the licensee. This reinspection program included cable pan hangers. This reinspection program was inspected and accepted by the NRC. No violations or deviations were identified.
(57) Concern: The alleger questioned the quality of the welds in Unit 1.
Review HECo NCRs 540 and 1235.
NRC Review: HECo NCR 540 was initiated due to defective welds in Units 1 and 2.
To facilitate the timely closure of the NCR for Unit 1, the Unit 2 deficiencies were removed from NCR 540 and documented in HECo NCR 1235.
Both of thee HECo's NCRs were transferred to CECO's NCRs F-786 and F-961 respectively. The CECO NCRs were necessary to facilitate a review and dispositioned of the NCRs by S&L. These NCRs were a part of CECO's reinspection program which was monitored and accepted by the NRC.
See Paragraph 5.a(56) above for additional details. In addition, a NRC Welding /NDE inspector stated in the Byron ASLB Hearings that he had personally inspected thousands of HECo welds and had found them acceptable.
Conclusions: The CECO reinspection effort resolved the deficiencies documented in HEco NCRs 540 and 1235. The NRC monitored and accepted this reinspection program. The NRC also performed additional inspection of HECo welds and found them acceptable.
No violations or deviations were identified.
(58) Concern: Under Procedure 7A, if a hanger is relocated, the welds may not be reinspected.
NRC Review:
The NRC inspector reviewed Procedure 7A, " Rework Control." This procedure defines rework as "the removal and reinstallation of previously installed work." Paragraph 5.4 states, "All work shall be performed to the current revision of
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the installa.:on documents";
i.e.,
if cable pulling is involved, use Procedure 10 or if welding is involved, use Procedure 13 series. Paragraph 5.8.2 requires that "an advance copy of all safety-related rework requests be provided to HEco QA/QC."
Paragraph 5.13 requires " notification of HECo QA/QC when the work is complete." All inspection reports are listed on the rework request. An independent review for acceptability is made by HECo QC with a quarterly surveillance by HEco QA.
In addition, HECo engineering reviews the rework request and provides a copy a
to CECO PCD for their review.
Procedure 13AA, " Class 1 Shielded Metal Arc Welding," Paragraph 5.15 requires "a weld traveler
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card (WTC) to be prepared for all welds." If the weld is safety-related, a QC weld inspector must inspect and complete Section III of the WTC in accordance with Paragraph 5.15 of
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Procedure 13AA, and Procedure 13AE, " Class 1 Visual Weld Examination Procedure." The WTC number is listed on the rework
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request.
In addition, the WTC number is also listed on the conduit support checklist or cable pan hanger checklist, as applicable.
The NRC inspector selected 100 rework requests for review.
In all cases where welding was required, a WTC number was listed.
Using the WTC number and the WANG, the inspector was able to identify the welder's ID, date welded, weld inspector, date inspected, item number, drawing number, and the rework request number was listed in the comment column.
Conclusions:
Based on the NRC inspector's review of procedures, rework requests, inspection reports, and WANG printout of WTC numbers requested, this concern is refuted in that no missed inspections were identified. No violations or deviations were identified.
(59) Concern: Hanger 15HV-1 has a " slugged-up" welds and no NCR or DR was prepared. This hanger is located at 364' elevation, at columns L and 15.
NRC Review:
From the column lines and elevation provided, the NRC inspector determined that hanger 15HV-1 was shown on S&L drawing 0-3099H01, Revision AA.
From this drawing, it was determined that the exact location of hanger 15HV-1 was l'9" south of 16 line and 2' west of L line. Using the WANG, it was determined that HECo NCR 1220, dated November 27, 1984, was prepared by the alleger to document a " slugged weld" on hanger 15HV-1. A slugged weld is a weld with excessive fit-up gap and the welder will place pieces of weld rod in the gap and weld over top of the rod. This type of welded joint does not develop the required strength and is therefore unacceptable.
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The slugged weld was removed and the joint was rewelded and i
inspected as documented on WTC 75377 and on NCR 1220.
In addition, the welder was retrained, and the NCR was properly closed on June 24, 1985.
Conclusions: This concern was not substantiated in that NCR 1220 had been prepared on hanger 15HV-1 for a slugged weld. The weld was repaired and the NCR properly closed.
No violations or deviations were identified.
(60) Concern: There are 8-10 discrepancies on the Unit 1 AF system l.
battery racks.
Do not think they will meet seismic l
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requirements and no NCR or DR was prepared on these racks. The battery racks are located at 383' elevation, at columns L and 19.
NRC Review:
From the equipment list, it was determined that the AF (Auxiliary Feedwater) system batteries, including racks, were assigned equipment numbers IAF01EA and 2AF01EB. A review of the records for this equipment revealed that DR 8094 was prepared by the alleger to document the fact that battery racks 2AF01EA and 2AE01EB were not installed per detail 801 on S&L drawing 0-3391H. This DR was subsequently upgraded to NCR 1734, dated October 24, 1985, which was forwarded to Ceco /S&L for disposition. After performing an analysis, S&L issued ECN (Engineering Change Notice) 30487 to document the as-built condition of the subject battery racks and NCR 1734 was dispositioned "use-as-is."
NCR 1734 was properly closed on May 23, 1986. Based on the NRC inspector's review, the S&L analysis was found acceptable.
Conclusions: The discrepancies identified on AF system battery racks 2AF01EA and 2AF01EB were documented on DR 8094 which was subsequently upgraded to NCR 1734.
The as-found condition was analyzed by S&L and found acceptable. ECN 30487 was issued to document the as-built condition of battery racks 2AF01EA and 2AF01EB. No violations or deviations were identified.
(61) Concern: HECo engineering or QA writes all NCRs per Procedure 6 and at times, they do not address the problem. The applicable QC inspector should have input in preparing the NCR or at least, let the QC inspector review the NCR before it is issued.
Inspectors can only write " practice" (un-numbered) DRs and NCRs.
NRC Review: A review of HECo Procedure 6, " Reporting of Damaged or Nonconforming Material or Equipment," Revision 15, dated September 23, 1985, revealed that QC inspectors were not permitted to prepare DRs or NCRs.
Paragraph 5.2.1 of this procedure states, " Deficient items which are not identified for correction and tracking thru the use of open inspection reports, will be brought to the attention of the appropriate supervisor for evaluation.
Supervisors shall write DR's as appropriate based upon their evaluation." DRs are then forwarded to HECo Project Engineer and/or QA/QC Manager for resolution.
DRs may be upgraded to NCRs. The NRC inspector expressed a concern with QC inspectors not being permitted to prepare, at a minimum, DRs. As a result of this NRC conern, HECo issued procedure change notice (PCN) 67 to revise Procedure 6.
This PCN allows the QC inspector / supervisor to prepare DRs..In that the QC inspector can now prepare DRs and DRs are typically attached to the NCR (when they are upgraded), this should alleviate the QC inspector's concern with the wording on NCRs. Also, the present QA/QC Manager has stopped the practice of preparing
" Practice" deficiency reports. During the inspection, the NRC inspector did not identify any hardware problems resulting from the use of " practice" DRs.
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A review of NCRs, DRs, and inspection reports (IR) revealed that in some cases _the description of the deficiency was not clear and/or pertinent data was missing.
This resulted in some poor and/or incomplete resolutions.
In order to prevent recurrence of similar deficiencies in the description of the deficiency, the HECo QA/QC Manager issued QA/QC Memorandum 2365, dated September 5, 1986. This memorandum states, in part, "The Lead Inspector, Group Leader and Assistant QC Supervisor is responsible for reviewing the reports (DRs, open and closed inspection reports) to assure completeness and inclusion of sufficient data to substantiate the inspection results. Any reports which lack sufficient data will be returned to the inspector for correction."
Conclusions: PCN 67 to Procedure 6 was issued to permit QC inspectors to prepare DRs. Most NCRs are upgraded DRs with the DR attached. This now allows QC inspector input to DRs and NCRs. A review of NCRs, DRs, and irs revealed that in some cases, the description of the deficiency was not clear and/or pertinent data was missing.
irs (open and closed) and DRs now go through several levels of QC review prior to issue.
In addition, the preparation of " practice" deficiency reports has been stopped by.the direction of the present HECo QA/QC Manager..The use of " practice" DRs did not impact the quality of the inspections.
(62) Concern:
The HECo QC inspectors cannot get QA/QC management to listen.
NRC Review:
From personnel interviews and observations during this inspection, the NRC inspector determined that there was a severe communication problem within the HECo QA/QC organization.
During this inspection, (a) the QA/QC Manager resigned and was replaced with an individual that has an "open-door" policy; (b)
the QC Supervisor resigned and was replaced with an individual that is known and respected by the QC inspectors; and (c) the QA Supervisor resigned. The QA Supervisor's position is being filled by the present QA/QC Manager.
In addition, the QC-field office was closed and all QA/QC personnel are now in the HEco main office. Since the above changes were implemented, there appears to be a harmonious atmosphere within the QA/QC office.
Based on the PTL overinspection program (See Paragraph 5.a(10)
above), the lack of communications did not affect the quality of inspections.
s Conclusions: There was a severe communications problems within the HEco QA/QC organization. However, the quality of inspections were not affected. This appears to have been resolved with the replacement of the " top-three" in the QA/QC organization and the closing of the QC field office. No violations or deviations were identified.
(63) Concern: The QC Supervisor (by name) harassed and attempted to intimidate a QC inspector (by name). The NRC inspector was provided a copy of HECo NCR 2021, dated May 12, 1986.
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NRC Review: The NRC inspector interviewed the named QC inspector and the inspector's immediate supervisor (Lead Inspector). The
Region.III inspector was unable to interview the named QC Supervisor in that he had terminated his employment with HECo.
<
_ The named QC inspector stated that on May 9, 1986, he was i
assigned to core drilling. This work operation is performed by another contractor (Litgen) but HEco is responsible for the QC
,!
inspection of cored holes in accordance with HEco Procedure 21,
" Cored Hole Requests and Inspections." On May 9, 1986, the
,
named QC inspector attended a meeting with two NRC inspectors i
(Reference: Paragraph 5.a above). Prior to attending this
!
meeting, he informed his lead inspector he would not be available to inspect cored holes while the meeting was in progress. After
'
i the meeting was over, the inspector stated he went into the i
plant and observed that Litgen had cored holes 2059 and 2060 j
without QC being present.
In that this was a violation of
procedures, the named QC inspector prepared two draft NCRs, one on each cored hole, and submitted them to his lead inspector for
i review and processing.
The named QC inspector stated that the
next time he saw the NCR (2021) was when the named QC Supervisor
called him into his office and " chewed him out" for missing two j
inspections. The QC inspector also stated that the supervisor threatened to place a letter (letter of reprimand) in his
personnel file. The QC inspector stated that he informed the QC
.
j Supervisor that he told his lead inspector he was meeting with
,
the NRC and that his lead attended the same meeting. The QC i
inspector stated that "the QC Supervisor told me that I was lying because XXXXX (lead inspector) said that I never told him I would be attending the meeting." The named QC inspector
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provided the NRC inspector copies of the two draft NCRs he had
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i prepared on cored holes 2059 and 2060. When the draft NCRs were compared with NCR 2021, it was observed that the two draft NCRs were combined into NCR 2021 with additional words added.
NCR 2021 now reads in part, " Core Hole #2059 was drilled without
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QC (inspector's name) present. This is a violation of Procedure l'
- 21, paragraph 5.3.3 and 5.3.3.1.
(Hatfield QC was notified prior to core drill, but choose not to attend to their
l responsibilities)." There was a single line drawn through the
inspector's name with initials and a date.
It was determined I
that the initials were placed there by the HEco QA/QC Manager, j
The NRC inspector was informed that the information within j
parentheses on NCR 2021 was added by the named QC Supervisor.
This was also confirmed by the lead inspector.
i During an interview of the subject lead inspector, the NRC
{'
inspector was informed that the named QC inspector had informed
,
him (lead inspector) that he would be attending the meeting with
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the NRC and that he was aware that the named QC inspector was
assigned to core drilling on that day (May 6, 1986). The lead
<
inspector stated that he had informed the named QC Supervisor l
j that hp (lead inspector) was at fault for not assigning another
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I inspector to the core drilling effort. This lead inspector confirmed that he had attended the meeting with the NRC on May 9, 1986 and that he had discussed his attending with the named QC i
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Supervisor before and after the meeting (Also see Paragraph 5.a(64) below).
The NRC inspector verified that a letter of reprimana had not been placed in the named QC inspector's personnel file. Also, NCR 2021 was properly closed on June 2,1986.
Conclusions:
From personnel interviews and review of records, it was determined that an unnecessary and uncalled for statement was placed on NCR 2021 by the named QC Supervisor.
However, since NCR 2021 was properly closed, no letter of reprimand was placed in the inspector's file, and the named QC Supervisor is no longer employed by HECo.
No additional NRC follow-up action is planned on dis concern.
(64) Concern: The QC Supervisor (by name) called a lead inspector (by name) into his office and questioned him about the May 9, 1986, meeting with the NRC. This meeting lasted approximately 1 1/2 hours and the lead told all.
NRC Review: The NRC inspector interviewed the named lead inspector about this concern.
The NRC inspector was informed that he (the lead inspector) discussed his attending the May 9, 1986 meeting with the NRC with his supervisor (named QC supervisor) and he initiated the interview with his supervisor following the meeting with the NRC. The lead inspector stated that he and his supervisor discussed the concerns expressed to the NRC.
Conclusions: This concern was not substantiated in that the named lead inspector initiated the interview with the named QC supervisor. No violations or deviations were identified.
(65) Concern: Safety-related drawings are not checked for inspections.
There are no termination cards for internal wiring and QC has to depend upon constructions to issue an inspection request.
NRC Review: The NRC inspector reviewed Procedure 11, " Class 1 Cable Termination and Splicing," and noted the folloving related requirements:
Paragraph 5.1.5 states, "The S&L Wiring Diagrams shall identify the terminal point of each conductor."
- Paragraph 5.1.7 states, "The cable will be terminated as shown on the wiring diagram."
- Paragraph 5.9.1 states, " Inspections for cable terminations, splices and repairs shall be performed using Fprm HP-118."
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Form HP-118, Cable Termination Inspection Report, inspection attribute 15, states, " Terminated per Wiring Diagram." The wiring diagram number and revision must be entered on this form.
- Exhibit N provides an example of a " Cable Pull Card,"
also, the back of the pull card provides the cable
"From End" and "To End" termination data.
- Paragraph 5.1.28 states, "Upon completion of the splice, the termination, or the repair, the field personnel will fill in the required information on the cable pull card and on the Form HP-118. These documents will then be returned to the QA/QC Department for acceptance and retention."
This is constructions method of notifying QC that an item has been installed and is ready for inspection.
For Unit 2, HECo QC is now in the process of listing all items requiring inspection (For examples, hangers, cables, cable pans, and conduit) and verifying that the applicable inspection reports are on file. To assure that revised drawings are being reviewed for additional work (revisions to installed items cr new work), the NRC inspector selected six drawings for review.
All six drawings had been reviewed by production, engineering, and QA/QC. This review resulted in four rework requests being prepared to rework items that had been previously installed and accepted. The NRC found the controls to be adequate and the controls acceptable.
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Conclusions:
Procedures are in place to preclude missing of required inspections for Unit 2.
Paragraph 5.a(39) above is an example where HECo identified missing WTCs for Unit 2 riser collar welds.
Procedures also require construction to notify QC when an item has been installed and is ready for inspection. No violations or deviations were identified.
(66) Concern:
Sargent and Lundy (S&L) added conduits to a J-Box without considering load effects. Think XXXXX (named QC inspector) wrote up one box and additional anchors (CEAs) had to be added.
NRC Review: The NRC inspector reviewed NCRs 540 through 1992 and could not identify any NCR that fits the description of this concern.
During this review, the NRC inspector noted that some NCRs had been issued on undersized concrete expansion anchors (CEA) being installed, or CEAs not being installed to the minimum embedded depth.
In all cases noted, the CEAs were found to be acceptable as installed based on analyses by S&L. During this review of NCRs on CEAs, the NRC inspector selected the NCRs dispositioned "use-as-is" and reviewed the S&L analysis to verify justification for the disposition.
l No discrepancies were identified with the analysis.
Conclusions: Based on the NRC inspector's review of approximately 1450 NCRs, without being able to identify an NCR that fit the allegers concern, this allegation was not substantiated.
In addition, the NRC inspector reviewed the S&L analyses on ten NCRs where the CEAs were accepted as installed. The S&L analyses was found to be adequate. No violations or deviations were identified.
(67) Concern:
HECo QC was directed to limit their inspections to the scope of the applicable 7A (Rework Request).
NRC Re,iew: During interviews of HECo QC inspectors and lead inspectors, the NRC inspector was informed that certain QC inspectors wanted to reinspect everything in the area when they were assigned to inspect an item on a rework request.
Two examples were provided (a) As a result of a drawing revision, a new conduit hanger is being installed on previously accepted tube steel by a rework request. At least one QC inspector would have the fireproofing removed so he could reinspect all the tube steel welds as well as the welds on the new conduit hanger and (b) As a result of a drawing revision, a new cable is being added to a cabinet by a rework request. Again, at least one inspector would reinspect all the terminations in the cabinet in addition to the termination of the new cable.
For the examples provided, it is not necessary to reinspect the surrounding items. Only the actual rework requires inspection.
If however, an item was being reworked, and the nature of the rework caused damage to the surrounding equipment, then an expanded reinspection would be justified.
In all examples discussed above, if a discrepancy was identified outside the scope of the rework request, it should be documented in accordance with HECo procedures. During a review of rework requests, the NRC inspector did not identify any rework that would justify a reinspection of any item (s) outside the scope of the rework request.
Conclusions: Based on personnel interviews and review of rework requests, the NRC inspector did not identify any rework that would justify a reinspection of any item (s) outside the scope of the rework request.
However, if any discrepancy is identified, it should be documented in accordance with HECo procedures. No violations or deviations were identified.
(68) Concern: When using a standard 45' or 90* conduit fitting, the minimum cable pulling and training radius is exceeded.
NRC Review:
Conduit fitting are designed to have cable pulled through the fitting without causing damage to the cable. When pulling cable, the cable does not follow the inside radius of a conduit bend (fitting or formed conduit).
The cable contact points, during a pull, would be the outside of the fitting radius on both ends and the inside of the fitting radius in the middle of the fitting.
Electrical cables (except for special
cables) can be pulled through a specified conduit fitting without exceeding the minimum cable bend radius.. Cables under tension have a more restrictive bend radius than cables not under tension. Therefore, the cable train radius would also be acceptable for a cable installed in a conduit with specified 45'
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or 90' fittings.
S&L Standard EB-146, paragraph 7.2.6, does not permit " standard" radius elbows (bends) unless specifically indicated on the Electrical Drawings.
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Conclusions:
Electrical cables (except for special cables) can be pulled through a specified conduit fitting without exceeding the minimum cable pulling or training radius.
S&L Standard EB-146 does not permit a " standard" radius elbow unless specifically indicated on the Electrical Drawings. No violations or deviations were identified.
(69) Concern: There is a memorandum from the Assistant Project Manager, dated April 18, 1986, on NCRs and DRs.
If this memorandum.is implemented, it would give the craft a chance to correct the deficiency before the DR/NCR is written and dispositioned.
NRC Review: The NRC inspector obtained a copy of the Assistant Project Manager's subject memorandum for review. This memorandum indicates that when a violation is identified, all the applicable HEco personnel should be notified immediately so the violation could be reccnstructed for the owner while the facts were fresh in people's minds. This memorandum states, in part, "The above subject (NCR and DR violations) has been discussed many times, where as QA/QC would identify violations such as pull over tensions, preheat and any other violations that we, HECo, knows will result in a NCR that we will have to reconstruct for the owner.
...
the QC inspectors can be instructed to let QC Supervisor know when there is a violation.
This will enable us to get it resolved and down on paper by the time the NCR appears, which in most cases has been weeks later." As can be seen from the memorandum, the Assisthnt Project Manager recognized the fact that an NCR would be prepared for certain violations and that the facts of the violation must be presented to the licensee on the NCR.
Conclusions: Based on a review of the Assistant Project Manager's memorandum of April 18, 1986, it was concluded that the purpose of the memorandum was to request early notification of violations. This early notification would permit HECo to gatter the facts of the violation for' presentation to the licensee and not to correct the violations before a DR/NCR was prepared. No violations or deviations were identified.
(70) Concern:
Field Change Request (FCR) F-26448 relocated a terminal box on panel 2PL85JA.
This panel was installed by Powers-Azco-Pope (PAP) and the subject terminal box appeared on a PAP drawing. HECo relocated the terminal box. Was FCR F-26447 ever incorporated on the applicable PAP drawing?
.
NRC Review: The NRC inspector reviewed FCR F-26447. This review revealed that'the subject FCR had been incorporated on Systems Control (panel vendor) drawing 6577-M-2PL85JA on September 19, 1985. The systems control drawing was provided to PAP for their use in the installation of instrument panel
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2PL85JA.
Conclusions:
FCR F-26447 was incorporated on Systems Control Drawing 6577-M-2PL85JA.
This drawing was provided to PAP for their use in the installation of panel 2PL85JA. No violations or deviations were identified.
(71) Concern: Review HECo NCRs 937 through 942 for proper closure.
Also review S&L's walkdown for separation violations.
NRC Review: The NRC inspector reviewed HEco NCRs 937 through 942 and found that all these NCRs pertained to electrical separation violations and were prepared after the CECO, HEco, and S&L separation walkdowns.
These NCRs identified previously identified separation violations. The NRC reviewed the separation walkdown effort; S&L analysis of the violations identified; applicable drawings to verify that tray covers were specified
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as part of the corrective action; and performed a tour of the power block and identified separation violations and verified
that these violations had been identified during the joint separation walkdown. (See NRC Inspection Report 454/84027; 455/84019). These walkdowns and corrective actions were found to be acceptable, however, the licensee was issued a violation, by the NRC, for failure to inspect for separation violations on i
items installed after the joint walkdowns were completed.
The
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NRC issued violations were subsequently closed in NRC Inspection Reports 454/84047; 455/84041 and 454/84069; 455/84047.
Conclusions: The electrical separation violations identified on NCRs 937 through 942 had been previously identified during a joint (CECO, HEco and S&L) separation walkdown. The NRC's actions on separation issues are documented in the NRC
Inspection Report referenced in the above paragraph. No violations or deviations were identified.
(72) Concern:
Review HECo QA/QC Manager's (by name) interoffice memorandum. QC inspectors need approval to go to Ceco for any
'
reason.
NRC Review:
The NRC inspector reviewed the QA/QC memorandum file and memorandum log. A review of the file revealed that QA/QC Memorandum 1669 was missing. A review of the log indicated that the subject of this memorandum was " Department Policy," and was prepared on January 10, 1985. During interviews with numerous QA/QC personnel it was revealed that during a staff meeting, conducted by the named QA/QC Manager, they were informed that they could not go to the CECO office without their Supervisors
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g huthorization. At the NRC'ii'spector's request, various inspectors,
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i p. lead inspectors, and clerks searched their personal files for a hopy of Memorandum.1669 with negative results., Based on the NRC
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j inspector's observations during the inspectin, neither quality nor communications nith the'11censee was affected by the HECo
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t QA/QC Manager's vernal directions and/or the subject memorandum.
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The named QA/Q? Manager was not interviewed in that he had
.g terminated his'empicyment with HECo.
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. Conclusions: 1This concern could not be refuted nor
- p substantiated in!that a copy of HECo QA/QC Memorandum 1669
~L could not be found. The named QA/QC manager was not interviewed
's in that he had terminated his employment with HEco. There was
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no effect on the quality of the plant and communications iwth-the licensee. Mo violations or deviations were identified.
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- W (73) Concern: LFor hurtain Unit 1 equipment, the weld downs inside
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the cabinets were not welded per detail. These weld downs were
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q never repaired.
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NRC Review: The NRC inspector was able to identify HECo DR
.
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4181, dated February 9,'1984, HEco NCR 855, dated Fe.bruary 13,
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e1984, and Ceco NCR F-916, dated June 1, 1984, that addressed
- this concern. JAs can be seen from the dates of the various
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documents, the deficiencies were first identified on DR 4181.
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'This DR identiflad defective welds or welds that were not welded
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'per.the drawing detail for the following items of. equipment;i
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1AP05E 1AP06E 1AP106E 1AP26E
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DR 4181 was subsequently upgraded to HECo NCR 855. The largest
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t number of defects pertained to slot welds not being welded per
.
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the drawing detail. Detail 47 requires slot welds to be welded
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onall?Jpursidesanditwasidentifiedthattheywereonlywelded Nh on the two long sides of the slot. 'Several instances of problems L['
with weld overlap, u'ndercut, slag inclusion, and weld spacing were'also identified. At the licensee's direction,-weld maps
~
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were prepared for the above listed equipe nt.
This information
!
O was ccmpiled and incorporated in CECO NCR C-916 whl:h was (
forwarded to S&L for their evaluation. Based on the S&L analyses
,,
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.r. "of the as-welded condition, it was determined that no additional
'
welding (repair or rework) was required fob these items to meet
'
l Ahe seismic requirements for Class IE equipment. These NCRs j
'were properly closed on July 9,1984. The same type of weld i
deficiencies were identified on similar Unit 2 equipment. The i
Unit 2 deficieacies were documented on HECo NCR 1669 and Ceco
'
'
i NCR F-1005. These Unit 2 NCRs were properly closed on i
December 14, 1965.
For additional details, see NRC Inspection l
Report 454/86019, 455/86014.
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Conclusions: As documented on HECo DR 4181, HEco NCR 855, and CECO NCR F-916, some Unit 1 and Unit 2 equipment weld downs were identified as not being welded to detail and/or had defective welds.
The S&L analyses of the as-welded condition determined that no weld repair / rework was required for these items to meet the seismic requirements. No violations or deviations were identified.
(74) Concern: Cable tray span is never verified.
NRC Review:
Cable tray span is defined as the span / distance between adjacent cable tray hangers. The maximum cable tray span is determined by the design analysis.
From this analysis, the design engineer determines the hanger location and the hanger installation tolerance.
If the cable tray hangers are installed per the design drawings (design location + the installation tolerance), then the cable tray span criteria would be met. During a review of HECo Procedure 9A, " Class 1 Cable Pan Hanger Installation," the NRC inspector verified that cable tray (pan) hanger location was inspected by QC. Attribute 6 on Form HP-9A-1, " Class 1 Cable Pan Hanger Inspections Checklist," states, " Hanger Location per Drawings." The criteria for this attribute states, "The hanger must be located within the tolerances specified on the Cable Pan Hanger Drawing 0-3272."
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The NRC inspector reviewed approximately 100 HP-9A-1 forms to
verify that QC was inspecting this attribute. No discrepancies
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were identified.
Conclusions: Cable tray span was in fact being verified by
~~
confirming that the cable tray hangers are installed per the design drawings.
Inspections for cable tray hanger location were properly documented on Form HP-9A-1. No violations or
!
deviations were identified.
(75) Concern: A HEco QC inspector (by name) and his wife were
'
threatened and HECo management did nothing about it.
The named QC inspector would not allow the craft to pull cable '
until they installed a dynamometer.
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NRC Review: Toprotecttheelectricalcablefrombeingdver stressed during cable pulling, a maximum cable. pulling tension is established. To prevent exceeding the msximum cable pulling tension, a dynomometer is installed to measure the actual pulling tension. The requirements for using a dynomometer are established in HECo Procedure 10, " Class 1 Cable Installation." The NRC inspector interviewed the named QC inspector with respect to this concern. The NRC inspector was informed that neither the named QC inspector nor anyone in his' family had even been threatened.
The named QC inspector stated that an incident had
~
taken place in approximately November 1985 where he had stopped a cable pull due to a lack of the required dynomometer being installed for the cable pull.
During this incident, one of the
__
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craftsmen addressed this QC inspector using abusive and foul language, but the inspector was never threatened.
This QC inspector reported the incident to his supervisor.
The NRC inspector was informed that an immediate investigation was performed by HECo management. This investigation culminated in the termination of the craftsman.
Conclusions: The named QC inspector stated that neither he nor his family had ever been threatened. However, there was an incident where a craftsman addressed the named inspector using
/
.busive and foul language. HECo management conducted an immediate investigation which culminated in the termination of the craftsman. No violations or deviations were identified.
)
(76) Concern: The signature of a QC inspector (by name) was forged on Class 1 Exposed Conduit System Inspection Checklist Report Numbers 576 and 577. These forged signatures were reported to the deco QC/QC Manager (by name) but nothing was ever done to get the issue resolved.
NRC Review: The NRC inspector discussed the alleged forged reports-(576 and 577) with the CECO QA Superintendent and present HECo QA/QC Manager. The named QA/QC Manager is no longer employed by HECo.
The licensee retrieved the original conduit inspection reports (576 and 577) with the purported signatures of the named QC inspector and 12 original documents containing the known signatures of the named inspector. These original documents were provided to a Foresic Document Examiner for examination to determine if all of the signatures were written by the named QC inspector.
.
During this inspection, the NRC inspector reviewed a letter, dated October 27, 1986, from the Forensic Document Examiner to the law firm of Isham, Lincoln and Beale that described the documents reviewed and the results of his review.
The Document Examiner's letter stated, " Based upon the examinations and comparisons of the exhibits submitted, the examiner is of the opinion that the writer of the known exemplars authored the three (3) questined signatures on Exhibits Q-1 and Q-1" (Inspection Report 576 and 577).
Conclusions: After examination by a Forensic Document Examiner, it was concluded that the signatures on conduit inspection reports 576 and 577 were not forged, therefore, this concern was not substantiated.
No violations or deviations were identified, i
1
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(77) Concern: Category II (non-safety-related) to Category I (safety-related) welds are not being inspected by HECo QC.
Also, there are many Category II to Category I cross-flange welds.
NRC Review: The NRC inspector reviewed Electrical Specification F-2790 for welding requirements in the areas of this concern.
Section 30.12 states that S&L Standard Form 1701, Revision G, forms a part of the specifications. The title of Form 1701 is
" Standard Specification for Welding in Steel Construction."
Section 401.19.1 of the specifications states, " Welds, includirg full and partial penetration groove welds, shall be subject to visual inspection as specified in BY/BR/VWAC."
~
Section 3.2.2 of Form 1701 states, " Fillet welds across flanges of any steel member will not be permitted unless specifically indicated on the design drawings; any under cutting or damage that will reduce the flange area will not be permitted."
Section 4.1.1 of Form 1701 states, "All welding shall be inspected and examined by contractor... unless otherwise indicated in the Project Specifications or the design drawings."
With respect to this concern, the inspector requested and received assistance from NRC Welding /NDE inspectors. The results of their findings will be documented in a subsequent NRC Inspection Report (454/86042; 455/86038).
Conclusions: With respect to this concern, NRC welding /NDE inspectors are investigating this concern,and the results of their findings will be documented in a subsequent NRC Inspection Report.
Pending the completion of this inspection, this item is open (454/86031-10, 455/86017-10).
(78) Concern: Procedure 20 is not compatible with S&L Standard EB-146.
NRC Review: The NRC inspector reviewed Procedure 20, " Class 1 Exposed Conduit System Installation," Revision 15, and compared it to the requirements of S&L Standard EB 146,." Standard Specification for the Installation of Seismic Category 1 Conc'uit Systems Containing Class IE Cable," dated April 23, 1986. The NRC inspector noted that there were several instances where a S&L drawing was referenced as the installation criteria rather than Standard EB146.
However, the Electrical Specification, Paragraph 304, states that the S&L drawings take precedence over S&L Standards.
Conclusions: During a review of Standard EB-146 and Procedure 20, it was observed that there were several instance where a drawing was referenced instead of Standard EB-146.
However, S&L drawings take precedence over S&L Standards. No violations or deviations were identified.
(79) Concer'n: During core drilling, there were numerous rebars
cut / hit in "Q" wall and many were not reported to S&L.
NRC Review: The NRC inspector reviewed approximately 100 cored hole reports (CHR).
For all safety-related CHRs that indicated a rebar cut / hit, an NCR was prepared if the cut / hit rebar was not permitted by the field change request (FCR) and/or core drilling request (CDR). Even though an NCR was not required, a copy of all safety-related and non-safety-related CHRs were forwarded to S&L for their review. During this inspection, the NRC inspector selected 10 CHRs for "Q" wall where rebar was cut / hit and verified that S&L was plotting / recording the cut / hit rebar on the appropriate "Q" wall (a safety related wall)
location.
In addition, the NRC inspector also selected five cut / hit rebar NCRs on "Q" wall and verified that they were
.
properly plotted / recorded.
No deficiencies were identified.
Conclusions: Cut / hit rebars were being preperly documented by S&L. No violations or deviations were identified.
(80) Concern:
Procedure 21, " Cored Hole Requests and Inspections,"
states that "no items may be installed in a cored hole until HECo receives a completed CHR signed-off by CECO PCD."
How can CECO sign-off (accept) a CHR with an open NCR against the cored hole?
NRC Review: The NRC inspector reviewed Procedure 21 and interviewed CECO PCD engineers. CECO PCD engineer's signature on a cored old report (CHR) is the licensee's approval for " Work May Proceed." If an NCR is prepared on the cored hole due to a rebar being cut / hit, the NCR tracks the deficiency. Therefore, a cored hole with a cut / hit rebar would not be " accepted" until the NCR was properly closed.
Conclusions: CECO PCD engineer's signature on a CHR is the licensee's approval for " Work May Proceed." The proper closure of the NCR would be the acceptance of the cored hole with identified deficiencies. No violations or deviations were identified.
(81) Concern: At final turnover to CECO, did the electrical raceway hangers meet the latest S&L drawings?
NRC Review: The NRC inspector reviewed the inspection, reinspection and overinspection history of the raceway hangers at the Byron Station. As a result of the NRC team inspection (See NRC Inspection Report 454/82005; 455/82004), a major reinspection program was initiated at Byron Station (See Paragraphs 5.a(56) and (57) for similar concerns).
This reinspection program included a reinspection of raceway hangers. The Following is a general sequence of events as relating to the raceway hanger, reinspection program:
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HECo NCR 407, dated February 11, 1982, documented that cable pan hanger inspections were inadequate. A sample inspection was performed on 20% of the total hangers in each of the six drawing areas with a 26% reject rate. The corrective action was to perform a 100% reinspection of i
all cable pan hanpers. This NCR was closed on June 9,
>
1982, before the reinspection was completed.
- HECo NCR 407R was initiated on December 3, 1982 to track the reinspection program.
- NRC Inspection Reports 454/82017; 455/82012 issued an Unresolved Item pending final review of NCR 407.
- NRC Inspection Report 454/83048 provided a status of NCR 407/407R.
- NRC Inspection Reports 454/84027; 455/84019 issued an NRC violation for inadequate inspections in conjunction with NCR 407R. As a results, 345 previously accepted cable tray hangers were reinspected and 129 were found defective and 19 were classified as indeterminate because they were inaccessible for reinspection. To document these deficiencies, HECo prepared NCR 989 and DRs 4921-4928, 4930, 4932, 4934-4937, 4943, 4945-4948, 5003, 5007, 5013-5017, 5019, and 5022-5032.
- NRC Inspection Reports 454/84047, 455/84041 closed the Unresolved Item identified in IE Inspection Reports 454/82017; 455/82012.
- l NRC Inspection Reports 454/84069; 455/84047 closed the l
violations identified in IE Inspection Reports 454/84027; l
455/84019.
During the review of this concern, the NRC inspector was provided
copies of various memorandums between Ceco and HECo. The following is a general description of these memorandums:
QA/QC Memorandum 897, dated July 1,1983, from a HECo QC lead inspector to the HECo QA/QC Manager identified certain pan hanger attributes that were not being inspected; e.g., gusset plate size, fit-up gap, and locus of working points.
- QA/QC Memorandum 1173, dated February 22, 1984, from a HECo QC inspector to the HECo QC Supervisor identified that " Prior to February 13, 1983, pan hangers were in most cases not inspected per detail."
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QA/QC Memorandum 1230, dated March 23, 1984, from HECo QA/QC Department to CECO PCD project electrical supervisor stated, "HECo QC has reviewed all detail connections on the 0-3200 series drawings. Attached is a copy of each detail including the items that have not been inspected."
The attachments to this memorandum listed the following types of items as not being inspected plate sizes; DV-161 stiffners; fit-up gap; I beam size; bolt hole dimensions; bent plate size; locus of working points; etc.
NOTE: The same types of discrepancies were previously identified by the NRC.
Fit-up (91); plate size (17); wrong connection detail (7); welding; missing bolts (See Inspection Reports 454/84027; 455/84019). This inspection was conducted between April 24 and May 11, 1984
CECO letter dated July 16, 1984, transmitted HECo QA/QC Memorandum 1230 to S&L for review.
- S&L letter to CECO, dated October 2,1984, documented the results of S&L's inspection program and analysis of uninspected items identified in HECo QA/QC Memorandum 1230. The following are excerpts from the S&L letter:
80 randomly selected supports were inspected.
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pre-approved checklist were utilized.
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engineering evaluation included observed discrepancies
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and Byron QC Inspector Reinspection Program.
engineering evaluation finds that the corresponding
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strength reduction in the connections is within the specified design limits.
the quality of cable tray support connection work is
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adequate through out the plant for both Units 1 and 2.
Based on the NRC inspector's review of the S&L inspection program and their engineering evaluation, S&L's evaluation was adequate to accept the hangers installed to date.
CECO letter from the PCD Project Electrical Supervisor to the HECo QA/QC Manager, dated October 8, 1984, transmits the S&L letter (October 2,1984) to HECo and states,
"This review has been completed and as identified in reference (b) above (S&L letter of October 2, 1984), the quality of the cable tray support connection work is adequate throughout the plant for both Units 1 and 2.
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cut / hit in "Q" wall and many were not reported to S&L.
NRC Review:
The NRC inspector reviewed approximately 100 cored hole reports (CHR).
For all safety-related CdRs that indicated a rebar cut / hit, an NCR was prepared if the cut / hit rebar was not permitted by the field change request (FCR) and/or core drilling request (CDR). Even though an NCR was not required, a copy of all safety-telated and non-safety-related CHRs were forwarded to S&L for their review. During this inspection, the NRC inspector selected 10 CHRs for "Q" wall where rebar was cut / hit and verified that S&L was plotting / recording the cut / hit rebar on the appropriate "Q" wall (a safety-related wall)
location.
In addition, the NRC inspector also selected five cut / hit rebar NCRs on "Q" wall and verified that they were properly plotted / recorded. No deficiencies were identified.
Conclusions: Cut / hit rebars were being properly documented by S&L. No violations or deviations were identified.
(80) Concern: Procedure 21, " Cored Hole Requests and Inspections,"
states that "no items may be installed in a cored hole until HECo receives a completed CHR signed-off by CECO PCD." How can Ceco sign-off (accept) a CHR with an open NCR against the cored hole?
NRC Review: The NRC inspector reviewed Procedure 21 and interviewed CECO PCD engineers.
CECO PCD engineer's signature on a cored old report (CHR) is the licensee's approval for " Work May Proceed." If an NCR is prepared on the cored hole due to a rebar being cut / hit, the NCR tracks the deficiency. Therefore, a cored hole with a cut / hit rebar would not be " accepted" until the NCR was properly closed.
Conclusions: Ceco PCD engineer's signature on a CHR is the licensee s approval for " Work May Proceed." The proper closure i
of the NCR would be the acceptance of the cored hole with identified deficiencies.
No violations or deviations were identified.
(81) Concern: At final turnover to CECO, did the electrical raceway hangers meet the latest S&L drawings?
NRC Review: The NRC inspector reviewed the inspection, reinspection and overinspection history of the raceway hangers at the Byron Station. As a result of the NRC team inspection (See NRC Inspection Report 454/82005; 455/82004), a major reinspection program was initiated at Byron Station (See Paragraphs 5.a(56) and (57) for similar concerns). This reinspection program included a reinspection of raceway hangers. The Following is a general sequence of events as relating to the raceway hanger reinspection program:
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attributes discussed in Memorandum 1230 on future work."
However, an ECN, FCR, or drawing revision was not issued to delete the requirements to install / inspect cable tray hangers in accordance with the design documents. QA/QC Memorandum 1631 documents that the HEcc QA/QC Manager provided a verbal directive not to inspect pan hanger connections per details specified on S&L drawings (Des.ign Documents).
The licensee was informed that failure to assure that changes to documents, such as instructions, procedures, and drawings are reviewed and approved by the same organizations that performed the original review and approval is an example of a failure to implement Criterion VI of 10 CFR 50, Appendix B (454/86031-15; 455/86017-15).
(82) Concern:
Procedure 10 has been revised to reduce inspection requirements.
NRC Review: The NRC inspector reviewed HECo Procedure 10,
" Class 1 Cable Installation," Revisions 19 through 24 (current revision). During this review, the following procedure differences were noted:
Between Revision 19, (February 14,1983) and Revision 22 (January 3, 1985) only minor changes were made to the HP-105 form (Cable Installation Inspection Checklist), the requirement to list the DR number (s), if applicable, was added.
- Between Revision 22 and Revision 23, (March 20, 1985) a major change was made to the HP-105 form. The following inspection attributes were celeted in Revision 23:
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Cables below top edge of pan, neat, flat and parallel.
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Half-rounds and edge protectors in place.
No sharp edges.
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i No damage or deformity to cables.
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No obvious violations of minimum bend in pan.
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Cables in pan protected from work in progress in area.
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No scaffold on pan in run.
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Embed conduit swabbed and acceptable.
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Cable ends were sealed.
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Minimum bend not exceeded (coiled cables).
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Cable routing acceptable.
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Cable free of damage.
Cable coiled properly.
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The following inspection attributes were added in Revision 23:
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Conduit reports HP-204, HP-205 and HP-206 complete and on file.
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Hangers installed and conduit properly attached.
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Conduit size is as specified in Exhibit K (Cable Tension Calculation).
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Installed junction boxes are as specified on Production Installation Reports.
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Exhibit K attached to HP-105.
A new section was added for Cable Rework.
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Revision 24 (October 18,1985) deleted the first three inspection attributes that we added in Revision 23. No inspection attributes were added in Revision 24.
During a tour of the plant by the NRC inspector, no discrepancies were identified that resulted from the reduced inspection i
criteria discussed above. The electrical construction activities, as of this inspection, are essentially complete at the Byron i
Station. However, it is the NRC inspector's understanding that HECo's contract has been extended through December 1987 to perform maintenance and modification work activities as directed by the licensee. Based on this extension of contract, the licensee was requested to evaluate HECo Procedure 10, Revision 22, 23 and 24, and provide justification for the deletion of the
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j above listed inspection attributes.
Conclusions: A review of Procedure 10, Revisions 19-24,
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indicated that inspection attributes were deleted from the cable installation procedure. During a tour of the plant, the NRC inspector did not identify any violations that resulted from the deletion of these inspection attributes. Construction is essentially complete at Byron, however, HECo's contract has been extended. Based on this extension of contract, the licensee was requasted to provide justification for the deletion of inspection attributes from Procedure 10.
Pending a review of this justification, this item is unresolved (454/86031-11; 455/86017-11).
(83) Concern: The only corrective action cn minimum cable bend
radius violations is to straighten the cable.
These violations are never evaluated.
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NRC Review: The NRC inspector reviewed HECo Procedure ;0,
" Class 1 Cable Installation." Paragraph 5.1.45 of this procedure states, "QA/QC Department will conduct an evaluation against the criteria of Exhibit G and if required, QA/QC will generate a DR or NCR, as applicable, per Procedure 6." Exhibit G states,
" Commonwealth Edison Company (PCD) shall be notified by DR or NCR if: A kink or twist is found that is caused by compressing a loop to less than the minimum bending radius." As stated in Procedure 10, "HECo shall document all minimum cable bend radius violations on an NCR or DR."
The NRC inspector reviewed two CECO NCRs (F-873 and F-878) that identified c*hle bend radius violations. The disposition on these NCRs seates, " Retrain the affected cables such that the bending radius is equal to or greater than the minimum specified training radius." However, the violations identified on these NCRs were evaluated by S&L and the Okonite Company (cable manufacture). The NRC inspector was also provided a copy of a CECO internal letter, dated April 16, 1982, that provided guidelines for field examination of suspected nonconforming cable bending radius. This letter states in part:
" Power Cable, Medium Voltage - Above 600V. (Sky, 8kv and 16kv)
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Dispositioned on a case-by-case basis via CECO.
Nonconformance Report.
Power, Control and Instrumentation Cable, Low Voltage -
Under 600V.
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Cable is to be accepted if the (MBR) Minimum Bend Radius was exceeded under the following conditions:
(a) MBR violation did not occur when the cable was under pulling tension.
(b) Visual inspection of the cable indicates that tnere is no rippling, tearing or stretching of the cable jacket or significant deformation of the cable at the point where the MBR was exceeded (both inner and outer radius).
(c) The copper conductor had not been bent 180' and/or crushed severely such as to cause the copper conductor to be permanently crimped and/or penetrate the insulation or strands to be broken.
(d)
If the cable has been handled roughly but the visual inspection indicates no damage, construction or quality control may request that conductor continuity be verified.
C' ables not meeting the above criteria will be repulled/
abandoned.
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In all instances where the MBR has been exceeded, the cable installation will not be deemed acceptable unless the cable is retrained and left in an unstressed condition (final radius equal to or greater than MBR)."
The licensee was requested to provide justification for not documenting all violations of minimum cable bend radius on NCRs.
Conclusions:
The NRC inspector identified two NCRs identifying cable bend radius violations where the disposition was to retrain the cables. These violations had been evaluated by S&L and the cable manufacturer. There is a CECO letter that limits the conditions under which an NCR is required for cable bend radius violations. The licensee was requested to provide justification for not documenting all bend radius violations on NCRs.
Pending a review of this justification, this item is unresolved (454/86031-12; 455/86017-12).
(84) Concern: Battery cables for safety-related diesel driven pumps were received non-safety-related and installed in a safety-related system.
NRC Review: The NRC inspector reviewed NCR 1741 and Project Specification F/L 2891.
During a review of the specifications, it was determined that Paragraph 206 imposes the following IEEE Standards on the vendor, Stewart and Stevenson, Inc.:
IEEE 308, " Criteria for Class 1E Electric Systems for
,
Nuclear Power Generating Stations."
- IEEE 323, " Standard for Qualifying Class 1 Electric Equipment for Nuclear Power Generating Stations."
IEEE 344, " Standard for Seismic Qualification of Class 1 Electric Equipment for Nuclear Power Generating Stations."
Form EM-29115 was attached to and was a part of Specification F/L 2891. Section 9.1 of this form requires flame tests be conducted on cables per IEEE 383-1974. Section 11.3 of EM-29115 requires thermal and radiation tests be conducted per IEEE 383-1974 and IEEE 323-1974 The only amendment (1) to Specification F/L 2891 was dated June 27, 1983. This amendment did not revise nor take exception to any of the above listed paragraphs or IEEE Standards.
In accordance with Specification F/L 2891, the subject battery cables are installed at the Byron and Braidwood Stations in conjunction with safety-related diesel driven Auxiliary Feedwater Pumps and Essential Service Makeup Water Pumps. The requirements for these battery cables was re-affirmed in an S&L letter (F. G. Gogliotti) to Steward and Stevenson (S&S) (H. M.
Arbuckle) requesting S&S submit a supplementary proposal for the battery cables. This letter specified that the cables were
Class 1E and must be qualified to IEEE 323-1974. S&S supplementary proposal letter of February 18, 1982, stated that the battery cables would be furnished in accordance with Military Specification M-5086A. S&L letter to S&S, dated February 19, 1982, authorized S&S to proceed with the delivery of the battery cables. A 500' reel of 1/c, #4/0, 600V battery cable was received at Byron Station on MRR 51998 dated June 1, 1982. A S&L letter to the Byron QA Superintendent (CECO),
dated October 11, 1982,' stated that no quality control documentation was required for the material (battery cable)
furnished on MRR 51998. On May 6, 1985, an additional 200'
of battery cable was ordered on Material Services Request 79551 (P0 501632). This additional battery cable was received on MRR 58918, dated June 26, 1985. On October 29, 1985, HECo prepared NCR 1741 to document the lack of adequate documentation for the battery cable received on MRR 58918. The disposition on NCR 1741 states, " CECO MSR 67395 written to change QA requirements on MSR 79551." This change made the battery cables a " Commercial Grade" item. A review of Table 3.11-1 of the Byron /Braidwood FSAR indicates that the applicable items associated with the Auxiliary Feed Water Pumps (diesel driven) would be qualified to IEEE 323. However, the NRC inspector was informed that this information had been revised by a later submittal to the NRC (NRR).
It is the inspector's understanding that FSAR Table 3.11-1 will be revised / deleted based on this later submittal of the Byron /Braidwood Equipment Environmental Qualification Report.
Conclusions: The NRC inspector's review of Project Specification F/L 2891, NCR 1741, applicable Material Receiving Reports, applicable Material Service Requests, and Chapter 3 of the Byron /Braidwood FSAR, verified that " Commercial Grade" battery cables were used in conjunction with the diesel driven Auxiliary Feedwater Pumps. Table 3.11-1 of the FSAR indicates these cables would be qualified to IEEE-323. However, a later submittal of the Byron /Braidwood Equipment Environmental Qualification (EQ) Report revised the information contained in Table 3.11-1 of the FSAR. It is the inspector's understanding that Table 3.11-1 will be revised / deleted based on the latest EQ report.
Pending a review of the revised FSAR (Table 3.11-1 and the applicable paragraphs), this item is unresolved (454/86031-13; 455/86017-13).
b Licensee Actions on Suspected Drug Use Concern: On June 24, 1986, NRC's Region III Office received an allegation that 13 named current or former employees of a known site contractor used drugs at a party attended by the alleger. Additionally, the alleger stated that these individuals used drugs in the Byron Station parking lot during lunch hour.
The contractor performs electrical installation / modification work on Unit 2, which is under construction, and modification work on Unit 1, which is operating.
The NRC's Region III office notified the licensee of the allegation and provided a list of the 13 names.
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Licensee Action:
In keeping with the licensee's established drug awareness program, the current employees (9) were interviewed by Byron Station Management. The nine employees were relieved of all duties, their photo identification security badges and access key-cards were revoked, and access to Byron Station denied pending the outcome of CECO's investigation.
In keeping with CECO procedures, the nine employees provided an observed urine specimen, at a local medical facility, for analysis.
After drug testing, four individuals showed positive results for THC (active ingredient of marijuana) and were subsequently terminated.
The other five individuals were returned to duty after testing showed no evidence of drug usage.
The remaining four named individuals who are no longer employed at Byron Station will be tested for drug usage if and when they are scheduled for re-employment.
In addition to the drug testing, the licensee conducted a search of the electrical contractor's office facilities and the parking lot utilized by construction personnel.
This search was conducted with trained dogs.
No drugs were found during the search.
The four individuals that were terminated had been employed as QC inspectors for the electrical contractor.
The licensee initiated a sample reinspection of these four individuals' work. This reinspection was performed by Pittsburgh Testing Laboratory (PTL) with the following results:
Inspector "A",
99 items reinspected with zcro rejects.
Inspector "B",113 items reinspected with one rejectable attribute
(slag inclusion in a weld). The weld was subsequently repaired.
Inspector "C", 149 items reinspected with zero rejects.
- Inspector "D", 104 items reinspected with zero rejects.
, The one unacceptable seld was considered to be an isolated case.
Conclusions: This allegation was substantiated, in part, in that four of the nine named individuals showed positive results when tested for drugs.
The termination of the four individuals testing positive was in keeping with CECO procedures. The past work of these four individuals was found to be adequate based on a sample reinspection of their work. No violations o deviations were identified.
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6.
Onen-Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involves some action on the part of the NRC or licensee or both. An open item disclosed during this inspection is discussed in Paragraph 5.a(77) of this report.
7.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations.
Unresolved items disclosed during this inspection are disclosed in Paragraphs 5.a(82), 5.a(83), and 5.a(84) of this report.
8.
Meetings with the Licensee a.
During a meeting with licensee personnel in the NRC's Region III Office on July 2, 1986, the findings to date of this special inspection were discussed. As a result of this meeting, the licensee initiated CECO QA Audit 6-86-201 which involved approximately 36 man weeks of audit / inspection effort. This audit resulted in Ceco QA issuing five findings (violations), four observations, and two open items.
b.
During a meeting with licensee personnel in the Region III Office on October 1,1986, the licensee briefed Region III on the results of their investigation of the alleged forged inspection reports. See Paragraph 5.a(76) above for the results of the licensee's investigation.
9.
Exit Interview The Region III inspector met with licensee representatives (denoted under Paragraph 1) at the conclusion of the special inspection on October 22, 1986. The inspector summarized the scope and findings of the inspection and also discussed the likely informational content of the inspection report with regard to documents or processes reviewed during the inspection.
The licensee was also informed that potential enforcement options were being considered.
The licensee acknowledged this information and did not identify any such document or processes as proprietary.
Attachment:
Cross Reference: Violation to Report Detail.
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BYRON STATION-
REPORT NO. 454/86031; 455/86017L Cross Reference:
Violation to Report Details Y
Item Criterion
. Paragraph Violation
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A1 10CFR21 5.a(15)
Failure to impose on site-contractors (U1, U2)
B1 I
5.a(6)
Lack of freedom to verify inspection (U1~, U2)
B2 II 5.a(14).
Failure to indoctrinate / train QA/QC personnel (U1,U2)
,
II 5.a(54)
Failure to assure QA/QC personne1'are properly qualified / certified (U1, U2)
.
B3 III 5.a(11)
Failure to assure that design changes were
approved by original design organizations.
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(U2)
III 5.a(41)
Failure to assure use-as-is dispositions on DRs/NCRs are approved by original design organization. (U2)
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a
B4 V
5.a(15)
Failure to follow procedures-(Unit 1 turnover).
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l (U1)
}
V 5.a(15)
Failure to have a proceduralized system for Byron construction to notify Byron Operations of deficiencies that could i
impact safe operations. (U1)
i V
5.a(51)
Failure to assure that activities affecting quality are accomplished in accordance
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with approved instructions. (U2)
V 5.a(53)
Failure to assure that activities affecting quality are prescribed by documented
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procedures. (U2)
B5 VI 5.a(81)
Failure to assure that activities affecting
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quality are accomplished in accordance with approved procedures (working to verbal / memo instructions). (UI, U2)
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B6 X
5.a(48)
Failure to assure that inspections are
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performed to verify conformance to design
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(inspections not performed per CECO i
directions). (U1)
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B7 XIV 5.a(15)
Failure to establish a system to accurately status inspections to preclude bypassing
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required inspections. (U1, U2)
i B8 XV 5.a(11)
Failure to assure that nonconforming items are reworked in accordance with NCR/DR program. (U2)
'XV 5.a(22)
Failure to control nonconforming items to
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prevent their inadvertent use. (U2)
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l B9 XVI 5.a(15)
Failure to assure that conditions adverse to quality were promptly identified and corrected.(U1)
XVI 5.a(26)
Failure to assure that conditions adverse to quality were promptly identified and corrected.(U2)
XVI 5.a(28)
Failure to assure that corrective action to prevent recurrence is complete prior to closing the NCR. (U2)
XVI 5.a(39)
Failure to assure that conditions adversd to quality were promptly identified and corrected. (U1)
XVI 5.a(41)
Failure to assure that conditions adverse to quality are determined and corrective s
action taken to preclude repetition. (U2)
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XVI 5.a(81)
Failure to assure that conditions adverse to quality were promptly identified and corrected.(U1,U2)
B10 XVII 5.a(47)
Failure to maintain sufficient records to furnish evidence of qualifications of personnel. (UI, U2)