IR 05000456/1982003

Applicant Exhibit A-185,consisting of Forwarding 820630 Safety Insp Repts 50-456/82-03 & 50-457/82-03 on 820524-28 & 0601-04.Violations Noted:Failure of Site Contractors to Follow Procedures

ML20214F127
Person / Time
Site:	Braidwood
Issue date:	11/19/1986
From:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Reed C COMMONWEALTH EDISON CO.
References
OL-A-185, NUDOCS 8705220419
Download: ML20214F127 (13)

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- [ ,,,,, So UNITED STATES f ,, NUCLEAR REGULATORY COMMISSION e CKETED - ,

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Docket No. 50 45s la th asas, d h fd.s ** O Docket No. 50-457 " -

Commonwealth Edison Company ""U

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ATTN: Mr. Cordell Reed WC3D *

lama *=r Vice President

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Post Office Box 767 cesrsorr m //- / f- %

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Chicago, IL 60690 -

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Gentlemen: n porter

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This refers to the special safety inspection conducted by Mr. D. H. Danielson and other staff members of this office on May 24-28, and June 1-4, 1982, of

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activities at B,raidwood Station. Units 1 & 2. authorized by NRC Construction Permits No. CPPR-132 and No. CPPR-133, and to the discussion of our findings with Messrs. W. J. Shewski, R. Cosaro and others of your staff at the con- .

clusion of the inspectio 'the purpose of this special team _ inspection was to assess the adequacy of certain MRects of the quality. assurance / cons, t ruction activities at the Braidwood Statio L The scope of this assessment included audits of quality assurance program inter-

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faces and overview, corrective action systems, design change control, material traceability of installed structures and components, electrical cable Installa-tien, inprocess inspections, and ef fectiveness of quality control inspector Within these areas the inspection consisted of a selective examination of pro-cedures and representative records, observations, and interviews with personne In general, within the areas inspected, the quality assurance program for the Braidwood Station appeared good. However, examples of program implementation deficiencies were identified which require corrective action on your par In addition, certain of your activities appeared to be in noncompliance with NRC requirements, as specified in the enclosed Appendix. A written response is re-quired. No response is required for Item 1.b of the Appendix. The corrective action taken and the corrective action to prevent recurrence is described'in Section 2.b.(11) of the repor ~

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter, the enclosures, and your response to this letter will be placed in the

NRC's Public Document Room. 'If this report contains any information that you (or your contractors) believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by telephone within ten (10) days from the date of this letter of your intention to file a request for withholding; and (b) ' submit within twenty-five (25) days from the date of this letter a written application to this of fice to withhold such informatio ~ .

870S220419 861119 6 kg PDR ADOCK 0500 w* G *

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Commonwealth Edison Company 2 Jijl 1 6 te2

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If your receipt of this letter has been delayed such that less than seven (7)

days are available for your review, please notify this office promptly so that -

a new due date may be established. Consistent with Section 2.790(b)(1), any such, application must be accompanied by an affidavit executed by the ownce of the information which identifies the document or part sought to be withheld,

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and which contains a full statement of the reasons which are the bases for the claim that ths information should be withheld from public disclosur This section further requires the, statement to address with specificity the considerations listed in 10 CFR 2.790(b)(4). The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear from you in this regard within the specified periods noted above, a copy of this letter, the enclosures, and your response to this letter will be placed in the Public Document Roo We will gladly discuss any questions you have concerning this inspectio

Sincerely, 22 iJ

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C. E. Norelius, Director ivision of Engineering and g ,

Technical Programs ,

Enclosures:

1. Appendix, Notice of Violation Inspection Re No. 50-456/8 -03 DETP)

No. 50-457/82-03(DETP)

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REGION III Report Nos. 50-456/84 DETP); 50-457/82-03(DETP) -

b Docket Nos. 50-456; 50-457 License Nos. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company P. O. Box 767 Chicago, IL 60690

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Facility Name: Braidwood St'ation, Unit 1 and 2 Inspection At: Braidwood Site, Braidwood, IL Inspection Conducted: May 24-28, an.1 June 1-4,1982

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Inspectors: D. H. Danielson J. M. Peschel 6hs/

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G. L. McGregor *

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Approved By: D. H. Danielson, Chief Materials and Processes Section Inspection Summary Inspection on Ms? 24-28, and June 1-4, 1982 (Recorts No. 50-456/82-03(DETp);

i 50-457/82-03(DETP))

i Areas Inspected: QA Program interfaces and overview; corrective action systems; design change control; material traceability of installed structures

.and components; electrical cable installation; inprocess inspections; QC inspector effectiveness. The inspection involved a total of 467 inspector-hours onsite by six NRC inspector .

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Results: Of the areas inspected two apparent violations were identified

, (failure of site contractors to follow their procedures - paragraphs b.(11.(b),

( e.(2).(a).3, and e.(2).'(b).i.; failure of site contractors to accomplish activities in accordance with procedures - paragraph f.(2).(a)).

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DETAILS

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Commonwealth Edison Company (Ceco)

• • J. Shewski, Manager Quality Assurance

• D. Cosaro, Project Construction Superintendent

• T. Trams, Nuclear License Administrator

• R. C. Schleiter, Administrative Assistant Construction V. I. Schlosser, Project Manager (Byron and Braidwood)

G. F. Marcus, Director of Quality Assurance (Engineering and Construction)

• T. R. Sommerfield, QA Superintendent R. M. Sacco, Engineering Technician

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R. C. Tate, QA Engineer

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S. M. Jaques, QA Engineer i V. D. Bruns, QA Engineer D. C. Boes, QA Engineer S. A. Reece, QA Engineer R. D. Pickell, QA Engineer

• C, D. Gray, Project Construction Structural Supervisor

• Merwin, Project Construction Mechanical Supervisor .

J. Hoffman, Project Construction Department D. Hoffer, QA Engineer M. Togliatti, Project Construction Department R. Vignocchi, QA Inspector -

4, - J. Natisotto, Field Engineer

• C. A. 'Mennecke, Project Construction Electrical Supervisor B. H. Kulik, QA Inspector (Documentation)

J. Galligan, Instrument Engineer E. A. Kram, QA Engineer

• L. J. Tapella. Electrical Field Engineer

• D. A. Brown, QA Supervisor j *S. C. Hunsader, QA Supervisor #

M. A. Gorski, QA Engineer K. Miller, QA Inspector l

Phillips. Getschow Company (PGCo)

A. Rubino, Quality Control Supervisor l E. Ullrich, Assistant Quality Control Supervisor R. Cronkite, Calibration Technician A. Rohla, Training and Procedures Coordinator

R. Veronda Engineering Clerk

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G. Jenkins, Draftsman J. Matrisotto, Field Engineer D. Ortiz, Area Foreman l

G. Balzer, General Foreman l

J. Ryder, Document Control Technician

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J. Devine Instrument Superintendent C. Johnson, Engineer S. Goryl, Field Engineer *

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L. K. Coastock and Company Inc. (LKC)

R. A. Brown, QC Manager C. Stiles, QA Engineer J. Hii, QC Inspector ~

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J. Peters, QC Inspector .

F. Rolan, QC Inspector -

.T. Rolan, QC Clerk R. Martens, Cable Engineer

- M. Kost, QC Supervisor Pittsburgh Testinz Laboratory (PTL)

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• L.'E. Smetana, Site Manager ,

S. L. Bank, Site Auditor Vestinghouse (V)

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R. Schultz, Site Manager Sarzent and Lundy Enzineers (S&L)

C. A. Zalesisk Field Engineer -

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Napoleon Steel Contractors. Inc. (NSC)

C. Zavada, QC Manager

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, Pullman Construction Industries, Inc. (PCI)

D. Grant, QA Manager

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Nuclear Insta11stien Services Company (NISCo)

J. Pruitt, QA Manager J

Pittsburnh-Des Moines Steel Company (PDM)

D. Pint, QA Manager H'artford Steam Boiler Engineering and Insurance Company (HSB)

L. Parkey, Authorized Nuclear Inspector

• Denotes those personnel attending the exit meeting held at the Braidwcod Site on June 4,1981. During the inspection at the Braidwood Station exit meetings were held on Wednesday and Friday in order to keep the licensee infor=ed of any finding The inspectors also contacted and interviewed other licensee and contractor personnel during this inspectio ,

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( General Backatound

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The purpose of this special tfas ins tion was to determine if

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there are indications of existing or potential construction ,

. problems similar to some of those identified at a number of other plants under construction. The scope of the assessments included

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quality assurance program interfaces and overviews, corrective action systems, design change control, material traceability of installed structures and components, electrical cable installa-tion, inprocess inspections, and effectiveness of quality control

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Prepared By: G. L. McGregor

\ Q.C. Inspector Effectiveness L

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(1) Obiectiv .

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The objectives of this assessment were to determine if:

(a) any problems exist that inhibit an inspector from properly

executing his assigned function (b) the' training, qualifications, and certification of QA/QC personnel working for contracting organizations to the

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Licensee are in compliance with 10 CFR 50r Appendix B, i ANSI N45.2.6 1978, ANSI SNT-TC-1A, USNRC Regulatory

,, Guides 1.58, USNRC Generic' Letter 81-01; Ceco Quality Assurance Program Manuals, Ceco Response to Generic

, . Letter 81-01 (L. D. De1 George to D. G. Eisenhut - -

August 17, 1981); and Contractor Qua,11ty Assurance Manual *

(2) Discussion

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The individuals selected for interview were chosen at random .

by the NRC Inspector from QA/QC inspector lists furnished by each contracto All contractors utilizing QA/QC personnel to monitor and accept

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,~ production activities at the site were selected. The organi-sations selected, production function monitored by the in-spectors, number of inspectors in the organization, number

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of inspectors interviewed and percentages are identified in Table I. Each inspector interviewed was asked a standard set of questions. The answers provided were summarized and are provided as Table I The individuals selected for interview were requested to provide the record of their training, qualification and certification to the NRC inspector. The inspector reviewed each of the training, qualifications and certification records to verify compliance with applicable regulatory requirements, standards and FSAR commitments. In verifying the implementation of the approved requirements emphasis was placed on (1) evaluation of performance / reevaluation; (2) de-termination of initial capability by suitable evaluation; (3) physical requirements identified and examined yearly; (4) written certification in appropriate form; (5) records of qualification established and maintained; and (6) quali-fication criteria followe Table II is provided as a summary of QC/QC inspector answers to the standard set of interview questions. Answers to <

questions 1, 2, 4, and 5 are self-evident and do not require further definition .

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• Question 3 relates to the number of inspectors that indicated during their answers to question 2 that they had prior inspec-

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g tion experience. Of the 46 inspectors, 78% indicated prior nuclear inspection experience; only 17% no nuclear experience;

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and 4% had no inspector experienc . .

Question 6: All inspectors answered with a resounding No or very few hours per week. When asked to qualify "very

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few hours", the inspectors replied two to three hours with

, , a maximum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in any wee Questions 7 and 8: The inspectors indicated that an insufficent number of QC inspectors cont.ributed to work being backlogge *

Concrete expansion anchors, some small bore pipe welding, and -

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cable paa supports were indicated as areas which need extra

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inspection effort One inspector noted that radiographs with questionable indica-

'tions were being approved by contractor QC personnel or addi-tional radiographs were being taken. Specific examples were

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given. The RIII inspector reviewed the radiographs for the examples given, as well as for several adjacent veld joint *

No ASME Code unacceptable indications were identifie .

Question 9: 'Ihe inspectors generally feel they have the authority to stop an activity if their contractor's work is not being properly performe A Question 10: The majority of inspectors interviewed indicated that the training they received was adequate for the work activity they are required to perform. The majority of in-spectors indicated they would welcoes additional trainin Question 11: The inspectors do not feel that a lack of i inspection personnel has caused construction activities to j come to a sto *

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Question 12: All inspectors indicated that their activity did not require additional checklist data sheets or guide-lines. One inspector felt that the welding production foreman should sign the completed work form before turnover to the QC department for inspectio Question 13: All inspectors indicated they have no problems going to chair management, regardless of the position, to communicate their problem Open Item (456/82-03--06: 457/82-03-06)

Based on the interview of inspectors, it is apparent that

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some areas are in need of additional inspectors to ensure

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that a backlog of inspection'a does not exist and that in-creasedworkeffortsdonotcombundtheinspectionprogra .

I No items of noncompliance or deviations were identifie '

" Unresolved Items

. Unresolved items are matters about which more information is required in order to ascertain weather they are acceptable items, violations, or

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deviations. Unresolved items disclosed during this inspection are dis-

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cussed in Paragraph f.(2).(c).h

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• Exit Interview l

The inspectors set with licensee personnel (denoted in Paragraph 1)

at the conclusion of the inspection on June 4, 1982. The inspectors summarized the scope and findings of the special inspection, which were

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acknowledged by the license ,

Attachments:

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. Table I, QC/QA Inspection Interview Summary -

Table II, Summary of Questions

Asked QC/QA Inspectors i During Interviews

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. THE I QA/QC INSPECTOR INTERVIEW SUMMARY

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Ornanization Function Inspectors Interviewed  %

G. K. Newberg General Contractor 1 1 100 Concrete and Labor Force NISCO Erection NSSS Equipment 2 1 50 Wallgren Concrete Block Wall 2 1 50 Erection Napoleon Containment Tendon 5 3 60 Installation

Midway Field Finish Coatings 1 1 100

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Pullaan HVAC 2 2 00 ,

Pittsburgh Independent Inspection 22 13 59 i

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Testing Lab (PTL) ANL Testing, NDT and

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L. K. Coastock Electrical 20 9 45 Phillips, Piping Systems 23 14 61 Getschow

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( TABLE II

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SUMMARY OF QUESTIONS ASKED QC/QA INSPECTORS DURING INTERVIEWS

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How long esployed as an inspector onsite? 0

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1 7 1-2'v y >3 y >5 yr *

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Years Yes No

. Prior inspection experience? <1 1 2 1-2 10

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Nuclear Non-Nuclear l

, Au What discipline (s)? 37 8

[ Yes No

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Comments

. Is there a sense of intimidation 44 based upon the need/ requirement to keep up with construction? Is there a reluctance to make 44 *

adverse findir.as if they will impact on the construction or audit schedule? Is it routine for QC inspectors 45

.to be working frequent and/or excessive overtime? . . .

l Do the inspectors feel that their '22 22 ' Need more

, particular section is adequately inspectors for

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staffed? welding and con-crete expansion

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S Yes No Comments Do they feel the required inspec- 32 10 Backlog for k- tions are being conducted promptly?

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and/or stop procesa authority? *

. Have they ever ussd this authority? 33 1

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If so do they feel they were supported 33 or will have the' support of manage-ment in the event of a stop work? ,

1 Do the inspectors feel the training 40 4 More formal they have been provised is adequate? classroom training for General Fore-men and -

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Foresen 1 Do situations arise where the lack 43 of A QC inspector causes construction *

activities to coes to a stop?

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12. Are the QC inspectors provided 43 adequate check lists for all

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activities they are inspecting?

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13. Do they feel that they have an, 43

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synnue to management if they come across a probles?

D9 'they feel manassent will get 43 lepolved?

, The totals for the questions differ because of the type of inspectocs inter-viewed and the inspector replies to the various question .

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