IR 05000456/1983009
| ML20137T311 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 02/13/1986 |
| From: | Paperiello C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 8602180311 | |
| Download: ML20137T311 (3) | |
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FEB 131986 Docket No. 50-456-Docket No. 50-457
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Comonwealth Edison Company ATTN: Mr. Cordell Reed-Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen; This is in response to your letters dated July 6, July 23, and August 31, 1984,
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and March 11, March 27, and April 25, 1985, in response to our Inspection Report Nos. 50-456/83-09 and 50-457/83-09. We have completed our evaluaticn of your answers to the violations and other matters to which you responded and find that collectively your responses are acceptable.
Regarding violation Items 1.c, 3.a 3.b, 3.c, 4.d, and 6.a your respcnses indicate that you do not-believe them to be violations. With the exception of Item 4.d, we continue to believe those items are violations. We offer the following bases for our conclusions:
Item 1.c We do not agree that the " accept as is" disposition of NCR BR-08 was adequate.
It is our position that any weld for which the welder is unknown is unacceptable and must be replaced. Your corrective acticn comitment to remove and replace any weld for which the welder identification cannot be established will acceptably resolve this issue.
-Item 3.a The many welding procedure variables coupled with t'he lack of documentation and the limited verification activities by QC personnel led us to conclude that your welding controls were inadequate. We believe those inadequate controls may have contributed to the numerous deficient conditions identified by you in 1982-1983 which led to your 100% reinspection effort in this area..
We believe your corrective actions since our inspection have resulted in your present welding controls being acceptable. Your HVAC Weld Testing Program will provide us with adequate confidence regarding the quality of work completed under the previous welding controls.
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FED 131986 Iten 3.b Since not all welds could be properly inspected for fit-up after ~ welding, it is clear that your controls should have required examinations for fit-up rior to welding to comply with AWS D1.1-1977. Additionally, your procedure p(B10.2.F) was deficient in that it failed to specifically require a check for increased fillet size when a 1/I6" to 3/16" fillet weld gap existed. These welding control deficiencies led us to conclude that your centrols for thest.
matters were inadequate. However, your corrective actions since our inspection have resulted in your present controls being acceptable.
Your resolution of the NCR concerning lack of fit-up inspection, the results of your 100%
reinspection program, and your HVAC Weld Testing Program will previde us with adequate conridence regarding the quality of work completed under the previous fit-up controls.
This item was closed in Inspection Report Nos. 50-456/85050 and 50-457/85048.
Item 3.c The lack of a program requirement for the examination of base metals for surface and edge discontinuities did not comply with AWS D1.1-1977. Your revision of procedure B10.2.F corrects that program deficiency. After reviewing the specific applications of the prior procedure, we believe that it is unnecessary for you to review past work for evidence of
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discontinuities. This item was closed in Inspection Report Nos. 50-456/85040 and 50-457/85039.
Item 4.d We agree that the conduct of your audits relative to the coninencen;ent of support selection activities was not untimely and indicative of an inadequate -
audit program in that area. Therefore, we retract this item as an example of the violation and will correct our records accordingly. Your followup audits since our inspection and your corx11tment to continue to monitor this activity assure that similar support selection problems do not recur.
Item 6.a It continues to be.our view that the Phillips-Getschow Company small bore piping and piping suspension system site activities involving field routing of piping' calculation of restraint loads, and selection of restraint types
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based on calculated loads have the ability to effect the quality of the final design. Therefore, we believe the violation to be proper as written.
We find the program revisions you instituted in response to our findings to be adequate to correct past deficiencies and to prevent the recurrence of future problems in this area.
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We 'will ~ examine your corrective actions during future inspections.
Sincerely,
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g Carl J.
aperie 10, Director Division of Reactor Safety cc:
D. L. Farrar, Director of Nuclear Licensing M. Wallace, Project Manager D. Shamblin, Construction-Superintendent E. E. Fitzpatrick, Station Superintendent C. W. Schroeder, Licensing and, Compliance Superintendent cc w/1trs dtd 07/06/84,07/23/84, 08/31/84,.03/11/85,03/27/85,.
and 04/25/85:
DCS/RSB (RIDS)-
Licensing Fee Management Branch
- Resident Inspector, RIII Braidwood Resident Inspector, RIII Byron Phyllis Dunton, Attorney General's Office, Environmental Control Division D. W. ' Cassel, Jr., Esq.
J. W. McCaffrey, Chief, Public Utilities Division H. S. Taylor, Quality Assurance Division E. Chan, ELD J. Moore, ELD G. Berry, ELD J. Stevens, NRR'
The Honorable-Herbert Grossman, ASLB The Honorable A. Dixon Callihan, ASLB The Honorable Richard F. Cole, ASLB
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Mr._ James G. Keppler, Regional Administratcr U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 Subject: ;Braidwood Station Units 1 & 2 Revision to Inspection Report 83-09 Response NRC Docket Nos. 50-456 and 50-457 Reference ~(a):
J. letter to Cordell Reed dated May 7, 1984.
(b):
L. O. De1 George letter to J. dated July 6, 1984.
(c):
D. H. Smith letter to J. dated March 11, 1985.
.(d):
D. H. Smith letter to J. dated March 27, 1985.
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Dear Mr. Keppler:
g References (c) and (d) submitted to NRC for review
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Commonwealth Edison's proposed HVAC Weld Testing Program which should demonstrate positive confirmation of HVAC weld adequacy.
Successful completion of this test program would also provide the NRC with sufficient additional confidence in the installed quality of welds and allow closure of'certain HVAC weld issues.
The
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attachment to this letter provides current status and a revision to the Reference (c) resconse of the " Unknown Welder" issue j
(456-457/84-09-07B) identified in Reference (a).
i If you have any questions concerning this matter, please contact this office.
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mith Nuclear Licensing Administrator
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NRC Resident Inspector-Braidwood l
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ATTACHMENT
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Supplemental Response to i
Inspection Report 456/83-09 and 457/83-09 Item 456/83-09-07B and 457/83-09-07B
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t Notice of Violation Item Ic
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Commonwealth Edison's Reference (b) response identified actions to be taken to resolve the issue of unstamped HVAC welds.
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included direction from Commonwealth Edison to Pullman Sheet Metal
.to either establish welder identification by in place physical marking or by other production or quality type records, or to
replace the welds, if no welder identification can,be established.
The HVAC Weld Test Program delineated in References (c) and (d),
will include welds from locations for which welder identification can not be verified.
Successful completion of this test program will provide additional confidence in the quality of installed welds where welder identification can not be established by in place physical markings or by other production or quality type records.
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The 53 welds identified in Reference (a) where welder identification can not be established will be replaced if welder
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identification can not be established by in place physical markings,
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production records or quality records.
Following is the current j-status of identification of these 53 welds:
29 - Welder ID found or determined by
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Production or Quality Records.
g 6 - Weld removed.
2 - Component removed.
l 16 - Welder ID currently not known.
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O,5 Adoress Reply c: Post Office Boa 767 sj" checago, maois 60690
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March 27, 1985
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I Mr. James G. Keppler, Regional Administrator U.S. Nuclear Regulatory Commission
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Region III 799 Roosevelt Road Glen Ellyn, IL 60137 Subject:
Braidwood Nuclear Power Station Units 1 & 2 Revision to Inspection Report 83-09 Response NRC Docket Nos. 50-456 and 50-457 Reference (a):
D. H. Smith letter to J. dated March 11, 1985
Dear Mr. Keppler:
Reference (a), submitted for NRC review, is Commonwealth Edison Company's proposed HVAC Weld Testing Program which should demonstrate positive confirmation of weld adequacy.
The specifics of the program were discussed with Mr. John Jacobson of your staff on February 26, 1985 and revisions were made based on thls discussion.
The NRC has reviewed the submitted program and requested a change to Item D.l.
In lieu of NRC * sign-off for acceptance" of sample selection and test results.the program now cites a " review for acceptability".
The new Item D.1 reads as follows:
D.
NRC Concurrence The assigned NRC Inspector will review for acceptability 1s.
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sample selection and test results on an as-completed bas A copy of the HVAC Weld Testing Program is attached.
If you have any questions concerning this matter, please contact this office.
y { truly yours, David H. Smith Nuclear Licensing Administrator bs cc:
NRC Resident Intpector - Braidwood 9930N MAR 2 91985
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ATTACHMENT HVAC WELD TESTING PROGRAM
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A.
Sample Selection Criteria
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Sample size will be a minimum of 75 safety related field inspected and accepted welds made prior to September 15, 1983.
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Each of the following types of welds will be included in the sample population:-
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a.
Welds that were considered acceptable without rework during the 100% reinspection effort.
b.
Welds made by welders having high reject rates.
c.
Welds that have troublesome weld configurations or special weld configurations, d.
Welds for which fitup can not be determined after welding, including angle splices, e.
Multi-pass welds.
f.
Welds from among the highly stressed connections.
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Welds made from all processes other than the silicon-bronze process (the silicon-bronze process will be addressed separately).
h.
Sheet to sheet welds j.
Structure to structure welds.
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3.
In some cases, multiple welds may be selected from a single component, provided the other selection criteria are met.
4.
In son.e cases, welds will be selected from locations for which welder identification can not be verified.
This data will be utilized to add confidence to the acceptability of welds of this type.
5.
In some cases, welds will be selected which had minor l
defects that had been accepted-as-is by the Architect / Engineer.
This data will be utilized to add confidence to the acceptability of welds of this type.
6.
If only a portion of a specific weld is tested, it will be confirmed that the sample is representative of the entire veld.
B.
Testing
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Testing will be performed which is appropriate for the nature of each weld sample, such as a tensile test, micro-etching, bend test, non-destructive examination, etc.
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Testing for a portion of the sample population may be accomplished by static loading of an assembly to equivalent design loads.
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Acceptance Criteria 1.
Acceptance criteria for each weld tested will be based on design requirements.
D.
NRC Concurrence
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The assigned NRC Inspector will review for acceptability, sample selection and test results on an as-completed basis.
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h-b) , . . Commonw.alth Edison - - - One Ferst Nationaal Plaza. Chicago, litanois Address Reply to: Post Office Box 767 Chicago, Ilknois 60690 March 11, 1985 Mr. James G. Keppler, Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 Subject: Braidwood Nuclear Power Station Units 1 & 2 Revision to Inspection Report 83-09 Response NRC Docket Nos. 50-456 and 50-457 Reference (a): J. letter to Cordell Reed dated May 7, 1984.
(b): L. O. De1 George letter to J. dated July 16, 1984.
(c): E. D. Swartz letter to J. dated July 23, 1984 (d): E. D. Swartz letter to J. dated August 31, 1984
Dear Mr. Keppler,
On February 20, 1985, M. J. Wallace, et al., of Commonwealth Edison Company met with Mr. John Streeter,)et al. of your staff to discuss our response in References (b), (c, and (d) to your Inspection Report, Reference (a), regarding HVAC weld concerns.
. During that meeting, we reiterated our position that there is adequate assurance of the quality of installed HVAC welds.
The NRC, however, stated the position that we be required to demonstrate positive confirmation of the adequacy of the welds through a limited sample test program.
Commonwealth Edison Company, therefore, has developed a proposed HVAC Weld Testing Program which is described in Attachment A.
This program will: 1.
Confirm that a final visual inspection for AWS welding is adequate to establish quality of the work; and thus MAR 14 585 eve n a r ~ ~# ' o JIIwv'TJ. ,
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Provide the additional assurance desired by the NRC that the installed HVAC welds are adequate.
It is our understanding that successful completion of this test program will provide the NRC with sufficient additional confidence in the installed quality of welds and allow closure of the following issues: 83-09-078 Unknown Welders 83-09-10A HVAC Weld Quality, including multi-pass welds 83-09-10B Fitup Inspection 83-09-10C Base Metal Inspection The specifics of this proposed HVAC Weld Testing Program were reviewed with Mr. John Jacobson of your staff on February 26, 1985.
Attachments B & C contain revisions to our Reference (b) and (d) responses to identify the HVAC Weld Testing Program as corrective action for specific items.
Attachment D contains revisions to our Reference (b) response outlining the sample program to provide additional assurance of correct material installation for class H instrument piping installed prior to February, 1984.
If you have any questions concerning this matter, please contact this office.
Ver truly ' urs, AA 4 David H. Smith Nuclear Licensing Administrator cc: NRC Resident Inspector - Braidwood
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. . ATTACHMENT A HVAC WELD TESTING PROGRAM A.
Sample Selection Criteria 1.
Sample size will be a minimum of 75 safety related field inspected and accepted welds made prior to September 15, 1983.
2.
Each of the following types of welds will be included in the sample population: a.
Welds that were considered acceptable without rework during the 100% reinspection effort.
b.
Welds made by welders having high reject rates.
c.
Welds that have troublesome weld configurations or special weld configurations.
d.
Welds for which fitup can not be determined after welding, including angle splices.
e.
Multi-pass welds.
f.
Welds from among the highly stressed connections.
g.
Welds made from all processes other than the silicon-bronze process (the silicon-bronze process will be addressed separately).
h.
Sheet to sheet welds.
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Sheet to structure welds.
J.
Structure to structure welds.
3.
In some cases, multiple welds may be selected from a single component, provided the other selection criteria are met.
4.
In some cases, welds will be selected from locations for which welder identification can not be verified.
This data will be utilized to add confidence to the acceptability of welds of this type.
5.
In some cases, welds will be selected which had minor defects that had been accepted-as-is by the Architect / Engineer.
This data will be utilized to add confidence to the acceptability of welds of this type.
6.
If only a portion of a specific weld is tested, it will be confirmed that the sample is representative of the entire weld.
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Testing 1.
Testing will be performed which is appropriate for the nature of each weld sample, such as a tensile test, micro-etching, bend test, non-destructive examination, etc.
2.
Testing for a portion of the sample population may be accomplished by static loading of an assembly to equivalent design loads.
C.
Acceptance Criteria 1.
Acceptance criteria for each weld tested will be based on design requirements.
D.
NRC Concurrence 1.
The NRC Inspector assigned to review sample selection and the testing program will sign off acceptance of samples selected and test results on an as-completed basis.
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. . ATTACHMENT B Supplemental Response to Inspection Report 456/83-09 and 457/83-09 Item 456/83-09-078 and 457/83-09-078 Notice of Violation Item Ic Commonwealth Edison's Reference (b) response identified actions to be taken to resolve the issue of unstamped HVAC welds.
This included direction from Commonwealth Edison to Pullman Sheet Metal to either establish welder identification by in place physical markings or by other production or quality type records, or to replace the welds, if no welder identification can be established.
The HVAC Weld Test Program delineated in Attachment A, will include welds from locations for which welder identification can not be verified.
Successful completion of this test program will provide sufficient additional confidence in the quality of installed welds where welder identification can not be established by in place physical markings or by other production or quality type records.
This test program will be completed in lieu of replacing welds described in our Reference (b) response.
- ' . . . ATTACHNENT C Supplemental Response to Inspection Report 456/83-09 and 457/83-09 Item 456/83-09-10A and 457/83-09-10A Notice of Violation Item 3a Commonwealth Edison's Reference (d) response outlined a review in the area of multipass welding to be performed in addition to the final visual inspection of the completed welds.
This review was to identify welders with a high rejection rate and then identify the hangers that were welded by these identified welders.
These hangers would be reviewed to identify the existence of any multipass welds which would then be magnetic particle inspected to provide additional assurance beyond the final visual examination as to the acceptable quelity of the completed welds.
The HVAC Weld Testing Program delineated in Attachment A calls for-the testing of multipass welds.
Successful completion of this program will provide sufficient additional confidence in the quellty of installed welds.
This test prog am will be completed in lieu of the review identified in R3ference (d).
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.. ATTACHMENT D Supplemental Response to Inspection Report 456/83-09 and 457/83-09 Item 456/83-09-07A and 457/83-09-07A Notice of Violation Item la Phillips Getschow Company established improved procedural controls fcr the Q.C. inspection and verification of safety related (class H) instrument piping materials in February, 1984.
These requirements are in procedure PGCP-30, Rev. 7.
The Region III Inspector identified a concern that PGCP-30 did not explicitly require the Q.C. inspector to compare the installed materials that were too small to be physically marked against the Stores Request.
In order to clarify this point, Supplement I was written to PGCP-30.
In order to provide additional confidence in the Stores Request documentation of class H instrument piping materials .' for work performed prior to February 1984, Phillips Getschow will develop a procedure similar to the Material Traceability Verification Program.
This procedure will require field verification by Quality Control of installed class H instrument materials on a sampling basis.
The installed materials will be verified against the Stores Raquest documentation and the bill of materials listed on the isometric drawing.
This procedure will be submitted to Commonwealth Edison Company for approval by April 4, 1985.
The installed material verification will be performed on a . random sample of class H instrument isometrics installed prior ' to February, 1984.
The random sample will be selected in accordance with Military Standard MIL-STD-105D.
It is anticipated that the field verifications will be completed by July 1, 1985.
As part of the field verifications, materials which do not have unique markings traceable to the Stores ~ Requisition and drawing will have digital thickness measurements or mechanical measurements taken to establish the ' schedule of the material.
The data from the field verification sample will be reviewed and a final report put together by August 30, 1985.
The final report will compare the installed material against the design requirements, the isometric bill of material and the Stores Request.
Installed material quantities will be compared against Stores Request quantities also.
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As part of final document review, Phillips Getschow Q.C. has been comparing the materials listed on the Stores Request against the materials listed on the isometric bill of material for class H instruments.
Any discrepancies noted during this review are brought to the attention of the Phillips Getschow . Engineering Department for resolution.
This process however, has not been fully delineated in a procedure.
Phillips Getschow will incorporate this process into a final document review checklist.
This checklist will be prepared by April 1, 1985, in accordance with Phillips Getschow procedure QPC-830.
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, n Common.. alth Edison " / One First National Ptr, Chicago, literos
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- Address Reply to. Post Ottice Box 767
- - Chicago, lihnois 60690 ' , August 31, 1984
% MrJ James ' Regional Administrator U.S. te; clear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Il 60137 . Subject: Braidwood Station Units 1 and 2 SupplementaLBgsponse to Inspection Report No. 50-456 23-09; M 457/83-09 NRC Docket Nos. 50-456 and 50-457 References (a): L. O. DelGeorge letter to J. dated July 6, 1984 (b): E. C. Swartz letter to J. dated July 23, 1984 (c): J. letter to J. J. O'Connor dated Hiy 7, 1984
Dear Mr. Keppler:
References (a) and (b) provided the Commonwealth Edison Company response to the Reference (c) Inspection Report tbnber 50-456/83-09; 50-457/83-09 concerning our Braidwood Station. The purpose of this letter is to provide a supplement to our Reference (a) response to Non-Compliance Items 2c, 3a and 3c.
. For your convenience, this information is provided in the form of supplemental pages numbered 13a, 22a, 22b and 26a to our Reference (a) response.
' c rs,. d la a toclear Licensing Adninistrator Attachment cc: RIII Inspector - Braidwood
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9130N
I o . . . Revision 2 dated August 31, 1984 13a -
- L Response to Item 2c (cont'd) ~ . SLPPLEEEAL RESPONSE , In order to provide additional assurance that piping bends meet the ovality requirements, a statistical sample of the small bore process piping bends will be performed by the Phillips, Getschow Company. A list will be developed for the safety related 2 inch and under process piping isometrics which have been "as-constructed" and which contain piping bends. From this list, a random sample will be selected and a documented QC inspection of the selected isometrics will be performed. This inspection will entail measuring the ovality of endi piping bend, and also measuring the wall thickness of the pipe on the outer face of the bend. Acceptability of the piping bends will be based on the criteria set forth in the Phillips, Getschow Company Procedure PGCP-ll and the allowable minimum wall thickness for the schedule of pipe being inspected.
This sample is expected to be completed by January 7, 1985.
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. . . Revision 2 dated August 31, 1984 _ _ i Response to Item 3a (cont'd) . StPPLEENTAL RESPONSE Filler Metal Control
Althoufi there is no documented evidence as t'o which type of filler metal was utilized on each component, we believe the existing welds are acceptable based on the following: A.
All of the carbon steel electrodes on the Braidwood site have a tensile strength of 70 ksi or greater. The only non-70 series electrodes purchased were two heats of E-6013 electrode. However, the Certified Material Test Reports for these two heats of E-6013 electrode indicate that each has a tensile strength greater than 70 ksi.
B.
A review of the Braidwood site records indicates that the following quantities of welding materials were purchased for the Pullman Sheet Metal work.
TYPE OF FILLER ETAL QUANTITY E-7018 12,875# E-6013 1,350# ER705-2 & E7-T-GS Wire 4,130 # RCuSI-A 750# E-308 & E-309 575# ER-308 & ER-309 1,780# The E-7018 filler metal constitutes over twice the amount of all the other welding electrodes on site. This is consistent with the Pullman Sheet Metal work scope because the hangers, braces, and auxiliary steel comprises 40% of the welding.
C.
Any misuse of silicon bronze filler metal would have been reported in the results of the visual weld inspection performed on all welds. Silicon bronze welds have a distinct gold color.
No cases were identified where this material was being used for the wrong application.
D.
The only other type of filler metal available to th'e welders was E-308 and E-309. This material does not produce a weld which is visually distinct from a E-7018 weld, and therefore the visual inspectlon program wnuld not identify this condition. Although we believe the inadvertant use of stainless filler material on a carbon steel component is unlikely, a statistical sample . .
- . - .- _. . r . . s Revision 2 dated August 31, 1984 22b - ( - L Response to Item 3a (cont'd) . , inspection was performed on the existing duct hangers to
address this concern. The sample (which included hanger, auxiliary steel, and brace welds) was inspected for the presence of stainless filler metal using a magnet. No evidence of stainless steel filler metal was found in the sample.
' Multipass Welding In order to provide additional assurance in the area of multipass welding, the following review will be performed in addition to the final visual inspection of the completed welds: A.
Pullman Sheet Metal will perform a review of the Correction Notices generated prior to the implementation of in-process welding inspections in order to identify welders with a high i rejection rate.
B.
Pullman Sheet Metal will identify the hangers that were i welded by the identified welders with high rejection rates.
C.
These hangers.will be reviewed to identify the existence of any multipass welds.
D.
The identified multipass welds will then be magnetic particle
inspected to provide add'tional assurance beyond the final visual examination as to the acceptable quality of the completed welds.
! This sample program of multipass welds is expected to be completed ' by January 7, 1985.
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i O Revision 2 dated August 31, 1984 - 26a - g L Response to Item 3c (cont'd) - . . SLPPLEENTAL RErPONSE Inspection of base metal conditions during fit-up is currently performed during fit-up inspections. However,-the procedure governing this visual weld inspection activity does not specifically identify surface and edge discontinuities as'an attribute of the inspection.
In order to provide additional confidence in the inspection program, Pullman Sheet Metal Procedure B10.2.F " Visual Weld Inspection", Section IV.C.1, will be revised to formally include checking for surface and edge discontinuities during fit-up.
This procedure revision is expected to be completed by October 31, 1984.
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' ' CT Commonwealth Edison _ > one First National Plan Crucago Illinois g ~~~~ jr Address Reply to Post Othee Box 767 yy, Chicago, liknois 60690 July 23, 1984 Mr. James Regional Administrator U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 Subject: Braidwood Station Units 1 and 2 Supplemental Response to Inspection Report , Nos. 50-456/83-09 and 50-457/83-09 NRC Docket Nos. 50-456 and 50-457 References (a): L. O. De1 George letter to J. ' dated July 6, 1984 (b): J. letter to J. J. O'Connor dated May 7, 1984
Dear Mr. Keppler:
Reference (a) provided the Commonwealth Edison Company response to the Reference (b) Inspection Report Number 50-456/83-09; 50-457/83-09 concerning our Braidwood Station.
The purpose of this letter is to provide a supplemental response to Non-Compliance Item 3b.
As stated in our Reference (a) response to Non-Compliance Item 3b, Commonwealth Edison intends to prepare an NCR to disposition the lack of fit-up inspection on certain welds.
During our review and evaluation to determine the scope of this NCR, we discovered that certain of the information provided in our Reference (a) response to Item 3b requires a revision.
Enclosed is a supplemental response to Non-Compliance Item 3b in the form of a revised Page 23 to Reference (a).
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very truly yours,( i _, [g E. Douglas Swaf z [ Nuclear Licensing Administrator
Attachment
cc: RIII Inspector - Braidwood f i 9009N ' i 30\\. -
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g , -a, - Revision 1 dated July 23, 1984- -23-Response td Item 3b ESPl>SE ' Refer to.the discussion under Item 3a.
Additionally, over 905 of all the HVAC welds can be inspected for fit-up'arter the weld is completed.. Althou@ B10.2.F did not specifically require a check for the increased fillet size (when a 1/16".to 3/16" gap exists), all of the Pullman Sheet Metal Quality Control inspectors had been instructed in the AWS Code requirements and were aware of this requirement.
CORECTIVE ACTION TAKEN AND RESLLTS ACHIEVED i _Approximately eleven duct hangers include welds which cannot be fit-up inspected after weld completion. Two of these contain welds which were completed prior to the below stated procedure change to check full penetration fit-up prior to welding. An NCR will be written to request an engineering disposition of the lack of fit-up inspection on these welds. Equipment bases and gallery support standard details have some welds which cannot be checked - for fit-up after welding completion. Fan bases for IVXO7C and 2VXO7C have four (4) all around welds per base, and gallery supports for IVX01F, IVXO3F, IVXO4F, IVE0lf, 2VX01F, 2VX03F, 2VXO4F, and 2VE01F have all around welds of 4 x 4 x 3/8" angle to . plates or structural steel.
The all around welds on the fan bases were shop welded and not field welded. Pullman performs full.
dimensional checks on all cut mesbers (i.e. members are saw cut squarely and checked to verify this). It would not be possible i ' for squarely cut members welded together in the shop to be fit-up ! -with a gap exceeding 1/16". The eight gallery supports are not i installed. Commonwealth Edison Company believes the programmatic i controls stated above were adequate to ensure correct fit-up of these welds.
' ! Angle splice alternate details are the only other items which cannot be checked for fit-up after weld conpletion. These full penetration welds are either square butt or bevel type welds. Any fit-up ! -
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problems could be corrected by addition of filler metal to attain ! .the proper fit-up gaps. During the 100% weld reinspection program described below, these welds were inspected for evidence of improper > fit-up. All welds were deemed acceptable.
{ Beyond that described above, Pullman Sheet Metal has reinspected . 100% of all other accessible welds previously made. During this inspection program, improper fit-up was specifically inspected for, and items if found, were identified on Correction Notices. All reinspection was performed utilizing Sergent and Lundy supplied AWS j.
acceptance criteria.- ~ - .. - -. .. -. _ _ _ _ _, _ - _ _
. - Sb 1)36- / t Commoni dth Edison - [. ) One Fust Nahv.A Ptara. Chicarjo. 6thnoes hd [ - , \\t C /* Address Reply to Post Office Box 767 (j ' Chicago, llimois 60690 . July 6, 1984 ( Mr. James Regional Administrator - Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 , Subject: tation Units 1 and 2 Response pection Report Nos.
50-45 d 50-457/83-09 NRC s. 50-456 and 50-457 Reference (a): J. letter to J. J. O'Connor dated May 7, 1984
Dear Mr. Keppler:
This letter is provided in response to the inspection conducted by Messrs. T. E. Vandel, R. O. Schulz, I. T. Yin, D. E. Keating, C. C.
Williams, and D. R. Hunter on June 20-24, June 27-July 1, August 1-5, August 9, October 4-7, and October 24, 1983, and January 11-13, January 26, and February 9,1984 of activities at our Braidwood Station.
Reference (a) indicated that certain activities appeared to be in non-compliance with NRC requirements.
- The Commonwealth Edison Company response to the Notice of Violation is provided as Attachment A to this letter. Our response to Unresolved Items 456/83-09-04 (A), 457/83-09-04 (A), 456/83-09-04 (B), , and 457/83-09-04 (B), and the description of our program to verify the l quality of installed piping components is included as Attachment B to ' this letter. An extension of the response period was requested from W.
S. Little and R. F. Warnick of Region III on separate occasions, and extension was granted to July 6, 1984. We a time given to us to respond to this matter. ppreciate the extension of , , ! Reference (a) revealed a nunber of deficiencies concerning the l programs and procedures which had been established at Braidwood Station i for the verification of correct material for ASE piping components, ' control of HVAC welding activities, and design control of field routed small bore piping and associated hanger installation activities. Our responses to the items of non-compliance describe the changes and improvements which we have made to those procedures as a result of our l intensive and comprehensive reviews of your findings and those of other inspections. The information provided in this submittal also serves to [
respond to the additional questions raised in the Reference (a) letter transmitting the Notice of Violation.
y)1.12 n n.n a = > d f6 ' $ ~'V' " I j . . .
a
. ' Y .' . . 1. G. Kappler-2-July 6, 1964 Comonwealth Edison believed that the programs and procedures, at the time of their approval, were adequate to assure the quality of the completed construction work. We acknowledge however, that they contained deficiencies with respect to meeting all regu,latory requirements, particularly with regard to the need for providing detailed documentation of activities. We also recognize the need in several cases to more rigorously follow and more effectively monitor approved procedures and activities.
Recently, an Atomic Safety and Licensing Appeal Board found that the critical questions regarding the assurance of quality of construction of complex nulcear power plants are whether identified construction deficiencies have been corrected, and whether there is a functioning quality assurance pr am so that there is reasonable assurance as to the overall integrity of facility. Cc m wealth Edison Company believes that the responses contained in the Attachments to this letter do substantiate that construction deficiencies have been and are being identified and corrected Quality Assurance at our,Braidwood Station.and that there is aggressive iglementation of We have established a rvater of corrective action programs to confirm the quality of specific areas of past construction work through a series of special inspections and @mtation reviews. The programs have been designed to demonstrate that past construction work is of acceptable quality, and that deficiencies are identified and appropriately dispositioned. These quality confirmation programs include: the Reinspection of Safety Related Mechanical Equipment * a QualitycontrolInspectorReinspectlon;thePipingHeatNumberMalerial Traceability verification Program; the Quality Control Structural Steel Review; an Electrical. Installation Document Review; a Review of Safety-Related Pipe Supports; the HVAC Welding Reinspection; the HVAC Configuration Review; the HVAC Duct Stiffener and Fitting Detail Review; an Instrumentation Installation Verification; and a NSSS Component Support Verification Review.
Finally, we have made extensive management and organizational changes within the Comonwealth Edison management team and the contractor management organizations, and within the Commonwealth Edison and contractor Quality Assurance / Quality Control organizations which effect overview activities, to provide assurance that procedural requirements will be met, and to ensure aggressive and effective management involvement in our Quality Assurance Program. A description of these changes is included as Attachment C to this letter.
i The co@ination of these efforts provide the basis for Commonwealth Edison Company's confidence in the performance of the site contractors, and our confidence that our Braidwood Station will be cogleted in cccordance with regulatory requirements.
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' , J. July 6, 1984 To the best of my knowledge and belief, the statements contained herein and in the Attachments to this letter are true and correct.
In some respects, these statements are not based on my personal knowledge but upon information furnished by other Comonwealth Edison enployees, contractors and consultants. Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
Very truly yours, e*" Louis 0. DelGeorge Assistant Vice President Attachments cc:- NFC Resident Inspector Braidwood -
, . 8931N
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. - 1 -- - ATTACHDENT A _C0be(NEALTH EDISON COWANY ' RESPON!E TO IN!PECTION REPORT
50-456/83-09 and 50-457/83-09 i '
4-ITEM OF NOICOWLIAtCE: t ,; I 1.
10 CFR 50, Appendix 8, Criterion XVI, as innlemented by Commonwealth Edison Company Quality Assurance Hanual, QR No.16.0, requires, in part, that measures be established to assure that conditions adverse ' to quality such as nonconformances are promptly identified and
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. corrected. In the case of significant conditions adverse to ! quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
i s Contrary to the above: 1/2" S/80, SA-312, Type 304, ASPE Boiler and Pressure Vessel s.
,
. Code, Section III, Class 1, NB pipe heat number 745107 was ' discovered in Section III installations without material test reports or records of receiving and receipt inspections by
either Commonwealth Edison Cospany or Phillips, Getschow Company as identified by Phillips, Getschow Company on , September 17, 1982, on Nonconformance Report No. 789. The
disposition of the Nonconformance Report resulted in accepting the pipe, after the only obtaining material test reports, without examining the pipe, initiating and maintaining receipt , ! inspection records, or determining the total' quantity of the j pipe in storage and installed.
, a f b.
The HVAC contractor had not established a corrective action program to assure that conditions adverse to quality such as deficiencies and deviations were analyzed for significance and i > subsequently that the causes of any significant conditions were determined and corrective action taken to preclude , repetition. Through August 4, 1983, 2,513 Correction Notices had been written by the HVAC contractor for deficiencies and
deviations, including numerous welding deficiencies and deviations,but the contractor's Quality Assurance Program did ' '
not require that Correction Notices be analyzed for , -
- -
significance.
' . { c.
Corrective action was not adequate concerning Nonconformance Report No. BR-08, dated 3;ne 15,1981, since the nonconforming ! welds completed by unknown welders were " accepted-as-is" after I ! only a visual examination. The acceptance of a weld by visual f' l examination pursuant to AWS Dl.1 is based on the fact that a > qualified welder performed the welding in accordance with the j qualified process.
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. .. -- - - -. .: ,~ P ' . . -2- . Response to Item la . ESPONSE Commonwealth Edison Conpany acknowledges that the disposition of NCR 789 was incomplete.
CORRECTIVE ACTION TAKEN APO RESLA.TS ACHIEVED Phillips, Getschow Company initiated NCR 1128 to document the additional disposition of NCR 789. NCR 1128 required the following: 1.
Field engineering to issue copies of drawings showing the installation location of both Schedule 80 and Schedule 160 1/2" pipe, heat number 745107.
2.
Phillips, Getschow Company Quality Control to verify wall thickness with UT thickness measurement device.
3.
Thickness information to be given to Phillips Getschow Company field engineering for determination of proper pipe schedule installation.
4.
The warehouse man shall initiate a Receiving Inspection Report
to document the receipt of the Schedule 80 pipe. Phillips, ' Getschow Company Quality Control shall review documentation.
5.
Total footage of pipe installed and in storage should be reconciled against the footage received for both Schedule 80 and Schedule 160 pipe.
These five (5) items could not be totally completed because all of the pipe could not be located. NCR 1128 was closed and was superceded by NCR 1640.
NCR 1640 has been dispositioned to locate all material in safety related and ASE Section III systems with heat nunber 745107 (1/2" + Schedule 80 and Schedule 160 pipe) through the Piping Heat Number Material Traceability Verification (MTV) Program. (Additionally,. this MTV Program will look at other material as discussed in Attachment B to this letter.) Wall thickness (schedule) will be verified by digital thickness measurement, and a Certificate of Conformance will be obtained from Guyon Alloys (the material' supplier) to document that a quality system program was in place at the time of material shipments.
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. \\ . . -3-Response to Item la (cont'd) CORRECTIVE ACTION TAKEN TO PREVENT RECURREPCE Over the past year, Phillips, Getschow Company has directed management attention towards improved review and dispositioning of PCRs. Included among the changes implerrented, are additional training of personnel, hiring of more experienced personnel for NCR reviews, and procedure and Quality Assurance Manual reviews and revisions to NCR related sections. Phillips, Getschow Company Procedure QAP-12, " Control of NCRs" was totally rewritten to better control PCR processing. QAP-12, Revision 5 was issued in April, 1984. This revision included a new NCR form. Additionally, .Phillips, Getschow Company Corporate Quality Assurance has completed a review of previously closed NCRs for thoroughness.
DATE OF FLA.L COWLIAKE . 1.
Phillips-Getschow Company management actions, procedure and Quality Assurance Manual changes are complete.
2.
Action to close NCR 1640 which will resolve this Finding is expected to be completed by January 31, 1985.
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. ' . -4-Response to Item lb RESPONSE Commonwealth Edison Company acknowledges that Procedure B16.1.F (Nonconformance/ Corrective Action) did not require trending of Correction Notices (CNs).
Correction Notices were first used in December,1980. Between Dece@er,1980 and Novenber,1982, seventy-two (72) Correction Notices had been written, all against new work. In October, 1982, the Pullman Sheet Metal 100% Weld Quality Retroinspection Program was initiated and in November,1982 the Pullman Sheet Metal 100% Configuration Retroinspection Program was initiated. These retroinspections of previously erected work resulted in 912 welding related Correction Notices encompassing an approximate population of 55,000 welds. Overall, 90% of the initial production inspected welding were acceptable.
Approximately 632 Correction Notices were written on norswelding related retroinspections (i.e. configuration, painting, etc.). The remaining 836 Correction Notices were written for construction activities completed after Novenber 1982 such as first time inspector work. In many cases, Correction Notices were written to document and disposition minor items (i.e. paint missing, rusting of material, overspray of fireproofing).
CORRECTIVE ACTION TAKEN APO REStLTS ACHIEVED Pullman Sheet Metal performed a trend analysis of the 1616 backfit retroinspection program Correction Notices. This review did not identify any significant trends, but it did substantiate the basis of our change from a 10% welding quality control inspection to a 100% inspection of welding and configuration quality control inspection. Additionally, the remaining Correction Notices (of the , total 2452 population) through August 2 1983 were also trended.
Again, no significant trends were ident$fied. However, the trend analysis did lead to some procedure revisions and increased training of personnel.
(It should be noted that generally, nonconforming items resulting from known reinspection /retroinspection programs are not included in the ongoing construction PCR data base trend analysis.
Including these nonconforming items may distort any true current trends.)
CORRECTIVE ACTION TAKEN TO PREVENT RECURRENCE Pullman Sheet Metal Quality Assurance has performed a trend analysis of Correction Notices by computer since in August,1983. Pullman Sheet Metal will generate a procedure by July 31, 1984 to more formally control trend analysis of NCRs and Correction Notices.
- - .. . . . . -5- . Response to Item Ib (cont'd) DATE OF FLLL CORIAfCE Trend analysis has been performed since August, 1983 and we are now in full compliance. Procedure issuance is expected to.be complete prior to July 31, 1984.
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\\ . . -6-Response to Item Ic RESPONSE Commonwealth Edison Company believes the corrective action for - Pullman Sheet Metal NCR BR-08 was adequate. We do acknowledge that the explanation for the " accept as is" based on final visual inspection needs to be expanded to explain all the bases behind this disposition. The bases for accepting 53 unstamped welds out of more than 55,000 welds performed by qualified welders is given below.
CORRECTIVE ACTION TAKEN APO REStLTS ACHIEVED Sargent and Lundy performed an engineering evaluation to address the nonconforming condition described in Pullman Sheet Metal NCR BR-08.
Commonwealth Edison NCR 558 documents this evaluation. The results of this evaluation stated that if a weld was acceptable (except for not being marked with the welder's ID) as determined by a visual inspection of the completed weld, then the weld could be considered acceptable. This conclusion was based on the fact that all Pullman Sheet Metal welders at the Braidwood Site were qualified by testing and trained in applicable welding procedures. Furthermore, all filler metal used by Pullman Sheet Metal was certified and only issued to qualified welders. Consequently, Commonwealth Edison believes that an AWS Code basis does exist to conclude that the unstamped welds were made by the qualified welders, and that these welds can be accepted by visual-inspection.
However, Commonwealth Edison Company does not wish the issue of replacing 53 welds to remain a point of contention between us and the Region. Consequently, we have directed Pullman Sheet Metal to either establish welder identification by in place physical markings or by other production or quality type records, or to replace the welds, if no welder identification can be established.
CORRECTIVE ACTION TAKEN TO PREVENT RECURREPCE As stated above, Commonwealth Edison believes the original corrective action was satisfactory; however, documenting the basis for acceptance was not sufficient. Project Construction Department personnel will be instructed to more fully ensure that corrective action bases are documented when reviewing Contractor nonconformance reports.
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- , l-7-Response to Item Ic (cont'd) DATE OF FLLL COM'LIAPCE The dispositioning of the unstamped Pullman Sheet Metal (NCR BR-08) welds is expected to be conpleted prior to September 1, 1984.
Project Construction Department personnel are scheduled to receive quality assurance training in July,' 1984 at which time documentation of corrective action bases will be re-emphasized.
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. i ' . , . . -8-COMONEALTH EDISON COWANY RESPONSE TO IN9'ECTION REPORT 50-456/83-09 and 50-457/83-09 ITEM OF NDPCOWLIAPCE: 2.
10 CFR 50, Appendix, B, Criterion V, as implemented by the Commonwealth Edison Company Quality Assurance Manual, QR No. 5.0, requires, in part, that activities affecting quality be prescribed by documented instructions, procedures, or drawings, and shall be accomplished in accordance with these instructions, procedures, or drawings.
! a.
Phillips, Getschow Company Construction Procedure 1.1, Revision 4, " Control of Engineering Change Notices and Field Change Requests," Section 5.3, requires that Document Control stamp applicable design documents with the field change request number.
, Contrary to the above, Field Drawing 42539C-4, Revision D, was not stamped with Field Change Request No. L-9194 and Field Drawing W 2542C-121, Revision A, was not stamrid with Field Change Request No. 9988.
b.
Commonwealth Edison Quality Assurance Manual, Revision 77, Q.P. No. 7-1, " Control of Procured Material and Equipment - Receiving and Inspection,"' Section 5.2.1.5.7, " Dimensional," requires visual checks be performed on a random basis to , assure that interface dimensions conform to drawings and/or specifications.
Contrary to the above, random visual checks of interface dimensions of piping components were not being done.
c.
Phillips, Getschow Company Quality Procedure-7, Revision 7, , ' " Control of Inspection Equipment," requires in Section 7-9 that the Site Manager or Shop Superintendent maintain a log on each piece of calibrated inspection equipment listing all items inspected and person doing the inspection with each piece of inspection equipment.
Contrary to the above, there was no documented record or log specifying that a calibrated instrument was used to measure numerous pipe bends for ovality requiring inspection measurements to the thousandths of an inch. Examples include the bends on Drawings 42546C-72, W2546C-44, >C-2546C-42, and W2546C-31.
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ITEM OF NONCOWLIAPCE: (cont'd) d.
Phillips, Getschow Company _ Construction Procedure-4, Revision 0 " Control of Rework of Conponent Supports," requires in Section IV that upon' issuance of revisions to conponent supports, the Field Superintendent shall initiate a Field Change Order to the Field Engineer when an ASE Section III, Subsection NF weld is involved.
Contrary to the above, Field Change Orders were not written , i for revisions involving ASE Section III, Subsection NF welds
for component support Drawings M-lRH02017R, Revision E, and , ! M-lSIl6021X, Revision B.
e.
The L. K. Comstock Company /L. K. Comstock Engineering Company , (LKC/LKCEI) Quality Assurance Program manual requires in Section 4.2 that voided documents (drawings) be returned to the document control within 3 days.
l - Contrary to the above, drawings located in site document Station No. 5 were voided in that they were up to four i i revisions old and were neither returned to the Document Control as voided drawings nor marked as being voided drawings ' for information only.
I r r I i , Y l s .
. $ . . - 10 - Response to Item 2a RESPONSE Commonwealth Edison Company acknowledges that the two referenced Phillips Getschow Company drawings were not stamped with the appropriate Field Change Request numbers.
CORRECTIVE ACTION TAKEN Ato RESLLTS ACHIEVED Phillips Getschow Company Field Drawing W 2539C-4, Revision D was since stamped with Field Change Request L-9194. Phillips Getschow Company Field Drawing 42542C-121, Revision A was since stamped with Field Change Request L-9988.
CORRECTIVE ACTION TAKEN TO PREVENT RECURREtCE Extensive attention has been placed on Document Control by Phillips, Gets::how Company since August,1983. Training has been intensified and increased, stressing that great attention to detail must be placed on all Document Control activities. The Document Control Station method of document issuance was started in November 1983 to minimize errors in keeping documents up-to-date. Subsequently, several Phillips, Getschow Company Quality Assurance and Commonwealth Edison Conpany Quality Assurance audits and surveillances have reviewed the current design change stamping efforts and have found that corrective actions have been acceptably taken.
(Reference: Phillips, Getschow Company Quality Assurance Audit
- 83-BR15, dated 7/26/83 with follow-ups on 9/20/83, 10/5/83, 11/18/83,12/13/83 and 4/16/84; and Commonwealth Edison Site Quality Assurance Audit 20-83-15 including follow-up action presented in Surveillance 2981 and Site Quality Assurance Surveillance 3450.)
DATE OF FULL COPFLIAFCE Full compliance has been achieved.
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'. . - 11 - Response to Item 2b Commonwealth Edison Company acknowledges that random dimensional checks of piping interface dimensions were not being performed by Phillips Getschow Company.
' CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED . Supplement S1, Revision 0 to Phillips Getschow Company Procedure QAP-33, Revision 1, titled " Receiving of Items, Material and Equipment" was written and approved for use on July 28, 1983 to provide a Quality Control inspection plan for dimensional verification of piping wall thickness on a 10% random basis.
Subsequently, QAP-33 and this inspection requirement was incorporated into Phillips Getschow Company Procedure QCP-B4, Revision 4, dated September 17, 1983 titled " Material Control (Receiving, Storage and Handling of Materials, Items and Equipment)".
This procedure was approved for use on January 23, 1984 and has been implemented since that time.
For the small bore and large bore pipe received prior to July 28, 1983 the action taken is summarized below: 1) One-hundred and twenty small bore pipe heats had been received of which forty-five heats had been installed in non-safety related piping systems. The remaining seventy-five heats were dimensionally inspected in the field for wall thickness, by Phillips Getschow Company, Quality Control using digital thickness gauges. All were found to meet minimum wall thickness acceptance criteria.
(Subsequent to these inspections, a problem concerning a minimum wall violation due to pitting was identified for a portion of one heat of pipe in storage. This was subsequently reported to the NRC under 10 CFR 50.55(e) notification No. 84-10. Additional details and actions related to this problem will be presented in the 30 day report due July 21, 1984.)
2) One-hundred and twenty-four large bore heats had been received. A 10% sample from each heat was taken and was dimensionally inspected in the field for wall thickness by Phillips Getschow Company Quality Control, again using digital-thickness gauges. All samples inspected were found to have acceptable pipe wall thickness.
3) A review was performed of Commonwealth Edison Company Material Receiving Reports ( mRs) for pipes received prior to the WC inspection. This review identified that prior to 1980, random dimensional inspections were performed by Phillips Getschow Company, Quality Control inspectors during receipt inspections. The results of these inspections are included in the applicable mR packages.
-_ _ _ . . . . - 12 - Response to Item 2b (cont'd) CORRECTIVE ACTION TAKEN TO PREVENT RECURRENCE Contirmed implementation of Procedure QCP-84 will prevent this item from recurring. Phillips, Getschow Company Quality Assurance will continue to monitor the implementation of this _ procedure through
audits and/or surveillances.
DATE OF FLLL COWLIAPCE Full compliance has been achieved.
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. b , . . - 13 Response to Item 2c = RESPONSE Commonwealth Edison Company acknowledges that the inspection equipment identification number was not always docunented by . .Phillips Getschow Company quality control. inspectors for the l , ' calipers used to measure ovality of pipe bends.
j CORRECTIVE ACTION TAKEN APO RESLLT ACHIEVED . The recording of inspection equipment identification nunbers on field travelers, in conjunction with other related logs, has always-been required by the Phillips, Getschow Company Quality Assurance Manual. Although a log was being maintair.ed, it appears that because a specific blank was not provided on the traveler for the ! caliper identification number, the caliper number was not recorded.
. A letter was issued to Quality Control personnel on July 5,'1983 by the Quality Control Supervisor instructing them to indicate the caliper number on the traveler. A review by Phillips, Getschow Company Quality Control determined that none of the calipers used to m measure ovality have ever gone out of calibration, or required repair or adjustment.
CORRECTIVE ACTION TAKEN TO PREVENT RECURREPCE , Phillips Getschow Company Construction Procedure PGCP-11, Revision 8 dated 9-13-83 and implemented 9-15-83 required the Quality Control ~ inspector to list the calibrated instrument number next to each bend on the bend inspection checklist. This requirement was further clarified in Revision 10 implemented 3-28-84 when a specific line , item for the calibrated instrument number became part of the checklist.
Additionally, Phillips, Getschow Company Quality Assurance Procedure ' QAP-7, Supplement Revision 4, dated 1-3-84 and approved 2-3-84 requires that specific identification numbers of inspection instruments used to accomplish inspections are to be recorded on the applicable checklists or travelers.
, DATE OF FULL COPPLIAtCE i ! Full compliance has been achieved.
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__ . . . - 14 - Response to Item 2d RESPONSE Pnillips Getschow Company Procedure PGCP-4, Revision 0, was not intended to be the governing procedure for revision work to the two component support examples at the time of the PfC inspection.
Phillips Getschow Company Procedure QCP B23, " Installation and Inspection of Component Supports", Revision 3, issued Decerter 8,
1982 and a subsequent revision was intended to control the revision work of component supports at that time. QCP-823 did not require the use of field change orders to control changes for pipe supports. Phillips Getschow Company failed to formally withdraw PGCP-4 from issuance at the time QCP-823 was issued for use.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Phillips Getschow Company by a letter to Commonwealth Edison Company dated June 23, 1983 formally requested that PGCP-4 be withdrawn from use based upon acceptable modification and incorporation of. 3CP-4 requirements into QCP-823. Commonwealth Edison Company authorized this withdrawl by a memo dated June 25, 1983. At this time, QCP-823 latest approved revision is the governing procedure for component support changes.
CORRECTIVE ACTION TO PREVENT RECURREPCE Over the past year, the Phillips, Getschow Company has completed the review and revision of many procedures. During this review, any procedural conflicts were addressed.
DATE OF FlLL CO WLIAPCE Full compliance has been achieved.
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. 15 - - Hesponse to Item 2e , RESPONSF Commonwealth Edison Company ackr.owledges that a small nuder of drawings located in L. K. Comstock site document Station No. 5 were not returned to Document Control within 3 days as required by L. K.
, Comstock/L. K. Comstock Engineering Incorporated Quality Assurance Program Manual, Section 4.2.
, I CORRECTIVE ACTION TAKEN Af0 RESLLTS ACHIEVED As noted in.the NfC inspection report, a complete audit of L. K.
Comstock Station No.~ 5 was performed. Additional voided drawings , were' identified and removed from the current stick files.
CORRECTIVE ACTION TAKEN,TO PREVENT RECURRE>CE . j .L. K. Comstock personnel received training in document control procedure requirements related to returning drawings within 3 days.
, l l Additionally, the surveillance activities of the Documentation Control Department were increased. Between July,1983 and January, 1984, sixteen (16) surveillances involving fifteen (15) documentation stations and a 100E check of the office engineering ~ drawings were performed. As a result of the surveillances [ performed, 8,335 drawings were reviewed and 352 superceded drawings L were found in the field. (However, 235 of these were in a single document station which is devoted to checking the status of past ' revision work. A 1005 check of all drawings was subsequently l performed at this M=nt station.)
L Additionally, between July, 1983 and January, 1984, L. K. Comstock Quality Control performed monthly random drawing control i surveillances. The results of these surveillances~ indicate L compliance with document control procedures.
i ~ In May,1984, L.K. Comstock completed a field audit of all document ' stations performing safety-related work activities. Commonwealth Edison Site Quality Assurance Department completed a document
control audit in April-May, 1984. Document control problems were
found during both audits. As a result of both these audits, L.K.
' Comstock implemented a long range plan to streamline these document control systems. Overall, the changes improve the efficiency and
l control of document control operations. Specifically, the long
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~ ' I - 16 - Response to Item 2e (cont'd) range plan will effect the following: (1) Reduce the numbers of document stations from 44 to approximately 26.
(2) Reduce the number of drawings at each station.
(3) Change the style of document master cards and reduce the ntsnber of document master cards.
(4) Eliminate void print files by the use of aperture cards.
(5) Change the style and format of print transmittal forms and reduce the number of field drawing transmittals.
(6) Computerize transmittals and returns.
. (7) Restructure the Document Control Department.
- DATE OF FlLL COM'LIANCE
' Since June, 1983, substantial attention has been directed toward this concern. The long range plan is expected to be fully
implemented prior to Septenber 1,1984.
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.- , . - 17 - C0h40NEALTH EDISON COWANY RESPONSE TO INSPECTION REPORT 50-456/83-09 and 50-457/83-09 ITEM OF NONCOWLIAFCE: 3.
10 CFR 50, Appendix B, Criterion II, requires, in part, that a quality assurance program be established which complies with the requirements of Appendix B and that the program be documented by written policies, procedures, or instructions and carried out in accordance with these instructions. The quality assurance program shall provide control over activities affecting quality and shall be accomplished under suitably controlled conditions including assurance that all prerequisites for the given activity have been satisfied including the need for special controls, processes, skills and the need for verification of quality by inspection. Criterion V requires, in part, that instructions be appropriate to the circumstances. Criterion IX requires, in part, that measures be established to assure that special processes, including welding are controlled and accomplished in accordance with applicable codes, standards, specifications, criteria and other special requirements.
Commonwealth Edison Company Quality Assurance Manual, QR 2.0, Paragraph 2.3, required that the Quality Assurance Program take into account the need for control of special processes including welding to attain and maintain the required quality. QR 9.0, Paragraph 9.4, required provision of process control records.
AWS Dl.1-1977, Section 3, " Workmanship," as inplemented by Sargent and Lundy (S&L) Specification F/L-2782, "HVAC Work," Amendment 7, requires, in part, that all applicable paragraphs of Section 3 be observed in the production and inspection or welded assenblies and structures pr >duced by any of the processes acceptable under AWS D1.1-1977. Paragraph 3.4.3 of AWS D1.1-1977 requires, in part, that t.h2 centractor shall prepare a welding sequence for a member of structae which in conjunction with the joint welding procedures and overall fabrication methods will produce members or structures meeting the quhlity requirements specified.
AWS Dl.1-1977, Section 6, " Inspection," requires that fabrication / erection inspections and tests be performed as necessary prior to assembly, during assembly, during welding, and after welding to ensure that materials and workmanship meet the requirements of the contract documents, including inspections to assure that electrodes are used only in the position and with the type of welding current and polarity for which they are classified and inspections to assure that the work meets the requirements of Section 3, " Workmanship," which includes fit-up and preparation of base metal prior to welding.
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. . - 18 - ITEM OF NONCO WLIANCE: (cont'd) Contrary to the above: a.
Instructions were not appropriate to the circumstances in that welding procedures specifying the essential variables were not prescribed on drawings or welding sequences (travelers) for each specific HVAC installation, and Quality Control inspections during the welding process were not of adequate scope and frequency to assure the use of correct welding variables.
b.
Quality Control was not required to examine the HVAC components for fit-up prior to welding on those components where fit-up tolerances cannot be determined after welding, such as all-around fillet welds and full penetration welds.
Consequently there was a lack of records documenting the conformance with the requirements of AWS Dl.1-1977, Section 3, and the Conmonwealth Editon Company Quality Assurance Manual.
Additionally, instructions to the quality control inspectors regarding fillet weld gaps after welding were not appropriate to the circumstances in that the HVAC contractor Visual Weld Inspection Procedure, B10.2.F. stated that a 3/16" gap was acceptable whereas AWS Dl.1-1977, Section 3.3, states that a 3/16" gap is allowed only if the leg of the fillet weld is increased by the amount of the separation or the contractor demonstrates that the required effective throat has been obtained.
c.
Quality Control was not required to examine the base metal prior to welding to assure that surfaces and edges were free of discontinuities. Consequently, there was lack of records documenting conformance with the requirements of AWS Dl.1-1977, Section 3, and the Commonwealth Edison Conpany Quality Assurance Manual.
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'. . - 19 - Response to Item 3a RESPONSE - It is the Commonwealth Edison Company position that the up front programmatic controls provided by Pullman Sheet Metal were and still are adequate to control the welding activities performed by Pullman Sheet Metal. Overall, the quality assurance controls applied to welding activities and performed by Pullman Sheet Metal provided controls necessary to provide adequate confidence that HVAC structures, systems and components 'will perform satisfactorily in service. These controls were consistent with HVAC system requirements.
AWS Dl.1-1977 has been referenced in Specification L-2782 and the Byron /Braidwood FSAR as the applicable code to which HVAC hangers and duct welding are to be performed at Braidwood Station.
Contained within AWS Dl.1 are many references requiring that "the weld inspector shall make certain" that certain pre-requisites have been met before the start of welding. Such pre-requisites. include, but are not limited to, such items as welder qualifications, i acceptable filler materials, and thy use of correct welding processes and procedures. Such assurance can be provided in different ways.
The individual inspector can document that all such pre-requisites have been met before the welding begins. Equally acceptable is the implemcntation of up-front programatic controls which do not rely solely on a Quality Control inspector's pre-welding checks and then a coupling of these controls with post-weld Quality Control visual inspection.
The following items provided confidence that such programmatic controls were in place at Pullman Sheet Metal and were functioning to provide assurance that the required welding quality was being provided: (1) S & L has reviewed and approved all duct brochure details, all field and shop procedures (including welding procedures), and all design documents. This review was performed to judge the technical adequacy of and adherence to FSAR commitments.
These Pullman Sheet Metal procedures incorporated corrective actions for other HVAC cor.cerns identified at LaSalle County-and Byron Stations.
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. . - - 20 - Response to Item 3a (cont'd)
(2) Pullman has purchased and shipped only acceptable materials, including filler material, to Braidwood Station. This was i verified by Comonwealth Edison in the field and in the Chicago Shop. Commonwealth Edison Conpany audits 20-82-20
(3-5-82) and 20-82-30 (8-23-82) specifically reviewed Pullman ' Sheet Metal's traceability of purchased material. These
audits were the direct result of attention to previous
, problems identified in the HVAC areas at LaSalle County and j Byron Stations. The audit results provide assurance that
Pullman had supplied only acceptable materials, and had adequate h-ntation and control for all such material , ' installed at Braidwood Station.
i (3) Documentation of training exists for all Pullman Sheet Metal welders in the approved procedures to which they were qualified..Such training covered the following welding , } aspects and requirements: material specifications, welding processes, position of welding, filler metal classification, single or multiple pass requirements, welding current, - polarity, welding progression, pre-heat and interpass
temperature, electrode size, amperes range, voltage range, and
type of joint detail. This training documentation has been verified by Commonwealth Edison Site Quality Assurance.
(4) Commonwealth Edison Site Quality Assurance had witnessed site welder qualification tests and ensured that welders were qualified. Since February,1981, Consnonwealth Edison Site , I-Quality Assurance has witnessed over 400 guided bend welder l Qualification tests to AWS. The evaluations of such test ' results were performed by PTL (the independent on site testing , ! laboratory working for Site Quality Assurance).
, t (5) The Pullman Sheet Metal welders had only a limited number of ' acceptable welding procedures available. This, coupled with the relatively small numbers of welders working with familiar , configurations and details, provide confidence that the proper j WPS and filler material were used.
I (6) Between February, 1983 and May, 1983, Pullman Sheet Metal had performed 55 documented in-process welding inspections. No , instances of the incorrect use of filler material or improper
procedure implementation were observed. Between June, 1983 and Decenber,1983, an additional 583 irsprocess surveillances , ! have been performed with no instances noted of the incorrect
placement of filler material. Two (2) instances were found . where the welding procedure was incorrect. The procedure was ' revised, reviewed and accepted.
(7) Pittsburgh Testing Laboratory, working for Site Quality Assurance performed the following surveillance activities to assure that Pullman Sheet Metal was performing adequately: .__- - . .. .. . ... . .
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- 21 - - . I' l Response to Item 3a (cont'd) <
(a) A 105 overview inspection of all Pullman Sheet Metal safety related final weld inspections. This activity
started in 1980 and is ongoing.
(b) Random overview surveillances directed by Site Quality Assurance for specification compliance. _Such.
, surveillances covered configuration, housekeeping and I storage, welding details, etc. A qualified inspector , was utilized by Site Quality Assurance to perform this activity.
. (c) Unit Concept Inspections (a planned series of l surveillance modules) which provide independent design j compliance verification were performed on' Pullman Sheet Metal. This sample covered both Safety Related and } Non-Safety Related, complete and incomplete construction, and included items already identified by i
Pullman Sheet Metal Quality Control.
i (8) Site Quality Assurance audits of Pullman's activities ' ! addressed not only Pullman Sheet Metal Quality Assurance
Manual commitments, 10CFR50 Appendix B, and selected Pullman l Sheet Metal's procedures, but also Regulatory Guides, i Specification L-2782 requirements, and AWS requirements. The l knowledge of problems identified at LaSalle County and Byron
Stations in the HVAC areas was also used in determining areas I to be checked to assure that those items did not recur.
i - (9) Commonwealth Edison's auditing activities to assure the l adarpcy of Pullman's Quality Assurance program and procedure . iglementation resulted in Pullman performing a 1005 visual verification /re-verification of all previous (1) welding, (2) - duct and hanger configuration, and (3) equipment installation . (January, 1983). When Pullman had completed significant . ! portions of the above re-verification inspections but were l falling behind in required rates of inspection, Commonwealth Edison Site Quality Assurance issued a Stop Work on all new " ' work (except the Unit 1 VC Fan Room and the Unit 1 D/G Rooms) in 3Jne of 1983, to allow Pullman to coglete the
re-verification program.
Commonwealth Edison Company continues to have confidence in. the adequacy of previous work. We understand that the subject of previous work (involving the Region's interpretation of AWS Dl.1 Code) has been referred by NfC Region III to PRR for resolution.' We have directed Pullman Sheet Metal to institute the welding control actions described below for future work.
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J . . - 22 - Response to Item 3a (cont'd) CORRECTIVE ACTION Ato REStLTS ACHIEVED - Pullman Sheet Metal revised Procedure 89.4.F to incorporate a process sheet. The process sheet is utilized to pre-assign the welding procedure. One hundred percent (100%) in-process quality control inspection of welding activities began in August,1983.
This 100% inspection level continued until February,1984. At that time, it was reduced due to the reverification of high confidence levels in Pullman Sheet Metal welders' ability to properly follow procedures.
The current in-process surveillance requirements as of May 9,1984 are the following: 1) 10% of the welder work force or 10 welders, whichever is greater, will have in-process surveillances each week.
2) Each welding process will have a surveillance each month.
3) Each active welder will have at least one in-process surveillance every three months.
(One within each calender quarter.)
4) For each new welder or returning welder, ten (10) consecutive in-process surveillances must be conpleted before beginning the above requirements. These in-process surveillances must be acceptable.
While Commonwealth Edison Company does not believe that this procedural revision is a regulatory requirement, we acknowledge that the revised Procedure 89.4.F results in quality documentation and improvements in the control over the HVAC welding activities.
CORRECTIVE ACTION TAKEN TO PREVENT RECURREtCE Metal welding activities. y will continue to monitor Pullman Sheet Commonwealth Edison Compan Should deficiencies be discovered, appropriate corrective action will be taken.
DATE OF FULL COWLIAFCE Commonwealth Edison Company believes that full compliance has always been achieved. The procedure revision was in effect on September 28, 1983.
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- 23 - Response to Item 3b ', RESPONSE Refer to the discussion under Item 3a.
' < Additionally, over 905 of all the HVAC welds can.be inspected for fit-up after the weld is conpleted. Although B10.2.F did not specifically require a check for the increased fillet size (when a 1/16" to 3/16" gap exists), all of the Pullman Sheet Metal Quality Control inspectors had been instructed in the AWS Code requirements and were aware of this requirement.
i CORRECTIVE ACTION TAKEN APO RESLLTS ACHIEVED
. Approximately six (6) duct hangers include welds which cannot be fit-up inspected after weld completion. None of these hangers were completed prior to the below stated procedure change to check full penetration fit-up prior to welding.
Equipment bases and gallery , support standard details have some welds which cannot be checked for
fit-up after welding completion. Fan bases for IVXO7C and 2VXO7C
have four (4) all around welds per base, and gallery supports for ! IVXOlF, IVXO3F, IVXO4F, IVEDIF, 2VX01F, 2VXO3F, 2VXO4F, and 2VE01F have all around welds of 4 x 4 x 3/8" angle to plates or structural L
steel. Commonwealth Edison Company believes the programatic controls stated above were adequate to ensure correct fit-up of these welds. An PCR will be written to request the engineering
disposition of the lack of fit-up inspection on these welds.
! ' Angle splice alternate details are the only other items which cannot
be checked for fit-up after weld completion. These full penetration welds are either square butt or bevel type welds. Any fit-up ' < problems could be corre:ted by addition of filler metal to attain the proper fit-up gaps. During the 100% weld reinspection program described below, these welds were inspected for evidence of improper fit-up. All welds were deemed acceptable.
Beyond that described above, Pullman Sheet Metal has reinspected 100% of all other accessible welds previously made. During this inspection program,-improper fit-up was specifically inspected for, and items if found, were identified on Correction Notices. All reinspection was performed utilizing Sargent and Lundy supplied AWS acceptance criteria.
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. . . - 24 - Response to Item 3b (cont'd) CORRECTIVE ACTION TAKEN TO PREVENT RECURRENCE A.
Pullman Sheet Metal Procedure B10.2.F (visual weld inspection) was revised to specifically address checking for increased . fillet size when a fit-up gap exists (1/16" to 3/16" gap for most Pullman Sheet Metal work).
B.
Pullman Sheet Metal Procedure 89.4.F (installation procedure) was revised to establish fit-up checks prior to welding in cases where fit-up cannot be checked after completion of the weld.
DATE OF FULL N M)LIAPCE Pullman completed the 100% weld reinspection by April 31,-1983.
Pullman Procedure B10.2.F vas implemented in September, 1983 to address checking for required fillet size when gaps are present.
Pullman Procedure 89.4.F wre; implemented in September,1983 to establish pre-welding fit-tip checks, as required.
The disposition of the NCR concerning lack of fit-up inspection is expected to be accomplished by October 1,1984.
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. . . . - 25 - Response to Item 3c RESPONSE AWS Dl.1-1977, Section 3.2.1 states in part, " Surfaces and edges to be welded shall be smooth, uniform, and free from fins, tears, cracks, and other discontinuities which would affect the quality or strength of the weld. Surfaces to be....". The discussion under Item 3a gives many of the controls applied to Pullman Sheet Metal HVAC welding activities. In part, these controls will preclude the use of materials with edge discontinuities which could impact welding activities.
Additionally, mild steel edge discontinuities are generally present in thick steel members. These discontinuities result from steelmaking processes. Pullman Sheet Metal welds thin members, generally from 1/16" to 1/2" in size. There is less likelihood for edge discontinuities in these sizes.
Quality Control has, by the time an item is fit-up in the field, inspected Pullman supplied sheet and structural items at least once. Items are inspected at the time of receipt in the Pullman Shop and at the time of shipping for shop fabricated items. Field .
fabrica: *.d items, are inspected at the time of receipt at the Braidwood site. These inspections include a check for discontinuities. Jobsite fabricated items are sscut and not oxygen cut. This minimizes the likelihood of irregular edges.
, Comonwealth Edison Company believes the necessary controls have been and are in place to preclude use of substandard materials.
These controls are present throughout the fabrication / erection
process.
f CORRECTIVE ACTION TAKEN Ato REstLTS ACHIEVED ' Commonwealth Edison Company believes that adequate controls were in place for previous work to preclude use of substandard materials.
No further corrective action is required.
' . CORRECTIVE ACTION TAKEN TO PREVENT RECURREPCE . Quality Control inspector and welder training to AWS Dl.1-1977 includes checking for base metal condition during fit-up inspections. This action along with other programmatic controls , L will preclude the use of substandard materials.
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l . . - 26 - i Response to Item 3c (cont'd) '
.DATE OF RLL COWLIANCE Full compliance has been achieved.
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. .-.. .. . . . . - 27 - < COP 90NEALTH EDISON COM3ANY RESPONSE TO INSPECTION REPORT 50-456/83-09 and 50-457/83-09 ITEM OF NONCOWLIAPCE: 4.
10 CFR 50, Appendix B, Criterion XVIII, as iglemented by the Commonwealth Edison Company Quality Assurance Manual, QR No. 18.0, requires, in part, that a comprehensive system of planned and periodic audits be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program.
, Contrary to the above: a.
Phillips, Getschow Ccmpany has not established and executed a plan for auditing the implementing procedures of the quality assurance program'on a periodic basis to determine the effectiveness of the program in accordance with the PG Quality Assurance Manual, Section 16.
b.
L. K. Comstock Company /L. K. Comstock Engineering Company auditing activities neither conformed with the comprehensive annual schedule of planned and periodic audits established as required by Quality Assurance Program Manual Section 4.14.1, nor did they verify cogliance with all aspects of the Quality Assurance Program.
. c.
Pullman Construction Industries, Inc., did not meet their yearly schedule for audit activities required by their Quality Assurance Manual, Section 18, in that the following iglementing procedures were not audited: B 3.1.F Design Control - B 5.1.F, HVAC Repair Adjustment - B 9.3.F, Expansion Anchor Installation - B 10.2.F, Visual Weld Inspection - d.
The licensee's audits of the installation of small bore instrumentation and process piping were inadequate in that contractor hanger design calculation problems were not identified for more than two years.
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. . . - 28 - Response to Item da RESPONSE Commonwealth Edison Company acknowledges that Phillips, Getschow Company did not audit each of its implementing procedures. Rather, the Phillips, Getschow Company Quality Assurance Program required all Quality Assurance Manual sections to be audited over the year period. This requirement met and fulfilled ASE Code requirements.
The audit schedule for the 1983/1984 period, dated March 17, 1983
provided for all Quality Assurance Manual sections to be audited. A special schedule was established to audit process control procedures.
CORRECTIVE ACTION TAKEN APO RESULTS ACHIEVED Phillips, Getschow Company revised their audit schedule on August 21, 1983 to include auditing of all procedures annually. Procedures not used in the annual period will be designated not applicable at the time of the audit.
CORRECTIVE ACTION TAKEN TO PREVENT RECURREPCE Commonwealth Edison Company verifies implementation of the Phillips, Getschow Company Audit Plans through our audits and surveillances.
l DATE OF FtLL COM)LIAPCE The revised Audit Plan has been implemented. Commonwealth Edison Company verification of the schedule has been completed.
(Reference Commonwealth Edison Company comprehensive onsite/offsite audit of October 198;). i i I i - l .
- - _ _ . J . . - 29 - Response to Item Ab RESPONSE , Commonwealth Edison Company acknowledges that L. K. Comstock did not fully implement their 1983 audit schedule. However, adequate Commonwealth Edison Quality Assurance audits were performed to cover all applicable L. K. Comstock activities. During the inspection visit, the NFC acknowledged that Commonwealth Edison Quality ' Assurance provided adequate quality audit coverage and that Site Quality Assurance was previously aware of the L. K. Comstock j shortfall.
CORRECTIVE ACTION TAKEN AND RESLLTS ACHIEVED , A review of L. K. Comstock's audit coverage (corporate and site) for 1982 and 1983, indicates that a total of six (6) Quality Assurance manual subsections and six (6) field work procedures had not been i i audited as follows.
A review of the six (6) Quality Assurance manual subsections not . audited by L. K. Comstock showed: '
! One (1) section covered the L. K. Comstock Policy Statement j One (1) section covered the overall program description ' One (1) section defined the program applicability One (1) section covered L. K. Comstock's reporting of 10 CFR
Part 21 items . One (1) section covered the corporate review of the site . Quality Assurance program - One (1) section covered the corporate Organization Chart L. K. Comstock corporate Quality Assurance has since completed audits of the above sections.
For the six (6) work procedures: Two (2) were new procedures as of late 1983 and therefore were not yet scheduled for audit One (1) covered silver plating of bus bars (an infrequently performed operation which is subjected to a 1004 Quality Control witness) -. . - . -- -_-_-. -_.
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... - _ . -.. .. -. . _ _ - - - - -- . ! - t _ 30 - _ Response to Ab (cont'd) i One (1) covered site organization position delineation. This section is normally audited by corporate auditors during their audits ! . - , One (1) covered Production's use of a Revision Work Request ' (RWR).
(W) wever, the related Quality Control inspection of RWRs had been audited. Subsequently, the work instruction was - audited during the week of January 9,1984 by L. K. Comstock.)
, One (1) covered Equipment / Junction Box Installation.
, (However, the related Quality Control inspection of equipment erection had been audited. Subsequently, the work instruction was audited during the week of January 9, 1984 by L. K.
Comstock.)
Therefore, the active applicable work procedures and quality control inspection procedures have been audited by L. K. Comstock as of the - week of January 9,1984.
A concern raised by the inspector in the area of supporting evidence for L. K. Comstock audits prompted Site Quality Assurance to review copies of the objective evidence for the L. K. Comstock corporate offsite audits. Commonwealth Edison Conpany Quality Assurance with L. K. Comstock site Quality Assurance performed this review.
(This information was not available onsite during the NfC inspection.)
This review disclosed that there was sufficient objective evidence
recorded to support the conclusions stated in the audit reports.
Copies of this objective evidence are available at the site for review.
. " CORRECTIVE ACTION TAKEN TO PREVENT RECURREPCE , L As a result of the Conmonwealth Edison Company Quality Assurance ' concerns, L. K. Comstock has placed two (2) fulltime, qualified auditors on site (one activated in October,1983 and one in l Novent>er, 1983). Counseling has been given to these auditors by - Commonwealth Edison Company Quality Assurance to include more
y descriptive evaluations of audit results in their audit reports.
Additionally, Procedures (4.14.3 and 4.14.1) have been revised to more clearly define the L. K. Comstock onsite auditing activities * ' -and qualification processes for site auditors.
l L. K. Comstock site Quality Assurance has submitted an audit plan ' for 1984 which indicates that the Quality Assurance Program and
their active safety related activities will be adequately covered.
M e m.
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-- ... . {~~ ;- . - 31 - Response to Item Ab (cont'd) DATE OF FtLL COM'LIAPCE All applicable site procedures were audited by the week of Anuary 9, 1984. Procedures 4.14.3 and 4.14.1 were revised to reflect onsite auditing activities and qualification processes.
Interim approval was granted on 2/29/84 and 11/2/83 respectively.
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, . . . - 32 - Response to Item Ac RESPONSE Commonwealth Edison Company acknowledges that Pullman's-1982 and 1983 audit program did not cover all implementing procedures.
Commonwealth Edison Site Quality Assurance audit number 20-83-12, performed in March,1983, identified the fact that Pullman failed to audit all of the eighteen (18) Criteria. The Pullman Quality Assurance program required that all Criteria of 10CFR50 Appendix B be audited, as a minimum, annually. This deficiency was closed by Commonwealth Edison Site Quality Assurance Surveillance number 2903 based-on Pullman's documented reasons for this deficiency and completing their 1982 audit schedule in early 1983.
It was Pullman's intention to audit their program against the eighteen (18) 10CFR50 Appendix B Criteria. Thus, Pullman's audits dated April 4, 1983 and April 28-29, 1982 did nct assess compliance to all current procedures.
Compliance with the eighteen Criteria was assessed by using their Quality Assurance Manual and implementing procedures together. This approach assured procedure adequacy and procedure compliance simultaneously on a sanpling basis.
CORRECTIVE ACTION TAKEN AND RESlLTS ACHIEVED Pullman performed two (2) audits in August and Decerrber of 1983.
These audits covered all sections of their Quality Assurance Program and assessed compliance with Pullman's implementing site procedures.
CORRECTIVE ACTION TAKEN TO PREVENT RECURRE T E Pullman has implemented an audit schedule matrix listing Appendix B criterion, Quality Assurance manual sections, and procedures to be covered for future audits. This will assure that future audits cover not only Appendix B Criteria, but also the entire population of implementing procedures.
DATE OF FlLL COW LIAT E' Full compliance has been achieved thru implementation of the audit schedule matrix.
.. . - 33 - Response to Item ed RESPONSE Comonwealth Edison Company does not agree with the PEC Finding that problems with the Phillips, Getschow Company support selection program were not identified and that correction of identified non-conformances were not performed in a timely manner. The history presented below represents the Site Quality Assurance Department activity in this area. The history demonstrates that an audit had been conducted and that work was stopped ~on safety related instrumentation piping support selection in October, 1981. The history also indicates the times when various instrumentation line
and small bore process pipe activities had been started.
(For example, safety related small bore process piping support selection started in January, 1983). The history demonstrates that Site Quality Assurance was actively involved in this area.
INSTRUENTATION
, ' Upon approval of Phillips, Getschow Company Procedure PGCP-22, Rev.
i 1, safety related instrumentation line support selection started in
July, 1981. After enough work had been completed so that a representative sample could be taken, this area was checked by i Commonwealth Edison Company Quality Assurance in an audit of ' October,1981. This audit identified deficiencies that are summarized as follows: 1.
Incorrect calculations 2.
Improper calculation reviews 3.
Three dimensional restraints not used per ECN 2194 4.
Adjacent line weights not used in line weight calculations 5.
Revision levels of applicable isometric drawings not listed on calculation sheets 6.
System component weights obtained from an uncontrolled source (uncalibrated scale) 7.
Quality Control not monitoring instrument group activities 8.
Documented training not given to Procedures PGCP-21 and 22 . l 9.
Interface document not clearly written , 10.
Organization chart in error . . . -
. . - 34 - ' Response to Item Ad (cont'd) The details of these items, including Quality Assurance follow-up work, corrective actions, and item close-outs, are described in the audit close-out surveillance reports. This audit resulted in a stop work action being placed on Phillips, Getschow Company until February, 1982. All items were resolved and closed by March, 1982.
" As an additional follow-up to the October, 1981 audit, an audit was performed in July, 1982. The concerns of the October,1981 audit were re-checked _as evidenced by approved checklist questions 1, 2, 3, 4, 5, 10, 11, 12, 14~, 15, 16, and 17. All question areas were found acceptably implemented. At that time, based on the audit history, Commonwealth Edison Company Quality Assurance believed that instrument support selection was being performed in an acceptable manner, and that Phillips, Getschow Company was implementing their procedures in this area.
S*LL BORE Small bore process pipe support selection started in January, 1983 upon approval of Revision 2 of PGCP-22 which then added support selection for small bore process pipe. Again, after work had been completed so that a representative sample could be taken, small bore pipe support selection was checked and instrumentation line support selection was re-checked in July, 1983 during audit QA-20-83-33. It was identified that Phillips, Getschow Company Procedure PGCP-22 did not give the step-by-step method for performing support selection calculations; that the procedure did not reference the current applicable ECN (4566); and that information on the calculation sheets was unclear or incomplete. This resulted in PGCP-22 being revised to more specifically define the methodology of performing support selection calculations. Revision 8 of this procedure was given interim approval by Commonwealth Edison Site Quality Assurance j on Novenber 10, 1983, and was accepted by Sargent and Lundy eq
December 2, 1983.
' Thoucf the above deficiencies were identified, for the calculations reviewed in Quality Assurance Audit 20-83-33, no cases were identified where calculations were being incorrectly performed or undersized pipe supports were being selected. The first process ! pipe support package was issued to the field for installation in August, 1983.
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. . . - 35 - Response to Item 4d (cont'd) Also, audit QA-20-83-33 identified that small bore pipe and instrumentation line support selection training files were inco@lete. Corrective actions were defined and implemented to correct this item as well.
Subsequent to the NRC inspection, Site Quality Assurance continued to audit this area. Site Quality Assurance audit QA-20-83-49 dated 10/20/83 specifically audited support selection activities and design document control related to support selection work. Three , (3) findings were identified which are summarized as follows: 1) Arithmetic errors were found in support selection calculations.
2) Drawings used to locate component supports were not verified "as constructed" drawings.
3) Drawings used as input for calculations were not the most current revision.
Each of these items has had corrective actions defined and completed, and verified by Site Quality Assurance as having been implemented. This audit was recently closed on 3/16/84.
In December, 1983, Quality Assurance audit 20-83-62 checked the implementation of Phillips, Getschow Procedure PGCP-22, Rev. 8, which had been revised to more clearly delineate and refine the technical support selection requirements provided by S & L in ECN 5776. Fifty-five (55) supports were reviewed in detail and no errors were identified indicating that the methodology used at that time was adequate to perform the support selection in an acceptable manner. As part of a recent audit of Phillips, Getschow Company, QA-20-84-518 dated 5/4/84, support selection was again checked and in this area, one (1) observation was identified for which ! corrective action has been defir.ed.
As of June,1984, the activities discussed above are being acceptably performed. Site Quality Assurance will continue to monitor this activity to assure proper compliance.
Comonwealth Edison Company overview of contractors continues to be improved as described in Attachment C.
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- _--. .- -i , . . 4- - 36 - COMEALTH EDISON COWANY ' RESPONSE TO INSPECTION REPORT 50-456/83-09 and 50-457/83-.09
i ITEM OF N0fCOWLIAPCE: ' I 5.
10CFR 50, Appendix B, Criterion VI, requires that measures be established to control the issuance of documents and these measures assure that changes to those documents are reviewed for adequacy and , approved for release by authorized personnel and are distributed to ' and used at the location where the prescribed activity is performed.
. Commonwealth Edison Company Quality Assurance Manual, QR No. 6 0, Paragraph 6.1, requires that a document-control system be used, including changes, and the documents and changes be reviewed and approved for release by authorized personnel. QP No. 6-2, Paragraph . 4.3.1, requires that field changes to drawings be submitted with a ! ! Field Change Request.
Contrary to the above, adequate measures had not been established to control field changes to drawings being made during the installation , ' of ASE Boiler and Pressure Vessel Code, Section III, Class 2 and 3, 2" and under piping. Craft personnel had been making field changes i to the drawings by rerouting lines, assigning weld nursers, and adding material which resulted in a lack of necessary control of < approving,. updating, and releasing drawings.
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. . . - 37 - Response to Item 5 RESPONSE Commonwealth Edison Company acknowledges that control of field changes to drawings required upgrading. The Phillips, Getschow Company re-routing of ASE, Class 2 and 3, small bore piping was allowed by Specification F/L-2739. Phillips, Getschow Company Procedure, QCP-821, Installation and/or Field Routing of Two Inch and Under Process Piping Systems A5E Classes 1, 2, and 3 - _ reflected the Specification requirements and procedural controls necessary to conduct re-routing. These controls involved drawing changes by Production, review of weld and bend additions or deletions by Quality Control and the ANI, and red line marking of actual field routed conditions. Commonwealth Edisori Company agrees that a review of proposed field re-routes by the contractor Engineering Department does add more assurance that important safety considerations are not bypassed.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED . Phillips, Getschow Company Procedure, QCP-821 was revised via Supplement, Revision 2, dated Aly 23, 1983 to require Phillips, Getschow Company Engineering Department review and approval of piping re-routes prior to installation. The method of Engineering Department review was further enhanced in Revision 6 to QCP-B21, dated October 10, 1983. The as-built routing of previous piping installations is currently being recorded. This work is being performed to Phillips, Getschow Company Procedure PGCP-40, Verification, Preparation and Transmittal of "As-Constructed" l Drawings. The procedure est&lishes the criteria for quality control verification of dimensional piping configurations.
CORRECTIVE ACTION TAKEN TO PREVENT RECURRENCE QCP-821, Revision 6, greatly increases the Engineering Department involvement in the preparation of initial small bore piping installation packages, the review of proposed re-routes, and the preparation of revised small bore piping installation packages.
Additionally, the re-organization of the Phillips, Getschow Company , l Engineering Department, plus the addition of personnel, has led to greater contractor engineering involvement in the Phillips, Getschow Company day-to-day activities.
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. . - 38 - Response to Item 5 (cont'd) DATE OF FtLL COWLIAPCE i The organizational and procedural changes are complete. Full inplementation of QCP-821, Revision 6 was completed in early 1984.
As-builts of previous installations are expected to be completed prior to December 31, 1984.
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. .- . - . _ . _ _ _ _ _ _ _. _ _ -.. _ ... _. . . - 39 - CO>NONEALTH EDISON COWANY it i RESP 0PeSE TO INSPECTION REPORT ! , 50-456/83-09 and 50-457/83-09 ' ITEM OF NONCOWLIAPCE: , 6.
10 CFR 50,. Appendix B, Criterion II, requires, in part, that a . quality assurance program be established which complies with the ! requirements of Appendix B and that the program be documented by j written policies, procedures, or instructions and carried out in accordance with these instructions. The quality assurance program ' shall provide control over activities affecting quality and shall '
provide for indoctrination and training of personnel performing - activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained. Criterion III requires, in ' part, that measures be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and
instructions and that these measures included provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled. Criterion III also requires that measures be established for the identification and control of design interfaces and for coordination among participating design organizations; that the measures include the establishment of procedures among participating design organizations for the review, approval, release, distribution, and revision of documents involving design t interfaces; and that the design control measures provide for
verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing ! program."
! Commonwealth Edison Company Quality Assurance Manual, QR No. 2.0, i Paragraph 2.2, requires that the Quality Assurance Program be applied to safety-related systems,in order to meet the requirements of ASPE, Appendix B to 10 CFR 50, and certain provisions of ANSI , N45.2 and N18.7. QP No. 3-1, Paragraph 2.0, required design requirements be applied and Paragraph 3-1 required the Architect / Engineer review and distribute revised documents.
' Sargent and Lundy (S&L) Specification F/L-2739, " Piping System ! Installation (Section III and Non-Section III)...Braidwood Station
Units 1 and 2," Paragraph 301.11, " Installation of 2" and Under l-Piping," controlled the basic field routing of each 2" and under ! piping system, including site design of safety-related small bore piping classes B, C, and H for operating temperatures up to 1500F maximum and field alteration of original system layouts and field
selection of supports / restraints by calculation based on Architect / Engineer provided guidelines.
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, . 40 - - ITEM OF NONCOWLIAICE: (cont'd) , , Contratry to the above, the licensee's control of site designed small bore (2" and under) process and instrumentation piping systems was considered inadequate and ineffective based on the following deficiencies: J a.
The programs and procedures established by the licensee and ' ' the Architect / Engineer (Sergent and Lundy Engineers (S&L) , prior to October 1983, did not provide sufficient assessments and verifications of Phillip, Getschow Conpany design capabilities prior to authorizing field routing of Class 2 and 3 small bore piping and field design of supports / restraints.
The lack of assessments and verification resulted in inadequate understanding of the Sat specifications by Phillips, Getschow Company to ensure the field routing of small bore piping was performed within the design requirements. Furthermore, the field routing of Class 2 and 3 small bore pipes, without detailed drawings being issued by
S&L or PG, resulted in the licensee's established Quality ' Assurance Program requirements being bypassed and prevented
the timely identification of nonconforming conditions.
' b.
The Phillips, Getschow Company small bore pipe routing
procedures lacked specific quantitative field design, installation, and inspection criteria to provide clearance i and/or separation from equipment and components as required by S&L specification, F/L-2739, Paragraph 301.11.
. c.
Procedure PGCP-22 requirements had not been completely i followed for small bore piping calculations performed by PG for lines 1CCE3AA-1/2", ICCE3BA-1/2", 1D008BC-2", and s ' 100D884-01.
! d.
Field Engineer authorities, duties, and qualifications were
not fully delineated in the PG Quality Assurance Manual, Rev.
t 0, dated Septenber 26, 1983, in that some of the specific work functions being performed by field engineering, such as pipe hanger design and calculation, were not adequately described.
e.
The PG training program was considered to be inadequate and
' ineffective based on the numerous errors identified in the PG i.
hanger calculations.
f.
The use of the Information Reg'est System by PG, in lieu of - . the Field Change Request (FCR) system, compromised the final design change acceptance review and approval.
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_ . _ _ -. _ _ _ _ .. , $ .. , l - 41 - ! i i~ Response to Item 6a
RESPONSE i Commonwealth Edison Company does not believe that the above Item
[456/83-09-09(A); 457/83-09-09(A)] is an exanple of a violation of . 10 CFR 50, Appendix B, Criteria II or III. Rather, we believe the
' intent of Criterion II and III have been met by the program established for small bore piping design and installation.
. . ! The Item of Non-Compliance includes the concern that the Phillips, Getschow Company is performing design activities during the field
routing of Class 2 and 3 small bore piping and during support ' selection activities. In the October 24, 1983 site meeting held > with N E representatives, Commonwealth Edison stated that the i l Specification wording allowed Phillips, Getschow Company to re-route i small bore piping when required to clear conflicts or interferences j-within certain pre-approved guidelines given in the Specification, which when followed, do not compromise the design basis of the piping. The conceptual pipe routing drawing,' initially designed by d . Sargent & Lundy, when used in conjunction with the Specification, constitutes an approved design at all times. Furthermore, submittal - s of "as-built" piping drawings to Sergent & Lundy was required.
Finally, the as-built design will be reviewed prior to system . acceptance. Commonwealth Edison Company demonstrated how the Specification wording was sufficient such that the re-routed piping met three (3) design checks (functionality, seismic interaction and piping stress). Additionally, Conmonwealth Edison demonstrated how this small bore piping program was controlled from start to finish, . and represented an efficient method to achieve a well designed t piping system (i.e. minimize snubbers, etc).
Additionally, during the October 24, 1983 site meeting, Commonwealth ' Edison and Sargent and Lundy discussed the reasons why the support selection guidelines given to Phillips, Getschow Company to select , supports are analogous to a construction drawing. Sargent and Lundy authorized the support selection guidelines. They represent a pre-calculated, pre-approved set of span length and support type
selection rules which Phillips, Getschow Company must follow.
" Phillips, Getschow Company cannot deviate from the rules to create t unique support location and types. For situations where unique support locations or types are required, Phillips-Getchow Company ' routinely requests Sargent & Lundy to perform this selection and a-design check. The legal authority (i.e. Professional Engineer's , stamp) remains with Sargent and Lundy under the guidelines; ' . ~ Phillips, Getschow Company does not Professional Engineer stamp the i support drawings generated in the selection process. Phillips j Getschow Company is not the design organization.
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. . - 42 - Response to Item 6a (cont'd) It remains our position that the Phillips, Getschow Company support selection activities were not design activities.
During the Decenber 20, 1983 Enforcement Conference Connonwealth Edison Company presented a chart indicating the difference between LaSalle County Station and Braidwood Station small bore piping support design activities. This difference resulted because of the assessment made by Connonwealth Edison Company and Sergent and Lundy that small bore piping support " design" activities should remain with the Architect / Engineer, and should not be placed with the Piping Contractor.
Commonwealth Edison Company plans no additional corrective actions regarding our piograms for assessing contractor capabilities. We will continue to monitor and verify compliance of contractor activities with Specification requirements.
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. . . - 43 - Response to Item 6b ESPONSE Commonwealth Edison Company acknowledges that the Phillips Getschow Conpany small bore pipe routing procedures and the Sargent and Lundy Specification F/L-2739, required upgrading to clearly delineate quantitative clearance requirements for re-routed piping. PGCP-40, Verification Preparation and Transmittal of "As Constructed" Drawings, Revision 0, dated May 31, 1983 Included a requirement to note on the "as-constructed" drawing when the piping installation was within 3 inches of another installation and indicate the point of that condition. This post-installation check went beyond the current Specification requirement, and did provide the Architect / Engineer the opportunity to evaluate clearances of piping from other installations.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEWD Sargent and Lundy Specification F/L-2739 was revised to require a mininun 3 inch clearance requirement of piping components from all other installations. Phillips, Getschow Conpany revised their piping installation procedures to require a contractor engineering department review of proposed field re-routes for conformance with Specification requirements prior to installation.
The notation of piping installations within 3 inches of another installation per PGCP-40 will determine if previous installations meet necessary clearance requirements.
CORRECTIVE ACTION TAKEN TO PREVENT RECURREPCE Implementation of revised piping installation procedures should assure that proper clearance requirements are reviewed prior to re-routing.
Commonwealth Edison Conpany and Sergent and Lundy plan to conduct ary assessment to ascertain if other site contractor's specifications and drawings adequately define component clearance requirements.
Additionally, a comprehensive plant walkdown is planned prior to Fuel Load to ascertain and resolve apparent component clearance problems.
.
Response to Item 6b (cont'd) DATE OF FtLL COWLIAKE .. Specification F/L-2739 and Phillips, Getschow Conpany procedural revisions were completed in February, 1984. The assessment of other site contractors and our overall approach to clearances is in progress, and is expected to be conpleted in August,1984. The comprehensive plant walkdown and any required corrective work will be complete prior to Fuel Load.
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. . . - 45 - Response to Item 6c RESPONSE Commonwealth Edison Company acknowledges this Finding.
CORRECTIVE ACTION TAKEN AND RESlLTS ACHIEVED The supports for lines ICCE3AA-1/2", ICCE304-1/2", ID0D88C-2" and ID00BBA-01 have been sent to Sargent and Lundy for review. Sargent and Lundy has also conducted a review of all safety-related Phillips, Getschow Company support selections on process piping.
Their review of 172 supports, indicated that 3 supports require installation tolerance adjustment, and 14 supports require re-calculation to the revised Phillips, Getschow Company support selection procedure. A field review indicated that the three supports were installed within the revised installation tolerance.
The re-calculation of the 14 other supports has been completed.
Commonwealth Edison Company Site Quality Assurance performed a special audit of support selection activities (Audit No.
QA-20-83-49). Although some calculational deficiencies were identified, no cases were found which required a physical change to the installed supports.
CORRECTIVE ACTION TAKEN TO PREVENT RECURRENCE , Sargent and Lundy has revised the piping support guidelines to better clarify their requirements such that support selectors do not need to interpret the guidelines. Procedure PGCP-22 Revision 8, dated 11/9/83 has been issued to enhance the procedure itself, as well as its implementation and training aspects. The procedural revision provided for better calculational consistency and reduction of the chance for error. Extensive re-training has been given to support selection personnel. Additionally, Sargent & Lundy has conducted a special technical audit of Phillips, Getschow Company support selection activities. Lastly, Site Quality Assurance will continue to monitor support selection activities by audit and surveillance.
DATE OF FlLL COWLIAtCE . The guideline changes, procedural changes and re-training have been completed.
The Sargent & Lundy technical audit and necessary corrective actions have been completed.
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. . . - 46 - Response to Item 6d ESPONSE Commonwealth Edison Company acknowledges that the Field Engineer authorities, duties and qualifications could have been more fully delineated in the Phillips, Getschow Company Quality Assurance Manual, dated August 26, 1983.
CORRECTIVE ACTION TAKEN A m RESLLTS ACHIEVED Phillips, Getschow Company initiated a change to their @ ality Assurance Manual changing Section 1.19, " Field Engineer" to read " Project Engineer". His duties are explained in general terms in the Quality Assurance Manual. Phillips, Getschow Company Engineering Policy EP-1, Revision 0, dated February 27, 1984, Engineering Personnel Qualifications and Review Criteria for Responsibility Assignment, more fully delineates the duties of the Engineering Department personnel.
CORRECTIVE ACTION TAKEN TO PREVENT ECUREEE Phillips, Getschow Company initiated broad management changes within their site organization on August 1, 1983. The management changes included a new Site Manager, Project Engineer, Assistant Project Engineer, and four Engineering Group Supervisors among others. The new management reviewed and more completely defined not only the Project Engineer's, but all engineering personnel job functions and responsibilities. This review resulted in a more structured organization.
' DATE OF FlLL COW LIAT E , The Phillips, Getschow Company management review and re-organization was completed on February 27, 1964.
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.: . . . - 47 - Response to Item de ESPONSE Commonwealth Edison Company does not dispute the MC assessment that ,the Phillips, Getschow Company training program was inadequate.
Commonwealth Edison Company Site Quality Assurance Audit No. 83-33 (Aly, 1983) identified the need for training program improvements.
Phillips, Getschow Company Procedure PGCP-22, 2" and thder and 2 1/2" - 4" Process and Instrument Line Supports in Category I Hu11 dings. Revision 7, dated April 16, 1953, required the Field Engineer supervisor to be responsible for training of qualified personnel to perform pfping layout and support selection. Phillips, Getschow Company Procedure, PGCP-29, Qualifying and Trainin3 Procedure for Phillips Getschow Company Field Hanger Selec; ion Personnel was rererenced in rur-22, Revision 7.
The training Procedure, PGCP-29, establishes the qualification and training requirements for personnel performing support selections. The basic requirements for support selection personnel include the following: a.
experience of one (1) year in support selection or a high school education.
, b.
documented training in PGCP-22.
c.
familiarization with applicable project documents (i.e. piping line lists, piping design tables, support detail drawings, etc.). d.
documented on-the-job training.
e.
proficiency requirements / reviews.
A review of training records indicates that the active and inactive support selectors in October, 1983 had the necessary training per PGCP-29. These records are available at the site for NR: review.
CORECTIVE ACTION TAMEN AND RESIATS ACHIEVED Sergent and Lundy completed an independent review of previous process piping support selections. This review amounted to an independent design check of Phillips, Getschow Co many support - selection work. The independent review results (discussed under Item de) are available at the site for review.
Phillips, Getschow Company has re-written PGCP-22 (Rev. 8) to enhance the procedure itself, as well as it's iglementation and training aspects. The procedure re-write reflects improvements by the new Phillips,ify any support selection guidelines.Getschow Company manage and Lundy to clar The procedure now specifies a more consistent methodology by which a
. . h - 48 - Response to Item 6e (cont'd) selector could better select and document calculations for individual supports. It highlights and reinforces the Sargent and Lundy requirements for the selector so he could more effectively select and calculate supports. Additionally, training requirements of PGCP-29 have been written into PGCP-22 (PGCP-29 has been deleted) and training has been expanded in scope, quantity and intensity, including the addition of a proficiency test. All selector personnel have been re-trained to PGCP-22, Revision 8.
A total review of recently completed support selection has been conducted by Sergent and Lundy and Commonwealth Edison Company to ensure correct procedural implementation. All reviews and audits indicate acceptable implemente. tion of PGCP-22, Revision 8.
CORRECTIVE ACTION TAKEN TO PREVENT RECURRENCE In December, 1983, Commonwealth Edison Company Quality Assurance conducted a technical audit (20-83-62) that checked the implementation of Phillips, Getschow Procedure PGCP-22, Rev. 8, which had been revised to more clearly delineate and refine the technical support selection requirements provided by Sargent and Lundy in ECN 5773. Fifty-five supports were reviewed in detail and no errors were identified which indicates that the methodology used at that time was adequate to perform the suppport selection in an acceptable manner. PGCP-22, Revision 8 training will continue on an ongoing basis.
DATE OF FlLL COWLIAPCE All procedural changes and re-training have been completed.
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. - -. . . - 49 - Response to Item 6f RESPONSE
Commonwealth Edison Company acknowledges this Finding.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Phillips, Getschow Company initiated a review of all previous Information Requests (irs) to ascertain whether other design information was obtained via the IR system. The review included a check to ensure that any applicable design information had been incorporated into permanent design drawings and specifications. The Phillips, Getschow Company Information Request form has been reviseo to include the requirement that design information must be transmitted via an Engineering Change Notice (ECN) or Field Change Request (FCR), and the IR itself cannot direct design change actions.
Phillips, Getschow Company personnel training programs now include instructions stating that " verbal instructions cannot alter design documents being utilized".
A review was made of design documents being utilized by Engineering Department personnel. Out-of-date documents have been purged.
Procedure PGCP-22, Revision 8, Section 7.8 specifically addresses these concerns, and Phillips, Getschow Company Procedure, PGCPl.1, Control of Engineering Change Notices (ECN), Field Change Notices (FCN), Field Change Requests (FG) and Field Problem Reports (FPR) was revised to more ticfitly control the usage of design documents.
A Work Instruction, PGWI-3, Clarification and Augmentation of Phillips, Getschow Company Design Change Revision Review (ECN, - FCN, FCR, DRN, Specification Changes, Etc.) was written to describe and clarify the method by which Change Documents are reviewed and processed by the Field Engineering Supervisor (Project Engineer).
CORRECTIVE ACTION TAKEN TO PREVENT RECURRETE An increased emphasis has been placed on document control within the Phillips, Getschow Company organization (ional and procedural changes as also discussed in Attachment C.
The management, organiza which have taken place should prevent future document control problems.
. DATE OF FLLL COWLIANCE The IR review and any required dispositions are expected to be complete prior to August 1, 1984.
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50 - ' - ATTACHENT B - COMALTH EDISON COWANY { ESPONSE TO LMESQ.VED ITEMS l i
1 4%/83-09-04 (A), 457/83-09-04 (A) j 456/83-09-04 (B), 457/83-09-04 (B) I' The Reference (a) inspection of the verification program for the installation of safety-related piping materials revealed that Phillips, Getschow Company did not have a documented inspection program for quality control inspectors to examine small bore piping conponents at installation to assure correct ' material usage. Therefore, quality control inspection records j verifying correct material installation for small bore piping i did not exist.
! t In addition to the small bore piping programmdtic problems, i Phillips, Getschow Company did not have a documented { inspection program for quality control inspectors to verify ' ! correct material at installation for large bore piping prior l to Revision 12 of the Phillips, Getschow Company Quality ' Assurance Manual, dated November 19, 1982. Therefore, quality l control inspection records' verifying correct material at
installation for large bore piping did not exist prior to l November 19, 1982.
I i ! DISCUSSION l i
Phillips, Getschow Company Procedure QCP-821, Installation and/or i~ Field Routing of Two Inch and Under Process Piping systems A5E -
Classes 1, 2 and 3, established the procedural controls for inspection and verification of correct small bore process piping ' , ! material. Phillips, Getschow Company Audit No. 83-8f0 (April 26, 1983) identified a Finding, whereby the verification on the Production drawing of different heat numbers in the case where more e i than one (1) heat number per drawing was being used, was not completed. In response to NRC concerns related to material traceability, Comonwealth Edison Company filed a potential 10 CFR.
l 50.55(e) deficiency report in July, 1983. This 50.55(e) report stated that Quality Control verification of heat or mark nunbers of , installed piping systems was not adequately documented.
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. . - 51 - CORRECTIVE ACTIONS TAKEN AND RESU.TS ACHIEVED
Procedure QCP-821 was revised in June,1983 to require verification of Code small bore material heat nuters on drawings. Specifically, the Quality Control inspector would verify all entries of traceability numbers made by Production and this verification would be documented by initial and date.
In order to establish a level of confidence that material traceability exists for previous Code small bore piping installations, Phillips, Getschow Company began traceability ~ verifications in August, 1983. This verification was based on random samples of previously installed Code small bore piping selected in accordance with Military Standard MIL-STD-1050.
The sample inspection program performed by Phillips-Getschow is complete. The preliminary results were reviewed by NfC personnel as documented in the NFC Inspection Report Nos. 50-456/83-09 and 50-457/83-0 9.
The sample inspection program identified a small ntnber of cases in which installed piping material was not in compliance with design requirements. Additionally, a Comonwealth Edison Site QA Audit 20-93-33 dated July 15, 1983, identified a case in which installed piping material was of a code class different from that required by the design. As a result of this sample inspection program and subsequent discussions with NfC personnel, we have since developed the Piping Heat Ponber Material Traceability Verification (MTV) Program.
CORRECTIVE ACTION TAKEN TO PREVENT RECURREPCE The MTV Program includes field inspections for material markings and reviews of supporting installation documentation for material traceability. A comparison of field markings against traceable documentation will be performed to establish the validity of the existing documentation as an acceptable means of maintaining traceability. The scope of this program includes ASE small bore piping installed prior to August 31, 1983, and ASE large bore piping installed prior to Novenber 30, 1982. (Documentation of the verification of material traceability by QC personnel has been generated for piping installed subsequent to these dates.) This Program will ensure that the installed material is traceable and that the material is in accordance with design requirements.
Details of this Program are contained in Phillips-Getschow Procedure QCP B31 which is available on site for review.
L
.:: . . - 52 - The procedure requires completion of the following steps: 1.
A material verification field walkdown on 100E of previously installed piping will be completed. The material heat nu mer will be recorded and/or verified by a Quality Control inspector. A check will be made to ensure that the field verified heat number is approved for use at Braidwood Station.
2.
A Quality Control verification will be made of field verified material heat numbers against the heat nu@ers recorded on the Stores Request for each installation package. This verification will establish that material withdrawn from Stores was installed in the correct location.
3.
A Quality Control verification will be made of field verified material heat numbers to ensure that the correct material is installed for the specific application.
4.
For those cases where material heat markings are no longer available in the field, a Quality Control review will be made of the Stores Request to verify that the material was approved for use at Braidwood Station and was the correct material for specific application.
The necessary installation and quality control documentation will be updated to record the above verification program. Non-conformance reports will be generated to disposition material which cannot be verified by the above program.
DATE OF FULL COWLIAPCE Procedure revisions and training to the revised procedures are couplete. The 100% material verification program has been initiated and is expected to be completed prior to April, 1985.
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. . - 53 - ATTACHENT C C0600NEALTH EDISON COWANY OfCANIZATIONAL IDWOOD STATION Since the Commonwealth Edison and NfC Enforcement Conference held in August 1982, Commonwealth Edison has performed a number of evaluations of various past and ongoing construction work at Braidwood Station. Independent evaluations were performed by experienced Comonwealth Edison Construction and Quality Assurance Engineers (known as the Technical Support Croup), and by a team of experienced engineers from a construction management organization, Daniel Construction Company. Further, several unusually extensive Commonwealth Edison evaluations have been performed by the General Office and Site Quality Assurance Departments, including the IPO Self Evaluation (20 people-3000 manhours) and a 35 person team audit (2800 manhours). These various reviews, evaluations and audits involved all site contractors and included both present and past work.
In early 1984, Consnonwealth Edison Conpany enployed a senior management evaluation team led by Vice Adn. J. D. Williams (Ret.) to conduct an extensive review of the Braidwood Project. In June, ' 1984, I r0 conducted an extensive construction site evaluation.
This is yet another step taken by Commonwealth Edison Company management to provide attention to, and involvement in support of the Commonwealth Edison Company Quality Assurance Program.
As a result of all of these efforts, significant organizational and management changes have been made within the Comonwealth Edison organization, as well as within our site contractor organizations.
A description of the Commonwealth Edison Company organizational and management changes follows.
A fulltime Project Manager was assigned to the Braidwood Project in early Septent>er 1982. This change was made to ensure that the Station.y management attention was constantly focused on Braidwood necessar AnewProjectMechanicalSupervisorwasassignedwithintheProject Construction Department. This individual has extensive construction and quality assurance experience received at our LaSalle County and Dresden Stations. The individual has been working for a period of time within the Phillips, Getschow Company organization for the ' purpose of assessing first-hand the effectiveness of their operation.
In late 1982, an individual from the Technical Support Group was retained in the position of Project W elity Control Coordinator.
This individual reported directly to the Braidwood Project Manager.
The Project Quality Control Coordinator was charged with the responsibility for follow-up on Technical Support Group recommendations, and to coordinate Braidwood Site responses to NRC and Quality Assurance Department items.
! . . - 54 - Throu@out 1983, six (6) additional experienced Construction Field Engineers joined the Project Construction Department. Many of these engineers have experience from our LaSalle County Station.
In mid-1983, the Braidwood Site Project Field Engineering Group was established. Additionally, the project Field Engineering Manager, Supervisors and most of the statf engineers all have extensive LaSalle County engineering or construction experience.
In order to effect the timely resolution of construction installation problems, Commonwealth Edison Company management directed the "on-site" Sargent and Lundy Engineering Group to be increased. The staffing level of this group grew from approximately 20 to 329 by the end of 1983. Moving the engineering effort closer to the field was perceived to be a major method of improving the communications between construction and engineering, and assuring the timely resolution of field problems. Nearly 80 of the Sargent and Lundy site engineering personnel came with experience from either our Byron or LaSalle County Station.
In order to incorporate our overall LaSalle County and Byron experiences in the area of system completion turnover and testing, Commonwealth Edison established the new posifion of Startup Superintendent for Braidwood Station. The individual assuming this position has extensive Byron startup experience and earlier Zion startup experience. This was perceived to be a major mechanism for incorporating both the overall methodologies, as well as the into the startup approach to be used at Braidwood Station.y Stations specific experiences gained at our Byron and LaSalle Count In April,1984, the Project Licensing and Compliance Group was established with a Superintendent reporting directly to the Braidwood Project Manager. The individual assuming this position has extensive LaSalle County technical and licensing background.
The formation of this group is to assure high level Project Management attention and responsiveness to NRC, Quality Assurance, and IWO matters.
This organization replaced the previous Project Quality Control Coordinator position.
Most recently, the former LaSalle County Station Construction Superintendent, who had been the Braidwood Project Field Engineering Manager since the inception of Project Field Engineering, became the Braidwood Project Construction Superintendent. Concurrent with this change, the former Project Mechanical Supervisor was promoted to a-newly created position of Braidwood Project Construction Assistant Superintendent. This arrangement allows the Construction Superintendent to devote the majority of his efforts toward Quality Assurance and NR: matters.
, .. . 55 - - Finally, there have been various enhancements in the Connonwealth Edison Company Quality Assurance Department. Recently, the reporting level of the Manager of Quality Assurance was changed from the Vice Chairman to the Chairman and President. This change was made to further assure full responsiveness to and interface with Quality Assurance by the Projects organization. Additionally, the new position of Assistant Manager of Quality Assurance was created, whose work location currently remains full-time at the Braidwood site. Several other changes in Commonwealth Edison Company Quality Assurance are delineated later in this Attachment C.
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. . . . 56 - CONTRACTOR WNAGEDENT APO QUALITY ASSURA>CE/ QUALITY CONTROL OTANIZATIONAL APO OWERVIEW CHANGES Following the Enforcement Conference in 1982, Commonwealth Edison Project r=rit met with management of all Braidwood Site Contractor, Production, and Quellty Control / Wality Assurance personnel. During these meetings the Igortance of quality and qualitydocumentationasatopprIorityamongallsiteactivitiesin cogerison to production oriented goals was stressed by Commonwealth Edison. Contractors were encouraged throu@ those meetings and other meetings to bring in the best available management talent in order to accomplish the Braidwood Project goals.
Phillips Getschow Comoony Oroanizational Channes As a result of the various reviews and activities carried on in early 1983, Commonwealth Edison Project Management determined the need to substantially increase the level of management talent in the Phillips, Getschow Company organization. Phillips, Getschow Company was encouraged to seek the best available people. Phillips, Getschow Company responded by hiring into their organization a nu eer of personnel previously employed by the LaSalle County Station machenical contractor. Specifically, beGinning August 1, 1983, Phillips, Getschow Company added a Site Manager, an Assistant to the Site Manager, a Site Superintendent, a Staff Assistant to Quality Control / Engineering, and a Pro t Engineer. In September and October, 1983, Phillips, Getschow added two Area Superintendents, an Area Assistant Superintendent, an Area General Foremen, and a Mi@t Superintendent. All the above individuals had prior nuclear experience with construction at LaSalle County Station.
In the Engineering area alone, besides the Project Engineer, Phillips, Getschow added an Assistant Project Engineer and four Group Supervisors with a contined total nuclear experience of forty-five years. Later seven other experienced personnel were added in the Engineering, area. To improve coordination with @s11ty SystemsTurnoverandTestingboup.EngineeringGroupdevelopeda Control on systems cogletion the When several concerns were identified in the quality documentation eres, the new Phillips, Getschow Company management established ehet came to be called the " Document Station Concept". This concept was based on Phillips, Getschow Cogeny's desire to have standardized and stringent control over all processed documents. Six Field Engineers were placed into four separate field documentation' stations. This Document Station Concept was successfully implemented at LaSalle County Station. Of the nineteen document te&nicians utt11 red for this concept, e1@ t technicians had previous LaSalle County experience.
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. . ' - 57 - c . Several changes were made in the Phillips, Getschow Company Quality Control organization. The organization was split into a field section and an office section. The overall Quality Control workforce was increased from 57 people to 125 people. A new Phillips, Getschow Company Quality Control Supervisor was assigned to the Braidwood Site.. Additionally, Phillips, Getschow Company assigned a General Forsman of Field Inspectors in order to provide more direct field supervision of the quality inspection efforts.- Phillips, Getschow Company also established the position of Lead Quality Control Technicisti with eight individuals functioning in that position. These individuals are involved in the document review areas. Three cf the.eight people had LaSalle County expe.lence.
, , . Phillips, Getschow Company revised their Quality Control Technician Certification Procedure and increased the number of quality control technicians from elyhteen to fifty-six. These technicians increased their involvement in the initial and final reviews of quality documentation. They also became involved in early implementation of the ASE Section III N-5 Review Program. The number of field inspectors increased from twenty-five inspectors to fifty inspectors. The increased number of field inspectors resulted in a s@stantial increase in the amount of 1& process construction work monitoring performed by Phillips, Getschow Cog eny Quality Control.
In October, 1982 a fulltime Qualit Assurance manager function was establishedonsItswithinthePhilIps,GetschowCogeny organization. Three additional Quality Assurance engineers were - . hired in early 1983. This group performs increased auditing and surveillance activities of the Phillips, Getschow Company work activities.
. - L. K. Comstock Company Oraanizational 01anoes Several management, engineering, and quality control organizational changes were made within the L. K. Comstock Company organization.
The mmber of ANSI N45.2.6 Level 11 inspectors was increased from 11 inspectors to 47 inspectors. The overall inspector workforce increased from 22 people to 51 people. Further when Wality Controlofficepersonnelwereadded,theoverallQualityCentrol manpower increased from 25 people to 64 people.
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. , '. . - 58 - Several @ality Control management changes and operational igrovements were made by L. K. Comstock Company. In November, 1982, a new Quality Control Manager was hired and charged with inproving the organization and retrievability of quality documentation. This individual was replaced in August,1983 when very little progress was made toward improving quality documentation retrievability. During 1983, a position of Supervisor of Inspectors was established, as were the positions of Lead Inspectors. This organizational change allowed better control over the inspection effort and assured timely completion of inspections. An inspection status / control system was implemented which allowed for timely and accurate determination of inspection status.
Fulltime Quality Assurance Engineers were hired by L. K. Comstock Company in 1982 and 1983. The amount of auditing and surveillance of the L. K. Comstock quality program was significantly increased with the addition of th::se quality assurance personnel.
In the area of document control, L. K. Comstock Company implemented inproved document tracking systems, replaced the Document Control Supervisor in February, 1983, and increased the number of document control personnel from seven people to fourteen people.
Pullman Sheet Metal Organizational Changes Pullman Sheet Metal increased non-production craft personnel from ei@ teen to e1@ty, and at the same time increased Quality Control /@elity Assurance personnel from three to nineteen. The Pullman Sheet Metal personnel increases were made in order to provide better control and review of documentation, and to inplement the various aspects of ongoing retroinspection programs.
Specifically, Pullman added several new departments including Survey and Research (5 Engineering and Document Control (9 people), ing Notices (5 people), people), Field Change Requests /Fleld Engineer and Correction Notices Group (3 people).
G. K. Newbera Organizational Changes Within the G. K. Newberg Company organization, Quality Control manpower was increased from three to six throughout 1983.
, Additionally, the G. K. Newberg site engineering department assumed greater responsibilities for preparation of traveler documents prior to issuance to the construction forces.
. . - 59 - CONTRACTOR AWAREESS OF QUALITY We are continuing our efforts to assure that all construction workers and their supervisors understand their role in building quality into our Braidwood Station. While we believe the results of reinspection and retroinspection programs conducted to date generally demonstrate that the requisite quality has been built into Braidwood Station, many of the identified problems concern the extent to which documentation is necessary to prove this requisite quality. It is to this aspect in particular that Comonwealth Edison Company has and is continuing to direct our efforts towards overall improvement.
To this end, the following has or will be accomplished: 1.
Regular meetings are held with contractor management including first-line supervisors to discuss quality (including.
docunentation) related matters.
2.
A special emphasis is being put forth by the Comonwealth Edison Company Project Construction Superintendent stressing that " quality is a production related function".
3.
The amount of craft and supervisory training has been substantially increased over the past six months.
, 4.
Many procedures have undergone significant enhancements.
5.
Management changes as described earlier have led to a greater awareness in performing quality work.
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. . .. 60 -- ComEALTH EDISON COWANY QUALITY ASSURANCE UNANIZAHuNRL AND DVtMVIEW CHANGES The CECO Audit and Surveillance program methodology was for CECO Quality Assurance to cover the 10CFR50 Appendix B Criterie and the contractors' Quality Assurance Program requirements but not each and every contractor procedure implementation. As is provided in the regulations, the subtier iglementation of the contractors' procedures is the contractors' responsibility under their program.
Assurance of this implementation is by audits of the contractors' auditing by CECO Quality Assurance. The key aspect to address the Region's concern was that more frequent and broader coverage by the contractor and Commonwealth Edison, particularly involving iglementation of contractor procedures, was needed to identify _ problems in a timely manner.
, As discussed in our response to Non-compliance Item 4, the subject contractors have included the auditing of active procedures in their audit schedules. Further guidance to Commonwealth Edison Company Quality Assurance personnel for performance of audits and/or surveillances as described below should ensure that contractor activities meet all established requirements.
The Quality Assurance overview of contractor work activities has been changed as described below.
1.
The Site Quality Assurance Organization has been augmented with experienced personnel from LaSalle County Site Quality Assurance as well as with experienced personnel being hired.
2.
The Quality Assurance Organization has been restructured to provide for closer and additional supervision of Site Quality Assurance activities. Specifically, an experienced manager has been assigned to a-new position, Assistant Manager of Quality Assurance, and two additional supervisors have been added to the Site Quality Assurance Organization.
3.
Site Quality Assurance manpower levels have been increased from twenty-five Commonwealth Edison Company personnel in January 1983 to the present level of forty-five.
4.
Quality Assurance auditing has been improved by the addition of an Audit Coordinator and the increased frequency of audits of the major site contractors about doubled such that about 10 to 12 audits are being conducted each five to six weeks.
- Audits are being performed with varying scope from very broad to very specific questions. Identification of the root cause for identified deficiencies is being eghasized. Guidelines have been established to assure that sufficient samples of documentation are being reviewed.
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Quality Assurance surveillarce activities have been enhanced by the.use of standardized checklists. The rationale behind , ' this approach is that our Quality Assurance people will have j positive direction as to what they must look at, that the ' checklists will provide a format to write objective evidence as the surveillance is being performed, that the objective evidence can be used in place of extensive report writing, and that the surveillan::e activities can be reproduced and verified at a later date by supervision.
6.
Overinspections by the Independent Testing Agency (PTL) at Braidwood Station are being increased from about 105 to a goal ,
of 255. As a result, the nunber of PTL inspectors has been increased to perform.the overinspections for Comonwealth . Edison Company Quality Assurance. These inspectors cover the ' three disciplines of electrical, mechanical and structural, and are qualified to ANSI N45.2.6.
(The Unit Concept ' Inspections involve another seven to eight people.) Both the overinspections and the Unit Concept Inspections are each l headed by lead inspectors.
7.
As for the Independent Testing Agency, the manpower level has significantly increased due to the increased work coverage undertaken in the past 6-8 months.
A.
The PTL organization at the construction site has been restructured to provide: a) Project Manager - technically qualified with strong management characteristics.
b) Assistant Project Manager - technically qualified to direct the detailed work activities in the field.
. c) Two Group Supervisors , ' ! One to head all the NDE and other testing t - activ* ties.
The other to head the ove: Inspection, Unit - Concept Inspection and other inspection groups.
, ' d) Document Coordinator , e) Another Quality Assurance Auditor i f . - -. - - .. ---,-,--, , -. -,. -.,
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PTL has established a technical person in their Chicago Area Office to ensure tha PTL Organization at Braidwood Station is carrying out its responsibilities
acceptably. This overview is intended to ensure the ' inspectors and technicians are performing acceptably ou , a continuing basis.
Special enphasis is placed on the Independent Testing l Agency inspection activities because this is the point , l where there is significant coverage very shortly after the construction work is completed and is the process by which we have the largest opportunity to identify essentially all deficiencies. This should go a long way toward early identification of problems.
. C.
To ensure that PTL performs their work activities acceptably, additional direct coverage by Commonwealth Edison Company Quality Assurance has been established - over the daily activities of the Independent Testing Agency.
L.
Basically, a lead person, as in the past, will coordinate and adninister the contract activities. In , i addition, Commonwealth Edison Site Quality Assurance people have been assigned responsibility for the specific work activities. The specific work activities to be closely monitored by separate Quality Assurance ' people are the NDE examinations and other testing, and the Unit Concept Inspections. An additional Quality Assurance person is being brought to the site to oversee the 25% goal of overinspections. This narrow and.
, concentrated coverage by Site Quality Assurance should ensure and achieve positive results.
' These actions should enhance our opportunities to identify deficiencies and potential problems.
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