IR 05000456/1985006

Intervenor Exhibit I-ROREM-149,consisting of 850308 Incomplete Insp Rept 50-456/85-06 & 50-457/85-06 on 850204- 0301 & Notice of Violation.Violations Noted:Failure to Ensure Insp Personnel Have Acceptable Level of Capability

ML20214D677
Person / Time
Site:	Braidwood
Issue date:	10/03/1986
From:	Forney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
References
OL-I-ROREM-149, NUDOCS 8705210427
Download: ML20214D677 (5)

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r.A n s u i 6 a .s 6 U.S. NUCLEAR REGULATORY COMMISSION

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REGION III '

'87 AFR 22 P7 :24 ,

Report No. 50-456/85-006(DRP); 50-457/85-006(DRP) . $,p. -

Docket Nos. 50-456; 50-457 Licenses No.'CPPR-132; CPPR-133

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Licensee: . Commonwealth Edison Company Post office Box 767 Chicago, IL 60690 Facility Name:- Braidwood Nuclear Power Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, Illinois Inspection Conducted: February 4 through March 1, 1985 Inspector: R. N. Gardner r LM _

Approved By: , e /

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Date Inspection Summary Inspection on February 4 throush March 1.1985 (Report Nos. 50-456/85-006(DRP);

50-457/85-006(DRP))

Aress Inspected: Special, announced safety inspection of the Braidwood Con-struction Assessment Program (BCAP) in regards to licensee action on previously

, identified items, Construction Sample Reinspection (CSR) Documentation Review Checklists, invalidated BCAP discrepancies, CSR reinspection activities, and RSCAP,setivities. The inspection consisted,of 144 inspector-hours onsite by one NRC inspecto .

Results: Of the five areas inspected, no items of noncompliance were identified in three areas; two items of noncompliance were identified in the remaining areas (failure to ensure that inspection personnel have acceptable level of capability - Paragraph 3; and failure to take proper corrective action - Paragraphs 3 and 4).

I NUCLEAR REGULATORY COMW15110N l Docket No. W N MSI Official Exh. N l

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Ex. 12.f-2, .

Appendix NOTICE OF VIOLATION

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Co m nwealth Edison Company Docket No. 50-456 Docket No. 50-457 As a result of the inspection conducted on February 4 through March 1,1985, and in accordance with the General Policy and Procedures for NRC Enforcement Actions, (10 CFR Part 2, Appendix C), the following violations were identified: CFR, Appendix B, Criterion II, states, in part, that "The quality

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assurance program shall provide control over activities affecting the -

quality of the identified structures, systems , and components. . . . The program shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained."

Commonwealth Edison Company Quality Assurance Masual, Quality Requirement No. 2.0, Section 2.3, states, in part, that " Qualifications and certi-

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fications will be... established to meet the applicable requirements of i

. . . ANSI Standard N45.2.6. . . Contractor personnel engaged in inspection. . .

will be required to be trained, qualified, and certified to perform their specific activity in accordance with the above requirement ANSI M45.2.6-1978, Paragraph 4, states, in part, that " Personnel who are assigned the responsibility and the authority to perform functions covered by this standard shall have, as a miniassa, the level of capa-

, bility shown in Table 1. Table 1 requires a 1,evel II capability for personnel evaluating the acceptability of inspection and ====4aation

results. According to Table 1. Ievel I inspectors are authorised to act

) as data takers but they are not authorized to determine the acceptability i gt of construction activitie '

AfiY p Contrary t.o the above, the licensee's electrical contractor utilized Level I Quality Control (QC) inspectors for inspection and acceptance

of electrical welds. This practice involved 14 different Level I

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inspectors over a four year time period.

I j This is a Severity Level IV violation (Supplement II).

] CFR 50, Appendix B, Criterion XVI, states, is part, that " Measures

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shall be established to assure that conditions adverse to quality, such

} as...nonconformances are promptly identified and corrected."

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Commonwealth Edison Company Quality Assurance Manual, Quality Requirement l

No.16, Section 16.1, states, in part, that "A corrective action system will be used to assure that such items as. ..nonconformancies. ..which are adverse to quality. . .are promptly identified and corrected."

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s Ex.12.F-2, Appendix 2 l Contrary to the above, the following instances of failure to take proper

- corrective actions were identified: Although the Braidwood Construction Assessment Program (RCAP)

had identified that Level I QC inspectors had inspected and accepted construction activitie's, in violation of the require- I ments delineated in ANSI N45.2.6, this nonconformisg condition l was not documented as a BCAP observatio gf-phila ) j l Thirty-seven BCAP observations, which dealt with the lack of i QC verified " red-lined" record copy drawings, were. invalidated I by the RCAP taskforce even though the documented basis for the invalidation of the observations did not support the l invalidation gf.ol, Of b) l This is a Severity Level IV violation (Supplement II). l l

Pursuant to the provisions of 10 CHL 2.201, you are required to submit to this l office within thirty days of the date of this Notice a written statement or  ;

explanation in reply, including for each iten of noncompliance: (1) ,

corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause show .

March 8, 1985 ME/l)a_

R. 7. Warnick, Chief

Dated Projects Branch .

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Ex.12.F-2, Level I inspectors is questionable. Previous inadequacies in the training program for Level I electrical weld inspectors, as documented -

in NRC Inspection Report Nos. 456/84-07 and 457/84-07, increases the concern rega'rding the acceptability of welds inspected and accepted solely by Level I QC inspector This failure to establish and implement a program which assures that QC

, inspection personnel, who are performing activities affecting quality, i are trained and certified to the level required to adequately perform

! those activities is an item of noncompliance to 10 CFR 50, Appendix B, i Criterion II '(50-456/85-006-02; 50-457/85-006-C2) .

. Review of Invalidated BCAP Discrepancies

The inspector reviewed 37 BCAP observations which documented deficiencies identified during Construction Sample Reinspection (CSR) documentation reviews. The population for which the documentation reviews were per-formed was small bore piping configuratio The observations dealt with the lack of QC verified " red-lined" record copy drawings required by Phillips Getschow Co. (PGCo) procedures. While the observations were validated by CSR engineers, they were subsequently invalidated by Sargent and Lundy (S&L). The inspector was informed by Evaluation Research Corporation (ERC) personnel that IRC observation number 007 had been initiated by ERC to document the Independent Expert Overview Group (IEOG)

position that the S&L invalidations were unacceptable. The ERC obser-vation correctly concluded that in developing the "As Constructed" drawing, QC was required by procedure to verify the accuracy of the verification drawing and that at issue in the BCAP observations was the lack of the signature or initials of the certified inspector who performed the verification. Since the inspector who performed the verification was not known, the acceptability of that inspector's level of certification could not be determined, and therefore rendering the status of the inspection indeterminat The inspector subsequently reviewed the BCAP written response to the

ERC observation. This response stated that tS QC -signature on the verification drawing was not required as the 5 inspector who performed the field verification marked up the verification drawing copy as necessary and signed the "Stop Work Order" to signify completion of the

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QC verification. The BCAP response further stated that the BCAP Small Bore Pipe Configuration Document Review Checklist would be revised to

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reflect the QC signed "Stop Work Order" form as an acceptable alternative to the QC signed or initialed " Red-line" drawi:3 (This revision was i subsequently issued on February 1, 1985.) Finally, the DCAP response stated that observations describing the lack of a QC signature on the

" red-line" drawing previously processed as valid would be reprocessed as

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invalid observations. ERC concurred in the respons In reviewing this matter the inspector, accompanied by the Senior Resident Inspector, discussed the PGCo implementation of procedures QCP-40, Revision 3 and QCP-21, Revision 6 with PGCo engineering and QC personnel. As a result of these discussions the inspectors determined

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Ex.12.F-2,- . .

that the QC inspector who signed the "Stop Work Order" was not the QC

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inspector who p u formed the field verification but was a QC inspector who I worked in the QC office. h e the QC signed "Stop Work Order" is not an

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acceptable alternative to a QC signed or initiated " red-lined" drawing.

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h invalidated observations do identify a valid nonconforming condition

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regarding the Small Bore Piping Configuration documentation in that there

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was no record of the QC inspector who actually performed the field verification. Therefore, the acceptability of that inspector's level of certification remains indeterminat ,

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The invalidation of the 37 BCAP observations is not acceptable, is ,

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considered to be improper corrective action, and is a further example l of noncompliance to 10 CFR 50, Appendix B, Criterion XVI '

l (50-456/85-00,6-01(B); 50-457/85-006-01(B)). 1

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' CSR Reinspection Activities ,

! On February 19, 1985, the inspector witnessed the overinspection of a 4" conduit. The overinspection was performed by BCAP QA inspectors. The conduit had previously been reinspected by the BCAP taskforce. The CSR reinspection package number was

> CSR-I-E-CMD-054 while the conduit number was C2A5194. During the overinspection the inspector determined that the reinspection performed by the BCAP taskforce accurately documented the

, acceptability of the conduit, On February 20, 1985, the inspector, accompanied by the Resident

Inspector, inspected tw conduits which had previously been

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reinspected by the BCAP taskforce. h CSR reinspection package numbers were CSR-I-E-CMD-004 and CSR-I-E-CMD-044 while the conduit numbers were C2A0217 and C0A760 .

The inspectors concluded that the BCAP reinspections were performed in an acceptable manner.

f On February 26, 1985, the inspector witnessed the overinspections I

of three cable pans. N overinspections were performed by ERC inspectors. N cable pans had previously been reinspected by

the BCAP taskforce. The CSR reinspection package numbers were CSR-I-E-CBP-054, CSR-I-E-CBP-056, and CSR-I-E-CBP-057 while the cable paa numbers were 11678J, 216161, and 1905A. During the

overinspections the inspector determined that the reinspections i

performed by the BCAP taskforce accurately documented the acceptability of the cable pan On February 27, 1985, the inspector witnessed the overinspection of a large bore pipe support which had previously been reinspected by the BCAP taskfor e. N overinspection was performed by BCAP QA inspectors. N CSR reinspection package number was CSR-I-M-002-052 while the pipe support number was M-ICV 07065R. During the overinspection, the BCAP QA inspectors identified that the 1/2" offset dimension for the support to beam attactment was out of i

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