IR 05000456/1985051

Safety Insp Repts 50-456/85-51 & 50-457/85-49 on 851007-11 & 1028-1101.No Violations or Deviations Noted.Major Areas Inspected:Followup on Allegations,Electrical Installations & Pipe Supports

ML20137B366
Person / Time
Site:	Braidwood
Issue date:	11/19/1985
From:	Kropp W, Lerch R, Little W, Malloy J, Patricia Pelke NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137B337	List: IR 05000456/1985051 ML20137B333
References
50-456-85-51, 50-457-85-49, NUDOCS 8511260252
Download: ML20137B366 (12)

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U.S NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. . 50-456/85051(DRP);50-457/85049(DRP)

Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, IL Inspection Conducted: October 7-11, and October 28-November 1, 1985 Inspectors: P .' //!/9fS6 Date an.P&ge W. J. Kropp fl[/9!6f Date b* W R. M. Lerch f l /i 9 [8J'~

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h9 bdr J. A. Mall by 1///9 Bf

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Approved By: 1 m L' tie, Braidwood Project irector // f/86 Date~ /

Inspection Summary Inspection on October 7 through 11 and October 18 through November 1,1985 (Reports No. 50-456/85051(DRP); 50-457/85049(DRP))

Areas Inspected: Routine, unannounced safety inspection of activities with regard to licensee action on previous inspection findings, followup on allegations, electrical installations, and pipe supports. The inspection involved a total of 136 inspector-hours onsite by four NRC inspector ,Results: No violations or deviations were identifie PDR ADOCK 05000456 G PDR

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DETAILS . Persons Contacted'

Commonwealth Edison Company (CECO)

• Wallace, Project Manager

• C. Schroeder, Project Licensing and Compliance Superintendent

• 0.~Shamblin, Project Construction Superintendent

• G. Groth, Assistant Construction Superintendent

• T. Quaka, Quality Assurance Superintendent

• C. Allen, Project Licensing and Compliance

• P. Barnes, Licensing Engineer

• G. Nelson, Assistant Technical Staff Supervisor

• J. Jasnosz, Technical Staff

• D. Cecchett, Licensing Engineer

• C. Tomashek, Staatup Superintendent E. Netzel, Quality Assurance Supervisor R. Preston, Quality First Director E. Fitzpatrick, Station Superintendent L. K. Comstock (LKC)

R. Seltmann, Quality Assurance Manager / Licensing Coordinator R. Simms, Quality Assurance Supervisor R. Bower, Document Control Supervisor L Seese, Administrative / Status Assistant Quality Control Manager L. Phillips, Quality Control Inspector Licensee Action on Previous Inspection Finding (Closed) Violation 456/83-09-02(e); 457/83-09-02(e): Failure of L. K. Comstock (LKC) to remove voided drawings from the fiel During inspection 83-09 the inspector identified in June 1983 that Drawing-1-3515, Revision N, 9-17-82, was located at drawing Station The current. revision _was "S". Prior to completion of 83-09, the inspector was informed by the LKC Project Engineer that a complete audit of Station 5 had been performe Sixteen additional voided drawings were identified in the current stick files out of a total of 528 drawings located at the station (15 safety-related drawings). The inspector was further informed that corrective action was being taken to assure that all 44 stations are maintained in a current status, l

i Inspection Report 83-09 was issued on May 7, 198 The inspector L reviewed the licensee's response dated July 6, 1984. The licensee stated in part.that, "Between July 1983 and January 1984, sixteen (16) surveillances involving fifteen (15) documentation stations and a 100% check of the office engineering drawings were performed. As a result of the surveillances performed, 8,335 drawings were reviewed and 352 superseded drawings 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 100% check of all drawings was

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- subsequently perfdrme'd at this ' station.) . Additionally, between July - _ j

- 1983 and January'1984, L. K. Comstock Quality Control performed monthly l random drawing' control.surveillances. The results of these surveillances  !

indicate compliance with document control procedures."

.LKC: Procedures 4.2.'1, " Document Control" and 4.8.15, " Drawing, Specification and Procedure Document Control Inspection," are the

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applicable controlling procedures in this are LKC performed 1984

. internal audits of_these procedures documented.in Audit Report

'Nos. I-057-084- dated March 13, 1984, and I-059-084 dated April 18, 198 .

~ Audit;Repo'rt No. I-059-084 had three findings and four concerns which

- were closed by May 30, 198 Ceco'QA performed Surveillance No. 3439 dated Apriljll, 1984i which identified deficiencies in LKC's control 'f drawings, o FCR's,_and ECN, LKC's response to this surveillance indicated that all_the deficiencies

~ had been corrected and action to preclude repetition was in_ place.-

. ;c However,' subsequent CECO inspection on May 3,t1984, revealed that not . .

all of the deficiencies had been corrected. As: a result, . CECO: performed

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- Special Audit No. QA-20-84-585 in.May 1984. In addition to CECO

- Surveillance No.-3439, there had been five previous CECO QA audit

. findings or observations concerning LKC drawing control documented in Audit Nos. QA-20-82-41 (September 1982), QA-20-83-20 (April 1983),- .

QA-20-83-37 (August 1983), and QA-20-84-511 (February 1984). CECO Audit-No.nQA-20-84-585 also noted that in the case of LKC Audit No.-I-059-084,

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prompt corrective action was not requested or initiated when a significant deficiency was identifie Sargent & Lundy/LKC QC completed a field audit.of all drawings on May 17, 1984. The audit found 726 voided drawings of a. total of 38,795 (1.87%).

LKC' implemented a long' range plan to streamline the document control system which included:

- Reduce the numbers of field document station . Reduce the number of drawings at each statio ,

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. Change'the style of document master cards and reduce the .

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number of master card Eliminate void print files by the use of aperture cards, t Change the style and format of print transmittal forms and '

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reduce the number of field drawing transmittal . f' . Computerize transmittals and returns.

F 1 Restructure the document control department.

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CECO QA conducted Surveillance No. 3764, dated August 2, 1984, to review the status of the findings from Audit No.-QA-20-84-585. In the  ;

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surveillance, 506 drawings were reviewed at stations G4, 08, 09, 11, 13, and 16. Thirteen voided drawings were found in the field. LKC's immediate corrective action was to replace the voided drawings. LKC agreed to conduct a review of each document station and to conduct more

' training. The surveillance was left open. A followup to the surveillance was conducted on' August 22, 1984. The LKC training had not been completed and 616 drawing were reviewed. Five voided drawings were found in the fiel In addition sepias were found in Document Control files which were out of revision. These out-of-revision sepias accounted for one voided drawing in the field. LKC agreed to review the sepias. Another CECO followup was conducted on September 28, 198 One discrepancy was identified out e of 665 drawings reviewed at 12 stations. A followup on November 2, 1984, ,

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closed the surveillanc '

,. y CECO has implemented a quarterly surveillanc,e program to m6nitor the area *

of LKC document control. The inspector reviewed surveillances 4212

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, (February 1985), 4451 (May 1985), and 4719 (July 1985) which indicate s ~

^ that LKC is adhering to Procedure 4.2.1.

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The insp'ctor e reviewed LKC Procedgre 4.8.15, Revision C, effective a' June 28, 1985, " Drawing, Specification and Procedure Document Control Inspection," which requires an LKC QC inspector to inspect at least 100 documents on a monthly basi nto verify compliance with LKC Procedur& '

3 :4.2.1. Previous revisions of4the procedure had required an inspection of ten or more documents on a monthly basis. However, in response to LKC Internal Audit I-059-084 (April 1984), the sample size was increased to 50, consisting of 40.dr.awings, eight procedures, and two specificatio.n The inspector reviewed LKC Internal'Abdit No. I-097-085 dated March 16, ; -

.1985, which reviewed the implementation of Procedures 4.2.1 and 4.8.1 Audit Finding:1-097-085-01 documented that.the LKC QC inspector was not adequately' implementing the inspection of 50 documents. Also, five of -

422 drawings ^.were found to be deficient. In response to Finding .

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I-097-085-01, the QC Manager conducted a training session with the QC f5 fnspector. Additionally, the QC inspector's work would be reviewed by his suparvisor to verify compliance with Pr,ocedure 4.8.15. LKC QA conduf.ed Surveillance No. S-085-08 dated Oct.ober 3, 1985, which closed Findirg I-097-085-01. The inspector reviewed' rMords for the August and September 1985s0C document inspectjons. The in'spections were conducted in accordance with Procedure ,4.8.15 and no do$nent contrdi discrepancies were identified by the QC inspecto f TheinspectorrandomlyselectedfielddrdwingsatStations2,22,.47,and 45 and found that all field revisions were

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q curren w LKC has implemented Procedure 4.13.1.1, " Turnover Document Reviek,"'which provides for a 100% review of' quality control inspection records utilizing 22 inspection checklists. The document reviewer is required to verify that each inspection was conducted to the correct drawing revision. The following areas are covered by the checklists:

Welding Core Holes Configuration s Revision Rework Requests Equipment Penetration Modifications (Unit 1)

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Junction Boxes Penetrations Conduits Penetration Modifications (Unit'2)

Cable Pans- Calibrations Cable Pan Covers .

Receipt Concrete' Expansion Anchors Concrete Expansion Anchor Travelers Cable Pulling Embedded Conduits Terminations . ..

Stud Weldin Cable Conductor Extensions General Inspections F As of May 1985, LKC ha'd reviewed 8,328 inspection records with these checklists of which 3,376 records were rejected. Performance of the

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QC inspection to the wrong drawing revision accounted for 35.5% of the rejected-records. As of October 8, 1985, 73,817 inspection records had '

been reviewed,-14,890. records had been rejected, and 7,142 of the L rejected records had been corrected. The proper implementation of the t Turnover Document. Review will be further evaluated during Region III's

inspection of 10 CFR 50.55(e) Report No. 456/84-01; 457/84-0 LKC -is initiating'a Drawing Review Program to ensure that revisions prior to April 1984.were properly implemented or corrected and documented. This nN program may involve a field walkdown of current installations and/or a review of LKC installat. ion and.QC documentation with respect to current field drawings.- If the field installations are not installed and inspected to the latest drawing revisions, rework / inspections will be implemented in accordance with current site procedures. This program has not yet been implemented and is being tracked by previously identified Open Item yo.456/85007-01;457/85007-0 'The licensee's drawing control corrective actions and the implementation

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of the Turnover Document Review and Drawing Review Programs resolves this A item of noncompliance. This item is considered to be close (Closed) Violation 456/83-09-08(b);457/83-09-08(b): During inspection 83-09, the inspector found that, (1) neither the LKC Corporate auditing

coverage.perfomed and/or scheduled from mid-year 1982 through mid-year 1983 nor the audit schedule established for the year 1983 would provide complete program verification coverage as prescribed by the Quality Assurance Manual, and (2) of the seventeen internal LKC audits scheduled to be performed during January through June of 1983, only five could be determined to have been completed with all five audits having been performed in January of 1983, and with no further auditing activity i performed (Reference Report 83-09, Pages 35-39). Inspection Report No. 83-09 was issued on May 7, 1984. The inspector reviewed the

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licensee's response, dated July 6, 1984.

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The licensee acknowlcdged that LKC did not fully implement their 1983 internal audit schedule. The inspector reviewed CECO Surveillance

.n .No. 4852 which was conducted to verify that the corrective action taken 4 by LKC was as stated in the licensee's response. The licensee took credit

.. for 17 Ceco QA audits of LKC from June 1982 through December 1983, to '

L compensate for the lack of LKC auditing. The inspector notes that Ceco's 4 auditing program has been previously reviewed in Reports 456/84-44;

.457/84-40 and 456/85046; 457/85045 and was found to be acceptabl . . , _ - . _-_- - -- - -

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LKC conducted 33 internal audits in 1984 and 37 internal audits are scheduled to be conducted in 1985. Two certified auditors have been in the LKC organization since January 1984. A third auditor, currently in training, will be certified in the near future. The audits conducted in 1984 and 1985 by LKC site and corporate auditors have adequately covered the QA program on an annual basi The inspector reviewed the following 1985 LKC internal audits for compliance with LKC Procedure 4.14.1, " Internal Audit Program":

Number Date of Report Coverage Results I-087-085 01-23-85 Installation of 1 finding Class 1E Embedded Conduit and Inspection of Class 1E Embedded Condui I-088A-085 02-08-85 DC Storage Battery and Battery Rack Installation and Inspectio I-089-085 02-13-85 Generating Work 2 findings Instruction observation I-090-085 02-26-85 Equipment / Junction 1 concern Box Installation, Inspection of Class 1E Equipment / Junction Box Installatio 'I-091-085 03-05-85 Electrical 1 finding Penetration Installation, Termination and Maintenance, Unit 2 Electrical Penetration Installation, Termination, and Maintenance, Inspection of Electrical Penetration I-092-085 03-22-85 Reporting of 1 observation Defects and Noncompliance; Nonconforming Item I-093-085 03-22-85 Field Problem Reporting Procedur I-094-085 04-16-85 Manual Soldering Procedur . .

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Number Date of Report Coverage Results I-095-085 ~ 03-18-85 Cancelle ' Procedure Deleted I-096-085 04-30-85 Corrective 1 finding Action, Stop 1 concern

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Wor observation I-097-085 05-16-85 Document Control, 1 finding Drawing and 2 concerns Specification-Document Control Inspection Procedur I-098-085 05-16-85 Design Change Contro I-099-085 05-22-85 System Completion / 5 concerns Turnover Procedur I-100-085 05-13-85 Rescheduled to 8/I2/8 I-101-085 05-13-85 Rescheduled to 6/24/8 I-102-085 06-06-85 Equipment 1 finding Maintenance 3 concerns Procedure (4.9.6). 1 observation I-103-085 06-28-85 Rewor observation I-104-085 07-10-85 Storage, Issue, 1 finding and Control of 1 observation Welding Materia I-105-085 06-10-85 Audit cancelled due to procedure deletio *

I-106-085 07-16-85 As-built Information Reporting Procedur I-107-085 08-13-85 Control of I concern Measuring and Test Equipmen Cable Pan 1 concern Installation of Class IE Safety-Related Cabic Pan '

Installation LKC Corporate audits have been conducted as follows:

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I Audit N Date of Audit Criteria Covered CQA-84-68 March 6-7, 1984 X, XII, XIII, XVIII CQA-84-130 June 18-19, 1984 I, II, XV, XVI, XVII CQA-84-166 August 6-8, 1984 VI, VIII, XIV CQA-85-10 January 28-30, 1985 III, V, IX CQA-85-51 March 25-27, 1985 I, II, XIII, XVIII CQA-P.5-74 April 29-30, May 1, Purpose: To conduct a review 1985 of the Qualification, Classification, and Training of QC Personnel to assure compliance with LKC Procedure 4. .CQA-85-112' August 5-9, 1985 II, XII, XIV, XV, XVI CQA-85-126' October 2-4, 1985 II, III, V, VI, VIII One more corporate audit is scheduled in-198 During the inspector's review of auditing, three concerns were identified as!follows: LKC Procedure 4.1.1, Revision C, dated May 6, 1985, " Site Organization Chart," does not document the actual Quality Control /

Quality Assurance organization in place. Additionally, LKC Procedure 4.1.2, Rev. C, May 23, 1985, " Position Delineation," requires updating to define the actual responsibilities of personnel in the LKC QA/QC organization. The inspector notes that LKC Corporate Audit CQA-85-51, Concern 4, identified the.same conccrfe which was subsequently closed out. . The LKC site response to Cont.ern 4 states that any new positions added must be approved via procedural revisions. At the conclusion of this inspection, LKC was in the

. process of revising Procedures 4.1.1 and 4.1.2. The inspector will review the revised procedures in a future inspectio . LKC Procedure 4.14.1, " Internal Audit Program," Paragraph 3.3.1, allows limited activity procedures to be placed on a 24 month audit schedule. However, Regulatory Guide 1.144,-(1979)C.3.a(2), states that applicable elements of the QA program should be audited at least annually or at least once within the life of the activity, whichever is shorte LKC Procedure 3.1.4, " Quality Assurance Program Review and Evaluation,"

Paragraphs 2.3 and 2.4 for scheduling of corporate audits state,

" Audits shall be performed in such a manner that the quality program will be reviewed and evaluated for compliance to each of the applicable criteria of 10 CFR 50 Appendix B at least once in a twelve (12) month pe ri od. . . Unscheduled audits may be performed when deemed necessary."

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.. .- .However, LKC Procedure 1.0.1, " Quality Assurance and Control Program,"

Paragraph 4.14,: states, " Audits shall be conducted quarterly or on a random,1 unscheduled basis, or both."' The phrase "or on a random, r unscheduled basis" allows any auditing' frequency to be chosen. The requirements.of the two. procedures appear to be inconsistent. The

' inspector. notes'that only.three' corporate audits were conducted in

- 198 'ItemC a, b, and'c'are open pending the licensee's resolution-(456/85051-01; 457/85049-01).

l 1%C's auditing program was previously reviewed in the CAT inspection

~(Report Nos.~ 84-44; . 84-40,~- Page VIII-3). The CAT inspector had one (concern regarding the program: "The L. K. Comstock audit procedure did

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not require the audit report to address the effectiveness of the elements audited and did not require verification of the effectiveness of corrective-action to audit findings."

!' The inspector verified that LKC Procedure 4.14.1, Rev. B, resolved this Concer ' Lack of LKC auditing is considered to be close No violations or deviations were identifie . Allegations (Closed) RIII-85-A-0130: On August 1, 1985, the Office of Inspection and Enforcement received an anonymous allegation regarding the Braidwood

/ Station. The alleger stated that, (1) the G.-K. Newberg Construction

. Company received $75,000 in damage to welding equipment due to sabotage l

over the last few months, and $40,000 in thefts have occurred, (2) there is.open' abuse of alcohol _and drugs, and (3) there is open drug dealing on site. _This allegation was forwarded to the licensee for their review in-a 1_etter dated September 9, 1985. 'The licensee assigned this allegation I to the Quality First Director,: Project Construction Superintendent, and L Station Security Administrator._ The Quality First investigation was

= , completed on September 27, 1985.

L .The' Project Manager for G. K. Newberg determined that during the period i of May 1 through August 1,1985, approximately nine welding grids'were lost, along with minor amounts _'of welding lead (total value estimated at

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!=, $4,000). ~During the'same period, six small tools were reported stolen (total value estimated at $1,500). No incidents of sabotage were

! , reported during'the perio CECO has implemented drug and alcohol abuse policies for both CECO employees and contractor personnel. For CECO employees, the company's e program 11s documented in the " Company Policy Regarding Drugs and Alcohol

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Abuse." Guidance for' implementation of the company policy is documented

in'" Supervisory Guidelines.for Administering the Company Policy Regarding

. Drug and Alcohol Abuse," and " Questions and Answers,'.' concerning the

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i In November 1984, the Braidwood Project implemented a formal policy and

implementing procedure specifically addressing-drug and alcohol abuse -

H at Braidwood by contractor personnel. Details of this policy were previously documented-in Reports No. 456/84-31; 457/84-2 Each contractor has been charged with the responsibility of developing their

'own policy and implementing procedure to support the Braidwood Projec Polic The licensee has:taken the following actions to assure that there is no open drug and alcohol abuse or dealing on site:

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Allegations of drug use are investigated when there is sufficient l information provided to facilitate an investigatio (

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Six searches of the work site have been made using dogs that are !

trained in the detection of drugs. The searches were conducted between November 20, 1984, and August-29, 1985. Drugs were found during 'only one of the searches which resulted in the termination of one employe .

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Personnel from the CECO Property Protection Department have, on several occasions, provided surveillance on back shifts in locations

.where there had been allegations or.a belief that drugs and/or alcohol have been used, or where there was evidence of property being stolen. Such surveillances did not substantiate the use of drugs on sit There have been five Quality First concerns which addressed the use of either drugs or alcohol botween the dates of December 11, 1984, and August 28, 1985. One of the concerns contained sufficient information to warrant personnel investigation. The investigation did not substantiate the concer !

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The Security Staff has received several anonymou:. tips and/or 1 allegations that there is drug and alcohol use on site; however, the

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anonymous allegers have not provided substantial information as to l any specific events.

i This allegation is considered to be close (Closed)RIII-85-A-0156: On August 31, 1985, Region III received an anonymous phone call from an alleger. He made a statement that certain personnel were using cocaine and that a lot of money was changing hand 'The personnel were identified only by general position titles without

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. reference to contractor or licensee organization. No more specifics were-given. ~The inspector gave this allegation to the Quality First Director and to Project Management for investigation in accordance with CECO's drug

.and alcohol abuse program as discussed previously in this report. Thi allegation is considered to be close No violations or deviations were identifie . Electrical-Installations

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The inspectors selected the following junction boxes:

' Junction Box Drawing 1JB1164A 20E-0-3373D01 20E-0-3393W-IJB703R 20E-0-3393J 20E-1-3544

'The inspectors verified that the following attributes were in compliance with established requirements:

• . junction box installed per latest drawings as to size, location and box type,

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• . junction box identification is correct

• junction box is free of any internal or external damage,

• junction box is clean,.i.e., no debris, tools or foreign material are stored in or on the junction bo ~

The inspection and installation reports were reviewed for each junction bo The inspectors selected the following conduits, which had been-inspected by LKC quality control inspectors, to verify the effectiveness of LKC's inspections:

Conduits Drawings CIA 8288 20E-1-3382 lf '20E-1-3382CT1 ,

C2A5331 20E-2-3353CT1 20E-2-3353D01 20E-2-3353C03

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The conduits were inspectedifor:

i' .* segregation code laael

• size of conduit

• separation criteria

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• correct bolting material

• flex' conduit fittings-No violations or deviations were identifie a

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5. -Pipe Supports The following Class 1 pipe-supports were found to be installed in accordance with the applicable drawings, installation packages, and travelers:

ISIO932V 1RY06003R Dimensions, welding, documentation,-traceability oi material, and general workmanship were checke No violations or deviations were identifie . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed by the inspector and which involve some action on the part of the NRC or' licensee or both. An open item' disclosed during the inspection.is discussed in Paragraph . Exit Interview The inspector met with licensee and contractor representatives denoted in Paragraph 1 during and at the conclusion of the inspection on October 31, 1985. The inspector summarized the scope and results of the inspection and discussed the likely content of this inspection report. The licensee

. acknowledged the information and did not indicate that any of the information disclosed during the inspection could be considered proprietary in natur .

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