IR 05000456/1985051
| 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: |
| 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
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//!/9fS6 Date an.P&ge fl[/9!6f W. J. Kropp Date b*
W R. M. Lerch f l /i 9 [8J'~
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J. A. Mall by 1///9 Bf Date
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// f/86 Approved By:
1 m L' tie, irector Braidwood Project Date~
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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 inspectors.
,Results: No violations or deviations were identified.
8511260252 851120 PDR ADOCK 05000456 G
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DETAILS 1.
. Persons Contacted'
Commonwealth Edison Company (CECO)
- M. 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 2.
Licensee Action on Previous Inspection Findings.
(Closed) Violation 456/83-09-02(e); 457/83-09-02(e):
Failure of L. K. Comstock (LKC) to remove voided drawings from the field.
During inspection 83-09 the inspector identified in June 1983 that Drawing-1-3515, Revision N, 9-17-82, was located at drawing Station 5.
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 performed.
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 l
assure that all 44 stations are maintained in a current status, i
Inspection Report 83-09 was issued on May 7, 1984.
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 -
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- 1983 and January'1984, L. K. Comstock Quality Control performed monthly 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 applicable controlling procedures in this area.
LKC performed 1984
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. internal audits of_these procedures documented.in Audit Report
'Nos. I-057-084-dated March 13, 1984, and I-059-084 dated April 18, 1984.
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~ Audit;Repo'rt No. I-059-084 had three findings and four concerns which
- were closed by May 30, 1984.
Ceco'QA performed Surveillance No. 3439 dated Apriljll, 1984i which identified deficiencies in LKC's control 'f drawings, FCR's,_and ECN,s.
o 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..
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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
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. 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 identified.
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:
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Reduce the numbers of field document stations.
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Reduce the number of drawings at each station.
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Change'the style of document master cards and reduce the
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number of master cards.
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- Eliminate void print files by the use of aperture cards, t
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Change the style and format of print transmittal forms and
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reduce the number of field drawing transmittals.
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Computerize transmittals and returns.
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- Restructure the document control department.
CECO QA conducted Surveillance No. 3764, dated August 2, 1984, to review
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the status of the findings from Audit No.-QA-20-84-585.
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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 field.
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, 1984.
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 surveillance.
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,. 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
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that LKC is adhering to Procedure 4.2.1.
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The insp'ctor reviewed LKC Procedgre 4.8.15, Revision C, effective
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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&
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- 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.ns.
-The inspector reviewed LKC Internal'Abdit No. I-097-085 dated March 16, ;
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.1985, which reviewed the implementation of Procedures 4.2.1 and 4.8.15.
Audit Finding:1-097-085-01 documented that.the LKC QC inspector was not adequately' implementing the inspection of 50 documents. Also, five of
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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
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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 inspector.
f TheinspectorrandomlyselectedfielddrdwingsatStations2,22,.47,and 45 and found that all field revisions were current.
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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 Revision Rework Requests s
Equipment Penetration Modifications (Unit 1)
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Junction Boxes Penetrations Conduits Penetration Modifications (Unit'2)
Cable Pans-Calibrations Cable Pan Covers
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Receipt Concrete' Expansion Anchors Concrete Expansion Anchor Travelers Cable Pulling Embedded Conduits Terminations
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Stud Welding.
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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 QC inspection to the wrong drawing revision accounted for 35.5% of the
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rejected-records. As of October 8, 1985, 73,817 inspection records had
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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; 457/84-01.
LKC -is initiating'a Drawing Review Program to ensure that revisions prior to April 1984.were properly implemented or corrected and documented. This n
program may involve a field walkdown of current installations and/or a N
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;457/85007-01.
'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 closed.
(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
licensee's response, dated July 6, 1984.
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The licensee acknowlcdged that LKC did not fully implement their 1983
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internal audit schedule. The inspector reviewed CECO Surveillance
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.No. 4852 which was conducted to verify that the corrective action taken
by LKC was as stated in the licensee's response. The licensee took credit
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for 17 Ceco QA audits of LKC from June 1982 through December 1983, to
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compensate for the lack of LKC auditing. The inspector notes that Ceco's
auditing program has been previously reviewed in Reports 456/84-44;
.457/84-40 and 456/85046; 457/85045 and was found to be acceptable.
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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 basis.
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 Conduit.
I-088A-085
02-08-85
DC Storage Battery
and Battery Rack
Installation and
Inspection.
I-089-085
02-13-85
Generating Work
2 findings
Instructions.
1 observation
I-090-085
02-26-85
Equipment / Junction
1 concern
Box Installation,
Inspection of Class
1E Equipment / Junction
Box Installation.
'I-091-085
03-05-85
Electrical
1 finding
Installation,
Termination and
Maintenance, Unit 2
Electrical Penetration
Installation, Termination,
and Maintenance,
Inspection of Electrical
I-092-085
03-22-85
Reporting of
1 observation
Defects and
Noncompliance;
Nonconforming Items.
I-093-085
03-22-85
Field Problem
Reporting Procedure.
I-094-085
04-16-85
Manual Soldering
Procedure.
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Number
Date of Report
Coverage
Results
I-095-085 ~
03-18-85
Cancelled.
' Procedure
Deleted
I-096-085
04-30-85
Corrective
1 finding
Action, Stop
1 concern
Work.
1 observation
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I-097-085
05-16-85
Document Control,
1 finding
Drawing and
2 concerns
Specification-
Document Control
Inspection Procedure.
I-098-085
05-16-85
Design Change Control.
I-099-085
05-22-85
System Completion /
5 concerns
Turnover Procedure.
I-100-085
05-13-85
Rescheduled to
8/I2/85.
I-101-085
05-13-85
Rescheduled to
6/24/85.
I-102-085
06-06-85
Equipment
1 finding
Maintenance
3 concerns
Procedure (4.9.6).
1 observation
I-103-085
06-28-85
Rework.
1 observation
I-104-085
07-10-85
Storage, Issue,
1 finding
and Control of
1 observation
Welding Material.
I-105-085
06-10-85
Audit cancelled due
to procedure
deletion.
I-106-085
07-16-85
As-built Information
Reporting Procedure.
I-107-085
08-13-85
Control of
I concern
Measuring and Test
Equipment.
1-108-085
08-13-85
Cable Pan
1 concern
Installation of
Class IE Safety-
Related Cabic Pan
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Installations.
LKC Corporate audits have been conducted as follows:
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Audit No.
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 4.1.3.
.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-1985.
-During the inspector's review of auditing, three concerns were identified
as!follows:
a.
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 inspection.
b.
. 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 shorter.
c.
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,
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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
1984.
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'ItemC a, b, and'c'are open pending the licensee's resolution
-(456/85051-01; 457/85049-01).
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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
not require the audit report to address the effectiveness of the elements
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audited and did not require verification of the effectiveness of corrective
-action to audit findings."
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The inspector verified that LKC Procedure 4.14.1, Rev. B, resolved this
Concerh.
' Lack of LKC auditing is considered to be closed.
No violations or deviations were identified.
3.
Allegations
(Closed) RIII-85-A-0130:
On August 1, 1985, the Office of Inspection and
Enforcement received an anonymous allegation regarding the Braidwood
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Station. The alleger stated that, (1) the G.-K. Newberg Construction
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Company received $75,000 in damage to welding equipment due to sabotage
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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
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to the Quality First Director,: Project Construction Superintendent, and
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Station Security Administrator._ The Quality First investigation was
completed on September 27, 1985.
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.The' Project Manager for G. K. Newberg determined that during the period
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of May 1 through August 1,1985, approximately nine welding grids'were
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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
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CECO has implemented drug and alcohol abuse policies for both CECO
employees and contractor personnel.
For CECO employees, the company's
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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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In November 1984, the Braidwood Project implemented a formal policy and
- implementing procedure specifically addressing-drug and alcohol abuse -
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at Braidwood by contractor personnel. Details of this policy were
previously documented-in Reports No. 456/84-31; 457/84-29.
Each
contractor has been charged with the responsibility of developing their
'own policy and implementing procedure to support the Braidwood Project.
Policy.
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
information provided to facilitate an investigation.
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Six searches of the work site have been made using dogs that are
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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 employee.
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Personnel from the CECO Property Protection Department have, on
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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 site.
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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 concern.
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The Security Staff has received several anonymou:. tips and/or
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
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any specific events.
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This allegation is considered to be closed.
(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 hands.
'The personnel were identified only by general position titles without
. reference to contractor or licensee organization. No more specifics were
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-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. This.
allegation is considered to be closed.
No violations or deviations were identified.
4.
Electrical-Installations
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The inspectors selected the following junction boxes:
' Junction Box
Drawing
1JB1164A
20E-0-3373D01
-IJB703R
'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,
. junction box identification is correct
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junction box is free of any internal or external damage,
junction box is clean,.i.e., no debris, tools or foreign materials.
are stored in or on the junction box.
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The inspection and installation reports were reviewed for each junction
box.
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
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'20E-1-3382CT1
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C2A5331
20E-2-3353CT1
20E-2-3353D01
20E-2-3353C03
The conduits were inspectedifor:
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segregation code laael
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size of conduit
separation criteria
the number ~of conduit supports
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flex' conduit fittings-
No violations or deviations were identified.
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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 checked.
No violations or deviations were identified.
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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 2.
7.
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
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information disclosed during the inspection could be considered
proprietary in nature.
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