IR 05000456/1986057
| ML20212B532 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 12/19/1986 |
| From: | Danielson D, Schapker J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20212B482 | List: |
| References | |
| 50-456-86-57, 50-457-86-47, NUDOCS 8612290268 | |
| Download: ML20212B532 (16) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-456/86057(DRS);'50-457/86047(DRS)
Docket Nos. 50-456; 50-457 Licenses No. NPF-59; 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, Illinois Inspection Conducted: October 7 through November 24, 1986 Inspector-
. F. Schapker
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Date bk Approved By:
D. H. Danielson, Chief
/ /f/r4 Materials and Processes Section Date '
Inspection Summary Inspection on October 7 through November 24, 1986 (Reports No. 50-456/86057(DRS);
50-457/86047(DRS))
Areas Inspected: Special, unannounced inspection of alleged safety concerns provided by a former L. K. Comstock, Inc. (LKC) employee (Allegation RIII-86-A-0155) (99014).
Results: One violation was identified, (failure to implement procedure requirements - Paragraph 2.1.).
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DETAILS
1.
Persons Contacted Commonwealth Edison Company (CECO)
- A, D' Antonio, Regulatory Assurance
- P. Barnes, Regulatory Assurance, Supervisor D. Cecchett, Regulatory Assurance B. Gagnon, Quality First
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- G. Groth, Assistant Construction Assistant l
- R. Bedford, Quality Assurance
- J. Phelan, Project Field Engineer, Electrical Supervisor D. Kunzman, Quality Assurance Inspector L. K. Comstock Co., Inc. (LKC)
R. Seltman, Quality Assurance Manager I. Dewald, Quality Control Manager T. Simile, Quality Control Supervisor J. Hii, Quality Records Supervisor B. Murphy, Quality Control Inspector M. Klechke, Quality Control Inspector Pittsburgh Testing Laboratory (PTL)
F. Forrest, Project Manager T. Fraizer, Assistant Site Manager Phillips-Gettshow Company (PGCo)
E. Ullrich, Quality Control Manager Sargent and Lundy Engineers (S&L)
A. Lunardini, Senior Structural Design Engineer F. Shallwani, Structural Design Engineer Nuclear Regulatory Commission (NRC)
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- W. Kropp, Senior Resident Inspector The inspector also contacted and interviewed other licensee and contractor personnel.
- Denotes those attending the final exit interview.
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2.
(Closed) Region III 86-A-0155 Allegations
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On September 16, 1986, Region III received a phone call from an individual who identified himself as an ex-employee of L. K. Comstock (LKC), the electrical contractor at the Braidwood Station. During the phone call the individual made a number of allegations regarding construction activities at Braidwood. The alleger was recontacted on October 10, 1986, to obtain more specific details concerning the allegations. The following details each allegation, the NRC review and conclusion.
a.
Allegation All stainless steel piping is contaminated due to its being held together at the flanges by carbon steel bolts.
NRC Review The individual provided specific areas where the carbon steel bolts were utilized in the plant with stainless steel flanges and valves when he was contacted by the NRC on October 10, 1986.
The NRC inspector located the flanges and valves as described by the individual. The NRC inspector reviewed the applicable drawings, design tables and code data reports to verify the type of bolting was as specified.
In all examples cited by the individual the bolting was as required by design.
The individual also stated he observed similar conditions with large bore pipe, but was unable to provide specific information. The NRC inspector selected a random sample of large bore pipe with bolted connections and verified that the bolting was as specified in design documents.
Conclusion This concern was substantiated; however, no detrimental effect to the hardware will result due to this condition. The stainless steel components which utilized carbon steel bolting were as designed.
This is not detrimental to the stainless steel.
Carbon steel
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bolting is utilized by design, for its high strength characteristics, i
resistance to galling, etc.
The contact of the carbon steel with the stainless flanges does not in itself contaminate the stainless steel.
There is no requirement in current codes (B31.7 or ASME) which prohibits dissimilar material for mechanical joints.
There have been no recorded cases of deterioration of stainless steel due to this type of contact with carbon steel.
b.
Allegation Piping welds have been brushed with carbon steel brushes.
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NRC Review
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Additional information was supplied by the individual on October 10, 1986, concurrently with concern "a".
The NRC inspector examined all of the areas of concern and concluded that the welds could have been brushed with carbon steel brushes as.some of the welds displayed light rust deposits. The NRC inspector reviewed the applicable contractors stainless steel weld procedure which stated " Wire brushing shall be done with stainless steel brushes."
Conclusion The NRC inspector was able to remove the rust with rubbing with a finger. The discoloration appeared to be confined to the heat affected zone of the weld and did not appear uniform over the weld.
This could have resulted from the carbon content within the stainless steel itself and may not have developed from wire brushing.
Regardless of the cause of the " rusty welds," the NRC inspector's observation of the rust found the rust to be superficial and readily removed with no pitting observed.. Based on past studies, there appears to be no solid technical basis for prohibition of carbon steel / stainless steel contact by handling tools or wire brushes, so long as such tools are clean and free from other contaminants.
Particles of iron which are left on the surfaces after fabrication will corrode (oxidize) and leave their imprint on the surface. This form of attack, per se, is not serious except for its detrimental effect on appearances, since no pitting results. Once the iron particles are depleted by the oxidation process, further corrosion is unlikely. The contractor's procedures require the use of stainless steel wire brushes, which is considered good practice, but there is no code or regulatory requirement. The condition (rust deposits) observed by the NRC inspector is not safety significant.
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Allegation
"DV8 electrical support connections have 11/16" holes with 1/2" bolts.
These conditions were missed during final walkdown inspections and accepted. The alleger stated that these conditions were known by the licensee but that only a portion had been corrected."
NRC Review The NRC contacted the concerned individual on October 10, 1986, and obtained the following additional information:
Sargent and Lundy (S&L) "came out with a fix to put in split washers, half washers, on bent plate." While many of the locations were listed on the bill of materials. Other locations
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existed where split washers were used but were not listed on the bill of materials. A walkdown would be the only way to determine where split washers were installed and not listed.
He recalled that most of those installations were on the 462' and 451'
elevations of the Auxiliary Building; however, he could not recall the specific locations.
Five hangers were involved.
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The NRC inspector examined the component described by the individual, as well as reviewing a similar _ situation previously identified to the Braidwood Quality First team where the individual identified five hangers, which he alleged were deficient.
Four of the five hangers identified by the individual were welded and had no bolted connections. The remaining hanger had bolted connections, but 5/8" diameter bolts were installed as required. The deficiency, of the 1/2" bolts installed in 11/16" holes attaching DV8 electrical support connections, was discovered during a walkdown performed by S&L, the architect engineer, with assistance from LKC Quality Control prior to the referenced "fix" by S&L. The "fix," as described by the individual in the preceding paragraph was documented on Engineering Change Notices and documented on the as-built drawings as required.
Conclusion The deficiency as described by the individual was not substantiated. Although the discrepancy was identified and dispositioned as described by the individual, the "fix" was evaluated and documented by the architect engineer and implemented by LKC in accordance with applicable procedure requirements. The examples the individual supplied to Quality First were not deficient and needed no correction.
d.
Allegation
"DV84 connection return welds are being ground bsck due to excessive length but they are leaving the root pass."
NRC Review The concerned individual was contacted and supplied a list of hangers and the following additional information:
The individual thought that all examples of the described conditions were identified on Inspection Correction Reports (ICR). According to the individual, a memorandum pertaining
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to clip angle returns and the excessive welding of return welds was written. The memorandum stated that "the root passes did not have to be ground out when shortening the return welds."
The individual thought that from a metallurgical standpoint the root pass must be removed. According to the individual, two named CECO employees were involved in the resolution of the problem as well as the " head of S&L structural at Braidwood" (name unknown). The individual also stated that the head of structural for S&L at Braidwood was not too knowledgeable.
He had to be shown what a return weld was by having a special demonstration coupon welded for him.
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The NRC inspector performed field inspections of the examples supplied
by the concerned individual. The condition was substantiated; however, in the inspector's opinion there is no metallurgical basis to remove the root layer.
From a metallurgical standpoint removal of the root layer would be more detrimental to the connection than beneficial. This opinion is based on the fact that additional repair would be required to the base materials to remove the root layer, which could negatively effect the base material of the clip angle and structural member of the attachment with no benefit to the function of the connection. The excessive welds on the DV84 connections were evaluated by the architect engineer (S&L) who determined that the excess welds caused the designed " pin" connection to be excessively rigid and therefore required the removal of the excess weld as described.
Conclusion The special demonstration coupon referenced by the concerned individual was made to evaluate the best method for removal of the excess weld and not to show the " head of structural for S&L at Braidwood" what a return weld was. The " head of structural at Braidwood for S&L" has a Bachelor of Science Degree in structural engineering and twelve years experience with S&L. S&L made an engineering evaluation to resolve the excess weld on the DV84 connection. The removal of the excess weld to the root layer was determined to be the least detrimental to the connection while maintaining the design integrity of the connection. The individual mistook the need of a demonstration coupon for engineering evaluation as a lack of knowledge, when in fact, the use of the coupon for evaluation of repair methods is good engineering practice.
e.
Allegation Due to the substitution of cables in cable trays (i.e. four conductor cables being substituted for two conductor cables) some trays are at over capacity. To correct this the licensee is beefing up the tray support unistrut welds with excessive welds, causing warpage.
NRC Review
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The NRC inspector inspected welds and subject warpage as described by the individual.
Since no specific areas were identified by the individual, the NRC inspector performed selected inspections in conjunction with the other concerns referenced by the individual.
Some warpage due to welding was observed; however, none of the warpage observed would be detrimental to the function of the components. No deficient conditions were observed during this NRC inspection.
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A similar concern,oas described by the individual, was previously
reviewed by the NRC (See NRC Inspection Report.No. 50-456/86038; 50-457/86022). The major technical concerns documented in this
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report were as follows:
(1) Additional welds may alter the behavior of specific connections with respect to their analytically assumed behavior.
(2) Additional welds may damage the base metal as a result of defects within the unspecified weld.
(3) Additional welds may distort the attached parts due to
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excessive heat input.
These concerns were addressed by the licensee in the following manner:
(1) Unspecified welds would adversely affect only two types of connections in the plant. These connections, cross flange welds and clip angle return welds, were specifically restricted from unspecified welds in S&L's general notes on Drawing M-999 and other specifications. All other connections would not be adversely affected even though its response could be changed frcm a pinned connection through the addition of unspecified welds.
(2) Although a weld may be unspecified, it will still be inspected by Quality Control Personnel for attributes that could adversely affect the base metal. The attributes specifically referenced are weld cracks and undercut. Assuming that these two items
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are within the acceptance criteria, any unspecified weld will not be a detriment to the base metal.
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(3) All welding performed in the plant is based on pre-approved welding procedures. These procedures control the size, and amount of heat input for any type weld. The basis for any procedure qualification is a resulting weld that produces an adequate attachment with acceptable warpage to the parts. On this basis, any unspecified weld will not adversely distort the attached pieces.
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Conclusion i
The conclusion reached in the review of these concerns was that no design significant changes were found in any of the analyses
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or inspections for warpage (due to welding) by the NRC inspector.
I f.
Allegation
Comstock is violating the regulatory requirements and their specifications which require them to use the current revision of AWS.
In some instances they are using the 1975 revision.
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NRC Review
The concerned individual was contacted on October 10, 1986, and provided the following additional information:
Specification No. L2790, Standards, EB-115, EB-116, and EB-117, which control the work of the L. K. Comstock Company, pertain to welder qualifications, materials to be tested and the structural code of the American Welding Society. According to the individual, this specification required Comstock to use the latest revisions of the AWS structural codes; however, they were not doing so in all cases.
Sometimes procedure changes used the 1975 code, while at other times the more recent revisions were included in the procedure changes. As an example weld symbols A21 and A22 in Revision I to Welding Procedure 4.3.3 were taken from the 1975 code rather than from the latest revision. According to the individual, this type of inconsistency confused the welders.
This concern was reviewed by the NRC inspector previously in conjunction with the Atomic Safety Licensing Board Hearings for the Licensing of Braidwood Unit 1.
This review concluded that the welding standard for electrical work to which the licensee has committed in the Braidwood FSAR is the AWS D1.1 Code (no edition specified).
There are, however, two exceptions in the Braidwood FSAR to this standard, both of which.have been approved by the NRC.
First, the Braidwood FSAR provides that deviations from the provisions of AWS D1.1 are permitted if supported by acceptable engineering evaluations. Second, the Braidwood FSAR provides that visual inspection requirements are based on guidelines stated in a document entitled " Visual Weld Acceptance Criteria for Structural Welding at Nuclear Power Plants" (NCIG-0I, Revision 2) prepared by the Nuclear Construction Issues Group.
The licensee's commitment to AWS D1.1-75 was made on May 3, 1976, the date of the original contract with the electrical contractor.
The licensee had not committed to any edition of the code, as the FSAR does not address the edition of the code. Therefore, the licensee had the option to use the edition best suited to their program. This is normally the current edition effective at the time of the contract. The licensee's Architect Engineer (Sargent and Lundy (S&L)) was authorized by the licensee to specify the technical requirements of the contract to the electrical contractor. This specification was identified as L2790 for the electrical installations at Braidwood. The individual's information concerning Specification No. L2790, Standard (STD) EB-115, EB-116, and EB-117, was reviewed by the NRC inspector.
STD-EB-115.0-B/B, page 2 of 4, Paragraph 2.7 states in part that, " Welder's qualifications, procedures, materials, etc., shall be in accordance with the latest AWS Structural Welding Code AWS D1.1."
STD-EB-116.0 is the " Seismic Category 1 (C-1)
Electrical Equipment Hangers" which are configuration drawings of the type hangers utilized for C-1 type electrical hangers.
STD-EB-117.0
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is the " Seismic C-1 Electrical Equipment Hangers Connection Details" which specifies the. connection details utilized in the installation of the hangers. The date of last revision for STD-EB-115.B/B was September-10, 1976, and for STD-EB-116 and STD-EB-117 was June 10, 1974. STD-EB-116 and STD-EB-117 both reference STD-EB-115.0 as the
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specification for fabrication cnd erection of Hangers. S&L Specification L-2790, Section 107.7 states:
"All references to American National Standards Institute (ANSI) Standard Specifications, and to other similar standard publications, are to-the latest issues of each as of the date of this Contract."-
In addition, Form 1701E, Standard Specification for Welding in Building Construction, which was a part of the L2790 Specification at the time of contract issuance states:
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" Publications of the following sponsoring agencies which are specified in this Form 1701 are herewith made a part of Form 1701 by reference; all such references to these publications are to _the latest issue of each, together with the latest additions and/or amendments thereto, as of the date of Contract, unless otherwise indicated; references to the sponsoring agencies will be made in accordance with the abbreviations' indicated:
1.3.1 ASTM.....American Society for Testing and Materials Standard Specifications 1.3.2 AISC.....American Institute of Steel Construction Manual, Specifications and Code 1.3.3 AWS...... Amer,ican Welding Society Standards
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- 1.3.5 ASME.....American Society of Mechanical Engineers Review of LKC welding procedures for safety related construction at Braidwood, including Revision I of Procedure No. 4.3.3, revealed-that all the weld procedures utilized by LKC reference and comply with the AWS D1.1-1975 welding standard.
Conclusion The individual misinterpreted the intent of STD-EB-115.0 that stated that the electrical contractor was required to utilize the latest edition of AWS D1.1.
The intent of that requirement by the AE, in the NRC inspectors opinion, was the current revision at the time of contract as stated in Paragraph 1.3 of S&L Form 1701E, and L2790, Section 107.7. The 1975 edition of AWS D.1.1 was referenced in all safety related welding procedures utilized by the electrical contractor.
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g.
Allegation QC personnel are not qualified.
NRC Review The NRC contacted the individual for more specific information on October 10, 1986. The individual supplied the following additional
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information regarding this concern:
This concern dealt with the qualifications of BESCO inspectors who were contracted to the L. K. Comstock Company (LKC).
1.
Named-LKC Inspector No. I was described by the individual as
"a homesteader." According to the individual, "a homesteader" is a person who makes work in order to justify his job.
The individual stated that Inspector No. I thought that he was an engineer in addition to being an inspector. Many times Approved Design Installations (ADI) were written to overcome Inspector No. I's objection during his inspection. Also, Inspector No. I was not well trained and could not properly calculate the floor depth during the installation of concrete expansion anchors. While the individual could not recall the specific instance, on one occasion, Inspector No. I's floor depth were inaccurate and caused a concrete expansion anchor to be installed too deep.
2.
Another individual, Inspector No. 2, had to be retrained as a welding inspector since "he didn't know backgouging or undercut." On at least one occasion Pittsburgh Testing Laboratory had to be called in as a third party reviewer on a Nonconformance Report written by Inspector No 2.
The result of that review was to retrain and requalify this inspector.
3.
According to the individual, most welding quality control inspectors did not have any background in welding. Most "were farmers" and "were given a book so they would know what a weid looked like."
The NRC inspector reviewed the qualification records of the two inspectors refere'nced by the individual.
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certifications were in compliance with LKC Procedure No. 4.1.3, Revision F, " Qualification Classification and Training of QC Personnel," and complied with the requirements of ANSI 45.2.6, "
Qualification of Inspection, Examination and Testing Personnel for Nuclear Power Plants." The NRC inspector also requested and obtained the trend reports from the independent over inspection contractor - Pittsburgh Testing Laboratory (PTL) - for the two named inspectors.
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Inspector No. l's acceptance rate for the last year was 97.03%,
that is, PTL observed 101 welds accepted by the inspector and found three with dcficiencies not identified by the LKC inspector.
Inspector No. 2's acceptance rate was 97.58% which represented
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his total data base (all overview inspection:) a tot:1 cf 579 over inspections by PTL with 14 deficiencies noted. The NRC.16spector also retrieved the total data base for the attributos for undercut and gouge for Inspector No. 2.
Back gouge is not a normal inspection attribute, as this term is utilized for a normal procedure in full penetration welds, where the root is " gouged" to sound metal prior to deposition of weld on the back side of the weld. The overview inspections by PTL for these attributes totaled 1158 inspections with no rejects. Review of this inspector's previous employment and qualifications revealed the inspe: tor was a " Certified Welding Inspector" (by the American Welding Society) certified in October 1984.
PTL was contacted concerning the individual's statement that PTL was a third party reviewer for an NCR issued by Inspector No. 2.
PTL stated that they had not performed in this capacity for this inspector. The NRC inspector reviewed all the NCR's generated by Inspector No. 2.
There was no evidence as a result of the inspector's NCR's, that a third party reviewer was required and thJt thi: f ripector was rRQuired to be retrained and resual"fici i
i The conterned stdividuai's statetent that ADI's were written to arriver * ;"speeter 89 14 ntfertions tr4tcates tr tre kki
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n; specter, that, Inspector Mo. I was~ purfctming his inspections to the design requirements. The initiation of an ADI, described in LKC Procedure No. 4.2.3, Revision D, " Field Problem Reporting / Approved of the Design for Installation," is based on the following criteria:
(1) The problem is a transposed or illegible item on a print.
(2) The item is already addressed on an unissued design document.
(3) The item needs to be installed outside of its allowable tolerance.
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(4) The design of the item had conflicting information/locationst on the drawings.
(5) The item is designed to be in the same locations as some other item.
(6) The installation could be redesigned to facilitate construction completion (i.e., a conduit routing th.t would remove excessive offsets /90 bends).
(7) A material / weld alternate is needed.
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The NRC Inspector also reviewed all of the Concrete Anchor
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installation and inspection travelers performed by Inspector No. I and LKC Procedure No. 4.3.6 " Concrete expansion anchor installation and inspection." This review did not reveal iny discrepancy in the
'LKC inspectors ability to perform CEA inspections. The individual's reference to the inspectors inability to calculate floor depth was not substantiated as-this process is performed by direct measurement hence, no calculation by the inspector is required, as this calculation is performed by LKC Engineering and recorded on the installation and inspection' traveler.
Conclusion The review performed by the NRC inspector did not support the concerns as expressed by the individual. The inspectors were certified and
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y qualifiedais required by regulatory requirements.
Further, PTL overinspections indicated that the original inspections were adequate.
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ADI's are initiated to resolve field problems as described by LKC
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Procedure 4.2.3 and not to overcome inspector's objections as described
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by the concerned individual.
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Allegation The licensee is trying to hang a named individual. They have lost some of his records and are trying to discredit him. The individual
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considers this to be a cover up.
NRC Review
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The NRC recontacted the individual on October 10, 1986, who supplied the following additional information:
The individual stated that he did not know this named individual.
The individual had learned that the named individual was a quality control inspector previously employed by L. K. Comstock and that he "had blown the whistle." According to the individual, Comstock started a reinspection of his work after departure from the Braidwood Site and many of his Inspection Reports were missing. As an exat;de, the former employee inspected Hanger No. 5H3 2HV3 on the 346' elevation of the Auxiliary Building in the vicinity of columns H6 and Pl.
That inspection was reviewed and accepted on January 8,1986, by a Level II named Inspector (here in identified as Inspector "A").
Subsequently, as part of the reinspection of the named individual's work, that hanger was reinspected by another inspector (Inspector "B") on July 9,1986, and accepted by Inspector A (ICR 16029).
However, AVO No. 00433 (AV0: Avoid Verbal Order) which directed the named individual to perform the original inspection and identified the criteria for that inspection, could not be found for the reinspection. According to the individual, attempts were maae to find AVO No. 00433 and included conversations with the person in charge of the records
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vault (name not recalled). The-individual in charge of the
vault refused to try to find AVO No. 00433 for the reinspection.
The person in charge'of the vault contended that by repeatedly
.asking for that document, he (the person in charge) was being harassed and intimidated by those people asking for the AVO.
The NRC inspector reviewed the events which led to the dismissal of the.~ named individual by LKC. According to the memo's and inspection records reviewed and interviews of personnel involved, the LKC General Q.C. Supervisor was notified by PTL independent inspectors concerning two LKC inspectors who.had allegedly performed inspections and accepted welds which were painted prior to the inspection. The LKC Q.C.
Supervisor's investigation substantiated this allegation. Further investigation by two Level III, two Level II weld inspectors and the LKC QC and QA managers concurred with the findings. As a result of these findings LKC terminated the two inspectors, including the named individual, involved for substandard work practices and violation of LKC Procedure 4.8.3, Paragraph 3.2.1, which states " complete weld surface shall be free of paint, slag, scale, flux, dirt, oil and foreign material that would impair the performance of the visual inspection."
The NRC inspector requested inspection reports for Hanger No. 5 H3 2HV3, Auxiliary Building - elevation 346'.
The initial inspection was performed on January 2,1986, by the named individual and reviewed by Level II welding Inspector A on January 3, 1986, as stated by the individual.
However, this review by Inspector A was for the completeness of the checklist and not a review of the actual weld inspection. This review was specified in LKC Weld Inspection Procedure No. 4.8.3, Paragraph 3.23.2.1 an Paragraph 5.0, " Forms," Form 19, line item 12 which states "A Level II welding inspector shall review the checklist for completeness and signify concurrence by signing and dating." The re-inspection by Inspector B on July 9, 1986, was a reject and the review by Inspector A on the same date was as stated previously, for the completeness of the Form 19. The ICR 16029 also dated July 9, 1986, was the result of Inspector B's inspection which documented numerous discrepancies not recorded on the initial inspection report by the named individual. The NRC inspector also located the AVO No. 00433 which directed the named individual to perform the original inspection. This document was not located in the quality records vault, as it is not a required QC document. However, LKC engineering maintains AV0's and a copy was supplied at the NRC inspectors request.
The AVO No. 00433 pertains to the installation of the subject hanger and is the AVO referenced on the Form 19 by the named individual on January 1, 1986. The NRC inspector also contacted the person in charge of the records vault. He did not recall refusing to try to find the AVO, and he stated that AV0's are not retained in the quality records vault as they are not QC records. He could not recall any incident as described by the individual.
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The NRC inspector also contacted two Level II LKC inspectors and two Level II PTL inspectors who had been involved in over inspections and re-inspections of the named individual's weld inspections performed through paint. The consensus of the inspectors interviewed was that this individual had inspected the welds through paint. The Rorem/ Hunter contention testimony before the Atomic Safety and Licensing Board of five individuals who had examined the welds which this individual had inspected through paint, was also reviewed.
The consensus of this testimony was that the welds had been inspected through paint in violation of LKC procedure requirements.
The NRC inspector also requested a list of all weld inspections performed by the named individual.
From the list supplied, the NRC inspector selected a random sample and verified the inspection records were available at the LKC Q.C. records vault. All records required to be on file were available.
Conclusion The NRC inspector could not substantiate this concern. The named individual was dismissed by LKC due to the use of improper inspection techniques. This was substantiated.by LKC and PTL Level III and Level II welding inspectors. The reinspection of the named individual's previous inspections identified numerous discrepancies which generated the ICR referenced by the concerned individual.
This reinspection was necessary to assure adequacy of the inspections performed by this individual and not to discredit him.
Review of his past inspection records did not disclose any " lost" records, as described by the individual.
1.
Allegation Many times ADIs (Approved for Design and Installation) were entered in the records vault and had never been signed by S&L engineering.
Many of the ADIs were still listed as open by S&L.
The individual thought this demonstrated that quality control was not qualified since quality control did not identify this deficiency.
NRC Review The NRC inspector reviewed LKC Procedure No. 4.2.3, " Field Problem Reporting / Approval of the Design for Installation."
Paragraph 3.4.2.12 requires the ADI to be routed to Sargent and Lundy (S&L) upon completion of Form 262 (ADI-AE Disposition Follow-up Form).
In some cases the ADIs had been misrouted to the quality records vault, prior to routing to S&L. This " deficiency" was discovered by a LKC Quality Control (QC) clerk who had been assigned responsibility for ADI tracking. Although the ADIs were misrouted in violation of the above procedure, the ADI's were not uncontrolled.
Paragraph 3.4.2.5 of LKC Procedure 4.2.3, requires that, "ADI's" shall be uniquely and sequentially numbered, and recorded on a log sheet by LKC personnel. The log for all areas shall be kept by LKC Document Control."
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ADI's initiated by LKC.
Since both logs require S&L approval's be recorded prior to close out, the misrouted ADI's had not been closed out by S&L or LKC Engineering.
LKC Quality Control upon discovery of the misrouted ADI's performed a document review of all ADI's submitted to the Quality Records Vault in accordance with LKC Procedure No. 13.4.1 " Quality Control Documentation Requirements of Quality Related Records." All incomplete ADI's were identified and re-routed to the appropriate designation required to complete the ADI. The NRC inspector reviewed the ADI logs at LKC Document Control and S&L. A sample of open/ closed ADI's were selected from the logs and reviewed for appropriate submittal to the LKC Quality Records Vault. No discrepancies were identified.
Conclusion
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ADI's were entered into the quality records vault without the required S&L approval; however, this deficiency was identified by LKC Quality Control and corrective action was initiated. As a part of this corrective action LKC revised Procedure No. 4.2.3 to further clarify the required routing of the ADI's. Although LKC performed the above corrective action, LKC Quality Control did not initiate a Nonconformance Report (NCR) as required by their Quality Program requirements. This failure of the licensee to assure that activities affecting quality be accomplished in accordance with prescribed procedures is a violation of 10 CFR 50, Appendix B, Criterion V (456/86057-01; 457/86047-01).
During the NRC inspection, the NCR was initiated by LKC and adequate corrective action was taken as described above, no further response to this violation is required.
J.
Allegation Comstock quality control " sat on paperwork" and because of that they could not perform rework inspections. The individual stated that an inspection of the base metal was required as part of a rework inspection, but quality control was too far behind. As a result there were instances (none specifically recalled) where a Comstock hanger was removed and another contractor had installed a hanger in its place.
Therefore, Comstock quality control could not do the I
base metal inspection required in their program.
NRC Review
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This concern was previously reviewed by the NRC (see NRC Inspection Reports No. 50-456/85044; 50-457/85043 and No. 50-4S6/86009; 50-457/86009). The results of these inspections concluded that base metal inspections were performed as required by the applicable procedure requirements. No violations were identified.
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Nonetheless, the NRC inspector performed an additional review of this
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concern. The NRC inspector reviewed the LKC weekly status reports from January 1975 to present. The status reports indicated the number of cable pan / conduit hangers submitted to Quality Ccntrol by production and the number inspected. Although there was a small back log of inspections during this time period January 1985 to May 1985, (50-60 inspections) this number should not have impacted base metal inspections. Additionally, this back log was reduced to zero by September 1985, since that date no back log was apparent.
In the instance where another contractor replaces a LKC hanger, it is that contractor's responsibility to perform the base metal inspection.
The NRC inspector reviewed intercraft work request, whereby another-contractor makes a request for removal or rerouting of hangers or conduit, to facilitate installations of their components, (piping)
where an interference exists.
Intercraft work requests are reviewed by LKC Engineering. When the intercraft work request requires removal of safety related equipment a rework report is generated as required by LKC Procedure No. 4.3.24.
This procedure requires appropriate Quality Control review for comments or special instructions (hold points, witness points, etc.) This procedure also requires an installation report be completed upon re-installation of the component. This installation report is prepared to the requirements of LKC Procedure No. 4.3.12.
Paragrapn 6.6 of this procedure requires a hold point and states "QC be notified to perform a base metal inspection if at any time a hanger's component is to be moved or cut down at the point of attachment during or after installation."
Conclusion A previous NRC inspection regarding a similar concern did not reveal a deficiency in the base metal inspections performed by LKC.
Additional review by the NRC inspector did not identify any concerns in this area.
In the example sited by the concerned individual where another contractor installed the hanger, it was confirmed that the
"other" contractor's quality program requires the base metal inspection prior to welding. The concern was therefore, not substantiated.
3.
Exit Interview The Region III inspector met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on November 24, 1986. The inspector summarized the purpose and findings of the inspection. The licensee representatives acknowledged this in formation.
The inspector also discussed the likely informational content of the inspection report with regards to documents or processes reviewed during the inspection. The licensee representatives did not identify any such documents / processes as proprietary.
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