IR 05000461/1981005
| ML19347F777 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 04/20/1981 |
| From: | Gardner R, Gilray J, Hawkins F, Hayes D, Heishman R, Wescott H, Yin I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19347F775 | List: |
| References | |
| 50-461-81-05, 50-461-81-5, NUDOCS 8105260281 | |
| Download: ML19347F777 (61) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-461/81-05 Docket No. 50-461 License No. CPPR-137 Licensee:
Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name:
Clinton Nuclear Power Station, Unit 1 Inspection At:
Clinton Site, Devitt, IL Inspection Conducted: February 9-13, 17-20, 23-27 and March 3-5, 1981
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Inspectors:
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J. W. Gilray ['
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(February 9-13, and 23-27, 1981 only)
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I. T. Yin-f R
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F. C. Hawkins M/20/6/
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(February 9-13, and 23-27, 1981 only)
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R. N. Gardner N '%1
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Approved By:
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l Division of Resident & Project Inspection Inspection Summary
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Inspection on February 9 to March 5, 1981 (Report No. 50-461/81-05)
Areas Inspected: Review of Quality Assurance Records; Review of Quality Assur-ance Implementing procedures; Observation of Work Activities - large bore pipe
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supports and restraints, guard pipe penetrations, electrical raceway supports, t
welding, NDE and equipment installation; Review of Design Activities - large l
bore pipe supports and restraints, field change requests, engineering change l
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notices, document control, and electrical raceway "As Built" hanger drawings; Review of Procurement Activities -electrical penetrations, electrical switch-gear, and use of commercial grade items.
Results: Of the seven areas inspected, 11 items of noncompliance were identified.
Criterion V - Failure to establish adequate procedures and failure to include applicable qualitative and quantitative acceptance criteria in procedures and drawings governing pipe hanger installations,
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mechanical snubber installations, and penetration seismic guide installations. Paragraph D.2.a(1); D.2.b(1)
Criterion V - Failure to follow specified design' requirements relative to pipe hangers and guard pipes.
Paragraph D.2.a(2); D.2.b(2)(a)
Criterion X - Examples of an inadequate inspection program in the areas of pipe hangers and pipe penetration seismic guides.
Para-graph D.2.a(3); D.2.b(2)
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Criterion XVIII-Failure to perform effective audits in the area of hanger design and installation activities. Paragraph D.2.a(4)
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Criterion IX - Failure to establish measures to assure that special process, i.e., welding, is controlled and accomplished within the guide-lines of gualified procedures.
Paragraph D.2.c Criterion XVII-No documented evidence to show nonconformance reports, audits, and surveillances, etc., have been reviewed for reportability requiremerits pursuant to 10 CFR 50.55(e). Paragraph D.2.d Criterion XVI-Failure to take prompt and effective corrective action to preclude repetition in response to audit findings and cor-rective action requests. Paragraph D.2.k Criterion III-Failure to establish measures to assure that the appropriate quality requirements and standards are specified and included in design documents for pipe suspension system components.
l Paragraph D.3.a(3)
Criterion II - Failure to apply Quality assurance Program requirements to the preparation and review of "As Built" electrical hanger l
drawings.
Paragraph D.3.g l
l Criterion VI - Failure to use electrical hanger drawings which reflect the latest changes and revisions.
Paragraph D.3.h Criterion V - Failure to follow procedures in regard to the receiving and inspection of electrical penetrations.
Paragraphs D.4.b l-2-
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Table of Contents A.
INTRODUCTION Page No.
1.
Purpose of Inspection.
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2.
Scope of Inspection.
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3.
Facility Description
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4.
Site Organizations a.
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b.
Baldwin Associates QA/QC.
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c.
Project Design and Construction
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B.
CONDUCT OF INSPECTION 1.
Interviews / Discussions
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2.
Persond Contacted
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3.
Management Meetings.
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C.
INSPECTION RESULTS.....................
D.
REPORT DETAILS 1.
Quality Assurance Program.
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a.
Observations.
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b.
Training and Qualification.
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2.
CONSTRUCTION ACTIVITIES Large Bore Pipe Supports and Restraints
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b.
Steam Tunnel Pipe Penetration Assemblies.
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c.
Welding Control
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d.
Reportability Pursuant to 10 CFR 50.55(e)
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e.
Nondestructive Examination (NDE).
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f.
Audit / Surveillance Reports.
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g.
Calibration Control
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h.
Civil / Structural.................
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Electrical Work Activities.
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A-36 Bolts.
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Review of Audits (Electrical raceway supports).
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1.
Observation of Electrical Work Activities
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3.
Design Activities Large Bore Pipe Supports and Restraints
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b.
Control Rod Drive System Supports and Restraints. 45 c.
Small Bore Pipe Suspension Systems.
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d.
Personnel Qualification
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Field Change Requests / Engineering Change Notices.
e.
f.
Review of ECN's, FCR's and PCR's.
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g.
Electrical Raceway "As Built" hanger Drawings
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h.
Document Control.................
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O A.
INTRODUCTION 1.
Purpose of Inspection This inspection was one of several conducted throughout the country at nuclear power plants under construction to evaluate the effectiveness of multi-disciplined team inspections utiliz-ing an integrated inspection approach. The NRC will study these evaluations to determine if the multi-disciplined team inspection concept is more effective in the overall utilization of inspectors and in identifying developing trends so as to avoid serious construction deficiencies and delays.
2.
Scope of Inspection The inspection covered four functional areas; design, procurement, cohstruction and quality assurance / quality control involving several major disciplines. The disciplines inspected included large bore pipe and electrical raceway supports and testraints, piping and electrical penetration assemblies, welding and non-destructive examination.
3.
Facility Description The Clinton Nuclear Power Station is co-owned and managed by the Illinois Power Company, with home offices located in Decatur, Illinois. The site is located in central Illinois in DeWitt County, approximately 22 miles north of Decatur and 30 miles west of Champaign, Illinois. The Clinton Power Station consists of two nuclear units.
Unit 1 is currently under construction. No date has been established for resumption of construction of Unit 2. Completion status of Unit I and shared facilities as of January 27, 1981, was 73%. Engineering was approximately 87% complete.
The nuclear units are boiling water reactors of the BWR 6/ Mark III design furnished by the General Electric Company. Condenser cool-ing is provided by a 5,000 acre man-made lake formed by an earthen dam on Salt Creek. The balance of the plant was designed by Sargent and Lundy Engineers. The plant is being constructed by Baldwin Associates, an Illinois based construction firm.
The license application for each unit is for a core power of 2984 MWT, which will result in a gross electrical output of approximately 950 MWE.
Construction permits CPPR-137 and CPPR-138 were issued for the units on February 24, 1976. The licensee's current project schedule is based on Unit I receiving an operating license and loading fuel in January, 1983.
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4.
Site Organization's a.
Illinois Power Company (IPC) Quality Organization Ultimate responsibility for engineering construction and quality assurance for the Clinton Power Station rests with the IPC Corporate President. Reporting to the Corporate President is the Executive Vice President who directs and manages Clinton Power Station activities through two Vice Presidents, the Vice President of Project Management for Purcha ing and Construction, and the Vice President for Quality Assurance and Station Engineering. The Director of Quality Assurance reports to the Vice President for QA and Station Engineering. He essentially has three major organizational elements:
(1) Quality Assur nce Supervisor of Plant Operations, (2) Quality Assurance Supervisor for Construction, and (3) Quality Assurance Supervisor for Engineering.
The QA Supervisor for Construction has nine Quality Engineers reporting to him with combined expertise in piping, mechanical.
welding, nondestructive testing, civil, structural, and elec-trical. The major responsibilities of the QA Superviser for Construction is to evaluate construction activities of both IPC and BA to assure compliance with the QA program. This is accomplished through regularly scheduled surveillance and reviews of construction activities, and through daily in-teractions with plant staff including the BA QA/QC personnel.
The QA Supervisor for Engineering and the three engineers reporting to him have responsibilities for assuring engineer-ing activities performed by Sargent & Lundy are in compliance with the QA program.
This is accomplished through regularly scheduled audits.
In addition, the QA Engineering Department conducts QA training courses and performs special investiga-
tions in those areas identified by the Director of QA.
Also reporting to the Director of QA is (a) an audit coordinator responsible for collating audit results and l
findings and assuring timely resolution and (b) a special process engineer responsible for review and evaluation of welding and nondestructive testing to assure compliance with the ASME Code.
The overall staffing of the IPC QA organization appears
".o be adequate in regards to size and capabilities with the
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exception that the site Supervisor of QA and s'ome members of his staff are recently new to their assignments.
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b.
Baldwin Associates (BA) Quality Organization The BA Manager of Quality and Technical Services functionally reports to the IPC QA Director and has three major departments;
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the Department of Technical Services, consisting of 50 engi-neers, the Department of Quality Assurance, consisting of 30 engineers, and the Department of Quality Control, consisting of 62 engineers. The Department of Technical Services is respons-ible for quality engineering and inspection of heat treatment, welding, and nondestructive testing. The Department of Quality Assurance is responsible for review and concurrence of quality related programs, engineering and system procedures, and for auditing BA activities at the site and BA suppliers. The Department of Quality Control is responsible for identifying inspection requirements on instruction checklists and for conducting inspection activities at the site. The BA QA/QC technical departments appear to be adequately trained and staffed with the exception of the unusually high turnover of personnel within the QC Department.
In summary, the quality organizations of both IPC and BA have the necessary independence from costs and schedules to effectively carry out their job functions. Botn organ-izations have the necessary authority, including stop work authority.
It is not evident, however, whether they have been unsuccessful in executing this authority or lack agressiveness in the use of this authority. As pointed out throughout this report, it appears the quality organizations could be more effective with stronger emphasis and support by top management and improved quality attention in certain disciplines. This is especially true in the areas of timely corrective actions and in the proper reporting of status and closeout of important problem areas.
c.
Project Design and Construction Organization Illinois Plower Company (IPC), as co-owner and licensee and acting as the project manager, is responsible for the design, construction, and operation of the Clinton Power Station.
IPC has retained Sargent and Lundy, an independent consulting engineering firm, as the architect / engineer and design consultant. The General Electric Company has been retained to design, fabricate, and deliver the Nuclear Steam t
Supply System. The construction contractor for Clinton Power Station is Baldwin Associates.
Baldwin Associates, a joint venture general construction contractor, is responsible for all phases of site and station construction.
B.
CONDUCT OF INSPECTION 1.
Interviews / Discussions During the course of the inspection, approximately 25 formal and informal interviews were conducted with construction, engineering, quality assurance and quality control personnel. These interviews /
discussions included management, supervisors, and inr.pectors and-7-
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were 10 addition to those normal licensee / contractor / inspector contacts and discussions'that occur during any routine inspection.
The purpose of the interviews was to evaluate management in-
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volvement in plant quality activities and to identify strengths and weaknesses in the implementation of the licensee's quality-assurance program and commitments.
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2.
Persons Contacted Principal Licensee Employees (
- G. M. Brashear, Manager of Clinton Site
- A. J. Budnick, Director of Quality Assurance
- W. L. Calhoun, Supervisor of Electric Construction
- R.
J. Canfield, Director of Construction
- E. E. Connon, Assistant Director of Construction
- L. W. Dozier, Assistant Director of Construction
- J. D. Geier, Nuclear Station Engineering Manager
- W.
C. Gerstner, Executive Vice President
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- M. C. Hollon, Supervisor of Construction Quality Assurance
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J. Koch, Vice Presider
- D. E. Korneman, Supervis, of Mechanical Construction
- J. D. McHood, Vice President
- J. S. Spencer, Director of Design Engineering Baldwin Astosiates
- G. A. Chapman, Technical Services Manager
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- B. A. Curby, Project Superintendent
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- J. E. Findley,. Senior Resident Engineer
- L. A. belbert, Quality Control Manager
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- W. J. Parrington, Project Manager l
- L. L. McQuality, Senior Mechanical Engineer
- D. R. Murphy, Senior Electrical Engineer R. Neeb, Senior Piping Engineer
- T. Selva, Quality and Technical Services Manager
- J. W. Smart, Quality Assurance Manager
- H.
Swift, Project Engineer
- T. G. Yearick, Assistant Project Manager Sargent and Lundy M. A. Atia, EMD Project Engineer
- L. E. Ackmann, Director of Services
- E. B. Branch, Head of EMD
- W. G. Hegener, Mechanical Department Manager
- R. C. Heider, Project Manager
- J. E. McFarland, Head of Quality Assurance Division
- J. M. McLaughlin, Structural Department Manager J. A. Patel, Supervising Structural Design Engineer
- H. M. Sroka, Project Director-8-
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General Electric Csmpany
- J. L. Dempster, Resident Site Manager U.S. Nuclear Regulatory Commission
- H. H. Livermore, Senior Resident Inspector The inspectors also contacted other licensee and contractor personnel including members of the quality, technical and engineering staffs.
- Denotes those present at the exit interview.
3.
Management Meetings An entrance meeting was conducted at the Illinois Power Cempany corporate offices in Decatur, Illinois on January 21, 1981, to inform licensee management of the impending inspection and to briefly discuss the purpose an3 scope of the trial program.
A similar entrance meeting was conducted with site management personnel prior to the start of the inspection on February 9, 1981. The team members were introduced and the initial schedule of activities was discussed.
Baldwin Associates Construc-tion managers each made a brief presentation of on-going and planned activities in their discipline for the next few weeks.
Brief interim meetings were held with site personnel on February 13, and 27, 1981, to discuss status of the inspection efforts and significant findings that may require immediate licensee attention.
A full exit interview was conducted at the Clinton site with site personnel and Illinois Power corporate management on March 5, 1981.
A summary of the itadings and significant observations was discussed.
A management meeting was held with representatives of Illinois Power Company, Baldwin Associates and Sargent and Lundy Engineers at the Region III offices on Match 12, 1981, to summarize the inspection results and conclusions. The matters discussed are documented in Section C, Inspection Results, below.
C.
INSPECTION RESULTS 1.
General One of the purposes of the trial team concept was the concurrent inspection of parallel ongoing functional areas by a multidisci-plined inspection team; then the evaluation of identified problems or lack of effectiveness in any of the functional areas to determine if they were symptomatic of a more common problem.
The conclusion from the trial team inspection at Clinton was that some of the observations and findings did appear to have a common root cause which is discussed under item 2 below. This-9-
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conclusion, in part, is subjective ano includes perceived strengths-and weaknesses in the Jicensre's management controls which may not have specific regulatory requirements or guidance.
A management meeting was held in the Region III offices on March 12, 1981, with representatives of Illinois Power Company, Baldwin Associates and Sargent and Lundy Engineers. The purpose of the meeting was to discuss the NRC conclusions from the trial team inspection at the Clinton Nuclear Power Plant. The licensee agreed to respond in writing to each of the matters discussed under item 2 below.
2.
Conclusion In general, the overall quality assurance program and the QA/QC organizations of IPC and BA appear to have the essential elements to control design and construction activities. Specific weaknesses do exist however, which left uncorrected could lead to a breakdown in the quality assurance program.
Based on observations, review of documents and interviews and discussions with construction, engineering and_QA/QC personnel, there appears to be a problem in the use of authority and involve-ment of the quality organization of IPC and BA in the engineering and construction organizations relative to the identification and resolution of QA/QC problems. Evidence of this include:
Weakness in the identification of root causes and the a.
initiation of prompt and effective corrective action.
For example - BA QA audits I-134 conducted January 10-16, 1980, and I-137 conducted February 16-17, 1980, and Cor-rective Action Request (CAR) No. 049 issued February 29, 1980, identified serious deficiencies relative to class IE electrical raceway hanger installations and contained warnings that considerable a.-d prompt improvement was needed. Although corrective action was taken it proved to be inadequate in that a followup audit I-150 conducted June 17-23, 1980, contained five adverse findings and a statement that the corrective action provided in response to audit I-134 and CAR 049 has been ineffective in prevent-ing recurrence of the discrepancies.
The initial response by Construction to audit I-150 was not accepted by BA/QA and a revised response sas requested in a memorandum dated July 29, 1980. A followup verification
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audit conducted August 7, 1980, still found that inadequate or no corrective act:on had been implemented for two of the five adverse findings in audit I-150.
On September 16, 1980, inadequate construction controls concerning electrical race-way hanger installations was verbally reported to the NRC hegion III office and on October 20, 1980, the matter was formally reported as a significant construction deficiency
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pursuant to the requirements of 10 CFR 50.55(e) and a stop work order was issued by the licensee. The open I-150 audit findings were suLsequently closed based on the 10 CFR 50.55(e)
report.
A significant percentage of approximately 2000 completed and in process hangers were found to deviate from the design re-quirements. Part of the necessary corrective action relative to the 10 CFR 50.55(e) report was the development of "As Built" drawings by IPC engineering personnel. The "As Built" drawings apparently were to be reviewed by S&L design engineering to
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determine if the hanger would still meet design functional re-
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quirements even if it was not completely in agreement with the initial design documents.
On February 19, 1981, an inspection team member conducted a sample review of the first group of these "As Built" drawings which bco been returned from S&L about three weeks earlier.
The review identified errors and inconsistences in dimensions on the drawings yet S&L had approved the drawings with no comments. Further review indicated considerable confusion existed relative to the preparation and review of the "As Built" drawings by IPC and the review and approval by S&L.
The apparent cause was that Clinton QA program procedure requirements had not been implemented for these activities.
Summary Deficient Class IE electrical raceway hanger installation ac-tivities continued over a nine month period with ineffective construction and engineering controls and inadequate QA involvement and enforcement of quality program requirements to bring about timely corrective action.
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No controlled and documented system has been fully and ef-
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fectively implemented as of February 27, 1981, to identify l
the status of items as to their acceptability to procurement l
specification requirements.
An IPC QA review conducted in November, 1978, noted that l
i standard S&L K-specification requirements including the I
development of a detailed list of quality control documenta-l tion to be included as part of the specification was not being met.
A QA audit of BA in March, 1979 noted the same deficiency. The corrective action was for BA to develop a checklist for each K-specification to identify the documenta-f tion requirements and provide a means for QC to evaluate the
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status of quality documentation submittals. The completed checklists were to be used as part of the receiving inspection records.
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When the use of the documentation checklists resulted in placing a large number of items on " conditional accept" because of missing documentation, BA was instructed by the IPC Assistant Director of Construction to develop two checklistn - One for documentation required by specifica-tion quality articles and the other for documentation required by technical articles. This action implemented by BA Procedure No. 2.20 (BAP), June 30, 1980, permitted QC to accept unconditionally an item in receiving inspection as long as the documentation required by the quality articles was available without regard to the availability or status of the so called engineering (technical) documentation.
IPC QA management apparently did not agree with this action and felt that the classification of certain quality doc-umentation as " engineering documentation" and unconditionally accepting items with missing or incomplete documentation was in violation of IPC commitments. This is evidencedlby state-ments contained in a report of a special review completed by IPC QA in September, 1980 and in a letter dated October 23, 1980, from the IPC supervisor - Construction Quality Assur-ante to the BA Manager, Quality and Technical Services.
Further the IPC Director of Quality Assurance reiterated this position in the letter transmitting the report of the IPC special Qi review to IPC corporate management with a recommendation that decisive action be taken to resolve the documentation problems discussed in the report.
The licensee maintains, as discussed during the March 12, 1981 meeting, that the provisions of BAP 2.20 Revision I and BAP 2.3 Revision C for:
(1) dividing documentation needed to show equipment conforms to procurement require-ments into two classifications " quality" ar.d " engineering,"
and (2) using only the status of the " quality" documentation for determining acceptability of equipment relative to its i
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release for installation is consistent with IPC's PSAR l
commitments, 10 CFL 50, Appendix B, ANSI N45.2, ANSI N45.2.2 and ANSI N45.2.13 requirements.
j The licensee's position on this matter appears to represent l
a significant departure from NRC guidance and requirements l
applicable to this activity and is considered unresolved
pending receipt of further information from the licensee.
l This additional information, needed before the issue can be fully defined for referral to the NRC headquarters staff for resolution is identified in Appendix B of the transmittal letter for this report.
As of March 5, 1981, the Engineering Documentation Checklist for selected class 1E electrical penetrations unconditionally released and installed was not available nor were other
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records made available to establish the acceptability of l
these penetrations to specification requirements.
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Summary Significant amounts of equipment has been accepted in violation of procurement specification documentation requirements, and released for installation without full
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knowledge of the status of required documentation or.
identification of the equipment as to its acceptability.
The Clinton plant quality control and quality assurance organizations and project management has allowed this situation to continue for two years and only recently had
<teps been taken to bring it under control.
c.
W(akness in the development of installation /QC inspection plans and criteria and in the timeliness and effectiveness of QC inspections.
For example, during the team inspection the following de-ficiencies were identified relative to large bore pipe supports and restraints:
(1) Some installation / inspection for dimensional tolerances, such as base plate bolt hole location, bolt pattern, support pin-to pin dimension, fastener torque valves, etc., had not been established.
(2) Specific installation instructions and precautions for handling mechanical snubbers were not included on procedures.
(3) QC inspection checklists did not reference specific criteria that were based on approved inspection / design documents.
(4) No time limit established between completion of hanger installation and QC inspection.
(5) Present hanger installation program does not require documentation as to who installed the component items and when the work was completed.
Further, in regard to the steam tunnel piping penetra-tions; there was a lack of detailed procedures for instal-ling the seismic guides between the guard pipe and process pipe to control weld distortion to maintain the critical clearances needed between the guides and process pipe.
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Summary Weaknesses in the travelers" which detail installation and inspection requirement, have frequently been identified in QA audits and surveillances.
Improvements have resulted from recent changes but further attention is needed as evidenced by the team inspection findings.
Included
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d should be:
(a) strong action by QA/QC when hold points are bypassed, (b) assuring current requirements are reflected in the travelers, if QC (as recently requested by the manager) is removed from the review cycle for Field Change Requests (FCR's) and-(c) closer review in establishing inspection points so they occur in the proper sequence to assure design requirements are met.
d Weakness in adherence to procedures, design requirements and PSAR commitments.
For example:
(1) No apparent procedure exists describing how PSAR commitments are carried out. A computer printout system was described to_the inspector whereby commit-
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ments and re:ponsibility for those commitments were identified however the printout did not include Regulatory Guidas, ANSI Standards and certain PSAR commitments.
(2) S&L Specification K-2978 for electrical penetrations and BAP 2.20 require a written authorization from the licensee to the vendor, prior to shipment, authorizing the vendor to substitute a certification of compliance (C0C), for missing documentation. These requirements were not adhered to.
(3) Procedures BA 2.20 and BA 2.3 specifically require that equipment received onsite with a C0C in lieu of complete documentary evidence of conformance to requirements, be accepted under a conditional accept" status. These procedure requirements are not being followed.
Summary Quality organization could be more effective with stronger emphasis and support by top management. Throughout the in-terviews and discussions, the prevailing attitude was getting the job done with inadequate concern for QA/QC and job details.
QA/QC in their enforcement of procedures'and other require-ments must not be unduly swayed by arguments based on cost and schedule considerations. Recent changes have resulted in improvements but further improvements are needed.
e.
Other items (1)
IPC QA does not review and concur with Nuclear Station Engineering Department and Clinton Site Activities Procedural Manuals. Both of these documents address QA/QC program controls and how they are to be carried out.
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(2) Construction and Engineering are making QA decisions.
For example, item C.2.b above, item D.2.j below and omission of QA on letters indicating corrective action relative to electrical raceway hanger "As Built" drawings.
(3) QA is not doing an adequate job of feedback on (a)
corrective action activities and highlighting those areas where serious weaknesses in construction exist, and (b) problem areas which have been previously identified but not yet corrected.
(4) Upper management does not appear to be sufficiently involved in assuring that (a) problem areas are-identified and reported to them in a timely manner, (b) proper attention is being devoted to determining the causes and resolutions of the problems, and (c)
followup action is initiated to verify problems are adequately resolved and closed.
Summary Management is not sufficiently involved in plant quality problems and has not fully utilized QA as a management tool.
D.
REPORT DETAILS 1.
Quality Assurance The QA inspection effort covered licensed activities in selected functional areas.
In each of the functional areas the inspector reviewed written policies, procedures, and instructions; inter-viewed selected personnel; and reviewed selected records and.
documents to determine whether:
The licensee had written policies, procedures, or instruc-
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tions to provide management controls in the subject area; The policies, procedures, and instructions of the item above
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were adequate to assure compliance with the regulatory requirements; and, The individuals assigned responsibilities in the subject
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area were adequately qualified and understood their responsibilities.
The observations provided in this report include perceived strengths and weaknesses in the licensee's management controls which may not have specific regulatory requirements or guidance.
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Specific areas that were reviewed are:
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Illinois Power Company's (IPC) tad Baldwin Associates'
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(BA) QA programs and the organizations responsible for establishing and implementing the programs.
Upper management involvement in assessing the status and
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adequacy of the _ QA program with emphasis placed on programs for reporting problems, causes, and corrective actions to preclude recurrence.
Traceability and accountability of PSAR commitments to.
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documented procedures and the program for documenting and verifying that PSAR commitments have been complied with.
The training and qualification program for BA Quality
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Control inspectors.
a.
Observations (1) The docketed PSAR QA programs of IPC and BA meet the requirements of Appendix B to 10 CFR 50 and include the necessary commitments to the quality related regulatory guides, codes and industry standards.
(2)
IPC and BA have further described their QA programs in the following procedural documents:
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I QA Instructions and Notices Nuclear Station Engineering Department Procedures Clinton Site Activities Procedure Manual BA I
BA QA Manual QA Procedural Manual Project Procedures Manual Job Instructions Manual Technical Services Manual Procurement Manual Quality Control Training / Qualification Manual l
l (3) The IPC and BA QA and the BA QC organizations charts show the necessary separation and independence from the engineering, construction, and procurement organizations to preclude undue influence and pressure from cost and schedules.
(4) The overall attitude of IPC and BA towards being responsive to problems presented by NRC has improved. This was previously reported as a problem in the November 12, 1980 SALP report.
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(5) In general, the overall QA program and the QA/QC organiza-tions of IPC and BA appear to have the essential elemants to control design and construction activities, however, the following weaknesses were observed in the QA program which require improvements in order for the QA program to be more effective.
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(a) IPC QA does not review and concur with Nuclear Station Engineering Department Procedures and the Clinton Site Activities Procedural Manual.
Since these documents address QA/QC program controls cnd how they are to be carried out, then the QA organization representing an independent department with QA/QC expertise.should be required to independently review and document concurrence of these documents prior to their issuance.
It is not sufficient to allow the compliance engineer in the departments originating these documents to be responsible for the quality review since he can easily be influenced by the departments' head and.by cost and schedules.
The review by the QA department should assure that the documents identify the organizations responsible for implementation and that the documents contain the necessary QA/QC controls consistent with the QA manual and the commitments and quality related regulatory guides and standards contained in the PSAR QA program.
(b) BA document control is lax in'several areas.
BA documents " Quality Control Training / Qualifications Manual" and " Quality Control Instructions" are not properly controlled by number and revision date on each procedural page.
(c) Surveillance, audits, and special surveillance findings are well documented but not adequately tracked and followed to assure proper attention has been given to documented causes and initiation of corrective action.
(d) IPC QA is not adequately involved in the Tuesday Weekly Schedule meeting to keep abreast and participate in quality related problems and schedules. This is an excellent opportunity to assess and determine if the scheduled. activities provide for adequate quality documentation and qualified QA/QC staffing to perform the assigned tasks.
IPC QA is, however, involved in the monthly Pre-owners and Owners meeting. The more important QA/QC matters are discussed in this meeting but the day-to-day schedules and construction and QA/QC problems are not.
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(e) QA controls appear weak in requiring traceability and accountability of PSAR commitments to documented-procedures and requiring documented verification that PSAR commitments have been met.
This was previously addressed in the November 12, 1980 SALP report.
The PSAR contains design _ inputs, design bases, regula-tory requirements, codes, and standards and should be classified as a controlled document. Accordingly, Appendix B, N45.2 and N45.2.11 require that procedures be established for translating these requirements of PSAR to design drawings, specifications, procedures, and instructions and that these documents be also controlled.
IPC and BA program manuals and procedures do not provide sufficient description of how PSAR com-mitments, including codes and standards, are translated into implementing procedures and the controls that are necessary to assure they are properly carried out.
In discussions with IPC and BA personnel, sufficient evidence could not be provided to demonstrate that an adequate system was in place to show accountability that PSAR commitments, especially the QA program com-mitments, were covered by procedures and properly carried out.
Responsibilities of who is to control the PSAR commitments were also not provided.
BA had a matrix of the ANSI N45.2.2 commitments but not of quality related ANSI Standards, QA program commit-ments, and other PSAR commitments. Top management should be involved to assure that all PSAR commitments are properly accounted for through procedural controls, with described responsibilities for assuring PSAR sections are properly carried out, and that a matrix system or comparable system be provided to show status of meeting PSAR commitments.
(f) There appears to be a problem in the use of authority and involvement of the quality organizations of IPC and BA in the engineering and construction organizations relative to the identification and resolution of QA/QC problems. This observation was arrived at by impres-sions received through discussions with personnel of construction, engineering, and QA/QC In addition, the apparent QA/QC weaknesses described in this r2 port further substantiates this observation.
(g) The IPC QA construction supervisor and IPC QA Director are strong in Nuclear Navy related activities; but, compared to expected experience for managers in these positions they may not have an adequate indepth know-ledge of QA/QC, nuclear construction and engineering
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background necessary to carry out and defend an effective and strong QA program and to hold their own with construction and engineering.
(h) There is lack of an effective feedback reporting system to management, especially at the VP and Executive VP level of thi strengths and weaknesses of the quality of plant activities. There appears to be no system within IPC QA for (1) reporting rework or repair against that projected, (2) reporting BA's corrective action ac-tivities and highlighting those areas where serious weaknesses in construction exist and (3) reporting problem areas which have been previously identified but not yet corrected.
(i) There appears to be a lack of a strong positive emphasis to QA by top management. Throughout the interviews, the prevailing attitude was getting the job done with in-adequate regard to QA/QC and attention to details.
Corporate management must stress and emphasize the company's total-commitment to quality assurance as a management tool which must permeate through and across all organizational levels. Therefore, it is imperative that top management understand the management, adminis-trative disciplines of quality assurance, and recognize the need for managers and working staff to incorporate these disciplines in day-to-day activities.
b.
Training and Qualification of the BA Quality Control Inspection Staff Baldwin Associates' (BA) training and qualification program for
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Quality Control personnel responsible for inspections in the following areas were evaluated: Material Control, Piping and Mechanical, Raceway and Supports, Electrical and Civil, and Structural.
(Note: This does not include inspectors involved in inspection and nondestructive testing of welds, which is under
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the responsibility of BA Technical Services.) The objective of
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this evaluation was to determine (1) the degree to which BA complied with their commitment to Regulatory Guide 1.58-1973,
" Qualification of Nuclear Power Plant Inspection, Examination,
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l and Testing Personnel," which endorses ANSI 45.2.6-1973, and (2) the effectiveness of the training and qualification program.
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The evaluation included a review of Illinois Power Company's (IPC)
and BA's Quality Assurance organization involvement in auditing l
BA's training and qualification program. Training procedures of j
the BA Quality Control Training / Qualification Manual were reviewed, the training records of twelve (12) inspectors were evaluated, and interviews with three inspectors were conducted l
to gain an appreciation of their knowledge of Quality Control
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principles and inspection functions.
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Observations (a) The BA Quality Control inspectors appear to be qualified to perform inspection functions within their assigned areas of responsibility. This is substantiated by (a)
the experience and training documented in their training and qualification-file; (b) through discussion and interviews with BA Quality Control Manager and Quality Control Inspectors, and (c) through selected observa-tions of ongoing inspections.
(b) The training and qualification procedures of the BA Quality Control Training /Qualificatdoa Manual are deficient in describing criteria and details for determining when an individual is properly trained and qualified. Specific documented training and qualifica-tion plans are necessary to supplement the Training and Qualification Manual.
(c) The BA Quality Control Training / Qualification Manual procedures are not controlled by a pt-ocedure number and by either a revision number or revision date on each procedural page consistent with other BA controlled documents. The front page of the training manual noted a complete revision 3, dated August 9, 1979, without notating other procedural pages in the manual by a revision 3 or by_the revision date, August 9, 1979.
This condition is not consistent with IPC and BA document control commitments. BA Documents S-1A42.1 (Training Manual) and S-1-A2.3.13 (QC Instructions)
need to be upgraded to controlled documents.
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(d) The Quality Control inspectors interviewed appeare. to have been properly trained and were knowledgeable in Quality Control and inspection techniques with the following exception.
They were not aware of the importance in determining +.he accuracy of inspection devices necessary to assure valid measurements.
BA PSAR QA Program (Section 17.1.10.5)
requires inspection procedures contain inspection methods, and the type, range, and accuracy of inspection instru-I ments; however, these are not reflected in the BA pro-cedures. This was discussed with the BA Quality Control Manager and he recognized the need to take actions to meet the PSAR commitments.
(e) IPC and BA QA audits of the BA training and qualifica-tion program appeared to be satisfactory in that substantive findings were made in the need for the BA Quality Control Department to conduct a more organized and formal on-the-job training program and provide for
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an improved system for documenting and filing training qualification and certification records commensurate with their training manual.
(f) BA Quality Control inspection staff consists of 63 in-spectors of which 12 are presently going through an ongoing training and qualification program to meet Level I requirements. Recruitment is ongoing to in-crease the staff to 77.
This recruitment is a result-of a recently high turnover of personnel due to trans-fers within the BA organization, better paying jobs at other utilities or layoffs due to poor inspector per-fo rmance.
Since there is a scarcity of qualified inspectors and quality engineers because of their demand throughout the nuclear industry, there is the real potential that the BA QC department.could be seriously weakened though a continued reduction in qualified in-spection personnel.
Accordingly, close attention is advised in this area by IPC and BA management to assure that the recruitment effort does not result in a deterioration of the quality engineering and quality control activities at the site.
(g) The overall BA Quality Assurance and Quality Control staffing is 130 and recruitment is ongoing to increase this to 166.
BA tries to maintain a ratio of one QA/QC man for every ten craft and technical personnel onsite Conclusions BA Quality Control inspectors appear to be. qualified; however, the procedures describing the training program are deficient and require action on the part of BA to improve these relative tt, the need for specific doc-umented training and qualification plans for each individual and the upgrading of their Training Manual and QC instructions to controlled documents. The in-spection program is deficient in not providing instructions as to the method of inspection and '.he type, range, and accuracy of inspection instruments, as required in the PSAR (Section 17.1.10.5).
Close manage-ment attention is advised to assure that the extensive recruitment effort of QC inspectors is effective in obtaining properly trained and qualified personnel.
Personnel contacted in the evaluation of the BA Quality Control Training and qualification of Quality Control Inspectors:
Randy Folck - IPC QA Construction Jim Smart - BA Quality Assurance Manager Larry Gelbert - BA Quality Control Manager Allen Lynch - Piping / Mechanical Inspector, Level 1
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Brian Weaver - Piping / Mechanical Inspector, Level II C. Winfrey - Civil Structural Inspector, Level II Training and Qualification files reviewed:
Bill Shinneman - Electrical Inspector, Level II Dennis Threatt - Electrical / Soils / Civil Inspector, Level II Don Richter - Electrical Inspector, Level II Ben Hendricks - Electrical Inspector, Level II Bob Helton - Electrical Inspector, Level I b ian Weaver - Piping Mechanical Inspector, Level II Allen Lynch - Piping Mechanical Ir.spector, Level I Coleman Price - Piping Mechanica!. Inspector, Level II Lee Shaffert - Civil Structural Inspector, Level II Richard Whitehead - Electrical Raceway Hanger Inspector, Level II David Cordy - Vendor Surveillance Inspector, Level II Jim Connelly - Rebar/ Concrete / Soils Inspector, Level II In addition to evaluating the training and qualifica-tions of BA Quality Control Inspectors, two Quality Assurance Audit Engineers (Richard Forbes, Level II, and H. Katayanagi, Level II) and one Systems and Procedures Engineer (D. Selva, Level II) were also evaluated and a finding made that their training and qualifications were well within requirements.
2.
CONSTRUCTION ACTIVITIES a.
Large Bore Pipe Supports as Restraints (1) Procedures Review The inspector reviewed the following BA procedures:
l BAP 2.14, " Fabrication / Installation of Items, Systems, Components, and Component Supports," Revision 2, dated
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October 4, 1979, including Project Change Request (PCR)
22-81, dated Februa ry 4,1981.
BAP 2.16, " Concrete Expansion Anchor Work," Revision 5, dated December 19, 1980.
BAP 2.11, "Higging, Hoisting, Handling," Revision 5, dated December 9, 1980, and PCR's including PCR-1-81.
QCI, " Piping / Mechanical QC Inspection Criteria, Phase II Hanger / Support Installation Instruction," dated January 23, 1981.
Subsequent to the procedure review the inspector concluded:
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(a) Not all installation / inspection dimensional tolerance, such as base plate bolt hole location / bolt pattern, support pin-to-pin dimension (see FCR 5856), fastener torque values, snubber cold settings had been estab-lished.
(b) Specific installation instructions and precautions,
-such as the handling of Pacific Scientific Company mechanical snubbers, were not included in the pro-cedures.
(c) The QC inspection checklists did not reference any specific acceptance criteria that were based on approved inspection / design documents.
The lack of adequate hanger installation and QC inspection procedure is considered an item of noncompliance. (461/81-05-01)
(2) Observation of Hanger Installations On February 9,10, and 12,1981, the inspector, in the company of IP QA and BA QC observed and inspected a number of safety-related hanger, restraint, and mechanical snubber installations. The findings are as follows:
(a) Snubber M-ISX17004S, Revision A. (Traveler H-SX-19-C)
The installation offset angle exceeded the 1*
requirement established on S&L Drawing M09-1001N, Revision C.
Pin-to pin measured l' - 8-1/2" versus l' - 9-1/16" design required.
Snubber Cold Position Setting (CPS) set at 1" versus 2-9/16" as specified.
Loose nuts.
Field weld completed on September 26, 1980. No record on who installed the hanger, and when the work was done.
(b) Variable Spring Hanger M-ISX17015V, Revision B.
(Traveler H-SX-23-A)
The installation offset angle exceeded the I requirement established on S&L Drawing M09-1001N, Revision C.
Loose nuts.
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Field weld completed on August 20, 1980. No record on who installed the hanger, and when the-work was done.
(c) Snubber M-ISX17016S, Revision A (Traveler H-SX-23-A)
The installation offset angle exceeded the l'
requirement established on S&L Drawing M09-1001N, Revision C.
Pipe clamp was tilted and covered up some weld areas on pipe elbow.
Snubber CPS set at 5" versus 2-7/16" as specified.
Field weld completed on September 8, 1980. No record on who installed the hanger, and when the work was done.
(d) Sway Strut M-ISX17017X, Revision C. (Traveler H-SX-23-A)
Support structure member (Item 2 on the drawing)
measured to be l' - 9" versus 2' - 3" as specified.
Installation of lug measured l' - 6" away from wail versus 2' - 0" as required.
Loose nuts.
Grease plug missing.
It was stated by BA construction that Revision C revised dimensions subsequent to the installation.
Field weld completed on March 3, 1980. No record on who installed the hanger, and when the
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work was done.
(e) Sway Strut M-1SX18012R, Revision B. (Traveler H-SX-20-C)
Bottom of the pipe clamp was buried in pipe in-l sulation of another pipeline below.
Loose nuts.
Grease plug missing.
Field weld completed on June 10, 1980. No record on who installed the hanger, and when the work was done.
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(f) Rigid Support M-1LPO4003R, Revision A. Traveler H-LP-2-0)
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Shear lug orientation was incorrect (5* versus
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45* required) resulting in a two point support on riser instead of four point-support as re-quired.
Anchor bolts with M-marking were observed where drawing called for 1/2" Kwik bolt, 5-1/2" long (I-marking).
Anchor bolts were not installed correctly. One
of the bolts was measured 2-3/4" from plate edge instead of 1" that was specified.
Drilling of t new anchor bolt hole, without first repairing the drilled hole adjacent to it, was not in accordance with BAP 2.16, " Concrete Expansion Anchor Work," Revision 0 (June 9, 1978)
to Revision 5 (December 19, 1960) requirement.
Shear lugs were not resting in full contact with the pipe riser clamp.
Loose nuts.
7-No field welding documentation.
No record on who installed the hanger, and when the work was done.
(g) Sway Strut M-1LP04030X, Revision A. (Traveler H-LP-2-E)
The sway strut assembly was installed 2" below the design elevation.
Nuts and cotter pin missing.
Loose nuts.
End of the sway strut was bent-shown material damage.
The installation offset angle exceeded the 2*
requirement established on S&L Drawing M09-1001N, Revision C.
Pipe clamp covered up weldment on pipe elbow.
No record on who installed the hanger, and when the work was done.
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(h) Rigid Hanger M-IVG01022R, Revision A QC inspected and accepted. The inspector had no adverse finding.
(i) Rigid Hanger M-1D004004R, Revision B. (Traveler H-D0-3-A)
The installation offset angle exceeded the 1*
requirement established on S&L Drawing M09-1001N, Revision C.
Excessive opening (or gap) on bottom of the pipe clamp-shown improper installation.
Rod (Item 7 on the drawing) was measured 2' - 5" 2' - 8" as specified.
Field weld completed on February 7, 1980.
No record on who installed the hanger, and when the work was done.
The inspector concluded:
(1) The actual QC inspection was performed by the BA QC inspectors. Their work performance was considered to be good. (2) There were generic problems on hanger installation.
Construction not in accordance with design requirements was considered an item of noncom-pliance.
(461/81-05-02)
(3) Review of Hanger Inspection Program In view of the fact that approximately 1220 safety-related pipe hangers had been installed to the date of the inspection, and that only 123 were inspected (with 66% rejection rate)
by January 19, 1981, there was apparent shortcoming of the subject program provisions.
In conjunction with findings l
l during installation observation and procedure review, the causes of the problems could be summarized into the follow-ing areas:
(a) There is a lack of program establishment on maximum i
time span between after hanger installation and QC
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inspection. Because of this, the corrective actions were not initiated to prevent the apparent repetitive nonconformances identified during the inspection.
(b). Present hanger QC inspection program does not recognize the need to distinguish the items of installation in-spection and the items of final adjustments prior to system functional testings, such as tightening the fasteners and adjusting the load settings.
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(c) Present hanger installation program does not require documentation on who installed the component items, and when the work was completed. As such, no trend analysis can be performed to identify the underlining causes of the problem and to initiate effective corrective measures to prevent recurrence.
The ineffective and insufficient hanger inspection program was considered an item of noncompliance.
(461/El-05-03)
As a result of the inspection findings. BA Resident Engineer issued a Stop Work Order, JEF-63-81, on February 13, 1981,
to stop installation of all safety-related pipe hangers.
(4) Review of Hanger Audits and Surveillances
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(a) The inspector reviewed some of the applicable S&L internal audit reports on hanger design and stress analysis on February 18, 1981, at S&L. He considered that the S&L QA did not identify the generic problem discussed in Paragraph D.3.a(3) below,-i.e., con-struction drawing issuance prior to calculations being pe rfo rmed.
S&L Reports oa Internal Audits (RIA) Reviewed:
RIA No. 33, conducted on December 11-15, 1978, review component calculations.
RIA No. 40, conducted on February 13-15, 1980, personnel qualification and training.
RIA No. 44, conducted on October 14-28, and November 17-25, 1980, component calculations.
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RIA No. 46, conducted on December 29-31, 1980 and January 5-7, 1981, calculation of component supports.
(b) The inspector reviewed all the IP audits of S&L from the period of 1977 to the present. Reports reviewed included:
Q35-PY-77(10-03)-0, conducted on October 25-28, 1977.
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Q35-78(12-05)-6, conducted on October 24-27, 1978.
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Q35-79-1, conducted on April 18-20, 1979.
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Q35-79-2, conducted on November o-8, 1979.
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Q35-80-1, conducted on April 30 and July 8-9, 1980.
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Q35-80-2, conducted on May 6-8, 198O.
Q35-80-3, conducted on October 20-23, 1980.
Except as discussed in Paragraph D.3.2(3) below, that Q35-80-3-1 identified hanger calculations were performed
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without review and approval, no other audits stated above - covered audits of hanger program adequacy.
In the program audit, Q35-PY-77(10-03)-0, finding in the area of design control was..."The method and result of design calculation review (as specified in Para-graph 3.B.2 of GQ-3.08) is not adequately documented with the design calculations in some cases. Several structural design calculations; SD-Q10-91DG01, SD-Q11-21DG00 and SD-Q1241DG00, were checked and did not contain any statement about the method or results of the design review." TP ecommendation on cor-rective action was..."S&L t.;uct in indepth review of all disciplines' design review calculations to establish the full extent of the problem, bring all calculations into full compliance with the require-ments.
Consider a documented training program which retrains the affected parties in the requirements of GQ-3-3.08."
In view of the lack of hanger calculation which' occurred in 1978 and 1979, the corrective action appeared to be inadequate.
(c) The inspector reviewed all the IP audits of BA site activities from the period of 1977 to the present, and found no audit of hanger installation and inspection activities. Audit reports reviewed:
Q31-PY-77(11-09)-6, conducted on September 1-20, 1977.
Q31-PY-78(05-08)-6, conducted on April 11-14, 1978.
Q31-78(10-24)-7, conducted on October 9-12, 1978.,
Q31-79-1, conducted on March 26-29, 1979.
Q31-79-2, conducted on October 22-25, 1979.
Q31-80-1, conducted on March 25 27, 1980.
Q31-80-2, conducted on July 28-31, 1980.
Q31-80-3, conducted on October 20-24, 1980.
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(d) The inspector reviewed some of the BA audit reports on piping erection. The BA QA Internal Audit Reports re-viewed included:
I-074, conducted October 3-6, 1977, piping traveler control.
I-098, conducted on May 22, and June 2, 1978, control of fabrication / installation travelers.
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I-107, conducted on October 17-20, 1978, similar to I-098.
I-133, conducted on November 30 and December 3-13, 1979, piping fabrication / installation.
I-135, conducted on January 22-24, 1980, piping hangers.
The only auc',
on hanger, I-135, concluded that, "the piping hanger installation program is both effective and properly implemented."
(e) The inspector reviewed the following IP surveillance reports relative to the site hanger activities:
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Q24-PY-78(05-23)-0, hay 15-19, 1978.
Q24-PY-79(02-14)-0, February 5-10, 1979.
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Q24-PY-79(03-29)-0, March 5-9, 1979.
Q24-PY-79(05-25)-0, April 23-27, 1979.
Q24-PY-80(05-15)-0, May 5-9, 1980.
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Q24-PY-80(05-19)-0, May 12-16, 1980.
Q24-PY-80(06-26)-0, June 16-27, 1980.
Q24-PY-89(09-24)-6, September 15-25, 1980.
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Q24-PY-80(10-03)-6, September 28 through October 3, 1980.
Q24-PY-80(10-14)-6, October 6-10, 1980.
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1_1 Q24-80(12-12)-0, December 8-12, 1980.
As a result of the review, the inspector concluded that there were a number of hanger welding inspections per-formed, problems relative to hanger installation traveler and drawings were being identified.
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In conclusion, the inspector stated that the lack of IP snd BA overall hanger program audits to ensure program adequacy and effectiveness resulted in problems as iden-tified during this inspection. This is an item of non-compliance.
(461/81-05-04)
b.
Steam Tunnel Pipe Penetration Assemblies (1) Review of Instructions The inspector reviewed the following drawings and specifica-tions prior to observation of installation activities:
S&L Drawing Nc M06-1000 Sheet 1, " General Notes" Revision F, dated October 31, 1979.
S&L Drawing No. M06-1000, Sheet 2, " Detail of Pipe Attach-ment," Revision F, dated July 17, 1980.
S&L Drawing No. M06-1000, Sheet 3, "Mair. Steam Head Fitting on Guard Pipe," Revision G, dated March 7, 1980.
S&L Drawing No. M06-1000, Sheet 4, "Special Forged Head Fitting Details," Revision C, dated June 13, 1980.
S&L Drawing No. M06-1000, Sheet 5, " Guard Pipe Details,"
Revision H, dated July 17, 1980.
S&L Drawing No. M06-1000, Sheet 6, " Guard Pipe Details,"
Revision H, dated May 21, 1980.
S&L Drawing No. M06-1000, Sheet 7, " Guard Pipe Details,"
Revision F, dated May 21, 1980.
S&L Drawing No. M06-1000, Sheet 8, " Guard Pipe Details,"
Revision E, dated November 19, 1979.
GE Specification 22A6792, " Installation Instruction for GE Piping Systems," Revision 0, dated August 10, 1979.
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GE Specification 22A4296, " Guide, Pipe, Main Steam,"
Revision 0, dated August 12, 1976.
GE Specification 22AS404, " Installation Instruction for GE Piping Systems," Revision 0, dated August 10, 1979.
GE Specification 22A5404A, data sheet, Revision 0, dated December 1, 1980.
Paragraph 7 of Specification 22A5404, regarding installation of penetration assemblies, states that, "This instruction pertains only to the process pipe, and except for specific certain interface requirements, does not apply to various
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supports, seismic guides, bellows, containment penetrations, insulation or jet deflectors," and " Installation of the penetration assemblies shall be performed in accordance with the A-E design requirements."
As a result of the review, the inspector considered thzt both GE instructions and S&L drawing design requirements to be adequate. However, subsequent to the observation of the pipe penetration installation for the 6" Reactor Water Cleanup (RWCU) line, the inspector considered the construction work procedures listed in BA Fabrication / Installation Travelers, Traveler No. RT-31-B inadequate in that there was a lack of necessary detail for installing the seismic guides inside the guard pipe to control weld distortions, which resulted in zero clearance between the process pipe and the guides.
The S&L drawing required 0.010" clearance on all four guide locations.
The lack of necessary detail in restraint installatt.on procedure was another example of the noncompliance ciscussed in Paragraph D.2.a. (1).
(461/81-05-01)
(2) Observation of Pipe Penetration Installation On February 26, 27 and March 4, 1981, the inspector observed the installation of the second set of seismic guides in the RWCU steam tunnel pipe penetration assembly, and the fitup of the RWCU guard pipe drywell wall guide assembly flange.
Per S&L Drawing No. M06-1000, Sheet 6, the clearance between all four seismic guides should be 0.010".
In actual measure-ment, it was found all four guides were bound up against the process pipe wall.
In view of the BA traveler No. RT-31-B Information Supplement No. 7.where required, " Set, Shim and weld seismic shoes, Remove shims," and the QC inspection acceptance dated l
October 8, 1980, the inspector considered the installation not in accordance with the design requirement. This is another example of lack of installation control discussed in Paragraph D.2.a(2).
(461/81-05-02)
Also in view of the fact that the QC inspection sign-off did not identify the deficient final installed condition showed that the QC inspection program was inadequate. This is another example of the noncompliance discussed in Para-graph D.2.a.(3).
(461/81-05-03)
On March 2,1981, the licensee issued a nonconformance report NCR 4151 documenting the problem including mapping of the clearance measurements. This NCR was forwarded to S&L for resolution.
In addition, the licensee agreed with the NRC
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not to proceed on any more work in this area prior to S&L resolutions and evaluation of this problem and possible similar problems on other installed seismic guides. The ten sets of seismic guides that had already welded in place and beyond any physical inspection and measurements are iden-tified as follows:
24" Main Steams lines A, B, C and D - a total of four sets.
20" Feedwater lines IFWO2KA20, and IFWO2KB20 - a total of two sets.
18" 1RH09A18 - one set.
4" 1RIO3C4 - one set.
3" Main Steam Drain Line IMS30B3 - one set.
6" RWCV line IRT01B6 - one set.
c.
Welding Control The objective of this part of the inspection.was to determine that effective welding controls were established using welding procedure specifications (WPS) and quality assurance procedures in accordance with the licensee's QA program and Code require-ments, as applicable.
The five (5) most recent audits of welding material vendors were reviewed to assure that the vendors were in compliance with 10 CFR 50, Appendix B, ASME B&PV Code Section III, and ANSI N-45.2.
These audits appeared to be adequate. The five vendors audited have valid Quality Systems Certificates issued
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by ASME.
Randomly selected purchase orders from vault records for veld filler metal were reviewed to verify receiving inspections had been performed and that weld filler metal physical and i
chemical certificates were traceable to the material specified.
l These records appeared to be adequate.
It was also noted that l
all weld filler metal is ordered as safety related.
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Review of Baldwin Associates " Welding Trends" for 1980, established that of 33,010 inches of weld deposited 740 inches of weld was
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defective or 2.2% average defect rate. The defects were found through radiography, therefore, were volumetric. Defects found l
by other NDE methods are not trended. The defect rate appears to be somewhat high based on the norm chosen by Baldwin Associates, however, not drastic. The inspector also reviewed " Piping Weld Summary," " Welder Performance Tally," and " Weld Defect Tally.
It is noted that when welders performance is sub-standard, re-qualification is required.
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The inspector, accompanied by an Illinois Power Company QA representative, observed in process welding, reviewed welding travelers, and questioned three welders, welding foreman, general fo.eman, and the welding superintendent.
It was apparent that the welders and foreman were not completely familiar with the we. ding procedure specification, welding parameters. Further review established that the WPS was not located at the activity location for the welders use, as required by 10 CFR 50 Aprendix B, Criterion IX and the ASME B&PV Code, S-74, subarticle NA-4411.
However, the welders are issued " Blue Books", a pocket size listing of the welding parameters. The " Blue Book" is not a controlled /'cument in that, revisions to the WPS are not kept current.
This item is considered to be in noncompliance with the require-ments of 10 CFR 50, Appendix B, Criterion IX.
(461/81-05-05)
Review of welding procedure specifications and procedure qualifica-tion records established that when an Argon gas flow is used only a minimum flow rate is specified with no maximum. Also noted was that a weld travel speed is not always specified. Although this is allowed by the ASME Code, it is an area of concern in that these welding parameters if not properly controlled could cause certain welding defects.
Observation There appears to be a need for more effective controls at the welding activity level and additional training of welders in the purpose and use of welding procedure specifications to assure quality welding.
d.
Control of Reportability Pursuant to 10 CFR 50.55(e)
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The objective of this part of the inspection was to verify that items reportable pursuant to 10 CFR 50.55(e) were being identified i
and reported promptly ani to establish that measures exist for reviewing NCR's, audits, surveillance reports, etc., for report-
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able items and that these measures are documented and effective l
controls practiced.
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The inspector reviewed " Nuclear Station Engineering Department" l
Procedure No. 22, Revision 2, dated January 23, 1981, " Reporting l
of Deficiencies, Defects and Noncompliances," Illinois Power i
Company's Quality Assurance Instruction 116.04, " Reporting of l
Deficiencies," Revision 0, dated October 16, 1980, Baldwin Associates BQA 140, Revision 2, dated October 30, 1980 "Noncon-l formance Review," and QA Manual, Section 13, Revision 6, dated November 7, 1978, "Nonconformances."
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l Review of these procedures and instructions established that there is no provision for documenting reviews of NCR's, audits surveil-lance, etc., for reportability persuant to the requirements of
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10 CFR 50, Paragraph 50.55(e). This appears to be contrary to the requirements for 10 CFR 50, Appendix B, Criterion XVII.
(461/81-05-06)
e.
Control of Nondestructive Examination (NDE)
The objectite of this part of the inspection was to establish that measures have been taken to effectively control nondestructive examination in accordance with Code and NRC requirements.
-The inspector reviewed qualification records of four (4) in-dividuals qualified to SNT-TC-1A, 1975, ranging from Levels I through III qualified in LP, MT, and RT.
The records appeared to be adequate and in conformance to SNT-TC-1A and U.S. Testing Procedure No. UST (PC-5)-TC-1A, Revision 0, issued January 27, 1978.
Further, the inspector reviewed several radiographs with their respective reader interpretation and technique sheets and considered them to meet requirements.
Conclusion U. S. Testing is under contract to IPC to perform nondestructive testing. The contract is under the direction of the construction-organization which can influence quality results due to cost and schedules.
It appears that the IPC QA organization should be directing and managing the contract to U.S. Testing since this is a QA/QC function.
f.
Control of Audit / Surveillance Reports The objective of this part of the inspection was to verify that measures had been established to effectively control IPC's audit /
surveillance system of subcontractors.
The inspector reviewed "IP Construction QA Surveillance Findings" (File No. S-1-A3.9.2) containing surveillance findings dated from September 9, 1977 to January 21, 1981. Comparison of the master surveillance finding log with permanent records located in the vault indicated that findings closed out in the master log did not show closed in the permanent records. The licensee indicated that there was some confusion in the routing of completed reports.
In addition, corrective action to preclude recurrence was not apparent in all cases and documentation was not available to enable verification that proper disposition of fin' dings was taken.
This item is considered to be unresolved pending resolution by the licensee and further review by the inspector.
(461/81-05-07)
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b g.
Calibration Control The objective of this part of the inspection was to verify that measures were established to effectively control the calibration of precision instruments.
The inspector randomly selected precision measuring devices, i.e.,
machinist levels, micrometers, vernier calipers, tong testers, etc., from the tool crib. All items were permanently identified-and in current calibration as indicated by the calibration sticker. The calibration recall cards agreed with the calibration dates on each instrument. Transfer standards were properly main-tained and traceable and certified to the National Bureau of Standards (NBS). Electrical measuring devices are being calibrated by an outside agency that also certifies calibration traceable to NBS.
Conclusion The calibration of measuring devices appears adequate and in conformance with codes.
h.
Planning Meeting - Civil / Structural The Region III inspector attended a meeting concerning the eleven remaining concrece placements on the C. tit I reactor building dome.
Topics discussed included concrete placement / consolidation techniques, curing methods, construction joint configuration, and forming methods. Attendees included representatives from IPC quality assurance, BA construction, BA engineering, BA quality control and a technical representative from S&L. The meeting was conducted in a business like manner and comments from each organ-ization's representative were given consideration in the final decision pro:ess.
i.
Electrical Cable Tray Field Installation The field erection of electrical cable trays was discussed in detail with the responsible BA engineer. Specific discussions concerned the use of Burndy-Husky (B-H) cable pan drawings for field installation and inspection. The B-H drawings are not stamped to document their review and' approval by S&L, the organ-ization responsible for the design review process.
Further review of the drawings and related correspondence revealed that the criginal drawings are prepared and subsequently reviewed by S&L to verify their conformance to applicable design require-ments. The cable tray design drawings are then approved and released for fabrication by S&L. The B-H drawings, used for field installation and inspection, were confirmed to be reproductions of the approved S&L design drawings. The additional information which they contain, e.g., catalog piece part numbers, miscelianeous
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erection information, contribute nothing which adversely affects their conformance to the original design requirements.
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ASTM A-36 Bolts The inspector learned of an interoffice memo dated January 14, 1981, to the manager of Quality Control from the BA Project Engineer relative to the subject matter. The memo stated, in part "You are hereby relieved of Quality Control inspection re-q.irements for such installations." Since this appeared to violate the intent of Criterion 1 of 10 CFR Part 50, Appendix B, the matter was reviewed with the principals involved. Both agreed that since the matter was a quality function the project engineer had overstepped his authority in writing the memo.
The project engineer stated that they had been unsuccessful in getting S&L to specify torque requirements for ASTM A-36 type bolts and the intent of his memo was not to interfer with QC but to bring the matter "to a head".
He added that he now realizes that this was not the proper way to handle the matter.
The QC manager confirmed the problem in getting inspection criteria established for these bolts.
He added that he was not concerned about construction directing QC inspection activities, that he does what he is told by his own management.
The use of these bolts include piping flange connection and equipment and tank anchorages.
Two Field Change Requests (FCR's) relative to this matter were located in the files. The first, No. 3477 was issued on December 27, 1979, and the second, No. 6365 was issued September 24, 1980.
The S&L response to FCR 6365 dated December 22, 1980, stated: " Snug tight the bolts, then tighten additionally by rotating 1/4 turn.
The S&L response to FCR 3477 dated January 13, 1981, stated:
Accept "BA change requested. Unless otherwise specified, flange j
bolts shall be tightened sufficiently so that no leakage is visible during hydrostatic testing or the initial service test.
l Unless otherwise-specified, anchor bolts of ASTM A-36 material
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shall be snug tight plus k turn; Anchor bolts of ASTM A-325 or A-490 shall be tightened using the AISC specification for structural joints."
l Discussions with S&L representatives indicated that, considering the application of these type bolts, they did not feel the torque l
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values or degree of tightness of these bolts was critical.
This item remains open pending further review of the application of ASTM A-36 bolts.
(Inspector followup item 81-05-08)
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k.
Review of Audits (1)
The inspector reviewed the following B=1dwin Associates (BA)
Quality Assurance Internal Audit Reports, Corrective Action Request (CAR), and Site Surveillance Reports:
(a) Internal Audit Reports 1-134 I-137
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1-150 (b) Corrective Action Requests CAR-049 (c) Site Surveillance Reports S-271 S-288 S-295 S-313 S-321 S-326 The above Audits, Requests and Surveillance Reports addressed the area of electrical raceway hanger installation.
(2) During the review of the aforementioned reports the inspector observed the following:
l (a) BA Audit Report I-134, dated January 22, 1980, identified l
five adverse findings in the areas of hanger traveler l
preparation, revision control and accountability. The I
initial response, dated February 21, 1980, to three of-the findings was considered inadequate by the licensee's Quality Assurance (QA) Department. The revised response L
was received on March 27, 1980, two months after the l
report was issued.
(b) BA Audit Report I-137, dated February 19, 1980, iden-l tified " numerous deficiencies" in the area of electrical
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hanger installation. Furthermore, the auditor stated in the report, " Based on the results of this audit, it appears the procedure for installation of electrical I
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hangers (BAP 3.3.1.) is not being followed.
If work continues without prompt corrective action, electrical hanger work Lay deterier-t-into a situation which is out of control. The corrective action taken should address detailed measures taken to prevent recurrence."
The corrective action taken, as identified by the Project Engineering response, dated March 6, 1980, did not specify corrective action for the reported " inordinate amount of time elapses between the completion of work and the trans-mission of the traveler from the field to the office.
This was observed on hundreds of travelers with varying degrees of time lapses."
(c) CAR-049, dated March 3, 1980, identified deficiencies in five areas of electrical travelers. Areas identified were:
issuance
control
revisions being used in the field
authentication (sign-offs)
processing of completed traveler An inter-office memorandum, Jated February 29, 1980, attached to CAR-049 states, in part, " Subsequent to implementation of corrective action, BA/QA will re-audit these areas and if considerable improvement is not noted, BA/QA will have no other choice but to issue a "Stop Work Order" until resolution is obtained."
(d) BA Audit Report 1-150, dated June 24, 1980, identified five adverse findings in the areas of traveler init ia-tien, revision control, performance of work without proper documentation, and fabrication signoffs.
Further-more, the auditor stated, in part, "Some of these areas were found deficient during the conduct of a previous audit (Reference Internal Audit T-134 dated January 22, 1980 and CAR-049 dated March 3, 1980). The corrective action provided in response to Audit I-134 and CAR-049 has been ineffective in preventing recurrence of the aforementioned discrepancies."
(e) Site Surveillance Report S-313, dated August 18, 1980, identified the results of a site surveillance conducted to verify implementation of corrective action responses to the five findings identified in BA Audit Report I-150.
The report indicated that contrary to the reported cor-rective action implemented for findings No. I and No. 5,
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no corrective action was implemented for finding No. I while inadequate corrective action was implemented for finding No. 5.
Verification of the corrective ac. ion response to finding No. 4 was not performed. A revised response to findings No. I and No. 5 was transmitted to QA on September 8, 1980.
(f) Site Garveillance Report S-326, dated October 29, 1980, indicated that items 1, 4, and 5 of Audit Report 1-150 were closed as a result of a " total revamp" of the electrical hanger traveler system subsequent to the licensee's report to the NRC of a deficiency involving inadequate construction controls and electrical raceway hanger installation.
The inspector informed the licensee that failure to take prompt effective corrective action to preclude repeti-tion, as indicated by the above, is contrary to the requirements of Criterion XVI of 10 CFR 50, Appendix B.
This is an item of noncompliance, as identified in Appendix A of the report transmittal letter.
(81-05-09)
(3) The inspector reviewed the Illinois Power Company (IPC)
Special QA Review of IEEE Environmental and Seismic Qual-ifications, dated September 17, 1980. The purpose of the review as stated in the review is ".
. to summarize the
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progress of equipment qualification to date and to assess the adequacy of actions taken to fulfill Illinois Power Company (IP) regulato.y commitments."
The report acknowledges BA's development of two documentation checklists to identify the required documentory evidence of conformance to procurement requirements. One checklist was developed for quality articles required by specifications while the other was for documentation required by technical articles of the specifications.
In Paragraph IV.B.1. the auditor addresses the above and states, in part, "This action permitted BA to accept items in receiving inspection as long as QC documentation was available without writing a noncon-formance report due to missing engineering documentation."
Furthermore, the auditor states in Paragraph IV.B.3., in part, " unconditionally accepting iteas with missing or in-complete documentation is in violation of IP commitments."
Attached to the subject review was a transmittal letter to IPC management from IPC QA which states, in part, "The review concludes that.....the current methods for handling class IE hardware received on site without adequate doc-umentation are not in compliance with IP commitments and I have personally reviewed this report in detail agree with major issues mentioned above, and feel that management
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needs to decisively act to resolve the' documentation problems discussed in this report."
As of February 27, 1981, corrective action taken by the licensee has not precluded the granting of unconditional acceptance status to components lacking quality documenta-tion. The electrical penetrations supplied by Conax Corporation and the 4160v Switchgear supplied by Westing-house were not given conditional accept status as required by current procures and specifications.
The inspector informed the licensee that failure to take prompt effective corrective action, as indicated by the
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above, is contrary to the requirements of Criterion XVI of 10 CFR 50, Appendix B.
This is an another example of the noncompliance, discussed under item D.2.k.(2) above.
(81-05-09)
1.
Observation of Electrical Work Activities On February 27, 1981, the inspectors observed the installation of interconnecting, safety-related, electrical cables for the Power Generation Control Complex (PGCC). During this inspection the following areas of concern were identified:
(1) Compatibility of Canon plugs with Amphenol receptacles.
(2) Sharp edges in cable routing.
(3) Cable separation and segregation requirements.
(4) Minimum bend radius requirements.
Due to time limitations resulting from commitments to the ongoing team inspection, the inspector was unable to pursue these areas of concern, however, this matter will be reviewed during a subsequent inst tion.
(81-05-10)
3.
DESIGN ACTIVITIES
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a.
Large Bore Pipe Supports and Restraints (1) Review of S&L Design Procedures The inspector reviewed some of the present day hanger design procedures at S&L office in Chicago on February 17-18, 1981, and had no adverse comment. The documents reviewed included:
(a) Design Criteria, DC-ME-16-CP, " Design Criteria for Design Verification of Structures and Components in Category 1 Buildings," Revision 0, dated October 24, 1980.
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(b) Project Instruction, PI-CP-016, " Piping Analysis, Component Support Design, and Structural Load Verifica-tion," Revision 1, dated August 25, 1980.
(c) PI-CP-010, "3ite Liaison ingineering Staff," Revision 1, dated February 3, 1981.
(d) PI-CP-003, " Process a Baldwin Associates FCR or NCR,"
Revision 7, dated July 28, 1980.
(e) General QA Procedure, GQ-3.08, " Design Calculations,"
Revision 4, dated March 5, 1979.
(f) Structural Design and Drafting Division (SDDD) Calcula-tion Procedere SD-Q10-94DG00, " Mechanical Component Support Steel Design Procedure," Revision 0, dated June 23, 1980.
(g) SD-Q10-94DG01, " Mechanical Component Support Steel Design Procedure," Revision 2, dated September 10, 1980.
(h) SD-Q10-94DG02, " Mechanical Component Support Steel Design Procedure for Control, Diesel Generator and HVAC, Auxiliary and fuel Building," Revision 1, dated September 10, 1980.
(i) SD-Q10-94DG05, " Building and Pipe Component Supports, Non-Standard Calculations," Revision 0, dated October 10, 1980.
(2) Review of S&L Stress Analysis The inspector reviewed the following stress calculations at S&L on February 17-18, 1981, and had no cdverse comment:
(a)
ISX17 Shutdown Service Water The inspector compared the stress computer runs dated July i, 1978 and December 3, 1980, and the effects of hanger combined upset loadings, and found:
Snubber M-ISX17004S, the loading was reduced from 1,944 lbs. to 980 lbs.
Variable Spring Hanger M-1SX17015V, the design load changed little, from 510 lbs. to 525 lbs.
Snubber M-ISX170163, the loading was reduced from 3,441 lbs. to 1,275 lbs.
Sway Strut M-1SX17017X, the loading was reduced from 2,465 lbs. to 1563 lbs.
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The reasons for the dynamic load reduction were at-tributed to more accurate modeling of SRV quenchers, and relocation of a rigid seismic restraint.
(b) ISX18 Shutdown Service Water
The Revision 0 of the calculation was performed on June 28, 1979.
The Revision 1, dated August 29, 1979, was made due to piping configuration changes.
The Revision 2, dated October 2, 1980, was per-formed based on revised combined response spectra for diesel and control building per SAD Calculation No. 8.18.11-0, Revision 2, dated July 29, 1980.
(3) Review of S&L Hanger Calculations The inspector reviewed calculations for some of the installed hangers observed at the site. The review was performed on February 18, 1981, at the S&L office. The findings are as follows:
(a) Snubber M-1SX17004S
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The snubber drawing, Revision A, was issued for fabrication and installation on March 26, 1979.
The verification of design loads within the hanger catalog rating was dated April 9, 1980.
No review and approval of the verification /calcula-tion.
(b) Variable Spring Hanger M-1SX17015V
The fabrication and installation drawing, Re-vision A, was issued on March 26, 1979. No hanger calculation was performed.
The fabrication and installation drawing, Re-l l
vision B, was issued on January 31, 1980. The formal hanger calculation was dated April ;0, 1980.
No review and approval of the April 10, 1980 hanger calculations.
(c) Snubber M-ISX17016S
The fabrication and installation drawing, Re-vision A, was issued an March 26, 1979. The formal hanger calculation was dated April 18, 1980.
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No review and approval of the April 18, 1980 hanger calculation. However, Revision B1 (not yet issued for construction) calculetion, dated January 22, 1981, was reviewed and approved by the authorized personnel.
Based on on-going evaluation, it was concluded by the Structural Engineer that hanger modification will be required after consideration of column buckling and self excitation loading interactions.
It was stated by S&L management that hanger self excitation loading, in terms of g factors, was not an original design criteria in hanger calculation.
(d) Sway Strut M-1SX17017X
The fabrication and installation drawing, Re-vision A, was issued on March 26, 1979. The hanger calculation was performed on March 24, 1979.
However, Revision B was issued on November 3, 1979, but formal cale,1ation was dated April 12, 1980.
Revision C was issued on September 4, 1980, in-corporating the FCR 4101, prepared by BA QC on March 6, 1980, and concurred with by S&L site representative on March 13, 1980. However, the hanger was installed to Revision B requirements during March, 1980.
No review and approval of hanger calculations.
(e) Sway Strut M-ISX1801?R
The fabrication and installation drawing, Re-vision A was issued on September 26, 1979. The hanger calculation was performed on September 10, 1979, without review and approval.
Revision B was issued on November 24, 1980. The hanger calculation was performed on November 24, 1980 with proper review, but withcut approval.
(f) Rigid Support M-1LP04003R
The fabrication and installation drawing, Re-vision A, was issued on March 23, 1978. The formal hanger calculation was dated November 8, 1978.
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(g) Sway Strut M-1LPO4030X
The fabrication and installation drawing, Re-vision A, was issued on March 3, 1977. The verification of design loads within the hanger catalo rating was dated April 11, 1980.
No review and approval of the verification /calcu-lation.
(h) Rigid Hanger M-IVG01022R
The fabrication and installation drawing Re-vision A, was issued on April 16, 1979.
The formal hanger calculation was dated June 7, 1979.
No review and approval of the hanger calculation.
(i) Rigid Hanger M-1D04004R
The fabrication and installation drawing, Re-vision A, was issued on April 16, 1979. The formal hanger calculation was dated June 8,1979, without review and approval.
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Revision B was issued on December 29, 1980. The hanger calculation (based on SDDD Procedure SD-Q10-94DG05 Revision 0) was performed on November 13, 1980.
The lack of review and approval for hanger calculations was identifieu :n an IP audit finding of S&L, No. Q35-80-3-1, dated October 22, 1980. However, the lack of design calcu-lation prior to the drawing issuance for hanger fabrication and installation was in nonconformance with S&L Procedure GQ-3.08, where it is stated that calculation shall be approved prior to the start of fabrication or start of construction of affected items. Furthermore, in review of the above records and in discussion with S&L design personnel, the lack of hanger calculation prior to issuance of construction drawings was made known to the S&L design staff in 1979 because of similar problems identified at other S&L designed facilities.
However, no management action was taken to hold those already issued drawings from fabrication and installation. This is considered an item of noncompliance with the requirements of 10 CFR 50, Appendix B, Criterion III.
(461/81-11)
Subsequent to the inspection at S&L office, S&L issued ECN 2071 on February 20, 1981, holding installation of 64 seismic restraints. S&L also prepared a summary, as of February 20, 1981, of the fabrication and installation status of snubber and seismic sway strut as follows:
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(a) Released seismic restraints - 578, among which 169 were installed. After formal load verification, it was de-termined that:
62 require major change from the original design such as FCR's and the use of different types of snubbers.
36 require minor change, such as changes of weld sizes.
229 new supports added.
251 require no modification.
(b) Supports released but on " Hold" per S&L ECN 844, dated October 11, 1978, and ECN 908, dated December 4, 1978 - 176 total.
(c) Seismic supports may have already been fabricated, but were put on " Hold" for installation per ECN 2071, dated February 20, 1981 - 64.
b.
Control Rod Drive System Supports and Restraints In accordance with S&L Contracted Specification K-2887, "Baldwin Associates (BA) and Reactor Control, Inc. (RCI) Control Rod Drive System, Clinton Power Station, Unit 1," dated November 22, 1978, RCI was contracted by BA to " design, procure, fabricate, furnish, deliver, place into storage and remove from storage, and install ready for its intended function and service." At the time of inspection, there were only two RCI personnel on site, i.e., the superintendent and the QA supervisor. The schedule for the design and installation of the CRD system was determined:
Inside and outside drywell piping analysis - February to April, 1981.
Hanger calculation - April to May, 1981.
Installation of 10" scram discharge header - April to June, 1981.
Hanger installation, outside drywell - June to August, 1981.
Hanger installation, inside the 'rywell - May to September, 1981.
d The inspector reviewed the correspondence between BA and RCI relative to BA's comments on the'recently revised RCI QA Instruc-tion Manual and the BA audits of RCI corporate office and fabrication shop; and discussed with the BA QA Management on the need for design audits at the RCI stress analysis department.
As a result of the review, the inspector concluded that there is
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insufficient site activity at the present to provide data needed for a meaningful assessment on the program adequacy and its effective impleme'ntation.
The inspector reviewed the following documents:
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(1) BA letter to RCI, dated January 28, 1981, providing comments after BA QA review of the RCI revised QA Instruction Manual, dated January 9, 1981.
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(2) RCI letter (RKC - 014) to BA, dated February 6,1981, responding to the BA QA' comments.
(3) BA External Audit Report No. E-264, BA audit of RCI, Waterford, Ct., on January 20-21, 1981.
(4) BA External Audit Report No. E-261, BA audit of RCI, San Jose, CA, on November 20, 1980.
c.
Small Bore Pipe Suspension Systems The inspector reviewed the following documents and had no adverse comment:
(1) S&L Instruction type drawing No. M09-1003N, " Component Supports Standard Details for 2" and Under Piping,"
Revision C., dated August 11, 1980.
(2) BA Job Instruction Manual Instruction P-021, "2 inch and Under Piping and Instrumentation Sensing Lines Safety-Related Component Support Drawings," Revision 1, dated May 15, 1980, and Revision 2, dated February 24, 1981.
The present design measures for the small bore pipe suspension system are considered acceptable based on the fact that all design criteria and calculation were established and performed by S&L. Three categories of small bore hangers were observed in the making, i.e., (1) details provided by the S&L office directly, (2) details prepared by BA site drafting group based on S&L established standard configurations, and (3) nonstandard hanger sketches made by BA drafting that will be analyzed and approved prior to fabrication and installation.
To the date of inspection, total number of BA hanger details isseed were approximately 844 (safety and nonsafety-related),
among which, 117 were nonstandard hangers, all of them waiting for S&L calculation and approval.
Installed safety-related small bore hangers were approximately 31.
The-inspector observed some of the installed ones in the auxiliary bailding on February 24, 1981, and had no adverse findings. The details of the installed hangers were all issued from S&L directly. No BA selected small bore pipe hanger was installed. Based on the limited installation
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work done, and the small amount of design activity since February, 1980, when the BA drafting group was put into effect, the inspector concluded that he was unable to perfcrm a meaningful assessment on program adequacy and its effective implementation at this time, d.
Personnel Qualification During inspection of the field small bore pipe support design program, the inspector questioned the personnel qualification of the BA small bore design group. The squad leader and the two checkers are classified as level four draftsmen. The other two group members are classified as level three draftsmen. The group activities were controlled by the BA Senior Piping Engineer. The inspector's question was based on IE Circular No. 80-22, " Con-firmation of Employee Qualifications," dated October 2,1980.
Whereas the IEC addressed only the designers / engineers, in fact some of the high level draftsmen are performing equivalent functions as designers. Subsequent to the discussion of the NRC requirements, the BA Resident Engineer issued a memorandum (JEF-97-81, dated February 17, 1981) to the BA Senior Piping Engineer, and the BA Personnel Manager to prepare job descriptions for personnel assigned to Piping Drafting Department, and to verify the employee resumes.
In addition, the IP and BA Manage-ment had committed to further evaluate present employment policy which should consist of:
(1) establishment of basic personnel qualifications based on job authorities and duties, and (2)
confirmation of employee education and career experience based on the personnel qualification requirements. This item will be reviewed in more detail during a future site inspection, and is presently considered an unresolved matter.
(461/81-05-12)
Field Change Requests (FCR's)/ Engineering Change Notices (ECN's)
e.
During observation of hanger and steam tunnel pipe penetration assembly installations, the inspector reviewed two of the FCR's which is a site generated request for design change and the use of ECN's which is an A-E issued notice for any design change prior to formal revisions of drawings or specifications. The specific problems encountered were as follows:
(1) FCR 5856, issued by BA QC on August 9, 1980, and concurred
j with by S&L site Engineer on August 1, 1980.
The FCR identified, during hanger installation, that there was no tolerance specified for component support " pin-to-pin" dimension, and suggested 1/2" linear tolerance be allowed.
IP
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Engineering rejected the BA request on August 21, 1980, and allowed 3-1/2" pin-to pin dimension tolerance for snubbers and
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sway struts, and was concurred with by S&L Site Engineer. The inspector considered the FCR 5856 in nonconformance with S&L PI-CP-010, " Site Liaison Engineering Staff" where the Site j
Engineering was not given the authority to approve any i
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generic engineering changes such as the allowable instal-lation tolerance. Furthermore, the suggested S&L instruc-tion type Drawing M09-1001, Sheet 2, was not revised to reflect the change including specific requirements on how to handle non-adjustable snubber assembly. The 3-1/2" tolerance was allowed by the hanger manufacturer (BE) on the snubber assembly with adjustable extension strut unit.
The issue involved is that, the inspector believes that the issuance of any generic design changes should be a function of the A-E and that an ECN should be utilized to provide con-trol measures commensurate with the original design considera-tions including preparation, review, and approval steps prior to sending it to the site for implementation. The licensee management disagreed with the inspector and maintained the position that IP engineering can issue generia design changes through FCR's provided the FCR receives concurrence from the S&L site representative and that the site representative has discussed the subject matters with the S&L home office design staff. The BA Project Procedure BAP 1.2, " Field Change Request," Revision 5, dated July 29, 1980, does not preclude such operation. However, during the management meeting held in IE:RIII or March 12, 1981, IP management stated that:
(1) the FCR form is being revised to record the contact made between the field engineer and the home office engineer within the S&L organization, (2) procedures will be modified to prohibit field implementation of generic changes based on FCR's.
This is an unresolved item pending further review.
(461/81-05-13)
(2) FCR 6754, issued by BA Field Engineer and concurred with by S&L Site Engineer on January 14, 1981.
THe FCR identified floor space interference during installa-tion fitup of the drywell wall guard pipe penetration guide l
i flange. The recommended trimming of the flange to clear the l
floor surface was carried out after signed concurrence from the IP Construction Supervisor on the FCR on November 5, 1980, but prior to concurrence from the S&L engineering. Such
operation was in accordance with BAP 1.2, " Field Change Request," Revision 5, dated July 29, 1980.
I The issue involved is that, the inspector believes that design changes involving modification of fabricated hard-ware, installation locations, and component cor_igurations and orientations should be directed by the A-E, through an
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l ECN cr the A-E's approval of a FCR.
It is inappropriate for the licensee / constructor to request change and approve its own change request. The inspector was fully aware of the fact that final review of the FCK by the A-E could cause modification or deletion of what was already modified how-ever, the principle remains that construction, including r
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modification thereafter, should have the engineering basis firmly established to ensure adequacy and safety prior im-plementation to of the work but not after the fact which could result in a reduction in safety margin or in compromis-ing the design intent. During the management meeting held in IE:RIII, the subject matter was further discussed and the licensee management stated the FCR procedure will be revised to emphasize the need for further consideration and com-munication with the A-E when dealing with a situation where design safety margin could be reduced as a result of the FCR issuance. This is an unresolved item.
(461/81-05-14)
f.
Review of ECN's, FCR's, and PCR's Documentation which provides the vehicle to initiate changes, in established design and inspection criteria was reviewad. The review focused on engineering change notices (ECN), field change requests (FCR), ar.d procedure change requests (PCR). The following observatious were made:
(1) Thirteen ECN's issued to the concrete and nuclear coating specifications (K-2944 and K-2895; respectively) were examined.
The Region III inspector verified that the ECN's were received and distributed in accordance with BAP 2.0, Document Control.
Additionally, the engineering basis for the design change invoked by each ECN was reviewed to determine its validity.
(2) Twenty-four FCR's issued to the concrete cod nuclear coating specifications (K-2944 and K-2895, respectively) were examined.
The Region III inspector verified that the FCR's were initiated and processed in accordance with BAP 1.2, Field Change Request.
The engineering basis for the design change invoked by each FCR was reviewed to determine its validity.
(3) Nineteen PCR's, issued to BAP 3.1.1. Concrete, were reviewed.
The PCR system provides the means of requesting a change to an approved procedure. Each PCR was reviewed to confirm that it had been approved by the proper personnel and that the approved changes were not contrary to quality.
No items of noncompliance were identified in these reviews.
g.
Review of "As Built" Electrical Raceway Hanger Program The inspector reviewed the licensee's program for the generation of electrical hanger drawings which identify the "As Built" in-stallation of electrical hangers. These hangers were installed prior to the licensee's notification to the Nuclear Regulatory Commission (NRC) of a reportable deficiency in the area of electrical raceway installation. The licensee initiated the program to assure that raceway hangers installed under controls in place prior to the notification complied with approved design requirements. The "As Built" drawings are prepared by Illinois
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Power Company (IPC) engineers, approved by Baldwin Associates (BA),
and transmitted to Sargent and Lundy (S&L) Architect Engineer, for review. Approximately 2070 electrical hangers are involved in this process.
(1) The inspector reviewed the following eight "As Built" hanger drawings:
E30-1000-03B-H11, Revision 00 E30-1000-03B-H12, Revision 00 E30-1000-03B-H14, Revision 00 E30-1000-06B-A8, Revision 00 E30-1000-06B-A12. Revision 00 E30-1001-04A-A22, Revision 00
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E30-1001-04A-A23, Revision 00 E30-1003-01B-A6, Revision 00 (2) During this review the inspector observed apparent errors in the dimensions recorded on severs 1 of the above "As Built" drawings prepared by IPC Engineering and reviewed by S&L.
(a) The plate dimensions on Drawing E30-1001-04A-A23 were identified as 3/8" x 8" x 9" on the hanger detail and 1/2" x 8" x 9" on the Bill of Materials. Since two dimensions were given for the same plate, the actual "As Built" plate dimension was indeterminate. Furthermore, the drawing had been reviewed by S&L and identified as status one by which S&L states, "No exception taken.
Contractor may proceed with fabrication or construc-tion in accordance with specification." The inspector accompanied the licensee in remeasuring the plate dimensions and determined the actual plate dimensions to be 1/2" x 8" x 9".
(b) The plate dimensions on drawing E30-1001-04A-A22 were identified as 3/8" x 8" x " on the hanger detail (the last dimension had not been entered on the drawing) and as 1/2" x 8" x 9" on the Bill of Materials. Further-more, the drawing had been reviewed by S&L and iden-tified as status one.
The inspector accompanied the licensee in remeasuring the plate dimensions and determined the actual plate dimensions to be 1/2" x 8" x 9".
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(c) The plate dimensions on drawing E30-1003-01B-A6 were identified as 3/8" x 8" x 9" on the hanger detail and 3/8" x 9" x 8" on the Bill of Materials. The actual orientation of the plate dimensions could not be deter-mined. Furthermore, the inspector observed that the drawing had been reviewed by S&L and identified as status one.
(d) The specified S&L detail which corresponds with BA detail one is identified as detail.DV-1 on Drawing E30-1000-03B-H14. The installed detail is identified as DV-17.
The referenced S&L base design detail drawing is E05-1908, Revision J.
This revision does not allow the use of detail DV-11 as an alternate to detail DV-1.
The use of detail DV-17 had been approved by S&L without changing the referenced base detail design drawing.
(e) The specititJ S&L detail which corresponds with BA detail two is identified as detail DV-1 on Drawings E30-1000-03B-H11 and E30-1000-03B-H12. The installed detail is identified as DV-17.
The referenced S&L base design detail drawing is identified as E05-1908, Re-vision J.
This revision does not allow the use of detail DV-17 as an alternate to detail DV-1.
The use of detail DV-17 had been approved by S&L without changing the referenced base detail design drawing.
(f) The inspector reviewed approximately 50 other "As Built" drawings and observed conflicting dimensions on Drawings E26-1000-02B-A10, Revision 00, E30-1000-01A-A2, Re-vision 00, E30-1000-03B-A1, Revision 00.
Each of these drawings had been reviewed and approved by S&L.
The inspector questioned the licensee concerning the errors in the "As Built" drawings and the review process used by S&L for these drawings. The inspector was informed that the drawings identified in Paragraphs 2(a) and 2(b) above were l
incorrectly identified by S&L as status one.
Furthermore, the lirensee rtated that a program had not been established te -ssure that approved "As Built" design parameters would be implemented into the base design documents.
(3) The inspector questior.ed the licensee concerning the involve-ment of the Quality Assurance (QA) organization in the "As Built" electrical hanger program. QA should have assured that the following prerequisites had been satisfied:
(a) An approved IPC procedure which Jelineates the responsi-l bilities of the preparer, reviewer, and approver of the I
"As Built" drawings.
(b) An approved S&L procedure providing specific guidelines l
for the review of IPC generated "As Built" drawings.
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The licensee informed the inspector that the above pre-requisites had net been satisfied.
The inspector determined that the licensee failed-to establish which Quality Assurance organization would have functional control over the "as Built" hanger program. As a result, the licensee failed to provide quality controls over the prepara-tion, review, and approval of "As Built" electrical hanger drawings prepared by IPC engineers.
The inspector informed the licensee that the above (i.e.,
item D.3.g) is contrary to the requirements of 10 CFR 50, Appendix B, Criterion II and is an item of noncompliance, as identified in Appendix A of the report trar,smittal letter.
(81-05-15)
On February 20, 1981, as a result of the inspection findings, the licensee suspended work on the preparation and review of
"As Built" hanger drawings pending the development of pro-cedures to control the preparation and review of these draw-ings and the review of those drawings previously reviewed by S&L. The NRC's understanding of the action to be taken by the licensee in regard to this matter was documented in an Immediate Action Letter, from the Region III office, dated February 18, 1981.
h.
Document Control The inspector reviewed 20 Sargent and Lundy (S&L) electrical hanger drawings to determine if all outstanding engineering change notices (ECN's) Field Change Requests (FCR's), and Nonconformance Reports (NCR's) were identified on these documents.
Furthermore, the in-spector reviewed the drawings to determine whether current
revisions to these documents were being distributed and used as required.
(1) The following S&L drawings reviewed by the inspector were located in the field engineering office at the 781 foot elevation of the control building:
i E30-1003-01A-CPH Revision E i
E30-1003-02A-CPH Revision C E30-1003-04A-CPH Revision C E30-1003-040-CPH Revision B E30-1400-CPH Revision B
E30-1402-CPH Revision D
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E30-1403-CPH Revision C E30-1451-CPH Revision C E30-1452-CPH Revision A E30-1453-CPH-Revision C (2) _The following S&L drawings reviewed by the inspector were located in the Quality Control field office at the 762 foot elevation of the control building:
E28-1000-08A-CPH Revision E E28-1001-01A-EIT Revision C E28-1001-02A-CPH Revision B E28-1001-02A-E1H Revision B E28-1001-03A-E1H Revision C E28-1001-05A-CPH Revision B E28-1001-06A-E1H Revision E E28-1001-06A-EIT Revision D E28-1001-07A-E1H Revision D E30-1451-CPH Revision C (3) During the review of the above drawings the inspector observed the following:
(a) FCR 6385, issued January 14, 1981, which the master file in Document Control identified as a change affecting Drawing E30-1003-02A-CPH, Revision C, was not listed on the field copy of that drawing as of February 24, 1981.
(b) FCR 7452, issued January 30, 1981, which the master
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file in Document Control identified as a change
affecting Drawing E30-1451-CPH, Revision C, was nct listed on the field copy of that drawing.s of February 24, 1981.
(c) FCR 7530, issued February 2, 1981, which the master file in Document Control identified as a change affecting Drawing E30-1451-CPH, Revision C, was not listed on the field copy of that drawing as of February 24, 1981.
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(d) FCR 7455, issued February 2, 1981, which the master file in Document Control identified as a change affecting Drawing E28-1001-06A-E17, Revision D, was not listed on the field copy of that drawing as of February 24, 1981.
l (e) Revision C to Drawing E28-1001-05A-CPH was issued February 17, 1981. Revision B to that drawing aas being used in the field as of February 26, 1981.
(f) FCR 7455, issued February 2, 1981, which the master-
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file in Document Control identified as a change affecting Drawing E28-1001-06A-E1H, Revision E, was not listed on the field copy of that drawing as of February 24, 1981.
(g) Revision E to Drawing E28-1001-07A-E1H was issued February 6, 1981. Revision D to that drawing was being used in the field as of February 24, 1981.
The inspector informed the licensee that failure to identify and use changes to documents affecting quality and the failure to distribute and use current revisions to documents affecting quality was contrary to the requirements of 10 CFR 50, Appendix B, Criterion VI and is an item of non-compliance, as identified in Appendix A of the the report transmittal letter.
(81-05-16)
d.
The inspector observed that ECN 1869 had been crossed out on the field copy of Drawing E28-1001-03A-E1H, Revision C, but was identi-fied in the master file in Document Control as an outstanding change affecting this drawing. Document Control personnel in-formed the inspector that the ECN was incorporated in Revision C to the above drawing and should have been removed from the master file. The inspector verified that Revision C incorporated ECN 1869, as stated.
- 4.
PROCUREMENT ACTIVITIES
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a.
Commercial Grade Items This portion of the inspection consisted of a review of procure-ment practices at the Clinton Site. Particularly of concern was the procurement of material, under non-safety designated purchas; orders, which ultimately is to be used in safety-related applica-tions. This type of item is referred to as a " commercial grade item."
The majority of effort was focused on the procurement of cable tray, cable tray supports, and cable tray accessories. The followind guidance presently exist concerning commercial grade items.
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e (1)
10 CFR 21.3(a-1) in part defines commercial grade items as an item to be ordered from the manufacturer / supplier on the basis of specifications set forth in the manufacturer's published product description (e.g., Catalog).
(2)
10 CFR 21.3 in part defines " basic component" as a plant structure system, component or part thereof necessary to assure the capability to shut dov,the reactor and maintain it in a safe shut down condition.
(3)
10 CFR 21.3(e-1) states that " dedication" of a commercial grade item occurs after receipt when that item is designated for use as a basic component.
(4)
10 CFR 21.3(d) states that a commercial grade item is not part of a basic component until after dedication.
IP presently procures prefabricated cable tray, supports, and ac-
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cessories from Husky Products, Inc. As a minimum, each shipment is accompanied by a certificate of compliance stating that the material conforms to the industry grade standard specified by the design. Husky material is procurred through safety related purchase orders to meet the requirements of Specification K-2980.
The licensee stated during this inspection that an audit of Husky Products is planned in order to establish the validity of the certificates received with the material.
IP also purchases cable tray support accessories from Super Strut.
This material is procured as commercial grade tnrough a nonsafety purchase order. Each shipment is accompanied by a certificate of compliance stating that the material conforms to the industry grade standard specified by Specification K-2999.
Super Strut material is identical to and used in the same safety applications as Husky Products, Inc. material.
Because of its commercial grade status, there is no means available to verify the validity of the certifi-cates received with the material.
There appears to be a lack of continuity within the IP procurement program. This is evidenced by the different quality requirements imposed on two man 2facturers (Husky and Super Strut) supplying
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l identical material to be used in identical safety applications.
This concern has been the subject of considerable debate within the IPC organizetion as evidenced by numerous letters and audits.
It should be noted that this problem concerning the necessary quality requirements for commercial grade items applys to other construction sites. Also, the commercial grade debate is not limited only to cable tray support accessories.
It is therefore apparent that more definitive guidance is required to clearly specify to what extent quality requirements should be applied to commercial grade material utilized in safety related
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applications.
It is Region III's intent to work with the respon-sible NRC headquarter and licensee staff to satisfactorily address this issue.
(461/81-05-17)
b.
Review of Procurement Documentation - Class IE Equipment The inspector reviewed procurement documentation relative to low voltage electrical penetration IEE21E, radium voltage elec-trical penetration IEE01E, and 4160 volt electrical switchgear IAP07E.
The inspector reviewed purchase specifications, Receiving Inspection Reports, vendor documentation, vendor surveillance reports, and nonconformance reports, and observed
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the following:
(1) The inspector observed that the quality documentation for Conax Corporation electrical penetrations was incomplete at the time of shipment of the penetrations from Conax to the licensee. Furthermore, a Certificate of Conformance (COC)
for each penetration was included in the. document packages.
The inspector requested the licensee to produce the letter authorizing the above shipment and the use of'a C0C in lieu of complete quality documentation. The licensee informed the inspector that a written authorization had not been developed. This condition is cont cary to the requirements of Paragraph 112.11 and 112.11a of Sargent and Lundy (S&L)
Specification K-2978 which states, "In special cases, where all of the documentation may not be available at the time
.the equipment is ready for shipment, shipment to the site will be permitted under the following conditions: Upon written approval of the Purchaser, a Certificate of Com-pliance shall be transmitted with the shipment. Approval for use of a Certificate of Compliance shall be obtained prior to shipment." Furthermore, Paragraph 5.2.3 of Baldwin Associates Procedure (BAP) 2.20 states, in part,
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"In cases where complete vendor quality documentation is unavailable at the time of shipment, the Manager of Quality Control may authorize a vendor to submit an authorized in-
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terim letter of compliance conforming to the requirements of the project specifications. The authorization shall be in letter form signed by the Manager of Quality Control and...shall form a part of the procurement documents."
The inspector informed the licensee that the above was an example of failure to follow procedures, an item of non-compliance, contrary to the requirements of Criterion V of 10 CFR 50, Appendix B.
(81-05-18)
(2) The inspector reviewed the Receiving Inspection Reports (RIR)'for the aforementioned electrical penetrations and 4160 volt switchgear 1AP07E. The inspector observed that a C0C had been included in the documentation package for the 4160 volt switchgear in lieu of complete quality doc-umentation.
(As previously stated, this condition was
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also noted for the electrical penetrations). The RIR's, Form JV-152, identifies the following five dispositions for received items:
A= conforms H= hold C= conditional accept S= accept storage only R= returned or scrapped The inspector observed that the final disposition for the above components was identified on the RIR's as
"A".
This disposition is defined by Paragraph 3.2.b of BAP 2.3 which.
states in part, " Documentation, as applicable, received and conforms to specification requirements."
This condition is contrary to the requirements of Para-graph 5.2.4 of BAP 2.20 shich states, in part, "Upon receipt of the authorized interim letter of compliance, items shall be placed on " Conditional Accept" status in accordance with BAP 2.3 for documentation requirements."
The inspector informed the licensee that the above was an another example of failure to follow procedures, an item of noncompliance, contrary to the requirements of Criterion V of 10 CFR 50, Appendix B.
(81-05-18)
(3) The inspector reviewed the Items / Materials Returned Report,
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dated April 13, 1980, which documented the return of the 7/8" diameter Primary Header Plate bolts for electrical penetration IEE21E to Conax Corporation for rethreading.
1his report referenced.'iCR 3474, dated July 21, 1980, which identified the inadequate thread length of the aforementioned bolts. During this review, the inspector observed that the original RIR (S-11630, dated September 29, 1980) was not revised to reflect the return nor was the subsequent receipt of the rethreaded bolts traceable to a specific RIR document-Iag their receipt and reinspection upon arrival from Conax Corporation. This condition is contra *y to the requirements of Paragraphs 6.9.1.3 and 6.9.1.3(c) of BAP 2.3 which states,
"When the material being returned has been inspected by Quality Control or a Quality Control RIR has been issued to cover the material, Quality Control shall:
revise documenta-tion related to the receipt of the items / materials, e.g.,
RIR, logs, etc., to reflect the return."
The inspector informed the licensee that the above was an another example of failure to follow procedures, an item of
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W noncompliance contrary to the requirements of Criterion V of 10 CFR 50, Appendix B.
(81-05-18)
(4) The inspector reviewed the licensee's method of acceptance of the electrical penetrations supplied by Conax Corporation.
Approximately forty electrical penetrations have been received and installed at Clinton Power Station. During this review the inspector observed the following:
(a) Paragraph 112.11 of Sargent and Lundy (S&L) Specifica-tion K-2978 states, in part, "In special cases, where all of the documentation may not be available at the tirae the equipment is ready for shipment, shipment to the site will be permitted under the following condi-tions: Upon written approval of the purchaser, a Certificate of Compliance shall be transmitted with the shipment.
.......The certification shall also identify any nonconfermances or procurement requirements that have not been met."
At the time of shipment of the Conax electrical penetrations, the documentation was_ incomplete.
En-vironmental testing for these penet rations is scheduled for completion in June of 1981. Conax supplied a Certificate of Conformance in lieu of the missing doc-umentation (e.g. seismic, environmental, and prototype test reports). These test reports are a part of the procurement requiremente of S&L Specification K-2978.
The Certificates of Conformance (C of C) supplied by Conax Corporation do not identify the procurement requirements that had not been met at time of shipment as required.
In fact the C of C for penetration IEE2IE, dated February 22, 1979, states, in part, "The materials, processes and equipment furnished on this Purchase Order were produced in conformance with all contractually applicable specifications."
(b) Paragraph 112.9 of Sargent and Lundy Specification K-2978 identified quality documentition requirements for the electrical penetrations. Among the documents required are the Certified Material Test Report and the following qualification reports:
Seismic.
Environmental.
Prototype.
Production test reports.
St ess reports.
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The licensee has chosen to divide the documentation identified in Paragraph 112.9 into two discrete areas,
. quality and engineering. The licensee has developed a
" Documentation Checklist" to identify what the licensee considers to be quality articles of the specifications and codes and an " Engineering Checklist" to identify the technical portions of the specifications and codes.
Both of these checklists are prepared by Baldwin Quality Assurance personnel.
(c) The Quality Control Receiving Inspection Report for the electrical penetrations identifies that:
(i) Documentation conforms.
(ii) Documentation accepted per interoffice memo which states "all documentation received and found satis-factory."
Based on the above, the inspector requested the licensee is supply the engineering checklist for the Conax pen-etrations or a checklist which would identify all completed or outstanding seismic, environmental, proto-type, or production testing required to establish the qualification of the electrical penetrations. The licensee informed the inspector that this checklist had not been developed for the electrical penetration.
Furthermore, the licensee informed the inspector that the documentation referenced in (c)(i) and (c)(ii) above refer solely to quality documentation sad that the quality documentation requirements for receipt inspec-tion and installation are defined on the documentation checklist.
(d) Paragraph 17.1.7.1. of the Clinton Power Station Pre-liminary Safety Analysis Report (PSAR) states, in part, r
" Contractors, subcontractors, and vendors shall be required to provide documentary evidence of product conformance to procurement requirements. This docu-mentary evidence shall be present at the site prior to t
installation of equipment or use of material."
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(e) To clarify the licensee's method of acceptance of components or equipment licensee representatives met and discussed their program with Region III representa-tives on March 12, 1981.
This matter is considered unresolved pending receipt and eraluation of the licensee's response to the items listed in Appendix B to the letter transmitting.this report.
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(5) The inspector observed that the following tendor documentation required by the electrical penetration documentation checklist (Form JV-146) was not on site:
(a) Weld Material Certification (b)
Impact Test (c) NDE Test Certification Furthermore, the inspector observed that the licensee had previously verified that all documentation on the checklist had been received an? reviewed.
The licensee informed the inspector that the above documents were not required for the Conax penetrations and should not have been included on the checklist. Furthermore, the licensee stated that the requirement for these documents would be remove' from the documentation checklist.
The inspector contacted Conax Corporation and confirmed the licensee's position. The inspector will verify the removal of the documents from the documentation checklist during a subsequent inspection.
(81-05-20)
(6) The inspector observed Vendor Surveillance Report No.
C-14181.4, dated February 28, 1979. The report indicated the Baldwin Associates inspector witnessed the Dielectric Strength Test, Insulation Resistance Test for Conax Corpora-tion electrical penetration IEE21E. The report indicated
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I areas tested, results of tests, and acceptability. Further-r more, the report identified the following areas in which Conax Corporation appeared to be deficient:
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I (a)
controlled access (b)
control of items in storage (c) measures not taken to prevent storage of food (d) entrance by unauthorized personnel (e) restriction to ANSI 45.2.2 - 1972 not identified l
The inspector observed report No. C-14181.5, dated June 25, l
1979, which stated that the above deficiencies had been
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corrected.
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5.
UNRESOLVED ITEMS Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of
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i noncompliace, or deviations. Unresolved items disclosed during this
inspection are discussed in Paragraphs D.2.f; D.2.j; D.2.1; D.3.d;
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D.3.e(1); D.3.e(2); D.4.a; D.4.b(4); D.4.b(5).
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