ML19210E695
| ML19210E695 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 10/23/1979 |
| From: | Maxwell G, Suermann J, Williams C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19210E691 | List: |
| References | |
| 50-454-79-14, 50-455-79-14, NUDOCS 7912050554 | |
| Download: ML19210E695 (23) | |
See also: IR 05000454/1979014
Text
.
.
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-454/79-14; 50-455/79-14
s
Docket No. 50-454; 50-455
License No. CPPR-130; CPPR-131
Licensee-
Commonwealth Edison Company
Post Office Box 767
Chicago, IL 60690
Facility Name:
Byron Nuclear Generating Station, Units 1 and 2
Inspection At:
Byron Site, Lyron, IL, and CECO Corporate Office
Inspection Conducted: September 11-28, 1979
/' f /'Y.'~~
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ft/f'//77'
Inspectors:
J. E. Konklin
-<
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J. Y
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G. F. Maxwel
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J. F. Suermann, (September 18-28 only)
/o /.2 J/29
Accompanying Personnel:
C. C. Williams (September 28 Exit Meeting only)
D. W. Hayes (September 28 Exit Meeting only)
J. H. Neisler (September 28 Exit Meeting only)
( ?c'] % /cb <. -
Approved By:
C. C. Williams, Chief
/ C/ 2 3/ 7 e
Projects Section 2
/
/
/
Inspection Summary
Inspection on September 11-28, 1979 (Report No. 50-454/79-14; 50-455/79-14)
Areas Inspected. Content and implementation of the licensee's Quality
Assurance Program in the following areas:
1.
Site quality assurance, including auditing, trending, and surveillance
activities, and the control of noncomformances.
2.
Corporate quality assurance, including auditing, trending, and interfaces.
3.
Design and design changes, including design document control, and incor-
poration of engineering changes. 1502
302
7 912 050 $$ y
.
'
4.
Procurement, including procedures, purchasing activities, and auditing
of materials suppliers.
5.
Control of purchased materials, including procedures, receipt inspec-
tion, otorage and maintenance, and surveillance of site contractors.
The inspection involved a total of 172 inspector-hours onsite or at the
CECO Corporate Office by three NRC inspectors.
s
Results: Of the five areas inspected, two items of noncompliance were
identified in two areas (infraction - inadequate procedures and failure to
follow procedures with regard to qualification of personnel, three examples
- Section I, Paragraph 1.b. and Section III, Paragraph 2; deficiency -
inadequate document control, two examples - Section I, Paragraph 2 and
Section II, Paragraph 4.b.).
1502
303
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'
DETAILS
Persons Contacted
Byron Site
Principal Licensee Employees
,
- G. Sorensen, Project Superintendent
+*J. McIntire, Site QA Supervisor
- R. Tuetkin, Lead Mechanical Engineer
- J.
Mihovilovich, Lead Structural Engineer
- G.
Smith, Lead Electrical Engineer
J. Porter, QA Mechanical Coordinator
- S.
Forsha, QA Structural Coordinator
AR. Aken, QA Electrical Coordinator
- R. Klingler, QA Mechanical Engineer
K. Key, Site Purchasing Coordinator
- J. Klink, QA Engineer
M. Stanish, QA Engineer
L. Combs, QA Engineer
Huriter Corporation
kM. Somsag, QA/QC Supervisor
H. Lindquist, Material Control Supervisor
M. Zeisk, Lead Auditor
A. Simon, QA Administrator
R. Irish, QA Training Coordinator
Blount Brothers Construction
- R. A. Donica, QA/QC Supervisor
T. Calsyn, Receipt Inspector
Hatfield Electric
- G. Van Lyssel, Construction Manager
- W. Gratza, QA danager
R. K. Donica, QC Inspector
CECO Corporate Office
1502
f.04
Licensee
+ W. Shewski, QA Manager
+*G.
Marcus, QA Director
J. Rohde, SNED QC Supervisor
-3-
J. Westermeir, ShTD Project Engineer
'
R. Janacek, Licensing Administrator
J. Iglehart, Office Supervisor, Purchasing
M. Zolfo, Ascociate Purchasing Agent
J. Harper, Assistant Purchasing Agent
J. Brynildsen, ShTD Engineer
Sargent & Lundy
,
.J.
Lavalle, Project Manager
R. Rakowski, Mechanical Engineer
USNRC-RIII (Exit Meeting Only )
+ C. Williams, Chief, Projects Section 2
+ D. Hayes, Chief, Engineering Support Section 1
+ J. Neisler, La Salle Project Inspector
The inspectors also contacted other licensee and contractor personnel,
including craftsmen, QA/QC, technical and engineering staff members.
- Denotes those attending the interim exit meeting at the Byron Site on
September 20, 1979.
+ Denotes those attending the final exit meeting at the RIII offices on
September 28, 1979.
Functional or Program Areas Inspected
Functional or program areas inspected are discussed in Sections I, II, and
III of this report.
1502
305
-4-
Section I
Prepared by J. E. Konklin
Reviewed by C. C. Williams, Chief
Projects Section 2
,
is
Procurement and Control of Equipment and Materials
The RIII inspector reviewed documentation and inspected activities
relating to the procurement and control of safety-related equipment
and materials by CECO and by three major site contractors, including
procedures, requisitions, purchase orders, receipt ir.spection reports,
vendor documentation packages, surveillance activities and reports,
audit reports, and storage and maintenance activities. The three
site contractors selected for the review included Hunter Corporation
(Hunter), the site contru9 tor responsible for safety-related piping
and mechanical component installation; Blount Brothers Corporation
(Blount), the site contractor responsible for safety-related structural
concrete work; and Hatfield Electric Corporation (Hatfield), the
site contractor responsible for safety-related electrical construction
activities.
a.
Review of Related Procedures
The inspector reviewed the following CECO general procedures
related to purchasing activities:
(1) Ceneral Procedure No. 702, effective September 6, 1969,
" Purchase Orders."
(2) General Procedure No. 703, effective November 28, 1977,
" Changes in Purchase Requisitions and Purchase Orders."
(3) General Procedure No. 701, effective September 15, 1977,
" Purchase Requisitions."
(4) General Procedure No. 704, effective July 28, 1969,
" Shipment Release".
In addition, the inspector reviewed the following CECO Quality
Assurance Procedures (QP's) related to purchasing activities:
(1) QP No. 4-1, Revision 6, dated October 28, 1977, " Request
for Bid, Proposal Evaluation and Recommendation."
1502
306
-5-
.
(2) QP No. 4-2, Revision 6, dated January 12, 1979, " Evaluation
of Contractor's Quality Assurance Program."
The inspector reviewed the following site contractor procedures
related to the purchasing, receipt and control of procured
materials:
(1) Hunter Procedure SIP 3.602, Revision 2, dated April 28,
'
1978,
-
" Material Receiving and Inspection."
(2) Hunter Procedure SIP 3.102, Revision 1, dated February 9,
1978,
" Material and Services Procurement."
(3) Hunter Procedure SIP 3.801, Revision 2, dated July 31,
1979,
" Storage of Mechanical Components and Materials."
(4) Blount QA/QC Work Procedure No. 2, Issue 8, Revision 7,
dated September 13, 1977, " Procurement Control."
(5) Blount QA/QC Work Procedure No. 10, Issue 4, Revision 3,
dated October 18, 1976, " Receiving, Storage, and Handling."
(6) Hatfield Site Procedure No. 5, Revision 1, dated July 7,
1977, " Class I Material and Equipment Receiving and
Inspection."
(7) Hatfield Site Procedure No. 6, Revision 1, dated July 28,
1977, " Reporting Damaged and Nonconforming Material and
Equipment."
(8) Hatfield Site Pro.edure No. 14, Revision 2, dated October 2,
1978, " Handling and Storage of Safety Related Material and
Equipment."
b.
On-Site Review of Procurement Documentation
The inspector randomly selected, from the Site Purchasing
files, five purchase orders for safety-related equipment and
materials utilized or installed by Hunter Corporation, three
purchase orders for safety-related equipment and materials
utilized or installed by Blount, and tbree pure. nase orders for
safety-related equipment and materials utilized or installed by
Hatfield. The inspector reviewed the purchase orders and the
associated Material Services Requisitions (MSL's) for comnlete-
ness, consistency, appropriate requirements, and appropriate
signoffs per procedures. The inspector also verified that the
1502
307
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selected vendors vere listed on the CECO Approved Bidders Liss
for the specific equipment or material procured.
The inspector noted one discrepancy in reviewing the selected
purchase o ders and MSR's - the CECO QA signoff was missing on
one purchase order; however, CECO QA had approved the associated
MSR which had identical requirements. The inspector then
checked approximately 20 additional purchase orders to verify
,
QA signoff and concluded that the lack of a signoff on the one
.
purchase order was an isolated occurrence and was not indicative
of a problem.
The inspector then reviewed the Material Receiving Reports
(MRR's) and the vendor documentation packages associated with
the selected purchase orders, and verified the warehouse storage
locations and maintenance conditions for the equipment purchased
and delivered under two of the purchase orders. The MRR's were
reviewed for completeness and appropriate signoffs, and the
vendor documentation packages were reviewed for tonformance
with the purchase order requirements.
During review of the MRR's, the inspector noted that the Receipt
Inspection Checklists for equipment and materials purchased by
the CECO General Office were completed and signed as " Inspected
By" CECO Station Construction field engineers and construction
supervisors, aone of whom had been qualified or certified in
accordance with ANSI N45.2.6, " Qualifications of Inspection,
Examination, and Testing Personnel for the Construction Phase
of Nuclear Power flants." CECO is committed to comply with t'e
requirements of Regulatory Guide 1.58/ ANSI N45.2.6 in CECO
Topical Report CE-1-A and in the CECO Quality Assurance Manual,
Quality Requirement QR No. 2.0, Revision 10, dated April 2,
1979. The inspector notified the licensee that this failure to
,
qualify / certify personnel performing inspection activities to
the requirements of ANSI N45.2.6 is an item of noncompliance
with Criterion V of 10 CFR 50, Appendix B (50-454/79-14-01;
50-455/79-14-01). Two additional examples of failure to comply
with Criterion V with regard to qualification of inspection
personnel are discussed in Paragraph 2 of Section III of this
report, and are included under the above item of noncompliance.
2.
Review of CECO Site Engineering Surveillance
The inspector reviewed the curveillance of site cor. tractors by CECO
Station Construction personnel, including the surveillance schedules
and the surveillance check sheets from January 31, 1977 to September 3,
1979 in the mechanical area, from February 1, 1977 to September 10,
1979 in the structural area, and from January 31, 1977 to September 10,
1979 in the electrical area. The inspector found approximately 35
1502
08
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check sheets which were
.t signed off by CECO QA as required by
Sections 3.3 and 4.2 of CECO Quality Procedure QP No. 18-2, Revision
5, dated October 28, 1977, " Surveillance of Contractor Quality
Assurance / Control Activities."
Approximately ten of the abcve discrepancies appeared to be isolat M
occurrences in a series of closely-spaced repetetive surveillances;
however, the inspector found fourteen check sheets in a row involving
'
calibration of instruments used by Hunter Corporation and covering a
-
period of approximately one year, and eleven check sheets involving
concrete and grout pour preparation by Blount, which were not signed
off by CECO QA and which were not isolated occurrences. The inspector
notified the licensee that this failure to properly review and
approve surveillance documentation in accordance with QP No. 18-2 is
an item of noncompliance with Criterion VI of 10 CFR 50, Appendix E
(50-454/79-14-02; 50-455/79-14-02).
One additional example of
failure to comply with Criterion VI with regard to documentation
control is discussed in Paragraph 4.b. of Section II of this report,
and is included under the above item of noncompliance.
3.
Storage of Safety Related Materials
The inspector inspected the warehouse storage of safety-related
materials by Hunter and Hatfield, the storage of structural steel by
Blount, the cable storage yard, the piping and conduit storage
areas, and field storage of the Unit 2 reactor vessel.
No items of noncompliance or deviations were identified.
4.
Review ofCECo Corporate Office Procurement Activities
a.
Audits Related to Purchasing
The inspector reviewed the CECO audit schedules for 1977 through
1979. The inspector then selected and &riewed specific aulits
related to procurement for the Byron Pro 3ect, including andits
of Byron Site Purchasing, QA audits of the CECO Purchasing
Department, and QA audits of materials suppliers including the
NSSS equipment supplier, Westinghouu . The following audi.s
were reviewed:
(1) QA audit of Site Purchasing, Audit Report No. 1, date d
April 25, 1977.
(2) QA audit of Site Purchasing, Audit Report No. 2, dat ed
September 21, 1977.
1502 .509
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(3) QA audit of the CECO Purchasing Department, Audit Report
dated October 5, 1978.
(4) QA audit of the CECO Purchasing Department, Audit Report
dated September 20, 1979.
(5) Audit Report No. 6-79-208, dated August 28, 1979, covering
an audit of Southwest Fabricating and Welding Company on
,
August 23-24,
979.
.
(6) Audit Report No. 6-79-189, dated May 8, 1979, covering an
audit of Ramco Industries Inc. on April 30, 1979.
(7) Audit Report No. 6-79-191, dated June 4, 1979, covering an
audit of Teledyne Brown Engineering on May 31, to . Tune 1,
1970 -
(8) Audit Report No. 6-79-200, dated July 18, 1979, covering
an audit of Pittsburgh Testing Laboratory on July 12-13,
1979.
(9) Audit Report No. 6-79-185, dated May 9, 1979, covering an
audit of Systems Control Corporation on April 24-25, 1979.
(10) Audit Report dated February 15, 1979, covering an audit of
Westinghouse, Monroeville, on February 6-7, 1979.
(11) Audit Report dated February 10, 1978, covering an audit of
Westinghouse, Pensacola, on January 31-February 2, 1978.
(12) Audit Report dated February 16, 1979, covering an audit of
Westinghouse, Cheswick, on February 8-9, 1979.
(13) Audit Report dated February 16, 1979, cevering an audit of
Westinghouse, Tampa, on February 5-6, 1979.
No adverse issues were identified.
b.
Review of General Office Purchase Orders
The inspector selected two purchase orders from the General
Office Purchasing files for review, with emphasis on the
inclusion of specified technical requirements in the procure-
ment documents, conformance with the approved bidders list, and
receipt of the required technical information in the vendor
documentation submittals. The following purchase orders and
associated documents were reviewed:
1502
510
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.
(1) Purchase Order No. 186239, dated June 27, 1975, with ITT
.
Grinnel Corporation, for procurement of safety-related
hangers, snubber and supports to S&L Specification F/L-2771
as revised March 14, 1974, with change order of August 20,
1976 to add procurement of mechanical seismic restraints
and attachments.
(2) S&L Specification F/L-2771, as noted above. The inspector
'
did not review the specification in detail, but verified
.
that the correct specification was included in the purchase
order and that the QA requirements fo' vendor documentetion
had been included.
(3) Station Nuclear Engineering Department (SNED) letter cf
June 17, 1975 to CECO Purchasing, requesting the inclusion
of Specification F/L-2886 for mechanical seismic restraints.
(4) Price requests dated April 5, 1974 to five bidders for the
original purchase to F/L-2771; and September 18, 1975 to
three bidders for the mechanical seismic restraints to
F/L-2886.
(5) Letter of April 4, 1978, from CECO to ITT Grinnel Corporation,
which accepts the Grinnel QA Program.
(6) The SNED vendor submittal file for Purcnase Order 186239.
The inspector verified that the required procedures,
analyses, and test results were submitted by the vendor
and reviewed by S&L.
(7) Purchase Order No. 222430, dated March 10, 1978, with
Chicago Bridge & Iron Company for pipe whip restraints to
Specification F/L-2909 dated September 21, 1977.
(8) Specification F/L-2909, as noted below. The inspector
verified that the specification included appropriate
acceptance criteria, that the QA requirements for vendor
documentation were detailed, and that an inspection point
program was incorporated.
(9) Nuclear Price Request NUPR No. 15218, dated September 27,
1977, and SNED to Purchasing letter dated January 23,
1978, which evaluated the proposals received and noted
that the QA manuals had been accepted for specific bidders.
(10) Letter of July 24, 1978 from CECO to Chicago Bridge & Iron
Company, which accepts the CBI Quality Assurance Program.
1502
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t
(11) The ShTD vendor submittal file for Purchase Order 222430.
-
The inspector verified that the required procedures,
analyses, and test results were submitted by the vendor
and reviewed.
No items of noncompliance or deviations were identified during
the above review.
s
.
1502 312
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.
.
Section II
-
Prepared by G. F. Maxwell
Reviewed by D. W. Hayes, Chief
Engineering Support Section 1
s
1~
Audits Conducted by CECO Site QA - Units 1 and 2
a.
The inspector reviewed the site audit schedule for 1977, 1978
and 1979 to determine if audits are being scheduled as required
by CECO " Byron Quality Instruction No. 11" (current revision),
CECO Topical Report CE-1-A (section 18) and therefore ANSI
N45.2.12Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2.12" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
b.
The inspector randomly selected the below listed Ceco Site QA
audits to observe if audits are being conducted as scheduled,
if audits are being documented, if CECO QA is conducting follow-
up inspectisn (as required) to determine that satisfactory
corrective action has been taken and if aedit personnel were
qualified - as required per CECO Topical Report CE-1-A, Section
18.
(1) Audits of Hatfield Electric Company (HECo) (the site
electrical contractor), CECO audit reports numbered;
6-77-72, 6-78-140, audit #6, 6-78-105, 6-78-162 and
6-78-123.
(2) Audits of Peabody Testing Services and Pittsburgh Testing
Laboratory (PTL) (the site testing groups responsible for
concrete testing and nondestructive examination of welds /
piping), CECO Unit reports numbered; 7-22-77, 6-79-192 and
6-79-172.
(3) Audits of Hunter Corporation (HC) (a site contractor),
CECO audit reports numhered; 6-78-121, 6-78-145 and
6-78-160.
(4) Audits of Blount Brothers Corporation (BBC) (a si'.e con-
tractor responsible for concrete activities), CECO audit
reports numbered; 6-78-101, 6-78-111, 6-78-133 and 6-78-156.
(5) Audit of CECO Station Construction, CECO audit reports
numbered; 6-78-154 and 6-77-56.
No items of noncompliance were identified.
1502 313
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2.
Nonconforming Conditions Identified by CECO or Site Contractor
-
Personnel - Units I and 2
The inspector observed that CECO site QA has established and is
a.
maintaining a Nonconformance Repert (NCR) station log to monitor
resolution per CECO Topical Report CE-1-A, Section 16.0, page
16-2 and therefore ANSI N45.2, Section 17.
'
b.
The inspector observed that resolution and appreval of corrective
.
actions by Engineering, relative to Nonconformance Reports
(NCR's), is ht ng completed in a timely manner - a requirement
of CECO Topical Report CE-1-A, Section 16.
This observation
was confirmed by a review of 45 NCR's initiated by B.B.C.,
four
NCR's initiated by P.T.L. and 16 NCR's initiated by H.C.
c.
The inspector observed that; Engineering is issuing monthly
reports indicating the status of all NCR's submitted for reso-
lution, the Site QA Supervisor is performing follow-up and
final approval to assure satisfactory correction of nonconforming
conditions, and the site QA Supervisor is conducting ar extensive
overview of site NCR's - a requirement of CECO Topical Report
CE-1-A, Section 16.
These observations were confirmed as a
result of interviews with site personnel, a review of the above
mentioned NCR's, Monthly QA Performance Measurement Reports
(CECO) and the NCR logs maintained by CECO.
No items of noncompliance were identified.
3.
Audits Conducted by Site Contractors - Units 1 and 2
a.
The inspector reviewed Hunter Corporation audit schedules (for
1977 and 1978) and Hunter audit reports numbered 2-06, 2-02 and
058-2 to observe; if audits are being conducted as scheduled,
if audits are being documented, if Hunter QA personnel are
conducting follow-up inspection (as required) to determine that
satisfactory corrective action has been taken and if audit
personnel were qualified. The audit scaedules, reports, follow-
up, audit personnel records and corrective actions were compared
with the requirements of Ceco Topical Report CE-1-A (section
18) and therefore ANSI N45.2.12.
b.
The inspector reviewed Blount Brothers Corporation (BBC) audit
schedules (for 1977 and 1979) and BBC audit reports numbered
Q4-323 and Q4-240. The audit schedules, reports, follow-up,
audit personnel and corrective actions were compared with the
requirements of CECO Topical Report CE-1-A (section 18) and
therefore ANSI N45.2.12.
1502Property "ANSI code" (as page type) with input value "ANSI N45.2.12.</br></br>1502" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.
314
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c.
The inspector reviewed Hatfield audit reports numbered H06-77-03,
H06-78-1 and audit report dated February 23, 1978 to observe;
if audits are being documented, if Hatfield QA personnel are
conducting follow-up inspection (as required) to determine that
satisfactory corrective action has been taken and if audit
personnel cere qualified. The reports, follow-up, audit per-
sonnel and corrective actions were compared with the requirement
of CECO Topical Report CE-1-A (section 18) and therefore ANSI
,
N45.2.12.
As a result, on September 13, 1979, the inspector
.
observed that Hatfield had not retained a copy of the site
audit schedules for the years prior to 1979. However, prior to
the NRC site exit (on September 20, 1979) these audit schedules
were re-constructed by the Hatfield Site QA Manager.
The
inspector compared the re-constructed schedules with CECO site
QA audit and surveillance schedules (for dates pricr to 1979);
the inspector has no further questions about this matter at
this time.
No items of noncompliance were identified.
4.
Design and Design Changes - Units 1 and 2
The inspector randomly selected eleven Field Change Requests (FCRs)
from the CECO Station Construction Department's (SCD) Field Change
Request Log. The purpose of selecting the FCRs was to determine:
if FCRs are receiving the proper approval prior to work being com-
pleted (as applicable); if adequate interface exists between SCD,
Station Nuclear Engineering Department (SNED) and the Architect
Engineer (Sargent & Lundy); if the applicable site cor. tractors are
maintaining or referencing the FCRs (as applicable) on the affected
design document (s); and if the SCD Field Change Request Log indicates
(accurately) the status of FCRs. The applicable requirements which
were used as a reference included CECO Topical Report CE-1-A Section
3.2 and 6.0; ANSI N45.2.11, Sections 2.2.15 and 5.1; CECO Quality
Procedure 3-2 (current revision); CECO Byron Site Instructions
numbered BQI-9 (revision 1) and BQI-10 (revision 4); Blount QA/QC
work procedure No. 1 (Issue 10, Revision 9); Hatfield Procedure
No. 4 (Issue 1, Revision 2); and SNED Procedures numbered Q.8 and
Q.9.
As a result of the reviews of the SCD Field Change Request
Log; interviews with CECO, SCD, SNED, S&L and contractor personnel;
and comparisons made with nine of the eleven FCRs at the applicable
contractors work locations:
The inspector observed that the site Hatfield QC inspection
a.
group did not have a copy of FCRs numbered 277 aor 281. Also,
the applicable drawings retained by this group did not have a
copy of these FCRs either attached or referenced on them
(reference Hatfield Procedure number 4, Revision 2, Issue 1,
paragraph 5.18.7).
During a subsequent inquiry, the inspector
1502 il5
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was informed by CECO QA that all FCRs held by Hatfield (that
are numbered 1 through 400) cre under re-evaluation by Hatfield
Engineering in reference co a NRC item of noncompliance identi-
fied in IE inspection repcrt 50-454/79-01 and 50-455/79-01.
The inspector confirmed this with the assigned NRC RIII electrical
inspector who had identified the noncompliance (454/79-01-C.,
455/79-01-02).
The aformentioned concern will be followed-up
as part of the RIII inspection to assure satisfactory resolution
,
of noncompliance item numbered 454/79-01-02 and 455/79-01-02;
.
this matter is unresc1ved (454/79-14-03;
455/79-14-03).
b.
Relative to three other FCRs, (numbered 605, 775 and 780), the
inspector observed:
(1) FCR 605 was initiated on November 16, 1978 to allow Hunter
to increase the sleeve length on some oiping system wall
sleeves for Unit 2 Reactor building.
on September 20,
1979, the inspector and CECO QA personnel noted that
neither Hunter, CECO, SCD, or CECO QA had a/the approved
copy of the FCR. On September 26, 1979, the inspector
noted that the S&L Project Manager for Byron has a letter
d aeu December 20, 1978, wherein he claimed that he was
forwarding the approved FCR 605 to the Byron Station Con-
struction Drpartment. On September 24, 1979, saile inter-
viewing tiu CECO SCD representative responsible for the
mechanic,1 piping system's erection, the inspector observed
that S&I approved an Engineering Change Notice (ECN)
numbered 957 on December 20, 1978.
S&L wrote ECN 957 in
response to FCR 605 thereby " superceding" or causing the
FCR condition to be upgraded by a more " senior" design
document.
The CECO SCD representative assured the inspector
that no affected construction activities had been conducted
prior to the site's receipt of the approved " senior"
document. The inspector observed that Hunter and SCD did
s
have a copy of ECN 957; however, neither the SCD Field
Change Request log or any other CECO site logs accurately
shoved the " approved" status of FCR 605.
(2) The inspector and CECO QA personnel observed that SCD
Field Change Request log did nat accurately show the
telephone approval for FCR 775 or 780.
A review of these
two FCRs, with attachments, indicated that tney had received
' telephone approval on May 4,1979 and May 10, 1979 respec-
tive_1y; however, the SCD Field Change Request log did not
show1h3L telephone approval had been received.
The CECO Q.i % nual, Quality Procedure 3-2, Revision 6,
paragraph 4.5 jequires that SCD be responsible for the
logging and coordination of FCRs.
The inspector informed
1502
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CECO SCD and CECO QA that there is no apparent jeopardy to
the public's safety, due to the inaccurate statusing of
FCRs (605, 775 and 780); however, that this is a condition
of noncompliance (a deficiency).
This conditior is another
example of the deficiency described in Section I, Paragraph
2 of the details section of this report.
The ir apector discussed this matter with the CECO Construc-
s
tion QA Manager who stated that the administrative condition (s)
-
which has caused the inaccuracies in the tracking of FCRs
will he resolved within two months.
He stated that the
FCR log will be checked item by item to determine and
reflect the current status and as required will obtain the
appropriate documents and signatures which correspond to
the status.
lie further stated that, to keep the log current,
each site will be required to review the log monthly to
determine which additional documents and signatures are
needed to update the log for previous months activities
and document their requests for additional information.
Except as noted, no items of noncompliance were identified.
5.
Audits Conducted by CECO Corporate Office - Units 1 and 2
The inspector reviewed the CECO Corporate audit schedules for
a.
Byron related activities covering 1977, 1978 and 1979.
The
schedules were reviewed to determine if corporate audits are
being scheduled as required by CECO Topical Report CE-1-A
(section 18) and therefore ANSI N45.2.12.
b.
The inspector randomly selected CECO corporate audit reports
of:
Byron Site activities (audit reports dated September,
1979, May, 1979 and March, 1278) and S&L Design Activities
(audit reports dated March,1977 and November, 1977). The
inspector reviewed these audit reports and related correspon-
dence to observe; if audits are being documented, if CECO QA is
conducting follow-up inspection (as required) to determine that
satisfactory corrective action has been taken and if audit
personnel were qualified as required per CECO Topical Report
CE-1-A section 18 and therefore ANSI N45.2.12.
No items of noncompliance were identified.
1502 .517
- 16 -
.
Section III
Prepared by J. F. Suermann
Reviewed by D. W. Ilayes, Chief
Engineering Support Section I
s
1.
Design and Design Change Control
The IE inspector reviewed Commonwealth Edison Company (CECO) QA
a.
Procedure Q.P. No. 3-2 " Design Change Control," and Station
Nuclear Engineering Department (SNED) Procedures Q.8 " Field
Change Requests," dated February 16, 1979 (Revision 3), Q.9
" Design Change Notices," dated December 1, 1977 (basic issue)
and Q.14 " Distribution Lists for Design Documents," dated
January 17, 1977 (basic issue).
The procedures reviewed as
well as discussions with SNED personnel indicated that CECO
appears to have a system that basically complies with ANSI
N45.2Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. for controlling design changes.
Items covered by the
procedures included, but were not limited to, conditions
requiring design changes; distribution, review, approval,
release and revision requirements; and provisions for assuring
that design changes are compared with SAR commitments.
The IE
inspector also reviewed Sargent & Lundy (S&L) Procedure GQ 3.13
" Engineering Change Notice," dated September 20, 1978 (Revision
5) and discussed implementation of the procedure with S&L
personnel.
S&L personnel appeared knowledgeable in the pro-
cedural requirements and responded to the inspector's satis-
faction on questions regarding the application of the procedure.
S&L appeared to have adequate control over design changes and
their translation into possible SAR commitments.
b.
A random selection of documents was made to inspect compliance
on the part of S&L and CECO (SNED) with their respective proce-
dures.
Other than one or two isolated instances of a missed
block on a form, the following documents appeared to indicate
the respective engineering organizations were following their
procedures:
(1) S&L Engineering Change Notice No. 1266, cover letter dated
August 2, 1979.
(2) Field Change Request No. 605, cover letter dated December 20,
1978.
1502
.618
- 17 -
.
(3) Field Change Request No. 77a, cover letter dated Septemoer 20,
1979.
(4) Engineering Change Notice No. 1172, cover letter dated
May 21,
1979.
(5) ECN Index and Status Report, Page 69, dated September 15,
,
1979.
.
2.
QA/QC Personnel Qualification / Certification
The IE inspector reviewed Hunter Corporation Site Implementation
a.
Procedure (SIP) 1.702 "QA Personnel Qualification and Training,"
Revision 1 dated Parch 5, 1979 for compliance with ANSI N45.2.6-1973,
which the licensee has committed to in its QA program. Additionally,
the personnel records of 23 QA/QC personnel were reviewed for
compliance with SIP 1.702 and ANSI N45.2.6.
Discussions with
the QA Supervisor, QA Administrative Supervisor, and QA Training
Coordinator were held to resolve questions on the procedures
and records.
Specific comments relating to the adequacy of the
site implementing procedure and the records relating to it are
as follows.
(1) The use of a proficiency test as a basis for certification
is fairly common throughout the records but the SIP does
not give definitive guidance as to whom the test is adminis-
tered (with the conclusion being inferred that it is at
the discretion of the QA Supervisor), whether the test is
a practical, oral or written test, or what passing grades
are required (i.e. quantitative criteria) for qualification.
(2) ANSI N45.2.6 requires that prior experience be in QA
inspection or testing or both.
The llunter SIP is 5ritten
such that prior experience in construction, instal;ation
or other equivalent fields is used as a basis for certifi-
cation in lieu of QA related experience. This is true of
both Level 4 and Level 5 requirements in the Hunter SIP.
(3) ANSI N45.2.6 requires that prior experience, education and
training all be considered as relevant factors in the
awarding of certifications.
In at least fourteen of the
23 records reviewed, the personnel had the minimal educational
requirements, but there was a lack of prior QA experience,
and a predominant number of certifications were based upon
site-conducted training and demonstrated proficiency (i.e.
no formal proficiency test was required).
1502
319
- 18 -
.
(4)
In at least three cases, the prior experience of the
-
personnel certified was not related to the position for
which he was certified as required by ANSI N45.2.6 but it
did meet the more liberally written SIP.
(5)
In one case of a Level 3 Lead Auditor, the qualification
certificate does not indicate the period of certification
as required by both the SIP and ANSI N45.2.6, nor does it
,
indicate the basis used for certification.
.
(6) Paragraph 5 of ANSI N45.2.6-1973 requires that certain
records be kept in the personnel folders. The Hunter SIP
lacks definitive guidance as to what records are required
ir. the qualification folders to substantiate the basis of
certification.
The specific cases of a lack of prior related experience are
considered to be the result of the liberally worded, and sub-
sequently inadequate, SIP.
The liberal interpretation of SIP
1.702, specifically in ita rewording of experience factors and
its arbitrary use of proficiency testing to offset specific
prior QA requirements, does not meet the intent of ANSI N45.2.6.
b.
The IE inspector reviewed Blount Brothers Corporatior,QA/QC
Work Procedure Number 33, " Personnel Qualification and Certifi-
cation Procedure," Issue 2, Revision 1, dated February 9, 1979.
In addition, the inspector discussed the implementation of the
procedure with the QA/QC Supervisor and reviewed the personnel
qualification folders of nine Blount QA/QC personnel.
Based
upon the above, specific comments relating to the adequacy of
the site implementing procedure and the records relating to it
are as follows.
(1) The QA/QC Supervisor informed the IE inspectr
that follow-
on training is conducted on an "as needed" basis. The
only training formally required by the procedure is the
initial training or indoctrination given at the time an
employee is hired and there are no procedural requirements
that formally require continued training to maintain
proficiency in technical areas or to keep personnel abreast
of changes in QA policy or procedures.
(2) Background education and prior experience are minimal in
meeting the requirements of ANSI N45.2.6-1973.
In one
case, the personnel record clearly showed an individual
lacked the minimum education and was apparently accepted
for a position based on extensive field experience without
documenting the exception taken to the procedural require-
ments. This was an isolated instance and not considered
i502
(20
- 19 -
.
to be injuricus to the puv '.c health and safety, but the
IE inspector did questian ;ne thoroughness with which
people were examined to establish their certification.
(3) The QA/QC Supervisor stated that on occasion a proficiency
test ma',' be used as the basis for certification, and
several records substantiated this. There are no procedural
requirements addressing this practice, either quantitatively
s
or qualitatively.
.
(4) Contrary to ANSI N45.2.6, which requires specific QA
related experience at certain levels and a balanced con-
sideration of prior related experience, education and
training, several people were awarded certification based
on the results of site conducted training and served minimal
apprenticeship periods as trainees before being awarded
Level 1 capabilities. One individual who had eight weeks
of site training and marginal prior experience before
being certified as a receipt inspector was interviewed by
the IE inspector.
Based on the interview the inspector
questioned the individual's knowledge of what should have
been basic requirements associated with his position.
The
individual was quite nervous and seemed to respond more
positively to the questions re phrased by the QA Supervisor
which indicated the individual may have been more knowledgeable
and simply did not respond well to this particular interview.
(5)
Blount Procedure 33 is vague on the quantitative criteria
used to measure acceptable physical requirements, whereas
ANSI N45.2.6 requires that specific criteria be met with
regard to visual acuity.
The practice of ascribing little weight to prior related
experience when certifying individuals, the lack of the
procedure to address quantitative criteria, failure to
reflect the use of proficiency testing and controlling its
use in the procedure, and failure to address continued
post-indoctrination training as a matter of record are
considered inadequate implementation of ANSI N45.2.6.
c.
The IE inspector reviewed Hatfield Electric Company Procedure
- 17A " Qualification and Certification of Inspection Personnel,"
Revision 0, Issue 2, dated September 14, 1978 and related
personnel records of six Hatfield personnel. Additionally, the
IE Inspector sought clarification from the Hatfield QA Supervisor
on several questions raised during the inspection. Documentary
review and discussion with QA personnel resulted in the conclusion
that the procedures are inadequate for the following reasons.
1502 .i21
- 20 -
.
(1) The QA supervisor informed the inspector that Hatfield
personnel are qualified to Procedure 17A and not to ANSI
N45.2.6Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2.6" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., yet the QA supervisor's Certificate of Qualifi-
cation states his own Level 3 capability was awarded per
Since Procedure 17A does not invoke ANSI
N45.2.6Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2.6" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. (either in whole or partially with exceptions so
stated) this is a conflict and the procedural basis of
certification is unclear.
,
.
(2) Procedure 17A does not specify what the period of certifi-
cation is for qualified persennel nor does it specify what
re-evaluations are required or when they are required.
(3) Procedure 17A does not specify what the basis of certifi-
cation is for awarding personnel certification.
It is not
clear if proficiency testing is a criterion used in evalu-
ating initial hire personnel or if test scores are solely
those of required training once the person embarks on the
Hatfield training cycle.
(4) Procedure 17A does not specify any quantitative criteria
for eye examination (i.e. what visual acuity criteria are
the acceptable minima for an inspector) nor does it specify
the frequency of examination and the disposition of exami-
nation results.
(5) Procedure 17A does not specify what records are required
as part of the person's qualification file.
(6) Paragraph 5.5 of Procedure 17A is so liberally written
that virtually any prior experience in general construction
may be considered adequate in meeting the experience
factors used as guidelines in ANSI N45.2.6.
The require-
ments of paragraph 5.5 do not comply with the minimum
requirements of ANSI N45.2.6-1973 from either a qualitative
or quantitative viewpoint.
d.
Paragraph 2c. above dealt with the procedural adequacy of
Hatfield Procedure 17A in complying with the intent and imple-
mentation of ANSI N45.2.6.
A review of the six Hatfield per-
sonnel files revealed the following discrepancies in following
the procedure, notwithstanding the procedure's inadequacy.
(1) Paragraph 5.5.5 of Procedure 17A requires that detailed
explanations be documented on the qualification certifi-
cate when equivalent experience is used to qualify an
individual.
In at least four of the six files, the
explanation was not documented to justify how the prior
experience related to the level assigned.
1502 ?22
- 21 -
.
(2) The experience and educational background stated on the QA
Supervisor's certificate of qualification did not comply
with the requirements of ANSI N45.2.6 at the time of
certification (May 31, 1977) and the level of capability
assigned was per ANSI N45.2.6.
(3) 6ne QC inspector was hired on August 13, 1979 and as of
the date of this inspection the certificate of qualifi-
,
cation reflected only the man's name, job title, and date
-
of hire. The inspector was informed verbally that the
individual was in a trainee status but the certificate did
not reflect this. The certificate did not indicate the
man's level of capability, nor was it signed, nor did it
list any criteria used for qualification. There were no
other documents in the file and a copy of the man's
employment application was finally obtained from the
Hatfield project manager; the experience shown on the
application was neither construction nor QC related.
(4) A second QC inspector's certificate of qualification was
signed and dated October 16, 1978 by the QA Supervisor,
but the qualification test awarding him a trainee level
was dated October 23, 1978.
This is contrary to Paragraph
5.5.5 of Procedure 17A. The experience shown on the
certificate was neither in inspection nor construction as
required by Paragraph 5.5.1 of Procedure 17A.
(5) A third QC Inspector hired on February 26, 1979 was certi-
fied to a Level I position but the certificate of qualifi-
cation was neither signed nor dated as of this inspection.
Moreover, the experience shown on the certificate did not
appear to meet the requirements of Paragraph 5.5.2 of
Procedure 17A. The/ individual had no prior QA/QC or
nuclear plant experience prior to joining Hatfield in
February 1979.
The examples of inadequate implementing procedures (paragraphs
e.
2.a.-c.) and failure to follow procedures (paragraph 2.d.) do
not meet the intent of ANSI N45.2.6, and as such constitute
noncompliance with 10 CFR 50, Appendix B, Criterion V.
These
two additional examples of failure to comply with Criterion V
are included inder the noncompliance discussed in Section I,
Paragraph 1.b.
.
Unresolved Items
Unresolved items are matters about which more information is required in
order to determine whether they are acceptable items, items of noncompli-
ance, or deviations.
An unresolved item disclosed during the inspection
is identified in Section II, Paragraph 4.a.
1502
e23
- 22 -
.
Exit Interview
An interim exit meeting was held at the Byron Site at the completion of
the On-Site portion of the inspection on September 20, 1979, The final
exit meeting was held at the Region III offices on September 28, 1979.
Attendees at both meetings are denoted in the Persons Contacted paragraph.
The inspectors sumuarized the scope and findings of the inspection. The
licensee acknowledged the findings.
,
.
1502
324
- 23 -