ML20027A796
| ML20027A796 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 05/26/1982 |
| From: | Goodie J ILLINOIS, STATE OF |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20027A786 | List: |
| References | |
| FOIA-82-328 NUDOCS 8206110068 | |
| Download: ML20027A796 (19) | |
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TYRONE C. FAHNER ZQd3~~' . '"/ '--
ATTORNEY GENER Al. * ** '
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TELEPHohg 160 NORTH LA S ALLE STMEET ,a 79h3Mof
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May 26, 1982 '
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- .*...__.J.'.-)usl NUCLEAR REGULATORY COMMISSION In the Matter of: )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-373
) 50-374 LaSalle County Nuclear )
Generating Station, Unit 1 )
and Unit 2 )
Mr. Harold Denton Director of Nuclear Reactor Regulation 9720 Norfolk Avenue Bethesda, Maryland 20814
Dear Mr. Denton:
This office has recently received three reports concerning the procedures for drilled and cored holes at the LaSalle County Nuclear Station, two by Commonwealth Edison Company and one by the NRC Region III staff. Edison's Final Report, dated May 7, 1982, was received May 12. Edison's Report in Response to Amended Petition, concerning rebar damage in the Unit 1 primary contain-ment, dated May 18, 1982, was received May 25. Upon reading i
I Edison's Final Report, I first learned that Region III had sub-mitted its own report on the drilling procedures (No. 5 0-37 3/8 2-21, DETP) to Edison on April 27, 1982. Upon my request, Mr. C.E.Norelius, the Region III Director of Engineering and Technical Progams, fur-ni,shed a copy of the April 27 inspection report. Mr. Norelius advised, however, that "another report will be issued which will identify the specific allegations and our related findings."
l (Letter of C. E. Norelius, May 14, 1982) The lack of specificity an'd factual findings in the April 27 report of Region;III has thus been acknowledged and hopefully will be corrected. -
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e Mr. Harold Denton i Page Two.
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This letter is intended to comment on a fes questions whi'h c
} are raised by Edison's Final Report of May 7, 1982 and which, in i
- the opinion of this office, remain to be addressed in the pending inquiry. In view of Region III's intention to issue another re-port, it is hoped that these. questions will also be addressed wi specificfindingsbeforetheinvestigationisconsidered"closedg .-
1.
Edison's Final Report purports to address rebar damage in "all2 structural Unit areas requiredelements in 1 for Unit alloperation."
Unit'l areas and in those (Page 33) There is no indication on the record thus far that Edison or the NRC staff intends to investigate possible damage to the integrity of Unit 26 It is obvious that Unit 1 has been reviewed first because of Edison's intention of keeping to its most recently revised start up schedule. However, we trust that the safety of Unit 2 will also be addressed before the NRC rules on our Section 2.206 requee 2.
Neither Edison nor Region III has addressed the question of how non-conforman,ing gation. At the h~ ear on March 31ce reports.wgrq_ treated in the c 1982 Edison admitted that tws incidents of rebar_ damage in non-conforming _ cored passageway holes which were cited in affidavit in our original petition, had in fact occurred.. (Transcript, pp. 62-63.)
date Edison has not reported on: Yet to y/a. The procedures for reporting all non-conformances in cored passageway holes.
, /b.
V The total number of non-conformance reports filed with respect to rebar damage in cored passageway holes.
j ec. The manner, if any, in which non-conforming cored rebar damage was accounted for in the total assess-ment of rebar damage.
t These questions are not addressed in Section 2.4 of Edison's Final Report. The Final Report Teviews only the cored passageway holes I which were drilled according to the structural design drawings.
- Edison's recent review of cored passageway.rebar damage is based entirely on assumptions made at the time the drawings were made, and not on any field verification or written prqcedure for carryinc out the instructions 6n the drawings. Yet the record shows clearl}
that deviations from the drawings did in fact occur.
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- Mr. Harold Denton Page Three.
- 3. The only written control on rebar damage in , cored passageway holes was the use of i,nstructional notes on an unknown n' umber of structural design drawings. Edison's Final Report gives qwo examples of such notes, which call for the use of metal de-tectors in two specific instances. (Section 2.4.4) A total of 971 cored passageway holes have been documented. (Table 2.4-1)
Edison has not reported on:
- a. The total number of holes for which metal detectors were required in drawing notes.
- b. How many bars, if any, were assumed to have been damaged in the drilling of such holes.
- c. What, if any, verification procedures were employed by the contractors to ensure that metal detectors were in fact used, and that undesired rebar damage did not in fact occur.
Our concerns about the failure to specifically account for non-conformances and the failure to explain how the use of metal detectors was actually verified are reinforced by a management audit on the LaSalle site which was made available to this office a few days ago. In a 1977 review of the planning and controls of Edison's construction activities at the LaSalle County Station, Arthur Andersen & Co. made several recommendations to Edison for improve-ments at the site.* Among the recommended improvements were:
" uniform procedures for routine construction tasks;"
" extension of internal auditing to include these proce-dures;" " implementation of exception reporting;" and
" establishment of training programs for construction engineers and auditors." (Letter from Jon H. Knoll
[Andersen] to Wallace B. Behnke [ Edison) dated 10/7/77)
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- Copies of the cited portions of the Andersen audit a e attached to this letter.
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, , i Mr. Harold Denton Page Four. ,
(dndings by Arthur Andersen 's au'ditors:These recommendations stemmed
.[ a. Because of the way the H. P. Foley contract was written,"C. E. Co. has to fight to get adequate -
supervision." (Document 4 0-V. 301, Interview with Site Project Superintendent.)
- b. " Quality Assurance. Staff is too young and inex-perienced. Creates problems and extra cost."
(Document 4 0-V. 301, Interview with Site Project Superintendent.)
c.
"No formal training is available for new engineers.
Experience in construction, estimating, and contract negotiating and administration is gained in the field." (Document 40-IV. 302, Interview with Mechanical Coordinating Engineer.)
- d. " Control over drawings is well established. A central file is maintained . . . . Engineers check out draw-ings, and if a revision comes in the file clerk -
notifies all engineers who have checked out the previous version. When a drawing comes in, the trans-
. mittal letter is routed to the engineers involved.
Procedures do not call for review of drawings by the engineers, which would be impractical due to the high volume." (Emphasis supplied) (Document 40-V. 300, Inter-view with Administrative Assistant.)
- e. ". .
. not all design chances on large jobs are routed through engineering for approval . . .
[The Administrative Supervisor] was not aware of any effort to verify the required approval process." ~
(Document 4 0-IV. 303, Interview with Administrative l Supervisor.)
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Thus deficiencies in personnel training and supervision and in administration in,1977.
were apparent at the LaSalle construction site From 1976 to at least 1980 passageway holes were cored wi,thout any procedure for verifying that the drawings were being followed in the field. As late as 1978-79, long after Edison was advised to beef up_its training and quality assurance; programs, j]was ordered by his supervisors to drill non-conforming core passageway holes.
Yet Edison and the Region III inspectors i
Mr. Harold Denton Page Five, i
havecontinuedtorelyuponassumptionsthatdrawinghnoteswere '
i'mplemented, that metal detectors'were used, and that instructions t'o notch walls for grouted anchor holes necessarily prevented r,ebar damage.
An explanation of the matters raised in paragraphs 1, 2, and 3 above presented.
is necessary to fill in the gaps in the information already Without such an explanation, we still do not know with assurance that all rebar damage has been accounted for. We know only about reported damage from anchor bolt drilling and assumed damage from cored holes located on structural drawings.
The contrast between the incomplete controls over drilling under the electrical equipment contract, and the careful supervision and control reported by Edison.for the drilling of holes in the primary containment, is striking. Edison's most recent submittal, dated May 18, 1982, describes detailed calculations, written instructions, close field supervision, and complete re' porting, with regard to rebar damage in the primary containment.* Such care is not evident with respect to the core drilling in other safety related structures. !.'hus the need to provide a more thorough analysis of the issues raised here.
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- It is noteworthy that the May 18th report describes holes cored into the containment walls as varying from l' 5-1/4" to 2' 4-7/8" I in depth (at p. 11). On March 31 Edison stated that holes in the l primary containment wall were up to 6" in depth. (Transcript, p. 60)
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Mr. Harold Denton Page Six.
i Once the pending inquiry is complete, this office looks forward t'o meeting with you to discuss your findings, with our consultant ib attendance, pursuant to the invitation extended in April by your staff.
Very truly yours, M
JUMTH S. GOODIE Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315 .
Chicago, Illinois 60601 (312) 791-2491)
JSG:bl Enclosures cc: James G. Keppler, Regional Administrator, Region III C. E. Norelius Richard Hoefling Philip P. Steptoe i
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40-IV.303
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COMMONWEALTH EDISON COMPANY PLANNING AND CONTROLS PIVIEW CONSTRUCTION -
MEMORANDUM FOR THE FILES
- Interviewers
- Dave Smitl T. Tuberge April 18, 1977
Subject:
Interview With Mr. Jerry Harlow, Administrative Supervisor, Station Construction Reference
- 1. The position of Administrative Supervisor was established a year ago to provide control and cocrdina-tion for Substation Construction office work. The mnin impetus was to reduce the time lag in processing vendor payments.
- 2. Payments to vendors for material.and labor used at most construction sites are processed through Station Construction. LaSalle, Collins, Byron and Braidwood invoices are processed at those locations.
Station Construction processin5 time for invoices has dropped fron 32 days to 5% days on the average.
Invoices with discounts applicable are hand carried
, throu5h Accounts Payable to ensure that 'the discount is received.
3 The Administrative Supervisor is responsible for ensuring clerical support within the office, time-keepins for all department members and financial contract administration, i.e. , processing bills.
- 4. Jerry has authored a booklet for distribution to all contractors. This book offers explanations of basic contract terms and includes examples of docu-mentation required of the contractors. (See Exhibit 40-IV.506) i 5 A new Construction Cost Documentation Manual
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has been written and is currently being prepared for distribution to the field.. -
- 6. Station Construction receives co' pies of all drawing release transmittal letters issued by Engineerin5 or the A/2. For small projects (i.e., not new generating stations) Station Construction issues a A37/t
contract change authorization (CCA) to the contractor requesting a proposal. These proposals are to be sent to Station ~ Construction and are forwarded to the field engineer upon completion of a field estinate.
The field en5 ineer is responsible for negotiating the contract change with the contractor. An acceptance CCA is issued by Station Construction When an aEree-i ment has been reached. This process is controlled via a contract change log (Exhibit 40-I7.406), and
- has been flowcharted for the department (Exhibit
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40-IV.600). Jerry noted that field engineers have, .
. on occasion, received a proposal before their estimate has been received at Station Construction.
7 Jerry noted that no system exists to ensure notification is forwarded to Station Construction of any field changes which may be initiated by a field engineer.
- 8. Station Construction is initiating technical audits to ensure the field engineers are providing adequate control over contracts and contract chan5es.
This effort has just begun and no procedures or reports have been' defined. An outside estimator has been contacted to re-estimate changes and these will be compared with the field estimates. No results are yet available from these audits.
9 Jerry has totally reworked the paperwork process-ing done in Station Construction. (See Eykibit 40-IV.60(
i The voucher processing done in the office is duplicated by the staff at Byron, Braidwood, LaSalle, and Collins.
l Efforts are underway to streamline the processinE done at the sites. Braidwood has completed an initial draft of the proposed processing structure (see Exhibit 40-IV.601). Byron's current processing (Exhibit 40-IV.6 is typical of the situation at the large construction sites.
- 10. Jerry is responsible for determini"5 departmental goals for station construction. He does not partici-pate in the development of the departmental bud Eet.
Jerry did not know of anyone who was concerned with monitoring the departmental budget. -
1 11. Jerry feels that not all design changes on large
- dobs are routed through engineering for approval.
- He feels this is an item that should be a concern of the internal audit. He was not aware;of any effort to
_ verify the required approval process.i __
- 12. Cost reportins for small projects is not currently ,
available in any useable form. The Maywood personnel therefore can not use ECP, PMS or Plant Accountin5 repor to monitor cost. Jerry is not sure of the usefulness i
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, 3 of these reporting systems to field personnel at LaSalle, Byron, Braidwood or Collins. The only involvement of the Station Construction Mafwood personnel in cost reporting is to ensure that con-tractors send a completed construction report to Plant Accounting for the unit property records.
(See Exhibit 40-III.410)
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, COMMONWEALTH EDISON COMPANY PLANNING AND CONTROLS REVIEW CONSTRUCTION
, MEMORANDUM FOR THE FILES [
I Prepared by T. Tubergen
- April 19, 1977
Subject:
Interview With Mr. Les Bird,
, Mechanical Coordinating Engineer, Station Construction Reference
- 1. As coordinating en5 ineer, Les has no people reporting directly to him. He maintains a functional -
relationship with the mechanical engineers at the sites. His job is to " keep the mechanical situation on an even keel" at LaSalle, Collins, Byron, and Braidwood Stations.
- 2. Les functions as a problem solver for field personnel. He is not notified of difficulties at the site unless the problems cannot be alleviated by the mechanical engineers in the field.
3 Construction Scheduling and Cost Control is
, currently working with Les and the other coordinati25 engineers to determine detail CEM schedules for Carroll County and Fossil I. This will be the first time a schedule has been compiled which includes target dates and elapsed tines for bid awards, engineering and procurement. Les is participating in this effort as no Station Construction field personnel have yet been assi 5ned to these stations.
- 4. The coordinating engineers do not serve any cost control function. Although Les receives trans-nittal letters for drawin5 releases, he does not receive drawings as he could not handle the volume of changes associated with constructing four generating
- stations.
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5 Les is not involved in estimating cost for contracts or contract changes. On cost plus contracts Edison does no chan5e estimating at all. $ argent &
Lundy forwards an est'imate to the field with the drawing chan5es, but no effort is made to relate these N
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to contractor estimates or actual cost. Les is involved in bid evaluation of contracts for field labor or mechanical work. Les relies on past experience with the contractor and his own back5 round to do this.
No contract review procedure exists to proyide a guide for contract evluation. Due to bid security, '
J no cost analysis can be performed by Les i's dudE ing
.j contract proposals.
- 6. Initial bidding for the large cost plus contracts at new station construction is done without any detail design drawings. Les noted that bids are prepared by considering several major items: job duration, number, i size and type of units, equipment and tool requirements and target man hour projections Eathered from industry statistics. Specifications, general arrangement draw-ings and P&ID's are used in estimating costs althou5h they may be incomplete or may not represent all the systems that eventually will be required in the plant.
Detail design drawings may not be available until they are required in the field. Les is hoping to begin establishing a somewhat uniform work scope for Carroll County and Fossil I for use as an estimating and scheduling tool. Les feels that the data currently available to the contractors for use in preparing proposals is not sufficient to produce a contract which will generally resemble the actual work performed in the field.
l '7 Although Les is not responsible for the work per-l formed by the field engineers, he does participate in the annual salary review. Salary recommendations are made dointly by Art Kleinmath, the site superintendent and the coordinating ens ineer. .
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- 8. No foI=al training is available for new enEineers.
Experience in construction, estimating and contract negotiating and ahinistration is gained in the field.
Little or no help is available from Company procedures.
Professional estimators have recently been hired at LaSalle to teach estimating to the engineers and to do estimating at the site.
9 Les noted the differences in the handlihg of material and procurement at the different construction
. : sites. No buying is done by the Edison people on the
- site at LaSalle. All material receiving and inspection is handled by the responsible contractor with Idison ensuring compliance with shipping and storige QA require-ments. Byron and Braidwood have on site purchasing and material coordinators to control receiving and storage. Collins station has no material coordinator.
Little assistance in material handlins is available through Company procedures.
c-N k ndfr.sen O Udih COITIONVEALTH EDISON COMPANY beenon PLANNING AITD CONTROLS REVIEW CONSTRUCTION MEMORANDUM FOR THE FILES _
3 . '
Prepared by: J. Knoll A. Burgess M. Thran April 22, 1977
Subject:
Interview with Al Kief, Administrative Assistant LaSalle County Station Enferance -
- 1. The positions and activities for which Al has responsibility are as follows:
i Office Supervisor - J. L. Gorling The six clerks in this area perform the following tasks:
- Print Control (reviewed by the Q.A. Department).
- Files, including Specifications, Purchase Order and General files
- Telephones / receptionist / mail opening and date stamping.
- Mail routing and delivery, atten. dance and timekeeping and overtime report preparation.
- General and contract administration related typing.
- Steno for the site superintendent and project manager and maintenance of superintendent's files.
Material Receiving Coordinator - C. H. Lenth.
Responsible for receiving and monitoring of Edison materials. This function deals primarily with Q.A. re-lated material's. . .
i Assistant Plannef - E. G. Otto This function is responsible for invoice clerical
- checking and processing, maintenance of purchase order files, maintenance of control cards tracing: for payments and changes, and for control and monitor of; change order proposals.
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.b Site Accountant - R. M. Shuer The Site Accountant is closely linked to the Construction Scheduling and Cost Control Departnent and is primarily responsible for providing necessary data for that system. ,
i 2. A1' indicated that lack of Station Construction I participation in final field contract negotiations has created some problems for the field in contract interpretation for payment and in, instructing vendors in administrative requirements. LaSalle Station is pre-paring a modified version of the contractor instruction book prepared by Maywood to aid in communication of administrative requirements to vendors.
, 3 LaSalle has no formal training programs for any of the administrative activities. However, several neet-ings have been held to provide ~ review and discuss the various activities and provide an understanding of over-
. all site activity for the Edison field office personnel.
- 4. LaSalle Station has no formal procedures relating specifically to the station. They do have appropriate General Procedures and the Station Construction Depart-ment Field Procedures (Greenbook)'and will receive the Station Construction Administrative Procedures when completed. They also have prepared numerous memos and instructions for such administrative activities as l . drawings and document control, receiving, security and l handling of audit memos.
i 5 The positions.of material coordinator and site accountant have been recently established at laSalle.
LaSalle does not perform site purchasing as do Byron and Braidwood. .
- 6. The material receiving activity is responsible for receipt and tracking of equipment and material ordered on Edison purchase orders. A procedure has been estab-lished for receiving, inspection, storage, and paperwork control for all Q.A. related items. Engineering is responsible for defining storage requirements. Con-
. tractors are responsible for receipt and control of f their own material.
I' 7 Control over drawings is well established. A central ~ file is maintained, usually with several copies of a drawing. Engineers check out drawings, and if a revision comes in the file clerk notifies all engineers who have checked out the previous version.
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_ _ _ _ _ _ _ _ . . _ _ _ - - . _ * *-_ *****"**o *CP* *_ Oo = - o -----~ - _ - - - - -
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- 1 When a drawing comes in, the transmittel lotter is routed to the engineers involved. Procedures do not call for review of drawings by the en5 neers, i which L
would be impractical due to ,the high volume.
- 8. Scrap is disposed of by C.E.Co. , not by the con-tractors, fo11owin5 normal company procedures.
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- 9. Field chan5es ,on cost plus centracts are not i estimated by C.E.Co. en5 ineers, due to the volume. The i
contractor is relied on to estimate the impact of i -
changes and include it in his best estimate of contract cost, which is required as part of his cost reports. The contractor's estimate is the basis for preparin5 the monthly company records only CR that is used to update commitments in FMS.
- 10. Authority and responsibility for settlement of claims is somewhat nebalous. . Site personnel feel that they don't have authority to settle a claim, but the definition of what constitutes a claim, especially for cost plus contracts, is not clear. Most items which might become considered claims can be settled by a CR and are small enough to be approved at the site.
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. COMMONWEALTH EDISON CCMPANY PIANNING AND CONTROLS REVLW CONSTRUCTION ,
MEMORANDUM FOR THE FTT E Prepared by: J. McAnally M. Thran
, April 25, 1977
Subject:
Interview Vith Mr. Leo Burke Site Project Superintendent LaSalle County Station Eaterence The salient points made by L. Burke are su==arized in this note.
1.
There is a lot of ignorance about the buildin5 trades in C.E.Co. ~Outside of Art Kleinrath, there are no specialists who know how to deal with trade unions.
- 2. The C.E.Co. system of personnel rotation presents continuity problems at a construction site due to it being a different situation then the rest of the-Company. Need people for the duration of the contract they are assigned.
3 The Walsh type contract (cost plus fixed negotiated j
' fee) is the best type of contract for cost-plus dobs.
Morrison, Foley have incentive clauses and it has created a lot of problems on what is in or out of scope when changes occur. Also we tried to put too F many items in the Fee, e.g. supe,rvision.is in the fixed -
portion of Foley's fee. C.E.Co. has to fight to get y adequate supervision. a 4.
Station Construction has been dealt out of contract ne50tiiation by Purchasing. Station Construction does not know what has been bought, Purchasing does not
- understand (technically) what they have bought. e.g.
~ Foley's site computer, P.O. said was to be furnished, but confusion over who was to pay. Purchasing has no accountability after award. ,
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5 Project Manarars There is a great deal of confusion over the role of the Prodect Manager (Bill Donaldson). He is in the Construction Department and reports to my boss.
It is a stranSe situation having my bosses man outside my door all the time. We tolerate because.we do not know what else to do. '
l- Project Mana5er should be independent of any department and work on major problems.
- 6. Qualit,7 Assurance D Staff is too yourg and inexperienced. Creates problems and extra cost. _
'/ . The key success factors in construction projects is meeting the schedule. Cost performance generally follows schedule performance. C.E.Co. builds plants cheaper because it builds them faster.
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ARTHUR ANDERSEN & CO.
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{ October 7, 1977 Mr. Wallace B. Behnke Exusutive Vice President Commonwealth Edison Company One First National Plaza
, Chicago, Illinois 60690
Dear Mr. Behnke:
Our planning and controls review of the Commonwealth Idison Company (Edison) construction activities has now been completed. This letter will summarize our conclusions regarding this area based on our rdview.
Objectives and Scope The overall objective of our work was to evaluate
{ the operating systems and procedures that comprise the management process to determine whether they promote economy and efficiency, and to develop specific recommendations as to where improvements were possible, leaving to you whether the benefits of making such improvements were sufficient to justify their costs. The management process has four components: planning, authorizing (decision making), executing (carrying out the plans) and monitoring (reviewing results to determine where corrective action is necessary).
The scope of the review of construction activities included detailed review of the Station Construction and Transmission & Distribution Construction Departments which have direct responsibility for supervision and management of generating station and transmission and substation construction.
This work included review of the field activities of the Station Construction Department at LaSalle County Station, as well as selected projects involving modification or
?
, expansion of operating generating stations. The Construction
- Scheduling and Cost Control Department (CSCC) which has
- primary responsibility for collection and reporting of cost
- and schedule data for major construction projects was also reviewed in detail as were internal audit activit.ies relating to construction. Construction of distribution facilities as performed by the various operating divisions was not included in this review.
/
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ARTHUR ANDER3EN & Co-fhl Mr. Wallace B. Behnke October 7, 1977 In carrying out their assigned respons[bilities '
I the personnel responsible for construction activi' ties necessarily
'} interact with numerous other company operating departments
- such as Purchasing, Quality Assurance, Environmental Affairs, and the various engineering departments. Although the nature of the interface between these departments and the construction group was considered, the activities of these departments were not included in the scope of the review.
Work Performed Our work, conducted jointly with Edison personnel, was performed in accordance with the detailed work program approved by you. In summary, this included:
- 1. Gathering of selected industry data relating to construction and analysis of Edison performance relative to other companies.
- 2. Review of the current organization involved in C construction.
- 3. Interviews with management personnel at all levels within the organization. .
- 4. Review of current procedures and other documentation describing or supporting activities involved in construction.
- 5. Review and analysis of reports received and generated by personnel involved in construction activities.
l
- 6. Review and analysis of the management process of
] planning, authorization, execution and monitoring.
Findings and Recommendations l
As you know,.the findings and recommendations
- resulting from our work in the construction area were i summarized and presented to Edison's management. A copy
- of the presentation outline is attached.
In summary, our review disclosed that bhsic systems and procedures necessary for economical ahd efficient execution of the. management process are in place and (g operating. Our analysis of available industry data indicated
4 Aarnon Awncasex & Co.
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" Mr . Wall a c e 'a . Behnke. October 7, 1977 that the company generally compares favorably with other utilities in terms of construction cost per kilowatt and ,
- schedule duration. The recent. implementation of the Project i Management System has provided Edison management at all
- levels a valuable tool for monitoring and control of construction a cost and schedule performance. The decentralization of the Station Construction Department has greatly improved the job site controls over co'nstruction. Procedures governing certain detailed construction activities are being expanded and audits of construction expenditures are conducted on an on-going ba. sis.
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Our review did disclose several specific areas where we believe further improvements can be made. Among these are the further definition of uniform procedures for routine construction tasks and the extension of internal auditing to include these procedures after they have been defined, review of CSCC objectives and reporting, implementation of exception reporting, and establishment of training. programs for construction engineers and auditors. ,
.s C.. It was a pleasure to assist you in this important work. If we can.further assist you in any way, please contact uc.
Very truly yours, ARTHUR ANDERSEN & CO.
f-By on H. Knoll AW l
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TYRONE C. FAHNER ATTORNEY GENERAL radcj) .
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STATE OF* ILLINOIS -_; .. ,
TELEPHONE 16o NORTH LA SALLE STREET 's, g , . , I
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May 26, 1982 [MR[. - h gy ~ o r
NUCLEAR REGULATORY COMMISSION In the Matter of: )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-373
) 50-374 LaSalle County Nuclear )
Generating Station, Unit 1 )
and Unit 2 )
Mr. Harold Denton Director of Nuclear Reactor Regulation 9720 Norfolk Avenue Bethesda, Maryland 20814
Dear Mr. Denton:
This office has recently received three reports concerning the procedures for drilled and cored holes at the LaSalle County Nuclear Station, two by Commonwealth Edison Company and one by the NRC Region III staff. Edison's Final Report, dated May 7, 1982, was received May 12. Edison's Report in Response to Amended Petition, concerning rebar damage in the Unit 1 primary contain-ment, dated May 18, 1982, was received May 25. Upon reading Edison's Final Report, I first learned that Region III had sub-mitted its own report on the drilling procedures (No. 50-373/82-21, DETP) to Edison on April 27, 1982. Upon my request, Mr. C.E.Norelius, the Region III Director of Engineering and Technical Progams, fur-nished a copy of the April 27 inspection report. Mr. Norelius advised, however, that "another~ report will be issued which will identify the specific allegations'and our related findings."
(Letter of C. E. Norelius, May 14, 1982) The lack of specificity aqd factual findings in the April 27 report of Region III has thus been acknowledged and hopefully will be corrected. -
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- a Mr. Harold Denton Page Two. *
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This letter is intended to comment on a few questions whi'h c a're raised by Edison's Final Report of May 7, 1982 and which, in the opinion of this office, remain to be addressed in the pending inquiry. In view of Region III's intention to issue another re-port, it is hoped that these questions will also be addressed with specific findings before the investigation is considered " closed."
1.
Edison's Final Report purports to address rebar damage in "all Unit 2 structural elements areas required in 1alloperation."
for Unit Unit'l areas and in those (Page 33) There is no indication on the record thus far that Edison or the NRC staff intends to investigate possible damage to the integrity of Unit 2.
It is obvious that Unit 1 has been reviewed first because of Edison's up schedule.
intention of keeping to its most recently revised start However, we trust that the safety of Unit 2 will also be addressed before the NRC rules on our Section 2.206 request.
- 2. Neither Edison nor Region III has addressed the question of how non-conformance reports were treated in the current investi-gation. At the hearing on March 31, 1982 Edison admitted that two incidents of rebar damage in non-conforming cored passageway holes, which were cited in . affidavit in our original petition, had in fact occurred. (Tfanscript, pp. 62-63.) Yet to date Edison has not reported on:
- a. The procedures for reporting all non-conformances in cored passageway holes.
- b. The total number of non-conformance reports filed with respect to rebar damage in cored passageway holes.
! c. The manner, if any, in which non-conforming cored i
rebar damage was accounted for in the total assess-l ment of rebar damage.
l These questions are not addressed in Section 2.4 of Edison's Final Report. The Final Report reviews only the cored passageway holes which were drilled according to the structural design drawings.
Edison's recent review of cored passageway. rebar damage is based i
entirely on assumptions made at the time the drawings were made, add not on any field verification o_r wri_tten procedure for carrying
' out the instructions 6n the drawings. Yet the record'shows clearly that deviations from the drawings did in fact occur. :
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. o Mr. Harold Denton Page Three. ,
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, 3. The only written control on rebar damage in. cored p'assageway holes was the use of i'nstructional notes on an unknown number of structural design drawings. Edison's Final Report gives (wo examples of such notes, which call for the use of metal de-tectors in two specific instances. (Section 2.4.4) A total of 971 cored passageway. holes have been documented. (Table 2. 4-1)
Edison has not reported on:
v a. The total number of holes for which metal detectors were required in drawing notes, y/ b. How many bars, if any, were assumed to have been damaged in the drilling of such holes.
- c. What, if any, verification procedures were employed by the contractors to ensure that metal detectors were in fact used, and that undesired rebar damage did not in fact occur.
Our concerns a ou the failure to specifically account for
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non-conformances an the ~failiiYe7o expla~1n how tihe use of . metal detectors was actually verified are i reinforced by a mankgement audit on the LaSalle site which was made available to this office a few days ago. In a 1977 review of the planning and controls of Edison's construction activities at the LaSalle County Station, Arthur Andersen & Co. made several recommendations to Edison for improve-ments at the site.* Among the recommended improvements were:
" uniform procedures for routine construction tasks;"
"extensi'on of internal auditing to include these proce-dures;" " implementation of exception reporting;" and
" establishment of training programs for construction engineers and auditors." (Letter from Jon H. Knoll
[Andersen] to Wallace B. Behnke [ Edison] dated 10/7/77)
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- Copies of the cited portions of the Andersen audit are attached to this letter. .
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. 2 Mr. Harold Denton Page Four.
These recommendations stemmed in part from the following f;indings by Arthur Andersen's; auditors:
- a. Because of the way the H. P. Foley contract was written,"C. E. Co. has to. fight to get adequate, supervision." (Document 4 0-V. 301,' Interview with Site Project Superintendent.)
- b. " Quality Assurance. Staff is too young and inex-perienced. Creates problems and extra cost."
(Document 40-V. 301, Interview with Site Project Superintendent. )
- c. "No formal training is available for new engineers.
Experience in construction, estimating, and contract negotiating and administration is gained in the field." (Document 40-IV. 302, Interview with Mechanical Coordinating Engineer.)
- d. " Control over drawings is well established. A central file is maintained . . . . Engineers check out draw-ings, and if a revision comes in the file clerk '
notifies all engineers who have checked out the previous version. When a drawing comes in, the trans-mittal letter is routed to the engineers involved.
Procedures do not call for review of drawings by the engineers, which would be impractical due to the high volume." (Emphasis supplied) (Document 40-V. 300, Inter-view with Administrative Assistant.)
- e. ". . .
not all design chances on large jobs are routed through engineering for approval . . .
[The Administrative Supervisor] was not aware of any effort to verify the required approval process."
(Document 4 0-IV. 303, Interview with Administrative Supervisor.)
Thus deficiencies in personnel training and supervision and in administration were apparent at the LaSalle construction site in 1977. From 1976 to at least_19_80 passageway holes were cored without any, procedure for verifying that the drawings.we,r,e being followed in the field. As late as 1978-79, long after Edison was advised to beef up its training and quality assurance! programs, was ordered by his supervisors to drill non-conforming corea passageway holes. Yet Edison and the Region III inspectors l
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Mr. Harold Denton Page Five.
have continued to rely upon' assumptions that drawing notes were '
ihplemented, that metal detectors were used, and that instructions t'o notch walls for grouted anchor holes necessarily prevented r)bar damage.
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' An explanation of the matters raised in paragraphs 1, 2, and 3 above is necessary to fill in the gaps in the information already presented. Without such an explanation, we still do not know with assurance that all rebar damage has been accounted for. We know only about reported damage from anchor bolt drilling and assumed damage from cored holes located on structural drawings. ~ ~~'-
The contrast between the incomplete controls over drilling under the electrical equipment contract, and the careful supervision and control reported by Edison for the drilling of holes in the primary containment, is striking. Edison's most recent submittal, dated May 18, 1982, describes detailed calculations, written instructions, close field supervision, and complete reporting, with regard to rebar damage in the primary containment.* Such care is not evident with respect to the core drilling in other safety related structures. Thus the need to provide a more thorough analysis of the issues raised here.
It is noteworthy that the May 18th report describes holes cored into the containment walls as varying from l' 5-1/4" to 2' 4-7/8" in depth (at p. 11). On March 31 Edison stated that holes in the primary containment wall were up to 6" in depth. (Transcript, p. 60) 2
g Mr. Harold Denton Page Six.
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} Once the pending inquiry is complete, this office looks forward t
i,o h meeting with_you_tp.
attendance, pursuant dis. cuss invitation to the_ _yp_ur findings, with in extended ourApril consultant by '
your staff!'- ~~ ,
Very truly yours,
& . !'_^ ' _
JUMTH S. GOODIE Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315 Chicago, Illinois 60601 (312) 791-2491)
JSG:bl Enclosures cc: James G. Keppler, Regional Administrator, Region III C. E. Norelius Richard Hoefling Philip P. Steptoe l
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