ML20039E988
| ML20039E988 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 12/28/1981 |
| From: | Gardner R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20039E980 | List: |
| References | |
| 50-456-81-14, 50-457-81-14, NUDOCS 8201110693 | |
| Download: ML20039E988 (11) | |
See also: IR 05000456/1981014
Text
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-456/81-14; 50-457/81-14
Docket Nos. 50-456; 50-457
Licenses No. CPPR-132; CPPR-133
Licensee: Commonwealth Edison Company
Post Office Box 767
Chicago, IL 60690
Facility Name: Braidwood Station, Units 1 and 2
Inspection At:
Braidwood Site, Braidwood, IL
Inspection Conducted: November 18-20, 1981
Inspectors: II. N Gardner
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Approved By: F .i
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Plant Systems Section
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Inspection Summary,
Inspection on November 18-20, 1981 (Reports No. 50-456/81-14; 50-457/81-14)
Areas Inspected: Observation of electrical cable termination activities,
observation of installed electrical equipment, observation of post-tension-
ing work and review of records, and observation of quality assurance program
performance. The inspection involved a total of 57 inspector-hours onsite
by three NRC inspectors.
Results: Of the three areas inspected, four items af noncompliance were
identified (failure to ensure that revision to specifications are trans-
lated into construction procedures; failure of manufacturer to install
required separation barriers in main control board panel; failure to take
adequate corrective action for post-tensioning noncompliances; and failure
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to issue inspection instruction for tendon inspection after 90 days).
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DETAILS
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Persons Contacted
, Commonwealth Edison Company (CECO)
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- R. Cosaro, Site Construction Superintendent
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- T. R. Sommerfield, Site QA Superintendent
- C. D. Gray, Project Structural Supervisor
- S. C. Hansader, QA Supervisor
- W. D. Bruns, QA Inspector
- C. Mennecke, Lead Electrical Engineer
- D. A Broca, QA Supervisor
- L. J. Tapella, Project Construction Engineer
- R. C. Schleiter, Administrative Assistant
Napoleon Steel Contractors Incorporated (NSCI)
- C. Zavada, QC Manager
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- T. M. Perala, Project Manager
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- V. Sawyer, Superintendent
- D. Rayka, Project Engineer
L. K. Comstock and Company (LKC)
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- R. A. Brown, Sr., QC Manager
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- L. Facchina, Project Manager
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- J.
A. Hii, Project Engineer
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- Denotes those present at the exit meeting on November 20, 1981.
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Section I
Prepared by R. N. Gardner
Reviewed by F. C. Hawkins, Acting Chief
Plant Systems Section
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1.
Observation of Electrical Cable Termination Activities
The Region III inspector observed the terminations for the
a.
following Class IE electrical cables in the Unit 1 main control
room:
Cable
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1 AP 312
1 AP 083
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1 AP 051
1 AP 050 (3 conductors were inspected)
The inspector verified that the cables were terminated in
accordance with Sargent and Lundy (S&L) wiring diagram 1-4044N,
Revision J.
The cables were observed to be trained into the
equipment without violation of minimum bend radius or separa-
tion criteria.
b.
The Region III inspector determined that the licensee had
purchased two types of electrical terminal lugs, for conductor
sizes smaller than No. 8 AWG, to be used on Class IE cable
terminations. The licensee had purchased " amp terminal" lugs
for use in non-high radiation areas and " amp nuclear terminal"
lugs for use in high radiation areas. Representatives of the
licensee's electrical centractor, L. K. Comstock, stated that
the contractor's electricians were being instructed to use only
the " amp nuclear terminal" lugs in high radiation areas. The
inspector verified that these actions were in accordance with
the latest revision of L. K. Comstock " Cable Termination In-
sta11ation" Procedure No. 4.3.9.
During subsequent discussions with the licensee and S&L repre-
sentatives, the inspector was informed that S&L " Electrical
Installation" Specification 2790A had previously been revised
to incorporate ECN 1359 which deleted the use of " Amp nuclear
terminal" lugs.
L. K. Comstock Procedure No. 4.3.9 had not
been revised to implement this revision to Specification 2790A.
As a result, unapproved terminal lugs were stored in Class IE
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storage facilities and L. K. Comstock electricians were being
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instructed to use these unapproved lugs on Class IE terminations.
This failure to control changes to specifications and procedures
to ensure the use of such changes at the location where the pre-
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scribed activity is being performed is considered an item of non-
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compliance with 10 CFR 50, Appendix B, Criterion VI as described
in Appendix A of the report transmittal letter.
(456/81-14-01;
457/81-14-01)
During the NRC exit meeting on November 20, 1981, the licensee
stated that the following actions had been initiated with regard
to this matter:
(1)
L. K. Comstock Procedure No. 4.3.9 was being revised to
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reflect the terminal lug requirements of S&L Specifica-
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tion 2790A.
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(2)
L. K. Comstock procedures were being reviewed to assure
implementation of current S&L specification requirements.
(3) All unapproved terminal lugs were removed from Class IE
storage to ensure that they will not be used on Class IE
cables.
(4)
L. K. Comstock electricians "ere being instructed in the
identification of approved terminal lugs to be installed
on Class IE cables.
The licensee stated that no unapproved terminal lugs have been
installed on Class 1E cables.
The RIII inspector verified that approved terminal lugs were
installed on all Class IE terminations observed during this
inspection.
During a review of the manufacturer's literature pertaining
c.
to the " amp terminal" lugs now specified for use in all areas
of the plant, the inspector was unable to determine the
acceptability of the lugs for use in hostile environments
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(e.g., high radiation, high temperature). The literature
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indicated that the lug insulating material was composed of
vinyl or plastic.
The Region III inspector contacted NRC Region IV Equipment
Qualification Section personnel on November 23, 1981, concern-
ing the acceptability of the subject lugs for use in hostile
environments. During a conversation on December 7, 1981, the
Region III inspector was informed that the consensus of opinion
within the Region IV Equipment Qualification Section was that
the subject lugs were acceptable. The Region III inspector
has no further questions concerning this matter at this time.
2.
Observation of Installed Electrical Equipment - Main Control Boards
During observation of the internal components and equipment pertaining
to the Units 1 and 2 main control boards, the inspector determined the
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following:
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Paragraph 4.1.5 of Westinghouse Specification 952538, Revision 1,
a.
states that, " Barriers shall be installed between PAM-1 and
PAM-2 indicators to provide separation."
The inspector observed the following examples of the manufac-
turer's failure to install the required separation barriers
between adjacent indicators located on the Westinghouse supplied
main control board panel 1 PM 04J.
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ADJACENT INDICATORS
PARAMETER MONITORED
IPI-524A (PAM-1)
Steam Generator Steam Pressure
IPI-525A (PAM-2)
Steam Generator Steam Pressure
IPI-526A (PAM-1)
Steam Generator Steam Pressure
IPI-534A (PAM-1)
Steam Generator Steam Pressure
1PI-535A (PAM-2)
Steam Generator Steam Pressure
1PI-536A (PAM-1)
Steam Generator Steam Pressure
The subject indicators are identified as being part of the
Post-Accident Monitoring (PAM) system on S&L drawings
20E-1-4049A, Revision E and 20E-1-4049B, Revision E.
Additionally, the inspector cbserved that barriers were not
installed between the corresponding Unit 2 indicators located
on Unit 2 main control board panel 2 PM 04J.
This failure to assure that purchased equipment conforms to
procurement specifications is considered an item of noncom-
pliance with 10 CFR 50, Appendix B, Criterion VII as described
in Appendix A of the report transmitcal letter (456/81-14-02;
457/81-14-02)
b.
Westinghouse Specification 952538, Revision 1, identified four
categories of main control board internal " critical wiring."
The inspector observed that the method developed for identify-
ing the different categories of internal wiring involves the
use of color coded markers which are installed within the main
control board panels. The inspector observed that the separa-
tion of internal wiring within the panels was less than one
inch at some locations. However, the correlation between the
installed color coded markers and the assignment of cables
to " critical wiring" categories was not clear. Westinghouse
Specification 952538 indicates that the internal wiring
separation criteria is dependent upon the assigned " critical
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wiring" category.
This matter is unresolved pending further review by the
inspector of the Westinghouse specifications and drawings
pertaining to internal wiring separation requirements.
(456/81-14-03; 457/81-14-03)
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Section II
Prepared by R. B. Landsman
Reviewed by F. C. Hawkins, Acting Chief
Plant System Section
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1.
Observation of Work _ Activities
Stressing of horizontal tendon No. 35 CB by Napoleon Steel Con-
tractors, Inc., (NSCI) was observed. The inspector verified that
the work was being accomplished in accordance with site procedures.
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All pertinent work and data was being verified by the QC Inspector.
2.
Review of Quality Records
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The following reviews of post-tensioning records were performed to
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verify their completeness and compliance with licensee specifications,
procedures and commitments:
It was determined from a review of gauge records that two
a.
gauges were found to be out of calibration on November 16,
1981.
NSCI corrective action was to send the gauges back to
Inryco for recalibration. However, corrective action was not
taken to identify and cortect any potential deficiency caused
by the use of the gauges. This failure to take proper correc-
tive action with regard to the nonconforming gauges is contrary
to Criterion XVI of 10 CFR 50, Appendix B.
(456/81-14-04) (A)
b.
NCR's were also reviewed to assure that the specified resolutions
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addressed the cause of the nonconforming conditions and that
appropriate corrective actions were taken. During this review,
it was determined that the resolution of NSCI NCR No. 137 was
incomplete.
NCR 137 addressed the fact that dome tendons were not being
stressed according to stressing sequence number 25.
The
specified disposition noted on the NCR was to remove and
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replace a defective tendon. The disposicion did not address
the fact that the stressing sequence was violated. The Region
III inspector determined that this failure to follow the
designated sequence was an isolated case.
This is considered a further example of noncompliance as cited
previously in Section 2., Paragraph 2.a. of this report.
(456/81-14-04) (B)
Through the review of tendon installation records, the inspectors
c.
determined that seventeen tendons had been in place over 180
days without being greased. Tendon installation Specification
L-2722 requires that tendons be greased with in 180 days after
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insertion. Discussions with NSCI personnel indicated that they
misinterpreted the specification requirements.
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This failure to promptly identify and correct nonconforming
conditions is considered a further example of noncompliance
as cited previously in Section 2. , Paragraph 2.a. and 2.b.
of this report.
(456/81-14-04) (C)
As a result of this finding, the NSCI QC Manager issued NCR
No. 167 to identify this nonconforming condition.
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d.
Records of grease shipments were reviewed.
The records con-
tained appropriate documentation verifying that all physical
and chemical requirements were met.
The inspector also re-
viewed the purchaser's onsite test results, as required by
Specification 2721, and determined that they were being pro-
perly performed.
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Section III
Prepared by R. N. Sutphin
Reviewed by J. M. Peschel, Acting Chief
Management Programs Section
1.
Observations of the Quality Assurance Program Performance Relative
to Drawings and Specifications
In the inspection areas covered by Sections 1 and 2 of this report
the inspector found that field drawings and specifications were
maintained under appropriate revision control and were readily
available for reference and use during the work activity. Revision
Control Logs and Records were maintained and up to date. Documents
in the hands of site contractors and sub-contractors were maintained
in an equally acceptable manner. The inspector observed that there
were differing responses from personnel at the site working on con-
tainment post-tensioning as to which document was to be used to control
the work in progress. Letters, drawings, design specifications, and
procurement specifications were identified as controlling documents
by supervisory personnel but they could not assure the inspector that
these were controlled documents traceable to the controlled contain-
ment specifications. This apparent uncertainity as to the identity
and traceability of documents governing containment post tensioning
is considered an Unresolved Item subject to future detailed review.
(456/81-14-05; 457/81-14-04)
2.
Observations of the Quality Assurance Program Performance Relative
to Field Inspections, Measurements and Workmanship
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The inspector witnessed the tensioning of tendon number 35 CB of
the Unit I containment post-tensioning system and the wiring
activity on Units 1 and 2 control boards in the control room, to
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discern if the equipment or systems were being installed / erected
as described by drawings and specifications and that inspections,
measurements and workmanship were receiving appropriate considera-
tion, per quality program requirements. Observations of the work
in process indicated that the work was being accomplished in a
satisfactory manner except for those items identified in Sections
I and 2 of this report, and the inspection of tendons in place
after 90 days without greasing.
S&L Specification L-2722, Revision 14 " Injection of Corresion
Preventive Grease," Section 13-508.2, states in part, "In addition,
each tendon which is not stressed within 90 days after it is in-
stalled in it's sheating, shall be greased within that 90 day
period." ... " Time from initial placement of the tendons to greasing
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may be increased to 180 days, provided a random sample of 10% of
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the tendons are withdrawn monthly between the 90 and 180 day period
and inspected for corrosion. Tendons which show signs of corrosion
during the 90 to 180 day period shall be rejected."
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A review of nonconformance reports and records indicated that this
requirement was known and that some inspections relative to the
potential problem of tendon corrosion were attempted, but with
results that are generally inconclusive and unresponsive to the
requirements.
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The inspector found that over 150 tendons had been installed for 90
days or more without greasing, that an inspection instruction or
procedure had not been written to address the requirements in the
specification for the corrosion inspections, that key aspects of
the requirement had not been defined or documented (i.e., random
sample; 10% of the tendons; withdrawn; monthly; acceptance criteria;
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signs of corrosion; etc.) and that the information provided from
the effort that was undertaken failed to satisfy the inspection
requirement. This is a violation of the inspection criteria of
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10 CFR 50, Appendix B, Criterion X.
(456/81-14-06)
3.
Observations on Field Engineering Activity
The inspector determined that engineering personnel were assigned
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to the site by the licensee and the contractors, independently
of the quality assurance organization, providing direction and
assistance in control of the work.
4.
Observations of Quality Control / Inspection Activities
The inspector reviewed the Quality Control and Inspection Activities
of a contractor at the site, NSCI, and determined that these functions
were being performed in an independent and effective manner with some
overview audits and inspections by licensee personnel. However, find-
ings by the NRC inspectors in the area of corrosion inspection of
tendons, indicates that more information is needed to allow the in-
spector to determine if increased attention to specification and
procedural detailed requirements by the Quality Assurance overview
personnel may be necessary to assure that timely and proper Q.C.
Program Action is accomplished. This is an Unresolved Item subject
to further revies. (456/81-14-07; 457/81-14-05)
5.
Observation of Nonconformance Reports and Corrective Action Activity
The inspector reviewed records and reports relative to nonconformance
reporting and the specified dispositions and corrective actions. The
inspector found that the reporting of nonconforming conditions by
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contractors was acceptable end in an effective and timely manner.
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Conversely, actions taken to address the repair or disposition of
the identified problems and the appropriate corrective actions do
not appear to be as effective, as indicated below:
During a review of NCR's prepared by LKC for the period of time
from August 5, 1981 to October 15, 1981 (NCR's 252 thru 381), it
was determined that one third (33.8%) of the recommended disposi-
tions for similar conduit installation problems was:
"use-as-is,"
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"will not (or does not) affect structural integrity," and (FCR)
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Field Change Request documents were written to refer the problems
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for design review and approvals, etc.
In addition to the above, NCR No. 252 was processed two times.
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was written on August 5, 1981 and processed the first time on
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August 27, 1981 with concurrence signatures on August 28, 1981, and
the second time on September 18, 1981 with concurrence signatures
on September 22, 1981 with essentially the same use-as-is disposi-
tion. Both copies are on file.
The inspector questions whether the "use-as-is" concept, with an
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installation prior to a design review, is consistent with established
Quality Program objectives and considers this an Unresolved Item
subject to further review (456/81-14-08; 457/81-14-06).
6.
Observations on Materials and Equipment Receiving, Inspection and
Use at Site
The inspector briefly reviewed, with various site supervision and
management personnel participating, the general policies and pro-
cedures relating to the procurement, receipt, inspection, control
and use of items at the site.
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The inspector observed that QC, QA, Site Supervision and Management
Personnel frequently suggested or recommended changing specifica-
tions or requirements when conflicts or problems were identified,
as a means of potential resolution of the problems. The inspector
considers the prevailing attitude to change specifications and
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requirements as somewhat adverse to compliance with established
Quality Program objectives and considers this an Unresolved Icem
subject to further review (456/81-14-09; 457/81-14-07).
7.
Observations of Audit Programs
The inspector reviewed the audit program schedules and determined
that audits had been scheduled in April 1981 and October 1981, for
NSIC, the contractor responsible for containment post-tensiening
activities. The April 1981 audit was scheduled to cover QA Manual
Sections 1 through 5 - the entire QA Manual. The October 1981 audit
was scheduled to cover Applicable Procedures for Post-Tensioning
Activities.
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The April 1981 audit report was on file as No. QA-20-81-18, 2722-B.
22A. The October 1981 audit report was on file as No. QA-20-81-31,
2722-B.22A.
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The audit plan covered several areas of the post-tensioning activi-
ties in sufficient detail to be considered an acceptable plan.
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Additionally, Item 21 of the October 1981 audit plan specified:
" Verify that stressed tendons are greased within one week of com-
pletion of stressing," (i.e., seven days). The audit found the
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following:
Tendon
Days to Greasing
D3-1
20
D1-12
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V-118
23
V-120
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V-121
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Someone added a note, in pencil, to the audit report copy:
"one
week or 28 days - Spec." and referenced Specification L-2722, Section
13-508.2.
The original copy of the audit plan had not been changed
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for Item 21.
The added pencil note was not dated or signed and
appears to be contrary to the auditing requirements of ANSI N45.2-1977.
The inspector is concerned about the apparent flexibility in penciled
changes to the audit plan. This is considered an Unresolved Item
subject to further review (456/81-14-10; 457/81-14-08).
Unresolved Items
Unresolved Items are items about which more information is required in
order to ascertain whether they are acceptable items, items of noncom-
pliance or deviations. Unresolved items disclosed during this inspection
are discussed in Section 1, Paragraph 2.b, and Section 3, Parta 1, 4, 5,
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6, and 7.
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Exit Interview
The inspectors met with licensee representatives (denoted in the Persons
Contacted paragraph) at the conclusion of the inspection on November 20,
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1981. The inspectors summarized the scope and findings of the inspection.
The licensee acknowledged the information.
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