ML20054H961

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IE Insp Rept 50-483/82-03 on 820426-0507.Noncompliance Noted:Corrective Action Re Damaged Cables in Cabinet RJ160A to Preclude Repetition Not Taken as of 820507.No Documented Training Given to Craft Personnel
ML20054H961
Person / Time
Site: Callaway Ameren icon.png
Issue date: 06/07/1982
From: Hawkins F, Holzmer M, Keg W, Key W, Konklin J, Naidu K, Neisler J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20054H958 List:
References
50-483-82-03, 50-483-82-3, NUDOCS 8206250263
Download: ML20054H961 (32)
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See also: IR 05000483/1982003

Text

{{#Wiki_filter:. U.S. NUCLEAR REGULATORY COMMISSION REGION III Report No. 50-483/82-03(DETP) Docket No. 50-483 License No. CPPR-139 Licensee: Union Electric Company Post Office Box le3 St. Louis, MO 63166 Facility Name: Callaway Plant, Unit 1 Inspection At: Callaway Site, Reform, M0 Inspection Conducted: April 26 to May 7, 1982 Inspectors: k. K f 4 kL ."R."$aidu S/7![2- ' l - I L. b. aw ins d,/7/81 ffh ' 1. M.Ilo b r k!/ 2 [-7-- 1 J. II. Neisler rf Senior Resident In ect , Approved By: J. . 'h lin, Chief _([//[[/ ojects Section 2A Inspection Summary Inspection on April 26 to May 7, 1982 (Report No. 50-483/82-03(DETP)) Areas Inspected: Special announced team assessment of the licensee's Construction Quality Assurance Program, including QA program overview and interfaces, corrective action systems, design change control, material trace- ability of installed structures and components, electrical cable installation, inprocess inspection, and effectiveness of quality control inspectors. This inspection involved a total of 416 inspector-hours onsite, which included 272 hours onsite by four region-based inspectors, 72 hours onsite by the Senior Resident Inspector, and 72 hours onsite by the Team Leader. 8206250263 820615 PDR ADOCK 05000483 O PDR

1 ,

Results: Of the seven major areas assessed, no items of noncompliance or deviations were identified in five areas; one apparent item of noncompliance was identified with examples in the other areas (Section V, Paragraph B - three examples; Section II, Paragraph E - one example). 2

. . . . . _ .. . -. - -_ . - . DETAILS Persons Contacted Union Electric Company (UE) . l

  • D.

F. Schnell, Vice President - Nuclear - *F. D. Field, Manager, Quality Assurance

  • M.

I. Doyne, General Superintendent, Callaway Construction

  • W.

H. Weber, Manager, Nuclear Construction

  • D. W. Capone, Manager, Nuclear Engineering
  • J. N. Kaelin, Saperintendent of Startup
  • W.

H. Stahl, Test Program Coordinator

  • R.

L. Powers, Superintendent, Site QA

  • J.

V. Laux, Supervising Engineer, Construction QA

  • J.

L. Harden, QA Consultant

  • C.

D. Naslund, Consultant to Electrisal Manager

  • C,

J. Plows, QA Consultant 1

  • A.

D. Sassuni, QA Engineer

  • S. M. Hogan, QA Engineer
  • J.

R. Veatch, QA Engineer

  • S. E. Nehrkorn, Administrative Engineer
  • H. W. Millwood, QA Engineer

Daniel International Corporation (DIC)

  • L. R. Smith, Regional Manager
  • H.

J. Starr, Project Manager

  • A.

D. Arnold, P*oject Quality Manager

  • J. R. Cook, Regulatory Quality Manager
  • J. C. Weaver, Project Electrical Manager (DELCON)

R. Gagne, Supervisor, Testing and Turnover J. Hollingsworth, Director of Welder Training C. Farley, Hanger Fab Shop Superintendent C. Wagner, Assistant Supervisor, Storage Warehouse K. Gibbs, Piping Service Supervisor S. Hawkins, Piping Engineer , Hartford Steam Boiler Insurance Company !-

  • H.

J. Potter, Site Lead Authorized Nuclear Inspector C. R. Lang, Authorized Nuclear Inspector i l- A. A. Mcdonald, Authorized Nuclear Inspector l Bechtel Cor.poration i

  • R. W. Bradford, Site Lead Liaison Engineer
  • A.

Mitchell, Lead Electrical Liaison Engineer , 3 i v. - .mm , _ _ - - - ,-.r- r ,-, m . . - . . -e , - , - - -, . ,- - , y.. - - , ,, -e

J NRC Observers (May 7 only)

  • J.'F.

Streeter, Chief, Projects Branch 2, Region III

  • W.

S. Little, Chief, Engineering Inspection' Branch, Region III .

  • Denotes those persons who attended the final exit meeting at.the Callaway

Site on May 7, 1982. .During the two-week assessment at the site, preliminary exit meetings were held with licensee management on April 28, 30, and May 5, 1982, to discuss findings as they were identified. Other members of the licensee's and contractors' staffs were interviewed during the course of the assessment. ! ! , ! I I 4 t -. Y

_. _ Section I Prepared By: J. E. Konklin C. H. Neisler GENERAL A. Construction Team Assessment - Purpose, Methodology and Conclusions Significant problems have been identified, during the past two years, at several nuclear power plants under construction; problems which have resulted in prolonged shutdowns of work activities in major areas of construction, and which have required substantial changes in the organizations and QA programs of the involved utilities and site con- tractors. In response to those identified problems, NRC Region III established teams to perform assessments of construction activities and QA programs at other nuclear plants under construction, including Callaway, to determine whether similar problems exist at those other sites. The team assessment concept is based on concurrent assessments of selected ongoing functional or program areas by a multi-disciplinary assessment group. The areas selected for these assessments parallel those which were identified as major problem areas at the construc- tion sites discussed above. The specific areas assessed at the ! Callaway Plant included quality assurance program interfaces and overviers, corrective action systems, design change control, material traceability of installed structures and components, electrical cable installa: ion, inprocess inspections, and effectiveness of quality control :nspectors. For the above specific areas, the assigned inspectors reviewed pro- cedures and records, interviewed personnel, and observed work activities to verify that site work is being performed in accordance with NRC re quirements and the licensee's commitments', and that the licensen's 0A program and the site contractors' QA/QC programs are functior ing in a manner to assure that significant discrepancies are promptly identified and properly corrected. Although cne noncompliance with several_ examples, and a number of concerns ce open items, were identified during the construction team assessment at Callaway, the conclusions which result from the assess- ment data documented in this report are that the overall QA program at the Callaway Plant is functioning in a satisfactory manner, and that the plant is being constructed substantially in accordance with l NRC requirements and the licensee's commitments. B. Corrective Action Systems The purpose of the assessment in this area was to determine whether: 5 .. __ . . . . . . _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ a

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1. The corrective action systems are adequate to assure that non- conformances, deficiencies and/or deviations identified during the construction phase of the plant are promptly and properly dispositioned. 2. Responsibilities have been adequately defined and that respon- sibic personnel have received the necessary training to enable them to effectively implement the corrective action systems. 3. Procedures defining the corrective action systems are adequate and are being effectively implemented for tracking and review, closcout, necessary trending of nonconforming conditions, and notification and involvement of appropriate levels of management. The assessment included a review of the procedures which are used to control the activities involved in correction of problems identified during receipt inspection, installation and inprocess inspection,.and final inspection of the completed installation or process, including the actions required to prevent the recurrence of problems. With regcrd to implementation of the corrective action systems, the inspector examined approximately 450 randomly selected nonconformance reports (NCRs), deficiency reports (DRs), and field change requests (FCRs). The specific areas examined included initiation of the reports, review and recommended disposition by the prime contractor's quality and engineering staff, review and approved disposition by the architect / engineer, completed action and closcout of the report, timeliness of the completed action and closcout, and approved actions to preclude recurrence of identified problems. The assessment determined that, in general, nonconformance reports, deficiency reports, and field change requests have been and are being handled in accordance with the established procedures, and that the corrective action systems in effect are adequate to assure the prompt and correct disposition of identified problems. The inspector also examined procedures, practices, and work assignments delineating responsibilities for the initiation, review, disposition, evaluation, closecut, and documentation of identified deficiencies and nonconformances, and for the initiation, review and disposition of field change requests. Discussions with responsible personnel indicated that they had received the necessary orientation and training to discharge their responsibilities as assigned by the corrective actica procedures. The inspector determined that the definition and assignment of respon- sibilities for the control and performance of the corrective action program are adequate to assure that the corrective action system will function in accordance with regulatory requirements and the quality , assurance program. > 6 -,

_ ~ . f l The procedures reviewed above indic.ted the adequacy of the.correc- i tive action systems as defined. Tr4.cking of nonconformanges, ' ' , deficiencies and other elements of the system is provided manually in ) log books as well as on a computeriaed. tracking system. A computer ' printout of all open nonconformance: and deficiencies is distilbuted weekly by the primo contractor to tfa projedd manager, discipline man- ~

agers, quality managers, and to the licensee's organization. Enviews , are performed according to procedura by the Initiator's supprvisor, 1 engineering, the architect engineer andi;.he qu,ality organizavion,. y Copies of all nonconformance report i are sent; to the owner's othan- ' .- ization, and for ASME Code items, ta tho' authorize nuclearifnspector. /s

7 ' The inspector found that closcout c f identified discrepancies has been . .'. , d / ' " generally accomplished in a timely mannar.. The time required to close ' an item was found to depend upon tie syt'ent of the review and evalua- ' tion, and the lead time required to des?gn and/or procure replacer.ent components. Copies of closed reports are returned to the initiator .' l after final disposition. A report is voided in the review process . when it isdeterminedthataproblemdoesnotexistorhasbeenupr- - , rected by the prior disposition of another item. ~ - j , , Trending of nonconforming or defic: ent items is performed in accordance > with approved procedures. Each trend analysis is distributed to the prime contractor's project manager and to the licensee organization for. action and information. Management receives copies of data and trend , ,s ' ' ., analyses pertaining to nonconforming or deficient conditions, for use , " , in determining the adequacy of the corrective action system and for I developing improvements in the system. . ,' /1 ' - The overall corrective action system, including the established / .. procedures, responsibility assignments, and implementation for correc- I a f tion and prevention of nonconformances and deficiencies, appears to be adequate to control or minimize problems at Callaway. No items of noncompliance were identified in this area. / C. Callaway Noncompliance History A review by the inspector of inspection records and Systematic Appraisal of Licensee Performance (SALP) reports showed that the number of noncom- pliances issued at Callaway is average for facilities under construction in Region III. During the past eighteen months, the majority of the noncompliances have been issued in the electrical a ea. The licensee is aware of this trend and has taken steps to increase staffing in the quality assurance and construction engineering groups to provide more effective control of electrical construction activities. - > The review indicated that the licensee's responses to nancompliances have been timely and the corrective actions initiated to prevent recurrence have normally been effective. ~ ' , , 7 , $

. . -.. - . . . - . -.- -- . . _ _ _ _ ._ _ - /r e > y There have been no civil penalties or enforcement actions against the licensee during the past three years. The licensee generally shows a s -' willingness to comply with NRC regulations and to the codes and stand- . . ards committed to in the Callaway Safety Analysis Report. D. ' Licensee's Evaluation of Construction Problems at Other Sites . j - A'R'egion III letter, dated December 17, 1981, from J. G. Keppler to licenseen, on the subject of quality assurance problems identified ' -at nuclear plants under construction, transmitted for information a ' number of documents relating to those problems. During this assess- ment the inspector discussed with Union Electric QA management personnel the actions which have been taken by the licensee and the , ' - SNUPPS organization to evaluate the information transmitted by the above Region III letter. . ! ~ Based partly on the information received from the NRC and partly on information received from other sources regarding the same construc- ' ' tion problem areas, the SNUPPS QA Committee, the SNUPPS utilities, and the SNUPPS staff have performed evaluations of the SNUPPS audit program and design assurance activities, including the review of key - design features and design documents and the planning of additional audits of the A/E, NSSS and other vendor design related activitics. As a result of the discussions in this area with the licensee and the ' review of portinent documents, the inspector concluded that adequate evaluations of the construction problems at other sites are being performed, and that appropriate actions are underway or planned to minimize the likelihood of similar problems at Callaway. . . N [ 8 - h -eno-' - v -- 4 y -. a m ,y + - e - m-

i l - . Section II Prepared By: M. M. Holzmer i QA Program Interfaces and Overview A. Assessment Purpose and Approach The purpose of the assessment in this area was to verify that the licensee's overall QA Program is in accordance with NRC requirements and licensee commitments and has been approved by NRC; that the QA programs of all site contractors have been evaluated for consistency with the approved program and are routinely audited to ensure con- tinued consistency; that the licensee has control of changes to the l approved program; that the licensee's QA Program provides for effective control and oversight of contractor activities; that the QA organizations of the licensee and major site contractors are adequately staffed; that effective audit and trend ans!vsis programs are included in the licensee's QA Program; and that periodic assess- ments of the QA Program are conducted by the licensee's upper management. In performing the assessment, the inspector reviewed the applicable Callaway FSAR sections, QA Program manuals, and procedures; discussed impicmentation of the program with licensee and contractor personnel; reviewed organization charts and staffing plans, trend analyses, audit reports, nonconformance documentation, and inspected selected work activities to verify specific aspects of program implementation. B. Review of Overall QA Program The inspector reviewed the following major Callaway QA Program docu- ments, and discussed the approval / change status of the documents with the appropriate Union Electric and Daniel International personnel. 1. SNUPPS QA Program for Design and Construction, Revision 04, dated December 1981. 2. SNUPPS QA Manual, latest Revision.

3. SNUPPS Administrative Control Procedure (ACP) 3.3, Revision of the Standard Plant PSAR, FSAR, Site Addenda, and Environmental Reports, Revision 6, dated March 1981. 4. Union Electric Procedure QA-16, Preparation, Review and Approval of Revisions to the QA Program for Design and Construction, Revision 0, dated September 1981. 5. SNUPPS PSAR, Chapters 17.0 and 17.1. . 9 . .. . . . .. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

- - - - . _ _ - - .- -. .- - _ - - _ . _ _ - - - _.- - _

, ! The inspector verified that the licensee's QA Program for Design and ' Construction (QAP D&C) is approved by NRC, and that the licensee effec-

tively controls changes to the QAP D&C by procedure. The inspector

i also verified that selected portions of the licensee's QA Manual are consistent with the QAP D&C, that the applicant has prime responsi- bility for executing the QA program and that upper levels of management , are aware of this and have issued an appropriate policy statement in i ! j support of the QA program. In addition, the inspector determined that ! the licensee's and the constructor's QA staffs are sufficiently inde- ' < pendent of cost and schedule, and that QA has the requisite authority to stop work. 4 C. Review of QA Staffing , The inspector reviewed the licensee's present organization and staffing plan relative to the QA function. The review indicated that the licensee's present QA staff is minimal with regard to maintaining an effective overview of site activities. There are presently 12 auditors in the Union Electric QA organization; the licensee is actively r recruiting additional auditors to increase the number. The need for j additional QA personnel has been previously pointed out in the SALP-2 management meeting on April 14, 1982, between Region III and Union 1 Electric. The licensee has provided information regarding the QA I staffing plans in a letter to Region III, dated May 4, 1982; therefore, no further response is requested on this matter. D. Licensee Oversight of Contractor Activities j The inspector assessed the effectiveness of the licensee's QA oversight of site contractors' activities, including the scheduling and perform- 1 ance of audits and surveillances, and the adequacy and timeliness of 1 responses. The inspector also assessed the effectiveness of the various corrective action systems and the interfaces between the various onsite and offsite organizations. i i In performing the assessments, the inspector reviewed applicable pro- cedures relating to audit and surveillance activities, QA audit schedules for 1981 and 1982, selected Construction QA activity reports, and approximately 60 Deficiency Reports, Field Change Requests, Noncon- ' formanco Reports, and Requests for Clarification of Information. In ! addition, the inspector discussed interface relationships with Union l Electric, Daniel, and other site contractor personnel, l The reviews and discussions indicated the existence of difficulties ! 1 and inefficiencies in the interface relationships between various ' onsite and offsite organizational units. Some examples of apparent ! interface problems are discussed below: I , 1. Inadequate Responses to RCIs ! ! Approximately 50 Requests for Clarification of Information (RCIs) l initiated by DELCON, the electrical contractor (a subsidiary of , 10 - . , . - _ . . .. , - - - - . .--- -. - -- - - - . _ , - , - .

Daniel), were reviewed by the inspector for adequacy of response. Eleven RCIs were selected by the inspector for the purpose of verifying that the questions were answered to the originators' satisfaction. Five of the responses were considered by the originators to be unsatisfactory. Three of these have been resolved by other means and two have yet to be resolved. Conversations with DELCON personnel indicated that the responses to most RCIs that were handled by Bechtel's site personnel have been adequate. In addition, RCIs which were submitted following telephone discussions were promptly handled to the originators' satisfaction. However, the responses from Bechtel's staff in Gaithersburg, Maryland, were cited by Daniel personnel to be frequently unsatisfactory. 2. Clarification of Cable Separation Requirements An FCR issued in September 1981, requested a specification revision to eliminate an apparent separation problem between Class 1E and non-Class 1E cables in specific Reactor Protection System cabinets. Bechtel rejected the FCR in October 1981, on the basis that safety related and non-safety related cables may be in close contact in the cabinets in question (SB037, 038, 041 and 041), as allowed by the FSAR. DELCON continued work in the cabinets on that basis. In January and February 1982, Daniel QC issued three Deficiency Reports for cable separation requirements violations in Cabinet SB037 and three other cabinets. Additional Deficiency Reports and a Nonconformance Report have since been issued on this matter. Because of ineffective interfacing between DELCON and Bechtel, there has not been a resolution of the matter for over seven months, while DELCON has continued work in this area in spite of possible separation problems. 3. Identification of Cut Cable Site procedures require QC verification to assure that, for cut cables, the reel number from which a cable is cut is the same as the reel number which is listed in the cable pull records. For some safety related cables cut from reels and shipped to a vendor for installation of connections, the QC verification was not performed prior to shipment. Although the cable can be identified as safety related, traceability to specific reels was lost. This situation was an example of inadequate interfacing between the involved site groups. The above three examples of interface problems are not in noncompliance with NRC requirements or licensee commitments; however, these examples and the numerous comments made by licensee and site contractor personnel regarding interface difficulties, indicate that increased attention should be given to this area by Union Electric. This is co;sidered to be an open item (50-483/82-03-01). A written response is aquested from the licensee. 11

E. Review of Licensee's Audit Program The inspector reviewed the applicable procedures, audit schedules, and audit reports, and verified that the licensee has approved and periodically audits the QA programs of the architect engineers, the constructor, and vendors and contractors for consistency with 10 CFR 50, Appendix B requirements. The inspector verified that the audits were conducted using an approved audit plan and that corrective actions were promptly taken. The closcout of open items by the auditing organization was also reviewed. In addition, the inspector verified that management assessment audits of UE's QA program are periodically conducted, that appropriate corrective action is taken by QA to prevent recurrence of deficiencies, and that these audit reports are routinely disseminated to the highest level of the licensee's management. The documents reviewed included the following: 1. QA-106, Audits, Revision 9, dated December 1981. 2. QA Manual Chapter 13.0, Audit and Surveillance, Revision 4, dated May 1975. 3. QS-3, Surveillance, Revision 3, dated March 1982. 4. Various QA Audit files of Daniel (DIC) from June 1981 to April 1982. 5. Management Audits and QA responses for 1979, 1980, and 1981. During review of the audit files, the inspector found a number of cases in whichifollowup and closcout actions on audit findings have not been accomplished in a timely manner.\\ There were more than 150 audit findings which had not been closed out at the time of this in- spection. Selected examples of failure to followup on audit findings , in a timely manner are given below: 1. Eleven findings were identified in a November 1981 audit report. DIC responded to each of these items wi+.hin 30 days as required. At the time of the inspection, only seven of these responses had been reviewed by UE QA, and no formal closcout of the items had been made. The remainder of the items had not been reviewed. Conversations with the audit team leader indicated a lack.of emphasis on the importance of prompt audit finding followup. 2. Audit Finding 9/81-04 had been responded to by DIC, with a scheduled completion date of 3/15/82. At the time of the inspection this item had not been closed out. Conversation with the auditor indicated that he was aware that the action required was overdue, but that he was tracking the matter on his own. The above examples of failure to take timely corrective actions are considered to be in noncompliance with Criterion XVI of 10 CFR 50, Appendix B and, as such, are included as part of the noncompliance cited in Section V, Paragraph B of this report (50-483/82-03-02). 12

In reviewing the UE audit program, the inspector found that, although the audit program is planned and scheduled, there is no similar planned method or program for scheduling surveillance activities by the UE QA auditors. Approximately 25-30 surveillances por month are conducted by the UE QA staff. A list of these is issued in the monthly report of construction activities. These surveillances are mostly reactive; i.e., they are normally used to devote QA attention to matters which are identified by other methods. During discussions on this subject, licensee personnel agreed that, although much of the surveillance activity is reactive in nature, a planned approach should be documented for the overall surveillance program. This is considered to be an open item (50-483/82-03-03) for which a written response is requested. F. Review of Licensee's Trend Analysis Program The trend analysis system was assessed for types of input, input evaluations, format and content of reports, management levels to which the reports are disseminated, and the corrective actions taken on adverse trends. The inspector reviewed the applicable procedure and the four most recent quarterly trend analysis reports, and inter- viewed the engineer responsible for the reports. The specific j documents reviewed included the following: ' 1. AP-VII-07, Nonconformance Trend Analysis, Revision 1 February 16, 1979. 2. Trend Analysis Reports No. 19, 20, 21, 22. The inspector discussed the following concerns regarding the trend analysis system with the licensee: 1. The trend analysis reports do not always indicate that past report results have been considered, or make clear whether an identified adverse trend applies to on*r one discipline, or to all disciplines. In addition, the c .oria for determining whether a trend is adverse are not cicarly defined. As an example, in Report No. 19, the piping and electrical disciplines were noted as having the most significant problems; in Report No. 20, the piping discipline was identified as having an-adverse trend; in Report No. 21, a significant increase in the mechanical and electrical areas was indicated; and in Report No. 22, although an adverse trend had been identified for more than six months, it was noted that there was an overall acceptable level of deficiencies except for increases in the electrical area. 2. The time required for the dispositioning of nonconformance. reports and deficiency reports has been identified as an adverse trend for more than a year. Procedure AP-VII-07, Section 4.1.4, requires the DIC Project Manager to review the Trend Analysis Report and to implement cc.rective actions. Discussions with the DIC Project Manager indicate that, although some actions have been taken in 13

--_ _ - _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ an attempt to decrease the disposition times of NCRs and DRs, th'e , increased number of reported deficiencies as the plant. construction increases in complexity will make reductions in disposition times- difficult to achieve. The above two concerns are considered to be an open. item (50-483/82-03-04). The licensee is requested to provide a written response which discusses the actions being taken to ensure that the noted trend analysis reporting deficiencies are corrected, and to decrease the disposition times for NCRs and DRs. Other than as noted in Paragraph E above, no noncompliances were identified in the QA Overview and Interfaces area of the assessment. '14

Section III Prepared By: W. J. Key A. Material Traceability of Installed Structures and Components The purpose of the assessment in this area was to verify that the material traceability of installed structures and components is in accordance with NRC requirements and licensee commitments. In con- ducting the assessment, the inspector reviewed applicable specifications, procedures, and records, and performed inspections of weld material control at the job locations. In addition, the inspector traced selected materials and components through purchasing, receipt and installation to verify that material traceability is maintained. 1. Review of Specifications and Procedures The inspector reviewed the following applicable specifications and procedures to the requirements of 10 CFR 50, Appendix B and the ASME Code, Sections III, V, and IX. a. Specification No. 10466-M-204(Q), Revision 30, Field Fabrication and Installation of Piping and Pipe Supports to ASME Section III, for the Standardized Nuclear Unit Power Plant System (SNUPPS), which incorporates the following codes and standards: (1) ASME Section II, Material Specifications, 1974 and Summer, 1975 Addenda. (2) ASME Section III, 1974, Summer 1975 Addenda. Installation of Parts, NA-1280. (3) ASME Section IX, Welding Qualifications, 1974, Summer 1975 Addenda. -(4) ANSI Standards N45.2.2, N45.2.3, and N45.2.6. b. Specification No. 10466-M-206(Q), Revision 12, " Preassembled Pipe and Equipment Formations to ASME Section III." c. Specification No. 16466-M-208B(Q), Revision 6, Purchase of Piping 2" and Smaller to ASME Section III. d. Specification No. 10466-C122(Q), Revision 11, Technical Specification for Contract for Erection of Structural Steel for the Standardized Nuclear Unit Power Plant System (SNUPPS), which incorporates the following codes and standards: 15

. - . J ' 1 (1) AISC Code for Buildings and Bridges, dated October 1972. (2) AISC Code for Design, Fabrication and Erection of Structural Steel Buildings, dated February 12, 1969, with Supplements Nos. 1, 2 and 3. (3) AISC Specification for Structural Joints Using ASTM A325/A490 Bolts, May 8, 1974. , (4) AISC Manual of Steel Construction, 1974, t (5) ANSI B46.1-62, Surface Texture, 1971. (6) ASTM E94-68, (1974) Recommended Practice for Radiographic Examination. (7) AWS D1.1-75, Structural Welding Code. (8) AWS-5.20-69, Specification for Mild Steel Electrode for Flux Cored Arc Welding. (9) ANSI Standards N45.2.2, N45.2.6, N45.2.3, and N45.2.5. (10) Structural and bolting materials ASTM-A36, ASTM-325, ASTM-490, ASTM-A-307, ASTM-A-606, ASTM-A-569, and ASTM-A-570. e. Specification No. 10466-C131(Q), Revision 12,' Technical Specification for Purchase of Miscellaneous Metal for the Standard Nuclear Unit Power Plant System (SNUPPS). i f. Specification No. 10466-C121(Q), Revision 13, Technical Specification for Purchase of Structural Steel.

g. Work Procedure WP-503, Revision 15, Control of Welding Consumables. h. Administrative Procedure AP-1X07, Material Issue. 1. Quality Control Procedure QCP-503, Monitoring of the Control of Welding Consumables. No items of noncompliance were identified in the review. 2. Control of Welding Materials Welding materials in the Storage Warehouse, Auxiliary Building issue room, Containment Building issue, and Fab Shop issue were examined by the inspector. Materials are issued from the Storage Warehouse to the field issue stations on request from designated welding engineers. As containers are opened at the issue stations, they are placed in controlled ovent, if required, and. issued to authorized welders on F-100 forms. Paterials are 16 . ,,n, - . ,v -. m- a, w - . - - ~ -..e.- ,,. ~ w .- .

._ . . . - - issued in portable heaters, when required, and only one type of material is issued at a time, as required by procedure and travelers. There are no baking ovens at the site; any damaged electrodes are either destroyed or sent to the welder training facilities located outside the concrolled area. -Temperatures of the holding ovens at the issue stations and the portable ovens are checked and recorded in accordance with procedures. The following welding materials were selected from travelers, storage, and issue stations, and traced back to the purchase orders. Selected receipt inspection reports and material control reports were also reviewed. Assigned AWS Heat Lot Number Number Size Number Number Purchase Order WE 42 ER 308 1/16" 482584 7186-SR-60001 WE 44 ER 308 3/32" 481771 7186-SR-60001 WE 46 ER 308 1/8" 482526 7186-SR-60001 l WE 52 E70S-2 1/8" 065150 7186-SR-57001 WE 116 E705-2 1/8" 065303 7186-SR-57931 WE 123 E7018 1/8" 401K7251 20018T03 7186-SR-57946 WE 124 E7018 3/32" 402K3461 20027Q02 7186-SR-57946 WE 125 E7018 3/32" 421K0681 2F025Q01 7186-SR-57946 WE 134 E70S-2 1/8" 402N5941 7186-SR-57961 WE 139 E70T-1 .045 H6233 7186-SR-57971 ' WE 139 - Receipt Inspection Report (RIR) No. 73197 WE 125 - Receipt Inspection Report (RIR) No. 73197 WE 124/123 - Receipt Inspection Report (RIR) No. 69369 WE 137 - Receipt Inspection Report (RIR) No. 92076 WE 79 - Material Control Report (MCR) 31331 WE 73 - Material Control Report (MCR) 32312A WE 77 - Material Control Report (MCR) 33272 No items of noncompliance were identified relative to the control of welding materials. 3. Material Traceability (Small-Bore Pipe) In order to confirm traceability of installed and in process small bore piping the inspector randomly selected systems, drawings, and purchase orders and compared the in process or installed materials with receipt inspection reports and material ' test reports to confirm that specification requirements were being met. Components from the systems listed below were selected, a. Essential Service Water System b. Reactor Coolant System i , 17 _ _ _

c. Residual Heat Removal System d. Main Steam Drain and Service Gas (N2) System e. Steam Generator Instrument Connections Listed below are examples of materials selected for examination. a. Valve No. V123 joined to pipe spool No. C08 by field weld (FW) 008 in the "B" train supply of the Essential Service Water System, as shown on Drawing No. M-DM-DSEF04(Q), Revision 3, and ordered on Purchase Orders M-231A; M-208B. h. Valve No. 412 joined to pipe spool No. PC017 by field weld (FW) 018 in the Reactor Coolant System Emergency Letdown. Shown on Drawing No. M-DM-0SB-16(Q), Revision 4, and ordered on Purchase Orders M-240; M-208A. c. Valve No. 086 joined to pipe spool No. SP002 by field weld (FW) 004 in the Residual Heat Removal System of the reactor building; shown on drawing No. M-0SEJ04IQ), Revision 6, and ordered on Purchase Order M-208A; M-231B. d. Pipe spool PC096 joined to pc3/sp023 by Field Weld (FW) 3 in the Main Steam Drain and Service Gas (N2) System of the auxiliary building; shown on Drawing No. M-DM-0SAB08(Q), Revision 7, and ordered on Purchase Order M-208A; M-208B. c. Pipe spool PC001 joined to valve ABV 0201, spool 001/262, by field weld (FW) 001-SG-A in the steam generator instru- mentation connection in the reactor building; shown on Drawing No. M-DM-05AE09(Q), Revision 2, and ordered on Purchase Order No. M-208A, M-231B. No items of noncompliance were identified relative to material traceability of small-bore pipe. 4. Material Traceability (Structural Steel) To confirm traceability of structural materials, random samples of hanger supports, pipe supports, component supports, and support plates in systems in the reactor building and auxiliary building were selected and traced to purchase orders, material test reports, drawings, and receipt inspection reports. Items from the systems listed below were selected by the inspector. a. Chemical and Volume Control System (CVCS) b. Chemical and Volume Control, Reactor Coolant Pump Seal Water Return and Excess Letdown c. Residual Heat Removal System 18

. d. Containment Spray System e. Essential Service Water System f. Reactor Coolant Pump Support Examples of items and components-selected from the identified systems are listed below. a. Support Plate LP737, Heat No. 803J77310, identified on Drawing No. M-D0-BG30-R507/132(Q), Revision 0; Purchase Order No. M-216. b. Pipe Support Pc 2-EJ04-R018/23(Q) in the Residual Heat Removal System, S/11-3-4 Heat No. 172K476, on Drawing No, M-D0-EJ04, Revision 0, Purchase Order No. 177715. c. Pipe support tube 811WO5220 in the CVCS on Drawing No. BG25-C534/231Q, Purchase Order No. M-216Q. d. Pipe Support EN05-C001 in the Containment Spray System, on Drawing No. M-D-2EN05-C001/231Q, Purchase Order No. M-216Q. c. Pipe support and sway strut beam No. 2EF02-R006/142Q in the Essential Service Water "A" Train Supply, Drawing No. M-D0-EF02-R006/142Q, Purchase Order No. 66001/M-218B-2. f. Westinghouse supplied reactor coolant pump column support assembly Serial No. 1067, Purchase Order No. 263751. g. Support plate No. 803J77310 in the CVCS minimum charging flow, shown on Drawing No. M-DO-BG01-C510/132Q, Revision 0, Purchase Order No. 66001. No items of noncompliance were identified relative to traceability of structural steel. 5. Conclusion Based on the abovenoted reviews of specifications and procedures, inspections of weld material control, and tracing of selected materials and components, the inspector concluded that the speci- ~ fications include the required codes and standards; that receipt, storage, and issue of welding materials are controlled and are in accordance with approved procedures; and material traceability is adequately maintained in the areas of piping and-structural steel. B. In-Process Inspections The purpose of the assessment in this area was to verify that the in process inspection procedures are adequate, that the inspection personnel are. qualified and the inspection procedures are being 19 ,

i . properly implemented. In performing the assessment, the inspector reviewed NDE procedures, welding procedures and procedure qualifica- tions, inspection personnel qualification records, and welder qualification records. 1. Non-Destructive Examination (NDE) Procedures Review The following Daniels NDE procedures were reviewed to meet the requirements of the ASME Code Sections III and V, and the require- ments of ASNT-TC-1A and 10 CFR 50, Appendix B, Criteria IX and X. a. NDE-7.1Q, Revision 4, Certification of NDE Personnel, b. NDE-7.3C, Revision 5, Liquid Penetrant Examination - ASME/ ANSI /AWS Codes. c. NDE-7.4A, Revision 4, Magnetic Particle Examination. d. NDE-7.5W, Revision 2, Radiographic Examination of Weldments, e. NDE-7.6, Revision 2, Ultrasonic Examination, ASME, including (1) 7.6 N, Revision 0, Ultrasonic Thickness Examination. (2) 7.6 TM, Revision 1, Ultrasonic Examination of Plate for Special Application. (3) 7.6 W, Ultrasonic Examination of Weldments. (4) 7.6 LW, Revision 1, Ultrasonic Examination of Longitudinal Welds in Pipe. No items of noncompliance were identified. 2. Welding Procedures (WPS) and Procedure Qualification Tests (PQT) The following WPS and PQTs were reviewed for conformance to the requirements of ASME Section IX and AWS D1.1. WPS PWT Welding Process a. N-1-1, Revision 30 59. 60, 61 GMAW, GTAW, SMAW, FCAW Title: Welding of Carbon Steel b. N-1-1-A-6A AWS D1.1 (Prequalified) Fillet c. N-1-3, Revision 6 149, 324 GTAW, SMAW Title: Welding of Carbon S+. eel to Alloy Steel d. N-1-5, Revision 0 262 GTAW, SMAW Title: Welding of Carbon Steel to Iow Alloy Chromium Molybdenum Steel 20

_ ._ -. - _ _ _ _ . ] ] . e. N-1-8, Revision 9 44, 42, 163, GTAW, SMAW j 371, 164 Title: Welding of Carbon Steel to Stainless Steel f. N-1-45, Revision 1 103 GTAW Title: Welding of Carbon Steel P-1 to Nickel Base Alloy P-45 g. N-8-8, Revision 27 335, 53, 94, GTAW 64 Title: Welding of Stainless Steel h. N-8-43, Revision 5 159 GTAW Title: Welding of Stainless Steel (P-8) to Nickel Base

Alloy (P-43) 1. N-8-45, Revision 3 158 GTAW Title: Welding of Stainless Steel (P-8) to Nickel Base Alloy (P-45) j. N-43-43, Revision 4 135, 387 GTAW > Title: Welding of Nickel Base Alloy (P-43) k. N-45-45, Revision 3 148 GTAW , Title: Welding of Nickel Base Alloy (P-45) 1. 1-1-BA, Revision 0 GTAW, SMAW 3 t Title: Combination Arc Welding of Carbon Steel Pipe No items of noncompliance were identified. 3. Review of Related Procedures The inspector also reviewed the following procedures which related in one or more ways to in process inspection requirements or activities:

a. WP-504, Revision 6, Weld Repair. f b. WP-506, Revision 2, Control of Tools Used on Stainless Steel l Plate and Shapes. c. WP-513, Revision 3. Wolder Performance.

' d. WP-514, Revisio'n 0, Delta Ferrite Measurement of Weld Pads, e. WP-502, Revision 13, Qualification of Welders. f. QCP-502, Revision 6, Monitoring of Welder Qualifications. g. QCP-505, Revision 2, Manual Welding Equipment Voltage Surveillance. i 21 i - - - - , --. . , - .. . -- - .._. . . . - . . . . . -- -. - - - - -

h. QCP-507, Revision 6, Inspection of Structural and Miscellaneous Safety Related Welding. 1. QCP-508, Revision 8, Visual Inspection of Welds. J. QCP-200, Revision 13, Inspection of Fabrication and Installation of Piping and Component Supports. k. WP-200, Revision 17, Field Fabrication and Installation of Piping and Component Supports. 1. WP-205, Revision 15, Preparation and Processing of Travelers. No items of noncompliance were identified. 4. Inspection Personnel Qualifications and Training Inspection Personnel Qualification Record Review The inspector reviewed the qualification and training records for eleven Daniels QC personnel, (ten level II and one trainee). From the review of inspection personnel records, observation of training facilities, and discussions, the inspector determined that inspection personnel are being trained to meet the require- ments of ANSI N45.2.6 and ASNT-TC-1A, and that procedures for accomplishing work activities are understood by the inspection personnel. The review indicated that there has been a significant increase in the number of inspection QC personnel hired in the past 6-12 months, and that many of the personnel are still in training, both ;1assroom and on the job training, for the various IcVels and disciplines. N: items of noncompliance were identified. 5. Welder Qualification Records (W-103) Review The inspector reviewed the welder qualifications for 23 welders. From the review of welder qualification records, welder training and qualification facilities, and hanger, structural, and pipe fabrication shop activities, the inspector determined that the welders are being adequately trained and qualified to meet the requirements of ASME Code, Section IX and AWS D1.1. Welder qualifications are maintained on a computer printout which identifies the process, procedure, and date last used. The welding engineers are supplied with the latest printout and are able to determine when a welder's qualifications are approaching the renewal date for requalification in a process. No items of noacompliance were identified. 22

6. Conclusions Based on the review of applicable procedures and qualification records, the inspector concluded that in-process inspection activities in the areas investigated are being conducted in ac- cordance with adequate procedures and are being properly recorded; that inspector training, qualification and certification meet the requirements of ANSI N45.2.6-and ASNT-TC-1A; and that welder training, qualification, and certification meet the ASME Code Section IX and AWS DI.1 requirements. C. ASME Code Interface The inspector interviewed the authorized nuclear inspection staff provided by the Hartford Steam Boiler Insurance Company, and dis- cussed the interface between the licensee and the constructor. - Hartford Steam Boiler is contracted by the licensee for ASME Code inspection of f tems and systems that are turned over to the owner and f all under the requirements of ASME Code Section XI, and is also contracted by the constructor for items and systems being installed to the requirements of ASME Code Section III. The discussion elicited the information that there have been instances when hold points established by the authorized nuclear inspector have been bypassed by the constructor. These instances have been handled on a case by case basis and have been documented. When a hold point in a weld has been bypassed, the authorized nuclear inspector has required the complete weld to be cut out and rewelded. In the case of bypassed non-destructive examinations, the authorized nuclear inspector has required a 100% re-examination by the required method. The Region III inspector's review indicated that there is good communi- cation between the involved parties for witnessing and verifying all examinations required by the Code and by the design specifications. The onsite nuclear inspection staff are all qualified in accordance to the requirements of ANSI N626.0. The onsite inspectors are supported by a technical staff located in district offices and corporate offices. Audits and monitoring of the Quality Assurance programs are performed by both the onsite inspectors and the district staff members. No items of noncompliance were identified in this area.

23 l !

. _ -. ! . . Section IV Prepared By: F. C. Hawkins QC Inspector Effectiveness A. Assessment Purpose and Approach The purpose of the assessment in this area was to provide the answers to five basic questions: 1. Are QC inspection procedures well defined? 2. Are QC inspection procedures consistent with QA. Program requirements? 3. Are QC inspectors adequately qualified and certified to perform their assigned tasks? 4. Are QC inspectors free from harassment, intimidation and other undue pressures which would affect their performance? 5. Are QC inspectors routinely waiving hold points or other j inspection requirements? ! The assessment approach in this area was threefold. The first part of the effort involved review of selected procedures associated with the quality control function;-the second part consisted of a review of qualification records for site quality personnel; the third part j involved interviews with quality control personnel and representatives from other site organizations which routinely interface with quality control. B. Procedure Review Selected Daniel International Company (DIC) administrative and quality control procedures were reviewed to assess their adequacy with regard to clarity, conformance to procedure development requirements, and con- sistency with general QA Program requirements. Included in the review were the following DIC administrative procedures: i ' 1. AP-I-02, Revision 12, " Preparation, Review and Approval of Construction Procedures." 2. AP-VII-01, Revision 4, " Selection, Training and Indoctrination of Quality Control Personnel." 3. AP-VII-02, Revision 9, "Nonconformance Control and Reporting." ' 4. AP-VII-03, Revision 7, " Material and Equipment Receiving and Inspection." ' 24

. . . ._ . 5. AP-VII-08, Revision 4, " Corrective Action." , 6. AP-VII-09, Revision 7, " Material and Equipment Storage and j Handling." j 7. AP-VII-11, Revision 2, " Quality Control Surveillance of Project Subcontractors." In addition, five DIC QC procedures were randomly selected for review , from each'of the three major disciplines: Civil, Electrical, and ! Hechanical/ Welding. ! l The inspector found that the procedures which were reviewed provided 4 appropriate guidance within their intended scope, contained functional checklists, and were consistent with general QA Program requirements. C. Qualification Records Review To assess the IcVel of qualification for QC inspectors at the Callaway site, the indoctrination, training and certification records for forty , DIC QC inspectors, two Robert Irsay Co. (RICo) QC inspectors and one Mid South Painting Specialists (MSPS) QC inspector were reviewed. The records were reviewed against the requirements of ANSI N45.2.6 as referenced by the applicable QA program manual of each contractor. I The following table summarized the number of QC inspectors' qualifi- cation records which were reviewed for each contractor.

Records Records Contractor Available Reviewed Requirements DIC 160 40 ANSI N45.2.6-1978 RICo 12 2 ANSI N45.2.6-1973 l MSPS 3 1 ANSI N45.2.6-1973

In each instance, the personnel qualification packages. contained ap- ! propriate records of indoctrination, training, and certification. Each met the intent of ANSI N45.2.6 as endorsed by Regulatory Guide 1.58. D. Personnel Interviews Interviews were conducted with selected quality control, quality < assurance, engineering, and management personnel. Although the i majority of interviews were held with quality control inspectors, it was felt that limited interviews with personnel which routinely inter- face with quality control would be valuable to the assessment. The following table summarizes the interviews which were conducted. , 25 ' i _ _ _ _ _ . _ - _ _ . . . . . _ __ . . - _ _ _ ~ _ -

. Total Personnel Organization Personnel Interviewed UE QA 13 1 UE Nuclear Construction 29 1 DIC QA 6 2 DIC QC 160 18 DIC Engineering 449 2 RICo QC' 12 2 MSPS QC 3 1 The format was similar for each interview. The approach included soliciting each employee's opinion regarding management support, training, stop work authority, inspector harassment or intimidation, adequacy of inspection procedures and checklists, and organizational interfaces. During the interviews the following concerns and observations were elicited. 1. RICo QC inspection personnel do not feel that they have stop work / process authority. Subsequent discussions with UE QA representatives indicated that stop work authority is not formally documented within the RICo quality program. 2. RICo QC inspectors stated that they have been instructed to perform inspections of field welds through paint for installed Category II over Category I IIVAC duct work and support. Items 1 and 2 are considered open and will be reviewed further during a subsequent inspection (50-483/82-03-05). A written response is requested for Items 1 and 2. 3. The interviews elicited three instances of altercations between QC inspectors and crafts personnel. The incidents were clearly isolated, and did not appear to be part of any intentional systematic attempts to harass or intimidate inspectors. Evidence of management involvement in the resolution of each was apparent. Two of the three QC inspectors involved were interviewed and ex- pressed their satisfaction with the resolution of their experiences. The third inspector was no longer employed at Callaway. Documentation regarding the third incident attested to its satisfactory resolution. 4. Good management support exists at all levels within DIC, MSPC, and RICo. 5. Inspection procedures and checklists provide appropriate guidelines and inspection attributes to assure. quality. 6. The specified QC inspection requirements are being met. 7. Training and Indoctrination programs are generally considered by the interviewees to be adequate. 26

8. Interf aces betweer. QC, QA, engineering, and the craf ts are functional. E. Conclusion The results of the procedure review, qualification records review and the personnel interviews indicate that the QC program at Callaway is providing an appropriate level and acceptable quality of inspection. More specifically, the assessment in this area showed that the QC inspection procedures are well defined and are consistent with the QA program requirements; that the QC inspectors are adequately qualified and certified to perform their assigned tasks; that the inspectors are free from harassment, intimidation or other undue pressures except for infrequent, isolated, cases which have been promptly and rigorously corrected; and that the required QC inspection requirements are being routinely met. 27 -

9 Section V Prepared By: K. R. Naidu A. Electrical Cable Installation The purpose of the assessment in this area was to verify that cables have been installed, separated, and routed in accordance with adequate procedures which reflect the~ relevant specifications, and that the cable installation craft and QC personnel have been adequately trained in those activities. In performing the assessment, the inspector reviewed the applicable procedures, observed installed cables, and interviewed selected craft-personnel. 1. The inspector reviewed work Procedures WP 302', WP 303, and- WP 304, QC inspection procedures QCP 302, QCP 303, and QCP 304, and determined that the procedures reflect the requirements of the engineering specifications, Specification E-01013 and Specification E-090. 2. The inspector observed the following cables which were installed in cable trays or conduits: 01NNY01AA, 02NNY01CA, 03NNY01BA,- 04NNY01DA, 01BB15BB, 01BB115AB, 1EJB01AA, IEGB01AA, 4EJB01BA, 4EGB01BA, 01EMG13AA, and 04EMG1313A. The inspector determined that the cables are adequately separated; the routing is as specified in the computer printed cable routing schedule; raceways are inspected to appropriate procedures to verify that each raceway is free of hazards such as sharp edges, burrs and debris; and that the cables are identified at each end and the cable color matches the raceway color identification. 3. The inspector interviewed a QC inspector, two termination craftsmen and two termination engineers, and established from discussions with them that they are knowledgeable in the cable separation requirements. Based on the above procedure reviews, observations, and interviews, the inspector concluded that the electrical cable installation is adequate. No noncompliances were identified in the area of electrical cable installation. B. Inprocess Inspections The-purpose of the assessment in this area was to verify that adequate inprocess inspections were performed during cable installa- tion procedures. The inspector conducted the assessment by reviewing installation records, surveillance reports, and nonconformance reports associated with the cable installation activities. Review of the following typical installation records indicated that inspections were performed. 28

- - _ . 1. Raceway checklists dated January 19, 1982, indicate that the installation of Conduits 1U1071, 1U1072, IU1073, 1U1074, 1U1075, and 1U1076 were inspected and determined to be acceptable. 2. Work assignment WA-CPU-0236 indicates that cables 01BBI15BB,

01BBI15AB, 01BBI15CB, and 01BBI15BB were installed in the race- ways on May 8, 1980. The QC inspector signed the document, and thu QC Level II inspector reviewed and signed the document. 3. Work assignment RA-CTM-0870A, Cable Termination and Jumper Record, indicates that the above cables were terminated during August, 1981. The terminator and the crimp tool used were identified. Review of the following Surveillance Reports (SRs) performed and documented by the Licensee's QA personnel indicated that periodic overview inspections were being performed. Corrective action was ~~~~ not complete at the time of the review. 1. Surveillance Report 2/82-14 dated February 16, 1982, identified the following: a. The height of the cables installed in the cable trays located in the upper and lower spreading rooms and ESF switchgear exceeded the fill limits and was above the top of the side i rail, due to inadequate training during installation. b. 'The cable installation in trays located in the lower cable spreading room was not done in a professional manner. 4 / Examples were edges on the bottom of the vertical tray not covered to protect cables pulled tight against the edges, and minimum bend radius of cables exceeded. c. Installations were not properly protected from damage during construction. 2. Surveillance Report 2/82-19 dated February 25, 1982, identified the following: a. Cables pulled in inclined sections of trays were installed under tension so that cables are above the top of side rails. b. Cables were not adequately tied down and were not pulled in a professional manner. c. Examples were cited of installed instruments and instrument tubing which were not protected against construction activi- ties. Furthermore, air hoses and other construction accessories were observed lying on instrument tubing. 29 . - - - - _ - _ . _ _ - - - -, .- .

The inspector reviewed Deficiency Reports generated by QC inspectors and determined that, in several cases, the causes of nonconformance were not accurately identified, the recommended corrective actions were not appropriate and the corrective actions taken to preclude repetition were not implemented. Examples are: 1. Deficiency Report DR2SD-5234-E indicated that the following cables were damaged in Cabinet RJ160A, installed in the Auxiliary Building at elevation 2026, Area 3. a. Cable 4EGR04DA had insulation on both conductors which adhered tightly and separated with difficulty. b. Cable 4EMR02BA had a cut on the white conductor 5/16" from breakout, and a cut on the black conductor 1/4" from breakout. Cable 4 GLR 14BA had a cut on the black conductor 1/4" from c. breakout. d. Cable 4GSR04AA had a nick on the white conductor 5/16" from breakout. Cable 4GTR06DA had a cut on the white conductor 1/4" from e. breakout. The inspector, accompanied by the licensee and the Daniel QC inspector, verified the above. The inspector concurred with the above findings. Recommended corrective action on the DR was to train the craft personnel. Other DRs which recommended similar corrective action were SD-5461E, SD-4236, SD-5502-E, and SD-4236-E. The latter DRs were initiated on August 20, 1981, and dispositioned on December 14, 1981. The inspector found that no documented formal training has been given to the craft personnel. The inspector informed the licensee that failure to take prompt cor- rective action to preclude repetition is an item of noncompliance contrary to the requirements of 10 CFR 50, Appendix B, Criterion XVI. (50-483/82-03-06). 2. Deficiency Report 2SD-4326-E initiated on September 9, 1981, identified that, in main control panels RL001/RL002, RL005/RL006 in the control room, the field installed cables violated the minimum separation criteria. The recommended corrective action, dated January 4, 1982, was to disposition the DR when the panel manufacturer would be onsite. The inspector interviewed the persons involved with the disposition and established that they did not physically look into the cabinet and determine that the problem was related to the physical routing of cables belonging to Safety Groups 1 and 4 and also non-safety related cables. The inspector informed the licensee that in this instance the cause of the adverse condition was not determined, and that this is contrary to the requirements of 10 CFR 50, Appendix B, Criterion XVI, and is another example of the item of noncompliance identified in the previous paragraph (50-483/82-03-07). 30 t

The inspector asked the licensee why cable installation activi- ties in the control room should be continued while the cable separation problems were still unresolved and training of the craft personnel had still not been accomplished. The licensee decided to discontinue electrical termination activities and cable pulling activities in the control room until the craft personnel were given refresher training on separation criteria. This is confirmed in a letter, UTD QA-1235, dated May 7, 1982. The letter also states that, upon completion of the refresher session, work will resume in the control room areas that do not have design separation concerns. The licensee stated that DIC Engineering would monitor the installation activities and would discontinue installation should separation problems be identified. A visit of UE Nuclear Engineering and possibly the AE was planned during the week of May 10-14, 1982, to review the existing separa- tion problems. The inspector concurred with the proposed action. 3. Deficiency Report SD-5409-E, initiated on February 4, 1982, identifies that eight safety group channel 4 cables, four belonging to the EFE system, and four belonging to the NGH system, were terminated with " incorrect hardware, using field supplied Burndy 2-hole lugs with 1/2" bolt hardware of unknown origin." Cause of deficiency was that the incorrect hardware was intentionally installed to expedite system release. Action to prevent recurrence was " Engineering will clarify, for the field, what material is to be used." The inspector determined from discussions with cognizant personnel that the construction planning was inadequate in that the termination hardware was not selected in advance, approved by cognizant individuals, and procured in time for the installation. Another deficiency report on the subject of termination, DR-2SD-6078-E, was initiated on April 6, 1982, identifying that cables in the Electrical Penetration Room Group 4 digital termina- tion cabinet RJ-160A were terminated with the wrong type of lugs. The terminations on the panel were initiated through Work Assign- ment WA-CTM-1492 dated June 23, 1981. Terminations appeared to have progressed through April 6, 1982 without verification that the wrong type of lugs was used by the cognizant terminations engineering personnel. The inspector noted that corrective action was not taken in a timely manner to correct the nonconforming condition, in that the correct hardware had not been procured several months after WA-CTM-1492 was initiated. The inspector informed the licensee that this is contrary to the requirements of 10 CFR 50, Appendix B, Criterion XVI, and is another example of the item of noncompliance cited above (50-483/82-03-08). 4. The inspector reviewed at least thirty-two NCRs, initiated between June 7, 1981, and March 30, 1982, which indicated discrepancies in the installation of raceway and raceway supports. The cause of nonconformance was cited as craft error. The recommended corrective action was to " instruct craft." As noted previously, above, there was no documentary evidence that the craft were trained. 31 )

_ _ -. . _ _ _ - _ . _ _ . . _ _ _ _ _ _ . . . _ . . . . . C. Design Change Control The purpose of the assessment in this area was.to verify that design ] change control is adequate. The inspector accomplished this by reviewing design drawing changes and by confirming that the initiated drawing changes went through the review cycle and were signed by the , cognizant discipline engineers. Specifically, the inspector reviewed the various Drawing Change Notices (DCNs) associated with revisions to the design of the Piping and Instrumentation Diagrams (P&ID) to verify the proper processing 1 and review cycle. The inspector reviewed the following changes: 1. Revisions 0, 1, 3, 5, 6, 8, 9, and 10 to Drawing M-02EJ01(Q). 2. Revisions 0, 4, and 5 to Drawing M-02EM01(Q). i 3. Revisions 4, 5, 6, and 8 to Drawing M-02EM02(Q). l Signatures on the DCNs indicate that the appropriate discipline engineers reviewed and approved the changes. j No items of noncompliance were identified in this area. Exit Interview The Construction Assessment Team met with licensee management during and at the conclusion of the assessment. Preliminary exit meetings were held on April 28, 30 and May 5, 1982, to discuss the ongoing status of the assessment. The final exit meeting was held on May 7, 1982. The team members summarized the scope and findings of the assessment. The licensee acknowledged the , findings. .* The specific findings or open items, other than noncompliances, for which written replies are requested from Union Electric, are noted in the body of the report (Section II, Paragraphs D, E and F; Section IV, Paragraph D). ! . t i 32 l }}

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