ML20055B411
| ML20055B411 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 06/16/1982 |
| From: | Danielson D, Forney W, Keshishian P, Love R, Nightingale E, Peschel J, Wescott H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20055B409 | List: |
| References | |
| 50-454-82-05, 50-454-82-5, 50-455-82-04, 50-455-82-4, NUDOCS 8207220171 | |
| Download: ML20055B411 (74) | |
See also: IR 05000454/1982005
Text
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
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Report Nos. 50-454/82-05(DETP); 50-455/82-04(DETP)
Docket Nos. 50-454; 50-455 License Nos. CPPR-130; CPPR-131
Licensee: Commonwealth Edison Company
P. O. Box 767
Chicago, IL 60690 1
Facility Name: Byron Station, Unit 1 and 2
Inspection At: Byron Site, Byron, IL
Inspection Conducted: March 29-31, April 1-2, 5-9, 12-14, and May 11, 1982.
Inspectors:
.lwin.. i/f~
D. H. D ielson l/ [#'
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//@. M. Peschel d[/4/PL
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R. S. Love S/;2.//9'A.,
W47176baf
H. M. Wescott d' g ,ffa
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I,dE.H. Nightingale
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M9A,aJun
W. Forney
(SRI Byron)
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210 8
shishian 6//4/87__
E Headquarters) '
Approved By:
47 8i A llo-
D. Danielson, Chief 0!/0l'l'
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Materials and Processes Section
Inspection Summary
Inspection on March 29-31, April 1-2, 5-9, 12-14, and May 11, 1982 (Reports
No. 50-454/82-05(DETP); 50-455/82-04(DETP))
8207220171 820624
PDR ADOCK 05000454
O PDR
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Areas Inspected: QA Program interfaces and overview; corrective action
systems; design change control; material traceability of installed struc-
tures and components; electrical cable installation; inprocess inspections;
QC inspector ef fectiveness. The inspection involved a total of 662 in-
spector-hours onsite by seven NRC inspectors.
Results: Of the areas inspected nine apparent violations were identified
(failure to assure contractors are operating with a QA organization as
described in their QA manual and to assure that QA is sufficiently inde-
pendent from cost and schedule - paragraphs b.(6).(b), b.(8).(b), and
b.(10).(b); failure of site contractors to control the issuance of docu-
ments - b.(10).(b); failure of site contractors to follow their procedures
paragraphs b.(10).(b), and c.(2),(d).2; failure of site contractors to
, accomplish activities in accordance with procedures paragraphs b.(10).(b),
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c.(2).(e).1, and f.(2).(a); failure to include certain ANSI N45.2.12
criteria in CECO audit reports of contractors - paragraph b.(10).(b);
failure of a site contractor to meet certain security standards established
l by ANSI N45.2.9 for storage of records - paragraph b.(10).(b); failure to
I meet ANSI N45.2.6 qualification, certification and training requirements
for contractor QC inspectors - paragraph h.(2); failure to specify complete
and adequate corrective actions on nonconformance reports - paragraph
c.(2).(a).4; failure to accomplish welding in accordance with applicable
codes paragraph g.(2).(d).
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DETAILS
1. Persons Contacted
Commonwealth Edison Company (CECO)
- W. Stiede, Assistant Vice President
- L. DelGeorge, Director of Nuclear Licensing
- V. I. Schlosser, Project Manager
- W. J. Shewski, Quality Assurance Manager
- G. Sorensen, Project Superintendent
- R. Tuotken, Assistant Project Superintendent
- M. A. Stanish, QA Superintendent, Byron
R. J. Farr, QA Supervisor
K. J. Hansing, QA Supervisor
T. R. Sommerfield, QA Superintendent, Braidwood
J. J. Mihovilovich, Structural Supervisor, PCD
R. B. Klingler, QA Qupervisor, PCD
G. F. Marcus, Director of QA, Engineering / Construction
J. O. Binder, Electrical Supervisor, PCD
M. E. Lohmann, Mechanical Supervisor, PCD
C. J. Tomashek, Startup Coordinator
H. J. Kaczmarek, QA Engineer
A. A. Jaras, Project Operations Analysis Supervisor
- T. Tramm, Nuclear License Administrator
P. Donavin, Project Engineering Department
R. E. Querio, Startup Superintendent
- J. T. Westermeier, Project Engineer
R. Gruber, QA Engineer
J. Klink, QA Inspector
P. Nodzenski, QA Engineer
J. Toney, Engineering Assistant
P. Macuiba, QA Engineer
K. Key, Senior Buyer
L. Channell, Material Coordinator
R. Schwartz, QA Engineer
Sargent and Lundy Engineers (S&L)
R. Rabin, Senior QA Coordinator
D. Demoss, Engineer, PMD
- T. B. Thorsell, Senior Electrical Project Engineer
V. Crisci, Project Leader
J. Kelnosky, Electrical Project Leader
Westinghouse (W)
D. R. Fraser, Manager, SAMU
S. Stahl, QA Engineer, NTD
Y. Kau, Associate Engineer, PIDG
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Hatfield Electric Company (HECo)
G. Vanderhei, Project Manager
J. Buchanan, QA Hanager
A. Koca, QC Supervisor
R. Barzeloski, QA Supervisor
D. Stoner, QC Foreman
L. Broege, QC Inspector
J. Mulrene, QC Inspector
Powers-Azco-Pope (PAP)
R. Larkin, QA Manager
M. Donahoe, Engineering Manager
C. Cremer, QC Supervisor
A. Limia, QC Inspector
Blount Brothers Corporation (BBC)
R. H. Bay, QA/QC Manager
W. Wills, QC Inspector
Ebasco Services, Inc.
R. Detommaso, NDE Supervisor
Johnson Controls, Inc.
B. Shah, QA Manager
S. Pearson, QC Inspector
Pittsburgh Testing Laboratory (PTL)
J. Troutman, Site Manager
J. Chasm, Calibration Technician
G. Mohammad, Site Auditor
Mi_dway Industries Contractor, Inc.
M. Windsor, Site Manager
Nuclear Installation Services Company (NISCo)
J. Pruitt, QA/QC Manager
Nuclear Power Services (NPS)
W. Whitaker, Project QA Engineer
Relleable Sheet Metal Works, Inc.
A. M. Schlegel, QA Supervisor
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Hunter Corporation
M. Somsag, QA Supervisor
L. Haddick, QC Inspector
D. Corasani, Piping Engineer
L. Hill, Auxiliary Building Superintendent
W. Evertt, Containment Building Superintendent
D. Askland, Warehouseman
J. Morrison, Project Engineer
J. Young, Hanger Engineer
A. Simon, Administrative Supervisor, QA
R. Irish, Administrative Assistant, QA
H. Lundquist, Material Control Supervisor
U.__S. Nuclear Regulatory Commission (Region III)
- C. E. Norelius, Director, Division of Engineering & Technical Programs
W. S. Little, Chief, Engineering Inspection Branch
L. McGregor, Senior Resident Inspector, Braidwood
L. Cox, Secretary
- Denotes those presonnel attending the exit meeting held at the USNRC
Region III office on May 7, 1982. During the inspection at the Byron
Station exit meetings were held on a daily basis in order to keep the
licensee informed of any findings.
The inspectors also contacted and interviewed other licensee and
contractor personnel during this inspection.
2. Function or Program Areas Inspected
a. General Background
The purpose of this special team inspection was to determine if
there are indications of existing or potential construction
problems similar to some of those identified at a number of other
plants under construction. The scope of the assessments included
quality assurance program interfaces and overviews, corrective
action systems, design change control, material traceability of
installed structures and components, electrical cable installa-
tion, inprocess inspections, and effectiveness of quality control
inspectors.
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Prepared By: J. M. Peschel
P. Keshishian
b. QA Program Interfaces and Overview
(1) Quality Assurance Manuals Reviewed
Pittsburgh Testing Laboratory Quality Assurance Manual
- QA-M-1, Revision 4, September 21, 1979
Powers-Azco-Pope Quality Assurance Manual, Revision 3,
! December 7, 1981
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Commonwealth Edison Topical Report, Revision 20,
February 17, 1982
Johnson Controls, Inc., SECD Quality Assurance Program,
Revision 0, June 29, 1978
Hatfield Electric Company Quality Assurance Manual,
Revision 9, August 13, 1979
Ebasco Nuclear Quality Assurance Program Manual, Revision 10,
September 30, 1981
Hunter Corporation Quality Assurance Manual, Revision 5,
August 1, 1981
Nuclear Power Services, Inc., Quality Assurance Manual,
Fevision 1, January 13, 1981
Reliable Sheet Metal k'orks, Inc. , Quality Assurance Manual,
July 21, 1981
(2) Procedures Reviewed
(a) Commonwealth Edison Company
Byron Quality Instruction (BQI)
BQI-1, Revision 2, March 22, 1982
Generating On-Site Quality Instructions
BQI-7.1, Revision 2, March 22, 1982
On-Site Contractor Non-Conformance Reports
BQI-7.2, Revision 5, March 22, 1982
QA Handling of CECO Non-Conformances
BQI-9, Revision 4, March 22, 1982
QA Handling of Field Change Requests
BQI-10, Revision 4, February 25, 1982
Site QA Handling and Review of On-Site
Contractor Procedures
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BQI-11.1, Revision 4, March 22, 1982
Byron Site QA Audits
BQI-12.1, Revision 1, March 22, 1982
Installed Equipment Surveillance Instructions
, BQI-24, Revision 1, March 22, 1982
Byron QA Training Program
Byron Site Instruction (BSI)
BSI-5, Revision 5, October 20, 1980
Material and Equipment Receiving, Receiving
Inspection Storage, and Removal from Storage
- Instruction
Quality Procedure (QP)
. QP, 2-1, Procedure for the Revision of the Quality
Assurance Manual - Engineering, Construction
and Operation, Revision 63, February 24, 1982
QP, 2-2 Training of Personnel to meet Quality Assurance
Requirements, Revision 63, February 24, 1982
QP, 3-3, Classification of System, Components, Parts
- and Materials, Revision 63, February 24, 1982
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QP, 4-2, Evaluation of Contractor's Quality Assurance
Program, Revision 63, February 24, 1982
QP , 5 - 1, Quality Instruction and Procedures,
i Revision 63, February 24, 1982
QP , 7 - 1, Control of Procured Material and Equipment,
- Receiving and Inspection, Revision 63,
February 24, 1982
QP, 12-1, Calibration Control of Commonwealth Edison
- Test and Measurement Equipment, Revision 63,
February 24, 1982
QP, 15-1, Reporting Quality Nonconformance during
Construction and Test, Revision 63,
February 24, 1982
I QP, 15-2, Reporting Incidents and Deficiencies that
- occur during Construction and Test, Revision
63, February 24, 1982
QP, 16-1, Corrective action for Reportable Deficiencies
and Quality Nonconformances that occur during
Construction and Tests, Revision 63,
-February 24, 1982
QP, 17-1, Quality Assurance Records, Revision 63,
February 24, 1982
QP, 4- 1, Request for Bid, Proposed Evaluation, and
Recommendation, Revision 63 February 24, 1982
QP, 18-1, Quality Program Audits, Revision 63,
February 24, 1982
QP, 18-2, Surveillance of Contractor Quality Assurance
Control Activities, Revision 63, February 24,
1982
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General Procedure
General Procedure No. 738, Site Buying, February 2, 1981
(b) Hatfield Electric Company Procedures
Procedure #6, Revision 6, January 15, 1982
Reporting of Damaged or Nonconforming
Material or Equipment
Procedure #8, Revision 2, Issue 1, July 6, 1981
Audits
Procedure #9E, Revision 6, Issue 1, January 23, 1981 ,
Class I Cable Pan Identification
Procedure #11, Revision 12, February 2, 1982
Class I Cable Termination and Splicing
Procedure #17, Revision 2, October 10, 1981
Qualification of Inspection and Audit
Personnel
Procedure #19, Revision 4, Issue 1, January 24, 1981
Equipment Turnover Reporting
Procedure #20, Revision 8, November 20, 1981
Class I Exposed Conduit System
Identification
Procedure #23, Revision 8, Issue 1, January 22, 1981
Concrete Expansion Anchor Installation
Procedure #24, Revision 1, Issue 2, January 28, 1980
Control and Calibration of Meters and
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Instruments
Procedure #29, Revision 5, November 20, 1981
Field Initiated Request for Design
Changes
(c) Hunter Corporation Site Implementation Procedures
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4.201 Revision 4, January 19, 1982
Installation Verification
7.502 Revision 7, Augast 20, 1981
Control of Measuring and Testing Equipment
11.101 Revision 4, April 28, 1981
Nonconformance Processing
12.301 Revision 5. March 19, 1981
Internal and External Site Quality Assurance
Audits
i 20.513 Revision 9 June 8, 1981
Installation of Concrete Expansion Anchors
(d) Powers-Azco-Pope Procedures
QC-4 Revision 7, September 30, 1981
Nonconformance Control
QC-5 Revision 5, December 17, 1981
Site Audit
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FP-3 Revision 9, December 22, 1981
Material Receiving-Inspection Controls . ,
FP-4 Revision 5, September 30, 1981 ,
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Material Storage .
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FP-11 Revision 7, January 21, 1982 , e " ,-
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Calibration and Control of Measuring,and Test ,- , .
Equipment (M&TE) , ' '3 'I . ;_ m ,
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(e) Pittsburgh Testing Laboratory-Procedure , ; . , ,
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Resident Internal Quality Assurance Audit, I'lan, *
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Revision 4, November 17, 1981 , i % -
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(f) Johnson Controls Inc., Procedures , ,
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QAS-210-BY Revision 2, January 28, 1980 ,
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Auditor Training and Qualification , ,
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QAS-211-BY Revision 2, February 5, 1980 , , '
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Training and Indoctrination, Procedure , ,,...
QAS-710-BY Revision 1, September 19, 1979 -
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On-Site Document Control Procedure ,.
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QAS-1011-BY Revision 3, January 10;- 1980. . <-
Weld Rod Control ""b '
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QAS-1310-BY Revision 1,'Ocotober 30, 1979 , /, ' < e /-
Calibration Cctitrol 9f, Measuring and Test M
Equipment / 1 ,-
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QAS-1510-BY Revision 0, Ap311-D , 1979-- -
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Status Tag Usage Procedure .
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QAS-1610-BY Revision 0, February 13,,1979 - **
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Nonconformance Control Procedure j >
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QAS-1710-BY Revision 0, September 16,. 1,9/9 , , -j
Corrective Action -
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QAS-1910-BY -Revision 1, November 8, 1979 .
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Audit Procedure '
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SP-611-BY Revision 1, April 3, 1981 h '
Field Change Control Procedure ,
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(3) Audits and Miscellar.cous Documentation Reviewed M
(r.) Commonwealth Edison Comp'any re *
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Audit Reoorts ?' *
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- 6-82-4 . , /
- 6-82-08 -
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- 6-81-300 , , , ,
- 6-81-308 , .
- 6-81-309 .
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- 6-81-330 '+O.. , / - ,'
- 6-81-331
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- 6-81-336
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- 6-81-340 '
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- 6-81-344
- 6-81-354
- 6-81-357
- 6-81-360
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General Office Audit of Byron Construction Site,
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April 30, 1981.
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General Office Audit of Byron Construction Site,
November 8, 1981.
General Office Quality Assurance Audit of Byron
Station, April 30, 1981.
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Gene ~ral Office Quality Assurance Audit of Byron
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Station, Noveraber 8, 1981.
Management Audit at LaSalle, Byron, and Braidwood
Construction Sites and the LaSalle Operating Station,
April, 1981, by Energy Incorporated.
Miscellaneous Documentation
c. Site Mechanical Organization Chart, March 16, 1982.
L Site Electrical Organization Chart, March 16, 1982.
n g. Site Structural Organization Chart, March 16, 1982.
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Site Project Construction Organization Chart, March 16,
1982.
1981 Byron Site QA Audit Schedule, Revision 0 and
/,< Revision 9.
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[' 198'l-Byron Site QA Survie11ance Schedule.
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../ Byron Quality Assurance Organization Chart, March 22,
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Byron Quality Assurance Status Reports, January 5, 1982
and February 4, 1982.
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. Byron Site Quality Assurance Semi-Monthly Report for
. December 1981.
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1982 Byron Site Quality Assurance QP Training Schedule.
'** (b) Hatfield Electric Company
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.- Audit Reports
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- S1-18
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7 #81-20
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- 82-04
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-r Audit Report of Byron Site Procedure 5, 6 and 22 by
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Energy Incorporated, September 21, 1981.
- E Follow-up' Management Audit Report by Energy Incorporated,
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September 21, 1981.
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Trend Analysis Reports
- 2, July 24, 1981, 2nd Quarter of 1981
- 3, November 6, 1981, 3rd Quarter of 1981
- 4, 4th Quarter of 1981
, #1, March 25, 1982, 1st Quarter of 1982
Miscellaneous Documentation
Discrepancy Reports, " Trouble Letters" No.'s 640 - 670,
680 - 720.
1981 Audit Schedule
1982 Audit Schedule
Quality Assurance Audit Log
Memorandum from C. Van Lyssel to W. Brock concerning
Quality Assurance Organization, March 17, 1982.
(c) Hunter Corporation
Audit Report
No. 084-4
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l Miscellaneous Documentation
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Audit Summary
Fourth Quarter Audit Report
Follow-up Audit #1
Hunter Audit Summary Report for Fourth Quarter, 1981.
Hunter Corporation, Byron Site Quality Assurance Audit,
June 3, 1981.
Hunter Corporation Quarterly Nonconformance Report (NR)
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Summary and Trend Analysis, December 29, 1981.
(d) Powers-Azco-Pope
Audit Reports
- 52 September 29, 1981
- 53 October 1, 1981
- 54 November 12, 1981
- 55 November 12, 1981
- 56 November 16, 1981
- 57 November 15, 1981.
- 58 November 25, 1981
- 59 December 3, 1981
- 60 December 29, 1981
- 61 January 27, 1982
Management Review Audit, Byron, March 17, 1982
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Miscellaneous Documentation
Weekly Storage Surveillance Report, March 10, 1982
Weekly Storage Surveillance Report, March 17, 1982
Weekly Storage Surveillance Report, March 24, 1982
Weekly Storage Surveillance Report, March 30, 1982
(e) Pittsburgh Testing Laboratory
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Audit Reports
- 81-21
- 81-22
- 81-23
- 81-24
- 81-25
- 81-26
- 81-27
- 81-28
- 81-29
Internal QA Audit #BY-3
Internal QA Audit #BY-4
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Miscellaneous Documentation
Pittsburgh Testing Laboratory Organization Chart
Pittsburgh Testing Laboratory Inspectors Eye Examination
Records
(f) Jchnson Controls, Incorporated
Audit Reports
Yearly QA Program Audit No. 00501, May 16, 1980
Yearly QA Program Audit No. 10801, August 5, 1981
Audit Report, Bensenville Office, September 15, 1981
Nonconformance Reports
- 001BY November 14, 1980
- 002BY November 14, 1980
- 003BY December 4, 1980
- 004BY August 19, 1981
- 005BY February 23, 1982
- 006BY March 25, 1982
- 007BY April 2, 1982
(4) Interviews with Site Personnel
Interviews were conducted with sixteen personnel from Common-
wealth Edison Company, six personnel from Hunter Corporation,
three personnel from Powers-Azco-Pope, three personnel from
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Hatfield Electric Company, two personnel from Pittsburgh
Testing Laboratory and one person from Johnson Controls,
Incorporated.
(5) Licensee's Quality Assurance Program
(a) Objective
The objectives of this assessment were to determine:
. that the licensee's Quality Assurance Program,
including all amendments, has been approved by NRR.
. if the licensee has control of changes to the
submitted Quality Assurance Program.
. if the Quality Assurance Manual is consistent with
the approved Qualit: Assurance Program.
(b) Discussion
The inspectors reviewed:
1. the licensee's Topical Report, CE-1-A, Revision 20,
and determined that the original program and all
subsequent revisions have been approved by NRR.
The licensee submits all changes to NRR and
includes minor or typographical changes at the
same time as substantive changes are submitted.
2. the licensee's Quality Requirements and Quality
Procedures and determined that the licensee
initiated and controlled changes to the program
through QP-2-1. The procedure requires the same
level of review for a QA Program change as the
original program received. The program has pro-
visions to input a change due to feedback of
experience, regulatory requireLents, codes and
standards, audits, and reviews.
3. the licensee's Quality Assurance Manual and referenced
documents to determine whether adequate QA plans and
procedures have been established (written, reviewed,
approved, and issued) to implement the docketed QA
program. The reivew indicated that the 18 Criteria
of 10 CFR 50, Appendix B were addressed by the
Quality Procedures of the Quality Assurance Manual.
The inspectors reviewed 6 of the 25 Quality Assurance
Manuals assigned to Byron Station to determine they
were of the latest revisions. The following manuals
were reviewed and no problems were detected.
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Manual No. Assigned To
111 Project Construction Superintendent
- 208 Byron Station Superintendent
177 CECO OAD Supervisor
191 Byron Station Maintenance Supervisor
62 Byron Station Technical Staff Supervisor
115 Byron Station Quality Assurance Super-
intendent '
(6) Quality Assurance Program of Contractors
(a) Objectives
The objectives of this assessment were to determine
if the licensee has approved and routinely audits the
Quality Assurance Programs of contractors for consistency
with 10 CFR 50, Appendix B, and to determine the current
status and effectiveness of licensee management of the
on-site Quality Assurance Programs.
(b) Discussion
The inspectors reviewed documentation, conducted extensive
interviews with licensee and site contractor personnel,
and reviewed portions of the licensee's and contractor's
QA manuals to determine levels of staffing, organizational
independence from cost and schedule, position descriptions,
and to determine if the status and adequacy of the QA
Programs were_ regularly reviewed by the licensee and
contractor's management.
At the time of inspection the licensee had 13 contractors
on site and each was performing safety related work under
their own specific Quality Assurance Programs (QAPs).
These QAPs had been submitted to the licensee for review
and approval. The licensee had reviewed and approved
j the QAPs prior to the contractors start of work. The
,
licensee was fully aware of its ultimate responsibility
i for site Quality Assurance and had its own QA organiza-
tion on site to monitor the activities of the various
site contractors through the mechanisms of surveillances-
and audits.
Table 1 is a matrix of licensee and on-site contractors
performing safety-related work indicating the areas
checked and compliance with these areas.
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Noncompliance (454/82-05-01a; 455/82-04-01a)
10 CFR 50, Appendix B, Criterion I, requires that "Such
persons and organizations performing quality assurance
functions shall report to a management. level such that
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this required authority and organizational freedom,
including sufficient independence from cost and schedule
when opposed to safety considerations, are provided."
Contrary to this requirement, the inspectors found that
the QA Managers of both Hatfield Electric Company and
Powers-Azco-Pope (PAP) reported directly to on-site
managers who had direct responsibilities for cost and
schedule for their respective contracts. The Hatfield
QA Manager reported to the Vice-President and the PAP
QA Manager reported to the Project Manager.
Unresolved Item (454/82-05-02; 455/82-04-02)
In addition to the foregoing, it appeared that the QA
Representative for Johnson Controls had production
responsibilities that also conflicted with organizational
independence. A review of the activities of Pittsburgh
Testing Laboratories (PTL) indicates that there is no
PTL on-site QA organization other than a site auditor
and that for a substantial period of time each week PTL
activities are not under surveillance. This condition
occurs because there are two shifts for PTL inspectors
and only one auditor.
The questions regarding Johnson Controls and PTL could
not be resolved during the current inspection and are
an unresolved item.
(7) Licensee Management Assessment of the Quality Assurance Program
(a) Objective
The osjective of this assessment was to determine if a
periodic assessment of the licensee's Quality Assurance
Program is conducted by Commonwealth Edison Company
upper level management.
(b) Discussion
The inspectors reviewed audits of the Byron Construction
site conducted by a General Office Audit Team. These
semi-annual audits are supplemented'by a biennial audit
conducted by an independent auditing organization. The
audits cover the entire scope of the Quality Assurance
Program and are reviewed by upper level management.
The licensee's Quality Assurance organization is headed
by a site QA Superintendent. He is assisted by two
Supervisor's who direct the activities of thirteen QA
Engineers and Inspectors in monitoring and auditing
the activities of the site contractors. In addition
four Pittsburgh Testing Laboratory personnel are
assigned to the organization for specific documentation
related assignments.
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Each engineer and inspector is assigned a specific list
of responsibilities so that all contractor activites and
other QA monitoring systems are fully covered. This
type of organization should be able to effectively
monitor site QA activities. However, the execution of
the program is not satisfactory, as evidenced by the
many problems uncovered by the inspectors. One factor
,
affecting the execution is the stability of service for
the QA personnel.
A key individual in a QA Program is the on-site super-
intendent. He has the direct responsibility for the
QA performance of the contractors and other plant
related activities. It is he who anticipates problem
areas, sees to the training of his staff, directs the
activities of his staff and is instrumental in producing
a quality product. Since January 1976 there have been
five QA Superintendents at the Byron Site:
J. Pizzica January 1976 to May 1976
D. Jeritz May 1976 to August 1977
R. Gousden Augu.t 1977 to May 1978
T. McIntere May 1978 to January 1981
M. Stanish January 1981 to Present
In addition to this undesirable condition, the QA
Engineers and Inspectors have an average on-site s rvice
time of approximately fourteen months and have limited
prior QA experience. Part of this on-site time was
spent in training and qualifying for various QA duties.
In addition to this problem, manpower is currently being
sent to other sites so that the QA effort is substantially
weakened. Out of a staff of sixteen, three men have been,
and currently are at other assignments:
R. J. Schwartz La Salle Station 12/7/81 to 2/19/82;
3/19/81 to Present
J. S. Hale La Salle Station 1/8/81 to 2/26/8?;
3/19/82 to Present
P. J. Nodgenski Quad-Cities Station 9/14/81 to 9/25/81;
l Byron Pre-op Testing 4/5/82 to Present
The constant change over of personnel resulting in a
minimum experience level and transfer of personnel could
hinder the QA organization in meeting its obligation
of effectively implementing a QA program.
In contrast to the experience level of the QA organ-
ization the inspectors made a review of the stability
of the supervisory and engineering personnel in the
construction organization. The key individuals and
service time at the Byron Station are:
16
_ _ _ _ _ _ _ _ - _ - _ _ _ - _ _ - _ _
.
.
Title Name On Site Since
Project Superintendent G. Sorensen 1976
Assistant Project R. Tuetken 1977
Superintendent
Lead Civil Engineer J. Mihovilovich 1975
Lead Mechanical Engineer M. Lohmann *1981
Lead Electrical Engineer J. Binder 1978
- Six years prior experience as a Mechanical Engineer at
La Salle County Station.
The pronounced difference in site time and experience
level indicates there is the potential for a problem
with QA personnel continually being transferred. In
an effort to determine the cause of this potential
problem a meeting was held with the Corporate Manager
of Quality Assurance, W. J. Shewski, on April 16, 1982.
His explanation was the the transfer of the QA Superin-
tendents was for promotional opportunities in four
cases and a death in the case of one superintendent.
His explanation for the large turnover and inexperience
level of the QA Engineers and Inspectors was that he
desired to seed the licensee departments with QA
experienced personnel and also not deny them promotional
opportunities.
This constant change over of QA personnel as contrasted
to the stable and experienced work force of the construc-
tion group indicates the need to create greater promo-
tional opportunities in the QA organization, or the need
to have some sort of system instituted to require QA
personnel to acquire minimum service time at nuclear
sites.
The inspectors reviewed the training that was given to
CECO QA personnel after they had completed corporate
quality assurance training. The Byron QA training is
an on-the-job type training and is intended to supple-
,
ment the corporate training and enhance the development
of new QA personnel.
A review of BQI-24. Revision 1, Byron QA Training
Program, revealed that although the stated purpose of
the instruction was to provide the necessary training
to appropriate personnel as quickly as possible, there
was no specified length of time in which the training
was to be completed. A lack of prompt training was a
finding annotated by the General Office Audit of
November 1981. A review of on-the-job training records
revealed that prompt training was still not being
accomplished and that the corrective action to prevent
17
_
_ _ _
.
.
recurrance, stated in the audit response, was not being
effectively implemented. The on-the-job training
system had no provision to alert supervisory personnel
when a new employee's training was lagging.
BQI-24 also states, "It is the new employees respons-
ibility to obtain and maintain the required training."
It is our belief that the training of new employees is
a management responsibility and cannot be delegated to
the new employee. *
Attachment A to BQI-24 lists fourteen areas of training,
and specific individuals are designated as authorized
trainers in each area. There are no lesson plans or
other types of written guidance for the required train-
ing. The lack of a formalized training program is not
conducive to the maintenance of a skilled, trained,
and competent Quality Assurance Department. With some
of the more experienced personnel assigned to duties
at other locations the training of the QA department
suffers.
Open Item (454/82-05-03; 455/82-04-03)
The inability of the licensee to dedicate resources to
the Quality Assurance organization to see that their
experience base is equivalent to other organizations,
leads the inspectors to question the licensee's
effectiveness in staffing the Quality Assurance Program
Organization. In addition, there is no evidence of a
Management Policy Statement emphasising the dedication
of the Company to Quality Assurance and quality in
general. The licensee's position is that the Company
policy is stated in the Quality Requirements of the
Quality Assurance Manual. It is our belief that these
are an explanation of the Quality Assurance Manual
and not a statement of policy.
(8) Licensee Quality Assurance Organization
(a) Objective
l The objective of this assessment was to determine if
the Quality Assurance Program provides sufficient
independence from cost and schedule.
l
(b) Discussion
The inspectors reviewed the organization charts in the
licensee's Topical Report and they indicate adequate
independence for the CECO Quality Assurance Organization.
Further inspection resulted in concern regarding the
activities of the Project Construction Department that
18
i
.
,
appear to be centrary to 10 CFR 50, Appendix B, Criterion-
I, regarding the independence of the Quality Assurance
effortWfrom production.
The licensee's site-Project Construction Department
is organized with a Manager, Technical Staff, Project
Engineers and Field Engineers. The inspectors inter-
viewed four supervisors and the assistant superin-
tendent of the construction group and found each of
them to be knowledgeable and experienced engineers
fully capable of meeting their respective respons-
ibilities. They all fully recognized the importance
of quality assurance and control and were determined
to build a quality plant.
The responsibilities of this group include:
. Advisor to Engineering for design suitability for
constructability.
. Coordinate requests for field revisions.
. Receipt and storage of materials.
. Assist Project Engineering in development of
overall schedule.
. Verify conformance and completeness of contractor's
installation to specification requirements.
. Supervise and approve mechanical and structural
construction tests.
. Coordinate and provif essistance for electrical
construction tests.
. Coordinate preoperation tests.
The Project Construction QC Supervisor and Project
Construction Electrical Supervisor have engaged in
Quality Assurance activities independent of the Byron
Superintendent of Quality Assurance and the offsite
Manager of Quality Assurance. The licensee could
not produce a position description for the areas of
responsibilities and the duties of the Project
Construction QC Supervisor. An example of specific
QA activities engaged in by these supervisors is:
. Letter of November 13, 1981 from the Electrical
and QC Supervisors to the on-site Vice President
- of Hatfield Electric Company suggesting duties
and responsibilities of the QA/QC Manager and a
suggested organization chart.
The activities of the two supervisors in QA activities
i
appears to be contrary to 10 CFR 50, Appendix B, Criter-
-
ion 1, that requires independence of QA supervisors from
cost and schedule. In addition, it seriously undermines
the effectiveness of the incumbent QA Superintendent
r
l
19
L
.
.
to monitor the activities of the site QA organizations.
The activities of these two supervisors resulted in a
reorganization of the Hatfield Electric Company QA/QC
Department that was not described in the QA Manual.
We believe that CECO QA should, at a minimum, be in-
volved in a review and concurrence capacity when such
suggestions are made to contractors.
In addition to the foregoing, a further problem with
QA independence from cost and schedule arises in that
the site Project Superintendent has final contractual
approval for some contractor QA organizations concerning
salary increases, promotions, and hires for QA non-manual
personnel increases. The requests for such action from
Hatfield Electric Company and Powers-Azco-Pope do not
have a concurrence from the contractors Quality Assurance
Department and come from the project construction manage-
ment.
,
The following list indicate salary changes or promotions
of QA inspectors for site contractors that were approved
by the site Project Superintendent.
Date Contractor Position
2/24/82 Powers-Azco-Pope QA Specialist
12/8/81 Hunter Corporation QA Inspector
11/23/81 Hunter Corporation QA Inspector
11/3/81 Hunter Corporation QA Inspector
11/5/81 Hunter Corporation QA Inspector
The inspectors recognize that the Project Superintendents'
responsibility for contract administration requires his
final approval for contractors staff size and changes in
compensation, however, a question of satisfying the re-
quirements of 10 CFR 50, Appendix B, Criteria I relative
to QA independence arises. Mechanisms are currently now
in effect for such independence in that the Pittsburgh
Testing Laboratory contract is administered by the
Corporate Quality Assurance Manager who is independent
of cost and schedule.
Noncompliance (454/82-05-01b; 455/82-04-01b)
The lack of independence between the Quality Assurance
Department and the Project Construction Department is
in violation of 10 CFR 50, Appendix B, which states
in part, "Such persons and organizations performing
quality assurance functions shall report to a manage-
ment level such that this required authority and
organizational freedom, including sufficient inde-
pendence from cost and schedule when opposed to safety
considerations, are provided.
20
-_
.
.
Open Item (454/82-05-04; 455/82-04-04)
The involvement of the Project Construction Department
in Quality Assurance Activities indicates the need for
an Interface Document or Interface Procedure to explain
the interaction of the licensee's Quality Assurance
Organization with the Contractor's Quality Assurance
Organizations, and the relation of the Project Con-
struction Department to all on-site Quality Assurance
Organizations.
(9) Quality Assurance Responsibility
(a) Objective
The objective of this assessment was to determine if
the licensee has the prime responsibility for establish-
ing and executing the Quality Assurance Program.
(b) Discussion
The inspectors reviewed the Topical Report and the
Quality Assurance Manual and interviewed the licensee's
Corporate and Site Quality Assurance Managers and the
Quality Assurance Manager of selected contractors.
The documentction review and the interviews showed
that the responsibility of the licensee was established,
documented and understood by responsible personnel in
both the }1censee's and contactor's organizations.
The inspectors were concerned about the lack of a policy
statement from upper management that went beyond the
explanation provided in Quality Requirement 1.0 and pro-
vided assurance that upper management of CECO supported
the Quality Assurance Program and it objectives.
i (10) Licensee Oversight of Contractor Activities
l (a) Objective
t The objectives of this assessment were to determine
l if the licensee has effective oversight of contractor
' activities and has detailed knowledge of those
activities.
(b) Discussion
The inspectors conducted interviews with Quality Assurance
- personnel from the licensee, Hatfield Electric Company,
[ Hunter Corporation, Powers-Azco-Pope, Johnson Controls,
} Inc., and Pittsburgh Testing Laboratory. These interviews
were supplemented by the review of related quality assur-
- ance procedures, audits and documentations; tour of work
l
,
21
l
= _ _ _ .
..
.
areas, warehouses and field offices; and discussions with
licensee and contractor personnel. -As a result of the
above the inspectors determined that the licensee has a .
program that should provide an effective oversight of
contractor activities. The ability of the licensee to
provide this oversight is questionable due to the man-
power limitation discussed in the " Licensee Assessment
of the Quality Assurance Program" section of this report
and the findings noted below.
Contractor QA Manuals
A review of the operating organization of two contractors,
Hatfield Electric Company and Johnson Controls, .Inc.,
revealed that the present organizations were not described
in the latest Quality Assurance Manual revisions.
Johnson Controls, Inc., changed the title of the Senior
QA Representative associated with Byron from the Quality
Assurance Representative to the Quality Assurance Manager
and did not update their Quality Assurance Manual.
Johnson Controls operated for approximately five months
with this discrepancy, and Commonwealth Edison Company
Quality Assurance was not aware of the discrepancy.
Hatfield Electric Company was operating with a Quality
Control Supervisor and a Quality Assurance Supervisor,
both of whom report to the Quality Assurance Manager
and who are not reflected in the Quality Assurance
Manual. The reason for this disparity is a letter
from the licensee's Project Construction Department to
the Hatfield Electric Company Vice-President suggesting
an organization change.
Noncompliance (454/82-05-01c; 455/82-04-01c)
10 CFR 50, Appendix B, Criterion I states, "The
authority and duties of persons and organizations
l performing activities affecting the safety-related
I
functions of structures, systems, and components
shall be clearly established and delineated in
writing."
The failure of Hatfield Electric Company to have its
I
,
'
Quality Assurance Manual reflect the actual Quality
Assurance Organization is contrary to the above and is
an item of noncompliance.
The failure of Johnson Controls, Inc. , to have its
Quality Assurance Manual reflect the actual Quality
- Assurance Organization is contrary to the above and
is an item of noncompliance.
22
- - - -
.
_- - _
.
.
The licensee has indicated that the above conditions
have been corrected. These items will be examined
during future inspections.
Safekeeping of Quality Records
A tour was made of the combined vault used by Johnson
Controls, Westinghouse-SAMU, Midway Industrial Con-
tractors, Ebasco Services, Inc., and Reliable Sheet
Metal. The safes of Westinghouse SAMU and Midway
Industrial Contractors were found unlocked and with no
attendant at the door of the vault. The Westinghouse
safe contained computer tapes which were described to
be non-safety-related and the Midway safe contained
quality records.
Noncompliance (454/82-05-05; 455/82-04-05)
10 CFR 50, Appendix B, Criterion XVII states, " Sufficient
records shall be maintained to furnish evidence of act-
ivities affecting quality." ANSI N45.2.9-1974 states,
"A full time security system shall be established to
preclude the entry of unauthorized personnel into the
storage area. This system shall guard against larceny
and vandalism."
The failure of Midway Industrial Contractors to lock
a safe containing quality records is contrary to the
above and is an item of noncompliance.
The licensee has indicated that this situation and the
condition of the Westinghouse-SAMU safe have been
corrected. This item will be examined during a future
inspection.
During tours of the combined vault, the Powers-Azco-Pope
,
vault, the Hatfield Electric Company vault and the li-
'
censee's vault, the inspectors noted that entrance holes
for conduit and other such piping had not been sealed
and possible air paths from the exterior existed.
Unresolved Item (454/82-05-06: 455/82-04-06)
- ANSI N45.2.9-1974 states that permanent and temporary
l records storage facilities shall be constructed to
protect the contents from possible destruction by fire.
The inspectors are concerned that with the possible air
paths around conduits and pipes that the Halon System
may not be able to extinguish a fire.
The 'icensee has indicated that action has been taken
to correct this condition. This item will be examined
during a future inspection.
,
23
-_ . .. _ _ _ _ _ _ __
'
e
.
Surveillances
The inspectors reviewed the licensee's Quality Assurance
Department 1981 surveillance schedule and noted that
approximately seven percent of the scheduled surveil-
lances were not conducted and there was no documented
reason for their omission. The licensee did conduct
approximately 800 more surveilla_ces than were scheduled
with an increase being made in some areas due to problems
discovered or to follow up on audit findings. We
recognize that such increased attention is necessary,
but are concerned about the omission of surveillances
without substantiating documentation, as surveillances
are one of the intergal methods by which the Quality
Assurance Organization provides an oversight of con-
tractor activities.
Open Item (454/82-05-7; 455/82-04-7)
The inspectors are concerned about the omission of
scheduled surveillances without substantiating docu-
mentation.
The licensee indicated that this item will be corrected.
This item will be examined during a future inspection.
Drawing Control
The inspectors reviewed selected drawings in the on-site
office of Johnson Controls, Inc., and at Hunter Corpora-
tion's Document Station 1-H, at the 426 level in the
containment.
Twelve drawings were chosed at Johnson Controls, and of
those chosen one was not the latest revision as indicated
on the Sargent and Lundy master drawing list located in
the CECO Quality Assurance office. Drawing M3393, Page
4 of 12, was Revision B and should have been Revision C,
which was issued February 12, 1982. The M3393 drawing
series is not marked to indicate how many drawings are
in the series but are annotated as 1 of " blank".
Ten drawings were reviewed at Hunter Corporation's
Document Station 1-H, at the 426 level in the contain-
ment, and of these two drawings, CS-58 and RH-15, were
not the proper revisions according to the Hunter
Engineering Department master list. Hunter Corporation
personnel explanined that the drawings in question were
for work on the Unit 2 containment, which had been
stopped, and all related drawings were supposed to have
been recalled to document control. Hunter instituted
an immediate recall of these drawings.
24
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
Noncompliance (454/82-05-08; 455/82-04-08)
10 CFR 50, Appendix B, Criterion VI states, " Measures
shall be established to control the issuance of docu-
ments, such as instructions, procedures, and drawings,
including changes thereto, which prescribe all activities
affecting quality." The failure of Johnson Controls, Inc.,
and Hunter Corporation to control the issuance of drawings
is contrary to the above and an item of noncompliance.
The licensee indicated that the condition has been
, corrected. This item will be examined durfug a future
'
inspection.
Process Traceability
The inspectors accompanied two CECO Quality Engineers,
one electrical and one welding, on inspections in the
containment, auxiliary building and the turbine building
to determine if they could trace the installation and
inspection process on welds, conduit hanger installation,
and cable pan installation. No problems were identified.
Quality Assurance Procedures
Inspection identified that two on-site contractors per-
forming safety related work were using forms which were
not controlled by procedures.
Hatfield Electric Company is utilizing a Discrepancy
Letter, also known as a Trouble Letter, for documenting
incomplete construction, non-conforming contruction,
requirements for Field Change Requests and other dis-
crepant items found during quality control inspections.
These Trouble Letters have been in use for approximately
the last 18 months and about 800 have been generated
in this time frame. The Trouble Letters are used as an
intermediate document during inspections prior to
corrective work or preparation of FCRs and NCRs and do
not become part of the quality records. Trouble Letters
numbers 640 thru 670 and 680 thru 720 were examined and
l It was found that in the inspectors opinion Trouble
Letters 658, 662, 664, 669, 679, 696, 697, 700 and 721
should have been documented as non-conformance reports.
As an example, in Trouble Letter 679, a Hatfield Electric
Company QC Inspector reports a conduit strap backing
j plate that is not welded to a hangar. The failure to
- have a procedure for this Trouble Letter is contrary
i
to Appendix B.
! A similar condition exists with the instrumentation
piping installer, Powers-Azco-Pope. k' hen making Quality
i
25
l
.. - .- -
____ __
.
..
.
.. .
.
.
Control inspections a Fabrication Installation Surveil-
lance form, for which there is no prescribed procedure
is used for purposes identical to the Hatfield Trouble
Letter.
The inspectors examined FIS numbers 180 through 216
and in their opinion a number of the FIS's should have
resulted in NCRs. As an example, FIS 186 reported items
that were installed but did not have the required heat
numbers.
We are not against the use of trouble letters or speed
letters to expidite some contractor functions, however,
when these documents are used to document inspection
discrepancies they must be procedurally controlled.
Noncompliance (454/82-05-09a; 455/82-04-09a)
10 CFR 50, Appendix B, Criterion V states, " Activities
affecting quality shall be prescribed by documented
instructions, procedures, or drawings, of a type appro-
priate to the circumstances and shall be accomplished
in accordance with these instructions, procedures, or
drawings."
The failure of Hatfield Electric Company to utilize a
procedure to control their Discrepancy Records is contrary
to the above and is an item of noncompliance.
The failure of Powers-Azco-Pope to control their
Fabrication Installation Surveillances is contrary
to the above and is an item of noncompliance.
The licensee has indicated that these conditions have
been corrected. These items will be examined during
a future inspection.
Audits
The inspectors reviewed audits that were conducted by
the corporate and site quality assurance organizations
of Commonwealth Edison Company, Hatfield Electric
Company, Hunter Corporation, Powers-Azco-Pope, Johnson
Controls, Incorporated, and Pittsburgh Testing Laboratory.
The audits were conducted according to an audit schedule
and the scope and content of the audits was acceptable.
The audit reports consistently failed to include a list
of persons contacted during the conduct of the audit
and a summary of audit results, including an evaluation
statement regarding the effectiveness of the quality
assurance program elements which were audited, as
required by ANSI N45.2.12.
26
.
..
.. - -- - ____ - ____ _ - -___________ - _ __-
.
.
Noncompliance (454/82-05-10; 455/82-04-10)
10 CFR 50, Appendix B, Criterion XVIII states tha; a
comprehensive system of planned and periodic audits
shall be carried out to verify compliance with all
aspects of the quality assurance program and to deter-
mine the effectiveness of the program.
ANSI N45.2.12-1977 states that audit reports shall pro--
vide a list of persons contacted during audit activities
and shall have a summary including an evaluation statement
regarding the effectiveness of the quality assurance pro-
gram elements which were audited.
.
Contrary to the above, the audit reports of the licensee,
Hatfield Electric Company, Hunter Corporation, Powers-
Azco-Pope, Johnson Controls, Inc., and Pittsburgh Testing
Laboratory consistently failed to include persons con-
tacted during the audit and an evaluation statement re-
garding effectiveness of the program elements as indicated
in the examples listed below:
List of Evaluation
Auditor Audit # Persons Contacted Statement
CECO 6-81-330 Yes No
CECO 6-81-308 Yes No
CECO 6-81-336 No No
CECO 6-81-357 Yes Yes
CECO 6-81-309 Yes No
CECO 6-81-344 Yes No
CECO 6-81-340 Yes No
CECO 6-81-300 No No
CECO 6-82-08 No No
Hatfield 81-02 No No
Hatfield 81-18 No No
Hatfield 81-19 No No
Hunter 84-4 No No
Hunter None July 9, 1981 No No
Johnson 00501 No Yes
Johnson 10801 No Yes
PAP 52 No No
PAP 54 No No-
PAP 55 No No
- PTL 81-21 No No
PTL 81-23 No No
PTL 81-25 No No
The licensee has indicated that action has been taken
to correct this situation in future audits. This item.
will be examined during a future inspection.
I
27
i
. . _ _ _ -._ ... - -
_ _ _ _
.
.
Measuring and Test Equipment
The inspectors reviewed the procedure and methods for
control of Measuring and Test Equipment used by Hunter
Corporation, Hatfield Electric Company, Powers-Azco-Pope,
Johnson Controls, Inc., and Pittsburgh Testing Laboratory
and inspected various instruments in office and field
locations.
The inspectors identified no problems with Hunter
Corporation, Johnson Controls, Inc., and Pittsburgh
Testing Laboratory (PTL).
During a review of torque wrenches in the Hatfield
Electric Company Quality Assurance office and the
Powers-Azco-Pope Quality Assurance office the following
items were identified.
. Hatfield Electric Company: The storage of torque
wrenches was not according to Hatfield Procedure
- 24 as the wrenches that were past the calibration
date were not red tagged and they were stored on
the same shelf as wrenches currently in calibration.
HE-151, HE-142, and HE-135 are some of the untagged,
uncalibrated torque wrenches stored with calibrated
wrenches.
. Powers-Azco-Pope: One torque wrench, TW-4, was
marked as defective, but did not have a Reject Tag
as required by Section 5.15 of Powers-Azco Pope
Procedure FP-11, Calibration and Control of
Measuring and Test Equipment (M&TE).
Noncompliance (454/82-05-11a; 455/82-04-11a)
10 CFR 50, Appendix B, Criterion V states, " Activities
affecting quality shall be prescribed by documented
instructions, procedures, or drawings, of a type
appropriate to the circumstances and shall be accomp-
lished in accordance with these instructions, procedures,
or drawings."
The failure of Hatfield Electric Company to follow its
procedure #24, with regard to tagging torque wrenches,
is contrary to the above and is an item of noncompliance.
The failure of Powers-Azco-Pope to follow its procedure
No. FP-11, with regard to tagging torque wrenches, is
contrary to the above and is an item of noncompliance.
The licensee has indicated that these conditions have
been corrected. These items will be examined during a
future inspection.
28
- -- ___
.
.
Purchasing, Receiving and Storage
The inspectors reviewed the process used to obtain safety
related material starting with a material request gen-
erated by a contractor and culminating with storage in
a warehouse. The inspectors noted no discrepancies in
the requesting, purchasing and receiving portions of
the project, but during tours of warehouse areas the
following items were noted:
. In Warehouse No. 1, safety-related equipment was
stored on shelves that also contained lumber,
boxes of paper, scraps of rubbish and food in a
housekeeping atmosphere that did not meet the
requirements of Section 6.2 of ANSI N45.2.2.
. In Warehouse No. 5, a pallet of bags containing
charcoal type compound was stored above safety
related valves. One of the bags had broken and
the material had spilled onto the valves, shelving-
and floor, and the housekeeping was not in accord-
ance with Section 6.2 of ANSI N45.2.2.
Noncompliance (454/82-05-11b; 455/82-04-11b)
10 CFR 50, Appendix B, Criterion V states, " Activities
affecting quality shall be prescribed by documented
instructions, procedures, or drawings, of a type
appropriate to the circumstances and shall be accomp-
lished in accordance with.these instructions, procedures,
or drawings."
The conditions maintained by the licensee in Warehouses
No. I and No. 5 were contrary to Quality Procedure 13-1
,
and to the requirements of ANSI N45.2.2-19?2, and are
'
an item of noncompliance.
The licensee has indicated that action has been taken
to correct the warehouse conditions. This item will
be examined during a future inspection.
. In Warehouse No. 4, Powers-Azco-Pope is storing
material that is tagged Rejected next to Accept
and Hold material and is not segregated as re-
quired by Section 5.6 of Powers-Azco-Pope Pro-
cedure No. FP-3, Material Receiving Inspection
Control.
>
. Powers-Azco-Pope is attaching a red tag that says
" Safety-Related" to material that has also been
tagged with PAP's Accept Tag. The red tag is not
referenced in any PAP or CECO procedure.
29
.
.
.
Noncompliance (454/82-05-11c; 454/82-04-11c)
10 CFR 50, Appendix B, Criterion V states, " Activities
affecting quality shall be prescribed by documented in-
structions, procedures, or drawings, of a type appro-
priate to the circumstances and shall be accomplished
in accc.-dance with these instructions, procedures, or
drawfu4s."
The failure of Powers-Azco-Pope to store rejected
material in accordance with their procedure No. FP-3
is an item of noncompliance.
The licensee has indicated that this condition has been
corrected. This item will be examined during a future
inspection.
(11) Quality Assurance Staffing
(a) Objective
The objective of this assessment was to determine if
the Quality Assurance Organizations of the licensee
and contractors are adequately staffed.
(b) Discussion
The inspectors interviewed personnel involved in the
management of the licensee's and selected contractor's
Quality Assurance Organizations; and approximately 14
percent of the Quality Control inspectors employed by
the contractors. Based on the interviews and a review
of scheduled and completed audits and surveillance
the inspectors were able to conclude that the Quality
Assurance Organizations were supplied with sufficient
manpower. The auditors of the selected organizations
were found to be adequately qualified. Qualifications
of Quality Control inspectors are discussed in detail
in the "QC Inspector Effectiveness" section of this
report.
The inspectors do not believe that the Quality Control
Supervisor for Powers-Azco-Pope was qualified to be a
Level II Supervisor on the day she was appointed to the
position, as she did not have the one year of Level I
experience as required by ANSI N45.2.6-1978. This is
discussed in greater detail in section h., QC Inspector
Effectiveness.
The CECO Quality Assurance Organization at Byron is
fully staffed with 16 personnel, but the effectiveness
of Quality Assurance section is being weakened by the
30
. _ _ _ _ _ _ .
.
.
deployment of Byron Quality Assurance personnel at
<
La Salle and Quad-Cities. This is discussed in more
detail in pargarph b.(7), Licensee Assessment of Quality
Assurance Program. In addition to the above, one
Quality Engineer was transferred to the Operations Quality
Assurance section during our inspection and a replacement
is not scheduled to arrive until June 1982.
The transfer of the Quality Assurance personnel to sup- i
port other programs is an area of concern.
(12) Trend Analysis Program
(a) Object f.ve
The objective of this assessment was to determine if
the licensee has an effective trend analysis program.
(b) Discussion
The inspectors reviewed the trend analysis reports of
the licensee and Hatfield Electric Company. Licensee
trending of NCR's is discussed in detail in section c.,
Corrective Action Systems. The licensee publishes an
annual Trend Analysis Report which is s summary of
NCR's by problem area for each contractot during the
previous year, and the Corrective Action System is
scheduled to be audited semi-annually.
(13) Compliance History
(a) Objective
The objectives of this assessment were to review the
licensee's compliance history and the effectiveness
of the associated corrective action.
(b) Discussion
The inspectors reviewed the licensee's history of
noncompliances, unresolved items, 10 CFR 50.55(e)
Reports, NCR's, IE Bulletins, IE Circulars, and IE
Information Notices and reviewed the systems used to
assign responsibility and to track the resolution of
the problem. A review of all 10 CFR 50.55(e) reports
and 30% of the noncompliances showed that the corrective
action was appropriate, with the cause identified and
! action taken to prevent recurrence. NCR's and their
resolution are discussed in detail in section c.,
'
Corrective Action Systems.
Except as noted, within the areas inspected, no items of non-
compliance or deviations were identified.
i
I
31
l
!
i
.
.
Prepared By: R. S. Love
c. Corrective Action Systems
(1) Objective
The objective of this assessment was to determine if:
(a) corrective action procedures are adequate.
(b) responsibilities have been adequately defined and that
the affected personnel have been trained and understand
the procedures.
(c) procedures are being effectively implemented. This
includes the areas of tracking and closeout, trending
of nonconformances, and upper management's involvement.
(2) Discussion
(a) Commonwealth Edison Company (CECO)
1. Procedure Review
A review of CECO Quality Procedures QP No. 15-1,
Revision 5, dated January 20, 1981, and QP No. 16-1,
,
Revision 5, dated December 29, 1980, indicates that
they appear to be adequate as relating to Corrective
Action.
Adverse trends and problem areas are brought to the
attention of the Vice President (Nuclear Operations),
Manager of Projects, Project Manager and Manager cf
Quality Assurance.
2 Review of NCR Log
The inspector reviewed CECO's Nonconformance Report
(NCR) log for the years 1979, 1980, and 1981. It
was observed that for the year 1981, 101 NCRs were
prepared and Hold Tags were applied in 96 instances.
In the 5 instances where Hold Tags were not applied,
the item was controlled by a Subcontractors tag or
the NCR was generic in nature.
3. Review of Open NCRs
.
The inspector reviewed eleven open NRCs that
were prepared during 1980. The following.is a
status of these NCRs.
a. F-491, dated April 7, 1980. There is an open
50.55(e) report on this item.
32
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
I
.
b. F-488, dated March 27, 1980. This NCR was
sent to Project Construction Department (PCD)
on May 15, 1980, for implementation of the
disposition.
c. F-526, dated June 27, 1980. This NCR is
still at Station Nuclear Engineering Depart-
ment (SNED) undergoing evaluation.
d. F-539 dated July 22, 1980. This NCR is still
at SNED undergoing evaluation, but, from infor-
mation received by the NRC inspector, the subject
cables have been terminated and energized based
on a " Work can Proceed" notation on the NCR.
e. F-544, dated August 8, 1980. This NCR is still
at SNED undergoing evaluation.
f. F-546, dated August 11, 1980. There is an
open 50.55(e) report on this item.
g. F-563, dated October 22, 1980. This NCR was
sent to PCD on August 27, 1981, for implementa-
tion of the disposition.
h. F-565, dated November 5, 1980. This NCR is
still at SNED undergoing evaluation.
i. F-575, dated November 26, 1980. This NCR
was sent to PCD on January 28, 1981, for
impicmentation of the disposition.
J. F-577, dated December 8, 1980. This NCR
was sent to PCD on February 13, 1981, for
implementation of the disposition.
k. F-582, dated December 12, 1980. This NCR
was sent to PCD on July 14, 1981, for imple-
mentation of the disposition.
Open Item (454/82-05-12: 455/82-04-12)
The NRC is concerned about NCRs that remain open
for an extended period of time in that as the
fuel-load date approaches, there may be a tendency
to accept items without proper engineering evalua-
tion, including back-up data, or to accept items
that should be reworked or repaired. Pending review
of the action taken to close the NCRs listed above,
this is an open item.
33
_ _ _ _ _ _ _ _ _
.
.
4. Review of Voided NCRs
The inspector selected six voided NCRs for review.
The subject procedures do not address voiding NCRs
, but this is an accepted practice in the industry,
when the-NCR is voided for just cause.
a. NCR F-597 was missing from the QA Records
Vault. The NCR log indicated that the NCR
was prepared on January 27, 1981 to document
that Pump Motor OCC01P terminations were
leaking. The log indicates this NCR was '
voided on April 13, 1981. l
b. NCR F-600 was missing from the QA Records
Vault. The NCR log indicated that the NCR
was prepared on February 6, 1981 to document
some damaged cables. The log indicates this
NCR was voided on April 3, 1981.
c. NCR F-634, dated March 23, 1981, was prepared
to document a minimum bend radius violation
on cable IRH119 and to point out that the
cause of the bend radius violation was that
the weight of the cable pulled the loop out
of cable tray. ECN 1992 was issued to add
a device to prevent cable slippage. The NCR
was voided on July 24, 1981, without an
evaluation of the subject cable. The licensee
had an inspection / evaluation performed on the
cable on April 7, 1982. Cable was acceptable,
d. NCR F-645, dated May 7, 1981, was prepared
to document that Westinghouse furnished watt-
meters installed on various panels supplied
by Systems Control did not meet the 1% toler-
ance requirements. The NCR was voided on
June 3, 1981. Systems Control letter to
Commonwealth Edison Company, dated August 19,
1981, stated in part, "The wattmeters will be
returned to Westinghouse for repair at their
expense."
e. NCR F-650, dated May 18, 1981, was prepared
to document certain nonconforming hangers.
This NCR was voided on June 3, 1981, because
it was being tracked on Hatfield NCR #298.
f. NCR F-682, dated October 28, 1981, was pre-
pared to document that concrete had been
placed next to a pipe, resulting in a weld
on the pipe becoming unaccessible for inspec-
i
34
.
.
tion under ASME Section XI. ECN 2336, dated
December 8, 1981, was issued to enlarge the
opening around the pipe so the weld would be
accessible for inspection. The NCR was voided
on December 16, 1981, because the ECN resolved
the problem.
Noncompliance (454/82-05-13a; 455/82-04-13a)
The items listed in peragraph1 ci d and f1 above
are exempics of improperly voided nonconformance.
For item c 2the issuance of the ECN 1992 was a
good corrective action to prevent recurrence but
did not resolve the bend radius violation. For
item d2 the return of the instruments to Westing-
house for repair was a good resolution to the
problem, net reasoning for voiding. Again, the
issuance of the ECN 2336 was satisfactory resolution
to the problem identified in item f2 not a reason
to void the NCR. Improper voiding of the NCRs.is
an item of noncompliance with Criterion XV of 10
CFR 50, Appendix B.
5. Review of Closed NCRs
On April 1, 1982, the Region III inspector reviewed
the following NCRs for proper closure and for cor-
rective action to prevent recurrence:
F-562, dated October 14, 1980, closed January 6, 1982
F-627, dated March 24, 1981, closed January 6, 1982
F-635, dated March 24, 1981, closed June 22, 1981
F-656, dated June 12, 1981, closed July 21, 1981
F-673, dated August 17, 1981, closed January 19, 1982
F-687, dated January 8, 1982, closed February 16, 1982
F-683, dated October 2, 1981, closed February 11, 1982
6. Review of Trend Analysis
On April 1, 1982, the Region III inspector reviewed
the trend analysis of NCRs prepared by CECO. This'
trend analysis is prepared by the Projects Engineer -
ing Department (off-site). Reports dated January 8,
1981, March 19, 1981, September 17, 1981, October 21,
1981, November 12, 1981, December 17, 1981,
January 12, 1982, January 20, 1982, and February 17,
1982 were reviewed during this inspection. All of
the aforementioned reports had the notation, "No
trends are evident" or "No trends could be identified."
CECO QA (on site) does perform a trend analysis on
contractor's nonconformances. On the trend anhlysis
reviewed, they agreed with the analysis being per-s
formed by the individual contactors. J )
35
t
s
~
.
.
7. Interviews with Personnel
Interviews with Ceco personnel indicate that they
appeared to be knowledgeable in their own procedures
on Corrective Action as well as their contractor's
procedures.
(b) Blount Brothers Corporation (Blount)
1. Procedure Review
Blount utilizes a Deviation Report (DR) System
versus an NRC system. If a DR requires CECO
Project Engineering approval, CECO transcribes
the information from Blount's DR onto a CECO NCR
which is then forwarded to Project Engineering
for approval.
A review of Blount's procedure number 4, Inspection
Nonconformances and Corrective Action, Revision 8,
Issue 9, dated February 12, 1981, indicates that
it appears to be adequate as relating to correction
action.
2. 2w of NCRs
The inspector selected several DRs from the DR
log for a detailed review for proper closure and
corrective action to prevent recurrence. Following
is a status of these DRs:
a. Q3-485, dated July 7, 1980. Closed October 14,
1980.
b. Q3-508, dated November 22, 1980. Closed
January 22, 1981.
c. Q3-505, dated December 1, 1980. Closed
February 23, 1981.
d. Q3-494, dated August 25, 1980. Closed June 2,
1981.
e. Q3-545, dated October 19, 1981. As of April 2,
1982, this DR was at CECO for final approval
for closure.
On all DRs reviewed, for years 1980, 1981, and
1982, che action to resolve the nonconformance and
the steps taken to prevent recurrence appeared to
be adequate.
36
,
-<
,3- r - 3 y
'
,
-
. .. , ;u . ~,# .:
w i V ,
.
'
.
,
> -
'
'-
V, ,
- -
,
,,
u a
,
,
- ,
- , .
,
3. Review of Trend An41ysis / o ' *
, . ~
ys , _ ,.
-
Per Blount's procedure, tread smalysis are desu- '
mented annually but a runni'ngf9 Eunt of DRs 'is made /
in each deviation area wb16hf rese.Its in a continuous
trend analysis. The tredds'nuted by the inspector... -
had been documented on Blount's trend analysis'.
"
report. These reports appear -to be given side "'
distributica.and includes a copy to CECO. 4, ,
?
4. Interviews wit _h Persor.hel
"
,
Interviews =with Blount personnel indicate that
the QA Manager was relatively new on the project /
but appeared to have an adequate knowledge of 'W
the procedures. The inspector was inpressed by
the knowledge displayed by the QC Inspector as _ ~
pertaining to the DRs reviewed and the corrective , . . .
action system in general. ,
,
(c) Hunter Corporation (Hunter)
s- ,
-
1. Procedure Reviews -
'
,,
-
~
/-
A review of Hunters S'ite Impler'neitt'ation/ Procedures '
/
Number 11.101, Nonconfec$ance Processing,NRevision '
4, dated April 28, 1981, indicates tha~t it; appears ,
to be adequate as relating to correct,1vp,ections. , . ,
2. Review of NCRs t #
% ^-
,4 %
'
. ,1 ,.
The inspector made a genaral review of approximately '
30 NRs and a detailed review of 10 hTis for proper
closure and for corrective action to prevent *rsturr-
ence. Following is a status.of the NCRs that were
reviewed in detail: f
.- y' .
a. NR-099, dated May 5, 1980. Closed Septebber"16, '
1980.
b. NR-132, dated July 22, 1980. This NR' was pro-
perly voided on August 4, 1980.
""
c. NR-119, drited July 15, 1980. Closed on
December 15, 1980.
d. NR-193, dated January 28, 1981. Closed on
March 18, 1981.
e. NR-263, dated September 17, 1981. Closed on
October 14, 1981.
L NR-151, dated August 4, 1980. Closed on f
February 26, 1981.
E NR-159, dated July 3, 1980. This NR was pro-
perly voided on December 2, 1980.
L NR-204, dated March 17, 1981. Closed on
April 15, 1981.
37
- - -
_ _ .
.
- l
.
.
'
i. NR-231, dated June 5, 1981. Closed on
August 21, 1981.
-
1 NR-262, dated September 11, 1981. Closed on
November 24, 1981.
'
,
3. Review of Trend Analysis
The inspector reviewed the nonconformance (NR)1og
for the years 1980, 1981 and 1982. It was observed
that with the way the NR log was prepared, a trend
, would be observed. The inspector selected two
attributes (unqualified welders and hold points
bypassed) and performed a trend analysis for the
years 1980 and 1981. A review of Hunters trend
'
analysis for the same period of time indicated
'
that the two analysis (Hunter's and the inspector's)
were compatable for the two attributes selected.
'i . Through training, unqualified weld NRs dropped from
, 11 in 1980 to 2 in 1981 and bypassing of hold points
, sf dropped from 23 in 1980 to 11 in 1981. Hunter
'
recognizes that they still have problems with hold
+
points.
,
-
4. Interviews with Personnel
Interviews with Hunter personnel indicate that they
<
appeared to have a good working knowledge of their
system and procedures. Their system and applicable
procedures appear to be adequate.
(d) Powers-Azco-Pope (PAP)
1. Procedure Review
A review of PAP Field Operating Procedure Number
QC-4, Nonconformance Control, Revision 7, dated
September 30, 1981 and PAP Quality Assurance
j Manual, Section B-8, Nonconforming Material and
Parts, Revision 1, dated October 22, 1981, indicates
that they appear to be adequate as relating to
Corrective Action.
2. Review of NCRs
The inspector performed a general review of approx-
imately 30 NCRs and a detailed review of 13 NCRs
and 11 Corrective Actions Requests (CARS). The
following is the status of the NCRs reviewed in
detail:
38
.
.
a. NCR 14, dated July 25, 1980. Closed August 1,
1980
b. NCR 19, dated September 18, 1980. NCR was un-
acceptable, with the note - see NCR 20.
c. NCR 20, dated September 30, 1980. Closed
October 1, 1980.
d. NCR 23, dated September 21, 1980. Closed
June 24, 1981.
f. NCR 44, dated April 3, 1981. Closed April 24,
1981.
g. NCR 39, dated February 27, 1981. Closed
March 4, 1982.
h. NCR 55, dated June 1, 1981. Closed August 13,
1981.
i. NCR 71, dated February 13, 1981. Closed
November 16, 1981.
J. NCR 73, dated July 15, 1981. Closed July 24,
1981.
k. NCR 81, dated July 31, 1981. Closed
November 9, 1981. Re-instruction was required
as part of corrective action.
1. NCR 90, dated September 10, 1981. Closed
January 6, 1982.
m. NCR 117, dated November 20, 1981. Closed
December 28, 1981.
Noncompliance (454/82-05-11d; 455/82-04-11d)
Of the 13 Powers-Azco-Pope NCRs reviewed in detail,
12 of the NCRs did not contain any corrective action
to prevent recurrence which is in violation of PAP's
Quality Assurance Manual, Section B-8, Revision 1,
dated October 7, 1981, Paragraph 13-8.8.2. The li-
censee was informed that this was an item of non-
compliance with Criterion V of 10 CFR 50, Appendix B.
3. Review of CARS and Trend Analysis
Of the 11 CARS generated by PAP as a result of
their trend analysis, the corrective action
appeared to be adequate.
4. Interviews with Personnel
Interviews with PAP personnel indicate that they
appeared knowledgeable in their system and procedures.
j (e) Hatfield Electric Company (HECol
1. Procedure Review
l
l The inspector reviewed HECo Procedure #6, Reporting
i of Damaged or Nonconforming Material or Equipment,
i
l
39
!
.
.
Revision 6, dated January 15, 1982, and Section XVI,
Corrective Action, Revision 5, of the QA Manual.
During review the following observation was made.
Noncompliance (454/82-05-09b; 455/82-04-09b)
The only reference to corrective action to prevent
recurrence in the above mentioned procedures is in
Section XVI, Paragraph 2.4, of the QA Manual. This
paragraph discusses corrective action for adverse
audit findings. The NCR form in use at the Byron
Station, as contained in procedure 6 has a section
titled " Action to Prevent Recurrence" but there is
no directions in the body of the procedure for this
section.
Failure to assure that applicable regulatory require-
ments are correctly translated into procedures and
instructions is an item of noncompliance with Criter-
ion V of 10 CFR 50, Appendix B.
2. Review of NCRs
The inspector reviewed approximately 180 NCRs for
proper closure and for corrective action to prevent
recurrence. The NCR log in use when most of the
NCRs were prepared did not provide a description
of the nonconformance, resulting in a larger number
of NCRs reviewed. The following observations were
made,
a. NCRs 98, 99, and 100 were prepared to docu-
ment a violation of concrete expansion anchor
(CEA) edge distance. The NCRs were voided on
February 25, 1980, because an FCR was or will
be issued to accept the CEAs as installed.
One FCR (2500) was not issued until July 16,
1980. By voiding the NCRs, they were removed
from the trending system. After this was
pointed out by the NRC, the contractor pre-
pared NCR 432, dated April 9, 1982, to docu-
ment the items originally contained in NCRs
98, 99, and 100,
b. NCR 168, dated March 2, 1981, documented that
a cable was deformed at routing point 1899B.
CECO engineering evaluated the cable and dis-
positioned the NCR as " Remove, Damaged Cable"
and pull a nec cable. Hatfield made the
decision, without CECO's concurrence, that
the subject cable did not need to be replaced.
The NCR was closed on August 22, 1981.
40
_ __
_ _ . _ _
.
.
i
c. NCR 154, dated February 24, 1981, documents
that cables 1FW441, 1FW482, and 1DC198 were
damaged and the disposition was to replace the
cables. Review of records indicate that cable
IDC197 was pulled out and scrapped on June 4,
1981 instead of cable IDC198. The NCR was
closed on June 4, 1981. A review of cable pull
cards for cables IDC197 and 1DC198 indicated
that IDC197 had been pulled and scrapped on
June 4, 1981, and that 1DC198 was initially
pulled on July 24, 1981. On April 6, 1982,
the HECo QA Manager corrected the subject NCR
and the attached documentation.
d. NCR 107, dated March 21, 1980. Closed
November 21, 1980.
e. NCR 97, dated February 20, 1980. Closed
August 21, 1981.
f. NCR 152, dated February 23, 1981. Closed
June 24, 1981.
g. NCR 164, dated March 2, 1981. Closed
August 15, 1981.
h. NCR 160, dated February 16, 1981. Closed
September 3, 1981.
i. NCR 103, dated March 6, 1980. Closed
January 8, 1981.
1 NCR 184, dated March 4, 1981. Closed June 8,
'
1981.
k. NCR 177, dated March 4, 1981. Closed March 23,
1981.
The inspector reviewed 42 NCRs generated between
1
September 15, 1981 and February 15, 1982. The
,
following is a status of the disposition of the
subject NCRs:
J 23 - Use-as-is, FCR issued
I
4 - Repair the item
4 - Open as of April 7, 1982
3 - Voided
2 - Replace the item
1 - FCR issued to add side rails
1 - Reject the item
1 - Reorder replacement item
1 - Retrain the cables
41
- . - _ . - -- .- - . _ -
. ..
.
.
.
1 - Closed - Being tracked by CECO NCR
1 - Clean the item
42
Noncomplainee (454/82-05-13b; 455/82-04-13b
The licensee was informed that items a and b
above are additional examples where NCRs were
improperly closed / voided and is an item of non-
compliance with Criterion XV of 10 CFR 50,
Appendix B.
3. Review of Trend Analysis
A review of Hatfields trend analysis .for 1981 and
1982 indicates that it was adequate.
4. Interviews with Personnel
Interviews with HECo personnel indicate that they
appeared knowledgeable in theie procedures and
system.
Except as noted, within the areas inspected, no items of
noncompliance or deviations were identified.
l
42
-
.
.
Prepared by: H. M. Wescott
d. Design Change Control
(1) Objectives
The objectives of this assessment were to ascertain that,
site design change interfaces are clearly defined and im-
plemented, design change control is adequate, personnel
understand and use appropriate procedures, and that the
procedures are being implemented to assure the timely
revising and distribution of drawings.
(2) Discussion
(a) Review of QA Manuals and Procedures
The inspector examined QA Manuals and Implementing
Procedures as follows:
1. Nuclear Power Services, Section No. 3, Revision 1,
dated December 30, 1980, " Design Control".
2. Powers-Azco-Pope QA Manual, Section B.1, Revision
1, dated October 7, 1981, " Design and Document
Control".
3. Hunter Corporation QA Manual, Section 2, Revision 5,
dated August 1, 1981, " Drawing and Specification
Control".
4. CECO QA Manual, Quality Requirement, QR No. 30,
Revisions 1, 3, 13, and 18, dated December 29,
1980, December 29, 1980, September 9, 1980, and
December 29, 1980 respectively, " Design Control".
5. CECO QA Manual, Quality Procedure, QP No. 3-2
thru Revision 13, dated November 12, 1981, " Design
Change Control".
l 6. Johnson Controls, Inc., QA Manual, Section 4,
'
Revision 0, dated June 29, 1978, " Design Control".
7. Byron Site Instruction No. 20, Revision 8, dated
December 17, 1981, " Instruction for Site Design
Document Receipt, Distribution and Control".
8. Byron Site Instruction No. 21, Revision 0, dated
i
July 13, 1978, "ECN Routing".
9. Westinghouse Policy / Procedure, WRD-OPR 3.0,
Revision 2, dated March 20, 1981, " Design Control".
l
43
_ _ . , _- ._ . - . _ , . _ - . . . . . _ . _ , .__ ,__ . . _ _ - - _ - - - , _ -. _ _ _ _
.
.
10. Westinghouse WRD-OFR 3.1 " Reactor Coolant System
Design Definition (Power Capability Working Group)"
Revision 3, dated March 22, 1981.
11. Westinghouse Instruction / Guidance SMD 1.4, Revision
4, dated January 18, 1982, " Byron Unit 1 Engineering
Change Notice".
12. Westinghouse Instruction / Guidance SMD 1.5, Revision
0, dated October 31,^1980, Byron Unit " Field Change
Requests".
13. AZCO Field Procedure FP-9, Revision 6, dated
December 21, 1981, " Design Change Control".
(b) Review of Audits of Site Contractors
The inspector reviewed CECO's audits of site contractors
concerning design change control as follows:
1. Sargent and Lundy Nos. 6-81-301, 6-81-314, 6-81-339
and 6-28-07.
2. Westinghouse SAMU No. 6-81-317.
3. Powers-Azco-Pope Nos. 6-81-326, 6-80-247 and
6-82-10,
4. Nuclear Installation Service Company Nos. 6-81-311
and 6-80-281.
5. Hatfield Electric Company Nos. 6-80-254 and 6-81-331.
6. Hunter Corporation Nos. 6-82-09 and 6-81-350.
7. Blount Brothers Corporation Nos. 6-80-248, 6-81-294
and 6-82-02.
8. Johnson Control, Inc. No. 6-80-250.
9. Hunter Corporation, Hatfield Electric Company,
Reliable Sheet Metal Works, Inc., Powers-Azco-Pope
Services, Inc., Blount Brothers Corporation,
Westinghouse SAMU, Pittsburgh Testing Laboratory,
and Nuclear Installation Services Company
No. 3/8-10/82.
(c) Review of Design Specifications
The inspector reviewed design specifications as follows:
4L
--. _
'
.
.
1 Certified piping design specification for the
" Outdoor Essential Water System" dated February 19,
1982.
! 2. Certified piping design specification for the
" Indoor Essential Water System" dated December 14,
1981.
3. Certified design specification for the " Reactor
Vessel" dated May 15, 1972.
. 4. Design Criteria for Category 1 Cable Tray, Cable
Tray Supports, Bus Duct Supports, HVAC Duct Supports,
Conduit and Conduit Supports, DC-51-03 BY/BR.
It is noted that item 2. above did not have the Pro-
fessional Engineer's Seal for Certification. Sargent
and Lundy further researched ten piping design specifi-
cations and found threa that did not have the required
'
seal. These were to be revised to include the seal by
April 23, 1982.
(d) Review of Control of Field Change Requests (FCR's) and
Engineering Change Notices (ECN's)
The inspector randomly selected fifteen (15) FCR's and
three (3) ECN's at Powers-Azco-Pope, seven (7) FCR's
at Hatfield Electric Company, and three (3) ECN's at
Westinghouse SAMU. They were verified to be under CECO
control. Additionally five (5) traveller packages for
in-process welding were verified to have the correct
drawing revisions in place.
'
The following are the totals of FCR's and ECN's issued
as of this inspection:
Electrical FCR's 4,492
Mechanical FCR's 13,702
Structural FCR-s 101
- Mixed FCR's 4,999
ECN's 2,454
TOTAL 25,746
- Mixed FCR's contain all disciplines prior to separation
by discipline.
(e) Review Site Design Change Interface
i
The inspector reviewed the following:
45
_ - - __ . _ _ _ _ _ __ ._ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _
-
i
i
i
1. Interface Control Agreement, Westinghouse Piping
and Structural Evaluation Program for the Byron
- Station Unit 1, dated October 13, 1980. Paragraph
'
4.3 states that, "The Byron Project Engineering
Organization,-as the Owner, has overall responsi-
! bility for the activities described in this
agreement."
2. Flow Chart for routing CECO Field Change Request,
Byron Site Instruction No. 10, Revision 5, dated
March 25, 1982.
! (f) Personnel Interviewed
The inspector interviewed personnel from CECO, Westing-
house, Powers-Azco-Pope, Sargent & Lundy, Hatfield
Electric Company, and Hunter Corporation.
i Within the areas inspected no items of noncompliance or
l deviations were identified.
1
4
,i
l
f
i
,
d
)
e
1
46
i
- . , _ . _ . _ . , _ - . _ _ . - , . _ , - - _ _ - _ - , _ _ _ . -m. .,, ., _ _._, -. . . _ , . _ . . _ . - . _ _ . - _ _ . _ _ _ . ,
. - --- -. -
.
.
Prepared By: E. H. Nightingale
4
c. Material Traceability of Installed Structures and Components
(1) Objective
The objective of this assessment was to determine that
material traceability was maintained from procurement
through installation for structural beams, small bore
piping and welding materials.
(2) Discussion
The following contractors were involved and their areas of
responsibility are as indicated:
Hatfield Electric Company: Cable Trays
Hunter Corporation: Small Bore Pipe Systems
Powers-Azco-Pope: Small Bore Piping Systems
Blount Brother Corporation: Structural *
,
(a) Hatfield Electric Company
1. Review of Procedures
,
The following site procedures were reviewed:
- 5, Class I Materials and Equipment, Receiving
and Inspection
- 13AA, Class I Shielded Metal Arc Field Welding
(S.M.A.F.W.)
- 13AB, Class I S.M.A.F.W. (Procedure Qualifica-
tion)
- 13AC, Qualification of Welders
i
- 13AD, Arc Welding Electrode Control
'
2. Review of Records
The documents reviewed for material traceability ;
were as follows:
. Weld Material Request
. Material Certification
. Weld Rod Request
. Weld Data Sheet
. Weld Material Issue Tag
47
. . _ . -_ _ - - , . - - _ _ _ , -__ __ _. .
_ _ - - .-_
-.
.
.
3. Review of Welder Qualification
The review of welder qualification records consisted
of reviewing the original qualification records as
well as the supportive documents pertaining to
their "up-date" qualification records. Hatfield
,
Electric Company welding efforts are to AWS Code
which requires six (6) month re-qualification
periods.
The following welders had their certification and
qualification records reviewed:
'
Name Welder ID#
N. Larrabee WW
C. W. Werner W
J. A. Dickson -MM
Greene CG
R. S. Glenny CF
C. Stagg CS
W. McVay BM
D. Gavin DG
T. Whitcomb TV
F. Plegge FP
These ten (10) welders are representatives of the
sixty (60) welders qualified by Hatfield and are
presently on site.
3
4. Review of Weld Material Control
!
The review of weld material control procedures and
direct observation of in process activities
indicate that sufficient efforts are being im-
plemented to assure material traceability and
, control.
Open Item (454/82-05-14; 455/82-04-14)
The Hatfield daily weld rod issue log did not
indicate the actual time weld rod was issued and
returned. The log only noted "a.m." or "p.m.".
The licensee has provided information to indicate
that Hatfield form HP-13AD-1 has been revised to
i
include provisions for the actual rod issue and
return times. This item will be reviewed during
j a future inspection.
(b) Hunter Corporation-
e
1. Review of Procedures
.
'
48
. ._ . - - , -_ ., -, ..- -. - , - ,
.
.
The following site implementation procedures were
reviewed:
1.601, QA Procedures and Instructions
3.102, Material and Services Procurement
3.602, Material Received and Inspected
5.101, Weld Filler Material Control
5.201, Welding Procedure Qualification Control
5.301, Welding Qualification
5.501, Weld Material Issuance
6.002, Visual Exaaaaation and Verification
6.501, NDE
2. Review of Records
The inspector selected three (3) safety related
small bore piping systems for review of material
traceability. The review of the data packages
consisted of documentation from the purchase order
to installation of the item. The systems involved
were as follows:
. Safety Injection (3)
Reactor Coolant (2)
.
Chemical Volume (4)
The documents reviewed were as follows:
. Material / Services Request
. Material Receiving Report
. Receipt Inspection Checklist
. QA Documentation Requirements List
. Material List
. Requisition
. Shipping Order / Packing Slip
. Material Certificate
. NDE Request
. Process Sheet
. Weld Record
. Material List
. Material Certification
. Weld Material Issue Report
The inspector reviewed data packages for the
following small bore piping systems:
SYSTEM SPOOL PC ITEM HT # MATERIAL REPORT
1016-S-CV-001 2 2" sch/160 462460 MSR 4967
1016-S-RC-001 1 2" sch/160 462460 MSR 4967
CECO-S-RC-001 105 3/4" sch/160 483245 MRR 9575
1016-S-SI-001 5 2" sch/160 462460 MSR 4967
1016-S-SI-001 16-5 2" sch/160 462460 MSR 4967
49
.
.
SYSTEM SPOOL PC ITEM HT # MATERIAL REPORT
1018-S-CV-100 1-5 3/4" sch/40 462224 MSR 4967
1016-S-CV-100 8-7A 2" sch/160 462460 MSR 4967
1016-S-CV-100 9-8 2: sch/160 462717 MSR 4967-
1065-S-SI-100 29-10 1" sch/160 HD7123 MSR 4967
The total footage involved consisted of 19,884'.
An expanded study of small bore piping was made
to include valves and fittings. Data packages
for the following items were reviewed:
NAME LOCATION SYSTEM SPOOL MRR
Globe Valve IRC8039B S-RC-001-51 2 10084
M.O.V. IRC8037B S-RC-001-51 2 10062
M.O.V. 1-SI-8871 S-SI-001 33 10144
NAME TYPE HT # SPOOL MRR
CPLG Fitting 2.0" 6000# S.S.-S.W. TL 2 496h
CPLG Fitting 3/4" 6000# S.S.-S.W. EGJ 2 5338
3. Review of Welder Qualification
The review of welder qualification records consisted
of reviewing the original qualification record as
well as the supportive documents pertaining to their
"up-date" qualification record. Hunter Corporation
welding efforts are conducted to the ASME Code which
requires three (3) month re-qualification periods.
Hunter Corporation routinely re-certifies their
wolders in two (2) month periods to preclude any
loss of certifications due to vacations, illness,
etc.
The following welders had their certification and
qualification records reviewed:
NAME WELDER ID #
R. Sturm D40
l B. Strom B17
'
D. Colby E52
R. Decker ,
A38
D. Upstone F19
, E. Baker E56
B. Burns
'
E82
1 R. Bilyeu B91
4
1
50
,
-_. ., m., _ - . . ._ --- _ - . . . ~ . _ - - -
.
.
NAME WELDER ID #
A. Arnold E48
V. Burdene C19 l
D. Radke A12 l
L. Anderson F3
These twelve (12) welders are representative of
the 237 welders qualified by Hunter Corporation
and are presently on site.
4. Review of Weld Material Control
The review of weld material control procedures and
direct observation of in-process activities indicate
that sufficient efforts are being implemented to
assure material traceability and control.
The documents reviewed for material traceability
are as follows:
. Weld Material Stores Requisition
. Purchase Requisition
. Materials / Services Request
. Material Receiving Report
. Receipt and Inspection Checklist
. Material Certificate
(c) Powers-Azco-Pope
1. Review of Procedures
The following procedures were reviewed:
. QC-4, Nonconformance Control
. FP-2, Control of Procurement and Requisitioning
of Material and Services
. FP-3, Material Receiving, Inspection Control
. FP-5, Weld Filler Material Control
. FP-6, Material Handling
. FP-7, Transfer Package and Weld Record Control
. WE-2, Welders Performance Qualification and
Control
2. Review of Records
The inspector selected three (3) safety related
small bore piping systems for material traceability
review. The review of the data packages consisted
of documentation from the purchase order to in-
sta11ation of the item involved. The systems
selected were as follows:
51
.
.
.
. Reactor Coolant
The documents involved for review were as follows:
. Weld Filler Material Requisition
. Receiving Inspection Check List
. Final As-Built Isometric (Supplement Weld and
Inspection Record)
. Material Certification
. Weld Rod Issue Tag
. P.O. (CECO Responsibility)
. NDE Records
A study of the data packages, for the systems
selected, consisted of the following items:
SYSTEM PIPE SIZE HT # REC. & INSP. ISO #
Report #
RX Coolant 0.50" 462,444 MRR# 7074 IF1S-418B
Feed Water 0.50" M81,577 RIR# 040 ILT-542
Feed Water 0.50" D85,772 RIR# 040 1LT-542
Feed Water 0.50" E89,871 RIR# 040 ILT-542
Containment 0.50" 744-783 MRR# 7074 IFT-CS011
Spray
Total footage of piping involved consisted of 27,900'.
The suppliers of weld material for the Byron facility
is Hunter Corporation. The pipe materials are
supplied to the small bore piping contractors by
CECO. Therefore, purchase orders are originated
from these two (2) sources. This system of pur-
chasing in large quantities by one contractor /
l licensee enhances material traceability.
An expanded study of small bore piping was made to
include valves and fittings. Data packages for
the following items were reviewed:
FIELD REC & INSP.
i
ITEM HT# WELD # REPORT # ISO #
<
, Coupling EGJ 41 057 IPT-RC009
90 Elbow OZ 52 131 1PT-403
Valve 1RV048 N/A 20049 11J-461
S/N N11591
Valve IRC025E N/A 230 1FT-415
S/N N11526
52
.-- _
.
.
.
, 3. Revieu of Welder Qualification
The review of welder qualification records con-
sisted of reviewing the original qualification
record as well as the sLpportive documents per-
taining to their "up date" qualificiation record.
PAP welding efforts are conducted to the ASME
Code which requires three (3) month re qualifica-
tion periods.
The following welders had their certification and
qualification records reviewed:
Name Welder ID#
B. Strom CS
R. Sutherland AF
H. Arteaga DU
L. Flynn DX
D. Tucker BH
H. Mitchell AJ
R. Boyle BM
D. Shurely CE
P. Meyers DE
W. Meyers DG
These ten (10) welders are representative of the
46 welders qualified by PAP and are presently on
site.
4. Review of Wold Material Control
The review of weld material control procedures
and direct observation of in process activities
indicate that sufficient efforts are being impli-
, mented to assure material traceability and control.
The documents reviewed for material traceability
are as follows:
. Weld Filler Material Requisition
i
. Receiving Inspection Check List
. Material Certification
l . Weld Rod Issue Tag
. Weld and Inspection Record
(d) Blount Brothers Corporation
1. Review of Procedures
, The following procedures were reviewed:
I
53
,
- ~ - - - - - , - , - - _ , - , . - . . , - - - , , ,-- ,- , - -
.
.
,
. QC 3385 #1, Document Control
. QC 828 #2, Procurement Control
. QC 3012 #4, Inspection (Nonconformance
and Corrective Action)
. QC 3262 #7, Calibration of Tools, G@uges
and Instruments Concrete)
. QC 835 #10, Receiving, Storage and Handling
. QC 3333 #11, Welding - (AWS D1.1) 1974
i . QC 845 #21, Structural Steel Erection
. QC 1992 #33, Personnel Qualification and
Certification
2. Review of Records
The inspector selected nine (9) structural beams
for material traceability. Beams selected were
three from Unit #1 containment building and three
beams from Unit #1 auxiliary building. Three
'
more beams were selected from Unit #2 containment
building.
Beams selected were as follows:
Beam I.D. Building Unit # Drawing #
a A220B2 Containment 2 E-205
A230BB3 Containment 2 E-205
A240BB1 Containment 2 E-205
A132B5 Containment 1 E-102
B111BB2 -Containment 1 E-102
B104BB1 Containment 1 E-102
333B3 Auxiliary 1 E-201
326G1 Auxiliary 1 E-201
603B1 Auxiliary 1 E-201
The inspector reviewed the data packages for the
following structural steel for material traceability.
Beam # 326G1 -
Film Roll 3 -
Dr. #326
Index # Heat # S&L Letter Date
440 2R6969 12-28-76
j 435 J-31694 11-30-76
464 96266 12-28-76
474 96723 11-29-76
461 63062 11-08-76
i
Mill B8 L511159 02-28-77
Beam # 333B3 -
Film Roll 3 -
Dr. #333
54
- , __ . - _-, -
- _--. _-
.
.
Index # Heat # S&L Letter Date
351 K-24080 11-10-76
474 96723 11-19-76
Beam #B104BB1 -
Film Roll 1 -
Dr. #B104
Index # Heat # S&L Letter Dale
11133 69C076 06-29-77
11127 69C050 07-01-77
90126 66C242 07-01-77
90127 69C167 08-10-77-
80123 63729 05-26-77
Beam #A230BB3 -
Film Roll 1 - Dr. #A230 - 80230
-
Index # Heat # S&L Letter Date
38 70C576 02-07-78
62 K58219 02-06-78'
K58377 02-06-78
573 T47512 06-26-78
S-22 87495 06-27-78
Beam #B111BB2 -
Film Roll 1 -
Dr. #B111B
Index # Heat # S&L Letter Date
11113 VY4703 07-01-77
11106 70C266 07-01-77
90126 66C242 07-01-77
90127 69C167 08-10-77
80123 63729 05-26-77
Beam #A220B2 -
Film Roll 1 -
Dr. #A220
Index # Heat # S&L Letter Date
B-9 J-51717 12-13-77
S-43 44B489 07-19-78
B-1 A-325 Bolts 09-12-78
B-2 A-325 Bolts 06-09-78
Beam #A132B5 -
Film Roll 1 -
Dr. #A132
Index # Heat # S&L Letter Date
80135 24456 05-26-77
C-80119 W35079 07-11-77
A-80190 B-34009 08-10-77
55
.
.
Beam #603B1 -
Film Roll 3 -
Dr. #603
Index # Heat # S&L Letter Date
l
1407 10005 03-04-77
287 18216 10-12-76
Beam #A240BB1 - Revised to Beam #E144-1
S&L Drawing S-1001, Revision H. , Dated 3-16-78,
Note 10. Fabricated by Midcity Architectural
Iron Company (on-site contractor).
Heat # K62702 and #83833
A-325 Bolts - C6810; 4048
,
3. Review of Welder Qualifications
The review of welder qualification records consisted
of reviewing the original qualification reccrd as
well as the supportive documents pertaining to
their "up-date" qualification records. Blount
Brothers Corporation welding efforts are to AWS
Code which require six.(6) month re qualification
periods.
The following welders had their certification and
qualification records reviews:
j Name Welder ID #
K. Knaub K-5
R. Long K-4
P. Fadness P-4
1
R. Sullivan B-4
D. Lower L-4
W. Thompson V-4
K. Flosi W-3
R. Schusler V-18
K. Todo Y-4
D. S. Wielan D-5
The ten (10) welders are representative of the
fifteen (15) welders qualified by Blount Brothers
Corporation and are presently on site.
4. Review of Weld Material Control
The review of weld material control procedures and
direct observation of in process activities indicate
- that sufficient efforts are being implemented to
- assure material traceability and control.
i
- 56
.- . . - _ _ _ , _ - . _ .
.
.
The documents reviewed for material traceability
are as follows:
. Material Requisition
. Receiving Inspection Report
. Material Certification
. Weld Material Issue Sheet
. Weld Data Report
Within the areas inspected, no items of noncompliance or
deviations were identified.
57
- _ _ .
,
.
, .
Prepared By: R. S. Love
f. Electrical Cable Installation
(1) Objective
The objectives of this assessment were to determine if:
. cable installation procedures are in accordance with
FSAR commitments and that they are adequate for con-
trolling cabic installation activities.
. the cable installation personnel and QC inspectors have
been adequately trained in this activity.
. safety related cables are routed, separated, and loaded
in accordance with procedure requirements.
(2) Discussion
(a) Review of Electrical Procedures
The inspector reviewed the following Hatfield Electrical
Company procedures:
1. Procedure No. 5, Class I Material and Equipment
Receiving and Inspection, Revision 4, Issue 1,
3 dated January 26, 1981. This procedure was
l reviewed and accepted by Sargent and Lundy on
l January 27, 1981.
2. Procedure No. 6, Reporting of Damaged and Noncon-
forming Material or Equipment, Revision 6, dated
January 15, 1982. This procedure was reviewed and
accepted by Sargent and Lundy on February 11, 1982.
3. Procedure No. 9-A, Class I, Cable Pan Hanger Instal-
lation, Revision 11, dated November 20, 1982. This
procedure was reviewed and approved by Sargent and
Lundy on December 23, 1981.
i
4. Procedure No. 9-B, Class I, Cable Pan Installation,
Revision 9, dated November 20, 1981. This procedure
was reviewed and approved by Sargent and Lundy on
l December 23, 1981.
5. Procedure No. 9-E, Class I, Cable Pan Identification,
Revision G, Issue 1, dated January 23, 1981. This
,
'
procedure was reviewed and approved by Sargent and
Lundy on January 26, 1981.
,
58
I
l
,- - , .
. . - - - _ _ -- , .-. ,- , --
.
.
6. Procedure No. 10, Class I, Cable Installation,
Revision 14, dated February 8, 1982. This proce-
dure was reviewed and approved by Sargent and Lundy
on February 18, 1982.
Open Item (454/82-05-15; 455/82-04-15)
Procedure No. 9-B, Class I, Coble Pan Installation,
Revision 9, dated November 20, 1981, did not address
the installation of cable pan and riser covers. The
inspector was informed that Procedure No. 9-C would
address the installation of covers as required by
the Byron /Braidwood FSAR. This is an open item.
Unresolved Item (454/82-05-16; 455/82-04-16)
During review of Procedure 9-E, Class I, Cable Pan
Identification, Revision G, Issue 1, dated January 23,
1981, the inspector observed that paragraph S.3.1
of the subject procedures states in effect that the
requirements to apply segregation identification to
raceway at a minimum of every 15' does not apply to
risers. This is contrary to the requirements stated
in paragraph 5.1.2 of IEEE 384-1974. Pending a review
of installed riser identification markings for compli-
ance to requirements, this item is an unresolved item.
Noncompliance (454/82-05-09c; 455/82-04-09c)
During review of Procedure No. 10, Class I, Cable
Installation, Revision 14, dated February 8, 1982,
the inspector observed that the subject procedure
does not address:
a. the requirements to calculate electrical cable
sidewall pressure. Maximum cable sidewall pres-
sures are specified by the cable manufacturers,
b. electrical cable rework. Example - An electrical
cable has been installed per Revision A of the
cable pull card and Revision B of the pull card
requires that the cable be " pulled back" to a
given point in the raceway system and re-routed
to a different landing point. What precautions
are taken to prevent damage to the cable being
" pulled back" and to the cables remaining in
the raceway. This would be especially important
when the cable was installed in conduit or duct
banks. Another example would be that as a result
of an NCR, a cable had to be removed (Ref.
Hatfield NCR's 164, 154, 107).
Failure to provide adequate instructions or procedures
to accomplish activities affecting quality in accord-
ance with Quality Assurance Program provisions is an
59
1
.
.
item of noncompliance with Criterion V of 10 CFR 50,
Appendix B.
(b) Review of Storage Facilities - Cable Yard
The inspector toured the Hatfield Electric Company
cable reel yard to verify proper storage and to select
several cable reel numbers for follow-up review of
material receiving reports and vendor documentation.
The cable reels were stored on dunnage (plywood),
identified, and separated as to cable type. Electrical
cable reel numbers 02146-409, 04146-215, 03367-7, and
01135-43 were selected for records review.
(c) Review of Electrical k'ork Activities
1. During a tour of the power block the inspector
observed that the weld heat affected zone inside
cable tray 11774J-C2E, located at the 439' eleva-
tion of the cable spreading room, had not been
touched-up with zinc rich paint in accordance with
Hatfield Electric Company Procedure No. 9-B, Class
I, Cable Pan Installation, Revision 9, dated
November 20, 1981.- The licensee took immediate
action to have the subject area cleaned and galva-
noxed. This was the only area identified where
the weld or heat affected zone had not been
touched-up.
2. The inspector observed that non-safety related
pipe number FP-41-4-10" was installed 3 1/2" from
safety related cable tray number 11461J-C2E.
These items are located in the Auxiliary Building
between column lines 17 and P at the 426' eleva-
tion. Further investigation indicates that the
fire protection (FP) system is classified as
moderate energy piping and is seismically supported
in the area observed. This appears to meet the
intent of Regulatory Guide 1.29, Seismic Design
Classification.
3. The inspector verified that electrical cable
i number IVX105 was routed in accordance with the
cable pull card, Revision A. The subject cable
is a 12c/14, 600V and was pulled from cable reel
12146-201. The cable extends from 1AP32E (MCC
j 132X5) to IVX02J (Vent System Local Control Panel).
l
The cable was physically verified in routine points
11461J-C2E, 1R369-C2E, 1910F-C2E, IR353-C2E,
11375M-C2E, and verified that the cable entered
, the conduit to the equipment,
i
l
60
_-- -
2 *
.
The raceway was accepted on January 18, 1982, and
cable pulled on January 19, 1982.
! 4. During discussions with an electrical foreman and
one electrical craftspersor., the inspector observed
that, with respect to cable pulling, they were very
knowledgeable and proud of their work. The subject
craftsperson assisted the inspector in verifying
the routing of electrical cable IVS105 (Ref. Para-
graph (c)3 above).
(d) Review of Procurement Documentation - Class IE Cable
The inspector reviewed the procurement documentation
relative to 600V and SKV electrical cable. The inspector
reviewed the cable specifications, Material and Equip-
ment Receiving and Inspection Reports (MRR), and vendor
documentation. The following observations were made:
1. The licensee purchased the following electrical
cable from Okonite Company to Sargent and Lundy
specification F-2823.
a. Cable reel number 02146-409 containted 2500
feet of 2c/14, 600V cable and was received
May 11, 1981 on MRR 50217.
I
b. Cable reel number 04146-216 contained 3124
feet of 4c/14, 600V cable and was received
April 22, 1980 on MRR 8569.
c. Cable reel number 03356-7 contained 2060 feet
of 3c/350 MCM, 600V cable and was received
October 4, 1978 on MRR 4187.
The following data was included in the on-site
i
documentation packages for the above listed cables:
. Certificate of Compliance
. Certificate of Conformance
. Certified Test Report
. Results of Water Absorption Test
. Results of Ozone Resistance Test
. Results of High Potential Voltage Test
. Sargent and Lundy letter, dated June 20, 1980,
that accepted the results of Flame Tests and
Tests for Design Basic Events.
2. The licensee purchased electrical cable, reel
number 01115-43 from Okonite Company to Sargent
and Lundy specification F2851. This reel contained
1094 feet of Ic/1000 MCM, SKV cable and was received
61
1
,m- - - , .- . ,. - . - - p , . _ , , . ~ ~ . - ,- - - < - - - -
- _ . - - .- - .-. .
,
,
!
July 11, 1979 on MRR 7032. The following data was
included in the on-site documentation package for
this cable:
. Certificate of Compliance
. Certificate of Conformance
<
. Certified Test Report
. Results of Water Absorption Test
. Results of Ozone Resistance Test
. Results of High Potential Voltage Test
'
. Sargent and Lundy letter, dated June 20, 1980,
that accepted the result of Flame Tests and
Tests for Design Basic Events.
(c) Review of Class 1E Cable Pull Cards
The inspector reviewed 20 completed cable pull cards
to verify that correct cable type was installed,
raceway was inspected prior to pulling cable, and that
QC accepted the cable pull. The following typical
observations were made:
1. Cable IVX105 was pulled on January 19, 1982 from
Cable Reel 12146-201. Revision A to the cable
pull card indicates the cable type code as 12146
which is 12/c-14, 600 volt cable. The raceway
was accepted on January 18, 1982, and the cable
pull was accepted January 19, 1982. This was a
complete pull.
2. Cable IRC223 was pulled on April 9, 1981 from
Cable Reel 02166-41. Revision A to the cable
pull card indicates the cable type code as 02166
which is one twisted pair, #16 (shielded), 600
volt cable. The raceway was accepted on
!
March 27, 1981, and the cable pull was accepted
April 9, 1981. This was a complete pull.
3. Cable IVC 019 was pulled on June 23, 1981 from
Cable Reel 09146-84. Revision A to the cable
pull card indicates the cable type code as 09146
which is 9/c-14, 600 volt cable. The raceway
was accepted on June 22, 1981 and the cable pull
was accepted on June 23, 1981. This was a
j complete pull.
Except as noted, within the areas inspected, no items of
noncompliance or deviations were identified.
i
1
62
__. _
.. _ _ _ - _ - - . - - - . - ~ _ - - - - . - -
l k 1
'
. 't
i ( $-
l G-
-
.
1
Prepared By: H. H. Wescott
'
i
g. In-Process Inspection ,
j
j (1) Objectives (3l
The objective of this assessment was'to ascertain that ,
, in-process inspection procedures are adequate and properly
implemented. ,
(2) Discussion .
.
j (a) Review of Procedures ;
The inspector reviewed procedures concerning in-process .i
"
inspection as follows:
,
1. Powers-Azco-Pope Quality Control Field Procedure
j FP-7, Revision 6, dated October 16, 1981, " Traveller
j Package and Weld Record Control PAP Isometric and
j
i
Installation Control".
2. Powers-Azco-Pope QC-6, Revision 6, dated
i September 30, 1981, " Quality Assurance Documen-
tation".
4 ,
3. Hatfield Electric Company Procedure 9-A, Revision
11, dated November 20, 1981, " Class I, Cable Pan
Hanger Installation".
! 4 Hatfield Electric Company Procedure 9-B, Revision
9, dated November 20, 1981, " Class I, Cable Pan
Installation".
i
i- 5. Hatfield Electric Company Procedure 20, Revision
- 8, dated November 20, 1981, " Class I, Exposed
'
Conduit System Installation". '
6. Hunter Corporation, Site Implementation Procedure
, SIP No. 1.601, Revision 1, dated March.3, 1981,
j " Quality Assurance Procedures and Instructions". '
! 7. Hunter Corporation, SIP No. 4.201, Revision 4,
i
dated January 19,.1982, " Installation Verification".
I
!
(b) Observation of Work Activities ,
j The inspector accompanied two Hatfield Electric
i Company QC inspectors and observed their inspection
{ of conduit hangers located in the control room.
i
f.
'
The inspector also observed the inspection and torquing m,
of four concrete expansion anchors.
.
'
! 63
!
l
!
_ _ , _ _ _ _ _ _ . _ _ , . . . . _ - . _ , . . . _ _ _ . , , _ _ _ . . _ __-_ _ _ . . _ _
. _ _ . . , _ . , _ , . . _ , , , , , , , , _ , .
. -. . . - _ _ . -
. _ _ . _ _ - . - . .. _ .__ _
._ ,
.
T
. i.
,
.
(c) Review of Records
, The inspector reviewed records as follows:
.
1. Hunter Corporation completed traveller packages
t ? for welds Numbered 45, Part No. 1-SA-76-AD-3;
, ,
3
4 565, Part No. 1-CC-50-B-4"; Numbr.r 571, Part No.
i '
,' 1-CC-50-C-6"; Number 1608, Part No. 1-CC-50-C-6"
rework; Number 1171 and 1178, Line No. 1-D-0-33-CA-
t
3l4".
2. idunter Corporation Field Order JTP No 's 5-PS-100-
i *
78, 5-PS-10-77, HOG-72-1, S-NT-100-2-15-A, and
'
i OG-61-7.
3. Hatfield Electric Company QA Process Sheet File
'
No. 13.09B.1, Class I, Cable Pan Inspection
1
Checklists (approximately 33 checklists).
4. Hatfield Electric Company Concrete Expansion
.< Ancnor File No. 13.25.02, Travellers 1901 thru
- i 1950'.
.,
5. Hatfield Electric Company Conduit Inspection
Reports; File No. 13.20.01, 766 thru 850.
\
(d) Personnel Int'rviewed e
'
The inspector interviewed two QC inspectors from
j Hatfield Electric Company.
i Noncompliance (454/82-05-17; 455/82-04-17)
'
The inspector interviewed four welders performing
in-process safety related welding (two from Hunter
J Corporation and two from Powers-Azco-Pope). Three
) of the welders did not have the welding procedure
,
1 specification (WPS) with the traveller packages.
When the inspector asked where the WPS was, two
i
welders did not appear to know what a WPS was and
I one-stated that he knew the WPS should be in the
j weld materia 1' issue point but stated that he had
l not seen it.
r
This item is considered to be in noncompliance with
the requirements of' 10 CFR 50, Appendix B, Criterion
IX.
l
l Except as noted, within the areas inspected, no items of
noncompliance or deviations were identified.
l
.
l
64
. . _ _ . - - _ _ _ _. _ . .. . ~ . _ , _ _ . _ _ _ . _ - . - _ - _ _
.
.
Prepared By: W. Forney
h. QC Inspector Effectiveness
(1) Objective
The objectives of this assessment were to determine if:
(a) any problems exist that inhibit an inspector from
properly executing his assigned functions.
(b) the training, qualifications, and certification of
QA/QC personnel working for contracting organizations
to the licensee are in compliance with 10 CFR 50,
Appendix B, ANSI N45.2.6-1978; ANST SNT-TC-1A, USNRC
Regulatory Guides 1.58, USNRC Generic Letter 81-01;
CECO Quality Assurance Program Manual; CECO Response
to Generic Letter 81-01 (L. O. De1 George to
D. G. Eisenhut-August 17, 1981); and Contractor Quality
Assurance Manuals.
(2) Discussion
Individuals selected for interview were chosen at random
by the NRC inspector. All contractors utilizing QA/QC
personnel to monitor and accept production activities at
the site were selected. The organizations selected, pro-
duction function monitored by the inspectors, number of
inspectors in the organization, number of inspectors inter-
viewed and percentages are identified in Table 2. Each
inspector interviewed was asked a standard set of questions.
The answers provided were summarized and are provided as
Table 3.
Individuals selected for QA/QC inspector interview were
requested to provide the record of their training, qualifi-
cation and certification to the inspector. Tne inspector
reviewed each of the training, qualifications and certi-
fication records to verify compliance with applicable
, regulatory requirements, standards and commitments. In
'
verifying the implementation of the approved requirements
emphasis was placed on (1) determination of initial cap-
ability by suitable evaluation (2) evaluation of perform-
ance/ reevaluation (3) written certification in appropriate
form (4) physical requirements identified and examined yearly,
and (5) qualification criteria followed and (6) records of
qualification established and maintained.
Table 3 is provided as a summary of inspector answers to the
standard set of interview questions. Answers to questions
1, 2, 4, 5 are self evident and do not require further
definitions. However, the answers to remaining questions
- require further clarification and conclusions.
, 65
i
- - - . .
.
.
Question 3 - relates to the number of inspectors that in-
dicated during their answer to Question 2 that they had
prior inspection experience. Of the 30 inspectors inter-
viewed 47% indicated prior inspection experience; however,
only 27% had prior inspection experience in nuclear work
related activities.
Question 6 - of the 19 inspectors interviewed that regularly
worked frequent or excessive overtime one worked less than
8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> weekly, fourteen worked from 8 to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> weekly,
and four work greater than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> weekly. The two
inspectors that provided qualified answers _ indicated the
overtime was intense at times based upon fluctuations of
production activities. All of the inspectors that answered
yes or qualified their answer were asked if the frequent or
excessive overtime caused the accuracy of their inspections
to be deminished. Without exception, none of the inspectors
felt the accuracy of their inspections were affected.
Question 7 and 8 - the inspectors that provided a qualified
answer to these questions indicated that the lack of adequate
staff and/or failure to conduct inspections promptly were a
result of fluctuations in production activities.
Open Item (454/82-05-18; 455/82-04-18)
Question 9 - indicates that inspectors generally do not
feel they have the authority to stop an activity in their
contractor's work that is not being properly performed,
nor have they been provided written management policy in
this area. The inspectors that provided qualified answers-
indicated that they would inform the area supervisor.
The inspectors were also asked if they felt they could
immediately stop the work activity of another contractor
worker who was performing work that was hazardous to
safety related equipment. The majority of inspectors
indicated they did not have that authority.
The licensee management committed to take actions to
re-emphasize to all inspectors their responsibility to
stop an activity which does not conform to applicable
quality requirements. This item will be examined during
a future inspection.
Question 10 - the majority of inspectors interviewed
indicated that the training they received was adequate
for the work activity they are required to perform. One
inspector did not feel his training was adequate and the
remaining inspectors felt that although their training
was not the best, that if they needed additional guidance
or clarification that management would provide the infor-
mation immediately.
66
O
.
i
Question 11 - indicates that inspectors do not feel that a
lack of inspection personnel is the cause for construction
activities to come to a stop and is consistent with the answers
provided in Question 8.
Question 12 - the inspectors that qualified their answer gener-
ally indicated that their activity did not require a check list
but was normally accomplished utilizing a combination of in-
sta11ation plans and/or procedures.
Question 13 - the inspectors that qualified their answer indi-
cated that they would have to follow the chain-of-command which
could be untimely.
When asked to discuss their opinion of how their management
portrays the relationship of quality to production the majority
of inspectors stated that quality was first and production
second, a number of inspectors stated that quality and produc-
tion were on an equal basis, and a few of the inspectros (pre-
dominately from one contractor) stated that production was
first and quality second.
When asked to discuss their opinion of the overall finished
product of their contractors activities the majority of in-
spectors stated that the work generally exceeded minimum
acceptable standards, a few stated the work generally met
minimum standards, and no inspectors felt that the work did
not meet minimum acceptable standards.
Noncompliance (454/82-05-19; 455/82-04-19)
Based on a review of training qualification and certification
records of a minimum of ten percent of the QA/QC personnel
working for contractors performing safety-related work it is
apparcat that an effective program does not exist to ensure
that a suitable evaluation of initial capabilities is performed,
that written certification is provided in an appropriate form,
and that qualification criteria is established.
Certain contractor QA/QC supervisors and inspectors were not
adequately qualified and/or trained to perform safety-related
inspection functions. The following examples of apparent non-
compliance were identified:
a. Contractor - Reliable Sheet Metal Works, Inc.
(1) The contractor Quality Assurance Manual did not require
inspection personnel to be trained and certified to
ANSI N45.2.6-1978.
(2) The certification record for the QA/QC supervisor did
not contain a satisfactory basis for certification.
(3) The certification record for the QA/QC supervisor did
not contain the level of capability.
67
.
__ __ _ _ . . - _
.
.
b. Contractor - Johnson Controls, Inc.
(1) The certification records reviewed did not contain a
determination of initial capability.
(2) The certificaticn records reviewed did not contain a
copy of the individuals high school diploma or veri-
.
fication of prior work history.
(3) The certification records reviewed did not support
adequate testing prior to certification. It is noted
that testing was accomplished by oral examination
consisting of 25 questions to determine the individuals
knowledge of 26 procedures. The oral examination noted
the individual was weak in ability to work with draw-
ings. However, there is no record to indicate addi-
tional training was provided or that the individual
was subsequently tested and found to be proficient in
his ability to work with drawings.
c. Contractor - Powers-Azco-Pope
(1) The certification records for the QC Supervisor did not
provide an adequate determination of initial capability.
(2) The certification records for the QC Supervisor did not
contain a high school diploma, or verification of pre-
vious employment.
(3) The certification records for the QC Supervisor did not
contain adequate evaluation and justification for certi-
fication to Level I or subsequent certification to
Level II Supervisor.
(4) The certification records for three (3) QC inspectors
did not contain a high school diploma.
(5) The certification folder for three (3) QC inspectors
did not contain verifications of prior employment.
(6) The certification records for the QC Supervisor and
three (3) QC inspectors contain open book examinations
that do not provide an adequate icvel of knowledge
prior to certification. The records did not contain
results of a capability demonstration to support certi-
fication.
(7) The certification records for three (3) QC inspectors
did not contain adequate evaluation and justification
for certification to Level I and subsequent certifica-
tion to Level II inspector.
68
[
.
.
d. Contractor - Hunter Corporation
(1) The certification records for two (2) of the seven (7)
QC inspector qualifications reviewed did not provide
determination of equivalent inspection experience to
support the level of certification.
e. Contractor - Hatfield Electric Company
(1) The certification records for three (3) of the nine
(9) inspector qualifications reviewed did not contain
c Certification Evaluation Sheet.
(2) The certification record for one (1) of the nine (9)
QC inspector qualifications reviewed did not have
records of examinations or work samples.
(3) The certification records for two (2) of the nine (9)
QC inspector qualifications reviewed did not provide
complete evaluation and justification for certification
to perform the level of inspection identified.
f. Contractor - Blount Brothers Corporation
(1) The certification record for one (1) of the two (2)
QC inspector qualifications reviewed did not indicate
the expiration date of certification as a Level I lead
auditor.
g. Contractor - Midway Industrial Contractor, Inc.
-
(1) The certification record for the QC inspector quali-
fications reviewed did not indicate the activities
certified to perform.
,
h. Contractor - Pittsburgh Testing Laboratory
(1) The certification record for one of the three (3)
QC/QA inspector qualification records reviewed did
not have an evaluation of prior work experience.
Based on a sample review of CECO audits conducted in the
area of training Tsalification and certification for the
period 1979-19Fa i+ . 2 determined that a program exists
to routinely review the acceptability of QA/QC personnel.
It was noted that many audit findings were identified and
resulted in notable improvements of contractor adherence
to ANSI N45.2.6-1978. During the meeting conducted April 9,
1982, CECO management committed to develop an alternate plan
for certification of contractor QC inspectors when the
recommendations of ANSI N45.2.6.-1978, Section 3.5 are not
complied with. Additionally, a commitment was made to
require each contractor to verify inspectors education and
experience.
69
_ . . . .. _. . _. . . . . .
. . ,
__
..
.
TABLE 1
Licensee and On-site Contractors
QA/QC Periodic QA/QC
Services # Cract QA/QC Organ. Review of Supv.
Organization Performed Workers Staff Indep. QA Program Pos. Des.
Commonwealth Licensee N/A 16 Yes Yes Yes
Edison
Blount Brothers Plant 220 5 Yes Yes Yes
Structures
Ebasco Services Inservice 10 2 Yes Yes Yes
Inspection
Hatfield Electric Electrical 555 83 No Yes No
l Company Installation
l
Hunter Corp. Piping 944 71 Yes Yes Yes
Systems
Johnson Controls HVAC 47 2 (2) Yes Yes
Controls .
Midway Indust. Field Finish 10 2 Yes Yes Yes
NISCO Mechanical 10 2 Yes Yes Yes
Erector
Nuclear P.S. Mechanical *96 1 Yes Yes Yes
Design
Pittsburgh Testing #28 1 Yes Yes Yes
Test Lab
Powers-Azco-iope Instrumenta- 135 11 No Yes Yes
tion
Reliable Sheet HVAC 37 2 Yes Yes Yes
Metal
Sargent & Lundy A. E. Firld *72 0 (1) Yes (1)
Group
Westinghouse Mechanical *47 0 (1) Yes (1)
SAMU Design
- - Testers * - Engineers
(1) - Not reviewed (2) - Unresolved item
6
70
-. . _. _
.
, TABLE 2
QA/QC INSPECTCR INTERVIEW SUMMARY
Total Inspectors
Organization Function Inspectors Interviewed 1
EBASCO Services Inservice Inspection 2 1 50
NISCO Erect miscellaneous 2 1 50
mechanical equipment,
final setting and
erection of NSSS
equipnent.
Reliable Sheetmetal HVAC 2 1 50
Johnson Controls HVAC Controls 2 1 50
, Powers Azco Pope Instrumentation 11' 4 36.36
(PAP)
Hunter Corporation Piping System 71 7 9.86
Hatfield Electrical Installation 83 9 10.84
Blount Brothers Plant Structures 5 2 40
Pldway Field Finish Coating 2 1 50
Pittsburgh Testing Lab Onsite NDT 28 3 10.71
, TCrrALS 208 30 14.42
!
._ - - - . - - ~ -
--
--
y
.
TABLE 3
.
SUMMARY OF QUESTIONS ASKED
QC/QA INSPECTORS DURING INTERVIEWS
1. How long employed as an inspector 3 mo. 6 mo. 6 no.-l yr.
onsite?
2 4 8
1-2 yr. 2-3 yr. 4 yr.
7 4 5
Yes pig,
2. Prior inspection experience? 14 16
Nuclear Non-Nuclear
3. What discipline (s)? 8 6
Implemented
Qualified
Yes pict Qualified Answer
4. Is there a sense of intimidation 29 1
.
based upon the neeo/ requirement
to keep up with construction?
5. Is there a reluctance to make 29 1
adverse findings if they will
impact on the construction or
audit schedule?
6. Is it routine for QC inspectors 19 9 2
to be working frequent and/or
excessive overtime?
7. Do the inspectors feel that their 19 2 9
particular section is adequately
staffed?
8. Do they feel the required inspections 18 2 10
are being conducted promptly?
9. Do the QC inspectors have stop work 13 3 14
. and/or stop process authority?
Have they ever used this authority? 13 9 8
If so do they feel they were supported 19 1 3 7
or will heve the support of manage-
ment in the event of a stop work?
v
.
"
o
Implemented
Qualified
Yes o
N_o Qualified Answer
10. Do the inspectors feel the 24 1 5
training they have been provided
is adequate?
11. Do situations arise where the 1 27 2
lack of a QC inspector causes
construction activities to come
to a stop?
12. Are the QC inspectors provided 15 15
adequate check lists for all
activities they are inspecting
or are they sometimrs using
vague guidelines?
13. Do they feel that they have an 28 2
avenue to management if they
come across a problem?
Do they feel management will get 27 3
, involved or just pay lip service?
.
o
O