ML20058H880

IE Insp Repts 50-456/82-03 & 50-457/82-03 on 820524-28 & 0601-04.Noncompliance Noted:Failure of Site Contractors to Follow QC Procedures & Failure to Accomplish Activities in Accordance W/Procedures

ML20058H880
Person / Time
Site:	Braidwood
Issue date:	06/30/1982
From:	Danielson D, Love R, Mcgregor G, Neisler J, Nightingale E, Nightingale E, Peschel J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20058H854	List: ML20058H852 ML20058H864 ML20058H880
References
50-456-82-03, 50-456-82-3, 50-457-82-03, 50-457-82-3, NUDOCS 8208090097
Download: ML20058H880 (60)

See also: IR 05000456/1982003

Text

{{#Wiki_filter:U.S. NUCLEAR REGULATORY COMMISSION REGION III Report Nos. 50-456/82-03(DETP); 50-457/82-03(DETP) Docket Nos. 50-456; 50-457 License Nos. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company P. O. Box 767 Chicago, IL 60690 Facility Name: Braidwood Station, Unit 1 and 2 Inspection At: Braidwood Site, Braidwood, IL Inspection Conducted: May 24-28, and June 1-4, 1982 Inspectors: D. H. Danielson k/bw< <s M J. M. Pesan & ~ R. S. Love G 57 A /W/l<w 'W 6/Bo!fb J. I ler 1. .x > > E. re- r 4/.?e//v- ' f , , . <blY ' w G. L. McGregor 6/30 V (SRI Braidwood) M eb Approved By: D. H. Danielson, Chief 6 Materials and Processes Section Inspection Summary Inspection on May 24-28, and June 1-4, 1982 (Reports No. 50-456/82-03(DETP); 50-457/82-03(DETP)) Areas Inspected: QA Program interfaces and overview; corrective action systems; design change control; material traceability of installed structures and components; electrical cable installation; inprocess inspections; QC inspector effectiveness. The inspection involved a total of 467 inspector- hours onsite by six NRC inspectors. 8208090097 820716 -. PDR ADOCK 05000456 G PDR - - - - -

Results: Of the areas inspected two apparent violations were identified (failure of site contractors to follow their procedures - paragraphs b.(11.(b), e. (2) . (a) .4, and e. (2) . (b) 4. ; f ailure of site contractors to accomplish activities in accordance with procedures paragraph f.(2).(a)). l

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DETAILS 1. Persons Contacted Commonwealth Edison Company (CECO)

• W. J. Shewski, Manager Quality Assurance
• D.=Cosaro, Project Construction Superintendent
• T.

Tramm, Nuclear License Administrator

• R. C. Schleiter, Administrative Assistant Construction

V. I. Schlosser, Project Manager (Byron and Braidwood) G. F. Marcus, Director of Quality Assurance (Engineering and Construction)

• T. R. Sommerfield, QA Superintendent

R. M. Sacco, Engineering Technician R. C. Tate, QA Engineer S. M. Jaquez, QA Engineer W. D. Bruns, QA Engineer D. C. Boes, QA Engineer S. A. Reece, QA Engineer R. D. Pickell, QA Engineer

• C. D. Gray, Project Construction Structural Supervisor
• J. Merwin, Project Construction Mechanical Supervisor

J. Hoffman, Project Construction Department D. Hoffer, QA Engineer M. Togliatti, Project Construction Department R. Vignocchi, QA Inspector J. Matisotto, Field Engineer

• C. A. Mennecke, Project Construction Electrical Supervisor

B. H. Kulik, QA Inspector (Documentation) J. Galligan,-Instrument Engineer E. A. Kram, QA Engineer

• L.

J. Tapella, Electrical Field Engineer

• D. A. Brown, QA Supervisor
• S. C. Hunsader, QA' Supervisor

M. A. Gorski, QA Engineer i K. Miller, QA Inspector Phillips, Getschow Company (PGCo) A. Rubino, Quality Control Supervisor E. Ullrich. Assistant Quality Control Supervisor R. Cronkite, Calibration Technician A. Rohla, Training and Procedures Coordinator R. Veronda, Engineering Clerk , l G. Jenkins, Draftsman l J. Matrisotto, Field Engineer l D. Ortiz, Area Foreman l G. Balzer, General Foreman l J. Ryder, Document Control Technicicn t' J. Devine, Instrument Superintendent C. Johnson, Engineer S. Goryl, Field Engineer , i l l i

3 1 ! i L

L. K. Comstock and Company Inc. (LKC) R. A. Brown, QC Manager C. Stiles, QA Engineer J. Hii, QC Inspector J. Peters, QC Inspector F. Rolan, QC Inspector T. Rolan, QC Clerk R. Martens, Cable Engineer M. Kost, QC Supervisor Pittsburgh Testing Laboratory (PTL) L. E. Smetana, Site Manager S. L. Bank, Site Auditor Westinghouse (W) R. Schultz, Site Manager Sargent and Lundy Engineers (S&L) C. A. Zalesiak, Field Engineer Napoleon Steel Contractors, Inc. (NSC) C. Zavada, QC Manager Pullman Construction Industries, Inc. (PCI) D. Grant, QA Manager Nuclear Installation Services Company (NISCo) J. Pruitt, QA Manager Pittsburgh-Des Moines Steel Company (PDM) D. Pint, QA Manager Hartford Steam Boiler Engineering and Insurance Company (HSB) L. Parkey, Authorized Nuclear Inspector

• Denotes those personnel attending the exit meeting held at the

Braidwood Site on June 4, 1981. During the inspection at the Braidwood Station exit meetings were held on Wednesday and Friday in order to keep the licensee informed of any findings. The inspectors also contacted and interviewed other licensee and contractor personnel during this inspection. 4

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 cabic installa- tion, inprocess inspections, and effectiveness of quality control inspectors. , i 5

- __. . _ d A Prepared By: J. M. Peschel b. QA Program Interfaces and Overview (1) QA Manuals Reviewed Commonwealth Edison Topical Report, CE-1-A, 2/17/82 Commonwealth Edison Quality Assurance Manual, Revision 68, 4/15/82 Pullman Construction Industries, Inc., Quality Assurance Manual, ' Revision 0, 9/19/79 Pullman Construction Industries, Inc., Quality Assurance Program Project Unique Addendum for Sargent & Lundy Specifica- tion #L-2782, Revision 0, 8/27/81 Nuclear Installation Services Company Quality Assurance Manual - ASME Section III, Revision C, 6/6/78 Nuclear Installation Services Company Braidwood Addenda to Corporate QA Manual - ASMC Section III - Division 1, Revision C, 8/28/80 , V. S. Wallgren Company Quality Assurance Manual, Revision 4, 10/8/80 Pittsburgh - Des Moines Steel Company Quality Assurance Manual, Revision 5, 1/19/81 Gust K. Newberg &' Associates Quality Assurance Manual, Revision 4, 10/1/80 Napoleon Steel Contractors, Inc... Quality Assurance Program, Revision 7, 9/6/79 Pittsburgh Testing Laboratory Quality Assurance Manual, ! Revision 4, 9/21/79 Midway Industrial Contractors, Inc., Quality Assurance Manual, Revision 5, 4/1/81 Phillips, Getschow Company Corporate Quality Assurance . Manual, Revision 4, 4/21/81 i Phillips, Getschow Company Site Quality Assurance Manual, Revision 9, 1/25/82 L. K. Comstock & Company, Inc., Quality Assurance Program Manual, Revision 4/6/82 (2) Procedures Reviewed (a) Commonwealth Edison Company Site Quality Instructions (SQI) SQI #1, Revision 3, 4/27/81 On-Site Contractor NCR's , SQI #2, Revision 2, 4/27/81 On-Site Contractor Procedures SQI #3, Revision 4, 4/22/82 CECO NCR's l SQI #4, Revision 4, 9/18/81 Field Change Request 6 . - . .. . . - - . - ._ _ - . - . - - ,

SQI #9, Revision 2, 8/20/81- Braidwood Site Instructions for On-Site Contractor Documentation Turnover SQI #10, Revision 0, 12/1/80 Site QA Instruction for Reviewing the Completeness and Acceptability of Installation Documents Referenced on Contractor N-5 Data Reports SQI #16, Revision 0, 9/18/81 CECO QA Hold Cards SQI #17, Revision 0, 3/15/82 Welding Surveillance Matrix, Guideline to Perform Welding Surveillances SQI-18, Revision 0, 5/20/82 QA Orientation, Receipt Inspection and On-the-Job Training Program Braidwood General Instructions (BG) BG-2, Revision 5, 8/5/81 Braidwood Construction Site Instruction for Site Design Document Receipt, Distribution, and Control BG-2-1, Revision 2, 6/29/81 Engineering Change Notices BG-3, Revision 5, 8/5/81 Material and Equipment Receiving, Inspection, Storage, Removal and Inventory Instruction BG-12, Revision 0, 9/15/77 Surveillance Sign-Off Sheet Instruction BG-16, Revision 3, 7/31/81 Hold Notification Sheet BG-17, Revision 2, 6/29/81 Field Change Requests BG-21, Revision 0, 12/1/80 CECO Processing Responsibility for the N-5 Form and Package (b) Phillips, Getschow Procedures QAP QCT 20.15, Training and Certification of Quality Control Inspection Personnel, Revision 5, 9/30/81 QAP 3, Storage Procedure, Revision 5, 3/24/81 QAP 5.1, Item and Material Identification Monitoring, Revision 0, 5/25/78 QAP 7, Control of Inspection Equipment, Revision 7, 10/12/81 QAP 12, Control of Nonconformity Reports, Revision 3, 5/24/79 a l QAP 12.1, Control of Audit Nonconformities, Revision 0, 2/16/79 QAP 33, Receiving Inspection of Items, Material and Equipment, Revision 1, 8/10/81 ! 7 ' , __ _ _ _ _ _ __ _. _ _

QAP 100, Quality Assurance Manual Control, Revision 0, 1/12/81 QAP 105-A, Quality Assurance Training Program, Revision 0, 6/1/81 QAP 108, Document Control Procedure, Revision 0, 3/13/81 QAP 109, Temporary Attachments, Revision ~1, 4/6/81 QCP B2,-- Control of Assembly Location Drawings and Field - Fabrication Drawings, Revision 3, 2/21/79 QCP B4, Handling of Safety Related Items, Revision 1, 2/19/79 QCP B8, Isstance and Control of Welding Material, Revision 6, 1/22/82 QCP B13, Storage Procedure, Revision 3, 6/4/79 QCP 15, Document Control Procedure, Revision 2, 8/29/80 QCP B21, Installation and/or Field Routing of Two Inch and Under Process Piping Systems - ASME Classes 1, 2, and 3, Revision 1, 2/16/82 PGCP-22, 2" and Under Process and Instrument Line Supports- in Category 1 Buildings, Revision 2, 10/15/81 PGCP-30, ASME Instrument Line Routing in Category I Buildings, Revision 0, 8/13/81 QCP-B1, Routing of Non-Destructive Examination, Revision 4, 6/8/81 PGCP-7, Control of ECN's and FCR's, Revision 1, 6/5/81 (c) Napoleon Steel Contractors, Inc. Procedures Procedure 1, Receipt & Storage - Reinforcing Steel, Revision 6, 3/12/79 Procedure 2, Placing of Reinforcing Steel, Revision 6, 6/13/77 Procedure 3, Cadweld Splicing, Revision 10, 3/12/79 Procedure 4, Receiving. Storage and Installation of Post Tensioning Embeds, Revision 4, 3/12/79 Procedure 7A, Post Tensioning Material Receiving and Storage, Revision 2, 11/20/80 Procedure 8, Personnel Qualification & Certification Tcogram, Revision 0, 7/11/80 (d) Pittsburgh Testing Laboratory Procedures Resident Internal Quality Assurance Audit Plan Revision 2, 2/4/82 QC-1A-1, Internal Audits, Revision 5, 5/8/81 QC-PQ-2, Personnel Qualifications, Revision 9, 9/21/81 QC-CRN-1, Control and Reporting of Nonconformances, Revision 3, 9/21/79 QC-CAL-3, Tool, Gauge, and Instrument Control, Revision 15, 11/12/81 8

_ (e) Nuclear Installation Services Company Procedures ES-116-1, Revision B, 7/26/78 Qualification and Certification of Nondestructive Examination Personnel ES-116-2, Revision A, 12/6/77 Qualification and Certification of Inspection Personnel ES-116-3, Revision A, 12/12/77 . Qualification and Certification of Auditing Personnel ES-153, Revision B, 9/11/79 Procedure for Control of Nonconformities ES-140, Revision B, 8/17/79 Calibration and Control of Measuring and Test Equipment (f) Pullman Construction Industries, Inc. Procedures B3.1.F, Design Control, Revision 2, 7/13/81 B6.1.F, Document Control, Revision 1, 7/13/81 i B8.1.F, Identification and Control of Material, Parts and Components, Revision 0, 3/31/80 B10.1.F Field Receiving Inspection, Revision 0, 3/31/80 B10.4.F, Final Inspection, Revision 1, 8/12/80 B12.1.F, Equipment Calibration / Verification, Revision 0, 3/31/80 B13.1.F, Storage and Handling, Revision 0, 3/31/80 B16.1.F, Nonconformance/ Corrective Action, Revision 1, 3/31/80 B10.2.F, Visual Weld Inspection, Revision 0,.8/14/80 (3) Miscellaneous Documentation Reviewed (a) Commonwealth Edison Company 1982 Braidwood QA Training Schedule, Revision 1 1982 and 1981 Monthly NRC Open and Unresolved Items List Audit Status Reports, April and May 1982 ' . . Surveillance Activity Reports, 1982 f NCR Trend Analysis Reports, 1981, 1980,, -1979 NCR Status Reports, February, April'1982, and December 1981 Braidwood Station Semi-Monthly Reports May 17, 1982, April 16, 1982, April 2, 1982 Braidwood Site QA Organizational Chart, May 7, 1982 Audit Reports , GeneralOfficeAuditofBraidwood,Augusk28and29,1980 General Office Audit of Braidwood, April 23, 24, 27, 1981 Energy Incorporated Management Audit of Braidwood, April 1981 General Office Audit of Braidwood, November 5 and 6,1981 General Office Audit of Braidwood, March ~11-15, 1982 , , ' General Office Audit of Braidwood, May 14-24, 1979 ' 1 9 , . . - . . -

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ys ' $- \\+ Unannounced Radiation Safety Inspection Reports, 1st ' ! g Quarter, 1982 - Unar'nounced Radiation Safety Inspection Reports, 4th ' lb.i t u t Plan, May 18, 1982 3esident QA Surveillance Procedure, Revision 1, May 20, 1982 ' ' Audit /SurvH, ,11ance Checklist, May 19, 1982 , \\ ) ~/ 1 i A_udi_t Reports . QA Audit #226 QA Audit #223,. QAAuditj#222 t , , [ ,QA vAudit [ #221 g,' , i ~ QA Audit! #220 ' , , , i QA Audit #2,19 V ". . I QAAudit#217,-{, ! QA Audit #21'8 _ 'N QAAuditi#21'b) 9 3

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QA Audit #198 QA Audit #197 QA Audit #196 QA Audit #195 (c) Pullman Construction Industries. Inc. Audit Reports Internal Audit #PCI 80-09/PFBr-06 Internal Audit #PCI 80-14/PFBr-07 Internal Audit #PCI 81-1/PFBr-08 Internal Audit #PCI 81-4/PFBr-09 (d) Phillips, Getschow Co. Audit Reports Audit Report No. 81-17 Audit Report No. 81-15 /.' adit Report No. 81-2 Audit Report No. 80-8 Audit Report No. 81-18 Audit Report No. 81-19 Audit Report No. 81-20 Audit Report No. 81-22 Audit Report No. 81-23 Audit Report No. 81-24 Audit Report No. 81-25 Audit Report No. 81-26 Audit Report No. 81-27 Audit Report No. 81-32 Audit Report No. 81-36 Audit Report No. 81-12 Audit Report No. 82-31 Audit Report No. 82-33 Audit Report No. 82-20 (e) Napoleon Steel Contractors Inc. Tendon Storage Surveillance April 2, 1982 Tendon Storage Surveillance April 8, 1982 Tendon Storage Surveillance April 16, 1982 Tendon Storage Surveillance April 23, 1982 Tendon Storage Surveillance April 30, 1982 Tendon Storage Surveillance May 7, 1982 Tendon Storage Surveillance May 14, 1982 Tendon Storage Surveillance May 21, 1982 Tendon Storage Surveillance May 27, 1982 Electrode Storage, Issuance and Control Check March 17, 1982 12

- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _____-_. _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ Welder and Welding Inspection March 31, 1982 Reinforcing Steel Storage Check March 31, 1982 Reinforcing Steel Storage Check April 30, 1982 Reinforcing Steel Storage Check May 28, 1982 Quarterly Audit Checklist March 31, 1981 Quarterly Audit Checklist June 23-30, 1981 Quarterly Audit Checklist September 28, 1981 Quarterly Audit Checklist December 28, 1982 (4) Interviews with Site Personnel Interviews were conducted with six personnel from Commonwealth Edison Company, three personnel from Phillips, Getschow Co., two personnel from Pittsburgh Testing Laboratory, two personnel from L. K. Comstock and Co., Inc. one person from Napoleon Steel Contractors, Inc. and one person from Pullman Construction Industries, Inc. (5) Licensee Action

several observations and two examples of noncompliance were identified during the course of the inspection. The licensee took prompt action in most cases to correct the deficient conditions or to alleviate the inspector's concerns. The licensee has also taken action to address concerns raised during a similar inspection at the Byron Station during March and April of 1982. Documentation related to these actions was reviewed, and these items will be inspected during a future inspection. (6) Licensee's Quality Assurance Program (a) Objective The objectives of this assessment were to determine: that the licensee's Quality Assurance Program, in- . cluding all amendments, has been approved by NRR. If the licensee has control of changes to the sub- . mitted Quality Assurance Program. if the Quality Assurance Manual is consistent with . the approved Quality Assurance Program. (b) Discussion A review was conducted of: 13

1. the licensee's Topical Report, CE-1-A, Revision 20, and it was 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 it was determined that the licensee initiated and controlled changes to the program through QP-2-1. The procedure requires the same icvel 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 requirements, codes and standards, audits, and reviews. 3. the licensee's Quality Assurance Manual and refer- enced documents to determine whether adequateaQA plans and procedures have been established (written, reviewed, approved, and issued) to implement the docketed QA program. The review indicated that the 18 Criteria of 10 CFR 50, Appendix B were addressed by the Quality Procedures of the Quality Assurance Manual. (7) Quality Assurance Program of Contractors (a) Objectives The objectives of this assessment were to determine if the licensee had approved and routinely audited the Quality Assurance Programs of contractors for consistency with 10 CFR 50, Appendix B, and to deter- mine the current status and effectiveness of licensee management of the on-site Quality Assurance Programs. (b) Discussion Interviews bcre conducted with licensee and contractor personnel, and the QA manuals and related documentation of the licensee and contractors were reviewed to deter- mine 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 nine con- tractors on site and each was performing safety related work under their own specific Quality Assurance Programs 14 - - - _

, .. . _ _ - _ _ _ _ - _ , (QAPs). These QAPs had been submitted to the licensee for review and approval. The licensee had reviewed and approved the QAPs prior to the contractors start of work. The licensee was fully aware of its ultimate respons- ibility for site Quality Assurance and had its own QA organization on site to monitor the activities of the various site contractors through the mechanisms of surveillances and audits. The Quality Assurance Manual of Napoleon Steel Contractors, Inc. (NSCI) had wording in Section 3.2.2 that contradicted the organization chart of Section 3.1. Revision 8 was made to the NSCI QA Manual to rectify the contradiction. Revision 8 was approved by the licensee on June 3, 1982. The inspector has not further questions in this area. (8) Licensee Management Assessment of the Quality Assurance Program (a) Objective The objective 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 Audits of the Braidwood Construction site, conducted by a General Office Audit Team, were reviewed. The General Office Audits are semiannual and are supple- mented by a biennial audit which is conducted by an independent auditing organization. The audits cover the entire scope of the Quality Assurance Program and are reviewed by upper level management. In addition, written reports are made to the Corporate Quality Assurance Office by the Site Quality Assurance organization, on a frequency varying from weekly to yearly. A review of lead auditor training records revealed one lead auditor did not have an annual evaluation for 1981 contained in his training record. A copy of the evaluation was promptly obtained from the corporate office and placed in the record. The inspector has no further questions in this area. CECO NCR 250-R, dated 2/26/81, was written on a form that was three revisions out of date and also had indications that " white-out" type correcting fluid was used. All of the information required on the up to date 15 _- --

______ ___-_____-______________________ i form was included on NCR 250-R. This was the only in- correct procedural reference or " white-out" detected during the course of the inspection and it appears to be an isolated incident. The licensee's Project Con- struction Superintendent and the Site QA Superintendent issued a joint memo, on May 27, 1982, to all site per- I sonnel, restating the CECO policy on correction fluid / tape and the approved method of making corrections. The inspector has no further questions in this area. (9) Licensee Quality Assurance Organization (a) Objective The objective of this assessment was to determine if the Quality Assurance Program provides sufficient independence from cost and schedule. (b) Discussion The licensee's Topical Report was reviewed and the organizational charts indicate that the CECO Quality Assurance Organization has adequate independence from cost and schedule. Interviews conducted with site personnel verified the independence. CECO QA personnel report to the Site QA Superintendent who reports off-site to the Director of Quality Assurance. (10) 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) A review was conducted of the licensee's Topical Report and Quality Assurance Manual. These reviews were supple- mented with interviews of the licensee's Corporate and Site Quality Assurance Managers and the QA/QC Managers of selected contractors. The documentation review and the interviews showed that the responsibility of the licensee was established, documented, and understood by responsible personnel in both the licensee's and con- tractor's organizations. (11) Licensee Oversight of Contractor Activities (a) Objective The objectives of this assessment were to determine if the licensee has effective oversight of contractor act- ivities and has detailed knowledge of those activities. l 16 l _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ l

(b) Discussion Interviews were conducted with QA/QC personnel from the licensee: L. K. Comstock and Co., Inc.; Phillips, Getschow Co.; Napoleon Steel Contractors, Inc.; Pittsburgh Testing Laboratory; and Pullman Construction Industries, Inc. These interviews were supplemented by the review of quality assurance procedures, audits, surveillances, inspections and related documentation; tours of work areas, storage areas and field offices; inspections of installed hardware; and discussions with other licensee and contractor personnel. As a result of this review it was determined that the 11- consee has a program that should provide an effective oversight of contractor activities. A discussion of some inspection findings and observa- tions, along with licensee action, follows: Control of ECN's In the Phillips, Getschow Co. (PGCo) Engineering Department, several ECN's were chosen at random and the affected drawings, in six different locations, were checked to assure that ECN's were being controlled. In five of the six locations drawings were properly annotated, but in the hangar drafting area affected drawings were not being marked as required by PGCo Construction Procedure No. 7. The contractor took immediate corrective action to mark all affected drawings. Two training sessions were held to instruct department personnel on PGCP-7 and the control of ECN's and FCR's. The inspector has no further questions at this time. Noncompliance (456/82-03-01a; 457/82-03-01a) 10 CFR 50, Appendix B, Criterion V states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings." The failure of PGCo to follow PGCP-7, with regard to controlling ECN's, is contrary to the above and is an item of noncompliance. 17

e E Performance of the Phillips, Getschow Co. Quality- Assurance Department A review of the training activities for PGCo revealed 4 that the PGCo Quality Assurance Manual and Quality Assurance Procedure 105-A were not being followed. Section 1.19 of the QA Manual requires that the Manager, Quality Assurance prepare and distribute a training matrix for each activity performed on the site on a quarterly basis. QAP-105A also assigns the respons- ibility for the matrix preparation to the Manager, l, Quality Assurance, and assigns training responsibility to the Supervisor, Quality Control and the Site Manager. The training matrix had not been provided for either the first or second quarter of 1982. Training was not

being conducted in accordance with QAP-105A, Rev. O, but ! was approximating Rev. 1 of QAP-105A which was in the draft stage. A Training Coordinator had been appointed, and training was being provided on procedures, procedure revisions, and problem areas. Training records on file indicate that training had been performed during the first two quarters of 1982 and at a level greater than any previous quarter. A PGCo audit, 81.15, conducted on February 17, 20 and 23, 1981, noted that the training matrix was not pro- vided during the fourth quarter of 1980. The reason given was insufficient staff within the QA Department. The corrective action was to add an additional person to the QA staff and to audit QAP-105A annually. QAP-105A has been rewritten to improve the training of site personnel. We encourage such action, but the fact that a new procedure is being prepared does not relieve an organization from its responsibility to follow , the Quality Assurance Manual and Quality Procedures. We d cannot condone PGCo not following QAP-105A, Rev. O, while the procedure is being rewritten. We are also concerned about the performance of the PGCo QA Department and the effectiveness of the corrective action 4 taken in response to audit 81.15. An addition was made to i the QA staff in 1981 and a nonconforming condition still existed regarding training matrices. The deficient condi- tion had not been addressed by a PGCo audit. The PGCo QA Department also failed to audit Section 6 of the PGCo QA Manual.during 1981. This deficiency was annotated by the > CECO General Office audit of March, 1982, and a PGCo audit has since been conducted. 18 - . . . - _ . . __

We realize that the licensee .i:s monitoring PGCo activi- ties and that the institution of a surveillance program by PGCo is a typical result of this monitoring. It is our belief that the licensee needs to devote more atten- tion to PGCo and in particular to the PGCo QA Department. Noncompliance (456/82-03-01b; 457/82-03-01b) 10 CFR 50, Appendix B, Criterion V states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings." The failure of PGCo to conduct training in accordance with Section 1.19 of the Quality Assurance Manual, and in accordance with QAP-105A is contrary to the above and is an item of noncompliance. Agreement Between the Installer and the NDE Contractor A review of the Agreement between PGCo, referred to as. the Installer, and Pittsburgh Testing Laboratory (PTL), referred to as the NDE Contractor, revealed some confusion on the part of the Installer and a discrepancy between a statement in the Agreement and the actions of the Authorized Nuclear Inspector (ANI). The Agreement is signed by PGCo, FTL, Ceco and the ANI. During an interview with the Insta11er's QC Manager an . organization chart was noted that showed the NDE Contractor i reporting to the Insta11er's QC Manager. The Insta11er's QC Manager was under the impression that the NDE Contractor worked for him in matters concerning radiography, which is contrary to the Agreement. The licensee took prompt action to assure that all parties understand the interface rela- tionship of the Agreement. The Agreement also states that the NDE Contractor shall assist the ANI in the performance of audits of the NDE Contractor's program as it affects work performed by the Installer. The ANI does not perform audits of the NDE Contractor, but he does perform an oversight or surveillance of the NDE Contractor. The licensee has agreed to have the Agreement rewritten to reflect the ANI performing surveillance activities of the NDE Contractor. 19 . . - - .-- - . - - . -_

Open Item (456/82-03-02; 457/82-03-02) The Agreement between the Installer and the NDE Contractor is to be rewritten to reficct the ANI performing surveil- lance activities of the NDE Contractor. Trend Analysis A review was conducted of the documentation and the cor- rective action resulting from a trend analysis performed by the licensee on NCR's, audits, surveillances, and NRC actions concerning the L. K. Comstock and Co., Inc. (LKC). The analysis showed that LKC had developed adverse trends concerning hangar installation and audit / surveillance responses. The licensee had identified a lack of training and a lack of LKC Quality Assurance involvement as contributing factors in the establishment of these adverse trends. As a result of the analysis the licensee has required LKC to institute training programs for hangar installation foremen, and to supplement the QA organization with an onsite QA engineer. The QA engineer's function will be to establish an audit program that will supplement the yearly corporate QA audits. This type of action is commendable, and we urge the licensee to apply similar diligent analysis to its other contractors. Corrective Action A review of the Pullman Construction Industries, Inc. (PCI) NCR log revealed that NCR #BR-09 had been open since July 7, 1981. The required action was for PCI to write an FCR to request resolution. At the time of the inspection an FCR had not been written. The licensee, upon notification by the inspector, took prompt action to have the NCR closed. The corrective action was determined to be a remeasurement that verified the initial values were in error. PCI Procedure B16.1.F, Non-Conformance/ Corrective Action, states that it will be the responsibility of the Project Manager to assure deficient items are corrected in a timely manner and the responsibility of the Site QA Representative to review the NCR log monthly and to assure implementation and maintenance of documentation generated by the procedure. The NCR log had received its monthly review but there was no evidence to indicate action had been taken to get the FCR written. The procedure is ambiguous, and appears to assign a log review function to the site QA Representative 20

. . with no requirement to assure that prompt corrective action -is taken. The licensee agreed to get the procedure rewritten to provide a meaningful monthly NCR log review and to assure prompt corrective action is taken. The inspector has no further questions at this time. Records Storage A May 27, 1982 tour of the records storage vault at PGCo revealed water leaking into the vault. The licensee initiated an immediate repair of the facility. The facility was reinspected on June 3, 1982 and no water was found. The inspeccor has no further questions at this time. Process Traceability During a review of weld traceability with PGCo, one of seventeen welds checked did not have the welder's symbol adjacent to the wold. PGCo was able to identify the welder and meet the requirements of ASME Section III by means of the weld records. The weld was promptly stamped with the welder's symbol. The stamping of welds is a PGCo policy and the licensee has agreed to see that PGCo maintains consistency in their weld identification process. The inspector has no further questions in this area. (12) Quality Assurance Staffing > (a) Objective The objective of this assessment was to determine if the Quality Assurance Organizations of the licensee and con- tractors were adequately staffed. (b) Discussion 4 i Interviews were conducted with personnel involved in the management of the licensee's and selected contractors' ' Quality Assurance Organizations; and approximately 14 ' percent of the Quality Control inspectors employed by the contractors. Based upon the interviews; a review of scheduled and completed audits, surveillances, and in- i spections; it was concluded that the QA/QC organizations

were staffed with sufficient manpower. The auditors of i selected organizations were found to be adequately quali- fled. Qualifications of Quality Control Inspectors are discussed in detail in the "QC Inspector Effectiveness" i section of this report. !

21 - -

_ . . . . - . . - .- (13) Trend Analysis-Program (a) Objective The objective of this assessment was to determine if the -licensee has an effective trend analysis program. (b) Discussion A review was conducted of the method the' licensee uses to analyze trends in the performance of contractors. The licensee conducts a trend analysis of each contractor's Nonconformance Reports and the finding of CECO audits of the contractor. The results of the analysis are reported to the Corporate QA Management in an annual report. The trend analysis of all contractors' NCR's and selected contractor audit findings were reviewed and no diccrepan- ! cies were noted. An example of effective trend analysis is discussed in Section 2.b.(11) of this report. (14) Compliance !!istory (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 A review was conducted of the licensee's history of noncom- pliances, unresolved items, 10 CFR 50.55(e) Reports, IE Bulletins, IE Circulars, IE Information Notices, and the , systems used to assign responsibility for the tracking and resolution of the items. A review of two 10 CFR 50.55(e) Reports, two noncompliances, two unresolved items, and 5 IE Bulletins showed that the tracking uas adequate and appropriate corrective action was taken, or an appropriate response made, t Except as noted, within the areas inspected, no items of noncompli- ance or deviations were identified. i , 22 , _ . - . _ - , , , - _ - . , . . . _

- _ . . . . . - = . . . -. -. __ 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. i (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 closcout, trending of nonconformances, and upper management's involvement. (2) Discussion (a) Commonwealth Edison Company (CECO) 1. Procedure Review i A review of CECO Quality Procedures QP 15-1, dated March 1, 1982, and QP 16-1, dated December 29, 1980, indicate that they appear to be adequate as relating i to corrective action. Adverse trends and problem areas are brought to the attention of the Vice President (Nuclear Operations), Manager of Projects, Project tlanager and Manager of Quality Assurance. 2. Review of NCR Log The inspector reviewed CECO's Nonconformance Report (NCR) Log for the years 1978 thru 1982. It was observed that there were 10 NCRs open longer than 18 months. These NCRs will be addressed later in this report. It was also observed that there were 65 NCRs prepared in 1981 and 38 NCRs prepared to date (June 1, 1982) in 1982. 3. Review of NCRs , The inspector reviewed NCRs for: proper closure, corrective action to prevent recurrence, and for , timely closure. 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 evaluation, including proper back-up data, or to accept items as is when the proper disposition should have been repair or rework. . 23 ! _ _ _ , _ _ _ ._ _ __- ___ _ _ _ _ . . _ . __ _ _ .___ _ _ .- ,

A general review of approximately 40 NCRs and a detailed review of 18 NCRs were made. The follow- ing observations were made: a. NCR 153. dated August 13, 1978, revised October 6, 1978. Anchor bolts were not placed in deck slab when concrete was placed. Concrete expansion anchors are being installed as equipment is being placed. As of June 1, 1982, this NCR is still open. b. NCR 176, date March 6, 1979. Fifty-nine (59) tanks, pumps, or pieces of equipment were grouted without an approved work procedure. Sent to SNED for disposition on March 7, 1979. As of June 1, 1982, this NCR has not been dispositioned. c. NCR 208, dated March 20, 1979. Embedded process pipe 1-AB-34 was installed at an angle. As of June 1, 1982, this NCR is still open. d. NCR 227, dated June 6, 1980. UT inspections performed on 24 welds joining P1 to P8 material. As of June 1,1982, I weld remains to be re-in- spected. e. NCR 235, dated July 9, 1980. Welding of structural members on the main control boards does not meet AWS D1.1 requirements. As of June 1, 1982, this NCR is still open. f. NCR 250, dated October 9, 1980, revised March 5, 1981. Length and size of welds on "some" hanger connections do not conform to' drawing details. As of June 1,1982, . this NCR is still open. 1 g. NCR 251, dated October 16, 1980. 3" 9 cable storage shield tubes were omitted on Units 1 and 2. As of June 1, 1982, this NCR is still open. h. NCRs 252, dated October 9, 1980, a.1d 263, dated _ November 13, 1980, pretains to welding of panel structural welds. As of June 1, 1982, these NCRs are still'open. , i. NCR 319, dated October 16, 1981. Bushings on tendons V15 and V90 not acceptable. S&L letter dated March 25, 1982 references tendons V15 and V19. NCR was closed on May 11, 1982. 24

When the discrepancy in tendon numbers was- brought to the attention of the licensee, S&L was contacted and it was confirmed that this was a typing error. S&L is to send a corrected letter to the site. 1 NCR 364, dated March 29, 1982. NCR was voided on April 20, 1982 because a re-inspection to FCR 3582, dated February 23, 1982 indicated that the item was acceptable, k. Additional closed NCRs were checked for steps to prevent recurrence and they appeared to be adequate. 4. Review of Trend Analysis of NCRs On June 2, 1982, the inspector reviewed 19 monthly trend analysis reports of NCRs prepared by CECO. The reports reviewed extended from October 22, 1980 through April 19, 1982. These trend analysis were prepared by the Project Engineering Department (off- site). All 19 of the aforementioned reports had the notation, "No trends-are evident." By reviewing CECO NCR log only, the inspector could not identify any apparent trends, but by reviewing individual NCRs, trends could be established. Example: CECO NCR 347 was prepared to obtain an engineering evaluation on Napoleon Stool Contractors, Inc. (NSC) NCRs 130, 159, 160, 161, 163, 164, 165, 168, 170, 176 and 178 which all protained to broken tendon wires. NCRs 159 through- 178 were. prepared within a two month period. NSC had identified this as an adverse trend. Ceco QA (on-site) does perform a trend analysis on contractor's NCRs. On the trend analysis reviewed, they appeared to be factual. 5. Personnel Interviews Interviews with CECO personnel indicate that they appear to be knowledgeable in CECO Procedures on Corrective Action as well as Contractor's Procedures. (b) L. K. Comstock and Company, Inc. (LKC) L Procedure Review a. A review of LKC procedure 4.11.1, Nonconforming Items, Revision-February 19, 1982, indicates that the procedure does not address corrective 25

action to prevent recurrence of the nonconforming conditions. As a result of the Byron inspection, CECO issued a directive to all applicable con- tactors at the Braidwood site to incorporate corrective action to prevent recurrence into their nonconformance program. This procedure was revised June 3, 1982 and submitted to CECO for review and approval. b. A review of LKC procedure 4.11.2, Corrective Action, Revision-February 15, 1982, indicates that this procedure does not incorporate the Regulatory Requirements of Criterion XVI of 10 CFR 50, Appendix B. A review of LKC corporate audit of their Braidwood project on March 23-24, 1982 indicates that the auditor identified the same concern as the Region III inspector. The resolution to the audit finding was to revise procedure 4.11.2 and incorporate Criterion XVI requirements. 2. Review of CECO Audits of LKC The inspector reviewed the audit reports, dated December 1, 1981 and April 5, 1982, of LKC in the Nonconformance and Corrective Action areas. In conjunction with the aforementioned audits, a trend analysis of LKC's NCRs was performed by CECO on December 17, 1981. All NCRs prepared between March 26, 1981 and November 23, 1981 were considered in this analysis. This analysis indicated that there were problems in the area of hanger installa- tion. On April 16, 1982, a more comperhensive trend analysis was performed. This analysis included all NCRs prepared between September 1, 1979 and April 8, 1982. This trend analysis reaffirmed that there was a severe problem-in the hanger installation area. A summary of the two trend analysis in the hanger installation area is as follows: Attribute 12/17/81 Trend 4/16/82 Trend General Problems 71 NCRs 98 NCRs Material Problems 68 NCRs 86 NCRs Hanger Location 8 NCRs 13 NCRs Dimensional Problems 60 NCRs 74 NCRs Fit-up Problems 27 NCRs 34 NCRs Welding Problems 16 NCRs 22 NCRs 26

As'a result of the CECO audits and trend analysis of LKC, CECO convened several Management Meetings with LKC's management. As a result of these meetings: 1. Various procedures were revised. 2. LKC has assigned a QA Engineer to the Braidwood. project. 3. CECO QA performs weekly surveillances of LKC. activities. 4. CECO QA performs monthly audits of LKC Quality Program. 5. Pittsburgh Testing Laboratory performs.over inspections on items installed by LKC. In view of the positive steps taken by the licensee to correct the problems identified in LKC's Quality Program, the inspector elected to discontinue the inspection of L. K. Comstock and Company, Inc. In the Corrective Action area during this reporting period. (c) Phillips, Getschow Company (PGCo) 1 Procedure Review The inspector reviewed PGCo's Quality Assurance Manual, Section 15, Revision 0, dated March 21, 1978, and this section.of the manual appears to be adequate as relating to correction action. 2. Review of NCRs The inspector made a general review of approximately 50 NCRs and a detailed review of 20 NCRs for proper closure and for corrective action to prevent recurr- ence. In all cases. observed, where the corrective action to prevent recurrence involved training of personnel, a training attendance list was attached to the NCR including one instance where training of CECO personnel in Code requirements was required. Following is a status of the NCRs that were reviewed in detail. ' a. NCR 693, dated April 22, 1982. Closed May 26, 1982. b. NCR 682, dated April 14, 1982. Closed May 17, 1982. The attached FCR (Number L-1508) could not be tied to the NCR. i.e., the NCR was not referenced on the FCR nor was the FCR referenced on the NCR. Research into other documents veri- fied that the attached FCR was in fact part of 27 n ._ _ .

.. . . . ._ _ __ __ _ ! the approved disposition to the NCR. PGCo took immediate action to cross-reference the two documents. c. NCR 681, dated April 14, 1982. Closed May 19, ' 1982. The same type problem existed with this NCR (Re: NCR 682). PGCo took immediate action to cross-reference the two documents. d. NCR 672, dated April 7, 1982. Closed May 17, 1982. c. NCR 663, dated April 2, 1982. Closed May 19, 1982. f. NCR 654, dated March 24, 1982. Closed April 19, 1982. g. NCR 648, dated March 11, 1982. Superseded by NCR 653. h. NCR 647, dated March 11, 1982. Closed May 26, 1982. i. NCR 639, dated February 26, 1982. Closed May 19, 1982. 1 NCR 638, dated February 25, 1982. Closed April 16, 1982. k. NCR 634, dated February 15, 1982. Closed February 23, 1982. 1. NCR 630, dated January 20, 1982. Closed March 26, 1982. m. NCR 329, dated January 20, 1982. Closed February 12, 1982. n. NCR 617, dated November 4, 1981. Closed December 29, 1981. o. NCR 616, dated November 3, 1981. hiosed May 17, 1982. p. NCR 613, dated October 14, 1981. Closed May 19, 1982. g. NCR 607, dated September 28, 1981. Closed January 25, 1982. 28

r. NCR 606, dated September 25, 1981. Closed December 29, 1981. s. NCR 603, dated September 16, 1981. Closed October 13, 1981. t. NCR 601, dated September 11, 1981. Still Open. 3. Review of Trend Analysis The inspector reviewed CECO's trend analysis of PGCo's NCRs. The analysis reviewed were dated December 15, 1981, December 21, 1981, December 18, 1980, and September 12, 1979. The December 21, 1981 trend analysis was performed by CECO corporate office and the other trend analysises were performed by CECO site QA. No trends were identified. 4. Interviews with Personnel Interviews with PGCo personnel indicate that they appear to have a good working knowledge of their system and procedures as relating to nonconformances and corrective action. . The inspector met with PGCo's Authorized l Nuclear Inspector (ANI) and discussed potential problem areas within PGCo's system. Among the items discussed with the ANI was an apparent trend in the area of bypassed ANI liold Points by PGCo. The ANI stated that there had been a misunderstanding in this area but this problem has since been corrected. (d) Napoleon Steel Contractors, Inc. (NSC) 1. Procedure Review A review of NSC's Quality Assurance Program, Revision 7, dated September 6, 1979, indicates that Section 5.2, Correctivo Action, of their program appears to be- adequate. 2. Review of NCRs Open Item (456/82-03-03; 457/82-03-03) The inspector performed a general review of approxi- mately 50 NCRs and a detailed review of 19 NCRs. Utilizing NSC's NCR log and the NCR, it was very difficult to determine when the NCR was closed. During this inspection, NSC revised the NCR form to add a date and signature for closure. CECO and NSC have formed a task group to review all NSC NCRs, including backup documentation, to establish that 29

_- _ _ - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ the NCR is in fact closed and the date of closure. It should be noted that a large percentage of NSC NCRs were closed based on a CECO NCR. Examples: NSC NCRs 130, 159, 160, 161, 163, 164, 165, 168, 170, ! 176, and 178 were closed based on CECO NCR 347; NSC

NCR 180 was closed based on CECO NCR 352; and NSC NCR i 182 was closed based on CECO'NCR 362. For all NSC generated NCRs that require disposition- approval by CECO PED and/or S&L, CECO generates their own NCR to track the item and to obtain the required approvals. As of June 3, 1982, NSC has prepared a total of 186 NCRs. This . item is open pending a review of NSC NCRs for proper closure. ' 3. Review of Trend Analysis A review of NbC's trend analysis, dated April 1, 1982, Indicates that two adverse trends were identified and their corrective action taken appears to be adequate. 4. Interviews with Personnel Interviews with NSC's QC Manager indicated that he appeared knowledgeable in NSC's system and procedures. Within the areas inspected, no items of noncompliance were identified. 30 m.

Prepared By: J. H. Neisler d. Design Change Control (1) Objectives The objective of this assessment was to determine whether site design change interfaces are clearly defined and implemented, if design changes are being adequately controlled, whether site personnel involved in design change control understand and use procedures as appropriate, and that procedures are being impicmented to assure the timely revision and distri- bution of drawings. (2) Discussion Design changes involving the Braidwood facility are controlled by the CECO Quality Assurance Manual specification, Quality Requirement #QR-3 " Design Control" and Quality Procedure

1. QP3-2 " Design Change Control." In addition to the above

Site Quality Instructions SQI-4 " Field Change Requests" and SQI-8 " Engineering Change Notices" provide implementing instructions for the onsite handling of changes originated by both on and off site organizations. Interfaces between offices and organizations performing design change activities are delineated in Procedure QP3-2. This procedure also establishes responsibilities for design change activities for the licensee's project engineering group, the architect engineer Sargent & Lundy (S&L), the nuclear steam system supplier IE), and the site organizations and contractors. With the exception of instrumentation piping and its suspension system, all design and design change activities are performed by S&L or y for physical changes. When a design change involves changes in control systems or logics, the licensee's engineering group must review and approve changes. Instrument piping and suspension design is performed by the site mechanical contractor according to approved procedures. Input for this design is from S&L design drawings for the particular systems, the contractor develops the field layout drawings, selects appropriate hangers from approved hanger designs supplied by SSL and performs design calculations to verify propor hanger selection. These calculations are performed by the designer and then independently recalculated by the reviewing engineer. After the piping is installed, the contractor's design group prepares an as-built drawing that is forwarded to S&L. This as-built drawing is reviewed by S&L and then incorporated into the plant design analysis. 31

- _ _ _ _ _ _ _ _ _ _ _ _ _ _ Design changes are originated at the site by field change requests (FCR), usually initiated by a site contractor. The FCR is reviewed by the contractor's engineering personnel, licensee's site construction department and approved for forwarding to the S&L site liaison and quality assurance. The S&L site liaison may provide advanced verbal concurrence to commence work on the design change after conferring with cognizant engineers at the S&L office. After the FCR is approved by the various interfac-ing groups, site QA verifies that drawings have been revised to incorporate the FCR. The inspector examined over twenty-five FCRs issued over a period of four years. The inspection included verifying that drawings had been revised and that the physical changes to the systems or components were as stated in the FCR. In each case the drawing had been revised and installation was as stated in the FCR. All FCRs examined had been reviewed by the appropriate organizations according to procedures. The FCRs examined during this inspection involved civil, mechanical, and electrical design changes. In most instances these changes resulted from interferences identified during system installation and did not involve a change in a system's functional capabilities. ' Interviews with personnel involved in design or design changes indicated an acceptable working knowledge of the procedures used on site for the control of design activities. The proco- dures are available at the one activity performing work in the design area. Personnel state they receive adequate orientation and training to perform their assigned activity. The inspector's review of training records indicated that training and orienta- tion had been accomplished for those personnel currently assigned to this area. The inspector examined audit report #20-81-30. The audit was performed on September 29-30 and October 1, 1981, of activities in the instrument piping field design group, the only design activity on site. The audit revealed seven findings and three observations of Quality Assurance program deviations. The inspector reviewed the corrective action for the findings and observations as described in the surveillance reports detailing the closecut of each audit item. The surveillance repcrts and inspection of activities in process indicate that the audit items have been satisfactorily resolved. The results of the inspection indicate that design changes are being controlled by approved procedures. That interfaces between organizations are defined, procedures are being imple- mented, personnel involved in design change activities under- stand the procedural controls and use them as appropriate, that reviews and verifications are performed according to 32 __-__ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _

procedures and that timely revision of drawings and their distribution to affected personnel is being implemented as required by the procedures and the QA program. No items of noncompliance or deviations were identified, . l l I l l 33 l ( l

, _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ , ! l Prepared By: E. H. Nightingale e. 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 and relevant areas were reviewed: (a) L. K. Comstock & Co., Inc. (LKC) 1. Review of Procedures The following site procedures were reviewed: 4.3.10 - Storage Issue and Control for Welding Material. 4.3.3 - Welding Procedure for Structural Attachments.

4.3.14 - Manual Shielded Metal Arc Welding of Stainless s Steel. 4.7.1 - Manual Shielded Metal Arc Welding for Structural Steel and Stainless Steel Qualification Procedure. 2. Review of Records The documents reviewed for weld material traceability are as follows: Weld Material Request . Material Test Report . Weld Rod Request . Weld Data Sheet . Weld Material Issue Tag . 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 " update" qualification records. The LKC welding efforts are to the AWS Code which requires six (6) month requalifica- tion periods. The inspector reviewed the following welder certifica- tion and qualification records: 34 - . _ _ _ _ _ _ _ _ _

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ , Name Welder ID#

• Gary Rose

73

• Thomas Cotner

90 l

• Ed Kelly

1 l Ron Smith 11

• R. Rawlins

97

• J. Vignocchi

150 C. Rice 154 B. Bertani 162 C. 11111 203

• D. Shepherd

171

• C . 11111

688

• J. Duggan

566 E. Patton 66

• G.

Cichosi 110

• J. Sevec

133 N. Mack 125

• R.

Fox 118 F. Leo 138 M. Nash 146 V. Null 179 E. Szaslok 184

• L.

Chapman 7 R. Grzetich 207

• D.

Ilayman 228

• Denotes inactive.

These twenty-five (25) welders are representative of the 181 welders qualified by LKC. 4. Review of Weld Material Control The review of weld material control procedures and direct observation of in process activities indicates that sufficient efforts are being implemented to assure , ' material traceability. Noncompliance (456/82-03-01c; 457/82-03-01c) Weld rod control after issue from weld rod issue station is deficient in that a portable weld rod oven, filled with 7018 rod, was not plugged in. The portable weld rod oven that was not plugged in is a failure of LKC to follow procedure 4.3.10 for the control of electrodes with low hydrogen covering. This failure to contral weld rod, is contrary to 10 CFR 50, Appendix D, Criterion V, and is an item of noncompliance. 35 - _. _ - _ _ _ _ _ _ _ _ J

- (b) Phillips. Getchow Company 1. Review of Procedures QCP-B3 - Control of Material Requisitions and Purchase I Orders. QCP-B8 - Issuance and Control of Welding Material 4.7.2 Clarification. QCP-B13 - Storage Control. QCP-B17 - Fabrication and Installation of Non-ASME Related Piping. QCP-B19 - Filing System for Controlling Certified Material Test Reports. QCP-321 - Installation and/or Field Routing of TWo (2)" and Under Process Piping Systems - ASME Classes 1, 2, and 3. QCP #16 - Control of Installation of Nuclear or Safety-Related Pipe Systems. QCP-VE01 - Visual Examination Procadure. WPS #MA-11-0-8. WPS #1A-MA-11. WPS #MA-11-0. WPS #MA-18-B. WPS #1A-MA-18B. 2. Review of Records Selected several safety related small bore piping systems for material traceability. The review of the data pack- ages consisted of documentation from the purchase order to installation of the item. The documents reviewed are as follows: Purchase Order (CECO) . Material / Services Request . Receiving Inspection Report . Receipt Inspection Checklist . QA Documentation Requirements List . Material List . Requisition . Packing Slip . Material Certificate . Stores Requisition . Weld Record . Material List . Material Certification . Weld Material Issue Report . Reviewed data packages for the following small bore piping systems. 36

_ _ _ _ _ _ - - - _ _ - . _ - . . _ _ _ ,_ y ' l ,- e' ' st - 4 5 , SMALL BORE PIPING >- Heat # System P.O. # Spool PC # Footage NRR # , KD6751 Containment 207003 2544A-24 75,353' 852 Service ' l Water (2") , l .h JF1570 Component 207003 M2537A-43 45,086' 885 Cooling (3/4") 744757 Containment 207003 2535A-33 10,564' 1254 Spray (1/2") JD1571 Fire Protec- 207003 2545A-21 54,390' 843 tion (1-1/2") 783243 Boron Thermal 207003 2549A-17 6,220' 1264 Regenerator (3/4") 745207 Chemical Feed 207003 2546A-1 3,569' 1264 & Volume Con- trol (3/4") 462773 Chemical Feed 207003 PG2546A-5 1,512' 1210 & Volume Con-

1. ', '

trol (2") 462897 Chemical Feed 207003 PG2546A-5 1,208' 1264 & Volume Con-

trol (2") 273088 Component 207003 , M2537C 1,509' 1163 Cooling (2.0") 483245 Chemical Feed 207003 Pb254(C-111 3,644' O 1369 & Volume Con- - trol (3/4")

" 462843 Reactor 207003 'Pd7& 2C-51. 1,736' 1210 Coolant (2") , <n ,r ' ,

<

,. 1 g s ,. , ' J - ' , .' 37 ' - l , . . . . . . . . . . . . .

r

_ . . . _-_____ _ - - - _ _ - _ _ . s. / s .v- . t - % ,. ': 9 . . ' g' COMPONENTS r , Heat # Type ., System P.O. # Spool PC # NRR #

> ISX144A Globe Valve (3/4") Essential 803074 75 PG2544A-32 3182 g . jr. f Service [. /4,p Water gq 1, 7351~[V.r, .- - '~ d 122383C Ball Valve (3/4") Ess,ential 804550 40 PG2544A-64A j_ ji Seryice t u,f Water . g - % '"; ~ /l., [ ,; l, k r t: ..) "" 122391X Ball Valve (2") Essenclial. 804550 90 M2544A-23 7929 . Service'. lal ' Water. \\ \\,1, j - ~ \\ 122391V Ball Valve (2") Edsentisp/M3550 -113 M2544A-23 7929 f// , Service ,t , s.. 1 i Wate'r l

"* '

• /

(i 'j 1 wy

, . , . . . ICV 8480 Check Valve (2") Chem!hai 149365 10 2546A-8 3- 10366 Feed d - Voles [i \\ 1 ^ Cdnu ol: '] . M#, 1 . [ \\ ' ff .,k -

Ih[

I 3. Review of Welder Qual;fications . / \\, .. '. ' ' . The review of uelder qurlification records consisted "- - of reviewing the' orig!nal i dalification record as w' ell l - ,. as the supportii'!e fe'7ocumon;'s pertaining to th,eir "updatq"

,, ,- qualification recerd. '-?.hillips, ' Getschow Co. welding 4 . ,7 j - efforts are to thd ASME Code which requires three (3) Zy :/ j

, month requalification periods. -)s t ' ?-

,,

j.( ~ Theinspectorrehe,iwedthefollowingweldercertifi- g,, cation and qualification records: p .j 4

1. if

Name Welder ID

• H. Arteaga

( 216 - D. Bailey 365 ) , , , M. Briggs ,t . - El

• R. Cankar

.. 458 J. Conry 474 +j/ J. Dobosz - - 137 ij f ' F. Fry g g, 126 j .j

• H. Gentry

s 304 -/ , . " [[ -[f

• L. Graven

.~ 443 r [ UU8 C ','/ / --

• R. Halweg

~l' ,477. .e - )

gs s R. Hernandes , R. Herrada ~f'/ 4A j 7 s ./,,, e '(' ' ' f , p, ,*{ -' p ,(.< ' 38 /- ,$/ - , p .~ . m, b. A

. . _ . ,. _ ., . __ -. . __ - ,- ., kj

t

tt

6,,/ s ' / < . , u- , 4 .f

1

' i -

4 - s , s , 4- " Name - ' ' Welder ID . -

i

• M.

Jacklich 299 ' , 'F

• K. Johnston

515

~ / (L

• G.

Kolski 442 > R. Ludkowski 190 ' /

• F. Matos

647 ,./ '" - G. Moore 513 i ?Q/ s.- E. Ogden 149 , -/-

• J.

Popp . \\ 623 i 528 ,

• P. Schulze /

E. Taylor- / . 243 ' j '+ ~ ' H. Wheatley . 537 M. Briggs, Jr. > 597 _. '% 'P. Feret 413 ' J. Harrier 235

• R. Jonder

- r 206 P. O'Reilly 391 -

, D. Sunbom 577 , . R. Bregar 460 -[

• T. Downing 7 ,

725 T. Mislich' VV7 & T. Voss 306

• R. Dozier

740 D. Oakes , . 749 s a

• Denotes inactive.

O Thescythirty-nine (39) welders-are representative of :the. approximately 325 welders qualified by Phf111ps, Getschow Co. v w. .. s y (g 4. Review of Weld Material Control - The review of weld material control procedures and 4' direct obseivation of in process activities indicates ,,

that sufficient efforts are being implemented to ' assure;_ material traceability and control. l The documents reviewed for material traceability are g- as .- fo11cws : l f -. . . .I Weld Filler Material Requisition '! < Receiving Inspection Check List . Receiving Inspection Check Report . Material Test Report . Weld' Rod Issue Tag . ,. " Weld-and Inspection Record , ,. ' { 3 l ! > > - i + . , i 1 M t 39 1 ,r -e-,.e - .- ,- , ,w vn+, , , + -w-- , - ~ , - , , - - - - , , - - ,,vr -,~ - ,,,- ~s, - -

. __ ' Noncompliance (456/82-C3-01d; 457/82-03-01d) Weld rod control after issue from weld rod issue - station is deficient in the area of discarding of spoiled or damaged weld filler material. The discarded weld rods were observed to be not bent double as required by QCP B.8. This failure to , control weld rod is contrary to 10 CFR 50, Appendix t B, Criterion V and is an item of noncompliance. (c) American Bridge & Iron Division, U.S. Steel Corporation 1. Review of Procedures The following procedure was reviewed: QA #7 - Weld Electrode Control & Field Welding Control. 2. Review of Records Selected six (6) structural beams for material trace- ability; 3 each from Unit #1 and #2 auxiliary building. Beams selected were as follows: Beam ID Building Unit # B402B3 Auxiliary 1 A514B6 Auxiliary 2 B423B5 Auxiliary 1 A515B1 Auxiliary 2 ' B402B6 Auxiliary 1 A513B1 Auxiliary 2

The data packages reviewed consisted of the following documents: Purchase Order (CECO) . Material / Service Request . Material and Equipment Receiving and Inspection . Report ., " Shipping Statement . Certified Material Test Report . A study of the data packages for the structures , selected, disclosed the following: 4 Date S&L Approval Beam Item # HT # Letter P.O. # A514B6 6039T(Y) 2R7468 5/2/77 186236 B423B5 - (Y) H09560 11/28/78 186236 40 . , ,_, _, - . - , . . . _ --.3 - -

B402B6 -(Y) 68A161 8/15/77 186236 A513B1 6057(Y) K55737 4/27/77 186236 H46461 A515B1 6080T(Y) H46701 6/24/77 186236 B402B3 - (Y) H09560 11/28/78 186236 American Bridge & Iron's welding efforts ended May 1978, and no' attempt was made to review welder quali- fication records or weld material traceability. (d) Napoleon Steel Contractors, Inc. 1 Review of Procedures 3 The following procedures were reviewed:

1. 5 - Welding
2. 6 - Erection of Structural Steel

2. Review of Records Selected six (6) structural beams for Material Trace- ability; 3 each from containment #1 and #2. Beams selected were as follows: Beam Unit B112BB1 1 B113BB1 1 A125BB1 1 A226BB1 2 A243B2 2 A239BB3 2 The data packages reviewed consisted of the following documents: Purchase Order (CECO) . Material Service Request . Material and Equipment Receiving and Inspection . Report Shipping Order . Certified Material Test Report . A study of the data packages for the structures selected, disclosed the following: 41

. . . - _ , 4 . s i Date S&L 4 Approval Beam Item # Size Heat # Letter P.O. # MRR # , BB112BB1 90127 (1-1/2")_ 69C167 6/21/78 186236 2468 2 1510 (3/4") W92312 8/15/77 186236 '2468 B113BB1 11052 (1.0") 1510 (3/4")' W92312 8/15/77 186236 2468 A125BB1 90127 (1-1/2") 69C167 6/21/78- 186236- 2468 90127 (3/4")

90127 (1/8") -Y35895 8/15/77 186236 2468 A226BB1 21091 (1/2") Y34571 9/16/78 186236 .2468 11154 (2/3") Y87516 8/8/78 186236 2468 (3/4") 52A319 None- 186236 2468 , A243B2 15131L (Y) 1R7285 None 186236 2468 ' A239BB3 21066X (1.0") Y71000 6/5/78- 186236 2468 5/18-78 ' (3/4") W92312 8/15/77 186236 2468 (1/8") Y35895 9/16/78 186236 2468 3. Review of Welder Qualifications ! The review of weld qualification records consisted of reviewing the original qualification record as . . well as the supportive documents pertaining to their ! "up-date" qualification records. Napoleon Steel Contractors, Inc. welding efforts are to the AWS Code which require six (6) month re qualification periods. The inspector reviewed the following welder certi- fication and qualification records: , Name Welder ID # 2 C. Blanton- BB R. Thomas TT I ' The two (2) welders are representative of th'e eight ' (8) welders qualified by Napoleon Steel Contractors, Inc. 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 indicates that sufficiene. efforts are being implemented to assure materini traceability and control. The documents reviewed for material traceability are as follows: i 42 , .,. , . , . -- , . - . . --, , ..- ..

._ _ _ Material Requisition . Receiving Inspection Report . Material Test Report . Weld Material Issue Sheet . Weld Data Report . (e) Nuclear Installation Services Co. 1 Review of Procedures The following site procedures were reviewed: E.S.-24 - Procurement of Mild Steel Covered Arc-Welding (Electrodes) E.S.-25 - Procurement of Stainless Steel Covered Arc-Wolding Electroces to SFA 5.4. E.S.-27 - Procurement of Bore Electrodes to SFA-5.9. E.S.-28 - Procurement of Mild Steel Bare Electrodes to SFA-5.18. E. A.-123 - General Welding Procedure. 2. Review of Records The documents reviewed for weld material traceability are as follows: Weld Material Request. . Material Test Report . Weld Rod Request. . Weld Data Sheet. . Weld Material Issue Tag. . 3. Review of Welder Qualifications 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. The NISCo welding efforts are to the AWS Code which requires six-(6) month re qualification periods. The inspector reviewed the following welder certifi- cation and qualification records: Name Welder ID S. Strafelda 9587 N. Gulley 6393 These two (2) welders are representative of the four (4) welders qualified by NISCo and are presently on site. 43 - - - _ - _ _ _ _ _ - _ _ - _ _ - _ _ _ _ _ _ _ _ _ - _ _ . _ _ _-__. - _ _ _ _ _ _ _ _ _ . _ _ _ _ .

. - _ _ _ _ _ _ - _ - - _ - _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ . . _ _ _ - . 4. Review of Wold Material Control The review of weld material control procedures and direct observation of in-process activities indicates that sufficient efforts are being imple- mented to assure material traceability and control. (f) Gust K. Newberg and Associates 1. Review of Procedures The following site procedures was reviewedi

1. 25

Receipt, Storage and Control of Welding Materials.

1. 26 - Welding.
2. 40 - Stainless Steel Welding.

2. Review of Records The documents reviewed for weld material traceability are'as follows: ' Weld Material Request. . Material Test Report. . Weld Rod Request. . Weld Data Sheet. . Weld Material Issue Tag. . 3. Review of Welder Qualification The review of welder qualification records consisted. of reviewing the original qualification records as I well as the supportive documents pertaining to their "up-date" qualification records. The Gust K. Newberg. and Associates welding efforts are to the AWS Code which requires six (6) month re qualification periods. The inspector reviewed. the following welder certifica- tion and qualification records: Name Welder ID G. Cloonen CCC J. Fisher 101 B. Hamman MM R. Bone WW These four (4) welders are representative of the twenty-six (26) welders qualified by Gust K. Newberg and Associates and are presently on site. 44 -- _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _

4. Review of Weld Material Control The review of weld material control procedures and direct observation of in process activities indicates that sufficient efforts are being implemented to assure material traceability and control. (g) Pullman Construction Industries, Inc. 1 Review of Procedures The following site procedures were reviewed: -B6.1.F - Document Control. B16.1.F - Non-Conformance/ Corrective Action. B9.2.F - Control of Welding Filler Metal. 2. Review of Records The documents reviewed for weld material traceability are as follows: Weld Material Request. . Certified Materials Test Report. . Weld Rod Request. . Wold Data Sheet. . Weld Material Issue Tag. . Receiving Inspection Report. . Fabrication Ticket. . 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. The Pullman Con- struction Industries, Inc. welding efforts are to the AWS Code which requires six (6) month re quali- fication periods. The inspector reviewed the following welder certi- fication and qualification records: Name Welder ID . Steve Caise PF-12 Terry Hahn PF-30 , t' R. Tusek PF-33 i R. E. Watson PF-36 C. Tull PF-40 4 ] 45 L.

These five' (5) welders are representatives of the twenty-nine (29) welders qualified by. Pullman Con- struction Industries, Inc~. 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 indicates that' sufficient efforts are being imple- mented to assure material traceability and control. Except as noted, within the areas inspected, no items of noncom- pliance or deviations were identified. 46

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 cable 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 L. K. Comstock and Company, Incorporated (LKC) procedures: 1. Procedure 4.3.1, Safety Related Conduit Installation, Revision July 18, 1980. Revised June 3, 1982. 2. Procedure 4.3.5, Safety Related Cable Pan Installation, Revision May 27, 1981. 3. Procedure 4.3.8, Cable Installation, Revision June 11, 1981. Revision May 20, 1982 - has interim approval (CECO only), Revised June 3, 1982. 4. Procedure 4.3.9, Cable Termination Installation, Revision May 28, 1981. 5. Procedure 4.3.12, Conduit and Cable Pan Hangers and Auxiliary Steel Installation, Revision, June 10, 1981. 6. Procedure 4.3.19, Housekeeping and Protection of Safety Related Class 1E Cables, Revision March 27, 1981. 7. Procedure 4.8.0, Inspection and Test Sampling Plan, Revision October 6, 1980. CECO issued a memo directing LKC to delete and remove this procedure from their manual. 8. Procedure 4.8.1, Inspection of Class 1E Safety Related Conduit Installations, Revision June 5, 1981. 47

9. Procedure 4.8.5, Inspection of Class 1E Safety Related Cable Pan Installations, Revisicn October 2, 1981. 10. Procedure 4.8.8, Cable Installat. ion inspection, -Revision December 7, 1981. 11. Procedure 4.8.12, Inspection of Seismic Class.I Supports / Hangers, Revision February 9, 1982. 12. - Procedure 4.8.19, QC Housekeeping Inspection and Verification Procedure for Protection of Class I Cable, Revision March 27, 1981. Noncompliance (05-456/82-03-04; 05-457/82-03-04) a. During a review of LKC procedures 4.3.1, Safety Related Conduit Installation, and 4.8.1, Inspection of Class 1E Safety Related Conduit Installations, it was observed that paragraph 3.12, of procedure 4.3.1, addressed the installation of caps / plugs in conduit to prevent - foreign matter from entering the conduit until the electrical cables are installed in accordance with Sargent and Lundy (S&L) Standard, STD-EB-146, dated December 28, 1979. It was further observed that.the verification of the installation of conduit caps / plugs was not addressed in procedure 4.8.1, nor in procedure 4.8.19, QC ibisekeeping Inspection and Verification Procedure for Protection of Class I Cable. . b. During a review of LKC procedures 4.3.8, Cable Installation, and 4.8.8, Cable Installation Inspec- tion, it was observed that the subject procedures do not address electrical cable rework. Example: j- An electrical cable has been installed per Revision A of the ' cable pull . card 'and Revision B of the pull l card requires that the cable be " pulled back" toi l 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 i 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. Failure to provide adequate instructions or procedures - i to accomplish activities affecting quality in accordance with Quality Program provisions is an item of noncom- pliance with Criterion V of 10 CFR 50, Appendix 3. , i ) i 48

e

As a result of this inspection, procedure 4.3.8, Cable Installation, was revised on June 3, 1982 to incorporate an electrical cable rework procedure. This procedure was submitted to Ceco for review and approval. Upon their review, the procedure will be submitted to S&L for their review and approval. (b) Review of Storage Facilities - Cable Yard The inspector toured the cable reel yard to verify proper storage and to select several cable reel numbers for a follow-up review of material receiving reports (MRR) and vendor documentation. The cable reels were stored on dunnage, identified, and drainage appeared to be adequate. Cable reel numbers BR-40, BR-125A, BR-52, and BR-362 were selected for record review. (c) Review of Electrical Work Activities 1. During a tour of the power block, the inspector observed that two 4" pipes, CC-27 and CC-29, were within 1/2" and 1" of cable pan 1884U-C1E in the Auxiliary Building at the 401' elevation. It appears that this situation does not meet the intent of Regulatory Guide 1.29, Seismic Design Classification. Unresolved Item (456/82-03-05; 457/82-03-05) Pending a review of the licensee's program to identify like situations and S&L's analysis of the possible conflicts with Regulatory Guide 1.29, this item is unresolved. 2. The inspector verified that electrical cables ISI129-C1E, 1SX013-C2E, 1SX016-C2E, and ISX017-C2E were routed in accordance with their respective cable pull card. l a. Cable ISI129-C1E, cable card - Revision A, ' cable reel number BR-36, cable type 12/c-14, 600 V. The cable extends from Main Control 1PM06J to Motor Control Center 131X28 (1AP25E-A). The cable was physically verified in routing points 1R484-C1E, 12032C-C1E, 12031C-C1E, , l 12030C-C1E, 12024C-C1E, 12015C-C1E, 11949C-C1E, ! 11906C-C1E, 12013C-C1E, 1R267-C1E, 11341B-CIE, 11340B-C1E, 11338B-CIE, 11336B-C1E, 11335B-CIE, ! 1997B-C1E, 11328B-C1E, and 11323B-C1E. b. Cable ISX016-C2E, cable card - Revision A, cable reel number BR-36, cable type 9/c-14, 600 V. The cable extends from ESF Switchgear to the Remote Shutdown Control Panel. The cable was 7 ! l 49 <

physically verified in routing points 11383M-C2E, 11384M-C2E, 11380M-C2E, 11378M-C2E, 11379M-C2E, 1R361-C2E, 1702B-C2E, 1906B-C2E, 1905B-C2E, 1904B-C2E, 1901B-C2E, 1900B-C2E, 1889BH-C2E, and 1613H-C2E. c Cable 1SX013-C2E, cable card - Revision B, 3 cabic reel number BR-20, cable type 2/c-10, 600 V. The cable extends from ESF Switchgear 142 to ESF Motor Control Center 132X3. The cable was physically verified in routing points 11383M-C2E, 11384M-C2E, 11380M-C2E, 11378M-C2E, 11379M-C2E, 1R361-C2E, 1702B-C2E, 1906B-C2E, 1905B-C2E,-1904B-C2E, 1901B-C2E, 1900B-C2E, 1894B-C2E, 1R244-C2E, 1734S-C2E, and 1735S-C2E. d. Cable 1SX017-C2E, cabic card - Revision A, cable reel number BR-36, cable type 9/c-14, 600 V. The cable-extends from ESF Switchgear 142 to the Remote Shutdown Control Panel. The cable was physically verified in routing points 11383M-C2E, 11384M-C2E, 11380M-C2E, 11378M-C2E, 11379M-C2E, 1R361-C2E, 1702B-C2E, 1906B-C2E, 1905B-C2E, 1904B-C2E, 1901B-C2E, 1900B-C2E, 1889BH-C2E,-1887H-C2E, 1R276-C2E, 1613H-C2E, 1615H-C2E, and 1616H-C2E. e. The inspector observed the inprogress pulling of cable 1SX093. There appeared to be sufficient craftpersons assigned to the pull and a Level II QC Inspector was present during the pull. The foreman had the latest revision (May 20, 1982) of the cable pulling work instruction but the - QC Inspector had an out-of-date work instruction , ' and an up-to-date inspection procedure for cable pulling. The licensee took immediate action to have the out-of-date instruction replaced. During a visit to LKC's QC office, the inspector spot checked various inspectors procedure books and all procedures checked were of the current revision. (d) Interviews with Personnel i During discussions with the craft personnel involved in the pulling of cable ISX093, the appeared knowledgeable and proud of their work. The LKC personnel interviewed appeared to be knowledgeable in their procedures and were aware of the documentation requirements. , 50

(e) Review of Procurement Cocumentation - Class 1E Cable 1 The inspector reviewed the procurement documentation relative to 600 V and 5 KV Class IE electrical cable. The cable specifications, Material and Equipment Receiv- ing and Inspection Reports (MRR), and vendor documenta- tion was reviewed. The following observations were made: 1. The licensee purchased elec*rical cable from Okonite Company to Sargent and Lundy (S&L) specifications 2823 and 2851 and from Sammuel Moore Company to S&L specifications 2852. a. Cable Reel BR-40, QC No. 82556-B, type 3/c-4/0, 5 KV, specification 2851, was received on December 27, 1979 on MRR 5604. The cable was _given an " Interim Acceptance" on January 2, 1980, and a " Final Acceptance" on July 8, 1980, after receiving S&L approval of all the docu- mentation on July 2, 1980. Interim Acceptance is given upon receipt and acceptance of: Certificate of Compliance; Certificate of Conformance; Certified Test Reports; Results of Water Absorption Tests; Results of Ozone Resistance Tests and High Potential Voltage Tests. Final Acceptance is given upon receipt and acceptance of the above listed documents and receipt and acceptance of the Flame Tests and Tests for Design Basic Events. , b. Cable Reel BR-125, QC No. 47651A1, type 2/c-10, 600 V, specification 2823, was received May 18, ! 1982, on MRR 8882. Interim accepted May 21, 1982. Final acceptance not granted as of ' May 24, 1982. c. Cable Reel BR-5, QC No. 65797, type 3/c-500 MCM, 5 KV. specifications 2851, was received December 6, 1978, on MRR 3501. Final acceptance August 6, 1979. d. Cable Reel BR-362, QC No. 47919D, type 12/c-14, i 600 V, specifications 2823, was received May 6, 1982, on MRR 8843. Interim acceptance May 6, 1982. Final acceptance not granted as of May 24, 1982. l ! l l i I 51 l

. . . . I l 4 ^ \\ Cable Reel BR-52, QC No. 015140-1, type 3/c 16, .e. 600 V, specification 2852,'was received May 5, -1981, on MRR 7099. Interim acceptance on May 11, 1981. Final acceptance on September 3, 1981. .I (f) . Review of Class 1E Cable Installation Records The inspector reviewed the Class IE cable installation records for the following cables to verify that correct. cable type was installed, raceway was inspected prior to pulling cable, and that QC had accepted the cable pull. ISI129-CIE 1AP117-P2E , ISX013-C2E 1AP118-C2E ISX017-C2E 1AP147-P1E ISX016-C2E 1AP152-P2E Except as noted, within the areas inspected, no items of noncom- pliance or deviations were identified. d . i e J 1 ' 52 I , w-- ,e--, . , , < ,w , , , - - - , ,

Prepared By: J. H. Neisler g. In-Process Inspections (1) Objectives The objective of this assessment was to determine if in process inspection activities were being accomplished with adequate procedural control, if personnel have been trained in the use of the procedures, and whether they understand the procedure requirements pertaining to inspection activities. (2) Discussion The assessment included a review of inspection procedures and their implementation in use by contractor inspection activities in the following areas: Mechanical and Piping Concrete and Structural Soils and Foundations Electrical Nondestructive Examination The inspector examined welding process and data packages for weld joints in the auxiliary feedwater system, reactor coolant loop piping, residual heat removal system piping, chemical and volume control system piping and the component cooling water system piping. The inspector noted that receipt inspections had been performed to determine if material complied with purchase specifications. Fitup inspections had been performed. Visual inspections of welds had been performed and that the assigned hold points had not been bypassed. The piping contractor's quality inspectors perform only visual inspections on weld- ments; all other Code required examinations such as radio- graphy, magnetic particle and ultrasonics are performed by an independent testing agency under contract to the licensee's Quality Assurance Department. Safety related civil activities at Braidwood are essentially complete. The inspector examined concrete pour records for fourteen safety related concrete pours. The records indicate that QC inspectors verified form cleanliness, compaction, vibration, mixing revolutions, curing times and methods, and that post pour inspections were performed. Required testing involving air entrainment, slump, compression strengths and uniformity tests were performed by the licensee's independent testing contractor. The inspector did not identify indications of inspection procedure violations in this area. 53

All work involving soils and foundations have been completed. The inspector examined records relative to soils and backfill placement inspections and testing in safety related areas. Included were five inplace density' test reports showing the results of eight relative density tests and eight percent compaction tests. Records indicate that the tests were per-

formed according to ASTM specifications and site procedures. The inspector examined records of electrical inspections performed on installation of electrical equipment and raceways. , In addition, the inspector selected several completed installa- tions and performed verification inspection that the installa- tion was in accordance with drawings and that the completed installation was as stated in the inspection reports. Electrical installations, in particular welding, are in- spected by the contractor's QC inspectors and then an addi- tional number of the welds are inspected by the licensee's independent inspection contractor. . Training records and procedures were examined for all the above contractors. Discussions with QC personnel indicated that their training was adequate to enable them to perform their assigned functions. The results of the inspections performed as a component of this assessment of Braidwood's In-Process Inspection program . indicates that procedures in general are adequate. Personnel have received the appropriate training and orientation for their level of inspection activity. The-procedures are being properly implemented with adequate checklists and hold points. No items of noncompliance or deviations were identified.

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Prepared By: G. L. McGregor h. Q.C. 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, ANSI SNT-TC-1A, USNRC Regulatory Guides 1.58, USNRC Generic Letter 81-01; CECO Quality Assurance Program Manuals, CECO Response to Generic Letter 81-01 (L. D. De1 George to D. G. Eisenhut - August 17, 1981); and Contractor Quality Assurance Manuals. (2) Discussion The individuals selected for interview were chosen at random by the NRC Inspector from QA/QC inspector lists furnished by each contractor. All contractors utilizing QA/QC personnel to monitor and accept production activities at the site were selected. The organi- zations selected, production function monitored by the in- spectors, number of inspectors in the organization, number of inspectors interviewed and percentages are identified in Table I. Each inspector interviewed was asked a standard set of questions. The answers provided were summarized and are provided as Table II. The individuals selected for interview were requested to provide the record of their training, qualification and certification to the NRC inspector. The inspector reviewed each of the training, qualifications and certification records to verify compliance with applicable regulatory requirements, standards and FSAR commitments. In verifying the implementation of the approved requirements emphasis was ! placed on (1) evaluation of performance / reevaluation; (2) de- termination of initial capability by suitable evaluation; (3) physical requirements identified and examined yearly; (4) written certification in appropriate form; (5) records of qualification established and maintained; and (6) quali- fication criteria followed. [ Table II is provided as a summary of QC/QC inspector answers ! to the standard set of interview questions. Answers to questions 1, 2, 4, and 5 are self-evident and do not require further definitions. ! 55

Question 3 relates to the number of inspectors that indicated during their answers to question 2 that they had prior inspec- tion experience. Of the 46 inspectors, 78% indicated prior nuclear inspection experience; only 17% no nuclear experience; and 4% had no inspector experience. Question 6: All inspectors answered with a resounding N0 or very few hours per week. When asked to qualify "very few hours", the inspectors replied two to three hours with a maximum of 8 hours in any week. Questions 7 and 8: The inspectors indicated that an insufficent number of QC inspectors contributed to work being backlogged. Concrete expansion anchors, some small bore pipe welding, and cable pan supports were indicated as areas which need extra inspection efforts. One inspector noted that radiographs with questionable indica- tions were being approved by contractor QC personnel or addi- tional radiographs were being taken. Specific examples were given. The RIII inspector reviewed the radiographs for the examples given, as well as for several adjacent weld joints. No ASME Code unacceptable indications were identified. Question 9: The inspectors generally feel they have the l authority to stop an activity if their contractor's work is not being properly performed. Question 10: The majority of inspectors interviewed indicated that the training they received was adequate for the work activity they are required to perform. The majority of in- spectors indicated they would welcome additional training. Question 11: The inspectors do not feel that a lack of inspection personnel has caused construction activities to come to a stop. Questi.a 12: All inspectors indicated that their activity did not require additional checklist data sheets or guide- lines. One inspector felt that the welding production foreman should sign the completed work form before turnover to the QC department for inspection. Question 13: All inspectors indicated they have no problems ' going to their management, regardless of the position, to communicate their problems. Open Item (456/82-93--06; 457/82-03-06) Based on the interview of inspectors, it is apparent that some areas are in need of additional inspectors to ensure 56

that a backlog of inspections does not exist and that in- creased work efforts do not compound the inspection program. No items of noncompliance or deviations were identified. 3. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain weather they are acceptable items, violations, or deviations. Unresolved items disclosed during this inspection are dis- cussed in Paragraph f.(2).(c).1 4. Exit Interview The inspectors met with licensee personnel (denoted in Paragraph 1) at the conclusion of the inspection ~on June 4, 1982. The inspectors summarized the scope and findings of the special inspection, which were acknowledged by the licensee. Attachments: 1. Table I, QC/QA Inspection Interview Summary 2. Table II, Summary of Questions Asked QC/QA Inspectors 'During Interviews

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_ _. - _ _ _ _ _ . - -_ TABLE I QA/QC INSPECTOR INTERVIEW SUMMARY Total Inspectors Organization Function Inspectors Interviewed % G. K. Newberg General Contractor 1 1 100 Concrete and Labor Force NISCO Erection NSSS Equipment 2 1 50 Wallgren Concrete Block Wall 2 1 50 Erection Napoleon Containment Tendon 5 3 60 Installation Midway Field Finish Coatings 1 1 -100 Pullman HVAC 2 2 00. Pittsburgh Independent Inspection 22 13 59 Testing Lab (PTL) ANL Testing, NDT and Concrete L. K. Comstock Electrical 20 9 45 Phillips, Piping Systems 23 14 61 Getschow . . . . . . . . . . .

_ TABLE II SUMMARY OF QUESTIONS ASKED QC/QA INSPECTORS DURING INTERVIEWS <3 mo. <6 mo. 6 mo.-1 yr. 1. How long employed as an inspector onsite? 0 1 7 1-2 yr. 2-3 yr. >3 yr. >5 yrs. 11 5 11 10 Years Yes No 2. Prior inspection experience? <1 1 2 1-2 10 >3-4 10 >5 22 Nuclear Non-Nuclear 3. What discipline (s)? 37 8 Yes No Comments 4. Is there a sense of intimidation 44 based upon the need/ requirement to keep up with construction? 5. Is there a reluctance to make 44 adverse findings if they will impact on the construction or audit schedule? 6. Is it routine for QC inspectors 45 l to be working frequent and/or i excessive overtime? ! l 7. Do the inspectors feel that their 22 22 Need more l particular section is adequately inspectors for staffed? welding and con- l crete expansion i anchors l l l ( m

, , _ ______ _ _-_________ _ Yes No Comments 8. Do they feel the required inspec- 32 10 Backlog for tions are being conducted promptly? hangers 9. Do the QC inspectors have stop work 42 1 and/or stop process authority? Have they ever used this authority? 33 1 If so do they feel they were supported 33 or will have the support of manage- ment in the event of a stop work? 10. Do the inspectors feel the training 40 4 More formal they have been provised is adequate? classroom training for General Fore- men and Foremen 11. Do situations arise where the lack 43 of a QC inspector causes construction activities to come to a stop? 12. Are the QC inspectors provided 43 adequate check lists for all activities they are inspecting? 13. Do-they feel that they have an 43 avenue to management if they come across a problem? Do they feel managment will get 43 involved? The totals for the questions dif fer because of the type of inspectors inter- viewed and the inspector replies to the various questions. \\ _ ______________________________________J }}