ML20072D193

QA Manual 18-1.2 Audit Rept.Related Correspondence Encl

ML20072D193
Person / Time
Site:	LaSalle
Issue date:	08/04/1981
From:	Hansing K COMMONWEALTH EDISON CO.
To:
Shared Package
ML20072D133	List: ML20072D170 ML20072D181 ML20072D189 ML20072D193
References
FOIA-83-89 NUDOCS 8306230039
Download: ML20072D193 (60)

Text

d' 0 P. FORM 18-1.2 fD DAT~' "8-4-81 Commonn21th (?.hs % Edhon Corap.ey e

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QUALITY ASSURANCE MANUAL AtfDIT REPORT G.O. Audit of Mor$*ison Construction Coc:pany laSalla Project Type Audit:

r7?regram Audit

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/ Product inspection Point L / Records G Specie.1 To:

J. Ha:nilton, Merris.m Construction Co rnany - ?:oject Manager Project _ L2Salle

_ _ Visit Date-6/29 - 7],53.0 port 2cte 7/8/S?

1932 Systm _

Co porent Identification N/A N/A Materisl Descrip:ior.

N/A Ver.de-7_arrison Cerstruttien Co. _ Location La5alle Subcon.ractor_

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_ Location N/A Car n:::

See He:t?t P.C. :10. 181110 Spec. No.

J-2530 Reece.:er5ed Inspections:

5 mos 3 mas 1 no Others__ As Scheduled._ _ _

Oiotes:

See Report Auditor E

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amt-,cer of Director of QA (Engr-Censtr)

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Site Constr. Supt. or Proj.

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Prod 4ct Manaser

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unaler of Projacts (List otacrs as required)

Aud:, tee

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A1 CIT RbTCRT TM PTRISON CONS'.RUCTION CCMPANY IASA1.T5 PRO.~.ECT JULY 3. 1932 P'310. 3E.

I.c pur Cer;.uy's (p.we of this audit was to evaluate Morrison ConstructionW;Co cent:A &ccrds, records corr.rcl and the Q.:ality Centrol review f=tticn-Mdition2117. the audit, inspectio.2 and su.veillen:

activities 1.t the area of MCCc cz.liS;rstien were evaluated to dete=ine if re7; ired reviews were parformed and t o ass:ss the c:etbility of their revie2 -sne sssociated documentation.

SCOTi I^.is audt exa:nined the following areas:

1.

CECO audits of McCo calibration activities

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GCo auditor cualifications 3.

Credibility of CECO audits 4.

Ceco surveillances of MCCo calibration activities 5

Authori:ed Nuclear inspector's involvement in McCo calibration ac t i,*i ties 6.

NCC: audits of McCo calibration activities 7.

Fr.C it:Yo!Ve::ent in MCCo calibration activities 3.

Ceco or MCCo NC1's generated which address calibration activitics 3.

'lecaire:xnt.s and perf accance of Quality Control reviews 10 Disp %itioning of out-of-calibration.or damspd calibrat:d tools and equipaent.

I li. A broad scope review of other dociantation activities to assess whether the types of documentation probicms identified in tle torque wrench calibration activities existed in other areas l

12. Trainin;, skills, and qualifications of MCCo personaci perfor ing l

tellbration functions

13. McCo review of calibtstions performed by others for them 11.

nccords control

15. Accornn bility of records

16. 7:rformance of.alibrations 17.

Celib a: ion procedure 2demiacy i

13. Stora;e and naintenance of calibrated tools and equip::ent

13..i r-view of all calibration records not recently revicwed by

ne ?.itC as part of the investigation.

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]5$.}!.f Page 2 AUDIT TEAM The G.O. QA audit team consisted of the following personnel:

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Principal Team Members D. A. Brown Auditor QA Supervisor-Braidwood.

S. M. Jaquez Auditor QA Engineer-Draidwood S. J. Reutcke Auditor QA Engineer-LaSalle R. D. Vine Auditor QA Engineer-LaSalle R. E. Waninski Auditor QA Engineer-LaSalle K. J. Hansing Lead Auditor QA Supervisor-Byron G. F. Marcus Management Observer Director Quality Assurance (Engr /Constr)

Others G. M. Maksimuk Auditor-Data Taker QA Engineer-LaSalle A. M. Montalt.o Auditor-Data Taker QA Inspector-LaSalle E. A. Kram Auditor-Data Taker QA Engineer-Braidwood R. F. Sneets Observer QA Engineer-LaSalle M. J. Wendell Observer QA Engineer-LaSalle Auditing activities conducted by the data takers and the LaSalle personnel were performed under the direction of a principal team member and were reviewed by an off-site member of the audit team.

PEP.50\\NEL CDNTACIED Thh fc11owing personnel were contacted during the course of this audit:

M. Wherry MCCo QC Supervisor D. Kanakares MCCo QC Inspector D. Ko-lowsky MCCo QC Inspector P. Granby MCCo QC Inspector B. Hamilton M(Io QC Inspector

- --- B. Angell MCCo QC Inspector I

R. McClosky MCCo QC Inspector T. Harrington MCCo (Former) QC Inspector K. Hamilton MCCo Project Manager B. Balz MCCo Head Doc. Clerk J. Terry MCCo QC Inspector J. Bitner MCCo QC Inspector D. Shamblin Ceco Proj. Constr. Super.

A. Fatak Continental Insurance MCCo. ANI W. Caldwell Hartford Insurance CECO's AN1 l

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'I Page 3 EN*IM.NCE MSETING

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An entrsne; meeting was conducted on June 29, 1982 with t.he following personnel in a: ten. lance:

• K. J. Har. sit:;

GCo QA Lead Auditor

• R. Wninski CECO QA Auditor

• S. M. Jaca:

GCo QA Auditor

• S. J. Rettche GCo QA Auditor D. L. sht:blin CCo PCD Site Proj. Const. St.pt.

D. A. Brcwn CSCo QA Auditor aK. J. H.y.ilton MCCo Project M3 nager aM. 5herry McCo QC Supervisor W. E. Vahle CCo PCD Lead Me6.2.ncial Engineer

~!. A. 3:zun CECO QA CA Superviser R. 3. Vir.e GCo QA Auditor v.'. E. Qmka GCo (JA 5;te QA 5:.:perintendent

• D. J. Skc:.a GCo PCD Engineer

3. J. Kanarates MCCo (C Inspector G. 7. Marcus CECO RA - G3 Managunent Observer ihe 3ccpc of the audit wss discussed at this time.

donctes present it 3.<1t meeting.

ET beim An exit :r.eeting was conducted on 7/8/82. The audit results were discussed and acP.nowledged by those present. The foilewi ig persannel w.:r: present Et the exit meeting in addition to the personnel indicated above:

A. R. H.WFman McCo QA Engineer R. T. Ecse CCo PCD Lead Struct. Eng.

J. J. N iey GCo knager of Projects

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OVERAIL AUDIT ASSESSGT l

It is the conclusion of this audit team, based on the extensive review of McCo c:ality records, ths; the doctmentation problems orir,inally identified by the ERC are limited to calibration records.

It was further concluced that the duplicating of sme signatures and data did not appear to be an atteapt to falsify quality records but rather was a tWe savr.r.g reasure used ta handle the numerous, repetitious calibration racords a.s they viewed the calisration functions as a go, nc-go type ch:ck.

I Relative to the adeqaacy of the surveillance and audit activities, cur eva'. union indicates th.at many q.mlidled individuals had exanined thi s area ard that without being specifically attentive to looking for rec:rd alterat'.ons they would not have identified tnis as a quality issue. Fmination of the overall surveillance and audit process, hswsver, does indicate that our auditing methodolorf involving large nt.abers of si:'tilar records needs to be changed to provide that larger sa ples be taken to achieve a better assessment. As a result, Quality Assurance has.crcmitted to implement this change.

Evaluatien of the reports where torque vrenches were fomd to be out of czlibratica or had c,nestionable calibration data or records were dested to have no adverse impact on plant construction. This is based on the records reviewed and the results of independent inspections of bolt torg:ing by the Independent Testing Agency involving Morrison. The inspecti:n, conducted by Ceco.'s independent Testing Agency, exar.ined 5,756 Morrison installations between 1977 ani June 1952. Only 81 of the 3,756 installations were rejected for low torque valdes during the 6 year j

period. The reject rate of less than 1.2% supports the conclusion that tc rge vrer.ch calibration was net : problem and helps explain, at least i

Ir. part, why this calibration docu:nen'.aticA matter,had not surfaced.

In sedition, e.umination by Q:ality Assurance of follow-up checks

< enducted by Project Construction of other calibration areas has not identifled any cases where the installed cetxlition of Unit #1 equi':nent

ppaars questionsble.

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Assessment of Audit questions 1-3 2 In order to ascertain if there were any actions which could have discovered the " deficiencies" in Morrisen calibration records which are the subject of this audit, the follewing areas were investigated.

1) Adequacy of site QA audits 6 surveillances

2) I:wolvement cf GCo 4 McCo ANI's

3) Trends of applicable GCo 4 MCCo NGt's O Mequacy of McCo it.ternal auditing

5) Past NRC site insocction activitics

5) Adequacy of GCo G.O. QA audits The efhrt was directed at detemining if this problem went unMectM due to oversight by many parties or a widespread problem not ade uately :tddressW. The results in these areas can be generali:ed as follass:

(1) MCCo's.\\NI and GCo's ANI did not document evidence of examining calibration reports as this was their normal practice in the pas t..

(2) Rerton III Inspections (57 in 193161982) did not uncover any problais with McCo quality control records.

Five of the fifty-seven site visits involved review of MCCo c,uality records.

One of these visits involved an NRC investigation of an allegnion of lack of control of quality records.

(3) No GCo NCR's have had to be issued for ccncerns relating to MCCo calibratfor) reccrds. Therefore, no trends were overlooked.

(4) No MCCo NCR's have had to be issued for concerns relating to calibration records. Therefore, no trends were overlooked.

(5) Morrison internal audits of calibration activities have been extensive ano did not identify any calibratinn record prshlems.

(6) GCo Site OA surveillance acitivites consisting of 27 celibration curveillances, which specifically covered thirteen cal:bratien records since 1979, were found to have adequste cover:p and fregency.

(7) Wenty-four Site GCo QA audits were done on scheduls with c.ualified auditors and recordai objective evidencs is sufficient to support the conclusions of those audits. Of the audits conducted since 1979, nine covered sits calibration activities.

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L Page 6 (E) G.O. audits addressed the areas of Morrison calibration cctivities and did not discover sbilar calibration do:umentation probicas.

(9) Site CCCo QA exmined 64 MCCo calibration reports during its curveillances and audits since 1979.

(107 !!one of the Morrison calibration docu.'xnts f';und deficient in the

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l2C investigatics wera specifically excnined in any GCo audit or i

cu rteillance.

In su-ntion, mar.y qualified individuals examined the calibration docu snts as we'l as.:.any other MCCo quality documents in ar.cordance with 4:ality auditing and surveillance plans; however, by the nature of the i

sa'plin; prvass inherent in the audit and surycillance process they did l

not spec 2fically discover the calibratien record deficiencies.

i Furthermre..withou;; being sensitized to lock ter record alterations or repe:ition either be alleta* ions, srecific training and experience or as a result of previcu.s probice s it is deubtful that the McCo calibratic.n doctcent type problems would be identified in the nomal audit and l

sun eillance process.

1.

Assessment of a::dit questions 13-16 In order to det mine the adecusev and accuracy of Quality Control reviews of pslity records, the following record types were enatined:

a.

Calibration records b.

Material procurecent doct.::ents j

c.

Eiterial receipt records d.

Irstillation doce.entation/ travelers i

e.

m reports f.

NCR's g.

Test reports h.

Precedures and work instructions

'c evaluatien was mde of the adeg:acy of the Quality Control revieus f3.1 the aboVe listed record types b' eAamining the Quality A%;drance manual and procedure requirements and by interviewing the Quality Control personnel who perfom the reviews.

It was found that the require'nents and meaning of the Quality Control reviass were not clearly delineated in the procedures for several of the i

reccrd types. As a result of interviewing the MCCo Quality Control persernel performing the actus1 revice.,, it appears that these Quality Control per::ornel are knowledy. cable in how to do the reviews and overall are doing adequate technical reviews. The lack of delineated l

rewirenents fer quality Control reviews is identified as a deficiency in Attachnent A of this repm.

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Page 7 To verify accuracy of Quality control reviews, a sample of each above l

listed recerd tyx was examined. Ifith the exception of calibrotion r: cords all of the record types reviewed were found coq 1ete ar.d a:ceptable. The deficien:y relating to calibration records is identified in Attache ent A cf this report.

To dete..ine proper disposition ef cut-of-calibratien or danged es.'.lbrated tools and equiptent, MCo NCR's were reviewed ;tr.d co: pared to t'.a Co Pe11ted Instrusent L62 and Hold Tag Log entri.:s involvin'g

C in?ted txis :M egiptent.

Thm.::;h this review it we deter =ined n.: MCCo.'s Cmlity Assur'ance haual require.7et,tv Settien 10.10, Aas not W rg corwistently foll;ded,in that noncentomances we:e not generated ev.h tima a calibrned thol or piece of egipant,'n.51 suspect aM put'on hW. The netd for issance of an NCR for suspect equipcent became a r:v.irer.ent en Octcir.:r.% 1979. ECo ?rceedure PC.31 dt,::s not include tts req.u.rexnt and thus appears to be a contributory;I nis and facter in th-ivenaistene issuance of NG's for suspect calibration.

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'.7.15 deficiency is ide.itified in Attachment A of this report.

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Assessee.-t of Audit Questions 17-22 2

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's A review,of all MCCo calibration reports, not previcttsly reviewed by NC. MS perftrced to deter ~iu the tises and extant. of ~dacu untation '

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problacs. This review iden!)cied a reproducticn of signatures and,dda'p' fric probinm th15 ting co a:& is identified in Attachment A of this report.

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.uso, inNn afrort to determine if the problems'found in the

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es.ibratien trea sire present in othegMCCs Quality ^ Control-do:unenta:icn, a review of the followirtg documenis was perfomed; i

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s) Receiving inspections

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b) W ld dat., O.d' traveler matkages e

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c) Ar-3uilt dr 2wints with checklist,s (mall bore), ' '~' -

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Page 3 d) Cemenent support checklists e) Mec'anical revision directives f) NCR's g) NCR Los h) Final line wal's reports il Pressure test reports j)) ASu Code Data Reports (C2Co supplied) x NUE Regnns u \\b!h/ Luu6'ivA > J a w u it.".*e 1 n) On 41te audits n) Purchase requisitions n) Ecider qualificaticns p) Qus11ty Control inspector qualifications

<C Calibratien personnel certifications This extensive review fcund only isolated instances of the use cf white out, incertplate information red Starping of Quality Control spproval siy.stures. Also, the isolated cases of white-cut identified

.: era judpd to he *or ective actions and not an attenpt to falsify.

Furt).er ore, the use of white-cut on quality documents was not P.::ifically prohibitel at the site uatil Febn:ary 1932 t/nen a letter to tb.is effect ns sent to all site cont.ractors as a result of a recent.5EC penalty assessment against the Zimmer Project. As a result, it is the conclusion of this audit that the decW.entation problems only involve the c:librstica arn and the quality control docunent review activities of a specific 0'.:ality Control In:pector. Alsa, one. case was identified during e.h3 review of Quality Centrol Inspector qualifications where the cert:fication of an inspector was net signed but otherwise appeared in arder.

'~hia deficiency is identified in Attachment A to this report.

Since anst cf the problems identified in the calibration area were traceable ta onn Quality Centrol individual, an expanded review was perfora:(. cf other records processed by that person. A selection of reemr.is fr n the followini record ;ypes reviewed by that MCCo Q.nlity Cont /o1 Inspector vera exanined:

a) p.e civing *.r.d storage inspections b) NO. 's c)

Installation records d) Rer.niving reports c) Heat treatment records f) Purdase req.:isitions t) Fressure test memoranda 4 test results i

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• l Page 9, This e.-aminstien fcund no repetitious occurrences of the docinentation probicas noted in the calibration area. 'ihis further supports the audit conclusion that the generic docuncntation problems are isolated in the area of cdibrations.

4.

Assesscent of Audit Questiens 23-25 A review c! trainirg and qualification records for the mi11 wrights end fitters perforcing calibrations indicated tuat all '.wre properly traind and the training was doctrented. The training a;peare1 adequate and bl.ther the required skills were within crs!t cspability.

Sye ertlinations of Q'rality Control Inspectors periming calibration teihities were reviewed to andre they had teqaired vision capubilities

.d all were Ecund acceptabis. Additionally, the mi11 wrights and fitters perfercing calibrations were eye tested for near and' f ar visien acuity and all paned. An examinati)n of the areas where c211bratien is perfornec as :enduct:d te assure that odoquate lighting vas present; all areas ;are f:und acceptable.

A review of MC"o's handling of calibrations perfor=cd by the Opersti.ng 5tation Maintenmca repart:wmt indicrtad that MCCo des not h:n ad:q.:ste guidelines to awura review of est results for acceptability of the eslibration. Bis defic.ene-/ is identified in Attachment A to this report.

5 Assess.ent of Audit Questions 27-33 McCo bs establi:.hed and inplecented r.=asures to centrol occess to the !ccumntation vat'It by using a listing of perso:uinel authori:cd to ree;e dsc'r.erts fras the vr. nit and requiri2.g log.iing of decum. ents being takan in or cut and identificatien of the person involved. Also, since A ne 29, 1932, a security guard has been pestad at the vault te c un:ersi;n issuance of docrenr.atien, r;enitor the review of such isst.wd Scum ntadon to assure no alterstions are made and a.ssure that Unit #1 am e-r.mn decu=er:tation wi-h Unit 2 is only reviewed in the presence of the.luard. uditionally, all Unit #1 decmentation in the vault is sacured mth 1:cks on the file cabis e.ts.

lhis special security ar:sagecer.: is to be maintained until conclusion of the NRC investigation.

Print to the actions taken on June 29, '.?s2, the CICo Project Cmst uction Superintendent had verbally ecc.:nnicated.to the Mcr.a Project Erszer, on June '.4,1982 th.st actions shou'.d be taken to insure that no doctmnts?.ica would be altacad. This repairement was co.nuni.ated to the quality Control xrsennel vmbally on June D,1982 and again on June 25, 1942 in the Nrn of written ccrrespondence frun the McCo Qeoliry contiul S'rervisor to the Ouality Control personnel. During the week of June 21, s

19.'1 shen the PCCo Q:.ality Control Inspector involved in the calibration de a.oentatien proble:n beccme aware of the fsct that duplicated sir.n.<ture; were unacteptabla en calibration ts >>rts, he decided to go back and initial those calibration reports he had 1.: sued with his sigt.atura duplicated. This. initialing of signaturch which occurred for ab;ut two hcurs ended on June 24, 1982.

It was the auditor's opinion that the oMition of the initials was done to correct an onission as opposed to falsifying records.

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Page 10 In the area of records accountability this auditor determined that McCo.'s logging syster.is are idequate to verify accountability or records. Mcwever, there was no docunented svidence that MCCo hr.s periened reviews to determine if docuwnts are missin2 Also, current t

proced. ires do not specifically provide instructions for rep 10c1hg 1 cst records. This deficien=y is identified in Attachment A to this report.

6.

A.n ssment of Audit Questions 34-38 A review of the storage and maintenance of calibrated equirent and scols noted that ther e.re kept in an orderly ;r:arr.er and in locked cabinets. Cbservsrce of millwri:; hts tnd fitter, in the perfor:::ence of calibraticas indict.te;i they were know'ed;eable and cecpetent in their jcb:i. One procedural deviation was ncted with the calibration of torg:e wrenches and is identified in Attachm nt A of this report.

The follovi.ng procedu al deficiencies were identified regarding l

calibrations:

1

. Acceptance criteria and calibration points are not stated for each type of tool or instrument.

b.

Net 211 calibrated equipment is addressed ia procedure FC-31.

De specific deficiencies are identified i:i Attachment A of this raport.

J For the majority of the calibrations witnessed, the procedure and actual performance of the calibrations was determined to be acceptable.

l'pon interviewing personnel perfor=ing' calibration and reviewing calibration histories it was concluded that, in ins:ances where the 3

to/ he established test reading, the actval test data was extrecitly 'cics t

actual values may net have been recorddd in all cases; rather, dts generic test point values were recorded.

In other verda, a go, no-go check was perf orned. Yae interviews did, however, indicate that cat of tolerance calibration readir.gn were identified. The deficiency rehting to recording of actual data is identified in Attachment A to this report.

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Respon:;e

) torr'ison Comtruction Cee.pany is requested to respond in writing to the Findings and Observations lister! in Attach:xnt A to this report by g 23, 1932. The respense must include the following:

1.

Action taken to correct the deficiency 2.

Action taken to prevent rect:ITance 3.

Data for full ctrpliance Please adcress your response to:

Cm.mnseslth Edisen Ceapany G. F. Parcus Directer of Q.:ality Assurance (Eng./Constr.)

P.O. Ecx 767 Chicage, IL 60690 With cepies to:

Cer.:nowaalth Edison Company W. J. Shesski M.tnager of Q.tality Assurance P.O. 3cx767 Caicago, IL 60690 and Con:.onwealth Edison ccmpany X. J.15a. vin 3 QA Supervisor - Syron Station Byren, IL 61010 1

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ATTAGNET A t

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FINDING #1 Con:rn-y to 10CFR50 Appendix B Criteria XVII the Quality Control I

final revims and seceptance of calibration reports was not adequately ieptemnted to assure ecn:picte and act.cptable calibration records.

piscussion

!.n exa::1 nation of cc:spleted and accepted calibration reports idene.ified th: foll wing problepts:

n)

Wrench type was not indicated on torga wrench #10?04 calibration reports dated March 16, April 5 and Septe:nber 25, I rl.

b) 0.:ality Centrol review of torcue wrench #97366 calibrated on July 31.1931 vas net docu:r.ented.

c)

Error n:easurements ware not indicated on the report for torque vrench 197365 calibrated on January 2,1981. The enor values, however, vere attainable 1:om information on the report and '

f:r.md ac:2ptable.

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Tc<t data was not recorded for pressure gauge #FG-31 calibrt.ted en Jtme 8,1932.

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--3.I.NG d2 FIN Contrary to MCCo Qstlity Assurance Manu(15ection 10.10, nen:or.fo: e ce reports have not be=n generated for disposition of each calibrated to:1 er :.nstrunnt found sspect.

DiscusSICn A review of MCCo's Deleted Instnment !.os, Hold Tag Log and NCR's indi sted the in11cving torque wrenches as damaged or out of calibration

'ut records of 4'G's for each was not available:

a)

Tore;ne vrench #4292 - Mcid Tag #nc5 - Torque wrench was scrappe ins tead.

b)

Torqt* vrenches #15758 and #10468 - hold tag #1223 - Torque vrwJtes needed to be repaired.

(The Hold T.tg Lc2 showed iter.

m repaire.1 and the Hold Tag resoved.)

c)

Torq'.e wrsach fE40408 - hold Tag #1171 - Torque wrench was da=ged while being used.

(Hold Ta rzpsired and the H4 d Tag removed.)g Log showed item u s 2

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Other instances of hold tags being issued on calibrated torque wrenches or terque screwdriver without references to applicable Na's are as follows:

Hold Tag s #1137, 1132, 1133, 1134, 1103, 1129, 1092, 1103.

Further. tare, a review of procedure PC-31 Rev. 3 dated July, 1977 indicates that the recuiren?nt of Section 1010 is not addressed and thus could be a centributin'2 facter in the inconsistent implenentation cf Not's for suspect calibrated tcols and equipment.

.Fn:iT;G #3 Cor.trary to 10CFR50 Ap;:erdix B Criteria XII, MCCo las not established a.t! i :7.le-ented adeq'utc guide. lines for receipt inspe.crion review of calthration c morts as to acceptability cf calibrations perforud by cut:ide acenties.

Discuzion Five celibrationr. were accepted for the torque wrench tester where the tester wu out ni calibration.

GCo NG #399 has been issued for e.ngins_ ring disposition.

FINrL' G #.t Contrary to 10CFR50 Appetidix 3, Criteria XII and V, MQlo Procedure IC-31 has the following deficiencies:

a)

Nct all calibrated tools E egliprent used by !!CCo are covered by this proccelure.

b)

The procedure does not address acceptance criteria for all the calibtated '.cols and equipmnt and c) h pro;edure does net always address the calibration method and specifically the points of calibration where applicable.

Discussien a)

A raview of calibration eq2ipnent indicates that scoe tools and ec,uipmnt have not been included in procedure PC-31. These it =.'..s are:

1) Deadweight tester

2) Torque wrench tester

3) Densitateter

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1-Page 3 Attaclunent A

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M 1h-followim items, although listed in McCo procedure PC-31, dij not have specific calibration acceptance criteria listed (ie acceptance tolerances). The auditor us told that the manufacturers recen:nendations were used as the basis for ac:cptance.

4

1) causa b ceks

2) blti peint reccrdter

3) Mi ner.cters

4) Linear tesauring devices

5) Optical level s) inn :ter

7) Standard raicrecetar lengths t) Star.dard varniers In addition, the following list cf items were found to have acceptan:e criteria ciscrepancies or lac.k clarity.

0)

P'-31 states that dial indicator 3 only need free novecent

.cf the plunger, but calibration Certificat. ion form PC-61 ind2 cates tools should be within 0.001" of a sta:uitrd.

10) PC-31 indicates pressure y,auges are to be caliMated within

+ 4.

While witnming pressure gauge calibra:icn cen nstration, MC:o personnel were noted to be divided as e

to wh:th:r this means 5% of full scale or each incrc= ental calibration valte.

c) 10 tile pC-31C was noted to be very sp2cific about data recording for torque wrenches, the following inct.nsist?ncies were noted in oth:r a eas:

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1)

Micrometer (S/N QC-5) was tested on June!4,1932 at six settings, whereas en March 4,1932 it was tested at thirteen settings.

2)

Test settings for pressure gauges are listed on Calibration Certification form PC-61, but are not indicated in prxedure PC-31.

t l

l aw:n l

l Contrary to 10CFR50 Appendix n, Criteria XII and.WII, it was an accented MCCo practice not to record the. actual test data nn calibration reedds whan ene da ca was exttwely close to the standard value used.

I Dircussion T"..rcugh intrrvim with the personnel performing and witnessing the calibration activities ar.d a review of the historical records, it becare evident that MCCo did not always record the actual test data readings when they were within acceptable limits. The generic test point values were recceded. A go, no-go check. was performed. The intervie w did conclude, hWever, that out of toleran e calibration readings were being identified.

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H Page 4 Attachwnt A s

FIh* DING #6 Contrary to 10CFR50 Appendix B, Criteria XII and IV11. Morrison Construction Co. is not adequately controlling calibration documentation for r.ressuring and test equipnent.

Discussion A review of all c:libration records on file at Morrison v.ns conducted to deternine the extent of docxmentation deficiencies. The deficiencies incived (1) the frequent use of reproductions of calibration report f:ms already signed by the cognizant Ouslity Control Inspector and t'itnesses to record calibration data, (2) the inccmpleteness of data, ec.es and signatures en callaration reports and (3) the use er reproduction of calibration dats on consecutive reports.

FI' GIN'G 87 Contrary to 10Ci?. /,ppendix 3, Criteria IX and XVII and Merrison procekre K-41 Rev. 0, three (3) voltage /anperage (V//J readings retarded on Morrison Quality Control surveillances were found to be out of :rocedure tolerances and there was no evidence of corrective ac:.lon.

In te lition, thera were instances of innsplate and/or inco'Tect infecation on the su;.el11ance fom3 Such as lack of proper precedure revision and V/A rang:s listed on the form which were not consistent with the procedure ranges, j

pis:us s'.on a) "hc following reports had the V/A rea' dings out of procedure

?.ci:Iances.

P.co;rt Date Rendhg Prneedurekanee Oh.erved Procedure 4/24/21 A=ps60-250 55 amps P1-3LS Rev. 7 6/1,2/78 Amps

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60-250 50 anps Pi-11Ls nev. 7 12/2/77 A;.ps60-110 125 arps P1-20Ls Rev. 4 Tha. Audit team subsequently revinved the three shove cases with a Sar;ent 6 '. undy ifelding Engineer. Tais discussion included a review of

-he associated weld procedures, the materials being welded, and the weld ins;ections perforr.ed. Based on this review. it did not appear to this 541. T.ngin2er that a q;nlity concern exists.

l

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e' Tage 5 Attachment A b) In addition, inaccurate recording of surveillance infort:ation was identified. Cut et 543 surveillance reports reviewed,104 had incorrect er no protedure revision identified on the report form and 95 had V/A raar.es listed which were not consistent with the ranges provided in the applicable procedura.

OMT2V.*.TTW #1 Quality Control final review requirements on q,:ality records are not clearly defined in liCCo procedures or site instruct;cna.

Ei_scussion The following record types receive a final review by McCo Q.tality Control personnel but the meaning and regirenents of this review are not delinsated:

i a)

Calibration records b)

Insta11atien documentation / travelers e)

CF. reports d)

Te.sr reports Addition.tlly, tha final Ouality Control review of the k' eld T.ata F.ecord is performed, but decmentation to indicate acceptance, other than entering selected infoTr.mtion from it 0:1 the Status Lo,v., is not provided.

0?21E/ATION #2 MCCO hcs not performed reviews of records to det. ermine if d=u entut. ion is missing. Additionally, current procedures do not pr:. side ins tructions for replacing lost records.

Discussion WlCo's systems of 1=gging dor.unentation appear adequate os a neans of

. m.untin; for dccu entation but no evidence was available to indicate ths VCo had perfer:xd reviews for missing de:umentation. >ICCo also has r.= ?. :stablished steps to be taken ts rep}nce documants discovered missin;;.

,-. ~ 3 _=~ ~-

Page 6 ll Attachroent A ORS'-2tVATION #3 M111erights were observed calibrating torque wrenches with seme I

variation from precedura PC-31.

Discussf.on Wile obSeWing millwight and pipefitter demonstrations of the calibration cf varicas tools, it. was noted that "clic.kcr type" torgtc ter2nches were ::arr.: ally calibrated. A review of procedure PC-31 indicates that these stanches are ta he calibrateil using the mchanic.11 lead device which is huilt into the torque vrench tester rather than be pulled by han1..

The follovir.; cenments are relevant to this observation:

1) ne pipefitters and r..111 wrights performing the various c.C.ibration functions appear to be cccpetent.

2)

Alth:: ugh use of the rechanical lead device uculd seem tn ineke the recording cf calibration data more accurate, the results obtained by manus 11v calibrating the " clicker type" vren:h were not substantially different.

3)

The mchanic21 device on the torque wrench test.er can net.

acccc.edate it.r.p (~,00 ft-lbs) torque wrenches.

OF.53VATTON #4

}!CCo Tool /Instrt=snts Inventory listing is not current.

Discussion Cauge bloch (S/.N bel-9) are not listed on SKro Tco1/ Instruments Inver. tory 1.ist. Also, as a comment, the lisc should be updated as several hand written entrics were r.oted.

OES?.VATION #3

~~' A~UIaTRV Centrcl Inspector certification was not signed by the MCro certifyir.g ir.dividual.

f Discussion A review of certifications for all Quality Control Inspectors

!dentified the omission cE th Certification signature for J. R. Ragan, Level 11 1.Init.-d.

Other than' the missing signature, the infor: nation on l

tb: certification fccm and back up documentation appeared to be in order.

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ACTION Tarci 3T /RO.T CC:::r"RUCTION 13 A ET2 OF NC A G C.I.Co./Q.A. CC :E.JS EL.lTI7U TO

!*S.RISO2; CC:iUTEUCTIC2! CCFS!2Tf CAL 23P.'.T 2 ECO?.23 DA C:

JULT 3, 1982 d

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?HCJECT CCU3MC" ION E;G3riIR Pst :.4E'D 37:

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F?.0 JECT CC:STRUCTION M E 215. CAL m g.;.n u A7:PD-c, Tt:

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jd:AGEit 0? ?.%TECTS 4

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M ART Csis repeM n+3. a. rises the confir=atory newoures perfo=ed by e :-ject Constaction to verd.fy the udeque. y of the field ve:E done bf Ibrri: r:n Cenutructica Co= pant which required the use of cc.ithmted

't=cre vru.:hvu and hydro test reseme purfes.

Oit: review cub-str.tiatea cc conclusien th..t boltz v:rre proporly tightened 2nd passre r/stens were properly sewc. red. Exceptions that were fsr:! represent ser.11 pc=cnti gae of the sa=ple.

It is not evident t.w.it v.hese exceptions am t.neeable to calibration deficiencies.

All creeptier.a discoversd hate been conectad or are othereise a/..h ncaed 6 this report.

T..erefore, we believe that the pl nt countMetien is atlequ.ta ar.1 ratiefactory.

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20?.02 '.0_M_3 u : arc.CATICNS:

Of the appre:timately 6.000 MCCO tor.uo vrench certifications the fo11ovi=g Einer and mjor catorgerius were identified,

.1.

Sye:Lflo Ccnce:no Tcer.ed Min.cr 1.

Torqr.e wrench 9,;e cisidenfiad or not st:.taf..

2.

Math crvors on certifiestics but vrench within tolers.nce.

3 Errar enlet:lntiono not performad but vrench within tol e:.:.no e.

h.

Minuing 2C sig.3.t:rsa or repcrt date.

2.

Specific Cc::: cmc.N. cced Major 1.

Singia xcacrad repert. data. and all sigt:res.

2.

C.rono r.e:. vied ze; ort - dati and all signaht-es (1-6 veck perica,1-12 v, e'c period, %3 vaek PAriod).

'i. Mioning teck'r or vitness siccature, h.

Ince:platu or uncerta.in data at isolt.ted data. points, F.

Min.eing reports.

C.

Torque *n5 sch Ov.t-Cf Tolersnee Concerts Ca:4ificatiens identified with out-of-tolerance readi gs st isolated da's join *3 end had been sewpted by MCCC q.C.

I'. Gr.e:Le Cence==s l

1 W: erovo ottf on of censecutive reports with.if estieAl orig!.al test enta indiesting actul tert.53 vos

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no'. recorded but a go/no go tar.t vss t.tili:2d and noninf. val'ast recorded when the data po n: vas daaced l

within calihrution solersnce.

7, ihntersus case: of Q.C. acceptance st.s-p :orcr.e4 onto i

call'arstien data al.nat alr 2# al@ed. C=1y date of Q.0, ruviev and page number uc.s affixed to indicate Q.C. accep'. anus ervix.r.

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e ee The specific ccncerns deened ms.nor Tequired no remedial field ch:cks of the verk done with tho subject vranebes.

In all casan the concern 10 a paper problen. Other informatien existed on the ce:-tificaties to scrrect the concern, or a calculatien vr.s ensity pa-fe sed te cor cet the concern, or the 9..C. ravi2v was 29.-. forced cs the calDratien certification.

The speci.fic findings dannef. najor and the out of tolernce v anch-as required cocert.:Lin!ng the asfet-related work sc fc ened with the *.- anch in que tien and field. checking the toz.r:0 for tece;tabilit/, g hangera with alpror.4*Ltvly 312, CTA's and bolti.ng; cr. 2 valven ve-e reqatred to be recheckeri. Che re s t.*.ts of th e re -

chaus indiested 1h CZI. bcT tn on o hangers were fc=11cvsr than t% sycir:..d test torque. Thece Sa'.ts vill to ret:rqued or me p1 ved Te:. IT-C"*.1 requi rements. The fir-2t h cf these hanger ae-.

nc.;tlica vers rec 2'.cuakted. and fet=d that the y would function with-cut thw ou' ject CT.1,'s, S.e m.-m%ing acrrectiva 2= :ien vill be cc. pir:sd t7 Jul,y 12,1930, T.u ba.:is fer acaepting the installed work given the generio finlin.gn are the follavi=g:

A.

P.':"O g2rer.1 calibratica procedure ?C.-31 only requires a 6 canth fecque==y for torque vrenches utilirod en n.11 verk except CIAft. CIA verk required veic~y or*nanthly calih-a-ti:n2 of T.orque vrnnches, Calibratien curtifications with aci;ual data exist to ?.ect the 6 month fraquency intervals.

P.

It has been shown that torqss wrsuch secursey is not i=pertant fer CIA vark, The pri=aay reasca for specify1.nr a scrtue vaine in CEA werk is to assu.'e nr. 2.uditable nethod of ascertmi. ie.g that the C7JL is set in the cancrete.

Once the anchor has been shown to hn ant, ttrqt:e tightness of the CEA teconss irrelevant. Thiohnjngtie:sse,thego/

no no calibratien test v.ti'.,1:ed abould be cuffioisnt to ascertain that the tnrque vranch is aceu.nte enc tr.h to net the CIA. An independant check perfer=e4 by Cer.1:n Inspection Arenty with thnir evn cc.librated torque % enehes en -% cini-cm of one anche,r ;er herpr nntionblies but at least one cut cf os ch ten e:qansien techorn installed in that asse=bly shoved no excessive re.leetic.n of CZ"A': threughcut the work h.isto:/. T.e rejection hu been e.:trene2y lav; cis the order of 15 of the bolt.o tested.

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<I Evidrmes ezists that torque vrsuches were discarded orre C.

the vrsach o.*,b ef-calib:stion.

R Fride.ca exiat 3 ttst the to que wrench calibration certi-a ficatien dit Tscoive a 4C. review even thouch the 40.'"he date of r b.

ot. m and sig=sture were xenxad.

.ve n=ber vers origi=si v

.thcs.

Ia n=sh,, we h4ve concluded that the tor @a Franches v2 ethe installid work suffletrnt:7 accu =ts to canr3 ti =.11 :a ;uirs=entc.

n.. TCM'J? '?T_ C3 TES'IT3 CAf.WAT'l'ot!

1.:::.in.; the Imc rwriev a. eeneer= was stated that the tecter utilized to calit, rate the torgte V enchan we.s cubef-tclerr.nce on specific lier.cenforau:ce Espert Cf.=menven1th Edicen Oc*.:pel Prelininsr? reviews s:C e ren:.t. is.

toe==nto:! tha es11bettian discrepracica.

ec3 h:sve indiertr.1 the follevirg:

i Ts.ristico cu:h as the tester eenditten and operator ra.rizate prsbably cr.uzcd the crrencouc n adings in the rantsc identified.

A.

O n turque tester cr tor pe vrench calibre.tien tolc:r.=:cs Tclurunces are not the pr!-=7 corecT, in torque o;aratiens.can be re'.r.ne I'.

bolt cendition is atteytsble.

On the e.b:Ne Mais, no check *: cf the incialled work has bven initisted.

IT:20 :Fr43tha GnG: CAIMOICI r.,_.ER_ATIGTS:

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bmar.eCalibration Ap raxi=s:cly 1000 MCCO Zyriro Tect Preestre Certifirmitenn for 103 gaupn were reviewed by C.S.Co. LA, auditers, the Ir:cun eence:m are tho followings

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d valves have been torqued to within the

r. n trac,,: ras ' recc=endert values.

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STATUS OF LASALLE INVESTIGATION (As of 6/2/82)

Total Number of Allegers/ References - 19 s'

1. Of Affidavits / Statements to NRC -

7 4

1. That Refused to Make Statement -

8

1. Unable to Contact -

2-

1. That Are Still Thinking About Making Statement -

2 f

I

i Installation of Hanger Supports The inspector discussed the allegations with the LaSalle Lead Structural

(

Engineer for construction, the Staf f Assistant for the Project Manager's Of fice and the Morrison Quality Control Supervisor, who all denied that any color coding system was used to differentiate between hanger supports made of dif ferent materials.

Also, one of Region III's inspectors, who WAnge,s, is a recognized expert in pipe (supports and restraints and who is f amiliar with LaSalle stated he was not aware of this type of practice being used there. The inspector also tou ed the sient and yard areas where hanger cd No materials are storedgand could find no evidence of color coding by material type.

A review of Morrison's installation Procedure, PC-16, entitledj(

" Erection of Supports-Restraints and Final Installation Verification" by the inspector revealed no references to color coding.

The inspector also found during the investigation that all of Morrison's n

safety related hangers are manufactured and supplied by I.T.T. Grjpell As d and are all manufactured of the same type and quality of material,aA36 carbon steel, and are supplied with a letter of conformance.

In addition to the pre-manufactured hangers, material is also supplied by I.T.T.

Grinnell-for modifications and for any hangers that may be required to be made on site. This material is the same type as is used for the pre-manufactured hangers and is also supplied with a letter of conformance.

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I The only differentation in color between various hangers is that hangers, supports and restraints located inside the containment are required to be painted, by Sargent and Lundy Specification No. J-2974, with specific types of paint that are a different color than those for use outside the containment. Hangers, supports and restraints supplied by I.T.T. Gry.nnell that are predesignated for a specific area are painted appropriately n

at Gripell as is any raw stock that has a know area of usage.

Any hangers, supports and restraints that are required for use inside the containment t

that were not previously so designated are stripped to bafe metal and painted according to Specification J-2974.

In addition, it was noted by the inspector that outside the containment the majority of piping and tneir associated hangers, restraints and supports are painted brown.

1 The one exception to this was the piping, hangers, restraints and supports for the fire system, which are painted red.

Based upon the above, it would appear that perhaps what the alleger thought was color coding for material type was in fact the different color paint of the hangers, restraints and supports used inside containment. He may have seen someone takeh a hanger that had been iceant for use outside the containment but was ultimately used inside containment.

It would have had be to have the original paint stripped of f anda epaintedA ' aCCordance With r

Specification J-2974.

This is acceptable as long as the hanger was of the correct size and geometry-the material types would have been identical and would not have been taken into consideration. Since all of Morrison's safety related hangers, restraints and supports were supplied by I.T.T.

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I Grihell and are manuf actured of the same type and quality of material and i

based upon the above, no evidence could be found to substantiate the j

allegation. The inspector considers that no further investigation is required to close out this item.

Auxiliary Buildino J-Line Walt Water Leakage The inspector discussed the attegation with the CECO Lead Structural Engineer for construction and the Walsh QA Supervisor and reviewed several non-conformance reports (

GRNCR 185 dated 8/3/79 and NCR 188 dated 8/28/79) that discussed repairs to the J-Line wall to stop water leakage.

In addition, the inspector viewed the entire JPGaall and noted at that time that it appeared dry. However, it was also noted that previous leakage had occurred based upon stains left on the concrete.

The inspector also noted tskCEthat no safety related equipment was located in the immediate vicinity of the watt and that a series of floor drains run in a line G tGmil.

parattet to the a:lt and approximately 5-7 feet awayA. On a subsequent inspection of the wall, several days af ter the first inspection, the in-spector found contractor personnel repairing several areas of the J-line watt that had started leaking. The leakage was of a very slight nature (surface moisture). The inspector discussed this additional finding and the repair methods being used with Region III construction inspectors and considers that the methods being used are standard industry practice and are acceptable.

The inspector considers that, based upon the av<bove, though/ b(akage has occurred in the past and continues to occure periodically, the repairs being performed are att that casan be practically expected of the licensee.

In addition, the lack of any safety related equipment in the immediate' l

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I vicinity plus the presence of the floor drains makes any resonably ex-pected leakage inconsequential.

It was also noted that no leakage equirements exist for this wall. The inspector considers that no addi-tional investigation into this matter is required.

L__.._

FL le Liquids In Fire Extinguishers

(

The inspector discussed the allegation with the construction and operations fire marshalls for CECO. The construction fire marshall stated that he had nK no knowledge of flamWable fluids being placed in fire extinguishers. The operations fire marshall stated that he had heard rumors of this, but in the last five years, while associated with the fire protection program, he had never found or knew of anybody else who found this to be the case. He felt that LaSalle's annual maintenance procedure for the fire extinguishers, LMS-FPS, provided a method of detecting this type of sabo+ age since it I

requires them to be disassembled.

In addition, there has never been a case, to the best of his knowledge, during the use of an extinguisher, either during a real fire or during a drill, where it did not decrease the intensity of the fire versus causing it to flare up.

The inspector also reviewed the 1980, 1981 and 1982 records on file with Commonwealth Edison i

m for LMS-FP/ and found no reported instances of any flarapble or foreign s

&5 substances being found in any of the fire extingushell.

The inspector also

^

1 reviewed the security records for the year 1979 on file with the Construc-tion Administration Assistant.

'5 ':'<This review revealed no reported 2n:tr"-

instances of any acts of sabatoge of a related nature to the allegation.

Based upon the above, the inspector could find no evidence to support the allegation and consides that no further investigation is required to close out this item.

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!b ii & Reactor Building Settlement

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The inspector discussed the allegation with Bob Rose and Mike Dougherity and reviewed Chapter 2 of the FSAR, Paragraph 2.5.4.10.1.2 and Table 2.5-41, regarding the comparison of theoretical to actual settlement of the Unit 1 and 2 reactor buildings and noted that the last measurement recorded therein was taken in May, 1981. The conclusion was reached in the FSAR, and approved by NRR, that the actual settlement agreed reasonably well 4

with the theoretical final settlements.

The inspector also reviewed the settlement readings taken since the last one recorded in the FSAR (May, 1981) to the most current on file (May,1982) with Walsh Construction s

Company and noted that the readings had basically stabilized at approximately 2.4" total settlement for the Unit 1 and 2 reactor buildings.

It was LLst also noted that during the ppriod of May,1981 to May,1982,4the Unit 1 meuf1 appea* to and 2 reactor buildingsrhave actually risen between 0.12" to 0.24"mg' /kaxJ upos tLe

• e co-del da(a. Koweve j it.is mo*e lilect) tkt ((( acca c

..( N meou cas%ly g is ec1gnsibk (o LUT app **ee.l v he.

The inspector concluded that the allegation appears to have no substance and could not be substantiated. No further investigation is required.

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e r-Reactor Building Roof The reactor building encloses the reactor and the primary containment and provides secondary containment when the primary containment is in service and provides primary containment when the primary containment is open, as during refueling or maintenance.

The reactor building up to and including the operating floor (refueling floor), is of reinforced concrete.

The operating floor is the uppermost level in the reactor? building and consists of a structural steet super-structure enclosing the floor and supporting the sheet metal siding and decking. The decking is covered with insulation and composition roofing as a water proofing covering.

As reported by the resident inspector in inspection report 50-373/81-30, sometime during the weekend of July 18-19, 1981, while LaSatte was in the process of conducting the Secondary Containment Leak Rate Test, the reactor building was inadvertently overpressurized, causing damage to the reactor building composition roofing and insulation.

This damage was reported to the NRC by Commonwealth Edison pursuant to 10 CFR 50.55(e) in Report 81 05, dated 8/18/82 (the accident was verbally reported on 7/20/81). Several NRC inspectors, including the Senior Resident Inspector, inspected the structural area above the operat kk-floor for signs of l

damage and could find nothing of significance.

The only damage noted was l

to the composition roofing which, as explained above, is only a water proof 4eg covering. During LaSatte's inspection of the roofing and decking e

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it was noted that, af ter stripping the composition roofing of f, some of the deck fasteners had sustained some minor damage and were subsequently replaced. The damage noted was only to the relief washer on the fastener and not to the decking or the structural steel in which it is installed.

Occcadoy;< Secondary containment integrity testing was performed on April 14, 1982 and again on April 24, 1982 with both tests being I

acceptable and meeting all FSAR and technical specifications require-ments. Both of these tests were witnessed by an NRC inspector to ve.. i 0< verify compliance with all requirements;as reported in inspection i

reports 50-374/82-20and50-)'74/82-26, respectively.

The 1978 date given in the allegation appears to be in error.

In 1978 wevs the walls, deu.ing and roof of the reactor building +HMr under construc-tion and no testing was performed until 1981. This has been verified through review of photographs of the site that are taken on an approximent monthly basis and by discussions with NRC and construction personnel who were present during this time period. Based upon the above, the investigator considers that no damage was sustained by any safety related structure during the accident of July 18-19, 1981 and that no further investigation is required.

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c s, Proposed Resolution

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Af fidavit -

Reinforcement bars may have been broken throughout

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the plant. The construction crews routinely did not use metal detectors to locate the rebars.

They would just start dri LLing.

The quality control inspectors

,did not seem.to care.,0uality control was more like a joke at LaSalle than anything else.

Statement to NRC -

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Construction crews routinety did not use metal detectors to locate l

rebar and I believe rebar may have been broken throughout the plant.

Quality Control inspectors did not seem t.o care.

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Affidavit -

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tell construction that some" thing was done wrong and I

's that he would be back.

Soon the inspector would come back and say the defect was OK after all.

Quality Control should be run by an outside firm that does not 1

have a conflict of interest.

Statement to NRC -

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Statement to NRC I have a friend who does not wish to come forward at this time who told me that records for torque wrench calibrations were f alsified.

The paperwork will show that the calibrations were done when in f act they were not.

This person has been threatened that if he tells what r

he knows he'LL regret it.

I can give no more information about the torque wrench f alsifications.

I will contact this person to see if he f

will come forward or give further information.

Proposed Resolution i

Review records and calibration requirements 7_

4 Have CECO provide us with calibrated wrench and RIII will conduct independent checks

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Affidavit -

Anottier LaSalle worker told me.... In 1978 there was a reactor pressure test that literally blew the roof off.

I believe the plant shouldhavetohassthis test before operations t,cgin.

The accident also ripped out the bolts for some of the piping.

Instead'of doing the holes over, they just redrilled the old holes and made them bigger.

Statement to NRC Same as above.

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Statement to NRC -

I have also heard that in the basement of auxiliary building the J-line l

wall is leaking water.

I believe this has been happening for sometime.

Proposed Resolution Review specifications Tour area J

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36 XXVIII f

e fk Sabotage - 1979, Statement to NRC -

In 1979, acts of sabotage were taking place at the plant.

No one was ever caught, but someone was breaking

• gauges and putting. flammable liquids like gasoline in fire extinguis'hers.

Proposed Resolutior.

4 Review licensee program to assure fire extinguishers are r;ow property l

filled 90 8

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Unit 2 Reactor Building Settling it iI

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Statement to NRC -

1 I have heard rummors that the Northeast side of reactor 2 is settling.

I was told by Walsh Construction Engineers that it has settled 4 to 5 inches already.

a....

Proposed Resolution Review ticensee's monitoring of building settlement

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Affidavit -

Another aspect of design controls involves material trace-ability. Even if a pipe or hanger support fits in a certain l

location, you have to insure that the specific quality pipe or support called for in the design is actually in-stalled. Unfortunately, that was not always the case.

For instance, the metal in hanger supports is identified by a color code. When construction had the.right size supports but not enough of the right color, they just repainted the color on the hanger.

I uncovered this prictice en about 5% of my ir.spections.

Commonwealth Edison responded that the colors were wrong in tne first place.

I question whether the same metal was installed as called for in the design.

Statement to NRC -

....said he observed this condition in an area near the Unit 1 reactor.

e Proposed Resolution Review procedure for installation - what type into what areas.

Assuming hanger supports are color coded, verify by visual inspec-tion for evidence of repainting.

Summary As a result of allegations received by telephone and by a request to institute a Show Cause Order f rom,the State Attorney General's Office on March 24, 1982, and a further 10 CFR 2.206 request received f rom Friends of the Earth on April 28, 1982, an investigation was conducted into alleged inadequacies in construction of the LaSalle Nuclear f a ci li ty.

As a part of this investigation, numerous people, in addition to those who had filed letters and affidavits were inter-viewed and some of them expressed concerns which are covered in this inspection report.

In the specific statements received from various individuals that were reviewed, it was determined that there were 36 separate alleged problems which were brought f o rt h.

These problems were categorized by the NRC staff into matters requiring prompt resolution prior to operation of the facility, those matters which require followup but on a longer time frame, and those matters which do not require a followup and were referred to other agencies or to the licensee.

Twenty of these specific allegations were identified as requiring immediate followup action. An investigation was conducted at the site and the licensee's architect engineering office and discussions were held with numerous individuals. All twenty issues were brought to a resolution based on the information provided and it was concluded V

that these $tems did not show a significant safety hazard with regard to any safety related structure or the operation of any safety related equipment at the LaSal'Le Nuclear Station. The remaining allegations and problems wiLL be reviewed at a later date and will be documented in a separate inspection report.

The inspection teams consisted of a total of fourteen NRC personnel and included one Section Chief, on investigator, two civil engineers, two structural engineers, two operations specialists, one QA specialist, two construction engineers, and three security specialists.

A total of three tours were conducted with different allegers. These are dor.umented in this report.

Details 1.

Personnel Contacted Commonwealth Edison Company (CEC 00 L. O. DelGeorge, Director of Nuclear Licensing

• T. E. Quaka, Site QA Superintendent

• R. T. Rose, Lead Structural Engineer

• C. Schroder, Nuclear Licensing

• D. L. Shamblin, Staff Assistant Project Manager B. R. Shelton, Project Engineering Manager

• D. J. Skoza, QA Engineer

• B. B. Stephenson, Project Manager Sargent and Lundy (S&L)

?

Walsh Construction Company M. R. Dougherty, QA Manager 2.

Background Information In early 1982, the Regional office received some allegations regarding construction activities at the LaSalle Nuclear f acilities. Two of these allegations related to (1) the inadequate ceiling depth for the offgas building and (2) the improper coring and drilling of holes in the walls of safety related structures.

The Region III staff concLeded that the offgas building was not a safety related structure and therefore no action was to be taken by the NRC.

The staff did consider the adequacy of the coring and drilling activities and decided that this was an activity that merited further investigation.

An onsite inspection was initiated on

,1982,into the program requirements for the Licensee and its principal electrical contractor, the Foley Company.

On March 24, 1982, the Attorney General for the State of Illinois initiated a request to institute a Show Cause Proceeding under the provisions of 10 CFR 2.206. Attached to that request were two affidavits, on of which was f rom a driller and related to his activities in drilling holes at the site. The Director of NRR requested a i

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meeting with the licensee and its architect engineer on March 31, 1982 to discuss the licensee's and AE's programs for determining that drilling activities did not weaken facility structures.

It was determined that the Office of Inspection and Enforcement l

l would look into concerns expressed regarding Region III's handling of the allegations regarding the thickness of the roof in the offgas building, that NRR individuals would make a technical assessment of the report provided by the licensee and Sargent and Lundy, and that Region III would conduct an investigation into the adequacy of the program at the site.

\\

As a result nf Regien III's initial took at the program of Ccmmenwealth Edison and its architect engineer and of the ensite evaluatien of calculations performed by Sargent and Lundy, a report addressing these issues was issued by Region III (Inspection Report No. 50-373/82-21 on April 27, 1982).

On April 28, 1982, the Friends of the Earth organization issued an additional request to institute a proceeding to show cause and provided four additional affidavits which contain allega-tions of improper construction practices at the LaSalle Nuclear facility.

A special inspection was initiated to consider the allegations made in the affidavits which have been provided to Region III and this was expanded when during discussions with individuals b

p a

who provided the affidavits additional names were provided who.could provide supporting information. As a result of this activity, numerous allegations were received. These were categorized and identified as being 36 separate issues. A summary of these issues is set forth in Attachment B to this report.

Since the allegations and concerns ranged from being directly safety related to being not safety related, and from specifics to generalities, a determination was made regarding the category of importance and determination as to which items should be promptly purrad. The breakdown involved was as follows:

Category 1 matters needing prompt resolution prior to power operation, Category 2 matters requiring followup but on a Longer time frame, and Category 3 matters requiring no further i

action and matters which were referred to other jurisdictions or to the Licensee. The categories of each of these items are also set forth in Attachment B to this report.

1 Matters which were identified as Category 1 items are set forth below and their resolution is docurented in the remainder of this report. The reporting of items ~ identified in Category 2 wiLL be contained in subsequent reports. issued by the Region III I

office.

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4 DIRECTOR'S 2.206 FINDINGS BASIS FOR FINDINGS - REGION III REPORT I

e I

ALLEGATIONS CATEGORIZED INTO 3 CATEGORIES:

e CATEGORY 1 - MATTERS REQUIRING SATISFACTORY RE TION TO PROCEED WITH LA SALLE UNIT 1 i

LICENSING PROCESS CATEGORY 2 - !%TTERS JUDGED TO REQUIRE FOLLOWUP SINCE MOST PERTAIN TO LA SALLE UNIT 2 CATEGORY 3 - MATTERS REQUIRING NO FURTHER ACTION L4 SALLE UNIT 1 PETITIONS DENIED AND LICENSEE e

AUTHORIZED TO PROCEED TO 5% PCWER ON JUNE 19, 1982 LA SALLE UNIT 2 - DECISION DEFERRED PENDING FURTHER e

INVESTIGATIONS

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