ML20076D046

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Rept of 810929-30 Audit to Verify Sargent & Lundy Conformance to NUREG-0588 Re Environ Qualification of Class IE Electrical Equipment
ML20076D046
Person / Time
Site: Byron, Braidwood, LaSalle, 05000000
Issue date: 10/06/1981
From: Marcus G
COMMONWEALTH EDISON CO.
To:
Shared Package
ML20076C924 List:
References
RTR-NUREG-0588, RTR-NUREG-588 NUDOCS 8305200655
Download: ML20076D046 (6)
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Text

( Q.P. FORM 18-1.2

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y Commonwealth Edison Ccmpany DE.Wei

(~ QUALITY ASSURANCE MANUAL -

AUDIT REPORT GENERAL OFFICE Type Audit: / / Program Audit M Product Inspection Point

/ / Records M /Special l

To: J. R. McFarland Project Byron /Braidwood Visit Date 9/29-30/81 Report Date 10/2/81 ,

Environmental

( System Qualification Component Identification N/A

! Material Description Electrical Eouiument Vendor Sargent & Lundy Location Chicaro. IL Subcontractor N/A Location N/A Contacts J.D. Regan, B.G. Treece, L.P. Dolder t P.O. No. N/A Spec. No.F/L 2773, 2804.01 Recommended Inspections: 6 mos 3.mos 1 mo Other: As recuired Notes:Please respond as indicated herein by October 28, 1981.

Auditor Date /0/g!#/ , ,

Rev ed -

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ng cc: Manager orGA /4-6-8 / I

-b o Manager of Projects 50' Project Manager

@@ Eng. Manager mg Director QA (Engr.-Const.)

h6 Site QA (Byron /Braidwood) 00 Auditee 0"c Sta. Nuclear Engr. Mgr.

$m Exec. Vice President gh Asst. Vice President V.P. (Nuclear Operations)

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( COMMONWEALTH EDISON AUDIT OF SARGENT & LUNDY September 29-30, 1981  :

The Commonwealth Edison General Office Quality Assurance Depart-ment conducted an audit of the Sargent & Lundy Byron /Braidwood Project Engineering Group on September 29th and 30th, 1981. The audit was conducted at the Chicago offices located at the Mid Continental Building. The scope of the audit was a review of Sargent & Lundy's evaluation / acceptance of environmental qualifi-cation documentation of Class 1E Electrical Equipment for Byron /Braidwood.

The purpose of this audit was to verify the conformance of the Sargent & Lundy review to that of the governing document:

NUREG 0588 for Comment - Interim staff position on Environ-mental Qualification of Safety Related Electrical Equipment.

The NUREG provides NRC positions and guidance to be followed for the environmental qualifications of items to the IEEE Standard 321, " Qualifying Class 1E Equipment for Nuclear Power Generating

\ Stations." The applicable IEEE Standard 323 printing date of 1974 was used since Byron /Braidwood construction permits SER were issued subsequent to July 1, 1974.

The pre-approved audit checklist consisted of ten (10) questions from NUREG-0588 and one (1) dealing with the status of NSSS supplied equipment qualification review. The first ten (10) questions were generic and were asked of a sample of balance of plant Class 1E equipment. Equipment selected had different qualification zones both inside and outside the containment.

Of the four (4) specific pieces of BOP equipment chosen to be ackages available for audited, review. Sargent & Lundy The audit showedhad that two (2) Up~/1 containment electrical only penetrations and RCFC fan / motors had been reviewed to date.

The review of NSSS equipment qualification was found not to be done under the scope of Sargent & Lundy's contract. This work was let by CECO. to NEQ who will perform an umbrella review of all Class 1E equipment for Byron /Braidwood.

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a CECO. Audit of Sergent & Lundy Septcmber 29-30, 1981 Both RCFC fan IVP01CC and neutron monitoring electrical penetra-tion qualification packages were examined by the audit team. The RCFC review work was in process and not complete whereas the Bunker Ramo penetration package had been reviewed and accepted by Sargent & Lundy. Of.the twenty (20) audit questions asked, two (2) problem _a prdiscovered. --.---

The first deficiency dealt with the complete and accepted electrical penetration 2NR04E. Contrary to NUREG 0588 Section 5(1), no description of the test setup and instrumentation used was available.

The RCFC package w~s a clearly in process of being reviewed and accepted. Careful inspection of available correspondence and checklists showed that four (4) attributes were not in the qualification package. This deficiency is in the fact that the open NUREG requirements were not being tracked and corrected.

These two (2) findings in the area of 1) lack of testing setup /

instrumentation description for electrical penetration and 2) lack of tracking missing performance characteristics, power supply variance, testing margins and testing failures are detailed in Appendix "A" of this report.

Overall quality of the review performed ~by Sargent & Lundy on I

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these qualification packages is acceptable. The areas which were reviewed in the audit and found acceptable were: methods supported by test sequence of testing, radiation environment, aging acceleration rate, caustic spray and developed test plan.

A project instruction with checklist is to be used in the near future which incorporates virtually all of the NUREG 0588 attributes.

The performance of the audit was as indicated in Appendix "B" (entrance briefing, exit debriefing). The audit team appreciated the cooperation shown by all Sargent & Lundy personnel involved.

l Sargent & Lundy is requested to report in writing to this audit by October 28, 1981. The response should indicate the corrective action taken, the action needed to prevent recurrence and the date of implementation. The response is to be directed to:

Mr. G. F. Marcus l Director of Quality Assurance Engineering and Construction l with copies to:

Mr. R. B. Klingler Mr. T. R. Sommerfield

( QA Supervisor QA Superintendent Byron Braidwood 1

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APPENDIX "A" FINDING #1

Contrary to NUREG 0588 Section 5(1),.the design qualification report for electrical penetration 2NRO4E, did not contain a description of the test facilities (test setup) and tastrumenta-

- tion used (including calibration records reference).

Discussion:

A review of Bunker Ramo report #123-2220, Rev. 4, revealed that there was no description of the test setup nor was there any mention of the specific instrumentation being utilized.

FINDING #2:

,- Contrary to NUREG 0588 Sections 2.2(7), 2.2(10), 3(1) and 5(1),

the Sargent & Lundy review of Joy Manufacturing environmental qualification report is not adequately tracking unresolved items.

Discussion:

Review of Joy environmental qualification report X-604 (3/20/80)

( by the auditor showed various deficiencies for the darrier RCFC unit IVP01CC. Correspondence between Sargent & Lundy and Carrier Air Conditionery Co. dated June 23, 1980, April 23, 1981 and August 12, 1981 showed Sargent & Lundy was tracking many concerns regarding Joy Manufacturing qualification test #X-604 -

(revision dated April 20, 1980). The audit revealed the

's following initial items are either not being tracked as open s or were auestioned and closed.

1. Performance characteristics of LOCA - amperage and insulation resistance were not identified.
2. Power supply frequency variance (1 5%) was not applied during the test cycle.

3 Margins for ambient - temperature, pressure and time were not generated prior to testing. Sargent & Lundy questioned this item but closed the issue incorrectly in letter by F.A. Kosik dated 4/23/81. The vendor's response stated that no margins were used and reported parameter values were exact values. This does not address what are acceptable

, testing margins per IEEE 323 - 1974, and NUREG 0588.

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,j Appandix "A" g If the IEEE 323 - 1974 margin of +15 F for test temperature 0

isenvokedthemeasuredtesttemperatureofg30Fis10F belog the marginal temperature of 340 F (325 F required

+ 15 F margin) hence invalidating the test results.

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During occurredLOCA in the testing,(twenty-eight one (28) equipment outages of continuous testing 1) atyear Jo and fifty-seven (57)(days Manufacturing. Two 2) failures which occurred (3/ 9/76 for two (2) hours, 4/22/76 for five and one-half (5 1/ ) hours) had no explanation of cause or what procedure was envolved to restart the i unit under test was documented in report X-604 or available l correspondence.

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APPENDIX "B" l PRE AUDIT CONFERENCE DATE: Tuesday September 29. 1981 TIME: 8:30 a.m. Room 24D35 NAME TITLE COMPANY T.R. Sommerfield QA Superintendent CECO.

G.F. Marcus Director of QA CECO.

J.J. Dennehy Project Engineer CECO.

J.E. McFarland Head QA Division S&L L.P. Dolder QA Coordinator S&L R.B. Klingler QA Supervisor CECO.

J.D. Regan Electrical Eng. S&L J.E. Szupillo S&L B.G. Treece SEPE S&L POST AUDIT CONFERENCE DATE: Wednesday September 30, 1981 TIME: 2:10 p.m. Room 26018 t

NAME TITLE '

COMPANY

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J.J. Dennehy State Asst. CECO. ,

B.G. Treece SEPE S&L J.E. McFarland Head QA Division S&L D.L. Leone Project Director S&L L.E. Ackmann Director of Services S&L D.C. McClintock Mgr., Elec. Dept. S&L E.V. Abraham Asst. Mgr. Mech. Dept. S&L J.D. Regan Electrical Engineer S&L J.M. McLaughlin Mgr. Str. Dept. S&L L.P. Dolder QA Coordinator S&L R.B. Klingler QA Supervisor CECO.

T.R. Sommerfield QA Superintendent CECO.

Audit Conducted by:

R.B. Klingler Team Leader T.R. Sommerfield Auditor

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