ML20079F856

Transparencies Presented at NRC 831220 Enforcement Conference Re Const & QA Activities at Facility

ML20079F856
Person / Time
Site:	Braidwood
Issue date:	12/20/1983
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20079F848	List: ML20079F846 ML20079F856
References
NUDOCS 8401190325
Download: ML20079F856 (82)

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NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT ,

DECEMBER 20, 1983 EXTENSIVE EVALUATIONS A. TECHNICAL SUPPORT GROUP SCOPE EVALUATE OVERALL EFFECTIVENESS OF QUALITY CONTROL PROGRAMS AND OF WORK ACTIVITIES FOR EACH CONTRACTOR (EIGHT TOTAL).

IEAti R. TUETKEN -

ASST. CONSTRUCTION SUPERINTENDENT, BYRON R. BYERS - CONSTRUCTION STRUCTURAL ENGINEER, BYRON J. GIESEKER - ASST. TECH STAFF SUPERVISOR, LASALLE R. BRAUN - QUALITY ASSURANCE SUPERVISOR, LASALLE L. TAPELLA - CONSTRUCTION ELECTRICAL ENGINEER, BRAIDWOOD G. GROTH - CONSTRUCTION MECHANICAL ENGINEER, BRAIDWOOD DURATION SEPTEMBER 14, 1983 THROUGH SEPTEMBER 24, 1982: NINE (9)

WORKING DAYS ho0*kNko!

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B. DANIEL CONSTRUCTION COMPANY EVALUATION SCOPE A. EVALUATE THE GENERATION AND PROCESSING OF PIPING, INSTRUMENTATION AND HANGER / SUPPORT TRAVELER DOCUMENTATION:

B. REVIEW RETRIEVABILITY OF TRAVELER DOCUMENTATION:

C. EVALUATE QUALITY CONTROLS ABILITY TO SUPPORT THE CONSTRUCTION EFFORT:

D. EVALUATE THE GENERATION AND PROCESSING 0F HANGER RETROFIT DOCUMENTATION:

E. REVIEW TRAVELER DOCUMENTATION TO DETERMINE IF IT PROVIDES THE INFORMATION REQUIRED TO COMPLETE N-5 DATA REPORTS.

IEAM TWO (2) SENIOR ENGINEERS -

COMBINED NUCLEAR CON TRUCTION EXPERIENCE OF TWENTY-0NE (21) YEARS .

DURATION INITIAL: MARCH 7, 1983 THROUGH MARCH 28, 1983: 26 MAN DAYS FOLLOW-UP: MAY 5, 1983 THROUGH JUNE 17, 1983: 25 MAN DAYS

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DANIELS REVIEW TEAM RESULTS/ RECOMMENDATIONS SMALL BORE PIPING SYSTEMS DOCUMENTATION INCOMPLETE ESTABLISH A QUALITY CONTROL DOCUMENTATION REVIEW GROUP TO PERFORM TECHNICAL AND COMPLETENESS REVIEWS IMPROVE DOCUMENTATION LEGIBILITY CLARIFY QUALITY ASSUANCE PROCEDURES WELDING SUPERVISOR REVIEW ALL WELD CONTROL RECORDS DEVELOP A SYSTEM FOR PREPARATION OF N-5 DATA REPORTS

SUMMARY

ACTIONS HAVE BEEN TAKEN OR ARE IN PROCESS ON ALL THE AB0VE RECOMMENDATIONS.

DANIEL FOLLOW-UP TO CONTINUE IN JANUARY, 1984.

INDICATES ACTION TAKEN WHICH RESULTED FROM TECHNICAL SUPPORT GROUP OR DANIEL CONSTRUCTION REVIEW RECOMMENDATIONS.

(0192D) 1

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RESULTS/ RECOMMENDATIONS PHILLIPS GETSCHOW:

A. IMPROVE / INCREASE ENGINEERING AND MANAGEMENT STAFF B. QUALITY CONTROL T00 INVOLVED IN LINE WORK C. DOCUMENT ACCOUNTABILITY NEEDS IMPROVEMENT D. RE-F0CUS PROBLEM RESOLUTION E. INCREASE TRAINING FOR PRODUCTION FIELD SUPERVISION F. QUALITY CONTROL SUPERVISOR T00 INVOLVED IN DETAILS L. K. COMSTOCK A. REDUCE THE NUMBER OF BACKLOGGED HANGER INSPECTIONS B. INCREASE THE CONFIGURATION INSPECTION REQUIREMENT FROM 35% TO 100%

C. INCREASE THE NUMBER OF INSPECTORS D. STREAMLINE DOCUMENTATION AND TRACKING DEVICES 6

RESULTS AND RECOMMENDATIONS -

(CONT'D)

PULLMAN A. INCREASE 10% CONFIGURATION INSPECTION REQUIREMENT TO 100%

B. PERFORM RETR 0-FIT INSPECTION C. INCREASE THE NUMBER OF INSPECTORS

SUMMARY

ACTIONS HAVE BEEN TAKEN OR ARE IN PROCESS ON ALL THE AB0VE RECOMMENDATIONS.

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t QUAL _ TTY ASSURANCL REVTFWS AblI). CORRECTIVE ACTIONS I. GENERAL OFFICE AUDIT o i

II. UNIT CONCEPT INSPECTION III. INCREASE AUDITS & SURVEILLANCES IV. INPO SELF INITIATED EVALUATION V. CONTRACTOR - QUALITY ASSURANCE l

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P I. GFNFRAI OFFICF AUDIT PURPOSE - TO DETERMINE ADEQUACY OF Q.C. INSPECTION PROGRAMS SCOPE - MULTIPLE AREAS SIX AUDITORS - 300 MANHOURS

. RESULTS I'

- HVAC HANGERS

- ELECTRICAL PENETRATIONS t - CONDUIT SEPARATION t

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l II. UNIT CONCFPT INSPFCTION PROGRAM i

3M PARTY OVERINSPECTION 4

PURPOSE 61 UNITS PERFORMED 5 MULTI - DISCIPLINE LEVEL II INSPECTORS RESULTS

- 185,825 So. FT. INSPECTED

- 28,906 ITEMS INSPECTED

- 2,782 ITEMS FOUND DEFICIENT l

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-III. INCRFASE AUDITS & SURVEft_IANCES QUANTITY PERFORMED AUDITS SURVEIIIANCES JANUARY '81 - JUNE '82 49 E 700 JULY 82 - PRESENT 89 ~ E 900 INCREASE 82% 25%

ANSI N45.2 STANDARDS OCTOBER, 1983 - COMPREHENSIVE AUDIT

- 35 TEAM MEMBERS

- OVER 2,800 MANHOURS i

ADDITIONAL AUDIT TRAINING g .

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IV. INPO SELF _INITTATFD EVALUATION J

4 COVERED BYRON AND BRAIDWOOD PROJECT 20 MAN TEAM 3,800 MANHOUR EFFORT AREAS EVALUATED

- ORGANIZATION & ADMINISTRATION

- DESIGN CONTROL

- CONSTRUCTION CONTROL

- PROJECT SUPPORT

- TRAINING

- QUALITY PROGRAMS

- TEST CONTROLS RESULTS 23 - NO WEAKNESS IDENTIFIED 10 - WEAKNESS IDENTIFIED 3 - GOOD PRACTICE IDENTIFIED 4

NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20, 1983 PROJECT CHANCES AND CORRECTIVE MEASURES A. PROJECT -

GENERAL QUALITY WORK AND QUALITY DOCUMENTATION A TOP PRIORITY

- GERRY GROTH, LEAD MECHANICAL ENGINEER, CONSTRUCTION

- LARRY TAPELLA, PROJECT QUALITY CONTROL COORDINATOR SIX (6) CONSTRUCIION FIELD ENGINEERS ADDED ON-SITE PROJECT ENGINEERING GROUP ESTABLISHED

- DAN SHAMBLIN, MANAGER -

LASALLE EXPERIENCE WARREN VAHLE GROUP LEADERS KEN STEELE EARL WENDORF LASALLE EXPERIENCE THREE (3) ADDITIONAL ENGI'NEERS LASALLE EXPERIENCE 0

t PROJECT GENERAL (CONT'D)

A.

- .SARGENT AND LUNDY SITE ENGINEERING

-- INCREASED FROM 20 - (8/82) TO 329 - (12/83) 4

- TIMELY RESOLUTION OF CONSTRUCTION INSTA l

- ENGINEERING EFFORT CLOSER TO FIELD 4

- 80 HAVE BYRON OR LASALLE EXPERIENCE

' - STARTUP SUPERINTENDENT ESTABLISHED

- CHUCK T0MASHEK BYRON EXPERIENCE

- INCORPORATE OVERALL LASALLE AND BYRON EX (METHODS AND PERSONNEL)

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EROJECT CHANGES AND CORRECTIVE MEASURES B

B. SITE CONTRACTORS -

OVERALL EDIS0N MANAGEMENT MET WITH CONTRACTOR PROJECT AND QUALITY CONTROL / QUALITY ASSURANCE PERSONNEL ENC 0URAGED CONTRACTORS TO BRING IN BEST AVAILABLE MANAGEMENT

! TALENT INCREASED INSPECTORS ALL INSPECTORS CERTIFIED TO ANSI N45.2.6 QUALITY CONTROL INSPECTOR CERTIFICATION .- RE-INSPECTION (SAME AS BYRON)

ALL CONTRACTORS UPGRADED WORK PROCEDURES INCRASED EMPHASIS ON TRAINING FOR ALL PERSONNEL COMPUTERIZATION OF INFORMATION RESULTED FROM TSG/ DANIEL REVIEW (0194D) e

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PROJECT CHANGES AND CORRECTIVE MEASURES C. PHILLTPS GETSCHOW COMPANY -

MECHANICAL EDIS0N PERSONNEL WORKED WITHIN PHILLIPS, GETSCH0W COMPANY, THEN TRANSFERRED BACK TO CONSTRUCTION PROJECT MANAGEMENT INITIALLY ADDED (08/01/83):

SITE MANAGER ASSISTANT TO SITE MANAGER LASALLE SITE SUPE.1INTENDENT TEAM STAFF ASSISTANT TO Q.C./ ENGINEERING PROJECT ENGINEER LATER ADDED:

2 AREA SUPERINTENDENTS -

NUCLEAR EXPERIENCE ASST. AREA SUPERINTENDENT LASALLE AREA GENERAL FOREMAN EXPERIENCE

_ NIGHT SUPERINTENDENT RESULTED FROM TSG/ DANIEL REVIEW i . .-

C. PHILLIPS GETSCHOW COMPANY -

. MECHANICAL (CONT'R1 ENGINEERING ADDED:

PROJECT ENGINEER s 45 YEARS ASSISTANT PROJECT ENGINEER s,'((;> NUCLEAR 4 GROUP SUPERVISORS -

EXPERIENCE 7 OTHER EXPERIENCED PERSONNEL DEVELOPED SYSTEM TURNOVER AND TESTING GROUP ---

COORDINATES WITH QUALITY CONTROL ON SYSTEMS COMPLETION ESTABLISHED DOCUMENT STATION CONCEPT:

- STANDARDIZED, STRINGENT CONTROL 0F PROCESS DOCUMENTS 6 FIELD ENGINEERS IN 4 DOCUMENT STATIONS l

LASALLE CONCEPT 8 0F 19 DOCUMENT TECHNICIANS ARE LASALLE EXPERIENCED RESUTLED FROM TSG/DANIE REVIEW

C. PHILLIPS, GETSCHOW COMPANY -

MECHANICAL (CONT'D) 0FFICE IMPROVEMENTS VAULT INCREASED 600 SQUARE FEET TO 1500 SQUARE FEET QUALITY CONTROL AREA INCREASED 1500 SOUARE FEET TO 3000 SQUARE FEET TRAINING FACILITY ADDED -

800 SQUARE FEET

C. PHILLIPS. GETSCH0W COMPANY -

MECHANICAL (CONT'D)

QUALITY CONTROL SPLIT INTO 0FFICE AND FIELD ASSIGNED NEW QUALITY CONTROL SUPERVISOR ASSIGNED GENERAL FOREMAN OF FIELD INSPECTORS ESTABLISH 8 LEAD TECHNICIANS IN DOCUMENT REVIEW (3 HAVE LASALLE EXPERIENCE)

REVISED QUALITY CONTROL TECHNICIAN CERTIFICATION QUALITY CONTROL TECHNICIANS INCREASED 18 TO 56 ---

BACKLOG REVIEW, INITIAL AND FINAL REVIEW, N-5 REVIEW FIELD INSPECTORS INCREASED 25 TO 50 QUALITY CONTROL OVERALL INCREASED 57 TO 125 INCREASED QUALITY CONTROL MONITORING COMPUTER ADDED ---

MATERIAL TRACEABILITY, INSPECTOR QUALIFICATIONS, WELD PROCEDURE QUALIFICATION EMPHASIS ON TRAINING AND CERTIFICATION RESULTED FROM TSG/ DANIEL REVIEW

g PHILLIPS, GETSCHOW COMPANY MECHANICAL (CONT'D)

.C.

VERIFICATION EFFORTS

1. QUALITY CONTROL INSPECTOR CERTIFICATION RE-INSPECTION

2. DOCUMENTATION REVIEW 0F 10,000 LARGE BORE WELD DATA SHEETS

3. HEAT NUMBER TRACEABILITY OF SMALL BORE PIPE BEFORE JULY 1, 1983 AND LARGE BORE PIPE BEFORE NOVEMBER, 1982

4. RE-INSPECT INSTRUMENTATION PIPING (D0ING 100%; COMPLETE .

0%)

5. HANGER RE-INSPECTION (D0ING 100%; COMPLETE 98%)

6. EQUIPMENT REINSPECTION (D0ING 100%; COMPLETE 100%)

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RESULTED FROM TSG/ DANIEL REVIEW (0195D)

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PROJECT CHANGES AND CORRECTIVE MEASURES D. L. K. COMSTOCK COMPANY -

ELECTRICAL QUALITY CONTROL MANPOWER FIELD INSPECTORS INCREASE 97/82 11/83 LEVEL II 11 47 LEVEL I 11 4 l TOTAL 22 51 l

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OVERALL INCREASE 25 TO 64.

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l RESULTED FROM TSG/ DANIEL REVIEW i

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D. L. K. COMSTOCK -

ELECTRICAL (CONT'D)

OUALITY CONTROL MANAGEMENT CHANGES AND OPERATIONAL IMPROVEMENTS QUALITY CONTROL MANAGER REPLACED 11/82 QUALITY CONTROL MANAGER REPLACED 08/83 WEEKLY QUALITY CONTROL AND CONSTRUCTION MEETINGS ESTABLISHED 09/82 SUPERVISOR OF INSPECTORS ESTABLISHED .

LEAD INSPECTORS ESTABLISHED INSPECTION STATUS / CONTROL SYSTEM IMPLEMENTED MARKING OF MYLARS FOR INSPECTION STATUS j -

INSTALLATION AND INSPECTION STATUS IS BEING COMPUTERIZED TRAINING C0ORDINATOR ESTABLISHED I

i INSPECTIONS INCREASE CONFIGURATION INSPECTION 35% TO 100%

l RESULTED FROM TSG/ DANIEL REVIEW l

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D. L. K. COMSTOCK -

ELECTRICAL (CONT'D)

DOCUMENT CONTROL IMPROVEMENTS IMPROVED DOCUMENT TRACKING SYSTEM DOCUMENT CONTROL SUPERVISOR REPLACED 02/83 PERSONNEL INCREASE 7 TO 14 0FFICE IMPROVEMENTS INCREASE 3700 SQUARE FEET TO 7000 SQUARE FEET NEW QUALITY ASSURANCE VAULT DOCUMENTATION REVIEW IMPROVE DOCUMENT QUALITY AND RETRIEVABILITY NEW VAULT CONSTRUCTED RECORDS REVIEW IN PROGRESS -

COMPLETE 02/15/84 DAILY, CURRENT REVIEW 0F NEW RECORDS RESULTED FROM TSG/ DANIEL REVIEW ,

(0202D)

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1 PROJECT CHANGES AND CORRECTIVE MEASURES G. K. NEWBERG

- STRUCTURAL E.

INCREASED 3 TO 6

- QUALITY CONTROL MANPOWER:

- REVISED OVER 20 PROCEDURES

- TOTAL REVISION TO QUALITY ASSURANCE MANUAL

- COMPUTERIZED SEVERAL PRODUCTION AND Q DEVICES

- INCREASED TRAINING

- QUALITY CONTROL STRUCTURAL STEEL REVIEW i

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-- RESULTED FROM TSG/ DANIEL REVIEW l

(0203D)

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', PROJECT CHANGES AND CORRECTIVE MEASURES F. PUI_LMAN -

HVAC MANPOWER:

06/82 12/83 PRODUCTIVE CRAFTS 40 42 NON-PRODUCTIVE CRAFTS 18 80 TOTAL 58 122 0.C./0.A. 3 19 NEW DEPARTMENTS:

ENGINEERING / DOCUMENT CONTROL -

9 SURVEY AND RESEARCH -

5 FCR/ FEM -

5 CORRECTION NOTICES -

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COMPUTERIZED TRACKING 0F INSPECTION STATUS WELDER QUALIFICATIONS, ETC.

INCREASED CONFIGURATION INSPECTION 10% TO 100%

i 100% RETRO-FIT INSPECTION COMPLETE FOR WELDING AND CONFIGURATION 100% RETRO-FIT INSPECTION OF DUCT BROCHURE ITEMS IN PROGRESS RESULTED FROM TSG/ DANIEL REVIEW (0204D)

n NRC ENFORCEMENT CONFERERCE BRAIDWOOD STATION DECEMBER 20, 1983 PULLMAN SHEET METAL WELDER QUALIFICATIONS

1. ALL WELDERS QUALIFIED.

2. WELDERS RECEIVE DOCUMENTED TRAINING BY PULLMAN SHEET METAL QUALITY ASSURANCE /0UALITY CONTROL ON EACH PROCEDURE FOR WHICH THEY ARE QUALIFIED.

TRAINING C0 VERS MATERIAL SPECIFICATION, WELDING PROCESS, FILLER METAL CLASSIFICATION, AND JOINT DETAIL.

3. EACH WELDER IS ASSIGNED A UNIQUE I.D. NUMBER.

4. WELDERS ARE REQUIRED TO STAMP EACH WELD WITH I.D.

5. QUALITY CONTROL VERIFIES PRESENCE OF WELDER I.D. DURING VISUAL INSPECTION OF WELDS.

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NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20, 1983 WELDING PRO'CEDURES

1. ALL WELDING' PROCEDURES APPROVED (REVIEWED AGAINST DESIGN SPECIFICATION AND CODE).

2. FROM MARCH, 1978 TO SEPTEMBER, 1979 ONLY TWO (2) WELDING PROCEDURES:

v A. 7018 SMAW FOR HANGERS B. SILICON-BRONZE HANGER TO DUCT i

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3. APRIL, 1980 TO DATE NUMBER OF PROCEDURES IS NINE (9). BREAKS INTO FOUR (4) GROUPS:

A. GROUP 1 -

HANGERS -

1 PROCEDURE B. GROUP 2 -

HANGER TO DUCT -

4 PROCEDURES C. GROUP 3 -

STAINLESS DUCT -

2 PROCEDURES D. GROUP 4 -

RCFC PLENUMS AND AUXILIARY BUILDING HOUSINGS -

2 PROCEDURES l

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WELDING MANHOUR BREAKDOWN f

. TYPE OF WELDING PERCENT OF TOTAL MANHOURS HANGERS 40%

(1 PROCEDURE AVAILABLE)

HANGER TO DUCT 15%

(4 PROCEDURES AVAILABLE)

SEAL. WELDING HOUSINGS AND DUCT 45%

(2 PROCEDURES AVAILABLE)

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(0207D)

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1 NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20, 1983 PULLMAN SHEET METAL FILLER METAL CONTROL

1. ALL WELDING FILLER METAL IS CERTIFIED MATERIAL.

2. WELDING MATERIAL REQUIRING ENVIRONMENTAL CONTROLS (E-7018, E-308 AND E-309) HAS HAD CONTROLLED ISSUANCE.

3. LISTED BELOW ARE THE QUANTITIES OF THE VARIOUS FILLER METALS WHICH MAVE BEEN USED ON-SITE:

TYPE OF FILLER METAL QUANTITY SMAW E-7018 12,875 POUNDS E-6013 1,350 POUNDS E-308 155 POUNDS E-309 420 POUNDS i MIG ER705-2 2,430 POUNDS ER308 360 POUNDS ER309 1,420 POUNDS E71T-GS 1,700 POUNDS SILICON RCU SI-A 750 POUNDS BRONZE I

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4. VERIFICATION OF PROPER FILLER METAL USAGE:

A. 100% VISUAL INSPECTION OF-HANGER WELDS IDENTIFIED NO EVIDENCE OF SILICON-BRONZE.

B. REVIEW 0F CERTIFIED MATERIAL TEST REPORTS FOR TWO (2)

HEATS OF E6013 SHOWS ACTUAL TENSILE STRENGTH TO BE 70KSI OR GREATER.

i C. PERFORMED RAND 0M INSPECTION OF HANGER WELDS TO IDENTIFY POSSIBLE IMPROPER USAGE OF STAINLESS STEEL FILLER METAL.

NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20, 1983 PULLMAN SHEET METAL QUALITY CONTROL INSPECTION OF WELDING

1. MARCH, 1978 TO SEPTEMBER, 1979 (SHUTDOWN)

A. 100% WELD INSPECTION BY PULLMAN SHEET METAL FOREMAN B. 10% WELD INSPECTION BY PULLMAN SHEET METAL QUALITY CONTROL C. 10% WELD INSPECTION BY PITTSBURGH TESTING LABORATORIES i

2. APRIL, 1980 (RESUMPTION OF WORK) TO PRESENT l

l A. 100% WELD INSPECTION BY PULLMAN SHEET METAL QUALITY i CONTROL B. 10% WELD INSPECTION BY PITTSBURGH TESTING LABORTORIES C. PERFORMED INSPECTION OF PREVIOUS WELDING (COMPLETED INSPECTION JANUARY, 1983)

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3. NOVEMBER, 1982 TO PRESENT A. INSTITUTED 100% CONFIGURATION INSPECTION OF PREVIOUS WORK (COMPLETED INSPECTION MAY, 1983)

4. AS OF MAY, 1983 ALL PREVIOUS DUCT HANGER WORK HAD BEEN INSPECTED FOR WELD QUALITY AND CONFIGURATION.

A. INSPECTION RESULTED IN 1480 CORRECTION NOTICES (CN'S)

ESTIMATED QUANTITY OF WELD'S INSPECTED IS 55,000.

B. CN'S WERE REVIEWED TO ANALYZE RESULTS OF WELbfNG DISCREPANCIES.

684 CN'S ON HANGER TO HANGER WELDS COVERING 4029 WELDS 441 CN'S ON HANGER TO DUCT WELDS COVERING 1726 WELDS 90% OF INSTALLATIONS ACCEPTABLE.

5. JULY, 1983 TURNED IN 50.55(E) ON DUCT FITTING CONFIGURATION.

A. BEGAN INSPECTION OF INSTALLED DUCT FITTINGS. INSPECTION 0F INSTALLED DUCT AND FITTINGS SCHEDULED TO COMPLETE SEPTEMBER, 1984.

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6. FEBRUARY, 1983 TO AUGUST, 1983 A. INSTITUTED INPROCESS INSPECTION OF WELDING BY PULLMAN SHEET METAL QUALITY CONTROL B. INSPECTED A MINIMUM 0F THREE (3) WELDERS PER WEEK C. SEVENTY-EIGHT (78) SURVEILLANCES PERFORMED TO DATE WITH ONLY ONE (1) DEFICIENCY NOTED. THE DEFICIENCY WAS AN ERROR IN THE WELDING PROCEDURE.

7. AUGUST, 1983 TO PRESENT A. INSTITUTED 100% INPROCESS INSPECTION OF WELDING BY PULLMAN SHEET METAL QUALITY CONTROL TO ESTABLISH CONFIDENCE LEVEL ON NEW PROGRAM IMPLEMENTATION.

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(0179D)

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~ NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20, 1983 9

PULLMAN PROGRAM IN EFFECT SINCE A!! GUST.1983

1. EXPANDED SHOP TICKET -

2. WELDING PROCEDURE PRE-ASSIGNED BY PULLMAN SHEET ME ENGINEERING

3. TYPE OF WELD R0D AND HEAT NUMBER USED ON INSTALL RECORDED ON SHOP TICKET t

4. WELDER I.D. RECORDED ON SHOP TICKET (0216D)

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REVIEW OF PROCEDURES A. S& L has reviewed all Pullman Site and Shop procedures.

duct brochure details, design drawings, field change requests.

B. Q.A. is 100% in line in assuring all procadures received S & L review before implementation.

C. S & L and O.A. review all procedures against Specification L-2782 FSAR committments, Q.A. Manual compliance, AWS Dl.1

, guidelines, and previous concerns with HVAC erection.

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APPROVED MATERIAL PSM's procurement, control, and incorporation of only approved materials (i.ncluding tiller materials) Q.A. verified 100% of Pullman's material adequacy on:

Q.A. Audit 20-82-20 Q.A. Audit 20-82-30 a

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WELDER TRAINING All Pullma3's welders received documented training for each procedure:

Training Covered Material Specifications Welding Processes Position of Welding Filler Metal Classifications Single or Multiple Pass Welding Current Polarity Welding Progression i

Preheat and Interpass Temperature Electrode Size Amperes Range i

Voltage Range Typec of Joints - Details Site Q.A. has verified this dccumented training.

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0.A. WITNFRSING DE QUAlTFICATION TFSTS SITE Q.A. HAS WITNESSED SITE WELDER QUALIFICATION TESTS. SINCE FEBRUARY OF 1981, Q.A. HAS WITNESSED 404 AWS GUIDED BEND QUALIFICATION TESTS.

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E,SM IN-PROCESS SURVEILLANCES From February through June, 1983. Pullman Q.C. performed 78 in-process survei13ances of actual welding. From June through December. 1983. PSM Q.C. has performed an additional des in-process surveillances - no instance of improper filler material placement was observed.

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t CONFIDENCE DDE IQ SJ2E DE WORK FORCE (1) ONLY A SMALL NUMBER OF WELDERS (2) WORKING WITH A LIMITED NUMBER OF ACCEPTABLE WELDING PROCEDURES (3) DEALING WITH FAMILIAR CONFIGURATIONS AND DETAILS RESULTED IN CONFIDENCE THAT PROPER WPS AND FILLER MATERIAL WAS USED.

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9 EIL EURVETIIANCES DIRFCTED B1 0.A.

A) 10M OVERVIEW OF ALL PSM WELD INSPECTIONS. FROM 1980 THROUGH 1983, 9132 WELDS WERE EXAMINED WITH 8577 FOUND ACCEPTABLE (94% ACCEPTANCE LEVEL).

B) RANDOM OVERVIEW SURVEILLANCES DIRECTED BY Q.A. ON CONFIGURATIONS, HOUSEKEEPING, STORAGE, WELDING DETAILS.

C) UNIT CONCEPT INSPECTIONS -

A PLANNED SERIES OF SURVEILLANCE MODULES WHICH PROVIDE INDEPENDENT DESIGN COMPLIANCE VERIFICATIONS -

l l OF 1121 ASPECTS ON PSM WELDING COVERED IN 14 UNIT CONCEPT INSPECTIONS, 877 WERE FOUND ACCEPTABLE. (THIS l SAMPLE WAS OF BOTH SAFETY RELATED, NON-SAFETY RELATED, COMPLETE AND INCOMPLETE CONSTR'JCTION, INSPECTED AND UNINSPECTED ITEMS.)

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. e SITE O.A. AUDITS OF PULLMAN'S ACTIVITIES 15 audits performed from May, 1980 through November, 1983 (two of these is'PSM Chicago Shop) 218 total questions 32 were related to welding activities and welder qualifications 44 were referenced to 10CFR50 Appendix B 69 were referenced to Pullman's procedures 42 were referenced to Pullman's Q.A. Manual 18 were referenced to ANSI daughter documents i

I 8 were referenced to Spec. 2782 requirements i 8 were referenced to Regulatory Guides i

3 were referenced to AWS Dl.1 l

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• NOTE - some questions had more than one reference.

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O,A,. SURVEILLANCES Site Q.A. Performed 119 surveillances from April, 1980 through tne present and of these, 59 addressed welding, welder qualifications or control of weld filler material.

4 12 documented actual witnessing of welding in compliance with correct welding procedure.

1 extensively documented a review of all WPS documentation.

1 involved actual destructive testing to verify the correct WPS was used.

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8 covered large samplings of acceptability of welder qualifications.

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. O t G.0, AUDITS Four of the General Office Audits conducted between April, 1981 tnrough October s 1983, examined Pullman's on eite activities.

A total of 75 questions were asked.

• 11 questions examined welding controls, welder qualifications, and filler metal control.

• 67 questions were referenced to 10CFR50 Appendix B.

7 questions were referenced to CECO Q.A. Manual compliance.

1 question was referenced to Pullman's Q.A. Manual.

• 30 questions were referenced to Regulatory Guidce.

3 questions were referenced to Pullman's procedures.

• 29 questions were referenced to Specification requirements.

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NOTE: Many questions had more than one reference.

l Additionally one of the General Office Audits which examined PSM (3/11-15/82) was composed of all LaSalle auditors with experience in LaSalle IIVAC concerns. Another audit (9/20-10/11/82) utilized a cognizant LaSalle auditor to audit Pullman's program adequacy.

(1246A)

4 ,

O.A. DIRECTED " RETRO" PROGRAMS i

A) 100% visual verification of all previous (1) welding, (2) duct and hanger configuration, and (2) equipment installation was required of Pullman (Jan., 1983).

B) Site Q.A. issued a Stop Work on all new work (except in U-l D/G Room) in June of 1983, to allow Pullman to complete the re-verification program.

i C) Re-verification program resulted in large numbers of Correction Notices being generated and the status of generation and closure of CN's was reported to and closely monitored by Site Q.A. (weekly status).

I i

i (1246A)

~

s m

BASES EQR COVSIDERING PulIMAN'S EASI PRACTICES ACCFPTABIE

1. S & L REVIEW AND APPROVAL OF ALL PROCEDURES.

2. P.S.M. INSTALLED ONLY VERIFIED ACCEPTABLE MATERIALS.

3. DOCUMENTED TRAINING OF ALL WELDERS.

4. SITE Q.A. HAS WITNESSED 100% OF ALL WELDER QUALIFICATIONS.

5. ONLY A LIMITED NUMBER OF ACCEPTABLE WELDING PROCEDURES AVAILABLE.

6. P.S.M. HAD PERFORMED IN-PROCESS WELDING SURVEILLANCES.

7. P.T.L. PERFORMING SURVEILLANCES FOR Q.A.

8. Q.A. AUDITS l

j (A) AUDITS ON PULLMAN REFERENCED TO ALL REQUIREMENTS.

(B) SURVEILLANCES ON PSM COVERED WELDING.

(C) G.O. AUDITS UTILIZING 0FF-SITE AUDITORS.

l

9. Q.A. ATTENTION TO P.S.M.'S STATUS OF INSTALLATION AND INSPECTION.

(1246A)

OVERALL POSITION Although, Ceco has directed Pullman to upgrade the quality of tne documentation of their Q.C. pre-welding, in-process, and post weld inspection checks in response to the NRC inspectors concerns, the up front programatic controls listed.above were and still are adequate to control the welding performed by PSM.

l o

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l (1246A)

-, m -,- ---

- , -e--- 3y ,m--r- -.--r---, > - - -- , - - - ---,, -.

O .

1 -PROCEDURAL CONCERNS PERCEIVED TO AFFECT HARDWARE e

4.3.7 - MINIMUM EMBEDDED CONDUIT BEND RADIUS VERSUS i S & L SPEC..EF-103 4.8.7 - INCORPORATION OF EF-103 REQUIREMENTS IN QC PROCEDURE 4.3.8 - PRECAUTIONS TO BE TAKEN ON SENSITIVE CABLE PULLS i

i f

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(0215D)

I.

0 .

2 - PROCEDURES REQUIRING MINOR CLARIFICATIONS 4.3.5 AND 4.8.5 - REVISE THE CABLE PAN INSPECTION FORM TO MATCH THE INSTALLATION REQUIREMENTS 4.8.5 - CLARIFY QUALITY CONTROL'S RESPONSIBILITY CONCERNING "IN PROCESS" INSPECTION OF CABLE PAN BOLTING 4.8.8 - CLARIFY PROCEDURE REQUIREMENTS WITH REGARDS TO INSPECTION FOR - SHARP EDGES AND TRAY EDGE SOFTENERS 4.8.8 - EXPAND / CLARIFY THE PROCEDURE TO SHOW HOW QC VERIFIES:

PROPER TYPE / SIZE OF CABLE j INSTALLED PER DESIGN ROUTING NO REVERSE BENDS i

4.3.13- EXPAND / CLARIFY TORQUE REQUIREMENTS FOR ELECTRICAL CONNECTIONS 4.3.8 AND 4.8.8 - EXPAND THE INSTALLATION AND INSPECTION REQUIREMENTS FOR CABLE GRIPS l

l l

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l (0215D)

L.R. .COMSTO CK &_ COMPANY;lNC QA: SECT

. BACKLOG: DOCUMENT REVIEW-STATJJSIBL Brown)

Week oEi ,y- p,e3- Report- by: Dst c so - pt.e 3 -

Documents; to: 7. compteteo_

j Area;.  ; Documents: Rev2.ewee ;

i this: week- i Review ~,

l ,

• t Welding (1) ' 31- /3 m : 7 h P.- b /' T ', .

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Ccnfiguraeions(2) 5-/c/ 7 y <! - ^; E/ f.

Tbrminationsf3) 6 4/- c 46- Mo /0.7  :

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t i CbudniH6-) e rn F.- cia toutument m n 78 -e %- /c':- R CEA.'s(8) # 9 R,,5f ,awr6- 'Ti.*J' -

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, dN81tlE 1 PUu.IA)G, -

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f SITE REVIEW BOARD MAKE-UP CECO Q.A.

PROJECT CONSTRUCTION PROJECT MANAGEMENT L. K. COMSTOCK (1) Q.C.

(2) Q.A.

(3) PRODUCTION (4) ENGINEERING THESE REVIEWS ADDRESS THE FOLLOWING ASPECTS FOR EACH PROCEDURE REVISION.

(1) CECO LESSONS LEARNED FROM BYRON /LASALLE l (2) LKC LESSONS LEARNED FROM FERMI / COOK / PERRY (3) RECENT SPECIFICATION CHANGES (4) ANY PENDING CECO, LKC, NRC AUDIT ITEMS t

(5) ANY ASSOCIATED Q.C. CONTROLS OR Q.A. ASPECTS RESULTING FROM SUCH CHANGES i

l (6) FUTURE PLANNED WORK ACTIVITIES i

I ,

[

l t

PIL INSPFCTIONS PITTSBURGH TESTING LABORATORIES INSPECTION ACTIVITIES (A) A 10% OVERVIEW INSPECTION OF ALL LKC WELDING INSPECTIONS.

(B) RANDOM OVERVIEW SURVEILLANCES DIRECTED BY O.A.

EXAMINING FOR SPECIFICATION COMPLIANCE AND PROCEDURE ADHERANCE.

t (C) UNIT CONCEPT INSPECTIONS - TO DATE 61 SUCH SURVEILLANCES HAVE BEEN COMPLETED WITH 44 HEAVILY COVERING ELECTRICAL ASPECTS.

I

Q.A. SITE AUDITS 42 AUDITS CONSISTING OF 423 OUESTIONS MAY '80 - PRESENT QUESTIONS REFERENCES # REF. AUDITED 10CFR50 APPENDIX B 86 LKC PROCEDURES 270 LKC Q.A. MANUAL 57 ANSI 41 REG. GUIDES 11 38 OTHER QUESTIONS REFERENCED SUCH THINGS AS:

CECO Q.A. MANUAL I

l NATIONAL FIRE CODE SPEC. L-2790A

• NOTE MANY QUESTIONS HAD MORE THAN ONE REFERENCE.

i l

l l-t b

s t

O.A. SURVEIL l ANCES l

FROM START-UP IN 1980 THROUGH THE PRESENT, 270

~

SURVEILLANCES HAVE BEEN PERFORMED ON LKC. THE AREAS REVIEWED (AGAINST REGULATORY BASIS, ANSI DAUGHTER l

DOCUMENTS, FSAR COMMITTMENTS, SPEC. L-2790A, LKC

(

l PROCEDURES) INCLUDED, BUT WERE NOT LIMITED TO, HOUSEKEEPING, STORAGE, WELDING, CABLE PULLING &

TERMINATING, DOCUMENT CONTROL, DESIGN CONTROL, GENERAL FIELD ACTIVITIES, & CALIBRATION CONTROL.

1 i -

i I

l i

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e

- , . - - --- ---a,. -

i G.O. AUDITS 5 AUDITS MAY '80 THRU PRESENT 50 QUESTIONS 40 QUESTIONS REFERENCED 10CFR50 APPENDIX B 7 QUESTIONS REFERENCED REG. GUIDES 4 QUESTIONS REFERENCED LKC PROCEDURES 2 OUESTIONS REFERENCED CECO Q.A. MANUAL

• NOTE, SOME QUESTIONS HAD MORE THAiJ ONE REFERENCE

• • THESE NUMBERS DO NOT REFLECT THE OCTOBER /1983 "MEGA-AUDIT"

,r- , ,,. . .- , . . , - - - - , , , ,. - - . , , -, -,.

LKC CHANGES (1) RECENT L. K. COMSTOCK Q.C. MANAGEMENT CHANGES (2) THE INCREASE IN Q.C. INSPECTOR MANPOWER LEVELS (3) THE STRENGTHENING OF LKC'S ON-SITE Q.A. GROUP TO 2 FULL TIME AUDITORS AS POSITIVE STEPS TO ENSURE A CONSTANTLY IMPROVING PROGRAM.

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9 v-ww, .,.m,-,--wm-- , , , , -, .w., ,.~,,e- -+- e w anw--'e'-**++we-- m --we- e ew - - -e

O.A. BASFS E.QR CONFIDENCE 11 M (1) ON-SITE PROCEDURE REVIEW PROCESS (2) S & L REVIEW OF ALL SITE PROCEDURES (3) PTL SURVEILLANCE ACTIVITIES DIRECTED BY Q.A.

(4) SITE Q.A. AUDITS & SURVEILLANCES (5) GENERAL.0FFICE AUDITS (6) RECENT CHANGES AND INCREASES IN LKC Q.C. AND Q.A.

t l

I l

t l

NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20, 1983 EVALUATIONS MANAGEMENT REVIEWS. PROJECT CHANGES AND CORRECTIVE MEASURES REVIEW GROUPS

1. TECHNICAL SUPPORT GROUP

2. DANIEL CONSTRUCTION

3. EDISON QUALITY ASSURANCE

4. PHILLIPS, GETSCHOW COMPANY l

f RESULTS

1. MANAGEMENT CHANGES AND ADDITIONS

2. RE-0RGANIZATION OF ENGINEERING AND QUALITY CONTROL DEPARTMENT

[ 3. INCREASED TRAINING FOR PERSONNEL

4. INCREASED EMPHASIS ON DOCUMENTATION

5. CLARIFY-QUALITY ASSURANCE PROCEDURES (0186D) .

L

6 8 NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20, 1983 AGENDA AS A RESULT OF REVIEW GROUPS WORK, MANY OF THE PROBLEMS IN THE FOLLOWING FOUR (4) AREAS HAD BEEN PREVIOUSLY IDENTIFIED AND CORRECTIVE ACTIONS WERE UNDERWAY AT THE TIME OF NRC INSPECTIONS. ,

1. SMALL BORE FIELD ROUTING CHANGES

2. VERIFICATION OF FIELD ROUTED DIMENSIONS

3. MATERIAL TRACEABILITY

4. SMALL BORE PIPE SUPPORT SELECTION (0187D)

P.G. CO. SMALL BORE INSTALLATION PROCEDURE - QCP-B21 - DEPICTS CLASS 2 & 3 ONLY; CLASS 1 PIPING CHANGES ALWAYS GO TO A.E. FOR PRIOR AlfIHORIZATION/ APPROVAL QCP-B21 ENGINEERING WELDING Q.C. A.N.I. PRODUCTION l

REV. 1 '

ISSUANCE FOR PF.V . 2 PRODUCTION REV. 3 O I Q

~

REV. 4 s WELD / BEND #

N ASSIGNFENT &

[o ) ,, O I

, QC AFI REVIEW s._ -

(AS N o i -

CHANGE ACTION REQUIRED) l .

j j COMPLETION I

REV. 4 . I ,

ISSUANCE FOR SUPPLEFENTS l l PRODUCTION S - REV. 0 S - REV. 1 O '

_ WELD / BEND #

S - REV. 2 './ Q '

i ASSIGNMENT &

QC ANI REVIEW f o-; . O l O l .

s/ Q l Q l CHANGE ACTION (AS REQUIRED) l COMPLETION l

REV. 5 DRAWING DRAWING DRAWING DRAWING ISSUANCE TO ISSUANCE TO DEVELOPFENT WELD REVIEW ~ REVIEW, HOLD REVIEW, j DOCUFENT PRODUCTION

& WELD / BEND # & APPROVAL iPOINT ASSIGN- HOLD , STATION FOR WuRK i PRE-ASSIGNFENT iFENT AND POINT l FOR RELEASE

APPROVAL ASSIGN-FENT, &l TO WORK APPROVAL l ~ DOCUMENT .

l PRODUCTION l f STATION I

' O O O O- ,

V V jV l

, ISSUANCE FOR' N PRODUCTION l

i' O O O O- -

J.Ea v o o i CHANGE aui wa I

COMPLETION l

NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20, 1983 SMALL BORE FIELD ROUTING CHANGES -

CLASS 2 AND 3 ONLY OCP B21. REVISIONS 0. 1. 2. 3. 4

1. QUALITY CONTROL /ANI REVIEW AND HOLD POINT ASSIGNMENT OF INITIAL PACKAGE.

2. ALL CLASS 1 PIPING ROUTING CHANGES SENT TO ARCHITECT / ENGINEER FOR REVIEW AND APPROVAL.

l

3. QUALITY CONTROL /ANI REVIEW AND HOLD POINT ASSIGNMENT OF l

ADDED/ DELETED WELDS / BENDS ON ROUTING CHANGES.

l

4. ROUTING REVISIONS MARKED IN RED.

(0175D) l

_. . , _ _, _ _ . . _ _ . , _ _ _ _ ._s. _ _

NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20, 1983 SMALL BORE FIELD ROUTING CHANGES -

CLASS 2 AND 3 ONLY OCP B21. REVISION 4. SUPPLEMENTS 0. 1. 2

l

1. ADDED FIELD ENGINEERING REVIEW AND APPROVAL 0F ROUTING CHANGE PRIOR TO ERECTION.

2. INCORPORATED QUALITY CONTROL DIMENSIONAL VERIFICATION OF INSTALLED PIPING PER PGCP-40.

l 3. INCORPORATED QUALITY CONTROL DIMENSIONAL VERIFICATION OF ALL PIPE, VALVE AND COMPONENT HEAT NUMBERS ON FIELD INSTALLATION DRAWINGS.

l (0176D)

NRC ENFORCEMENT CONFERENCE -

BRAIDWOOD PROJECT DECEMBER 20, 1983 SMALL BORE FIELD ROUTING CHANGES -

CLASS 2 AND 3 ONLY OCP B21. REVISION 5

1. COMPLETE REWRITE OF PROCEDURE A. UPDATE TO ESTABLISH PROCEDURAL / QUALITY ASSURANCE l

MANUAL CONSISTENCY AND STANDARDIZE PROCEDURAL FORMATS AND INCORPORATE NEW MANAGERIAL CONCEPTS.

l l B. INCORPORATE ALL SUPPLEMENTS INTO PROCEDURE l 2. EXPANDED GENERALIZED QUALITY CONTROL INSPECTION l REQUIREMENTS TO DE MORE SPECIFIC.

3. ADDED REQUIREMENT FOR FIELD CHANGE ORDER (FCO) INITIATION AND APPROVAL BY ENGINEERING OF ROUTING CHANGES.

4. ADDED DOCUMENT STATION REQUIREMENTS.

i 5. IDENTIFIED RECORD RETENTION REQUIREMENTS -

TEMPORARY / PERMANENT.

(0177D)

NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20, 1983 l

! VERIFICATION OF FIELD ROUTED DIMENSIONS APRIL, 1983 - PHILLIPS, GETSCH0W COMPANY SITE QUALITY ASSURANCE -

AUDIT IDENTIFIED FINDING -

LACK OF QUALITY CONTROL VERIFICATION OF FIELD ROUTED SMALL BORE PIPING DIMENSIONS.

MAY, 1983 - PHILLIPS, GETSCH0W COMPANY DEVELOPED, OBTAINED APPROVAL FOR PGCP-40 " VERIFICATION. PREPARATION AND TRANSMITTAL OF AS-CONSTRUCTED DRAWINGS".

1. RESPONSE T0.PHILLIPS, GETSCHOW COMPANY QUALITY ASSURANCE DEPARTMENT FINDINGS.

l MAY, 1983 - PHILLIPS, GETSCH0W COMPANY IMPLEMENTED PGCP-40, VERIFICATION OF PREVIOUSLY INSTALLED PIPING.

OCTOBER, 1983 - PHILLIPS, GETSCHOW COMPANY CHANGED ALL PIPING INSTALLATION PROCEDURES TO REQUIRE "AS-CONSTRUCTED" VERIFICATION AS PART OF INSTALLATION INSPECTION CRITERIA.

FEBRUARY, 1984 - PGC0-40, VERIFICATION OF PREVIOUS INSTALLATIONS WILL BE COMPLETE.

(0184D) 1

NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20, 1983 VERIFICATION OF FIELD ROUTED DIMENSIONS PGCP-40

1. PROVIDES SPECIFIC DIMENSIONAL CRITERIA FOR VERIFICATION OF PIPING CONFIGURATION (INPUT PROVIDED BY ARCHITECT / ENGINEER).

2. PRODUCTION DEPARTMENT TAKES DIMENSIONS.

l

3. QUALITY CONTROL DEPARTMENT PERFORMS 100% VERIFICATION.

i

4. NOTES IF PIPING IS WITHIN 3 INCH OF ANOTHER INSTALLATION AND POINT OF THAT LOCATION.

l

5. ESTABLISH TRANSMITTAL MECHANISM OF "AS-BUILT" DRAWINGS.

.I .

L

-l NRC ENFORCEMENT CONFERENCE BRAIDWOOD-PROJECT DECEMBER 20, 1983

, PGCP-40 -

VERIFICATION STATUS - SMALL BORE SCOPE OF PGCP-40 IN MAY, 1983 (ASME SMALL BORE DRAWINGS 758 ,

COMPLETED AS-CONSTRUCTED ASME SMALL BORE DRAWINGS PER PGCP-40 TO DATE , 869 i

TOTAL INSTALLED ASME SMALL BORE DRAWINGS TO DATE 979 AS-CONSTRUCT STATUS OF INSTALLED SMALL BORE PIPING 89%

' TOTAL ASME SMALL BORE DRAWINGS DEVELOPED BY PHILLIPS, GETSCH0W COMPANY T0'DATE 1,335

-PGCP-40 SHALL BE UTILIZED TO AS-CONSTRUCT. ALL ASME SMALL BORE l DRAWINGS INSTALLED PRIOR TO QCP-B21, REVISION 5.

(0212D)

a .

NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20, 1983 MATERIAL TRACEABILITY NOVEMBER, 1982 -

PHILLIPS, GETSCHOW COMPANY REVISED WELD DATA REPORT TO REQUIRE VERIFICATION 0F MATERIALS JOINED BY WELDING PROCESS ON LARGE BORE PIPING.

APRIL, 1983 - PHILLIPS, GETSHOW COMPANY QUALITY ASSURANCE IDENTIFIED DEFICIENCY WITH DOCUMENTATION OF SMALL BORE MATERIAL HEAT NUMBERS ON DRAWINGS.

JUNE, 1983 - PHILLIPS, GETSCHOW COMPANY REVISED QCP-B21 TO REQUIRE VERIFICATION OF SMALL BORE MATERIAL HEAT NUMBERS ON DRAWINGS.

JULY, 1983 -

COMMONWEALTH EDIS0N COMPANY REPORTED POTENTIAL 50.55(E) DEFICIENCY - QUALITY CONTROL VERIFICATION OF HEAT OR MARK NUMBERS OF INSTALLED PIPING SYSTEM COMP 0NENTS WAS NOT ADEQUATELY DOCUMENTED.

AUGUST, 1983 - SURVEY STARTED BY PHILLIPS, GETSCHOW COMPANY UTILIZING MIL-STD-105D TO ESTABLISH TRACEABILITY.

JANUARY, 1984 -

TRACEABILITY SURVEY PLANNED COMPLETION.

PHILLIPS, GETSCH0W COMPANY e 8 SMALL BORE CUMULATIVE SAMPLE 2 INCH AND UNDER TOTAL NUMBER OF DRAWINGS IN SAMPLE -

128 TOTAL NUMBER OF ITEMS TO VERIFY -

1415 TOTAL ITEMS VERIFIED IN THE FIELD -

1230 86.9%

T0TAL ITEMS VERIFIED THROUGH DOCUMENTATION -

1383 97.7%

TOTAL ITEMS VERIFIED IN THE FIELD & THROUGH DOCUMENTATION -

1414 99.9%

TOTAL ITEMS NOT VERIFIED TO BE TRACEABLE IN THE FIELD OR THROUGH DOCUMENTATION -

1 .1%

i NOTE: THIS ITEM WAS IDENTIFIED ON A PHILLIPS, GETSCHOW COMPANY l NONCONFORMANCE.

l t

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, , NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20, 1983 MATERIAL TRACEABILITY -

SUMMARY

1. PHILLIPS, GETSCHOW COMPANY HAS INITIATED CORRECTIVE ACTIONS TO FULLY DOCUMENT MATERIAL TRACEABILITY DURING THE INSTALLATION PROCESS.

2. A SAMPLE VERIFICATION SHOWS THE ADEQUACY OF SMALL BORE MATERIAL TRACEABILITY FOR PREVIOUS INSTALLATIONS.

SMALL BORE SAMPLE SIZE 1415 ITEMS TRACEABILITY MARKINGS VERIFIED IN FIELD 1230 ITEMS (86.9%)

TRACEABILITY MARKINGS VERIFIED BY DOCUMENTATION 1383 ITEMS (97.7%)

l TRACEABILITY MARKINGS VERIFIED IN i

FIELD AND BY DOCUMENTATION 1414 ITEMS (99.7%)

3. IN ALL SAMPLE CASES PHILLIPS, GETSCH0W COMPANY HAS A STORES REQUEST DOCUMENT TO SUPPORT THE TRACEABILITY MARKINGS VERIFIED IN FIELD.

-4. SIMILIAR RESULTS ARE BEING OBTAINED FOR LARGE BORE PIPING MATERIAL.

l

5. FINAL REPORT - 50.55(E) WILL DOCUMENT SAMPLE RESULTS AND CONCLUSION.

(0213D)

I

e I -

SMALL BORE PIPING SUPPORT SELECTION ACTIVITY BY PHILLIPS, GETSCHOW C0. AT BRAIDWOOD COMPARIS0N OF LASALLE PIPING CONTRACTOR'S ACTIVITIES AND BRAIDWOOD PIPING CONTRACTOR'S ACTIVITIES

( #Mu> <en tti 1 R P M now co.3 SUPPORTED H0T PIPING YES NO SUPPORTED COLD PIPING YES . YES CONCEPTUAL SUPPORT DESIGN YES NO SELECTION OF. TYPICAL SUPPORT DETAILS YES YES METHOD & DATA UTILIZED: *PI-LS-16 SIMPLIFIED GUIDELINES ANALYTICAL LOCA'TIONS YES NO THERMAL LOADS & MOVEMENTS YES NO DYNAMIC LOADS & MOVEMENTS YES N0 GLOBAL COORDINATE FORMAT (X, Y, & Z) YES N0 TYPICAL CALCULATION FORMULAS YES YES ASSEMBLY COMPONENTS YES NO TYPICAL SUPPORT CONFIGURATIONS YES YES ALL-BUILDING AREAS YES ii0 "S&L PROJECT INSTRUCTION UTILIZED BY THE A.E.'S (S&L)

SUPPORT DESIGNERS, AS WELL AS BEING ISSUED TO MORRIS 0N

.AS AN INCLUSION IN THEIR SPEC. "

. . =. .

PHILLIPS, GETSCH0W C0. PROCEDURE PGCP-22 FOR SUPPORT SELECTIONS TOTALLY RESTRUCTED PROCEDURE, BOTH IN CONCEPT AND IN WORDING, T0:

BE MORE SPECIFIC IN METHODOLOGY REINFORCE REQUIREMENTS ENHANCE TRAINING BENEFIT PROCEDURAL IMPLEMENTATION 4

I i

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PHILLIPS, GETSCHOW C0. PROCEDURE PGCP-22 FOR SUPPORT SELECTIONS SOME CHANGES MADE:

ORGANIZATION CHANGE: ADDED CllECKER POSITION EXPANDED TRAINING: SCOPE, QUANITY AND INTENSITY ADDED PROFICIENTY TEST: EVALUATION TRAINING AND PERSONNEL COMPENTENCY INSTITUTED " CONTROLLED REFERENCE BOOK DEVELOPED STANDARD CALCULATION SHEETS:

20 TECllNICAL CALCULATION SHEETS AND 4 ADMINISTRATIVE CONTROL SHEETS

. c

^

PHILLIPS, GETSCH0W C0. PROCEDURE PGCP-22 FOR SUPPORT SELECTIONS 4

r4 t

VERIFICATIONS: (ALL WERE FOUND ACCEPTABLE)

S&L TOTAL REVIEW 0F WORK PRIOR TO 10/83.

/

S&L IMPLEMENTATION REVIEW CECO. 0.A. SURVEILLANCE AND AUDIT FORMAL PROCEDURE ACCEPTANCE / APPROVAL BY CECO.

(PCD & 0.A.) AND THE A.E. (S&L) h 8 I

NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20, 1983

SUMMARY

1. REVIEW GROUPS IDENTIFIED MANY OF THE PHILLIPS, GETSCHOW COMPANY PROBLEMS WITH SMALL BORE PIPING INSTALLATION ROUTING CHANGES, QUALITY CONTROL VERIFICATION OF PIPING CONFIGURATION, PIPING MATERIAL TRACEABILITY, AND SMALL BORE PIPE SUPPORT SELECTION.

2. CORRECTIVE ACTIONS WERE UNDERWAY AT THE TIME OF NRC INSPECTIONS FOR MANY OF THE PROBLEMS.

3. THESE CORRECTIVE ACTIONS INCLUDED MANAGEMENT CHANGES AND ADDITIONS, REORGANIZATION OF ENGINEERING AND QUALITY CONTROL DEPARTMENTS, PROCEDURAL REVISIONS, VERIFICATIONS OF PREVIOUS INSTALLATIONS AND TRAINING 0F PERSONNEL.

l l 4. THE STRENGHTENING OF THE PHILLIPS, GETSCHOW COMPANY QUALITY I

PROGRAM AS PREVIOUSLY COMMITED TO THE NRC HAS BEEN AN ONG0ING

! AND EVOLVING PROCESS AND SHOULD BE COMPLETED SHORTLY.

l l (0214D)

I .

SMALL-BORE PIPING 0.A. INVOLVEMENT I. CONCERNS ADDRESSED BY Q.A.

i II. CONCERNS CONSIDERED IN COMPLIANCE III. CONCERNS PREVIOUSLY IDENTIFIED l

l IV. CONCERNS NOT IDENTIFIED BY Q.A.

V. CONCLUSION l

,, , --.., ., . - - . , . -.n.. .,,.~...-...,-.-.n,,,,,,,, _,,- - ----.----,,-n.-_, ,- , , . - .- - , - . . ,,... , - , -

t

..w i

I. CONCERNS ADDRESSED BY Q.A. -

A. MEASURING EQUIPMENT USAGE B. FIELD ENGINEER RESPONSIBILITIES C. SUPPORT SELECTION l

D. SUPPORT SELECTOR TRAINING l

l L

t s .

4 4

II. CONCERNS CONSIDERED INCOMPLIAN}E i

A. PGC0 AUDIT PLAN B. S & L ASSESSMENT OF PGC0 C. FIELD ROUTING OF PIPE D. ROUTING PROCEDURE ADEQUACY l

(

i l

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i O

i ICI. CONCERNS PREVIOUSLY IDENTIFIED -

A. FCR STAMP ON DRAWING B. MATERIAL TRACEABILITY DOCUMENTATION

1. SMALL BORE

2. LARGE BORE I

h c

IV. CONCERNS NOT IDENTIFIED BY Q.A. .-

A. Q.C. CONFIGURATION CHECKS B. Q.C. DIMENSIONAL CHECKS C. PGC0 NCR #789 DISPOSITION D. PGC0 INFO REQUEST INSTEAD OF FCR N

N

.--,c- - - . -- , - c , - , , - . . , , + - . - . _ . - . , , , . _ , , . . _ - , . , , - . , . .

3 0

s >

V. CONCLUSION A. MAJORITY OF ITEMS PREVIOUSLY ADDRESSED B. NEED FOR IMPROVEMENT C. Q.A. PROGRAM EFFECTIVE g

I

..,',- NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20, 1983 VIII.

SUMMARY

EXTENSIVE EVALUATION PERFORMED BY TECHNICAL SUPPORT GROUP AND DANIEL CONSTRUCTION SIGNIFICANT ORGANIZATIONAL, PROCEDURAL, MANAGEMENT, AND PERSONNEL CHANGES PHILLIPS, GETSCH0W COMPANY REPLACED ALL TOP SITE MANAGEMENT -

21 NEW PERSONNEL ON-SITE ACQUIRED MANY LASALLE AND BYRON EXPERIENCED PERSONNEL REPLACED OR ADDED QUALITY CONTROL SUPERVISORS AT EACH OF THE THREE MAJOR CONTRACTORS ADDED ON-SITE QUALITY ASSURANCE SUPERVISOR AT EACH

OF THE THREE MAJOR CONTRACTORS 1

INCREASED MAJOR CONTRACTOR QUALITY CONTROL / QUALITY ASSURANCE i

l 88 (08/82) 214 (12/83) i 1 --

INCEASED MAJOR CONTRACTOR QUALITY CONTROL INSPECTORS l

53 (08/82) 123 (12/83) f (0217D)

i

, . . s VIII.

SUMMARY

QUALITY CONTROL INSPECTOR RE-INSPECTION (ALL CONTRACTORS)

DOCUMENT REVIEW 10,000 LARGE BORE WELDS (PHILLIPS, GETSCH0W COMPANY)

PIPING HEAT NUMBER TRACEABILITY (PHILLIPS, GETSCHOW COMPANY) 100% RE-INSPECTION INSTRUMENTATION (PHILLIPS, GETSCH0W COMPANY) 100% RE-INSPECTION HANGERS (PHILLIPS, GETSCHOW COMPANY) 100% RE-INSPECTION EQUIPMENT (PHILLIPS, GETSCH0W COMPANY) 100% DOCUMENATION REVIEW (L. K. COMSTOCK)

QUALITY CONTROL STRUCTURAL STEEL REVIEW (GKN) 100% RE-INSPECTION WELDING (PULLMAN) l 100% RE-INSPECTION CONFIGURATION (PULLMAN) 1 100% RE-INSPECTION DUCT BROCHURE ITEMS (PULLMAN)

(0218D)

, , .- , , - - - . - - . , - - . . . .