ML20135F266
| ML20135F266 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 09/12/1985 |
| From: | Fitzpatrick E, Quaka T COMMONWEALTH EDISON CO. |
| To: | ROREM, B. |
| References | |
| CON-#385-508 OL, NUDOCS 8509170208 | |
| Download: ML20135F266 (100) | |
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% ED Nm% % September 12, 1985 Y 16 gg,.
UNITED STATES OF AMERICA -
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NUCLEAR REGULATORY COMMISSION ' . '.u.' -
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: )
COMMONWEALTH EDISON COMPANY ) 'e, ' '
) Docket Nos. 50-456 (Braidwood Nuclear Power. ) 50-457 dL Station, Units 1 and 2) )
APPLICANT'S EIGHTH PARTIAL RESPONSE TO ROREM'S FIRST SET OF QUALITY ASSURANCE INTERROGATORIES AND REQUESTS TO PRODUCE On July 2,.1985, Intervenors Rorem, et al.
("Intervenors"), filed their First Set of Quality Assurance Interrogatories and Request to Produce. On July 30, 1985, Commonwealth Edison Company (" Applicant") filed objections to ,
certain of those discovery requests and provided to Intervenor,s' counsel a partial response to Intervenors' discovery requests. Applicant's first partial ~ response was revised and resubmitted on August 1, 1985. Applicant filed a second partial re,sponse on August 5, 1985, a third on August 10, 1985, a fourth on August 13, 1985, a fifth on August 14, 1985, a sixth on August 27, 1985 and a seventh on September 6, 1985. This submission, which is Applicant's eighth partial response to Intervenors' discovery requests, provides a response to Specific Interrogatory 35. Investigation 8509170208 850912 PDR 9 ADOCM 05000456 PDR .+
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's continues for responses to all of the requests to which Applicant has not objected and Applicant expects to supplement certain responses previously filed. In addition, Applicant will provide at a later date additional affidavits and updated indices of documents made available for inspection and copying.
Each document referenced in Applicant's responses to Interrogatory 35 has been identified with a number. In addition, Applicant will provide an index fcr Interrogatory 35 organized by interrogatory number, which will identify for each numbered document the date, author, recipient, and type of document. Updated indices will be provided for all interrogatories as appropriate.
With regard to requests for addresses and telephone numbers of individuals employed by Commonwealth Edison or its contractors, onsite personnel can be located by contacting Braidwood Nuclear Power Station, Braceville, Illinois 60407 (phone 815-458-2801). Other Commonwealth Edison personnel can be located by contacting 72 W. Adams St., P.O. Box 767, Chicago, Illinois 60690 (phone 312-294-4321).
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Specific Interrogatorv #35 Has Commonwealth Edison Quality Assurance ever failed to identify deficient contractor programs at Braidwood where such Programs have been subject to Commonwealth Edison Quality Assurance auditing? If so, please describe each instance in detail and any and all corrective action taken with respect to such instance.
' Identify any and all documents which reflect such instances and such corrective action. Has the NRC ever identified such instances? If so, please describe in detail and identify any documents which reflect such instances and any corrective action taken.
Response
The response to Specific Interrogatory #35 was developed in the following manner. A review of all Edison Site or Corporate Quality Assurance audits was conducted. Review was limited to audit reports involving specific subcontention items of Intervenors' Quality Assurance contention. The review was further limited to audits conducted within 90 days of the first site inspection visit identified in the various NRC inspection repor-ts which were the source of the various subcontention items. Approximately 150 audit areas contained within 50 audits were reviewed'under this approach which is deemed reasonable in view of the general nature of Interrogatory 35. -
The audit review encompassed both a review of the audit report itself and an examination of the audit checklis't questions and backup, i.e. " objective", evidence. Those instances in which an Edison audit did not formally identify a concern subsequently identified by the NRC in an inspection visit beginning within 90 days-of the audit (and later included in an Inspection Report used as the source of a subcontention iten) were determined to be responsive to Specific Interrogatory 35. Specifically, the following information is provided.
- Page 2
, 1. The NRC identified in their inspection which began in June, 1983 (Report 83-09) that Phillips, Getschow Company was not properly documenting the use of dial calipers for measuring the ovality of piping after bending (contention item 6B.3). During its review of the cold bending program for small bore safety related piping, the NRC identified that four (4) out of five (5) drawings reviewed had no documented record of the use of calipers. The NRC considered this to be contrary to Getschow Procedure QAP-7, Rev. 7 " Control of Inspection Equipment" which required that a record of the use of inspection equipment be maintained.
Edison Site Quality Assurance performed audit 20-83-25 in May of 1983 which examined this area. Audit checklist question 38 of the subject audit sought verification that Getschow ,
Quality Control maintained a listing of all items and materials inspected with each piece of inspection equipment. The Edison Q.A. auditor examined Getschow's Q.C. tool / instrument issue log from July, 1982 through May, 1983 to determine, among other things, whether dial caliper usage was being properly documented. Getschow maintained this log to comply with QAP-7, Rev. 7. For the period reviewed, the auditor found the log to i be completely filled out except for two (2) instances where a callper had been logged out, but the specific caliper usage was i
not properly documented. Based on the review, the auditor i
found Getschow's log acceptable for the identification of caliper usage. ;
(3336A) l l
4 Page 3 Although both the Edison audit and the NRC inspection reviewed whether dial caliper usage was properly documented by Getschow, it appears that the NRC reviewed pipe bend field drawings as well as the Getschow tool / instrument issue log, while the Edison audit reviewed only the log. The Edison audit did not review field drawings because, at that time, the tool / instrument issue log was the document used by Getschow to comply with Procedure QAP-7, Rev. 7.
A current review of the tool / instrument issue log for the period in which the NRC reviewed pipe bend field drdwings for caliper documentation confirmed, at the time of the NRC inspection, that n'o' log entries existed to document the I calipers used to measure the listed pipe bends. Despite the 1
fact that audit 20-83-25 had reviewed the tool / instrument issue ,
l log during the same period, the Edison auditor could not have 1 identified the specific caliper documentation concerns identified by the NRC because no record of the specific caliper usage was entered in the log. Further, the auditor apparently
- considered the two identified instances of faulty caliper usage
! documentation by Getschow over the ten month period reviewed to be isolated cases that did not require finding the overall documentation of the-usage of dial calipers contained in the 4
log to be deficient. Thus, although audit 20-83-25 did not identify the same concern subsequently identified by the NRC during its site inspection visit, Edison does not view this audit as an example of inadequate auditing.
(3336A)
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Page 4 It should be noted that subsequent to audit 20-83-25, but concurrent with the NRC's site inspection visit, Edison Site Quality Assurance audit 20-83-33 (pages B0000175 - 25),
performed between July 5 and July 12, 1983, identified as finding No. 2 that Getschow Q.C. inspectors were not recording on field drawings the instrument control number of the calipers used to measure pipe bend ovality. A description of the corrective action taken in response to the NRC's and Edison's concurrently identified concern is contained in the response to Specific Interrogatory 58 and 59, contention item 6B.3.
- 2. The NRC identified in their inspection which began in June, -
1983 (Report 83-09) that Phillips, Getschow Company did not have a documented inspection program for Quality Control inspectors to examine' piping components at the time of installation to assure correct piping material usage (contention item 10L). The NRC did not believe it was appropriate to rely on the Getschow " Stores Request System",
which documented material heat numbers at issuance, as a means of verifying that correct piping materials were being installed.
(3336A)
Page 5 i
Ceco Site Quality- Assurance performed audit 20-83-25 in May of 1983 which covered this area. Audit checklist questions 1 and 2 of the subject audit sought verification that Getschow Q.C. was establishing the acceptability of base (piping) materials being installed. The auditor noted that Getschow established this acceptability through its Stores Request System, which required the documentation of heat numbers to ensure the traceability and correctness of materials to be installed. In audit question 2, the auditor found the Getschow Stores Request System acceptable for determining the adequacy of installed piping material, i.e. for assuring correct material usage and material traceability. In audit question 1, the auditor compared the heat numbers on items of installed -
piping reviewed with the heat numbers on the Getschow stores request document for these items of piping and found that the materials identified on the. Stores Request matched the
] .
materials installed in all cases.
1 Although the NRC inspection and Edison Q.A. Audit 20-83-110
, conducted in September of 1983 (I0000214-0575) subsequently found cases where the correct materials had not been installed by Getschow, Edison's position was that these cases were I
isolated in nature and that the Getschow Stores Request System was an acceptable method of demonstrating correct material (3336A)
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usage at the time of installation. Based on this position and on the audit findings that the Getschow Stores Request System was verifying the correctness of materials installed, Edison does not believe audit 20-83-25 represents a case where its auditing program was ineffective in identifying a deficient condition.
Further, Edison has instituted a Material Traceability Verification (MTV) program to demonstrate the acceptability of the Getschow Stores
]
f Request System. Edison believes that its MTV program will confirm the adequacy of the Getschow stores request material traceability
' approach to establish the acceptability of piping materials at the time they were installed. Partial results from the MTV program are reflected in the response to Specific Interrogatory 31 and a summary of a presentation made to the NRC Staff about the Program is set -
forth in the letter of July 8, 1985.from L. DelGeorge to J. Keppler.
- 3. The NRC identified in its inspection which began in December, 1984 (CAT Report 84-44) that Phillips, Getschow Company Quality Control inspectors failed to note a number of installation deficiencies on i
Q.C. accepted supports / restraints (contention items 10C & 10E).
r These conditions involved failures to conform to design requirements,
) including improper or undersized welds, wrong material installed, attachment locations out of tolerance and excessive snubber to rear 1
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1 bracket angularity. The CAT inspectors examined in detail a i total of 36 supports / restraints and observed on a random basis approximately 100 more for obvious deficiencies in making its finding. Based on the observations of installed hardware, the NRC CAT inspectors concluded, in part, that Getschow's Quality Control / Production inspection programs had not been effective in assuring that installed hardware conformed to design requirements.
Edison Site Quality Assurance performed audit 20-84-552 in November of 1984 which examined the area of pipe supports / restraints installation in audit checklist questions 9 and 10. Question 9 sought verification that Getschow Q.C. -
inspections were being performed as required on snubbers, whip restraints and hangers and were in accordance with established t
procedures. Question 10 sought verification that snubbers, f
whip restraints and hangers were installed by Getschow per the design drawings. In answering questions 9 and 10 with respect to snubbers and hangers, the area of the NRC's inspection concern, the auditor reviewed a total of 7 Getschow pipe
- supports / restraints in the field and confirmed that the supports / restraints were actually installed per the design
! documents and were properly inspected by a Getschow Q.C.
I inspector.
(3336A) f -
Page 8 Although the Edison audit did not identify the same concern subsequently identified by the NRC during its site inspection visit, comparison of the 7 installations checked by the Edison auditor in audit 20-84-552 with those checked during the NRC CAT inspection visit revealed that in no case did Edison and the NRC inspect the same support / restraint installations. The lack of coincidence in installations reviewed by Edison and the NRC is not unexpected or unusual, since at the time of the CAT inspection there were thousands o'f Getschow support / restraints which had previously been Q.C. accepted. Further, it appears that the review of each hanger / restraint installation performed in audit 20-84-552 by Edison Quality Assurance was comparable in scope and detail, to those performed by the NRC CAT Team.
Since auditing is necessarily a sampling process which does not purport to examine every applicable item in every audit of a particular area, it is not unreasonable for the conclusions reached by the Edison site Q.A. audit team to be different from those reached by the NRC CAT inspect.lon team, based on the different samples reviewed. As such, Edison does not view audit 20-84-552 to be an example of inadequate auditing.
A description of the corrective actions taken in response to the NRC identified concern is provided in the response to Specific Interrogatory 58 and 59, contention items 10C and 10E.
(3336A)
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Page 9
- 4. The NRC identified in their inspection which began in June, 1983 (Report 83-09) that Phillips, Getschow had not established and executed a formal plan for auditing the implementing procedures of its Q.A. Program on a periodic basis 4
to determine the effectiveness of the program in accordance with the Getschow Q.A. Manual, Section 16 (contention item 14.B.1). Edison Site Quality Assurance performed audit 20-83-15 in March of 1983 which examined this area. Audit checklist question 25 reviewed Getschow's internal audit schedule for 1982/1983 to verify that the entire scope of Getschow's on-site activities was covered. The auditor verified that all applicable manual sections of Getschow's Quality Assurance Manual were audited on a yearly basis. _
Objective evidence supporting the auditor's finding noted procedures which were included in the scheduled audits.
However, no review was conducted to verify that all site implementing procedures were being audited by Getschow under its audit schedule.
In its response to Inspection Report 83-09, Edison acknowledged that Getschow did not audit each of its implementing procedures. During the time frame of the Edison audit and the subsequent NRC inspection visit, the NRC's l
interpretation that the auditing of all implementing procedures (3336A)
. Page 10 was necessary to constitute, in the words of Criterion XVIII of Appendix B to 10 CFR Part 50, "a comprehensive system of planned and periodic audits" was not shared by Edison. Until the issue was 4
raised by the NRC's inspection visit, Edison's position was that compliance with all aspects of the quality assurance program and a determination of the effectiveness of the program could be accomplished by auditing all Quality Assurance Manual sections .
applicable to the work being performed, including the auditing of selected procedures in use at the site. Audit 20-83-15 examined i Getschow's audit schedule in accordance with the Edison position.
Accordingly, Edison believes the conclusion reached in audit 20-83-15 that Getschow's audit schedule conformed to Q.A. requirements is not i
l indicative of ineffective auditing.
i Phillips, Getschow Q.A. Manual was subsequently revised to include j
auditing requirements for implementing procedures and the audit
- schedule was revised in August, 1983 to provide for the auditing of ;
- all active procedures. Edison Q.A. Audit 20-83-110 conducted in ,
September of 1983 (I0000214-0575) verified that PGCo had complied a
' with the committed corrective action and was auditing its implementing procedures on a yearly basis. Continued adherence to the requirement for Getschow to audit all Q.A. Manual sections and :
I procedures annually has been verified in Edison audits in 1984 and 1985.
For further explanation, .see the response to Specific Interrogatory 49. l L
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- 5. The NRC identified in their inspection which began in June, 1983 (Report 83-09) that L. K. Comstock was not conforming to its annual schedule of planned audits not was it verifying compliance with all aspects of its Quality Assurance Program (contention item 14.B.2). The NRC noted that Comatock did not perform a complete verification of its Quality Assurance Program in 1982 and 1983. Specifically, the following Quality Assurance Manual Subsections and work procedures were identified as not having been audited:
- 1. Section 1.0.0, " Policy Statement"
- 2. Section 1.0.1, " Quality Assurance and Quality Control Program"
- 3. Section 2.0, " Applicability" -
- 4. Section 3.1.3, " Reporting of Defects and Non-Compliance"
- 5. Section 3.1.4 " Quality Assurance Program Review and Evaluation"
- 6. Section 3.2, " Organization (Corporate)"
- 7. Work Proceduce 4.3.3.1, " Welding Procedure for Structural Attachments (6013)"
- 8. Work Procedure 4.10.4 " Housekeeping"
- 9. Work Procedure 4.3.23, " Silver Plating"
- 10. Work Procedure 4.1.2, " Position Delineation" (3336A) l l
- m Page 12
- 11. Work Procedure 4.3.16. " Revision / Work Request of All Electrical Equipment"
- 12. Work Procedure 4.3.13. " Equipment / Junction Box Installation" CECO Site Quality Assurance performed Audit 20-83-20 in April, 1983 which examined the Comstock site audit schedule.
Audit checklist question 30 sought verification that Comstock 2
Internal site audits were conducted at least annually. The auditor reviewed the Comstock site audit schedule for 1983 along with the site audit reports issued up to the time of the audit. The auditor concluded that the Comstock internal audit schedule was set up to audit the entire site Q.A. program in 4
one year, and that f.KC was meeting its 1983 internal audit _
schedule.
In response to the NRC finding in Inspection Report 83-09 Edison' acknowledged that Comstock did not fully implement its 1983 audit schedule. Thus, in this instance the NRC identified
! a concern not previously identified by an Edison audit conducted within 90 days of the NRC's first site inspection visit. It should be noted, that it was not the intent of audit 20-83-20 to review the Comstock corporate audit schedule which was designed to accomplish verification.of the entire Comstock Quality Assurance Program as prescribed by the Quality Assurance Manual.
(3336A)
_ - _ . _ _ . . _ . _ _ _. . . ~..___. _ _ ._ . _ _ . _ _ _ . __ _ _ _
Page 13 Further, Edison Site Quality Assurance actually bucame aware of the Comstock shortfall subsequent to audit 20-83-20, but l_
i l prior to the start of the NRC inspection visit. Awareness of i this situation ultimately led to the resolution of the j problem. The Comstock Quality Assurance Engineer responsible for these audit activities at the time officially resigned from Comstock in July, 1983 and his position was filled by R. Seltmann l in September, 1983.
Although Comstock audits were not conducted as scheduled, adequate Commonwealth Edison Quality Assurance audits were j performed to cover all applicable Comstock activities. During i
the inspection visit, the NRC acknowledged that Edison Quality Assurance provided adequate quality audit coverage and that f Site Quality Assurance was previously aware of the Comstock -
failure to conform to its annual audit schedule. The resolution of the NRC's concerns regarding Comstock auditing i
are detailed in the response to specific Interrogatory 58 and 59, contention item 14.B.2.
! In conclusion, five Edison audits conducted within 90 days of the first site-inspection visit identified in the various
) inspection reports which were the source of the various Quality i
{ Assurance subcontention items were founo potentially not to
'. note a concern later identified by the NRC. However, Edison l believes that in four of the five identified audits, differences in items reviewed by Edison and by the NRC or (3336A) l_ _ - __ __ ..
Page 14 differences in interpretation of Q.A. requirements held by Edison and the NRC indicate that Edison did not perform faulty audits. Only in the case of audit 20-83-20, with respect to Comstock site audit schedules, did Edison actually not identify the concern identified by the NRC and, in this instance, Edison has taken sufficient corrective action to ensure that the concern identified by the NRC has been resolved.
Commonwealth Edison Quality Assurance has also focused considerable effort on improving its audit program at Draidwood during 1984 and 1985. Edison's commitment to comprehensive auditing was reaffirmed when it assigned an experienced individual as a full time site Audit Coordinator to provide .
guidance to the audit teams, assure consistency of the audit process and participate in the evaluation of audit results. A series of feedback sessions with auditors to identify methods for' improving the audit process have enhanced the depth and thoroughness of Site Q. A. audits and established auditing as a priority activity. Pre-audit preparations have been enhanced by formalizing pre-audit activities, placing greater emphasis on audit checklist preparation and more clearly establishing audit objectives. During the course of the audit, the lead auditor's involvement with the audit team and with the review i of potential deficiencies has increased. Postaaudit team
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(3336A) l I. .
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Pagd 15 debriefings prior to the exit meeting have been expanded to more completely evaluate compiled objective evidence and audit results, thereby assuring that the audited areas are fully addressed. Increased emphasis is now placed on establishing agreed upon corrective actions during exit meetings and to provide for prompt initiation of corrective actions. Finally, Edison has expanded its audit reports by requiring more complete documentation of evaluated areas and assessment of program implementation.
The effectiveness of Edison's audit program, including audit reports, schedules, and follow-up to audit findings, was examined by the NRC CAT inspection team in December 1984 -
(Report 84-44). This inspection determined that the Site Quality Assurance Audit Program is comprehensive and capable of identifying both implementation and programmatic problems.
(3336A)
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d s
UNITED STATES OF AMERICA -
NUCLEAR REGULATORY COMMISSION l
t In the Matter of: )
COIOGONWEALTH EDISON COMPANY )
i ) Docket Nos. #50-456 (Braidwood Nuclear Power ) #50-457 Station, Units 1 and 2) )
i f Affidavit of Euaene E. Fitznatrick I, Eugene E. Fitzpatrick, being first duly sworn, hereby depose and otate as follows:
I
- 1. I an employed by Commonwealth Edison Company as Assistant Manager of Quality Assurance.
3 2. My business address is Braidwood Nuclear Power Station, Braceville, Illinois 60407.
- 3. I jointly supervised with Mr. Thomas E. Quaka the review of j Commonwealth Edison Site and Corporate Quality Assurance audits conducted in preparation for responding to Specific In'terrogatory No. 35 filed by Intervenors Rotes, 31. A1 I l also jointly prepared with,Mr. Quaka the response to specific Interrogatory No. 35.
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! 4. To the best of my knowledge and belief, the statements
! contained in the response to Specific Interrogatory No. 35 of 4
Intervenor's First Set of Quality Assurance Interrogatories -
and Request to Produce are true and correct.
I Further affiant sayeth not.
_f g+tL ~
l l EUg4ne E. Fitzpatrick i Subscribe 4 sworn to before Co this D , day of September, 1985
~
N E, -
I Nytary Public V My Commission expires on b .
! 3352A i
f l (3352A)
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of: )
COMMONWEALTH EDISON COMPANY )
) Docket Nos. #50-456 (Braidwood Nuclear Power ) #50-457 Station, Units 1 and 2) )
Affidavit of Thomas E. Quaka I. Thomas E. Quaka, being first duly sworn, hereby depose and state os follows:
- 1. I an employed by Commonwealth Edison Company as Site Quality Assurance Supervisor at the Braidwood Station.
- 2. My business address is Braidwood Nuclear Power Station, Braceville. Illinois 60407.
- 3. I jointly supervised with Mr. Eugene E. Fitzpatrick the review of Commonwealth Edison Site and Corporate Quality AsHurance audits conducted in preparation for responding to Specific
- Interrogatory No. 35 filed by Intervenors Rotem, 31. al. I also jointly prepared with Mr. Fitzpatrick the response to i specific Interrogatory No. 35.
- 4. To the best of my knowledge and belief, the statements l contained in the response to Specific Interrogatory No. 35 of ~
Intervenor's First Set of Quality Assurance Interrogatories and Request to Produce are true and correct.
Further affiant sayeth not.
1 .
Thomas E. Quaka, Subscribed sworn to before to this t ay of September, 1985
- A. M 1A k."
Notary Public My Commission expires on cb 3352A i
l (3352A) l l *
'. '. y ,. l . ..---- ..- -_ _ _ .
Q,P. FORMla_1.r,2 DATE SA S1 QUALITY ASSURANCE MANUAL AUDIT REPORT ,
QA-20-83-25 Type Audit: - @ gram Audit U Product Inspection Point O ecords / /Special ,
To: J. Carlson Project Braidwood Visit Date 5/12-29 /83 Report Date 9-31-83 System N/A Component Identification N/A Material Description N/A Vendor Phillins. Getschow Co.
Location Braidwood Subcontractor N/A Location N/A Contacts See Attachment " A" t- P.O. No. 1943h9 Spec. No. L-2739 Recommended Inspections: 6 mos. J. mos 1 no _
Other: As Scheduled i
Notes: The auditee is required to respond in writing to the Findings and Observation .by 6-17-83 Lead Auditor k =1 d /m M 4 6 Date 6 #
3 Auditor S L . /b_A , Date 6-7-83 Auditor [rI /IJ7f 2 (Ow Date 6-2 M Auditor $ _ $ s 6 .- x / Date 4 ~8-9 5 Auditor h/n/f d M ore w De e (, -P J 3 Reviewed /. [ d w / a to 8' W SLC/nic /_ . . #
cc: Manager of QA, Director of QA (Engr-Constr)
Site Constr. Supt.
Site Quality Assurance /2 l
Project Manager Project Engineering Mgr.
/ Manager of Projects Auditee- 35 B00066c'y e
. s.
. Commonwealth Edison Co.
Quality Assurance Audit Phillips, Getschow Co.
Audit DQA-20-83-25 Braidwood Station May 31. 1983 1
The Commonwealth Edison Quality Assurance Department conducted a scheduled audit beginning May 12 and concluding May 25, 1983 to
! verify that Phillips, Getschow Company was properly implementing I their Quality Assurance Program. The audit covered the below listed areas:
- 1. Large Bore Pipe Installation
1973 (ANSI N45.2.1 - 1973)
- 3. Personnel Qualifications (Reg. Guide 1.58 -
1980)
- 4. Wold Rod Control
- 5. Storage Control
- 6. .ASME Code Inspection (Q.A. Manual Section 12)
- 7. Calibration Control (Q.A. Manual Section 13)
- 8. Test and Inspection Control (Q.A. Manual Section 14)
An entrance meeting was' held on May 12, 1983. with the audit commencing immediately afterward. The audit was completed and an exit meeting was held on May 25, 1983, and a post audit discussion was held on May 27, 1983. Auditing was not performed during the period S/16-18/83 due to a combination of scheduled vacation days taken by the audit team members, and scheduled offsite training. A list of those attending these meetings is included on Attachment "A".
As a result of the audit, five (5) findings and one (1)
. observation were identified. These items are briefly listed below and are described in detail on Attachment
~
I "B".
1 Findinc #1 Nonconformance reports were not generated for testing and
! measuring devices found out of calibration and an outdated calibration procedure was in use.
1 Findine #2 l
l Welders were observed making joints in excess of the thickness
! specified in PGCo welding procedure IA-MA-11-N. Also, this procedure did not have end gap fit-up dimensions listed.
I Findine #3 Travelers for several welded and bolted connections made in the plant could not be produced.
(00640)
B000GG23 l
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-QA-20-83-25 Page 2 Findine #4 4
Weld edge prep inspections were not being made by PGCo Q.C. for edge props cut by PGCo.
. 1 Findina #5 Qualifications of. inspection personnel did not meet ANSI N45.2.6 and CECO site requirements in several. areas.
-y, ,, e . +
observation #1 Adequate measures were not taken in some cases to insure that internal cleanliness of stored and installed piping system components.
l ASSESSMENT
! The areas audited, with exception of the deficiencies identified, appear acceptable and PGCo is properly implementing their Quality Assurance Program and the Regulatory Guides mentioned r above.
Large bore piping installation appears to be satisfactory.
welders qualified to the procedures and thickness ranges they used in the field, acceptable and appropriate material was used for j welded connections observed in the field and Q.C. hold points were ;
being implemented as required. Other than the deficiencies noted, the maintenance of cleanliness for piping systems was being performed by pGCo during piping system installation. Q.C. personnel qualification appeared to be consistent with ANSI N45.2.6 and i
Braidwood Site requirements and adequately documented with the exceptions noted in the audit deficiency. Wold rod control, test and inspection control, storage control and ASME Code Inspection interfaces appeared to be adequate and in compliance with PGCo 0.A.
~
Manual requirements.
The audit team would like to extend their appreciation to PGCo for their assistance and cooperation during this extensive audit.
l By copy of this report, PGCo is required to respond in writing on or before June 17, 1983. The response shall indicate the corrective action'taken, the date of corrective action initiated to i prevent recurrence, and the expected date of corrective action implementation. Please send your response to Mr. T. R. Sommerfield.
l Q.A. Superintendent. Braidwood Station with a copy to M. A. Gorski,
! Lead Auditor.
i Reported by: 61. btk #1N$b ate: b-A-83 Accepted by: 777 7/ date:M 3
! (00640) / / /
_ - - -BoeCGG-29 l
.. e' Attachment "A" 1
Entrance Meetina: 5-12-83 Name Company Decartment
- S. L. Clark
~
Ceco QA
- W. J. Marcis CECO QA
- K. A. Miller Ceco QA
- E. T. Mazur Ceco QA Exit Meetina: 5-25-83 Name Comoany Decartment
_ *M. A. Gorski Ceco QA ,
A. Rubino PGCo QC Post Audit Discussion: 5-27-83 Name comoany Denartment _
- M. A. Gorski Ceco QA .
J. Carlson PGCo QC H. Beyer PGCo Production S. C. Hunsader Ceco QA
- K. A. Miller CECO QA
- Denotes audit team ,
(00640) l Bucc 6600
t -
4 Attachmont "B" Findine #1 Contrary to 10CFR50 Appendix B Criterion KII and the PGCo Q.A.
Manual'Section 13. NCR's were not always generated for inspection equipment found out of tolerance and torque wrenches were found not being calibrated in accordance with the latest approved procedure.
, c. ir .
Discussion v c. .
.- c ., . ,..
10CFR50 Appendix B Criterion XII states. " Measures shall be established to assure'that' tools, gauges, instruments, and other.
measuring and' testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary li'mits".
The PGCo Q.A. Manual Section 13.1 requires the use of written calibration procedures for tools, gauges, and other testing devices that affect quality.
Contrary .to the above requirements, the following items were observed. .
A. Pyrometer CP-Ol sont-out for calibration was returned with "as found" data which showed it to be more than 6% off. .The Manufacturer's specification is 11%. It was calibrated 1-31-83. No nonconformance report as required by Section 31.2 of the PGCo Q.A. Manual (white pages of the QAM were then in effect) was written.
B. Pyrometer CP-02 same as above. -
C. Torque meter T.M.-5 was listed in the PGCo Calibration Log as having a broken needle on 5-25-82. The instrument had been used on 5-6-82. 5-10-82 5-12-82 and 5-17-82. No nonconformance report had been written in accordance with Section 13.2 of the PGCo Q.A. Manual in effect at that time.
D. Dial indicator PG 7MW was listed in the mi11 wrights calibration log as sent out for repair on 4-18-82. The instrument had been used on 4-12-82 4-13-82. 4-14-82 and 4-15-82. No nonconformance report had been written in accordance with Section 13.2 of the PGCo Q.A. Manual in effect at that time.
E. The latest CECO approved PGCo procedure for torque wrench calibrations is QAP 7.4 Rev. 2. It was observed that Revision 1 of this procedure was still in use although Revision 2 had been approved since 1-28-83.
(00640)
B0006631
e 4
Attachment "B" Page 2 F. Torque wrenches were not calibrated in both directions as required by QAP 7.4 Rev. 1 Sections 6.9 and 7.4.
G. Section 13.2.1 of Revision 13 to the Braidwood Supplement (pink pages) of the PGCo QAM states the a deviation report shall be generated in accordance with Section 15 of the manual"if a piece of inspection equipment is found to be out of calibration. Section 15 of PGCo Q.A. Manual does not address deviation reports.
Note, it was observed that the torque wrench calibrations reviewed during the audit appeared to be technically correct and adequately documented.
Findine #2 Contrary to lOCPR50 Appendix B Criterion V, PGCo welding procedure IA-MA-11-N Rev. 10 did not define fit-up requirements.
Also, welders were observed installing GTAW portions of welds in excess of the thickness specified in the procedure.
Discussion 10CFR50 Appendix B Criterion V states, " Activities affecting quality shall be prescribed by documented instructions, procedures.
or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions. Procedures, or -
drawings. Instructions. Procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished". .
Contrary to the above requirements. PGCo procedure IA-MA-11-N Rev. 10 did not contain limiting gaps for the edge to edge fit-up of welded pipe joints. Furthermore, page 4 of the procedure states that the first two weld passes will be done by the GTAW process and*
the remaining passes will be done by the SMAW process. Page 10 of the procedure which is the Welding Procedure Specification (WPS) for IA-MA-11-N dated 6-8-78 under Base Metain states that 1/8" deposit will be made by GTAW and the tenainder SMAW. Contrary to this welding procedure, welder ID #512 was observed completing all passes of weld 9G-67-FW7CA by the GTAW process. The wall thickness of the weld was .216 inch (3 inch diameter schedule 40 pipe). Review of the Procedure Qualification Record (PQR) for IA-MA-ll-N and ASME Section IX paragraph QW2Ol.3 indicates that the procedure is qualified to .250 inch thickness for GTAW.
(OO64Q)
B00CSG32 _-
Attachment "B" Page 3 ,
Findine #3 Contrary to 10CFR50 Appendix B Criterion XIV and the PGCo Q.A.
Manual Section 5. travelers indicating the production and inspection status.of.some bolted. connections and welded joints could agt be performed during the course of the audit.
Discussion . .eg ; ; m o ; ..w t v . . . . . , ( . 3 -.
t 1. , r t L C C :. . t h i .: ;n
~~'t_O..
10CFR50 Appendix B Criterion XIV states in part. " Measures shall be established to indicate, by the use of markings such as stamps, tags, labels, routing cards, or other suitable means, the status of inspections and tests performed upon individual items of the nuclear power plant and fuel reprocessing plant. These measures shall provide f or the ' identification of : items which have satisfactorily Passed required inspections and tests, where necessary to preclude inadvertent bypassing of such. inspections and tests".
-The Phillips. Getschow Q.A. Manual Section 5.3.1 (Braidwood Supplement) states in part. "On all field ~ installed, items, except whip restraints and those falling under the requirements of
- Subsection NF (Component Supports) the Field Engineering Department shall prepare for each weld a Field Fabrication process and Data Sheet (Form PG 119-5. Ex. 18) for each bolted joint, a Mechanical Joint Checklist (Exhibit 18G)".
Contrary to the above requirements the following traveler ,
packages could not be produced during the course of the audit.
Field Fabrication Process and Data Sheet (Welds):
i CC-31 FW-3A Mechanical Joint Checklist (Bolted Connections):
SX-18F4 CV-36F4 CC-17P3 SX-5F3
- CV-10F3 SX-SP7 SC-5F9 Findina #4 Contrary to 10CFR50 Appendix B. Criterion IX & X which states in part. " Measures shall be established to assure that special processes, including welding...are controlled and accomplished...in accordance with applicable codes, standards, specifications.
criteria. and other special requirements"; PGCo Q.A. did not perform a geometrical inspection for a weld prep prepared by PGCo to determine if the weld prey was in accordance.with the welding procedure.
i (00640) l B0006633
Attachment "B" Page 4 Discussion A Phillips, Getschow Q.C. inspector was observed inspecting for l Fabrication Requirements for weld #FW-28 FW-5-1 which includes an inspection of the weld end prep. The inspector visually observed the end prep for indications however no measuring devices were used ,
to check the end prep geometry to verify if it was in accordance l with the welding procedure. The weld prey was prepared by PGCo. l therefore. this inspection should be made.
Findine #5 Contrary to 10CFR50 Appendix B Criteria II which states in part.
"The (Q.A.) program shall provide for indoctrination and training of o personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained."
Criteria V which states in part, " Activities affecting quality shall be prescribed by documented instructions...and shall be accomplished in accordance with these instructions." and Criteria XVII which states in part, " Sufficient records shall be maintained to furnish evidence of activities affecting quality..." Phillips, Getschow Co.
qualification of inspection personnel,was not properly implemented in accordance with Ceco directives and documentation of personnel qualification was found to be incomplete' or illegible.
Discussion A review of the qualification records of PGCo non-NDE inspection personnel was conducted and the following items were observed to be deficient:
- 1. The conditional waiver of the on the job training as
. delineated in CECO letter BRD #7272 which had been intended for inspection personnel with significant previous Braidwood inspection experience had been requested for inspection personnel with minimal inspection experience at the Braidwood site. The following personnel in question are as follows:
J. Emond 3 months
- q D. Grachen 3 months
- j J. Johnson 2 months
- 1 C. Tazelaar 2 months * ]
R. Shannon 3 months
- E. Shue 3 months
- l G. Linick 3 months
- I W. Balmes 3 months *
- Experience at Braidwood prior to procedure revision )
incorporating CECO qualification minimum requirements. )
l (0064Q) !
B0096634 l_. & _ _ . - _ _ .__ _ ___ _ __ _ _ - . .
~: ~
+
Attachment "B" Page 5 t
This resulted in the inspectors not receiving the minimum O.J.T. for each area of certification as delineated in PGCo
, procedure QCT 20.15.
- 2. The amount of verified experience used-for the basis of certification did not equal the minimum requirements of N45.2.6-1978 Section 3.5. the objective evidence of previous experience was not available. This amount varied per inspector. however it was observed for 19 of the 27 inspectors reviewed.
- 3. The records of training session contained in the qualification records were reviewed. The older records did not have the duration of the sessions documented. therefore itformal couldtraining not be verified that the correct number of hours of were received.
- 4. During the review of training session records contained in the inspector qualification records it was observed that several records were illegible. A review of the originals of these records found that the originals were legible.
Observation #1 Contrary to 10CFR50 Appendix B Criterion XIII. Reg. Guide 1.37 ANSI N45.2.1-1973 and Specification L-2739 Section 305.5 and Form 1
278-A. cleanliness and protection of stored and installed piping has -
not been maintained in all cases observed.
l .
Discussion lOCPR50 Appendix B Criterion XIII states in part. " Measures '
shall be established to control the handling, storage. shipping, cleaning and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration".
ANSI N45.2.1-1973 which is endorsed by Regulatory Guide 1.37 states in part in section. "The installetion process represents an opportunity for the introduction of contaminants into a cleaned item and care should be taiten to minimize contamination. Operations which generate particulate... controlled. Local cleanup of I contaminat d areas is recommended as installation progresses. rather than one cleanup operation when installation is completed.
Consideration should be given to sequencing installations and erection operations, when practical, to facilitate cleaning and cleanliness control. Where visual inspection of internal surfaces of a portion of a system can be blocked. that part of the system 1 should be fabricated as a complete unit and a visual inspection should be performed just before the access points are closed.
(0064Q) ,
i B9006635
. .. . . . -._ -. .- - - . - . . . ~ . .._. .
a Attachment "B" page 6 l
l 1
Openings and pipe ends shall be sealed at all times except when '
they must be unsealed to carry out necessary operations. Fitted and
- tack-welded joints (which will not be immediately sealed by welding) shall be wrapped with polyethylene or other nonhalogenated plastic film until the welds can be completed".
S & L Speci'fication L-2739 Section 305.5 states in part.
" Contractor shall maintain in place the temporary closures on all open ends of the piping during erection. as far as possible, until permanent closures are made. Contractor shall ensure that temporary closures and protective devices are securely attached to all open terminal connections to prevent entry of foreign matter, until permanent connections and closures are completed".
Form 278A in S & L Specification'L-2739 states in part (Section 4.3). " Materials shall be handled, stored and protected in such a manner as will prevent damage to it and prevent entry of foreign material and moisture.
Contractor shall- ensure that all piping openings are provided
- with temporary protectors securely attached and sealed, up to the
! time of field fabrication or erection.
For piping field fabricated by Contractor, all openings of the fabricated piping and remaining cut pipe shall be provided with protectors, as soon as possible after cleaning. protectors shall be similar to those specified in Subarticle 4.3.1 above and shall _
remain in place until removal is necessary for connection thereto.
Contractor shall, at the end of each working day, ensure that all remaining openings in piping erected by him and all new openings l made by him in existing piping are provided with temporary protectors".
Contrary to the above requirements the following items were observed.
i A. Outdoor Storage
- 1. Carbon steel pipe material west of turbine building by heater bags in sand. Some stainless steel pipe stored in this area was not capped.
- 2. Carbon steel pipe material north of aux. b1dg. by condensate polisher bldg. was not capped.
(0064Q) i 1
g.)ci.'.6636 t .
4 Attachment "B" Page 7 B. Indoor Storage Location Item condition El 380 S+23 U-2 Curved Wall CV-18-11 not capped CV-28-15 not capped El 364 Y+23 U-2 Curved Wall Valve 2SI8806 damaged end cap Valve 2SI8927 damaged end cap El 364 2CVO2P Pump Room msc SS spools not capped El 364 U-2 Curved Wall Area SI-40-14 stored on floor SI-38-10 stored on floor El 346 near pump 2CSOlPB CS-17-2 not capped U-2 Curved Wall Area CS-16-11 not capped This represents approximately 15 - 20% of the total items -
reviewed. ,
C. Installed Items ,
Location Item Condition 346 El U-2 Curved Wall Area SX-20 not capped 401 El U-2 Curved Wall Area Fit-Up Joint on not covered CS-19-5 383 El. P & 19 SX88-2 hole in end cap 383 El. U-2 Aux. Feedwater Branch on Exhaust not capped Diesel Rm. Line 383 El U-2 Aux. Feedwater Flex Hose to Pump hole in tape Diesel Rm.
364 El. 2CVOlPA Pump Room CV Lina to Pump not capped N& 19 mac lines in room not capped 364 21 2CVO2P Pump Room W Check Valve not capped S/N 0272 364 El U-2 Curved Wall Area Penetration not capped 71 & 73 l 364 El U-2 Curved Wall Area 16-3 sht. 3 not capped (0064Q)
D3006637 .
. r ,' , .
Attachment "B" l Page 8 Location Item condition 346 El near 2CSolPB CS-95-A not capped "T" connection on not capped CS-17-4 3" Branch on not capped 2ACS-16-2 346 El near 2CSOlPA Vertical Line not capped through Cieling This represents approximately 15 -
20% of the items reviewed.
D. During the pre-weld inspection of joint SX47-2FW1. The O.C.
inspector made the manditory cleanliness inspection 2 inches on either side of the weld area as required by PGCo procedure VE-01. Further investigation made by the auditor discovered a significant amount of metal shavings and powder in spool piece SX47-2 further along in the pipe. The spool
, piece was cleaned during the course of the audit.
h e
I i
5 (00640)
B0006638
ga e CHECKLIST AND RECORD SHEET BRAIDWOOD STATION AUDIT NO. CA-20-83-25 AUDIT OF: Phillies. Getschow Co. Page 38 of 46 Checklist Prepared By: M. A. Gorski. S. L. Clark. E. T. Mazur. W. J. Mare K. A. Miller Lead Auditor: M. A. Gorski Auditors: S. L. Clark. E. T. Mazur. W. J. Marcis. K. A. Mill P.G.co. Q.A. Manual Rev. 4 dated 4-21-81 Braidwood Addenda Rev. 13 dated 1-3-83 No. / Ouestion / Reference / Ace / Def / N/A
- 38. Verify that Quality Control 10CFR50
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CHECKLIST AND RECORD SHEET l BRAIDWOOD STATION AUDIT No. OA-20-as-2R' 1
AUDIT OF: Phillins. Getschow Co. Page 1 of 46 DATE: May 12. 1993 -
-- Approved: /
_. .. .- Date:
-Checklist Prepared By: M. A. doraki 8. L. Clark. E. ?. Mazur. W. J. Ma r e i' K. A. Miller 7-
= Lead Auditor:~ M. -
A. corski
~
Auditors: S. L. Clark. E. T. Mazur. W. J. Marein. K. A. Mille!
P.G.co. Q.A. Manual Rev. 4 dated 4-21-81
-Braidwood Addenda Rev. 13 dated 1-3-83 No. / O'3 e s t i on
/ Reference / Ace / Def / N/A
'1T ~'
Verify that a pror.ierly completed P.G.co.
stores request is present in the QAM Section 8.3
.. ,.~ ._ pipe installatioa package for the 10CFRSO n'.4 ,/~f//j*!' j, spools or materials being welded. Appendix B e
Criterion VIII
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.EEEEEIEEEEEEEEEEEEEEEEEEEE
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i CHECKLIST AND RECORD SHEET 5 BRAIDWOOD STATION AUDIT No. OA-20-83-25 AUDIT OF: Phi 111Ds. Getschow Co. Page 2 of 46 Checklist Prepared By: M. A. Gorski. S. L.
~
Clark. E. T. Mazur. W. J. Marc K. A. Miller Lead Auditor: M. A. Gorski Auditors: S. L. Clark. E. T. Mazur. W. J. Mareis. K. A. Mill P.G.co. Q.A. Manual Rev. 4 dated 4-21-81 Braidwood Addenda Rev. 13 dated 1-3-83 No. / Cuestion / Reference / Ace / Def / N/A
- 2. Verify that base materials are IOCFR50 p ,.gchecked for accepta3111ty.,rior A,,endix a to welding. Criterion VIII
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CUALITY A00URANCE MANUAL :
. . ,, AUDIT REFORT --
. ' \
- QA-20-84-552 I
Type Audit:
i
, h / Program Audit / / Product Inspection Point C Records ,
M Special ,
i .
To. Tom O'Connor Jack Carlson g_gg 'g Project Braidwood Visit Date 11-6 to Report Date 11-26-_84
. System N/A Co=ponent Identification N/A '
Material Description M/i Vendor Phillips Getschow Co. Location Braidwood 4
Subcontractor N/A Location N/A ~
i Contacts See Attachment A ~
1 P.O. No. 1'qh to Spec. No. 973o j Reco== ended Inspections: .5 :.x eas 1 .& . . . ,
Other: As scheduled Notes:
i " Response reqdired by 12-12-84. PCD should perform '
the PM-04 review of the findings for possible reportability,~
and forward the results to site QA for inclusion in our Auditor a w -
Date //!J7!8Y '
Auditor I N W Date " 27 # '
i Auditor [I M l /[td/> ~ ' '
- Date N/6T/JV
- Lead Auditor. 41f,. b hderwle./ b .
Date il /J8/#7
[ Reviewe Date //!c2P'!f(C/
cc: Manager of 0.A. -
Director of Q.A. (Er.gr-Constr)
Site Constr. Supt. ,
Site Cuality Assurance /3 Project Manager , ,
Project Engineering Mgr. ..
Manager of Projects ,
i Auditee ~
i AMM .
s'c H ue.4 Cant A%t GA AT.
e ce
- maen Jun
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---. -- E_- -. -. .
i .
COMMONWEALTH EDISON CO.
QUALITY ASSURANCE DEPT..
AUDIT OF PHILLIPS GETSCHOW CO. l
- QA-20-84-552 l Introduction & Scope.
The Commonwealth Edison Co. site Quality Assurance Dept.
conducted a scheduled audit of Phillips Getschow Co. (PGCo) at the Braidwood site November 5-9, 1984. The purpose of the audit was to determine if PGCo is effectively implementing it's approved Quality Assurance program.
The audit checklist consisted of twenty-three (23) questions which were developed from the references listed in the following audit scope:
Activitv/ Area Reference
- 1) Nonconformance/ Corrective Quality Assurance Manual Sect. 15 Action
- 2) Audits Quality Assurance Manual Sect. 15
- 3) Component Support Design / 10CFR50 App. B Crit. III Field Changes .
- 4) Component Support Storage ANSI 45.2.2 QCP-B4
- 5) Component Support A Installation 10CFR50 App. B Crit. V QCP-B23A B QC inspection 10CFR50 App. B Crit. X QCP-B23 C Concrete Expansion Anchor Installation PGCP-10
- 6) Whip Restraint -
A Installation PGCP-18 B QC Inspection PGCP 18 10CFR50 App. B Crit. X' C Material PGCP 18
- 7) QC Inspector Certification Reg. Guide 1.58 ANSI 45.2.6
.The audit team consisted of the following personnel:
A. M. Montalto - Lead Auditor E. S. Steckhan - Auditor R. M. Sacco - Auditor C. A. Hayes - Auditor An entrance meeting was held on November 5, 1984 in the PGCo site office and the exit meeting was held on November 9, 1984 in the CECO site PCD Meeting Room. Attachment "A" lists entrance and exit attendees and personnel contacted during the audit. One question was determined to be not applicable at the time of the audit. This '
question covered the adjusting of constant supports. This function will not be performed until the hot line walk down is performed.
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- B0008655 l
4 ,. ,
- QA-20-84-552 Page 2 One (1) Finding, two (2) Observations and three (3) Open Items were identified as a result of this audit. A brief description of each deficiency is given below. Attachment B includes a detailed discussion of each Finding, Observation and Open Item. In addition to the above. a deficiency was identified pertaining to larger snubber assemblies received, disassembled at the site, and then I
assembled using the appropriate torque value. No documentation was available for review to conclude the proper torque value was applied. This item was not issued as a deficiency within this report since subsequent to the audit exit, PGCo personnel produced a internal site audit that' identified the torque deficiency issue. A PGCo nonconformance report was not issued however, the audit '
deficiency did address a corrective action to prevent recurrence and corrective action to address past work (Retro program for snubbers via the final line walk procedure). Also the PGCo Corporate office performs a trend analysis on all site audit deficiencies.
Deficiencies Identified Findinc #1 ,
i Corrective action for one PGCo audit finding (Audit BR-3 Finding #3) did not go far enough in addressing or evaluating the corrective action for past work.
Observation #1 .
One additional weld not specified on the design drawing was -
incorporated into the pipe whip restraint installation however, no installation or inspection records were documented.
Observation #2 No documentation exists to verify that snubber jam nuts were torqued to the appropriate values required by the approved procedure QCP-B23A Rev. O at the time of installation.
General Evaluation Non Conformance Reports (NCR) and NCR Corrective Action NCR's were reviewed and it was verified that the QC supervisor verifies Corrective Action prior to close-out. Also material lacking proper documentation is being identified with a Hold tag and segregated until properly dispositioned. Finally, it was determined that the PGCo Site Manager provides a timely response to PGCo NCR trends identified by their QA Manager. Based upon the results of the items reviewed during the audit. PGCo is implementing their NCR program in accordance with their QA Manual.
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_ . _ =- - . - . . . _ - . - -. - .- - - - -
o L 1
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- QA-20-84-552 Page 3
]
Audits -
p -
' . . _t <,1 ; ,jo ,
. - PGCo_ Sitee and Corporat.eu l984 audi.ts were reviewed,and it was verified that applicable sections of the QA Manual-and associated procedures are being audited. Additionally, the audit deficiencies identified on the PGCo Site audits were reviewed to verify that corrective action is performed in a timely manner. Both of these ,
items were found to be implemented in an acceptable manner.
However, duri.ng the review of PGCo 1984 Site Audits one of the thirteen-(13)-deficiencies revi'ewed appeared.to be a case where the corrective action implemented did not go far enough to address adequate corrective action for past work. This item will be j - addressed in detail as Finding #1, in Attachment B, and is discussed j further in the assessment portion of this report.
- h: 1 -
Desian Chances for* Component Supports s A random sample of field problem reports were reviewed. It was determined that the appropriate design review was being performed-in all cases observed. Based on the above it was determined that design changes for component supports are being performed in an i acceptable manner.
i
- Material Storace
! Material storage was focused on PGCo's Handling and Storage of snubbers. Snubber stcrage was reviewed at 3 storage warehouses and -
found to be in accordance with PGCo Procedure QCP-B4 and ANSI N45.2.2. Based upon the items reviewed PGCo is properly
, implementing their program and snubber storage is acceptable.
iI Component Support Installation /OC Inspection A partial field reinspection of three (3) snubber installations i and seven component support installations (including sway struts, l trapeze, constant and rigid types) was performed during the course of this audit. Certain attributes such as size of components, location, angularity, mechanical connections, material traceability, clearances, auxiliary structural steel and welding were verified to meet the applicable design drawing requirements. However, documentation to substantiate the acceptability of torque values for snubber jam nuts was not available for review. This item is detailed as Observation #2 in Attachment B and is further discussed
.in the assessment portion of this audit. Also a Open Item was issued pertaining to damaged load scales on constant supports. It
.was determined not to be deficiency primarily because this attribute will be reviewed during the final line walk when adjustment will be l made if necessary. This issue is detailed as open item #1.
I These supports which were verified to meet the design drawings were previously inspected and. accepted by PGCo QC. Therefore QC Inspections were determined to be acceptable in this regard. ggpoGG5'7
_ ( 03 'i 8 Q ) _ ,_ _. _, __ ___ _, _ , _ _ _
- QA-20-84-552 Page 4 Concrete Expansion Anchor (CEA) Installation In-process and. completed CEA's~ installed under the newly revised pGCP 10 (revision 16) procedure were examined for proper QC verification and adherence to design drawing and BY/BR/CEA 4
requirements. QC Inspectdrs contacted during the audit appear to be well versed in the requirements and in generating in-process deficiency repo'rts (9006 form) where necessary. Also all traveler documentation reviewed was accurate and appropriate. This indicates acceptable implementation of the new CEA program.
Whip Restraint Installation /OC Inspection / Material This area was examined by overview on QC inspections, field re-inspections and review of quality aspects documentation. Overall this area was determined to be acceptable based on the fact that the installations checked were in adherence to design drawing and PGCo requirements with the exception of one weld added to a whip restraint which did not include the proper installation -
documentation. This item is detailed in Attachment "B" as Observation #1. -Also an area of concern that was determined not to be a deficiency was the manner in which PGCo uses the G. K. Newberg surveyors for whip restraint as-built drawing / sketch and final quality control verification. This item is detailed as Open Item #2 in Attachment "B" of this report.
Whip restraint material traceability was examined and was found -
to be in compliance with the PGCo program requirements.
A review of whip restraint installation process sheets found that the proper welding procedures-have been assigned for the materials welded. In addition PGCo is recording weld rod heat numbers and welder symbols on the appropriate' form namely - rod tickets and installation travelers.
- OC Inspector Certification For Vfsual Weld Inspectors Previous certification requirements for PGCo visual weld inspectors (VWI) did not include provisions to consider all the requirements of ANSI N45.2.6. A sample of inspector certification packages was reviewed and it appeared that the inspectors experience met the intent of ANSI N45.2.6. Nonetheless this item is being issued as an open item requiring a review of all past VWI certification packages to ensure the minimum experience level of 45.2.6 is met. Also it will be necessary to address other differences between the PGCo procedure and ANSI N45.2.6. This item
- is detailed as Open Item #3. >
/ 1 (0358Q) 4
, BOUCGGS8
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+
- QA-20-84-552 Page 5 Assessment Audits
. PGCo Audit #84 BR-3 Finding #3 identified the following deficiency: The weld supervisor did not establish the storage temperatures of electrode holding ovens. The audit deficiency corrective action (C/A) as implemented required the welding to supervisor,'s.
temperature provide Therethe wasmanufacturers recommended no documentation availablestorage for review to determine whether or not any weld rod was stored below recommended temperatures nor was there any evidence that this was evaluated.
This appears to be a case where the C/A did not go far enough to address past work. Therefore an assessment on the impact for the PGCo audit deficiency cannot be made until it is determined whether or not weld rod was stored below the recommended temperatures. In regards to the deficiency identified during this audit (inadequa'te ~
corrective action) the audit team took issue with the C/A for ~
_ finding #3 (84 BR-3) however, we feel that this is a isolated -
incident based on the acceptable results from reviewing corrective action for other 1984 PGCo audit deficiencies.
Overall Assessments Excluding the areas in which deficiencies were identified it was determined that overall the PGCo personnel are adequately -
implementing their QA program for areas reviewed during this audit.
i
Response
A written response to each deficient item noted in Attachment "B" is required by December 12, 1984. The response should be addressed to T. E. Quaka, Q.A. Superintendent. Braidwood Station, copy-to A. M. Montalto,-O.A.' Inspector, Braidwood Station and shall address Corrective Action Taken, Action Taken to Prevent Recurrence, and date all action will be complete, for each item noted. For the open items document a discussion of the action taken to address each item and a date by which this action will be complete.
[ (03580) ggt '.L'UUO l
ATTACHMENT "A" Page 6
- QA-20-84-552 ENTRANCE MEETING 11-5-84 A M. Montalto CECO Lead Auditor R. J. Farr CECO PCD D. Boone CECO PCA R. E. Waninski CECO QA Engineer R. M. Sacco CECO Auditor G. A. Donaldson PGCo Staff Eng.
F. Fato PGCo Asst. QA Coord.
W. Salealewsk PGCo Lead QC Tech.
J. Stewart PGCo Project Eng.
G. M. Galloway PGCo Eng.
E. S. Steckhan CECO Auditor G. Marquardt PGCo QC K. S. Erickson PGCo QC J. M. Murphy PGCo Admin. Asst. Supv. QC R. D. Murphy PGCo Asst. QC Supv.
C. A. Hayes CECO Auditor - -
^ . EXIT MEETING 11-9-84 A. M. Montalto CECO QA Lead Auditor R. Murphy PGCo Asst. Supv. QC ;
T. Johnson PGCo Eng. Group Supv.
W. F. Clover PGCo Engineering G. M. Galloway PGCo Asst. Proj. Engr.
W. Salealewsk PGCo Lead QC Tech G. Marquardt PGCo Comp. Supv.
T. O'Connor PGCo Site Manager S. Forbes PGCo Site QA Coord.
G. A. Donaldson PGCo Staff Eng.
J. R. Stewart PGCo Proj. Engr.
D. A. Boone CECO PCD Field Engineer J. Carlson PGCo QC B. J. Acas CECO PCD R. J. Farr CECO PCD E. S. Steckhan CECO QA Auditor R. M. Sacco CECO QA Auditor R. E. Waninski CECO QA Engineer (03580)
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ATTACEMENT "A" Page 7
- QA-20-84-552 CONTACTS J. Murphy Admin. Asst. Supv. - QC B. Cahill QC Inspector G. Kreger Foreman of QC Inspectors T. Doyle QC I'nspector W. Berg General Foreman of QC Insp.
R. Holtz QC Inspector R. Czajkowski QC Tech J. Lardi QC Tech B. Clover Engineer -
J. Cletcher QC Inspector W. Baker Foreman W. Robinson QC Tech J._Haley QC Tech T. Johnson Hanger Engineering -
T. Robinson QC S. Farbush QC - '
G. Marquardt NCR's -
J. O'Reilly NCR's - Hold Tags / Storage (snubbers)
J. Fata Audits S. Forbes Audits T. O'Connor NCR Trending R. Lipke NCR Trending M. Carrescia Snubber Storage _
K. Erickson NCR's E. Ulrich QC R. Murphy QC l
J. Carlson QC B. Acas Snubber Storage (CECO PCD)
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ATTACHMENT "B" Page 8 Findinc #1 10CFR50 App. B Criteria XVI (Corrective Action) states in part that ... measures shall be established to assure that conditions adverse to quality such as... deficiencies...are promptly identified and corrected." Contrary to this, corrective action for a internal PGCo audit finding did not go far enough to address the deficiency for past work.
Discussion Finding'#3 of PGCo Internal Site Audit 84-BR-3 identified the following deficiency:
Findinc #3: (PGCo-84 BR-3 Audit)
Reference:
QCP-B4. Paragraph 8.9.2.7 states: "The Welding Supervisor shall establish electrode oven holding temperatures from Manufacturer's recommendations: He shall provide the Supervisor-Q.C. with updated listings of electrode types, including Manufacturer, and the storage temperature requirements for each.
Finding: Welding Supervisor apparently does not establish the storage temperature requirements. Copies of the Manufacturer's Vault.
recommendations are in the O.C.
The Calibration Department does not have a -
copy of the Manufacturer's recommendations. Ovens are calibrated from 1500 -2000 F from information passed down by previous Calibration Department Personnel. (As of 4/24/84, ovens are now calibrated at 2750 F and noted on a round, yellow sticker).
Action Taken to Correct the Deficiency (PGCo Response to 84-BR-3)
The welding supervisor submitted the current manufacturers recommended storage temperatures to QC and the calibration department. This included preparing and giving a chart listing manufacturer and temperature requirements for all weld rod in use to date.
Corrective Action to Prevent Recurrence (PGCo Response to 84-BR-3)
None applicable isolated case (03580)
D00CSSG2
ATTACHMENT "B" Page 9
- QA-20-84-552 Upon reviewing the corrective action for the deficiency it was
-noted that there was no mention of corrective action for weld rod which may have been stored below the manufactures requirements prior to the deficiency being identified. It would have been appropriate to document any weld rod stored below minimum requirements on a NCR for a proper engineering disposition. Furthermore if there was no weld rod stored under minimum temperature requirements there was no documented evidence or assessment to determine that corrective i action for weld rod stored prior to the audit deficiency was not I necessary.
Succested Corrective Action
)
Establish and provide documentation that no weld rod was stored below minimum temperature requirements or identify weld rod stored below minimum temperature requirements and document on a NCR for engineering disposition.
Observation #1 PGCP 18 paragraph 8.6.3 require that weld inspection and NDE shall be performed in accordance with Quality Assura7ce procedures QAP-1, QAP-1A or VE-01 and as delineated on the whip restraint process sheet. Contrary to this there was no inspection records for an extra weld on a QC Inspected and accepted Whip Restraint -
Installation nor was there any installation documentation. .
Discussion A review of several installed whip restraints identified an extra weld placed on the underside of the east leg on LWR-MS-P3.
! Supporting documentation was also examined and no evidence of weld l material, welder, QC inspection of weld, engineering /QC approval, or i any other records were found. Although adding welds to whip
- restraints is permitted under S & L drawing S-1650 note 35, the t
proper processing, approval, inspection, and documentation must be
! completed per procedure PGCp-18.
Corrective Action Proposed Initiate a PGCo NCR, inspect similar installations for this deficiency to assure that this incident is isolated and train appropriate personnel involved in proper processing procedure.
l (0358Q)
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l ATTACRMENT "B" Page 10
- QA-20-84-552 0bservation #2 Contrary to PGCo Procedure QCP-B23A Rev. O dated 10-26-83 (paragraph 7.2.14) which states " Tighten all nuts and lock nuts .
Certain jam nuts require the application of measured torque.
Following are the appropriate values of these connections". PGCo has no evidence of torquing jam nuts on snubber installations.
Discussion A review of 9 QC complete snubber documentation packages dating back to February 1984 revealed a lack of bolt-up torquing documentation required by procedure. In all cases the hanger checklist item for torque was designated N/A and signed off by the Production and Quality Control personnel.
Further investigation produced a 3-26-84 ITT Grinnell installation instruction booklet revisi~on which permits installatfon of jam nuts'to hand tight and then wrench tightened 1/8 turn; however, previous revisions required torquing as does the PGCo procedure. It was also noted that'on all the hanger checklists reviewed the item " locking devices installed and secure" was signed off, complete and acceptable, but no evidence of QC verification of
- 1/8 turn past hand tight was available. The allowance for non-torquing was only allowed by ITT Grinnell after 3-6-84, the ITT Grinnell approval date for their installation booklet. -
Corrective Action Proposed l Recently, a revision to procedure QCP-B23A has been submitted which includes the non-torquing installation option, this will accommodate future installations. Additionally, the final line walk procedure under development will provide an additional check to verify locking devices installed are secured. However, PGCo has not evaluated ~and dispositioned snubbers installed and QC verified in violation of procedure requirements, at the time of installation. A NCR would be an acceptable mechanism to document inadequate ,'
procedure implementation.
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ATTACHMENT "B" Page 11
- QA-20-84-552 Open Item #1 The area of concern for this item is that'three.out of three constant support installation reinspected during this audit had damaged load adjustment scales on the assembly. PGCo personnel indicated that although the support installation was QC inspected and accepted it would be more appropriate to look at this type of inspection attribute during the final linewalk when the support stop's are released after the pipe is filled with the appropriate fluid.. The final line walk procedure which was in draft form during the audit included provision for adjustments for constant supports.
PGCo personnel agreed to incorporate a specific documented requirement to verify that the load adjustment scale plate is not damaged and is legible into the final line walk checklist included in PGCP-48. This item will remain open pending incorporation of the verification and the appropriate approvals of PGCP 48. ;
I In regards to the three damaged scales on the constant supports QA suggests that a memo be issued to field personnel reminding them to take care when handling these type of supports during 4 installation and when working around them..
I Open Item #2 This open item concerns the usage of G. K. Newberg for production layout work and for final quality control verification / inspection of whip restraints. The current whip ~
,j restraint installation procedure PGCP-18 Rev. 11 does not identify or address utilization of GKN surveyors nor does it delineate how the requests, drawings, specifications, tolerances, required to j
~
perform the survey work will be-controlled. As a result the GKN as-built drawing / sketch and the surveyor sign-offs are performed in an inconsistant manner (eg. sign-off only on speed memo not sketch, sketch on back of PGCo controlled drawing). For the items reviewed during the audit no deficiencies were identified as a result of these practices. The procedure needs to be clarified to delineate
- responsibilities and actions.
Proposed Action Revise PGCo procedure PGCP-18 to state how the G. K. Newberg j surveyors will be used as well as how this activity will be controlled. Also incorporate into the QC completion review j
checklist, a check to ensure acceptable documentation practices for l past work.
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ATTACHMENT "B" Page 12
- QA-20-84-552 Open Item #3 Reg. Guide 1.58 (Rev. 1) position statements 1,. 2 & 3 indicate applicability of ANSI N45.2.6 to visual weld inspection. Reg. Guide 1.58 states that the standard should be used in conjunction with ASME Section III and Section XI Requirements. The previous certification requirements for Phillips Getschow visual weld inspectors (VWI) did not include provisions to consider all the requirements of ANSI N45.2.6 (1978) as modified by the Reg. Guide.
Three VWI Level II inspector certification packages were reviewed to determine if the actual experience or related experience of the l inspectors could meet the ANSI N45.2.6 time experience requirements since it was determined that this was the major difference. The results of the review are as follows:
PGCO Procedure Level II VWI Inspector Level II WP-NDT-1 (Rev. 0) Certification Package ANSI 45.2.6 Level II Experience High School Grad. -High School Grad.
Plus three yrs. of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> -training Phil Reitz a related experience 10 hrs. work exp. Fitter welder 8 years +
High School Grad. High School Grad. Albert Insciso a Plus three yrs. of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> training Pipe fitter 3 yrs. +
j related experience 10 hrs. work exp.
High School Grad. High School Grad. Norbert Grzyb *
~
Plus three yrs. of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> training Pipe fitter 3 yrs. -
related experience 10 hr. work exp.
Migh school diploma or equivalent was verified to be in each package.
Note: + after the amount of years indicates that more experience is available but was not included when accumulating experience.
l (03580)
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e ATTACHMENT "B" Page 13
- QA-20-84-552 l
The experience data reviewed above was an expansion of the inspectors previous employment history requested from each inspector. PGCo had not received a documented concurrence from the previous employer, in all instances attesting to the expanded job i description at the time this review was performed. Nonetheless, it was determined that although the procedure WP-NDT-1 did not specifically include the ANSI N45.2.6 experience requirement it appears that PGCo VWI inspector experience meets the intent of the ANSI N45.14 requirement. The primary basis for this conclusion was the results of the review of the expanded job description. However, this item will be issued as an open item requiring PGCo to review all past VWI inspector certification packages to ensure the minimum experience requirement is attained. It will also be necessary to ensure their recertifications is attained under PGCo procedure QCT20.15/ Revision 14 which more clearly addresses the ANSI requirements in the certification of visual weld inspectors.
i Finally, it will be necessary to address other differences between the PGCo procedure WP-NDT-1 previously utilized to certify visual weld inspectors and ANSI N45.2.6 requirements.
i r
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CHECKLIST AND RECORD SHEET i BRAIDWOOD STATION AUDIT NO.10-04-552 l AUDIT OF: Phillips. Oetschow l Page 9 of W '
Checklist Prepared By:
's 3 hb A. M. Montalto R. M. Sacco ,
C. A. Mayes
. .~_
-E.S. Stockhan Lead Auditor: A, M. Montalto Auditors: R. M. Sacco C. A. Haves E. S. Steekhan
, /
No. / Ouention / Reference V/ Acc /\Det / N/A
- 9. Verify that Q.C. inspections are QCP-B23 V
}hIl*S)I being performed on snubbers /wb4,p 10CFR50
~-* " Lass / hangers as required App. B and are in accordance with
~
established procedures.
Crit. X a V h T \
6 tech : ra, ,edinen $
y stea w h sy.g p h, y.
2hk : // Sl'!- 1 -9V y g g DA used guedaons
... .ry 9 No in conjasefren ,ai t4 on e a,,o /Are .
7?1c sane bree .rnalber$ inskthiw.s Q [n, ae~ )w r.9er m dallahoma suett (c/ Sed l0 Gench Gr on$chton M Osse in pniron */o . i & 4d}<d f4 fassbsa '/b are fl4- kgid CC,0le CS nAY'h l!co drMn9sak / -
h.afpre,cr,ait QC iequcdoa sk~fs a- J 37r 'Sf d^ 6't -
lldus't. S,tQ , d// M9uiord GC inajke fren s a c'< PN'"*I Grd ,
(A.ce n sded cm th c. kee add of dle dra"'<~f. n a de' Icn . rioch pi; /*e!) re see&<d sesue a spa H s/ i,>s/n th lion. on p <s t..on u so, flit 9;((gaacy ci l <> G C "IfY'*U 'S bHNW Sab sban fided, f EYdad anhd clin.enwons weld riee +/sca//sns a>'Asu~ &ian.r, 2!c.. afMrd tod/o dbst QfGC anc/ Hee dosep doi .
f',
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(03490)
- pV ggjez/ gn the absM., &Its3 /kt is an94Ms '
I B00066Gs
DN Sc ll n\1I 3 ~
CHECKLIST AND RECORD SHEET BRAIDWOOD STATION AUDIT NO. 20-84-552 AUDIT OF: Phillips, Getschow Page 10 of M
'23 "
. Checklist Prepared By: A. M. Montalto R. M. Sacco I d .
C. A. Hayes E. S. Steckhan Lead Auditor: A. M. Montalto OI 'O .
Auditors: R. M. Sacco pf C. A. Hayes '
gA~
E. S. Steckhan f
\ kh No. / Ouestion
\Oa3 HNA
/ Ref erencUr Acc / \Def / N dla/'
- 10. Field verify that snubbers / whip 10CFR50 Y l(kd restraints / hangers are installed App. B per the design drawings. p Crit. V a,, a . r., a -c,,- a ca -
~
~
pf p ,4 ,quev.sp - QC 5e ta' bAc ti- S/ it- 1 -N
$A CISCSe af mndem three Q'i SnuNwr tr s k lIo !r n a a e d o
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- Auditor 8 M A m Date #tAJ Auditor M / M Date 4 /6/gm Auditor Q M o Toft k GAR Date M/6, /B3 Observor [o //k2/b U
Date4,I,/m DAB /nlc Reviewed /- // / te d cc: Manager of QA Director of QA (Engr-Contr) Site Constr. Supt. Site Quality Assurance /2 Project Manager Project Engineering Mgr. Manager of Projects Audit ' 66'7'd e QA-20-83-15 , Ph111193 Gotochow Co. l On March 25 - 31. site Q.A. conducted an audit of Phillips. Getschow's activities. The purpose of the audit was to verify PGCo's compliance with their Q.A. program in those areas. listed below. The audit was performed from a pre-approved checklist and the scope of the audit covered the following areas.
- 1. PGCo QAM Section 9 - Welder filler material control
- 2. PGCo QAM Section 10 - Document Control
- 3. PGCo QAM Section 11 - Welding Controls
- 4. Manger Installation & Inspection
~
- 5. Whip Restraint Installation & Inspection
- 8. Reg. Guide 1.144 -
- 9. ANSI N45.2.23 -
- 10. Also covered were topics in the areas of 10CFR50 Appendix B
- a. Criteria X
- b. Cirteria V
- c. Criteria XVI
- d. Criteria IX -
- e. Criteria VI
- f. Criteria VIII
- g. Criteria XIV Entrance and Exit Meeting were held and a list of those attending each briefing and a list of those contacted is included as Attachment "B" of this report.
As a result of this audit. five ( 5) deficiencies were identified. Findinc #1 Contrary to Criteria XVI. Phillips. Getschow has failed to implement adequate corrective action for previous deficiencies identified in the control of field change requests. Observation el Contrary to Criteria V. Procedures have not been developed for - reporting Q.C. monitoring activities and as a result inconsistant/ incomplete reporting has occurred. (00430) D00006"/.1 - ,, .m Pago 2 QA-20-83-15 Observation #2 Procedure QCP-B4 Rev. 1 is currently in use; however, comments from S & L received.4-13-79 have not been incorporated. i Observation #3 Contrary to 10CFR50 Appendix B, Criteria 18, two (2) questions on audit 82-BR4 did not have sufficient objective evidence recorded to determine acceptability. Observation #4 ~ Contrary to QCP-38 Rev. 7, weld rod stubs are not being returned to the warehouseman at the end of each shift. ( ASSESSMENT j Phillips, Getschow has not implemented adequate corrective i action in the area of marking FCR's on design documents and needs to devote management attention to this matter. However; with the exception of those items-listed as deficient, Phillips, Getschow appears to be adequately implementing their Quality Assurance Program in the areas examined. , We wish to thank Phillips. Getschow for their cooperation in the performance of this audit. A written response is neces sary for each of the above listed deficiencies and shall include the corrective actions to be taken, the date of expected completion, and the actions that will be taken _ to prevent recurrence. This response should be addressed to T. R. Sommerfield Q.A. Superintendent Braidwood no later than - t April 15, 1983. l l i 1 ~ (00430) l l B0006675 Attachmont "A" Findine #1 Contrary to Criteria XVI, phillips, Getschow has failed to implement adequate corrective action for previous deficiencies identified in the control of field change requests. Discussion During the audit, the following were observed.
- 1. FCR 3006 was stamped on drawing M1226 Sheet 4 Rev. A- the FCR belongs on M1212 - 1 Rev. T.
- 2. For Hanger drawings -
Eighteen (18) drawings examined for twenty (20) applicable FCR's with the following results: Two (2) drawings in Engineering Book were missing applicable FCR's. Two (2) drawings in Engineering Book has wrong FCR stamped. Three (3) drawings in Q.C. Book Copy missing applicable FCR stamp. Three (3) data pack copies (field copies) were missing applicable FCR stamp. Note: PGCo performed a 100% surveillance of O.C. Book . Copies and out of 700 open FCR's found 21 additional FCR's not marked on drawings. All were stamped on the applicable drawing by time of exit. 1 Also ill Engineering Book & Data packs cited have been corrected by time of exit.
- 3. For Whip Restaint drawings:
Fifteen (15) FCR's affecting three (3) drawings were checked with the following results: i' In Containment 1- 14 FCR's not recorded at all; I hand written in pencil not clearly stamped. In Containment 2 - 6 FCR's not stamped: 1 had been hand written on but has since been erased and 8 were hand written on in pencil - no stamp. Note: procedure calls for red ink. (00430) B00"6676 i
- I l
, Attachmont "A" Pago 2 Discussion (cont'd.)
- 4. Contrary to PGCo QAM 10.3.3 the Field Engineer does not maintain a system to provide sufficient assurance that FCR's/ECN's are marked on applicable drawings.
Comment: PGCo Master FCR Log (INFORMATION ONLY) only listed three (3) out of the above fifteen (15) checked FCR's. This concern is a repetitive violation. During QA-20-82-40. this item was identified as Finding #1 on 7-29-82. Follow-ups were performed on September 30 and November 15 and found to be still deficient. A letter was written to R. Cosaro in November requesting PCD attention to this area. Two final surveillances on 11-23-82 and 11-29-82 were performed which showed a large sample of drawings were in compliance. Since Phillips, Getschow has comitted to implement corrective action to prevent recurrence as a result of QA-20-82-40 and this item was discovered deficient again, this citation is issued for failure to implement corrective action. Observation #1 . Contrary to Criteria V. procedures have not been developed for reporting Q.C. monitoring activities and as a result inconsistant and incomplete reporting has occurred. Discussion The lack of a procedure outlining how to report and closeout Quality Control monitoring reports has resulted in several areas of , inconsistancy or incompleteness. Some of these areas are listed below:
- 1. The problems identified, corrective actions suggested. and basis for closeout is sometimes unclear. An example of a
, cited problem: " Bad Weld" *
- 2. Several monitoring reports for the period January thru March. 1983 have not been signed by the inspector performing the surveillance.
Three months of reports performed by "R. Tasmond" had a Xeroxed title block on the report but no signature of this inspector. (0043Q) D000SG77 -- .- --e. --- Attachmont "A" Pogo 3
- . Discussion (cont'd.)
- 3. From the same-three month sample of ":R. Teemond" monitoring reports, the report date is the date of record and the date the surveillance was performed was not recorded on the report. It was possible; however, to determine the date the surveillance was performed from the inspectors personal log book and the inspection status card file.
- 4. The monitoring reports are being signed by someone other than the "Q.C. Supervisor" as called for on the report. If r
Q.C. inspector is to be designated, an indication should be made of such delegation. 2 Although none of the above areas of concern taken singly appear to compromise the integrity of the monitoring reports, the implementation of a procedure or work instruction will guarantee consistant reporting and documentation of closecut. 4 Observation #2 Procedure QCP-B4 Rev. 1 is currently in use: however, comments from S & L received 4-13-79 have not been incorporated. Discussion Although Rev. 2 of this procedure incorporated these comments. i Rev. 2 was withdrawn with instructions to use Rev. 1. If Rev. 1 is I to be used with comment, then a Rev. 3 needs to be developed incorporating such comments. i observation #3 . Contrary to 10CFR50 Appendix B, Criteria 18, two (2) questions on audit 82-BR4 did not have sufficient objective evidence recorded to determine acceptability. j Discussion i i ' One of the questions cited had "N/A - Not auditible at this time" listed as objective evidence. Further explanation needs to be given as to why this question was N/A'ed. A second question on this audit (Q#14) had no determination listed as to acceptapillef and no objective evidence listed. During this exit, evidence was presented that showed these questions had been re-opened and properly closed. l (0043Q) DOCOSG"/S t - ~ - - - - - - - - - - - - - - --- - - - ' - - - - - " ~ ~ ~ ' ~ ~ ' ' ' ~ ' Attachment "A" Page 4 Observation #4 Contrary to QCP-B8 Rev. 7 weld rod stubs are not being returned to the warehouseman at the end of each shift. Discussion ~ If CECO designated stub barrels are to be used for stub disposal, then the procedure should be so amended. (During the field check, stubs were being disposed of in the designated stub barrels.)
- m 1
t 4 (00430) OW bbIb l Attachment "B" PGCo Audit QA-20-83-15 , Entrance Meetina 3-25-83 R. C. Tate Ceco Q.A. E. A. Kram CECO Q.A. J. A. Walters CECO Q.A. .D. A. Brown CECO Q.A. A. Rubino PGCo Q.C. Exit Meetina 3-31-83 D. A. Brown Ceco Q.A. Supv. J. Merwin CECO PCD S. C. Hunsader Ceco Q.A. Supv. R. C. Tate Ceco Q.A. J. Groth Ceco PCD M. P. Vrla CECO Q.A. A. Rubino PGCo Q.C. - J. Lee PGCo B. Meyers PGCo Project Manager E. A. Kram CECO Q.A. S. Forbes PGCo Q.A. T. R. Sommerfield Ceco Q.A. Supt. R. Cosaro CECO PCD Const. Supt. - Persons Contacted Durino PG Audit Rachael Forsythe PGCo Document Control William "Todd" Johnson PGCo Q.C. Gerry Groth CECO Harry Gray Crib Attendant Rodger Hilger Crib Attendant J. Kelly Crib Attendant Marshall Brawder Crib Attendant Joe Meyers PGCo Dick Farr Ceco Jeff Ortiz PGCo Foreman George Cavalenes PGCo Q.C. Ed Gray PGCo Ernie Ullrich PGCo Q.C. Asst. Supervisor Wayne Robinson PGCo Q.C. Mike Goode PGCo Q.C. Scott Forbes PGCo Q.A.* William Roche PGCo A. Rubino PGCo Q.C. J. Jacklich PGCo Walder B000GG60 Attachment "B" Page 2 Persons Contacted Durina PG Audit (cont'd.) T. Swienk PGCo Weldec C. Procope PGCo Welder R. Kim PGCo Welder G. Akin PGCo Welder K. Smock PGCo Welder R. Hamilton PGCo Welding Supv. R. Teemond PGCo Q.C. J. Coh PGCo Q.C. J. Hammond PGCo Handling Foreman T. Sullivan - PGCo Aset. Supt. K. Lilee PGCo Engineer W. Mueller GKNA Foreman G. Kelly GKNA M111 wright C. Gray CECO PCD C. Mennecke Ceco PCD J. Perryman GKNA Q.A. T. Punjak PGCo Q.C. ' T. Styx PGCo Q.C. e l l l l l l ! (00430) l B0006631 s/yk3 CHECKLIST AND RECORD SHEET BRAIDWOOD STATION AUDIT NO. oA-20-83-15 AUDIT OF: Phillips. Catschow Co. Page 25 of 27 Checklist Prepared By: D.A. Brown. R.C. Tate. E.A.Kram. M.P. Vrla. J.A. Waltere Lead Auditor: D. A. Brown Auditors: R.C. Tate. E.A. Kram. M.P. Vrla. J.A. Walters No. / Ouestion / Reference / Ace / Def / N/A
- 25. Does the internal audit schedule Reg. Guide cover the entire scope of on site 1.144 activities? ,
&& aA4 TF WM a~~~i Gs-Wym+ n nra p ,, ,g,, aszdro s G O s %a'/j 7(,2m6sa / , 8.> 4,'% % '2,/.s,ivz /. gig ,I i / ,L /y e z. B Z-3
- b' 3 w dj 6 I%.a h &N A2}7]I85ge y;'$1es g m gy L'A hAAS u 2i 'g;p'~m - a,.w e%p e uw w e I
. we. k!2 na- 82 pces p 2.s w &% 95 5 W / BJ le 2 2'd $4. fag san,9OA Oz . ((o & 92 j7%C9-/-2,L,pa,g,3w i (coa o) 7.g2 3 < e (Q #-AM&A secesosa .i N'wfxaq.) /DQMeM4fh A.3 % W*/d %3 p e3 99 pg3 6 s ? W W M' ne h9 w 93-u2 d - S 83 $ p#80/-/ S<d/ 9xut/ hi 9.3 0c'f822 9,e p 2k'85 El/3 y/' s/ Se/4 9xss &/f GeW8.3 . ~ ~ Nlk fbsy 83 ' h/1 osas h b $ 83 & ^b h U h f/f8} 5 83f8f' W ++,swa og 3[gauesssa Q.P. FORM 18-1.2 Commonwealth e rei c- > " "? QUALITY ASSURANCE MANUAL AUDIT REPORT ' QA-20-83-20 Type Audit: M Program Audit / / Product Inspection Point /- / Records / /Special To: Frank Rolan; Tom Corcoran - L. K. Comstock Project Braidwood 1 & 2 Visit Date 4/18-21/83 Report Date 5-3-83 System N/A Component Identification N/A Material Description Electrical Installation Vendor L. K. Comstock Location Braidwood _ Subcontractor N/A Location N/A Contacts same as on attachment "B" P.O. No. 231360 Spec. No. L2790A Reco= mended Inspections: 6 mos 3 mos 1 mo Other: as scheduled Notes: Contractor to respond in writing by May 20,1983 to T. R. Somnerfield. Response should state corrective actions taken, date when full compliance will be achieved, and the actions taken to prevent recurrence. Lead Auditor A Date f~ 8 3 Auditor Sn n n- 1 (%Jr Date c- L- a s i Auditor s M , Date f BS Reviewed Y ./ ate # 4 E.3 ELM /nlc / / cc: Manager of QA Director of QA (Engr-Contr) Site Constr. Supt. Site Quality Assurance /2 Project Manager Project Engineering Mgr. Manager of Projects i Auditee 3 90006684 e Quality Accurenco Doportmont Audit of L. K. Comstock Co. at Braidwood Construction Site April 18-21, 1983 Q.A. Audit #20-83-20
SUMMARY
This audit was performed to verify that L. K. Comstock is implementing their Q.A. Program in accordance.with 10CFR50 Appendix B as applied to electrical installation work at Braidwood. The following. areas were covered:
ie,: 1. Document Control
- 2. Material Control
- 3. Control of Welding Material
'4. -Installation of Conduit
- 6. Welding
- 7. Nonconforming Materials. Parts,and Components
- 8. Corrective Actions
- 9. Record Storage
- 10. Reg. Guide 1.144 (ANSI N45.2.12 -
1977)
~
I Of the above listed ten audit areas, four (4) Findings were
- identified in the following areas
- NCR/ICR Open Item Status Reports, tracking of obsolete / void construction drawings, inspection of Revision / Work Requests of Safety Related Equipment and prompt identification of nonconforming items.
Specific details of each deficiency are presented in Attachment "A". Attachment "B" lists the attendees of the Entrance and Exit Meetings, plus the audit team.
AUDIT ASSESSMENT The overall assessment is that, other than the four items noted.
{ L. K. Comstock is adequate'ly implementing their Q.A. Program.
l The L. K. Comstock Document Control system das reviewed and found current with regards to distribution of drawings to the field for use. However, tracking of obsolete / void drawings was found deficient.
(00520)
D0006635
Page 2 Control and issuance of material (except for traceability of welding materials) was found to be controlled and orderly. Rod oven calibrations were within approved tolerances. Welder qualifications ,
were reviewed and found current. {
l The installation of conduit and electrical penetration was found !
to be in accordance with established procedures and latest approved design drawings.
i L. K. Comstock's instrumentation installation of safety-related switchgear was not inspected in accordance with approved inspection requirements (deficiency is noted in Exhibit "A").
l The system for reporting and reviewing nonconforming items was tuuhd theduquete lh some ef eau (deticionales are noted in Exhibit "A"). However the logging, filing and overall control of NCR's and ICR's was found acceptable. Additionally, resolution of identified j deficiencies was found to be done in a timely manner.
L. K. Comstock,'s internal audit program was found to be in l
~
accordance with established schedules. The audits were conducted in a timely manner by a qualified lead, auditor.
i AUDITEE RESPONSE REQUIREMENTS The audit team would like to thank L. K. Comstock for their cooperation during this audit.
A written response to each deficiency stating corrective actions -
, taken, date when full compliance will be achieved and the actions taken to prevent recurrence is required. The response should be sent to T. R. Sommerfield by May 20, 1983.
i E. L. Martin - Lead Auditor
. Senior Q. A. Inspector Braidwood Station 1
I
( s2o)
B0006686
Attachment "A" Q.A. Audit #20-83-20 L. K. Comstock April 18-21, 1983 Findine #1 L. K. Comstock Procedure 4.11.1 (Nonconforming Items) and Procedure 4.11.2 (Corrective Action) requires that an Open NCR and Open ICR Status Report indicating open NCR/ICR's by number and date of issuance be issued on a monthly basis. Contrary to this requirement. L. K. Comstock could not demonstrate that the af,orementioned_ reports.had been go,nerated on a monthly basis.
Discuss' ion ' ~' '
During a site Q.A. audit of L. K. Comstock (Audit No.
QA-20-02-25) conducted in 1982, it was determined that the aforementioned status reports were not being issued to the L. K. Comstock Project Manager. In reponse to the 1982 audit deficiency. L. K. Comstock stated that all NCR Status reports to the LKC Project Manager would have a correspondence control number assigned (for-tr'aceability only) and superceded status reports would be-kept on file. A review of the L. K. Comstock NCR and ICR file ,
verified that monthly Open Item Status' Repcrts for ICR's and NCR's were issued for March, 1983. However, it could not be demonstrated that reports had been issued on a monthly basis prior to March, 1983. The superceded status reports have not been retained in accordance with the 1982 audit commitment.
Findinc #2 10CFR50 Appendix B. Criterion VI. states, in part. " Measures shall be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting quality. Contrary to this requirement, L. K. Comstock has failed to implement a system to properly track the return of obsolete / void construction drawings.
Additionally, L. K. Comstock has failed to control their copy of the stores request form for weld rod materials.
Discussion A review of the L. K. Comstock document control system verified that open drawing transmittals (obsolete drawing not yet returned from field) are tracted for three (3) working days after transmittal to field. If void / obsolete drawings are not returned after 3 days, the cognizant general foreman is given the pink (#3) copy of the drawing transmittal for action. Additionally, if the void / obsolete drawings are not returned after 4 days, the gold (1ast) copy of the 1
drawing transmittal is given to the area manager for action. Thus, the document control group has no documentation of which drawing (00520)
B0008687
l
- 1 Attachmont "A" Page 2 Discussion (cont'd.)
transmittals are open. A review of the void / obsolete drawings returned from the field, but not yet processed by document control, '
verified that the applicable drawing transmittals were not retained, yet the drawings were sill outstanding.
Secondly, a field check was made of the weld rod material !
presently being used which yielded three types of weld rod material, each having a different heat number. Of the three heat numbers, only two could be traced back to their respective CMTR's via the retention of the stores request. The two heat numbers with traceability are 40187441, and 48844. However, heat number 422C4871 could not be traced to its CMTR since the stores request was not retained, and the MRR cannot be referenced. During the exit meeting this subject was discussed, but further follow-up concluded that this deficiency still exists.
Findina e3 ANSI N45.2.5 -
1972. Installation, Inspection, and Testing
, Requirements for Instrumentation and Electric Equipment During the
-Construction of Nuclear power Generating Station, paragraph 2 .' O states, in part. " Measures shall be established and implemented for documenting insta11aton and inspection...to verify conformance to specified requirements." Also, ANSI N45.2.4 -
1972 paragraph 1.3 reads, in part. "It is the responsibility of each organization participating in site construction activities to comply with the procedures and instructions issued for the project". Contrary to these requirements. L. K. Comstock failed to comply with LKC Procedure 4.3.16 (Rev. 3-30-81), Revision / Work Request of Class lE Safety Related Equipment, for some safety related equipment revisions. No documented evidence exists for these installations nor were inspections performed to verify conformance with specified requirements.
Discussion During the audit safety related switchgear lAPOSE was examined in the field using S & L drawing 6/20E-1-4610A Rev. E and Westinghouse drawings ENO37-2A, B, C Rev.'s 4, 4, and 5 7 respectively. During the examination it was observed that many revisions to the instrumentation had been performed however no documented evidence of this could be found in the LKC Q.C. vault file. The file contained various information concerning the Main Control Boards' modifications, the Human Factors modifications to the Remote Control Shutdown Panels, and internal wiring revisions to the 4kv switchgear. No documented inspections were performed on the internal wiring revisions.
(0052Q) 8 l
B0006688
, , - - - - . . , , - - -- .n , , - - - - . . - , . - . - - . . . . . . . - ,
'o Attachment "A" Page 3 Discussion (cont'd.)
Based upon the many_ instruments " shipped loose" or sent for a design change for " field to add" on safety related specifications L-2737-01, 4kv switchgear, L-2755, 480 volt motor control centers, and L-2752, 480 volt substations, and other electrical specifications, as applicable, t hie extent of this deficiency should not be considered limited to just EPN 1APOSE. Therefore it is requested that LKC perform a complete backfit inspection of presently installed equipment which was' reworked / modified by '
L,. K. .Comstock to, verify,conformance wl,t,h design documents.,
Pindinc #4 '
_ l' 10CFR50, Appendix B, Criterion XVI, states, in part, " Measures shall be established to assure that conditions adverse to quality...
are promptly identified and corrected." Contrary to this requirement, the welding of main control board 2PM01J to the floor embed, does not conform to details specified on installation print 20E-O-3372B and FCR L-5543, the equipment was set 9-15-82 however no '
inspection was performed on the subject equipment to identify the welding deficiencies. ,
Discussion Drawing 20E-O-3372 Rev. U specifies' welding detail 26 on drawing 0-3391C which requires the end of the MCB to have 1/4" fillet welds 3" in length at 12" centers. Also, FCR L-5543 requires the rear panel welds to be of the same description. Contrary to these -
requirements no weld exists on the end of the MCB and the rear panel welds are spaced farther apart than required. 'The installation was completed and turned over to Q.C. on 9-15-82 as evidenced by the Equipment Set Report in the Q.C.. vault; however no inspection was performed on the above equipment. Presently the welds are painted, also there is no exposed embed to weld to the end of the MCB.
A further review of installations in the area indicated that panels 2PMO2J. 2PMO3J, and 2PMO4J were also installed on 9-15-82 however L. K. Comstock could not demonst' rate that inspections were performed on the subject equipment.
l (0052Q)
BOP 0G689 I
Attachmont "B" Q.A. Audit #20-83-20 L. K. Comstock Apatl 18-21. 1983 -
,. An entrance interview was 'he'1d on April 18,,1983 in the office of the L. K. Comstock Quality Control Supervisor to. discuss the scope of the Ludit. Additionally, an exit debriefing was conducted 3
on April 25. 1983 in the office of the CECO Quality Assurance Site Superintendent to discuss the results of the audit. Those who were present are listed below:
T. R. Sommerfield* CECO'Q.A. Superintendent '
9'
- 2. L. Martin CECO Q'.A. S'nior e Inspector (Lead Auditor)
- 5. L. Clark CECO Q.A. Engineer (Auditor)
E. A. Krama Ceco Q.A. Engineer (Auditor)
J. A. Walters* CECO Q.A. Engineer (Management Observer)
C. Mennecke* Ceco PCD Electrical Supervisor L. J. Tapella* CECO Project Management Q.C. Coordinator F. Rolan* L. K. Comstock Project Manager J. A. Hii* L. K. Comstock Project Engineer T. Corcoran L. K. Comstock Q.C. Manager R. M. Shalok* L. K. Comstock Q.C. Supervisor -
- Denotes present at Exit debriefing only. _
The following additional personnel were contacted during the audit.
J. Blanchette LKC Assistant Document Control Supervisor M. Kast LKC Q.A. Supervisor J. Seeders LKC Q.C. Inspector L. Phillips LKC Q.C. Inspector ~
C. Stiles LKC Site Q.A. Auditor T. Rolan LKC Q.C. Technician J. Faccina LKC Q.C. File Clerk B. Brown LKC Q.C. Inspector D. Soberski LKC Q.C. Inspector J. Burnes LKC Engineer (00520) n0006690
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CHECKLIST AND RECORD SHEET BRAIDWOOD STATION. AUDIT NO. CA-20-83-18 AUDIT OF: L. K. Comstock ~ Page 30 of 37 Checklist Prepared By: E. L. Martin. S.L. C1 rk. E.A. Kram. J.A. Walters
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Lead Au,ditor: E. L. Martin Auditors: S.L. Clark. E.A. Kram. J.A. Walters (observer)
No. /
- Ouestion / Reference / Acc / Def / N/A E- Verify that internal audits See 36.
R-conducted at lease annually. --
Reg. Guide' (
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CJgk dh.: ANSI N45.2.12-1977, para. 3.5.2 W 54ud4ALy 5% pq PLWWA & ep k audd-
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Accress aeoly to Post O*ce Boa 767 CNeago. likner: 60690 July 8, 1985 9
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Mr. James 0. Keppler l Regional Administrator l
U. 5. Wuclear Regulatory Consission Region III 799 Roosevelt Road Glen Ellyn' . IL 60137 SUBJacT: Material Traceability Verification
_ _ _ . . _ _ (11171 FM[El]Illlliililf11 Dear Mr. Keppler on June 25, 1985 a presentation was made of the Braidwood Material Traceability Verification (MTV) Program. The purpose of this letter is to provide a stannary of that presentation.
An Interim Report updating 10 CPR 50.55(e) Wo. 83-07 will be issued within a few weeks. It was delayed pending results of this meeting.
The Progress and findings of the NtY Program will be specified at that time.
Please address any questions that you or your staff may have concerning this matter to this office. -
Very truly yours.
L. C. De10eorge Assistant Vice-President 140/dak
, cc- WRC Resident Inspector -
Brat h Diroctor of Inspectfort and Dnforcamant D. s. suelear Regulatory h ==1ce Vanhington, _ D.C. 20555 (16434) -
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. ATTAconNT 1 stneoJtY CF ccMMENTS MADE BY ccMMouvEALTH episoW GwANY PEiEM 1 1
_ July 11, 1985 INTRc M 12( ,
I In the stamer of 1983, NRC personnel had a concern about traceability of piping materials. Simply stated, their concern was whether, for a particular field location, the specified or correct material was checked out of the Warehouse and installed, and whether our documentation of the material used
_ is cortect. - .. - - - - - - - - - - - - - ~ ~ -
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l C'moWEALTM EDIR3r coqPANY RESPON5E -
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. I To address the unc concern and confirls our confidence in a system whieb the Phillips, Getschow Ccapany had used for many years in doing AsME work, we implemented a sampling review of the material. traceability system. That review included a field walkdown of piping for identity of pipe markings, and a ccuparison of those markings to office documentation supporting material traceability. In February of 1984 we called in a team of ASMR ced; c:q=rt= to rwia th Phillips, ostsctiow'Compahy---- * '-~ ~ ~~ -
material traceability system, it's implementation, and the results of the sempling effort. That team consisted of the ,
fo11 caring irdividuals: !
1 ad neouy -
r w lth adison ccupeny Ernie Branch -
sargent and Lundy ,
Howard Dubeli --
Hartford Steam Boiler I e .
It was the ceinica of the ASME Code knowledgeable persons that the Phillips, Getschow system, as established, was adequate, and, as implemented was adequate to meet ASME Ctade Easterial Traceability requiremmets.
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%1th adison company personnel and the tems of Cada - '{ $: .'.-ip experts, presented those conclusions to MEC peransasi in '
Pobruary of 1964. Despite the conclusions presented, m *. .
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personnel requested meditional assurance that Etne material *
.!,UI traceability system had been adequately implementes. ..f -
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mTgltIAL TRACEABILITY VERIFICATI0bi (MTV) PROGRAM In responding to the NRC's concern on this issue, Commonwealth l Edison company implemented the Material Traceability verification program, a 100% review of system implementation.
nericus sussEOUENT TO MV PROGRAM IMPt.Lu.siTATION In eoditi n t c.de. ad Hentyy,ggjlg,'g,fgjg g)ggsph8AIdIlf5n to -- -
The AsME National Board was invited to Braidwood by Edison, in l I
response to discussions with the NRC. They have been at I
Braidwood since February 18, 1985. The National Board has been involved in the disposition of all non-conformances (Wat's) since about June 1,1985, and is auditing WC2's dispositioned prior to their involvament. They are also auditing material traceability implementation after the 1983 cutoff dates.
Based believe:on discussions with us, it is our understandin5 that they
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That the phillips, cetschow System, as implemented, provided adequate trocoability of material and that the Stores Request System cglies With the ASM Code.
2.
That in dispositioning ac2's, Edison is taking a conservative approach and meeting AsME Code requirements.
i 3 That, given our approach to resolving MTV related issues, Edison will end up with a piping installation in full compliance with the Asm code.
4.
'Ihat the code recognizes the occurence of non-mnformances
, as ccamon. and therefore provides for non-ccaformance
- disposition and corrective action efferts, with i involvement by the authorized inspection agency, as standard methods for assuring adequata resolution of the j problems and compliance with the AsME code.
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l coanonwealth Edison company, by it's own initiative, requested an opportunity to discuss the MV Program and it's results with the ASME 1,ocal jurisdiction -- the Division of Boiler and Pressure Vessel Safety of the Illinois State Fire Marshal's Office, A meeting was arranged in Springfield on May 31. 1985 with representation also free the Illinois Department of Wuelear Safety. Subsequently, an additional meeting was held on June 17, 1985, at Braidwood. At the second meeting the results of the my program wre discussed in more detail, and the state of Illinois agencies had an opportunity again to discuss our efforts with the authorized inspection agency and the AsME National Board personnel.
I Folicwing the above meetings, Edi. son was informed that the personnel frca the Illinois State Fire Marshal's office were , , , , , . . ,
I satisfied that our Program will result in assuring the piping !
systems at Braidwood site will be in compliance with the ASME l Code. Further, they indicated that all decisions and acceptances of Edison's Program will be based on the advice and )
i cowuel of the ASME National Board personnel presently on the '
Braidwood site.
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0%%iED September 12, 1985
'85 sgp 75 A10:S2 UNITED STATES OF AMERICA Si chh[7{h4 ff NUCLEAR REGULATORY COMMISSION gg hyfg, BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: )
COMMONWEALTH EDISON COMPANY )
> ) Docket Nos. 50-456 (Braidwood Nuclear Power ) 50-457 Station, Units 1 and 2) )
CERTIFICATE OF SERVICE I, Joseph Gallo, one of the attorneys for Commonwealth Edison Company, certify that the following persons have been served in the above entitled matter with copies of the documents indicated and that service has been executed in the manne. ..dicated. a
- Lawrence Brenner, Esq. **Mr. William L. Clements Chairman Chief, Docketing and Services Administrative Law Judge United States Nuclear
- Atomic Safety and Licensing Regulatory Commission Board Office of the Secretary United States Nuclear Washington, DC 20555 Regulatory Commission Washington, DC 20555
- Herbert Grossman, Chairman *Ms. Bridget Little Rorem Administrative Law Judge 117 North Linden Street Atomic Safety and Licensing P.O. Box 208 Board Essex, IL 60935 U.S. Regulatory Commission Washington, DC 20555 1
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- Dr. Richard'F. Cole **Dr. A. Dixon Callihan Administrative Law Judge Administrative Law Judge Atomic Safety and Licensing 102 Oak Lane Board Oak Ridge, TN 37830 U.S. Nuclear Regulatory Commission Washington, DC 20555
- Stuart Treby, Esq. ** Atomic Safety and Licensing Elaine I. Chan, Esq. Board Panel Office of the Executive Legal United States Nuclear Director Regulatory Commission United States Nuclear Washington, DC 20555 Regulatory Commission Washington, DC 20555
- Robert Guild ** Atomic Safety and Licensing Douglas W. Cassel, Jr. Appeal Board Panel Timothy W. Wright, III United States Nuclear BPI Regulatory Commission 109 North
Dearborn Street Washington,
DC 20555 Suite 1300 Chicago, IL 60602
- Federal Express delivery on September 12, 1985 of the following documents:
- 1) Applicant's Eighth Partial Response to Rorem's First Set of Quality Assurance Interrogatories _
and Request to Produce dated September 12, 1985, transmitting the response to Specific Interrogatory No. 35.
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- 2) Affidavits of Eugene E. Fitzpatrick and Thomas E. Quaka in support of Interrogatory No. 35.
- Deposit in the United States mail on September 12, 1985 of the following documents:
- 1) Applicant's Eighth Partial Response to Rorem's First Set of Quality Assurance Interrogatories and Request to Produce dated September 12, 1985,_ transmitting the response to Specific Interrogatory No. 35.
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- 2) Affidavits of Eugene E. Fitzpatrick and Thomas E.'Quaka in support of Interrogatory No. 35.
J m+h ph G411o ISHAM, LINCOLN & BEALE 1120. Connecticut Ave., N.W.
Suite 840 Washington, D.C. 20036 Dated: September 12, 1985 c
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