ML20136G619
| ML20136G619 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 12/02/1983 |
| From: | Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Norelius C, Spessard R, Streeter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20136G602 | List: |
| References | |
| FOIA-85-452 NUDOCS 8508190568 | |
| Download: ML20136G619 (4) | |
Text
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December 2, 1983 NOTE T0: R. L. Spessard C. E. Norelius J. F. Streeter W. S. Little l
There will be a meeting with Commonwealth Edison Company concerning actions being taken at the Braidwood site. The meeting is scheduled for December 5, 1983 in Conference Room C at 10:00 a.m.
! For further Information, please contact me.
R. C. Knop 6 ,.
cc: D. W. Hayes L. G. McGregor R. Lerch/
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l programs. This reinspection program was designed to addresst questions raised at other nuclear plant sites by the NRC staff with respect to QC inspector qualification and '
cartification under ANSI N45.2.6. I Ecch site contractors' programs for the qualification and certification of inspectors was ravised in ' late 1982 to reflect the NRC's latest interpretation of ANSI N45.2.6 (1978). A program was established . to validate, through reinspection, the certification and
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qualifications of contractor QC inspectors _ established prior to these program upgrades. The .
' first three months of accessible and recreatable inspections for every fifth inspector for the f
five major site contractors are being reinspected. Based upon agreement between the results cf the inspector's initial inspections and those of the reinspection, the acceptability of an inspector's qualification and certification is established. If agreement to predetermined t
ccceptance criteria cannot be established for these inspections, provisions exist to expand
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the sample of reinspections for that inspector whose '
initial inspections were deemed !
deficient. If the expanded sample of inspections for this inspector cannot establish '
reasonable agreement for the reinspections, then the sample of inspectors is also expanded.
This program is designed to confirm the acceptability of the historical inspector qualifications and certifications at Braidwood in addition this program'is also expected to !
previde, through reinspection, an additional indication of the quality of a significant fraction p cf previously installed plant systems. '4 The reinspections required by this program were started in July 1983 and are now
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rpproximately 80% complete. It is expected that the reinspection effort will be completed in 1~
lata 1984. '
Piping Heat Number Traceability '
In June 1983, the Phillips Getschow Company procedure for the maintenance of ASME piping material traceability was enhanced to require quality control verification of heat numbers at -
the point of installation. In order to reconfirm that all ASME piping materials installed prior to'3une 1983 were traceable, PGCo established a program for the 100% reinspection for
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. traceability markings of all accessible piping and a 100% review of material traceability 7
gg documentation supporting previously installed large and small bore ASME piping systems.
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The program is intended to establish that material traceability requirements were met; that is, that each piece of ASME Code piping material is uniquely traceable to material certifications, either through the documentation traceable to the piping installation, or by identification markings physically on the piping material. The results of the program should j verify that only acceptable material was installed and should validate the existing material j documentation supporting traceability.
g PGCo began implementation of this program in March 1984. The expected duration of this program is approximately one year. l I
Quality Control Structural Steel Review (QCASR)
In late 1982, based on experiences at other nuclear plant construction sites, Commonwealth j Edison Company undertook a program to reinspect, on a statistical sampling basis, various 4 design attributes of structural steel erected by the various contractors responsible for this I work. The initial sampling and the criteria for expansion of the sample are based on MIL STD 105D. The reinspection by site contractor QC personnel of essential attributes against design
,lg drawings and specifications will provide Sargent & Lundy with information to analyze any differences between the design and the as-constructed condition.
Work on QCSSR was initiated in early 1983 and is approximately 70 percent complete.
Completion of this program is intended to confirm that the installed structural steel meets j the design requirements.
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} Electrical Installation Document Review I
p During 1982, Commonwealth Edison Quality Assurance audits identified deficiencies relative
{( to the control of electrical installation and associated quality control records. As a result, in
) February 1983, Commonwealth Edison Company directed its electrical contractor, L. K. Comstock (LKC), to enhance their procedure governing documentation of electrical installations and to perform a comprehensive review of their quality documentation for prior
[ electrical installations. This program is intended to confirm that each completed LKC i
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'JtOUTING 'AND. TRANSMITTAL SUP Jun2 5, 1924 i l
l in reame. emco symmer, e m amener, enness cete hempeng Agency / Pest) ,-- ..-
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lE. Branch chiefr )Ub g, Section Chiefs 4.
3, cc: J. F. Streeter Action ! Fde / INote and Return Approval For Clearance / Per Conversation lAs Requested For Correction / .
Prepare Reply Circulate For Your Inform / son 15ee Me Comment lI investigate [ ; Segnature
- - - lCoordmation I Justify /
REMARK!
The attached memorandum e tablishes policy within the Division of Engineering for enforcement actions associatC with Quality Assuranar vrocram( findings. Please review the attached me careful , d provide input te hoper Walk r tv COF June 15, 196% 'onitemsorstater4entg which need additional claritication in a traintnp sessiou
Attachment:
As stated DO flDi use tnis f:*m as a RE00RD c' approvals, concurrences, dispossts.
/ c6estances, and simdar actens ThDb*4?stmt, cri symW. 4tn gt) l Room ho.-blCG
'f M L.1.'SPES$ALL,DIRECTOh,G J f> , o i D.E. j p, n he i
m -se? OPTBONAL FORM 41 (Rev. 7-701 heensed h ESA FPasR 441 Cruu 101-11.20t
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Address Reply to Post Office Box 767 iA I 8' y
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3A 1L EIiT Filot .M December 21, 1983 Mr. Burt Davis Deputy Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road s Glen Ellyn, IL 60137
Dear Mr. Davis:
Attached are copies of the transparencies which we used in our presentation to you on December 20, 1983, regarding Construction and Quality Assurance Activities at Braidwood Station.
Very ruly y .
)_-_=-::
D L. Ferrar Director of Nuclear Licensing Attachment 7851N
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NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20, 1983 EXTENSIVE EVALUATIONS A. TECHNICAL SUPPORT GROUP SCOPE EVALUATE OVERALL EFFECTIVENESS OF QUALITY CONTROL PROGRAMS AND OF WORK ACTIVITIES FOR EACH CONTRACTOR (EIGHT TOTAL).
IEAti R. TUETKEN - ASST. CONSTRUCTION SUPERINTENDENT, BYRON R. BYERS - CONSTRUCTION STRUCTURAL ENGINEER, BYRON J. GIESEKER - ASST. TECH STAFF SUPERVISOR, LASALLE R. BRAUN - QUALITY ASSURANCE SUPERVISOR, LASALLE ;
L. TAPELLA - CONSTRUCTION ELECTRICAL ENGINEER, BRAIDWOOD ,
G. GROTH - CONSTRUCTION MECHANICAL ENGINEER, BRAIDWOOD DURATION -
2 SEPTEMBER 14, 1983 THROUGH SEPTEMBER 24, 1982: NINE (9)
WORKING DAYS i
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B. DANIEL CONSTRUCTION COMPANY EVALUATION SCOPE A. EVALUATE THE GENERATION AND PROCESSING OF PIPING, INSTRUMENTATION AND HANGER / SUPPORT TRAVELER DOCUMlNTATION:
B. REVIEW RETRIEVABILITY OF TRAVELER DOCUMENTATION:
C. EVALUATE QUALITY CONTROLS ABILITY TO SUPPORT THE CONSTRUCTION EFFORT:
D. EVALUATE THE GENERATION AND PROCESSING 0F HANGER RETROFIT DOCUMENTATION:
E. REVIEW TRAVELER DOCUMENTATION TO DETERMINE IF IT PROVIDES THE INFORMATION REQUIRED TO COMPLETE N-5 DATA REPORTS.
IEAM TWO (2) SENIOR ENGINEERS -
COMBINED NUCLEAR CONSTRUCTION EXPERIENCE OF TWENTY-ONE (21) YEARS . -
DURATION INITIAL: MARCH 7, 1983 THROUGH MARCH 28, 1983: 26 MAN DAYS FOLLOW-UP: MAY 5, 1983 THROUGH JUNE 17, 1983: 25' MAN DAYS 1
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DANIELS REVIEW TEAM RESULTS/ RECOMMENDATIONS SMALL BORE PIPING SYSTEMS DOCUMENTATION INCOMPLETE ESTABLISH A QUALITY CONTROL DOCUMENTATION REVIEW GROUP TO PERFORM TECHNICAL AND COMPLETENESS REVIEWS IMPROVE DOCUMENTATION , LEGIBILITY CLARIFY QUALITY ASSUANCE PROCEDURES s
WELDING SUPERVISOR REVIEW ALL WELD CONTROL RECORDS DEVELOP A SYSTEM FOR PREPARATION OF N-5 DATA REPORTS
SUMMARY
ACTIONS HAVE BEEN TAKEN OR ARE IN PROCESS ON ALL THE ABOVE RECOMMENDATIONS. ,
DANIEL FOLLOW-UP TO CONTINUE IN JANUARY, 1984. ,
INDICATES ACTION TAKEN WHICH RESULTED FROM TECHNICAL SUPPORT GROUP OR DANIEL CONSTRUCTION REVIEW RECOMMENDATIONS.
(0192D) -
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RESULTS/ RECOMMENDATIONS PHIt t IPS, GETSCHOW- ,
A. IMPROVE / INCREASE ENGINEERING AND MANAGEMENT STAFF B. QUALITY CONTROL T00 INVOLVED IN LINE WORK C. DOCUMENT ACCOUNTABILITY NEEDS IMPROVEMENT s
D. RE-FOCUS PROBLEM RESOLUTION E. INCREASE TRAINING FOR PRODUCTION FIELD SUPERVISION F. QUALITY CONTROL SUPERVISOR T00 INVOLVED IN DETAILS L. K. COMSTOCK A. REDUCE THE NUMBER OF BACKLOGGED HANGER INSPECTIONS B. INCREASE THE CONFIGURATION INSPECTION REQUIREMENT FROM 35% TO 100%
C. INCREASE THE NUMBER OF INSPECTORS D. STREAMLINE DOCUMENTATION AND TRACKING DEVICES 1
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RESULTS AND RECOMMENDATIONS - (CONT'D)
PULLMAN ,
A. INCREASE 10% CONFIGURATION INSPECTION REQUIREMENT TO 100% l B. PERFORM RETRO-FIT INSPECTION C. INCREASE THE NUMBER OF INSPECTORS J
SUMMARY
ACTIONS HAVE BEEN TAKEN OR ARE IN PROCESS ON ALL THE ABOVE RECOMMENDATIONS.
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l QUALITY ASSURAMcE REVIFWS AER CORRECTIVE ACTIONS s
!. GENERAL OFFICE AUDIT
!!. UNIT CONCEPT INSPECTION
!!!. INCREASE AUDITS & SURVEILLANCES IV. INPO SELF INITIATED EVALUA' TION 4
V. CONTRACTOR - QUALITY ASSURANCE t q s
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1, RFMFRAl DFFICE AllE.T. . ;
PURPOSE - TO DETERMINE ADEQUACY OF Q.C. INSPECTION PROGRAMS !
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SCOPE - MULTIPLE AREAS
$!x AUDITORS - 300 MANHOURS RESULis
- HVAC HANGERS
- ELECTR! CAL PENETRATIONS . ;
- CONDU!T SEPARATION ,
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38A PARTY OV(RINSPECTION i PURPOSE 1
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61 UNITS PERFORMED i
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.i 5 MULT! - DISCIPLINE LEVEL !! INSPECTORS '
i i RESULTS
- 185,825 $0. FT. INSPECTED ,
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- 28,906 ITEMS INSPECTED
- 2,782 ITEMS FOUND DEFICIENT
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!!!. IMcRFASF AUDITS & SURVEli1AMcFS QUANTITY PERFORMED .
AUDITS SURVFILLANCFS JANUARY ' 81 - JUNE '82 49 m 700 JULY '82 - PRESENT 89 W 900 INCREASE 825 255 k
ANS! N45.2 STANDARDS OCTOBER, 1983 - COMPREHENSIVE AUDIT
- 35 TEAM MEMsERS
- OVER 2,800 MANHOURS .
ADDITIONAL AUDIT TRAINING i
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- I IV. IMEQ SELE JutTt ATFD EVALUATION f
COVERED BYRON AND BRAIDWOOD PROJECT <
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s 20 MAN TEAM 3,800 MANHOUR EFFORT AREAS EVALUATED
- ORGANIZATION & ADMINISTRATION
- DESIGN CONTROL
- - CONSTRUCTION CONTROL ,
- - PROJECT SUPPORT
- TRAINING
- QUALITY PROGRAMS r
- TEST CONTROLS 4
RESULTS , .
23 - NO WEAKNESS IDENTIFIED 10 - WEAKNESS IDENTIFIED 3 - GOOD PRACTICE IDENTIFIED e
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NRC ENFORCEMENT CONFERENCE
. i BRAIDWOOD PROJECT t
DECEMBER 20, 1983 PROJECT CHANGES AND CORRECTIVE MEASURES A. PROJECT - GENERAL
- QUALITY WORK AND QUALITY DOCUMENTATION A TOP PRIORITY
- GERRY GROTH, LEAD MECHANICAL ENGINEER, CONSTRUCTION
- LARRY TAPELLA, PROJECT QUALITY CONTROL COORDINATOR
- SIX (6) CONSTRUCI!ON FIELD ENGINEERS ADDED
- ON-SITE PROJECT ENGINEERING GROUP ESTABLISHED
- DAN SHAMBLIN, MANAGER - LASALLE EXPERIENCE
- WARREN VAHLE GROUP LEADERS KEN STEELE .
EARL WEND 0RF LASALLE EXPERIENCE THREE (3) ADDITIONAL ENGINEERS
- LASALLE EXPERIENCE l
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- GENERAL (CONT'D)
! A. PROJECT
- .SARGENT AND LUNDY SITE ENGINEERING
- INCREASED FROM 20 - (8/82) TO 329 - (12/83)
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- TIMELY RESOLUTION OF CONSTRUCTION
- ENGINEERING EFFORT CLOSER TO FIELD
- 80 HAVE BYRON OR LASALLE EXPERIENCE
- STARTUP SUPERINTENDENT ESTABLISHED ,
- CHUCK TOMASHEK
- BYRON EXPERIENCE l
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- INCORPORATE OVERALL LASALLE'AND BYRO (METHODS AND PERSONNEL) .
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PROJECT CHANGES AND CORRECTIVE MEASURES i B. SITE CONTRACTORS - OVERALL l
EDISON MANAGEMENT MET WITH CONTRACTOR PROJECT AND QUALITY CONTROL / QUAL'ITY ASSURANCE PERSONNEL ENCOURAGED CONTRACTORS TO BRING IN BEST AVAILABLE MANAGEMENT TALENT INCREASED INSPECTORS ALL INSPECTORS CERTIFIED TO ANSI N4S.2.6 QUALITY CONTROL INSPECTOR CERTIFICAT!0fl -
RE-INSPECTION (SAME AS BYRON)
ALL CONTRACTORS UPGRADED WORK PROCEDURES l
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INCRASED !MPHASIS ON TRAINING FOR ALL PERSONNEL COMPUTERIZATION OF INFORMATION ,
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l RESULTED FROM TSG/ DANIEL REVIEW (01940)
t PROJECT CHANGES AND CORRECTIVE MEASURES l C. PHILLIPS, GETSCHOW COMPANY - MECHANICAL
- EDISON PERSONNEL WORKED WITHIN PHILLIPS, GETSCHOW COMPANY, l THEN TRANSFERRED BACK TO CONSTRUCTION 1
PROJECT MANAGEMENT l
INITIALLY ADDED (08/01/83):
SITE MANAGER ASSISTANT TO SITE MANAGER '
l ~~s,, LASALLE SITE SUPERINTENDENT - TEAM STAFF ASSISTANT TO Q.C./ ENGINEERING ,,, -
PROJECT ENGINEER l
LATER ADDED:
, 2 AREA SUPERINTENDENTS -
NUCLEAR EXPERIENCE
^SST. AREA SUPERINTENDENT ,
AREA GENERAL FOREMAN LASALLE l '
NIGHT SUPERINTENDENT EXPERIENCE l
i RESULTED FROM TSG/ DANIEL REVIEW
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C. PHILLIPS. GETSCHOW COMPANY - MECHANICAL (CONT'D)
ENGINEERING l
- ADDED:
- PROJEC'T ENGINEER . 45 YEARS l l - ASSISTANT PROJECT ENGINEER ]((;) NUCLEAR
- 4 GROUP SUPERVISORS - EXPERIENCE 4
- 7 OTHER EXPERIENCED PERSONNEL
- DEVELOPED SYSTEM TURNOVER AND TESTING GROUP COORDINATES WITH QUALITY CONTROL ON SYSTEMS COMPLETION
- ESTABLISHED DOCUMENT STATION CONCEPT:
- STANDARDIZED, STRINGENT CONTROL OF PROCESS DOCUMENTS I
- 6 FIELD ENGINEERS IN 4 DOCUMENT STATIONS
- LASALLE CONCEPT '
l - 8 0F 19 DOCUMENT TECHNICIANS ARE LASALLE EXPERIENCED
--- RESUTLED FROM TSG/DANIE REVIEW ,
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C. PHILLIPS. GETSCHOW COMPANY - MECHANICAL (CONT'D) l l
OFFICE IMPROVEMEXIS
- VAULT INCREASED 600 SQUARE FEET TO 1500 SOUARE FEET l -
QUALITY CONTROL AREA INCREASED 1500 SQUARE FEET TO 3000 l SOUARE FEET .
TRAININGFA(ILITYADDED
- 800 SQUARE FEET m
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C. PHILLIPS, GETSCHOW COMPANY - MECHANICAL (CONT'D)
DUALITY C0kT10L SPLIT INTO OFFICE AND FIELD f
ASSIGNED NEW QUALITY CONTROL SUPERVISOR ASSIGNED GEN'ERAL FOREMAN OF FIELD INSPECTORS ESTABLISH 8 LEAD TECHNICIANS IN DOCUMENT REVIEW (3 HAVE LASALLE EXPERIENCC)
REVISED QUALITY CONTROL TECHNICIAN CERTIFICATION l
QUALITY CONTROL TECHNICIANS INCREASED 18 TO 56 ---
BACKLOG REVIEW, INITIAL AND FINAL REVIEW, N-5 REVIEW 1
FIELD INSPECTORS INCREASED 25 TO 50 QUALITY CONTROL OVERALL INCREASED 57 TO 125 l -
INCREASED QUALITY CONTROL MONITORING COMPUTER ADDED --- MATERIAL TRACEABILITY, INSPECTOR ,
QUALIFICATIONS, WELD PROCEDURE QUALIFICATION' I
EMPHASIS ON TRAINING AND CERTIFICATION l
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RESULTED FROM TSG/ DANIEL REVIEW a
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PHILLIPS. GETSCHOW COMPAMY - MECHANICAL (CONT'D)
C.
l VERIFICATION EFFORTS i
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- RE-INSPECTION
- 1. QUALITY CONTROL INSPECTOR CERTIFICATION l
- 2. DOCUMENTATION REVIEW OF 10,000 LARGE BORE WELD DATA SHEETS j ,,
- 3. HEAT NUMBER TRACEABILITY OF SMALL BORE PIPE BEFORE JULY 1, 1983 AND LARGE BORE PIPE BEFORE NOVEMBER, 1982
- 4. RE-INSPECT INSTRUMENTATION PIPING (DOING 100%; COMPLETE .
0%)
S. HANGER RE-INSPECTION (DOING 1005; COMPLETE 98%)
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- 6. EQUIPMENT REINSPECTION (DOING 1005; COMPLETE 1005) i 1
--- RESULTED FROM TSG/ DANIEL REVIEW 1
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PROJECT CHANGES AND CORRECTIVE MEASURES D. L. K. COMSTOCK COMPANY - ELECTRICAL QUALITY CONTROL MAMP0hlER ,
FIELD INSPECTORS INCREASE s
07/82 11LE LEVEL 11 11 47 -
LEVEL I 11 4 I
TOTAL , 22 51 OVERALL INCREASE 25 TO 64. .
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., r-D. L. K. COMSTOCK -- ELFCTRI*4L
, (CONT'D)
OUALITY C0kTROL MANAGEMENT CHA'JGES AND OPERATIONAL IMPROVEMENTS QUALITY CONTROL MANAGER RE'? LACED 11/82 QUALITY CONT,ROL MANAGER REPLACED 08/83 WEEKLY QUALITY CONTROL AND CONSTRUCTION MEETINGS ESTABLISHED 09/82
. I SUPERVISOR OF INSPECTORS ESTABLISHED .
l LEAD INSPECTORS ESTABLISHED INSPECTION STATUS / CONTROL SYSTEM IMPLEMENTED MARKING Cf MYLARS FOR INSPECTION STATUS INSTALLATIONANDINSPECTIONSTATUSISBEINGCOMPUTERIZEb TRAL'41NG COORDINATOR ESTABLISHED INSPECT M '>
INCREASE CONFIGURATION INSPECTION 355 TO 1005 RESULTED FROM TSG/ DANIEL REVIEW ,
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D. L.'K. COMSTOCK - ELECTRICAL fCONT'D)
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DOCUMENT CONTROL IMPROVEMENTS IMPROVED DOCUMENT TRACKING SYSTEM DOCUMENT CONTROL SUPERVISOR REPLACED 02/83 PERSONNEL INCREASE 7 TO 14 l l
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DEEICE IMPROVEMENTS ,
INCREASE 3700 SQUARE FEET TO 7000 SOUARE FEET NEW QUAllTY ASSURANCE VAULT DOCUMENTATIOJLREVIEW ,
IMPROVE DOCUMENT QUALITY AND RETRIEVABILITY NEW VAULT CONSTRUCTED RECORDS REVIEW IN PROGRESS -
COMPLETE 02/15/84 : -
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- DAILY, CURRENT REVIEW 0F NEW RECORDS
. RESULTED I /
FROM TSG/ DANIEL REVIEW 4 j , ,
(02020) '
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EROJECT CHANGES AND CORRECTIVE MEASURES G. K. NEWBERG - STRUCTURAL E.
INCREASED 3 TO 6
- QUALITY CONTROL MANPOWER:
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- REVISED OVER 20 PROCEDURES I
- TOTAL REVISION TO QUALITY ASSURANCE MANUAL .
- COMPUTERIZED SEVERAL PRODUCTION AND QUALITY CON DEVICES -
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- INCREASED TRAINING QUALITY CONTROL STRUCTURAL STEEL. REVIEW IN. PROGRES E
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--- RESULTED FROM TSG/ DANIEL REVIEW
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PROJECT CHANGES AND CORRECTIVE MEASURES F. Pul l MAN - HVAC -
MANPOWER:
08/82 12/83 PRODUCTIVE CRAFT.S 40 42 NON-PRODUCTIVE CRAFTS 18 80 TOTAL 58 122 1
0.C./0.A. 3 19 NEW DEPARTMENTS:
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ENGINEERING / DOCUMENT CONTROL -
9 s SURVEY AND RESEARCH -
5 FCR/ FEM -
5 CORRECTION NOTICES 3 COMPUTERIZED TRACKING OF INSPECTION STATUS WELDER QUALIFICATIONS, ETC. ,
_ INCREASED-CONFIGURATION INSPECTION 10% TO 100%
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100% RETRO-FIT INSPECTION COMPLETE FOR WELDING AND ,
CONFIGURATION 100% PETRO-FIT INSPECTION OF DUCT BROCHURE ITEMS.IN
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PROGRESS RESULTED FROM TSG/ DANIEL REVIEW (0204D)- ; <
NRC ENFORCEMENT CONFERENCE BRAIDWOOD STATION DECEMBER 20, 1983
~ PULLMAN SHEET METAL WELDER 00ALIFICATIONS
- 1. ALL WELDERS QUALIFIED.
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- 2. WELDERS RECEIVE DOCUMENTED TRAINING BY PULLMAN SHEET METAL i
QUALITY ASSURANCE / QUALITY CONTROL ON EACH PROCEDURE FOR WHICH THEY ARE QUALIFIED.
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. TRAINING C0 VERS MATERIAL SPECIFICATION, WELDING PROCESS, FILLER METAL CLASSIFICATION, AND JOINT' DETAIL.
- 3. EACH WELDER IS ASSIGNED A UNIQUE I.D. NUMBER.
- 4. WELDERS ARE REQUIRED TO STAMP EACH WELD WITH I.D.
- 5. QUALITY. CONTROL VERIFIES PRESENCE OF WELDER I.D. DURING VISUAL INSPECTION OF WELDS.
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l NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20,'1983
~ WELDING PROCEDURES
- 1. ALL WELDING PROCEDURES APPR0c5D (REVIEWED AGAINST DESIGN SPECIFICATION AND CODE).
! 2. FROM MARCH, 1978 TO SEPTEMBER, 1979 ONLY TWO (2) WELDING PROCEDURES:
A. 7018 SMAW FOR HANGERS B. SILICON-BRONZE HANGER TO DUCT r
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- 3. APRIL, 1980 TO DATE NUMBER OF PROCEDURES IS NINE (9). BREAKS INTO FOUR (4) GROUPS:
A. GROUP 1 -
HANGERS -
1 PROCEDURE s
. B. GROUP 2 -
HANCIR TO DUCT -
4 PROCEDURES i
- C. GROUP 3 -
STAINLESS DUCT -
2 PROCEDURES 4
D. GROUP 4 -
RCFC PLENUMS AND AUXILIARY BUILDING ;
HOUSINGS -
2 PROCEDURES i
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WELDING MANHOUR BREAKDOWN TYPE OF WELDING ,
PERCENT OF TOTAL MANHOURS HANGERS 40%
(1 PROCEDURE AVAILABLE)
HANGER TO DUCT 15%
(4 PROCEDURES AVAILABLE)
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SEALWELDkNGHOUSINGSANDDUCT 45%
(2 PROCEDURES AVAILABLE)
(0207D) e
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NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT
.. DECEMBER 20, 1983 PULLMAN SHEET METAL FILLER METAL CONTROL
- 1. ALL WELDING FILLER METAL IS CERTIFIED MATERIAL.
- 2. -WELDING MATERIAL' REQUIRING ENVIRONMENTAL CONTROLS (E-7018, E-308 AND E-309) HAS HAD CONTROLLED ISSUANCE.
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- 3. LISTED BELOW ARE THE QUANTITIES OF THE VARIOUS FILLER METALS WHICH HAVE BEEN USED ON-SITE:
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TYPE OF FILLER METAL QUANTITY SMAW C-7018 12,875 POUNDS E-6013 1,350. POUNDS E-308 155 POUNDS E-309 420 POUNDS MIG ER705-2 2,430 POUNDS ER308 360 POUNDS ER309 1,420 POUNDS E71T-GS 1,700 POUNDS SILICON RCU SI-A 750 POUNDS
- BRONZE 5
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14 . -VERIFICATION OF PROPER FIL.5.ER METAL USAGE:
A. 100% VISUAL INSPECTION OF HANGER WELDS IDENTIFIED NO l EVIDENCE OF SILICON-BRONZE.
B. REVIEW 0F CERTIFIED MATERIAL TEST REPORTS FOR TWO (2)
HEATS OF E6013 SHOWS A.CTUAL TENSILE STRENGTH TO BE 70KSI OR GREATER.
C. PERFORMED RAND 0M INSPECTION OF HANGER WELDS TO IDENTIFY POSSIBLE IMPROPER USAGE OF STAINLESS STEEL FILLER METAL.
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NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20, 1983 PULLMAN SHEET METAL QUALITY CONTROL INSPECTION OF WELDING
- 1. MARCH, 1978 TO SEPTEMBER, 1979 (SHUTDOWN)
A. 100% WELD INSPECTION BY PULLMAN SHEET METAL FOREMAN B. 10% WELD INSPECTION BY PULLMAN SHEET METAL QUALITY CONTROL i
l C. 10% WELD INSPECTION BY PITTSBURGH TESTING LABORATORIES
- 2. APRIL, 1980 (RESUMPTION OF WORK) TO PRESENT A. 100% WELD INSPECTION BY PULLMAN SHEET METAL QUALITY CONTROL .
l B. 10% WELD INSPECTION BY PITTSBURGH TESTING LABORTORIES C. PERFORMED INSPECTION OF PREVIOUS WELDING (COMPLETED INSPECTION JANUARY, 1983)
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- 3. NOVEMBER, 1982 TO PRESENT A. ' INSTITUTED 100% CONFIGURATION INSPECTION OF PREVIOUS WORK (COMPLETED INSPECTION MAY, 1983)
- 4. AS OF MAY, 1983 ALL PREVIOUS DUCT HANGER WORK HAD BEEN INSPECTED FOR-WELD QUALITY AND CONFIGURATION.
A. INSPECTION RESULTED IN 1480 CORRECTION NOTICES (CN'S)
ESTIMATED QUANTITY OF WELD'S INSPECTED IS 55,000.
B. CN'S WERE REVIEWED TO ANALYZE RESULTS OF WELDING DISCREPANCIES.
684 CN'S ON HANGER TO HANGER WELDS COVERING 4029 WELDS 441 CN'S ON HANGER TO DUCT WELDS COVERING 1726 WELDS 90% OF INSTALLATIONS ACCEPTABLE.
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S. JULY, 1983 TURNED IN 50.55(E) ON DUCT FITTING CONFIGURATION.
A. BEGAN INSPECTION OF INSTALLED DUCT FITTINGS. INSPECTION :'
0F INSTALLED DUCT AND FITTINGS SCHEDULED TO COMPLETE SEPTEMBER, 1984.
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- 6. FEBRUARY, 1983 TO AUGUST, 1983 A. INSTITUTED INPROCESS INSPECTION OF WELDING BY PULLMAN SHEET METAL QUALITY CONTROL B. INSPECTED A MINIMUM OF THREE (3) WELDERS PER WEEK C. SEVENTY-EIGH'T (78) SURVEILLANCES PERFORMED TO DATE WITH ONLY ONE (1) DEFICIENCY NOTED. THE DEFICIENCY WAS AN ERROR IN THE WELDING PROCEDURE.
- 7. AUGUST, 1983 TO PRESENT A. INSTITUTED 100% INPROCESS INSPECTION OF WELDING BY PULLMAN SHEET METAL QUALITY CONTROL TO ESTABLISH CONFIDENCE LEVEL ON NEW PROGRAM IMPLEMENTATION.
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(0179D)
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NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20, 1983 PUILMAN PROGRAM IN FFFECT SINCE AUGUST. 1983 s
- 1. EXPANDED SHOP TICKET t
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- 2. WELDING PROCEDURE PRE-ASSIGNED BY PULLMAN SHEET METAL ENGINEERING i
- 3. TYPE OF WELD R0D AND HEAT NUMBER USED-0N INSTALLATIO RECORDED ON SHOP TICKET
- 4. WELDER I.D. RECORDED ON SHOP TICKET (0216D) d b
8
REVIEW OF PROCEDURES l
A. S & L has reviewed all Pullman Site and Shop procedures, duct brochure details, design drawings, field change requests..
f B. Q.A. is 100% in line in assuring all procedures received 8 & L review before implementation. ,
C. S & L and Q.A. review all procedures against Specification L-2782, FSAR committments, Q.A. Manual compliance. AWS Dl.1
. guidelines, and previous concerns with HVAC erection.
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APPROVED MATERIAL PSM's procurement, control, and incorporation of only approved materials (including filler materials) 0.A. verified 100% of Pullman's material adequacy on:
Q.A. Audit 20-82-20 s
Q.A. Audit 20-82-30 i
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WELDER TRAINING f
All Pullman's welders received documented training for each procedure:
Training Covered Material Specifications Welding Processes Position of Welding Filler Metal Classifications Single or Multiple Pass 1
4 Welding Current i
Polarity Welding Progression Preheat and Interpass Temperatu'e r ,
. 1 Electrode Size i Amperes Range Voltage Range Types of Joints - Details Site Q.A. has verified this documented training.
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O.A. WITNFSSTNG DE QUAlTFTCATION TFSTE SITE Q.A. HAS WITNESSED SITE WELDER QUALIFICATION TESTS. SINCE FEBRUARY OF 1981, Q.A. HAS WITNESSED 404 AWS GUIDED BEND QUALIFICATION TESTS.
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4 Egg IN-PROCESS SURVEILLANCES From February through June, 1983, Pullman Q.C. Performed 78 in-process surveillances of actual welding. From June through December, 1983. PSM Q.C. has performed an additional 488 in-process was surveillances - no instance of improper fille" material placement observed. s i
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'l CONFIDFNCE DilE 10 SIZE DE WORK FORCE (1) ONLY A SMALL NUMBER 0F WELDERS (2) WORKING WITH A LIMITED NUMBER OF ACCEPTABLE WELDING PROCEDURES 1
(3) DEALING WITH FAMILIAR CONFIGURATIONS AND DETAILS RESULTED-IN CONFIDENCE THAT PROPER WPS AND FILLER MATERIAL WAS USED.
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! EIL SURVFIt I ANCFE DIRECTFD B1 Q.A.
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i i A) 105 OVERVIEW 0F ALL PSM WELD INSPECTIONS. FROM 1980 i THROUGH 1983, 9132 WELDS WERE EXAMINED WITH 8577 FOUND
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ACCEPTABLE (94% ACCEPTANCE LEVEL).
B) RANDOM OVERVIEW SURVEILLANCES DIRECTED BY Q.A. ON i CONFIGURATIONS, HOUSEKEEPING, STORAGE, WELDING DETAILS.
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l C) UNIT CONCEPT INSPECTIONS -
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! A PLANNED SERIES OF SURVEILLANCE MODULES WHICH PROVIDE
~ INDEPENDENT DESIGN COMPLIANCE VERIFICATIONS -
OF 1121 ASPECTS ON PSM WELDING COVERED IN 14 UNIT CONCEPT INSPECTIONS, 877 WERE FOUND ACCEPTABLE. (THIS SAMPLE WAS OF BOTH SAFETY RELATED, NON-SAFETY RELATED,'
COMPLETE AND INCOMPLETE CONSTRUCTION,-INSPECTED AND UNINSPECTED ITEMS.)-
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(1246A) ,
, .n- - . - . . - . , - - , , , - . , . , ,,,,--,-e, - . - - - - , - - - . . - , , . . , , . ~ , .,---+.-w ---,-.a ,.. , , ., , --,
e SITE O.A. AUDITS QE PULLMAN'S ACTIVITIES i
15 audits performed from May. 1980 through November. 1983 (two
, of these is PSM Chicago Shop) i
.i 218 total questions 32 were related to welding activities and welder s
qualifications 44 were referenced to 10CFR50 Appendix B 69 were referenced to Pullman's proceduces 42 were referenced to Pullman's Q.A. Manual 18 were referenced to ANSI daughter documents l
8 were referenced to Spec. 2782 requiremente 1
8 were referenced to Regulatory Guides 3 were referenced to ANS D1.1
- NOTE - some questions had more than one reference.
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O.A. SURVEILLANCES l
Site Q.A. performed 119 surveillances from April, 1980 through tne present'and of these,
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59 addressed welding, we1 der qualifications or control of I weld filler material.
s 12 documented actual witnessing of welding in compliance with. correct welding procedure.
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i 1 extensively cocumented a review of all WP5 documentation.
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! 1 involved actual destructive testing to verify the correct i
WPS was used.
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8 covered large samplings of acceptability of welder qualifications.
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1 929x AUDITS Four of the General Office Audits conducted between April, 1981 tnrough October, 1983, examined Pullman's on site activities.
A total of 75 quest' ions were asked.
s all questions examined welding controls, welder qualifications, and filler metal control.
- 62 questions were referenced to 10CFR50 Appendix B.
7 questions were referenced to Ceco Q.A. Manual compliance.
1 question was referenced to Pullman's Q.A. Manual.
- 30 questions were referenced to Regulatory Guides.
3 questions were referenced to Pullman's procedures.
- 29 questions were referenced to Specification ,
requirements.
NOTE: Many questions had more than one reference.
Additionally one of the General Office Audits which examined PSM (3/11-15/02) was composed of all LaSalle auditors with experience in LaSalle HVAC concerns. Another audit (9/20-10/11/82) utilized a cognizant LaSalle auditor to audit Pullman's program adequacy.
(1244A)
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O.A. PIRECTED " RETRO" PROGRAMS I
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A) 100% visual verification of all previous (1) welding. (2) duct and hanger configuration, and (2) equipment i
installation was required of Pullman (Jan.. 1983).
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B) Site Q.A. issued a Stop Work on all new work (except in U-1 s
D/G Room) in June of 1983, to allow Pullman to complete the a
re-verification program.
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c) Re-verification program resulted in large numbers of Correction Notices being generated and the status of generation and closure of CN's was reported to and closely I . monitored by Site O.A. (weekly status).
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t BASES EDR CONSIDERING PutiMAN's !
t EASI. PRACTf CFS ACCFPTABLE i
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- 1. S & L REVIEW AND APPROVAL OF ALL PROCEDURES.
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! 2. P.S.M. INSTALLED 0(LY VERIFIED ACCEPTABLE MATERIALS.
t i 3. DOCUMENTED TRAINING OF ALL WELDERS. :
i I 84 . SITE Q.A. HAS WITNFSSED 1005 0F ALL WELDER QUALIFICATIONS. )
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- 5. ONLY A LIMITED NUMBER OF ACCEPTABLE WELD'ING PROCEDURES AVAILABLE.
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- 6. P.S.M. HAD PERFORMED IN-PROCESS WELDING SijRVEILLANCES. t 4
l 7. P.T.L. PERFORMING SURVEILLANCES FOR Q.A.
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i 8. Q.A. AUDITS j .
i (A) AUDITS ON PULLMAN REFERENCED TO ALL REQUIREMENTS. .,
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(B) SURVEILLANCES ON PSM COVERED WELDING. .
(C) G.0. AUDITS OTILIZING OFF-SITE AUDITORS.
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- 9. Q.A. ATTENTION TO P.S.M.'S STATUS OF INSTALLATION AND INSPECTION. '
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OVERALL POSITION I
I Although. Ceco has directed Pullman to upgrade the quality of tne documentation of their Q.C. pre-welding. in-process, and post weld inspection checks in response to the NRC inspectors concerns.
> the up front programatic controls listed above were and still gig adequate to control the welding performed by PSM.
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1 -PROCEDURAL CONCERNS PERCEIVED TO AFFECT HARDWARE 4.3.7 - MINIMUM EMBED.DED CONDUIT BEND RADIUS VERSUS S & L SPEC. EF-103 l 4
4.8.7 - INCORPORATION OF EF-103 REQUIREMENTS IN QC PROCEDURE 4.3.8 - PRECAUTIONS TO BE TAKEN ON SENSITIVE CABLE PULLS t
(0215D) ,
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2 - PROCEDURES REQUIRING MINOR CLARIFICATIONS I
4.3.5 AND 4.8.5 - REVISE THE CABLE PAN INSPECTION FORM TO MATCH THE INSTALLATION REQUIREMENTS 1 4.8.5 - CLARIFY QUALI,TY CONTROL'S RESPONSIBILITY CONCERNING "IN PROCESS" INSPECTION OF CABLE PAN BOLTING s
4.8.8 - CLARIFY PROCEDURE REQUIREMENTS WITH REGARDS TO INSPECTION FOR - SHARP EDGES AND TRAY EDGE SOFTENERS 4.8.8 - EXPAND / CLARIFY THE PROCEDURE TO SHOW HOW QC VERIFIES:
1 PROPER TYPE / SIZE OF CABLE INSTALLED PER DESIGN ROUTING NO REVERSE BENDS 4.3.13- EXPAND / CLARIFY TOROUE REQUIREMENTS FOR ELECTRICAL CONNECTIONS 4.3.8 AND 4.8.8 - EXPAND THE INSTALLATION AND INSPECTION REQUIREMENTS FOR CABLE GRIPS ,
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(0215D) ,,
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kK. .COMSTOCK &_ COMPANY;lNC . QA:SEET
.BACKt0G: DOCUMENT REVIEW'STATIIS-(B; Brown-)
Week-off f Jv,r3- Repori.- by: D~ater ec-//.t Ar.ea; ; Documents;Rev2.eweo.j Documents; to: 7. completeo.
e this: week- I Review _
Welding (1) ! 37- /.0 c4 : 7?crl--% /'T i Configurations (2) 5-/e/ 7 z/ ^; __
E /de Terminationsf3) 6 ^/-04 -- % /0.7 '
Jhnerien- Bbres(4-) & . / 77.f' G--,4 / 7. I Chbiet Thtv(5') . r:- r 495 -cHhr / ~; ** $
Cbnduit(6-1 e e is- o- A Eauirmentf7) # p.3 - -G:-% /c.7 5 CIA's(8) & 9 72,57 We 7. 'I !
Tbtali9) ac, 33*H n- -%.-P-75 '~ **.
CR8LE .
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IN*whG'k5kerovs'_ . tan %
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- SITE RFVIEW BOARD MAKE-UP c
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, f. CECO Q.A.
PROJECT CONSTRUCTION PROJECT MANAGEMENT L. K. COMSTOCK (1) Q.C.
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(2) Q.A.
(3) PRODUCTION (ii) ENGINEERING 1
i THESE REVIEWS ADDRESS THE FOLLOWING ASPECTS FOR EACH PROCEDURE REVISION.
(1) CECO LESSONS LEARNED FROM BYRON /LASALLE (2) LKC LESSONS LEARNED FROM FERMI / COOK / PERRY )
1
/ ' (3') . RECENT SPECIFICATION CHANGES s..
' ( 84 )
ANY PENDING CECO, LKC, NRC AUDIT ITEMS
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.I (5) ANY ASSOCIATED Q.C. CONTROLS OR Q.A. ASPECTS RESULTING FROM SUCH CHANGES
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(6)l. FUTURE PLANNED WORK ACTIVITIES
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EIL INSPFCTIONS PITTSBURGH TESTING LABORATORIES INSPECTION ACTIVITIES s
(A) A 10% OVERVIEW INSPECTION OF ALL LKC WELDING 4
INSPECTIONS.
(B) RANDOM OVERVIEW SURVEILLANCES DIRECTED BY Q.A.
EXAMINING FOR SPECIFICATION COMPLIANCE AND PROCEDURE ADHERANCE.
(C) UNIT CONCEPT INSPECTIONS - TO DATE 61 SUCH SURVEILLANCES HAVE BEEN COMPLETED WITH 44 HEAVILY COVERING ELECTRICAL ASPECTS.
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Q.A. SITE AUDITS J
42 AUDITS CONSISTING OF 423 QUESTIONS MAY '80 - PRESENT QUESTIONS s
REFERENcFs # REF. AunfTED 10CFR50 APPENDIX B 86
{ LKC PROCEDURES 270-
- LKC Q.A. MANUAL 57 ANSI 41 REG. GUIDES 11 I
38 OTHER QUESTIONS REFERENCED SUCH THINGS AS:
a
- CECO Q.A. MANUAL NATIONAL FIRE CODE -
' SPEC. L-2790A .
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- NOTE MANY QUESTIONS HAD MORE THAN ONE REFERENCE.
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0.A. SURVEftt.ANCFS FROM START-UP IN 1980 THROUGH THE PRESENT, 270 SURVEILLANCES-NAVE BEEN PERFORMED ON LKC. THE AREAS REVIEWED (AGAINST REGULATORY BASIS, ANSI DAUGHTER DOCUMENTS, FSAR COMMITTMENTS, SPEC. L-2790A, LKC i
PROCEDURES) INCLUDED, BUT WERE NOT LIMITED TO, HOUSEKEEPING, STORAGE, WELDING, CABLE PULLING &
TERMINATING, DOCUMENT CONTROL ~, DESIGN -CONTROL, GENERAL FIELD ACTIVITIES, & CALIBRATION CONTROL.
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G_O. AUDITS
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5 AUDITS MAY '80 T'HRU PRESENT s 50 QUESTIONS I
40' QUESTIONS REFERENCED 10CFR50 APPENDIX B 7 QUESTIONS REFERENCED REG. GUIDES 4 QUESTIONS REFERENCED LKC PROCEDURES 2 QUESTIONS REFERENCED CECO Q.A. MANUAL
' NOTE, SOME QUESTIONS-HAD MORE THAN ONE REFERENCE
- THESE NUMBERS DO NOT REFLECT THE OCTOBER /1983 "MEGA-AUDIT" b
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k LKC CHANGES i
(1) RECENT L. K. COMSTOCK Q.C. MANAGEMENT CHANGES.
- (2) THE INCREASE IN Q.C. INSPECTOR MANPOWER LEVELS (3) THE STRENGTHENING OF LKC'S ON-SITE Q.A. GROUP-TO 2 FULL TIME AUDITORS AS POSITIVE STEPS'TO ENSURE A CONSTANTLY IMPROVING PROGRAM.
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,. - - , .e- - - --+ r --. - - , , - ,
w R BASFS EQR CONFIDFNCE 1R LKC (1) ON-SITE PROCEDURE REVIEW PROCESS 4
(2) S & L REVIEW OF ALL SITE PROCEDURES (3) PTL SURVEILLANCE ACTIVITIES DIRECTED BY Q.A.
(4) SITE Q.A. AUDITS & SURVEILLANCES (5) GENERAL OFFICE AUDITS (6). RECENT CHANGES AND INCREASES IN LKC Q.C. AND Q.A.
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I NRC ENFORCEMENT CONFERENCE l
BRAIDWOOD PROJECT l
DECEMBER 20, 1983 l EVALUATIONS MANAGEMENT REVIEWS. PROJECT CHANGES
'AND CORRECTIVE MEASURES REVIEW GROUPS
- 1. TECHNICAL SUPPORT GROUP
- 2. DANIEL CONSTRUCTION
- 3. EDISON QUALITY ASSURANCE
- 4. PHILLIPS, GETSCHOW COMPANY RESULTS
- 1. MANAGEMENT CHANGES AND ADDITIONS
- 2. RE-0RGANIZATION OF ENGINEERING AND QUALITY CONTROL DEPARTMENT
- 3. -INCREASED TRAINING FOR PERSONNEL
- 4. INCREASED EMPHASIS ON DOCUMENTATION
- 5. CLARIFY QUALITY ASSURANCE PROCEDURES (0186D) . .
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NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20, 1983 s
AGENDA AS A RESULT OF REVIEW GROUPS WORK, MANY OF THE PROBLEMS IN THE FOLLOWING FOUR (4) AREAS HAD BEEN PREVIOUSLY IDENTIFIED AND CORRECTIVE ACTIONS WERE UNDERWAY AT THE TIME OF NRC INSPECTIONS.
4
- 1. SMALL BORE FIELD ROUTING CHANGES 4
- 2. VERIFICATION OF FIELD ROUTED DIMENSIONS 4 3. MATERIAL TRACEABILITY
- 4. 'SMALL BORE PIPE SUPPORT SELECTION (0187D)-
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P.G. CO. SMALL BORE INSTALLATION PROCEDURE - QCP-B21 - DEPICTS CLASS 2 & 3 ONLY; CLASS 1 PIPING CHANGES ALWAYS GO TO A.E. FOR PRIOR i
, ALTHORIZATION/ APPROVAL QCP-B21 ENGINEERING WELDING Q.C. A.N.I. PRODUCTION l !
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REV. I t ISSUANCE FOR
^ '
REV. 2 PRODUCTION REV. 3 O I Q
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REV. 4 s WELD / BEND #
~ ASSIGN)ENT &
[o_\ ; _ _ _ _ _. _~ O l
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i CHANGE ACTION (AS REQUIRED) l ,
j l COMPLETION I
REV. 4 .
~
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ISSUANCE FOR SUPPLEMENTS i PRODUCTION S - REV. 0 S - REV. 1 O '
_ WELD / BEND #
Q
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S - REV. 2 i ASSIGNMENT &
%/ V V-l CHANGE ACTION (AS REQUIRED) l COMPLETION l
REV. 5 DRAWING DRAWING DRAWING DRAWING ISSUANCE TO ISSUANCE TO DEVELOP)ENT WELD REVIEW ' REVIEW, HOLD REVIEW,j DOCUMENT PRODUCTION
& WELD / BEND # 6 APPROVAL ; POINT ASSIGN- HOLD , STATION FOR WORK PRE-ASSIGNMENT lNENT AND POINT I FOR REIIASE jAPPROVAL ASSIGN-jTOWORK l MENT, 6 1
APPROVAL l DOCUMENT l PRODUCTION l STATION O O O I O_ _'j:
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ISSUANCE FOR PRODUCTION l l
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O O O -
O- r. l EO V o v i
' CHANGE l wswa COMPLETION
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NRC ENFORCEMFNT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20, 1983 SMALL BORE FIELD ROUTING CHANGES -
CLASS 2 AND 3 ONLY OCP B71. REVISIONS 0. 1. 2. 3. 4 i
- 1. QUALITY CONTROL /ANI REVIEW AND HOLD POINT ASSIGNMENT OF INITIAL PACKAGE.
- 2. ALL CLASS 1 PIPING ROUTING CHANGES SENT TO ,
ARCHITECT / ENGINEER FOR REVIEW AND APPROVAL.
- 3. QUALITY CONTROL /ANI REVIEW AND HOLD POINT ASSIGNMENT OF ADDED/ DELETED WELDS / BENDS ON ROUTING CHANGES.
- 4. ROUTING REVISIONS MARKED IN RED.
I (0175D)
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i NRC ENFORCEMENT CONFERENCE )
l BRAIDWOOD PROJECT DECEMBER 20, 1983 SMALL BORE FIELD ROUTING CHANGES -
CLASS 2 AND 3 ONLY OCP B21. REVISION 4. SUPPLEMENTS 0. 1. 2
- 1. ADDED FIELD ENGINEERING REVIEW AND APPROVAL'0F ROUTING CHANGE PRIOR TO ERECTION.
- 2. INCORPORATED QUALITY CONTROL DIMENSIONAL VERIFICATION OF INSTALLED PIPING PER PGCP-40.
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- 3. INCORPORATED QUALITY CONTROL DIMENSIONAL VERIFICATION OF ALL PIPE, VALVE AND COMPONENT HEAT NUMBERS ON FIELD INSTALLATION DRAWINGS.
(0176D) i
NRC ENFORCEMENT CONFERENCE 3 BRAIDWOOD PROJECT DECEMBER 20, 1983 -
I SMALL BORE FIELD ROUTING CHANGES - CLASS 2 AND 3 ONLY 4
4 OCP B21. REVISION S 1
4
- 1. COMPLETE REWRITE OF PROCEDURE
! A. UPDATE T0' ESTABLISH PROCEDURAL / QUALITY ASSURANCE
! MANUAL CONSISTENCY AND STANDARDIZE PROCEDURAL FORMATS AND INCORPORATE NEW MANAGERIAL CONCEPTS.
1 B. INCORPORATE ALL SUPPLEMENTS INTO PROCEDURE
- 2. EXPANDED GENERALIZED QUALITY CONTROL INSPECTION REQUIREMENTS TO BE MORE SPECIFIC.
- 3. ADDED REQUIREMENT FOR FIELD CHANGE ORDER (FCO) INITIATION AND APPROVAL BY ENGINEERING OF ROUTING CHANGES.
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- 4. ADDED DOCUMENT STATION REQUIREMENTS.
- 5. IDENTIFIED RECORD RETENTION REQUIREMENTS -
TEMPORARY / PERMANENT.
(0177D) j I
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NRC ENFORCEMENT CONFERENCE
, BRAIDWOOD PROJECT DECEMBER 20, 1983 i
VERIFICATION OF FINLD ROUTED DIMENSIONS s
APRIL, 1983 - PHILLIPS, GETSCH0W COMPANY SITE QUALITY ASSURANCE AUDIT IDENTIFIED FINDING -
LACK OF QUALITY CONTROL VERIFICATION OF FIELD ROUTED SMALL BORE PIPING DIMENSIONS.
MAY, 1983 - PHILLIPS, GETSCH0W COMPANY DEVELOPED, OBTAINED APPROVAL FOR PGCP-40 " VERIFICATION. PREPARATION AND TRANSMITTAL OF AS-CONSTRUCTED DRAWINGS".
- 1. RESPONSE TO PHILLIPS, GETSCHOW COMPANY QUALITY ASSURANCE DEPARTMENT FINDINGS.
MAY, 1983 -
PHILLIPS, GETSCHOW COMPANY IMPLEMENTED PGCP-40, VERIFICATION OF PREVIOUSLY INSTALLED PIPING.
OCTOBER, 1983
- PHILLIPS, GETSCHOW COMPANY CHANGED ALL PIPING ,
INSTALLATION PROCEDURES TO REQUIRE )
"AS-CONSTRUCTED" VERIFICATION AS PART OF I INSTALLATION INSPECTION CRITERIA.
FEBRUARY, 1984 - PGC0-40, VERIFICATION OF PREVIOUS INSTALLATIONS WILL BE COMPLETE.
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BRAIDWOOD PROJECT DECEMBER 20, 1983 VERIFICATION OF FIELD ROUTED DIMENSIONS PGCP-40
- 1. PROVIDES SPECIFIC DIMENSIONAL CRITERIA FOR VERIFICATION OF PIPING CONFIGURATION (INPUT PROVIDED BY ARCHITECT / ENGINEER).
- 2. PRODUCTION DEPARTMENT TAKES DIMENSIONS.
- 3. QUALITY CONTROL DEPARTMENT PERFORMS 100% VERIFICATION.
- 4. NOTES IF PIPING IS WITHIN 3 INCH OF ANOTHER INSTALLATION AND POINT OF THAT LOCATION.
- 5. ESTABLISH TRANSMITTAL MECHANISM OF "AS-BUILT" DRAWINGS.
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NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20, 1983 PGCP-40 -
VERIFICATION STATUS - SMALL BORE SCOPE OF PGCP-40 IN MAY, 1983 (ASME SMALL BORE DRAWINGS 758 i
COMPLETED AS-CONSTRUCTED ASME SMALL BORE DRAWINGS PER PGCP-40 TO DATE 869 TOTAL INSTALLED ASME SMALL BORE DRAWINGS TO DATE 979 AS-CONSTRUCT STATUS OF INSTALLED SMALL BORE PIPING 89%
TOTAL ASME SMALL BORE DRAWINGS DEVELOPED BY PHILLIPS, GETSCHOW COMPANY TO DATE 1,335 PGCP-40 SHALL BE UTILIZED TO AS-CONSTRUCT. ALL ASME SMALL BORE DRAWINGS INSTALLED PRIOR TO QCP-B21, REVISION 5.
(0212D) 8
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NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20, 1983 MATERIAL TRACEABILITY NOVEMBER, 1982 - PHILLIPS, GETSCHOW COMPANY REVISED WELD DATA REPORT TO REQUIRE VERIFICATION OF MATERIALS JOINED BY WELDING PROCESS ON LARGE BORE PIPING.
APRIL, 1983 - PHILLIPS, GETSHOW COMPANY QUALITY ASSURANCE IDENTIFIED DEFICIENCY WITH DOCUMENTATION OF SMALL BORE MATERIAL HEAT NUMBERS ON DRAWINGS.
JUNE, 1983 -
PHILLIPS, GETSCHOW COMPANY REVISED QCP-B21 TO .
REQUIRE VERIFICATION OF SMALL BORE MATERIAL HEAT
! NUMBERS ON DRAWINGS.
i JULY, 1983 -
COMMONWEALTH EDIS0N COMPANY REPORTED POTENTIAL .
50.55(E) DEFICIENCY - QUALITY CONTROL -
VERIFICATION OF HEAT OR MARK NUMBERS OF INSTALLED PIPING SYSTEM COMPONENTS WAS NOT ADEQUATELY DOCUMENTED.
AUGUST, 1983 - SURVEY STARTED BY PHILLIPS, GETSCHOW COMPANY UTILIZING MIL-STD-105D TO ESTABLISH TRACEADILITY.
JANUARY, 1984 -
TRACEABILITY SURVEY PLANNED COMPLETION.
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SMALL BORE CUMULATIVE SAMPLE 2 INCH AND UNDER TOTAL NUMBER OF DRAWINGS IN SAMPLE -
128 s
TOTAL NUMBER OF ITEMS TO VERIFY -
1415 TOTAL ITEMS VERIFIED IN THE FIELD -
1230 86.9%
TOTAL ITEMS VERIFIED THROUGH DOCUMENTATION -
1383 97.7%
- TOTAL ITEMS VERIFIED IN THE FIELD & THROUGH DOCUMENTATION -
1414 99.9%
TOTAL ITEMS NOT VERIFIED TO BE TRACEABLE IN THE FIELD OR THROUGH -
DOCUMENTATION _1_ .1%
NOTE: THIS ITEM WAS IDENTIFIED ON A PHILLIPS, GETSCHOW COMPANY ,
NONCONFORMANCE.
0
, , , NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20, 1983 MATERIAL TRACEABILITY -
SUMMARY
- 1. PHILLIPS, GETSCH0W COMPANY HAS INITIATED CORRECTIVE ACTIONS TO FULLY DOCUMENT MATERIAL TRACEABILITY DURING THE INSTALLATION PROCESS.
- 2. A SAMPLE VERIFICATION SHOWS THE ADEQUACY OF SMALL BORE MATERIAL i
TRACEABILITY FOR PREVIOUS INSTALLATIONS.
SMALL BORE SAMPLE SIZE 1415 ITEMS 1
TRACEABILITY MARKINGS VERIFIED IN FIELD 1230 ITEMS (86.9%) '
TRACEABILITY MARKINGS VERIFIED BY DOCUMENTATION 1383 ITEMS (97.7%) .
TRACEABILITY MARKINGS VERIFIED IN FIELD AND BY DOCUMENTATION 1414 ITEMS (99.7%)
- 3. IN ALL SAMPLE CASES PHILLIPS, GETSCHOW COMPANY HAS A STORES REQUEST DOCUMENT TO SUPPORT THE TRACEABILITY MARKINGS VERIFIED IN FIELD.
- 4. SIMILIAR RESULTS ARE BEING OBTAINED FOR LARGE BORE PIPING MATERIAL.
- 5. FINAL REPORT - 50.55(E) WILL DOCUMENT SAMPLE RESULTS AND CONCLUSION. -
(0213D) ,
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i SMALL BORE PIPING SUPPORT SELECTION ACTIVITY BY PHILLIPS, GETSCHOW C0. AT BRAIDWOOD COMPARIS0N OF LASALLE PIPING CONTRACTOR'S ACTIVITIES AND BRAIDWOOD PIPING CONTRACTOR'S ACTIVITIES
( b b M) (PHil 1.1 HOW CO.
SUPPORTED HOT PIPING s YES NO SUPPORTED COLD PIPING YES . YES CONCEPTUAL SUPPORT DESIGN YES N0 SELECTION OF TYPICAL SUPPORT DETAILS YES YES METHOD & DATA UTILIZED: *PI-LS-16 SIMPLIFIED GUIDELINES ANALYTICAL LOCATIONS YES NO THERMAL LOADS & MOVEMENTS YES N0 DYNAMIC LOA'DS & MOVEMENTS YES N0 GLOBAL COORDINATE FORMAT (X, Y, & Z) YES NO TYPICAL CALCULATION FORMULAS YES YES
- ASSEMBLY COMP 0NENTS YES NO TYPICAL SUPPORT CONFIGURATIONS YES YES ALL BUILDING AREAS YES N0 r
'S&L PROJECT INSTRUCTION UTILIZED BY THE A.E.'S (S&L)
.AS AN INCLUSION IN THEIR(L SPEC. AS BEING ISSUED TO MO
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I PHILLIPS, GETSCHOW C
O. PROCEDURE
PGCP-22 FOR SUPPORT SELECTIONS
? ..
TOTALLY RESTRUCTED PROCEDURE, BOTH IN CONCEPT AND IN WORDING, T0:
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BE MORE SPECIFIC IN METHODOLOGY l
REINFORCE REQUIREMENTS ENHANCE TRAINING BENEFIT PROCEDURAL IMPLEMENTATION D
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PHILLIPS, GETSCHOW C
O. PROCEDURE
PGCP-22 FOR SUPPORT SELECTIONS P
SOME CHANGES MADE:
l ORGANIZATION CHANGE: ADDED CHECKER POSITION l -
- EXPANDED TRAINING: SCOPE, QUANITY AND INTENSITY l
- ADDED PROFICIENTY TEST; EVALUATION TRAINING AND l PERSONNEL COMPENTENCY
\
INSTITUTED " CONTROLLED REFERENCE BOOK l
- DEVELOPED STANDARD CALCULATION SHEETS; 20 TECHNICAL CALCULATION SHEETS AND 4 ADMINISTRATIVE CONTROL SHEETS l
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L PHILLIPS, GETSCH0W C0. PROCEDURE PGCP-22 l FOR SUPPORT SELECTIONS l
VERIFICATIONS: (ALL WERE FOUND ACCEPTABLE)
S&L TOTAL REVIEW OF WORK PRIOR TO 10/83.
S&L IMPLEMENTATION REVIEW CECO. 0.A. SURVEILLANCE AND AUDIT FORMAL PROCEDURE ACCEPTANCE / APPROVAL BY Ceco.
(PCD & 0.A.) AND THE A.E. (S&L) ,
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NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20, 1983
SUMMARY
- ~
! 1. REVIEW GROUPS IDENTIFIED MANY OF THE PHILLIPS, GETSCHOW COMPANY PROBLEMS WITH SMALL BORE PIPING INSTALLATION ROUTING CHANGES,
! QUALITY CONTROL VERIFICATION OF PIPING CONFIGURATION, PIPING l MATERIAL TRACEABILITY, AND SMALL BORE PIPE SUPPORT SELECTION.
- 2. CORRECTIVE ACTIONS WERE UNDERWAY AT THE TIME OF NRC INSPECTIONS FOR MANY OF THE PROBLEMS.
- 3. THESE CORRECTIVE ACTIONS INCLUDED MANAGEMENT CHANGES AND l ADDITIONS, REORGANIZATION OF ENGINEERING AND QUALITY CONTROL DEPARTMENTS, PROCEDURAL REVISIONS, VERIFICATIONS OF PREVIOUS ,
, INSTALLATIONS AND idAINING OF PERSONNEL.
- 4. THE STRENGHTENING OF THE PHILLIPS, GETSCHOW COMPANY QUALITY PROGRAM AS PREVIOUSLY COMMITED TO THE NRC HAS BEEN AN ONGOING I AND EVOLV!hG PROCESS AND SHOULD BE COMPLETED SHORTLY.
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1 SMALL BDRE PIPING R INVOLVEMENT ,
i I. CONCERNS ADDRESSED BY 0.A.
t II. CONCERNS CONSIDERED IN COMPL!ANCE l l ,
!!!. CONCERNS PREV!OUSLY IDENTIFIED l IV. CONCERNS NOT IDENTIFIED BY 0.A. .
V. CONCLUSION ,
e I I l
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I. CONCERNS ADDRESSED BY G.A. ..
A. MEASURING Ecu!PMENT USAGE
- 3. FIELD ENGINEER RESPONS!BILITIES C. SUPPORT SELECT!oN -
D. SUPPORT SELECTOR TRAINING o
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!!. CONCERNS CONSIDERED IN COMPLIANCE
'/
A. PGC0 AUDIT PLAN B. S & L ASSESSMENT OF PGC0 C. FIELD ROUT!bG OF P!PE
' D. ROUTING PROCEDURE ADEQUACY t
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s III. CONCERNS PREVIOUSLY IDENTIFIED l A. FCR STAMP ON DRAWING l
B. MATERIAL TRACEABILITY DOCUMENTATION
- 1. SMALL BORE l
- 2. LARGE BORE l l
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A IV. CONCERNS NOT IDENTIFIED BY Q.A. .
A. Q.C. CONFIGURATION CHECKS B. Q.C. DIMENSIONAL CHECKS l
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' C. PGC0 NCR #789~ DISPOSITION D. PGC0-INFO REQUEST INSTEA'D OF-FCR P
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s V. CONCLUSION A. MAJORITY OF ITEMS PREVIOUSLY ADDRESSED B. NEED FOR IMPROVEMENT I Q.A. PROGRAM EFFECTIVE C.
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! 3..'. NRC ENFORCEMENT CONFERENCE BRAIDWOOD PROJECT DECEMBER 20, 1983 1 ..
VIII.
SUMMARY
EXTENSIVE EVALUATION PERFORMED BY TECHNICAL SUPPORT
- GROUP AND DANIEL CONSTRUCTION
-- SIGNIFICANT ORGANIZATIONAL, PROCEDURAL, MANAGEMENT, AND PERSONNEL CHANGES
-- PHILLIPS, GETSCHOW COMPANY REPLACED ALL TOP SITE MANAGEMENT -
21 NEW PERSONNEL ON-SITE ACQUIRED MANY LASALLE AND BYRON EXPERIENCED PERSONNEL REPLACED OR ADDED QUALITY CONTROL SUPERVISORS AT
- EACH OF THE-THREE MAJOR CONTRACTORS .
ADDED ON-SITE QUALITY ASSURANCE SUPERVISOR AT EACH 0F THE THREE MAJOR CONTRACTORS i
INCREASED MAJOR' CONTRACTOR QUALITY CONTROL / QUALITY ASSURANCE 88 (os/s2) 214 (12/s3)
}
INCEASED MAJOR CONTRACTOR QUALITY CONTROL INSPECTORS 53 (os/s2) 123 (12/as)
(0217D)' -
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VIII.
SUMMARY
QUALITY CONTROL INSPECTOR RE-INSPECTION (ALL CONTRACTORS)
DOCUMENT REVIEW 10,000 LARGE BORE WELDS (PHILLIPS, ;
GETSCHOW COMPANY)
PIPING HEAT NUMBER TRACEABILITY (PHILLIPS, GETSCHOW COMPANY) 100% RE-INSPECTION INSTRUMENTATION (PHILLIPS, GETSCHOW COMPANY) 100% RE-INSPECTION HANGERS (PHILLIPS, GETSCHOW COMPANY) 100% RE-INSPECTION EQUIPMENT (PHILLIPS, GETSCHOW COMPANY) 100% DOCUMENATION REVIEW (L. K. COMSTOCK)
QUALITY CONTROL STRUCTURAL STEEL REVIEW (GKN) 100% RE-INSPECTION WELDING (PULLMAN) 100% RE-INSPECTION CONFIGURATION (PULLMAN) !
100% RE-INSPECTION DUCT BROCHURE ITEMS (PULLMAN) l l
1 (0218D)
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,' \. \ 8D Commonwealth ECson
'/ -i) one First Nationit Plan. Chic go. Ithnois
,% 1O 1 Address i'(g) Reply Chicago. Ilhnois 60690 to: Post Othee Box 767 PRINCIPAL STAFF RA DPRP January 12, 1984 A/RA RA y E sF h
RC W '.A Mr. A. Bert Davis DAO SCS Assistant Regional Administrator gg g U.S. Nuclear Regulatory Commission gjF FI10 Region III ,.
799 Roosevelt Road j/"*j Glen Ellyn, IL 60137 8emMM2
Subject:
G d.41.0c nP Braidwood Station Units 1 and 2 Response to Region III Concerns in the Areas of Piping, HVAC and Electrical NRC Docket'Nos. 50-456/457
Dear Mr. Davis:
1983, During the meeting held in your offices on December 20, discuss the recent Region III inspection findings in the areas ofth piping, During that electrical meeting and HVAC relative to our Braidwood Station.
our presentations provided the Region with an overview of many pos,itive actions that we have and are currently taking at Braidwood Station relative to these inspection The purpose of this letter is to briefly address each item offindings.
concern individually as we now understand it.
As discussed on December 20, 1983, and in the Enclosures to thisthe of letter, Commonwealth inspection findings. Edison does acknowledge and concur in some However, we do not agree with the Region's conclusions.for certain of the findings, We,are hopeful that the enclosed information will enable you and your Staff to further evaluate the merit of your inspection findings in such instances.
In.most cases, merely summarizes the information provided in the Enclosures our position.
We are available to further discuss of our conclusions available for your inspection on site.these mat Very truly your ,
E ouis 0. DelGeorg AssistantVice-Pre [sident EDS/ rap s Enclosures 7934N I
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. -.- January 11, 1984 OVERVIEW We appreciated the opportunity to present our story to you at the Enforcement Conference in your Region III offices on December 20, 1983.
It was our intent to demonstrate to you at that time that building
- quality into the Braidwood project has been in the forefront.of our thinking and that we have taken many far-reaching steps since the August, 1982 Enforcement Conference. These started with extensive evaluations and management reviews, including the Technical Support Group evaluation of the Quality Control program and work activity effectiveness of each contractor, and-the.Daniels Construction Company'c independent review of Phillips, Getschow traveler and hanger retro-fit documentation and i Quality Control's ability to support the construction effort. The steps. '
taken continued with Edison site management changes which drew heavily on
~
j LaSalle County and Byron experience. In addition, and most importantly,
} extensive changes and additions were made in the site contractors' i j organizations, primarily but not exclusively in the Quality l 1 Control / Quality Assurance areas. These-additions looked to prior nuclear 1
! construction experience to strengthen the site contractor management.
1 This new experience at Getschow has helped in totally revising'the i i traveler preparation and processing by establishing a document station i i
concept. Concurrently with these changes, large programs of
. re-inspection, re-qualifications and review were begun. Some' examples of i
these were the equipment re-inspection and hanger retro-fit programs with Getschow, the inspection documentation' review at Comstock and the hanger retro-fit effort at Pullman.~
1 The point.to be made is that many changes were in p mcess and were to the point of bearing fruit when your inspectors. visited the site
! during several inspections in 1983 and expressed the concerns cited on December 20, 1983. Some of these we had already identified: most we had not.
However, several of those concerns identified we feel we would have found as new procedures, practices and management systems were setup. In ,
addition,Emany of the concerns we disagree with,' some with regard to the essential-facts but more'so in the characterization of the concern as a basis for non-compliance. We might summarize all this as.follows: i l
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a) Concerns we believe we had previously identified:
HVAC - No. 5 Electrical -
Nos. I and 4.c)
Small Bore -
Nos. 5.a) and 5.b)
Large Bore -
No. 1.a) b) Concerns identified during recent NRC inspections which we had not previously identified:
Electrical - Nos, l., 3.d), 3.f), 4.a) 4.b)*, 5.a), 5.b)*
Small Bore - Nos. 1.*, 2.b)*, 2.c), 3., 4.a), 4.b)*, 5.c),
5.d), 7.b), 8.
Large Bore - Nos. 1.b), 2.
We believe we would have found as new procedures, practices and management systems were setup.
c) Concerns which we do not agree with or do not consider bases for Non-Compliance:
HVAC - Nos. 1., 2., 3., 4., 6., 7., 8.
Electrical - Nos. 3.a), 3.b), 3.c),13.e), 6.a), 6.b)
Small Bore -
Nos. 2.a), 6 We have attached our responses to the individual concerns expressed by your staff at the December 20th Enforcement Conference. In the discussion we have attempted to clarify the issue involved, where '
necessary, and cited whether we agree or disagree. We trust that this meets with your request that we be more responsive to the individual concerns.
With this additional information, and review of the various quality-verification efforts initiated since August, 1982, we trust that you will recognize the effectiveness of the re-inspection and verification programs and the controls that are now in place, so that you will be confident with both.
(0257d)
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SMALL BORE PIPING
- 1. Phillips, Getschow Company training program was inadequate based on numerous errors identified in the Phillips, Getschow Company hanger calculations and considering the fact that all present hanger selectors did not have prior design experience. Criteria 2.
DISCUSSION Commonwealth Edison Company (CECO) will not dispute the NRC assessment that the Phillips, Getschow Company (PGCo) training
. program was inadequate. This assessment was based on, (1) numerous
- errors identified in Phillips, Getschow Company piping support selection calculations and (2) the NRC's opinion that the present hanger selectors should have prior design experience. Commonwealth Edison Company Site Quality Assurance Audit No. 83-33 (July, 1981) identified the need for training program improvements.
Phillips, Getschow Company procedure PGCP-22, 2" and Under and 2 1/2" - 4" Process and Instrument Line Supports in Category I Buildings, Revision 7, dated April- 16, 1983, required the Field Engineer supervisor to be_ responsible for training of qualified i personnel to perform piping layout and support selection. Phillips, Getschow Company Procedure, PGCP-29, QualifYinq and Training Procedure for PG Field Hanger Selection Personnel was referenced in 3 PGCP-22, Revision 7. The training procedure, PGCP-29, establishes l the qualification and training requirements for personnel performing !
support selections. The basic requirements for support selection l personnel include the following:
- a. experience of one (1) year in support selection or a high ,
school education,
- b. documented training in PGCP-22.
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- c. familiarization with applicable project documents.(i.e. piping j line lists, piping design tables, support detail drawings, etc.).
- d. documented on-the-job training.
- e. proficiency requirements / reviews.
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~Comunonwealth Edison Company Site Quality Assurance performed an implementation verification of PGCP-29 in their Audit No. 20-82-15.
j A review of training records shows the active'and inactive support selectors in October, 1983 had the necessary training per PGCP-29. These records are available et the site for NRC review.
The need for prior design experience for support selection
' personnel is a subjective assessment by the NRC. The procedure which established the qualification and training requirements underwent multi-level reviews within Phillips, Getschow Company,'
{ Ceaumonwealth Edison Company and Sargent and Lundy. The concensus
- of the qualified reviewers was
- that the qualification and training l requirements within the procedure are adequate for the type of i
i support selection activity being conducted by Phillips, Getschow Company. Prior design experience is still not a requirement for-support selectors today. . We request the NRC re-evaluate this basis (i.e. subjective assessment) upon which the training
- non-compliance is given.
I CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED i
Commonwealth Edison Company issued a stop work order on Phillips,
! Getschow company support' selection activities until procedural and_ r traning aspects had been improved.
Sargent and Lundy completed an independent review of-previous j Process piping support selections. This review amounted to an j ir. dependent design check of Phillips,-Getschow Company support selection work. The independent review results are available at the site.
Phillips, Getschow Company has re-written PGCP-22 (Rev. 8) to
. enhance the procedure itself, as well as it's implementation and training aspects. The procedure re-write reflects improvements by.
- - the new Phillips, Getschow Company management and input from Sargent and Lundy to clarify any. support selection guidelines.
The procedure now specifies a more consistent methodology by which a selector could better select and document. calculations for-
! individual supports. It highlights-and reinforces the Sargent and Lundy requirements to the selector so he could more effectively select and calculate supports. Additionally, training requirements of PGCP-29 have been written into PGCP-22 (PGCP-29
-has been deleted) and training has been expanded in scope, j
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quantity and intensity, including the addition of a proficiency >
test.. All selector personnel have been re-trained to PGCP-22, 1
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, Revision 8. A total review of newly completed support selection has been conducted by sargent and Lundy and Commonwealth Edison Company to ensure correct procedural implementation. All reviews and audits show acceptable implementation of PGCP-22, Revision 8.
CORRECTIVE ACTION TAKEN TO AVOID RECURRENCE Commonwealth Edison Company Site Quality Assurance verified 100%
Personnel qualifications of support selectors. This verification included the checking that education, training and testing requirements of PGCP-22 Revision 8 are being met.
Commonwealth Edison Company will conduct a technical audit prior to April 30, 1984 of the Phillips, Getschow Company support selection activities. The audit results will indicate the effectiveness of the enhanced training program. If required, further corrective measures will be taken.
DATE WHEN ALL CORRECTIVE ACTION WILL BE COMPLETE All procedural changes and re-training has been completed. The auditi results and any further recommended corrective actions will be complete prior to May 15, 1984.
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(0258d)
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. e c . 2.a) Programs and Procedures established by Commonwealth Edison Company and Sargent and Lundy did not provide sufficient assessments and i
verifications of the Phillips, Getschow Company design capabilities prior to authorizing field routing in class II and III Small Bore Piping and field design of support / restraints. The
. lack of assessments and verification resulted in inadequate
- ! - understanding of the Sargent-and Lundy specifications by Phillips, Getschow Company to insure the field routing of small bore piping
.was performed within the design requirements. Furthermore, the result of,the present field routing of Class II and III Small Bore Pipes without detail drawings being issued by Sargent and Lundy or Phillips, Getschow Company resulted in the licensee established gn i program requirements being bypassed.
DISCUSSION l
Commonwealth Edison Company (Ceco)'does not agree with the above
- l Finding.
The NRC contends Phillips, Getschow Company is performing design activities during the field routing of Class II and III small bore i- piping and during support selection activities. In the October l 24, 1983 meeting held with NRC representatives, Commonwealth j Edison Company stated the. Specification wording allowed Phillips, j Getschow company to re-route small bore piping when required to clear conflicts or interferences within certain pre-approved quidelines given in the specification, which when followed, do not compromise the design basis of the piping. The conceptual piping
- j routing drawing, when used in conjunction with the specification, constitutes an approved design drawing at all times. . Comunonwealth Edison Company showed how the= specification wording was sufficient i such that the re-routed ~ piping met three (3) design checks 3
(functionality, seismic interaction and piping stress). We believed there was an understanding between Commonwealth Edison Company and the NRC that.the Phillips, Getschow company re-routing l ' activities were not design activities and not in violation of established Quality Assurance program requirements.
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, Additionally, during the october 24, 1983 meeting Commonwealth Edison Company /Sargent and Lundy presented how the support selection guidelines given to Phillips, Getschow Company to select supports are analogous to a construction drawing. Sargent and Lundy authorized the support selection guidelines. They represent a pre-calculated, pre-approved set of span length and support type selection rules which Phillips, Getschow Company must follow.
Phillips, Getschow Company cannot deviate from the rules to create unique support location and types. The legal authority (i.e.
Professional Engineer's stamp) remains with Sargent and Lundy and the guidelines. Phillips, Getschow Company does not Professional Engineer stamp the support drawings generated in the selection Process. They are not the design organization. Again,Jwe ,
believed there was an understanding between Commonwealth Edison Company and the NRC that the Phillips, Getschow Company support selection activities were'not design activities.
During the December 20, 1983 Enforcement Conference, Commonwealth Edison Company presented a chart showing the difference between-LaSalle County Station and Braidwood Station small bore piping 4
support design activities. The purpose of this chart was to show the definitive difference between work scopes at the two (2) sites. This definitive work scope difference resulted because of assessments made by Commonwealth Edison Company and Sargent and Lundy that small bore piping support " design" activities should remain with the Architect-Engineer and should not be placed with the Piping Contractor.
Commonwealth Edison Company plans no additional corrective actions regarding their programs for assessing contractor capabilities.
We will continue to monitor.and verify compliance of contractor activities with specification requirements.
(0259d) 1 i
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. 2.b) The present Phillips, Getschow Company implementing procedures for small bore pipe,-lacked specific quantitative field design installation and inspection criteria to provide clearance and or separation from equipment and components as required by Sargent
- and Lundy specification, F/L-2739, Paragraph 301.11.
1 DISCUSSION PGCP-40, Verification Preparation and Transmittal of "As
- constructed" Drawings, Revision 0, dated May 31, 1983 included a requirement to note on-the "as-constructed" drawing when the piping installation was within 3"'of another installation and indicate the point of that condition. This post-installation check went beyond the current specification requirement and did
- provide the Architect-Engineer the opportunity to evaluate j clearance of piping from other installations.
It should be noted that Phillips, Getschow Company Procedure QCP-B21 did include qualitative clearnace requirements and these were understood by the crafts.
4 CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Sargent and Lundy specification.F/L-2739 will be revised to require a minimum 3" clearance requirement of piping components from all other installations. Phillips, Getschow Company will revise their piping installation procedures to require a-contractor engineering department review of proposed field i re-routes for conformance with specification requirements prior.to 1 installation. The notation of piping installations within 3" of another installation per PGCP-40 will determine if previous installations meet necessary clearance requirements. Final quality control inspections of new installations will include a l clearance inspection.
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, . CORRECTIVE ACTION TAKEN TO PREVENT RECURRENCE Implementation of revised piping installation procedures should assure proper clearance requirements are reviewed prior to re-routing and checked at the installation.
Commonwealth Edison Company and Sargent and Lundy plan to conduct' an assessment to ascertain if other site contractors specifications / drawings adequately define component clearance requirements. Additionally, a comprehensive plant walkdown is planned prior to Fuel Load to ascertain and resolve any apparent component clearance problems.
DATE CORRECTIVE ACTIONS WILL BE COMPLETED Specification F/L-2739 and Phillips, Getschow Company procedural revisions are in progress and will be complete prior to Febraury 1, 1984. The assessment of other site contractors will be completed prior to March 15, 1984. The comprehensive plant walkdown and any required corrective work will be complete prior to Fuel Load.
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. i 2.c) PGCP-22 Requirements were not completely followed for calculations for lines ICCE3AA-1/2", ICCH3BA-1/2", 1DOD8BC-2", and IDOD8BA-01.
Criteria 3.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The supports for lines ICCE3AA-1/2", ICCE3BA-1/2", IDOD8BC-2" and IDOD8BA-01 have been sent to Sargent and Lundy for review.
j Sargent and Lundy has also conducted a review of all Phillips.
Getschow Company support selections on process piping. Their review indicated of 172 supports, 3 supports require installation tolerance adjustment and_14 supports require re-calculation to the revised Phillips, Getschow Company support selection procedure. A field review showed the three (3) supports were installed.within the revised installation tolerance. The re-calculation of the fourteen (14) other supports is in process.
Commonwealth Edison Company Site Quality Assurance performed a 4
special audit of support selection activities. (Audit No.
QA-20-83-49.) Although some calculational mistakes were
- identified, no cases were found which required a physical change to installed supports.
CORRECTIVE ACTION TAKEN TO PREVENT RECURRENCE Sargent and Lundy has revised the piping support guidelines to better clarify their requirements so support selectors do not need to interpret the guidelines. Procedure PGCP-22 has been re-written to enhance the procedure itself, as well as it's implementation and training aspects. The procedural revision Provided for better calculational consistency and reduced the chance for error. Extensive re-training has been given to support selection personnel. Additionally, Commonwealth Edison Company will conduct a special technical audit of Phillips, Getschow i
company support selection activities. _ Lastly, site Quality Assurance will continue to monitor support selection activities by audit and surveillance.
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4 6- l DATE CORRECTIVE ACTIONS WILL BE COMPLETED The guideline changes, procedural changes and re-training have been completed. The Comenonwealth Edison Company technical audit
'and any necessary corrective actions will be completed prior.to May 15, 1984.
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- 3. Field Engineer authorities, duties, and qualifications were not fully delineated in the Phillips, Getschow company Quality Assurance Manual Revision 0, dated August 26, 1983. Some of the specific work functions being performed by field engineering / craft personnel such as pipe hanger design and calculations were not adequately described in the Phillips, Getschow Company Quality Assurance Manual or Phillips, Getschow Company Procedures.
Criteria 4.
EISCUSSION 1
Commonwealth Edison Company does agree that the field engineer authorities, duties and qualifications could have been more fully delineated in the Phillips, Getschow Company Quality Assurance r
Manual, dated August 26, 1983. We do not believe that pipe hanger design and calculations were being performed by craft personnel.
The Finding should be corrected to delete the reference to craft personnel.
l CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED i
Phillips, Getschow Company has initiated a change to their Quality Assurance Manual changing Section 1.19, " Field Engineer" to read
" Project Engineer". His duties are explained in the general terms in te Quality Assurance Manual. Phillips, Getschow Company Work Instruction PGWI-4, Revision 0, dated December 23, 1983, Engineering Personnel Oualifications and Review Criteria for Responsibility Assignment, more fully delineates the duties of the Engineering Department personnel.
CORRECTIVE ACTION TAKEN TO PREVENT RECURRENCE Phillips, Getschow Company has initiated broad management changes within their site organization on August 1, 1983. The new
. management is reviewing all job functions and responsibilities with the goal of better defining an individuals job function and responsibility. This review will result in a more structured-organization.
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DATE FULL COMPLIANCE WILL BE ACHIEVED ~
i Phillips, Getschow Company management reviews and re-organizations are complete.
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} 4.a) The use of the Phillips, Getschow Company uncontrolled information request system in' lieu of the formal field change request system 1
to request.and receive approval on safety-related design changes bypassed the licensee Quality Assurance program requirements established in QP 3-1,~ there were also cases where verbal 4 instructions have altered the approved design procedure and out of date engineering change notices were utilized in hanger.-
calculations.
I CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED i
Phillips, Getschow Company initiated a review of all previous Information Requests (IR) to ascertain whether other design. ,
- information was obtained via the IR system. The review will
- include _a check to ensure any applicable design information has i been incorporated into permanent design drawings and specifications. The Phillips, Getschow company Information Request form has been revised to include the requirement that !
design information must_be transmitted.via an Engineering Change Notice (ECN) or Field Change Request (FCR) and the IR itself cannot direct design change actions.
Phillips,.Getschow Company Personnel training specific' programs now include instructions stating that-" verbal instructions cannot alter design documents behg utilized". '
i I
. A review was made of des'ign documents being utilized by ,
Engineering Department personnel. Any out-of-date documents have been purged. Procedure PGCP-22, Revision 8, Section ~1.8-specifically addresses these concerns, plus Phillips, Getschow-Company Procedure, PGCPl.1, Control of Engineerine Change Notices (ECN), Field Change Notices-(FCN), Field Change Requests (FCR) and '
l Field Problem ReDorts (FPR) were revised to more tightly control I
! the usage of design documents. 'A Work Instruction, PGWI-3, Clarification and Auenentation of PG Design Chance Revision
- Review -
(ECN, FCN, FCR, DRN, SDecification Changes, Etc.) was l written to describe and clarify the method by which Change j Documents are reviewed and-processed by the Field Engineering. I
- supervisor'(Project Engineer).
CGemECTIVE ACTION TAKEN'TO PREVENT RECURRENCE l
l 0
An increased emphasis has been placed on document control with the
- _ Phillips, Getschow company organization. _The management, organizational'and procedural changes which have taken place-should prevent. future document control' problems, i
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DATE FULL COMPLIANCE WILL BE ACHIEVED The management, organizational and procedural changes are complete. Personnel training is complete. The IR review and any required dispositions will be complete prior to June 1, 1984.
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4.b) Craft personnel had been deviating from drawings by re-routing ASME Section III, Class II and III 2" and Under Piping Lines,.
j assigning _ weld numbers and adding material were resulted in lack
- of engineering control for approving, updating and, releasing i'
drawings.. Decisions to re-route pipe which involved
- considerations such as ability to support valve accessibility and '
piping contacts / separations with other items important to safety ,
were being made during the installation processed by craft ,
personnel not trained in engineering requirements. Criteria 4 and i 2.
) DISCUSSION i
i i The Phillips,' Getschow company re-routing of ASME, Class II and
, III, small bore piping is allowed by Specification F/L-2739.
Phillips, Getschow Company procedure, QCP-B21, Installation and/or j Field Routino of Two Inch and Under Process PiDino Systems -
l .ASME Classes 1, 2, and 3 reflect the specification requirements
} and procedural controls necessary to conduct re-routing. These i controls involve drawing charges by Production, review of weld and '
i bend additions or deletions by Quality control and the ANI and red line marking of actual field routed conditions. Connonwealth '
Edison Company agrees a review of proposed field re-routes by the i contractor Engineering Department does add more assurance that important safety considerations are not bypassed.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED i i Phillips, Getschow company procedure, QCP-B21 was revised via
- j. Supplement, Revision 2, dated July 23, 1983 to require Phillips, I i
Getschow Company Engineering Department review and approval of piping re-routes prior to installation.. The method of Engineering l' Department review was further enhanced in Revision 6 to QCP-B21,
-dated October 10, 1983. The as-built routing of previous piping installations is currently being recorded. -This work is being done to Phillips, Getschow Company Procedure POCP-40, Verification, PreDaration and Transmittal of "As-Constructed" Drawines. The procedure establishes the criteria for quality I
control verification of dimensional piping configurations including clearances.
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CORRECTIVE ACTION TAKEN TO PREVENT RECURRANCE i
QCP-B21 Revision 6, greatly increases the Engineering Department ;
' involvement in the preparation of initial small bore piping
. installation packages, the review of proposed re-routes and the preparation of revised small bore piping installation packages.
Additionally. the re-organization of the Phillips, Getschow Company Engineering Department, plus the addition of personnel, ,
1 has led to greater contractor engineering. involvement in the Phillips, Getschow Company day-to-day activities.
DATE FULL COMPLIANCE WILL BE ACHIEVED The organizational and procedural changes are nearly complete.
j Full implementation of QCP-B21, Revision 6 will be complete prior j to February 1, 1984. As-builts of previous installations will be complete prior to February 28, 1984.
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1 5.a) An inspection program had not been established and executed for l quality control to verify correct material installation for 2" and under safety-related piping. Contrary to ASME Section III MA-4510
,, and Commonwealth Edison Company QR No. 10. l; j DISCUSSION Phillips, Getschow Company (POCO) Procedure QCP-B21, Installation and/or Field Routino of Two Inch and Under Process PiDino Systems ASME Classes 1. 2 and 3, established the procedural controls 7 for inspection and verification of correct.small bore process l piping material. Phillips, Getschow Company Audit No. 83-BR3
-(April 26, 1983) identified a Finding, whereby the, verification on the Production drawing of different heat numbers in the case where i more than one (1) heat number per drawing was being used was not 4
completed. In response to NRC concerns related to material '
traceability, commonwealth Edison Company filed a potential i 50.55(e) deficiency in July, 1983. This 50.55(e) stated Quality i control verification of heat or mark numbers of installed piping i systems was not adequately documented. i 4
I CORRECTIVE ACTIONS TA N AND RESULTS ACHIEVED h
l' Procedure QCP-821 was revised in June, 1983 to require verification of code small bore material heat numbers on.
drawings. Specifically, the Quality control inspector would verify all entries of traceability numbers made by Production and
! this verification would be documented by initial and date.
In order to establish a level of confidence that-material 4
traceability existed for previous Code small bore installations Phillips, Getschow Company began traceability verifications in j August, 1983. 'This verification was based on random samples of j previously installed code small bore piping selected in accordance i j with Military Standard MIL-STD-105D.
i The definitions below applied to the sampling Programs:
Total Items to Verify -
total sample number as determined by Military Standard 105D.
u Items verified in the Field - traceability is established l
since component has physical identification marking existing in the field and can be verified to an approved heat number. '
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i Items verified through documentation traceability -
traceability is established by correlation of Stores Request documentation with specific traveler package.
Items verified in the field and through documentation -
traceability is established by either physical ;
identification markings in field or correlation of Stores Request documentation with specific traveler package or both '
methods.
The sample results for small bore piping installations are the following:
Total number of items to verify -
1415 Total items verified in the field -
1250 (86.9%)
I Total items verified through documentation -
1383 (97.7%)
Total items verified in the field and through documentation -
1414 (99.9%)
The conclusions below can be reached from the above sampling:
- 1. A direct physical identification check today of previously installed piping showed the material was from approved heat j numbers for 86.9% of the sample.
- 2. An indirect documentation check today of previously installed piping showed the material was from approved heat numbers for 97.7% of the sample.
- 3. Utilizing hgitt methods, previously erected piping was installed with material from approved heat numbers for 99.9%
t of the sample.
- 4. Stores Request documentation exists to support the traceability markings verified in the field for the sample cases.
9 i
, t overall, a high level of confidence was established that material ;
traceability exists for previous Code small bore installations.
Recognizing the NRC concerns to show that correct material was utilized for code small bore piping installations. Commonwealth Edison Company proposes to complete the following verification program for previously (prior to June 1983) installed Code small bore piping installations.
- 1. A material verification field walkdown on 100% of previously installed piping will be completed. The material heat number will be recorded and/or verified on the installation
] drawing by a Quality control inspector. A check will be made to ensure that the field verified heat number is approved for use at Braidwood Station.
f 2. A Quality control verification will be made of field verified material heat numbers against the heat numbers
- recorded on the Stores _ Request'for each installation package. This verification will establish that material withdrawn from Stores was installed in the correct location.
- 3. A Quality Control verification will be made of field verified material heat numbers to ensure that the correct
, material is installed for the specific application.
)
- 4. For those cases where material heat markings are no longer available in the field, a Quality control review will be made of the Stores Request to verify that the material was approved for use at Braidwood Station and was the correct material for specific application.
- The necessary installation and quality control documentation will
! be updated to record the above verification program.
Non-conformance reports will be generated to disposition material which cannot be verified by the above program.
I CORRECTIVE ACTION TAKEN TO PREVENT RECURRENCE Installation quality control procedures have been revised to require 100% material identification of code items by Production and verification by Quality control on installation drawings, i
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I DATE CORRECTIVE ACTIONS WILL BE COMPLETE Procedure revisions and training to the revised procedures are
. complete. The 100% material verification program will be started now and complete prior to fuel Load.
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l 5.b) An inspection program had not been established and executed j _
including field examination for quality control _to verify the e
accuracy of,_the craft drawn piping re-route as documented in the j , original design l drawing to assure the proper inputs for design and U ', analysis acceptability, contrary to ASME Section III NA-4510 and t* , ,,
/
Commonwealth Edison Company QR No. 10. '
DISCUSSION t
Phillips, Getschow Company Audit No. 83-BR3 (April 26, 1983) identified a Finding regarding the lack of quality control j verification of field routed small bore piping dimensions. In response to the Audit Finding, Phillips, Getschow Company initiated PGCP-40, verification. Preparation and Transmittal of TJ-Constructed Drawines. This procedure was approved and implemented in May, 1983..,The procedure provided for the quality control verification of previously installed piping.
CGihih,tiVE ACTION TAK8Lht AND RESULTS ACHIEVED Corrective actions were already underway at-the time _of the NRC inspection to dimensionally verify piping configuration by Quality Control. These corrective actions were implemented by PGCP-40 for previously installed piping. For new installations the requirement to dimensionally verify installed piping per PGCP-40 was included in QCP-821 in June, 1983.-
CORRECTIVE ACTION TAKEN TO PREVENT RECURREMCE
{d' . ' Phillips, Getschow Company. piping installation procedures now include dimensional verification prior to final Quality Control' acceptance..
- t. ,'j DATE FULL COMPLIANCE WILL BE ACHIEVED i-u ,
t Procedural changes have been completed. The PGCP-40 verification
.,i' Program for previous installations will be complete prior to March V 1, 1984. ,, j i
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1 5.c) Random dimensional checks of piping components were not being done by either Phillips, Getschow Company or Commonwealth' Edison Company, contrary to ANSI 45.2.2 and Commonwealth Edison company QP 7-1.
RESPONSE
Commonwealth Edison Company does agree with the above Finding, but feels that it should be put in perspective when viewed against the current receipt inspection activities. Stated below are the receipt inspection checklist activities done by' Quality Control.
1.0 Physical Inspection: , ,
1.1 Material markings are in accordance with Purchase Order requirements:
1.2 CMTR or C of C compared to matebial for correct identification as to heat or heat code number: l l
1.3 Check end conditions for burrs, scale and defects:
1.4 Check I.D. and O.D. surface condition:
1.5 Enclosures, where ' required, intact:
8 2.0 Documentation Review:
2.1 Q.S.C. (M) Number and Expiration date or revision status and date of approved Quality Systems Program indicated on CMTR or C of C:
' 2.2 Chemical and Mechanical test results are in accordance with specification' requirements:
2.3 C of C reflect material specification, grade, class and heat treated condition, as applicable:
2.4 Results of test required by the purchase order and special requirements of the applicable ASME III Sub-Section reported (Charpy CV impact, Volumetric,. ,
NDE, Etc.):
2.5 Date of review of C of C or CMTR by the Authorized Nuclear Inspector, as indicated by 1.?'tals and date:
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CORRECTIVE ACTION AND RESULTS ACHIEVED There have been 120 different small bore pipe heat lots received on site to date. Forty-five (45) heat lots were completely used in non-safety-related areas. Portions of the remaining seventy-fiva (75) heat lots were used for safety-related applications.. All seventy-five (75) heat lots have been dimensionally verified (on a random basis) by Quality Control and all wall thickness checks were found acceptable.
N CORRECTIVE ACTION TAKEN TO PREVENT RECURRENCE Phillips, Getschow Company Procedure QAP-33 Supplement, Revision-1, dated June 24, 1983 provides a Quality Control inspection plan for dimensional verification of piping wall thickness.
DATE CORRECTIVE ACTION WAS COMPLETED Corrective actions have been completed.
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5.d)- There was no documented record or log specifying that a calibrated instrument'was used to measure numerous pipe bends for ovality.
Examples include the bends on drawings M-2546C-72, M-2546C-44,.
M-2546C-42, M-2546C-31, contrary to Phillips, Getschow Company Quality Procedure No. 7. Criteria 10 and 8.
CORRECTIVE ACTION AND RESULT ACHIEVED' The recording of testing equipment I.D. numbers on field travelers'
.has always been required by the Phillips, Getschow Company Quality Assurance Manual. It appears that since a specific blank was not provided on.the traveler for the caliper.I.D. the I.D number.was not recorded. A' letter was issued to the field Quality control on July 5, 1983'by the Quality control supervisor instructing the field to indicate the caliper number on the traveler.- A review by Phillips, Getschow Company Quality control determined that none of
.the calipers used to measure ovality have ever gone out of calibration or required repair / adjustment.
CORRECTIVE ACTION TAKEN TO PREVENT RECURRENCE Phillips, Getschow Company Quality Procedure 7 supplement,
. Revision.4, dated January 3, 1983 was prepared and issued to Commonwealth Edison Company for approval. This supplement requires the Quality control Inspector to indicate the caliper number on the traveler when inspecting ovality.
DATE CORRECTIVE ACTION WILL BE COMPLETE-'
The revised' procedure will be approved prior to February 1, 1984.
Interim measures to assure recording of measuring and test equipment are in place. '
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! '6. The use of the uncontrolled information request system by l 4
Phillips, Getschow Company in lieu of the Field Change Request l System prevented the timely identification and correction of
, non-conforming conditions. Criteria 15.
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DISCUSSION J
Commonwealth Edison Company does not understand this Finding for the following reasons:
- 1. Field Change Requests are not utilized by our program to resolve non-conforming conditions, our program requires the.
use of non-conformance reports per Q.P. 15-1.
I
- 2. No objective evidence was presented at the December 20,
- 1983, Enforcement Conference to substantiate the use of i Information Requests to resolve non-conforming-conditions.
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, We believe this Finding should be withdrawn by the NRC.
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7.a) The installation of small bore / instrumentation piping began before March, 1981, and the small bore process piping before July, 1981, the licensee audit did not reveal the PGCo hanger design problems until two years later on July, 1983, which coincided-with Region
'III inspection. This is evidence that commonwealth Edison company's inability to identify and correct non-conformances in a timely manner.
DISCUSSION Commonwealth Edison Company does not agree with the NRC Finding that problems with the Phillips, Getschow Company support 4
selection program were not identified and correction of identified non-conformances were not done in a timely manner. We would like to clarify the concern. The history presented below represents the Site Quality Assurance Department activity in this area. The history shows that an audit had been conducted and work r:opped on safety related instrumentation piping support selection in October, 1981. The history also shows the times when various instrumentation line and small bore process pipe activities had been started. (For example, safety related small bore process piping support selection started in January, 1983). The history demonstrates that Site Quality Assurance was actively involved in this area.
INSTRUMENTATION Upon approval of Phillips, Getschow Company procedure PGCP-22, Rev. 1. safety-related instrumentation line support selection ,
started in July, 1981. After enough work had been completed so '
that a representative sample could be taken, this area was checked by Commonwealth Edison Company Quality Assurance in an audit of October, 1981. This audit identified deficiencies that are summarized as follows:
- 1. Incorrect calculations
- 2. Improper calculation reviews
- 3. Three dimensional restraints not used per ECN 2194
- 4. Adjacent line weights not used in line weight calenlations
- 5. Revision levels of applicable isometric drawings not listed on calculation sheets
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- 6. System component weights obtained from uncontrolled source
!- (uncalibrated-scale)
I 7. Q.C. not monitoring instrument group activities
-8. Document'ed training not given to procedures, PGCP-21 and 22 4 .
! 9. - - Interface document not clearly' written u .
- 10. Organization chart in error ,
The details of these items, including Quality Assurance follow-up
. work, corrective actions, and item close-outs, are described in
', the audit close-out surveillance reports. This audit-resulted in j a stop work action being placed on Phillips, Getschow company
!' until February, 1982. All items were resolved-and closed by i March, 1982.-
i
! As as additional follow-up to the.0ctober,-1981 audit, an audit-was performed in July, 1982. The concerns of the October, 1981' audit were re-checked as evidenced by approved checklist questions 1, 2, 3, 4, 5, 10, 11, 12, 14,-15, 16, and 17. All question areas
. were found acceptably implemented. At that time Commonwealth' l Edison Company Quality Assurance believed instrument support selection was being done in an acceptable manner and'Phillips, Getschow Company was implementing their procedures in this area.
l INSTRUMENTATION AND SMALL BORE 4
4 Small Bore Process Pipe support selection started in January, 1983 upon approval of Revision 2 of POCP-22 which then added support selection for small bore process pipe. Again, after work had been-i completed so that a representative sample could be taken, small.'
l^ Bore Pipe support selection was checked and instrumentation line support selection re-checked in July, 1983 during audit ;
j QA-20-83-33. It was identified that Phillips, Getschow company
.)
' Procedure POCP-22 did not-give the step-by-step method for 3
Performing support selection. calculations; that.the procedure did j not reference the current applicable ECN (4566); and that:
information on the calculation sheets was unclear-or incomplete.
1 This resulted in PGCP-22 being revised'to more'specifically define-
- .the methodology of performing support selection calculations.' l Revision 8 of this procedure was_given'interia approval'by site i Quality Assurance on 11-10-83.and was accepted by sargent and
- Lundy on 12-2-83.- '
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Though the above deficiencies were identified, for the calculations reviewed, no cases were identified of calculations being incorrectly performed or undersized pipe supports being selected. The first process pipe support package was issued to.
the field for installation in August, 1983. As of 12-20-83, two hundred forty-nine (249) small bore process pipe supports have been selected with one hundred ninety-three (193) of these issued
. to production for-installation. This is approximately 6% of the roughly 4,000 small bore process pipe supports to be selected by 2
Phillips, Getschow company.
Also audit QA-20-83-33 identified that small bore pipe and instrumentation line support selection training files were i incomplete. Corrective actions have been defined and' implemented to correct this item as well.
As of December, 1983, the areas discussed above are being 3
acceptably performed.. Site Quality Assurance will continue to
- monitor this area to properly assure compliance.
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7.b) =1/2" S-80, SA-312, Type 304 ASME Boiler Pressure Vessel Code, ,
Section III, Class I NB pipe heat number 745107, was discovered in l Section III installations without material test reports or records of receiving receipt inspections by either Commonwealth Edison
- Company or Phillips, Getschow company as identified by Phillips, Getschow Company on September 17, 1982, on Non-conformance Report i No. 789. The disposition of-the non-conformance report resulted i
in accepting the pipe after only obtaining material test reports without examining the pipe, initiating and maintaining receipt :
inspection records or determining the total quantity of the pipe in storage and installed. Phillips, Getschow company recommended j scrappiag the material. Criteria 16,:7 and 8.
l CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED
!= A 4'
Phillips, Getschow Company initiated NCR No. 1128 to document
, additional disposition of NCR No. 789. NCR No. 1128 requires the generation of a Receiving Inspection Report to document receipt of l '746 feet of 1/2 inch, schedule 80, SA-312, Type 304, Heat No.
- 745107 pipe per purchase Order No. 207003.- Additionally, an
! ultrasonic test verification to assure correct schedule pipe (Neat No. 745107) was installed per applicable design table will be j performed.
t CORRECTIVE ACTION TAKEN TO PREVENT RECURREN & l i
i 4 Phillips, Getschow Company has directed management attention
' towards improved review and dispositioning of NCR's. Among the ,
changes under review, included are additional training of Personnel, procedure and Quality Assurance Manual reviews and l re-writes, and the formation of,an interdepartmental review board. Additionally, Phillips, Getschow Company Corporate Quality 1 Assurance has initiated a random review of previously closed NCR's.
I DATE CORRECTIVE ACTIONS WILL BE COMPLETE l The ultrasonic verifications and any required corrective actions s
will be complete prior to March 1,'1984. Phillips, Getschow Company management actions will be complete prior to April'1, 1984.
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- 8. Phillips, Getschow Company had not established and executed a plan for auditing the implementing procedures of the Quality Assurance Program on a periodic basis to determine the effectiveness of the program in accordance with the Phillips, Getschow Company Quality Assurance Manual, Section 16. Criteria 18.
DISCUSSION The Phillips, Getschow Company Quality Assurance Program required all manual sections to be audited over the year period. This requirement fulfilled ASME Code requirements. Audit schedule 1983/1984 period, dated March 17, 1983 provided a schedule with all manual sections on the schedule and a special schedule for process control procedures. The rationale of this schedule was to audit major work activities / procedures associated with manual sections. Commonwealth Edison Company views the requirement to include all procedures in the audit schedule a change from previous interpretations of Criteria 18.
2 CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED 1
Phillips, Getschow Company revised their audit schedule on August 21, 1983 to include auditing of all procedures annually.
Procedures not used in the annual period will be designated not applicable at time of audit.
CORRECTIVE ACTION TAKEN TO PREVENT RECURRENCE 4
Conunonwealth Edison Company will verify the implementation of the Phillips, Getschow Company revised Audit Plan through their audits and surveillances.
DATE FULL COMPLIANCE WILL BE ACHIEVED The revised Audit Plan has been implemented. Commonwealth Edison !
Company verification will be complete prior to October 1, 1984. '
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LARGE BORE PIPING f
1.a) An inspection program had not been established and executed for quality control to verify correct material installation for over 2" safety-related piping, prior to November, 1982.
DISCUSSION Phillips, Getschow Company during a Quality Assurance Manual revision in November, 1982, added to its large bore piping weld data traveler the requirement for Quality Control to verify material traceability. This requirement was implemented in November, 1982. In June, 1983, wording was added to Phillips, Getschow Company Procedure QAP-16, Control of Installation of
- Nuclear or Safety-Related PiDe Systems, which formally Proceduralized the above requirement. (Note
- The verification activity was ongoing since November, 1982.)
CORRECTIVE ACTION TAKEN AND RESULTU ACHIEVED Commonwealth Edison Company will conduct a 100% material verification program for large bore piping installed prior to November, 1982 which has had Phillips, Getschow company purchased material added and large bore piping which has been modified with other Soutnwest Fabricators material. This verification program will be similiar to the program outlined above for small bore Piping. The goal will be to verify that correct large bore material was installed in the plant.
CORRECTIVE ACTION TAKEN TO PREVENT RECURRENCE Phillips, Getschow company has revised their piping installation Procedures to include verification of all identification markings by Production and Quality Control.- ;
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DATE CORRECTIVE ACTIONS WILL BE COMPLETED t
Procedural changes have been made and implemented. The material verification program of pre-November, 1982 large bore piping will be complete prior to Fuel Load.
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1.b) Random dimensional checks of piping components were not being done by either Phillips, Getschow Company or Commonwealth Edison Company. Criteria 10 and 8.
f CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Portions of 124 large bore heat lots were identified in the Phillips, Getschow Company storage area. A 10% sample from each lot was taken to verify dimensional accuracy. . All samples were verified acceptable. Records are available in Commonwealth Edison Company MRR packages indicating random large bore dimensional checks prior to 1980 were being taken by Quality Control personnel at receipt inspection.
CORRECTIVE ACTION TAKEN TO PREVENT RECURRENCE Phillips, Getschow Company Procedure QAP-33 Supplement, Revision 1, dated June 24, 1983 provides a Quality control Inspection Plan i for dimensional verification.
DATE WHEN CORRECTIVE ACTIONS WILL BE COMPLETE All corrective actions have been completed.
S (0292d)
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- 2. Phillips, Getschow company had not established and executed a plan for auditing implementing procedures of the Quality Assurance Program on a periodic basis to' determine the affectiveness of the program in accordance with Phillips, Getschow company Quality 4
Assurance Maunual Section 16. Criteria 18.
DISCUSSION
- , The Phillips, Getschow Company Quality Assurance Program required l all manual sections to be audited over;the year period. This requirement fulfilled ASME Code requirements. -Audit schedule l 1983/1984 period, dated March 17,'1983 provided a schedule with
- all manual sections on the schedule and special schedule for process control procedures. The rationale of this schedule was to i audit major work activities / procedures associated with manual i
sections. Commonwealth Edison Company views the requirement to i
include all procedures in the audit schedule a change from ,
j Previous interpretations of criteria 16.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED' i
Phillips, Getschow company revised their audit schedule on August i 21, 1983 to include auditing of all procedures annually.
Procedures not used in the annual period will be designated not
! applicable at time of audit.
CORRECTIVE ACTION TAKEN TO PREVENT RECURRENCE i
\ Commonwealth Edison company will verify the implementation of the
! Phillips, Getschow company revised Audit Plan through their audits and surveillances. ~
}
j DATE FULL COMPLIANCE WILL BE ACHIEVED The revised Audit Plan has been implemented. Commonwealth Edison company verification will be complete prior to october 1, 1984.
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- 1. Adequate written policies, procedures or instructions had not been
[;. established for controlling weldingLincluding fit-up during the installation of the HVAC components, and as a result the welding .'
j -
prerequisites for acceptable installations were not met as j- evidenced by deficient control, inspections, examinations,
- documentation and corrective action. Criteria 9. ,
RESPONSE
1 It is Comenonwealth Edison Company's position that adequate procedures were in place to meet the requirements of Sargent and i Lundy Specification F/L-2782 and the AWS Code. Pullman Sheet
- Metal utilized approved welding procedures,-trained qualified l welders and purchased certified materials. All welds have
, received a visual inspection by Pullman Quality Control to verify j weld acceptability and proper procedure implementation.
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j CORRECTIVE ACTION I
1 In response to the NRC's concern Commonwealth Edison Company l instructed Pullman Sheet Metal to upgrade their program for future .
j work. Pullman revised procedure 59.4.F to incorporate a process
, sheet which is utilized to pre-assign the welding procedure and
- j. document the filler metal utilized and the welder who performed
- the work. This procedure was granted interim approval in i September, 1983.. ,
I In addition, Pullman Sheet Metal expanded their in process weld "
} inspection program which was originally implemented in February,
! 1983. When work resumed to Procedure 39.4.F, Revision ~4 the
! in process weld inspection went to a 100% basis in order to obtain a confidence level for the implementation of the revised program.
! t j DATE M' FULL CoffLIANCE Pull compliance with.the NRC's interpretation of AWS Code j requirements was met September 28, 1983.
- i, j (0249d) 4
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- 2. Quality Control did not verify through inspection of examination of records that the correct welding material was used in each HVAC component installation or that the correct welding material was requisitioned for each HVAC component to be installed. "(AWS !
D1.1, Section 6 states that the inspector shall make certain that only material conforming to the requirements of this code are employed)". Criteria 10 and 8. -
j RESPONSE ;
J l Pullman Sheet Metal Quality Control satisfied the requirements of AWS D1.1 by verifying that only certified weld materials were
, purchased and received on-site. Quality control also verified that each welder was qualified and they conducted a training class 1
for the welders in each procedure that they were qualified. The training covered base material, filler metal requirements, joint configuration, fitup, etc. In addition, the final visual inspection performed by Pullman revealed no evidence of improper filler metal usage, i
i CQRRECT H E_ ACTION In response to the NRC's concern CECO instructed Pullman Sheet 1
Metal to revise their program. Pullman now controls the issuance of all filler metal utilizing the weld rod issuance log. The
- welder records the type and heat number of the filler metal used on the process sheet. Additionally, pullman Sheet. Metal Quality
- Control verifies proper filler metal as part of their in process l
weld inspection.
, DATE OF FULL COMPLIANCE Full cciapliance with the NRC's interpretation of AWS Code
- requirements was met September 28, 1983. ,
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. 3. Quality control did not verify through inspection that welding was being performed by qualified welders, as a result 55 welds have i
been identified by the HVAC contractor on Non-Conformance Report No. BR-08, dated June 15, 1981, as being welded without knowledge-
- that a qualified welder performed the welding. "(AWS D1.1, I
- Section 6 states that the inspector shall permit welding to be performed only by welders who are properly qualified)". Criteria
- 10.
- l
- RESP 0NSE l
i All welders are assigned unQue I.D. numbers which they are required to stamp adjacent to the welds they make. During the -
l final visual inspGction of the welds Quality Control verifies that t
] the welds are stamped. Non-Conformance Report No. BR-08 is evidence of this inspection. pullman Sheet Metal Quality Control t
- I has inspected over 55,000 welds. We believe that the fact that 55 1 welds out of 55,000 welds were not stamped does not indicate a l significant problem exists. In our interpretation of the AWS j Code, Pullman Sheet Metal Quality Control satisfied the j requirements of AWS D1.1. by verifying the certification of each j
welder on-site when he takes his qualification test and conducting a training class for each welder covering weld procedure i requirements.
.i i
CORRECTIVE ACTION j
In response to the NRC's concern pullman sheet Metal now records i
the welder I.D. on the process sheet and Quality Control verifies 4
, welder I.D. as part of their in-process weld inspection. ,
1 DATE OF PULL COMPLIANCE i
Pull compliance with the NRC's interpretation of AWS Code
! requirements was met september 28, 1983, {
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l 4. Instructions were not adequate in that the welding procedures to be used for each specific HVAC installation were not prescribed on drawings, travelers, or pre-determined documentation form.
l Quality control did not verify through inspection that the acceptable weld procedure was employed for each HVAC installation j and did not perform adequate in-process inspection to assure that l the welders were complying with the welding procedure essential variables. "(AWS D1.1, Section 6 states that the inspector shall make certain that only welding procedures that meet the requirements of this code are used.)" Criteria 5 and 10.
RESPONSE
It is Commonwealth Edison Company's position that adequate instructions were in place. Each Pullman Sheet Metal welder was qualified on-site and received documented training in the Procedure requirements. The Quality control inspection of all welds has revealed no evidence of improper procedure usage. The in-process inspection that began in February, 1983 has not identified any cases of improper procedure implementation.
CORRECTIVE ACTION In response to the NRC's concern Commonwealth Edison company directed Pullman Sheet Metal to upgrade their program. Pullman Sheet Metal revised procedure 89.4.F to incorporate a process sheet which is utilized to pre-assign the welding procedure. In addition, Pullman Sheet Metal Quality Control is performing in-process inspections to verify compliance with the welding procedure requirements. We are presently performing 100% '
in-process inspections in order to establish a confidence level for the implementation of the new program.
DATE OF. FULL COMPLIANCE l
l l Full compliance with the NRC's interpretation of AWS Code
! requirements was met September 28, 1983.
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1 (0252d)
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2 5. Quality control did not perform in-process inspections during the HVAC installation to verify fillet metal type, fillet metal size, welding position and welding polarity. "(AWS Dl.1, Section 6 states the inspector shall make certain that electrodes are used only in the position and with the type of welding current and polarity for which they are classified.)" Criteria 10.
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RESPONSE
The Pullman Sheet Metal Quality Control inspector made certain that the welders were implementing the procedures by verifying that all welders were qualified and that each welder received a
- training class in each procedure that they were qualified.
J Pullman Sheet Metal Quality control implemented an in-process inspection prosram in February, 1983. From February, 1983 until July, 1983 Pullman Sheet Metal Quality control performed 89 I
r in process inspections. These inspections did not identified any cases where the welder was improperly implementing the welding procedure. These surveillances demonstrate that the training given the welders was effective and that they understood the procedure requirements.
1 CORRECTIVE ACTION TAKEN 1
In response to the NRC's concern Pullman Sheet Metal expanded
{ their in process checklist to specifically address all the essential variables of the applicable welding procedure.
The frequency of in-process inspections has also been increased.
1 We are presently performing 100% in process inspections. This is being done to establish a confidence level for the implementation i of the new program. -
l DATE OF. FULL COMpLIANC5 i .
1 Full complia.;ce was met September 28, 1983.
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3 l 6. Quality control'did not inspect HVAC components for fit-up prior j to welding on those components for which fit-up tolerances can not i be determined after welding, such as all around fillet welds and
! full penetrations welds. Furthermore, documented instructions to
! the Quality control inspectors of fillet gaps after welding was inadequate.in that the HVAC contractor visual weld inspection
~
Procedure B10.2.F stated that a 3/16" gap was acceptable while AWS Dl.1-1977 Section 3.3 states that a 3/16". gap is allowable only if the leg of the fillet weld in increased by the amount of.the separation or the contractor demonstrates that the required
' effective throat has been obtained.- " (AWS Dl.1 Section 6 states that the inspector shall examine the work to make certain it meets 1
the requirements of Section 3 which included fit-ups.)" Criteria 10 and 5.
I l RESPONSE 4
4 Approximately 90 to 95% of all the HVAC welds can be inspected for fit-up after the weld is completed. Although B10.2.F did not specifically state to check for the increased fillet size, all of i
the Quality control inspectors had been trained in.the AWS Code requirements and were aware of'this.
- CORRECTIVE ACTION l I
i
, pullman Sheet Metal procedure B10.2.F has been upgraded to ,
specifically address checking for the_ increased fillet size. Also.
4 welds which cannot be checked after welding are now inspected for 1
fit-up prior to welding.
I DATE OF FULL COMPLIANCE 3 Full' compliance was met September 28, 1983.
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- 7. Pullman Sheet Metal had not established a corrective action Program to assure that conditions adverse to quality such as l l
deficiencies and deviations were identified for significance in i' and subsequently that the cause of the significant conditions were determined and corrective action taken to preclude repetition.
a)' Through August 4, 1983, 2,513 correction notices had been j written by Pullman Sheet Metal for deficiencies and deviations but their Quality Assurance program did not require correction notices to be analyzed for significance.
These correction notices included numerous weld deficiencies i
and deviations.
5 b) Corrective action was not adequate concerning 4
Non-Conformance Report No. BR-08, dated June 15, 1981, since-l the 55 welds for which the welders.were unknown were l accepted as is after only a visual examination. The
- acceptance of a weld by visual examination pursuant to AWS D1.1 is based on the fact that a qualified welder' performed ,
the welding in accordance with the qualified process. ;
- Criteria 16. J 4
RESPONSE
~
a) When Pullman Sheet Metal revised their inspection. program changing from a 10% Quality contro1' inspection to a 100%
- Quality control. inspection a commitment was made to inspect +
all welds which had,not been Quality Control inspected. The inspections of previous work was completed in May,1983.
These inspections resulted in 1480 correction notices. ,
These correction notices were-not trended since they would
, not be representative of the present level of the work.
Prior to this inspection only 39' correction notices had been l granted.
b) Commonwealth Edison company'does not agree that the corrective action for NCR BR-08 was not adequate. We do agree-that the explanation for the accept "as is" based on i final visual inspection needs to be expanded to explain all
, the bases behind this disposition.
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CORRECTIVE ACTION 6
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a) Pullman Sheet Metal performed a trend analysis of the 1480 correction notices. This review did not identify any significant problems but it did substantiate the basis of our change from a 10% Quality Control inspection to a 100%
inspection, b) The basis for the accept "as is" dispostion on NCR BR-08 r
will be expanded to explain all the bases behind the disposition.
DATE OF FULL COMPLIANCE ,
a) Full compliance was met August, 1983.
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- b) The disposition on NCR BR-08 will be expanded by January 27, 1984.
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- 8. Craft. records were not available for weld material traceability.
i Welding procedures used during production welding and fit-up l
, documentation such as extending the leg of a fillet weld due to a i
. gap over a 1/16 of an inch. Criteria 17. !
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RESPONSE
It is Commonwealth Edison Company's position that this level of f documentation is not required for AWS Code work. The procedures t j which were in place and the auditing of their implementati6n l j provide the necessary controls. j I
i l CORRECTIVE ACTION 1
In response to the NRC's concern Commonwealth Edison Company had
! Pullman Sheet Metal upgrade their program to utilize a process
} sheet. The welding procedure is specified on the process sheet
! .and the weld rod type and heat number as well as the welder ID are
- also recorded. I L
DATE OF FULL COMPLIANC5 4
i Full compliance was met on September 28, 1983 i ,
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- 1. Inadequate measures were established in the drawings located at site Document Station No. 5., were up to four (4) revisions old
! and were neither returned to Document Control as voided drawings or marked as bellig voided drawings for information only. L. K.
l Comstock Quality Assurance program Manual in Section 4.2 requires voided documents "(drawings)" to be returned to Document Control within three (3) days. Criteria 6.
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RESPONSE
i The surveillance activities of the Documentation Control l Department have been increased. Since July, 1983, sixteen (16) curve 111ances covering j d }i drawings involving fifteen (15) documentation stations and a 100% check of the office engineering prints were performed. As a result of the surveillances performed in the field documentation stations 8,335 prints were reviewed and 352 superceded prints were found in the field. (However 235 of these were in a single document station wh.ch is devoted to checking the status of past revision work. As a result, in this station a 100% check of all drawings was performed.)
Additionally, L. K. Comstock Quality Control has performed monthly random drawing control surveillances. Since July, 1993, six (6) have been performed with good results.
CORRECTIVE. ACTION TO AVQID FURTHER CONCERN Continue to perform surveillances by the Document Control and Quality control Departments.
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! i i' 2. 'L. K. Comstock auditing activities neither conformed with the [
comprehensive annual schedule of planned and periodic audits t 4
established as required by [L. K. Comstock] Quality Assurance !
{ program Manual section 4.14.1 to verify compliance with all j
- aspects of the Quality Assurance Program. Criteria 18. -
l l l DISCUSS 1m :
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) Commonwealth Edison company acknowledges that L. K. Comstock had i
, failed to comply with their 1983 audit schedule. [The inspector l l acknowledged that Commonwealth Edison company's audit activities !
i had covered all applicable L. K.-Comstock activities.] This i
{
shortfall, along with three other Quality Assurance concerns were ;
i consunicated verbally to L. K. Comstock guality Assurance in April l i of 1983 and stated in writing on May 16 the site Quality Assurance 4 4
superintendent to L. K. Constock's Corporate Quality Assurance l Manager. (Ref, tad letter 94715.) As a result, Comstock placed a ;
I regional Quality Assurance manager on site to assume the duties ,
j (including auditing) of the site auditor who had resigned '
{
I effective May 5, 1983 until a replacement could be found.
! A review of L. K. Coastock's audit coverage - corporate and site -
! for 1942 and 1943, shows that a total of 6 Quality Assurance i manual subsections and 6 field work procedures hadn't been audited.
I i j For the 6 work procedures, l
) 2 were new procedures as of late 1983 (after the NRC
,; inspection) i i 1 covered silver plating of bus bars (an infrequently i
! performed operation which is subjected to a 100% Quality ;
j Control witness) i i l 1 covered site organisation position delineation , ,
i 1 covered production's use of a Revision Work Request
) (However, the subsequent guality Control inspection of R.W.R.'s had been audited and the work instruction was
- l. audited during the week of January 9, 1984 by L. K.
I Comstock.)
i i i covered squipment/ Junction Box Installation. (However, j the subsequent Quality control inspection of equipment j erection had been audited and the work instruction was
- audited during'the week of January 9, IM 4 by L. K. '
- Comstock.)
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l Therefore, the active work procedures have been audited.by L. K. l constock at the time of this report. !
l A review of the 6 guality Assurance manual subsections not audited by L. K. Comstock showed, 1 covered the L. K. comstock policy statement i
1 covered the overa'.1 program description i i
1 defined the program applicability ,
1 covered L. K. constock's reporting of part 21's 1 covered the corporate review of the site Quality Assurance program i i covered the corporate organizat:on chart i copies of the objective evidence for the corporate offsite audits ,
were then examined by commonwealth Ediscn company guality !
Assurance with L. K. Comstock site Quality Assurance. (This j
( information was not available onsite during the estc inspection.) ;
j This review disclosed that there was obj H:tive evidence recorded ;
to support the conclusions stated in the audit reports. copies of [
this objective evidence are available at the site as of this date. :
CORRECTIVE ACTICM TAKEM 10 PREVENT RECURRENCE As a result of Cosmonwealth edison compt.ny Quality Assurance concerns predating the late inspection L-. K. Comstock has placed '
two (2). fulltime, qualified auditors on site. (one activated in I october one in November.) counseling has been given to these "
auditors by commonwealth Edison Company $ ality Assurance to ,
include more descriptive evaluations of audit results in their audit reports. Additionally, two new site procedure revisions have been implemented to further define the onsite auditing activities and qualification process for site auditors. !
l L. K. constock site Quality Assurance has submitted an audit plan !
' for 1984 which shows that all active safety related activities !
will be adequately covered. !
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! -43_ l i-DATE OF FULL COMPLIANCE !
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All above actions are complete as of January 9, 1984. ,
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3.a) Comunonwealth Edison company failed to assure that criteria for tightening electrical connections as delineated in Commonwealth Edison Company position paper dated January 8, 1982, was not incorporated in electrical Specification F/L 2790 and L. K.
Comstock work and inspection procedures.
l i
, RESPQNSE
\
l Comenonwealth Edison Company Project Construction feels the tightening of electrical connections delineated in the January 8, i 1982 position paper is being met.
Because of the lack of industry standards and direction in specification F/L -2790, Comunonwealth Edison Company provided requirements on how to tighten electrical connections. The requirement to tighten electrical bolted connections by compressing the lock or star washer is an indication of a good electrical connection. Compression of the lock or star washer is accomplished in a good workmanship like manner.
The requirement to assure electrical connections are " tight" in a f
" good workmanship manner" is delineated in L. K. Comstock Procedures 4.3.9, (Paragraph 1.1.12.3) and 4.8.9, (inspection check point 3.3. item d).
t j Although we feel the requirements of the January 8, 1982 position paper are being met, Specification F/L 2790 and the L. K. Comstock procedures will be expanded to clarify the NRC concern.
CORRECTIVE ACTION TAKEN AND ACTION TAKEN TO AVOID FURTHER CONCERN Revise L. K. Comstock's Procedures 4.3.9, (Paragraph 3.1.12.3) and 4.8.9, (Paragraph 3.3, item d)) to reflect Commonwealth Edison Company directive of January 8,1982. Clarify Specification F/L 2790 to reflect Comenonwealth Edison Company requirements.
DAff OF COMPLETION Expected date of completion February 1, 1984.
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L. K. COMSTOCK & COMPANY. INC.
c g,aidwud 4.8.9 '
't Q. C. INSPECTION CHECKLIST OF ELECTRICAL TERMINATIONS CABLE NO.
CA8LE TYPE CONTROL I POWER INSTRUMENT C OTHER CABLE DESCRIPTION SHIELDED L., l COAX /TRIAX O
\ EOulPMENT l0 TERMINATION FROM TO WIRING DIAGRAM NO. REV. DATE__
ECI. . TCR
- "OAD" FCR
- "0AD" Entry #
(If Pars. 6.5 is involved)
[h
. 3.1 CABLE TERMINATION CARD IS CORRECT.
I I 3.2 CABLE TERMINATED PER WlRING DIAGRAM RD.
I I a) CONDUCTORS PROPERLY COLOR CODED / IDENTIFIED. O b) SHIELD /DR AIN WlRES TERMINATED CORRECTLY. I I I I 3.3 Proper lug or connections used.
Calibrated . Calibrated ; '.---- p-Cal. Due <
. Cal. Due
, Crimp Too'1 No. Stripper No.
a) Protective bushings used on conduits.
j b) Stripped conductor inserted into lug to correct lungth. { ~j < -~ --
(
c Crisp properly fomed on lug & fac d
Lue connection tiithe at term poin outwarg
,-Da coo +'g.,
I I L ll]
3.4 Mali L lL -
C UU CABLE PROPERLY DRESSED, AND SUPPORTED WITH SUFFICIENT S .ACK.
and no danage to pushed in cables, as applicable.
a) BEND RADIUES MAINTAINED.
C l l b) CABLE 10 CORRECT AND CLEARLY VISIBLE, C
c) SPARE CONDUCTOR ARE PROPER LENGTH, COILED, TAPED AND ID'D.
CC d)SPECIFIED SEPARATION Identified "CSCR Report"# I R 3.5 IN. PROCESS SPECIAL TERMIANTION/ SPLICES MADE IN ACCORDANCE WITH APPLICABLE ENGJMANUFACTURERS SPECS. OR INSTRUCTIONS.
al PROPER HARDWARE USED.
C[
,, CCD 4.0 b) COR R ECT)lE AT SHR INK / TAPE APPLIED.
O O (~~l LlOUlDTITE FLEXIBLE METAL CONDUlf COMPLETE.
GROUNDING COMPLETE.
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REMARKS
(([
APPROVED BY is DATE REVIEWED GY
- DATE QC INSPECTOR
(. LEVEL 11 PREPAHED A PPROvtD REVi3ED flTLE HAP 098G. D A TI REV.DATE RR RMS FORM NsRf PROCEDURE $/12/80 C as (8/22/S3)
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s L. K. CCMSTCCX & CCMPANY. INC.
3RA l'NCCD k.3.3 3Ca.)
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8RCCI URE 3.1.3 3efore attaening terminations, all current transfe r- er s anc faultsensing transformers snould be installec, wita
- alarizations as designatec ey one-line diagrams.
3.1.10 All acoro.:riate safety precautions snall be observec, including isolation anc lockout of electrical potential, provision for acecuate lignting anc ventilation, pro-taction frem moving equipment, acecuate scaffolding, fire protection (such as an extinguisner in close reaca of the worianan) anc convenient means to exit an enclosure or restrictec c moartment, suen as a mannole.
3.1.11 The ter-ni sia to r shall sign, date and ft!I cut all required information on the termination csrc. See Attachment 'C1'.
3.1.12 Terminations requiring bolted connections such as at switchgear, MCC's and motors, shall be in accorcance with acproved specificatico and standards.
3.1,12.1
- All bolted connections shall use stainless steel hareware unless otherwise specified.
3.1.12.2 Hardware shall include a bolt, nut wi.th flat
( washer at each end and the sopreoriate lock-wasner (splic ring or belleville) at the nur end.
3.1.12.3 The connection shall be tigh ened in a d LMc:t / ,
wrkmansnip iIke manner. ~- Cp- tuM4M 3.1.13 Any flashing of metal (sharp protrusions) resulting frem .
the ccursressions should be carefully removed by use of a smooth file.
3.1.14 The Installing tools and dies shall be as specified in the Ref. Spec. Where UL listing is applicable for the connectors, the manufacturer's instructions relative to the application of the compression dies shall be followed.
3.2 silver plating when required shall be performed per Procedure 4.3.23.
.3.3 Attachment of Cable Terminations to bus, etc. ...
3.3.1 (Surfaces shall mate properly - draw fil e for flatness if l necassary.
}
3.3.2 centact surfaces shall be bright, clean and fece of exication.
. 3 3.3 Grease or oil shall be remo'ved from the bus bar using approved non-inflammacLe degreaser.
/
3.3.4 i . Acolication be recuireaofif'NO-0X-IDA'the aus is not or similar platec.c'emocunes snail .
aeEPAato Apuneov to AevtseQ TITLI.
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M3 M M i
PRCCECURE 05/08/30 3 4 of 11 !
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3.b)
L. K. Comstock Procedure 4.3.5 failed to address the verification that cables were not damaged and that cable pans are free of all debris prior to installation of cable pan covers.
3.c) L. K. Comstock Procedure 4.3.5 failed to address the verification
.that cable pan covers were installed in accordance with specifications, drawings and standards, and that cable tray splice plate bolts were torqued to project requirements.
RESPONSE
Commonwealth Edison Company Project Construction Department does not feel the NRC concerns warrant an item of non-compliance.
To date no cable pan covers have been installed. However, appropriate L. K. Comstock procedures will be revised to reflect, as a minimum, the following in regards to cable pan cover installation:
cables not damaged cable pan free of debris verification of installation of pan covers per specification.
Requirements for pan cover installation / inspection will be similar to the Byron procedure..
CABLE TRAY SPLICE PLATE BOLTS Procedural requirements to assure cable tray splice plate bolts are tightened to Sargent and Lundy Design Requirements are.
accomplished as follows: ,
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Sargent and Lundy Specification F/L 2790, Standard EB-702, (paragraph 3.1.1) describes the requirements of how to tighten splice plate bolts (EB-702 attached). Assurance, that requirements are being met is a two (2) step process consisting of craft personnel and Quality control inspections. Both installation and inspection procedures (4.3.5 and 4.8.5) reference EB-702 as a requirement. L. K.
Comstock Quality Control performs 100% visual inspection of the cable pan installation. Confusion may have resulted because of the wording in L. K. Comstock Inspection Procedure 4.8.5. (Paragraph 6.1) describes an in-process-inspection of the installation of cable pan. In-process inspections were performed early in the project when torque requirements were specified and Comstock Quality control was witnessing craft personnel torque splice plate bolts.
Subsequently, splice plate bolt installation has evolved as described in the attached EB-702 standard.
CORRECTIVE ACTION TAKEN AND ACTION TAKEN TO AVOID FURTHER CONCERN L. K. Comstock's Quality Control Procedure 4.8.5 will be clarified to reflect actual practice consisting of a 100% verification that splice plate bolt heads are in contact with the cable tray surface.
4 DATE OF COMPLETION Expected date of completion February 1, 1984.
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'., 3h ERECTION (Cont'd)
. s 3.1.1 i sufficient torque shall be applied to pull the c ribbed I n
head is-in contact with the cable tray surf The nut ace.until the rib using no larger than a nominal 8 inch wrench to ensu the cable tray and splice plate fit together tightly .
i 3.2 3 -
The Contractor shall use only the splice plates and "11" plate connectorn detailed on Sargent & Lundy's Standards Sheets or the Construction Dravings for all connections within the Cable Tray Systca.
3.2.1 Certain cable tray connections require special splice plates, such as eben
' joining cable trays of different widths. Under such conditions, the Om-tractor shall install the Installation Detail Drawings. splice plate indicated on Sargent & Lundy's 1ield 3.3 If it should be necessary for the-Contractor to cut a tray section, it shall o be his side in the responsibility rails, andtothat see-that new splice plate counting holer. are drilled l
I & Lundy's Field Installation Detail Drawings.the tray At no timsections shall ::ny are joined as show crole
! tray sections, verticals,, enclosures, etc., be joined by velding. '
!3.4 The Contractor shall install an "H" Plate Connector, Standard STD-EE-602, at 1 each cable tray splice, as shown on Sargent & Lundy's Ficld Instr.llation 1 Detail Drawings. ' !
I f3.5- When a bottom stiffener on any tray section interferes with a cable tray i
i support member,such stiffener shall be removed or suitably modified to permit the installation of the support. The support menber will eerve as
{ the stiffener bar at that point.
l 3.6 Concrete Anchors shown on the Standards, Sketches, and Cable Tray Dravi:q,r I shall be as specified on Sargent & Lundy's " Standard Specification for R Concrete Expansion Anchor Work", Form 1738.
j tapping screws, Concrete anchors, bolts, self- 3 F
installation Contracter. field welding materials, etc., shall be furnished by the E
! 'I l 3.7 Af ter cable trays are installed on their supports, the trays shall be 9 g
attached to the support, as shown on Sargent & Lundy's held Instr.llntm 9
l Detail Drawings.
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- 3.8 After conplete erection of the Cable. Tray w System, the trays shall be inspecte.1, and l all sharp edges, w 1d spots,. bolt heads.
)
- nuts, etc., that project from the inside SARGE.NT & LUNDY tr y nurfaces, that right dunnge enbles, CABLE TKAY SYSTng j shall be ground smoth or otherwise suit- FIELD INSTALIATIO i
. ably eli:-inated. SPFCIFTC.tTim:c
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! 3.d) The minimum embedded conduit bend radius in Paragraph 3.9 of L. K.- ;
p Comstock Procedure 4.3.7 violated the minimum conduit bend radius established in Paragraph 3.10 of Sargent and Lundy Standard STD-EF-103.
RESPONSE
. Sargent and Lundy Standard EF-103, Paragraph 3.10 references a 2" i conduit, with a bend radius of no less than 36". Sargent.and
. Lundy Standard, EB-146 references a 2" conduit bend radius of 24". Both Standards, EF-103 and EB-146 are part of L. K.
Constock's Procedure 4.3.7 and possibly has caused confusion as to what the conduit ~ bend radius should be. Per Sargent and Lundy the i
requirements in EF-103 are primarily intended to be used in the construction of concrete duct banks, manholes and handholes.
Generally, this type of; construction is external to any building
, and may result in longer cable pulls thus affecting maximum (
! allowable pull tension. 'For the Braidwood Project. EF-103 was used primarily for non-safety related underground construction to i the Lake Screenhouse and Switchyard. Because bend radius is a
! Primary factor in determining maximum allowable pull. tension it i
becomes evident that a 36" bend radius would be more desirable for the longer cable pulls.
r As stated earlier, the requirements of EF-103 could be confusing.
The title not only addresses Duct Banks, Manholes and Handholes, f but conduits in concrete ~ floors. L. K. Coastock ' Procedure 4.3.7 ,
} therefore would.be. inconsistent with EF-103 and correct with
! respect to EB-146. In.either case the intended purpose / design of a conduit system,.in general, is to allow routing, physical Protection and installation of cable without violating maximum ,
i allowed pull tension.- This is accomplished, since our procedure
, for cable pulling establishes the maximum allowable pull tension 1
- for cable (s) based on a minimum bend radius of 24" for a 2"
, conduit.
i Project Construction feels the confusion in the Sargent and Lundy
~
Standard and L. K. Comstock procedure has not affected the 3
instal 19 tion'of cable _and or.may actually restrict.the maximum allowable pull' tension._. Commonwealth Edison Company Project
- Construction acknowledges the NRC's_ concern and will clarify the
- applicable documents (Procedure 4.3.7).
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CORRECTIVE ACTION TAKEN AND ACTION TAKEN TO AVOID FURTHER CONCERN
- Revise and clarify L. K. Comstock's Procedure 4.3.~1 to appropriately reflect-the requirements of EF-103.
DATE OF COMPLETION Expected date of completion February 1, 1984.
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CONDUIT & DUCT INSTALLATION (Cont'd.)
3.7 I J When offsets greater than 5-5/80 (.0982 rad) are required, or when standard manufacturer's bends or curved segments cannot be used, a standard bend f shall be cut to fit. 1 3.8 Where the conduits are shown to be fanned out from the normal spacing, such as at the entrance to a manhole or other terminations, the spreading of the conduits in the duct bank shall be confined to the shortest distance permitted by the offset of the tapered joir.ts or by the use of 5 (.0873 rad) offset couplings.
3.9 The inside edges of the conduits shall be teamed with a rasp where necessary socable of that may therebewill be no sharp or rough edges on which the sheath or jacket damaged.
3.10 Unless otherwise specified on the construction drawings, the radii of bends shall be no less than the following:
Nominal Diameter Radius of of Conduit Bend a .c 4 inches __Qlm) 36 inches _
'^
3 inches (76mm)
( .913m))
36 inches (914m) 3 inches (89mm) 36 inches (914mm) 4 inches (102mm) *36 inches (914mm) 5 inches (127mm) 48 inches (1.219m) 6 inches (152mm) 48 inches (1.219m) 3.11 Asbestos-cement electrical ducts shall be terminated with End Bells as show in Detail 107A of STD-EF-107, unless otherwise shown or indicated on the
(
y duct bank Construction Drawings. Plastic type conduits and ducts shall be terminated with Bell Ends of a similar type that will provide a rounded surface for cable pulling and training.
3.12 The ends of all conduits shall be suitably plugged or capped at the end of each day's pour to protect them from damage during construction. Ends of conduits which are not to be used for long periods shall be protected from dirt, rodents, etc., by being plugged at both ends with wooden or other '
suitable plugs.. A suitable compound may be used on the plug to make it adhere to the conduit end.
portion of the plug to provide A k."(6.4m) hole drainage of theshall be drilled in the lower conduit. - -
3.13 ,
All conduits in duct banks shall be thoroughly swabbed immediately after l
s completion of the concrete pouring. After the concrete has set, but before
' backfilling, 'a mandrel not less than 4 inches (102mm) long, having a diameter ,
of the nominal inside diameter of the conduit, minus i pulled through each conduit. inch (12.7mm),.shall be o white to give indication of any protrusionsThe mandrel shall be lead covered or painted on the inside of the conduit that might damage the sheath or jacket of cable. CONCRETE DUCT BANKS, MANHOLES, HANDH0LES, AND CONDUITS IN CONCRETE FLOORS - SPECIFICATIONS
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- 7. . CONDt'IT INSTALLATION (Cont'd) 7.2 Steel conduit (Cont'd) 7.2.6 All manuf acturer furnished or field-formed steel conduit bends shall con-form to the radii shown in the tabulation below, unless otherwise speci-k(- fically indicated on the Electrical Installation Drawings:
- a. Conduit Trade Size Bend Radius Conduit Trade Size Bend Radius 1" (25 nun) 12" (305 mm) 3" (76 mm) 36" (914 mm) 1-1/4" (32 mm) 18" (457 mm) 4" (102 m) 36" (914 c=)
1-1/2",(38 mm) _4B"_(457_mm) 5" (127 m) 48" (1.22 m)
% _2,"_(5 Emni)L ( 24"'(610_am)2 6" (152 m) 48" (1.22 m) 2-1/2" (64 m) '24#(610 m)
~
- b. Conduit bends shall be made so the internal diameter of the conduit will not be effectively reduced.
c.
?!anufacturer's standard radius elbows (bends) sh'all not be used unless specifically indicated on the Electrical Installation Drevings.,
7.3 Licuidticht Flexible Metal Conduit 7.3.1 The minimum length of liquidtight flexible metal conduit installed to equipment shall be l' (305 m) per inch (25 mm) of conduit diameter or 18" (457 mm), whichever is greater. The maximum installed length shall not exceed 6' (1.83 m) unless otherwise dimensioned on the Electrical Installation Drawings. Where the Electrical Installation Contractor determines that any of the above requirements cannot be met, the Electrical Installation Contractor shall notify Sargent & Lundy or the Purchaser's Representative.
1.3.2 Uhen cutting liquidtight flexible metal conduit, nor portion of the synthetic outer jacket shall be removed from the steel core.
s 7.3.3 Special flexible conduit requirements for containment service conditions shall comply with Paragraph 5.2.5 of this Standard.
7.4 Entlosures 7.4.1 Conduit installation shall contain no more than the equivalent of three 90* bends without a pull point in a single conduit run. Junction and pull boxes shall be installed in accordance with the Electrical Instal-lation Drayings, and shall conform to Reference 11.8.
r q 7.4.2- Where the Electrical Installation Contractor determines additional pull or junction boxes are required to prevent exceeding maximum cable pulling
- @ ' tension or side wall pressure, he shall select the appropriate junctien box
,j,
- and load tables when shown on Electrical Installation Drawings. For spe-cial junction or pull box requirements and to record the installation of S' any contractor selected pull or junction box, the Electrical Installation Contractor shall notify Sargent & Lundy or the Purchaser's Representative.
' 7.' 4. 3 In locations where it may be more practical to install a pull box fitting that requires no additional conduit supports, an 0.Z./Gedney type PFV fitting TReference 11.14) may be substituted for the ou11 box referred to in Paragraph 7.4.2 of this Standard.
STANDARD SPECIFICATION FOR ThE INSTALLATION OF SEISMIC CATEGORY I CONDUIT SYSTD'.S CO!.7AINING CLASS IE CABLE
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1 3.e) The requirements of Sargent and Lundy Standard EF-103, Paragraph 3.13 were not reflected in L. K. Comstock Inspection Procedure 4.8.7.
- RESPONSE The requirements of Paragraph 3.13 refer to " Duct Bank" installation. For the Braidwood Project Duct Bank installation was limited to Non-Safety-Related underground construction and is not required to be part of L. K. Comstock procedure 4.8.7.
However, cleaning / swabbing of any underground installation is considered good work practice and was performed at the Braidwood-Project. To date no problem has been identified with any cable resulting from undesirable protrusions or debris in duct bank installations.
For other embedded conduits installed in all buildings it was and is our practice, as a good work practice, to' assure that no burrs or sharp edges remain on the inside of conduits during installation. Verification of this practice is assured during cable pulling. L. K. Comstock's Procedures 4.3.8 (Installations) and 4.8.8-(Inspection) allow for the inspection of cable during the pull.
To date no conduit or cable was replaced because of undesirable Protrusions or debris inside of conduit. -However, Commonwealth' Edison Company Project Construction Department acknowledges the NRC's concern and will expand / clarify L..K. Coastock's procedures.
to assure L. K. Comstock is more attentive to cable condition as they exit conduit.
DATE OF COMPLETION February 1, 1984.
O (0247d) i s;
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j 3.f) L. K. Comstock Procedure 4.3.8 did not address precautions to be taken when pulling small cables "(Less than 100 pound pulling tension)" and did not address the installation.of cable grips in vertical conduit runs per Sargent and Lundy Standard STD-EB-200. J.
Criteria 5 and 10.
l 1
RESPONSE I Commonwealth Edison Company Project-Construction Department feels !
adequate precautions were taken. !
Procedure 4.3.8, Paragraph 3.2.7.2.2 states, " Dynamometers or breakable pull. links must be used on all pulls through conduit".
This statement applies.to g n cables including sensitive cable whether hand-pulled or mechanically-pulled.
The only exception'-to this rule is Paragraph 3.2.7.2.3 - Pushing Cable Through Conduit. For installations where cables are pushed '
through conduit no tension monitoring device(link s / dynamometer) are required. Pushing of-cable is limited to a maximum of 25 feet. '
Paragraph 3.2.7.4 '. Power Pulls.through Tray states, "Dynamamaters.or. breakable pull links must-be used on all power :
pulls through tray". The_only' exception to this rule _is Paragraph 3.2.7.3 -
Hand Pulls through Cable' Tray. This paragraph allows
. hand pulling of all cables, including sensitive cables, and -
describes the process of hand guiding cables. Any cable that is not hand guided around a-corner or changes direction requires tension monitoring devices.
Commonwealth Edison Company Project Construction Department feels the " sensitive cable" issue is adequately addressed.
~No further action is required.
CABLE ORIPS IN VER7ICAL CONDUIT RUNS Although the use of cable grips 1n conduit runs was not addressed 1
.in Procedure 4.3.8 it was addressed for vertical pan' risers. The intended purpose of Paragraph 3.2.8.5 was-to include both risers and conduit as applicable.: Procedure 4.3.8, (Paragraph 3.2.8.5).
.will be revised to-include the use of grips _in vertical conduit runs.
To date'no instances of_not using cable grips have been i reported / identified.
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. l DATE OF COMPLETION February 1, 1984.
Y (0248d)
4.a) L. K . Comstock failed to verify that approximately 30 to 40 cable grips in cable tray risers 1R267-CIE, IR270-KlE, 1R311-CIE, were installed in accordance with S&L standard ST-EB-200 and LKC Procedure 4.3.8.
DISCUSSION In evaluating the cause of this condition it was determined that re positioning of cables in the trays listed above caue*d these cables and grips to move from previously set positions. Thia same condition can occur again as long as cable activity continues.
CORRECTIVE ACTION TAKEN AND ACTION TO PREVENT RECURRENCE Immediately after being informed of the cable grip deficiencies the necessary steps were taken to reset the questionable grips.
Also, as part of an ongoing survey of all cable grips, the need to check for proper grip setting was included in the survey.
After cable work is complete and cover installation is underway an additional check of grip seating will be made to confirm or reset cable grips. For any newly installed cable grips, procedures will be revised to require field and Quality Control personnel to check previously installed cables for proper seating.
DATE OF COMPLETION February 1, 1984.
l (0263d) l
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4.b) L. K. Comstock failed to verify that tie wraps, bolts, screws, metal bracing, etc., had been removed from the interior of MCCIAP26E, in accordance with L. K. Comstock Procedure 4.8.13, (Paragraph 3.1.7).
CORRECTIVE ACTION TAKEN MCIAP26E was cleaned prior to the NRC inspector leaving the site.
CORRECTIVE ACTION TO PREVENT RECURRENCE-We were aware of this condition as a result of an Edison General.
Office Audit conducted in October of 1983. Training sessions were held concerning storing of materials inside equipment. Those sessions addressed new installations and present units whenever additional work is required. It was evident that units previously installed might not be covered for extended periods of time.
Discussions with Station personnel were underway to determine responsibility areas for cleaning equipment. This item will be resolved by the end of January, 1984.
Project Construction Department has also provided for PTL inspectors to perform monthly checks of all installed equipment.
Any housekeeping deficiencies identified are reported and resolved by' applicable craft personnel.
All panels will be re-inspected and cleaned no later than Febraury 29, 1984.
(0264d)
e 4
4.c) L. K. Comstock failed to verify that inspections had been Performed in accordance with L. K. Comstock Procedures 4.8.3, 4.8.6, 4.8.13, and 4.8.17 as evidenced by: 34 items of 71 items reviewed had no records indicating that Quality control had performed an installation inspection: 29 of 53 items reviewed had no records to indicate that Quality Control had performed a welding inspection: 125 volt DC panel IDC05E had no records to indicate that PTL had performed an inspection of the concrete expansion anchors: 19 of 19 electrical penetration records did not provide actual torque values to mounting bolts, and did not indicate the torque wrench number utilized. Critera 5, 10 and 17.
RESPONSE
Commonwealth Edison Company Project Construction Department was aware of the need to assure that timely inspections have been performed in accordance with L. K. Comstock procedures and that results are retrievable.
As early as March, 1982, Commonwealth Edison Company Quality Assurance audits and tre Technical Support Evaluation of September, 1982, identified deficiencies indicating the need to improve the L. K. Comstock documentation / filing system.
As a result of identified deficiencies Commonwealth Edison Company felt that improvements could be made in the areas of:
- 1. Timeliness of records retrievability
- 2. Better accountability of the production records which support.the status of installation
- 3. Reconcile the use of previously used outdated forms.
In October, 1982 it was determined that progress was poor in the ,
document review. In November of 1982 the L. K. Comstock Quality Control Manager was replaced because he lacked administrative abilities. However, poor progress in the document revieir continued. In March, 1983, Project Construction Department held a meeting with L. K. Comstock's Regional Vice President and in April, 1983 with L. K.lConstock's Executive Vice President, Corporate Quality Assurance Manager and Regional Vice President to discuss the poor progress being made on the document review.
L. K. Comstock committed to provide four (4) inspectors to complete _the document review and provide a plan for completion.
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,4 '
The plan to complete the review was submitted to Commonwealth Edison Company for concurrence on March 9, 1983. The plan's ,
scope and depth was to reconcile audit deficiencies of document retrievability, as well as assuring record completeness and Correctness.
In June, 1983 Project Construction Department and Quality Assurance met with L. K. Comstock to discuss the status of the document review. It was determined that L. K. Comstock was not progressing as scheduled to meet their September, 1983 completion date. As a result of the June meeting, Commonwealth Edison Company again replaced the L. K. Comstock Quality Control Manager, with intent to more adequately organize and complete the document review as projected for February 1, 1984.
These corrective measures which provide improvements to the L.
K. Comstock document system were presented to the NRC (Messrs.
Little, Williams and Love) on November 3, 1983 and the program was mentioned on December 20, 1983 during the Enforcement conference.
To date L. K. Comstock is 88% complete with their review of all documents on file.
125V DC Panel IDC05E The NRC Finding that, no inspection records exist for the installation of anchor bolts on panel IDC05E is correct.
However, this panel is not anchor bolted to the floor but welded per the requirements of Sargent and Lundy equipment attachment detail drawing. Weld inspection records are available for review.
Possible confusion with regards to what panel is in question exists. Adjacent to panel IDC05E is IDC03E. Panel IDC03E was inspected on July 7, 1982 per the requirements of L. K. Comstock i Procedure 4.8.13. ,
L Electrical Penetrations Conunonwealth Edison Company Project Construction Department acknowledges your cencern that penetration records did not provide actual torque values to mounting bolts and did not indicate the torque wrench number utilized is correct.. However, Ceaunonwealth Edison Company Project Construction Department feels L. K. Comstock's procedure and method of inspection using qualified inspectors to verify that proper torque values were applied with calibrated . instruments is acceptable.
1 Inspection of the installation of electrical penetrations was completed during an in-process inspection. Verification that craft personnel used calibrated wrenches and torqued penetration bolts to the requirements of Procedure 4.3.17. Table 5-10 was witnessed by a qualified L. K. Comstock Quality Control inspector. Even though torque wrenches were not recorded on inspection checklists, wrenches A181 and 837 were determined to be used during the installation. Review of calibration records show these wrenches were in calibration at the time of use.
e (0262d)
.I
(
5.a) Neither an ICR or NCR had been prepared to document damaged lower braces and missing cross bars inside MCC1AP226E.
DISCUSSION The damaged lower braces and missing cross bars appear to be the same item.
CORRECTIVE ACTION The missing brace / cross bar was laying in the MCC and was re-installed. An NCR has been prepared to determine the function and requirements of these brace / cross bars as to whether replacement or repair of the bent portions is necessary. All safety-related MCC's will be inspected for any similar damage.
l l
l (0268d) 1 I
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, ,- . 4-63-i l 5.b) Neither an ICR or NCR had been prepared to document that Class IE l Cable ICV 587 was not terminated per design. The cable was i erroneously marked as a spare cable. Records indicate that the termination of-this cable had been inspected and accepted by L. K.
Comstock QC. Criteria 16..
l i
. RESPONSE Commonwealth ".dison Company Project Construction Department
- acknowledges che NRC concern and offer the following clarification and corrective action taken.
ICV 587 was correctly terminated and not marked spare. However, cable 1cv036 was inadvertantly not terminated and marked spare.
Both cables ccanect to the same terminal points and caused some confusion-to both the terminator and L. K. Comstock inspector.
4 Connonwealth Edison Company. Project-Construction ~ Department feels i this is an isolated occurrence. Furthermore, we believe that
] Cosmonwealth Edison Company Operational Analysis Department would
- have detected ~the error during electrical test, which has not yet been performed.
1 i
CORECTIVE ACTION TAKEN L. K. Comstock issued Inspection Correction Report 3440 to identify the discrepancy. ICR 3440 was closed on November 14, 1983.
ACTION TAKEN TO PREVENT FURTHER OCCURENCE Discussed the nature of the error.made with both the terminator j and Quality control inspector. . Both individuals were reminded of the need for accuracy.
P 4
DATE OF CORRiiCTIVE ACTIONS 4
i j November 14, 1983.
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6.a) Inside Unit 1 Containment Building at elevation 397' near cold leg number.3, a 2" pipe was being temporarily supported by safety-related conduit CIR2329-1P2E. This support was at about a 450 angle indicating that the piping may have been installed to support the pipe for welding.
6.b) Inside Unit 1 Containment Building at elevation 412' radius R12, instrument rack IPL71J was being utilized to support 2 step ladders. The step ladders were chained in place so it was not possible to inspect the instrument rack for damage. Criteria 13.
CORRECTIVE ACTION TAKEN FOR 6 a) and 6.b) 6.a) Immediately after being informed of the problems the mechanical contractor was notified and the item was corrected before the inspector left the site. No damage to the conduit was observed.
6.b) Both step ladders were removed from the instrumeat rack. No damage to the instrument rack was observed.
Commonwealth Edison Company Project Construction Department feels these items should not be considered as items of Non-Compliance because no damage to equipment was observed. Ilowever, corrraonwealth Edison Company normal practice is not to use equipment to support contruction materials.
(0269d)