ML20204F708
| ML20204F708 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 04/04/1983 |
| From: | Reed C COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20204F683 | List: |
| References | |
| 6232N, NUDOCS 8305020234 | |
| Download: ML20204F708 (22) | |
Text
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\ Commonwrith Edison
- * $ ) one First National Plaza. Chicago. Hlinois ,
O ' Address Reply to: Post Office Box 767 Chicago,. tilinois 60690 April 4, 1983 Mr. James G. Keppler, Regional Administrator Directorate of. Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Braidwood Generating Station Units 1 and 2 Proposed Civil Penalty I.E. Inspection Report Nos.
50-456/82-05 and 50-457/82-05 References (a): February 2, 1983, letter from J. G.
Keppler to J. J. O'Connor.
(b): February 2, 1983, letter from J. G.
Keppler to J. J. O'Connor.
l (c): February 7, 1983, letter from J. G.
i Keppler to J. J. O'Connor.
(d): February 18, 1983, letter from Cordell Reed to J. G. Keppler.
(e): February 25, 1983, letter from C. E.
Norelius to Cordell Reed.
(f): September 1, 1982, letter from W. L.
. Stiede to J. G. Keppler.
j (g): September 8, 1982, letter from R. L.
Spessard to W. L. Stiede.
! (h): October 8, 1982, letter from T. R. Tramm i to J. G. Keppler.
Dear Mr. Keppler:
! This letter contains Commonwealth Edison's response to the Notice
- of Violation and Proposed Imposition of Civil Penalties regarding defici-encies in the control of certain mechanical equipment installation work at l Braidwood Generating Station. In accordance with the arrangement documented in references (d) and (e), this reponse is submitted within 60
[ days of the date of the Notice rather than within 30 days as specified in references (a) and (b). We appreciate being given the extra time to 7
prepare our response to this complex matter.
t
! 8305020234 830426 6m gDRADOCK 05000456 PDR gg 6 5383 APR L ,
e J. G. Keppler April 4, 1983 As indicated in our previous discussions we understand clearly the significance of the violations at Braidwood Station. Careful design and quality construction provide for safe operation of this facility, but these factors may be insufficient to instill public confidence in the inherent safety of this plant. To establish that confidence, we must provide controls and auditable records which demonstrate the quality of construction. We acknowledge the basic deficiencies in the control and documentation of mechanical equipment installation which were identified by the NRC inspectors. These deficiencies had already been identified by our own inspections and audits. In retrospect, however, it is quite appa-rent that timely corrective action was not taken in some matters. As will be described here, inspections and other corrective actions are well underway which should restore confidence in the quality of mechanical equipment installation at Braidwood. The work completed so far has confirmed the absence of significant quality problems.
In responding to the Notice, we have the choice of paying the fine cr protesting the imposition of civil penalties in whole or in part.
We are protesting the penalty in part and requesting partial remission.
In our view, the facts do not completely support the NRC's findings and extenuating circumstances have not been adequately considered. Partial mitigation is also requested because unusually extensive corrective actions core taken even though those actions cannot be considered prompt in every aspect.
Attachment A to this letter contains Commonwealth Edison's responses to each of the specific examples of noncompliance which were identified in the Notice. In several responses, we have included a discussion of specific inspection findings and related facts and circum-stances which bear on the accuracy and completeness of the record on that specific example. Not all of the examples are items of noncompliance.
We believe that two of the NRC examples of violations of the NRC regulations are factually unfounded. First, in Example 5 of Violation A NRC notes a previously identified steam generator bolting problem at Byron Station and asserts that the corrective action initiated to remedy it had not been taken into account at Braidwood. This is incorrect. It is true that during Byron's construction, difficulties in bolt installation were encountered; the proposed solution at Byron (and at other stations being built by other utilities) was to shorten the bolts. Later, when similar bolts were being installed at Braidwood, the lessons learned at Byron were cpplied and actions were taken to obtain shorter bolts. Thus the corrective action initiated at Byron was also initiated at Braidwood.
Unfortunately, this remedy did not completely solve the bolting problems, and different corrective action was necessary. The further problems with the bolt installation at Braidwood were properly documented and the corrective action was timely,
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J. G. Keppler April 4, 1983 Second, in Example 7 of Violation A the NRC asserts that no audits were performed by CECO prior to June 30-July 9, 1980, relative to mechanical equipment erection and inspection activities of Phillips, Getschow Company. Our records demonstrate that this is not true. The response contained in Attachment A to this letter summarizes the results of two CECO audits of these activities which were performed in 1979.
Construction at Braidwood was shut down from September 1979 to March 1980 for financial reasons. Since audits of mechanical equipment erection acti-vities were conducted when work was in progress prior to June 30-July 9, 1980, this cannot reasonably be considered an example of noncompliance.
As indicated in references (a), (b), and (c) the NRC proposes to escalate the $40,000 base penalty for Violation A because Commonwealth Edison failed to take corrective action at Braidwood after experiencing steam generator bolting problems at Byron and because of multiple occurrences of Appendix B violations at Braidwood. In our view, mitigation seems more appropriate.
Escalation of the fine on the basis of failure to take corrective action on the Byron steam generator bolting experience is unjustified. As described previously, actions were taken to prevent the bolting problems at Braidwood. There is no regulatory requirement or other guidance which indicates the extent to which experience from the construction of other plants must be factored into the design and construction of new plants.
We do this, of course. There are obvious economic incentives to avoid repetition of bolt installation problems. Even if we had taken no action, however, there appears to be no basis for such a violation or escalation of a civil penalty.
Escalation of the fine on the basis of multiple occurrences also is unjustified. In light of the preceeding comments on Examples 5 and 7 of Violation A, the remaining examples all refer in various ways to only two basic problems: control of steam generator bolts and control of mechanical equipment erection. The basic aspects of both of these problems were self-identified and there appears to be no safety significance in either issue. In the case of erection activities, Example 1 cites CECO for not having procedures, Examples 3, 5 and 6 then cite CECO for not assuring adherence to those nonexistent procedures. The examples are repetitive and not truly indicative of multiple violations. The same is true for Examples 2 and 4 regarding steam generator bolts. Escalation of the civil penalty on the basis of multiple occurrences is inappropriate.
Mitigation of the penalty for Violation A is more appropriate because of the unusually extensive corrective actions which have been taken in response to the deficiencies in control of mechanical equipment erection. As discussed in the Novamber 19, 1982 enforcement conference, we have assigned a full-time project manager to the Braidwood site and
r J. G. Keppler April 4, 1983 comprehensive reviews of contractor performance have been conducted. All site contractors were reviewed and substantive changes were made in several contractors' organization and procedures. A major site QA audit was advanced and increased in scope. All of these actions were taken in direct response to NRC concerns identified in this inspection report.
This response goes considerably beyond what would normally be expected for this type of violation. Responsible regulation should encourage this type of activity through mitigation of penalties.
With regard to Violation B, we concur that the problems with control of mechanical equipment installation should have been reported earlier. The situation was reportable in March 1982, when it became apparent that actions taken to correct the audit findings were ineffec-tive. Work was stopped then. Adequate corrective actions were taken in spite of the reporting failure. When the NRC pointed out the reportability of this issue in the August 31, 1982 enforcement conference, a full report was provided promptly.
In summary, we understand the importance of procedural control of construction activities and are undertaking to correct all previous deficiencies through reinspection and, where necessary, rework. No substantive safety problems resulted from the QA deficiencies identified.
The amount of the proposed civil penalty is excessive in light of the extenuating circumstances and minor omissions and errors in the inspection reports. We request that the NRC mitigate the fine for Violation A based on the unusually extensive corrective actions which were taken.
We would be pleased to discuss this matter further at your convenience.
Very truly yours, Cordell Reed Vice-President TRT/1m Attachments SUBSCRIBED and SWORN to before me this 6d day of (tt h f , , 1983 tVM$L 0 MA&J Notary Public
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ATTACHMENT A Response to Notice of Violation I
Civil Penalty Violation A 10 CFR 50, Appendix B, Criterion II requires holders of construction permits for nuclear power plants to document by written policies, procedures, or instructions, a quality assurance program which complies with the requirements Appendix B for all activities affecting the quality of safety-related structures, systems, and components and to implement that program in accordance with those documents.
Contrary to the above, Commonwealth Edison Company and its contractors did not adequately document and implement a quality assurance program to comply with the requirements of Appendix B as evidenced by the following examples:
Example 1: 10 CFR 50 Appendix B, Criterion V requires in part, "Activi-ties affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."
Commonwealth Edison Company (CECO) Quality Assurance Manual (QAM) Quality Requirement No. 5.0 (QR 5.0) states in part, "The quality assurance actions carried out for design, construction, testing and operation activities will be described in documented instructions, procedures, drawings, specifications, or checklists...." The CECO QAM Quality Procedure No. 5-1 (QP 5-1) implements this requirement.
Braidwood Construction Contract Specification F/L 2797, Article 113.5 and Specification F/L 2797, Article 305, state in part, " Procedures governing onsite work shall be submitted to the Station Construction Site Project Superintendent for review and acceptance by the Purchaser.... The procedures shall detail how all elements affecting quality will be processed and shall include the specification of the necessary documentation."
Contrary to the above, approved procedures for the installa-tion or installation inspection of mechanical safety-related equipment did not exist until July 16, 1980, although numerous pieces of this equipment were finally or partially installed prior to this date. Equipment installed prior to July 16, 1980, included the four Unit 1 Steam Generators, the four Unit 1 and Unit 2 Residual Heat Removal Pumps and the four Safety Injection Pumps. Further, the procedure developed by the installation contractor, Phillips, Getschow Company, subsequent to July 16, 1980, was not consistently implemented in that the four Unit 2 Steam Generators and seven of the eight Primary Reactor Coolant Pumps were installed without use of the installation procedure.
Corrective Action Taken and Results Achieved This deficiency was self-identified. A detailed chronology and a description of the corrective action taken are documented in the 30-day 50.55(e) report submitted on October 8, 1982 from T. R. Tramm to J. G. Keppler (attached). In short, all of the subject installation work is being rechecked using a current procedure.
A total of 78 NCR's were written. These NCR's can be classified as follows:
62 NCR's - Documentation for grout release not available, but equipment grouted; or anchor bolt thread engagement not sufficient; or internal cleanliness not verified.
16 NCR's - Improper or missing documentation.
To date 67 of these NCR's have been dispositioned and corrective action is underway or complete. All equipment has been released for further installation work.
Corrective Action Taken to Avoid Further Violations As described in the October 8, 1982 report, a full time project manager was assigned to the Braidwood site. The performance of all site contractors was reviewed closely to determine if similar problems existed. None was found but substantive improvements were made in the organization and procedures of several site contractors. Additionally, a scheduled major QA audit was advanced and the scope was broadened.
Date When Full Compliance Will Be Achieved All of the inspections were completed prior to December 30, 1982.
As will be discussed later, reverification of all the steam generator bolts will be completed by the end of 1983.
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Example 2: 10 CFR 50, Appendix B, Criterion VIII requires in part,
" Measures shall be established for the identification and control of materials, parts, and components, including partially, fabricated assemblies."
The CECO QAM QA No. 8.0 states in part, "... Materials (including consumables), parts, and components, including partially fabricated subassemblies, will have their identity marked on the item or on tags and records traceable to the item. Identification assigned to materials, parts and compon-ents, including partially fabricated subassemblies, will be documented and maintained by the respective vendors, contrac-tors, or oganzations having responsibility for the items involved throughout fabrication, installation or erection...."
The CECO QAM, QP 8.1 implements this requirement.
Contrary to the above, identification or traceability records were not maintained as required for some of the large cap screws used to secure the steam generator to its supporting columns. At least 19 of 192 screws were cut off and the identifying numbers were neither transferred nor marked on tags and records traceable to the screws. Further, adequate traceability records were not maintained for several hundred of these screws which were transferred back and forth between the Byron Station, the Braidwood Station, Rockwell Engineering (for QC checks) and Teledyne Brown Engineering (the installa-tion contractor).
Corrective Action Taken and Results Achieved As a result of bolt installation problems at Byron Station and other nuclear plants, Phillips-Getschow Company (PGC) issued Field Change Order (FCO) 3272 to shorten nineteen steam generator bolts on September 30, 1981. On October 13, 198], Phillips-Getschow issued NCR No. 612 which identified that heat numbers were cut off bolt ends and not transferred to the applicable bolt heads. On December 14, 1981, Commonwealth Edison Company issued NCR No. 332. In reviewing the NCR it was decided to re-stamp heat numbers on the bolt heads since all bolts received on MRR 5954, had the same heat number. On October 20, 1982, FCR No. 6762 was issued to re-stamp the bolts. Re-stamping was completed on October 26, 1982. This traceability problem was self-identified and preceded the NRC inspection.
Traceability of all other bolts is being verified during the removal and reinspection of the bolts in accordance with PGCo Procedures 33 and 34.
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- 4-I Actions Taken to Avoid Further Violations If any other bolts are shortened the heat numbers will be re-stamped at the time of cutting.
Date When Full Compliance Will Be Achieved The steam generator bolts were re-stamped on October 26, 1982.
Traceability will be verified on all steam generator bolts as part of the inspections which will be completed by the end of the year.
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Example 3: 10 CFR 50, Appendix B, Criterion X requires in part, "A pro-gram for inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures and drawings for accomplishing the activity."
The CECO QAM QR No. 10.0, Paragraph 10.0 states in part,
" Inspection and test plans shall be prepared by respective contractors, vendors or organizations having responsibility
.for the item (s) involved, either as a separate document identified with the parts, components or assemblies; or as an integral part of work instruction and procedure documents.
Inspection and test plans shall consist of a flow chart, dia-gram or narrative description of the sequence of procurement, fabrication, processing, assembly, inspection and test activities and shall specify the inspection points. The inspection and test plan shall provide testing requirements, the characteristics to be measured, the inspection and test procedure and the applicable acceptance criteria." The CECO QAM QP No. 10-1 implements this requirement.
Braidwood Construction Contract Specification F/L 2739 Article 113.4.J and Specification F/L 2797 "For Nuclear Support Steel,"
Article 304.10 state in part, "The program for inspection of activites affecting quality that is established and executed by or for the Contractor and his subcontractors to verify conformance with the documented instructions, procedures and drawings shall be described. Such inspections shall be performed by individuals other than those who perform the activity being inspected and the results shall be documented."
Contrary to the above, an inspection program was not developed to verify the proper installation, including bolting, of the main steam generators in either Braidwood Unit 1 or 2. Although the manufacturer's procedure for setting major nuclear steam supply system (NSSS) components, including bolt installation, was available and suggested that the installation contractor provide a detailed setting procedure for the manufacturer's review, such a procedure was not developed. No records exist indicating that travelers, or process sheets, were used or reviewed by the quality control department to establish either surveillance or hold points. As of August 1982, installation inspections of the majority of mechanical safety-related equip-ment were either not conducted, were inadequate, were incomplete were not documented.
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Discussion Procedures were in effect for the transporting, lifting and setting of the Steam Generators through the implementation of the Reliance Truck procedures. Although no installation travelers were initiated docu-menting the bolt installation, on October 13, 1981, Phillips-Getschow issued NCR 612 which identified the failure to initiate and route equipment erection forms for the Steam Generators. A Stop Work was issued, effective December 2, 1981, as noted on CECO NCR 332.
Corrective Action Taken and-Results Achieved This deficiency was self-identified. As described in the attached 50.55(e) report submitted on October 8, 1982, mechanical installation work is being reinspected to verify adequacy. The scope of this work includes bolt installation.
Action Taken to Avoid Further Violation Phillips-Getschow Company initiated FCO's: 5431, 5432, 5433, and 5434 on July 20, 1982, in response to the CECO NCR to replace the steam generator bolts.
On September 16, 1982 FC0 6734 was issued to void FCO's 5431-5434.
Work to reinspect the steam generator bolts is to be completed in accordance with PGCo procedures CP-33, and CP-34 (Removal and Installation of Steam Generator Bolts).
Date When Full Complance Will Be Achieved PG CP-34, Revision 3 was accepted on February 28, 1983. PG CP-33, Revision 1, was accepted for use on September 15, 1982. All bolts are to be reworked by the end of 1983.
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Example 4: 10 CFR 50, Appendix B, Criterion XV requires in part, " Measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation."
The CECO QAM QR No. 15.0, Paragraph 15.3 states in part, " Items which are found to be nonconforming to design and specification requirements or workmanship standards will be positively
- identified and uniquely segregated or handled as nonconforming to prevent their inadvertent.use."
Contrary to the above, 70 to 72 steam generator support bolts (exact number not known by CECO or the contractor) were received on MRR 3725 in January 1979 and identified as nonconforming.
No records exists to show the disposition of these bolts and no Nonconformity Report was issued as required by Phillips, Getschow Company's Quality Assurance Manual, Section 15.
Corrective Action Taken and Results Achieved As described in the response to Example 2, traceability of the bolts is being verified during their removal and reinspection in accordance with PGCo procedure PG CP-33 and 34.
Action-Taken to Avoid Further Violations CECO site personnel were reminded of their responsibilities in the dispositioning of materials, parts and components which are rejected at the time of receipt. Proper disposition may not include issuance of an NCR if the material is rejected and scrapped during receipt inspection.
However, a reject tag should be issued and may be documented on the Material Receipt Request (MRR).
Date When Full Compliance Will Be Achieved i
March 23, 1983.
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Example 5: 10 CFR 50, Appendix B, Criterion XVI requires in part " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, devia-tions, defective material and equipment, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition."
The CECO QAM QR No. 16, Paragraph 16.1 states in part, "A corrective action system will be used to assure that such items as failures, malfunctions, deficiencies, deviations, defective material and equipment and nonconformances which are adverse to quality might affect the safe operation of a nuclear generating station are promptly identified and corrected." Paragraph 16.3 states in part, " Records will be regularly reviewed and analyzed by Quality Assurance and Engineering personnel...to determine whether corrective measures will preclude recurrence." The CECO QAM QP No. 16.1 implements this requirement.
Contrary to the above, CECO did not assure that a matter poten-tially adverse to quality was promptly identified and corrected at the Braidwood Station. CECO identified a significant problem with bolting of the steam generator supports that occurred at the CECO Byron Station. Timely or adequate corrective action was not taken by CECO to prevent the same or a similar problem from occurring at Braidwood Units 1 and 2. Nonconformity Report No. 322 concerning this bolt problem was issued at Braidwood on December 2, 1981, yet effective corrective action was not taken until August 1982.
In addition, effective corrective action was not taken by CECO relative to Phillips, Getschow Company's failure to implement and utilize installation procedure (identified during CECO audits conducted June 30 - July 9, 1980 and June 23-25, 1981),
concerning installation and installation inspection of mechanical safety-related equipment. The same deficiencies were again identified during a surveillance conducted by Phillips, Getschow Company on February 19, 1982.
Discussion At the time steam generator support bolts were being installed at Braidwood, CECO was aware of the bolting problem encountered at Byron and had taken timely steps to employ the corrective action used at Byron. This was documented by PGCo NCR 334 on February 8, 1979. For the Unit 1 Steam Generators, bolts were shortened before installation.
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However, the shortening of the bolts did not completely resolve the problem at Braidwood. Further and different action became necessary. CECO issued nonconformance report No. 332 on December 2, 1981, which resulted in a stop work order. When in August, 1982 CECO was suffiently satisfied with the adequacy of the the new corrective action, the stop work order was lifted and the corrective action implemented.
Corrective Action Taken and-Results Achieved Actions taken to correct deficiencies in the control of mechanical equipment installation were described in the 50.55(e) report submitted on October 8, 1982.
Action Taken to Avoid Further Violations Site Q.A. audit ~ deficiencies will be closed only after corrective action completion has been verified. This practice, in combination with routine reporting of open audit deficiencies, will assure visibility to CECO management of contractors who fail to resolve deficiencies in a timely manner.
Date When Full Compliance Will Be Achieved October 1, 1982.
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Example 6: 10 CFR 50, Appendix B, Criterion XVII requires in part,
" Sufficient records shall be maintained to furnish evidence of activities affecting quality. The records shall include at least the following: ...results of reviews, inspections, tests, audits, monitoring of work performance, and materials analyses... Records shall be identifiable and retrievable."
The CECO QAM QR No. 17.0, Paragraph 17.1 states in part,
" Quality Assurance records will be maintained either by Edison or by an agent of Edison, under Edison's control. . . . Records are retained and maintained in accordance with a Quality Procedure to furnish evidence of activities af fecting quality."
The CECO QA QR No. 10.0, Paragraph 10.5 states in part,
" Inspection and test records will provide objective evidence that inspections and tests were performed in compliance with instructions and procedures to verify design and code requirements. Inspection and test results will be recorded to show conformance with acceptance criteria and/or record and identify the cause of rejected items." The CECO QAM QP No.
17-1 implements the above requirements.
Contrary to the above, with a few exceptions, official records were not generated or maintained relative to the installation of mechanical safety-related equipment by either CECO or their erection contractor. Records that failed to show compliance with quality assurance, design, and code requirements included:
(1) equipment releases to engineering for installation, (2) travelers or process sheets to identify required installation activities and inspections, (3) installation inspections, (4) pretensile loads for bolting, and (5) data on final equipment settings.
Corrective Action Taken and Results Achieved As described in the 50.55(e) report submitted on October 8, 1982, previously installed mechanical equipment has been reinspected and records have been generated to document the adequacy of the installation.
Actions Taken to Prevent Further Violations As also indicated in the 50.55(e) report, future such installation work will be done in accordance with a revised procedure.
Date When Full Compliance Will Be Achieved The inspections were completed on December 30, 1982. Steam generator bolt verification will be completed by the end of 1983.
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l Example 7: 10 CFR 50, Appendix B, Criterion XVIII requires in part, "A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program.... Followup action, including reaudit of deficient areas, shall be taken where indicated."
The CECO QAM QR No. 18.0, Paragraph 18.1 states in part,
" Audits will be performed by Commonwealth Edison Company and/or its contractors, subcontractors and vendors to verify the implementation and effectiveness of quality programs under their cognizance." The CECO QAM QP No. 18-1 implements this requirement. Paragraph 5.1 of QP No.18-1 states in part,
" Audits of on-site contractors will be performed, as a minimum on an annual basis.... The selection of contractor on-site activities to be audited and the frequency of audits will be based on site Quality Assurance and CECO Construction Surveil-lance Reports or findings from previous audit reports.... The
- frequency will be based on the nature and safety significance ;
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of the work being performed."
Contrary to the above, no audits were performed by CECO prior to June 30 - July 9, 1980 relative to mechnical equipment 4
erection and inspection activities of Phillips, Getschow Company. This important activity involves the installation of most of the 7ritical nuclear steam supply system and other mechanical safety-related equipment. Significant amounts of this equipment, including that identified in I.A.1 above, had either been finally or partially installed prior to this date.
- Further, no significant followup audit was conducted by CECO until June 23-25, 1981 to determine the effectiveness of the Phillips, Getschow Company's quality assurance program for these installations, or to verify that proper quality records were being generated and maintained as required, although a major finding during the June - July 1980 audit was that Phillips, Getschow Company had not implemented an approved procedure for installing equipment and inspecting that installation.
Discussion The following list of audit activities demonstrate that adequate audits were conducted: '
a) CECO Quality Assurance audits had been performed prior to June 30, 1980 as follows: ,
- 1) During the period May 17-21, 1979, General Office Quality Assurance audited the Braidwood site and identified that PGCo Quality Control involvement in equipment setting was not evident. Eq~uipment Erection Records were later produced that demonstrated QC involvement for equipment grouting and tightening of anchor bolts. Based upon this the observation i was closed on August 31, 1979.
- 2) On 6-21-79, Site Q.A. Audit #20-79-37 was performed that addressed equipment installation. The use of current documents, and the use of qualifieo personnel, procedures, materials, tools, and equipment were questioned. Also the presence of in-progress inspection of the work and work areas being done during equipment installation was checked. No items of non-compliance were identified.
b) For financial reasons, construction activities were stopped from September, 1979 to March, 1980. No Quality Assurance audits of this area were required and as a result were not performed.
c) Another CECO site Q.A. audit (20-80-21) was performed from 6-30-80 to 7-9-80. This audit identified that Phillips, Getschow had not implemented adequate procedures for equipment installation and installation inspection. Phillips, Getschow's 7-21-80 response stated that equipment which had been previously installed would be backfitted to document any information available and bring the equipment into full compliance.
To verify proper implementation of corrective action for this item an audit follow-up surveillance was performed by site Q.A. on January 9, 1981. Eleven pieces of equipment were examined to verify that Phillips, Getschow procedure PGCP-8 (Equipment Erection) was being implemented. For each piece of equipment examined it was determined that the required " Equipment Erection Record" (Installation Traveler in use at the time) had been completed and was being utilized by PGCo Production and Q.C. for equipment previously installed and at the time being installed.
As a result, since it appeared that PGCo was implementing procedure PGCP-8 and had started to backfit previously installed equipment, the deficiency was closed. There was no reason at this time to believe that PGCo would not continue to implement their procedure PGCP-8.
d) During the period March 11-15, 1982 the General Office Q.A.
Department performed an audit that identified the following deficiency as Finding #7:
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" Contrary to 10CFR50, Appendix B, Criteria XV, XVI, and XVII, Phillips, Getschow (PGCo) has not adequately demonstrated or documented Q.C. involvement with regard to mechanical equipment installation at Braidwood. For 110 cases of installed equipment, Q.C. involvement was not documented. Production was not routing Equipment Erection Forms to Q.C. for Q.C. to assign hold points."
As part of the audit report the G.O. Audit team presented the following assessment:
"An initial review of installation records for the following equipment was performed: 2AF0lPA, 3AC03P, 2BR01A, 2CC0lPA, 2CC01A, 2CC0iT, 2CF0lP, and 2CS0lPA. In all cases with the exception of 2CC01T (cc Surge tank) no Q.C. hold points were established prior to installation.
In the case of 2CC0lT, a hold point for torqueing was established and was witnessed on 8-4-81. In addition, review of over 40 unit 2 EER's indicated that only one hold-point was established for welding and 16 were established for torqueing. In no case was any other aspect of equipment installation witnessed by Q.C. Review of 63 unit 1 EER's indicated similar activity. Therefore, in over 110 cases Q.C.
involvement was not documented or demonstrated.
It is, therefore, indicated that Criterion X is being compromised with respect to inspections since procedure PGCP-8, Rev. 2 is inadequate to properly define Q.C. involvement with this activity.
Criterion XVII requires inspection records, as a minimum to identify the inspector, the type of observation, the results, and the acceptability of the inspection. Corrective actions taken should accommodate these requirements. In no case during the review of the above EER's was there a report where all required signatures appeared completed in accordance with PGCP-8. It is therefore not clear what the status of installation or inspection is for the mechanical equipment at Braidwood.
Further review indicated th9t PGCo identified problems concerning the Equipment Erection Reports on 2-19-82. This was documented on a PGCo surveillance that date. As a result of that surveillance, PG NCR 649 was initiated on 3-12-82. In June 1981, CECO Audit 20-81-22 identified related problems concerning equipment installation. PG NCR 592 was initiated at that time to address the concerns.
Contrary to Criterion XVI timely corrective action has not occurred with respect to equipment records. Prompt identification and correction of deficiencies within the Program is not evident. No progress in corrective action was evident since August 1981.
As a result of the Finding listed in the General Office Q.A. audit, PGCo Q.C., on 3-30-82, placed a stop work on equipment installation.
The stop work memo stated:
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"I have been directed by our Quality Assurance Manager and CECO Site Q.A., to stop all safety related work performed under PGCP-8, Revision #1 until our EER forms have been revised and personnel are properly trained in their use. All EER forms for safety related equipment shall be returned to this office immediately and no work is to proceed without approval of this office." (Signed A Rubino, Q.C.
Supervisor, Phillips, Getschow Co.)
In response to the General Office audit and the stop work order the following actions were taken:
- 1. With the help of CECO Q. A. , PGCo draf ted two (2) new forms for equipment erection; QCP-822-1, Equipment Installation Record, and QCP-B22-2, Equipment Alignment Data Sheet. These were given Q.A.
interim acceptance for use on 4-2-82 to be used in conjunction with PGCo procedure PGCP-8.
- 2. Via a 5-13-82 letter, CECO Project Construction Department forwarded guidelines to be used for the inspection and documen-tation of equipment installed prior to 4/82. (Again to be used in conjuction with PGCP-8) This was the result of discussions among CECO Q.A., PCD, and PGCo.
- 3. Based upon the acceptance of the above forms and the 5-13-82 letter, PGCo Q.C. allowed installation work to proceed on a case by case basis. As new QCP-B22-1, QCP-B22-2 forms were properly filled out by PGCo Engineering and issued to the field by PGCo Q.C., work was allowed to proceed (only for equipment that had new forms issued).
- 4. PGCo procedure PGCP-8 was revised and superseded by PGCo procedure QCP-B22, this was a complete rewrite to more specifically define criteria and guidelines followed for the installation of mechanical equipment.
These corrective action measures were sufficient to adequately correct the mechanical equipment installation problem and allow the audit finding to be closed on 7-15-82.
As is stated above, CECO Quality Assurance performed quality audits and follow-up surveillances of mechanical equipment installation in a timely fashion in accordance with the requirements of 10CFR50, Appendix B, Critellon XVIII. The March, 1982, General Office Q.A. Audit re-identified the mechanical equipment problem and the associated concern of corrective action not being timely. It was from this audit that firm corrective measures were put into motion to correct the equipment installation problem prior to the NRC involvement of April, 1982.
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4 Exception is taken to the assertion that 10CFR50 Appendix B, Criterion XVIII and CECO Q.A. Manual Section QR 18.0 have been violated. As presented above, a comprehensive system of planned and periodic audits was carried out to verify compliance with the aspects of the quality assurance program related to mechanical equipment installation and to determine the ef fectiveness of that program. Follow-up action, including follow-up surveillances and audits of the deficient areas, was performed as described above.
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Civil Penulty Violation B 10 CFR 50.55(e)(1) requires in part, "If the permit is for construction of a nuclear power plant, the holder of the permit shall notify the Commission of each deficiency found in design and construction which, were it to have remained uncorrected, could have affected adversely the safety of operations of the nuclear power plant at any time throughout the expected lifetime of the plant, and which represents:
(i) A significant breakdown in any portion of the quality assurance program conducted in accordance with the requirements of Appendix B; or...
(iv) A significant deviation from performance specifications which will require extensive evaluation, extensive redesign, or extensive repair to establish the adequacy of a structure, system, or component to meet the criteria and bases stated in the safety analysis report or construction permit or to otherwise establish the adequacy of the structure, system, or component to perform its intended safety function."
Commonwealth Edison's Quality Assurance Manual, Quality Procedure QP No.
15-2, Paragraph 5.1.1 states in part, "The site Construction Superintendent or Project Engineer and appropriate Engineering Project Engineer will mutually agree upon and review with the Director, Nuclear Licensing, as to chich deficiencies and defects are reportable, based on preliminary information and shall promptly notify the NRC Regional Office with 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of occurrence.
Braidwood Construction Contract Specification F/L 2739, Article ll3.4.P and Specification F/L 2797 states in part " Measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. The identification of the advdrse condition, the cause of the condition, and the corrective action taken to prevent future recurrence of like deficiencies shall be documented and reported to appropriate levels of management."
Contrary to the above, the licensee had identified as early as July 1980 a quality assurance breakdown relatis e to the installation and inspection of mechanical safety-related equipment, but did not report this matter to the NRC until September 2, 1982.
Corrective Action Taken and Results Achieved This matter was not considered reportable until it was reviewed with the NRC at the August 31, 1982 enforcement conference. It was reported promptly after that meeting. A detailed 30-day written report was provided on October 8, 1982.
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Action Taken to Avoid Further Violations All audit findings will be routinely reviewed for reportability under the terms of 50.55(e). To assure that these reviews are conducted in a uniform manner, a checklist has been developed for use by engineering personnel in determining reportability. It provides more specific criteria than are provided by the regulation.
Date When Full Compliance Will Be Achieved All CECO Q.A. audit reports issued after January 1, 1983, will be routinely reviewed for reportability. Reports issued since January 1, 1983 will be reviewed by April 30, 1983.
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Violation Not Assessed a Civil Penalty 10 CFR 50, Appendix B, Criterion XIII, requires in part, " Measures.shall be established to control the handling, storage, shipping, cleaning and preser-vation of material and equipment...to prevent damage or deterioration."
The CECO QAM commits to comply with Regulatory Guide 1.39, Revision 2 which in turn endorses ANSI Standard N45.2.3-1973.
ANSI N45.2.3 states in part, "The control of all tools, equipment, materials and supplies that are used shall be maintained to prevent inadvertent inclusion of deleterious material or objects in critical systems."
Contrary to the above, the licensee failed to protect the 480-volt Motor Control Center No. 133V1 (LAP 40-E) (located on elevation 364 near column P15, auxiliary building Unit 1), from a mixture of water and fine grained concrete powder which resulted from the core boring through a concrete block wall adjacent to the motor control center. In Unit 2, containment building, the licensee failed to protect steam generator No. 2 column support, lower universal hinged joint, from steel cables used to position and support heavy steel jet deflector beams.
Corrective Action Taken and Results Achieved MCC 133V1 (1AP40-E) was cleaned. The steel cable which damaged the protective 0-ring was removed.
Action Taken to Avoid Further Violations Site contractors were all reminded of the requirements for the proper care and protection of safety-related equipment. A procedure was developed to prevent damage to unprotected joints on the steam generator legs.
Date When Full Compliance Will Be Achieved March 23, 1983.
Newburg Procedure #31 was approved on October 20, 1982 for use in preventing further damage to steam generator leg joints.
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