ML20214C569
| ML20214C569 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 02/13/1986 |
| From: | Gardner R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20214C321 | List: |
| References | |
| OL, NUDOCS 8602210179 | |
| Download: ML20214C569 (23) | |
Text
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UNITED STATES OF AMERICA -
NUCLEAR REGULATORY COMMISSION
~
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
C0 20NWEALTH EDISON COMPANY ) Docket Nos. 50-456 50-457 (Braidwood Station,. Units 1 and 2 1 AFFIDAVIT OF RONALD N. GARDNER IN SUPPORT OF NRC STAFF'S RESPONSE TO APPLICANT'S MOTION FOR SUMARY DISPOSITION OF ROREM QA SUBCONTENTION 12.F I, Ronald N. Gardner, being duly sworn, aver and state as follows:
- 1. I am employed by the U.S. Nuclear Regulatory Comission, Region III, 799 Roosevelt Rd., Glen Ellyn, IL 60137 as Project Manager for the Kewaunee,' Point Beach, and Prairie Island facilities in Branch 2, DRP. A copy of my professioral qualifications is attached hereto as Exhibit 12.F-1.
- 2. Prior to becoming Project Manager, I was the NRC inspector assigned to follow the implementation of the Braidwood Construction Assessment Program (BCAP). BCAP is a program of inspections and reviews .
undertaken by the licensee in response to various concerns regarding the overall quality of construction of the Braidwood Station.
- 3. The BCAP was comprised of three elements. The first element, the Construction Sample Reinspection (CSR), consists of a review and reinspection of a sample of the completed construction work. The second element, the Reverification of Procedures to Specification Requirements (RPSR), consists of a review of current installation and inspection procedures which govern ongoing and future safety-related construction B602210179 860218 DR ADOCK O y 46
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work. The third element of BCAP, the Review of Significant Corrective ,
Action Program:; (RSCAP), consists of a review of the implementation, methodologies, and resulting documentation associated with the ,
significant corrective action programs which resulted from previously identified deficiencies.
- 4. My assigned duties in following the BCAP included: the performance of inspections and investigations of BCAP activities to assure that the program was being conducted in accordance with regulatory requirements and Applicant commitments including recomendations for any appropriate enforcement action; action as liaison between NRC staff J'
personnel and senior Applicant management in BCAP and escalated enforcement matters; and preparation of an evaluation of the BCAP for the NRC SALP report.
- 5. The purpose of this Affidavit is to support the NRC Staff's I Response to Applicant's Motion for Sumary Disposition with regard to Rorem QA Subcontention 12.F. This subcontention states:
- 12. Contrary to Criterion XVI, " Corrective
, Action," of 10 C.F.R. Part 50, Appendix B, .
, Commonwealth Edison Company has failed to
) ensure that measures were established to ,
assure that conditions adverse to quality, l such as failures, malfunctions, deficiencies, and nonconformances are properly identified and corrected. And in the case of significant conditions adverse to quality, Applicant failed to ensure that the cause of the condition is detennined and corrective action taken to preclude repetition.
F. In addition, 37 BCAP observations were invalidated by S&L even though the documented basis for the invalidations of the observations did not support the invalidations. (Inspection Report 85-06, Exh. 11.)
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- 6. In preparing this Affidavit, I have reviewed the following ,
documents:
- a. " Material Facts as to Which There is No Genuine Issue to Be Heard" (with regard to 12.F);
- e. NRC Inspection Report Nos. 50-456/85006 and 50-457/85006 (pertinent portions attached as Exhibit 12.F-2 hereto);
- f. Licensee's Response of May 6,1985 to NRC Inspection Report Nos. 50-456/8506 and 50-457/86006 (pertinent portions attached as Exhibit 12.F-3);
- g. IE0G Observations 007 (dated January 14,1985);
- h. BCAP Task Force response to IEOG Observation 007 (dated .
' January 25, 1985); and
. ~
- i. BCAP QA logs of invalidated observations (various).
- 7. The item of noncompliance referred to in Rorem QA Subcontention 12.F was identified by me during a special inspection and is documented in NRC Inspection Report Nos. 50-456/85006 and 50-457/85006. The Applicant responded to this notice of violation in a letter dated May 6,1985, wherein it maintained that no noncompliance existed. (See Exhibit 12.F-3)
- 123 -
- 8. In further response to this Inspection Report, members of .
Applicant's staff and I discussed this item in a me.eting on May 17, 1985.
During that meeting, the Applicant stated that the following actions with respect to invalidated observations / discrepancies had been initiated:
- a. BCAP QA established mandatory hold points during the processing of invalidated observations or discrepancies to allow QA to review the justification for invalidation.
- b. BCAP QA reviewed previously invalidated observations and discrepancies to ensure that sufficient _iustification for the invalidations existed.
(See NRC Letter, dated June 27, 1985, attached as Exhibit 12.F-4 hereto).
- 9. I have reviewed the logs of these QA reviews recently and I conclude that the Applicant's commitment has been fulfilled. No further response by the Applicant is required.
- 10. The corrective actions taken by the Applicant adequately addressed my concerns as inspector and these actions provide additional confidence in the adequacy of the Applicant's review and evaluat.fon of identified observations and discrepancies.
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- 11. The item of noncompliance that forms the basis of Subconten- ,
tion 12.F will be closed upon the issuance of the final BCAP inspection report expected in February 1986.
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Ronald N. Gardner Sworn and subscribed before me this /:'J' day of February,1986 .
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Notary Public My Commission expires.N
- I ESINUI'U 27. 33 5
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Professional Qualifications ,
s RONALD N. GARDNER 4
e ORGANIZATION: U.S. Nuclear Regulatory Comission, Region III TITLE: Project Inspector, Division of Reactor Projects l BIRTH DATE: June 19, 1945 EDUCATION: 1968 - 1970, Thomas Nelson Community College
, 1970 - 1972, Virginia Polytechnic Institute, B.S.
in Electrical Engineering 1975. Department of the Navy, Ship Superintendent
- School (Nuclear) 4 EXPERIENCE
July 1, 1985 to Project Inspector - NRC - Maintaining status of Present operational and regulatory perfonnance of operating 4
reactors.
August 1984 to Project Manager - NRC - Manages and coordinates
, July 1, 1985 inspections / investigations of BCAP activities to l assure that the program is being conducted in accordance with regulatory requirements and licensee commitments.
October 1982 to Profect Manager - NRC - Coordinate licensing August 1984 a,ctivities and perform inspections on reactors under j construction (Office of Special Cases).
3 i October 1980 to . Electrical Inspector - NRC - Perform electrical October 1982 inspections on reactors under construction.
1977 to 1980 Electrical Engineer - Daniel Construction Company -
Responsible for systems completion and cable terminations on nuclear plants under construction.
- 1975 to 1977 Electrical Engineer - Norfolk Naval
- Shipyard - Responsible for timely overhaul of Nuclear Submarines.
1972 to 1975 Electrical Test Engineer - Newport News Shipyard -
Responsible for testing of electrical systems on Nuclear Surface Ships.
1
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Exhibit 12.F-2 U.S. NUCLEAR REGULATORY COMMISSION REGION III Report No. 50-456/85-006(DRP); 50-457/85-006(DRP) l Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Nuclear Power Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, Illinois ,
Inspection Conducted: February 4 through March 1, 1985 Inspector: R. N. Gardner r LM Approved By: e /
Date Inspection Summary Inspection on February 4 throuah March 1.1985 (Report Nos. 50-456/85-006(DRP);
50-457/85-006(DRP))
Areas Inspected: Special, announced safety inspection of the Braidwood Con-struction Assessment Program (BCAP) in regards to licensee action on previously identified items, Construction Sample Reinspection (CSR) Documentation Review .
Checklists, invalidated BCAP discrepancies, CSR reinspection activities, and
.RSCAP activities. The inspection consisted of 144 inspector-hours onsite by one NRC inspector.
Results: Of the five areas inspected, no items of noncompliance were identified in three areas; two items of noncompliance were identified in the remaining areas (failure to ensure that inspection personnel have acceptable level of capability - Paragraph 3; and failure to take proper corrective action - Paragraphs 3 and 4).
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l Ex. 12,(_g,p g Appendix 4
NOTICE OF VIOLATION f
. Commonwealth Edison Company Docket No. 50-456 l Docket No. 50-457 I
As a result of the inspection conducted on February 4 through March 1,1985, and in accordance with the General Policy and Procedures for NRC Enforcement Actions, (10 CFR Part 2, Appendix C), the following violations were identified:
- 1. 10 CFR, Appendix B, Criterion II, states, in part, that "The quality assurance program shall provide control over activities affecting the quality of the identified structures, systems, and components.... The program shall provide for indoctrination and training of pers,onnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained."
Commonwealth Edison Company Quality Assurance Manual, Quality Requirement No. 2.0, Section 2.3, states, in part, that " Qualifications and certi-fications will be... established to meet the applicable requirements of
- ... ANSI Standard N45.2.6... Contractor personnel engaged in inspection...
t will be required to be trained, qualified, and certified to perform their
( specific activity in accordance with the above requirements.
ANSI N45.2.6-1978, Paragraph 4, states, in part, that " Personnel who are assigned the responsibility and the authority to perform functions covered by this standard shall have, as a mininas, the level of capa-bility shown in Table 1. Table 1 requires a Leiel II capability for personnel evaluating the acceptability of inspection and examination results. According to Table 1, Level I inspectors are authorized to act as data takers but they are not authorized to determine the acceptability 1 of constructi.on activities.
h'gl'9-Contrary to the above, the licensee's electrical contractor utilized
- Level I Quality Control (QC) inspectors for inspection and acceptance of electrical welds. This practice involved 14 different Level I inspectors over a four year time period.
This is a Severity Level IV violation (Supplement II).
- 2. 10 CFR 50, Appendix B, Criterian XVI, states, in part, that " Measures shall be established to assure that conditions adverse to quality, such as...nonconformances are promptly identified and corrected."
Commonwealth Edison Company Quality Assurance Manual, Quality Requirement No. 16, Section 16.1, states, in part, that "A corrective action system will be used to assure that such items as. . .nonconformancies. ..which are adverse to quality...are promptly identified and corrected."
l
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l Ex.12.F-2, p.3 Appendix 2 Contrary to the above, the following instances of failure to take proper
. corrective actions were identified:
- a. Although the Braidwood Construction Assessment Program (BCAP) had identified that Level I QC inspectors had inspected and i
accepted construction activities, in violation of the require-ments delineated in ANSI N45.2.6, this nonconforming condition was not documented as a BCAP observation. gf-DI +tla )
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- b. Thirty-seven BCAP observations, which dealt with the lack of QC verified " red-lined" record copy drawings, were invalidated by the BCAP taskforce even though the documented basis for the invalidation of the observations did not support the invalidations. ,
gf.ob hi[b)
This is a Severity Level IV violation (Supplement II).
Pursu?nt to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each ites of noncompliance: (1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown. .
March 8, 1985 ME/L)aw'4]c R. Y. Warnick, Chief Dated
, Projects Branch 1 9
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l Ex.12. F-2, p.4 l
l Level I inspectors is questionable. Previous inadequacies in the i training progree for Level I electrical weld inspectors, as documented -
l in NRC Inspection Report Nos. 456/84-07 and 457/84-07, increases the concern regarding the acceptability of welds inspected and accepted solely by Level I QC inspectors.
This failure to establish and implement a program which assures that QC l inspection personnel, who are performing activities affecting quality, are trained and certified to the level required to adequately perform
, those activities is an item of noncompliance to 10 CFR 50, Appendix B, 4
Criterion II (50-456/85-006-02; 50-457/85-006-02).
- 4. Review of Invalidated ECAP Discrepancies l The inspector reviewed 37 BCAP observations which documented deficiencies identified during Construction Sample Reinspection (CSR) documentation reviews. The population for which the documentation reviews were per-formed was small bore piping configuration. The observations dealt with the lack of QC verified " red-lined" record copy drawings required by Phillips Getschow Co. (PGCo) procedures. While the observations were validated by CSR engineers, they were subsequently invalidated by Sargent and Lundy (S&L). The inspector was informed by Evaluation Research Corporation (ERC) personnel that ERC observation number 007 had been initiated by ERC to document the Independent Expert Overview Group (IEOG) position that the S&L invalidations were unacceptable. The ERC obser-l vation correctly concluded that in developing the "As Constructed" drawing, QC was required by procedure to verify the accuracy of the verification drawing and that at issue in the BCAP observations was the lack of the
, signature or initials of the certified inspector who performed the
! verification. Since the inspector who performed the verification was not known, the acceptability of that inspector's level of certification could not be determined, and therefore rendering the status of the inspection indeterminate. ,
The inspector subsequently reviewed the BCAP written response to the ERC observation. This response stated that the QC signature on the l verification drawing was not required as the QC inspector who performed the field verification marked up the verification drawing copy as necessary and signed the "Stop Work Order" to signify completion of the ,
QC verification. The BCAP response further stated that the BCAP Small Bore Pipe Configuration Docuser.t Review Checklist would be revised to reflect the QC signed "Stop Work Order" form as an acceptable alternative l to the QC signed or initialed " Red-line" drawing. (This revision was i subsequently issued on February 1,1985.) Finally, the BCAP response stated that observations describing the lack of a QC signature on the i " red-line" drawing previously processed as valid would be reprocessed as j invalid observations. ERC concurred in the response.
i In reviewing this matter the inspector, accompanied by the Senior i Resident Inspector, discussed the PGCo implementation of procedures QCP-40, Revision 3 and QCP-21, Revision 6 with PGCo engineering and QC personnel. As a result of these discussions the inspectors determined 4
Ex.12.F-2, p.5
)
l i
I that the QC inspector who signe'd the "Stop Work Order" was not the QC inspector who performed the field verification but was a QC inspector who worked in the QC office. Thus the QC signed "Stop Work Order" is not an acceptable alternative to a QC signed or. initiated " red-lined" drawing.
The invalidated observations do identify a valid nonconforming condition
, regarding the Small Bore Piping Configuration documentation in that there j was no record of the QC inspector who actually performed the field verification. Therefore, the acceptability of that inspector's level of certification remains indeterminate.
The invalidation of the 37 BCAP observations is not acceptable, is
, considered to be improper corrective action, and is a further example
- of noncompliance to 10 CFR 50, Appendix B, Criterion XVI '
(50-456/85-006-01(B); 50-457/85-006-01(B)).
- 5. CSR Reinspection Activities ,
i
- a. On February 19, 1985, the inspector witnessed the overinspection
- of a 4" conduit. The overinspection was performed by BCAP QA
] inspectors. The conduit had previously been reinspected by the
! BCAP taskforce. The CSR reinspection package number was CSR-I-E-CKD-054 while the conduit number was C2A5194. During
- the overinspection the inspector determined that the reinspection j performed by the BCAP taskforce accurately documented the i acceptability of the conduit.
I
- b. On February 20, 1985, the inspector, accompanied by the Resident Inspector, inspected two conduits which had previously been reinspected by the BCAP taskforce. The CSR reinspection package numbers were CSR-I-E-CMD-008 and CSR-I-E-CND-044 while the conduit
( numbers were C2A0217 and C0A7605.
l The inspectors concluded that the BCAP reinspections were performed
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in an acceptable mant er.
- c. On February 26, 1985, the inspector witnessed the overinspections of three cable pans. The overinspections were performed by ERC inspectors. The cable pans had previously been reinspected by the BCAP taskforce. The CSR reinspection package numbers were CSR-I-E-CBP-054, CSR-I-E-CBP-056, and CSR-I-E-CBP-057 while the cable pan numbers were 11678J, 21616J, and 1905A. During the overinspections the inspector determined that the reinspections performed by the BCAP taskforce accurately documented the acceptability of the cable pans.
- d. On February 27, 1985, the inspector witnessed the overinspection of a large bore pipe support which had previously been reinspected by the BCAP teskforce. The overinspection was performed by BCAP QA inspectors. The CSR reinspection package number was CSR-I-M-002-052 while the pipe support number was M-ICV 07065R. During the overinspection, the BCAP QA inspectors identified that the 1/2" offset dimension for the support to beam attachment was out of 5
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Exhibit 12.F-3
) Commonwealth Edison one FHst National Plaza Chicago lihnois -
Idaress Reply to Post Office Box 767 {
Cnicago. Ilknois 60690 l
May 6, 1985 Mr. James G. Keppler Regional Administrator '
Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Il 60137
SUBJECT:
Braidwood Station Units 1 and 2 Response to Inspection Reports Nos.
50-456/85-006 and 50-457/85-006 NRC Dockyt Nos. 50-456 ano 50-457 REFERENCE (a): R. F.
Warnick letter to C. Reed dated March 8, 1985
Dear Mr. Keppler:
Mr. R. N. This letter is in response to the inspection conducted by at Braidwood Gardner Station. on. February 4 through March 1, 1985, of activities 6 Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements.
The Commonwealth Edison Company disagrees with the items listed in the Notice of Violation.
our disagreement is provided in the enclosure.Our detailed discussion of the bases for
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Commonwealth Edison Company has initiated increased interface BCAP resident of the inspector.
Project Licensing and Compliance group with"the NRC onsite communications withItthe is NRC our desire to and are clear assure thatanroutine--
provide appropriate level of attention to NRC concerns.
Mr. R. F. The delay in submitting this response was discussed with Warnick on April 8, 1985 and Mr. W. S. Little on April 22, 1985.
direct them to this office.If you have any further questions on this matter, please Very t uly yours a
_ =:m
- D. L. Farrar -
Director of Nuclear Licensing
/klj ,
Enclosure '
, Ex.12.F-3, p.2 ENCLOSURE TWO COMMONWEALTH EDISON COMPAN9 RESPONSE TO INSPECTION REPORT 50-456/85-006 AND 50-457/85-006 ITEM 50-456/85-006-OlA AND 50-457/85-006-OlA ITEM 50-456/85-006-01B AND 50-457/85-006-018 Item of Noncompliance
- 2. 10 CFR 50, Appendix B, Criterion XVI, states, in part, that
" Measures shall be establisheo to assure that conditions adverse to quality, such as...nonconformances are promptly identified and corrected."
Commonwealth Edison Company Quality Assurance Manual, Quality Requirement No. 16, Section 16.1, states, in part, that "A corrective action system will be used to assure that such items as...nonconformances...which are adverse to quality...are promptly identified and corrected."
Contrary to the above, the following instances of failure to take proper corrective actions were identified:
g a. Although the Braidwood Construction Assessment Program (BCAP) nao identified that Level I QC inspectors had inspected and accepted construction activities, in violation of the requirements delinated in ANSI N45.2.6, this nonconforming conoition was not documented as a BCAP observation.
- b. Thirty-seven BCAP observations, which dealt with tne l lack of QC verified " red-lined" record copy drawings, were invalidated by the BCAP~taskforce even though the documented basis for the invalidation of the observations did not support the invalidations.
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l Response 2.a l
Commonwealth Edison Company does not agree that this is an cxample of an item of non-compliance. Contrary to tne description of this item in the notice of violation, this issue was documented i
on BCAP Observation Record CSR-R-G-ELE-XXX-171 on February 27,
! 1985. Unfortunately, due to apparently ineffective communications between BCAP personnel and the NRC inspector, the NRC inspector was not aware that this observation was issued during the week prior to his monthly exit interview meeting. .
Ex.12.F-3, p.3 ENCLOSURE TWO ITEM 50-456/85-006-OlA AND 50-A57/85-006-OlA ITEM 50-456/85-006-016 AND 50-457/85-006-018 The NRC inspector has now seen the Observation Record CSR-R-G-ELE-XXX-171. .
It is Commonwealth Edison Company's position that BCAP Observations will be documented and processed in accordance witn BCAP Procedure BCAP-06, " Observation and Discrepancy / Concern Processing".
Resoonse 2.b Commonwealth Edison Company disagrees that this item, as stated in the notice of violation, is an example of non-compliance.
This is because, contrary to the violations as stated, the BCAP task force did not invalidate any of the 37 BCAP observations in question. We do acknowledge that there does exist a valid concern regarding documentation of review of certain red-line drawings by Phillips Getschow QC inspectors and that this concern was identified and documented by Commonwealth Edison Company Quality Assurance.
q In order to fully understand the details of this issue, the following review of events is presented. It is especially noteworthy that several events occurred quickly and in parallel in the January 1985 timeframe.
Phillips Getschow (PGCo) is the contractor responsible for the generation and QC verification of as-constructed drawings for
. piping systems. PGCP-40 is the proce' dure governing this activity.
Revision 3 of this procedure, which is similar to earlier revisions-requires -
"5.3 the Supervisor-Quality Control shall:
5.3.1 Dimensional verify installed piping 5.3.2 Compare the As-Constructed drawing to the As-Installed condition...
5.3.5 Return verified drawing and form PG/QA-5-33, Section 3(a) properly signed j to the Project Engineer."
Paragraph 4.4 allows the delegation of authority to appropriately cortified personnel.
The thirty-seven observations were generated by a review by BCAP of the contractor documentation supporting the verification of '
as-constructed dimensions using BCAP checklist and instruction CSR-R-M-1 Rev. 1. The instructions to the BCAP document reviewer Ny ,cere:
"2.3 By reviewing the data package, verify the existence of the QC verified red-line record copy isometric leading up to the As-Constructed l isometric.
IT?
n Ex. 12.F-3, p.4 ENCLOSURE TWO
' ITEM 50-456/85-006-OlA AND 50-457/85-006-OlA ITEM 50-456/85-006-018 AND 50-457/85-006-018 2.4 Verify that the preparer (s) of the red-lined record copy isometric has a minimum certification level of LevelProcessII QC Piping inspectorand
... [ Certification Area:
Instrumentation]."
Additionally, Sections 2.1 and 2.2 recuire a QC signature on the final As-Constructed drawing. These instructions were based on BCAP's interpretation of PGCP-40, which indicated that the field verified drawing should be signed.
In their review of the " red-lined" drawings, BCAP found This resulted in the many which were not ' signed by QC in the itempersonnel.
of noncompliance. These observations referenced observations were processed by BCAP as valid for in accordance further with processing.
procedure BCAP-06 and sent to PCO and S&L They were validated because BCAP had no information at that time to indicate that the QC signature on the red-line drawing was not S&L reviewed these observations per BCAP-06 Rev. 6 required.
paragraph 4.6.1, at the end of December 1984, with the evaluation recommending that the observation be invalidated:
"There is no requirement for a " red-lined record copy isometric", as per S&L Specification F/L-2739, Article 301.11 and per Phillips Getschow Procedures 3."
QCP-821, Rev. 6 anc PGCP-40, Rev.
it is l
However, in accordance with BCAP-06 paragraph 4.7.1, Step 4.4 BCAP which must make the flnal determination of validity.
must be completed by BCAP before an observation is deemed invalid.
This step had not taken place for the tnirty-seven observations in question. BCAP has taken no steps to formally invalidate these observations. They remain valid at this time.
Group On January 14, 1985, the Independent Expert Overview (IEOG) identified a concern regarding S&L's recommendations that these observations be invalidated and documenteo their concern on their observation BCAP-0BS-007 which stated,
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Ex. 12.F-3, p.5 (4 .
(/ ENCLOSURE TWO ITEM 50-456/85-006-OlA AND 50-457/85-006-OlA ITEM 50-456/85-006-01B AND 50-457/85-006-01b
" Observation: S&L has responded to several BCAP Observations ... declarf.ng them to be invalid because no " red-lined record copy isometric" is required.
However, Phillips, Getschow Co. Procedures QCP-821, Revision 6 and PGCP-40, Revision 3 both require some form of verification drawing to be signed by QC.
This is a copy of the installation drawing which has been marked in the field to show actual dimensions and configuration of work completed in the plant for that part of construction. Whether it is called a
" red line" drawing, a verification drawing, or a field verification installation drawing is a technicality. The name of the drawing was not the subject of the observations listed below. At issue in these obstrvations is the lack of a signature or initials of a certified QC inspector. For this reason, the following S&L responses to BCAP Observations invalidly have been marked " Invalid..."
jf Also on January 14, 1985, a meeting was held, allowing PCD, PGCo, and S&L to explain their positions to BCAP regarding the contractor's documentation requirements supporting the generation and QC acceptance of "as-constructed" isometrics. At this meeting, en agreement was reached between the involved parties as to what documentation was required by the applicable procedures. The m;eting was documented by a January 15, 1985 letter BR/PCD 85-43 from the PCO Superintendent to the BCAP Director.
On this basis, on January 25, 1985 BCAP responded to tne
- IEOG observation as follows,
" DISCUSSION:
During the preparation phase of Documentation Review Checklist, CSR-R-M-1, Rev. O, "Small Bore Piping Configuration", the PGC0 Procedures, QCP-40, Rev. 3 and QCP-B21, Rev. 6, were reviewed and interpreted to require a "QC Signature" on the verification drawing (" Red-Line").
During the subsequent document review activities, several observations were written by the BCAP Inspectors and processed as valid. As a result of these observations, a meeting was held on January 14, 1985 between CECO PCD, S&L, PGCo, and BCAP in which PGCo provided a clarification of the documentation requirements of the above referenced -
procedures. A QC Signature on the verification drawing was
({
not required. Rather, QC was to sign section 3(a) of the "Stop Work Order", signifying completion, and to sign the QC approval block on the mylar of "As-Constructed" drawing. PCO later issued a memorandum, BR/PCD 85-43, on
l' f .
Ex. 12.F-3, p.6 f
e e _
ENCLOSURE TWO ITEM 50-456/85-006-01A AND 50-457/85-006-OlA ITEF 50-456/85-006-016 AND 50-457/85-006-016 January 15, 1985 confirming this clarification. Basec upon this clarification and a subsequent review of the PGCo procedures by BCAP, it has been determined that the referenced observations are invalid. The PGCo Procedures do not require that the verification drawings ("Reo-Line")
require a QC signature. The inspector performs the fielo verification, marking as necessary on the verification copy and signs the Stop Work Order to signify completion. The Engineering Department then revises the drawing mylar, as necessary, to reflect the marked-up verification copy. The mylar is then resubmitted to the QC organization for rev'ew and approval. These QC signatures on the "Stop Work Order" form and the mylar of the "as-constructed" drawing provide adequate quality documentation of Quality Control's Verification of the as-constructed dimensions.
" CORRECTIVE ACTIONS:
9 The QC-signed "Stop Work Order" form is the document which signifies QC acceptance of the " red-line" drawing, and will therefore be the document reviewed by BCAP in lieu of the " red-line" drawing. The Small' Bore Piping Configuration Documentation Review Checklist will be revised to reflect this change. Those portions of the document reviews performed to date affected by this revision will be redone using the revised checklist ano instructions. The Observations describing the lack of a QC signature on the " red-line" drawing previously processed as valid will be reprocessed as invalid.0bservations." "
Immediately following the January 14, 1985 meeting d2 scribed above, BCAP's discussions with BCAP QA determined a course of action that included revision of the checklist to properly reflect procedural requirements, a re-review of the contractor documentation to the new requirements, a surveillance of the contractor's activities in this area by site QA which was to be Orranged by BCAP QA, and subsequent to these activities, the invalidation of the previously generated observations.
The site QA surveillance #4151 was performed on January ,
22-24 and February 4-5, 1985 and documented on 2/14/85. It identified certain examples of nonadherence to the contractor proceoures.
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Ex. 12.F-3, p.7 3 ENCLOSURE TWO -
ITEM 50-456/85-006-01 A AND 50-457/85-006-01 A ,
ITEM 50-456/85-006-018 AND 50-457/85-006-018 -
In accordance with the above specified Corrective Actions, the BCAP instruction CSR-R-M-1 was revised on 2/1/85 and the re-review of the contractor's documentation began shortly thereafter.
This re-review documented concerns similar in nature to those identified by the QA surveillance.
BCAP has not invalidated the 37 observations.Because of these concerns, In conclusion, we believe BCAP's actions were prudent. The corrective actions specified in the response to the IEOG observation, in conjunction with the CECO site QA surveillance, could assure that any relevant concerns with the contractor's QC program for the verification of as-constructed drawings would have been identified. The thirty-seven observations in question will remain valid until a determination can be made as to the existence of acceptable documentation supporting certified QC inspectors verification of the as-constructed drawings.
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Exhibit 12.F-4 5104 2 7 $35 -
Docket No. 50-456
- Docket No. 50-457 Consonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL. 60690 1 Gentlemen:
Thank you for your letter dated May 6,1985, infoming us of the steps you have taken to correct the items of noncompliance which we brought to your attention in Inspection Report Nos. 50-456/85006 and 50-457/85006 forwarded
, by our letter dated March 8,1985.
Your response to Item 1 of the Notice of Violation stated that you do not agree i that this is a violation of your connitment to the requirements of ANSI M45.2.6-1978. We are referring this to NRC Headquarters for guidance on this yO matter and will contact you later as to our decision.
Regarding your response to Item 2.a of the Notice of Violation, we agree that this is not an example of noncompliance (and we will remove it from our records).
The information presented in your response was not known to the NRC inspector at the time of the inspection.
Regarding your response to Item 2.b of the Notice of Violation, we have reviewed the infomation in your response and still believe this is an example of noncompliance. This matter was discussed ^with members of your staff during a meeting on May 17, 1985. During this meeting your staff stated that the
! following actions had been initiated in regards to invalidated observations /
j discrepancies:
- 1. BCAP QA has established mandatory Hold Po'nts during the processing of invalidated observations / discrepancies to allow QA to review the justification for invalidation.
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- 2. BCAP QA would review previously invalidated observations /
i discrepancies to ensure that sufficient justification for
, the invalidations exists.
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Commonwealth Edison Company All of the above were discussed in a mee' ting with your Braidwood staff on May 17, 1985. Based on the actions described above and in your response no further response to this item of noncompliance is required. We will review these actions in a future inspection.
~
l Your cooperation with us is appreciated.
Sincerely, v 5{g h is{'gned b7 E M f80f2 f C. E. Norelius, Director Division of Reactor Projects cc: D. L. Farrar, Director of Nuclear Licensing M. Wallace, Project Manager
,D. Shamblin, Construction Superintendent J. F. Gudac, Station Superintendent ffet C. W. Schroeder, Licensing and (re" Compliance Superintendent DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII Braidwood Resident Inspector, RIII Byron Phyllis Dunton, Attorney Geieral's Office Environmental Control Division l D. W. Cassel, Jr. , Esq. -
.J. W. McCaffrey, Chief, Public Utilities Division H. S. Taylor, Quality Assurance Division E. Chan, ELD i
J. Stevens, LPM 1
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SUBCONTENTION 12.J .
, Rorem QA Subcontention 12.J as admitted in this proceeding states:
- 12. Contra'ry to Criterion XVI, " Corrective Action," of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that measures were established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are properly identified and corrected. And in the case of significant conditions adverse to quality, Applicant failed to ensure that the cause of the condition is determined and corrective action taken to preclude repetition.
J. In two areas, supports / restraints and piping runs, deficiencies were identified by the NRC CAT that were not identified by the BCAP inspectors. On the basis of the limited sample overinspected, it appears that BCAP inspection effort needs to be improved in areas of supports / restraints and piping runs.
In its Motion for Sumary Disposition, Applicant concedes that in the areas of pipe supports / restraints and piping runs deficiencies identified by the NRC Construction Appraisal Team (CAT) were not identified by BCAP inspectors. Applicant's Motion 12.J at 1, 6.
However, Applicant argues that even the best inspectors make mistakes -
occasionally and based on subsequent overinspections' Applicant concludes that the errors made by the BCAP Task Force inspector with respect to the piping runs were an isolated incident. Applicant's Motion 12.J at 7. In the area of pipe supports / restraints Applicant states that the BCAP Task Force reviewed all attributes called into question by the CAT findings.
Although 8 of 20 new observations were attributable to inspector error it was determined that initial inspections were greater than 98 percent accurate. d .
I_d Based on the overinspection program initiated as a result
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of this item, together with the high degree of qualification, training ,
and professionalism of the BCAP inspectors, Applicant contends that its
. inspection activities for piping runs and pipe supports / restraints complies with Criterion XVI of 10 C.F.R. Part 50, Appendix B. Therefore, Applicant arguer that there is no genuine issue of material fact to be heard with respect to the adequacy of BCAP Task Force inspections of pipe runs and pipe support / restraints. Applicant's Motion 12.J at 7-9. The Staff agrees.
The issue of a need for improved inspection effort in the areas of pipe supports / restraints and runs was identified during the CAT inspection of the Braidwood facility conducted during December 10-20, 1984 and January 7-18, 1985. Affidavit of Ronald N. Gardner in Support of NRC Staff's Response to Applicant's Mottun for Sumary Disposition of Rcrem QA Subcontention 12.J at 17 (hereinafter Gardner Affidavit 12.J).
In addition to the CAT inspection, Region III NRC Inspector Gardner witnessed overinspections of a concrete placement on January 16, 1985 where he noted four items not found by BCAP inspectors, (Gardner Affidavit 12.J at 118) and an everinspection of electrical conduit hangers where additional items not found by BCAP inspectnrs were noted (Gardner Affidavit 12.J at 19).
Mr. Gardner met with the Applicant's BCAP Director to discuss the need for significant actions to address the issue of reinspection deficiencies. Following this meeting the Applicant initiated the following currective actions:
(a) The Applicant performed a partial repeat reinspection of 160 previously reinspected mechanical pipe supports;
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(b) BCAP instructions were revised; and .
(c) Additional training was provided te BCAP inspectors. -
Gardner Affidavit 12.J at 111.
Mr. Gardner determined that the corrective actions adequately address the CAT findings. Gardner Affidavit 12.J at i 12. Furthermore, subsequent inspections of BCAP inspector performance in these areas provided addition,a1 assurance that the BCAP inspections wer'e satisfactory. Id. This unresolved item will be closed in the final BCAP inspection report expected to be issued in early February 1986. Id.
Hence, with regard to Subcontention 12.J, BCAP inspection efforts were in fact improved in the areas of pipe supports / restraints and pipe runs.
Id. Intervenor has not presented any information during discovery to controvert Mr. Gardner's or Applicant's assertions. Therefore, there are no genuine issues of material fact to be heard regarding this subcontention. Applicant is entitled to a favorable decision on this contention as a matter of law. Based on the discussion above, the Staff concludes that Applicant's Motion for Summary Disposition of Contention 12.J should be granted. .
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