ML20214E386
| ML20214E386 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 05/07/1986 |
| From: | Ramirez L, Tapella L COMMONWEALTH EDISON CO. |
| To: | Knopp D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| OL-I-ROREM-003, OL-I-ROREM-3, NUDOCS 8705220064 | |
| Download: ML20214E386 (12) | |
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a SPECIFIC TROUBLE REPORT L. J. Tapella L. Ramirez
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Braidwood Station 3:OO;un 1/31/84
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Couucawealth Edison Ccumpany is reporting the I
following potential 50.55E.
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'.rua During audits perfomed by CBCo Q.A., it was felt that improvements can be made to the L. K. Ccenstock files in the areas of:
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Timeliness of records retrievability.
2.
Better accountability of production records which support installation.
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Reconciliation of some cases of the use of outdated forms.
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Assuring completeness of records.
As a result of these concerns, L. K. Comstock was directed to perform a 100% documaant review.
Nearing completion of this review, we are finding the need to' verify some of the documents mostly through additional office reviews and in limited cases, field verification / inspection.
We will be evaluating the extent of the fisld verification affort required.
NOTIFIID:
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NUCLEAR REGULATORY CC '.WI SS.,.
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.s Docket No. 50-456 Docket No. 50-457 Commonwealth Edison Company ATTN:
Mr. Cordell Reed Vice President i
Post Office Box 767 Chicago, IL 60690 Gentlemen:
This refers to the routine inspection conducted by Mr. R. S.t Love and other members of this office on October 31 through November 4, November 7-21, 1983, and January 12, 13, 1984, of activities at Braidwood Station. Units 1 & 2-authorized by NRC Construction Permits No. CPPR-132 and No. CPER-133 and to the discussion of our findings with Mr. M. J. Wallace and others of your staf f
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on November 4, 1983, and with Messrs. D. Brown and L. Tapella of your staf f on 3,'
January 13, 1984 Since the causal factors of the identified violations are similar to the causal factors of other significant violations identified during a contemporary NRC inspection, the findings of this inspection were
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also discussed during an Enforcement Conference conducted on December 20, 1983,'in the Region III office which was attended by Mr. B. Davis and other members of this office and Mr. C. Reed and others of Commonwealth Edison Company.
The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a seicetive examination of proceduras and representative records, observations, and interviews with personnel.
.A During the inspection, certain of your activities aceeared to be in me pliance with NRC requirements as specified in the enclosed Appendix. A wrt ten response is required. Also, a written response is requested for the u. resolved matter involving torquing requirements for mour. ting electrical equipment which is discussed in Paragraph 3.D.(1).h of the enclosed report.
Because of the number and nature of our findings, we requested additional information to assist us in evaluating the effectiveness of CECO and L. K. Comstock organizations in accomplishing electrical construction i, activities in accordance with NRC requirements and commi,tments. Details M,
the requested information are described in Paragraph 7 of the enclosed reitort and in a CICo letter (M. J. Wallace to R. L. Spessard, of the NHC) dated November 17, 1983. In your response to this letter we request that you provide this information as well as a schedule for completing the on going documentation review, including any required re-inspectior.i, and,a schedule k
for rework (as required), re-inspection, and closecut"ofb tre 1,173 Inspection Correction Reports and 401 Nanconformance Reports discussed in Paragraph 3.A.(5) of the enclosed report.
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Commonwealih Edison Company 2
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'_Y'l dInc'e with 10 CFR 2.790(a), a copy of this letter and the enclosure (s)
In ace will be placed in the NRC Public Document Room unless you notify this nffice,
.j by telephone, within ten days of the date of this lettgr and submit written application to withhold information contained therein within thirty days of the date of this letter. Such application must be consistent with the ee-quirements of 2.790(b)(1). If we do not hear from you in this regarel within the specified periods noted above, a copy of this letter, the enclosure (s),
and your response to this letter will be placed in the Public Document. Ranm.
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The responses directed by this letter (and the accompanying Notice) are not subject to the clearance procedures of tho'0ffice of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
s We will gladly discuss any questions you have concerning this Npection.
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.R. L. Spessard, Director 3
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Ecclosures:\\
1.
Appendid, Notice
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of Violation
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2.
Inspection Reports
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No. 50-456/83-18(2 ) and
.No. 50-457/33-17(DE) s i ec w/encis:
D. L.1 Inrrar, Director I
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of Nuclear Licensing
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Resident Inspector, RIII Phyllis Dunton, Attorney i', General's Office, Environmental W
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2.
Actions on Previously Identified Items Cs (Closed) Unresolved Item (50-456/83-13-01):It was previously identified that the spacing length between hangers for sensing lines connecting flow transmitters FT-AF011 and flow indicator FI-AF021, exceeded the maximum span length for half inch pipes.
Subsequent to Inspection 83-13 Phillip Getchow (the piping contractor) issued Piping Support Field Problem Reports I-263 and I-585 to install two additional hangers.
ites is closed.
This (Closed) Noncompliance (50-456/83-13-02):
that instrument sensing line connections were reversed in fourIt was previo safety-related flow transmitters and four safety-related flow indication gauges connected to an auxiliary feedwater pipe.
from a Sargent and Lundy drawing M-828 which indicated' flow in theThe prob opposite direction from the auxiliary feedwater pumps.
has initiated corrective action on Field Change Order 1AF-563 to correct Phillip Getchow the discrep sacy on the transmitter's les rotating the body of the transmitter and to reverse the 3/8 inch tubing connections on each flow indicator.
instruments had been corrected.The inspector verified that the connections to This ites is closed.
i (open) Unresolved Item (50-456/83-13-06):
It was previously observed that cables of redundant divisions were terminated on motor operated valve M01CV8804A.
It has not been determined whether the installation is acceptable.
An additional probles not previously identified was observed
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in that only one of the two limit switches (in the " closed" position) mounted on the stem of the valve was electrically connected.
not be determined whether the "open" position limit switch should also be It could connected. This item is open.
(Closed) Noncompliance Item (50-456/82-06-01):
This item refers to the' apparent aisrouting of Cable ISX001. The report (456/82-06) failed to provide the dimensions observed between routing node point and the cable entry point to indicate the 3' foot tolerance.
It was agreed in the W. L. Stiede letter to Mr. James G. Keppler dated July this ites would be deleted.
12, 1983) that from NRC records has been' initiated.The necessary paperwork to delete this item 3.
Functional or Proeras Areas Inspected A.
Review of Audit Reports During this reporting period, the Region III inspectors reviewed the following CICo audits of L. K. Comstock Company, Inc. (LKC):
(1)
Audit of September 26 through October 5, 1983.
reviewed,the DRATT of this audit.
The inspector consisting of approximately 34 auditors.This was a CECO Team Audit The electrical portion of the sudit was conducted by an Audit Team Leader and six auditors.
observation in the electrical area.The auditors identified nine find 44f
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observation are as follows:
The findings and b
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a.
Findine #1 Fireproofing material (Pyrocrete) was found in C:
contact with non-ferrous metal causing possib?e deteriora-tion of the metal (
Reference:
b.
Finding #2 Cabling was found improperly stored inside the plant area, i.e., cable ends not sealed, and cable reels laying on their side.
c.
Finding #3 Weld inspection reports did not furnish proper evidence of an acceptable weld inspection in that portions of the reports were photo-copied.
d.
Finding #4 Lack of proper housekeeping was identified inside of cable pans, switchgear and motor control centers.
Findina #5 Grounding jumpers were not installed on e.
sealtight containing power cables.
f.
Findine #6 Unacceptable welds were in fact accepted by one LXC QC inspector. Welds were rejectable due to lack of fusion, undersize, undercut and slag.
3 Findina #7 Weld inspections were preformed by two unqualified and one de-certified QC inspectors.
h.
Findine #8 Nine instances where installation and C
inspection reports were not retreivable and four instances where the installation did not conform to S&L drawings.
i.
Findint #9 Audits were not indepth and the sample size was small.
j.
Observation #1 CICo has not imposed Branch Technical Position (BTP) 9.5-1 on the electrical contractor.
BTP 9.5-1 is discussed in the Byron /Braidwood Fire Protection Report.
This audit appeared to be an in-depth and well planned audit.
(2) Audit No. QA-20-83-37.
Performed August 15-18, 1983, Findings identified during this audit are as follows:
Procedures do not address testing interface and use of a.
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checklists and status logs.
b.
Travelers were prepared after the work was performed.
Adequate in process concrete-erpansion-anchor (CEA) c.
inspections are not being performed, actual CEA torque values are missing, and drawing revision number missing on CEA Reports. This finding was closed on October 26, 1983.
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d.
One hundred seventy-seven (177) rejected CEA reports sere C
open from greater than three months to approximately 27 months, (lack of timely corrective action).
i Findings a, b, and d were still open as of November 4, This audit reviewed CEA installation, Operator Analysis 1983.
Department (CAD) testing interface, and rework activities.
(3) Audit No. QA-20-83-32 Performed June 13-15, 1983. This audit reviewed document control records and personnel qualifications.
s Two observations were identified.
LKC did not give specific tests for tool / instrument a.
calibration, receipt and storage inspection, and electrical penetration inspection.
October 24, 1983.
This item was closed b.
If document transmittals are not acknowledged within 20 days, followup notices are required.
This is not being done in all cases.
1983.
This item was closed September 20, (4) Audit No. QA-20-83-20, Performed April 18-21, 1983. This audit-reviewed document control, material control, conduit installation, welding, nonconformance reports (NCR)/ inspection correction reports, corrective action, records storage, audits, and electrical installation inspections.
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findings were identified:
The following NCR/ICR open status reports were not issued monthly.
a.
item was closed on August 8, 1983.
This-b.
Return of void drawings was not being tracked and weld red stores requests were not controlled.
October 26, 1983.
This item was closed Lack of installation / inspection records for installed c.
equipment.
d.
Welding of main control board 2PM01J was not per installation drawings. No inspection reports were available for items 2PM01J, 2PM02J, 2PM03J and 2PM04J.
This equipment was installed on September 15, 1982.
Items e and d were still open as of Novemhet 4,1983.
(5) Audit No. QA-20-83-06, Performed February 9-16, 1983. This audit identified two findings and one observation.
Findings and observation are as follows:
a.
Findint #1 Housekeeping in general was poor. This item was closed on April 28, 1983.
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Findine #2 Terminations were not properly installed and C
I were not properly documented. Inspector performing these inspections was not properly. certified. This item was closed on June 10, 1983.
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Observation The installation of J-Boxes was not adequately covered by existing procedures. This item was closed on June 20, 1983.
4 During a review of the above listed audits, it became apparent that LKC had numerous probless with missing, incomplete, and inaccurate installation and inspection records. During interviews with the Ceco Electrical Quality Assurance Supervisor and CECO Lead Electrical Engineer, the Region III inspectors learned.that a major review of -
LKC QC records was taking place. This review.of records was to identify the missing, incomplete, and inaccurate inspections and reports.
Following is the status of the documentation review as of October 31, 1983:
No. Scheduled Area of Inspection for Review No. Completed
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Welding 20,183 7,589 Note 1, 4 Hanger Configuration 10,650 11,044-Note 2, 4
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Cable Pulling 2,496 2,496' Note 3 Terminations 4,045 None Note 1, 4 J-Box 1,715 None Note 1, 4 Cable Pan 3,395 None Note 1, 4 Conduit 818 None Note 1, 4 Equipment 83 None Note 1, 4 CEAs 11,878 2,212 Note 1, 4 Note 1 - Compilation of number and type of discrepancies observed will be made after the review has been completed.
Note 2 - Review of hanger configuration records has been completed but as of November 4, 1983, the compilation of discrepancies observed had not been completed.
Note 3 - In the area of cable pulling, 236 discrepancies were observed.
Following is a breakdown of the.ae discrepancies by attribute.
Uncertified inspector Use of out-of-date forms 13 41 QC did not witness cable pull 7
cRe-verification of inspection required 19 Inspection Report / Pull Card not signed 47 Lineouts/ changes not initiated and dated 109 k
Note 4 - NRC requested a copy of the breakdown of the discrepancies by attribute when available.
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The planned completion date for the record review is February 1, 1984.
A review of backlog of inspections of current work and review of the status of Inspection Correction Reports (ICR) and Nonconformance Reports (NCR) revealed the following:
Backlog of inspection from August 1,1983 through November 3,1983.
Equipment inspections 257 Raceway inspections 50 Manger Welding Inspections 477 Hanger configuration inspections 140 Open ICRs 1173 Open NCRs 401 During subsequent interviews with Ceco and LKC personnel, it was learned that since approximately October 1, 1983, eight (8) LKC Quality Control inspectors left the Braidwood site to accept employment elsewhere. In view of the records review program, the increase of backlog of inspections, the number of open ICRs/NCRs, and the loss of 8 inspectors, the Region III inspector expressed'a coacern about the adequacy of the LKC quality organization to,
address the above issues.
The CECO Lead Electrical Engineer informed the Region III inspector that LKC has been authorized to employ 20 new inspectors and that LKC was only pursuing qualified Level II type inspectors. Five new inspectors reported onboard the
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week of October 31, 1983 and are undergoing training. Five additional inspectors are expected by November 17, 1983 and ten more inspectors by November 30, 1983.
It was also observed that LKC employed a new QC Manager as of August 1,1983 (third within one year), a new Assistant Quality Control Manager as of October 20, 1983, and a new QA Engineer as of September 19, 1983. To supplement the LKC QC organization, Ceco has assigned several PTL inspectors to LKC QC.
Based on all the foregoing observations NRC expressed concern in regard to the ability of the Ceco /LKC organizations to continue new electrical construction activities at their current pace.
In summary, the constraining conditions are as follows:
(1) Reduce backlog of approximately 924 inspections, (2) Rework / repair and re-inspect approximately 1173 items documented on ICRs, (3)
Disposition approxinately 401 NCRs and rework / repair / reinspect as required, (4)
Complete a broad review and correct, as required, approximately 32,316 existing QC records, j
(5) Train and manage approximately 25 new LKC QA/QC personnel coming onboard during September, October, and November, 1983.
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As a result of this concern, NRC requested that the licensee take five specific actions to demonstrate their capabilities to accomplish the job. These issues, including actions required by the licensee, are discussed in the exit interview portion of this report (paragraph 7) and in the letter of transmittal for this report.
B.
Review of Procedures During thir reporting period, the Region III inspectors reviewed LKC work and inspection procedures and the following observations vers made:
(1). Procedure No. 3.1.3, " Reporting of Defects and Noncompliances",
Revision dated April 1,1980.
Paragraph 2.4 - Licensee should be notified in conjuction with the NRC.
If the licensee reports an event to the NRC in accordance with the requireeent of 10 CFR 21 or 10 CFR 50.55(e), it is not necessary for a site contractor to report the same event. In many cases, site contractors may not have the background / design information to perform an effective evaluation to determine if the event is reportable.
Attachment B - 10 CFR 21 is out of date. If Part 21 is going to be part of this procedure, it should be the
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current esvision.
Attachment D - Listing of NRC Regional.0ffice addresses and phone numbers are not current.
(2) Procedure 4.1.2, " Position Delineation", Revision A, dated February 18, 1983.
This procedure appears to be adequate.
(3)
Procedure 4.1.3, " Qualification Classification and Training of QA/QC Personnel", Revision B, dated August 11, 1983, i
This procedure appears to be adequate.
(4) Procedure 4.3.1, " Safety Related Conduit Installation",
Revision dated July 20, 1982.
This procedure appears to be adequate.
(5). Procedure 4.8.1, " Inspection of Class IE safety Related Conduit Installation", Revision dated May 20, 1982.
Paragraph 3.1.8 - This paragraph requires the LKC QC inspector to verify that all sharp edges have been removed from the conduit installation. Paragraph 3.1 states that QC will initiate their inspection on the completed conduit installation after receiving lthe Raceway Installation Report from LKC-construction. How does the QC inspector e
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h Unit 1 Unit 2 Overall Electrical Cable tray installation 70%
1 20%
Conduit installation 99.5%
Cable installation 87%
Not available Cable terminations 57.6%
Not available 5.6%
Small bore piping installation 58%
4%
Small bore pipe hanger installation 58.9%
15.4%
Instruments by mech. contractor 2.4%
0.0%
78.2%
Unresolved Matters 9.9%
5.
order to ascertain whether they are acceptableU on is required in or deviations.
discussed in Paragraphs 3.B.(5), 3.B.(6), 3 B (12) Unre 3.E. (1).a, 3.E. (2).b, and 3.E. (3).b.
are I
, 3.D. (1). f, 3.D. (1).h, 6.
Open Pfatters need to be followed up on in future inspection.Ope n the report, that during this inspection are discussed in paragraph 3 D (Open ite 1).e.
7.
Exit Interview
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The inspectors met with licensee representatives (d one) at the conclusion of the onsite inspection on Nenoted under para stated in the body of the report, ovember 4, 1983. As Regica III office.
With reference to the procedure reviewthe I.KC pro inspectors conducted an exit interview with the El, the on November 7, 9 18 and 21, 1983 inspectors summar,ized the scope and findinvia telephone. ectrical Q In all instances, the licensee representatives acknowledged this informatigs of the insp The on.
As part of the exit interview, as requested by th i
a presentation to the Region III representatives ine NRC, the licensee made of concern regarding the I.KC organization and effectithe following a quality p'rogram:
veness of their (1)
Discuss the backaround information leading up to discuss the delavs in completing this review.
review and records The licensee discussed the CECO audit and surveill identified a potential problem with LKC records ance program that I.KC QC Managers, and several management meetings, the repla additional details, see Paragraph 3. A of this repo t with 1.KC.
For (2) r.
Discuss the IIC QC organizational personnel chan ses.
The licensee reiterated the information provided i
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of this report as to changes in QC management and the n Paragraph 3.A additional inspectors.
salaries and other compensation for LKC QC inspectoThe employment of rs.
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(3)
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Provide an evaluation of LKC records review and discuss how this will affect the backlog of inspections on current work aettvitte's.
The licensee provided a current status of the records review and backlog of inspection activities.
The licensee also stated that the weekly tracking system indicated that inspections of current work were being completed within 30 days of the completion of the work activity. For additional details, see paragraph 3.A of this report.
(4)
Summarize CECO's efforts to assure that LKC can comolete the orofe in accordance with drawings, specifications, and renulato ry requirements.
The licensee reiterated the'information contained in Paragraphs (1),
(2) and (3) above. They also stated that Ceco had assigned 2 PTL inspectors full time to LKC, 2 PTL inspectors to assist LKC on Saturdays, and 3 PTL inspectors were undergoing training in LKC procedures in preparation for full or part-time assignment to LKC.
Also, LKC corporate has assigned 3 inspectors to Braidwood to assist in the records review program.
CICo has the following personnel assigned to follow the electrical construction activities:
5 Ceco Electrical Field Engineers 4 CICo Electrical QA Engineers
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14 CECO QAD Electrical Engineers 90 S&L Electrical Engineers on site for all areas The NRC Region III Plant Systems Section Chief thanked Ceco for their presentation and requested additional information to assist the NRC in evaluating the effectiveness of LKC and CECO organiza-tions in accomplishing electrical construction activities in accordance with NRC requirements and commitments.
To ensure that there was a mutual understanding regarding the information requested during the exit interview, Messrs. Cordell Williams and Ray Love of the Region III office telephoned Mr. M. J. Wallace, Braidwood Project Manager, on November 8,1983. During this telecon, Mr. Williams reviewed the requested information and stated the the NRC perferred that this information be formalized.
following information was requested from CECO:
In sur.:ma ry, the l
(1) Assessment of the LKC management, including:
Project Management and QA/QC How they are organized Staffing plan (2) Define the interfaces between:
CICo Field Engineering ar.d LKC (b
Ceco Project Construction and LKC CECO onsite Engineering and CECO offsite Engineering S&L onsite Engineering and S&L offsite Engineering A001sois
s avn (3)
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Define how S&L onsite Engineering participates in t.he resolution of electrical problems, including but not limtted to:
Field Questions Field Change Requests (FCR)
Nonconformance Reports (NCR), CECO and LKC originated (4)
Review of the adequacy of the LXC organization and how each group functions.
Are they effective?
(5)
Assess the capabilities of LXC craft personnel ahd their awareness of QA/QC controls imposed on work activities.
(6)
Discuss the ratio of LXC craft personnel to QA/QC personnel.
On November 10, 1983 CICo would formalize their response to the additional informat clarified during the telecon of November 8, 1983. requested by s-l L
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