ML20214E531
| ML20214E531 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 05/07/1986 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 8251N, OL-I-ROREM-007, OL-I-ROREM-7, NUDOCS 8705220131 | |
| Download: ML20214E531 (17) | |
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Ma.ch 23, 1984 4
Mr. James G. Kappler Regional Administrator U.S. Nuclear Regulatory Commi.sfon Region III
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799 Roosevelt Road W,Elfyn, IL 40137
Subject:
Oraidwood Station Units 1 and 2 f
Response ta IE Inapection Report :
Ne S0-436/83-18 and S0-457/83-171 NRC Oceket Nos. 50-454/457 References (a):
i R. L. Spessard letter to Cordell Reed 1
i dated February 14, 1984
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(b):
R. L. Spessard letter to Cordell Reed i
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dated January 27, 1984 l
l (c):
L. O. Calcecrge letter to A. B. Oavis dated January 12, 1984 3
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(d):
M. J. Wallace letter to R. L. Spessard i
l dated Novemeer 17, 1983 l
Cear Mr. Kappler:
3 Company with the results of an inspection conducted by Mr.
Love and other members of your office during the periods of Octocar i
31 through. November 4, 1983, November 7 through 21, 1983, and l
i January 12 and 13 1984 During that inspec, tion,,certain activities appeared to be inof activities a j
non-compliance with NRC requirements.
Enclosure No letter provides the Commonwealth Edison Company resp. 1 to this Notice of Violation as appended to Reference (b).
onse to the Our response addresses each example cited under the items of non. compliance, and further addresses each additional example identified witnin
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Reference (b) that relate to the requisite item of non compliance i
Our delay in submittal of this thirty day resconse until i
Maren 23, 1984 was discussed on separate occasions with Messrs
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C. williams and W.
C.
having been given additional time to respond in this matter.S. Little o ji t
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. The four items of non-compliance and various examples I
contained in Reference (b) were discussed during tne Enforcemen' Conference held in your offices on Occem0er 20, 1983.
Reference (c) briefly addressed each of these conLJrns as we unoerstocc them at that time.
Our response to the items of non-compliance centainec in Enclosure No. I to this letter are based on our further review of each item.
It should be noted that in the majority of our reviews, we found that the Region's concern did not have a negative imcact hardware in the field.
on Also, the resultant procecural changes are expected to be accomplisned by Haren 30, 1984 in the majority of nc CascS.
As requested in Reference (b), and in accordance with our commitments provided in Reference (d), Enclosure No. 2 to this letter provides additional information to assist the Region in evaluating the effectiveness of the Commonwealth Edison and L. K.'
Comstock organizations in accomplishing electrical construction i
activities at Braidwood Station.
The updated senedule for completion of recuired L. K. Comstock activities is documented on L.
K. Comstock " review Region's review.
of status" sheets available on-site for the Finally, Reference (b) recuested a written response to the j
(*
unresolved item Nos. 50-456/83-18-091 50-457/83-17-06 torquing requirements for mounting electrical equipment.concerning l
Our interim response is contained in Enclosure No. 3 to this letter.
1 To the best of my knowledge and belief, the statements contained in the Enclosures are true and correct.
In some respects these statements are not based on my personal knowledge but upon information furnished by otner Commonwealth Edison employees.
Such information has been reviewed in accordance with Company practice and I believe it to be telisole.
Que to the complexity of these issues, se are available to meet with members of your staf f at their earliest convenience to review tna enclosed information.
Please address any cuestions tnat you or your staf f may have concerning this matter to tnis of fice.
Very truly yours, Louis 0. Delceorge Assistant vice Presi ent E35/ rap
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En:Losures - 3 cet R: 11 Inspector - Braid cod A9916019
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, VIOLATION 3 10 CFR 50, Accendix 0, Criterion X, Edison Company Topical Report CE-1-A,as imoleme9tec cy Ccemonnealth Section 10, requires a program for inscection of activities affec conformance with instructions, procecures, ting quality to verify anc craatngs.
Contrary to the above, the following examoles nere identified:
Commonwealth Edison company fallec to verify that a.
approximately 30 - 40 caule grics in caole tray risers 1R267-ClE, 1R270-KlE, and 1R311-ClE were installec in Procedure 4.3.8.accorcance with 5 & L Stancard STD-EB-200 b.
Commonwealth Edison Company f ailee to icentify camagec lowet braces and missing cross bars insice HCC 1AP26C in accordance with L. K. Comstock Procecure 4.8.13.
c.
Commonwealth Edison Company failed to verify that Class lE cable 1Cv036 was terminated per cesign documents.
Tne caoli conductors were erroneously marked as soare concuctors.
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Records indicate that the termination of this cacle nac Seer inspected and accepted by L. K. Comstock Quality Control.
d.
Commonwealth Edison Company failed to verify that T Dolts, screes, metal bracing, etc., nac eeen remove:y-Ra:s, ft:9 the interior of NCC 1AP26E in accordance witn L. K.
COnstccb Procedure 4.8.13, Paragrapn 3.1.7.
Commonwealtn Edison Company failed to verify tnat e.
insoections had been performed in accorcance witn L. K.
t Comstock Procedures j
evidenced by:
4.8.3, 4.8.6, 4.8.13, and 4.8.17 as 1
(1) j 30 of 68 items reviewed had no records to indicate that Quality Control nac performed an installati:n inscection.
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(2) 27 of 50 items reviewed had no records to inci:ste i
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that PTL nac performed an insoection of the concrete expansion ancnors.
i (3) 125V QC canel 10C05C had no recores to incicate tnat j
PTL hac perfornec an inspection of tne concrete expansion anchors.
i (4) 19 of 19 electrical penetration inspecti:n re::r::
die not provice actual torgue values for tne m untis; colts and cic not indicate tne torque arenen num:er (nor calieration cue cate) utilizac to perfarn tne torquing operation.
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i Accitional cetails are celineated in attachec Insoection
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Report 50-456/83-18; 50-457/83-17, Paragrapns 3.0.(1),1 anc t
3.0.(2).
This is a Severity Level IV violation (Supplement II.0).
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RESPONSC 5
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i The following provices the Commonwealth Ccison company ressanse to
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I each example citec uncer non-compliance Item 3.
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3.e Commonwealth Edison Company failed to verify tnat insoections nac been performed in accordance with L.
K. Comstock Procecures 4.6,3, 4.8.6, 4.8.13 and 4.8.17 as evidenced by:
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Issue (1) 30 of 68 items reviewed nad no records to incicate that Quality Control had performee an installation inspection.
Issue (2) 27 of 5O items reviewed had no records to inc!cate that Quality Control had performed a nelding inspection.
Issue (3) 125V DC panel 10COSE had no records to inoicate snat PTL had performed an inspection of the concrete expansion ancnors.
Issue (4) 19 of 19 electrical penetration inscection records did not provide actual torque values for the mounting bolts and did not indicate the torcue wrench nummer (nor calibration due date) utilized to perform the torquing operation.
Additional details are delineated in attached Inspection Reoort
(
50-456/83-18; 50-457/83-17, Paragraphs 3.0.(1).1 and 3.0.(2).
RESA0NSE 70 ISSU($ (1) ANO (2)
Commonwealth Edison Company is aware of the recuirements to assure that timely inspections are performed in accorcance with L. 4.
Comstock procedures and tnat results are retrievaole.
fne issues set forth above were identified wnile commonwealtn Edison anc L.
Comstock were involved in a major ef fort to reorganize recceds for 4
more efficient retrievability, and identification of those areas it which records were deficient.
Commonwealth Edison admits that during the NRC inspection the records cited 40cvs were not accessible.
of our record reorganization ef fort,However, subsecuent to the NRC insco the records identified in tne examole es missing, were either located or information suf ficient to reconctie and reconstitute them was catained.
In some cases, the inspection record was incomplete and inspections were perfor9e:
C0AAECftvt ACit0N fawtN AN0 ACff0N fawtN f0 04tvtNT 4(OCCUA8tN0t TIk As early as Maren, 1982. Commonweattn (dison Company Quality Assurance audits and the Tecnnical Suecort tvalustien of Soote9mer, 1982, identified deficiencken angesasing tne noso to Imorove tne L.
- 4. Comstoew documentation / filing system.
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l As a result of identified deficiencies Commonwealth Edison Comoany
, ceterminec that improvements were neecec in the areas of:
1.
Timeliness of recorcs. strievacility.
2.
Setter accountability of the producticn recorcs wnicn support the status of installation.
3..
Reconciliation of use of previously used outcatec forms.
In Octocar 1982, it was determined that progress was coor in tne document review.
In Novemoer 1982, the L. K. Comstock Quality Control Manager was replaced because he lacked administrative abilities.
However, poor progress in the document review continued.
In March 1983, the Commonwealth Edison Company Project Construction Department held a meeting with L. K. Comstock's Regional Vice President and in April 1983, with L. K. Comstoew's Executive Vice President Corporate Quality Assurance Manager anc Regional Vice President to discuss the poor progress being mace.on the document review.
As a result, L. K. Comstock committed to provide four (a) inspectors to complete the document review and provide a plan for completion.
C The plan to complete the review was submitted to Commonwealtn Edison Company for concurrence on March 9,1983.
The plan's sccce and depth was to reconcile audit deficiencies of document retrievabilit correctness. y, as well as assuring record completeness and In June 1983, the Commonwealth Edison Company Project Constructicn Department and Quality Assurance met with L. W. Comstock to ciscusi the status of the document review.
It was determined that L. K.
Comstock was not proceeding as seneduled to meet the Septemoer 198 completion date.
Edison Company again replaced the L. K.As a result of the June meeting, Com Comstock Quality Control Manager, with intent to more adequately organise and complete tne doc,ument review as projected for rectuary 1, 198a.
The corrective measures which provide imorevements to the L. 4 Comstock document s williams and Love) ystem were presented to tne NRC (Messrs. Little, on Novemoer 3, 1983 and the program was mentioned on Decemoer 20, 1983 during the Inforcement Conference.
Subsequently, on January 3L, Lp4A Consenseelth (dison Comoany Project Construction reported to the NMC a potential 30.55(e).
L. 4. Comstock is 1004 complete with their review of all documents on file.
The updated status reports concerning the completion of the recuired L. K. Comstock activities are avaitsels on site for the Region's review.
A00150 5
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i I In additien to the actions described acove, the Commonwealtn E iso Company Project Construction Department has autnerized tne use of 4
computerized tracking system.
This system will ce used to cocumen the status of installation and inspections.
To prevent incomoiete i
i or unacceptable documents from being filed, L. K. Comstock nas provided for a 3-level review.
Lead Inspectors are'responsicle fo reviewing all documents initiated in their areas of responsibility.
The Supervisor of Inspectors provides a secenc d
level management review.
It is his responsibility to determine i
whether additional dire.ction or clarifiestlon is needed to ce ;ivet to inspectors who continue to improperly fill out reocrts.
Finally, all documents are reviewed by Occument Control oefore One:
j are filed.
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Dart or Counterros e
date I completion for their document ev ew 3 May l 193a j
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ENCLOSURE 2 ADDITIONAL INFORMATION TO ASSIST THE REGION IN EVALUATING THE EFFECTIVENESS OF COMMONWEALTH EDISCN j
AND L. K. COMSTOCK ORGANIZATIONS IN ACCOMPLISHING CLECTRICAL CONSTRUCTION ACTIVITIES AT BRAIDWOOO STATION i
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i CORDELL WILLIAMS REQUEST FOR ADDITIONAL INFORuaT:CN A.
L.
K.
i Comstock Manacement Orcanization L. K. Comstock's site mana I
independent organizations:gement organization consists of tnree (3 Assurance.
Production, Quality Control anc Qualit
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Independence of these organizations is snown in ene l
attached organizational charts (Attachments 1 and 2).
y The Project Manager directs production activities anc reports to 3
the Central Region Vice President.
directed by the Quality Control Manager. Quality-Control activities are i
Both the Quality Control Manager and Quality Assurance Engineer reports to the Central Region Quality control Services Manager.
As reouired by i
Commonwealth Edison Company, and demonstrated in the L. K.
Comstoc Quality Assurance Manual, both quality organizations are free to implement the L. K. Comstock Quality Assurance Manual enrougn inspections inspection p,rocedures. surveys and audits of the site installation and 1
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Production Orcanization I
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Reporting to the Project Mana j
and seven (7) Area Managers. ger are the Pro ject Encineer 4
Thirty-three (33) people consisting of Engineers and a.
Document Control personnel report to the Project Engineer.
Their primary responsibilities are as follows:
i 1)
Aid in the solution to field proclems; i
2)
Recommend corrective action to contractor NCRt i
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3)
Control all records pertaining to camle
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pulling and terminating; 4)
Calculate maximum allowacle caule pull tensier 5)
Control the issuance of drawings to the field; i
6)
Review drawings and procedures to assure that specification requirements are adequately addressed.
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9,
b.
Area Managers' primary responsiollities are as follows:
j 1)
Supervise craft personnel; 2)
Assure that procedural and schecular commitments are met; 3)
Assure that work is completec per drawing 4
i specification and/or work instructions; Currently, craft manpower averages 496 personnel with projections of increasing to 520 by mid-year.
Altneugh the number of current Engineering, Craft Supervisory anc Craft Personnel is adequate, the Commonwealth Edison Company 3
Project Construction Department will continue to monitor tni need for additional personnel to assure that procedural anc:
schedular commitments are met.
For all primary craft production activities, training 4
sessions are presented to all craft personnel at the beginning of their employment.
Welders require the most extensive training and qualification.
Cable ~ pullers anc terminators require indoctrination / training to the a
requirements established in applicaDie procacures.
As part of their training sessions, basic Quality Assurance / Quality Control ideas sucn as, necessity of reporting non-conforming i
conditions, responsibility with respect to hold tags, anc i
the requirement of not deviating from drawings or procecures unless authorired by appropriate documents are presentec.
Besides the initial training sessions, follow-up/accitional sessions are presented, as needed, to highlight specific concerns or clarifications.
All training sessions are documented and filed in the L. K. Comstock Project Engineering office.
t The Commonwealth Edison Company Project Construction Department is reasonably assured through Quality Assurance
-audits, that craf t personnel are aware of Quality i
Assurance / Quality Control controls and will continue to 1
monitor tne need for additional training.
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2.
Quality Control and Quality Assurance Orcaniration Quality Control activities are directed /supervisec :
a.
the Manager and Assistant Quality Control Manager.
Two (2) new supervisory positions, "Suoervisor o f
' Inspectors" and " Lead Inspector" were estaclisne:
to better manage inspection activities.
Personnel selected for these positions wer~e generally senior inspectors with the Project who are thoroughly familiar with specification, drawing and procecural requirements.
Commonwealth Edison Company Project Construction is confident these new positions anc personnel selected to fill these positions will provide additional uniformity of inspection between all Comstock inspectors.
i Currently the L. K. Comstock, Quality Control organization consists of sixty-nine (69) people., Tnt field inspection force has more than coubled from twenty-two (22) to fifty-one (51) and the overall
(/
department increased from twenty-five- (25) to sixty-nine (69) as shown on the attached organizational chart.(Attachment 3).
This increase represents, one (1) inspector for every 7.1 cra f t personnel.
Commonwealth Edison Company Project Construction is confident that the number of Quality Inspectors is adequate to assure that timely inspections are performed and that the number of backlogged inspections is reduced.
To maintain this confidence, Project Construction plans to monitor the progress and closecut of L. K. Comstock open items (NCR, ICR, etc.) and corrective actions.
Further, the L. K.
Comstock Quality Control inspector workforce will te 1
monitored to assure that it is adequately staffed to address any additional work resulting from the document review, while staying current with all othe:
work.
b.
Commonwealth Edison Company Project Construction is ultimately responsible for assuring that contractor quality programs are carried out.-
Besides Commonwealth Edison Company scheduled audits and surveillances, L. K. Comstock Quality Assurance k,
organization is responsible, as a minimum, to audit their entire Quality Assurance program on a yearly basis.
In addition, L.
K. Comstock site Quality Assurance Engineers are respon'ible to perform aucits s
and surveillances to a plan concurred in by A002gregg
Commonwealth Edison Company Quality Assurance.
The plan requires accits and/or surveillances of all si:
procedures.
Currently, two (2) L. X. Comstock i
certified quality auditors are assignec to the Braidwood Project.
Based on the total Quality Assurance program of L. K. Comstock, P'roj ec t Construction is confident that work is accomolisne:
in accordance with the requirements of drawings, specifications and procedures.
B.
Braidwood Project Interface Responsibility for overall design 'and design implementation of electrical systems is assigned to the Commonwealth Edison Company Project Engineering Department, Site or Chicago Of fice.
Responsibility for certain phases of design has been delegated to Sargent and Lundy.
The Commonwealth Edison-Company Project-Construction Department is responsible for constructing and has no design responsibilities.
Certain construction responsibilities
(/
have been assigned to L. K. Comstock Engineering Department.
The Braidwood Project executes these responsibilities in accorcance with the requirements and procedures described in the Commonweal n Edison Company Quality Assurance Program.
Because of desirable experiences gained at other Comoany projects, Commonwealth Edison Company believes the develcoment of on-site Engineering (CECO and Sargent and Lundy), and the use of L. x.
Comstock Engineering personnel are ef ficient and positive stecs to assure that Project Construction activities are performed in a quality and timely manner.
1.
Sit'e Project Engineerino Interface Per the requirements of the Commonwealth Edison Comoany Quality Assurance Manual, Manager is responsible for:the Project Field Engineering Engineering design implementation; a.
b.
Reviewing systems for modifications and deficiencies; Resolving construction problems; c.
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d.
Coordinate and oversee the.Sargent and Lundy field group.
A0015629
. These responsibilities are similar to those of personnel at the Chicago Office.
As needed, site personnel may ootain input from other departments and organizations to rescive daily problems.
Sargent and Lundy Electrical Field Engineering personnel currently total 80 and have the same responsibilities as their counterparts at the Sargent and Lundy Corporate Office.
As a minimum, _ these include the following items :
a.
Determine routing of unrouted cables; b.
Prepare and review electrical installation drawings; Process wiring drawing changes and resolve wiring c.
drawing discrepancies identified by Commonwealth Edison Company; d.
Process Field Change Requests and Engineering Change Notices;
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Process Commonwealth Edison Company and contractor e.
NCR's.
Control of all these responsibilities is described in specific Sargent and Lundy site procedures and Commonwealth Edison Company quality procedures.
involvement in resolving field matters andThe procedures govern Sargent and formal documentation o f the resolution.
While they cover a variety of possiole interchanges between Sargent and Lundy engineers and site contractors, as well as Sargent and Lundy and Commonwealth Edison personnel, the primary contact is in the latter area.
To the extent that certain computer systems and information is located off-site at Sargent and Lundy Corporate offices, the on-site Sargent and Lundy engineering personnel may refer questinns for resolution to their of f-site of fice.
If in fact a question is so
- referred, and documentation are empicyed. procedures parallel to those used on-site f 2.
Project Construction Interface L. K. Comstock Engineering activities are directed by the Commonwealth Edison Company Project Construction Department.
Similar to Project Engineering, Project
(
Construction responsibilities are described
)
throughou.
applicable sections of the Company Quality Assurance Manual.
A0015o3x3 l
. In addition to the responsibilities previously listed the L. K.
Edison Company ProjeJ*Comstock Engineering personnel, Comm for are responsicle for the following: Construction personnel, as a min a.
Coordinate construction activities (schedules, manpower, etc.);
b.
Review and implement contractor procedures; c.
Monitor Contractor Quality Control procedures; d.
Evaluate and implement methods to increase contract:
efficiency, e.
Evaluate and oversee the installation of eculament t assure that design specifications are met and minimize conditions that would result in NCR's; f.
- Review, closecut to field problems;suggest solutions and follow-up,
.t g.
Provide interface with the NRC.
described in the Company Quality Assurance Manu Construction Department procedures, and numerous c,ontractcr Proj ec t procedures.
In summary, we beleive that the above de.;cribed upgraded L. K.
organization and Commonwealth Edison Company controls through our Comstock interface described above will be effective in resolving the Regi concerns with L. K.
Comstock Company and their ability to perform quality on's work.
Similarly, Commonwealth Edison Company is satisfied with electrical problems in the field. adequacy of the on-site Sargent and the scooe and 8251N L
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