ML20214E805
| ML20214E805 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 07/10/1986 |
| From: | Quaka T COMMONWEALTH EDISON CO. |
| To: | |
| References | |
| OL-A-083, OL-A-83, QA-20-84-528, NUDOCS 8705220259 | |
| Download: ML20214E805 (17) | |
Text
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DATE 8 6-81 Comm:nwealth g, EJI:;on Company CUALITY ADOURANC2, MANUAL RECEIVED
,, AUDIT RIPORT MAY 291984 oA-20-e4-52s
= 2.
L K.CollSTOCK & CO.,1140.
Type Audit:
/~l"7 Program Audit G Product Inspectyp Poi t m
o
/
/Special "gh hRecords a
g To: Mr. Frank Rolen, Project Manager
$3]
g.v Visit Dat[! ~
Report Dake5/21I_84' "N Project Braidwood System "/,
Component Identificati,onN/A 5
/
6 Material Description Electrical Vendor L. K. Comstock LocatiorBraidwood Site Subcontractor N/A Location N/A i
i Contacts See Attachment "A" P.O. No.
231360 Spec. No. L-2790A i
Reco== ended Inspections:
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3 :::
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Other: As Schaduled Contractor is required to r'espond in writing by June 12,1954.)
Notes:
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COMSTOCK4 B. Seltmann
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v Commonwealth Edison Company Quality Assurance Department Audit of L. K. Comstock i
QA-20-84-528 Introduction and Scope The Comacnwealth Edison Company site Quality Assurance Department conducted a scheduled audit of L. K. Comstock at the Braidwood site May 8-16, 1984.
Because of a special Q.A. audit of Comstock which took precedence, this audit was extended two days.
The purpose of the audit was to determine if Comstock is effective 1'y implementing its approved Quality Assurance Program.
The audit checklist consisted of nineteen (19) questions which were developed from the references listed in the following audit scope:
i Activity / Area Raference Control of Special Processes QAM 4.7 l
Inspection and Tests QAM 4.8 F* l I Control of Measuring & Test Equipment QAM 4.1 Handling. Storage, and Shipping QAM 4.10 r
i Cable Pulling L.K.C. Procedure 4.3.8 Terminations L.K. C. Procedure 4.3.9 OAD Testing Interface OAD/Comstock Interface The audit team consisted of the following personnel:
i E. T. Mazur - Lead Auditor J. A. Walters - Auditor M. J. Wendell - Auditor 4
J.
E. Smith - Observer An entrance meeting was held on May 8, 1984 in the Ceco 0.A.
site offices at 9:00 A.M.
The exit meeting was held in CECO Q.A.
site offices at 2:00 on May 16, 1984.
Attachment "A"
lists entrance and exit attendees and personnel contacted durin~g the audit.
. Deficiencies Identified i
Three (3) Findings and one (1) Observation were identified during this audit.
A brief description of each deficiency is given below:
Findina #1 l
Violations of separation between trays, and conduits and trays for safety related segregations are not being documented and reported ta S & L.
s QA-20-04-528 Page 2 Findinc #2 Instruments were not calibrated to established frequency, calibration reports were not reviewed by Q.C. for acceptability, and reviews were not performed of past work for out-of-tolerance M & TE.
Findina #3 Q.C. is not reviewing MRRs to assure material being released for use is acceptable.
Observation #1 Maximum allowable pulling tension for cables was exceeded.
General Evaluation Control of Special Processes Review of welder qualifications, witnessing of welder tests by QC, identification test specimens, inspection of test specimens by an independent test company (PTL), records on maintaining welder qualification, and control of weld symbols and weld cards were acceptable.
l Inspection & Test The audit reviewed the witnessing of in-process welding activities and noted that at this time there is no aluminum welding activities in process.
Ten (10) randomly selected safety related segregations were
. reviewed for minimum space requirements of 1" between trays and between trays & conduits.
Four (4) violations of the minimum la space were noted.
One Atem was documented as violating a previous minimum requirement of C3*, but there was no documentation for the other three (3) and consequently were not reported to 5 & L as required.
Equipment installation activities were founded to be acceptable.
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(02550)
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QA-20-04-528 Page 3 control of Test & Measurina Eauinment D
Identification and traceability of measuring & test equipment f
was verified by developing a list of various METE control numbers from the inventory control log. locating the various equipment and checking for proper identification.
An additional sample of M&TE which was issued to the field was inspected, the control numbers and calibration status were noted and checked against the inventory control log and corresponding calibration cards.
All were found satisfactory.
l During a review of daily temperature records for stationary weld rod ovens, it was noted that the daily temperature sheets for october and November of 1983 for oven #784 were missing.
The missing sheets were located during the audit.
They had apparently been misfiled.
With the correct filing of the misplaced records,
(
this area wat satisfactory.
During a review of the calibration records for thermometers, it ws noted that the thermometers were calibrated on a six month basis, however L. K. Comstock procedure 4.9.1 requires thermometers to be calibrated on a three month frequency (see Finding #2).
Calibration records reviewed for instruments & gauges calibrated by an outside agency indicated that certifications for acceptable results were not being reviewed and documented by Q.C.
Also on instruments or gauges found out of calibration no action was taken to evaluate the validity of previous inspections or tests (see Finding #2).
2 Handlina. Storace. and Shinnina Rigging was inspected in the tool rooms and found in satisfactory condition.
Storage surveillances were being performed satisfactorily and storage areas were found acceptable.
Material was adequately marked with traceable identification.
A review of material requests and corresponding Form 39A's
~
(Comstock material receiving report), indicated that the QC inspectors were not reviewing the applicable MRR to assure that Ceco accepted the material for use.
Additionally, incorrect MRR's were referenced additionally on L. K. Comstock's Form 39A (see Finding #3).
(0255Q)
s 6
Attachment "A" Page y W
Findina #2 Item #1 Contrary to 10CFR50 App. B Crit. XII " Control of Measuring and Test Equipment" and L. K. Comstock procedure 4.9.1 para. 4.0 thermometers are being calibrated on a 6 month frequency schedule instead of the specified 3 month frequency.
Item #2 Contrary to L. K. Comstock procedure 4.9.1 para. 3.2.5.
the calibration records for instruments / gauges sent to an outside agency for calibration are not reviewed by Q.C. for acceptability.
Item #3 Contrary to L. K. Comstock procedure 4.9.1 para. 3.3.7.1.
Inspection Correction reports were not generated to evaluate the validity of previous inspection or test results for all 4
instruments / gauges found out of calibration.
Discussion Item #1 i
During a review of the calibration records for L. K. Comstock thermometers TH-29. TH-32. TH-33. TH-34, and TH-35 it was identified these thermometers were being calibrated on a 6 month frequency l
that l
schedule.
This is contrary to L. K. Comstock procedure 4.9.1 which requires a 3 month calibration frequency.
This was discussed with J. Seeders who immediately initiated and subsequently completed the I
following actions:
- 1) Documented training was given on 5-9-84 covering the calibration frequency requirements as specified in L. K.
Comstock procedure 4.9.1.
t
- 2) The calibration frequency schedule for all L. K. Comstock thermometers was reviewed and corrected in accordance with L. K.
Comstock procedure 4.9.1.
- 3) A surveillance was performed on the frequency requirements on all other types of instrutaents/ gauges to insure that the proper calibration frequency was adheated to.
No other deficiencies were,no,ted.
(02550)
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The above corrective actions are considered adequate. and as a result L. K. Comstock need only respond to action to prevent recurrence.
Item #2 During the review of the calibration records for instruments / gauges sent to an outside agency for calibration, it was identified that the following calibrati
.J:ecords had not been reviewed and accepted by L. K. Coastoc Q.M :
Instrument /cauce Calibration date Al6fAAMaAO fot" l0A Dynamometer 2550 11- -
-j Dynamometer A951 ow-2', Q-2 9 -8 3) 8th'e <:.
g Micrometer 786 G-1 %
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Art Pin gauge set 785
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Item #3 84.g During the review of the calibration records for various instruments / gauges, several instances were noted where the instrument was found out of calibration.
The following were found out of calibration with no evaluation of previous inspections or test results:
Instrument Date found out of Cal.
Remarks Crimper N112-163 3-22-82 ICR #1172 was generated however it did not include an evaluation of past work.
Pin gauge set #785 10-4-82 No ICR was generated.
10-5-83 No ICR*was generated.
Plug gauge set #A968 4-9-84 No ICR was generated.
t These concerns were discussed with J. Seeders who immediately initiated the follow actions:
Crimper N112-163 - Nonconformance report #2199 was generated to address this item Pin Gauge Set #785 - ICR #4855 was generated to address this item.
j Plug gauge set #A960 - ICR #4854 was generated to address this item.
(02550)
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vosT achment "A" Page 5 q The corrective actions for above item #3 are considered acceptable. however L. K. Comstock is required to assess if other items are affected and address actions taken to prevent recurrence.
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Findinc #3 W u o f funt Contrary to 10CFR50 App. B Criterion VII " Control of Putchased Material, Equipment and Services" and L. K. Comstock procedure 4.10.3 para. 3.2. Comstock Q.C. is not verifying that the applicable MRR has been accepted by Ceco prior to the completion of form 39A and the release of the corresponding material.
Discussion During the review of a sample of various L. K. Comstock material requests and corresponding form 39A's the following was identified:
- 1) The material on L. K. Comstock request #671 had been released per the corresponding form 39A prior to CEC'o acceptance of the applicable MRR.
(MRR 11335) WPONj copy of NBA //.33.r /97TWMe
[ 2) L. K. Comstock request #667Freferences MRR's 247 and 132
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which are ILg1 for panels OVV05J and OVV06J as indicated on the y
request.
MRR's 247 and 132 are for nuts & bolts and V-Belts.
( respectively.
pg og7gg Observation #1 Contrary to L. K. Constock procedure 4.3.0, which requires maximum cable pulling tension to be calculated from the smallest bend radius in the run, pulling tension for the cables in conduit CIA 0503 was incorrectly determined.
Discussion
. During the audit a cable pull was observed in the Unit 1 aux, feedwater tunnel.
This pull consisted of a multiple cable configuration and utilized a mechanical pulling device.
Pulling size.
sheaves were used for cable guides and were of the correct The final pulling sheave, however, was incorrectly rigged so as to effectively reduce the pulling radius in half.
Based upon this now radius, a re-calculation of pulling tension indicated a value of 1000 pounds.
The actual pulling tension in the field reached a maximumof1450poundswhj)chexcoedsthemaximumallowabletensio by 450 pounds.
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Comstock Engineering, Inc.
Memorandum to T. E. Quaka Of fice:
Braidwood From; R. soltaann Ctco Audit QA-20-84-528 Date:
6-12-91 Subtect:
Control No 84-06-12-04 Attached please find L. K. Coastock's response to CICO Quality Assurance Audit QA-20-84-524 consisting of three (3) findings and one (1) observatien.
Please contact my office if there are any questions concerning this matter.
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- 1. oit nn QA Engineer Rs/ jab Attachments cc:
D. Shamblin C. Msnnecke D. Hoffer
- 3. Nelson F. Rolan I. DeWald L. Seese QC file m_
1 Findine t'2 1125 I1 Contrary to 10CFR50 App B. Criteria XII " control of Measuring and Test Equipment" and L. K. Comstock Procedure 4.9.1. Para. 4.0, thermometers are being calibrated on a 6 month frequency schedule instead of the specified 3 month frequency.
Item 92 Contrary to L. K. Comstock Procedure 4.9.1. Para. 3.2.5. the calibration records for instruments / gauges sent to an outside agency for calibration are not reviewed by Q.C. for acceptability.
Item 93 Contrary to L. K. Comstock Procedure 4.9.1. Para. 3.3.7.1. Inspection correction Reports were not generated to evaluate the validity of previous inspection or test results for all instruments / gauges found out of calibration.
piscussion 4
item 91 During a review of the calibration records for L. K. Comstock thermometers TM-29. TM-32. TM-33. TM-34, and TM-35 it was identified that these thermometers i
were being calibrated on a 4 month frequency schedule. This is contrary to L. K.
Comstock Procedure 4.9.1 which requires a 3 month calibration frequency. This was discussed with J. Saeders who imunediately initiated and subsequently completed the l
following actions:
i 1)
Documented training was given on 5-9-84 covering the calibration frequency requirements as specified in L. K. Comstock Procedure 4.9.1.
2)
The calibration frequency schedule for all L. K. Constock thermoneters was reviewed and corrected in accordance with L. K. Comstock Frocedure 4.9.1.
l 3)
A surveillance was performed on the frequency requirements on all other types of instrument / gauges to insure that the proper calibration i
freque.cy was adhered to.
No other deficiencies were noted.
Resnonse In the Audit Finding Report Caco stated that the above corrective actions were considered adequate aM that L. K. Comstock need only to respond to action to prevent recurrence.
Action to Prevent menetition L. K. Comstock Inspector J. seeders received training on 5-9-84.
The subject of the training session was " Calibration Frequency of All Area" in accordance with Braidwood Procedure 4.9.1 Revision C.
Training Porn 101 attached.
Date Action Completed 5-9-84
i ll85 !I i
During the review of the calibration records for instruments / gauges sent to en outside agency for calibration it was identified that the following calibration records had not been reviewed and accepted by L. K. Comstock 9.A.t Instrument /cauee Calibration Date Dynamometer 2550 11-1-82 Dynamometer A9S1 9-29-82, 9-29-83 Micrometer 746 9-16-82 Fin gauge set 785 10-4-82 Rassense 4
No corrective action required. Per L. K. Comstock Procedure 4.9.1, Para.
3.2.1 if a calibrated tool is required to be sent to an outside testing laboratory, certifications would be requested. Upon receipt of the recalibrated tool the guality control Inspector will review the applicable certifications for acceptable results and signify by signing and dating the certificate.
A brief esplanation of the items listed above are as follows:
Dynamometer 2550 - Calibration date 11-1-82.
The only document in this package with a date of 11-1-82 was a " General Inspection Report - Porn 104 by J. Soeders. This document does not apply to the requirement of 4.9.1 Paragraph 3.2.5.
Dynamometer A951 - Calibration date 9-29-82 and 9-29-83.
The certifi-i cation on 9-29-82 was issued by Dillion Manu-facturing and is in fact signed by a 9C Inspector (J. Seeders) as a result of an LKC Internal Audit.
No. I-045-83.
The only document reflecting a 9-29-83 date was again, A General Inspection Report - Porn 104 by J.
Seeders. This was issued to document that the tool was not used since its last calibration and there-fore, no recalibration is necessary. A new cal, due date was then established based on Para. 6.1 of Procedure 4.9.1.
Micrometer 746 Calibration date 9-16-42.
Again, the only document corresponding to this date was a General Inspection l
Report - Form 104 by J. Seeders. This document does not apply to the requirement of 4.9.1, Para. 3.2.5.
Fin Gauge set 'l45 - Calibration date 10-4-82.
This instrument was sent out to Pittsburgh Testing Laboratory (PTL) and calibration record were received 10-4-82.
The re-quirement to review outside vendor certifications became effective on 11-10-82 of Procedure 4.9.1 Revision 10-11-82. Therefore, no discrepancy exists. This information is documented in LKC Internal Audit I-045-83, Item 3 attached.
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As a result of LKC C:rporato Audit CQA-348 and LKC Internal Audit 1-045-43.
all controlled tool files were reviewed by J. Seeders. Any certifications that were not reviewed by an LKC Inspector were reviewed, signed and dated. Only certifications after 11-10-82 were brought into compliance as required by Procedure 4.9.1.
Action to preclude Repetition None required.
L. K. Coastock's program was in compliance with procedural requirements.
nate action e - iated N/A Itsa 93 During the review of the calibration records for various instruments / gauges, several instances were noted teere the instraent was found out of calibration.
The following were found out of calibration with no evaluation of previous inspections or test results:
Instrument Data raamt cut of cal.
M crimper W112-163 3-22-02 ICR 91172 toss generated, hauever, it did not include an evaluation of past work.
pin gauge set 970S 10-4-82 No ICR was generated.
10-S-83 No ICR was generated.
Plug gauge set GA968 4-9-84 No ICR was generated.
These concerns were discussed with J. Seeders who isusediately initiated the fallow actions:
Crimper N112-163
- Nonconformance Report 921gg was generated to address this item.
Fin Gauge set
- ICR 644S5 was generated to address this ites.
Flug gauge set SA944 - ICR 94054 was generated to address this ites.
assoonse corrective action was completed by J. Seeders during course of audit as stated above.
Action to prec1*
- nematitian A training class was held on 6-9-84 with J. Seeders concerning the issuance of ICR/NCR for gli tool discrepancies. Training Form 101 is attached.
nate Action e - iated 6-g-04
1 I
L K. Comstock & Casupony, lac.
AUDIT ftESOftT I3 3
of Pay n
B.F.
4.9.1
CoasCEmer Famammana l
5 AUDIT pOIIsf l
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- 3) Verify that the QC Inspector Findles llo. 1 Verified calibratioe records la le reviseing the certification QC vault for compliance to SF j
2 :s j
ES of compliance for acceptable Calibrettom reports / certificates 4.9.1. Para. 3.2.5.
This pert-E reemite by the presence for the following teele did met scular regetrement mee Recorrereted l
of their signature /dete on contain the registred QC angesture late Precedere 4.9.1 in Revisten j
the document.
and date sigolfying the records 18/11/82 ultick had an effective l
2 were reviewed for acceptability.
date of 11/16/02. Cert if icet tees n
werified la this review were sely l
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(Bef. B.F. 4.9.1. Para. 3.2.5)
Calibration feend discrepeat if me review Tool Report note algaeture mes evident en records j
received af ter 11/10/02.
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Records reviamed:
1RC 2549 Bitlen 2,_-- =::er 11/24/82
- 1) 9111em 2,-
- ::er. IKC 2549 Serial me. Ass-26430 O
13C 2550
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l certificate of celibration deced m -.
EE W1111ame Torque Teeter, IRC 2221 3/17/83 11/24/82 une met reviewed for ecceptance results. No QC l
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Cooper Dial olyneture/date.
Thermometer. IRC T-2 1/5/03 4/6/03
- 2) Dillem 2,
_ - ::er.12C 2550
, 7/8/83 serial me. Ass-41292 i
Certificate of calibration dated
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E IIOTE: Similar discrepeecies 11/24/82 use not reviewed for 2
were reported in IKC acceptance resulte. No 4C Corporate Asadit No. II)A-368. eignature/date.
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027 Comstock Engineering, Inc.
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Memorandum Braidwood To:
R. Seltmann Offies:
I.F. DeWald p,,,
12/2/83 Internal Audit I-045-83 o.i :
swbiect.
Control No:
83-12-06-01 The following is a response to the subject audit report con-sisting of three (3) findings.
Responses:
Finding No. 1 A review was performed by John Seeders of 11 calibration reports /
certificates that were received af ter 11/1 2.
Any discrepant reports have been updated during this review and files have been completed to correct standards.
Since Mr. seeders is solely responsible for these files and the f act that he himself performed the audit, no additional training is necessary.
See attached memo from J. Seeders dated 11/18/83.
All files current is respect to 3.P. 4.9.1, Para. 3.2.5.
I Finding No. 2 Auditors recommendation complied with Braidwood Procedure 4.9.1, Revision C deleted para. 6.2.1 and para. 6.2 was revised for l
I clarification.
This procedure was granted " Interim Approval" on 11/18/83.
See copy of page 6 of 7 of 4.9.1 attached.
No further corrective action necessary.
c Finding No. 3_
Auditors recossaandation complied with Braidwood Procedure 4.9.1, Form 23 was revised in Revision "C" of this procedure.
The old Form '23 was renumbered at Form 23A due to duplication of this form in 3.P. 4.9.4.
The new Form 23A added appropriate QC Inspector and Level II review blocks at bottes.
B.P. 4.9.1, hevision C was granted " Interim Approval" on 11/16/63 and has been distributed to manual holder as of 12/2/83.
No further corrective action necessary.
Form 23A attached.
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PERSONNEL INSTRUCTION LOG I
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