ML20214F268
| ML20214F268 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 05/08/1986 |
| From: | Seltmann R COMSTOCK ENGINEERING, INC. |
| To: | |
| References | |
| OL-I-ROREM-024, OL-I-ROREM-24, NUDOCS 8705260010 | |
| Download: ML20214F268 (11) | |
Text
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L. K. COMSTOCK & COMPAM. INC.
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NONCONFORMANCE RER0RT 3.$,CO
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NONCONFORMANCE REPORT NO. b M ef REV.
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INSPECTION CRITERIA:
DWG.
N/A REY.
N/A SPEC. L-2?o PROCEDURE:
h.1.2 Rgy;6/1 /81,A,3 OTHER N/A ITEM (5) OESCRIPTION Quality Centrol Supervisor Certificatien LOCATION N/A DESCRIPTION OF NONCONFORMANCE:
See attached sheets for description of q gs-Nonconfor=ance.
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a ORIGINATOR AM -
DATE 4 /'/-M
( ] Engineering HOLO TAG N0'S N/A
%QC OCEMED REPORTABLE PER *10CFR21 (8.P. 3.1.3)
YES ( )
NO ()(I QC MANAGER / DESIGNEE REVIEW DATE N d T~
SYSTEM (5) 2Y (if applicable)
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CAUSE C00E 1) oi 2)
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NONCONFORMANCE CODE 67 OISPOSITION: ( l USE-AS-IS [ ] REWORX [ ] REPAIR ( ] SCRAP (>4 OTHER 1
EXPLAIN.10STIFICATION:
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j ACTION TO PRECLUDE REPETITION:
i ME #M O # IO' 8705260010 860500 PDR ADOCK 05000456
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PDR DISPOSITIONED BY/TITL ?
wo / C4/~//W/86#2 DATE / f '6 j
(continued on back) 1 pagpAAgO ApenOVEQ SEvls&Q TerLE OntG.OATE R EVISION
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50.55E [ ] YES N NO (COMMENTS)
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DATE CECO FIEtDf(NG. DATE CORRECTIVE ACTION COMPLETED / ACTION TAKEN TO PRECLUDC REPETITICN:
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J 6 DATE RESPONSISLE LXC ENGINEER Q.C. VERIFICATION OF CORRECTIVE ACTION g g(,i,
[ ] REJECT QC INITIAL /DATE
,,g REASON FOR REJECTION:
h Q$ ACCEPT REMARKS / ACTION TAXEN:
/M 86 QC INSPEC OATE NONCONFORMANCE CLOSED REVIEWED QC NGR/ DESIGNEE
-h OATE /-2 /-?/.o COPIES:
LXC ENGINEERING DEPT.
Q.C. RECOR05 FILE REASON FOR YOIO (IF APPLICA8LC)
CECO QUALITY ASSURANCE l
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L. K. COMSTOCK & COMPANY. INC.
BRAIDWOOD 4.11.1 y sgey l
NONCONFORNANCE REPORT CONTINUATION SHEET NCR NO.
.b M f REY. O Sht.
2 of DbS NOTE: STATE SECTION CONTINUED AND INITIAL AND DATE ALL ENTRIES Descrittien of Nonconfor=ance:
1.
Precedure violation of Procedure k.l.2 " Position Deliniation" Rev.
6/15/81 raragrath 1.25.
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l (A) M. Kast was designated QC Sutervisor from 10/19/81 to 7/01/82 for all areas of insteetion. Free 7/01/82 to 6/2k/83 he vas reassigned the areas of Visual Weld, Configuration an:1 Receipt Insrection.
The crocedure violation occurred during the period 10/19/81 4
to 7/01/82 as he was not certified in the areas of Cable Pulling, Terminations, and Penetrations. Although he became certified 1
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2 in the areas of Cable Pull 12/01/82, Termination 12/01/82, j
and Penetration 12/01/82. Therefore, becoming fully qualified in all areas.
i (B) R. M. Saklak vas QC Sutervisor for the period of 7/01/82 to 3/29/85. During the EeNod of 7/ObEd.'tb$d3he suNrvised 1
j the areas of Cable Pull, Conduit, Cable Tray, Equipment, Terminations and CIA's.
He was certified in the areas of Cable Dull ll/2L/82. Terminatiens 12/01/82. Conduit 11/23/S2.
CEA ll/2k/83. For the period of 8/83 to 9/8h he was assiened l
i
'i, all insteetien areas. For the teriod of 9/8k to 3/85 he was l
assigned the insteetion areas of Ecuipment, Cable Pull, Ter=,
t CIA, Receipt, Calibration, and Conduit. For the period of (Cont. on Ps. 3) t C0312751 pot ra m t o apenovgo atvisto farLg omic.oAft REylsioN FemM g i
'T JOS IFD PROCEDURE 06/18/84 14A 4A b4 j
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L. K.COMSTOCK & COMPANY. INC.
BRAI E OD 4.11.1 CA SEcr i
NONCONFORMANCE REPORT CONTINUATION SNEET NCR NO. b 4 8 REY.O Sht.
3 of b41,J!=
i NOTE: STATE SECTION CONTINUED AND INITIAL AND DATE ALL ENTRIES Descrittien of Nonconfor=ance:
1/Aq t3 1/2o/89 he was assiened the areas of E9eeitt, Calibration, CEA and Eculpcent. The procedure violation occurred throughout the entire period R. Saklak held the tosition of QC Sutervisor as he vas not certified in all areas he surervised.
(C) J. Hall vas desienated acting CC Surentser free 6/2h/83 to 8/83 for the areas of Cable Pulling, Tercination, Cable Pan, Conduit, and Equittent. He was certified in Cable Pull en o/21/81 and Terminattens on 12/22/81. The trocedure violation to h l.2, Rev. A occurred during the period of 6/2k/83 to 8/83 as he was not certified in Cable Pan, Conduit, and l
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i (D) L. Phillies vas destenated acting"StipervdVt'st!!c 6/2h/83 te 8/83 for the areas of Ree 6a1 r *ica, CEA, and Welder cualification. He was certified in Receipt en 8/15/79 and Confieuration en 10/71/81. The trocedure violatten to L.l.2 Fev. A occurred during this teriod as he vas not certified in Calibration, CEA, and Visual Weld.
2' (El Bruce Brown was designated acting QC Superviser frec 1/Sk to i'
2/06/8h for the areas of Confiauration, Visual Weld, Receipt, Calibratien, and CIA's.
He vas certified in Confizuratien
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JOS ITD PROCEDURE 06/18/84 14A 4A)4 1
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L. X. COMSTOCK & COMPANY. INC.
BRAIDWOOD 4.11.1 CA SEcr l
NONCONFORMANCE REPORT CONTINUATION SHEET l
l NCR NO. b Af REY. O Sht.
k of Edk NOTE: STATE SECTION CONTINUED AND INITIAL ANO DATE ALL ENTRIES Descrintion of Nenconfer=ance:
ll/2L/82, Visual Weld 11/2L/82, Conduit ll/2L/82, Cable Pan N
il/2h/02. Cable Pull ll/2k/82, Penetrations 11/2L/82, and Ecuirnent ll/2h/82. The violatten to Procedure h.1.2 Pav. A occurred durine this teriod as he vas not certified in Calibrstion, CEA's, and Receipt.
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- 2. Procedure violation of Procedure k.1.2 Rev. B " Position Deliniation," paragraph 1.21 QC Supervisor. The following tresent Quality Control Surervisors vere desienated to the l
eesition of QC Surervisor and vere not certified in all areas surarrised.
l 1
( Al P. Tuita vss desicated CC Suterviser en 3/85 for the aress cf ('able Pulline Ter=inations and Conduit Insteetien, and was certified in the aress of Cable Pull 6/05/85 Visual Weld
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5/28/85, al* hough he was not certified in the ara,p qt"'.e t
i.q,., a Ter=instien and Conduit.
va f d (3) J. Mit was destensted QC Sutervisoy h/29/85 for the aress y
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. on ef Ecuipment, Receipt, Calibratien, CEA, and Cable Tray f
N srectien. and was cartiftad in sll srass axeart fer Ecuirnent (Equircent is made un of Penetrations and Junction Boxes; Penetrations are essentially installed so certificat10n (Cent. on F ;. 5) i 00312'/53 enceaaco 4..aavco aavino tirts c aic. ca re navision acau 9 F
JOS ITD PROCEDURE 06/18/84 14A 44A b4 que suD sepe n.6 @e e D eSM =
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BRAIDWOOD 4.11.1 CA SEc?
NONCONFORNANCE REPORT CONTINUATION SHEET NCRNO.Yb$[
REY. o Sht.
5 of ' /
4 NOTE: STATE SECTION CONTINUE 0 ANO INITIAL ANO DATE ALL ENTRIES Description of Nonconformance:
in Penetrations is no longer tractical), and Cable Tray.
9 (C) J. Walters was designated QC Supervisor. on 6/01/85 for the second shift. The inspection areas involved are Ter=inattens, Cable Pulling. Visual Weld Insueetten. Configurations, Conduit and Cable Tray, of which he was not certified in Ter inations.
Conduit or Cable Palline.
(D) A. Simile was designated QC Supervisor from 9/8h to 3/27/85 at which time he was designated General QC Superviser to present.
The areas of resconsibility for the period of 9/8h to 3/27/85 van Visual Weldine and Configurations. He was not certified
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in either Visual Weld or Configurations, although he was in trM a'aa for Visumi Weld and was certified en 7/12/85 as a Level III. The crecedure violation occurred during the i
veriod 9/8h to 6/12/85 when Revision C of Precedure k.1.2 was implemented. which changed the certification requirements.
(E) K. Worthington was designated Asst. QC Manager free 6/8k to 3/11/85 and was cualifiable to a Level III. although he had not retained certification until 2/1h/85 for the folleving:
I';
Visual Weld and Configurations. Frem 3/11/85 to 5/03/85 he l'
was redesignated to QC Supervisor at which time the areas
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sure-vised vere Cable Pan Visual Weld, Configurations, (Coy gag.fp),'i,2 ~
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'T PROC 80URS 06/18/84 14A JOS ITD tAA b4 4
L. X.COMSTOCK & COMPANY,INC.
BRAIDWOOD 4.11.1 CA SECT h
t NONCONFORMANCE REPORT CONTINUATION SHEET NCRNO.hd88 REY. O Sht.
6 of @# dtJ6 NOTE: STATE SECTION CONTINUED AN0 INITIAL ANO DATE ALL ENTRIES Descrittien of Noneenfor=ance:
Special Projects. The procedure violation occurred during the period of 6/84 thru 2/1h/85 as he was not certified in Cable T-sv. Visual Weld, and Configurations. The violation co'ntinued after 2/lk/85 until 5/03/85 as he was not certified in Cable Tray Inspection. D/rs-I i
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JOS ITD PROCEDunt 06/18/84 14A f dA W a
L. K. CCMSTOCK & COMPANY. INC.
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NONCONFORMANCE REPORT CONTINUATION SHEET
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i NCR NO.
h528 REY.
O Sht.
7 of 10 l
NOTE: STATE SECTION CONTINUCD AND INITIAL ANO DATE ALL ENTRIES i
11 EXPLAIN JUSTIFICATION:
In accordance with LKC Procedure 4.1.2 h
(Position Delineation), the position of Quality control Supervisor s
was incorporated into revision 06/15/81 with an implementation date of 08/28/81.
The LKC Quality Assurance program is based on two (2) ANSI standards that reflect QA requirements associated to this nonconformance, these being: ANSI N45.2 - Quality Assurance Program Requirement for Nuclear Facilities,1977 edition and ANSI N45.2.6 - Qualifications of Inspection, Examination, and Testing Personnel for Nuclear Power Plants,1178 edition.
ANSI N45.2 Item 3 " Organization" states "The organization structure, functional responsibilities, levels of authority, and lines of internal and external consnunication for management, direction, and execution of the Quality Assurance Program shall be documented.'
This standard does not detail the responsibilities in order to comply with ANSI N45.2.
L. K. Comstock has developed the various positions, responsibilities, etc. and has incorporated these requirements into Procedure 4.1.2.
The position and responsibilities of the QC Supervisor were developed by L. K.
Comstock and is not a position or requirement related to ANSI N45.2,
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l therefore, the nonconformance is a procedural violation and not I
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PMOCEDURE JOS ITD 06/19/84 ll A 14444
L. K. COMSTOCK & COMPANY. INC.
BRAIWCCD i.11.1 o n :-
NONCONFORMANCE REPORT CONTINUATION SHEET f
NCR NO.
h528 REY.
O Sht.
6 of
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NOTE: STATE SECTION CONTINUED AND INITIAL AND DATE ALL ENTRIES i
progransnatic in nature.
I L. K. Comstock created the QC Supervisor position in order to develop a middle management position between the Assistant QC j
Manager and the QC Inspectors. At that time in the LKC QA Program, 1
the QC Supervisor was responsible for first line direction of the h
inspection staff. ANSI N45.2.6 (1978) Table 1, Minimum levels of F
b Capability for Project Functions, requires that a person b
' supervising equivalent or lower level personnel" must have a i
minimum Level II caoability. All of the individuals listed on this i
NCR were certified inspectors to a Level II capability prior to their appointment as QC Supervisor with the exception of R. Saklak and A. Simile.
R. Saklak was appointed QC Supervisor on 07/01/82 and did not receive his initial certification as Level II Inspector until 11/24/82 at which time his initial capability did not meet the i
requirements of Procedure 4.1.3 Revision C
' Qualification /
Classification and Training of QA/QC Personnel". This discrepancy was subsequently documented on NCR 3681 as a result of Comstock's inspector certification upgrade program in accordance with CECO Procedure PM-12.
A. Simile was appointed to QC Supervisor 09/84 and did not receive his initial certification as an Inspector Level III 6 " l 1.bl 'b w
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JOS ITD PROCEDURE 06/19/8/.
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3RMDWOCO !.. !!.1 o sn-NONCONFORNANCE REPORT CONTINUATION SHEET i
NCR NO.
h528 REY.
O Sht.
9 of 10 j
i NOTE: STATE-SECTION CONTINUED AND INITIAL AND DATE ALL ENTRIES l"
j capability until 08/15/85. A review of Mr. Simile's resume provides j.
sufficient past experience and qualifications prior to 09/84 in g\\\\
order to satisfy the Level II capability requirements of ANSI j
N45.2.6 (1978).
}
The requirement for being certified in all designated areas of l!l responsibility was intended to enhance the knowledge and experience of the individual in order to have a better working knowledge of his l
areas of responsibility. This better working knowledge assists the-i QC Supervisor in resolving problems in his area and provides for j
better direction and supervision of their respective subordinates.
1 It does not oermit the OC supervisor to cerform inspections or i
review OC insoection checklists without. or orior to, formal l
certification in accordance with LKC Procedure 4.1.3.
To assure that QC inspection checklists were not performed or l
l reviewed by uncertified personnel, LKC has developed and implemented Procedure 4.13.1.1
' Turnover Document Review" which reviews inspection documents prior to turnover to Commonwealth-Edison. This procedure implements unique checklists in the review process which t
incorporates specific attributes to assure program compliance related to proper inspection checklist completion. This review l
j, supplies the objective evidence that inspections are performed ni f5 I!
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L. K. COMSTOCK & COMPAt;Y. INC.
3RAI 003 4.11.1 o gn-NONCONFORMANCE REPORT CONTINUATION SHEET I
i NCR NO.
L528 REV.
O Sht. 10 of 10 l
1 NOTE: STATE SECTION CONTINUED AND INITIAL AND DATE ALL ENTRIES l'
f.i and reviewed by certified individuals.
I:
Based on the above, Procedure 4.1.3 Rev. B was revised. This revision stated that the QC Superviso'r "will obtain certification to
.i Level II capability in those areas' of their responsibility. No
]
further action is required. [Ref. 4.1.2 Rev. C para. 3.29(a)]
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g ACTION TO PRECLUDE REPETITION: None. -As stated in the justification section of this disposition, the requirement for QC
- i Supervisor, as related to certification in responsible areas, was i
revised and allows the individual to obtain these certifications j
after being appointed to the supervisor position. No further action i
is required.
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