ML20214V930
| ML20214V930 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 12/05/1986 |
| From: | Love R, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20214V927 | List: |
| References | |
| 50-454-86-31, 50-455-86-17, NUDOCS 8612100011 | |
| Download: ML20214V930 (83) | |
See also: IR 05000454/1986031
Text
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-454/86031(DRS); 50-455/86017(DRS)
Docket Nos. 50-454; 50-455
Licenses No. NPF-23; CPPR-131
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Licensee: Commonwealth Edison Company
Post Office Box 767
Chicago, IL.60690
Facility Name: Byron Station, Units 1 and 2
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Inspection At: Byron Site, Byron, Illinois
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Inspection Conducted: May 27 through October 22, 1986
N f4
Ray S. Tove
M
Ah//C
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Inspector:
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Date ' /
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Approved By: Monte P. Phillips, Chief
/A/S//t
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Operational Programs Section
Date/ '
Inspection Summary
Inspection on May 27 through October 22, 1986 (Report No. 50-454/86031(DRS);
50-455/86017(DRS)
Areas Inspected:
Unannounced special inspection of licensee's action
on previous inspection findings, IE Bulletins, and 10 CFR 50.55(e) reports.
Also, an NRC review was initiated following receipt of allegations and
concerns from numerous sources relating to safety-related electrical work.
The inspection consisted of an examination of pertinent procedures, records,
and specifications, observations, and interviews of personnel. During this
inspection, Inspection Procedures 92701, 92703, 099014 and 099020 were used.
Results:
In the area of allegations reviewed, one example of a violation
of 10 CFR Part 21 and 21 examples of violations of ten of the eighteen criteria
of 10 CFR Part 50, Appendix B, were identified. See the Attachment for a cross
reference between the violations and report details.
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8612100011 861205
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ADOCK 05000454
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DETAILS
1.
Persons Contacted
Commonwealth Edison Company (CECO)
- +T. J. Maiman, Vice President, Projects
- +E. L. Martin, QA Superintendent
- +K. J. Hansing, Director of QA
- W. J. Shewski, Manager of QA
- G. E. Peterson, Section Engineer
- J. O. Binder, Project Electrical Supervisor
- G. E. Groth, Assistant Construction Superintendent
- B. R. Shelton, Project Engineering Manager
- K. A. Ainger, Nuclear Licensing Administrator
- D. Farrar, Nuclear Licensing
+R. B. Klingler, Project QC Supervisor
E. Briette, QA Engineer
- L. E. Bihlman, QA Engineer
- V. Schlosser, Project Manager
- G. Sorensen, Project Construction Manager
- J. L. Woldridge, QA Supervisor
- T. L. Lamb, PCD Electrical Field Engineer
- E. M. Zittle, Regulatory Assurance Staff
Sargent and Lundy (S&L)
T. E. Thorsell, Senior Electrical Project Engineer
- J. D. Regan, Electrical Project Engineer
- R. J. Netzel, Senior Structural Project Engineer
Hatfield Electric Company (HEco)
G. Vanderhet, Project Manager
R. P. Larkin, QA/QC Manager (Present)
A. Smith, QA/QC Manager (Past)
J. T. Hill, QC Superivsor (Present)
R. Farra11, QC Supervisor (Past)
D. Griggs, QA Supervisor (Past)
D. McCarty, Assistant QC Supervisor
S. Bindenagel, Electrical QC Group Leader
,
K. Higgins, Assistant Office Supervisor
E. Tovo, Project Engineer
U.S. Nuclear Regulatory Commission, Region III (NRC)
- A. B. Davis, Deputy Regional Administrator
- C. W. Hehl, Branch Chief, DRS
- +J. J. Harrison, Branch Chief, DRS
- R. F. Warnick, Branch Chief, DRP
- B. Berson, Regional Counsel
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- D. H. Danielson, Section Chief, DRS
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- W. -L. Forney, Section Chief, DRP
- +R. S. Love, Reactor Inspector, DRS
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- J. M. Jacobson, Reactor Inspector, DRS
- J. M. Hinds, Jr. , Senior Resident Inspector, Byron
- K. D. Ward, Reactor Inspector, DRS
- T. Vandel, Reactor Inspector, DRS
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- R..M. Lerch, Project Inspector, DRP
- C. H. Weil, Investigation and Compliance Specialist
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The' inspector also contacted and. interviewed other Itcensee and contractor
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. personnel during this inspection.
- Denotes those present at the meeting in Region III Office on July 2,1986.
+ Denotes those present at the meeting in Region III Office on
October 1, 1986.
- Denotes those present at the exit interview on October 22, 1986.
2.
Licensee Action on Previous Inspection Findings
(Closed) Open Item (455/83000-15; 455/85047-02): As part of the Safety
Evaluation Report (SER), Paragraph 8.2.4, the licensee committed to perform
verification testing to determine the adequacy of station electric
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distribution system voltages in accordance with guidelines in Part 4 of
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Branch Technical Position (BTP) PSB-1. To perform this test, the licensee
prepared and implemented Procedure AP-61. The Region III inspector reviewed
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Procedure AP-61; witnessed the test; reviewed the test data collected; and
determined that the voltages were within the guidelines established in the
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BTP.
Based on the inspector's observations as noted above, this item is
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closed,
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3.
Licensee Action on IE Bulletin 85-02
(Closed) IE Bulletin (454/85002-BB; 455/85002-BB):
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was issued to inform all power reactor licensees and applicants of
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reliability problems with Westinghouse 08-50 type ci cuit breakers
utilized in the reactor trip system.
Byron Station uses DS-416 type
circuit breakers rather than DB-50 breakers in the reactor trip system
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(RTS). However, to prevent the same type of problems with the 05-416
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circuit breakers, Westinghouse issued Field Change Notices (FCN)
(CAEM 10749, CAEM 10807, and CAEM 10808 for Unit 1 and CBEM 10685,
CBEM 10707, and CBEM 10709 for Unit 2) to replace the under voltage (UV)
trip assemblies and to modify the RTS to add an automatic shunt trip feature
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on the Main and Bypass Circuit Breakers. The inspector reviewed the
Westinghouse FCNs, the Material Receiving Reports, vendor documentation,
Work Releases to incorporate the various FCNs, QC inspection reports, and
the OAD test reports for the Unit I and 2 RTS main and bypass circuit
breakers.
Based on the inspector's observations as noted above, this
item is closed.
4.
Licensee Action on 50.55(e) Report
(Closed) 50.55(e) Inspection Report (454/83009-EE; 455/83009-EE): On
July 6,1983, the licensee notified Region III of a deficiency reportable
pursuant to 10 CFR 50.55(e) regarding the Westinghouse 7300 process
protection. system at Byron station. The first deficiency involved the
adhesive bond in the heat sink assembly on loop power supply (NLP) cards
was subject to failure.
Failure of the bond could cause the separation
of the metal heat sink plate from the thermal links such that it falls
off of the printed circuit board. Under certain conditions, this plate
could cause shorting of the low-level signal if it became wedged between
cards in the card frame.
For corrective action, the heat sinks on the
NLP cards were replaced. The second deficiency involved contact bounce
as experienced in seismic testing of the temperature channel test (NTC)
card. This would result in signal saturation of the RTD Amplifier (NRA)
card in the T
U ) and T
N ) circuits. This deficiency could
hot
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cold
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delay initiation of the over temperature - delta temperature (OT-AT) and
overpower - delta temperature (OP-AT) trips. Westinghouse issued FCN
No. CAEM-10756 to provide a temporary bypass of the input test relays
pending a final resolution of the contact bounce deficiency.
For final
corrective action, Westinghouse issued FCN No. CAEM-10832A for Unit 1 and
FCN No. CBEM-10730 for Unit 2.
These FCNs installed modified NTC printed
circuit cards (8 per unit) to resolve the mercury wetted relay contact
bounce problem during a seismic event. These modified daughter boards
have reed relay contacts wired in parallel with the mercury wetted relay
contacts on the printed circuit boards. The inspector verified corrective
action by reviewing the following: the above referenced Westinghouse FCNs; the
revised drawings that ir corporated these FCNs; S&L Post Fuel Load ECN
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No. P-374 that incorporated the Westinghouse FCNs; the Work Requests that
installed the modified circuit cards; the Westinghouse safety evaluation;
and the test data that verified the proper operation of the modified NTC
printed circuit cards.
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5.
Followup on Allegation RIII-86-A-0090
a.
Background: On May 7,1986, the NRC Senior Resident Inspector (SRI)
at Byron Station received an allegation involving alleged harassment
and intimidation of HECo Quality Control (QC) inspectors at the
Byron Station. On May 9, 1986, the SRI and Chief, Projects Section
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1A (Region III) met with 16 Level II HECo QC inspectors onsite at
Byron Station. On May 28, 1986, the NRC's Division of Reactor Safety
(Region III) was assigned the responsibility for followup on the HECo
QC inspector's concerns.
In most cases, these concerns were so general
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in nature that it would be impossible for the NRC to perform a
meaningful followup inspection on the expressed concerns.
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Due to the large number of concerned QC inspectors, the NRC inspector
elected to contact all QA/QC personnel employed by HECo from
February 1, 1986, through the start of this inspection, May 27, 1986.
The purpose of this contact was to provide each individual an
opportunity to identify and discuss their concerns, if any, with an
NRC inspector one-on-one off-site. A review of organizational charts
indicated that 94 persons had been/were employed during the time
frame selected. The NRC inspector telephonically interviewed 75 of
the 94 HECo QA/QC personnel. At the discretion of the interviewee,
the NRC inspector took the individuals concern over the phone or
met with the individual to receive their concerns.
For the 19
individuals the inspector was unable to contact, they were sent
registered letters, inviting them to contact the NRC inspector if
they had concerns with the safety-related equipment and/or applicable
documentation at Byron Station. The registered letter receipts were
returned from all 19 individuals, however, no additional concerns
were identified.
Summary: As a result of the special NRC inspection conducted at the
Byron Station, multiple examples of apparent violations of 10 CFR Part 21
and 10 CFR Part 50, Appendix B, were identified. These proposed
violations demonstrate Commonwealth Edison Company's failure to exercise
adequate oversight and control of their principal electric contractor,
Hatfield Electric Company, to whom they had delegated the establishment
and execution of a quality assurance program in the electrical area.
During the inspection _it was revealed that (1) Commonwealth Edison
Company (CECO) failed to incorporate the requirements of 10 CFR Part 21
into their contract with Hatfield Electric Company; (2) Ceco failed to
resolve (repair / rework / reject /use-as-is) identified hardware deficiencies
in Unit 18 emergency diesel generator system.
Some of these deficiencies
had been identified as early as 1983; (3) CECO and HEC 0 had dispositioned
NCRs, DRs, and inspection reports "use-as-is" without the design
organization's approval or without a clear basis for the inspection
elements acceptability; (4) CECO did not have a procedure for CECO
construction to notify CECO operations of deficiencies that could affect
the safe operation of Unit 1 or a procedure to ensure that items are
reassembled after fireproofing activities had been completed; (5) CECO
was deleting inspection attributes by memorandum and HECo was deleting
inspection attributes by verbal directions; (6) by verbal directions from
a CECO field engineer, the modification of 11 items of Unit I safety-
related equipment were not QC inspected; (7) HECo failed to accurately
status Unit 1 inspection reports which resulted in 57 required inspections
not being performed; (8) two HECo QA Lead ' Auditors and 16 HECo QC inspectors
were improperly certified; (9) HECo failed to include all NCRs and DRs in
their trend analysis (i.e., 98 of 104 NCRs and 199 of 236 DRs prepared
during the trending period were not included in the trending analysis),
and (10) HECo had closed NCRs (approximately 38 identified) before the
corrective action to prevent recurrence had been implemented.
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(1) Concern: Temporary hangers were installed by using an unsigned
Field Change Request (FCR). These hangers are welded to
Category 1 steel and are located inside the secondary shield
wall next to each steam generator (S/G) in Unit 2.
They have
weld travelers but the welds have never been inspected.
NRC Review: The NRC inspector performed a physical inspection
of the area identified by the alleger. The inspector identified
12 temporary hangers (three per S/G) that were welded to
Category 1 (safety-related) box beams. During personnel
interviews, the inspector was informed that these hangers were
installed per the verbal direction of CECO Project Construction
Department (PCD) to protect the electrical wiring associated with
the " Loose Parts Monitor" for each S/G. Through the review of
the applicable weld travelers, the inspector determined that
these hangers were installed during the February 24-28, 1986,
time frame. The inspector was also informed that these temporary
hangers are scheduled for removal prior Unit 2 fuel load. The
HECo Level III welding inspector was maintaining the applicable
weld travelers in his " work pending" file.
In accordance with
HECo procedures and site instructions on temporary attachments,
an inspection of the attachment weld is not required. However,
when these temporary attachments are removed, an inspection of
the base metal will be required per CECO direction.
In this
instance, the box beams are scheduled for a visual and magnetic
particle (MT) inspection when the 12 temporary hangers are
removed.
Conclusions:
It was substantiated that 12 temporary hangers
were installed in the area of Unit 2 S/Gs and that these hangers
were attached to Category 1 steel (box beams). Additionally, it
was established that these hanger attachment welds were not QC
inspected.
However, there is no requirement for the inspection
of temporary attachment welds. The base metal is scheduled for
visual and MT inspections when the temporary hangers are removed.
No violations or deviations were identified.
(2) Concern: HECo QA/QC management instructs QC inspectors to stay
out of Unit 1 areas. If an inspector identifies a deficiency in
Unit I area, he " catches hell".
Examples of defective wd ds in
Unit 1 are hangers WCP1-1 and WCP1-5.
NRC Review:
During personnel interviews, (CECO PCD, Ceco QA
and HECo QA/QC), the NRC inspector was informed that when Unit 1
was declared operational, CECO informed all contractors to keep
their personnel out of Unit I areas unless they had a specific
job to perform in those areas.
In addition, as part of CECO's
Nuclear General Employee Training (NGET) personnel are informed
that the security program required controlled access for certain
areas. Due to their job requirements, most HECo QC inspectors
have a photo badge and a key card that allows them access to
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'both Unit 1 and Unit 2' areas.
If an' inspector was inspecting
Unit 2 work operations, he/she would have free access to Unit 1
equipment. Therefore, the only way to control access to Unit 1
items is through verbal or written direction.
If an inspector
was'in the Unit 1 area without a specific job assignment, that
meant they were not performing their required job functions in
Unit 2.
However, if the inspector observed a deficiency while
passing through the Unit 1 area, the inspector is expected to
notify CECO of the deficiency by the use of a meno. With:
respect to hangers WCP1-1 and WCP1-5, the inspector was unable
to' locate those hangers with defective welds. Without a speci-
fic drawing number, it is impossible to identify the hangers
that the alleger was alluding to in that most all drawings
reviewed had these hanger numbers assigned, i.e., each building,
and each elevation of the building, and if different drawings,
each area of a given elevation could have hangers WCP1-1 and
WCP1-5. When queried, the alleger could not remember the
building, elevation, area, or drawing. As stated above, the
inspector could not identify any WCP1-1 or WCP1-5 hangers with
defective welds.
Conclusions: . It was substantiated that HECo QC inspectors were
directed to stay out of Unit I areas. However, this direction
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was given so as to limit the personnel in the vital areas of an
operating plant (Unit 1) and was at the direction of the
licensee.
If an inspector identified deficiencies in Unit I
while his job assignment was for Unit 2 work activities, he/she
may " catch hell" for being in Unit 1, but not for reporting a
discrepancy. With respect to hangers WCP1-1 and WCP1-5, the
inspector could not identify any WCP1-1 or WCP1-5 hangers with
defective welds. No violations or deviations were identified.
(3) Concern: Weld traveler cards are missing on approximately 20%
of the Unit 2 J-Box' attachment welds.
NRC Review: During interviews of HEco QC and engineering
personnel and the review of Discrepancy Reports (DR) and
Nonconformance Reports (NCR) it was apparent that HECo had an
extensive problem with missing weld travelers (lost or never
prepared). DR 8512 identified 37 Category 1 J-Boxes that were
missing weld traveler (WT) cards. After research, it was found
that 11 J-Boxes did not require WT cards in that the J-Boxes
were installed with concrete expansion anchors (CEA) or by bolts
to tube steel.
For the remaining 26 J-Boxes, new WT cards were
generated and the welds inspected and repaired as necessary.
If
some of the data required on the WT was not recreatable from
other records, the DR number was entered in that space.
For
example if the actual date of installation could not be
determined from the foreman's construction reports, DR 8512
would be entered as the installation date.
In addition, Ceco QA
Surveillance Reports 6941, dated February 11, 1985; 3780, dated
July 25, 1985; and 7948, dated March 5, 1986, also addressed the
fact that HEco was missing WT cards.
Concern (4) below also
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addresses alleged missing WT cards.
The NRC inspector verified
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that DR8512 and CECO QA Surveillance Reports 6941, 7380, and 7948
were properly closed.
In addition, the inspector randomly selected
- 24 Category I and II J-Boxes from the 6E-2-3600 series drawing
for review of WT cards. One or more WT cards were reviewed for
each J-Box selected and were found acceptable.
Conclusions: HECo had problems with missing WT cards for Unit 2
J-Boxes, however, the missing WTs had been documented and
resolved by HECo on DR8512 and on Ceco QA Surveillance Reports
No. 6941, 7380, and 7948.
In addition, the NRC inspector
selected 24 J-Boxes at random and did not identify any missing
WT cards. No violations or deviations were identified.
(4) Concern: There are no WT cards for Category II welds.
Example
provided was cabinet / panel attachment welds.
NRC Review: The NRC inspector reviewed approximately 125
non-safety related (Category II) Equipment Installation Reports
where attachment welds were required.
In all cases, WT cards
had been prepared for these attachment welds. Also, see
Concern (1) above for additional examples of WT cards being
prepared for the installation of non-safety related items.
Conclusions:
In that weld travelers were prepared for the
approximately 125 non-safety-relatea items reviewed, this
concern could not be substantiated.
No violations or
deviations were identified.
(5) Concern:
If a hot item (item required to support testing and/or
turnover) was rejected by one inspector, another inspector was
directed to reinspect the item and accept it.
For example,
approximately four months ago (February 1986) an inspector
rejected some welds on Category I cabinet attachments in Area 7
and HECo QC inspector (by name) accepted the welds.
NRC Review: All WT cards are entered into the HEco computer
system by WT number, drawing number, area number,
hanger / equipment number, welder, and QC inspector that accepted
the weld (s) associated with that WT. The NRC inspector requested
and was provided a printout of all WT cards inspected by the
named individual in Area 7 between November 1985 and June 1986.
A review of the WT cards indicated that the named individual
had not inspected any weld in Area 7 (between November 1985 and
June 1986) that had been previously inspected by another
inspector.
It should be noted that the QC inspector documents
his/her inspections on the original WT card.
This included
rejections and reinspections. As part of CECO's ongoing
overinspection program, Pittsburgh Testing Laboratory (PTL)
selects, at random, 10% of each inspectors work for reinspection.
PTL's 10% sample of the named individual's work resulted in a
50% reinspection of his work in Area 7 between November 1985
and June 1986, with no rejections.
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Conclusions:
Based on the NRC-inspector's review of the named
individuals work in the area specified this concern could not
be substantiated.
This concern was also refuted based on PTL's
overinspection of his work. No violations or deviations were
identified.
(6) Concern: The HECo QA supervisor restricted access to vaulted
records. The following examples were provided: (a) QC inspectors
were not allowed to look at old (vaulted) WT cards and could
only use the WANG to verify acceptability; (b) if a QA inspector
wanted to look at any vaulted records, the inspector must have
the QA supervisors written approval, i.e., the supervisor
initials the records sign-out card;-(c) the QA supervisor would
look at the records requested and inform the inspector that "You
don't need to see the record, it was inspected and accepted -
Trust me."
NRC Review: To establish the need for QC inspectors to review
vaulted records, the NRC inspector reviewed several of HECo
procedures. The following are typical examples where the
inspector needs to verify vaulted records (completed QC records
stored in a records vault):
(a) Procedure 20
" Class I Exposed Conduit System
Installation." When the QC inspector is performing
a conduit inspection per Form HP-201, Item 3 on the
checklist requires verification that the supports
(hangers) were installed per drawing. This task is
performed by verifying support inspection checklist,
Form HP-203, was complete and acceptable.
Form HP-203
is completed by a welding inspector.
(b) Procedure 20 - When the QC inspector is completing a J-Box
installation report, Form HP-206, the inspector has to verify
that a complete and acceptable WT or CEA traveler is on
file.
(c) Procedure 19
" Equipment Turnover Reporting" and
Procedure 19A
" Electrical Panel Turnover Reporting."
These procedures require QC to verify that numerous
inspection reports are complete, acceptable, and on file.
If there are any exceptions, these exceptions must be
noted on the turnover report.
Based on the NRC inspector's review of HECo procedures, it was
determined that the QC inspector must have free access to the
vaulted records to perform his/her job related functions.
During personnel interviews, the inspector was informed by the
vault clerk that the QA Supervisor must initial the " Records
Checkout Card" before she could provide the QC inspector with
the requested records. The inspector also observed various QC
inspectors obtaining the QA Supervisors initials on checkout
cards. Also during interviews of computer operators and QC
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personnel, the NRC inspector was informed that the general
guidance provided was to utilize the computer to determine
item acceptance. This was enforced more if the records were
in Vault No. 2.
Vault No. 2 is under the control of CECO and
contains HECo Unit I records, some Unit 2 records, and
' certification records for former HECo QA/QC personnel. With
respect to the third example provided (Concern c. above), this
appeared to be a statement taken out of context.
In order to
resolve this problem, meetings were held with Ceco and HEco
personnel and HECo was directed to "open the vault" to all
QA/QC personnel; i.e., allow personnel to checkout documents
without the QA supervisors approval. The subject QA supervisor
was terminated July 2, 1986.
Conclusions: Based on the inspector's observations and personnel
interviews, examples (a) and (b) of this concern were substantiated
and it was also determined that the QC inspector needed free
access to the vaulted records in order to perform his/her job
related functions as described in the HECo procedures.
The licensee was informed that failure to assure that QC
inspectors had the authority and organizational freedom to
verify inspections of safety-related _ functions is an example of
failure to implement 10 CFR 50, Appendix B, Criterion I
(454/86031-01; 455/86017-01).
(7) Concern: Temporary Ticket Holders are afraid to reject anything
for fear of being fired.
HEco QC inspector (by name) is a good
example. Temporary Ticket Holder was defined as a craft
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journeyman that was working as a QC inspector (Red Hat) and -
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took a pay cut under the new union agreement to work as a QC
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inspector (White Hat).
CECO Project Electrical Supervisor (by
name) directed HECo to get rid of Red Hat QC inspectors.
Red
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Hat QC inspectors that went "back to the tools" (working as
craft journeymen) were better' qualified than many present QC
inspectors.
NRC Review: To fill a void in the HECo QC Department,
journeymen electricians and welders were transferred on.a
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temporary basis to the QC department. These personnel were
trained, tested, and certified as QC inspectors. At a point
in time, the HEco QC department was made up with non-union QC
inspectors and union journeymen QC inspectors (Red Hats). Due
to the large difference in pay, the non-union inspectors
organized and a union contract was negotiated for HECo QC
inspectors. At that time, " Red Hats" were afforded the
t
opportunity to change over to " White Hat" QC inspectors at a
reduced pay.
In accordance with the QC union contract,-the Red
Hats were the "first to go" on a reduction in force (RIF). At
the present time, there are no Red Hats in the HEco QA/QC
department.
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With respect to qualification of QC inspectors, the NRC
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established the minitrum requirement that would be acceptable ~
for certification with the issuance of Regulatory Guide 1.58
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previously employed HEco QC inspector's qualification records.
and Generic Letter 81-01. A sample review of present and
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indicated that all 0C inspectors met.the minimum requirements'
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for certification.
In fact, some'of these Red Hat and White Hat
inspectors exceeded the minimum requiremeKts for certificattorJ
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The inspector reviewed the last eight .nonths 'of welding
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-inspections (area certified) performed by the named QC
.s
inspector and the inspections of eigat additional 16spectors.
The reject rate on initial inspections wis higher for the named
inspector than for the.other eight inspectors.
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Conclusions: Basedon'theNRCinspector'srevkewofinspection
reports, certification records, and union contra:ts, the
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allegers conc ^rns could not be substantiated. All QC
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inspectortwere qualified and properly certified.- There wts no
evidence thaii the " Red Hats" were treated it, a discriminatory
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manner. Na VI'olations or deviations were identified.
(8) Concern: .The Assistant QC Supervisor (by 1narne) was fired. 'He
was the one lha.t lied about his education. 011y Leads and
a
fanagement .oro allowed to reips,%ct his work after he was
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terminated.
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NRC Review: 7 Threugh the review of records relate'd to this
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concern, it war donfirmed that the named individe,41 had falsiYied
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a Diplo.n of Graduation from North Cee. tral Collega, School of
Technology. The individual resigned from HEco on tierch 21,
1986. A reinspection of the indisicual's hori wa3 nerformed
.under the guidance of CECc. At the time of tin reiaspec'. ion of
,
stud welding, thesonly 19dividual certified inithis ares \\was the
Level JII inspector., Thu, required " Management" to. p'nspect
the in:lividuals stud weldirq inspections. The rainsphtton of
,
-
the individual's visual weld lnspections were perforr.ed by a
HEco QC Lead Ir.spector. .Further,research by the NRC inspector
,~
indicated that'the indivicarl's Neld ingections had been ;
'
previously reinspected under the Byron Reinspection Prcgram.
It
i
should also"ce noted that the NRC SRI at Byron Station had been
'
previously informed of the falsified education, reinspection
program, and resbits of the reinspection.
'
,
1
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!
Conclusion:' This concern v a .substantikted in that Management
(
D.evel DT) uid reinspect the individuals stud weld inspections,
.however, tha Level III was the only inspector certified in<this
- area at,the.tiie of reinspection. Also, a certified dead
inspectur rcinspected the individuals visual,welo inspections.
h/
Additionally, the individual's visual weld inspections had been
previously reinspected under the Byron Reinwetion Program.
No violations or deviations were identified
.,
11
,
-L
-.-
-____.__--.-,...,-__.___-_---.--.,,.,_,----,m
-_
_ ._. . _ . . .
._.
, _ _ _ __
. _ _ _ . _ _
._
. _ _ _
'
(9) Concern: A QC inspector questioned an engineering design on
a Detail J-(type of conduit hanger attachment). At.a special-
meeting, the Level III Welding Inspector (by name) informed the
QC inspectors that they do not perform engineering design
j
reviews. The. Level III also stated that if an engineer said to
put bubble gum on a hanger, QC's job was to inspect the bubble
gum.
l
~
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..
NRC Review: During an interview of the named Level III, the
i
Level III confirmed his meeting with the inspectors.
In that a
,
small faction of the welding QC inspect' ors wanted to " redesign
the plant", the Level III deemed the meeting to be justified.
-
3
With respect to the bubble gum, the Level III stated that the
allegers statement was not correct. The Level III informed the
3 -
NRC inspector that what he actually said was, "If engineering
,
said to put bubble gum on a hanger, it was QC's job to inspect
!
.i
the bubble gum and to make damn sure it was the brand specified."
Conclusion:
The Level III welding. inspector made a valid point,
in that QC inspectors are to verify compliance with instructions,
procedures, and drawings, not to conduct engineering reviews,
The Level III's analogy was taken out of context. No violations
,
or deviations were identified.
4
(10) Concern: HEco QC Department has gone to hell since Energy
Incorporated (EI) came in.
i
+
,
i
NRC Review:
EI is a company that supplies QA/QC personnel
.
l
'
under a contract with HECo. These personnel were assigned
positions as QA engineers and cs QA/QC Management /Supervisers.
During personnel interviews, it was perceived by the Region III
'
inspector that an anomic condition exists within the HEco QA/QC
,
Department. This appeared to stem from the fact that outside
'
personnel (EI) were brought in and placed in management and
I
supervisory positions and the lack of communications between
Managment/ Supervisors and the QA/QC staff. However, this anomic
i _
condition did not affect the inspection effort and integrity of
j.
the QC inspectors. As part of . Ceco's QA program, PTL does a 10%
overinspection of the HECo work.
From September 27, 1985
'
l
through July 10, 1986 (inspector's sample period), PTL performed
approximately 800 overinspections and identified only two (2)
rejectable attributes that had been previously accepted by
,r
.
HEco QC inspectors.
'
'
Conclusions: Although it was evident that some high level'of
4
animosity had developed between HECo QC staff ara the EI staff.
.
and significant communication probelms existed, a high level of
'
l
quality inspections was maintained. This is based on the fact
that PTL performed approximately 800 overinspections and found
two rejectable attributes. Therefore, thfs concern was not
substaptiated. No violations or deviations were identified.
l
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12
'
-
-n
il
s
)
.
(11) Concern: ' QC identified deficiencies on inspection reports
are being dispositioned "use-as-is" by CECO and HECo. HEco
engineering prepares a separate report (OIR) to accept the
items as installed.
Some of their engineering reports were
not numbered, or after the QC inspection report is closed,
'
the engineering backup documentation (0IR) was destroyed.
i
NRC Review:
Based on a review of Paragraph 5.1 of HECo
Procedure 6, " Reporting of Damage or Nonconforming Material or
-
Equipment," and personnel interviews, the following is a summary
of how the Open Inspection Report (OIR) system should work:
(a) Deficiencies identified during routine surveillance or
inspection activities are identified on the appropriate
inspection checklist (IR) by the QC inspector.
'
(b) OIRs (reports that indicate deficient checklist items found
during QC inspections) are filed in a " work pending" file.
(c) Copies of OIRs,'along with the associated installation
report, are provided to the Assistant Project Manager
for resolution of the deficiencies,
i.e., construction
corrects the deficiencies.
(d) Corrected installation reports are returned to QC
for verification of the corrected deficiencies.
(e) QC verifies the resolution and documents their acceptance
on the OIR from the work pending file.
The NRC inspector identified the following examples of
deficiencies within the HEco OIR program:
(a) Conduit inspection checklist, (Form HP-201) No. 4902,
identified that conduit C2A7429 contained 370 of bends
(maximum is 270 per specification). This nonconforming
condition was dispositioned "use-as-is" by HECo
engineering without licensee and S&L approval on an
,
uncontrolled HECo engineering document (No form number)
identified as 0IR No. 4902-19?.
(b) Equipment modification inspection checklist (Form
HP-12A-1) No. 5101, identified exposed copper at a
termination lug on Terminal 13. This nonconforming
condition was found acceptable as installed per a " Speed
Letter" from T. Lamb, CECO PCD, to S. Bindernagel
(Bindenagel), HEco' QC.
'.
(c) Conduit inspection checklist (Form HP-201), No. 4788,
identified that the "0" ring was missing on conduit
C2A1209.
"0" rin'gs are required per S&L specifications,
13
,
.
- ,-
-
__
Standard EB-146. This nonconforming condition was found
acceptable as installed per a " Speed L:.cter" from S.
Vovos, CECO PCD, to E. Tovo, HECo engineering.
(d) Conduit inspection checklist (Form HP-201), No. 4736,
identified that conduit C0A62F9 was installed outside the
elevation tolerance. The inspection report indicated that
during a reinspection, the Detail J connections had been
cut off of a previously accepted hanger (SCC-1) and
reinstalled without any documentation, i.e., Discrepancy
Report (DR), Nonconformance Report (NCR), or Form 7A, Rework
Request. During a review of this inspection checklist, the
NRC inspector was informed that HECo engineering had prepared
an 0IR to rework the hanger to correct the conduit
elevation, however, no OIR could be found.
(e) Equipment modification checklist (Form HP-12A-1), No.14217,
required a 100% inspection of panel 2PA11J prior to turnover
to CECO. The inspector identified two potential problems:
(1) "Cannot determine if wire size is per print"
(2) "Cannot inspect lugs landed up-side down"
Both of these items were marked " acceptable" on the HEco
inspection report by a CECO PCD engineer.
As a result of a management meeting in NRC's Region III office
on July 2,1986, CECO QA initiated Audit 6-86-201 to address
NRC concerns expressed during the management meeting. The lack
of control of OIRs, as noted above, was one of these NRC concerns.
The CECO QA audit was performed by seven CECO auditors with
assistance from PTL certified QC inspectors. This audit was
initiated on July 7,1986, and concluded on August 4,1986. As
a result of Ceco QA review of the HECo 0IR program, Ceco QA
issued two findings against HECo and one finding against the
CECO PCD electrical group.
Conclusions:
Based on the five examples of violations identified
by the NRC inspector and the three findings identified by the
licensee in Audit 6-86-201, this concern was substantiated.
The licensee was informed that failure to assure that design
changes were approved by the organization (S&L and/or
Westinghouse) that performed the original design was an example
of failure to implement Criterion III of 10 CFR 50, Appendix B
-
(Reference: Paragraph 5.a.(11)(a), (b), (c), and (e) above)
(50-455/86017-02).
The licensee was further informed that failure to assure that
nonconforming conduit C0A62F9 (Reference: Paragraph 5.a.(11).(d)
above) was reworked or repaired in accordance with documented
instructions (NCR or DR) or procedures is an example of a
failure to implement Criterion XV of 10 CFR 50, Appendix B
(50-455/86017-03).
14
(12) Concern: HECo material is not traceable. There are no heat
numbers on any of the material.
If CECO accepted the material,
HECo QC is not to question its acceptability.
NRC Review: Criterion VIII of 10 CFR 50, Appendix B, requires
that the identification of an item be maintained in some manner
throughout fabrication, erection, and use of the item. This
identification and control is designed to prevent the use of
incorrect or defective material, parts, and components. Based
on an interpretation by the NRC, it is not necessary to provide
unique traceability for items such as hanger material (A36),
unistrut, conduit, cable tray, etc. that are used in the
electrical area (non-coded applications) provided:
The material is ordered safety-related,
'
During receipt inspection, it is verified that the material
meets the applicable specification requirements, including
documentation,
Safety-related material is not comingled with
non-safety-related material, and
The issue of the material for use or installation is
controlled.
At the Byron Station, Ceco procures all material for all site
contractors. With respect to electrical raceway material,
these items are procured and received as safety-related.
In
accordance with HECo Procedure 5, " Class I Material and
Equipment Receiving and Inspection", HECo QC performs receipt
inspection of CECO procured material, upon request, to Ceco
requirements as stated on the Material and Equipment Receiving and
Inspection Report (MRR).
In addition, for CECO Station Nuclear
Engineering Department (SNED) procured items (permanent plant
material items), CECO PCD and Ceco QA also performs a receipt
inspection and/or documentation review. The release of the
items or material for installation or use is performed by CECO
QA after the material and documentation has been inspected / reviewed
and accepted.
In general, when CECO issues items / material to
HEco for installation or use, an additional receipt inspection
by HECO QC is not required to determine its acceptability.
In
that the vendor documentation is controlled by S&L or Ceco,
'
HECo QC can not determine the acceptability of an item. However,
t
if a damaged or defective item is observed by the HECo QC inspector,
this deficiency must be documented and reported in accordance
I
with HEco Procedure 6, " Reporting of Damaged or Nonconforming
Material or Equipment."
'
Conclusions: This concern was substantiated, however, the
tracking of an item by part or heat number is not required for
non-coded applications in the electrical area. HECo and/or
CECO performs the required receipt inspections. HECo can
however identify nonconforming hardware problems.
In that HEco
QC does not have access to the vendor documentation, they cannot
determine an items software acceptability. No violations or
l
deviations were identified.
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-_.
.
.
. .
_ _ _
_
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-
_
__
.
_ _.
_
,
4
(13) Concern: HECo QC was instructed not to look at vendor welds.
HECo QC rejected better welds than most of the vendor welds,
however, CECO bought-off all of the vendor welds. Think the
i
vendor was Systems Control.
NRC Review: A review of the history on Systems Control
revealed that welding problems had been identified and documented
by HECo, CECO, and the NRC. As documented by CECO and the NRC,
there were instances where undersized welds and missing welds
were evaluated by S&L and found acceptable as installed.
The following are examples of NCRs and reports that address
'
problems, corrective actions, and acceptance of welding by
Systems Control: HECo NCRs 461,1062, 1065, 1066 and 1067; CECO
NCR 885; Ceco 50.55(e) Reports No. 454/82008 and No. 455/82008;
CECO QA Audit Report No. 6-84-309; and NRC Inspection Reports
'
454/83039, 455/83029, 454/84C31, 455/84024, and 454/84050,
455/84034.
.
Conclusions:
It was substantiated that Ceco experienced
problems with Systems Control welding and based on an analysis
by S&L, many of these welds were accepted in the as-found
l
' condition.
However, these welding problems had been documented
and resolved by the licensee with followup inspections and
acceptance by the NRC.
No violations or deviations were
identified.
(14) Concern: The HECo QC Supervisor (by name) does not have any
certifications to any of the procedures at Byron Station.
HECo
5
wanted to make the named individual a Level III inspector but the
present Level III (by name) would not sign his name to any
>
certifications for the named QC Supervisor.
It was also stated
that this same QC Supervisor misplaces / destroys NCRs and DRs.
A QC inspector (by name) told the alleger that the Supervisor
destroyed three of his NCRs/DRs. The named QC Supervisor managed
by intimidation and was interested in quantity, not quality.
NRC Review: The NRC inspector reviewed the training,
!
qualification and certification file for the named QC Supervisor.
Except for a resume, this individual's file folder was blank.
,
,
HECo Procedure 17, " Qualification and Training of Inspection and
i
Audit Personnel", Paragraph 5.3, requires that all QA/QC personnel
!
complete the "QA/QC Personnel Indoctrination Checklist",
Form 172. This indoctrination includes but is not limited to:
4
reading electrical specifications; knowing Byron alarm signals,
i
<
emergency phone location and procedure; reading the HECo QA
Manual and QC procedures; and becoming familiar with the S&L
i
drawings and standards.
This named QC Supervisor started his
employment with HEco at the Byron Station on October 7,1985,
and as of June 13, 1986, he had not started his basic
!
indoctrination as indicated by his file.
In addition, the HECo
QA/QC Manager (Employment date of August 6,1984) and the QA
.
Supervisor (employment date of February 25,1985) had not
1
l
completed their basic indoctrination as of June 13, 1986. The
i
16
- - ,
. .
.
- - - .
,..- - -.-
,
- .
. .
- - - - . - - , , - . - . -
QA Supervisor inform d the NRC inspector that none of his QA
engineers had completed this training. During an interview
of the named Level III inspector, the NRC inspector was informed
that the Level III had no confidence in the named QC Supervisor
and that he would not certify him to any procedures.
On August 6, 1986, a physical search was made of the named QC
Supervisors office and no open NCRs, DRs or 0 irs were found.
During an interview of the named OC inspector, he did not
identify any concerns pertaining to any specific documents that
the named QC Supervisor may have destroyed. As stated in
Paragraph 5.a.(10) above, there was a lack of communications
between Supervision and the QC inspectors, however, based on the
small rejection rate (0.25%) of HECo QC inspection activities by
PTL's overinspection, this lack of communication did not affect
quality.
Conclusions:
It was verified that the named QC Supervisor was
not certified and the named Level III would not certify him,
however, there is no requirement for a supervisor to be certified
if he/she does not perform QC acceptance inspections.
It could
not be verified that this supervisor destroyed or misplaced any
quality related documentation. Based on the results of PTL's
overinspection program, this supervisor's management techniques
did not affect the quality of the project. However, the licensee
was informed that failure to assure that indoctrination and
training was provided to QA/QC personnel in accordance with
approved procedures is and example of failure to implement
Criterion II of 10 CFR 50, Appendix B (454/86031-14A;
455/86017-14A).
(15) Concern: The QA/QC Manager told a QC Group Leader (by name)
to hold a stack of Unit 1 inspection reports. These reports
identified deficiencies that were never corrected and items
that were never reinspected. The Unit 1 turnover logs are not
accurate.
NRC Review: On July 18, 1986, while conducting personnel
interviews related to this concern, the NRC inspector was
provided a printout that listed 44 Unit 1 and 11 Unit 2 open
inspection reports. The NRC inspector provided a copy of this
printout to the CECO QA Site Superintendent for information and
corrective action.
In that Unit I was shutdown for other
maintenarce activities, immediate action was taken to resolve
the 44 Unit 1 open inspection reports. The reinspection
identified some deficiencies which resulted in 15 nuclear work
requests (NWR) being issued to rework and reinspect the
identified deficiencies. Upon returning to Byron Station on
Monday, July 21, 1986, the NRC inspector was informed that all
corrective actions had been completed to resolve the deficiencies.
The inspector reviewed all the NWRs and selected 12 for physical
inspection of the reworked items. All corrective actions
reviewed were found to be adequate.
Following are examples
of the deficiencies identified:
17
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.-
t
NWR 6DG049 - Class IE Equipment Modification Inspection
Report No. 4377, dated August 15, 1983, identified that all
the bolts.on a buss bar insulator support were loose (i.e.,
less than finger tight). This deficiency was located in
Unit 1 4160V diesel generator panel IDG01KB.
NWRs 6DG046 and 6DG047 identified improperly installed
,
4
heat shrink tubing.
Six NWRs identified conductor insulation damage.
In
several cases, the copper. conductor was also damaged.
In these cases, damaged conductors were cut off and new
conductors butt spliced onto the cable.
Five NWRs required the replacement of termination lugs
due to improper installation or damage.
To determine the root cause for Unit 1 inspection reports still
being open approximately 17 months after the unit went into
operation, additional interviews were conducted. During these
interviews, the NRC inspector was informed that a HECo QC Group
Leader was made aware of the existence of an unknown quantity of
Unit 1 inspection reports in HECo's possession that had not
been processed. With HEco management approval, a physical
search of the HEco premises was conducted on April 12, 1986.
This search uncovered 360 Unit I and 13 Unit 2 inspection
reports in a tool box controlled by the QC Group Leader named
in the concern. This named Group Leader was permitted to
resign, effective April 22, 1986, indicating that he was not
holding these reports at the direction of the QA/QC Manager.
HECo QA took possession of these 373 reports and-initiated a
review to determine acceptability. In that Unit I had been
turned-over to CECO, the HECo Quality Program had no means to
'
'
formally transmit a Unit 1 deficiency to CECO except when they
are performing work activities under the licensee's nuclear
work request (NWR) program. A review of the HECo QA Manual and
Specifications F-2790 indicated that the requirements of
10 CFR 21 had not been imposed on HECo.
In addition, a
Commonwealth Edison Company Vice President stated during a meeting
i.
in the NRC's Region III Office on July 2, 1986, that Commonwealth
Edison Company does not impose the requirements of 10 CFR Part 21
on any of their onsite contractors. On approximately June 10,
1986, a HEC 0 QC Group Leader informally informed the CECO PCD
Project Electrical Supervisor and a PCD Electrical Engineer of
the 44 Unit 1 open inspection reports that had been identified by
'
HECo QA.
In that the HECo QA/QC Manager and QA Supervisor had
'
baen terminated approximately July 2,1986, the NRC inspector
could not determine why CECO was not notified sooner. When
cuestioned as to why he (QC Group Leader) decided to inform CECO
of the open inspection reports, he responded, "I knew that sooner
,t
,
,,
18
t
,, - - - . . - - - - . - _
,
-- - , . - . .
,.-...c
-
--,,#.,r.-
-
m.,.,-e.,.xm,.
,m
m-
r--.-
4
e---..,
---.-s..
.,--~r.-,m7_.u
- , - , , , . , . , +
r
,-y
-
-
or later you would ask the right question and I thought they
(CECO) should know about it before I had to tell you."
Although
CECO PCD became aware of the Unit 1 open inspection reports on
approximately June 10, 1986, this fact was not documented in
any CECO corrective action system as of July 18, 1986.
Based on this latest information, the inspector queried several
QA engineers to determine the location and status of the 360
Unit 1 inspection reports. Upon request, the NRC inspector was
provided a stack of Unit 1 inspection reports. Again, this
information was shared with the CECO QA Site Superintendent.
During a review of these reports, it was observed that there
were 28 unnumbered inspection reports r.nd an additional 13
reports where the status of the item was indetcrminate.
An
immediate reinspection of these items was initiated by the
licensee. This reinspection verified that five of the inspection
reports were acceptable and eight reports required rework and
reinspection. The rework and reinspection was completed in
approximately 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />.
The NRC inspector performed in process
inspections of these work activities and found them to be adequate.
In addition to the 360 Unit 1 inspection reports discussed above,
HECo QA had an additional 81 closed Unit 1 inspection reports for
work activities directed by the licensee. On approximately
July 24, 1986, these 441 (360 plus 81) Unit 1 inspection reports
were transmitted to the licensee on transmittals 293, 294, 323,
and 314.
With respect to the concern regarding Unit 1 turnover logs, the
concern was substantiated by the fact that neither the turnover
reports or turnover log identified the 360 inspection reports
discussed above.
In addition, HECo failed to establish a
system to accurately status inspection reports (i.e., open,
closed) to preclude inadvertent bypassing required inspections
and tests and assurance of final acceptance.
The NRC inspector also established during the review of this
concern that CECO does not have a proceduralized system for
Byron Construction to notify Byron Operations of construction
deficiencies which could potentially impact the safe operation
of Unit 1.
Also, it was apparent that CECO does not have an
effective system to determine if the site contractors have
turned-over all required documentation prior to accepting an
item / system from the contractors (HECo).
Also, as of July 17, 1986, the deficiencies identified with
Unit 1 items, as identified above, were not evaluated for
reportability per the requirements of 10 CFR 21. An evaluation
for reportability would have been initiated per procedure if
CECO PCD had prepared an NCR when they learned of the open
Unit 1 inspection reports.
,
19
Conclusions:
It was established that HECo was holding 360
Unit 1 inspection reports (with an indeterminate status) and
that CECO was not aware of this problem until approximately
June 10, 1986. Of these 360 reports, 28 were not numbered and
57 required reinspection or rework and reinspection.
It was
also verified that the HECo turnover log / reports were not accurate
in that these 360 Unit I reports were not listed.
The licensee was informed that:
(a) Failure to incorporate the provisions of 10 CFR 21 intc
the HECo contract is an example of a failure to implement
Paragraph 21.31, " Procurement Documents", of 10 CFR 21.
This violation is generic for all CECO site contractors
(454/86031-02; 455/86017-04).
(b)
Failure to assure that conditions adverse to quality were
promptly identified and corrected is an example of a
failure to implement Criterion XVI of 10 CFR 50, Appendix B
(454/86031-04).
(c) Failure of the electrical contractor (HECo) to ensure that
all required documentation (inspection reports) were
contained in the Unit I turnover packages in accordance
with HECo Procedure 22A is an example of a failure to
implement Criterion V of 10 CFR 50, Appendix B (454/86031-05).
(d) Failure of the electrical contractor (HECo) to establish a
system to accurately status inspection reports to preclude
inadvertent bypassing required inspections and tests is an
example of a failure to implement Criterion XIV of 10 CFR 50,
Appendix B (454/86031-06; 455/86017-05).
(e) Failure of CECO to have a proceduralized system for Byron
Construction to notify Byron Operations of deficiencies
which could potentially impact the safe operation of Unit 1
is an example of a failure to implement Criterion V of
10 CFR 50, Appendix B (454/86031-07).
(16) Concern: HECo received an FCR for a TYK connection, (this.is a
tube steel to tube steel weld). HECo was to qualify this joint
but they never prepared a WPS or anything. AWS does not have a
pre qualified procedure for a flared V weld.
NRC Review: During interviews of QC personnel regarding this
concern, the NRC inspector was provided a copy of Discrepancy
Report (DR) 8311.
The DR stated, " Weld detail DV-315 and DV-316
on drawing 1-3366F, Revision E, requires a flare V groove weld.
Hatfield has no welding procedure for this joint configuration."
The resolution to this problem was to revise the joint
configuration so that a flare V groove weld was no longer
required. This was accomplished by S&L's approval of Field
Change Request (FCR) No. F-26801 and FCR No. F-26803.
20
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_
_ _
. __
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Conclusion: Based on the NRC inspector's review, it'was
established that HECo did not have a qualified weld procedure
for flared V groove welds. However, the requirements for this
type weld was deleted by issuing FCRs F-26801 and F-26803. No
violations or deviations were identified.
(17) Concern: Welding QC inspectors were denied overtime (OT)
because their number of inspections were not up to par. Also,
'
the Level III Welding Inspector (by name) stated at a safety
meeting on May 7,1986, that there was a planned lay-off in
August and the inspectors with the most acceptable inspections
would stay. Quantity not Quality.
NRC Review: With respect to the concern that welding QC
,
l
inspectors were denied 0T because their number of inspections
were not up to par, this concern was refuted. During personnel
'
interviews, the NRC inspector was informed of OT problems in
January 1986 and was provided copies of letters on this
subject.
Overtime had been scheduled for numerous welding and
conduit inspectors on Saturday, January 25, 1986, however, 11
,
inspectors (including the alleger) failed to show up for the
scheduled overtime. The following week, when the OT schedule
i'
-was being prepared, these 11 inspectors were not asked to work
due-to their refusal to work the previous week. The QC
Supervisor had a change of. heart after some of the inspectors
apologized for their actions the previous week at about 4:00
p.m. January 31, 1986.
In that the alleger had left the site
at approximately 2:30 p.m. that day, he could not be contacted
i.
to work on Saturday, February 1,1986.
With respect to the scheduled lay-off, as a result of personnel
interviews and observing the reduction in force (RIF) schedule,
.
this concern could not be substantiated. As part of this
I
inspection, the NRC inspector obtained the HECo RIF schedule from
l
CECO. This schedule was prepared by HECo and submitted to CECO
for information. This RIF schedule has been generally adhered
'
'
to.
The exceptions to this schedule are as follows:
four
inspectors were terminated due to positive tests for drugs
,
(Reference Paragraph 5.b of this report); termination of the
QA/QC Manager, QA Supervisor, and QC Supervisor; and the
extension of employment of several inspectors. The named
Level III welding inspector stated that he had informed his
inspectors of the pending RIF, and that the RIF schedule was
'
determined by their Lead Inspector's evaluation of their
performance and attendance. This statement was confirmed during
.1
interviews of other QC personnel. The safety meeting was not
limited to welding inspectors in that the named Level III is
also the Assistant QC Supervisor. See Paragraph 5.a.(10) on
quality of inspections.
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Conclusion: Based on personnel interviews, review of HECo
letters, and the comparison of the RIF schedule with
termination dates, these concerns could not be substantiated.
See Paragraph 5.a.(10) on quality of inspections. No violations
or deviations were identified.
(18) Concern: HEco engineering sent out a clarification letter on
Detail J installations. An inspector rejected an installation
based on this letter and a discussion with an S&L engineer.
Engineering reversed their decision after thousands of
Detail Js were installed and the inspector got hell for going
to S&L.
NRC Review: During personnel interviews, the NRC inspector was
provided a copy of the subject letters and Discrepancy Report
(DR) 8320. The first letter, dated March 8, 1985, provided two
examples of acceptable Detail J (type of raceway support)
configurations and one example that wcs unacceptable. A QC
inspector contacted an S&L engineer for an interpretation on a
hanger being inspected.
In accordance with the S&L engineer,
the QC inspector described the unacceptable Detail J
configuration. The S&L engineer informed the QC inspector
that the configuration described was unacceptable. Based on his
discussion with the S&L engineer and HECo engineering letter of
March 8,1985, the QC inspector prepared DR 8320 on February 20,
1986. The DR was dispositioned "No Discrepancy as Written" with
justification.
It appears that the QC inspector confused a CS
type connection (actually installed) with an unacceptable
Detail J type connection. These two types of connections are
similar in appearance except, the CS connection is welded at
the four coraers only and the unacceptable Detail J is welded
on two sides of the plate.
DR 8320 was closed on March 3, 1986.
The second HECo letter on Detail J connections, dated April 22,
1986, states, in part, "The acceptable configurations for a
Detail J are shown on the attached sketch. Notice that the
configuration that was disallowed in the March 8, 1985, letter
has been re-analyzed by S&L structural as being acceptable."
From a safety stand point, the 1986 letter did not disallow any
configurations that were allowed in the 1985 letter. Also, the
design change was made by S&L, not HECo engineering, and is
shown on S&L drawing 6E-0-3393F.
In accordance with HECo
policy, HECo engineering interfaces with S&L engineering.
If a
HECo QC inspector has an engineering type problem, they are to
take their problem, through their Lead, to HECo engineering for
re:,ol u tion. This policy meets the intent of Criterion III of
10 CFR 50, Appendix B, which states, in part, " Measures shall
be established for the identification and control of design
interfaces. . . ."
Conclusions: HECo engineering did in fact issue two
clarification letters on Detail J configurations. The second
letter, based on an S&L analysis, allows the installation of a
previously disallowed configuration. The use of these two HECo
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engineering letters would not permit the installation of an
unacceptable Detail J configuration. DR 8320 was properly
closed. HECo interface policy with S&L is acceptable. No
violations or deviations were identified.
(19) Concern: A QC inspector (by name) prepared an NCR approximately
one year ago for cross-flange welds, blow hole (burn thru) in
the J-Box, no welding pre-heat, and welded with 6010 rod. This
J-Box is located in the cable spread room, 451' elevation, and
the cables entering this J-Box came from the screenhouse. The
NCR was dispositioned use-as-is and it shouldn't have been.
NRC Review: During a review of NCRs issued in the timeframe
specified above and interviews of QC personnel, NCR 1537, dated
June 10, 1985, was identified as the NCR of concern. This NCR
documented four cross-flange welds, use of 6010 rod and lack of
pre-heat during the installation of J-Box 704A. The J-Box was
located in the cable spread room at columns 21 and P at the
473' elevation. The S&L approved disposition stated, " Abandon
the four cross-flange welds and add new welds per FCR 70050."
'
NCR 1537 was properly closed on July 29, 1985, by the alleger.
Conclusions: This concern was not substantiated in that NCR
1537 was reworked in accordance with an S&L approved disposition
and the NCR was properly closed by the alleger.
(20) Concern: The HECo QA/QC Manager (by name) is " bird-dogging" a
QC inspector (by name). Every time the named QC inspector came
to the office to review drawings or documentation, the named
QA/QC manager would call the inspector's Lead and/or the
Assistant QC Supervisor or the QC Supervisor and inquire as
to why the named inspector was in the office again.
NRC Review: As part of the followup on this concern, the NRC
inspector reviewed the Byron SRI's notes of his interviews of
the named QC inspector and named QA/QC Manager on the
" bird-dogging" issue. The NRC inspector was unable to interview
the named QA/QC Manager, the involved QC Supervisor, and one of
the involved Lead Inspectors because they were no longer employed
by HECo. The NRC inspector interviewed co-workers and previous
supervisors of the named QC inspector and also reviewed
performance evaluations of this QC inspector. The named QC
inspector was assigned to work out of a field office some
distance from the HECo main office. All the QC inspectors and
supervisors working out of the field office had a need to go to
the main office to review " vaulted" documents. During personnel
interviews, the NRC inspector was informed that the named QC
inspector was noted for his socializing when he had to go to
the main office.
During an interview with the NRC SRI, the named
QA/QC Manager stated that he did in fact call the inspector's
superv,isor one time to verify that the inspector had a need to
be in the main office.
The QA/QC Manager also stated that he
made the call to the supervisor only after cbserving the named
P
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QC inspector in the main office every day for a week. During
an interview of the involved supervisor, he stated that the
QA/QC Manager called him several times about the named QC
inspector being in the main office.
The supervisor also stated
that in general, the inspector had a need to be in the main
office and the inspector's Lead knew the task being worked on.
The supervisor said that at times he felt that the QC inspector
would invent reasons to go to the main office just to antagonize
the QA/QC Manager. However, from a review of performance
evaluations and additional interviews, it would appear that
undue restrictions were placed on the named inspector in that
he was the only inspector that required specific approval from
his Lead Inspector to go to the main office.
Following is part
of a written statement (one of four) made by one of the named
inspector's Leads, "During the period from January 6 to April 28,
1986 (named inspector) was assigned to the Welding QC Department
under my supervision.
During this period I was directed by
(name) (QC Supervisor) and (name) (Asst. QC Supervisor) to
insure that (name) did not make unnecessary visits to the
Hatfield Main Office.
(Name) was to inform me of his reasons
for such visits to the main office.
I understand the reason
for this policy being implemented was that (name) had previously
been observed spending unnecessary time in the main office."
This written statement is typical of the four statements provided
to the inspector.
Conclusions: Based on interviews of QA/QC personnel and the
review of written statements, it appears that undue restrictions
(bird-dogging) were placed on the named inspector in that he
was the only inspector that required specific approval to go to
the HECo Main Office. However, a contributing factor appears
to be his (named inspector) excessive socializing while in the
main office and attitude toward QA/QC management.
No violations
or deviations were identified.
(21) Concern: Construction worked through a Hold Tag (NCR 1860).
The inspector could not write an NCR, instead QA wrote
Corrective Action Reports (CAR) 002 and 003.
NRC Review: During an interview with the alleger, the NRC
inspector was provided a copy of a draft NCR (NCR without a
report number assigned) and CARS 002 and 003. The draft NCR
stated that Hold Tag 1860 was attached to J-Box 2JB683A and
that construction installed conduit and cable in the J-Box in
violation of the Hold Tag. The inspector reviewed the NCRs
prepared in the same timeframe (February 1986) to verify that
the draft NCR had not been placed in the system without the
alleger's knowledge. No NCR was observed for working through
Hold Tag 1860. CAR 002 was prepared on February 17, 1986 to
document the violation of Hold Tags, with a sequence of events
attached. On February 21, 1986, CAR 002 was voided due to an
incorrect description of the concern and CAR 003 was prepared.
24
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CAR 003 not only described the violation of Hold Tag 1860
(NCR 1860), it also describes the violation of Hold Tag 1825
(NCR 1825).
CAR 003 was properly closed on March 11, 1986.
For this type of nonconformance, working through Hold Tags, the
CAR would be the most effective document in that it receives a
higher level of management review.
Conclusions:
This concern was substantiated, however, for
this type of nonconformance the CAR would be the most effective
document to identfy and resolve these violation. No violations
or deviations were identified.
(22) Concern: HECo was working through Hold Tags per direction from
CECO PCD.
NRC Review: The NRC inspector was provided a copy of a memo to
the HECo QA/QC Manager, dated January 16, 1985.
Following is a
sequence of events as described in the above referenced memo:
(a) Roughneck (Ceco's core holing contractor) was coring a 3"
hole for HEco when a rebar was hit. The HECo QC inspector
verbally stopped work and prepared NCR 1281 to document
the rebar hit.
(b) A HECo QC supervisor informed the PCD engineer that work
could not continue on the coring until HECo received a
disposition on the NCR.
(c) A Ceco PCD engineer (by name) instructed Roughneck to
continue coring the hole and that an FCR would be prepared
to allow the rebar hit.
(d) When the inspector went back to the area to attach the
Hold Tag, he observed that the core hole had been
completed.
(e) S&L issued FCR F-25836 after NCR 1281 was prepared _ without
referencing the NCR, indicating that the FCR was being
used to document a nonconforming condition.
Based on the above memo, the NRC inspector performed an indepth
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review of HECo core drilling activities.
Even though the
'
actual core drilling is performed by a different contractor,
HECo is responsible for the inspection and documentation of the
cering when tbc hele is being used for electrical installations.
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HECo Procedure 21, " Cored Hole Installation and Inspections,"
states, in part, " Paragraph 5.1.13 - No items may be installed
in a cored hole until Hatfield Electric Company receives a
completed CHR (Cored Hole Report) signed off by CECO PCD.
Paragraph 5.3.3.3 - Only cored holes in Category I structures
.
where rebar has been cut and/or hit and which are in areas
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where rebar cuts are not allowed, shall have the cut / hit
documented on a HECo NCR. The NCR number shall be referenced on
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the CHR." Paragraph 5.3.5.3 of HECo Procedure 6, " Reporting of
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Damaged or Nonconforming Material or Equipment," states, " Items
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identified as nonconforming, if not yet installed, may not be
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used or if installed, may not have additional work performed on
them unless it is authorized by the owner."
A review of HECo's NCR form indicates that the owner's
authorization to work on a nonconforming item prior to corrective
action being completed (work may proceed) requires approval by
CECO PCD with concurrence by CECO QA. During an interview with
the CECO QA Superintendent, he stated that the NRC inspector's
understanding of the HECo NCR form was correct in that " Work May
Proceed" must be approved by CECO PCD and receive concurrence
from Ceco QA. During a review of HECo NCRs, the NRC inspector
observed that when HECo prepares an NCR to document the fact
that HECo construction installed conduit in a cored hole in
violation of a " Hold Tag", the NCR would be forwarded to CECO
PCD for disposition. A typical disposition by CECO's Project
Electrical Supervisor for this type NCR is "This is not an NCR,
therefore, no C/A (Corrective Action) is required." With the
explanation that "The completed CHR, signed off by CECO PCD is
the owner's authorization to proceed with installation work."
NCRs 2056 and 1627 are two examples with the above disposition.
In addition, the inspector was provided several " draft" NCRs
(i.e., no number assigned) that were voided by the HECo QA/QC
Manager with the disposition for UCR 1627 attached.
During an
interview of the CECO PCD structural engineer (engineer that
reviews and approves CHRs), the NRC inspector received the
impression that this Engineer did not realize that his signature
was the Owner's authorization (per NCR dispositions) for HECo
to proceed with installation work when there was an open NCR on
the subject cored hole.
During a review of NCRs on cored holes versus conduit
installation reports, approximately ten instances were identified
where " Hold Tags" were violated. However these violations were
not documented based on PCD's interpretation of Owner's
authorization.
Conclusions:
Based on the NRC inspector's review as noted above,
it was established that CECO PCD (Project Electrical
Supervisor) directed HECo to violate their Procedure 6 with
respect to Owner's authorization for continued work on a
nonconforming item.
This violation appeared to be for cored
holes only.
The licensee was informed that failure to control
nonconforming item to prevent their inadvertent use is an
example of failure to implement Criterion XV of 10 CFR 50,
Appendix B (455/86017-06).
(23) Concern: HECo Project Engineer (by name) threatened to void NCR
on procedure violation.
The alleger told the Project Engineer
that he would take the NCR to the NRC if it was voided.
The
Project Engineer signed the NCR.
Example was not provided.
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NRC Review: The NRC inspector reviewed HECo Procedure 6,
" Reporting of Damaged or Nonconforming Material or Equipment,"
to determine the duties and responsibilities of the Project
Engineer with respect to NCRs.
Paragraph 5.3.3 assigns the
responsibility for preparing NCRs to HECo QA and Engineering.
During the review of NCRs, it was noted that both QA and
Engineering did, in fact, prepare NCRs.
Paragraph 5.3.4
assigns the responsibility for the completion of the deficiency
description on the Construction Deficiency Evaluation (CDE) form
and attaching this form to the NCR. Utilizing this form, the
licensee evaluates the deficiency for reportability per the
requirements of 10 CFR 50.55(e). A completed CDE form was
attached to all NCRs reviewed during this inspection.
Paragraph 5.3.6.1 assigns HECo engineer the responsibility for
completion of Part II (Corrective Action and Action to Prevent
Recurrence) of the NCR, when appropriate, prior to review by the
HECo QA/QC Manager. This is a recommended disposition only.
The final disposition is made by the licensee and/or S&L. When
the NCR comes back from the licensee, HECo engineering is
responsible for notifying the appropriate personnel of the
required " corrective action" and " action to prevent recurrence"
to be implemented. The only time the Project Engineer signs an
NCR is when he is the preparer of the NCR. During the NRC
inspector's review of hundreds of NCRs, it was observed that all
voided NCRs had been voided by the HECo QA/QC Manager.
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Conclusions: Based on the NRC inspector's review of Procedure 6
and hundreds of NCRs, this concern could not be substantiated.
No violations or deviations were identified.
(24) Concern:
Procedure 20, " Class I Exposed Conduit System
Installation," Paragraph 5.6.5, states that final inspection
of conduit terminations would be made during cable termination
inspections. This is not addressed in Procedure 11, " Class I
Cable Termination and Splicing."
NRC Review:
Paragraph 5.6.5 of Procedure 20 states, in effect,
that final inspection of conduit terminations to equipment,
except J-Boxes and Pull-Boxes, would be made during cable
termination inspections when the equipment was not installed at
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time of the conduit inspection, per Procedure 11.
Paragraph
5.1.24.1 of HECo Procedure 11 states, in part, "If a short run
of Sealtite or conduit is required to bring the cable into a
gear, Hatfield QC must be notified so that any required
,
inspections can be picked up."
This attribute is inspected
and documented on Form HP-118, " Cable Termination Inspection
Report," item 14. The NRC inspector reviewed HP118 Reports
21601 through 21850 and verified that item 14 was being
inspected by the QC inspector.
No deficiencies were
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identified.
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Conclusions: Based on the NRC inspector's review of HECo
Procedures 11 and 20, and the review of 250 Cable Termination
Inspection Reports, this concern was not substantiated.
No
violations or deviations were identified.
(25) Concern:
For Battery Rack 2DC01EA and 2EC02EA, the minimum
embed depth for CEAs (concrete expansion anchors) is four
inches.
PTL (Pittsburgh Testing Laboratory) Reports 23821 and
23820 indicated embed depths of 3 1/2" and 3 1/8". A HECo QC
inspector (by name) could not write an NCR on these two
nonconforming conditions.
NRC Review: During interviews of HECo QC and engineering
personnel and CECO QA and engineering personnel, the NRC inspector
was informed that Blount Brothers Corporation (BBC) installed
the CEAs for Battery Racks 2DC01EA and 20C02EA.
During the CAT
Inspection on August 19 through September 20, 1985 (Reference:
IE Report No. 50-455/85027), an inspector identified one CEA on
each of the subject battery racks that did not appear to meet
the minimum embed depth. As a result of this observation, PTL
was directed to inspect the CEAs for these two racks. Using
the ultrasonic test (UT) method, PTL identified one of ten CEAs
on battery rack 2DC01EA with an embed depth of 31/2". The
other nine CEAs exceeded the minimum 4" embed depth (Reference:
PTL Report 23821, dated September 10,1985). Based on this PTL
report, BBC prepared Deviation Report (DR) Q3-955 to document
the deficiency. This deficient CEA was evaluated by S&L and DR
- Q3-955 was dispositioned "use-as-is" and FCR F44367 was issued
to document the as-built conditions.
PTL also identified one of
ten CEAs on battery rack 2DC02EA with an embed depth of 31/8".
The other nine CEAs exceeded the minimum 4" embed depth
(Reference: PTL Report 23820, dated September 10,1985). This
deficiency had been previously identified on September 15, 1983,
as documented on BBC's OR Q3-725.
S&L issued FCR F-43535, dated
May 29, 1984, to accept the CEA (DR Q3-725) in the as-found
condition. Based on the licensee's actions, this item was
closed in the CAT Report 455/85027, Paragraph II.B.3.b.(5).
Based on the CAT report and the NRC inspector's review of the
PTL reports, BBC DRs, and S&L FCRs discussed above, the NRC
inspector determined that there was no need for HECo to prepare
an NCR to identify the same nonconforming issues.
Conciustoas: Based on the NRC CAT inspection report and the
NRC inspector's review of the applicable documents referenced
above, it was concluded that there was no need for HECo to
prepare an NCR or tne two CEAs that did not meet the minimum
embed depth. No violations or deviations were identified.
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(26) Concern: There are no weld travelers listed for conduit hanger
WP2-1 on hanger inspection report (Form HP-203) number 1021.
Two Detail J's are not welded to the hanger and the AP
attachment is no good.
NRC Review: Utilizing the WANG (computerized tracking system),
it was determined that no weld travelers were listed for hanger
WP2-1.
During a review of inspection report 1021, the NRC
inspector observed that hangers TS-1, WP2-1, SWCP3-3, and
SWCP3-4 had been inspected to drawing 0-3302A and were found
acceptable on May 4, 1982. A review of the applicable drawing
indicated that these hangers were located in the Auxiliary
Building, Columns 15 and L, 346' elevation. During a physical
inspection of conduit hanger WP2-1, the NRC inspector observed
that the two Detail J's (steel plates) were not attached (welded)
to the hanger and tbc AP connection was not installed per the
design drawing and that hanger WP2-1 supports conduits C0A0203
and C0A0204.
In that hangers / supports are also verified during
conduit inspections, the inspector reviewed Conduit (C0A0203)
Inspection Checklist 928, dated May 5,1982 and Conduit (C0A0204)
Inspection Checklist 929, dated May 5,1982. During the review,
both of these checklists (928 and 929), the supports were checked
as acceptable and hanger inspection Report 1021 was referenced,
and both reports were signed off as being acceptable.
During
electrical cable installation, a pre pull inspection is performed
on the applicable raceway and this inspection is documented in
Part 1 of the Cable Installation Inspection Checklist
(Form HP-105) (Reference: HECo Procedure 10).
From applicable
records, the NRC inspector determined that cable 2SX031-P1E was
installed in conduit C0A0204 and cable 2SX032-CIE was installed
in conduit C0A0203. A review of Cable Installation Inspection
Checklist for cable 2SX032 indicated that the raceway was
acceptable, and the cable was released for pull on October 13,
1982. Cable 2SX032 was installed on November 8, 1982. A
review of Cable Installation Checklist for cable 2SX031 has
conduit (Part 1, Item B) marked as "N/A", however, Page 3 of 3
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of this checklist listed conduits C0A09E5 and C0A0204 for cable
routing points. The checklist for cable 2SX031 indicated that
the cable was released for installation and installed on April 27,
1984. On July 30, 1986, the licensee prepared NCR 2059 on hanger
WP2-1 to document the as-found condition. The issuance of this
NCR should result in the correction of the problems found with
hanger WP2-1.
Corclusions: This concern was substantiated in that a physical
inspection of hanger WP2-1 revealed two detail J connections were
not welded and the AP attachment was not in its designed location.
Also, using the WANG, it was determined that a weld traveler had
not been prepared for hanger WP2-1, listed on drawing 0-3302A.
The licensee was informed that failure to assure that measures
,
were established to promptly identify and correct conditicns
adverse to quality is an example of a failure to implement
Criterion XVI of 10 CFR 50, Appendix B (455/86017-07A).
<
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(27) Concern: There are no conduit inspection reports (Form HP-201)
for conduits C0A32K8-C2E, C0A2265-K2E, C0A0282-P2E and
NRC Review:
During interviews of HECo QC and engineering
personnel and review of applicable records, the NRC inspector
established that the conduits noted above were installed in
Byron Unit 1.
Utilizing the WANG system, it was also established
that conduit inspection reports (Form HP-201) for the subject
conduits did not exist. The licensee determined that the subject
conduits did not need to be reinspected to HECo's routine
inspection program (Procedure 20) in that they had been inspected
and accepted under the licensee's as-built inspection program.
Conclusions: The HP201 forms had not been prepared to document
the inspection and acceptance of conduit C0A32K8, C0A2265,
C0A0282 and C0A0283, however, these conduits had been
subsequently inspected and accepted under the licensee's as-built
inspection program. No violations or deviations were identified.
(28) Concern: Nonconformance reports (NCR) are typically
dispositioned "use-as-is."
Think there should be more rework
or repeir dispositions.
Corrective action to prevent recurrence
is not effective or not adequate (Reference: HEco memo 1866)).
Poor disposition on NCR 1581.
NRC Review: The NRC inspector reviewed all HECo NCRs prepared
between June 1,1985 and June 8,1986. The NRC inspector also
reviewed HECo Procedure 6, " Reporting of Damaged or Nonconforming
Material or Equipment." In that most of the items requiring
rework / repair are documented on Inspection Reports (IR) or
Discrepancy Reports (DR), the NCR is generally reserved for
deficiencies that HECo is requesting an analysis for a "use-as-is"
disposition. The NRC inspector reviewed the NCRs for proper
closure with respect to corrective action and action to prevent
recurrence. During the review, the NRC inspector selected
approximately 30 NCRs for review of analyses at the S&L onsite
facilities. All analyses reviewed at S&L were found to be
adequate.
During the review of NCR 1990, it was observed that Pin Connector
Termination Tool W-002 had been sent to Burndy for repair and
calibration. Tool W-002 was received back onsite in calibration,
however, Burndy failed to record the as-found condition, thus
making the quality of the termination crimps made since the
previous acceptable calibration indeterminate. During the review
of the tool checkout log and inspection reports, HECo determined
that Tool W-002 had been utilized on 16 plug connectors since
the previous calibration. The NCR (1990) was dispositioned
" Accept crimps as is. The last 16 inspections were done in
proces; and the crim;. tool's calibration date had not been
reached when the tool was in use."
This disposition was approved
by a CECO PCD engineer without considering that all documentation
from Burndy indicated that the tool had been repaired. After
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the NRC inspector expressed a concern with the disposition of
NCR 1990, the licensee obtained the tool acceptance criteria
from Burndy.
From the HECo inspection reports, the last usage
of the tool was identified. Using the information from Burndy,
the licensee measured the termination crimp indents and found
them acceptable. This reinspection resolved the inspector's
concern with the acceptability of the crimps made with
Tool W-002.
HECo NCR 1581 and CECO NCR F-997 documented the improper use
of Kellem type cable grips (Detail G) that was specified for
use in the Auxiliary Electrical Equipment Room only and was
used in other areas of the plant.
S&L issued FCR F-6665 to
allow the use of Detail G cable grips in all areas of the
plant. S&L drawing 6E-0-3393P was revised to incorporate this
FCR.
CECO NCR F-997 was properly closed on November 22, 1985,
based on the issucce of FCR F-6665 and the training of HECo
crt.f t personnel . 3ECo NCR 1581 was properly closed on
December 3, 1985, based on the closure of CECO NCR F-997.
On May 23, 1985, a training session with craft personnel was
conducted due to the number of nonconformances being identified
by HECo QC inspectors. Topics covered included installation
requirements; drawings; S&L standards; HECo procedures; and the
requirement to obtain prior written approval before making any
deviations. HECo QA/QC Memorandum 1866 was prepared to
document this training and states, in part, "This training
session covers training required per ' Action to Prevent
<
Recurrence' for any NCR's written on work completed prior to
May 23, 1985." During the review of NCRs, Memorandum 1866 was
referenced on numerous NCRs, however, no misuse of the memorandum
was observed.
With respect to " Action to Prevent Recurrence," during the
review of NCRs, the inspector observed 12 instances where NCRs
were improperly closed before action to prevent recurrence had
been completed.
(Reference: NCRs 1772, 1758, 1754, 1798, 1787,
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1783, 1825, 1822, 1818, 1816, 1815, and 1802) Based on the
NRC inspector's concern, HECo QA performed a review of NCRs and
identified 38 NCRs that were improperly closed before action to
prevent recurrence had been completed.
In addition, CECO QA
Audit 6-86-201 identified that the instruction / retraining required
as part of the action to prevent recurrence had not taken place
until, in some cases, nine months after the NCR was prepared.
This resulted in additional NCRs being prepared on the same type
problems involving the same personnel.
Conclusions: A review of NCR 1581 indicated that the disposition
'
was adequate based on S&L analysis and the issuance of FCR F-6665.
,
For the NCRs reviewed, with one exception, the NRC inspector
found the "use-as-is" disposition acceptable.
For NCR 1990, it
was identified that there was inadequate justification for the
31
.
_
_ _
_
_
- .
.
_
__.
"use-as-is" disposition until additional tests were performed.
During the review of Action to Prevent Recurrence, the NRC
inspector identified 12 NCRs that were closed before action to
prevent recurrence was completed. The licensee also identified
that in many cases the action to prevent recurrence was not
effective due to the time interval between the preparation of
the NCR and the implementation of the required retraining.
The licensee was informed that failure to assure that corrective
action to prevent recurrence was completed prior to closing the
NCR was an example of a failure to implement Criterion XVI of
10 CFR 50, Appendix B (455/86017-078).
(29) Concern: The trend analysis as performed by HECo QA does not
prove anything.
NRC Review: During a review of NCRs discussed in. Paragraph
5.a(28) above, the NRC inspector performed a " bean count" of the
NCRs prepared during the fourth quarter 1985 for comparison to
the trend analysis performed by HECo QA. The NRC inspector
determined that 104 NCRs were prepared and 12 of these NCRs were
written on concrete expansion anchor (CEA) installation problems.
A review of the HECo trend analysis indicated that none of the
12 NCRs on CEAs were trended and only 6 of 104 total NCRs
prepared during the fourth quarter were trended.
A review of DRs for the fourth quarter 1985 revealed that '!36
DRs had been prepared. When compared to the HECo trend analysis,
only 37 of the 236 total DRs prepared during the fourth quarter
were trended.
During interviews of the HECo QA personnel responsible for the
trend analysis, the NRC inspector was informed that if the physical
work activity was not performed during the subject quarter, the
NCR/DR was not counted for trending purposes in that quarter.
The NRC inspector was also informed that HECo does not perform
a running (complete) trend analysis;
i.e., include two or more
i
l
quarters in the trend analysis performed each quarter.
During
!
interviews with the HECo QA/QC Manager, the NRC inspector was
l
informed that during the fourth quarter of 1985, HECo QC had a
1
60-90 day backlog of inspections and presently (June 1986), the
backlog was down to 30 days and for practical purposes this is
considered current with work activities. When the QA personnel
were asked if the previous quarter trend analysis was revised to
reflect the additional NCRs/DRs identified, their reply was no.
In summary, when HECo QA performed the fourth quarter trend
analysis, 94% of the NCRs and 84% of the DRs were discarded from
the trending population. Under ideal conditions (30 day backlog),
approximately 33% of the pertinent data would not be included
in the trend analysis.
/
32
1
t
Conclusions: This concern was substantiated in that prior to
performing the trend analysis, HECo QA discarded up to 95% of
the pertinent data needed to perform the analysis.
(30) Concern: We had problems with the welds on DV88 and DV89 type
connections. There are 456 in Unit I and 542 in Unit 2.
CECO
QA Audit 6-84-309 caused the reinspection of 58 DV88 and DV89
connectors that had been reworked by HECo. Why wasn't a larger
sample taken? Also, Page 2 of 2 of HECo's response to Audit
6-84-309 is missing from Ceco's file copy of this audit. A
copy of HEco QA/QC Memorandum 1405 was provided.
NRC Review:
HECo QC inspectors identified undersized welds
on electrical raceway hangers as supplied by Systems Control.
These undersized welds were documented on HECo NCR 461. The
NCR disposition directed HEco to add additional welds to 58
DV88 and DV89 connectors with undersized welds. During CECO
QA Audit 6-84-309, a cracked weld was identified on one of the
hangers repaired by HECo. HECo was directed to visually
reinspect the 58 hangers and identify any welds that had crack
indications. The reinspection identified ten potentially
cracked welds, six were accepted by PTL using the magnetic
particle (MT) method of nondestructive examination (NDE). The
remaining four welds were repaired by HECo per NCRs 1062, 1065,
1066, and 1067 and subsequently accepted by PTL, using the MT
method. CECO NCR F885 was prepared to document potential
undersized welds on DV88 and DV89 type connectors supplied by
Systems Control.
Based on statistical guidelines, an additional
60 hangers were inspected and weld maps prepared. Based on worst
case analysis, S&L was able to accept these hangers with
undersized welds. The weld deficiencies identified by CECO on
items supplied by Systems Control were closely monitored by the
NRC (see NRC Inspection Reports 454/84031, 455/84024, 454/84032,
455/84025, 454/84050, 455/84034, 454/84071, and 455/84049).
The NRC inspector's review of QA Audit 6-84-309 revealed that
the corrective actions and corrective action to prevent
recurrence were agreed to during the audit and were documented in
the audit report.
Therefore, no HEco response to the audit was
required. Memorandum 1405, dated July 18, 1984, is from a HECo
Level II welding inspector to the HEco QA/QC Manager. This
memorandum documents, in summary form, the results of HECo's
and PTL's reinspection of the DV-88 and DV-89 hanger connections.
The inspector could not find any evidence that the HECo QA/QC
Manager had ever transmitted this memcrandum to CECO. Hcwever,
,
Memorandum 1405 was found in the HECo vaulted records file.
In
that the applicable QA/QC Manager was no longer employed by HECo,
he was not interviewed in reference to this memo.
.
33
_ _ _ _ _ . -
- . -
. -
.
._ __.
Conclusions: This concern could not be substantiated in that
-additional hangers were reinspected per CECO'NCR F885~and an
analysis was performed by S&L. -In addition, the welding
problems. identified on items supplied by Systems Control were
closely monitored by NRC inspectors. No HECo response to
Ceco QA Audit 6-84-309 was required and the inspector could
find no' evidence that HEco QA/QC Memorandum 1405 was ever
transmitted to CECO. Therefore, there was no requirement for
HEco QA/QC Memorandum 1405 to be placed in the CECO audit file.
No violations or deviations were identified.
(31) Concern:
In Unit 1 on the west face of Q wall, 426'
elevation, Area 5, a DR was prepared for a cover being left
off of a J-Box. Was the cover replaced and the DR closed?
NRC Review: Using the applicable Unit 1 drawing, it was
determined that the concern could apply to.any one of three
J-Boxes that are installed in the area described. .Using the
WANG system, it was identified that DR3282 had been written
against J-Box IJB1737A. A review of DR3282 indicated that it
had been prepared on October 5, 1983, for a missing J-Box
cover.~ The cover was replaced and DR 3282 was closed on
October 18, 1983.
Conclusions: DR 3282 documented the missing cover on J-Box
1JB1737A. The J-Box cover was replaced and the DR closed. No
violations or deviations were identified.
.(32) Concern:
Rebars were cut in a non-safety-related man-hole-(MH)
during the cutting of a cored hole.
The FCR stated that no
rebar.was to be cut. HECo could not write an NCR on these cut
rebars.
For non-safety-related walls, HECo has no way to report
cut. rebar. This happened in approximately January 1986.
NRC Review: The NRC inspector reviewed all Cored Hole Reports
[
prepared between January 1 and March 31, 1986. No reports were
identified for a non-safety-related MH. The inspector reviewed
'
Cored Hole Reports prepared between October 1 and December 31,
1985. This review found that Report 85-10-26, dated October 24,
1985, documented rebar cuts in MH 2B. This report also referenced
HECo NCR 1738. A review of the NCR revealed that two vertical
'
!
rebars vere cut on the south face of MH 2B and FCR 26571 only
t
permitted one rebcr to be cut.
The information contained in
(
the NCR was analyzed by S&L and the NCR was dispositioned
"use-as-is."
During interviews with CECO and S&L personnel, the
!
NRC inspector was informed that ali Cored Hole Reports are
,
routed to S&L. "Rebar cuts" or "no rebar cuts" are documented
L
on the cored hole reports, so that even though a rebar is cut
in a non-safety-related wall / floor and e.n NCR is not prepared
'
(which is typical) S&L would be aware of any/no rebar cuts.
'
.
Except upon request, QC does not inspect non-safety-related
!
!
34
1
- . _ . _ . _ . . _ _ . _ _ _ _ . _ ~ _ _ . _ _ _ - . _ . _ _ _ - _ . _ , - _ _ . _ -
_ . . _ , _ . - -
_
_
_
_
installations, therefore, NCRs are not normally prepared on
non-safety-related items. During the review of Cored Hole
Reports, non-safety-related MH 28 Report 85-10-26 was the only
report identified that fits the description of the concern.
Conclusions: This concern was refuted in that NCR 1738 had
been prepared to document cut rebars, in MH 28, even though
an NCR was not required. No violations or deviations were
identified.
(33) Concern:
PTL rejected concrete expansion anchor (CEA)
installations for Category II (non-safety-related) equipment
inside Containment 2 for spacing and edge distance. NCR 2017
was preparea to document the rejected CEAs however, it was
cancelled.
NRC Review: A review of HECo NCR 2017, dated May 9, 1986,
indicated that this NCR had been cancelled. The description of
the nonconforming condition indicated a CEA edge distance
violation only. A review of PTL CEA Inspection Report 24673,
<
on the same installation, found that the violation was for edge
distance only and S&L had dispositioned the PTL report "use-as-is"
on March 28, 1986 (Approximately 42 days before NCR 2017 had been
prepared).
In that the edge distance violations had been
previously addressed by S&L, the NRC inspector concurs with the
4
cancelling of NCR 2017.
Conclusions: The CEA edge distance violation identified on
PTL Report 24673 had been satisfactorily addressed by S&L,
therefore, a HECo NCR was not required. No violations or
deviations were identified.
(34) Concern: The ceiling is leaking in the feedwater tunnel,
causing pitting of the conduits. Conduit segregation code is
K2R (safety-related instrumentation conduit).
See conduit
inspection reports (Form 201) 5780 and 5978.
In accordance
with the HECo Project Engineer, this deficiency is not within
HECo's scope of work.
NRC Review: The NRC inspector performed a physical inspection
of the feedwater tunnel.
During this insoection it was observed
that at some point in time, the ceiling had, in fact, been
leaking. However, the licensee had taken appropriate action to
seal the leaking ceiling. An inspection of the conduit in the
,
area of the leaks snowed a deposit that appeared to be calcite.
'
'
Upon removal of the deposit, no pitting of ti e conduit was
observed.
In that the ceiling had been repaired (sealed), it
was apparent that CECO was aware of the leak, therefore, no
HECo NCR/DR was required.
Conclusions: A physical inspection of the feedwater tunnel
indicated that the ceiling leak had been repaired and the
leakage caused no detrimertal effects on the conduit. No
violations or deviations were identified.
35
-
_
-
_.-
.-.
-
. _ _ _ _ _
_ - - - . -. -
-.
(35) Concern: White out was used on NCR 1759. also changes were made
on NCRs 1759, 1766, 1775, 1802, and 1825 that were initialed
but not dated.
NRC Review: HEco NCRs are typed by the clerks and during the
preparation of NCR 1759, it appears that the letter "S" on one
word was retyped. A correction fluid had not been used. When
reviewing a copy of this NCR, it appears that a correction fluid
(white out) may have been used, which, in the NRC inspector's
opinion, resulted in this concern. With respect to the changes
on NCRs 1759, 1766, 1776, 1802, and 1825, they were made by an
individual with the intitials "R.A.B." and was not dated.
These NCRs were corrected during this inspection and from the
number of NCRs reviewed during this inspection, it appeared
that these were isolated instances.
Conclusions: Correction fluid had not been used on NCR 1759,
however, it appears that the clerk typed over/ retyped the
letter "S" in one word. Changes had been made, initialed but
not dated on NCRs 1759, 1766, 1775, 1802 and 1825. These NCRs
were corrected during the inspection. Based on the number of
NCRs reviewed during this inspection, these errors are considered
isolated instances and no further action is required.
(36) Concern: Wrong FCR numbers are referenced on core hole inspection
reports 26884, 26887, 26890 and 26891.
NRC Review: During the review of core hole reports, the NCR
inspector could not identify any reports with the numbers
provided by the alleger. The NRC inspector was informed that the
series of numbers provided appeared to be FCR numbers.
Using
the FCR log, it was confirmed that the numbers provided were, in
fact, FCRs issued for cored holes.
The log also provided a
cross-index to the Core Hole Inspection Report (CHIR) number.
During a review of the FCRs and the inspection reports, the
following observations were made:
CHIR 86-04-02 referenced FCR F26984 and on June 15, 1986,
this FCR number was corrected to read F26884.
CHIR 86-04-03 referenced FCR F26897 and on June 15, 1986,
this FCR number was corrected to read F26887.
'
FCR F26884 was superseded by FCR F26890 (after the hold
was cored) which abandoned the hole because it was not
needed.
FCR F26884 was identified as being superseded.
FCR F26891 deleted one 3" hole and added two 3" holes.
This FCR was correctly listed on CDRs 2052 and 2054.
,
i
36
' Conclusions: CHIRs 86-04-02 and 86-04-03 referenced an
incorrect FCR number, however, they had been corrected prior to
the NRC inspector's review.
FCRs F26890 and F26891 were listed
correctly on the applicable reports. No violations or
deviations were identified.
(37) Concern:
Cable installation Report 9877 incorporated an FCR
before it was issued.
NRC Review: A review of cable installation report 9877, revealed
that the cables were released for pull on February 17, 1986, and
that FCR F26763 was referenced on the report. This FCR was
issued on February 14, 1986, to change the cable from type 01599
to type 01646. This cable type change affected cables 2AR189,
191, 193, 195, 252, 253, 258, 259, 266, and 267. A comparison
of the cables listed on the FCR and on Report 9877 indicated
that there were one or more additional cable installation
reports affected by the FCR. Additional research revealed that
Report 9878 was the other report within the scope of the FCR.
A review of cable installation report 9878 indicated that the
cables were also released for pull on February 17, 1986.
Conclusions:
FCR F26763 was issued three days before the
affected cables were released for pull as indicated on cable
installation reports 9877 and 9878. This concern was therefore
not substantiated.
No violations or deviations were identified.
(38) Concern: We only inspect for minimum torque valves (Note 5,
,
Drawing 0-3000L, Sheet 1, Revision L). During operations the
vibration could pop the boltheads off if they were overtorqued.
NRC Review:
Bolt torque valves are specified in order to
preload the bolts for high cycle fatigue, shear connection or
locking considerations. Of these three reasons, only high cycle
fatigue has critical requirements for minimum and maximum bolt
preload values. The other two considerations, which are
basically static load cases, really only have a minimum preload
requirement.
For most static bolting applications, if the bolt
does not break during the initial torque-down, then it should
not break during service. This is because during installation
the bolt must withstand the induced tensile force as well as
the applied torque. The tensile and shear stresses resulting
from these two forces are approximately the same under normal
conditions.
Since the ultimate shear stresses are about half of
the ultimate stresses, the biaxial state of stress will be
overall one of the most highly stressed conditions for the
bolt. Once the bolt is installed, the residual torsional
stresses disappear due to slight frictional slippages after the
torque is removed. Once this torsional stress component is
,
37
removed, the available tensile capacity above the preload value
increases significantly. As long as the applied load is less
than the bolt preload, the increased tensile stress should be
less than the bolt capacity and therefore, never fail.
(Reference: Mechanical Engineering Design, Shigley, J. E. c
1977, Third Edition.)
Conclusions: Although dynamic loads are considered for this
bolting application, there are no high cyclic fatigue
+
concerns. On this basic, maximum torque valves need not be
considered during installation.
The concern in therefore
unsubstantiated.
(39) Concern: There are no weld traveler cards for Units 1 and 2
riser collars.
c
NRC Review: A riser collar is a type of raceway support used to
support vertically mounted cable tray (risers) and is shaped like
a collar. Riser collars are installed at floor penetrations.
Weld travelers (WT) had been prepared for riser collar welds,
however, due to the lack of unique identification, WTs could not
be traced to a given weld or series of weld on a given riser
collar.
On January 26, 1986, HECo QC prepared DR 8314 to document that
WTs for 17 safety-related and non-safety-related Unit 2 welded
riser collars could not be found.
New WTs were prepared, the
welds were inspected, and the DR was closed on March 17, 1986.
On February 28, 1986, DR 8444 was prepared to document additional
i
missing WTs for Unit 2 riser collars having welded connections.
As a result of this DR, 136 WTs were prepared and the welds were
inspected. As a result 96 were rejected for various deficiencies.
These deficiencies were transferred to NCR 2073, dated September 9,
1986, and DR 8444 was closed on September 15, 1986, based on the
preparation of the NCR. With respect to Unit 2, HECo identified
the problem of missing WTs and corrective action was in process
before the allegers concern was received.
With respect to the missing Unit I riser collar WTs, it appears
that the licensee was aware of the problem in the same time
frame that HECo DR 8314 was prepared, on January 29, 1986. On
February 14, 1986, CECO QA performed Surveillance No. 7898 on
missing WTs for Unit 2 riser collar welds which resulted in
l
HECo DR 8444 being issed on February 28, 1986.
From interviews
'
of CECO QA and engineering personnel and review of records, the
NRC inspector could not identify any actions taken by HECo or
the licensee to identify and document (NCR, DR, etc.) the
missing WTs for Unit I riser collar welds. On June 9, 1986,
while investigating this concern on the missing WTs, the NRC
inspector expressed a concern regarding the lack of licensee
action to document the missing WTs on Unit I riser collar welds.
On June 20, 1986, Project Instruction (PI)-BB-106 was issued for
38
.--
.
_ - __.
_
_-
- - - .
. .
-Tt
<
q,
i
I.
l\\
!
'
L ' 'l
'
s<
1
L
}
'
,
,
the inspection of Unit I riser collar welds.
Gom June 23 to
,
.
June 25,' 1986, a S&L Level III weld inspector inspect.ed 50 of
,
-
the! approximate'ly 150 Unit 1 and common riser collar welds. Per
.
' -
an S&L (R. J. Netzel) to CECO (R. E. Querio) letter dated
'
July 29, 1986, an engineering evaluation was performe.1 o, Unit i
s
riser collar walds based on results from the S&L inspecb!cn.
S&L's evaluation of the discrepancies based onja worse mase
,
i
analysis, determined that the riser collar welds are within
'
o
s
the allowable stress limits., However, one case was identified
4
<
s
where the as-found yeld condition was less than the detign
V
drawing requirements.4 This riser collar is located on~ elevation
439, l'5" south of column line 10 and 10'9" west of column line
.
L, as shown on drawing.6E-1-3061. These riser collar welds were
repaired and accepted by HECo on September 16, 1986, as documented
,
on Nuclear Work Request (NWR) 6EG018.
-
Conclusions: This concern was substantiated. However, for-
Unit 2, HECo had identified the problem of missing WTs for
'
riser collar welds on DR 8314 and DR 8444 and corrective action
was in-process before this coacern was identified to the NRC.
With respect to missiag WTs for Unit I riser collar welds, it
i
.appears that the licensee became sware of the missing Unit 1
WTs in the January to February 1986. However, th? licensee
.
failed to take any corrective actioris until the NRC inspector
expressed his concern on June 9, 1986.
'
The licensee was inforced that:
.(
r
(a) Failure to assure'~that conditions adverse to quality were
'
'
promptly identified and corrected is an exanple of a
failure :to implement Criterion XVI of 10 CFR 50, Appendix B
(454/86031-04B).
,
,
i
s
(40) Concern: .The disposition on DR 8350 is not correct. An HP-7A
(Rewat Requast) should have been inithted.
v
NRC Review: A review of DR 8350 identifled the discrepancy as
" cable 2FW216 was determinated to terminate cable 2FW230 on the
same terminals without an HP7A form being prepared. This is in
s
.
violation to Procedures 7 and 7A."
The disposition on the OR
stated, in effect, "that procedures were not violated and the DR
was written in error." The DR referenced various paragraphs
s.
\\
from HEco Procedures 7, " Electrical Design Changes" and 7A,
y
" Rework Control."' The NRC inspector reviewed HECo Procedures 7
and 7A.
Procedure 7' describes the actions to be taken by HECo
1'
when a desiqn change is received.
In that the discrepancy noted
'
'
j
was not a design change, crocedure 7 was listed in error on the
l
DR.
Procedure 7A, Paragraph 2 d , states, in part, "The scope
of this procedure includes the revisions to installed work
>
required by design change or removal and reinstallatica of-
previously installed work . . . ." Paragraph 2.4 of
j
Procedure 7A states, in part, "The scope does not include
i
the remaval of wire or cable conductor terminations in order
,
k
,
'
39
s
- s
y
i-
. -
~
.-
.
>
to terminate additional wires or cable conductors on the same
point ...." During the review of Cable Termination Inspection
Report 21586 fcr cable 2FW230, it was noted.that the termination
inspection was performed "in process", indicating that a QC
inspector had observed the determination an'd re-termination of
cable 2FW216. Based on the NRC inspector's review of
Procedures 7 and 7A, DR 8350, and inspection report 22586, the
NRC inspector concurs with the HECo engineer that the DR did
not describe any violation of procedures.
"
Conclusions: DR 8350, as writtenp did not describe a procedure
violation.
In addition, a certified HECo QC inspector did in
fact perform an in process _ inspection of cable terminations. .No
violations or deviations were fdentified.
(41) Concern: There are bad resolutions on DRs 8339 and 8426.
In
addition, "use-as-is" DRs should have been documented on NCRs.
NRC Review: The NRC inspector reviewed approximately 300 prs,
including DRs 8339 and 8426, for proper closure.
Following
are the results of this review:
'
DR 8339 - Documented screws and terminal points have
corrosion on them and 3" sealtite outer jacket is pulled
out of the connector in panel 2VA-04J. A CECO PCD engineer
dispositioned this DR "use-as-is" with an explanation,
however, "use-as-is" dispositions require design engineer's
approval;
i.e., S&L or Westinahouse.
During a physical
inspection of Panel 2VA-04J, the NRC inspector determined
that the observed corrosion was not detrimental to the
operation of the equipment. No discrepancies were
observed with the sealtite jacket.
DR 8426 - Documented 2 1/2 pages of discrepancies or
potential discrepancies that were identified during a 100%
inspection of Panel 2PS47J prior to turnover to the
licensee. All discrepancies identified on this DR were
" accepted-as-is" by a Ceco PCD engineer. A typical
disposition was "ok" or "all ok."
Several of the potential
discrepancies were " terminal lugs landed backwards - Can't
check." To verify the acceptance of these lugs, the lugs
'
would have to be determinated for inspection. When
questioned by the NRC inspector, the PCD engineer stated
that the lugs were not determinated for inspection but were
accepted ("use-as-is") based on his knowledge of like
terminations.
From the interview, the inspector
determined that no physical corrective actions were taken
before the discrepancies were' accepted; 1.e., dispostioned
"use-as-is".
i
40
i
.
/
+.
DR 8501 - Documented that Class I (safety-related) cables
2RC437, 2RC422, 2RC419, and 2RC440 were pulled without QC
<
being present. NCR 1992, dated April 17, 1986, was
prepared to document this procedure violation. This NCR
was dispositioned "use-as-is" by a CECO PCD engineer
without design engineer's approval. DR 8501 was closed
based on " Resolution Implementation Documented on: (HECo
QA) Special Surveillance #13-86 and NCR 1992." During a.
review of HECo QA vaulted Surveillance Reports, the NRC
irspector could not locate Special Surveillance #13-86.
During personnel interviews, the NRC inspector was informed
by a HECo QA engineer that Special Surveillance #13-86 had
not been issued.
DR 8504 - Documented that cable installation inspection
report 8790 was issued for the removal and reinsta11ation
of safety-related cable 2MS518.
Report 8790 only documented
the removal of the cable.
There is no documentation for the
reinstalls. tion of the cable. This DR was dispositioned
"use-as-is" by.the HECo QA Supervisor and final reviewed
and accepted by the same Supervisor on May 20, 1986. This
disposition was not approved by the design engineer.
DR 8534 - Documents miscellaneous discrepancies, (including
lack of cable tension data during the pull), with two cable
cable installatior, inspection reports (9991 and 9992). The
inspector who originally witnessed the cable pull was no
longer employed in HECo QC. The inspection reports could
not be closed because no one knowns the circumstances of
each cable installation. This DR was dispositioned
"use-as-is" by HEco engineering.
The "use-as-is" disposition
i
was not approved by the design engineer.
'
DR 8049 - Documented that conouit fittings are loose at
2PSL-DG0878 and 2PS-DG094B. These conduits were acceptable
as installed, based on a memorandum from a CECO PCD engineer.
This memorandum stated, "Above installations are acceptable
as installed. HECo should close their DR. Conduit cannot
become looser. Byron Station can tighten connector during
a future calibration." This disposition was not approved
by a design engineer.
CECO QA Audit 6-86-201, that was conducted as a result of NRC
concerns, also reviewed the HECo DR program.
This audit states,
in part, "A review of 356 DR's which were closed during the
aforementioned period verified that HECo Engineering / Production
had properly dispositioned the identified concerns in 205
'
instances. An additional 50 DR's were elevated to NCR's for
resolution by the Owner. However, 101 DR's were either dispo-
sitioned by PCD as acceptable per an attached speed memo or
were d,ispositioned as acceptable per PCD without a clear basis
for the inspection Llements acceptability.
'
>
's
1
41
.
.
-
.
- - - -
..
-
During the course of the audit, minor concerns were identified
which related to the processing and/or closecut of DR's.
However, the instances were unrelated and were submitted to
HECo QA for resolution.
In general, the HECo DR program was
found to be acceptably implemented with the exception of its
trending process."
Conclusions: The NRC inspector's review of HECo's DR program
revealed that DRs were being dispositioned "use-as-is" by HECo
QA, HECo Engineering, and CECO PCD Engineers without the con-
currence of the design engineer and/or without a clearly
documented basis for the closure of the DR.
The licensee was informed that:
(a) Failure to assure that design changes were subject to
design control measures commensurate with those applied to
the original design is an example of a failure to
implement Criterion III of 10 CFR 50, Appendix B
(455/86017-028).
(b) Failure to assure that conditions adverse to quality are
identified and corrected and the cause of the condition is
determined and corrective action taken to preclude repetition
is an example of a failure to implement Criterion XVI of
10 CFR 50, Appendix B (455/86017-07C).
(42) Concern: Cables were pulled with a " mares tail" (non-metallic
basket weave cable pulling device) in the steam tunnel at twice
the maximum allowable cable pulling tension. This happened
9-12 months ago and no NCR was prepared.
NRC Review: A review of cable pull records and interviews of
HECo QC and engineering personnel revealed that the concern
related to a bulk cable pull involving 16 cables. These
cables were being pulled from J-Box 2JB101A through conduits
C2A-4115, C2A-0141, C2A-0104, C2A-0501 and C2A-0595 to J-Box
2JB031A. These 16 cables were being pulled with a " mares tail"
and a pulling tension of 1600 pounds was recorded.
S&L
Standard EA-121 limits the maxinum pulling tension to 1000
pounds when using a basket weave cable pulling device. This
violation was documented on DR 7884 which was subsequently
up graded to HECo NCR 1682 on September 5, 1985. To transmit
this information to S&L for analysis, CECO prepared NCR F-1011,
dated September 13, 1985.
In an S&L letter dated September 18,
1985, S&L transmitted Ceco NCR F-1011 to the Okonite Company
(cable manufacture) for their review and analysis. On October 7,
1985, S&L transmitted additional information to Okonite per their
request. The Okonite Company responded in a letter to S&L on
October 9, stating that, " based on their evaluation of the
information provided, the cables in question are acceptable for
,
42
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use in their intended application."
In an S&L to CECO letter on
November 5, 1985, S&L provided their concurrence with an " accept
as-is" disposition on CECO NCR F-1011.
Personnel involved were
re-trained in the 1000 pound pulling tension limitation when
using a basket weave cable pulling device.
CECO NCR F-1011 was
closed on November 26, 1985 and HECo NCR 1682 was closed on
December 3, 1985.
Conclusions: This concern was not substantiated in that both
HECo and CECO prepared NCRs on the over tensioning of cables
being pulled with a " mares tail". These NCRs were properly
analyzed, dispositioned, and closed. No violations or
deviations were identified.
(43) Concern: The cable pull training requirements for QC inspector
(by name) were lowered so he could be certified. He never
observed a Class IE (safety-related) cable pull before he was
certified.
NRC Review: ANSI N45.2.6-1978, " Qualification of Inspection,
Examination, and Testing Personnel for Nuclear Power Plants,"
Subsection 2.2 states, "The capabilities of a candidate for
certification shall be initially determined by a suitable
evaluation of the candidate's education, experience, training,
test results, or capability demonstration."
In accordance with
Table 1 of N45.2.6, the discipline Level III inspector is
responsible for evaluating each candidate for certification and
determining the minimum training, if any, required prior to
certification. This training may consist of formal training
(classroom) or on-the-job training (0JT) or a combination of
both. HECo Procedure 17, " Qualification and Training of
Inspection and Audit Personnel," basically reiterated N45.2.6
for evaluation and training of QC inspectors. The NRC inspector
reviewed the training and certification records package for the
named individual.
For cable pull and terminations, the Level
III evaluation indicated that the individual required nine hours
of formal training and 40 hc9rs of OJT. A review of the documented
training (cable pull and tenninations) indicated that the named
individual had received 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of formal training and 45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br />
of OJT.
In that HECo utilized the same procedures for safety-
related and non-safety-related work activities (for QC inspections
are not performed on non-safety-related work), therefore it is
acceptable to train and test QC personnel on non-safety-related
work activities.
In the case of the named individual, his 0JT
was on four safety-related and two non-safety-related cable pulls.
Due to the lack of safety-related cable pulls, the named
individual's practical test was given on a non-safety-related
cable pull. The NRC inspector reviewed the written test (closed
book) taken by the named individual for Level II certification.
A minimum of 80% is required on the written tests and the named
individual had a passing grade of 84.5%.
43
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&
Conclusions:
In that the named QC inspector had been evaluated
by HECo's Level III inspector, and minimum training requirements
established, the individual met the qualification and certifica-
tion requirements of ANSI N45.2.6 and HEco's Procedure 17, this
concern was not substantiated. No violations or deviations were
identified.
(44) Concern:
In electrical panels 2PA09 and 2PA10, there is bare
vendor wire showing and this has been accepted.
NRC Review: The NRC inspector and a CECO QA electrical engineer
performed independent inspections of panels 2PA09 and 2PA10
located in the Auxiliary Electrical Equipment Room. No discre-
pancies were identified with vendor or HECo installations.
Conclusions: Based on a physical inspection of panels 2PA09
and 2PA10, this concern was not substantiated. No violations
or deviations were identified.
(45) Concern:
The CECO PCD Project Electrical Supervisor directed
HECo on how to perform QC inspections. This occurred during a
training session prior to the butt splice reinspection. QC was
directed to accept exposed copeer beyond the lug insulation.
NRC Review: As a result of a 1984 NRC concern (see IE
Inspection Reports 454/84027; 455/84019), the licensee performed
a reinspection of accessible butt splices in Units 1 ar.d 2.
This reinspection program, including the training session
4
alluded to by the alleger, was closely monitored by two NRC
inspectors (See NRC Inspection Reports 455/84029; 455/84021).
The subject training session was conducted by the Project
Electrical Supervisor on May 24, 1984 and was attended by NRC
inspectors.
For butt splices that were to be covered with
'
Raychem heat-shrink tubing or tape, it was permissible to have
,
exposed copper beyond the lug insulation in that the exposed
copper would be covered in the final product. This action was
acceptable to the NRC.
In addition, the licensee had notified
the NRC of this problem via a 10 CFR 50.55(e) report
(455/84003-EE; 455/84003-EE). This 50.55(e) report was
addressed in IE Inspection Reports 454/84055; 455/84038. An
open item pertaining to the butt splice reinspection program
is also addressed in IE Inspection Report 454/84072; 455/84050.
Conclusions: This concern was substantiated, however, the
exposed copper that extended beyond the lug insulation was
being appropriately covered with heat-shrink tubing or tape.
The entire butt splice reinspection program was monitored and
accepted by NRC inspectors. No violations or deviations were
identified.
(46) Concern: The HEco QA/QC Manager (by name) pre-dated and
back-dated inspection reports, also, QC inspector (by name)
back-dated equipment modification reports (Form 12A).
44
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NRC Review: -The NRC inspector reviewed several hundred
[
~
inspection report and did not observe the named QA/QC Manager's
'
name on any reports. -A review of personnel qualification files
revealed that this individual was not certified in any area by
HECo. During interviews'of HECo QA/QC personnel, the NRC
inspector was informed that. they (the interviewees) were not
aware of .the named QA/QC Manager pre-dating or back-dating any
documents and were not aware of him approving / signing any
inspection reports. The inspector was unable to interview this
individual in that his employment with HECo was terminated
July 2, 1986.
With respect to the named QC inspector, it was established
through personnel interviews and review of records that this
QC inspector back-dated his " review" of Class 1 Equipment
Modification Inspection Requests (Form HP-12A-1).
In accordance
with HECo procedures and inspection report forms, the QC
inspector that performed the inspection, signs, dates and enters
his/her certification level (Level I,'II or III) at the bottom
of the report. This report is then " reviewed" by an additional
QC inspector certified Level II or III. When inspection reports
reach the QC office from the field, they are given to the QC
4
clerks. The QC clerks then formally transmit these reports to
,
the appropriate Lead QC inspector for their review. After the
reports have been reviewed, they are returned to the clerks for
filing. At the time of filing, the clerk enters the inspection
!
date and the date filed in a permanent log.
1
Modification inspection reports 6132 through 6137 were received
by the QC clerk from the field on August 10 or 11, 1984, and
transmitted to the Lead Inspector on August 13, 1984. When
these reports were received for filing, all had a " review" date
of March 21, 1984. All the QC inspectors and the lead inspector
_
involved with these inspection reports have not been employed by
I~
HEco for some time.
In that the involved personnel are no
longer employed by HECo and the " review" function did not change
or modify the inspection results, no additional followup is
planned.
>
j
Conclusions: The named QA/QC Manager had not signed any
.
inspection reports and none of the QA/QC personnel interviewed
!
were aware of any documents that he pre-dated or back-dated.
!
Records indicated that the named QC inspector back-dated his
review of modification reports 6132 through 6137. The review
function did not change or modify the inspection results and
l
does not have any impact on quality of the item inspected.
!
(47) Concern: Certification and records packages were missing from
the vault. Craft personnel need to be recertified every six
'.
months on cable terminations.
Some of the craft were
i
recert,1fied without any backup data,
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NRC Review: A review of HECo Procedure 11, " Class 1 Cable
Termination and Splicing," revealed that Paragraph 5.9.2
" requires an in process QC inspection of each terminator's
work at least once every six months for the terminator to
maintain his/her qualifications." A log is maintained for each
terminator and lists the QC inspector's name that performed
the in process inspection, termination report number and date.
The NRC inspector selected five terminators for a review of their
maintenance of qualifications.
During this review, the
,
following observations were made:
Terminator 4069 (individual's Brass Number) - Two reports
were listed as in process inspections when in fact they
were not.
If an inspection was performed in process, it
is so noted on the inspection report. During a review of
termination inspection report 14610, it was noted that the
termination was made on December 3, 1984, and the inspection
was conducted on December 19, 1984. Also, termination
inspection report 22757, dated March 7, 1986, was not
identified as being an in process inspection. These errors
did not affect the terminator's qualifications in that valid
in process inspections were on file for the applicable six
month periods.
Terminator 4193 - Termination inspection report 2165 was
also listed in error in the log for this terminator in that
the termination was made on December 10, 1985 and inspected
December 11, 1985; not in process inspected.
Valid
in process inspections for November 1985 and January 1986
were also on file and this error did not affect the termi-
nator's qualifications.
Terminator 3320 - Termination Report 15278 was listed in
the log for this terminator, however, the report was
missing from the HEC 0 Records Vault. A review of the
Termintaion Report Log reve led that reports 15270 through
15275 and 15277 through 15285 had been " thrown away by DG
5/16/86."
During interviews of HECo QA/QC personnel, the NRC inspector was
informed that for terminators to maintain their qualifications,
they were permitted to make " test booth" terminations with a QC
inspector present.
These " test booth" termination inspections
were documented on termination reports 15270 through 15275 and
15277 through 15285. Under current HECo procedures, all documents
are reviewed by HEco QA prior to being vaulted. When these
reports were transmitted to QA for their review, a QA engineer
showed the reports to a QA/QC clerk and informed her that the QA
Supervisor said that these reports were not needed and threw
them in the clerk's trash can. After the QA engineer left
the area, the clerk retrieved the reports from the trash can
and stored them in her desk. The clerk could not " vault" these
records because they had not been reviewed by HECo QA. To
46
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account for the termination report numbers, the clerk noted in
the Termination Report Log that these reports had been " thrown
away by DG."
After the NRC inspector expressed his concern with
the discarded reports they were retrieved by the clerk and were
again transmitted to HECo QA for review. After QA completed
their review, termination inspection reports 15270 through 15275
and 15277 through 15285 were returned to the QA/QC clerks and
properly filed in the HEco Records Vault.
During interviews of QA/QC personnel, the NRC inspector was
informed that during the 1982-1983 time frame, a named QA
Supervisor removed certain QC inspector's (by name) certification
records from the inspector's vaulted files. These missing
certifications were discovered after this QA Supervisor terminated
his employment with HECo on November 14, 1983. The named
individual's records were subsequently corrected by using the
master list of personnel certifications and copies of records
retained by the individual QC inspectors. On August 5, 1986,
the NRC inspector reviewed approximately ten inspector's files
and compared the certifications with the master list.
In
addition, the NRC inspector queried the named inspectors still
employed by HECo as to their area of certifications and compared
their responses with the master list of their certifications.
No discrepancies were identified.
Conclusians: Through personnel interviews, the NRC inspector
determined that certification records had been removed from
personnel files by a QA Supervisor during the 1982-1983 time
frame.
However, the inspectors' certification record files had
been corrected prior to the NRC involvement in this concern.
The review of termination inspection records that support the
recertification of craft terminators revealed that several
inspection reports were missing from the HECo records vault.
The termination inspection report log indicated that reports
15270 through 15275 and 15277 through 15285 had been " thrown
away" by the HECo QA Supervisor on May 16, 1986. This was
verified by a QA/QC clerk and a QA engineer. However, the
clerk had removed the termination reports from the trash can
and stored them in her desk. After the NRC expressed concerns
in this matter, the termination reports were retrieved from the
clerks desk, reviewed by HECo QA and subsequently filed in the
HECo records vault.
The licensee was informed that failure to assure that sufficient
records are maintained to furnish evidence of qualification of
personnel (craft terminators) is an example of a failure to
implement Criterion XVII of 10 CFR 50, Appendix B (454/86031-08;
455/86017-08).
(48) Concern: When HECo craft personnel perform work activities
under the direction of CECO OAD, this work was not always
inspected by HECo QC.
47
NRC Review: A review of Unit 1 Cable Termination Inspection
Reports (Paragraph 5.a. (47) above) revealed that several
inspection reports associated with NWR 6EG006 were marked N/A
(not applicable) for all inspection attributes. A note on
these reports stated, " Work performed under 0AD direction. No
inspection required per XXXXX (named CECO PCD electrical
engineer). The following are examples identified during this
review:
Report 21105, dated November 25, 1985, Class 1E equipment
1FWO6JB. All inspection attributes were marked N/A with
the above listed note.
Rework Request (Form HP-7A-1) 7963
was referenced on termination report 21105. The work
description on this Rework Request stated, "F1d, to
replace existing SIS wire W/Rockbestos SIS wire as
required in 1FWO6JA, JB and JC per PCD."
SIS wire is a
type of single conductor wire used in switchgear, motor
control centers, panels, and valve operators. The NRC
inspector was informed that the existing SIS wire was not
qualified and it was being replaced with qualified
Rockbestos SIS wire.
Reports 21106, 21113, 21114, 21119, 21120, 21115, 21116,
21102, 21103 and 21117 were all similar to termination
inspection report 21105, except they applied to different
items of equipment and rework request numbers. The work
description on the rework request were similar to Rework
Request 7963, except they applied to different items of
equipment.
During interviews of QA/QC personnel, the NRC inspector was
provided a copy of open HEco Cable Termination Inspection Report
19980, dated July 3, 1986. This report documented that the red
conductor on cable 2RH033-P2E was butt spliced and the splice
covered with heat-shrink tubing. This butt splice work activity
was inspected in process by a CECO 0AD engineer and was
documented on HECo termination report 19980. However, this OAD
engineer was not certified to HECo's termination and splicing
procedure. This discrepancy had been previously identified by
HECo QC and is being corrected under HECo's open inspection
report (0IR) program.
In that the butt splice is covered with
heat-shrink tubing and cannot be inspected, the butt splice must
be replaced with HECo QC performing an in process inspection of
the work activity.
,
48
1
,
Conclusions: During a review of cable termination inspection
reports, the NRC inspector identified 11 reports where no
inspections were conducted during the replacement of unqualified
SIS type wire. This wire was replaced in various Unit 1 items
of Class 1E (safety-related) equipment. The required QC
inspections were not conducted per the directions of a CECO PCD
electrical engineer.
00e instance was identified where an in process termination / splice
inapection was performed by an un-certified CECO OAD engineer.
However, this discrepancy had been previously identified by
I!ECo QC and corrective action was being implemented.
The licensee was informed that failure to assure that
inspection activities are executed to verify conformance to
documented instructions (NWR 6EG006) is an example of a failure
to implement Criterion X of 10 CFR 50, Appendix B (454/86031-09).
(49) Concern: DR 8160 was prepared for a Procedure 7A violation.
The DR was rejected about two months ago. The same type of
situation arose with an NWR and the HECo Project Engineer stated
at that time that a Rework Request (Form 7A-1) was required.
Both these situations involved 8' flex conduit. NWR log in the
conduit trailer (remote office) should indicate the 7A number.
NRC Review: DR 8160, dated January 7, 1986, identified the
following, discrepancy " Conduit C2A4201 has 7' 8 1/2" of flex
installed per FCR 26570.
This work was accomplished after the
^
original 6' 0" flex was installed per CIR (conduit inspection
report) 8534. The above mentioned work was accomplished without
initiating a 7A-1 (Form 7A-1, Rework Request) and in violation
of Procedure 7A, Revision 1."
The resolution on this DR states,
in part, "This item is not in the scope of 7A per section 2.3.
The CIR 8534 stated the sealtite was not connected to the
equipment at the time it was turned in."
The NRC inspector verified that the flex conduit had not been
inspected and accepted on Conduit Installation Report 8534,
dated February 21, 1985. After instrument 2PT-0937 was installed
(termination point for conduit C2A4201 flex), S&L authorized the
,
installation of a 8' maximum flex conduit by issuing FCR 26579
on September 11, 1985. A 7' 81/2" flex was installed, terminated,
inspected and accepted on September 17, 1985, as documented on
Inspection Report 19604.
OR 8160 was properly closed on March 11,
1986.
In addition, Paragraph 2.3 of Procedure 7A, " Rework Control,"
states, "The scope does not include reinspection of reworked
appurtenances. This shall be construed as installation work
and shall be inspected in accordance with the appropriate
installation procedure."
A review of the NWR log indicated that the alleger was alluding
to NWR-6VC092, dated February 17, 1985, and Rework Request
i
(Form 7A-1) 5412, dated March 18, 1985. A review of these
documents indicated that PECN P-40 was issued on January 21,
49
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1985 to install HVAC " Bubble Tight" dampers. This required a
conduit modification. An NWR (6VC092) was issued in February to
repair the flex conduit.
In that a Rework Request was required
to complete the conduit modification per the PECN, the flex
repair was included on Rework Request 5412.
Conclusions: DR 8160 and Rework Request 5412 described two
different situations. DR 8160 discussed the replacement of
flex conduit per an FCR prior to the inspection and acceptance
of the originally installed flex conduit.
Rework Request 5412
discussed the modification of a previously accepted conduit
system per an PECN and the repair of the attached flex conduit
per an NWR.
In both instances, the work activity was properly
performed, inspected and accepted.
No violations or deviations
were identified.
(50) Concern: A Detail J connection was installed and accepted on
WT (weld traveler) 79929. Conduit Inspection Checklist 4736
rejected the detail. The Detail J was cut down and reinstalled
without a rework request. DR 8485 was prepared, however, this
DR was rejected.
NRC Review: A review of HECo Procedure 6, " Reporting of
Damaged or Nonconforming Material or Equipment" and Procedure
7A, " Rework Control" revealed the following:
Procedure 7A states, in part, "The scope (of this
procedure) does not include any rework required as a result
of initial quality control inspections. The scope
includes the revisions to installed work required by
design change or removal and reinstallation of previously
installed work when directed by HECo engineering and/or
the owner."
Procedure 6 states, in part, " Items discovered to be
deficient during routine surveillance or inspection
activities shall not be considered a nonconformance.
These deficiencies shall be tracked thru the use of open
inspection reports provided, the deficiency does not
affect any work previously accepted. Deficient items
which are not identified for correction and tracked thru
the use of open inspection reports, will be brought to the
attention of the appropriate supervisor for evaluation.
Supervisors shall write DRs (Discrepancy Reports) as
appropriate. based upon their evaluation."
A review of WT 79929 revealed that the welding on hanger SCC-1
had been inspected and accepted. Also, Conduit Inspection
Checklist 4736, dated October 21, 1985, rejected the Detail J
connection on initial inspection because of incorrect location.
DR 8485, dated April 28, 1986, was prepared to document the
removal and reinsta11ation of the Detail J without a Rework
Request. The resolution on DR 8485 states, "that the
discrepancy is not within the scope of Procedure 7A and can be
50
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repaired / reworked under HECo's 0IR program". A stated in the
various procedure paragraphs above, the discrepancy was not
within the scope of Procedure 7A in that the-location violation
'
was identified during initial conduit inspection. Also, the
Detail J could not be reworked / repaired under the OIR program in
that the welding had been accepted on a weld traveler.
In-
accordance with-HEco procedures, the appropriate document to
rework / repair the Detail J connections on. hanger SCC-1 would be
a DR or an NCR (DRs can be upgraded to an NCR). During the
rework of hanger SCC-1, a new WT (81221) was generated for the-
new welds which were inspected and accepted, and attributes
including configuration and location were reinspected and
accepted on Conduit Inspection Checklist 4736.
In summary, it
would appear that there was an in adequate understanding of
procedure requirements prior to preparing the DR and the
engineer provided a partially correct resolution. As documented
throughout this report, the inspector reviewed numerous DRs
and inspection reports and this was the only violation of this
type identified.
Conclusions: A-hanger was reworked under the OIR program when
a DR/NCR should have been prepared. DR 8485 was written
without an adequate understanding of the nonconformance/ rework
process. The resolution on DR 8485 was partially correct in
that the rework was not in the scope of Procedure 7A. However,
the resolution incorrectly implies that the hanger could be
reworked under the OIR program.
This is considered an isolated
programmatic deficiency with no hardware impact.
(51) Concern: Rework requests, at times, lack clarity of work to be
performed and work performed.
Rework Request 07510'is a good
example. Cables and flex conduit were determinated, what
authorized their reinstallation? Also, why wasn't a 201 form
(conduit inspection checklist) issued to inspect the
re-terminated conduit?
NRC Review: The rework description on Rework Request 07510
states, "Determ cables and seal tites (flex conduit) a valve
10G-057A." This rework was completed on November 1, 1985. There
were no work instructions on this rework request to indicate
that the cables and flex conduit were to be re-terminated.
However, Rework Request 07510 documents the re-termination of
cables 10G093, 10G092 and 10G123, and their associated flex
conduits on November 5, 1985. The re-termination of the flex
conduits is documented on Cable Termination Inspection Reports
20766, 20767, and 20768 (Attribute 14), therefore, a separate
Form 201 would not be required for the flex conduit termination.
Rework Request 8854, dated February 18, 1986,- is another example
of an inadequate work description.
In this case, the rework-
was to determinate cable 2FW870 and pull the cable back to a
defined point.
Rework Request 8854 also indicated that cable
2FW870 was re pulled, re-terminated, and re-inspected, which
was outside the scope of the rework description. The NRC
51
inspector selected one file folder of rework requests from 1985
and one from 1986 for review. As a result of this review,
Rework Requests 6957, 6967, 9006, 9017, 9018 and 9055 were also
identified as having an inadequate work description which
resulted in work being performed that was outside the scope of
the work request. -All HECo rework requests are approved by
CECO PCD engineers and in some cases, the request is initiated
by a CECO PCD engineer. The NRC inspector's concerns with these
rework requests were discussed with HEco and CECO PCD engineers.
Following the NRC inspector's meeting with these engineers,
they have made a concentrated effort to ensure that the work
description adequately defines the work activities that need to
be performed. The NRC inspector reviewed the September 1986
rework requests and did not identify any additional violations,
indicating that corrective action was adequate.
Conclusions: The NRC inspector confirmed that there were
inadequate work descriptions on rework requests (eight examples
were identified) which resulted in work being performed without
adequate instructions. A review of cable termination inspection
report associated with rework request 97510 revealed that
attribute 14 documents the inspection of the reterminated
flex conduits and a separate conduit inspection was not
-
required.
The licensee was informed that failure to assure that activities
affecting quality are prescribed by documented instructions and
accomplished in accordance with these instructions is an
example of a failure to implement of Criterion V of 10 CFR 50,
Appendix B (455/86017-09A).
(52) Concern: Do not think CECO's audit of HECo on cored holes was
properly closed.
This audit was performed mid-1985 by a (named)
CECO QA engineer.
NRC Review: The NRC inspector reviewed all audits of HECo
performed by this CECO QA engineer and determined that this
concern related to CECO QA Audit 6-85-150 or Audit 6-85-152.
CECO QA Audit Report 6-85-150, dated May 26, 1986, documented
that Concrete Core Drilling Requests were reviewed to verify
.
that the cored holes were inspected by HECo QC prior to conduit
installation. HECo QC had indicated that there had been a
'
problem in the field with conduit being installed prior to the
QC inspection of the cored hole. The audit also revealed that
HECo had identified this deficiency on Special Surveillance 85-15,
an additional review was deferred to allow HECo time to implement
corrective action. A review of CECO QA Audit Report 6-85-152,
dated October 11, 1985, indicated that CECO QA verified that HEco
52
____
-
-
-
_
. _ .
.
.
-
had implemented corrective action and action to prevent recurrence
for the deficiencies identified in HECo's Special Surveillance
85-15.
This verification was made by CECO QA's review of NCRs,
cored hole reports, training records and procedure implementation
dates. The NRC inspector's review of Audit Report 6-85-152,
including audit backup data, indicated that the audit was
adequate to close the concern on cored holes.
Conclusions: The NRC inspector reviewed CECO QA Audit Reports
No. 6-85-150 and 6-85-152 and determined that these audit reports
were properly closed.
No violations or deviations were identified.
(53) Concern: No one is preparing a rework request for fire proofing
when items such as pull sleeves, tray covers, and J-Box covers
are removed or disassembled so Transco can install fireproofing
material. Without a rework request, HECo QC does not know when
to reverify reinsta11ation of pull sleeves, covers, etc.
NRC Review: A review of rework requests (Form HP-7A-1),
'
determined that 7A-1 forms were prepared if the fireproofing
was identified on a Nuclear Work Request (NWR); required the
removal of cable tray siderails; and required the removal of
a raceway hanger.
Rework requests were not being prepared for removal / replacement
.
of items such as J-Box and cable tray covers, and pull sleeves.
During interviews with HECo and Transco QC personnel, the NRC
inspector was informed that neither ccmpany was verifying the
reinstallation of these items after fireproofing. During the
inspection, the licensee initiated an interface agreement
'
between HECo and Transco to assure that all items were returned
to their designed conditions upon completion of fireproofing
work activities.
To verify past work activities, CECO QA
initiated a surveillance program. As of October 2, 1986, CECO
QA identified several discrepancies with the installation of
flex conduit.
However, it could not be deternined if these
discrepancies were the result of fireproofing or construction
activities.
Conclusions: The NRC inspector verified that when a rework
request was not prepared for fireproofing activities (For
.
examples; removal of J-Box and cable tray covers, disassembly
of pull sleeves and flex conduit), these items were not
reinspected by HECo or Transco after the fireproofing was
completed. During the inspection, the licensee initiated an
interface agreement between HECo and Transco to ensure that
all future items would be reinspected after fireproofing work
activities had been completed. CECO QA has initiated a
surveillance program on past work activities to ensure that
affected items were returned to their designed condition after
fireproofing was completed.
53
. - .
.- -
. -
. - .
-_
_-_
.
-
-.
---.
.-
The licensee was informed that failure to assure that activities
affecting quality are prescribed by documented instructions and
. accomplished in accordance with these instructions is an
example of a failure to implement Criterion V of 10 CFR 50,
Appendix B (455/86017-098).
(54) Concern: HECo does~not have a Level III Electrical QC
Inspector. Who certifies QC inspectors?
NRC Review: The NRC inspector reviewed HECo's list of QA/QC
personnel _ certifications and observed that a qualified individual
(by name) had been properly certified Level III in all HECo QC
procedures on August 3, 1984.
In order to verify that HECo
QA/QC personnel were qualified and properly certified, the NRC
inspector selected 16 individuals for review.
Following are the
results of this review:
The QA/QC Manager and QC Supervisor not certified to any
HECo procedures.
In that these two individuals were not
performing any inspections, there is no requirement that
they be certified.
The QA Supervisor was certified as a Lead Auditor on March 4,
1985.
In reviewing this individuals certification (Form
HP-177), the NRC inspector noted that the audit participation
(five audits within last three years prior to
certification) did not meet the requirements of HEco
Procedure 17, " Qualification and Training of Inspection
and Audit Personnel," Paragraph 5.5.8.3.
A review of the remaining individuals records revealed
that in several cases, the individual was certified
without or before the Level III inspector's approval.
As a result of the inspector's concern, HEco QA performed
several Special Surveillances in this area.
Following are the results of the Special Surveillances
performed by HECo QA:
Special Surveillance Report (SSR) 16-86 identified a QA
engineer that was certified as a Lead Auditor that did not
meet the requirements of Paragraph 5.5.8.3 of Procedure 17.
This was in addition to the QA Supervisor identified by
the NRC. Corrective action was to withdraw the individuals
lead auditor certification.
As a result of SSRs 21-86 and 22-86, NCR 2057, dated July
25, 1986, was prepared to document that 16 individuals
were certified without prior approval of the Level III
inspector as required by Paragraph 4.2 of Procedure 17.
54
-_ .
-
. .
_ _ _ _ . .
_ _ _ __ _ _ _._ . _ ._ _ _ _- _
_
.
1
c
A review of HECo Procedure 17 determined that this procedure
'
met ANSI N45.2.6-1978, " Qualification of Inspection, Examination,
and Testing Personnel for Nuclear Power Plants," for qualifica-
,
tion and certification of QC inspectors and ANSI N454.2.23-1978,
'
" Qualification of Quality Assurance Program Audit Personnel for
Nuclear Power Plants," for qualification and certification of
Auditor and Lead Auditor personnel.
!
Conclusions: The NRC inspector verified that HECo has a
qualified and certified Level III Electrical QC Inspector on
staff. This individual was certified Level III in all HECo
2-
- procedures on August 3, 1984. However, a review of QA/QC
certifications by the NRC inspector and HECo QA identified that
L
18 individuals (16 QC and 2 QA) were not qualified and/or
l
certified in accordance with HECo Procedure 17.
!
The licensee was informed that failure to assure that QA/QC
i:
personnel were properly qualified and certified is an example
j-
of failure to-implement of Criterion II of 10 CFR 50, Appendix B
(454/86031-14B; 455/86017-14B).
.
l
(55) Concern:
Cable pulling and rework was done on the back shift.
Least experienced QC inspectors were assigned to the back shift
j
with no supervision.
l
.NRC Review:
From interviews of QC personnel and review of records,
it was established that the increase in second shift (back-shift)
3
i
QC personnel occurred in approximately February 1985. The
second shift nucleus consisted of a foreman (QC Lead Inspector)
c
j
and four QC inspectors. This QC nucleus was supplemented by
-
additional inspectors on an as-needed basis. A review of the
experience level of the four QC inspectors assigned to second
i
shift indicates that inspector "A" was initially certified on
i
October 15, 1982; inspector "B" on December 18, 1981; inspector
I
"C" on June 24, 1982; and inspector "D" on December 18, 1981.
!
All four inspectors were qualified and certified in four or more
i
areas, and in addition,~they were all journeymen electricians.
The foreman was certified in six areas of inspection. The
.
i
foreman was not certified in cable pulling, cable termination,
i
Class 1 equipment installation, and cable pan and pan hanger
!
installation although the personnel he was supervising were
certified in these areas of inspection. However, ther is no
l
requirement that a supervisor be certified'in all areas of
?
inspection. Also see Paragraph 5.a(14) above for another
!
example where a supervisor was not certified in the areas he was
i
supervising.
i
l"
Conclusions: The experience of the QC inspectors on second
shift exceeded two years per inspector, in addition, all the
i
inspectors were journeymen electricians. The QC foreman on
- -
second, shift was not certified in all areas of inspection,
l
however, there are no requirements for a supervisor to be
!
certified in all areas that he is supervising.
No violations
or' deviations were ioentified.
55
i
t
mm,-<--<,mo,,,,o--
,-m-.,v-nw-,-mw --
w.~+
--.-.--.---+we.-.
-..e+
,.e.--+-<.e.---e.-,.---,--.
- - - - - -
(56) Concern:
During the spring of 1983, Energy Incorporated
audited HEco on Procedures 9A, 99, and 9C. This has been
referred to as the " Black Book Audit." During this audit,
approximately 70 of approximately 1200 hangers were hand picked
for review. The sample was too small and 80-90 QC identified
discrepancies went away as a result of this audit.
NRC Review: A review of HEco procedures indicated that
Procedure 9A is for " Class 1 Cable Pan Hanger Installation";
Procedure 98 is for " Class 1 Cable Pan Installation"; and
Procedure 9C is for " Class 1 Cable Pan Cover Installation."
Energy Incorporated (EI) is under contract to HECo to perform
periodic management audits of HECo at the Byron Station and to
supply a limited number of QA/QC personnel to supplement the
HECo QA/QC Department. The NRC inspector reviewed EI audits of
HEco.
The NRC inspector was unable to identify an audit that
fits the description of this concern. The only audit, that the
inspector could identify, that approached the alleger's concern
was CECO QA 6-84-309. This CECO QA Audit is discussed in
Paragraph 5.a(30) above. The alleger stated that 80-90 deficiencies
went away as a result of the alleged audit. With this concern
in mind, the NRC inspector reviewed the NCR and DR logs and
selected NCRs and DRs (HECo DR system was implemented May 1982).
The NRC inspector was unable to identify any group of NCRs and
DRs relating to pan hangers that were closed in a relatively
short time frame. There were several major HEco and CECO NCRs
prepared that caused a large reinspection effort of cable pan
hangers (HECo NCRs 407, 407R, 540, and 1235 and CECO NCRs F-786
and F-961). These reinspection efforts were monitored by NRC
inspectors, (Inspection Report numbers are listed below). As
a result of an NRC team inspection at the Byron Station (See
NRC Inspection Report 454/82005; 455/82004) a major reinspection
was initiated.
In the case of HECo, the NRC SRI selected 20%
of HECo's QC inspectors (by name) for a reinspection of their
inspections performed during the first 90 days after their
certification.
Due to the construction effort in that time
frame, a large percentage of the reinspection activity was
concentrated on cable tray hangers.
The following is a partial
listing of NRC Inspection Reports that documents NRC's review
of the CECO reinspection program (This list is not complete in
that the inspector did not perform a 100% review of all 1982,
1983, 1984, and 1985 reports for Byron Station):
Unit 1
Unit 2
454/82017
455/82012
454/83037
455/83029
454/83048
455/83037
454/84013
455/83048
454/84027
455/84009
454/84047
455/84019
454/85,069
455/84041
455/84047
56
The above listed NRC Inspection Reports provide a status and a
final acceptance of the CECO Reinspection Program, which included
cable tray hangers and appeared to be the allegers prime concern.
Conclusions: This concern could not be substantiated in that
the NRC inspector could not identify any audits that came close
to the allegers description that were preformed by Energy
Incorporated. A major reinspection program had been conducted
at Byron Station by the licensee. This reinspection program
included cable pan hangers. This reinspection program was
inspected and accepted by the NRC. No violations or deviations
were identified.
(57) Concern: The alleger questioned the quality of the welds in
Unit 1.
Review HECo NCRs 540 and 1235.
NRC Review: HECo NCR 540 was initiated due to defective welds
in Units 1 and 2.
To facilitate the timely closure of the NCR
for Unit 1, the Unit 2 deficiencies were removed from NCR 540
and documented in HECo NCR 1235.
Both of thee HECo's NCRs were
transferred to CECO's NCRs F-786 and F-961 respectively. The CECO
NCRs were necessary to facilitate a review and dispositioned of
the NCRs by S&L. These NCRs were a part of CECO's reinspection
program which was monitored and accepted by the NRC.
See
Paragraph 5.a(56) above for additional details. In addition, a
NRC Welding /NDE inspector stated in the Byron ASLB Hearings that
he had personally inspected thousands of HECo welds and had found
them acceptable.
Conclusions: The CECO reinspection effort resolved the
deficiencies documented in HEco NCRs 540 and 1235. The NRC
monitored and accepted this reinspection program. The NRC also
performed additional inspection of HECo welds and found them
acceptable.
No violations or deviations were identified.
(58) Concern: Under Procedure 7A, if a hanger is relocated, the
welds may not be reinspected.
NRC Review:
The NRC inspector reviewed Procedure 7A, " Rework
Control." This procedure defines rework as "the removal and
reinstallation of previously installed work." Paragraph 5.4
states, "All work shall be performed to the current revision of
,
the installa.:on documents";
i.e.,
if cable pulling is involved,
use Procedure 10 or if welding is involved, use Procedure 13
series. Paragraph 5.8.2 requires that "an advance copy of all
safety-related rework requests be provided to HEco QA/QC."
Paragraph 5.13 requires " notification of HECo QA/QC when the
work is complete." All inspection reports are listed on the
rework request. An independent review for acceptability is made
by HECo QC with a quarterly surveillance by HEco QA.
In addition,
HECo engineering reviews the rework request and provides a copy
a
to CECO PCD for their review.
Procedure 13AA, " Class 1 Shielded
Metal Arc Welding," Paragraph 5.15 requires "a weld traveler
)
57
card (WTC) to be prepared for all welds." If the weld is
safety-related, a QC weld inspector must inspect and complete
Section III of the WTC in accordance with Paragraph 5.15 of
-
Procedure 13AA, and Procedure 13AE, " Class 1 Visual Weld
Examination Procedure." The WTC number is listed on the rework
'
request.
In addition, the WTC number is also listed on the
conduit support checklist or cable pan hanger checklist, as
applicable.
The NRC inspector selected 100 rework requests for
review.
In all cases where welding was required, a WTC number
was listed.
Using the WTC number and the WANG, the inspector
was able to identify the welder's ID, date welded, weld inspector,
date inspected, item number, drawing number, and the rework
request number was listed in the comment column.
Conclusions:
Based on the NRC inspector's review of procedures,
rework requests, inspection reports, and WANG printout of WTC
numbers requested, this concern is refuted in that no missed
inspections were identified. No violations or deviations were
identified.
(59) Concern: Hanger 15HV-1 has a " slugged-up" welds and no NCR or
DR was prepared. This hanger is located at 364' elevation, at
columns L and 15.
NRC Review:
From the column lines and elevation provided,
the NRC inspector determined that hanger 15HV-1 was shown
on S&L drawing 0-3099H01, Revision AA.
From this drawing, it
was determined that the exact location of hanger 15HV-1 was
l'9" south of 16 line and 2' west of L line. Using the WANG,
it was determined that HECo NCR 1220, dated November 27, 1984,
was prepared by the alleger to document a " slugged weld" on
hanger 15HV-1. A slugged weld is a weld with excessive fit-up
gap and the welder will place pieces of weld rod in the gap and
weld over top of the rod. This type of welded joint does not
develop the required strength and is therefore unacceptable.
.
The slugged weld was removed and the joint was rewelded and
i
inspected as documented on WTC 75377 and on NCR 1220.
In
addition, the welder was retrained, and the NCR was properly
closed on June 24, 1985.
Conclusions: This concern was not substantiated in that
NCR 1220 had been prepared on hanger 15HV-1 for a slugged
weld. The weld was repaired and the NCR properly closed.
No violations or deviations were identified.
(60) Concern: There are 8-10 discrepancies on the Unit 1 AF system
l.
battery racks.
Do not think they will meet seismic
l
i
s
l
l
\\
58
l
l
_ - ,
..
- -
. _ _
_
. . .
-
-
.
- -
. . - - . . -
- - - . .
_ , - _ _ _ .
requirements and no NCR or DR was prepared on these racks. The
battery racks are located at 383' elevation, at columns L and
19.
NRC Review:
From the equipment list, it was determined that
the AF (Auxiliary Feedwater) system batteries, including racks,
were assigned equipment numbers IAF01EA and 2AF01EB. A review
of the records for this equipment revealed that DR 8094 was
prepared by the alleger to document the fact that battery racks
2AF01EA and 2AE01EB were not installed per detail 801 on S&L
drawing 0-3391H. This DR was subsequently upgraded to NCR 1734,
dated October 24, 1985, which was forwarded to Ceco /S&L for
disposition. After performing an analysis, S&L issued ECN
(Engineering Change Notice) 30487 to document the as-built
condition of the subject battery racks and NCR 1734 was
dispositioned "use-as-is."
NCR 1734 was properly closed on
May 23, 1986. Based on the NRC inspector's review, the S&L
analysis was found acceptable.
Conclusions: The discrepancies identified on AF system battery
racks 2AF01EA and 2AF01EB were documented on DR 8094 which was
subsequently upgraded to NCR 1734.
The as-found condition was
analyzed by S&L and found acceptable. ECN 30487 was issued to
document the as-built condition of battery racks 2AF01EA and
2AF01EB. No violations or deviations were identified.
(61) Concern: HECo engineering or QA writes all NCRs per
Procedure 6 and at times, they do not address the problem. The
applicable QC inspector should have input in preparing the NCR
or at least, let the QC inspector review the NCR before it is
issued.
Inspectors can only write " practice" (un-numbered) DRs
and NCRs.
NRC Review: A review of HECo Procedure 6, " Reporting of
Damaged or Nonconforming Material or Equipment," Revision 15,
dated September 23, 1985, revealed that QC inspectors
were not permitted to prepare DRs or NCRs.
Paragraph 5.2.1 of
this procedure states, " Deficient items which are not identified
for correction and tracking thru the use of open inspection
reports, will be brought to the attention of the appropriate
supervisor for evaluation.
Supervisors shall write DR's as
appropriate based upon their evaluation." DRs are then forwarded
to HECo Project Engineer and/or QA/QC Manager for resolution.
DRs may be upgraded to NCRs. The NRC inspector expressed a
concern with QC inspectors not being permitted to prepare, at a
minimum, DRs. As a result of this NRC conern, HECo issued
procedure change notice (PCN) 67 to revise Procedure 6.
This PCN
allows the QC inspector / supervisor to prepare DRs. .In that the
QC inspector can now prepare DRs and DRs are typically attached
to the NCR (when they are upgraded), this should alleviate the
QC inspector's concern with the wording on NCRs. Also, the
present QA/QC Manager has stopped the practice of preparing
" Practice" deficiency reports. During the inspection, the NRC
inspector did not identify any hardware problems resulting from
the use of " practice" DRs.
59
-_ --
. . _ - .
-_
1
A review of NCRs, DRs, and inspection reports (IR) revealed that
in some cases _the description of the deficiency was not clear
and/or pertinent data was missing.
This resulted in some poor
and/or incomplete resolutions.
In order to prevent recurrence
of similar deficiencies in the description of the deficiency,
the HECo QA/QC Manager issued QA/QC Memorandum 2365, dated
September 5, 1986. This memorandum states, in part, "The Lead
Inspector, Group Leader and Assistant QC Supervisor is responsible
for reviewing the reports (DRs, open and closed inspection
reports) to assure completeness and inclusion of sufficient data
to substantiate the inspection results. Any reports which lack
sufficient data will be returned to the inspector for correction."
Conclusions: PCN 67 to Procedure 6 was issued to permit QC
inspectors to prepare DRs. Most NCRs are upgraded DRs with
the DR attached. This now allows QC inspector input to DRs
and NCRs. A review of NCRs, DRs, and irs revealed that in some
cases, the description of the deficiency was not clear and/or
pertinent data was missing.
irs (open and closed) and DRs
now go through several levels of QC review prior to issue.
In
addition, the preparation of " practice" deficiency reports has
been stopped by.the direction of the present HECo QA/QC
Manager. .The use of " practice" DRs did not impact the quality
of the inspections.
(62) Concern:
The HECo QC inspectors cannot get QA/QC management to
listen.
NRC Review:
From personnel interviews and observations during
this inspection, the NRC inspector determined that there was a
severe communication problem within the HECo QA/QC organization.
During this inspection, (a) the QA/QC Manager resigned and was
replaced with an individual that has an "open-door" policy; (b)
the QC Supervisor resigned and was replaced with an individual
that is known and respected by the QC inspectors; and (c) the
QA Supervisor resigned. The QA Supervisor's position is being
filled by the present QA/QC Manager.
In addition, the QC-field
office was closed and all QA/QC personnel are now in the HEco
main office. Since the above changes were implemented, there
appears to be a harmonious atmosphere within the QA/QC office.
Based on the PTL overinspection program (See Paragraph 5.a(10)
above), the lack of communications did not affect the quality
of inspections.
s
Conclusions: There was a severe communications problems within
the HEco QA/QC organization. However, the quality of
inspections were not affected. This appears to have been
resolved with the replacement of the " top-three" in the QA/QC
organization and the closing of the QC field office. No
violations or deviations were identified.
(63) Concern: The QC Supervisor (by name) harassed and attempted to
intimidate a QC inspector (by name). The NRC inspector
was provided a copy of HECo NCR 2021, dated May 12, 1986.
60
_-
.
-
._- - -
-
-
-._
-
. - - - - - - - - - . . -
. -
t
.
NRC Review: The NRC inspector interviewed the named QC inspector
and the inspector's immediate supervisor (Lead Inspector). The
Region.III inspector was unable to interview the named QC
Supervisor in that he had terminated his employment with HECo.
<
_ The named QC inspector stated that on May 9, 1986, he was
i
assigned to core drilling. This work operation is performed by
another contractor (Litgen) but HEco is responsible for the QC
,!
inspection of cored holes in accordance with HEco Procedure 21,
" Cored Hole Requests and Inspections." On May 9, 1986, the
,
named QC inspector attended a meeting with two NRC inspectors
i
(Reference: Paragraph 5.a above). Prior to attending this
!
meeting, he informed his lead inspector he would not be available
to inspect cored holes while the meeting was in progress. After
'
i
the meeting was over, the inspector stated he went into the
i
plant and observed that Litgen had cored holes 2059 and 2060
j
without QC being present.
In that this was a violation of
procedures, the named QC inspector prepared two draft NCRs, one
on each cored hole, and submitted them to his lead inspector for
i
review and processing.
The named QC inspector stated that the
next time he saw the NCR (2021) was when the named QC Supervisor
2
called him into his office and " chewed him out" for missing two
j
inspections. The QC inspector also stated that the supervisor
threatened to place a letter (letter of reprimand) in his
personnel file. The QC inspector stated that he informed the QC
.
j
Supervisor that he told his lead inspector he was meeting with
,
the NRC and that his lead attended the same meeting. The QC
i
inspector stated that "the QC Supervisor told me that I was
lying because XXXXX (lead inspector) said that I never told him
I would be attending the meeting." The named QC inspector
-
provided the NRC inspector copies of the two draft NCRs he had
-
i
prepared on cored holes 2059 and 2060. When the draft NCRs were
compared with NCR 2021, it was observed that the two draft
NCRs were combined into NCR 2021 with additional words added.
NCR 2021 now reads in part, " Core Hole #2059 was drilled without
.
'
QC (inspector's name) present. This is a violation of Procedure
l'
- 21, paragraph 5.3.3 and 5.3.3.1.
(Hatfield QC was notified
prior to core drill, but choose not to attend to their
l
responsibilities)." There was a single line drawn through the
inspector's name with initials and a date.
It was determined
I
that the initials were placed there by the HEco QA/QC Manager,
j
The NRC inspector was informed that the information within
j
parentheses on NCR 2021 was added by the named QC Supervisor.
This was also confirmed by the lead inspector.
1
i
During an interview of the subject lead inspector, the NRC
{'
inspector was informed that the named QC inspector had informed
,
him (lead inspector) that he would be attending the meeting with
'
the NRC and that he was aware that the named QC inspector was
assigned to core drilling on that day (May 6, 1986). The lead
<
1
inspector stated that he had informed the named QC Supervisor
l
j
that hp (lead inspector) was at fault for not assigning another
'
I
inspector to the core drilling effort. This lead inspector
confirmed that he had attended the meeting with the NRC on May 9,
1986 and that he had discussed his attending with the named QC
i
4
61
i
-~v-,-,-
,
--
.__---,-__,--,---~w-.
.
.v..--~....
.
. -
Supervisor before and after the meeting (Also see Paragraph
5.a(64) below).
The NRC inspector verified that a letter of reprimana had not
been placed in the named QC inspector's personnel file. Also,
NCR 2021 was properly closed on June 2,1986.
Conclusions:
From personnel interviews and review of records,
it was determined that an unnecessary and uncalled for
statement was placed on NCR 2021 by the named QC Supervisor.
However, since NCR 2021 was properly closed, no letter of
reprimand was placed in the inspector's file, and the named
QC Supervisor is no longer employed by HECo.
No additional
NRC follow-up action is planned on dis concern.
(64) Concern: The QC Supervisor (by name) called a lead inspector
(by name) into his office and questioned him about the May 9,
1986, meeting with the NRC. This meeting lasted approximately 1
1/2 hours and the lead told all.
NRC Review: The NRC inspector interviewed the named lead
inspector about this concern.
The NRC inspector was informed
that he (the lead inspector) discussed his attending the May 9,
1986 meeting with the NRC with his supervisor (named QC
supervisor) and he initiated the interview with his supervisor
following the meeting with the NRC. The lead inspector stated
that he and his supervisor discussed the concerns expressed to
the NRC.
Conclusions: This concern was not substantiated in that the
named lead inspector initiated the interview with the named
QC supervisor. No violations or deviations were identified.
(65) Concern: Safety-related drawings are not checked for
inspections.
There are no termination cards for internal
wiring and QC has to depend upon constructions to issue an
inspection request.
NRC Review: The NRC inspector reviewed Procedure 11, " Class 1
Cable Termination and Splicing," and noted the folloving
related requirements:
Paragraph 5.1.5 states, "The S&L Wiring Diagrams shall
identify the terminal point of each conductor."
Paragraph 5.1.7 states, "The cable will be terminated as
shown on the wiring diagram."
Paragraph 5.9.1 states, " Inspections for cable
terminations, splices and repairs shall be performed using
Fprm HP-118."
62
_
-
Form HP-118, Cable Termination Inspection Report,
inspection attribute 15, states, " Terminated per Wiring
Diagram." The wiring diagram number and revision must be
entered on this form.
Exhibit N provides an example of a " Cable Pull Card,"
also, the back of the pull card provides the cable
"From End" and "To End" termination data.
Paragraph 5.1.28 states, "Upon completion of the splice,
the termination, or the repair, the field personnel will
fill in the required information on the cable pull card
and on the Form HP-118. These documents will then be
returned to the QA/QC Department for acceptance and
retention."
This is constructions method of notifying QC
that an item has been installed and is ready for
inspection.
For Unit 2, HECo QC is now in the process of listing all items
requiring inspection (For examples, hangers, cables, cable pans,
and conduit) and verifying that the applicable inspection
reports are on file. To assure that revised drawings are being
reviewed for additional work (revisions to installed items cr
new work), the NRC inspector selected six drawings for review.
All six drawings had been reviewed by production, engineering,
and QA/QC. This review resulted in four rework requests being
prepared to rework items that had been previously installed and
accepted. The NRC found the controls to be adequate and the
controls acceptable.
'
Conclusions:
Procedures are in place to preclude missing of
required inspections for Unit 2.
Paragraph 5.a(39) above is
an example where HECo identified missing WTCs for Unit 2 riser
collar welds.
Procedures also require construction to notify
QC when an item has been installed and is ready for
inspection. No violations or deviations were identified.
(66) Concern:
Sargent and Lundy (S&L) added conduits to a J-Box
without considering load effects. Think XXXXX (named QC
inspector) wrote up one box and additional anchors (CEAs) had
to be added.
NRC Review: The NRC inspector reviewed NCRs 540 through 1992
and could not identify any NCR that fits the description of this
concern.
During this review, the NRC inspector noted that
some NCRs had been issued on undersized concrete expansion
anchors (CEA) being installed, or CEAs not being installed to
the minimum embedded depth.
In all cases noted, the CEAs
were found to be acceptable as installed based on analyses by
S&L. During this review of NCRs on CEAs, the NRC inspector
selected the NCRs dispositioned "use-as-is" and reviewed the
S&L analysis to verify justification for the disposition.
l
No discrepancies were identified with the analysis.
63
Conclusions: Based on the NRC inspector's review of approximately
1450 NCRs, without being able to identify an NCR that fit the
allegers concern, this allegation was not substantiated.
In
addition, the NRC inspector reviewed the S&L analyses on ten
NCRs where the CEAs were accepted as installed. The S&L analyses
was found to be adequate. No violations or deviations were
identified.
(67) Concern:
HECo QC was directed to limit their inspections to the
scope of the applicable 7A (Rework Request).
NRC Re,iew: During interviews of HECo QC inspectors and lead
inspectors, the NRC inspector was informed that certain
QC inspectors wanted to reinspect everything in the area when
they were assigned to inspect an item on a rework request.
Two examples were provided (a) As a result of a drawing revision,
a new conduit hanger is being installed on previously accepted
tube steel by a rework request. At least one QC inspector would
have the fireproofing removed so he could reinspect all the
tube steel welds as well as the welds on the new conduit
hanger and (b) As a result of a drawing revision, a new cable is
being added to a cabinet by a rework request. Again, at least
one inspector would reinspect all the terminations in the
cabinet in addition to the termination of the new cable.
For
the examples provided, it is not necessary to reinspect the
surrounding items. Only the actual rework requires inspection.
If however, an item was being reworked, and the nature of the
rework caused damage to the surrounding equipment, then an
expanded reinspection would be justified.
In all examples
discussed above, if a discrepancy was identified outside the
scope of the rework request, it should be documented in
accordance with HECo procedures. During a review of rework
requests, the NRC inspector did not identify any rework that
would justify a reinspection of any item (s) outside the scope
of the rework request.
Conclusions: Based on personnel interviews and review of
rework requests, the NRC inspector did not identify any rework that
would justify a reinspection of any item (s) outside the scope
of the rework request.
However, if any discrepancy is
identified, it should be documented in accordance with HECo
procedures. No violations or deviations were identified.
(68) Concern: When using a standard 45' or 90* conduit fitting, the
minimum cable pulling and training radius is exceeded.
NRC Review:
Conduit fitting are designed to have cable pulled
through the fitting without causing damage to the cable. When
pulling cable, the cable does not follow the inside radius of a
conduit bend (fitting or formed conduit).
The cable contact
points, during a pull, would be the outside of the fitting
radius on both ends and the inside of the fitting radius in the
middle of the fitting.
Electrical cables (except for special
64
cables) can be pulled through a specified conduit fitting without
exceeding the minimum cable bend radius. . Cables under tension
have a more restrictive bend radius than cables not under
tension. Therefore, the cable train radius would also be
acceptable for a cable installed in a conduit with specified 45'
<
or 90' fittings.
S&L Standard EB-146, paragraph 7.2.6, does
not permit " standard" radius elbows (bends) unless specifically
indicated on the Electrical Drawings.
.
Conclusions:
Electrical cables (except for special cables) can
be pulled through a specified conduit fitting without exceeding
the minimum cable pulling or training radius.
S&L Standard
EB-146 does not permit a " standard" radius elbow unless
specifically indicated on the Electrical Drawings. No violations
or deviations were identified.
(69) Concern: There is a memorandum from the Assistant Project
Manager, dated April 18, 1986, on NCRs and DRs.
If this
memorandum.is implemented, it would give the craft a chance to
correct the deficiency before the DR/NCR is written and
dispositioned.
NRC Review: The NRC inspector obtained a copy of the Assistant
Project Manager's subject memorandum for review. This memorandum
indicates that when a violation is identified, all the applicable
HEco personnel should be notified immediately so the violation
could be reccnstructed for the owner while the facts were fresh
in people's minds. This memorandum states, in part, "The above
subject (NCR and DR violations) has been discussed many times,
where as QA/QC would identify violations such as pull over tensions,
preheat and any other violations that we, HECo, knows will result
in a NCR that we will have to reconstruct for the owner.
...
the QC inspectors can be instructed to let QC Supervisor know when
there is a violation.
This will enable us to get it resolved
and down on paper by the time the NCR appears, which in most
cases has been weeks later." As can be seen from the memorandum,
the Assisthnt Project Manager recognized the fact that an NCR
would be prepared for certain violations and that the facts of
the violation must be presented to the licensee on the NCR.
Conclusions: Based on a review of the Assistant Project
Manager's memorandum of April 18, 1986, it was concluded that
the purpose of the memorandum was to request early notification
of violations. This early notification would permit HECo to
gatter the facts of the violation for' presentation to the
licensee and not to correct the violations before a DR/NCR was
prepared. No violations or deviations were identified.
(70) Concern:
Field Change Request (FCR) F-26448 relocated a
terminal box on panel 2PL85JA.
This panel was installed by
Powers-Azco-Pope (PAP) and the subject terminal box appeared on
a PAP drawing. HECo relocated the terminal box. Was FCR
F-26447 ever incorporated on the applicable PAP drawing?
65
.
NRC Review: The NRC inspector reviewed FCR F-26447. This
review revealed that'the subject FCR had been incorporated on
Systems Control (panel vendor) drawing 6577-M-2PL85JA on
September 19, 1985. The systems control drawing was provided
to PAP for their use in the installation of instrument panel
-
2PL85JA.
Conclusions:
FCR F-26447 was incorporated on Systems Control
Drawing 6577-M-2PL85JA.
This drawing was provided to PAP for
their use in the installation of panel 2PL85JA. No violations
or deviations were identified.
(71) Concern: Review HECo NCRs 937 through 942 for proper closure.
Also review S&L's walkdown for separation violations.
NRC Review: The NRC inspector reviewed HEco NCRs 937 through
942 and found that all these NCRs pertained to electrical
separation violations and were prepared after the CECO, HEco,
and S&L separation walkdowns.
These NCRs identified previously
identified separation violations. The NRC reviewed the separation
walkdown effort; S&L analysis of the violations identified;
applicable drawings to verify that tray covers were specified
<
as part of the corrective action; and performed a tour of the
power block and identified separation violations and verified
1
that these violations had been identified during the joint
separation walkdown. (See NRC Inspection Report 454/84027;
455/84019). These walkdowns and corrective actions were found to
be acceptable, however, the licensee was issued a violation, by
the NRC, for failure to inspect for separation violations on
i
items installed after the joint walkdowns were completed.
The
'
NRC issued violations were subsequently closed in NRC Inspection
Reports 454/84047; 455/84041 and 454/84069; 455/84047.
Conclusions: The electrical separation violations identified
on NCRs 937 through 942 had been previously identified during a
joint (CECO, HEco and S&L) separation walkdown. The NRC's
actions on separation issues are documented in the NRC
Inspection Report referenced in the above paragraph. No
violations or deviations were identified.
(72) Concern:
Review HECo QA/QC Manager's (by name) interoffice
memorandum. QC inspectors need approval to go to Ceco for any
'
reason.
NRC Review:
The NRC inspector reviewed the QA/QC memorandum
file and memorandum log. A review of the file revealed that
QA/QC Memorandum 1669 was missing. A review of the log indicated
that the subject of this memorandum was " Department Policy," and
was prepared on January 10, 1985. During interviews with
numerous QA/QC personnel it was revealed that during a staff
meeting, conducted by the named QA/QC Manager, they were informed
that they could not go to the CECO office without their Supervisors
66
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huthorization. At the NRC'ii'spector's request, various inspectors,
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p. lead inspectors, and clerks searched their personal files for a
hopy of Memorandum.1669 with negative results. , Based on the NRC
.
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inspector's observations during the inspectin, neither quality
nor communications nith the'11censee was affected by the HECo
'
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QA/QC Manager's vernal directions and/or the subject memorandum.
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The named QA/Q? Manager was not interviewed in that he had
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terminated his'empicyment with HECo.
'
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. Conclusions: 1This concern could not be refuted nor
- p
substantiated in!that a copy of HECo QA/QC Memorandum 1669
~L
could not be found. The named QA/QC manager was not interviewed
's
in that he had terminated his employment with HEco. There was
}.
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no effect on the quality of the plant and communications iwth-
the licensee. Mo violations or deviations were identified.
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(73) Concern: LFor hurtain Unit 1 equipment, the weld downs inside
"
the cabinets were not welded per detail. These weld downs were
$
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never repaired.
!
'
-
NRC Review: The NRC inspector was able to identify HECo DR
.
, .
4181, dated February 9,'1984, HEco NCR 855, dated Fe.bruary 13,
1
'
!
e1984, and Ceco NCR F-916, dated June 1, 1984, that addressed
- this concern. JAs can be seen from the dates of the various
'
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documents, the deficiencies were first identified on DR 4181.
4
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'This DR identiflad defective welds or welds that were not welded
Q
'per.the drawing detail for the following items of. equipment;i
44'
+
1AP05E
1AP06E
1AP106E
1AP26E
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1AP99E
1AP98E
1PLO4J
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DR 4181 was subsequently upgraded to HECo NCR 855. The largest
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number of defects pertained to slot welds not being welded per
.
'
the drawing detail. Detail 47 requires slot welds to be welded
[ p
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onall?Jpursidesanditwasidentifiedthattheywereonlywelded
Nh
on the two long sides of the slot. 'Several instances of problems
L['
with weld overlap, u'ndercut, slag inclusion, and weld spacing
were'also identified. At the licensee's direction,-weld maps
~
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-
were prepared for the above listed equipe nt.
This information
!
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was ccmpiled and incorporated in CECO NCR C-916 whl:h was
(
forwarded to S&L for their evaluation. Based on the S&L analyses
,,
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.r. "of the as-welded condition, it was determined that no additional
'
welding (repair or rework) was required fob these items to meet
'
l
Ahe seismic requirements for Class IE equipment. These NCRs
j
'were properly closed on July 9,1984. The same type of weld
i
deficiencies were identified on similar Unit 2 equipment. The
i
Unit 2 deficieacies were documented on HECo NCR 1669 and Ceco
'
'
i
NCR F-1005. These Unit 2 NCRs were properly closed on
i
December 14, 1965.
For additional details, see NRC Inspection
l
Report 454/86019, 455/86014.
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Conclusions: As documented on HECo DR 4181, HEco NCR 855, and
CECO NCR F-916, some Unit 1 and Unit 2 equipment weld downs were
identified as not being welded to detail and/or had defective
The S&L analyses of the as-welded condition determined
that no weld repair / rework was required for these items to meet
the seismic requirements. No violations or deviations were
identified.
(74) Concern: Cable tray span is never verified.
NRC Review:
Cable tray span is defined as the span / distance
between adjacent cable tray hangers. The maximum cable tray
span is determined by the design analysis.
From this analysis,
the design engineer determines the hanger location and the
hanger installation tolerance.
If the cable tray hangers are
installed per the design drawings (design location + the
installation tolerance), then the cable tray span criteria
would be met. During a review of HECo Procedure 9A, " Class 1
Cable Pan Hanger Installation," the NRC inspector verified that
cable tray (pan) hanger location was inspected by QC. Attribute
6 on Form HP-9A-1, " Class 1 Cable Pan Hanger Inspections
Checklist," states, " Hanger Location per Drawings." The criteria
for this attribute states, "The hanger must be located within
the tolerances specified on the Cable Pan Hanger Drawing 0-3272."
'
The NRC inspector reviewed approximately 100 HP-9A-1 forms to
1
verify that QC was inspecting this attribute. No discrepancies
'
were identified.
Conclusions: Cable tray span was in fact being verified by
~~
confirming that the cable tray hangers are installed per the
design drawings.
Inspections for cable tray hanger location
were properly documented on Form HP-9A-1. No violations or
!
deviations were identified.
(75) Concern: A HEco QC inspector (by name) and his wife were
'
threatened and HECo management did nothing about it.
The
named QC inspector would not allow the craft to pull cable '
until they installed a dynamometer.
'
NRC Review: Toprotecttheelectricalcablefrombeingdver
stressed during cable pulling, a maximum cable. pulling tension
is established. To prevent exceeding the msximum cable pulling
tension, a dynomometer is installed to measure the actual pulling
tension. The requirements for using a dynomometer are established
in HECo Procedure 10, " Class 1 Cable Installation." The NRC
inspector interviewed the named QC inspector with respect to
this concern. The NRC inspector was informed that neither the
named QC inspector nor anyone in his' family had even been
threatened.
The named QC inspector stated that an incident had
~
taken place in approximately November 1985 where he had stopped
a cable pull due to a lack of the required dynomometer being
installed for the cable pull.
During this incident, one of the
68
__
i
i
craftsmen addressed this QC inspector using abusive and foul
language, but the inspector was never threatened.
This QC
inspector reported the incident to his supervisor.
The NRC
inspector was informed that an immediate investigation was
performed by HECo management. This investigation culminated in
the termination of the craftsman.
Conclusions: The named QC inspector stated that neither he nor
his family had ever been threatened. However, there was an
incident where a craftsman addressed the named inspector using
/
.busive and foul language. HECo management conducted an
immediate investigation which culminated in the termination of
the craftsman. No violations or deviations were identified.
)
(76) Concern: The signature of a QC inspector (by name) was forged
on Class 1 Exposed Conduit System Inspection Checklist Report
Numbers 576 and 577. These forged signatures were reported to
the deco QC/QC Manager (by name) but nothing was ever done to
get the issue resolved.
NRC Review: The NRC inspector discussed the alleged forged
reports-(576 and 577) with the CECO QA Superintendent and
present HECo QA/QC Manager. The named QA/QC Manager is no
longer employed by HECo.
The licensee retrieved the original conduit inspection reports
(576 and 577) with the purported signatures of the named QC
inspector and 12 original documents containing the known
signatures of the named inspector. These original documents
were provided to a Foresic Document Examiner for examination
to determine if all of the signatures were written by the named
QC inspector.
.
During this inspection, the NRC inspector reviewed a
letter, dated October 27, 1986, from the Forensic Document
Examiner to the law firm of Isham, Lincoln and Beale that
described the documents reviewed and the results of his review.
The Document Examiner's letter stated, " Based upon the
examinations and comparisons of the exhibits submitted, the
examiner is of the opinion that the writer of the known
exemplars authored the three (3) questined signatures on
Exhibits Q-1 and Q-1" (Inspection Report 576 and 577).
Conclusions: After examination by a Forensic Document
Examiner, it was concluded that the signatures on conduit
inspection reports 576 and 577 were not forged, therefore, this
concern was not substantiated.
No violations or deviations were
identified,
i
69
1
,
!
--
(77) Concern: Category II (non-safety-related) to Category I
(safety-related) welds are not being inspected by HECo QC.
Also, there are many Category II to Category I cross-flange
NRC Review: The NRC inspector reviewed Electrical Specification
F-2790 for welding requirements in the areas of this concern.
Section 30.12 states that S&L Standard Form 1701, Revision G,
forms a part of the specifications. The title of Form 1701 is
" Standard Specification for Welding in Steel Construction."
Section 401.19.1 of the specifications states, " Welds,
includirg full and partial penetration groove welds, shall be
subject to visual inspection as specified in BY/BR/VWAC."
~
Section 3.2.2 of Form 1701 states, " Fillet welds across flanges
of any steel member will not be permitted unless specifically
indicated on the design drawings; any under cutting or damage
that will reduce the flange area will not be permitted."
Section 4.1.1 of Form 1701 states, "All welding shall be
inspected and examined by contractor . . . unless otherwise
indicated in the Project Specifications or the design drawings."
With respect to this concern, the inspector requested and
received assistance from NRC Welding /NDE inspectors. The
results of their findings will be documented in a subsequent
NRC Inspection Report (454/86042; 455/86038).
Conclusions: With respect to this concern, NRC welding /NDE
inspectors are investigating this concern ,and the results of
their findings will be documented in a subsequent NRC
Inspection Report.
Pending the completion of this inspection,
this item is open (454/86031-10, 455/86017-10).
(78) Concern: Procedure 20 is not compatible with S&L Standard
EB-146.
NRC Review: The NRC inspector reviewed Procedure 20, " Class 1
Exposed Conduit System Installation," Revision 15, and compared
it to the requirements of S&L Standard EB 146,." Standard
Specification for the Installation of Seismic Category
1 Conc'uit Systems Containing Class IE Cable," dated April 23,
1986. The NRC inspector noted that there were several instances
where a S&L drawing was referenced as the installation criteria
rather than Standard EB146.
However, the Electrical Specification,
Paragraph 304, states that the S&L drawings take precedence over
S&L Standards.
Conclusions: During a review of Standard EB-146 and
Procedure 20, it was observed that there were several instance
where a drawing was referenced instead of Standard EB-146.
However, S&L drawings take precedence over S&L Standards. No
violations or deviations were identified.
(79) Concer'n: During core drilling, there were numerous rebars
70
cut / hit in "Q" wall and many were not reported to S&L.
NRC Review: The NRC inspector reviewed approximately 100 cored
hole reports (CHR).
For all safety-related CHRs that indicated
a rebar cut / hit, an NCR was prepared if the cut / hit rebar was
not permitted by the field change request (FCR) and/or core
drilling request (CDR). Even though an NCR was not required, a
copy of all safety-related and non-safety-related CHRs were
forwarded to S&L for their review. During this inspection, the
NRC inspector selected 10 CHRs for "Q" wall where rebar was
cut / hit and verified that S&L was plotting / recording the cut / hit
rebar on the appropriate "Q" wall (a safety related wall)
location.
In addition, the NRC inspector also selected five
cut / hit rebar NCRs on "Q" wall and verified that they were
.
properly plotted / recorded.
No deficiencies were identified.
Conclusions: Cut / hit rebars were being preperly documented by
S&L. No violations or deviations were identified.
(80) Concern:
Procedure 21, " Cored Hole Requests and Inspections,"
states that "no items may be installed in a cored hole until
HECo receives a completed CHR signed-off by CECO PCD."
How can
CECO sign-off (accept) a CHR with an open NCR against the cored
hole?
NRC Review: The NRC inspector reviewed Procedure 21 and
interviewed CECO PCD engineers. CECO PCD engineer's signature
on a cored old report (CHR) is the licensee's approval for " Work
May Proceed." If an NCR is prepared on the cored hole due to a
rebar being cut / hit, the NCR tracks the deficiency. Therefore,
a cored hole with a cut / hit rebar would not be " accepted" until
the NCR was properly closed.
Conclusions: CECO PCD engineer's signature on a CHR is the
licensee's approval for " Work May Proceed." The proper closure
of the NCR would be the acceptance of the cored hole with
identified deficiencies. No violations or deviations were
identified.
(81) Concern: At final turnover to CECO, did the electrical raceway
hangers meet the latest S&L drawings?
NRC Review: The NRC inspector reviewed the inspection,
reinspection and overinspection history of the raceway hangers
at the Byron Station. As a result of the NRC team inspection
(See NRC Inspection Report 454/82005; 455/82004), a major
reinspection program was initiated at Byron Station (See Paragraphs
5.a(56) and (57) for similar concerns).
This reinspection
program included a reinspection of raceway hangers. The Following
is a general sequence of events as relating to the raceway
hanger, reinspection program:
71
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HECo NCR 407, dated February 11, 1982, documented that
cable pan hanger inspections were inadequate. A sample
inspection was performed on 20% of the total hangers in
each of the six drawing areas with a 26% reject rate. The
corrective action was to perform a 100% reinspection of
i
all cable pan hanpers. This NCR was closed on June 9,
>
1982, before the reinspection was completed.
HECo NCR 407R was initiated on December 3, 1982 to track
the reinspection program.
NRC Inspection Reports 454/82017; 455/82012 issued an
Unresolved Item pending final review of NCR 407.
NRC Inspection Report 454/83048 provided a status of NCR
407/407R.
NRC Inspection Reports 454/84027; 455/84019 issued an NRC
violation for inadequate inspections in conjunction with
NCR 407R. As a results, 345 previously accepted cable
tray hangers were reinspected and 129 were found defective
and 19 were classified as indeterminate because they were
inaccessible for reinspection. To document these
deficiencies, HECo prepared NCR 989 and DRs 4921-4928,
4930, 4932, 4934-4937, 4943, 4945-4948, 5003, 5007,
5013-5017, 5019, and 5022-5032.
NRC Inspection Reports 454/84047, 455/84041 closed the
Unresolved Item identified in IE Inspection Reports
454/82017; 455/82012.
l
NRC Inspection Reports 454/84069; 455/84047 closed the
l
violations identified in IE Inspection Reports 454/84027;
l
455/84019.
During the review of this concern, the NRC inspector was provided
copies of various memorandums between Ceco and HECo. The following
is a general description of these memorandums:
QA/QC Memorandum 897, dated July 1,1983, from a HECo QC
lead inspector to the HECo QA/QC Manager identified
certain pan hanger attributes that were not being
inspected; e.g., gusset plate size, fit-up gap, and locus of
working points.
QA/QC Memorandum 1173, dated February 22, 1984, from a
HECo QC inspector to the HECo QC Supervisor identified
that " Prior to February 13, 1983, pan hangers were in most
cases not inspected per detail."
J
72
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- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
QA/QC Memorandum 1230, dated March 23, 1984, from HECo
QA/QC Department to CECO PCD project electrical supervisor
stated, "HECo QC has reviewed all detail connections on
the 0-3200 series drawings. Attached is a copy of each
detail including the items that have not been inspected."
The attachments to this memorandum listed the following
types of items as not being inspected plate sizes;
DV-161 stiffners; fit-up gap; I beam size; bolt hole
dimensions; bent plate size; locus of working points; etc.
NOTE: The same types of discrepancies were
previously identified by the NRC.
Fit-up (91); plate
size (17); wrong connection detail (7); welding;
missing bolts (See Inspection Reports 454/84027;
455/84019). This inspection was conducted between
April 24 and May 11, 1984
CECO letter dated July 16, 1984, transmitted HECo QA/QC
Memorandum 1230 to S&L for review.
S&L letter to CECO, dated October 2,1984, documented the
results of S&L's inspection program and analysis of
uninspected items identified in HECo QA/QC Memorandum
1230. The following are excerpts from the S&L letter:
80 randomly selected supports were inspected.
-
pre-approved checklist were utilized.
-
engineering evaluation included observed discrepancies
-
and Byron QC Inspector Reinspection Program.
engineering evaluation finds that the corresponding
-
strength reduction in the connections is within the
specified design limits.
the quality of cable tray support connection work is
-
adequate through out the plant for both Units 1 and 2.
Based on the NRC inspector's review of the S&L inspection program
and their engineering evaluation, S&L's evaluation was adequate
to accept the hangers installed to date.
CECO letter from the PCD Project Electrical Supervisor to
the HECo QA/QC Manager, dated October 8, 1984, transmits
the S&L letter (October 2,1984) to HECo and states,
"This review has been completed and as identified in
reference (b) above (S&L letter of October 2, 1984), the
quality of the cable tray support connection work is
adequate throughout the plant for both Units 1 and 2.
73
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.
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cut / hit in "Q" wall and many were not reported to S&L.
NRC Review:
The NRC inspector reviewed approximately 100 cored
hole reports (CHR).
For all safety-related CdRs that indicated
a rebar cut / hit, an NCR was prepared if the cut / hit rebar was
not permitted by the field change request (FCR) and/or core
drilling request (CDR). Even though an NCR was not required, a
copy of all safety-telated and non-safety-related CHRs were
forwarded to S&L for their review. During this inspection, the
NRC inspector selected 10 CHRs for "Q" wall where rebar was
cut / hit and verified that S&L was plotting / recording the cut / hit
rebar on the appropriate "Q" wall (a safety-related wall)
location.
In addition, the NRC inspector also selected five
cut / hit rebar NCRs on "Q" wall and verified that they were
properly plotted / recorded. No deficiencies were identified.
Conclusions: Cut / hit rebars were being properly documented by
S&L. No violations or deviations were identified.
(80) Concern: Procedure 21, " Cored Hole Requests and Inspections,"
states that "no items may be installed in a cored hole until
HECo receives a completed CHR signed-off by CECO PCD." How can
Ceco sign-off (accept) a CHR with an open NCR against the cored
hole?
NRC Review: The NRC inspector reviewed Procedure 21 and
interviewed CECO PCD engineers.
CECO PCD engineer's signature
on a cored old report (CHR) is the licensee's approval for " Work
May Proceed." If an NCR is prepared on the cored hole due to a
rebar being cut / hit, the NCR tracks the deficiency. Therefore,
a cored hole with a cut / hit rebar would not be " accepted" until
the NCR was properly closed.
Conclusions: Ceco PCD engineer's signature on a CHR is the
licensee s approval for " Work May Proceed." The proper closure
i
of the NCR would be the acceptance of the cored hole with
identified deficiencies.
No violations or deviations were
identified.
(81) Concern: At final turnover to CECO, did the electrical raceway
hangers meet the latest S&L drawings?
NRC Review: The NRC inspector reviewed the inspection,
reinspection and overinspection history of the raceway hangers
at the Byron Station. As a result of the NRC team inspection
(See NRC Inspection Report 454/82005; 455/82004), a major
reinspection program was initiated at Byron Station (See Paragraphs
5.a(56) and (57) for similar concerns). This reinspection
program included a reinspection of raceway hangers. The Following
is a general sequence of events as relating to the raceway
hanger reinspection program:
,
74
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attributes discussed in Memorandum 1230 on future work."
However, an ECN, FCR, or drawing revision was not issued to
delete the requirements to install / inspect cable tray hangers in
accordance with the design documents. QA/QC Memorandum 1631
documents that the HEcc QA/QC Manager provided a verbal directive
not to inspect pan hanger connections per details specified on
S&L drawings (Des.ign Documents).
The licensee was informed that failure to assure that changes
to documents, such as instructions, procedures, and drawings
are reviewed and approved by the same organizations that
performed the original review and approval is an example of
a failure to implement Criterion VI of 10 CFR 50, Appendix B
(454/86031-15; 455/86017-15).
(82) Concern:
Procedure 10 has been revised to reduce inspection
requirements.
NRC Review: The NRC inspector reviewed HECo Procedure 10,
" Class 1 Cable Installation," Revisions 19 through 24 (current
revision). During this review, the following procedure
differences were noted:
Between Revision 19, (February 14,1983) and Revision 22
(January 3, 1985) only minor changes were made to the
HP-105 form (Cable Installation Inspection Checklist), the
requirement to list the DR number (s), if applicable, was
added.
Between Revision 22 and Revision 23, (March 20, 1985) a
major change was made to the HP-105 form. The following
inspection attributes were celeted in Revision 23:
-
Cables below top edge of pan, neat, flat and parallel.
-
Half-rounds and edge protectors in place.
No sharp edges.
-
i
No damage or deformity to cables.
-
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No obvious violations of minimum bend in pan.
<
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Cables in pan protected from work in progress in area.
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No scaffold on pan in run.
l
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Embed conduit swabbed and acceptable.
!
Cable ends were sealed.
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Minimum bend not exceeded (coiled cables).
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Cable routing acceptable.
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Cable free of damage.
Cable coiled properly.
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The following inspection attributes were added in Revision 23:
-
Conduit reports HP-204, HP-205 and HP-206 complete and
on file.
-
Hangers installed and conduit properly attached.
-
Conduit size is as specified in Exhibit K (Cable
Tension Calculation).
'
,
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Installed junction boxes are as specified on
Production Installation Reports.
-
Exhibit K attached to HP-105.
A new section was added for Cable Rework.
-
Revision 24 (October 18,1985) deleted the first three
inspection attributes that we added in Revision 23. No
inspection attributes were added in Revision 24.
During a tour of the plant by the NRC inspector, no discrepancies
were identified that resulted from the reduced inspection
i
criteria discussed above. The electrical construction activities,
as of this inspection, are essentially complete at the Byron
i
Station. However, it is the NRC inspector's understanding that
HECo's contract has been extended through December 1987 to
perform maintenance and modification work activities as directed
by the licensee. Based on this extension of contract, the
licensee was requested to evaluate HECo Procedure 10, Revision
22, 23 and 24, and provide justification for the deletion of the
'
j
above listed inspection attributes.
Conclusions: A review of Procedure 10, Revisions 19-24,
'
indicated that inspection attributes were deleted from the cable
installation procedure. During a tour of the plant, the NRC
inspector did not identify any violations that resulted from
the deletion of these inspection attributes. Construction is
essentially complete at Byron, however, HECo's contract has
been extended. Based on this extension of contract, the
licensee was requasted to provide justification for the
deletion of inspection attributes from Procedure 10.
Pending a
review of this justification, this item is unresolved
(454/86031-11; 455/86017-11).
(83) Concern: The only corrective action cn minimum cable bend
radius violations is to straighten the cable.
These violations
are never evaluated.
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.
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--
=
NRC Review: The NRC inspector reviewed HECo Procedure ;0,
" Class 1 Cable Installation." Paragraph 5.1.45 of this procedure
states, "QA/QC Department will conduct an evaluation against the
criteria of Exhibit G and if required, QA/QC will generate a DR
or NCR, as applicable, per Procedure 6." Exhibit G states,
" Commonwealth Edison Company (PCD) shall be notified by DR or
NCR if: A kink or twist is found that is caused by compressing a
loop to less than the minimum bending radius." As stated in
Procedure 10, "HECo shall document all minimum cable bend radius
violations on an NCR or DR."
The NRC inspector reviewed two CECO NCRs (F-873 and F-878) that
identified c*hle bend radius violations. The disposition on
these NCRs seates, " Retrain the affected cables such that the
bending radius is equal to or greater than the minimum specified
training radius." However, the violations identified on these
NCRs were evaluated by S&L and the Okonite Company (cable
manufacture). The NRC inspector was also provided a copy of
a CECO internal letter, dated April 16, 1982, that provided
guidelines for field examination of suspected nonconforming
cable bending radius. This letter states in part:
" Power Cable, Medium Voltage - Above 600V. (Sky, 8kv and 16kv)
.
Dispositioned on a case-by-case basis via CECO.
Nonconformance Report.
Power, Control and Instrumentation Cable, Low Voltage -
Under 600V.
'
Cable is to be accepted if the (MBR) Minimum Bend Radius
was exceeded under the following conditions:
(a) MBR violation did not occur when the cable was under
pulling tension.
(b) Visual inspection of the cable indicates that tnere is
no rippling, tearing or stretching of the cable jacket
or significant deformation of the cable at the point
where the MBR was exceeded (both inner and outer radius).
(c) The copper conductor had not been bent 180' and/or
crushed severely such as to cause the copper conductor
to be permanently crimped and/or penetrate the
insulation or strands to be broken.
(d)
If the cable has been handled roughly but the visual
inspection indicates no damage, construction or
quality control may request that conductor continuity
be verified.
C' ables not meeting the above criteria will be repulled/
abandoned.
77
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_ _ . _ _
In all instances where the MBR has been exceeded, the cable
installation will not be deemed acceptable unless the cable
is retrained and left in an unstressed condition (final
radius equal to or greater than MBR)."
The licensee was requested to provide justification for not
documenting all violations of minimum cable bend radius on NCRs.
Conclusions:
The NRC inspector identified two NCRs identifying
cable bend radius violations where the disposition was to retrain
the cables. These violations had been evaluated by S&L and the
cable manufacturer. There is a CECO letter that limits the
conditions under which an NCR is required for cable bend radius
violations. The licensee was requested to provide justification
for not documenting all bend radius violations on NCRs.
Pending
a review of this justification, this item is unresolved
(454/86031-12; 455/86017-12).
(84) Concern: Battery cables for safety-related diesel driven pumps
were received non-safety-related and installed in a
safety-related system.
NRC Review: The NRC inspector reviewed NCR 1741 and Project
Specification F/L 2891.
During a review of the specifications,
it was determined that Paragraph 206 imposes the following IEEE
Standards on the vendor, Stewart and Stevenson, Inc.:
IEEE 308, " Criteria for Class 1E Electric Systems for
,
Nuclear Power Generating Stations."
IEEE 323, " Standard for Qualifying Class 1 Electric
Equipment for Nuclear Power Generating Stations."
IEEE 344, " Standard for Seismic Qualification of Class 1
Electric Equipment for Nuclear Power Generating Stations."
Form EM-29115 was attached to and was a part of Specification
F/L 2891. Section 9.1 of this form requires flame tests be
conducted on cables per IEEE 383-1974. Section 11.3 of EM-29115
requires thermal and radiation tests be conducted per IEEE 383-1974 and IEEE 323-1974
The only amendment (1) to
Specification F/L 2891 was dated June 27, 1983. This amendment
did not revise nor take exception to any of the above listed
paragraphs or IEEE Standards.
In accordance with Specification F/L 2891, the subject battery
cables are installed at the Byron and Braidwood Stations in
conjunction with safety-related diesel driven Auxiliary
Feedwater Pumps and Essential Service Makeup Water Pumps. The
requirements for these battery cables was re-affirmed in an S&L
letter (F. G. Gogliotti) to Steward and Stevenson (S&S) (H. M.
Arbuckle) requesting S&S submit a supplementary proposal for
the battery cables. This letter specified that the cables were
78
Class 1E and must be qualified to IEEE 323-1974. S&S
supplementary proposal letter of February 18, 1982, stated that
the battery cables would be furnished in accordance with
Military Specification M-5086A. S&L letter to S&S, dated
February 19, 1982, authorized S&S to proceed with the delivery
of the battery cables. A 500' reel of 1/c, #4/0, 600V battery
cable was received at Byron Station on MRR 51998 dated June 1,
1982. A S&L letter to the Byron QA Superintendent (CECO),
dated October 11, 1982,' stated that no quality control
documentation was required for the material (battery cable)
furnished on MRR 51998. On May 6, 1985, an additional 200'
of battery cable was ordered on Material Services Request 79551
(P0 501632). This additional battery cable was received on MRR
58918, dated June 26, 1985. On October 29, 1985, HECo prepared
NCR 1741 to document the lack of adequate documentation for the
battery cable received on MRR 58918. The disposition on NCR
1741 states, " CECO MSR 67395 written to change QA requirements
on MSR 79551." This change made the battery cables a " Commercial
Grade" item. A review of Table 3.11-1 of the Byron /Braidwood
FSAR indicates that the applicable items associated with the
Auxiliary Feed Water Pumps (diesel driven) would be qualified
to IEEE 323. However, the NRC inspector was informed that this
information had been revised by a later submittal to the NRC
(NRR).
It is the inspector's understanding that FSAR Table
3.11-1 will be revised / deleted based on this later submittal of
the Byron /Braidwood Equipment Environmental Qualification Report.
Conclusions: The NRC inspector's review of Project Specification
F/L 2891, NCR 1741, applicable Material Receiving Reports,
applicable Material Service Requests, and Chapter 3 of the
Byron /Braidwood FSAR, verified that " Commercial Grade" battery
cables were used in conjunction with the diesel driven Auxiliary
Feedwater Pumps. Table 3.11-1 of the FSAR indicates these
cables would be qualified to IEEE-323. However, a later
submittal of the Byron /Braidwood Equipment Environmental
Qualification (EQ) Report revised the information contained in
Table 3.11-1 of the FSAR. It is the inspector's understanding
that Table 3.11-1 will be revised / deleted based on the latest
EQ report.
Pending a review of the revised FSAR (Table 3.11-1
and the applicable paragraphs), this item is unresolved
(454/86031-13; 455/86017-13).
b
Licensee Actions on Suspected Drug Use
Concern: On June 24, 1986, NRC's Region III Office received an
allegation that 13 named current or former employees of a known site
contractor used drugs at a party attended by the alleger. Additionally,
the alleger stated that these individuals used drugs in the Byron
Station parking lot during lunch hour.
The contractor performs
electrical installation / modification work on Unit 2, which is under
construction, and modification work on Unit 1, which is operating.
The NRC's Region III office notified the licensee of the allegation
and provided a list of the 13 names.
79
.
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Licensee Action:
In keeping with the licensee's established drug
awareness program, the current employees (9) were interviewed by Byron
Station Management. The nine employees were relieved of all duties,
their photo identification security badges and access key-cards were
revoked, and access to Byron Station denied pending the outcome of
CECO's investigation.
In keeping with CECO procedures, the nine employees provided an
observed urine specimen, at a local medical facility, for analysis.
After drug testing, four individuals showed positive results for THC
(active ingredient of marijuana) and were subsequently terminated.
The other five individuals were returned to duty after testing showed
no evidence of drug usage.
The remaining four named individuals who are no longer employed at
Byron Station will be tested for drug usage if and when they are
scheduled for re-employment.
In addition to the drug testing, the
licensee conducted a search of the electrical contractor's office
facilities and the parking lot utilized by construction personnel.
This search was conducted with trained dogs.
No drugs were found
during the search.
The four individuals that were terminated had been employed as QC
inspectors for the electrical contractor.
The licensee initiated a
sample reinspection of these four individuals' work. This reinspection
was performed by Pittsburgh Testing Laboratory (PTL) with the following
results:
Inspector "A",
99 items reinspected with zcro rejects.
Inspector "B",113 items reinspected with one rejectable attribute
(slag inclusion in a weld). The weld was subsequently repaired.
Inspector "C", 149 items reinspected with zero rejects.
Inspector "D", 104 items reinspected with zero rejects.
, The one unacceptable seld was considered to be an isolated case.
Conclusions: This allegation was substantiated, in part, in that four
of the nine named individuals showed positive results when tested for
drugs.
The termination of the four individuals testing positive was
in keeping with CECO procedures. The past work of these four
individuals was found to be adequate based on a sample reinspection of
their work. No violations o deviations were identified.
,
80
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6.
Onen-Items
Open items are matters which have been discussed with the licensee, which
will be reviewed further by the inspector, and which involves some action
on the part of the NRC or licensee or both. An open item disclosed
during this inspection is discussed in Paragraph 5.a(77) of this report.
7.
Unresolved Items
Unresolved items are matters about which more information is required in
order to ascertain whether they are acceptable items, violations, or
deviations.
Unresolved items disclosed during this inspection are
disclosed in Paragraphs 5.a(82), 5.a(83), and 5.a(84) of this report.
8.
Meetings with the Licensee
a.
During a meeting with licensee personnel in the NRC's Region III
Office on July 2, 1986, the findings to date of this special
inspection were discussed. As a result of this meeting, the
licensee initiated CECO QA Audit 6-86-201 which involved approximately
36 man weeks of audit / inspection effort. This audit resulted in Ceco
QA issuing five findings (violations), four observations, and two
open items.
b.
During a meeting with licensee personnel in the Region III Office on
October 1,1986, the licensee briefed Region III on the results of
their investigation of the alleged forged inspection reports. See
Paragraph 5.a(76) above for the results of the licensee's investigation.
9.
Exit Interview
The Region III inspector met with licensee representatives (denoted under
Paragraph 1) at the conclusion of the special inspection on October 22,
1986. The inspector summarized the scope and findings of the inspection
and also discussed the likely informational content of the inspection
report with regard to documents or processes reviewed during the
inspection.
The licensee was also informed that potential enforcement
options were being considered.
The licensee acknowledged this information and did not identify any such
document or processes as proprietary.
Attachment:
Cross Reference: Violation to Report Detail.
I
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_
BYRON STATION-
REPORT NO. 454/86031; 455/86017L
Cross Reference:
Violation to Report Details
Y
Item
Criterion
. Paragraph
Violation
'
A1
5.a(15)
Failure to impose on site-contractors (U1, U2)
B1
I
5.a(6)
Lack of freedom to verify inspection (U1~, U2)
B2
II
5.a(14).
Failure to indoctrinate / train QA/QC personnel
(U1,U2)
,
II
5.a(54)
Failure to assure QA/QC personne1'are
properly qualified / certified (U1, U2)
.
B3
III
5.a(11)
Failure to assure that design changes were
approved by original design organizations.
'
(U2)
III
5.a(41)
Failure to assure use-as-is dispositions on
DRs/NCRs are approved by original design
organization. (U2)
.
a
B4
V
5.a(15)
Failure to follow procedures-(Unit 1 turnover).
<
l
(U1)
}
V
5.a(15)
Failure to have a proceduralized system
for Byron construction to notify Byron
Operations of deficiencies that could
i
impact safe operations. (U1)
i
V
5.a(51)
Failure to assure that activities affecting
quality are accomplished in accordance
-
with approved instructions. (U2)
V
5.a(53)
Failure to assure that activities affecting
quality are prescribed by documented
'
procedures. (U2)
B5
VI
5.a(81)
Failure to assure that activities affecting
,
quality are accomplished in accordance
with approved procedures (working to
verbal / memo instructions). (UI, U2)
,
B6
X
5.a(48)
Failure to assure that inspections are
j _
performed to verify conformance to design
.
(inspections not performed per CECO
i
directions). (U1)
'
B7
XIV
5.a(15)
Failure to establish a system to accurately
status inspections to preclude bypassing
,
required inspections. (U1, U2)
i
B8
XV
5.a(11)
Failure to assure that nonconforming items
are reworked in accordance with NCR/DR
program. (U2)
'XV
5.a(22)
Failure to control nonconforming items to
'
prevent their inadvertent use. (U2)
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.
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l
B9
XVI
5.a(15)
Failure to assure that conditions adverse to
quality were promptly identified and
corrected.(U1)
XVI
5.a(26)
Failure to assure that conditions adverse to
quality were promptly identified and
corrected.(U2)
XVI
5.a(28)
Failure to assure that corrective action to
prevent recurrence is complete prior to
closing the NCR. (U2)
XVI
5.a(39)
Failure to assure that conditions adversd
to quality were promptly identified and
corrected. (U1)
XVI
5.a(41)
Failure to assure that conditions adverse
to quality are determined and corrective
s
action taken to preclude repetition. (U2)
/
XVI
5.a(81)
Failure to assure that conditions adverse
to quality were promptly identified and
corrected.(U1,U2)
B10
XVII
5.a(47)
Failure to maintain sufficient records to
furnish evidence of qualifications of
personnel. (UI, U2)