ML20235P329
| ML20235P329 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 04/30/1987 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20235P327 | List: |
| References | |
| 3011K, NUDOCS 8707200451 | |
| Download: ML20235P329 (38) | |
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Commenwcalth Edia:n Mj One First National Plaza, Chicago, Illinois Address Reply to: Post Offe Box 767 Chicago, Illinois 60690 0767 l
April 30, 1987 i
i Mr. A. Bert Davis Regional Administrator U.S. Nuclear Regulatory Commission I
Region III I
799 Roosevelt Road iT
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Glen Ellyn, IL 60137 3
Subject:
Byron Station Units 1 and 2 I
Response to I.E. Inspection Report l
C Nos. 50-454/86031 and 50-455/86017 1
7 NRC Docket Nos. 50-454 and 50-455_
t References (a): December 5, 1986 letter from C. J. Paperiello to Cordeli Reed (b): March 10, 1987 letter from N. J. Chrissotimos i
to Cordell Reed
Dear Mr. Davis:
Reference (a) provided the results of a special inrpection by R. S.
Love on May 27 through October 22, 1986 of allegations regarding electrical work at Byron Station. As a result of this inspection and an enforcement conference in the NRC Region III office on January 7, 1987, certain activities were found in violation of NRC requirements. Attachment A of this letter contains commonwealth Edison's response to the Notice of Violation enclosed with reference (b). Our response also addresses actions at Braidwood Station to avoid similar types of violations, where applicable. On April 7, 1987, a 3-week extension was granted a>n the due date for the response to the Notice of Violation.
Our review of items 2c and 5f has not concluded these issues represent violations of 10 CFR 50, Appendix B.
In light of the information provided in Attachment A, we request the NRC te reconsider whether these items represent violations of NRC requirements.
Please direct any questions regarding this matter to this office.
Very truly yours,
[or D. L. Farrar Director of Nuclear Licensing g 139 Attachment cc: Byron Resident Inspector
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ATTACHMENT A VIOLATION 1 10 CFR Part 21, Section 21.31, as implemented by Commonwealth Edison company Topical Report (CEl-A), Section 7, requires licensees for nuclear power plants to assure that each procurement document for a facility, or a basic component issued on or after January 6, 1978, specifies when applicable, notification to vendors and contractors that the provisions of 10 CFR Part 21 apply.
Contrary to the above, Commonwealth Edison Company failed to specify in their contract with Hatfield Electric Company (electrical installation contractor) that the provisions of 10 CFR Part 21 applied. The contract with Hatfield Electric Company was signed prior to the effective date of 10 CFR Part 21, however, there have been approximately 50 amendments to the contract since January 6, 1978.
Corrective Action Taken and Results Achieved commonwealth Edison Company acknowledges an oversight of executing supplemental contract change documents to identify that the provisions of 10 CFR Part 21 apply to the Hatfield Electric Company contract. However, it should be noted that NUREG-0302 (Public Regional Meeting - 10 CFR Part 21)
Question / Answer, 21.31, Q-7, response states:
"A Purchaser does not have an obligation to amend existing long-term contracts to specify that Part 21 applies." Also, NUREG-0302, Question / Answer, 21.31, Q-8, states:
"Section 21.31 requires that each procurement document issued on or after January 6, 1978 specify the applicability of Part 21.
Although Part 21 does not require that each procurement document already in existence on January 6 be revised to specify Part 21 applicability, the specification should be added to any subsequent amendments or orders which are issued after January 6, 1978."
This response (to Q-8) was in reply to a question asked about an established open order for spare parts with a supplier.
Finally, NUREG-0302, Question /
Answer, 21.31, Q-5, states that:
" Contractors who knowingly supply basic components are subject to Part 21 even if Part 21 is not referenced in their contracts."
Commonwealth Edison Company's understanding of the applicability of 10 CFR Part 21 notification as clarified by NUREG-0302 did not include site labor contracts established prior to January 6, 1978.
Further, we believe it was clearly demonstrated to the U.S. NRC inspector that the applicability of provisions of 10 CFR Part 21 have been provided to the site contractors including Hatfield Electric Company as a part of the Byron site's mandatory NRC reporting regulations which have been posted since 1978.
Additionally, Byron site contractors have, as a requirement of Commonwealth Edison Company, established procedures for reporting significant deficiencies to Commonwealth Edison Company for evaluation and deportability.
In turn, Commonwealth Edison company has established procedures for evaluating significant deficiencies reported by site contractors to determine the requirements for U.S. NRC notification.
t 4 In order to avoid further conflicts on the interpretation of applicability of 10 CFR Part 21 notification, Commonwealth Edison has amended all existing Byron labor contracts to identify that the provisions of 10 CFR Part 21 apply.
Corrective Action to Avoid Further Violation Not Applicable Date When Full Compliance Was_ Achieved Existing Byron labor contracts were amended by January 5, 1987.
Braidwood Response Existing Braidwood labor contracts will be amended by May '., 1987.
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9 4-VIOLATION 2a
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10 CFR 50, Appendix B, Criterion V, as implemented by Commonwealth Edison Company Topical Report (CE l-A), Section 5, requires that activities affecting quality be prescribed by documented instructions or procedures and be accomplished in accordance with these instructions or procedures.
Contrary to the above, licensee and contractor personnel failed to follow established procedures or procedures were found to be inadequate or non-existent. Specifically, as of July 18, 1986, Commonwealth Edison Company did not have a proceduralized system for Byron construction to notify Byron operations of deficiencies which could potentially impact the safe operation of Unit 1, which is operating.
Corrective Action Taken and Results Achieved In the past, Unit 2 construction deficiencies considered to have a potential. impact on Unit 1 operations were presented to the Byron Startup superintendent for action. We believe this informal system was effective, but was limited to the amount of information presented to the Startup Superintendent. A formal system has now been created.
Dyron Station management has issued procedure BAP 1250-1 with Form 1250-Tll, "Possible Deviation / Discrepancy Report". This procedure outlines the method for reporting possible reportable deficiencies between project groups and Station management. After issuance of the aforementioned procedure, the project Construction Department incorporated Form 1250-T11 into its Site Instruction No. 121, Revision 1 dated August 5, 1986.
Corrective Action to Avoid Further Violation We believe'the identification of construction deficiencies and their evaluation for impact on Unit 1 operations is now adequately prescribed by procedures and instructions.
Date When Full Compliance Was Achieved Site Instruction No. 121, Revision 1 was approved for-use August 26, 1986.
Braidwood Response L.K. Comstock procedures 4.13.2 " System Release to Operation" (RTO) and 4.13.3 " Area Completion / Turnover" assure that all required items are installed and that the appropriate quality documentation exists.
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Braidwood Project Construction Department Procedure PCD-37 " Area Turnover and Access Control Procedure" provides a uniform and controlled method for Project Construction to turnover to the Station areas of the building and items which are not included in a system documentation package.
Both of these systems have proceduralized mechanisms to inform station Operations of deficiencies. PCD-37 cctivities are overviewed by QA on a surveillance basis.
Braidwood Project Management and/or Project Construction Department procedures are being revised to include a control process similar to Byron l
Site Instruction 121 which will take effect after the RTO and ATO processes have been completed for a given system or building area. This procedure is expected to be completed by May 30, 1987.
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l The Area completion / Turnover Program was recently reviewed by NRC Region III and found acceptable. The details of this review are documented in NRC Inspection Report 456/87-007 and 457/87-006.
Additionally, QA had prepared a " Fuel Load Checklist" and a " Mode 2 Checklist" that listed all known open deficiencies (audit, surveillance, NCR, contractor deficiency) that affected Unit 1.
These items were evaluated by the station for potential effect on Unit 1.
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VIOLATION 2b 10 CFR 50, Appendix B, Criterion V, as implemented by commonwealth Edison Company Topical Report (CE 1-A), Section 5, requires that activities l
affecting quality be prescribed by documented instructions or procedures and be accomplished in accordance with these instructions or procedures.
l Contrary to the above, licensee and contractor personnel failed to follow established procedures or procedures were found to be inadequate or non-exit. tent. Specifically, as of July 18, 1986, Hatfield Electric Company (electrical contractor) failed to ensure that approximately 360 inspection reports were contained in the Unit 1 turnover packages as required by Hatfield Procedure 22A, Section 5.1.
Corrective Action Taken and Results Achieved The concern relative to outstanding Unit 1 inspection reports was addressed by Commonwealth Edison Company Quality Assurance and identified as Finding #1 in their Audit 6-86-201.
This audit details the circumstances surrounding the outstanding inspection reports and Hatfield QA program inadequacies that contributed to the condition (i.e., inadequate records turn-over due to insufficient tracking of open inspection reports).
As documented in the contractor response to Audit 6-86-201, the group of outstanding Unit I reports was reviewed and turned over to Commonwealth Edison Company via Hatfield transmittals 293, 294, 313, and 314 on July 24, 1986 and August 6, 1986.
Corrective Action to Avoid Further Violation The following actions were implemented to establish better control of inspection reports:
1)
A centralized consolidated log was established in the contractor's main QA/QC office area for tracking all open inspection reports.
Prior practice involved individual logs for the various reports which were being maintained in several different locations by different l
clerical employees.
2)
Open inspection reports (OIR's) were accounted for, retrieved from various field stations, and filed in the main QA/QC office pending processing in accordance with Hatfield Procedure 6.
3)
Hatfield Procedure Change Notice (PCN) 54 was initiated on August 7, 1986 and approved for use on August 11, 1986. This PCN established specific routing and processing requirements to enhance the OIR system.
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A weekly surveillance of the OIR system by Hatfield QA was implemented July 21, 1986 to assure proper report processing in accordance with the requirements of Hatfield Procedure 6.
5)
Detailed instructions for performing the review of final QA records were prepared via Hatfield letter 2331 to assure compliance with the criteria provided in Hatfield Procedures 22 and 22A. These instructions were issued on August 11, 1986 and documented training was completed for all Hatfield QA engineering personnel on the same date. Those instructions have since been incorporated into Hatfield Procedure 22, Revision 11.
6)
The Hatfield practice of issuing blank inspection reports in blocks of numbers was discontinued as of August 25, 1986. This was documented by Hatfield QA Directives 2339 and 2346.
Inspection report forms are now being dedicated to specific components prior to issuance instead of blanket issuance to a designated supervisor.
Additionally, the contractor has implemented a work package program for all work performed under the Nuclear Work Request Program. The work package program provides a more structured method of report issuance and accountability.
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Hatfield QA surveillance 24-86 was initiated on August 29, 1986.
This surveillance produced a computerized listing by report number of the primary inspection report types. Hatfield Quality Assurance reviewed this listing to establish total accountability of all such inspection reports issued prior to August 29, 1986. The completed printouts (and data base) have been retained by Hatfield QA for report accountability purposes and copies have been turned over to Commonwealth Edison Company.
Date When Full Compliance was Achieved All inspection reports were accounted for by August 29, 1986. The programs and procedure revisions described above have been approved and implemented as of the dates shown.
Braidwood Response L.K. Comstock does not utilize an "Open Inspection Report" System.
L.K. Comstock procedures 4.13.2 " System Release to Operation (RTO) and 4.13.3
" Area completion / Turnover" assure that all required items are installed and that the appropriate quality documentation exists.
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~The Area completion / Turnover program was recently reviewed by NRC Region III and found acceptable. The details of this review are documented in NRC Inspection Report 456/87-007 and 457/87-006.
Utilizing these procedures, the L.K. Comstock' method for determining the status of installation and inspection of an individual item is based on a I
two part review. First, a determination is made as to what attributes require I
inspection (such as configuration, welding, bolting). Second, a review of the quality control files is made to assure that documentation of the. inspection of these attributes is on file.
L.K. Comstock procedures 4.13.2 and 4.13.3 were audited by Commonwealth Edison QA during Audit 20-87-504 (February, 1987) and were found to be properly implemented.
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4 VIOLATION 2c 10 CFR 50, Appendix B, Criterion V, as implemented by Commonwealth Edison Company Topical Report (CE l-A), Section 5, requires that activities affecting quality be prescribed by documented instructions or procedures and be accomplished in accordance with these instructions or procedures.
i Contrary to the above, licensee and contractor personnel failed to i
follow established procedures or procedures were found to be inadequate or non-existent.
Specifically, rework requests 7510, 8854, 6957, 6967, 9006, 9017, 9018 and 9055 had inadequate work descriptions which resulted in work being performed outside the scope of the work request by verbal direction.
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Response
We believe the instructions contained in Hatfield Procedure 7A and Form HP-7A-1, both direct and implied, were of a type appropriate to the circumstances for the cited rework requests. Hatfield Procedure 7A, Paragraph 2.1, states "The scope of this procedure includes the removal and reinstallation of installed work."
The rework request Form HP-7A-1, under
" scope of rework", provides a columnar matrix depicting " removal comp".
Procedure 7A Exhibit C " Instruction for completing Form HP-7A-1", Article IV, states " field will initial... when removal is completed (as applicable) and
" field will initial... when reinstallation is completed (as applicable)".
Rework requests 7510, 8854, 6957, 6967, 9006, 9017 ar.d 9018 limited the scope of the work request by describing the removal requirements in section 4 of the rework request Form HP-7A-1.
For example, rework request (Form HP-7A-1) 7510 states "determ cables and sealtites at valve 10G057A".
This rework request did not describe the reinstallation in section 4 of the form, but as the information in the preceding paragraph suggests, the HP-7A-1 forms not only cover the removal, but also the reinstallation process.
In every case, the reinstallation was completed and documented on the request request form. The work was reinspected and approved and the equipment was successfully turned over for required testing.
Rework request 9055, in section 4, stated " channels T-10 and T-12 l
are reversed at the reactor side of the reactor head plate".
In section 7 i
of the form, the " scope of rework" column listed " cable termination T-10 and I
T-12".
This non-safety related rework request identified the problem and limited the scope of the rework by listing the cable terminations. Due to the simple nature of the work, exchanging the termination positions of non-safety related cables, the documented instructions were of a type appropriate to the circumstances.
As with the other "7A's", the work was well documented on the HP-7A-1 rework request form, inspected and approved, j
l and successfully turned over for the required testing.
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- During the construction phase of the plant, it is well understood by electricians that their work (or rework) is geared toward a completed state of installation that meets the design.
If, for example, rework request 7510 would have said "determ cables and sealtites at valve 10G057A and abandon in place", then Commonwealth Edison would agree work would have been done outside the scope of the rework request had the cable and sealtite been installed. However, a very small percentage of rework requests are used to "determ cables and abandon in place", or to accomplish any other l
incomplete installations.
In those cases, directions are almost always included to leave something intentionally undone.
The language used in the rework request fctms is typically in a " shorthand" version that has been correctly interpreted by the electricians over the course of the project.
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For the reasons stated above, Commonwealth Edison does not agree the work instructions on the cited rework requests were not of a type l
appropriate to the circumstances.
In light of this, we request the NRC to reconsider whether this item is a violation of 10 CFR 50, Appendix B, criterion V.
Braidwood Response L.K. Comstock procedures 4.3.16 " Revision / Work Request of all Electrical Equipment", and 4.8.16 " Inspection of Revision to Installed Electrical Equipment" are the Braidwood procedures that relate to this item.
These procedur;s are audited annually by both Commonwealth Edison company Quality Assurance and L.K. Comstock Corporate Quality Assurance Departments. As recently as March 20, 1987, L.K. Comstock audited these 1
procedures and no observations or findings were identified.
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1 L.K. Comstock procedures 4.3.16 and 4.8.16 were audited by Commonwealth Edison Company QA on audit 20-86-560 (October, 1986) and full compliance was verified.
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. VIOLATION 2d 10 CFR 50, Appendix B, Criterion V, as implemented by Commonwealth Edison Company Topical Report (CE l-A), Section 5, requires that activities affecting quality be prescribed by documented instructions or procedures and be accomplished in accordance with these instructions or procedures.
Contrary to the above, licensee and coatractor personnel failed to follow established procedures or procedures were found to be inadequate or non-existent.
Specifically, prior to August 15, 1986, there was no proceduralized system to verify that junction bon covers, cable tray covers, conduit pull sleeves, seal tight conduit, etc. were reinstalled or reassembled after fireproofing work activities had been completed.
Corrective Action Taken and Results Achieved production personnel did a final walkdown of all areas to assure all electrical work was complete. particular attention was paid to junction box covers and seal tight conduit installations. This walkdown was completed in December of 1986. Minor discrepancies were noted and immediately corrected (i.e., missing screw on junction box cover, etc).
In addition, Commonwealth Edison Company QA personnel performed surveillance on February 11, and March 6, 1987. A total of 48 junction boxes and 126 conduits were inspected in areas where penetration sealing work had taken place. No deficiencies were found. The results of the QA surveillance indicate that junction box covers, conduit pull sleeves and sealtite conduits were reinstalled or reassembled after fireproofing work activities had been completed.
Corrective Action to Avoid Further Violation An interface agreement was initiated in late August of 1986 between the electrical contractor (Hatfield) and the penetration sealing contractor.
This agreement requires Hatfield to generate rework requests for electrical work other than the opening of junction boxes, conduit covers and pull sleeves.
The initiation of a rework request form assures a final QC inspection by Hatfield. For the opening of junction boxes, conduit covers and pull sleeves, the interface agreement requires the sealing contractor's QC personnel to verify electrical equipment reassembly following seal work.
This verification is documented in a " Final Verification of Electrical Equipment Re-Assembly Log."
Date When Full Compliance Was Achieved The interface agreement discussed above was developed in late August, 1986.
- l Braidwood Response 1
This violation refers to the removal / replacement of junction box covers, pull sleeve connections and flexible conduit connections that was required to allow the sealing contractor to gain access to install penetration seals.
prior to the sealing contractor starting work, it was decided that electrical support would be supplied by the existing site electrical contractor. The project Construction Department reviewed the type of work l
that would be assigned to the electrical contractor and divided this work into
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the following two categories:
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Removal and reinstallation of covers of junction boxes and conduits, the uncoupling of sealtite connections and the uncoupling of pull sleeve q
connections. This category involved simple tasks which had no special l
inspection requirements other than the connections were to be made hand tight. Therefore, QC verifications were not involved. A system exists to notify L.K. Comstock that the seal contractor has completed his work and that reinstallation may proceed.
B.
Other types of removal such as hanger disassembly are controlled by the
" Rework Request System".
L.K. Comstock procedure 4.8.16 " Inspection of Revision to Installed Electrical Equipment" requires QC inspection of safety related items.
L.K. Comstock Engineering personnel do a final walkdown of all areas to assure all electrical work is complete. particular attention is paid to junction box cover and sealtite conduit installations.
L.K. Comstock procedure 4.13.3 " Area Completion / Turnover" controls this activity.
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. VIOLATION 2e 10 CFR 50, Appendix B, Criterion V, as implemented by Commonwealth Edison Company Topical Report (CE l-A), Section 5, requires that activities l
affecting quality be prescribed by documented instructions or procedures and
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be accomplished in accordance with these instructions or procedures.
j Contrary to the above, licensee and contractor personnel failed to follow established procedures or procedures were found to be inadequate or non-existent. Specifically, during the period February 26, 1985 through July 13, 1986, QA personnel and the QA/QC Supervisors had not received basic indoctrination and training as required by Hatfield Electric Company Procedure 17, Section 5.3.
In addition, as of July 25, 1986, sixteen QC inspectors had i
been certified without prior approval of the Level III inspector as required q
by Hatfield Procedure 17, Section 4.2.
Further, the Hatfield QA Supervisor and the QA Engineer _had not met the audit participation requirements of Procedure 17, Section 5.5.8.3 prior to certification as lead auditors.
Corrective Action Taken and Results Achieved 1
A review of training records for all Hatfield supervisors, managers, and engineers was done for the time period January, 1985 to the present.
Fifteen personnel required indoctrination training to Hatfield Form HP-172.
The results showed that 5 of 15 personnel had not received any training.
Included in these five were the present QC Supervisor, QA Supervisor and 3 QA Engineers.
Immediately after finding this lack of documentation for required training, the five personnel completed indoctrination training in accordance with the Hatfield HP-172 training requirement. Also, the QA/QC Manager had not documented his review of Specification F-2790 Division II Safety Practices and Building Layout. On June 17, 1986 the QA/QC Manager documented his familiarity with these areas.
l Hatfield 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 Hatfield Procedure 17.
This individual's lead auditor certification was withdrawn.
Hatfield Electric, as a result of SSRs 21-86, 22-86 and 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.
Subsequently, the Hatfield certified Level III inspector performed a review of these personnel packages and documented his j
approval of their certification.
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0 l Corrective Action to Avoid Further Violation A detailed review of all QA/QC supervision and QA Engineer program responsibilities has been made and specific training requirements have been placed in the Hatfield Procedures Manual.
Procedure 17, Revision 13 incorporates specific requirements for QA/QC supervisory personnel indoctrination and training as well as enhanced criteria for approving Level III certification.
Approximately 30 persennel were certified subsequent to August 9, 1986. A follow-up surveillance conducted by Hatfield QA verified all contain appropriate Level III review and approval.
Date When Full Compliance Was Achieved All Hatfield QA and QC personnel had complete indoctrination and training as of June 18, 1986.
Braidwood Response (1)
L. K. Comstock Quality Assurance / Quality Control supervisors receive indoctrination and training to applicable procedures, specifications and codes as required by procedure 4.1.3 " Qualification, Classification, and Training of Quality Control Personnel". Training and indoctrination of Quality Assurance / Quality control personnel is current.
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L. K. Comstock Procedure 4.1.3, Section 3.6.1 requires:
"Upon satisfactory completion of the indoctrination, training and testing requirements as defined by this procedure, the candidate is 4
eligible for certification.
The responsible Level III will initiate l
a Certificate of Qualification (Form 56) and inform the candidate of his successful completion. Certifications are valid for a period not to exceed three years."
Form 56 requires the signature of the Level III.
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L. K. Comstock lead auditors are certified in accordance with Procedure 4.14.3 " Qualification, certification and Training of I
Auditors".
Section 3.4.4 establishes the minimum requirements for
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audit participation.
j These procedures are audited annually by both Commonwealth Edison I'
company Quality Assurance and L.K. Comstock Corporate Quality Assurance Departments. As recently as March 20, 1937, L. K. Comstock audited these procedures and no observations or findings were f
identified.
. L.K. Comstock Procedure 4.1.3 was reviewed during Commonwealth Edison QA audit 20-86-536 (November, 1986). QC certifications by a Level i
.III were found to be acceptable. Additionally, all ANSI N45,2.6 certification documentation is reviewed by Commonwealth Edison Company QA.
L.K. Comstock auditor certifications (4.14.3) were reviewed on Commonwealth Edison QA audit 20-86-525 (August, 1986) and found to be acceptable.
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. VIOLATION 2f 10 CFR 50, Appendix B, Criterion V, as implemented by Commonwealth Edison Company Topical Report (CE l-A), Section 5, requires that activities affecting quality be prescribed by documented instructions or procedures and be accomplished in accordance with these instructions or procedures.
Contrary to the above, licensee and contractor personnel failed to follow established procedures or procedures were found to be inadequate or non-existent. Specifically, Commonwealth Edison Company letter of October 8, 1984, instructed Hatfield Electric Company QC inspectors not to inspect certain raceway hanger attributes; however, the design drawings, inspection procedures, and the electrical specifications were not revised to delete these inspection attributes until March 15, 1985. Between October 8, 1984 and March 15, 1985, these attributes were not inspected based on verbal direction from the Hatfield QA/QC Manager.
Corrective Action Taken and Results Achieved i
A March 23, 1984 Hatfield memorandte (No. 1230) documented the attributes of each cable pan hanger detail that were not inspected during the normal contractor Hatfield QC inspection process prior to February 13, 1984.
I Utilizing the information contained in Hatfield memorandum 1230, Sargent &
Lundy developed 15 separate checklists which identified specific attributes to be inspected on 80 randomly selected supports. The data collected from these j
checklists was evaluated to determine if any of the uninspected items identified in Hatfield memorandum 1230 had any design significance. The result, documented in Sargent & Lundy's letter dated October 2, 1984, was that the quality of cable tray support connection work is adequate throughout the plant for both Units 1 and 2.
Commonwealth Edison Company issued a letter dated October 8, 1984, advising Hatfield that inspection of the previously uninspected attributes identified in memorandum 1230 on past installations and on future installations was not necessary.
Sargent & Lundy issued a letter dated November 9, 1984 to supplement their letter of October 2, 1984. This letter reiterated that the items being documented by the contractor's QC inspection of cable tray supports was adequate for future work.
It further stated that "From a design standpoint, every dimension of a cable tray support detail does not require a QC work inspection. Some dimensions are redundant to others for design purposes, however, all of the dimensions are shown for the purpose of fabrication".
Commonwealth Edison Company transmitted Sargent & Lundy's November 9, 1984 letter to Hatfield to enhance their understanding of Commonwealth Edison's previous direction regarding the disposition of memorandum 1230.
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. Based on the above, it was concluded that the documented attributes associated with the QC inspections of pan hangers prior to February 13, 1984 were adequate and no revisions to design documents were required.
Hatfield memorandum 1631, dated December 11, 1984 documents that the responsible QC personnel were informed of the conclusions of the issues relating to memorandum 1230 - that the approved method of cable pan hanger inspections performed prior to February 13, 1984 was adequate and should continue to be implemented by the department.
Corrective Action to Avoid Further Violation The Hatfield cable pan hanger inspection procedure (Procedure 9A) was revised on March 19, 1985 to more clearly reflect the inspection method to be utilized.
Date When Full Compliance was Achieved I
Hatfield Procedure 9A was revised March 19, 1985.
j Braidwood Response We believe the circumstances surrounding this violation are unique to Byron. Cable pan hangers are inspected under L.K. Comstock Procedure 4.8.12.
Deletion of any inspection attributes from this procedure can only be accomplished with a revision to the procedure. Procedure revisions must be approved by QA, PCD and the architect / engineer.
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l VIOLATION 24 10 CFR 50, Appendix B, Criterion V, as implemented by Commonwealth Edison Company Topical Report (CE l-A), Section 5, requires that activities affecting quality be prescribed by documented instructions or procedures and be accomplished in accordance with these instructions or procedures.
- follow established procedures or procedures were found to be inadequate or
'l Contrary to the above, licensee and contractor personnel failed to non-existent. Specifically, Commonwealth Edison Company failed to assure that nonconforming items were controlled in that a Commonwealth Edison field engineer directed the core drilling contractor to continue drilling a cored hole that had been. identified as nonconforming on Hatfield Nonconformance Report 1281. During this event, the core drilling contractor was working under the auspice of the Hatfield Quality Assurance Program.
Corrective Action Taken and Results Achieved Hatfield nonconformance report (NCR) 1281 involves a partially cored hole that deviated from rebar cutting restrictions.
The effect on the rebar was evaluated by Sargent & Lundy and found acceptable. This was documented in Field Change Request 11685.
Corrective Action to Avoid Further violation Hatfield Procedure 21, which governs core drilling operations, was f
revised to require a pre-drilling layout inspection, allow the drilling contractor to completely drill the hole, and then require a post-drilling inspection to check for cut rebar.
Date When Full Compliance Was Achieved Hatfield Procedure 21 was revised in August, 1986.
I Braidwood Response L.K. Comstock performs their own core drilling operations. This operation is controlled by L.K. Comstock Procedure 4.8.25 " Core Drilling Inspection". Section 3.4 of this procedure states:
"The Quality Control Inspector shall initiate an ICR (Inspection Correction Report), Form No. 30, or an NCR (Nonconformance Report),
Form No. 14, per procedure Section 4.11 for any item deviating from l
the above requirements."
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" Absolutely no work is to be performed on a nonconforming, hold tag item, unless a conditional Release Tag is attached to the hold tag or h
an approved disposition is noted on the NCR."
Core drilling inspections (Procedure 4.8.25) for L.K. Comstock were last reviewed on Commonwealth Edison QA audit 20-85-540 and found to be acceptable (July, 1985). Additionally, Commonwealth Edison QA surveillance 6964 (dated March 5, 1987) reviewed one cored hole by L.K. Comstock and found it acceptable.
Proper disposition of NCRs and closure of NCRs (Procedure 4.11.1) was verified on Commonwealth Edison QA audit 20-86-525 (August, 1986) ar.d found acceptable.
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.. VIOLATION 3 10 CFR 50, Appendix B, Criterion X, as implemented by Commonwealth Edison Company Topical Report (CE l-A),Section X, requires a program for inspection of activities affecting quality be established and executed to verify conformance with documented instructions, procedures, and instructions.
Contrary to the above, none of the inspection attributes on Unit 1 Cable Termination Inspection Reports 21105, 21106, 21113, 21114, 21119, 21120, 21115, 21116, 21102, 21103, and 21117 were QC inspected per verbal directions of a Connonwealth Edison Company Field Engineer. These inspection reports are associated with Nuclear Work Request 6EG006 that was issued to remove unqualified SIS wire in various items of equipment and install qualified Rockbestos SIS wire.
Response
This violation involves SIS cable terminations made by Hatfield craft personnel under the direction of Commonwealth Edison project Operational Analysis Department (pOAD) engineers. These terminations were not formally inspected under the Hatfield QC inspection program. However, for the following reasons, we are confident that an acceptable level of quality has been maintained in these cable terminations. The terminations were made with calibrated crimping tools.
If tools are found out of tolerance, a written evaluation is performed to justify the acceptability of past installations.
In addition, Hatfield QC performs periodic in-process inspections of termina-ting activities of all craft personnel to check their cable terminating capabilities. Furthermore, the quality of Hatfield cable terminations has been documented by other cable termination inspections during the time frame the SIS wire was being replaced. Between April and September, 1986, 597 termination inspection reports were generated. Only four reports were rejected for exposed copper or bad crimps.
This computes to a reject rate of 0.67%.
Lastly, POAD field engineers were continually available to the craft presonnel if questions arose regarding those cable terminations.
For the reasons stated above, we believe an acceptable level of quality exists in the subject cable terminations.
Corrective Action to Avoid Further Violation Although we believe sufficient quality exists in the SIS cable terminations, to assure continued quality in the future, QC documentation is now required for safety related cable termination work under the direction of POAD e? ept lifting and landing wires on terminal blocks for testing.
Date When Full Compliance Was Achieve $
The requirement for QC documentation discussed above became effective October 29, 1986
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. Braidwood Response Commonwealth Edison Company nonconformance report (NCR) No. 707 and Project Construction Department Procedure PCD-44 "Non-Rockbestos SIS Wire Walkdown" controlled the identification and replacement of non-Rockbestos SIS
. wire at Braidwood. The replacement of non-Rockbestos wire was' performed in accordance with L.K. Comstock Procedure 4.3.16 " Revision / Work Request of all Electrical. Equipment" by L.K. Comstock craft personnel.
Inspection of the l
wire replacement was performed Jn.accordance with Procedure 4.8.16 " Inspection of Revision to Installed Electrical Equipment" by L. K. Comstock Quality Control inspection personnel.
Procedure PCD-44, covered by Commonwealth Edison NCR 707, was
-verified to be ecceptably closed by Commonwealth Edison QA surveillance 6442.
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. VIOLATION 4 10 CFR 50, Appendix B, Criterion XIV, as implemented by Commonwealth Edison Company Topical Report (CE l-A), Section 14, requires measures be established to provide for the identification of items which have satisfactorily passed required inspections and tests to preclude inadvertent bypassing of such inspections and tests.
Contrary to the above, Commonwealth Edison Company's electrical contractor, Hatfield Electric Company, failed to establish a system to accurately status inspection reports which resulted in 57 required reinspection of nonconforming items in Unit I not being performed prior to July 18, 1986.
Corrective Action Taken and Results Achieved The reinspection of Unit I nonconforming items were completed by July 22, 1986. These reinspection resulted in minor rework on 8 inspection reports involving diesel generator components.
Corrective Action to Avoid Further Violation The corrective actions presented in response to Violation 2b, specifically those details relating to control and issuance of inspection reports (item 6) and the accountability surveillance (item 7) also address this violation.
In addition to those previously described actions, the contractor has implemented a work package system (i.e., installation / inspection report) incorporating a package index to control work assignments issued via Nuclear Work Requests (NWR).
This system, as described in Hatfield Site Instruction L, provides instructions for package development, report initiation and assignment, work completion, and final review and turnover of the package.
Using this system, the scope of the work / inspection is pre-determined by Hatfield engineering and documented on the NWR package index. Upon work completion, the package index is also utilized to assure inspection completion and provide accountability of the associated reports.
Date When Full Compliance Was Achiev_ed The NWR work package system described above was initiated by Hatfield letter 2354 dated August 26, 1986. The revision to Hatfield Site Instruction L was issued December 26, 1986.
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Braidwood Response L. K. Comstock procedures 4.13.2 " System Release to Operation (RTO) and 4.13.3 " Area Completion / Turnover" assure that all required items are installed and that the appropriate quality documentation exists.
Utilizins' these procedures, the L. K. Comstock method for determining the status of installation and inspection of an individual item is based on a two part review.
First, a determination is made as to what attributes require inspection (such as configuration, welding, bolting). Second, a review of the quality control files is made to assure that documentation of the inspection of these attributes is on file.
The Area Completion / Turnover Program was recently reviewed by NRC Region III and found acceptable. The details of this review are documented in NRC Inspection Report 456/87-007 and 457/87-006.
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. VIOLATION Sa 10 CFR 50, Appendix B, Criterion XVI, as implemented by Commonwealth Edison Company Topical Report (CE-1-A), Section 16, requires measures be established to assure that conditions adverse to quality be promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition be determined and corrective action taken to preclude repetition.
Contrary to the above, measures were not established to assure that conditions adverse to quality were promptly identified and corrected.
Specifically, Commonwealth Edison Company and their electrical contractor, Hatfield Electric Company, failed to take prompt action to resolve the Unit 1 I
deficiencies identified on 57 open inspection reports that were found in
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Hatfield's possession on April 12, 1986. Hatfield did not report these open inspection reports to Commonwealth Edison Company until approximately June 10, 1986 and Commonwealth Edison Company did not document nor take corrective action to resolve these deficiencies until July 18, 1986.
Corrective Action Taken and Results Achieved The deficiencies identified on the open inspection reports were processed through the Nuclear Work Request (NWR) program and were resolved by July 22, 1986. The open inspection reports were completed and turned over to Commonwealth Edison Company as of August 6, 1986.
Corrective Action to Avoid Further Violation The following actions have been implemented to prevent further violations of this nature:
1.
The outstanding Unit 1 inspection reports were initiated as a result of the Hatfield Electrical panel Over-Inspection program. The reports were intentionally held by the Hatfield Electrical Inspection Group Leader and therefore, these reports were not processed within the inspection report processing system.
The responsible Hatfield Electrical Inspection Group Leader was terminated on April 22, 1986.
2.
The Hatfield QA Supervisor responsible for failing to provide timely notification of the incomplete Unit 1 reports was replaced in July, 1986.
3.
Hatfield procedure 6 was revised on August 11, 1986 to incorporate instructions for reporting potential deficiencies on equipment installed by others (or previously turned over to the owner) for disposition /
resolution.
4.
The corrective actions presented in our response to Violation 2b established control of inspection reports and deficiencies prior to completion of Unit 2 construction.
Implementation of the NWR program and Hatfield's Work package System after Unit 2 construction completion provides a more manageable system which assures report accountability.
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. 5.
Byron Site Instruction 121, " Reporting of Possible Deficiencies Between l
Project Groups and Station Management" was prepared on August 5,- 1986, with all personnel training completed by September 5, 1986.. Additionally, Station Procedure BAP 1250-1 was issued on July 23, 1986, to address possible deviations reported by the construction Group. Project-4 construction personnel training on BAP-1250-1 was completed on July 29, I
l 1986.
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i Date When Full Compliance Was Achieved The open inspection reports were completed and turned over to Commonwealth Edison as of August 6, 1986. Hatfield Procedure 6 was revised August 11, 1986.
l Braidwood Response l
l We believe the circumstances surrounding this violation are unique to Byron. The system described in the Braidwood response to Violation 2b should preclude the possibility of missing inspection reports.
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VIOLATION Sb 10 CFR 50, Appendix B, Criterion XVI, as implemented by Commonwealth Edison Company Topical Report (CE-1-A), Section 16, requires measures be established to assure that conditions adverse to quality be promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition be determined and corrective action taken to preclude repetition.
Contrary to the above, measures were not established to assure that conditions adverse to quality were promptly identified and corrected.
Specifically, as of July 29, 1986, Commonwealth Edison Company's electrical contractor, Hatfield Electric Company, failed to identify, document and correct nonconforming conduit hanger WP2-1, located in the Auxiliary Building, Columns 15 and L at the 346' elevation. Although this hanger was nonconforming, it had been inspected and accepted by Hatfield QC on May 4, 1982.
Corrective Action Taken (ad Results Achieved Upon notification of the alleged condition, the conduit hanger was inspected by Hatfield QC personnel who confirmed the allegation and documented the unacceptable condition with nonconformance report (NCR) 2059 on July 29, 1986. The conduit hanger was reworked to comply with approved design details and was inspected and accepted. NCR 2059 was reviewed and closed by Hatfield QA on September 15, 1986.
Corrective Aciltn to Avoid Further Violation This deficiency was very specifically identified by component identification, drawing number, report number, and a description of the incomplete / unacceptable attributes affecting the conduit hanger. According to inspection / installation reports, this conduit hanger was installed prior to May 4, 1982. This indicates the person who filed the allegation (a Hatfield QC inspector) had specific knowledge of the unacceptable conditions affecting the conduit hanger for quite some time and he failed to report these conditions in accordance with the requirements of Hatfield's QA Manual Section IV and procedure 6 (reporting of nonconforming conditions). Based on these circumstances, we believe this deficiency was an isolated occurrence.
Nevertheless, Hatfield procedures have been enhanced overall to emphasize inspection and installation requirements since the May, 1982 installation date of this specific conduit hanger.
Date When Full Compliance Was Achieved j
NCR 2059 was closed September 15, 1986.
Braidwood Response l
l We believe the circumstances surrounding this violation are unique to Byron.
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. VIOLATION Sc 10 CFR 50, Appendix B, Criterion XVI, as implemented by Commonwealth Edison Company Topical Report (CE-1-A), Section 16, requires measures be established to assure that conditions adverse to quality be promptly identified and corrected.
In the case of significant conditions adverse to quality, the l
measures shall assure that the cause of the condition be determined and corrective action taken to preclude repetition.
Contrary to the above, measures were not established to assure that conditions adverse to quality were promptly identified and corrected.
Specifically, Commonwealth Edison Company's electrical contractor, Hatfield Electric Company, closed Nonconformance Reports 1772, 1758, 1754, 1798, 1783,
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1802, 1815, 1816, 1818, 1822, and 1825 before the required training was actually provided and in other cases, nine months had elapsed before the training was given.
Corrective Action Taken and Results Achieved This violation involves documentation for training of Hatfield l
personnel indicating completion of action to prevent recurrence for certain l
nonconformance reports (NCR's). Hatfield personnel changes which impacted implementation of the training were not adequately documented on the subject NCR's or back-up records prior to closure of the NCR's.
Hatfield QA initiated a special surveillance on June 27, 1986 to review all NCR's issued from January, 1985 to June 19, 1986 which specified training as action to prevent recurrence. The surveillance involved a review of 793 NCR's.
As a result of this surveillance, personnel still available on the project (regardless of their current assignments) were identified and trained as specified on the applicable NCR.
In those cases where the personnel were no longer employed by Hatfield, indication of their termination was added to the NCR package. Upon completion of the training, Hatfield QA Surveillance 17-86 was closed on August 25, 1986.
With respect to the time interval between initiation of certain NCR's and implementation of the action to prevent their recurrence, a training session was held on August 4, 1986 with Hatfield QA personnel to emphasize that action to prevent recurrence of NCR's must be promptly initiated.
Corrective Action to Avoid Further Violation Hatfield has implemented a system to initiate action to prevent recurrence upon issuance of an NCR.
Documented training on this system was l
conducted for responsible Hatfield QA personnel on August 4, 1986.
Additionally, training that is implemented to prevent recurrence of NCR's is now being documented on the NCR (i.e., scope of training assignment). Those cases affected by personnel terminations or reassignments are now being documented on the NCR or in an attachment thereto.
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i u Date When Full Compliance Was Achieved Hatfield QA surveillance 17-86 was closed' August 25, 1986.
Braidwood Response We believe this item is unique to Byron.
It should be noted,-
however, that L. K. Comstock procedure 4.11.1 "Non-conforming Items", Section 3.3.9, requires the completion of corrective. action and action to prevent recurrence, including training, to be verified by QC prior to closure of the NCR.
This procedure is-audited by both Commonwealth Edison Company Quality Assurance and'L. K. Comstock Corporate Quality Assurance annually. As recently as March 20, 1987, L. K. Comstock Corporate Quality Assurance audited this procedure and no findings or observations were identified.
Proper disposition of NCRs and closure of NCRs (Procedure 4.11.1) was checked by Commonwealth Edison QA audit 20-86-525 (August, 1986) and found acceptable.
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VIOLATION _5d 10 CFR 50, Appendix B, Criterion XVI, as implemented by Commonwealth Edison Company Topical Report (CE-1-A), Section 16, requires measures be established to assure that conditions adverse to quality be promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition be determined and corrective action takan to preclude repetition.
Contrary to the above, measures were not established to assure that conditions adverse to quality were promptly identified and corrected.
Specifically, as of June 9, 1986, commonwealth Edison Company failed to document and initiate a review of weld traveler cards, including inspection results, that were missing or never prepared on approximately 150 Unit I riser collars (vertical cable tray supports).
Commonwealth Edison Company was aware that these deficiencies existed in Unit 2 since January 1986 and failed to initiate corrective actions for Unit 1.
Corrective Action Taken and Results Achieved on June 20, 1986, Sargent & Lundy Project Instruction (PI)-BB-106 was issued for the inspection of Unit 1 riser collar welds.
From June 23 to June 25, 1986, a Sargent & Lundy Level III weld inspector inspected 50 of the approximately 150 Unit 1 and common riser collar welds. On July 29, 1986, Sargent & Lundy documented their engineering evaluation of the Unit 1 riser collar welds they inspected. Sargent & Lundy's evaluation of the discrepancies, based on a worst case analysis, determined that the riser collar welds are within the allowable stress limits. However, one case was identified where the as-found condition of the welds was less than the design drawing requirements.
These riser collar welds were repaired and accepted by llatfield QA on Septetaber 16, 1986.
Corrective Action to Avoid Further Violation As identified in Commonwealth Edison's QA Audit 6-86-201, no proceduralized system existed at Byron for the construction departments to formally notify the Station Operating Department of possible deviations or discrepancies found on Unit 2 which could affect Unit 1.
As a result, the Station issued Procedure BAp 1250-1, with Form 1250-T11 "Possible Deviation /
Discrepancy Report", on July 23, 1986.
In addition, Byron Site Instruction 121, " Reporting of Possible Deficiencies Between Project Groups and Station Management", Revision 1, dated August 5, 1986 was also developed and implemented.
Date When Full Compliance Was Achieved Sargent & Lundy's engineering evaluation was completed by July 29, 1986. The deficient riser collar was repaired and accepted by Hatfield QA on September 16, 1986.
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Braidwood Response We believe the circumstances surrounding this violation are unique to Byron. The system described in the Braidwood response to Violation 2b should preclude the possibility of missing weld records.
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VIOLATION 5e 1
10 CPR 50, Appendix B, Criter$on XVI, as implemented by Commonwealth Edison Company Topical Report (CE-1-A), Cection 16, requires measures be established to assure that conditions adverse to quality be promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition be determined and corrective action taken to preclude repetition.
Contrary to the above, measures were not established to assure that conditions adverse to quality were promptly identified and corrected.
Specifically, Commonwealth Edison Company and their electrical contractor, Hatfield Electric Company, closed or directed the closure of Deficiency Reports 8426, 8501, 8504, 8534, and 8049 without a clearly documented basis for their closure, and without proper design approval by Westinghouse or Sargent & Lundy,,
ccrrective Action Taken end Results Achieved DR 8426; This deficiency report (DR) resulted from Hatfield QC "overinspection" of electrical panel 2PS47J. The Hatfield DR was closed based on an accept-as-is disposition from Commonwealth Edison l
Company Project Construction Department (PCD). This disposition was l
based on an evaluation of the reported conditions and a subsequent i
vendor document review and field inspection.
DR 8501: This DR was elevated to a nonconformance report (NCR) 1992 in accordance with Hatfield Procedure 6.
Based on issuance of the l
NCR, DR 8501 was closed. NCR 1992 was subsequently reviewed and dispositioned by Commonwealth Edison Company PCD and QA, and closed by Hatfield.
DR 8504: This DR was initiated when no QC inspection report was made for reinstallation of cable 2MS518 under rework request 07541. A j
followup QC inspection of the cable reinstallation showed the installation was acceptable as is because the cable was pushed, not pulled, into the conduit.
DR 8534: This DR involved the installation of thermocouple assemblies. Due to their unique configuration, the Hatfield QC inspector became confused while inspecting this installation to the criteria in Hatfield Procedure 10 (cable pulling). According to the Hatfield engineering disposition of the DR, the inspection attributes referenced by the QC inspector were not applicable due to the configuration of the equipment.
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. DR 8049: This DR involved loose fittings on instruments. Based on the l
Commonwealth Edison Company PCD engineer's inspection and subsequent l
evaluation, it was determined that the loose fittings on the instruments did not pose a problem that would deteriorate after time. Based on the PCD documented direction, Hatfield closed DR 8049. PCD subsequently reinspected the connections and found that the fittings were still loose and that further loosening could not occur due to the configuration of the assembly. As further assurance, Commonwealth Edison Company startup deficiency 68612 was initiated and the fittings have since been tightened.
PCD documented further justification for their disposition of all DR's identified by Commonwealth Edison QA as having insufficient information to support the disposition. The Commonwealth Edison QA review of Hatfield DR's is documented in Byron letter 15422.
Correctivy_ Action to Avoid Further Violation The majority of these items involved reporting of potential deficiencies by Hatfield QC on vendor installed components associated with electrical panels / equipment resulting from a request by Commonwealth Edison PCD for Hatfield QC to conduct an "overinspection" of such equipment. As discussed in the response to Violation 5g, this resulted in the application of Hatfield caceptance criteria to components installed by others (vendors) in accordanta with their own QA programs and specifications.
Based on the apparent conflict or acceptance criteria and Hatfield's proceduralized requirements to report cable related discrepancies through their DR system, Hatfield documented these conditions and submitted the DR's to PCD for resolution. Upon review, PCD engineers determined many of the reported conditions to be acceptable based on available vendor information or prior similar conditions four.d acceptable.
In many cases, the PCD disposition did not provi$9 a sufficient explanation or reference to other information to clearly substantiate the PCD disposition.
The following actions have been taken to avoid recurrence of the problem described above:
- 1) Commonwe61th Edison Company PCD electrical group personnel were trained on the proper application and use of an accept-as-is disposition with emphasis on the requirements for obtaining architect / engineer approvals.
This training was issued by a July 21, 1986 letter to appropriate PCD electrical group personnel.
- 2) Commonwealth Edison Company PCD clarified the intended scope of Hatfield QC overinspection of vendor equipment and Hatfield's translation of this activity into their inspection procedures. Hatfield Procedure Change Notice 063 to Procedure 12A accomplished this. Additional clarification for reporting potential deficiencies affecting equipment beyond the scope of Hatfield's contract was provided in Procedure Change Notices 054 and I
06'i and subsequent revision 16 to Procedure 6.
This revision also clarified the proper application of the Hatfield DR and NCR.
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0 Date When Full Compliance Was Achieved The concerns identified by Commonwealth Edison QA in Byron letter 15422 were resolved by October 14, 1986.
Braidwood Response The L.K. Comstock QA/QC Program does not utilize a " Deficiency Report" System. The L.K. Comstock Inspection Correction Report (ICR) would be utilized to document similar types of conditions.
L.K. Comstock Procedure 4.11.2 " Inspection Correction Report" controls the issuance, review and final disposition of ICRs. Procedure 4.11.2 does not allow " accept-as-is" dispositions. Any item for which an " accept-as-is" is requested must be processed on an L.K. Comstock NCR.
Contractor NCR's are processed by PCD in accordance with Procedure PCD-23 " Site Contractor Nonconformance Report /
Procedure Processing".
In addition, Procedure PCD-45 " Project Construction Technical Evaluation of Selected Closed L.K. Comstock Nonconformance Report" was utilized to verify the adequacy of the NCR content through all phases of problem identification and resolution, including corrective actions to prevent recurrence.
Procedure PCD-2.3 was verified by Commonwealth Edison QA as being acceptably performed on Audit 20-86-531 (September, 1986).
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. VIOLATION Sf 10 CFR 50, Appendix B, criterion XVI, as implemented by Commonwealth Edison Company Topical Report (CE-1-A), Section 16, requires measures be established to assure that conditions adverse to quality be promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition be determined and corrective action taken to preclude repetition.
Contrary to the above, measures were not established to assure that conditions adverse to quality were promptly identified and corrected.
Specifically, Hatfield Electric Company failed to assure that nonconforming conduit COA 62F9, identified as nonconforming on conduit inspection checklist 4736, was reworked in accordance with documented procedures.
Response
The rework of conduit COA 62F9 was performed in accordance with Hatfield Procedure 6 " Reporting of Damaged or Nonconforming Material and Equipment." Paragraph 5.1.1 of procedure 6 states:
" Items discovered to be deficient during routine surveillance or inspection activities shall not be considered a nonconformance provided the following conditions are satisfied:
5.1.1.1 The deficiency is corrected prior to the acceptance of the final assembly, and the deficiency can be documented by identifying it as unacceptable on the appropriate inspection checklist when applicable.
5.1.1.2 The deficiency does not affect any work previously accepted.
5.1.1.3 No programmatic violation or weakness is evident.
5.1.2 Deficient items that meet the requirements of 5.1.1.1 thru 5.1.1.3 shall be tracked thru the use of open inspection reports."
The deficiency involved the elevation of conduit COA 62F9 which was out of tolerance at hanger SCC-1 and was identified on inspection form HP-201
- 4736 an an unacceptable inspection element.
To correct the deficiency, the detail J attachment on hanger SCC-1 needed to be removed and then reinstalled at the proper elevation. This work fell into the scope of the Hatfield open inspection report (OIR) program and did not require a HP-7A-1 Rewcrk Request to be generated for the following reasons:
1.
Acceptance of the final assembly, the conduit run, is accomplished by the generation and acceptance of the HP-01, Class I Exposed Conduit Inspection Checklist.
2.
The detail J is accepted by the HP-201 inspection for its elevation. The fact that the welds had been previously accepted does not require a HP-7A-1 Rework Request because final acceptance is based on the complete assembly. The acceptance of hanger SCC-1 is not contingent upon the detail J.
The scope of Hatfield Procedure 7A " Rework Control" does not include the reinspection of reworked appurtenances, i.e. the welds on the detail J.
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There were no programmatic violations or weaknesses evident.
(Ref. Procedure 6 para 5.1.1.3)
Based on the above, the rework of the detail J attachment fell into the scope of the OIR program and a DR, NCR or HP-7A-1 was not required. The welds for the detail J were properly reinspected on weld traveler 81221 and the elevation was verified correct upon reinspection on HP-201 #4736. We believe the subject conduit installation was accomplished in accordance with documented procedures. Accordingly, we request the NRC to reconsider whether this item constitutes a violation of 10 CPR 50 Appendix B, Criterion XVI.
Braidwood Response The L.K. Comstock QA/QC Program does not utilize a " Deficiency Report" System. The L.K. Comstock Inspection Correction Report (ICR) would be utilized to document similar types of conditions.
L.K. Comstock procedure 4.11.2 " Inspection correction Report" controls the issuance, review and final disposition of ICRs. Procedure 4.11.2 does not allow " Accept-as-is" dispositions. Any item for which an " accept-as-is" is requested must be processed on an L.M. Comstock NCR.
Contractor NCR's are processed by PCD in accordence with Procedure PCD-23 " Site Contractor Nonconformance Report /
Procedure Processing".
In addition, Procedure PCD-45 " Project Construction Iechnical Evaluation of Selected closed L.K. Comstock Nonconformance Reports" was utilized to verify the adequacy of the NCR content through all phases of problem identification and resolution, including corrective actions to prevent recurrence.
Procedure PCD-23 was verified by Commonwealth Edison Company QA as being acceptably performed on Audit 20-86-531 (September, 1986).
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VIOLATION 5q j
10 CFR 50, Appendix B, Criterion XVI, as implemented by Commonwealth f
Edison Company Topical Report (CE-1-A), Section 16, requires measures be l
established to assure thet conditions adverse to quality be promptly identified j
and corrected.
In the case of significant conditions adverse to quality, the I
measures shall assure that the cause of the condition be determined and corrective action taken to preclude repetition.
Contrary to the above, measures were not established to assure that conditions adverse to quality were promptly identified and corrected.
Specifically, corrective actions for identified deficiencies were improper in that the deficiencies were accepted by Commonwealth Edison Company or Hatfield Electric Company personnel without proper design (Westinghouse or Sargent and I
Lundy) approval in the following cases:
(1) Conduit inspection checklist 4902 identified that conduit C2A7924 contained 370' of bends although electrical specifications limit the maximum amount to 270*;
(2) Modification inspection checklist 5101 identified exposed copper at a termination lug; l
(3) Conduit inspection checklist 4788 identified a missing "O" ring for conduit C2A1209 although electrical specifications requices an "O" ring.
Corrective Action Taken and Results Achieved l
1.
Conduit Inspection Report Hp-201 #4902 was dispositioned by Hatfield i
engineering per Sargent & Lundy Standard EB-146 which specifies 270'
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maximum bend as a recommendation to avoid overtensioning of the cable during installation (i.e. cable pull).
Since the cable had previously been installed and was not overtensioned (based on a documented QC inspection) it was concluded that there was no advantage to reworking the conduit.
2.
Equipment Modification Inspection Report Hp-12A-1 #5101 was closed by Hatfield based on documented direction from Commonwealth Edison Company pCD.
The reported deficiency (exposed copper at a termination lug) involved vendor installed components beyond the scope of Hatfield's specification. The deficiency was evaluated by pCD and found acceptable.
1 3.
Conduit Inspection Report Hp-201 #4788, which reported missing 0-rings in
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a sealtite connector, was accepted as documented by pCD on January 13, 1986. Sargent & Lundy Standard EB-146 was revised shortly thereafter (March 12, 1986) to allow the deletion of 0-rings on indoor applications.
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' Corrective Action to Avoid Further Violation This violation involves certain OIRs being dispositioned " accept as-is" solely by contractor engineering personnel or PCD engineers.
It should be noted that many of these cases involved Hatfield reports of potential deficiencies in vendor installed components of electrical panels. Since the scope of these inspections was not clearly defined by PCD, Hatfield QC inspection criteria were utilized ar.d resulted in a significant number of rejected reports which, in most cases, were acceptable per the equipment supplier's program / specifications. Hatfield QC inspection personnel appeared confused regarding the scope and boundaries of these inspections and the proceduralized acceptance criteria did not clea:1y coincide with the intent of the program. Compounding matters was the lack of information or an explanation to substantiate PCD dispositions of the concerns identified by Hatfield. The following actions have been taken to avoid recurrence of the situation described above:
1.
Hatfield Engineering personnel received documented training on the use of j
accept as-is dispositions for deficiencies reported by Hatfield QC.
This j
action was implemented on July 24, 1986. This training emphasized the requirements for thoroughly documenting why an inspection item has been incorrectly identified as a rejectable condition. The requirement for A/E review and approval of conditions which vary from the specified design was also emphasized.
2.
Commonwealth Edison Company PCD electrical group personnel were trained on the same criteria described in item 1 above by issuance of a July 21, 1986 letter. These personnel were also notified that PCD dispositions were only to be epplied to NCR's and DR's (not OIR's).
3.
With respect to the Hatfield QA overinspection of vendor installed components on electrical equipment, PCD provided a clarification of the intended inspection scope to Hatfield. This was proceduralized by a revision to Hatfield Procedure 12A on September 5, 1986.
Training on the new criteria was completed on September 12, 1986 and the revision was implemented on September 17, 1986. Additionally, Hatfield Procedure 6 was modified to incorporate specific provisions for processing OIR's.
This procedure change includes a formal review by Hatfield engineering prior to production issuance and permanent retention of an "OIR coversheet" which provides a means for documenting the Hatfield engineering response to the rejected condition. Frovisions were also incorporated for reporting potentially unacceptable items or conditions affecting equipment which is beyond the scope of Hatfield contract specification F2790. This change to procedure 6 was issued August 15, 1986.
Date When Full Compliance Will be Achieved Refer to the information provided above. These actions have been fully implemented as of the dates noted.
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i Braidwood Response The L.K. Comstock QA/QC Program does not utilize an "Open Inspection Report" System. The L.K. Comstock Inspection Correction Report (ICR) would be utilized to document similar types of conditions.
L.K. Comstock procedure 1
4.11.2 " Inspection Correction Report" controls the issuance, review and final l
disposition of ICRs.
Procedure 4.11.2 does not allow " accept-as-is" dispositions. Any item for which an " accept-as-is" is requested must be processed on an L.K.
Comstock NCR.
Contractor NCRs are processed by the Project Construction Department in accordance with procedure PCD-23 " Site Contractor Nonconformance j
Reports / Procedure Processing".
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>E c violatiq,_6 10 CFR 50, Appendix B, criterion XVII, as implemented by Commonwealth I
Edison Company Topical Report (CE l-A), Section 17, requires sufficient records be maintained to furnish evidence of qualifications of personnel.
Contrary to the above, the Quality Assurance Supervisor for Hatfield Electric Company directed the destruction of termination inspection reports 15270 through 15275 and 15277 through 15285 which were the qualification test reports for certain cable terminations.
Corrective Action Taken and Results Achieved This violation concerns the retention of cable termination reports (HP-118) which documented the continued proficiency of cable terminators. The cable termination reports cited in the violation documented mock terminations made solely to maintain qualification of cable termination personnel, not actual cable terminations in the plant. The discarded reports were retrieved, reviewed and approved by Hatfield QA personnel and filed in their QA records vault. The reports were subsequently transferred to Commonwealth Edison as part of the construction records turnover process.
Corrective Action to Avoid Further Violation The reports were transferred to Commonwealth Edison as part of the construction records turnover process. Additionally, the Hatfield QA supervisor who discarded the reports is no longer employed by Hatfield.
Date When Full Compliance Was Achieved The cable termination inspection reports were reviewed and properly filed July 22, 1986.
Braidwood Response This item is unique to Byron. The system of installer qualification is not utilized at Braidwood, e
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