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Answer to Intervenor 850307 Motion for Leave to File Addl Contention.Intervenors Contention Not Limited to Challenge of Recent Events & Consequently Not Based on New Info. Motion Should Be Denied.Certificate of Svc Encl
	ML20100B605
Person / Time
Site:	Braidwood
Issue date:	03/25/1985
From:	Gallo J, Lauer J, Lauer R; COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE
To:	; Atomic Safety and Licensing Board Panel
References
	CON-#185-258 OL, NUDOCS 8503280470
	Download: ML20100B605 (32)
	v • d • e

{{#Wiki_filter:..... m. O March 25, 1985

                                                   .         Ost r,E TED        .

USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISS N r# 27 P3:07 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD GFFIC 0F SECRETARY

                                                       ~00CK ING & SERVICE In the Matter Of:                )                 BRANCH
                                             )

COMMONWEALTH EDISON COMPANY ) .

                                             )    Docket.Nos. 50-456-         -

(Braidwood Nuclear Power ) ,,QO - ,457 [ Station, Units 1 and 2) ) COMMONWEALTH EDISON COMPANY's ANSWER TO INTERVENORS' MOTION FOR LEAVE TO FILE ADDITIONAL CONTENTION On March 7, 1985, Intervenors Bridget Little Rorem, et al. filed a motien in this proceeding styled as a

            " Motion For Leave To File Additional Contention" (" Motion").

Intervenors seek the admission of a new contention that challenges the adequacy of the quality assurance and quality control ("QA/QC") programs at the Braidwood Nuclear Station. Commonwealth Edison Company (" Applicant") submits this Answer in opposition to the Motion. Contentions filed in NRC licensing proceedings must satisfy the test imposed by the Commission's regu-lations for admissibility. General allegations are insuf-ficient. Contentions must be articulated with specificity and supported with adequate bases so that the true nature of the complaint can be litigated effectively as an issue in controversy. Contentions must also be filed on a timely _se <25t

basis. Late-filed contentions, as Intervenors concede is the case with respect to their new contention, not only must satisfy the requirements for specificity and basis, but they must also meet the rigorous test imposed by the Commission's regulations for the tardy submission of contentions. ' Applicant has analyzed Intervenors' new contention and.the supporting arguments set forth in the Motion against the foregoing regulatory requirements. As explained below, the newly proferred contention fails to satisfy the speci-ficity and basis requirements, at.d moreover, Intervenors' tardiness is not excused. The Motion should be denied. I. Bases For.Intervenors' Proposed Quality Assurance Contention Specificity. Have Not Been Set Forth With Reasonable A. Applicable Law. The Commission's regulation, 10 C.F.R. S 2. 714 (b) , requires that bases for proposed contentions must be " set forth with reasonable specificity." This requirement does not mean that an intervenor must plead evidence as a basis for a contention; and licensing boards will not evaluate the merits of contentions when ruling on their admissibility. Mississippi Power & Light Company (Grand Gulf Nuclear Sta-tions, Units 1 and 2), ALAB-130, 6 AEC 423 (1973); Common-wealth Edison Company (Byron Nuclear Power Station, Units 1 and 2), LBP-80-30, 12 NRC 683, 688 (1980). Nevertheless, an intervenor must provide bases for their contentions which are reasonably specific in order that concrete issues for adjudication can be defined. See Gulf States Utilities

             -Company (River Bend Station, Units 1 and 2), ALAB-444, 6 NRC 760, 769 '(1977). Therefore, the bases need to be stated with sufficient specificity to put the Applicant and the
             ' Staff on notice as to what evidentiary presentations are needed in order,to respond to the contention.             Philadelphia Electric Company (Peach Bottom Atomic Power Station, Units 1 and 2), ALAB-216 8 AEC 13, 20 (1974); Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2), LBP-82-43A, 15 NRC 1423, 1481 (1982); Illinois Power Ccmpany (Clinton Power Station, Unit 1), LBP-81-61, 14 NRC 1735,
                            +                                                          -

1737.(1981). Where a proposed contention is prepared by an attorney experienced in practice before the Nuclear Regu-latory Commission, the Commission's adjudicatory boards have required that the basis and specificity requirements de-manded by the regulations be fully met before a contention is deemed admissible. Kansas Gas & Electric Company (Wolf Creek Generating Station, Unit No. 1), ALAB-279, 1 NRC 559, 576-77 (1975); Tennessee Valley Authority (Browns Ferry Nuclear Plant, Units 1 and 2), LBP-76-10, 3 NRC 209, 217-18 (1976); see also Houston Lighting & Power Company (Allens m ._ _ - _. _. . -- ._._ __., _ __

Creek Nuclear Generating Station, Unit 1), ALAB-590, 11 NRC 542, 546 (1980). This. strict standard is applicable in this instance since the proposed quality assurance contention was prepared and filed by Mr. Cassel, an attorney experienced in quality assurance and quality control issues before the Commission. Mr. Cassel and his organization, Business and Professional People for the Public Interest ("BPI"), repre-sented intervenors in the recently concluded Byron licensing proceeding with respect to extensive litigation of QA/QC issues. Accordingly, this Board should examine the clarity and precision of the proposed contention and evaluate its adequacy against the regulatory standard with full awareness that Intervenors' proposed contention is the product of counsel who is skilled and experienced in NRC practice. B. Analysis Of Intervenors' Contention.

1. The Contention Generally Intervenors have stated their proposed contention as follows:

Quality Assurance Commonwealth Edison has not implemented, maintained and overseen an adequate quality assurance program for the construction of Braidwood. Edison has not and does not adequately supervise the quality assurance programs of its construction contractors. This is illustrated by, e.g.: I l

                                                                                                                                                     - _ - _ -   ------_------a

the $100,000 fine imposed against Edison for the faulty QA program of the Philips-Getschow Corporation; the non-compliance history of Edison and its contractors at Braidwood; the NRC Regional Administrator's testimony in August, 1984, that there are ' serious quality assurance questions at Braidwood'; the February, 1985 NRC CAT inspec-tion report, which documented con-tinuing quality assurance defi-ciencies, as well as inadequacies in the Braidwood Construction As-sessment Program ('BCAP'). Because without an adequate QA program, Edison cannot show reasonable assurance that Braidwood will safely operate, no operating license may issue. Intervenors' proposed contention is a broad and general attack upon Applicant's construction QA program at Braidwood and upon Applicant's supervision of the QA pro-grams of its construction contractors. By citing only exar.ples in support of a broad QA contention, Intervenors have failed to define the parameters of the contention and thereby have failed to identify completely what issues they would seek to litigate. The licensing board in Washington Public Power Supply System (WPPSS Nuclear Project No. 1), LBP-83-66, 18 NRC 780 (1983) considered a similar situation where a peti-tioner proposed a broad construction QA contention and offered specific items only as examples of defects in sup-s s port of the contention. The WPPSS board declined to admit

            ' the breidly-worded' contention, because- admission of the contension with.the specifics serving only as. illustrations or examples would have left'the contention vague and overly broad so as to, permit the peEitioner to later " expand its
              ' shopping list' of construction defects."     Id. at 79s.' For this same reason the contention proposed"by Intervenors shoulq be rejected for lack of basis and specificity and t
                              ~

Intervenors' Motion should be denied.

                                .      .i-

2. The Four Examples Af ter determining that the broadly-worded QA contention could not be adpitted if the specific items were -

construed to be only examples, the WPPSS board # undertook to modify the. proposed contention by limiting it in scope to the specific examples enumerated therein. Id. However,

           'such an approach should not be adopted in this instance.         In
                                                                            ~.

light of the experience of Mr. Cassel in litigating QA/QC matters before the NRC, strict application of the basis ahd specificity requirements of Section 2. 714 (b) should be im-posed. As explained above, review of Intervenors' con- , t tention against this standard reveals that the entire con-tention is inadmissible due to its overbroad and open-ended s reach. Nevertheless, assuming arguendo that the Board might be inclined to rewrite the contention for Intervenors' I

l counsel to so limit the contention, Applicant undertakes to l examine each of the four examples to determine if, considered alone, each provides adequate basis and specificity for a contention.

a. The $100,000 Fine The first example listed in the contention is "the

              $100,000 fine imposed against Edison for the faulty QA program of the Phillips-Getschow Corporation."      The fine referenced in this example arose in the context of a Notice of Violation and Proposed Imposition of Civil Penalty asso-ciated with NRC Braidwood Inspection Report 82-05.       In that Notice of Violation, the NRC Staff cited Applicant for de-ficiencies in the controls and documentation associated with the installation and inspection of mechanical equipment.

While Inspection Report 82-05 contains' adequate basis and specificity to support a contention limited to the findings underlying the fine, they lack sufficient basis and specificity to support the Intervenors' far-reaching chal-lenge to the entire Braidwood QA/QC program. Intervenors fail to allege any link between this isolated enforcement action and their general attack on the adequacy of the Braidwood QA/QC program. This missing nexus is the neces-sury basis required by the Commission's regulations that J would establish a reasonably well-defined and concrete issue

for adjudication. See Gulf States Utilities Company (River Bend Station, Units 1 and- 2), ALAB-444, 6 NRC 760, 769 (1977). Thus, the Phillips-Getschow incident does not pro-vide basis and specificity for Intervenors' contention.

b. The Non-Compliance History Intervenors' second example is listed as "the non-compliance history of Edison and its contractors at Braid-wood." Intervenors totally fail to identify the events which they seek to put in issue, and there is no showing of what, if any, aspects of the non-compliance history In-

, tervenors contend demonstrate deficiencies indicative of an inadequate construction QA program. This item is so vague and overbroad that it provides no indication as to what Applicant might be required to marshall as evidence to meet its burden of proof. Consequently, application o'f-the well-established specificity ~ standard as defined by the Appeal Board, requires that this example be rejected as a basis for Intervenors' contention. See Gulf State Utilities Company (River Bend Station, Units 1 and 2), ALAB-444, 6 NRC 760, 769 (1977); Philadelphia Electric Company (Peach Bottom Atomic Power Station, Units 1 and 2), ALAB-216, 8 AEC 13, 20 (1974).

c.- The Regional Administrator's State-ment The third suggested example for Intervenors' con-tention is the statement of the Regional Administrator that there are " serious quality assurance questions at Braid-wood." . (See Transcript of Byron proceeding at p. 10,143, included in Attachment A hereto). A statement of opinion as

     , vague and broad as the one presented here cannot serve to inform the parties of the issues to be litigated.      While the Regional Administrator was under no obligation at the' time he made this statement to provide the basis and specifics underlying his opinion, that fact does not relieve Inter-venors of their responsibility to provide reasonably spe-cific bases for their contentions. Thus, the statement does not provide a sufficient basis for Intervenors' contention.

The experience of Ms.-Whicher and later'Mr. Cassel and Mr. Wright in litigating QA/QC issues at Byron was

                                  */
     -available to Intervenors.   -

Also, information from the Local Public Document Room and through direct distribution to counsel, was available on the Braidwood plant speci-

     -fically, including its enforcement history.      Rather.than.
           . */   Ms. Whicher, formerly of BPI, filed an appearance on-beEalf of Intervenors Bridget Rorem, et al. with respect to QA issues in the Braidwood proceeding on May 9, 1984.

Mr. Cassel and Mr. Wright filed similar appearances on October 17, 1984 and October 19, 1984, respectively. All three attorneys participated in the Byron proceedings while employed by BPI. b

       . fulfilling their obligation to use this experience and the publicly available information to formulate a contention. with reasonably specific bases, Intervenors are attempting here to rely on the Regional Administrator's general statement to create a presumption that the Braidwood QA program is inade-quate.       However, Intervenors ' failure to satisfy the plead-ing . requirements of Section 2.714 (b) is not cured by the fact that the statement in question was made by an important NRC official,

d. The CAT Inspection Report The final example cited in Intervenors' contention is the NRC CAT inspection report for Braidwood. (Attachment B hereto). Intervenors assert that the report " documented continuing quality assurance deficiencies, as well as inade-quacies in the Braidwood Construction Assessment Program

( ' BCAP ' ) . " This assertion alone is insufficient to satisfy the requirements of basis and specificity.-*/ However,

               */        The Braidwood Construction Assessment Program

("BCAP") referred to in the contention is an ongoing acti-vity initiated by the Applicant; however, it is not intended to serve as a substitute for the QA/QC programs already in place to assure quality construction at Braidwood. Inter-venors indicate at page 5 of their Motion that they expect Applicant in this Answer to oppose their challenge to the Braidwood QA/QC programs on the basis that "the continuing problems identified by the CAT report will be cured" by BCAP. Therefore, the alleged BCAP deficiencies referred to are made in anticipation of and in order to defeat any such affirmative defense that might be offered by Applicant. (continued on p. 11) L

1 l Applicant acknowledges that, on page four of their Motion, Intervenors enumerate seven concerns which they have dis-tilled from the report and which the Board ~should consider as additional information offered in support of their con-tention. Hence, Applicant provides herein an analysis of this information, treating it as though it is part of the contention. The body of the CAT report identifies the specific findings underlying each of the seven criticisms contained in Intervenors' Motion. Therefore, if Intervenors' purpose had been to place each of these seven criticisms into issue as a separate contention, then an adequate basis for each might be found by referring to the more detailed findings in the CAT report. However, this was not the approach or the purpose of Intervenors' proposed contention. Intervenors' contention attacks the overall adequacy of the Braidwood QA/QC program. The CAT report, with its listing of indi-vidual,. unrelated findings, cannot serve as an adequate basis for this generalized attack. The question of the admissibility of such a ge-

   .neral QA contention on the basis of examples from the CAT (continued from p. 10)

Accordingly, Applicant does_not construe the Motion as attempting to place BCAP in issue affirmatively, despite its

   . reference in the proposed contention; and BCAP is not con-sidered further in this Answer.

h . i i-t 1 L reportJshould be examined with an awareness of the realities I of the regulatory process and the legal-- iteria for the litigation of,OA issues. The fact that QA deficiencies are identified'during construction does not mean that there is not' an adequate QA program. As the Appeal Board has ob-served, "[i]n any project even remotely approaching in magnitude and complexity the erection of a nuclear power plant, there inevitably will~be some construction defects

tied to quality assurance lapses." Union Electric Company l- (Callaway Plant,. Unit 1) , ALAB-740, 18 NRC 343, 346 (1983).

However, a simple recitation of particular QA deficiencies

                 .does not demonstrate-a failure in the overall QA program, with.its many elements and layers of review.                              Some further basis is needed for the-judgment that the individual defi-ciencies are indicative of a QA " breakdown" or of a "per-vasive failure" to carry-out the QA program. Id.

Intervenors have not alleged a basis for their judgment that the seven CAT items cited in their contention are indicative of such a breakdown or pervasive failure.

                'Indeed,'the NRC Office of Inspection and Enforcement re-ported that "[t]he NRC CAT noted no pervasive breakdown in meeting construction requirements in the samples of in-i

stalled hardware inspected by. the team or in the applicant's project construction. controls for managing the Braidwood project." Attachment B at p. 1. Intervenors' approach of

 &,   . - . . ,       ---,..e... .~ .

~ attempting merely to rely on the fact there were deficiencies identified by the CAT to somehow show a failure to carry out an adequate QA program generally is at odds with the reason-ing of the Appeal Board in the Callaway decision. The licensing board in the Limerick proceeding considered a contention that was based on a number of ad-verse findings in NRC inspection reports not unlike those

*/

identified in the CAT report. In that case, the licensing board rejected the general QA/QC contention based upon the reasoning that: the mere recitation of unrelated adverse

                   .                         findings in reports of inspections _and audits performed by the Staff and Appli-cant does not supply information on what specifically would be litigated. It sug-gests a broad, unfocused, item by item cross-examination of the very Staff and 2

Applicant inspectors who reported the prob-lems and approved their resolution. This is to be contrasted with proceedings where particular allegations of specific patterns of QA/QC problems, often based on inspec-tion' reports, have been litigated. It is also'in sharp contrast with supported alle-gations of particular existing construction de fec ts .- Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2), LBP-83-39, 18 NRC 67, 89 (1983). As the Limerick decision suggests, Intervenors' approach of sum-marizing and reciting unrelated adverse findings from the f

                          ~*/               Attachment C hereto sets forth the language of the QA/QC contention submitted in Limerick.

CAT report without articulating any pattern of QA/QC prob-lems ~ or other nexus supporting their challenge to Appli-cant's QA/QC program fails to meet the, basis and specificity requirements of S 2. 714 (b) .

3. Conclusion As To Basis And Specificity The QA contention, as drafted and proposed by In-tervenors' counsel, is inadmissible on the grounds that the basis for-the contention'has not been-set forth with suf-ficient specificity to inform the parties of the matters Intervenors propose to litigate. Moreover, if this Board were to decline to hold Intervenors' counsel to the strict standard appropriate for counsel experienced in.NRC pro-ceedings and if the Board'therefore undertook to modify the

           - proposed contention to limit-it in scope to the four il-I           'lustrative examples, the modified contention would still
                                                       ~

prove inadmissible under-S 2.714(b) for the reasons stated above. II. Intervenors' Proposed Quality Assurance Contention-Does Not Meet The Standard For Admissibility Of Late-Filed Contentions. A. Applicable Law. As conceded by Intervenors, the proposed con-tention must meet the standard for admissibility of late-

?.

L

filed contentions set forth in 10 C.F.R. S 2. 714 (a) . All five factors set forth in the regulation must be applied to determine if Intervenors' late-filed QA contention is ad-missible. See Duke Power Company (Catawba Nuclear Station, Units 1 and 2), CLI-83-19, 17 NRC 1041 (1983). The relevant factors are as follows: (i) Good cause, if any, for failure to file on time. (ii) The availability of other means where-by the petitioner's interests will be p rotected. (iii) The extent to which the petitioner's participation may reasonably be ex-pected to assist in developing a sound record. (iv) The extent to which the petitioner's interest will be represented by exist-ing parties. (v) The extent to which the petitioner's participation will broaden the issues or delay the proceedings. 10 C.F.R. S 2. 714 (a) (1) . With regard to the first of these five factors, there is a well-developed body of NRC case law which holds that a determination as to whether there is good cause for late filing should focus upon whether the issue presented could have been raised earlier because of the availability of the information underlying the contention. Long Island Lighting Company (Shoreham Nuclear Power Station, Unit 1), ALAB-743, 18 NRC 387 (1983); Detroit Edison C mpany (Enrico

y y--

          . Fermi Atomic Power. Plant, Unit 2), ALAB-707, 16 NRC 1760 (1982); Cincinnati Gas & Electric Company (William H. Zimmer Nuclear Power Station, Unit'l), LBP-83-58, 18 NRC 640 (1983).

Intervenors have a duty tx) diligently search out publicly

available information -and to formulate their contentions in-a timely fashion. Duke Power Company (Catawba Nuclear Station, Units 1 and 2), CLI-83-19, 17 NRC 1041, 1048 (1983); Kansas Gas & Electric Company (Wolf Creek Generating Station, Unit No. 1), LBP-84-17, 19 NRC 878 (1984). Where information underlying a contention was publicly available as much as four to six months or more prior to the filing of the contention, good cause for the late filing does not exist.- See Detroit Edison Company (Enrico Fermi Atomic Power Plant, Unit 2), ALAB-707, 16 NRC 1760 (1982); Washington Public Power Supply System (WPPSS Nuclear Project No. 3), ALAB-747, 18 NRC 1167, 1172-73 (1983); Long Island Lighting

         -Company (Shoreham Nuclear Power Station, Unit-1), LBP-84-30, 20 NRC 426, 437-39 (1984).       In addition, failure to show
         - good cause for the late filing of a contention increases the burden on the petitioner with respect to the other four-factors. See Virginia Electric & Power Company (North Anna Station, Units 1 and 2), ALAB-289, 2 NRC 3: 5,     398 (1975);

CincinnatiLGas & Electric Company (William H. Zimmer Nuclear

         -Power' Station, Unit 1), LBP-83-58, 18 NRC 650, 663 (1983).

Factor two (availability of other means to protect petitioner's interest) and factor four (extent to which petitioner's interest will be represented by existing parties) are considered to be of minor importance relative to the other three factors of S 2. 714 (a) . See Long Island Lighting. Company (Shoreham Nuclear Power Station, Unit 1), LBP-84-30, 20 NRC 426, 439-40 (1984); Kansas Gas & Electric Company (Wolf Creek Generating Station, Unit No. 1), LBP 17, 19 NRC 878 (19 84) . A demonstration of special expertise in the sub-

ject of the contention, as well as an identification of particular issues the intervenor plans to address and the witnesses-and evidence likely to be offered by the inter-venor, are means whereby an intervenor can satisfy factor three (the extent to which petitioner's participation may reasonably be expected to assist in developing a sound record). See Mississippi Power & Light Company (Grand Gulf Nuclear ~ Station, Units 1 and 2), ALAB-704, 16 NRC 1725, 1730 (1982); Long Island Lighting Company (Shoreham Nuclear Power Station, Unit 1), ALAB-743, 18 NRC 387, 400-401 (1983); Kansas Gas & Electric Company (Wolf Creek Generating Sta-tion, Unit No. 1), LBP-84-17, 19 NRC 878 (1984). The final factor requires that the Board evaluate the extent to which admission of the contention, by virtue of being late-filed, would broaden the issues or delay the proceedings. See 10 C.F.R. S 2. 714 (a) (1) (v) ; Detroit Edison m

   *1 Company (Enrico Fermi Atomic Power Plant, Unit 2) , ALAB-707,
           ~

16 NRC 1760, 1766 (1982). B. Analysis Of Intervenors' Contention.

1. The Contention Generally Intervenors have-failed to show good cause for the late filing of their contention. As discussed supra, page 5, Intervenors' proposed contention is so overbroad and far reaching that-it challenges the Applicant's QA/QC program from the start of construction.

Lacking limitation to deficiencies of recent vintage, the contention fails to pass the' good cause standard. The licensing board in Clinton faced a similar set of circumstances, and that board held that a proposed contention that is " broad.enough to include

      -every failure of Applicants' QA/QC program from the in-ception of construction" and that "is in no way limited to items of recent date" does not meet the good cause factor.

Illinois Power Company (Clinton Power Station, Unit No. 1), LBP-82-103, 16 NRC 1603, 1615 (1982). The Clinton board's holding is directly applicable to the situation presented by Intervenors' motion. Not only have Intervenors failed to show good cause for-the late filing of their contention, they have also failed to make a compelling showing with respect to the J ~- l

remaining four factors. See Virginia Electric & Power Company (North Anna Station, Units 1 and 2), ALAB-289, 2 NRC 395, 398 (1975); Cincinnati Gas & Electric Company (William H. Zimmer Nuclear Power Station, Unit 1), LBP-83-58, 18 NRC 640, 663 (1983). Applicant concedes that the two factors of relatively minor importance weigh in favor of admission of the contention. See Long Island Lighting Company (Shoreham Nuclear Power Station, Unit 1), LBP-84-30, 20 NRC 426, 439-40 (1984); Kansas Gas & Electric Company (Wolf Creek Ge-nerating Station, Unit No.'l), LBP-84-17, 19 NRC 878 (1984). However, both' factors three and five weigh against admission of the contention. In an effort to show that their participation in sponsoring the proposed GA contention may be expected to assist in developing a sound record (factor three) , In-tervenors refer to the experience of.their counsel in liti-gating similar issues. While the ability to conduct ef-fective cross-examination may, as one licensing board held,

*/

favor admission of a contention, an intervenor's ability to contribute sound evidence, rather than its asserted legal skills and experience, is of more significance under factor three. See Mississippi Power & Light Company (Grand Gulf Nuclear Station, Units 1 and 2), ALAB-704, 16 NRC 1725, 1730

           */   Consumers Power Company: (Midland Plant, Units 1 and 2), LBP-82-63, 16 NRC 571, 587-88 (1982).

(1982); Kansas Gas & Electric Company (Wolf Creek Generating Station, Unit No. 1), LBP-84-17, 19 NRC 878 (1984). In this instance, Intervenors have-failed to show any special ex-pertise~in the area of QA, have failed to state with any particularity the issues they plan to address, and have failed to identify any witnesses or evidence they might present. These failures indicate that Intervenors' parti-

          'cipation in sponsoring-the proposed QA contention would likely not be of assistance in developing a sound eviden-tiary record. See Mississippi Power & Light Company (Grand
          . Gulf Nuclear Station, Units 1 and 2), ALAB-704, 16 NRC-1725, 1730 (1982); Long Island Lighting Company (Shoreham Nuclear Power Station, Unit 1), ALAB-743, 18 NRC 387, 400-401 (1983). -Moreover, Intervenors' tardiness in raising this t        issue further reflects poorly on their inclination to assist in developing a sound record.~*/     See Cincinnati Gas & Elec-tric Company (William H. Zimmer Nuclear Power Station, Unit
                 */    Not only were Intervenors late in filing their contention in relation to the special prehearing conference held on August 23, 1979, but they also failed to file in accordance with their representations to the Board. Three months after filing her appearance limited to QA issues, Ms.

Whicher indicated in an August 6, 1984 letter to the Board that Intervenors planned to submit new contentions and that they believed this could be accomplished within ninety days. In an October 17, ~1984 letter to the Board, Mr. Cassel again

         ~ indicated'that Intervenors would be preparing a construction

.. quality assurance contention within a reasonable period of !- ' time. Intervenors' proposed quality assurance contention was not filed until five months later. f: l i 1),'LBP-83-58, 18 NRC 6.40, 661 (1983). For all these reasons, factor three should be taken as weighing against admission s offthe_ contention. In an attempt to address . the final factor, In-tervenors argue that admission of their proposed contention will not delay the fuel load date for Braidwood. However,

      - as both the language of the regulation itself ~ and the Appeal
      ' Board's decision in ALAB-707 indicate, the pertinent inquiry under.. factor five is delay of the proceeding, not delay in
      . operation of the_ facility.              See Detroit Edison Company (Enrico Fermi Atomic-Power Plant, Unit 2), ALAB-707, 16 NRC 1760,_1766 (1982); Long Island Lighting Company (Shoreham PowerLStation, Unit 1),.LBP-83-30, 17 NRC 1132, 1146-(1983).

Clearly, admission of_the proposed contention would broaden the; issues in this proceeding considerably and likely would require additional. time for adjudication. Hence, the po-tential- for delay of the proceeding tilts this . factor against Intervenors' position. Balancing the five factors for determining the admissibility of late-filed contentions, the conclusion to be reached is that Intervenors contention should be re-jected. Their inexcusable delay in filing this broad con-tention coupled with their failure - to demonstrate that their participation might be expected to assist in developing a sound record and the-fact that this broadly-worded conten-

                                                                               -. - . , . . - . . ~    _.2._,-,-____u-_..-...._-_._._,            .

tion.would both broaden the issues and expand the scope of

      ~ the proceedings is more than adequate to conclude that this contention should be-denied. In ALAB-642, the Appeal Board reversed a licensing board's grant of an untimely inter-vention petition on the grounds that there would otherwise be an expansion of the scope of the proceeding and that there was inexcusable lateness in filing with only a mar-ginal showing of ability to contribute to the - record. South Carolina Electric & Gas Company (Virgil C. Summer Nuclear     !

Station, Unit 1), ALAB-642, 13 NRC 8 81. (19 81) . This reason-ing, as well as the body of applicable case law, mandates that the proper disposition in this instance should be a denial of Intervenors' motion under S 2. 714 (a)-.

2. The Four Examples Again, for purposes of complete discussion, Ap-plicant provides the following analysis of each of the four examples found in Intervenors' contention. This inquiry is necessary only if the Board does not choose to impose the strict standard of basis and specificity to which Inter-venors and their counsel should be held (see supra, pages 3-

4) and if the Board then chooses to rewrite Intervenors' contention so as to limit it in scope to the four examples.

For each of the examples, an analysis of factors two through five will yield the same results as the analysis of these

*/

factors for the contention as a whole.- With regard to the first factor, Applicant provides an analysis for each of the examples.

a. The $100,000 Fine The first example listed in the proposed con-l tention is an issue which was raised in documents which have

**/

been publicly available for quite some time.~~ The $100,000 fine was proposed in a Notice of Violation issued on February 2,

                                                                  ***/

1983 that accompanied Braidwood Inspection Report 82-05. (See Attachment D hereto). Moreover, a Commonwealth Edison employee testified concerning this fine in the Byron pro-coeding and was cross-examined about the natter by Ms.

   .Whicher. See Transcripts of Byron proceeding for March 28-29, 1983 at pages 2353-55,.2454-85.       Intervenors offer no justification for delaying two years before raising this           <

issue with the Braidwood Board for the purpose of attacking Applicant's QA program. Hence, they have failed to show

           */   Applicant acknowledges that the broadening of the issues and the likely delay in the proceeding would not be as great if the scope of the contention were more limited.          l
           **/  NRC Inspection Reports and Notices of Violation for Braidwood are made available in the Local Public Docu-ment Room in Wilmington,-Illinois. -In addition, copies of at least some of these reports have been sent directly to Intervenors' counsel by the NRC.
         ***/   The Office of Inspection and Enforcement issued the-Order Imposing Civil Monetary Penalties on June 27, 1983.

good cause for their late filing. This fact, coupled with t an analysis of the other four factors, indicates that a con-tention based upon the $100,000 is inadmissible under S 2.714(a).

b. The Non-compliance History Likewise, there can be no showing of good cause for the late filing of the second example of the contention.

As the Clinton decision cited above indicates, an allegation questioning generally the non-compliance history at Braid-wood runs afoul of the good cause standard because it is broad enough to include every item of non-compliance from-the-inception of construction ~and thus "is in no way limited to-items of recent date." See Illinois Power Company (Clinton Power. Station, Unit No. 1), LBP-82-103, 16 NRC 1603, 1615 (1982). This example cannot provide good cause for a late-filed contention. .Thus, when all five factors ar'e considered, 5 a contention based on the non-compliance history of Braidwood is inadmissible,

c. The Regional Administrator's State-ment The third example listed in the contention is a statement that was made by the Regional Administrator over

         'seven months ago at the Byron hearings while Mr. Cassel was present. Intervenors offer no justification for having 4

delayed raising this issue for seven months, nor is there

any indication in their pleading that the time was used. to develop the issue with greater specificity. Hence, no good cause has been shown for this delay. See Washington Public Power Supply System (WPPSS Nuclear Project No. 3), ALAB-747, 18 NRC 1167, 1171-73 (1983) (four-month delay found to be inexcusable); Detroit Edison Company (Enrico Fermi Atomic Power Plant, Unit _2),-ALAB-707, 16 NRC 1760, 1763-65 (1982) (six or seven-month delay found to be inexcusable) . This lack of good cause, together with the analysis of the other four factors of S 2.714 (a) , indicates that the contention insofar as it relies on this statement is inadmissible.

d. The CAT Inspection Report The fourth item focuses upon the NRC CAT inspec-tion report which was issued in February 1985. Because this report only recently became available, good cause'for the late filing of a contention based upon it exists if the information crucial to the contention was not publicly available earlier. However, if the information essential to the contention was publicly available earlier, then the recent issuance of this report does not. establish good cause for filing the contention late. Duke Power Company (Catawba Nuclear Station, Units 1 and 2), CL1-83-19, 17 NRC 1041, 1048 (1983); Kansas' Gas & Electric Company (Wolf Creek Generating Station, Unit No. 1), LBP-84-17, 19 NRC 878 (1984); Long Island Lighting Company (Shoreham Nuclear Power Station,, Unit 1) , LBP-84-30, 20 NRC 426, 436 (1984). A review of publicly available documents indicates that items one,'four and part of seven as set forth in the Motion have been addressed in earlier Staff in3pections such that these

*/

issues could have been raised earlier.- The first issr.e drawn from the CAT report concerns

      ' deficiencies in the area of electrical separation.        The CAT expressed concerns about the implementation of electrical separation criteria consistent with the standard of IEEE 384-1974. See Attachment B at II-9 -- II-10. As early as December 10, 1982, the Staff issued a notice of violation to Applicant for alleged non-compliance with this standard.

See Braidwood Inspection Report 82-06 (Attachment E hereto) , items 82-06-02A and 82-06-02B. The issue was ref, erred to again by Region III in a May 23, 1983 letter. (Attachment F hereto). --**/ The CAT itself confirms the existence of prior information when it states in the body of its report that

             */    The third item cited by Intervenors was the state-ment that "[n]umerous examples of generally poor [ mechanical]

construction practices were observed." A careful reading of the report reveals that this item was related to mechanical equipment maintenance and protection for installed and accepted hardware and that the item did not relate to any specific QA deficiency. Therefore, this item does not pro-vide a basis for a QA contention.

            -**/ Attachment F was available to Intervenors in the Local Public Document Room.
         "with regard to electrical separation many of the types of deficiencies noted in both cable and raceway installations have previously been identified by Region III inspectors."

See Attachment B at II-4. As shown, previously available information indicated a concern in the area of electrical separation such that Intervenors could have raised this issue earlier. They have failed to demonstrate that the CAT finding in this regard is new information so as to show good cause. As noted in the body of the CAT report, concerns about possible piping clearance violations (item 4) were identified by the NRC in 1983. Attachment B at III-2. The CAT finding in this regard concerned the inclusion of pro-visions in QC and engineering procedures for maintenance and verification of clearances for piping. The CAT report also noted that clearance violations were observed in the plant. Id. In Inspection Report 83-09 issued on May 7, 1984, the NRC noted a finding that QC procedures and construction procedures lacked specific quantitative acceptance criteria for clearances. See Attachment G, item 83-09-09 (B) . Additional findings in this area are documented in the July 2, 1984 Inspection Report 84-09 wherein the NRC ad-dressed examples of clearance violations and the failure to prescribe physical clearance criteria prior to installation. See Attachment H, item 84-09-01. As shown by these reports, n_ the~ fact that there is an NRC concern about piping clear-ances and the criteria for clearances is not new infor-mation. Since this information was publicly available as much as ten months ago, Intervenors lack good cause for raising this issue now. The seventh CAT item specifically referenced by Interver s alleges the need for better QC inspector train-

    .ing and points to pipe support deficiencies, as well as deficient welds in the electrical, instrumentation and structural areas. See Attachment B at IX-9, IX-ll. In-spection Report 84-07 issued on July 20, 1984 documented findings related to the qualifications of weld inspectors employed by the electrical contractor L. K. Comstock.       In addition, the report also documented findings related to the
    . indoctrination and training program for Comstock's QC in-spectors.      See Attachment I hereto, items 84-07-02, 84       04,-84-07-05. This same Inspection Report included an item of noncompliance citing past problems with the qualification and certification-procedures for the QC inspectors employed by Napoleon Steel.      The inspectors affected by this-finding performed inspection activity in the area of containment structural steel welding.      See Attachment I, item 84-07-06.

Inspection Report 84-08 issued on May 22, 1984 also ad-dressed deficiencies in weld inspection activities by QC

i

*/

personnel in the structural steel area.' See Attachment J, item 84-08-02. As these reports indicate, at least for the areas of electrical end structural welding and associated QC activity and training, the CAT report does not present new information sufficient to establish good cause for the late filing of a contention en these matters. For those portions of the CAT report which do not represent new information, good cause for raising the issues at this time does not exist, and that fact, taken into con-sideration with the other factors of S 2. 714 (a), demon-strates that these issues are inadmissible.

3. Conclusion As To Admissibility Under The Standard For Late-Filed Contentions-Intervenors' contention is not limited to a chal-lenge of recent events and consequently is not based upon new information. Therefore, there does not exist good cause for the failure to make - a timely filing. Moreover, Inter-venors have failed to make a compelling showing with respect ~

to the other four factors, and, therefore, admission of the contention under S 2.714 (a) should be denied. Even if Applicant assumes for the sake of argument

             */   Applicant's review of the Local Public Document Room revealed that Inspection Reports and Notices of Vio-lation are publicly available there.      Inspection Report 84-08 happened to be missing from the Wilmington library, but the cover letter transmitting the report indicates that it was sent directly to Ms. Whicher.

L

that the Board might be willing to rewrite the proposed contention to limit it to the four examples given, Inter-venors have not satisfied the requirements of S 2.714(a) with respect to the $100,000 fine, the non-compliance his-tory of Braidwood, the Regional Administrator's statement, and certain of the CAT findings. Moreover, these examples, as well as the rest of the CAT findings for which good cause may exist, are insufficient for the reasons set forth supra at pages 4-14 to serve as bases for the broad contention proposed by Intervenors. The Motion should be denied. Respectfully submitted, j/ sLL)Lb - Soseph Gallo Y/ll (A , m.w Rebeccard . Lauer Two of the Attorneys For Applicant, COMMONWEALTH EDISON COMPANY Joseph Gallo, Esq. ISHAM, LINCOLN & BEALE 1120 Connecticut Avenue, N.W. Suite 840 Washington, DC 20036 > (202) 833-9730 Rebecca J. Lauer, Esq. ISHAM, LINCOLN & BEALE Three First National Plaza Suite 5200 Chicago, Illinois 60602 (312) 558-7500 DATED: March 25, 1985 E t.

                                                                  00thETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
                                                           '85 MA9 27 P3:07 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD GFFIC 0F SECRETARY WMfTING & SERylCf.       '

In the Matter Of: ) BRANCH

COMMONWEALTH EDISON COMPANY ) _, ,,

                                      )     Docket Nos. 50'-456

(Braidwood Nuclear Power

                                      )              .
                                                             ' 5'0 ~ 4 5 7 '

Station, Units 1 and 2) )

                                                     "- ^ ~ ~""' " "

CERTIFICATE OF SERVICE I, Rebecca J. Lauer, one of the attorneys for Commonwealth Edison Company, certify that copies of the Answer To Intervenors' Motion For Leave To File Additional Contention have been served in the above-captioned matter on those persons listed in the attached Service List by United States mail, postage prepaid, this 25th day of March, 1985. eg- d ocs Rebecca'J. Lauer ISHAM, LINCOLN & BEALE Three First National Plaza Suite 5200 Chicago, Illinois 60602 (312) 558-7500 DATED: March 25, 1985 = . ._

SERVICE LIST Lawrence Brenner, Esq. Mr. William L. Clements Chairman Chief, Docketing and Services Administrative Law Judge United States Nuclear Regulatory Atomic Safety and Licensing Commission Board Office of the Secretary United States Nuclear Regulatory Washington, DC 20555 Commission Washington, DC 20555 C. Allen Bock, Esq. P.O. Box 342 Dr. Richard F. Cole Urbana, IL 61801 Administrative Law Judge Atomic Safety and Licensing Board Thomas J. Gordon, Esq. United States Nuclear Regulatory Waaler, Evans & Gordon Commission 2503 South Neil Washington, DC 20555 Champaign, IL 61820 Dr. A. Dixon Callihan Ms. Bridget Little Rorem Administrative Law Judge 117 North Linden Street Union Carbide Corporation P.O. Box 208 P.O. Box "Y" Essex, IL 60935 Cak Ridge, TN 37830 Douglass W. Cassel, Jr. Myron Karman, Esq. Timothy W. Wright, III Elaine I. Chan, Esq. i BPI Office of the Executive Legal 109 North Dearborn Street Director Suite 1300 United States Nuclear Regulatory Chicago, IL 60602 Commission Washington, DC 20555 Ms. Lorraine Creek Route 1 Atomic Safety and Licensing Box 182 Board Panel Manteno, IL 60950 United States Nuclear Regulatory Commission Washington, DC 20555 Erie Jones, Director Illinois Emergency Services and Disaster Agency Atomic Safety and Licensing 110 East Adams Appeal Board Panel Springfield, IL 62705 United States Nuclear Regulatory Commission Washington, DC 20555

y _. 9916 @ mm1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

     .           4
                      -_______________x 5    In the Matter of:                                                                 :

6 COMMONWEALTH EDISON COMPANY : Docket Nos. 50 ;454 OL 7

50-455 OL (Byron Nuclear Power Station, :

Units 1 and 2) : 8 . ________________x 9 10 Clock Tower Inn 11 7801 East State Street Convention Rooms Y and Z 12 Rockford, Illinois 13 Wednesday, 1 August 1984 14 The hearing in the above-entitled matter was 15 reconvened, pursuant to recess, at 9:10 a.m. i7 BEFORE: 18 IVAN W. SMITH, Chairman Atomic Safety & Licensing Board 19 A. DIXON CALLIHAN, Member 20 Atomic Safety & Licensing Board , 21 RICHARD F. COLE, Memt'r Atomic Safety & Licensing Board 22 23 24 25 s I

                                                                                                                                           ,.I A      -

f._.. --a_, v7vww t < %ff-ATTACHMENT "A"

r 9917 , F 1 mm2 APPEARANCES: 2 On behalf of the Applicant: 3 MICHAEL A. MILLER, ESQ. BRUCE BECKER, ESQ. 4 MICHAEL GOLDFEIN, ESQ. MARK FURSE, ESQ. 5 ALAN BIELAWSKI, ESQ. Isham, Lincoln & Beale 6 Three First National Plaza Chicago, Illinois 60603 and 8 JOSEPH.GALLO, ESQ. 9 Isham, Lincoln & Beale Suite 840 10 1120 Connecticut Avenue, N.W. Washington, D.C. 20036 12 On behalf of the NRC Staff: 13 STEPHEN LEWIS, ESQ. MICHAEL WILCOVE, ESQ. . Id Office of the Executive Legal Director U.S. Nuclear Regulatory Commission 15 Washington, D.C. 20555 a On behdit M V5a w.F Trae venors, DAARE/ SAFE and 17 Rockford League of MOgOu Voters: 18 DOUGLASS CASSEL, JR., ESQ. Business and Professional People for the l' Public Interest 109 N. Dearborn 20 Chicago, Illinois 60602 21 22 23 24 25 C

10,139 8-1 1 JUDGE SMITH: I heard that. i 2 (Laurjnter. ) 3 JUDGE SMITH: -The Board has no questions. d REDIRECT EXAMINATION 3 BY MR. LEWIS: 0

                  ,Q    Mr. Keppler, you sat through some testimony 7

today in which various members of your Staff expressed a their views with regard to the reinspection procram and : discussions on inferences that can be drawn from that , 10 program. i 11 ! Could you please explain to us your view as . 12 to what the. reinspection program results demonstrated 13 to you regarding the question of the quality control Id inspector certification issue at Byron? IS A Yes. But before I do that, I would like to 16 address again the purpose of the reinspection program, 17 because, to me, I've heard a lot of comments made regarding. 18 the importance of this reinspection program, and there are 19 some things that I believe are important to say to the Board, 20 and it's really one of the reasons why I asked to come up 21 here today. 22 Frankly, as Mr. Hayes stated earlier, when the 23 Staff testified before this Board last year, the Staff had 24 confidence in the quality of construction at Byron. 25 Unfortunately, as I look back on the record for l j 1 I J

~

~*

10,140

      -2    1 that, we did not do a very good job of articulating that 2

confidence to the Board. I take the blame for that I

           ~3 personally, because normally in matters of this type, d

I would normally be testifying and representing Region III. 5-At that time, we were caught up in two major 6 cases with Zimmer and Midland, and I was locked up in those [ 7 cases myself. And I really didn't pay a lot of attention 8 to the hearing up here at Byron and to the testimony that

          '9 was being presented. I kept in touch from the standpoint 1 0  of satisfying myself that the Staff felt comfortable with 11 their testimony, but I was not aware, until the Board 12   decision came out, that the Board had serious cuestions         j i

13 regarding'the adequacy of quality in the quality assurance ' id prcgram at Byron. ~ 15 So I apologize to the Board for whatever I 16 contributed to this matter. But you should understand that 17 the Sta.ff had confidence in Byron at the time it testified. 18 The basis for that confidence was not the reinspection 19 program. The basis of that confidence was the routine 20 inspection program that is carried out by the Regional Office 21 and a special type of inspection that I had conducted at 22 a number of plants as a result of the findings of problems 23 at Zimmer. 24 When I testified before Congressman Udall's I 25 committee back in 1981, I was deeply concerned at how I would l l l

^~

10,141 i I 4-3 tell that committe whether or not there were other Zimmers 2 in my Region, how did I satisfy myself that Byron wasn't 3 another Zimmer, how did I satisfy myself that Clinton wasn't another Zimmer, Braidwood and the rest of the plants that 5 I had under my responsibility. 6 As a result of that, I initiated a very comprehen-7 sive team inspection approach, which has been discussed 8 here as the CAT inspections. These inspections were carried out at all of the Region III sites for the purpose of

           'O determining whether or not we had another plant with the potential problems of Zimmer.

That inspection was oriented toward the hardware:

          '3 Was the adequacy of construction okay for its intended
          'd purpose?

15 We concluded from the Byron inspection that the 16 adequacy of construction was sound. We did not identify

          '7 any major hardware deficiencies.       That fact seems to have 18 gotten lost in this discussion.       But we did generate a finding with respect to the fact that we could not verify 20 that the quality control inspectors had been certified in 21 accordance with the applicable standards.

22 As a prudent measure, we felt it was important 23 to follow up on that finding. 24 You've hea::d a lot of discussion here today 25 as to what the intended purpose of that was, but basically

10,142

     ;28-4   1 you should understand that the direction we were coming 2

from'was trying to determine whether there were major 3 construction problems at the site. So it was a hardware d oriented thing, and we really focused -- I'm not sure 5 I can exactly tell you how this evolved, because I wasn't 6 in on the details right from the beginning, but to me, 7 the important measure was trying to determine whether, 8 as a result of questions regarding the qualifications of 9 people, whether that meant poor quality built into the 10 plant. 11 I feel that the reinspection program, and my Staff 12 feels that the reinspection program, gives us a high degree 13 of assurance that that isn't the case. Id Now I think you can go one step beyond that and 15 infer from the fact that throughout the course of our lo inspection program, we found a number of problems at the

17 site in quality assurance which tells us inspectors -- 18 workers were not always doing their jobs right. I' I think the fact that you had a very large amount 20 of work looked at again in the process of this reinspection 21 program by inspectors who were qualified, checking the 22 work of inspectors who were of questionable qualifications, 23 I think all of this gives you an inference, perhaps not 24 quantitatively, but gives you an inference that the inspectors l 25 who did the initial work were capable of doing their job !

10,143 t 8-5 3 properly. 2 So in that sense, I answer the question that 3 way, d Another point, though, I would like to make, if 5 I could, is, I tried to express to this Board the confidence 6

                  'that I have -- more importantly the Board ought to be 7

interested in the confidence my Staff has -- and I say !- 8 1: this because the Staff has had to contend with major : 9 quality problems at Zimmer, at Midland. We've got serious 10 quality assurance questions at Braidwood and at Clinton, 11 and major reinspection efforts are underway to deal with 12 these concerns. 13 I take a great degree of comfort out of hearing id my Staff tell me that they feel pretty comfortable with 15 this plant, because they don't buy in cheap. And I would 16 think the Board would derive some degree of comfort from 17 that. ' 18 Region III has been what I would say is very I' aggressive in its pursuit of construction problems. We have 20 taken some very strong regulatory actions in plants under 21 construction. We are not afraid to deal with concerns i 22 when we have them. The fact that the Staff feels 23 comfortable with Byron gives me a warm feeling. 24 MR. LEWIS: All it took was one question. That's 25 all I have. i

F. 10,144 8-6 i JUDGE SMITH: Anything further for Mr. Keppler? 2 MR. CASSEL: No. 3 MR. MILLER: No. 4 JUDGE SMITH: Mr. Keppler, I want to.thank you 5 for coming. I thought it was apprqariate for you to come, 6 and we appreciate it. 7 THE WITNESS: I appreciate your havina me. 8 Thank you. 9 (Witness excused.) 10 JUDGE SMITH: Do you want to start the next n panel this evening? We have fifteen minutes, or should we 12 wait until tomorrow? 13 MR. MILLER: I think it makes sense to wait, 14 myself. . 15 MR. CASSEL:

        .                                           I would heartily concur in that.

16 JUDGE SMITH: I feel guilty leaving -- 17 MR. MILLER: Maybe we ought to begin. I understand 18 there are some quantity of minor corrections to prepared 19 direct testimony, and perhaps we could get that out of the 20 Way in the fifteen minutes that are left. 21 JUDGE SMITH: We've got thirteen minutes. 22 One of the things we've overlooked this time is 23 that those minor corrections, since they are on -- already 24 on the copy that is in the transcript, do not have to be 25 made on the record. I prefer they not be made, because there'si I l l L

IN g:P %, UNITED STATES

      !"                          NUCLEAR REGULATORY COMMISSION i
 ;   {o           :p                       WASHINGTON, D. C. 20555
                 /-

February 20, 1985 , e ..; Docket Nos. 50-456 50-457 Commonwealth Edison Ccmpany ATTN: Mr. Cordell Reed Vice President P.O. Box 767 Chicago, IL 60690 Gentlemen:

SUBJECT:

CONSTRUCTION APPRAISAL TEAM INSPECTION 50-456/84-44, 50-457/84-40 Enclosed is the report of the Construction Appraisal Tec1 (CAT) inspection conducted by the Office of Inspection and Enforcement (IE) on December 10-20, 1984 and January 7-18, 1985 at the Braidwood site. The Construction Appraisal Team was composed of members of IE, NRC Region III and a number of consultants. The inspection covered construction activities authorized by NPC Construction Permits CPPR-132 and CPPR-133. This inspection is the tenth of a planned series of construction appraisal inspections by the Office Ir spection and Enforcement. The results o# these inspections are being used to evaluate the management control of construction activities and the quality of construction at nuclear plants. The enclosed report identifies the areas examined during the inspection. Within these areas, the effort consisted primarily of detailed inspection of selected hardware subsequent to quality control inspections, a review of selected portions of your Quality Assurance Program, examination of procedures and records, observation of work activities, and an examination of your project management. Appendix A to this letter is an Executive Summary of the results of this inspection and of conclusions reached by this office. The NRC CAT noted no pervasive breakdown in meeting construction requirements in the samples of installed hardware in Dected by the team or in the applicant's project construction controls for managing the Braidwood project. However, deficier.cies noted by the NRC CAT in a number of hard'are installa-tions indicate a need for more management attention. The deficiencies included examples of inadequate hardware inspection and examples of inadequate ! quality assurance and engineering review of deficiencies for general applica-tion. The major areas of concern to the NRC CAT are: (1) the dependence on i final walkdown inspections late in the construction program to identify and resolve problems; and (2) the ability to manage the large number (over 20) of ongoing major corrective action programs and ensure that current work is cor-rectly performed. ATTACHMENT "B"

I February 20, 1985 a tr Commonwealth Edison Company ' The NRC team observed that Ceco was implementing some good construction practices at the Braidwood site. These include active CECO management involvement in the construction of the project, the use of an independent test agency for inspection overview and unit concept review for construction adequacy, and the initiation of a Quality First Program. Appendix B to this letter contains a list of potential enforcement actions based on the NRC CAT inspection observations. These are being reviewed by the Office of Inspection and Enforcement and the NRC Region III Office for appropriate action. In addition, Region III will be following your corrective action for deficiencies identified during this inspection. In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures will be placed in the NRC Public Document Room. No reply to this letter is required at this time. You will be required to respond to these findings after a decision is made regarding appropriate enforcement action. Should you have any questions concerning this inspection, please contact us i or the Region III Office. James M. Taylor, Direc r j Office of Inspection and Enforcement t l

Enclosures:

1. Appendix A - Executive Summary l 2. Appendix B - Potential Enforcement Actions i 3. Inspection Report cc w/ enclosures:

l See next page l

. February 20, 1985 cc w/ enclosures: Mr. Dennis L. Farrar Dr. Bruce von Zellen Director for Nuclear Licensing Department of Biological Sciences Commonwealth Edison Licensing Northern Illinois University P.O. Box 767 DeKalb, IL 61107 Chicago, IL 60690 Mr. William Kortier Mr. Julian Hinds Atomic Power Distribution U.S. Nuclear Regulatory Commission P.O. Box 355 Byron / Resident Inspectors Office Pittsburgh, PA 15230 Byron, IL 61108 Joseph Gallos, Esquire Ms. Diane Chavez Isham, Lincoln & Beale 528 Gregory Street 1120 Connecticut Ave., N.W. Rockford, IL 61108 Suite 840 Washington, DC 20036 C. Allen Bock, Esquire Mrs. Phillip B. Johnson P.O. Box 342 1907 Stratford Lane Urbana, IL 61801 Rockford, IL 61107 Thomas J. Gordan, Esquire Douglass Cassel, Esquire Waaler, Evans & Gordan 109 N. Dearborn Street 2503 S. Neil Suite 1300 Champaign, IL 61820 Chicago, IL 60602 Ms. Bridget Little Rorem Ms. Pat Morrison Appleseed Coordinator 5568 Thunderidge Drive 117 North Linden Street Rockford, IL 61107 Essex, IL 60935 Mr. Edward R. Crass Mr. David C. Thomas, Esquire Nuclear Safeguards and 77 5. Wacker Drive Licensing Division Chicago, IL 63601 Sargent & Lundy Engineers . 55 East Monroe Street Dic=qo, IL 60603 , J.S. Nuclear Regulatary Ms. Rebecca J. Lauer, Esquire i Resident Inspectors 3ffice Isham, Lincoln & Beale i RR#1, Box 79 Three First National Plaza Braceville, IL 60407 Suite 5200 t Chicago, IL 60602 Mr. Erie Jones, Director Ms. Lorraine Creek Illinois Emergency Services Rt. 1, Box 182 and Disaster Agency Manteno, IL 60950 139 East Adams j S, ringfield, IL 62705 : i

b

        ,                                                                                                                                              APPENDIX A EXECUTIVE SuletARY i

An announced NRC Construction Appraisal Team (CAT) inspection was conducted at Commonwealth Edison company's (Ceco) Braidwood Station during the period December 10-20, 1984 and January 7-18, 1985.

Overall Conclusions I Hardware, Project Management and documentation for construction activities were j generally in accordance with requirements and licensee commitments. However, the NRC CAT did identify a number of construction program weaknesses that require increased management attention. These are:

1. The effectiveness of first level quality control (QC) inspection activi-i ties needs to be improved, particularly in the pipe support / restraint and

, welding areas. j 2. A large number of final inspection activities are being included in a final walkdown, when greater difficulty will be encountered in identifying deficiencies because of interferences, accessibility and the pressure of schedule.

                                                        .3.                 The identification and resolution of cable tray and conduit electri-cal separation deficiencies is inadequate.

4.

An excessive number of incidents of damage to installed equipment has been caused by current construction activities.

The foregoing identified weaknesses require additional management attention to assure that completed installations meet design requirements.

'                                                        An effort was made by the NRC CAT to evaluate the ongoing Braidwood Construc-tion Assessment Program (BCAP). The schedule for the BCAP inspection program was such that only limited hardware samples were available for NRC CAT over-inspection. It was possible to overinspect a very small sample of hardware in the areas of supports / restraints, piping runs, HVAC supports and ducts for welding, HVAC ducts for configuration and conduit runs. In four of the six areas that were overinspected, there was general agresment between BCAP and NRC CAT findings; in two areas, supports / restraints and piping runs, deficien-i                                                        cies were identified by the NRC CAT that were not identified by the BCAP inspectors. On the basis of the limited sample overinspected, it appears that BCAP inspection effort needs to be improved in the areas of supports /rert.raints and piping runs.

AREAS INSPECTED AND RESULTS Electrical and Instrumentation Construction i The electrical and instrumentation samples inspected generally met the applicable design and construction requirements. However, construction and i inspection deficiencies were identified in several areas including several i items which will require additional NRC review and analysis, A-1 i

   .m__     ._.._ ,_._,, _ . .._ _ . _ _ . _ .. _ . _ . _ _ _ _ , , . . . _ . _ . _ . , . _ _ _ _ , _ _ . _ , _ , , . - _ _ _ _ _ _ . . . _ _ _ _

Site implementation of electrical separation criteria is not consistent with the FSAR commitment which, with several exceptions, endorses IEEE Standard 384-1974. will require additional NRR review.Several items regarding the interpretation o The electrical contractor's quality control program was found deficient in that the inspection criteria was not sufficient to ioentify separation deficiencies. As a result, a number of installations of non-Class 1E to Class 1E raceway and cable were found that did not aet the IEEE requirements and the FSAR commitments for minimum separation The majority of bolts used with raceway supports are of indeterminate material as they do not contain the manufacturer's identification required by the ASTM standard. Although the instrumentation sample was not sufficiently large because of an ongoing reinspection program to draw an overall conclusion, a number of instances were identified of items dameged during the erection of scaffolding. Mechanical Construction Contractor QC inspections and site QA programs have not been effective in ! assuring that installed pipe supports /restaints meet design requirements. The inspection and acceptance criteria provided for activities such as QC inspec-tion and document review and control need to be strengthened and clarified. Numerous examples of generally poor construction practices were observed. The need to protect and maintain installed and accepted hardware needs to be reemphasized. Piping, HVAC, concrete expansion anchors and mechanical equipment were ge found to be installed in accordance with requirements or with deficiencies that had previously been identified. However, because of ongoing re evaluations and reinspections, it was not aossible to establish a complete and conclusive assessment of these areas. The NRC CAT inspectors do not consider that the previously identified NRC concern regarding pipe to pipe and interdisciplinary clearances has been responded to in a timely or effective manner. System and area walkdown inspec-tions performed late in the construction program must be recognized as only an additional level of assurance of proper installation and not a substitute for detailed, item specific first line QC inspections. Welding and Nondestmetive Examination Welding and nondestructive examination activities were generally found to be conducted in accordance with the governing codes and specifications. However, a number of examples were identified where completed structural welds in pipe supports ings. / restraints did not have the weld sizes specified by the design draw-These inspection by QC. undersized welds should have been identified during the weld The licensee has performed an engineering evaluation con-cerning this problem and concluded that most of these welds are adequate for the intended application. In the area of vendor supplied ASME tanks and heat exchangers a number of tanks were found to have undersized weld reinforcement in nozzle to shell and manway to shell welded joints. l A-2 l

The NRC CAT acceptance inspectors criteria. also found radiographs which did not meet the specified The licensee's quality assurance procedures do not 1 require to final that an independent storage in the vault.interpretation of radiographs be performed prior !

  -                                            The NRC CAT believes that this lack of indepen-dont radiographic interpretation may have contributed to the Project's inability to detect deficient radiographs.

Civil and Structural Construction Concrete quality was acceptable. Requirenehos for rebar around three $ four inspected construction openings and cadweld testing frequency were nc' aet. Structural identified. concerns steel member sizes, configurations and connections had no major A few high strength steel bolts were found to be installed at below specified torque values. In the area of masonry wall construction, a concern was identified regarding the need to assure proper rebar anchorage prior to replacement of masonry in the removed sections of masonry walls. Material Traceability and Control The measures presently established for material traceability and control for ongoing work appear to be adequate except for one area. During this inspec-tion, it was determined that 10,500 feet of switchboard wire not qualified to IEEE 383-1974 was installed at Braidwood Station. Corrective Action The requirements. with corrective action programs generally are being implemented in accordance However, based on the results of this inspection, the controls for nonconformance reports issued by site contractors previous to 1983 need additional review. These include: 1. Some nonconformance reports were voided without documented justification. 2. Nonconformances dispositioned "Use-As-Is" or " Repair" were not routinely reviewed by the appropriate engineering personnel. 3. The specified corrective actions did not in some cases adequately resolve the nonconformances. Desian Chance Control Design change control was determined to he generally in conformance with applicable requirements. In the area of the most significant finding was the failure ments. to annotate unincorporated design changes on controlled design docu-The most significant finding in the area of design change control was design change documents written against superseded revisions of the approved dcsign drawings. In at least one instance, this deficiency resulted in a pipe support being installed and inspected to other than the latest approved design. A-3

  .       Project Manacement i

The overall project management effort is evaluated to be satisfactory to

    '     construct the project in conformance with quality standards. Additional                                      j management attention is required to impr ve contractor performance in the areas  of contractor inspector  training. deficiency trending, and craft and quality control 4

l l J 1 .l A-4 _....-,9-, v. , , - - ,_,.w,,,, --,_ ,_ . y -, ym. , , , .-- - . , .,_ m , -- , _

. APPEhSIX 8 POTENTIAL ENFORCEMENT ACTIONS

      #is a result of the NRC CAT inspection of December 10-20, 1984 and January 7-18, 1985 at the Braidwood site, the following items are being referred to Region III as Potential portion             Enforcement of the inspection      Actions (section references are to the detailed report).

1. Contrary to 10 CFR S0, Appendix B, Criterion VII and Ceco Quality Assurance Manual, Quality Requirement No. 7.0, the measures to assure that equipment and services conform to the procurement documents were found to be ineffective in that vendor procured tanks and heat exchangers were accepted and installed with deficient welds. In addition, various vendors have supplied radiographs which did not have the required weld and film quality. (Section IV.B.1, 10) 2.. Contrary to 10 CFR 50, Appendix B, Criterion VIII and Ceco Quality Assurance Manual, Quality Requirement No. 8.0, the licensee failed to implement measures to prevent the following incidents:

a. 10,500 feet of General Electric "VULKENE" switchboard wire was received at Braidwood.

appropriate qualification Some to IEEEof 383-1974. this wire has been installed without (Section VI.B.1)

b. Sargent & Lundy standard EB115.0 required the use of ASTM A307 bolting material for Class IE seismic cable tray hangers. Hangers in the lower cable spreading room did not utilize ASTM 307 fasteners in some cases. 'Also, the generic qualification document for the Class 1E storage batteries specified ASTM A307 bolts for the battery racks.

The battery racks were inspected and found to have bolting material that did not meet the requirements of ASTM A307. (Section VI.B.1) 3. Contrary to 10 CFR 50, Appendix B, Criterion X and Ceco Quality Assurance Manual, Quality Requirements No. 10.0, the licensee's inspection programs have failed to identify areas where seismic category I pipe supports / restaints and other seismic pipe supports / restraints have not been constructed in accordance with design requirements. (Section III.B.2) 4. Contrary to 10 CFR 50, Appendix B, Criterion X, and CECO Quality Assurance Manual, Quality Requirement No. 10.0, the licensee failed to provide an adequate inspection program in that electrical separation criteria established in quality control procedures were not sufficient to identify installations of raceway and cables violating design requirements for separation. (Section II.B.1) 8-1

S. Contrary to 10 CFR 50, Appendix B, Criterion X and the Ceco Quality Assurance Manual, Quality Requirement No.10.0, the program for inspection of activities affecting quality was not effectively implemented in that

   -     the inspection programs have not identified that the specified weld sizes in structural pipe support / restraints have the required weld configura-tion. (Section IV.B.1) 6.

Contrary to 10 CFR 50, Appendix B, Criterion XVI and Ceco Quality Assurance Manual, Quality Requirement 16.0, the licensee's electrical contractor's inadequate: corrective actions for the following NCRs were found to be a. NCR 39, issued in April 1979, identified weld deficiencies in elec-trical struts and hangers. The supporting documentation attached to the NCR identified that 90 percent of the welds were unacceptable. The corrective action block on the NCR was marked "N/A" and cont a statement identifying the welds as acceptable. There was no documentation supporting this corrective action statement on the NCR. (Section VIII.B.1) b. NCR 293, issued in May 1981, identified weld deficiencies on back to back B-line strut and spaced back to back strut. The corrective action was to rework the deficient welds on the back to back strut and return the spaced back to back strut to the vendor. Inspection of installed spaced back to back strut identified numerous weld deficiencies. Based on the weld deficiencies noted in the installed strut, the corrective action for this NCR was ineffective. (Section VIII.B.1) l B-2

UNITED STATES NUCLEAR REGULATORY CO M ISSION OFFICE OF INSPECTION AND ENFORCEMENT DIVISION OF INSPECTION PROGRAMS REACTOR CONSTRUCTION PROGRAMS BRANCN Report No.: 50-456/50-457/84-44, 84-40 Docket No.: 50-456, 50-457 Applicant: Commonwealth Edison Company Facility Name: Braidwood Inspection At: Braidwood, Illinois Inspection Conducted: December 10-20, 1984 and January 7-18, 1985 Inspectors: c ~ K

P. Keshishian, Sr. Reactor Construction Engineer Oste Signed Te Leader M LA ,i $ 4/I' W

,G.

B. Geofgiev, Sr. Re' actor Con!rtruction Engineer D&te S'igned fw & kYAk-K.rR. Hooks, Reactor Construction Engineer o2//Yk6~ Date Signed t+ W. Kropp, Reactor Inspection (Region III) S /f//f Odte Signed

                                                       // -                                             #jJM~ .5~

T. K. McLellan, Reactor Constraction Engineer ~ Date Signed Nemoto, Reactor onstruction Engineer El/SkS~ Date Signed

                    -                                M                                                               PI
                  ' S. R." Stein, Reactor Construction Engineer                                        Date Signed Consultants:                   R. M. Comptcn, D. C. Ford, J. B. McCormack, O. P. Mallon, W. S. Marini, E. Y. Martindale, A. iller, R. E. Serb and W. J. Sperko, Jr.

Approved By: . Rob'ert F. Heishman, Chief

                                                                                                          / f Oftte' Signed      !

Reactor Construction Programs Branch l

l l TABLE OF CONTENTS TOPIC SECTION INSPECTION SCOPE AND OBJECTIVES ................................ I ELECTRICAL AND INSTRUMENTATION CONSTRUCTION .................... II MECHANICAL CONSTRUCTION ........................................ III WELDING AND NONDESTRUCTIVE EXAMINATION ......................... IV CIVIL AND STRUCTURAL CONSTRUCTION .............................. V MATERIAL TRACEABILITY .......................................... VI DESIGN CHANGE CONTROL .......................................... VII CORRECTIVE ACTION SYSTEMS ...................................... VIII PROJECT MANAGEMENT ............................................. IX ATTACNMENT A - PERSONS CONTACTED AND DOCUMENTS REVIEWED ATTACHMENT 8 - GLOSSARY OF ABBREVIATIONS

. I. INSPECTION SCOPE AND OBJECTIVES The objective of this inspection was to evaluate the adequacy of

construction and project management controls at the Braidwood Station.

This objective was accomplished through review of the construction program, evaluation of project construction controls, and review of selected portions of the Quality Assurance Program, with emphasis on the installed hardware in the field. In addition, the scope and significance of identified problems were determined. Within the areas examined, the inspection consisted of a detailed examination of selected hardware subsequent to Quality control inspections, a selective examination of procedures and representative records, and limited observation of in process work. Interviews were conducted with site personnel from Management, Quality Assurance, Quality Control and various crafts. For each of the areas inspected, the following was determined: Were project construction controls adequate to assure quality construction? Was the hardware or product fabricated or installed a; Jesigned? Were quality verifications performed during the work process with applicable hold points? Was there adequate documentation to determine tie acceptability of installed hardware or product? Are systems turned over to the startup organiza'.fon in operable condition and are they being properly maintainet ? I-1

   .         II. ELECTRICAL AND INSTRUMENTATION CONSTRUCTION A. Ob.iective                                                               I
 ;                   The primary objective of the appraisal of electrical and instrumentation i                     construction was to determine whether safety-related components and

! systems were installed in accordance with regulatory requirements, Final Safety Analysis Report (FSAR) commitments, and approved vendor and 4 construction specifications and drawings. Additional objectives were to

determine whether procedures, instructions and drawings used to accom-l plish construction activities were adequate and whether quality related i records accurately reflect the completed work.

j 8. Discussion 1 Within the broad categories of the electrical and instrumentation ] construction, attention was given to several specific areas. These i included electrical cable, raceways, electrical equipment, instrumentation cable and instrumentation components. Additionally, a

review was made of a select number of documents associated with design i change control and nonconformance reporting.

A number of documents were generated by the applicant to record , individual observations of the NRC Construction Appraisal Team (CAT)

inspectors. Several are referenced directly in the discussions that
follow and Table II-1 is a complete listing of the documents initiated as a result of the electrical and instrumentation inspection.
1. Electrical Raceway Installation: a. Inspection Scope I

Eighty-five segments of installed Class 1E cable tray, with a total , length of about 1,200 feet, were selected from various plant areas 4 for detailed examination by the NRC CAT. These segments were i inspected for compliance to requirements relative to routing, location, protection and physical loading. Additionally, 43 runs of installed Class 1E conduit, with an aggregate length of about 1,050 F feet, were inspected for compliance to specified requirements such as routing, location, separation, band radii, support spacing and i associated fittings. Forty-two raceway supports and 145 concrete expansion anchors were i examined in detail for such items as location, material, anchor i spacing, weld quality, bolt torque and installed configuration. See Table II-2 for a listing of raceway support, cable tray and i conduit inspection samples. The following documents provided the basic acceptance criteria for the inspection: 1 6 1 II-1 l

I

                " Electrical Installation Work"Braidwood Station Units 1 e L. K. Comstock and Company, Inc. (LKC) Quality Control Procedure 4.3.12 " Conduit and Cable Pan Hangers and Auxiliary Steel Installation," Rev. 8, February 24, 1984 LKC Quality Control Inspection Procedure 4.8.1 " Inspection of  Class 1E Rev.

Installation," Safety-Related Conduit Installation / Wireway B, May 3, 1984 l l LKC Quality Control Inspection Procedure 4.8.5 " Ins of Class Rev. 1E Safety-Related D, July 31, 1984 Cable Pan Installations,pection LKC Quality Control Inspection Procedure 4.8.6 " Inspection of Concrete Expansion Anchors," Rev. C, Cctober 8,1984 LKC Quality Control Inspection Procedure 4.8.12 " Inspection of Seismic Class I Supports / Hangers," July 29, 1982 LKC Quality Control Inspection Procedure 4.8.13 " Inspection August 9, 1984of Class 1E Equipment / Junction Box Installation

b. _ Inspection Findings that in general Class 1E raceway installations with applicable design criteria.

Important quality attributes such tion were found to be as shown on approved c However . discusse,d several construction in the following deficiencies were identified and are sections. (1) Raceway Separation The Braidwood Station Final Safety Analysis Report (FSAR) section 8.3.1.4 "section and specifically Physical Independence of Redundant Systems," 8.3.1.4.2.2, provides the basic criteria Station. for acceptable raceway installations at the Braidwood This section describes requirements for physical arrangement of raceways in order to comply with the requira-ments of Regulatory redundant systems. Guide (RG) 1.75 for independence of , In general, these requirements specify that physical separation must be maintained between components of redundant divisions. NRC CAT inspectors noted that the separation distances spect-fied in the FSAR accurately reflect those detailed in RG 1.75 and the Institute of Electrical and Electronic Engineers (IEEE) Standard 384-1974 which it endorses. II-2 I

Separation criteria has also been established between safety and nonsafety-related raceway components. In this area the Braidwood Station FSAR specifies an exception to the standard

   -         separation distances of five feet vertical and three feet                      1 horizontal and reduces these distances to 12 inches vertical                   l and three inches horizontal. NRC CAT inspectors used this                        '

reduced criteria as basis for the inspection of raceway installations. The NRC CAT examination of the selected raceway sample dis-i closed numerous installations in which required spatial separation had not been maintained. Most of the identified deficiencies were observed between safety and nonsafety-related raceway components. of raceway separation deficiencies. Reference Table II-3 for a listing These deficiencies were discussed with the licensee and Sargent and Lundy Engineers (S&L) personnel. The discussions , disclosed that separation criteria has been designed into the raceway installation; thus in areas where less than the required separation exists, approved fire barriers such as cable tray covers would be shown on design drawings. NRC CAT inspectors selected seven of the identified deficiencies and reviewed the applicable design drawings with S&L engineering personnel to ascertain whether fire barriers had been specified for these installations. The results of this review indicates that in three of the seven examples identified, design details had not specified fire barriers. Additionally, as a result of the numerous separation deficien-cies observed, NRC CAT inspectors reviewed Quality Control inspection procedures to ascertain why many of these deficien-cies had not been documented by inspection personnel. Several procedures were reviewed, two of which concern the installation of Class 1E cable trays. L.K. Comstock & Company, Inc. (LKC) Quality Control Procedure 4.3.5 " Cable Pan Installation" section 3.17.11 states, in part..."all cable pan shall be installed such that a minimum of (1") separation is maintained between the cable pan being installed and: (1) all conduits (including sealtite and all EMT conduit for lighting, communi-cation, fire protection, etc.); (2) And all other cable trays." LKC Quality Control Procedure 4.8.5 " Inspection of Class IE Safety-Related Cable Pan Installations," section 3.1.17 states..." Verify a minimum of 1" space separation is maintained between all tray to conduit and tray to tray. If the separa-tion is unacceptable, the Quality Control inspector shall notify LKC Engineering via an ICR. LKC Engineering shall evaluatt the separation per the requirements of Procedure 4.3.5." NRC CAT inspectors noted that although the FSAR and design documents specify distances of 12 inches and three inches separation, the electrical contractor's procedures for con-trolling installation and inspection of raceway components specify only one inch of separation. Thus, installations : II-3

I which exhibited greater that one inch separation but less than that requ red by design documents would not be identified by craft or inspection personnel as deficiencies. q

   '                                                                                                                                                                                          \

Additionally, site procedures do not require the inspection of l nonsafety-related raceway components. As such, although the ' safety-related raceway may be installed in the proper location, an improperly located nonsafety-related raceway may cause an interface which results in an undete:ted violation of separation criteria. NRC CAT inspectors also identified several installations which exhibited less than one inch of separation. Many of these deficiencies had not been identified by inspection personnel. As a result of this observation, the electrical contractor has issued several Inspection Correction Reports (ICRs) to document and correct these conditions. Finally, with regard to electrical separation many of the types of deficiencies noted in both cable and raceway instal-lations have previously been identified by Region III inspectors. The deficiencies identified by Regional personnel and NRC CAT inspectors are the result, in some areas, of a difference in interpretation of criteria between the applicant and NRC personnel. Consequently, additional evaluation will be required by the NRC Office of Nuclear Reactor Regulation (NRR). Further discussion of this issue is presented in l Section II.B.2, below. ' With regard to many of the deficiencies identified above, NRC t i CAT inspectors concluded that the licensee has not beer effective in implementing a program to assure that sepa, deficiencies are identified and corrected. (2) Electrical Conduit Although geneially conforming to requirements, several isolated installation deficiencies were noted in the NRC CAT inspection sample. In addition, three flexible conduits and a valve solenoid casing were found to be damaged due to construction activities in the area. The following is a list of those deficiencies and the ICRs written as a result of the NRC CAT l findings. Conduit No. Findina ICR No. CIA 16E7 missing 0-ring 7549 1 1 C0A1380 missing segregation l code marker 7548 l 1 C0A13A8 missing segregation 7548 code marker II-4 l

CIA 5108 flex. conduit beyond -- maximum length , ,, C1R1205 construction damage 7546 C1R4487 construction damage 7861 C1R1315 construction damage 7880 CIA 1616 solenoid casing damage 7547 j The NRC CAT examined eight conduits which were within the

scope of the Braidwood Construction Assessment Program (BCAP) reinspection. These are identified on Table II-2, Raceway Inspection Sample. Although no significant deficiencies were j

identified by BCAP or the NRC CAT, the sample inspected was l not of sufficient size from which to draw a meaningful con-clusion regarding the effectiveness of the BCAP effort in this i area. 1 (3) Raceway Supports ! The examination of raceway supports was accomplished for both i conduit and cable tray applications. In general, attributes 4 such as location, material typa and size, anchor spacing, welds 1 (location, size and general quality), and installed configura-4 tion were found to be in accordance with design requirements. However, several discrepancies were noted within the sample of i supports inspected. Bolts of an indeterminate material were found by the NRC CAT inspectors on a number of supports. S&L's standard E8-115.0, Seismic Category I Electrical Equipment Fabrication and Erection Specifications, requires that bolts used with supports shall conform to ASTM-A-307 which requires a manufacturer's identification mark. Unmarked bolts were found by the NRC CAT on 10 of the 13 cable tray supports inspected whose design requires bolts as well as on a majority of the conduit sup-ports. As a result of the NRC CAT findings Commonwealth Edison Company (Ceco) issued NCR-692 regarding A-307 bolts for all plant systems. This issuo is further addressed in Section VI, Material Traceability and Co1 trol, of this report. Dimensional discrepancies were noted where lateral braces attach to cable tray supports for both of the braces inspected by the NRC CAT. The attachment location is identified on the detail drawings as dimension "T" and the value of T for a , J particular brace is provided on the hanger list drawings. However, the drawings do not provide an installation or inspection tolerance for tne T dimension. Although the actual location of brace H543 for support H043 was only one inch from its design dimension, the actual value of T for brace H562 to suppor*. H062 was found to be 15 inches from design. The QC check 1 P s for the two braces indicates acceptability to the drawing requirements. The dimensional discrepancy for brace II-5

1 2 11562 was subsequently oocumented on ICR 7575 by the electrical contractor. i - As the T dimension has not been translated into an adequate

inspection attribute additional review by the licensee wiil be l braces. to determine the extent of discrepant cable tray required Another issue regarding the configuration inspection of cable tray supports cable involves inspection of supports for Class IE tray. Prior to November 1,1982, only 35 percent of

! seismic Category I (safety and nonsafety) cable tray supports i were inspected for configuration. The Ceco memorandum to LKC requiring 100 percent inspection of all safety-related supports

after that date indicated that backfit inspecticns would be subsequently addressed. However, the NRC CAT inspectors found that the current LKC inspection procedure, 4.8.12, still only requires inspection of 35 percent of the supports and a backfit inspection program still is not documented. An internal CECO memorandum dated November 27, 1984, indicates that a System

i Control walkdown with S&L personnel will be used for, among other reasons, configuration inspection of those supports not originally inspected. The walkdown program therefore was i not reviewed by the NRC CAT inspectors. l Two other discrepancies were noted with cable tray supports by the NRC CAT inspectors and are considered to be isolated cas-l Support H070 was being used to support scaffolding and suppo - H001 included a Unistrut spring nut which war, rotated and not.'

fully engaged. As a result of these NRC CAT findings LKC: issued ICRs 7576 and 7585 respectively to document these conditions.

! In regard to conduit supports, a discrepancy was noted by the NRC CAT inspector with 8-Line strut welds. The welds on B-Line strut members of a conduit support and a juncticn box support were found to be in violation of acceptance standards ; specified by the strut manufacturer in an attachment to pre- ' viously issued Ceco NCR-293. The disposition of this NCR was that all installed B-Line struts meet the manufacturer's standards. As a result of this NRC CAT findino, LKC issued NCR 3770 to document and correct the installed S '.ane strut. The dispositioning of NCR-293 is further discussed in Section VIII, Corrective Action Systems, of this report. The NRC CAT inspection sample of concrete expansion anchors (CEAs) previously inspected and accepted by the licensee revealed several discrepancies. Embedded length was determined by subtracting the measured extension from the length marked on the CEA bolt end. The discrepancies noted are es follows: Conduit support WS-4, Drawing 20E-1-3552A: anchors did not meet criteria for spacing and ; embedded length. ICR 7875 subsequently was written.

II-6

I

- Conduit support WS-5, Drawing 20E-1-3552A:

anchors length. did not meet criteria for embedded ICR 7876 subsequently was written. Conduit support WS-505, Drawing 20E-1-3554A: anchors did not meet criteria for embedded length and thread engagement. TCR 7877 subsequently was written. Conduit support WS-503, Drawing 20E-1-3554A: I anchors did not meet criteria for embedded i length and thread engagement. In addition to the above CEA discrepancies, the anchors for cable tray support H038, Drawing 20E-1-3043H, were found with the ends cut off rendering their embedded length indeterminate. These anchors had been installed by the previous contractor (E.C. Ernst) and inspected by LKC in 1981. The General Inspection Report indicated the CEA's condition but there is no evidence of any further action to correct the deficiency. It is noted that prior to the NRC CAT inspection the ifcensee had identified a generic programmatic deficiency with respect to the inspection of CEAs and has notified NRC Region III of this deficiency in accordance with the requirements of 10 CFR 50.55(e).

c. Conclusions The licensee's implementation of electrical separation criteria has not been consistant with the FSAR commitment to IEEE 384, and several items regarding the interpretatico of separation criteria ,

will require additional NRC review. In addition, the applicant's program separation has not been effective in identifying and correcting raceway deficiencies. The 'najority of bolts used on raceway supports are of indeterminate material by the ASTM as they do not contain a manufacturcr's mark as required standard. The location dimensions for brace to cable tray support attachments inspected were fcund to be deficient as the dimensions are not toleranced on the detail drawings.

2. Electrical Cable Installation

a. Inspection Scope The NRC CAT inspectors selected a sample of installed Class IE cable runs that had been previously accepted by QC inspectors.

The sample included high voltage, power, control and instrument cables. For each of these cable runs, physical inspection was made to ascertain compliance with applicable design criteria relative to size, type, location, routing, bend radii, protection, separation, identification and support. II-7

- Additionally, the NRC CAT inspectors selected approximately 182 cable ends for examination of terminations. These were inspected relative to the applicable design and installation documents for items such as lug size and type, proper terminal point configura-tion, correct identification of cable and conductors, proper crimping of lugs or connectors and absence of insulation or jacket damage. ned. See Table II-4 for a listing of cable terminations exami-The following high voltage and power cables totaling approximately 1,900 feet were solected from different systems, electrical trains, locations and were of various sizes: Cable Tyge ISIOO1-PIE 3 conductor No. 2 AWG SKV 1SIO32-PIE 3 conductor No. 10 AWG 600V 1RH001-PIE 3 conductor No. 2 AWG SKV 1RH019-P1E 3 conductor No.10 AWG 600V 1SX039-P1E 3 conductor No. 10 AWG 600V 1DC021-P1E 3 conductor No. 10 AWG 600V 1DG075-P1E 3 conductor No. 10 AWG 600V The following control cables totaling approximately 2,000 feet were selected from different systems, electrical trains, locations, and were of various sizes: Cable Tyge 1MS298-C1E 7 conductor No. 14 AWG 600V 1MS315-CIE 9 conductor No. 14 AWG 600V 1RC055-C2E 4 conductor No. 14 AWG 600V 1RC091-C1E 12 conductor No.14 AWG 600V 1RC107-C2E 4 conductor No. 14 AWG 600V 1 WOO 32-C2E 4 conductor No. 14 AWG 600V 1SI003-C1E 2 conductor No. 14 AWG 600V 1RH003-C1E 9 conductor No.14 AWG 600V The following instrument cables totaling approximately 750 feet were selected from different systems, electrical trains, and locations: Cable Tyge IRC427-K3R 1 pair No. 16 AWG 1MS109-K1R 1 pair No. 16 AWG ICS071-K1E 1 pair No. 16 AWG 1FW019-K2R 1 pair No. 16 AWG 1CS088-K2R 1 pair No. 16 AWG II-8

The following documents provided the basic acceptance criteria for the inspections: LKC Quality Control Inspection Procedure 4.8.8, " Cable Installation Inspection," Rev. 8, September 14, 1984 LKC Quality Control Inspection Procedure 4.8.9, " Electrical Termination Inspection," Rev. E, July 9, 1984 LKC Work Instruction 4.3.9, " Cable Termination Installation," Rev. D, May 1, 1984

b. Inspection Findings (1) Routing In general, the routing of Class 1E cables through design designated raceway systems was found to De in accordance with specified criteria. However, a discrepancy was noted with the pull ticket for cable IMS109-K1R. The ticket did not indicate the cable tray segment through which the cable was routed. This was considered an isolated case by the NRC CAT inspectors.

(2) Separation The inspection of Class 1E cable installations revealed a number of instances in which cable of one electrical division did not maintain separation from cable or raceway of another electrical division. Deficiencies occurred primarily in installations where cable exited design designated raceway and were run free-air before entering electrical equipment or additional raceway segments. NRC CAT inspectors identified several examples in which a cable of one electrical division was in physical contact with raceway or cable of another division. i Additionally, NRC CAT inspectors identified nonsafety-related cables 1FW269-C18, IMS148-C18, IMS147-C1B and IMSO95-K1B which had been routed with Class 1E cables in safety-related cable trays and conduits.

NRC CAT inspectors observed that these installations were l not in compliance with requirements detailed in section l

8.3 of the Braidwood Station FSAR and the commitment to IEEE standard 384-1974, " Criteria for Separation of Class 1E Equipment and Circuits." ( IEEE 384-1974 section 4.6.1 requires that... "Non-Class 1E circuits shall be separated from Class 1E circuits by l the minimum separation requirements specified in Section i 5.1.3, 5.1.4 or S.6 or they become associated circuits." Additionally, section 4.5 specifies that... " associated circuits shall comply with one of the following: i II-9

(1) They shall be uniquely identified as such and shall remain with, or be separated the same as, those Class i 1E circuits with which they are associated. (2) They shall be in accordance with (1) above from the Class 1E equipment to and including an isolation device. Beyond the isolation device the circuit is not subject to the requirements of this document provided it does not again become associated with a Class 1E system. (3) They shall be analyzed or tested to demonstrate that Class 1E circuits are not degraded below an accept-i able level." Finally, with reference to analysis, section 5.1.1.2 states... "In those areas where the damage potential is limited to failures or faults internal to the electrical equipment or circuits, the minimum separation distance can be established by analysis of the proposed cable instal-lation. This analysis shall be based on tests performed to determine the flame retardant characteristics of the proposed cable installation considering features such as cable insulation and jacket materials, cable tray fill, and cable tray arrangement." Discussions with licensee and engineering personnel concerning the cable separation deficiencies identified by the NRC CAT inspectors revealed that: (1) Based on stte design criteria these cable configurations were not considered by the licensee to be deficiencies. (2) Although some non-Class 1E cables are routed with or share enclosures with Class IE cables they are not designated as associated circuits. 3 (3) No analysis had been performed to demonstrate that these non-Class 1E circuits would not degrade Class IE circuits. As discussed in Section II.B.1.b.(1), above, several areas of site implemented separation criteria differ from the requirements specified in section 8.3 of the Braidwood FSAR and IEEE standard 384-1974. Relative to cable i a installations, differences exist in the following areas: i (1) Classification of non-Class 1E cables which are routed with, share enclosures with, or are installed in close j proximity to Class 1E cables. t (2) Separation between cables installed free-air and cables I, or raceways of other electrical divisions. 1 I ' II-10

(3) The use of cable jacket insulation as an approved fire barrier for Class IE cables. Some of these issues have previously been identified by Region III inspectors and have resulted in a number of meetings with the applicant, Sargent & Lundy Engineers and NRC Office of Nuclear Reactor Regulation. The results of these meetings and correspondence reviewed by the NRC CAT inspectors indicates that a number of items remain open relative to proper interpretation of cable separation criteria. As a result the items documented by Region III and the additional concerns identified during the NRC CAT inspection will be discussed with NRR for appropriate action. Cable separation deficiencies were also identified within many electrical equipment enclosures. However, in each instance identified by NRC CAT inspectors the electrical contractor had initiated a Cable Separation Conflict Report to document the condition. Finally, as a result of comments made by NRC CAT inspectors S&L developed engineering analyses for several of the cable installation deficiencies discussed in this section. These analysis reports will be discussed with NRR for appropriate evaluation. (3) Cable Spacina Braidwood Station power cable installations have been designed in accordance with AIEE/IPCEA P-46-426, 1962

         " Power Cable Ampacities - Volume I - Copper Conductors" and P-54-440, 1972 "Ampacities - Cables in Open Top Cable Trays." The power cables have been derated in accordance with the AIEE/IPCEA Standards such that cables sharing raceway may be in contact. As a result, cables in solid metal trays could be installed without maintained spacing.

No deficiencies or concerns were identified in this area. (4) Cable Damage The NRC CAT inspectors observed the following cable installations which exhibited damage to the cable jacket or insulation:

Cable 1CV548-C1E has a slice in its jacket which extends into the conductor of the cable. The location of this damage was near cable tray node 15138 below motor control center MCC-1AP21E. As a result of this observation, the electrical contractor has issued NCR-3713 to document and correct this condition.

II-11

Cable IVP029-C2E was found with a perranent indentation in its jacket and bent below the requirec minimum bend radius due to scaffold lumber against the coiled cable. LKC NCR-3704 was subsequently issued to document this condition.
Cable ICC174-CIE was found not meeting minimum bend radius requirements at the Kellums grip above riser 1R483. LKC QC tion.issued NCR-3717 to document and correct this condi-These three instances are considered by the NRC CAT inspectors to be isolated cases.

(5) Cable Identification In general, the identification of Class 1E cable instal-lations was found to be in accordance with applicable design criteria. One example was identified in which a Class IE cable had been inappropriately identified. Cable 1C0037 located in 4160V switchgear 1AP05E had been labled with both safety (dark background) and nonsafety-related (light background) segregation codes. A possible explanation for this condition was that in attempting to identify the positive and negative phases of this cable craft personnel had inadvertently used labeling which represents a nonsafety-related systems designation. As a result of this observa-tion, the electrical contractor has issued ICR 7868 to identify and correct this condition. No other deficiencies were identified in this area. (6) Tray Fill The Braidwood Station FSAR section 8.3 sets forth requirements for limiting tray fill to the top of the side rails of the tray. During the inspection of Class 1E cable installations, NRC CAT inspectors observed several cable trays in which this requireme1t had not been met. However, in each instance identified, the electrical contractor had previously issued inspection reports to document and correct this condition. (7) Terminations Although the vast majority of the NRC CAT inspection sample was found to conform to design requirements, several isolated deficiencies were noted. These discrepancies were not considered to be technically or programmatically significant by the NRC CAT inspectors. However, a failure to meet an FSAR comitment regarding wire splices was also found by the NRC CAT. II-12

The Braidwood Station FSAR commitment to IEEE Standard 42 prohibits the use of wire splices in Class 1E equipment. However, NRC CAT inspectors observed in-line butt splices in numerous electrical panels. As site procedures do not require the location of splices to be depicted on design documents, NRC CAT inspectors were unable to determine how extensively these splices have been utilized. Additional-ly, the licensee had previously issued NCR-598 to document hardware deficiencies in installed butt splices and reported this condition to NRC Region III in accordance with 10 CFR 50.55(e). The use of butt splices in Clast 1E panels requires documentation in the FSAR as an exception to the IEEE standard. The following are the isolated discrepancies noted by the NRC CAT inspector: Conductor insulation damage on the orange conductor of cable 1RH108-CIE in motor control center IAP21E, cubicle F3. ICR-7610 was subsequently issued to document this condition. Several terminal screws were found loose in the Diesel ShutdownGenerator ControlIPLO5J. Panel, section Panel 1A and in the Remote ICR's 7646, 7644, and 7643 were subsequently issued to document these condi-tions. Internal motor lead T-9 was found damaged in motor operated valve ICSQO1A. ICR-7867 was subsequently issued to document this condition. The red conductor of cable ISIO53-CIE, in motor operated valve ISIB802A, was excessively bent and not meeting minimum bend radius criteria. ICR-7870 was subsequently issued to document this condition. (8) Seepage of Oil From Okonite Cable NRC CAT inspectors observed any oily substance seeping from jackets of numerous installed and terminated cables manufactured by the Okonite Company. This condition was observed in both Class 1E and non-Class lE cables in various Class IE equipment throughout the facility (motor control centers, main control boards, control panels, motor operated valves, etc.). Information obtained from NRC Region III, CECO, and S&L revealed the following: In a letter dated October 4, 1982, including an attached engineering report (No. 364), the Okonite Company informed Ceco that, with reference to the identical condition identified at Byron Station, this seepage "will not affect the reliability or life of the cables." II-13

i In a letter dated November 1, 1983 from Illinois Power Company (IPC) to NRC Region III (in accordance with 10 CFR 21), IPC stated that "...The effect of this oil on equipment connected to the cable is of concern. If oil that leaked from the divisional cable were to accumulate on essential components in Class 1E equipment, the possibility exists that misoperation of Class IE equipment could occur." On January 10, 1984, Information Notice 84-1 was issued by the NRC Office of Inspection and ) Enforcement to all nuclear facilities. This Information Notice references the above letter from IPC and states the concern that "... Leakage of oil from the cable at terminations may create a fire hazard, and degrade other electrical equipment." In addition, this Information Notice suggests that "... Addressees review the information for applicability to their facilities." The NRC CAT inspectors provided a copy of the above referenced IPC letter to licensee personnel and asked whether Ceco or S&L has reviewed the question of the possible degradation of Class IE equipment. The licensee indicated that no such review had been made. Further attention is required by the licensee to assure that Class 1E equipment or components will not be adversely affected by the seepage from certain Okonite cable.

c. Conclusions In general, cable installations including terminations have been accomplished in accordance with requireients. However, numerous separation deficiencies exist in areas where cable has been run free-air. In these areas further licensee attention is required to assure that deficiencies are identi-fied and that analysis subsequent corrective action or appropriate is initiated.

Further attention will be required by the licensee to assure that Class 1E equipment and components are nat adversely affected by the deficiencies identified in some Okonite manufactured cable.

3. Electrical Equipment Installation

a. Inspection Scope Over 45 pieces of installed or partially installed electrical equipment and associated hardware items were inspected.

Samples were based on system function and safety classification. i II-14 i

The following specific electrical components were inspected in detail: (1) Motors The installation of five motors and associated hardware was inspected for such items as location, anchoring, grounding, identification and protection. The motors , inspected were: J Component Cooling Pump Motor ICC01PA Containment Spray Pump Motor ICS01PA-M Containment Spray Pump Motor IC501PB-M Residual Heat Removal Pump Motor 1RH01PA Safety Injection Pump Motor ISIO1PB s (2) Electrical Penetration Assemblies The following containment penetration assemblies were inspected: 1LV09E - Instrumentation ILV10E - Instrumentation INR03E - Nuclear Instrumentation ' ISIO1E - Essential Power ISIO2E - Essential Power ISIO4E - Essential Control Power The location, type, mounting and identification of these penetrations were compared with the installation drawings

i and vendor manual.

(3) Circuit Breakers Circuit breakers for the following Class 1E motors were examined to determine compliance with design and installation documents for size, type, system interface and maintenance. Residual Heat Removal Pump 1A Residual Heat Removal Pump 1B Safety Injection Pump 18 The use of circuit breakers with integral undervoltage trip attachments at Braidwood Station was also investi-( gated. (4) Switchgear and Motor Control Centers The following switchgear and motor control centers were inspected: II-15

IC50078 1C5001A 1RH8701A ISI8821A ISI8802A The following documents provided the basic acceptance criteria for the inspections: i Sargent & Lundy Engineers Electrical Specification LKC Quality Control Procedure 4.3.17. " Electrical Penetration Installation, Termination and Maintenance," Rev. A, January 3, 1983 LKC Quality Control Inspection Procedure 4.8.6,

                                                                      " Concrete Expansion Anchors," Rev. C, October 8, 1984 LKC Quality Control Inspection Procedure 4.8.13,
                                                                      " Inspection of Class IE Equipment / Junction Box Installation," Rev. E. August 9, 1984 LKC Quality Control Inspection Procedure 4.8.16,
                                                                      " Inspection of Revision to Installed Ele:trical Equipment," Rev. C, August 2, 1984 LKC Quality Control Inspection Procedure 4.8.17,
                                                                      " Inspection of Electrical Penetrations," Rev. O, March 5, 1984 l

b. Inspection Findings (1) Motors i

The inspection of the 4kV Class 1E motors revealed no I major hardware deficiencies. The motors examined were of the size, type and configuration shown on design documents. Although the installation documents for most of the motors ! did not indicate torquing of the motor hold down bolts, Phillips, Getchow Company (PGCo) is in the process of i performing an overall reverification program which includes retorquing all bolts with QC verification. The maintenance activities for the motors were found by the NRC CAT inspectors to be fragmented among several organi-zations. The electrical contractor performs periodic I surveillance for protection and space heater operation, , Ceco's Operational Assessment Department performed the periodic insulation resistance tests during storage, and the site Operating Department performs the periodic shaft rotation. This division of maintenance responsibilities was previously identified as a program weakness by the ' Institute for Nuclear Power Operations (INPO) which resulted in Ceco NCR-689. The NCR requires projact construction to develop a procedure to define responsi-II-17 3 1 f

1 bilities for preventive maintenance and to control the activities of Ceco's contractors who must also provide maintenance procedures. l No deficiencies were found with the maintenance activities , and records reviewed by the NRC CAT. i (2) Electrical Penetrations ; i The penetrations examined were found to be in accordance with the design documents. A review of the weekly pene- , l tration pressurization checks revealed that the QC inspec-tor used a meno form to request that a penetration which had lost its pressure be repressurized. The electrical contractor indicated during discussions with the NRC CAT inspector that the weekly recording of pressure required by the inspection procedure, 4.8.17, was not considered 4 an installation requirement. Therefore, it was their position that the procedural requirement to record f deviations of installation requirements on an Inspection Correction Report was not applicable. However, no procedural guidance is provided for correctiun of a zero i pressure situation. When the NRC CAT inspector requested the leak rate test documentation for a penetration with consistently falling weekly pressure readings, the inspector was informed that the leak rate calculations for Unit I penetrations could not be produced. NCR-7918 was subsequently written to ] document and correct this situation. 4 Although not technically significant, these instances indicate a laxity in generating and maintaining ouality related records. 1 (3) Circuit Breakers The examination of the selected circuit breakers indicated ' that they had been purchased, installed and maintained in accordance with the applicable design documents. Important installation attributes such as proper alignment and main contact penetration were verified by physical inspection and review of construction test records. Maintenance records were also reviewed and indicate that j lubrication and set point verification had been performed. , i NRC CAT inspectors also evaluated licensee initiated actions and review of NRC Information Notice 83-18 j " Failures of the Undervoltage Trip Function of Reactor Trip

System Breakers" and NRC Generic Letter 83-28 " Required I

Actions Based on Generic Implications of Salem ATWS Events." NRC CAT inspectors noted that the Braidwood Station design will utilize Westinghouse type 05-416 breakers in the Reactor Trip System. The review of initial and supplemental actions to Generic Letter 83-28 indicates l II-18 3 i

  . . . . _ _ . . _ _ - . _ . , _ . _ . _ _ _ _ . . . _ _ _ _                                                 _ . . ~ _ _ . _ _ . . . . , _              . - , . . . .

an ongoing effort by the licensee to resolve the main-tenance and operational problems identified in the use of these breakers. (4) Switchaear and Motor Control Centers The installation of Class IE 4160V switchgear 1AP05E and 1AP06E was found to be in accordance with design details and vendor requirements. Some examples of separation deficiencies were observed in cable and wiring installa-tions within this equipment. However, in each instance identified, the electrical contractor's QC inspectors had previously identified and documented the condition. (5) Station Batteries and Racks During the inspection of the 125V dc battery rooms NRC CAT inspectors observed debris in the rooms and on the battery cells. Much of this debris appears to have been caused as a result of construction activity associated with the installation of adjoining block walls. As a result of this observation the debris was removed and the battery cells were cleaned by the licensee. The to be125V batteries in good were then examined in detail and found condition. Maintenance activities were reviewed and in general had been performed in accordance with requirements. Records demonstrating performance of intercell terminal resistance checks were not provided by the licensee. However, NRC CAT inspectors noted that the licensee plans to disassemble the 125V battery connections and that this maintenance activity would be performed when cell connections are re-established. In connection with this issue, the review of Station maintenance activities in general indicates that while some adninistrative respon-sibilities are not clearly defined, the maintenance program and its implementation were found to be comprehensive. The inspection of the 125V battery racks disclosed that indeterminate bolting material had been used in the assembly process. This issue is discussed in detail in Section VI, Material Traceability and Corrective Action, of this report. (6) 125V DC System Inspection of components comprising the 125V de system disclosed a deficiency in the installation of 125V de fuse panel 1DC10J. Design details found on drawing 20E-0-3391-AR specify the use of concrete expansion anchors for installation of this equipment. The details show 5/8-inch anchors spaced 12 inches center to center. Physical inspection of this equipment disclosed that a number of the anchors installed exhibited less than the 12-inch spacing required. Additionally, several anchors 11-19

were in violation of edge distance requirements detailed in site procedures and the electrical specification. As a result of this observation the electrical contractor has issued NCR-3782 to identify and resolve this condition. Other 125V de system components examined were found to be installed in accordance with applicable requirements. (7) Control Panels The various control panels examined were installed in accordance with applicable design documents, and no significant deficiencies were noted. (8) Motor Operated Valves The installation of the motor operated valves inspected conformed to the applicable requirements with only one deficiency noted by the NRC CAT inspectors. A crack was observed in the number 2 control rotor for valve IRH8701A. ICR 7869 was subsequently issued to document this condi-tion.

c. Conclusions The installation of Class 1E equipment and associated hardware at Braidwood Station was generally found to be in accordance with the applicable design documents.

Current maintenance activities were found to be effectively implemented.

4. Instrumentation

a. Inspection Scope

! Due to a recently instituted retrofit program pertaining to the i installation of instrumentation components, few items were con-i sidered by the contractor to be complete during the NRC CAT inspection, NRC CAT inspectors did select nine supports, four instrument racks, runs for inspection. seven instruments, and three instrument tubing It should be noted that the three instrument tubing runs selected represented QC inspected installations. the entire amount of completed and 1 of items inspected. See Table II-5 for a detailed listing Additionally, approximately 200 feet of in process instrument tubing was examined for general workmanship and conformance to industry standards. Theinspection: the following documents provided the basic acceptance criteria for 1 [ t II-20 l

PGCo Construction Procedure PGCP-22. " Process Piping and Instrument Line Supports in Category I Buildings - Selected Supports," Rev. 12 PGCo Construction Procedure PGCP-30, " Installation of ASME III and Safety Related Instruments and Instrument Lines," Rev. 7

b. Inspection Findinos Although the inspection sampit was limited, only one installation deficiency was noted. The NRC CAT inspectors measured a dimension of %-inches on tubing run OPC-WO020 which is depicted on Detail A on drawing OPC-W0020, Sh. 1, Rev. A as being 1-foot %-inches.

This installation had been inspected and accepted, and is considered complete by the contractor. In addition, the NRC CAT inspectors observed a number of instances of damage caused by construction activity and scaffold erection. These include: Instrument Line ILT-0459 Near Rack IPL50J Instrument Line 1FW-91E8 Near Rack IPL56J Electrical Wireway Section of Rack IPL75J

c. Conclusions The NRC CAT inspectors consider' the quantity of completed instru-mentation installations far too limited to draw a valid conclusion as to the quality of instrumentation construction.

However, it is evident that additional care needs to be exercised by personnel erecting scaffolding to insure that completed or partially activity completed in the area. installations are not damaged by subsequent II-21

TABLE II-1

00CthENTS ISSUED AS A RESULT OF THE NRC CAT INSPECTION ELECTRICAL AND INSTRUMENTATION Document Number

Subject Document Number
Subject AIR 169 Supports ICR 7617 Separation NCR 0692 Bolting ICR 7618 Separation NCR 2262 Conduit NCR 2315 ICR 7619 Separation Support ICR 7620 NCR 3202 Separation Conduit ICR 7621 Separation NCR 3704 Cable NCR 3713 ICR 7622 Cable Tray Cable ICR 7623 NCR 3717 Cable Cable Tray NCR 3758 ICR 7624 Separation Equipment ICR 7643 NCR 3770 Supports Cable NCR 3783 ICR 7644 Cable Concrete Anchors ICR 7645 Cable ICR 1603 Cable Tray ICR 7646 Cable ICR 4591 Cable Tray ICR 6075 ICR 7647 Cable Cable ICR 7678 ICR 7546 Support Conduit ICR 7679 Support ICR 7547 Conduit ICR 7548 ICR 7680 Support Conduit ICR 7681 Support ICR 7549 Conduit ICR 7811 Separation ICR 7571 Conduit ICR 7575 ICR 7812 Separation Support ICR 7813 ICR 7576 Support Cable Tray ICR 7816 Clearance ICR 7585 Support ICR 7600 ICR 7817 Separation Separation ICR 7867 ICR 7601 Separation Termination ICR 7868 Termination ICR 7602/7603 Conduit ICR 7869 ICR 7607 Equipment Cable ICR 7870 ICR 7608 Cable Termination ICR 7609 ICR 7875 Concrete Anchors Conduit ICR 7876 ICR 7610 Cable Concrete Anchors ICR 7611 ICR 7877 Concrete Anchors Cable ICR 7880 l ICR 7612 Conduit Cable ICR 7881 ICR 7615 Cable Conduit ICR 7915 Equipment ICR 7616 Cable ICR 7918 Equipment
AIR: As-built Information Report ICR: Inspection Correction Report NCR: Nonconformance Report II-22

1 4 i TABLE II-2

RACEWAY INSPECTION SAMPLE Cable Tray: 2502E-P2E 2503E-P2E 21511L-P2E 1502F-PIE 1189MC-C1E 1555J-P2E 1554J-P2E 1573F-P1E 1R219-PIE 12006C-CIE 1553J-P2E 1552J-P2E 1517A-P1E 1516A-P1E 11900C-CIE 1551J-P2E 1703F-C2E 1513A-PIE

;                                                                                                                                                                                                                         1511A-P1E                     11951C-C1E 1915F-C2E                                                 1914F-C2E                    1510A-PIE                                                                       1514A-P1E                      1R227-CIE 1912F-C2E                                                 1911F-C2E                    15148-P1E                                                                       1515A-P1E                      11894C-CIE 1910F-C2E                                                 1909F-C2E                     15158-P1E                                                                       1516A-P1E                      11898C-CIE 1908F-C2E                                                 1R369-C2E                    15168-PIE 1R370-C2E                                                                                                                                                              1613H-C2E                       11952C-CIE 11461J-C2E                   1612H-C2E                                                                       1610H-C2E 4

11460J-C2E 11459J-C2E 11885C-C1E 1599H-C2E 1609H-C2E 18145-PIE 18135-P1E 11912G-K1E 1R275-C2E 1R340-P2E 18125-P1E 18115-P1E 11910G-K1E 11530M-P2E 11519M-P2E 18095-P1E 18075-PIE 11907G-K1E 11518M-P2E 11517M-P2E 1977A-P1E 1978A-PIE 1190$G-K1E 11516M-P2E 11487M-P2E 11911G-K1E 1980A-PIE 1981A-P1E 1R345-P2E 12121M-C1E 11908G-K1E

1982A-PIE 1983A-P1E 12137M-C1E 12138M-CIE 11906G-K1E 1991A-P1E 12141G-K1E 12062M-CIE 12034M-CIE 1R270-K1E Cable Tray Supports:

Support No. Drawing No. Support No. Orawing No. ' i 13H2O (3 supports) 20E-0-3031 H042 H001 20E-0-3052H 20E-2-3244H H046 20E-2-3244H H025 20E-0-3052H H048 N033 20E-2-3244H 20E-0-3063H H062 H025 20E-2-3244H 20E-0-3063H H562 (brace) t H042 20E-2-3244H 20E-0-3063H H063 H043 20E-2-3244H 20E-0-3063H H065 H543 (brace) 20E-2-3244H 20E-0-3063H H070 20E-2-3244H N071 20E-2-3244H l Conduits: ' Conduit No. Lenoth (Feet) Conduit No. Length (Feet) ! *C1R1213 12 C0A13A8 i CIR1315 6 35 C0A1380 6 C1R1334 37 C0A5410 6 C191387 40 C0A7271 5

                                               *C1R1494                                                              20                                                            C0A7269                                                                    6 l                                                C1R3441                                                              13                                                           CIA 1616 i

C1R3443 30 76 CIA 16E6 C1R4220 21 48 CIA 16K1 C1R4235 10 25 CIA 17KO i C1R4336 6 74 CIA 4317 1 C1R4364 11 58

CIA 5105 45 i

11-23 1

l

  .                                                                TABLE II-2 (Continued)

RACEWAY INSPECTION SAMPLE Conduit No. Length (Feet) Conduit No. Lenath (Feet) CIR4462 20

CIA 5108 18 CIR4487 16
CIA 5133 27 CIR44C5 30
CIA 5166 18 C1R5109 32 CIA 5189 26 C1R5401 20 CIA 5329 5 CIR5402 12 CIA 5368 10 CIR54F2 26
CIA 6140 30 CIR54F3 26
CIA 6185 10 C1R7612 25 CIA 61GO 20 C1R7614 25 CIA 61G2

' 20 CIR7823 36 i Conduit Supports: Support No. Drawina No. Location FC-10 20E-1-3544A TCC-3 Reactor Building 20E-0-3363A Auxiliary Building CC-20 20E-1-3342A CC-115 Auxiliary Building 20E-1-3544A Reactor Building CC-CP-3 20E-1-3544A WH-4 Reactor Building 20E-0-3362A CF-1 Auxiliary Building ' 20E-0-3313A _ Auxiliary Building CF-3 20E-0-3313A WH-3 Auxiliary Building 20E-0-3362A Auxiliary Building CC-171 20E-0-3362A 1 WV-27 Auxiliary Building 20E-0-3544A Reactor Building TS5-1 20E-1-3542A Reactor Building CP-500 20E-1-3322A TS3-2 Auxiliary Butiding 20E-1-3343A Auxiliary Building CC-3 20E-1-3343A CC-74 Auxiliary Building 20E-0-3313A Auxiliary Building CC-87 20E-0-3313A CC-30 Auxiliary Building 20E-0-3363A Auxiliary Building CC-44 20E-0-3363A WV-8 Auxiliary Building 20E-1-3532A Reactor Building CC-5 20E-1-3533A Reactor Building CC-5 20E-1-3533A Reactor Building FC-5 20E-1-3533A Reactor Building TS3-6 20E-1-3533A Reactor Building IJB201R 20E-1-3513 Reactor Building 11-24

TABLE II-2 (Continued) RACEWAY INSPECTION SAMPLE Concret Expansion Anchors: Quantity Quantity Anchor Diameter (irches) Inspected Torque Tested 1/4 56 54 3/8 44 0 1/2 26 16 5/3 19 13 BCAP inspection sample II-25

O TABLE II-3 ELECTRICAL RACEWAY SEPARATION DEFICIENCIES Raceway segments listed in the A columns do not maintain required separation as installed relative to raceway segments listed in the B columns. A B A B C0A3125-PIB 1900A-P2E CCA3117-CIB 1900A-P2E C0A3114-P1B 18998-C2E CCA3220-PIB 1895A-P2E 1870P-CIB 1894J-K2E 1870N-F1B

18948-C2E 1888J-K2E 18880-C1B C0A5242-P1B 11460J-C2E C0A5245-PIB 11459E-P2E C0A5286-PIB 11459E-P2E CIA 4279-P1B 1832E-CIE CIA 4257-P1B 1833E-C1E CIA 4258-PIB 1833E-CIE 18098-P1E 1809N-PIB 1930TS-P1E 1805P-C1B C0A5291-K2B 11317A-PIE C0A5191-CIE C0A5266-P2B CIA 7131-PIB 11519M-P2E C0A5191-CIE C0A5250-C2B 11584J-C2B
11519M-P2E 11591L-P2E 11621E-PIB CIA 6169-PIE
11564E-PIB 11520L-P2E 11547C-CIB 11547C-C1B 11583J-C2E 1613H-C2E
C0A12F7-P2B C0A12F8-P2B 1613H-C2E 1514A-PIE CIA 0287-C2B CIA 0274-K2B
1516A-P1E 7702AA-C2E C0A3323-K1E 11430N-P2B 11448V-C2E

   },         1778R-X1B       1797J-K3R                     1785R-K1B       1797J-K3R 11583J-C2E      115447C-C1B                   CIA 51381-CIB   19828-CIE C0A3170-PIB     1896A-P2E                     1896A-P2E       1844N-PIB C0A3167-CIE     18968-C2E                     11906C-CIE      119058-K18 1713D-CIB       1696H-CIE                     CIR5130-P2B

C290R-P2E 1397R-P2E 13978-P2B 13980-K2B 1398E-C2E 1427M-CIE 1358K-P1B 1800V-PIB 1799T-PIE CIR4701-C1B 1380E-C2E 1309J-C1B 1380E-C2E CIR4201-C2B IJB303R-K3R CIR4322-P2E 1343J-C1B CIR44C5-C2E 1430J-C1B CIP7806-KIR 1R104-PIB CIR7820-K4R 1341P-P2B CIRS405-K2R 1341P-P1B 1694A-PIE 1696G-C1B 17:30-C1B 1696H-C1E 1784U-CIE 1804P-C1B 17! 70-CIE 1804P-C1B 17980-CIE 1788R-K1B CIR4220-K3R
lighting conduit NOTE: The (*) designation indicates physical separation of less than one inch between the two raceway segments.

l l II-26

L

1

 ,                                                                                         TAELE II-4                                            l CABLE TERMINATION INSPECTION SAMPLE Location                                              Drawing No.                           Cable No.

MOVISI8802A 20E-1-4884 ISIO53, 151054 MOVISI8821A 20E-1-4883C 1SI189, 15I190 MOV1RH8701A 20E-1-4874 1RH027, 1RH028 MOVICS001A 20E-1-4877A 1C5046, 1C5109 MOVICS001B 20E-1-4875 1CS031, 1CS032 Sequencing and 20E-1-4123C IEF043, IEF045, 1EF084, IEF087, Actuation Cabine'. IPA 14J 1EF064, IEF044, 1SX314, 1SX524, 1EF041, IEF040, IEF085, IEF052, IEF049, 1EF051, IEF050, 1EF053, IEF048, IEF097, IEF042 Process Instrumentation 20E-1-4118 1FW707, IFW706, IRC372, IRC391, and Control Rack IPA 02J 1RC396, IRC401, IFW876, 1FW877, IM5116, IM5122, IFWO43, 1FWO48, 1C5088, 1SI654. ICC290, IRC383, 1RC377, IMS113, IMS119, IRC386, IRC380, 1RY202, ISI468, IFW921, IRC375, IRC394, IRC399, IRC404, 1RY204, IRC406, 1FWO26 Diesel Generator 20E-1-4093A 1DG027, 1DG155, IDG018, 1DG200, Panel 1PLO7J IDG022, 1DG115, IDG165, IDG034, IDG169, 1DG083, 100062, 100064, IDG157, 100073, IDG071, IDG070, IDG173, IDG082, IDG168, 100058, IDG117, IDG111, 100002, IDG094, IDG119, 1DG118, IDG206, IDG207, ISX2 ISX290, ISX295, IVD004 Main Control Board 20E-1-4044N 1AP139, IAP050, IAP075, 1PM01J 20E-1-4044V 10C085, IAP120,1AP119,1AP137,1APO! l 1AP045, 1AP138, 1AP080 1 Remote Shutdown 20E-1-4087K IVC 015, IVC 023, 10C183, IMS581, Panel IPLO4J 1MS584, IMS269, IMS308, IMS531 l 1MS288, IMS278, IMS285, IMS272, IMS275, IM5519 20E-1-4089G IVP038, IVPO42, ISX305, ISX209, ISX019, ISX016, ISX020, 1EF044, ISX017, ICV 016, ICV 012, ICV 015, ICV 033, ISX304, ISX314, ICC013, ICC012, ICC014, 1EF064, IVP082, IVP0( 1CC032, IVP254, ISX018, ICV 014, ICC107, ICC030 Motor Control Center 20E-1-46618 ISX046, ISX047, ICV 611, ICV 609, ICV 61 1AP21E t 1CV612, 1CS148, 1C5046, 1C 5094, 1C 51( 1C5047 20E-1-4661F 1SX218, ISX217, 1RH109, 1RH017, 1 RHO) 1RH108, 1RH068, 1RH069, 1RH067 l 1 II-27

          .                                                                                       TABLE II-4 (Continued)

CABLE TERMINATION INSPECTION SAMPLE Location Drawing No. Cable No. Motor Control Center 20E-1-464878 1AF039 1AP28E 20E-1-4687D ICC146, ICC041, ICC043, ISI201, 1SI203 20E-1-4687E IVX036, IVX038 20E-1-4687F 15I493, 151193, 15I194, 151195 20E-1-4687K IVA162, IWOO78, 1 WOO 80 i 20E-1-4687M 1SI173, ISI172, ISI175 I i i l l i I II-28

. TABLE II-5 INSTRUMENTATION INSPECTION SAMPLE Instruments: OPC-WOO 20 IFT-AF016 ILS-00036 1PT-934 IPT-935 1PT-936 1PT-937 Tubing Runs: OPC-WOO 20 34 feet 1FT-AF016 15 feet 1LS-D0036 6 feet Instrument Racks: IPL50J IPL56J IPL71J IPL75J Instrument Supports: H1012A-1 OPC-WOO 20-H220-1 OPC-WOO 20-H102A-2 OPC-WOO 20-H1358-3 OPC-WOO 20-H1358-4 1PT-935-H234A-1 IPT-936-H234A-1 1PT-937-H234A-1 1PT-934-H234-1 s II-29

  ,   III. MECHANICAL CONSTRUCTION A. Objective The ch > tive of the appraisal of mechanical construction was to deternino if installed and Quality Control (QC) accepted mechanical items conformed to engineering design, regulatory requirements and licensee commitments.

B. Discussion The specific areas of mechanical construction evaluated were piping, pipe supports / restraints, concrete expansion anchors, mechanical equipment, and heating, ventilating and air conditioning (HVAC) systems. To accomplish the above objective, a field inspection of a sample of QC accepted hardware was performed in each area. In addition, certain programs, procedures and documentation were reviewed as required to support or clarify hardware inspection findings.

1. piping

a. Inspection Scope ,

Piping depicted on the sixteen Phillips, Getschow Co. (PGCo) isometric drawings listed in Table III-1 was inspected by the NRC CAT. Approximately 350 feet of 2 inch diameter and smaller piping and approximately 700 feet of greater than 2 inch piping which had previously been accepted by PGCo QC was inspected. The inspection sample included piping located in both the auxiliary and containment buildings. Pipe sizes ranged from 3/4 to 10 inches and pipe classifications were ASME 1, 2, and 3. Attributes inspected - included configuration (i.e., component orientation and dimensions), component locations and types, and valve operator orientations. l Additional features such as support locations and types, maintenance of In-Service Inspection (ISI) clearance criteria and site construc-l tion practices were observed. l As is identified in Table III-1, four of the piping isometrics included in the NRC CAT inspection sample had previously been inspected by Commonwealth Edison Company's (Ceco) Braidwood Construction Assessment Program (BCAP) personnel. This small coincident sample permitted only a limited review of the SCAP i program. The following documents provided the acceptance criteria and background information for the NRC CAT inspection: PGCo Construction Procedure, PGCP-40, Rev. 3. " Verification, Preparation and Transmittal of As-constructed Drawings." PGCo Quality Control Procedure (QCP), QCP-821 Rev. 9

                            " Installation of ASME Section III and Safety-Related Process Piping Systees-2 Inch and Smaller."

( III-1 l l 1

1 , PGCo, QCP-828, Rev. 4, " Fabrication and Installation of ASME i III and Safety-Related Large Bore Process Piping Systems." Sergent & Lundy (S&L) Drawing M-919, Rev. P, Component Support , Installation Guidelines and Tolerances," Sheet 6. ! i * ' 4 S&L Drawing M-99 Rev. D, " Component Support Installation ' Guidelines and Tolerances," Sheet 6. S&L, " List of Lines That Will Undergo In-Service Inspection of Welds," J. review dated February 7,1984 and approved by S. Mattingly,

b. Inspection Findinos NRC CAT inspection observations associated with specific piping isometric drawings are listed in Table III-1.

Procedure PGCP-40 requires measurement and recording of linear dimensions within one eight inch by QC inspectors. Two design dimensions on Drawing 1A-SX-57 differed considerably from measurements by the NRC CAT inspector. Also, on Drawing 1A-AF-8, one difference between design and measured dimensions was detected. Numerical III-1. detail regarding these differences is included in Table by PGCo. NCRs regarding each of these dimensions were written - Although not insignificant, these differences appear to be isolated instances not indicative of the overall QC effort. For the coincident NRC CAT and BCAP piping inspection samples, two differences in findings were detected. piping included on Drawing 1A-AF-8. Both conditions are on In one case, the BCAP inspec-tion did not detect the 3-inch dimensional difference noted by the NRC CAT. In the other case, the BCAP reported a 10-inch dimen-sional difference from the floor at elevation 383' 0" to the top of the riser which penetrates that floor. The NRC CAT inspection l verified the original dimension to be correct within 0.5 inches. In 1983, the NRC identified a concern with possible piping clearance violations. The site has taken several actions to address this concern including revision of the piping "as-constructed" inspection procedures, an assessment of other contractor specifications and procedures and issuance of ECNs in September 1984 to provide installation criteria guidelines to other contractors. However, at the time of the NRC CAT inspection at Braidwood, most quality control and engineering procedures still did not include specific provisions for maintenance or verification of clearances between piping and other components / structures, including pipe to sleeve ; clearances. During the inspection, NRC CAT members observed many instances of less than 3-inch pipe-to pipe and pipe-to-structure clearances. Site personnel noted that upcoming revisions to pro-cedures would include provisions for minimum clearances. Currently a final walkdown of piping installation is planned which would identify clearance violations for resolution by analysis or rework. However, a draft copy of this procedure reviewed by the NRC CAT only required noting of direct contact with pipes in the hot position. III-2

l Although thermal clearance checks during final walkdown programs are ! - necessary, the NRC CAT notes that experience at other sites has demonstrated that system or area walkdown inspections have not

 '    proven to be reliable methods to resolve potentially unacceptable interferences. The NRC CAT considers that additional actions are needed on this matter.

Several instances of generally poor construction practices were observed during the inspection. A large temporary platform was found to be supported at one point by las inch diameter, Class 1 RC piping (line IRC22AC). Pipe design would obviously not account for a load of the magnitude possible in this case. The platform was subsequently removed from the pipe and a calculation was performed by S&L which concluded that allowable stresses had not been exceeded. Another scaffold was noted tied to Class 2 line ICS05A8. Other examples of inadequate mechanical equipment maintenance or protection were observed by the NRC CAT. In one instance, metal grating was found to be installed in such a manner as to bear against the hanger rod for the constant support spring hanger of support ICV 06009C. Other examples included grating stored against installed pipe and a snubber was left unattached at its rear bracket and hanging loose from the pipe it was apparently intended to restrain. In addition, several installed lines (2CV-218, 2A-RF-4) were observed to be uncapped (open to the atmosphere) by NRC CAT inspectors. A relatively large air operator is installed on valve 15I8880 located on 2-inch piping depicted on Drawing PG-2539A-29. The operator displaces significantly in response to very slight loading and is not restrained or otherwise protected from accidental loading by construction personnel or equipment. Several similar situations of large operators mounted on small bore piping were observed. Examples of such unrestrained, unprotected operators are those of valves 15188778, IRC8036C and ICV 8141C. Three of the four valves have permanent supports designed, however temporary supports should ! have been provided, as there is a concern,that an inadvertent bump of the operator could result in significant loading at the valve and adjacent piping. Drawing 1A-AF-8, Revision C incorrectly listad a Field Change Order, (FCO) 1AF-1213, as having been incorporated. This FC0 modified the first horizontal piping run downstream of pump 1AF01PA-1A. Discrepancies between the design drawing and the piping configuration resulting from this FC0 include an overall dimensional difference for the affected run of approximately 6 ! inches and several location differences for components within that pipe run. l l l Three pipe supports were observed during inspection of small bore I pipe line number IRC22AC depicted on Drawing PG-2542C-17. It was I determined during discussions with PGCo QC personnel that each of these supports had been accepted by QC in their then current locations. The subject pipe line is included on the S&L line list III-3 1

a I. referenced by PGCo QC for identification of pipe subject to ISI. i As such, included welds are subject to the 3 inch clearance required per l>999. One of these supports,1RC18030R, was located such that

    '                the support structure covered a pipe socket weld and in addition the sgport member intended to provide pipe-to-support contact was located 0.25 inches from the toe of the same weld. As a result of weldNec the        CAT observation, this restraint was relocated away from the in question.

! Plate used to shin another of these supports,

1RC18032X, overlapped the toe of an adjacent socket weld. The 4 third support,1R018031G, was located 1.25 inches from sn adjacent socket weld. During discussion with PGCo QC it was determined that

! QC personnel believed that socket welds do not require ISI. I Because socket welds require only a visual / surface ISI vs. i voltmetric) it is possible that the 3 inch clearance cr(iteria can be reduced for these welds. PGCo QC has issued a request for { clarification of the criteria to SM.. i inspection was performed on these supports / restraints.Regardless, a

c. Conclusions 1

Piping was found to generally conform to design documents. However, 3 sufficient discrepant conditions were found to warrant additional

management attention to QC design verification activities.

Communication between design, construction and QC organizations regarding criteria, such as necessary clarification of ISI clearance requirements, should be closely monitored by Ceco. The need for is tion practice increased apparent.licensee surveillance of contractor construc-The platform mounted on nuclear safety-related pipe and numerous instances of uncapped pipe and unprotected valve operators illustrate a greater incidence of poor construction practice than normally observed by the NRC CAT. The NRC CAT is concerned that reliance on a final walkdown of mechanical installations to identify pipe clearance violations is overly optimistic and could result in extensive inspection, analysis and rework very late in the construction schedule. '

2. Pipe Supports / Restraints

a. Inspection Scope Thirty-one ASME Class A, B and C and five Class D pipe supports /

restraints were selected for detailed inspection. These supports / restraints represented a variety of types, sizes, systems and , location. All had been inspected and accepted by the mechanical contractor, Phillips, Getschow Co. (PGCo). Six of the ASME supports / restraints had been inspected during the BCAP activities. These supports / restraints were inspected for configuration, clearances, member size, location, damage, weld size and proper fasteners. III-4

In addition, approximately 100 other sapports/ restraints were obse:ved at random in the field for obvious deficiencies such as lesse or missing fasteners, improper clearances or angularity, damage, etc. Desamientation packages consisting of Weld Data Travelers, Hanger Checklist Travelers and Stores Requests for nine ASME supports / restraints were also examined for completeness, accuracy and conformance to procedural requirements. See Table III-2 for a listing of the pipe support / restraint inspection samples. Acceptance criteria for these inspections were contained in the following documents: PGCo Quality Control Procedure (QCP)-823, Rev. 8

                                     " Installation and Inspection of Component Supports."

PGCo QCP-823A, Rev. O, " Supplemental Procedure for Handling and Installation of Component Support Speciality Items." PGCo Work Instruction PGWI-6, Rev. 1, " Implementation of Advanced Hanger ECN (AECN) Field Actions." Sargent & Lundy Engineers (S&L) Drawing M-919, Rev. P,

                                     " Component Support Installation Guidelines and Tolerances."

S&L Drawing M-999, Rev. D, " Component Support Installation Guidelines and Tolerances." (Superseded M-919 on August 13, 1984). Applicable design drawings and change documents,

b. Inspection Findings At the time of this inspection, approximately 80 percent of the approximately 13,160 ASME and Class 0 large bore supports /

restraints had been QC accepted. Approximately 42 percent of the approximately 16,300 ASME and Class D small bore supports / restraints had been QC accepted. The NRC CAT inspectors observed a large number of installation deficiencies on QC accepted supports / restraints. See Table III-3 for a listing of inspection observations. On the 36 supports / restreints in the primary sample, approximately 17 observation on 12 supports / restraints indicated conditions outside of allowable tolerances had been accepted by PGCo Production and QC personnel. These conditions included improper or undersized welds (4), wrong material installed (4), attachment locations out of tolerance (5) and excessive snubber to rear bracket angularity. In addition, one Class O support that had been " inspected" by Production personnel was found to have a smaller than specified strut installed. For Class D supports / restraints, (non-safety systems but installed in III-5

seismic buildings and thus near safety-related pipe / components) only attachment welds and concrete expansion anchor installations are inspect.ed by QC.

                                                   " inspected" by Production personnel.The remainder of the support fe I

Based on the observations of installed hardware, the NRC CAT inspectors considered that QC inspectors did not always have citar inspection / acceptance criteria. Several instances were noted where no visible clearance could be seen between piping and member of hox restraints, potentially causing an axial restraint where one had not been designed. . The M-999 drawing allowed a tolerance of minus 1/16 inch where a 1/16 inch gap was specified for box restraints and U-bolts, thus a bound condition could be accepted per the , tolerance drawing. i In another instance, the M-999 drawing specified in the General Notes that locknuts or jannuts are required for

threaded fasteners (as required by ASME Code), but then indicates that vendor's catalogues will be the governing document for minimum requirements. Vendor's catalogues do not usually reflect any lock / jam nuts or reflect compliance with specific ASME requirenerets. In another instance, Revision 8 to M-999 defines a " riser" for different pipe diameters with a plus or minus tolerance where only a minimum length should have been specified. See Section IV of this , i report for a discussion of acceptance criteria regarding skewed tee welds. l One large bore box restraint was noted to have a gap between the lower support member and pipe, thus not supporting the pipe for "supports. dead weight" loading and passing the loading to adjacent pipe The NRC CAT inspectors were infomed that this would be an inspection item in the system walkdown procedure (PGCP-48), but , a draft of this procedure reviewed by the inspectors did not address this ites.

Hardware inspections and the review of documentation packages

! indicated several cases where engineering reviews (and in some cases QC inspection effort) had baan inadequate. Several examples are as follows: t

(1) On 1C503025V, field engineers reported by Field Change Request
(FCR) that the clip angles that had been installed were larger than specified on drawing Revision "E". In fact the correct material had been installed per Revision E and accepted by QC.
However, in response to the FCR, Revision F was subsequently
issued to reflect larger clip angles. PGCo QC erroneously i updated the inspection checklist traveler, apparently without field verification, to reflect that the support was installed per the FCR.

Thus when inspected by the NRC CAT this support did not conform to the latest design documents. (2) For Class D support 1 WOO 2009X, work and QC acceptance was apparently perfomed to drawing Revision "C" and Field Problem I Report (FPR) C-289 that allowed deleting two beam stiffeners. However, ECN 12140, issued to incorporate the FPR, still showed the stiffeners installed. Revision D to the drawing also shows stiffeners installed. These stiffeners are not installed. i III-5 i

    .                            (3) For restraint ICS0450025, angle iron beam stiffeners have been removed by Field Change Orders (FCO's), but the latest support drawing revision ("D", issued 30/84) did not reflect removal of
                    .                       stiffeners and showed a one inch thick cover plate on the wrong         I side of beam. This installed and QC accepted support does not confom to the latest design documents.                                  <

, (4) For 1AB16018R, Advanced Engineering Change Notice (AECN) 15114 was issued in March 1984 to change the attachment location on a beam weld that had been incorrectly installed and accepted 5-3/8 inches beyond allowed tolerances in February 1984. No NCR requiredwasby written to document the out of tolerance condition as site procedures. See Section VII for a further discussion of design change control activities. Three QC accepted supports / restraints had been disassembled without i the required authority or documentation to assure that necessary reinspection were performed, Numerous instances of loose or missing ! fasteners were also observed. These examples indicate a need R r greater attention to the problem of altering completed and accepted

hardware.

Of the six supports / restraints that had undergone a previous { inspection by the BCAP program, two were found to be installed as t designed by both the NRC CAT and BCAP and one had deficiencies that

'                             were identified by both the NRC CAT and 8 CAP. Three of the supports / restraints were found to be installed with discrepent, conditions not identified by the BCAP inspection. On ISX06028R, BCAP did not note that the attachment to existing steel was approximately three inches out of tolerance. In addition, the 8 CAP inspection did not note that an undersize pipe clamp and load bolt had been installed on this support. The 8 CAP inspector did note on a material listing that the clamp was marked N3H rather than the 3HN marking indicated in the drawing Bill of Materials. It is doubtful if a review of this discrepancy in marking of the catalogue number would have revealed that a wrong size clamp nad been installed. On 1C5040025, beam stiffeners shown on the latest design drawing were not installed and a cover plate not shown on the drawing was installed. The BCaP inspector did note, in the remarks column of                      '

the inspection report, that he was unable to identify if the i stiffener was installed. This may have been identified as a problem during the BCAP engineering review of the inspection report. On IC5030295, the BCAP inspection did not note that the attachment location along the supplementary steel was out of i' tolerance by 21/2 inches and that four clip angles were smaller in size than specified on the drawing. Another condition noted during the hardware inspection was a large number of supports / restraints in contact or close proximity to pipe or other structures. Of special concern were several instances of snubbers binding against other structures (see Table III-3). See Section III.B.1 of the report for a further discussion of clearance violations. .i III-7 I

r The licensee stated that a number of future inspection / review programs are planned or being drafted that possibly could identify _

 ,                      the problems noted by the NRC CAT inspectors. However, the reliance

on system or area walkdowns performed at the end of the construction program to identify construction deficiencies is no substitute for ;

thorough and timely first line inspections. 1

c. Conclusions The number and type of discrepancies identified in installed ASME and Class D hardware indicates the QC/ Production inspection programs have not been effective in assuring that installed hardware conforms to design requirements.

Existence and clarity of inspection / acceptance criteria, drafting / i- document control / engineering review activities, general construction practices and timely development / implementation of clearance criteria are all issues requiring additional review and attention. Late construction walkdown programs should only be relied on as an extra level of quality verification and not a substitute for thorough and timely first_line inspection efforts. The accept-ability of previously accepted support / restraint work must be evaluated and final walkdowns addressing clearances and other features not previously verified must be extensive, thorough and closely managed.

3. Concrete Expansion Anchors for Pipe Supports / Restraints

a. Inspection Scope

! Forty eight concrete expansion anchors on 13 pipe supports / restraints were inspected for proper diameter, length (by UT and code stamping), spacing, edge distance, damage, washers and residual torque (an indication of anchor preload). The anchors inspected were selected on a variety of systems at random during a plant walkdown and ranged in diameter from 1/4 inch to 1 inch. Table III-4 provide a listing of the anchors inspected. Anchors were torqued to the 15 day-3 month test torque specified in site procedures (approximately 50-60 percent of installation torques). Acceptance criteria for these field inspections were contained in the following documents: Form BY/BR/CEA, Rev. 21, " Standard Specification for Concrete Expansion Anchor Work." PGCo. Construction Procedure PGCP-10, Rev. 16, " Installation of Wedge and Sleeve Type Concrete Expansion Anchors." Detail drawings for pipe supports / restraints. III-8

1. i 5

b. Inspection Findinos

\ The concrete expansion anchor program at Braidwood has recen! 4 undergone extensive review and various procedures were revised to 1 programsa more provide moreconsistent. complete QC inspection role and to make the various l The intent is to issue a generic site

procedure anchors identically. so that all contractors will be installing and inspecting ;

1 i ' Only 4 of the 48 anchors turned prior to reaching the test torque and all reached torque in less than one quarter turn of the nut. i Even considering that the test torques were relatively low, no , installation deficiency is indicated. ' All other characteristics examined identified and were either within tolerance or had been previously evaluated. i

c. Conclusion i

The concrete expansion anchors installed in pipe supports / restraints that were inspected by the NRC CAT were installed in accordance with design and procedural requirements.

4. Mechanical Equipment i

4

a. _ Inspection Scope 1

The following four items of mechanical equipment were inspected for proper orientation, support configuration and foundation bolting. Letdown Reheat Heat Exchanger, ICV 05A i *

Moderating Heat Exchanger, IBR01A i

Letdown Chiller Heat Exchanger, 18R03A i Recycle Evaporator, OA8010A 3 Installation documentation for this listed equipment was also examined. [ Acceptance criteria was provided by vendor technical manuals and drawings and site structural drawings.

b. Inspection Findings 4

In general, the mechanical equipment examined was installed in accordance with vendor and A/E requirements. A problem was noted i with apparently inadequate clearances for expansion on the sliding

and of the Moderating Heat Exchanger. Also, review of documentation i indicated thst all.. fasteners may have been torqued down at install-ation (in 1981-1982) including the sliding ends of heat exchangers.

PGCo procedure QCP B22 is not completely clear on the requirements and acceptance criteria for these characteristics. However, bot 1 of

;                              these concerns had been previously identified and were being evalu-ated by S&L on a generic basis.

i Installed and accepted equipment III-9

will require priate. reinspection and untorquing and retorquing as appro-

c. Conclusions
No apparent mechanical unidentified deficient installations were observed on equipment.

j j The acceptability and installation status of 1, mechanical equipment on site is indetarminate and adequate expansion clearance on heat exchangers. 1 i 5. l Heatino Ventilating and Air Conditioning (HVAC) l a. Inspection Scope l Fourteen one in-lineHVAC fan were Category inspected. I supports / restraints, one duct section, and The sample included five HVAC supports / restraints and one duct section inspected by BCAP. See Table inspected III-5bfor listing and observations of the HVAC hardware i auxiliary, y the NRC CAT. HVAC supports were examined in the reactor, diesel generator, and control buildings.

!                                              Features examined were location, configuration, member connection details and support to duct connection details. The seismically i                                              supported duct runs were not completely erected and/or QC accepted j                                               limiting the NRC CAT inspection sample. Safety related equipner

installed by Pullman Sheet Metal Works Incorporated (PSM) had a i "stop per NCR work BR-254. order" in effect addressing installation and inspection i Only approximately 10 percent of the safety-related

! equipment had been QC inspected. QC inspectors and BCAP personnel , i were interviewed regarding their knowledge of requirements and their responsibilities.

The following documents provided the acceptance criteria for the

< inspection of HVAC hardware installations. Sargent and Lundy Engineers (S&L) Specification L-2782 for HVAC Work s i L rawi 61, " Safety-Related HVAC Hanger Details," i S&L " Safety-Related HVAC Hanger List" ', "Pullman Installation Sheet Metal Works Inspection Inc. (PSM) Procedure B10.3F, Rev. 6, Procedure" { Commonwealth Edison Company (Ceco), NCR No. 349, "Nonconfor-mance Report for Construction and Test", Ref: Weld Detail on S&L DWG M-1261-1 PSM " Duct Brochure", Rev. F i Ceco NCR No. 460 Rev. O and Rev.1, Ref: Safety-Related HVAC j Hangers, Braces, Aux. Steel and All Safety-Related Details and Connections

III-10 I

PSM NCR BR 254, Ref: "stop-work order" Addressing Installation and Inspection of HVAC Equipment

           ,                                               Applicable Duct Support / Restraint and Layout Drawings

b. Inspection Findings Approximately 25 percent of the Category I supports had been QC '

accepted by PSM and approximately 65 percent of BCAP's HVAC support reinspection program was completed. In addition to the equipment "stop-work-order" currently in force, problems were identified in 1982 and 1983 requiring extensive program changes, reinspection, reanalysis and rework for duct welding, duct fabrication and support / restraint installation deficiencies. Although numerous minor dimensional discrepancies were observed by the NRC CAT, no major installation deficiencies involving location, geometry and member size were identified. In the area of welding and connection details of the HVAC supports the NRC CAT identified missing welds, undersize welds and at the support to duct connection " blow holes" in the duct sheet metal were identified. See Section IV of the report for farther discussion of HVAC welding findings. The NRC CAT inspection findings of the five BCAP HVAC support / restraint samples and duct section #4430 were similar to BCAP's findings. i The NRC CAT inspected one sample of safety-relateo equipment, an in-line fan (1V08CA) and its support (#3763) as the remaining seven equipment samples were partly or not installed. No deficiencies were noted on the in-line fan. However, for the fan support the following observations were made (1) bolt detail for fan to support attachment not shown or referenced on fan support drawing #M-1315 , Rev. H, i.e., bolts welded to frame steel with no weld symbol, (2) two of four diagnal braces were not detailed on fan support drawing, nor noted in the PSM QC inspection report. Nonconformance Report BR-254 and the "stop-work-order" (BR-84-221) concerning the lack of adequate installation and inspection criteria and documentation for HVAC equipment were reviewed. The NCR dis-position indicates that corrective action will be directed at a review, statusing and necessary reinspection of installed equip-ment for vendor requirements only. The NRC CAT notes that a thorough evaluation and/or reinspection of previously accepted items for all attributes appears warranted. This conclusion is 4 based on the problem description in the stop-work-order, the exten-sive construction and inspection problems in other HVAC hardware (duct and supports) and the observations made by the NRC CAT. The NRC CAT inspectors found the QC inspectors and BCAP personnel to be knowledgeable of requirements and their responsibilities in the area of HVAC.

c. Conclusions HVAC safety-related support / restraints generally conformed to design and procedural requirements. Conclusions cannot be made on HVAC duct runs and safety-related equipment because III-11

of the limited sample available and indeterminant hardware status.

Additional evaluation of the corrective action regarding the HVAC equipment stop-work-order is necessary. l 4 l III-12

i TABLE III-1 l PIPING INSPECTION SAMPLE Small Bore Pipe (2 Inch Diameter or Less)

No. of Support Isometric Diameter Locations (Note 1) (Inches) Class Checked Notes Observations 2539A-29, 3/4, 1, 2 B, C 6 - Large unstable valve Rev. C operator is not sup-ported or otherwise protected 2539A-31, 3/4 8 7 - Rev. A 2539C-82, 3/4 8 2 2 Rev. C 2541A-4, 2 C 3 - Rev. C 2541A-7, 2 C 5 - Rev. C 2542C-17, 1 1/2 A Rev. B 3 3 3 Support to weld ISI clearance violations Platform mounted on pipe elbow 2545A-100, 1 1/2 C 0 4 Rev. B 2546C-15, 3/4 A, 8 0 - Rev. 0 2546C-16, 3/4 A 0 - Rev. C 2549A-75, 2 C 0 4 Rev. A III-13

TABLE III-1 (Continued)

PIPING INSPECTION SAMPLE Laree Bore Pipe (Greater Than 2 Inch Diameter) No. of Support Isometric Diameter Locations (Note 1) (Inches) Class Checked Notes Observations lA-AF-8, 6 C 9 2 FC0 1AF-1213 incor-Rev. C rectly listed as incorporated

3'5%" design dimen-sion measures 3'2" ;

1A-AF-33, 3 C 1 1 Rev. A Continuation iso-metric sheet - are switched :.4 . branch connections 1A-CV-3, 8,6,4 8 10 3 Rev. B 1A-CV-3A, a B 8 2 , Rev. A IC-SI-8, 6, 10 A, B 0 2, 3 Rev. 0 1A-SX-57, 3,4,6 C 14 Rev. O 3'2" design dimen-

sion measures 3'6" 2'5" 1/8" design dime i sion measures 3'11" Notes: 1. Letter designations 'A' and 'C' of isometric drawing numbers identify pipe locatior, as auxiliary and containment buildings respectively.; 2. This isometric is included in BCAP piping inspection scope.; 3. This isometric includes piping subject to ISI.

i 4. QC inspection including "as-contructed" dimensional checking for this piping is in accordance with QC Procedure B21. i III-14

                                                                                                                             - - - - . . . . . - . . . . . - . _ , , , . . _.,~, _ __.

TABLE III-2 ~ PIPE SUPPORT / RESTRAINT INSPECTION SAMPLES Size QC S/R Number Class Inspection (Inches) Tyge Location _ Oate 1A807001R C 4 Strut Auxiliary 09/84 1A811019R C 3 Box Auxiliary 10/84 1A812003G C 4 Box Auxiliary 11/84 1AB16018R C 3 Strut Auxiliary 03/84 1AB21035X C 4 Box Auxiliary 11/84 ISXO3005R C 20 Rod Auxiliary 03/84 ISXO6001R B 16 Strut Auxiliary 05/83 ISX07008R B 14 Strut Reactor 04/84 ISXO90385 B 10 Snubber Reactor 07/84 1CC03067R C 14 Box Auxiliary 02/84 1CC03074V C 12 Spring Auxiliary 05/83 1CC04001X C 6 Strut Auxiliary 04/83 1CC10008V C 4 Spring Auxiliary 04/83 1CC13037R C 16 Strut Auxiliary 04/83 1RC01004V A 8 Spring Reactor 01/85 1RC10032S A 3 Snubber Reactor 08/84 1RC11093R A 3 Box Reactor 11/84 1RC100345* A 3 Snubber Reactor 05/84 1RC01007S A 8 Snubber Reactor 01/84 15I01025S C 8 Snubber Reactor 04/84 15103046S A 6 Strut Reactor 05/84 1S101032S B 10 Snubber Reactor 07/84 III-15

TABLE III-2 (Continued) PIPE SUPPOR1/ RESTRAINT INSPECTION SAMPLES Size QC S/R Number Class Inspection (Inches) Type Location Date ISIO403G B 10 Strut Auxiliary 09/84 ISI14027A B 3/4 Anchor Reactor 11/84 1RH020075 A 12 Snubber Reactor -- 1RH02029R B 12 Strut Reactor 05/84 ISX07007X* B 4 Strut Reactor 03/83 1CS03029V" B 6 Spring Auxiliary 11/82 1CC200125 8 4 Snubber Reactor 05/84 ISX06028R* C 10 Strut Reactor 05/83 1C5040025* B 10 Snubber Reactor 02/84 1 WOO 10255 0 10 Strut Reactor 07/83 IWOO2009X D 8 Rigid Reactor 03/83 1FC99004X 0 4 Strut Reactor 08/83 1CC39051X D 4 Strut Reactor 02/84 1 WOO 1001R D 10 Rod Reactor 01/83

Supports / Restraints that had also been inspected by BCAP program.

Document Packages Reviewed 1A816018R 1RC100345 1SX06001R ISX03005R 151010255 15I030465 1AB21035G 1RC10032S 1SX07008R III-16

TABLE III-3 PIPE SUPPORT / RESTRAINT INSPECTION OBSERVATIONS Primary Sample Support / Restraint Observation (PGCo NCR Issued) 1AB07001R Adjacent pipe cut and removed program did not require reinspection of previously accepted S/R for location or angularity. 1A812003G Missing locknut. Attachment welds not full penetration as specified (NCR 2947). ISX03005R Undersized pipe clamp installed (NCR 2964 One inch clearance to ten inch SX pipe. ISX06001R Attachment location exceeds tolerance by 1/2". Orientation dimensions reversed (NCR 3151). 3/4 inch clearance to slectrical conduits. ISX09038S Underfilled flare bevel weld and missing return welds where specified (NCR 2976). ICC03074V Beam attachment location on embed exceeds tolerance (NCR 3308). IRC01004V 3/4 inch beam attachment installed, 1/2 inch specified-not allowed by N-999 l (NCR 3310). l 1RC10032S t Snubber disconnected without authorizatio. documentation (NCR 2909). 1RC010075 Snubber to end bracket angularity of 7 degrees exceeds vendor specified maximum of 5 degrees. 1RH02029R Location on embed exceeds tolerance by 5/: inch. Mislocated welds result in less than desit weld length (NCR 3053). 1CS03029V Location along supplementary steel exceeds tolerance by 2 inch. Undersized clip angles installed.

III-17

1

TA8LE III-3 (Continued)

PIPE SUPPORT / RESTRAINT, INSPECTION OBSERVATIONS Primary Sample Support / Restraint 4 Observation (PGCo NCR Issued) ICC20012S Damaged snubber extension piece paddle. ISX06028R Disassembled without authorization / documentation. Attachment location to be exceeds tolerance by 3 inches.

Unspread cotter pins.

Undersized pipe clamp and load pin installed (NCR 3385) ICSO4002S j Loose fasteners. Drafting / engineering error. 1 WOO 2009X Stiffeners shown on drawing not installed i ICC39051X Undersized strut installed. 1A821035X Zero clearance to strut ISX17034X. ICC04001X 3/4 inch clearance to strut ICC04036R. Adjacent Sample 1SX09001R Drawing specified return welds missing. 1A821008X Box guide with no visible pipe to support clearance (NCR 3313). i 1FWO4018X j Verticle restraint with no visible pipe to support clearance (NCR 3391). ICS03084X Gap (0.090 inch) under 8 inch pipe c-weight box support. IRC100325 Disassembled without authorization / documentation (NCR 2909). ISXO3004X Loose pipe clamp fasteners. 1A811020X Load pin cotter severed and pin almost disengaged. 1A811090X Loose strut locknut. 1RC01006S Snubber tube in contact with whip restraint. III-18

l TABLE III-3 (Continued) PIPE SUPPORT / RESTRAINT INSPECTION OBSERVATIONS Primary Sample i Support / Restraint Observation (PGCo NCR Issued) ICV 02004S Snubber binding against wall. 2FWO6014S Snubber binding on structural steel. l III-19 4

1 TABLE III-4 CONCRETE EXPANSION ANCHOR INSPECTION SAMPLE Pipe Support Drawing Number-Diameter (Inches) of Anchors Inspected 1WO34009X 4-3/4 1 1WO34007X 4-3/4 1WDF49005T 1-1 3-3/4 2FP03049X 5-1/4 2FP03009X 4-1/2 1BR1001X 3-1 1BR10029X 4-1/2 IBR3101R 4-3/4 1BR31009X 4-1/2 IWX65B006T 4-1 IWE068040T 4-1/2 1WO37006A 4-1 4 l l l III-20

TABLE III-5

HVAC INSPECTION SAMPLES AND OBSERVATIONS o Supports / Restraints BCAP S&L Restraint Selection Merk Number Number Buildine Observations

5-2169 M-1323-7 CSR-I-H-03-43 Auxiliary Missing welds on lower stiffener plate to vertical member; material reduction on top of horizontal member 1 greater than 1/16";

auxiliary steel inacces- t sible not inspected. S-2164 M-1323-7 CSR-I-H-03-42 Auxiliary

Auxiliary steel inacces-sible not inspected.

5-160 M-1310-2 CSR-I-H-03-06 Auxiliary Diagonal brace edge dis-tance 5/32". 3/16" minimum

                                                                                                                                   .equired.

S-2008 M-1274-2 CSR-I-H-03-053 Reactor Duct dented, and water Containment inside duct run, S-3281 M-1326-5 CSR-I-H-03-52 Control i i Overlap dimension of i support leg to auxiliary

is 2" vs. 2 " overlap required.

4 S-1309 M-1283- CSR-I-H-03-022 Diesel No findings on support frame, Generator auxiliary steel not inspected. (Support had not yet been inspected by BCAP) S-42 M-1309-6 N/A Auxiliary ! Undersize welds on frame vertical member to attach-ment plate at four places. S-043 M-1309-6 N/A Auxiliary None S-1041 M-1313-01 N/A Auxiliary None S-196 H-1310-04 N/A Auxiliary 3/8" actual edge distance of horizontal member of vertical member vs.1/4" edge distance allowed. i I III-21 l l. rW gu y -w,-'-e --e,no. -- - - wrr---o-, w--,-e,, -----,--u,--- - - --- w-a +--eeem-g,-.e--mWe a y-,----m-w-w9,w--w -e

TABLE III-5 (Continued) HVAC INSPECTION SAMPLES AND 08SERVATIONS Supports / Restraints BCAP S&L Restrain

Selection Mark Number Number Building Observations S-010 M-1309-5 N/A Auxiliary Two ' blow holes' in bottom of duct sheet metal at support to duct attachment, warped and dented duct, missing welds vertical members to top horizontal member.

S-3282 M-1326-5 N/A Control Support vertical legs incorrectly numbered on FEM 241A and FCR 12187, upper diagnal attachment to wrong leg, duct to leg No. 1 (dimen.) out of tolerance, dimension of 1 " between bottom of diagonal member to hori-zontal member exceeds maximum required dimensaw. of 1", gusset plate and weld undersize more than 10%. S-90 M-1309-9 N/A , Auxiliary None S-135 M-1310-2 N/A Auxiliary Temporary pipe support for 3/4" pipe attached to duct support, 2" end weld at duct to support attachment is 1 1/8" from corner rather than 1/2" maximum allowed. 1 i l l l III-22 i l __ _ - - _ _ . - - - . - - - - - - - - - - ~ ~ - ~ ~ ~ ' ~ ~ ~ ~

TABLE III-5 (Continued) HVAC INSPECTION SAMPLES AND OBSERVAT ONS HVAC Duct Sections and Safety-Related Equipment BCAP S&L Duct Selection Section Number Number Building Observations 4430 ft 1323-2 CSR-I-H-01-046 Control None 8 CAP ' S&L Safety-Related Selection Equipment Number Number Buildinc Observations IVA08CA & N/A Auxiliary (Fan Suport For fan: None

                           #3763)

For fan support: detail for fan to support attachment not shown or referenced on drawing, i.e., bolts welded to frame - no weld symbol, two of four diagonal braces not detailed on drawing nor noted in PSM QC inspection report. i i i I l III-23 1

IV. WELOING AND NONDESTRUCTIVE EXAMINATION (NDE) A. Ob.iective The objective of the appraisal of welding and nondestructive examinetton (EE) was to determine if Quality Control (QC) accepted work related to welding and NDE activities was controlled and performed in accordance with design requirements, Safety Analysis Report (SAR) commitments, and applicable codes and specifications. ' An additional objective was to determine if personnel involved in welding and NDE activities were trained and qualified in accordance with established performance standards and applicable code requirecents. ! B. Discussion To accomplish the above objectives, welds and welding details for piping, pipe supports / restraints, field and shop fabricated tanks, structural steel installations, heating, ventilation and air conditioning (HVAC) installations, electrical supports, and instrumentation and control tubing were inspected. The inspected welds were selected to provide a representative sample of the applicant's contractor welding activities in terms of welding processes used, materials welded and existing weld-joint configur-ations. Considerations such as physical location, difficulty of welding and limited accessibility were also used in sample selection. NDE activities were appraised through the review of radiographs for i both field and vendor fabricated welds, the review of NDE procedures ! and personnel qualifications, the inspection of the calibration status of NDE equipment and the witnessing of in process NDE activities. The ! NRC Construction Appraisal Team (CAT) inspectors reviewed samples of radiographic film in final storage in the vault at the licensee's facility. In addition, a sample of film which was stored at the

Westinghouse storage facility was also brought to the site for review.

} During the inspection of welds on pipe supports / restraints, the NRC CAT identified welds which did not have the weld size specified by the Architect Engineer, Sargent & Lundy (S&L). Undersized welds were found

 '                on both skewed and non-skewed connections on pipe supports. S&L has 1                  evaluated for adequate      most theofintended the undersized       welds and determined that the welds are application.

Undersized weld reinforcements were also found in nozzle to shell joints (ASME Code category 0 joints) on tanks and heat exchangers. A detailed discussion concerning these I

welds is included later in this section. The licensee has undertaken a program of inspections and reviews intended to perform an overall assessment of the Braidwood Station. The Braidwood Construction Assessment Program (BCAP) was sat up to include inspections of welds in all of the major areas of plant con-struction such as electrical, piping, instrumentation, HVAC and structural steel construction. During the time of the NRC CAT 1 inspection, the BCAP had completed only the HVAC weld inspection. The NRC CAT inspectors inspected three HVAC supports which were inspected previously by the BCAP team in order to assess the adequacy of their IV-1

h inspection. ' In essence, the BCAP observations were identical with the NRC CAT findings which tends to indicate that the BCAP was effective identifying weld deficiencies in the HVAC area. ; i In the area of NDE, the review of the licensee's Quality Assurance l i procedure SQI #20 revealed that the project reviews 10 percent of the radiographs transmitted to Quality Assurance from on and off site vendors and contractors. However, the QA review is not intended as an independent interpretation of radiographs and is confined to a paper ! review of the associated NDE documentation. The team believes that i thistheir to apparent 5tortet:lack of independent interpretation of radiographs prior inability te ider tify questionable or deficient radiograph j review of radiographs supplied by various vendors and contractors, the NRC required CAT found weld radiographs which showed that some welds did not hav quality. i their associated deficiencies are provided later in this sect The welding and NDE activities were examined in order to ascertain compliance with the governing construction codes and specifications. This effort involved the review and inspection of the following contractors: Field Fabrication

1. Sargent & Lundy Engineers: Architect Engineer.; 2. Phillips, Getschow Company (PGCo):
supports /restriants, instrumentation installation and instrume

! tion supports, fire protection fabrication and installation. i 3. Chicago Bridge and Iron Company (C8&I): containment liner and i containment penetration fabrication and installation, tank fabricator.

4. Pittsburgh-Des Moines Corporation (PDM):

fuel pool liner fabrication and installation, tank fabricator. reactor pool an

5. L.K. Comstock and Co., Incorporated (LKC):

4 and electrical supports electrical installations

6. Pullman Sheet Metal Works, Inc. (PSM): heating ventilation and air conditioning (HVAC).

7. Gust K. Newberg Construction Company (GKN):

installation structural steel

8. American Bridge Company (A8):

suppliers. structural steel erectors and

9. Napoleon Steel Contractors, Incorporated: i structural steel installation

10. Mid-City Steel Company:

!                                                                                                               structural steel installation i

i IV-2

                                                                                                                                                                                        \
  . . _     _ _ . , ~ , , _ _ _ . . _ . . _ _ _ _ _ , _ , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

i 1 2

11. Nuclear Installation Services Company (NISCO): reactor internals installation.

Shop Fabrication ! 1. Southwest Fabricating & Welding Company, Inc.: shop fabricated piping spools.

2. Harnischfeger Corporation: crane manufacturer

3. Westinghouse Electric Corporation: nuclear steam supply system i

4. Anchor / Darling Valve Company: valve manufacturer

5. Graver Company: tank fabricator

6. Carrier Corporation: chillers and coolers manufacturer

7. Gulf & Western Corporation: containment spray eductors supplier

8. Cooper Energy Services: tank fabricator

9. Control Components, Incorporated: valve manufacturer

10. Dresser Industries, Incorporated: valve manufacturer

11. Unitech Division of Ecodyne: radwaste evaporators suppliers

12. Atwood and Morrill Co., Incorporated: valve manufacturer

13. L A/ Water Treatment Corporation: feedwater heater manufacturer

14. W.K.M.: valve manufacturer

15. Yuba Heat Transfer Corporation: high pressure heater manufacturer

16. Aerojet-General Corporation: volume reduction system supplier

17. McQuay-Perfax: steam generator blowdown condenser fabricator

18. ITT Grinnell Corporation: pipe hangers supplier

19. Cleaver Brooks: heating boilers manufacturer

20. TRW Missions: valve manufacturer

21. Teledyne Brown Engineering: NSSS support steel supplier

22. Borg-Warner Fluid Controls: valve manufacturer

23. Continental Boiler Works: tank fabricator, miscellaneous stack and platework supplier

24. Rockwell International: hydrogen recombiner manufacturer IV-3

l

       .                                                                                                 l

25. Greer Hydraulics:

pulsation dampeners supplier

26. W.J. Woolley Company:

supplier containment vessel hatches fabricator and

27. Jamesbury Corporation:

valve manufacturer

28. Atlas Industrial Manufacturing Company:

heat exchanger manufacturer

29. Bingham-Willamette: pump manufacturer

30. Joseph Oat Corporation:

heat exchanger aa.1ufacturer 31.1.anco Industries, Incorporated: tank fabricator The results of the inspection activities involving each of these areas and contractors are documented as fellows:

1. Pipe and Pipe Support Fabrication

a. Inspection Scope (1) Welding Activities The NRC CAT inspectors reviewed activities relating to fabrication contracts in the areas of piping system welds, support / restraint welds, welding procedures, welder qual tions, NDE procedures, personnel qualifications, and the

of radiographic film for shop and field fabricated welds. . . . . . . Field welding involving pipe fabrication was perfonned by Philips, Getschow Company (PGCo). Welding supplied the shop fabricated pipirig spools. Southwest The NRC CAT inspected 44 pipe supports / restraints involving l approximately 700 welds in order to verify conformance of l welding to drawing requirements and canfirm the visual acceptability of the welds. supports subjected to detailed inspection.See Table IV-1 for a listin Additionally, another 18 supports / restraints involving 350 welds were also visually inspected to verify the quality of the completed welds. The welds on the Unit 1 pressurizer lower ring girder and upper guides were also included in this inspection. See Table IV-2 for a listing of supports inspected. The NRC CAT inspection of piping welds consisted of visual inspection during walkdown of piping systems and inspection of pipe welds located near the supports / restraints being inspectcd. Class 1, 2 and 3 welds were inspected.Approximately 47 pip Twenty of those piping spools were subjected to detailed inspection which included the review of pertinent QC documentation while the remaining 27 spools were only visually inspected. Both field and shop welds were inspected in order to assure compliance with the require-ments of the ASME Code. Some of the surfaces of the inspected welds were blended for inservice inspection. See Tables IV-3 IV-4

and IV-4 for listings of piping. spools inspected. In addition, 50 welding filler metal test reports,19 welder qualification test records and 5 welding procedures were reviewed for compliance with applicable specifications, procedures and the ASME Code requirements. (2) Nondestructive Examination Activities The NRC CAT inspection of NDE activities for the pipe fabrication area included the review of 104 shop and 86 field fabricated welds which involved 2326 film. The field welds were fabricated by PGCo and the shop fabricated pipe spools were supplied by Southwest Fabricating and Welding. In addition 6 NDE procedures and 7 NDE personnel qualification records were reviewed in order to verify compliance with the governing codes and specifications. Five NDE technicians were observed while performing in process inspections and i were evaluated inspection procedures. for their ability to follow the applicable Ten pieces of NDE equipment were inspected for calibration and one quality assurance NDE procedure was reviewed for adequacy.

b. Inspection Findings

!                                         (1) Welding Activities i

l In general, the inspected pipe and pipe supports /retraints welding activities were found to comply with the governing codes and specifications. However, discrepancies were identified involving undersized welds in both skewed and non-skewed welded connections. Fifty-two of 1050 structural welds inspected, I l involving 62 pipe supports / restraints, were found to be defi- ! cient with respect to the specified acceptance criteria. i Thirty-three of the welds were undersized, three welds were short on length, eleven flair and full penetration welds were underfilled, one support had an extra load-bearing plate welded and 4 welds were completely missing. See Table IV-1 for details. As a result of this finding the licensee issued NCRs and most of the welds were determined to be adequate for the intended application. Eight of the 1400 pipe welds inspected were found to deviate l from the specified acceptance criteria. As a result of these findings, the licensee issued NCRs and the welds will he evaluated and dispositioned by S&L. The welds, and their associated deficiencies are listed as follows:

1) PG-25-52C, FW 2 had excessively convex bead shape (NCR 3009).

2) RH-7-5 had weave width which exceeded that permitted by applicable WPS (NCR 3271).

IV-5

     ;                                              3) 1-SI-RPP-1-FW1 and 1-SI-RPP-2-FW1 exhibited excess c height, surface porosity, lack of fusion, poor bead shape and arc strikes (NCR 2935) 4)

Containment Sump A in Unit 1 exhibited arc strikes (NCR , 3257).

5) RH-12-11 (12" Schedule 40 pipe) had been ground heavily in an area that would not normally be ground. PGCo could not show that this work was authorized or controlled, specu-lating that it was repair of an arc strike. A subsequent thickness thickness (NCR check showed the area to be under minimum wa 3309).

6) A small diameter drain line under one Fuel Pool Cooling HeattoExchanger due being walked wason.observed to have been bent, probably Subsequent reinspection showed that it had been straightened. PGCo could not show that the repair had been authorized or controlled. Monitor Report 6308 was written, resulting in Letter 8-8-693 requiring training sessions for all construction personnel performing the regarding work.need to have appropriate controls prior to

7) The end preparation on 1-D0-46 was found to be out of l conformance with fit-up requirements after fit-up inspection (NCR 3100)

Two of the 50 welding filler metal test reports reviewed were found to be deficient with respect to the applicable requi"e-ments. l One test report was found to be incomplete, in that the ! lateral expansion values for impact testing was not reported ' (NCR 3390). In addition, the purchasing specification for E7018 welding electrodes was found to not meet the requirements i of ASME Section III for impact testing. NCR~3389 was generated l to correct the specific purchasing specification. (2) Nondestructive Examination Activities In general, the inspected NOE activities were found to comply with the applicable codes and specifications. However, during the review of the radiographic film several irregularities were identified which involved the following 12 welds: Field Welds SI-7-FW58 and FW-1-9-W100

The radiographs for these welds were found to have film densities above 4.0. When a high intensity viewer was used, i the weld quality was found to be acceptable.

Field welds AF-13-FW6 and ISI-RPP-2-FW1 These two welds were identified as having unacceptable weld quality. Weld AF-13-FW6 had porosity in excess of ' code and weld ISI-RPP-2-FW1 had incomplete fusion. As a IV-6

result of this finding, the licensee issued NCR 214 and NCR 215 and the welds are scheduled to be repaired.

             .                                 Field Welds AF13-FW17 and FW51-FW11                       l 1

Those two welds were identified as having questionable indications. After the welds were reradiographed, these indications were determined to be film artifacts and the weld quality was determined to be acceptabic. Field Weld RH-7-FW1 The reader sheet for this weld indicated that the weld was rejected by the original interpreter. The review of existing film could not establish whether the present status of the weld was acceptable or rejectable. The weld was reradiographed and the final radiographs revealed that a proper repair had been accomplished. The weld quality was determined to be acceptable. Shop welds SX-36-1-SW3 and SX-36-1-SW4 These two welds had two identical radiographs. Both welds were raradiographed to determine which weld had been radiographed two times with different weld identification. The final radiographs indicated that the weld quality for the two welds were acceptable. Shop Weld FW-2-6-W4 This weld had incomplete coverage between stations 22 and

25. A linear indication could not be evaluated because the penetraneter was placed in the area of interest at stations 7 to 9. Several areas had lead numbers placed in the weld area which also prevented the proper inter-pretation of the area of interest. The weld was reradio-graphed and the weld quality was found to be acceptable.

Shop Weld RH-12-7-W4 The original radiograph for this weld showed a questionable linear indication in one of the weld areas. The weld was raradiographed and liquid penetrant examined after which the indication was determined to be an acceptable surface condition. Shop Weld SI-43-1-W4 4 4 The original radiographs for this weld showed an unaccept-able linear indication. Subsequent reradiographs and visual examination revealed a sharp valley on the internal weld surfaces. The indication was photographed and the pictures were used to aid the radiographic interpretation process. The quality of the weld was determined to be acceptable. IV-7

        '                                                         The review of the project quality assurance procedures SQI
                                                                  #20 revealed that the project does not perform independent interpretation of radiographs prior to their storage in the vault. The procedure requires 10 percent review of NDE documentation and is not intended to review radiographs.

c. Conclusions

1. Weldina Activities In general, the inspected welding activities were found to comply with the requirements of the applicable codes and specifications. However, the NRC CAT found structural welds on pipe supports / restraints which did not meet the weld specifi-cations. Most of these supports were evaluated by the Archi-tect Engineer and determined to be adequate for the intended application. The project had also instituted the BCAP program which is intended to assess the welding worlunanship. Our review uf BCAP inspections in the HVAC area tend to indicate that the program is effective in identifying weld deficiencies.

Nevertheless, the NRC CAT identified undersized welds which

showed that the original weld inspection of the supports was not effective in the identification of weld deficiencies. This indicates a program weakness in this area.: 2. Nondestructive Examination In general, the inspected NDE activities were found to comply with the requirements of the governing codes and specifica-tions. However, the NRC CAT found welds which did not have the '

required weld quality. The review of the licensee's quality assurance procedure SQI #20 revealed that the project reviewed 10 percent of the radiographs transmitted to quality assurance for final storage in the vault. The review was not intended to be an independent interpretation of radiographs and was confined to the review of NDE documentation. The NRC CAT believes that this lack of independent interpretation of radiographs has contributed to the licensee's inability to identify deficient radiographs.

2. Reactor Internals Installation

a. Inspection Scope Approximately 25 tack welds on the upper and lower reactor internals locking caps were inspected. In addition, the welds on the upper internals tubing clamps and the welds on the energy absorbers for the lower internals were also inspected. The

' documentation packages for three welds were reviewed to determine compliance with the applicable code requirements. One welding procedure and 7 welder qualification test records were also reviewed for adequacy. The reactor internals installation was performed by NISCO.

!                                                                                IV-8

l ] .t

b. Inspection Findings and Conclusions

, No problems were identified in the area of inspected welding acti-vities. l criteria. Activities were found to meet the specified acceptance 1

3. Electrical Installation and Electrical Supports i

a. Inspection Scope

! The NRC CAT inspected approximately 100 field and 50 shop welds in the area of electrical installation. Three welding procedures and

the qualification test records for 10 welders were reviewed. Two

' studs were torque tested to verify the adequacy of the stud welding procedure. In addition, the personnel qualification test records for two welding inspectors were also reviewed and two inspectors

were observed inspection and evaluated for their ability to follow the visual procedures.

j The welding activities in the electrical area were performed by LKC.

b. Inspection Findings i,

Five of the 150 inspected welds were found to be deficient with l respect to the specified acceptance criteria. One weld was under-i sized and four welds had longer lengths across the baan flange j than those specified by the Architect Engineer. As a result of

this finding, the licensee issued NCR's and the welds were evaluated by S&L.

be adequate for the intended application.The welds were accept t 1

c. Conclusions No significant welding problems were identified in the area of inspected activities.

With the exception of the minor finding 4 previously discussed, the inspected welding activities were found to comply with the applicable construction codes arid specifications. 4. Instrumentation Tubina Installation and Instrumentation Supports

a. Inspection Scope t

i t Approximately 170 welds involving 25 instrumentation supports, 5 i panels, and 60 tubing welds were visually inspected to ascartain 1 compliance with the specified acceptance criteria. Three welding procedures and qualification test records for six welders were reviewed. NDE procedures and qualification records for three NDE l inspectors were also reviewed. Two visual welding inspectors and 1 one liquid penetrant inspector were observed and evaluated for l their ability to follow the applicable inspection procedures. The welding in the instrumentation area was performed by PGCo. i J i IV-9

b. Inspection Findings During the time of this inspection, instrumentation construction activities were suspended by the applicant as a part of an effort ,

1

                          'te evaluate and correct deficiencies that existed in this area.                   I The NRC CAT inspected the sample of welds to determine whether a major problem existed in the areas of welding and NDE. No signi-ficant problems were identified in these areas. However, instru-mentation specified weld   racks were found to have welds which did not have the size.

In addition, the welds on two skewed instru-mentation supports were found to be undersized. As a result of j these findings, the licensee issued NCRs and these items will be ; activities. during the restart of the instrumentation construction addressed

c. Conclusions No significant welding and NDEproblems were identified in the area of inspected activities. With the exception of the items previously discussed, activities were found to comply with the applicable construction codes and specifications.

5. Heatina, Ventilatina and Air Conditionina, Installation and Supports

a. Inspection Scope Approximately 140 welds involving 23 supports were inspected for compliance with the specified acceptance criteria. Six weldi.

procedures and the qualification test records for 10 welders were reviewed. In aadition, four personnel qualification test records i were also reviewed and two welding inspectors were observed and

evaluated for their ability to follow the visual inspection procedures.

i The vendor welds on four duct pieces and two air blowers were also included in this inspection. Three BCAP inspected supports involving 30 welds and two BCAP duct pieces were also inspected in order to assess the effectiveness of the BCAP inspections. i l The welding in the HVAC area was performed by Pullman l Sheet Metal Inc.

b. Inspection Findinas Four of the inspected 140 welds were found to be undersized. As a result of this finding, the licensee issued NCRs and the welds were evaluated by S&L.

I The welds were accepted "as is" and l determined to be adequate for the intended application. I The three supports which were previously inspected by BCAP were i also found to contain undersized welds. In addition, a burn through i i I the duct was observed in the brazed joints between the duct and the ! duct companion flanges. The BCAP inspectors had made the same findings this inspection.in their report which was submitted to the project prior to ! IV-10

4

c. Conclusions

! e , In general, the inspected welding activities were found to comply

- with the requirements specified by the Architect Engineer. However, undersized welds were found in HVAC supports which indicated that the initial welding inspection was not effective in identifying undersized welds and showed a program weakness. The BCAP welding inspection performed in the HVAC area was found to be effective in identifying welding deficiencies.: 6. Structural Steel Fabrication and Erection

, a. Inspection Scope i Approximately 160 walds comprising 50 field and 110 shop welds were visually inspected in order to ascertain compliance with the specified acceptance criteria. ! Two welding procedures and the qualification test records for eight welders were reviewed. Visual inspection procedures and the quali-fication test records for two inspectors were also reviewed. Two welding inspectors were observed and evaluated for their ability to follow the visual inspection procedures. The original structural steel contract was performed by American Bridge Company, Napoleon Steel Contractors, Inc. (NSCI) and Mid-City Steel Company. The modification to the structural steel fabrication was performed by G.K. Newberg Company. , b. Inspection Findinas No problems were identified in the area of inspected welding activities involving the modification of structural steel. However, several shop welds involving clip to beam web connection welds were i found to be deficient. Specifically, the design drawings required

fillet welds some areas. allThese around while the connection was seal welded in welds were fabricated by American Bridge Company, which supplied the structural steel for the project.

One connection fabricated by NSCI was found to be welded while the drawings required a bolted connection. No Field Change Request (FCR) was found to document this change. Two welds fabricated by Mid-City were found to deviate from the construction drawings. The drawings required that the fillet welds be completed with returns around the clip while these two welds did not have returns around the clip. As a result of these findings, the licensee issued NCRs and the welds were evaluated by S&L. The welds were accepted "as is" and determined to be adcquate for the intended applications. 1 i 4 i IV-11

c. Conclusions In general, no significant problems were identified in the area of inspected welding activities. With the exception of the deficient welds previously discussed, activities were found to comply with i

the applicable construction codes and specifications. The deficient welds were determined to be adequate for the intended application by the Architect-Engineer.

7. Fuel Storace Pool and Refuelina Cavity Liner Fabrication

a. Inspection Scope The NRC CAT inspected approximately 100 feet of welded seas on the Fuel Storage Pool and the Refueling Pool Liner. Two welder qualification test records and one welding procedure were reviewed for compliance with the applicable codes and specifications. In addition, five plug welds and one cross plate welded sean located inside the refueling cavity were liquid penetrant examined. Two NDE technicians were observed while perfoming these liquid pene-trant inspections and were evaluated for their abilities to follow the applicable inspection procedures. The Fuel Storage Pool and Refueling Cavity Liner Fabrication was completed by PDM.

b. Inspection Findinos and Conclusions No problems were identified in the areas of inspected welding and NDE activities. Activities were found to comply with the applicable construction codes and specifications.

8. Fire Protection System Fabrication and Installation

a. Inspection Scope Approximately 80 welds involving 12 pipe supports and 25 pipe welds were visually inspected. One welding procedure and the qualification test records for five weldert were also reviewed for adequacy. The fire protection installation was completed by PGCo.

b. Inspection Findings and Conclusions No problems were identified in the area of inspected welding and NDE activities. Activities were found to comply with the governing construction codes and specifications.

9. Containment Liner and Containment Penetration Installation

a. Inspection Scope The NRC CAT visually inspected approximately 60 feet of liner seam, the welds on five patch plates, the attachment weld for one equip-ment hatch, one construction opening and the attachment welds for two mechanical and two electrical penetrations. In addition, one welding procedure and three welder qualification test records were also reviewed for adequacy In the area of NDE, the NRC CAT IV-12

 ~
 -                     reviewed 117 feet of liner seas which involved 289 films. One magnetic particle inspection procedure was also reviewed as a part of this inspe: tion. The centainment liner and penetrations were installed by CB&I.

b. Inspection Findinas and Conclusions No problems were identified in the area of inspected welding and NDE activities. Activities were found to comply with the governing construction codes and specifications.

10. Vendors and Shop Fabricators Other Than Those Previously Addressed

a. Inspection Scope The NRC CAT visually inspected 14 vendor supplied tanks and heat exchangers. See Table IV-5 for inspected vendor supplied equipment. In addition to the welds inspected and listed in Table IV-5, the NRC CAT inspectors reviewed radiographs related to work perfomed by 32 vendors which have supplied various equipment and hardware to the Braidwood project. A total of 750 feet of welded sean involving 1069 radiographs and 79 welds involving 364 film were reviewed. The radiographs for 23 valves involving 471 film, and the radiographs for 96 spot welds involving 186 film were also reviewed for compliance with the governing codes and specifications. See Table IV-6 for detailed listing of vendors reviewed.

b. Inspection Findinas During the inspection of tanks and heat exchangers suppifed by the vendors listed in Table IV-5, the NRC CAT found that the size of the nozzle and manway weld reinforcement did not meet the requirements stated in the vendor drawings. In addition, the welds on some of the inspected supports were also found to be undersized. A total of 14 tanks and heat exchangers were found to deviate from the required drawing sizes. As a result of these findings, the licensee issued NCRs and this item will be reviewed and dispositioned by S&L. See Table IV-5 for details.

In the area of NDE, the NRC CAT inspectors identified several irregularities related to radiographs supplied by six vendors. As a result of these findings, the licensee has issued NCRs and the welds will be evaluated and repaired as needed. The welds and their associated irregularities are identified as follows: Two welds fabricated by CB&I (reference Al and A2 Report 282A, Index Box 94) were found to have linear indications. One weld fabricated by Aerojet General identified as PX6030, piece 2 weld 2 was found to have linear indication. One weld fabricated by Harnischfeger Corporation showed excessive internal slag or surface pitting. IV-13

One seas weld fabricated by PDM identified as seam 57 in the Refueling Water Tank was found to have a crack in area 3 to 4.

    -                           Film supplied by Cleaver Brooks did not meet the low density requirements of the Code. However, adequate density was available to interpret the area of interest and the weld quality was found to be acceptable.

Film supplied by Greer Hydraulics did not meet the low density requirements of the Code. However, sufficient density was available to interpret the weld and the weld quality was found to be acceptable.

c. Conclusions In general, the inspected welding and NDE activities were found to comply with the requirements of the governing codes and specifications.

However, several tanks and heat exchangers were found to deviate from the requirements stated in the applicable drawings and specifications. In addition, the radiographs for some welds quality.were found to be deficient with respect to the specified ' l l IV-14

TABLE IV-1 PIPf. SUPPORTS / RESTRAINTS SUBJECTED TO DETAILED INSPECTION

IWO25006 1A812003G (2) ISX68017R 1FWO12365 ISIO6027S (1) 2WXF26001T 1CV54009R (3) 1CV020035 1CV02001C (4) 1RH02054S 1RH0201R (5) 1RH020085 1REF40003G (6) 15I01030S 15I040165 (21) 1CV52016G (7) 1FWO4009V 1FWO2009X (8) 1RC130695 1RC12073X 1FWO5002R ISX08037G (9) 1WR-FWR-22 1RH20595 1RE04008X ICV 03003S ISI16020X (10) 1RH02026R ISI13002G (11) ICV 37038 (12) 1RH02073X 1CV02006V (13) 1CV02004S ISI19023G 1RF26003T 1RY29031T IWOO1021X (14) 1FIS-447-H140-1 (15) 1RH0281S 1RC100325 (16) ISXO90385 (17) 15I060355 (18) 1AB18019G (19) ICS06032X (20) NOTES: (1) Four flare bevel welds undersized. Pipe attachment weld undersized. NCR 2941 (2) Two full penetration groove welds did not have full penetration; 2 fillet welds were short for more than 10% of the weld length. NCR 2947 and 3394 (3) Skewed fillet welds undersized for full length. NCR 3156. (4) Two non-skewed fillet welds undersized NCR 2975. (5) Weld undersized due to overgrinding. (6) Support has extra load-bearing plate which was not specified on the drawing. FPR-G2690 IV-15

r

TA8tE IV-1 (Continued)

PIPE SUPPORTS / RESTRAINTS SUSJECTED TO DETAILED INS (7) Skewed fillet welds undersized. NCR 2977. (8) Skewed fillet welds undersized. NCR 2978. (9) Skewed fillet welds undersized; penetration. four groove welds did not have full NCR 2965 (10) Skewed fillet welds undersized. NCR 3008. (11) Tube steel to embedment weld was short in length. NCR 3155 (12) Two 3387. welds missing; two skewed fillet welds undersized. NCRs 3055 and (13) Two skewed fillet welds undersized. Flare bevel weld was not welded flush. NCR 3011. (14) Two skewed fillet welds undersized. NCR 3261. (15)undersized Four skewed fillet welds undersized. Three non-skewed fil

(16) Two flare bevel welds were not filled. NCR 2976. (17) Two flare bevel welds were not filled. NCR 2941. (18) undersized. Two welds were missing; incorrect welding symbol used; two fillet welds NCR 3393. (19) Two skewed welds undersized. NCR 3261 (generic). (20) Two skewed welds undersized. NCR 3261 (generic). (21) Skewed welds undersized. NCR 3261 (generic). IV-16

TABLE IV-2 PIPE SUPPORTS WHICH WERE SUBJECT TO VISUAL INSPECT ICC40AA 1CV02002S 1F0F10001T IFC99008X ICV 52016G ICV 52026R ISI19025X IFC01005X ICC13037R 1RH020585 1CV420s1G (1) 2RH01Ca 1RYO90805 ISIO6124X 1CS06032X 1RH01001V 15I060915 1FWO4018X Unit 1 Pressurizer Lower Ring Girder and Upper Guides (2) NOTES: (1) Pipe bent due to interference by temporary support. (2) Arc strikes (found). l 1 l IV-17

TA8LE IV-3 PIPE WHICH WAS SUBJECTED TO VISUAL INSPECTION ONLY ITEM DESCRIPTION PIPE SIZE (in.) DESCRIPTION 1-CC-13-W-1 Component Cooling 18 Carbon Steel 1-C5-16-11 Containment Spray 10 Stainless Steel 1-CS-16-2 Containment Spray 10 Stainless Steel ICV-34 Chemical Volume Control 4,6,2 Stainless Steel 1-CV-41 Chemical '!alune Control 3 Stainless Steel 1-CV-41-1 Chemical Volume Control 12, 1 Stainless Steel 1-CV-A38 Chemical Volume Control 2 Stainless Steel 1-00-46 Diesel Oil 4 Carbon Steel 1-FC-1-5 Fuel Pool Cooling i 18 Stainless Steel l 1-FC-2-2 ' Fuel Pool Cooling 12 l Stainless Steel 1-FC-8-1 Fuel Pool Cooling 16 Stainless Steel 1-FC-8-2 Fuel Pool Cooling 10 Stainless Steel 1-FC-8-5 Fuel Pool Cooling 16 Stainless Steel 1-FW-030A Feedwater 16 Carbon Steel 1-FW-13-7 Feedwater 16 Carbon Steel 1-FW-16-7 Feedwater 16 Carbon Steel 1-RC-0-12 Reactor Coolant 36 Stainless Steel 1-RC-7-2 Reactor Coolant 4 Stainless Steel 1-RE-4-5 Containment Equipment Drain 4 Stainless Steel 1-RF-02AA Containment Floor Drain 2 Stainless Steel l 1-RH-01AA Residual Heat Removal i 12 Stainless Steel 1-RH-2-5 Residual Heat Removal l 6 Carbon Steel 1- RH-7-5 Residual Heat Removal 16 Stainless Steel 1-RH-19-6 Residual Heat Removal 6 Stainless Steel IV-18 l

TABLE IV-3 (Continued)

PIPE WICH WAS SUBJECTED TO VISUAL INSPECTION ONLY ITEM DESCRIPTION PIPE SIZE (in.) DESCRIPTION 1-SI-03A8 Safety Injection 4 Stainless Steel 1-SI-10-1 Safety Injection 8 Stainless Steel 1-S1-10-6 Safety Injection 10 Stainless Steel I i , t IV-19

    -                                                                                                                                                                                                         l TABLE IV-4
'                                 PORTIONS OF PIPING SYSTEMS WHICH WERE SUBJECTED TO DETAILE ITEM                      DESCRIPTION                                                                        PIPE SIZE (in.)                                              MATERIAL 1-FW-15-01                Feedwater                                                                                              16                                       Carbon Steel 1-FW-15-03                 Feedwater                                                                                              16                                       Carbon Steel 1-FW-15-04                 Feedwater                                                                                              16                                       Carbon Steel 1-FW-15-05                  Feedwater                                                                                              16                                       Carbon Steel 1-FW-15-06                  Feedwater                                                                                              16                                       Carbon Steel 1-MS-16-1                   Main Steam                                                                                            32                                        Carbon Steel 1-MS-16-2                   Main Steam                                                                                            32                                        Carbon Steel 1-MS-16-3                    Main Steam                                                                                            32                                       Carbon Steel 1-MS-16-4                    Main Steam                                                                                           32                                        Carbon Steel 1-MS-16-5                    Main Steam                                                                                            32                                        Carbon Steel 1-MS-16-6                    Main Steam                                                                                            28                                        Carbon Steel 1-MS-16-7                    Main Steam                                                                                            28                                        Carbon Steel 1-MS-16-8                     Main Steam                                                                                               8                                      Carbon Steel 1-MS-16-8A                    Main Steam                                                                                               8                                      Carbon Steel 1-0G-33-2                     Off Gas                                                                                                  3                                      Carbon Steel 1-0G-33-4                      Off Gas                                                                                                  3                                      Carbon Steel 1-0G-33-5                      Off Gas                                                                                                 3

. Carbon Steel 1-0G-33-6 Off Gas 3 Carbon Steel 1-0G-33-7 Off Gas 3 Carbon Steel 1-0G-33-8 Off Gas 3 Carbon Steel l 1 IV-20

i [ . I

  -i     ;                                                                            TA8LE IV-5 f

l VENDOR SUPPLIED TANKS AND HEAT EXCHANGERS i WHICH WERE VISUALLY INSPEcrED ITEM MANUFACTURER Two Spent Fuel Heat Exchangers 2FC01A/1FC01A (1) Atlas Industrial Manufacturing Component Cooling Surge Tank 2CC01T (2) i Westinghouse Electric Two Boric Acid Storage Tanks 1A8037/2A803T (3) C8&I

  ,                     Two Recycle Holdup Tanks OA801TA/0A80178 (4)                                              C8&I Letdown Reheat Heat Exchanger ICV 05A (5)

Atlas Industrial Manufacturing Diesel Fuel Oil Day Tanks 10010T (6) Graver Volume Control Tank ICVOIT (7) Lanco Industries Mixed Bed Domineralizer Tank 2CV01DA (8) Lanco Industries RHR Heat Exchanger 13H02AA (9) Joseph Oat Spray Additive Tank 2CS01T (10) Graver Horizontal Letdown Heat Exchanger ICV 04A8 (11) Joseph Oat NOTES: (1) One coupling had undersized fillet weld. (2) Support welds undersized; manway fillet welds undersized; two 4" nozzles have undersized fillets between nozzle and reinforcing pad. (3) Tank support welds still covered with welding flux; manway fillet welds undersized; nozzle welds undersized. ! NCR 694. l (4) Manwty welds fillet welds missing. NCR 694. undersized; nozzle welds undersized; stiffening ring (5) Three nozzle fillet welds undersized. (6) Support fille't welds on one saddle undersized. (7) Kanway drawings. nozzle configurations different than those shown on the design (8) Nozzle to reinforcing pad fillet weld undersized. { 1 undersized. Four support fillet welds (9) Three 3/4" half-couplings had undersized fillet welds. IV-21

TA8LE IV-5 (Continued) VENDOR SUPPLIED TANKS AND HEAT EXCHANGERS WHICH WERE VISUALLY INSPECTED (10) Three nozzle to reinforcing pad welds undersized. (11) Two 3/4" nozzle fillet welds undersized. i i I i IV-22 i

TABLE IV-6 VENDOR RADIOGRAPHS REVIEWED Valve Spot Feet of Contractor Welds Pumps Welds Welds Film Notes Chicago Bridge 82 and Iron 164 (1) Yuba Heat Transfer 50 252 Aerojet-General 3 28 (1) Westinghouse Electric 70 118 W.K.M. 40 34 Harnischfeger 40 72 (1) Anchor / Darling 5 192 Graver 60 86 PDM 80 162 (2) Carrier 12 17 Gulf & Western 100 116 American Bridge 21 68 Cooper Bessemer 20 14 Control Components 30 41 Dresser Industries 2 36 Unitech Div. of Ecodyne 8 16 Atwood and Morrill 1 12 L.A. Water Treatment 6 6 McQuay-Perfax 5 16 ITT-Grinnell 8 8 Pall Trinity 40 54 Cleaver Brooks 50 54 (3) TRW Mission 3 18 IV-23

 ;                                                     TABLE IV-6 (Continued)

VENDOR RADIOGRAPHS REVIEWED Valve Spot Feet of Contractor Welds Pumps Welds Welds Film Notes Teledyne Brown 2 Engineering 28 Borg-Warner 4 98 Continental Boiler Works 20 22 Rockwell International 30 43 Greer Hydraulics 30 64 (3) W.J. Wooley 20 30 Jamesbury 3 27 Bingham-Willamette 3 60 Atlas Industrial Manufacturing 100 132 NOTES: (1) Linear indications found (2) Crack found in area 3-4, seam 57 of the Refueling Water Tank (3) Film density not within the ranges required by the code. 1 IV-24

V. CIVIL AM) STRUCTURAL CONSTRUCTION A. Objective The objective of the appraisal of civil and structural construction was to detemine by evaluation of completed work and by review of documentation whether work, inspection and test activities relative 3 i to civil and structural construction ar,eas were accomplished in ' accordance with regulatory requirements, Safety Analysis Report (SAR) commitments, and project specifications, drawings and procedures.

8. Discussion The specific were: areas of civil and structural construction evaluated concrete, reinforcing steel configuration, cadwelds, structural steel installation and bolting, masonry walls, and the concrete expansion anchor bolt qualification report.

For concrete, reinforcing steel configuration, structural steel installation and bolting, and masonry walls, a physical or hardware inspection and a quality Control (QC) documentation and field procedures review were conducted. For cadwelds and the concrete expansion anchor bolt qualification report a review of QC documen-tation and field procedures was performed. 4

1. Concrete Activities .

a. Inspection Scope The reinforced concrete activities reviewed by the NRC Construction Appraisal Team (CAT) inspectors included four construction openings.

! These areas were reviewed for conformance of rebar placement with

the design drawings (see Table V-1) and specifications. General concrete quality was also examined from surrounding areas for conformance to site specification requirements. Records associated with the concrete placements were also reviewed. These included the concrete placement reports, concrete placement checklists and the field inspection reports for reinforcing steel.

, Using the cadweld splice performance records, adequacy of the production and sister splices testing frequency was reviewed. In Table V-2 the numbers of the cadweld splices reviewed are listed along with the production and sister splices taken for those cadwelds. The inspection sample size of the tensile tests covered 1200 cadwelds. Documentation and requirements for cad-welder quellfication and requalification procedures were reviewed. The qualifications of five cadwelders were checked to see if they met visual and tensile test requirements. t The requirements and acceptance criteria for concrete activities and robar placement are included in the following specifications and procedures: l l V-1 I i

1 Ceco Specification F/L-2722 " General Structures Work"

,                         Ceco P*aidwood Station Units 1 and 2 Quality Control Procedure factH . 11, Rev. 14 " Concrete and Grout Placement" 10.02.01 Cadweld Splicing Qualifications Horizontal (Expired) 17.01 "Cadweld Spifce Performance Record NS-7" 17.02 "Cadweld Splice Procedure Inspection NS-8" Forn BY/BR/MCS, Rev. 7 " Quality Control Procedures Napoleon Steel Contractors, Inc. Procedure #3 - Cadweld Splicing"

b. Inspection Findings In the four concrete areas inspected, three areas were identified where the rebar was not placed in accordance with design drawings.

I Two areas were in the Reactor Auxiliary Building where the reinforcing shown on the design drawings was not placed in the temporary con-struction openings at elevation 401 in the 15 and 21 line walls between column line U and column line V. For both faces of the east ends of 1 the construction specified eleven #7openings bars. in the walls en lines 15 and 21, the drawings ' However, caly ten #7 rebars were found in ( the north faces of the 15 and 21 line wall openings. For the south I faces of the 15 and 21 line wall openings, there were twelve #7 and nine #7 rebars, respectively. Although the construction openings had not been filled, the proper number of rebars should have been pieced ' when the concrete was placed for the 15 and 21 line walls. 4 Followup discussions with responsible engineers and examination of inspeci. ion criteria disclosed that the construction openings had not been signed off for placement of concrete. The reinforcement arrangement will have to be inspected and approved by craft, field , engineers, and construction inspectors prior to placement of concrete. The licensee stated that the reinforcing steel will be added prior to placement of the concrete. The third area was a construction opening located at the east end 1 l of the Unit 2 Containment Building at elevation 426'-0". Reinforcement ; was not placed around the construction opening as shown on the design i

         'Jrewings. On the drawing three layers of eight-#11 rebars were required.

However, only three layers of seven-#11 were found. Also, some of the I rebar spacings on all four sides of the construction opening were ! out of tolerance. The licensee has written a Nonconformance Report ' (NCR) to evaluate these discrepancies. A preliminary explanation by the licensee for the missing eighth #11 robar in the three layers of , rebar was that the eighth robar could be embedded in the surrounding ' concrete placement. i V-2 j

f

  .                  Procedures required that for the first 498 cadwelds 5 production and 12 sister splices perfereed           be taken, if only one cadveld operator or crew had all of them.                                                            !

11 sister splices were taken. Records showed that only 5 production and operators were involved for the first 498 cadwelds.In addition, it app t ' Since it could not he shown that any of the 5 cadwsid operators had worked together as a unit, 2 additional test samples were missing for each extra cadwelder performing more than 100 cadwelds in that sample. This discrepancy was also found in the next 702 cadwelds inspected. Had

a single cadwelding unit performed all 702 cadwelds, the procedures i required a total of 21 production and sister splices.

18 were tested. had performed some of those cadwelds.Also, it appeared i more than 100 cadwelds in those additional cadwelds, 2 more l test samples were required. This deficiency was brought to the attention of QC personnel. Their subsequent investigation determined that the problem was generic. Following NCR was being this,prepared. an NCR was issued and a resolution to disposition the No problems were identified with the qualification of the five cadwelders reviewed. However cation documentation, no requa,lification documents were Appro-found priate QC personnel requalification were questioned and they confirmed that there was no documentation. The reason stated was that no cadwelder required failed for requalifiestion any cadwelder.since no two consecutive tensile tests had

c. Conclusions The concrete quality was found to be acceptable. !

Three areas were identified the where the reinforcing had not been placed in accordance with design drawings. i issued or being prepared.To resolve these concerns, NCRs were either ~ Despite the generic problem with the deficient frequency of cadweld production and sister splices taken, the results of those which were tested did not indicate a concern for the quality of cadwelds installed. No concerns were found with cadwelder requalificat appeared no cadwalder required it. 2. Structurel Steel Installation

a. Inspection Scoos Installed and QC accepted structural steel was inspected for member size, configuration and conformance of bolted connections to the design drawings (see Table V-3) and specifications.

bolts were tested using a calibrated torque wrench to determineStructural ste whether the bolts were properly tightened. The inspection sample was selected randomly from structural steel assemblages installed in the Reactor Containment Building Units 1 and 2 and the Reactor Auxiliary Building. l V-3

Structural steel installations inspected included 38 members and 30 connections for proper sizes, dimensions and configuration, and 316 high strength bolts for minimum inspection torque. Table V-4 gives the distribution of the various members and connections inspected in the three buildings.

strength bolts torqued see Table V-5.For the distribution of high The 1-1/8 bolts tested A490 inch diameter included bolts. 7/8 inch diameter A325 bolts and 1 and : Skideore Wilhelm tension tester in which bolt tension torque requirements were measured and compared against job inspection torques. Valuesinspectors. by construction obtained were in general agreement to those used l The requirements and acceptance criteria for :tructural steel installation tions and inspection are included in the following specifica-and procedures:

CECO Specification F/L-2722 " General Structures Work"
Ceco Specification L-2735 " Structural Steel"
S&L (Form 1700-T) " Standard Specification for Fabrication of Structural Steel"

b. Inspection Findinas No discrepancies were identified between the installed 38 structural steel members and 30 connections and the design drawings. Part of the inspection sample covered steel beams in the Reactor Containment Building Units 1 and 2 that were subject to a major modification program at the site to account for loads identified at another nuclear power plant, Commonwealth Edison Company's (Ceco) Byron Station, which was similar in design. No problems wers found with the QC procedures which controlled 38 inspected proper modification of the beams that were part of the beams.

i' With tr.e high strength bolt torque sample, 19 bolts were found to have been torqued significantly below agreed upon minimum inspection torque values. Of the 19, 5 had zero installation torque and were in the Unit 1 Containment Building. No significant concentration of overall bolt torque failure was fon d in any single butiding. In Unit 1 for the 1-1/8 inch diameter A490 bolts, 2 out of 5 bolts 1 failed. This was the only case that experienced a high percentage i rate of failure. However, the sample size was small.

c. Conclusion In general, structural steel installation activities (member size, configuration and connections) were found to be in conformance with the design drawings. The 14 bolts found to have low torque values were probably isolated cases.

This includes the two that failed in the Unit 1 Containment Building for 1-1/8 inch diameter A490 bolts. The V-4

licensee indicated that NCRs will be written for the five bolts that were found to be loose and that new high strength bolts will be installed.

3. Masonry Walls

a. Intoection Scope Masonry wall construction attributes inspected included controlling pro:edures, specifications, and installed block walls. Fo: the installed block walls, the inspection concentrated on exterior and rebar. column fixes and removed portions of masonry walls exposing interior Building.All masonry work reviewed was in the Reactor Auxiliary The requirements construction and acceptance and inspection were: criteria used for review of masonry t

Ceco Specification F/L-2722 " General Structures Work"
Quality Control Procedure Section 32 Storage and Installation of Masonry Material Form 32-3 " Interrupted and Repair of Masonry Work Checklist"

b. Inspection Findings Examination of completed work showed that masonry wall installations in general conformed with design drawings and specifications. Portions of the masonry walls had been removed around embedded structural steel columns in order to expose the steel for a separate Ceco QA inspection.

The purpose was to verify that the embedded structural steel conformed to design drawings and specifications. walls had been removed, embedded rebars had become exposed.In Some of s those rebars had been doweled into the remaining portion of the masonry walls. A few instances were noticed in whit.h the exposed doweled rebars had become loose and may have no longer been able to meet anchorage requirements. walls did not require inspection of this attribute.The QC procedure

c. Conclusions In general masonry wall activities were found to be acceptable. The licensee should revise existing procedures for repair work on masonry walls to ensure that the doweled rebars are adequately anchored.

4. Concrete Expansion Ar.chor Bolts

a. Inspection Scope The qualification test report for the wedge type concrete expansion anchors used at the Braidwood site was reviewed for technical adequacy, conformance to the project specifications and demonstration of satisfactory anchor performance.

V-5

l s The following qualification test report was reviewed:

Byron /Braidwood Structural Project Design Criteria

    ,              DC-ST-03-BY/BR Table 38.1

' The requirements and acceptance criteria for wedge type concrete expansion bolts was contained in the following docume,t:

Form BY/BR/CEA "BY/BR Standard Specification for Concrete Expansion Anchor Work Byron Units 1 and 2 and Braidwood Units 1 and 2"

b. Inspection Findings The qualification test report was found to be consistent with the specifications and procedures for installation and inspection, i

c. Conclusions i

The concrete expansion bolt qualification test program was found to be acceptable. i i V-6

Table V-1 DRAWINGS USED FOR CONCRETE CONSTRUCTION REVIEW Drawing No. Title Inryco-A-302, Rev. 2 Containment Building 5'-0" Deep Slab at E1. 426'-0" Slab Botton Steel Reinforcement Inryco-A-303, Rev. 2 Containment Building 5'-0" Deep Slab at E1. 426'-0" Slab Top Steel Reinforcement Inryco-C-91, Rev. 3 Auxiliary Building Walls on Lines 15 and 21 from El. 383'-0" to 481'-0" Inryco-C-104, Rev. 3 Auxiliary Building Tunnel Floor El. 375'-6" Tunnel Floor E1. 394'-6" Lines Q to Q.8 and 15 to 21 Inryco-C-123, Rev. 10 Auxiliary Building Wall on Line 15, Q to W Wall on Line 21, Q to W El. 401'-0" to E1. 426'-0" Inryco-0-23, Rev. 5 Fuel Handling Building Wall Along Line W (Column Lines 15 to 21) El. 426'-0" to E1. 485'-0" 1 V-7

Table V-2 i O CADWELD TENSILE TESTING FREQUENCY INSPECTION SAMPLE f Cadweld Spitee No. Production Splice No. Sister Splice No. 1 thru 498 5, 49, 198, 362, 444 435, 745, 945, 133S, 166S, 2305, 2695, 300S, 332S, 3925, 4985 529 thru 774 636SP* 5305, 5455, 6075, 6525, 6785 785 thru 815 801SP 8075 842 thru 895 none 8595 I 911 thru 945 none none j 965 thru 1005 none 996S 1 1024 thru 1049 none none l 1062 thru 1078 none f none 1105 thru 1164 none none 1190 thru 1262 1190SP, 1191SP, 1235SP, 12375P, 12595P 1278 thru 1305 none i none i 1333 thru 1346 none none 1369 thru 1445 1385SP 13985, 14175

       *SP designates a sister splice in lieu of a production splice.

V-8

Table V-3 ORAWINGS USED FOR STRUCTURAL STEEL INSTALLATION REVIEW Drawing No. Title S&L-S-914, Rev. AJ Cont. Bldg. Floor Framing Plan El. 412'-0" Areas 2 & 3 S&L-S-927, Rev. T Cont. Bldg. Column Schedule S&L-S-1010, Rev. BA Cont. Bldg. Floor Framing Plan E1. 426'-0" Areas 5 & 8 S&L-S-1287, Rev. V Aux. Bldg. Floor Framing Plan El. 409'-6" Area 6 S&L-S-1290, Rev. BE Aux. Bldg. Floor Framing Plan E1. 414'-0" Area 7 S&L-S-1293, Rev. CC Aux. Bidg. Mezz. Floor Framing Plan E1. 426'-0" Area 2 S&L-S-1294, Rev. BP Aux. Bldg. Mezz. Floor Framing Plan El. 426' Area 3 S&L-S-1297, Rev. BD Aux. Bldg. Mezz. Floor Framing Plan El. 426'-0" Area 6 S&L-S-1354, Rev. AA Aux. Bldg. Cover Plate Schedule S&L-S-2108, Rev. D Cont. Bldg. Framir.g Modif. Plan E1. 412'-0" Areas 2 and 3 S&L-S-2127, Rev. AP Cont. Bldg. Framing Modif. Sched. for E1. 412'-0" S&L-S-2128, Rev. AD Cont. Bldg. Framing Modif. Sched. for El. 412'-0" S&L-S-2135, Rev. AD Typical Modification Details S&L-S-2180, Rev. AP Aux. Bldg. Framing Modif. Sched for E1. 375'-6"; 376'-0"; 391'-6"; 392'-0"; 394'-6"; 401'-0"; 409'-6"; 414'-0"; 415'-0"; 417'-0" S&L-S-2181, Rev. AP Aux. Bldg. Framing Modif. Sched, for E1. 426'-0" S&L-S-2213, Rev. F Cont. Bldg. Framing Modif. Plan for E1. 426'-0" Areas 5 and 8 S&L-S-2227, Rev. Z Cont. Bldg. Framing Modif. Sched. for E1. 426'-0" S&L-S-2305, Rev. C Framing Modification Sections and Detafis , S&L-S-2335, Rev. E Framing Modification Sections and Details S&L-S-2345, Rev. E Framing Modification Sections and Details S&L-S-2365, Rev. B Framing Modification Sections and Details S&L-S-2403, Rev. B Framing Modification Sections and Details S&L-S-2407, Rev. D Framing Modification Sections and Cetails S&L-S-2423, Rev. D Framing Modification Sections and Cetails V-9

Table V-4 l STRUCTURAL STEEL INSTALLATION SAMPLE O Number Number Number Location of Benas Number of of Braces of Columns Connections

Comments Containment 10 1 None 10 Building Unit 1 No deficiencies identified.

Containment 8 1 5 Building Unit 2 13 No deficiencies identified. Auxiliary 9 1 3 Building 7 No deficiencies __ identified. Total 27 3 8 30

     *This sample is separate from the high strength bolt torque sample.

V-10

l . Table V-5 HIGH STRENGTH BOLT TORQUE SAMPLE I A325 A490 Location A490 7/8 in. dia. 1 in. dia. 1-1/8 in. dia. Not Not Not Accepted 1 Accepted Accepted Accepted Accepted Accepted Containment 67 9 16 None 3 2 Building Unit 1 Containment 31 0 79 3 14 2 Building Unit 2 Auxiliary 79 2 None Nonc 8 Building 1 Tota 1 2/ 177 11 95 3 25 5 1#

         " Accepted" designates the number of bolts that reached minimum acceptable bolt torque values. "Not Accepted" designates the number of bolts which did not reach minimum torque values. Minimum acceptable bolt torque values used for the inspection of 7/8 in., 1 in, and 1-1/8 in, diameter high strength bolts were 400 ft-lbs, 900 ft-lbs and 1200 ft-lbs, respectively.

2/ The range of torque values of bolts found below the minimum acceptable torque values in ft-lbs were: 7/8 in. dia. 1 in. dia. 1-1/8 in, dia. O to 325 750 to 850 200 to 700 (5 had zero torque) V-11

VI. MATERIAL TRACEA8ILITY AND CONTROL A. Ob.lective This portion of the inspection was to verify, through selected the adequacy of the traceability and control of material and equip The inspection was also to verify the adequacy of the licensee's program relative to these activities. B. Discussion The method utilized to determine the adequacy of the licensee's traceability and equipmentprogram included selecting samples of installed material for examination. Material delivered such as protective coating materials) but not yet installed, werel samp(ed from storag areas. selectedSome samples of installed material that were not accessible were from records. extents. Table VI-1, " Summary of Samples", indicates th contractors involved and the types of activities and samples examined. Various procedures from active on-site contractors were reviewed. The procedures reviewed included the following: Phillips-Getschow

Quality Control Procedure (QCP) B21, Rev. 9. " Installation of ASME Section III and Safety Related Process Piping Systems - 2 Inches and Smaller"
QCP B4, Rev. 5, " Material Control"
QCP B28, Rev. 4, " Fabrication and Installation of ASME Section III and Safety Related Large Bore Process Pipe"
Phillips-Getschow Connections" Construction Procedure (PGCP) 15, Rev. 4, " Bolte
PGCP 46, Rev. 0, " Mechanical Joint Review / Retro-Fit Program" Gust K. Newbera
Section Materials"9, Rev.10 " Receipt, Storage and Issuance of Safety-Related
Section 7, Rev. 3, " Receipt and Storage-Reinforcing Steel"
Section 16. Rev. 4, " Storage of Cadweld Materials" L. K. Comstock
Procedure 4.3.8, Rev. D, " Cable Installation"
Procedure Material" 4.3.10, Rev. F " Storage, Issue and Control of Welding VI-1

1

Procedure 4.10.2, Rev. B. " Receiving and Storage" Installed material and equipment was inspected to verify that markings on various samples, such as equipment (mechanical, electrical and instr eantation), pipe hangers / supports and weld joints, were traceable to associated documentation. Samples were also selected from items in l

warehouses and on-site fabrication shops. Table VI-2, " Sample Breakdown by Contractors", identifies the number and type of samples applicable to each contractor. Table VI-3, " Weld Filler Material Compliance", i I contains a list of weld filler material samples. The following sections describe the inspection results:

1. Material Traceability

, a. Inspection Scope i I The 267 samples selected were examined for traceability to drawings, i specifications, procurement records, Certified Material Test Reports (CMTRs), Certificates of Compliance, heat numbers or other required { documentation.

b. Inspection Findinas l

Procedures for material traceability and control of material at the site were determined to be in place. At present, the site mechani- ! cal contractor is implementing a Material Traceability Verification 1 (MTV) program for large bore piping installed prior to November 1982 and , mall bore piping installed prior to July 1983. It had pre- ! viously been determined that the site mechanical contractor did not have to prior adequate procedural controls to ensure piping traceability these dates. This generic programmatic deficiency, with respect to piping traceability, has been identified to NRC Region i III in .secordance with the requirements of 10 CFR 50.55(e). The MTV program is to determine that: 1) the correct piping material was f installed test and 2) the material is traceable to certified material repcrts. This program was almost complete and was to be evaluated under the Braidwood Construction Assessment Program. The piping / tubing samples selected during this inspection had been verified for traceability by the site mechanical contractor's quality control under the MTV program. i i ' The site mechanical contractor has developed a program for reviewing, verifying and tracking mechanical joints. Tnis is a retro-fit program which was developed as a result of an internal audit finding issued by the site mechanical contractor. Fasteners for two mechanical joints sampled during the inspection were determined to be the wrong grade of material. However, the existing , i documentation identified these as temporary mechanical joints. The

mechanical joint retro-fit program, if properly implemented, should ,

ensure correct fasteners are installed for mechanical joints. l 4 VI-2 l - 1

Twenty samples of weld filler material listed in Table VI-3 were examined for traceability and compliance with the applicable code and were found to be acceptable. Nine weld rod holding ovens in the Phillips-Getschow weld rod issue stations were examined and found te meet requirements. The site contractors use a combination of computerized and manual records to help control the identification and status of material and equipment. The following observations were identified: (1) As a result of the NRC CAT inspector investigating the quali-fication of switchboard wire, over 10,500 feet of General Electric switchboard wire not qualified to IEEE 383-1974, was identified as being received at Braidwood. Programmatic controls did not exist to prevent this wire from being utilized in an application requiring IEEE 383 qualification. As a result, Commonwealth Edison issued NCR 707 to identify this item. (2) Sargent & Lundy Standard EB 115.0 required the use of ASTM A307 bolting material for Class IE seismic cable tray hangers. Hangers in the lower cable spreading room were examined and found to have fasteners installed that did not comply with ASTM A307. Also, the generic qualification document issued by Gould Inc. for Braidwood's Class 1E storage batteries specified ASTM A307 bolts for the battery racks. The battery racks were inspected and found to have bolting material that did not meet the rriquirements of ASTM A307. 692 to identify these items. Commonwealth Edison issued NCR (3) A certified material test report for a loop 4 jet deflector embed was reviewed and noted not to be in compliance with Sargent & Lundy Drawing S-1089. This drawing required the material for the embed to be ASTM A588 Grade 8. The embed insc.alled was fabricated with ASTM 588 Grade A material. (4) The anchor assembifes for the diesel generators consisted of studs which were required to meet ASTM A293 Grade 87. The installed studs were not marked with the material grade as required by ASTM 193.

2. Conclusions Except for the observations noted above, the material traceability program presently in place appears to be adequate. However, it should be noted that there has been past problems identified pertaining to traceability. Specifically, in the area of large and small bore piping. The licensee has established a program to determine acceptability of installed piping in regards to trace-ability which is still in process.

l VI-3 l

TABLE VI-2 SAMPLE BREAKDOWN BY CONTRACTORS

                                           $          GKN          N_ag          LKC                      Nid                     Tel    C8&I   g Equipment                          8         -             -            -                         -                       -       -     -
     ,      Pipe / Tubing                  30            -            -             -                         -

1 - - Steel-Strue. 5 2 - - - - - 3 Steel-Plate / 3 3 - - - Sheet 5 3 - Hanger / Supports 9 - - 11 - - - - Embedmont - 4 - - - - 3 - Weld Filler 14 - 3 3 - - - - Material Wald Joints 44 - - - - 4 10 - Elec. Cables - - - - - - - - (Reels) Fasteners 22 7 - 6 - 3 - - Cadweld Sleeves / - - 9 - - - - - Powder Coatings - - - - 6 - - - Rebar - 6 40 - - - - - l TOTALS 135 22 52 20 6 13 16 3 i VI-5

TA8LE VI-3 WELD FILLER MATERIAL COMPLIANCE Material Heat No. Desianation Compliance Material I.D. Comments E7018 3/32 22272 Acceptable E7018 1/8 49556 Acceptable E308 3/32 507761 Acceptable E308 1/8 08022 Acceptable E316 3/32 08203 Acceptable E316 1/8 1F102M02 Acceptable E309 3/32 50737-1 Acceptable E309 1/8 616280 Acceptable E316 3/32 21810 Acceptable E7018 1/8 48840 Acceptable E7018 3/32 33255 Acceptable E309 3/32 626218 Acceptable E7018 1/8 33807 Acceptable E3092 1/8 11846-1 Acceptable E7018 5/32 411H4691 Acceptable E7018 1/8 23553 Acceptable E7018 1/8 33228 Acceptable E7018 1/8 33004 Acceptable E7018 3/32 33255 Acceptable VI-6

, VII. DESIGN CHANGE CONTROL A. Objective The primary objective of the appraisal of design change control was to determine whether design change activities were conducted in compliance ! with regulatory requirements, Safety Analysis Report (SAR) commitments and approved licensee, engineer, constructor and vendor procedures. An additional objective was to determine that the changes to structures and hardware prescribed in a sample of design change documents were accurately completed. 1 B. Discussion 10 CFR 50, Appendix B, Criterion III " Design Control" and Criterion VI ! " Document Control" establish the overall regulatory requirements for design change control. These requirements are elaborated in Regulatory Guide (RG) 1.64 Rev. 2, June 1976, " Quality Assurance Requirements for the Design of Nuclear Power Plants" which endorses American National Standards Institute (ANSI) Standard N45.2.11-1974 " Quality Assurance Requirements for the Design of Nuclear Power Plants." The licensee's : i commitment to comply with RG 1.64 is stated in Chapter 17 of the Byron / Braidwood Stations Final Safety Analysis Report (FSAR). The areas of design change control evaluated by the NRC Construction Appraisal Team (CAT) inspectors were control of changes to design , documents and control of design changes. In each of these areas, interviews were conducted with personnel responsible for the control of activities, procedures were reviewed, and a sample of the controlled documents was reviewed. In addition, a sample of the completed structures and hardware which had been inspected and accepted by e 4 on-site contractor quality control personnel was inspected by the NRC CAT inspectors. basis. These evaluations were performed on an interdiscipline

1. Control of Desian Documents The specific aspects of the control of design documents inspected were the availability to the users of the latest approved design documents and design change documents and the methods of assuring that approved changes not yet incorporated into design documents are provided to the users prior to work being performed.

a. Inspection Scope (1) The following procedures related to distribution and control of design documents and design change documents were reviewed:

Commonwealth Edison Company (Ceco) Quality Requirement (QR) 3.0, " Design Control," Rev. 15, August 15, 1984 Ceco QR 6.0, " Document Control," Rev. 9, August 15, 1984 Ceco Quality Procedure (QP) 6-1, " Distribution of Design Documents," Rev. 7, October 10, 1983 VII-1

Ceco QP 6-2, " Procedure for Station Construction Department Design Document Control," Rev. 3, May 12, 1983 Ceco Braidwood Nuclear Station Project Procedure PCD-03,

                                                  " Field Change Request," Rev. O, June 15, 1984 Sargent & Lundy Engineers (S&L) General Quality Assurance Procedure October   21,(GQ) 19813.07, "Sargent & Luncy Drawings," Rev. 6, S&L1981 21,    GQ-3.13, " Engineering Change Notices," Rev. 6, October S&L GQ-6.01, " Project Distribution List and Project File Indexes," Rev. 5, October 21, 1981 S&L Project Instruction for Byron /Braidwood (PI-BB) 29,
                                               " Distribution and Control of Design Documents for S&L Field Personnel at the Byron /Braidwood Stations" L. K. Comstock & Company, Inc. (LKC) Procedure 4.2.1,
                                              " Document Control," Rev. F, October 12, 1984 Gust K. Newberg Construction Co. (GKN) Quality Assurance Manual (QAM) Section IV, " Document Control," Rev. 4, October 3, 1984
,                                            GKN Quality Control Procedure (QCP) Section 3, " Drawing Control," Rev. 6, October 25, 1984 GKN QCP Section 4, " Specification Control," Rev. 4, October 4, 1984 Phillips, Rev.          Getschow Co. (PGCo) QCP B-29, " Document Control,"

2, October 31, 1984 Pullman Sheet Metal Works Inc. (PSM) Quality Assurance Program (QAP) Section 86.1.F. " Document Control,'? Rev. 2 September 9, 1983 PSM QAP Section 83.2.F, " Drafting," Rev. O, July 22, 1984 (2) Ceco and contractor Quality Assurance (QA) audit and surveillance reports concerning design document control were reviewed for findings, trends and corrective actions. 1 (3) Ceco, S&L and contractor document control, engineering, construction and QA personnel were interviewed c.oncerning distribution, change documents. control and use of design documents and design i' VII-2 l , _ _ _ _ _ -------- ------- -- '- ~~

1 . l i

b. Insoection Findinas
(1) )

EL design documents and Engineering Change Notices I distributed by ML to Ceco, contractor and %L organ (izatio and personnel bution lists. in accordance with PI-88-29 and the ML distri-!! Field Change Requests (FCRs), which are Ceco ' j- design change documents, are distributed by the Ceco P

Constructionand organizations Department personnel. (PCO) to EL, contractor and CECO i

j (2) 4 CECO, ML and the contractors each control the redistribut

and use of design documents and design change documen their organizations in accordance with their separate and i different document control procedures.

design documents and design change documents is record p ' documents and design change documents ar (satellite) document control stations and the superseded revisions destroyed or stamped. Five of the six document control systems reviewed by the NRC CAT inspectors control the j { i annotating the design change identification n controlled copies of the affected design documents. i GKN has. recently revised their procedure to identify unincorporated i 1 design changes on a separate list, a copy of which is maintai i at each GKN document control station. ! (3) which other document control station recor i Typically, possible contractor discrepancie comparison to the design documents and i i in the Ceco PCD document control station. list (s), ECN status list and FCR status list are also used butT the data is not current since they are issued monthly and the input dates. issue data cutoff can be several weeks prior to the lists (4) The most prevalent and sustained deficiency identified in the QA audits and surveillances of the various document systems is incorrect annotating of design change documents. The majority of these deficiencies are ECNs ~and FCRs listed on design documents after the changes have been incorporated. The more serious deficiency is failure to list unincorporated , nation).changes on the design documents (possible lost infor-design this type of deficiency have been made in each document control programs. (5) Thefollowing the NRC CAT review discrepancies: of the ML Distribution Lists ident VII-3 t

       '                         a. The Mechanical Department Distribution List, Rev.19, and the Structural Department Distribution List, Rev. 24, do not have the total number of pages on each page. GQ-6.01 states, in paragraph 3.A.1, "All pages of the Project Distribution List shall contain the project number, revision number, page number and the total number of pa now revising the procedure to permit putting "ges. " S&L is        final"   on the last page in each list, which is consistent with current practice.

their l

b. The Structural Department Distribution List, Rev. 24, and I the Electrical Department Distribution List, Rev.19, do not identify the controlled copies. GQ-6.01 states, in paragraph 3.A.1, that the lists "...will identify the recipients of S&L drawings who are res taining controlled sets of drawings." ponsible S&L QA informed for main-the NRC CAT inspector that all design documents distributed in accordance with these lists are " controlled" copies.

(6) The NRC CAT inspectors reviewed about 150 S&L design documents at 3 LKC document control stations (Numbers 10, 19 and 28) for legibility, LKC date stamp, and other stamping (i.e. , "For Reference Only" and "For QC Use Only"). The revision numbers and ECNs/FCRs annotated were recorded for about 60 design documents and checked against the LKC Document Master Cards. No incorrect design document revisions were identified. At Station Number 28 (Quality Control) drawing 20E-2-3503, Rev. D was not stamped "For QC Use Only" in accordance with LKC Procedure 4.2.1 paragraph 6.2, and FCR-L-13419 was not anno-tated on S&L drawing 20E-0-3091H01, Rev. E, although it was listed on the Document Master Card. In addition, several cases were identified where ECNs/FCRs were still annotated on design documents when the Document Master Cards showed them in porated (i.e., ECN-22123 on drawing 20E-0-3393, Rev. AF). (7) About 50 design documents were reviewed for legibility and i stamping (i.e., " Controlled") at PGCo documen control station i Number 1 (Engineering Files), and the revision numbers and ECNs/FCRs annotated were recorded and checked against the Document Distribution Cards, hand-updated S&L ECN Status Report and PGCo FCR log. All design doctments were in accordance with the Document Distribution Cards, ECN Status Report and FCR log except where new design documents and design change documents had been received within about five working days. PGCo procedure QCP B-29 does not contain any time limit for replacing on design supersededdocuments. design documents or annotating ECNs/FCRs (8) About 30 of the design documents reviewed for revision number and ECN/FCR annotation were cross-checked against design documents in the CECO PCD document control station. Discre-l pancies were noted on about fifteen, mainly in the ECNs/FCRs I annotated on the design documents. Investigation showed that most discrepancies were due to different time lags in replacing VII-4

design documents and adding or deleting ECNs/FCRs on design documents.

        -                                                            Two ECNs, 23416 and 23486, were not annotated on Ceco PCD's controlled copy of. drawing 20E-0-3237E, Rev. A, due to a mis-understanding of a note on the ECNs.

Several ECNs/FCRs which had been incorporated were listed on design drawings (i.e., FCR L-14744 was listed on drawings M-820, Sheet 1, Rev. P; M-823, Sheet 2, Rev. H; M-823, Sheet 7, Rev. H). (9) Distribution of controlled copies of approved design documents and design change documents within contractor organizations is based control). positive on some form of receipt acknowledgement (i.e., However, distribution of design and design change documents by S&L and Ceco to contractors does not involve receipt acknowledgement. It is thus possible that a contractor may not receive certain documents and will not know that the documents have not been received. Although the contractors can check the project document status lists i (see paragraph 1.b(3) above) cross checking against these 1 listings is not generally a contractor procedural requirement, ! although it appears to be a requirement of Ceco QP 6-1. As an example, ECNs 22696, 23544, 23587 and 23620 had not been received by L. K. Comstock as of December 18, 1984; these ECNs had, however, already been annotated on S&L drawings 20E-0-3393T, Rev. H and 20E-0-3-393G, Rev. S by Ceco PCD. Ceco QA Surveillance Report 3450, March 16,1984, identified non-receipt of the latest revision of an S&L drawing by PGCo. (10) In general, the number of ECNs/FCRs not incorporated into design documents is small, particularly on electrical drawings for which responsibility (and the sylar originals) has been transferred to the S&L Braidwood site organization. As an example, S&L drawing 20E-0-3388 was revised and reissued on January 6, March 7, March 23, September 12 and October 10, 1984 and Rev. G, dated October 10,'1984 had no approved, unincorpo-rated ECNs/FCRs at the time of the NRC CAT inspection.

c. Conclusions i

For the sample inspected, the control of design documents is generally adequate. However, deficiencies in annotating ECNs/FCRs ce design documents have been previously identified by Ceco and contractor QA audits and surveillances and by NRC Regional and Resident Inspectors, and are still present in two of the three document control systems inspected by the NRC CAT.

2. Control of Desian Chances The specific aspects of the control of changes to design inspected
by the NRC CAT were the change control systems for ECNs and FCRs,

' and implementation and verification of the changes. I ( l VII-5 l

a. Inspection Scope (1)

The following changes were reviewed: procedures relating to the control of design Ceco QR 3.0, " Design Control," Rev. 15, August 15, 1984 Ceco QP 3-1, " Design Control," Rev. 5, October 5,1984 Ceco QP5,3-2, October 1984 " Design Change Control," Rev. 13, Ceco24, May PCD-02,1984 " Engineering Change Notices," Rev. O, Ceco PCD-03, " Field Change Request," Rev. O, June 15, 1984 S&L GQ 3.07, "Sargent & Lundy Drawings," Rev. 6, October 21, 1981 S&L GQ 3.08, " Design Calculations," Rev. 4, March 5, 1979 S&L GQ21, October 3.13 1981 " Engineering Change Notices," Rev. 6, S&L PI-88-13. " Procedure for Processin Comapny Field Change Requests (FCRs),"g Commonwealth Ediso Rev. 12, September 27, 1984 i S&L PI-B8-18, " Procedure for Handling Commonwealth Edison Company Field Change Requests Transmitting "As-Built" Information," Rev.1, May 7,1984 S&L PI-B8-23, Rev. 7, October"25, Byron /Braidwood Electrical Field Personnel," 1983 S&L PI-88-25, Group," Rev. O,"August Activities of the On-Site Structural Design 29, 1983 S&L PI-88-28, " Activities of the Byron /Braidwood Station Mechanical Engineering Piping Design, Support Design and Analysis Field Personne,l," Rev. 3, August 4, 1983 LKC Procedure Rev. A, April 27,4.2.3, 1983" Field Problem Reporting Procedure," , LKC Procedure 4.2.4, "As-Built Information Reporting Procedure," Rev. 8, August 20, 1984 GKN QAM Section III, " Design Control," Rev. 4, October 3, 1984 VII-6

GKN QCP 33, " Design Change Control," Rev. 5, f October 25, 1984

             '                                        PGCo Construction Procedure (PGCP) 1.1, " Control of                e Engineering Change Notices (ECN), Field Change Notices              i (FCN), Field Change Requests (FCR) and Field Problem Reports (FPR)," Rev. 9. May 31, 1984 PSM Procedure B3.1.F, " Design Control," Rev. 4, December 2,1983                                                     l (2) Ceco and contractor QA audit and surveillance reports concerning design changes were reviewed for findings, trends and corrective actions.

(3) Interviews were conducted with personnel from Ceco, S&L, LKC, l GKN, PGCo and PSM concerning initiation (origination), review, approval and implementation of design changes.

b. Inspection Findings i I

(1) S&L has approximately 500 people in their Braidwood site ~ organization, of whom about 400 are assigned in engineering l and design groups. The majority of the engineering and design personnel are engaged in resolving field problems by clarifying design documents and making design changes. > The contractors do no engineering or design; however, GKN,

PGCo and PSM prepare supplementary drawings / sketches from the S&L approved design drawings for use as aids in fabrication and construction. Generally such aids are prepared by the contractor field engineers an,d both contractor engineering and QC personnel review them for conformance with the S&L approved drawings. QC inspections of structures and hardware are to be made only from S&L approved design drawings. CECO and contractor QA audits and surveillances have identified discrepancies between these aids and the design drawings, but the discrepancies appear to be isolated programmatic failures.

(2) Design changes are accomplished through design change l documents such as FCRs, ECNs, Field Change Notices (FCNS) and t through revision of design documents without an intermediate design change document. FCRs are a Ceco design change document generally originated in the field by Ceco or contractor personnel and approved by both Ceco and S&L. ECNs l are an S&L design change document originated in the field or i 1 S&L's Chicago office and approved by S&L. FCNs are a - Westinghouse Electric Corporation (the Nuclear Steam Supply i System vendor) change document originated and approved by off-site Westinghouse personnel. i VII-7 ! i t

 -_, _ _       _ . _ . . _ _ __ ,_         _ _ ._ _          . . _ _ _        _   _ _ _ _ _ _ _ _ _                        l

i o

Roughly 40,000 FCRs/ECNs have been issued for the Braidwood Project.

An average of about 200 FCRs and 300 ECNs have been issued each month since June 1984, and the present trend is decreasing. (3) Problems, conflicts and items requiring clarification identified by the contractort in the approved design documents are fonvarded to S&L for resolution. When resolution requires a design change, an FCR, ECN or drawing revision is prepared and issued to the contractor. LKC and PGCo use Field Problem Reports (FPRs), GKN uses Framing Modification Field Problem Reports, and PSM uses Field Engineering Memoranda (FEMs). These contractor documents are generally not controlled or considered QA documents. (4) Approximately 600 ECNs and FCRs were selected and reviewed for procedural compliance, adequacy of problem description and resolution (design change). A number of minor procedural deficiencies and inconsistencies were identified: The FCR form differentiates between " major" and " minor" changes; the definitions are provided in Ceco QP 3-2, Attachment A. However, review of in process and completed FCRs and discussion with Ceco, S&L and contractor person - indicated that considerable variations exist in practice in determining what constitutes " major" and " minor" changes. In the sample of FCRs inspected by the NRC CAT, it appears that NCRs. structural FCRs were " Minor" even when resulting from HVAC FCRs were generally " major" even though an NCR was not involved. Some. piping FCRs were " Major", although

the stated reason for the change request is "S&L Drawing Clarification." Examples are:

FCR L-15823, November 16, 1984 FCR L-158830, October 9,1984 FCR L-14065, May 4, 1984 < FCR L-16152, November 29, 1984 i FCR L-16039, October 19, 1984 FCR L-16344, December 7,1984 ' i S&L's procedure PI-B8-13 does not differentiate between

                                         " major" and " minor" changes, and discussions with S&L

, personnel indicated that this designation is not considered in their processing of FCRs. Changes were made to FCRs (Part C and Part D) with 4 " whiteout" or by lining through previous information and

;                                       adding new information without dating and initialing the changed items. Examples are:

VII-8

t L-14665, June 22, 1984

     -                                 L-14893, July 20,1984 L-30651, March 24, 1983 L-30686, March 30, 1983 Although the CECO procedures reviewed do not prohibit
                             " whiteout" or require that all corrections on FCRs be initiated and dated S&L PI-BB-13, paragraph 4.8, states "Any changes or corr,ections made ... are to be circled and initialed. The person circling and initialing ... shall sign and date under Part C ...".       Failure to do so can result in concerns about when changes were made (prior to or after approval) and by whom they were made.

FCRs and ECNs are not stand alone documents. In general,

the descriptions of the design changes and the reasons for the design changes on FCRs are terse almost to the point of inadequacy, and extensive use is made of references to other documents, often superseded FCRs. FPRs and FEMs are referenced in the margins of FCRs, if at all, and the references are not required by procedure. Examples are

FCR L-13026, February 21, 1984 FCR L-16174, November 9, 1984 FCR L-20604, March 17,1984 ECN 7909, June 1984 ECN 0-00040, November 5, 1984 The " Request Class" blocks for " Limited Construction" or

                           " Plant Modification" and " Major" or " Minor" change were not checked on a number of FCRs.        Examples are; L-12041, December 14, 1983 L-13026, February 21, 1984                           ,

L-13062, February 23, 1984 L-14830, July 5,1984 l This appears to be inconsistent with the requirements of Attachment B to Ceco QP 3-2. (3) Several of the ECNs/FCRs reviewed in detail had the " Reason for Change Request" phrased so that it appeared an NCR should have been written, but none was identified. Subsequent investigation by Ceco QA determined that FCR L-16,127 dated November 15, 1984, described a discrepancy that should have l been identified on an NCR. PSM has now issued NCR BR-332 on this item. Other apprently isolated cases of inadequate attention to the reason for issuance of a design change are described in Section III.B.2.b. Ceco Site QA issued a memorandum on January 2, 1985 (BRD

                       #14,354) directing that all new FCRs be routed through Ceco VII-9

 "                                                     Site QA for review prior to filing. It is possible that this review will identify discrepancies such as whiteout, missing initials and dates on lined through changes, unchecked items and missing references to NCRs.

(4) FCRs/ECNs for which the work had been completed and accepted by contractor QC were selected for verification. Prior to inspection of the physical changes, the base design drawings, i applicable change notices and backup calculations and QC I inspection reports were reviewed by the NRC CAT inspectors. The physical changes associated with the following FCRs/ECNs ) were then inspected to verify that the changes were implemented as described. FCR L-14830, July 5, 1984 - The change required addition of a vertical member to an HVAC duct hanger and the acceptance of two existing, non-standard weld connections. The FCR resulted, at least in part, from NCR 460, January 31, 1983. Action on this change was acceptable. FCR L-30651, March 24,1983 and ECN 10202 (supersedes FCR L-30651) - The changes required modification of a pipe support and welded pipe attachment due to an uninstalled beam connection plate and an interference. Action on this change was acceptable. FCR L-11032, August 23, 1983 - The change required coping the top of a column to avoid interference from two pipes.

                  -                                           The actual copes and reinforcement plate were inaccessible 1                                                              due to application of fire protection material; however, interferences which would have existed between the beam, an 4                                                             electrical conduit and a copper pipe, if the copes had not been made, were identified.

FCR 14890, July 20, 1984 - The change required addition of a wingplate and concrete expansion anchor (CEA) to the baseplate of a blockwall column. The change resulted from a baseplate CEA which did not meet minimum embedment criteria, per NCR 213-799, June 12, 1984. Action on this change was acceptable. ECM 7944, June 26, 1984 - This change required a new connection detail for an electrical tray support brace. The physical installation was in accordance with the intent of the ECN. A discrepancy in the associated paperwork (incorrect orientation / numbering) was identified by LKC on NCR 3139, August 24, 1984. (5) The calculations for about 20 ECNs/FCRs were reviewed for conformance with applicable requirements (particularly S&L GQ 3.08). All the calculations were for changes to previously approved designs, and thus were in effect partial revisions to previous calculations. They consisted of both 4 l VII-10

e .

  '                                                    hand and computer calculations, involving mostly structural 1

attachments, core drilling and pipe supports / restraints. Examples are: FCR 14890, July 20, 1984 FCR L-30651, August 24, 1983 ECN 23843, December 7, 1984 The calculations in the sample inspected were prepared, checked and reviewed in conformance with procedural require-ments. They had been reviewed and approved prior to the approval date on the related ECNs/FCRs. Due apparently to varying standards between the S&L technical disciplines, page numbers, revision numbers, references to ECNs/FCRs and locations of signatures and dates were inconsistent, but adequate. No calculational errors were observed in the sample inspected. (6) The NRC CAT inspectors identified cracked and spalled diesel generator exhaust silencer foundations on both Unit 1 diesel generator installations, which appeared to be due to inadequate provisions for thermal expansion of the silencers. Discussions with CECO personnel showed that the cracked foundations had been identified on Ceco NCR 618, April 19, 1984. The NCR states " Original design did not allow for adequate thermal expansion." The deficiencies will be corrected in accordance with ECN 22326, August 17, 1984 which requires modifying / repairing the pedestals and anchor bolts, and ECN 22578, August 30, 1984, which requires modifying the slots on the exhaust silencer saddle plates for both longitudinal and lateral movement and adding plate washers. The ECNs apply to Braidwood Units No. I and 2. Subsequent discussions with S&L indicated that the pedestal spalling appeared to be caused by both lateral and longitudinal forces, the plate slots were partially flame cut and not ground smooth, and loose grout was found in the slots after the pedestal failures. The NRC CAT inspectors had observed that the bolted connections ' i between the embedded plates in the pedestals and the sliding end silencer saddle plates appeared to be too tight to permit movement for thermal expansion. If these connections were excessively tight at the time of the diesel generator tests, or the rough slots and grout interferred with thermal movements, the cracking could be attributed to incorrect installation as well as inadequate design. ECN 22886, September 14, 1984 which was written to resolve NCR 213-582 on the Letdown Heat Exchanger, also requires modifying the bolt slots on the sliding supports. Braidwood QA Sur-veillance Report 3305, January 9, 1984 states "... the foundation details as documented on drawing M-1221 sheet 2, Revision 5 were found to differ from those as installed."

,                                                    It appears that CECO should consider the possibility of a VII-11
    ,,   -,v-.      n- , , . . -,----w, -n,,,-,                 .,,,.c            .--,-,--,--wn.--,.,----,---._n

l I

 .                  generic problem in either or both design of supports for and installation of equipment requiring sliding connections for thermal expansion (see Section III.B.4.b for additional details).

(7) A pipe support was identified by the NRC CAT inspectors which had been installed and inspected in accordance with ECN 19783, October 25, 1984, written against support drawing 1RC01004V, Rev. D, although Rev. E. of the support drawing had been issued September 13, 1984. Rev. E of the drawing changed some physical items on the support, including the spring can size. Subsequent investigation by S&L identified the following addi-tional six previnusly unidentified supports for which ECNs had been issued against superseded revisions of pipe support drawings.

10G14005G
1AB22007R
1A822034X
10G14006X
1CV57001G
1RC04004V These discrepancies were stated by S&L to have occurred as a result of S&L Chicago modifying support designs due to analysis at the same time that the S&L site organization was modifying the supports to resolve field problems.

The discrepancies might have been identified and resolved when the final revision of the support drawing, incorporating all

     .           design changes, was issued prior to the final PGCo walkdowns.

S&L Braidwood Field Instruction (BRFI) 4 is being modified to prevent reocurrence of this problem. Discussions with PGCo personnel indicated that it is not uncommon for them to receive ECNs written against superseded support drawings. Such problems may be identified by PGCo to S&L by a FPR (i.e. , FPR G-2137, August 24, 1984).

c. Conclusions For the sample isoected, the control of the design change process is adequate.

Manag m nt attention is needed to preclude future design changes being astie to superseded design documents. VII-12

' VIII. CORRECTIVE ACTION SYSTEMS ' i A. Objective This Portion of the NRC CAT inspection was to verify through selected samples, whether measures were established and implemented to assure that nonconformances promptly identified and and other conditions adverse to quality were corrected. B. Discussions The method utilized to determine the adequacy of the applicant's corrective action program included selecting samples of documents for review. Some of the documents reviewed were: Trend Analyses Audits and Surveillances Stop Work Orders Nonconformances Corrective Action Reports Table VIII-1 " Corrective Action Samples", identifies the documents randomly selected for review for each major site contractor. The following procedures of active on-site contractors were the criteria to which these documents were evaluated: Phillips, Getschow Co.

Quality Assurance Manual, Section 15, Rev. O, September

                     " Control of Nonconforming Items, Material or Activities"27, 1984,

Quality Assurance Manual, Section 16, Rev. O, September 27 , 1984,

                    " Audits"

Quality Reports"Assurance Procedure (QAP)-12, Rev. 6, " Control of Nonconform
QAP-12.1, Rev. 6, " Internal Audits"
QAP-12.2, Rev. O, " Corrective Action Request"
QAP-110, Rev.1, " Reporting of Defects and Noncompliance"
Quality Control Procedure (QCP)-B27, Rev. 3, " Quality Control Mo
Phillips, Getschow Construction Procedure (PGCP)-1, Rev. 14, " Control of Field Change Orders" ;

1 I l VIII-1

'. l l ,~ L. E. Comatock & Company, Inc.

Procedure Program" 1.0.1, Rev. August 31, 1983, " Quality Assurance ontrol and
Procedure 4.11.1, Rev. F, " Nonconforming Items"
Procedure 4.11.2, Rev. C, " Corrective Action"
Procedure 4.11.3, Rev. A, "Stop Work"
Procedure 4.13.2, Rev. A, " System Completion / Turnover
Procedure 4.14.1, Rev. A, " Internal Audit Program" Pullman Sheet Metal Works Inc.
Procedure B16.1F, Rev. 3, "Non-Conformance/ Corrective on" Acti Pittsburah Testina Laboratory
Instruction Sheet,IS-BRD-22-UC, Rev. 2, " Unit Concept Instru ti c on"
QC-CRN-1, Rev. 4, " Control and Reporting of Non-Conformances" Gust K. Newbert Construction Co.
Quality Reports"Control Procedure, Section 15, Rev. 2 ,

                                                             "Nonconfo rmance Commonwealth Edison Company
                                                                                  '~ '

Procedure PM-02, Rev. O, "Stop/ Start Work Authority"
Quality Procedure 18-1, Rev.17, " Quality Program Audits"
Quality Requirement 18.0, Rev. 19, " Audits"
Quality Requirement 16.0, Rev. 16, " Corrective Action" The results licensee's of the review of these procedures were discussed with t personnel.

documents were selected to ensure specific measures ne for the control of corrective actions. Also, samples of specific nonconformances requiring actual correction of material / equipment wer identified in progress.and inspected to verify that corrections had been md a e or wet and 20 material / equipment samples were inspected actual corrective actions. l l l

VIII-2

t

1. Corrective Action Measures

a. Insmeetion Scope M e 229 corrective action document samples selected were examined i

for adequate corrective action, action to preclude recurrence, and verification of the effectiveness of the corrective action. Procedures for identifying and resolving conditions adverse to quality were reviewed for compliance to applicable codes and i standards.

b. Inspection Findinas The review of the procedures for implementing the corrective action system resulted in identifying the following procedural problems:

(1) The Phillip, Ge'schow Co. (PGCo) audit procedure did not require that the corrective action for audit findings be verified supplemental for effectiveness audits. nor did it address the scheduling of It was also noted that the PGCo procedure '

for trending nonconformance reports did not require verifica-

!_ tion trend. of the corrective action taken as a result of an adverse I (2) The L.K. Comstock audit procedure did not require the audit report to address the effectiveness of the elements audited and did not require verification of the effectiveness of correction action to audit findings. The elements of the applicant's audit program which included audit reports, schedules and follow-up to audit findings, were reviewed

 ,                                                                                             and determined to be comprehensive. These audits are identifying i

not only lack of Laplementation, but also programmatic problems, The examination of samples listed on Table VIII-I revealed the following concerns regarding corrective action: (1) Two nonconformance reports (NCR), issued by the electrical contractor, had improper corrective action: i (a) NCR 39, issued in April 1979, identified weld deficiencies in electrical struts and hanger assemblies. The supporting l documentation attached to the NCR identified that 90 percent of the welda associated with this NCR were unacceptable in accordance with AWS D1.1-1975. The cor-rective action block on the NCR was marked "N/A" and contained a statement identifying the welds as accept-able. There was no documentation supporting the conclusion stated in the corrective action block on the NCR. As a i result, L. K. Comstock has issued a NCR to reopen and resolve the deficiencies noted on NCR 39. i i VIII-3 i

(b) NCR 293, issued in May 1981, identified questionable welds on back to back B-line strut and spaced back to back strut.

   * '                The corrective action stated on the NCR consisted of reworking the welds on the back to back strut and returning the spaced back to back strut to the vendor. Inspection of installed spaced back to back strut by L. K. Coastock and NRC CAT inspectors identified numerous weld deficiencies.

Based on these weld deficiencies noted in the installed strut, it is apparent that the corrective action stated on NCR 293 was ineffective. (2) L. K. Coastock voided approximately 2.5 percent of the NCRs issued from October 1976 through December 1982 and approxi-mately 5 percent of the Inspection Correction Reports issued from May 1977 through July 1981. Ten of the voided documents were selected to determine if a documented justification existed. None of the ten sampled had a documented justifica-tion. In addition, four NCRs were voided by Phillips, Getschow Co. without a documented justification. (3) It appears nonconformances issued prior to 1983 and disposi-tioned "USE-AS-IS" or " Repair" were not routinely submitted to Sargent & Dandy for their review. An example is Gust K. Newberg NCR 469 which identified laminations in the embed for jet deflector. The embeds were repaired, but there is no objective evidence that Sargent & Lundy reviewed the repair.

2. Conclusions The applicant's corrective action program is generally acceptable except for those concerns noted above.

VIII-4

TABLE VIII-1 CORRECTIVE ACTION SAMPLES ITEMS QUANTITY EXAMINED Ceco PGCo LJK Others Total 4 3 4 2 13 Trend Reports 5 6 - 18 Site Audits 7 2 3 - 6 Corporate Audits 1 15 20 15 50 Inspection Reports -

                                                                               -     12 Surveillance Reports                12         -        -

Nonconformance Reports 10 18 11 20 59

                                                  -        10        -         -      10 9006 Inspection Correction 18           -      18 Reports Material Receiving 9      17          -      26 Reports Material / Equipment Samples for Field Verification of                                4         3       12 Corrective Action                     2         3 5        -          -          5 Conditional Releases                  -

TOTAL 36 70 83 40 229 Ceco = Commonwealth Edison PGCo = Phillips Getschow LKC = L. K. Comstock Other = Gust K. Newberg, Pullman. Sheet Metal and Pittsburgh Testing Laboratory VIII-5

IX. PROJECT MANAGEMENT

   -                                                                                                                l A. Objective The objective of the appraisal of the licensee's pro,iect management organization and construction controls was to determine if the project management organization was properly controlling the total project, maintaining quality control of construction and test activities to assure that construction activities were accomplished in accordance with regulatory requirements, codes, standards, specifications and licensee commitments.

B. Discussion To accomplish the appraisal of the project management organization approximately 25 members of the Braidwood Station project management organization were interviewed and project organization charts and managerial position descriptions were reviewed. The interviews and reviews were conducted to determine the project organization's prior nuclear construction experience, Commonwealth Edison Company (Ceco) management involvement in the project, adequacy of management reports and intercommunications, management awareness of industry problems, control of site contractors, and management and supervisory support of Quality Assurance and Quality Control activities.

1. Project Organization

a. Inspection Scope To review the project management organization and implementing procedures to determine that they are effective in monitoring and controlling the construction, startup, and quality activities to assure a quality end product in conformance with regulatory require-ments.

b. Inspection Findings Commonwealth Edison Company (CECO) is performing the function of project manager and construction manager of the Braidwood Station.

They have utilized this type of approach in the past for the con-struction of their nuclear units. There are approximately ten contractors performing discrete work at the site under the direction of the CECO Project Construction Superintendent. Sargent and Lundy (S&L) is the Architact Engineer for Braidwood and has a staff of approximately 450 engineers at the site performing field engineering and stress analysis. The activities of S&L Engineers at the site is directed and coordinated by the Ceco Project Field Engineer. CECO has structured their Braidwood organization essentially along project lines. The Ceco Manager of Projects is responsible for the activities and personnel required to design, engineer, construct, test and startup the plant. Ceco, as the licensee, represented by the Manager of Projects and the Assistant Manager of Projects acknowledge that they hold full responsibility for the design and construction of the project and for compliance with the applicable IX-1

I . , . regulatory requirements. The Chairman of the Beard of Directors of l Ceco has vested in the Manager of Projects the responsibility for construction of the plant. The Manager of Projects is located in Ceco headquarters, however, he allocates a significant portion of his time to the Braidwood project including time on site. Located at the site is his direct representative, the Assistant Manager of Projects, who is responsible for the daily direction and control of site activities. l Reporting to the Assistant Manager of Projects are the Construction 1 Superintendent, Startup Superintendent, Licensing and Compliance Superintendent and the Station Superintendent. l The ten site contractor organizations are directaid and coordinated in their activities by three discipline supervisors who work directly for the Ceco Project Construction Superintendent. The Ceco site QA organization is under the direction of the Assistant Manager of QA who reports off-site to the headquarters QA Manager who in turn reports directly to the Chairman of the Board of Direc-tors of Ceco. This reporting relationship provides the independence of the QA organization from the pressures of cost and schedule. The Assistant Manager of Projects has an organization of appr:xi-mately 160 individuals directly engaged in the direction and control of site construction and engineering activities. - Some observations made from management interviews, review of correspondence and reports are: The project management organization as a group have had significant prior nuclear construction experience.

The staffing of the project management organization appears adequate to contrci site activities.

The project management organization appears to be functioning adequately to direct and control site activities.

Functional' responsibilities that have been assigned to management personnel were in agreement with the organization charts and position descriptions and are understood by the personnel interviewed.
A cooperative relationship appears to exist among management in the various functional areas of the project.
The relationship between Ceco project management and site 4 contractor's management is defined clearly and is understood by both parties.
The CECO Project Training Supervisor to date has not exercised sufficient monitoring and coordination of site contractor training activities as determined from interviews with site

 !                                                             contractor training coordinators.

IX-2

(1) Manaaement Involvement st Braidwood By interviews, review of docupants and procedures the NRC

   -       CAT inspector was able to determine that CECO management at all levels was actively involved in the construction of the project and participating in the resolution of site problems. This was demonstrated by the following actions of Ceco:

The Chairman of the Board of Directors of Ceco inspects the site on an approximately monthly basis and receives first hand reports on critical project areas from the respective managers. The Chairman of the Board of Directors of CECO on an approximately monthly basis meets witn CECO executives and Sargent and Lundy executives for the status of Braid-wood engineering effort and resolution of problem areas. The Manager of Projects spends a significant portion of his time at the Braidwood site following construction activities. The Manager of Projects periodically makes a presentation to the Ceco Board of Directors reporting the status of construction at the Braidwood site. The Assistant Manager of Projects is assigned full time to the Braidwood site and is actively involved in site construction and quality problems and in their resolution. The Assistant Manager of Projects holds a monthly meeting with key Sargent and Lundy, Ceco and Westinghouse managers to determine the status and resolution of construction problems and quality issues in the areas of enginsering, construction, production, startup and operations. CECO is the construction manager for the Braidwood ! Station and under the direction of the Project Constrt.ction Superintendent and a staff of approximately 60 engineers directs, coordinates and monitors the construction activities of the site contractors. CECO is directly responsible for the pre-operational and startup testing of the unit and under the direction of the Startup Superintendent and approximately 100 engineers and technicians they are conducting the necessary pre-operational and startup tests. IX-3

i l l

CECO has a project field engineering group on site under the direction of a manager who directs a staff of approximately 17 CECO engineers and a Sargent and Lundy engineering group of approximately 450 engineers.

The Manager of Projects reports directly to the Chairman of the Board of Directors of CECO and there is frequent communication between them relative to site construc-tion status and problems. (2) Management Reports and Intercommunications The NRC CAT. inspector through interviews, report reviews, procedure reviews and observation determined whether construction reports and intercoerunications of the Ceco project management and contractor organizations were sufficiently detailed to reflect the status of activities and problems of the project. The reports listed below are those that are prepared and distributed to various levels of management: A monthly Projset Scheduling and Control report is prepared by the Manager of Projects and distributed to Ceco officers. The Ceco Board of Directors make an annual inspection of the Braidwood Station and receive a comprehensive report of project activities that is distributed to the Chaire and all CECO officers. The Assistant Manager of Projects issues a quarterly report to members of site management that essentially establishes construction and quality goals for the coming quarter. The Ceco Director of Nuclear Licensing issues a Monthly Activities Report that identifies inspection and enforcement highlights, NRC IE Bulletins, Notices and Circulars received during the month and graphs NRC noncompliances versus NRC inspection hours at the Braidwood Station. The Ceco Supervisor of Licensing and Compliance prepares and distributes a semi-monthly open item list that tracks NRC inspection findings. The site contractors transmit periodic production and quality issues reports to the Ceco Project Construction Superintendent and the Quality Assurance Manager. An NRC open items list prepared by the Byron Station is ' transmitted approximately twice a month to the Braidwood Station Supervisor of Project Licensing and Compliance. The Byron and Braidwood units are replicate units so that a review of the Byron open items can significantly reduce similar problems at the Braidwood Station. ' IX-4 {

 ,                      The site contractor's quality assurance managers and the Ceco Quality Assurance Manager meet approximately semi-monthly to review and discuss quality issues, problem areas and on going quality programs. Minutes of these

meetings are prepared and distributed.

The CECO Quality Assurance Manager prepares and distributes a weekly Open Item Progress Report to site management that identifies NRC violations, audit findings, nonconformances, contractors inspection deficiencies and CECO field change requests. This tracking is done to expedite the closing of these items within an appropriate time frame. The Assistant Manager of Projects prepares and distributes to the Manager of Projects and other members of management a monthly Regulatory and Quality Issues Status report that identifies and trends NRC Reports, audit findings, nonconfonsances, inspection deficiencies, and field change requests. The CECO Quality Assurance Manager issues a monthly activities report to the Corporate QA Manager. The Ceco Quality Assurance Manager prepares and distributes a monthly 60 day open audit item status report to the Assistant Manager of Projects. The purpose of this 1oport is to focus attention on the necessity for prompt closure of open audit findings. The Corporate Manager of Quality Assurance prepares and forwards to the Chairman of the Scard of Directors of Ceco an annual report of site quality assurance activities. (3) Management Awareness of Industry Construction Problems Through interviews, discussions, and review of documentation the NRC CAT inspector evaluated if Project Management was aware and participated in the resolution of nuclear industry construction problems. The inspector determined that the following associations, reports and methods were utilized to stay abreast of industry wide problems: Ceco is a participating member of the Westinghouse Pressurized Water Reactor and Steam Generator Owners Group. Various engineers in the CECO organization are committee and subcommittee meinbers who are actively engaged in the resolution of problems associated with pressurized water reactors and steam generators. IX-5

Ceco is a participating member of the Edison Electric Institute and has engineers as members of committees that actively deal with the resolution of problems and

               '                                                          interchange information relative to technical areas associated with nuclear power plants. Currently, CECO has membership on the Nuclear Operations Committee, Fire Protection Committee, Quality Assurance Committee and Metallurgy and Piping Committee among other committee participation.

CECO supports research efforts of the Electric ' Power Research Institute and has individuals assigned to the various committees and task forces of certain of the ongoing activities associated with nuclear power plants. CECO is a member of the Institute for Nuclear Power Operations (INPO), participates in their various programs and provides on-loan employees to participate in INP0 activities. Through various INPO audits, reports and information interchange they become cognizant of nuclear construction and equipment problems. CECO is a member of the Quality Assurance Committee of the Nuclear Construction Utilities Group that meet periodically to interchange information and resolve problems relative to quality issues at nuclear power plant construction sites. CECO receives periodic Westinghouse Nuclear Service Division Technical Bulletins reporting on problems with equipment provided by Westinghouse. CECO receives, analyzes, and institutes corrective action where required for NRC IE bulletins, circulars and information notices. CECO, within the last six months, has instituted a Lessons Learned Task Force that identifies generic problems at the Byron Station and applies them to the Braidwood Station so as to avoid as much as possible similar problems occurring at Braidwood. Byron r*.d Braidwood are replicata units so that many identified problems at Byron can be avoided or minimized at Braidwood because Byron is in a later construction stage. l There is also a Startup Task Force and Fire Protection Task Force that takes problems identified at Byron in these areas and determines applicability and corrective action required at the Braidwood Station. (4) Control of Site Contractors Ceco has the responsibility for construction management at the Braidwood site. The Project Construction Superinten-IX-6

I 1

 ;                   dont has a staff of supervisors and engineers in each discipline that coordinate and direct the activities of the site contractors.

At the present time there are ten contractors at the site performing safety-related work. < These contractors are working under their own Ceco approved construction j procedures and Quality Assurance Programs. Each of the

contractors have their individual QA/QC organizations which

( conduct surveillances, inspections and audits of their respective work. The Ceco construction department also conducts surveillances of contractors work perfomance. In

addition, Ceco QA conducts surveillances and audits of the contractor activities.

I There is reporting to CECO Quality Assurance the Pittsburgh Testing Laboratory (PTL) that acts as an independent test agency for QA. This test agency overinspects a percentage of the work conducted by the contractors to give an ; additional level of assurance as to work quality. The PTL organization is also assigned certain core activities by CECO in the area of nondestructive examinations, concrete testing, structural steel bolting and testing of concrete 6 expansion anchors. Sargent and Lundy has an engineering force of approximately 450 engineers on site under the direction of the Ceco Project Field Engineering Manager. The work of these engineers is audited by the Ceco headquarters Quality Assurance organization and the site QA organization. ' The following observations were made of Ceco's control of site contractors: The QA/QC organizations of the site contractors were essentially fully staffed in budgeted positions and further their staffings were periodically reviewed to determine adequacy as construction progresses. Table IX-1 lists the licensee and contractors QA/QC organiza-tions. At the present time there are approximately 2500 crafts performing work at the site. There are approximately 360 employees of the Ceco and the contractors engaged in quality assurance activities. There appears to be a satisfactory ratio of QC inspectors to craftsmen. The site contractor QA/QC managers indicated they have access to upper management and freedom to express their concerns and implement corrective action if necessary. The CECO and contractor site QA/QC organizations appear to be independent from the pressures of construction cost and schedule. IX-7

Trending information generated by the site contractors is reviewed by the Ceco Quality Assurance organization and the contractors QA organization.

I The CECO site QA superintendent holds semi-monthly l meetings with the site contractors QA/QC supervisors to i discuss and resolve quality issues. Meeting minutes of the November 27, 1984 meeting were reviewed and items discussed included inspector recertification, hold /

witness points and the reinspection program. The CECO Quality Assurance organization requires the princi' pal contractors to conduct trend analyses of all deficiency reports and submit an analyses of trends in a quarterly report. Included in the report, when necessary, are actions to be taken for any identified adverse trends. Four recent reports of the principal i contractors were reviewed and it was determined that some of the contractors were submitting data for quarterly periods but not including data for prior quarterly periods so that meaningful trend information could be determined. Further it was determined that , some contractors were not trending deficiencies deter- l mined from the PTL overview inspections and that one j contractor, G.K. Newberg, was not trending first Ic QC inspection deficiencies. Another contractor, Pullman Sheet Metal, trends weld rejects as a percentage of Correction Notices rather than a percentage of welds inspected. Further it treats weld rejects in such a broad context that it is not possible to make a meaningful trend analysis. The Commonwealth Edison QA audit schedule for 1984 was examined by the NRC CAT inspector and it was determined to contain a schedule of approximately 75 audits to be implemented over the course of the year. These scheduled audits covered all the applicable criterion for specific contractors. It was determined the schedule included all the applicable site contractors. Random audits were selected for review and they determined to have been implemented in accordance w specific check lists relative to the specific area being ' inspected. The reviewed reports were found to have been issued in a time frame as required by procedure. The response to audit findings, corrective action and follow-up confirmation was reviewed for a sample of audits and was evaluated to be acceptable. CECO was l found to be performing audits in agreement with their audit procedure. Contractor craft training was reviewed with the training ! coordinators of the four principal contractors. It 1 appeared that with some of the contractors the training was primarily for new hire orientation and indoctrination and for construction procedure revision. There appeared . IX-8

to be a lack of training schedules and programs to igrove craft workmanship.

          '                                  The control of measurement and test equipment for the site contractors Phillips Getschow, G. K. Newberg, L. K.

Comstock and Pittsburg Testing Laboratories was reviewed. t Procedures, calibration certifications, out of tolerance t reports, corrective actions and the physical equipment was reviewed. In L.K. Coastock's crib no. 4 in the Auxiliary Building, two portable weld rod carriers were identified with calibration stickers indicating they were beyond their calibration due date. In the G.K. Newberg fabrication shop, three portable weld rod carriers were located that did not have any identifying calibration stickers nor hold tags. A log entry for one of the carriers indicated it had been taken out of service. A CECO QA audit in 1984 had previously identified a number of deficiencies in both L.K. Comstock and G.K. Newberg control of measurement and test equipment

                                         ' programs and both contractors were in the process of taking corrective action.

Craft performance and effective contractor first level quality control inspections need improvement. As documented in Section III of this report, numerous pipe support / restraint deficiencies were identified by the NRC CAT inspectors that indicated poor craft performance and inadequate contractor quality control inspections. In Section IV of this report, the CAT inspectors identified numerous deficient welds in the areas of electrical supports, instrumentation supports and structural steel that had not have been identified by first level contractor quality control inspectors. l Table IX-1 lists CECO and site contractors and the work each is performing. In addition, the table indicates the number of craft workers, the size of the QA/QC staff, the existence of QA/QC organizational independence, the presence of QA/QC supervisory position descriptions and if there is periodic review of the contractor's QA program. (5) Menacement and Supervisory Support of QA/QC The NRC CAT inspector conducted interviews and discussions with Ceco and contractor QA/QC management, engineers, auditors and inspectors to determinc if CECO is committed to the support of quality assurance efforts to build a quality plant. The following observations were made: IX-9

Ceco has initiated and is implementing a Quality First program to resolve employee concerns relative to plant construction. It is planned to have a " hot line" program in effect so employees can readily communicate their concerns. The programs appears that it will be effective in resolving employee concerns but at the time of the inspection the inspector could not find a policy statement by senior Ceco management that they encourage employees to support the program. In addition to the policy statement, the program should include Ceco and Sargent and Lundy headquarters personnel working on the project and a procedural requirement that quality i concerns be investigated by an organization independent of the area of concern. The staffing of Ceco and contractor's QA/QC organizations appears to be adequate for their existing responsibilities. CECO and contractor QA management personnel are actively involved in site construction activities and in the chain of pertinent communicaticn channels for construction. The Ceco QA personnel are experienced and qualified personnel indicating management commitment to the overall QA program. The QA managers of CECO and the contractors do have access to senior management when the need arises. Ceco and contractor QA managers are of the opinion tna; they do have senior management support, when justified in their disagreements with construction personnel. Within the past six months CECO has created and filled a new position, Assistant Manager of Quality Assurance, to strengthen the QA organization. Ceco is utilizing the PTL organization to conduct a series of over inspections of installed QC inspected installations and equipment to give an added measure of confidence for quality construction.

c. Conclusions The Ceco overall project management effort is evaluated to be satisfactory to complete the project in conformance with quality requirements. The senior management of Ceco has integrated a qualified, competent team that work in unison to reach a common objective. The management structure and accountabilities are essentially in agreement with the organization charts and position descriptions.

IX-10

Ceco management involvement at Braidwood is comprehensive and the reports and intercommunications amongst the various site organizations appears satisfactory. CECO and project management have made a determined effort to stay informed about industry construction and equipment problems and are well represented in various industry and utility groups attempting to resolve such problems. At all levels of project management and contractor management interviewed there appeared to be management support and the recognition for the need of a strong and comprehensive Quality Assurance / Quality Control effort to assure quality construction. A senior management notice endorsing the Quality First Program was not evident to the NRC CAT inspector. At the latter portion of the inspection a draft policy statement was in the Ceco review process. The area of project management that requires additional attention and improvement is the control of site contractors. Improvement is necessary in the area of contractor deficiency trending and craft and quality control inspector training. In addition, improvement is required in some of the contractors control of measurement and test equipment. l 1 ( IX-11

TABLE IX-I LICENSEE AND SITE CONTRACTORS QA/QC Perii Services Craft QA/QC QA/QC Supv. Revi. Organization Performed Workers Staff Org. Ind. Pos. Des. of Q, Ceco Licensee N/A 64 Yes Yes Yes CB&I Tank 5 1 Yes Yes Yes Repairs L.K. Comstock Electrical 465 84 Yes Yes Yes P. Getschow Piping 1169 158 Yes Yes Yes Midway Coatings 31 3 Yes Yes Yes G. K. Newberg Concrete 560 17 Yes Yes Yes Nuclear Installation Services NSS 3 2 Yes Yes Yes Pittsburgh Testing Laboratory Testing +94 2 Yes Yes YEs Pullman Sheet Metal HVAC 198 28 Yes Yes Yes V.S. Wallgren Masonry 46 * * *

Westinghouse Technical 6 # Yes Yes YEs Services

         * - V.S. Wallgren - Working under G. K. Newberg QA Program
         # - Audited by Westinghouse - Pittsburgh
         + - Testers IX-12 t,W

i l ATTACHMENT A A. PERSONS CONTACTED The following list identifies applicants representatives and NRC personnel present at the exit meeting, applicants discipline coordinators for each area, and individuals contacted during the inspection.

1. Exit Meetina Licensee P. L. Barnes J. F. GudaK D. A. Boone R. M. Preston T. F. Hallaren T. E. Quaka R. L. Byers J. Hawkinson D. L. Cecchett C. W. Schroeder D. L. Jones B. Shelton A. J. D' Antonio N. N. Kaushal W. J. Shewsi J. D. Deress L. M. Kline T. W. Simpkin R. J. Farr R. D. Kyrouac D. H. Smith D. L. Farrar R. C. Lemke N. P. Smith E. E. Fitzpatrick T. Maiman R. E. Spence J. W. Gieseker D. M. Mathew E. D. Swartz M. A. Gorski C. A. Mennecke H. L. Vener C. Gray J. J. O'Connor M. Wallace G. L. Groth G. M. Orlov Contractors T. Brooks J. A. Hite G. Minor J. Carlsen G. Jones T. D. Morrow W. L. Chase J. Klena J. M. Murphy D. Craven L. J. Koch C. Novak I. Dewald K. Kostal T. O'Connor W. H. Donaldson P. P. Lantermo A. Rodds R. Donica R. Lauer F. Rolan S. Forbes R. Lawler R. Seltmann K. J. Fus R. Leigh D. Stegemuller D. A. Gallagher D. L. Leone J. Stewart G. Gorski D. M. Mathew R. Voss D. Grant NRC and Consultants R. M. Compton W. S. Marini D. C. Ford E. Y. Martindale W. Forney L. McGregor G. B. Georgiev T. K. McLellan E. G. Greenman J. I. Nemoto R. F. Heishman R. D. Schulz K. R. Hooks R. E. Serb P. Keshishian W. J. Sperko W. J. Kropp S. R. Stein O. Mallon R. F. Warnick AA-1 i

l

2. Applicant's Coordinators Area Name Project Licensing & Compliance Supt. Chuck Schroeder I and Ceco CAT Coordinator Supplies & Gary Watts Support Services Project Construction Superintendent Dan Shamblin Structural Area (Ceco) Clif Gray GKN Rick Domica Midway Rich Leigh VSW Al Stein Mechanical Area (Ceco) Mike Gorski PGCo Jim Murphy NISCO Clay Novak HVAC Area (CECO) Ken Kroft PSM Dave Grant Electrical Area (Ceco) Larry Tapella LKC Bob Seltman Housekeeping and Preventive Maintenance Area Dave Boone Administrative Services Area Jim Brylka Site Q.A. Superintendent Tom Quaka Welding / Radiographs Tony D' Antonio Pittsburg Testing Lab Fred Forrest ANSI 45.2.6 Dick Spence Project Field Engineering Warren Vahle Sargent & Lundy Ke7 Kostal Project Operating Joe Jasnosz Project Start-up Hank Zimmerman Project BCAP Howard Vener Quality First Ray Preston AA-2

3. Braidwood and Licensee Corporate Personnel Interviews

P..Bertain G. E. Groth J. Carlsen R. Schoults T. Halloren R. Seltmann D. Cteven L. Kline I. Dewald W. Shewski P. Lantermo N. Smith J. Dominique C. Mennecke R. Donica W. Szuberal D. Niebaum R. Farr J. J. O'Connor C. Tomashek E. E. Fitzpatrick N. Tomis T. O'Connor V. Trickle S. Forbes R. Preston F. Forest W. E. Vahle )

D. Gallagher T. Quaka M. Wallace C. Reynolds E. Wendorf D. Grant F. Rolan C. Gray R. Wolfer C. Schroeder In addition to the above personnel, numerous other inspectors, engineers and supervisory personnel were also contacted. AA-3

   . B. Documents Reviewed The types of documents listed below were reviewed by the inspection team members to the extent necessary to satisfy the inspection objectives stated in Section I of this report. References to specific procedures, specifications, and drawings are contained within the body of the report.

1. Final Safety Analysis Report; 2. Quality assurance manuals
3. Quality assurance procedures: 4. Quality control inspection procedures; 5. Administrative procedures; 6. General electrical construction installation procedures; 7. General electrical installation specifications; 8. General piping installation procedures; 9. General piping specifications; 10. General mechanical installation specifications; 11. General concrete specifications; 12. As-built drawings; 13. NDE procedures; 14. Personnel qualification records; 15. Material traceability procedures; 16. Procedures for processing design changes; 17. Procedures for processing field change requests; 18. Procedures for controlling as-built drawings; 19. Procedures for processing nonconformances i

AA-4

o ATTACHMENT B

                                                                    ,                                             GLOSSARY OF AB8REVIATIONS l

AECN Advanced Engineering Change Notice AIEE American Institute of Electrical Engineers AIR As-built Information Report AISC American Institute of Steel Construction ANSI American National Standards Institute ASME American Society of Mechanical Engineers ASTM American Society for Testing and Material AWG American Wire Gage BCAP Braidwood Construction Appraisal Program CAT Construction Appraisal Team CEA Concrete Expansion Anchor CB&I Chicago Bridge and Iron Company Ceco Commonwealth Edison Company CMTRs Certified Material Test Reports CSCR Cable Separation Conflict Report ECN Engineering Change Notice FCN Field Change Notice FC0 Field Change Order FCR Field Change Request FPR Field Problem Report FSAR Final Safety Analysis Report GKN Gust K. Newberg Construction Company GQ General Quality Assurance Procedure HVAC Heating, Ventilating and Air Conditioning ICR Inspection Correction Report IE Office of Inspection and Enforcement IEEE Institute of Electrical and Electronic Engineers INPO Institute of Nuclear Power Operations IPCEA Insulated Power Cable Engineers Association ISI In-Service Inspection , LKC L. K. Comstock & Company, Inc. ! MCC Motor Control Center l MTV Material Traceability Verification , NCR Nonconformance Report ! NDE Nondestructive Examination i NISCO Nuclear Installation and Services Company NRC Musteer Regulatory Commission NRR Office of Nuclear Reactor Regulation l NSCI Napoleon Steel Contractors, Inc. I NSSS Nuclear Steam Supply System PCD Project Construction Department PGCo Phillips, Getschow Company ( PGCP Phillips, Getschow Construction Procedure PSM Pullman Sheet Metal Works, Inc. 4 PTL Pittsburg Testing Laboratory QA Quality Assurance l AB-1 l

                                                          . - - , - - - - - - - , - - - - - - - , - - - ~ - - - -               - - - - - - - - - - - - - - - - - -

QAM Quality Assurance Manual . QAP Quality Assurance Procedure QC Quality Control QCP Quality Control Procedure QP Quality Procedure QR Quality Requirements RG Regulatory Guide SAR Safety Analysis Report S&L Sargent and Lundy Engineers A8-2

 'M      ,\

1p1 831913

                                                                                                     \
    ,_       JUDrrn A. DORSEY LAW OFFICES 1815 WAINUT ST SUITE 1632 Pmr.2nELPEIA. PA.19107 31s Tsa.7soo April 12, 1983 Judge Lawrence Brenner Atomic Safety and Licensing Board
                .U.S. Nuclear Regulatory Commission Washington, DC 20555 l

j Judge Richard'F. Cole i Atomic Safety and Licensing Board , U.S. Nuclear Regulatory Commission Washington, DC 20555 Judge Peter A. Morris Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555 Re: Docket Nos. 50-352, 50-353 Limerick Generating Station Gentlemen, Please find enclosed the specifications of conditionally admitted contentions, as well as new PRA contentions, per the Board's February 10, 1983 Memcrandum and Order.

            '           Also included in the enclosed material is the newly specified contention VI-1, of Frank Romano.

Sincerely, e J cith A. Dorsey 4 4 Charles Elliott Counsel for Limerick Ecology Action xc: Service list attached. ( ATTACHMENT "C"

                    .= ._                                   -.

VI. QUALITY ASSURANCE / CONTROL VI-I. (ROMANO) Applicant has failed to establish and carry out an adequate quality assurance program as required by Appendix B of 10 CFR Part 50. This is shown by a pattern of careless workmanship, departure from specified procedures, and faulty inspection and supervison in the construction of Units 1 and 2 of the Limerick

            . Generating Station. The lack of-quality assurance during the construction of the Limerick reactors increases the risk of an accident during operation, and thereby threatens the health and safety of interVenors and the public.          BASIS:

a)' Established QA procedures ,in 1976 were insufficient-to assure that welding of structural steel was accomplished in accordance with applicable welding ccde specifications. Specifically, , the weld procedure for limited access welds had not been qualified, nor had the welder. NRC inspection of the welds, upon discovery of the faulty procedure, revealed that they in fact did not comply with applicable " workmanship" cede require-ments, in spite of the fact that a Bechtel Power Corporation quality control inspector had verified their quality in QA records. The applicant's response to the Notice of Violation stated that all faulty welds that were still accessible had been re-paired. Applicant is unable to assure that faulty welds that were

    '       'not a'ny longer accessible for repair, do not in fact affect the i integrity of the steel structures in question, and therefore

2. .

( the health and safety of the public. IE Inspection Report No. 50-353/76-06, Notice of Violation, and Applicant response.

b. The following infractions and items of noncompliance are indicative of the pattern of inadequate QA/QC. Correction of infractions and items of noncompliance is irrelevant to the hactthatsuchapatternexists. Training programs instituted in response to notification of violations should have.been and should be implemented to prevent violations, rather than imple-menting them after the fact.

1. Failure to properly inspect limited-access welds; failure of QA inspection to verify conformance with job specifications; failure.

t to implement document control requirements of a job rule. IE Inspection Report No. 50-353/76-06, Notice of Violation, and applicant response.

2. Failure to implement cleanliness control require-ments, resulting in CRD penetrations imprcperly covered and weld ends containing dust, particulates, and paint overspray; failure to maintain reinforc-ing steel clearances in Class I seismic structure; Yailure to implement nonconformance control system in construction of containment drywell walls with nonconforming cement. IE Inspection Report No.

50-352/76-09 and appiclant response.

3. Failure to provide adequate control of weld-related sampling inspections (audits) ; failure to control weld temperature in area that could result in

( damage to nearby electrical penetration assemblies. IE Inspection Report 50-352/80-21.

3.

*k

4. Welding documents for control room consoles contained references to obsolete design criteria; -

other obsolete quality control acceptance criteria were referenced on quality control inspection records (QCIR's); failure to provide quantitative or qualitative criteria to ascertain acceptability of weld-related sampling inspection (audit) program. IE Inspection Report No. 50-352/80-08.

5. Failure to construct plant in conformance with approved engineering specifications, drawings and procedures -- unauthorized joint end preparations .

on reactor recirculation piping and unacceptable weld undercuts on feedwater pipe restraint. IE Inspection Report Nos. 50-352/80-20 and 353/80-18 (combined) and Notice of Violation. l

6. Comment in Combined Office of Inspection and En- .

forcement Management Meeting Report Nos. 50-352/81-03 and 353/81-03: "The discussion stressed the singular ! area of concern, the implementation of subcontractor QA programs." The attached Evaluation Report 4 cover-ing Oct. 79 to Oct, 80) sited 6 QA violations or

            ~                                        infractions and 2 deficiencies for Unit 1. It was further stated: "QA-Due to nature and number of noncompliances ag'ainst subcontractors, increased inspections of this singular area is (sic) planned."

7. Failure to implement nonconformance control system (failure to use nonconformance reports); QCIR ,

did not reflect the failure to repair concrete imperfection within time limits stated in job

4.

-(

specifications. IE Inspection Report No. 50-352/ 81-01, 353/81-01. '

8. Failure to follow core drilling procedural controls; failure to follow valve storage procedures; failure of program for control cf rebar cutting to assure adequate control of activities. IE Inspection Report No. 50-352/81-04, 353/81-04.

9. Failure to carry out holdpoint inspections on full penetration groove welds. IE Inspection Report No. 50-352/82-03, 353/82-02.

10. Failure to correct welding inadequacies; unacceptable undercuts in welds. IE Inspection Report No. 50-352/81-06, 353/81-05.

11. Failure to control issuance of documents affecting quality, including changes thereto. IE Inspection Report No. 50-352/82-16.

Intervenor is unable at this time to provide further specificity for this contention, due to:

1. Failure of applicant to supply certain documents requested during informal discovery. For instance, intervenor requested copies of all correspondence between the NRC and applicant (or contractors) related to weld infractions.

Certain inspection reports and related correspondence known to exist have not been provided (or not properly identified in the large volume of documents produced

in applicant's discovery document room so that intervenc k'

could locate them).

2. Refusal of Bechtel Power Corporation, prime PECO

5.

 . -{ .

contractor, to produce information and documents

unless subpoenaed. -

3. Loss in mail of one of intervenor's two Sept. 3, 1982 written discovery requests to applicant. (Other parties on the service list received it.) Having not received a response to the request, intervenor sent applicant a copy of the request on March 2, 1983, at which time applicant stated that it.had not been previously received.

Applicant is in the process of responding to this request. Intervenor requests that he be allowed to further specify his QA/QC contention at a later date, based upon further dis-covery. QA/QC at Limerick is an important issue, particularly in light of recent allegations by engineers accusing Bechtel Power Corporation of sloppy, unsafe cleanup of TMI, and in light of serious QA/QC problems that have come to light con-

cerning Bechtel's performance at the Midland site. Na NOTE: Marvin Lewis intends to discontinue his participation

in the QA/QC contention, due to the fact that NRC rules and regulations do not provide for, adequate protection of confidential sources. Mr. Lewis requests that he be given the opportunity to address the Board concerning this matter at the May 9 conference, and also requests that the Board give serious con-(s sideration to providing the protection necessary for Mr. Lewis i to raise QA/QC deficiencies of which he has knowledge, in this proceeding.

      . f ** a ,                                                                          (* Q     '

UNITED STATES

 ^ 7'*[     #           %o,t.

NUCLEAR REGULATORY COMMISSION 3*

                          .. tI                            REGION 111 d                                                   799 ROOSEVELT ROAD
                   *      ,[                        GLEN ELLYN. ILLINots 50137 FEB     2 1983 Docket No. 50-456 Docket No. 50-457 Commonwealth Edison Company ATTN:    Mr. James J. O'Connor President Post Office Box 767 Chicago, IL 60690 Gentlemen:

This refers to the routine safety inspection conducted during the period April 19 through July 20, 1982, and the special inspection conducted on September 8-10, 1982, of activities at Braidwood Station, Units 1 and 2, authorized by NRC Construction Permits No. CPPR-132 and No. CPPR-133. The results of the inspections were discussed during an enforcement conference conducted at tne NRC Region III office on August 31, 1982, and at the Commonwealth Edison Company corporate offices in Chicago, Illinois on November 19, 1982. The reports setting forth the results of the inspections (, and the enforcement conferences are enclosed. In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days of the date of this letter. Such application must be consistent with the re-quirements of 2.790(b)(1). If we do not hear from you in this regard within the specified periods noted above, a copy of this letter and the enclosed inspection report will be placed in the Public Document Room. A separate letter is enclosed that sets forth certain matters of concern and the items of noncompliance found during these inspections. The responses directed by this letter are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

                                                                     "D" ATTACHMENT                                ,

m. W - Commonwealth Edison Company 2 FEB 2 1983 We will gladly discuss any questions you have concerning these inspections. Sincerely, CL b -

                                                          - k k' ~i r

((JamesG.Keppl Regional Administrator

Enclosure:

Inspection Report No. 50-456/82-05(DPRP) and No. 50-457/82-05(DPRP) cc w/ enc 1: Cordell Reed, Vice President . Louis O. De1 George, Director of Nuclear Licensing V. I. Schlosser Project Manager R. Cosaro, Project Superintendent J. F. Gudac, Station Superintendent DMB/ Document Control Desk (RIDS) Resident Inspector, RIII ! Karen Borgstadt, Office of Assistant Attorney General Michael V. Hasten, Chairman Illinois Commerce Commission Neil Hartigan, Attorney General i l l l

        ~ **          *

. i. ,

     .s      .

U.S. NUCLEAR REGULATORY COMMISSION REGION III Reports No. 50-456/82-05(DPRP); 50-457/82-05(DPRP) Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Station, Units I and 2 Inspection At: Braidwood Site, Braidwood, IL Inspection Conducted: April 19-23, May 11-18, June 21-25, July 12-20, and September 8-10, 1982 Inspectors: L. re 2 -[ bw tv V. J. Key 4p3 (September 8-10, 1982, only)- Approved By: D. W. ay s, Chie 2-[ Reactor Projects Section IB

                                ,6 ,/ .- ' .                                       ,

D. H. Danielson, Chief Materials and Processes Section Inspection Summary Inspection on April 19-23, May 11-18, June 21-25, July 12-20, and September 8-10, 1982 (Reports No. 50-456/82-05(DPRP); 50-457/82-05(DPRP)) Areas Inspected: Licensee actions on previously reported items, observation of containment post-tensionsing work activities, observation of electrical cable installation, review of electrical drawings, observation and review of site activities related to concrete placement, inspection and review of steam generator final setting activities, observation of weld rod control require-ments, follow-up inspection and resolution on bullet resistant fire doors, follow-up on vital information received from a concerned citizen, and an independent inspection and review of licensee's activities relative to the installation and inspection of Nuclear Steam Supply System and other mechanical , safety-related equipment. This inspection involved a total of 264 inspector-hours onsite by the resident NRC inspector, including 64 inspector-hours onsite during of f-shift hours, and 24 inspector hours by a Regional based inspector. e J

Results: Of the areas inspected, three apparent violations were identified - failure of the licensee to implement a quality assurance program for the erection of enchanical safety-related equipment (Paragraph 3.e and 3.e(1)(7)), failure to issue a construction deficiency report (Paragraph 3.e), and failure to ensure protection and preservation of safety-related materials and equipment (Paragraph 3.h). s 2

 '.4  .      .

a 4

SECTION I Prepared By: L. G. McGregor Reviewed By: D. W. Hayes, Chief Projects Section IB DETAILS

1. Persons Contacted Commonwealth Edison Company (CECO)

                   *R. Cosaro, Site Construction Superintendent
                   *J. Merwin, Site Lead Mechanical Engineer
                   *T. R. Sommerfield, Site QA Superintendent C. D. Gray, Project Structural Supervisor S. C. Hunsader, QA Supervisor R. C. Schleiter, Administrative Assistant Napolean Steel Contractors Incorporated (NSCI)

V. Sawyer, Superintendent C. . . . ada, QA Manager Pittsburgh Testing Laboratory (PTL) S. L. Bank, QA Supervisor i P. K. Leahy, C.M.T. Supervisor L. K. Comstock and Company (LKC) L. Facchina, Project Manager R. A. Brown, Sr. , QA Manager Phillips, Getschow Company (PG) R. Myers, Construction Superintendent ' D. Ortez, Area General Foreman A. Robino, QA Supervisor

Denotes those personnel attending the exit interview.

The inspectors also interviewed other licensee personnel including members of the Engineering and Construction staffs.

2. Licensee Actions on Previously Reported Items (Open) Item of Noncompliance (456/78-06-02; 457/78-06-02): Chloride

! fon concentration in concrete batching water exceeded 250 ppe chloride. The requirement for chloride consentration is stated in plant construc- - tion contract Specification L-2722 and Section 3.307.1 and CC 2223 of 3

+ ASME Boiler and Pressure Vessel Code Section III, Division 2 and was exceeded during the placement of concrete for Containment Buildings No. I and 2. The inspector discussed this with the licensee and with Region III personnel (July 23, 1982) with regard to the disposition and i any necessary corrective actions. Region III is requesting the licensee to obtain concrete core samples from each containment building and submit i these samples to an independent testing laboratory for chloride concen-tration tests. A final decision is pending-the test results. l (Closed) Open Item (456/80-09-03; 457/80-09-03) CECO QA department failed to audit the meteorological contractor, Murray and Trettle, Inc. !, The inspector reviewed CECO QA records which indicate the licensee is i performing monthly checks on the meteorological contractor. 4 The contractor is performing the following required checks:

a. signs of vandalism

b. guy lines intact

c. remote visual inspection of the tower

d. temperature and dew point recorder operating

e. wind speed and director recorder operating

f. all necessary power is on 3 the HVAC system is on and operable

h. housekeeping

1. security of the area This matter is considered resolved.

3. Functional or Program Areas Inspected

a. Observation of Work Activities - Containment Post Tensioning (1) A number of tendons stored .ht the service building and in an outlying metal building were inspected. All tendons are stored on dunnage, coated with a corrosion protection grease and covered with a waterproof plastic sheeting. Each tendon remains covered until installed. No evidence of corrosion was observed on any of of the tendons. The storage areas meet the Level D storage requirements, described in ANSI N45.2.2.

(2) The inspector observed the installation of Tendons 11DF,10DF, 9DF, and 8DF and no conflicts were noted with the installation process. While attempting to install Tendons 43 FE (horizontal), V245 (vertical) and 2 FE (horizontal) the sheathing was found to be plugged. The concrete containment outer wall was chipped away to gain access to the blocked sheathing. The concrete blockage was removed, sheathing repaired, containment concrete replaced, and Tendons 43 FE and V245 installed. The blockage of Tendon 2 FE is suspected to be due to separation of the sheathing and work to establish access to this tendon is in ; progress. As of July 30, 1982, ten tendons remain to be in- ' stalled in Unit No. 2. A tentative date of September 17, 1982, has been programmed for all tendons to be stressed and greased.

4' > _a,----,,,...-- a------w,~, e---re~

   .   - =     .

b. Observation of Electrical Installation Activities (1) 7he inspector selected the following three cables within Division one Class 1E which have been installed. The respective pull cords and routing requirements were compared with the appropriate drawings.

(a) Cable 1-AP326 - (IP2E-Pu11) From equipment 1AP06E0 wire diagram 1-4613Q To equipment 2AP06ED wire diagram 2-4613D (b) Cable 1FW017 - (KIR-Pull) From equipment 1 SI 05E wire diagram 1-4328A To equipment 1 PA01J wire diagram 1-4111A (c) Cable 1SX002 - (CII-Pull) From equipment 1AP05EB wire diagram 1-4611B To equipment IAP21E wire diagram 1-4661L The inspector observed that the raceway internals were free from sharp edges and hazardous rubble or refuse. The conduit bushings were installed and cable raceways were properly identified. A separation violation, NCR 591, has been identified between Cable 1AP05EB and 1CF062 CIB. This is an inside cabinet 6" space violation which will be considered for re-inspection when the nonconformance report has been resolved. ! (2) The inspector, during tours of the Unit No. I and Unit No. 2 observed that cable reels are properly stored and no reels were placed on their side. No items of noncompliance were identified.

c. Electrical Drawings During the reporting period, the inspector reviewed the following construction field drawings to verify that Field Change Requests (FCR), Drawing Change Requests (DCR), and Engineering Change Notices (ECN) were received and transmitted on current drawings.

(1) Drawing No. 20E-1-3318 Revision N, 1/15/82 Electrical Installation Main Steam Pipe Tunnel. El. 367 and 377 FCR L-2976 TCR L-3142 FCR L-3850 FCR L-318 FCR L-3474 FCR L-3095 FCR L-3357 (2) Drawing No. 20E-1-3318 D01 Revision K. 12/31/81 Electrical Installation Main Steam Pipe Tunnel Sections. FCR L-3850 5 '

(3) Drawing No. 20E-1-3321 Revision P, 11/25/81, Electrical

      ,                -Installation Auxiliary Building E1. 383 DCR 711         FCR L-3301A ECN 245 7       FCR L-3306 FCR L-3301 (4) Drawing No. 20E 1-3321A Revision K, 9/18/81, Category 1 Conduit Supports Auxiliary Building El. 383, Cols. L-Q-6-10 FCR L-3767 (5) Drawing No. 20E-1-3321 C05 Revision C, 9/18/81, Category 1 Conduit Supports Auxiliary Building El. 383 FCR L-3767 FCR L-3815 (6) Drawing No. 20-E-1-3305, Revision G, 10/5/81. Electrical Installation Auxiliary Feedwater Pipe Tunnel Plan 2 DCR 932 DCR 856 (7) Drawing No. 20-0-3383A, Revision T, 2/3/82, Category 1 Conduit Supports Auxiliary Building El. 463'5" Columns L-Q-23-26 FCR L-4366             FCR L-3199          FCR L-3120 FCR L-4365             FCR L-3200          FCR L-1909 FCR L-2556             FCR L-3305          FCR L-3541 FCR L-2637             FCR L-3564          FCR L-3484 FCR L-2959             FCR L-3525          FCR L-3391 (8) Drawing No. 20-0-3383 D01, Revision H, 12/28/81, Electrical Installation Auxiliary Building El. 463'5" Section and Damper

, Schedule l l FCR L-3120 i (9) Drawing No. 20-E-3393J. Revision P. 2/22/82, Category 1 l Conduit Support Junction Box Details FCR L-1883 FCR L-1965 FCR L-1541 FCR L-2632 FCR L-1950 FCR L-1703 (10) Drawing No. 20E 1-3311A, Revision P, 6/10/81, Category 1 Conduit Supports Auxiliary lullding Plan E1. 364 Cols. L-Q-10-5 i FCR L-1648 FCR L-2070 FCR L-3885 FCR L-2012 l FCR L-2953 i

6

~~ ECN STB-17 ECN CC-55 ECN WSC-12 ECN CC-81 ECN CC-13 ECN CC-213 ECN CC-16 ECN CC-313 (11) Drawing No. 20-E-1-3332 C03, Revision H 12/4/81, Category 1 Conduit Support Schedules Auxiliary Building El. 401 Cols. Q-W-10-5 FCR L-4330 ECN CC-95 ECN SS-2C (12) Drawing No. 20-E-0-0393C, Revision M, 11/2/81, Category 1 Conduit Supports Typical Details of Supports Attachment to Structures FCR L-3133 ECN SS3A (13) Drawing No. 20-E-0-3393H, Revision N, 11/2/81, Category 1 Conduit Supports Supplementary ST'L Types and Details FCR L-3133 FCR L-1379 (14) Drawing No. 20-E-0-3393J, Revision P. 2/22/82, Category 1 Conduit Support Junction Box Details FCR 2-1883 FCR L-2632E FCR L-1541 FCR L-1703 FCR L-1950 FCR L-1965 (15) Drawing No. 2E-0-3393L Revision L, 6/29/81, Category 1 Conduit Supports Miscellaneous Connection Details DCR 666 (16) Drawing No. 20-E-1-332, Revision M,12/4/81, Electrical Installation Auxilliary Building El. 401 Cols. Q-W-10-15 FCR L-4052 FCR L-3023 ECN CP8-CC26 (17) Drawing No. 20-E-1-3332A, Revision K - 12/4/81, Electrical Installation Auxiliary Building El. 401 FCR L-4052 (18) Drawing No. 20-E-0-3238 Revision D,10/1/79, Cable Pan Special Hangers - Sheet 16 (19) Stick Pan Installation Details Drawing No. 20-E-03239. Revision A, 7/12/78, Sheet '17 Drawing No. 20-E-03240, Revision D, 9/25/80, Sheet 18 Drawing No. 20-E-03241, Revision B, 10/18/78, Sheet 19 Drawing No. 29-E-03242 Revision B,1/14/81, Sheet 20 Drawing No. 20-E-03243A, Revision F, 6/23/81, Sheet 21 7

Drawing No. 20-E-032438, Revision C, 1/23/81, Sheet 22 Drawing No. 20-E-03243C, Revision F, 10/20/80, Sheet 23-(20) Drawing No. 20-E-0-3244,' Revision D, 3/14/79, Sheet 1 Cable Pan Manger Auxiliary Steel Attachment Schedule (21) Drawing No. 20-E-0-3265, Revision M, 8/15/78, Sheet 3 Cable Pan Manger Special-Connection DCR 769 DCR 779 All field construction drawings concide with the. site construction drawings. No items of noncompliance were identified,

d. Observation of Containment Concrete pours The inspector observed concrete placement activities in containment No. 2, construction opening (pour 2RL61A). The preplacement require-ments were verified prior to concrete placement, roving surveillance by Quality Control was adequate and satisfactory, the placement areas were clean of debris, rebar tie fastenings were secure, placement crew members and equipment were adequate, the concrete delivery was timely and satisfactory, and the consolidation t'echniques were ample.

Test personnel were present at the concrete truck discharge point and concrete test samples were being collected at the required frequency. No items of noncompliance were identified.

e. Inspection of Steam Generator Supports and Mechanical Equipment Installation and Inspection In response to NURIG-0577, " Potential for Low Fracture Toughness and Lamellar Tearing on Power Steam Generator and Reactor Coolant Pump Supports," the inspector examined the condition of all 32 support columns for the steam generators in Units 1 and 2. During this examiniation bolting defects were noted on both Unit 1 and Unit 2 steam generator supports with the defects being more severe in Unit 2. Of 192 Unit 2 support bolts,107 had evidence of damage to the socket head, 23 bolts were loose, and 18 bolts were'aissing.

Damage to the bolts consisted of deep wrench marks on the bolt shoulders and mechanical damage sufficient to cause deformation to the Allen socket heads. The mechanical damage exists in forms of curling, poening and distortion of the sides of the homagon socket head. In Unit 1 the inspector observed 53 steam generator support bolts in positions other than being tight or fully inserted. The inspector learned from various workers that no instructions were provided for installing the bolts and hydraulic torque wrenches, pneumatic operated impact wrenches, a six foot pipe extension handle on hand held wrenches were methods used to install the bolts. A i S 3

         .'. a      .

4 non-documented system of shortening the bolt thread length was also

             ,                         .      revealed to the inspector by contract workers and that at least 19 bolts have been shortened without transferring the bolt information.

Further the exact location of these modified bolts was unknown. Further review established that the Commonwealth Edison Company

, haTknowleTge 6flal significant proMem with b'olting of the steam ! generatorsupports,tha,toccurredatthelrByronStati6nj,Tield d Change Request 591 was issued on November 13, 1978, in regard to this problem and was applicable to the Braidwood Station. Adequate corrective action was not taken to prevent the same or similar problem occurring at Braidwood Unit 2. Nonconformity Report No. 332 concerning this bolting problem was issued at Braidwood on December 2,1981, yet timely and effective action still was not taken until the problem was brought to the licensee's attention by the NRC Senior Resident Inspector during exit meetings conducted on April 23, May 18, June 25, July 30, 1982, and during an enforcement conference held on August 31, 1982. This is contrary to the requirements of 10 CFR 50, Criterion XVI, and the licensee's quality assurance program as documented in the appendix to the report transmittal letter (50-456/82-05-01;

                                              $456/82-05-01).

As a result of the problems identified with the steam generator - support bolts, the inspector reviewed installation and inspection procedures and records not only for the eight steam generators but for other mechanical safety-related equipment installed under S&L Specification T/L-2739. THe inspector specifically requested from l the licensee and the contractor that all installation and inspection i records for the steam generators be made available for his review including support bolt data. l The results of these reviews were as follows: (1) No procedures had been approved for the installation or inspection of mechanical safety-related equipment prior to July 16, 1980, although numerous pieces of equipment were installed, both finally and partially prior to this date. This equipment includes but is not limited to the four Unit 1 steam generators, the component cooling heat exchangers, rssidual heat removal pumps, safety injection pumps, and the essential service water pumps. I Revision 0 (c-f ginal issue) of the applicable procedure, PGCP-8, as stated above, was first approved for use (with comments) by Largent and Lundy on July 16, 1980. Revision 1 to the procedure was approved October 29, 1980 and Revision 2 was approved on January 8,1981. No procedure for the instal-lation and inspection of the steam generator support bolts had been issued as of September 10, 1982. 9

                 -.       - _ _ _ _ _ _ _ _ _ . _ _ . ~ _ _ _.. _ _ _ . _ _ _. _ _ _ _ _

Phillips Getschow Company (contractor installing the subject t equipment) in a response dated August 3, 1981, to an audit conducted by Commonwealth Edison Company (Ceco) site quality assurance organization June 23-25, 1981 stated: "PGCP-8,

                             " Equipment Erection Record," was implemented on December 16, 1980. Prior to this, there were no specific instructions addressing equipment erection; therefore, on several events Equipment Erection Records may not have been used by produc-tion or approved by Quality Control as required by PGCP-8."

(see Paragraph 3.e.(5) below for additional information on this CECO audit, NO. QA-20-81-22, and the followup action). The inspector's review of installation and inspection records for other mechanical safety-related equipment including the accumulators, Unit 1 and 2 Reactor Coolant Pumps, and the Unit 2 steam generators indicate that Procedure PCGP-8 was not consistently implemented as late as March 1982. (2) No traceability records were maintained as required for some of the large cap screws used on the steam generator supports. An unknown number, but at least 19 of the 192 screws used in Unit 2 were cut off and the identifying number was not trans-ferred. Further, several hundered of these cap screws were transferred back and forth between Braidwcod Station, Byron Station, Rockwell and Teledyne Brown without adequate records maintained to show which ones were sent, which ones were returned and how the unaccentable cap screws were dispositioned. For example:

                              . Of 192 cap screws sent to Rockwell on CECO Purchase Order (PO) No. 722186, thirty (30) cap screws remain unaccounted for.
                               . Of 123 cap screws sent to Rockwell on Ceco PO No. 727837 l

eighty two (82) remain unaccounted for. l

                               . Seventy or seventy-two (exact number not known) received on MRR 3725 and identified as nonconforming can not be located or accounted for. (Also see Itam 3.e.(4) below)

An additional 88 cap screws are unaccounted for. This is based on receiving records which show that 455 acceptable cap screws were received at Braidwood and only 7 367 of the 455 cap screws have been installed in the supports for the eight Unit 1 and Unit 2 steam generators. (3) No meaningful quality control inspections or surveillances were conducted by Phillips, Getschow prior to November 13, 1978, that concerned installation of mechanical safety-related equipment. Of 173 reports of QC surveillances conducted by PG between the dates of November 13, 1978 and August 17, 1982, only one surveillance addressed the erection of the subject equipment and then no adverse findings were t 10 L _-

+.

identified. This surveillance was number 2127 dated February 26, 1982. As stated elsewhere in this report Section (see Items 3.e.(1) above and 3.e.(6) below) installation inspections of the majority of mechanical safety-related equipment as of August 1982, were either not conducted, were inadequate, or were not documented. (4) Seventy to seventy-two cap screws were received on MRR 3725 and identied as nonconforming. No record exists to show the disposition of these screws and no Nonconformity Report was issued as required by PG Quality Assurance Manual Section 15. (5) Commonwealth Edison Company (CECO) had knowledge of a potential and significant problem relative to the implementation of quality requirements for the installation and inspection of mechanical safety-related equipment, at least as early as July 9, 1980 and certainly by August 31, 1981, when Phillips, Getschow (PG) issued Nonconformity Report (NCR) No. 592, yet failed to assure that adequate and timely corrective action was taken. CECO site QA conducted an audit of PG during June 30 to July 9, 1980 (Audit No. QA-20-80-21) . One of the findings from that audit was that PG had not implemented adequate procedures for equipment installation and installation inspection. PG's response to that finding was as follows: A procedure for equipment installation and installation inspection has been developed and has been approved. It will be implemented immediately. Equipment which has been previously installed will be back fitted to document any information available (also see Item 3.e.(1) above). CECO closed out this audit on January 9,1981, based on review of erection records for several room coolers. Another audit of PG by CECO site QA was conducted June 23-25, 1981 (Audit No. QA-20-81-22) Observation No. 1 from that audit was as follows:

                         " Contrary to PGCo Procedure PGCP-8, Section 4.3, 13 of 69 Equipment Erection Forms (PGCP-8-1A) have not been reviewed by Quality Control of such forms previously completed by production. Also, of 308 grout release forms completed it is not clear that EET's have been initiated for each case."

PG's response to Observation No. I was as follows:

                         "PGCP-8, " Equipment Erection Record," was implemented on December 16, 1980. Prior to this there were no specific instructions addressing equipment erection; therefore, on several events, Equipment Erection Records may not have been used by production or approved by Quality Control as required by PGCP-8."

e 11

4

      -               "Nonconformance Report No. 592 (attached) has been generated

instructing our Field Engineering Department to research previous equipment installation to determine if a properly ,

prepared and completed Equipment Erection Record exists for each. When discrepancies are found, the Field Engineering Department shall initiate an Equipment Erection Record in accordance with - Paragraph 4.1 of PGCP-8, and a Retro-Fit inspection shall be performed as required." . NCR 592 was issued by PG on August 3, 1981, in response to

                      " Observation No. 1" of CECO's Audit No. QA-20-81-22.

The proposed disposition by PG for NCR 592 was:

+
                      "Phillips, Getschow Company Field Engineering Department shall research all Equipment installation up to to December 16, 1980 to determine if a properly prepared and completed Equipment Erection Form exists for each. When discrepancies are found, the Field Engineering Department shall initiate an Equipment Erection Record in accordance with PGCP-8, Paragraph 4.1, l                     submit the Equipment Erection Record to Quality Control for approval and a Retro-fit inspection shall be performed as required."

CECO site QA in their followup on August 10, 1981, of PG's response to Observation No. 1" from Ceco's audit

,                     No. QA-20-81-22 considered NCR No. 592 inadequate because no method to indicate the status of installed equipment had been implemented. PG responded on November 10, 1981, and stated that there was still a question as to which installed

,- equipment has had equipment erection records prepared, that PG is currently initiating an " Equipment Installation Log" which will indicate the status of equipment erection records once complete and that once updated; this log will be fully implemented by PG QC throughout the remainder of the project to avoid a repeat of the situation described in Observation No. 1. As a result of their followup QA surveillance No. 1981, p conducted November 11, 1981, CECO closed Observation No. 1. The close out stated: i l "After receiving this response, the " Equipment Installation l Log" mentioned was reviewed. It was found to be a nearly l complete list of equipment and PG QC had begun to enter equipment erection forms in the los next to the appropriate equipment number. The los does show the status of installed i equipment. Based on the above information, an acceptable l program in response to this audit has been initiated and j therefore this ites is censidered closed." l l , 6 e 12 -

No further action was taken by CECO until March 26, 1982,

               ,                          when they approved the disposition for NCR No. 649. NCR 649 was issued by PG on March 12, 1982, as a result of a                            '

PG surveillance report conducted February 19, 1982. NCR

                                          ~ 649 stated the probles as follows:
                                           "As a result of a surveillance report conducted 2-19-82, it has been determined that the following deficiencies exist in the PGCo equipment erection records:

1. Numerous equipment has been installed prior to imple-mentation of any equipment erection procedure. (5-27-80)

2. Equipment erection records Procedure PGCP-8 has not been properly implemented.

3. We are unable to determine status of all safety-related and seismic equipment at this time.

4. Present PGCP-8 does not meet the requirements of ANSI 45.2.8 as required by customer QA manual."

, The disposition stated on NCR 649 and approved by CECO on March 26, 1982 is as follows:

                                           .     " Revise PGCP-8 to address applicable customer requirements.
                                           . Field Engineer to list all equipment we are responsible for and generate equipment erections for all items.
                                           . A complete retro-fit inspection of all equipment in place to indicate status.    (It will be noted, however, that certain prerequisites can't be verified in a retrofit inspection e.g.,  foundation, rough set, grout release, etc.)

l . Implement revised procedure on equipment which remains to be erected." 2 The NRC inspector's review of mechanical equipment installation l and inspection records, established that effective and timely corrective action bed not been taken as a result of CECO's

audits QA-20-80-21 a.nd QA-20-81-22 nor was an effective backfit program carried out prior ,to March 26, 1982.

As of August 31, 1982, tarrective action was in progress to resolve NCR 649. P

(6) With minor exceptious, no official quality records relative

                                           'to the installation or installation inspection of sechanical safety-related equipment were generated or maintained prior

to May 27, 1980. Further, following a Ceco audit finding in July 1980 ( Audit No. QA-20-80-21) and the subsequent issuance and approval of PC Procedure PGCP-8, Revision 0, entitled, Equipment Erection Record, which required such records, they -

13

        .. .  '.    ~

(the installation records) were still not consistently generated and maintained as late as March 12, 1982. An estimated 90% of the subject equipment was erected with no or inadequate installation records being generated or maintained. (See report Section 2, Paragraph 10 for a list of equipment requiring installation records) Because of the lack of official records relative to the installation and installation inspection of mechanical safety-related equipment, the equipment installation dates stated in this and other parts of Paragraph 3.e of this report are the best estimate by the inspector. These estimates are based on review of construction speed memos, unofficial notes maintained by the craftsmen and construction foreman, discussions with personnel involved in the installations including the surveys or (surveyor), and after the fact entries made by the contractor en form PGCP-8-1A. Surveillance data relative to the setting of the four Unit 2 Steam Generators were documented but are contained in a per-sonal note book and copies of this data did not exist in the official quality assurance files of either CECO or PG as of August 1982. Similar surveillance data for the four Unit 1 steam generators were requested but could not be provided by either PG or CECO. . The Unit 1 steam generators were set during May and June, 1979. Unit 2 steam generators were set during December 1980 and January 1981. Of the eight Unit 1 and Unit 2 reactor coolant pumps, instal-lation records exist for only the Loop C Unit 2 pump (No. 2RC01PC) and these records are incompleted and some entries were made after the fact. For example, an entry was made on September 9, 1982, on Step C.5 to the " Procedural Sequence for Loading, Transport, Unloading, Upending, and Setting Reactor Coolant Pump Casings." Revision 0 dated November 3, 1981, which indicated that this step was not applicable (N/A). The requirement of Step C.5 was as follows and is considered to be applicable by the NRC inspector:

                            "Reacter Coolant Pump casings must be within .125 inches level across the face of the main flange. The center of the outlet nozzle must be at elevation 393'-0."' Add shim plates as required to the lower shim aras on each leg to meet the above two requirements. Lower pump casing until the complete load is on the support legs. Check the outlet nozzle elevation and the level of the main flange. If measurements do not meet the specified requirements adjust-
                           .sent of the shim packs will be required, otherwise, tighten the eight upset bolts to a snug tight condition. Tighten each upset bolt an additional 2/3 turn. Install the eight 1 1/4" diameter shim plate retaining bolts and washers."

14

 .~_                    __                                  _                   _        _ _ _

Three apparent QC hold points were also signed off on September 9, 1982, on Form PGCP-8-1A. These hold points were Foundation Checked, Release for Piping, and Torqued to Proper Range. l 1 Records show that reactor coolant pump casings were set on the following dates: Unit 1 - A Loop - November 3, 1981 B, C, and D Loops - November 4, 1981 Unit 2 - A and B Loops - November 4, 1981 C Loop - December 22, 1981 D Loop - Pump casing is installed, but records show it still in storage. CECO site QA conducted a surveillance on December 22-30, 1981, relative to the moving and setting of reactor coolant pump No. 2RC01PC (Loop C). The surveillance (Report No. 2056) stated:

                    " Moving and setting of reactor coolant pump 2RC01PC (Loop 3) was observed. An equipment erection record for the pump had been filled out as required by PG Co. Procedure PGCP-8. A procedural sequence for loading, transport, unloading, upending, and setting of reactor coolant pump casings            -

required by PG Co. Procedure QCP-B4 Revision 1 had been written, approved and was present at the work area at the time of the upending and setting. Two minor variations to the steps outline in the procedural sequence were made in the field with CECO approval. Good work practices and the basic requirements of the written procedure were adhered to during the upending and setting." Entries on Form PGCP-8-1A, Revision 2 dated December 16, 1980, indicate the following equipment was installed on the dates shown:

                 .  . Residual Heat Removal Pumps 1RH01PA and 1RH01PB -

June 1, 1978

                    . Residual Heat Removal Pumps 2RH01PA and 2RH01PB -

j June 13, 1978

                   .      Accumulators ISIO4TA, IS104TB, ISIO4TC, and 1SIO4TD -

July 7, 1980 l . Safety Injection Pumps ISI01PA, ISIO1PB, 2SIO1PA, and 2SIO1PB - May 25, 1978 L Since the above equipment installation dates pre-date the existance of Form PGCP-8-1A, Revision 2, it is assumed that these entries were part of a "backfit" effort. I 15 {

         ,                       (7) No audits were performed prior to June 30 - July 9, 1980, by CECO relative to mechanical equipment erection and inspection activities of Phillips, Getschow Company. This important activity involves the installation of most of the critical nuclear steam system and other mechanical, safety-related equipment. Significant amounts of this equipment had either
                                     'been finally or partially installed prior to this date.

No significant followup audit was conducted until June 23-25, 1981, to determine the effectiveness of the PG quality assur-ance program for these installatirns or to verify that proper quality records were being generated and maintained as required, although, a major finding during the June - July 1980 audit was that PG had not developed or implemented a procedure for equipment installation and installation inspection. In addition no evidence could be provided to the NRC inspectors to establish that PG had conducted audits prior to February 1982, relative to the effective implementation of their quality assurance program for the installation and inspection of mechanical safety-related equipment installa-tion or documentation of these activities. Further, a review of PG Quality Control Reports indicated that no QC surveillances were conducted of these activities prior to February 26, 1982.1 Neither the 1980 nor the 1981 CECO audits referenced above were effective in that the same deficiencies were again identified during a surveillance conducted by PG on February 19, 1982.8 i (8) During the review of records for the installation of reactor , coolant pump No. 2RC01PC it was noted that apparently the ', procedure used entitled " Procedural Sequence for Loading, Upending, Transport, Unloading and Setting Reactor Coolant l Pump Casings" Revision 0 dated November 3,1981, had not l been approved by the architect engineer (Sargent and Lundy) l as required by the Commonwealth Edison Quality Assurance ! Manual, Quality Procedure QC No. 5-1, Paragraph 4.2. i No procedure number was on the installation sign off sheets for the installation of the reactor coolant pump other than it was Revision 0 dated November 3, 1981. CECO's surveillance report identified the procedure as QCP-B4, Revision 1. This item is considered unresolved pending further review 456/82-05-02; 50-457/82-05-02). 8 PG NCR No. 649 references a February 19, 1982, surveillance but records of this surveillance could not be located. It was subsequently learned that this was not a surveillance but was an inter-office monitoring of i PG procedure implementation. 16

~-^

p( (9) The four Unit 2 steam generators and the four reactor coolant 1 pumps do not appear to be installed in accordance with ' Westinghouse recommended setting procedure. Since official quality assurance records are lacking or inadequate, the cold setting of the support columns for this equipment remains in question. The Westinghouse Nuclear Service Division procedure for setting of major NSSS components, Revision 2, dated February 13, 1979, states on Page IV-2-5 in Paragraph 3.5: "When properly erected, the columns will be slightly out of plumb toward the reactor vessel so that they will become vertical when the system is at operating temperature. The following values should be used as a guide: The two columns on the reactor vessel side of the steam generator - approxiestely 1 and 1/2 inches out of vertical cold. The two columns away from the reactor vessel side - approximately 2 inches out of vertical cold." The procedure further states on Page IV-3-8 in Paragraph 4.4 in regard to the reactor coolant pumps: "When properly erected, the columns will be slightly out of plumb leaning toward the reactor vessel. The following values should be used as a guide: The two columns toward the RPV, one on each side of the cold leg - approximately 1 and S/8 inches out of vertical cold. The column directly behind the cold leg - approximately 2 inches out of vertical cold." The support columns for the subject Unit 2 equipment are cold set in the opposite direction (i.e. , the columns lean away from the reactor vessel as much as 3 and 1/2 inches). Once the reactor heats up to operating conditions the reactor inlet and outlet piping will expand about 2-inches. This would appear to increase the leaning of these support columns away from the reactor vessel an excessive amount. Similar conditions may exist with the Unit 1 steam generators and reactor coolant pumps. This satter was discussed during the enforcement conference ~ conducted August 31, 1982, and the opinion of the Sargent and Lundy engineer present was that the position of these columns would not be a probles. This matter remains unresolved pending further review by the NRC. (50-456/82-05-03; 50-457/82-05-03) S e 17

     ,,v.-,,.       < .,.,---.        - , , . , ,   n  ,        ,

e ...,.---,,,,,,,,.,,.,,-a. . , . . , - ., , . . . , , , , , . , _ . _ , . _ . , . , . , , ~ . . _ - - . n,.-.. , , , _

t, - The above Items (3.e and 3.e(1) through (7)) appear to be contrary to the requirements of 10 CFR Part 50, Appendix B, Criterion V, VIII, X, XV, XVI, XVII, and XVIII and thus indicate a breakdown in the quality assurance program for the installation and inspection of mechanical safety-related equipment as as stated in the Appendix to the report trans=ittal letter (50-456/82-05-04; 50-457/82-05-04). Further, and as also stated in the Appendix to the report transmittal letter, the Commonwealth Edison Company had evidence of this quality assurance breakdown as early as July 198o and certainly by March 26, 1982, yet failed to report the matter to the NRC as required by 10 CFR 50.55(e) until September 2, 1982. (50-456/82-05-05; 50-457/82-05-05) Because of the seriousness of these findings, and the addi-tional information provided by CECO during an enforcement conference conducted on August 31, 1982, in regard to this matter, a second inspection in this area was conducted by a Region III based inspector. The results of this independent inspection are documented in Section II of this report,

f. Weld Rod Control The inspector observed in progress welding of cable pan hangers.

Welding materials were checked for proper control, both at the weld issue crib and at the welder's station. Proper maintenance and calibration of the following weld rod ovens was verified: Oven Serial No. Inspection and Calibration Due Date 2240 06/18/82 244 07/12/82 132 07/01/82 364 06/04/82 30A 10/05/82 41A 06/01/82 No items of nonconformance were identified. l g. Bullet Resistant Fire Doors (Followup on 10 CFR 21 Report - V.P.S.C l dated November 20, 1980) ? . The resident inspector was requested by Region III to determine the manufacturer of installed bullet resistant fire doors and determine if the licensee had documentation specifically confirming that the doors had been tested and approved for fire resistance by a j nationally recognized laboratory. The inspector determined that the doors were manufactured by Chicago Bullet Proof Equipment Company, 2250 Western Avenue, Park Forest, Illinois, 60466. Documentation provided by the manufacturer and Underwriters Laboratories Inc. , 333 Pfingsten Road, Northbrook, Illinois, 60062, specifically confirmed the doors as being tested and approved. The resident inspector examined these doors which 18

 *                ~    '

l l W t - have an attached conjugated label, that is, a U.L. fire rating 4 three Mrs. (A) and a bullet resistive door / frame rating of H. P. R. (High Power Rifle). This dual label has caused some confusion as to the validity or authenticity since U.L. has not previously authorized such a label; however, this label problem should be resolved within the testing company. The testing laboratory did satisfactory fire test (U.L. Report R8402-1) and did satisfactorily complete the bullet resistive tests (U.L. Report BP 1942) on the subject doors installed at Braidwood Nuclear Power Station. , ! No items of noncompliance were identified.

h. Observation of Housekeeping and Protection of Safety-Related Eculpment i

During the span of the reporting period, the inspector toured containment No. 's 1 and 2, the auxiliary building, the turbine building and the outside storage yard. These tours were intended to assess the cleanliness of the site, storage conditions of equip-ment and material being used in site construction; the potential for fire or other hazards which might have a deleterious effect on personnel and equipment, and to witness construction activities in progress. I (1) Mechanical safety-related material was segregated, properly 1 marked, off the ground, protected, and in general, adequately stored. (2) The cleanliness of site buildings continues to be adequately 4 addressed by the licensee. (3) During the core boring of a concrete block wall, a mixture of water, ground up aggregate and cement were thrown against a safety-related 480 volt motor control center. No protective

measures were taken to protect this equipment.

(4) The inspector noted the support columns for the main steam generators were being used to position and support heavy steel jet deflector beams. Steel cables surround these support columns at the upper and lower universal hinged joint and in two instances, these cables have broken the protective "O" ring which seals the lubricated spherical surface of the hinged joint and were wedged against this machined surface. Items 3.4.(3) and (4) are considered to be in noncompliance '! with requirements of 10 CTR 50, Appendix B, Criterion XIII, Protection of Safety-Related Equipment (50-456/82-05-06; 50-457/82-05-06). i<

i. Follovup on Letter from Concerned Citizen The resident inspector contacted the concerned individual who had written Region III with regards to "some vital information concern-ing the Braidwood Nuclear Station." The inspector met with this 19

individual and general information was received in regard to welding repairs and distruction of partial radiographs of welding problems in Unit 1. Specific information as to pipe size, pipe location and system, other than Reactor No. I was not known or at least was not submitted by the individual. The inspector with the aid of a Region III inspector has reviewed weld records and radiographs of Unit 1 eeactor coolant outlet nozzle piping field welds. All records were complete, dated and signed and all radiographs viewed were acceptable. The concerned citizen also covered generalities such as "there is a lot of shady stuff going on out there that I hear about, but I don't know about." Without specific data the inspector cannot review these concerns. The inspector will . amain alert to potential problems during his routine inspections of the Braidwood facility but for now feels, based on the information provided, that the concerns of the individual have been properly addressed. j . Resident Inspector Meetings with Local public Officials On_ July 21, 1982, a meeting was held in Braidwood, Illinois, with elected county and municipal chief executives in accordance with Regional Procedure 0951. This meeting was informal and opened with a presentation of the NRC's organizational structure and regulatory responsibilities. The inspector discussed the Resident Inspector Program, NRC activities at the Braidwood Nuclear Station, plant design and operation. Following the presentations, questions 4 frem the elected officials were answered. Questions raised included trench installation at Braidwood, cooling lake locations, licensing of operators, drug and alcohol use at nuclear sites, emergency pre-paredness issues, plant life and decommissioning, allegations, and general construction activities. All officials in attendance expressed their appreciation for the meeting and indicated that it was of great value to them. The following individuals were present at the meqting. Name Title Town / County Represented Patricia {ancasky Township Supervisor Custer Park, IL ( David Do,1;n Manager LLW Illinois D.N.S. Henry 5(oba Mayor Grundy John B. Hokey Village President Grundy Albert J. Vota Trustee Grundy Henry Gaddo Mayor Braceville R. W. Roskland Commissioner Coal City Chester A. Grygiel Fire Chief Braidwood George Schock President Eileen Ray Sereno Mayor Gardner Leonard G. McGregor SRI-Braidwood NRC-RIII D. W. Hayes Section Chief NRC-RIII Julian M. Hinds Project Inspector NRC-RIII l NRC-RIII William B. Menezer RSLO e 20 , n, , _ . _ . ..-, - _. r- -_ )

I

4. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of non-compliance or deviations. Unresolved items disclosed during this inspection are discussed in Paragraphs 3.e(8) and 3.e(9).

5. Exit Interview The resident inspector met with licensee representatives on April 23, May 18, June 25, 1982 and at the conclusion of the inspection on July 30, 1982. The inspector summarized the purpose and findings of the inspection.

The Region III inspector met with licensee representatives at the conclusion of his inspection on September 10, 1982.

6. Enforcement Conferences An enforcement conference was held with the licensee on August 31, 1982, at the NRC Region III office in Glen Ellyn, Illinois. Attendees are listed below. The purpose of the conference was to discuss NRC action in regard to the inspection findings documented in Section 1, Paragraph 3.e of this report concerning installation of mechanical safety-related equipment.

Also discussed was the accuracy of a statement in the Braidwood Final Safety Analysis Report (FSAR), Chapter 17, Appendix B, Paragraph B.9.5. The statement was that the fabrication and installation of N.S.S.S. (Nuclear Steam Supply System) component supports were (emphasis added) accomplished in conformity with NF 4000 of ASME Section III, Subsection NF when in fact, the installation of the Unit 1 and Unit 2 Steam Generators, as of August 31, 1982, did not fully conform to NF 4000 in that Paragraphs NT 4711 " Bolting and Thread Engagement," NT 4723 " Precautions Before Bolting" and NT 4724 " Bolt Tension" were not met. As stated in Section II of this report, the design specifications did implement the FSAR commitment but the contractor did not fully implement this specification requirement. This matter has been referred to the NRC Headquarters Staff for resolution. In regard to the first item of discussion, Commonwealth Edison sub-sequently submitted a letter dated September 1,1982, outlining the action being taken to correct the deficiencies identified in the control of the erection of mechanical equipment at Braidwood. The NRC's under-standing of the four activities outline in the CECO September 1,1982, letter and two additional required actions were later documented in a NRC Region III Confirmatory Action Letter dated September 8, 1982. 21

   ,-l...     .

Attendees Commonwealth Edison Company W. L. Stiede, Assistant Vice President L. O. De1 George, Director of Nuclear Licensing J. J. Maley, Manager of Projects M. J. Wallace, Assistant Manager of Projects V. I. Schlosser, Project Manager, Jyron/Braidwood Stations J. D. Deress, Project Engineering Manager, Byron /Braidwood Stations J. J. Westermeier, Project Engineer W. J. Shewski, Manager of QA R. E. Jortberg, Director of Nuclear Safety T. R. Tramm, Nuclear Licensing Administrator R. Cosaro, Braidwood Site Project Superintendent J. T. Merwin, Project Mechanical Supervisor T. R. Summerfield, QA Superintendent, Braidwood Sargent and Lundy R. J. Netzel, Engineer NRC - Region III A. B. Davis, Deputy Regional Administrator R. L. Spessard, Director, Division of Projects and Resident Programs R. C. Knop, Branch Chief, Projects Branch 1 D. W. Hayes, Chief, Projects Section IB L. G. McGregor, Senior Resident Inspector, Braidwood W. H. Schultz, Enforcent Coordinator

7. Followup Enforcement Conference A followup enforcement conference was conducted on November 19, 1982, l at the Commonwealth Edison Company corporate office in Chicago, Illinois.

Attendees are listed below. The purpose of this conference, requested by the licensee, was to further explain the items of noncompliance and l the NRC proposed enforcement action to review the status of the licensee's ! corrective actions. In regard to the apparent incorrect FSAR statement concerning compliance . to the ASME Section III, Subsection NF, the Region III Deputy Administrator I explained that Region III was not recommending enforcement action on this item. This decision was based the fact the design specifications did implement this commitment and the lack of clear cut NRC guidance on when the FSAR sust accurately reflect "as built" conditions. It was emphasized l that this recommendation was subject to review by our headquarters staff. Attendees (Followup Enforcement Conference) Commonwealth Edison Company C. Reed, Vice President W. L. Stiede, Assistant Vice President 22

A M. J. Wallace, Assistant Manager of Projects

    -              L. O. DelGeorgc, Director of Nuclear Licensing T. R. Tramm, Nuclear Licensing Administrator W. J. Shewski, Manager of QA NRC - Region III J. G. Keppler, Regional Administrator A. B. Davis, Deputy Regional Administrator R. C. Knop, Branch Chief. Proiects Branch 1 D. W. Hayes, Chief, Projects Section IB L. G. McGregor, Senior Resident Inspector, Braidwood S. Lewis, Region III Counsel 4

23

SECTION II Prepared By: W. J. Key Reviewed By: D. H. Danielson, Chief Materials and Processes Section Persons Contacted Commonwealth Edison Company (CECO) R. Cosaro, Project Superintendent D. Merwin, Assistant Project Superintendent S. C. Hunsader, QA Supervisor W. Carlson, Mechanical Field Engineer Phillips Getschow Company (Getschojw A. Rebino, QA Supervisor E. Uilrich, Assistant QA Supervisor B. Whitmann, General Foreman D. Ortiz, Containment Foreman Functic:._1 or Program Areas Inspected During the past year problems have been identified with installation of N.S.S.S. equipment at the Braidwood Station that has resulted in the issuance of a stop work order in this area, and has made the installation of other safety-related components questionable. This special inspection was conducted to answer questions that were raised as a result of a meeting between Commonwealth Edison Company and NRC Region III staff held on August 31, 1982, in the Region III office. The questions and the items that were examined are as follows:

1. Did design documents provided to Braidwood Contractors implement the

                          ,  Braidwood FSAR commitments specifically the commitment to Subsection NF-4000 of the ASME Code Section III.

CECO's FSAR, Section 3.9.3.4.2, commits to the ASMI Boiler and Pressure Vessel Code, 1974 Edition, Summer 197S Addenda for N.S.S.S. Component Supports.

                             . Section III, Division 1, Subsection NA, Appendix I, XVII and F
                             . Section III, Division 1, Subsection NF
                             . Code Case 1644-4 The following design documents were supplied to the appropriate con-tractors for installation of equipment. The responsibility of developing procedures in accordance with specification and getting approval from the design engineer and licensee rested with the contractors.

24

Sargent & Lundy (S&L) Specification F/L-2797 Titled: N.S.S.S. Support Steel Braidwood Units 1 and 2. This specification references ASME Code as committed to by the licensee. The fo11'owing design documents form a part of this specification. Structural Design Drawings S-1105 N.S.S.S. Support Framing - General Arrangement Equipment Support Steel Units 1 and 2 5-1106 N.S.S.S. Support Framing - Equipment Lug and Hinge Location Plan Units 1 and 2 S-1107 N.S.S.S. Support Framing - Reactor Coolant Pump Support Plan E1. 393'-2" Units 1 and 2 S-1108 N.S.S.S. Support Framing - Coolant Pump Support Plan and Sections Units 1 and 2 S-1109 N.S.S.S. Support Framing - Coolant Pump Support Sections and Details Units 1 and 2 S-1110 N.S.S.S. Support Framing - Steam Generator Support Plan El. 397'-1" Units 1 and 2 S-1111 N.S.S.S. Support Framing - Steam Generator Support Plan El. 443'-8" Units 1 and 2 S-1112 N.S.S.S. Support Framing - Steam Generator Support Plan El. 396'-7" Units 1 and 2 S-1113 N.S.S.S. Support Traming - Steam Generator Support Sections and Details S-1114 N.S.S.S. Support Framing - Steam Generator Support Section and Details S-1115 N.S.S.S. Support Framing - Reactor Vessel Support Units 1 and 2 S-1116 N.S.S.S. Support Framing - Pressurizer Support Plan and Sections Units 1 and 2 S-1117 N.S.S.S. Support Framing - Coolant Pipe Restraint Plan and Sections Units 1 and 2 S-1118 N.S.S.S. Support Framing - Miscellaneous Sections and Details Units 1 and 2 5-1119 N.S.S.S. Support Framing - Steam Generator Suppcrt Section and Details Sh. 1 Units 1 and 2 S-1120 N.S.S.S. Support Framing - Sections and Details, Units 1 and 2 25 .

I l (._ i-The following ASME Code Sections are referenced in this specification. Section II Material Specification Section III Subsection NT, Article NF-4000 . Section V Nondestructive Testing Section IX Welding and Brazing Qualifications. Structural Welding Code AWS-DI.1 l As indicated below the specification further requires the contractor 4 to submit procedures governing the work to the licensee and Consulting Engineers for approval. Quality Control Procedures Submittals , Within twelve (12) weeks after award of Contract, the Contractor should submit the detailed procedures to be used, or a schedule for submitting these procedures. Procedures governing work that is to be performed Offsite shall be submitted to the Purchaser's Consulting Engineers' Quality Centrol Division for review and acceptance. Procedures governing Onsite work shall be submitted to the Station Construction Site Project Superintendent for review and acceptance by the Purchaser. Schedules for submitting procedures shall be submitted in a similar manner. The Contractor shall not start any work covered by these procedures until the appropriate procedure has been accepted in writing by the Purchaser or the Purchaser's Consulting Engineer *, as appropriate. The Quality Control procedures shall contain those administrative pro-cedures necessary to implement each Section, 304.1 through 304.18 of the Quality Assurance Plan.

2. Did Phillips Getschow have approved procedures for installation and inspection of subject equipment, including bolting prior to the installa-tion; specifically the steam generators and reactor coolant pumps?

Although the manufacturer's procedure for setting major N.S.S.S. Components was available and suggests that the contractor " provide a detailed setting procedure for review" by the manufacturer's site personnel a procedure was not developed by Phillips Getschow. Further the manufacturer's Guide Line for M.S.G. Bolt Installation was available. Reference to these procedures were not made. The installation contractor did not develop installation or bolting procedures for submittal and ap-proval. There is no record indicating when components were released from storage to engineering for installation, nor were traveler or process sheets used or reviewed by the quality control department to establish either surviellance or hold points. In fact, it appears that there was no involvement by the Getschow quality control department during installation of any components. The latest equipment installed by Getschow did have an approved procedure for equipment installation, however, they were not followed. 6 e 26

The following Getschow procedure was approved by the licensee and design engineers for equipment installation.

                        . PGCP-8, Revisions 0, 1, and 2. Approved for use by the design engineers on July 16, 1980, October 29, 1980 and January 8,1981 respectively.

Titled: Equipment Erection Record (EER) There are no records to indicate when components were released from storage to engineering for installation. In addition there are no installation records. e 6 t 27 . r -- . _ _ --

FORM PGCP-8 S&L Equipment Equipment Name Number Location ._ Engineering Function Date Signature Nonconformance Report Submitted Nonconformance Report Cleared Construction Function Date Signature Foundation Checked Rough Set Final Set Torque to Proper Range (if appl.) Threads Showing above nut Welds to embedment plate (if appl.) Grout Release Grout Complete Alignment Complete Motor Run-in Complete Release for piping Quality Control Function Hold Point Date Signature I Torqued to Proper Range Visual Test of Welds i 28

               \     ,

1 1

3. Was traceability and identification of Steam Generator (S.G.) cap screws maintained by Getschow/ CECO during transfer between Byron and Braidwood, and during shortening of some screws 7 The S.G. cap screws arrived onsite with an identifying number stamped on the bottom or threaded and of the screw. As the screws were fitted to the S.G. support pad holes it and the hole should have been match marked.

Likewise when screws were shortened this number was transfered to the screw head on some screws but not all. For the Unit I steam generators (SGs) the inspector was informed that the screws were matched to the SG support pad holes and recorded. However, this was not done for the Unit 2 SG or for the screws removed from the Unit 1 SGs and transfered to Byron. The manu-facturer's Guide Line for M.S.G. Bolt Installation, states, " record the total length of the bolt hole..." "The bolt should go in by hand." "A wrench eav be used but excessive torque should not be used." " Matching and marking and measuring is to be done as outlined on attachment M.S.G. bolt data sheet. .." The inspector was informed by installation personnel that air wrenches were used to tighten the SG screws and that for the most part screws were not fit to the holes and match marked. When the installed screws were examined by the inspector it was noted that many are jammed / galled and extended as much as an inch out of the holes in the 3" thick support column pads, i No records exist indicating what screws were sent to Byron er which ones were returned to Braidwood. Following is a history of SG cap screws at Braidwood. There are 192 screws required per SG and they were supplied by Teledyne Brown. On March 10, 1978, 384 screws were received on Material Receipt Record

(MRR) 1750. Of these one set or 192 screws were sent to Byron Station.

The remainder of the screws were stored in the laydown area. On January 8, 1979, 70/72 screws were returned to Braidwood Station from Byron on MRR 3725, all were rejected by Getschow. On February 8,1979, one set of screws (192) received on MRR 1750 were found unacceptable by Getschow and NCR No. 334 was generated. On March 22, 1979, the unacceptable screws on NCR No. 334 were sent to Rockwell Engineering on CECO P.O. No. 722186. On March 23, 1979, 50 screws were received on MRR 4228 from Rockwell Engineering. On May 4, 1979, 64 screws were received on MRR 4485 from Rockwell Engineering. On June 14, 1979, 123 screws on Byron MRR's 3664, 3699 and 6187 were received at Braidwood on MRR 4731. On June 14, 1979, all screws received on MRR 4731 were sent to Reckwell Engineering on CECO P.O. No. 727837. e 29 -

         .r..,       '.*

On June 27, 1979, 41 acceptable screws were received from Rockwell on MRR 4807. On May 16, 1980, 48 screws were received from Teledyne Brown on MRR 5954. On November 17, 1980, 64 screws were received from Teledyne Brown on MRR 6506. Unit 1 Steam Generator Screws

Date No. of Screws Received On 04/17/79 48 .

MRR 1750 05/14/79 3 (Replaced) MRR 1750 05/24/79 50 MRR 1750 07/06/79 41 MRR 4731 08/08/80 29 MRR 5954 07/29/81 24 MRR 7004 Unit 2 Steam Generator Screws Date No. of Screws Received on 11/26/80 64 MRR 6506 06/16/81 32 MRR 7004 08/17/81 32 MRR 7004 Not Known 45 MRR 7004 Not Kravn 19 MRR 5954

4. Did Getuchow, CECO or an independant testing agency perform inspections on the installation of equipment including bolting?

bc . umentation is available to indicate that inspections of installed equ pacnt was performed. To date no equipment has been torqued to the required tightness.

5. Did Getschow/ CECO maintain adequate protection of installed equipment following installation? Do procedures and records exist to substantiate the required inspections?

All installed equipment is protected with visquine and records do exist to indicate that installed equipment is inspected as required by Getschow's maintenance group. Mechanical and electrical cards are maintained at the equipment.

6. Per CECO /Getschow QA Program or 10 CFR 50 Appendix "B", were nonconformance reports required relative to the steam generator cap screws? If so, were they issued? .

Per the QA Program and 10 CTR 50 Appendix "B", Criteria XV, the cap screws returned to Braidwood from Byron and found unacceptable by Getschow should have been and were documented on NCR 334. Likewise, cap screws sent to Rockwell for examination in accordance with NF-2580 should have been documented. However, screws being fitted to the steam generators and damaged during the process are considered in process work and need not be documented with an 30

NCR. Only those replaced, repaired, or reworked im accordance with r documented procedures require an NCR.

7. Did CECO /Getschow fail to take adequate corrective action when they identified the installation problem? Including potential generic application?

The problem with steam generator support column cap screws at Braidwcod Station does not appear to be a generic problem. The problem is that an installation procedure was not developed along the guide lines of the manufacturer's recommendations. The stop work action taken by CECO in March 1982 and released May 13, 1982 (case by case) was appropriate. The development of Phillips Getschow i Procedure QCP-B22 and the rechecking and documentation of installed i equipment, and training of personnel to the new procedure are appropriate. Subsequently it was learned that Procedure QCP-B22, Revision 0 was approved for use (with comments) on October 6, 1982, by the design engineer.

8. Identify what records were required per specification and CECO /Getschow QA Program relative to equipment installation including bolting. Were they maintained? Identify those not maintained or available for NRC review.

Phillips Getschow Procedure PGCP-8 requires that Equipment Erection Record Form PGCP-8-1 be completed for component installation. The Phillips Getschows QA department did not maintain a log or records showing when an item was released from storage to engineering for installa-

                                            "n No travelers or process sheets were used to show what activities and r ections were required or completed.

In January 1982, an equipment installation log was started by Getschow's QA department.

It is the inspector judgement that there should be more interface between the Getschow QC department and engineering and that all travelers or process sheets should be routed to QC prior to start of activities in order to establish QC hold and inspection points.: 9. Identify all CECO QA Audits of installed equipment or QC inspections of installed equipment.

There is no documentation to indicate that Getschow QC conducted inprocess inspection or surviellance of component installation. Commonwealth Edison (CECO) Quality Assurance performed the following audits of Phillips Getschow activities related to S&L Specification 2739. Audit records do not indicate that Specification 2797 was audited. Start Complete Audit Report No. Area Audited Date Date Closecut QA-20/80-8 Quality Related Records 04/01/80 05/06/80 QA-20/80-10 Pipe Support 03/29/80 06/06/80 01/08/81 31

Start Complete Audit Report No. Area Audited Date Date Closecut QA-20/80-14 Design 06/02/80 06/21/80 QA-20/80-21 ANSI-N45.2.6 06/30/80 03/10/81 QA-20/80-26 F.U. Surveillance 07/28/80 12/11/80 No. 1335 QA-20/80-31 QA Program Sections 1, 08/19/80 01/29/81 3, 10, 13 QA-20/80-53 QA Manual 11/19/80 01/29/81 QA-20/81-07 QA Manual Sections 1, 02/19/81 05/05/81 3, 9 QA-20/81-22 Support Installation 06/23/81 Installation History and Rigging QA-20/81-30 Instrument Design 09/29/81 03/09/81 QA-20/81-34 Document Control, 10/22/81 ' 11/10/81 Welding Control ASME Code Inspections " Test Control Nonconformances QA-20/81-47 Whip Restrant Storage 12/31/81 03/31/82 QA-20/82-04 QAM. 1, 3, 4,'5, 6, 7, 02/22/82 03/15/82 06/07/82 8, 9 Applicable Procedures QA-20/82-12 Pipe Supports, Whip 04/20/82' 05/02/82 06/18/82 Restrants QA-20/82-15 2" and Under Pipe 06/24/82 07/06/82 Open Design and Installation QA-20/82-40 Document Control 07/22/82 07/29/82 Open 1- Design Control Record Storage Final Analysis QA-20/82-22 Large Bore Pipe 08/17/82 08/24/82 Open Installation QA-20/82-32 ANSI-N45.2.2, QCP-B13 03/19/82 03/23/82 05/20/82 QA-20/82-36 Whip Restrant Instal- 05/18/82 05/28/82 Open i lation Large Bore Pipe Installation

10. List all Key safety-related equipment involved. Identify dates of Installation.

No documentation exists that shows component installation dates. l l Equipment Installation Records (EIR) have been requested for the following f- safety-related and N.S.S.S. items. i l t 32 ' l

_ SAFETY-RELATED MECHANICAL EQUIPMENT (Quality Groups A, B, C and H) IIR B/F Equipment No. Issued Complete Eouipment Name OAB01DA Boron Recycle Evaporator Feed Demineralizer 0A OAB01DB Boron Recycle Evaporeter Faed Demineralizer OB OAB01F Recycle Evaporator Concentrates Filter OAB01PA Recycle Evaporator Feed Pump OA OAP01PB Recycle Evaperator Feed Pump OB OAB020DA Recycle Evaporator Package OA OAB02DB Recycle Evaporator Package OB OAB02FA Recycle Evaporator Feed Filter OA OAB02FB Recycle Evaporator Feed Filter OB OAB03P Boric Acid Transfer Pump 0 1AB03P Boric Acid Transfer Pump 1 1AB04F Boric Acid Filter IAF01PA

Motor Driven Auxiliary Feedwater Pump 1AF01PB
Diesel Driven Auxiliary Feedwater Pump IB 1BR01A Moderating Heat Exchanger IBR01DA Thermal Regeneration Demineralizer 1A IBR01DB Thermal Regeneration Domineralizer IB _

IBR01DC Tr.ermal Regeneration Demineralizer 1C - 1 BRO 1DD Thermal Regeneration Demineralizer ID 1 BRO 1DE Thermal Regeneration Demineralizer 1E IBR04J Chiller Control Panel OCC01A Component Cooling Heat Exchanger OCC01P Component Cooling Pump 0 ICC01A Component Cooling Heat Exchanger 1CC01PA Component Cooling Pump 1A ICC01PB Component Cooling Pump 1B ICC01T Component Cooling Surge Tank 1CS01PA Containment Spray Pump 1A (Motor Driven) ICS01PB Containment Spray Pump 1B (Motor Driven) ICS01SA Containment Spray Eductor 1A ICS01SB Containment Spray Eductor 1B ICS01T Spray Additive Tank ICV 01AA Excess Letdown Heat Exchanger 1A ICV 01AB Excess Letdown Heat Exchanger 1B 2CV01DA Mixed Bed Domineralizer 1A ICV 01DB Mixed Bed Domineralizer IB ICV 01FA Seal WTR Injection Filter 1A 1CV01FB SEAL WTR Injection Filter 1B 1CV01PA

Centrifugal Charging Pump 1A 1CV01PB Centrifugal Charging Pump 1B 1CV015 Boric Acid Blender ICV 01T Volume Control Tank 1CV02A Seal Water Heat Exchanger ICV 02D Cation Bed Domineralizer ICV 02F Seal Water Filter '

ICV 02P Positive Displacement Charging Pump 33 l l

EIR B/F Equipment No. Issued Complete Equipment Name ICV 03AA Regenerative Heat Exchanger 1A ICV 03AB Regenerative Heat Exchanger 1B ICV 03F Reactor Coolant Filter ICV 04AA Letdown Heat Exchanger 1A ICV 04AB Letdown Heat Exchanger IB ICV 04A Letdown Reheat Heat Exchanger 1DG01KA Diesel Generator 1A IDG01XB Diesel Genexator IB 20 GPM Transfer Pump 1B ID001PA 20 GPM Transfer Pump IC ID001PB i 1D001PC 20 GPM Transfer Pump ID 1 20 GPM Transfer Pump 1D ' 1D001PD ID002TA 500 Gallon Day Tank 1A 1D002TB 500 Gallon Day Tank 1B 1D010T Diesel Oil Day Tank (500 gal) IFC01A Spent Fuel Pit Heat Exchanger 1FC01P Spent Fuel Pit Pump Waste Gas Compressor Package OA OGWOISA Vaste Gas Compressor Package OB 03WOISB OGWOITA Gas Decay Tank OA OGWOITB Gas Decay Tank OB OGWOITC Gas Decay Tank OC Gas Decay Tank OD OGWO1TD OGWOITI Gas Decay Tank OE OGWOITF Gas Decay Tank 0F Local Instrument Panel Cont. Bldg. Elev. 377 IPL50J Local Instrument Panel Cont. Bldg. Elev. 377 IPL52J Local Instri. ment Panel Cont. Bldg. Elev 412 IPL57J Local Instrument Panel Cont. Bldg. Elev. 377 IPL67J Local Instrument Panel Cont. Bldg. Elev 401 1PL69J Local Instrument Panel Cont. Bldg. Elev. 412 IPL71J Local Instrument Panel Cont. Bldg. Elev. 412 IPL72J Local Instrument Panel Cont. Bldg. Elev. 377 1PL75J Local Instrument Panel Aux. Bldg. Elev. 346 1PL81JA Local Instrument Panel Aux. Bldg. Elev. 346 1PL81JB Local Instrument Panel Aux. Bldg. Elev. 346 1PL82JA Local Instrument Panel Aux. Bldg. Elev. 346 IPL82JB Local Instrument Panel Aux. BIdg. Elev. 346 IPL84JA Press Stm. Sample Heat Exchanger IPS01A IPS01J Primary Sample ISOL Viv Panel Press Liq. Sample Heat Exchanger IPS02A Reactor Cool Sample Heat Exchanger IPS03A Steam Generator Loop 1 1RC01BA Steam Generator Loop 2 1RC01BB Steam Generator Loop 3 1RC01BC Steam Generator Loop 4 1RC01BD Reactor Coolant Pump 1A 1RC01PA Reactor Coolant Pump 1B 1RC01PB Reactor Coolant Pump 1C 1RC01PC Reactor Coolant Pump ID IRC01PD 34

4 . ., .

  ',                                EIR    B/F Equipment No. Issued Complete Equipment Name t

1RH01PA Residual Heat Removal Pump 1A

1RH01PB Residual Heat Removal Pump 1B 1RH01SA Valve Containment Assembly 1RH01SV Valve Containment Assembly

                  -1RH02AA                          Residual Heat Exchanger 1A 1RH02AB                         Residual Heat Exchanger IB 1RV01S                          Pressurizer 1SIO1PA                         Safety Injection Pump 1A ISIO1PB                         Safety Injection Pump 1B 1SIO4TA                         Accumulator Tank 1A ISIO4TB                         Accumulator Tank 1B ISIO4TC                         Accumulator Tank IC 1SIO4TD                         Accumulator Tank 1D ISX01FA                         Essential Service Water Pump Strainer IA ISX01FB                         Essential Service Water Pump Strainer IB ISXO1JA                         Essential Service Water Pump Strainer 1A Control Panel ISX01JB                        Essential Service Water Pump Strainer IB Control Panel ISX01PA                         Essential Service Water Pump 1A ISX01PB                        Essential Service Water Pump IB IVA01SA                        Aux. Bldg. HVAC System SX Pump-1A Cubicle Cooler IVA01SB                         Aux. Bldg. HVAC System SX Pump-1B Cubicle Cooler IVA02SA                         Aux. Bldg. HVAC System RH Pump-1A Cubicle Cooler IVA02SB                         Aux. Bldg. HVAC System RH Pump-1B Cubicle Cooler IVA03SA                         Aux. Bldg. HVAC System CS Pump-IA Cubicle Cooler IVA03SB                         Aux. Bldg. HVAC System CS Pump-1B Cubicle Cooler                -

IVA04SA Aux. Bldg. HVAC System SI Pump-1A Cubicle Cooler IVA04SB Aux. Bldg. HVAC System SI Pump-1B Cubicle Cooler IVA05S Aux. Bldg. HVAC System Pos. Disp. Pump-1 Cubicle Cooler IVA07S Aux. Bldg. HVAC System S F Pit Pump-1 Cubicle Cooler IVA08S Aux. Bldg. HVAC System D-D AF Pump-1B Cubicle Cooler OVC01AA Control Room HVAC System Chilled Water Cooling Coil and Cabt.-0A OVC01AB Control Room HVAC System Chilled Water Cooling Coil and Cabt.-0B DWODICA . Chilled Water System - Control Room Refrigeration Unit-0A DW001CB Chilled Water System - Control Room Refrigeration Unit-05 3S .

          ,i
  ".                          EIR     B/F Equipment No. Issued Complete Equipment Name DW001PA                          Chilled Water System - Control Room Chilled Water Pump-0A OWOO1PB                          Chilled Water System - Control Room Chilled Water Pump-0B OWX0ST                           Spent Resin Storage Tank 2AB03P                           Boric Acid Transfer Pump-2 2AB04F                           Boric Acid Filter 2AF01PA                          Motor Driven Auxiliary Feedwater Pump 2AF01PB                          Diesel Driven Auxiliary Feedwater Pump-2B 2 BRO 1A                         Moderating Heat Exchanger 2BR04J                           Chiller Control Panel 2CC01A                           Component Cooling Heat Exchanger         *

2CC01PA Component Cooling Pump 2A l 2CC01PB Component Cooling Pump 2B 2CC01T Component Cooling Surge Tank 2CS01PA Containment Spray Pump 2A (Motor Driven) 2CS01PB Containment Spray Pump 2B (Motor Driven) 2CS01SA Containment Spray Eductor 2A 2CS01SB Containment Spray' Eductor 2B 2CS01T Spray Additive Tank 5000 Gal.

2CV01AA Excess Letdown Heat Exchanger 2A 2CV01AB Excess Letdown Heat Exchanger 2B 2CV01FA Seal Water Injection Filter 2A 2CV01FB Seal Water Injection Filter 2B 2CV01PA Centrifugal Charging Pump 2A 2CV01PB Centrifugal Charging Pump 2B 2CV01S Boric Acid Blender 2CV01T Volume Control Tank 2CV02A Seal Water Heat Exchanger 2CV02F Seal Water Filter 2CV02P Positive Displacement Charging Pump 2CV03AA Regenerative Heat Exchanger 2A 2CV03AB Regenerative Heat Exchanger 2B 2CV03F Reactor Coolant Filter 2cV04AA Letdown Heat Exchanger 2A 2CV04AB Letdown Heat Exchanger 2B 2CV05A Letdown Reheat Heat Exchanger 2DG01KA Diesel Generator 2A 2DG01KB Diesel Generator 2B 2D001PA 30 GPM Transfer Pump 2A 2D001PB 30 GPM Transfer Pump 2B 2D001PC 30 GPM Transfer Pump 2C 2D001PD 30 GPM Transfer Pump 2D 2D002TA 500 Gallon Day Tank 2A 2D002TB 500 Gallon Day Tank 2B 2D020T Diesel 011 Day Tank (500 Gal.) 2FC01A Spent Fuel Pit Heat Exchanger 2FC01P Spent Fuel Pit Pump 2PL81JA Local Instrument Panel Aux. Elds. - Elev. 346 2PL81JB Local Instrument Panel Aux. Blds. - Elev. 346 36 .

i EIR B/F Equipment No. Issued Complete Equipment Name 2PL82JA Local Instrument Panel Aux. Bldg. - Elev. 346 2PL82JB Local Instrument Panel Aux. Bldg. - Elev. 346 2PS01A Press Stm. Sample Heat Exchanger 2PS01J Primary Sample ISOL VLV Panel 2PS03A Reactor Cool Sample Heat Exchanger 4 2RC01BA Steam Generator Loop 1 2RC01BB Steam Generator Loop 2 2RC01BC Steam Generator Loop 3 1 2RC01BD Steam Generator Loop 4 Reactor Coolant Pump 2A 2RC01PA 2RC01PB Reactor Coolant Pump 2B 2RC01PC Reactor Coolant Pump 2C 2RC01PD Reactor Coolant Pump 2D 2RH01PA Residual Heat Removal Pump 2A 2RH01PB Residual Heat Removal Pump 2B 2RH01SA Valve Containment Assembly 2RH01SB Valve Containment Assembly 2RH02AA Residual Heat Exchanger 2A

                                .2RH02AB                                                         Residual Heat Exchanger 2B

! 2RYOIS Pressurizer 2SIO1PA Safety Injection Pump 2A 2SIO1PB Safety Injection Pump 2B 2SIO4TA Accumulator Tank 2A 2SIO4TB Accumulator Tank 2B 2SIO4TC Accumulator Tank 2C ' 2SIO4TD Accumulator Tank 2D 2SX01FA Essential Service Water Pump Strainer 2A 2SX01FB Essential Service Water Pump Strainer 2B i 2SX01JA Essential Service Water Pump Strainer 2A Control Panel 2SX01JB Essential Service Water Pump Strainer 2B Control Panel 2SX01PA Essential Service Water Pump 2A 2SX01PB Essential Service Water Pump 2B 2VA015A Aux. Bldg. HVAC System SX Pump-2A Cubicle r Cooler ~ l 2VA01SB Aux. Bldg. HVAC System SX Pump-2B Cubicle - l Cooler . l 2VA02SA Aux. Bldg. HVAC System RH Pump-2A Cubicle l Cooler 2VA02SB Aux. Bldg. EVAC System RH Pump-2B Cubicle Cooler 2VA035A Aux. Bldg. HVAC System CS Pump-2A Cubicle Cooler 2VA03SB Aux. Bldg. HVAC System CS Pump-2B Cubicle i Cooler i 2VA04SA Aux. Bldg. HVAC System SI Pump-2A Cubicle Cooler l 2VA04SB Aux. Bldg. HVAC System SI Pump-2B Cubicle Cooler 37 i

   >,- - - - - -          , - .      ,,-+.r,----
                                                   -m,-,-,_       ----m,,     --v.--,
                                                                                  . _--,n      4,---v--    ,y  - , -

g.---,- - - - , -.--,,--.~~v,w.,&c,,,,.-- - - -- - ,-*r ,w,

EIR B/F Equipment No. Issued Complete Equipment Name 2VA05S Aux. Bldg. HVAC System Pos. Disp. Pump-2 Cubicle Cooler 2VA06SA Aux. Bldg. HVAC System Cen. Chg. Pump-2A Cubicle Cooler- ~ 2VA07S Aux. Bldg. HVAC System S F Pit Pump-2 Cubicle Cooler 2VA08S Aux. Bldg. HVAC System D-D AF Pump-2B Cubicle Cooler Conclusion The inspection confirmed that no procedures were developed for installation of N.S.S.S. equipment. In addition, inspections were not performed on the installation of other mechanical safety-related components. l i . p 1 I l 38 e .- . , , , , - , - , - - . , . . - . . - - ~ , _ - - - - - _ , _ - - - - , _ - , y,m--, ..--- ---.--- .----,_ , - - - ,..- ,--,- , .- --- . - - - - - - -

17L F 1, - 1% * # . . jg' a'KE:vq'o UNITED STATES

 .          E                  o              N'JCLEAR REGULATORY COMMISSION
    ,      3
                       '"'    .E                            REGION ill o                 #                       790 ROOSEVELT ROAD e                       GLEN ELLYN. ILLINOIS 60137 FEB      2 1983 Docket No. 50-456 Docket No. 50-457 EA 82-136 Commonwealth Edison Company A'ITN:  Mr. James J. O'Connor President Post Office Box 767 Chicago, IL 60690 Gentlemen:

This refers to the routine safety inspection conducted by Mr. L. G. McGregor of this office on April 19 through July 20, 1982, and the special inspection conducted by Mr. W. J. Key on September 8-10, 1982, of activities at Braidwood Station, Units 1 and 2, authorized by NRC Construction Permits No. CPPR-132 and No. CPPR-133. The results of the routine inspection were discussed on August 31, 1982, during an enforcement conference in the Region III office between Mr. W. L. Stiede and others of your staff and Mr. A. B. Davis and others of : NRC staff. The results of the special inspection were dis-cussed by Mr. Key with plant representatives at the conclusion of his inspection on September 10, 1982. A second enforcement conference was conducted at your request on November 19, 1982, at the Commonwealth Edison Company (CECO) corporate offices in Chicago, Illinois, between Mr. C. Reed and others of your staff and me and others of the NRC staff. The results of the inspection indicate serious weaknesses in your management control systems as evidenced by a breakdown of your quality assurance (QA) program as it relates to the installation and installation inspection of mechanical safety-related equipment. Although a CECO site QA audit conducted in July 1980 identified the failure of your mechanical equipment contractor to implement the requirements of Appendix B of 10 CFR Part 50, your Quality Assurance Manual, and the design specifications, adequate and effective cor-rective action was not taken. This lack of adequate corrective action l CERTIFIED MAIL RETURN RECEIPT REQLTSTED I

    . 15 .' ' . . '
                  '. Commonwealth Edison Company FEB   '* 1983 2

becomes more significant when one considers that CECO had knowledge in July 1980, June 1981 and March 1982 of a QA breakdown in this important area. In spite _ of this knowledge, installation of Nuclear Steam Supply System components as well as other mechanical safety-related equipment continued without benefit of procedures or quality verification. In addition, although the holder of a construction permit is required to report such deficiencies to the NRC within 24 hours and in writing within 30 days, it was not reported to the NRC until more than two years had elapsed (after your July 1980 audit). In order to emphasize the need for CECO management to ensure implementation of an effective quality assurance program that identifies and corrects con-struction deficiencies, we propose to impose civil penalties for the items set forth in the Notice of Violation that is enclosed with this letter. The violations in the Notice have been categorized at the severity levels described in the General Statement of Policy and Procedure for Enforcement Actions, Appendix C of 10 CFR Part 2. The base value for each of the two Severity Level III violations is $40,000. However, after considering that CECO had previously identified a similar breakdown in the QA program at the CECO Byron Station and failed to recognize that the same problems existed at the Braidwood Station, and the multiple occurrences of Appendix B violations identified at the Braidwood Station, the civil penalty for Violation I.A is being increased to $60,000. After consultation with the Director of the Office of Inspection and Enforcement, I have been authorized to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalties in the cumulative amount of One Hundred Thousand Dollars. During the November 19, 1982 enforcement conference, you described the corrective actions that you have taken to correct this problem and to prevent recurrence. These actions include the assignment of a new project manager and the re-inspection of all installed safety-related equipment. This backfit program will identify and correct installation problems and provide a complete installation record for this equipment. It appears that, these actions are responsive to our concerns. We will evaluate these l actions during future inspections. l You are required to respond to this letter and should follow the instructions in the Notice when preparing your response. Your reply to this letter and the results of future inspections will be considered in determining whether further enforcement action is appropriate.

         , i.,       .

Commonwealth Edison Company 3 FEB 2 1983 In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosure will be placed in the NRC Public Document Room.

The responses directed by this letter and the enclosed Notice are not subject to.the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511. Sincerely, D.>$$ n-^0 b _ hamesG.Kepp3rU Regional Administrator

Enclosure:

Notice of Violation and Proposed Imposition of Civil Penalties i l l l l l e

Commonwealth Edison Company 4- FEB 2 1983 cc w/ enc 1: PDR

                       - NSIC LPDR ACRS                              .

SECY CA RCDeYoung, IE JHSniezek, IE

                         -JAxelrad, IE JLieberman, ELD VStello, DED/ROGR FIngram, PA JGKeppler, RIII Enforcement Coordinators RI,'RII, RIII, RIV, RV JCummings, OIA JFitzgerald, OI
                          ~HDenton, NRR MWilliams, NRR Project Manager, NRR JCrooks, AEOD EJordan IE-JTaylor, IE NRC Resident Inspector IE/EA File IE/ES Chron EDO Rdg File DCS Michael V. Hasten, Chmn.

Commerce Commission 527 E. Capitol Ave. Springfield, IL 62706 Neil Hartigan Attorney General 500 S. Second Street Springfield, IL 62701 1

NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES

               -Commonwealth Edison Company                       Docket Nos. 50-456; 50-457 Braidwool Station, Units 1 and 2                  Constructic:n Permits No. CPPR-132; CPPR-133 EA 82-136 Inspections conducted during the period April 19 through September 10, 1982 identified certain violations of NRC requirements. The licensee did not adequately document and implement a quality assurance program to ensure that the installation or installation inspection of mechanical safety-related equipment was carried out in accordance with the require-ments of 10 CFR Part 50, Appendix B.      In addition, after an audit by the licensee identified a breakdown in the quality assurance progrrm as-related to the installation and inspection of mechanical safety-related equipment, the licensee did not make a required report to the NRC on a timely basis.

In order to emphasize the need for improvements in your management controls, as related to an adequate quality assurance program, we propose to impose civil penalties in the cumulative amount of One Hundred Thousand Dollars. In accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C) 47 FR 9987 (March 9,1982), and pursuant to Section 234 of the Atomic Energy Act of 1954, as amended ("Act"), 42 U.S.C. 2282, PL 96-295, and 10 CFR 2.205, the particular violations and the associated civil penalties are set forth in Section I below: I. CIVIL PENALTY VIOLATIONS A. 10 CFR Part 50, Appendix B, Criterion II requires holders of construction permits for nuclear power plants to document by written policies, procedures, or instructions, a quality assurance program which complies with the requirements of Appendix B for all activities affecting the quality of safety-related structures, systems, and components and to implement that program in accordance with those documents. I i i [

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e t-Notice of Violation 2 Contrary to the above,. Commonwealth Edison Company and its contractors did not adequately document and implement a quality assurance program to comply with the requirements of Appendix B as evidenced by the following examples:

1. 10 CFR 50 Appendix B, Criterion V requires in part,

                                    " Activities affecting quality shall be prescribed by docu-mented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

Commonwealth Edison Company (CECO) Quality Assurance Manual (QAM) Quality Requirement No. 5.0 (QR 5.0) states in part, '

                                    "The quality assurance actions carried oct for design, construction, testing and operation activities will be described in documented instructions, procedures, drawings, specifications, or checklists...."    The CECO QAM Quality Procedure No. 5-1 (QP 5.1) implements this requirement.

Braidwood Construction Contract Specification F/L 2797, Article 113.5 and Specification F/L 2797, Article 305, state in part, " Procedures governing onsite work shall be submitted to the Station Construction Site P oject Superintendent for review and acceptance by the Purchaser.... The procedures shall detail how all elements affecting the product quality will be processed and shall include the specification of the necessary documentation." Contrary to the above, approved procedures for the installation or installation inspection of mechanical safety-related equipment did not exist until July 16, 1980, although numerous pieces of this equipment were -finally or partially installed prior to this date. Equipment installed prior to July 16, 1980, included the four Unit 1 Steam Generators, the four Unit I and Unit 2 Residual Heat Removal Pumps and the four Safety Injection Pumps. Further, the procedure developed by the installation contractor, Phillips, Getschow Company, subsequent to July 16, 1980, was not consistently implemented in that the four Unit 2 Steam Generators and seven of the eight Primary Reactor Coolant Pumps were installed without use of the installation procedure. e

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Notice of Violation 3

2. 10 CFR 50, Appendix B, Criterion VIII requires in part,

                              " Measures shall be established for the identification and control of materials, parts, and components, including partially fabricated assemblies."

The CECO QAM QR No. 8.0 states in part, "... Materials (including consumables), parts, and components, including partially fabricated subassemblies, will have their identity marked on che item or on tags and records traceable to the it em'. Identification assigned to materials, parts and components, including partially fabricated subassemblies, will be documented and maintained by the respective vendors, contractors or organizations having responsibility for the items involved throughout fabrication, installation or erec-tion...." The CECO QAM, QP 8.1 implements this requirement. Contrary to the above, identification or traceability records were not maintained as required for some of the large cap screws used to secure the steam generator to its supporting columns. At least 19 of 192 screws were cut off and the identifying numbers were neither trans-ferred nor marked on tags and records traceable to the screws. Further, adcquate traceability records were not maintained for'several hundred of these screws which were transferred back and forth between the Byron Station, the Braidwood Station, Rockwell Engineering (for QC checks) and Teledyne Brown Ergineering (the installation contractor).

3. 10 CFR 50, Appendix B, Criterion X requires in part, "A program for inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the

                               'scumented instructions, procedures, and drawings for cecomplishing the activity."

The CECO QAM QR No. 10.0, Paragraph 10.2 states in part,

                              " Inspection and test plans shall be prepared by respective contractors, vendors or organizations having responsibility for the item (s) involved, either as a separate document identified with the parts, components or assemblies; or as an integral part of work instruction and procedure documents.

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Notice of Violation 4 Inspection and test plans shall consist of a flow chart, diagram or narrative description of the sequence of procure-ment, fabrication, processing, assembly, inspection and test activities and shall specify the inspection points. The

                               ' inspection and test plan shall provide testing requirements, the characteristics to be measured, the inspection and test procedure and the applicable acceptance criteria." The CECO QAM QP'No. 10-1 implements this requirement.

Braidwood Construction Contract Specification F/L 2739 Article 113.4.J and Specification F/L 2797 "For Nuclear Support Steel," Article 304.10 state in part, "The program for inspection of activities affecting quality that is established and executed by or for the Contractor and his subcontractors to verify conformance with the documented instructions, procedures, and drcwings shall be described. Such inspections shall be performed by individuals other than those who perform the activity being inspected and the results shall be documented." Contrary to the~above, an inspection program was not developed to verify the proper installation, including bolting, of the main steam generators in either Braidwood Unit 1 or 2. Although the manufacturer's procedure for setting major nuclear steam supply system (NSSS) components, including bolt installation, was available and suggested that the installation contractor provide a detailed setting procedure for the manufacturer's review, such a procedure was not developed. No records exist indicating that travelers, or process sheets, were used or reviewed by the quality control department to establish either surveillance or hold points. As of August 1982, installation inspections 7 of the majority of mechanical safety-related equipment were either not conducted, were inadequate, were incomplete or were not documented.

4. 10 CFR 50, Appendix B, Criterion XV requires in part,

                               " Measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation."

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Notica of Violation 5 The CECO QAM QR No. 15.0, Paragraph 15.3 states in part,

                                 " Items which are found to be nonconforming to design and specification requirements or workmanship standards will be positively identified and uniquely segregated or handled
                                *as nonconforming to prevent their inadvertent use."

The CECO QAM QP No. 15-1 implements the above requirements and states in Paragraph 5.2, "Onsite contractor nonconform-ances will be documented in accordance with the contractor's approved Quality Assurance Program and Procedures." Contrary to the above, 70 to 72 steam generator support bolts (exact number not known by CECO or the contractor) were received on MRR 3725 in January 1979 and identified as nonconforming. No record exists to show the disposition of these bolts and no Nonconformity Report was issued as required by Phillips, Getschow Company's Quality Assurance Manual, Section 15.

5. 10 CFR 50, Appendix B, Criterion XVI requires in part,

                                 " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.

In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition." The CECO QAM QR No. 16.0, Paragraph 16.1 states in part, "A corrective action system will be used to assure that such items as failures, malfunctions, deficiencies, deviations, defective material and equipment and noncon-formances which are adverse to quality and might affect the safe operation of a nuclear generating station are promptly identified and corrected." Paragraph 16.3 states in part, " Records will be regularly reviewed and analyzed by Quality Assurance and Engineering personnel. . .to deter-mine whether corrective measures will preclude recurrence." The CECO QAM QP No. 16.1 implements this requirement.

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Notice of Violation 6 Contrary to the above, CECO did not assure that a matter potentially adverse to quality was promptly identified and corrected at the Braidwood Station. CECO identified a significant problem with bolting of the steam generator supports that occurred at the CECO Byron Station. Timely or adequate corrective action was not taken by CECO to prevent the same or a similar problem from occurring at Braidwood Unit's 1 and 2. Nonconformity Report No. 332 concerning this bolting problem was issued at Braidwood on December 2, 1981, yet effective corrective action was not
taken until August 1982.

In addition, effective corrective action was not taken by CECO relative to Phillips, Getschow Company's failure to implement and utilize installation procedures (identified during CECO audits conducted June 30 - July 9,1980 and June 23-25, 1981), concerning installation and installation

                           .         inspection of mechanical safety-related equipment. The same deficiencies were again identified during a surveillance conducted by Phillips, Getschow Company on February 19, 1982.

6. 10 CFR 50, Appendix B, Criterion XVII requires in part,

                                     " Sufficient records shall be maintained to furnish evidence of activities affee-      g quality. The records shall include at least the following:      ...results of reviews, inspections, tests, audits, monitoring of work performance, and materials analyses.... Records shall be identifiable and retrievable."

The Ceco QAM QR No. 17.0, Paragraph 17.1 states in part,

                                      " Quality Assurance records will be maintained either by Edison or by an agent of Edison, under Edison's control. . . .

Records are retained and maintained in accordance with a Quality Procedure to furnish evidence of activities affecting quality." The CECO QAM QR No. 10.0, Paragraph 10.5 states in part,

                                      " Inspection and test records will provide objective evidence that inspections and tests were performed in compliance with instructions and procedures to verify design and code re-quirements. Inspection and test results will be recorded to show conformance with acceptance criteria and/or record and identify the cause of rejected items." The CECO QAM QP No. 17-1 implements the above requirements.
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o Notice of Violation 7 Contrary to the above, with few exceptions, official records were not generated or maintained relative to the installation of mechanical safety-related equipment by either CECO or their erection contractor. Records that failed to show compliance with' quality assurance, design, and code requirements included: (1) equipment releases to engineering for instal-lation, (2) travelers or process sheets to identify required installation activities and inspections, (3) installation inspections, (4) pretensile loads for bolting, and (5) data on final equipment settings.

7. 10 CFR 50, Appendix B, Criterion XVIII requires in part, "A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program.... Followup action, including reaudit of deficient areas, shall be taken where indicated."

The CECO QAM QR No. 18.0, Paragraph 18.1 states in part,

                                   " Audits will be performed by Commonwealth Edison Company and/or its contractors, subcontractors and vendors to verify the implementation and effectiveness of quality programs under their cognizance." The CECO QAM QP No. 18-1 implements this requirement. Paragraph 5.1 of QP No. 18-1 states in part, " Audits of on-site contractors will be performed, as a minimum on an annual basis. . . . The selection of contractor on-site activities to be audited and the frequency of audits will be based on site Quality Assurance and CECO Construction Surveillance Reports or findings from previous audit reports.... The frequency will be based on the nature and safety significance of the work being performed."

Contrary to the above, no audits were performed by CECO prior to June 30 - July 9,'1980 relative to mechanical equipment erection and inspection activities of Phillips, Getschow Company. This important activity involves the installation of most of the critical nuclear steam supply system and other mechanical safety-related equipment. Significant amounts of this equipment, including that identified in I.A.1 above, had either been finally or partially installed prior to this date. s

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O 8 Notice of Violation Further, no significant followup audit was conducted by CECO until June 23-25, 1981 to determine the effectiveness of the Phillips, Getschow Company's quality assurance program for these installations, or to verify that proper quality records were.being generated and maintained as required, although a major finding during the June - July 1980 audit was that Phillips, Getschow Company had not implemented an approved procedure for installing equipment and inspecting that installation. This is a Severity Level III violation (Supplement II) (Civil Penalty - $60,000) B. 10 CFR 50.55(e)(1) requires in part, "If the pe,rmit is for con-struction of a nuclear power plant, the holder of the permit shall notify the Commission of each deficiency found in design and construction which, were it to have remained uncorrecced, could have affected adversely the safety of operations of the nuclear power plant at any time throughout the expected lifetime of the plant, and which represents: (i) A significant breakdown in any portion of the quality assurance program conducted in accordance with the requirements of Appendix B; or... (iv) A significant deviation from performance specifications which will require extensive evaluation, extensive redesign, or extensive repair to establish the adequacy of a structure, system, or component to meet the criteria and bases stated in the safety analysis report or construction permit or to other-wise establish the adequacy of the structure, system, or component to perform its intended safety function." Commonwealth Edison's Quality Assurance Manual, Quality Procedure QP No. 15-2, Paragraph 5.1.1 states in part, "The site Construction Superintendent or Project Engineer and appropriate Engineering Project Engineer will mutually agree upon and review with the Director, Nuclear Licensing, as to which deficiencies and defects are reportable, based on preliminary information and shall promptly notify the NRC Regional Office within 24 hours of occurrence."

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s., , *- . eA e Notice of Violation 9 Braidwood Construction Contract Specification F/L 2739, Article 113.4.P and Specification F/L 2797 state in part, " Measures shall be estab-lished to assure that conditions adverse to quality are promptly

identified and corrected. The identification of the ad'rerse condition, the cause of the condition, and the corrective action taken to prevent future recurrence of like deficiencies shall be documented and reported to appropriate levels of management." Contrary to the above, the licensee had identified as early as July 1980 a quality assurance breakdown relative to the installation and inspection of mechanical safety-related equipment, but did not report this matter to the NRC until September 2, 1982. This is a Severity Level III violation (Supplement II). (Civil Penalty - $40,000) II. Violation Not Assessed A Civil Penalty 10 CFR 50, Appendix B, Criterion XIII, requires in part, " Measures shall be established to control the handling, storage, shipping, cleaning and preservation of material and equipment. . .to prevent damage or deterioration." The CECO QAM commits to comply with Regulatory Guide 1.39, Revision 2 which in turn endorses ANSI Standard N45.2.3-1973. ANSI N45.2.3 states in part, "The control of all tools, equipment, materials and supplies that are used shall be maintained to prevent the inadvertent inclusion of deleterious material or objects in critical systems." Conn ; the above, the licensee failed to protect the 480-volt Motor Control Center No. 133V1 (1AP40-E) (located on elevation 364 near column PIS, auxiliary building Unit No.1), from a mixture of water and fine grained concrete powder which resulted from the core boring through a concrete block wall adjacent to the motor control center. In Unit 2, containment building, the licensee failed to protect steam generator No. 2 column support, lower universal hinged joint, from steel cables used to position and support heavy steel jet deflector beams. This is a Severity Level IV violation (Supplement II).

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Notice of Violation 10

   -e Pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison Company is hereby required to' submit to the Director, Office of Inspection-and Enforcement. U.S. Nuclear Regulatory Commission, Washington, DC 20555 and a copy-to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region III, 799 Roosevelt Road, Glen Ellyn, Illinois 60137, within 30 days of the date of this Notice a written statement or explanation, including for each alleged violation:     (1) admission or denial of the alleged violation; (2) the reasons for the violation, if admitted; (3) the corrective steps which have been taken and the resulta achieved; (4) the corrective steps-which will be taken to avoid further violations; and (5) the date when full compliance will be achieved. Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Within the same time as provided for the response required above under 10 CFR 2.201, Commonwealth Edison Company may pay the civil penalties in the cumulative amount of $100,000 or may protest imposition of the civil penalties,- in whole or in part, by a written answer. Should Cormonwealth Edison Company fail to answer within the time specified, the Director, Office of Inspection and Enforcement will issue an order imposing the civil penalties proposed above. Should-Commonwealth Edison Company elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, such answer may: (1) deny the violations-listed in this Notice, in whole or in part; (2) demonstrate extenuating circumstances; (3) show error in this Notice; or (4) show other i reasons why the penalties should not be imposed. .In addition to protesting the civil penalties, in whole or in part, such answer may request remission or mitigation of the penalties. In requesting mitigation of the proposed penalties, the five factors contained in Section IV(B) of 10 CFR Part 2, Appendix C should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate statements or explana-tion by specific reference (e.g., giving page and paragraph numbers) to avoid repetition. Commonwealth Edison Company's attention is directed to the other provisions of 10 CFR 2.205, regarding the procedures for imposing a civil penalty. Upon failure to pay any civil penalties due, which have been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalties, unless compromised, remitted, or mitigated, may be collectei by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282. i FOR THE NUCLEAR EEGULATORY COMMISSION [ t O _ ~ _ bh[e f JamesGTKepp [RegionalAdministrator Dated this at g n Ellyn, Illinois , (, s day February 1983 h L

o UNITEJ STATES !

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  /            o              NUCLEAR REGULATORY COMMISSION g          .t                              REGION lli

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C $ l fl3 e 3101952 Docket No. 50-456 Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen: This refers to the routine safety inspection conducted by Messrs. R. Mendez and K. Naidu of this office on October 21-22 and 26-27, 1982, of ace.ivities at_Braidwood Nuclear Power Station, Unit 1, authorized by NRC Construction

Permit No. CPPR-132 and to the discussion of our fir. lings with Mr. R. Cosaro at the conclusion of the inspection. The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel. During this inspection, certain of your activities appeared to be in non-compliance with NRC requirements, as specified in the enclosed Appendix. TvrinerrrEsponse is required. In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter, the enclosures, ani your response to this letter will be placed in the NRC's Public Document Room. If this report contains any information that you (or your contractors) believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by tele-phone within ten (10) days from the date of this letter of your intention to file a request for withholding; and (b) submit within twenty-five (25) days from the date of this letter a written application to this office to withhold such information. If your receipt of this letter has been delayed such that less than seven (7) days are available for your review, please notify this office promptly so that a new due date may be estab-lished. Consistent with Section 2.790(b)(1), any such application must O ATTACHMENT "E"

e , Commonwealth Edison Company 2 0:010 1932 ( be accompanied by an affidavit executed by the owner of the information which identifies the document or part sought to be withheld, and which contains a full statement of the reasons which are the bases for the claim that the information should be withheld from public disclosure. This section further requires the statement to address with specificity-the considerations listed in 10 CFR 2.790(b)(4). The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear from you in this regard within the specified periods noted above, a copy of this letter, the enclosures, and your response to this letter will be placed in the Public Document Room. We will gladly discuss any questions you have concerning this inspection. Sincerely,

                                            $ $.YS C. E. Norelius, Director Division of Engineering and Technical Programs

Enclosures:

Appendix, Notice O1.2. of Violation Inspection Report No. 50-456/82-06(DETP) cc w/encis: Louis 0. DelGe,rge, Director of Nuclear Licensing V. I. Schlosser, Project Manager R. Cosaro, Project Superintendent J. F. Gudac, Station Superintendent DMB/ Document Control Desk (RIDS) Resident Inspector, RIII Karen Borgstadt, Office of Assistant Attorney General O

Appendix NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-456 As a result of the inspecticn conducted on October 21-22 and 26-27,1982, and in accordance with the NRC Enforcement Policy, 47 FR 9987 (March 9, 1982), the following violations were identified:

1. 10 CFR Appendix B, Criterion III, states in part, " Measures shall be established to assure that applicable regulatory requirements and the design basis...as specified in the license application, for those structures and components to which this appendix applies are correctly translated into specifications...and instructions. These measures shall include provisions to assure that appropriate quality standards are specified...and deviations from such standards are controlled."

Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for Nuclear Gene:ating Stations," Revision 15, Section 3.1, dated January 2, 1981, states in part, "... designs and materials will conform to... standards, regulatory requirements, SAR commitments, and appropriate quality standards as applicable." O Contrary to the above, the following instances of inadequate design control were identified:

a. The Braidwood FSAR Section 8.2.1.4.2.1 commits to compliance with IEEE 384-1974, which delineates methods of acceptable separation between Class 1E and non-Class 1E cable trays, and states that minimum separation be at least one inch. However, the inspector observed the following instances of safety related trays in physical contact with non-safety trays:

(1) 1696H CIE and 1713D C1B (2) 11335B CIE and 11335F PIB (3) Safety Cable ISX001 and 1689A PIE Additionally, the horizontal spacing between Class 1E tray node 21398S P2E and non-Class IE tray 21384T P2B was less than the required one inch. O !

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Appendix 2

b. IEEE 384-1974 further states, "Where plant arrangements preclude maintaining the minimum separation distance, the... circuits shall be run in enclosed raceways that qualify as barriers...." Hewever, as of October 27, 1982, the licensee had not designated barriers on drawings or other appropriate documentation where the minimum separation from non-safety trays could not be met for Class 1E tray Sections 21398T C2E and 12028C CIE.

This is a Severity Level IV violation (Supplement II).

2. 10 CFR Appendix B, Criterion X, states in part, "A program for inspection of activities affecting quality shall be established and executed...to verify conformance with documented instructions, pro-cedures...for accomplishing the activity."

Commonwealth Edison Company Topical Report CE-1-A, Revision 20, Section 10, states in part, " Quality Assurance inspections...will be conducted...during construction...to verify conformance to applicable drawings, instructions, and procedures as necessary to verify quality." L. K. Comstock and Company Braidwood Procedure 4.3.8, Revision June 3, 1982, Section 3.2.8.1, states in part, " Cables will be routed as designated on the Cable Pull Cards.... There will be no deviations for cables in Class I areas without prior written approval by Commonwealth Edison Lead Electrical Engineer.... O In all cases LKC Engineering will be contacted prior to pull if deviations occur." Contrary to the above, Class 1E cable ISX001 was not routed as designated per its respective pull card. Additionally, the QC inspection performed to verify proper installation failed to identify the apparent deviation. As a result, the cable inspection report was signed off, although the routing of the cable was not in accordance with the cable pull card. This is a Severity Level V violation (Supplement II).

3. 10 CFR Appendix B, Criterion V, states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures...

end shall be accomplished in accordance with these instructions, procedures...." t b' I i

Appendix 3 (. Commonwealth Edison Company Topical Report CE-1-A, Revision 14, Section 5, states in part, "The quality assurance actions carried out for... construction... activities will be described in documented instructions, procedures...or checklists. These documents will assist personnel in assuring that important activities have been performed." L. K. Comstock Braidwood Procedure 4.3.8, Revision June 3, 1982, Section 3.2.11.3, states in part, " Cables which travel in free air and continue to equipment unsupported by electrical raceway shall maintain the following separation. If any field condition prevents compliance with the following separation criteria, work shall halt and the cable pulling foreman shall notify the LKC Field Engineer for resolution." Section 3.2.11.3.2, states, "12" between safety related (Category E. R and N) and non-safety related (Category B) cables." L. K. Comstock Braidwood Procedure 4.11.1, Revision June 3, 1982, Section 3.2, states in part, "A Nonconformance Report...shall be initiated by Quality Control personnel on detecting of deviations... detailing the nonconformity and applicable standard, or specifications." Contrary to the above requirements, the inspector observed four locations where the minimum separation criteria between Class 1E and non-Class 1E cables which travel in free air was less than the required twelve Anches. In addition, no hold tags were evident in these areas O or a Nonconformance Report issued that dealt specifically with the four locations. The following node sections where safety and non-safety cables enter or exit their respective trays were observed to be in apparent violation:

a. 1696H-CIE and 1713D-C1B

b. 17771J-C2E and 117715-K2B

c. 11798J-C2E and 11798S-K2B

d. 11721M-C2E and 11837S-K2B This is a Severity Level V violation (Supplement II).

4. 10 CFR Appendix B, Criterion XV, states in part, " Measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation. These measures shall include... procedures for identi-fication, documentation... disposition, and notification to affected organizations. Nonconforming items shall be reviewed and accepted, rejected...in accordance with documented procedures."

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      - Appendix                             4 Commonwealth Edison Company Topical Report CE-1-A, Revision 20, Section 15, states in part, " Items involving construction...which are found nonconforming to the engineering requirements or specifications
             ...or workmanship standards...will be controlled to prevent their inadvertent use of installation. Nonconforming items are identified, documented and segregated for disposition.... Nonconforming items accepted 'as-is' or reworked to an acceptable condition shall be identified through documentation records and in a manner that will establish the condition as installed. When the responsible CECO personnel authorizes acceptance of the item 'as-is,' or rework of the nonconfroming item, the action will be documented."

Commonwealth Edison Company Topical Report CE-1-A, Revision 9, Section 14, states in part, " Nonconforming material and equipment will be identified through the use of a Quality Assurance ' Hold tag'.... Such ' Hold'... tags shall only be removed at the direction of Quality Assurance personnel." Contrary to the above, as of October 24, 1982, measures established by the licensee to identify nonconforming components did not assure the identification of nonconforming equipment as follows:

a. During a receipt inspection performed on October 2, 1979, the receipt inspector identified five cable reels which arrived with damaged flanges. The receipt inspector suggested and noted on O the Receipt Inspection checklist (MRR 5308) that the damaged reels be inspected by Ceco QC for recommended action. However, there appears to be no documented evidence that the apparent noncon-forming condition was dispositioned or a hold tag or a NCR issued to specifically identify the cable reels or authorize acceptance of the reels. The affected cable reels are as follows: 20 BR, 16 BR, BR-129, BR-131 and BR-165.

b. The inspector observed a damaged cable reel in the Auxiliary Building lying on the floor at the 426' elevation. There appeared to be no hold tags evident in the immediate area or hold tags physically placed on cable reel BR 12. Consequently, since the cable reel had not been identified there was no mechanism that could prevent its inadvertent use in the field.

This is a Severity Level IV violation (Supplement II). O

  .- ,-- Appendix                            5 t-Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written state-ment or explanation in reply, including for each item of noncompliance:

(1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full cor.+ pliance will be achieved. Consideration may be given to extending your response time for good cause shown.

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n F L. $.$ M4M Dated C. E. Norelius, Director Division of Engineering and Technical Programs O

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c U.S. NUCLEAR REGULATORY COMMISSION (' REGION III Report No. 50-456/82-06(DETP) Docket No. 50-456 License No. CPPR-132 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Nuclear Power Station, Unft 1 Inspection At: Braidwood Site, Braidwood, IL Inspection Conducted: October 21-22 and 26-27, 1982 Inspectors: R. Hendez At./3 r2 K Naidu W /J./s /r1. Approved By: C. C. Williams, Chief '

                                                                         /2/3[sPS Plant Systems Section     #r[ j                     '

Inspection Summary Inspection on October 21-22 and 26-27, 1982 (Report No. 50-456/82-06(DETP)) Areas Inspected: Observation of electrical installation activities, including review of as-built raceway installation, and review of QA imple-mentation procedures. The inspection involved a total of 42 inspector-hours by two NRC inspectors, including 4 inspector-hours during off shifts. Results: Of the three areas inspected, four apparent items of noncompli-ance (Criterion III - examples of failure to translate design criterion into specifications - Paragraphs 3.c and 3.d; Criterion V - failure to follow procedures - Paragraph 3.f; Criterion X - failure to perform adequate l inspection - Paragraph 3 b; Criterion XV - failure to identify and also to control nonconforming components - Paragraphs 3.h and 4.a) were identified in three areas. O

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1. Persons Contacted

           *R. Cosaro, Project Construction Superintendent
           *T. R. Sommerfield, Quality Assurance Superintendent
           *C,  Mennecke, Project Construction Lead Electrical
           *D. A. Brown, Quality Assurance Supervisor
           *L. J. Tapella, Project Construction Electrical Engineer
           *E. Kram, Quality Assurance Engineer The inspector also contacted and interviewed other licensee and contractor personnel during this reporting period.

Denotes those present at the exit interview.

2. Licensee Action on Previously Identified Items (CLOSED) Noncompliance (456/80-04-02; 457/80-04-02): Two examples were identified where the commitments of Braidwood PSAR were inadequately translated into specification 3815. One was relative to coating of carbon steel components and the other was relative to spot welds on unistruts.

The following documents were reviewed relative to spot welds on unistruts: () a. Licensee's letter dated July 11, 1980 to Region III office with response to violation.

b. Licensee's letter dated July 18, 1980 to Region III.

c. Sargent & Lundy (S&L) letter to Unistrut Corporation dated September 18, 1980.

d. Licensee's letter dated October 15, 1980 to Region III,

e. Licensee's letter dated December 11, 1980 to Region III.

f. Licensee's letter dated March 4, 1981 to Region III.

3 S&L letter dated March 12, 1981 to Licensee.

h. Licensee's letter dated March 26, 1981 to Region III.

The documents state that after extensive literature research was performed to establish a corrosion rate for pregalvanized material for over a 40 year period, S&L conservatively assumed a 8.5 mils corrosion allowance for uncoated carbon steel in rural atmosphere. Unistrut, which provided the unistruts for supports, performed shear tests with allowance for 8.5 mils corrosion. Based on the results of these tests, it was determined that tha maximum load was less than the reduced allowable. O-2

 . Regarding the uncoated carbon steel material installed and welded

( inside the containment, the licensee contracted Midway Industrial Coating to sandblast and paint the uncoated carbon steel components. Carbonzine 11 is used to coat material inside the containment and red lead is used in other buildings. Materials which have not been installed is sandblasted and coated in a coating shop located on site prior to installation. Review of Surveillance Report 2471 dated September 28, 1982 indicates that surveillances are being performed to ensure that uncoated carbon steel hanger material is being coated by Midway Industrial Coatings. (CLOSED) Noncompliance (456/80-12-02; 457/80-11-02): Two examples of failure to control purchased material were identified. One was that hanger support material supplied by Systems Control did not meet the drawing requirements. Specifically, the shop welds on H008, HS1, H071, and H135 were undersized. The second was the welds on the main control board panels did not meet Ak'S D1.1 Code requirements. Licensae letter dated December 4, 1980 states that the weld inspection program and repair program are expected to be complete by June 1981. For the hangers, NCR-250-R was initiated to identify that Systems Control, the vendor, did not follow drawing detail DV-120 en drawing 6/20E-0-3284 on all connections. The NCR was sent to S&L for reso-lution. S&L in letter dated July 6, 1981 to the licensee indicated they performed an analysis and determined that the as-built welds meet the minimum weld requirements. S&L requested the site to issue a Field Charge Request (FCR) so that the relevant drawings could be revised. FCR-L-6554 dated July 29, 1981 was initiated and sent to O S&L. This FCR was rejected and returned on April 9, 1982 for insuf-ficient information. The revised FCR was reissued on August 31, 1982 and was closed on October 22, 1981. Relative to the main control board panels, a reinspection of the welds was performed. Sargent & Lundy engineers reviewed the results of the inspection on the control board panel welds and documented their findings in weld inspection report dated June 30, 1981. A typical control panel was marked up with the various weld deficiencies. A. list of weld repairs was then prepared for each panel. Licensee authorized LK Comstock to initiate weld repairs on October 27, 1981. The weld repairs have been complete on panels identified .s 1PM11J, 12J, 01J, 04J, IDC10J, 1DC11J, OPM01J, and OPM02J. The repaired welds appear acceptable. The welds on six of the unit 2 panels have to be repaired. This item is being closed because the method of repair and reinspection is acceptable. (CLOSED) Unresolved (456/80-12-03; 457/80-11-01,: It was previously identified that incorrect hanger support plates were used for electri-cal hangers H-151 and H-128. NCR 254 was initiated on October 1, 1980 to document this condition. Action taken to correct the nonconformance was to leave the plates in place and issue Field Change Request (FCR) 896. The FCR dated October 8, 1980 requested S&L to changt the weld O . l 3

d -~* ' length and size to reflect the as-built attachment plate. S&L changed ( the sizes and lengths of the welds on hangers H-151 and H-128 on May 8, 1981.

3. Observation of Electrical Work Activities ,

s. The inspector verified that electrical control cables ISX013 and ISX095 were routed in accordance with their respective pull cards.

(1) Cable'1SX013-C2E, cable card - Revision B,' cable reel number BR-20, cable type 2/C-10, 600V. The cable extends from ESF Switchgear 142 to ESF Hotor Control Center 132X3. The cable was physically verified in routing points 11383M-C2E, 11384M-C2E, 11380M-C2E, 11378M-C2E, 11379H-C2E, 1R361-C2E, 1702B-C2E, 1906B-C2E, 1905B-C2E, 1904B-C2E, 1901B-C2E, 1900B-C2E, 1894B-C2E, 1R244-C2E, 17345-C2E, and 1735S-C2E. (2) Cable 1SX095-C2E, cable card - Revision A, cable reel nnsber BR-27, cable type 9/C-14, 600V. The cable extends from the Main Control Board IPM06J to Motor Control Center 132X1.(1AP23E). The cable was physically verified in routing points 1601K-C2E, 1599K-C2E, 1600K-C2E,'1R243-C2E,

                                                                       -1R244-C2E, 11736J-C2E, 11800J-C2E, 11749J-C2E, 11751J-C2E, 11779J-C2E, 11776J-C2E, 11775J-C2E, 11774J-C2E, and 11771J-C2E.

b. The inspector also verified the routing of power cable 1SX001, O_ but determined that the actual routing was not in accordance with its cable routing card. L. K. Comstock Braidwood Procedure 4.3.8 allows no tolerances concerning cable routing and requires

that the routing card reflect the actual field installation. : The inspector verified the following routing nodes from the 4160V ESF Switchgear 141 to the Essential Service Water Pump 1A

motor (ISX01PA-M): 1982A-P1E, 1981AC-PIE, 1981A-P1E, 1980A-PIE, 1979A-P1E, 1978A-PIE, 1977A-P1E, 1R256-P1E, 1708M-P1E, 1R252-P1E, 1680A-P1E, 1681A-P1E, 1682A-P1E, 1683A-P1E, 1685A-P1E, 1686A-P1E, !

1687A-P1E, 1689A-P1E, 1C219-P1E, 1580R-P13, 1R220-P1E, 1R219-P1E, 1502F-P1E, 1573F-P1L and C-P1E. ; Consequently, the above cable routing verification did not agree with the respective cable pull card. For example, the routing card specifies that last three nodes as 1R219-P1E, 1502F-P1E and C-PIE, however, the card does not include node 1573F-P1E, although the cable enters this section before entering conduit C-P1E. Furthermore, the apparent discrepancy between the pull card and the actual cable installation was not identified on : the applicable inspection report, although the report had been signed off by QC on March 24, 1982. Ine failure to accurately route cables in accordance with design instructions including failure to report as-built conditions through QC inspections is considered to be in noncompliance with O 4

 ...              10 CFR Appendix B, criterion X as described in the appendix of

( the report transmittal letter (50-456/82-06-01).

c. The Braidwood FSAR in Paragraph 8.3.1.4.2.1 commits to compliance with IEEE 384-1974 which states in Section 4.6.1 that "Ncn-Class IE circuits shall be separated from Class 1E circuits by the minimum requirements in Sections 5.1.3, 5.1.4'or 5.6 or they become associated circuits." IEEE 384-1974, Section 4.5 iden-tifies separation requirements for associated circuits. As of October 27, 1982, safety related raceways were observed to be in (metal to metal) physical contact with non-safety related raceway for the following tray node locations:

(1) 1696H-CIE and 1713D-C1B (2) 11335B-C1E and 11335F-P1B (3) Safety cable 1SX001 and 1689A-P1E Additionally, the horizontal spacing between Class 1E tray node 213985-P2E and non-Class 1E cable tray 21384T-P2B was less than the one inch minimum as specified in IEEE 384-1974 and Section 8.3.1.4.2.2.C of the FSAR. This failure to assure that regulatory requirements and the design basis are translated into specifications and instructions and that deviations from such standards be controlled is considered to be in noncompliance with 10 CFR 50, Appendix B, O Criterion III as described in the appendix of the report transmittal letter (50-456/82-06-02A).

d. During a tour of the Auxiliary Building, the inspector observed instances where the separation of safety and non-safety trays were less than that specified in the licensee's FSAR. Where the separation criteria cannot be met, it is expected that drawings or other applicable documentation, designate tray covers for each apparent conflict in separation. The inspector chose at random three locations where separation in the field was not maintained and compared each instance with the applicable drawing to deter-mine if a tray cover was designated. The inspector determined that in two of the three locations, the applicable drawing did not specify a tray cover. For example:

(1) Safety related tray Section 21398T-C2E is separated horizontally from non-safety tray 21384U C2B by about two inches. The FSAR commitment is a minimum of three inches. However, print No. 20E 0-3072, Revision N did not specify that either one of the two sections mentioned above be run in enclosed raceways. l (2) Safety related tray Section 12028C-C1E is separated vertically from non-safety tray 12086D C1B by about two inches. The FSAR commitment is twelve inches vertically l (-) 5

n or six inches when one tray crosses another. However, ( print No. 20E-0-3072D, Revision L did not specify a cover for either one of the trays. This failure to adequately control design commitments is a further example of noncompliance as cited previously in Section 3.c of this report (50-456/82-06-02B).

e. The inspector identified other areas where the minimum separation between safety and non-safety was not maintained. Verification that metal tray covers be specified on drawings or other docu-mentation to determine if the licensee is meeting its FSAR commitments could not be made in all the identified areas during this inspection (the minimum separation distances are mentioned in the above section).

The following instances were identified in the Auxiliary Building and the cable spreading rooms: (1) 4 inch vertical separation between Class 1E tray 1997A-P1E and non-Class IE tray 11325F-P1B. (2) 4 inch vertical separation between Class 1E tray 1997A-PIE and non-Class IE tray 11329G-C1B. (3) 6 inch vertical separation between Class 1E tray 1980A-P1E and non-Class 1E tray 1320G-C1B. (4) 2 inch vertical separation between Class 1E tray 1685B-CIE O and non-Class 1E tray 1684G-C1B. (5) 4 inch vertical separation between Class 1E tray 11906C-C1E and non-Class IE tray 12070D-C1B. (6) 4 inch vertical separation between Class 1E tray 11951C-C1E and non-Class 1E tray 12070D-C1B. (7) 4 inch vertical separation between Class 1E tray 1913E-P2E and non-Class 1E tray 1901B-P2B. (8) 4 inch vertical separation between Class 1E tray 1899B-C2E and non-Class 1E tray 1899C-P2B. (9) 4 inch vertical separation between Class 1E tray 1883C-C1E and non-Class 1E tray 1882M-P1B. (10) 2 inch vertical separation between Class IE tray 1687A-P1E and non-Class 1E tray 1712D-CIB. A review to determine if the above cases are designated to be run in enclosed raceways will be made during a subsequent inspection. This item is open (50-456/82 06-03). O 6

f. The inspector observed four locations where the minimum separation f

criteria between Class 1E and non-Class IE cables which travel in free air, was less than twelve inches as specified by Comstock Procedure 4.3.8. The following node sections where safety and non-safety cables enter or exit their respective trays were observed to be in apparent violation: (1) Class 1E tray 1696H C1E and non-Class 1E tray 1713D C1B. (2) Class 1E tray 11771J C2E and non-Class IE tray 11771S K2B. (3) Class 1E tray 11798J C2E and non-Class 1E tray 11798S K2B. (4) Class IE tray 11721M C2E and non-Class 1E tray 11837S K2B. In each instance, the cables were not temporarily supported. In addition, no hold tags were evident in these areas or a Nonconformance Report (NCR) issued that dealt specifically with the four locations. In these instances, a minimum of ten cables were involved in each location and the licensee commits to 100% QC inspection for Class 1E cable installation. The licensee produced Comstock NCR Report Nos. 490 and 581 that appeared to have identified Sections 11771J-C2E and 11798J-C2E. However, the reports identified separation probicas inside equipment No. IPA 34J and the Main Control Board IPM06J respectively, but did not address the problem outside the control cabinets. This failure to follow procedures and accomplish activities Cs ) affecting quality using documented procedures is considered to be in noncompliance with 10 CFR Appendix B, Criterien V as described in the sppendix of the report transmittal letter (50-456/82-06-04).

g. During a tour of the Upper Cable Spreading Room, the inspector observed an apparent non-seismic HVAC duct resting on safety related tray Section 12031C CIE. The inspector determined that the safety related tray and HVAC duct were both installed to the correct elevation and dimensions and within the tolerances allowed by design. It appeared that this situation did not meet the intent of Regulatory Guide 1.29, Seismic Design Classification.

However, IEEE 384-1974 states in part, "In those areas where the damage potential is limited to failures or faults internal to the electrical equipment or circuits, the minimum separating can be established by analysis of the cable installation." Pending a review of the licensee's program to identify similar situations and S&L's analysis of the possible conflicts with Regulatory Guide 1.29, this item will remain unresolved (50-456/82-06-05).

h. During a tour of the Auxiliary Building in the 426' elevation, the inspector observed cable real BR 12 with the flange damaged and the wound cable in a position that appeared to support the weight of the reel. There were no hcid tags evident on the reel 7

L.

I r as required by the licensee when an apparent nonconforming con-dition is identified. The cable reel had been brought into the plant on February 12, 1982, and had not been identified by the licensee as of October 27, 1982. The licensee took immediate corrective action and moved the subject reel out of the Auxiliary Building and had the cable re-reeled. However, this failure to control parts or components which do not conform to requirements in order to prevent their inadvertent use or installation is considered to be in noncompliance with 10 CFR Appendix B, Criterion XV as described in the appendix of the report transmittal letter (50-456/82-06-06A).

i. During a review of drawing 20E-0-3021A, Revision M, the inspector observed that detail 10 specified an open ladder type tray for safety related tray Section 1697H-C1E. Tray Section 1697A-CIE and all the trays in the immediate area are solid bottom trays.

It is expected that the licensee will issue a revised drawing to reflect the actual field installation. This matter is open (50-456/82-06-07).

4. Review of QA/QC

a. During a receipt inspection performed on October 2, 1979, the receipt inspector identified cable reels that arrived with damaged flanges. The receipt inspector suggested and noted on the Material and Equipment Receiving and Inspection Report (MRR 5308) checklist that the damaged reels be inspected by Ceco QC for recommended action. However, there appears to be no documented evidence that the apparent nonconforming condition was dispositioned, or a hold tag or NCR report issued to specifically identify the cables or authorize the acceptance of the reels. The affected cable reels are as follows: 20 BR, 16 BR, BR-129, BR-131 and BR-165.

l The licensee's response was that the receipt inspection was the necessary NCR required, and assured the inspector that the cable reels were undamaged, although no documentation existed to qualify that statement. The inspector toured the cable reel yard and determined that at least two of the five cable reels had flanges damaged to the point where the initial breakage of the flanges could have harmed the cable. Additionally, cables from reels 20 BR and 16 BR have been installed in the plant. This failure to take corrective action concerning nonconforming conditions is a further example of an item of noncompliance as previously stated in Section 3.h (50-456/82-06-06B).

b. The inspector expressed concern that involved the adequacy of Comstock inspection checklist 4.8.8 form 37. It appeared that qualitative and quantitative attributes were either lacking or not clearly defined. The inspector discussed some of the details with QC inspectors and determined the following:

8 k - - _ _ - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

(1) L. K. Comstock inspection checklist 4.8.8 does not contain ( a requirement to verify that installed cables be in accord-ance with the cable pull card. Although, there is no evidence to suggest that QC inspectors were not verifying routing points, there is still the question that such an attribute is not included on the QC checklist. (2) The inspector questioned a Level II inspector on what he thought separation of redundant cables meant. The QC inspector replied that redundancy meant the separation of Class IE and non-Class i?. cables. (3) A S&L specification allows cables to be routed within three feet of a routing marker. Licensee representatives and some QC inspectors are aware of this tolerance. However, Comstock Procedure 4.3.8 requires that cables be routed in accordance with the cable pull card and that no deviations are allowed. In addition, the procedure requires that LKC Engineering be contacted if deviations occur. Evidence of a cable not being routed in accordance with the cable pull card was cited earlier. The licensee is presently in the process of modifying the inspec-tion checklist. Pending review of inspection Procedure 4.8.8, this item is unresolved (50-456/82-06-08). Unresolved Matters ()Unresolvedmattersareitemsaboutwhichmoreinformationisrequiredin order to ascertain whether they are acceptable items, items of noncom-pliance, or deviations. Unresolved items disclosed during the inspection are' discussed in Paragraphs 3.g and 4.b. Exit Interview The inspector met with licensee representatives (denoted under Persons Contacted) at the conclusion of the inspection on October 27, 1982. The inspector summarized the scope and findings of the inspection. The licensee acknowledged the information. f we 9

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8 ' .,.. *[gf oLEN ELLYN, ILLINotS 60137 9 *.% MAY 2 31983 Docket No. 50-456 Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, Illinois 60690 Gentlemen: On April 1, 1983, our Regional Office received your letter dated March 31, 1983 stating your position on items of noncompliance which we brought to your attention in Inspection Report No. 50-456/82-06 forwarded by our letter dated March 8, 1983. We reviewed your response to the items of noncompliance and found Itams 1.a.3 and 4.a to be incomplete by our understanding. We subsequently requested a management meeting to discuss and clarify these issues for the purpose of reaching a mutually acceptable understanding of the issues. On May 10, 1983, Mr. W. S. Little and other members of this office met with Mr. J. T. Westermeier and members of your staff to discuss C: this matter. As a result of this meeting Region III reached the following conclusions:

1. With respect to Item 1.a.3 concerning the separation of a Class 1E cable with a non-class 1E tray, we take exception to your position, and maintain that this is an item of noncompliance. Your interpreta-tion that no standard addressed the separation of raceway and cables in air, does not appear consistent with the requirements of IEEE 384.

While it is conceded that IEEE 384 does not explicitly address separa-tion between a tray and a cable in air, it does primarily address separation of electrical circuits. It is to this extent that we maintain the position outlined in the subject inspection report. However, as a result of our discussions on May 10, 1983 this matter will be referred to the Office of Nuclear Reactor Regulation (NRR) for disposition. Pending a response from NRR, this matter remains open. It is our understanding that while the citation is against Braidwood Station, your Byron plant will be affected to the same extent by the pending NRC ruling on this issue. However, until an NRC disposition is reached, your electrical construction activities such as raceway and cable installation proceeds at risk that NRC disposition may result in re-work of certain areas. O ATTACHMENT "F"

4 *

   ,      Commonwealth Edison Company                                                                                                                       MAY 2 31983

2. With respect to Item 4.a concerning potentially nonconforming cable reels, we acknowledge tF;t this is not an item of noncompliance since not enough evidence exists to support a violation. Accordingly, non-compliance No. 50-456/82-06-06B will be deleted from our records.

We will contact you when a position on Item 1.a.3 is reached. No response to this letter is necessary. Your cooperation with us is appreciated. Sincerely, n AW 5e*- R. L. Spessard, Director Division of Engineering cc: Dennis L. larrar, Director of Nuclear Licensing V. I. Schlosser, Project Manager s R. Cosaro, Project Superintendent J. F. Gudac, Station Superintendent cc w/1tr dtd 3/31/83: DMB/ Document Control Desk (RIDS) Resident Inspector, R III Philip L. Willman. Esq. Office of Assistant Attorney General Reed Neuman, Esq. Office of Assistant Attorney General O

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A"** ~ MAY 7 324 Docket Nos. 50-456 50-457 Construction Permit Nos. CPPR-132 CPPR 133 EA 84-35 Coninonwealth Edison Company ATTN: Mr. James J. O'Connor President and Chief Executive Officer Post Office Box 767 Chicago, IL 60690 Gentlemen: This refers to the special quality assurance program inspection conducted by Messrs. T. E. Vandel, R. D. Schulz, I. T. Yin, D. E. Keating, C. C. Williams, and D. R. Hunter of this office on June 20-24, June 27-July 1. August 1-5, August 9, October 4-7, and October 24, 1983, and January 11-13, January 26, and February 9,1984, at Braidwood Station, Units 1 and 2, and to the C, discussions of our findings during the conduct of the inspection. This also refers to enforcement conferences which were conducted concerning the findings of this inspection in the Region III office on December 20, 1983, between Mr. C. Reed and other members of your staff and Mr. A. B. Davis and other members of the Region III staff, and on March 7,1984, between you and me and members of our staffs. The purpose of this inspection was to assess the effectiveness of the quality assurance programs of the piping contractor, the electrical contractor, and the heating, ventilation, and air conditioning (HVAC) contractor. The I enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel. Tha inspection revealed a number of deficiencies concerning the verification of correct material for ASME piping components, control of HVAC welding activities, and design control of field run small bore piping and associated hanger installation activities. These deficiencies existed even though CECO l had recently conducted comprehensive reviews of the perfonnance of all site contractors in response to a proposed civil penalty issued on February 2, 1983, involving one of these contractors. We are concerned that experience gained at other Ceco facilities and the lessons learned from the mechanical equipment place-ment violations at Braidwood were not adequately applied to the Braidwood facility. L CERTIFIED MAIL _ RETURN RECEIPT REQUESTED ATTACHMENT "G" {

i 1 , 6-Commonwealth Edison Company 2 MAY 7 E4 1 ' . The major factors contributing to the deficiencies were inadequate contractor ! programs and workmanship, inadequate licensee reviews of the contractor pro- ! grams, and inadequate licensee quality assurance overview to ensure contractor activities met all requirements. The violations indicate the need for more aggressive CECO management involvement in and support of the CECO QA Program to ensure that all safety-related activities perfomed by contractor personnel are in accordance with the regulations, codes, standards, and license require- , ments. The stop work orders and construction deficiency reports which were issued as a result of our inspection findings in the areas of small bore piping hangers, HVAC welding activities, and piping material control should have been initiated by CECO without the involvement of the NRC. We are encouraged by the personnel and organizational changes you described during the March 7, 1984, enforcement conference which indicate that you recognize the need for increased management involvement in the quality assurance program and have taken some positive actions in that regard. l The deficiencies concerning piping material control resulted in the quality of some installed piping being indeterminate and resulted in some material being installed that did not meet design requirements. A documented ' inspection program had not been implemented to assure correct material installation for 2"-and-under safety-related piping prior to July 1983; therefore, inspection records verifying correct material installation prior to that date do not exist. A documented inspection program had not been implemented to assure correct material installation for safety-related piping over 2" prior to November 1982; therefore, inspection records verifying correct material installation prior to that date do not exist. During the March 7, 1984 enforcement conference you described a verification program you are developing which will include a 100% inspection of all installed piping and associated records. We understand that the results of that program and the completion of any necessary corrective actions that might result will ensure that all installed piping material meets design requirements. Since we will need to evaluate the results of your verification efforts in order to fully assess the significance of the programatic deficiencies, enforcement ' action is not being taken on this violation at this time. Following our review of your. efforts we will determine the appropriate enforcement action. Until that time, this matter is being classified as Unresolved Items

456/83-09-04(A);457/83-09-04(A)and456/83-09-04(B);457/83-09-04(B).

l The items of noncompliance identified during the inspection are specified in 1 the enclosed Appendix, and have been categorized as a Severity Level IV in accordance with the NRC Enforcement Policy of 10 CFR Part 2, Appendix C, published in the Federal Register 47 FR 9987 (March 9, 1982). A written response is required. A response is also requested for Unresolved Items 1 456/83-09-04(A);457/83-09-04(A)and456/83-09-04(B);457/83-09-04(B). Your response should include a descriptior, of your program to verify the quality of installed piping components, your efforts to improve the aggressiveness and effectiveness of Ceco management involvement in and support of the Ceco QA Program, and the basis for your confidence in the performance of all site contractors. Your response should address why the contractor programs in the piping and HVAC areas were inadequate, why Ceco reviews of the deficient programs failed to identify the deficiencies, and why the CECO QA overview was

i Comonwealth Edison Company 3 MAY 7 1934

inadequate to ensure the contractor activities met all requirements. Also, your response should describe your efforts to assure that all construction workers and their supervisors understand their role in building quality into the facility. In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure (s' will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days of the date of this letter. Such application must be consistent with the re-quirementsof2.790(b)(1). If we do not hear from you in this regard within the specified periods noted above, a copy of this letter, the enclosure (s), and your response to this letter will be placed in the Public Document Room. The response directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511. . We will gladly discuss any questions you have concerning this inspection. Sincerely. n- A M YA [JamesG.Kepplel Regional Administrator

Enclosures:

1. Appendix, Notice of Violation

2. Inspection Reports No. 50-456/83-09(DE);

No. 50-457/83-09(DE) cc w/encis: D. L. Farrar. Director of Nuclear Licensing M. Wallace, Project Manager R. Cosaro, Project Superintendent J. F. Gudac, Station Superintendent DMB/ Document Control Desk (RIDS) Resident Inspector, RIII Phyllis Dunton, Attorney General's Office, Environmental Control Division Jane Whicher, Esq. -

9 . Comonwealth Edison Company 4 ggy 7 $gg4 Distribution PDR LPDR. RCDeYoung, IE JTaylor, IE JAAxelrad, IE GKlingler IE JLieberman, ELD JKeppler, RIII JhGrace, IE NRC. Resident Inspector IE:EA File IE:ES File DCS i l l' r i i. e i, L 1 t

i , l 1 NOTICE OF VIOLATION Comonwealth Edison Company Docket No. 50-456 Braidwood Units 1 and 2 Docket No. 50-457 EA 84-35 As a result of the inspection conducted on June 20-21, June 27-July 1, August 1-5, August 9, October 4-7, October 24, 1983, January 11-13, January 25, and February 9,1984, and in accordance with the NRC Enforcement Policy, 47 FR 9987 (March 9, 1982), the following violations were identified:

1. 10 CFR 50, Appendix B, Criterion XVI, as implemented by CECO QA Manual, QR No. 16.0, requires, in part, that measures be established to assure that conditions adverse to quality such as nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.

Contrary to the above:

a. 1/2" S/80, SA-312, Type 304, ASME Boiler and Pressure Vessel Code, Section III, Class 1 NB pipe heat number 745107 was discovered in Section III installations without material test reports or records of receiving and receipt inspections by either Commonwealth Edison Company or PGCo as identified by PGCo on September 17, 1982, on Nonconformance Report No. 789. The disposition of the Nonconformance Report resulted in accepting the pipe, after only obtaining material test reports, without examining the pipe, initiating and maintaining receipt inspection records, or determining the total quantity of the pipe in storage and installed.; b. The HVAC contractor had not established a corrective action program to assure that conditions adverse to quality,such as deficiencies and deviations were analyzed for significance and subsequently that the causes of any significant conditions were determined and corrective action taken to preclude repetition. Through August 4, 1983, 2,513 Correction Notices had been written by the HVAC contractor for deficiencies and deviations, including numerous welding deficiencies
and deviations, but the contractor's Quality Assurance Program did l not require that Correction Notices be analyzed for significance,: c. Corrective action was not adequate concerning Nonconformance Report No. BR-08, dated June 15, 1981, since the nonconforming welds completed by unknown welders were " accepted-as-is" after only a visual examination. The acceptance of a weld by visual examination pursuant to AWS DI.1 is based on the fact that a qualified welder performed i the welding in accordance with the qualified process.

This is a Severity Level IV violation (Supplement II). r l

_ . . _ . . ~ . _ _ _ . . . _ , - , . . _ _ _ - - - - - - - , - - - . - -

s . Notice of Violation 2 E

2. 10 CFR 50, Appendix B Criterion V, as implemented by the Ceco QA Manual, QR No. 5.0, requires, in part, that activities affecting quality be prescribed by documented instructions, procedures, or drawings, and shall be accomplished in accordance with these instructions, procedures, or drawings,

a. Phillips, Getschow Company Construction Procedure 1.1, Revision 4

                                   " Control of Engineering Change Notices and Field Change Requests,"

Section 5.3, requires that Document Control stamp applicable design i documents with the field change request number. Contrary to, the above, Field Drawing M-2539C-4, Revision D, was not stamped with Field Change Request No. L-9194 and Field Drawing M-2542C-121, Revision A, was not stamped with Field Change Request No. 9988.

b. Comonwealth Edison Quality Assurance Manual. Revision 77, Q.P.

No. 7-1, " Control of Procured Material and Equipment - Receiving and Inspection," Section 5.2.1.5.7, " Dimensional," requires visual checks be performed on a random basis to assure that interface

dimensions conform to drawings and/or specifications.

Contrary to the above, random visual checks of interface dimensions of piping components were not being done.

c. Phillips, Getschow Company Quality Procedure-7, Revision 7. " Control of Inspection Equipment," requires in Section 7-9 that the Site Manager or Shop Superintendent maintain a log on each piece of calibrated inspection equipment listing all items inspected and person doing the inspection with each piece of inspection equipment.

Contrary to the above, there was no documented record or log specifying that a calibrated instrument was used to measure numerous pipe bends for ovality requiring inspection measurements to the thousandths of an inch. Examples include the bends on Drawings M-2546C-72, M-2546C-44, MC-2546C-42, and M-2546C-31.

d. Phillips, Getschow Company Construction Procedure-4, Revision 0,

                                  " Control of Rework of Component Supports," requires in Section IV that upon issuance of revisions to component supports, the Field Superintendent shall initiate a Field Change Order to the Field Engineer when an ASME Section III, Subsection NF weld is involved.

Contrary to the above, Field Change Orders were not written for revisions involving ASME Section III Subsection NF welds for L component support Drawings M-IRH02017R, Revision E, and M-1SI16021X, ! Revision B.

e. The L. K. Comstock Company /L. K. Comstock Engineering Company (LKC/LKCEI) QA Program Manual requires in Section 4.2 that woided documents (drawings) be returned to document control within 3 days.

4 4

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1 4 Notice of Violation 3 f3Y 7 1994 ~1 , - Contrary to the above, drawings located in site document Station No. 5 were voided in that they were up to four revisions old and were neither returned to Document Control as voided drawings nor marked as being voided drawings for information only. This is a Severity Level IV violation (Supplement II).

3. 10 CFR 50, Appendix B, Criterion II, requires, in part, that a quality assurance program be established which complies with the requirements of Appendix B and that the program be documented by written policies, procedures, or instructions and carried out in accordance with these instructions. The quality assurance program shall provide control over activities affecting quality and shall be accomplished under suitably controlled conditions including assurance that all prerequisites for the given activity have been satisfied including the need for special controls, processes, skills and the need for verification of quality by inspection. Criterion V requires, in part, that instructions be appropriate to the circumstances. Criterion IX requires, in part, that measures be established to assure that special processes, including welding are controlled and accomplished in accordance with applicable codes, standards, specifications, criteria and other special requirements.

CECO QA Manual, QR 2.0, Paragraph 2.3, required that the QA Program take into account the need for control of special processes including welding to attain and maintain the required quality. QR 9.0, Paragraph 9.4, required provision cf process control records. AWS DI.1-1977, Section 3 " Workmanship," as implemented by Sargent and Lundy (S&L) Specification F/L-2782, "HVAC Work," Amendment 7, requires, in part, that all applicable paragraphs of Section 3 be observed in the production and inspection of welded assemblies and structures produced by any of the processes acceptable under AWS D1.1-1977. Paragraph 3.4.3 of AWS D1.1-1977 requires, in part, that the contractor shall prepare a welding sequence for a member or structure which in conjunction with the joint welding procedures and overall fabrication methods will produce members or structures meeting the quality requirements specified. AkS D1.1-1977, Section 6, " Inspection," requires that fabrication / erection inspections and tests be perfomed as necessary prior to assembly, during assembly, during welding, and after welding to ensure that materials and workmanship meet the requirements of the contract documents, including inspections to assure that electrodes are used only in the position and with the type of welding current and polarity for which they are classified and inspections to assure that the work meets the requirements of Section 3

                " Workmanship," which includes fit-up and preparation of base metal prior to welding.

t

Notice.of Violation 4 W.Y 7 1954

     .g Contrary to the above:

a. Instructions _were not appropriate to the circumstances in that welding procedures specifying the essential variables were not prescribed on drawings or welding sequences (travelers) for each specific HVACl installation, and Quality Control inspections during the welding process were not of adequate scope and frequency to assure the use of correct welding variables.

b. Quality Control was not required to examine the HVAC components for fit-up >rior to welding on those components where fit-up tolerances cannot >e determined after welding, such as all-around fillet welds and full penetration welds. Consequently there was a lack of records documenting the conformance with the requirements of AWS D1.1-1977, Section 3, and the Ceco QA Manual. Additionally, instructions to the quality control inspectors regarding fillet weld gaps after welding were not appropriate to the circumstances in that the HVAC contractor Visual Weld Inspection Procedure, B10.2.F. stated that a 3/16" gap was acceptable whereas AWS D1.1-1977, Section 3.3, states that a 3/16" gap is allowed only if the leg of the fillet weld is increased by the amount of the separation or the contractor demonstrates that the required effective throat has been obtained.

c. Quality Control was not required to examine the base metal prior to welding to assure that surfaces and edges were free of dis-continuities. Consequently, there was a lack of records documenting conformance with the requirements of AWS D1.1-1977, Section 3, and the CECO QA Manual.

This is a Severity Level IV violation (Supplement II).

4. 10 CFR 50, Appendix B, Criterion XVIII, as implemented by the CECO QA Manual, QR No. 18.0, requires, in part, that a comprehensive system of l planned and periodic audits be carried out to verify compliance with all aspects of the quality assurance program and to determine the effective-ness of the program.

Contrary-to the above:

a. Phillips, Getschow Company has not established and executed a plan for auditing the implementing procedures of the quality assurance program on a periodic basis to determine the effectiveness of the program in accordance with the PG QA Manual, Section 16.

b. L. K. Comstock Company /L. K. Comstock Engineering Company auditing activities neither conformed with the comprehensive annual schedule i

of planned and periodic audits established as required by QA Program i Manual Section 4.14.1, nor did they verify compliance with all [ aspects of the Quality Assurance Program. . i l l l

   .         _ , . ~ . . .      ... _ ____. _.__ _ _. - _ ,- -. _ _ _ ___._ _ .__ _. _. _ _   . , . . _ _ . , . . . _ , . _ . . , _ _ _ .

I 9' o Notice of Violation mv

                                                                                                                             "~                         ~' gy            !

5 l

<- I

c. Pullman Construction Industries, Inc., did not meet their yearly schedule for audit activities required by their QA Manual, Section 18, in that the following implementing procedures were not audited:

                          - B 3.1.F. Design Control
                          - B 5.1.F. HVAC Repair Adjustment                                                                                                              ,
                          - B 9.3.F. Expansion Anchor Installation
                          - B 10.2.F, Visual Weld Inspection

d. The licensee's audits of the installation of small bore instrumen-tation and process piping were inadequate in that contractor hanger design calculation problems were not identified for.more than two years.

1 This is a Severity Level IV violation (Supplement II). 5. 10 CFR 50, Appendix B Criterien VI, requires that measures be established to cortrol the issuance of documents and these measures assure that changes to those documents are ~ reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where the prescribed activity'is performed. CECO QA Manual, QR No. '6.0, Paragraph 6.1, requires that a document control system be used., including changes, and the documents and changes be revieweo and approved for release by authorized personnel. QP No. 6-2 Paragraph 4.3.1, requires that fu' ' changes to drawings be submitted with a Field Change Request. Contrary to the above, adequate measures had not been established to control field changes to drawings being made during the installation of ASME Boiler and Pressure Vessel Code, Section III, Class 2 and 3, 2" and under piping. Craft personnel had been making field changes to the drawings by rerouting lines, assigning weld numbers, and adding material which resulted in a lack of necessary control of approving, updating, and releasing drawings. This is a Severity Level IV violation (Supplement II). t

6. 10 CFR 50, Appendix B, Criterion II, requires, in part, that a quality assurance program be established which complies with the requirements of Apper. dix B and that the program be documented by written policies, procedures, or instructions and carried out in accordance with these instructions. The quality assurance program shall provide control over activities affecting quality and shall provide for indoctrination and

raining of persennel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.

Criterion III requires, in part, that measures be established to assure that applicable regulatory requirements and the design basis are. correctly translated into specifications, drawings, procedures, and instructions and 1 __ , -_ _ . . , . . _ _ , _ _ . , - , , . ,_,__,,.-._.....,..-.,,,m . . , _ , _ . , , - - , - . , , . . , , - ~ - - - - _ , - , . - - - _ _ .

                                                        .      .           .                                   _ .                                                    =-

Notice of Violation 6 IEY 7 UE4 that these measures include provisions'to assure that appropriate quality standards,are specified and included in design documents and that devia-tions from such standards are controlled. Criterion III also requires that measures be established for the identification and control of design interfaces and for coordination among participating design organizations; that the measures include the establishment of procedures among parti-cipating design organizations for the review, approval, release, distri-bution, and revision of documents involving design interfaces; and that the design control measures provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program." Ceco QA Manual, QR No. 2.0, Paragraph 2.2, requires that the QA Program be applied to safety-related systems in order to meet the requirements of ASME, Appendix B to 10 CFR 50, and certain provisions of ANSI N45.2 and N18.7. QP No. 3-1, Paragraph 2.0, required design requirements be applied and Paragraph 3-1 required the Architect Engineer (AE) review and distribute revised documents. Sargent and Lundy (S&L) Specification F/L-2739, " Piping System Installation (Section III and Non-Section III)...Braidwood Station Units 1 and 2," Paragraph 301.11. " Installation of 2" and Under Piping," controlled the basic field routing of each 2" and under piping system, including site design of safety-related small bore piping classes B, C, and H for operating temperatures up to:150*F maximum and field alteration of origiral system layouts and field selection of supports / restraints by calculation based on A-E provided guidelines. Contrary to the above, the licensee's control of site designed small bore (2" and under) process and instrumentation piping systems was considered inadequate and ineffective based on the tollowing deficiencies:

a. The programs and procedures established by the licensee and the A-E (Sargent and Lundy Engineers (S&L) prior to October 1983, did not provide sufficient assessments and verifications of Phillip, Getschow Co (PG) design capabilities prior to authorizing field routing of Class 2 and 3 small bore piping and field design of supports / restraints. The lack of assessments and verification resulted in inadequate understanding of the S&L specifications by PG to ensure the field routing of small bore piping was performed within the design requirements. Furthermore,.the field routing of Class 2 and 3 small bore pipes, without detailed drawings being issued by S&L or PG, resulted in the licersee's established QA Program requirements being bypassed and prevented the timely identification of nonconforming conditions.

c

b. The PG small bore pipe routing procedures lacked specific quantita-tive field design, installation, and inspection criteria to provide clearance and/or separation from equipr.ent and components as required by S&L specification, F/L-2739, Paragraph 301.11.

l i

   - . . ,     . _ . - . _ - , _ _ . ._.__ _ _ ._ -. _ ._.                                .. _ . _._.__ _ .. _ _ __- _ ___ . ._.. _ ...____ _._ _ ___ _                ~ _ _ _ _ _ _ .

l Notice of Violation 7 I4Y 7 1934

c. Procedure PG CP 22 requirements had not been completely followed for small bore piping calculations performed by PG for lines ICCE3AA-i",

ICCE3BA-i", 100D8BC-2", and 100D8BA-01.

d. Field Engineer authorities, duties, and qualifications were not fully delineated in the PG QA Manual, Rev. O, dated September 26, 1983, in that some of the specific work functions being performed by field engineering, such as pipe hanger design and calculation, were not adequately described.

e. The PG training program was considered to be inadequate and ineffective bcsed on the numerous errors identified in the PG hanger calculations.

f. The use of the Information Request System by PG, in lieu of the Field Change Request (FCR) system, compromised tie firal design change acceptance review and approval.

This is a Severity Level IV violation (Supplement II). Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each item of noncompliance: (1) corrective action taken and the results achieved; (2) corrective. action to be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown. FOR THE NUCLEAR REGULATORY COMMISSION (w_ a - L fa ' bs-James G. Kepple7 " [)RegionalAdministrator Dated ak Glen Ellyn, Illinois this #" tray of May 1984 l l

    ,'   i U. S. NUCLEAR REGULATORY COMMISSION i                          .                              REGION III

,- Reports No. 50-456/83-09(DE); 50-457/83-09(DE) Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood - Units 1 and 2 Inspection At: Braidwood Site - Braidwood, IL Enforcement Conferences At: Region III Office, Glen Ellyn, IL Inspection Conducted: June 20-24, June 27-July 1, August 1-5, August 9, October 4-7, October 24, 1983, January 11-13, January 26, and February 9, 1984 Enforcement Conferences Conducted: December 20, 1983 March 7, 1984 i Inspectors: Db_ :S& R. D. Schulz y% Date

                                        ,          *a NNam//w I. T. Yin                                                     3 4
                                                                                                 / 1'Y lchv .

T. E. Vandel J - J / - M, Date

                               ,             f           ,.

O D. E. Keating b Date Approved By: D. R. Hunter, Chief Nte /N Management Programs Section Date Inspection and Enforcement Conference Summary Inspection on June 20-24, June 27-July 1 August 1-5, August 9, October 4-L October 24, 1983, and January 11-13, January 26, and February 9, 1984; and Enforcement Conferences on December 20, 1983, and March 7, 1984 (Report No. 50-456/83-09(DE); 50-457/83-09(DE)], O

                 ,,,- - . -                -     , - . -           -    --,,.--             ,, ,      ,e --- - , -

Areas Inspected: Special, announced inspection of the piping contractor QA Program for training, large bore and Class 1 small bore piping design control, 'l procurement egntrol, document control, receipt inspection, special processes, inspections, measuring and test equipment, nonconformance and corrective action, audits, and small bore piping design; of the electrical contractor QA Program for staffing and qualifications, contractor auditing, document control, noncon-formance control, equipment installation control, licensee auditing; and of the heating, ventilation, and air conditioning (NVAC) contractor QA Program for qualification and training, design control, drawing control, material inspection, installation, nonconformance/ corrective action, and audits. Enforcement conferences were conducted on December 20, 1983, and March 7, 1984, to discuss the inspection findings. The inspection involved a total of 300 inspector-hours onsite by four NRC inspectors and the enforcement conferences involved a total of approximately 64 staf f-hours. Results: Six items of noncompliance were identified (failure to establish control for revisions to drawings - Section I, Paragraph 6.a; failure to follow procedures - Section I, Paragraphs 6.b, 7, 8.c and 9.b, Section II, Paragraph 3.c; failure to take adequate corrective action - Section I, Paragraph 11; inadequate control of small bore piping design - Section I, Paragraph 13; failure to execute a comprehensive audit plan - Section I, Paragraph 12, Section II, Paragraph 5.b, and Section III, Paragraph 9.a; and failure to provide design control which complies with the requirements - Section III, Paragraphs 7 and 8.a.). O O 2 l

Overview

         .i                                                                                                                        ;

1. Persons Contacted !

l See Paragraph 1 of Section I, II and III of this report.

2. Pipina See Section I of this report.

3. Electrical See Section II of this report.

4. HVAC l See Section III of this report.

! 5. Unresolved Items i Unresolved items are matters which require more information to make a

- determination whether it is an item of noncompliance, a deviation, or an acceptable matter. Unresolved items included in this report are located in Section I, Paragraphs 8.c and 9.a. and Section III, Paragraphs 7 and 9.b.

Another unresolved item (456/83-09-04(A) and (B); 457/83-09-04(A) and (B)) i located in Section I, Paragraph 9.a represents a violation but more informa- , tion is needed to fully assess the significante of the matter and to determine a the appropriate enforcement action. i

6. Exit Interviews The inspectors summarized the results of the inspection with licensee representatives during exit meetings held on July 1, August 9, October 24, l

1983, January 13, January 26, and February 9,1984.

7. Enforcement Conferences The Region III staff met with licensee representatives for an enforcement conference on December 20, 1983. The Region III staff summarized the

_ inspection findings and the licensee provided additional information related to those findings. Region III made a decision to review the ; additional information provided by the licensee before proceeding with further enforcement action. Region III representatives stated that another , enforcement conference might be scheduled subsequent to the completion of the Region !11 review and inspection of the additional information. Following the Region III review and inspection of the additional information

 ;                              provided by the licensee, the Region III staff met with licensee representa-                      3
!                               tives for a second enforcement conference on March 7, 1984. The Region III staff summarized all violations and discussed in more detail the findings I

in the areas of installed safety-related piping material traceability and O 3

1 l

HVAC. The licensee discussed corrective actions taken and planned to ensure the quality of ongoing safety-related work and the verification of previous,1y completed work, including the areas of piping material trace-ability and HVAC welding activities. The licensee stated that 100% verification o,f installed safety-related piping materials and correction of the deficiencies in the HVAC welding would be accomplished as well as l verification of the acceptability of additional aspects of the HVAC i installation. The licensee stated that the walkdown of the installed ; safety-related piping would include the verification of the as-built con-figuration. Additional matters discussed included CECO personnel and organizational changes to strengthen the construction project management team and to increase the emphasis on quality assurance. A e 1 o O 4

SECTION I - PIPING DETAILS

1. Persons Contacted Commonwealth Edison Company (CECO)

M. J. Wallace, Assistant Manager Projects D. Cosaro, Construction Superintendent D. Brown, QA Supervisor S. Hunsader, QA Supervisor G. Groth, Lead Mechanical Engineer T. Sommerfield, QA Superintendent R. Kelm, Field Engineer S. J. Reutke, QA Engineer L. J. Tapella, QC Coordinator R. J. Farr, Engineer D. Farrar, Nuclear Licensing M. A. Gorski, QA Engineer E. D. Swartz, Nuclear Licensing M. J. Morris, Field Project Engineer Phillips, Getschow Company (PGCo) K. J. Hamilton, Consultant T. G. O'Connor, Site Manager R. G. Meyers, Site Manager J. Carlson, QC Supervisor L. J. Butler, Assistant Site Manager J. R. Stewart, Project Engineer A. Rubino, QC Office Manager K. McNeely, Field Engineering Supervisor C. Rachke, QC Training Coordinator M. Yenser, QC Technician S. Giordano, Field Engineer D. Petritis, Field Engineer D. Sprague, QC Inspector B. Roche, Material Control Supervisor G. Cavalenes, QC Inspector E. Ulrich, QC Inspector W. Robinson, QC Technician D. Casey, Calibration Technician S. Forbes, Quality Assurance Coordinator R. Adkins, QC Trainee-

5. Brens, QC Trainee R. Reitz, QC Trainee T. Styx, QC Trainee Sargent and Lundy K. Fuss, Mechanical Field Coordinator -

W. C, Cliff, Project Manager 5

i e i Pittsburah Testina Laboratory (PTL) R. A. Vignocchi, Receipt Inspector Hartford Steam Boiler R. Rainey, ANI Supervisor L. Parkey, ANI K. Kilmer, ANI

2. Documents Reviewed

a. Commonwealth Edison Quality Assurance Manual, Revision 77.

4

b. Phillips, Getschow Quality Assurance Manual, Revision 13.

c. Commonwealth Edison Company FSAR, Volume 8.

d. Phillips, Getschow Procedures:

(i) QAP-QCT-20.15, Revision 9 " Training and Certification of Clerks, Trainees, Level I and II Quality Control Personnel." (ii) QAP-105A, Revision 3, " Quality Assurance Indoctrination and Training Program." (iii) PGCP-1.1, Revision 4, " Control of Engineering Change Notices and Field Change Requests." (iv) PGCP-4, Revision 0, " Verification, Prep'aration and Transmittal of 'As Constructed' Drawings." (v) QCP-B21, Revision 4, " Installation and/or Field Routing of Two Inch and Under Process Piping Systems - ASME Classes 1, 2, and 3." (vi) QAP-33, Revision 6, 'IReceiving Inspection of Items, Material and Equipment." (vii) QAP-5.1, Revision 0, " Item and Material Identification Moni-toring." (viii) BM-101, Revision 2, " Quality Assurance Interface for Requisi-tioning, Purchasing and F.eceiving Material." (ix) PGCP-4, Revision 0, " Control of Rework of Component Supports." ' (x) QCP-B23, Revision 3, " Installation and Inspection of Component Supports." (xi) QAP-16, Revision 1, " Control of Installation of Nuclear or Safety Related Pipe Systems." O 6

c (xii) PGCP-11, Revision 5, " Cold Bending of 2" and Under Pipe and Tube." 4 " (xiii) QAP-7, Revision 7, " Control of Inspection Equipment." (xiv) QCP-B-26, Revision 0, " Calibration Check of Torque Wrenches." (xv) QAP-7.6, Revision 2, " Calibration of Precision Dimensional Measuring Equipment." (xvi) QAP-12, Revision 3, " Control of Nonconformity Reports." (xvii) QAP-110, Revision 0, " Reporting of Defects and Noncompliance." (xviii) QAP-12.1, Revision 0, " Control of Audit Nonconformities." (xix) QCT-2.16, Revision 1, " Qualification of Audit Personnel."

3. Training The training program for piping personnel was reviewed and found to be in conformance with commitments in the licensee's Quality Assurance Program, Phillips, Getschow (PGCo) Procedures, and Regulatory Guide 1.58, Revision 1.

Quality Control Personnel were trained and certified in accordance with PGCo Procedures and Regulatory Guide 1.58, . Revision 1, which endorses ANSI N45.2.6-1978. Four quality control trainees were interviewed and all appeared knowledgeable in the applic.able codes and standards specific to their inspection discipline. On-the-job training was documented and new personnel worked under the direction and guidance of qualified personnel until they were familiar with all the aspects of their related inspection activity. Indoctrination was given to craft, engineering, and quality control personnel when revisions were made to the Quality Assurance Manual, Quality Assurance Procedures, Quality Control Procedures, or Construction Procedures. The training program, established and implemented, w&s in accordance with 10 CFR 50, Appendix B, Criterion II which requires that suitable proficiency be achieved and maintained. Qualification and. training records for the following quality control inspection personnel were examined:

a. Employee Number 76

b. Employee Number 101

c. Employee Number 108

d. Employee Number 111

e. Employee Number 109 No items of noncompliance or deviations were identified.

7

t

4. Design Control

a. The design change piping program for large bore (over 2") piping and ASME Class I small bore piping was reviewed to ascertain that '

the licensee has established and implemented a program in accordance with the Ceco Quality Assurance Manual. The review of documents included a verification of the following activities: (i) Procedures to control design requests have been established. (ii) Procedures and responsibilities for design control have been established. (iii) Responsibilities and controls to assure that design changes were incorporated into drawings have been est2blished. (iv) Channels of communications between design organizations and responsible individuals have been established. (v) Controls requiring that implerectation of approved design changes in accordance with approved procedures have been established.

b. The following Field Change Requests were reviewed and found to be processed and dispositioned in accordance with licinsee design control criteria:

(i) FCR #9988 * (ii) FCR #L-9588 (iii) FCR #L-9194 (iv) FCR #L-9148 (v) FCR #L-9945 , (vi) FCR #L-9189 No items of noncompliance or deviations were identified.

5. Procurement Control Procurement documents were checked for technical adequacy, QA program requirements,10 CFR 21 provisions, specific identification of items, and statements concerning access to the suppliers plant or records i

for purposes of audit. Procedures were reviewed to determine if responsibilities were assigned in writing for the initiation of procurement documents, the review and approval of procurement documents and making changes to procurement documents. The following procurement documents were checked along with the supplied materials documentation, including traceability to the ites: O 8

          '    i

{ \ .. .

a. purchase order #272802, studs and nuts.

b. putchase order #501647 PCR 111, fittings.

c. purchase order #501796 PCR 1, flanges,

d. purchase order #272913, pipe and fittings.

e. purchase order #501794, pipe and fittings.

No items of noncompliance or deviations were identified.

6. Document Control a.

The document control program for small bore (2" and under} safety-related piping was reviewed for compliance to r'egulatory requirements. The inspector found that craft personnel were deviating fram approved design drawings for ASME Section III Class 2 and 3 piping by re-routing lines, assigning weld numbers, and adding material in the field, PGCo engineering was unaware of these field changes made during the field installation activities, resulting in a lack of engineering control for approving the design and updating and releasing drawings. This practice was allowed regarding ASME Section III Class 2 and 3 piping by PGCo Procedure QCP-B21, Revisica 4 " Installation and/or Field Routing of Two-Inch and Under Process Piping Systems - ASME Classes 1, 2, and 3." Decisions to re route pipe which involve con-siderations such na ability to support, valve accessibility, main-tenarae accessibility, and piping contact / separation with other items important to safety were being made during the installation process by craft personnel not trained in engineering requirements. If material was to be added that did not appear on the drawing, craft personnel used the design piping tables as referenced on the drawing and selected the correct material from the design table; however, training of craft personnel in the use of piping design tables was not provided. Process piping installations deviating from approved drawings and involving craft decisions to revise,the drawings during the installation process without engineering approval, update, or release was documented by craft personnel on the following drawings: (i) M-2539C-21 (ii) M-2539C-40 (iii) M-2537A-32 (iv) M-2546C-31 (v) M-2546C-41 (vi) M-2546C-10 (vii) M-2542C-42 O 9

t (viii) M-2539A-24 (ix) H-2539A-31 The installation described on Drawing M-2546C-10 was re-rcuted, resulting in a deletion of a ninety degree elbow; however, the bill of material on the drawing was not corrected to reflect the as-built condition. Drawings M-2539A-24 and 31 had similar inconsistencies. Phillips, Getschow Internal Audit #83-22, conducted in April 1983 stated: "Considering the amount of spools inspected (21), the amount of obse'r vations noted (13) and considering that 5 of the observations would have to be addressed on a Nonconformance Report if they had been found during a walk-down it would appear that PGCo may experience

delays during the N-5 completion in order to research and resolve differences spool drawing found between field walk-down information and reworked information".

Craft personnel were documenting their field changes to drawings for Class 2 and 3, small bore safety-related piping; however, engineering personnel had no way of knowing whether these changes were in accordanc'e with all the engineering and quality requirements or whether the craft documentation of changes was complete and accurate. The failure to es' tablish measures to control field changes to drawings is a violation of 10 CFR 50, Appendix B, Criterion VI, as implemented by CECO QA Manual, QR No. 6.0 (456/83-09-01; 457/83-09-01).

b. During the review of small bore safety-related drawings, it was determined that the following field drawings were not stamped with the field change requests that affected the installations:

(i) M-2539C-4, Revision D - Field Change Request #L-9194 (ii) M-2542C-121, Revision A, Field Change Request #9988 The failure to follow PGCo Procedure PGCP-1.1, Revision 4, " Control of Engineering Change Notices and Field Change Requests," Sec-tion 5.3, which required that Document Control stamp applicable design documents with the field change request is an example of a violation of 10 CFR 50, Appendix B, Criterion V (456/83-09-02(A), 457/83-09-02(A)). [ 7. Receipt Inspection Receipt of piping components was reviewed to ascertain compliance with i regulatory requirements and comnitments in the Quality Assurance Program and implementing procedures. Responsibilities were assigned for receipt, acceptance, and release of items. Nonconforming items were revieved for identification, segregation, control and release. O 10

   , - - , - - - - , ,      - - - , , -      -,--.w- ,,,---e.          --------,--+w--~,,,    ,--w.., , - --w,,---,--   ,s,,,.-- - - , , - g --     -- - , , -, - - - , , ,- e     - , - - - - - - ----.n

I I

                                                                                       -                     i Receipt inspection reports were examined for applicable signatures,
  '                record of damage, and stipulated inspection criteria. The following receipt. inspection reports were examined:

a. MRR#13473 - 20' 3" of 3" S/80, SA-106GR.B pipe

b. MRR#13310 - 17' 11" of 4", S/40, SA-312TP316 pipe

c. MRR#13354 - 1000i of 3/4", S/160, SA-376TP304 pipe

d. MRR#8788 - 206' 8" of 4", S/40, SA-312TP304 pipe

e. MRR#8788 - 508' 4" of 3", S/40, SA-312TP304 pipe f.

MRR#12618 - 2,265' of 1&1/2", S/40, SA-312TP304 pipe 3 MRR#12618 - 2,239' of 2", S/80, SA-312TP304 pipe

h. MRR#8873 - 322' of 3" S/40, SA-312TP304 pipe

i. MRR#12436 - (20) - 3" S/40, SA-403WP304, 90 degree elbows The review of receipt inspection reports and interviews of PGCo and CECO inspection personnel revealed that neither CECO or PGCo were examining piping components for wall thickness or diameter compliance with the procurement specifications. CECO quality assurance personnel indicated that they were under the impression that PGCo was performing dimensional checks at receipt inspection. The licensee's failure to perform dimensional checks it accordance with the Quality Assurance Manual, Revision 77, Q.P. No. 7-1 is an example of a violation of 10 CFR 50, Appendix B, Criterion V (456/83-09-02(B), 457/83-09-02(B)). The licensee

{ took immediate corrective action for future shipments and revised PGCo Procedure QAP-33 to require PGCo to verify a ten percent random sampling of dimensional requirements. Previously only CECO was required to verify I. dimensions on a sampling basis. Code data reports were examined for Reactor Coolant Loop Piping, piece mark numbers LP3-CLI and LP4-CLI. The NPP-1 Data Reports were in accordance with the requirements established in Table 5.2.2., Volume 8, of the FSAR. In addition, the inspector exsmined NPV-1 Code Data Reports for the Reactor Coolant Drain Tank Pump and Reactor Vater Mike-Up Pump. The Data Reports were in accordance with Table 5.2.3, Volume 8, of the FSAR.

8. Special Proce.sses

a. Welding Program The welding program was reviewed to ascertain that controls have been implemented to assure compliance with the ASME Boiler and Pressure Vessel Code, Sections III and IX. The following Field Fabrication Process and Data Sheets were examined:

11 l

Weld Map Joint No. System (i) FW-52-3 FW-5 Feedwater (ii) FW-78 FW-78 Feedwater (iii) FW-78 FW-2A Feedwater (iv) FW-52-3 FW-3 Feedwater (v) RC-6 FW-1AP Reactor Coolant (vi) RC-3 FW-3 Reactor Coolant

b. Welding Procedures The welding procedures and welders were qualified in accordance with ASME Section IX and the feedwater welding procedures were impact test qualified in accordance with the Sargent and Lundy Piping Design Specification for the prevention of non-ductile failure. Quality Control hold points included:

(i) pre-weld (ii) cleanliness (iii) identification . (iv) alignment (v) pre-heat (vi) root pass (vii) interpass temperature (viii) final weld l

c. Cold Bending i

The cold bending program for small bore safety-related piping was reviewed to ascertain compliance with the ASME Boiler and Pressure Vessel Code, Section III. The following field bending i data reports were examined: (i) Drawing M-2546C-72, Revision A - Bend 1A Bend 2A Bend 3A

Bend 4A (ii) Drawing M-2546C-44, Revision B - Bend 1 1 .

l 12

i 4 (iii) Drawing M-2546C-42, Revision D - Bend 1A Bend 2A

    ;                                                                                                                  Bend 3A Bend 4A Bend 5A (iv) Drawing M-2546C-31, Revision C - Bend 1A d

Bend 4A Bend 5A i (v) Drawing M-2546C-27 Revision C - Bend IA 9 Bend 2A

The inspection revealed that of the five drawings reviewed, only the bends on Drawing M-2546C-27 had a documented record of the use of i

calipers for measuring the ovality of the piping af ter the bend. The failure to maintain a record of the use of inspection equipment in accordance with PGCo Procedure QAP-7, Revision 7, " Control of Inspection Equipment" is an example ua a violation of 10 CFR 50, Appendix B, Criterion V (456/83-09-02(C); 457/83-09-02(C)). PGCo Procedure PGCP-11, Revision 5, " Cold Bending of 2" and under Pipe and Tube," did not require qualifying the bending procedure for wall thickness, because thinning allowances are incorporated into the wall thicknesses for piping specified in the design engineer's design tables. An analysis by the design engineer involved maximum thickness of pipe or. tubing as received from the vendor as stipulated in Subsections NB-3642 and NC-3642 of the ASME j Boiler and Pressure Vessel Code. Since measurements of wall thick-j ness have not been made upon receipt of pipe to assure quality, as required by the CECO QA Manual, the design basis for not taking thickness measurements after bending requires further review (reference Paragraph 7). In addition, there was no record of the type of bender used in the field or that an acceptable bending process was employed. PGCo records did not indicate that bends were made in accordance with the ASME Code or PGCo Procedure PGCP-11. Pending review of the licensee evaluation of the bending process in relation to wall thickness requirements, this issue will remain unresolved (456/83-09-03; 457/83-09-03).

9. Pipina Material and Component Supports 4

e

a. Piping Material The verification program for the installation of safety-related piping materials was reviewed to ascertain compliance with regulatory requirements. The inspection revealed that PGCo did not have a documented inspection program for quality control inspectors to .

examine small bore piping components at installation to assure correct material usage. Therefore, quality control inspection records O e 13

        , . . , ..,        ..      .,     .--.,-,-_,_,,....,.,.n. , . _ , . , _ , , , , , , , , , ,,, ,    n- ,,e,.w,,    _ _ _        ,-m,.,r,ce.,       . ,,r. -,,.c-_ --m.yeg ,m w-- w . ,y.r-.

verifying exist. correct material installation for small bore piping did not This is an example of a violation of 10 CFR 50, Appendix B, g Criterion X. Since the NRC will need to review the results of the licensee's 100% verification efforts in order to fully assess the significance of the matter and to determine the appropriate enforce-ment action, this matter is classified as an unresolved item pending

    ;                    completion of the licensee's verification program and completion of the NRC's review of the results (456/83-09-04(A); 457/83-09-04(A)).
  -                     The licensee revised PGCo procedure QCP-B21 subsequent to the inspector's findings requiring that quality control perform and docu-ment examinations on installed material, consisting of a check that the heat numbers on the drawing are the same as the heat numbers on the pipe.

An audit by PGCo in April 1983, Audit No. 83-BR3, " Installation and/or Field Routing of 2" and Under Process Piping Systems," had also identified the several findings related to material traceability. Thirteen field completed drawings withdrawn from the Quality Control Field for review, deficiencies were noted on eight, such as: Where stores requests indicated the withdrawal of two beat numbers for materials of the same size, type and design, it was noted that these heat numbers had not been entered on the drawing at the locations in the plan views where they were used, and Heat numbers that were indicated on the drawings were not in agreement with stores requests. In addition, of approximately 160 pre-hydro small bore walkdown monitoring reports examined during the audit, about 60 of these repcrts identified inadequate heat number identification on drawings which should have been incorporated by Field Engineering in accordance with paragraph 5.4.3 after marked-up drawings were returned from the field. Examples of the deficiencies identified in the pre-hydro walkdown for small bore piping included: Drawing M-2538C-3, Revision A, no heat number on pipe between weld 12 and 13. ' Drawing M-253BC-1, Revision 0, no heat nambers on pipe. Drawing M-2539C-20, Revision 0, no heat number on pipe between weld 3 and 4. Drawing M-2539C-14, Revision A, ne visible heat number on coupling. The inspectors examined installed small bore piping lines identified on the following drawings: O 14

M-2542C Sheet 41 M-2556A Sheet 14

  *i                                       . M-2539A             Sheet 37 M-2539A             Sheet 24a M-2539A             Sheet 31 M-2537A            Sheet 37 M-2537A            Sheet 53 These pipe runs included approximately 120 items, of which 107 were identified with heat or mark numbers on the component. The remaining 13 did not have a heat or mark number that was readable on the item production documentation, either on the drawing or the stores request was available that agreed with the certified material

test report. The production documentation was initiated by crafts-men involved in the work.

In addition to the small bore piping programmatic problems, PGCo did

                              .not have a documented inspection program for quality control inspectors to verify correct material installation for large bore piping prior to Revision 12 of the PGCo QA Manual, dated November 19, 1982. Therefore, quality control inspection records verifying correct material installation for large bore piping did not exist prior to November 19, 1982. This is an example of a violation of 10 CFR 50, Appendix B, Criterion X.                              Since the NRC will need to review the results of the licensee's 100% verification efforts in order to fully assess the significance of the matter and to determine the appropriate enforce-ment action, this matter is classified as an unresolved item pending completion of the licensee's verification program and completion of the NRC's review of the results (456/83-09-04(B); 457/83-09-04(B)).

Following the NRC inspection findings, on July 1, 1983, Commonwealth i

Edison submitted a 10 CFR 50.55(e) report identifying a potential deficiency concerning quality control verification and documentation 4 of heat or mark numbers of installed piping system components. CECO believed that this verification was done by comparing the mark number documented on the stores r,equest with the installed component mark l number but had not been documented. Six piping inspectors interviewed ! stated that they had verified correct material installation but had I ' not documented the verification. The licensee's project management believed that only a documentation problem existed. The licensee stated in the July 1,1983, 50.55(e) report that a sample inspection of installed large bore piping and installed small

bore piping would be performed. The large bore sample would be l selected from piping components installed prior to November 1982. The l sample was divided into four areas

Small Bore Piping Phillips Getschow Stock Material, Large Bore Piping Southwest Fabricating Surplus Material, Large Bore Piping , i e 15

        - , - -   .4- - ,. -,y--_r-.----,,         ,.7---r-,-.- .----.,-7,,.,,_,,,-r,        .,.-+---,m,ww...,.. ..----,r-,,-.,- ,%v.-,. ...--w-.-%-,.--,,,w,,-----n.,s,

Piping Spools identified with Manufacturer's ASME Nameplates. ! f ' The independent sample verification was conducted by Phillips Getschow quality control personnel and revealed the following: Small Bore Piping Items in Sample (Represents 15%)

                          .                                                  1415 Traceability by Markings on Hardware                             1250 Traceability by Production Documentation                        1383 Only Production Documentation /No Markings on Hardware                                           163 Items Missing Production Documentation                             32 (stores request)

The following small bore items.were dispositioned to be removed: Installed Drawing Item ASME Class System M-2534C 1" S/40 SA-376 2 Safety Sheet 95 TP 304 Pipe Injection (Drawing required 1" S/160 pipe)* M-2537C Unknown 3 Component Sheet 40 2" Pipe Cooling (Lack of traceability of item - no markings or documentation.)

Subsequently, the licensee examined and measured the wall thickness of pipe installed on all additional drawings where more than one schedule or wall thickness of pipe was required.

This was in addition to the 1415 item sample, and was done because the piping contractor could not verify through the stores request system correct wall thickness installations. The stores request system specified the drawing where the pipe was to be used but not the location on the drawing. Therefore, where two different wall thicknesses were required for one drawing assurance of correct placement could not be established. The licensee's efforts identified three pieces of pipe that were incorrectly placed resulting in schedules or wall thicknesses of pipe not in accordance with the drawing and Sargent and Lundy design. These pieces which are identified below were disposi-tioned to be removed. O 16

                            ~ - . - . ---.----                   . . . - . .        ..-.- - - - - -

i i

Installed Drawing Item (SME Class System I - M-2546C 3/4" S/160 2 Sheet 90 Chemical Feed SA-312 TP304 and Volume Pipe Control M-2546C 2" S/160 2 Sheet 18 Chemical Feed SA-312 TP304 and Volume Pipe Control (Both items required S/40) M-2539C 1" S/40 2 Safety Sheet 93 SA-312 TP304 Injection Pipe (Drawing required 1" S/160)

         .Large Bore Piping (Phillips Getschow Stock)

Items in sample (represents 11%) 371 Traceability by Markings on Hardware l 268 Traceability by Production Documentation 306 Only Production Documentation /No Markings on Hardware 100 Items Missing Production Documentation 65 (stores request) At the end of the NRC inspection the licensee indicated that the following three installed items appeared to require removal due to lack of hardware markings and documentation traceability: Installed Drawing Item ASMI Class System 2A-AF-25-13 Unknown 3 Auxiliary 4" Pipe Piece Feedwater 2A-AF-23-4 Unknown 3 Auxiliary 4" Pipe Piece Feedwater 1A-SI-11-7 Unknown 2 Safety 4" Pipe Piece Injection Large Bore Pipina (Southwest Fabricating Surplus) Items in Sample (represents 20%) 81 Traceability by Markings on Hardware 52 Traceability by Production Documentation 42 Only i'roduction Documentation /No Markings on Hardware 28 e 17

                                                                           -    -     ~ ,,- ,m -.-   * - _ - - -     ----.r-y-

Items Missing Production Documentation 39 (stores request)

               ~ At the end of the NRC inspection the licensee indicated that one installed ites appeared to require removal due to lack of hardware markings and documentation traceability as detailed below:

1 Installed Drawing Ites ASME Class System 1A-SX-93-1 Unknown 3 Essential 4" Pipe Piece Service Water Large Bore Piping (Nameplates) Items in Sample (represents 7%) 110 Traceability by Markings on Hardware 110 Traceability by Production Documentation 101 Items Missing Production Documentation 9 (stores request) In addition to not having established an inspection program requiring verification and documentation of correct material installed, the sample inspection performed by the licensee revealed additional l information that heightened NRC concerns for the following reasons: Four small bore piping items were not the specified wall thickness and were examples of a failure to control material , installation and execute an inspection program to assure the quality of installed items. The licensee stated that material was v'erified as being correct, although not documented, and the method the inspectors employed was checking the heat number or mark number against the stores request. Since numerous stores requests (based on the sample) cannot be found, the verification method (checking the stores request for all items) by all inspectors remains in question. Furthe rmore , retention of the stores request was a program requirement, documenting that the correct material was withdrawn and that it was withdrawn from a safety-related storage area. Numerous sample items did not have hardware identification markings, resulting in these items being of indeterminate

quality, as independent inspection records verifying correct material at installtion did not exist. The indeterminate quality was a further example of a failure to control material installation and to execute an inspection program to assure the quality of installed items.

The licensee has decided to perform a 100% inspection of all installed piping components in order to: 18

Comply with the ASME Code and 10 CFR 50 Appendix B.

   *                                 ~  Verify correct material installation by hardware markings where available.

Establish confidence in production documentation where no hardware markings exist by comparing production documentation against the hardware markings that do exist, thereby assuring , that craftsmen were well trained and installed only acceptable i material as reflected in their records. The 100% inspection does not include large bore piping installed after November 19, 1982, where documented inspection records do exist for the items. Additionally, the NRC inspection revealed that when a piping spool was cut the heat number markings were required to be transferred

                             .by craft personnel to maintain traceability. Quality control verified the transfer of heat numbers only on a sample basis. This sample basis, for assurance of correct transfer, was being reviewed by the licensee for possible. corrective action and will remain an unresolved item.       (456/83-09-06; 457/83-09-06)

A review of Phillips, Getschow Nonconformances #792 and #793 was performed and the inspector found that the nonconforming conditions were being adequately controlled. Nonconformance #792 resulted from a design change by Sargent & Lundy requiring an ultrasonic examination of numerous lengths of previously installed small bore pipe, and nonconformance report #793 resulted from a design change requiring a liquid penetrant examination of previously installed small bore fittings. These design changes were incorporated due to l the possibility that the requirements of ASME Boiler and Pressure Vessel Code, Section III, NB-3673, Special Design Requirements j would not be met. The disposition of the nonconformances was to cut out and replace some of the pipe and fittings and further analyze the remaining pipe and fittings for design acceptability to the requirements of NB-3673. Certified material test reports were reviewed for installed piping components anc were found to be in compliance with ASME Code requirements. Certified material test reports were reviewed for randomly selected ASME Boiler and Pressure Vessel Code, Section III, NB, Class I material in storage and for the installed material identi-fled on the following reactor coolant drawings: M-2542C Sheet 38 M-2542C Sheet 50 M-2542C Sheet 5 The test reports were in accordance with the piping design tables and the ASME Boiler and Pressure Vessel Code. e 19 I

l

b. Component Supports The component support program was reviewed to ascertain compliance with the ASME Boiler and Pressure Vessel Code, Section III, Subsection NF. The following component supports were reviewed:

System Support Number Component Cooling' M-1CCO2007R, Revision E Fire Protection M-1FP16010R, Revision B Residual Heat M-1RH02017R, Revision E Safety Injection M-ISI16021X, Revision B Residual Heat M-1RH050035, Revision C Chemical and Volume Control M-ICV 01039R, Revision D Changes were identified on component support drawing M-1RH02017R from Revision D to Revision E and drawing M-ISI16021X from Revision A to Revision B. Both drawing changes involved ASME, NF welds. Rework of M-1RH0217R was completed on June 20, 1983, without a Field Change Order. Rework of M-ISI16021X was completed on May 9, 1983, without a Field Change Order. The failure to initiate a Field Change Order in accordance with PGCP-4, Revision 0,

                 " Control of Rework of Component Supports," is an example of a violation of 10 CFR 50, Appendix B, Criterion V (456/83-09-02(D)).

The hanger check list traveler included quality control hold points for:

                 - location
                 - clamp condition
                - locking devices
                - torque plumb of cold position pin to pin distance
                - welding
                - condition of assembly O

20

                         - proper material
                         - hanger number
                               ~

i

                         - self aligning bushing free
                         - angle of strut or snubber in tolerance ASME Section III NT welds were controlled with a Weld Data Traveler                             )

and each weld was assigned a unique number. The drawings categorized supports as " plate and shell" or " linear" for material requirements according to ASME, NF-2130; and " primary or secondary," and " plate and shell," " linear," or " component standard supports" for nonde-structive examination requirements according to ASME, NF-5200. The drawings referenced the specific section of the NF code for nonde-structive examination.

10. Measuring and Test Equipment Procedures were reviewed to verify that controls have been established concerning measuring and test equipment which set forth the criteria and responsibility for assignment of calibration frequency; a formal require ment for marking or f ientifying calibration status for each piece of equipment; a system which assures that each piece of equipment was calibrated on or before the required date; a written requirement which prohibited the use of equipment beyond its calibration period; controls preventing use of out-of-calibration equipment; and controls for evalu-ating the status of equipment and items previously tested or measured using the equipment found to be out-of-calibration.

Calibrated equipment was certified in accordance with the National Bureau of Standards. Storage of calibrated equipment in the field was adequate for preventing damage due to temperature / humidity conditions or contact with other items. The following pieces of equipment were examined for acceptable storage, proper certifications, identification, and that calibration frequencies were being adhered to: Torque Wrench #TRW-8 Inside Micrometer #1M-1 Volt Ammeter Box #VA-PG-002 Contact Pyrometer #CP-01 Dial Indicator #PG6-MW Torgometer #TM22-MW Torque Wrench #8AMW i Torque Wrench #8AMW was found out of calibration on October 22, 1983, ~ and an evaluation was done for items previously tested. . m 21

No items of noncompliance or deviations were identified.

11. Nonconformance/ Corrective Action The inspector reviewed this area to verify that measures have been established to identify and correct conditions adverse to quality.

Corrective action taken to preclude repetition was also examined. The following piping nonconformances were reviewed:

                                              #841 - minimum wall violation
                                               #849 - welding deviation
                                               #852 - welding deviation
                                              #870 - spool damage
                                              #1031 - documentation error
                                              #690 - procurement deviation
                                              #693 - procurement deviation
                                              #697 - procurement deviation
                                              #796 - fit-up gaps
                                              #816 - welding procedure error
                                              #13 - undersized welds'
                                              #801 - filler metal deviation
                                             #789 - inadequate records for small bore pipe The nonconforming conditions, with the exception of Nonconformance #789, were properly identified and corrected. Measures were implemented to prevent recurrence of the nonconforming conditions where applicable.

Nonconformance #789, dated September 17, 1982, stipulated that 1/2" S/80, SA-312 Type 304, ASME Boiler and Pressure Vessel Code, Section III, NB pipe, heat number 745107, was discovered in Section III installations without material test reports or records of receiving and receipt inspec-tions by either CECO or PGCo. The PGCo initial disposition was to cut out and replace this piping. The CECO final disposition stated, " Attached are CMTR's for 1/2" S/80 pipe. It may have been received as S/160". Records of receiving and receipt inspection existed for 2,662' 9" of 1/2" S/160 SA-376 Type 304, with the same beat number. The 1/2" S/80, SA-312 Type 304 was approved as an acceptable heat of material by CECO and PGCo without performing examinations for markings, damage, or dimensions, and i there were no receiving records or receipt inspection record verifying quality or quantity. The certification for the 1/2" S/80 pipe was for 746' 7", but the licensee and PGCo were unaware of the amount of pipe received. Another nonconformance report, #1128, was written by PGCo on 6/28/83 for the 1/2" S/80 pipe, after the inspector identified the deficiencies. The failure to correct the nonconforming condition con-(_ cerning the 1/2" S/80 pipe is an example of a violation of 10 CFR 50, Appendix B, Criteria XVI (456/83-09-07(A); 457/83-09-07(A)). i l t l l l . I 22 1 _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ - ~ . . . _ - _ _ _ _ . _ . _ _ _ - - . _ . . _ , . _ _ _ _ . _ . - . . _ _ _ _ _ _ _ . . _ _ . _ . - . _ _ _ _ . --

s -

12. Audits i

The licensee's a~udit program of the piping contractor and the piping contractor's audit program was reviewed to ascertain compliance with ANSI N45.2.12, ANSI N45.2.23, and implementing procedures. The following piping contractor audits were reviewed:

             - Process Control, Small Bore Piping, 4/12/83 - 4/20/83
             - Welding Controls, 3/29/83 - 3/31/83
             - Documentation Control, 5/10 5/18/83
             - Process Control, Large Bore Piping, 2/22/83 - 3/11/83 The following licensee audits of the piping contractor were reviewed:
             - QA-20, 82 Instrumentation Design and Installation, 2" and Under Pipe Design and Installation, June 1982.
             - QA-20, 82 PGCo Q.A. Manual Sections 10, II, 12, 14, 15, 16, 17 and Applicable Procedures, October 1982.
             - QA-20, 82 Pipe Supports / Whip Restraints, April 1982.
             - QA-20, 83 Large Bore Pipe Installation, Personnel Qualifi-cations, Weld Rod Control, Storage Control, PGCo Q. A. Manual Sections 12, 13, 14, May 1983.

The audits performed were in accordance with a pre-determined schedule included pre-established questionnaires for depth and continuity, and contained objective evidence and evaluation statements concerning the audits. Pre and post audit conferences were held. The certifications for the PGCo lead auditor were examined and found to be in compliance with

ANSI N45.2.23. Responsibilities for corrective action were assigned to specific individuals and findings were followed up for correction of the concerns.

After review of the PGCo audit schedule and discussions with the PGCo lead auditor, the inspector learned that PGCo had not established and executed a plan for auditing the implementing procedures of the quality assurance program on a periodic basis to determine the effectiveness of the program. PGCo was required by Section 16 of its QA Manual to audit the entire QA manual annually, but no requirement existed to audit the implementing procedures such as the Quality Assurance Procedures, Quality Control Procedures, or Construction Procedures in a specified time period. These procedures were being audited on a random basis, without regard to complete coverage in Any period of time. For example, a review of audits in the welding area revealed the following audits not performed:

            - QCP-B7, Ferrite Control of Stainless Steel Field Welds
            - QCP-B20, General Repair Procedure i
            - P QCP-2, Reforming of Pipe Ends and Welds
            - P QCP-13, Preparation of Welds for In-Service Inspection        ,

e 23

Failure to establish and execute a comprehensive audit plan is an example of a violation of 10 CFR 50, Appendix B, Criterion XVIII f (456/83,09-08(A); 457/83-09-08(A)).

13. Small Bore Pipina Desian The inspector reviewed site design control measures for safety related process and instrumentation small bore piping (2" and under). Process systems installation started in July 1981. Instrumentation systems installation started in March 1981.

a. Review of Procedures and Specifications To assess the overall program adequacy, the inspector reviewed the following document... ions: .

Phillips, Getchow Co. (PG) Quality Control Procedure (QCP) B21, " Installation and/or Field Routing of Two Inch and Under Process Piping Systems - ASME Classes 1, 2, and 3", Rev. 4, dated December 3, 1982, including " Supplement For Contract," dated July 22, 1983. PG Construction Procedure (CP) 22, "2" and Under and 2\"-4" Process and Instrument Line Supports in Category I Buildings," Rev. 7, dated April 16, 1983. PG QCP B23, " Installation and Inspection of Component Supports," Rev. 4, dated May 11, 1983, including " Supplement For Contract," dated May 11, 1983. PG CP 40, " Verification, Preparation and Transmittal of 'As Constructed' Drawings," Rev. O, dated May 31, 1983. Pertinent portions of S&L Specification F/L-2739, " Piping System Installation (Section III and Non-Section III) Byron Station - Under 1 and 2, Braidwood Station Units 1 and 2," Amendment 4, dated July 22, 1982. Findings: (i) Per PG Procedure CP 22, PG was authorized to construct Category I (safety related) 2" and under process and instru-mentation piping with a maximum operating temperature of 150*F, as directed by S&L design guides. Design tasks of: (1) pipe support location and type and routing analysis, (2) documenta-tion of design on routing and structural drawings, (3) hanger detail drawings / material documentation, and (4) design review / documentation of design acceptability were performed. In view of the many program and computation deficiencies and errors identified during the inspection, it became apparent that neither the licensee nor the AE had performed sufficient assess-ments and verifications to determine the adequacy of EG design capabilities, program provisions, or effective procedure imple-4 mentation. 24

l (ii) The'" field running" of Class 2 and 3 small bore piping allowed field engineering to change the design pipe routing ( without prior concurrence from the AE. The AE would not assess the design adequacy of the systems until near turnover for system testing. At that time, PG would prepare "as constructed" field routing drawings and "as built" pipe restraint drawings which would then be reviewed by S&L. These design provisions

and control measures are contrary to the licensee QA program

.                                                                        which required: (1) installation and inspection to be in I                                                                         accordance with the reviewed and approved up-to-date design
;                                                                        drawings, (2) utilization of the Field Change Request (FCR)                        l system to minimize the risk of drastic alterations or modifica-                    '

tions after system component installation, and (3) timely identification of any nonconformances, and implementation of i swift and effective corrective or preventative measures. Items (i) and (ii) are examples of a violation of 10 CFR 50, Appendix B, Criteria II and III (456/83-09-09(A); 457/83-09-09(A)). (iii) S&L Specification F/L-2739, Paragraph 301.11, " Installation of 2" and Under Piping", states:

                                                                         "For two inch and under piping, Sargent & Lundy drawing numbers

. M-2535A through M-2616C, released under an alpha revision except an alpha revision released for ' Record Revision Only':

;                                                                        (1) "All dimensions and configurations are conceptual to

, provide the basic routing of each specific 2 inch and under piping system. Should conflicts or interferences occur, the piping may be rerouted using care and judgment, so as to provide sufficient clearance around electrical switchgear, instrument panels and other equipment, structural features, etc., to facilitate good routing j practice, (i.e., valve accessibility, interference elimina-tion, maintenance accessibility, the ability to properly support, etc.); and to provide a minimum of 3 inch clearance from other process piping and instrument sensing lines. The original dimensioned routing and configuration shall be followed throughout the pipeline except in the area required to clear the conflict or interference." In review of the PG QCPs and cps, the inspector determined there was a lack of specific quantitative acceptance criteria to provide small bore Class 2 and 3 piping with sufficient clearance or separation from electrical switchgear, instrument panels, etc., as delineated in the S&L specification. This is an example of a violation of 10 CFR 50, Appendix B, Criterion III (456/83-09-09(B); 457/83-09-09(B)). i 1 O 25

b. Review of PG Calculations i

i The inspector reviewed the following PG small bore Class B, C, and H, ; (ASME 2, 3 and instrumentation), piping with maximum operation i temperature of 150'F: (i) Lines ICCE3AA-\" and ICCE3BA ", a Class H instrumentation line connecting to ICCA2A-3" at F1. El. 394'-7". Findinas: The design pipe weights and spans were per S&L ECN 4566. However, valve weights and component weights were not documented in the calculation. Root valve (isolation valve) weights were not taken into consideration per verbal instructions. The designer was not aware that verbal exceptions to the procedure were not acceptable. Restraint IFIS CC063-H5A-6 showed a calculated load of 23 lbs. The type H5A support data from S&L Drawing M-5010,

                            " Instrument Line Supports Typical Details," Rev. D, dated August 29, 1983, showed:

Cantilever Length Maximum Load (L) (ft) (P) (1bs) 1.5 25 2.0 16 The designer did not use the above design data and incorrectly selected L of 2.0 feet based on PG Hanger Drawing No. HSA, Rev. 1, dated April 14, 1980, where it stated: L (ft) max. P (Ibs,1 2.0 40 (ii) Line 1D0D8BC-2", Diesel Oil in Auxiliary Building at F1. El. 383'-0". Findinas: The design was based on S&L ECN 2715, dated July 2, 1982, which was subsequently incorporated in S&L Specification F/L-2739, Amendment S, dated February 18, 1983. Since the calculation was performed after May 1983, ECN 4566, "Providing Installation and Support Selection Guidelines

l 26

                             --m  e----,------       -----,r-   .,- ,---,----y- - - - .e - - - n,------m-,,-      ,w, - - - - -   ---,--,---,--,---,----e,-- ren,----- -

for Process Piping, Instrumentation Piping and Tubing in Category I Building, Rev. 2," dated May 14, 1983, including j - Table IV, " Span Length (Ls) and Weight Data, Uninsulated Pipe", should have been used. The pipe coupling weight was not considered in the calcu-lation based on PG-Information Request (IR) No. 2101, dated October 21, 1982, which requested that coupling weights should not be considered in small bore support calculation. The IR was approved by S&L on October 21, 1982. The inspector stated that the use of an IR in lieu of an FCR to change design requirements was not in accordance with licensee QA program provisions, requiring final design deviation review and approval, and update of affected drawings. (iii) Line ID0D8BA-01, shown on Drawing No. PG 2556A-15, the calcula-tion was signed on July 14, 1983, and was reviewed and approved on July 19, 1983. Findinas: The lack of a documented step-by-step pipe span measure-ment and dead weight load determination. The latest calculation which was performed during the inspection showed the following discrepancies between calculations based on as-built drawings and previous calculation dated July 14, 1983. Calculation Calculation dated dated October 6, 1983 Hanaer No. July 14, 1983 (date of RIII inspection) Span / Load Span / Load 1D003AB- (ft) (1bs) (ft) (1bs) 01 '6 /64 5.5 /40 02 6.9/36.5 6.75/58.5 , 03 12 /38.1 8.65/53 04 8.7/39 6.8 /30 05 7.2/31 6.85/30.2 The failure to include the correct component weight in the pipe span mass calculation was largely contributed to the fact that the valve weight proportionment design methods described in PG CP 22 had not been followed by the designer. This is an example of a violation of 10 CFR 50, Appendix B, Criterion III. (456/83-09-09(C); 457/83-09-09(C)). 27

        . q~---   n-, - ~ ~ - ,, , - , , - - , , - - - - - , , - -   ,,,,,,-.e,-,ww r,,-----  ,,w,--rw--w-r-m  r----m--,m._mm,,n_--,m-,n--_,,,--                   - - - -----

In view of the many errors observed during review of the calculation, and the absence of PG design checking and verification procedures, the inspector requested to inter-view the individual (with initial RS) who reviewed and approved the apparent erroneous calculations on October 6, 1983. The PG management informed the inspector that the t reviewer had called in and resigned the same morning. {

c. PG Personnel Authorities, Duties, and Qualifications Findinas:

(i) The inspector reviewed PG Site QA Manual, Rev. O, dated

August 26, 1983. Section 1.19, " Field Engineer," (FE) states that "The FE shall have no design responsibilities...." The stctement is contrary to the PG procedures listed in Paragraph 13.a above. PG QCPs and cps assign the FE responsi-bility for the design of small bore pipe routing and some calculation responsibility for safety-related small bore pipe supports. F.urthermore, qualification and training requirements commensurate with the FEs' authorities and duties had not been established in procedures. This is an example of a violation of 10 CFR 50, Appendix B, Criterion II (456/83-09-09(D);

457/83-09-09(D)). In view of the many errors that were observed during the review of PG calculations, the inspector reviewed the designers' (Hanger Selectors) qualification and past training. The inspector reviewed PG CP 29, " Qualifying and Training i Procedure for Hanger Selection Personnel," Rev. 5, dated June 22, 1983. PG CP 29 ccasiders that personnel with a high school education or one year in hanger work to be qualified. Training includes familiarization with design documents and

receiving documented training of PG CP 22 requirements.

The inspector reviewed resumes of all six Hanger Selectors (initials: LG, WH, JL, EG, SC, and WS) and noticed that they i were all high school graduates, but had no prior hanger or l restraint design work experience. Based on the many calculation i errors, the inspector's interview with some of the designers j discussions with licensee and PG management, and observation l of the site design control activities, the inspector determined i that the training program for the Hanger Selectors did not assure that the individuals had achieved and maintained suitable proficiency. This is an example of a violation of 10 CFR 50, Appendix B, Criterion II (456/83-09-09(E); 457/83-09-09(E)). l l i

28 l

l

        .         d. Review of PG Information Request (IM) System l

I. As discussed in Paragraph 13.b(ii) above, pipe coupling weight was nbt taken into consideration due to incorrect utilization of the IR system. The specific IR involved was No. 2101, dated October 21, 1982. During further investigation of the problem, the inspector revealed l that approximately 5300 irs had been issued prior to PG management's ! decision to better control the system, and to provide better distri- :

 -                      bution of these irs by developing a new system format. The inspector                                                        '

reviewed the 68 new irs with revised format, starting on September 1, 1983, and determined that some problems still existed. The specific

case observed was IR No. 6 issued on September 8,1983, and approved on the same date. On this IR PG requested and S&L approved substi-i

tuting A-155 CM65 material for A-155 CM70 material. The use of the IR in lieu of the FCR system is contrary to the licensee's QA design control program and compromised final design change acceptance review and approval. This is an example of a violation of 10 CFR 50, 4

Appendix B, Criterion III (456/83-09-09(F); 457/83-09-09(F)). e. Review of Licensee Site Desian Control Audits The inspector reviewed the pertinent portions of the following CECO QA Audit Reports: No. QA-20-83-33, July 5-12, 1983

                               " Instrumentation Installation 2" and Under Piping Installation, Material Traceability, Design Change" (5 findings; 3 observations)

No. QA-20-82-15, June 24-29, 1982

                              " Instrumentation and Small Bore Pipe Installation" (3 findings; 3 observations)

No. QA-20-82-12, April 20-23, 1982

                              " Hanger Installation: 2" and Under Pipe Insta11aton" (no finding; 1 observation)

No. QA-20-81-30, February 29 through October 1,1981,

                             " Instrumentation System Layout Activities" (7 findings; 3 observations)

Findings similar to those discussed in Paragraph 13.b were also uncovered by the CECO audit team. Finding No. 5 in report QA-20-83-33 states:

                             " Contrary to 10 CFR 50 Appendix B Criterion III, Support Loading calculations are being performed to a procedure that does not clearly define the step by step approach for performing the calculation. Furthermore, the current ECN utilized for the calculation activity has not been incorporated into PGCo's Procedure PGCP-22. Also, the drawings from which rated loads are obtained are not referenced on the calculation sheets.

0 29

                                              . w w w - w ,w r,,-,-,~-*---yme-,-v---em,--------ma_wv--wmw-m-w-~----o-           - , ~ - - - - - ---

Discussion:

                                     . 1. The following calculation sheets are used to document the results of hanger selection calculations:

Instruments: " Restraint Calculation Sheet" 2" and Under: " Support Calculation Sheet" Procedure PGCP-22 states that these forms will be used to document the results of the calculations. The procedure did not give the actual step by step method for performing the calculations to arrive at the results written on the calculation sheets.

2. ECN 4566 is the current document to be followed for the support selection activity. PGCP-22, Rev. 4, currently references ECN 2715 only.

3. The typical hanger used is listed on the calculation sheet by hanger number. The revision of the drawing from which the rated load is taken is not referenced. As a result it is difficult to determine which revision was used to establish the rated load for the load calculations.

Also, the references for the weights of fittings, valves, instruments, etc. are not shown on the calculation sheets. As a result it is difficult to determine the origin of the load values listed." The site installation of small bore instrumentation piping began before March 1981, and the small bore process piping before July 1981. Two years had passed prior to the Ceco design audit findings. Based on the above findings the inspector concluded that the site design control deficiencies had not been identified and corrected in a timely manner. Inadequate audits it an example of a violation of 10 CFR 50, Appendix B, Criterion XVIII (456/83-09-08(D); 457/83,-09-08(D)). Based on the many programmatic and implementation deficiencies described above the inspector concluded that the licensee control over the site small j bore piping design activities was inadequate and ineffective. Subsequent to the inspection, PG management suspended the Engineering Department Support Selection Program for process piping and instrument piping and tubing in Category I Buildings on October 10, 1983, until the program could be evaluated for compliance to S&L Specification L-2739 and PG Procedure CP-22. CECO letter, BRD No. 9627, "PG Co Letter B-B-531, , dated 10/10/83," dated October 11, 1983, concurred with PG's decision, and requested PG to maintain this suspension until written concurrence to resume this activity was obtained from CECO. i 4 e 4 30

I An exit meeting was held at the site on October 24, 1983, during which CECO presented corrective actions for the design, installation, and inspection of the small bore Class B, C, and H safety related piping systems with operation temperature less than 150*F. Program improvements include: (1) more specific installation tolerance and acceptance require-ments, (2) upgrading of PG procedures to provide better feedback to the A-E, (3) improvements in the PG hanger selection calculation format and review verification, and (4) expanding the A-E and Ceco engineers' role in field pipe routing design changes and overview of PG support selections. Region III management representatives requested licensee representa-tives to: (1) conduct comprehensive QA/ technical audits prior to the, lifting of the stop work order and (2) perform a detailed evaluation by the A-E to determine effectiveness of PG improved design program, and adequacy of the A-E design guidance and control. e e e O O 31

       .b .

l SECTION II Electrical Contractor

1. Persons Contacted Ceco Personnel D. Brown, QA Coordinator, Electrical D. Cosaro, Construction Manager C. Mennecke, Project Construction Lead Electrical T. Sommerfield, QA Superintendent L. Tapella, Project QC Coordinator Electrical Contractor Personnel B. Brown, Lead Inspector, Level II, L. K. Comstock Engineering Company (LKCEI)

T. Corcoran, QC Manager, LKCEI J. Facchina, File Clerk, LKCEI W. Gardner, Manager, QA/QC Services, LKCEI N. Kimble, Level II Inspector, LKCEI M. Lechner, Inspector Trainee, LKCEI P. Pysell, Assistant QC Manager, LKCEI T. Rolan, QC Analyst, LKCEI C. Tyler, level II Inspector, LKCEI J. Barnes, Engineer, L. K. Comstock Company (LKC) J. Blanchette, Document Control Supervisor, LK3 , K. Easton, Document Centrol, LKC J. Hii, Project Engineer, LKC V. Kilgove, Area Foreman, LKC R. Koslowski, Document Control, LKC M. Mangra, Area Engineer, LKC F. Rolan, Project Manager, LKC R. Thompson, Area Manager, LKC,

2. Quality Assurance Program A review was performed of the Electrical Contractor's QA Program Manual as follows:

a. Licensee Approvals The inspector reviewed the licensee's acceptance of the LKC/LKCEI QA Program documented in the following letters of acceptance.

February 8, 1979, accepting the submitted manual for use at the Braidwood site. August 13, 1980, accepting the program as revised effective May 1, 1980. O 32

       . l May 26, 1982, accepting the revised program effective May 12, 1982.

i, .

b. Proaram Manual Review 3 The inspector reviewed the latest revision of the QA Manual sections, numbered and titled as follows.

                                                  - 3.0 QA Program
                                                  - 4.0 QC Program
                                                  - 4.1 Site QC Organization
                                                  - 4.2 Drawing and Specification Control
                                                  - 4.3 Work Instructions
                                                  - 4.4 Procurement Document Control
                                                  - 4.5 Supplier Evaluation
                                                  - 4.6 Control and Identification of Equipment and Components
                                                  - 4.7 Control of Special Processes
                                                  - 4.8 Inspection and Tests
                                                  - 4.9 Control of Measuring and Test Equipment
                                                  - 4.10 Handling, Storage, and Shipping
                                                  - 4.11 Nonconforming Items and Corrective Action
                                                  - 4.12 Test Control
                                                  - 4.13 QC Records
                                                  - 4.14 Audits

c. Items Discussed The inspector requested clarification of certain items reviewed in the QA Manual.

(i) It was noted that in Section 4.8 a Sampling Plan was included and that several of the detailed inspection procedures included a sampling plan to a "not less than" minimum (i.e., 4.8.1, Inspection of Class IE Safety Related Conduit Installation", not less than 35% of installed conduit). l In response to the inspector's concern, the CEI QA Coordinator Electrical stated that the contractor has been elevated to a 100% inspection coverage for all activities, and that it was

  ,                                                                   considered unnecessary to revise the procedures since 100%

inspection was compliant to the procedures as written. (ii) It was noted that several procedures indicated that inspection was to be done by a Level I or Level II inspector, it was explained that Level I and/or Level II Inspectors could perform

inspection coverage as necessary; however, it was explained: i. that when Level I inspectors perform the inspection activity, it is necessary for a Level I inspector to review the inspection coverage and report,and sign as approved.

No items of noncompliance or deviations were identified. i 33 l i

       ._   _ . . . _ _ _ . , _ . , , . ~ . _ _ , . _ _ _ _ . . . . _ , _ . _ _ _ _ _ . _ _ _ . . _ . , _ . _ _ _ _ , _ _ _ , _ _ _ , _ , . . . _ _ . _ . _ . , _ . _ _ _ , . . _ . _ _ , _ . . _ _ _ _ _ . . . . , , _ _ , - _ . _ -

3. Implementation Proaram by the Electrical Contractor

Program activities currently in progress by the electrical contractor, were reviewed by the inspector as follows:

a. Staffina and Qualifications of Inspection Staff (i) The inspector was informed that the LKC inspection staff was at authorized levels and that the staff, as broken down below, was considered to be adequate to perform adequate and timely inspection coverage.

(1) Total Staff (approx.). . . . . .37

(2) Level III Inspectors . . . . . .1 (3) Level II Inspectors. . . . . . .25 (4) Level I Inspectors . . . . . . .5 (5) Clerical . . . . . . . . . . 4 The above staff represented a 1/10 ratio of inspection staff to total construction work fo ee, which the contractor considered normal. (ii) The inspector qualification program was reviewed by the inspector with the'following results. (1) The master qualification list was reviewed which showed the areas of qualification of all inspectors, the recertification due date for each area or discipline and certification completion date. (2) The inspector selected a sample of one inspector per performance level (including trainee) from the qualifi-cation list, for a total of four inspectors. A review of their qualification, training and certification records (as depicted on the master list) was performed. Those selected were as follows: Level III QC Inspector l

Level II QC Inspector Level I QC Inspector Trainee The records were complete and up-to-date for each sample reviewed. In the case of the trainee selected, the file folder was in place and those training / qualifications I

activities accomplished to date (i.e., eye test and self-reading log) were present in the folder. 34 i

(3) The inspector observed a field-conducted on-the-job training session. A one-on-one training activity was ' being conducted. A Level II QC Inspector accompanying a trainee while the trainee performed inspection activity of cable terminations. The instruction by the Level II included such parameters as: (a) how to locate terminal blocks involved, and (b) inspection of terminations for crimp, tightness, and location of conductor in crimp ferrel. A good exchange of information appeared to be taking place. ?

b. Auditina Performance

            *     (i) The LXCEI corporate auditing activity is performed on a

} quarterly basis to accomplish a complete program verification on an annual basis. The 1983 approved corporate office audit schedule.for the Braidwood site was reviewed. The schedule, issued as a meno on March 18, 1983, listed four audits to be performed as follows: Date of Audit Criteria to be Covered March 15, 1983 III, VI, XIV, XV June 28,1983 IX, XVIII September 20, 1983 X, XII, XVII December 6, 1983 I, II, V, XIII The first scheduled audit was performed on April 12-14, 1983 (report number CQA-313) and covered Criteria III, VI, { XIII, XIV, and XV with no adverse findings being identi-fled. The inspector also observed a meno which provide notice of the second audit, scheduled for June 28-30, 1983, covering Criteria IX and XVIII (delayed until a later date because of i the inspection coverage in progress during that period of time at the site). The inspector requested the corporate audit reports for the last half of 1982 for review. The reports and criteria covered by the audits were reviewed by the inspector as follows. Audit Report Number Date of Audit Criteria Covered CQA-250 December 16-17, 1982 XIV & XVIII CQA-182 September 21-22, 1982 III, VI, & XII 4 4 Neither the auditing coverage performed and/or schedul'e'd from l mid-year 1982 through mid-year 1983 nor the audit schedule established for the year 1983 would provide complete program verification coverage as prescribed by the QA manual. 35

f t (ii) The LKCEI internal auditing activity for Braidwood,

                 - beginning with audit report I-001, was reviewed by the

( inspector. (1) The 1982 audit activity and results are tabulated as follows: Number Date of Report Coveraae Results Remarks I-001 7-12-82 Storage, I finding Issue & Control of Welding Material I-002 7-12-82 Housekeep- 2 findings ing & Pro- I concern tection of Safety-Related Class IE Cable - I-003 7-15-82 Control of Measuring & Testing Equipment & Calibration of Torque Wrenches I-004 10-14-82 Cable In ' 3 findings stallation

                                                                               & Inspection I-005           7-22-82                                    Safety related cable pen in-stallation &

inspection procedures I-006 7-12-82 Nonconform- 2 findings ing Items 2 concerns I-007 8-6-82 Inspection

   ,                                                                          of Class 1E safety-related conduit install-ations I-008          8-25-82                                      Design Con- I concern trol
                                                                                                          ~.

I-009 9-1-82 Corrective 2 findings Action 2 concerns 36

Number Date of Report Coverate Results Remarks I I-010 8-30-82 Welding inspection I-011 9-10-82 Receiving, 2 findings storage, handling I-012 9-17-82 Installa- 2 findings tion of Class 1E equipment I-013 10-22-82 Electrical 1 finding termination installation inspection I-014 11-29-82 QA Manual 2 concerns Dist. & Control 1-015 Revision LKC to schedule work requests for 1983 of safety re-lated equip-ment I-016 10-22-82 Stop Work I-017 10-22-82 Electrict1 I finding penetrations installation, te rminati ons and maint ena. ice I-018 11-3-82 , Welding pr o- 6 findings cedure ic-structural attachments

                                                                                                       & weld inspection I-019         11-9-82                                                              Concrete                                                       1 finding expansion anchor installation Inspection of safety-related CEA installations B

e 37

I Number Date of Report Coverate Results Remarks

i. .

I-020 11-9-82 Powder actuated fastener install-ations & inspections i of actuated fastener in-sta11ations I-021 12-6-82 Safety related cable pan in-stallation &

                       ,                                                                                                 inspection I-022                     To Be Scheduled in 1983 1-023                     12-2-82                                    Housekeeping receipt inspec-tion & storage I-024                     12-3-82                                    Pointing release notice I-025                                                                 Qualification,                                       Not

' calibration, per training of QC formed personnel & in 1982

QC records These audits varied in duration from one day audits to one that extended over a period from September 24, 1982, to October 21, 1992 (I-013). Report findings were deter-mined to be corrected and closed in a reasonable time.

The worse case was report I-018, " Welding Procedures for Structural Attachments, and Weld Inspection". It con-tained six findings and two concerns requiring five months to close. The audit was done on November 3, 1982, with the concerns being closed out on April 4, 1983. (2) The 1983 auditing activity began on January 2-6, 1983, with report number I-027. The audit activity and results,

for the year 1983, are tabulated below.

Report No. Dates Coverase Results Remarks I-025 -- Qualification Report not

                                                                                                                   & Classification                                                            in file.

i 1-026 1/5-7/83 Control of I finding

 '                                                                                                                  Special Proc-esses t

38

     . , - , - - _ , -     ,. _ . . - . . -%,.p._em,.w.       ._,w.7.m_,..,.w.. . . . . _ , , , _ _ , , , ,                , _ , . , _ . _ , _ , . _ , , - , _         . . - , . . , . , . , , . , . - . , . , _  - , , -

Report No. Dates Coverase Results Remarks I ~ I-027 1/2-6/83 DC Storage 3 findings Batteries & Racks I-028 1/5-7/83 SMAW Welding no findings of Stainless Steel & Inspec-tion I-029 1/25-28/83 Stud Welding 3 findings

                                                                                       & Inspection I-030 1/19 thru Installation 2 findings 2/8/83             of Class 1E Embedded

, Electrical Items

                                                                                       & Inspection I-031        1/21/83             Inspection of                  Report Notes MIG Welding of                  no aluminum Aluminum                        welding having been performed.

I-032 -- Drawings,& Specs. Report not in Document Control file. Inspection Proce-dure I-033 -- Heat tracing Rescheduled, system Installa- no procedure tion & Inspection I-034 -- --------- Voided, to be scheduled 1ater (iii) The approved, issued audit schedule for the year 1983 provided for audits to be performed as follows: (1) four audits for January, (2) three audits for February, (3) three audits for March, (4) two audits for April, (5) two for May, and (6) three audits for June. Of the seventeen audits scheduled to be performed duricg January through June of 1983, only five could be determined to have been completed with all five audits having been performed in January of 1983, and with no further auditing activity performed. The auditing activity performed by LKCEI failed to conform with the requirements established by the QA Program for a comprehensive system of planned and periodic audits. This is an example of a violation of 10 CFR Part 50, Appendix B, Criterion XVIII (456/83-09-08(B-), 457/83-09-08(B)). O 39

       - - , - -   - - - - _ . . - - _ - -                                 __ .- - _ - _ - - _ _ - -    . _ _ -  .- -         - _ _ _ _ _ _ = _ _ _ _ _ - -

c. Document Control \

1 ! The LKC document control activities were reviewed by the inspector. I The QA Program Procedure 4.2.1 was being implemented with the trans-mittal form 4.2.1 utilized as provided for the control of issuance of new revisions disposal of obsolete to documents documents. and for the control of return and It was noted that the applicable ECNs and FCRs were listed on the new revision drawings when issued. A document master card was maintained for each drawing issued and was maintained in current revision status (including ECNs and FCRs). i A survey was conducted of several document stations located through-out the plant construction area with the following results: (i) Main Station: Auxiliary Building elevation 451 adjacent to the control room areas. Review of drawings and discussions with personnel working out of that station established that wiring diagrams of the control room wiring terminations drawings, both the current revision and all old voided revisions were maintained and marked appropriately. The inspector was informed that the as-built condition of termina-tions were marked on the prints, therefore, old drawings need be maintained to provide a complete as-built history. In addition obsolete drawings (voided drawings) were stamped as such and were maintained separately in temporary file cartons. The system appeared to be functioning adequately with sample drawings of the current revisions found to be the latest issued revision (Drawings 20E-1-3785 Rev. X, 4491D Rev. X, 4631C Rev. F). (ii) Station 5: Located in a lower level of Unit 2 containment; however, it was reportedly being used by electricians performics work in Unit I containment. ' The inspector, during a review of the racks of drawings located in the station, selepted sample drawing numbers at random to be checked for status. The results are as follows: Drawing 3513, Rev. AF 6-22-83, Current Drawing 3515, Rev. N 9-17-82, Current Revision is S Additionally, Station 5 notebooks (maintained for copies of the current FCRs and ECNs) failed to include numerous of the listed current FCRs and ECNs for the above listed drawings. In discusrions with the document control personnel, it was learned that the document center records for Station 5 showed that Revision N of drawing had not been returned. In addition, a general meno dated April 9, 1983, was provided, regarding 1 missing (unreturned) voided prints, now considered to be lost or missing. Four revisions old drawings remain availa,ble for construction activity in the stick file of Station 5 without any marking as to void status is contrary to the document control procedure.

 ,                                                                                                                  40
       ,-,...-,...-r...._,.r,              ,._-,--,.m.       ._,__...--..._e.,.,.y....-,,-.w,.-._-_r...,_,,_-                                        --.,,,.-c-----,..,.-,c-_-..,.c.. - - - -

Prior to the completion of the inspection, the inspector was informed by the LNC Project Engineer that a complete audit of Station 5 had been performed. Sixteen additional voided drawings were identified in the current stick files out of a total of $28 drawings located at the station (15 safety related drawings). The inspector was further informed that corrective action was being taken to assure that all 44 !. stations are. maintained in a current status. This item is an example of a violation of 10 CFR 50, Appendix B, Criterion V and the L. K. Comstock QA Manual, Section 4.2 for failing to assure that only approved current 9 revision documents were available for use at the location where the activity is performed (456/83-09-02(E); 457/83-09-02(E)).

d. Nonconformance Control The LKCEI nonconformance control activities were reviewed by the 1 inspector. The QA Program Manual Procedure 4.11.1, 4.11.2, and j 4.11.3 provide the procedural instructions for this program control. The control provided in two strata: 4.11.1 covered noncon-formance reports (NCRs) control of material so designated, while 4.11.2 covered inspection correction reports (ICRs) for those in-process items where further work or processing was needed to complete the hardware in an acceptable condition to established design requirements. The results of the review follows.

j (i) Nonconformance' Reports (NCR) 4 NCRs were prepared by the QC Inspection department and were signed by the QC Manager. A log being maintained for all issued NCRs by number and by hold tag numbers. A review of the los established that the first nonconformance report, NCR#1, was issued by the predecessor electrical con-tractor (E. C. Ernst) on October 21, 1976. NCR#47 of that era remained open regarding " Lack of documentation for concrete

expansion anchors." The latest dispostion for the open NCR was provided by Ceco on November 18, 1982.

i Current era activities and status included: (1) three old (1981) NCRs showing that CECO has issued NCRs regarding this problem, (2) 36 NCRs that are more than one year old with 13 not yet dispositioned by CECO, and (3) of the more recent i open items, a majority appeared to be awaiting Ceco disposi-tions. .

;                                                                         NCR hold tag control appeared to have been a problem in the past with most of the tags being issued and being used on
;                                                                         nonconforming equipment having not been returned when the NCRs were closed. Currently the problem of unreturned tags has been improved, however, in discussions with the Assistant QC Manager, O

41 4 s

  -r,.w--   ,,, , -     w,------,      ,e.-.,   ,- . , _ . , , - , . . , , _ , ,            .,,,,,-n,,,------..---.n.-,--
                                                                                                                                    .w,--,_   ,,,,---m,sy-         -p-- -w--- w.---,,,--,-e.-   s-. -,- - - -

it was learned that an improved (more durable) type tag was

                    - being considered along with a change in the procedure to further improve this control.

(ii) Inspection Correction Report (ICR) Control 4 ICRs (Form 30) were used to control those less than complete deficiencies that could be brought to design conformance. QC Inspection also maictained a status log of these items. The results of a review of the log revealed: (1) two 2-year old ICRs, 784 and 920, cover hangers within Unit 1 containment, loop 4, that have rejectable welding and both have been reissued at least twice, in 1982 and 1983, and appear to be items that should have been converted to NCRs; (2) ICR #1287 was an old item related to electrical cable pan fill which remained open and was carried in the log with a note that it cannot be closed (this is a concern discussed later in this paragraph);

and (3) 50 items were in excess of 1 year old.

The inspector expressed concern regarding the practice of using ICRs to report electrical separation deficiencies. The inspector was informed by licensee personnel that this concern had been identified at Byron Station and that it had been dis-cussed with Region III personnel. It now was an agreed prac-tice, to be reviewed further in the future, that the ICR system was to be used to identify each and every electrical cable problem such as separation of cable in air and in cabinets, metal to metal separation, cable tray fill, minimum bend radius of cables, and pull tension concerns. The designer, Sargent & Lundy (S&L) had reserved the right to review and evaluate each and every instance of apparent violation and to make a separate determination in each case as to its accepta-bility on a violation to be reworked. The inspector indicated that the previous agreement should stand and that the results should be equally applicable to Braidwood.

e. Equipment Installation Control

, The inspector conducted a review of electrical equipment installation to determine the adequacy of adherence to drawings during installa-i tion and control of problems during installation. 4 Unit 2 control room main control panels numbered 2PM05J and 2PM06J were selected for review. The inspector was accompanied by: (1) the Area Manager, (2) an engineer, (3) the responsible foreman, and (4) the QC Inspector involved. The inspector reviewed the following documents relative to the installation: Drawing 0-3372, B, Rev. L Electrical Installation of Equipment Main Control Room Drawing 0-3391, X, Rev. H Electrical Installation Section and Details 42

Drawing 0-3391C, Rev. AB, Electrical Installation of Equipment Manufa.cturing Details Sheet 1 Drawing 0-3391 AC, Rev. A Electrical Installation of Equipment Miscellaceous Mounting and Shim Plate Details The inspector determined by direct measurements that the equipment was placed on location as-dimensioned on the drawings. It was also determined that the interface fit between the equipment mounting base plate and the floor embeds had considerable attachment welding problems. The LKC Engineer had performed an engineering evaluation and prepared a set of 18 FCRs that depicted an engineered resolution of each of the installation problems for all the equipment on

drawing 0-3372-B (including panels 2PM05J and 2PM06J). The QC inspector had prepared an NCR-677 related to the two panels under consideration, identifying attachment welds staggering problems and dimensional problems and had attached three of the FCRs (6288, 6291, and 6292) prepared by the engineer to resolve the problem.

Although the NCR was still open, most of the repair welding work was done according to the new drawing 0-3391 AC which was issued to incorporate all of the FCRs previously mentioned. The contractor had not completed its final acceptance inspections of the equipment installation, however, the inspector believed that the activities have been conducted in a controlled acceptable manner.

4. Licensee Auditing of the Electrical Contractor The inspector reviewed the Ceco QAM procedures QR-18 and QP-18-1 and conducted a review of the licensee auditing activity of the electrical contractor. The review covered one General Office (GO) audit performed September 13-21, 1982, and four on-site scheduled audits as follows:

         - QA-20-82-53 September 29, 1982
         - QA-20-83-06 Februa ry 9-16, 1983
         - QA-20-83-09 Februa ry 25, 1983
         - QA-20-83-20 April 18-21, 1983 Only one of the above five audits contained no findings. The inspector also reviewed a May 16, 1983 (BRD #8715) letter covering Ceco immediate concerns. In addition, the onsite unscheduled auditing and surveillance activity was selectively reviewed as follows:
         - Audits No. 82-37 No. 82-43    -

No. 83-06

         - Surveillances No. 2727 February 8,1983. Storage of Cable No. 2794 March 24, 1983, Conduit Installation No. 2887, May 25, 1983, Storage and Protection of Diesel Generator      --

No. 2920, June 12, 1983, Storage of Cable on Reels O 43

It was noted that on an average, approximately 6 surveillances were being performed per month in addition to the scheduled and unscheduled audits. Emphasis appeared to be and needed to be on the storage and protection of installed equipment. More emphasis also needed to be placed on this subject by the station personnel. The inspector concluded that good emphasis was being placed on installed equipment by the auditors, and that the QA activity had been effective in gaining contractor control improvement. No items of noncompliance or deviations were identified. O e O 44

I SECTION III - HVAC ( . DETAILS

1. Persons Contacted Commonwealth Edison Company (CECO)

M. J. Wallace, Project Manager D. Cosaro, Construction Superintendent W. Shewski, Manager of Quality Assurance (Corporate) T. Sommerfield, QA Superintendent G. Groth, Lead Mechanical Engineer D. Brown, QA Supervisor L. Tapella, Project Coordinator J. Hawkinson, Construction HVAC Engineer S. Reece, QA Engineer J. Walters, QA Engineer. C. Hayes, QA Welding Engineer Pittsburah Testing Laboratory (PTL) A. Fraizer, NDE Supervisor F. Forrest, Project Manager Pullman Construction Industries, Inc. M. Jarigese, QA Manager (Corporate) D. Grant, QA Manager (Site) R. Waterfield, QA Supervisor (Site) D. Lawler, Project Manager R. Ewald, Engineering Supervisor

2. Documents Reviewed

a. Commonwealth Edison Company Quality Assurance Manual, Revision 77.

b. Pullman Construction Industries, Inc., Quality Assurance Manual, Revision 1.

c. Sargent and Lundy Specification F/L-2782, HVAC Work, Amendment 7.

d. Pullman Construction Industries, Inc., Procedures:

(i) B2.1.F, QA/QC Qualifications, Revision 1 (ii) B3.1.F, Design Control, Revision 3 (iii) B5.1.F HVAC Repair / Adjustment, Revision 2 s W 45

(iv) B6.1.F, Document Control, Revision 1

  !             (v} 88.1.F. Iedentification and Control of Parts and Components, Revision 0 (vi) B9.1.F. Welder Qualification, Revision 2 (vii) B9.2.F. Control of Welding Filler Metal, Revision 0 (viii) B9.3.F Expansion Anchor Installation, Revision 7 (ix) 89.4.F, Inst 11ation Procedure, Revision 2 (x)    B.10.1.F. Field Receiving Inspections, Revision 2 (xi) B.10.2.F, Visual Weld Inspection, Revision 1 (xii) B.10.3.F      Installation Inspection, Revision 3 (xiii) B10.4.F, Final Inspection, Revision 1 (xiv) B12.1.F, Equipment Calibration / Verification, Revision 3 (rv) B13.1.F, Stor. age and Handling, Revision 0 (xvi) B16.1.F. Non-Conformance/ Corrective Action, Revision 1 (xvii) B17.1.F, Q. A. Records, Revision 0 (xviii) FWP-300, Gas Metal Arc Welding, Revision 8 (xix) FWP-300B, Gas Metal Arc Welding, Revision 2 (xx) FWP-301, Shielded Metal Arc Welding, Revision 5 (xxi) FWO-301C, Shielded Metal Arc Welding of Galvanized Steel to Galvanziaed~ Steel or Carbon Steel, Revision 4 (xxii) FWP-304, Gas Metal Arc Welding of Stainless Steel, Revision 4 l        (xxiii) FWP-403A, Shielded Metal Arc of Stainless Steel, Revision 4 l

(xxiv) FWP-304B, Semi-automatic and Machine Gas Metal Arc Welding, Revision 1 (xxv) WP-305A, Gas Shielded Flux-cored Arc Welding, Revision 1 (xxvi) FWP-306, Carbon Arc Brazing, Revision 8 [ 46 l

3. Qualification and Training Welders were given general training in welding and brazing procedures.

The inspector reviewed one of the nine procedures for the following attributes:

a. material specification

b. welding process

c. position

d. filler metal classification

e. single or multiple pass

f. welding current 3 polarity

h. welding progression

1. preheat and interpass

j. electrode size

k. amperage

1. voltage

m. type of joint detail The following welders' qualification records were reviewed and found to be in compliance with AWS DI.1-1977, Section 5, Tables 5.23 and 5.26.1:

Welder I. D. # 39 44 50 66 36 The Pullman welders were qualified for one or more processes including Shielded Metal Arc Welding, Gas Metal Arc Welding, Flux-Cored Arc Welding, and Carbon Are Brazing. Nine welding and brazing procedures had been qualified for the Braidwood Site, subdivided into over seventy procedure specification sheets. Quality control personnel were trained and certified in accordance with approved procedures and Regulatory Guide 1.58, Revision 1. Documented records included training in applicable codes and standards, on-the-job ' training, examinations including mock inspections, and eye tests. Certification was divided into disciplines such as mechanical inspection, material control inspection, and documents. No items of noncompliance or deviations were identified. 1

4. Desian Control The design change HVAC Program was reviewed to ascertain that the licensee has established and is implementing a program in accordance with_ regulatory requirements and the CECO Quality Assurance Manual. The review of documents included a verification of the following activities:

47

t

a. Procedure to control design requests have been established,

b. Procedures and responsibilities for design control have been established.

c. Responsibilities and controls to assure that design changes will be incorporated into drawings have been established.

d. Channels of communications between design organizations and responsi-ole individuals have been established.

e. Controls requiring that implementation of approved design changes be in accordance with approved procedures have been established.

f. The following Field Change Requests and Engineering Change Notices were reviewed and found to be processed and dispositioned in accordance with proper design control criteria:

(i) FCE #L10649 (viii) ECN #4315 (ii) FCR #L10135 (ix) ECN #4259 (iii) FCR #L-9861 (x) ECN #4619 (iv) FCR #L-9717 (xi) FCR #L-10575 (v) FCR #L-9687 (xii) FCR #L-10115 (vi) FCR #L-9752 (xiii) FCR #L-10563 (vii) FCE #L-9724 (xiv) FCR #L-10134 (xv) FCR #L-10159 No items of noncompliance or deviations were identified.

5. Drawing Control Drawings were reviewed for current revisions, distribution lists, and responsibilities assigned for implementation. Drawings, both in the field and in the office were checked, includsag posting Field Change Requests, as detailed below:

Office Drawings Field Drawings M-1314-8 M-1277-1 M-1267-9 M-1283-2 M-1274-2 M-1283-1 M-1274-1 M-1281-3 M-1273-4 M-1274-2 M-1275-1 M-1270-1 M-1276-1 M-1326-6 M-1311-10 M-1326-5 M-1312-1 M-1326-3 M-1311-11 M-1326-2 M-1283-2 M-1326-1 M-1322-1 M-1313-3 M-1313-2 .- M-1319-2 48

t Field Drawinas M-1314-4 M-1323-1 M-1323-6 M-1323-7 M-1314-3 H-1314-8 M-1323-1 M-1314-3 A control system had been established for issuing and returning drawings. No items of noncompliance or deviations were identified.

6. Material Inspection The welding issue station was inspected and the E7018 and stainless steel welding rod was found to be stored in the ovens within acceptable temperature parameters. The issue station was only open at designated times of the day and only the E7018, E308, and E309 rod was issued by means of a requisition system. The E7018, E308, and E309 requisition log indicated the welder to whom the rod was issued to, the amount issued, and the amount returned, but not where the rod was to be used. With the issue station open on a limited basis, a strain is placed on planning, taking into consideration the amount of filler metal required and the assignment of joints requiring the same filler metal type. Without a requisition system, for other than E7018, E308, and E309 rod controls for quantity issued is absent for filler metal such as carboc wire, stainless wire, and E6013. Since quality control does not inspect filler metal type during the welding process, nor are welding procedures which specify type of filler metal documented prior to welding for each HVAC installa-tion, weld material control at issue and lack of the traceability to the item takes on added significance (reference Paragraph 7).

The following welding material certifications were reviewed and found to be in compliance with AWS DI.1:

                  .035 wire - ER705-2, Heat No. 27403
               - 1/8" - E309-16, Heat No. X37712
               - 3/32" - E7018, Heat No. 41170411
               - 3/32" - E7018, Heat No. 431P2321 Receipt inspection reports were reviewed for the following material types:

Report No. Material Type 202 Duct, plate, nuts, bolts, angle 203 Auxiliary steel, screens, seal angles 210 E7018 weld rod ,_ 214 Auxiliary steel, angle 49

i , 270 E71T wire, flex connections, tube steel 298 - Plate 297 Angle, plate, tube Attributes including identification, cleanness, coating, dimensions, workmanship, damage, and documentation were checked. The inspector randomly selected two ducts, attached stiffeners, and one hanger in the control room vent system and found the material and the certifications in accordance with the design requirements including yield stress. No items of noncompliance or deviations were identified. 7'

          .          Installation The installation program was reviewed to ascertain that the licensee has established and is implementing a program in accordance with 10 CFR 50, Appendix B, and AWS D1.1 1977. The inspector determined that the HVAC QA Program did not have adequate policies, procedures, or instructions for controlling fit-up and welding during the installation of HVAC components.

Quality control personnel were required to examine the final weld for compliance to AWS DI.1 1977, but the only mandatory in-process verification required by Pullman Procedure B10.2.F, " Visual Weld Inspection", involved checking amperage, voltage, interpass temperature, travel speed, and preheat temperature for compliance with the welding procedure specification sheets. This was being done on three welds per week, the minimum required by Procedure BIO.2.F. Fit-up was required to be checked after welding was completed per B10.2.F. No requirement existed in the QA Program for the welding procedure to be specified for each specific HVAC installation before welding commenced. The HVAC QA program was deficient in the following areas: Instructions were not adequate in that welding procedures to be used for each specific HVAC installation were not stipulated on drawings, travelers, or predetermined by any documentation form. The selection of welding procedures had been performed by the craftsmen. The weld procedure selected was not documented and there were nine welding procedures divided into over seventy detail sheets. The craftsmen were required to select the welding procedure detail sheet. Additionally, during the installation process quality control did not verify welding position or polarity for electrode classification, nor verify that acceptable welding procedures were employed for each HVAC installation or inspect on a fre-quency adequate to assure by an acceptable confidence level that the welders were complying with the welding procedure essential variables. This is an example of a violation of 10 CFR 50, Appendix B, Criteria II and IX (456/83-09-10(A); 457/83-09-10(A)). Quality control did not inspect HVAC components for fit-up prior to welding on components. Fit-up tolerances cannot be determined after welding cer-tain components, such as all-around fillet welds and full penetration welds. Furthermore, documented instructions to the quality control inspectors of 50

e fillet weld gaps after welding was inadequate as the NVAC contractor procedure " Visual Weld Inspection Procedure", B10.2.F, stated that a 3/16" gap was acceptable, while AWS D1.1-1977, Section 3.3, states that a 3/16" gap is allowed only if the leg of the fillet weld is increased by the amount of the separation or the contractor demonstrates that the required effective throat has been obtained. This is an example of a violation of 10 CFR 50, Appendix B, Criteria II and IX (456/83-09-10(B); 457/83-09-10(B)). Quality Control was not required to examine the base metal prior to welding to assure that surfaces and edges were free of discontinuities. This is an example of a violation of 10 CFR 50, Appendix B, Criteria II and IX (456/83-09-10(C); 457/83-09-10(C)). Records were inadequate for the following quality activities as a result of a lack of controls and inspections: (i) Welding procedures employed during the installation process were not specified and after October 1982 there was no documented evidence available of the welding procedures used for each HVAC component installation. Prior to October 1982 quality control listed the welding procedure used on the final weld inspection form presumed to be used after examining the completed weld. The Pullman Quality Assurance Site Supervisor stated that by examining the final weld, in most cases, the welding procedure that was used could be determined. Of course, if the weld was ground down, determination would become increasingly difficult. In addition, examination of the final weld did not provide assurance that the welding procedure essential variables were complied with during the in process welding. (ii) Fit-up inspection for full penetration welds, all around fillet welds, and other welds inaccessible for fit-up inspection after welding. (iii) Btse metal surfaces and edges prior to welding. (iv) Welders that performed the welding on the joints identified in Pullman Nonconformance Report #BR-08, dated 6/15/81. (v) Welding position and polarity. Failure to implement an adequate quality assurance program with regard te installation activities of HVAC components in accordance with CECO QA Program, Topical Report CE-1-A Section 2, Sargent and Lundy HVAC Specification F/L-2782, and AWS DI.1-1977 as evidenced by the above identified deficiencies is in violation of 10 CFR 50, Appendix B, Criteria II and IX. After the inspector identified these deficiencies, a stop work order was issued for all safety-related NVAC welding on August 3, 1983, by Pullman Construction Industries, Inc. O 51

e The inspector verified that the three weekly in-process surveillances of amperage, voltage, interpass temperature, travel speed, and pre-heat temperature were being done. Record reviews included surveillances on the following days: 3/11/83, 3/18/83, 4/28/83, and S/5/83. Prior to November 30, 1982, the surveillances were less than three per week, only required by procedure to be done on a random basis. Final quality control weld inspection reports were reviewed as follows and found to be in compliance with Pullman Procedure B10.2.F. Piece Number Date Drawing Drawing Title S-3981 Hanger 8/2/83 M-1326-6 Auxiliary Bldg. Control Room Vent Duet Patch 7/29/83 M-1281-1 Diesel Generator Vent

          #2133c                                               Floor Plan Duct Patch             7/29/83        M-1281-1      Diesel Generator Vent
          #2133a                                              Floor Plan Duct Patch             7/29/83        M-1281-1     Diesel Generator Vent
          #2131c                                              Floor Plan Duct #2582 to          3/1/83         M-1314-1     Auxiliary Building Vent Stiffener S-1339, Hanger

8/1/83 M-1281-3 Diesel Generator Vent Floor Plan AS-1189, Aux- 7/14/83 M-1281-3 Diesel Generator Vent iliary Steel Floor Plan Duct #2664 to 3/1/83 M-1314-3 Auxiliary Building Vent Stiffener Floor Plan Duet #3155 10/27/82 M-1314-4 Auxiliary Building Vent Floor Plan l Duct #470 10/9/82 M-1309-3 Auxiliary Building Vent l Partial Floor Plan l

l Duet to Hanger 10/1/82 M-1274-2 Containment Purge Vent Rings #3511A, System 3512A , Ceiling Panels 9/21/82 M-1317-1 Auxiliary Building Equipment i Room Hanger #1425 & 9/18/82 M-1314-4 Auxiliary Building Vent Hanger # 1424 Floor Plan e 52

HIPA Filter 8/30/82 M-1317-1 Auxiliary Building Equipment Frame. Room Attachments for 10/6/82 M-1317-2 Auxiliary Building Equipment Charcoal Canister M-1317-1 Room Duct #2582 to 3/1/83 M-1314-10 Auxiliary Building Vent Stiffeners Final quality control Type A installation reports were reviewed as follows and found to be in compliance with Pullman Procedure B10.3.F. Installation Inspection: Piece No. Date Drawing Drawing Title S-3220-Hanger 7/30/83 M-1326-4 Auxiliary Building Control Room Vent Duet #2174 8/1/83 M-1281-1 Diesel Generator Room Vent Floor Plan Auxiliary Steel 8/1/83 M-1281-3 Diesel Generator Room AS-1189 Vent Floor Plan Duct Patch 7/29/83 M-1281-1 Diesel Generator Room

                     #2133A                                        Vent Floor Plan Safety-related control room HVAC ducts #4927 and'#4928 were examined. The companion angle flanged joints were installed in accordance with Sargent and Lundy Specification F/L-2782, with regard to 1" stitch-welds being on 9-inch centers and flanges bolted together on not less than 6-inch centers.

On August 4, 1983, a region-based inspector reviewed the physical condi-tion of the hanger and stiffener welds, the angle frame to duct brazing, and the appropriate welding procedures. An inspection of hanger,

 ,          stiffener, and brazing welds was performed in the upper cable spreading rooms of Units 1 & 2 and the HEPA filters of Unit #2. In addition, the inspector witnessed a qualification and break test (preliminary) for a prequalified procedure covering square butt, full penetration weiding of sheet to sheet to AWS Code D1.3-1977. Approximately six (6) hangers on each of three (3) duct runs plus four (4) sections of duet per run were inspected. This represented an approximate total of 450 welds inspected.

These included arris that had not been inspected as yet; areas that had been inspected but not yet repaired, reworked, and areas which had been accepted and had final visual inspection by Pittsburgh Testing Labora-

           -tories. Of the in-process inspected welds, Pullman QC had identified twelve (12) that had rejectable defects. The region based inspector identified approximately twelve (12) of the same type defects in the in process, uninspected welds. These additional defects were located on welds which were within the planned inspection program and would likely be identified during the inspection of these welds by Pullman.

l 53 {

o During the examination of the accepted welds, the following four condi-i tions were identified which the inspector indicated warranted further investigation and/or evaluation by the licensee. Hanger No. 2219 (S ergent and Lundy No. S-3881, Drawing No. M-1323, Sheet 10) - North Leg, East side, had possible lack of fusion at end , of weld. Hanger No. 2221 (Sargent and Lundy No. S-3883, Drawing No. M-1323, Sheet 10) Southwest corner, had possible slag inclusion. Duct to flange connection Pc No. 9 (Sheet 4033) - east side of duct. Outside corner weld at top of duct - crater and possible surface crack in weldment. These three conditions were in duct run in Unit 2 at El. 469'0, approximate Col. L-25. Upper cable spreading room, El. 463'5", Col. L. 23 (approx.) Actuator motor hanger bracket, east side of duct between HEPA filters and main supply duct possible crater in corner. This item had been modified from the standard mounting bracket and an FCR had been written. The licensee was pursuing these items as a result of the inspection findings. These matters are considered an unresolved item and will be reviewed during a future inspection (456/83-09-11.; 457/83-09-11).

8. Nonconformance/ Corrective Action l

The HVAC contractor divided deficiencies, deviations or defects into Nonconformances and Correction Notices. Correction Notices were written instead of acnconformances, if a nonconforming item could be made con-forming by approved procedures or other corrective means. l Forty-two Nonconformances had been written since hpril 18, 1978, while through August 4, 1978, 2513 Correction Notices had been written by Pullman for deficiencies and d'viations, e but their QA program did not require that Correction Notices be analyzed for significance. These Correction Notices identified approximately 6,000 welding deficiencies and deviations, including incomplete fusion, craters, cracks, insufficient throat, weld length, undercut, undersize and weld placement. These deficiencies in the welds were identified by the HVAC contractor's quality control personnel and either had been repaired or were in-process of being repaired. Pullman Construction Industries, Inc., had not established a corrective action program to assure conditions adverse to quality such as deficiencies and deviation were identified for significance and subse-quently that the cause of the significant condition was determined and corrective action taken to preclude repetition with regard to the root l causes of the 2513 Correction Notices. In November 1982 Ceco performed l a 100% inspection of safety-related installed components, including all I r 54

o e a components installed prior to November 1982, as a sample program was all

  ;               that was. originally required. The reinspection effort included approxi-mately 1,950 items and as a result of numerous deficiencies, Pullman Construction Industries, Inc., issued a Stop Work Order on June 28, 1983, for all new work, except for the diesel oil storage rooms and diesel J

generator rooms, in an effort to correct past work. Despite the numerous deficiencies identified, the licensee failed to institute quality controls prior to commencement of welding. The NRC expressed a concern to the licensee that a contribeting factor to the welding deficiencies may be attributable to the failure to specify the welding procedure that the craftsmen were to use, stipulating such factors as current and travel speed. The following five Nonconformances were reviewed for corrective action: NCR D Date BR-11 8/24/81 BR-40 4/25/83 BR-28 7/3/82 BR-08 6/15/81 BR-07 3/3/81 Corrective actior.s on all except BR-08, dated June 15, 1981, were satisfactory. This nonconformance concerned fifty-five welds for which the welder was unknown. The program, approved by the licensee, required quality control to verify the welder stamp numbers affixed near the completed weld against the welder qualification listing. The program did not require performing in-process inspections on a frequency to , assure that a qualified welder was, in fact, 4 being employed for the specific welding joint for which he was pre quali-a fied. The welders had failed to stamp their identification numbers adjacent to the fifty-five welds identified and this condition resulted in indeterminate welder qualifications associated with the fifty-five welds. The corrective action accepted by Commonwealth Edison QA was to examine the welds visually and, if acceptable, approve the weld. The AWS DI.1 Code requires that visual examination is the basis for acceptance only if a qualified welder performed the welding. A visual surface examination of a weld, based on the fact that an unqualified weld 6r may have performed the welding, does not provide assurance of weld acceptability. Therefore, corrective action was inadequate. The failure to establish a corrective action program for the 2513 deficiencies and take adequate corrective action for nonconformance report BR-08 is in noncompliance with 10 CFR 50, Appendix B, Criterion XVI (456/83-09-07(B); 457/83-09-07(B)). i 55

E o

9. Audits .

a. Contractor Audits The NVAC contractor's year y audit program, as established by its QA manual, for 1982 was not completed until April 4, 1983. This deficiency was identified and documented by Commonwealth Edison Quality Assurance. The audits, which are to cover all aspects of the Quality Assurance Program as stated in 10 CFR 50, Appendix B, Criterion XVIII, were conducted in three days by one lead auditor.

The audits dated April 4, 1983, and April 28-29, 1982, were limited in scope and failed to cover the following implementing procedures: B3.1.F, Design Control B5.1.F. HVAC Repair Adjustment B9.3.F, Expansion Anchor Installation B9.4.F Installation Procedure B10.2.F, Visual Weld Inspection This is an exampie of a violation of 10 CFR 50, Appendix B, Criterion XVIII (456/83-09-08(C); 457/83-09-08(C)).

b. Licensee Audits The following Commonwealth Edison audits of the HVAC contractor were reviewed:

Audit No. Areas Reviewed 83-31 Qualification Q.C., Weld Material Control, Welder Qualifications, Installation, Inspection Status, and Design Change 82-06 The NRC inspectors' review was limited to Material Traceability and Component Identifica-tion. 83-12 Design Document Control, Procurement Control, Storage and Handling, Housekeeping, Q. C. Inspections, Calibration Control, Equipment Installation, Inspector Qualifications, Nonconforming Items, Auditing 82-56 Timeliness of Inspections I l 82-51 Material Traceability, Drawing Control, [ Component Documentation, Fabrication

I e 56 I

o e e The audits met the requirement of 10 CFR 50, Appendix B, Criterion XVIII, which states, "A comprehensive system of planned i and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program"; however, as described in Paragraph 7 the Quality Assurance Program did not meet the require-ments of 10 CFR 50, Appendix B. It appeared that a technically qualified, experienced auditor would have identified some of the deficiencies listed in Paragraph 7. For example, one of the questions from Audit 82-06 stated, " Verify that Pullman provides for trace-ability of safety related materials?". The answer documented by the auditor stated, " Fab tickets contain heat code (MTR) numbers for material and heat numbers for shop welding material. Onsite welding mate-lal is traced based upon duct installation date. Welding material distribution log has heat numbers of rod issued to welders on a given day. Only one heat of welding material is kept in oven at one time providing heat traceability". This answer failed to address: (1) Welding material other than E7018 E308 and E309 rod which was the only filler metal documented in the distribution log and kept in the ovens. (2) Welding material heat traceability was maintained to the component in the shop but was not being maintained to the component in the field. (3) Assurance that the correct filler metal type was used and traceable to a specific component. (The duct installation date did not provide assurance.) The answer demonstrated that the auditor was not fully knowledgeable in AWS DI.1-1977, Section 6, requirements. The qualification, knowledge level, and certification of auditors is considered an unresolved item and will be reviewed further in a subsequent inspection (456/83-09-05; 457/83-09-05). i l l - I 57 l i

        &       g A tte,                                    UNITED STATES k
                    'ei ,' S NUCLEAR REGUL ATORY COMMISSION REGloN lli

[ r 3-

    'd',

3 4 f 799 ROOSEVELT ROAD GLEN ELLYN, ILLINOl$ 60937 i

                        ' l fJUL 0        27       5   30 Docket No. 50-456 Docket No. 50-457 Commonwealth Edison Company ATTN:      Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Geiltlemen:

This refers to the routine safety inspection conducted by Messrs. L G. McGregor_ a.nd R. D. Schulz of this office on May 1 through June 4, 1984. o.f._actjyltjes at Braidwood Nuclear Power Station,_ U_ nits 1 and 2, authorized by NRC Construction Permits No. CPPR-132 and No. CPPR-133 and to the discussion of our findings with Mr. R. Cosaro at the conclusion of the inspection. The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel. Dying th.is, inspection,_certain n of vo.u_r._a.clivities appeared _toJ1e_in non . compliance with NRC requirements, as specified in the enclosed Appendix. fwritten response is redu~ ired. In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure (s) will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days of the date of this letter. Such application must be consistent with the re-quirements of 2.790(b)(1). If we do not hear from you in this regard within the specified periods noted above, a copy of this letter, the enclosure (s), and your response to this letter will be placed in the Public Document Room. The responses directed by this letter (and the accompanying Notice) are not subject to the clearance procedsres of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511. ATTACHMENT "H"

r,

                                                                        .'O ' 984.,
  . Commonwealth Edison Company             2                 " jut We will gladly. discuss any questions you have concerning this inspection.

Sincerely, R f SL.'sZ M 2Ne k' R. F. Warnick, Chief Projects Branch 1

Enclosures:

1. Appendix, Notice of Violation

2. Inspection Report No. 50-456/84-09(DPRP);

No. 50-457/84-09(DPRP) cc w/encls: D.- L. Farrar, Director of Nuclear-Licensing M.-Wallace, Project Manager D. Shamblin,' Construction Superintendent J. F. Gudac, Station Superintendent

DMB/ Document Control Desk (RIDS)

Resident Inspector, RIII Braidwood Resident Inspector, RIII Byron Phyllis Dunton, Attorney General's Office, Environmental Control Division Jane Whicher, Esq. C-

t Appendix { NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-456 Docket No. 50-457 As a result of the inspection conducted on May 1 through June 4, 1984, and in accordance with the General Policy and Procedures for NRC Enforcement Actions, (10 CFR Part 2, Appendix C), the following violations were identified:

1. 10 CFR 50, Appendix B, Criterion V requires that activities affecting quality shall be" prescribed by documente.1 instructions, procedures, or drawings and shall include appropriate quantitative or qualitative accep-tance criteria for. determining that important activities have been satis-factorily accomplished.

ANSI N45.2.8, 1975, requires in paragraph 2.9, that engineering limita-tions be incorporated into procedures and instructions and shall include physical clearances; and paragraph 2.1 requires that activities shall be planned and documented to be consistent with engineering and design requirements.

             . Contrary to the above, .the architect engineer, Sargent and Lundy, did not f       prescribe clearance criteria for safety related HVAC components or' safety related large bore (>2") piping in relation to other items such'~as equip-ment._ conduit.cabletray.orDioing.andal'so'failedlojrescrib~e~ clear-
                                                                                   ~

ance_ criteria.for. safety.related electrical _ items,_such as cable tray or-conduit,_in r. elation. to all. p.iping, _HVAC. gomponents , .or_e.quipmen.t in documented . instructions, procedu es,, or_..dtawings. __ As a_re.sul t,_ delign control measures for installation and insp_ection activities were not a.dequate in that they..did not address: Hydraulic and thermal considerations that require flexibility and movement of items, including pipe supports, and the affect on items d,ue..tr t_ heir close_ proximity or direct contact with each other,

             .      Stress and compatibility of materials due to metal to metal contact and therefore subsequent item deterioration, degradation, or failure r.e_sult_i_ng_from factors _s_uch as piping thermal expansion,
             .      Accessibili M f items for in-service         inspection, maintenance, and r,epai r ,                             ~~          ~ ' ~ - ~ ' - -
             .      F_unctional reliability of a component or item due to interferences.

[ Appendix 2 Furthermore, clearance installation limitations have not been required to be met by the contractors and therefore physical clearances have not

been planned by craft personnel or documented-in quality control inspec-tion reports to assure the prompt identification of installation condi-tions adverse to quality.

This is a Severity Level IV Violation (Supplement II).

2. 10 CFR 50, Appendix B, Criterion V, requires that activities affecting

              . quality shall be accomplished in accordance with the instructions, procedures, or drawings.

Whip restraint drawing 1WR-RCl-6 Revision A, Field Change Order #5497, Weld Data Sheets FW-12 and FW-14, and F/L-2909 Amendment 6, dated October 12, 1979 - Specification for Pipe Whip Restraints all require ASTM A572 GR.50 material for a l'9"x2'1"x1" whip restraint plate. C_ontrarv to the above. material installed for the l'9"x2'1"x1" whip._ restraint plate. identified on drawina 1WR-RCl-6 Revision _Ax was ASME_ SA-516 GR.60. This is a Severity Level V Violation (Supplement II). Pursuant to the provisions of 10 CFR 2.201, you a e required to submit to this office within thirty days of the date of.this Notice a written statement or explanation in reply, including for each item of noncompliance: (1) cor-rective action taken and the results achieveo; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown. I W %, si.vilH u, Dated R. F. Warnick, Chief Projects Branch 1 L

h U.S. NUCLEAR REGULATORY COMMISSIGN REGION III Report No. 50-456/84-69(DPRP); 50-457/84-09(DPRP) Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 767 , Chicago, Il 60690 Facility Name: Braidwood Nuclear Power Station, Units 1 and 2 Inspection Conducted: May 1 through June 4, 1984 Inspectors: L. G. McGregor R. Schulz Approved By:

                      '.h.D      D*S W. 6rney, Chieg                                 6/.> , /f-f
    .                  Projects Section 1A                               Date Inspection Summary Inspection on May 1 throuoh June 4, 1984 (Report No. 50-456/84'-09(DPRP );

50-457/84-09(DPRP)) Areas-Inspected: Routine, unannounced safety inspection of licensee action on previous inspection findings, work activities observed during plant tours, safety related piping, whip restraints, piping post weld heat treatment, piping material verification program, Field Change Requests, electrical installations, structual steel drawing control, craft training, safety related equipment, and preoperational test performance. The inspection consisted of 292 inspector-hours onsite by two NRC inspectors including 30 inspector-hours onsite during off shifts. Results: Of the twelve areas inspected, no items of noncompliance or deviations were identified in ten areas; one item of noncompliance was identified in each of the remaining areas-(failure to stipulate physical clearance criteria - Paragraph 3; failure to install the correct whip restraint plate paragraph 5.

                                              '?t" r ' "-

DETAILS {

1. Persons Contacted

            - Commonwealth Edison Company (CECO)

M. Wallace, Project Manager R. Cosaro, Construction Superintendent

                 *C. Schroeder, Licensing and Compliance Superintendent
               '*D. L. Shamblin, Construction Superintendent T. Quaka, Quality Control Supervisor L. Tapella, Engineer G. Groth, Lead Mechanical Engineer B. Tanouyi, Engineer S. Hunsader, Quality Assurance Supervisor G. Fitzpatrick, Assistant Manager Quality Assurance Corporate M. Curinka, Engineer
                 *C. J. Tomashek, Startup Superintendent E. R. Wendorf, Project Field Engineering Mechanical Supervisor
                 *S. J. Reutcke, Quality Assurance Engineer J. D. Deress, Engineer C. Mennecke, Engineer
                *K. Steele, Electrical Supervisor
                *E. R. Netzel, Quality Assurance Supervisor

, *R. J. Farr, Project Mechanical Superintendent

                *R. Wrucke, !iramin; Engineer
                *ri. Gorski, Engineer
                *C. D. Gray, Project Structural Supervisor
                *W. D. Bruns, Staff Assistant Phillips Getschow Company (PGCo)

T. G. O'Connor, Site Manager K. J. Hamilton, Consultant J. Carlson, Quality Control Supervisor L. J. Butler, Assistant Quality Control Supervisor M. Galloway, Assistant Project Engineer J. Stewart, Project Engineer S. Hamilton, NDE-Level II R. Hamilton, Welding Supervisor G. K. Newberg Company J. J. Hairston, Quality Assurance Manager R. Voss, Project Engineer L. K. Comstock and Company, Inc. (LKC) I. Dewald, Quality Control Manager R. E. Marino, Quality Assurance Manager Corporate L. G. Seese, Assistant Quality Control Manager Site b' R. M. Saklak, Quality Control Supervisor 2

, Sargent and Lundy (S&L) W. C. Cleff, Project Manager D. A. Gallagher, Field Supervisor T.' B. Thorsell, Project Engineer

         -   S. L. Wahlert, Engineer

Denotes those personnel attending the exit interview.

2. Licensee Action on Previously Identified Items (Closed) Noncompliance (50-456/82-06-068): Potentially nonconforming cable reels. This item of noncompliance ,me, retracted by a Region III letter to the licensee dated May 23, 1983.

3. Plant Tours The inspectors observed work activities in progress, completed work, and plant status during general inspections of the plant. Observation of work included high strength bolting, safety-related pipe welding, anchor bolts, structural welds, and cable trays in the containments and auxiliary building. Particular note was taken of material identification, noncon-forming material identification, housekeeping, and equipment preservation.

Craft personnel were interviewed in the work areas. During the general plant tours the inspectors have noticed numerous items in close contact or direct contact with each other, such as safety-related ( small bore piping in contact with safety-related large bore pipe, safety-related conduit in close proximity to or in contact with safety-related pipe, and safety-related pipe in contact with or in close proximity to safety-related duct work. The NRC construction resident inspector in-vestigated these physical clearance concerns and discovered that physical clearance criteria had not been established by the design engineer, Sargent and Lundy, other than for small bore piping, <2", ASME Section III, Subsection NC and Subsection ND. This physical clearance which was stipulated as 3" in Specification F/L-2739, Piping System Installation, was prescribed for only 2" and under pipe installations, Subsections NC and ND, because this pipe was allowed to be field run, deviating from the design drawings. The design engineer failed to address the fact that numerous electrical items such as conduit or cable trays, large bore piping components, or HVAC components would be installed or revised after the small bore piping installations and also these items required pre-scribed physical clearance criteria due to the placement of the field run small bore pipe. Further investigation revealed that the licensee committed to ANSI N45.2.8, 1975 through Regulatory Guide 1.116 in their Quality Assurance Manual and Topical Report. ANSI N45.2.8 requires, in paragraph 2,9, that engineering limitations be incorporated in procedures and instructions and shall include physical clearances, and paragraph 2.1 requires that activities shall be planned and documented to be consistent with engineering and design requirements. " 3

The NRC inspectors met with Commonwealth Edison and Sargent and Lundy on May 17, 1984, and the licensee was informed of the NRC concerns. On May 30, 1984, the NRC met with Sargent and Lundy and Commonwealth Edison and the licensee was informed that a violation for failure to establish physical clearance acceptance criteria would be issued based on the fact that Sargent and Lundy did not prescribe in documented instructions, procedures, or drawings clearance criteria for safety-related HVAC components or safety-related large bore ( 2") piping in relation to other items such as equipment, conduit, cable tray, or piping nor pre-scribe clearance criteria for safety related electrical items, such as cable tray or conduit, in relation to all piping, HVAC components, or equipment. As a result, design control measures for installation and inspection activities were not a'iequate in that they did not address:

              .      Hydraulic and thermal considerations that require flexibility and movement of items, including pipe supports, and the affect on items due to their close proximity or direct contact with each other,
             .      Stress and compatibility of materials due to metal to metal contact and therefore subsequent item deterioration, degradation, or failure resulting from factors such as piping thermal expansion,
             .      Accessibility of items for in-service inspection, maintenance, and repair, such as interferences preventing the opening of junction boxes,
             .      Functional reliability of a component or item due to interferences, such as obstructing HVAC damper linkage, impeding the manual opera-tion of valves, and blocking HVAC filter access doors.

Furthermore, clearance installation limitations have not been required to be met by the contractors and therefore physical clearances have not been planned by craft personnel or documented in quality control inspec-tion reports to assure the prompt identification of installation condi-tions adverse to quality. Failure to prescribe physical clearance criteria prior to installations is in violation of 10 CFR 50 Appendix B, Criteria V (456/84-09-01; 457/84-09-01). During a tour of the containments the inspector noticed that the bolts

for the steam generator lower lateral, inner frame, support columns had inadequate thread engagement. Further investigation revealed that Nuclear Installation Services Company had written nonconformance reports 3009-96 and 3009-97 identifying these deficiencies for corrective action. The inspector considers this issue controlled and closed.: 4. Safety Related Piping Main Steam piping welds between the inner and outer Unit 1 containment walls at elevation 386' were inspected, as were Feedwater piping welds between the inner and outer Unit 1 containment walls at elevation 390'.

l l 4 l i L- _

4 (- Attributes checked included: quality of the welds, identification of the weld and welder, and identification of the spool piece. Subsequently, documentation was examined for the following welds and associated spool pieces:

          - System            Weld No.       Spools              Size      ASME Class Main Steam       FW-4      MS-18-3/MS-18-4          32.75"         2 Main Steam       FW-5      MS-18-5/ Penetration 86  32.75"         2 Main Steam       FW-3      MS-17-2/MS-17-3          32.75"         2 Main Steam       FW-4      MS-17-3/MS-17-4          32.75"         2 Feedwater        FW-6      FW-15-3/ Penetration 84  16"            2 Feedwater        FW-6      FW-16-3/ Penetration 87  16"            2 Documentation reviewed included verification of material requisitions, welding material test reports, fit-up inspections, root weld inspections, final weld inspections, code data reports, magnetic particle test reports, and radiographic inspection reports.

The inspector discovered that FW-5, repair 2, radiographic inspection report for film view 43-53, stated, " Foreign material inside pipe in area of interest. Does not interfere with interpretation." When foreign material is identified inside of pressure boundary piping it should be documented as to what the cbject or foreign material consists of and then appropriately dispositioned, such as removal of foreign material or accept as is. The inspector requested the licensee to investigate this parti- { cular radiographic inspection report and others that may not have properly documented the nature of foreign material. Pending licensee and further NRC review this issue will remain unresolved (456/84-09-02; 457/84-09-02). No items of noncompliance or deviations were identified.

5. Whip Restraints The inspector examined whip restraints, 1WRMS P7 and 1WRMS P15, in the Unit 1 containment at elevation 395', and noticed that washers had not been installed for the ASTM A490 high strength bolts, as required by 1705, Standard Specification For Erection of Structural Steel. These bolting connections had not been examined and accepted by Phillips, Getschow Co.

However, a review of the Phillips, Getschow quality control inspection program revealed that inspections to determine that washers were installed for high strength bolt connections were not required to be done. The inspector brought this to the attention of the licensee and the licensee responded that all whip restraint high strength bolting connections would be inspected or re-inspected to assure correct washer installation. Pending these inspection efforts, which will determine if any connections had been ' inspected and accepted without washers installed, this issue will remain unresolved (456/84-09-03; 457/84-09-03). In addition, the inspector revieweo Comonwec'th Edison Audit, QA-20-84-508, which identi-fied that Phillips, Getschow whip restraint installation is inadequate in that documentatien of high strength bolt tightening was not required. L 5

( Corrective action to be undertaken includes verification of tightening

     \    for all previously installed connections.        This is an open item (456/84-09-04; 457/84-09-04).

Documentation for safety-related whip restraints IWR-RCl-6 and IMS-P11 was reviewed, including stores requests, material test reports for installed steel, filler metal test reports, welding procedures, and installation inspection reports. The inspector determined that drawing IWR-RCl-6 (Revision A), Field Change Order #5497, data sheets for field weld 12 and field weld 14, and Specification for Pipe Whip Restraints F/L-2909 required ASTM A572 GR.50 plate material. The inspector verified through documentation and by a physical inspection of the reactor coolant whip restraint, IWR-RCl-6, that ASME SA-516 GR.60 material was installed. This is in violation of 10 CFR 50, Appendix B, Criterion V (456/84-09-05; 457/84-09-05). Phillips, Getschow Audit #83-BR22 had identified that material substitutions were made by craft personnel during whip restraint installation without the knowledge of field engineers. The NRC inspector identified that quality control inspectors had not been involved in verifying and documenting acceptable substitute material installations. Pending Phillips, Getschow quality control inspections of all substitute material installed, and documentation of correct or incorrect material installations, this issue will remain unresolved (456/84-09-06; 457/84-09-06).

6. Piping Post Weld Heat Treatment

( The following documents were reviewed:

          .      PGCP-41, Revision 3, Centrol of Preheat and Interpass Temperature and Post Weld Heat Treatment
          .      Welding Procedure Specification 1A-MA-13, Revision 3.

The documents were in accordance with the ASME Boiler and Pressure Vessel Code, Section III and Section IX, 1974. However, the inspector noted that although certified thermocouples and calibrated strip chart recorders were being used during post weld heat treating operations, Procedure PGCP-41 did not require the use of certified thermocouples or calibrated strip chart recorders. The inspector brought this to the attention of the licensee, who immediately revised the procedure to require certified thermocouples and calibrated strip chart recorders. The inspector con-siders this issue closed. Actual heat treat recording charts were reviewed for the following post weld heat treated components:

          .      Feedwater nozzle to Steam Generator 1RC01BD
          .      Feedwater nozzle to Steam Generator IRC01BC
           . Steam Generator Outlet Nozzle 2A, MS-60-1.

6

(

The heat treat charts were in accordance with ASME Boiler and Pressure Vessel Code, Section III, NB-4600, including tables NB-4622, mandatory requirements and exemptions. The inspector's review verified that the post weld heat treatment temperatures and holding times were within allowable limits, as were the maximum heatup and cool-down rates. No items of noncompliance or deviations were identified.

7. Piping Material Verification Program Phillips, Getschow Procedure QCP-B31, Revision 0, Material Verification Program, was reviewed. The purpose of the procedure is to establish a controlled method for verifying the traceability of materials utilized in ASME Section III process piping systems, due to the violation identi-fied in NRC Inspection Report No. #83-09. Overall the procedure appeared adequate, but the following aspects require clarification and/or incor-poration in the procedure:

Documentation and analysis of pipe footage requested versus footage installed and overage reports,

             . Identification, control, and documentation of pipe and fittings with identical heat numbers but subject to different nondestructive examinations due to ASME Section III, Subsection requirements,
            .      Documentation and analysis of hardware markings with regard to manufacturer markings or Phillips, Getschow markings, Define allowable heat number transposition errors and responsibility assigned for resolution, and
            .      Issue nonconforming reports for deficient findings identified in Column 8, 12 or 16 under Section 10, Quality Control Documentation Review.

Pending licensee clarification and/or corrective action, and NRC review, the above items will remain open (456/84-09-07; 457/84-09-07). No items of noncompliance or deviations were identified.

8. Field Change Requests Field Change Requests were reviewed for timely resolution. Commonwealth Edison QA Manual, Q.P. No. 3-2, Design Change Control, allows verbal concurrence of Field Change Requests from Project Engineering, the Station Nuclear Engineering Department, or the Architect Engineer. Detailed below are the Field Change Requests reviewed:

C 7

{ FCR's L5000 thru L5199 Month / Year May/1982

                                                                  % Verbal Concurrence Only 33%

L5200 thru L5399 June /1982 10%

           .L5800 thru L5999         July /1982                             80%
        -. L6000 thru L6199          August /1982                           85%

L6400 thru L6599 September /1982 85% The number of outstanding Field Change Requests with only verbal approval and not documented written approval appear to exceed acceptable quality practices, considering the possibility of verbal miscommunication. The Project Manager for Commonwealth Edison also stated the licensee had previously identified this concern and was instituting corrective action, which included increased emphasis by Sargent and Lundy in documenting concurrence of Field Change Requests and incorporating the changes in the affected drawings in a timely manner. Pending licensee corrective action and NRC review, this issue will remain open (456/84-09-08; 457/84-09-08). No items of noncompliance or deviations were identified.

9. Electrical Installations Nonconformance reports written due to deficiencies in electrical installa-tions were reviewed. Problems identified by the nonconformances included:

incorrect weld details, exceeding dimensional tolerances, damaged cable pans, incorrect weld placement, and improperly located concrete expansion anchors. Nonconformances numbered 100'thru 150, written between April C 1981 and June 1981, and nonconformances numbered 1101 thru 1150, written between May 1983 and June 1983, were examined for proper signatures, disposition, and corrective action to prevent repetition. L. K. Comstock's Procedures 4.3.8, Cable Installation and 4.8.8, Cable Installation Inspection were examined. The inspector discovered that the QC inspector was required to check during cable installation such aspects as maximum pull tension, minimum bend radii, and cleanliness of the cable tray, but not check if the routing was correct, whether the cable was properly supported, and if the' cable pulled was of the correct type. Subsequently, the inspector discovered that Commonwealth Edison had been sited for deficient procedures concerning quality control inspections of proper routing, adequate support, and correct cable type in NRC in-spection report number 83-17, and had responded to the violations stating that procedures 4.3.8 and 4.8.8 were expected to be revised by March 30, 1984. The inspector brought the procedure deficiencies and the licensee commitment to the attention of Commonwealth Edison Project Management on May 10, 1984, and Project Management immediately issued a stop work order on all safety-related cable pulls. On May 18, 1984, the stop work order was lifted after the procedures 4.3.8 and 4.8.8 were revised, training was provided, and all applicable L. K. Comstock personnel were knowledge-able in the requirements to check adequate cable tray support, proper routing, and correct cable type. No items of noncompliance or deviations were identified. 8

. 10. Structural Steel Drawing Control The purpose of this inspection was to determine if G. K. Newberg Company and Commonwealth Edison Company were posting Engineering Change Notices (ECNs) and Field Change Requests (FCRs) to drawings and if the drawings were of the latest revision. The following structural drawings were reviewed:
. 5672 Rev. AN, Auxiliary Bldg. Foundation
. S673 Rev. AV, Auxiliary Bldg. Foundation
. 5682 Rev. AY, Auxiliary Bldg. Floor
. S695 Rev. AU, Auxiliary Bldg. Floor
. 51001 Rev. AP, Containment Bldg. Floor Framing
. S1283 Rev. C, Auxiliary Bldg.
. 5918 Rev. BB, Containment Bldg. Floor Framing
. 5965 Rev. P, Containment Bldg, Foundation Two locations were checked, the Commonwealth Edison main site office and the G. K. Newberg main site office. All the drawings were of the latest revision, however, Commonwealth Edison was writing on the applicable drawings the ECN and FCR numbers that affected the drawings, while G. K. Newberg was attaching 3"x5" index cards to the drawings stipulating the applicable ECNs and FCRs. The 3"x5" index card attachment was not adequate as the inspector identified drawings, specifically structural drawing S/283 and architectural drawing A-253, which had 3"x5" index cards missing, which were later found lying on the floor. With the cards lying on the floor, an individual checking the drawing for inspection or installation, would not be aware of drawing revisions, due to ECNs or FCRs.

The licensee was informed of the condition and immediately revised G. K. Newberg Company Procedure, Design Change Control, Section 33, Revision 4, to require that an FCR-ECN status book be maintained at each drawing location and each drawing noted "See Status Book", to assure awareness of all drawing revisions. The inspector considers this issue closed. No items of noncompliance or deviations were identified.

11. Craft Training L. K. Comstock has developed and implemented Work Instructions for electrical craft personnel. The inspector selected a sample of these work instructions and reviewed training records of electrical craft foremen. Work Instructions selected included:

             .      4.3.1,  Safety Related Conduit Installation
             .      4.3.5,  Safety Related Cable Pan Installation
             .      4.3.6,  Concrete Expansion Anchor Installation
             .      4.3.8,  Cable Installations
             .      4.3.9, Cable Termination
             .      4.3.13, Equipment Installation Procedure
             .      4.3.24, Rework 9

f- . 4.9.1, Control of Measuring and Test Equipment A . 4.9.3, Hanger Fabrication Procedure

              . 4.10.1, Handling
              . 4.10.2, Receiving and Storage The inspector discovered the following deficiencies:
              . No training records existed for craft foremen for Work Instruction 4.9.3,
              . The warehouse foremen had no training records for Work Instruction 4.10.2, and
              . Three foremen out of 23 did not have training records for Work Instruction 4.3.24.

Further investigation revealed that measures have not been established to assure that personnel were trained in the applicable Work Instructions prior to being assigned as craft foremen nor that all craft foremen were trained in all the applicable Work Instructions pertaining to their task responsibilities such as cable pulling, support installation, or rework duties. This item was brought to the attention of the licensee who stated that it was their belief that all craft personnel had been properly trained, but the training was not documented. The-licensee's construction manager, on May 31, 1984, stated to the NRC construction resident inspector that a formal written training program would be established for all craft ( foremen and the resultant training would be documented. This issue will

            . remain unresolved pending licensee implementation of the formal training program, NRC review of the program and NRC further investigation into electrical craft foreman knowledge of the applicable work instructions (456/84-09-09; 457/84-09-09).

While interviewing L. K. Comstock quality control supervision, the inspector discovered that L. K. Comstock does not have a final walkdown procedure. A final quality control inspection prior to licensee turnover assures that all installations are acceptable, and previously installed items have not been damaged or removed by other craft discipline personnel. uncontrolled removal has been a problem for L. K. Comstock, as identified in NRC Inspection Report 84-06. Pending licensee evaluation of this con-cern and NRC evaluation of L. K. Comstock inspections prior to installation turnover to the licensee, this issue will remain unresolved (456/84-09-10; 457/84-09-10).

12. Safety Related Equipment The Nuclear Regulatory Commission has previously asked Commonwealth Edison, (Byron /Braidwood Final Safety Analysis Report Question Q10.15 and Q10.38) to indicate postulated potential internally generated missile sources such as failures of valves, pump impellers and drive couplings for the entire Auxiliary Feedwater System including the diesel and motor driven pumps and the routing of system piping in the auxiliary building and the pipe tunnel. The licensee's analysis stated, "No missiles are C

10

n

l f- expected to result from failure of the motors ur diesels. A fragmented

     \      rotor will be contained by the stator of the electric motor. Parts ejected following an internal failure of the diesel engine would be con-tained by the engine crankcase. -In the unlikely event of fragments penetrating the stator or the crankcase, damage will be limited to the
        - room enclosing the diesel".        During an independent inspection of the auxiliary feedwater pumps the inspector noted a potential problem with the protective features provided for safety related systems assuming internal missiles are generated within the room which houses the diesel driven auxiliary feedwater pump. With a diesel engine failure, such as the loss of a connection rod, engine parts could be ejected through the engine housing, causing damage to the minimum flow lines, common to the diesel driven pump and the electrical motor driven pump, which are in close proximity (one to two feet in some areas) of the diesel engine.

The rupture of these minimum flow lines could result in the reduction of the total pump head pressure delivered to the system thus limiting the amount of water placed in the steam generators. Should the steam genera-tor pressure be greater than what the pump can attain while feeding a break in the 2 inch minimum flow line, no water would be delivered to the steam generators. This piping installation appears to be contrary to 10 CFR 50, Appendix B, Criterion IV, and the design analysis as stated in Section 3.5 of the Final Safety Analysis Report. The "as built" condi-tion of the auxiliary feedwater minimum flow lines is considered to be an unresolved item (456/84-09-11; 457/84-09-11), pending the licensee's demonstration that the installed system is designed such that missiles generated internally to the plant will not cause the loss of function of any design features provided for either continued safe operation or ( shutdown during transient or postulated accident conditions. A second area of concern is the designed lubricating oil system for the auxiliary feedwater pumps (electric motor and diesel driven) and the lubricating oil system for the speed increaser (1765 RPM up to 3570 RPM) for the diesel driven auxiliary pumps (see Attachment 1). In both systems all pressure and temperature sensing devices are located after the oil cooler.and do not indicate to an operator the condition of the oil filter on the discharge of the positive displacement oil pumps. No over pressure protection is installed for the main, (direct driven) oil pump and no oil filter by pass is provided to maintain minimum oil flow to the pump bearings should the filter become plugged. With only the present oil pressure switches or indicating gauge an operator cannot determine the condition of the pump output pressure, the AP_ across the oil filter, and AP or AT across the oil cooler. These readings are vital signs which are necessary to understand the operating conditions of each component and potential problem areas. The "as-built" condition of the auxiliary feedwater pump lubricating oil systems are considered to be an unresolved item (456/84-09-12; 457/84-09-12) pending further information from the licensee. No items of noncompliance or deviations were noted. L 11

.' 13. Preoperational Test Performance { During this reporting period the capacity tests, Procedure BWTP-DC-10, Sections 9.4 and 9.9, were performed on safety related battery banks _ Nos._111 and 112. The purpose of the test was to determine the capacity of the battery bank by performing an eight hour discharge test at a constant rate of 150 amps. Each battery bank was tested, continuously for eight hours and twelve minutes before the test was terminated by the System Test Engineer. At-the conclusion of each test the battery voltage remained above the cut off value of 101.5 volts meeting or exceeding the design criteria. The battery banks were placed on equalizing ' charge and monitored until normal operating voltage was obtained. No items of noncompliance or deviations were noted.

14. Open Items Open items are' matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. Open items disclosed during the inspection are discussed in Paragraphs 5, 7, and 8.

15. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncom-

    -fA      pliance, or deviations. Unresolved items disclosed during the inspection are discussed in Paragraphs 4, 5, 11 and 12.

16. Exit Interview The inspector met with licensee representatives (denoted under Persons Contacted) during and at the conclusion of the inspection on May 31, 1984. The inspector summarized the scope and findings of the inspection.

The licensee acknowledged the information. C 12

9 s O f tile r C oole r

                                                                                                                                                                                                  '_ C
                                                                                                                                          -%                                                     ,' L3 4

Cliock Valve 50 l us. il P mp o Oil S u c Main Oil Pump ( l I i i i 4 ! OstSumc G il Eur.o O il v cu rr, t R e lie t Valve Oil ic Be a rings

1. T e moc ra t ur e Gh ugc E. Low Oil F r e s s ur e Ala r r.

3. A u s sita r y Stog pr e ss ure S witch 4 A u a ilia r s Start Fretsure S witch

5. Oil Frescure Gauge L -

ATTACHMENT 1

p 1 i t

 ,                                                  UNITED STATES                                          I
 ~j    g9 garsag\                      NUCLEAR REGULATORY COMMISSION                                       l

{, c ,[' Q _ REGloN 111 ,

J s\* #'. E e 799 ROOSEVELT ROAD '

O, GLEN ELLYN, ILLINOIS 60137 WL.20284

                                                                   ,. m   m y     JUL 2 4 E0
                                                                   ~ . v Docket No. 50-456 Docket No. 50-457 Commonwealth Edison Company                                            .

ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen: This refers to the special safety inspection conducted by R. Schulz, J. Malloy and W. Kropp of this office on March 26, 28-29; April 3-5, 10-12 and May 23 and 31, 1984, of activities at Braidwood Station, authorized by NRC Construc-tion Permits No. CPPR-132 and CPPR-133 and to the discussion of our findings with Mr. C. Schroeder and others of your staff at the conclusion of the inspection. The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective Cexaminationof.proceduresandrepresentativerecords, views with personnel. observations,andinter-During this inspection, certain of your activities appeared to be in noncom-pliance with NRC requirements, as specified in the enclosed Appendix. A written response is required.

          -In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure (s) will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days of the date of this letter.      Such application must be consistent with the requirements of 2.790(b)(1). If we do not hear from you in this regard within the specified periods noted above, a copy of this letter, the enclosure (s), and your response to this letter will be placed in the Public Document Room.

The responses directed by this letter (and the accompanying Notice) are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511. L ATTACHMENT "I"

J12 010M Commonwealth Edison Company 2 F, - We will gladly discuss any questions you have concerning this inspection. Sincerely, h..,p. L ' .,.

                                                                              . .    ....N.

R. D. Walker, Chief Operations. Branch

Enclosures:

1. Appendix, Notice of Violation

              '2. Inspection Reports No. 50-456/84-07(DRS) and No. 50-457/84-07(DRS) cc w/encls:

D. L. Farrar, Director-of Nuclear Licensing M. Wallace, Project Manager R. Cosaro, Project Superintendent

         '{J.F.Gudac, Station Superintendent DMB/ Document Control Desk (RIDS)

Resident Inspector, RIII-Phyllis Dunton, Attorney General's Office, Environmental Control Division Jane Whicher, Esq. l-

~ f

                                                ' Appendix 4'                                     NOTICE OF VIOLATION
        ' Commonwealth Edison Company                           Docket No. 50-456 Docket No. 50-457 As a result of the inspection conducted on March 26, 28-29, April 3-5, 10-12 and May 23 and 31, 1984 and _in accordance with the NRC Enforceinent Policy 47 FR 9987 (March 9, 1982), the following violations were identified:

A. 10 CFR 50, Appendix B, Criterion II, as implemented by Section 2 of the Commonwealth Edison (CECO) Quality Assurance Program (QAP) Topical Report.

              -requires the program for the' indoctrination and training of personnel to be documented by written policies, procedures or instructions and carried out in accordance with those policies, procedures or instructions.

Contrary to the above:

1. L. K. Comstock failed to establish and implement a program for identifying the required reading for weld inspectors as part of their required training for certification.

2. L. K. Comstock failed to establish and implement a suitable program for conducting practical tests for the purpose of ascertaining if

( prospective weld inspectors were proficient in identifying weld defects.

3. Gust K. Newberg Construction Company failed to adequately implement the personnel indoctrination and training program with regard to the grading of General Tests given to QC inspectors. Specifically, three of the six tests reviewed were misgraded.

This is a Severity Level V violation (Supplement II) B. 10 CFR 50, Appendix B, Criterion II, as implemented by Section 2 of the CECO QAP Topical Report, requires the program to take into account the need for skills necessary to attain the required quality and to provide for indoctrination and training of personnel performing activities affecting quality. Contrary to the above, four L. K. Comstock weld inspectors were not proficient in the American Welding Society Structural Welding Code, AWS D1.1. This was evidenced by their inability to answer questions pertaining to the repair of weld cracks and fit up tolerances. This is a Severity Level IV violation (Supplement II) C. 10 CFR 50, Appendix B, Criterion XV, as implemented by Section 15 of CECO QAP Topical Report, requires that nonconforming items be reviewed and ( accepted, rejected, repaired or reworked in accordance with documented procedures.

Appendix 2 LContrary to the above,'L.'K. Comstock weld inspectors allowed craft

                          -personnel to repair / rework weld defects identified during final QC inspections, thereby circumventing the nonconformance- reporting system.

Thislis a' Severity Level IV violation (Supplement-II) D. :10-CFR 50, Appendix B, Criterion <XVI, as implemented by Section 16 of CECO QAP Topical Report, requires' conditions adverse to quality be promptly identified and corrected. Contrary to the above,' CECO did not take appropriate corrective action with regard to Audit QA-20-80-22, in that, an assessment of the QC inspectors

                          .' qualifications was not performed to address the potential' impact on work performed prior to the audit finding.
                          -This is a Severity Level V violation (Supplement II)

Pursuant to the provisions'of 10 CFR 2.201, you are required to submit _to this office:within thirty days of the date cf this Notice a written statement or-explanation in reply, including for each item of noncompliance: (1)

                    = corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance-will be achieved.' Consideration may be given to extending your response time r   for good cause shown.
              . (..

IC 2 6 G.V, g -r QUL 201964 C . - . u .? T , N I r $ - Date R. - DY Wal ker, Chief - Operations Branch j. !~ 4

 . *yt U. S. NUCLEAR REGULATORY COMMISSION REGION III Reports No. 50-456/84-07(DRS); 50-457/84-07(DRS)

Docket'Nos.'50-456; 50-457 Licensees No. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company P. O. Box 767 Chicago, IL ;60690 Facility Name: Braidwood Station, Units 1 and 2 Inspection At: Braidwood-Site, Braidwood, IL Inspection Conducted: March 26, 28-29, April 3-5, 10-12 and May 23 and 31, 1984

                          .      ?bO' e . x                                           .

Inspectors:, R. Schulz- -

                      .                                                        Date r

J. Kalloy U k 1/ 20/O '/ Date/ / W. dropp .' 7/20/P//

                             ,                                                 Dat( _ /

Approved By: F. Hawkins, Chief 7/20/6Y Quality Assurance Programs Section Dats ' Inspection Summary Inspection on March 26, 28-29, April 3-5, 10-12 and May 23 and 31, 1984

       .(Reports No. 50-546/84-07(DRS); 50-457/84-07(DRS)

Areas Inspected: Special safety inspection by regional inspectors of activi-ties pertaining to the qualification and certification of quality control inspectors. The inspection involved a total of 64 inspector-hours onsite by three NRC inspectors. Results: In the areas inspected, four items of noncompliance were identified (failure to suitably establish and implement a personnel training and indoctrination program - Paragraphs 2.b.(2)(b)2.c, 2.b.(2)(b)4_. and 2.b.(5); failure to provide adequate training - Paragraph 2.b.(2)(b)5; failure to identify nonconforming conditions - Paragraph 2.b.(2)(b)6; and failure to take appropriate corrective action - Paragraph 2.b.(4)(b)).

=

1. Persons Contacted Commonwealth Edison Company (CECO)

R. Cosaro, Construction Site Superintendent L. Tapella, Project QC Coordinator

             *C. D. Gray, Project Structural Supervisor C. Mennecke, Project Electrical Supervisor                .

T. Quaka, Site QA Superintendent T. R. Sommerfield, BCAP Representative G. Watts, Licensing and Compliance Staff Assistant

            *S. Reutcke, QA Engineer
            *C. Schroeder, Licensing and Compliance Superintendent D. Brown, QA Supervisor M. Curinka, Field Engineering R. Tate, QA Engineer
            *R. Wrucke, Licensing and Compliance Engineer
            *D. Shamblin, Project Construction Superintendent
            *K. Steele, Electrical Supervisor-Project Field Engineering
            *C. Tomashek, Startup Engineer
            *M. Gorski, PCD Engineer                                                               '
            *W. D. Burns, Staff Assistant
            *E. R.-Netzel, QA Supervisor
            *R. Farr, Project Mechanical Engineer Gust K. Newberg Construction Company (Newberg)

J. Harriston, QA Manager J. Perryman, Records Clerk D. Gorham, level II Inspector C. Zavada, Level II Inspector Pullman Power Products (Pullman) R. Waterfield, QA Coordinator D. Grant, QA Manager L. K. Comstock (Comstock) N. Conner, Level II , Weld Inspector L~. Bossong, Level II Weld Inspector M. Gerrish, Level II Weld Inspector J. Miner, Level II Weld Inspector J. Sumrow, QA, Engineer Pittsburg Testing Laboratory (PTL) F. Forest, QC Site Manager b 2

4

U. S. Nuclear Regulatory Commission (NRC) L. McGregor, Senior Resident Inspector

Denotes-those also attending the exit on May 31, 1984.

2. Functional or Program Areas Reviewed

a. Procedures Reviewed (1) Newberg Quality Control Procedure, Section 37, Revision 3,

                                     " Personnel Qualifications" (2)'       Newberg Quality Control Procedure, Section 31, Revision 9,
                                     " Erection and Inspection of Structural Steel"

_(3) Comstock Procedure 4.1.3, Revision B, " Qualification Classification and Training of QA/QC Personnel" (4) Napolean Steel Procedure No. 8, Revision 0, " Personnel Qualification and Certification Program" (5) Pullman Procedure B2.1F, Revision 3, "QC Personnel Qualifications" (6) CECO Directive BRD 7921, dated January 11, 1983 (7) _ CECO Memo, ERD-3630, dated March 11, 1980 (8) CECO Memo, dated March 27, 1980 (To: Newberg, Phillip-Getshow and L. K. Comstock, from: Ceco Construction Manager)

b. Site Contractor QC Inspector Certification Process (1) General The inspectors reviewed the pr.d ant QC certification procedures to verify compliance to ANSI N45.2.6-1978, CECO directives and CECO commitments to Regulatory Guide 1.58. The inspectors also reviewed the certificatior, of selected past and present QC inspectors. The review of the procedures and personnel certifi-cation records was performed pertaining to the following contractors:

(a) Newberg (civil and structural) (b) Napolean Steel (structural and post tensioning) (c) Pullman (HVAC) (d) L. K. Comstock (electrical) A Ceco directive (BRD 7921), dated January 11, 1983 was not in conformance to Regulatory Guide 1.58, in that, the directive (C - allowed site contractors to certify individuals as Level I or Level II inspectors when they did not meet the specified. experience requirements. 3

r' (I Specifically, the directive allowed this practice when on-the-job training was increased to the satisfaction of site contractor Level III. The CECO commitment to Regulatory Guide 1.58 as stated on Amendment 33 (October 1981) to the FSAR committed the licensee to the experience requirements specified in Section 3.5 of ANSI N45.2.6-1978. The CECO directive (BRD 7921) required the following minimum training for individuals being certified as a Level I or Level II inspector: 1 Required Reading 2 Formal Lecture (9 hours) 3 40 hours of mock inspections (on the job training) 4 General Test 5 Specific Test Even though the CECO directive (BRD 7921) is in conflict with the CECO commitment to Regulatory Guide 1.58, it appears the training and certification program described is an acceptable alternative to the experience levels defined in ANSI N45.2.6. This matter is considered an open item pending resolution of the conflict between CECO directive BRD 7921 and the FSAR (456/84-07-01; 456/84-07-01). ( The inspectors reviewed CECO correspondence BRD 3630, dated f4 arch 11,1980, and a memo dated March 27, 1980. Correspondence BRD 3630 required that each site contractor prepare a personnel qualification procedure which met the intent of ANSI N45.2.6. This correspondence further stated that if a qualification procedure already existed, the site contractors were to review and revise it to conform with ANSI N45.2.6. Correspondence BRD 3630 was sent to site contractors Newberg, Phillip-Getshow, and Comstock. Site records indicated that the correspondence was not sent to site contractor Napolean Steel. As a result, Napolean Steel did not have a procedure for certifying QC inspectors. The lack of a personnel qualification procedure for Napolean Steel was identified during a CECO audit (QA-20-80-22) in May, 1980. Paragraph 2.b.(4) of this inspection report documents further details regarding the audit finding. , (2) L. K. Comstock (a) Present Certification Program The present Comstock certification procedure, "Qualifi-cation, Classification and Training of QA/QC Personnel," Revision B was reviewed by the inspector and verified to be in compliance with ANSI N45.2.6-1978. Individuals were required to participate in 40 hours of mock inspections, { eight hours of lecture / demonstration, and one hour of formal lecture prior to certification ;ts a Level I or 4

( Level-II inspector. Individuals were also required to pass (80% or above) a general test of 40 questions and a specific / practical exam using a checklist and inspection tools. (b) 'QC Inspector Certification

              -1     The NRC inspectors reviewed certification documenta-tion of four QC inspectors who were certified on October- 20, 1981; June 22, 1982; July.7, 1981; and July 8, 1981. The certification documentation was reviewed to verify compliance to the Comstock proce-dure in effect at the time the inspectors were certi-fied. The procedure allowed certification of individuals without related experience when other factors provided reasonable assurance that an individ-ual could competently perform a particular task. Two of the inspectors were certified without any related experience. The basis for certifying these individu-als consisted of field training and an open book test.

The certification process of these two individuals was determined to be in compliance with the regulatory. requirements and the procedural requirements of the Comstock certification procedure in effect at the time of their certification. 2 One aspect of the prospective inspectors' training ({ consisted of a Familiarization Log which identified specific codes and procedures to be read. Discussion with Comstock's QA Department revealed that there was no formal system for identifying required reading for a specific inspection activity. As a result, the required reading completed by weld inspectors was not consistent for each individual. The inconsistencies were as follows: a

One QC Inspector did not read QC Manual, Section 4.8.15 (" Document Control") and the AWS D.1.1 Code b One QC Inspector did not read QC Manual, Section 4.8.2 (" MIG Welding Inspection") and Section 4.3.14 (" Manual Shielded Metal Arc Welding Stainless Steel") c One QC Inspector did not read QC Manual, Section 4.8.2 (" MIG Welding Inspection") This failure to establish and implement an indoctrination and training program documented by written policies, procedures or instructions is considered to be an item of noncompliance with j ( 10 CFR 50, Appendix B, Criterion II. (456/84-07-02(a); 456/84-07-02(a)) 5 L-

3 The review of the certification folders for three C inspectors revealed that the folders did not contain the written QA test as required by Comstock Procedure 4.1.3 and CECO directive BRD 7921. The tests were subsequently located by the licensee and reviewed by the inspector. The test consisted of three questions with each question being weighted respectively, (45%, 40%, 15%). Therefore, the third question, which appeared to be the most difficult, could be missed and the individual would have a passing grade of 85%. Licensee personnel stated that the test was being revised to resolve the inspector's concern. This matter is considered an open item (456/84-07-03; 457/84-07-03). 4_ The inspector reviewed the practical test given to four prospective weld inspectors. The practical tests included the-inspection of installed items under the supervision of a Level II weld inspector. The practical test performed by these four inspectors did not test the individuals' capability of identifying weld defects because the items which were inspected did not contain weld defects (i.e., undercut, cracks, porosity, etc). This failure to establish a suitable program for ( conducting practical tests is a iurther example of noncompliance with 10 CFR 50, Appendix B, Criterion II (456/84-07-02(b); 456/84-06-02(b)). 5 Interviews were conducted with four Level II weld inspectors to assess their working knowledge of the AWS Dl.1 Structural Welding Code. The AWS Code was the applicable welding code for Comstock activities. The NRC inspectors concluded from the interviews that the Comstock inspectors had not achieved the necessary level of competency to perform their assigned weld inspection tasks. This was evidenced by the inability of the weld inspectors to state the correct tolerance for weld fit-up and the proper technique for the repair of cracks as required by AWS Dl.l. This failure

                   .to provide for indoctrination and training of personnel performing activities affecting quality is considered to be.an item of noncompliance with 10 CFR 50, Appendix B, Criterion II (456/84-07-04; 457/84-07-04).

6 Mock inspections totalling at least 40 hours had been performed by prospective weld inspectors. These mock inspections were performed on installed items (i.e. cable hangers, cable trays, etc.) under the direct ( supervision of a Level II weld inspector. The inspector checklist for one mock inspection report 6

e-( contained the statement, " welds repaired prior to acceptance." Discussions with the four Level II welding inspectors revealed that defects identified during a final QC inspection were allowed to be reworked / repaired by craft personnel. This practice, in effect, circumvented the Comstock nonconformance reporting system. Comstock Procedure 4.11 ("Noncon-

                             . forming Items.and Corrective Action") requires that a nonconformance report be initiated by QC personnel on detection of deviations that confl-ict with specifications and/or drawings.          This failure to                  .

assure that noncomforming items are reviewed and accepted, rejected, repaired, or reworked in accordance with documented procedures is considered to be an item of noncompliance with 10 CFR 50, Appendix B, Criterion XV (456/84-07-05; 457/84-07-05). (3) Pullman Power Products The inspectors reviewed the present Pullman certification procedure and it was determined to be in compliance with ANSI N45.2.6-1978. The certifications of four previously employed QC inspectors and four present QC inspectors were reviewed. The practical tests administered to prospective weld inspectors consisted of weld coupons with known defects that (. the. inspector was required to identify. No items of noncom-pliance or deviations were identified, s (4) Napolean Steel The NRC inspectors reviewed the QC inspector certification process for Napolean Steel. Although no longer on site, Napolean Steel had performed concrete preplacement, reinforcing steel, cadwelding, post-tensioning, and inprocess containment structural steel weldments inspections. Prior to August 4, 1980, Napolean did not have an approved procedure to qualify and certify QC inspectors. Review of CECO audits performed on Napolcan Steel revealed the following: (a) Audit.QA-20-78-23, performed on June 30, 1978, was a special audit to verify Napolean was in compliance with the intent of ANSI N45.2.6. No significant audit findings were noted by the lic'ensee. (b) Audit QA-20-80-22, performed on May 30, 1980, identified Napolean did not have a procedure for qualifying and certifying QC Inspectors. The specified corrective action required Napolean to write and issue a procedure for certifying QC inspectors. The corrective action did not ( assess the adequacy of the inspectors' qualifications for potential impact on work performed prior to the audit 7

4. finding. These inspectors had performed inspection in the C areas of concrete preplacement, reinforcing steel installa-tion, cadwelding activities, and containment structural steel welding. This failure to take appropriate corrective action in regard to an identified nonconformance is considered to be an item of noncompliance with 10 CFR 50, Appendix B, Criterion XVI. (456/84-07-06; 457/84-07-06) The inspector reviewed the Napolean Procedure NSCI-8, Revision 0 (" Personnel Qualification and Certification Program"). The procedure was written and issued as a result of CECO audit QA-20-80-22. The procedure allowed individuals with a high school diploma and no related experience to be certified with indoctrination in the QA program and six hours of on-the-job training in each specific quality control procedure applicable to the area of certification. Amendment 33 of the Braidsood FSAR,_ dated October 1981, stated that CECO complied with Regulatory Guide 1.58 (September 1980), position 6, with no exception to experience requirements. However, Napolean Procedure NSCI-8, Revision 0, was not revised subsequent to Amendment 33 of the FSAR to comply with CECO's commitment to Regulatory Guide 1.58. A review of certification files of QC inspectors certified af ter October 1981 revealed that une inspector was certified without any previous related experience. The review of the file for the inspector revealed that he was hired August 6, 1982, and certified as Level I in field button ( heading of post tensioning tendons (8/10/82); post tensioning tendon installation (8/18/82); and stressing of post tensioning tendons (8/18/82). The inspector had no previous related experience and certification was based on eight days of on-the-job training and a written examination. The certification of this individual was in accordance with Napolean procedure, NSCI-8. Even though Napolean procedure NSCI-8 did not meet the requirements of CECO's commitment to Regulatory Guide 1.58, the training received by the individual was appropriate for the narrowly defined area of inspection responsibility. The inspector has no further questions regarding this matter at this time. (5) Gust K. Newberg Construction Company The inspector reviewed the Newberg Quality Control Procedure,

               " Personnel Qualification", Section 37, Revisinn 3, to verify compliance with ANSI N45.2.6-1978.      The procedure was reviewed to ensure incidsion of experience and education requirements for the inspectors.

The inspector reviewed the certification records for eight Newberg inspectors. The certification review included the j' verification of experience, education, and certification tests. t The tests included a general written test, specific written ( test, and practical oral test administered by a Level II or Level III inspector. The method of conducting the practical tests was reviewed and found to be acceptable. 8 L-

, _- - ~

     ,                    c' a

( Additionally, six general tests were reviewed and three were found to be graded incorrectly. According to Table 1 of Section 37, the requirement for passing the general test was a score of 80%. One Newberg structural steel and concrete expansion anchor Level II inspector answered 31 of 40 questions

                              -correctly; constituting a failing score of 77.5%.      This general test was erroneously scored 80% and the 80% score was documented on Form 37-1, " Qualification Examination Form." When identified to the Newberg Quality Assurance Manager, he stated that the inspector would be retested. Also, general tests for two other inspectors were incorrectly graded. Two questions for each individual were marked correct when in fact they were.

the wrong answers. After the correction, the scores for both individuals were still above 80%. These three instances of failing to carry out the training and indoctrination program in accordance with written policies, procedures, and instructions is considered to be a further example of noncom-pliance with 10 CFR 50, Appendix B, Criterion II (456/84-07-02(c); 456/84-07-02(c)). Newberg began conducting QC inspections at Braidwood as early as March 1, 1976. The Newberg Quality Control Procedure,

                               " Personnel Qualifications", Revision 0, was dated March 19, 1980. Prior to March 19, 1980, no procedural requirements existed for personnel qualification. However, a review of qual-ification records for three QC inspectors who performed inspec-(                tions prior to March, 1980, indicated the inspectors were qualified to perform their assigned tasks.

3. Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspectors, and which involve some action on the part of the NRC or licensee or both. Open items disclosed during the inspection are discussed in Paragraphs 2.b.(1) and 2.b.(2)(b)3.

4. Exit Interview The inspectors met licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on May 31, 1984. The inspectors summa-rized the scope and results of the inspection.

L 9

LD5 8, p t efg UNITED STATES y .

                          'g                NUCLEAR .":EGULATORY COMMISSION .

{' c g REGION lil

g. j 799 ROOSEVELT ROAD GLEN ELLYN. ILLINOl$ 60137

.;Z.. #g MAY 231934 Mg25 m Docket No. 50-456 Docket No. 50-457 Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:

                .This refers to the routine safety inspection conducted by Messrs. L. G. McGrecor and R. D. Schulz of this office on April 1 through April 30, 1984, of activities
                                                                      ~

at Braidwood Nuclear' Power 5tation711 nits 1 and 2,"3utho~ rized by NRC C3nstruc ' tion Permits No. CPPR-132 and No. CPPR-133 and to the discussion of our findings with Mr R. Cosaro at the conclusion of the inspection. The enclosed copy of our inspection report. identifies areas examined during

     .           the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.

During this inspection, certain of your activities appeared to be in non-comoliance with NRC requirements, as specified in the enclosed Appendix. A written response is required. In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter, the enclosures, and your response to this letter will be placed in the NRC's Public Document Room. If this report contains any information that you (or your contractors) believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by telephone within ten (10) days from the date of this letter of your intention to file a request for withholding; and (b) submit within twenty-five (25) days from the date of this letter a written application to this office to withhold such in-formation. If your receipt of this letter has been delayed such that less than

                -seven (7) days are available for your review, please notify this office promptly so-that a new due date may be established. Consistent with Section 2.790(b)(1),

any such application must be accompanied by an affidavit executed by the owner of the information which identifies the document or part sought to be withheld, and which contains a full statement of the reasons which are the bases for the claim that the information should be withheld from public disclosure. This section further requires the statement to address with specificity the con-siderations listed in 10 CFR 2.790(b)(4). The information sought to be withheld ATTACIIMENT "J"

CCommonwealthEdisonCbmpany 2 [W$,v 4 i ueg r,..gga4 v shall be incorporated as far as possible into a separate part of the affidavit.

         .If we do not hear from you in this regard within the specified periods noted above, a copy of this letter, the enclosures, and your response to this letter will be placed in the Public Document Room.

The responses directed by t'.is letter (and the accompanying Notice) are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

        -We will gladly discuss any questions you have concerning this inspection.

Sincerely, RFidwM R. F. Warnick, Chief-Projects Branch 1

Enclosures:

1. Appendix, Notice of. - '

Violation

2. Inspection Reports No. 50-456/84-08(DPRP);

No. 50-457/84-08(DPRP) cc w/encis: D. L. Farrar, Director of Nuclear Licensing M. Wallace, Project Manager

       ~R..Cosaro, Project Superintendent J. F. Gudac, Station Superintendent DMB/0ccument Control Desk (RIDS)

Resident Inspector, RIII Phyllis Dunton, Attorney General's Office, Environmental Control Division Jane Whicher, Esq. L

E *

.(

Appendix NOTICE OF VIOLATION Commonwealth Edison Comnany Docket No. 50-456 Docket No. 50-457 As a result of *he inspection conducted on April 1 through April 30, 1984, and in accordance with the General Policy and Procedures for NRC Enforcement Actions, (10 CFR Part 2, Appendix C), the following violations were identified:

1. 10 CFR 50, Appendix B, Criterion IX requires that measures shall be established'to assure that'special-processes, including welding are controlled and accomplished in accordance with applicable codes.

Sargent and Lundy Specification, F/L-2735, Structual Steel, 11/25/77 commits to AWS 01.1, Structual Welding Code, 1975. AWS 01.1, 1975, requires in Section 6, Inspection, the inspector shall examine the work to make sure that it meets the requirements of Secticr. 3, which includes fit-up tolerances. ( Contrary _to Jhe above. the_Napolean Steel Contractors, Inc. Quality

             . ,A.ssurance Program.did not require fit-up inspections for safety related, structural steel members _joi.ned by welds and therefore, quality control personnel did not i,spect and assure acceptable gaps for weld joints.

This is a Severity Level IV Violation (Supplement II).

2. 10 CFR 50, Appendix B, Criterion XVI, as implemented by Ceco QA Manual, QR No. 16.], requires that measures shall be established to assure that conditions adverse to quality are promptly identified and corre;ted.

Commonwealth Edison Audit No. QA-20-80-22, performed on 5/30/80 and 7/10/80, stated that in-process inspections of welding activities conducted by Napolean Steel Contractors, Inc. have not been performed in sufficient depth, as no documented in process inspection is performed on the actual weld prccess itself for pre-heat, interpass temperature, position, weld Lead layering and interpass grinding, where a defect could' conceivably be buried deep with a multi pass weld. l

f . J f. , , Appendix 2 Contrary to the aboye __ a Commonwealth FJis.on_ Quality Assurance identifiecj_ the inspection deficiencies but failed to take corrective action f' with regard to Napolean Steel __ Contractors, Inc. past welding inspection activities to assure that defects do not exist in multi pass welds. This is a Severity Level IV Violation (Supplement II). Pursuant to the provisions of.10.CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written state-

t. ment or explanation in reply, including for each item of noncompliance:

(1) corrective action taken and the resuits achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when. full compliance will be achieved. Consideration may be given to extending your response time for good cause shown. MM 221984 ggg7),,g Dated Re . F. Warnick, Chief Projects Branch 1 C t

?,

r I i

i

({ U. S. NUCLEAR REGULATORY COMMISSION REGION III , Reports No. 50/456-84-08(DPRP); 50/457-84-08(DPRP) Docket Nos. 50-456/ 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, Il 60690 Facility Name: Braidwood Nuclear Power Station, Units 1 and 2 Inspection Conducted: April 1 through April 30, 1984 Inspectors: L. G. McGregor R. Schul 3 Q- 1% 1, t y. Approved By: .fcrr6dr,'ChiefT d- [fY Projects Section IB Dats // Inspection Summary

         < insoection April 1 throuch April 30, 1984 (Reports No. 50-456/84-08(DPRP);

50-457/84-08(OPRP) Areas Inspected: Routine, urannounced safety inspection to review preopera-tional testing, plant tours of general work activity including' fire, safety and implementation of housekeeping requirements, review of structual steel installation inspection program, review of cable tray installation, inspection of safety related welding records and review of material purchasing records. The inspection consisted of 294 inspector hours onsite by two NRC inspectors including 43 inspection hours onsite during off shifts. Results: Of the six areas inspected, no item of noncompliance or deviations were identified in five areas, two items of noncompliance were identified for failing to perform required fit-up inspection and failure to take correc-tive action with regard to welding inspections (paragraph 3.a). S

( DETAILS

1. Persons Contacted '

Commonwealth Edison Company (CECO)

                *M. Wallace, Project Manager
               *R..Cosaro, Construction Superintendent
               *C. Schroeder, Licensing and Compliance Superintendent
               *T. Quaka, Quality Control Supervisor
               *L. Tapella, Engineer G. Groth, Lead Mechanical Engineer

8. Tanouyi, Engineer S. Reutcke, Quality Assurance Engineer R. Tate, Quality Assurance Engineer

               *S. Hunsader, Quality Assurance Supervisor G. Fitzpatrick, Assistant Manager Quality Assurance Corporate M. Curinka, Engineer
               *R. C. Lemke, Technical Staff Supervisor
               *C. J. Tomashek, Startup Superintendent
               *E. R. Wendorf, Project Field Engineering Mechanical Supervisor
               *R. Wrucke, Licensing Engineer
               *D. L. Shamblin, Project Field Engineering Manager Phillips Getschow Company (PGCo)

T. G. O'Connor, Site Manager K. J. Hamilton, Consultant J. Carlson, Quality Control Supervisor L. J. Butler, Assistant Quality Control Supervisor M. Galloway, Assistant Project Engineer G. K. Newberg Company J. J. Hairston, Quality Assurance Manager L. K. Comstock and Company, Inc. (LKC) R. E. Marino, Quality Assurance Manager Corporate L. G. Seese, Assistant Quality Control Manager Site J. A. Hii, Project Engineer R. Brown, Lead Inspector Mechanical D. Holley, Quality Control Inspector Pittsburgh Testing Laboratory (PTL) , F. Forest, Site Manager T. Frazier, Assistant Sita Manager *

Denotes those personnel attending the exit interview.

2

(2. Plant Tours The inspectors observed work activities in progress, completed work and plant status in numerous areas during genbral inspections of the plant. Activities witnessed included transfer and rigging of pipe' spools, end prepping of pipe, pipe installation, structual support welding, anchor bolt installation, cable tray support installation, and housekeeping. Craft personnel, supervision, and quality inspection persor.nel were interviewed as such personnel were available in the work areas. The inspectors noted that many cable trays are extremely dirty and will require a significant amount of effort to bring them to the required cleanliness levels, prior to final cable tray acceptance. Also the protection of installed cables, located beneath in process welding activities, requires additional attention. During one of the tours it was noted that some pipe, that had not been permanently supported, was being used to support scaffolding. The inspectors brought this concern to the attention of the PGCo Site Manager, who immediately corrected the situation by removing the scaffolding. No items of noncompliance or deviations were identified.

3. Structual Steel .

The inspector reviewed Napolean Steel Contractors, Inc. (NSCI) structual steel erection and inspection program. Napolean was awarded the structual steel erection contract on March 28, 1979 for Containment No. I and No. 2. Documents reviewed included: Napolean Procedure #5, Welding, Revision 6 Napolean Procedure #6, Erection of Structual Steel, Rev'ision 1 AISC Specification For Structual Joints Using ASTM A325 or A490 Bolts, dated 1976 AISC Manual of Steel Construction Sargent and Lundy Specification, F/L-2735, Structual Steel 11-25-77 AWS D1.1, Structual Welding Code, 1975

a. Welding /NDE In process welding inspections were done by Napolean quality control inspectors while Pittsburgh Testing Laboratory quality control inspectors perfo'rmed the final welding inspection and subsequent nondestructive examinations. In process welding inspections were required to be done every three months on a random selection of welders. Napolean employed approximately two to twelve welders during their structual steel erection work, which is now completed, and utilized seven welding proce-dures consisting of four groove weld procedures and three fillet weld procedures. The in process inspection records were. checked, by the NRC inspector, for the period April 1979 through April 1981 and in process inspections were performed every three months 3

r _ ( on an appropriate number of welders, with the exception of the period that Braidwood construction activities ceased, from September 1979 through March 1980. The following attribute's were checked: '

                . welding current
                . proper procedure
                . electrode condition
                . welds properly stamped
                . correct current and voltage of welding machine Napolean Quality control personnel did not perform fit-up checks as the Napolean Quality Assurance Program for welding in process inspections did not require fit-up verifications. This is in      !

violation of 10 CFR 50, Appendix B, Criterion IX and AWS DI.1, Section 6, Inspection (456/84-08-01; 457/84-08-01). Commonwealth Edison Audit No. QA-20-80-22, performed on 5/30/80 and 7/10/80 for Napolean construction activities, was reviewed - and the auditor reported a finding concerning the lack of depth of in process inspections. The audit report stated:

                      "In process inspections of welding activities conducted by NSCI have not been performed in sufficient depth to adequately assure that welding is being performed according to procedures."

(

                      "Although in process welding inspections are being performed on welding activities in the areas of electrode condition, welding machine condition, stamping, and proper current levels, no documented in process inspection is p'erformed on the actual welding process itself for such items as pre-heat, interpass temperature, position, weld bead layering and interpass grinding or cleaning. This type of surveillance is very important for multi pass welds where a defect could conceivably be buried deep within the weld."

The QC Manager for Napolean responded on July 22, 1980 as follows:

                     "To clarify the documentation of NSCI in process welding inspection, the welding detail, weld number, and activities monitored such as the cleaning, grinding, layering etc, will be noted in the remarks section on future NS-10 reports."

NS-10 reports were the inspection reports documenting the three month in process inspections. The response.was accepted by the Commonwealth Edison QA Supervisor on October 8, 1980. The acceptance of this response failed to consider corrective action 4

c ( for past work with regard to multi pass welds where a defect, caused by improper welder workmanship or technique, could con-ceivably be buried deep within the weld. AWS 01.1, Section 4, Technique, addresses proper preheat, intsrpass temperature, layering, progression and position. AWS D1.1 Section 3, Workmanship, addresses in process cleaning. AWS D1.1, Section 6, Inspection, requires the inspector to examine the work to the requirements of Section 3 and Section 4. Failure to take corrective action with regard to past welding inspection activities, which are found to be inadequate, is in violation of 10 CFR 50, Appendix 1, Criterion XV (456/84-08-02, 457/84-08-02). Subsequently, the inspector reviewed numerous Pittsburgh Testing Laboratory (PTL) final welding inspection reports and nondestructive examination reports, including a review of the PTL inspection request logs and weld details. From this review the inspector identified the following issues, and requested the licensee to investigate each issue in detail for resolution and possible corrective action: (1) Some of the visual weld inspections performed by PTL were performed after the weld joints were painted. An example of this inspection method af ter painting is documented on PTL inspection report #709VW. The visual weld inspections were for Unit 2 Containment and identified on #709VW as follows: ( Drawino No. Weld No. Weld Type Size E209 1344A Fillet 3/16", E209 1344B Fillet 3/16" E201 1585E Fillet 3/8" E201 1585F Fillet 1/4" The report stated " Inspected through paint per Commonwealth Edison QA". (2) It appeared that when a weld was nondestructively examined, such as a full penetration weld, the final visual weld inspection was waived. Final visual weld inspection is required by AWS 01.1, Section 6. (3) There did not appear to be a quality documentation system established, assuring that all the structual steel welds which Napolean completed, had all the required examinations performed, such as visual, magnetic particle, ultrasonic, or radiograph as applicable for each weld. For example, although weld No.1052, had a Ultrasonic Test Report #206, PTL was, not able to locate a final visual report or magnetic p6rticle report. This full penetration weld was located in Unit 2 Containment and identified on drawing E203. 5

e ( Pending licensee evaluation and possible corrective action and subsequently supplying the appropriate information to the

                     'NRC for review, these three issues will remain unresolved (456/84-08-03; 457/84-08-03).          '

Napolean Procedure #5, Welding, stated that all welding performed by liapolean was deemed prequalified joints and exempt from tests or qualification. The inspector has requested the licensee to address whether all, joints completed by Napolean are considered prequalified. Normally, considering the scope of Napolean's work, approximately five percent of the joints would not be pre-qualified and therefore would be subject to qualification. Review by the licensee needs to include a review of all the Sargent and Lundy weld details within the scope of Napolean's contract. This issue will remain open pending licensee review (456/84-08-04; 457/84-08-04).

b. High Strenoth Bolting The inspector determined through visual inspections and documentation reviews that each day Pittsburgh Testing Laboratory.

tested three bolts in a tension device and determined a torque-tension relationship for each bolt diameter as stipulated in Sargent and Lundy Specification, F/L-2735, Structual Steel. Based on the torque-tension relationship, ten percent of the installed high strength bolts, but never less than two, were ( tested to the derived torque value with a calibrated torque wrench as required by AISC Specification For Structual Joints Using ASTM A325 or A490 Bolts. If any of the bolts tested failed, all the bolts in the connection were re-torqued. Pittsburgh Testing Laboratory inspection reports for the following beam and column connections were reviewed: Inspection No. of Torque, Bolt Report Connection Bolts-Size Ft-lbs. Specification No. 246B3, 212R29* 24-1 1/8" 1150 ASTM A490 58-283 24281, embed 6-1 1/8" 1150 ASTM A490 SB-283 24784, 210R31* 24-1 1/8" 1150 ASTM A490 SB-283 26782, R31* 3-1 1/8" 850 ASTM A490 SB-281 23781, 211R30* 6 7/8" 360 ASTM A325 SB-283R1 185B2, A159B1 9 7/8" 360 ASTM A325 5B-245 15881, 1598: 16 7/8" 360 ASTM A325 SB-245 157B1, A171R17 16 7/8" 360 ASTM A325 5B-245 188B2, 18883 9 7/8" 360 ASTM A325 SB-264 18382, 199R5 15 7/8" 360 ASTM A325 58-249 A182B2, 19781 14 7/8" 360 ASTM A325 58-249 25781, 279R30 9 7/8" 360 ASTM A325 SB-281 L ' 6

c ( 294R32, 25783 28189, A253B4 9 7/8" 6 7/8" 360 360 ASTM A325 ASTM A325 58-283 SB-281 294R32, 28883 9 7/8" 360 ASTM A325 SB-283 A255R33, 28881 9 7/8" 360 ASTM A325 58-285 R21 Column Splice

44 7/8" 360 ASTM A325 '58-298 B122B6, 8122B2* 6 7/8" 360 ASTM A325 SB-270 R18 Column Splice
66 7/8" 360 ASTM A325 58-298 8122B9, B12284 6 7/8" 360 ASTM A325 58-272 R11 Column Splice
_44-7/8" 360 ASTM A325 SB-298 B12286, B122Bl* 6-7/8" 360 ASTM A325 58-272 291B4, 257B1* 6-7/8" 360 ASTM A325 58-281 R32 Column Splice
44-7/8" 360 ASTM A325 5B-283 R35 Column Splice
66-7/8" 360 ASTM A325 58-285 26384, L272B2* 6-7/8" 360 ASTM A325 58-285 237B1, 211R30* 6-7/8" 360 ASTM A325 SB-283R1 259B1, R30 9-7/8" 360 ASTM A325 SB-281

            *The connections with an asterisk were re-torque tested and examined by the NRC inspector for correct marking of bolts, minimum edge distance, and correct number of washers ~.

All of the ASTM A325 bolts were installed correctly and passed the additional NRC requested torque test, with the exception of connection 211R30, 23781, which is a column to beam connection in Unit 2, Reactor Containment. All six bolts were torque tested and witnessed by the NRC with the following results: 2 bolts - 50 Ft.-lbs. 1 bolt - 100 Ft.-lbs. 2 bolts - 175 Ft.-lbs. I bolt - 275 Ft.-lbs. These figures are considerably below the 360 Ft.-lb. installation inspection torque. It appears these bolts had been removed and replaced, but not re-torque tested. The inspector has requested the licensee to determine if these torque values are acceptable for this type of connection. Pending licensee review and possible corrective action the acceptability of this connection will remain unresolved (456/84-08-05; 457/84-08-05). All of the ASTM A490 bolts were acceptable with regard to number of washers, correct marking, and minimum edge distance. Identi-fled below are the results of the NRC witnessed additional beam to column torque test: m 7

 ~                                              _

y

[ No. of Bolts Original Inspection Date of Torque Bolts In Torque Original Connection Tested Connection Ft.-lbs. Inspection 24784, 210R31 14 24 1150 1-15-81 (Results)

                -                      (2 - 300 Ft-lbs)

(1 - 400 Ft-lbs) (5 - 600 Ft-lbs) (2 - 800 Ft-lbs) (3 - 900 Ft-lbs)

                                     *(1 - 1050 Ft-lbs) 24683, 212R29        11           25            1150             1-15-81 (Results)

(2 - 500 Ft-lbs) (3 - 700 Ft lbs)

                                     *(6 - 1050 Ft-lbs) 26782, R31             3            3             850             11-18-80 (Results)-

(1 - 550 Ft-lbs). (2 - 900 Ft-lbs)

                                     *(1 - 1050 Ft-lbs)

( *The bolts with an asterisk did not turn at 1050 Ft.-lbs. 'there-fore they were torqued to a value higher than 1050 Ft.-1bs. The other bolts turned at the value reported. A calibrated torque wrench was used for the testing. All the cannections were located in Unit 2, Reactor Containment. Based on the ASTM A490 torque test results the inspector has requested the licensee to address the following three questions: (1) What relaxations (Ft.-lbs.), over time, are anticipated for ASTM A490 bolts, considering size of bolts and type of connections? (2) Are these ASTM A490 Connections, tested and witnessed by the NRC, acceptable or do they require bolt replacement? (3) Since the low torque values recorded only represent a sample, what generic implications, if any, need to be considered; and is the testing of only 10% of the bolts but never less than two, adequate to assure acceptable installations? Pending licensee review and evaluation, and NRC review based on licensee submitted information, the ASTM A490 high strength bolt installations will remain unresolved (456/84-08-06;.457/84-08-06). 8

Cable Tray Support Welding ( 1. The following documents were initially reviewed:

             . Sargent and Lundy Specification, F/L-2790, Electrical Installation Work, Amendment 30, 7-14-83.
            . L. K. Comstock Procedure 4.8.3, Weld Inspection, 12/28/83.

L. K. Comstock Procedure 4.3.3, E7018, Welding Procedure For Structual Attachments, 12/3/83.

            . L. K. Coms'.ock Procedure 4.3.3.1, E6013, Welding Procedure For Structual Attachments, 4/05/84.
           . AWS D1.1, 1975 After reviewing the above documents and interviewing craft personnel and L. K. Comstock quality control inspectors, the NRC inspector learned that the correct welding detail is selected and documented by craft personnel, (and not stipulated by engineering personnel prior to commencement of welding), on, the traveler package or as referred to by L. K. Comstock, the " Welding Installation Record".

Obtaining the correct detail involves examining the hanger list and subsequently reviewing various cross reference tables. Numerous welding details exist, with only slight variations for some of the details. ( Placing this responsibility on craft personnel, rather than on engineering personnel, can only be justified if all craft personnel are thoroughly familiar with all the welding details and therefore, only the correct welding details are selected. The inspector selected six cable tray supports, located in the auxillary building, Unit 2, and examined the field welded details and associated hardware. On two of the six supports, craft personnel recorded an incorrect welding detail. The supports selected are identified below: Acceptable Suoports Cable Tray Support Welding Details Recorded Correct Welding Octails H110-13H Yes Yes H-115-A/S Yes Yes H534-A/S Yes Yes H106-A/S Yes , Yes Deficient Supports ,

         .      For cable tray support H96-4H, craft personnel recorded .

a welding detail of DV-89 on the " Welding Installation 9

e ( Record", while the actual field welded detail (as installed) for connection #1, STD-EB-116.4 was UV-90-B-2. In addition, after checking the hanger and cross re,ference tables the inspector learned that. connection #1 was' stipulated as a DV-58 detail. For connection #2, STD-EB-116.4, the actual field welded detail (as installed) was DV-1, but craft personnel recorded the detail on the " Welding Installation

                ,         Record" as DV-2. Thg connection was stipulated as a DV-1 detail per the hanger and cross-reference tables.
                    . For cable tray support H105-13H, craft personnel recorded a welding detail of DV-89 on the "Weldirg Installation Record",

while the actual field welded detail (as installed) for connection #1, STD-EB-116.13, was DV-90 alternate. This connection was correct, as installed, per the hanger and cross-reference tables. Since December 1983 craft personnel have been selecting and recor' ding the welding detail on the " Welding Installation Record." Cable tray support H96-44 had a " Welding Installation Record" dated 1/26/84. Cable tray support H105-13H had a " Welding Installation Record" dated 2/3/84. Therefore, due. to the NRC sample inspection identifying the previously mentioned deficiencies, the inspector has requested the licensee to take the following corrective action:

a. Examine all field welded electrical supports installed

( since December 3,1983 for the purpose of determining the accuracy of the documentation and the acceptability of the actual field welded detail.

b. Transfer the responsibility and task of correct welding

                       . detail selection to engineering personnel prior to commencement of welding, instead of the present welding detail selection by craft personnel.

92 i Propose an alternative to (1) and (2) that will assure correct installations and accurate documentation. Pending licensee review, evaluation, and corrective action, the issue of correct electrical support details and accurate documentation will remain an unresolved item (456/84-08-07; 457/84-08-07).

5. Preoperational Test Performance The inspector witnessed the performance of portions of test procedure AP-13 Auxiliary Power 480 volt unit substations and above (ESF),

t 10

e ( section 9.1. The test included briefings, installation of calibrited test equipment, observations of precautions, documentation of results. No apparent items of noncompliance were observed.

6. Records Review

          -   During a review of plant certified material test reports and product specification sheets, it was noted by the inspector that ASME piping components and material was being ordered under the requirements of ASME Section III, Division 1, Class 1,1980 edition including Summer of 1980 addenda. In the Final Safety Analysis Report (FSAR), the licensee has established, per ASME Code requirement, the Code Edition and Addenda to be included in the Design Specifications. The licensee's QA Manual (Section 17 of the FSAR) and the Design Specifications have committed to the construction of the Braidwood Nuclear Power Plant to ASME Section III, Division 1, Class 1, 1974 edition including Summer 1975 addenda.      The use of differing code editions becomes compounded by the following statement which is part of the product specification sheet for material purchasing. "The code dates and addendas specified herein have been accepted in lieu of the former requirements of the Summer of 1975 edition by the enforcement authorities having juris-diction at the Braidwood Nuclear Power Station Site."

The Code definition for Enforcement Authority; denotes a regional or local governing body, such as a State of Municipality of the United ( States or Canadian Province, empowered to enact and enforce boiler code legislation. The Regulatory authority denotes a Federal Government Agency, such as the United States Nuclear Regulatory Commission, empowered to issue and enforce regulations concerning the design, construction and operation of nuclear power plants. i The failure to follow FSAR commitments with regard to ASME Code require-ments and the position of the Division of Project Management, Office of Nuclear Reactor Regulation has been stated in a reply letter to Boyce H. Grier, Director, Division of Reactor Inspection Programs and the appropriate section follows:

                    "It is our position that selective (partial) substitution of construction requirement from later code editions or addenda to a given component should not be permitted without appropriate justification and evaluation whicit demonstrates that any additional requirements or restrictions associated with the use of the later requirements are also satisfied.       This is especially true when the use of a part from a later code edition results in relaxation of the original construction requirements. The applicant's justification should also describe the reason for such substitution and evaluate any effects on the component or system integrity."

L 11

r o ( The Braidwood FSAR does not contain sufficient information to permit an evaluation, an amendment or reference to applicable ASME Code Cases number N242-1. Materials Certification Section III, Division 1, Class 1, 2, 3, MC and CS Construction, approved by Council April 10, 1980. The Commission has found this Code Case acceptable subject to those conditions specified in the Code Case and with the following condition, that the " applicant should identify in their Safety Analysis Report the components and supports for which th'e Code Case is being applied and should specify the respective paragraphs of the Code Case". The resident inspector has contacted the Director of Boiler Safety, a Division of the State of Illinois Fire Marshal, requesting confir-mation of correspondence or other forms of communication the licensee has submitted with regard to the use of the 1980 ASME Boiler and Pressure Vessel Code or the adoption of ASME Boiler and Pressure Vessel Code Case N-242-1. The Chief State Inspector and his staff reported the Licensee has had no contact with the State enforcement authority with regard to the above mentioned ASME Code change. The Office of Nuclear Regulatory Commission, (regulatory authority) and the Illinois Department of Nuclear Safety were also contacted with the same negative response as supplied by the Director of the Illinois Boiler Safety division. . The licensees statement accepting the 1980 ASME Code in lieu of the 1974 Summer 1975 edition on product specification for material purchasing, the ASME Materials Certification Code Case with the Nuclear Regulatory { Commission requirements, the requirement of 10 CFR 50.30, " Filing of applications for Licenses" which states in part: "each applicant for a license, including where appropriate, a construction permit, or amendment therefore, and each amendment of such application, and correspondence, reports or other written communication from the applicant...should be filed with the Director of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission and the requirements of 10 CFR 50.55(a) " Codes and Standards" paragraph a, b and d are obligations which the licensee has not addressed formally or informally to the NRC. The licensees statement accepting the 1980 ASME Boiler and Pressure Vessel Code in lieu of the 1974 Summer 1975 edition, which is a portion of the material purchasing specification, is also contrary to the above requirements. This item is considered an open item (456/84-08-08; 457/84-08-08) pending the licensee demonstration of supportive documentation which requested the acceptance of the 1980 ASME Boiler and Pressure Vessel Code for the purchasing of safety related piping and components.

7. Welding Records Review The inspector reviewed welding records, associated with the feedwater and component cooling water systems for unit one and two. The field fabrication process and data sheet was examined for completion by various craft individual, quality control and appropriate review L

12 L

P' ] C perscnnel. Weld rod issue slips assigned to each field weld were also examined for conformity with rod issue procedures. This review disclosed discrepancies between the dates when craft personnel accomplished their assigned tasks and when the hold points monitbring these installation tasks were signed by quality control personnel. The following examples were noted.

           .                        QC              QC            QC Pre-Weld           Pipe       Root Weld       Weld Rod Weld No.       Cleanliness        Alignment     Installed         Issued _

FW28 - FW10 11/30/83 1/9/84 2/6/84 1/19/84 (The root weld was completed by welder No. 764 on 1/19/84) FW28 - FW11 11/30/83 11/30/83 2/8/83 1/24/84 (The root weld was completed on 1/24/84) CC 1 FW23 9/26/77 9/26/77 9/26/77 9/23/77 (The root weld was completed by Welder No. 124 on 9/23/77) - CC 1 FW24 7/7/78 7/10/78 11/2/78 7/7/78 (The root weld was completed on.7/7/78) CC 1 FW 9 12/21/78 12/27/78 1/19/79 12/21/78 (The root weld was completed on 12/21/78)

       /      CC 1 FW13A       4/8/82          4/9/82          5/18/82       4/8/82

( (The root weld was completed on 4/8/82) CC 1 FW12A 6/23/78 6/26/78 11/12/78 6/23/78 (The root weld was completed between 6/23/78 and 6/28/78) FW25 - FW6 12/14/82 12/20/82 12/14/82 12/14/82 FW13 - FW7 No dates or signatures on form. Form was prepared on 4/14/83, QC hold points assigned on 4/20/83 and welding was accomplished between 6/25/81 and 8/21/81. FW13 - FW9 8/29/81 8/31/81 9/29/81 8/31/81 (The root weld was completed on 8/31/81) CC 1 FW8 11/28/78 11/29/78 12/6/78 11/28/78 (The root weld was completed on 11/28/78) FW15 - FW9 10/13/81 (18/27/81?) 2/22/82 10/13/81 (The root weld was completed between 10/31/81 and 10/26/81) This is considered an unresolved item (456/84-08-09; 457/84-08-09) pending licensee demonstration of Quality Assurance Records, And b 13 L

r .

 ?)
,o g C      appropriate evidence of proper weld inspections which comply with FSAR requirements and ASME Boiler and Pressure Vessel Code requirements.

No items of noncompliance were identified. '

8. Unresolved Items

_ Unresolved items are matters about which information is required in order .to ascertain whether they are acceptable items, items of non-compliance, or deviations. Unresolved items disclosed during this inspection are discussed in Paragraphs 3, 4, 6,and 7.

9. Exit Interview The inspector met with licensee representatives (denoted under Persons Contacted) during and at the conclusion of the inspection on December 16, 1983. The inspector summarized the scope and findings of the inspection. The licensee acknowledged the information.

O L 14}}

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@@ Line 195: / Line 195: @@
             . Gulf Nuclear Station, Units 1 and 2), ALAB-704, 16 NRC-1725, 1730 (1982); Long Island Lighting Company (Shoreham Nuclear Power Station, Unit 1), ALAB-743, 18 NRC 387, 400-401 (1983). -Moreover, Intervenors' tardiness in raising this t        issue further reflects poorly on their inclination to assist in developing a sound record.~*/     See Cincinnati Gas & Elec-tric Company (William H. Zimmer Nuclear Power Station, Unit
                    */    Not only were Intervenors late in filing their contention in relation to the special prehearing conference held on August 23, 1979, but they also failed to file in accordance with their representations to the Board. Three months after filing her appearance limited to QA issues, Ms.
-Whicher indicated in an August 6, 1984 letter to the Board that Intervenors planned to submit new contentions and that they believed this could be accomplished within ninety days.
+Whicher indicated in an {{letter dated|date=August 6, 1984|text=August 6, 1984 letter}} to the Board that Intervenors planned to submit new contentions and that they believed this could be accomplished within ninety days.
 In an October 17, ~1984 letter to the Board, Mr. Cassel again
            ~ indicated'that Intervenors would be preparing a construction
@@ Line 246: / Line 246: @@
         ' deficiencies in the area of electrical separation.        The CAT expressed concerns about the implementation of electrical separation criteria consistent with the standard of IEEE 384-1974. See Attachment B at II-9 -- II-10. As early as December 10, 1982, the Staff issued a notice of violation to Applicant for alleged non-compliance with this standard.
 See Braidwood Inspection Report 82-06 (Attachment E hereto) ,
-items 82-06-02A and 82-06-02B.       The issue was ref, erred to again by Region III in a May 23, 1983 letter.        (Attachment F hereto). --**/ The CAT itself confirms the existence of prior information when it states in the body of its report that
+items 82-06-02A and 82-06-02B.       The issue was ref, erred to again by Region III in a {{letter dated|date=May 23, 1983|text=May 23, 1983 letter}}.        (Attachment F hereto). --**/ The CAT itself confirms the existence of prior information when it states in the body of its report that
                */    The third item cited by Intervenors was the state-ment that "[n]umerous examples of generally poor [ mechanical]
 construction practices were observed."        A careful reading of the report reveals that this item was related to mechanical equipment maintenance and protection for installed and accepted hardware and that the item did not relate to any specific QA deficiency. Therefore, this item does not pro-vide a basis for a QA contention.
@@ Line 805: / Line 805: @@
 The red conductor of cable ISIO53-CIE, in motor operated valve ISIB802A, was excessively bent and not meeting minimum bend radius criteria. ICR-7870 was subsequently issued to document this condition.
 (8) Seepage of Oil From Okonite Cable NRC CAT inspectors observed any oily substance seeping from jackets of numerous installed and terminated cables manufactured by the Okonite Company. This condition was observed in both Class 1E and non-Class lE cables in various Class IE equipment throughout the facility (motor control centers, main control boards, control panels, motor operated valves, etc.). Information obtained from NRC Region III, CECO, and S&L revealed the following:
-In a letter dated October 4, 1982, including an attached engineering report (No. 364), the Okonite Company informed Ceco that, with reference to the identical condition identified at Byron Station, this seepage "will not affect the reliability or life of the cables."
+In a {{letter dated|date=October 4, 1982|text=letter dated October 4, 1982}}, including an attached engineering report (No. 364), the Okonite Company informed Ceco that, with reference to the identical condition identified at Byron Station, this seepage "will not affect the reliability or life of the cables."
 II-13
-i In a letter dated November 1, 1983 from Illinois Power Company (IPC) to NRC Region III (in accordance with 10 CFR 21), IPC stated that "...The effect of this oil on equipment connected to the cable is of concern. If oil that leaked from the divisional cable were to accumulate on essential components in Class 1E equipment, the possibility exists that misoperation of Class IE equipment could occur."
+i In a {{letter dated|date=November 1, 1983|text=letter dated November 1, 1983}} from Illinois Power Company (IPC) to NRC Region III (in accordance with 10 CFR 21), IPC stated that "...The effect of this oil on equipment connected to the cable is of concern. If oil that leaked from the divisional cable were to accumulate on essential components in Class 1E equipment, the possibility exists that misoperation of Class IE equipment could occur."
 On January 10, 1984, Information Notice 84-1 was issued by the NRC Office of Inspection and                                      )
 Enforcement to all nuclear facilities. This Information Notice references the above letter from IPC and states the concern that "... Leakage of oil from the cable at terminations may create a fire hazard, and degrade other electrical equipment." In addition, this Information Notice suggests that "... Addressees review the information for applicability to their facilities."
@@ Line 2,845: / Line 2,845: @@
 (Nuclear Steam Supply System) component supports were (emphasis added) accomplished in conformity with NF 4000 of ASME Section III, Subsection NF when in fact, the installation of the Unit 1 and Unit 2 Steam Generators, as of August 31, 1982, did not fully conform to NF 4000 in that Paragraphs NT 4711 " Bolting and Thread Engagement," NT 4723 " Precautions Before Bolting" and NT 4724 " Bolt Tension" were not met.
 As stated in Section II of this report, the design specifications did implement the FSAR commitment but the contractor did not fully implement this specification requirement. This matter has been referred to the NRC Headquarters Staff for resolution.
-In regard to the first item of discussion, Commonwealth Edison sub-sequently submitted a letter dated September 1,1982, outlining the action being taken to correct the deficiencies identified in the control of the erection of mechanical equipment at Braidwood. The NRC's under-standing of the four activities outline in the CECO September 1,1982, letter and two additional required actions were later documented in a NRC Region III Confirmatory Action Letter dated September 8, 1982.
+In regard to the first item of discussion, Commonwealth Edison sub-sequently submitted a {{letter dated|date=September 1, 1982|text=letter dated September 1,1982}}, outlining the action being taken to correct the deficiencies identified in the control of the erection of mechanical equipment at Braidwood. The NRC's under-standing of the four activities outline in the CECO {{letter dated|date=September 1, 1982|text=September 1,1982, letter}} and two additional required actions were later documented in a NRC Region III Confirmatory Action Letter dated September 8, 1982.
@@ Line 3,296: / Line 3,296: @@
 : 2. Licensee Action on Previously Identified Items (CLOSED) Noncompliance (456/80-04-02; 457/80-04-02): Two examples were identified where the commitments of Braidwood PSAR were inadequately translated into specification 3815. One was relative to coating of carbon steel components and the other was relative to spot welds on unistruts.
 The following documents were reviewed relative to spot welds on unistruts:
-()    a. Licensee's letter dated July 11, 1980 to Region III office with response to violation.
+()    a. Licensee's {{letter dated|date=July 11, 1980|text=letter dated July 11, 1980}} to Region III office with response to violation.
-: b. Licensee's letter dated July 18, 1980 to Region III.
+: b. Licensee's {{letter dated|date=July 18, 1980|text=letter dated July 18, 1980}} to Region III.
 : c. Sargent & Lundy (S&L) letter to Unistrut Corporation dated September 18, 1980.
-: d. Licensee's letter dated October 15, 1980 to Region III,
+: d. Licensee's {{letter dated|date=October 15, 1980|text=letter dated October 15, 1980}} to Region III,
-: e. Licensee's letter dated December 11, 1980 to Region III.
+: e. Licensee's {{letter dated|date=December 11, 1980|text=letter dated December 11, 1980}} to Region III.
-: f. Licensee's letter dated March 4, 1981 to Region III.
+: f. Licensee's {{letter dated|date=March 4, 1981|text=letter dated March 4, 1981}} to Region III.
-     S&L letter dated March 12, 1981 to Licensee.
+     S&L {{letter dated|date=March 12, 1981|text=letter dated March 12, 1981}} to Licensee.
-: h. Licensee's letter dated March 26, 1981 to Region III.
+: h. Licensee's {{letter dated|date=March 26, 1981|text=letter dated March 26, 1981}} to Region III.
 The documents state that after extensive literature research was performed to establish a corrosion rate for pregalvanized material for over a 40 year period, S&L conservatively assumed a 8.5 mils corrosion allowance for uncoated carbon steel in rural atmosphere.
 Unistrut, which provided the unistruts for supports, performed shear tests with allowance for 8.5 mils corrosion. Based on the results of these tests, it was determined that tha maximum load was less than the reduced allowable.
@@ Line 3,311: / Line 3,311: @@
 ( inside the containment, the licensee contracted Midway Industrial Coating to sandblast and paint the uncoated carbon steel components.
 Carbonzine 11 is used to coat material inside the containment and red lead is used in other buildings. Materials which have not been installed is sandblasted and coated in a coating shop located on site prior to installation. Review of Surveillance Report 2471 dated September 28, 1982 indicates that surveillances are being performed to ensure that uncoated carbon steel hanger material is being coated by Midway Industrial Coatings.
-(CLOSED) Noncompliance (456/80-12-02; 457/80-11-02): Two examples of failure to control purchased material were identified. One was that hanger support material supplied by Systems Control did not meet the drawing requirements. Specifically, the shop welds on H008, HS1, H071, and H135 were undersized. The second was the welds on the main control board panels did not meet Ak'S D1.1 Code requirements. Licensae letter dated December 4, 1980 states that the weld inspection program and repair program are expected to be complete by June 1981.
+(CLOSED) Noncompliance (456/80-12-02; 457/80-11-02): Two examples of failure to control purchased material were identified. One was that hanger support material supplied by Systems Control did not meet the drawing requirements. Specifically, the shop welds on H008, HS1, H071, and H135 were undersized. The second was the welds on the main control board panels did not meet Ak'S D1.1 Code requirements. Licensae {{letter dated|date=December 4, 1980|text=letter dated December 4, 1980}} states that the weld inspection program and repair program are expected to be complete by June 1981.
-For the hangers, NCR-250-R was initiated to identify that Systems Control, the vendor, did not follow drawing detail DV-120 en drawing 6/20E-0-3284 on all connections. The NCR was sent to S&L for reso-lution. S&L in letter dated July 6, 1981 to the licensee indicated they performed an analysis and determined that the as-built welds meet the minimum weld requirements. S&L requested the site to issue a Field Charge Request (FCR) so that the relevant drawings could be revised. FCR-L-6554 dated July 29, 1981 was initiated and sent to O S&L. This FCR was rejected and returned on April 9, 1982 for insuf-ficient information. The revised FCR was reissued on August 31, 1982 and was closed on October 22, 1981.
+For the hangers, NCR-250-R was initiated to identify that Systems Control, the vendor, did not follow drawing detail DV-120 en drawing 6/20E-0-3284 on all connections. The NCR was sent to S&L for reso-lution. S&L in {{letter dated|date=July 6, 1981|text=letter dated July 6, 1981}} to the licensee indicated they performed an analysis and determined that the as-built welds meet the minimum weld requirements. S&L requested the site to issue a Field Charge Request (FCR) so that the relevant drawings could be revised. FCR-L-6554 dated July 29, 1981 was initiated and sent to O S&L. This FCR was rejected and returned on April 9, 1982 for insuf-ficient information. The revised FCR was reissued on August 31, 1982 and was closed on October 22, 1981.
 Relative to the main control board panels, a reinspection of the welds was performed.
 Sargent & Lundy engineers reviewed the results of the inspection on the control board panel welds and documented their findings in weld inspection report dated June 30, 1981. A typical control panel was marked up with the various weld deficiencies. A. list of weld repairs was then prepared for each panel. Licensee authorized LK Comstock to initiate weld repairs on October 27, 1981. The weld repairs have been complete on panels identified .s 1PM11J, 12J, 01J, 04J, IDC10J, 1DC11J, OPM01J, and OPM02J. The repaired welds appear acceptable.
@@ Line 3,416: / Line 3,416: @@
    ' .,..  *[gf                        oLEN ELLYN, ILLINotS 60137 9 *.%
 MAY 2 31983 Docket No. 50-456 Commonwealth Edison Company ATTN:     Mr. Cordell Reed Vice President Post Office Box 767 Chicago, Illinois 60690 Gentlemen:
-On April 1, 1983, our Regional Office received your letter dated March 31, 1983 stating your position on items of noncompliance which we brought to your attention in Inspection Report No. 50-456/82-06 forwarded by our letter dated March 8, 1983. We reviewed your response to the items of noncompliance and found Itams 1.a.3 and 4.a to be incomplete by our understanding. We subsequently requested a management meeting to discuss and clarify these issues for the purpose of reaching a mutually acceptable understanding of the issues. On May 10, 1983, Mr. W. S. Little and other members of this office met with Mr. J. T. Westermeier and members of your staff to discuss C:           this matter.
+On April 1, 1983, our Regional Office received your {{letter dated|date=March 31, 1983|text=letter dated March 31, 1983}} stating your position on items of noncompliance which we brought to your attention in Inspection Report No. 50-456/82-06 forwarded by our {{letter dated|date=March 8, 1983|text=letter dated March 8, 1983}}. We reviewed your response to the items of noncompliance and found Itams 1.a.3 and 4.a to be incomplete by our understanding. We subsequently requested a management meeting to discuss and clarify these issues for the purpose of reaching a mutually acceptable understanding of the issues. On May 10, 1983, Mr. W. S. Little and other members of this office met with Mr. J. T. Westermeier and members of your staff to discuss C:           this matter.
 As a result of this meeting Region III reached the following conclusions:
 : 1. With respect to Item 1.a.3 concerning the separation of a Class 1E cable with a non-class 1E tray, we take exception to your position, and maintain that this is an item of noncompliance. Your interpreta-tion that no standard addressed the separation of raceway and cables in air, does not appear consistent with the requirements of IEEE 384.

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