ML20092N491

Summary of Direct Testimony of Jo Binder on Issues 5 & 6 Re Cable Overtensioning,As Limited by ASLB 840608 Order.Related Correspondence

ML20092N491
Person / Time
Site:	Byron
Issue date:	06/29/1984
From:	Binder J COMMONWEALTH EDISON CO.
To:
Shared Package
ML20092N488	List: ML20092N487 ML20092N491 ML20092N497
References
NUDOCS 8407030203
Download: ML20092N491 (192)

Text

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Commonwealth Edison Company June 29, 1984

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y r g4g UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DC TEg ATOMIC SAFETY AND LICENSING BOARD a

'31 R -2 P2 :25 '

i In the Matter of ) Docket Nos..STN 50-454 OL

) STN 50-455 OL i COMMONWEALTH EDISON COMPANY )

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'(Bryon Nuclear Power Station, ) -

Units 1 and 2) )

SUMMARY

OF DIRECT TESTIMONY OF JAMES O. BINDER ON ISSUES 5 AND 6 (CABLE OVERTENSIONING) , AS LIMITED BY THE LICENSING BOARD'S ORDER OF JUNE 8, 1984 I. James O.' Binder of Commonwealth Edison Company is the Project Electrical Supervisor at Byron Station.

II. Cable overtensioning concerns the amount of tension wh2ch is applied to electrical cable when it is pulled through conduit. If the applied pulling tension causes certain criteria, established by the cable manufac-  ;

turer, to be exceeded, a cable could be rendered unable to perform its intended function.

III. The NBC has idtutified two items of noncompliance and two cvher items with respect to potential cable over-tenst2ning, all of which have been satisfactorily resoaved by Commonwealth Edison.

A. The NRC identified as an unresolved item the ,

fact that !!atfield Electric Company, which is responsible for cable installation at Byron Station, used an installation procedure which 8407030203 840629 PDR A E K OS000454 T PDR

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did not address how it would be verified that the allowable cable pulling tension had not been exceeded when small cables or instrument cables were pulled.

B. This item was resolved by revising the cable pulling procedure to address the required pre-cautions to be taken when small cables or in-strument cables are pulled.

C. The first item of noncompliance identified that the Hatfield Electric installation procedure did not address the requirements to calculate electrical cable sidewall pressure and did not provide instructions regarding electrical cable rework.

D. This item of noncompliance was resolved by re-vising the Hatfield Electric cable installation procedure to address the subjects identified by the NRC. In addition, Sargent & Lundy performed an analysis of all safety-related cables installed in conduit prior to the implementation of the p revised procedure to determine their accept-ability. All of these cables were found to be acceptable, ie., they would perform their in-tended functions.

E. As part of an investigation of allegations con-cerning IIatfield Electric, the NRC identified as

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.an open item the Commonwealth Edison Nonconform-ance Reports (NCRs) which had been written con-cerning potential cable overtensioning.

F. This open item'was' resolved by the analysis men-tioned,in'II. D., above, and by the satisfactory T

dispositioning of the Commonwealth Edison NCRs

pertaining to potential cable overtensioning.

f G. 1The second item of noncompliance identified that one Hatfield-Electric Discrepancy Report ( D R) ,,

which had been written concerning potential cable overtensioning, had received an inadequate res-ponse. This had resulted~in 12 safety-related

-cables whose. quality was indeterminate, in that one more of those cables had been overtensioned during'the attempted. pull-back of another cable.

H. That item'of' noncompliance was resolved by re-placing 7all 13 safety-related cables involved, by reviewing all Hatfield Electric'DRs.for cables which had been pulled out of conduit, and by taking steps to prevent the recurrence of this type of incident.

IV. Based upon (1) the review of safety-related_ cables installed'in conduit prior to the implementation of the-revised cable pulling procedure in December, 1982, and

-(2) the ' revised cable pulling procedure used by Hatfield

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su . + -IV-Electric since~ December, 1982, all of the safety-

related: cables installed in conduit at Byron Station '

are; acceptable. Their ability to perform their in-

' tended functions has not been impaired by overten-

.<. ' sioning.

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February, 1984. I am licensed as a professional engineer in the State of Illinois.

Q-5. Please describe your employment experience.

A-5. I have worked for Commonwealth Edison Company since June, 1974. My first position was as a Field Engineer

~in the Division Operational Analysis Department. In October, 1978, I was assigned to work at the Byron Station,_and I have worked there continuously to this date. My first position at Byron Station was as a General Engineer in the System Operational Analysis Department; I was subsequently promoted to Principal Engineer. In December, 1980, I transferred to the Project Construction Department. I became Project Electrical Supervisor in June, 1981, and still hold

-that-position today.

Q-6. Please describe your duties as Project Electrical Supervisor at Byron Station.

A-6. My duties include managing the activities associated with the electrical ' construction of the Byron Station,

' including supervision of the Project Costruction elec-trical department on site and contract administration concerning the electrical contractor, Hatfield Elec-tric-Company.

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e Q-7. Please describe the scope of your testimony.

A-7. My testimony is in response to Issues 5 and 6, relating to potential cable overtensioning, or overstressing, at Byron Station, as those issues have been limited by the

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' Licensing Board's Order of June 8, 1984. My testimony-describes the history of-the question of cable over-tensioning at' Byron Station and sets forth the response which Commonwealth Edison has made to certain items of-noncompliance and open items concerning this matter which the'NRC identified during_various inspections.

The attachments to my testimony consist of certain NRC inspection reports and certain other documents which pertain to this matter. I am familiar with the con-tents of all of these attachments to the extent that they pertain to the cable overtensioning matter.

Q-8. Please describe the concept of cable overtensioning.

A-8. The concept of cable overtensioning concerns-the amount of tension which is-applied to electrical cable when it is pulled;through conduit. When cable is installed in conduit it is pulled, either by hand or by machine, and a certain amount of tension is exerted on the cable in the_ process. Cable' tension criteria have been estab-lished to give reasonable assurance that the cable's published rating will not be impaired during installa-tion. These' criteria address both maximum allowable

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tensile strength and maximum allowable sidewall pres-sure. If the maximum allowable tensile strength of-the cable were exceeded, thinning of the conductor (s) or breakage could' occur. If the applied pulling tension

. caused'the maximum allowable sidewall pressure to be exceeded, the. insulation surrounding the conductor (s) could be damaged. Either of these events could render a cable unable to perform its intended function.

-Q-9. Who establishes the criteria defining maximum allowable cable pulling tension for a. cable?

A-9. The cable manufacturers establish these criteria for their cables.

Q-10. Who is responsible for cable installation at Byron Station?

.A-10. The electrical contractor, Hatfield Electric Company, is responsible for cable installation at Byron Station.

0-11. How does the electrical contractor know the amount of tension which is exerted on a cable during a cable pull?

A-ll. The electrical contractor monitors the tension exerted on a cable during a cable pull using an instrument known as a dynamometer.

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-Q-12. How are instructions given to the electrical con-tractor regarding the allowable cable pulling tensions for cables installed in conduit?

A-12. The architect-engineer, Sargent & Lundy, utilizing cable. pulling information supplied by each cable manu- s facturer, determines the allowable pulling tensions for each cable type.

This information appears on the

. installation drawings issued to the contractor by Sargent & Lundy. In addition, the contractor has develope'd a procedure, accepted by the architect-engineer, which describes the steps to be taken re-garding the calculation, monitoring and recording of cable tensions for cable installation.

Q-13. Please describe how'the question of possible cable overtensioning first arose.

A-13. During an inspection conducted in September, 1981, the NRC' inspector observed that the Hatfield Electric procedure governing class lE cable installation did not address how it would be verified that the allowable cable pulling tension had not been exceeded when small cables or instrument cables were pulled. See Attach-ment A (Inspection Report . 50-454/81-16; 50-455/81-12)

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at pages A-7 to A-8.

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Q-14. What action-was'taken in response to this observation?.

A-14. . In -response to this observation, the Hatfield Electric cable pull'ing procedure was revised to address the required precautions'to be taken when small cables or instrument cables are pulled. See Attachment B (In-p.

spection~ Report 50-454/83-16) at page B-6.

Q-i5. Please describe the next event which occurred. concern-

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ing possible cable overtensioning.

A-15. An item of noncompliance (82-05-09c, 82-04-09c)

.related to the subject of cable overtensioning was identified during the NRC construction team inspection conducted at Byron Station in the Spring of 1982. This inspection found that Hatfield Electric's cable in-stallation procedure did not address the requirements to calculate electrical cable sidewall pressure prior to pulling cable and did not provide instructions regarding electrical cable-rework. See \ttachment C

.(Inspection Report 50-454/82-05; 50-455/82-04) at pages C-70 to C-71.

0-16. Please describe how this item of noncompliance was resolved.

A-16. The resolution of this item involved two phases.

First, the Hatfield Electric procedure regarding cable installation was revised to address both the calcu-h .

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+ i lation of the allowable pulling tension considering sidewall pressure' limitations and instructions re-  !

garding electrical cable rework. As explained in a l

letter from Commonwealth Edison to the NRC dated November 5, 1982 (Attachment D) , Sargent & Lundy specified allowable pulling tensions for cable in conduit which considered both the tensile strength of the conductors and the allowable sidewall pressure.

Methods were also established to determine the allow-  ;

able pulling tension for multiple cable pulls in con-duit and for cable pulls in conduit with non-standard l i

radius bends. In addition, the Hatfield Electric l

procedure was revised to implement these instructions for new cable-installation as well as for cable rework.

This revision also required inspectors to monitor (with a dynamometer) and record the maximum tension reached during all cable pulls. The revised. procedure was implemented in December, 1982. See Attachment D at pages D-2 to D-3. The NRC found the revised procedure i to be satisfactory and closed this portion of the item i of noncompliance in its May, 1983 Inspection Report.

See Attachment B at page B-6.

Q-17. Please describe the second phase of the resolution of l this item of noncompliance.

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A-17. As stated above, the revised Hatfield Electric pro-cedure regarding cable pulling was implemented in December, 1982. In order to verify that the sidewall -

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. pressure was not exceeded for cables installed prior to [

the date of the revised procedure, Commonwealth Edison [

committed to review the cable pull reports for pre-i viously installed cables against the current critoria. [

If it were found that the allowable sidewall pressure l had been exceeded, the Company committed to take appro- l E

priate corrective action with the advice of the cablo j r

manufacturer. Those actions would ensure that all cables, regardless of when they were installed, would [

perform their intended functions. See Attachment D at ,

page D-3. This review was carried out by Sargent &

Lundy, which performed an analysis of all safety-related cablos installed in conduit prior to Decembor, [

t 1992. The scopo of that analysis, the methodology l f

used, the results of the analysis and the conclusions [

drawn from it are set forth in detail in the testimony of Bobby G. Treece of Sargent & Lundy. Based upon that f analysis, it was concluded that all of the safety-related cables installed in conduit prior to the im-  !

i plomontation of the revised critoria in December,1982,  !

i were acceptablo. The NRC inspectors reviewed Sargent & f l Lundy's analysis and concluded that thoro was a reason-  ;

able assurance that the safety-rolated cables that wore ,

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the subject of the analysis would perform their in- l tended functions. See Attachment E (Inspection Report 50-454/84-27; 50-455/84-19) at pagos E-14 to 3-15.

l Q-18. Picaso describo the next event relating to the possiblo l

overtonsioning of cables.

A-18. As a result of allegations concerning the construction activitics of the !!atfield Electric Company, the NRC conducted a special inspection betwoon August 2, 1983, and January 18, 1984. Ono allogation which was in-vostigated assorted that cablos had boon overstressed when pulled, even to the point of breaking the cablo.

The results of the NRC's investigation are not forth in Inspection Report 50-454/84-02: 50-455/84-02, which is Attachment F to my testimony. The NRC intarviews related to that allegation revealed that individuals know of only one instanco where a cablo had boon overstressed to the breaking point; the persons in-torviewed stated that that cablo had boon replaced and the occurrence had boon documented. The inspectors also reviewed the Commonwoalth Edison Nonconformanco Roport (NCR) log and found that at least 25 NCRs con-corning potential ovortonsioning of cablos had boon written. Tho NRC datormined that the allegation con-stituted an open item (84-02-03) pending the vorifi-cation of correctivo action on: 1) cables installed 9

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prior to'the implementation of the revised cable pulling procedure in December,1982, and 2) cables identified on NCRs and Discrepancy Reports (DRs) as .

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potentially overtensioned. See Attachment F at pago l F-17.

Q-19. Please describe the stcps which were taken to close this item.

A-19. My Answer number 17, above, describes tho analysis

.which was undertaken by Sargent & Lundy in ordor to assure that cables installed prior to the implomon-tation of the revised pulling proceduro would perform their intended functions. That analysis was reviewod and accepted by the NRC, and that part of tho itom was closed, in Inspection Report 50-454/84-27; 50-455/84-19.

See Attachment E at pages C-14 to E-15.

In order to close the remaining portion of this item, the NRC inspector reviewed the Commonwealth Edison NCRs which documented potential cable ovor-tensioning. This review is documented in Innpoetion Report 50-454/84-09, which is Attachmont a to my testimony. Thoro were a total of 19 NCan on this subject written by Commonwealth Edison. Tho NRC inspector also reviewod NCRs preparod by flatflold Electric regarding the potontial overtonnioning of electrical cables. Soo Attachmont 0 at pagon 0-6 to j

G-12. Becauso certain of the Commonwoalth Edison NCRs woro not yet closed as of the dato of that inopoction, this item was considorod unrosolved (84-09-01) . During the inspection referenced in 50-454/84-27: 50-455/84-19 (Attachment E), thu inspectors reviewed the dispositions of the romaining Commonwealth Edison NCRs portaining to potential cable overtensioning and found thom to be acceptable. The NRC then closed this itom. Soo Attachmont E at pago E-15.

Q-20. Please describo tho disposition of thono Commonwoalth Edison NCRs portaining to potential cable overtonnioning.

A-20. Many of the cablos woro found to bo .ecoptable as insta11od. Some of theso woro datorminod to bo accopt-ablo by an analysis performed by Sargent & Lundy, somo woro datormined to be acceptablo by an analysin par-formed by the cablo manufacturor, and somo woro dator-mined to be acceptablo by tasting, as recommanded by the cablo manufacturer. For the romaining cablon, it was datormined that the maximum allowable pulling tension had in fact boon exceodod and the cablon woro I thereforo unacceptablo.

Q-21. What was the enginouring dinposition of the cablon 1 which woro datormined to bo unacceptablo?

A-21. Tho ongincoring dinponition wan to replaco the cablon, 1

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-Q-22. Were those cables replaced? 1 A-22. Yas.

Q-23. Did . the NRC identify an item of noncompliance in regard to cable overtensioning during the inspection documented in Inspection Report 50-454/84-09; 50-455/84-07 (Attachment G) ?

A'-23. Yes. An item'of noncompliance is described at pages G-12 to G-13 of that Inspection Report.

10-24. Please' describe this item of noncompliance.

- A-24. During a review of 1000 discrepancy reports prepared by Hatfield Electric, che NRC inspector identified one report, DR 3382, which,-after interviewing the Hatfield Electric. cable pulling and QC personnel involved, was determined ~to have been inadequately dispositioned. DR.

3'382 is AttachmentLH to my testimony. The DR had been prepared to-document the fact that,,while attempting to remove a cable from a conduit which contained other cables, the remaining 12 cables were-subjected to 500 4

. pounds total (tension. .As the~ distribution of the 500 pounds of tension among the 12' remaining cables could

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u not be _ verified, one or more of the cables may have

~ been subjected to the total 500 pounds of tension exert d during the pull,-: and therefore beer overten-sioned. Because the Hatfiefd Electric QC inspector's written description of the problem was unclear in that k A

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it failed to specifically state that only one of the 13 cables was being pulled on, the Hatfield Electric engineer who evaluated the DR mistakenly assumed that

'the 500 pounds of-tension had been applied to all 13 cables in the conduit. The engineer then calculated the allowable pulling tension for the 12 remaining cables to be 557 pounds. Because the 500 pounds of tension which had been applied during the pull was less Ethan the 557 pounds of allowable tension which had been calculated, the engineer concluded that the 12 re-maining cables were acceptable as installed. The DR was returned to QC and-was closed based on the engi-neer's response that.the cables had not been over-tensioned. .The'NRC inspector concluded that the failure to provide an adequate response to DR 3382 had resulted in 12 safety-related cables whose quality was indeter-

minate, in that _ one' 'or more' of .those cables was over-stressed during the attempted' pull-back of another

-cable. This was identified as' item of noncompliance 84-09-02.

Q-25. Did'you review-the circumstances surrounding DR 3382 to determine the cause of the inadequate-disposition?

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.A-25. Yes.

Q-26. Please describe the-results of your review.

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-A-26. After discussions with the NRC inspector and the Hatfield El.ectric engineer who evaluated the DR, I concluded ~that DR 3382 had been inadequately disposi-tioned for the following reasons:

1) The QC inspector who wrote the DR failed to pro-vide an accurate written description of the problem;

2) Due to the inaccurate description, the engineer's evaluation did not address the actual problem;

3) The verification of the resolution of DR 3382 was not completed by the same QC inspector who had witnessed the problem and written the DR. This QC Inspector determined that the engineering resolution adequately addressed the problem as' described. The DR was therefore closed.

Q-27. Was there any evidence that the cable overtensioning which occurred was not properly reported in accordance with

- written procedures?

A-27. No. The proper reporting procedures were followed.

It'was due to an inaccurate description of the problem on the DR that inadequate corrective action was taken.

Q-28. Please describe the resolution of item of noncompli-ance 84-09-02.

A-28. The resolution of this item of noncompliance comprised three parts. First, Hatfield Electric prepared NCR 841 to~ document the potentially overtensioned cables identified

'in item of noncompliance 84-09-02. I dispositioned

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t this NCR by requiring that all 13 cables be replaced. l This action was taken. Second, Hatfield Electric DRs

.for all.other cables which were pulled out of conduit j

.were reviewed to confirm that the inaccurate descrip-tion associated with DR 3382 was an isolated incident.

See Attachment I (Letter from Commonwealth Edison to  !

the NRC dated April 25, 1984, enclosing Response to  ;

Notice of Violation) . Third, Commonwealth Edison took steps.to_ prevent recurrence of this type of incident, ,

as outlined in my February 2, 1984 letter to Hatfield  !

Electric (Attachment J to.my testimony). This letter i'

sets forth the criteria for determining the allowable

-pulling tension when cable is to be pulled out of I conduit.- The'use of these criteria will assure that i

.any cables-remaining in a conduit will not be over-

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tensioned when a cable or cables are pulled out. This

. letter also re-emphasizes that cables should never be pulled.unless the cable pulling crew and the'QC.per-sonnel know what the allowable pulling tension is.for the-cable pull to be performed. Finally, this latter stressesLthat when a problem is identified, it is

.important-that the deficiency be clearly described so that it can be properly evaluated and dispositioned.

O c ~See Attachment J at page J-2. The NRC accepted the Company's resolution of this matter and closed this item in Inspection Report- 50-454/84-27, 50-455/84-19.

See Attachment E at page E-15.

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~16-Q-29. What is your opinion of the condition of the safety-related cables installed in conduit at Byron Station with respect to potential cable overtensicning?

A-29. In ny opinion, the safety-related cables installed in conduit at Byron Station are acceptable. Their ability to perform their intended functions has not been im-paired by overtensioning.

Q-30. Please describe the basis for that opinion.

A-30. For all safety-related cables installed in conduit before December, 1982, my opinion is substantiated by the analysis which was performed by Sargent & Lundy.

This analysis is described in Answer 17, above, and in the testimony of Mr. Treece of Sargent & Lundy, For all safety-related cables installed after. December, 1982, my opinion is based upon the revised cable pulling procedure used by Hatfield Electric. I.believe that that procedure adequately addresses cable in-stallation activities with respect to cable pulling tensions. ' Finally, I believe that all Commonwealth Edison NCRs and all Hatfield Electric DRs and NCRs which have been written addressing potential cable overtensioning problems have been properly reviewed and

-dispositioned.

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• n re Binder g 4 .

o g UNITED $TATES Attachment A i *-8 o NUCLEAR REGULATORY COMMISSION

$ E REGION 111 4 0 799 ROOSEVELT ROAD 4

g*****,o[ s GLEN ELLYN. lLLINOIS 60137 0C 21001 Docket'No. 50-454 Docket No. 50-455 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 Mr. R. S. Love of this office on September 22-25, 1981,- of activities at Byron Generating Statiqrt,_.JIrti,ts 1 and 2. authorized by NRC Construction Permits No. CPPR-130 and No. CPPR-131 and to the discussion of our findings with Mr. R. Tuetken, Assistant Project Superintendent 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 in-terviews with personnel.

During this inspection, certain__of your activities __ appeared to be in non-

,cm pliance with NRC__ requirements, as specified in enclosed Appendix A. A written response, submitted under oath or affirmation, 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 the enclosures contain any information that you or your contractors believe to be exempt from dis-closure under 10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by telephone within seven (7) 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. Section 2.790(b)(1) requires that any such application must be accompanied by an affidavit executed by the owner of the information which identifies the docwnent 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 A-1

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- 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, C.$. kA '- -

C. E. Norelius, Director Division of Engineering and Technical Inspection

Enclosures:

1. Appendix A, Notice of Violation

- 2. IE Inspection Reports No. 50-454/81-16 and No. 50-455/81-12 cc w/encls:

Louis 0. De1 George

~ Director of Nuclear Licensing Gunner Sorensen, Site Proj ect . Superintendent V. I. Schlosser, Project Manager

- R. E. Querio, Station Superintendent DMB/ Document Contorl Desk (RIDS)

Mary Jo Murray, Office of Assistant Attorney General Myron M. Cherry.

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Appendix A NOTICE OF VIOLATION .

Commonwealth Edison Company Docket No. 50-454 Docket No. 50-455 As a result of the inspection conducted on September 22-25, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violation was identified:

10 CFR 50, Appendix B, Criterion XVI, states in part, " Measures shall be established to assure that conditions adverse to quality...are promptly identified and corrected."

-Commonwealth Edison Company Topical Report No. CE 1-A, Revision 9, Section 16, states in part, "A corrective action system will be used to

-assure that such items...which_are adverse to quality and might affect the safe operation of a nuclear generating station are promptly identified and corrected."

Contrary to the above, the licensee had not taken the necessary actions to assure that an identified item of noncompliance, concerning the separation criteria between safety-related and non-safety-related cables, was promptly corrected. This is exemplified by the fact that the appropriate Hatfield procedure addressed in the licensee's correspondence, was not being imple-

-mented as of September 24, 1981. The licensee committed to have the procedure implemented by_ June 1, 1981. (Reference CECO letter dated May 7,

'1981, from Cordell-Reed to James.G. Keppler.)

This is a Severity Level V violation (Supplement II).

- Pursuant to the provisions of 10 CFR 2.201, you are required to submit to thin 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 achieved; (2) corrective action to be taken to -avoid further noncompliance;'and (3) the date when full compliance will be achieved. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation. Consideration may be given to extending your response time

- for good cause shown.

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a..t w~ > .kh Dated C. E. Norelius, Director Division of Engineering and Technical Inspection T

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i U.S. NUCLEAR REGULATORY COMMISSION ,

OFFICE OF INSPECTION AND ENFORCEMENT REGION III ,

Reports No. 50-454/81-16; 50-455/81-12 Docket Nos. 50-454; 50-455 Licenses No. CPPR-130; CPPR-131 Licensee: Commonwealth Edison Company  !

Post Office Box 767 '

Chicago, IL 60690 Facility Name: Byron Generating Station, Units 1 and 2 Inspection At: Byron Site, Byron, IL Inspection Conducted: September 22-25, 1981

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Inspector: .

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. Love ic/21,/B1 Approved By: . . Hawkins, Acting Chief IDfti/fbl i Plant Systems Section '/

Inspection Summary Inspection on September 22-25, 1981 (Reports No. 50-454/81-16; 50-455/81-12)

Areas Inspected: Follow-up on previously identified inspection findings; review of electrical procedures and records. This inspection involved a

-total of 30 inspector-hours onsite by one NRC inspector. -

Results: Of the areas inspected, one apparent item of noncompliance was identified (Criterion XVI - failure to promptly identify and correct items of nonconformance - Paragraph 2.a).

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, DETAILS Persons Contacted  ;

r Commonwealth Edison Company G. Sorensen, Project Superintendent

• J. O. Binder, Project Electrical Superzisor

• R. B. Klingler, Quality Assurance Supervisor

• M. A. Standish, Quality Assurance Superintendent ,

• R.~Tuetken, Assistant Project Superintendent The inspector also contacted and interviewed other licensee and contractor personnel during this reporting period.

• Denotes those present at the exit interview. <

1. Licensee Action on Previous Inspection Findings

a. (0 pen) Noncompliance (50-454/80-09-01; 50-455/80-08-01): CECO

'did not ensure that Sargent and Lundy (S&L) adequately translated the requirements of the Byron PSAR and S&L Specifications 2831 i into S&L Specifications 2815 in'that corrosion protection was not specified for the exposed carbon steel material and exposed spot welds used in the installation of seismic Category 1 electrical cable tray hanger supports. Due to the unavailability of personnel, the inspector was unable to obtain the answers to the questions contained in NRC letter to CECO dated August 14, 1981.

b. (0 pen) Noncompliance (50-454/80-12-01; 50-455/80-11-01): CECO did not ensure that Sargent and Lundy adequately translated the requirements of 10 CFR 50, Appendix A, Criterions IV and V, into the design of the cooling water piping for Emergency Diesel Generator IB in that the cooling water lines for D/G 1B pass ,

through the. room housing Unit 1A. As indicated in NRC letter to CECO, dated November 18, 1980, this matter has been referred to our headquarters staff for resolution. We will advise you of their findings.

c. (Closed) Noncompliance (50-454/80-15-01; 50-455/81-14-01):

Activities affecting quality were not prescribed by instructions,

. procedures, or drawings in that: (1) Requirements were not estab-lished for the hardware used to assemble the seismic Category 1

. battery racks to be capable of withstanding acidic atmosphere; (2) Documented instructions were not established to conduct timely inspections; (3) Documented instructions were not established to control instruments which were determined to be defective during bench testing.

(1) Station Procedure BHS 8.2.3.2.C-1 (125V Battery Bank and Charger Operability, Revisio.n 0, dated August 1981) includes an inspection point to verify that the battery rack and battery rack hardware is free of corrosion.

A-5

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

F

. (2) Procedure QC-3, Paragraph 9.1, was revised to incorporate an " Inspection Request" form to ensure timely inspection.

Most of the inspection requests were honored the same day they were prepared. ,

~ (3) The licensee has taken and completed action to control (tag) the defective instruments and revise the procedure.

d. (0 pen) Noncompliance (50/454/80-25-09; 50-455/80-23-05): Safety related cables were bundled with non-safety related cables in the lower cable spreading room in violation of IEEE 384 and FSAR com-mitments. Procedure 10, " Class IE Cable Installation" was revised to incorporate a 12" separation requirement. This procedure was implemented on September 24, 1981. This item will remain open until implementation can be verified.

e. (0 pen) Noncompliance (50-454/80-25-13): Welds on cable pan bent plate stiffeners do not conform to Sargent and Lundy (S&L) Standard STD-EB-701. Pittsburgh Testing Laboratories made sketches of a pre-determined number of stiffener plate welds, showing weld size, crac ks, lack of fusion, craters, undercut, porosity, weld profile and underrun. This information was forwarded to S&L for evaluation.

This item will remain open until the results of S&L's evaluation can be reviewed,

f. (Closed) Unresolved item (50-454/80-25-15; 50-455/80-23-06): Incom-plete/ inaccurate documentation received from Okonite Cable Company for SKV power cable. The inspector reviewed the documentation for the subject cable. All required documentation is on-site and the Quality Assurance Traceability Schematic has been corrected to show the proper QC Length Number.

g. (Closed) Noncompliance (50-454/80-25-16): The minimum separation criteria for redundant impulse sensing lines as specified in the Byron PSAR was not translated into instructions, procedures, specifications, and drawings. Engineering Change Notice Number 1958, dated January 14, 1981, was issued to incorporate separation criteria and color coding requirements for all instrument sensing lines into Specifications F-2906 and F/L-2739.

2. Review of Electrical Procedures and Records

a. In accordance with Ccmmonwealth Edison's (CECO) commitment to the NRC (May 7, 1981 letter from Cordell Reed to James G. Keppler, Paragraph 2.a), Procedure Number 10, " Class 1E Cable Installation",

Revision 10, Issue 2, was prepared to incorporate the 12 inch separation requirement between Class IE and non-Class IE cables in free-air. This procedure was approved with conments by Sargent and Lundy (S&L) of August 7,1981 and transmitted to Hatfield Electric by CECO on August 13, 1981.

A-6 L

While attempting to close Noncompliance 50-454/80-25-09; 50-455/80-23-05, which concerns the separation of Class 1E and non-Class IE cable in free air, it was observed that the separa-tion problems identified on a previous inspection had been corrected, but there are still separation problems in the lower cable spreading room.

During discussions with the Hatfield Quality Assurance Manager on September 24, 1981 (AM), it was learned that Hatfield chose not to implement Revision 10, Issue 2 but were implementing Revision 9, Issue 1, dated February 3, 1981.

The inspector queried the licensee as to when they planned to honor their commitment of May 7, 1981.

On September 24, 1981 (PM), CECO issued a letter to Hatfield directing them to implement Procedure Number 10, Class IE Cable Installation, Revision 10, Issue 2, dated June 8, 1981 with S&L comments immediately.

The Region III inspector informed the licensee of the failure to assure that conditions adverse to quality are promptly identified and corrected is an item of noncompliance in accordance with 10 CFR 50, Appendix B, Criterion XVI as described in Appendix A of the report transmittal letter. (50-454/81-16-01; 50-455/81-12-01)

b. During a tour of the Unit I containment, it was observed that the cable pan markings on 1396E-C2E and 1396R-P2E exceeded the 15 foot maximum spacing requirements of S&L drawing 6E-0-3390, Hatfield Procedure 9E, " Class 1 Cable Pan Identification," Revision 6, Issue 1, dated January 23, 1981 and IEEE 384-1974 as committed to in Byron FSAR, Paragraph 8.3.1.4.2.1.

During discussions with the Hatfield Quality Assurance Manager on September 24, 1981, it was learned that Hatfield chose not to implement Procedure 9E after it had been reviewed and accepted by S&L on January 26, 1981. The licensee informed the inspector that Hatfield's failure to implement Procedure 9E had been identified by CECO during an audit of Hatfield on September 9-10, 1981 and were awaiting their response. Pending a review of the response to the subject audit, this matter is unresolved. (50-454/81-16-02; 50-455/81-12-02)

c. The Region III inspector observed that Hatfield Procedure 10, Revision 10, Issue 2 (Class IE Cable Installation) did not address how the licensee was going to verify that the maximum cable pulling tension had not been exceeded when small cables and/or instrumentation cables were pulled. (i.e., cables that have a maximum pulling tension that is less than the force that can'be exerted on a cable by one person) Tests performed on other projects indicate this force to be approximately 125 pounds.

A-7

E .

Pending a detailed review of cable pulling records to verify

• ' that maximum cable pulling tensions have not been exceeded, this item is unresolved. (50-454/81-16-03; 50-455/81-12-03)

d. During an inspection of the main control room, it was observed that the safety related switches, instruments, recorders, etc. were not distinctively identified as being in the protection system as required by Paragraph 4.22 of IEEE-279. Pending a review of the technical specifications, FSAR requirements, etc., this

. item is unresolved. (50-454/81-16-04; 50-455/81-12-04)

e. During an inspection of Unit I containment, it was observed that the horizontal separation between Class 1E and non-Class IE cable trays was approximately six inches. Trays involved were 1396E-C2E and 1396CC-C2B and 1396-P2E and 1396B-P2B. Para-graph 8.3.1.4.2.2 of the Byron FSAR discusses minimum raceway separation criteria for:

(1) Minimum spacing for Engineering Safety Features (ESF) ,

Divisions and Reactor Trip System (RTS) Channels.

(2) Separation for Non-Safety-Related Cable Trays.

The FSAR does not discuss the separation requirements for Safety-Related (ESF & RTS) Cable Trays and Non-Safety-Related Cable Trays.

Sargent and Lundy (S&L) drawings 6E-1-4027A, B, and C, Revision A, dated May 16, 1977 have interpreted the "Separt. tion Requirements for Non-Safety-Related Cable Trays" to encompass the separation require-ments between Safety Related and Non-Safety-Related Cable Trays.

This item is unresolved pending a review of S&L calculations for all Safety-Related/Non-Safety-Related separation requirements where they deviate from the criteria established in IEEE-384. (50-454/81-16-05; 50-455/81-12-05).

Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items or items of noncom-pliance or deviations. Unresolved items disclosed during this inspection are discussed in Paragraphs 2.b, 2.c, 2.d, and 2.e.

Exit Meeting The inspectors met with licensee representatives (denoted under Persons Contacted) on September 25,_1981. The inspectors summarized the scope and findings of the inspection. The licensee representatives acknowledged the findings reported in previous paragraphs.

A-8

m Binder ,

Attachment B

1. o UNITED STATES y n NUCLEAR REGULATORY COMMISSION 3

,i REGION 111 o 'i 799 ROOSEVELT ROAD

/

(.....f GLEN ELLYN. ILLINols So137 t&Y 311933 Docket No. 50-454 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 Mr. R. S. Love of this office on March 21-25, and April 4-8, 1983, of activities at Byron '

Station authorized by NRC Construction Permit No. CPPR-130 and to the discussion of our findings with Mr. G. Sorensen at the conclusion of the inspection.

i 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.

A written response is required.~Information gathered in this inspection indicates that the use of interim lead auditors who are not certifiable per ANSI 45.2.23 may be common practice at CECO construction sites. Please include in your response to the item of noncompliance a discussion of the extent of this practice at all CECO sites, including steps being taken to remedy the problem. Also, include in your response the steps you plan to take to assure that audits conducted by non-certifiable lead auditors were properly conducted.

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 heat 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.

B-1

7

. o. .

2 Commonwealth Edison Company g,yy 3 g 1g33 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.

We will gladly discuss any questions you have concerning this inspection.

Sincerely,

.')

, j/, ___Z'

/*r h k*- ? ' ,..

3o

,* 4 /l/l W. S. Little, Chief Engineering Branch II

Enclosures:

1. Appendix, Notice of Violation

2. Inspection Report No. 50-454/83-16(DE) cc w/encls:

D. L. Farrar, Director of Nuclear Licensing V. 1. Schlosser, Project Manager Gunner Sorensen, Site Project Superintendent R. E. Querio, Station Superintendent DMB/ Document Control Desk (RIDS)

Resident Inspector, RIII Byron Resident Inspector, RIII Braidwood Philip L. Willman, Esq.

Assistant Attorney General Environmental Control Division Reed Neuman, Esq., Assistant Attorney General Ms. Jane M. Whicher Diane Chavez, DAARE/ SAFE B-2

~

t pi

(

Appendix [

NOTICE OF VIOLATION l

e

. Commonwealth Edison Company Docket No. 50-454

?

. i

.As a result of the. inspection conducted on March 21-25, and April 4-8, 1983, and  !

in accordance with the NRC Enforcement Policy, 47 FR 9987 (March 9,1982), the  ;

following violation was identified:  !

'10 CFR 50,-Appendix B Criterion II, states, in part, "The program shall provide

• for indoctrination and training of personnel performing activities affecting [

quality as necessary to assure that suitable proficiency is achieved and main- -

tained." i Commonwealth Edison Company (CECO) letter, L. O. De1 George to D. G. Eisenhut, U.S. NRC, Director Division of Licensing, dated August 17, 1981, affirmed CECO commitment to Regulatory Guide 1.146, August 1980 and ANSI N45.2.23-1978 as required by Generic Letter 81-01. i ANSI N45.2.23-1978, paragraph 2.3, states, "An individual shall meet the re-  !

quirements of paragraphs 2.3.1 through 2.3.5 prior to being designated a lead auditor."

ANSI N45.2.23-1978, paragraph 2.3.1, states, in part, " Education and Experience.  !

The prospective lead auditor shall have verifiable evidence that a minimum of i ten (10) credits under the following scoring system have been accumulated.  ;

Education (4 credit maximum). Experience ( 9 points maximum).. Other credent-fals of professional competence (2 credit maximum). Rights of Management (2 points maximum). .

~ Contrary to the above, the Commonwealth Edison Company-Quality Assurance Lead-Auditor performing the-Power-Azco-Pope audit was not adequately qualified [

and/or trained to perform lead auditor functions. Details of apparent non-  !

compliance to the above requirements are delineated in paragraph 3. A.(1) of the attached report.-

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 '

L 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- t achieved.. Consideration may be given to extending your response time for good  ;

cause shown. i

~

Date,#f- / M'. S. Liftle,/ Chief l

/ .1 Engineering Branch II j I

B-3 [

~

U.S. NUCLEAR REGULATORY COMiISSION REGION III Report No. 50-454/83-16(DE)

Docket No. 50-454 License No. CPPR-130 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Byron Station, Unit 1 Inspection At: Byron Site, Byron, IL Inspection Conducted: March 21-25 and April 4-8, 1983.

]

Inspector: . S. Love ,

.fl,,.,f,.3

/ ~

Approved By- . C. Williams, Chief f/ /

~ Plant Systems Section ' '

Inspection Sununary Inspection on March 21-25 and April 4-8, 1983 (Report No. 50-454/83-16(DE))

Areas Inspected: Review of licensee action on previously identified items.

Reviewed installation of instrument sensing lines, installation and term-ination of instrumentation cables, and the review of associated procedures and records. This inspection involved a total of 69 inspection-hours by one NRC inspector.

Results: In the areas inspected, one potential item of noncompliance was identified. The licensee failed to assure that CECO lead auditors were properly qualified and certified (Paragraph 3.A.(1)).

B-4 1.

DETAILS

1. Persons Contacted Commonwealth Edison Company (CECO)

1. • G. Sorensen, PCD Construction Superintendent

1. • R. Tuetkon, PCD Assistant Construction Superintendent

• J. T. Westermeier, PED Project Engineer

• M. A. Stanish, QA Superintendent

1. • R. B. Klingler, Staff Assistant

• P. T. Myrda, QA Supervisor

1. • R. A. Westberg, QA Engineer

• A. J. Rosenbach, QA Inspector

• F. A. Mazzini, QA Engineer

• M. E. Lohmann, PCD Mechanical Supervisor

1. K. J. Hansing, QA Supervisor

1. E. Sager, Field Engineer

1. J. Binder, Project Electrical Supervisor R. G. Gruber, QA Engineer Power-Azco-Pope (PAP)

R. P. Larkin, QA Manager R. C. Schulz, Project Manager

• D. M. Nelson, QC Supervisor

• M. C. Donohoe, Engineering Manager i Hatfield Electric Company (HECo)

T. Hill, QA/QC Manager J. D. Spangler, Lead Welding Inspector (PTL)

R. Quias,. Welding Inspector (PTL)

G. A. Cason, QC Lead Inspector (PTL)

Westinghouse

• M. D. Pitlyuk, Manager

• G. L. Laughlin, Engineer ,

The inspector also contacted and interviewed other licensee and con-tractor personnel during this reporting period.

• Denotes those present at the exit interview on March 25, 1983.

1. Denotes those present at the exit interview on April 8, 1983.

2, Action on Previously Identified Items (CLOSED) Noncompliance (50-454/80-25-13): This item pertained to the failure to apply hold tag on items identified on CECO Nonconformance Report (NCR) F-529. This NCR identified the fact that the cable tray 2 B-5

q stiffener welds did not meet the requirements of AWS DI.1 and the ,

purchase order specifications. Veld profile maps were prepared on cable tray stiffner welds that did not meet the acceptance criteria. The design engineer, Sargent and Lundy (S&L), performed an analysis on the identified weld and with a few exceptions, found that the welds met the

• design intent. The welds that did not meet the design intent were repaired by the electrical contractor. Paragraphs 3.10.3.2.2.a.1 of the FSAR was revised by Amendment 41, February 1983, to state, " Deviations from the AWS requirements for specific weldments are made on the basic of design calculations." This item is closed.

(CLOSED) Unresolved Item (50-454/81-16-03; 50-455/81-12-03): Itatfield procedures did not address methods to verify that maximum cable pulling tension had not been exceeded when small cables were pulled. S&L drawing 6E-0-3000B, Sheets 1 thru 5, and llatfield Procedure No. 10 were revised to address the required precautions to be taken when small cables are pulled. This item is closed.

(CLOSED) Unresolved Item (50-454/81-16-04; 50-455/81-12-04): This item identified that the safety-related switches, instruments, recorders, etc., in the main control room were not distinctly ider.tified as being in the protection system. Paragraph 8.3.1.3.3 of the FSAR identifies the fact that the switches, instruments, records, etc. in the main control room would not be color-codes to identify the items as being in the protective system. This item is closed.

(CLOSED) Noncompliance (50-454/82-05-09b; 50-455/82-04-09b): This item identified that llECo procedure number 6 did not address corrective action to prevent recurrence when a nonconformance or deviation was identified. -

Procedure 6, Revision 11, dated October 9, 1982, now addresses corrective action to prevent recurrence. A review of HECo NCRs indicates that the procedure is being implemented. This item is closed.

(CLOSED) Noncompliance (50-454/82-05-09c; 50-455/82-04-09c): This item identified that HECo procedures did not address the precautions to be taken to prevent exceeding maximum cable sidewall pressure during cable installation. Also, this procedure did not address cable rework. HECo Procedure 10, Revision 19, dated February 14, 1983, satisfactorly addresses cable rework and steps to be taken so as not to exceed cable sidewall pressure. This item is closed.

(CLOSED) Noncompliance (50-454/82-05-11d; 50-455/82-04-11d): This item identifies that PAP procedure QC-4 did not address corrective action to prevent recurrence when a nonconforming condition was identified. PAP Procedure QC-4, Revision 10, dated Spetember 21, 1982, satisfactorly addresses corrective action to prevent recurrence. This item is closed.

(CLOSED) Open Item (50/454/82-05-12; 50-455/83-04-12): This item identi- '

fled that Ceco NCRs were remaining open for an extended period of time.

A review of the identified NCRs indicates that a concerted effort has been made to implement the disposition and close these NCRs. The CECO PCD Staff Assistant is implementing a tracking system to expedite the  !

closure of NCRs. This item is closed.

3 B-6

(CLOSED) Noncompliance (50/454/82-05-13; 50/455/82-04-13): This item identified that NCRs were being improperly closed / voided by CECO and HECo. Improperly closed / voided NCRs were reopened by preparing a new NCR. These NCRs were then properly closed and procedure were revised so as to mitigate the possibility of this situation re-occuring. This item is closed.

(CLOSED) Open Item (50-454/82-05-15; 50-455/82-04-15): This item identi-fied that there was not a procedure inplace that addressed the installa-tion of covers on cable tray and risers. HECo Procedure 9C, Revision 1, was prepared. to address the installation of cable tray and riser covers j in accordance with S&L drawings. This item is closed.

(CLOSED) Unresolved Item (50-454/82-05-16; 50-455/82-04-16): This item identified that HECo procedure 9E did not meet the requirements of IEEE-384 as relating to marking of cable tray risers. Procedure 9E, Revision 10, Paragraph 5.3.1, now requires risers to be identified every i 15'. This is in accordance with IEEE-384. Inspection Reports for the retro-fit of riser markers were reviewed by the inspector. This item is closed.

(CLOSED) Unresolved Item (50-454/82-17-01; 50-455/82-12-01): This item identified the possibility of QC inspectors inspecting items that they had installed or worked on. Hunter, HECo, and PAP are utilizing craf t personnel as QC inspectors. These contractors reviewed their records and determined that no QC inspector had final inspected his own work.

This item is closed.

3. Functional or Program Areas Inspected A. Powers-Azco-Pope (PAP)

(1) The Region III inspector reviewed the last three CECO audits of PAP, (PAP is the licensee's non-electrical instrumentation installation contractor). These audits were conducted on June 8 thru 10, 1982, December 15 thru 21, 1982, and February 1 thru 4, 1983. The findings and concerns identilied during the audits were corrected by PAP.

During the review of CECO audit reports, the Region III inspector observed that the CECO lead auditor that performed the PAP ,

audit was classified as an Interim Lead Auditor. The auditor's =

qualification and certification records contained a letter from the Byron Station Quality Assurance Superintendent to the CECO Manager, Quality Assurance. This letter (BY8067, August 24, 1982) was a request for Interim Lead Auditor Certification for the subject auditor. However, the letter indicated that the lead auditor candidate, based on education, experience, etc,...

had accumulated eight (8) points to date. This is less than the minimum of 10 credit points specified by ANSI N45.2.23-1978.

Moreover, an approved procedure allowing the use of Icad auditors who do not meet the minimum requirements of the referenced code 4

B-7

was not available. This letter received the concurrence of the Ceco Manager, Quality Assurance on August 26, 1982.

Interim Lead Auditor Certification is not addressed in the LECo Quality Assurance Manual, Ceco Topical Report (CE-1-A),

nor in ANSI N45.2.23-1978. -CECO letter, L. O. DelGeorge to D. G. Eisenhut, U.S. NRC, Director, Division of Licensing, dated August 17, 1981, affirmed CECO commitment to Regulatory Guide 1.146, August 1980 and ANSI N45.2.23-1978 as required by Generic Letter 81-01.

During interviews with Byron Station Quality Assurance personnel, including site Quality Assurance Superintendent, the Region III inspector was informed that it has been standard practice within CECO to certify an individual as an Interim Lead Auditor when he/she does not meet the qualifications of a Lead Auditor.

The licensee was informed that failure to assure that Lead Auditors were trained, qualified, and certified in accordance with the CECO Quality Program and ANSI N45.2.231978, was an item of noncompliance in accordance with Criterion II of 10 CFR 50, Appendi:: B (50-454/83-16-01).

(2) During this reporting period, the Region III inspector reviewed three CECO Material Receiving Reports (MRR) for material to be installed in the safety-related instrumentation system by PAP.

Following are the results of this-review:

(a) MRR-50225 was for 3/8" x 1/2" U-bolts. The original purchase order stated that three U-bolts were to be manu-factured to the ASME Code,Section III, Subsections NF-2130 and NF-2150, 1974 edition through summer 1975 Addenda. The Code edition and addenda was revised (CECO letter to Elcen Metal Products Company, December 12, 1979) to read, 1977 edition through summer 1977 addenda. Certi-ficate of Conformance, September 2, 1980, stated that the 3/8" x 1/2", SA-36, Batch / Lot No. A000812A, U-bolts meet the requirements of Subsection NF of the 1977 ASME Code through 1977 addenda.

-(b) MRR-50554 was for 81 safety-related pressure gauges per Purchase Order 247695. Certificate of Conformance, July 10, 1981, was in the documentation package. Engineer-ing qualification tests (environmental, radiation, seismic, etc.) have been submitted to Sargent & Lundy for their evaluation and approval.

(c) MRR-52504 was for 3 safety-related Rosemount 1153 pressure transmitters per Purchase Order 261620. Certificate of Conformance, September 21, 1982, was in the documentation package. Preliminary qualification test data to the re-quirements of IEEE-323 and IEEE-344 has been submitted to B-8 5

CECO. This data indicates that the pressure transmitter will qualify to the requirements of IEEE-323 and IEEE-344.

Final test data is being prepared by Wyle Laboratories.

No items of noncompliance were identified in this area.

(3) During this reporting period, the Region III inspector reviewed the following PAP procedures:

. FP-1, Document and Drawing Control, Revision 5 FP-2, Control of Procurement and Requesitioning of Material and Services, Revision 9

. FP-4, Material Storage, Revision 6

. FP-5, Weld Filler Material Control, Revision 10

. FP-12, Cold Bending of Pipe and Tube, Revision 6 FP-13, Hanger Installation and Control, R aision 9 FP-16, Identification and Marking of Pipe and Components, Revision 8 The above listed procedures appeared to be adequate.

(4) During this reporting period, the Region III inspector reviewed the installation of the instrument sensing lines for the following' instruments:

(a) 1 FT-0434 - Loop "C" flow, instrument mounted on panel IPL66J, located in the Containment Building at 377' elevat. ion between Radius I and 2. The instrument sensing lines were installed in accordance with drawings T4-1FT-0434, Sheets 1, 2, and 3 and were identified in accordance with Field Change Request (FCR) 15437. This FCR modified specification F-2906. The installation and separation appeared to be adequate.

(b) 1 LT-548 and 1 LT-549 - Redundant level transmitters for Steam Generator No. 4. During a walk down of the sensing lines for these instruments, the Region III inspector observed that there was only a 2" separation (18" required) between the sensing lines near hangers ILT548H135-12 and ILT549H136-7. The licensee's instrumentation installa-tion contractor (PAP) prepared Fabrication / Installation Surveillance Report No. 992, March 24, 1983, to document the separation violation identified by the NRC.

In accordance with FCR-15437, the licensee has instituted a program to identify instrument sensing line separation violations for Containment Building safety-related RPS sensing lines:

1 PAP prepares as-built drawing of the installation and submits these drawings to Westinghouse Elect ric Corporation-Nuclear Technology Division (WNTD) for review.

6 g g1

2. Utilizing their computer system, ENTD reviews the as-built drawings for separation violations.

Violations are then analyzed on a case by case basis to determine acceptability and/or provide recommended resolutions.

To confirm that this method of analysis will in fact identify separation violations, the Region III inspector requested that a computer run be made on the ser. sing lines for instruments ILT-548 and ILT-549. Note the full computer run for instrument sensing lines for Unit #1 is scheduled for June 1983. The inspector also requested that ENTD be provided the information on the separation violation observed.

During the week of April 4-8, 1983, ENTDperformedan analysis on the subject sensing lines. This analysis indicated a separation of 3", center to center, in the same area identified by the Region III inspector.

Pending a review of the Unit #1 final separation analysis by ENTD, this item is open (50-454/83-16-02).

(5) During this reporting period, the Region III inspector reviewed the installation and inspection documentation and as-built drawings for the following instrument sensing lines:

(a) Pressurized level transmitter ILT-0460 Installation drawing T146-1LT-0460, Sheet 1 of 4, Revision 5; Sheet 2 of 4, Revision 6; Sheet 3 of 4, Revision 6; and Sheet 4 of 4, Revision 8.

As a result of a previously identified item of noncom-pliance (Reference 454/82-05-19; 455/83-04-19), PAP has instituted an extensive re-inspection program. During a review of the sensing line installation records for this instrument, it was observed that for Weld Numbers 1 thru 16, 8 of these welds were rejected during the re-inspection. The original weld inspection was performed on October 29, 1980 by Inspector "A". A review of Inspector A's qualification records indicated that he had been certified as a Level I weld inspector on November 1, 1980, and a Level II weld inspector on November 15, 1980.

Inspector "A" was terminated on July 8, 1981. It is the Region III inspectors understanding, that, as a minimam, all accessible welds inspected by Inspector "A" through April 1981 will be re-inspected. This understanding is based on interviews with licensee and contractor personnel and a review of the re-inspection program. This re-inspec-tion effort is being tracked by the item of noncompliance referenced above.

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7

(b) Loop C flow transmitter IFT-0434 Installation drawing T4-1FT-0434, Sheet I of 3, Revision 4; Sheet 2 of 3, Revision 6; Sheet 3 of 3 Revision 3.

During a review of the sensing line installation records for'this instrument, it was observed that Inspector "A" (Reference paragraph (5).a above) performed a visual inspection on 56 welds in this system in one day. Per the re-inspection program, these welds are scheduled for re-inspection. It was also observed that the Authorized Nuclear Inspector (ANI) performed / observed one visual weld inspection and 6 liquid penetrant examinations (PT) on the welds in this system. The re-inspection effort for this system is being tracked by previously identified item of noncompliance (Reference 454/82-05-19; 455/82-04-19).  ;

< t (6) Summary of PAP Re-Inspection Effort, as of, April 3,1983.

(a) As a minimum, the first three months of each certified inspectors (21) work will be re-inspected. Depending upon the reject rate as defined in the procedure, the re-inspection for a given inspector's work may encompass an additional three months or longer.

(b) The initial scope (three months per inspector) of the re-inspection effort has been defined. '

(c) Approximately 25% of the re-inspection effort has been completed. To date, April 3, 1983, 125 valid welding rejects have been identified.

E. Hatfield Electric Company (HEco)

(1) During this reporting period, the Region III inspector veri-fled the installation and termination of instrumenation cables 1 for instrument 1FT0434, ILT0548, and ILT0549. This verifica-tion consisted of a physical walkdown of the cables, inspection of the terminations, and a review of the associated records.

(a) Loop C flow transmitter 1FT-0434 is mounted on instrument rack, IPL66J. Signal sent to Process I&C Protection ,

Channel 1, Cabinet 1, Panel IPA 01J.

1. Cabic 1RC-723 - From transmitter 1FT-0434 to junction box IJB-428R. As of April 7, 1983, this cable has not been installed.

2. Cable IRC-364 - From IJB-428R to electrical penetration E24-IS105E-1K1R. Cable type - ITW-PR #16 (shielded),

600 volt. Reel No. 02166-39. Installed December 4, 1980 to Revision A of the pull card. Cable routing B-ll 8

. z. -

is as follows: 1JB-428R, C1R-1303-1K1R, IJB-334R, C1R-2301-1K1R, IJB-348R, CIR-2371-1K1R, IJB-623R, CIR-4326-1K1R, 1377U-1K1R, 1359U-1K1R, terminating (inline splice) at electrical penetration, inside Containment Building.

3.

' Cable'IRC-363 - From electrical penetration E24-IS105-IKIR to Panel 1PA01J. . Cable type ITW-PR #16 (shielded),

600 volt. Reel No. 02166-41. In talled April 5, 1981 to Revision B of the pull card. Cable routing is as follows: inline splice at penetration, 1823D-1K1R, 1829D-1K1R, 1973D-1K1R, 1828D-1K1R, 1827D-1K1R, IR319-1KIR, 11885F-1K1R, 11886F-1K1R, 11887F-1K1R, 11888F-1K1R, 11889F-1K1R, 118901-1K1R, 11891F-1K1R, IR401-1K1R, Panel IPA 01J.

This installation was in accordance with drawings, cable pull card and S&L Cable Tabulation printout.

(b) Steam Generator No. 4 level transmitter ILT-0548. Signal to Process I&C Protection Channel 3, Cabinet 3, Panel IPA 03J.

1. Cable 1FW-057 - From transmitter ILT-0548 to electrical

-penetration E51-1S107E-1K3R. Cable type - ITV-FR #16 (shielded), 600 volts. Reel No. 02166-69. Installed October 21, 1982 to Revision B of the pull card.

Cable routing'is as follows: ILT-0548, C1R-4103-tK3R, IJB074R, C1R-4104-1K3R, terminating at the penetra-tion, inside containment.

2. Cable 1FW-056 - From electrical penetration E51-IS107E-1K3R to Panel IPA 03J. Cable. Type ITW-PR 316 (shielded), 600 volts. Reel No. 0216631.

Installed : Apri1~ 2,1980 to Revision B of the pull card. Cable routing is as follows: inline splice i

at penetration, 1798J-1K3R, 1797J-1K3R, 1972J-1K3R, *

• 3C216D-1K3R, 11880A-1K3R, 11881A-1K3R, 11882A-1K3R, 11883A-1K3R, IR400-1K3R, Panel IPA 03J, terminal block  :

F, landing points 10,-11, and 12. l

• Where cable 1FV-056 enters conduit IC216D-1K1R, it [

was observed that the cable jacket was damaged at  ;

cable footage marker 4684. The shield wire was exposed but did not appear to be damaged. The licensee's I electrical contractor, HEco, prepared NCR 597, April 6, 1983, to document the damaged cable jacket. '

Also, during the labeling of conduits IC216C and IC216D, the markings were reversed on both ends of ,

these embedded conduits. Field Change Request (FCR) l 22863, April 7, 1983, was prepared to have this error  ;

corrected on the as-built drawing. This item is open o

9 B-12 [

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~ _ . _ . _ _

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I pending a review of NCR 597 for proper closure and  ;

review of FCR 22863 for approval and correction i of as-built drawing (50-454/83-16-03).

Except as noted, this installation was in accordance with drawings, pull cards, and S&L Cable Tabulation printout.  !

i (c) Steam Generator No. 4 level transmitter ILT-0549. Signal to Process I&C Protection Channel 2, Cabinet 2, Panel IPA 02J.  ;

1 Cable 1FW-049 - From transmitter ILT-0 A9, Rack i IPL57J, to electrical panetration E35-1S106E-1K2R. [

Cable installed November 5,1981, to Revision A of  !

the pull card. Cable type - ITV-PR #16 (shielded),  !

600 volts. Reel No. 02166-46. Cable routing is as follows: 1LT-0549, CIR4478-1K2R, IJB088R, CIR5124- '

1K2R, terminating at penetration, inside containment. j

2. Cable 1FW-049 - From electrical penetration E35-IS106E-IK2R to Panel IPA 02J. Cable installed April 8, 1981 l to Revision A of the pull card. Cable type ITW-PR i

1. 16, 600 volts. Reel No. 02166-41. Cable routing is as follows: inline splice at penetration, 114588-1K2R, IR364-1K2R, 11467H-1K2R, 11485H-1K2R, 11464H-1K2R, 11418H-1K2R, 11417H-1K2R, 11620H-1K2R, 11623H-1K2R, 11624H-1K2R, Panel IPA 02J, terminal block J, landing points 22, 23, and 24.

This installation was in accordance with drawings, ,

pull cards, and S&L Cable Tabulation printout.

(2) ' Summary of HECo Re-Inspection Effort as of April 3, 1983.

'(a) As a minimum, the first three months of 22 certified

~ inspectors work will be re-inspected. The 22 inspector equals 1 in 5 of all inspectors employeed by HECo since  ;

start of project. Depending upon the rejection rate as defined in the procedure, the re-inspection for a given inspector's work may encompass an additional three months <

or 100% of his/her work. In addition, the original sample size of inspectors may be increased 50%.

. l (b) The initial scope (three months per inspector) of the

~

re-inspection effort has been defined.

(c) -Approximately 5% of the inspection effort has been completed. ,

4. Status of Installation Effort Unit 1 Unit 2,

(

Cable' tray installation 100% 98%

Conduit installation 90% 54%

13 10 .

Cable installation 80% 34%

Cable terminations 80% 30%

Equipment installation. 100% 90%

Instruments & sensing lines 98% 01%

5. Open Items Open items are matters, not otherwise categorized in the report, that need to be followed up on in future inspections. Open items disclosed during this inspection are discussed in paragraphs 3.A.(4).b and 3.B.(1).b.2.

6. Exit Interview The inspector met with licensee representatives (denoted under Persons Contacted) on March 25 and April 8, 1983. The inspector summarized the scope and findings of the inspection. The licensee representatives acknowledged this information.

11 B-14

~

Bindel

... Attachment C y'* 't, *

• NUCLEAR REGULATORY COMMISSION

• M GiON lli

'; 790 ROostVf LT Roao

'g

• OLIN ELLYN ILLINots 60137 QUN ?. 4 92

' Docket No. 50 454 -

Docket No. 50-455 Commonwealth Edison Company -

ATTN: Mr. Cordell Reed ^

Vice President Post Office Box 767 Chicago, IL 60e90 Gentlemen:

This refers to the special safety inspection cend.c ed by *:r. P. F N-  :$rn and other staf f c:errbers of this office on March 29 31, Arr:1 12, 5 4  :. ; .

and !!ay 11,1982, of activities at B y r on S t a t t en , L*n t t s ! f, 2. ...t ! : ~. .' o : t:y NRC Construction Permits No. CPPR-T3U and No. CFFh-121. T!.ts 1.sr rc'se.

to the discussion of our findings with Mr. V. S::edo and ethers cf e . aff during a treeting in our of fices on May 7,1982.

The purpose of this special team inspection was tc. assess the aJc..a;r e.

certain aspects of the quality assurance / construe:1 n act:vaties Lt ?F Byrcn 5:stien. The scope of this assessment inc!.d id aucits cf ;./ .t >

assurance progra. interfaces and everview, corrective actacn sy,te-a.

design change centrol, r.aterial traceability cf 3r.stal;ed str.;;a a ma corponents, electrical cable installation, inpro:es. Ins;ect:c:a, a .;

ef f ect 2ver.ess of quality control inspectors. Va htn these area t ra inspecticn censisted of a selective examination et procedures and representative records, obse:vations, and interviews with perser.ns!.

In general, within the areas inspected, the qua;2ty assurance progra-for the Byron Station appeared good. However, exa ples cf pregra- im-plementation deficiencies were identified which re;; ire ccrrect;vt a. ..:

on your part.

Please note that we expect Commonwealth Edisen Cc pny to revieu programe for its other facilities under cc .structier: to ast are that similar problems do not exist at these facilities.

The activities that appeared to be in noncomplia:ce with NRC rotiuire e-:s are specified in the enclosed Appendix. A written respense is rez.ared.

In respondias to noncompliance Item (82, please describe the actact taion er planned to assare that:

(1) other quality coatrol inspecters are preperly

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s trained and-certified, (2) quality,controisinspectors working for contractors that have 'coepleted sfiityarclated Verk an'd?no longer..have personnel on site were prope'r)y trained and qual ~ifled;to perform. the irispection functions assigned, and J(3)s inspection 9iperferred by quality control inspectors that were improperly t' rained aid' qualified dere valid. .

v s

Ve are also concerned about yodr past verformance concerning the staff:ng of the Pyron Q.1 Superintendent i position and the on-the-job tra:ning of

,o:ur byisn Si?h Qual 51y Assurai.Je persennel as discussed in the deta: Is t h :. s r epo fi' .' Please prov:de us'with'a response explaining what act::n

',2u wil' he igking to assure that your,Cuality Assurance Organization

= staf: cd an,. trained to a level that will ensure effective oversight 0;ality activities. of

. c-ia accerJ2 ;e uith 10 s i CNN 2.79O' of the Commission's regulatiens, a c py of t,is le:3er, t5e cpylos2res, and yob response to this letter will be placed

a the N.C' .' Pablic Dacuse,hi, Rose.

t ,.. a t If' this report contains any informatzen ycu (or your centr.s:t6is) believe to be exe=p: from disclosure under F. CTR 9.5i1)'*), it is'necessary that you (a) notify'this office by te:e-

-: 5:ne w: thin file a r aq:.es t ten (10) d.sys from the date of this letter of your intent:en for withhold ng; and (b) submit within twenty-five (25) says fror. t he date of this letter a written application to this off ce to

..thhcld such infer:ation. If your' receipt of this letter has been

. layed suc.h that les.r than seven (7) days are available for y ur review, o; easu 1.otify *.his of fice prc=pily secthat a n'ew due date may be estab-

) . shed.

Consistent with Section 2.790(b)(1), any such applica: 2en eus:

et. acccrpanied by an affidavit executed by the' owner of the inf:::ati:n

.r.ich identifies the document g or part sought to be withheld, and wh ch

ntains a fu:1 state. ment of the reasons which ire the bases for the

.laim that the information 11.ould br withheld.from public disclosure.

D.is sewtion further requires the'staterent to address with specificity the te be considera,d witt.hci - shalb benco i: ions listed.in 10 CFh'2.790(b)(4). The information scught

art of the 'af fidavit'. If w? porated do not hear as far 'es possible into a separa

e

~from you in this regard within t ? 'r spe. ified perlsds noted above, a 2bpy of this letter, the en:losures, u u youz respense telthis letter will be placed in the Public D :uzen:

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V. will x adly discuss any questions you have concerning this inspc.ction.

Sincerely,

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.I. E. Norelius, Directer Division of Engineering and Technical Progra.s Luclostres:

1 Appc:idix, Notice of Violation- .

Insr.'r_ tion Report Nr. SC '54/62-05 and Nc. SC '55/82-04 w/en:Is:

..ais O. DeIGeorge, Director-of Nu:: car. Licensing I.-Scl.losser, Project Manager u ..ine: 'Scrensen, Site Project Superintendent

) 1: 'E..Queric, Station Supe r::.:endent

"l3 De:u ent Ccntrol Desk (R:05) f

!. 2 :de.m: Inrpeeter, RII: Syrta hosid(nt inspecter, RIII Braicweed-I':ren 5 :;stad:, Office of

.\s s i s t :it Attcrney General

'!:eron M. Charry.

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.w Appendix NOTICE OF VIOLATION .

Commonwealth Edison Company Docket No. 50-i.54 Docket No. 50-I.55 As a result of the in:ipecti:: conducted on '! arch 29-31 April 1-2, 5-9, 12-14, .m 3 :tay 11, 1982, and in accordance with the NRC Enfor:ement Pel:cy,

7 FR 9%7 (?: arch 9,1952), the following violations were ident:fied:

1.

IC CTR 50, Appendix B, Criterion I, states in part, "The authority and du-ies of persons and organizations performing activities affect-in;; the safety-relsted functions of structures, systems, and com-ponen:.5 shall be clearly established and delineated in writing" and "Such persons and organizations performing quality assurance func:: ens shall report to a management level such that this required authcrity and organi:stional freedom, including sufficient independence frem cest and schedulu when epposed to safety consideratiens, are provided."

'The I.icer.see's Topical Eeport, CE-1-A, Revisien 20, Section 1.A states

" Edison has prime respensibility for controlling the quality of on-site werk by field centracters,"... "The Commonwealth Edison Company Qual::y Ass.;rance Program for Nuclear Generating Stations covers the organ::s-

) t 2ea arra::gement whereby the Quality Assurance Depar:ren is a separa:e and :nder4ncent or;3niza 2cn."

~

Cc:.trary to the above:

a. On ! arch 30, 1952, it was identified that the Quality Assurar.ce

.'hn.iger for Hat field Electric Coepany, as shown in the Qual::y

-Asst.rance '!anual, reports to the Vice-President, who is located

.on s:te and has direct responsibility for cost and schedulec

b. On April 2,1982, it was identified that the Qua!ity Assurance

!!ancger for Powers-A:co-Pope, as shown in the Quality Assurance

'hnn il, reports to the Project !!anager, who has direct respons-ibility for cost and schedule.

c. - On April 8, 1982, it was identified that the Project Constructicn Department of the licensee is part of the approval chain regarding the hir ing and pro: o:ing of contractor's quality assurance persennel .

d. On ?! arch 30, 1982, it was identified that the Hatfield Electric Company has been operating with a Quality Assurance Organization other than that described in their Quality Assurance Pfanual.

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'.,- -  :- . C '

' Q_ T.

Appendix 2

')

e. On April 4, 1982, it was identified that Johnson Controls, Inc.

has been operating with a Quality Assurance Organization other than that described in their Quality Assurance Maa.ual.

This is a Severity Level IV violation (Supplement I I )'.

IC' TI R 50, A;pendia B, Craterion II - Quality Assurance Prcgra s: 2:es in i.trt, The program shall provide for indoctrination and tra:n:ng cf ; ersenrel perfe: ming activities affecting quality as necessary to ass;.re that suitable proficiency is achieved and maintained."

Cenmenwealth Edisen Cc=pany (CECO) letter, L. O. De1 George to D. G. Eisenhut, U.S. NRC, Director, Division of Licens:ng, dated August 17, 1981, affirmed CECO ce==itment to Regulatory Guide 1.58, ANSI N45.2.6-1978 as required by Generic Letter 81-01.

ANSI N45.2.6-1978 - Paragraph 1.1 states in part, "This Standard del r.estes the requirements for the qualification of persennel who perferm 2nspectien, examination and testing to verify confer:ance te specil:ed requirerents of nuclear power plant items (structures, syst. s ard comp:ntnts of nuclear power plants) where satisfactory

, pe r fe rn.snce is required c prevent postulated accidents which ceuld cause undue risk to the health and safety of the public, or to ei: g:u th? censee,uences of such accidents if they were to occur."

) Asi s-I .. .e-1778 - Para graph 1.2 states in part , "The requireren:s ef - ? is F: indard a; ply :: pers:nnel sh: perfers inspections, exa :na-t i c :. ..

cs:s-during fatrication prior to and during receipt of s t e --- o: tr.e c:ns :ue:::: s::e, during construe::en, during pcrepere-t ier :'. cnd sta rtup test . . . ." The requirements apply to pers:nnel of the c-;.c:s..., plat.: de.igners and plant constructors. .."

ANS: N45.2.6-1978 - Paragraph 2.2 states, "The capabilities of a ca.a*d=te fe: cert:ficatien shall be initially deter =ined by a sui:-

ab!v c.n'uat ten cf the :anf.2da e's education, experience, training, test :tsults, or capability demonstration."

ANF1 N45.2.6-1978 - Sectica 3.1 states, "The requirements contained with:r. th:s section define the minimum capabilities that qualify persor.r.cl te perform inspections, examinations, and tests which are with:r. the sccpe of this standard."

AN5' N;5.2.6-1976 - Sections 3.2, 3.3, and 3.4 specify the personnel car abilit ies of Level I, II, and III inspectors respectively. Secti ns

~3.5, 3.5.1, 3.5.2, 3.5.3 provide education and experience recom.menda-tions for Level I, II, and III inspectors.

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ANSI N45.2.6-1978 - Section 4 states in part, " Personnel who'are assigned the responsibility and authority to perform functions covered by this Standard shall have, as a minimum, the level of capability shewn in Table 1...."

Con:rsry to'the .1bove, certain contractor QA/QC supervisers and inspecters ucre not adequately qualified and/or tra:ned c perf::=

safety-rela ed inspection functions. Examples'of apparent ncnc: -

pliance are identified in paragraph h.(2) of the attached report.

This is a Severity Level IV violation (Supplement II).

3. 10 CFR 50, Appendix B, Criterion V states in part, "A::ivities affect-ing quality shall be prescribed by documented instructions, pro:edures, or drsvings, of a type appropriate to the circumstar.ces ..

The licensee's Topical Report, CE-1-A, Revision 20, Section 5 states, "The quality assurance actions carried out for design, constructien, te .:i.,g, and operation activities will be described in de:umented in st ruct ens. procedures, drawings , specifica icns, or che:klists."

"A ::vities affecting q iality are required by the Edison quality p: g r a. to be prescribed by documented instructions, pro:edures or dr1. age."

) Ca.:rar!. to the abcVe; he fellew:ng activities were no: centrol:ed by cr: red-res or instru.tions:

a. 2n ': arch 30, 1952, it was identified that Hatfield Ele:::::

C:rgany was utilin.ng a Discrepancy Report System, which was n:: referen:ed or centre 11ed by a precedure, to tra:k and *

orrect discrepanc.es and noncenferming conditiens d:scovered during inspections of safety-related equipment.

b. On April 2, 1952, it was identified that Powers-Accc-Pepe was util::ing a Fabrication Installation Surveillance System, which was r.c: cor. trolled by a procedure, to track and correct dis-

repancies and non enforming conditions discovered during in-spoetions of safety-related equipment.

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67g; Appendix

c. On April 9, 1982, it was identified that Hatfield Electric ,

Ccmp.my proce 3ures did not contain an electrical cable rework procedure nor the requirements to calculate electr: cal cable sidewall pressures prior to pulling cable. .

d. On April 7, 1982, it was identified that the Hatfield Electric Company's NCR for. contained a secticn titled " Action to Prevent Recurrence" but thcre was no direction in the body of Procedure nor Number 6 for actions to be taken to satisfy this requirerent does the procedure assign responsibility for this section of the NCR.

Th:s is a Severity Level IV violation (Supplement II).

e. 10 CFE 50, Appendix B, Criterion XV, states in part, " Measures shall be est ab!:shed to contrel materials, parts, or compenents wh:ch do their inadvertent not ecnferm to req;irements in order to prevent use or installat:on."

The I:cer .ec's Topical Ecpert , CE-1-A, Revision 20, dated February 17, 1H 2, Section 15. states in part, " Items involving constructien, ca:n-t e: 2nce, and modif icat iens which are f ound nonconforcing. . .will be cm ro'.le d to prev 2nt their inadverent use or installation." ,

Cc: trary to the above:

)

a. Dr. *.!a rch 31, 1952, it was identified that three (3) CECO ncncen-re:r.ince reports (F-e34, F-645, and F-682) had been vcided rathat than closed, with reference to corrective act:en taken to resolve the noncenformance. By voiding the subjec.t SCRs, r the tracking syster. to verify that the approved dispositienrecurrence has been completed and corrective action to prevent is nagated. Also, the voided NCRs are removed from the trend analysss system.

b. On April 7,1982, it was identified that three (3) nonconforrance reports (96, 99, and 100) had been voided by the Hat field Electric Ccc.pany rather than closed, with reference to corrective action taken to resolve ti.e nonconformance. The subject NCRs were the iters voided because an FCR was or would be issued to accept

~

as installed. At the time the NCRs were voided, there was no a>>urance that all the FCRs would be approved. By voiding the NCRs, the tra: king system to verify that the proposed disposition was ace.epted, was 1:egsted and the NCRs were removed from the trend analysis system. ,

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Appendix 5

c. On April 7, 1982, it was identified that the Hatfield Elwetric Company had improperly closed NCR 168, in that after Ceco engineering disposstioned the subject NCR to replace the item, the Hatfield Electric Company closed the NCR without accc plish-ing the approved disposition. At the present tire, there is a ncn: enforcing cable installed, and the tracking system to repla:e tl.c cable, has been negated.

O This is a Severity Level IV violation (Supplement II).

~

10 CFE 5", Appendi.x B, Criterien V states, " Activities af fecting quality s!.all be prescriced...and shall be acceeplished in ace:rdance wit h t! e'e instruct ions, procedures or drawings."

The li cr.see's Tcpical Report, CE-1-A, Revision 20, Sectien 2.2 co- tr to comply with the Regulatory Position of Regulatory Guide 1.16 Fecis:en 2, which endorses ANSI N45.2.2-1972. Also Secti:n 5 states. "T;te quality assurance actions carried out for design, cen- >

struction, testing, and operation activities will be descr: bed in d tt erted :r.structions, precedures, drawings, specificaticas, or che.k'.ists."... " Activities affecting quality are required by the i E: 1>cn qual:ty pregram ts be prescribed by documented instructiens, prc et res er draw:ngs."

Cc..; : a ry t o t he abc.ve; the following activities were not acceepl:shed a:t :d:ng te proccCures o t- instructions:

a. Cr April 2, !!S2, it was identified that Pesers-A:ce-Pepe was sicz:n; rejectec esterial a==ng accepted material in Vareheuse No. 4 This as contrary to their Procedure No. PP-3.

i

b. On April 2, 1982, it was identified that Powers-A:co-Pope had

• not tagged a defective torque wrench with a Reject Tag. This is c. ntrary to their Procedure No. FP-11.

c_-

c. On March 30, 1982, it was identified that Hatfield Electric Cerren) did not tag torque wrenches which were past their cali-tration due date. This is contrary to their Procedure No. 24. ,

e

d. On April 5, 1982, of 13 reports reviewed it was identified that 12 ncncenformance reports prepared by Powers-A:co-Pope did not add.ess correttive action to prevent recurrence. This is

. tent:1ry to their Quality Assurance Manual, Section B-8, paragraph F -8. t . 2.

c. On .'.pril 7, 1982, it was identified that the conditions main-t aira ,1 by the licensee in Warehouse No. I and No. 5 were contrary to Cl:Cc Quality Prcpedure 13-1 and to the requirements of ANSI- -

'45.2.2-1972.

1 c-8

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Appendix , 6 "'

This is a Severity Level V violation (Supplement II). t 67 10 CFR 50, Appendix B, Criterion VI, states, "ticasures shall be established to control the issuance, of documents, such as instruc-tionr.. procedures, and drawings, including changes thereto, which prescribe all activities affecting quality."

4

• Thi lice:mec's Topical f.eport , CE-1-A, Revision 20, Ser.tien e states, "A da.:cment centrol system will be used to assure that d:c;:ents sui 5 as specificat ions , procedures , and drawings are reviewed f::

a.b 3 a:.y and approved for release by authorized personnel.". . . "Eath raceiving of fice or area shall have a centro 11ed trethod for check:ng r aipt of new or revised doeurents and assuring that the lates r**.ised d:cunent is in use." ,'

Cm t rary to the absve: 1

a. On April 4, 1982, of 12 drawings reviewed it was identified that i

onc drawing lacated in the Jchnsen Controls Incorporated en-stte

• of fite drawing file was not of the proper revision,

b. On April 7, 19S2, cf 10 drawings reviewed it was identified that

[

tur drcwings located in the Hunter Cerporation docueent statien

-F were not of the preper revision.

Th:s u. a Severity I. eve.' V violation (Supplement II).

7. 10 CFI; 50, Apper..lix 2, Criterien IX, states in part, "'feasures shall be eth'. ished to assure that special processes, including welding. . . ,

i are c.c.it:clied and acec.eplished by qualified personnel using qualified pr r..ed ar e s in accordance with applicable codes,...."

The licensee's Topical F.eport, CE-1-A, Revision 20, dated February 17, 19e.:. pat e 9-1, Kevisien 15, dated January 2,1981 Sect aen 9, " Cent rol of Spo..ial Precer.ses," third paragraph, states in part, that, " Process cerarol ptoredures will be used as required by specifications, codes or .t a*:d ards , as applicable...."

The AS'E M.PY Code Section Ill,1974 Edition, Summer 1974 Addenda, Ar' ...le '.MDCO, Sabarticle NA-4411, states in part, that "The prir n shall include treasures to control the issuance and dispcsi-t ion of d:cuments., such as. . . , instructions, procedures . . . , includ-inr. d in;;es thereto, wh:ch prescribe the activities affecting quality.

The

+ ne raurcs shall assure that documents including changes..., and di :

is 4.hu'.sd p.rformed."

to and used at the location where the prescribed activity z

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Atpendix 7 Con:rary was not to the above, c,n April 13. 1982, it was identifed that welding being accomplished in accordance with applicable codes, in that, cent rolled welding proccdure specifications with the associated welding parame;er sheets were r.ot located at the prescribed activity (wel:i:ng) in 3 ose of 4 locations checked. '

Tn.s b a Severity Level V violation (Supplement II).

t.

10 CTR 53, Appendix B, Criterion XVII states, " Sufficient rec rds sra'; he ratntained to furnish evidence of activities af fecting qu.:: .ty. Consistent with applicable regulatory require:ents, the ap; ' :i:an t shall establish requirerents concerning reccrd retentzen, such .ss duration, location, and assigned responsibility."

The litensee's Tepical Eeport, CE-1-A, Revisica 20, Section 2.2, ce--its tc the Regulatery Position of Regulatory Guide 1.65, Rev:s:en 2, which endorses ANSI N45.2.9-1974 Co:.t rary to the above, en April 7,1982, it was identified that ':: 1. a y Inm. atrial Contractors did not provide the security standards estab::shed

! by ANSI G5.2.9-1974, to preclude the entry of unauthorized pers:nnel inia -he s:crage area ard to guard against larceny and vandalis=.

T;. . s 5 a Sever --/ Level V violation (Supplement II).

) .

12 of ,

JF. 5;, A; Ten lis B, Criterien XVIII states, "A cerprehens:ve system a:.:. i and p >riodic aadats shall be carried out to ver:fy cc ;..':ance s.' all n;.. cts of the quality assurance program and to deter :r.e the ef.

• n , . t v. of the program.

T; licen.ce's Topical heport CE-1-A, Rev2sion 20, Sect ion 2.2 c:--its to at ;> 1 / sath the Regulatory Pos: tion of Regulatory Guide 1.144, h i ior.1, which ender: es ANSI N 5.1.12-1977.

Cx ary to the above, on '! arch 29, 1982, it was identified that the aa 'i t re,mrts of Comeensealth Edison Company, Powers A:co Pope, N t e ur ah Testing Laboratory, Johnson Controls, Incorperated. H.! ter C.. 3r.stion, and Hatfield Electric Company failed to inc ude the cr t..rta, established in ANSI N45.2.12-1977, regarding pers=ns c:n-ts.ttd in the audit and a summary of audit results including an er elust:en statement regarding the effectiveness of the quality o' '.rgnen pregram elements which were audited.

Th.s is a Severity Level V violation (Supplement II).

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/ppendix ,

3 Tursuant to the provisions of 10 CFR 2.201, you are required to submit to t his of fice within thirty days of the date of this Notice a written state-

r.cnt 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 cortpliance will be achieved. Consideration may be given to extending your response tiet for good caust shown.

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Dtrecter

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v U.S. NUCEEAR REGULATORY CO'1.'!ISSION REGION III Report Nos. 50-454/82-05(DETP); 50-455/82-04(DETP) '

Docket Sos. 50-454; 50-455 License Nos.,CPPR-130; CPPR-131 L'bensec:

Cc. mon'.ealth Edi:,an Ccmpany P. O. Box 767 Chic'ago, IL 60690 '

l'aciliti Name: Eyron Statica, Unit 1 and 2 Inspect wn At: Eyron Site, Byron, IL Inspe:::rn Cc.du::ed: .farch 29-31, April 1-2, 5-9, 12-14, and .'!ay 11, 1982.

A'WL!< -s . --

Inspecters; D. H. D .ielson 4 !l^

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• Pcschel dd(!?4-N* dv' W K. S. Leve f'j A/ /'A. S

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D. . Danielson, Chief '

flaterials and Processes Section i inspect en .cygg liispec t c.i. en !! arch 29 31, Apr_il_1-2, 5-9, 12-14 and May 11, 1982 (Reperts No. 5 0 -a ",4 / 6.' - 0 5 ( DETP )j 50-455/82-Oa(DETP))

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, Areas Inspected: QA Program interfaces and overview; corrective action systems; design change control; material traceability of installed struc-g tures and cemponents; electrical cable installation; inprocess inspectiens; 7 QC inspector effectiveness. The inspection involved a total of 662 in-spector-hours onsite by seven NRC inspectors.

Results: Of the areas inspe:ted nine apparent violations were identified (Isilure to assure contractot s are operating with a QA organization as  ;

described in their QA manual and to assure that QA is sufficiently inde-pond er.t frer erst and schedule paragraphs b.(6),(b), b.'(8).(b), and b ( 10 ) , ( L. ) , fa: lure of site contractors to control the issuance of d:cu-mants - b.(10' (b); fai:ure ef site contractors to follo. their pro:edures parcgr.ghe 1 (IC).(h), and c.(2),(d).2; f ailure of site cer.tracters to

. . corr!231. act:vities in acccrdance with procedures paragra,rhs b.(10)-(b), I e (2).(c'.1. a:.d f.(2).fa); failure to include certain ANSI Na3.2.12

...ite:ia ir CiCo audit reports of contractors - paragraph b.(;0).(b);

silu:e et a site contractor to meet certain security standards established Ir ANFI N i 2.c for sterage of reccrds - paragraph b.(10).(b); f ailure to 4..

m t A'.5 : N45.:.6 qual:fication, certification and training require er.ts

.:r ccr.t: octo: 02 inspectors paragraph h.(2); failure to specify cer;1ete

...d ac(q.ute cer:tctive acticas on nonconformance reports - paragraph n (2).(s' s: failure to accceplish velding in acccrdance with appitcable s.. des - paragr.ph g.(2).(d).

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4 DETAILS .

.') 1. ,P,g gons Contacted ,

Co men.ealth Edison Company (Ceco)

• W. Stiede, Assistant Vice President '

• L. DelGeorge, Director of Nuclear Licensing

'*V. 1. Schlosser, Profect Manager -

• V. J. Shewski, Qualit*, Assurance Manager

• G. Screasen, Project Superintendent

• K. Tuetken, Assistant Project Superintendent

• M. A. Stanish, QA Superintendent, Byron R. J. Farr, QA Supervi , or K. J. Hansing, QA Supervisor T. R. For.merfield, QA Superintendent , Braidwood J. J. Mihovilovich, Structural Supervisor, PCD R. B. Klingler, QA Qupervisor, PCD G. F. Marcus, Director of QA, Engineering / Construction J. O. Binder, Electrical Supervisor, PCD M. E. L:hmann, Mechanical Supervisor, PCD C. J. T: ashek, St artup Coordinator H . J. - K J::.-a rek , QA Engar.eer A. A. Jaras. Project Operations Analysis Superviser

• T Tram , Nucletr License Ad-inistrator P. Denw ein, Prc ject En,;ineering Department R. E. C terio, Startup .4 perintendent g *J T. k a t t e r ei rr , P:c,'c:t Engineer E. Gral.tr, CA Engineer J. K!:rJ:, QA Inspector P N *:--ski, C A Eng:naer J. T:nt/, Eng:neering As istant P. Ms:ctba, QA Engineer K Key, Senior Buyer L. Channell, Material Co:rdinator R. S:nwart:, QA Engineer Sargent ar.d Lun.h Er.gineers (SSL)

R. Rabin, Senier QA Coordinator D. Demess. Engineer, PMD

*T. B. Thorsell, Senior Electrical Project Engineer V. Crisci, Project Leader J. Keinosky, Electrical Project Leader Vas t in ghpu s e (V) n<

D. R. Fraser, Manager, SAMU S. Stahl, QA Engineer, NTD Y. Kau, Associate Engineer, PIDG

_A 3

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c. 'as H_a t ri 1_d.,Eli et rirJorrpspL(HECo)

'} G. 'ianderhei, Project Manager J. Suchanan, CA Manager

• A. Koc.1, QC Supervisor R. Bar:elasti. QA Supervisor D. Stoner. QC Toreman L. Broese, QC Insp ctor .

J. Mulrene, QC Inspector ,

Pcuers-A.- o-Pope (PAP)

R. Larkin, QA Manager M. Donahoe, Engineering Manager C. Cremer, QC Supervisor A. L:nia, QC Inspe:ter B . gtt, Prothers Corperation (BPC)

R. H Pay. QA/CC Manager V. V.!:s, QC Inspe: tor T. 6 =;p Sa-efees, Inc.

R Deterasso, NDE Supervisor J.-! c a:t " r.trels. ine.

) B .han, QA Manager S P. a. se:1, CC Inspe:ter Pit..L..rti Testfr: Lab : stery (FTL)

J. Tra. in. Site '!anager J. Chase, Calibr.ition Technician ,

G. Moha .mid, $ tte Auditor Eli!.;1y inJaetries Cor.t ract or. Inc.

M. Vttidser, Site Manager

$,uf! f ar Inst allation Servf:es Ce-rany (NISCol J. Pruitt, QA/QC Manager C Auf l car _P,oger SeQi,ces (E W. Wh takur, Project QA Engineer Reise.ahl Sheet 'letal Vorks. Inc.

A. M. Scl.legel. QA Supervisor C-15

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. Himter Corporation '

i 3 M. Somsas, QA Supervisor '

/ L. Haddick, QC Inspector D. Cerasani, Piping Engineer ,  ;

L. Hill, Auxiliary Building Superintendent j W. Evertt, Containment Bailding Separintendent D. Askland, Varehouseman .

J. Morrison, Project Ent,ineer

• i J. Young, Hanger Engineer ~

A. Sir.ior., Administrative Superviser QA R. Irish. Administrative Asistant, QA H. L'inJysist , Material Control Supervisor l' . S - Nhlear R*;;ulatory Co--issien (Region I!!)

"C. E. Orelius Directt r, Division of Engineering & Technical Prcgra s k S. Little, Chief En gineering Inspection Branch L M a regor, Senior Resident Inspector, Braidwood L Co.< , d e r. r e t a r y

^:.a mts these presor.ne: attending the exit reeting held at the USNRC htar,n 11I office on May 7, 1982. During the inspection at the Byren St.n:ca exit meetings were held on a daily basis in order to keep the Ite:ntee infermed of any findings.

Th. inspniers also contacted and interviewed other licensee and certract:r persennel during this inspection. I T

1. }it 6 tim or i regt a Aters Inspected

a. En.ral Isciground

'he purpose of this special team inspection was to deterette if t!.eru are indicatiens of existing or potential construction prot.ees similar to some of those identified at a nueber of other 7 ptar.ts under construction. The scope of the assesseents included q'iality assurance trograo interfaces and overviews, corrective 1 a*. tion systems, design change control, raterial traceability of

• a.st311ed structures and cerponents, electrical cable installa-t t o!. . inprocess in pectfuns, and effectiveness of quality certrol inspectors.

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3.!:_

Prerared By: J. M. Peschel P. Keshishtan

b. Ord'rng r am Interfar. s and Overview (1) ,0uality Assur;pce ?!anuals Reviewed Pittsburgh Te:, ting 1.aboratory Quality Assufance Manual itQA ?!-1, Revision 4, September 21, 1979 Po. ors A:co-Pepe Quality Assurance Manual, Revis:en 3, Dc: ember 7, 1981 Cc monwealth Edison Topical Repert, Revisien 20 Tetruary 17, 1952 Jc.'.nson Contd 1s, Inc. , SECD Quality Assurance Pregram, Kevision 0, J:.ne 29, 1978 Hatfield Electric Cer.pany Quality Assurance Manual, F.evision 9 August 13, 1979 Ebasco Nt. clear Cuality Assurance Program Manual, Revisien 10, September 30, 1981

, Ha .ter Cerporation Quality Assurance Manual. Revisien 5, Aug;st 1, 1951 l \

Nu: lear To.er Services, Inc. , Quality Assurance ':anual, he.*isten 1. J m sry 13, 1951 T.eliable Sheet ! ctal Vorks, Inc. , Quality Assurer.ce ':ar.ual, July 21, 1981 (2) Preced.:g s Reviewed (a) 3 C --enwes!th Edisen Cc--any

,B,yyn Quality Inst ruct f en (801) 201 1, Revision 2, March 22, 1982 Ceneratina On Site Quality Instructions BQI 7.1, Revision 2, March 22, 1982 On Site Contractor Non Cenformance Reperts BQI-7.2, Revision 5. March 22, 1982 QA Handling of Ceco Non Cenformances SQl 9 Revision 6 March 22, 1982 QA Handling of Field Chanae Requests 3QI 10 Revision 4. February 23, 1982 Site QA Handling and Review of On Site Contractor Procedures A

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BQI-11.1, Revision 4, March 22, 1982  !

Byron Site QA Audits  !

g- BQI-12.1, Revision 1, March 22, 1982  ;

Installed Equipment Surveillance Instructions i

1 BQI-24 Revision 1, March 22, 1782 ,

Byren QA Training Program ,

Byren Site Instruction (BSI) . [

B3I-5, Revision 5, October it, 1950 Material and Equipment Receiving. Re:e:'.:rg Inspeccion Storage, and Re:cval frc: St:r ga Instruction C;ality Precedure (QP)

QP, 2-1, Procedure for the Revision of the Qaality Assurance Madual - Engineering, Constructi:n and Operation, Revision 63, February 24, 1952 CP, 2-2, Training of Personnel to meet Quality Assurance Requirer.ents, Revision 63, February 24, 1952 QP, 3-3, Classification of System, Components, Parts and Materials, Revision 63, February 24, 1952 Q?, 4-2, Evaluation of Contractor's Quality Assurar.:e Program, Revision 63, February 24, 1952 QP, 5-1, Quality Instruction and Procedures, Revision 63, February 24, 1982 Q?, 7-1, Control of Procured Material and Equiprent, i Receiving and Inspection Revision 63 T' Tebruary 24, 1982 CP, 12-1, Calibration Control of Commonwealth Ed:s:n Test and Measurement Equipment, Kevisien c3, February 24, 1982 CS, 15-1. Reporting Quality Nonconformance during Constructien and Test, Revision 63 February 24, 1982 QP,15-2 Reporting incidents and Deficiencies that occur during Construction and Test, Res:szon o3, February 24, 1982 CP,16-1, Corrective acticn for Reportable Deficien:ics and Quality Nencenformsnees that occur dur:rg Construction and Tests, Revision e3, February 24, 1982 QP, 17-1, Quality Assurance Records, Revision 63 February 24, 1982 QP , 4 1, Request for Bid, Proposed Evaluation, and Recommendation, Revision 63, Tebruary 24, 1952 QP, 18-1, Quality Program Audits, Revision 63, February 24, 1982 QP,18-2, Surveillance of Contractor Quality Assurance Control Activities, Revision 63, February 24, 1982 i

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General Procedure 0

General ?rocedure No. 738, Site Buying, February 2,1981 (b) Patfield Electric Company Procedures Procedure #6, Revision 6, January 15, 1982 Reporting of Damaged or Nonconforming Material or Equipment' Procedurc #8, Revision 2 Issue 1, July 6, 1981 Audits  ;

Procedure #9E, Revision 6, Issue 1, January 22, 195; Class I Cable Pan Identification Procedure #11, Revision 12, February 2, 1982 Class I Cable Ter=2 nation and Splacing  !

Procedure st17, Revision 2, October 10, 1981 Qualification of Inspection and Audit Personnel Procedure n19, Revision 4, Issue 1, January 24, 1951 Equipment Turnover Reporting Procedure s:20, Revision 8, Nove:ber 20, 1981 Class I Exposed Conduit Syste=

Identification Frecedure #23, Revision 8, Issue 1, January 22, 1981 Concrete Expansion Anchor Installation i Procedurc v24, Revision 1, Issue 2, January 28, 1952  ;

Control and Calibration of Meters and Instruments

) Protedure C29, Revision 5, November 20, 1921 Pield Initiated Request fer 2es:gn Changes (c) Hunter C:rperstien Site Ieole-ertatien Procedures  ;

4.201 Revision 4, January 19, 1982

nstallation Verification 7.502 Revision 7, August 20, 1981 Control of Measuring and Testing Equ:p ent 11.101 Revision 4, April 28, 1981 Nonconformance Processing

'~

' 12.301 Revisien 5, March 19, 1981 Internal and External Site Quality Assurance Audits 20.513 Revision 9, June 8, 1981 Installation of Concrete Expansion Anch:rs (d) Powers-A.co-Pope Procedures QC-4 Revision 7 September 30, 1981

.Nonconformance Control QC-5 Revision 5. December 17, 1981 Site Audit i

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FP-3 Revision 9, December 22, 1981 Material Receiving Inspection Controls TP-4 3 Revision 5 September 30, 1981 ,

Material Storage

.') TP-11 Revision 7. January 21, 1982 Calibration and Control of Measuring and Test Equipment (M&TE)

(e) Pittsburnh Testing Laboratory Precedure Resident Internal Quality Assurance Audit Plan, Revision 4, November 17, 1981 (f) Johnsen Controls Inc., Procedures QAS-210-EY Revision 2. January 28, 1980 Auditor Training and Qualification QAS-211-FY Revision 2 February 5, 1980 i Training and Indoctrinatien Procedure QAS-710-FY Revision 1 September 19, 1979 On-Site Document Control Procedure QAS-1011-BY Revision 3 January 10, 1980 Weld Rod Control QAS-1210-BY Revision 1, Ocotober 30, 1979 Calibration Control of Measuring and Test Equipment QAS-1510-BY Rev2sion 0, April 17, 1979 Status Tag Usage Procedure

) QAS-1610-BY Rev:sion 0, February 13, 1979 Nonconformance Control Procedure QAS-171C-3Y Revision 0, September 18, 1979 Corrective Action QAS-1910 EY Revision 1. November 8, 1979 Audit Procedure SP-611-BY Revision 1, April 3, 1981 Tield Change Control Procedure (3) Audits and 'i.tce!!aneous Documentation Reviewed (a) Coe en-ecith Edison Coreany 7 Audit Rrrorts

1. 6-82-4

1. 6-82-08

1. 6-81-300

1. 6-81-308

1. 6-81-309

1. 6-81-330

1. e-81-331

1. 6-81-336

1. 6 81-340 as v

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1. 6-81-344

1. 6-81-354

1. 6-81-357

-]) #6-81-360 General Office Audit of Byron Construction Site.

April 30, 1981.

Geners! Office Audit of Byron Construction Site, November 8, 1981. '

General Office Quality Assurance Audit of Eyren Station, April 30, 1981.

General Office Quality Assurance Aud:t of hyren Station, November 8, 1981.

Manageecnt Audit at LaSalle, Byren, and Era 2d-Ocd Construct ien Sites and the LaSa;1e Operating Stat:::.,

April, 1931, by Energy Incorporated.

Miscellanaeus Docurentation Sitc Mechanical Organisatien Cnart, March 16, 1952.

Site Electrical Organization Chart, March 16, 1952.

Site Stru:tural Organizatien Chart, March 16, 1952.

Site Project Construction Organi:stien Chart, March it.

1982.

1951 Byrca Site QA Audit Schedule, Revision 0 and Revision 9.

1951 Byren Site QA Survie11ance Schedule.

Byren Quality Assurance Organizatien Chart, March 22.

-} 1962.

Byren Quality Assurance Status Reports, January 5, 1952 and Tebrusry 4, 1982.

Byren Site Quality Assurance Semi-Menthly Repcrt fer December 1951.

1952 Byron Site Quality Assurance QP Training S:heda:e (b) Hatfield Electric Company 2 Audit Reports

1. S1 02

1. 61-18 FEl 19

1. 61-20

1. 62-04 Audit Report of Byron Site Procedure 5, 6 and 22 by Energy Incorporated, September 21, 1981.

Follow-up Management Audit Report by Energy Incorporated, September 21, 1981.

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,p*7 Trend Analysis Reperts ,

1. 2, July 24, 1981, 2nd Quarter of 1981

1. 3, November 6,1981, 3rd Quarter of 1981

) #4, 4th Quarter of 1981

1. 1, March 25,1982,1st Quarter of 1982 Miscellaneous Documentation ,

Discrepancy Reports , " Trouble Letters" No. 's 640 - 670, 650 - 720.

1981 Audit Sche'dule 1982 Audit Schedule Quality Assurance Audit Log Me=crandum from C. Van Lyssel to V. Brock cencerning Quality Assurance Organization, March 17, 1982.

(c) Hunter Corporation Audit Report No. 084-4 Miscellaneeus Docu entation Audit Summary Tcurth Quarter Audit Report Follow-up Audit #1 Hunter Audit Sum sry Report for Fourth Cuarter,1951.

g Hunter Cc poration, Byron Site Quality Assurance Audit, June 3, 1981.

Hunter Cc:ptratien Quarterly Noncenfer-ance Rep:rt C'3 ;

Sumcary a.tc Trend Analysis, December 29, 1951.

7 (d) Pe ers A::e-Pere

• Audit Reaerts

1. 52 Septetber 29, 1981

1. 53 October 1, 1981

1. 5; November 12, 1981 v55 Noveeher 12, 1981

1. 56 November 16, 1981

1. 57 November 15, 1981

1. 58 Noveeber 25, 1981

1. 59 Deeweber 3, 1981

1. 60 December 29, 1981

1. 61 Janusry 27, 1982 Hanegement Review Audit, Byron, March 17, 1982

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...p Misc.c11ancous Docurentatfon

) Veel.ly Storage Surveillance Report, March 10, 1982 Veel.ly Storage Surveillance Report, March 17,.1982 Weel.ly Storage Surveillance Report, March 24, 1982 Veel.ly Storage Surveillance Report, March 30, 1982 (e) Pittsburrh Testing Laboratory Audit Rererts -

1. 81-21

1. 81-22 ,. .

1. 81-23

1. 81-24

1. 81-25

1. 81-26

1. 81-27

1. 81-28

1. 81-29 '

Internal QA Audit feBY-3 Internal QA Audit f*BY-4 Misec113recus Docu~entation Pittsburgh Testing Laboratory Organi:stien Chart Pittsburgh Testing Laboratory inspetters Eye Exa-ir.atien Eccords

) (f) Jetteen 7:: trols , Ir:erperited Aedst Per rts Yeanly QA Pregram Audit No. 00501, May 16, 1980 Yearly QA Program Audit No.10801, August 5,1981 Audit Report, Bensenville Office, Septexber 15, 1961 Nent.cnformance Reperts

1. CO*BY November 14, 1980 hC023Y Neverber 14, 1980

1. C032Y Decerber 4, 1980

1. CO BY August 19, 1981

1. 0055Y Tebruary 23, 1982

1. C068Y March 25, 1982

1. 0078Y April 2, 1982 (4) Interviews with Site Personnel Interviews were conducted with sixteen personnel from Cor. mon-wealth Edison Company, sin personnel frm Hunter Corporation, 9 three personnel from Po6ers Asco Topa, three personnel from d

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c ., .e Hatfield Electric Company, two personnel from Pittsburgh Testing Laboratory and one person from Johnson Controls, Incorporated.

} .

(5) Licensce's Quality Assurance Program (a) Ob_lectivo The ob,)cctives of this assessegnt were to deter ane:

that the licensee's Quality Assuran:e Prcgra .

including all amendments, has been a;;r:.ed by 'JR.

if the licensee has control of changen t: the '

sut..itted Quality Assarance Progra.t.

if the Quality Assurance '!anual is consistent with the approved Quality Assurance Pregram.

(b) Dis:ussten The ins;ictors reviewed:

L the licensee's Topical Report, CE 1 A, Revisten :0, and determined that the original program and a!!

suit equent revisions have been a;; roved by STsR.

The licensee submits all changes to NRR and I ine;udes minor or typographical changes at the sa c t tre as substantive changes are sutettted.

L the licensee's Quality Requiretents anc 0.s'.ity Precedures and determined that the licensee initiated and controlled changes to the pr:gra-thrcush QP 2 1. The procedure requires the sa e ,

lesel of review for a QA Program change as the original program received. The program has pro-visions to input a change due to feedback of experience, regulatory requirements, codes and star.dards, audits, and reviews.

J., the licensee's Quality Assurance ?fanual and referen:ed deci.ments to determine shether adeqaate QA r:ars and precedures have been established (written, revne.ed, approved, and issued) to implement the docketed CA -

program. 7ne reivew indicated that the 18 Crateria of 10 CTR 50, Appendia I were addressed by the '

Quality Procedures of the Quality Assurance 'tanual, The inspectors reviewed 6 of the 25 Quality Assurance Planuals assigned to Syron Station to determine they were of the latest revisions. The following eanuals here reviewed and no problems here detected.

.A 13 c.;4

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, v (t Manual No. Assianed To

• 111 Project Construction Superintendent

) 203 Byron Station Superintendent 177 Ceco 0AD Supervisor 191 Byron Station Maintenance Supervisor 62 Jyron Station Technical Staff Sepervisor 115 Byron Station Quality Assurance Super-intendent fn) f

%. ! i t v .M u r an.c Pregis _o, f , Cont ra e t e r s

, (=) [hl"tives The obje:taves of this assessment were to determine if the licensec has approved and routinely audits the Quality Assurance Programs of centractors for consistency with 10 CFR So, Appendix 3, and to determine the current status and effectiveness of licensee management of the on-hite Quality Assurance Programs.

(t ) Discussten

• The inspectors reviewed documentation, conducted extensive intervi is with licensee and site contractor persennel, and reviewed pertions of the licensee's and contracter's CA manuals to determine levels of staffing, organi:stiena independence from cost and schedule, positten descr:pta:ns,

) and to determine if the status and adequacy of the OA

'i Progra s were regularly reviewed by the licensee and cent racter s management, At the time of inspecticn the licensee had 13 centracters on site and each was performing safety related wc k under

' their own specific Quality Assurance Programs (QAPs).

These QAPs had been submitted to the licensee for review and appreval The licensee had reviewed and approved the QAPs priir to the contractors start of work. The >

lacensee was fully aware of its ultimate responsibility for sfte Quality Assurance and had its own QA organiza-tier, on site to mon 2 tor the activities of the varteus site contractors through the mechanisms of surveillan:es and audits.

Table 1 is a matrix of licensee and on site centracters performing safety related work indicating the areas checked and compliance with these areas.

Eencoe21 since (454/52 05 0!a: &$$/82 04 01a)

JO CFA 50, Appendia B, Criterson 1, requires that "Such Persons and organlaations performing quality assurance functions shall report to a management level such that

.A C-25 L.

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• ,s~ ,..w ? p -

this required authority and organizational freedom, intluding sufficient independence from cost and sched le

} when opposed to safety considerations, are provided."

Contrary to this requirement, the inspectors found that

g. . . " the QA Hanagers of both Hatfield Electric Company and

" Powers-A:co-Pope (PAP) reported directly to on-site managers who had direct responsibilities for cost and schedule for their respective contracts. The Hatfield QA Manager renorted to the Vice-President and the PAP QA Manager reported to the Projact ':anager.

3 Unresolved Item (454/82-03-02; L55/82-04-021 u

In addition to the forege:ng, it appeared tha: the CA Representative for Johnscn Controls had pr:dut ::n respons:bilities that also conflicted with organ::sti:nal independence. A review of the activities of F:::shurgh Testing Laboratories (PTL) indicat-s that there is no PTL on-site QA organization other than a s::e aud::::

and that for a substantial period of time each L.eek PT*.,

activities are not under surveillance. This cond::: n oc:urs because there are two shif ts for PTL inspect:rs and only one aud:ter.

The questions regarding Johnson Controls and PTL could no: be resolved during the current inspection and are an unresolved item.

) (7) L,; ten *ee "anage ent Assess ent of the Cuality Aw rr:e t r a-(a) C!;j,e : t ive w The objective of this assessment was to ce:er=:ne if a periodic assessment of the licensee's Quality Assuran:e Program is conducted by Co:.monwealth Edison Company upper level management.

I (t.) Discussion The inspectors reviewed audits of the Byron Construct on site conducted by a General Office Audit Team. These set:-annual audits are supplemented by a bienn al aud::

conducted by an independent auditing organizatien. The audits cover the entire scope of the Qual ty Assurance Program and are reviewed by upper level management.

The licensee's Quality Assurance organizatien is headed by a site QA St.perintendent. He is assisted by two Supervisor's who direct the activities of thirteen CA Engineers and Inspectors in monitoring and auditing the activitics of the site contractors. In addition four Pittsburgh Testing Laboratory personnel are au f gned to the organization for specific decoment a: ion 3 related assignments, k

15 C-26

TS. .'

4, . , .

Each engineer and inspector is assigned a specific list of responsibilities so that all contractor activites and other QA monitoring systems are fully covered. This

) type of organization should be able to effectively monitor site QA activities. However, the execution of the program is not satisfactory, as evidenced by the many problems uncovered by the inspectors. One factor (2 affecting the execution is the stabil.ity of service fer tha QA personnel.

A kcy individual in a QA Program is the on-site s.;er-intcndent. He has the direct responsibility for the QA performance of the contractors and other plant 1 related a:tivities. It is he who anticipates pret:e-arecs, sees to the training of his staff, directs the act2vitics of his staff and is instrumental in prcduc:ng a quality prodtet. Since January 1976 there have been f avo QA Superir.tendents at the Byron Site:

J. fizzies January 1976 to May 1976 D. Jeritz May 197e to August 1977 R. Cousden August 1977 to May 1978 T. PcIntere May 1978 to January 1981

• M. Stanish January 1951 to Present In addition to this undesirable condition, the QA Engineers and Inspectors have an average on-site serv::e time of approxima ely fourteen months and have lietted

') prier QA expertence. Part of this on-site tace was  ;

spert in tra ning and qualifying for various CA duties.

Ir. additien to this problem, canpower is current!) te:rg sent to a:her sites so that the QA effort is substant: ally scaveneil. Out of a staff of sixteen, three me.. ha.e been, and currently are at other assignments:

R. J. Sch.artz La Salle Station 12/7/81 to 2/19/82; J. S. Hale 3/19/81 to Present La Salle Station 1/8/81 to 2/26/82; 3/19/82 to Presen:

P. J. Nod enski Quad Cities Station 9/14/81 to 9/25/81; Syron Pre op Testing 4/5/82 to Present The constant change over of personnel resulting in a min: mum experience level and transfer of personnel could '

hinder the QA organization in meeting its obligation of ef fec:ively implementing a QA program.

In contraat to the experience level of the QA organ-1 ration the inspectors made a review of the stability of the supervisory and engineering personnel in the const ructior, organization. The key individuals and scrs ice time at the Byron Station are: '

.1 r

16 C-27

o

• ~

e Wh . '.*E .

, e ..

Tl_tle Name On Site Since 3 Project Superintendent G. Sorensen 1976 J Assistant Project R. Tuetken 1977 Superintendent Lead Civil Engineer J. Mihovilovich 1975 Lead Meclianical Engineer M. Lohmann *1981 Lead Electrical Engineer J. Binder 1978

• Six years prior experience as a Mechanical Engineer at La Salle County Station.

The pronounced difference in site time and experience level indicates there is the potential for a pt:ble.

with QA personnel continually being transferred. In an effort to determine the cause of this potential problem a meeting was held with the Corporate Manager of Quality Assurance, V. J. Shewski, on April 16, 1952.

His explanation was the the transfer of the QA Superin-tendents was for promettenal opportunities in four cases and a death in the case of one superintendent.

' Mis explcnatien for the large turnover and inexperience

' lever of the QA Engineers and Inspectors s:ss that he desired to seed the licensee departments with CA experier.ce.' persennel and also not deny them prem:tienal

, opp:rtunities.

This con tant change over of QA personnel as centrasted

} to the stable and experier.:ed work force of the construc-t.on gree.p indicates the need to create greater prce:-

~ tional cpportunities ir. the QA crgantastion, or the need to have re c sort of system instituted to requ:re ",A peraennel t'ocacquire minleur service tiee at nu:' ear sites Th'e inspect 5:s reviewed the training that was given to Ceco QA rersonne'. af ter they had ceepleted corporate

~ '

qualit) tssuranc'e iraining. The Byron QA training as

'I

' an en-the-jeb type training and is intended to sup;1e.

ment 'the corporate training and enhance the develep ent of new QA persont.e1.

A review of BQI 24, Revision 1, Byron QA Training Progro,levealed that although the stated purpose of

^

the intruction was to' provide the necessary training

..? to approtraste per,onnel as quickly as possible, there was no specified le'g.h of time in which the training n

'was ti be completed. A lack of prompt training was a finding annotated by the General Office Audit of C

November 1981. A review of en the-job training records rev aled that prompt training was still not being act'p'plished and that the corrective action to prevent g w, 9 Y*

17 C-28

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F .. -

s.

o -h * :s *g recurrance stated in the audit response, was not being effectively implemented. The on the-job training system had no provision to alert supervisory persentel when a now employee's training was lagging. ,

O SQI-24 also states. "It is the new employees respons-ibility to obtain and maintain the required training,"

It is our belief that the training of new employees is a managerent responsibility and cannet be delegated to the new tmpicyee. .

Attat.h ent A to SQ! :!- lists fourteen areas cf trsar.ing, and specafic indisiduals are designated as 4.thert:ed trainers in ea:h area. There are no less:n plans ::

othnsee's Topical Report and they indicato adequate j in+ pendtnce for the CECO Quality Assurance Organizatien. Further inspection resulted in concern regarding the activitics of the Project Construction Department that t  ? .5 ) g 16 C-29 L i . , . ^ ^ ,. , s., - . - t , w .. ' ~ ~ , . v > 4 , 4. % , - y. . - . .. .p.g . , f, .. . , , , .N_. . g, .v s. - ,

• _~,

, . . , . .- -s ' f4 + 8 i appyai't'6'be'contraryto10CTRSI,AppendixB, Criterion  ! I,,regarding the independence of the Quality Assurance effort from production. Theslicensee's site Project Construction Department  ! is. organized with a Manager, Technical Staff. Project

• Engineers and Tield Engineers. The inspectors inter-viewed four supervisors and the assistant superin- l tendent of the consiruction group and found each of i them'to be knowledgeable and experienced engineers I fully capable of meeting their respective resp:ns-ibilities. They all fully recognized the importance of quality assurance and control and were dett-rm:ned to. build a quality plant. .

,The respensibilities of this group include: ' 'S  ! s. Advisor to Engineering 'for design suitabili y for constructability. ' Cuo:dinate requests for field revisions. Receipt and storage of materials. j Assist Project Engineering in' development of s ove:all schedule. l N Verify conferrance and torpleteness of contra:ter's  ! installation to specificaiion requirements. Suptrvise and approve mechanic _al and structura! ( "~eonstruction tests. ' g . _ _ Coerdinate and provide assistance for ele:::::al 7

t. construction tests. i-

.,-,-Coordinate preoperation tests. i ! Tt' .e Projcct Constructien QC Supervisor and Project Constructica Electrical Supervisor have engaged in Quality Assurance activities independent of the Byron Superintyndent of Quality ' Assurance,4n'd the offsite Manager of Quality Assurance. The lidensee could not produce a position descriptfor.-for'the areas of r sponsibilitie's-ind the duties of the Project , l Construction QC Supervisor. An example of specific t C QA activities engaged in by these supervisors is: i sletter of November 13, 1981 from the Elec:pacal i and QC Supervisors to the on-site Vice Presider.: of Hat field Electric Compa,ny suggesting duties and responsibilities of the QA/QC Manager and a l- _ suggested organization chart. ' , i i The activities of the two supervisors in QA activities . ! appears to be contrary to 10 CTR 50, Appendix B. Criter- ! ion 1, that requires independence.of QA supervisors from cost and schedule. In addition, it seriously undermines l the effectiveness of the incumbent QA Superintendent e %. l u e. r 5

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7 to monitor the activities of the site QA organizations. .gtThe activities of these two supervisors resulted in a .,'reorganization Department of the Hatfield Electric Company QA/QC - } that was not described in the QA Manual. . ,, We believe that CECO QA should, at a minimum, be in-volved in a review and concurrence capacity when such - suggestions are made to contractors.

s. p . -

In addition to the foregoing, a furthe' r problem with QA independence from cost and schedule arises in that the site Project Superintendent has final centrac:usi approval for some contractor QA organizat: ens centern:ng sal try increases, procotions, and hires for QA ncn manual peraonnel increases. The requests for such act: n frem Hatfield Electric Company and Powers-A:co-Pepe do n t have a centurrence from the contractors Quality Assurance Department and ccmc from the project construct:en 2nage-ment. The follcuing list indicate salary changes or pre ::::ns of QA inspectors for site contractors that were approved by the site Project Superintendent. Date Contractor Position 2/24/82 Powers-A:co-Pope QA Specialist 12/3/81 Hunter Corporation QA Inspectc 11/23/81 Hunter Corporation QA Inspector ' 11/3/81 Hunter Corporation QA Inspector 11/5/81 Hunter Ccrporation QA Inspector , The inspectors reccgnize that the Project Super:n:erder.:s' / resp:nsibility for contract administration requ res h:s final approval for contractors staff size and changas in compensation, however, a question of satisfy:rg the re-quirements of 10 CFR 50, Appendix B, Criteria I relative to QA independence arises. Mechanisms are currently new in effect for such independence in that the Pittsturgh Testing Laboratory contract is administered by the Corporate Quality Assurance Manager who is independent of cost and schedule. Npy1:ompliance (454/82-05-01b; 455/82-04-01b) The latk of andependence between the Qual 2ty Assurance Department and the Project Construction Department is in violation of 10 CTR 50, Appendix B, which states in part, "Such persons and organizations performing quality assurance functions shall report to a manage-ment level such that this required authority and organizational freedom, including sufficient inde-pendence from cost and schedule when opposed to safety considerations, are provided. - M-A ) 20 G C-31 I . g - ~ V

• 4 ,

Open Item (454/62-05-04: 455/82-04-04) O The involvement of the Project Construction DQartmen in Quality Assurance Activities indicates the need for ' } an Interface Document or Interface Procedure ta explain r the interaction of the licenset t Quality Assu ance Organization with the Contractor's P :lity Assurance e Organizations, and the relation of the Project Con-struction Department to all on-site Quality Assurance Organizations. . U)) Qualitv Assurance Remonsibility (a) Objective The cbjective of this assessment was to determ:nc if the licensee has the prime responsibility for est at::s!.- ing and executing the Quality Assurance Program. (b) Discussion The inspectors reviewed the Topical Report and the Quality Assurance Manual and intervieued the licensee's Corporate and Site Quality Assurance Managers and the Quality Assurance Manager of selected contracters. The decumentation review and the interviews sh: ed that':he resp:nsibility of the licensee was estatlished, decu vnted and understood by respensible pers:nnel in both the licensee's and centactor's organizat: ens. The irspectors were concerned about the lack cf a pel:cy staterent from upper management that went heyend the explanation provided in Quality Requireren: 1.C and pr:- vided assurance that upper management of CE~o supporte: the Quality Assarance Program and it objecstves. (10) Licens.ae Oversight of Contractor Activities t (a) Objective The objectives of this assessment were to determine if the licensee has effective oversigh: of centractor activities and has detailed knowledge of these activities. (b) Discu=sien 'lh e inspectors conducted interviews with Quality Assurance personnel from the licensee, Hatfield Electric Company, liunter Corporation Powers-Azco-Pope, Johnson Controls, Inc., and Pittsburgh Testing Laboratory. These interviews were supplemented by the review of related quality assur-ance procedures, audits and documentations; tour of work l l 21 C-32 r itn3 with ,. areas, warehouses and fiald effices; and discusa&a a result si tha ..s . f*9b4j -- . licensee and contractor personnel. has a ~4*NN" i above the inspectors determined that the i htlicensee of program that should provide an effective he man-overs gThe ability of contractor activities. provide this oversight is questionable f this due Assessment to t report power limitation discussed in the "Licenseeof the and the findings noted below. i Contractor QA Manuals tractors, 9 A review of the operating organization of two con Inc., Hatf ield Electric Company and Johnson ot described Centrols, revealed that the present organizations he Senior were n l ty Jchnson Controls, Inc. , changed the title of t QA Representative associated withce Byren Manager f rem the Qua Assurance Representative to the Quality Manual.Assuran nths and did not update their Quality Edisen Coepany AssuranceJchns - - , with this discrepancy, and Commenvealthaware of the discrepancy. Quality Assurance was not l Hatfield Electric Company was operating with a Qu Centrol Supervisor to the Quality Assurance Manager ance beth of whom report and who are not reflected in the Quality Assurto The reason for this disparity is a letter Manual. frem the licensee's Project Construction Vice-President suggesting Department ' the Hatfield Electric Company an cirgani:stion change. 455/82-04-01c} "The Scntoreliance (454/82-05-Ole: 10 CTR 50, Appendix B, Criterson I states, i tions authority and duties of persons and organ lated za i (? performing activities af fecting d in the safety-ref shall be clearly established and delineate wr it ing. " have its The f ailure of Hatfield Electric Company to Quality Assurance Manual reflect the d is actual Quality Assurance Organization is contrary to the above an an ttem of noncompliance. its The f ailure of Johnson Controls, Inc., toandhave Quality Assurance Manual reflect the actual Quality Assurance Organization is contrary to the above is on item of noncompliance. - 22 , ~ , C-33

• g. -

y ** w 7" The licensee has indicated that the above conditions have been corrected. These items will be examined during future inspections.  ; } Saf. kcginJ of Quality Records , A tour was made of the combined vault used by Johnson  : Controls, Vestinghouse-SAMU, Midway Industrial Con- , tractors, Ebasco Services, Inc., and-Reliable Sheet Metal. The safes of Westinghouse SAMU and Midway ' Industrial Contractors the door of were found the vault. Theunlocked Vestingheuse and with no attendant at safe contained computer tapes which were desertbed to  ! be non-safety-related and the Midway safe contained i quality (records. Nonterpliance (45a/S2-05-05; 455/62-04-05) , 10 CTR 50, Appendix B, Criterion XVII states, " Sufficient [ records shall be maintained to furnish evidence of act-ivities affecting quality." ANSI N45.2.9-1974 states, "A full time security system shall be established to preclude the entry of unauthorized personnel into the lar:eny storage area. This system shall guard against , and vand:lism."' The failure of Midway Industrial Contracters to 1cck  : a s.1fe centaining quality records is contrary to the ' abote and is an item of nonce:pliance. l The lice: sce has indicated that this situation and the conJttic:. of the Vestinghouse-SAM *J saf e have been L correctec. This item will be examined durtng a future inspectu n. the Pcwers-A::e .:pe Dur ing teurs of the ce=bined vault , and the li-vault, ti.e Hatfield Electric Company. vault entrance h::es censee's vault, the inspectors noted that and other such piping had not been sea;ed l for conduit , i and possible air paths from the exterior existed. I 455'82-04-061 - l'nreselved item (454/82-05-06: states that permanent and temp =rary ANSI N45.2.9-1974 records storage facilities shall be constructed to ' I_ protect the content,s, from possible destruction by fire. The inspectors are concerned that with thethe possible Halon Systemair paths arcund conduits and pipes that may not te able to extinguish a fire. The licensee has indicated Thisthat itemaction has been taken will be examined to correct this condition. during a future inspection. I Q _;L l ! 23 i C-34 f . . . l .ji- . .3 C' .y G ~

- L.*" .

ff'y - - u. Surveillances The inspectors reviewed the licensee's Quality Assurance ) Department 1981 surveillance schedule and noted that approximately seven percent of the scheduled surveil-lances were not conducted and there was no documented reason for their omissio'n. The licensee did conduct approxim1tely 800 more surveillances,than were scheduled with an cncrease being made in some areas due to prob; ems discovered or to follow up on audit findings. We recogni:c that such increased attention is necessary, but are concerned about the omissien of surveillances without substantiating documentation, as surveillances are one of the intergal methods by which the Qua:ity Assurance Organization provides an overs:ght of ccn-tractor activities. Open Iten (454/80-05-7; 455/82-04-7) The inspectors are concerned about the omissien of scheduled surveillances without substantia:ing d:cu-mentation. The licensee indicated that this item will be corrected. This itte will be examined during a future inspec::en. Drawing Centrol The inspactors reviewed selected drawings in the en-s:te ) cffice of Johnsen Controls, Inc., and at Hunter Ccrpera-tion's Dacument Station 1-H, at the 4:6 level :n the l centainment. Twelve drawings were closed at Jchnsca Cen:: Is, and :f those chosen one was not the latest revisien as ind:ca:ed en the Sargent and Lundy master drawing lis: located in the CECO Quality Assurance office. Drawing M3393, Page 4 of 12, was Revision B and should have been Revision C, which was issued February 12, 1982. The M3393 drawing series is not marked to indicate how many draw:ngs are in the series but are annotated as 1 of " blank". Ten drawings were reviewed at Hunter Corpt,ratien's Document Station 1-H, at the 426 level in the contain-rent, and of these two drawings, CS-58 and RH-15, were not the proper revisions according to the Hunter Engineering Department master list. Hunter Corporation personnel explanined that the drawings in question were for work on the Unit 2 containment, which had been stopped, and all related drawings were supposed to have q7 been recalled to docvment control. Hunter instituted an immediate recall of these drawings. A 24 C-35 a /\n- _ _ _ ~ , -

• '*2 f '_

, .? .g eft. ~' **' Noncompliance (454/82-05-08; 455/82-04-08) 10 CFR 50, Appendix B, Criterion VI states, " Measures shall be established to control the issuance of docu-ments, such as instructions, procedures, and drawings, ') including changes thereto, which prescribe all activities affecting quality." The failure of Johnson Controls, Inc., ar.d Hunter Corporation to control the issuance of drawings is contrary to the above and an item of noncompliance. The licensee indicated that the condition has been corrected. This item will be examined during a future irspectien. Prouess Traceability The inspectors acccmpanied two CECO Quality Engineers, or.c electrical and one welding, on inspections in the '.' centainment, auxiliary building and the turbine build:ng to determine if they could trace the installat:en and irspection process on welds, conduit hanger installatien, ard cable pan installation. No problems were identif:ed. Qi.Jj i ty Assurance Procedures . I s;,ecticn identified that two on-site centractors per-fr-reing safety related work were using forms which were nct controlled by procedures. Hat field Electric Ccepany is utili-ing a Discrepa:.:y g Lc:t er, alr.o known as a Trouble Letter, f or datu- .t ;ng is cceplete censtruct ion, non-conf orming cc:.truct ion,  ; requirements for Field Change Requests and cther d:s-crepant 2:ces found during quality control inspect;cns. - These Trcuble Letters have been in use for arrr:x;-atcl;. the last 18 months and about 800 have been generated in this time frame. The Trouble Letters are used as an L intermediate document during inspections prior to cerrective work or preparation of TCRs and NCRs and do net become part of the quality records. Trouble Letters numbers 640 thru 670 and 680 thru 720 were examined and it was frund that in the inspectors opinion Trouble Letters o58, 662, 664, 669, 679, 696, 697, 700 and 721 should have been documented as non-conformance repcrts. As an example, in Trouble Letter 679, a Hatfield Electric Ccmpany QC Inspector reports a conduit strap backing plate that is not welded to a hangar. The failure to have a procedure for this Trouble Letter is contrary to Appendix B. A similar condition exists with the instrumentation piping installer, Powers-Azco-Pope. When making Quality - O A t 25 C-36 s .* ~ [ ~ c , gk .

g) . ,

Control inspections a Tabrication Installation Surveil-lance form, for which there is no prescribed procedure is used for purposes identical to the Hatfield Trouble Letter. } The inspectors examined TIS numbers 180 through 216 , and in their opinion a number of the FIS's should have resulted in NCRs. As an example Tls 186 reported items that were installed but did r ot have'the required heat numbers. We are net against the use of trouble letters or speed letters to expidite seme contractor functicas, hc-ever,

nspectien when these documents are used to docueent ,

discrcpsncies they must be procedurally con:rclied. Nenecepliance (45a/82-05-09a: 455/82-Oc-C9a) IC CTR 50, Appendix B, Criterion V states, " Activities af fecting quality shall be prescribed by documented  ; instructions, procedures, or drawings, of a type appro-priate I: the circumstances and shall be accerpl:shed in accordance with these instructions, procedures, or drawings." The f ailure of Hatfield Electric Company to utilize a proc.edure to centrol their Discrepancy Records is centrary te the above and is an item of noncompliance. , The failure of Powers-A:co-pope to centr:1 their r Sp Fabrication Installation Surveillances is centrary tc the ab:ve and is an item of noncompliance. The licensee has indicated that these cenditions have been corrected. These ite=s will be exa:ir.ed during a future inspection. Audits The inspectors reviewed audits that were conducted by ? the. corporate and site quality assurance organiza:iens of Commorwealth Edisen Company, Hatfield Electric Cempany, Hunter Corporation, Powers-Azce-Pope, Jchnsen Controls, Incorporated, and Pittsburgh Test:ng Laboratory. ' The audits were conducted according to an audit schedule ar.d the scope and content of the audits was acceptable. The audit reports censistently failed to include a 125t of persons centacted during the conduct of the aud:: and a sae=ary of audit results, including an evalua::en . statement regarding the effectiveness of the quality assurance pregram eierents which were audited, as required by ANSI N45.2.12. . ._A I 26 l C-37 j . iw y9s- . . . . . R. ~ # 7- . ... ~. a- - ~ ~ . - i 4 h, t /82/8_2-05-jo 04 @XVIII,455_ states-dthat a periodic au Neilcomp_1_ lance (454 and 10 CFR 50,system comprehensive Appendix of planne Brogram Criterionverify and to deter-compliance with a shall be carried out to aspects of the quality assurance pof the program. - mine the effectiveness repo'rts shall pro-acrissties states that auditcontacted during audit statement ANSI N45 2.12-1977 ding an evaluat:en vide a list of personsand shall have a sur. mary incluof the qua regarding the ef f ectiveness dited. gram elements which were au reptrts or the ': c aee. - Corper st :en. Oc. ~e ::ng Contrary to the above, the auditard ?: u.b.:f Hatfield Electric Company, Huntar include perse-s . : -*- A co-Pope Laboratory , Johnson consistently failedControls,to s Inc. ,and an evaluat:o tacted during the auditof the program e'.erents e Esl'uat cn ..., garding ef fectivenessin L:stheof examples 5:4:e e:.:listed below: Fersen:. Centacted Auditor Audit n No Yes Su 6-51-330 Yes Se CECO Yes 6-81-308 So CECO 50 CECO 6-61-336 Yes 6-51-357 Yes So CECO Yes ha 6-81-309 CECO 6-SI-3;a Yes 50 CECO 81-340 No No CECO ho 6-81-3C0 No CECO 6-S2-08 No No CECO Sc Hatfield 81-02 No - No ho Hatfield 81-18 Hatfield 81-19 No 5-84-4 No its Hunter None July 9, 1981 No Yes Hunter 00501 No No Johnson 10801 No b Johnson 52 No N:' PAP No N:' 54 PAP No ho 55 PAP No No 81-21 PTL 81-23 No PTL 81-25 PTL , acticn has been This ::taken <m The licensee has indicated thati n in future audits. inspection. , to correct this situat owill be examined during a fctu p h l ) 27 C-38 . ...e s..' ,.:.,..~ W. , f .

• ~-~^

NQ-T ' 4 g c- T - m. "* . .,. . l.$ . 4; ,, MeasurihcandTestEquipment ' The inspectors reviewed the procedure and methods for -) control of Measuring and Test Equipment used by Hunter Corporation, Hatfield Electric Company, Powers Azco-Pope, s Johnson Controls, Inc., and Pittsburgh Testing Laboratory and inspected various instruments in office and field , locations. , The inspectors identified no pioblems with Hunter Corporation, Johnson Controls, Inc., and Pit:sburgh Testing Laboratory (PTL). During a review of torque wrenches in the Hatf: eld Electric Ccmpany Quality Assurance office and the Powers-A.*.co-Pope Quality Assurance office the following iters were identified. . Hatfield Electric Company: The s:crage of terque wretches was not according to Hatfield Pr:cedure

1. 24 as the wrenches that were past the calibra:::n date were not red tagged and they were stored en the same shelf as wrenches currently in calibra:icn.

HE-151, HE-142, and HE-135 are seme of the untagged, uncalibrated torque wrenches stored with calibrated wrenches. . Powers-Azco-Pope: One torque. wrench TV-4, was ) marked as defective, but did not have a Reject Tag as required by Section 5.15 of Powers-Azco F:pe Procedure FP-ll, Calibration and Control of Measuring and Test Equipment (M5TE). Nencereliance (454 'E2-05-11a; 455 /82-04-11a) 10 CFR 50, Appendix B, Criterion V states, " Activities affecting quality shall be prescribed by documented l instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be ace:mp-lished in accordance with these instrue:: ens, procedures, 9 or drawings." The failure of Hatfield Electric Company to fellow its procedur.t st24, with regard to tagging torque wrenches, is contr:ry to the above and is an item of ncncerpliance. The failure of Powers-Azco-Pepe to follow its precedure No. FP-II, with regard to tagging torque wrenches, is contrar) to the above and is an item of noncompliance. The licensee has indicated that these conditions have been corrected. These items will be examined during a future inspection. -A \ 28 I I- C-39 =., , y: ' r Eghb-,r.'. E-o Purchasing, Receiving and Storage The inspectors reviewed the process used to obtain safety g related material starting with a material request gen- -J ersted by a contractor and culminating with storage in a warehouse. The inspectors noted no discrepancie's in the requesting, purchasing and receiving portions of the project, but during tours of warehouse areas the C) following items were noted: In Varchouse No. 1, safety-related equipeent was stat ed on shelves that also centained lumbc r. boxes of paper, scraps of rubbish and fe:d :n a housekeeping atmosphere that did not meet the requirements of Secticn 6.2 of ANSI Sa5.2.0. In Warehouse No. 5, a pallet of bags contain:ng charcoal type co pound was stored abeve safety related valves. One of the bags had broken ar.d the material had spilled onto the valves, shel.:ng and floor, and the housekeeping was not in accord-ance with Section 6.2 of ANSI S45.2.2. Nence oliance (454/82-05-11b; 455/S2 04-11b) IC CFR 5'[~ Appendix F, Cr :erien V states , "Activit:es af fecting quality shall be prescribed by documented instruc:: ens, procedures , or drawings, of a type appropriate to the circumstances and shall be accc p-lishad in accordance with .these instructions, precedures , ) or draw:::gs ." TI e cond::: ens maintained by the licensee in Vareh:ases Sc 1 and No. 5 were centrary to Quality Precedure 13-1 ar.d to the requirerer.ts of ASS! Sa5.2.0-1972, and are an item cf nencompliance. ] The licensee has indicated that action has been taken to correct the warehouse conditiens. This item will be i.xamined during a future inspection. In Verehouse No. 4, Pcwers-A:co-Pepe is 5:Oring I I' ma:cr:al that is tagged Eejected next to Accept and Hold material and is not segregated as re-quired by Section 5.6 of Powers-A:co-Pope Pro-( cedure No. TP-3, Material Receiving Inspection E _.___,e- ' Control. t Powc rt.-A:co-Pope is attaching a red tag that says " Safety-helated" to material that has also been tagged with PAP's Accept Tag. The red tag is not referenced in any PAP or Ceco procedure. u k . ) 29 9 C-40 I t - . '.$g* - lrg B 4 1. .. w f- ,s g g.:e.  % .r:. . j . v ? " ' Noncompliance (454/82-05-11c: 454/82-04-11c) 10 CTR (0, Appendix B, Criterion V states, " Activities ) affecting quality shall be prescribed by docum.ented in-structions, procedures, or drawings, of a type' appro-priate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings." , The failure of Powers-Azco-Pepe' to s:cre reje:ted material in accordance with their precedure No. T. - 3 is an item of noncompliance. The licensee has indicated that this cend::icn has been corrected. This item will be examined dur:rg a future inspecti:n. (31) Quality Assurance Staffing (a) Objective The objective of this assessment was to determine if the Quality Assurance Organizatiens of the licensee and con::seters are adequstely staffed. (b) Djscuss:en The inspt::ers interviewed personnel inv 1ved in the j mancgement of the licensee's and selected centra:::r's Quality Assurance Organ::ations; and appr:x:matcly la percent cf the Quality Control inspect :s employed by the contra: ors. Based on the interviews and a revie. of scheduled and cerpleted audits and surveillance the inspe:: ors were able to conclude tha: the Quality Assurance Organi:ations were supplied si:h sufficient manpower. The auditors of the selected organiza:icas were found to be adequately qualified. Qua'.ifications of Quality Control inspectors are discussed in deta:1 in the "QC Inspector Effectiveness" section of this report. o The inspectors do not believe that the Quality C:n:rol Supervisor for Powers-Azcc-Pope was qualified to be a Level II Supervisor on the day she was appointed to the pos2 tion, as she did not have the one year of Level I experience as required by ANSI N45.2.6-1978. This is discussed in greater detail in section h., QC Inspector Effectiveness. The CECO Quality Assurance Organization at Byron is fully staffed with 16 personnel, but the effectiveness of Quality Assurance section is being weakened by the A 30 C-41 e . u.,,..,. .~ .y .e . , 3 .i- G. .s  ?- deployment of Byron Quality Assurance personnel at La Salle and Quad-Cities. This is discussed in more ) detail in pargarph b.(7), Licensee Assessment of Quality Assurance Program. In addition to the above, one Quality Engineer was transferred to the Operations Quality Assurance section during our inspection and a replacement is not scheduled to arrive until June 1982. The transfer of the Quality Assurance' personnel to sup-port other programs is an area tf concern. (12) Trend Analysis Pregram (a) Obicetive ! The objective of this assessment was to determine if the licensee has an effective trend analysis pr: gram. (b) Discussicn The inspectors reviewed the trend analysis reperts cf the licensee and Hatfield Electric Company. Licensee trending of NCR's is discussed in detail in sect:en c., Ccrrective Acticn Systems. The licensee publishes an annual Trend Analysis Report which is a summary Of NCR's by problem area for each contractor dur:ng the previous year, and the Corrective Acticn System :s scheduled to be audited semi-annually. ) (:31 Cercli, .te Histerv (a) Objective The objectives of this assessment were to rev:ew the licensee's compliance history and the effectiveness of the associated corrective ac:fon. l (b) Dyscussion The inspectors reviewed the licensee's history of nentoepliances, unresolved items,10 CFR 50.55(e) C Reports, N R's, IE Bulletins. IE Circulars, and IE Information Notices and reviewed the systems used to ass gn responsibility and to track the resolution of the probitm. A review of all 10 CFR 50.55(e) reports and 30*, of the noncompliances showed that the correct:ve act;en was appropriate, with the cause identified and act;on taken to prevent recurrence. NCR's and their resc,lution are discussed in detail in section c., Cctrective Action Systems. Enc;.t as ncted, within the areas in ;pected, no items of non-compliance or deviations were identified. 31 C-42 w- .- . . s.: .,4&l, r.% , .. ,,

• • Q .

• ' 4:. ' ..  : - RM e.

Prepared By: R. S. Love '), c. Corrective Action Systems v ' (1) Objective The objective of this assessment was to determine if: (a) corrective action procedures are adequate. (b) responsibilities have been adequately def:ned ini thi; the affected personnel have beer. trained and 4. de- .: ar i the procedures. (c) procedures are being effectively implemented. This includes the areas of tracking and clesecut, t"'  ; of nonconformances, and upper e t,r agenent 's int-!'. t-e i (2) Discussion I (a) Co- onwealth Edisen Comoany (CE0o) 1 Procedure Review A review of CECO Qual:ty Procedurcs QP No !; 1, Revisien 5, dated January 20, l'181, and Q? N 1:-I. t Revision 5, dated December 29, 1980, ice....it. - that  ; they appear to be adequate as rel t:ng to C77 . :::ve Action. ) Adverse trends and problem ares:. art 5:- .ht ~.c attent:o: of the Vice President (Na:;r r ;, - . ns . Manager of Projects, Project Manager a:: " i.a- cf l Quality Assurance.

2. Review of NCR Log The inspector reviewed Ceco's Non:enfor.taace Ee; ort ,

(NCR) log for the years 1979, 1980, and 1981. 1  ; was observed that for the year 198;,10; Schs ere ' prepared and Hold Tags were applied in 96 inst:ntes. In the 5 instances where Hold Tags were not arpl:ed; the item was controlled by a Subcontratt::s ts; or the NLR was generic in nature. 3 Review of Open NCRs The' inspector reviewed eleven open NRCs that were prepared during 1980. The following is a status of these NCRs. a F-491, dated April 7, 1980. There is an open 50.55(e) report on this ites. b 32 C-43 5 *' w b; T-488, dated March 27, 1962. Th:s NOF was g sent to Project Constructien Depart ert (T":) J on May 15, 1980, for amplenes.tatinn of t h-disposition. - c; T-526, dated June 27, 1980. This NOR n-still at Station Nuclear Erg:n,eer:ns < ; 12 * - ment (SNED) undergoina evaluction d; T-539 dated July 22, 1350. Th:s '.' - at SNED undergoing ev.iluatier tr:. -- mation rece tved by the NRC ::.spet: t . : . i.e: cables have been tere;nated and : r. .: si: on a " Work can Procee.!" n: tat :.:n en n. *'. e; T-544, dated August 8. 1962. Th:s %"h ~ .t'. at SNED undergoing cvilustien.

f. T-546, dated August 11, 19SC. There :> -

open 50.55(e) report on this ite=.

g. T-563, dated October 22, 1950. This N2~ -as sent to PCD on August 27, 19 51, f e r ir; ' t c n t a -

tion of the disp:sition. h; T-565, dated November 5, 1982.  !?. : s '. : :s still at SNED undergo;ng evaluat:cr.. ) i; T-575, dated November 26, 19F3. This N~r. was sent to PCD on January !, 195!, fer implementation of the disp:s:t::n 1 T-577, dated December 8, 195~ This 50.; was sent to PCD on February 13, 1951, fer implementation of the disposition. k; T-582, dated December 12, 19E0. This 5;h was sent to PCD on Ju!y 14, 1951, fer :erle - eentation of the dispositicn. Open Item (454 /P2-05-12: 4tS'P2 ni-101 The SRC is concerned abo SORS that rt:::n c;: for an extended period of time in that as the fuel-load date approaches, there may be a ter.de ey to accept items without preper enginecting eval a-tion, including back-up data, or to accept s t em.- .) that should be reworked or repaired. Pending r+ vies of the action taken to close the NCRs listed at:se, this is an open item. 1 33 C-44 9 s . s~' % g's ha. t' - _y, . d'.

4. Review of Voided NCRs

) The inspector selected six voide d NCRs f er -a- to. The subject procedures do not address vo.dtr; N. but this is an accepted practice in the 2 rid;> : t. when the NCR is voided for just cause. a; NCR T-597 was missing from the' QA Ret.crd, Vault. The NCR log indicated that tne Nk s was prepared on January 27, 1951 to 1:r.- that Pump Motor OCC01P tc m:nat: ens wc:e leaking. The log indicstes this NCh was voided on April 13, 1981. b; NCR T-600 was missing from the CA Ricerd-Vault. The NCR log indicated that the N~- was prepared on February 6, 1981 to d:.i. . ,t some damaged cables. The log ind.catcs ' NCR was voided on April 3,1931. c; NCR F-634, dated Mare! 23, 19S1, was pre;a ect to document a minimum '-end redius v::: si ..:5 on cable IRM119 and to poir.t out that t! cause of the bend radius violation was the the we2ght of the cable pulled the ler; m.- of cable tray. ECN 1992 was issued to Jt; a device to prevent cable 512ppage. Tre - ) was volded on July 24, 1961, without at evaluation of the subject cable. T! ,- s. .e had an inspection /evaluat:en perfor d. - . . - 1 cable on April 7, 1962. Ctb;e w.is a.:.,- 't. d; NCR T-645, dated May 7,19f1, was prop a .' to document that Vestinghetse furn::.hes s . : - meters installed on various panels sup; . . t . by Systems Control did not meet the l'. te?"r-ance requirements. The NCF was voiard on June 3, 1981. Systems Contrcl Ictter to Commonwealth Edison Company, datad A.g. - 19 1981, stated in part, "The vattmeters u;:1 be returned to Vestinghouse fer reps.r at thrar expense."

e. NCR T-650, dated May 18, 1981, was prer ated

.to document certain nonconferming har.gers This NCR was voided on June 3, 19S1, btuause - it was being tracked on Hatfield NCE u:96. "' f: NCR T-682, dated October 2E, 1981, was pre-pared to document that concrete had been placed next to a pipe, resulting in a weld on the pipe becoming unaccesreible for inspec-A 34 C-45 t n- 1 v .. . .. - - - ,.a " . . n- - ~ tion under ASME Section XI. ECN 23' . ta ec December 8, 1961, was issued to en!a a d., ') opening around the pipe so the we,Id s;2:4 :s accessible for inspection. The NCR was .c:ied on December 16, 1981, because the ECN -e..el..id the problem. Nonce oliance (454 '82-05-13s; 455 /82-04-110 The items listed in paragraph2 c 2d andf[~a'::e ' are examples of improperly voided nen::n'-- r e For item c2 the issuance cf the E2N 1792 - a good corrective action to prevent recurrence t.: did not resolve the bend radius v:o:a::en Ter item d2 the return of the instrum:nts te so-: .;- house for repair was a gocJ resolutica to tne problem, not reasening for void:ng. Aga:r. the issuance of the ECN 2336 was satisfa ::ry res . .: .r: to the problem identified :n item f, n-t a r s .. . to void the NCR. Improper void.ng cf tFo N.. :s an item of noncompliance with Criterion ::" =f :: CTR 50 Appendix B. r

5. Review of Closed NCRs On April 1, 1982, the Regi:n II: inspe: tor re...aed the following N2Rs for preper c:osure arl f:: .:- ,

rective action to prevent recurrence: T-562, dated October.14, 1982, r!: sed .an :ary ' . ;9'. T-627, dated March 24, 1981, c osed Jan.ary c, ;-:2 T-635, dated March 24, 1951 closed June 22, 17!; T-656, dated June 12, 1951, clor.cd July 21, 193; T-673, dated August 17, 1951, closed January 19, 1952 r T-687, dated January 8, 1952, closed February :e. Ici: T-653, dated Octcber 2,1951, c1csed Febr.ary :1, Ic3, i

6. Revice of Trend Analvsis On April 1, 1982, the Region III inspector re;:e ed  !

the trend analysis of NCRs prepared by CECO. T .ts trend analysis is preparad by the Projects En;:nacr-ing Department (off-site). Reports dated J.n :: y 5. 1981, March 19, 1981, Sept,5 b er 17, 1951, 0 : 'er 22, ' 1981, November.. 12, 1981, De'cember 17, 1981. January 12, 1982, January 20, 1982, and Teb.23r. ;7 1982'were reviewed during this inspection. A!! ef the aforementioned reports had the notation "Na trends are evident" or "No trer.ds could be iden.4f:ed CECO QA (on site) does perform a trend analy, - en contractor's nonconformances. On the trend solly is .' reviewed, they agreed with the nnalysis bein,; per-formed by the individual contactors. A 35 C-46 .. , . .w .. ~' . Wy,; - y -- '3 / , ,,4  % ._ a . A. , %; ,+..' ~ ~ v. . %  :& . .r.

• s.

. 7. Interviews with Personnel ') Interviews with Ceco persennel indicate that they appeared to be knowledgeable in their own F,ro.*d res on Corrective Action as well as their contric or's procedures. (b) Blount Brothers Corporatien (Bl:unt) - 1; Procedure Review Blount utilizes a Deviatien Report (OR) Syster versus an NRC system. If a DR requ:res CIC: Project Engineering approval, Ceco transcr:Ns the information from Blount's DR onto a CIC, NC3 which is then forwarded to Project Eng:ncering for approval. A review of Blount's procedure number 4, Inspe ::en Nonconformances and Corrective Action, Re is::n 3, Issue 9, dated February 12, 1981, indicates that it appears to be adequate as relatir.g to cerra : ion action.

2. Review of NCRs The inspector selected several DRs f rom the D' g log for a detai:ed review for proper clesure 2:. i corrective action to prevent recurrence. Tel:-- ng is a status of these DRs:

a. Q3.;a5, dated July 7, 1950. C1csed Oct:: 6r 14, 1980.

b. Q3-508, dated November 22, 1980. C : sed January 22, 1981.

c; Q3-505, dated December 1, 1950. Cle=ed February 23, 1981. d; Q3-494, dated August 25, 1983. Closed Ju:.e 2, ~ 1981. e Q3-545, dated October 19, 1951. As of April 2, 1982, this DR was at CECO for final approval for closure. On all DRs reviewed, for years 1950,1951, and 1982, the action to resolve the noncenfor. Tan:e ar.d the' steps taken to prevent recurrence appeared te be adequate. . l 1 0 -l C-47 36 ... ->. +. % ~ %;~ * ~ e- .,-- 1 .,. . ,  : t.'. , y - s' ,  ;- ~

a. .

3. Review of Trend Analysis

') Per Blount's procedure, trend analysis er" :. i-niented annually but a running count of I:! .. . . n . b. in each deviation area which results in n cen i.r:as trend analysis. The trends noted by the in.po .ur had been documented on Blount's trend ann'y:.is report. These reports appear to be giver 6 . d .. distribution and includes a cery *.o CE.:c 4 Interviews with Persennel Interviews with Blount persenne! Ind:: ate- : L .i t the QA Manager was relatively ncs on ::.e pres s:. but appeared to have an adequa:( knowledge cf the procedures. The inspector .as in;resse :' v., - the knowledge displayed by the OC Inspector as '- pertaining to the DRs reviewed and the ccrre ct :ve action' system in general. (c) Hunter Corocration (Hunter) 1_ . Precedure Reviews A review of Hunters Site Inple entatica Ir:ceduces Nu=ber 11.101, Nonconfermance Pror.ess:ng. Rc us.:n 4, dated April 28, 1981, and2:ates :h.1: 2: .:r e_r> ) to be adequate as relating to cerre:t:ve a : ns

2. Review of NCRs The inspector made a general resiew of .=;r .s. .te:3 30 NRs and a detailed review of 10 NR3 f: pr.p-r closure and for corrective actien to preser- : e < *.r r -

ence. Following is a statis of the NCRs that ...re reviewed in detail:

a. NR-099, dated May 5, 1980. Closed Is r:r-i. r 6, 1980.

b. NR-132, dated July 22. 198C. This NR sas r re-perly voided on August 4, 1960.

c. NR-119, dated July 15. 198C. Clcse: en December 15, 1960. -

d. NR-193, dated January 25, 1981. C1csed en March 18, 1981.

e. 'NR-263, dated September 17, 1981. Clesed or.

October 14, 1981.

f. NR-151, dated August 4, 1980. Closed on February 16, 1981.

3 NR-159, dated July 3, 1980. This NR was pro-perly voided on December 2, 1980.

h. NR-204, dated March 17, 1981. Closed on April 15, 1981.

.A 37 C-48

a. . . . a . m.

e.yy ~' % . . - , 4 y- .gy3.Q;.c,n:::e- . ' 4 ." g ,

4. .-

g,4 .~.,~ . ~..r. < .et . 1. NR-231, dated June 5, 1981. Closed on August 21, 1981. } j. NR-262, dated September 11, 1981. Closed on November 24, 1981. *

3. Review of Trend Analysis The inspector reviewed the noncenformance (NF)1og for the years 1980, 1981 a,nd 1982. It was cbserved  !

that with the way the NR log was prepared, a trend would be observed. The inspector selected :-o attributes (unqualified welders and held points byp_ssed) and perfor=ed a trend analysis for the years 1980 and 1981. A review cf Hunters trend  ; analysis for the same period of time indicated ' that the two analysis (Hunter's and the inspector's) ( were compatable for the two attributes selected. Threugh training, unqualified weld NRs dr:pped f rem 11 in 1980 to 2 in 1921 and bypassing of hold pe:r.:s dropped from 23 in 1980 to 11 in 1981. Hunter recrgnizes that th,ey still have problems with hc!d  : p o i:.t s .

h. Inttrviews with Persennel In:crviews with Hunter personnel indicate tha: they ,

I appeared to have a good werking knewledge of the:: sys:em and procedures. Their system and applica:1e procedures appear to be adequate. (d) Powers-A::0-?:ce (TAP)

1. Procedure Review A review of PAP Field Operating Procedure ".mber QC-a, Noncenformance Control, Revisien 7, dated Septe-ber 30, 1981 and PAP Quality Assurance Manual, Section B-8, Nonconforming Material and Parts, Revision 1, dated October 22, 1981, ind: cates that they appear to be adequate as relating :e Corrective Actaen.

2. Review of NCRs Thc inspector performed a general review of approx-imately 30 NCRs and a detailed review of 13 NCRs and 11 Corrective Actions Requests (CARS). The following is the status of the NCRs reviewed in detati:

d 3, C-49 . . . .tg , ,. s -- . . 1

• 1;.

. i Q: a; NCR 14, dated July 25, 1980. Closed August 1, 1980 g- b; NCR 19, dated September 18, 1980. NCR was un- / acceptable, with the note - see NCR.2'. .O c; NCR 20 dated September 30, 1980. Closed October 1, 1980. d; NCR 23, dated September 21, 1980. Closed June 24, 1981. f; NCR -4, dated April 3, 1981.' Closed Apr:1 24, 1981. - g; NCR 39, dated,Tebruary 27, 1951. Cicset March 4, 1952. h; NCR 55, dated June 1, 1981. Closed A c.s: 13, 1961. i; NCR 71, dated February 13, 1951. Closed , Nove=ber 16, 1981. J; NCR 73, dated July 15, 1981. C1csed Jul 24, 1981. k; NCR 81, dated July 31, 1981. Closed November 9, 1981. Re-instructicn was re u red as part of corrective action. la NCR 90, dated Sep: ember 10, 1951. Cicsed January 6, 1982. m; NCE 117, dated November 20, 1981. CI: sed December 28, 1981. N:n,:- eliance .'454 /82-05 -11d : 455/82-Ca-::d* Of :ae 13 P -ers-A:co-Pope .NCRs rev:ewed :n deta:1 T 12 of the NCRs did not centain any correc::ve a::::n to prevent recurrence which is in viciat::n ef FAF's Quality Assurance Manual, Section S-5, Rev:s::n 1, date! October 7,1981, Paragraph 13-S.5.2. The 1:- censee was infer =ed that this was an iter cf n:n-compliance with Criterien V of 10 CTR 50, A;;end:x S. 3; Review of CARS and Trend Analvsis Of the 11 CARS generated by PAP as a result of their trend analysis, the corrective a::ica appeared to be adequate. ~ 4 2nterviews with Persennel Interviews with PAP persennel indicate tha: they appeared knowledgeable in their system and pre:edures. (e) Hp,tfield Electric Co pany (HECo) 1; Proctdure Review ! The inspector reviewed HEco Procedure #6, Report:ag l of Damaged or Nonconforming Material or Eqaip ent, J 39 C-50 F , ri" . 'L - b w, 3 . '4 ' " N Og 7 '. ; ], ... W y , Revision 6 dated January 15, 1982, and Section XVI, Corrective Action, Revision 5, of the QA Hanual. During review the following observation was =ade., Noncenpliance (45h/82-05-09b; 455/82-04-095) The only reference to corrective action to prevent , recurrence in the above mentioned procedures is in Section XVI, Parastaph 2.4, of the QA Panual. This paragraph discusses corrective action for adverse audit findings. The NCR form in use at the fyr:n Station, as contained in procedure 6, has a se:: ten tit;ed " Action to Prevent Recurren:e" but there is no directions in the body of the pro:edure fer this scetion. Tallure to assure that applicable regulatory re:;u:re-ments are correctly translated into precedures and instructions is an item of non:cepliance w::h Cr:ter-ion V of 10 CTR 50, Appendix B. L Review of NCRs The inspe::or rev:ewed appreximately 150 NCRs f : pre;er closure and for corrective acti n to prevent recurrence. The NCR log in use when mest of the NCRs were prepared did not provide a descr:ptien of the noncenformance, resulting in a larger number of NCRs reviewed'. The following observa:1:ns -ere 1 esde. a_ NCRs 98, 99, and 100 vere prepared :: d::u-ment a violation of concrete expansien an:h:r . (CIA) edge distance. The NCRs were vei:ded en February 25, 1960, because an TCR was or w:11 be issued to accept the CEAs as installed. One TCR (2500) was not issued until July 16, 1960. By voiding the NCRs, they were re eved from the trending system. Af ter this was po:nted out by the NRC, the contract:r pre-pared NCR 432, dated April 9, 1952, to docu-een: the items originally contained in NCRs 3 98, 99, and 100, b_:, NCR 168, dated March 2, 1981, documented that a cable was deformed at routing point 18993. CECO engineering evaluated the cable and dis-positioned the NCR as " Remove, Damaged Cable" and pull a new cable. Hatfield made the decision, without CECO's concurrence, that the subject cable did not need to be replaced. The NCR was closed on August 22, 1981. .a 40 C-51 O . _ __ _ _ _ . _ _ _ . . _ r y ~ . 1 -- e ,. .. . . .

,. *n. .

. v~ s4 * (3 c; NCR 154, dated February 24, 1981, documents that cabics trW441, trW482, and 1DC198 were g damaged and the disposition was to replace the / cables. Review of records indicate that cable 1DC197 was pulled out and scrapped on June 4, 1981 instead of cable 1DC198. The NCR was closed on June 4, 1981. A review of cable pull cards for cables IDC197 and,1DC198 indicated that 3DC197 had been pulled and scrapped en June 4, 1981, and that IDC198 was init: ally pulled on July 24, 1981. On April 6 195:. the HECo QA Manager corrected the s.t;c;; N .' and the attached documentatien. d; SCR 107, dated March 21, 1950. C:osed November 21, 1980.

e. SCR 97, dated February 20, 1930. C1csed August 21, 1981.

f; SCR 152, dated February 23, 1981. C1csed June 24, 1981.

g. NCR 164, dated March 2, 1951. C1csed g August 15, 1981.

h; . hCR 160, dated Tebruary 16, 1981. C1csed September 3, 1981. I

1. NOR103,datedNarch6,1950. C!csed January 8, 1951.

12 NCR 184, dated March 4, 1951. C1csed J.r.e 5, 19S1. h; NCR 177, dated March 4, 1951. C1csed ': arch 23, ?981. The inspector reviewed 42 NCRs generated bet-sen September 15, 1981 and February 15, 1952. The fol:owing is a status of the dispositien of tre sub,iect NCRs: 23 - L'se-as-is, FCR issued 4 - Repair the item 4 - Open as of April 7, 1982 3 - Volded 2 - Replace the item 1 - FCR issued to add side rails 1 - Reject the item 1 - Reorder replacement item 1 - Retrain the cables a 41 m . . .s. ~ ' _n - - m- . 1 - Closed - Being tracked by CECO NCR 1 - Clean the item 3 42 Nencomplainee (454/82-05 13b; 455/82-04-13b The licensee was informed that items a and b (? above are additional examples where NCRs were improperly closed / voided and is an item of non-compliance with Criterion XV of 10 CTR 50, Appendix B. - 3; Review of Trend Analysis A re.iew of Hatfields trend analysis for 19E: a r. 1952 indicates that it was adequate. 4 Interviews with Personnel Interviews with HECo personnel indicate that they appeared knowledgeable in their precedures ar.d system. Execpt as noted, within the areas inspected, no :tems cf nencem;11 ante er deviations were identified. 1 I 42 C-53 g;~ ,t -  :,w . r.... - ,p:.-.; - .a. . . , . - . a

l... ;Y A '

Prepared by: H. H. Vescott

d. Design Change Control

} (1) Objectives The objectives of this assessment were to ascertain that, site design change interfaces are clearly defined and i - picmented, design change control is , adequate, persennel ur.derstand and use appropriate procedures, and that the precedures are being implemented to assure the timely r(vising and distributien of drawings. (2) Discussion (a) Review of_qA Manuals and Precedures The inspector examined QA !!anuals and leplementing Procedures as follows: L Nuclear Power Services, Se: tion No. 3 Revis1:n 1, dated December 30, 1980, " Design Centrol".

2. Pcwc rs-Azco-Pepe QA !!anual Section B.1, Rev si:n 1, dated October 7, 1981, " Design and 00:utent Centrol".

L Hunter Corp = ration CA !!anual, Section 2, Revisien 5, ) dated August 1, 1951, " Draw:ng and Spe:ifi:at:en Cen:rc1". L CEC: QA !!anual, Quality Requirement, QR No. 30, Rev2sions 1, 3, 13, and 18, dated Decerber 29, 1960, December 29, 1980, September 9, 1950, and December 29, 1980 respectively, " Design Centrel" 5_ CECO CA ?!anual, Quality Procedure, QP No. 3-2 t h r t. Revision 13, dated November 12, 1951, " Design Change Control". L Johnsen Contrels. Inc. , QA !!anual . Section 4, l Revision 0, dated June 29, 1978, " Design Centrol". L Byron Site Instruction No. 20, Revision 8, dated g- December 17, 1981, " Instruction for Site Design ,. Document Receipt, Distribution and Control". ( 8. Byron Site Instruction No. 21, Revision 0, dated July 13, 1978, "ECN Routing". 9_ Westinghouse Policy / Procedure, WRD-OPR 3.0, Revision 2, dated ?! arch 20, 1981, " Design Control". 43 I t . gg . . 5:) . .. . . .e,. - 3 l . . . :y .. . ,, . A A g ~ ^'**'% .,,?'.

10. Westinghouse VRD-OPR 3.1 " Reactor Coolant System '

Design Definition (Power Capability Verking Group)" ~ Revision 3, dated March 22, 1981.  ;

11. Westinghouse Instruction / Guidance SMD 1.4, Revisien 4,. dated January 18, 1982, " Byron Unit I tngineering Change Notice".

12. Vestinghouse Instructien/ Guidance SMD 1.5, Revisien 0, dated October 31, 1980,' Eyren Cnit "Tield Char.ge Requests".

13. AZCC Tield Procedure TP-9, Revision 6, dated December 21, 1981, " Design Change Contrel" (b) Review of Audits of Site Contractors t

The inspector reviewed CECO's audits of site contracters concerning design change control as follows: 1; Sa^ gent and Lundy Nos. 6-81-301, 6-81-314, 6-81-339 and 6-26-07. ~ 2; Vestinghouse SAMU No. 6-81-317. 3; Pcwers-Asco-Pepe Nos. 6-81-326, 6-80-247 and 6-62-10. ~ 1 l 4; Nuclear Installation Service Ccrpany Nes. 6-51-311 and 6-50-251. 5; Hatfield Electric Company Nes. 6-50 and 6-El-231 6; Hunter Corperation Nos. 6-S;-09 and 6-B1-350. 7; Eletnt Brothers Corporation Nos. 6 45, 6-5.-294 and 6-82-02. 8; Jchr. son Contrcl, Inc. No. 6-80-250. 9; Hunter Corperation. Hatfield Electric Cerpany. Rel:able Sheet Metal Verks. Inc., Powers-A:co-Pepe '! Services, Inc., Blount Brothers Corporatien, Westinghouse SAMU, Pittsburgh Testing Laterat:ry, and Nuclear Insta11stien Services Ccepany l No. 3/8-10/82. (c) Review of Design Specifications r The inspector. reviewed design specifications as follews: l l A 1 44 i. - C-55

c. .

• 1

~ . ._ , r. .. 2 w e h' , e ,.< w _f.7t g ,.. v ' a ..4 7 x- ~ 'I ' " " [' 1. y Certi led piping ~ design specification for the -~ / "Outdcor Essent'(31 Vater System":. dated Tebr' ary 19, , 1982. . ~ <'. + , . E ,1 -~

2. Cert)7ded piping design specification for the

, >~ " Indoor Essential' Vater. System" dated December 14 1981. - .e' ,' .' '3~ . ,. ~ Cerlified desi 8n sPecificatica fer the " React:r r Yessel" ,e dated May 15, 1972. 4; ,DJsign Criteria for Category 1 Cable Tray, Cable ' Tray Suppoifs, Eus Duct Suppor:s, W.'AC Cuct Supp:::s, Conduit and Conduit Supperts, DC-51-03 EY,JP. It is noted that item 2 . ab'ove did net have the Pro- ,fessional Engineer's Seal for Certifica:fon. Sargent and Lundy further_ researched ten piping design specifi-cat ens and found three that did not beve the required seal. April 23, . These sere to be revised to intlude the sea'. by 1952. , ' /

• ~

s. < 1 .)'

' Review of Control of Tield chan[ 'Reeuests fr:E's- syd ir gj neer n.r Change Net ices ( ECN's) The inspe: tor randeriv~ selected" fifteen (15J TCR's ar.d ~

• ,thite (3) ECS's'at Pobers-Aito-Pope, seven (7) TCR's f at7dp,tfield Electric 'acmcany,i and 'three (3) ECN's a:

~) , Wes'idigh:ase SAM'J. . They Aere verified to be .nier :E:: centrol.- Additionally five (5) travejict p ii'r a ge s f:: in process welding were ver faed to havs !.e ::rra:: - draw:ng rev:stens in place. , The folle.'ing or'e the Yitals of TOR's' at ECN's issue: as of this' inspection; Electri_ cal TCR's 4,492 Mechanical TCR's 13,702 Structural TCR-s 101

• Mixed FOR's '

4,999 ECN's .- - .. 2.454 <* TOTAL 25,746

• Mixed TCR's contain all disciplines prict to separat:en

^ Er + ~ by discipline. . .~ / // '(e) Review Site Design Chenie Interface .The inspettor reviewed the following: . I A -- ,f .s ) , ~ > 45 - ,'~ . g- 'h. g# , w "a W ,. .'fh, .L,y # ; ~ -'h ~ 2 : j '- e: .. 1.. Interf ace Cont rol Agreement, Westinghouse Piping and Structural Evaluation Program for the Byron g i 1 Station Unit 1, dated October 13, 1980. Paragraph ' 4.3 states that, "The Byron Project Engineer 2ng Organization, as the Owner, has overall'responsi-bility for the activities described in this [ agreement." I 2; Flow Chart for routing CE;o Tie d Change Ecquest, Byran Site Instruction .No. 10, Revis::n 5. d:: d March 25, 1952. (f) Perser.ncl Interviewed The inspector interviewed personnel frem CEC , West:ng-house, Powers-Azco-Pope, Sargent & Lundy, Hatf: eld Electric:-Corpany, and Hunter Corperation. Within the a:cas inspected no ite s of nence pliar:e or deviations he ro identified. 46 C-57 w o . . /, .- , . . F- .. , .: -h .Ai-*Y b . \, ~ , . , . .,;. . W . - Prepsred,By: Er H. Nightingale ' ' g e. Material Traceability of Instelled Structurch and Cemoonents ..f .- (1) Objective' ' ' s <

• 3, ,

Th'e objective of this assessment was to determine that material trat.cability was maintained from. procurement through installatien for structural beams, small bere piping and wo; ding materials. g .'. s (2) Discussion ' Th5 "f 5110.cing centractors were involved and the:r areas cf resp 5nsibility are'as indicated: ' Hatfield Electric Company: Cable Trays Hunter Cerperstion: Small Bore Pipe Syste:r.s . Fewers-A:co-Pope: Small Bore Piping Systeds Blount B--ther Corporation: Structural 3 (a) H at field Electric Cemoliny f

1. Review of Procedures The followIng site procedures Vere resfeved:

s5, Class I Materials and-Equipment, Rece:vi g and Inspection .) , . f:12AA, Class I Shielded Metal' Arc Field Vel:Org . ( S . 't . A . F . W . ) fil2AB, Class I S.M. A.F.W. (Preie, dure Qual:f:ca-t'icn) , (!I2C,dualificationofVelders s fil2AZ Arc Velding Electrode Contro)~ L Revic of Records The documents reviewce for mater 2al traceab:!:ty were as-follows: Veld Material Request Material Certification . Veld Rod Reque'st' ' . Veld Data Sheet' . . Veld Material Issue Tag b b e- g . x - 47 s 1 , e . .Or ~ . .. ' .. "* s. - . , ,g , . , . ~ [- ,y .e . ' h ... . ~#' . - 3 Review of Velder Qualifiestion Th'e review of welder qualification records consisted ') -- of reviewing the original qualification reccrds as well as the supportive documents pertaining to their "up-date" qualification records. Hatfield Electric Company welding efforts are to AVS Code which requires six (6) month re qualification periods. The following welders had their certift:aticr. and qualification records reviewed: Name Welder 13.r . N. Larrabee VW C. V. Verner V J. A. Dickson .M.M Greene CG R. S. Glenny CT C. Stagg CS W. McVay BM D. Gavin DG T. White ==b TV F. Plegge FP These ten (10) welders are representatives cf the sixty (60) welders qualified by Hatfield an: are presently on site. i-4 ., Review of Veld '!aterial Centrol The review of weld material centr:1 precedures and dire : observation of in process ac 2v tzes indicate that sufficient ef ferts are being ir-plerected to assure material traceability and control. Oper. It em (45' '82-05-14 ; 455 /82 14) The Hatfield daily weld rod issue log did not indicate the actual time weld rod was issued and returned. The log only noted "a.m." or "p.e." The 1:censee has provided informa: ion to :nd:: ate that Hatfield form HP-13AD-1 has been revised to include provisions for the actual red issue and return times. This item will be reviewed dur:ng a future inspection. (b) Hunter Corporation l a Ressew of Procedures I 48 C-59 ~~ c . . .y W:4 - O cu ** g K 6#3 Q* if ; '.Y The following site implementation procedures were reviewed:' l.601, QA Procedures and Instructions '. 3.102, Material and Services Procurement 3.602, Material Received and Inspected 5.101, Weld Piller Material Control 5.201, Welding Procedure Qualification Control 5.301, Welding Qualificati.on 5.501, Weld Material Issuance 6.002, Visual Examination and Verificatzen 6.501, NDE

2. Rev:ew of Recerds

^ The inspector selected three (3) safety related small bore piping systems for review of materss! traceability. The review of the data packages conristed of docueentation from the purchase crder to 2nstallatien of the item. The systems inv:lved were as follows: . Safety Injection (3) Reactor Ceolant (2) Chemical Volume (4) The doc ments reviewed were as follows: ) . "aterial/ Services Request .'!ateri91 Receiving Report Receipt Inspection Checklist QA Documentation Requirements L.st Material List . Requisition Shipping Crder/ Packing Slip Material Certificate . SCE Request . Proccss Sheet . Weld Record . Material List Material Certification (t . Weld Material Issue Report The inspector reviewed data packages for the following small bore piping systems: _S_Y f. .T_L_M _S_P_O_OL PC ITEM KT # MATERI AL EET:RT 1016 S-CV-001 2 2" sch/160 462460 MSR 4967 1014-8-RC-001 1 2" sch/160 462460 MSR 4967 CECO S-R;.-001 105 3/4" sch/160 483245 MRR 9575 101--S-Sf-001 5 2" sch/160 462460 MSR 4967 lui S-SI-001 lb-5 2" sch/160 462460 MSR 49o7 .h 49 C-60 - 2, .w 1."OW- ..;a. [ +: .-e .. " ';4 : ' 3- .',q~

• f~

SYSTEM SPOOL PC ITEM NT # MATERI/ L REPORT 3 1016-S-CV-100 1-5 3/4" sch/40 462224 MSR 4967 / 1016-S-CV-100 8-7A 2" sch/160 462460 MSR 4967 - 1016-S-CV-100 9-8 2: sch/160 462717 $SR 4967 1065-S-SI-100 29-10 1" sch/160 HD7123 MSR 4967 The total footage involved consisted of 19,884' An expanded study of small bore piping was cade to :nclude valves and fittings. Data packages fer the following iters were reviewed: N A

• F. LOC CICN SYS'"EM SPCOL _MER Globe Valve IRC3039B S-RC-001-51 2 102B4 M.O.V. IRC3037B S-RC-001-51 2 10062 M.O.V. 1-SI-8871 S-SI-001 33 101'4 N'"E TYPE HT d SPOOL MRR CPL 3 Titting 2.0" 6000n S.S.-S.V. TL 2 4968 CPLG Fit:ing 3/4" 600C# S.S.-S.V. EGJ 2 5338

3. Review of Velder Ous11fication The review of selder qualifica:icn records cens:ste'd

- 'I of reviewing the original qualification reccrd as well as the supportive documents pertaining to the:r , "up-date" qualification record. Hunter Corpora:icn welding efforts are conducted to the ASME Ocde which requires three (3) mon:h re qualifica en pericds. Hunter Corporation routinely re-certif:es the:r welders in two (2) month periods to preclude any loss of certifications due to vaca:icns, illness, etc. The following welders had their certification and qualification records reviewed: NAME VELDER ID n R. Sturm D40 B. Strom B17 D. Colby ES2 R. Decker ' A38 D. Upstone T19 E. Laker E56 B. Burns E82 R. Bilyeu 391 M ()' C-61

e. .. ..:

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p. c .. -. - ; ,, i

+ NAME VELDER ID # 3I A. Arnold E48 V. Burdene C19 D. Radke A12 , L. Anderson 73 These twelve (12) welders are representative of the 237 welders qualified.by Hunter Corpora::en and are presently on site. 4; Review of Veld ?!aterial Control The review of weld material control pr:cedures and direct observation of in precess activities ind::ste L that sufficient efforts are being ieplemented to l assure material traceability and centrol.

• The documents reviewed for material tra:e bi:::y are as follows:

• Veld Materiai Stores Requisition Purchase Requisition Materials / Services Request Material Receiving Report Receipt and Inspection Check!:st  ;

Material Certificate T (c) Powers-A.co-Pooe 1; Review of Procedures The following Trecedures were revie-ed:  ! t . QC-4, Nonconfermance Control ' . :-, TP-2, Control of Procurement and Requisitten:ng of Material and Services i TP-3, Material Receiving, Inspectica Cen:rol . TP-5, Veld Tiller Material Control . TP-6, Material Handling  ! . TP-7. Transfer Package and Weld Recerd Centrol . WE-2, Velders Performance Qua!2fi:a: 1:n and [ Control

2. Review of Records The inspector selected three (3) safety related _

small bore piping systems for material traceabil:ty review. The review of the data packages consisted of documentation from the purchase order to in-stallation of the item involved. The systems - selected were as follows: l __a l l l 51 C-62 kY = .. - . .; 3 4 -~

• [**' **r(6 I c.3 '~p- ,

O .. ". .3,S. . Teedwater . Containment Spray . Reactor Coolant } The documents involved for review were as follows: . Veld Filler Material Requisition . Receiving Inspection Check-List Final As-Built Isometric (Supplement Veld and Inspection Record) . Material Certification Veld Rod issue Tag P.O. (CECO Responsibility) . NDE Records A study of the data packages, for the systems selected, consisted of the following items: NT # REC. & INSP. ISO-SYSTEM PIPE SIZE Rerert tt

0. 50" ' 462,444 MRKr; 707a 1 TIS-a183 RX Coolant 0.50" M51,577 RIRr! 040 ILT-Se:

Feed Water ILT-54 Feed Vater 0.50" D85,772 RIRn 040 0.50" E89,871 RIRu 040 ILT-5-2 Feed Vater 1FT-C5011 Con:ainment 0.50" 744-783 MRRrr *07e Spray Total footage of piping involved consisted cf :7,9:1' 'i The suppliers of weld material for the Syr:n faci!ity is Eur.ter Corperation. The pipe e.aterials are su;;11ed to the small bore piping c:n::a::::s by CECO. Therefere, purchase orders are cr:ginsted frem these two (2) sources. This system cf pur-chasing in large quantities by one contra:::r, licensee enhances material traceability. An expanded study of small bore piping was made :o include valves and fittings. Data packages for the following items were reviewed: FIELD REC & INSP. REPORT # I S 3't ITEM NTtt VELD # 41 057 IFT-R 0 9 Coupling EGJ IFT-403 52 131 90 Elbow OZ 11J-461 N/A 20049 Valve IFV048 S/N N11591 230 1FT-415 Valve IECO25E N/A S/N N11526 <? 4 1 52 C-63 o ."Q'A& % ,Q .. , v

s. A.. .;. . r . . -

.% ,f,h- ti . h- ~ "',' 8~ ~ , N '

3. Review of Welder Qualification

• 3/ The review of welder qualification records con-sisted of reviewing the original qualification record as well as the supportive %cuments per-taining to their "up date" qualificiation record.

PAP welding efforts are conducted to the AS."E Code which requires three (3) month re qualifica-tion periods. , O The follewing welders had their certif::.st:en ar.d qualification records reviewed: i l N3 e Welder IDn ' B. Strom CS R. Sutherland AF ' H. Arteaga DU ' L. Flynn DX D. Tucker BH H. Mitchell AJ R. Boyle BM D. Shurely CE P. Meyers DE V. Meyers DG These ten (10) welders are representative cf t!.e I 46 kelders qualified by PAP and are present . cn site. . L Review of Veld Material Centrol The review of weld material control proced_res an.4 direct observation of in process activtties ir?.icate that sufficient efforts are being i: pli-mented to assure material traceability and control. The documents reviewed for material traceability are as follows: Weld Filler Material Requisition . Receiving Inspection Chetk List Material Certification . Weld Rod.Tssue Tag . Weld and Inspection Record (d) Dieunt Brothers Corporation L Reva_ew of Procedures The following procedures were reviewed: a 53 C-64 ) .

. . .~ n

.*- 3 . .

e ,.3.- .

. QC 3385 #1, Document Control . QC 828 #2, Procurement Control } . QC 3012 #4, Inspection (Nonconformance and Corrective Action) . QC 3262 #7, Calibration of Tools, CGuges and Instruments Concrete) QC 835 #10, Receiving, Storage and Handling . QC 3333 #11, Velding - (Ak'5 D1.1) 1974 QC 845 #21 Structural Steel Erection . QC 1992 v33, Personnel Qualif::st:en and Certification L Rev:ev of Feccrds The inspector selected nine (9) structural bes s for material traceability. Beams selected *ere three from Unit #1 containment building and three beams from Unit #1 auxiliary building. Three more beams were selected from Unit #2 centa:n ent building. Bes: s selected were as follows: Eea- I.D. Building Uni n D-s i r 4 AO .~32 Containment 2 E-205 A 3J553 Centainment 2 E- ~5 g A: ..~ 3!1 Centainment 2 E-2 5 , A12:35 Centain ent 1 E-10; 511135: Containeent 1 E-10: E10-351 Containment 1 E i 3 3 3.~ 3 Auxiliary 1 E :11 326G1 Auxiliary 1 E-201 602E1 Auxiliary 1 E-::1 The inspector reviewed the data packages for the follo.ing structural steel for material tra:estility. Beam # 32631 - Film Roll 3 - Dr. n3 6 Index tt Heat # 551. 1. citer Oste 440 2K6969 12- E 76 435 J 31694 11-30 76 i 464 96266 12-26-7e 474 96723 11-29-76 461 63062 11 08-75 Mill B8 L511159 02 28-77 O leas a 33333 - Film Roll 3 - Dr. #333 s F 54 i C-65 O - .g. v' . 4- . . . " .. " ., . ). , , s E I '* ss ; - * ~$ ' _ , , , 3 - ~% Index A , Heat 6 S&L Letter Date T. 351 K-24080 11-10-76 / 474 96723 11-19.-76 Bear. OB104BB1 - Tila Roll 1 - Dr. #E104 C' Index a Heat e S&L Letter Dale 11133 69C076 06-29-77 11107 690050 07-01-77 90116 66C242 07-01-77 90127 69C167 08-10-77 801~3 63709 05-06-77 Bear MA230!B3 - Film Roll 1 - Dr. #A230 - 5:233 Inde d Heat n S&L Letter Date 38 70C576 02-07-78 62 K58219 02-06-78 K58377 02-06-78 573 747512 06-26-78 S-:: 87495 06-27-78 Bear etB111E32 - Film Roll 1 - Dr. us1;;3 Index n Heat n SSL Letter 01:e 11113 VYa703 07-01-77 1110e 70~266 07-01-77 ' 901*6 66C242 07-01-77 90127 69C167 08 10-77 8:1;3 63729 05-26-77 Beati vA:20B2 - Tilm Roll 1 - Dr. #A 20 Indcx n Heat # $5L Letter Date B-9 J-51717 12-13-77 S-43 44P489 07-19-78 P-1 A-325 Bolts 09 12-78 B-2 A-325 Bolts 06 09 78 Beam #A132B5 - Tilm Roll 1 - Dr. (lA13 Indix # Heat # S&L Letter Dste 80135 24456 05-26-77 C-80119 V35079 07-11-77 A-80190 3-34009 08-10-77 _.4 55 g C-66 4- - '* r- .w , yu * * ' - < + a, " %;i _ Q C"." - Film Roll 3 - Dr. #603

• Beam #603B1 Index # Heat # S&L Letter Date 1407 10005 03-04-77 287 18216 10-12-76 .

Begm #A240BB1 - Revised to Beam #E144-1 S&L Drawing S-1001, Revision H. , Dated 3-16-78 Note 10. Fabricated by Midcity Architectural Iron Ceepsny (on-site contractor). ' Heat c K62702 and #83833 A-325 Bolts - C6810; 4048 _3_. Review of Velder Qualifications The review of welder qualification records censisted of reviewing the original qualification record as well as the supportive documents pertaining to their "up-date" qualification records. Blount Brothers Corperation welding efforts are to AWS Code which require six (6) month re-qualification periods. . The following welders had their certificatica and qustification records reviews: . Name Velder ID_vJ \ K-5 K. Knaub R. Long K-4 P. Tadness P-4 E. Sullivan B-4 D. Lewer L-4 V-4 V. Thenpson W-3 K. Flosi V-18 R. Schusler K. Todo Y-4 D. S. Vielan D-5 f The ten (101 welders are representative of the fifteen (15) welders qualified by Blount Srethers 4 l Corporation and are presently on site. 4_. Review of Veld Material Control The review of weld material control procedures and J direct observation of in-process activities indicate that sufficient efforts are being implemented to assure material traceability and control. 4 1 56  ! C-67 r o

• * *""I VD .!* : r / I y-.

p +..... .,. g._h..c *'y q .s %. . .'*g...s .<- . - :w- .. . g . _' :- Q, _ p . c % D~, .,,~r. The documents reviewed for material traceability are as follows: ) ' Material Requisition Receiving Inspection Report Material Certification Veld Haterial Issue Sheet Weld Data Report . Within the areas inspected, no items'of no:.ce pliance er deviations were identified. . i i i 4 .T I F T l l C' i ( l i I I I I I s P l 57 I t C- R ' O h j i' Prepared By: R. S. Love i . f. Electrical Cable Installation (1) Objective ' r - The objectives of this assessment were to determine if: cable installation procedures are in accordance with TSAR commitments and that they are adequate for cen-trolling cable installation activities.  ! the cable installation persennel and QC inspecters have been adequately trained in this activity. safety related cables are routed, separated, and loaded in accordance with procedure requirements. (2) Discussion r (a) Review of Electrical Procedures The inspector reviewed the following Hatfield Electrical Ccepany procedures:

1. Procedure No. 5, Class I Material and Equipment Receiving and Inspection, Revision 4, Issue 1, dated January 26, 1981. This precedure was reviewed and accepted by Sargent and Lundy on T January 27, 19S1. .

2; Procedure No. 6. Reporting of Damaged and Scncen-ferm.ns Material or Equipment Revisien 6. dated January 15, 19S2. This precedure was revie ed and accepted by Sargent and Lundy on February 11, 1952. Procedure No. 9-A, Class I, Cable Pan Hanger Instal-3: lation, Revision 11, dated November 20, 1962. This and procedure was reviewed and approved by Sargent Lundy on December 23, 1981. ,

4. Procedure No. 9-B, Class I, Cable Pan Insta11atten, Revision 9, dated November 20, 1981. This precedure was reviewed and approved by Sargent and Lundy on- ,

December 23, 1981. 5 Procedure No. 9-E, Class I, Cable Pan Identificatien, Revision G, Issue 1, dated January 23, 1981. This procedure was reviewed and approved by Sargent and i Lundy on January 26, 1981. i . .. N,*P+ k I 58 i l C-69 l ,r . s . .. . - t  %,. ~

1. Mi M g.. rih!w..< M.7, ~ .. -,,

. ' ~~

• w

,* 6_ Procedure No. 10, Class I, Cable Installation, Revision 14, dated February 8, 1982. This proce- , dure was reviewed and approved by Sargent and Lundy ' ) on February 18, 1982. Open Iter (454/82-05-15; 455/82-04-15) . . . Procedurc No. 9-B, Class I, Cable Pan Installation, Revision 9, dated November 20, 1981,.did not address the installation of cable pan and riser covers. The inspector was informed that Procedure No. 9-C would address the installation of covers as required by the Byren/firaidwood TSAR. This is an open item. Unresolved Item (454/82-05-16; 455/82-04-16) Dar ng review of Procedure 9-E, Class I, Cable Pan Idcatification, Revision G Issue 1, dated January 23,  ; 1981, the f*.spector observed that paragraph 5.3.1 of the subject procedures states in effect that the requirerents to apply segregation identificatien to raceway at a minimum of every 15' does not apply to risers. This is contrary to the requirements stated in para,;raph 5.1.2 of IEEE 384-1974 Pending a review of installed riser identification markings for ccepli- , ance to requirements, this item is an unresolved ite=. l Non:orpliance (454tS2-05-09c: 455/82-04-C9c) l During review of Precedure No.10. Class I, Cable Installation, Revision 14, dated February 8, 1952, ) the inspector observed that the subject procedure does not address: i L the requirements to calculate electrical cable sid< wall pressure. Maximum cable sidewall pres- > sures are specified by the cable manufacturers, b_ ., electrical cable rework. Example - An electrical cable has been installed per Revision A of the cable pull card and Revision B of the pull card l requires that the cable be " pulled back" to a i giv(n point in the raceway system and re-routed to e different landing point. What precautions  ! are taken to prevent damsge to the cable being " pulled back" and to the cables remaining in the raceway. .This would be especially important wher. the esble was installed in conduit or duct banks. Another example would be that as a result of an NCR, a cable had to be removed (Ref. Hatfield NCR's 164, 154, 107). Failure to provide adequate instructions or procedures to accomplish activities affecting quality in accord-  ; ance with Quality Assurance Progras. provisions is an ..,. ., l m ( 59 i C-70 i , 7

a. .

l .f . ".. , , . - - w..e. ~ ites of noncompliance with Criterion V of 10 CTR 50, Appendix B. 3/ . (b) Review of Storage Tacilities - Cable Yard " The inspector toured the Hatfield Electric Company g cable reel yard to verify proper storage and to select several cable reel numbers for follow-up review of material receiving reports and vendor docueentat:en. The cable reels were stored on dennage (pl>-ced), ident:fie,1, and separated as to cable type. Ele:tr ual cable reet numbers 02146-409, 04146 215, 0226?-7, and 01115-43 were selected for records review. (c) Review of Electrical Verk Activities L During a tour of the power block the inspecter observed that the weld heat affected :ene ins:de cable tray 11774J C2E, located at the 439' elevs-tion of the cable spreading room, had not been touched up with zine rich paint in accorda..ce w:th Hatf: eld Electric Company Procedure No. 9-3, Class I, Cable Pan Installation, Revision 9, dated November 20, 1981. The licensee took imrediate action to have the subject area cleaned and galva-nexed. This was the only area identif:ed where the weld or heat affected zone had net been touched-up. L The inspector observed that ncn-safety reined pipe number TP-41 4-10" was installed 3 1,2" frem safety related cable tray number 111.elJ-22I. ~ These items are located in the Auxiliary E.:Id:ng between column lines 17 and P at the 42e' eleva-tion. Further investigation indicates that the fire protection (TP) system is classified as moderate energy piping and is seismically supported in the area observed. This appears to meet the intent of Regulatory Guide 1.29, Seistic Design Classificatien. L The inspector verified that electrical cable nurnber IVX105 w.ts routed in accordance w:th the cable pull card, Revision A. The subject cable is a 12c/14, 620V and was pulled from cable reel 12146-201. The cable extends from 1AT32E (H2C 132X5) to 1YX02J (Vent System Local Control Panel). The cable was physically verified in routine points ll4blJ C2E IR369 C2E, 1910T C2E, IR353 C2E, 11375H C2E, and verified that the cable entered the conduit to the equipment. M 60 tJ C 71 l_ o . .,. \.. 2 . f5;w.M-% y * . 4 e. J, . .A -h- - h  !

[ ~

v The raceway was accepted on January 18, 1982, and cable pul' led on January 19, 1982. 42 During discussions with an electrical foreman and one electrical craftsperson, the inspector observed that, with respect to cable pulling, they were very knowledgeable and proud of their work. The subject craftsperson assisted the inspector in verifying the routing of electrical, cable IVS105 (Ref. Para-graph (c)3 above). -(d) Raview of Procurement Docu entatien - Class IE Cat:e The inspector reviewed the procurement documentation C relative to 600V and SkT electrical cable. The inspe:ter reviewed the cable specifications, Material and E:;utp-rent Receiving and Inspection Reports (MRR), and vender documentation. '!he following observations were made: J. The licensee purchased the following electrical cable from Okonite Company to Sargent and Lundy specification F 2823. E Cable reel number 02146 409 containted 2500 feet of Oc/14, 600V cable and .as received May 11, 1981 on MRR 50:17.

b. Cable rect number 04146 216 centained 310 T

~ feet of ac/14, 600V cable and was re:e:u d April 22, 1963 on MRR 65c9. L Cable rect number 03356-7 conta:ned :t: (+et of 3c/350 MCM, 600V cable and was re:eived October 4, 1978 on MRR 4167. The following data was included in the on site documentation packages for the above listed cables: Certificate of Compliance , . Certificate of Conformance . Certified Test Report . Results of Water Absorption Test . Results of Ozone Resistance Test . Results of High Potential Voltage Test Sargent and Lundy letter, dated June 20, 1953, that acce ' Tests for,pted theBasic Design results of Flame Tests and Events. L The licensee purchased electrical cable, reel number 01113 43 from Okonite Company to Sargent and Lundy specification F2851. This reel contained C' 1094 feet of Ic/1000 MCM, $XV cable and was received , e I C-72 M ' ,, .. ..- Ng -' p* .' ' 3;.M ' . n . ,w '; . e' +z , 7 M* ' T s' Y " . w'.. * - ^* 3 f..*. g;6 4 . u: e.

r. . . ..

2

• n July 11, 1979 on MRR 7032. The following data was '

included in the on-site documentation package for , this esble: - . Certificate of Compliance . Certificate of Conformance . Certified Test Report Results of Water Absorption. Test Results of Ozone Resistance Test Results of High Potential Voltage Test Sargent and Lundy letter, dated June 20, 1950, that accepted the result of Flame Tests and Tests for Design Basic Events. (e) Rev!cv of Class 1E Cable Pull Cards The inspector reviewed 20 completed cable pull cards to verify that correct cable type was installed, raceway was inspected prior to pulling cable, and that QC accepted the cable pull. The following typical observations were made:

1. Cable IVX105 was pulled on January 19, 1982 frc=

Cable Reel 12146 201. Revision A to the cable pull card indicates the cable type code as 12146 which is 12/c-14, 600 volt cable. The raceway was accepted on January 18, 1982, and the cable , pull was accepted January 19, 1982. This was a 'h complete pull. 2 Cable IRC2:3 was pulled on April 9, 1951 frc= Cable Reel 02166-41. Revisien A to the cable pull card indicates the cable type code as C2166 which as one twisted pair, #16 (shielded), 600 volt cable. The raceway was accepted on March 27, 1981, and the cable pull was accepted April 9, 1981. This was a complete pull. 3; Cable IVC 019 was pulled on June 23, 1981 from Cable Reel 09146-84 Revision A to the cable pull card indicates the cable type code as 09146 khich is 9/c-14, 600 volt cable. The raceway was accepted on June 22, 1981 and the cable pull was accepted on June 23, 1981. This was a complete pull. Except as noted, within the areas inspected, no items of noncompliance or deviations were identified. e __g 62 C-73 e = ' l: . $ '3 , Prepared By: M. M. Vescott 3 In-Process insoection (1) Objectives The objective of this assessment was to ascertain that in-process inspection procedures are adequate and preperly implemented. . (2) Discussicin (a) Revdek of Procedures The inspector reviewed procedures concerning in process inspection as follows: L Powers-Azco-Pope Quality Control Pield Prncedure ' PP-7, Revision 6, dated October 16, 1981, " Traveller Package and Veld Record Control PAP Isometric and Installation Control".

2. Po ers-A:co-Pope QC-6, Revision 6, dated Ser: ember 30, 1981, " Quality Assurance Documen-ta :en".

L Hatfield Electric Cor pany Procedure 9-A, Revis:en 11, dated November 20, 1981, " Class I, Cab;e Fan T Hanger Installation". L Hatfield Electric Co=pany Procedure 9-B, Revisien 9, dated November 20, 19S1, " Class I, Cab;e Pan Installation". L Hatfield Electric Company Procedure 20, Revisien 8, dated November 20, 1981, " Class I, Exposed  : Conduit System Installation", L Hunter Corporation, Site Implementation Procedure SIP No. 1.601, Revision 1, dated March 3, 1951, " Quality Assurance Procedures and Instruct: ens". L Hunter Corporation, SIP No. 4.201, Revisien 4, dated January 19, 1982, " Installation Verificat:en". (b) Observation of Verk Activities ) The inspector accompanied two Hatfield Electric Company QC inspectors and observed their inspection of conduit hangers located in the control room. The inspector also observed the inspection and torquing of four concrete expansion anchors. 63 C-74 gh~ , .q f *' f, h J w '"~ . - - - ~ ~. ,, ' (c) Review of Records ') ~ The inspector reviewed records as follovs: ' s I; Hunter Corporation completed traveller packages for welds Numbered 45, Part No.1-SA-76-AD-3; 565, Part No. 1-CC-50-B-4"; Number 571, Part No. 1-CC-30-C-6"; Number 1608, Part No.1-CC-53-C-6" rework; Number 1171 and 1178, Line No. 1-D-C-33-CA-3/4". 2 Hunter Corporation Field Order JTP No.'s 5-PS-:: - 78, 5-PS-10-77, HOG-72-1, S-NT-100-2-15-A, and OG-61-7. t 3 Hatfield Electric Company QA Process Sheet Pile No. 13.09B.1, Class I, Cable Pan Inspection Checklists (approximately 33 checklists). i; i Hatfield Electric Company Concrete Expansion Anchor File No. 13.25.02, Travellers 1901 thru 1950. 52 Hatfield Electric Company Conduit Inspectien Reperts, Tile No. 13.20.01, 766 thru 850. ' (d) Persenne: Interviewed I .i t The insp(etor interviewed two QC inspecters fre: Hatfield Electric Company. ' Non:errl:an:e f;54/62-05-17; 455/80-0'-17) The inspector interviewed four welders performing in process safety related welding (two from Hunter ' Corporaticn and two frco Powers-Azco-Pope). Three of the welders did not have the welding procedure spetification (WPS) with the traveller packages. When the inspector asked where the VPS was, two welders did not appest to know what a WPS was and ' one stated that he knek the VPS should be in the wcld material issue point but stated that he had not seen it. This item is considered to be in noncompliance with the requirements of 10 CPR 50, Appendix B, Criterien IX. c, - Except as noted, within the areas inspected, no items of noncompliante or deviations were identified. 64 C-75

• ~,. ,, . - -

.., ', ~ .s . y -- , ~- ~ . -2 . . . er Prepared Ey: W. Ferney. ~ .h. QC_ Inspector Ef fectiveness i , j (1) Objective ' The objectives of this assessment were to determine if: (a) any problems exist that inhibit,an inspector from properly executing his assigned functions. , (b) the training, qualifications, and certification cf , , QA/QC personnel working for contracting organizations to the licensee are in compliance with 10 CFR 50,  ; Appendix B, ANSI N45.2.6-1978; ANST SNT-TC-1A, USNRC , Regulatory Guides 1.58, USNRC Generic Letter 81-01;  ; CEto Quality Assurance Program Manual; Ceco Respense to Generic Letter _8101 (L. O. DelGeorge to , D. G. Ei.senhut-August 17, 1981); and Contractor Quality Assurant.c Manuals. (2) Discussien i Individuals selected for interview were chosen at rando= by the SRC inspector. All contractors utilizing QA/QC personnel to monitor and accept production activities at  ; the site were selected. The organizations selected, pro-  ; ) du: tion function monitored by the inspectors, number of inspectors in the organization, number of inspectors inter-  ! viewed and percentages are identified in Table 2. Each inspector interviewed was asked a standard set of questi:ns. The ans-ers pr;vided were summarized and are previded as , Table 3.  ! Individuals selected for QA/QC inspector interview were  ; requested to provide the record of their training, qualifi-cation and certification to the inspector. The inspector reviewed each of the training, qualifications and certi-ficatien records to verify compliance with applicable regulatory requirements, standards and commitments. In verifying the implementation of the approved require ents emphasis was placed on (1) determination of initial cap-ability by suitable evaluation (2) evaluation of perform-ance/ reevaluation (3) written certification in appropriate form (4) physical requirements identified and examined yearly, and (5) qualification criteria followed and (6) records of qualification established and maintained. Table 3 is provided as a summary of inspector answers to the standard set. of interview questions. Answers to questions ~ 1, 2, 4, 5 are self evident and do not require further definitions. However, the answers to remaining questions require further clarification and conclusions. 4 65 Q C-76 . - - = s . .  ::# .* , .- -c. * -j ;%: i u . w  %,.,s _ M .- . .. .a -  : m n w  :..y- _ O - . Question 3 - relates to the number of inspectors that in-dicated during their answer to Question 2 that they had  ! '} - prior inspect 2on experience. Of the 30 inspectors inter-viewed 47% indicated prior inspection experience; however, only 27% had prior inspection experience in nuclear work ~ related scriv2 ties. Question 6 - of the 19 inspectors interviewed that regularly [ worked frequent or excessive overtime one worked less than # 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> weekly, fourteen worked from 8 to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> weekly, and four work greater than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> weekly. Tne two  ! inspectors that provided qualified answers 2ndicated the { overtime was intense at times based upon fluctuations of production activities. All of the inspectors that answere d yes or qualified their answer were asked if the frequent or  ; excessive overtime caused the accuracy of their inspecticns , to be deminished. Without exception, none of the inspec:crs felt the accuracy of their inspections were affected. , Question 7 and 8 - the inspectors that provided a qualified answer to these questions indicated that the lack of adequate staff and/or failure to conduct inspectiens promptly were a ' result of fluctuations in production activities. Open Item (45'/$2-05-18: 455/82-04-18) Question indicates that inspectors generally do not feel they have the authority to stop an activity in their centractor's cork that is not being preperly performed, 'b ner have they been provided written manageeent policy in this area. The inspectors that provided qualtfied answers indicated that they would inform the area supervisor. The inspectors were also asked if they felt they could feeediately step the work activity of ancther contracter ' werker who was perforeirs work that was hazardous to safety related equipment. The majority of inspectors indicated they did not have that authority.  : The licensee caragement committed to take actions to ,

l. re-emphasize to all inspectors their responsibility to

step an activity which does not conform to applicabJr

! quality requirements. This item will be examined during ( a future inspection. l Question 10 - the majority of inspectors interviewed  ; indicated that the training they received was adequate f for the work activity they are required to perform. One j inspector did not feel his training was adequate and the ren.aining inspectors felt that although their training was not the best, that if they needed additional guidance  : or clarification that management would provide the infor-l mation fumediately. ,

<? ...

I .Eb i C-77 66 .-- , _.-- _I. _ . _ _ ~ . . _ . - - . _ _ - . , . - . _ . . _ . - _ . . . _ _ - _ . _ - . _ , _ . _ . ~ . . . _ . - - ' C a .- .~ ^ . . .

s. -

Sj,. * ' ~ ~ . Question 11 - indicates that inspectors do not feel that a lack of inspection personnel is the cause for construction T . activities to come to a stop and is consistent with the answers / provided in Question 8. . Question 12 - the inspectors that qualified their answer gener-ally indicated that their activity did not require a check list but was normally accomplished utilizing a combination of in- ~ stallaticon plans and/or procedures. , Question 13 - the inspectors that qualified their answer indi-cated that they would have to follow the chain-of ccemand which could be untirrely. When asked to discuss their epinion of how their management portreys the relationship of quality to productica the majority of inspectors stated that quality was first and production second, a number of inspectors stated that quality and produc-tion were on an equal basis, and a few of the inspectres (pre-do:inately from one contractor) stated that production was first and quality second. , When asked to discuss their opinion of the overall finished product of their contractors activities the majority of in-spectors stated that the work generally exceeded =inimum acceptable standards, a few stated the verk generally eet minimum standards, and no inspectors felt that the werk did not meet minimum acceptable standards. Nonce eliance (454/82-05-19: 455/82-04-19) Based on a review of training qualificatien and certifica:!cn records cf a minimum of ten percent of the QA/CC persennel work:ng for contractors performing safety-related werk it is apparent that an ef fective program does not exist to ensure .^ that a suitable evaluation of initial capabilities is perferred, that written certification is provided in an appropriate form, and that qualification criteria is established. Certain contractor QA/QC supervisors and inspectors were not adequately qualified and/or trained to perform safety-related inspecticn functions. The following examples of apparent ncn-compliance were identified:

a. Contractor - Reliable Sheet Metal Verks, Inc.

(1) The contractor Quality Assurance Manual did not require inspection personnel to be trained and certified to ANSI N45.2.6-1978. (2) The certification record for the QA/QC supervisor did not contain a satisfactory basis for certification. (3) The certification record for the QA/QC supervisor did " not contain the level of capability. 67 C '7 8 k r ,s ,, .n ,

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.b. Contractor - Johnson Controls. Inc. / [ (1) The certification records reviewed did not contain a determination of initial capability. (2) The certification records reviewed did not contain a copy of the individuals high school diploea or veri-fication of prior work history. ' (3) The certification records reviewed did ne: s '.:p;e r: adequate testing prior to certificati n. It is n::ed that testing was accomplished by oral examinatien ' consisting of 25 questions to determine the ind:.ad.als knowledge of 26 procedures. The oral exarinatter. ncted the individual was weak in ability to work with draw-ings. However, there is no record to indicate adda-tional training was previded or tnat the individual was subsequently tested and found to be preficient in his ability to work with drawings.

c. Contracter - Powers-Arco-Pope (1) The certification records for the QC Supervisor did not provide an adequate deterr:ination of initial capability.

(2) The certification records for the QC Supervisor did not centain a high school diploma, or verificatten of pre-g vious employment. (3) The certification records for the QC Superviscr did not centain adequate evaluatien and justifica:icn f certt-fication to Level I or subsequent certift:st:c. to Level !! Supervisor. (4) The certification records for three (3) Q inspecters did not contain a high school diploma. (5) The certification folder for three (3) QC inspectors did not contain verifications of prior errployrent. (6) The certification records for the QC Supervisor and three (3) QC inspectors centsin open book eu ana tens that do not provide an adequate level of kne. ledge prior to certification. The records did not contain results of a capability demonstration to support cert s-fScation. (7) The certification records for three (3) QC inspectors di(notcontainadequateevaluationandjustification ic~r certification to Level I and subsequent certifica-tica to 14 vel 11 inspector. --a. / 68 C-79 e .

o. h . ; 5 .... . ,

(*. 9 ,N . .'-* f*. y f .. ,[ o -., i ' ' M.f'.

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.. - Wi . _ y1 . s.M- ** ,d. Contractor - Hunter Corporation (1) The certification QC inspector records for qualifications two (2) reviewed didofnot the seven (7) provide determination of equivalent inspection experience to support the level of certification.

e. Contractor - Hat field Electric Coreany (1) The certification records 'for three (3) of the nine (9) inspector qualifications reviewed did nct cot.tain a Certification Evaluation Sheet.

(2) The certification record for one (1) of the nir.e (9; QC inspector qualifications reviewed did not have records of examinations or work samples. (3) The certification records for two (2) of the nine (9) QC. inspector qualifications reviewed did not provide cceplete evaluation and justification for certification to perform the level of inspection identified. f. Contracter - Blount Brothers Corocratien (1) The certification record for one (1) of the two (2) QC inspector qualifications reviewed did not ind::ste the expiration date of certification as a Level I lead auditor. I

g. Contracter - Mid sy Industrial Centractor. Inc.

(1) The certification record for the QC inspecter quali-fications reviewed did not indicate the activities certified to perform.

h. Contracter - Pittsburzh Testina Laboratory (1) The certification record for one of the three (3)

QC/QA inspector qualification records reviewed did not have an evaluation of prior work experience. Based on a sanple review of CICo audits conducted in the area of training qualification and certification for the period 1979-1981 it was determined that a program exists to routinely reviev 4he acceptability of QA/QC personnel. It was noted that eeny audit findings were identified and resulted in notable improvements of contractor adherence to ANSI N45.2.6-1973. During the meeting conducted April 9, 1982, CECO management committed to develop an alternate plan for certification of contractor QC inspectors when the recommendations of ANs! N45.2.4. 1978 Section 3.5 are not complied with. Additionally, a coenitsent was made to require each contractor to verify inspectors education and s . - experience. f 69 C C-80 e

• ,e o6 ;rk [ 51 k ..

yy ~' -MW'%. ' ' . , . w " ,, - . TABLE 1 7. Licensee and On-site Contractors ~ Services (i Cract QA/QC Periodic QA/QC Organization QA/QC Organ. Review of Supv. Performed k'ork e rs Staff _Ind en . QA Pregram Pos. Des. Commonwralth Licensee ' Edison N/A 16 Yes Yes ' Yes Eleunt Prothers Plan: 220 5 Yes Yes Structures Yes Ebasco Services Inservice ~ 10 2 Yes Yes Inspection Yes hatfield Electric Electrica[ C:epany 555 83 No Yes Installation No Hunter Corp. Piping 944 71 Yes Yes Systems

• Yes hhnson Controls HVAC 47 2 Cor.t rols (2) Yes Yes Midway Indust.

Field Finish 10 2 Yes Yes Yes ) .NICO Mechanical 10 2 Yes Yes Yes Erector Nucles: P.S. Mechanical *96 1 Yes Yes Yes Design FJttsburgh Te st ing f/28 Test Lat 1 Yes Yes Yes l' owe rs - Antn Fope Instrumenta- 135 11 No Yes tion Yes R.= l i a b l e. Sheet HVAC 37 2 't. t a 1 Yes Yes Yes '.irgent & Lunrfy A. E. Field *72 0 Group (1) Yes (1) Wa s t i nr.l.ons e Mechsnical *47 SAMU 0 (1) Yes Design (1) ti - Testers * - Engineers . .(1) - Not reviewed (2) - Unresolved item c0 i ' ,, c-81 c, ,- , ~ 8 ' . . - ', g' N.. .. .-<= ev " . . .. . e , ~ - , N5' Is', 9 TABLE 2 - QA/QC INSFECTOR INTERVIEW SUw. WARY Organizatien Total Inspectors Function Insee: tors _ Interviewed .% EBASC') Services Intervice Inspection 2 1 50 N!SCO Erret ndscellaneous 2 1 5; trechanical equape.ent, final setting and erection of NSSS equipe.ent. ' Feliable Sheetretal NVAO , 2 1 53 Johnson Ccntrols KVA Controls 2 1 50 PO-ers A::e Pope (FAF) Ins tr.=entation 11 4 36.36 ) Hunter C r;cratten Piping System 71 7 t 9.56 Hatf: eld a Electrical Installation 83 9 10 . S t. s Ilount Brothers Plant Structures 5 2 40 Midway Field rinish Coating 2 1 50 Pittsburgh Testing Lab Onsite NDT 28 3 10.71 TCTALS 208 30 14.42 .s I C-82 t . s ., - -

.; 3 y 4 ' , ,, 3

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SUMMARY

OF QUESTIONS ASKED

. QC/QA INSPECTORS DURING INTERVIEWS

1. How long employed as an inspector 3 me. 6 me.

onsite? _6 re -l vr. -

2 4 8

.1-2 yr. 2-3 yr. 4 yr.

7 4 5 Yes NO

2. Prior inspection experience?

14 16 Nuclear Ner.-N;: lear

3. Wnat discipline (s) ?

8 6 Irple ented Q.a'ified Yes No Qualif:ed A.saer 4.

Is diere a sense of intimidation 29 1 base:1 upcn the need/ requirement to ), cop up with construction?

5.

Is there a reluctance to make 29 1 adcerse findings if they will ir. pact on the construction er audit schedule?

6. IsitroutineforQC$nspectors 19 9 2 to be werking frequent and/or excessive overtime?

7. Do the inspectors feel that their 19 2 9 particular section is adequately staffed?

8. Do they feel the required inspections 19 2 10 are being conducted promptly?

9. Do the QC inspectors have stop work 13 3 14 -

and/or stop process authority?

Have they ever used this authority? 13 9 8 If so do they feel they were supported 19 1 3 7 or will have the support of manage-rent in the event of a stop work? '

4,

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Implemented Qualified Yes g Qualifjed Answer t

10. Do the inspectors feel the '

24 ' 1 5 training'they^have been provided is adequate? '~+ -

11. Do situations.arise where the 1 27 2 lack of a QC inspector causes .

construction'aitivities to come <

to a stop? ..

12. Are the QC inspectors provided 15' 15 adequate che:X lists for all activities they are inspecting  ;

or are they scenetimes using vague guidelines? ,

--13. Do they feel that they have an 28' 2 avenue to r.anagement if they ,. .

co: e across a problen?

Do t.ney feel msnage. ment will get 27 3 invcived or 3ust pay lip service?

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Binder Commonwealth Edison Attachment D One First Nationa. Piara Crucago, Illinois Address Reply to. Post Office Box 767 CNcago. Ithnois 60690 November 5,1982 ,

Mr. James G. Keppler, Regional Administrator

• Directorate of Inspection and

• Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Byron Station Units 1 and 2 I&E Inspection Report Nos.

50-4 54/82-0 5 a nd 50-455/82-0 4 Ret'erences (a): Ju n e 2 4, ' 19 82 letter from C. E. Norelius to Cordell Reed.

(b): July 30, 1982 letter from W. L. Stiede to J. G. Keppler.

(c ): Septemmer 22, 1982 letter from C. E. Norelius to Corcell Reed.

(d): Au gust 17, 1981 letter from L. O. DelGeorge t o D. G. Eisenhut .

Dear Mr. Keppler:

This is to provide additional information regarding corrective actions taken in response to violations at Byron Station identified in reference (a). This information supplements the responses provided in reference (b) and addresses the NRC comments contained in reference (c).

Our response to Violation 2 indicated that we would review the treining/ qualification / certification records of quality control inspec-tors including these of contractors who have completed their scope of tork and no longer have personnel on site. This review is being uncertaken for contractors performing safety-related work a fter March 16, 1981, the date on which Revision 16 was issued for the Commonwealth Edison CE A topical report " Quality Assurance Program f or Nuclear Generating Stations." As indicated in reference (d), that was the date on which we established ANSI N45.2.6-1978 as the basis for the qualifi-cation of our QA/QC personnel. The minimum features and methodologies to be verified in our review at Byron were established in a June 9,1982 directive.

The objective of the review is to determine if the records demonstrate deficiencies in the inspector certification process employed.

If the review establishes that records demonstrate compatibility with the minimum features and methodologies, the review report will document D-1

9 l 5*  !

J. G. Keppler November 4, 1982 Occeptablity. If- the review establishes.that a deficiency exists which  ;

is one of format (i.e. , the individual inspector's certificatibn records lack documentation of education, experience, and training) the deficiency cill be classified as insignificant, documentation will be established, l cnd the review report will document acceptability. If the review  ;

establishes that a deficiency exists which is one of substance and  ;

ossence (i.e., previous related 7xperience inoadequate, on-the-job i

-training process, and capability $9monstration process do not meet the {

presently established minimum features and methodologies), the deficiency  ;

uill-be classified as significant, and the review report will document unacceptability. If the inspector is still performing inspection functions he will be retrained /requalified/ recertified to present  !

procedures.. .

When .the review process establishes inspector certification is ,

unacceptable a reinspection of the features inspected by the subject inspector for the first' month after certification will be performed to

• establish acceptability of inspect' ion. Wh'en~ inspections are found to i have been performed unacceptablyf adoitional sampling will be used to l

establish the scope of ' work 'needed to be reinspected., Reinspections for -

other causes will be considered when, establishing thei scope of further I inspections. If the feature's inspected are no longers accessible for rein-  ;

spection a review will be performed to detemine if ovsrview inspections l performed by the independent inspection contractor or:,the Commonwealb _

Edison Quality Assurance Department establish the acceptability of  !

inspections. . If no overview inspections establish the acceptability o f [

inspections, an evaluation of testing performed or an evaluation of the  !

g inspection elements and attributes will .be. performed to determine if "

j further corrective action is required. .

s + , ,;  ;

Our review of qualification records is expedted to be: complete l by December 31, 1982.- Any required retraining /requalification/recertifi-  !

cation is to be complete by February 1,1983. The reinspections or

~

additional review and' evaluation "of inspectors determined t'o be inade-quately qualified and certified should be complete by March-1,1983. t I

l: Also in responding

• to Violation 2 we indicated <that the -

procedures of the various contractors were being review and revised as 'l necessary t' incorporate the minimum features and m'ethodologies of ANSI N4 5. 2. 6-li t d . That work was completed an of September 30, 1982.

Aoditionally, all contractors perf~ rming o safety-rela'ted kork 'on-site are being requested t~o revise their quality assurance' manuals to include a

. commitment to ANSI N45.2.6-19 78. This is expected to be completed by February 15, 1983.

In response to Violation 3.c.'s we indicated that the cable side-call pressures were adequately considered in establicning the maximum i cable pulling tensions. We have rereviewed the documents relating to i cable pulling' which were being used at the time of the inspection and now [

concur with the conclusion that'sideWhl1 pressure was not adequately f l

addressed.- '

l D-b

e .

7 i

', . )

J. G. Keppler November 4, 1982 l

Subsequent to the inspection the architect-engineer specified allowable pulling tensions for cables in conduit which consider both tensile strength of the conductors and the sidewall pressure exerted on ,

the cable. Methods were also established to determins the allowable pulling tension for multiple cable pulls in conduit and for cable pulls l in conduit with non-standard radius bends. To verif y that the sidewall pressure was not exceeded for cable installed prior to these revisions the cable pull reports are being reviewed. If it is found that the Ollowable sidewall pressure has been exceeded appropriate corrective action will be specified with the advice of the caole manufacturer.

This review is expected to be complete by January 31, 1983.

To assure correct pulling tension limits are used in the future the electrical contractor's procedure will be revised to specify the Canner in which the allowable pulling tnesion is to be determined for  :

011 cable pulled through conduit. The revised procedure is to be fully '

implemented by December 17, 1982.

In responding to Violation 7 we described our practices for control of documents specifying and documenting welding activities.

.These specific construction activities have undergone the survey for implementation requirements of the ASME Boiler and Pressure Vessel Code ,

Section III and Certificates of Authorization have been granted. We believe that the welding is being adequately controlled in a manner I which satisfies the Code. By letter dated October 4, 1982 we have

-submitted to ASME a formal inquiry which should resolve this matter. A i response is expected by March 1,1983.

Please direct further questions regarding these matters to this office.

very truly yours, wy /AA Wayne L. Stiede Assistant Vice-President ,

i 1m l

i 5381N I

l D-3

e

,a re:g Binder

UNITED STATES t Attachment E NUCLEAR REGULATORY COMMisstON g a- f f, Recto'u lit i

%f , 79,acoggvCLv4040 S A y CLE% ELLvN. ILLINot5 60337 k...a#

g; 6 '534 g - 7 E t-Occket No. 50-454 Docket No. 50-455 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. S. Love and E. Christnot of this of fice on April 24-27, April 30-May 4, and May 10-11, 1984, of activities at Byron Station authorized by NRC Construction Periits No. CPPR-130 and No. CPPR-131 and to the discussion of our findings with Messrs. R. Tuetken and R. B. Klingler and others of your staf f at the '

conclusion of the inspection.

The enclosed copy of our inspection report identifies areas exa-ined curing the inspection.

Within these areas, the inspection consisted of a selectise examination of procedures and representative records, observations, and e 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.

A written response is required.

As a result of this inspection, it is our understanding that you will conduct a reinspection of all electrical conductor butt splices at Byron Station, Units 1 and 2, as outlined in your letter of May 17, 1984, D. Farrar to James G. Keppler. '

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 Roorr..

The responses directed by this letter (and the accompanying Notice) are not subject to the clearance procedures of the Of fice of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

E-1 L

Commonwealth Edison Company 2 ,-

s... .,

We will gladly discuss any questions you have concerning this inspection.

Sincerely,

/

1 R. L.-Spessard, Director Division of Engineering

Enclosures:

1. Appendix, Notice of Voilation

2. Inspection Reports [

No. 50-454/24-27 and No. 50-455/S4-19 cc w/encls:

D. L. Farrar, Director of Nuclear Licensing V. I. Schlosser, Project Manager

. Gunner Sorensen,_ Site Project Superintendent R. E. 0.uerio, Station e Superintendent DMS/ Document Control Desk (RIDS)

Resident Inspector, RIII Byron Resident Inspector, RIII Braidwood Phyllis Dunton, Attorney -'

General's Office, Environmental Control Division '

Ms. Jane M. Whicher Diane Chavez, DAARE/ SAFE R. Rawson, ELD E-2

Apoendix NOTICE OF VIOLATION .

Commonwealth Edison Company Docket No. 50-452 Docket No. 50-455 As'a result of the inspection conducted on April 24-27, April 30-May 4, arc May 10 and 11, 19E4, and in accordance with the General Policy and Procedares for NRC Enforcement Actions, (10 CFR Part 2, Appendix C), the follo.ing violations were identified:

1.

10 CFR 50, Appendix B, Criterion V, as implemented by Commonwealth Ecison -

Cercany Tepical Report (CE 1-A), Section 5, requires that activities af fecting quality be prescribed by documented instructions or pectedures.

Contrary to the above, the licensee failed to assure that the recuire-ments of S&L Dra ing 6E-0-3237 B, February 1983 Revisicn, Note 47, were translated into instructions or procedures. Note 47 requires the elec-trical contractor.to inspect for caole tray separation and add cable traf '

covers-when the. minimum separation requirements have been violated. Tnis is exemplified by the fact that 124 units of safety-related cable tray has been installed since February 1983 and this tray has not been inspec-ted for separation recuire ents. Accitional details are ciscussed in Paragraph 2.d of Inspection Report 454/54-27; 455/84-19(CE).

This is a Severity Level V violation (Su;plement II).

2. 10 CFR 50, Appendix B, Criterion XVI, as implemented by Commonwealth Edison Company Topical Report (CE 1-A), Section 16, requires that  ;

measures be established to assure that conditions adverse to quality '

sucn as nonconformances are promptly identified and corrected.

Contrary to the above, the licensee failed to assure that nonconforming cable tray hangers were identified and corrected. This is exemplified by the fact that as a result of this NRC inspection, 345 previously accepted cable tray hangers were reinspected and 119 were found defective and 19 were indeterminate because they were inaccessible for reinspection.

A contributing factor to this item is that Ceco Quality Assurance failed to determine the effectiveness of the electrical contractor's cable tray hanger reinspection program (Reference - HECo NCR 407R). Additional details are discussed in Paragraph 2.c of Inspection Report 454/S4-27; 455/84-19(DE).

This is a Severity Level IV violation (Supplement II).

E-3

Appendix 2 Pursuant to the provisiens of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written stateter.t or explanation in~ reply, including for each ite.t. of nonccepliance: (1) cor-rective 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 extencing your response time for good'cause shown.

M 5 li' g /

Dated R. L. Spessard, Director Division of Engineering e

E-4

. U.S. NUCLEAR REGULATORY CCMMISSION REGION III Reports No. 50-454/84-27(DE); 50-455/84-19(DE)

Occket Ncs. 50-454; 50-455 Licenses No. CPPR-130; CPPR-131 Licensee: Commonwealth Edison Cc' par.y Post Office Sex 767 Chicago, IL 60690 Facility Name: Byron Station, Units 1 & 2 Inspection At: Byrca Site, Byrca, Illinois Inspection Conducted: April 24-27, April 30-May 4 and May 10-11, 1924 Inspectors: R. S. Love e

,A A d/

Date fJ ,9. g /.'/.C x '; ~. .".

i E. Christn:t / L ,,' ' ' ~,

Date l/,7(-,9 'r rf'lc,: W

_ //" .

Approved By: C. C. Willia s. Chief Plant Systems Section b /6 / 'O Cate Inscettien Stemary Inscection on Acril 20-27. Acril 30. May 4, and May 10-11, 19E4 (Recert No. 50-454/e4-27(DE); 50-455/S4-19(DE))

Areas Insoected: Review of licensee action on previously identified items.

This involved the review of applicable procedures, drawings, records and calculation on-site and at Sargent and Luncy (licensee's A/E). This inspec-tion involved a total of 146 inspection hours by two NRC inspectors. Six of these inspector hours were expended in Nuclear-General Employee Training which will be required for unfettered access (Ref. 10 CFR 50.70).

Results': In the areas inspected, two items of noncompliance were identified (Paragraph 2.c, failure to identify and control nonconforming conditions-Criterion XVI, and Paragraph 2.d, failure to assure that activities affecting quality are prescribed in instructions or procedures-Criterion V).

E-5

DETAILS

1. Persons Contacted Common =ealth Edison Comoary (Ceco)

G. Sorensen, Construction Supe *intendent K. J. Hansing. Quality Assurance Superintencent "J. O. Binder, Project Electrical Supervisor

• R. B. Klingler, Project Quality Control Su;ervisor

• J. L. Bergner,_ Quality Assurance Supervisor

• M. V. Dellabetta, Electrical Quality Assurance Enginee-

• E. T. Sager, Electrical Field Engineer

• J. W. Ra;peport, Quality Assurance Engineer E. L. Martin, Quality Assurance Supervisor J. W. Zid, Quality Assurance Engineer

.P.'T. Myrda, Quality Assurance Supervisor Hatfield Electric Comeary (HECo)

D. L. Heider, QA/QC Marager S. Hubler, Lead Quality Cor. trol Inspector Sarcent and Lundy (S&L)

J. D. Regan, Electrical Engineer B. G. Treece, Senior Electrical Project Engineer J.'F. Clancy. Quality Assurance T. R. Eisenbart, Electrical Engineer J. J. Kamca, Senior Structural Engineer

-T. J. Ryan, Structural Project Engineer The inspectors also contacted and interviewed other licensee and contractor _ personnel during this reporting period.

• Denotes those present at the exit interview conducted on May 4,1954

2. Action on Previously Identified Items

a. (Closed) Noncompliance (50-454/80-09-01; 50-455/80-08-01): During a previous inspection it was identified that the requirements of the Byron SAR and Loecification 2831 were not adequately translated into Specification 2815 in that corrosion protection (painting) was not specified for the exposed carbon steel material and exposed spot welds utilized in the installation of seismic Category I electrical raceway hanger supports. Engineering Change Notice (ECN) Number 4362 was issued to revise Specifications F/L 2815-and F/L 2831. The licensee's painting contractor (Midway Industrial Contractor, Inc.)

has a program in place that will assure that the items have been painted. CECO Project Construction Department (PCD) is monitoring the progress of the painting contractor. This item is closed.

2 E-6

b.

(Closed) Unresolved Item (50-454/82-17-02; 50-455/82-12-02): Ouring a previous inspection it was identified that conduit and cable tray hanger bolts.no longer met the bolt torque requirements as specified in the applicable procedures. The licensee was requested to evaluate these relaxed torque conditions and determine if they were acceptaDie.

With respect to cable tray hangers, as part of the hanger reinscection program, the hanger bolt torque was verified and any bolts found not meeting the torque requirements were re-torqued to Drocedure recuire-ments.

With rescett to conduit hangers, a reinspection of 300 ccncait hangers was concucted.

This reinscettion identified 89 condait harge-bolts with less than the specified tcrque. These hangers were tren analyzed for worst case cor.citions. Inis analysis was reviewec by tne inspectors and found to be ace;aate. The analysis identified that the concuit hanger would have performed their design function in the as-found condition. This item is closed.

c.

(0 pen) Unresolved Item (50-454/22-17-C4; 50-455/82-12-04): Durirg a previous inspection it was identified that tne hanger co nection details under fireDroofing were being accepted without 0; inscec-tion. The HECo QA Manager had instructec :ne CC ins;ec. ors to accect connection details covered by fireprcofing based on the infcrmaticn on the weld traseler for the subject connection detail. These instructions we e doc:-'ented in QA/QC Memcrand.m 1.mcer 295. These

' instructions -e e pr0vided in conjunction with the ca0le ::an ha ger reinspection required by HECo NCR 407. At that time, the Re; ion III inspector infor. ed the licensee that the weld traveler cauld be utilized for acceptance providing the hanger connection de. ail usec was noted on the traseler. In accordance with a CECO letter, cstec Spetember 22, 1952 HECo was recuired to submit certain cata ce--

taining to this reinspection program on a periccic basis. Curing this reporting period, the Region III inspector revie-ed these data provided by HECo. These data indicated that of 4,3C8 hangers rein-spected, fireprcefing had to be removed from 131 hangers to deter-mine acceptance. This report indicated that 3 of the hangers were rejected after the fireproofing was removed. To determine hy these three hangers were rejected, the inspectors revie-ed the applicaole weld travelers, hanger de-hang /re-hang forms (HDRF), rework requested, field change request (FCR), deficiency reports (OR), nonconformance reports (NCR), and the hanger inspection checklists. Following are the results of this review:

(1) Hanger BHV11 on Drawing 0-3097H, Revision T.

HDRF 1151 indicates hanger originally installed August 19, 1980. HECo could not locate a weld traveler for this installation.

FCR 1807, dated August 19, 1980, was issued to relocate the hanger.

DR 119, dated June 11, 1982, stated that the hanger could not be inspected due to installation of fireproofing.

This DR was, closed on December 21, 1982.

. . HDRF-1151, dated September 30, 1982, indicates that the hanger was not installed per the drawing and FCR 1807.

Hanger was removed on October 12, 1982.

3 E-7

Weld Traveler 19038, dated October 12, 1982, states,

" Welded plate to tube steel and structural steel (South side only)." Accepted by QC Welding Inspector.

Weld Traveler 19039, dated October 15, 1982, states,

" Repaired weld on plate to structural and tube steel".

Accepted by QC Welding Ins:ector.

HDRF 1151 incicates har;er was reinstalled on October 22, 1982.

Hanger installation was accepted by QC.

The following discrepancies were cbserved:

Initial weld traveler missing, Weld traveler for Nortn side of hanger missing, NCR, CR, or Inspection Re: ort (as acclica::le) identifying that the hanger was not installed per crawing and FCR 1807 was missing.

(2) Hanger HCC5, Drawing 1-3C51H, Revision H Weld Tra.eler 2:343, dated July 25, 1973, dec; ents the installaticn of the hanger. Accepfed by QC Welcir; Inspector.

Inspection checklist, dated Sectember 27, 1932, rejected the hanger because the ins:ector could net verify *.ne hanger type and config.: ration'. ;Was11ater acce:tec b.

Me o #295.

HEco to Ceco summary report, dated Cctcber 10, 1953, indicates this harger was rejected during the reins:ec-tion.

Tne folicoirg ciscre:ancies were cbse vec:

No doc; .e .tation to shc., why the hanger .' as rejected, No doc:. mentation to indicate that the harger was re: sire:

or re-orked, as applicaole, No inspection checklist / weld traveler to indicate that the' hanger is now acceptable.

(3) Hanger. H 153, Drawing 1-3061H, Revision S, Inspection checklist, dated February 22, 1984, was a final acceptance of this hanger. The checklist referenced:

FCR 22920, Revision 1; FCR 21871; Rework Request 646; DR 1025; and HDRF 2197.

Work Request 648 involved the removal and replacement of the hanger-horizontal members.

FCR 21871 involved the pan to hanger attachments. Work Request 648 and FCR 21871 were not in the area of concern and the inspector chose not to followup on these items during this inspection.

DR 1025, dated October 23, 1982, documents that Connection No. I was a DV5 detail instead of a DV4 as specified, and Connection No. 2 was a DV89C2 instead of a DV89El as specified.

. .- FCR 22920, dated November 8, 1983, changed connection No. 1 to a DV3 detail and Connection No. 2 to a DV89G2.

4 E-8

The following discrepancies were observed:

The inspectors could not determine how FCR 22920 was implemented in that a HDRF/ Work Request was not available for review. The inspection checklist, dated February 22, 1984, indicated that Details DV3 and DV89G2 were actually installed.

(4)

Based on the results of the records review of the three rejected '

hangers, the inspectors elected to review a rand:m sam le of the records for hangers that nad been reins:ected and accepted by HECo QC. Folicwing are the results of this review:

(a). Hanger HCJ3, Dra.ing 0-3C61H, Revision M, was ac:ested :n Inspection Re: ort 4270, dated October 5,1952. Inspection appeared to be adequate.

(b) Hanger H1:3, Drawing 0-3063H, Revision L, was acte:ted on Inspection Re;crt 2172, dated Oct:ber 21, 1932. Ins:ection appeared to be ade;cate.

(c) Hanger hC01, Dra ing 1-305;H, Revisi:n H, was accepted on Inspection Report 3650, dated Sentercer 17, 1952. Cenre:-

tion cetails 1 and 2 aere acce:ted on the Insce:*.ico RE: Ort based on Weld Traveler 24900, dated July 18, 1973. A resiew of the traveler indicated that a DV34 conre:tien detail was utilized as specified on the dra.ing. Tnis -as found to be acce: table.

(d) Ha ger #..~3, Drawing 1-3051H, Revisicn H, was acre:te:

n Inspection Report 3657, dated October 7,1952. Cc- e:t'en details 1 and 2 were accepted based on Weld Traie e- 2;i;3, dated July 26, 1978. During a review of the traveler, it was observed that the tra eler did not indicate wnich connection details were used to attach the hanger to the structural steel, i.e., details 1 and 2. Based on the documentation presented, this hanger installation could not be accepted by the Region III inspectors.

(e) Hanger H080, Drawing 0-3051H, Revision L, was accepted on Inspection Report 3484, dated October 16, 1982. Connection details 1 and 2 were accepted based on Weld Travelers 24301, 24804, and 24834. During a review of these travelers, it was observed that the travelers did not denote which con-nection details were used to attach the hanger to the -

structural steel. Based on the documentation presented, this hanger installation could not be accepted by the Region III inspectors.

(f) Hanger H028, Drawing 0-3051H, Revision L, was inspected on Inspection Report 3433, dated October 5, 1982. This Inspectisn Report referenced DR542. During a review of this DR, it was observed that the auxiliary steel plate size was listed as being the wrong size. This item was not disposition nor corrected and the DR was improperly 5 E-9

o l closed. Based on the documentation presented, this hanger installation could not be accepted by the Region III inspectors.

(g) Hanger HOSS, Drawing 1-3051H, Revision H, was noted as being unacceptable on Inspection Report 3734, dated July 30, 1982. Reasons noted were: (1) unable to verify connection details 1 and 2 because they were covered itn

, fireproofing, and (2) weld travelers did not specify the connection details installed. On Se:tember 27, 1952, this hanger was accepted per Memo 295. Based on the documenta-tion presented, this hanger could not be accepted by the Region III inspectors.

(5) Based on the results of the documentation revie. for the ten  !

above listed hangers, the Region III ins;ectors terminated their review of caole tray harger docurer.tation. On April 25.

19E4, the insoectors cond;cted a mini-exit-inte vie. witn Ceco and SECo QA and construction personrel. During this intervie ,

the inspectors revie-ec their concerns with the accs:tacility [

of the cab;e tray hanger documentation. The insoectors requested that the licensee review the hanger documentation and determine what hangers were unacceotaole. On May 1, 1952 '

the inspectors were informed by the licensee that there were approximately 345 nanger that were accepted based on Memo 295. i The licensee stated that approximately 6000 hanger packages were reviewed by CECO QA arc HECo QC persor.nel. The licensee continued to pro.ide daily updates on the progress of the hanger reinspection ef fort and tneir findings. During a telechone consersation bet een Mr. J. Binder (CECO) anc Mr. R. 5. Love (RIII) on May 11, 1954, Mr. Bincer proviced the following results of the reinspection effort:

. Total number of hangers requiring reinspection 314

. Number of hangers inaccessible 19 These hangers were documented on HECo NCR 990

. Total number of hangers reinspected 295

. Total number of deficiencies identified 129 .

. Deficiencies by attribute: ,

Welding fitup 91 Wrong connection detail 7 Wrong weld length, elevation, auxiliary steel plate size, and missing bolts 31 Fit up deficiencies are documented on HECo NCR 989. Connection detail and steel plate deficiencies, etc. are documented on HECo DRs 4921-4928, 4930, 4932, 4934-4937, 4943, 4945-4948, 5003, 5007, 5013-5017, 5019, and 5022-5032.

6 E-10

r (6) As a result of the . inspector's observations noted above, the inspectors requested that the licensee provide the last three audit / surveillance reports performed by Ceco in the area of hanger acceptance for the subject reinspection program. As stated earlier in this recort, tnis initial reinspection effort involved 4308 hangers. The CECO QA Engineer informed the inspectors that to tre best of his kncoled;e, no audits or surveillances were performed in this area and furthermere, he (CECO QA Engineer) .as not a.are of this hanger reinspe: tion program. On May 10, 1954, Messrs. C. C. 'a'illiams and R. S. Lo.e of the Region III staff centa: ed Mr. K. J. Hansing, CE:o GA Superintendent, by telechone ano discussed the reinsse:tien pregram and lack of Ceco QA accits and/or surveillances in .is area. In summary, Mr. Hansing stated that:

(1) CECO CA .35 a are of the hanger reinspection pacgram.; (2) CECO QA cnose net to perform a scecial audit / surveillance of this hanger reins:ec-tion program; (3) CECO QA was not a.are of Region III's ir.terest in this pregram. It shculd be noted that Regi:n III's insol,e-ment with this reins:ection effort was dec_ entec in ! asps: tic, Repcrts 454/52-17; 455/22-12 and 454/33-48.

On May 11,1984, Mr. R. 5. Love, Regi:n III, cc-tacted Messrs.

' AJ. O. Bincer, J. L. Bergner anc others of the Ceco PCJ anc ";A yren site organization by telephere. During tnis conve-sation it as learned that CECO QA had in fact perfer e.: an au::it of the subject reinscection program in Jure 1933 and had a cence-o with HECo Me o 295. Mr. Bergner cid not elaterate on this concern. Mr. Sinder stated that during this ins:ect n :er"cc.

he (Mr. Sinder) directed the HECo Q./QC Mana;er to preca e a letter to cancel Memo 295. Upon review of :ne se:Ler:e Of events and the results of the hanger reins:ection ef fert, it would appear that the 129 deficiencies observed on 119 safetj-related cable tray hange s would have gone uncetected if tre Region III inspectors had not uncovered the proolem areas anc requested CECO to perform an incepth review of hanger docu-mentation and the subsequent reinspection program. The licensee was informed that failure to establish a program to assure that conditions adverse to qualify are prceptly identi-fied and corrected is an item of noncomplaicance in accordance with Criterion XVI of 10 CFR 50, Appendix B (50-454/84-27-01; 50-455/84-19-01).

d. (0 pen) Noncompliance (50-454/82-17-05; 50-455/82-17-05): During a previous inspection it was identified that the licensee was not identifying, controlling, and correcting cable tray separation violations. As part of the corrective action, during the latter part of 1982 and early 1983 a concerted effort was made by CECO, HECo and S&L to identify all cable tray separation violations. This information was compiled and analyzed by S&L. The corrective action were: (1) relocate one or more cable trays to correct the violations; or (2) install cable tray covers on one or more of the cable trays (by the installation of covers, the separation criteria is reduced 7

E-ll

frem 3" horizontal and 12" vertical to 1" horziontal and 1" vertical);

or (3) based on the analysis, accept the installation as installed; and (4) place a distinctive mark (black octagon mark) on the appii-cable drawings to indicate that a sepa-ation violation had been identified in that area and that the violation had been analyzed by the engineer, S&L.

During this reporting pericd, the instectors: (1) reviewed the engineer's analysis and found it to be ade:;. ate; (2) revie ed sele:-

ted drawirgs and verified that they were marsed to indicate that the engineer had ana!yred the separation violations; (3) revie-ed seie:t drawing to verify that tray covers were specified as part of the  ;

1 correcti.e action: and (4) toured the pc er slock anc identified separati:n violations ard verfied that tne viciations had teer.

addressed by the engineer and appropriate action taken. During interviews ditn S&L pers:nnel identified in Paragr3:n 1 of this report, the inspectors were informed that several nctes ha: been added or resise:: on Driwing EE-0-32373, Fe::rua y 1523 revisien, to prevent recurra ce of caole tray separation vi:13ti:ns. During a review of Dra-ing 6E-0-32378, Revisien L, it was c: served that Note 47 directed the electrical centractor, HECo, to install cable traj covers in accordar:e witn the electrical specifications when the 3" hori: ental and 12" vertical separatien rec;uire ents were viciated even thougn the acclicable dra.ing does not sh:w the subje:t tray to be covered. Ncte cS directs the electrical contractor to notify 5LL if the 1" metal t0 metal separation is violated af ter the installa-tion of cable tray covers. During a review of HEco 9 Series prece-dures, it was o ;ssrve:: :nat t'e re;uirements of Note 43 were a:e-cua:ely a:: dressed but tre recaire .ents of N::e 47 were not ad:res sed.

Ou-ing intervie-s with the Ceco Project Electrical Su::ervisor, CE::

Electricai QA Enginee , CECO Electrical Field Engineer, HECo GA/~~

Maanger, and HEC: Project Engineer, it appeared that these persc nel we e not a-are of the require ,ent of Note 47 on Dra ing 6E-0-32373 until it was brougnt to treir attention by the Regicn III ins:ect:rs.

It was also learned that HECo QC, engineering, and construction ere not verifying cable tray separation.

During this reporting period, the licensee instituted a program to determine the amount of safety-related cable tray installed in Units 1 and 2 since February 1983 (effective date of Note 47). As a result of this review, it was determined that 83 cable tray inspection reports (Note: each report can address 1 or more sections of cable tray) had been prepared for Unit 1, and cable tray separation requirements were not verified (

Reference:

HECo NCR 975, dated May 4,1984), and 41 reports were submitted for Unit 2 (

Reference:

HECo NCR 976, dated May 4, 1984). The licensee was informed that failure to assure that activities affecting quality are prescribed ir. documented instructions or procedures is an item of noncompliance in accordance with Criterion V of 10 CFR 50, Appendix B (50-454/84-27-02; 50-455/84-19-02).

8 E-12

e. (Closed). Noncompliance (50-454/82-17-06; 50-455/82-12-06): During a previous inspection it was identified that the licensee was not identifying, controlling, and correcting cable separation violations inside of parels, cabinets, motor control centers, swit:cgear, etc.

As part of the corrective action, during the latter part of 1982 and early 1983, a concerted effort was made by CECc, HECo and 51*. to

' identify all caole separatico violations inside of e:uip er.t. Tnis infortaticn as comoilec and analy:ed by S&L. Tne corre:ti.e a: tic s were: (1) re'ocate/rercute one or more of the cables to ::*re:: the violation; or (2) install fire barriers betaeen the inv 've: Ca 'es; or (3) route re of the involved cable inside a cercait tnet cuali-fies as a fire tarrier; or (4) based on the analysis, 3: e: tre installaticn as installed; .and (5) establish a pregra: to infer- fil of future violations 30 that they could De analy:ed and ::# recti.e acticn assig ed. -

During this re:Orting ;eriod, the insce: tors: (1) rei sae: *he i

engineer's ar.alysis and fourc it to be a e:;uste; (2) re,ie ec the ele:trical centractor's (HECa) tertinatica insce:-icn : ::ed e an:

ice tifie:: that the QC ins:,e:ter was receired to ins:ect fcr and identify se:aration violations bet.een safetj-related and ncn-sa'aty-related cacies and betaeen redunda-t cables; and (3) verified i.tcie e-tati n of tnis prcgram by revieaing ca:le se:aratic, prc:t e-re :-ts that .e e tei g for arded to the ergireer for ar.a'jsis. Tre cor e:t he a:ti:ns a-d t'e corrective actions to pre.ent ric;.r e :e a:: eared t: :e ade:: ate. This item is closed.

f. (C':se:) N: :: :lia .:e (50-25:/53-37-01): During a cres cus r ci t.

i it .as ide tefie: t.,at the CE:: Marager of Q ality Ass;ra :e ra:

eit3 lis e: an Inte 4: Leaa Audit 0r certificati:r. progra, trat .35 not d.

ented in the CECO Quality Assurarce Manual, or in tre CE:

Tcc cal Re;;rt nor is it permitted by AN5I N45.2.23-1973, "Q ali fi: 5-i tien of Quality Assurance Program Audit Personnel for Nuclear P:-er Plants." This informai progra.thad been established within CECO to certify an individual as an Interim Lead Auditor wnen he/sne Cid not meet the qualification requirements of a lead auditor as specified in ANSI N45.2.23-1978.

As. part of CECO's corrective action, the Interim Lead Auditor corcept was discontinued, the personnel holding Interim Lead Auditor certi-fications were de-certified, and records were reviewed to determine the names of personnel that had been certified that did not meet the minimum qualification requirements. The records review indicated that between 1977 and 1983, eight (8) CECO personnel had been certi-fled as Interim '.ead Auditors by the CECO Manager of Quality Assur-ance. The audits performed by these 8 people were reviewed and evaluated by qualified Ceco Lead Auditors. With a few exceptions, the audit reports and the objective evidence and the audit deficiency close outs were in compliance with the CECO audit program. During a review of these audit evaluations, the most significant audit deficiencies observed by the Region III inspectors were:

(1) One item on the checklist had insufficient objective evidence for acceptance. This attribute was adequately covered on a subsequent audit by a different auditor and found acceptable.

9 e

O (2) One item as relating to records storage was marked acceptable and from the information documented ill the report, it should have been listed as a deficiency. This item was subsequently icenti fied and corr !cted.

The corrective action and corrective actica to prevent recurrence appears to be adequate. This item is closed.

g. (Cpen) Non :.-pliance (50-252/83-49-04): During a previous ins:e:-

tion, it was identified that Kellem ty:e cable grips (used to se=:rt electrical cables in cable pan risers a-d in1 vertical cer:uit eers) were not installed in accorca ce with the electrical soe:ificatic s.

This item is also icentifiec in 10 CFR 50.55(e) re;:rts 452.'53-14-55 and 455/a3-14-55. During this re;crting period, the Re;icn III inscectors c:ser,ed tnat the installation of3caDie grips in safety-relate: rise: s R277 R345, R363, and R369 were deficient in t at they .ere rct sur; rting the cables in accordance witn the design s;s:ifica.'c.s. Pending verification of the licensee's ccrrective acti n. nis ite re ains ocen. This item has been assigred Cste;;r3 1 ar.c must :e closed prict to fuel load,

h. (Closed) C::en Item (50-154/84-C2-03; 50-455/84-02-03): Ouring the ASLB nearing for 53 ron Station, Unit 1, the licensee stated that the cable pull re: orts for cables already installe: are being resie-ec to ensare tnat the maximum all;wa:le cable pulling tension anc maxir a alle.able ca:le side all pressure had not been exceedec. "5 decrented in Ins;ectico Re: Ort No. 50-450/54-09 and 50-155i 52-07, the Regien III inspector reeie.e: the on-site rec:rcs arc itn :

• ex:eption (Nanccmplian:e 452.'52-05-02; 455,54-07-;2), these re::r:s

.ere fourd to be adequate. Caring this re;crting ;:e-ica, tr.e Region III inscect:rs revie ed tre e--ir.aering calculations at tre engi eer's facilities. The engineering analysis was perfor e:

utilizing one or more of the following metheds:

(1) _ Calculations for an assumed worst case conduit configuration containing a worst cable configuration, i.e. conduit run itn four 90 bends with minimum bend radius (270 total bends allowed at Byron Station) and with the maximum cable density.

Utilizing this methodology, a critical conduit length was calculated for each conduit size. Using this information, a review of the approximate 2600 conduit runs was made. If the actual length of the conduit run approached the calculated critical length, that run was flagged for further analysis per paragraph (2) below. Worst case accepted, as observed by the inspectors, during this first cut, had a safety factor of approximately four, i.e. allowable pulling tension 40C# versus calculated of approximately 100#.

(2) Calculations for an assumed worst case conduit configuration (4-90* bends) containing the actual installed cable configura-tion. The worst case accepted, as observed by the inspectors, had a safety factor of approximately 3.3. Again, questionable conduit runs were flagged for analysis per paragraph (3) below.

10 E-14

(3) Calculations for' actual conduit configuration containing the actual cable configuration. Worst case accepted, as observed by the inspectors, had a safety factor of approximately 4.7.

Upon completion of this three step analysis, three conduit runs were questionable. They were analy:ed by Okonite Company,

' cable manufacturer, as des ribed in paragraph (4) below.

(a) The folle-ing informatien as for.a-ded to Ok: nite to assist in ineir evaluation cf ca:ies installea in con: Lits CCA-5153, CCA-6192 and CCA-5193:

Conduit size all 5" Certuit configuration frcm as-built draai ;5 Caole configa-ation fr m cable pull car:s Cen:Jit CCA-5153 1/C-750 MCM, EC.', ca:les Condu't CCA-5192 and 6193 1/C-750 MCM, EC!, ca:les

. Cacle pull directicn The . mas'7.m cable ;ulling tension for the subject ca:les .as 00 '-

questien for these tnree installa icns in that the ma<imum al!:.2- 'e tension for the 2-1/C-750 MCM cable pull is 120,0CC= and 150,:CC8 for the 3-1/C-750 MCM cacie pull. Due to cencait configuraticr, Os:-':e was .recuested to perform an analysis for pcssible catle sice a'l pressure violaticrs. Ok: nite's letter of Cctober 11, 1923 i-ci:a:es trat they performed their analysis and fcu no side all cress.re violations. It should be nota: that each casle ma ufacturer estas-lishes the axim m cable sideaall pressure that thei ca:1es are desig ed t .itrstar .itetut causing da a;9 to tre :*rcutt:r insalati0n Based on t e results Of pre,ic.5 ins:e:ti: s a-d c: -

mentation revie ed during this ins;e::ica, the ins:e:: ors nave a reasoraale assurance that these safety-related caDies will pe-f:--

their intended function. This item is closed.

.i. (Ciosed) Unresolved Item (50-454/34-09-01; 50-455/34-07-01): Da ' ;

a previous inspection, it was cbserved that there were seseral at:-

standing NCRs that were prepared to docurent possible over tensioning of safety-related cables during initial installation or during re :rk (pull back). During this reporting period, the inspectors revie-e:

the disposition and implementation of CECO. NCRs F838, F839, F545, F864, and F865. The inspectors also reviewed the back up data for

'these NCRs and found it to be adequate. This item is closed.

J. (Closed) Noncompliance (50-454/84-09-02; 50-455/84-07-02): During a previous inspectio a it was identified that HECo DR 3382 was inade-quately dispositioned, resulting in 12 cables being installed whose quality was indeterminate. Subsequent to the inspectors findings, HECo prepared NCR 841 to document the overstressed cables. During this inspection, the inspectors verified that the cables had been replaced, and action to prevent recurrence had been implemented.

This item is closed.

11 E-15

3.

Licensee Action on 10 CFR 50.55(e) Recerts (Closed) 10 CFR 50.55(e) Report (454/82-07-EE and 455/82-07-EE):

current (CC) control pc.er cable failures. Several single conductorDirect ASW

1. 2 DC control pc.er cables, which run from the auxiliary building to tre essential to greure.service water cooling t:.er in an uncerground duct, have f ailed placed in se vice.The f ailures oc:ured af ter the caoles had been tested and f ailure of DC cacies 1 CC 073 anc 1 OC 073, 2 CC 074 and 2 CC 075 in Unit 2. 075 in Un 1es 2 CC Re: ercs indicated the f 1! wing:

a.

Caoles,1 DC 073 arc 1 CC 075 in Unit 1 were replaced cy euiti-conccc cr :acies 1 JC 742 an 1 DC 243 res;ectively.

b.

Cacles multi 2 CC 073, ccrauctor 2 GC cables 2 00074 C41,anc 2 CC 075 in Unit 2 we e re:'a:ed :y 2 CC 225 and 2 CC 2*3 res;ecti.e!;.

c. T.:

nc ::nf:eran:e re: orts (N:

the failu es arc ::tn NCR's ere closed cut on A:rilR) 566 and 732 .ere .ri 15, 1954 d.

A sasas'.e of tre cacies was pulled and tested by the Ta u#acture .

The

?e fai?ed a production test (e.g. a 13,500 voit s:a < test) 9 wnien it ra: passed prior to shipment.

e.

Tne prc: sole f ailure to pass the test was due to elen a:icn of tie cacie insulatien.

The ins;e: tors determi e: from a re.iew of installation re::r:s t it e cables is closec. were replace; ir at:Or:19:e oitn appr05e3 pr:ce:;res, Tnis i te-4 Ecnduct:r Butt 5olices Due to the pr:blems en: untered with conductor butt splices at other Nuclear Plants, the inspectors queried the licensee as to what actions had been splices at taken or were the Byren planned to verify the acceptability of the butt Station.

initiated a review of approximately 11,000 cable termination reports identified 646 of these reports that documented the installation of butt splices.

Between March 13-16, 1984, Ceco QA and HECo QC randomly checked 221 safety-related and 78 non-safety related conductor butt splices.

Following are the results of the checks made on the 221 safety-related butt splices March as documented in Ceco QA Surveillance Report 5944, dated 27, 1984:

27 splices were not inspected because they were covered with tape or heat shrink material.

194 splices were visually inspected and 72 were " tug-tested".

1 butt splice failed the tug-test and was replaced.

16 splices were identified as defective and replaced. Failure attributes were not provided.

All 194 butt splices were installed with the proper crimping tool.

12 E-16

-O<

t

, e metal shielding braid or tace shield on control or instrument cables as addressed in S&L Standard EA-215. The inspectors made a detailed revies of 34 of these CITRs. Folicwing are the results of this review:

CITR No. Cable No. Nc. of Solices Re arks 119 1M5529 1 11942 1AF151 1 11941 1AF180 1 11940 1AF179 1 11933 1AF170 1 11935 IVAC53 1 Re: laced-da age: :: .:::r 11933 insulation IVA533 1 11913 1CC2:5 1 119C5 1VC590 1 Replaced-data;e: cend.:ter 11905 insalatien 1CV545 2 Re:lacec-da age: co-c.:ter 11904 insulatien 1CV91 2 Replace:-da a;ed co-c;;;;r 11891 insulatien 1C5115 2 11550 151523 1 11559 15I523 Recla:ed butt solice 11555 1 9eplaced cutt solice 1VA:23 11557 1VA102 1 Re:ia:ed tu : scii te

'10973 1N;225 1 Reala:ed cutt spiite IC557 1N;227 1

Shield traid s: lice 10535 1 Shield wire 5:' ice 1hE225 1 Shield ire s:li;e S:37 1V"313 1

--8033 IVA707 1 7955 IVA709 1 7954 IVA705 1 7953 IVA317 1 5554 1NRG14 5550 1 In process inspection 1CC010 1 5549 1CC001 5534 1 In process inspection 3FW213 3 5528 1RC439 5527 1 In process inspection 1NR102 1 In process inspection 5526 1RC436 5272 1 In process inspection 1FW221 5 4561 1MS308 4 4391 IFWO55 1 Crimp tool not calibrated-replaced butt splice.

Dates 1984.

of these inspections ranged from March 3,1982 thru February 25, It was observed that all of the inspection reports randomally selected were for Byron Station Unit 1. In the 34 reports reviewed, it appeared that there were five defective butt splices and six examples of damaged / cut conductor insultation identified.

14 L

m

CECO NCR F899, dated April 5,1984, was prepared to document that the conductor insulation on cables provided by Okonite Company would not fit inside the insulation barrel of Amp butt splice connectors. ,This NCR has been for arded to CECO Project Engineering Department (off-site) for resolution. As of May 4,1984, a resolution / disposition had not been received on-site.

To understand hy the conductor cutt splices were reje:ted, the ins:ectors requested the applicasle inspection checklists /termina*. ion reports for review. The ins:e: tars reviewed the following Cable Insce: tion Termina-tion Reports (CITR) ard Equipment Modification Inspection Requests (E":R):

Re: ort Nc. Cable No. No. Re ie:ts Re a"ks CIRT 12318 2SXO33 1 Butt Splice Replaced CITR 12130 1Rh;53 2 Butt Splice Re: lace:

CITR 12119 1RHC52 1 Butt Splice Rep? ate:

CITR 12143 1Rr:53 3 Butt Solice Reclace:

CITR 121:5 1C5Ci3 2 9. t 5: lice Re:iace:

CITR 12144 1RMI:2 2 Butt Splice Replate:

CITR 12131 1Rw:53 3 Butt Solice Re ! ace:

CITR 12150 1R-22 1 Butt Sclice Replate:

CITR 12123 1RH;3 1 3ctt 5;1 ice Repia:ed EM:R 5950 ICC155 1 Cut insalation bet-ee, Butt Splice and te-minal l ug- repl aced.

EM:R 55E3 1RC159 1- Cet insulati:n repaired witn shrink-fit mater al i

1R:137 1 Ea: cri ; on conne:t:r-replaced IRCI:7 3 Cut insulation replaced IRC165 1 Exposed copper at splice replaced IRC173 1 Exposed ccper at Splice-replaced 10G157 1 Butt splice replaced 10G153 1 Cut insulation-repaired with shrink-fit material 10G163 J Butt splice replaced 27 Total From the above information, it would appear that an addition ten butt splices were rejected and repaired during the repair of the L rejected by CECO QA. Utilizing this latest information, it would appear that the reject rate 27/194 is 13.9%. During interviews with the CECO and HECo personnel involved in this reinspection effort, the inspectors were informed that the largest number of rejected butt splices were because the conductor (copper) was not visible at the connector crimp.

The inspectors also performed a general review of the 646 CITRs identified by the licensee that doucmented butt splices. It was observed that a large percentage of these splices were associated with the termination of 13 mrt

9 4

To determine if all QC terminatien inspectors were documenting butt splices on CIRTs, the ' CECO Electric 1 Field Engineer intervie-e: the HECO Electrical GC termination inspe:ters ano determined that only~ appr:xi-mately 50% of those intervie-ed documented their inscettion cf butt splices.

In vie- of the informatien ebtaine by CECO during their re.d e-of potential tutt splice ;r:elems at the Byrca Stat cn i (i.e. ,13.9%

reject rate), the Reig:n III inspector expressed his conce-n es 10 * .

Ceco-failed splices.

to imcle e : a ICC% reins;e: tion / ins;e::4ce of c :.:t: :.it .

As a result of the instector's concean, CE: 0, By"On 3ta!':P.

proviced a ver:al nctificatien to Regien III of a ;cte tial 10 CFR 50.55(e) re::rt en May 10, 1954, relative to electri:31 cc-d.c;;r :.it

-solices.

(CECO Syren As Staff) a result andofMrtete:rcre con.ersatiens bet-een Mr. R. I'et~in C. C. Williams (Regi:n III) en 'a/ .0 n : '1. '

195A. CEC: de.eleted an ins:e::ico plan for tre rein _s:ectica of ele ;-ica cor.:. tar butt s lices at tre Eyron Station, Units 1 a : 2. Tnis ins:e:-

tion plan is ::: mente: i n 'ir. D. Farrar (CECO Dire:ter of N;:len*

Liteasir;) 'ette- to Mr. ,a es G. Ke::ler (h C Re;": 31 Actinis *S* -),

d = . a. ". ".= ,' '.7 . , c.. .: ~a.

Re ,-t.-. I '. .t  %. . .: 3 .: 4--

=.3.g.... ..>......

.c ..,j... ... s..... ..., ... :  ;.:

r e i a. >- . =. . *. '. .- -

e. .- , . . 7 . L'..- . c .- o ' a. *. ;. a. a. wa

'. +..e r a. i. a .t . e-

. - . '. . r. .- . .-

sera ste ins:e::icn re: -ts (5C-252. E:-C9 a-d 5:-255 52-21) -il ? :e i s = . =. ". *. . m" . . . =- . *. ' . . - = . '.' " . ' . ~ , ~ > - a . . .c - - - . .- . ' . a.

s..'.n

• .are. .

5. c.w t., s.-.=.~ :,-

-The insrect:rs et wits, the lice see re: ese' tat'<es ( e tes in paragra: 1) a: t e :: :1.s':

en May 4, 193*, a-a cis:'s:-e: t?e Ofstre cr-site

e a-d 00 crii:. Of tre ins:ect - #

!* 5 Of t*#s iri:i t':-

As state: in :a a 5:5 a :f tr.is repert, Regi n III ;e's:rnel C s .sie: i tne concerns of t5is irs:e:tien witn Mr. R. Tuetsen en May 10 5 : l '. .

1954 by tele:m:ne. On May 25, 1952, Mr. R. Lc.e teie;P.cr.icall . :*e-sente: the fincirgs of this ins;ection to Mr. R. B. Klingler (CEC: Sj : 9 Stati n staff). The licensee ackncwlec;ed this information.

4 15 ft-d9

1, .

Binder ja ceci,, Attachment F ./

UNITED STATES 2

• NUCLEAR REGULATORY COMMIS$10N

'i.- . 3 i ^^

r( [' g

1. ' 8 REGloN til k+., h' N /

[ 7se moostvtLT moao eLEN ELLYN. 6LLINO15 60137 J A N: - ...- . . .::,

Docket No. 50-454 Docket No. 50-455 Commonwealth Edison Company ATIN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:

This refers to the special inspection conducted by Messrs. D. W. Hayes and K. A. Connaughton on various dates between August 1983 and January 1984, into allegctions concerning construction activities at the Byron Station, Un.its.1,and.2, authorized by NRC Construction Permits No. CPPR-130 and No. CPPR-131 and to the discussion of our inspection findings on January 18, 1984, with Mr. R. Tuetken.

The enclosed copy of our inspection report identifies the allegations inspected and documents the status of other allegations that had not been Hearings resolved at the in August close of the Byron Unit 1 Operating License (OL) 1983.

inspections as of NovemberThe report also summarizes the Region Ill 22, 1983 relative to the Commonwealth Edison Company item 82-05-19. reinspection program implemented in response to noncompliance No.

courseitems _of noncompliance of.this inspection. with NRC,,r_equirements were identified during the 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.

quirements of 2.790(b)(1). Such application must be consistent with the re-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.

F-1

Commonwealth Edison Company

' ~

We will gladly discuss any questions you have concerning this inspection. "

Sincerely, W?

R.C. Knop, Chief [

Projects Branch 1

Enclosure:

Inspection Reports No. 50-454/84-02(DPRP);

No. 50-455/84-02(DPRP) cc w/enel:

D. L. Farrar, Director of Nuclear Licensing V. I. Schlosser, Project Manager Gunner Sorensen, Site Project Superintendent R. E. Querio, Station Superintendent DMB/ Document Control Desk (RIDS)

Resident Inspector, RIII Byron Resident Inspector, RIII Braidwood Phyllis Dunton, Attorney General's Office, Environmental Control Division Ms. Jane M. Whicher Diane Chavez, DAARE/ SAFE Mitzi A. Young, ELD F-2

r U. S. NUCLEAR REGULATORY COMMISSION REGION III Reports No. 50-454/84-02(DPRP); 50-455/84-02(DPRP)

Docket Nos. 50-454; 50-455 Licenses No. CPPR-130; CPPR-131 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Byron Station, Units 1 and 2 Inspection At: Byron Site, Byron IL Inspection Conducted: Various dates between August 2, 1983, and January 18, 1984

/d Inspectors: D. W. Haye

~

//27 Date OY

% a.Connat C h[ghton K. A. 1 !2.7 ! E'/

Date V

Approved By:

h R. C. Knop, Chief

n. 2 - A A$

Projects Branch 1 Date Inspection Summary L Inspection on various dates between August 2, 1983 and January 18, 1984 i

- (Reports No. 50-454/84-02(DPRP); 50-455/84-02(DPRP))

l Areas Inspected: 3pecial inspection into allegations concerning construction l activities. The report also documents the status of other allegations that had not been resolved at the close of the Byron Unit 1 Operating License Hearing in August 1983. Report also summarizes RIII inspections as of l November 22, 1983 into the CECO reinspection program. The inspection involved  ;

a total of 48 inspector-hours onsite by two NRC inspectors including 18 inspector-hours onsite during offshifts.

Results: No items of noncompliance with NRC regulations were identified.

8 F-3 v - - - + w -- --.m , - - --w- ._ ,. % --.-e em -.9w--- v-

DETAILS

1. Persons Contacted Commonwealth Edison Company (CECO)

,R. Tuetken, Assistant Construction Superintendent M. Stanish, QA Superintendent R. Klingler, QC Supervisor R. L. Byers, Project Construction Engineer Hatfield Electric Ceepany (HECo)

T. Hill, Quality Assurance Manager Greg Cason, QC Inspector, level II The inspector also contacted and interviewed other licensee and contractor employees.

2. Introduction At the close of the Byron OL Hearings on August 12, 1983, into Contention 1, quality assurance / quality control, two main issues remained that had not been fully addressed. These issues were:

31 allegations concerning construction activities of the Hatfield Electric Company Commonwealth Edison Company's construction reinspection program implemented in response to Region III inspection finding 82-05-19.

The purpose of this report is to briefly summarize the status of these items and provide the inspection report references where details are documented. The report also addresses five allegations not previously documented. Two of the five are part of the original 31 allegations.

The remaining two were received during or subsequent to the close of the Hearings on August 12, 1983.

I i

l i

l l

l 2 F-4 L

3. Allegations

a. Allegation A11eger advised that a DR had been written for excessive amounts of dirt and debris on top of motor control centers. For the previously cited reasons, the DR was refused, wasn't voided, was destroyed and the DR number reissued. Similarly, another DR was written for a linear crack in a steel beam. This DR cannot be found and the number has been reissued.

Finding i

The portion of the allegation concerning housekeeping was addressed in NRC Inspection Report No. 50-454/82-17; 50-455/82-12 (Page 7 Item C). The text of the DR (Deficiency Report) in the Hatfield ,

DR log book did not match the text of the DR of the same number ,

provided by the alleger. However, the allegation could not be proved or disproved because DR forms are easily available to inspectors and were not pre-numbered and the Hatfield DR log at that time was a loose-leaf type (subsequently the log was changed to a bound type). The housekeeping problem documented on the DR provided by the alleger had been corrected as verified by the NRC inspector. ,

Tbh DR concerning a lines.r,. crack in a steel beam had not been destroyed and the number reissued as alleged. A review of the DR, other records, and discussions with cognizant personnel established  ;

the following:

i The beam was number 6AB186, located underside of elevation 426 foot framing in the Unit 1 Auxiliary Building and is shown on S&L Drawing S-1293. The beam is 36 inches wide by ,

182 pounds (W36 x 182) and from standard tables the flange '

would be 1 3/16 inches thick and the web 3/4 inches thick.

The linear indication was not a hairline crack but rather was l a 4 inch long scratch, apparently caused by a tool used to remove fireproofing material. The indication (scratch) was less than 1/32 inch deep. (The fireproofing material was

! removed to install an additional support.)

V The DR was forwarded by Hatfield Electric Company to a CECO j

engineer who in turn forwarded it to Blount Brothers Corporation (BBC) for resolution. (BBC has responsibility  ;

for structural steel installations in the Auxiliary Building.)

i 3

F-5

.c'

,e f t s

l The indica' tion was repaired by grinding to remove any abrupt changes-in' contour in accordance with BBC Procedure No. 11 Paragraph ~9.0, Weld repair was not required s'ince the t

' depression did not extend below the rolled surface by more than 1/16 inch,limil specified by the procedure.

The beam _hepair.was inspected and.the DR closed out by BBC quality assurance on August 24, 1982.

The Hatfield computer DR record printout and the engineering log showed the DR as closed. The hatfield DR log book showed the-DR as still open, apparently due to an oversight.

Conclusion

~

This allegation was not substantiated and no further action is planned by Region III.

b. Allegation -

/

~

Quality Control, inspectors are being pressured to have all hangers inspected by January 31, 1983.

Findings -

The inspecior tr ed first ,to establish whether or not January 31, 1983'h=d ever been established by Hatfield Electric Company (EECo) as-a projected completion dat'e for hanger inspections. While the inspector did not find documentation which established this date as a tentative completion date, the_ inspector did determine, by document review and interview of the individual employed as QA/QC Hanager for HECo at the time, that the Applicant had, on several occasions requested reports on the status of hanger inspections required to be completed prior to Unit I fuel load and projections, based on committed manpower and best estimates of QC inspector productivity, of hanger inspection completion. For example, a letter dated June 2; 1982 fro.e EECo's QA/QC Manager to l the Applicant's Project Construction lead Electrical Engineer l documented such a ' projection and estiented hanger inspection l completion'by October 1,.1982. The former HECo 'QA/QC Manager

~

indic'ated that he held weekly meetings with lead QC inspectors to discuss inspection program status, any problems j encountered by inspectors, and productivity of inspection persour.e1. During these meetings.,jt was not uncommon to reference these projected completion dates for har.ger inspections as goals that, in arder to achieve,

~

required continued accountability, on the part of Lead Inspectors, for~the productivity of indieidual inspectors under their super-vision. The alleger implied, but did not directly state, that QC inspections were being compromised by the establishment of these goals for completion of hanger inspections. The alleger did not 4 F-6

^

+

provide any examples of inadequate inspections resulting from these projections of hanger inspection completion dates. If

' Janua ry 31, 1983, had been established as a projected completion date for hanger inspections. The projection was far from accurate. Not only were initial hanger inspections incomplete as of that date, a very large number of additional hanger inspections were required by the reinspection program established by the Applicant in responsa to noncompliance 454/82-05-19; 455/82-04-19.

Conclusion The establishment of a projected date for completing hanger inspections was substantiated. Meeting this goal assumed a minimum level of QC inspector productivity. That this goal resulted in inadequate QC inspections could not be s7.bstantiated.

c. Allegation Carpenters and ironworkers at Byron are coming to work under influence of marijuana. Received August 10, 1983.

Findings i

Discussions with the alleger indicated that the information was provided by a f riend who did not want to be identified. The alleger stated that a carpenter who constructed forms for concrete walls in 1977 at the Byron Site told the friend that people were coming to work under the influence of marijuana and were also using it at the site. The friend also told the alleger that some ironworkers have come to work recently who were stoned on marijuana.

The alleger was informed that because of the general nature of the allegations it would be very difficult to investigate. The alleger committ.ed to obtain and provide more specific information and wis told to call collect either the NRC Region III Office or the NRC Byron Site Office. No specific information was provided.

The alleger was last contacted on December 27, 1983, but still could not provide additional or specific information as to worker names, dates of occurrence, equipment identification or building locations. The alleger was again asked to call collect to the Region III or Byron Site NRC Offices if further information was received.

The alleger was informed that in process and completed safety-related work is inspected by quality control inspectors to assure deficiencies are identified and corrected. Further, that the licensee, his agents and the NRC audit, on a sampling basis, quality control inspector activities and the adequacy of completed work.

5 F-7

4 ,

m 4

s , -

While some drug and alcohol use occurs :.n every segment of society, L their use is very difficult to detect ar d control. The licensee has taken steps as discussed below to minimize the effects.

Commonwealth Edison Company and contractor superv3s, ion as well as NRC inspectors are routinely alert to use of drugs or a,lcohol on

.the Byron Site as well as to persons who exhibit aberrint behavior of any kind.

Per discussions with Commonwealth Edison personnel',

workers'~using alcohol on the Byron Site have been caught and ,

discharged from the job. On one occasion a worker was caught using marijuana onsite and was discharged and arrested.

Conclusion This allegation could not be substantiated. No evidence was found',

during special and routine NRC inspections, to indicate safety-related work was not being properly performed due to drug or alcohol use or that deficiencies,-that may have been caused by a worker under the-influence, bere not identified and corrected. No further action on this matters is planned . s.

by Region 11I.'['

d. Allegati5n '

Welders at Byron smoke pot and drir.k 'eer,on the job.

Received August 12, 1983.- - '

Finding \'

, , cs i. _

The slleger could not provide specific initfmation' and declined to identify the source of in'rornation. Tbc alleger was asked to call the Region III'or Byrosi' Site NRC Office if additional or specific information was obtained. The alleger was last contacted on December 27,-1983 and did not provide ady further information.

The allese'r was again requested to notify the Region III or Byron Site NRC Office should additional information be obtained.

s This allegation was investigated in conjunction with the allegation documented in Paragraph 3.c above, and basically the same discussion was held and the same information provided to each\ alleger.

Conclusion This allegation'could not be substan.> J. Ne further action on this matter is planned by Region I'i.

s 6

F-8

. t s

e. Allegation Unistrut hanger members are being welded to plates with wedge i anchors installed. Wedge anchors are thereby being subjected to excessive heat and stress.  ?

Finding i

This allegation could not be substantiated and is considered closed. Details of the resolution are contained in NRC Inspection Report No. 50-454/83-39; 50-455/83-29 on Pages 51 and 52, Item 1.

f. Allegation The electrical area at Byron Station is going to be another i Zimmer. t Finding This allegation, which was originally documented as a comment, does not provide any specifics and is of a highly subjective nature. This matter is addressed in NRC Inspection Report No. 50-454/83-41; 50-455/83-31 on Page 5, Item d and is considered closed.

g. Allegation '

r Cable pan covers are removed and reinstalled without QC inspection as required for initial installation.

Finding At the time the allegation was received, permanent cable pan covers had not been installed. This problem was identified by the NRC inspector prior to receipt of the allegation and is documented in Inspection Report No. 50-454/82-05; 50-455/82-04 as open item 454/82-05-15; 455/82-04-15. This open item was subsequently resolved in Inspection Report No. 50-454/83-16 (page 4).

h. Allegation PTL (Pittsburgh Testing Lab) inspectors detailed to HEco l

(Hatfield Electric Co.) were told not to discuss problems with PTL supervisors. '

i l

7 F-9

Finding This allegation is addressed in NRC Inspection Report No. 50-454/83-41; 50-455/83-31 (Page 4 Item b). PTL inspectors, detailed to HEco, report administrative 1y to supervision at PTL and functionally to supervision at HECo. Although the allegation may be true it is not considered significant because methods of escalating inspector concerns are prescribed in writing and all inspectors including those detailed to HECo are given indoctrination training which includes a presentation on these avenues for having their concerns resolved.

i. Allegation Hatfield Electric has n extensive training and retraining program which "doesn't accomplish anything." In December 1981, Hatfield only had four inspectors, but now has 85. The program has not been able to handle and adequately qualify the number of new inspectors.

Finding This allegation is addressed in Inspection Report No. 50-454/82-17:

50-455/82-12 on Pages 6 and 7, Item (4). At that time the inspector determined that training and requalification of Hatfield QC inspectors was being closely monitored by the licensee. The item was left open pending further evaluation as to the effectiveness of the training. Followup and closeout of the allegation is docu-mented in Inspection Report No. 50-454/83-37 (Page 7 bottom of paragraph closing unresolved item 50-454/82-17-07; 50-455/82-12-07).

The allegation was not considered substantiated.

j. Allegation Weld undercut is a widespread and serious problem.

Finding The resolution of this allegation is discussed in Inspection Report No. 50-454/83-39; 50-455/83-29 on Pages 41 and 42,

[ Item 7.a (hereafter this report is referred to by 83-39).

The allegation could not be substantiated and is considered closed.

8 F-10

t I

k. Allegation Some bangers do not have weld travelers for the aux steel.

Finding This allegation is addressed in Inspection Report No. 83-39 on Pages 42 and 43, Item 7.b. The allegation is true; however, the problem was independently identified by the Hatfield quality program and corrective action initiated.

This matter remains open pending completion of the correction action and evaluation by the NRC inspector. The tracking number is 454/83-39-01; 455/83-29-01.

1. Allegation A large number of welds performed in 1979 and 1980 that were accepted as satisfactory in reality do not meet AWS requirements (40%) due to procedural deficiencies (i.e. lack of; QC hold points for preheat verification, temperature stick logs, etc.).  ;

Finding Resolution of this allegation is documented in Inspection Report ,

No. 83-39; on Pages 43 and 44, Item 7.c. The allegation could not be substantiated and is considered closed.

m. Allegation ,

For certain hangers covered with fireproofing insulation and for which weld. travelers were missing, the insulation was removed and '

L welds reinspected. A reject rate of approximately 90% has been established for these welds.

. Finding i

' Resolution of this allegation is documented in Inspection Report No. 83-39; on Page 44, Item 7.d. A reject rate of approximately 90% could not be substantiated. '

n. Allegation A " Unit Surveillance Walkdown" of a system (not specified) performed by Pittsburgh Testing Labs and Ceco resulted in a 38% weld rejection rate.

Finding l The resolution of this allegation is documented in Inspection Report No. 83-39 on Pages 44, 45, 46 and 47, Item 7.e. The allegation although substantiated was made after the reinspection '

program had started. This allegation is considered closed.

9 F-ll

o. Allegation In Drawing Area 03051 or 13051 (426' level) 64 hangers were to be checked. Of the 36 or 37 hangers with all welds accessible, 14 had bad connections. The inaccessible welds had to be accepted on the strength of the weld cards. Authorization to remove insulation to inspect welds was denied.

Finding This allegation is addressed in Inspection Report No. 83-39 on Page 47, Item 7.f. The allegation was substantiated in part and is considered closed. i

p. Allegation Panels in Unit I containment supplied by Systems Controls Corporation have welds that are not to code (AWS) in that they are undersized (3/8" vs 5/8").

Finding The resolution of this allegation is documented in Inspection

. Report No. 83-39 on Pages 47 and 48, Item 7.g. The 3/8 vs 5/8 inch undersized welds could not be substantiated. This report indicates that the only welding Hctfield performed on the panels was the termination of the elettrical connections.

Further review subsequent to the inspection indicate that this statement is incorrect in that Hatfield did weld some braces in panels supplied b; System Control Corporation. This item is reopened pending further review. The tracking number is 50-454/84-02-04; 50-455/84-02-04.

q. Allegation Some welds that have been covered with fireproofing are only  ;

tackwelded. When found, a traveler is written without a Discrepancy Report being written.

Finding t t

Resolution of this allegation is documented in Inspection Report No. 83-39 cui Pages 48 and 49, Item 7.h. The allegation concerns incomplete welds being covered by fireproofing insulation. Since welding was not completed, weld travelers indicating weld comple-tion and QC inspection did not exist. Had the welds been previously accepted, a Discrepancy Report as indicated by the alleger should have been written but this was not the case. This allegation although true in part (i.e. two welds were found tackwelded) is not considered significant and is closed.

l l

i

(

10 F-12 l _ . _ . .

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

i I

I

r. Allegation An inspection by alleger revealed a weld not to plan. The welder indicated on the traveler was neither onsite, nor issued weld rod on the date indicated on the traveler. A person asked alleger to change the date on the traveler.

A11eger stated that he would not. '

Finding i

This allegation is addressed in Inspection Report No. 83-39 on Pages 49 and 50, Item 7.1. The allegation could not be substantiated and was considered closed in the referenced report. However, further review indicates additional information is available and further inspection is needed r to fully resolve this item. The item is thus reopened and will  ;

be tracked as Item No. 50-454/84-02-01; 50-455/84-02-01. ,

s. Allegation

" General surveillance of this project illustrates that I approximately 90% of the 'B' welds on DV-164's are 1/8" ,

undersize where tube steel has been used. In most cases this represents a 40% decrease in size and 55% in strength."

Finding  ;

Resolution of this allegation is documented in Inspection i Report No. 83-39 on Page 50, Item 7.j. The report states l

that the allegation could not be substantiated. Technically  ;

this is correct but the fact that 2 of 18 "B" welds were 7 identified as undersized on DV-162's rather than DV-164's

• as alleged indicates the allegation has some validity. This item is thus reopened pending further review and verification of corrective action. (454/84-02-02; 455/84-02-02)

t. Allegation The disposition on a DR was false. The report was written for lack of welding pre-heat. The inspector observed the

. process throughout, but the dispositioning engineer took the word of the welding foreman, who claimed pre-heat had been done. The report claimed the weld was removed, but it ,

wasn't. >

Finding This allegation could not be substantiated and is considered closed. Detai.ls of the resolution are contained in NRC Inspection -

Report No. 50-454/83-39; 50-455/83-29 on Page 50, Item k. At the NRC inspector's request the weld was magnetic particle tested and found acceptable. The inspector determined that the weld met all code requirements and there was no visible signs of damage to the '

structural member.

i I

11 F-13 i 6

u. Allegation Allegation: Corrective action is often untimely. Resolution  ;

of discrepancies may take up to four months. This may preclude the Discrepancy Report originator from reviewing the resolution ,

for acceptability. ,

Finding This allegation is addressed in Inspection Report No. 50-454/83-41; 50-455/83-31 on Pages 4 and 5, Item 6.c. Timeliness of corrective action is a concern as discussed in the referenced report. The  ;

alleger's concern that the originator may not have the opportunity to verify corrective actf on does not have potential safety significance. As long as the condition requiring corrective  ;

action is adequately documented (as required) and the individual '

accepting the resolution is qualified, it is not mandatory that i the originator review the resolution for acceptability. No further action in regard to this allegation is planned.

v. Allegation

• Some electricians have told me (alleger) that they have over- '

stressed cables when pulling, even to the point of breaking the cable. The alleger later (on January 10, 1983) provided the "

last name of an individual be said witnessed the overstressing -

of cables during cable pulling.

Finding On August 8, 1983, the individual whose name was provided by the alleger and one other member of a cable pulling crew were inter-viewed. Both stated that they knew of only one instance where a cable was overstressed to the breaking point and that was an l instrument cable. The broken instrument cal < t was replaced and

• both felt the occurrence had been documented. [

The electrical craftsman whose name was provided by the alleger stated that most electrical cables were hand pulled and be did i

not feel that overstressing had been a problem. He added that the only cases he could recall where tension greater than specified

occurred was when cables were pulled back from conduit after the l pulling compound (lubricant) had set up, r

l l l

L 12 F-14

. t t

During an inspection conducted on September 22-25, 1981, the NRC i Region III elecrical inspector did identify that Batfield '

. Procedure No. 10, Revision 10, Issue 2 (Class 1E Cable Installation) ,

did not address how it would be verified that the maximum cable '

pulling tension had not been exceeded when small cables and/or '

instrument cables were pulled. (See Inspection Report No.

50-454/81-16; 50-455/81-12, Pages 4 and 5, Item 1.c). Subsequently .

S&L Drawings 6E-0-3000B Sheets 1 through 5 and Hatfield Procedure '

No. 10 were revised to address the required precautions to be taken when small cables are pulled (see Inspection Report No. 50-454/83-16, Page 3, unresolved item 50-454/81-16-03). ,

During the construction team inspection conducted at Byron Station March 29-31, April 1, 2, 5-9,12-14, and May ll, 1982, and documented in NRC Inspection Report No. 50-454/82-05; 50-455/82-04, an item of noncompliance was issued relative to failure of Hatfield procedures to contain electrical cable rework instructions and requirements to calculate cable sidewall pressure prior to pulling. (See Page 4 of the Notice of Violation, Item 3.c, identified in report as noncom-pliance item No.50-454/82-05-09c, 50-455/82-04-09c). Ceco's initial response to this item contained in CECO's letter W. L. Stiede to J. G. Keppler dated July 30, 1982 was rejected. (See NRC letter C. E. Norelius to Cordell Reed dated September 22, 1981, Page 2.)

CECO subsequently committed to take appropriate corrective action and this item was closed in NRC Inspection Report No. 50-454/83-16, Page 3.

The following documents a brief review of the development of HECo Procedure No. 10 (Class IE Cable Installation).

Revision 3 Issue 3 (Approved by Sargent and Lundy on Septeinber 7,1979, implementation date not determined)

Procedure did not require cable tension measurements for either machine pulled or hand pulled. Information was provided on

[ maximum tension by cable type and minimum bend radius. Neither Procedure 10 or the S&L drawings addressed factor for sidewall pressure.

Revision 4 Issue 1 (issued August 5, 1980, S&L approval or implementation date not determined).

No new requirements relative to measuring cable tension.

Additional clarification provided on calculating cable l

tension.

Revision 10 Issue 2 (implemented September 24, 1981).

Requirement made for measuring cable tension for all machine pulls. QC inspectors required to monitor and record installed tension measurements for machine pulled cable. QC monitoring of tension for hand pulled cables was

! optional.

j 13 F-15 L

Revision 14 (implemented February 15, 1982).

I Made cable tension measurements manditory for all pu11s machine or hand. QC inspector still not required to monitor or record tension for hand pulled cables.

Revision 15 1ssue 2 (implemented August 7, 1982).

Section added to address cable rework. Original QA/QC requirements apply to cable rework.

S&L Drawing 6E-0-3000B Rev. D, dated November 5,1982, issued to include sidewall pressure factor in calculating maximum cable pulling tension.

Revision 16 (implemented December 17, 1982).

QC inspectors required to monitor and record installed tension for all cable pulls.

Hatfield Procedure No. 10 Revision 16 and subsequent approved revisions presently requires the following relative to cable pulling tensions:

The maximum recommended cable pulling tensions will be determined by Hatfield Engineering Department in accordance with the criteria on S&L Drawing 6E-0-3000B unless otherwise approved by CECO.

The recommerA ; maximum pulling tension based on the minimum radius allowed for the size of conduit installed (and S&L Drawing 6E-0-3000B) will be documented on Form HP-105 and provided to the Hatfield QC Department.

The QC inspector will monitor (w!th a dynamometer) and record the installed tensions for all machine and hand pulls.

All information will be entered on Form HP-105.

If the installation tension exceeds the maximum recommended tension, the pull is completed and the maximum installation e tension is documented on Form HP-105 and a HECo Discrepancy Report (DR) is issued.

I l

l i

! 14 F-16 l

HECo Engineering reviews the DR and recalculates the maximum allevable pulling tension based on the "as built" configuration of the conduit rather than the minimum (the actual bend radius is generally larger than the minimum allowed).

If the actual pulling tension exceeds the recalculated maximum then a nonconformance report (NCR) is issued and sent to CECO /S&L for resolution. ,

A cursory review of the NCR log for the period February 24, 1982 through January 12, 1984 indicated that at least 25 NCRs concerning over tensioning of cables had occurred. Fourteen of these were still open as of January 14, 1984. Most of the NCRs had been issued in 1983 subsequent to receipt of the allegation.

The DR log was also reviewed but did not contain enough detail to identify a DR concerning cable over tensioning.

Discussions with cognizant Hatfield QC personnel indicated that the number of over tensioned cables was not unusual considering the several thousand cables being installed and that when over tensioning did occur it was documented and properly resolved.

Documentation relative to the broken instrument cable was not located but only a cursory review was performed.

This item remains open pending further and more detailed review of the records, discussions with other QC inspectors and electrical craftsmen and verification of corrective action on: (1) cables identified on DRs and NCRs as over tensioned, and (2) cables installed prior to when installed tension measurements were required. (50-454/84-02-03; 50-455/84-02-03)

w. Allegation A11eger claimed to have reviewed the qualification records of the Hatfield and Pittsburgh Testing electrical inspectors.

A11eger considered ocly about six of eight Level II inspectors '

to be qualified for the position they hold. As an example, the lead inspectors had background in civil, not electrical, inspectien.

Finding This allegation is true but the item was previously identified during the team inspection at Byron Station and is being tracked as an item of noncompliance, No. 454/82-05-19; l 455/82-05-19. Also see NRC Inspection Report No. 50-454/82-17; 50-455/82-12, Item 3.b.(1) on Pages 4 and 5.

l 1

15 F-17

Twenty-three (23) of the 31 allegations still unresolved at the close of the Byron OL Hearing were assigned to NRC Region III for resolution.

Inspection into 2 of those 23 has not been completed, i thus no information as to these can be provided at this time.

4. Allegations Investigated by OI (Office of Investigation)

Eight of the 31 allegations received but not resolved at the close of the Hearings on August 12, 1983 had been referred to OI because they involved possible wrongdoing.

OI has completed their investigation into these allegations but results have not been released as of January 13, 1984. Per l discussions with the Region III Director of OI on January 4,1984, the final draft of their report has been completed and is under

• review by OI management. '

5. Summary of NRC Followup Inspections Concerning Noncompliance 454/82-05-19; 455/82-04-19, " Inadequate Training and Improper Certification of Contractor QC Inspectors"

a. Background The reinspection program was implemented to determine the validity of inspections performed by quality control inspectors whose qualifications were in question because of deficiencies identified in the Byron Station contractor's evaluation and certification of quality control inspectors. The initial deficiencies in certifying quality control (QC) inspectors were identified during an NRC inspection documented in Report Nos. 50-454/82-05 and 50-455/82-04.

The reinspection program was defined in a letter dated Februa ry 23, 1983, from Mr. W. L. Stiede, Assistant Vice President, Commonwealth Edison Company to Mr. J. G. Keppler, NRC Region III Administrator. Basically, the program consisted of the following:

For six of the eight contractors every fifth inspector (20%)  ;

was selected from a chronological listing based on the date of certification of each QC inspector certified since the beginning of the project. Further a minimum of three additional inspectors for each contractor was selected by the NRC Senior Resident Inspector. Each individual inspection performed during the first 90 days by the selected contractor inspectors were reinspected where uccessible.

For the remaining two contractors, each individual inspection performed during the first 90 days of each QC isspector  ;

(100%) certified since the beginning of the project was reinspected where accessible.

16 F-18

Inaccessible inspections were defined as those which would require dismantling to gain access (e.g. embedded or buried in concrete, internal alignments, etc.) or where the process was an event which could not be recreated. Fireproofing, insulation, etc. did not make the item inaccessible and was removed where necessary to conduct the inspection.

Provisions were contained in the program to make another selection if all or most of an inspector's inspections were inaccessible.

Provisions also existed in the program to increase the sample size, both as to the number of inspections made by a selected inspector or the number of inspectors selected to have their initial work reinspected, if an unacceptable number of rejectable defects were identified during the reinspections.

b. Inspection Report Nos. 50-454/83-26; 50-455/83-19 (Inspection Conducted June 7-10, 1983)

This report documented a special inspection conducted on the overall status of the reinspection program. In particular, the inspectors examined each contractor to determine approximate percentages of all inspectors whose first 90 days were initially subjected to reinspection, actual numbers of inspectors included for initial reinspection population and approximate percentages of initially required reinspections completed to date. The inspectors examined in more detail, the program status for four key contractors; Hatfield Electric, Hunter Corporation, Johnson Controls Incorporated and Pittsburgh Testing Laboratory. For these contractors, the inspection report detailed functional areas being reinspected, attributes included in each functional area and, a summary of reinspection results, accumulated from the beginning of the program up until the time of the NRC inspection. The results were obtained directly from the contractors and had not t

yet been subjected to review by the independent Level III inspector as provided for in the program.

It was determined during this inspection that, to date, CECO Quality Assurance had not yet conducted any audits of reinspection program implementation, though CECO QA personnel did state that l

such audits were planned. This matter was documented as Unresolved Item 50-454/83-26-01; 50-455/83-19-01 pending NRC review of future Ceco QA activity in this area.

I L 27 F-19 i

c. . Inspection Report No. 50-454/83-37 (Inspection Conducted on i August 8-12, 16-19, and September 7-9, 1983

[

This inspection consisted of a review of reinspection program results accumulated from the beginning of the program up until l August 15, 1983 for two Byron Site contractors; Powers-Asco-Pope  !

and Hatfield Electric Company. The inspection report documents reinspection results obtained directly from the contractors and l not yet subjected to independent, third party, Level III inspector l review. The results are presented by inspector, attributes  ;

inspected, total number of inspections for each attribute and,  !

number of rejects for each attribute. In addition, the report i Provides a breakdown of rejected items including, for each '

attribute reinspected, a description of the specific basis for  ;

rejection and the number of items rejected on each specific basis.  :

A similar breaMown of items rejected based upon visual weld i re-examinations was not provided in this report but was included '

in NRC Inspection Report Nos. 50-454/83-39; 50-455/83-29, discussed below.

t

d. Inspection Report No. 50-454/83-38; 50-455/83-28 (Inspection Conducted on August 3-4, 8, 1983)

This inspection report documents concerns identified by NRC -

inspectors concerning Hatfield Electric Company quality control inspection documentation utilized to identify items previously [

inspected by inspectors selected for reinspection. Hatfield  ;

Electric Company's documentation system did not readily lend  ;

itself.to sorting inspection reports by QC inspetor nor were i superseded inspection reports so identified. As a result, the NRC inspectors were concerned that items identified for reinspection may have been subject to rework, modification or  ;

removal since originally inspected by the selected inspector.  ;

In such cases the item would not be representative of the selected inspector's work. This concern was identified to  ;

the Applicant in a meeting held on August 4,1983. The  !

Applicant agreed to review the matter and establish measures, ,

as necessary, to assure that reinspection of Hatfield Electric 7 Company work would encompass only those items which would be representative of the selected inspector's work. Followup on t this matter will be included in the NRC Region III's review and  ;

evaluation of the reinspection program.  !

e. Inspection Report Nos. 50-454/83-39; 50-455/83-29 (Inspection l

Conducted on August 8-12, 15-19, 22-23, 29, September 2, 8-9,

l 12-15, 22, 26-26, November 16-17 and 22, 1983) t t

This inspection of the Applicant's reinspection program, by  !

, far the most comprehensive performed by NRC Region III to date,  :

l was performed after the vast majority of required reinspections  ;

i l 18 20 r

were_ completed. The report provided an overview of the program  !

including analysis, by contractors, of: the quantity of inspectors whose work was reincpected versus the total number of individuals employed as inspectors over the time period in which work subject to reinspection was performed; the quantity i of items reinspected; the number of inspectors qualified in a given area versus the number of inspectors in that area whose work was reinspected and; inspector performance based upon initial i reinspection of subsequent work required based upon the results i of reinspection of the first 90 days work and, any required reinspection of work performed by inspectors not originally selected but added to the population due to previous reinspection results.

Following the overview described above, the report documents review of inspector certification records for Midway Industrial  ;

Contractor, Inc., whose work was not subject to reinspection due l to unrecreatability of inspection attributes or inaccessibility for reinspection.

The next section of the report documents review of weld inspector certification packages and weld reinspection results, including independent visual examination of numerous reinspceted welds by an NRC inspector. The contractors included in this review were: .

Hatfield Electric Company, Hunter Corporation, Nuclear Installation  !

Services Company, Pittsburgh Testing Laboratory, Powers-Azco-Pope, Johnson Controls Incorporated, Blount Brothers Corporation and, Reliable Sheet Metal Works Incorporated. Review of what the '

Applicant determined to be the 100 " worst case" welds identified l by reinspection, the disposition of welding discrepancies identified by reinspection and NRC inspector observations concerning the performance and results of weld re-examinations for all contractors l were documented and included in this section of the report.

The last section of the report dealing with the reinspection program concerns review of safety-related component handling, installation, and protection. A summary of reinspection results by inspection type (documentation, hardware, welding and bolt i torque) is provided for thrre contractors, Hunter Corporation, L Nuclear Installation Services Company and Johnson Controls Incorporated.

f. Additional NRC Review Performed or Planned NRC Region III Staff reviewed the Applicant's Preliminary Report on the reinspection program results submitted October 28, 1983.

19 F-21

As a result of this review the Applicant was notified by telephone on November 10, 1983 and subsequently by letter dated November 18, 1983 that the following comments be incorporated into the final report:

(1) The report should be drafted in accordance with the original program. Specifically, the tables and conclusions based ,

on those tables should be based on the findings of the Level II examiner or the independent Level III examiner.

Use of a Ceco Level III examiner to change the results ,

[

of the independent Level III findings is not in accordance  ;

with the original program.

(2) Provide tabulation of the results of inspection attributes (weld overlap, undercut, etc.) in order to determine the need if any, for further inspections. This tabulation could be made available to our inspectors, and need not be in the report, but as a minimum, the conclusions you have reached regarding the tabulations should be included in the report. ,

(3) Review different inspection activities and determine if certain areas such as final hanger inspections warrant further review based on reject rates.

As a result of incorporating comment 1 in the evaluation of reinspection results, the Applicant determined the need for additional  !

reinspections. Subsequently, the Applicant submitted his final ,

report dated January 12, 1984 which included the results of these additional reinspections with the exception of reinspections of one Hatfield Electric Company visual weld inspector's work. The Applicant will provide these results in a future supplement to the final report.

The NRC Region III staff will review the final report to determine whether a need for further reinspection or other corrective action in response to Noncompliance 454/82-05-19; 455/82-04-19 is warranted.

Region III inspectors will also perform additional hardware inspections to verify reinspection program results and as part of the NRC's '

routine inspection program. <

6. Exit Meeting  !

The inspection findings were discussed with Mr. R. Tuetken on January 18, 1984.  ;

[

E 20 P-22

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

s

[ ', Binder UNITE 3 STATES Attachment G T ~ [percqIo, , NUCLEAR REGULATORY COMMISSION t

,5

,*'r ( g' Q CIEGioN l18

- 3 8 199 noosEvtLT no Ao e h ' ' / r.[ GLEN ELLYN. ILLINOtS 40137

%y . .-s...s I'.I' 13 U04 Docket No. 50-454 Docket No. 50-455 Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen: '

i-This refers to the special safety inspection conducted by Mr. R. S. Love of this office on January 23-27, 1984, of activities at Byron Station authorized by NRC Construction Permit No. CPPR-130 and No. CPPR-131 and to the discussion of our findings with Mr. G. Sorensen 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 exam-ination 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. 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 t,o 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.

G-1

c Commonwealth Edison Company 2 ~ ".15 1534 We will gladly discuss any questions you have concerning this inspection.

Sincerely,

[. C W. . Little, Chief Engineering Branch 2 Enclosurer:

1. Appendix, Notice -

of Violation

2. Inspection Reports No. 50-454/84-09(DE) and No. 50-455/84-07(DE) cc w/encls:

D. L. Farrar, Director of Nuclear Licensing V. I. Schlosser, Project Manager Gunner Sorensen, Site Project Superintendent R. E. Querto, Station Superintendent DMB/ Document Control Desk (RIDS)

Resident Inspector, RIII Byron Resident Inspector, RIII Braidwood Phyllis Dunton, Attorney General's Office, Environmental Control Division Ms. Jane M. Whicher Diane Chavez, DAARE/ SAFE G-2

_ m _

Appendix

, NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-454 As a result of the special safety inspection conducted on January 23-27, 1984, and in accordance with the NRC Enforcement Policy, 47 FR 9987 (March 9, 1982),

the following violation was identified:

10 CFR 50, Appendix B, Criterion XVI, as implemented by Ceco Topical Report CE-1-A, Section 16, requires that measures be established to assure that conditions adverse to quality are promptly identified and corrected.

Contrary to the above, the failure of Hatfield Electric Company to provide an adequate response on DR 3382 has resulted in 12 safety-related electrical cables being installed in Byron Station, Unit 1, whose quality is indeterminate in that one or more of these cables was overstressed during the attempted pull-back of cable IVA709.

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 tic:e for good cause shown.

/?

Dated /' W. S. LitQe, Chief

/

Engineering Branch 2 G-3

- -. ,,,..n --

- *^ ^*

o U.S. NUCLEAR REGULATORY COMMISSION

, REGION III Reports No. 50-454/84-09(DE); 50-455/84-07(DE)

Docket Nos. 50-454; 50-455 Licenses No. CPPR-130; CPPR-131 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, Illinois 60690 Facility Name: Byron Station, Units 1 and 2 Inspection At: Byron Site, Byron, Illinois Inspection Conducted: Janua ry 23-27, 1984 Inspector: R. S. Love _J // $ T/

Date Approved By: C. C. Williams, C Plant Systems Section

_3 //f FM

~ ~

Date Inspection Summary

_ Inspection on January 23-27, 1984 (Reports No. 50-454/84-09fDE):

50-455/84-07(DE))

Areas Inspected: Review of licensee action on previously identified items.

Followup on an allegation that safety-related electrical cables had been over-tensioned during installation. This allegation was substantiated by the review of records and personnel interviews. This inspection involved a total of 40 inspect ~or-hours by one NRC inspector.

Results: In the areas inspected, one item of noncompliance (inadequate disposition on a Deviation Report - Paragraph 3.c) was identified.

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t DETAILS

1. Persons Contacted Commonwealth Edison Company

• G. Sorensen, Construction Superintendent

• K. J. Hansing, Quality Assurance Superintendent

• J. O. Binder, Project Electrical Supervisor

• E. L. Martin, Quality Assurance Supervisor

• H. Dellabetta, Quality Assurance Engineer >

• E. Sager, PCD Electrical Engineer

• J. W. Rappeport, Quality Assurance Engineer R. B. Klingler, Project Quality Control Supervisor M. E. Lohmann, Assistant Construction Superintendent Hatfield Electric Company (HEco)

D. L. Heider, QA/QC Manager

.The inspector-also contacted and interviewed other licensee and contractor

' personnel during this report period.

• Denotes those present at the exit interview conducted on January 27, 1984.-

2. Action on previously Identified Items

a. (Closed) Open Item (50-454/82-17-03; 50-455/82-12-03): This item pertained'to the conflict between the SAR commitment to the 1972 edition of the'AWS DI.1 Code and the implementation of the 1975 edition by the electrical contractor. SAR Amendment 44, dated December 1983, revised Table 3.8-2 to delete Code edition. Effective i

Code edition will be determined by the date of the applicable contracts,

b. (Closed) Open Item (50-454/83-16-03): This item pertained to the damaged cable documented on NCR 597 and the misrouted cables caused by improper labeling of conduits. Thefdamaged cable was replaced and FCR F-22863 was issued to show'as-built conditions for conduit markings and cable routing.

c. (0 pen) 10 CFR 50.55(e) Report (50-454/83-11-EE; 50-455/83-11-EE):

After completion of the Hot Functional Testing at Byron Station Unit 1, the covering on the Anaconda Type NWC flexible conduit utilized inside the containment was observed to be split open on several installations. All liquid tight flexible conduits inside Unit I and Unit 2 containments are being covered with Okonite T-35 Jacket tape. This tape is qualified for containment environment.

As of the date of this inspection, Unit'l is approximately 95% com-plate. This item must be closed for the applicable unit prior to loading fuel.

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r l

3. Follow-up on Allegations The Region III office received an allegation that some safety-related '

electrical cables had been overstressed during installation at the Byron Station. As noted below, this allegation was substantiated.

Reference:

Open Item 454/84-02-03; 455/84-02-03. -

Background - Electrical cables may be overstressed by exceeding the maximum pulling tension or sidewall pressure during installation or re-work activities. The information required to calculate these maximum values are normally provided by the cable manufacturer for the various types of cable provided.

s.

A review of CECO nonconformance reports (NCRs) indicated that the following NCRs were prepared to document potential electrical cable overstressing: -

F539, dated April 2, 1981. During the installation of safety-related cables IDC030 and IDC089 (type 1/c-350 MCM) a pulling guide with a 9" radius was utilize 3. Installation tension was 2800#. Per project drawings, a pulling guide with a mimimum of a 18" radius should have been used during the installation acti-vities. Using a 9" radius pulling guide, the maximum pulling tension should have been limited to 375# so as not to exceed the maximum cable sidewall pressure. The subject cables were replaced and the NCR was closed on September 7, 1982.

F679, dated October 30, 1981. During the installation of safety-related cable 2SXO98 (type 3/c #4/0) a pulling guide with a 6" radius was utilized and cable installation tension was not measured. Per the approved disposition, a High Potential (Hi-Pot) Test at 17 kV for 5 minutes and an Insulation Resistance Test at 2.5 kV de were satisfactorily performed on the subject cable. NCR was closed on March 9, 1982.

F747, dated November 16, 1982. Was prepared to document that the cable pulling tension criteria delineated in ECN 2579, dated May 19, 1982 and ECN 3015, dated October 13, 1932, was not im-plemented by the electrical contractor, HIco, until October 27, 1982. Between May 19, 1982 and November 4, 1982, 133 cables i were installed in conduit where the tension was measured.

Utilizing the criteria contained in ECNs 2579 and 3015, these cable pulls were analyzed by Sargent and Lundy. Upon completion of the analysis, it appeared that 17 of these cables may have been overstressed. All of the applicable data, including sketches of the routing, for these 17 cables was forwarded to the cable manufacturer, Okonite Company, for their analysis.

The Okonite analysis indicated that the 17 cables were accept-able as installed. The Region III inspector reviewed the Okonite analysis and found it acceptable. The NCR was closed on November 10, 1983. This item is also documented on HEco NCR 482.

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F756, dated December 23, 1982. During the installation of safety-related cables IFW217 (12/c #14), IFW262 (2/c #14),

IFW346 (2/c #14),-1FW458 (2/c #14), IFW510 (2/c.#14), IFW561 (2/c #14), IMS282 (12/c #14), IMS283 (12/c #14), IMS325 (2/c

1. 14), ISD054 (7/c #14), ISD058 (7/c #14), and ISD062 (7/c #14) it appeared that the cables had been overstressed. The a'ctual pulling tension was 610#. Utilizing the equation Ta = 0.6 x n x Tes, the maximum allowable tension would be approximately 4750, where: Ta = allowable tension in pounds; a = number of cables in the pull; Tes = maximum pulling tension of the smallest cable in the pull (2/c #14 = 66#); and 0.6 = additional safety factor.

Utilizing equation Ta = 0.008 x em x n x 0.7, as provided by Okonite, the allowable tension would be approximately 1590#.

Equation Ta = 0.008 x em x n is found in IEEE Standard 422-1977 and the safety factor of 0.7 was provided by Okonite. Based on the above information, the subject cables were accepted as installed. Sidewall pressure was not a factor. NCR was closed on July 20, 1983. This item is also documented in HEco NCR 511.

F775, dated January 24, 1983. During the installation of safety-related cables:

1AP183 (HEco NCR 556); 1AP073, IAP320, 1AP322 (HECc NCR 557); 1AP072, IAP319, 1AP321 (HEco NCR 558);

2SX138, 2SX139, 2SX140, 2SX149, 2SX153 (HEco NCR 559); 2AP179, 2AP300. 2AP401, 2SXO79, 2VX044, 2DC072 (HEco NCR 560); IVC 028 (HEco hJR 561); IIP 005, IIP 006 (RECo NCR 562); 11P033, IIP 034 (HECo NCR 563); IVA580, IVA581 (HEco NCR 564); IVA580, IVA581 (HEco NCR 565); IVA558, IVA559, IVA560 (HECo NCR 566) and IVA374, IVA375, IVAS48 (HEco NCR 567) it appeared that the cables had been overstressed. Based on the revised criteria for calculating maximum allowable pulling tension, all cables except 1AP183 were accepted as installed. Cable 1AP183 was Hi-Potted at 29.5 kV de for 5 minutes and was found satisfactory for its intended use. NCR was closed on November 10, 1983.

F799, dated March 14, 1983. During installation of safety-re-lated cable 2EF096 (4/c #14), the cable was overstressed.

Actual pulling tension was 145# and the maximum allowable pul-ling tension was 132#, Okonite performed an evaluation of this cable and found it acceptable as installed. NCR was closed on December 18, 1983. This item is also documented on HEco NCR 579 and Discrepancy Report (DR) 1777.

F800, dated March 14, 1983. During installation of safety-re-lated cable 2VA319 (4/c #14), the cable was overstressed.

Actual pulling tension was 140# and the maximum allowabic pul-ling tension was 132#. Okonite performed an evaluation of this cable and found it acceptable as installed. NCR was closed on December 13, 1983. This item is also documented on HEco NCR 580 and DR 1800.

F802, dated March 23, 1983. During pull back of safety-related cable 1AF279 (2/c #14), it appeared that the cable was over-stressed. Actual pulling tension was 40# and utilizing the 4

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i revised criteria, the maximum allowable pulling tension is 66#. i The cable was accepted as installed, (MECo NCR 586 and DR 1835).

~

During installation of safety-related cables 10G189 (24/c #20) and 1DG187 (2/c #16), it appeared that these cables were over-stressed. Actual pulling tension was 71# and utilizing the revised criteria, the maximum allowable pulling tension is approximately 250#. These cables were accepted as installed. '

This NCR was closed on June 28, 1983, (HECo NCR 588 and DR 1857).

F809, dated April 15, 1983. During rework (pullback) of safety-related cables 1VD119 (2/c #14), IVD120 (2/c #14), and DG042 (2/c #10), the cables were overstressed. For cable IDG042, the maximum allowable pulling tension is 1660 and the actual tension was 195#. Cable 1DG042 was replaced. For cables IVD119 and -

IVD120, the maximum allowable pulling tension is 105.60 and the  ;

actual tension was 110#. These cables were accepted as instal- ,

led based on an evaluation by Okonite. NCR was closed on '

January 9,1983. (KEco NCR 599).

l F821, dated May 20, 1983. During installation of safety-related cable IVA709 (2/c #16), the cable was overstressed. The maximum allowable pulling tension is 58# and the actual tesnion was ,

1 120#. The cable was replaced and the NCR closed October 14,  ;

j 1983, (HECo NCR 605 and DR 2075).

i F827, dated July 8, 1983. During installation of safety-related cable 2VA707 (2/c #16), the cable was overstressed. The maximum [

allowable pulling tension is $80 and the actual tension was 180#. The cable was replaced and NCR closed on October 28, i 1983. (HECo NCR 642 and DR 2458).

F837, dated August 5, 1983. During installation of safety-re-lated cables 2VA786 (2 x 1/c #14), IVA784 (2/c #14), and IVA756 (2/c #14), the cables were overstressed. The maximum allowable pulling tension for each cable is 66#. The actual pulling ten-sion for each cable was 1150, 92/120#, and 100# respectfully.

Cable IVA784 was overstressed (92/120#) in two portions of the ,

pull. As of January 26, 1984, this NCR was still open. These '

items are documented on HECo NCRs 658 (2VA786), 660 (IVA784),

662 (IVA784) and 666 (1VA756).

F838, dated August 5, 1983. During installation of safety re-  !

lated cables 1RC650 (16/c #16), IRC651, IRC652, IRC653, IRC654, IRC655, IRC656, 1R;u57, and IRC658 (IRC651-1RC658 all 3/c #16),  ;

the cables were overstressed. The combined maximum pulling tension for these cables is 354# and the actual tension was j 440#, (KICo NCRs 649 and 650). During installation of safety-related cables 1AR025 (2/c#16) and 1AR160 (2/c #16), the cables were overstressed. The combined maximum pulling tension for [

these cables is 116# and the actual tension was 260#. As of Janua ry 26, 1984, this NCR was still open. t i

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. F839, dated August 8, 1983. During rework (pull back) of safety-related cable ICV 029 (4/c #14), the cable was overstres-sed. The maximum. allowable pulling tension is 132# and the actual tension was'1450. Based on an evaluation *.by Okonite, the calbe was acceptable for re-installation. NCR was closed on January 13, 1984. (HEco NCR 673 and DR 2787). .

. F844, dated August 22, 1983. During rework (pull back) of safety-related cables IFWO20 (2/c #16), IRC395 (2/c #16), and IRC400 (2/c #16), the cables were apparently overstressed. The maximum allowable pulling tension was calculated to be 139# and the actual tension was 175#. Based on the criteria supplied by Eaton, cable manufacturer, the maximum allowable pulling tension for these cables is 176.4#. The cables were acceptable for re-installation. NCR was closed on November 17, 1983. (KEco NCR 681). ,

. F845, dated August 20, 1983. During installation of safety-related cables IAP149 (3/c #500 MCM) and 1AP152 (3/c #500 MCM),

the cables were'overstressed. The maximum allowable pulling tension due to sidewall pressure limitations is 3000#. The actual pulling tension for cable 1AP149 was 5400# and 5754# for cable 1AP152. As of January 24, 1984, this NCR was still open, (EECo NCR 687).

. F865, dated November 17, 1983. During installation of safety-related cable 2VA787 (2/c #14), the cable was overstressed. The maximum allowable pulling tension is 66# and the actual tension was 115#. As of January 24, 1984, this NCR was still open (EECo NCR 769 and DR 3596).

. F864, dated November 17, 1983. During installation of safety-related cable 2DG105 (4/c #14), the cable was overstressed. The maximum allowable pulling tension is 1320 and the actual tension was 310#. As of January 24, 1984, this NCR was still open (HICo NCR 765 and DR 3523).

i

. F865, dated December 2, 1983. During installation of safety-related cables IVA755 (2/c #14) and IVA795 (2/c #14), the cables were apparently overstressed. The maximum allowable pulling tension is 132# and the actual pulling tension was 138#. As of January 24, 1984, this NCR was still open, (HECo NCR 733 and DR 3687).

Pending a review of CECO NJ.s F837, F838, F839, F845, FS63, F864, and F865 for proper closure, this item is unresolved (50-454/84-09-01; 50-455/84-07-01).

b. A review of HEco NCRs 1-450 and the NCR log for NCRs 451-839 indi-caced that the following NCRs were prepared to document potential overstressing of electrical cables:

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6 G-9 l

Note: Where the nonconformance is described on a Ceco NCR, only the  ;

status of the HECo NCR and a reference to the Ceco NCR will be provided. -

483, Opened October 27, 1982. Closed November 29, 1983.

Reference:

CECO NCR F747.

511, Opened December 2, 1982. Closed January 13, 1983.

Reference:

CECs NCR F756. ,

556, Opened January 24, 1983. Closed January 21, 1984.

Reference:

CECO NCR F775.

557, Opened January 25, 1983. Closed January 21, 1984.

Reference:

CECO NCR F775. .

558, Opened January 25, 1983. Closed January 21, 1984

Reference:

CECO NCR F775.

559, Opened January 25, 1983. Closed January 21, 1984.

Reference:

CECO NCR F775.

560, Opened January 25, 1983. Closed January 21, 19S4.

Reference:

Ceco NCR F775.

561, Opened January 25, 1983. Closed January 21, 1984.

Reference:

CECO NCR F775.

562, Opened January 25, 1983. Closed January 21, 1984.

Reference:

CECO NCR F775.

563, Opened January 25, 1983. Closed January 21, 1984.

Reference:

CECO NCR F775.

564, Opened January 25, 1983. Closed January 21, 1984.

r

Reference:

CECO NCR F775.

565, Opened January 25, 1983. Closed January 21, 1984.

Reference:

Ceco NCR F775.

566, opened January 25, 1983. Closed January 21, 1984.

Reference:

Ceco NCR F775.

l . 567, Opened January 25, 1923. Closed January 21, 1984.

Reference:

CECO NCR F775.

. 586, Opened March 17, 1983. Closed September 6, 1983.

Reference:

Ceco NCR F802 and HECo DR 1835.

. 588, Opened March 18, 1983. Closed September 6, 1983.

I

Reference:

CECO NCR F802 and HEco DR 1857.

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l 579, Opened March 11, 1983. As of January 25, 1984, this NCR was still open.

Reference:

Ceco NCR F799 and HECo DR 1777. ,

~

580, Opened March ~11, 1983. As of January 25, 1984, this NCR was still open.

Reference:

Ceco NCR F800 and HECo DR 1800.

642, Opened July 5, 1983. Closed January 25, 1984.

Reference:

CECO NCR F827 and HEco DR 2458.

605, Opened May 12, 1983. Closed October 17, 1983.

Reference:

CECO NCR F821 and HECo DR 2075.

599, Opened April 12, 1983. As of January 25, 1984, this NCR was still open.

Reference:

Ceco NCR F809.

687, Opened August 12, 1953. As of January 25, 1984, this NCR was still open.

Reference:

Ceco NCR F845.

. 681, Opened August 11, 1983. Closed January 25, 1984

Reference:

Ceco NCR F844 668, Opened August 1, 1983. As of January 25, 1984, this NCR was still open.

Reference:

Ceco NCR F838.

666, Opened July 26, 1983. As of January 25, 1984, this NCR was still open.

Reference:

CECO NCR F837.

662, Opened July 21, 1983. As of January 25, 1984, this NCR was still open.

Reference:

CECO NCR F837.

660, Opened July 21, 1983. As of January 25, 1984, this NCR was still open.

Reference:

CECO NCR F837.

658, Opened July 20, 1983. As of January 25, 1984, this NCR was still open.

Reference:

CECO NCR F837 and HEco DR 2714.

. . 673, opened August 5, 1983. As of January 25, 1984, this NCR was still open.

Reference:

Ceco NCR F839 and HEco DR 2787.

650, Opened July 18, 1983. As of January 25, 1984,'this NCR was still open.

Reference:

CECO NCR F838.

649, Opened July 18, 1983. As of Janurry 25, 1984, th:s NCR was still open.

Reference:

Ceco NCR F838.

. 773, Opened November 17, 1983. As of January 25, 1984, this NCR was still open.

Reference:

Ceco NCR F865 and HEco DR 3687.

. 769, Opened November 9, 1983. As of January 25, 1984, this NCR was still open.

Reference:

CECO NCR F863 and HEco DR 3596.

766, dated November 3, 1983. Cable 2DG070 (9/c #14) was pulled into a conduit without measuring the cable pull tension in 8

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.44 i

T accordance with approved procedures. The cable was pulled back and re-pulled u' tilizing a dynamometer during the entire opera-tion to measure cable pulling tension. The actual pulling tension was 40# and the allowable maximum pulling tension is 296#. Cable 2DC070 was accepted as installed. This NCR was closed on November 10, 1983.

Reference:

HECo DR 3518. -

765, Opened November 3,1983. As of January 25, 1984, this NCR was still open.

Reference:

CECO NCR F864 and HECo DR 3523.

113, dated June 16, 1980. During installation, cable ISI523 (2/c #14) was hand pulled through conduit containing approxi-mately 350' of bends. . Conduit runs are normally limited to 270*

of bends between pulling points. The maxinara allowable pulling tension for 2/c #14 cable is 66#. The calculated pulling tension for this installation was 25.655#. The Region III inspector. reviewed the calculations and they appeared to be adequate. This NCR was closed on May'21,1981.

. 109, dated April 26, 1980. During installation, cables ISXO67 (3/c #10) and 1SX043 (12/c #14) were hand pulled through conduit containing more than 270' of bends. .The maximum allowable pulling tension for these cables was 645# The calculated pulling tension for this installation was 1320. based on the calcula-tions the cables were accepted as installed. 'fhis NCR was closed on May 21, 1981,

c. The Region III^ inspector selected the KECo DRs prepared during the 3rd quarter of 1983 for review. DRs 2468 through' 3362 were prepared during this time frame. Due to the method of filing, the inspector reviewed DRs 2400 through 3400. With respect te possible over-stressing of safety-related cables during installation or re-work, all DRs, except number 3382, were subsequently documented on NCRs and are discussed in paragraphs a and b above. . Tillowing are the Region III observations as relating to DR 3382.

During pull back of safety-related cable 1VA709 (2/c #16). from 21/2" conduit COA 7464.(

Reference:

CECO NCR F821), the other 12 cables remaining in the conduit were overstressed. Based on interviews with HECo craft, engineering'and QC personnel, Ceco engineering personnel and the review of applicable documentation, following is a sequence of events as understood by the Resion III inspectort (1) During the initial installation of cable IVA709, the cable wss overstressed. The maximum allowable pulling tension for this type of cable is 58.8# and the actual pulling tension was 120#.

This fact was documented on HEco DR 2075, KEco NCR 605, and Ceco NCR F821. The disposition on the Ceco NCR was to replace the cable.

(2) On or about October 4,1983, while attempting to remove cable IVA709 from conduit C0A7464, pulling tensions of 250fi, 4500, 1400 and 500# vere exerted on cable 1VA709. At that potat in I

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.4 9 time, the decision was made to abandon that portion of cable IVA709 contained within the conduit. A new cable IVA709 was installed and the applicable HEco and CECO NCRs were closed.

HECo QC inspector prepared DR 3382, dated October 4,1983, to document that the remaining cables (IVA182, IVA185, IVA707, '

IVA712, IVA714, IVA716, IVA720, IVA721, IVA722, IVA723, IVA818, and IVA819) may have been overstressed during the attempted removal of cable IVA709. All cables contained within conduit COA 7464 were 2/c #16 with an individual maximum pulling tension of 58.8#.

(3) During the HEco engineer's evaluation of DR 3382, the engineer erroneously assumed that the cable pulling crew was attempting to remove all of the cables in conduit COA 7464 when the pulling tensions of 2500, 4500,140# and 500# were reached. Using the above assumption, the HEco engineer calculated the maximum allowable pulling tension for all the cables as 557#. Based on the engineer's calculations, the cables were accepted as installed and the DR was closed on October 10, 1983. In that the description of the discrepancy as noted on the subject DR did not contain all of the facts, the inspector can understand how the engineer made an incurrect assumption. It would appear that the engineer failed to gather all the facts prior to providing a resolution on the DR.

(4) The failure to provide an adequate response on DR 3382 has resulted in 12 safety-related cables (IVA162, IVA185, IVA707, IVA71, IVA714, IVA716, IVA720, IVA721, IVA722, IVA723, IVA818, and IVA819) whose quality is indeterminate in that one or more of these cables was overstressed during the attempted pull-back of cable IVA709. The individual maximum cable pulling tension for these cables is 58.8# and the actual measured pulling tension was 500#. Subsequent to the inspectors findings, HECo prepared NCR 841, dated January 27, 1984, to document the overstressed cables.

The licensee was informed that failure to assure that conditions adverse to quality are promptly identified and corrected is an item of noncompliance in accordance with Criterion XVI of 10 CTR 50, Appendix B (454/84-09-02).

d. During the Byron team inspection (IE Inspection Report No. 50-454/82-05 and 50-455/82-04) it was observed that the HEco procedures did not contain an electrical cable rework procedure nor the requirements to calculate electrical cable sidewall pressures prior to pulling cable. This information became part of the Byron.

Unit 1, ASLB hearings conducted in Rockford, IL during August 1983.

During these hearings, the licensee stated that cable pull reports for cables already installed are being reviewed against the current criteria and any needed corrective action will be taken with the advice of the cable manufacturer and that all cables, regardless of when installed, will meet the current criteria.

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Ir. accordance with Sargent and Lundy (T. R. Eisenbart) letter to Commonwealth Edison Company (J. T. Westermeier) dated June 23, 1983, S&L performed a'n analysis of all safety-related cables pulled into conduit. prior to December 1982. These cables' pulled into approxi-mately 2600 conduits and required analysis. Per the S&L letter, one of the following nethods was utilized in performing the analysis:

1 .

(1) Calculations for an assumed worst case conduit configuration-containing a worst cable configuration.

(2) Calculakions for an' assumed worst case conduit configuration containing the actual cable configuration.

(3) _ Calculations for the actual conduit configuration containing the actual cable configuration.

S&L's review identified three conduits that required additional analysis by the cab'e manufacturer. Cable pulling information for these conduits was torwarded to Okonite Company, cable manufacturer, by S&L letter dated June 22, 1983, for their use in perforcing the detailed analysis, s

In accordance with S&L (T. R. Eisenbart) letter to CECO (J. T. Westermeier) dated Dec' ember 12, 1983, all safety-related cables pulled into conduit prior to December 1982 we.e accept:ble.

This acceptability is based on' analysis performed by S&L and the Okonite Company's letter of October 11, 1983, and subsequent discussions with HEco to determine the actual direction of cable pulls into the three corduits analyzed by Okonite. Cable pulied into cable tray was not considered ~a potential problem by'S&L since the cable it. formation drawings addressed cable side-wall pressure by specifying minimum" cable pulling guide radii, and in. addition, the majority of cables pulled in tray were hand pulled.

The Region III inspector obcerved that the analytical method would' not provide 100% assurance that. all safety-related cables installed prier to December 1982 had~not-been overstressed. However, the analysis plus the vario'us tests performed prior to reactor operations does provide a reasonable assurance that all the safety-related cables will perfor'.'their n intended function. Pending a review of the analysis performed by S&L, this item remains open.

Reference:

Open Item 454/84-02-03; 455/84-02-03. ' ~

~

4. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompli-ance, or deviation. An unresolved item disclosed during this inspec' tion is discussed in- Paragraph 3.2 of this report. -

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i The inspector met with licensee representatives (denoted in. Paragraph 1) {

at the conclusion of the inspection on January 27, 1984. The inspector summarized the scope and findings of the inspection. The licensee acknowledged this information. -

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. Address Reply to Post Office Box 767 Attachment I Chicago, lifinois 60693 April 25, 1984 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission 799 Roosevelt Road - Region III Glen Ellyn, IL 60137

Subject:

Byron Generating Station Units 1 and 2 I&E Inspection Report Nos. 50-454/84-09 and 50-455/84-07 Reference (a): March 19, 1984 letter from W. S. Little to Cordell Reed.

Dear Mr. Keppler:

Reference (a) provided the results of an inspection report at Byron Station by Mr. R. S. Love on January 23-27, 1984. During that inspection certain activities were found to be not in compliance with NRC regulations. Attachment A to this letter contains Commonwealth Edison's response to the Notice of Violation which was appended to reference (a).

Please address further questions regarding this matter to this of fice.

Very ruly your

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D. F. Farrar Director of Nuclear Licensing Im Attachment A 8426N I-l b

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ATTACHMENT A Response to Notice'of Violation

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Violation 10 CFR 50, Appendix B, Criterion XVI, as implemented by CECO

. Topical' Report CE-1-A, Section 16, requires that measures be established to assure that conditions adverse to quality are promptly identified and corrected.

_ Contrary to the above, the failure of Hatfield Electric Company

/

to provide an adequate response to DR 3382 has resulted in 12 safety-related electrical cables being installed in Byron Station,

l. . Unit 1, whose qulaity is indeterminate.in that one or more of these E cables was overstressed during the attempted pull-back of cabl IVA709.

~ Corrective Action Taken and Results Achieved All thirteen' safety-related. cables in conduit C0A7464 are being

replaced.1 Contractor. discrepancy. reports for all other cables E

which were pulled out of conduit have been reviewed to confirm t

that this was an isolated incident.

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- Corrective Action'Taken to Avoid Further Noncompliance As. described in Section 3.C of the inspection report, the L possible overstressing of the twelve safety-related . cables was i

not evaluated because insufficient information was the basis for l

disposition of Discrepancy Report DR 3382.  ;

- Commonwealth Edison has. addressed the circumstances and events pertaining to this. item of noncompliance in a letter to the -;

contractor. dated February 2, 1984. This letter emphasized the i i

sneed for all personnel to clearly define problems so that when

~they'are evaluated, the proper-disposition can be given.

This letter also re-emphasized that cables should never be f

-pulled unless the cable pulling crew and the QC personnel know l what the allowable pulling tension is for the cable pull to be i p'e r f o rme d .

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r 2-Additionally, when cables are to be pulled out of conduit, the allowable pulling tension should be the lesser of the two following tensions:

1. The calculated maximum pulling tension of the cable (or

. group of cables) being pulled out; or

2. The calculated maximum pulling tension of the single smallest size cable remaining in the conduit.

By utilizing the lesser of these two tensions, we can reasonably be assured that any cables remaining in the condilt will not be overtensioned.

Date When Full Compliance Will Be Achieved The cables will be replaced by April 30, 1984. Training ses-sions were held with cable pulling crews on February 29, 1984 and March 7, 1984.

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P.O. Bon 8 V - Syron. imno's 61010 February 2, '9E-TO: Hatfield Electric Co.

ATTENTION: Mr. G. Vanderhei Mr. E. Tovo Mr. D. Heider .

SUBJECT:

Pulling Cable Out of Conduit REFERE'NCES: HECo NCR 605, CECO NCR 821, HEco DR 3382 and HECo NCR-841 i Hatfield NCR 605,' dated May 11, 1983, was written to identify and '

document the overtensioning of cable 1VA709 during installation.

The disposition of this NCR was to implement the corrective action provided upon resolution of Commonwealth Edison Company NCR 821, dated May 18, 1983.

Cor.nonwealth Edison' Company NCR 821 was dispositioned in August, 1983, >

with corrective action being to pullout cable 1VA709 and repull it with new cable. In the process of implementing this corrective. action, 500 pounds of tension was applied to cable 1VA709 while trying to pull it out._ DR 3382, dated October 4, 1983 was written to docur.ent this condition and identify that the remaining twelve (12) cables in the cor.-

duit may have been overtensioned due to this 500 pounds of tension be-ing applied during the pullout of 1VA709 In_ fact, even with this 500 pounds of tension applied, a portion of 1VA709 could not be pulled cut and had to be abandoned in the conduit. The new cable 1VA709 was pulled in without any problems.

DR 3382 was dispositioned by Hatfield's EnEineering Departnent on Octoter 7, 1983. The resolution was essentially that no problem existed as the calculated pulling tension for these cables was 557 pound which is greater than the.500 pounds that was applied during the pullout of 1VA709 J-l b

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It was discovered during an NRC inspection that cable 1VA709 was individually pulled out of the conduit and as such was subjected to the full 500 pounds of tension. The question raised which can-not be answered is: "How many of the remaining cables in the con-duit were subjected to this 500 pounds tension?" At Project Con-struction Department's request, Hatfield has written NCR 841, dated January 27, 1984 to document this condition.

This letter is being written to identify the proolems associated with the-above. sequence of events so that Hatfield can take the necessary corrective actions required to ensure that they never happen again on this project.

First of all, cables should never be pulled urless the cable pull-ing crew and-the OC personnel know what the allowable pulling ten-sion is for the cable pull to be performed.

Second, when cables are to be pulled out of conduit, the allowable pulling tension for the pullout should be the lessor of the two

-following tensions:

1. The calculated maximum pulling tension of the cable (or group of cables) being pulled 'out, or

2. The calculated maximum pulling tension of the single smallest size cable remaining in the conduit.

By utilizing the lessor of these two tensions, we can reasonably be assured that any cables remaining in the conduit will not be damaged as a result of overtensioning. These tensions should be reviewed for the particular job in question and if it is apparent that the

-cable (s) cannot be pulled out due to this constraint, then Project Construction Department should t>e notified.

The fact that'QC initiated DR 3382 to identify and track the poten-tial overtensioning of the additional cables was fine, except that the description of the deficiency did not adequately address the problem. The DR doesn't specifically state that cable 1VA709 was being pulled out individually and, due to it being twisted around the remaining cable in the conduit, it was impossible to determine if the .500 pounds tension was applied to just one of the remain-ing cables or all of them.

'It must be' emphasized to'all personnel that when a problem is being.

identified, it must' clearly identify exactly what the problem is.

In the case of DR 3382, Hatfield Engineering's resolution indicated that there was no problem based on the pulling tension calculation

~for the remaining twelve cables in the conduit. This would not have

' happened if the deficiency would have been clearly described.

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f Please conduct a. training session addressing.the. problems identified in this letter for all. production and QA/OC personnel involved with cable pulling'and cable pulling rework. *~

If you have any questions, please contact me.

Very truly yours, Ja:r.es 0. Byder O-Project Electrical Supervisor Byron Station JB/rc

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cc: K. Hansing E. Sager File F2790.19 1 J-3

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