ML20069G010

Motion for Reconsideration of ASLB 820910 Memorandum & Order Granting Summary Disposition of Dekalb Area Alliance for Responsible Energy/Sinnissippi Alliance for Environ Contention 1 Re Qa/Qc.Exhibits & Certificate of Svc Encl

ML20069G010
Person / Time
Site:	Byron
Issue date:	09/23/1982
From:	Cassel D DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE)
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8209280330
Download: ML20069G010 (131)

Text

_ _

• ~

UNITED STATES OF AMERICA I NUCLEAR REGULATORY COMMISSION 00(.NETED USHRC BEFORE Tile ATOMIC SAFETY AND LICENSING BOARD W SEP 27 NO In the !!atter of )

COMMONWEALTil EDISON COMPANY ) Docket Nos. 50-454 f

[oC h G SE

) 50-455 BRANCH (Byron Station, Units 1 and 2) )

DAARE/ SAFE'S HOTION TO RECONSIDER SUM!!ARY DISPOSITION OF CONTENTION l WITli RESPECT TO QUALITY ASSURANCE AND QUALITY CONTPOL DAARE/ SAFE, by its undersigned attorneys, hereby moves the Board to reconsider its ruling granting summary disposition agair-DAARE/ SAFE's Contention 1, with respect to issues concerning

quality assurance and quality control by Commonwealth Edison and Edison's contractors. /

The grounds of this motion are as follows:

1. The Board's ruling overlooked the portion of DAARE/ SAFE'-

l Contention 1 relating to QA/QC. The ruling on Contention 1 l (pp. 5-9) makes no reference to QA/QC. The Appendix to the Board

i

. ruling, entitled "DAARE/ SAFE ADMITTED CONTENTIONS," omits the

! O l

I portion of DAARE/ SAFE's Contention 1 relating to QA/QC.

2. In relevant part, DAARE/ SAFE's Contention 1 cites

h. The history at all of Applicant's egg plants (whether now operating) of it.s mg failure (and that of its architects-

> n, engineers and contractors) to observe em on a continuing and adequate basis the 80 applicable quality control and quality i assurance criteria and p1dns adopted" O pursuant thereto.

g (Emphasis added)

"D A PJ i EE"

• / " Memorandum and Order Ruling on Motions for Sune.ary Disposit ion of DAARE/ SAFE Contentions," dated Sept ember 10, 1932, docketo!

in the NRC and served by mail on DAARE/ SAFE, September 13, 1 W .

'D56 3 _

g d

3. While the Board's ruling ignored the foregoing portion of DAARE/ SAFE's Contention 1, Edison properly quoted i t in Cull in Edison's motion for summary disposition (p. 1-3). Moreover, Edison's counsel stated at the August 18 prehearing conference, If DAARE/ SAFE . . . has concerns with respect to quality assurance, perhaps felt with safety of the plant. [ sic]

Those concerns can be raised and the applicant is prepared to, and will, litigate the issues which pertain to the health and safety of the public, and the safe operation of the Byron plant.

Transcript at 50 (Emphasis added)

4. DAARE/ SAFE attaches hereto four newly available exhibit: ,

briefly described in paragraphs 5-8 below, in support of i ts QA/QC contention and this motion for reconsideration. Together these exhibits demonstrate genuine issues of material fact as to whether QA/QC at Byron has been and is sufficient to assure safe construction and operation of the plant.

5. The affidavit of Peter Stomfay-Stitz, dated fiepter6er 20 [

1982 (Exhibit A hereto), states that he was a QA/QC Inspector for a contractor at Byron from October 1978 to March 1979 and an ironworker apprentice at Byron from March to September 1979. As A QA/QC Inspector, he was responsible for inspection and dccumen-l tation relating to structural steel erection and bol ting in.

As such, he found many nonconforming steel reenforcing tendons I which were neither returned to the manufacturer nor co:npletely repaired (Ex. A at 1-2), were improperly stored and handled (id. at 2-3), and had cracked buttonheads which were not properly 0 m

- _ .m .o,., m. .- ,

q

. inspect ed (id. at 3). He also wi tnessed poor testing of En aggregate used for concrete, (id, at 3-5), such that "I .nn convinced that a good deal of bad aggregate was used t o f a b r i ca te the cement which was -used in the construction of the contaf nment buildings." d at 4-5.)

(Id. He also testifies concerning: wet or dirty concrete blocks, supposed to be used only for Category I!

construction, but actually used for Category 1 (id. at 5) , ques ti me able alteration of design plans to conform to otherwise roncon-forming construction (id.); inadequate inspection of bolta in '~

the containment building (id. at 5-6); inadequate staffing and pay for QA/QC (id. at 6-7); and subordination of QA/QC personnel to production personnel (id. at 7) . In sum, his experience was that, "The contractor and the utility were primarily concerned that the QA/QC staff completed the paper work. The gene ra l attitude was that as long as everything looked good on paper, then the QA/QC inspectors were doing their jobs properly." (Id.

at 6.)

6. The affidavit of Michael A. Smith, dated Sept en:ber 21, 1982 (Exhibit B hereto), states that Smith was a quality assurance auditor for another Byron contractor from October 1978 to January 1980. He testifies that his QA training was inadequ t.e (Ex. B at 1-2); that the contractor's QA program "had been thrown together in a matter of a few days" (id. at 1) ; that the QA manual was too vague (id. at 2); that his audit of pipe supporta carry-ing Class 2 piping showed "100% non-compliance with the design drawings" (id. at 3); that his audit reports on this and other findings were edited "to downplay problem areas" (i ,3 1. at 4);

m

r 4-that to his knowledge, " design engineers had not approved t he altered locations of the supports" (id. at 6); that during his tenure with the contractor, "I was kept at a dLatance from NRC inspectors on site" and that it was "made clear to me by lhis supervisor) that all dealings with Commonwealth Edison were to gc through him" (id.), who also told Smith "that it would take too much time and research to get the QA program in shape" (id. at .

6-7) Finally, he states , "We were so short o f s ta f f t ha t [

e believe an effective QA program was not possible" (id at 7)

7. The affidavit of Daniel W. Gallagher, dated September 6.

1982 (Exhibit C hereto), states that he was a batch plant operato for the concrete contractor at Byron from August 1975 to I:o vembei 1977 and February 1978 to June 1979, when he was fi red "wl c a 1 refused to mix incompetent and unusable batches of concre t e tend approve thei r quality for safety-related use" (Ex. C at 1) lie also testifies that the contractor "was under a great dent of p ressure from CE supervisory personnel to produce concrete to keep up with the high-paced construction schedule" and that the i

contractor therefore " felt compelled" to take shortcuts (i_d. at 3, .

that "[ f jor over two years , aggregate which had not met specifi-cations was used to mix the concrete for the Unit One containment and turbine building" (id. at 4) ; that this problem was never adequately remedied by the NRC or by Edison (id. at 4-5); and that Edison stalled corrective action "because the poor quality of the aggregate was not reflected in any paper work, even though CE knew the aggregate did not meet safety specificat ions"

. (id, at 5); that on one occasion the contractor's QC personnel

" blatantly lied to NRC investigators" (id. at 5); that "it was apparent to me that the [ contractor's] staff did not want the batch plant operators and the other workers talking to the NRC inves tigato rs" (id, at 6); that the contractor's "QC people stretched the truth on a variety of quality control practices" (i_d. ) ; that excessive water was added to the concret e , wealcening it (id. at 6- 7) ; and that another worker told him that oi1 was also leaking into the concrete (id. at 7-8). In s un, Mr . ca Llag' c states:

All of the violations of safety speci-fications which I observed and in whi.ch I was asked to participate were overlooked or not discovered by CE inspectors. I believe that the CE supervisors were mainly worried about meeting safety specifications on paper. I further believe, from mv experience at the Byron facility, th'at actual compliance with specified procedures for producing concrete for safety-related use was not nearly as important to CE as pushing Blount supervisors into increasing the speed of concrete fabrication to meet the daily quotas for the construction project.

(Id. at 8.)

8. In addition, a June 24, 1982 NRC Getter to Edison (Exhibit D hereto, which was not placed in the public document room nor made available to DAARE/ SAFE until mid-August) repo rtn the results of a special team inspection of QA/QC at Byron, conducted during March-May, 1982. While the letter st a te- that,

"[i]n general," Edison's QA/QC program " appeared good," it r.o t e:

that " program implementation deficiencies were identi f ied ,;hich

~

- . .- .=_. ~.

e

. e require corrective action." The accompanying notice of vi- htio:

listed nine separate kinds of QA/QC violations and the let t or expressed particular concern about inadequate QA/QC t r.iini n",.

staffing and certification by Edison and its contractors at Sy ron The inspection report itself is even more illuminat ine a.. Io the adequacy of Edison's QA/QC program at By ro n . Af ter um in ' hat Edison's QA program "should" he able to handle the job. i s note:

"llowe ve r , the execution of the program is not 9atis fact o r v . .is evidenced by the many problems uncovered by the inspec or: One factor affecting the execution is the stability of service for the QA personnel." (Ex. D at 16.) It adds: c Since' January 1976 there have been five QA superintendents at the Byron site:

In addition to this undesirable condi tion, the QA Engineers and Inspectors have an average on-site service tine of approx-imately fourteen months and have limi ted prior QA experience. Part o f this on-r. i tc time was spent in training and qualifying for various QA duties.

In addition to this problen, manpower is

currently being sent tr other sites so

that the QA effort is t abstantially wenkened .

The constant change over of personnel resulting in a minimum experience level and transfer of personnel could hinder the GA organization in meeting its obligation of effectively implementing a QA program.

1

_I d.

101c foregoing findings are not consistent with Edison's claims of a zealous commitment to vigorous QA/QC. What emernes from this report is a sketch of a low-priority, low-pay, low-power

. program, incapable of effectively handling its critical i

1 m-_-

_7-responsibilities. Thus, Edison's own explanation for the rapid turnover and low experience level in QA/QC at 3yron is , in part, a desire to offer QA/QC personnel " promotional opportunitie ," in other departments. (Id. at 17.) As the report noted, Edison's 1

" inability ... to dedicate resources" to QA leads the inspectors to question both Edison's " effectiveness in staffing" its own QA Program, and its oversight of contractor QA/QC programs . Id.

at 21, 22. The inspectors were also concerned about the lack of

" assurance that upper management of CEC supported the Quality Assurance Program and its objectives." (Id. at 21.) It then v

comes as little surprise that, for example, Edison's response to the November 1981 GAO finding was still inadequate. "prwnpt training (of QA personnel] was still not being accortplinhed and

... the corrective action to prevent recurrence, stated in :he audit response, was not being effectively implemented. " (14 at 17-18.)

9. Edison's failure to ensure effective QA/QC by i t' contractors at Byron is longstnading. (See Peti tior of LW M /SAll For Waiver Of Or Exception To Financial Qualifications Rerxlatio: ,

filed July 30, 1982, at pp. 9-13, and Exhibits Q through V there-to, which are incorporated by reference herein in their entirety.-

Indeed, Edison has knowingly tolerated QA/QC deficiencies at Byron, which are now the subject of a pending criminal ir.vesti gation by the Department of Justice (id at 10-11), and which have now led to an NRC Information Notice concerning "thc potentially significant problem pertaining to welds in main m

8-control panels", issued September 17, 1982 (Exhibit E hereto).

10. Edison's Motion For Summary Disposition cont.ainn s ixt..m fact statements which it labels " Material Facts as to Which There is No Genuine Issue to be licard," each c.llegedly supported by portions of the four affidavits also submitted, llowever, the self-serving, conclusory affidavits submitted by Edison do not controvert Contention 1. The affidavit of Corde!i Reed, Edison's Vice President for Nuclear Operations , cor.tains on specific facts which speak to DAARE/ SAFE's allegations , but rather generally describes Edison's corporate nuclear prep.ims.

Further, Exhibit F hereto, a published newspaper quota ti:n af Edison spokesman James Toscas, states that- Edison deer not inspect at least some kinds of suppliers ' equipnent for wu at Edison plants, but instead relics on the QA/QC progran, of suppliers.

The similarly conclusory affidavit of Mr. Shewski care fully refrains from dealing with Edison's responsibility for the conduct of its contractors. Its allegations, particularly at pp. 5-6, are stated in the future tense, indicating that Edison intends a change in its programs. The affidavit does not, however, speak effectively to Edison's track record of QA/QC deficienci es .

Mr. Querio's affidavit merely alleges 0 that all personnel who will eventually be employed at the Byron plant once it is oper-ating will be qualified, but fails to discuss the qualifications of any person other than Mr. Querio. It contains only a table with the number of years of unspecified types of experienm of unnamed persons.

~

Mr. Steide's affidavit addrcases some of the speci fics ra eil in contention 1, but not more recent and serious infractions of NRC regulations by Edison. Both Mr. Steide and !!r. Forney (NRC resident inspector at Byron, whose af fidavit is appended to the

~

staff's response to Edison's motion) attempt to make rauch o f the fact that each incident mentioned in the Contention occurred between 1974 and 1978. However, DAARE/ SAFE's contentions were submitted in 1979; it is hardly surprising that only incidents up to that time were mentioned in the Contention.

Edison's more recent QA/QC failures at Byron and 71scwhere are evidenced in Exhibits A-F hereto and in Exhibits O thro y,h W to DAARE/ SAFE's financial qualificatione petition.

In sum, in no way can it be said that Edison's history of QA/QC breakdown and poor plant management has long since passed.<

Indeed, it appears to continue at an undininished rate.

11. The affidavit of Edward W. Gogol, inadvertently omitted from DAARE/ SAFE's reply and attached hereto as Exhibit G, refleco his study of Edison's infractions of NRC regulations which have resulted in fines. It supports DAARE/ SAFE's Contention and controverts the assertions in Edison's and the scaff's affidavit >

thus giving rise to a genuine issue of material fact.

12. The Order, at p. 6, indicates that the af fidavit of Michael D. Mollander has been accorded no weight by the Eoa rd.

Mr. Mollander, however, does not purport to be a nuclear expert ,

but merely uses his technical background to aid the Board in reading the exhibits which he submits. The fact that "the data i

^

he bases his opinions on was never detaile@' (Order at p. /> is equally true of the Edison and staff affidavits.

13. Finally, the subject of the Contention - quality .tasur-ance/ quality control - is of paramount importance to fut fi I Lent o f the Commission's duty to protect the public health and N f ety In response to a question concerning consideration of QA/(t innuen in operat ing license proceedingn , Cha i nua n l'a I ! .id i no han stated,

... I think the Coimnission as a whole i n ve ry strong on quality assurance and, if anything, I think leans over as far as it can to accomodote every aspect of quali.ty assurance."

guality Assurance in Nuclear Power Plant Construction, IIR 9 /-26, 97th Cong. 1st Sess., at 30 (Nov. 19, 1981). In sum, DAA RE/SAE[I QA/QC contention is too important to overlook, and its evidence of QA/QC deficiencies at Byron is too substantial to deny a full hearing and thorough Board consideration of the relevant fa c ts .

DAARE/ SAFE therefore urges the Board to reconsider its earlier ruling and to deny summary disposition of Contention 1 with respect to QA/QC matters.

September 23, 1982 Respectfully submi.tted, Douglass W. Cassel, Jr.

For Service: Jane M. Whicher Douglass W. Cassel, Jr. Attorneys for DAARE/SAFF. wit h Jane M. Whicher respect to issues conccrninr.

109 North Dearborn quality assurance / quality coqtrol Suite 1300 Chicago, IL 60602 (312) 641-5570 p #

By: G b.-%.. -[

Douglass W. Cassel, Jr. h

~

~

e.

CERTIFICATE OF SERVICE I hereby certify that I served copies of the foregoing DAARE/ SAFE's Motion For Reconsideration on all parties bv causing copies thereof to be placed in envelopes and deposir.ed in the U.S. mail at 109 North

Dearborn,

Chicago, Illinaiu. first class postage prepaid, properly addressed as indicated on the attached service list, and by Federal Express to the Peard members, this 23rd day of September, 1982.

Attorney

_ _ ~-

j.

SERVICE LIST N

Morton B.  ?!arguli en , Chairman Steven C. Goldberg, Esq.

Administrative Judge Office of the General Counsel Atomic Safety and Licensing Board U:S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission

ashingten , D. C. 20555

.. Washington, D.C. 20555 Dr. A. Dixon Callahan Office of the Secretary of Administrative Judge the Commission Union Carbide Corporation ATTN: Docketing & Service P.O. } sox Y Section O'.3. Ridge, Tennessec 38730 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 -

Dr . Ri cha rd F. Cole Myron M. Cherry admi ni s t rat i ve Judge Cherry & Flynn stomic Sciety and Licensing Board Three First National Plaza U . S . .. wl e:i r liegulatory Commission Room 3700 aslu a en- 1; . C . 20555 Chicago, IL 60602

'lan

- r Bielawski inhan :.ircoln & Beale me 16 ca r ilational Plaza

' lst +loor

1. i ca ; . , IL 60603 0

f i

i l

TABLE OF EXilIBITS

' , TO DAARE/ SAFE's Motion To Reconsider Summary Disposition Of Contention 1 With Respect To Quality Assurance And Quality Control ,

EXilIBIT

1. Affidavit of Peter Stomfay-Stitz.

B. Affidavit of Michael A. Smith. c3 C. Affidavit of Daniel W. Gallagher.

D Letter from NRC Region III to Commonwealth Edison Co. ,

June 24, 1982, with enclosures.

E. NRC Of fice of Inspection and Enforcement In fornm t ion Notice No. 62-34, Rev 1, September 17, 1982.

F. Illinois Times, Jan. 7-13, 1982, p. 3, " Nucleal Time Bombs?"

G. Affidavit of Edward M. Gogol.

l l c, l

t I

i i

l l

f a

h_

AFFIDAVIT OF PETER STOMFAY-STITZ My name is Peter Stomfay-Stitz. I was employed as a Level I quality Assurance / Quality Control Inspector for Blount Brothers Corporation (Blount) from October 1978 to March 1979 at the Byron Nuclear Power Plant being built by Commonwealth Edison Company (CE). From March 1979 to September 1979, I was an Ironworker Apprentice for Ironworkers Local 498 at the Byron facility.

As a QA/QC inspector I was responsible for required inspection and documentation of structural steel erection and bolting in. I was also responsible for receiving inspection for nuclear safety-related equipuent and materials as Blount QA/QC Material Controller, establishi.ng quality conformance to the procurement documents . I further participated in a program of planned and periodic audits to veri fy compliance with all aspects of the QA/QC program. All

,tateacuts i elow refer to incidents and observations which occurred

,iuring uy tenure as a Blount QA/QC inspector at the Byron site.

it.' primary responsibility at the beginning of my employment uith Blount involved on-site inspection of steel reenforcing tendons which were used to strengthen the concrete placed in the containment buildings . I was told to examine the tendons visually "o determine whether any nicks, wetness or other damage had O

,1ccurted during shipping. Many times I found such nonconformances

.ind authorized the return of the noncomplying tendons to the i.anufacturer as I had been instructed to do.

Even though I was merely following the instructions I had l>een given by Blount's QA/QC manager Rick Donica, I was told by

(~,

fyld W A

~

both Blount and CE supervisory personnel that returning the non-complying tendons to the manufacturer presented an inconvenience o' t o Blount and CE. I believe the inconvenience with shipping tendons back involved slow down of construction and great shipping cost.

The question of what should be done with the damaged tendons

t. a c finally resolved by a memo I received from my supervisors. I was informed through the memo that the tendons were to remain on c ite, because InRoyCo (also known as Inland Ryerson Steel Co.),

the tendon manufacturer, would come to the Byron site and fix any ilamaged tendons. InRoyCo personnel did come on site later in 1978 or in 1979, but I believe that it is unlikely that the tendon manufacturer was able to completely repair the noncomplying tendons.

Many tendons, as I have described above, did not conform to

,pecifications upon their receipt on site. In addition, many other n enconformances resulted from the mistreatment of the safety-related tendons during transfer and storage of the tendons at the Byron

.ite. The tendons were packaged in pairs in large plastic bundles.

"ince it was extremely important that the tendons stayed clean and drv on the extremely dirty and dusty construction site, it was critical that the plastic bags remained sealed at all times.

?!any of these plastic coverings, however, were torn open as the r endons were loaded and unloaded for transportation to and from torage areas.

Also, the tendons were stored in tendon barns which did not ddequately protect the Londons from dirt and dampness. The

endon barns were open at the bottom, and standing water and mud vere connequently all over the ground upon which the stored m

3-O tendons rested.

In the Winter of 1978, several buttonheads, which hold the wires of the tendon in place, were found to have cracked. The ones uith the greatest splits were supposedly sent back to InRoyCo.

Because the cause of the cracks was not cl.early determined, all t he tendons stored in the tendon barns needed to be inspected.

Blount organized a two day inspection of all the tendons on site.

I participated in this inspection of the buttonheads. The temper-ature on the days of the inspection was around 10 degrees (F) below zero. We had to tear open the plastic coverings and attempt to maneuver the steel tendons which weighed thousands of pounds, to determine if the buttonheads had cracked. Many of rl.J ends of the tendons were inaccessible due to the way they were coiled, raaking inspection of the cracks with a feeler gauge (to detennine the width of the crack) impossible. Finally, I

.ind the other inspectors had to rescal the plastic bags which i eld the tendons. However, the gray duct tape used to seal the

,.y;s w uld not stick at -10 F. The inspection of the buttonheads as t echnically completed, with no additional findings of cracked uttonheads. The rushed inspection, under terrible weather ondiL wns, however, could not in any sense been accurate in

upectin ; the tendons. Buttonhead splits or cracks may have existed in the tendons, but because of the speed and difficulty of the inspection process these cracks went unnoticed.

In the course of Cv other inspection duties, I witnessed a u ri e t :- o f questionable practices. The testing of the aggregate a

O used in the fabrication of concrete for the containment buildings provides one such example. Pittsburg Testing Laboratories would call Blount's QA/QC staff to inform us that a certain sample on aggregate had failed to comply with specifications. A Blount 0.>/QC inspector -- of ten myself -- would go out to the aggregate pile and inquire as to the exact location of the bad sample. The rittsburg Testing Laboratories inspector would point to a general area of about 50 to 60 feet of the six-or-seven-hundred-foot-long pile. The inspector would then suggest that another sample be aken from some other part of the same pile. Samples were taken until one was found that passed minimum specification requirements.

The Bleunt inspector would then condemn a small portion of the pile where some o f the bad sampics had been found. This non-complying aggregate remained on site, but it was not supposed to be used in the production of concrete for safety-related purposes.

I believe that at least some, if not most, of this condemned ar regate was used in fabricating safety-related concrete in pite of its temporary segregation from the pile.

The m<. s t signilicant problem with the aggregate testing p roce du re was the practice of testing sample after sample until good one wa:. found. It was evident to all the inspectors and t e :t era that this process did not ensure that aggregate

hich di d not meet speci.fications was prevented from being atili w d.in the production of cement for use in safety-related r.ruc t u res . I am convinced that a good deal of bad aggregate r, utie,! to fabricate the cement which was used in the construction (J

o f the containment buildings.

The same type of problem occurred with the receiving inspec-t ion of concrete blocks to be used in Category I construction.

Many times the blocks would arrive wet or dirty and were placed in a separate building, often the turbine building, to dry, and upposedly were to be used only in Category II, not Category I, construction. I believe, however, that many of these blocks were used in Category I construction.

Another area of significant manipulation of specification r egula tioac involved the repeated incidents of change in design.

A fter the completion of construction, the design plans would be

.a ttered so that the structure which actually was constructed would appear to have met design specifications. This change of design occurred on a regular basis. The following scenario

erven as an example of the manner in which the change of design p acedure was regularly implemented. Blount would complete construcLion of an area of a structure and an engineer would realize th a t a support beam inadvertently had not been placed

' n th e s t ruc ture . Rather than rework the construction to meet ihe Sargent. & Lundy design, Blount QA/QC persons would call

. argent & Lundy engineers and ask them to alter the design plans,

!eaving out the forgotten beam. Correcting the construction defect in this manner was considerably cheaper than physically niacing the beam into the completed structure.

About three months before I left Blount, an increase in welding activity resulted in a need for extra QA/QC inspectors t.o check welds. Consequently, Blount shifted the QA/QC inspector J.

.ho checked the structural steel " bolting in" (essentially making

.ure all bolts in the cement in the containment buildings were in place and properly tightened) to weld inspections. All the bolt-ing in inspections become part of my duties. Tendon and other cid hoe inspect ions which had been occupying all my time were not

upposed to be cut back in any respect. I was simply given more tork than I could possibly complete.

The bolting in inspection duties included checking every bolt placed anywhere in the eight stories of either containment building.

I never received proper training in this area, and essentially ,

bumbled my way through the bolting in inspections. Because of the t ime pressures placed on me by my supervisors, I often simply did iat inspect several bolts which required inspections.

Neither CE nor Blount supervisory personnel seemed concerned

'y the entreme overstretching of Blount's undersized QA/QC taf f, uh tch consis ted of only five people. The contractor and t ne utility were primarily concerned that the QA/QC staff completed the paper work. The general attitude was that as long an everything looked good on paper, then the QA/QC inspectors vere doing their jobs properly. This was accomplished by other nembers of the QA staff performing audits of others' paperwork.

The incredible pressure I was under in attempting to perform inspections without the necessary time to complete the tasks, or t e training to understand the tasks, finally led to my decision to resign from Blount's QA/QC staff. Also, my job never paid s . .._

i more than $4.00 per hour. Such pay was extremely low, especially in light of the tremendous pressure and responsibility which were involved in the job. The los salary in comparison with production-ui.de employees also contributed to my decision to seek other employment. I understand that, according to NRC regulations, Hiount's QA/QC staff was to be separate and independent from Biount's production staff. Such independence did not exist at th e By ron j ob . For example, several times I tried to get an in crea se in my pay to be coa.parabic with the other inspectors I vorked with. Rick Donica, the QA/QC manager, would meet with I' Lo un t production chiefs Charles Smith and Bill Beesing regarding this. I also always had to go to production personnel for other

' ia t te rs such as time off.

I have read the above seven (7) page affidavit, and to the best of mf knowledge, it is true, accurate and complete.

)

// I N 2 ('

PETER STOMFAY-ST

.;ubscribed and sworn to before me this 20 day of September, 1982.

/

' , ' ./

l 'f.

, - ( ( ,] / / , g '

) /t NOTARY PUBLIC ily Ccam! asion Expires :

I

')

p? s s \\ s h* W

AFFIDAVIT OF MICHAEL A. SMITH 1, Michael A. Smith, being first duly sworn, hereby depose and av as follows.

I was employed by Hunter Corporation as a quality assurance

("QA") atiditor at the Byron Nuclear Power Station, Byron, Illinois, f rom Ocrcbe r, 1978 to January, 1980. Prior to that time, I had orked ene .ind one half years as a production planner for Sunstrand iviation, and two years as a service station manager for Martin 011.

I had .c prior experience in the quality assurance field. I'was

ired by Dutch Somsag, Hunter Corporacion's QA supervisor. I was first hired as a QA inspector, but during my training a need developed for a QA auditor.

Mv t raining program for my j ob with Hunter Corporation consisted only of learning, the site policy manual and taking a LO4t en it. The manual was typewritten, covered approximately 24 areas and was 500-600 pages in length. Once I passed the test, I

.as ce rt i fied and allowed to go out into the service area either as a QA in meccar or a QA auditor.

e a Q.\ auditor my job was to inspect what the QA inspectors

ad done, she QA inspectors were to inspect welds on pipes and

.opport s and support locations.

At the time I was hired, Hunter Corporation had been at the byron s i t e for one or two years as the replacement for the Pope campany. Sotasag told me that Hunter's QA program had been t hrown together in a matter of a few days when Hunter took os _r the pioing contract from Pope. It was the first time Hunter had hh b c - . .

2-neen involved in nuclear construction. When they hired me, they

. J no de finite plan of where to put me. They were trying to upgrade t heir W program because it was too vague. Ify job was to fill in cherever needed and I assisted in the revision of the QA program.

Tx QA program consisted of 18 ANSI criteria and the site

.olicy t.;anun1 broke these criteria down so that the workers in 5e fi i d coul d foilow t hem.

lie fo re I was hLred the QA staff consisted of about six welding

'nnpectors and one auditor. I was hired as a co-auditor. The taff ti.en increased to about 12 welding inspectors , two auditors

. including me) and a third auditor who was part time and also erve d .m an i nspec to r, t!y co-auditor and I reported directly to

'onsag, and Somsag reported directly to the home office in Le",no n .i . indiana. Somsag also dealt with Commonwealth Edison orsen w 1 on the site.

We s ri i ted dig:;ing up problem areas , or " gray areas . " These ore dn 6o the fac t that the QA manual contained no stringent iideiire. and t.he workers were given too much freedom to put re t h e i .u. , wh e re they wanted. For example, the policies regarding l

. A:. . # eiping t up p o r t:. inade(piately defined installation and m pt et o.i.. .u. outlincd b, t.he working instructions of the most arrem a.ml; codes.

t i Oct ober and November of 1979, my co-auditor and I did a i

I .>ec i a i audit of certain pipe supports. I had been told by l raduci'on workers that they felt there was a need for it. They a i d t'iat they had been rushed to put them in as quickly as ruibl. . uni thought tiney were putting them in where piping was it w ou d to be. One support had no documentation at al1.

l l

~

3-O '

'le looked at the support and its dimensional location was several t eet o f f and the support faced the wrong direction. This prompted 1

<ur more extensive audit, described below.

Ur dre < out at random between 100 and 150 supports to audit.

.e wen- intu the field to verify that the supports were where they r re "ug osed to be. These hangers were in the auxiliary buildings

.r abo ut the 364 level and the 400 level, just outside the reactor

.ailn The supports carried Class 2 piping. We picked these areas

.ceaus. there had been so many questions about the inspectors ic;ning of f without inspecting the supports. The inspectors would

na pe c t only the welding process but not the location of any 1 i ping

,upport . We fo6hd out that they could not verify the

.seation of any piping supports because they had no, tools to cas ure the locations. The most they would do was to verify the oeat ion by " eyeballing" the support in relation to some other hjeet We found that some supports were off by as much as four feet, ,

.nd that none of the 100 to 150 supports we audited was in the oper location indicated by the design drawings. In other words,

. fc und 1071 non-compliance with the design drawings .

N', , one had given the QA department any as-built data, i.e.,

oue th ; in; te say that this hanger had been moved to a location j . h e r 4 ..au t h at designated in the line drawings. In other words, i

ae "s: ned-of f" drawings did not match the plans.

l

! W co-auditor and ] wrote up a handwritten report, consist-l ag of aporoxiuately eight pages, and gave it to Somsag. Somsag l

l l

i C '

e told un he felt we had opened a can of worms and wanted us to r ewri. t.e our audit. lie re-edited it personally, and gave it back o us in typewritten form. The changes he made were quite extensive and result ed in the fact that our report made less of an impact that we felt the problem deserved. The report as we. wrote it pointed to tuo areas of concern: production and QA inspection.

Somsag cbanged the report so that it did not necessarily imply Ihat these ucre problem areas. This is not the only time Somsag

$ hanged eur reports to downplay problem areas; he did this quite often.

To the best of my knowledge, prior to our audit no inspector ad e ec t ver2.fied piping locations on either Class 1 or Class 2

. t r uc t .n e- %veral of the support.s could not be located at all nn : n-b : .c re were "nigned-o f f" documents that said t.he ut n: . me in fact in place. Later, after confronting the c m dne "n people, these were located. The production department

.cnt tm ongh the past paperwork and verified that they had moved one .;upports. The particular piping involved in our audit was

'asn ? piping from the reactor building into the auxiliary I uildin; this is not as volatile as Class 1 piping but is as O

mportant because it c.rcries contaminated waste.

Prior to our audit and the change in QA procedures stemning

' mm our audit, I do not know how many supports were without c rope r in.spection. 'Only in case of a weld to a support would here be anyone to verify or inspect it at all and even then

>Sey '.nuld only innpect the weld and not the location.

Because the supports are not in the exact locations the ,

engineers had designed, it is questionable how much stress the joints and pipes can take in their present positions.

j We were told to forget the audit but instead we called a c.t etin,; o f the Hunter Corporation's proj ect manager (Ben Krasawski),

the four production superintendents, Somsag, myself and my co-

. ,uditor This was in December of 1979 after Somsag had edited and returned our report so that the severity of the findings was not so ucticeable. Even with Somsag's changes, the report did .

. a us e re-evaluation of the problem of inspection procedures.

Uaat we were trying to get across to the production people

as that we did noc have as-built data included anywhere.

l Ac the meeting regarding the audit, there seemed to be a

reat deal of concern by the building superintendents that we

e re op e ni ng up a can o f worms . They wanted to know where we got ur abilit.y to inspect pipe supports since we were not pipe fitters.

4

..c7said that we had used a tape measure and anybody could do it.

'Ite building superintendents were at odds with the QA mpartment and said that the whole problem was the inspectors '

tult ! ecause they should have caught it before our audit.

.O the muting, Krasawski acted as a mediator between the CA

.mpart"ent ,and the production department. Everyone acknowledged i -hat I w re war indeed a QA problem.

t i

W dtd a follow-up audit to verify that the problems stated n my f'ndingy had been corrected or that as-built documentation i o pr ided. That is, that the drawings and documentation for t

, 9

y cach support were changed to show as-built data and properly signed.

In all b u r :n few instances, this was done. In the cases where it I

..as not done, non conformance _ reports were written up and the c atte r wc.s then out of my hands . The QA supervisor kept a log on a ll non-conformance reports .

This follow-up audit did not satisfy my concerns, because the design engineers had not approved the altered locations of the

appo rt s . I ' tniked with design engineer Bill Wellborn from Sargent L Lund.. lie said that this would be handled at a later date and that he didn't think it was serious enough to be dealt with. To ray 3nowle dge . these altered supports have not been approved by any design engineers.

Duri ng my tenure at llunter Corporation, I was kept at a

< stance from NRC inspectors on site. Every time they were on ie L.". n i ven a specific taon in the piping laydown area in i 'm noct b end o f the site which was many acres away from where t

a no r . I duties were. I believe this was done to make sure I

.:id no' t alk to NRC personnel about the findings of my audits.

wr.c t.ade elear to me by Somsag that all dealings with Common-al'a 1.dison were to go through him. I believe this was so Sat at could control what Edison was told about the findings l

! ^ my .mdits .

E doing other audits, I saw a need for revisions to the i t.e pcli cy manuals and made other suggestions for corrective

t. io n . My recommendations were generally ignored by Somsag, 4 ho t 01 d rae th at it would take too much time and research to

,,e t the QA program in shape. We were so short of staff that I believe an effective QA program was not possible.

I feel that there were more placement problems than my co-audi tor and I could possibly handle. The QA staff was so s, mall because of the budget. ,

I have read the above affidavit consisting of 7 pages and it is true and correct to the best of my knowledge and belief.

e i

{ fl.C dL l ' d // L i' _

MICHAEL A. SMITH

..Lnci . bc 41 and sworn to before me this 3d- day of September,1982.

(

u u l' e NOTARY PUBL

%W'-

s Cont n: .aion Expires :

6 . h i.i. 0;i,C &;',24,1353 m

a

%Jef AFFIDAVIT DANIEL W. GALLAGHER f My nat.:e is Daniel Gallagher. I have been a member of the operar i ng Em;ineers Local 150 since 1974 and have worked as a oncrere mix operator since 1975. I am also active in local I ,oli t i e I was Chairmzm of the Democratic Party of DeKalb

':ounty of Illinois from 1978 to 1980. I was alderman of the

'ud Unrd in Genoa, from 1977 to 1981. Recently, I was defeated by a small margin in the Genoa mayoral race.

I ias employed asb1 batch plant operator for the Blount

'iro the rs Corporation (Blount) from August, 1975 to November, 1977 ind irom February, 1978 to June, 1979 at the Byron Nuclear Power

lant being built by Commonwealth Edison Company (CE) . All 1 t a t erre n ts beLow refer to events which occurred during my employment with Blount at the Byron plant site, r.

1 vas fired by Blount in June of 1979, when I refused to ii x Treompetent and unu:;able batches of concrete and approve heir quality for safety-related use. The incident arose when he A i a ev:apater-n.casured mixing apparatus was receiving a a111 ra t ion i n:;pec t ion . While this mixer was shut down for i *nspection, my supervisor _ directed me to utilize the back-up ni x u s t erc., which was a dry batch system. I had assisted in he construction of the back-up mixer and had operated it in 1977.

the s".; tem only worked when mixer trucks were utilized in the

,rocena. At the time I was asked to employ the back-up system to fabricate the concrete, agitators, also known as trens fer kt

• .'1

!Y 2- pJWj-7 t rucks, were the only equipment available to mix the concrete.

There vzero no mixer trucks availabic.

Fron my earlier experience with the dry batch system, 1 knew

. hat dry hatches of concrete would not mix properly in the gi t a to rt. He had tried to utilize agitators for two weeks in 977 to fabricate concrete for non-safety related purposes. At

, hat time laborers in the placement center where the concrete as forued for use in Ge plant told me that lumps of ice and alids .;ere not mixing into the batch, rendering the batches cirtually useless. Ice was used to keep the mixture at the roper temperature. The agitators simply were not able to ategrate the ice. This failure properly to integrate the

a te r ia ls in the mixture resulted in the formation of the ice oalls. To alleviate this problem, in 1977, Blount had temporarily' matR raixer trucks which were adequately able to integrate the aterials in the concrete mixture to use instead of the agitators.

'lhe concrete which I had been mixing in the dry batch system

n 19 77 had not been used for safety-related purposes, and,

,cre f ore ,

• uan not required to sign my name to verify the iua l it _ of the batches. In June of 1979 when I was asked to mpim the back-up mixer to fabricate concrete for the cooling "nwe re ,

I had to check a box marked "CllECK, IF SAFETY-REIATED CONCRI.TE" and sign my name. (See Blount Brothers Corp. form attached, and marked " Attachment A".)

I told my supervisors that I could not sign the audit form, ince I knew from my past experience with the mixer that the concrete produced in the back-up unit would not racet the quality

< w -

d ! VM standards in the safety specifications. My supervisors continued Lo insist that I mix the dry batches in spite of my explanation concerning the inadequacy of the concrete mixing process . I complained to union representatives about the situation. The trion, however, was not able to help me, because I had refused t3 operate a machine. As a result, Blount supervisors terminated my employw.ent. I later learned that my replacement attempted to i dx the concrete in the back-up mixer, only to find that ice balls formed in the mixture, making the concrete unusable for safety purpo se.. .

Blount was under a great deal of pressure .from CE supervisory persor.nel t o p roduce concrete to keep up with the high-paced construction achedule. I knew that CE plant superintendent lorer.: an o f ten reprimanded my Blount supervisors for failure to mect CE'1 desired production levels. CE construction supervisors could visit my Blount supervisors on a weekly basis to complain that the necessary concrete quotas were not being met. I believe Blbunt was under tremendous pressure from CE to increase the nace o f i.Li cancrete production. Thus, when the computer-

'easured mix system was shut down for its calibration check, I hine dloun: <upervisora felt compelled by CE's demand for oncre*e to t ry t:0 operate the back-up system.

1 my four years as batch plant operator at Byron, I observed 4rher ' v.tances in which safety specifications were circumvented.

In Now aber o f 19 75, when I was crained as a batch plant 4peratei both my supervisor and the experienced batch plant perm c who were conducting the training told me that the B

I ND'))h aggregate being used in the fabrication of the concrete did not

tec t t'ae specifications required for concrete utilized in a fety related areas . The concrete was being used in the construction of the containment and turbine buildings. The experienced batch plant operator complaine.d to CE engineers about LH poar condition of the aggregate being used. CE did nothing

o rerredy th e problem.

Blount workers and CE personnel were not the only persons ho recognired the non-complying condition of aggregate. Sometime 1 19 / n . an Inracli engineer on tour of the Byron construction roj ec i que t ioned me about the pile of aggregate near the batch

.lant ;U w n i informed him that it was being used to make the onc rei e u.wd in the containment building, he expressed surprise, od es n ' .ii.u d that t.he stone was not clean enough to be used to ti < c.neiete for sa fety-related purposes .

c i t.a ll y , in 1978, NRC safety investigators and/or independent entir. ecmpany inspectors condemned the aggregate pile, o rohi . i t i n,- the use of,the stone until it was c1 caned to specifi-at ior : 1.arge quantiLies of the aggregate had already been used a th( 'abri. cation of safety-related concrete . Neither CE

'f fi cia ls nor NRC staff investigators ever took any action that knew of in regards to the concrete which had already been ude vi.th the condemned aggregate. For over two years, aggregate hich had not met specifications was used to mix the concrete

'o r ti e lin t t One containment and turbine building. In my estimate, wer 'C 000 yards of cancrete mi.xed with the non-complying

Je 1

tu Lg)f) 5-w,rema e wim fabricated, and used, with a great deal of the on c rei .. being used in the lower level of the containment structure

nel ading the portions built below the ground.

tn migust, 1982, I was informed by a representative of BPI nat Imt: I & 1: reports indicate that a pile of aggregate at otrionwa lt h Edison's Byron nuclear power plant was condemned in

,ecembe r 1975, for failure to meet specifica t ions . I was not saare o f thi s particular condemnation. I remain certain that la te r

,lles oi aggregate used in mixing concrete for use in the Byron m a t a ilmien t buildi.ng failed to meet specifications. The conversation iescribed above with the Israeli engineer concerning the poor

,aality of the aggregate occurred, to the best of my recollection, a the latt er part of lo76, about one year af ter I had become sa: ch olant ope rat or in November, 1975. The problem of which I u a 4.ae with the aggregate, and which is described above in this f rin. i .

a.. not rectified until NRC investigators or independent estin- -otepany inspectors condemned the pile sometime in 1978.

n t h.2 i n :nu:ime, during 1976, 1.977 and part of 1978, aggregate t na : t i n,,  ; reci fi cat i.ons continued to be used in the fabrication

.f con. r 't e utilized in safety-related areas at Byron.

I believe CE " ailed to take corrective action, prior to he Ml:C condemnation of the aggregate pile, because the poor

,ualit- of the aggregate was not. reflected in any paper work, even t hough CE knew the aggregate did not meet safety speci fications.

1:. ano ther exr.mple o f a failure to meet safety specifications ,

'ich ' titnessed while citting in my office, Blount Quality ont n 1 ner4onnel blatantly lied to NRC investigators. On one

' j /I occasion I heard a Blount QC employee tell the NRC that weekly

,ind. monthly maintenance checks were being performed. In fact, ach inupections were only conducted when machinery happened to break down.

Also, in general, it was apparent to.me that the Blount QC

,taff did not want the batch plant operators and the other workers

' alking to the NRC investigators . When NRC engineers spoke with B loun t OC staff persons in my presence, I knew from the cold alares directed at me that I was not supposed to talk'about afety topics being discussed, despite the fact that they of ten sacerned natters about which I was quite familiar. I of ten sat

aietly as the Blount QC people stretched the truth on a variety C quality control practices. I think that Blount supervisors,

nxior i to neet CE's daily demand quotas, did not feel that

<trict adaerence to quality control procedures was necessary, ad t ho ugh t that strict adherence would interfere with the speed it which the concrete was produced'.

Another practice in which I was often involved provided a tood i l lustration of Blount supervisors' lack of regard for afety ;p eci fica t ions . Every 10-yard batch of concrete was

uppared to be approved by a CE engineer or an independent testin3, cer.:pany inspector. CE did not have enough engineers assigned to the proj ect to watch every batch produced. Many times, sii5n a batch was ready to be sent to the placement center, and when the CE engineer was not around, my supervisor would have ne add wate r to the mixed concrete. I was told to add water to

D' (f * , s/T ehe mixture, because the extra liquid made the concrete easier ta work with. This practice was in violation of safety specifi-ca t ion s . Also, my supervisor knew that by the time the batch with the added water reached _the placement center, the form of rhe concrete mixture would appear to meet _ specifications, as

.he mixture would harden somewhat from the time it left the. batch nlant un:11 its-receipt at the placement center. Concrete workers at the placement center told me that after batches reached them,

i. hey were o t' ten directed to add even more water, in further violation of specifications.

The arc.ounts of each material (including water) to be inte-3 rated into the concrete mixture utilized for safety purposes was specified in regulations. The addition of water by tampering wi th t hese amounts was a clear violation of the regulations. Also, Jrom mv experience with concrete mixing, I knew that when too auch vater was added to concrete the mixture loses its strength.

!y Blount supervisors knew that the process was in violation of c e r,u l a i t o n s , but aince it made the concrete easier to handle, he re alat ions wer e ignored.

m told by a fellow worker, Glenn Garrison, about another

.inu: i c. :n! violation of safety specifications relating to the

..i nduct ion of concrete. Garrison, the cement tender (also referred in construction slang as the " pig operator"), informed me that oil

..a s itakinn into the concrete mixture f en the large blower which

.n

,w ep rm ed. The hatches of cement being mixed with the oil were in route to the containment buildings. I shared Garrison's belief that (la presence of oil in the mixture presented a safety hazard.

l

/

011 considerably weakens the strength of a concrete mixture, by preventing ihe concrete from reaching its normal levels of density and hardness. Garrison told me that he had reported the oil icakage to his supervisor, but to my knowledge no action was taken to remedy the matter. Garrison quit his job at Blount bort , after 1 was fired.

Al1 of the violations of safety specifications which I observed and-in which I was asked to participate were overlooked or noi discovered by CE inspectors. I believe that the CE super-n

.isor were mainly wofried about meeting safety specifications en paper I further believe, from my experience at the Byron facility, i:ha t actual compliance with specified procedures for iroducing concrete for safety-related use was not nearly as important to CE as pushing Blount supervisors into increasing the speed of concrete fabrication to meet the daily quotas for n

t he ci n.s truction proj ect.

have read the above eight (8)-page affidavit, and to the

.e s t- o f my knowledge, it is true, accurate, and complete.

1

.. t ,

)l l l 8 . I  ; } ,

,NU _s g , lL i f. ! '- , f'

, Daniel W. Gallagher -

i WBsC!U11D AND SWORN T0 before me

his _ _ day of 1 /s. , , 1982.

i

/

s s y l Notary Public l

< ' y c .,

. "BLOUNT BROTHERS CORPORATION 9 5 New Y ek Chicago Boston Houston . 3.1377

} *g*

JiT fACli:K,'T A -- N -

9 g filon'gomery, Ala.

ro BYRON STATION - UNITS 1 & 2 I OWNER Commonwealth Edison Company Chicago, Illinois

. o r h a n .iiW- ~ ~~ hini w

B eeESS ria=Lv vou AaE =AxiNo s COPIES

2We

/ } / bh.;d

^ $)

/

llf

/l

1. e f, ,

Gf 3

}'co* fjG l a S3 I.._. l HATM DATA l CHECK,IF SAFETY RELATED CONCRETE _i X , g ,

11 ATCH PL A*. 7 OPE '1ATOR S SIGN ATURE  ;-

g IF HEJECTED GIVE REASONS AND DISPOSITION OF LOAD l

k knem te: , . sq lW, %

l A.M.

g TIME EMPTIED PM i HECEIVED BY:

g X AUTHORIZE D SIGN ATUHE B B. CORP. FOREMAN l

l '

. A T E F< l t . M Y P. J t S g, gg g WATEFt ADDEC G ALS.

( 0751 #NE q;ete p i L U "J P _ _ _ _ . ._ IN.

^ ~ .9

! . % t:

. stat.

4 Cl? 1 Ni - l'

\IR CON TE N T  %

~ ~ '

I' t '- Su l ,

T E MPER ATU>il _OF.

WA 4,- )

Oh* 1 4 l

X m ICt '

AUT,40Rl2E0 SIGN ATUR E. TESTING AGE N T

/37 -:

' -W..

{,

r n ;t '

p

.( p /Mgg'o, UNITE D STATES

} j, 'g NUCLEAR REGULATORY COMMISSION g r ae# REGION ill e '

799 ROOSEVELT ROAD

' b.# ' ,e CLEN E LLYN. lLLINOls 60137 PlVN 2 4 632 o

Docket No. 50-454 Docket No. 50-455 Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice President r Post Office Box 767 Chicago, IL 60690 Gentlemen:

This refers to the special safety inspection conducted by Mr. D. h. Inininison and other staff members of this office on March 29-31, April 1-2, 5-9, 12-14, and May 11, 1982, of activities at Byron Station, Units 1 & 2, author ined by NRC Construction Permits No. CPPR- M o. CPPR-131. This also refers to the discussion of our findings with Mr. W. Stiede and others of your . staff during a meeting in our offices on May 7, 1982.

The purpose of this special team inspection was to assess the adecuacy ni certain aspects of the quality assurance / construction activities r.t the Byron Station. The scope of this assessment included audits of qualit.s assurance program interfaces and overview, corrective action systens, design change control, material traceability of installed structutes and components, electrical cable installation, inprocess inspections, cc.d effectiveness of quality control inspectors. Within these' areas t he inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.

In general, within the areas inspected, the quality assurance program for the Byron Station appeared good. However, examples of prograr im-plementation deficiencies were identified which require corrective actica on your part. Please note that we expect Commonwealth Ecison Company to review prop-ams for its other facilities under construction to assure th it similar rioblems do not exist at these facilities.

The activities that appeared ta be in noncompliance with NRC requirements aro specified in the enclosed Appendix. A written response is required.

Ir, responding to noncompliance Item #2, please describe the action taken or planned to assure that: (1) other quality control inspectors are prcperly c

L  %

-v 1 a ,

Q \

t umonwealth Edison Company 2 i

.nm o 41982 .

l trained and certified, (2) quality control inspectors working for contractors that have completed safety-related work and no longer have personnel on site were properly trained and qualified to perform the inspection functions sssigned, and (3) inspections performed by quality control inspectors that were inproperly trained and qualified were valid.

We are also concerned about your past performance concerning the staffing of the l'yron QA Superintendent position and the on-the-job training of 3 aur liyron Site Quality Assurance personnel as discussed in the details of this report. Please provide us with a response explaining what action

,;u wil: be t.iking to assure that your Quality Assurance Organization 5 statted and trained to a level that will ensure effective oversight of 2 a l it:, activitics.

la accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter, the. cnclosures, and your response to this letter will be placed zu the NRC'. Iablic Document Room. If this report contains any information t5at you (o your contractors) believe to be exempt from disclosure under is CFR u.S(1)(4), it is necessary that you (a) notify this office by tele-

..cne w2 thin ten (10) days from the date of this letter of your intention ta file a roquest for withholding; and (b) submit within twenty-five (25)

2ys freu t he date of this letter a written application to this office to

-ithhold such information. If your receipt of this letter has been celayed st.ch that less than seven (7) days are available for your review, icase notify this office premptly so that a new due date may be estab-

shed. Consistent with Section 2.790(b)(1), any such application must be accompanied by an affidav2t executed by the owner of the information J.ich identifies the document or part sought to be withheld, and which tantains a full statement of the reasons which are the bases for the

1 aim that the information should be withheld from public disclosure.

This section further requires the statement to address with specificity tue cou,Iderations listed in 10 CFR 2.790(b)(4). The information sought to be withheld shall be incorporated as far as possible into a separate p :: of the affidavit. If we do not hear from you in this regard within t; t spniided periods noted above, a copy of this letter, the enclosures, nd your response to this letter will be placed in the Public Document 03.

m w-

, a.nos.. a ! t L Edison Company 3 y-j ej 4 (42 W.: will gladly discuss any quest ions you have concerning this inspection.

Sincerely,

/

d . E. Norelius, Director Division of Engineering and Technical Programs

. . ; c s u r . ;,

Al pendix. Notice of Vit I c.t ic n Ir.81. <. t i or. Repo r t No. 50'-i.54 / 62-05 and Nc. 3 r'- .: 3 / 6 2 -04 w/( r.c i s :

.zis O. De?Gecrge, Director of Nuc itar I icer. sing

'.' I. Schlosser, Project Manager aner Forensen, Site Pr oject S upe r ii.t cride::t E. ys2to, Station Supe r :i.t ender:t

3/Docu=cnt Ccntrol Det.k (RIDS) 1.~ s i d e r.t ;nspectcr, RII] Byron L -s ider.t inspector, RIII Braid-ood 1: .r.en I e s r ,s t act , Office of a :s i < t .it t A:torney General in 9 (:acrry

Appendix NOTICE OF VIOLATION Ccemonwealth Edison Company Docket No. 50-454 Docket No. 50-455 A 1, a resalt of the inspection conducted on March 29-31, April 1-2, 5-9, 12E24, and May 11, 1982, and in accordance with the NRC Enforcement Policy, 07 l'R 9937 (March 9, 1982), the following violations were identified:

1. 10 CTR 50, Appendix B, Criterion I, states in part, "The authority and duti s of persons and organizations performing activities affect-inn th" safety-rcisted functions of structures, systems, and com-ponents shall be clearly established and delineated in writing" and "Such persons and organizations performing quality assurance functions saall report to a management 1cvel such that this required authority and organ izat ional freedem, including sufficient independence from a...i and u hedule when cpposed to safety considerations, are provided."

Thi f cersee 's Topical 11eport , CE-1-A, Revision 20, Section 1.A states "D _ an has prime responsibility for controlling the quality of on-site ne:k bv field contractors," .. "The Commonwealth Edison Company Quality Ar m mcc Program for Nuclear Generating Stations covers the organiza-t i< n ar ranger..ent whereby the Quality Assurance Department is a separate a v. ,ndependent organization."

Co:c . ary to the above:

a. On " arch 30, 1982, it was identified that the Quality Assurance Manager for liatfield Electric Company, as shown in the Quality isssurance Manual, reports to the Vice-President, who is located on :.ito and has direct responsibility for cost and schedule.

b. On April 2, 1982, it was identified that t..e Quality Assurance 1anager for Powers-Azco-Pope, as shown in the Quality Assurance Manual, reports to the Project Manager, who has direct respons-ibility for cost and schedule.

{

i 1 c. On April 8, 1982, it was iden,tified that the Project Construction Department of the licensee is part of the approval chain regarding l the hiring and promoting of contractor's quality assurance personnel.

! d. On March 30, 1982, it was identified that the Hatfield Electric

! Corpany has been operating with a Quality Assurance Organization

other than that described in their Quality Assurance Manual.

i i

4 I

n~ ,-

a 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 Manual.

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

L. 10 CFR 50, Appendix B, Criterion II - Quality Assurance Program states in part, "The program shall provide for indoctrination and training of perior nel performing activities affecting quality as necessary to assure that suitable proficiency is. achieved and maintained."

Cca.aunwealth Edison Company (CECO) letter, L. O. DelGeorge to D. J Eisenhut, U.S. NRC, Director, Division of Licensing, dated August 17, 1981, affirmed CECO commitmen't to Regulatory Guide 1.58, ANf! N45.L.e-1978 as required by Generic Letter 81-01.

ANFi N45.2.e-1976 - Paragraph 1.1 states in part, "This Standard dclitcates the requirements for the qualification of personnel who peiform in:,pection, examination and testing to verify conformance te y ecified requirements of nuclear power plant items (structures, syst e ms and compononts of nuclear power plants) where satisfactory pernamance is required to prevent postulated accidents which could

c. m undue risk to the health and safety of the public, or to mit inate the consequences of such accidents if 'they were to occur."

ASS! N45.2.6-1978 - Paragraph 1.2 states in part, "The requirements of tlis Standard apply to personnel who perform inspections, examina-tiens, and tests during fabrication prior to and during receipt of ite's at the construct 19n site, during construction, during peropera-t icnal and startup test. . . ." The requirements apply to personnel of the owners. ., plant designers and plant constructors...."

t.N51 N45.2.6-1978 - Paragraph 2.2 states, "The capabilities of a candidate for certification shall be' initially determined by a suit-able esaluation of the candidate's education, experience, training, test results, or capability demonstration."

ANF1 N45.2.6-1978 - Section 3.1 states, "The requirements contained wit hin this section define the minimum capabilities that qualify

, personnel to perform inspections, examinations, and tests which are l wit hin the scope of this standard."

i ANSI N45 J.6-1978 - Sections 3.2, 3.3, and 3.4 specify the personnel l car abilit ies of Level I, II, and III inspectors respectively. Sections ,

! 3.5, 2.5.1, 3.5.2, 3.5.3 provide education and experience recommenda- I j ticas foi 1.evel 1, 11, and III inspectors.

5 i

i i

l 1

. _ , , = . - _ . . ~ , .,_s ..,._,__...,__,,,__.---.___._,_.m. _ _ . _ _ . _ , ~ , , _ . _ _ , _ . _ . . _ , , _ , _ _ _ _ - , _ , , , , , _ _ . . . . . _ , , , , - . ~ , .

4. .

y Appendix- ,

3 q _

ANSI Na5.2.6-1978 - Section 4 states in part, " Personnel who are assignec the responsibility and authority to perform functions covered

~

by this .itandard shal1 have, as a minimum, the level of' capability shown in Table 1...."

Contrary to the above, certain contractor QA/QC supervisors and i m. p r. tors were not adequately qualified and/or trained to perform s af e t y -r elated inspection f unctions. Examples of apparent nonccam-pl.mr- are identified in paragraph h.(2) of the attached report.

Th n, i, i Severity Level IV violation (Supplement II).

. ID Crs 50, Appendix B, Criterion V states in part, " Activities affect-i n c, q.ility shall be prescribed by documented instructions, procedures, or oi winp, of a type appropriate to the circumstances ..."

The licensee's Topical Report, CE-1-A, Revision 20, Section 5 statcs,

" Tor qiality assurance actions carried out for design, construction, te:,;ing, and operation activities will be described in documented instructicns, procedures, drawings, specifications, or checklists."

" Activities affecting quality are required by the Edison quality prcgram to be prescribed by documented instructions, procedures or d r . ia g:, . " a Cm.;rary to the above; the following activities were not controlled by rrocedares or instructions:

n. On '! arch 30, 1982, it was identified that Hatfield Electric Cor.pany was utilizing a Discrepancy Report System, which was not referenced or controlled by a procedure, to track and correct discrepancies and nonconforming conditions discovered during inspections of safety-related equipment.

b. Oi' April 2, 1982, it was identified that Powers-Azco-Pope was utilizing a Fabrication Installation Surveillance System, which was riot controlled by a procedure, to track.and correct dis-rrq ancies and noin:enforming conditions discovered during in-spections of safety-related equipment.

T)

Appendix 4

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

~ Carpany procedures did not conta!n an electrical cable rework precedure nor the requirements to calculate electrical cable

- Weall pressures prior to pulling cable.

d. Da April 7, 1982, it was identified that the Hatfield Electric Comp any's NCR form contained a section titled " Action to Prevent hecurrence" but. there was no direction in the body of Procedure

'. amber 6 for actions to be taken to satisfy this requirement nor dae. the procedure assign responsibility for this section of the N::l< .

Tb u . a Severity Level IV violation (Supplement II).

10 CFl: So, Appendix B, Criterion XV, states in part, " Measures shall Le est ablished to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent nse or i t.s t a l la t ion . "

The licensee's Topicaliieport, CE-1-A, Revision 20, dated February 17, 1962, Section 15, states in part, " Items involving construction, main-tenance, and modificaticns which are found nonconforming...will be controlled to prevent their inadverent use or installation."

Contiary to the above:

a. On " arch 31, 1982, it was identified that three (3) CECO noncon-formance reports (F-634, F-645, and F-682) had been voided rather than closed, with reference to corrective action taken to resolve the nonconformance. By voiding the subject NCRs, the tracking system to verify that the approved disposition has been completed and corrective action to prevent recurrence i

is rmgat ed. Also, the voided NCRs are removed from the trend analysis system.

l

! b. On April 7, 1982, it was identified that three (3) nonconformance repcrts (95, 99, and 100) had been voided by the Hatfield Electric Company rather than closed, with reference to corrective action taken to resolve the nonconformance. The subject NCRs were voided becausa an ICR was or would be iesued to accept the items as installed. At the time the NCRs were volded, there was no i n<scrance that all the FCRs would be approved. By voiding t!.e NChn, the tra: king system to verify that tle proposed disposition was accepted, was siegated and the NCRs were removed from the tioni analysi, system.

1 s

J Appendix 5

c. Cc Ag.ril 7, 1982, it was identified that the Hatfield Electric Ccmpany hsd improperly closed NCR 168, in that after CECO cry,inaering dispositioned the subject NCR to replace the item, the liat f ield Electric Company closed the NCR without accomplish-isn the approved disposition. At the present time, there is a nrnccaforming cable installed, and the tracking system to replace the table, has been negated.

Tbit i: n Severity Level 1V violation (Supplement II).

10 Cth 50, Appendix B, Criterion V states, " Activities affecting quality shall be prescribed...and shall be accomplished in accordance with these instructicas, procedures or drawings."

The licensee's Tcpical Report, CE-1-A, Revision 20, Section 2.2 corta i t s t o comply with:the Regulatory Position of Regulatory Guide 1.33 Fevision 2, which endorses ANS1 N45.2.2-1972. Also Section 5 states, "The quality assurance actions carried out for design, con-struction, testing, and operation activities will be described in docuraented instructions, prccedures, drawings, specifications, or checklists."... "Activitics affecting quality are required by the Edison quality program to be prescribed by documented instructions, procedures or drawings."

Ccatrary to the above; the followin>; activities were not accomplished according to procedures or instructions:

a. On April ~2, 1982, it was identified that Powers-Azco-Pope was

• storing rejected material ampng accepted material in Warehouse No. 4 This in contrary to their Procedure No. FP-3.

b. On April 2, 1982, it was identified that Powers-Azco-Pope had not tagged a defective torque wrench with a Reject Tag. This is centrary to their Procedure No. FP-11.

c. On '!crch 30, 1982, it was identified that Hatfield Electric ren,mny did not tag torque wrenches which were past their cali-brat f or due date. This is contrary to their Procedure No. 24.

d. On April 5, 1982, of 13 reports reviewed it was identified that 12 nonconformance reports prepared by Powers-Azco-Pope did not address corrective action to prevent recurrence. This is contrary to their Quality Assurance Manual, Section B-8, paragraph li - 8 . b . 2 .

e. Cn April 7, 1982, it was identified that the conditions main-tained by the licensee in Warehouse No. I and No. 5 were contrary to CI Co Quality Precedure 13-1 and to the requirements of ANSI h45.2.2-1972.

Appendix 6 This is a Severity Level V violation (Supplement II).

6. 10 CFR 50, Appendix B, Criterion VI, states, " Measures shall be established to control the issuance of documents, such as instruc-tions, procedures, and drawings, including changes thereto, which prescribe all activities affecting quality." ~

The licensee's Topical Report, CE-1-A, Revision 20, Section 6 states, "A document control system will be used to assure that documents such as specifications, procedures, and drawings are reviewed for adequacy and approved fer release by authorized personnel."... "Each receiving office or area shall have a controlled method for checking rm.eipt of new or revised documents and assuring that the latest revu.ed dccument is in use."

Cent rary to the abave:

a. On April 4, 1982, of 12 drawings reviewed it was identified that one drawing located in the Johnson Controls Incorporated on-site -

office drawing file was not of the proper revision.

b. On April 7, 1982, of 10 drawings reviewed it was identified that two drawings located in the Hunter Corporation document station 1-H were not of the proper revision.

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

10 CTH 30, Appendix B, Criterion IX, states in part, " Measures shall be established to assure that special processes, including welding...,

are controlled and accorplished by qualified personnel using qualified 7,procedutes in accordance with applicable codes,...."

The licensee's Topical Report, CE-1-A, Revision 20, dated February 17, IW:2. page 9-1, Revision 15, dated January 2, 1981, Section 9, " Control of Speciil Processes," third paragraph, states in part, that, " Process cot t roi ;rocedures will be used as required by specifications, codes

or u.-u.d eds, as applicable...."

! Th. AS:E BLPV Code Section III,1974 Edition, Summer 1974 Addenda, 1

A n i .. s e N\-4000, Sabarticle NA-4411, states in part, that "The

! p r . n ...n aall include measures to control the issuance and disposi-t mo of d xunents, such as. ., instructions, procedures,..., includ-in). < h a:ws thereto, which prescribe the activities affecting quality.

Th. s . ntasures shall assure that documents including changes. ., and d i: L: .br.ed to and used at the location where the prescribed activity is p " . . m .r e d . "

l l

4 l O

'O Arjendix 7 Contrary to the above, on April 13, 1982, it was identifed that welding van not being accomplished in accordance with applicable codes, in that, controlled welding procidure specifications with the associated welding parameter sheets were not located at the prescribed activity (welding) in 3 out of.4 locations checked. .

Tn ts Lis a Severity Level V violation (Supplement II).

F. 10 CFR 50, Appendix B, Criterion XVII states, " Sufficient records shall be maintained to furnish evidence of activities affecting q uia l i t y . Consistent with applicable regulatory requirements, the applicant shall establish requirements concerning record retention, soi.h as duration, location, and assigned responsibility."

The licensee's Topical Report, CE-1-A, Revision 20, Sect n 2.2, co.tmits to the Regulatory Position of Regulatory Guide i.88, Revision 2, which endorses ANSI N45.2.9-1974.

Contrary to the above, on April 7, 1982, it was identified that Midway Industrial Contractors did not provide the security standards established by ANSI N45.2.9-1974, to preclude the entry of unauthorized personnel into the storage stea and to guard against larceny and vandalism.

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

. 10 CPH 10, .\ppendix B, Criterion XVIII states, "A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the et i emt iwaens of the program.

T5- 1itensee's Topical Report CE-1-A, Revision 20, Section 2.2 commits-to e nrply w tt h the Regulatory Position of Regulatory Guide 1.144, Rn i' ton 1, el ich endorses ANSI N45.1.12-1977.

Cn d : try to the above, on flarch 29, 1982, it was identified that the no iii repsr s of Commonwealth Edison Company, Powers-Azco-Pope, Ptitstm gb Testing Laboratory, Johnson Controls, Incorporated. !!unt er Gn: : rat icn, and llatfield Electric Company failed to include the tritoris, established in ANSI N45.2.12-1977, regarding persons con-to tod in the audit and a summary.nf audit results including an ec+! int 2on statement regarding the effectiveness of the quality as. trance program elements which were audited.

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

O i

v-o-

(ppendix 9 8 l'ursuant 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.x n t or explanation in reply, including for each item of noncompliance:

11) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full (uepliance will be achieved. Consideration may be'given to extending your response time for good cause shown.

n h at e ,js a ,l'f /hh f ' Noreffus, Director

,/ '

, ct C. E.

Division of Engineering and Technical Programs I

i 1

l l

i 1

F l

w

m ..

. .h.

U.S. NUCLEAR REGULATORY COMMISSION a

REGION III Leport Nos. 50-454/82-05(DETP); 50-455/82-04(DETP)

Docket Nos. 50-454; 50-455 -License Nos. CPPR-130; CPPR-131 Licensee: Cen.monwealth Edison Company

_ P. O. Box 767 Chiciago , IL 60690 Facility Name: Byron Station, Unit I and 2 Inspection At: Byron Site, Byron, IL

'r.spect wn Ctr. ducted: March 29-31, April 1-2, 5-9, 12-14, and May 11, 1982.

,L/12lc-s~u'L c'~

Jnspectors; D. H. D d ^ '

Qu/lbasielsonA0 (I M. Peschel k/4!F d-

"bY W R. S. Love S/A/ ',:L M%' 11. M. bescott 7cb g A a

,t.7,{0 s e "L u

/

jt E. H. Nightingale d 2/[d'L ,

.47W L.u s cJ/f#.L .

/ 'a' . Forney (- t- f c.-

[(SRIByron)

}

t P.fh}es/ hishian 6/jc/g r_

p .N E Headquarters) l-fpprcred By:

.I79A[< 6ca llc~

D. II. Danielson, Chief d /t// /

i- Materials and Processes Section  ;

'l 2nspect_ ion Summary l 'n yecticn ca p rch_29-31,_f.pril 1-2, 5-9, 12-14, and May 11, 1982 (Reports i

.a._5G 454/62-05(DE_TP]j_.50-455/82-04(DETy l i

1

. . . . . - ,, . - . - ,_r - - _ . - , , . , , . , . - - . . . . - . . - - , -

Areas _luga<tedj QA Program interfaces and overview; corrective action

, ys ten.s ; des ir.n change unitrol; material t raceability of installed struc-tures and_ components; electrical cable installation; inprocess inspections; QC ins p( 6 :cr elfcctiveness. The inspection involved a total of 662 in-

.eectcq-bours onsite by seven NRC inspectors.

19 suit s : Of the areas inspected nine apparent violations were identified

'1tlur( tc assure contractors are operating with a QA organization as

d. w.ribal in their QA manual and to assure that QA is suf ficiently inde-pondent frem cost and schedule - paragraphs b.(6).(b), b.(8).(b), and b.(10).(b;; failure of site contractors to control the issuance of docu-

,mnts - b.(10),(b); failure of site contractors to follow their procedures

- paragraphs b.(10).(b), and c.(2),(d).2; failure of site contractors to a compli:,b activities. in acCrdance with procedures paragraphs b. (10). (b),

o (2) . (c ) . l . and f. (2) . (a); f ailure to include certain ANSI N45.2.12

..riteria in CFCo audit reports of contractors paragraph b.(10).(b);

! illur e. e a site contractor to meet certain security standards established

h. ANSI N 5.2.9 for storage of records paragraph b.(10).(b); failure to

- et ANSI N45.2.6 qualification, certification and training requirements ne cer.t ractor QC inspectors paragraph h.(2); failure to specify complete ami adcquate ' corrective actions _ on nonconformance reports paragraph

r. (2).(a).4; failure to accomplish welding in accordance with applicable enios - paragraph g.(2).(d).

2

v b

DETAILS 1

3 Persons Contacted Coracnwealth Edison Company (CECO)

• W. Stiede, Assistant Vice President

• L. DelGeorge, Director of Nuclear Licensing

• V. I. Schlosser, Project flanager -

• W. J. Shewski, Quality Assurance Manager

• G. Sorensen, Project S;iperintendent ali. Taetken, Assistant Project Superintendent er:1. A. Stanish, QA Superintendent, Byron R. J. Parr, QA Supervisor K. J. Ilansing, QA Supervisor T. R. Scmmerfield, QA Superintendent, Braidwood J. J. Mihov11ovich, Structural Supervisor, PCD R. E. Klingler, QA Qupervisor, PCD G. F. ?! arcus, Director of QA, Engineering / Construction J. O. Binder, Electrical Supervisor, PCD t!. E. Lohmann, Mechanical Supervisor, PCD C. J. Temashek, Startup Coordinator

11. J. Maczmarck, QA Engineer A. A. Jiras, Project Operations Analysis Supervisor

• T. Trana, Nuclear License Administrator P. Donavin, Project Engineering Department R. E. Querio, Startup Superintendent

• J. T. Westermeier, Project Engineer R. Gruber, QA Engineer J. Elink, QA Inspector P. Nalzenski, QA Engineer '

J. foney, Engineering Assistant P .!teriba, QA Engineer E Key, Senior Euyer L Channell, Material Coordinator R S_hwirtz, QA Engineer S.o e :t q.d Lundy Engine _e rs (S&L) h h4 bin. Senior OA Coordinator D a vu . Engineer, PilD OT. F Thor ell, Senior Electrical Project Engineer V. C isci, Project Leader J. Kolumky, Electrical Project Leader We u . n;hguse_(WJ D. h Faaser, Manager, SAMU

h. St ahl, QA Engineer, NTD Y. Kau, Associate Engineer, PIDG e

i 1

3 l

1

- i

. l{atfield !j_lectric Company _plECo)

G. Van.lerhei, Project flanager J. Buchanan, QA ?!anager A. Koca, QC Supervisor R. Btrue:oski, QA Supervisor D. St one r , QC Foreman L. Biooge, QC Inspector J . 'lo iren e , QC Inspector Pev.r -A:..o7: 1ope,lPAP)

R. i.a rl. i s. , QA ? tanager

!! . A naboe, Engineering flanager C I:sener, QC Supervisor A. l..rii a . QC Inspector H lo mi le others Corporat ion (BBC)

R . 11. I!ay, QA/QC llanager W. W2: Is, QC Inspector Elv .o Se rvices , Inc.

R . lic t on.r . iso , NDE Supervisor O

Jahrmon Cont rols , Inc.

11 . Shah, QA flanager S. Pe.i r son , QC Inspector Pit:sburgh Testing Laboratory (PTL)

.I . Trouttran, Site !!anager J. Chasm, Calibration Technician G. %hamrnad, Site Auditor

!;id av In.last ries Cont rpctor, Inc.

!! . Windser, Site !!1naget

's 1. a r i nst allation Set vices Certpany (NISCo)

J. P2 n2 t: , QA/QC Flanaget Nm ' ..a r P we r Services (NPS)

W. Whitalar. Project QA Engineer Re,..aolo Sheet !!e tal Works ,_Inc .

A. 'I F l. !el;e1, QA Supervisor 4

~

r Hunter Corporation H. Sonsag, QA Supervisor L. liaddick, QC Inspector D. Cerasani, Piping Engineer L. Ilill, Auxiliary Building Superintendent W. Evertt, Containment building Superintendent D. Ashland, Warehouseman J. Morrison, Project Engineer

=J. Young, }! anger Engineer A. Sinon, Administrative Supervisor, QA R. Irish, Administrative Assistant, QA li. Lundquist, Material Control Supervisor U. S. Nucicar Regulatory Commission (Region III)

• C. E. Norelius, Director, Division of Engineering & Technical Programs W. S. Little, Chief, Engineering Inspection Branch

< 73 L. McGregor, Senior Resident Inspector, Braidwood L. Cox, Secretary

• Denotes those presonnel attending the exit meeting held at the USSRC Region 111 office on May 7, 1982. During the inspection at the Byron Stat ion exit meetings were held on a daily basis in order to keep tne licensee informed of any findings.

The in:.pectors also contacted and interviewed other licensee and cot.t rntor personnel during this inspection.

l'in , i c i, or Progrjyn, Areas inspected

a. Gen.c r a ) Background Tue pur pose of this special team inspection was to determine if th.: re are indications of existing or potential construction p4 cblems similar to some of those identified at a number of other piants under construction. The scope of the assessments included quality assurance program interfaces and overviews, corrective action systems, design change control, material traceability of installed structures and components, electrical cable installa-tion, inprocess inspections, and effectiveness of quality control .

.nspectors.

O 5

y ---u e- .- _ -~ . se r > = ~ . a ss.. .sa - _ s.u- -i - su. ,

- . . . - Lx Prepared By: J. M. Peschel i

4 P. Keshishtan

b. QA Program 'nterfaces and Overview (1) Quality Assurance Manuals Reviewed Pittsburgh Testing Laboratory Quality Assurance Manual

1. QA-!!-1, Revision 4, September 21, 1979

/

Powers-Azco-Pope Quality Assurance Manual, Revision 3 j December 7, 1931 Commonwealth Edison Topical Report, Revision 20, Tebruary 17, 1962

, Johnson Controls, Inc., SECD Quality Assurance Program, j Revision 0, June 29, 1978

,rlatfield Electric Company Quality Assurance !!anual, lievision 9, August 13, 1979 Ebasco Nuclear Qaality Assurance Program Manual, Revision 10, September 30, 1981 4

Hunter Ccrporation Quality Assurance Manual, Revision 5, August 1, 1981 i Nuclear Power Services, Inc. , Quality Assurance !!anual, l Revision 1, January 13, 1981 Reliable Sheet Metal w'crPs. Inc., Quality Assurance Manual, July 21, 1981

] (2) Procedures Reviewed ,

(a) Corrn onwealth Edison Company c,

Byrg @ ality Instruction (BQI)

BQI-1, Revision 2, March 22, 1982 Generating On-Site Quality Instructions BQ1-7.1, Revision 2, March 22, 1982 On-Site Contractor Non-Conformance Reports BQI-7.2, Revision 5, March 22, 1982 QA Handling of CECO !,on-Conformances BQ1-9, Revision 4, March 22, 1982 QA llandlir.g of Field Change Requests BQI-10, Revision 4, February 25, 1982 Sit e QA llandling and Review of On-Site Contractor Procedures 6

i

r l

i BQI-11.1, Revision 4,tiarch 22, 1982 Byron Site QA Audits BQI-12.1, Revision 1, March 22, 1982 l Installed Equipment Surveillance Instructions BQl-24, Revision 1, March 22, 1982 Byron QA Training Program Byron Site Instruction (BSI)

BSI-5, Revision 5, October 20, 1980 0 Material and Equipment Receiving, Receiving Inspection Storage, and Removal from Storage Instruction Quality Procedure (QP)

QP, 2-1, Procedure for the Revision of the Quality i Assurance Manual - Engineering, Construction l and Operation, Revision 63, February 24, 1982 QP, 2-2, Training of Personnel to meet Quality Assurance Requirements, Revision 63, February 24, 1982 QP, 3-3, Classification of System, Components, Parts and Materials, Revision 63, February 24, 1982

QP, 4-2, Evaluation of Contractor's Quality Assurance Program, Revision 63, February 24, 1982 QP, 5-1, Quality Instruction and Procedures, Revision 63, February 24, 1982 QP, 7-1, Control of Procured Material and Equipment, Receiving and Inspection, Revision 63, February 24, 1982 QP, 12-1, Calibration Control of Commonwealth Edison Test and Measurement Equipment, Revision 63, February 24, 1982 QP, 15-1, Reporting Quality Nonconformance during Construction and Test, Revision 63, February 24, 1982 QP, 15-2, Reporting Incidents and Deficiencies that occur during Construction and Test, Revision 63, February 24, 1982 QP, 16-1, Corrective action for Reportable Deficiencies -

l and Quality Nonconformances that occur during Construction and Tests, Revision 63, l February 24, 1982 l QP, 17-1, Quality Assurance Records, Revision 63, j February 24, 1982 l

QP, 4-1, Request for Bid, Proposed Evaluation, and Recommendation, Revision 63, February 24, 198; QP, 18-1, Quality Program Audits, Revision 63, j February 24, 1982 QP, 18-2, Surveillance of Contractor Quality Assurance Control Activities, Revision 63, February 24, i 1982 l

l l

! 7 l

I t

=.

General Procedure General Procedure No. 738, Site Buying, February 2, 1981 (b) Hatfield Electric Company Procedures Procedure #6, Revision 6, January 15, 1982 Reporting of Damaged or Nonconforming Material or Equipment Procedu e US, Revision 2, Issue 1, July 6, 1981 Audits Procedure #9E, Revision 6, Issue 1, January 23, 1981 Class I Cable Pan Identification Procedure #11, Revision 12, February 2, 1982 Class I Cable Termination and Splicing Procedure #17, Revision 2, October 10, 1981 Qualification of Inspection and Audit Personnel Procedure #19 Revision 4, Issue 1, January 24, 1981 Equipment Turnover Reporting Procedure #20, Revision 8, November 20, 1981 Class I Exposed Conduit System Identification Procedure #23, Revision 8, Issue 1 January 22, 1981 Concrete Expansion Anchor Instal-lation Procedure #24, Revision 1 Issue 2, January 28, 1980 Control and Calibration of Meters and Instruments Procedure #29, Revision 5, November 20, 1981 Field Initiated Request for Design Changes O) lunter j Corpo_ ration Site Implementation Proceduras 4.201 Revision 4, January 19, 1982 Installation Verification 7.502 Fevision 7, August 20, 1981 Control of Measuring and Testing Equipment 11.101 Revision 4, April 28, 1981 Nonconformance Processing 12.301 Revision 5. March 19, 1981 Internal'and External Site Quality Assurance Audits 20.513 Revision 9, June 8, 1981 Installation of Concrete Expansion Anchors (d) Powers-Arco-Pope Procedures

.n QC-4 Revision 7, September 30, 1981 Nonconformance Control QC-5 Revision 5, December 17, 1981 Site Audit 8

. C' FP-3 Revision 9. December 22, 1981 Material Receiving Inspection Controls FP-4 Revision S September 30, 1981 Material Storage FP-11 Revision 7, January 21, 1982 Calibration and Control of Measuring and Test Equipment (MSTE)

(e) Pittsburgh_ Testing _I.,aboratory Procedure Resident Internal Quality Assurance Audit Plan, Revision 4, November 17, 1981 (f) Johnson Controls Inc., Procedures QAS-210-EY Revision 2, January 28, 1980 Auditor Training and Qualification QAS-211-LY Revision 2, February 5, 1980 Training and Indoctrination Procedure QAS-710-EY Rev2sion 1, September 19, 1979 On-Site Document Control Procedure QAS-1011-BY Revision 3, January 10, 1980 Weld Rod Control QAS-1310-BY Revision 1, Ocotober 30, 1979 Calibration Control of Measuring and Test Equipment QAS-1510-BY Revision 0, April 17, 1979 Status Tag Usage Procedure QAS-1610-BY Revision 0, February 13, 1979 Nonconformance Control Procedure QAS-1710-BY Revision 0, September 18, 1979 Corrective Action QAS-1910-BY Revision 1, November 8, 1979 Audit Procedure SP-611-BY Revision 1, April 3, 1981 Field Change Control Procedure

'M Audits and Miscellaneous Documentation Reviewed (a) Comnonwealth Edison Company

! Audit Reports j i #6-82-4

1. 6-82-08

1. 6-81-300

1. 6-81-308

1. 6-81-329

1. 6-81-330 l #6-81-331

1. 6-81-336

1. 6-81-340 4

I 9

- - , , -- . -,r .- y -,w- - ,- .%., ,.-,---w.4. . - - - , - - - - - ..

-_r~ ,.. , ,,

1. 6-61-344

1. 6-61-354

1. 6-61-357

1. 6-El-360 Gencral Office Audit of Byron Construction Site, April 30, 1981.

General Office Audit of Byron Construction Site, Novcmber 8, 1981.

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

General Office Quality Assurance Audit of Byron Station, November 8, 1981.

Management Audit at LaSalle, Byron, and Braidwood Construct ion Sites and the LaSalle Operating Station, April, 1981, by Energy Incorporated.

Miscellaneous Documentation c, Site Mechanical Organization Chart, March 16, 1982.

Site Electrical Organization Chart, March 16, 1982.

Site Structural Organization Chart, March 16, 1982.

Site Project Construction Organization Chart, March 16, 1982.

1981 Byron Site QA Audit Schedule, Revision 0 and Revision 9 1981 Byron Site QA Survic11ance Schedule.

Byron Quality Assurance Organization Chart, March 22, 1982.

Byren Quality Assurance Status Reports, January 5, 1982 and l'ebruary 4, 1982.

Byrcn Site Quality Assurance Semi-Monthly Report for December 1931.

1982 Byron Site Quality Assurance QP Training Schedule. '

(b) llatfield Electric Company Audit Reports

1. 61-02 l

1. 61-18 981-19

1. 81-20

1. 82-04 g Audit Report of Byron Site Procedure 5, 6 and 22 by Energy Incorporated, September 21, 1981.

Tollow-up Management Audit Repart by Energy Incorporated, [

September 21, 1981. <

10

f Trend Analysis Reports

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

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

1. 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 Schedule 1982 Audit Schedule Quality Assurance Audit Log Mercrandum f rom C. Van Lyssel to W. Brc -k concerning Quality Assurance Organization, March */, 1982.

(c) llunter Cor1 oration Aud_i t Report No. 084-4 Mistellanocus Documentation Audit Sumenry Fourth Quarter Audit Report rollow-up Audit #1 Hunter Audit Summary Report for Fourth Quarter, 1981.

llant er Cor}arat ion, Byron Site Quality Assurance Audit, June 3, 1981.

Ilunter Cor} oration Quarterly Nonconformance Report (Nk)

Sunn ary and Trend Analysis, December 29, 1981.

(d) Powers-Azco-Pope Audit Reports n52 September 29, 1981 st53 October 1, 1981 n54 November 12, 1981

55 Novoaber 12, 1981

<tS6 November 16, 1981 r:57 November 15, 1981 rtSS November 25, 1981 v59 December 3, 1981

1. 60 December 29, 1981

1. 61 January 27, 1982 Management Review Audit, Byron, March 17, 1982 11

< i l

I Miscellaneous Documentation Weekly Storage Surveillance Report, March 10, 1982 Weekly Storage Surveillance Report, March 17, 1982 Weekly Storage Surveillance Report, March 24, 1982 Veekly Storage Surveillance Report, March 30, 1982 (e) Pittsburgh Testing Laboratory i

Audit Reports -

i ,~s, #81-21

1. 81-22

1. 81-23

1. 81-24

1. 81-25

1. 81-26

1. 81-27 i

1. 81-28

1. 81-29 Internal QA Audit #BY-3 j Internal QA Audit #BY-4 Misc.ellaneous Documentation Pittsburgh Testing Laboratory Organization Chart

! Pittsburgh Testing Laboratory Inspectors Eye Examination i Records (f) Jchnson Controls, Incorporated Audit Reports Yearly QA Program Audit No. 00501, May 16, 1980 Yearly QA Program Audit No. 10801, August 5, 1981 AuditReport, Bensenville Office, September 15, 1981 Ncnconformance Reports

1. 001BY November 14, 1980

1. 002BY Nevenber 14, 1980

1. 003BY December 4, 1980

1. 004BY August 19, 1981

1. 005BY February 23, 1982

1. 006BY March 25, 1982

1. 007BY April 2, 1982 (4) Interviews with Site Personnel ,

Interviews were conducted with sixteen personnel from Common-wealth Edison Company, six personnel from Hunter Corporation, three personnel from Powers-Azco-Pope, three personnel fr n L

12

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

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

(r) 1. ensee's Quality Assurance Program (a) Objo_ct ive The objectives of this assessment were to determine:

, that the licensee's Quality Assurance Program, including all amendments, has been approved by NRR.

. If the licensee has control of changes to the submitted Quality Assurance Program.

. If the Quality Assurance Manual is consistent with th0 approved Quality Assurance Program.

(b) Discussien The inspectors reviewed:

1. the licensee's Topical Report, CE-1-A, Revision 20, and determined that the original program and all subsequent revisions have been approved by NRR.

The licensee submits all changes to NRR and includes minor or typographical changes at the same time as substantive changes are submitted.

2. the licensee's Quality Requirements and Quality Procedures and determined that the licensee initiated and controlled changes to the program through QP-2-1. The procedure requires the same level 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.

3 ., the licensce's Quality Assurance Manual and referenced documents to determine whether adequate QA plans and procedures have been established (written, reviewed, approved, and issued) to implement the docketed QA program. The reivew indicated that the 18 Criteria of 10 CFR 50, Appendix B were addressed by the Quality Procedures of the Quality Assurance Manual.

The inspectors reviewed 6 of the 25 Quality Assurance Manuals assigned to Byron Station to determine they were of the latest revisions. The following manuals were reviewed and no problems were detected.

13

M_aylual No. Assigned To 111 Project Construction Superintendent 208 Byron Station Superintendent 177 CECO 0AD Supervisor 191 Byron Station Maintenance Supervisor 62 Byron Station Technical Staff Supervisor 115 Byron Station Quality Assurance Super-intendent (6) . Quality Assurance Program of Contractors (a) Objectives The objectives of this assessment were to determine if the licensee has approved and routinely audits the Quality Assurance Programs of contractors for consistency with 10 CPR 50, Appendix B, and to determine the current status and effectiveness of licensee management of the on-site Quality Assurance Programs.

(b) Discussion The inspectors reviewed documentation, conducted extensive interviews with licensee and site contractor personnel, and reviewed portions of the licensee's and contractor's QA nanuals to determine levels of staffing, organizational independence from cost and schedule, position descriptions, and to determine if the status and adequacy of the QA Programs were regularly reviewed by the licensee and centractor's management.

At the time of inspection the licensee had 13 contractors on rite and each was performing safety related work under their own specific Quality Assurance Programs (QAPs).

Ther.c QAPs had been submitted to the licensee for review and approval. The licensen had reviewed and approved the QAPs prior to the contractors start of work. The licensee was fully aware of its ultimate responsibility for site Quality Assurance and had its own QA organiza-t ien on site to monitor the activities of the various site contractors through the mechanisms of surveillances and audits.

Table 1 is a matrix of licensee and on-site contractors y

performing safety-related work indicating the areas checked and compliance with these areas.

Noncompl_igncej454/82-05-0!a; 455/82-04-01a) 10 CPR 50, Appendix B, Criterion I, requires that "Such persons and organizations performing quality assurance functions shall report to a management level such that 14

^~~

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

w .

--- - . --- --. w-,-- =mem --z this requ! red authority and organizational freedom, including sufficient independence from cost and schedule l,P when opposed to safety considerations, are provided."

Contrary to this requirement, the inspectors found that the QA !!anagers of both ifatfield Electric Company and Powers-Azco-Pope (PAP) reported directly to on-site managers who had direct responsibilities for cost and schedule for their respe,ctive contracts. The Itatfield QA Manager reported to the Vice-President and the PAP QA Manager reported to the Project !!anager.

Unreso_lved Item (454/82-05-02; 455/82-04-02)

In addition to the foregoing, it appeared that the QA Representative for Johnson Controls had production responsibilities that also conflicted with organizational independence. r. review of the activities of Pittsburgh Testing Laboratories (PTL) indicates that there is no PTL on-site QA organization other than a site auditor and that for a substantial period of time each week PTL activities are not under surveillance. This condition occurs because there are two shifts for PTL inspectors and only one auditor.

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

(1) Lu ensea 'la n agenyn t Assessment of_ the Quality Ay.orance Program (6) 9bjr(tive

.u Tim objective of this assessment was to determine if a periodic assessment of the licensee's Quality Assurance Program is conducted by Commonwealth Edison Company upper level management.

(b) _Disgussion The inspectors reviewed audits of the Byron Construction site conducted by a General Office Audit Team. These Ti-annual audits are supplemented by a biennial audit conducted by an independent auditing organization. The audits cover the entire scope of the Quality Assurance Program and are reviewed by upper level management.

~

The licensee's Quality Assurance organization is headed by a site QA Superintendent. He is assisted by two Supervisor's who direct the activities of thirteen QA Engineers and Inspectors in monitoring and auditing the activities of the site contractors. In addition f our Pit tsburgh Testing Laboratory personnel are assigned to the organization for specific documentatica related assignments.

15

___ I

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 typt of orga::ization should be able to ef fectively 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 affecting the execution is the stability of service for the QA personnel.

A key individual in a QA Program is the on-site super-  !

int (ndent. He has the direct responsibility for the

~

QA perfctmance of the contractors and other plant related setivities. It is he who anticipates problem areas, sees to the training of his staff, directs the '

activities of his staff and is instrumental in producing a quality product. Since January 1976 there have been five QA Superintendents at the Byron Site:

i J. Pizzies January 1976 to May 1976 D. Jeritz May 1976 to August 1977 I R. Gousden August 1977 to May 1978 T. McIntere May 1978 to January 1981 M. Stanish January 1981 to Present In addition to this undesirable condition, the QA Engineers and Inspectors have an average on-site service time of approximately fourteen months and have limited pr2cr QA experience. Part of this on-site time was spert in training and qualifying for various QA duties.

In addition to this problem, manpower is currently being sent to other sites so that the QA effort is substantially weakened. Out of a staff of sixteen, three men have been, and currently are at other assignments:

R.J. Sch.attz La Salle Station 12/7/81-to 2/19/82; 3/19/81 to Present J. S. llale La Salle Station 1/8/81 to 2/26/82; 3/19/82 to Present

p. J. Nodgenski Quad-Cities Station 9/14/81 to 9/25/81; Byron Pre-op Testing 4/5/82 to Present The constant change over of personnel rasulting in a minimum experience level and transfer of personnel could hinder the QA organizstion in meeting its obligation of effectively implementing a QA program.

In contrast to the experience level of the QA organ-ization the inspectors made a review of the stability of the supervisory and engineering personnel in the construction organization. The key individuals and service time at the Byron Station are:

16

Title Name On Site Since Project Fuperintendent G. Sorensen 1976 Assistant Project R. Tuetken 1977 Superintendent J Lead Civil Engineer J. Mihovilovich 1975 Lead Mechanical 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 problem 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, W. J. Shewski, on April 16, 1982.

!!1s explanation was the the transfer of the QA Superin-tendents was for promotional opportunities in four cases and a death in the case of one superintendent.

His explanation for the large turnover and inexperience level of the QA Engineers and Inspectors was that he desired to seed the licensee departments with QA experienced personnel and also not deny them promotional opportunities.

• his constant change over of QA personnel as contrasted to the stable and experienced work force of the construc-tion grcup indicates the need to create greater promo-tional cgportunities in the QA organization, or the need to have some sort of system instituted to require QA personnel to acquire minimum service time at nuclear sites.

The inspectors reviewed the training that was given to CECO QA personnel after they had completed corporate quality nssurance training. The Byron QA training is an on-the-job type training and is intended to supple-ment the corporate training and enhance the development of nnv QA personnel.

A review of BQl-24, Revision 1, Byron QA Training Program, revealed that although the stated purpose of the instruction was to provide the necessary training to appropriate personnel as quickly as possible, there was no specified length of time in which the training was to be completed. A lack of prompt training was a finding annotated by the General Office Audit of November 1981. A review of on-the-job training records revealed that prompt training was still not being ai.complished and that the corrective action to prevent 17

.__._n

T recurrance, stated in the audit response, was not being effectively implemented. The on-the-job training system had no provision to alert supervisory personnel when a new employee's training was lagging.

BQI-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 management responsibility and cannot be delegated to the new employee. -

Attachment A to BQI-24 lists fourteen areas of training, and specific individuals are designated as authorized t rainers in each area. There are no lesson plans or other types of written guidance for the required train-ing. The lack of a formalized training program is not conducive to the maintenance of a skilled, trained, and competent Quality Assurance Department, k'ith some of the more experienced personnel assigned to duties at other locations the training of the QA department suffers.

Open Item (454/82-05-03; 455/82-04-03)

The inability of the licensee to dedicate resources to .

the Quality Assurance organization to see that their experience base is equivalent to other organizations, leads the inspectors to question the licensee's e f fectiveness in staffing the Quality Assurance Program Organization. In addition, there is no evidence of a Management Policy Statement emphasising the dedication of the Ccmpany to Quality Assurance and quality in

, general. The licensee's position is that the Company policy is stated in the Quality Requirements of the Qaality Assurance Manual. It is our belief that these

~

are an e).planation of the Quality Assurance Manual.

and not a statement of policy.

th) Qcensee quality Assurance Organization (a) Objective The objective of this assessment was to determine if the Quality Assurance Program provides sufficient independence from cost and schedule.

(b) Discussien i

The inspectors reviewed the organization charts in the licensee's Topical Report and they indicate adequate independence for the Ceco Quality Assurance Organization.

Further inspection resulted in concern regarding the activities of the Project Construction Department that i

I

( 18

O appear to be contrary to 10 CFR 50, Appendix B, Criterion I, regarding the independence of the Quality Assurance effort from production.

The licensee's site Project Construction Department is organi::ed with a Manager, Technical Staf f, Project Engineers and Field Engineers. The inspectors inter-viewed four supervisors and the assistant superin-tendent of the construction group and found_cach of them to be knowledgeable and experienced engineers fully capable of meeting their respective respons-ibilities. They all fully recognized the importance of quality assurance and control and were determined to build a quality plant.

The responsibilities of this group include:

Advisor to Engineering for design suitability for constructability.

. Coordinate requests for field revisions.

. Reihipt and storage of materials.

Ass ist Project Engineering in development of overall schedule.

Verify conformance and completeness of contractor's installation to specification requirements.

. Supervise and approve mechanical and structural construction tests.

. Coordinate and provide assistance for electrical construction tests.

. Coordinate preoperation tests.

The Project Construction QC Supervisor and Project Construction Electrical Supervisor have engaged in Quality Assuranco activities independent of the Byron Superintendent of Quality Assurance and the offsite Man.iger cf Quality Assurance. The licensee could not produce a position description for the areas of responsibilities and the duties of the Project Const ruct ion QC Supervisor. An example of specific QA activities engaged in by these supervisors is:

better of November 13, 1981 from the Electrical and QC Supervisors to the on-site Vice President of !!at field Electric Company suggesting duties and responsibilities of the QA/QC Manager and a suggested organization chart.

The activities of the two supervisors in QA activities appears to be contrary to 10 CFR 50 Appendix B, Criter-ion 1, that requires independence of QA supervisors from cost and schedule, in addition, it seriously undermines the effectiveness of the incumbent QA Superintendent 19 n

0

to monitor the activities of the site QA organizations.

The activities of these two supervisors resulted in a reorganization of the llatfield Electric Company QA/QC Department 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, in addition to the foregoing, a further problem with QA independence from cost and schedule arises in that the site Project Superintendent has final contractual approval for some contractor QA organizations concerning salary increases, promotions, and hires for QA non-manual

~

'4 personnel increases. The requests for such action from Hatfield Electric Company and Powers-Azco-Pope do not have a ccncurrence from the contractors Quality Assurance Department and come from the project construction manage-ment.

The follcwing list indicate salary changes or promotions of QA inspectors for site contractors that were approved by the site Project Superintendent.

Date Contractor Position 2/24/82 Powers-Azco-Pope QA Specialist 12/8/81  !!unter Corporation QA Inspector 11/23/81 liunter Corporation QA Inspector 11/3/81 liunter Corporation QA Inspector 11/5/81 Ilunter Corporation QA Inspector The inspectors recognize that the Project Superintendents' responsibility for contract administration requires his final approval for contractors staff size and changes in compensation, however, a question of satisfying the re-quirements of 10 CFR 50, Appendix B, Criteria I relative to QA independence arises. Mechanisms are currently now in effect for such independence in that the Pittsburgh Testing; Laboratory contract is administered by the Corporato Quality Assurance Manager who is independent of cost and schedule.

Noncompliance (454/82-05-Olb; 455/82-04-Olb)

The lack of independence between the Quality Assurance Dep1rtment and the Project Construction Department is in violation of 10 CFR 50, Appendix B, which states in part, "Such persons and organizations performing quality cssurance functions shall report to a manage-ment level such that this required authority and orgsnizational freedom, including sufficient inde-pendence from cost and schedule when opposed to safety considerations, are provided.

20

_n --

I Onon_! tem (454]f2-05-04; 455/82-04-04)

The involvement of the Project Construction Department in Quality Assurance Activities indicates the need for an Interface Document or Interface Procedure to explain the interaction of the licensee's Quality Assurance Organtzation with the Contractor's Quality Assurance Organizations, and the relation of the Project Con-struction Department to all on-site Quality Assurance Organizations.

(9) Quality Assurance Responsibility (a) Object ive The objective of this assessment was to determine if the licensee has the prime responsibility for establish-ing and executing the Quality Assurance Program.

i (b) Discu_ssion The inspectors reviewed the Topical Report and the Quality Assurance Manual and interviewed the licensee's Corporate and Site Quality Assurance Managers and the Qualit y Assurance Manager of selected contractors.

The dccumentation review and the interviews showed that the responsibility of the licensee was established, documented and understood by responsible personnel in both the licensee's and contactor's organizations.

The inspectors were concerned about the lack of a policy s t a t ea cn t from upper management that went beyond the explanation provided in Quality Requirement 1.0 and pro-vided assurance that upper management of CECO supported t he Quality Assurance Program and it objectives.

!'0) Licensee 06ersight of Contractor Activities (a) Objective The objectives of this l assessment were to determine 2f the licensee has effective oversight of contractor nctivities and has detailed knowledge of those nctivitses.

(b) Discussion The inipectors conducted interviews with Quality Assurance Tersonnel from the licensee, Hatfield Electric Company, hunter Corporation, Powers-Azco-Pope, Johnson Controls, Inc., and Pittsburgh Testing Laboratory. These interviews were supplemented by the review of relat ed quality assur-ance procedures, audits and documentations; tour of work l

21 n __

areas, warehouses and field offices; and discussions with licensee and contractor personnel. As a result of the above the inspectors determined that the licensee has a program that should provide an effective oversight of contractor activities. The ability of the licensee to provide this oversight is questionable due to the man-power limitation discussed in the " Licensee Assessment of the Quality Assurance Program" section of this report

,) and the findings noted below.

Contractor _QA Manuals A review of the operating organization of two contractors, Hatfield Electric Company and Johnson Controls, Inc.,

revealed that the present organizatisms were not described in the latest Quality Assurance Manual revisions, Johnson Controls, Inc., changed the title of the Senior QA Ecpresentative associated with Byron from the Quality Assurance Representative to the Quality Assurance Manager and did not update their Quality Assurance Manual.

Johnson Controls operated for approximately five months with this discrepancy, and Commonwealth Edison Company Quality Assurance was not aware of the discrepancy.

1 Hatfield Electric Company was operating with a Quality Control Supervisor and a Quality Assurance Supervisor, both of whom report to the Quality Assurance Manager and who are not reflected in the Quality Assurance Manual. The reason for this disparity is a letter from the licensee's Project Construction Department to the Hatfield Electric Company Vice-President suggesting an organization change.

Noncompliance (454/82-05-Ole; 455/82-04-Olc)

III CFR 50, Appendix B, Criterion I states, "The authority and duties of persons and organizations performing activities affecting the safety-related functions of structures, systems, and components shall be clearly established and delineated in writ ing,"

The failure of Hatfield Electric Company to have its Quality Assurance Manual reflect the actual Quality Assurance Organization is contrary to the above and is an item of noncompliance.

The failure of Johnson Controls, Inc., to have its Quality Assurance Manual reflect the actual Quality Assurance Organization is contrary to the above and is an item of noncompliance.

22 O

The licensee has indicated that the above conditions have been corrected. These items will be examined during future inspections.

Safekeeping of Quality Records A tour was made of the combined vault used by Johnson Controls, Westinghouse-SAMU, Midway Industrial Con-tractors, Ebasco Services, Inc., and Reliable Sheet Metal. The safes of Westinghouse SAMU and Midway Industrial Contractors were found unlocked and with no attendant at the door of the vault. The Westinghouse safe contained computer tapes which were described to be non-safety-related and the Midway safe contained quality records.

Noncompl:ance (454/82-05-05; 455/82-04-05) 10 CFR 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 storage area. This system shall guard against larceny and vandalism."

The failure of Midway Industrial Contractors to lock a safe containing quality records is contrary to the above and is an item of noncompliance.

The licensee has indicated that this situation and the condition of the Westinghouse-SAMU safe have been corrected. This item will be examined during a future inspection.

Daring tours of the combined vault, the Powers-Azco-Pope vault, the Hatfield Electric Company vault and the li-censee's vault, the inspectors noted that entrance holes for conduit and other such piping had not been sealed and possibJe air paths from the exterior existed.

Unresolved Item (454/82-05-06: 455/82-04-06)

ANSI N45.2.9-1974 states that permanent and temporary records storage facilities shall be constructed to protect the contents from possible destruction by fire.

The inspectors are concerned that with the possible air paths arcund conduit s and pipes that the llalon System may not be able to extinguish a fire.

The licensee has indicated that action has been taken to correct this condition. This item will be examined daring a future inspection.

23 O

-3 Surveillances The inspectors reviewed the licensee's Quality Assurance Department 1981 surveillance schedule and noted that approximately seven percent of the scheduled surveil-

'2 lances were not conducted and there was no documented reason for their omission. The licensee did conduct approximately 800 more surveillances than were scheduled with an increase being made in some areas due to problems disccvered or to follow up on audit findings. We recognize that such increased attention is necessary, bet are concerned about the omission of surveillances without substantiating documentation, as surveillances are one of the intergal methods by which the Quality Assurance Organization provides an oversight of con-tractor activities.

Open Iten (454/82-05-7; 455/82-04-7)

The inspectors are concerned about the omission of scheduled surveillances without substantiating docu-mentation.

The licensee indicated that this item will be corrected.

This item will be examined during a future inspection.

Drawing Control The inspectors reviewed selected drawings in the on-site office of Johnson Controls, Inc., and at Hunter Corpora-tion's Document Station 1-H, at the 426 level in the conta itrent .

Twelve drawings were chosed at Johnson Controls, and of those chosen one was not the latest revision as indicated on the Sargent and Lundy master drawing list 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 drawings are >

in the series but are annotated as 1 of " blank".

Ten drawings were reviewed at Hunter Corporation's O Document Station 1-H, at the 426 level in the contain-nent, and of these two drawings , CS-58 and RH-15, were -

not the proper revisions according to the Hunter i

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 been recalled to document control. Hunter instituted l an immediate recall of these drawings.

E 24

O Nonco_mpliance (454/82-05-08; 455/82-04-Og 10 CFR 50, Appendix B, Criterion Vi states, "licasures shall be established to control the issuance of docu-ments, such as instructions, procedures, and drawings, I including changes thereto, which prescribe all activities '

affecting quality." The failure of Johnson Controls, Inc.,

and !!unter 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 inspection.

Process Traceability The inspectors acccapanied two CECO Quality Engineers, one electrical and one welding, on inspections in the containment, auxiliary building and the turbine building to determine if they could trace the installation and inspection process on welds, conduit hanger installation, and cable pan installation. No problems were identified.

Qtta_lity Assurance Procedures Inspectica identified that two on-site contractors per-forning safety related work were using forms which were not controlled by procedures.

llatfield Electric Company is utilizing a Discrepancy Letter, also known as a Trouble Letter, for doccmenting

' incomplete construction, non-conforming contruction, -

requirements for Field Change Requests and other dis-crepant items found during quality control inspections.

These Trcuble Letters have been in use for approximately the last 18 months and about 800 have been generated in this time frame. The Trouble Letters are used as an intermediat e document during inspections prior to corrective work or preparation of FCRs and NCRs and do not become part of the quality records. Trouble Letters numbers e40 thru 670 and 680 thru 720 were examined and it was fcund that in the inspectors opinion Trouble Letters 658, 662, 664, 669, 679, 696, 697, 700 and 721 should have been documented as non-conformance reports.

As an example, in Trouble Letter 679, a Hatfield Electric l Company 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.

k' hen making Quality

, 25

)

Control inspections a Fabrication. Installation Surveil-lance form, for which there is no prescribed procedure is used for purposes identical to the Hatfield Trouble Letter.

The inspectors examined FIS numbers 180 through 216 and in their opinion a number of the FIS's should have resulted in NCRs. As an example, FIS 186 reported items that were installed but did not have the required heat numbers. -

We are not against the use of trouble letters or speed letters to expidite some contractor functions, however, when these documents are used to document inspection discrepancies they must be procedurally controlled.

Nencompliance (454L82-05-09a; 455/82-04-09a) 10 CFR 50, Appendix B, Criterion V states, " Activities affecting quality shall be prescribed by documented instructions, 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 Hatfield Electric Company to utilize a procedure to control their Discrepancy Records is contrary te the above and is an item of noncompliance.

The failure of Powers-Azco-Pope to control their Fabrication Installation Surveillances is contrary 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.

Audits Tlie inspectors reviewed audits that were conducted by the corporate and site quality assurance organizations of Commonwealth Edison Company, liatfield Electric Company, Hunter Corporation, Powers-Azco-Pope, Johnson Controls, Incorporated, and Pittsburgh Testing Laboratory.

The audits were conducted according to an audit schedule and the scope and content of the audits was acceptable.

The audit reports consistently failed to include a list of perso;,s contacted during the conduct of the audit and a summary of audit results, including an evaluation statement regarding the effectiveness of the quality assurance program elements which were audited, as rrqaired by ANSI N45.2.12.

26 n ..

Noncompiinnce (454/82-05-10; 45jf,82,-f4-loj 10 CFR 50, Appendix B, Criterion XVIII states that a comprehensive system of planned and periodic cudits shall be carried out to verify compliance with all aspects of the quality assurance program and to deter-mine the effectiveness of the program.

O ANSI N45.2.12-1977 states that audit reports shall pro-vide a list'of persons contacted during audit activitles and shall have a summary including an evaluation stater.mnt regarding the effectiveness of the quality assurance pro-gram elernents which were audited.

Contrary to the above, the audit reports of the licensee, llatfield Electric Company,liunter Corporation, Powers-Azco-Pope, Johnson Controls, Inc., and Pittsburgh Testing Laboratory consistently failed to include persont ten-tacted during the audit and an evaluation statctr.cnt re-garding effectiveness of the program elements as indicated in the examples listed below: .

Likt of Evaluatton Auditor Audit /t Persons Contacted St at en:ent CECO 6-81-330 Yes No CECO 6-81-308 Yes No CECO 6-81-336 No No CECO 6-81-357 Yes Y.9 CECO 6-81-309 Yes No CECO 6-81-344 Yes No CECO 6-81-340 Yes Nn CECO 6-81-300 No No CECO 6-82-08 No No llat field 81-02 No No llatfield 81-18 No No llat field 81-19 No No llunter 84-4 No No llunter None July 9, 1981 No No Johnson 00501 No Yes Johnson 10801 No Yes PAP S2 No No PAP S4 No No PAP 55 No No PTL 81-21 No No PTL 81-23 No No PTL ,81-25 No No L The licensee has indicated that acticn has been taken to correct this situation in future audits. This item will be examined during a future inspection.

27 e . .. _

O

?!easurinju nd Test Faufpment The inspectors reviewed the procedure and methods for control of t!easuring and Test Equipment used by Hunter Corporation, Hatfield Electric Company, Powers-Azco-Pope, Johnson Controls, Inc., and Pittsburgh Testing Laboratory and inspected various instruments in office and field locations.

The inspectors identified no problems with Hunter Corporation, Johnson Controls, Inc., and Pittsburgh Testing Laboratory (PTL).

During a review of torque wrenches in the HatficId Electric Company Quality Assurance office and the Powers-Azco-Pope Quality Assurance office the following items were identified.

Hatfield Electric Company: The stcrage of torque wrenches was not according to Hatf. eld Procedure

1. 24 as the wrenches that were past the calibration date were not red tagged and they wtre stored on the same shelf as wrenches currently in calibration.

IiE-151, HE-142, and HE-135 are some of the untagged, uncalibrated torque wrenches stored with calibrated wrenches.

Po. ors-Azco-Pope: One torque wrench, TW-4, was marked as defective, but did not have a Reject Tag as required by Section 5.15 of Powers-Azco Pope Procedure FP-11 Calibration and Control of

?!casuring and Test Equipment-(?!STE).

%ncompiiance (454/82-05-lla; 455/82-04-lla 10 CFR 50, AppendixB,CriterionVstates,f Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomp-lished in accordance with these instructions, procedures,-

or drawings."

The failure of Hatfield Electric Company to follow its procedure #24, with regard to tagging torque wrenches, is contrary to the above and is an item of noncompliance.

The fai{ure of Powers-Azco-Pope to follow its procedure No. FP-il, with regard to tagging torque wrenches, is contrary 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.

28 r,

~

Purchasing, Receiving and Storage The inspectors reviewed the process used to obtain safety related material starting with a material request gen-erated by a contractor and culminating with storage in a warehouse. The inspectors noted no discrepancies in the requesting, purchasing and receiving portions of the project, but during tours of warehouse areas the following items were noted:

. in Warehouse No. 1, safety-related equipment was stored on shelves that also contained lumber, boxes of paper, scraps of rubbish and food in a housekeeping atmosphere that did not meet the requirements of Section 6.2 of ANSI N45.2.2.

. In Warehouse No. 5, a pallet of bags containing charcoal type compound was stored above safety related valves. One of the bags had broken and the material had spilled onto the valves, shelving and floor, and the housekeeping was not in accord-ance with Section 6.2 of ANSI N45.2.2.

Noncompliance (454/82-05-11b; 455/82-04-llb) 10 CFR 50, Appendix B, Criterion V states, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomp-lished in accordance with .these instructions, procedures, or drawirgs."

The conditions maintained by the licensee in Warehouses Nc 1 and No. 5 were contrary to Quality Procedure 13-1 and to the requirerents of ANSI N45.2.2-1972, and are an item of noncompliance.

The licensee has indicated that action has been taken to correct the warehouse conditions. This item will be examined during a future inspection.

In Warehouse No. 4, Powers-Azco-Pope is storing material that is tagged Rejected next to Accept and Hold material and is not segregated as re-quired by Section 5.6 of Powers-Azco-Pope Pro-cedure No. FP-3, Material Receiving Inspection Control.

Powers-Azco-Pope is attaching a red tag that says

" Safety-Related" to material that has also been tagged with PAP's Accept Tag. The red tag is not referenced in any PAP or CECO procedure.

29 1

Ncncompliance (454/82-05-llc; 454/82-04-11c) 10 CFR 50, Appendix B, Criterion V states, " Activities affecting quality shall be prescribed by documented in-structions, procedures, or drawings, of a type appro-priate t~ the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

The failure of Powers-Azco-Pope'to store rejected material in accordance with their procedure No. FP-3 is an item of noncompliance.

The licensee has indicated that this condition has been corrected. This item will be examined during a future inspection.

(11) Quality __ Assurance Staffing (a) Objective The objective of this assessment was to determine if the Quality Assurance Organizations of the licensee and contractors are adequately staffed.

(b) Discussion The inspectors interviewed personnel involved in the management of the licensee's and selected contractor's Quality Assurance Organizations; and approximately 14 percent of the Quality Control inspectors employed by the contractors. Based on the interviews and a review ot e.cheduled and completed audits and surveillance the inspect ors were able to conclude that the Quality As.surance Organizations were supplied with sufficiunt manpower. The auditors of the selected organizations were found to be adequately qualified. Qualifications of Quality Control inspectors are discussed in detail in the "QC Inspector Effectiveness" section of this report.

The inspectors do not believe that the Quality Control Supervisor for Powers-Azco-Pope was qualified to be a Level 11 Supervisor on the day she was appointed to the position, 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 30

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 of concern.

( 12.; Tr end An.ilys is Program (a) Old ect ive The objective of this assessment was to determine if the licensee has an effective trend analysis program.

(b) Discussion The inspectors reviewed the trend analysis reports of the licensee and Hatfield Electric Company. Licensee trending of NCR's is discussed in detail in section c.,

Corrective Action Systems. The licensee publishes an annual Trend Analysis Report which is a summary of NCR's by problem area for each contractor during the previous year, and the Corrective Action System is scheduled to be audited semi-annually.

(13) Compliance History (a) Objective The objectives of this assessment were to review the licensee's compliance history and the effectiveness ;4 of the associated corrective action.

(b) Dis _cussien The inspectors reviewed the licensee's history of ncncompliances, unresolved items, 10 CFR 50.55(e) heports, NCR's. IE Bulletins. IE Circulars. and IE Information Notices and reviewed the systems used to assign responsibility and to track the resolution of the problem. A review of all 10 CFR 50.55(e) reports and 30*. of the noncompliances showed that the corrective action was appropriate, with the cause identified and action taken to prevent recurrence. NCR's and their resolution are discussed in detail in section c.,

Corrective Action Systems.

I'scept as ncted, within the areas inspected, no items of non-ccmpliance or deviations were identified.

31

3-~

(~)

Prepared By: R. S. Love

c. Corrective Action Systems (1) Objective The objective of this assessment was to determine if:

(a) corrective action procedures are adequate.

(b) responsibilities have been adequately def f nca ans! that the af fected personnel have been trained and underst and the procedures.

(c) procedures are being effectively Impicmented. Tais includes the areas of tracking and closecut, treading of nonconformances , and upper einagenent 's f rvol .mmr nt .

f (2) Discussion (a) Commonwealth Edison Company (CECO)

1. Procedure Review <

A review of CECO Quality Procedures QP No. 15-1, i Revision 5, dated January 20, 1961, and QP Na. 16-1,

Revision 5, dated December 29, 1980, indic~ates that

, they appear to be adequate as relating to Corrective Action. -

i

Adverse trends and probler areas are brought to the attention of the Vice President (Nuclear Operations),

Manager of Projects, Project Manager and Manager cf i Quality Assurance.

2. saview of NCR Log l

The inspector reviewed CECc's Nonconformanca Report (NCR) log for the years 1979, 1983, and 1981. It was observed that for the year 1981, 101 NCRs were prepared ar.d Hold Tags were applied in 9n instances.

In the 5 instances where Hold Tags were not applied, the item was controlled by a Subcontractors tag or the NCR 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 item.

l 32

b. F-488, dated March 27, 1980. This NCR was sent to Project Construction Department (PCD) on May 15, 2980, for implenentation of the disposition.

c F-526, dated June 27, 1980. This NCR is still at Station Nuclear Engineering Depart-ment (SNED) undergoing evaluation.

d F-539 dated July 22, 1980. This NCR is still at SNED undergoing evaluation, but, l' rom infer-mation received by the NRC inspector, the subject cables have been termitated and energir.< d ! ased on a " Work can Proceed" notation on the NCF.

e. F-544, dated August 8, 1980. This NCR is : ill at SNED undergoing evaluation.

L F-546, dated August 11, 1980. There is .m open 50.55(c) report on this item.

g. F-563, dated October 22, 1980. This NLI w .

sent to PCD on August-27, 1961, for inple9 < nt a-tion of the disposition.

h F-565, dated November 5, 1980. Thia NLF i-still at SNED undergoing -evaluat mn.

i. F-575, dated November 26, 1960. This NCR was sent to PCD on January 26, 1961, for implementation of the disposition.

J. F-577, dated December 8, 1980. This NCE was sent to PCD on February 13, 1981, for implementation of the disposition.

k. F-582, dated December 12, 1980. This NCR (',

was sent to PCD on July 14, 1981, for in ple-mentation of the disposition.

Open item (454/82-05-12: 455/82-04-12)

The NRC is concerned about NCRs that rem 11n open for an extended period of time in that as ti.e fuel-load date approaches, there may be a tendency to accept items without proper engineering evalua-tion, including back-up data, or to accept items that should be reworked or repaired. Pendirg review of the action taken to close the NCRs list ed above, this is an open item.

33

, - - - u-.n,J 4 s F- - -&a - -#,- a LA +- - - -- L-b Review of Voided NCRs The inspector selected six voided NCRs for review.

i The subject procedures do not address voiding NCRr, '

but this is an accepted practice in the industry, when the NCR is voided for just cause.

a NCR F-597 was missing from the QA Records Vault. The NCR log indicated that the NCR was prepared on January 27, 1981 to docueent that Pump Motor OCC01P terminations were leaking. The log indicates this NCR was voided on April 13, 1981.

b. NCR F-600 was missing from the QA Records Vault. The NCR log indicated that t he NrE was prepared on February 6, 1981 to document some damaged cables. The log indicates this NCR was voided on April 3, 1981.

c. NCR F-634, dated March 23, IJ81, war, prepared to document a minimum bend radius viointten on cable IRH119 and to poir.t out that the cause of the bend radius violation was that the weight of the cable pulled the Inop out of cable tray. ECN 1992 was issued to add a device to prevent cable slippage. The NCR was voided on July 24, 19P1, without an evaluation of the subject cable. Thu licensee had an inspection / evaluation performed on the cable on April 7, 1982. Cable was acceptable.

i d. NCR F-645, dated May 7, 1961, was prepared to document that Westinghouse furnished watt-i meters installed on various panels supplied by Systems Control did not meet the 1*. toler-ance requirements. The NCR was voided on June 3, 1981. Systemr, Control letter to Commonwealth Edison Company, dated Augur.t 19,

( 1981, stated in part, "The wattmeters will be returned to Westinghouse for repair at their expense."

i L,-

e. NCR F-650, dated May 18, 1981, was prepared

. to document certain nonconforming hangers.

3 This NCR was voided on June 3, 1981, because it was being tracked on Hat field NCE #298.

f NCR F-682, dated October 26, 1981, was pre -

pared to document that concrete had been placed next to a pipe, resulting in a weld on the pipe becoming unaccessible for in.pm.-

i i

34

l

. c2 I

i tion under ASME Section XI. ECN 2336, dated December 8, 1981, was issued to enlarge th" opening around the pipe so the weld woul'i 50 accessible for inspection. The N2R was voiced on December 16, 1981, because the ECN re olved

the problem.

, N0'lCOEP3 MHSej @53/82-05-l'3a_; 455/82-0;-13a)

! The items listed in paragraph c.. d, and f., an se ,

are examples of improperly voided nonconforman -

j For item c, the issuance of the ECN 1992 was ,

good corrective action to prevent recurtonce b.;t

, did not resolve the bend radius violation. F.: '

item d a the return of the instruments to Vesting-l house for repair was a good resolution to tFe problem, not reasoning for voiding. Again, the issuance of the ECN 2336 was satisfactory resolution

, to the problem identified in item f, not a reason

, to void the NCR. Improper voiding of the NCRs is

!' an item of noncompliance with Criterion XV of 10-CFR 50, Appendix B. t1  ;

5. Review of Closed NCRs On April 1, 1982, the Region III inspector reviawed .

I the following NCRs for proper closure and for cor-t rective action to prevent recurrence:

F-562, dated October.14, 1980, closed January 6, 1982 F-627, dated March 24, 1981, closed January 6, 1982 F-635, dated March 24, 1981, closed June 22, 1981

, F-656, dated June 12, 1981, closed July 21, 1951 i F-673, dated August 17, 1931, closed January 19, 1982 F-687, dated January 8, 1932, closed February 16, 1982 F-683, dated October 2, 1981, closed Febru'ary :1,-1982

6. Review of Trend Analysis l On April 1, 1982, the Region III inspector reviewed the trend analysis of NCRs prepared by-CECO. This

} trend analysis is prepared by the Projects Engineer-ing Department (off-site). Reports dated Jcnu:ry 8, 1981, March 19, 1981, September 17, 1981, October 21, 1981, November. 12, 1981, Dec c or J7, 1981, i

January 12, 1982, Jar.uarv 1, iB2, and February 17,

, 1982'were reviewed dur tt ai. .nspection. All of the aforementioned rel'A e >> hw notation, "No f trends are evident" or 'No trer.os could be identified."

CECO QA (on site) does perform a trend analysis on

, contractor's nonconformances. On the trend analysis

.. reviewed, they agreed with the analysis being per-formed by the individual contactors.

S t 35 4

.-s_--,- , _ - ._ _ _ _ , . - . - - , ---..-.,s. w-r-n.-- . - - , - . ~ _ t

- , _ , e - -

+

7_ . Interviews with, Personnel Interviews with CECO personnel indicate that thef appeared to be knowledgeable in their own procedures on Corrective Action as well as their contractor 's procedures.

(b) Blount Brothers Corporation (Blount)

1. Procedure Review Blount utilizes a Deviation Report. (DR) System l Versus an NRC system. If a DR requires CECO Project Engineering approval, Ceco transr.rit;c:s the information from Blount's DR onto a CECO N:3 which is then forwarded to Project Engismerine.

for approval.

A review of Blount's procedure number 4, inspc tion Nonconformances and Corrective Action, I,evisi.m 6, Issue 9, dated February 12, 1981, indicat.s ti.at it appears to be adequ.1te as relating to cornm tion action, i 2. Review of NCRs l The inspector selected several DRs from the DR

log for a detailed review for proper closure and I corrective action to prevent recurrence. FollowingE, is a status of these DRs

a. Q3-485, dated July 7, 1980. Closed October 14, 1980.

b. Q3-508, dated November 22, 1980. Closed January 22, 1981.

c. Q3-505, dated December 1, 1980. Closed February 23, 1981.

d. Q3-494, dated August 25, 1980. Closed June 2, 1981.

e. Q3-545, dated October 19, 1981. As of April 2, 1982, this DR was at Ceco for final approval I for closure.

On all DRs reviewed, for years 1980, 1981, and 1982, the action to resolve the nonconformaace at.d the' steps taken to prevent recurrence appeared to be adequate, 36.

i 1

4 0 u

3. Review of Trend Analvsis Per Blount's procedure, trend analysis are docu-mented annually but a running count of DRs is made in each deviation area which results in n continuous trend analysis. The trends noted by the inspector had been documented on Blount's trend analysis report. These reports appear to be given wide distribution and includes a copy to CECO.

4: Interviews with Personnel Interviews with Blount personnel indicate that the QA Manager was relatively ncw on the prcjtct I. but appeared to have an adequate knowledge of the procedures. The inspector was inpres sed by the knowledge displayed by the QC Inspector n>

pertaining to the DRs reviewed and the correct ive action system in general.

I (c) Hunter Corporation (llunter) ,

1. Procedure Reviews J j A review of Hunters Site Implementation frocedures y Number 11.101, Nonconformance Processing, Revis:en 4, dated April 28, 1981, indicates that it appears j to be adequate as relating to corrective actions.

2. Review of NCRs The inspector made a general resiew of approximately 30 NRs and a detailed review of 10 NRs for proper closure and for corrective acticn to prevent recurr-ence. Tollowing is a status of the NCRs that were reviewed in detail:

a. NR-099, dated May 5,1380. Closed Septetber 16, 1980, b; NR-132, dated July 22, 1980. This NR was pro-perly voided on August 4, 1980.

c. NR-119, dated July 15. 1980. Closed on December 15, 1980.

d. NR-193, dated January 28, 1981. Closed cr.

March 18, 1981.

e. "NR-263, dated September 17, 1981. Closed nr  !

October 14, 1981.

f_ . NR-151, dated August 4, 1980. Closed on Tebruary 16 1981.

g. 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.

l J

37 I

A

-- v-

1. Nk-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 nonconformance (NR)1og for the years 1980, 1981 and 1982. It was observed that with the way the NR log was prepared, a trend would be observed. The inspector sele.ted two attributes (unqualified welders and hold points ,

bypassed) and performed a trend analysis for the years 1980 and 1981. A review of 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.

, Through training, unqualified weld NRs dropped from 11 in 1980 to 2 in 1981 and bypassing of hold points dropped from 23 in 1980 to 11 in 1981. Hunter recognizes that they still have problems with hold points.

L Interviews with Personnel Interviews with !!unter personnel indicate that they appeared to have a good working knowledge of their system and procedures. Their system and applicable pretedures appear to be adequate (d) Powers-Anco-Pope (PAP}

l_ Procedure Review l A review of PAP Field Operating Procedure Number QC-4, Nonconformance Control, Revision 7, dated September 30, 1981 and PAP Quality Assurance Manual, Section B-8, Nonconforming Material and Parts, Revision 1, dated October 22, 1981, indicates l that they appear to be adequate as relating to i

Corrective Action.

O

2. Review of NCRs The 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 detail:

38

a. NCR 14, dated July 25, 1980. Closed August 1, 1980

b. NCR 19, dated September 18, 1980. NCR was un-acceptable, with the note - see NCR 20.

c. NCR 20, dated September 30, 1980. Closed October 1, 1980.

d. NCR 23, dated September 21, 1980. Closed June 24, 1981.

f. NCR 44, dated April 3, 1981. Closed April 24, 1981. -

g. NCR 39, dated February 27, 1981. Closed March 4, 1982.

1.

3 NCR 55, dated June 1, 1981. Closed August 13, 1981.

i. NCR 71, dated February.13, 1981. Closed November 16, 1981.

J. NCR 73, dated July 15, 1981. Closed July 24, 1931.

k. NCR 81, dated July. 31, 1981. Closed November 9, 1981. Re-instruction was required as part of corrective action.

1.g, NCR 90, dated September 10, 1981. Closed January 6, 1982.

m. NCR 117, dated November 20, 1981. Closed December 28, 1981.

Noncomp1_fance (454/82-05-11d; 455/82-04-11d)

Of the 13 Powers-Azco-Pope NCRs reviewed in detail, 12 of the NCRs did not contain any corrective action to prevent recurrence which is in violation of PAP's Quality Assurance Manual, Section B-8, Revision 1, dated October 7, 1981, Paragraph 13-8.8.2. The li-censee was informed that this was an item of non-compliance with Criterion V of 10 CFR 50, Appendix B. .

(

ls 3. Review of CARS and Trend Analysis Of the 11 CARS generated by PAP as a result of their trend analysis, the corrective action appeared to be adequate.

i. Interviews with Personnel Interviews with PAP personnel indicate that they i appeared knowledgeable in their system and procedures.

(e) llatfield Electric Company (HECo)

1. Procedure Review The inspector reviewed !!ECo Procedure #6, Reporting of Damaged or Nonconforming Material or Equipment, 39

Revision 6, dated January 15, 1982, and Section XVI, Corrective Action, Revision 5, of the QA Manual.

During review the following observation was made.

Noncompliance (454/82-05-09b; 455/82-04-09b)

The only reference to corrective action to prevent recurrence in the abova mentioned procedures'is in Section XVI, Paragraph 2.4, of the QA Manual. This paragraph discusses corrective action for adverse audit findings. The NCR form in use at the Byron Station, as contained in procedure 6, has a section titled " Action to Prevent Recurrence" but there is no directions in the body of the procedure for this section.

Failure to assure that applicable regulatory require-ments are correctly translated into procedures and instructions is an item of noncompliance with Criter-ion V of 10 CFR 50, Appendix B.

2,, Review of NCRs The inspector reviewed approximately 180 NCRs for proper closure and for corrective action to prevent recurrence. The NCR log in use when most of the NCRs were prepared did not provide a description of the nonconformance, resulting in a larger number of NCRs reviewed. The following observations were made.

a. SCRs 98, 99, and 100 were prepared to docu-ment a violation of concrete expansion anchor (CEA) edge distance. The NCRs were voided on February 25, 1980, because an FCR was or will be issued to accept the CEAs as installed.

One FCR (2500) was not issued until July 16, 1980. By voiding the NCRs, they were removed from the trending system. After this was 9 pointed out by the NRC, the contractor pre-pared NCR 432, dated April 9, 1982, to docu-ment the items originally contained in NCRs 98, 99, and 100.

b. NCR 168, dated March 2, 1981, documented that a cable was deformed at routing point 1899B.

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.

40

-r

c. NCR 154, dated February 24, 1981, documeits that cables IFW441, IFW482, and 1DC198 were damaged and the disposition was to replace the cables. Review of records indicate that cable IDC197 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 IDC198 indicated that IDC197 had been pulled and scrapped on June 4, 1981, and that IDC198 was initially pulled on July 24, 1981. On April 6, 1982, the HECo QA Manager corrected the subject NCR and the attached documentation.

d. NCR 107, dated March 21, 1980. Closed November 21, 1980.

e. NCR 97, dated February 20, 1980. Closed August 21, 1981.

f. NCR 152, dated Febre'ry 23, 1981. Closed June 24, 1981.

g. NCR 164, dated March 2, 1981. Closed August 15, 1981.

h. NCR 160, dated February 16, 1981. Closed September 3, 1981.

i. NCR103,datedNarch6,1980. Closed January 8, 1981.

1 NCR 184, dated March 4, 1981. Closed June 8, 1981.

k. NCR 177, dated March 4, 1981. Closed March 23, 1981.

The inspector reviewed 42 NCRs generated between September 15, 1981 and February 15, 1982. The following is a status of the disposition of the subject NCRs:

23 - Use-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 41

r O

1 - Closed - Being tracked by CECO NCR

_1_ - Clean the item 42 Noncqmplaince (454/d2-05-13b; 455/82-04-13b The licensee was informed that items a and b above are additional examples where NCRs were is. properly closed / voided and is an item of non-compliance with Criterion XV of 10 CFR 50, Appendix B. -

3. U. view of Trend Analysis A review of Hatfields trend analysis for 1981 and 1982 indicates that it was adequate.

4. Interviews with Personnel Interviews with IIECo personnel indicate that they appeared knowledgeable in their procedures and system.

Except as noted, within the areas inspected, no items of noncompliance or deviations were identified.

~s 42

i 1

) Prepared by: H. M. Wescott ~

l

d. D_es_ign Chanr.c Control (1) Object ives The objectives of this assessment were to ascertain that, site design change interfaces are clearly defined and im-plemented, design change control is , adequate, personnel ut.derstand and use appropriate procedures, and that the piecedures are being implemented to assure the timely re vising and distribution of drawings.

(2) ljiscussion (a) Review of QA Manuals and Procedures The inspector examined QA Manuals and Implementing Procedures as follows:

1. Nuclear Power Services, Section No. 3, Revision 1, dated December 30, 1980, " Design Control".

2. Powers-Azco-Pope QA Manual, Section B.1, Revision 1,g; lated October 7, 1981, " Design and Document Control".

3. Hunter Corporation QA Manual, Section 2, Revision 5, dated August 1, 1981, " Drawing and Specification Control".

4. CECO 0A Manual, Quality Requirement, QR No. 30, Revisions 1, 3,-13, and 18, dated December 29, 1980, December 29, 1980, September 9, 1980, and December 29, 1980 respectively, " Design Control".

5. CECO QA Manual, Quality Procedure, QP No. 3-2 -

thru Revision 13, dated November 12, 1981, " Design Charige Control".

[. Johr son Controls. Inc., QA Manual. Section 4 Revision 0, dated June 29, 1978, " Design Control".

7. Byron Site Instruction No. 20, Revision 8, dated December 17, 1981, " Instruction for Site Design Document Receipt, Distribution and Control".

p. Byren Site Instruction No. 21, Revision 0, dated July 13, 1978, "ECN Routing".

' Westinghouse Policy / Procedure, WRD-OPR 3.0, J.

Revision 2, dated March 20, 1981, " Design Control".

43

10. Westinghouse WRD-OPR 3.1 " Reactor Coolant System Design Definition (Power Capability Working Group)"

Revision 3,-dated tiarch 22, 1981.

11. Westinghouse Instruction / Guidance SMD 1.4, Revision

'4, dated January 18, 1982, " Byron Unit 1 Engineering Change Notice".

12. Westinghouse Instruction / Guidance SMD 1.5, Revision 0, dated October 31, 1980, Byron Unit "Fi eld Change Requests".

13. AZCO Field Procedure FP-9, Revision 6, dated December 21, 1981, " Design Change Control".

(b) Review of Audits of Site Contractors The inspector reviewed CECO's eudits of site contractors concerning design change control as follows:

1 2 Sargent and Lundy Nos. 6-81-301, 6-81-314, 6-81-339 and 6-28-07.

2. Westinghouse SAMU No. 6-81-317.

3. Powers-Azco-Pope Nos. 6-81-326, 6-80-247 and 6-82-10. -

Nuclear Installation Service Company Nos. 6-81-311 4 .,

and 6-80-281.

52 Hatfield Electric Company Nos. 6-80-254 and 6-81-331.

6 Hunter Corporation Nos. 6-82-09 and 6-81-350.

~

7. Blount Brothers Corporation Nos. 6-80-248, 6-81-294 and 6-82-02.

82 Johnson Control, Inc. No. 6-80-250.

9.  !!unter Corporat ion, llat field Elect ric Company, heliable Sheet Metal Vorks. Inc., Powers-Azco-Pope i Services, Inc., Blount Brothers Corporation, Westinghouse SAMU, Pittsburgh Testing Laboratory,

and Nuclear Installation Services Company No. 3/8-10/82.

I (c) Review of Design _Snecifications i

lhe Inspector reviewed design specifications as follows:

D i

i 44

., , .e n,-- .- , - a ,, -m w-- w -

7

1. Certified piping design specification for the

" Outdoor Essential Water System" dated February 19, 1982.

2. Certified piping design specification for the 't

" Indoor Essential Water System" dated December 14, 1981.

3. Cert ified design specification for the " Reactor Vessel" dated May 15, 1977.

4. Design Criteria for Category 1 Cable Tray, Cable Tray Supports, Bus Duct Supports, HVAC Duct Supports, Conduit and Conduit Supports, DC-51-03 BY/BR.

It is noted that item 2. above did not have the Pro-fessional Engineer's Seal for Certification. Sargent and Lundy further researched ten piping design specifi-

' cations and found three that did not have the required seal. These were to be revised to include the seal by April 23, 1982.

(d) Review of Control of Field Change Requests (FCR's) and Eng_ineering Change Notices (ECN's)

The inspector randomly selected fifteen (15) FCR's and three (3) ECN's at Powers-Azco-Pope, seven (7) FCR's at liatfield Electric Company, and three (3) ECN's at Westinghouse SAMU. They were verified to be under CECO control. Additionally five (5) traveller packages for

! in process welding were verified to have the currect drawing revisions in place.

The following are the totals of FCR's and ECN's issued as of this inspection:

i Electricel FCR's 4,492 Mechanical FCR's 13,702 l Structural FCR-s 101 I

• hixed FCR's 4,999 ECS's 2,454 TOTAL 25,746 l *Mi).ed FCR's contain all disciplines prior to separation

! by discipline.

! (e) Review Site Design Change Interface The inspector reviewed the following:

i 45

1. Interface Control Agreement, Vestinghouse Piping and Structural Evaluation Program for the Byron Station Unit 1, dated October 13, 1980. Paragraph 4.3 states that, "The Byron Project Engineering Organization, as the Owner, has overall responsi-bility for the activities described in this agreement."

2. Flow Chart for routing CECO Field Change Request, Byron Site Instruction No. 10, Revision 5, dated

, March 25, 1982.

(f) Personnel Interviewed The inspector interviewed personnel from CECO, Westing-house, Powers-Azco-Pope, Sargent & Lundy, Hatfield Electric Company, and llunter Corporation.

i Within the areas inspected no items of noncompliance or deviations were identified. ,

i 4

_3 1

1 4

46

Pr.? pared By: E.-H. Nightingale 1

1 e, . 1(erial Traceability of Installed Structures and Components 1  ;

!. (1) Obj ect ive The objectivQ of this assessment was to determine that material traceability was maintained from procurement through installation for structural beams, small bore piping and welding materials.

(2) Discussion The following contractors were involved and their areas of responsability are as indicated:

Hatfield Electric Company: Cable Trays Hunter Corporation: _Small Bore Pipe Systems Powers-Asco-Pope: Small Bore Piping Systems Blount Brother Corporation: Structural (a) llatfield Electric Company i

1. Review of Procedures The following site procedures were reviewed:

l

1. 5, Class I Materials and Equipment, Receiving and Inspection

1. 13AA, Class I Shielded Metal Arc Field. Welding (S .!!. A. P.W. )

1. 13AB, Class I S.M.A.F.W. (Procedure Qualifica-tion)

[ #13AC, Qualification of Welders l

l #13AD. Arc Welding Electrode Control

2. Review of Records The documents reviewed for material traceability were as follows:

~

. Weld Material Request

. Material Certification

. Weld Rod Request

. Weld Data Sheet j . Weld Material Issue Tag t

i 47 l

{

~

r c

3. Review of Welder Qualification The review of welder qualification records consisted of reviewing the original qualification records as well as the supportive documents pertaining to ,

their "up-date" qualification records. Hatfield Electric Company welding efforts are to AWS Code which requires six (6) month re qualification periods.

t The following welders had their certification and qualification records reviewed:

I Name Welder ID#

N. Larrabee WW C. W. Werner W J. A. Dickson MM Greene ' CG R. S. Glenny CF i C. Stagg CS W. McVay BM i

D. Gavin DG

, T. Whitcomb TV F. Plegge FP These ten (10) welders are representatives of the sixty (60) welders qualified by Hatfield and are

! presently on site.

1 4

4. Review of Weld Material Control i

The review of weld material control procedures and direct observation of in process activities indicate that t.ufficient efforts are being im-plemented to assure material traceability and j control.

, Open__ Item (454/82-05-14; 455/82-04-14) j 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.m.".

The licensee has provided information to indicate that Hatfield form HP-13AD-1 has been revised to include provisions for the actual rod issue and return times. This item will be reviewed during I

a future inspection.

(b) Hunterharporation l 1. Review of Procedures i

48 i

i i

O 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, Veld Filler Material Control 5.201, _

Velding Procedure Qualification Control 5.301, Velding Qualification 5.501, Veld Material Issuance 6.002, Visual Examination and Verification 6.501, NDE

2. Review of Records The inspector selected three (3) safety related small bore piping systems for review of material traceability. The review of the data packages consisted of documentation from the purchase order to installation of the item. The systems involved were as follows:

O

. Safety Injection (3)

Reactor Coolant (2)

Chemical Volume (4)

The documents reviewed were as follows:

. Material / Services Request

. Material Receiving Report

. Receipt Inspection Checklist

. QA Documentation Requirements List

. Material List

. Requisition

. Shipping Order / Packing Slip Material Certificate NDE Request

. Process Sheet

. Veld Record Material List Material Certification

. Weld Material Issue Report The inspector reviewed data packages for the following small bore piping systems:

SYSTf.M SPOOL PC ITEM HT # MATERIAL REPORT 10)e-S-CV-001 2 2" sch/160 462460 MSR 4967 101c-5-RC-001 1 2" sch/160 462460 MSR 4967 Ceco-F-RC-001 105 3/4" sch/160 483245 MRR 9575 1016-F-SI-001 5 2" sch/160 462460 MSR 4967 1016-S-SI-001 16-5 2" sch/160 462460 MSR 4967 49

~

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

SWTEM SPOOL PC ITEM HT # MATERI AL REPORT 1018-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 MSR 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 made to include valves and fittings. Data packages for the following items were reviewed:

,m NAME I,0 CATION SYSTEM SPOOL MRR Globe Velve IRCS039B S-RC-001-51 2 10084 M.O.V. IRC3037B S-RC-001-51 2 10062 M.O.V. 1-SI-8871 S-SI-001 33 10144 NA'fE TYPE HT # SPOOL MRR CI'I.G l it t ing 2.0" 6000# S.S.-S.W. TL 2 4968 CI'U; rit t ing 3/4" 6000# S.S.-S.W. EGJ 2 5338

3. Review of Welder Qualification The review of welder qualification records consisted of reviewing the original qualification record as well as the supportive documents pertaining to their "up-date" qualification record. Hunter Corporation welding efforts are conducted to the ASME Code which requires three (3) month re qualification periods.

Hunter carporation routinely re-certifies their welders in two (2) month periods to preclude any loss of certifications due to vacations, illness, etc.

d The following welders had their certification and qualification records reviewed:

i NAME WELDER ID #

I l

l R. Sturm D40 B. Strom B17 D. Colby E52

, R. Decker '

A38 l D. L'pstone F19 E. Paker E56 I B. Purns E82 l R. Bilyeu B91 i

l i

50 i

NAME VELDER ID #

A. Arnold E48 V. Eurdene C19 D. Radke A12 I. Anderson F3 These twelve (12) welders are representative of the 237 welders qualified.by Hunter Corporation and are presently on site.

4; Review of Veld Material Control The review of weld material control procedures and direct observation of in process activities indicate that sufficient efforts are being implemented to assure material traceability and control.

The documents reviewed for material traceability are as follows:

. Veld Material Stores Requisition

. Purchase Requisition

. Materials / Services Request

. Material Receiving Report

. Receipt and Inspection Checklist

. Material Certificate (c) Powers-Azco-Pope

1. Review of Procedures The following procedures were reviewed:

. QC-4, Nonconformance Control

. TP-2, Control of Procurement and Requisitioning of Material and Services

. FP-3, Material Receiving, Inspection Control

. TP-5, Weld Filler Material Control

. FP-6, Material Handling FP-7. Transfer Package and Veld Record Control VE-2, Welders Performance Qualification and Control

2. Review of Records The inspector selected three (3) safety related small bore piping systems for material traceability review. The review of the data packages consisted of documentation from the purchase order to in-sta11ation of the item involved. The systems selected were as follows:

m 51

. Feedwater

. Containment Spray

. Reactor Coolant The documents involved for review were as follows:

. Weld Filler Material Requisition

_ Receiving Inspection Check List Final As-Built Isometric (Supplement Weld and Inspection Record)

. Material Certification

. Weld Rod Issue Tag

. P.O. (CECO Responsibility)

. NDE Records A study of the data packages, for the systems selected, consisted of the following items:

SYSTEM PIPE SIZE HT # REC. 6 INSP. ISO #

Report #

RX Coolant 0.50" 462,444 MRR# 7074 1FIS-418B Fee.1 Water 0.50" M81,577 RIR# 040 1LT-542 Feed Water 0.50" D85,772 RIR# 040 ILT-542

.' Feed Water 0.50" E89,871 RIR# 040 ILT-542 Containment 0.50" 744-783 MRR# 7074 1FT-CS011

) Spray Total footage of piping involved consisted of 27,900'.

The suppliers of weld material for the Byron facility-is Hunter Corporation. The pipe materials are supplied to the small bore piping contractors by CECO. Therefore, purchase orders are originated fre.n these two (2) sources. This system of pur-chasing in large quantities by one contractor /

l licensee enhances material traceability.

An expanded study of small bore-piping was made to include valves and fittings. Data packages for the following items were reviewed:

FIELD REC 6 INSP.

ITEM HT# WELD # REPORT # ISO #

Coupling EGJ 41 057 IPT-RC009 90 Elbow OZ 52 131 IPT-403 i

Valve lhV048 N/A 20049 11J-461 S/N N11591 Valve lhCO25E N/A 230 IFT-415 S/N N11526 52

3. Review of Welder Qualification r The review of welder qualification records con-sisted of reviewing the original qualification record as well as the supportive documents per-taining to their "up date" qualificiation record.

PAP welding ef forts are conducted to the ASME '

Code which requires three (3) month re-qualifica-t io: periods. ,

The following welders had their certification and qualification records reviewed:

Namo Welder ID#

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. Mcyers DE W. Meyers DG These ten (10) welders are representative of the 46 welders qualified by PAP and are presently on site. .

4 Review of Weld Material Control The review of weld material control procedures and direct observation of in process _ activities indicate that sufficient efforts are being impli-mented to assure material traceability and control.

The documents reviewed for material traceability are as follows:

. Weld Filler Material Requisition

. Receiving Inspection Check List l . Material Certification

. Weld Rod. issue Tag

. Weld and Inspection Record (d) Blount Brothers Corporation i

L Review of Procedures The following procedures were reviewed:

d 53

. QC 3385 #1, Document Control

. QC 828 #2, Procurement Control

. QC 3012 #4, Inspection (Nonconformance and Corrective Action)

. QC 3262 #7, Calibration of Tools, G@uges and Instruments Concrete)

. QC 835 #10, Receiving, Storage and Handling

. QC 3333 #11, Welding - (AWS D1.1) 1974

. QC 845 #21, Structural Steel Erection

. QC 1992 #33, Personnel Qualification and Certification

2. Review of Records The inspector selected nine (9) structural beams for material traceability. Beams selected were-thrie from Unit #1 containment building and three

~

benns from Unit #1 auxiliary building. Three more beams were selected from Unit #2 containment building.

Beams selected were as follows:

Beam I.D. Building Unit # Drawing #

1 A220B2 Containment 2 E-205 A230BB3 Containment 2 E-205 A200BB1 Containment 2' E-205 A132BS Containment 1 E-102 B111BB2 Containment 1 E'-102

B104BB1 Containment 1 E-102 l 333B3 Auxiliary 1 E-201 326G1 Auxiliary 1 E-201 603B1 Auxiliary 1 E-201 1

The inspector reviewed the data packages for the following structural steel for material traceability. l Beam # 326G1 -

Film Roll 3 -

Dr. #326 Index # Heat # S6L Letter Date 440 2R6969 12-28-76 435 J-31694 11-30-76 j l 464 96266 12-28-76 i 474 96723 11-29-76 l 461 63062 11-08-76 l

Mill B8 L511159 02-28-77 Bese is 333B3 -

Film Roll 3 -

Dr. #333

, 54 l

l

Index # ,

Heat # S&L Letter Date 351 K-24080 11-10-76 474 96723 11-19-76 Beam #5104BB1 -

Film Roll 1 -

Dr. #bl04 Index # Heat # S&L Letter Dale 11133 69C076 06-29-77 11127 69C050 07-01-77 90126 66C242 07-01-77 90127 69C167 08-10-77 60123 63729 05-26-77 Beam #A230BB3 -

Film Roll 1 - Dr. #A230 - 80230 Index # Hect # S&L Letter Date 38 70C576 02-07-78 62 K58219 02-06-78 K58377 02-06-78 573 T47512 06-26-78 S-22 87495 06-27-78 Beam itB111BB2 -

Film Roll 1 -

Dr. #B111B Index # Heat._# S&L Letter Date 11113 VY4703 07-01-77 11106 70C266 07-01-77 90126 6bC242 07-01-77 90127 69C167 08-10-77 80123 63729 05-26-77 Beam #A220B2 -

Film Roll 1 -

Dr. #A220 In@ix# Heat # S&L Letter Date B-9 J-51717 12-13-77 S-43 44B489 07-19-78 B-1 A-325 Bolts 09-12-78 B-2 A-325 Bolts 06-09-78 Beam #A132B5 -

Film Roll 1 -

Dr. #A132 Index # Heat # S&L Letter Date 80135 24456 05-26-77 C-80119 k'35079 07-11-77 A-80190 B-34009 08-10-77 55

9 Beam #603B1 -

Film Roll 3 -

Dr. #603 Index # Heat # S&L Letter Date 1407 10005 03-04-77 T' 287 18216 10-12-76 Beam #A240BB1 - Revised to Beam #E144-1 S&L Drawing S-1001, Revision H. , Dated 3-16-78, Note 10. Fabricated by Midcity Architectural tron Company (on-site contractor).

Heat # K62702 and #83833 A-325 Bolts - C6810; 4048

3. Review of Welder Qualifications The review of welder qualification records consisted of reviewing the original qualification record as well as the supportive documents pertaining to their "up-date" qualification records. Blount Brothers Corporation welding efforts are to AWS Code which require six (6) month re qualification periods.

The following welders had their certification and qualification records reviews:

Name Welder ID #

K.fKnaub K-5 R. Long K-4 P. Fadness P-4 R. Sullivan B-4 D. Lower L-4 W. Thompson V-4

K. Flosi W-3 R. Schusler W-18 K. Todo Y-4 D. S. Wielan D-5 The ten (10) welders are representative of the fifteen (15) welders qualified by Blount Brothers Corporation and are presently on site.

4. Review of Weld Material Control The review of weld material control procedures and direct observation of in-process activities indicate that sufficient efforts are being implemented to assure material traceability and control.

I 56

. ;i:p ~ 4 k i .4 hi;,dM;igdif,, _

The documents reviewed for material traceability are as follows:

.  ?!aterial Requisition

. Receiving Inspection Report

.  ?!aterial Certification

. Weld ?!aterial Issue Sheet

. Weld Data Report

~

Within the areas inspected, no items of noncompliance or deviations were identified.

57

,. ~

Prepared Ey: R. S. Love

f. Electrical Cable Installation (1) Objective The objectives of this assessment were to determine if:

. cable installation procedures are in accordance with FSAR commitments and that-they &re adequate for con-trolling cable installation activities.

the cable installation personnel and QC inspectors have been adequately trained in this activity.

safety related cables are routed, separated, and loaded in accordance with procedure requirements.

(2) lli,s cuss ion (a) Review of Electrical Procedures The inspector reviewed the following Hatfield Electrical Company procedures:

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

2. Pr60cdure No. 6. Reporting of Damaged and Noncon-forraing Material or Equipment, Revision 6, dated January 15, 1982. This procedure was reviewed and accepted by Sargent and Lundy on February 11, 1982.

3. Procedure No. 9-A, Class I, Cable Pan Hanger Instal-lation, Revision 11, dated November 20, 1982. This procedure was reviewed and approved by Sargent and Lundy on December 23, 1981.

l

4. Procedure No. 9-B, Class I, Cable Pan Installation, l Revision 9, dated November 20, 1981. This procedure ,

was reviewed and approved by Sargent and Lundy on Decenber 23, 1981.

5. Procedure No. 9-E, Class I, Cable Pan Identification, Revision G, Issue 1, dated January 23, 1981. This procedure was reviewed and approved by Sargent and Lundy on January 26, 1981.

58 1

i t _

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 Item (454/82-05-15; 455/82-04-15)

Procedure No. 9-B, Class 1, 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 Byron /Braidwood FSAR. This is an open item.

Unresolved Item (454/82-05-16; 455/82-04-16)

During review of Procedure 9-E, Class I, Cable Pan Identification, Revision G, Issue 1, dated January 23, 1981, the inspector observed that paragraph 5.3.1 of the subject procedures states in effect that the requirements to apply segregation identification to raceway at a minimum of every 15' does not apply to risers. This is contrary to the requirements stated in paragraph 5.1.2 of IEEE 384-1974. Pending a review of installed riser identification markings for compli-ance to requirements, this item is an unresolved item.

Noncompliance (454/62-05-09c; 455/82-04-09c}

During review of Procedure No. 10, Class , Cable Installation, Revision 14, dated February 8, 1982, the inspector observed that the subject procedure does not address:

a. the requirements to calculate electrical cable sidewall 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 requires that the cable be " pulled back" to a given point in the raceway system and re-routed to a different landing point. What precautions l

are taken to prevent damage to the cable being

" pulled back" and to the cables remaining in the raceway. This would be especially important when the cabic was installed in conduit or duct banks. Another example would be that as a result of an NCR, a cabic had to be removed (Ref.

!!atf ield NCR's 164, 154, 107).

Failure to provide adequate instructions or procedures to accoaplish activities affecting quality in accord-

! ante with Quality Assurance Program provisions is an l

l l

i l 59

n iteni of noncompliance with Criterion V of 10 CFR 50, Appendix B.

(b) Review of Storage _ Facilities - Cable Yard The inspector toured the llatfield Electric Company cable reel yard to verify proper storage and to select several cable reel' numbers for follow-up review of material receiving reports and vendor documentation.

The cable reels were stored on dunnage (plywood),

identified, and separated as to cable type. Electrical cable rr91 numbers 02146-409, 04146-215, 03367-7, and 01115-43 were selected for records review.

(c) Review of Electrical Work Activities

1. During a tour of the power block the inspector observed that the weld heat affected zone inside cable tray 11774J-C2E, located at the 439' eleva-tion of the cable spreading room, had not been touched-up with zinc rich paint in accordance with Hatfield Electric Company Procedure No. 9-B, Class I, Cable Pan Installation, Revision 9, dated ,

November 20, 1981. The licensee took immediate action to have the subject area cleaned and galva-noxed. This was the only area identified where the weld or heat affected zone had not been touched-up.

2. The inspector observed that non-safety related pipe number FP-41-4-10" was installed 3 1/2" from safety related cable tray number 11461J-C2E.

These items are located in the Auxiliary Building between column lines 17 and P at the 426' eleva-tion. Further investigation indicates that the fire protection (FP) 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, Seismic Design Classification.

3. The inspector verified that electrical cable number IVX105 was routed in accordance with the cable pull card, Revision A. The subject cable is a 12c/14, 600V and was pulled from cable reel 12146-201. The cable extends from 1AP32E (MCC 132X5) to IVX02J (Vent System Local Control Panel).

The cable was physically verified in routine points 11461J-C2E, IR369-C2E, 1910F-C2E, IR353-C2E, 11375M-C2E, and verified that the cable entered 7 the conduit to the equipment.

60

The raceway was accepted on January 18, 1982, and cable pulled on January 19, 1982.

4. 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) Review of Procurement Documentation - Class IE Cable The inspector reviewed the procurement documentation relative to 600V and SKV electrical cable. The inspector review'ed the cable specifications, Material and Equip-ment Receiving and Inspection Reports (MRR), and vendor documentation. The following observations were made:

1. The licensee purchased the following electrical cable from Okonite Company to Sargent and Lundy specification F-2823.

a. Cable reel number 02146-409 containted 2500 feet of 2c/14, 600V cable and was received May 11, 1981 on MRR 50217.

w

b. Cable reel number 04146-216 contained 3124 feet of Ac/14, 600V cable and was received April 22, 1980 on MRR 8569.

c. Cable reel number 03356-7 contained 2060 feet of 3c/350 MCM, 600V cable and was received October 4, 1978 on MRR 4187.

The following data was included in the on-site documer.. etion packages for the abcve listed cables:

. Certificate of Compliance

. Certificate of Conformance Certified Test Report Results of k'ater Absorption Test

. Results of Ozone Resistance Test

. Results of High Potential Voltage Test

. Sargent and Lundy letter, dated June 20, 1980, that accepted the results of Flame Tests and Tests for Design Basic Events.

2. The licensee purchased electrical cable, reel number 01115-43 from Okonite Company to Sargent and Lundy specification F2851. This reel contained 1094 feet of Ic/1000 MCM, SKV cable and was received 61 C'

~

I July 11, 1979 on MRR 7032. The following data was included in the on-site documentation package for this cable:

. Certificate of Compliance

. Certificate of Conformance

. Certified Test Report

. Results of k'ater Absorption Test

. Results of Ozone Resistance Test

.O Results of High Potential Voltage Test

. Sargent and Lundy letter, dated June 20, 1980, that accepted the result of Flame Tests and Tests for Design Basic Events.

(c) Review of Class IE 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 from 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 complete pull.

1 Cable IRC223 was pulled on April 9, 1981 from Cable Reel 02166-41. Revision A to the cabic pull card indicates the cable type code as 02166 which is 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 which 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 ite.as of noncompliance or deviations were identified.

62

Prepared liy: H. H.'Wescott

g. In-Process Inspection (1) Obj e ct ives The objective of this assessment was to ascertain that in process inspection procedures are adequate and properly implemented. .

(2) Discussion (a) Review of Procedures The inspector reviewed procedures concerning in-process inspection as follows:

1. Powers-Azco-Pope Quality Control Field Procedure FP-7, Revision 6, dated October 16, 1981, " Traveller Package and Weld Record Control PAP Isometric mad Installation Control".

2.

Pm *s-Azco-Pope QC-6, Revision 6, dated eptember 30, 1981, " Quality Assurance Documen-tation".

3. Itatfield Electric Company Procedure 9-A, Revision 11, dated November 20, 1981, " Class I, Cable Pan

!! anger Installation".

4. llatfield Electric Company Procedure 9-B, Revision -

9, dsted November 20, 1981, " Class I, Cable Pan Installation".

5. liatfield Electric Company Procedure 20. Revision 8, dsted November 20, 1981, " Class I, Exposed Conduit System Installation".

6. Ilunter Corporation, Site Implementation Procedure SIP No. 1.601, Revision 1, dated March 3, 1981,

" Quality Assurance Procedures and Instructions".

7. liunter Corporation, SIP No. 4.201, Revision 4, dated January 19, 1982, " Installation Verification".

(b) Observation of Work 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

m (c) Review of Records The inspector reviewed records as follows:

1. 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-50-C-6"; Number 1608, Part No. 1-CC-50-C-6" rework; Number 1171 and 1178, Line No. 1-D-G-33-CA-3/4".

2. Hunter Corporation Field Order JTP No.'s 5-Pt .00-78, 5-PS-10-77,It0G-72-1, S-NT-100-2-15-A, and OG-61-7.

3. Hatfield Electric Company QA Process Sheet File No. 13.09B.1, Class I, Cable Pan Inspection Checklists (approximately 33 checklists).

4 Hatfield Electric Company Concrete Expansion Anchor File No. 13.25.02, Travellers 1901 thru 1950.

5. Hatfield Electric Company Conduit Inspection Reports, File No. 13.20.01, 766 thru 850.

(d) Personnel Interviewed The inst.ector interviewed two QC inspectors from Hatfield Electric Company.

Noncompliance (454/82-05-17; 455/82-04-17)

The inspector interviewed four welders performing in process safety related welding (two from Hunter Corporation and two from Powers-Azco-Pope). Three of the welders did not have the welding procedure specification (WPS) with the traveller packages.

When the inspector asked where the WPS was, two welders did not appear to know what a WPS was and one stated that he knew the WPS should be in the weld material issue point but stated that he had not seen it.

This item is considered to be in noncompliance with the requirements of 10 CFR 50, Appendix B, Criterion IX.

Except as noted, within the areas inspected, no items of noncenpliance or deviations were identified.

64

m Prepared by: W. Torney

h. QC Inspector Effectiveness (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 of 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, USSRC Generic Letter 81-01; CECO Quality Assurance Program Manual; CECO Response to Generic Letter 81-01 (L. O. DelGeorge to D. G. Eisenhut-August 17, 1981); and Contractor Quality Assurance Manuals.

(2) JIiscussien Individuals selected for interview were chosen at random by the NRC inspector. All contractors utilizing QA/QC personnel to nonitor and accept production activities at the site were selected. The organizations selected, pro-duction function monitored by the inspectors, number of inspectors in the organization, number of inspectors inter-viewed and perceraages are identified in Table 2. Each inspector interviewed was asked a standard set of questions.

The answers provided were summarized and are provided 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-fication records to verify compliance with applicable regulatory requirements, standards and commitments. In verifying the implementation of the approved requirements emphasis was placed on (1) determination of initial cap-ability by suitable evaluation (2) evaluation of perform-ance/ reevaluation (3) written certification in appropriate term (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

e. .indard set of interview questions. Answers to questions 1, 2, 4, 5 nie self evident and do not require further defin.tions, lieweve r , the answers to remaining questions require further clarification and conclusions.

65

Question 3 - relates to the number of inspectors that in-dicated during their answer to Question 2 that they had prior inspection experience. Of the 30 inspectors inter-viewed 47% indicated prior inspection experience; however, only 27% had prior inspection experience in nuclear work related activities.

~ 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. The two inspectors that provided qualified answers indicated the overtime was intense at times based upon fluctuations of production activities. All of the inspectors that answered yes or qualified their answer were asked if the frequent or excessive overtime caused the accuracy of their inspections to be dominished. Without exception, none of the inspectors felt the accuracy of their inspections were af fected.

P 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 inspections promptly were a result of fluctuations in production activities.

Open Iten (454/82-05-18; 455/82-04-18)

Question 9 - indicates that inspectors generally do not feel they have the authority to stop an activity in their centractor's work that is not being properly performed, nor have they been provided written management policy in this area. The inspectors that provided qualified answers indicated that they would inform the area supervisor.

The inspectors were also asked if they felt they could immediately rtop the work activity of another contractor worker who was performing work that was hazardous to safety related equipment. The majority of inspectors indicated they did not have that authority.

The licensee management committed to take actions to re-emphasize to all inspectors their responsibility to stop an activity which does not conform to applicable quality requirements. This item will be examined during a future inspection.

Question 10 - the majority of inspectors interviewed indicated that the training they received was adequate for the work activity they are required to perform. One inspector did no', feel his training was adequate and the remaining inspectors felt that although their training was not the bcst, that if they needed additional guidance or clarification that management would provide the infor-cation inmediately.

66

---

1

Question li - indicates that inspectors do not feel that a lack of inspection personnel is the cause for construction 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-stallation plans and/or procedures. ,

Question 13 - the inspectors that qualified their answer indi-cated that they would have to follow the chain-of-command which could be untimely.

, When asked to discuss their opinion of how their management portrays the relationship of quality to production 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 inspectros (pre-dominately 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 minimum ar.ceptable standards, a few stated the work generally met ninimum standards, and no inspectors felt that the work did not meet minimum acceptable standards.

Noncompliance (454L82-05-19; 455/82-04-19) based on a review of training qualification and certification records of a minimum of ten percent of the QA/QC personnel working for contractors performing safety-related work it is apparent that an effective program does not exist to ensure that a suitable evaluation of initial capabilities is performed, that written certification is provided in an appropriate form, and that qualification criteria is established.

Certain contr. actor QA/QC supervisors and inspectors were not adequately q6/ lified and/or trained to perform safety-related inspection functions. The following examples of apparent non-compliance were identified:

a. Contractor - Reliable Sheet Metal Works, 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 J , _ .

- ~ _,-

b. Contractor - Johnson Controls. Inc.

(1) The certification records reviewed did not contain a determination of initial capability.

n (2) The certification records reviewed did not contain a copy of the individuals high school diploma or veri-fication of prior work history.

(3) The certification records reviewed did not support adequate testing prior to certification. It is noted that testing was accomplished by oral examination consisting of 25 questions to determine the individuals knowledge of 26 procedures. The oral examination noted the individual was weak in ability to work with draw-ings. However, there is no record to indicate addi-tional training was provided or that the individual was subsequently tested and found to be proficient in

, his ability to work with drawings.

c. Contractor - Powers-Asco-Pope (1) The certification records for the QC Supervisor did not provide an adequate determination of initi.a1 capability.

(2) The certification records for the QC Supervisor did not contain a high school diploma, or verification of pre-vious employment.

r (3) The certification records for the QC Supervisor did not contain adequate evaluation and justification for certi-fication to Level I or subsequent certification to Level II Supervisor.

(4) The certification records for three (3) QC inspectors l did not contain a high school diploma.

(5) The certification folder for three (3) QC inspectors did not contain verifications of prior employment.

(6) The certification records for the QC Supervisor and i three (3) QC inspectors contain open book examinations that do not provide an adequate level of knowledge prior to certificatior The records did not contain results of a capability demonstration to support certi-fication.

(7) The certification records for three (3) QC inspectors did not contain adequate esaluation and justification for certification to Level < and subsequent certifica-t ion to Level 11 inspector.

68

r -

d. Contractor - }!unter Corporation (1) The certification records for two (2) of the seven (7)

QC inspector qualifications reviewed did not provide determination of equivalent inspection experience to support the level of certification.

e. Contractor - Ilatfield Electric Company (1) The certification records'for three (3) of the nine (9) inspector qualifications reviewed did not contain a Certification Evaluation Sheet.

(2) The certification record for one (1) of the nine (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 complete evaluation and justification for certification to perform the level of inspection identified.

f. Contractor - Blount Brothers Corporation (1) The certification record for one (1) of the two (2)

QC inspector qualifications reviewed did not indicate the expiration date of certification as a Level I lead cuditor.

g. Contractor - Midway Industrial Contractor, Inc.

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

h. Contractor - Pittsburgh Testing 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 sample review of CECO audits conducted in the area of training qualification and certification for the period 1979-1981 it was determined that a program exists to routinely review the acceptability of QA/QC 9ersonnel.

It was noted that many audit findings were identified and resulted in notable improvements of contractor adherence to ANSI N45.2.6-1978. During the meeting conducted April 9, 19112, CECO management committed to develop an alternate plan for certification of contractor QC inspectors when the recommendations of ANSI N45.2.6.-1978, Section 3.5 are not complied with. Additionally, a commitment was made to require each contractor to verify inspectors education and experience.

69

e

~

TABLE 1 Licensee and On-site Contractors QA/QC Periodic QA/QC Services 4 Cract QA/QC Organ. Review of Supv.

Qrganization Performed k'orke rs Staff Indep. QA Program Pos. Des.

O Commonwealth Licensee N/A 16 Y,es Yes Yes D!ison h!ount brothers Plant 220 5 Yes Yes Yes Structures Lt,asco Services Inservice 10 2 Yes Yes Yes Inspection Hatfield Electric Electrical 555 83 No Yes No Company Installation Hunter Corp. Piping 944 71 Yes Yes Yes Systems Johnson Controls HVAC 47 2 (2) Yes Yes Controls Midway Indust. Field Finish 10 2 Yes Yes Yes VISCO Mechanical 10 2 Yes Yes Yes Erector Yaclear P.S. Mechanical *96 1 Yes Yes Yes Design

'ittsburgh Testing #28 1 Yes Yes Yes fest Lab i

Powers-Azco-Pope Instrumenta- 135 11 No Yes Yes 1

tion P.eliable Sheet HVAC 37 2 Yes Yes Yes Metal t

l Sargent & Lundy A. E. Field *72 0 (1) Yes (1)

Group Writinghouse Mechanical *47 0 (1) Yes (1)

Si ' U Design

? - Testers. * - Engineers (1) - Not reviewed (2) - Unresolved item 70

m 4

TABLE 2 g It3SFECTOR INTERVIEW

SUMMARY

Total Inspectors Organization Function Inspectors Interviewed %

EBASCO Services Inservice Inspection 2 1 50 1:ISCO Erect miscellaneous 2 1 50 mechanical equipnent, final setting and erection of NSSS equipment.

Feliable Sheetectal HVAC 2 1 50 Johnson Controls HVAC Controls 2 1 50 Powers. Azco Pope Instrumentation 11 4 36.36 (FAl')

Ifunter Cor; oration Piping System 71 7 9.86 ilattiold Electrical Installation 83 9 10.84 Bloun. Brothers Plant Structures 5 2 40 Midway Fiald Finish Coating 2 1 50 Pittsburgh Testing Lab Onsite NDT 28 3 10.71 TOTALS 208 30 14.42

e TAELE 3

SUMMARY

OF QUESTIONS ASKED pC/QA INSPECTORS DURING INTERVIEWS

1. How long e.mployed as an inspector 3 mo. 6 mo. 6 mo.-l yr.

onsite?

2 4 8

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

7 4 5 Yes No

2. Prior inspection experience? 14 16 Nuclear Non-Nuclear

3. Wnat discipline (s) ? 8 6 Implemented Qualified Yes o N,o, Qualified Answer 4 Is there a sense of intimidation 29 1 based upcn the need/ requirement to keep up with construction?

'. Is there a reluctance to make 29 1 adverse findings if they will inpact on the construction or audit schedule?

6. Is it routine for QC inspectors 19 9 2 to be working frequent and/or excensive overtime?

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

8. Do they feel the required inspections 18 2 10 are being conducted prcutptly?

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-ment in the event of a stop work?

a

m v s' .

a Implemented Qualified Yes }lt j Qualified Answer

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 activities to come to a stop?

12. Are the QC inspectors provided 15 15 adequate check lists for all activities they are inspecting or are they so.netimes using vague guidelines?

13. Do they feel that they have an 28 2 avenue to management if they .

come across a problem?

Do they feel msnagement will get 27 3 involved or just pay lip service?

e

SSINS No.: 6835 IN 82-34 R2v. 1 UNITED STATES NUCLEAR REGULA10RY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D. C. 20555 September 17, 1982

!E INFORMATION NOTICE NO. 82-34, REV 1: WELDS IN MAIN CONTROL PANELS Sqdressees:

ill: holders of a nuclear power reactor operating license (OL) or construction se -it (CP).

]gtpose:

This revision is made to provide the specific time period during which the R1 ictentially significant problem pertaining to welds in main control panels R1 oy ha/e existed. The panels of concern were supplied to a number of R1 a eratia.; plants and construction sites by Systems Control of Iron Mountain, R1

";chigan prior to March 1980; Reliance Electric of Stone Mountain, Georgia R1 aiior to March 1932; and Comsip of Linden, New Jersey prior to March 1982. R1 loly thase pinels nanufactured prior to these dates are now included in the R1

' st of sites which may have panels with defective welds. The potential

. R1 mtety significance of this problem is still under review by the Nuclear R1 1rgulatory Commission (NRC) staff. If NRC evaluation so indicates, further R1 licensee action may be requested. In the interim, the staff expects licensees R1 h revies the informaticn herein for applicability to their facilities. No R1 o ecific action or respense is required at this time. R1 L.scription_ot Circumstances:

laspections at the venders' facilities conducted in March of 1980 (Systems R1

ontrol) and March of 1982 (Reliance and Comsip) disclosed numerous welding R1

aactices not in accordance with the American Welding Society (AWS) Standards

md several quality assurance practices not in compliance with the vendors'

,aocedures or NRC requirements. Among these were the following:

1. Cert i fied material test reports not obtained, not available, R1 ar not in accordance with AWS specifications

2. Changes to dralings not properly reviewed and accepted

3. Welt'ing Deir9 done by unqualified individuals without qualified procedures and using uncalibrated equipment

4. Poor welds, including lack of fusion, undercuts in excess of 1/32",

and w l! > ire remnants from 1/2" to 4" in accepted welds

5. Widing procedure qualification and welder qualification testing reym nd by AWS Standards not accomplished

f. . Issential variables as specified by AWS Standards violated

7. Managnu.t oversight not accomplished for lengthy periods; lack of eparate review and approval for Quality Assurance

8. Ifn uhmti fied weld f iller metal used

9. Cas t.ungsten arc weldiny (GTAW) process used but not documented in H ai e- of required gas metal arc welding (GMAW) or shielded metal arc widing (SMAW) processes YUS190222 h.b

n _-

IN 82-34 Rev. 1 S:ptemb;r 17, 1982 Page 2 of 2 s.nce the inspection determined that the non-conforming practices of all three

/.ndors were similar and widespread at each manufacturing facility, it can be R1 x aamed that any panel furnished by these vendors prior to the respective NRC R1 is,spection dates may have defective welds. Although the vendors have seismically R1 oratified sinilar panels, improper welding practices and defective welds prior R1 it-the NRC inspection may affect the validity of those qualifications. R1

<,n-s ois.

control panels were identified during vendor inspections as having defective R1

<; lows:

Sites which have received panels that may have defective welds are as Palo terce 1, 2, and 3; Byron 1 and 2; Braidwood 1 and 2; Midland 1 R1

',,oa 2; -

Vogtle 1 and 2; Callaway 1; Comanche Peak 1 and 2; Waterford 3; Wolf Creek; R1

, wick I and 2; Seabrook; Susquehanna; Three Mile Island 1; Salem 1 and 2; R1 Creek. Monticello; Perry 1 and 2; Hatch 1 and 2; Indian Point 2; Shearon 1 .

is 1, .', 3, and 4; St. Lucie 2; Shoreham; Virgil Summer; Dresden; and R1

<lle.

R1

, ao ha s. wy questions regarding this matter, please contact the adminis-

, ,r ot : *,4:

appropriate Regional Office or this office.

/Edward Jordan, Director Divisi of Engineering and Qua ty Assurance Office of Inspection and Enforcement

nicai .:catact: 11. S. Wegner 301-492-4511

. . hine n t D it of Ret.ently Issued IE Information Notices

h6

- - - - - + -. - -. + - . -

• g

%.,,,m m y A _,ro,.m w.L t 'scM *: lit' 'M nr l!stMd?!Lf \t .s i n t Y$ $4tM . U! i6 ht0

.LNlld3M* LIIIIe DOInOS f lLx:v W s . ' c mn- he r 4 , ,

, . o .,.m.~..m m u .m em,g. ...a" ..

pumps that could cause a s . . .. o m .

h p% * .. e 2, x

., e m ., - , e . w m.m - 3

+e nuclear power plant -

?g.Y.h.,

g

.m pu, m m.tm v,,mi

--f. .....

w.o

+

accident u

i t w n pumas ' r M W e 2 ? * ? n'" ^~ 3 M 3 ? Lme.m A by W tVsedow rid Alan MacRobert W N:

Jent, su h 4. escurrd a Three Nile Istara, a sore vermor.t Vanguard preu ~-

me! down couU re uh Such an addent. .i.curdag fer.(Y 3

y . : , %.u. 3 C. .~ , . ma. a s a ecm of theusenth of r corde m a thaliev settled g ,

gy ty ,

rea. in w: u + to a ..aan ter m.19n mue. .nd came N'I'orn of delar? m preper'y darnan g -3

, "I persoruffy would an-r lue :*t the u:m tv of a r r:ar-tetr fat,W tha' had Hws e ? T3!e er* m any sort of critgal capacity." say ; Alf red f. I homas

[,8 l [ ,

y b-a fermer meihedh te.hn. car for the manufa runry Jeparf r'.cet e If ar arJ Ty!cr. *1 ha.c no fa.th in the h ~

i h rg ' - Q product that I wa; msnhed .ufh m manufacturing

• N.f Commonwealth Ediwn. Chicago's electricity utili-

.y. has pumps manufactured by Hayward T>ler at

• M four nuc! car plants under comiruction. two at **

Bgon, soeth of Rodford. and 140 at Bra 6Jmood.

8" M r ' Y- . .

wuth of Johet. IJnlike wrre of the pumps made by ,p* fU p3  ; e . , ,d Hayward Tyler, thme at Commonwealth Edmon's , h f -

['  ; h

• plants are not dwec*fy related to the Lmergency Core

• l * ' _ .. a Cooling Spiem. the met critical safety system m a f h nuclean plant. I hey are, nonetheless, important to l

'N* MTI bh .

. Idem C - _J-  ; g7gj--' '

the mera!! safety of the plant in an emergency and { - - se ~ ~ * " .** =_.

imieg _ --

CF officials are tal6mg the allegations of shoJdy j-workmambip seriously. -- / *'  %% _

.duuW -~

~

"We can't afford any shp-ups." said Jim Tmcas.

nuclear communication specit.ibst with CE. "W e Compens headquarters in Iturhaston geremont, hase already notified our ens tineering staff to in-sestigate " Tmcas said the pumps m question, awo at welder Fred Loron, and another ranking es-crnploye Chairman Nunzio J. Palladino to conduct a fullin-each of the four nudear plants, are used to supply who wishes to remain anonymous-recently se tigation of the workers

• charge, one that would in-coolmg water to a dinel engme on a backup elecirnal power generator. The generator would be used to rrnented afledauts spelhng out their charges to the clude testing and X-raying of a "reinant sample" of

-upply powet to the nuslear plant in theca c ef a ma. UX House Interior Committee's Subcommittee on pumps that hase been recened by Hayward Tyler's Osersight and Imntigt.tiom, shaired by Rep. Ed. nuclear customers-mostly nuclear plant comtrue.

for storm or earthquake disrurtmp the plant's not. ward \larkey ( D-%1awachusett O. All fisc were mat elecirk w supply. "If there were a blackout, this lion firms and electric utihties.

employed by Ha>=ard Tyler for between one and Says Congrewman Starkey, "If thne a!!cgations generator would be needed to supply power to the three years between 19'6 and 1950. Three of the fise prose correct. I am shocked that the NRC failed to -

t mergency Core Coohnu Sytem." Toscas said, "so m that seme it is related " say thes quit soluntarily for reasom of profenional turn up nidence earher in its preuous probes of ethws. One was laid of f, and one was fired quality awurance at the g lant. If Hayward Tyler Imcas said Common *calth Idmon den not Their statements to the subcommittee run to l'0 Company pumps of mafor safety significance to nu-f routmels cond At its own quaht) te is on sush equip-ment but mstead take the word of the supplier com-typewritten pagn mostly sworn under oath and in- clear power plants base indeed been sent out with vsm that the part is free of defects. "Theive bound dudmg some company documents. They allege serious quahty defects, we need to mee swiftly to doiem of imtances of faulty manufacture, corner. discoser w here these pumps are located, to forntall a t s their program to condust these mspections," he cuttmg. ignoring of defects, and uolatiom of the possible nuclear accident worse than Three State ud . ")ou can't go m and impect netythmg strict record-Leeping required for work done on Island."

sourself " but former employn sa) takmg Hapard critical nuclear power plant components.

Tsler's worJ about the quahty of its pumps could be NRC insestigators are at the Vermont plant this Company offacials have denied these charges, and w eek a f atal mntake.

term them "utterl) without merit." They say the pumps in que tion routmely pass inspections by all the partie insolsed with them. They say they he Hayward-Tyler Purnp Company employs fred Thomas and the four other es- welcome an insestigation. 155 people and has sales of 110 milhon to ll2 milhon ernpl0>ewmashmnt Dasid De Lauriers, rnanufac- After receiung the af fidaut s, Congressman a > car, accordmg to a IMI statemcm bv the com-

_ euns seg eim 1 a nim e f%wmAllums_dger Mhrben s.A omenimm un DNrnhn.JULmrume - -

e e

F O g ontmuedfrom prenous IMke r n>'s then president Dennis Chalmers, lie said 40 o $0 percent of the company's buuness is nuclear. { h g

Most of the fne evemployes had nner discuncJ , ,8 .,  ;, .

H* ,

heir alkgatiorn mong themwlin before John War- } 6 ,

• , tTi how of the Vermont VentuardIvess brought them .

y ether during his elesen month insestigation for 4 Vermont gliernatne newspaper. Ilut their allega- .,.

y ,

iorn are very similar, and they pamt an alarmmg pic.  ;

ute of shoddy manufacturmg practices which top i'3 'f e i anagement at the plant knew about but faded to orrect.

s '

}f,aj t

'{-

5

~ t' I ,,1 "%

ilow could llayward Tyler hase pawed routme m-ctions by the Nuclear llegulatory Commimon i

, g:) '

i a

[r. ' .~_

nd the American Society of Metharucal I ngmeets fASMI-) and two specialinsestigations jM e(

7 by ,

ga the NRC {l. , ,,

g I' g) ek Ag -

fgg*/g g

nd one by the IIll? E p } ,!, 1 i , id, g f*j. -- '

w -.a=

Ired Loion, former chief welder for lla) ward -. J p&g 4 ,

.-?

yler, says in ha deposition to the Marke) suhtom- ,- g.s .

J 8g J d/'i- 7"~~. -

• 4 /3 m.

,ttee, "A%IL. Aioh at the paper *of k. w hether it ,

- . O 38 y e 1, as signed off right; they look at the date, and ,. Qi .

g d.3 @Y 4 . ,$ 7 'l Qi

3. ,

bether ca(h job was donc m order.1he) neser look 4{ , / d - f <g t the part....It was the same when the NRC came ,f b,y ..f ep -a 8 slj hrough. They'd come out and haik at the paperwork 3ij 4, Q l[,g;t, ' -

~

,pam but not look at the part. t+

/' '

hg. , 'f ** ,qq

..l! thn n their attitude in auddu.g and inspee-mg ceriam parn, you can (ome up with any kmd of rt, you can put anything out thef e--)ou muld use

{f ,e/

, g S, g  ;[ y .. I,! . 02[ f a

pg,g g p L h  % .# 4 . ,' , .4 3 attel parts as far as that goes, plastw toy parb/ f 4 ,

In her swor n statemeni, Janne Per r audm. ,

} > f

'y 'a,w .

2

,]

mplo)cd as a wtretan to the inanu faciunag p d4 . y ana er at llay*ard l>kt liom 106 until January 9m, an th.it m Nmember 1979 tshinity tietore she M, Q, g%. . $ min]j ,

g, ,, M j,,gey perraudin and Deind Desl.auriers: occounts for hasty enansla.ture, broen sc4u,a as fired wohout enplanationh se per uinaH y tions, and alsered documents.

Itered t'russal paperwtuk on ordcas inun hn bou.

-( )"' k before the A%Il' msgn tum f ar the Ihne charges have been repeated in the sworn and lia)w ard T yler refle,' 'h.d n.m ~'c N stamp' (nu(fear manuf as tur mir aut honianonl signed alldasits to Markey4 subcommittee. ,

enewal, my work tonsi d of updanny. rehpsng, a arges to John Warsham nd thanging documenh, she stain- T he oi 8- l'anguard Prm, who conducted an hi mmt e r tn al a t s '

m :nnlT 4 ny's purpmc for ihn was to make a e t\rhausine investiption that snebded dorean of in e anan.iias tuard hs li.o

• a e' l i b . " "" " '

anufacturmg prat lh o and insin hon resu er W on of doi uments from the I t i l, psewunird wasse tra

• c'" 'e "V C"'c '

cuously performed sonf orm to the yunh, bun o , nd thc Verrnent Department of l.atur and in- spicna (I t CM l b a l m o; . . .'n of t h- i he ermed 8)uaha v Ampath e Meu al Y through the l acedam of luformatio1 Att- n em nrol to IN hm uni w . ' the mrrn, "s sin the techny I

• es u s m es up t<w .att it c. No one at llay j )g, myq,nd foundy em W-

, m.uas es oui in t he shop. she aihlrit dunast en uuc, so the attesanons despoe repedied tath. I ases. I an y

,m t%.h manaser of to'D*" **e * *"nmunn anom foi in Nmlev fown m a Pows' , , ' , ,, , ,

l t he mam e r.u ter t t .o' o e :- r'""'I; -

dien liced, Inc.~the P4e* Vos b tiawd mutunanonal l

1 J he c T holdmg company that owrn llJWard Iller.csplain tinou, h 1.c era. as .om. th( w,hi trasol-a s e,,om ane ganom unghe nr cs base ed shar asi neuestsons shoulJ be doetied to him. heal to h.r feedo atrr s s:(tu si er te o uw d : ia been the harhe of .sn h.ed a mw been for ihr deser. steans thn dvs.es im bin.: p a ::.at.m to proda pmuinon of mashstmr Da nf Ibl .suners and hn at- When rust contacted. (tek said he sould mn encn>

,orney fellow Vretnam era screran Tom Itailey The answer questions about llayward I)ler because he was unfamihar with the plant and had noct been A tue ik or wn,N ar le d m +c icacto, a oo met at a hical s eter arn' tenter llailey there. lie later presented the following statement spiem - u lowobawl m a Jen. a shc h pa e i ppte enied Dnl auncts m unemployment hearmgs from the twmpany: cident nu. lear plo.: eg.cr.aoo. tw rnost 1 hc p. n :

phen he qu i hn job m late 1979 m doFust oser a!!cp in the 1005 mus' thcn inina h v N start it :n "We behese allegations of poor quahty control m y poor man f atture, after workmg a year at the tractor core wnh shoum b t i galhos of v x

$a>watd lyler. the construction of 'N rated' pumps at lla>waid smnurt Tyler's llurlington, Vermont plant to be uiterl) w nh Ic keep 'le cue term rs etheave it oi l In the course of hn unemployment hearmgs, FCCS shou!J f a I, s.,<< r mght na lange. mo +

pest.autiers tharged that liayward I)ler w as out merit. Any pump or replaecruent part for an) pump that is sold for u.e in a nuticar facilny mmi reactor imi, w hii h wo;ta th.vi he ome where r o . i '

growly ncFb Fens...m their darepid for product bepn io melt, po mt4, tanes i t aough the r ,

giety." lie said that parh for nuticar pumps were pass a sariety of inspectionwby regulatory thud- ,

party inspectors, inspections by the product prnsure smel an.1 tt.e mniamnsra Nai!dmg . v.!

emg mashined without the requued appsmal of in- releasu,3 bdbom of cm u r s koa ir..Jtoactn o s ptors; unfmished pumps were bems sent out to manufacturer,'in this case llayw ard Tyler, and by the ri-purchaser. Furthetmore, lla)warJ T)ler has neier the emirenment.

shry plants; management was conimually over- MccrJmg to wmkm who tu iu and ha . b. o hng in-house mspectors m order to approve use of recened a product quably complame from pur-chasers of its pumps for installation m rit(lear FCC5 sur:ps, some of ihm pumrs wdl f ad & i h sected pump parts; contracted blueprints, parts, after goinF snio optra:i3n ur he as s tient conde

% designs were altered without the required ap- facihties....it is our pohcy to operage within the spiot o and letter of all laws and regulations and to conduct p,cfo e joinittg Hay unt l yf e , -1 Ihomas u u .

/ost! of the customers; and paperwoik was routme- in Victr.a n as a t ensc g=ree meet.am end crew , t u r forged or altered to cover up the defwienciet All all our busmesses with the highe i moral and ethical l standards. Indian licad benesn she prastnes at

.wenm m os wir & **

~

% s o

s 4 r tW!!Mdd front l ?f'e mt.s [ ltf then mor6ed for the Liectuc Fioat do nion of General  %.rteer P.*" Pe ee e s.mme He** erd Tven p.mys. errore g l DynAmiei .r. t.ra:ca. Gr...c,14 n. .. t.w; . .... N

, e.t..,,,,,,

l- pms in, rb, wp. nocte=, s.?mmm see mo4 ed ,_.,,

for several mone.: m Hayward I):er's shop as a j%

f maetunist before be ng promoted it, twen2e a me.

thods technician in the fror.t offke. He deelared in f

l

{

g jg f])s N s'Saut to Corgama . Markc; . " Nr.;

castings, irr're'lers. ahafts, ha;k cosers- any gn en

/

k j

'/

f y 9

Cy$ f J ,

pump tomponent was at one time er another, m my esperserne, railroaded thrnugh the shop mithout the

/ Y f b #

) / , w ** - . .

benefit of coniphance with the Quality Assurance System."

I k

1 ..,

• • ~

1. 8 Dave DesLauriers came to Hayward Tyler directly \

out of the Navy, where he gerformed "sub. safe level \ f l

i

} I '

work in relation to valves and pumps that mere used in submarines." He .as hered in the fa!! of 1972 as a

\ s

% i

/

~

j

==i @

g * **

T =

horizontal boring mill operator. .. .;  ! *

"I had on numerous occasions helped the aswmbly O -*

workers assemble some of those pumps that were go- 00 ing out for shipment." DesLauriers wrote to Markey. "I found bearmgs bems put on shafts with *"'"'*" *b o -

• 4 sledgehamrners, and Crazy Glue bems used on pumps....In the navy...when we found cracks and defects in casings me had them immediately melted l

() a., ar.co  !

down and then me remade the casings....I did not see this happen at Hayward Tyler. O**d"'**'"*****"***"***  !'

"I know on various occasions pumps ment out to l different facihties around the country mnsing some of their key internal parts. One pump went out to a sleepers-that is, they will pass the incoming inspec- plains the circumstances in which irregularities at company on the % est Coast and did not base its im- tion." Pollard says. "You may mind up hasing a Hayward Tyler became, he says, a matter of routme.

peller, its bearmgs, or anythms mside. lig just had plant in operation with a defectne pur:.p whose "In the beginning, thmss wer*t rathet smoorhb.'

the shaf a that the impeller would ride on- defect is not going to show up unless there is an acci-if these allegations are accurate. one might monder he wrote to Markefs subcommittee. "I worked long dent. Thew pumps are not required to perform at hours but enjoyed them. w hen me started buildmg why the defects hase not been detected by the thdr design capacity cucept durms an accident."

cuuomers. Robert Pollard, nudear safery er.gineer nuclear pumps. the trouble began..

Pollard adds that NRC m<pections of plants under with the Umon of Concerned Scient ats m construction are moefully madequate:"It's entirely a "After about two and a hatf years, me me*cTt W ashmgton. D C., and a f ormer beenung project paper inspection. They don't do any inspection of the standmg up to our production commitments with manager for the NRC thmks he may base an equipment, and they don't esen irnpect all the paper. Stone Platt {then the parent companyJ. Management ansmer. Pollard quit the NRC m 19'6 afte' morking Iti a spot inspection of the paper." was told they mould make these commitments or be for the agency for sn and a half years because, he out on their ears. To make a long story short, the says. "I was conunted the NRC mas more mtersted w hole place turned mio a human time bomb-a com-in protectmg the mdustry than the pubhc.* om could this all happen? The high-ranking plete state of (haot Men were mer king an "You base some debenencies that are potentia!!y es-employ who wishes to remain anonymous es- contma.crf on nett pace e-W

TV {Q -- I &p . ,.; ((*.Nme* -

.. f

• l i

'i*

- i mmc. 9 A

s e (--

A

.x g)

% ,n yp ,A; .g

.hQ pM,pg.6 [

7 .1 : . *

,; . . q 17

% W AtC

%ertical service water pumps for nuclear m

f' * '

. ; .A(, . # 9@f-!*' Y # <' *k

. . . [@wM ~

Po*ft Plants under constreetion la

^) hh ryg the Haywaril Tyler plant.

e,pY

' f* W-%h

,, I .

I

(

4 connnuedfrom prenous page assembly wouk done at nrghn."

unbehevable amount of hours under unheard-of pressure.. Thomas claims that during the second shift machine operators were often told to forget the 2. he bts question now is whether the NRC will

" Things started gettmg worse instead of better. follom through on the request from Markey's comit-lhe deadline was getting close. Management ran paperwork, forget the Quahty Assurance system:

tee to carry out an intensive investigation of the around like escaped lunatics, but hell or high water. " 7ou know what has to be done--I want the several hundred pumps in question, including pumps were being shipp d. Somewhere, we lost the base plate (or t hateser component) finished when we X. raying and dismantling a sigmficant number of fechng of becoming the best pump company,in the get it in the morning,* " is the kind of thing Thomas said he heard. them to look for defects. .

world. Mer. were tired and manners were few. If the NRC does so, the question will become whe-

,i, Escryone was at their wits

• end. Still, management "It's very possible that welding work mas done by insisted on more osertime. others than me or the melders working under me," ther it can be trusted to do a competent ~o s b. Robert "A pair of shoes should not be built under these Fred Loron explains. "There mere cases of work we Pollard of the Union of Concerned Scientists says,"I started to do, that meren's finished at the end of the don't think the NRC has the capabihty to do it.

conditions.... Parts were remachined after inssection; They*'; ,- mme to have to contract it out to some p*

emploses were asked to sign off on route sheets who shift. The nest day they weren't thece-they were completely gone-me had oc idea who did them. tional laboratory w &me other plase."

did no perform the operation; men were complain- What they did at night I hase no sdea." Pollard is also apprehensese on another score:

ing about a part not being up to standard and mere very smoothly consinced by management that the "T he NRC has this tendency to... protect The unnamed employe says that in his mind. "The themselses....The people w ho wrote these anegations part wasokay;mhen a cor: tract called for a perceritage it ng of all mas tN impellers [ rotors that pr+

of pumps in that contract to be tested. the ones we may become the target of the insestigation rather e ro e pumd Some would not fit than the company or the pumps."

mere not so sure of were naturally the ones we did not o and JMn't run true or concentre. Tky Congressman Markey shares Pollard's concerns.

mere knosked around, tightened and loosened until "The onus should not be on the fase former workers The etemplo>cs cite the second shift as the tur.c .

thes woulJ run true. There mere also the ken for the at the plant who hate spoken out; thev should be when irregularities mere most commonplace. "The impeHers whish did not lit, and mere ground bs hand conFratulated.* Marke> stated befxe sendtng his wcond shif t was tacitly acknowledged as the shift till they ran true. If a pump was run to a m$imum Ictier to NRC Chairman Pallandino. "The onus that tot the work done," up Al Thomas. "One of RPM, they could become fome or out of talance and should be on the NRC and the Hayuard Tyler Pump the reasons behmd that was that me didn't hate to sesre a pump up or shak e it to bits. I behese these im. Company to show that the pumps are indeed safe.

deal with engineers and the Quahty Apurance and pellers are suppo ed to be interchangeable; and if they are, and a change as made n; the liciJ not k now- ' ,'

Quahry Control people. There mas a great deal of ing this, it would be a catastrophe.'

,g nTm u .,_.. , - --t~.

r- e u - e - e - --- -

s . --- - - -

A

g

? .

• C AFFIDAVIT OF EDRARD M. GOGOL My name is Edward M. Gogol, and I am a professional author .ind v1:: a l t.m on nuclear power plant hazards, costs and benefits. I have ntuated *hece issues since 1974, with particular reference to Commonwecith 1::12 mn' iuclec plants, and have participated in several proceedings before .ind pe.:: ions to the Nuclear Regulatory Commission. I received a B.S. degree in enen .:ry fr.

the University of Chicago in 1976 and have since done graduate studies in environmental health science. I am f amiliar with the history et Coma < nwea l t :

Edison's infractions of NRC regulations for which it has been fined. Recent I have made an exhaustive study of all public information concern 199 cons truction deficiencies at Edison's LaSalle County Station, including ssfrn af fidavits from construction workers, and including NRC cocuments 7btained from the NRC under the Freedom of Information Act.

I have read numbers 4 through 16 in Ediscn's " Material Facts For Which There Is No Genuine Issue". The affidavits from LaSalle construction worker and the NRC's own documents concerning the LaSalle station inaicate that indeed there are grounds to question Edison's qualifications and willingness to build and operate the Byron station safely.

Edison alleges that it employs people for its nuclear oper a tion s uno "a o_

dedicated to safety." This assertion is directly contradicted cy tne construction workers who have given sworn af fidavits concerning the Lc calle nuclear plant. These workers described how adherence to correct precedures was a low priority at LaSalle due to management pressure to get the p b dcne quickly no matter what the consequences. These werkers also dercr ibe:. hew Edison managerial personnel knowingly and deliberately covered up cenr.truc* .

defects and lack of adherence to specifications, crdered workers to follow unsafe and and incorrect procedures, and threatened that any worset ha described these conditions to NRC inspectors would be fired. Spectric construction flaws and defects included:

a. Concrete work is defective and honeycombed with holes;

b. The steel reinforcing rod structures within the concrete were indiscriminately cut and severed, drastically weakening the str uctures.

5470A-1 [g , h

c. There are many flaws in high-density concrote bloc <. walls t: i for radiation shielding;

d. Welding was done without adequate trainir.g or adherence to q u il t'/

control procedures;

e. Piping was defective, and Edison altered color-codes en equi; ment b

• it appear as if the correct component haa been installed when in fac* .

had not;

f. Quality control and inspections were inadequate; constr uction deficiencies were covered up.

The following material is directly quoted from these atticavita, wh were filed with the Nuclear Regulatory Commission on March 24 and April 1.

1982, or from material obtained from the NRC via a Freeden at Infernatico +

~

Request 1982. The full text of these allegations is appended reto;o:

"I have seen enough cases of shoddy construction (at LaSa2lel hat a question is not a shot in the dark. Most of the time the pm work si because of pressure to rush the job.

"I repeatedly saw the results of sloppy concrete pours t.c b .; and honeycombs in the concrete."

"I performed core drilling in all buildings, at all elev.>tna.;, thri the plant site...From the time I began drilling at f.aSa i tt i, June until about February, 1980, it was the usual practice, upon cantact .or metal reinforement or rebar during core drilling, to dril; thrcugh ' te metal rebar. I was instructed to follow this pr actice, and t> the be of my knowledge, it was the general practice amcng the other core drillers.

"On one occasion I drilled a 6" diameter hole through tebar in the reactor building of Unit 1. It was at 3 place where all tho steel ',

together, and I removed about 25-40 pounda of steel. It teck me 2 t ;

days to drill this hole. [The foreman) instructed me to keep drilli tu this hole, and he added, "If you can' t do it, we'll get seneone who -

" Construction crews core-drilled right through the reinforcerent 5 4 7 0A-2

]* @ # " T- .f we,; /q {i[v[ E.T MT{NMIIZ7 f 7p'

l.

bars. .. Reinforcement bars may have been broken throughet:t the plant *h construction crews routinely did not use metal detectore to locate 'b rebars. They would just start drilling. The quality centrol inspect did not seem to care. Quality control was more like a jcke at LaSel:e than anything else."

"I do not trust the mortar work at LaSalle. Sometimes the problem wm that the mortar was not used...When I complained to a foreman he saic that Quality Control did not care. . .Even when mortar wan used , it was shoddy quality. There was too.much sand in the mortar...Around a taa .

of the time my superintendent was present and ordered me to add extra sand...There were mortar tests, but the superintendent always knew whr-the tests were scheduled and let me do it right then."

"Sometimes Morrison project management says to accept rome th ings t! o are not according to our standard operation procedures. For example welders may be certified to a weld procedure after the weld is made Sometimes, if a welder is not qualified en a weld he hen nado. he management says, 'We will call it another kind of weld.'"

"The foremen don't appear to know what welding procedures apply. . .Or * -

the foremen say sloppy work is okay becaune it is in seme place hare see. The foremen say they will never see it; it is okay."

"The installation of parts did not always match their location on th -

blueprints. Sometimes one part was installed in a location wnere tLe blueprints called for another.. .For instance, the metal in hanger supports is identified by a color code. When construction had the . a size supports but not enough of the right color, they just copatnteo i color on the hanger." ,j

" Management always knew two days in advance of NRC inspectiona and ha.

clean up the plant superficially. That was gcod enough. The NRC re"ar took initiatives to talk to us workers... We always wonderoo .hy

• b. 4 didn't come when the utility didn't know in advance.

"All too often management would hire Mexican or other foro t m velde: I, 54 7 0A- 3 z~ --

the street by obtaining temporary work permits. There employees weer i o.

always well qualified and frequently could not communicate well due t -

language barriers. They were very well paid and were totally at tht mercy of the company to keep their jobs. As a result, they could not -

counted on for thorough, professional work independent of pressures '. 2 speed production.

"Another reason for my doubts is the management attit uce at LaSalle, which was heavy-handed toward workers who raised safety concerns. . . Management of ficials harassed the workers wr.o spoke out.

There were also utility spies among the construction workers. On balance, employee morale was very low. Post employees I speko with h+

become apathetic. They felt that their complaints would not :1a k e a difference except for themselves - they might lose their jobs."

"Many times I have overheard a quality control inspector tell construction that something was done wrong and that he would oe bact Soon the inspector would come back and say the defect was OK af ter .,

Clearly, Edison's lower-level employees ontensibly responsttle for quality assurance at LaSalle carried out their duties in a raanr.er which no f have produced a severely flawed and deficient kkructure. Conce:ntag the high-level Edison personnel responsible for the overall quality assuranc.-

program, one of two conclusions must hold: either (1) Edinon's top manager-

• knew of, permitted, encouraged and bears ultimate responsibility tar the .

construction defects and violations; or (2) Edison's top managem..n: did m know of these defects and violations, which casts doubts on t he "ntire i competence and efficacy of these personnel.

The NRC is currently investigating the evidence put foraaco h/

construction workers at LaSalle (in response to a petition t 1"d h/ the '

of Illinois requesting a suspension of licensing activittoa at as;211e .u full public hearings regarding this evidence) . Rega rd lead o :. t:m :-ven t ua outcome of this investigation, the sworn affidavitt by constructror. sock,  ;

prove that any allegation that Edison's employees put safety firat is on t :.

face untrue.

Edison alleges that the quality assurance program to te amployed at a tt en during station operation meets the criteria set forth in 10 CFR Pa r t 50.

Edison has made similar allegations concerning construction ictivttles at 5470A-4

4 LaSalle. Since these allegations are on their f ace untrue it LaSalle, Edison's allegation concerning Byron should be viewed by the NRC with th strongest scepticism.

Edison alleges that it has created " corporate level deputments to utilize experience from each of its operating stations to improve operatt: n

• all stations", that it has " engaged a group of distinguished scientists an i business leaders from t he Chicago area to evaluate the ef f ectiveness of :ts nuclear operations, and has improved its corporate control of nuclear operations based on recommendations made by tne panel." If this were tru' y the case, it would have been Edison itself, not the State of Illinois or r Government Accountability Project, which has brought the evidence of construction fraud and deficiencies at LaSalle to the NRC's attention.

Clearly, these " corporate level departments" and " business leaders" are et t -

window-dressing, designed to make it look as if Edison is dealing with a problem.

Edison attempts to down-play the significance of the nany eiciatiomi .:

NRC regulations for which it has been fined. In reality , cdisor:' c past sa casts severe doubt on its technical competence to operate a plant as technically complex and demanding as a nuclear plant. At one point in t!x last several years, NRC Regional Director James A. Keppler was quoted an saying that Edison's management at the Zion plant was so lax that "the tiutt hand doesn' t know what the lef t is doing". Tnis attitude en the part of Edison's management is directly in contradiction with the utility's clai.t. ta put safety first.

Edison alleges that the number of deficiencies identified by NRC inspectors at Edison plants has declined over the last five years. Regar ;"

of whether this allegation is true, the allegation equally could imply tnat-Edison has become more adept at covering up these deficiences frcn the NFi inspectors or that the NRC inspectors themselves have become more tax.

Evidence that such covarups occurred at LaSalle is in the hands of the Nit there is no reason to suppose that such coverups were not cccurring at ry n.

Edison alleges that its Quality Assurance Programs have been review < -

a variety of outside agencies. Clearly these must have been " paper rev2< -

The question must again be asked: why did notathese outside agenctes, er i^,

Ed itself, report to the NRC the huge amount of evidence of censtructicr.

defects at LaSalle which has been brought forward in the laut few month- w.

the State of Illinois and other sources?

5470A-5

, y- u Ultimately, Edison's assertions are based on affidavits : r c.T several 'r Edison's high level employees. Clearly these employees' al' egat : nna car- <>

be taken at face value; their allegations are opinions, not " material t._': ~

Only an investigation by an outside body whicn would interview lower-lev <

reactor operators, engineers and technicians while promising complete anonymity to these personnel, could adequately assess to what degree the company actually adheres to quality assurance standards and to t. hat daqr e ty company makes safety its first concern. Such an investigation wculd hav+ to be done by an outside body and would have to premise workers cemplete anonymity or it would have no validity: as the LaSalle worker: made cle n ,

they are afraid that if they do make unsafe ccnditions public or complain about them even internally, they will be summarily fired.

Over the last five years I have interviewed numerous Edison employer a Dresden and at LaSalle, including se"eral reactor operatcrs or reactor operator trainees. Many of these e.aployees have had attitudes showing tt safety is not a concern at all; in many cases, the employees believed ti: n nuclear plants could not M unsafe, and they indicated a great deal of ignorance of the special dangers of nuclear power which have necensitate... .*-

plants be located in relatively unpopulated areas, that evacuation planc ..

place for all residents located within 10 miles from the reactor , and ti:at .-

special government bureaucracy be created to regulate nuclear plants. It is this ignorance which is perhaps the most frightening aspect of Edison's inability to operate nuclear plants safely: the people running the pl.!,t 1.am little or no awareness of the special hazards of the plant.

I have read this six-page affidavit; it is true and cerrplete to the t+v of my knowledge.

, s c[ ., Te g/

Edward Gogol Date Lcknowledged and sworn to before ne this 22 d day of Septenber, 1932.

k h to/cdtu %

5470AE6 Motary Public

-