ML20197G719
| ML20197G719 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 03/23/1984 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20197G699 | List: |
| References | |
| 8320N, NUDOCS 8406180131 | |
| Download: ML20197G719 (48) | |
Text
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e t- ,/ ^ h .)Commonwe:lth Edison
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\ f Chicago. Illinois 60690 March 23, 1984 Mr. James G. Keppler Regional Administrator .
U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Braidwood Station Units 1 and 2 Response to IE Inspection Report N . 50-456/83-18 and 50-457/83-17 b' <C Docket Nos. 50-456/457 References (a): R. L. Spessard letter to Cordell Reed dated February 16, 1984 (b): R. L. Spessard letter to Cordell Reed dated January 27, 1984 (c): L. O. DelGeorge letter to A. B. Davis dated January 12, 1984 (d): M. J. Wallace letter to R. L. Spessard dated November 17, 1983
Dear Mr. Ket )ler:
References (a) and (b) provided the Commonwealth Edison Company with_the results of an inspection conducted by Mr. R. S.
Love and other members of your of fice during the periods of October 31 through November 4, 1983, November 7 through 21, 1983, and January 12 and 13, 1984, of activities at our Braidwood Station.
During that inspection, certain activities appeared to be in non-compliance with NRC requirements. E, closure No. 1 to this letter provides the Commonwealth Edison Company response to the Notice of Violation as appended to Reference (b). Our response addresses each example cited under the items of non-compliance, and further addresses each additional example identified within Reference (b) that relate to the requisite item of non-compliance.
Our delay in submittal of this thirty day response until March 23, 1984 was discussed on separate occasions with Messrs. C.
C. Williams and W. S. Little of your office, and we appreciate having been given additional time to respond in this matter.
8406180131 840608 e PDR ADOCK 05000456 G PDR M4Sg6 g.
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The four items of non-compliance and various examples contained in Reference (b) were discussed during the Enforcement Conference held in your offices on December 20, 1983. Reference (c) briefly addressed each of these concerns as we understood them at that time. Our response to the items of non-compliance contained in Enclosure No. 1 to this letter are based on our further review of each item. It should be noted that in the majority of our reviews, we found that the Region's concern did not have a negative impact on hardware in the field. Also, the resultant procedural changes are expected to.be accomplished by March 30, 1984 in the majority of the Cases.
As requested in Reference (b), and in accordance with our commitments provided in Reference (d), Enclosure No. 2 to this letter provides additional information to assist the Region in evaluating the effectiveness of the Commonwealth Edison and L. K.
Comstock organizations in accomplishing electrical construction activities at Braidwood Station. The updated schedule for completion of required L. K. Comstock activities is documented on L.
K. Comstock " review of status" sheets available on-site for the Region's review.
Finally, Reference (b) requested a written response to the unresolved item Nos. 50-456/83-18-09; 50-457/83-17-06 concerning torquing requirements for mounting electrical equipment. Our interim response is contained in Enclosure No. 3 to this letter.
To the best of my knowledge and belief, the statements contained in the Enclosures are true and correct. In some respects these statements are not based on my personal knowledge but upon information furnished by other Commonwealth Edison employees. Such information has been reviewed in accordance with Company practice
-and I believe it to be reliable..
Due to the complexity of these issues, we are available to meet with members of your staff at their earliest convenience to review the enclosed information. Please address any questions that you or your staff may have concerning this matter to this office.
Very truly yours, Louis 0. DelGeorge W
Assistant Vice Presi ent EDS/ rap Enclosures - 3 cc: RIII Inspector - Braidwood nrcr.rn
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ENCLOSURE 1 COMMONWEALTH EDISON COMPANY I RESPONSE TO NOTICE OF VIOLATION l
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VIOLATION"1 10 CFR.50, Appendix B, Criterion III, as implemented by Commonwealth Edison Company Topical Report CE-1-A, Section 3, requires that the design basis be translated into specifications, drawings, procedures, and instructions.
Contrary to the above, Commonwealth Edison Company failed to assure that criteria.for tightening electrical connections, as delineated in Commonwealth Edison Company position paper dated
' January 8, 1982, were incorporated into Electrical Specification F/L.2790.and L. K. Comstock work and inspection procedures.
This'is a Severity Level IV violation (Supplement II.0)
RESPONSE' Commonwealth Edison Company agrees that not all of the specific language describing the criteria for tightening electrical connections asLdelineated in the Commonwealth Edison Company-position paper dated January 8, 1982 (" compress the. lock or star washer") was incorporated into Specification F/L 2790 and L. K.
Comstock work and inspection procedures.
-Because of the' lack of industry standards.and direction in Specification F/L 2790, Commonwealth-Edison-Company required L.
K. Comstock procedures to meet the criteria of the position paper by including.in Procedure-4.3.9 (Paragraph-3.1.12.'3) the requirement "The connection shall be tightened in a good
' workmanship'like manner" and in Procedure _4.8.9 (Point 3.3 d))
the~1nspection point " Lug.connectionotight at-term. point", each effective 1since-March'1982.
We believeEthat;the L. K. Comstock procedures adequately met the p
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intent of.the Commonwealth Edison Company position _. paper to assure that connections were tightened. .However, in order to address-the Region's concern in this_ area, CECO will revise the L. K. Comstock Procedures 4.3.9 and 4.8.9 at paragraphs 3.1.12.3 and 3.3 d) respectively to provide specific language concerning compressing the lock and star washer, and will revise the S&L Design' Drawing No. 20E-0-3390~to reflect this change. Because the activity in question affects field work and is not
.specifically reflected in Specification F/L 2790 language and requirements, it is our judgement that revision to S&L Design Drawing 20E-0-3390 as opposed to Specification F/L 2790 is-
--preferable and sufficient ~to address the Region's concern.
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Because the intent of the Commonwealth Edison Company position paper was being met through implementation of the Comstock Procedures 4.3.9 and 4.8.9, Commonwealth Edison does not believe that this item is a circumstance with more than " minor safety or environmental significance" and therefore Commonwealth Edison believes that this item has been improperly classified as Severity Level IV. Our work practices, as set out in the procedures, require that the connections be tightened and inspected to check if the tightening occurred; we do not believe that there has been any negative impact on hardware in the field.
CORRECTIVE ACTION TAKEN AND ACTION TAKEN TO AVOID FURTHER CONCERN Revise L. K. Comstock Procedures 4.3.9 (Paragraph 3.1.12.3) and 4.8.9 (Paragraph 3.3, Item d)) to reflect and reference the Commonwealth Edison Company directive of January 8, 1982.
Clarify Design Drawing 20E-0-3390, Sheet 1.
DATE OF COMPLETION Sargent and Lundy Design Drawing 20E-0-3390, Sheet 1 was revised on January 6, 1984.
Revisions to the L. K. Comstock Procedures 4.3.9 and 4.8.9 are expected to be completed by March 30, 1984.
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i' e VIOLATION 2
- l'0 CFR 50, Appendix B, Criterion V, as implemented by Commonwealth Edison Company Topical Report CE-1-A, Section 5, requires activities affecting quality be prescribed by documented instructions, procedures, or drawings and shall be accomplished in accordance with these instructions, procedures, and drawings.
Contrary to the above, the following examples were identified:
- a. L. K. Comstock Procedure 4.8.5 failed to address the verification that cables were not damaged and that cable pans are free of all debris prior to installation of cable pan covers.
- b. L. K. Comstock Procedure 4.8.5 failed to address the verification that cable pan covers are installed in accordance with specifications, drawings and standards.
- c. The minimum embedded conduit bend radius in Paragraph 3.9 of L. K. Comstock Procedure 4.3.7 violates the minimum conduit bend radius established in Paragraph 3.10 of Sargent and Lundy (S & L) Standard STD-EF-103.
- d. The requirements of Sargent and Lundy Standard STD-EF-103, Paragraph 3.13, are not reflected in L. K. Comstock Inspection Procedure 4.8.7.
- e. L. K. Comstock Procedure 4.3.8 does not address precautions to be taken when pulling small cables (less than 100 pounds maximum pulling tension), and does not address the installation of cable grips to vertical conduit runs in accordance with Sargent and Lundy Standard STD-EB-200.
Additional examples were identified and are delineated in attached Inspection Report 50-456/83-18; 50-457/83-17, Paragraphs 3.B.(8),
3.B.(9), 3.B.(10), 3.B.(ll), 3.B.(12) and 3.0.(1).g.
This is a Severity Level IV Violation (Supplement II.D).
RESPONSE
Commonwealth Edison does not believe that all of the cited examples relate to a Severity Level IV violation. Severity Level IV requires that the items involve episodes of more than " minor safety or environmental significance". In many of the items cited, there was no actual hardware involvement in the field. Examples 2.a and 2.b concern areas in which no work had been performed or scheduled as yet; there remains ample time to initiate such procedures. We plan to use the related requirements contained in the Byron Station procedures to address cable pan cover installation activities.
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Example 2.d does not concern safety related equipment or procedures and is not subject to citation under Appendix B. The first issue in example 2.e dealing with precautions in tensioning small cables is addressed by the existing procedures. Finally, although example 2.c and the second issue in example 2.e dealing with cable grips did highlight areas wherein the procedures were inadequate, in spite of the inadequacy, the work was performed in a manner that assured proper hardware installation. The bend radius actually used in the procedure-cited in example 2.c was conservative in that maximum cable pull tension was less than the allowable in all instances. Similarly, although we admit the procedures did not properly require cable grips, we note we have found no situations in the field wherein cable grips were not installed as required relative to vertical conduit runs.
The following provides the specific Commonwealth Edison Company response to each example of non-compliance and each " additional example" cited under non-compliance Item 2.
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,o 2.a and 2.b L. K. Comstock Procedure 4.8.5 failed to address the a.
verification that cables were not damaged and that cable pans are free of all debris prior to installation of cable pan covers.
- b. L. K. Comstock Procedure 4.8.5 failed to address the verification that cable pan covers are installed in accordance with specifications, drawings and standards.
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RESPONSE
r Commonwealth Edison Company admits that procedures identified in examples 2.a and 2.b did not contain certain verification points relating to cable pan covers. However, it should be noted that the particular work activity involving cable pan covers had not been accomplished or even. scheduled as yet. We were aware of the -
necessity of including these points in the inspection procedures.
We plan to use the related requirements contained in the Byron Station procedures to address cable pan cover installation ,
activities.
CORRECTIVE ACTION TAKEN AND ACTION TO PREVENT RECURRENCE ,
. Prior to performing cable pan cover installation activities, applicable Quality Control Procedures will be revised or developed to assure, at a minimum, the following inspection attributes: .
- cables are not damaged
- cable pans are free of debris
- design requirements are met in relation to cable pan covers 0 ATE OF COMPLETION ,
The procedures will be in place prior to performing cable pan cover installation activities.
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- c. The minimum embedded conduit bend radius in Paragraph 3.9 of +
L. K. Comstock Procedure 4.3.7 violates the minimum conduit bend radius established in Paragraph 3.10 of Sargent and Lundy (S&L) Standard STD-EF-103.
RESPONSE
Example 2.c involves the minimum embedded conduit bend radius in Paragraph 3.9 of L. K. Comstock Procedure 4.3.7 and suggests that it violates the minimum conduit bend radius in paragraph 3.10 of S&L Standard STD-EF-103. This also relates to example 3.B(9) of the inspection report. Commonwealth Edison acknowledges that the procedure violated the minimum conduit bend raulus established by the S&L standard.
Sargent and Lundy Standard EF-103, Paragraph 3.10 references a two inch (2") conduit, with a bend radius of no less than thirty-six inches (36"). It is intended to be used in the Generally, construction of concrete duct banks, manholes, and handholes. this type of construction is external to any building and may result in longer cable pulls thus affecting maximum allowable pull tension.
For the Braidwood Project, EF-103 was used primarily for non-safety related underground construction to the Lake Screenhouse and Switchyard.
Sargent & Lundy EB-146 references a 2 inch conduit bend radius of 24 inches. It refers to external exposed conduit on walls inside of a building. Because bend radius is a primary factor in determining maximum allowable pull tension, it becomes evident that a 36 inch bend radius would be more desirable for the longer cable pulls.
However, both standards EF-103 and EB-146 are part of L. K.
Comstock Procedure 4.3.7 and possibly can cause confusion as to what the conduit bend radius should be.
Commonwealth Edison Company believes that the confusion in the S&L standards and the L. K. Comstock procedure has not affected the installation of cable and has actually reduced the maximum ,
allowable pull tension. The intended purpose and design of a conduit system in general is to allow routing, physical protection, and installation of cable without violating maximum allowable pull tension. This is accomplished because our procedure for cable pulling establishes the maximum allowable pull tension for cables based on a minimum bend radius of 24 inches for a 2 inch conduit.
However, Commonwealth Edison agrees that the confusion should be clarified and will modify the L. K. Comstock Procedure 4.3.7 to reflect the above.
CORRECTIVE ACTION TAKEN AND ACTION TAKEN TO AVOID FURTHER CONERN Revise and clarify L. K. Comstock Procedure 4.3.7 to appropriately reflect the requirements of EF-103. ,
DATE OF COMPLETION
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Expected date of Procedure 4.3.7 Revision is March 30, 1984.
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- d. The requirements of Sargent and Lundy Standard STD-EF-103, Paragraph 3.13, are not reflected in L. K. Comstock Inspection Procedure 4.8.7.
RESPONSE
Commonwealth Edison Company believes item 2.d should not be classified as a noncompliance with 10 CFR 50 Appendix B Criteria V However, the because it does not deal with a safety related issue.
following addresses the Region's concern in Item 2.d and Example 3.B.(10).
The requirements of Paragraph 3.13 refer to " Duct Bank" installation. For the Braidwood Project, duct bank installation is limited to non-safety related underground construction and is not Cleaning required to be part of L. K. Comstock Procedure 4.8.7.
and swabbing of any underground installation is considered good work practice and was performed at the Braidwood Project. To date, no problems has been identified with any cable resulting from postulated undesirable protrusions or debris in duct bank installations. For other embedded conduits installed in all buildings it was and is our practice, as a good work practice, to assure that no burrs or sharp edges remain on the inside of conduits during installation. Verification of this practice is assured during cable pulling. L. K. Comstock Procedures 4.3.8 (Installation) and 4.8.8 (Inspection) allow for the inspection of cable during the pull. We have not replaced any cable damaged because of undesirable protrusions or debris inside of conduit.
However, we acknowledge the possible confusion which may result from the combination of the non-safety related and safety related activities contained within one standard. As an added precaution, we will clarify L. K. Comstock procedures to assure L. K. Comstock remains attentive to cable condition as cables exit conduit (as a measure to assure the effectiveness of the crafts' attention to burrs or sharp edges).
CORRECTIVE ACTION TAKEN At this time the majority of_ embedded conduit work has been completed. However, for any_ future conduit installations, either embedded or exposed, L. K. Comstock Quality Control will perform selected in-process inspections. Further, L. K. Comstock cable pulling and inspection procedures will be clarified to assure that L.K. Comstock personnel remain attentive to the cable condition as cables exit conduit.
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DATE OF COMPLETION -
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L. K. Comstock Procedures 4.3.8 and 4.8.8 are expected to be [
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- e. L. K. Comstock Procedure 4.3.8 does not address precautions l to be taken when pulling small cables (less than 100 pounds maximum pulling tension), and does not address the installation of cable grips to vertical conduit runs in accordance with Sargent and Lundy Standard STD-EB-200.
RESPONSE
There are 2 issues listed in example 2.e. The first deals with precautions needed to be taken when tensioning small cables.
Commonwealth Edison Company believes adequate precautions were taken for pulling of cables with tensions less than 100 pounds.
Procedure 4.3.8, Paragraph 3.2.7.2.2 states, " Dynamometers or breakable pull links must be used on all pulls through conduit".
This statement applies to all cables including sensitive cable whether hand pulled or mechanically pulled, whether large or small.
The only exception to the rule stated above is found in Paragraph 3.2.7.2.3 - Pushing Cable Through Conduit. For installations where cables are pushed through conduit, no tension monitoring devices (link / dynamometer) are required. Pushing of cable is limited to a maximum of twenty-five feet (25').
Paragraph 3.2.7.4 - Power Pulls Through Tray states,
" Dynamometers or breakable pull links must be used on all power pulls through tray". The only exception to this rule is Paragraph 3.2.7.3 - Hand Pulls Through Cable Tray. This paragraph allows ,
hand pulling of all cables, including sensitive cables, and !
describes the process of hand guiding cables. Any cable that is not hand guided around a corner or changes direction, requires tension monitoring devices.
In our judgement, the above requirements adequately guard against the problems which may be encountered in pulling small cable.
Commonwealth Edison believes no more explicit precautions are necessary.
The second issue in example 2.e deals with the use of cable grips in vertical conduit runs. Commonwealth Edison Company admits that this activity is not adequately addressed in the procedure. We note it was covered in the procedure for vertical pan risers (Paragraph 3.2.8.5) and was intened to include both vertical pan risers and vertical conduit runs as applicable. We also note that '
to date, no instance of failure to install cable grips as required by design has been identified relative to vertical conduit runs.
CORRECTIVE ACTION TAKEN AND ACTION TAKEN TO AVOIO FURTHER CONCERN i Procedure 4.3.8, Paragraph 3.2.8.5 will be revised to include the use of cable grips in vertical conduit runs.
I DATE OF CORRECTIVE ACTION >
r Revision of L. K. Comstock Procedure 4.3.8 is expected by March 30, 1984. >
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OTHER EXAMPLES CITED UNDER NON-COMPLIANCE ITEM 2 Additional examples were identified and are delineated in attached Inspection Report 50-456/83-18; 50-457/83-17, Paragraphs 3.B.(8),
3.B.(9), 3.B.(10), 3.B.(ll), 3.B.(12) and 3.D.(1).g.
ITEM 2, EXAMPLE 3.8.(8)
Procedure 4.8.5, " Inspection of Class lE Safety Related Cable Pan Installation", Revision A, dated February 4, 1983.
Paragraph 3.2.2.1 - This paragraph needs to be revlsed to require the Level II inspector performing the review of Form 17 for completeness to also review the data for acceptability and/or rejectability when a Level I inspector records the data. All procedures / forms need to be revised, as required, to clarify this requirement.
RESPONSE / CORRECTIVE ACTION TAKEN Commonwealth Edison Company acknowledges the need to revise Procedure 4.8.5 so that the scope of a Level II inspector's review of a Level I inspector's records clearly includes recorded data for i acceptability and rejectability. Prior to the NRC Inspection, in an in-house letter, L. K. Comstock's Project Quality Control Manager clarified the level of review to be completed when Level I and Level II inspectors sign reviews. These clarifications will be incorporated into all applicable L. K. Comstock procedures. We further believe that the actual practice of a Level II signing for a Level I has been in accordance with ANSI N45.2.6.
DATE OF COMPLETION Applicable L. K. Comstock procedures are expected to be revised by March 30, 1984.
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ITEM 2. EXAMPLE 3.B.(8) (continued)
Procedure 4.8.5, " Inspection of Class lE Safety-Related Cable Pan Installation", Revision A, dated February 4, 1983.
A review of Work Procedure 4.8.5, and Specification F/L 2790 indicates that this procedure does not adoress the following inspection attributes:
a.
verification that cables are not damaged and that the cable
. pans are free of all debris prior to installation of cable pan covers.
This item is covered in work procedure 4.3.5.
- b. verification that cable pan covers are installed in accordance with specifications, drawings, and standards.
This item is covered in work procedure 4.3.5.
c.
verification that the horizontal hanger member bolts are torqued per Project requirements.
RESPONSE
Inspection attributes a and b above were discussed under our response to non-compliance Item 2.a and 2.b.
Concerning inspection attribute c, Commonwealth Edison Company acknowledges that the Inspection Procedure 4.8.5 did not clearly address the attribute concerning the verification of the tightening of horizontal member bolts per Specification F/L 2790 (the Project requirements).
Inspection Procedure 4.8.5 did require that an inspection tight".
be made to verify that the " bolt connections are The general reference section in Inspection Procedure 4.8.5 does include a listing of the Installation Procedure 4.3.5 which explicitly the horizontal' gave member hanger the torque values to be used when installing bolts. Commonwealth Edison Company believes that sufficient direction has been given to the inspectors because QC inspectors are trained to inspect the bolts per the criteria value in the Installation Procedure 4.3.5 which provides torque requirements. However, to address the NRC's concern, the Inspection Procedure 4.8.5 is being revised to include, in addition to the existing reference to Installation Procedure 4.3.5, the explicit torque values contained in it.
CORRECTIVE ACTION TAKEN AND ACTION TAKEN TO AVOID FURTHER CONCERN Revise L. K. Comstock Procedure'4.8.5 to include, in addition to the existing reference to Installation in it.Procedure 4.3.5, the explicit torque values contained DATE OF COMPLETION Revisions are expected to be completed by March 30, 1984.
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-ITEM 2 EXAMPLE 3.B.(9) ,
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This example was discussed under our response.to non-compliance !
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- ITEM 2, EXAMPLE 3.8 (10)
This example was discussed under our response to non-compliance Item 2.d.
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ITEM 2, EXAMPLE 3.B.(ll)
Example 3.B.(ll) identifies 4 items involving Procedure 4.3.8,
" Cable Installation" Revision B, dated July 20, 1983. It should be noted that the third and fourth items deal with precautions for pulling small cable and the use of cable grips in vertical conduit runs which are each addressed in our response to example 2.e.
Item (1) - Paragraph 3.1.4 - This paragraph does not define the term " Cable Pull and Termination Report" as required by Paragraph 3.1 " Definitions".
Item (2) - Paragraph 3.2.7.2 " Pulls Through Conduit", this paragraph does not require the field to advise the Engineering Department of the cable or cables being pulled and the diameter of the smallest sheave used in the run. Without this information, the engineers cannot perform valid cable pull tension calculations as required by this paragraph. It should be noted that the field is required to provide this information for power assisted cable pulls ,
through cable tray.
RESPONSE / CORRECTIVE ACTION TO BE TAKEN Commonwealth Edison Company admits that Paragraph 3.1.4 does not define the term " Cable Pull and Termination Report" as required by Paragraph 3.1 - Definitions. Paragraph 3.1.4 will be revised to include a definition of the " Cable Pull and Termination Report".
Commonwealth Edison Company has always interpreted the language in Paragraph 3.2.7.2 to require that the smallest sheave size used for any power pull be reported to the Engineering Department.
- Calculation cards are available to demonstrate this. However, Procedure 4.3.8 will be revised to explicitly state " Power Pulls in l Conduit" shall have the same constraints as " Power Pulls in Cable Tray".
DATE OF COMPLETION i
Revisions to Procedure 4.3.8 incorporating these changes are expected to be completed by March 30, 1984.
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ITEM 2, EXAMPLE 3.B.(12)
Procedure 4.8.8, " Cable Installation Inspection", Revision dated August 19, 1982.
Paragraph 3.2 states in effect that prior to pulling cable, the Quality Control Inspector shall verify that the raceway is clean of all debris, correctly identified, conduits do not exceed a total of 2700 of bends, tension meter is correctly rigged and that the cable installation foreman has initialed the back of the cable pull card to signify that he has performed a pre-pull inspection per Work Procedure 4.3.8. This paragraph or cable pre-pull inspections do not address:
- a. verification that raceway is free from sharp edges,
- b. verification that edge softners are properly installed,
- c. the witnessing of embedded conduits being swabbed prior to pulling cable,
- d. verification that authorized scaffolding built on the raceway system will not damage the cable (s) being installed,
- e. verification that the cable to be pulled is of the proper type and identified in accordance with the cable pull card,
- f. verification that cable pull calculations, if l required, are available, l
l g. verification that the temperature limitation for pulling cable have been met,
- h. verification that the cable pull is properly rigged and that-the' raceway is complete and supported to the point that the raceway will properly support the cable (s) to be installed.
Paragraph 3.2.3 should be re-numbered in that this paragraph addresses cable pulling inspection, not pre-pull inspections. This paragraph fails to address the following cable pulling inspection attributes:
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- a. verification that cables are in fact installed in the raceway designated on the cable pull card and that the cable and raceway have the same segregation code marker, i.e., PlE, P2E, C1E, C2E, etc. There is a Quality Control signoff on the front of the cable pull card but the only reference to this signoff is in Paragraph 3.2.4 which states, in part, "At the completion of the pull verify that the cables:
(3.2.4.4) Pull card has been filled out correctly and signed / initialed in the applicable sections",
- b. verification that cables were not subjectea to reverse bends, kinks, twists, etc.,
- c. verification that the as-received cable is not damaged. This verification / inspection is normally done when the cable is being removed from the reel for installation.
Paragraph 3.2.4 should be re-numbered in that this paragraph addresses cable post-pull inspection, not pre-pull inspections. This paragraph fails to address the following cable post-pull inspection attribute:
- a. verify tht cable grips have been installed, when required, in vertical raceway in accordance with Sargent and Lundy STD-EB-200.
Form 37-QC Cable Pulling Checklist:
A review of this form indicates that it is being utilized for pre-pull, pull, and post-pull inspections. The inspection attributes listed on this form do not match the attributes listed in the body of the procedure. Also, as noted above, many required inspection attributes are not addressed in the body of the procedure.
[ The licensee was informed that the observations in sub-paragraph
! (12) above are additional examples of an item of non-compliance with Criterion V of 10 CFR 50, Appendix B, failure to assure that
! activities affecting quality are prescribed by documented instructions or procedures (50-456/83-18-03E; 50-457/83-17-03E).
RESPONSE
Commonwealth Edison Company admits tnat Procedure 4.8.8 did not explicitly categorize all of the items described above as pre-pull, pull, and post-pull inspection activities.
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- While all of the requirements and statements in both the installation and inspection procedures are not Quality Control checklist items, or in the sequence that the NRC desires, most of the NRC listed items under this Example 3.B.(12) are identified in L. K. Comstock procedures. (The sole exception is that the verification of the swabbing of embedded conduits is not always necessary prior to pulling.) However, to address the NRC's concern, we will revise the procedure so that the actions are taken and in the order suggested by the NRC.
CORRECTIVE ACTION TO BE TAKEN Revise L. K. Comstock Inspection Procedure 4.8.8 with applicable enhancements as determined by the Commonwealth Edison Company Project Construction Department.
DATE OF CORRECTIVE ACTION Revisions are expected to be completed by March 30, 1984.
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ITEM 2 EXAMPLE 3.D.(1).g.
During a review of MCC 1AP26E feeder cable LAP 146(PIE) for proper termination to the unit busbar, it was observed that the feeder cable appeared to be properly terminated. During a review of Quality Control Inspection Checklist of Electrical Terminations, Form 36, it was observed that the checklist indicated that the feeder cable terminations to the busbar had been landed, bolted finger tight and left untaped in accordance with Paragraph 3.5 of Procedure 4.8.9. Paragraph 3.5 requires power cable connections at the switchgear end be landed, bolted finger tight and left untaped to assist Commonwealth Edison Company Testing Group (OAD). For these type cases and in accordance with Paragraph 6.4, the L. K.
Comstock Cable Engineer will issue a Cable Determination Card when OAD is ready to test the cable and a Cable Termination Card when the tests have been completed and the cable is ready to be re-terminated. The Cable Engineer is also responsible for transmitting the Determination and Termination Cards to Quality Control for inspection. A review of the records indicate that a Cable Determination-Card and Cable Termination Card were not issued for feeder cable 1AP146(PlE). This resulted in a power feeder cable being terminated without Quality C:..rol inspection.
The licensee was informed that this is an additional example of an item of non-compliance with Criterion- V of 10 CFR 50, Appendix B, failure to accomplish activities affecting quality in accordance with documented instructions and procedures (50-456/83-18-03F).
RESPONSE
Commonwealth Edison Company admits that in the instance cited in the example 3.D. (1).g, procedures were not followed for one termination point on feeder cable 1AP146(PlE) so that a Cable Termination Card was not issued. (It should be noted that investigation revealed that a Cable Termination Card was issued for the other end of Cable 1AP146(P1E). Surveillance No. 1042 was performed on February 17, 1984 by L. K. Comstock Quality Assurance to verify proper usage of term and determ cards as prescribed by the procedures. The results have confirmed that procedures are being followed for other cables.
CORRECTIVE ACTION TAKEN MCC 1AP26E was de-energized cn March 1, 1984. L. K. Comstock Quality Control has completed their required inspections.
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CORRECTIVE ACTION TAKEN TO PREVENT RECURRENCE Commonwealth Edison Company Operational Analysis Department was advised of the need to assure that L. K. Comstock Quality Control is present to witness the final installation / inspection.
Commonwealth Edison Company Project Construction Department reviewed the results of Surveillance No. 1042 dated February 17, 1984 performed by L. K. Comstock Quality Assurance to verify that procedures for term and determ cards were followed for other cables.
DATE OF COMPLETION L. K. Comstock Quality Control has completed their required inspection on March 1, 1984.
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. - a VIOLATION 3 10 CFR 50, Appendix B, Criterion X, as implemented by Commonwealth Edison Company Topical Report CE-1-A, Section 10, requires a program for inspection of activities affecting quality to verify conformance with instructions, procedures, and drawings.
Contrary to the above, the following examples were identified:
- a. Commonwealth Edison Company failed to verify that approximately 30 - 40 cable grips in cable tray risers 1R267-ClE, 1R270-KlE, and 1R311-ClE were installed in accordance with S & L Standard STD-EB-200 and L. K. Comstock Procedure 4.3.8.
- b. Commonwealth Edison Company failed to identify damaged lower braces and missing cross bars inside MCC 1AP26E in accordance with L. K. Comstock Procedure 4.8.13.
- c. Commonwealth Edison Company failed to verify that Class lE cable 1CV036 was terminated per design documents. The caole conductors were erroneously marked as spare conductors.
Records indicate that the termination of this cable had been inspected and accepted by L. K. Comstock Quality Control.
- d. Commonwealth Edison Company failed to verify that Ty-Raps, bolts, screws, metal bracing, etc., had been removed from the interior of MCC 1AP26E in accordance with L. K. Comstock
, Procedure 4.8.13, Paragraph 3.1.7.
- e. Commonwealth Edison Company failed to verify that inspections had been performed in accordance with L. K.
Comstock Procedures 4.8.3, 4.8.6, 4.8.13, and 4.8.17 as evidenced by:
(1) 30 of 68 items reviewed had no records to indicate i that Quality Control had performed an installation l inspection.
(2) 27 of 50 items reviewed had no records to indicate
! that PTL had performed an inspection of the concrete expansion anchors.
(3) 125V DC panel 1DC05E had no records to indicate that l PTL had performed an inspection of the concrete l
exoansion anchors.
I (4) 19 of 19 electrical penetration inspection records did not provide actual torque values for the mounting bolts and did not indicate the torque wrench number (nor calibration due date) utilized to perform the torquing operation.
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Additional details are delineated in attached Inspection Report 50-456/83-18; 50-457/83-17, Paragraphs 3.D.(1),i and 3.D.(2).
This is a Severity Level IV violation (Supplement II.D).
RESPONSE
The following provides the Commonwealth Edison Company response to each example cited under non-compliance Item 3.
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l 3.a Commonwealth Edison Company failed to verify that approximately 30-40 cable grips in cable tray risers 1R267-CIE, 1R270-KlE, and ,
1R311-ClE were installed in accordance with S&L Standard STD-EB-200 '
and L. K. Comstock Procedure 4.3.8.
RESPONSE
Commonwealth Edison Company acknowledges that 30 to 40 cable grips ,
were not correctly in place on cable tray risers 1R267-ClE, 1R270-KlE and 1R311-ClE as noted in example 3.a. These loosened grips required tightening. Commonwealth Edison Company believes that these grips were properly installed initially in accordance with S&L Standard STD-EB-200 and Procedure 4.3.8, but became disengaged during subsequent construction activity. It is not unusual for the repositioning of cable to cause cable grips to move from previously set positions. To date, no damage to any cable has been identified resulting from loose cable grips. However, as discussed below, Commonwealth Edison Company has taken action to reposition the actual cable grips cited and will assure this condition is identified and corrected on all other cable grips.
CORR't C'TV_F_ ACTION T AKEN AND ACTION T AKEN TO PREVENT RECURRENCE Immediately after being informed of the cable grip deficiencies, necessary steps were taken to reset the questionable grips. Also, included as part of an ongoing survey of all cable grips was the need to check for proper cable grip setting.
After cable work is complete and cable pan cover installation is ,
underway, an additional check of cable grip setting will be made to confirm proper setting or to reset cable grips for proper setting as necessary. For any newly installed cable grips, procedures will be revised to require field and Quality Control personnel to check previously installed cable grips for proper setting.
DATE OF COMPLETION Revisions to the L. K. Comstock procedures are expected to be completed by March 30, 1984.
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3.b Commonwealth Edison Company failed to identify damaged lower braces and missing cross bars inside MCC 1AP26E in accordance with L. K.
Comstock Procedure 4.8.13.
RESPONSE
Commonwealth Edison Company did not identify the damage inside MCC 1AP26E in accordance with L. K. Comstock Procedure 4.8.13. The missing brace was laying on the bottom of the MCC and was subsequently reinstalled. Commonwealth Edison Company NCR No. 588 was issued to determine the function of, and requirement for the brace as to whether replacement or repair of the bent portion is necessary.
CORRECTIVE ACTION TAKEN TO PREVENT FURTHER OCCURENCE L. K. Comstock Quality Control Department held additional training sessions with Quality Control Inspectors. During the sessions, their inspection responsibilities / requirements stated in Procedure 4.8.13 were reviewed to assure that if similiar problem are discovered, that they are reported.
DATE OF CORRECTIVE ACTION Commonwealth Edison Company NCR No. 588 was issued on January 5, d 1984 and is expected to be closed by March 30, 1984.
Training sessions for L. K. Comstock inspectors were held on January 13, 1984 and January 20, 1984.
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3.c Commonwealth Edison Company failed to verify that Class lE cable 1CV036 was terminated per design documents. The cable conductors were erroneously marked as spare conductors. Records indicate that the termination of this cable had been inspected 8.1d accepted by L.
K. Comstock Quality Control.
RESPONSE
The conductors of Class 1E cable ICV 036 were erroneously marked.
Design documents require cables ICV 587 and ICV 036 to be terminated at the same terminal point. During the initial installation, both the terminator and inspector failed to properly mark and terminate the cables correctly. We believe our Operational Analysis Department (OAD) would have detected this error during electrical testing, which had not yet been performed.
CORRECTIVE ACTION TAKEN L. K. Comstock Management personnel discussed the nature of the error made with both the terminator and inspector. Both individuals were knowledgeable with the requirements of their procedures and design drawings. Commonwealth Edison believes that this occurrence is not representative of the field work of these and other individual L. K. Comstock personnel.
DATE OF CORRECTIVE ACTION Corrective action was completed and L. K. Comstock Inspection Correction Report (ICR) was closed on November 14, 1983.
3.d Commonwealth Edison Company failed to verify that Ty-Raps, bolts, screws, metal bracing, etc., had been removed from the interior of MCC 1AP26E in accordance with L. K Comstock Procedure 4.8.13, Paragraph 3.1.7.
RESPONSE
Ty-Raps, bolts, screws, and metal bracing had not been removed from the interior of MCC 1AP26E in accordance with procedures. The Commonwealth Edison Company Project Construction Department is concerned with housekeeping matters, and had previously initiated a site-wide program to address the problem, as discussed below.
CORRECTIVE ACTION TAKEN AND ACTION TAKEN TO PREVENT RECURRENCE MCC 1AP26E was cleaned prior to the NRC inspector leaving the site. All similar equipment will be reinspected and cleaned or protected as necessary.
As part of the site-wide program, various G. K. Newberg and L. K.
Comstock procedures provide for housekeeping activities, and Commonwealth Edison Company requires Pittsburgh Testing Laboratory (PTL) Inspectors assigned to the Project Construction Department to perform monthly checks of all insta] led-equipment. Any housekeeping deficiencies identified are reported and resolved by applicable craft personnel. For equipment turned over to the Operating Department, inspections are performed by the Tech Staff and Startup Group personnel to assure adequate plant housekeeping continues.
DATE OF CORRECTIVE ACTION On February 5, 1984, memorandum TS-509 was issued to Operating Department personnel informing them of their responsibility concerning housekeeping.
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3.e Commonwealth Edison. Company failed to verify that inspections had been performed in accordance with L. K. Comstock Procedures 4.8.3, 4.8.6, 4.8.13 and 4.8.17 as evidenced by:
Issue (1) 30 of 68 items reviewed had no records to indicate that Quality Control had performed an installation inspection.
Issue (2) 27 of 50 items reviewed had no records to indicate that Quality Control had performed a welding inspection.
Issue (3) 125V DC panel 1DC05E had no records to indicate that PTL had performed an inspection of the concrete expansion anchors.
Issue (4) 19 of 19 electrical penetration inspection records !
did not provide actual torque values for the mounting bolts and did not indicate the torque wrench number (nor calibration due date) utilized to perform the torquing operation.
Additional details are delineated in attached Inspection Report 50-456/83-18; 50-457/83-17, Paragraphs 3.0.(1).1 and 3.D.(2).
RESPONSE TO ISSUES (1) AND (2)
Commonwealth Edison Company is aware of the requirements to assure that timely inspections are performed in accordance with L. K.
Comstock procedures and that results are retrievable. The issues set forth above were identified while Commonwealth Edison and L. K.
Comstock were involved in a major effort to reorganize records for more efficient retrievability, and identification of those areas in which records were deficient. Commonwealth Edison admits that during the NRC inspection the records cited above were not accessible. However, subsequent to the NRC inspection, and because of our record reorganization effort, the records identified in the example as missing, were either located or information sufficient to reconcile and reconstitute them was obtained. In some cases, the inspection record was incomplete and inspections were performed.
CORRECTIVE ACTION TAKEN AND ACTION TAKEN TO PREVENT REOCCURRENCE As early as March, 1982, Commonwealth Edison Company Quality Assurance audits and the Technical Support Evaluation of September, 1982, identified deficiencies indicating the need to improve the L.
K. Comstock documentation / filing system.
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As a result of identified deficiencies Commonwealth Edison Company determined that improvements were needed in the areas of:
- 1. Timeliness of records retrievability.
- 2. Better accountability of the production records which support the status of installation.
- 3. Reconciliation of use of previously used outdated forms.
In October 1982, it was determined that progress was poor in the document review. In November 1982, the L. K. Comstock Quality Control Manager was replaced because he lacked administrative abilities. However, poor progress in the document review continued. In March 1983, the Commonwealth Edison Company Project Construction Department held a meeting with L. K. Comstock's Regional Vice President and in April 1983, with L. K. Comstock's
' Executive Vice President, Corporate Quality Assurance Manager and Regional Vice President to discuss the poor progress being made on the ducument review. As a result, L. K. Comstock committed to provide four (4) inspectors to complete the document review and provide a plan for completion.
The plan to complete the review was submitted to Commonwealth Edison Company for concurrence on March 9, 1983. The plan's scope and depth was to reconcile audit deficiencies of document retrievability, as well as assuring record completeness and correctness.
In June 1983, the Commonwealth Edison Coinpany Project Construction Department and Quality Assurance met with L. K. Comstock to discuss the status of the document review. It was determined that L. K.
Comstock was not proceeding as scheduled to meet the September 1983 completion date. As a result of the June meeting, Commonwealth Edison Company again replaced the L. K. Comstock Quality Control Manager, with intent to more adequately organize and com,lete the document review as projected for February 1, 1984.
The corrective measures which provide improvements to the L. K.
Comstock document system were presented to the NRC (Messrs. Little, Williams and Love) on November 3, 1983 and the program was mentioned on December 20, 1983 during the Enforcement Conference.
Subsequently, on January 31, 1984 Commonwealth Edison Company Project Construction reported to the NRC a potential 50.55(e).
L. K. Comstock is 100% complete with their review of all documents on file. The updated status reports concerning the completion of the required L. K. Comstock activities are available on-site for ss the Region's review.
In addition to the actions described above, the Commonwealth Edison Company Project Construction Department has authorized the use of a computerized tracking system. This system will be used to document the status of installation and inspections. To prevent incomplete or unacceptable documents from being filed, L. K. Comstock has provided for a 3-level review. Lead Inspectors are responsible for reviewing all documents initiated in their areas of responsibility. The Supervisor of Inspectors provides a second level management review. It is his responsibility to determine whether additional direction or clarification is needed to be given to inspectors who continue to improperly fill out reports.
Finally, all documents are reviewed'by Document Control before they are filed.
DATE OF COMPLETION L. K. Comstock estimated date of completion for their document review is May 1, 1984.
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" ITEM 3e, ISSUE (3)
Issue (3) 125V DC panel 1DC05E had no records to indicate that PTL had performed an inspection of the concrete expansion anchors.
RESPONSE TO ISSUE (3)
The NRC finding that no inspection records ex.ist for the installation of anchor- bolts on panel 1DC05E is correct. However, this panel is not anchor bolted to the floor but welded per the requirements of Sargent and Lundy equipment attachment detail drawing. Weld inspection records are available for review.
Confusion may exist with regard to the identity of the panel in question. Adjacent to panel 1DC05E is 1DC03E which is anchor bolted. Panel 10C03E was inspected on July 7, 1982 per the applicable requirements of L. K. Comstock Procedure 4.8.13. All inspections are complete.
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ITEM 3e, ISSUE (4)
Issue (4) 19 of 19 electrical penetration inspection records did not provide actual torque values for the mounting bolts and did not indicate the torque wrench number (nor calibration due date) utilized to perform the torquing operation.
RESPONSE TO ISSUE (4)
Commonwealth Edison Company admits that penetration records did not provide actual torque values for mounting bolts and did not indie le the torque wrench number utilized. Actions are being taken to prevent recurrence of these omissions.
Commonwealth Edison Company believ?s that L. K. Comstock procedures and method of inspection using qualified inspectors to verify torque values provide assurance that the correct torque values and calibrated instruments were actually used in the field.
Inspection of the installation of electrical penetrations was completed during an in-process inspection. Verification that craft personnel used calibrated wrenches and torqued penetration bolts to
, the requirements of Procedure 4.3.17, Table 5-10 was witnessed by a qualified L. K. Comstock Quality Control inspector. Even though torque wrenches were.not recorded on inspection checklists, L. K.
Comstock QC subsequently determined that wrenches A181 and 837 were used during the installation. Their review of calibration records showed that these wrenches were in calibration at the time of use.
CORRECTIVE ACTION TAKEN TO PREVENT RECURRENCE L.K. Comstock has revised their inspection procedure. Specific
. signoff points have been provided, indicating what torque wrench was used and date of calibration.
DATE OF COMPLETION l
y Final acceptance was granted on February 6, 1984.
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VIOLATION 4
-10 CFR 50, Appendix B, Criterion XIII, as implemented by l
Commonwealth Edison Company Topical Report CE-1A-A, Section 13, requires measures to be established to control the storage and i preservation of material and equipment.
Contrary to the above, the following examples were identified:
- a. ~ Inside the Unit 1 Containment Building at elevation 397',
near cold leg Number 3, a 2" pipe was being temporarily supported by safety-related conduit ClR2329-1P2E. This support!was at about a 450 angle, indicating that the piping contractor may have installed this support to '
position the pipe for welding.
- b. Inside Unit 1 Containment Building at elevation 412', radius R12, Instrument Rack IPL71J was being utilized to support two (2) step ladders. The step ladders were chained inplace
- so it was no possible to inspect the instrument rack for damage.
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This is a Severity Level V violation (Supplement II.E).
RESPONSE / CORRECTIVE ACTION TAKEN AND DATE ACHIEVED Commonwealth Edison Company Project Construction Department acknowledged the inspector's concern at the time of the audit and immediately removed the temporary support and two (2) step ladders. No damage resulted to-any component as a result of the observed condition.
As previously indicated in' aur response to Example 3.d, Commonwealth Edison has instituted a housekeeping program for the protection of equipment from damage. The Coiamonwealth Edison Company Project Construction Department requires Pittsburgh Testing
' Laboratory (PTL)' inspectors assigned to the Project Construction Department to perform monthly checks of all installed equipment.
These. personnel were reminded of the need to report all unauthorized use of equipment.
J 4-i' l ENCLOSURE 2 ADDITIONAL INFORMATION TO ASSIST THE REGION IN EVALUATING THE EFFECTIVENESS OF COMMONWEALTH EDISON
-AND L. K. COMSTOCK ORGANIZATIONS IN ACCOMPLISHING
-ELECTRICAL CONSTRUCTION ACTIVITIES AT BRAIDWOOD STATION e
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1 CORDELL WILLIAMS REQUEST FOR ADDITIONAL INFORMATION A. L. K. Comstock Management Organization L. K. Comstock's site management organization consists of three (3) independent organizations: Production, Quality Control and Quality Assurance. Independence of these organizations is shown in the attached organizational charts (Attachments 1 and 2).
The Project Manager directs production activities and reports to the Central Region Vice President. Quality Control activities are directed by the Quality Control Manager. Both the Quality Control Manager and Quality Assurance Engineer reports to the Central Region Quality Control Services Manager. As required by Commonwealth Edison Company, and demonstrated in the L. K. Comstock Quality Assurance Manual, both quality organizations are free to implement the L. K. Comstock Quality Assurance Manual through inspections, surveys and audits of the site installation and inspection procedures.
- 1. Production Organization Reporting to the Project Manager are the Project Engineer and seven (7) Area Managers.
- a. Thirty-three (33) people consisting of Engineers and Document Control personnel report to the Project Engineer. Their primary responsibilities are as follows:
- 1) Aid in the solution to field problems;
- 2) Recommend corrective action to contractor NCRs;
- 3) Control all records pertaining to cable pulling and terminating;
- 4) Calculate maximum allowable cable pull tension;
- 5) Control the issuance of drawings to the field;
- 6) Review drawings and procedures to assure that specification requirements are adequately addressed.
- b. Area Managers' primary responsibilities are as follows:
- 1) Supervise craft personnel;
- 2) Assure that procedural and schedular commitments are met;
- 3) Assure that work is completed per drawing specification and/or work instructions; Currently, craft manpower averages 496 personnel with projections of increasing to 520 by mid-year. Although the number of current Engineering, Craft Supervisory and Craft Personnel is adequate, the Commonwealth Edison Company Project Construction Department will continue to monitor the need for additional personnel to assure that procedural and schedular commitments are met.
For all primary craft production activities, training sessions are presented to all craft personnel at the beginning of their employment. Welders require the most extensive training and qualification. Cable pullers and terminators require indoctrination / training to the requirements established in applicable procedures. As part of their training sessions, basic Quality Assurance / Quality Control ideas such as, necessity of reporting non-conforming conditions, responsibility with respect to hold tags, and the requirement of not deviating from drawings or procedures unless authorized by appropriate documents are presented.
Besides the initial training sessiens, follow-up/ additional sessions are presented, as needed, to highlight specific concerns or clarifications. All training sessions are documented and filed in the L. K. Comstock Project Engineering office.
The Commonwealth Edison Company Project Construction Department is reasonably assured through Quality Assurance audits, that craft personnel are aware of Quality Assurance / Quality Control controls and will continue to monitor the need for additional training.
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- 2. Quality Control and Quality Assurance Organization
- a. Quality Control activities are directed / supervised by the Manager and Assistant Quality Control Manager.
Two (2) new supervisory positions, " Supervisor of Inspectors" and " Lead Inspector" were established to better manage inspection activities. Personnel selected for these positions were generally senior inspectors with the Project who are thoroughly familiar with specification, drawing and procedural requirements. Commonwealth Edison Company Project Construction is confident these new positions and personnel selected to fill these positions will provide additional uniformity of inspection between all Comstock inspectors.
Currently the L. K. Comstock, Quality Control organization consists of sixty-nine (69) people. The field inspection force has more than doubled from twenty-two (22) to fifty-one (51) and the overall department increased from twenty-five (25) to sixty-nine (69) as shown on the attached organizational chart (Attachment 3). This increase represents, one (1) inspector for every 7.1 craft personnel.
Commonwealth Edison Company Project Construction is confident that the number of Quality Inspectors is adequate to assure that timely inspections are performed and that the number of backlogged inspections is reduced. To maintain this confidence, Project Construction plans to monitor the progress and closecut of L. K. Comstock open items (NCR, ICR, etc.) and corrective actions. Further, the L. K.
Comstock Quality Control inspector workforce will be monitored to assure that it is adequately staffed to address any additional work resulting from the document review, while staying current with all other work.
- b. Commonwealth Edison Company Project Construction is ultimately responsible for assuring that contractor quality programs are carried out. Besides Commonwealth Edison Company scheduled audits and surveillances, L. K. Comstock Quality Assurance organization is responsible, as a minimum, to audit their entire Quality Assurance program on a yearly basis. In addition, L. K. Comstock site Quality Assurance Engineers are responsible to perform audits and surveillances to a plan concurred in by l
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Commonwealth Edison Company Quality Assurance. The plan requires audits and/or surveillances of all site procedures. Currently, two (2) L. K. Comstock certified quality auditors are assigned to the Braidwood Project. Based on the total Quality Assurance program of L. K. Comstock, Project Construction is confident that work is accomplished in accordance with the requirements of drawings, specifications and procedures.
B. Braidwood Project Interface Responsibility for overall design and design implementation of electrical systems is assigned to the Commonwealth Edison Company Project Engineering Department, Site or Chicago Office.
Responsibility for certain phases of design has been delegated to Sargent and Lundy. The Commonwealth Edison Company Project Construction Department is responsible for constructing and has no design responsibilities. Certain con:.truction responsibilities have been assigned to L. K. Comstock Engineering Department. The Braidwood Project executes these responsibilities in accordance with the requirements and procedures described in the Commonwealth Edison Company Quality Assurance Program.
Because of desirable experiences gained at other Company projects, Commonwealth Edison Company believes the development of on-site Engineering (CECO and Sargent and Lundy), and the use of L. K.
Comstock Engineering personnel are efficient and positive steps to assure that Project Construction activities are performed in a quality and timely manner.
- 1. Site Project Engineering Interface Per the requirements of the Commonwealth Edison Company Quality Assurance Manual, the Project Field Engineering Manager is responsible for:
- a. Engineering design implementation;
- b. Reviewing ~ systems for modifications and deficiencies;
- c. Resolving. construction problems;
- d. Coordinate and oversee the Sargent and Lundy field group.
These responsibilities are similar to those of personnel at the Chicago Office. As needed, site personnel may obtain input from other departments and organizations to resolve daily problems.
Sargent and Lundy Electrical Field Engineering personnel currently total 80 and have the same responsibilities as their counterparts at the Sargent and Lundy Corporate Office. As a minimum, these include the following items:
- a. Determine routing of unrouted cables;
- b. Prepare and review electrical installation drawings;
- c. Process wiring drawing changes and resolve wiring drawing discrepancies identified by Commonwealth Edison Company;
- d. Process Field Change Requests and Engineering Change Notices;
- e. Process Commonwealth Edison Company and contractor NCR's.
Control of all these responsibilities is described in specific Sargent and Lundy site procedures and Commonwealth Edison Company quality procedures. The procedures govern Sargent and Lundy involvement in resolving field matters and formal documentation of the resolution. While they cover a variety of possible interchanges between Sargent end Lundy engineers and site contractors, as well as Sargent and Lundy and Commonwealth Edison personnel, the primary contact is in the latter area. To the extent that certain computer systems and information is located off-site at Sargent and Lundy Corporate offices, the on-site Sargent and Lundy engineering personnel may refer questions for resolution to their off-site office. If in fact a question is so referred, procedures parallel to those used on-site for interface and documentation are employed.
- 2. Project Construction Interface L. K. Comstock Engineering activities are directed by the Commonwealth Edison Company Project Construction Department. Similar to Project Engineering, Project Construction responsibilities are described throughout l applicable sections of the Company Quality Assurance Manual.
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In addition. to the responsibilities previously listed for the L.:K. Comstock-Engineering personnel,1 Commonwealth
. Edison Company Project Construction personnel, as a minimum, are responsible for the following:
.a.. Coordinate construction. activities (schedules, manpower, etc.);
- b. . Review and implement contractor procedures;
- c. Monitor Contractor-Quality Control procedures; d.- Evaluate and implement methods to increase contractor efficiency.
.e. Evaluate and oversee the installation of equipment to assure that design' specifications are met and minimize conditions that would result in NCR's;
- f. Review, suggest solutions and follow-up, to assure.
closecut to field problems; 13 Provide interface with the NRC.
These responsibilities / functional relationships are
' described in:the Ccmpany Quality Assurance Manual, Project Construction Department procedures, and n'umerous contractor >
.prncedures.
- Inisummary, we beleive that the above described' upgraded L. K. Comstock
. organization and Commonwealth Edison Company controls through our ,
i interface described above will be effective in resolving the Region's concerns work. with L. K. Comstock Company and their ability to perform quality- !! '
Similarly, Commonwealth' Edison Company is satisfied with the scope and
- electrical' adequacyproblems of'the on-site in-the Sargent-and field. Lundy participation in resolving i f
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w ENCLOSURE 3 INTERIM RESPONSE TO UNRESOLVED ITEM NOS. 50-456/83-18-09; 50-457/83-17-06 1 b 8320N t r I I- [ l f
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( , RESPONSE TO UNRESOLVED ITEM NOS 83-18-09; 83-17-06 OBSERVATION 3.D.(1).h Utilizing Sargent and Lundy's Drawing 20E-0-3391C, Revision AB, and Westinghouse Drawing 2260C43, Revision 2, the Region III inspector reviewed the mounting of MCC 1AP26E. It was observed that these drawings do not specifiy a torque value for the 1/2 inch mounting bolts. Paragraph 3.6.1 of procedure 4.3.13, Revision A, " Equipment Installation Procedure", states, " Torquing of bolted conections shall be performed to torque values indicated on approved drawings , or manufacturers specifications". Utilizing a calibrated torque wrench, it was observed that the 1/2" mounting bolts were torquad to approximately 35 foot pounds. In that this is a safety-related, seismically supported motor centrol center, the licensee was requested to perform an engineering analysis to justify the lack of mounting bolt torquing requirements for this* unit and similar type units, e.g., switchgear, cabinets, panels, etc. The requirements of 10 CFR 50, Appendix A, Criteria 1 and 2, are required to be considered in the analysis. Pending a review of the engineering analysis, this item is unresolved (50-456/83-18-09; 50-457/83-17-06). The licensee was requested to respond to this item in the report transmittal letter. INTERIM RESPONSE This item is currently under review by the Commonwealth Edison Company. The review is expected to be completed by April 1984. Based upon the results of this review and existing field conditions, appropriate corrective actions will be taken. The results will be made available for the Region's review when available. 8320N I}}