ML20214C606

Affidavit of Pr Pelke Supporting NRC Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 14.B.2.Supporting Documentation Encl

ML20214C606
Person / Time
Site:	Braidwood
Issue date:	02/13/1986
From:	Patricia Pelke NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20214C321	List: ML20214C317 ML20214C330 ML20214C334 ML20214C358 ML20214C380 ML20214C409 ML20214C439 ML20214C451 ML20214C468 ML20214C496 ML20214C514 ML20214C526 ML20214C552 ML20214C569 ML20214C580 ML20214C583 ML20214C596 ML20214C606 ML20214C628 ML20214C676
References
OL, NUDOCS 8602210202
Download: ML20214C606 (23)

Text

- 158 -

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i

In the Matter of )

)

COMMONWEALTH EDIS0N COMPANY ) Docket Nos. 50-456

) 50-457 (Braidwood Station, Units 1 and 2 )

AFFIDAVIT OF PAUL R. PELKE IN SUPPORT OF NRC STAFF'S RESPONSE TO APPLICANT'S MOTION FOR

SUMMARY

DISPOSITION OF ROREM -QA SUBCONTENTION 14.B.2 I, Paul R. Pelke, being duly sworn, depose and state as follows:

1. I am employed as a Project Inspector in the Reactor Projects Section of the United States Nuclear Regulatory Commission, Region III, 799 Roosevelt Road, Glen Ellyn, IL 60137. I have been employed in this capacity since February 1983. A copy of my statement of professional qualifications is attached hereto as Exhibit 14.B.2-1.

2. As Project Inspector I am responsible for performing inspections to assure that the Braidwood Station is constructed in accordance with regulatory requirements.

3. The purpose of this Affidavit is to support the NRC Staff's i

response to Applicant's Motion For Summary Disposition of Rorem QA Subcontention 14.8.2. This subcontention states:

14. Contrary to Criterion XVIII, " Audits," of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that a comprehensive system of planned and periodic i

audits is carried out to verify compliance l with all aspects of the quality assurance program and to determine the effectiveness of i

i 0

- 159 -

the program. The Applicant also failed to ensure follow-up action, including reaudit of deficient areas. .

B. A special NRC QA inspection reported May 7, 1984 that: -

2. Electrical contractor L. K. Comstock Co./L. K. Comstock Engineering Company auditing activities neither conformed with the comprehensive annual schedule of planned and periodic audits established as required by QA Program Manual Section 4.14.1, nor did they verify compliance with all aspects of the Quality Assurance Program.

4. In preparing this Affidavit I reviewed the following documents:

a. Applicant's Statement of " Material Facts As To Which There

- Is No Genuine Issue To Be Heard" (On Rorem Subcontention 14.B, Part 2 - L. K. Comstock);

b. Testimony of Thomas E. Quaka (On Rorem Q.A. Subcontei. tion 14.B.2);

c. Inspection Report Nos 50-456/83009 and 50-457/83009; (pertinent portion of which is attached hereto as Exhibit 14.B.2-2);

d. Applicant's Jul'y 6, 1984 Response to Inspection Report l Nos. 50-456/83009 and 50-457/83009 (pertinent portions

attached hereto as Exhibit 14.B.2-3);

e. Inspection Report Nos. 50-456/85051 and 50-457/85049.

(pertinent portions attached hereto as Exhibit 14.B.2-4).

l 5. I agree with Applicant's Material Facts 13 through 27, all of which relate specifically to Rorem Subcontention 14.B.2. Also, I note that the numbers of the Inspection Report referred to in Applicant's Material Fact 27 are 50-456/85051 and 50-457/85049.

- 160 -

6. This violaticn was identified by Region III NRC Inspector ,

T. E. Vandel in Inspection Report Nos. 50-456/83009 and 50-457/83009.

Although this particular item was identified in June 1983, Inspection Report Nos. 50-456/83009 and 50-457/83009 was not issued until May 7, 1984.

7. In its response dated July 6, 1984 (the pertinent portion of which is attached as Exhibit 14.B.2-3.), Applicant acknowledged that L. K. Comstock did not fully implement its 1983 audit schedule.

Applicant ' stated that the applicable work procedures and quality co.ntrol inspection procedures had been audited by L. K. Comstock as of the week of January 9,1984. The Applicant placed two full-time, qualified auditors onsite. L. K. Comstock procedures were revised and L. K. Comstock site Quality Assurance had submitted an audit plan for 1984 which indicated that the Quality Assurance Program and their safety-related activities would be adequately covered.

8. I closed this violation in Inspection Report Nos. 50-456/85051 and 50-457/85049 (see Exhibit 14.B.2-4). I closed this item on the basis of the facts stated in Paragraphs 9-11.

9. First, I reviewed Applicant's QA S'urveillance No. 4852. This surveillance was expressly undertaken to verify that L. K. Comstock took appropriate corrective actions to remedy the violation. Applicant conducted 17 QA audits of L. K. Comstock from June 1982 through December 1983. These audits compensate for any auditing inadequacy on the part of L. K. Comstock. Applicant's QA audit program has been reviewed by the NRC and found to be acceptable in previous inspections.

- - . _ - , . . . , ~ - - -,. , - _ _ _ . - , - , . , , - - - - - _ _.-.--,,.w_ y --- - , . - . . - - - -

- 161 -

10. I reviewed audit schedules versus completed audits for 1984 and ,

1985 to verify that the L. K. Comstock QA program was adequately audited on an annual basis. L. K. Comstock conducted 33 internal audits in 1984 and 37 internal audits were scheduled to be conducted in 1985 at the time of my inspection. Two certified auditors have been in the L. K. Comstock organization since January 1984. At the time of my inspection, a third auditor was scheduled to be certified.

11. I specifically reviewed nineteen L. K. Comstock internal audits conducted in 1985 and eight L. K. Comstock Corporate audits conducted in 1984 and 1985. This review enabled me to to verify that L. K. Comstock is in compliance with applicable auditing requirements.

12. I identified one minor open item regarding the L. K. Comstock internal auditing program. L. K. Comstock Procedure 4.14.1, " Internal Audit Program," allowed " limited activity" procedures to be placed on a 24 month audit schedule. However, Regulatory Guide 1.144 states that applicable elements of the QA Program should be audited at least annually or at least once within the life of the activity, whichever is shorter.

It is my understanding that the Applicant has directed L". K. Comstock to revise Procedure 4.14.1 to bring it into conformance with Regulatory Guide 1.144. After verifying that L. K. Comstock has in fact so revised Procedure 4.14.1, this open item will be closed in a subsequent inspection report.

13. I agree with Applicant that the violation which forms the basis of Rorem Subcontention 14.B.2 is an isolated instance and does not l evidence a significant breakdown in Applicant's quality assurance l

l

- 162 - -

1 program. Consequently, there is no genuine issue to be litigated -

regarding Rorem Subcontention 14.B.2.

~

0P&ul R. Pelke Swornan(subscribedbeforeme ,

this /J-day of February,1986

.0nhe ./ 7' t Notary Public I ' " N I " 5CP' IO W 3 My Commission expires: -

e

g&;h JUl~l

- 163 -

\

Professional Qualifications .

PAUL R. PELKE 1

Organization: U.S. Nuclear Regulatory Connission, Region III

Title:

Reactor Inspector (Nuclear Engineer)

Birth Date: July 8, 1953 Education: B.S. Engineering (Nuclear), Purdue University,1974 M.S. Operations Management, University of Arkansas, 1979 Experience:

February 1983 to Reactor Inspector (Nuclear Engineer) - NRC, 4

Present Region III, Projects Inspector, Reactor Projects Section - Performs routine safety inspections, assists Section Chief with the regulatory management of assigned facilities.

February 1982 to Intern Resident Inspector - NRC, Region III, February 1983 Projects Inspector, Reactor Projects Section -

Performs routine safety inspections, assists Section Chief with the regulatory management of assigned facilities.

February 1981 to Intern Resident Inspector - NRC, Region III, February 1982 Operational Support Section. Tracks licensee reports and performance, assists with SALP appraisals.

December 1980 to Intern Resident Inspector - NRC, Region III,

~ February 1981 Reactor Operations and Nuclear Support Branch -

4 Nuclear Support Section 1 - Inspects reactors in operation, test, and startup phases.

1976 to Civil Engineer Corps Officer, U.S. Navy -

December 1980 Functioned as a facilities engineer and construction i

contract administrator at U.S. Naval shore establishments.

k t

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

h b b / 0 2- 2,.

U. S. NUCLEAR REGULATORY COMMISSION REGION III '

Reports No. 50-456/83-09(DE); 50-457/83-09(DE)

Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood - Units 1 and 2 Inspection At: Braidwood Site - Braidwood, IL Enforcement Conferences At: Region III Office, Glen Ellyn, IL Inspection Conducted: June 20-24, June 27-July 1, August 1-5, August 9, October 4-7, October 24, 1983, January 11-13, January 26, and February 9, 1984

~

Enforcement Conferences Conducted: December 20, 1983 March 7, 1984

~

WM af u, /g4 Inspectors: R. D. Schulz %

Date

. in 3 d'Y g ,  :\

T. E. Vandel J-J/ -h '

j Date ,

. t D. E. Keating

. Date Approved By: D. R. Hunter, Chief Y~t 4 /N Management Programs Section Date Inspection and Enforcement Conference Summary Inspection on June 20-24, June 27-July 1. August 1-5, August 9, October 4-7 October 24, 1983, and January 11-13, January 26, and February 9, 1984; and Enforcement Conferences on December 20, 1983, and March 7, 1984 (Report No. 50-456/83-09(DE); 50-457/83-09(DE))

i -

l -

~

l l

ff. MA 2 ~'

(3) The inspector observed a field-conducted on-the-job -

training session. A one-on-one training activity was being conducted. A Level II QC Inspector accompanying a' '

trainee while the trainee performed inspectio6 activity of cable terminations. The instruction by the Level II included'such parameters as: (a) how to locate terminal blocks involved, and (b) inspection of terminations for crimp, tightness, and location of conductor in crimp ferrel. A good exchange of information appeared to be taking place,

b. Auditina Performance (i) The LKCEI corporate auditing activity is performed on a quarterly basis to accomplish a complete program verification on an annual basis. The 1983 approved corporate office audit schedule for the Braidwood site was reviewed. The schedule, issued as a meno on March 18, 1983, listed four audits to be performed as follows:

Date of Audit Criteria to be Covered .

March 15, 1983 III, VI, XIV, XV ,

~

June ES, 1963 IX, XVIII September 20, 1983 X, XII, XVII December 6, 1983 I, II, V, XIII The first scheduled audit was performed on April 12-14, 1983 (report number CQA-313) and covered Criteria III, VI, XIII, XIV, and XV with no adverse findings being identi-fied. The inspector .also observed a memo which provide notice of the second audit, scheduled for June 28-30, 1983, covering Criteria IX and XVIII (delayed until a later date bec' use a of the inspection cover' age an progress during that period of time at the site). .

The inspector requested the corporate audit reports for the last half of 1982 for review. The reports and criteria covered j by the audits were reviewed by the inspector as follows.

I Audit Report Number Date of Audit Criteria Covered CQA-250 December 16-17, 1982 XIV & XVIII CQA-182 September 21-22, 1982 III, VI, & XII l'either the auditing coverage performed and'/or scheduled from mid-year 1982 through mid-year 1983 nor the audit schedule es'tablished for the year 1983 would provide complete program

,,/ verification coverage as prescribed by the QA manual.

O 35

hf. /Y.$ 2 -

(ii) The LXCEI internal auditing activity for Braidwood, beginning with audit report I-001, was reviewed by the .

inspector, r (1) The 1982 audit activity and results are tabulated as follows:

Number Date of Report Coverage Results Remarks 1

I-001 7-12-82 Storage, I finding Issue &

Control of Welding

, Material I-002 7-12-82 Housekeep- 2 findings ing & Pro- I concern tection of' Safety-Related Class IE Cable -

I-003 7-15-82 Control of -

Heasuring E'. -

Testing

. Equipment &

Calibration s/ of Torque Wrenches I-004 10-14-82 Cable In- 3 findings stallation

& Inspection .

I-005 7-22-82 Safety related

, cable pen in-stallation & ,

inspection -

procedures I-006 7-12-82 Nonconform- 2 findings ing Items 2 concerns I-007 8-6-82 Inspection of Class 1E safety-related conduit install-ations 1 .

1-008 8-25-82 Design Con- I concern trol

_s) I-009 9-1-82 Corrective 2 findings Action 2 concerns l

36

h /Yo $. 2. ~ "

\

Number Date of Report Coverste Results Remarks I-010 8-30-82 Welding -

inspection ,

I-011 9-10-82 Receiving, 2 findings storage, handling I-012 9-17-82 Installa- 2 findings tion of Class 1E equipment I-013 10-22-82 -

Electrical 1 finding termination installation inspection I-014 11-29-82 QA Manual 2 concerns Dist. & Control I-015 Revision LKC to schedule work requests for 1983 .

of safety re-lated equip-N ment I-016 10-22-82 Stop Work I-017 10-22-82 Electrical 1 finding j penetrations installation, terminations ,

and maintenanc'e I-018 11-3-82 . Welding pro- 6 findings

. cedure for i structural -

attachments .

& weld I inspection l

I-019 11-9-82 Concrete 1 find!ag expansion anchor installation Inspection of safety-related i CEA installations l w

l 1

I d

e O

6 37

W l

. \ Number Date of Report Coverage R,esults Remarks I-020 11-9-82 Powder actuated -

fastener install-ations &

inspections of actuated fastener in-stallations I-021 12-6-82 Safety related cable pan in- l stallation &

, inspection I-022 To Be Scheduled in 1983 I-023 12-2-82 Housekeeping receipt inspec-tion & storage I-024 12-3-82 Pointing release notice -

I-025 Qualification, Not

~ss calibration, per training of QC formed personnel & in 1982 QC records These .iudits varied in duration from one day audits to one that extended over a period from September 24, 1982, to October 21, 1982 (I-013). Report findings were deter-ained to be corrected and closed in a r'easonable time.

The worse case was report I-018, " Welding Procedures for Structural Attaghaents, and Weld Inspection". It con-tained six findings and two concerns requiring five months to close. The audit was done on November 3, 1982, with the concerns being closed out on April 4,1983. *

(2) The 1983 auditing activity began on January 2-6, 1983, with report number I-027. The audit activity and results, for the year 1983, are tabulated below.

Report No. Dates Coverage Results Remarks I-025 --

Qualification Report not

& Classification in file.

I-026 1/5-7/83 Control of 1 finding

, Special Proc- '

esses

..j O

38

h /YZ-2,

~%

. Report No. Dates Coverage Results Remarks 1-027 1/2-6/83 DC Storage 3 findings ,

Batteries &

Racks I-028 1/5-7,/83 SMAW Welding no findings ~

of Stainless Steel & Inspec- -

tion i

I-029 1/25-28/83 Stud Welding 3 findings

& Inspection I-030 1/19 thru Installation 2 findings 2/8/83 of Class IE Embedded Electrical Items

& Inspection I-031 1/21/83 Inspection of Rep. ort Notes MIG Welding of no aluminum Aluminum welding having

_ been performed.

-- I-032 --

Drawings & Specs. Report not in Document Control file.

Inspection Proce-dure I-033 --

Heat tracing Rescheduled, system Installa- no procedure tion & Inspection I-034 --

---.----- Voided, to be' scheduled 1ater (iii) The approved, issued audit schedule for the year 1983 .

provided for audits to be performed as follows: (1) four audits for January, (2) three audits for' February, (3) three audits for March, (4) two audits for April, (5) two for May, and (6) three audits for June. Of the seventeen audits scheduled to be performed during January through June of 1983, only five could be determined to have been completed with all five audits having been performed in January of 1983,

-and with no further auditing act.ivity performed.

The auditing activity performed by LKCEI failed to conform with the requirements established by the QA Program for a' comprehensive system of planned and periodic audits. This is an example of a violation of 10 CFR Part 50, Appendix B, Criterion XVIII (456/83-09-08(B),

,, ', , ,/

457/83-09-08(B)).

39 I

s Commonw:dth Edison hIb8.Z-3 h one best Nitionat Pius ch.cago m.no.. i (3/ Accress Riply to Post OIIce BF767 Chicago. liknois 60690 July 6, 1984 ,

Mr. James Ge Keppler Regional Administrator - Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Braidwood Station Units 1 and 2 Response to Inspection Report Nos.

50-456/83-09 and 50-457/83-09 NRC Docket Nos. 50-456 and 50-457 Reference (a): J. G. Keppler letter to J. J. O'Connor dated May 7, 1984

Dear Mr. Keppler:

This letter is provided in response to the inspection conducted by Messrs. T. E. Vandel, R. D. Schulz, I. T. Yin, D. E. Keating, C. C.

Williams, and D. R. Hunter on June 20-24, June 27-July 1, August 1-5, August 9. October 4-7, and October 24, 1983, and January 11-13, January 26, and February 9,1984 of activities at our Braidwood Station.

Reference (a) indicated that certain activities appeared to be in r.on-compliance with NRC requirements.

The Commonwealth Edison Company response to the Notice of Violation is provided as Attachment A to this letter. Our response to -

Unresolved Items 456/83-09-04 (A), 457/83-09-04 (A), 456/83-09-04 (B),

and 457/83-09-04'(B), and the description of our program to verify the quality of installed piping components is included as Attachment B to '

this letter. An extension of the response period was requested from W.

S. Little and R. F. Warnick of Region III on separate occasions, and extension was granted to July 6, 1984. We appreciate the extension of time given to us to respond to this matter.

Reference (a) revealed a number of deficiencies concerning the programs and procedures which had been established at Braidwood Station for the verification of correct material for ASPE piping components, control of HVAC welding activities, and design control of field routed small bore piping and associated hanger installation activities. Our responses to the items of non-compliance describe the changes and improvemeni.s which we have made to those procedures as a result of our intensive and comprehensive reviews of your findings and those of other inspections. The information provided in this submittal also serves to respond to the additional questions raised in the Reference (a) letter transmitting the Notice of Violation.

y)\.12

b/Y.02-3 i

l COMONEALTH EDISON COWANY  !

RESPONSE TO INSPECTION REPORT 50-456/83-09 and 50-457/83-09 ITEM OF NONCO WLIANCE: ,

4. 10 CFR 50, Appendix B, Criterion XVIII, as implemented by the Commonwealth Edison Company Quality Assurance Manual, QR No. 18.0, requires, in part, that a comprehensive system of planned and periodic audits be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program.

Contrary to the above:

a. Phillips, Getschow Company has not established and executed a plan for auditing the implementing procedures of the quality assurance program on a periodic basis to determine the effectiveness of the program in accordance with the PG Quality Assurance Manual, Section 16.

b. L. K. Comstock Company /L. K. Comstock Engineering Conpany auditing activities neither conformed with the comprehensive annual schedule of planned and periodic audits established as required by Quality Assurance Program Manual Section 4.14.1, nor did they verify compliance with all aspects of the Quality Assurance Program.

c. Pullman Construction Industries, Inc., did not meet their yearly schedule for audit activities required by their Quality Assurance Manual, Section 18, in that the following implementing procedures were not audited:

- B 3.1.F, Design Control

- B 5.1.F, HVAC Repair Adjustment

- B 9.3.F, Expansion Anchor Installation

- B 10.2.F, Visual Weld Inspection

d. The licensee's audits of the installation of small bore instrumentation and process piping were inadequate in that contractor hanger design calculation problems were not identified for more than two years.

i

h/Y0.2-3 Response to Item Ab

RESPONSE

Commonwealth Edison Company acknowledges that L. K. Comstock did not fully innlement their 1983 audit schedule. However, adequate Comonwealth Edison Quality Assurance audits were performed to cover all applicable L. K. Comstock activities. During the inspection visit, the NK ackn3wledged that Commonwealth Edison Quality Assurance provided adequate quality audit coverage and'that Site Quality Assurance was previously aware of the L. K. Comstock shortfall.

CORRECTIVE ACTION TAKEN AND RESLLTS ACHIEVED A review of L. K. Comstock's audit coverage (corporate and site) for 1982 and 1983, indicates that a total of six (6) Quality Assurance 4

manual subsections and six (6) field work procedures had not been audited as follows.

A review of the six (6) Quality Assurance manual subsections not audited by L. K. Comstock showed:

l One (1) section covered the L. K. Comstock Policy Statement One (1) section covered the overall program description One (1) section defined the program applicability One (1) section covered L. K. Comstock's reporting of 10 CFR Part 21 items One (1) section covered the corporate review of the site Quality Assurance program One (1) section covered the corporate Organization Chart l L. K. Comstock corporate Quality Assurance has since completed I audits of the above sections.

For the six (6) work procedures:

Two (2) were new procedures as of late 1983 and therefore were

( not yet scheduled for audit i

One (1) covered silver plating of bus bars (an infrequently performed operation which is subjected to a 1005 Quality Control witness)

I k

5 / 6 13. 2 .3 Response to Ab (cont'd) -

One (1) covered site organization position delineation. This section is normally audited by corporate auditors during their audits One (1) covered Production's use of a Revision Work Request (RWR). (However, the related Quality Control inspection of RWRs had been audited. Subsequently, the work instruction was audited during the week of January 9,1984 by L. K.,Comstock.)

One (1) covered Equipment / Junction Box Installation.

(However, the related Quality Control inspection of equipment erection had been audited. Subsequently, the work instruction was audited during the week of January 9, 1984 by L. K.

Comstock.)

Therefore, the active applicable work procedures and quality control inspection procedures have been audited by L. K. Comstock as of the week of January 9,1984.

A concern raised by the inspector in the area of supporting evidence '

for L. K. Comstock audits prompted Site Quality Assurance to review copies of the objective evidence for the L. K. Comstock corporate offsite audits. Commonwealth Edison Company Quality Assurance with L. K. Comstock site Quality Assurance performed this review. (This information was not available onsite during the N E inspection.)

i This review disclosed that there was sufficient objective evidence recorded to support the conclusions stated in the audit reports.

Copies of this objective evidence are available at the site for review.

CORRECTIVE ACTION TAKEN TO PREVENT RECURRETE l

As a result of the Comonwealth Edison Company Quality Assurance concerns, L. K. Comstock has placed two (2) fulltime, qualified auditors on site (one activated in October, 1983 and one in 4

Novenber, 1983) . Counseling has been given to these aud tors by l

Commonwealth Edison Company Quality Assurance to include more descriptive evaluations of audit results in their audit reports.

Additionally, Procedures (4.14.3 and 4.14.1) have beca revised to more clearly define the L. K. Comstock onsite auditing activities and qualification processes for site auditors.

L. K. Comstock site Quality Assurance has submitted an audit plan for 1984 which indicates that the Quality Assurance Program and their active safety related activities will t.e adequately covered.

i

h/Y3-2 ')

l Response to Item Ab (cont'd)

DATE OF FLA.L COWLIAPCE All applicable site procedures were audited by the week of January 9, 1984. Procedures 4.14.3 and 4.14.1 were revised to reflect onsite auditing acti'ities and Qualification processes.

Interim approval was granted on 2/29/84 and 11/2/83 respectively.

4 e

nw---a .- ,,m -

l hjif,/ /d8. 2-l

U.S NUCLEAR REGULATORY C0tEISSION ,

REGION III Reports No. 50-456/85051(DRP);50-457/85049(DRP)

Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: Comonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, IL Inspection Conducted: October 7-11, and October 28-November 1, 1985 Inspectors: P .' ////1/fi Date c

f.e.%4pp

. J. Kro fl /19f6f Date b W R. M. Lerch Ii/i9[$J'~

Date h9 hMdr J. A. Mall by -

///fi Bf

. Date

~ 9 Approved By: am S. L tie, irector //f!/[

Braidwood Project Date ' /

Inspection Sumary Inspection on October 7 through 11 and October 18 through November 1,1985 (Reports No. 50-456/85051(DRP); 50-457/85049(DRP))

Areas Inspected: Routine, unannounced safety inspection of activities with regard to licensee action on previous inspection findings, followup on allegations, electrical installations, and pipe supports. The inspiction involved a total of 136 inspector-hours onsite by four NRC inspectors.

Results: No violations or deviations were identified.

( h*W01~Y Junction Boxes Penetrations Conduits Per.etration Modifications (Unit 2)

Cable Pans Calibrations "

Cable Pan Covers Receipt Concrete Expansion Anchors Concrete Expansion Anchor Travelers Cable Pulling Embedde'd Conduits Terminations Stud Welding Cable Conductor Extensions General Inspections As of May 1985, LKC had reviewed 8,328 inspection records with these checklists of which 3,376 records were rejected. Performance of the QC inspection to the wrong drawing revision accounted for 35.5% of the rejected records. As of October 8, 1985, 73,817 inspection records had been reviewed,14,890 records had been rejected, and 7,142 of the rejected records had been corrected. The proper implementation of the Turnover Document Review will be 'urther evaluated during Region III's inspection of 10 CFR 50.55(e) Report No. 456/84-01; 457/84-01.

LKC is initiating a Drawing Review Program to ensure that revisions prior to April 1984 were properly implemented or corrected and documented. This .

program may involve a field walkdown of current installations and/or a review of LKC installation and QC documentation with respect to current field drawings. If the field installations are not installed and inspected to the latest drawing revisions, rework / inspections will be implemented in accordance with current site procedures. This program has not yet been implemented and is being tracked by previously identified Open Item No. 456/85007-01; 457/85007-01.

The licensee's drawing control corrective actions and the implementation of the Turnover Document Review and Drawing Review Programs resolves this item of noncompliance. This item is considered to be closed.

(Closed) Violation 456/83-09-08(b);.457/83-09-08(b): During inspection 83-09, the insputor found that, (1) neither the LKC Corporate auditing coverage performed and/or scheduled from mid-year 1982 through mid-year 1983 nor the audit schedule established for the year 1983 would. provide complete program verification coverage as prescribed by the Quality Assurance Manual, and (2) of the seventeen internal LKC audits scheduled to be performed during January through June of 1983, only five could be detennined to have been completed with all five audits having been perfonned in January of 1983, and with no further auditing activity performed (Reference Report 83-09, Pages 35-39). Inspection Report i No. 83-09 was issued on May 7, 1984. The inspector reviewed the licensee's response, dated July 6, 1984.

The licensee acknowledged that LKC did not fully implement their 1983 internal audit schedule. The inspector reviewed Ceco Surveillance No. 4852 which was conducted to verify that the corrective action taken by LKC was as stated in the licensee's response. The licensee took credit

! for 17 CECO QA audits of LKC from June 1982 through December 1983, to

compensate for the lack of LKC auditing. The inspector notes that CECO's

auditing program has been previously reviewed in Reports 456/84-44; i 457/84-40 and 456/85046; 457/85045 and was found to be acceptable.

5

i

( h NA,2 ~ Y LKC conducted 33 internal audits in 1984 and 37 internal audits are scheduled to be conducted in 1985. Two certified auditors have been in the LKC organization since January 1984. A third auditor, currently in' training, will be certified in the near future. The audits conducted in 1984 and 1985 by LKC site and corporate auditors have adequately covered the QA program on an annual basis.

The inspector reviewed the following 1985 LKC internal audits for -

compliance with LKC Procedure 4.14.1, " Internal Audit Program":

Number Date of Report Coverage Results I-087-085 01-23-85 Installation of 1 finding Class IE Embedded Conduit and Inspection of Class 1E Embedded Conduit.

I-088A-085 02-08-85 DC Storage Battery and Battery Rack Installation and Inspection.

I-089-085 .

02-13-85 Generating Work 2 findings Instructions. 1 observation I-090-085 02-26-85 Equipment / Junction 1 concern Box Installation, Inspection of Class 1E Equipment / Junction Box Installation.

I-091-085 03-05-85 Electrical 1 finding Penetration Installation, Temination and Maintenance, Unit 2 Electrical Penetration Installation, Temination, and Maintenance, Inspection of Electrical Penetrations.

I-092-085 03-22-85 Reporting of I observation Defects and Noncompliance;

, Nonconforming Items.

i 1-093-085 03-22-85 Field Problen Reporting Procedure.

l I-094-085 04-16-85 Manual Soldering

Procedure.

I 6

( (' ff No $.2

• Y Number Date of Report Coverage Results -

I-095-085 03-18-85 Cancelled. Procedure Oeleted I-096-085 04-30-85 Corrective I finding Action, Stop I concern Work. 1 observation L.097-085 05-16-85 Occument Control, I finding Drawing and 2 concerns Specification Document Control Inspection Procedure.

I-098-085 05-16-85 Design Change Control.

I-099-085 05-22-85 System Completion / 5 concerns Turnover Procedure.

1-100-085 05-13-85 Resched~uled to 8/12/85.

1-101-085 05-13-85 Rescheduled to 6/24/85.

1-102-085 06-06-85 Equipment I finding Maintenance 3 concerns Procedure (4.9.6). 1 observation I-103-085 06-28-85 Rework. 1 observation 1-104-085 07-10-85 Storage, Issue, I finding and Control of 1 observation Welding Material.

I-105-085 06-10-85 Audit cancelled due to procedure deletion.

1-106-085 07-16-85 As-built Information Reporting Procedure.

1-107-085 08-13-85 Control of I concern Measuring and Test Equipment.

1-108-085 08-13-85 Cable Pan 1 concern Installation of Class 1E Safety-Related Cable Pan Installations.

LKC Corporate audits have been conducted as follows:

7

s ( p N I),4 - Y Audit No. Date of Audit Criteria Covered CQA-84-68 March 6-7, 1984 X, XII, XIII, XVIII

• CQA-84-130 June 18-19, 1984 I, II, XV, XVI, XVII CQA-84-166 August 6-8, 1984 VI, VIII, XIV CQA-85-10 January 28-30, 1985 III, V, IX CQA-85-51 March 25-27, 1985 I, II, XIII, XVIII CQA-85-74 April 29-30, May 1,

Purpose:

To conduct a review 1985 of the Qualification, Classification, and Training of QC Personnel to assure compliance with LKC .

Procedure 4.1.3..

CQA-85-112 August 5-9, 1985 II, XII, XIV, XV, XVI CQA-85-126 October 2-4, 1985 II, III, V, VI, VIII One more corporate audit is scheduled in 1985.

During the inspector's review of auditing, three concerns were identified as follows:

a. LKC Procedure 4.1.1, Revision C, dated May 6, 1985, " Site Organization Chart," does not document the actual Quality Control /

Quality Assurance organization in place. Additionally, LKC Procedure 4.1.2, Rev. C, May 23,1985, " Position Delineation," requires updating.to define the actual responsibilities of personnel in the LKC QA/QC organization. The inspector notes that LKC Corporate Audit CQA-85-51, Concern 4, identified the same concern which was subsequently cicsed out. The LKC site response to Concern 4 states that any new positions added must be approved via procedural revisions. At the conclusion of this inspection, LKC was in the process of revising Procedures 4.1.1 and 4.1.2. The inspector will review the revised procedures in a future inspection.

b. LKC Procedure 4.14.1, " Internal Audit Program;" Paragraph 3.3.1, allows limited activity procedures to be placed on a 24 month audit schedule. However, Regulatory Guide 1.144, (1979) C.3.a(2), states that applicable elements of the QA program should be audited at least annually or at least once within the life of the activity, whichever is shorter.

~

c. LKC Procedure 3.1.4, " Quality Assurance Program Review and Evaluation,"

Paragraphs 2.3 and 2.4 for scheduling of corporate audits state,

" Audits shall be performed in such a manner that the quality program will be reviewed and evaluated for compliance to each of the applicable criteria of 10 CFR 50 Appendix B at least once in a twelve (12) month period... Unscheduled audits may be perfonned when deemed necessary."

8

(

( f i M s. 1. - Y._

However, LKC Procedure 1.0.1, " Quality Assurance and Control Program,"

Paragraph 4.14, states, " Audits shall be conducted quarterly or on a random, unscheduled basis, or both." The phrase "or on a random, unscheduled basis" allows any auditing frequency to be chosen. The requirements of the two procedures appear to be inconsistent. The inspector notes that only three corporate audits were conducted in 1984.

Items a, b, and c are open pending the licensee's resolution (456/85051-01; 457/85049-01). -

LKC's auditing program was previously reviewed in the CAT inspection (Report Nos. 84-44; 84-40, Page VIII-3). The CAT inspector had one concern regarding the program: "The L. K. Comstock audit procedure did not require the audit report to address the effectiveness of the elements audited and did not require verification of the effectiveness of corrective action to audit findings."

The inspector verified that LKC Procedure 4.14.1, Rev. B, resolved this concern.

Lack of LKC auditing is considered to be closed.

No violations or deviations were identified.

3. Allegations (Closed) RIII-85-A-0130: On August 1, 1985, the Office of Inspection and Enforcement received an anonymous allegation regarding the Braidwood Station. The alleger stated that, (1) the G. K. Newberg Construction Company received 575,000 in damage to welding equipment due to sabotage over the last few months, and $40,000 in thefts have occurred, (2) there is open abuse of# alcohol and drugs, and (3) there is open drug dealing on site. 'This allegation was forwarded to the licensee for their review in a letter dated September 9, 1985. The licensee assigned this allegation

. to the Quality First Director, Project Construction Superintendent, and Station Security Administrator. The Quality First investigation was -

completed on September 27, 1985.

i The Project Manager for G. K. Newberg determined that during the period of May 1 through August 1,1985, approximately nine welding grids were lost, along with minor amounts of welding lead (total value estimated at l $4,000). During the same period, six small tools were reported stolen (total value estimated at $1,500). No incidents of sabotage were reported during the period.

CECO has implemented drug and alcohol abuse policies for both Ceco employees and contractor personnel. For CECO employees, the company's program is documented in the " Company Policy Regarding Drugs and Alcohol Abuse." Guidance for implementation of the company policy is documented i in " Supervisory Guidelines for Administering the Company Policy Regarding Drug and Alcohol Abuse," and " Questions and Answers," concerning the l

Policy.

9 L