ML20214C334
| ML20214C334 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 02/13/1986 |
| From: | Muffett J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20214C321 | List: |
| References | |
| OL, NUDOCS 8602210100 | |
| Download: ML20214C334 (24) | |
Text
.
UNITED STATES OF AMERICA .
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Station, Units 1 and 2 )
AFFIDAVIT OF JAMES W. MUFFETT IN SUPPORT OF NRC STAFF'S RESPONSE TO APPLICANT'S MOTION FOR
SUMMARY
DISPOSITION OF ROREM QA SUBCONTENTION 5.A I, James W. Muffett, being duly sworn, depose and state as follows:
- 1. I am employed as a Reactor Inspector (Mechanical Engineer) by the U.S. Nuclear Regulatory Comission (NRC), Region III, 799 Roosevelt Rd, Glen Ellyn, IL 60137. I have been employed by the NRC in this capacity since August of 1983. A copy of my Statement of Professional Qualifications is attached hereto as Exhibit 5.A-1 to this affidavit.
- 2. As a Reactor Inspector, I am primarily responsible for reviewing the design of and performing inspections of mechanical and structural components.
i
- 3. The purpose of this Affidavit is to support the NRC Staff's response to Applicant's Motion For Sumary Disposition of Rorem QA f Subcontention 5.A. This subcontention states as follows:
- 5. Contrary to Criterion III, " Design Control,"
of 10 C.F.R. Part 50, Appendix B, Comonwealth Edison Company has failed to establish measures to assure that applicable regulatory j requirements and design bases are correctly translated into specifications, drawings, procedures, and instructions including provisions to assure that appropriate quality standards are specified in design documents l
8602210100 860219 DR ADOCK O y 46 I
and the deviations from such standards are .
controlled. Applicant has also failed to requirement that measures are established for the identification and control of design interfaces and for the coordination among participating design organizations, that the measures include the establishment of procedures among participating design organizations for the review, approval, release, distribution, and revision of documents involving design interfaces; and that the design control measures provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program.
A. The NRC CAT inspection concluded that in the area of design control the most significant finding was the failure to annotate unincorporated design changes on controlled design documents. The most significant finding in the area of design change control was design change documents written against superseded revisions of the approved design drawings. In at least one instance, this deficiency resulted in a pipe support being installed and inspected to other than the latest approved design. (CATInspection Report 84-44/40, Exh. 10.)
In preparing this Affidavit I reviewed the following materials:
4.
- a. Applicant's Statement of " Material Facts As To Which There Is No Genuine Issue To Be Heard;"
- b. Testimony of Kenneth T. Kostal (On Rorem Q.A.
Subcontention 5.A)
- c. Testimony of Michael A. Gorski (On Rorem Q.A.
Subcontention 5.A)
- d. Inspection Report Nos. 50-446/84044; 50-457/84-40 ,
- 5. The discrepancies upon which Rorem Subcontention 5.A is based were identified in the course of a Construction Assessment Team (CAT)
_ _ , - - - - - - - - , . , - - - - - - . - , y
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inspection of Braidwood. During that inspection the, CAT Team discovered , ,
a small number of design drawings were not annotated.in compliance with applicable procedural requirements. These discrepancies were isolated examples and were not determined to be significant, and therefore these items were not elevated to the status of a violation.
- 6. In an effort to enhance its control of these activities, the licensees through Sargent & Lundy, made improvements to "Braidwood Field Instruction, BRFI-4, Resolution of Hanger Field Problems." This
, improvement in the field instruction calls for an explicit " hold" on resolution of field problems until new drawings are issued.
- 7. I reviewed and evaluated the Applicant's enhancement in this area. I am satisfied that this change will improve the licensee's program in this area. To the best of my knowledge, there has oeen no recurrence of the type of discrepancies described in Subcontention 5.A.
- 8. Rorem Subcontention 5.A is not based on a violation. I believe that the comment in the CAT inspection report was motivated by an interest in improving an acceptable process. For this reason this item does not represent a significant breakdown in the Applicant's quality assurance program. Consequently I agree with the Applicant
that there is no genuine issue to be litigated regarding Rorem ,
Subcontention 5.A.
4 dames W. Muffet%
Sworn and-subscribed before me this /F day of February,1986
[t tu1.v1. hgud1 Totary Public M%QMORExpiresHOV.27,1000 My Comission expires:
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Professional Qualifications .
JAMES W. MUFFETT Organization: Region III
Title:
Reactor Inspector (Mechanical)
Birth Date: January 5,1950 Ed ucation : B.S. Physics, Purdue University 1972 M.S. Mechanical Engineering -
University of Idaho 1978 Registration : Professional Engineer, Illinois, Indiana, Minnesota Ex perience:
1983 - Present Reactor Inspector - Responsible for inspection of reactor under construction and in operation.
1981 - 1983 Engineering Manager - Managed mechanical design and analysis group with staff of 20 (NuTech).
1980 - 1981 Product Engineer - Responsible for development of advanced design methods. (International Harvester) 1978 - 1980 Senior Engineer - Responsible for development and application of advanced design methods. (Cummins Engine Co., Inc.)
1975 - 1978 Group Leader - Leader of piping analysis group
, which performed piping analysis for LOFT reactor at l Idaho National Engineering Lab. (EG & G Idaho)
! 1972 - 1975 Stress Analyst - Performed piping stress analysis, support design and field interface duties at various nuclear power stations. (Sargent & Lundy) l l
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l
Exhibit 5.A-2
{
4 UNITED STATES NUCLEAR REGULATORY COMMISSION .
OFFICE OF INSPECTION AND ENFORCEMENT DIVISION OF INSPECTION PROGRAMS REACTOR CONSTRUCTION PROGRAMS BRANCH Report No.: 50-456/50-457/84-44, 84-40 Docket No.: 50-456, 50-457 Applicant: Commonwealth Edison Company '
Facility Name: Braidwood -
- Inspection At
- Braidwood, Illinois Inspection Conducted: December 10-20, 1984 and January 7-18, 1985 Inspectors: /~ ce1 m / K P. Keshishian, Sr. Reactor Construction Engineer 04te Signed Te Leader Ml A ,i G. B. Geofgiev, Sr. Re' actor Conktruction Engineer
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Dite S'igned
$d K.r R. Hooks, Reactor ~ Construction Engineer Yb W/fkS~~
Date Signed f/
W. Kropp, Reactor Inspection (Region III) m 62f/f/fJ'*
Dnte Signed
$YA-T. K. McLellan, Reactor Construction Engineer A)Dh'.s~
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Date Signed
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! Eh6lW g Nemoto, Reactor onstruction Engineer Date Signed
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- S. R. Sfein,' Reactor Construction Engineer Date Signed Consultants: R. M. Compton, D. C. Fora, J. B. McCormack, O. P. Mallon, W. S. Marini, E. Y. Martindale, A. Miller, R. E. Serb and W. J. Sperko, Jr.
e Approved By: / ,
M!/j .5 Rot,hrt F. Heishman, Chief Date' Signed j . -
. Reactor Construction Programs Branch
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( TABLE OF CONTENTS '
TOPIC SECTION INSPECTION SCOPE AND OBJECTIVES ................................ I ELECTRICAL AND INSTRUMENTATION CONSTRUCTION .................... II MECHANICAL CONSTRUCTION ........................................ III WELDING AND NONDESTRUCTIVE EXAMINATION ......................... IV CIVIL AND STRUCTURAL CONSTRUCTION .............................. Y MATERIAL TRACEABILITY .......................................... VI DESIGN CHANGE CONTROL ...:...................................... VII CORRECTIVE ACTION SYSTEMS ...................................... VIII
. PROJECT MANAGEMENT [ ..... ....................................... IX ATTACHMENT A - PERSONS CONTACTED AND DOCUMENTS REVIEWED
( ATTACHMENT B - GLOSSARY OF ABBREVIATIONS o
e e * *
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h APPENDIX A
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EXECUTIVE
SUMMARY
An announced NRC Construction Appraisal Team (CAT) inspection was conducted at i
Commonwealth Edison Company's (Ceco) Braidwood Station during the period December 10-20, 1984 and January 7-18, 1985.
Overall Conclusions Hardware, Project Management and documentation for construction activities were generally in accordance with requirements and licensee commitments. However, the NRC CAT did identify a number of construction program weaknesses that require increased management attention. These are: -
- 1. The effectiveness of first level quality control (QC) inspection activi-ties needs to be improved, particularly in the pipe support / restraint and welding areas.
- 2. A large number of final inspection activities are being included in a final walkdown, when greater difficulty will be encountered in identifying deficiencies because of interferences, accessibility and the pressure of schedule.
- 3. The identification and resolution of cable tray and conduit electri-cal separation deficiencies is inadequate.
I'
- 4. An excessive number of incidents of damage to installed equipment has been caused by current construction activities.
The foregoing identified weaknesses require additional management attention to assure that completed installations meet design requirements.
An effort was made by the NRC CAT to evaluate the ongoing Braidwood Construc-tion Assessment Program (BCAP). The schedule for the BCAP inspection program was such that only limited hardwre samples were available for NRC CAT over-inspection. It was possible to overinspect a very small sample of hardware in the areas of supports / restraints, piping runs, HVAC supports and ducts for
- welding, HVAC ducts for configuration and conduit runs. In four of the six j
' areas that were overinspected, there was general agreement between BCAP and NRC CAT findings; in two areas, supports / restraints and piping runs, deficien-cies were identified by the NRC CAT that were not identified by the BCAP inspectors. On the basis of the limited sample overinspected, it appears that BCAP inspection effort needs to be improved in the areas of supports / restraints and piping runs.
AREAS INSPECTED AND RESULTS Electrical and Instrumentation Corstruction f The elechic'al-and instrumentation samples inspected generally met the
( applicable design and construction requirements. However, construction and inspection deficidhU es were identified in several areas including several items which will require additional NRC review and analysis.
A-1
6.6.A Th2 NRC criteria.
acceptance CAT insptctors also fcund rcdiographs which did not e specified meet The licensee's quality assurance procedures do not i require to that an final storage independent in the vault. intemretation of radiographsorbe perfo !
( dent radiographic interpretation may have contributed to the PThe inability to detect deficient radiographs. roject's
_ Civil and Structural Construction
~
Concrete quality was acceptable.
inspected construction openings and cadweld testing e not met.
frequenc Structural concerns steel member identified. sizes, configurations and connections major had installed at below specified torque values.A few high strength steel bolts the need to assure proper rebar anchoraIn the areangof maso the removed sections of masonry walls. ge prior to replacement of masonry in Material Traceability and Control
The measures ongoin presently established for material traceability tion, g work appear to be adequate except for one area. or and c During this inspec- <
it was detenmined that 10,500 feet of switchboard IEEE 383-1974 wire e
not o
qualif was installed at Braidwood Station.
Corrective Action J
Therequirements.
with corrective action However programs generally are being implemented ance in based on the results of this inspection, the controls need for nonconformance, additional review. These include: reports issued by sMte contractors pr 1.
Some nonconformance reports were voihd without documented on.
jus 2.
Nonconformances reviewed by the appropriate dispositioned "Use-As-Is" or " Repair" were engineering personnel.
3.
The the specif.ied corrective nonconformances. actions did not im some cases adequa Mesign Chance Control '
applicable requirements. Design change control was determined to be g In the area of the most significant finding was the failure to annotate unincorporated design channes on controlled ments.
ocu- des The most significant finding in the area; of design change control wa design design change documents written against superseded revisions drawings. roved t of the 4 -
support being installed and inspected to other thn the .
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7 EXT OF 697 REpony VII. DESIGN CHANGE CONTROL '
A. Ob.iective TM primer 9y objective of the appraisal of design change control w determine Wwther design change activities were conducted in com with regulatory requirements, Safety Analysis Report (SAR) consitm and approved licensee, engineer, constructor and vendor procedures An additional objective was to determine that the changes to structu .
and hardware accurately prescribed in a sample of design change documents were completed.
- 8. Discussion
" Document Control" establish the overall regula design change control.
Guide (RG) 1.64 Rev. 2, June 1976, " Quality Assurance the Design of Nuclear Power Plants" which endorses American National Standards Institute (ANSI) Standard N45.2.11-1974 " Quality Assurance Requirements for the Design of Nuclear Power Plants." The 1,1censee's Braidwood Stations Final Safety Analysis Report (F The areas of design change control evaluated by the NRC Construction Appraisal Team (CAT) inspectors were control of changes to design documents and control of design changes.
In each of these areas, I
activities, procedures were reviewed, and a samp documents was reviewed. In addition, a sample of the completed structures and hardware which had been inspected and accepted by
.- on-site CAT contractor quality control personnel was inspected by the NRC inspectors.
basis. These evaluations wre performed on an interdiscipline
- 1. Control of Design Documents The specific aspects of the control of design documents inspected were the availability to the users of the latest approved design documents and design change documents and the methods of assur that approved changes not yet incorporated into design documents are !
provided to the users prior to work being performed. ' l
- a. Inspection Scope (1)
The following procedures related to distribution and control of design documents and design change documents were reviewed:
Commonwealth Edison Cospany (Ceco) Quality Requirement (QR) 3.0, " Design Control," Rev. 15, August 15, 1984 CECO QR 6.0, " Document Control," Rev. 9, August'15, 1984 CECO Quality Procedure (QP) 6-1, " Distribution of Design Documents," Rev. 7, October 10, 1983 VII-1
& SA- z. ' .
CECO QP 6-2, " Procedure for Station Construction Department Design Document Control," Rev. 3, May 12,1983
,( -
CECO Braidwood Nuclear Station Project Procedure PCD-03,
" Field Change Request," Rev. O, June 15, 1984 Sargent & Lundy Engineers (S&L) General Quality Assurance October 21,(GQ)
Procedure 19813.07, "Sargent & Lundy Drawings," Rev. 6, i
S&L1981 21, GQ-3.13. " Engineering Change Notices," Rev. 6, October S&L GQ-6.01, " Project Distribution List and Project File Indexes," Rev. 5, October 21, 1981 S&L Project Instruction for Syron/Braidwood (PI-88) 29,
" Distribution and Control of Design Documents for S&L Field Personnel at the Byron /Braidwood Stations" L. K. Coastock & Company, Inc. (LKC) Procedure 4.t.1,
" Document Control," Rev. F, October 12, 1984 - -
Gust K. Newberg Construction Co. (G101) Quality Assurance Manual (QAM)Section IV, " Document Control," Rev. 4, October 3, 1984 j GKN Quality Control Procedure (QCP) Section 3, " Drawing Control," Rev. 6, October 25r, 1984 GKN QCP Section 4, " Specification Control," Rev. 4, October 4, 1984 Phillips, Getschow Co. (PGCat) QCP B-29, "Doctment Control "
Rev. 2, October 31, 1984 Pullman Sheet Metal Works Inc. (PSM) Quality Assurance Program (QAP) Section 86.1.F," Document Control," Rev. 2 September 9, 1983 PSM QAP Section 83.2.F, "Dra fting," Rev. 0, July,22,1984 (2) Ceco and contractor Quality Ass urance (QA) audit and surveillance reports concerning design document control were reviewed for findings, trends a nd corrective actions.
- (3) CECO, S&L and contractor docuneint control, engineering, construction and QA personnel w.ere interviewed concerning distribution, change documents.
control and use of design documents and design VII-2
CxC4 L
- b. Inspection Findings (11 S&L design documents and Engineering Change Notices distributed by S&L to Ceco, contractor and S&L organizations and bution personnel lists. in accordance with PI-BB-29 and the S&L distri-Field Change Requests (FCRs), which are Ceco design change doc uents, are distributed by the Ceco Project .
Constructionand organizations Department personnel.(PCD) to S&L, contractor and CECO (2)
CECO. S&L and the contractors each control the red and use of design documents and design change documents within their organizations in accordance with their separate and different doc uent control procedures.
design docuents and design change documents is reconied on documents and design change documents are iss (satellite) document control stations and the superseded revisions' destroyed or stamped.
Five of the six doc uent control systems reviewed by the NRC CAT inspectors control the use of approved, unincorporated design change documents by annotating the design change identification numbers on all controlled copies of the affected design documents.
GKN has .
recently revised their procedure to identify unincomorated design changes on a separate list, a copy of which is maintained at ea::h GKN document control station.
(3)
, The CECO PCD document control station is the " master" against which other document control station records are evaluated.
Typically, possible contractor discrepancies concerning the latest approved and issued revision of a design document and o- the correct annotated design change documents are resolved by comparison to the design documents and document receipt logs in the Ceco PCD document control station.The document control list (s). ECM status list and FCR status list are also used b the data is not current since they are issued monthly and the input data cutoff can be several weeks prior to the lists issue dates.
(4)
The most prevalent and sustained deficiency identified in the QA audits and surveillances of the various document <:ontro systems is incorrect annotating of design change documents.
The majority of these deficiencies are ECNs and FCRs listed on design documents after the changes have been incorporated.
The more serious deficiency is failure to list unincorporated design changes on the design documents (possible lost infor-nation).
i Substantial efforts (corrective actions) to eliminate
- this type of deficiency have been made in each of the various document control programs.
(5)
Thefollowing the NRC CAT review of the S&L Distribution Lists identified discrepancies:
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- a. The Mechanical Department Distribution List, Rev.19, and
, the Structural Department Distribution List, Rev. 24, do not have the total number of pages on each page. GQ-6'.01 states, in paragraph 3.A.1, "All pages of the Project Distribution List shall contain the project number, revision mmber, page number and the total number of pages." S&L is now revising the procedure to permit putting " final" on the last page in each list, which is consistent with their current practice.
- b. The Structural ' Department Distribution List, Rev. 24, and the Electrical Department Distribution List, Rev.19, do not identify the controlled copies. GQ-6.01 states, in paragraph 3.A.1, that the lists "...will identify the recipients of S&L drawings who are res taining controlled sets of drawings." ponsible for main-S&L QA informed the NRC CAT inspector that all design documents distributed in accordance with these lists are " controlled" copies.
(6) The NRC CAT inspectors reviewed about 150 S&L design documents >
at 3 LKC document control stations (Numbers 10, 19 and 28) for legibility, LKC date stamp, and other stamping (f.e!, "For Reference Only" and "For QC Use only"). The revision numbers and ECNs/FCRs annotated were recorded for about 60 design documents and checked against the LKC Document Mester Cards.
- No incorrect design document revisions were identified. At Station Number 28 (Quality Control) drawing 20E-2-3503, Rev. D
[J was not stamped "For QC Use only" in accordance with LKC Procedure 4.2.1 paragraph 6.2, and FCR-L-13419 was not anno-tated on S&L drawing 20E-0-3091H01, Rev. E, although it was
.- listed on the Document Master Card. In addition, several cases were identified where ECNs/FCRs were still annotated on design documents when the Document Master Cards showed them incor-
- porated (i.e., ECN-22123 on drawing 20E-0-3393, Rev. AF).
(7) About 50 design documents were reviewed for legibility and stamping (i.e., " Controlled") at PGCo document control station Number 1 (Engineering Files), and the revision numbers and ECNs/FCRs annotated were recorded and checked against the Document Distribution Cards, hand updated S&L ECM Status Report and PGCo FCR log. All design documents were in accordance with the Document Distribution Cards, ECM Status Report and FCR log except where new design documents, and design change documents had been received within about five working days. PGCo procedure QCP 8-29 does not contain any time limit for replacing superseded design documents or annotating ECNs/FCRs on design documents.
(8) About 30 of the design documents reviewed for revision number and ECN/FCR annotation were cross-checked against design documents in the Ceco PCD document control station. Discre-pancies were noted on about fifteen, mainly in the ECNs/FCRs annotated on the design documents. Investigation showed that '
l most discrepancies were due to different time lags in replacing l
VII-4
h I4- 2.
i design documents and adding or deleting ECNs/FCRs on design documents.
i .
Two ECNs, 23416 and 23486, were not annotated on Ceco PCD's controlled copy of drawing 20E-0-3237E, Rev. A, due to a mis-
- understanding of a note on the ECNs.- Several ECNs/FCRs which had been incorporated were listed on design drawings (i.e., FCR i L-14744 was listed on drawings M-820, Sheet 1, Rev. P; M-823, Sheet 2. Rev. H; M-823 Sheet 7. Rev. H). i i
(9) Distribution of controlled copies of approved design documents and design change documents within contractor organizations is based on some form of receipt acknowledgement (i.e.,
positive control). However, distribution of design and design change documents ny S&L and Ceco to contractors does not involve receipt acknowledgement. It is thus possible that a contractor may not receive certain documents and will not know that the documents have not been received. Although the contractors can check the project doctment status lists (see paragraph 1.b(3) above) cross checking against these listings is not generally a contractor procedura.1 requirement, although it appears to be a requirement of Ceco QP '-1.6 As an example, ECNs 22696, 23544, 23587 and 23620 had not been received by L. K. Coastock as of December 18, 1984; these ECNs had, however, alrea@ been annotated on S&L drawings 20E-0-3393T, Rev. H and 20E-0-3-393G, Rev. S by CECO PCD. Ceco QA Surveillance Report 3450, March 16,1984, identified non-receipt of the latest revision of an S&L drawing by PGCo.
(10) In general, the number of ECNs/FCRs not incorporated into design documents is small, particularly on electrical drawings for which responsibility (and the sylar originals) has been transferred to the S&L Braidwood site organization. As an example, S&L drawing 20E-0-3388 was revised and reissued on January 6, March 7. March 23, September 12 and October 10, 1984 and Rev. G, dated October 10, 1984 had no approved, unincorpo-rated ECNs/FCRs at the. time of the NRC CAT inspection.
- c. Conclusions For the sample inspected, the control of design documents is generally adequate.
However, deficiencies in annotating ECNs/FCRn os design documents have been previously identified by Ceco and contractor QA audits and surveillances and by NRC Regional and Resident Inspectors, and are still present in two of the three document control systans inspected by the NRC CAT.
- 2. L Control of Desian Chances The specific aspects of the control of changes to design inspected by the NRC CAT were the change control systems for ECMs and FCRs, and implementation and verification of the changes.
VII-S
fy L 4-t-4
- a. Inspection Scope .
i -
g (1)
The following procedures relating to the control of design changes were reviewed:
Ceco QR 3.0, " Design Control," Rev. 15, August 15. 1984 CECO QP 3-1, " Design Control " Rev. 5, October 5,1984 Ceco QP5,3-2, Octotrer 1984" Design Change control," Rev. 13, CF'.o V4y 24,PCD-02, 1984 " Engineering Change Notices," Rev. O, Ceco PCD-03, " Field Change Request," Rev. 0, June 15,1984 S&L GQ 3.07, "Sargent & Lundy Drewings," Rev. 6 October 21, 1981 S&L GQ 3.08, " Design Calculations," Rev. 4, March 5,1979 S&L GQ21, October 3.13, " Engineering Change Notices," Rev. 6, 1981 S&L PI-88-13. " Procedure for Processing Ccms-salth Edison
, Conspety Field Change Requests (FCRs)," Rev.12,
- l. ,
September 27, 1984 .
S&L PI-88-18. " Procedure for Handling C-rzalth Edison Comparty Field Change Requests Transmitting "As-Built" Infomation," Rev.1, May 7,1984 S&L 7, Rev. PI-98-23, October "25, Byron 1983/Braidwood Electrical Field Personnel,"
S&L PI-88-25, " Activities of the On-Site Structural Design
. Group " Rev. O, August 29, 1983 S&L PI-88-28, " Activities of the Byron /Braidwood Station Mechanical Engineering, Piping Design, Support Design and Analysis Field Personnel," Rarv. 3, August 4,1983 LKC Procedure Rev. A, April 27,4.2.3, 1983 " Field Probles Reporti ;g Procedure,"
LKC Procedure 4.2.4, "As-8uil t Informati6n Reporting Procedure," Rev. 8, August 20,1984 GKN QAM October Section III, " Design Control," Rev. 4, 3, 1984 VII-6
)
4 54-2.
GKN QCP 33, " Design Change Control," Rev. 5, October 25, 1984 I * .
PGCo Constructicn Procedure (PGCP) 1.1, " Control of Engineering Change Notices (ECN), Field Change Notices (FCN), Field Change Requests (FCR) and Field Problem Reports (FPR)," Rev. 9, May 31, 1984 PSM Procedure 83.1.F. " Design Control," Rev. 4 December 2,1983 I (2) Ceco and contractor QA audit and surveillance reports l
i concerning design changes were reviewed for findings, trends
.and corrective actions.
(3)
Interviews were conducted with personnel from Ceco, S&L, LKC, GKN, PGCo and PSM concerning initiation (origination), review, approval and implementation of design changes.
- b. Inspection Findinas (1) S&L has approximately 500 people in their Braidwood ite organization, and of whom about 400 are assigned in engineering design groups.
The majority of the engineering and design personnel are engaged in resolving field problems by clarifying design documents and making design changes.
~ The. contractors do no engineering or design; however, GKN,
{( PGCo and PSM prepare supplementary drawings / sketches from the S&L approved design drawings for use as aids in fabrication and construction. Generally such aids are prepared by the contractor field engineers an,d both contractor engineering and QC personnel review them for conformance with the S&L approved drawings.
QC inspections of structures and hardwtre are to be made only from S&L approved design drawings. CECO and contractor QA audits and surveillances have identified discrepancies between these aids and the design drawings, but the discrepancies appear to be isolated programmatic failures. -
(2) Design changes are accomplished through design change documents such as FCRs, ECNs, Field Change Notices (FCNS) and through revision of design documents without an intermediate design change document.
FCRs are a Ceco design change doctament generally originated in the field by Ceco or contractor personnel and approved by both Ceco and S&L. ECNs are an S&L design change document originated in the field or S&L's Chicago office and approved by S&L. FCNs are a Westinghouse Electric Comoration (the Nuclear Steam Supply System vendor) change document originated and approved by off-site Westinghouse personnel.
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1 Roughly 40,000 FCRs/ECNs have been issued for the Braidwood Project.
An average of about 200 FCRs and 300 ECNs have been issued each month since June 1984, and the present trend'is decreasing. !
(3) Problems, conflicts and items requiring clarification identified by the contractors in the approved design documents are forwarded to S&L for resolution. When resolution requires 1 a design change, an FCR, ECM or drawing revision is prepared and issued to the contractor. LKC and PGCo use Field Problem Reports (FPRs), GXM uses Framing Modification Field Problem Reports, and PSM uses Field Engineering Memoranda (FEMs).
These contractor documents are generally not controlled or considered QA documents.
(4) Approximataly 600 ECNs and FCRs were selected and reviewed for procedural compliance, adequacy of probles description and resolution (design change).
A number of minor procedural deficiencies and inconsistencies were identified:
The FCR fora differentiates between " major" and "sinor" changes; the definitions are provided in Ceco QP 3-2, Attachment A. However, review of in process and completed FCRs and discussion with Ceco, S&L and contractor personnel indicated that considerable variations exist in practice in i i detemining what constitutes " major" and," minor" changes.
I In the sample of FCRs inspected by the NRC CAT, it appears that NCRs.
structural FCRs were " Minor" even when resulting from HVAC FCRs were generally " major" even though an NCR was not involved. Some piping FCRs we m " Major", althougn
- the stated reason for the change request is "S&L Drawing Clarification." Examples are:
FCR L-15823, November 16, 1984 FCR L-158830, October 9, 1984 FCR L-14065, May 4, 1984 '
FCR L-16152, November 29, 1984 FCR L-16039, October 19, 1984 FCR L-16344, December 7, 1984 S&L's procedure PI-B8-13 does not differentiate between
" major" and " minor" changes, and discussions with S&L personnel indicated that this designation is not considered
, in their processing of FCRs.
Changes were made to FCRs (Part C and Part 0) with
" whiteout" or by lining through previous infomation and adding new information without dating and initialing the changed items. Examples are:
VII-8
- h $ h 2-L-14665, June 22, 1984 L-14893, July 20, 1984 L-30651, March 24,1983 L-30686, March 30,1983 Although the Ceco procedures reviewed do not prohibit
" whiteout" or require that all correcticas on FCRs be initiated and dated S&L PI-88-13, partgraph 4.8, states "Any changes or corr,ections ande ... are to be circled and initialed.
sign and date under Part C ...".The person circling and initia Failure to do so can result in concerns about when changes were made (prior to or after approval) and by whom they were made.
. FCRs and ECNs are . sot stand alone documents. In general, the descriptions of the design changes and the reasons for the design changes on FCRs are terse almost to the point of inadequacy, and extensive use is made of references to other doctments, often superseded FCRs.
FPAs and FEMs are referenced in the margins of FCRs, if at all, and the references are not required by procedure. ExampJes are:
FCR L-13026, February 21, 1984 FCR L-16174, November 9, 1984 FCR L-20604, March 17, 1984 E3 7909, June 1984 i ECM D-00040, November 5,' 1984
'(
The " Request Class" blocks for " Limited Construction" or
" Plant Modification" and " Major" or " Minor" change were not checked on a ntaber of FCRs. Examples are; L-12041, December 14, 1983 L-13026, February 21, 1984 .
L-13062, February 23, 1984 L-14830, July 5,1984
. This appears to be inconsistent with the requirements of Attachment 8 to Ceco QP 3-2. -
(3)
Several of the ECNs/FCRs reviewed in detail had the '" Reason for Change Request" phrased so that it appeared an NCR should have been written, but none was identified. Subsequent investigation by Ceco QA deterstned that FCR L-16,127 dated November 15, 1984, been identified on an NCR. described a discrepancy that should have this ites. Other apprently isolated PSM has now issued NCR BR-332 on cases of inadequate attention to the reason for isstsance of a design change are described in Section III.B.2.b.
CECO Site QA issued a memorandum on January 2,1985 (BRO
- 14,354) directing that all new FCRs be routed through CECO VII-9
[$.S*4'2.'
- l. Site QA for review prior to filing. It is possible that this initials and dates on lined through changes, un and missing references to NCRs.
(4)
FCRs/ECNs for which the work had been completed and accepted by contractor QC were selected for verification.
> Prior to l inspection of the physical changes, the base design drawings applicable change notices and backup calculations and QC , i inspection reports were reviewed by the NRC CAT inspectors.
The physical changes associated with the following FCRs/ECNs were then inspected to verify that the changes were implemented as described.
FCR L-14830. July 5, 1984 - The change required addicion of a vertical member to an NVAC duct hanger and the acceptance of two existing, non-stanuard weld connections. The FCR resulted, at least in part, from NCR 460, January 31, 1983.
Action on this change was acceptable.
FCR L-30651, March 24,1983 and ECM 10202 (supersedes FCR L-30651) - The changes required modification of h pipe support and welded pipe attachment due to an uninstalled heam connection plate and an interference. Action on this change was acceptable.
FCA L-11032, August 23, 1983 - The change required coping the top of a column to avoid interference from two pipes.
! The actual copes and reinforcement plate were inaccessible due to application of fire protection material; however, 2
interferences which would have existed between the beam, an electrical conduit and a copper pipe, if the copes had not been made, were identified.
i
- FCR 14890, July 20, 1984 - The change required addition of a wingplate and concrete expansion anchor (CEA) to the baseplate of a blockwall column. The change resulted from a baseplata CEA which did not meet minimum embedment criteria, per NCR 213-799, June 12, 1984.
change was acceptable. Action on this ECN 7944, June 2ti,1984 - This change required a new connection detail for an electrical tray support brace.
The physical installation was in accordance with the intent of the ECN. A discrepancy in the associated paperwork (incorrect orientation / numbering) was identified by LKC on NCR 3139, August 24, 1984.
(5)
The calculations for about 20 ECHs/FCRs were reviewed for conformance with applicable requirements (particularly S&L GQ 3.08). All the calculations were for changes to previously approved designs, and thus were in effect partial revisions to previous calculations. They consisted of both VII-10
fff.g_
hand and computer calculations, involving mostly structural y , attachments, Examples are: core drilling and pipe supports / restraints. ,
i FCR 14890, July 20, 1984 FCR L-30651, August 24, 1983 ECM 23843, December 7, 1984 i
i j
The calculations in the sample inspected were prepared, checked eents. and reviewed in conformance with procedural require-i They had been reviewed and approved prior to the approval date on the related ECNs/FCRs. Due apparently to varying standards between the S&L technical disciplines,
! page numbers, revision numbers, references to ECNs/FCRs and.
locations of signatures and dates were inconsistent, but adequate.
i No calculational errors were observed in the sample inspected. l (6) 1 l The NRC CAT inspectors identified cracked and spalled diesel generator exhaust silencer foumistions on both Unit I diesel provisions for thermal expansion of the Discussions ' silencers. gen i
with Ceco personnel showed that the cracked foundations had been identified on Ceco NCR 618, April 19,1984. The NCR states "Ori i
expansion."ginal design did not allow for adequate thermal l The deficiencies will be corrected in accordance with ECN 22326, August 17, 1984 which requires modifying /
) (/\
- repaicing the pedestals and anchor bolts, and ECN 22578, August 30, 1984, which requires modifying the slots on the exhaust silencer saddle plates for both longitudinal and lateral movement and adding plate washers. The ECNs apply to i
~
Braidwood Units No. I and 2.
- Subsequent spallin discussions with S&L indicated that the pedestal i forces,g appeared to .be caused by both lateral and longitudinal' the plate slots were partially flame' cut and not ground .mth, and loose grout was; found in the slots after the pedestal failures. ,
i i The NRC CAT inspectors had observed that the bolted connections
- between the embedded plates in the pedestals and the sliding l end silencer saddle plates appeared to be too tight to permit movement for thermal expansion.
If these connections were excessively tight at the time of the diesel generator tests, or the rough slots and grout interferred with thermal movements,
{
the cracking could be attributed t.o incorrect installation as well as inadequate design.
i ECN 22886, September 14, 1984 whicm was written to resolve NCR 213-582 on the Letdown Heat Exchanger, also requires modifying ^
the bolt slots on the sliding supports. Braidwood QA Sur-weillance Report 3305, January 9,1984 states "... the foundation details as documented on drawing M-1221 sheet 2, Revision 5 were found to differ from those as installed."
It appears that Ceco should consider the possibility of a VII-11 .
5164-z-generic prcblem in either or both d2 sign of supports for anc installation of equipment requiring sliding connections for thermal expansion (see Section III.B.4.b for additional details).
(7)
A pipe support was identified t;y the NRC CAT inspectors which had been 25,installed and inspected in accordance with ECN 19783, 4
i October 1984, 1 Rev. D, although Rev. E. of the support drawing had be issued September 13, 1984.
Rev. E of the drawing changed some physical items on the support, including the spring can size.
Subsequent investigation by S&L identified the following addi-tional six previously unidentified supports for which ECNs had been issued against superseded revisions of pipe support drawings. i
- 10G14005G
~
- 1AB22007R
- 1AB22034X
- 10G14006X -
- ICV 57001G . .
- 1RC04004V These discrepancies were stated by S&L to have occurred as a result of S&L Chicago modifying support designs due to analysis at the same time that the S&L site organization was modifying the supports to resolve field problems.
The discrepancies might have been identified and resolved when the final revision of the support drawing, incorporating all design changes, was issued prior to the final PGCo walkdowns.
S&L Braidwood Field Instruction (8RFI) 4 is being modified to prevent reocurrence of ts.is problem.
Discussions with PGCo personnel indicated that -it is not uncommon for them to receive ECNs written against superseded support drawings.
S&L by a FPR (i.e., FPR G-2137, 24, AugustSuch 1984). problems may b
[ c. Conclusions For the sample inspected, the control of the design change process is adequate.
Management attention is needed to preclude future design changes being made to superseded design documents.
i l
VII-12 i
SUBCONTENTION 5.B ,
Rorem QA Subcontention 5.B as a6nitted by the Licensing Board states as follows:
- 5. Contrary to Criterion III, " Design Control,"
, of 10 C.F.R. Part 50, Appendix B, Commonwealth
, Edison Company has failed to establish measures to assure that applicable regulatory requirements and design bases are correctly translated into specifications, drawings, i procedures, and instructions including provisions to assure that appropriate quality standards are specified in design documents and that deviations from such standards are controlled. Applicant has also failed to require that measures are established for the identification and cdntrol of design interfaces and for the coordination among participating design organizations, that the measures include the establishment of procedures among participating design organi-zations for the review, approval, release, distribution and revision of documents involving design interfaces; and that the design interfaces; and that the design control measures provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of performance of a suitable testing testing program.
B. Repairs to coatings by Midway Industrials in the Unit I and 2 containments were performed utilizing a coating system not qualified for -
i the Design Basis Accident in accordance with Section 5 of ANSI N101.2 (1972). (Inspection Report 85-15, Exh. 17.)
In its Motion for Sunmary Disposition, Applicant argues that this problem with containment coating repairs arose not because of a. failure of design controls, but rather due to an inspector's lack of awareness that he had observed a nonconforming condition. Applicant's Motion, i Subcontention 5.B at 8. Therefore, Applicant argues, the problem is one 1
of improper implementation of a procedure which properly incorporates the provisions of ANSI N101.2, rather than a design flaw. Id. In addition, w + - - - - - - - . - %. -_ , , -.,-.__-..~.-.--- --.,. __. _,_ _- _, -.. _,- _-, - _,_.-- -__ . . - -
- - - -. ---...-,-,-.-..y --
Applicant has determined that the problem was limited to one inspector ,
under circumstances which are unlikely to occur again. _I d . Applicant concludes on this basis that the failure which forms the basis for this subcontention is an isolated occurrence with no implications for other coating applications. Applicant's Motion, Subcontention 5.B at 8-9.
The incident which forms th'e basis for this subcontention was identified during a routine inspection conducted by the Staff. During this inspection, Mr. Kropp, the Resident Inspector for Construction at the Braidwood facility determined that the Applicant did not have documents to substantiate the qualification for Design Basis Accident conditions through laboratory testing of a coating system used for repairs in the Braidwood Unit 1 and 2 containments during 1978 and 1979.
This coating repair system involved the use of a power grinder, a primer coat, and a finish coat of phenoline-305. Affidavit of Wayne J. Kropp In Support of NRC Staff's Response to Applicant's Motion For Sunmary Disposition of Rorem QA Subcontention 5.B at 115, 7 [ hereinafter Kropp Affidavit]. ANSI N101.2 requires that such coating repair systems be qualified to withstand Design Basis Accident conditions. This standard I
delineates the test methods to be used to evaluate the coating repair process for its ability to withstand this condition. Kropp Affidavit j at 11 5-6. As a result of this inspection, the Staff determined that a portion of Criterion III of 10 C.F.R. Part 50, Appendix B has r,", been satisfied. Kropp Affidavit at 17. As corrective actions to preclude the recurrence of this problem, Midway Incustrials, the coating contractor, issued Nonconformance Reports 23-26 to document the areas of containment where repairs were performed using a process which was not
r qualified in accordance with ANSI N101.2. In addition Midway issued ,
QCP-3A, Rev. 4 delineating the coating repair process to be used.
Finally, S&L determined that the affected area involved approximately 200 square feet of the containments, and the areas rep?". red with the unqualified coating repair process were placed on Sargent & Lundy's coatings exception list. Kropp Affidavit at 11 8-9.
The Staff agrees with Applicant's conclusion that this particular problem with this particular type of repair represents an isolated incident affecting only a small area of the containments. Kropp Affidavit at 1 11. The Staff determined that the corrective actions of revising the applicable procedure and placing the affected area on the coatings exception list were adequate corrective actions. Id. Due to the small areas of the containments involved, the Staff concluded that the incident would not affect ^he ability of a component or system to perform its design function. M.
Due to the isolated nature of the incident describec* above, the Staff agrees with Applicant that there are no genuine issues of material fact to'be heard and that Applicant is entitled to a favorab1e decision as a matter of law. Based on the above, Applicant's Motion for Summary Disposition of Subcontention 5B should be granted.
.