ML20076D015

Rept on INPO Self-Initiated Evaluation for Byron & Braidwood Nuclear Station Const Projects

ML20076D015
Person / Time
Site:	Byron, Braidwood, LaSalle, 05000000
Issue date:	11/17/1982
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20076C924	List: ML20076C922 ML20076C992 ML20076D015 ML20076D046 ML20076D074 ML20076D111 ML20076D131 ML20076D135 ML20076D144 ML20076D148
References
NUDOCS 8305200647
Download: ML20076D015 (350)

Text

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COMMONWEALTH EDISON COMPANY Report on the INPO SELF-INITIATED EVALUATION for BYRON & BRAIDWOOD NUCLEAR STATION CONSTRUCTION PROJECTS November 17, 1982 O

B305200647 830511 PDR ADOCK 05000373 P PDR

l COMMONWEALTH EDISON COMPANY f -

MANAGEMENT REPORT INPO SELF-INITIATED EVALUATION OF BYRON AND BRAIDWOOD PROJECTS November'17, 1982 SCOPE In accordance with guidelines and direction from the _

Institute of Nuclear Power Operations , Commonwealth Edison Company conducted a Self-Initiated Evaluation of the Byron and Braidwood Nuclear Power Station Projects. Specifically, these plants were evaluated to the INPO Performance Objectives and Criteria for Construction Projects.

Commonwealth Edison Company, formulated a team of twenty people who had broad experience in design, construction, management, production, operating and quality assurance. Included on the team were five people from consulting firms; this was done in order to achieve an additional level of independence. The team evaluation assignments are shown on Exhibit A. Team members spent approximately four days in training and preparing work plans and schedules. The two week evaluation effort of the Byron and Braidwood Projects began on October 25, 1982 at Byron, continued the second week at Braidwood and concluded with a presentation to the Chairman and President and other top executives of the Company on November 17, 1982. The total time spent in the evaluation effort amounted to approximately 3,800 manhours.

The team conducted the evaluation at the Byron and Braidwood construction sites, the Commonwealth Edison Corporate offices in Chicago and the Sargent & Lundy _ Corporate offices in Chicago. In connection with the evaluation at Sargent & Lundy, i Edison team members met daily with similar teams from Illinois t

Power Company and Public Service Company of Indiana. These three utilities conducted evaluations concurrently at the Sargent &

i Lundy offices, but for the most part, each evaluation was performed independently.

l The documented Observations and the Performance Evaluation Summary and Detail Reports covering each Performance

Objective for each project resulting from this evaluation effort are included herein as Attachments I and II, respectively.

OVEP.VTEW AND ASSESSMENT 2.c rccult_ cc indiccted on Exhibit A and the sun =ary of results shown on Exhibit B of this report, show that the Byron and Braidwood projects measure up well against the INPO Performance Objectives. Of the 35 Performance Objectives evaluated at each site, the final outcome for about 2/3 of them was an acceptable

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determination. It is important, however, to understand what

" acceptable" means in this context. In some cases, Performance Objectives were termed " acceptable" even though deficient items were identified by the team. When deficiencies were minor or isolated and could not be considered generic, then a weakness was not reported, the Performance Objective was consida. red

" acceptable", and the deficient item was listed as a detail in the .

associated Performance Objective Detail Report.. Also, where the site had previously identified the deficiency through their own management control system, and proper corrective action was underway, then the deficiency was not called out as a weakness as it was no longer considered a problem that needed to be brought again to the attention of management. In total, about 1/3 of the Performance Objective evaluations uncovered weaknesses that need attention. These weaknesses, however, varied in degree of significance.

The Performance Objectives which were found to be satisfied as acceptable across both sites covered the following areas: Organization structure; management involvement and commitment to quality; control of design input, processes, interfaces and field change; control of corrective actions and test equipment; adequate project control, contract administration and document control; properly implemented quality programs; good test plans and good system status control. In view-of the many, days spent evaluating these areas, it is a credit to both sites to have so many project and quality activities. found acceptable based on the INPO Criteria.

Also, it is appropriate to state that Illinois Power and Public Service Company of Indiana did evaluations at Sargent and Lundy at the same time as Edison and none of the thtee utilities found any significant problems with the design activities.

A summary listing of the specific weaknesses and good practices identified for each construction site during the avaluation, as well as the respective committed corrective action for each problem, is included as Exhibit C. A total of 25 weaknesses and 8 good practices were identified for the two sites. Where similar weaknesses were identified at each site, for

~ the purpose of analysis, these have been grouped together and identified as " common to both sites". As a result, twelve areas having similar problems have been established and are listed ze,.:.rctely in EnLibit D.

The first four deficiencies are grouped together because they are about the same in degree of significance. This group includes, position descriptions, trending and design output. The design output items resulted in field problems but were limited in scope.

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The next four deficiencies have a greater level of significance. These include: following procedures, fire protection, industrial safety and scheduling. Problems in these areas have much more impact because they affect a wide range of work activities performed at the sites. Corrective action commitments have been established in these areas and consist of _

the following: A program will be put into effect by Project Construction to monitor conformance to procedures ; the fire protection program will be reviewed by the Project C'onstructionDepartment and specific corrective actions will be implemented by February 1,1983; industrial safety problems will be given positive attention and will be trended to better identify areas needing attention, and the Manager of Projects will lead an effort to review and improve the effectiveness of the project scheduling activities.

Finally, the last four deficiencies, common to both sites, indicate a need for a coordinated corporate effort toward site training requirements. Training was found to range from extensive to minimal and in many cases was not effective and suited to the needs of the people. This may be the underlying roct cause of some of the past workmanship and inspection problems. The Project Department committed to have the Assistant Manager of Projects examine, in detail, the extent of the weaknesses in the overall training area and establish correctiv'e actions by March 11, 1983.

Deficiencies specific to each site are listed in Exhibit E. Of the four deficiencies which are unique to Byron, the most significant one is the rate that systems are being turned over for

Pre-Operational testing. Inability to achieve a more balanced and timely turnover rate may result in a negative impact on the overall schedule. Attention to correct this situation is coccitted by Byron Project Construction.

At Braidwood, there are four weaknesses unique to the site. Two of these stand out as most significant - Inadequate procedures for system flushing and the need for experience in the Tech Staff Organization. Significant problems could develop in the handling and testing of equipment if upgrading the experience level is not achieved in a timely manner. Commitment was established to enhance the procedures and experience level.

From a revieu of the good practices identified at these two construction sites, it was concluded that three stand out and they are as follows: The establishment of a Quality Control Supervisor in the Project Construction Department at Byron; the system walk downs performed by Byron Station personnel and the establishment by CECO Quality Assurance of the new " Unit Concept" l inspections of unique plant elements which are being performed at both Byron and Braidaoed.

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As for an overall evaluation, the following are the team's specific assessments of each of the seven INPO Performance Ojbective areas.

. Organization and Administration The Project site organizations are properly structured and, the senior Company and Project management personnel throughout the projects are actively involved. The

. project management system, however, is somewhat informal in that position descriptions, or their equivalent, when they are established are not really used and generally they don't completely state the minimum qualifications, experience, training requirements and the authorities and responsibilities of each key pceition.

Design Control Design Control activities of the Architect Engineer, Project Engineering and site contractors doing design work were satisfactorily implemented. The areas reviewed during this evaluation and deemed acceptable were:

design input, interfaces, design processes, and design changes. Isolated design output problems were identified which resulted in field problems. This included flexible conduit exceeding allowable seismic limits and unacceptable internal terminations on non-safety related motors. Otherwise , the design output activities were found acceptable. Overall, the Architect Engineer's design control program was very thoroughly documented in procedures and standards and the program was understood and followed by the design staff.

Construction Control The Construction Engineering, Quality Inspections,-

Corrective Actions & Test Equipment Control areas are satisfactory. There is a need to improve the program for the protection and preservation of equipment. The area of plant cleanliness is also in need of improvement.

Adherence to procedures along with the adequacy of some procedures is in need of attention.

Frc;ect Support The Procurement, Contract Administration and Document Management activities ar'e satisfactory. Industrial Safety at both sites has the potential for serious problems to develop, primarily in two areas: Eye injuries and evacuation in case of a fire. Project

5

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Planning and Project Control activities are receiving a considerable amount of attention within Project Management and at each site; however, the single concern in'this area is the apparent lack of a unified project plan (or schedule) that is used by the Projects and the contractors for each site.

Training Training programs for the Project and Contractors organizations at both Byron & Braidwood vary from extensive to minimal which is an indication that Project Management has not established a comprehensive training policy and guidelines which would provide direction for all organizations associated with projects.

Quality Programs Overall, the Quality Program as applied to the Byron and Braidwood Projects is clearly defined, understood and effective. The only item of concern in this area was that new QA personnel at Byron need additional training before being allowed to perform surveillances by themselves.

Test Control The Test Plan & System Status Controls are satisfactory.

System deficiencies are not being identified by Project Construction prior to Pre-Op turnover. The rate of turnover of equipment does not appear adequate to support the fuel loading date. Tech Staff staffing levels and experience at Braidwood needs to be upgraded. Some Braidwood procedures need additional details included to preclude equipment change. The integration of the station personnel into the testing programs should contribute to the training and experience of the station ~

staff.

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Sl&fMARY

. In summary, although weaknesses were identified at each site, it appears that corrective action can readily be implemented

. for each of them. Furthermore, the team concluded that the design, construction and quality controls are being sufficiently ,

implemented at both sites, despite the identified weaknesses, to ensure the plants are being constructed correctly and this should result in safe and reliable operating facilities.

- . W' Team Coordinator i

f' .

1055Q -- .- . _

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. JiIBIT A l

PERFORMANCE OBJECT 2VES AND CR2TERIA '

. POR CONSTRUCTION PROJECT EVALUATIONS e

O

$ INDEI a o O.

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>e e.

L EVAI.UATOR -

PART TITLE _ASSTC M T9 OA ORGANIIATION AND ADMINISTRATION..................

CA.1 ORGANIIATION STRUCTURE........................... 'k. Ferguson CA.2 MANAGEMENT INVOLVEMENT AND COMMITMENT

~

TC QUALITY..................................... A. W. Kleinrath 1-F 2-F CA.3 THE ROLE OF FIRST-LINE SUPERVISORS AND MIDDLE MANAGERS................................ J. Bitel. F. Palmer DC DESIGN CONTR0L...................................

DC.1 CESIGN INPUTS.................................... R. Harris (EI)

• DC.2 C ES I GN INTERFACES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . *

• R. Curran (EI)

DC.3 DESIGN PR0 CESS................................... R. Harris (EI) 2-F DC.4 CESIGN CUTPUT....................................' R. Curran (;I) ,

DC.5 OESIGN CEANGES................................... M. Gerski CC CONSTRUCTION CONTR0L.............................

CC.1 CONSTROCTION ENGINEERING......................... N. Main (EI) 1-F CC.2 CONSTRUCTION FACILITIES AND EQUIPMENT............ J. Woods 1-P CC.3 MATERIAL CONTR0L.................................. H. P. Studt$Ar.n i l-F,1-CP l-F CC.4 CONTROL or CONSTRUCTION PROCESSES................ T. Didesch'(EI)

CC.5 CCNSTRUCTION CUALITY INSPECTIONS................. T. Didesch (EI) 1-CP CC.6 CONSTRUCTION CCRAECTIVE ACTIONS.................. E. Martin CC.7 TEST EQUIPMENT CONTR0L........................... T. Didesch '

PS PROJECT SUPP0RT..................................

2-F,1-CP 2-F.1-CP PS.1 INDUSTRIAL SAFETY................................ E R.. Vertovec/

Ancerson ..

1F PS.2 PROJECT PLANNING................................. A. Kleinrath PS.3 PROJECT C0NTRCL.................................. J. hoods 1-F PS.4 PROJECT PROCUREMENT PRCCESS...................... . H. P. Studt= ann PS.5 CONTRACT ADMINISTRATION.......................... R. Vertovec PS.6 DOCUMENT MANAGEMENT.............................. E. Martin -

TN TRAINING.........................................

2-F 2-F TN.1 TRAINING MANAGEMENT SUPPORT...................... E. Fitzpatrick l TN.2 TRAINING CRGANIIATION AND ADMINISTRATION......... E. Vilmere TN.3 GENERAL TRAINING AND CUALIFICAT10N............... E. Wiltere 1-F,1-CP 1-F.1-CJTN.4 TRAINING FACILITIES, EQUIPMENT, AND MATERIAL..... E. Fitzpatrick QP QUALITY PROGRAMS.................................

CP.1 Q"ALITY PR0 GRAMS................................. N. Main (EI)

PROGRAM IMPLEMENTATICN........................... R. Ferguson lCP.2 2-F 1-F,1-C? CP. 3 INDEFEN ENT ASSESSMENTS.......................... R. Ferguson CP.4 CCRRECTIVE ACTIONS............................... E. Martin TC TEST CONTR0L.....................................

1-F,1-CP TC.1 TEST PROGRAM................... .. .............. C. Schumann 1-F 70.2 TEST GROUP ORGANIIATICN AND STATFING............. G. Abrell TC.3 TEST PLAN........................................ C. Schumann 1.F TC.4 SYSTEM TURNOVER FOR TEST......................... G. Abrell j 1-F 70.5 TEST PROCEDURES AND TEST DCC"MENTS............... C. Schumann SYSTEM STATUS CCNTR0LS........................... G. Abrell l lTC.6 12-F 13-F. Tecs Coordir.ater - G. F. Marvus 5-OP 3-OP Management Otserver - W. J. Shewski Joint 3-F F-Findings

! GP- Oood Practices I,

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EXHIBIT B -

h November 16, 1982

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SUMMARY

OF RESULTS e OF THE INPO SELF-INITIATED EVALUATION OF THE BYRON /BRAIDWOOD PROJECTS 10/25 - 11/5/82 Of.the. thirty-five (35) Performance Objectives For Byron Alone

' 24' - had no weaknesses identified 9 -- had 5 had eleven

" good (11) weaknesses practices" identified identified For Braidwood Alone .

23 - had no weaknesses identified 10'3 -- had had "thirteen (13) weaknesses good practices" identifiedidentified Common To Byron /Braidwoo^d 2 - had three (3) weaknesses identified J

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EXHIBIT C CARNESSES & CORRECTIVE ACTION (RON PROJECT Finding)

(OA.3-1 -

Position descriptions were not available for some contractor supervisors and middle managers, and the minimum qualifications, experience and

. training requirements are not defined.

Corrective Action Construction will revicu and evaluate existing position descriptions and initiate revisions. Construction will also make all personnel aware of existing descriptions; these actions will be completed by February 1,1983 Finding)

(CC.2-1 The Program for the protection and preservation of permanent equipment is in need of improvement.

Corrective Action The surveillance activities employed to police these conditions will be increased in frequency and comprehensiveness. Additional visible indicators and instruction will be undertaken to increase personnel sensitivity to the needs. The activities will be enacted by February 1, 1983.

Findit m .

(CC.4-1)

Craft Foremen and Field personnel are not aa ;ys knowledgeable of applicable procedures and design documenti cumber of areas were noted where personnel did not adhere to site } .ee .res and design documents.

Corrective Action:

The importance of adhering to work procedures will be reiterated and re-emphasized to all contractor supervisors. This action will be completed by December 17, 1982. In addition, a conitoring program will be stablished to ensure adequate progress is being made in the coming months.

l EXHIBIT C EAKNESSES & CORRECTIVE ACTION I

!(RON PROJECT Finding)

(PS.1-2 -

The Fire Protection Program and its implementation need to be improved.

Numerous examples were noted that reflected procedural deficiencies and lack of complete awareness of the program.

Corrective Action The PCD-Administrative Assistant will review the fire protection program and its implementing elements using the examples provided as a basis to determine action and activities to be taken to enhance implementation.

The review will be completed and documented by December 17, 1982; the specific corrective actions will be enacted by February 1,1983.

Finding)

(PS.1-3 The effectiveness of the Industrial Safety Program needs to be improved.

A number of areas were noted where personnel did not adhere to established work procedures, especially involving eye protection, manual lifting and tripping problems, gas bottle storage, etc. Utilizing trending of accidents, injuries and fire reports would also serve as a means to enhance the program.

Corrective Action Trending is presently being performed on a minor scale by various contractors. Through the data base maintained by the Claims Department -

Workman's Compensation Program, a comprehensive project trending of frequency, severity rate, and incident rate of accidents and injuries will be performed. This activity will be directed by the PCD-Administrative Assistant, and will be in implementation by February 1983.

The importance of adhering to safety procedures will be re-emphasized to contractor craf t labor supervisors , and the safety personnel of the various contractors will be directed to increase the severity of their disciplinary actions when policing established lack of adherence to established procedures. This directive will be issued by November 29, 1502.

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EXHIBIT C MKNESSES & CORRECTIVE ACTION (RON PROJECT

. Finding (PS.2 & 3-1) -

The effectiveness of the Byron and Braidwood project scheduling system needs to be reviewed. Specifically, the various contractors do not have a composite schedule to work from.

Corrective Action The Manager of Projects will meet with the Project Managers together and separately to review present schedules and re-identify their needs and develop improvements by December 10, 1982. Engineering's involvement, the report distribution and trending analysis will be reviewed as to their n'eeds and benefits. A detailed plan will then be developed to improve the effectiveness of the projects scheduling.

Finding)

(TN.1-3 Evidence was not available that CECO Project Management in three of the departments have documented the qualifications and training needs of the individuals with respect to their assigned tasks, or are obtaining /using feedback or trending information to improve the effectiveness of the training programs.

Most of the instructors in all of the organizations have not had training in instructional skills including the preparation of training objectives and lesson plans. This type of training would enhance training effectiveness.

Corrective Action Due to the condition that this finding relates to an issue of broad scope with complex details, the extent of this weakness will be examined in detail under the direction of the Assistant Manager of Projects. The results of this review will be determined by January 14, 1983. The implacentation of the corrective actions established as a result of this revi_.. will begin by 12rch 11,1983.

EXHIBIT C MKNESSES & CORRECTIVE ACTION (RON PROJECT Finding)

(TN.1-2 -

The structural, electrical and HVAC Sheet Metal Contractors' Training Programs for their craft supervisory personnel and foremen need improvement in that the programs need to be more completely defined, and a method needs to be established to assure that the appropriate information is completely and accurately disseminated to the craft personnel.

Most of the instructors in all of the organizations have not had training in instructional skills including the preparation of training objectives and lesson plans. This type of training would enhance training effectiveness.

Corrective Action The PCD-Assistant Superintendent, in conjunction with the PCD-Quality Control Supervisor, the PCD-Structural Supervisor, the PCD-Electrical Supervisor, and the PCD-Mechanical Supervisor, will review the training programs and techniques employed by the structural contractor, electrical contractor, and HVAC contractor to determine what changes or additional activities are required to enhance training effectiveness. The review will be completed and documented by February 18, 1983; the specific corrective actions will be enacted by April 15, 1983.

Finding)

(TN.4-2 The Electrical Contractor needs to improve administrative controls over access to its multiple purpose training area to avoid distractions and interruptions while training sessions are in progtess. Additionally, the Electrical Contractor needs to provide additional training equipment to permit alternative modes of presentation to supplement the " stand-up" mode.

Corrective Action Corrective action will be taken to provide more adequate training quarters by remodcling the present structure to provide a dedicated single purpose area; this action aill be couplete by February 18, 1982. The PCD-Quality Control Supervisor, in conjunction with the PCD-Electrical Supervisor and t ?. e electrical contractor Project Manager, will perform a review to establish what additional training equipment, pre-formed mock-ups , and multi-media equipment would enhance the training ef fectiveness. The review will be completed and documented by December 17, 1982; the additional hardware will be in-place by March 4,1983

. EXHIBIT C

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EAKNESSES & CORRECTIVE ACTION RON PROJECT Finding)

(QP.3-1 -

The effectiveness of the PED field surveillance of storage activities needs improvement. The need for a written PCD procedure and training for this activity should be addressed.

Corrective Action An evaluation of PCD field surveillance of storage activities will be conducted to establish written procedures which more definitively establish' the objective and criteria associated with the checklists employed to document the activity. The evaluation will be completed, and rocedures will be created by January 4,1983. Personnel will be p'nstructed i in the revised requirements by January 28, 1983.

Finding)

=

(QP.3-2 CECO QA surveillances need improvement; specifically the newer personnel conducting these surveillances need to be better trained in order to achieve a more comprehensive surveillance program.

Corrective Action This OJT Program for Quality Assurance personnel is currently under review. The program will be revised to set minimum criteria for training in the area of conduct of surveillances. A program will be established whereby new personnel will conduct surveillances with or under the direction of experienced individuals until such time as his supervisor feels he is proficient. This prcgram-should assure that new personnel have adequate knowledge of surveillance requirements. This ' program will be fully implemented by December 17, 1982.

Finding (TC.1-2)

The walkdown by Project Construction prior to Pre-Op turnover is in need of iaprovement to provide early identifict tion of system deficiencies. In many instances these deficiencies arc ' eft to be identified by the station walkdown s .

1 EXHIBIT C LAKNESSES & CORRECTIVE ACTION TRON PROJECT Corrective Action Guidance for construction personnel will be provided in a form similar to that which is in use by the station. That is, general guidance on types i of items to look for during a system walkdown. The use of System Data l Packages as a list of the needed equipment for each test will be continued. Implementa- tion of this change will be ' completed by December 17, 1982.

Finding)

(TC.4-1 The rate of turnover of equipment to operating can be improved to more adequately support the start-up schedule. The rate of turnover of equipment for testing should be re-evaluated to assure that it contributes to a balanced, consistent release rate that supports the fuel loading date. Additionally, every effort should be made to ensure that systems are released in total versus in pieces.

Corrective Action: .

The rate of Turnover for testing has decreased in the last six months.

Several causes were identified. Those that could be dealt with were addressed as follows:

1. A field engineer was added to the Startup staff to follow the need for materials, purchasing activities, expediting activities and receiving activities.

2. Sargent & Lundy electrical and mechanical personnel were added to the daily startup meeting to expedite design information. A Project Engineering engineer was added to improve the interface with Westinghouse and other vendors.

3. Consolidated punchlists of items remaining to be completed are being prepared for all systems. This will better identify remaining work, allow for earlier identification of missing materials and better identify remaining design problems.

The rate of turaover will be re-evaluated with respect to fuel load dates Every effort is made to turn over complete systems for test. However, almost every system will have some minor problems at the time of turnover for test. These problems are negotiated with the Technical Staff before turnover. In many cases months will pass before completion, due to delivery times. Waiting to begin testing until all such items are complete could cause considerable delay in fuel load. A re-evaluation of system concition at turnover will be rauce.

l EXHIBIT C LOD PRACTICES (RON PROJECT

- FINDING (CC.4-2) -

The following good practice was noted: On seismic qualified block walls there are bright yellow signs (approx. 18" x 18") stating:

NOTICE THIS WALL HAS BEEN AS-BUILT NO ADDITIONAL ATTACHMENTS WITHOUT APPROVAL BY FIELD CHANGE REQUEST In addition, all attachments to these walls had a small as-built sticker a,ttached.

FINDING (CC.6-1)

The following good practice was noted: The Project Construction Department has reinforced their involvement in corrective action.

activities with the installation of a Quality Control Supervisor to oversee quality related activities.

FINDING (PS.1-1)

The following good practice was noted. The concractor safety personnel meet daily to correct safety problems at the early stages.

FINDING (TN.4-1)

The following good practice was noted: The Mechanical Piping Contractor's selection of multiple media and use of actual equipment as visual aids ~

enhance training sessions. Additionally, the use of pre-formed mock-ups during practical weld inspector examinations is an effective method of trainee evaluation.

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EXHIBIT C JOD PRACTICES (RON PROJECT FINDING (TC.1-1) -

The following good practice was noted: The station's portion of the system walkdown prior to turnover for Pre-Operational testing is well defined, extensive and includes four independent station groups to ascertain system readiness. Additionally, the recently initiated,

" Shakedown Testing" prior to Pre-Operational Testing should provide additional assurance of system readiness.

FINDING (PS.1-1)

The following good practice was noted: the accident followup activity by the Site Safety Supervisor points out repetitive accident cases to the respective contractor foreman for corrective action.

FINDING (TN.4-1)

The following good practice was noted: The mechanical piping contractor has provided an excellent facility for conducting classroom training. The selection and effective use of various training equipment, visual aids, and handouts, were observed to have a positive effect in the presentation of the material and in the attitude of the students toward training.

Additionally, a piping mock-up, including various hangers and snubbers, constructed for training purposes is an effective training aid for installation and inspection demonstrations and for student evaluation.

FINDING (QP.3-2)

The following good practice was noted: CECO QA has initiated a program titled " Unit Concept" surveillance inspections. This program initiates independent inspection on all items in a given unit of a system using the design documents as the criteria base. 'Dris is a positive departure from the industry practice of inspecting items. Details are stated in the detail sheets.

EXHIBIT C AKNESSES & CORRECTIVE ACTION LAIDUOOD PROJECT Finding)

(OA.3-1 Position descriptions for the supervisors and managers for this performance area are not in universal use for contractors and major entities of the Project Management Group. Where position descriptions are written, personnel covered by them were in some cases une.iare of their existence. Minimum qualifications, experience level and training requirements were not specified.

Corrective Action:

Construction will review and evaluate existing position descriptions and initiate revisions. Construction will also make all personnel aware of existing descriptions. These actions will be completed by February 1, 1983.

Finding)

(OA.3-2 PCD and PED trending programs and programs based on milestones are not as effective in determining job status as they could be due to the fact that the input data is not consistent among contractors or major Edison Departments. This makes advance trends difficult to determine. In addition, comparison of performance against other construction sites is not done.

Corrective Action:

"The Project Organization at Byron and Braidwood will undertake a detailed evaluation of the issues presented and identify appropriate acticns consistent with the evaluation report. This will be completed by January 14, 1983."

Finding)

(DC.4-1 A non-safety related drive motor used on the essential service water strainers was supplied with internal wiring connections which were not suitable for the expected moisture and vibration service conditions.

EXHIBIT C MKNESSES & CORRECTIVE ACTION LAIDWOOD PROJECT Finding)

(DC.4-1 Cont'd -

Corrective Action:

Project Construction Department acknowledges the concern identified. Proj ect Construction's normal practice is to replace all wire nut connections with an approved connection. The connections in question on the essential service water strainers were previously evaluated by Project Construction and it was determined to leave as is. The Project Construction Department did upgrade the connections in question. One layer of isulating and hi-temp tape was added to the individual wire nut installations to assure a good connection. The Project Construction Department feels this fix is acceptable for the intended use and should remain as is.

For any connections made on Safety-Related equipment that cannot be terminated per specification, advance verbal direction is obtained from Sargent & Lundy prior to making the connections.

The normal method of discovering these conditions is during testing activity by the contractor or OAD. These groups are aware of the need to identify these situations and bring them to the attention of Station Electrical / Project Construction Department for evaluation.

Finding (DC.4-2)

A flexible conduit, installed between a junction box and a Category I isolation valve, was found to be longer than allowed by the Architect Engineer's Standards.

Corrective Action:

1. The appropriate electrical installation drawing will be revised to indicate that the subject flexible conduit exceeds the maximum six foot length allowed in SLL STD-EB-146.

2. S&L will revise STD-EB-146 to a) clarify the manner in which flexible conduit longer than six feet is indicated on the electrical installation drawings and b) clarify it is the responsibility of the electrical installetion contractor to report all instances where the maximum si, foot length is exceeded.

3. The above documents will be revised by January 31, 1983

EXHIBIT C 1

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1AKNESSES & CORRECTIVE ACTION LAIDWOOD PROJECT Finding):

(CC.3-1 There is a need for improvement in cleanliness in the plant.

Specifically, long term storage of valves on the Turbine Room floor, pipe and cable pans covered with debris and installed equipment are not being covered to maintain cleanliness.

Corrective Action:

Project Construction Department will review and evaluate existing housekeeping procedures and revise them accordingly to meet current requirements by November 24, 1982.

F'inding)

(CC.4-1 A variety of procedures are not adequate and do not provide sufficient detail for personnel to perform the activities.

Personnel are not always knowledgeable of applicable procedure requirements. Some instances of failure to adhere to procedural requirements and for design documents was also observed.

Corrective Action:

The importance of adhering to work procedures will be reiterated and re-emphasized to all contractor supervisors. This action will be completed by December 17, 1982. In addition, a monitoring program will be established to ensure adequate progress is being made in the coming months.

Finding (PS.1-2)

The Fire Protection Program and its implementation need to be improved. Numerous examples were noted that reflected procedural deficiencies and lack of complete awareness of the program.

EXHIBIT C EARNESSES & CORRECTIVE ACTION LAIDWOOD PROJECT Finding)

(PS.1-2 cont'd Corrective Action The Project Construction Department will review the fire protection program and its implementing elements using the examples provided as a basis to determine action and activities to be taken to ,

enhance implementation. The review will be completed and documented by December 17, 1982; the specific corrective actions will be enacted by February 1,1983.

Finding (PS.1-3)

The effectiveness of the Industrial Safety Program needs to be improved. A number of areas were noted where personnel did not adhere to established work procedures, especially involving eye protection, manual lifting and tripping problems, gas bottle storage, etc. Utilizing trending of accidents, injuries and fire reports would also serve as a means to enhance the program.

Corrective Action Trending is presently being performed on a minor scale by various contractors. Through the data base maintained by the Claims Department - Workman's Compensation Program, a comprehensive project trending of frequency, severity rate, and incident rate of accidents and injuries will be performed. This activity will be directed by the Project Construction Department, and will be in implementation by February 1983.

The importance of adhering to safety procedures will be re-emphasized to contractor craft labor supervisors, and the safety personnel of the various contractors will be directed to increase the severity of their disciplinary actions when policing established lack of adherence to established procedures. This directive will be issued by November 29, 1982.

Finding (PS.4-1)

Incorrect use of, and improper procurement of cable grips.

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EXHIBIT C M NESSES & CORRECTIVE ACTION -

lAIDWOOD PROJECT Finding)

(PS.4-1 -

Corrective Action In summary, we acknowledge the use of unapproved cable grips.

Project Construction Department did identify the concern pr.' ar to the INPO evaluation. Project Construct.*_on Department feels this is an isolated instance where the systen of on-site purchase of material failed. As corrective action to prevent recurrence, Project Construction Department, QA and Purchasing vill be instructed in the correct procedure of on-site purchasing review.

This will be completed by December 17, 1982.

FINDING (TN.1-1)

Evidence was not available that most of the project organizations have documented the training needs of individuals with respect to their assigned tasks, or in using feedback or trending information to improve the effectiveness of training programs.

Most of the instructors in c11 of the organizations have not had training in instructional skills, including the preparation of training objectives and lesson plans.

Corrective Action:

~~

Due to the condition that this finding relates to an issue of broad scope with complex details, the extent of this weakness will be examined in detail under the dirt ction of the Assistant Manager of Projects. The results of this review will be determined by January 14, 1983. The corrective actions established as a result of this review will begin implementation by March 11, 1983.

FINDING (TN.1-2)

The trcining progranc cf contractors with craft personnel need improvement in assessing the effectiveness of their craft supervicor and foremen training, and a method needs to be established to assure that the appropriate information is completely and accurately disseminated to the craft personnel.

Ifost of the instructors in all of the organizations have not had training in instructional skills, including the preparation of training objectives and lesson plans.

i EXHIBIT C EAKNESSES & CORRECTIVE ACTION 1AIDWOOD PROJECT FINDING (TN.1-2) cont'd '

Corrective Action:

Due to the condition that this finding relates to an issue of broad scope with complex details, the extent of this weakness will be examined in detail under the direction of the Assistant Manager of Proj e cts . The results of this review will be determined by January 14, 1983 The corrective actions established as a result of this review will begin implementation by March 11, 1983.

FINDING:

(TN.4-2)

The electrical contractor needs to provide some additional training equipment and training aids / materials to enhance the effectiveness of the training sessions.

Corrective Action:

The deficiencies in the training area are being evaluated.

Training aids such as visual aids / samples, handouts, and overhead projector will be reviewed and implemented as needed. A new training room is under construction and will be provided with adequate facilities for training the personnel. The review will be completed and a course of action identified by November 24, 1982.

Finding (QP.3-1)

The effectiveness of the PCD field surveillances need improvement.

The need for a written PCD procedure addressing training for this activity should be considered.

Corrective Action:

An evaluation of PCD field surveillance activities will be conducted to establish written procedures which core definitively establish the objective and criteria associated with the checklists employed to document the activity. The evaluation will be cocpleted, and procedures will be created by January 4, 1983 Personnel will be instructed in the revised requirements by January 28, 1983

EXHIBIT C T.AKNESSES & CORRECTIVE ACTION 1AIDWOOD PROJECT j Finding)

(TC.2-1 The Test Group Staffing and experience is not adequate to support the flushing, testing, and surveillance procedure writing programs necessary for start-up. Additionally the absence of a training department at this time makes it difficult to compensate for the lack of experience.

Corrective Action:

The present technical staff has a cadre of 12 well-experienced supervisory personnel and 19 others, some of whom are experienced.

The additional new personnel required for the future testing are being obtained according to the budgeted schedule. Much of the required training for these personnel is being requested from the Production Training Department. Efforts are being made to obtain additional personnel with commercial PWR experience. The success of there efforts depends on the cooperation of the other Commonwealth Edison stations and departments.

The Braidwood procedure writing is aided by the use of Byron procedures. Action will be taken to strengthen the flow of information from Byron to Braidwood.

FINDING (TC.5-1)

The Generic Flushing Procedure CFP-0 Rev. 2 does not require sufficient detail in the system specific flush procedures to preclude damage to equipment. Furthe rmore , initial Pump Run Procedures ClFR-0 permits systems to be filled for long periods of time without meeting the water quality requirements of CFP-0 Rev. 2.

Corrective Action:

The flushing performed to date was conducted by experienced personnel.

New personnel are trained before they are certified to perform flushing activities. Because of tne addition of cany new personnel, the General Flushing Procedure will 'oe modified by January, 1983, to provide additional guidance.

The water chemistry control during and after final acceptance flushing is specified in the present General Flushing Procedure. The initial fill and rough flushing of dirty systems requires suitable but not necessarily high quality water. The Initial Pump Run Procedure will be changed by January, 1983, to include guidance on a suitable source of water for initial filling of the system and guidance on chemistry considerations should a period of wet layup occur prior to the final acceptance flush.

EXHIBIT C l

30D PRACTICES LAIDWOOD PROJECT FINDING (PS.1-1)

The following good practice was noted; the accident followup activity by the Site Safety Supervisor points out repetitive accident cases to the respective contractor foreman for corrective action.

FINDING (TN.4-1)

The following good practice was noted: The mechanical piping contractor has provided and excellent facility for conducting classroom training.

The selection and effective use of various training equipment, vusual aids, and handluts, were observed to have a positive effect in the presentation of the material and in the attitude of the students toward training. Additionally, a piping mock-up , including various hangers and snubbers, constructed for training purposes is an effective training aid for installation and inspection demonstrations and for student evaluation.

FINDING (QP.3-2)

The following good practice was noted: CECO QA has initiated a program titled " Unit Concept" surveillance inspections. This program initiates independent inspection on all items in a given unit of a system using the design documentes as the criteria base. This is a positive departure from the industry practice of inspecting items. Details are stated in the detail sheets.

i4Q

EXHIBIT D WEAKNESSES CONMON TO BYRON AND BRAIDWOOD -

• POSITION DESCRIPTIONS

• TRENDING ADVERSE CONDITIONS

• DESIGN OUTPUT - INTERNAL MOTOR CONNECTION

• DESIGN OUTPUT - FLEXIBLE CONDUIT LENGTH

• FOLLOWING PROCEDURES

• FIRE PROTECTION

• INDUSTRIAL SAFETY

• SCHEDULING

• TRAINING - C.E. PERSONNEL

• TRAINING - CONTRACTOR PERSONNEL

• TRAINING - FACILITIES

• PCD SURVEILLANCE

EXHIBIT E WEAKNESSES e

SITE SPECIFIC BYRON

• SYSTEM TURNOVER FOR TESTING

• PCD SYSTEM WALKDOWNS

• PROTECTION OF EQUIPMENT

• Q.A. SURVEILLANCE - EXPERIENCE LEVEL BRAIDWOOD

• FLUSHING PROCEDURES

• TECH STAFF EXPERIENCE

• EQUIPMENT CLEANLINESS CAELE GRIPS - IMPROPER USE

ATTACHMENT I INPO SELF-EVALUATION OBSERVATIONS FOR BYRON & BRAIDWOOD PROJECTS O

O

BYRON STATION October 29, 1982 -

INDEX OF OBSERVATIONS

1. Observation of CECO. Surveillance of Contractor

2. Observation 'of Project Operational Analysis Department Activities at Byron

3. Observation of Pre-Op Testing Activity

4. Observation of Trouble Shooting of Temperature Controller 5 Observation of System Walkdown of Aux. Feedwater System

6. Observation of Partial Walkdown of RC System Being Readied for Turnover for Pre-Op RC 6312 With Station Construction Engineer 7 Observation of Status Indicators for Calibrated Instruments in IM Shop

8. Observation of Storage Activities 9 Observation of Cable Pulling

10. Observation of Power And Control Cable

11. Observation of Conduit Installation

12. Observation of Piping Contractor Large Bore Pipe Supports

13. Observation of Training Class

14. Observation of Large Bore Pipe Supports 15 Observation of Fab / Installation - Small Bore Piping

16. Observation of Shop / Field Fab - Piping & Hangers 17 Observation of Rigging and Lifting

18. Observation of Installation of Block Wall Supports 19 Observation of Masonry Wall and Column Supports

20. Observation of Grouting Operation

21. Observation of HVAC System Installation by Sheet Metal Contractors Co. at Byron

22. Observation of Installation cf Instrumentation and Rework of Existing Instrumentation Systems 23 Observation of Coatings

24. Observation of Piping Contractor 25 Observation of Receiving Inspection C.C.3

26. Observation of Structural Steel Rework

27. Observation of Fire Drill (0915Q)

l Observation No. 1 BiRON STATION OBSERVATION.

OF CECO. SURVEILLANCE OF CONTRACTOR I. Sc qp e Conducted an observation of CECO. site QA surveillance of the mechanical contractor. Specifically of a hanger installation in the . Aux. building (364' Area 3)

II Observations A. The traveller package was selected at random and thoroughly reviewed 'for completeness. ,

B. The dimensions recorded in the as-built sketch were checked in the field to verify accuracy.

C. ,The QA inspector was not knowledgeable as to what cable tray contained safety-related cable.

D. The QA inspector could not answer questions relating to the S&L Spec. or the vendor requirements for jam nut torque, use of washers or where A-490 bolts were used.

E. In the area around the hanger three nonsafety-related cable pans were observed to contain debris such as 2x4's, 2" threaded pipe, paper, welders shield.

F. Two pipe whip restraints were observed to pass within 1/2" of adjacent pipes.

H. The QA inspector stated he had been in this job for seven (7) months.

III. Conclusions A. QA person did not display an awareness of the specification requirements which were beyond the scope of his surveillcace.

0890Q

Observation No. 2 BYRON STATION OBSERVATION OF PROJECT OPERATIONAL ANALYSIS DEPARTMENT ACTIVITIES I. Scope Numberous electrical testing activities conducted by Project OAD at the Byron site were observed on 10/25/82.

II. Observations-A. While conducting a control circuit test for fan OSXO3CC

'{ESW cooling tower), an OAD test enineer was found using an Information Only" print (6E-0-4030SX03, Rev. F) for troubleshooting purposes. This print was later verified to be the latest revision. This was determined to be an isolated case.

B. A Hatfield electrician was observed using an air wand to blow dirt debris from the interior of motor-generator 1RD02E (451' El. Aux. Bldg.) . The electrician was wearing a dust mask but was not wearing eye protection.

C. Personnel were observed cleaning the U-1 computer (U.-1 computer Rm 451' El. Aux. Bldg.) . They stated that the computer f an system would draw up dust through the cable pentrations in the floor and cover P.C. cards and internals. Aproximately every six (6) months it was necessary to shut down the computer and vaccum or blow off the internals. The general cleanliness of the room was not condusive to the proper operation of precision electronic equip ment . It was stated that the cable floor penetrations could not be sealed since all of the cables have not been

-p ulled .

D. Determination of the cable to the non1E motor drive for ESW strainer 1SX01FB (330' El. Aux. Bldg.) was observed. It was noted that the cable termination was being made in accordance with specification requirements (ring type connectors, torqued screws, Oskinite tape system), while the vendor motor terminations used a Sktotch-Lock type twist connector and vinyl tape. A review of Spec. 2749 for l the supply of the strainer, Spec. 2790 for general electrical installation and CECO. PCD personnel were l checked and there is no requirements for vendor terminations for these motors.

l l

i

Pege 2 Observation of Project Operational Analysis Department Activities -

Observation 2 .

E.- During the retermination referenced in D. above, an electrician was observed standing on the aluminun insulation cover on the adjacent SX piping. The aluminum

- cover was dented but not torn.

F .. It was noted that the white concrete finish coating'in a system cubicle in the 401' El. of the Aux. Bldg. (5 E of N 19' S of 24) was covered by a significant amount of ink marking. The marking consisted of grafitti and a large amount of construction information (FCR #'s, Traveller #'s etc.).

G. Development and implementation of project OAD administrative procedures was checked. The adminstrative procedures covered areas such as jumper control, sp are parts control, control of component removeal replacement

, , and control of OAD wiring drawing changes. The procedures were detailed and included interfaces for turnover to station operating. Field imlementation was acceptable.

III. Conclusions A. There is a minor document control problem at QAD.

B. Personnel safety requirements need more enforcement C. The condition of computer room cleanliness needs improvement D. Further investigation is required by engineering to determine the impact of vendor supplied connections on motors E. Requirements for protection of equipment and coatings need more enforcement F. The project OAD department has achieved good administrative control on jumpers, parts removal and replacement and wiring drawing changes.

0890Q

Observation No. 3 BYRON STATION OBSERVATION OF PRE-OP TESTING ACTIVITY I. Scop e .

Observed WX Coalescer test in progress.

II. Observations A. Upon arrival at the test activity, testing had stopped because of difficulty filling one of the vessels. We were told that a float valve appeared to be hung up and there was difficulty venting the tank. Water was being forced out the vent. The flange of the float had been loosened and water was issuing from the loosened flange.

B. Motors of the carbon filter pumps as well as equipment below was being splashed with water from the loosened flange. Motor was drip proof and probably would not be seriously affected but no effort was made to protect any equipment .

C. A Cabon Filter Pump was blue tagged for Pre-Op testing but still had a tag which read " Warning - check rotation before coupling pump to driver" III. Conclusion A. More attention to equipment protection is needed G. Equipment status is not necessarily indicated by attached tags.

0893Q

Observation No. 4 BYRON STATION OBSERVATION OF TROUBLE SilOOTING OF TEMPERATURE CONTROLLER I. Scop e Observed IM troubleshooting a temperature controller for the -

ventillation system for the main steam tunnel. He was assisted by the System Test Engineer. This controller was manufactured by Johnson Controls.

II. Observations A. The system engineer was testing the ventillation system for the main steam tunnel when a problem developed with a temperature controller that is used to shift dampers and trip the fans on low tecperature.

B. ' The temperature controller was brough to the IM shop for troubleshooting.

C. No Technical Manual was available for troubleshooting from Johnson Controls. The system engineer thought he could get-one from construction which he did obtain. This Tech Manual was only marginally useful for the IM as it was more of a " generic" type for pneumatic transmitters (not specific for this instrument)

D. IM found a nut that had been soldered in the transmitter i

that was broken. He thought that it should have been soldered but could not determine this from the procedure.

i

! E. IM was checking out the transmitter by placing the gas bulb

, in a heated bath and checking the output against the calibration sheet data.

F. IM Foreman thought there was probably a Tech Manual in the center File - additionally the IM Dept. is still developing their Instrument Procedures.

III. Conclusions The IM appeared to be ' adequately trained and was doing a good job troubleshooting this instrument in view of the fact that he had no Tech Manual. Until all of the station instrument l

procedures are written, increased emphasis should be given to t

providing the Instrument Maintenance Dept. with the vendor Tech l Manuals.

0895Q l -. . . -__ _.

6 Observation No. 5 BYRON STATION OBSERVATION OF WALKDOWN OF AUX. FEEDWATER SYSTEM I. Scope Observed system walkdown of the Auxilliary Feedwater System. -

The purpose of the walkdown was to determine readiness of the system for Pre-Operational Testing and provide a feedback to station construction on incomplete construction.and/or discrepant equipment.

II. Observations A. The System Test Engineer had a procedure that defined the criteria needed to evaluate the completeness of the system. He also had the latest P&ID with him.

B. These system walkdowns are performed by the following station groups -

Tech Staff (Syatem Test Engineer)

Operating Mechanical Maintenance Electrical Maintenance C. The STE checked the system valves, gauges, instruments, i

electrical connections, etc. for installation, calibration

& numerous other listed criteria. From this he developed a punch list of nineteen (19) items such as; temp erature sensing line bent, gauge installed too close to header, gauge not calibrated, nuts missing on packing gland etc.

D. There was a considerable amount of hanger and pipe restraint work in progress in the diesel driven Aux.

Feedwater pump room.

l

Page 2 Observation No. 5 Walkdown of Aux. -

Feedwater System III. Conclusion A. The STE performed a good walkdown of the system. -

B. The system of using four (4) separate groups is a good system for determining system status prior to turnover for Pre-Operational Testing.

C. This portion of the program provides for a good system walkdown prior to the Pre-Operational Testing.

e 0897Q 9

e

- . - - - . - - - . _ - _ - - - . - - _ - . - - _ _ r . - - - - - - - - -

Observation 6 BYRON STATION OBSERVATION OF SYSTEM WALKDOWN I. Scopa Observed partial walkdown.of RC system being readied for -

turnover for Pre-Op RC 6312 with Station Construction Engineer.

II. Observations-A. The engineer stated that it would be necessary to examine other Pre-Op Tests such as 6310 and 6311 to determine whether any component not on this pre-op equipment list had been turned over for testing. There was no P&ID marked to show what was turned over. This was done for system flush but not for testing.

B. .The engineer stated that he did not have a checklist for his walkdown. At Station Construction he had received no indoctrination or training or guidelines as for what he should look for during system walkdowns. (He had been assigned to the Tech Staff for a year before his assignment to PCD.) He said that he used engineering.

Judgement as to what constituted a construction problem in the field.

C. On either side of valve IRC8037A the spring hangers were

, loose. The valve appeared to have been turned over for l testing previously. The test engineer said that he ignored hangers in his walkdown unless they provided interference for some other component. The hanger group was responsible for the hanger walkdown and problem resolution.

D. The immediate action group of Station Construction was I

responsible to see that systems and components were

! available when needed for the Pre-Op Testing. It could not be determined that the hanger group provided a readiness report for the Pre-Op Testing. I was advised that Pre-Op Testing could be done if 70% of the hangers were installed.

Conclusions _

A. There is no indoctrination program for station l construction field engineers to perform walkdowns prior to l Pre-Op Testing.

B. There is no record of what is examined during PCD system l walkdowns.

0901Q

Observation No. 7 BERON STATION OBSERVATION' 0F STATUS INDICATORS FOR CALIBRATED INSTRUMENTS IN IM SHOP I. Scop e

. Examined equipment at the IM Shop in various calibration status-

'II. Observation A. In the IM Shop there were four (4) shelves for instruments calibrated for Project Construction.

1st shelf - Instruments to be calibrated were not marked.

2nd shelf - Instruments calibrated - all instruments were appropritely tagged.

.3rd shelf - Defective Instruments which could not be calibrated. Some were tagged as defective and some were not marked in any way.

4th shelf - Scrap instruments used for spare parts. These were not marked defective nor was there any indication of s the problem with the instrument. .

B. Numerous file cabinets contained defective instruments by various manuf acturers but these were not identified as defective.

III. Conclusion Defective instruments are not clearly identified in the IM Shop.

0903Q

Observation No. 8 BYRON STATION OBSERVATION OF STORAGE ACTIVITIES I. Scope Accompanied a PCD field engineer on a storage surveillance of -

structural steel, gallery steel and masonry steel .

II. Observations .

A. The field engineer stated that he did not review for rust on steel items in storage during the performance of each surveillance. He stated that rust is reviewed on a six (6) month basis. This six (6) month frequency could not be verified during the observation. The surveillance checklist requires review for rust.

B. The field engineer stated he had no concern about waist high weeds growing up through wood d Jnnage. The surveillance checklist requires a review of cleanliness (Possibility of Fire)

C. The field engineer reviewed sections of the rebar storage area and noted some rebars without dunnage. However., a complete review of the area would have identified bent rebars off of dunnage in row #1 of storage area.

D. The field engineer did not review all areas of the masonry steel storage area. Inspector missed the storage of masonry lintels. He stated that the storage areas change as construction progresses and he was not aware of all new storage areas.

E. The field engineer stated that he was not certain that the surveillance checklist used on this observation was the latest approved issue. He stated that he did not know how to check the issue date of surveillance checklists.

F. Both PCD QC and Site QA could not demonstrate what the latest approved issue of PCD surveillance checklist was in use.

III. Conclusions A. PCD Field Engineer was not cognizant of surveillance requirements and areas to be reviewed.

! B. The construction site does not appear to have a record of the review and approval of surveillance checklist form.

0906Q

4.

Observation No. 9 BYRON STATION OBSERVATION OF ~

CABLE PULLING I. Scop e

. Conducted field observation of cable pulling by craft -

electricians at the turbine room mezzanine level and cable spreading room over the main control room.

II. Observations A. Observed pull of two pre-cut cables from a 440V MCC to a M.O. valve. Excess cable at valve was coiled up but foreman did not know minimum coil radius required.

B. Observed pull of 250 f t. of control cable from cable spreading room over the control room to the HVAC panel and

.the Aux. bldg. radiation monitor in the vent stack. Cable pulling crew stepped on cables when crawling into pans.

The cables in pan 12089DClB were bunched up at 900 turn and hanging over pan edge. Cables in pan 1971DClB were also bunched up .

C. One member of the cable pulling crew stepped on an -

insulated pipe.

III. Conclusions t A. Does not demonstrate an awareness of cable installation requirements and conformance to Procedure #10 during cable installation.

l 0911Q 1

6 -

Observation No. 10 BYRON STATION OBSERVATION OF POWER AND CONTROL CABLE TERMINATIONS e

I. Scope Observed construction electricians terminating control and power.

cable in the Unit I computer room, Unit II turbine oil tank and service building.

II. Observations.

A. In the main control cabinets, control wiring terminations were found to be very congested and lacking neatness. This is due to the close proximity of the double row of terminal blocks and the fact that terminal blocks are surface mounted. The general foreman indicated that it was impossible to maintain neat terminations due to the fact that the cable entries were between the terminal blocks and previously terminated cables had to be disturbed to add new cable terminations.

B. The general foreman indicated that training for people doing terminations was verbal and not documented.

C. The electrician terminating the Unit II turbine oil pump was using an unsigned sketch made out by OAD. The sketch was dated. A check of OAD verified that they had produced the sketch based on the termination of equivalent Unit I P ump .

D. A crimp tool being used to termiaate wires in a service i building motor control center had a torn calibration sticker. The year was missing from the calibration date.

l l E. The electrician terminatin8 wires in the service building motor control center was using trichlorethy:ene to clean wires and lugs prior to taping. The fluid was contained in an unmarked glass jar.

III. Conclusions A. Future designs should consider elevating terminal blocks to eleviate crowding wires.

l B. Calibration stickers which are not legible are in use in the field. .

C. Cleaning fluids are not being properly controlled.

1 0906Q

Observation No. 11 BYRON STATION OBSERVATION OF CONDUIT INSTALLATION

1. Scop e Observe the hydraulic bending and installation of 1 1/4" conduit-and welding of conduit hangers.

II. Observations A. Craftsmen using hydraulic bender was knowledgable of this equipments operation.

B. Craftsmen applied pipe joint to both ends of conduit in a proper manner.

C. Scaffolding planking was not secured in any way causing a tripping hazard.

D. Some of the scaffolds were missing locking pins and crossbraces were hanging free.

E. Craf tsmen used a level during installtion and reversed it to check the level. .

F. Welder tacked hanger in place according to procedure with procedure at this location.

G. Craf tsman helper holding hanger in place for welder was not wearing safety glasses or a shield, gloves or long sleeves.

III. Conclusions A. Craftsmen installing scaffolding are not following' safety procedures.

t B. Personnel involved in welding operations were not wearing shields, gloves and long sleeves.

0913Q

Observation No. 12 BYRON STATION OBSERVATION OF PIPING CONTRACTOR INSTALLING LARGE EORE PIPE SUPPORTS -

I. Scop e Observation of piping contractor activities in the auxiliary -

building to evaluate the role of the first line supervisors and middle managers with regards to OA 3.

II. Observations- -

A. The fabrication of hanger supports, control and identification of sub-assemblies between fabrication shop and job site, and installation of hanger supports and hangers.

B. Interviewed Auxiliary Building Supervisor who is in charge of all piping and hanger work in building. Discussed his responsibilities and knowledge of job. No problem in either area. He demonstrated his capabilities by reviewing in detail the documentation of piping and hanger jobs picked at random.

C. Interviewed General Foreman (next level of management) in charge of al hanger work in Aux. building. Discussed his responsibilities and knowledge of job. No problem, a very strong and knowledgeable individual.

D. Interviewed Area Foreman (next level of management) and Crew Foreman. Span of control of personnel is good. Good control of work assignment, crew foreman spend at least 90%

of his time with the crew. Drinking or use of drugs not tolerated. All management personnel felt close control of crafts and any problems are detected early.

E. Procedures and documentation appeared good, checked some job packages which were found to be complete.

F. Operation of fabrication shop was excellent good control on material e.g. transferring heat numbers to material bring cut prior to cutting, good safety practices, use of safety glases for cutting, good housekeeping, documentation of caterial between shop and job site tracked and found acceptable.

Page 2 Observation No. 12 Piping Contractor G. Personnel at job site had completed work packages, using a procedure for setting 'of baseplate to wall. This job was selected random in walk through the Aux. building.

'III. Conclusion A .' The activities involved in the fabrication of hanger supports and their installation were found to be well planned and carried out.

B. Documentation and control of work packages appeared to be in good order to permit traceability in the future.

0914Q

'6 ---- ~- -

Observation 13 BYRON STATION OBSERVATION OF TRAINING CLASS I. Scope

~

Conducted a review of the mechanical piping contractor's -

training class for quality control personnel concerning hanger inspection.

II. Observations- -

A. The training coordinator had prepared a program for training hanger inspectors, which indicated the training would take five days.

B. A lesson plan was not used, but the subject procedures listed in the program were utilized as guides.

C. The student was allowed to read the subject procedures before the class discussion.

D. Quality control inspectors were utilized as instructors without any formal instructor training.

E. A test was not given for individual training areas, 'but a general and specific test is required for qualification of quality control inspectors to do hanger inspections.

III. Conclusion i A. Training programs are being conducted without lesson plans or formal training for the instructors, but the programs appear to be adequate.

i l

l 0904Q l

Observation 14 BYRON STATION.

OBSERVATION.

OF FABRICATION AND INSTALLATION OF LARGE BORE PIPE SUPPORTS ~

I. Scop e Conducted a review of pipe support fabrication and -

installation operations.

II. Observations A. Reviewed Process sheets (travelers) for the installation of pipe supports. The process sheets were prepared per the contractor's Quality Assurance Program Site Implementation Procedure B. Reviewed the crew sizes under each foreman. A magnetic board is used with each foreaan identified along with his

. crew. This allowed the superintendent to easily keep crew sizes even.

C. Observed the method used to store pre-cut support components and the assignment of supports to the foreman. Each foreman had their own storage area, which allowed the general foreman to allocate supports to .the crew short of work.

D. Observed the activities of the support component pre-cutting shop area. Area was clean and well organized. Pre-cut components were identified and metal banded together.

E. Observed the installation of a pipe support. The process sheet was checked to determine if all appropriate information was included. Weld procedures and inspection hold points were included. The workers were questioned concerning installation tolerances, weld sequences, and support function. They appeared very knowledgeable. No inspection activities were observed.

III. Conclusion A. The contractor's activities observed were found to be well planned. The craf t people understood their jobs.

l 0905Q

s Observation 15 BYRON STATION OBSERVATION OF FAB / INSTALLATION - SMALL BORE PIPING l 1

I. Scop e l l

Conducted a review of emall bore piping fabrication and ,

installation for 4 separate work packages. In addition, observations were made of pipe bending, fit-up of elbow and tee welds, QC inspections, and material traceability for above installations.

II Observations A. Heat number on 900 elbow was noted to be different from heat number recorded on the Field Order (material requisition) and on the material traceability part of Weld Process Sheet. The installation had been signed off by QC inspector. Subsequent review with QC supervisor established that the heat number discrepancy would not be detected by "walkdown" inspection because verification of fitting heat number is not a check item.

B. Material identification control was encountered during review of work activities for another work package. This was on a volume control system and involved a 1.0" t'ee and 1.0" 900 elbow. The heat code identifications were interchanged on the same documents as noted in A above.

Fit up (tacked) had been made for one weld joint using the tee. QC inspector detected the error during the I

inspection of fit-up, and documents were appropriately corrected.

C. QC inspector, checking a socket weld fit-up, stated that there is no mimimum on how f ar the pipe must be withdrawn from the socket. His criteria was that he must be able to see the scribed line. A second inspector stated that

( the minimum gap is 1/16", which is defined in a procedure.

D. Pipe spool with valve welded on one end was noted with valve opening not covered.

f

III. Conclusions I A. Material traceability trail (hardware vs. documentation) will not support the installation.

B. Material traceability trail (hardware vs. documentation) will not supp ort the installation.

C. Inspectors are not trained in a consistent manner.

D. Protection of equipment is in need of upgrading.

0907Q

Observation #16 BYRON STATION OBSERVATION

• OF SHOP / FIELD FAB ' PIPING AND HANGERS I.. Scop e -

Observation of the mechanical contractors activitie s related to shop and field fabrication of piping and hangers.

II. Observations A. The performance of work in the pipe f abrication shop located on-site was observed. Several on-going work packages were looked at, documentation was reviewed, personnel performing the work were intervi(wed, and procedures used to perform the work were discussed.

All documentation reviewed was acceptable. The work being performed was being done in accordance with approved procedures. The personnel performing the work had a good knowledge and understanding of the procedures and appeared to be adequately trained..

B. Field fabrication and rework in the field was also observed. The work was being performed to approved procedures and was also accompanied by' a work package prepared by contractor personnel. FCR s associated I with the rework being performed were included in the work package and noted on the applicable drawings.

The work was being performed in an acceptable manner and the people performing the work were knowledgeable in what they were doing. ,

C. In addition to the observations noted above a discussion was held with the contractors project manager relating to organizational structure, identification of trends, tracking of NCR's, ECN's and FCR's, and training of personnel. The organization structure was not clear and difficult to understand.

The organization chart in the Q. A. manual is different from the site organization chart. Tracking of NCR's, FCR's, and ECN's is not performed to establish trends. . Training is performed in accordance with a pre-established schedule.

Page 2

- Observation of Shop / Field - Piping and Hangers '

Observation #16 III. Conclusion A. Organization should be clarified to reflect the real organization. _

B. Shop fabrication and field fabrication is well controlled and documented.

C. FCR's, ECN's, and NCR's are well controlled and used in accordance with established procedures.

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Observation 17 BYRON STATION OBSERVATION OF RIGGING & LIFTING I. Scop e Observe rigging and lifting of pipe (for underground fire -

main) and fire hydrant for outside fire loop position 10 with P&H picker.

II. Observations A. The craf tsman in charge of the lift was not in visual contact with the crane operator.

B. Crane operator was smooth and precise on the pick.

C. Fire extinguisher on PLH picker was not sealed and was

. not up to proper fill pressure.

D. Rigging was placed to properly balanced the load.

E. While performing the lift, 3 craftsmen were not wearing hard hats.

F. While maneuvering equipment, all craftsmen were wearing work gloves.

G. The window on P&H picker was cracked, and operator stated that this would probably not cause 'any problems.

H. Craf tsmen working on hydrant were using proper wrenches for installation.

I. The 2" sling used for the lift was cut halfway through the sling.

J. Spring clip on eye of hook was inoperable.

III. Conclusions A. Rigging and lif ting equipment is not in proper working order.

B. Some safety procedures are not being followed.

4 0889Q l

Observation 18 BYRON STATION OBSERVATION OF INSTALLATION OF BLOCK WALL SUPPORTS I. Scop e Conducced a review of the installation of steel column ~

supports for block walls in the Aux. Building @ El. 401, Col.N-19 and various other locations in Aux. Building, Col.

2AWC197.

II. Observations A. Craftsman explained why column had to be installed in two pieces because of interferences.

B. Checked welder making splice joint on column as to his qualifications. He had a stamp designation J-S, and his superintendent stated that the welder was certified for the required weld.

C. The welder did not knou how many passes were required to complete weld.

D. The iron worker superintendent states that there was no procedure covering block wall support structural steel work.

E. Neither the welder nor his forman knew the setting requirements for welding machine. They indicated that the welder knew when proper amperage was attained.

F. Personnel contacted, both contractor and C.E.Co. , were knowledgeable of job requirements.

G. Fit-up of splice weld surveillance was not documented.

QC inspector stated that he observed fit-up.

H. Welder was using the same container for storage of used and new weld rod. Also, a rod oven was near by and in use.

I. Typical detail for splice welds on columns resulted from an FCR. S&L detail only good for 8" VF beams, Drwg.

S-1623 Rev. "K".

J. Col splice on 2AUC197 used a 4"x7"x5/8" plate (2).

Detail called for 3/8" plate.

K. Inspection of storage area for block wall reinforcement steel revealed unidentifiable material, slotted conn.

with large burrs and mixed bolts. No heat numbers on clip angles .

Page 2 Observation of. Installation of Block Wall Supports -

Observation 18 L .' Monthly weld'ing reports are filled out on a given day.

Some of the report information comes from surveillances

. that are 1-2 weeks old and by memory.

III. Conclusions A. Documentation of weld fit-up, root pass, cleanliness are not recorded at the time of inspection.

B. Weld rod control is not enforced.

C. Receipt inspection and material control questionable for block wall reinforcement.

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. Observation 19 BERON STATION OBSERVATION OF MASONRY WALL AND COLUMN SUPPORTS I. Scop e Conducted a review of preparation of existing solid masonry walls for tie-in to a new five foot thick reinforced solid block wall and additional shielding blockwork attached to structural tanks steel-beams in the' at EL. 409S around demineralized filter Aux. Building.

, II. Observations .

A. Craf tsmen were working in a poorly lit atmosphere for safety and good workmanship.

B. Craf tsman was welding parts of L piping hanger without shielding adjacent to masonry work area.

C. Masonry saw cutter had no eye protection.

D. Hand railing along work area not adequate.

E. No kickplates to protect workman below.

F. Craftsmen were using galvanized reinforcement that were rusted.

G. 3/16" diameter and ladder type reinforcement did not have sufficient mortar coverage as required.

l H. Tapping of metal door jambs in masonry walls gave a hollow sound indicating that they had not been filled with mortar or grout as required. Approximately 9 out of 9 tests sounded hollow.

III. Conclusion A. Safety requirements are not rigidly enforced.

B. More instruction to the masonry foreman and Blount QC personnel to ensure adherence to specification requirements.

0892Q ,

Observation 20 BYRON STATION OBSERVATION OF GROUTING OPERATION I. Scope

. Performed an observation of grout installation of anchor bolts -

in Rad-Waste Building.

II. Observations A. Grouting work area was cluttered.

B. Large shims under mixing hopper supports lef t very little grout area.

C.- Grout precedure (contractor Procedure #52) required 5 minute mixing time. Craftsman mixed 2-3 minutes, as called for in manufacturer's recommendation.

D. Inside of cored hole was not roughened per S&L specification.

E. Craftsman did not rotate bolts as they were lowered into grouted hole. He used a different unapproved method..

Procedure called for rotation of bolt.

F. Craftsmen in general followed procedure.

G. Craftsman was aware that curing was required, and he l

would proceed at the proper time.

I H. QC inspector was aware of above violations.

III. Conclusion .

I A. Violated grout procedure and job specification in some areas.

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Observation 21 BYRON STATION OBSERVATION OF HVAC SYSTEM INSTALLATION BY SHEET METAL CONTRACTORS CO.

I. Scop e Several areas where HVAC system installation was being performed by HVAC contractors at the Byron site were observed.

II. Observations

• A. An uncontrolled drawing stamped "For Information Only" was being used by contractor s personnel for the layout of HVAC plenum platework on the 467' EL of the Aux.

Building. The drawing used was a contractor take off of SLL Drawing M1318-2, dated 10-08-82.

E. On the 451' EL of the Aux. Building Damper OVA 85YA had a plywood walkway resting on the damper vanes.

C. The HVAC filter areas on the 451' and 467' EL's of the

' Aux. Building were generally dirty. A large amount of the dirt was from removed pipe insulation.

D. The sealtight (flexible conduit) portion of conduit 2VA361 was installed in such a manner that it could be damaged by the operation of damper OVA 46YA.

E. On the 467' EL of the Aux. Building, (Area 5), it was l observed that pump 1SH03P had been removed. The inlet i

' and outlet of the pump were not covered, and one flanged connection on the piping system where the pump was removed wac act covered.

F. The Unit 1 battery / charger room on the 451' EL of the l Aux. Building was observed to have a significant amount I of debris on the floor. This debris consisted of insulation, cardboard and light fixtures.

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Page 2 Observation of HVAC System Installation by Sheet Metal Contractors Co.

Observation 21 ,

The installation of CEA's tas observed at the bottom of G.

RCFC Loop 3 in the U-l Containment. The structural

. contractor performing the installation stated that 5/8" diameter anchors were being installed to replace 1/2" _

diameter anchors that had failed during installation.

The workman further stated that since the 5/8" diameter anchors were replacing 1/2" diameter anchors, the embeded length and torque requirements for 1/2" diameter anchors were being used. This is contrary to structural contractors Procedure #20, Rev. 16 (current revision as of the time of installation), for CEA installation. The workman further stated that no rebar detection had been performed since he " knew" that there were no rebar close to the surface. Procedure #20, Rev. 16 requires rebar detection and structural contractors CEA Traveler #1364 indicated that rebar location was required for this installation.

III. Conclusion A. Sheet Metal Contractor is using uncontrolled drawings for installation in at least one case. .

B. Requirements for equipment protection need to be better enforced.

C. Cleanliness in the U-l battery room and the filter areas i of the 451' and 467' EL of the Aux. Building needs improvement.

D. The locations of flexible conduits in the Aux. Building filter areas needs to be checked to ensure that the conduits will not be dausged by damper operations.'

E. Structural contractors has installed CEA's in accordance i with their own procedure. Installation personnel are not I aware of procedural requirements for CEA s.

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Observation 22 BYRON STATION OBSERVATION OF INSTALLATION OF INSTRUMENTATION I. Scope Observation of installation of instrumentation and rework of -

existing instrumentation systems are as follows:

A. Installation of feed water flowmeter reservoir pots (lPT-536).

B. Fabrication of hangers for instrumentation lines (IPT-515).

II. Observations A. Reviewed weld rod control and material control systems.

We also reviewed welder qualifications and talked with welders concerning procedures, which they used for welding and the applicable essential variables.

B. Review of the material control system indicated that the requirement for recording heat numbers for hanger material to provide traceability had been recently deleted.

C. Reviewed training records for production, foreman and QA/QC personnel. The records documented that training had been performed, but the extent of the training was not well defined.

! D. Reviewed the documentation packages associated with work in progress and also for work which had been completed, and the packages which had been reviewed by QA/QC personnel. All the documentation packages contained the required documents and required signatures.

E. Contractors personnel observed seemed to have a positive attitude toward quality and a willingness to work within the syste=. They also appeared to have a good working relationship with the CECO. project engineer, which seemed to improve the effectiveness of the contractors program.

F. There is no formal method for dispensing materials to be used in work packages.

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Page 2 Observation of Installation of Instrumentation -

Observation 22 r

III. Conclusions A. Training records clearly docunent the individuals who were present at the training and the subject of the training. However, the actual details of the scope of the training received was not adequate.

B. The deleting of requirement for recording heat numbers on materials for traceability should be re-evaluated.

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Observation 23 BYRON STATION OBSERVATION OF COATINGS I. Scop e Conducted a review of prime coating of structural steel hanger '

material.

II. Observation A. Painting shed contained large quantity of sand on floor and racks.

B. Shed had drop cord with receptacle cover missing.

C. Shed had mix of explosien proof and standard type fixtures.

D. Painting being done outside indicates considerable drift of spray.

E. Paint shed located in remote area to reduce the hazard from drift, fire and sand blasting. .

F. Paint and hazardous material stored in remote area in temperature controlled space. ' Recorded with calibrated instrument.

G. Material with outdated shelf life and/or out of specification was separated and controlled under lock.

H. Contractor QC performing 100% inspection on surface preparation and coating thickness utility spot check about twice a week.

III. Conclusion A. Very limited amount of painting being done on site. That observed was well inspected and controlled.

0910Q

Observation 24 BYRON STATION.

OBSERVATION, OF '

PIPINC CONTRACTOR I. Scope Observation of activities of Piping Contractor in the Turb. '

and Aux. Building of the role of the first line supervisors and middle managers.

II. Observations A. Unit 1 start-up feedpump, two crews working together, millwrights and fitters. Job in progress was fitting up of discharge flange pipe to pump casing.

D.' Interview millwright foreman who was in charge of millwright crew. Discussed his responsibilities and knowledge of job. No problem in either area. Control of -

crew appeared good. Did not have any procedure since work of aligning pump had been completed. The crew was present to assure there was no movement of the setting due to the makeup of the flange. Asked what movement was acceptable, he said no or zero movement.

C. General millwright foreman arrived in the area, discussed his responsibilities and control. No problem in answering questions.

D. Foreman spoke of control of personnel in areas of safety, drinking and drug use, and performing work assignments are good. Crew size small. Foreman at job site 90% of his time.

E. Procedures and documentation appeared good. The job packages, which were checked, were complete.

F. Information on pump and motor alignment is provided to production maintenance group . This was confirmed data to be used when machinery ir operated.

III. Conclusion l A. The contractor's activities involved in the setting of 1

rotating machiner'y were found to be well planned and carried out.

I l' B. Interface with production is good to provide smooth transfer of ionformation for plant start-up.

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BYRON STATION.

OBSERVATION.

OF ^

RECEIVING INSPECTION I. Scop e Accompanied a contractor on a receiving inspection.- _-

II. Observation A '. The receiving inspector took a copy of the procurement document with him to the receiving area, also a Material Receiving Report, which is the checklist used for the inspection.

B.. The Material Receiving Report is given a control number -

froc the log book.

C. At the receiving area, the inspector made a count of the items to assure they matched the amounts required by the purchase document.

D. The next step was verifying the sizes and heat numbers of the materials, also a check was made for physical damage.

E. The receiving inspector then applied the Material Receiving Report number to the items.

F. All the items were checked by the inspector to assure they were on cribbing.

G. The final step of the receiving inspection was completed at the stores office, where a review of the Material Test Report was checked against the A.S.T.M. Standards. The receiving inspector then signed the checklist for .

acceptable material. ,

III. Conclusion A. The receiving inspection was performed as required by the contractor approved procedure.

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. Observation 26 BYRON STATION OBSERVATION-OF -

STRUCTUPAL STEEL REWORK I. Scop e The structural contractor ironworkers were observed replacing

, beam bolting to comply with new design requirements.

II. Observation A. The workmen were changing the bolting on a beam at U2 412' EL. Column R13 to R14 by replacing the friction bolting with new bolts and a plate washer.

B. The work superintendent stated the changin bolting was under the direction of the QA/g QCof the Department and was due to a specification deficiency found by the

, architect engineer.

C.

The workmen did not have any work instructions or design drawings.

D. The work was checked against a recently (10-15-82) revised design drawing, S-915 Revision "W", and it was P discovered that the workmen had replaced the bolting at the R13 end of the beam with fri'c~ tion type bolting.

However, the revised drawing specified a slip joint instead of the friction joint.

E. The work had not yet been inspected by Quality Control, but it was verified that there is a functioning system in place for Quality Control to verify field conditions for compliance to newly issued design drawings.

III. Conclusion A. Contractor personnel did not consult latest design drawings to do work.

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6 Observation 27 BYRON STATION OBSERVATION OF FIRE DRILL I. Scop e Observed the assembly of the Fire Brigade for a fire drill at .

the Technical Support Center.

II. Observations A. The 22 members of the fire brigade assembled outside the Technical Support Center with 5 members, each bringing a

.20# dry chemical extinguisher.

B. Attendance was taken by CECO.'s construction fire marshall, in which all were present.

C. The safety man in charge of the drill explained the use of both CO2 and dry chemical extinguishers, and all members of the brigade participated in hands-on use of the extinguisher.

j D. The safety man stated that any time an extinguisher is used, it should be turned in to him for recharge.

E. The fire alarm siren was unable to be heard inside the Technical Support Center.

F. Some craftsman, not on the fire brigade, stated they were unaware of what the siren sounded like or what they should do.

III. Conclusion A. In some areas of the plant, the siren is not audible.

B. Some craftsmen are unaware of evacuation or fire procedures and the distinction of alarm siren.

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BRAIDWOOD STATION Ibvmber 5,1982 INDEX OF OBSDIVATIO!E Observation #1 - Protective Painting Observation #2 - HVAC Hanger Installation Observation #3 - Cable Termination Observation #4 - CECO QA Surveillance Observation #5 - Receiving Inspection Observation #6 - Section III Piping Observation #7 - Megger Test of Generator Fxcitor Observation #8 - meck of Belay Setting and Trip Set Points Observation #9 - A Bench Certification of a Test Gauge Observation #10 - Ptznp Test Observation #11 - Rigging and Lifting Observation #12 - A Fire Drill Observation #13 - Activities of Mechanical Contractor Steam Tunnel Work -

Observation #14 - Cable Pulling Observation #15 - Installation of Concrete Block Walls Observation #16 - Weld Rod Control Observation #17 - 0.A.D. Activities Observation #18 - Training Session Observation #19 - Project Construction Department Surveillances Observation #20 - Electrical Conduit Insta11atico Observation #21 - Small Bore Piping Fabrication / Installation Observation #22 - Pipe Fabrication Observation #23 - Iarge Bore Piping Installation Observation #24 - Project Construction Department Systen Walkdown Observation #25 - Crane Inspection Observation #26 - Electrical Contractor Training Session Observation #27 - Grouting Practices for Setting Equipment

(0937Q)

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& servation tb. 1 BRAI MOOD STATION OBSERVATION OF IROITITIVE PAINTING

. I. Secpe Conducted a review of paintirg contractor's offices, warehouses, paint shop, sandblastirg area and outside storage.

Reviewed sandblastirg of various metal stpports. No painting was in progress. Reviewed inspection and instrument calibration.

II. &servaticns A. Muriatic acid dru=s stored next to insulator's office trailer. No eye-wash station nearby.

B. Q.C. inspector for painting contractor stated that he inspects only safety-related work.

C. Project Construction Field Engineer stated that he was responsible for inspection and Q.C. of non-safety related painting.

D. No htnidity or paint thickness checks are made by Project Construction.

E. Verified that contractor has a procedure for instrumentation calibration. Calibration recod s were reviewed and found to be in order.

F. Relative humidity readings are taken a rnin4== of twice daily.

G. In stroage area for safety-related material tecp. recorder was in use with a Q.A. hold card attached.

H. A batch of carboline coating material #4674 was in storage available for use but was beyond its shelf life. No hold cards m re found on the material.

I. Two fire extinguishers had ne record of inspection.

l J. Fire retardant pair.t was stored in non-safety related storaSe area.

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Observations (cont). ,

K. 15 - 5 gallon cans of various flemahle materials, were stored on the ground outside of storage trailers.

L. 'Ibere are explosion proof lighting fixtures and outlets in the paint shop.

M. The paint bakiry oven within the paint shcp did not have explosion proof electrical connections.

N. The paint shop did_ not have any "No Smoking" signs.

O. Finished painted steel columns stored outside had rough surfaces due to sand contamination.

P. 'Ihe. interior of finish painted tubular stpport steel was not painted.

III. Conclusions A. Control of storage of hazardous materials needs inprovement.

B. 'Ihe contractor's Q.C. Inspector is knowledgeable of the contract test requirements and their inplementation.

C. Non-safety' painting needs more attention by the contractor s Q.C. and P.C.D.

D. Contractor's control of shelf life of paintirs materials is inadequate.

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Observation No. 2 ERAIDUOOD STATION OBSERVATION OF

, HVAC HANGER INSTAUATION

. I. Secpe Conducted an observation of the installation of a HVAC duct hanger.

II. Observations A. Hanger stpport brace was being added at the 439 elevation Col. 18-V.

B. Drawing sletch and approved F(R #L-4982 was at the work area.

C. Weld rods were in portable weld ovens.

D. Weld procedure was in the work area and the welder knew the procedure.

E. No portable fire extinguisher at the work area. 'Ihe work area was on a wooden platform. Craftscan did know a ,

portable fire extirguisher was on the floor below.

F. 'Ihe welder was grindirg the weld and his helper did not wear protective face s'aield.

I G. No HVAC being installed at this time.

III. Conclusion Except for certain safety practices the installation was being performed properly.

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4 Observation No. 3 BRAIADOD STATION OBSERVATION OF CABLE TERMINATION I. Scope Observed termination of a 3 conduceer 500 mem cable by contractor electricians in the 480 volt Aux. Building Unit Substation 133X 1AP14E.

II. Observaions' A. Attachment A.2 of Termination Procedure 4.3.9, " Termination of Rubber Insulated Okonite Jacketed Nuclear Station Cable" calls for cleanirg the terminal Itg and wire insulation with an appropriate solvent prior to applying cement and tape. The electrician did not clean the 1tg or insulation before applying the cement. A ccpy of the procedure was available at the job location.

III. Conclusion A. 'Ihe construction electrician did not follow the procedure for cleanirg cable terminations. .

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Observation No. 4 BRAIIM00D STATION OBSERVATION OF CECO QA SURVEILIANCE

. I. Scope A CECO Q.A. surveillance of the observation of electrical

! contractor installation of a conduit stpport FC-4 between 5.7 &

l 12 on 414 E1. in the Atoc. Bldg. Wis was a continuation of a surveillance which was begun earlier.

II. Observations A. The Q.A. Engineer (who has 16 months experience) took the drawings and went to the Aux. Bldg. where the work was being done. The electrical contractor's engineer and foreman were there and the problems associated with the job were discussed. The Q.A. Engineer was very knowledgeable of the job, spec requirements and the drawings.

B. Byron Station had initiated an Fm to change the base plate location of the conduit stpport, but because in this case there are separate drawings for Braidwood, the FCR hadn't been initiated at Braidwood and therefore the Q.A. Engineer .

found the problem on a surveillance.

C. When leaving the area, the Q.A. Engineer saw a loop of cable (110 ft. long) beirg stpported at a single point. He contacted an electrical contractor engineer and foreman and electrician who were close by and they corrected the situation right away.

D. 0 on rett.rning to the office a review was made of several surveillance reports of the electrical contractor. he reports included both cat.1 and cat. 2 work and were well written.

III. Conclusions A. We Q.A. Engineer perfonned a cocprehensive survei.11ance.

, B. We surveillances reviewed indicate good coverage of the electrical contractors activities.

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Cbservation No. 5 BRAIDWOOD STATION OBSERVATION OF A RECEIVING INSminON I. Scope Conducted an observation of a site contractor performirg a receivirg inspection.

II. Observations A. Warehouse person unloaded the shipment from the truck.

B. Contractor receiving form was used to document the type and amount of ite=s received.

C. Quality Control Inspector was informed of the shipment beirg received.

D. 'Ihe Q.C. Inspector verified that the materials were not damaged and subsequently cross checked to purchase order.

E. A Certified Material test report from the vendor was checked against the ASME Code Section II requirements. .

F. All items were found acceptable.

G. Receiving Report number was marked on the boxes for traceability.

H. Material sent to storage location.

III. Conclusion

'Ihe receivirg inspection was performed as required by the procedure.

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Observation No. 6 BRAIDi100DSTATION OBSERVATION OF SECTION III PIPING

. I. Scope Observation of activities of pipirg contractor in the Auxiliary Building concerning the role of the first line stpervisors and middle managers.

II. Specific Items Cbserved A. 'Ihe work of a ten man crew in the curved wall section 2 -

Unit 1 of Auxiliary Building. Crew was broken into four sub-grotps under the control of one foreman.

B. Major work in progress for one crew was field welding of pipirg assembly to an isolation valve for the fuel pool cooling system. Line is three inch stainless steel. Other crews were preparing weld ends for a containment pentatration, P-60, and were moving piping sub assemblies into work area.

C. Interviewed Foreman in charge of work. Discussed his -

responsibilities, qualifications and knowledge of job. No problems observed in this area. He demonstrated his capabilities when asked to review in detail ~ the work in progress making use of the work packages.

D. Interviewed General Foreman (next level of management) in charge of work in this area of the Auxiliary Building. He has three foreman reporting to him. Discussed his responsibilities and knowledge of the work in progress in his area. 'Ihe General Foreman explained what he expected of his foremen and work crews.

E. Job procedures and documentation appeared in order.

l F. Area is very confined making working conditions difficult, because of this Foreman and General Foreman have to do pre-planning of pipe installation and welding. Both men talked at length on how they do pre-planning to insure good working conditions for welding pipe.

I Personnel are not sure of Fire Protection Program, answers I G.

l were different on what to do if there was a major fire in f' the plant or their area.

H. Work safety practices appeared good. Foreman has a structured safety meeting once a week for 30 minutes.

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.4 III. Conclusions A. The piping contractor activities involved in the piping work in this section of the Atmiliary Building was found to be well planned and carried out.

B. Documentation and control of work packages appeared to be in good order, to permit traceability. Sanple checks of drawings for fuel pool cooling pipe indicated good tracking of work and revisions.

C. Considering the confined area some action is needed in the area of fire protection training.

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e Observation No. 7 BRAIN 00D STATION OBSERVATION ON MBGGER TEST OF

- GEh"iRKKR EXCI'KR I. Scope .

Observed two Operational Analysis Department Engineers (OAD) conducting a megger test of the main generator excitor, to ascertain the insulation condition. It was explained that large motors are meggered every four months and the Main Generator, Excitor, and the Diesel Generators are meggered on a monthly basis by GAD.

II. Observations A. 'Ibe engineer had an OAD test data sheet that had the acceptance criteria listed as " Polarization Index 1" and places for the data points.

B. At the start of the test, the engineer took readings at 15 second intervals, for the first minute after which he took readings at one minute intervals.

C. 'Ihere is a level bubble on the megger which indicated that the megger was not absolutely level during the test. I asked if it made any difference whether or not it was level. 'Ibe test engineer explained that it really didn't

! make any difference as they were just looking for relative direction on the meter any way, i.e. ; the meter was to increase with time during the megger test. 'Ibe ergineer l

however did stop and adjust the megger to level.

l III. Conclusion I

A. 'Ibe megger test was performed satisfactorily with no obvious problems.

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J Cbservation No. 8 BRAIDWOOD STATION OBSERVATION OF CHECK OF REIAY SEITING AND TRIP SET POINTS

1. Scope An observation was made of an OAD ergineer checking under voltage relays for setting and the trip set points.

II. Observation A. The engineer used a " Relay Setting Order" which was sent to the project from System Planning.

B. The ergineer used a Certified Digital Voltmeter for the relay check, when in fact he was not required to. He said they used these on all relay calibrations and checks.

C. The engineer had the latest electrical print.

D. The yellow line by the adjacent 480V Turbine Building Unit Substation-Buss 133VIAP72E had pipe laying inside of it, next to a Circuit Breaker. Project procedures forbid this practice. .

III. Conclusion The relay check went very well by a well qualified ergineer.

However Project Construction is not adequately enforcing the yellow clearance areas around MCC's and Switchgear.

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1 Observation No. 9 BRAIIM00D STATION '

OBSERVATION OF A BENCH CERTIFICATION

- OF A TEST GAUGE I. Scope An observation was made of an Instrument Mechanic performira a monthly bench certification of a test gatge.

II. Observation A. We IM selected a 2000psig test gatge that was due for a monthly bench certification.

B. The IM worked from an approved guideline, most of the work was in fact " craft capability."

C. 7he certification was performed with a Dead Weight Tester.

The test gauge was calibrated at five points.

D. The five points were listed on the " Test Report Data Sheet", which included the acceptance criteria.

E. The calibration sticker was replaced to show the current -

calibration status.

III. Conclusion i A. The test was performed well with no problems. At this site there is not much meaningful testing to observe due to the construction status.

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Cbservation '.4o.10 ERAIDWOOD STATION OBSIRVATION OF PUMP TEST I. Scope Conducted an observation of testing the electric and diesel driven construction fire pucps. (Elevation 401 construction pucp test.)

II. Observation' A. Diesel Fire Pucp had a large quantity of oil and oil dry underneath diesel ergine.

B. Craftsman visually checked pucp and motor before starting.

C. Craftsman started pucps and acknowledged alarms form Burns Security.

D. Water fire extinguisher was filled and dry chemical extinguisher was at proper pressure level.

E. Diesel fuel day tank sight glass indicated 3/4 full. ,

F. Craftsman started diesel both manually and by pressure drcp in the test position.

G. Batteries were clean, filled and craftsman checked for specific gravity.

H. Craftsman took apprcpriate readings according to weekly Fire Pucp Test Sheet.

I. Stpply valve in pit from demineralized water tank was locked in the open position.

i III. Conclusion A. 'Ihe craftsman seemed knowledgeable in the testing and operation of the diesel and electric driven fire pucps.

12 (0937Q) l

e Observation No. 11 BRAIW OOD STATION ,

OBSHtVATION '

OF RIGGING AND LIFrING I. &@e ,

Conducted an observation of the rigging and lifting of a 20" pipe section to be welded in place on the roof of the 426 elevation of the Turbine Building.

II. Observations A. Fire extinguisher on picker was sealed and monthly tag was signed off for October of 1982.

B. Oiler on picker was cleaning windows and waxing cab.

C. Rigging was placed to properly balance the load. ,

D. Craftsmen doing the lift on the roof were not wearing hard hats.

E. The crane operator was smooth and precise in the pick and also knowledgeable of this equipment. .

F. It was observed that craftsman in charge of lift was not using proper hand signals. The operator also stated this is a problem in craftsmen not using proper hand signals, l especially where the operator is not in visual contact with the load.

G. Ioad Charts were located in the cab of the picker.

Operator stated that the Ioad Garts are very helpful.

H. The operator of the picker was using hearing protection.

III. Conclusion

! A. The craftsmen doing lifting and rigging are not using proper hand signaling procedures, otherwise the rigging and lifting was satisfactory.

(0937Q) 13 l

5

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Observation No. 12 BRAIDWOOD S*dTION OBSERVATION OF A FIRE IRIII I. Secoe Conducted an observation of the Fire Brigade for a fire drill on the 451' elevation of the 1brbine Building.

II. Observation A. The Fire Brigade Drill was initiated by the C.E.C.O. Fire Marshall on the portable radio system.

B. 12 of 16 brigade members responded to the drill in less than 5 minutes. The remaining 4 members did not respond due to pagers not being able to receive the page.

C. Craftsmen in the area stated that they were unaware of any fire procedures or what to do in the event of a fire.

D. The brigade leader recorded attendance and lectured on the use of extinguishers and fire hose.

E. 7be C.E.C.O. Fire Marshall stated that 2 drills per month are conducted at different locations in the plant.

F. The brigade leader stated that all brigade members receive hands on extinguisher training annually.

III. Conclusions l A. Craftsmen are unaware of evacuation or fire procedures and the distinction of alarm siren.

B. Adequacy of pagers should be reviewed.

(0937Q) 14

~

@servation No.13 BRAIIMOOD STATION OBS EVATION OF ACTIVITIES OF MECHANICAL CONIRACITR STERI 1UNNEL WCRK

. I. Secpe

@servation of activiti'es of mechanical contractor in Unit I St'eam Tunnel of the role of the first line supervisors.

I.I. Specific Items Observed A. The work of a crew on mainsteam piping both B31.1 and Section III pipe.

B. Work was being done on one of the main steam lines on weld repair. These were welds that had defects in them, grinding and rewelding was being done. These repairs were downstream of the main steam isolation valve, therefore is B31.1 pipizg code.

C. Take off header from main steam line to safety valve header was being fitted tp.

D. Work packages and documentation of work in progress were in .

order.

E. Interviewed General Foreman in charge of all work in the steam tunnel areas. Discussed his responsibilities and knowledge of the work in progress in his area. He has Area Foreman work for him. Crew sizes 8 to 10 men. Span of control very good.

F. General Foreman discussed his qualifications and had a good knowledge of the work being done in the steam tunnel and welding procedures and repair procedures.

G. Work safety practice ~ appeared good. Confirmed there is a structured safety program.

l l

III. Conclusion

~

i

! A. The mechanical contractors activities in steam tunnel area were found to be well planned and carried out.

B. The role of the first line stpervisor was good, indicating good control of crews and the work in progress. Foremen were knowledgeable in procedures and control documentation.

15 (0937Q) l

-- w . ,---,,,w --- - - - - - -- - -

j Observation No. 14 l BRAIDWOOD STATION l OBSERVATION l OF '

CABLE FULLING I. Scope Conducted field observation of cable pullirg by contractor electricians in the cable spreading room over the control room, the Auriliary Buildirg and attended the weekly Status Meeting of electrical foremen at the contractors office.

II. Observations A. Observed cable pulling operation in the cable spreadirg room above the control room.

B. When leavirg the cable spreading room over the control room at location 10-L, a 3" capped pipe was observed leaking water into a cable tray and onto the ladder used to enter the cable spreading room. The foreman stated that the leak had been reported about 1 year ago.

C. When attending the weekly Status Meeting the foreman brotght up job related problems after reportirg work .

status. 7Vo foremen reported that their work was delayed due to a shortage of 1 1/2" conduit and 3/43" gray flex conduit. The moderator stated that this material was on order, but the delivery date was unknown.

III. Conclusions A. Cable pullirg activities were generally satisfactory.

B. The corrective action program for handling deficiencies needs to be strergthened.

C. Coordination of stpplies with schedule requirements for construction needs inprovement.

(0937Q) 16

&servation No. 15

~

BRAIIM00D STATION OBSERVATION OF INSTALIATION OF CONCRETE BIlXX k%LLS

- I. Scope Conducted a review of specification and plans for installation of solid concrete block walls and it's reinforcing. Reviewed

. the storage of masonry material, mixing of mortar, cutting of block, laying of units and installation of reinforcing. Iooked at Q.A. procedures and material test, reports.

II. Observation A. Check for block sa:ples - no longer on site.

B. Monthly sieve analysis being made on mason sand.

C. Gecked out verbal approval of Huron type-M cement.

D. Bricklayer stperintendent stated 38 average size shovelfuls

. of sand equal to 3 cubic feet.

E. No measuring box at mixer site. .

F. Poor weather protection allowing rain water- to drip into mixer and sand pile. Gement was protected by approved cover.

G Plastic milk container containing gasoline was in mixing area.

H. Bricklayer was grooving mortar bed joints.

I. Gecker board and checkers were laying inside of ventilation duct.

J. Neither CEro Q.A., PCD or bricklayer stperintendent were aware that Cert's were needed on mortar cement.

K. Looking for test reports on mortar found two other Q.C.

reports misfiled.

L. CECO Q.A. and Project Construction engineers were unclear on masonry work testing requirements.

M. Door freces, in cost cases, inspected sounded hollow.

(0937Q) 17

III. Conclusions .

A. Inkdequate control of mix proportioning. No leeway in contractor's procedure.

B. Not all job specification and test requirements are followed.

C. P.C.D., Q.A. and contractor are not aware of all details of job specifications.

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i 18 l (0937Q) f

Observation No. 16 BRAIDWOOD STATION OBSIRVATION OF WELD ROD O(NIROL

. I. Scope

~

Conducted an observation of Weld Rod Control by the electrical contractor II. Observations A. Containers of weld rod stored on racks in warehouse.

B. Weld rod being issued to satellite stores areas in plant in 500# lots.

C. Rod oven tecperature control gatges are calibrated.

D. Field foreman issues a request for additional weld material.

E Storekeeper at satellites reviews form for all pertinent data and if correct issues 5# of weld rod.

F. Welder takes weld rod to work area and stores rod in ~

portable oven.

~

G. Weld rod to the fabrication shcp is given to the foreman directly (no material request is required).

H. Procedure for control of weld rod does not address issue and control of weld materials used in the fab shop.

III. Conclusion A. No formal system for control of weld rod in the Fabrication Shap.

(0937Q) 19

@servation No.17 BRAIDWOOD STATION OBSIRVATION OF O.A.D. ACTIVITIES I. Scope Accoapanied O.A.D. Supervisor and observed various O.A.D.

tests. This included an O.A.D. megger test of the exciter,

lanping of a meter circuit, and general observations of the l make-up demineralizer, heating boiler and various switchgear.

II. &servations A. Observed O.A.D. Megger Test of exciter. See writetp on this subject.

B. Briefly observed lanp test by 0.A.D. personel at Bus 133VIAP72E. Test was stopped because of problem with test switch.

C. At 69KV Bus 157 and 158 several breakers were taped orarge, but there was no yellow tape on the floor to ma4*ain operator clearance.

D. Observed several instances of equipment and material inside the yellow taped area at switchgear. O.A.D. Supervisor contacted electrical contractor to clear the yellow taped area.

E. At Bus 153, it was noted the reactor coolant punp underwattage relays have a warning tag which requires relay blocks to be removed before energizing the equipment.

O.A.D. does not account for these relays which must be unblocked, but maintains a listing of relays which they have made ready for service.

F. At one of the switchgear a worker, encloye.3 by the structural contractor, voiced his ccacern about welding and grinding near urprotected transformers. The O.A.D.

Stpervisor agreed that this was a dangerous practice and energized electrical equipment should be protected before welding or grinding in the vicinity. The worker voiced concern that some of the newer people on site were not aware of the hazards of working around electrical equipment and he suggested something more striking than the yellow tape to make the crafts aware of energized electrical equipment.

(0937Q) 20

III. Conclusion A. Project Construction policies on yellow tagged clearance areas near switchgear and energized electrical equipment are not being enforced.

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. (0937Q) l

.j i

1 (bservation No. 18

~ .

BRAIDWOOD STATION OBSERVATION OF

'IRAINING SESSION I. Scope Observed the mechanical piping contractor conducting training classes for quality control personnel concerning field design change procedure revisions and qualification for receiving inspectors.

II. Items Observed A. 'Ihe classroom facility was good, isolated, well lighted and use was specifically for training.

B. 'Ihe instructor used a copy of the revised procedure in the presentation.

C. 'Ihere were approximately 30 people in the class, many of whom showed that they were knowledgeable of the existing procedure and were followirg the progress of the trainig by the questions asked on how the new revisions would apply to the work. .

D. 'Ibe instructors used transparencies and an overhead projector to display sarple forms and how to fill them out.

E. 'Ibe instructor appeared knowledgeable. 'Ibe instructor gave f exa::ples of types of stainless steel weld filler metal that was cocpatable for dissimilar metals.

F. 'Ibe instructor for the receiving inspectors qualification class had an outline of the material to be covered and reference material for handouts.

1 G. Both classes, and especially the class on receiving inspection, showed enthusiasm on the part of both the instructor and students III. Conclusion

'Ihe mechanical pipirg contractor's training classes which were reviewed appeared to be effective.

22 (0937Q)

&servation No. 19 BRAliE00D STATION OBSERVATION OF

. PROJECT CONS'IRUCTION DEPARTMENT SERVEILLANCES

- I. Secpe Acconpanied individual PCD field ergineers on scheduled PCD surveillances of storage of electrical items, installation of masonry blockwalls and tack welding of HVAC Duct.

II. &servations A. Accocpanied an electrical PCD field engineer on a storage surveillance of electrical items stored indoors and outdoors at Braidwoood.

1. During a review of the site electrical contractor's warehouse, two boxes marked "Flamable Material" were observed to be stored on a shelf on the typer level of the warehouse without adequate ventilation. Cigarette butts were noted in the area. The PCD surveillance checklist requires that fla-ahle materials be stored in a well ventilated, marked area. This item was marked acceptable on the checklist. .

2. The surveillance of the electrical storage areas for

' structural steel. unistrut and cable pans was conducted from a car. H5 stated that walkthroqghs were part of his daily activities.

, 3. The surveillance was to cover all electrical items presently stored on site. The cable storage area and equipment stored in the plant were not reviewed during this surveillance. .

4. The field engineer stated that he did not receive trainirg on PCD surveillances due to his past Q.A.

experience.

5 The PCD/SCD Procedure Manual does not address training on PCD surveillances.

B. Accocpanied a structural PCD field engineer on an installation surveillance of easonry block wall being j

installed and of masonry block wall previously installed.

1. The PCD field engineer stated that he did not know the acceptance criteria for allowable rust on rebar.

23 (0937Q)

I

17 -

2. @ served the bars being stored in enpty cable pans.

- 'Ihe PCD field engineer stated that items could be stored in enpty cable pans only.

3. PCD field ergineer observed the rebar spacing prior to placemnt of mortar. 'Ihe engineer knew the reinforcing requirements of the specification.

4. 'Ihe handle and stem of a valve on the steam blowdown condensor tank was found protruding tp through a cutout in a scaffold deck without any protection. 20 lb. ,

masonry blocks were stacked 10 inches from the valve stem. On the same scaffold, the motor of a valve operator was found protruding up through a similar cutout without protection. Masonry blocks were also stacked near the motor protrusion.

5. Eight 20 lb. masonry blocks were found stacked on a mortar board on top of a cable pan which contained 14 cables.

6. 'Ihe field engineer stated that he did not receive training for conducting PCD surveillances.

C. Accocpanied a mechanical PCD field engineer on a welding surveillance of HVAC Duct. .

1. 'Ihe PCD field engineer was knowledgeable of the specification requirements for duct welding. ,

2. '1he welder's qualifications were reviewed and found acceptable.

i

! 3. A welder's helper did not wear any hand or eye protection during the welding activities. 'Ihe welder

. was properly dressed.

l

4. 'Ihe PCD field engineer stated that he did not receive training for conducting PCD surveillances.

III. Conclusions A. PCD field engineers are not given training on how to perform PCD surveillances.

B. Provisions to protect installed equipment are not being prcperly implemented.

C. Some material is beirg imprcperly stored in cable pans.

24 (0937Q)

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

Observation No. 20 MXDD STATION OBSERVATION OF

. ELECIRICAL (DNDUIT INSTAU.ATION

. I. Scope

~

Observed the installation of hanger stpports and electrical conduit by the site electrical contractor.

II. Observation A. 'Ibe foreman and general foreman were knowledgeable of l

drawing details and requirements.

B. 'Ihe fore =an stated that the minimum clearance requirement between electrical installations and other installations was one inch. He stated that items installed closer than 1" were reported to the site electrical engineering department by a trouble letter. A review of electrical contractor Procedure 4.3.1 states that min 4== clearance requirements are 3" edge to edge. After reviewing Procedure 4.3.1, the foreman stated that he was not aware of the 3" requirement.

C. 'Ihe foreman stated that he did not receive training on revisions to procedures. He stated that his procedures manual was removed by the site office personnel who updated

! the manual and then returned the manual to the field. He also stated that revised areas of the procedures are not

) clearly identified or flagged.

D. Stperseded drawings which are retained in the field for recording purposes are not marked "For Reference Only."

Observed drawing #20El-3331A Rev. S was found in the foreman's work area, however Rev. T was observed to be the latest approved drawing.

E. Craftsmen using a hydraulic bender and cutting saw were knowledgeable of the equipment's operation.

F. Scaffold planking was not secured and was cluttered with debris.

G. Craftsmen were not wearing eye protection in the conduit grinding area.

h -

H. Cable pans were used to store scaffold poles, cable pan hangers, tools and conduit.

25 (0937Q)

I. A scaffold platform access ladder was observed to have cracked ladder ruogs.

III. Conclusions A. Foremen are not beirg trained on revisions to procedures.

B. Installation drawings are not always controlled.

C. Safety requirements are not rigidly enforced.

9 3

(0937Q) 26

• 9

Observation No. 21 BRAIIE00D STATION OBSERVATION OF SMAIL BCRE PIPING

- FABRICATION / INSTALLATION .

I. Scope _

Reviewed the activities associated with the fabrication and installation of small bore piping. Specific activities were:

requisition of material and subsequent control, fitup, welding, Q.C. inspections, weld material control and nondestructive examination.

II. Observations A. PT inspection of four welds was incocplete relative to 100%

coverage of the circumference. Developer was not applied to approximately 1 1/2" of each weld. Trainee performed, Invel II interpreted.

B. The penetrant batch number recorded on the NDE report form was 81J106. The penetrant on the job was not in the original container. It was in a glass jar with a number written on cover - 79E0'6.4 .

C. Necessary NDE reports were cocpleted but the PT operation was not signed off on traveler. It was stated the inspector would return later in day to cocplete the

! traveler.

D. Storage of small bore fittings in the Aux. Bldg. storeroom is neatly maintained. It is apparent that access to and issue of fittings is under good control E. Hold points for inspection of fittps are on an undefined sa::ple basis - perhaps 1 of 5 or 6. Observed pipe being installed in boric acid system. An identified Q.C. hold point was by-passed. The hold point was for a fitup inspection.

(bserved pipe being fabricated under drawing #M-2542C-112 l in Containment Bldg. #1. Weld #9 had a hold point identified for Q.C. to inspect the fitup. This hold point was by-passed. Foreman stated that the Q.C. Inspecter had been at fab area earlier to check this weld and two others. However, the Q.C. Inspector stated he was not asked to insoect Weld #9 earlier and had not done so. L' hen he checked scribe marks on the pipe and fitting for veld in question, he determined that " pull-out" for this socket weld was questionable and may be inproper 27 (0937Q) l

Cbservations (cont.) .

F. The " Report of NDE" form has a line for the Q.C.

Inspector's signature. The Q.C. Inspector in the main small bore pipe fab area in the Aux. Bldg. is initialling l

instead of signing.

G. Weld numbers were not marked on the Safety Injection System pipe for the FW5A & 5B Welds (drawing PG2539A-47).

1

! H. Overall documentation at the work locations appears to need

( attention. Controlled ccpies of isometrics which serve as a record of fabrication and inspection activities have a l lot of poorly written remarks and other markings. In one case original FW numbers were crossed out and changed with no substantiating signatures or remarks. Stores Requests quantities are often obliterated by signatures.

I. Ibted several CV System limit switches were installed, but had parts uncovered (Valve 1C110B). Noted also that limitorque valve ICV 8104 was missing a cap. The foreman stated that this had been identified several weeks ago, but no action has been taken.

J. On weld travelers (drawing 2939-29) numerous " visual, final weld" inspections have been initia11ed but not dated. Q.C.

Inspector stated he initials without dating as part of his personal accounting system to ensure he knows what welds he is wor' on. If such a system is needed, it should not ,

involve initialling method to avoid any suggestion of inspection cocpletion. .

III. Conclusions A. Foremen are not assuring that production personnel l recognize and honor Q.C. hold points.

B. Better attention to the clarity of records which support fabrication and inspection activities is needed.

C. The traceability of penetrant material to a specific job is questionable.

28 (0937Q)

Observation Ib. 22 l

BRAIIA'00D STATION OBSERVATION OF -

PIPE FABRICATION I. Scope Cbserved pipe fabrication being performed on site by mechanical contractor personnel. 'Ibe fabrication was performed in a shop which had been specifically designated for this purpose. i l

II. Observations A. Fabrication of several piping spools which were in progress was observed. /pplicable procedures were noted, drawings were available and material control (traceability) was verified.

B. General Superintendent was totally familiar with procedures, overall controls, storage location of raw materials and cocpleted work.

C. Reviewed weld rod control and material control systems.

Welder qualifications were reviewed and welders were questioned concerning proceduras used for welding and the .

applicable essential variables.

D. General training and experience of personnel performing the work was adequate for the scope of the work being performed.

E. Reviewed the documentation packages associated with work in progress. All the documentation packages contained the required documents and the applicable sign-offs. Hold points are identified on the process travelers and l individual weld data sheets are used for each weld joint. l III. Conclusions A. No problems or areas of weakness were detected during the

, observation.

B. Q.C. is involved in the fabrication process and overall quality is maintained.

C. Contractor personnel are' knowledgeable of quality requirements and have a positive attitude toward quality and a willingness to work within the system.

D. 'Ibe interface with CECO personnel is well defined and a good working relationship exists.

29 (0937Q)

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@servation tb. 23 BRAIDWOOD STATION OBSERVATION OF 1ARGE Bm E PIPING INSTALLATION I. Secpe -

Conducted a review of mechanaical contractor's installation of a piping spool pieces and valves.

II. Observations A. Observed the field welding of diaphragm valve. Valve was disassemblied to prevent da= age to the diaphragm during welding. %is work was defined in the work package. We work activities were all defined on the process sheets including Q.C. hold points. We craft people were very knowledgeable of work procedures.

B. Observed the fittp of a pipe spool piece. Work activities -

included the inspection of the weld prep area by Q.C. and the fittp of the spool. 'Ibe Q.C. Inspector did a thorough visual inspection. The work procedure required a visual.

'Ibe spool was the final piece to be installed in the system ,

and therefore requires much care in fittp. The craft people were willing to take the tim to get a good fittp.

III. Conclusion The mechanical contractor's activities observed were found to be well planned. The craft people and Q.C. Inspectors understood their jobs.

1 i

(0937Q) 30

Observation No. 24 BRAIDWOOD STATION ,

OBSERVATION OF IROJECT (INSTRUCTION DEPARTMENT SYSTDi WAIKDOWN I. Secpe

& served the Project Construction Engineer conducting a i walkdown of the Couponent Cooling System and discussed flush plans and procedure. Reviewed generic flush procedure and a preliminary flush procedure for the Couponent Cooling System.

II. & servations A. No systems have been forually flushed at this time.

Walkdown of the system consisted of following the piping however, details of the system such as valve positions, valve packing, etc. were not checked.

B. Project Construction has not established guidelines for system walkdown for flushing or turnover.

C. Project Construction depends on the Station Tech Staff for .

technical details of the system.

D. For mechanical systems, Project Construction has ass 4ned Turbine Blc5g., Aur. B dg.,

an engineer to the Containment,4 and HVAC Systems. There are 3- engineers in the electrical area.

E. Project Construction does not have a harger grotp.

F. For systems in operation, the Project Construction Bgineer issues a written request to take portions out of serv.ce.

The PCD Engineer is of the opinion that both electricians  ;

and mechanics can concurrently work on the same equipment  !

under one out-of-service card.

G. Project Construction is preparing to shift from an area concept (i.e. Containment, Ibrbine Bldg., Aux. Bldg.) to a system concept.

! H. The Imad PED Mechanical Engineer visits Braidwood about l once/ month.

I. Reviewed Generic Flush Procedure CFP-0 Rev. 2.

l Responsibilities were assigned, and cleanliness standards

! uere identified. Responsibility for final acceptance of

! the flush is not specified. Tech Staff Supervisors do not review the procedure until the flush is cocplete. Flush j procedure can be executed with approval of Testing Supervisor and PCD Engineer.

, m y

&servations (cont.)

J. Reviewed Preliminary Flush Procedure CFD-0 CFP CCOl and noted the following: ,

1. Pucp suction filter is installed for the flush. Filter plugging and potential subsequent damage to the pump is not addressed. Limitations, were not specified for the Puup suction filters such as: How often should filter differential pressure be read, are causuunications established with Control Room, filter differential -

pressure limitation, and =4n4== suction pressure for the ptsp.

2. The procedure identified a limitation of 4800 GIM for ptmp flow, but all flow orifices and nozzles are required to be removed prior to the flush.

3. 7he Generic Procedure called for flushing at rated system flow or higher. However, flow instru::entation is not available and the procedure did not identify a method to judge system flow.

i

4. The procedure merely required the system to be filled and vented. The procedure did not identify vents by ntsnber or location and did not specify what constituted an acceptable venting of the system.

K. PCD B1gineers have several years of construction and/or -

maintenance experience.

t III. Conclusions A. Guidelines should be established for the Project Construction walkdown for flushing and turnover for test.

B. Out of Service Card Procedures should be reviewed with Project Construction Ehgineecs.

1 C. Flushing procedures should be more detailed to assure that fill and vent is adequate, equipment is properly protected and flushirg boundaries are properly identified.

(0937Q) 32 l

, \

\

Cbservation tb. 25 BRAII%.'00D STATION OBSERVATION OF GANE Itcst'tA;n0N I. Scope Conducted an observation of the Daily Inspection of a P & H Picker.

II. Observations A. We operator and oiler look over the picker in general for any noticable problems.

B. The oiler checked the tire pressure, engine oil, hydraulic oil, and coolant level.

C. We operator started the machine and went throtgh an overall check of equipment.

D. We oiler cleaned the windows and wiped tp any oil spills.

E. We operator and oiler inspected the headache ball and book.

F. We operator checked the pressure and the seal on the CO2 fire extinguisher.

G. We "No Smoking" sirgs are missing at the refuelirg ptmps.

H. We slings on the picker were visually inspected by the operator.

III. Conclusion We operator and oiler appeared knowledgeable in the inpsection, testing and cperation of this equipment.

(0937Q) 33 i

@servation No. 26 BRAIIM00D STATION OBSIRVATION OF ELirIRICAL CONIRACItR TMINING SESSION I. Scope .

& served the electrical contractor project engineer conducting a training class for engineers and several Q.C. Inspectors concerning concrete expansion anchor installation in accordance with procedure 4.3.6 Rev. A (in final sign-off).

II. Items Observed A. 'Ihe classroa= vas an isolated area, which was adequate for the purpose. A blackboard was available, but other visual aids and training equipment are not used.

B. Handout materials were not provided for this session; the

instructor displayed sketches and tables from the procedures during the presentation.

C. 'Ihe instructor called particular attention to each of the major changes in the procedure and expanded on each of the ,

changes. Sketches were made on the board for explanation purposes. Questions were solicited from the students throqghout the session and cocprehensive answers were supplied.

D. Imsson plans or Training objectives were not used and it was confirmed that this is true for all sessions.-

E. Testing was not conducted following the session and it was confirmed that this is the general practice.

III. Conclusions A. 'Ihe project ergineer is a natural and effective instructor, l who has not had any formal instructor training; however, he has had previous stand-up instructor experience.

B. Visual aids or training equipment other than the blackboard are not used in the electrical contractor's training

program, use of such aids and equipment could enhance the effectiveness of the training sessions.

1 C. Since testing is not conducted in the classroom and foremen are expected to keep the crafts in the field informed, some follow-up to ensure crafts are knowledgeable of procedures affecting job related tasks needs to be conducted.

(0937Q) 34

Cbservation No. 27 BRAIDWOOD STATION OBSERVATION OF 20UTING IRACTICES RR SETTING EQUIRIENT I. Scope Conducted a review of documentation pertaining to grout work, including surveillances, contractors procedures, A/E -

specification and manufacturer's installation rece-wndations.

Performed a field review of equipment and miscellaneous supports previously grouted.

II. Observations A. Tapping a number of pucp bases in the turbine room gave an indication of areas of no contact between grout and puop base.

B. A floor drain was inside the oil retention basin for oil storage tenk at column K-25, elev. +357.

C. Two floor stpport beams at elev. 4401 adjacent to column L-20 had slotted end connections that were constrained by partial welding. (These were teaporary beams)

D. Bingham, Pacific and Ingersoll-Rand grouting requirements ,

were not alike.

E. There isn't any indication on the Mechanical Contractor's grout release form for leaving in or removing shims or wedges.

F. Review of contractor's coupleted grout release form showed grout requirement inadequacies and approval inconsistencies.

G. Starttp feed ptmp (non-safety related) @ Elev. 4436 in the Turbine Room was released for grouting by Mechanical Contractor with drive motor in place. 'Ihis was contrary to manufacturer's requirements.

H. 'Ihe underside of the starttp boiler feed ptmp (SBFP) base was covered by a greasy film.

I. The SBFP base was set on concrete foundation without surface being roughened as required.

J. Grouting forms around SBFP hase were in place with incocplete roughening of concrete surface under pucp base.

(0937Q) 35

Observations (Cont'd)

K. Grouting forms in place precluded removal' of water from bolt sleeves after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> soaking requirement. ,

L. The grout material to be used differed from manufacturer's requirements.

M. It was stated that there were ten more Pacific Punps installed on site that did not have drive units removed -

prior to groutiry ptmp bases.

N. 'Ihe Mi11 wright Foreman stated that manufacturer's manual installation instructions were used for setting ptmp bases.

O. 'Ihe M111 wright Foreman stated that he called P.C.D's attention by speed letter and verbally to hollow spots under pt=p bases and has been waiting for disposition instructions from P.C.D. since 3/10/82.

P. The M111 wright Foreman stated that he alwys leaves shims in place after grouting.

Q. Further review of observation "M" found twelve not ten Pacific Puaps were set and grouted. 'Ihese 12 punps are safety-related and are located at elevations +383 and

+3M in the Aux. Bldg. .

R. 'Ihe 12 pucps are identified as: ICV 01PA, 1CV0lPB, ISIO1PA, ISI0lPB, 2CV01PA, 2CV01PB, 2SIO1PA, 2SI0lPB @

elev. +3 M and 2AF01PA, 2AFDlPB, IAF01PA, IAE01PB @

elev. +383.

S. 'Ihe 4 pucp bases at elev. +383 were tapped and found to have hollow sounds.

III. CONCLUSI0tE A. 'Ihere are considerable differences in requirements by A/E and various punp manufacturers for setting and grouting of equipment which requires the close attention of P.C.D., Contractors and Q.A.

B. P.C.D. did not adequately monitor contractor performance.

l C. Contractors' Q.C. programs indicate need for inprovement.

(0937Q) 36 l

l

ATT&CHIENT II INDEX l

PART TITLE

~

OA ORGANIIATION AND ADMINISTRATION..................

i CA.1 CRGANIZATION STRUCTURE..........,.......'..........

CA.2 MANAGEMENT INVOLVEMENT AND CCM.MITMENT

, TO QUALITY.....................................

l a .

CA.3 THE RCLE Or FIRST-LINE SUPERVISORS AND .

MIDDLE MANAGERS................................

DC DESIGN CONTROL...................................

4 DC.1 CESIGN INPUTS....................................

DC.2 DESIGN INTERTACES.................................'

DC.3 BESIGN PR0 CESS...................................

DC.4 DESION OUTPUT....................................

• DC.5 CESIGN CEANCES.........................s.....'....

CC CONS TRUCTION CONTR0L. . . . . . . . . . . . . . . . . . . . . . . . . . . . .

CC.1 CCNSTRUCTICN ENGINEERING.........................

CC.2 CONSTRUCTION 1ACILITIES AND EQUIPMENT............

CC.3 KATER I A L CO NTR0 L . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

CC.4 CONTROL OF CONSTRUCTION PROCESSES................

CC.5 CONSTRUCTION CUALITY INSPECTIONS.................

CC.6 CONSTRUCTION CCRRECTIVE ACTIONS . . . . . . . . . . . . . . . . . .

CC.7 TEST EQUIPMENT CONTR0L...........................

PS PROJECT SUPPORT....,..............................

PS.1 INDUSTRIAL SAFETY................................

PS.2 PROJECT PLANNING..........,......................

PS.3 PROJECTCbNTRCL.................................., . . .

PS.4 PROJECT PRDCUREMENT PROCESS. . . . . . . . . . . . . . . . . . . . . .

PSe5 CONTRA CT ADMINI STRATION . . . . . . . . . . . . . . . . . . . . . . . . . .'.

PS.6 DOCUMENT MANAGEMENT..............................

TN TRAINING..........................................

1 TN.1 TRAINING MANAGEMENT SUP PORT. . . . . . . . . . . . .'. . . . . . . . .

TN.2 TRAINING CRCANIIATION AND ADMINISTRATION.........

TN.3 GENERAL TRAINING AND QUALIFICATION...............

TN.4 TRAINING TACILITIES, EQUIPMENT. AND MATERIAL.....

QP QCALITY PROGRAMS.................................

OP.1 QUALITY PROGRAMS.................................

CP.2 PROGRAM IMPLEf.ENTATION...........................,

CP.3 INDEPENDENT ASSESSMENTS..........................

OP.4 CC RR ECTI VE ACTI ON S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '. .

1 TC TEST CONTR0L.....................................

TC.1 TEST PROGRAM.....................................

TC.2 TEST GROUP ORGANIIATICN AND STAFFING.............

TC.3 TEST PLAN.........................................

TC.4 SYSTEM TURNOVER FOR TEST.........................

I TC.5 TEST PROCEDURES AND TEST DOCUMENTS...............

TC.6 SYSTEM STATUS CONTR0LS...........................

1-

- - . - - -- - -- - , , - . - y--,---

PERFORMANCE EVALUATION.

SUMMARY

Construction Project BYRON /BRAIDWOOD Organizational Structure & Mgot' Parformance Area Involvement & Commitment to Quality Obj ective No. OA- lL2 Evcluetor(s) R. N. Ferguson, A. W. Kleinrath Parformance Objective 1 The owner's corporate organization and all other project organizations responsible for the design, engineering, planning, scheduling, licensing, construction, quality assurance, and testing of a nuclear plant should previde an organizational structure that ensures effective project management control.

2 Senior and' middle managers in the owner's corporate office, designer's office, and at the construction site who are assigned functional rosponsibility for matters relating to the nuclear project should exhibit, through personal interest, awareness, and knowledge, a direct involvement in significant decisions that could affect their responsibilities.

Scope of Evaluation The evaluation of this area involved reviews of various reports, schndules, organization charts, etc. , and interviews with all levels of Project Management and the Company and contractors management that are involved with the Projects . The evaluation of this area involved in excess of sixty-five manhours.

Conclusion All areas reviewed were generally satisfactory. The performance criteria were met. The organizational structure is well defined and understood and management is involved and committed to quality.

9660/0957Q

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON /BRAIDWOOD Organizational Structure & Mgmt Parformance Area Involvecent & Commitment to Quality Obj ective No. OA.1&.2 Evalustor(s) R. N. Ferguson, A. W. Kleinrath

. Aress of weakness and corrective action; Good Practices Thore were no findings in'this area.

546Q/0957Q/pg. 2

PERFOIWANCE EVALUATION DETAILS Construction Project BYRON /BRAIDWOOD Organization Structure & Mgmt Pnrformance Area Involvement & Commitment to Quality' Obj ective No. OA. lb.2 (Title)

Provide factual information that supports the Performance Evaluation summary The Chairman, Vice Chairman, Manager of Projects, ' Assistant Man'ager of Projects , Manager of Quality Assurance, Project Managers , Project Engin:ering Manager, Project Site Construction Superintendents, Site Quality Assurance Superintendents and the Assistant Project Site Construction Superintendent for Byron and several contractor superintendents were interviewed and the following items were noted:

1) All personnel interviewed were familiar with schedule, budget and public relations types of problems.

2) The organization structure is defined clearly and is well understood by all parties interviewed.

3) All personnel were familiar with the Company Quality Assurance Program.

4) Written instructions to specifically improve quality on the project (as opposed to schedule & budget) other than as a result of QA or NRC findings were not evident except in the written QA Program.

5) Trending is used in the QA Department and required in the Project Engineering group. Other groups that could use trending as a control and information system do not appear to use it. Criteria do no exist in any group that establishes what constitutes a trend.

6) Systems for schedule and budget information appear to be updated and distributed in a timely manner. However, the quality and' consistency of the input information is apparently not reviewed to assure its completeness and accuracy.

7) Communications both vertically and horizontally appear to be adequate; however, vertical communications are documented more often than horizontal communications.

8) Scheduled meetings with key personnel are held at least quarterly with the appropriate personnel associated with the Project.

9) Corrective actions are in general well thought out and controlled.

O) A good relationship exists between management, construction, QA and QC at all levels of the Project.

946Q/0957Q/pg. 3

PERFORMANCE EVALUATION DETAILS Construction Project BYRON /BRAIDWOOD Organization Structure & Mgmt Parformance Area Involvement & Commitment to Quality Obj ective No. OA.1&.2 (Title)

Provide factual information that supports the Performance Evaluation Summnry

11) All personnel including the Chairman are initimately involved in the Proj ect on a daily basis.

12) Another mechanism for cross communications and status reporting is the annual system.

goals reports which is part of the Company strategic planning Each principal manager (QA included) presents his operating plan for the subsequent year (if possible, five years) at an annual two day meeting with the Company officers. From this established the Company plans & policy directions and status is determined against the current plan.

13) Functional responsibilities that have been delegated to a?.1 of the management personnel interviewed below the level of Chairman were well understood by the individual and his immediate supervisor.

14) The Company has an extensive management training program consisting of career planning, formal training classes and, when possible, job rotation through different positions within the Company.

L5) The AE's managers were interviewed extensively in June of 1982 and exhibited satisfactory knowledge, involvement and commitment to all facets of the projects.

l 946Q/0957Q/pg. 4

~

- 1 PERFORMANCE EVALUATION

SUMMARY

Construction Project Byron THE ROLE OF FIRST LINE SUPERVISORS Pcrformance Area AND MIDDLE MANAGERS Obj e ctive No . OA.3 Evalustor(s) J. Bitel, ' F. Palmer -

Parformance Objective Tne projecc first line supervisors and middle managers should be qualified by verified background and experience and have the necessary authority to carry out their functional area responsibilities.

Scope of Evaluation Tha evaluat_'on of this area involved observations and discussions with various levels of supervisors and managers in both the contractors and project organizations. Records were examined where appropriate to verify observations and discussion information. Approximately sixteen man-hours vara expended on this activity. .

i l

Conclusion Tne majority of the activities evaluated for this objective were satisfactory. There was , however , a weakness identified that indicated a need to strengthen certain management controls and provide documentation.

hQ/U963Q

I PERFORMANCE EVALUATION

SUMMARY

Construction Project Byron THE ROLE OF FIRST LINE SUPERVISORS Parformance Area AND MIDDLE MANAGERS Objective No. OA.3 Evaluetor(s) J. Bitel, F. Palmer Areas of weakness and cor'rective action; Good Practices Finding)

(OA.3-1 Position descriptions were not available for some contractor supervisors and middle managers, and the minimum qualifications, experience and training requirements are not defined.

Corrective Action Coristruction will review and evalu. te existing position descriptions and initiate revisions. Construction will also make all personnel aware of existing descriptions; these actions will be completed by Febrta ry 1,1983.

6Q/0963Q/pg.2

PERFORMANCE EVALUATION DETAILS Construction Project Byron THE ROLE OF FIRST LINE SUPERVISORS Parformance Area AND MIDDLE MANAGERS Objective No. OA.3 (Title)

Provide factual informatio'n that supports the Performance Evaluation Summary

1. Position descriptions were requested from the contractor and Project Organizations. The contractor stated they did not have position descriptions. Those position descriptions that were provided, describe the duties, responsibilities and authority of supervisors and managers. Since some position descriptions were not available, a determination could not be made in all cases. Contractor management describe the duties and responsibilities verbally to all first line supervisors.

2. The Project Engineers were not aware of the Zion Generator Hydrogen Cooler Tube Cracking problem. SOER's from the Nuclear Safety Department are reviewed, but no formal documentation of action taken was found.

3. The Contractor's Containment Superintendent described the method used to install hangers in the containment. During this discussion we were shown the form used to document needed design changes and this document is sent directly to the A/E or W for correction. The resulting design f

revision is sent back to the contractor for installation. Copies of this documentation is sent to PCD for review and approval which at times occurs after the installation is made.

4. Operation of both Auxiliary building and Containment hanger fabrication shops , was observed. Operation of both shops was excellent; there was good control of material and documentation of material from a bulk state through fabrication to final installation.

Span of control for middle management and first line supervisors was good. Problems, either job or personnel related, are apparent to all levels of managment. Effective use is made of daily meetings and time is spent in' the field to assure a smooth flow of work.

The Contractor maintains written records on all rotating machinery. A program exists for turning shafts of idle machinery up until the time of transfer to the Production Department.

The Contractor has a structured industrial safety program. Review of the program for the work of October 25, revealed the sessions are conducted by job feremen. The content of program was good.

Q/0963Q/pg. 3

PERFORMANCE EVALUATION DETAILS Construction Pi oject Byron THE ROLE OF FIRST LINE SUPERVISORS Performance Area AND MIDDLE MANAGERS Objective No. OA.3 (Title)

Provide factual informatio'n that supports the Performance Evaluation Summary

4. (cont 'd)

Communications between Contractors, Construction, Engineering, both on and off site, and Production is good. Interviews with personnel in each of these groups indicated the use of periodic structured meetings, formal reports for trending and controlling work, and informal daily meetings.

9 P

5Q/090s. pg. 4

PERFORMANCE EVALUATION

SUMMARY

Construction Project

, BRAIDWOOD Role of First Line Supervisors Parformance Area and Middle Managers Objective No. OA.3 Evaluetor(s) F. Palmer, J. Bitel '

Parformance Objective Tha project first line supervisors and middle managers should be qualified by verified background and experience and have the necessary authority to carry out their functional area responsibilities.

Scope of Evaluation The evaluation of this area involved observations and discussiona with various levels of first line supervisors and middle managers in both the contractor and project organizations. Records were examined where appropriate to verify the observations and discussions were held with parconnel to obtain supporting information. Approximately, 18 manhours ware expended on this activity.

l i

Conclusion The majority of the activities evaluated for this objective were satisfactory. There were, however, a number of weaknesses identified that indicate a need to strengthen and document certain management controls.

I 5Q/lO22Q 1

l

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDNOOD The Role of First Line Supervisors Parformance Area and Middle Managers Objective No. OA.3 Evaluator (s) F. Palmer, J. Bitel Arnas of weakness and corrective action; Good Practices Finding)

(OA.3-1 Position descriptions for the supervisors and managers for this performance crea are not in universal use for contractors and major entities of the Project Management Group. Where position descriptions are written, parsonnel c' overed by them were in some cases unaware of their existence.

Minimum qualifications, experience level and training requirements were not specified.

Corrnctive Action:

Construction will review and evaluate existing position descriptions and initiate revisions. Construction will also made all personnel aware of existing descriptions, these actions will be completed by February 1,1983.

Finding)

(OA.3-2 PCD and PED trending programs and programs based on milestones are not as offective in determining job status as they could be due to the fact that tha input data is not consistent among contractors or major Edison Departments. This makes advance trends. difficult to determine. In cddition, comparison of performance against other construction sites is not dona.

Corrective Action:

"The Project Organization at Byron and Braidwood will undertake a detailed cycluation of the issues presented and identify appropriate actions consistent with the evaluation report. This will be completed by January 14, 1983."

l l

l l

6Q/1022Q

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD The Role of First Line Supervisors Parformance Area and Middle Managers Objective No. OA.3 (Title)

Provide factual information that supports the Performance Evaluation Summtry

1. The Electrical Contractor activities of cable pulling and termination was observed to determine how these jobs are implemented and managed.

The relations and interface with the PCD were also reviewed and interviews were held with contractor workers, foreman, general foremen and the PCD Electrical Supervisor. The weekly foreman job status meeting held by the Electrical Contractor was also attended. The overall work activities appeared to be satisfactory, personnel were trained on their work procedures, and computer programs were used to keep track of construction status and deficiencies.

2. An interview with the PCD Electrical Supervisor was held and his organization, responsibilities and duties were discussed along with those of his six staff people. Position descriptions were available for each member of the Electrical Group and detailed work assignments were available in the Electrical Supervisor's Office. Qualifications were not indicated on position descriptions such as degree or experience required. The Electrical Supervisor reviews the qualifications of Electrical Contractor Supervisors (position d scriptions were not used for this purpose) and has approval authority over new hires. The Electrical Supervisor contacts the Byron Station t Electrical Supervisor periodically to exchange information. He also l

' receives NRC Bulletins and Information Notices on industry problems, but documentation was not available as to their disposition.

Pariodically, Electrical Contractor personnel from Braidwood are sent to Pyron to review construction practices. The status of Electrical Construction is determined by the PCD Electrical Supervisor by reviewing the computer data supplied by the Electrical Contractor. A l trending program was not in place to evaluate contractor performance l and compare performance with other job sites.

3. The Mechanical Supervisor and the Construction Superintendent for PCD

! and the Manager of the Piping Contractor were interviewed. Areas discussed included organization, department interfaces, trending, corrective action programs, management controls, training and the plant fire prevention plan.

A. Follow up with the Mechanical Supervisor on the method used to repair reported piping leaks or other deficiencies that do not fall within prescribed procedures for construction deficiencies indicated that these items are handled informally either verbally or by speed letter.

5Q/1022Q

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD The Role or First Line Supervisors Parformance Area and Middle Managers Objective No. OA.3 (Title)

Provide factual information that supports the Performance Evaluation Summary B. Discussions with both off site and on site PCD management indicated that no formal program exists to provide information to construction sites on equipment or construction problems found in other utility construction sites. Only NRC Information Notices and Bulletins are received at the sites and a formal response is not provided, NOTEPAD Informa' tion is sent to operating and they notify construction if they cre involved.

C. A review of organization charts for PCD and related contractors was performed. This review indicated that PCD personnel understand their responsibilities, duties and reporting relationships. In reviewing the piping contractor's organization it was noted that five PCD Engineers are shown on the chart in key positions in the engineering area. This crrangement was made by agreement with the piping contractor and PCD management.

D. Position descriptions were reviewed for PCD. The quality and consistency were not as good as those of PED. The piping contractor position descriptions were described in one pencil writeup covering overy key supervisor in the organization. Personnel covered by their position descriptions were unaware that they were in written form, but had been told verbally of the content.

E. Plant Equipment Lubrication and Rotation Programs under the control of the Piping Contractor were reviewed'. A program is in place for turning shafts of idle machinery and their lubrication from the time of their being set in place until their transfer to the Production Department.

The program and its documentation were satisfactory.

F. The interface between PCD and Off-Site PED, Byron Station and contractors was discussed. Good communications exist between PCD and Site Contractors. PED visits to site are very infrequent. Most communication is between site PCD personnel and a PED person located at the Byron site. Relations with QA Department appear to be satisfactory.

G. A review of training indicated that all PCD personnel have had plant systems training given by the Operating organization. The PCD personnel received QA manual training in 1982. The Piping contractor training program for supervisors and foremen was reviewed and found acceptable. l 6Q/1022Q

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD

~

The Role of First Line Supervisors Parformance Area and Middle Managers Objective No. OA.3 (Title)

Provide factual information that supports the Periarmance Evaluation Summnry H. Trending and evaluation of construction stcr/a is tracked primarily by the PED with reports for AE, contractors an.' FS & CC. Comprarison of performance with other construction sites tas not evident. Experience et LaSalle and other construction sites does not appear to be factored into scheduling activities. There does not appear to be any program by Project Management to take an overall view of design, work practices cnd performances from the two other construction sites and incorporste them in to this site. For example, the future hanger work involving design activities on site, material control, fabrication and installation is being handled as an on-site activity. The Mechanical Contractor tracks installed pipe and hangers, however, the progress toward completion of the job is not made or compared with performance at other sites by POD. The Electrical Contractor keeps track of cable pulled and terminations, but nothing was available on manhours. No ellowance is presently made for pre-op problems.

K. Evaluation of the interrelationship of first line supervisors, middle f management and top site management was conducted through the use of observation and interviews. Span of personnel control for middle managers and first line supervisors was good. Problems either job or personnel related are handled in an expeditious manner and are apparent to all levels of management.

L. Inspection of the plant indicated that some major design deficiencies found at Zion were not corrected at Byron and Braidwood. The system to control those items appears to be ineffective. For example, the regulator valves in the auxiliary feedwater system, which will be used on unit startup, are installed horizontally at Zion and are installed in the same position at Byron and Braidwood. The result over the long term is high maintenance with its effect on plant availability. Other examples in containment and auxiliary building are not changing, and in some cases reducing, the space available to both permit ease of l maintenance on equipment and to meet the requirements of ALARA. An I example of this space problem are the Reactor Primary loop isolation valves, for a very high radiation job. In order to remove the bonnet and internals of these valves it is necessary to either cut the valve l

stem or cut and remove structural steel above the valve. These valves have to be disassembled at least every 10 years for ISI. At Zion there is ample space to remove the valve internals.

l 6Q/1022Q

PERFORMANCE EVALUATION-

SUMMARY

Construction Project Byron /Braidwood P:rformance Area Design Inputs Objective No. DC.1 Evalustor(s) R. Harris Parformance Objective Inputs to the design process should be defined and controlled to achieve complete and quality designs.

Scope of Evaluation Tha evaluation or this area involved one team member. Approximately 35 menhours were devoted to interviewing the project management team and design staff and in reviewing design criteria documents. The materi:1 rsviewed are noted in the section entitled Performance Evaluation Details.

l Conclusion

. The activities and documents evaluated under this performance objective l

wara found to be excellently documented and widely distributed to the

! design l

staff.

l Q/0947Q

PERFORMANCE EVALUATION

SUMMARY

Construction Project Byron /Braidwood Parformance Area Design Inputs Obj ective No. DC.1 Evalustor(s) R. Harris Arci.s of weakness and corrective action; Good Practices No findings identified.

1 i

Q/0947Q/Page 2

s PERFORMANCE EVALUATION DETAILS Construction Project

~

Byron /Braidwood Performance Area Design Control (Input) Objective No. DC.1 (Title) i

' Provide factual information that supports the Performance Evaluation

, summary

1. The SAR contains a reference section for the codes, standards, and regulatory requirements, which include the date and revision level which apply. Appendix A of the FSAR give the dates for all the applicable regulatory criteria. In addition to the PSAR, the Project Engineers for each engineering discipline have prepared design criteria documents to cover all aspects of the job. These documents are very thorough and draw together all the requirements. The Design Engineers assigned to the project were given copies of these criteria documents

' for their use.

Currently, there is very little original design activities in process.

However, the activities which are underway are well documented in the governing specifications. These specifications include work scope, schedules, design criteria and interfaces with other design organizations. The above documents were approved by the individual defined by the company as having the authority.

2. The A-E has by Administrative procedures defined senior staff members as equipment specialists. Each defined staff member is responsible to stay abreast of the state.-of-the-art developments on the equipment assigned to them. This is done by scheduling presentations , acting as audit team members for vendor qualification audits, and maintaining maintenance information on the equipment. In the mechanical area, the organization responsible for the preparation of the equipment specifications follow-up the completion of the plant with questionaires on equipment functionability. The results of these questionaires are -

fed back to the equipment specialists.

These staff members are available to the design staff during the design phase and to review equipment specification before they are released.

56Q/0947Q/Page 3

PERFORMANCE EVALUATION DETAILS Construction Project Byron /Braidwood Parformance Area Design Control (Input) Obj ective No . DC.1 (Title)

~

Provide factual information that supports the Performance Evaluation Summary

3. In the design phase equipment removal and maintenance space drawings were prepared for use by the designers when locating other equipment end piping. The A-E has initiated a program where they meet monthly to address problems or violations to the reserved space. The program tracks the progress of all noted action items.

In addition, the A-E has a program for inservice inspection. All piping systems and components which require inservice inspection has been identified by color coded P&ID's. These drawings have been distributed to all organizations involved in construction. The pipe installers are not allowed to cover any welds on the pipe requiring inservice inspection without notifying the A-E. In addition, the A-E meets monthly with the construction staff and contractors to resolve cny problems resulting from the inservice inspection requirements.

4. As noted in Item 1, the A-E Project Engineering Staff prepared detailed design criteria documents for each engineering discipline. These documents restate the commitment made in the PSAR. In addition, the documents reiterate the requirements of the codes and standards and the governing Regulatory Guides and the Standard Review Plan. Examples of some of the criteria documents are:

• Separation requirement for Class IE electrical cables

• Remote shutdown design criteria

• Engine Safeguards design criteria

• Communication system design criteria

• Structural design criteria These documents are distributed to the design and analysis staff essigned to the project for their use. The documents have all been periodically updated to include changes to the criteria.

cQ/0947Q/Page 4

l PERFORMANCE EVALUATION DETAILS Construction Project Byron /Braidwood Performance Area Design Control (Input) Objective No. DC.1 (Title)

Provide factual information that supports the Performance Evaluation Summary

5. Several equipment specifications were reviewed in the mechanical L electrical area to determine if functional testing was required by the specifications. The functional test requirements were extensive and in i some cases went beyond the regulatory requirements. These equipment specifications are reviewed by the A-E's Equipment Specialist to assure the completeness of the testing requirements and the specification.

6. .As noted in Item 4, design criteria documents are prepared by the Project Engineers. These documents are issued and controlled by the j Project Document Control System. The procedures governing the issue and control of these documents are Project Instructions.

In addition, the A-E prepares the specification which establishes the work scope of other contractors involved in. design activities. These specifications include design criteria, work scope, schedules, and interface requirements. These documents are controlled by the organization responsible for their preparation. ,

!7. The A-E has a very thorough document control system. Documents are issued under these systems and have revision control. Document lists

! are periodienlly issued listing all the controlled documents and their latest revisions. All the design input documents reviewed throughout the project were the current revisions.

!8. The Design Staff had access to the supplier information through the

vendor library maintained by the A-E. In addition, the Staff had

. access to the supplier expertise through the Equipm5nt Specialist on

! the A-E's staff. See Item 2.

!9. The design criteria documents were readily available to the Design l Staff. These documents were visually available in the design areas visited. When requesting the' criteria documents the staff was immediately familiar with the request and the documents were available in their bookcases.

L6Q/0947Q/Page 5 L

PERFORMANCE EVALUATION

SUMMARY

Construction Project Byron /Braidwood Derformance Area Design Interfaces ~ Objective No. DC.2 Evaluotor(s) R. Curran Parformance Objective i

Design organization external and internal interfaces should be identified end coordinated to ensure a final design that satisfies all input requirements.

Scope of Evaluation The evaluation of this area involved essentially one man. Approximately, 32 man-hours were expended reviewing interface documents (both internal and external) and interviewing personnel in the mechanical, structural and electrical design engineering departments: Review of interface documents and interviews with personnel, in the construction areas, were made principally in the area of electrical construction. -

l-1 Conclusion Essentially, all of the interface requirements are in place and are 1

functioning in accordance with the procedural requirements , Quality Assurance requirements and good engineering practices.

6Q/0956Q

PERFORMANCE EVALUATION

SUMMARY

Construction Project Byron /Braidwood Parformance Area Design Interfaces Objective No. DC.2 Evaluator (s) R. Curran

, Arn':s of weakness and corrective action; Good Practices No findings identified.

bQ/0950Q

PERFORMANCE EVALUATION DETAILS Construction Project Byron /Braidwood Performance Area Design Interfaces Objective No. DC.2 (Title)

Provide factual information that supports the Performance Evaluation Summary '

The Mechanical, Structural and Electrical Design Departments of S&L were reviewed to determine if design interfaces, both internal and external are established, documented and functioning.

1. The A/E Quality Assurance Manual requires that the Project Manager define t'he responsibilities and authorities within the design organization. A review of three Project Instructions demonstrated that

,these authorities and responsibilities are well defined.

2. A review of the Foreign Document Report indicates that the flow of design information both externally and internally is controlled and timely. The Foreign Document Report is updated every two weeks ard is.

distributed by Project Distribution List every month. Additional information reviewed concerning interfaces were two letters from vendors providing test data for their products requested by the Electrical Department. Also reviewed were interdepartmental memoranda between the Electrical and Structural Departments transmitting vendor l test data, requesting seismic analysis of the vendors equipment and recommendations resulting from'the analysis. -

!3. Nina Project Instructions were reviewed, incuding the interdepartmental instruction. It was found that both internal and external interfaces are doiined and controlled. In addition, Attachment A to " Interface Control Agreements" covering electrical Field Change Notices was reviewe'd. This agreement defines interfaces between Westinghouse, CECO i and the A/E. One isolated case of an incomplete interface was noted, Proj ect Instruction PI-BB-17 " Procedure for Control of Cable Tray l Loading" defines an interface between the Electrical and Structural Departments . The requirements for this interface deals with the analysis and re-design, if required, of cable tray hangers in the event 7

that a cable tray weight overload occurs. The responsibilities for this interface were not specified.

The instruction is being revised and the interface requirements will be incorporated in the revision. This particular interface has not been, needed to date.

5Q/0956Q j l

I .- _ _- _ _ _ _ . __ _ _ . . - _ .__.._..J.___...___ . . _ _ - . _ _ _ _ _ _ _ . _ , _ _ _ . - . . ,- , . , - . _ _ , _ , _ _ _ , _ . .

PERFORMANCE EVALUATION DETAILS Construction Project Byron /Braidwood Performance Area Design Interfaces Objective No. DC.2 (Title)

Provide factual information that supports the Performance Evaluation Summary 4.

Several project proposed memos and meeting minutes were reviewed which discussed changes. They were traced by project correspondence and in one case where the design criteria was changed it was found that the change was made and properly approved based on the new information. In the second supported bycase, theinformation.

the new criteria is in the process of being changed as

5. The review of the already mentioned Project Instructions and their thoroughly defined responsibilities for interfaces, Field Change Raquest procedures and Engineering Change Notice procedures should they all consider system interactions in system design and analysis.

6.

Interviewsdepartments electrical with design personnel in the mechanical, structural and indicates that lines of communication, both inter and intradepartmental are established both by procedure and routine practice and that these lines of communications are effective.

7 Design information disseminated by already described procedures, instructions, etc. indicate effective coordination. A review of approximately 20 drawings being used by the construction cone actors indicate that most changes were received by the construction organizations within 1 to 3 days following release of the drawings.

Interviews with Byron construction contractor personnel indicated that changes were being effectively handled.

Interviews with the construction company personnel, concerning transfer vf design documents, indicated that these transfers are planned and implemented in a controlled manner. Interviews with the A-E mechanical, Project structural and electrical design personnel and a review of Instructions,' which define interface responsibilities, also indicates that the transfer of desi implemented in a controlled manner.gn responsibilities are planned and i

Q/0956Q

4 PERFORIM CE EVALUATION

SUMMARY

Construction Project Byron /Braidwood Terformance Area DESIGN PROCESS Objective No. DC.3 Evaluator (s) R. Harris Performance Objective The management of the design process should result in designs that are safe, reliable, verifiable, and in compliance with the design requirements.

Scope of Evaluation The evaluation of this area involved one team member. Approximately 30 manhours were devoted to interviewing the Project Management Team and Design Staff, and in reviewing procedures, standards, and scheduling documents.

Conclusion The activities and documents evaluated under this performance objective were found to be very thorough and excellently documented.

mQ/0954Q

4 l

PERFORMANCE EVALUATION

SUMMARY

Construction Project Byron /Braidwood Performance Area DESIGN PROCESS Objective No. DC.3 Evaluator (s) R. Harris Areas of weakness and corrective action; Good Practices No findi'gs identified.

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PERFORMANCE EVALUATION DETAILS Construction Project Byron /Braidwood Performance Area Design Control (Process) Objective No. DC.3 (Title)

Provide factual information that supports the Performance Evaluation Summary

1. Most of the design activities are complete for the project. The design activities which were still in progress are planned and scheduled. The overall planning is completed by CECO's Project Scheduling and Cost Control. . Their schedules give the time frame for the design, construction and testing for the project. The design activities have been planned based on these time frames. The current design activities are traced by.the organization responsible for the design by preparing punch lists showing activities and completion dates or expected completion dates. The activities tracked include the field change request activities, pipe support design activities and the "as-built" program. The current design activities are reviewed to determine their impact on the plant completion dates. Weekly and monthly meetings are held to discuss schedules and to identify activities which may impact fuel load.

2. The Project Engineer for the given engineering discipline is responsible for controlling the design process in his area. The design process in all the disciplines is well documented. As noted in Performance Objective DC.1, Design Input , the Project Engineers are responsible for the development of design criteria documents. These documents form the basis for the design. The Project Instructions and GQ's give the direction for the control and approval of all design documents. These instructions are thorough and clear.

3. The design review and verification processes are well documented. GQ 3.10 gives the general requirements for design reviews. It requires the Project Engineer for each discipline to define which systems, l

l components or structures require design reviews and to schedule the design reviews. Additional guidance and instruction for design reviews are given in the Department Standards and the Project Instructions.

Each design review is thoroughly documented in a design review report.

These reports contain the completed checklists used for the reviews, items discussed during the review, action items requiring additional work, and a listing of all the review team members. To track the i design review progress,each Project Engineer is required to I periodically prepare a " Design Review Status Report" which lists the status of the design review for each system requiring a review. In most cases the design reviews were completed by personnel from other projects.

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0Q/0954Q/Page 3 1

PERFORMANCE EVALUATION DETAILS Construction Project Byron /Braidwood Parformance Area Design Control (Process) Objective No. DC.3 (Title)

Provide factual information that supports the Performance Evaluation Summ:ary The verification of calculations including computer analysis is a documented process. As an example, the piping analysis final reports contain the review comments including the review checklist which defines the specific items requiring checking. Independence is required by the GQ Procedures.

Computer programs used for analysis on the project are required to have

, documented validation reports. The A-E performing most calculations has a system where only computer programs which have been validated and controlled by the computer library are available to the analyst. The other contractors doing design calculations have been required to complete all analysis with validated computer programs, verified under the contractor's procedures.

4. The design documents reviewed during the evaluation (drawings, calculation reports, and specifications) all were clear and well documented. The originators and checkers (reviewers) were identified.

5. A review of calculation reports completed by the A-E were found to be comp'.ete and clear. The reports referenced the controlling design criteria and standards; the design loads were documented; and the app'.icable design drawings were referenced (in some cases the design drawings were included in the reports).

6. No cases were found requiring independent calculation. Calculations were verified by detailed checking.

7. At the current status of the project limited original design activities are in progress. These activities involve the design of supports for piping and electrical conduit and equipment. The progress and problem resolutions are tracked by monthly meetings and monthly progress reports. Meeting minutes are published and action items are noted

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including commitment dates. These commitments are tracked by punch lists and followed in monthly meetings. CECO's Project Construction team felt that design problems are resolved in a timely manner.

6Q/0954Q/Page 4

PERFORMANCE EVALUATION DETAILS Construction Project Byron /Braidwood P:rformance Area Design Control (Process) Objective No. DC.3 (Title)

Provide factual information that supports the Performance Evaluation Summary

8. During'the evaluation, interviews were held with the management team of the utility (both Construction and Project Engineering) the A-E, and other contractors involved in the design process. In all cases management was aware and current on the design status of the project.

In addition, the management was aware of design problems which the staff was working on. Management is distributed the project punch lists and were found to be knowledgeable of the contents.

9. In interviews with CECO's Construction Staff and the construction contractors, its was determined that the design organizations are providing support and timely resolution of design problems. This was evident by the fact that the A-E had moved a portion of its design staff to the construction site. This was to accelerate the resolution of Field Change Requests and to aid the contractors in interpreting the design drawings. This group is an extension of the home office design staff and has the properly approved authority to act on design change requests.

10. Currently, the design efforts on the project are in a reaction mode.

That is, reaction to the construction progress. "As-built" activities are in progress as the systems are completed. These activities are defined in the Project Instructions prepared by the A-E. Monthly progress . reports are prepared which track the progress of these activities. The reports identify both the scheduled completion dates and actual completion dates. Current progrees and problems are also noted in these reports.

11. The design activities are extremely well documented through the use of design criteria documents, specifications, drawings, analysis reports, design review status reports, and published lists showing all documents released on the project. These design documents are controlled by the organization responsible for their preparations.

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PERFORMANCE EVALUATION DETAILS Construction Project Byron /Braidwood Parformance Area Design Control (Process) Objective No. DC.3 (Title)

> Provide factual information that supports the Performance Evaluation Summary

12. Design documents are prepared under a controlled process. Direction as to what documents are required and what format to use comes from the AaE Project Instructions (for the specific project) and the Department Standards (Company Standards). The Byron and Braidwood project has a very complete set of Project Instructions giving direction to the design staff as to the required documents. In addition, each of the

, Engineering Departments (Mechanical, Structural, Electrical and Engineering Mechanics) have their own standards. These standards give the designer and analysis guidance as to drawing formats and analysis methods and procedures. These Standards and instructions are well written and thorough.

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l PERFORMANCE EVALUATION

SUMMARY

Construction Project Byron /Braidwood Parformance Area Design Output Obj e ctive No . DC.4 Evalua tor (s) R. Curran, M. Gorski -

Parformance Objective Project design documents should specify constructable designs in terms of complete, accurate, and understandable design requirements.

Scope of Evalua tion The evalua tion of this area involved two men. Approximately, 46 manhours were expended reviewing design documents and interviewing personnel in the machanical, structural and electrical design engineering departments.

Interviews of personnel in the construction areas were also performed including the electrical and mechanical construction contractors and the Architect Engineering firms field mechanical engineers.

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l Conclusion Essentially all design output requirements are in place and functioning in accordance with the procedural and Quality Assurance requirements. Two deficiencie s were identifie d in the interpretations and implementation design output documents.

6Q/0958Q

PERFORMANCE EVALUATION SUmfARY Construction Project Byron /Braidwood Performance Area Design Output Objective No. DC.4 Evalua tor (s) R. Curran, M. Gorski l

Areas of weakness and corrective action; Good Practices 1

Finding)

(DC.4-1 A non-safety related drive motor used on the essential service water strainers was supplied with internal wiring connections which were not suitable for the expected moisture and vibration service conditions.

Corrective Action:

Project Construction Department acknowledges the concern identified.

Project Construction's normal practice is not to replace all wire nut connections with an approved connection. The connections in question on the essential service water strainers were previously evaluated by Project Construction and it was determined to leave as is. The Project Construction Department did upgrade the connections in question. nOne layer of isulating and hi-temp tape was added to the individua l wire nut installations to assure a good connection. The Project Construction Department feels this fix is acceptable for the intended use and should remain as is.

For any connections made on Safety-Related equipment that cannot be terminated per specification, advance verbal direction is obtained from Sargent & Lundy prior to making the connections.

The normal method of discovering these conditions is during testing activity by the contractor or OAD. These groups are aware of the need to identify these situations and bring them to the attention of Station Electrical / Project Construction Department for evalua tion.

Finding (DC.4-2)

A flexible conduit, installed between a junction box and a Category I isolation valve, was found to be longer than allowed by the Architect Engineer's Standards .

SQ/0958Q/Page 2

PERFORMANCE EVALUATION

SUMMARY

Construction Project Byron /Braidwoo'd Performance rea Design Output Objective No. DC.4 Evaluator (s) R. Curran, M. Gorski

, Areas of weakness and corrective action; Good Practices Finding)

(DC.4-2 (Cont'd)

Corrective Action:

1. The appropriate electrical installation drawing will be revised to indicate that the subject flexible conduit exceeds the maximum six foot length allowed in SLL STD-EB-146.

2. ' S&L will revise STD-EB-146 to a) clarify the manner in which flexible conduit longer than six feet is indicated on the electrical installation drawings and b) clarify it is the responsibility of the electrical installation contractor to report all instances where the maximum six foot length is exceeded.

3. The above documents will be revised by Janua ry 31, 1983.

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PERFORMANCE EVALUATION DETAILS Construction Project Byron /Braidwood Performance Area Design Output Objective No. DC.4 (Title) l

[ Provide factual information that supports the Performance Evaluation l Summary Project design documents were reviewed and the Project Staff in the Mechanical, Structural and Electrical Design Departments were interviewed to varify that the design documents specify constructable designs.

1. A review of design drawings, specifications, project instructions and A/E Standards revealed that these documents were defined as to their purpose. Drawing purpose is noted by titles. The other documents contain a statement of purpose.

2. A review of design output documents, drawings standards and specifications reflect constructable, operable and maintainable designs. In addition, interviews with construction personnel verified that constructable designs were being provided. However, during the observations a condition was noted which could affect the maintenance of non-safety related motors. The internal motor connections for the non-ssfety related vendor supplied motors used on the essential l services water strainers were found to be inadequate for the expected moisture and vibration service conditions. These connections were made using wire nuts and vinyl tape. This application is an unusual condition in that the motors are cet up for a dual voltage application requiring additional internal motor wiring. It is expected that this condition could exist in other motors requiring additional internal wiring . It appears that the A/E and CECO General Standards do not cover this unique application.

3. The review of design documents generally indicate a complete and I understandable interpretation of design packages. However, one l instance of a misunderstood design requirement was indentified in the area of the installation of flexible conduit. Both the A/E Standard, covering the installation of flexible conduit and the General Notes Drawings covering installation, require that flexible conduit installations be limited to six feet or less unless otherwise specified

! by the installation drawing.

An interview with the construction company's engineer revealed that his interpretation of this requirement is as follows : If the equipment, devices, conduit, etc. are located per the installation drawing the

! interconnecting flexible conduit meets the requirements of the drawing i regardless of conduit length. This has resulted in flexible conduit of longer than six feet being installed. The general notes drawings which

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PERFORMANCE EVALUATION DETAILS Construction Project Byron /Braidwood Performance Area Design Output Objective No. DC.4 (Title)

Provide factual information that supports the Performance Evaluation Summary

3. (Continued) require the installer to report, by way of established procedures, whenever flexible conduit cannot be installed per the drawing or standard requires clarification and enforcement.

4. Interviews with design organization personnel indicate an awareness of

, vendor capability. In particular, personnel responsible for review of vendor's qualification reports for Class IE equipment are aware of vendor capabilities and requirements. Interviews with the design organization's field personnel also indicate an awareness of the construction organization capabilities through ob7ervation of work being done, review of construction contractors procedures and training practices. -

, 5. In general the details, legibility and clarity of the design output j documents are clear and are being correctly implemented. A detailed review of the electrical conduit support drawing identified an isolated case where the drawing did not provide the load capacity information.

This condition was immediately corrected by the A-E on an Engineering Change Notice.

6. A review of int'erdepartmental memoranda shows a willingness of the design organizations to work together to clarify and update design output. As an example, the Electrical and Structural Departments for seismic analysis of flexible conduit and cable grips has resulted in the limitation of applicability of certain manufacturers cable grips for Category I applications and a proposed revision to the standard governing flexible conduit lengths for Category I installations.

7. Design output documents (drawing specifications and standards) were reviewed and found to be issued using a controlled process. Changes to -

these documents, resulting.frcw ECN's, NCR's A-E internal comments, etc., are being kept current using the same controlled process. The l current documents have been given the same level of evaluation, review l and approval for quality, safety and design input requirements as were the original documents.

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. PERFORMANCE EVALUATION.

SUMMARY

Construction Project Byron / Braidwood Performance Area Design Changes Obj ective No . DC.5 Evaluator (s) M. Gorski ~

Performance Objective Changes to released project design documents should be controlled to ensure that constructed designs comply with the most recent design requirements.

Scope of Evaluation The evaluation of this area involved selected team members. Approximately 57 manhours were expended on this area of evaluation. The evaluation consisted of interviews with on-site contractor lead engineers , interview s with off-site and on-site A-E engineers, reviews of design changes and backup calculations and reviews of design change procedures and systems.

1 Conclusion The activities evaluated under this perforcance objective were satisfactory.

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I PERFORMANCE EVALUATION DETAILS Construction Project Byron /Braidwood Parformance Area Design Changes Obj e ctive No . DC.5 (Title)

Provide factual information that supports the Performance Evaluation Summary

1. The Architect-Engineers (AE's) scope of work at the time of this evaluation included general design and engineering responsibilities for the Byron and Braidwood projects excluding the NSSS design and certain piping subsystem design and analysis, During the evaluation, the Structural, Mechanical, Electrical and HVAC groups at the A-E home office were checked as well as various A-E field liaison groups at both the Byron and Braidwood sites. The scope of design changes reviewed included those resulting from the following:

A. Field Change Requests (FCR)

B. Engineering Change Notice (ECN)

C. Site Nonconformance Report (NCR)

D. Vendor Nonconformance Report E. Vendor Drawing Revisions -

F. As-Built Drawings G. Changes requested by CECO Engineering H. A-E internal comments, both solicited and unsolicited, on design drawings and documents It was noted that at this point in the project, the vast majority of design changes have resulted from field installation conditions. These changes are documented, tracked and dispositioned on Field Change Requests or Nonconformance reports . Engineering Change Notices are also issued by A-E's in response to requests for design change from the field or from design changes generated internally by the A-E design organization.

. There are currently several thousand FCR's, ECN's and NCR's outstanding on the Eyron/Braidwood projects . Emphasis has been placed by top management on greatly reducing the number with the goal being a ninety day turnaroun d on routine engineering changes. Tracking and status reporting methods had been established to ensure timely evaluation and incorporation of design changes . Status reports for the year 1982 indicate that a steady reduction in the number of outstanding design changes has been achieved. Interviews with contractor engineering personnel at both sites indicate that field change preliminary approval via FCR's has in general been adequate and sufficiently timely to support the construction effort.

oQ/0960Q/Page 2

PERFORMANCE EVALUATION DETAILS Construction Project Byron /Braidwood Performance Area Design Changes Obj ective No . DC.5 (Title) l .

Provide Summary factual information that supports the Performance Evaluation

2. (Continued)

It was further noted that in some cases the turnaround in resolving range.problems and issuing revised drawings was in the two-to-ten day field 3.

, Reasons for changes inputs listed in (1). are listed on FCR's and most other design change Generally, reasons for changes are automatically evaluated and considered during the evalua' tion of the change itself.

There is an incentive for all parties involved to review the causes of design time money, changes in order and effort. to prevent repetitious changes and thereby save The results of chis type of design change review has been items such as the establishment of detailed and comprehensive tolerances for the installation of pipe supports, and the ~

modification of contractor concrete placement procedures to reduce the incidence of exceeding the temperature limits.

4.

In all disciplines, the responsible A-E evaluated all proposed design changes against the design criteria used for the original design. The codes, standards, computer programs, calculation techniques, design guides and analysis methods used for the evaluation of design changes were the same as, or had the same basis as, the methods used for the original design. For one A-E, when calculations or analysis was required for a design change, the original design calculations or analyses were reviewed and the revised calculations or analysis reflecting design. the change were performed and incorporated into the original 5.

The coordination of design changes between disciplines is accomplished in cao ways . When a design change is initially evaluated, personnel in the affected discipline contact the cognizant personnel and/or refer to the appropriate drawings for other disciplines to coordinate applicable elements of the proposed change. In one organization, a drawing that has been changed is required, by procedure, to be routed to all other disciplines for comments prior to approval and release. The drawing ,

by procedure, cannot be approved or released until all comments have been resolved.

]/U960Q/Page 3

PERFORMANCE EVALUATION DETAILS Construction Project Byron /Braidwood Performance Area Design Changes Obj e ctive No . DC.5 (Title)

Provide Summary factual information that supports the Performance Evaluation 6.

Generally, not the scope require changes of design changes to procedures at this stage of the project do and methods.

notable examples where this has occurred. There are , however, two expansion anchor installation procedures have been revisedconcrete Site contractor to incorporate standard. design changes made in the A-E concrete expansion anchor Mechanical contractor pipe support installation procedures have been revised to incorporate revised A-E requirements for the use of chain dimensions for pipe support installation.

7.

For the scope of the design changes reviewed, considerations of safety quality and cost appeared to be included in the design change process.,

Site contractors to field problemscontacted were closely at both sites indicated coordinated that A-E in with personnel solutions the field in order to achieve a practical and installable design solution.

Drawings' and for field included problem solutions were reviewed in a number of areas sufficient information for fabrication and installations.

Quality Requirements such as weld sizes, material types and special components requirements were included in design changes in the same manner as in the original design. Safety classification of revised designs were the same as the original design. Changes to the design are evaluated against the same desi the original design (See #4 above) gn inputs for safety and quality as 5.

For all disciplines it was found that measures for the control of design changes were the same as those employed for the original design.

The control measures for design changes were specifically delineated by procedures and instructions and consisted of a documented independent review and approval of each change. Evidence of design review andand revisions approval for changes supporting was observed on FCR's, ECN's, Drawing calculations.

$. At r the time adequacy, anwhen a proposed design change is reviewed for technical assessment is made of the impact the change may have on other is parts of the system, other systems and other plants. This review the area being responsibility changed. In of the cognizant A-E personnel for the particular some cases, it was found that the cognizant personnel for design . changes were the personnel involved with the same area for the original plant design. Unit 1 vs. Unit 2 and Braidwood vs. Byron impacts are considered for specific design changes by the cognizant personnel since they are familiar with all 4 units. It was

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PERFORMANCE EVALUATIO.N DETAILS Construction Project Byron /Braidwood Parformance Area Design Changes Obj e ctive No . DC.5 (Title)

Provide factual infor=atio'n that supports the Performance Evaluation Summary noted that one A-E had established a system for changes to piping supports that considered Byron /Braidwood and Unit 1/ Unit 2 changes that included consideration of whether already installed supports could be left as-is. Where significant changes to design were made , the impact on system function was also evaluated. This evaluation considered such items as air flow recalculation for HVAC changes and piping system function for items effecting P&ID changes on the auxiliary steam system.

10. ' The timely implementation of design changes is the responsibility of the site contractors and the CECO Project Construction Department. At this stage of the project, most design changes result from field problems. As a result, the changes are usually implemented as soon as an approved design change is issued to the field, usually an FCR.

Contractor document control programs ensure that drawings and 4:CN's are issued to field personnel for the implementation of latest design changes. As systems or parts of systems near completion, contractor personnel perform field system walkdowns to ensure installation is complete and in accordance with the latest design documents,

11. The possible inputs that can result in a design change are:

A. Field Problems B. Site Nonconformances C. Vendor Nonconformances D. Vendor Drawing Revisions E. As-Built Drawings Changes Requested by CECO (This would include regulatory

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changes and revised licensing requirements).

The handling, review and incorporation of the design changes resulting from the above listed inputs are defined in A-E procedures and instructions. The possible design change outputs may be:

A. Preliminary approval on'an FCR B. Issuance of an ECN C. Drawing Change D. Specification Change aQ/0960Q/Page 5

PERFORMANCE EVALUATION DETAILS Construction Project Byron /Braidwood Parformance Area Design Changes Objective No. DC.5 (Title)

Provide Summary factual information that supports the Performance Evaluation

11. (Continued)

Items A & B above are preliminary releases of design changes and are later incorporated into a revision of a drawing and/or specification.

For the sample of design changes reviewed it was observed that inputs resulting in a change were properly proces, sed, reviewed, reconciled against design criteria, incorporated into design documents and approved for field implementation in accordance with appropriate procedures and instructions.

12.

The system being employed at the A-E's for the evaluation of design changes requires that the cognizant discipline personnel review the change. Drawings are reviewed and/or appropriate discipline personnel are contacteu other areas. Itaswasrequired to determine the impact of the change in noted that there was good cooperation between disciplines in this respect (See #5). Calculations performed by an A-E Structural Department in support of design changes originating in the Electrical and Mechanical Departments were well documented and traceable to the item changed. The advance approval of design changes is sufficient to support the construction effort. The final incorporation of design changes had a backlog of items at the time of the evaluation. This backlog, however, was being reduced due to a l concerted effort by the A-E (See Item #2) l

13. For each design change item checked in depth during the evaluation, necessary backup calculations and/or other justification were documented and traceable to the change. The evaluation of the design changes reviewed was performed against the criteria used for the original design (See #4). Selection of equipment and material was done in the same manner as the original design. Review of the design change output released to the field showed that sufficien t information was included to install and inspect the items effected by the change.

Field liaison personnel are relied upon to provide information that will ensure the installability and maintainability of the revised designs. Functional systen-type analysis are performed for major design changes as required. (See #9)

Q/0960Q/page 6

PERFORMANCE EVALUATION.

SUMMARY

Construction Project BRAIDWOOD Performance Area Construction Engineering Obj ective No. CC.1 Evaluator (s) N. Main l

P:crformance Objective Engineering and design performed under the autho~rity of the construction organization should be controlled as to consistency with the basic design criteria to ensure compliance with applicable codes, standards and regulatory commitments.

Scope of Evaluation The evaluation of this area involved performing observations of the project construction organization and three on site contractor construction organizations. Interviews and document reviews were also conducted to gain additional information regarding the performance area.

Approximately 12 manhours were spent in the activities involved in ~he evaluation of this performance area.

Conclusion The project construction organization does not perform engineering and design activities. This responsibility is retained by S&L to ensure that the required controls are maintained. The activities which were evaluated for this performance evaluation indicated that the overall performance objective was satisfactory No weaknesses or good practices were noted.

Q/0990Q

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD Performa.nce Area Construction Engineering Objective No. CC.1 '

Evaluctor(s) N. A. Main Areas of weakness and corrective action; Good Practices No Findings identified. (See Details) l l

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PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Parformence Area Construction Engineering Objective No. CC.1 (Title)

Provide faccoal information that supports the Performance Evaluation Summary

1. The activities of the Project Construction organization were observed to evaluate the engineering and design functions which are being performed within this organization. It was noted that actual engineering and design activities are not performed within this organization. Their basic activities involved maintaining an interface with contractor personnel, review and approval of contractor p'rocedures , identification of construction problems, preparation of proposed" solutions, obtaining approval of the required design changes from S&L, review of NCR's, performance of surveillances, and assuring that changes are installed in accordance with the design change documents.

2. Interviews and document reviews were also conducted to evaluate the performance area.

A. Lead Mechanical Engineer l

The following items were discussed:

a) Duties and responsibilities of personnel and a general understanding of their job activities. Job description was available for the Lead Mechanical Engineer. Personnel were assigned responsibilities by area of the plant. The areas and person responsible were identified on an assignment sheet.

( b) Preparation of FCR's, review, approval, and follow-up.

c) Identification of problems, involvement of Project Construction

organization and interface with S&L. Sk1 maintains overall I

responsibility for review of original design criteria, and l inclusion of appropriate codes and standards in changes.

d) Performance of surveillances and methods used to perform.

Looked at checklists which are used in these activities.

e) Tracking of FCR's , ECN's and revisions to design documents made by S&L.

The items discussed and documents .eceived indicated good overall l performance of activities in this area.

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PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Pnrformance Area Construction Engineering Objective No. CC.1 (Title)

Provide factual information that supports the Performance Evaluation Summary B. Lead Structural Engineer The following items were discussed:

a) Duties and responsibilities

-Interface with structural contractors

-Review procedures

-Review costs and schedules b) Responsibilities are delegated by areas through the use of a matrix.

c) Problems are identified by the contractors and are resolved by SLL. S&L maintains overall design responsibility, d) Contractor has an interface procedure which defines responsibilities.

e) Design changes are documented on FCR's, ECN's or by actual revision to design documents. Drawings are being reviewed to pick up changes and assure that work is performed. Master plan has been developed to update contractors work complete and what has to be completed.

f) Contractor's procedures and NCR's are approved by Project Contruction.

Items discussed and documents reviewed indicated good performance of activities in this area.

C. Lead Electrical Engineer The following items were discussed:

a) Duties and responsibilities

-Proper administration and performance of contract by contractor.

-Administration of QA/QC Program

-Cost and schedule

-Supervise CECO electrical engineers

-Resolution of changes identified by both CECO and contractor personnel.

t: .r.R Qpg. -

PERFCRMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Performance Area Construction Engineering Objective No. CC.1 (Title)

Provide factual information that supports the Performance Evalua, tion Summary b) Engineers are assigned by areas which is~ documented on a matrix.

Six (6) engineers currently on staff.

c) Drawing revisions are being reviewed to assure that work is completed to latest revisions.

d) Changes are documented on FCR's, ECN's or drawing changes. ECN's and FCR's are noted on applicable drawings.

e) S&L maintains ultimate design responsibility. Compliance with original design criteria and codes and standards is maintained by S&L.

f) Contractor's procedures and all FCR's are approved by Project Construction.

j No problems were noted in the review of activities in this area.

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3. Further evaluation of the performance area was performed by conducting observations, interviews and document reviews of two on site construction contractors. The mechanical contractor and the electrical l contractor were selected.

A. Mechanical Contractor The mechanical contractor's engineering organization was observed in the performance of activities associated with piping, hangers and instrumentation. The instrumentation work has been included in the scope of the mechanical contractor on this project. No actual design engineering functions are' performed by contractor personnel. Their primary function is to prepare documents l (drawings & specifications) based on S&L documents, which provide l

fabrication and erection details to construction personnel, assist in identification and resolution of construction problems, tracking of design changes and verification that they are resolved, and preparation of as-built drawings. A recent organizational change in the contractors engineering organization was noted. The change was unique from the standpoint that CECO engineers have been placed

-Q/0990Qpg. 5

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Performance Area Construction Engineering Obj ective No . CC.1 (Title)

Provide factual information that supports the Performance Evaluation Summary in the contractor's organization to act as the leads for certain areas. The organization charts show them reporting directly to the contractor's site manager. The change was effective 9/22/82 but is still in the process of being fully implemented. Preliminary indications are that this will be a beneficial change for both CECO and the contractor. However, it is recommended that further evaluations be performed to determine its effectiveness over the long _un.

Documents were reviewed and interviews were conducted with the contractor's Lead Field Engineer and other engineering personnel from various areas. The results of these activities are outlined below:

a) As a result of the organizational change, preparation of process travelers and work packages is being transferred from QC to engineering. Procedures relating to this change have been revised and approved by Ceco and are at S&L for approval.

b) Procedures are approved by CECO and S&L.

c) In process of implementing dual NCR & DR program, d) No actual engineering work is performed on site by contractor personnel, e) Drawing revisions are reviewed and any rework or new work required is documented on a Field Change Order.

f) Field changes controlled by FCR, ECN or actual revisions to l

design documents.

g) As-builts are being tracked on a current basis through the use of rework spool drawings and revisions to isometric drawings, iQ/0990Qpg. o

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Parformance Area Construction Engineering Objective No. CC.1 (Title)

Provide factual information that supports the Performance Evaluation Summary h) Duties and respcnsibilities are vague as a result of the organizational change. Training sessions are currently being conducted to resolve this situation.

1) S&L is interfaced in' all design problems by contractor and CECO personnel through the use of FCR's and ECN's. Also through review of NCR's and review and approval of procedures.

j) The instrumentation group had no method of tracking outstanding Field Change Orders. A method was suggested and will be implemented.

No significant problems were noted in this area.

B. Electrical Contractor l

Interviews and document reviews were performed with the electrical contractors Project Engineer. The results of these activities are outlined below:

a) There are 18 people in the contractor's engineering organization. Only 2 or 3 are graduate engineers. Their duties include:

-Generate FCR's

-Solve problems

-Interpret details

-Prepare CEA traveler forms b) No design done on site by contractor personnel. Changes are made using FCR's. Work is performed using S&L design documents. ECN's and FCR's are identified on the drawings.

c) As-built are prepared by S&L on their drawings by incorporating FCR's.

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PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Parformance Area Construction Engineering Obj ective No . CC.1 (Title)

Provide factual information that supports the Performance Evaluation Summary d)^ Problems are identified on a Field Problems Report initiated by Production.

-Engineer investigates problem

-Proposes solution

-Prepare FCR

-Obtains CECO and S&L approval, e) QC is notified through the use of Installation Reports.

f) All procedures are approved by' CECO and SLL. Procedure changes are a continuous process. ECN s are used to identify S&L changes which effect contractor's procedures and require revisions.

g) Drawing revisions are reviewed by the assigned engineers, changes are identified and rework or new work is performed. No formal system is in place for tracking the status ca work activities. Contractor is aware of situation and is in the process of correcting.

No significant problems were noted in the activities looked at.

5Q/0990Qpg. 6

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON Performance Area Construction Engineering Obj ec tive No . CC.1 Evaluator (s) N. Main Pnrformance Objective Engineering and design performed under the authority of the construction organization should be controlled as to consistency with the basic design criteria to ensure compliance with applicable codes, standards, and regulatory commitments.

Scope of Evaluation The evaluation of this area involved performing observations of the project construction organization and two on-site construction organizations. In addition, interviews and document reviews were conducted with the three organizations to gain additional information to substantiate the evaluation. Approximately, 12 manhours were spent in the activities involved in evaluation of this performance area.

Conclusion The activities involved in the performance evaluation indicated that the overall performance objective was satisfactory. There were no weaknesses or good practices that were noted. All of the criteria involved in this r.rea could not be evaluated because the responsibility is retained by S&L

'off-site.

GQ/0986Q

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON

?;rformance Area , Construction Engineering Objective No. CC.1 Neluetor(s) N. Main Ar:=: is of weakness and corrective action; Good Practices No Findings identified =. (See Details) l 5Q/0956Q

PERFORMANCE EVALUATION DETAILS Construction Projec BYRON Performance Area Construction Engineering (Title)

Objective No. CC.1 Provide summary factual information that supports the Performance Evaluation 1.

The Project Construction organization was observed to evaluate the engineering and design activities which are being performed within this organization.

electrical, Includedand mechanical, in the observation structural werewhich engineers the activities are of the to performed support.the construction program. It was noted observation that actual engineering and design ctivities aas a result areofnotthe parformed within this organization.

maintaining an interface with contractor Theirpersonnel, basic activities involve of identification problems, preparation of " proposed" solutions, obtain installed in accordance with the design change documents.

2.

also conducted to evaluate the performance area.In addition to the with the Lead Structural Mechanical Engineer, Lead Electrical Engineer and LeadInterviews w Engineer.

Lead Mechanical Engineer The following items were discussed with the Lead Mechanical Engineer:

a.

Preparation, review, approval and follow-up of FCR's.

b.

Initiation of ECN's by the AE and. tracking.

c.

Identification organization. of problems and involvement of Project Construction d.

Review of original design criteria, codes and standards and inclusion of changes is performed by the AE.

c.

Duties and responsibilities of personnel and a general understanding of their job activities.

f.

Overall training of responsibilities. personnel and understanding of job All itemsgood indicate discussed showedinthat performance this the area.overall performance of activities

/0966Q

PERFORMANCE EVALUATION DETAILS Construction Project BYRON Parformance Area Construction Engineering Obj ective No. CC.1 (Title)

Provide factual information that supports the Performance Evaluation Summary Lecd Electrical Enginegr The following items were discussed with the Lead Electrical Engineer:

c. Identification of c " Problem Report" problems identified by contractor through the use of

b. Preparation of FCR's, review, approval and follow-up.

c. Review of original design criteria, codes and standards and inclusion in changes is performed by the AE.

d. Duties and responsibi3 tties of personnel and understanding of job responsibilities. A document had been developed which documents these responsibilities in a formalized manner.

Ic. Overall training of personnel.

All items discussed showed that the overall performance of activities indicate good performance in this area.

Land Structural Engineer The following items were discussed:

a. Duties and responsibilities of personnel and understanding of job responsibilities. Interface with Project Engineering and administration of day to day activities of structural contractors was reviewed.

'b. Identification of problems and documentation on FCR's.

• All problems are documented on FCR's or DR's.

• All FCR's require CECO involvement and must be signed-off prior to further processing. -

• Problems are resolved on site by SLL personnel.

c. Revieu of original design criteria, codes and standards and inclusion of changes is performed by S&L.

6Q/0966Q

a PERFORMANCE EVALUATION DETAILS Construction Project

~

BYRON

~

Parformance Area Construction Engineering Objective No. CC.1 (Title)

Provide factual information that supports the Performance Evaluation Summary

d. Overall training of personnel and understanding of job responsibilities.

All items discussed and reviewed indicate good performance in this area.

Further evaluation of the performance area was performed by conducting observations', interviews and document reviews of two construction-contractors. One of the contractors selected was the mechanical and the other was the instrumentation contractor.

A. Mechanical Contractor The Mechanical Contractor's Engineering Organization was observed in the performance of their day to day activities associated with piping end hangers. It should be noted that no actual design engineering functions are performed by the contractor's personnel. Taeir primary function is to preparc documents (drawings & specifications) which

provide fabrication and erection details to construction personnel, I

assistance in identification and resolution of construction problems, tracking of design changes and verification that they are resolved, and preparation of as-built drawings.

! Documents were reviewed and interviews were conducted with the Engineering Manager and Lead Engineers. The results of these

activicies are outlined below

I a. Original design requirements are obtained from S&L's drawings and design specifications.

b. Design problems identified during construction are documented on Field Problem Reports, NCR's, DR s, or FCR's. They are resolved and approved by.S&L who maintains overall design responsibility.

c. S&L maintains the responsibility to assure compliance with basic design criteria and applicable codes, standards, and' regulatory

! requirements.

d. Problems are resolved using FCR's, ECN's or revisions to S&L drawings.

1 i

1 56Q/0986Q t

PERFORMANCE EVALUATION DETAILS Construction Project BYRON Parformance Area Construction Engineering Objective No. CC.1 (Title)

Provide factual information that supports the Performance Evaluation Summary

c. Whatever method is used to resolve problems, the documents are controlled by the contractors Document Control Procedures. No problems were identified in the system used.

f. As-built drawings are prepared and sent to CECO Project Engineering and S&L for review, verification and incorporation into design documents. Incorporation of FCR's on S&L drawings is reviewed and checked by contractor's QA personnel. Document Control reviews and verifies incorporation of ECN's.

g. DCN's are issued to control work in progress and to retrieve documentation being used in the field to do work.

h. Site Implementation Procedures (SIP's) are used to control contractor's activities in the design control area. They are reviewed by Project Construction, QA and S&L. All NCR's and DR's are also reviewed and approved by the organizations noted above.

i. Field sketches are prepared by contractor personnel. However, they are based on S&L design drawings or specifications. Field sketches are issued and controlled in accordance with documented procedures.

No problems were noted in any of the activities which were looked at.

B. Instrumentation Contractor The Instrumentation Contractor's Engineering Organization was observed in the performance of their day to day activities associated with installation of instrumentation and hangers. They have no engineering ccpability on site. Their basic function is " interpretive engineering". All work is performed in accordance with S&L drawings and specifications. Documents were reviewed and interviews were conducted with the Lead Engineer. The results of these activities are outlined below:

a) Original design requirements are obtained from S&L's drawings and design specificaticus. They have come latitude for routing of instrumentation lines, but not instruments or root valves. All systems are as-built and submitted to CECO and S&L for review and verification.

5Q/0966Q

PERFORMANCE EVALUATION DETAILS Construction Project BYRON Parformance Area Construction Engineering Objective No.

(Title) ~

CC.1 Provida

Sumanry factual information that supports the Performance Eval uation b.

Design problems are identified on FCR's, NCR's or DR's . They are c.

resolved and approved by S&L who maintains design responsib .

S&L maintains the responsibility to assure compliance withasic b design criteria requirements. and applicable codes, standards and regulatory d.

Problems are resolved using FCR's , ECN's or revisions to S&L drawings.

c.

and S&L for review, verification and incorporat documents. ng f.

Activities are controlled by QA Manual and Implementation Procedures.

Construction, QA and S&L.These procedures are reviewed and approved approved by the organizations noted above.All NCR's and DR's are also review g.

Hangers documents. are fabricated and installed in accordance with S&L d No problems were noted in any of the activities which were look e dat.

PERFORMANCE EVALUATION.

SUMMARY

Construction Project BYRON Control of Construction Parformance Area Facilities and Equipment Objective No. CC.2 Evaluntor(s) John P. Woods Parformance Objective Construction facilities and equipment should be~ planned for, acquired, installed, and maintained consistent with project needs to support quality construction.

Scope of Evaluation The evaluation of this area consisted of reviews of records, interviews with responsible project personnel, plant walkthroughs and observations.

Approximately, 14 manhours were expended in this effort.

l l

l l Conclusion l The majority of activity evaluated under this performance ojbective was l satisfactory. However, there 'is a need to strenghthen certain aspects of l tha organization.

l 1

l SQ/0968Q

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON Control of Construction Psrformance Area Facilities and Equipment Obj e ctive No . CC.2 Evaluator (s) John P. Woods Areas of weakness and corrective action; Good Practices Finding)

(CC.2-1 The Program for the protection and preservation of permanent equipment is in need of improvement.

Corrective Action The surveillance activities employed to police these conditions will be increased in frequency and comprehensiveness. Additional visible indicators and instruction will be undertaken to increase personnel acncitivity to the needs. The activities will be enacted by February 1, 1983.

6Q/0988Q/Page 2 .

PERFORMANCE EVALUATION DETAILS Construction Project BYRON

, Control of Construction Parformance Area Facilities and Equipment Objective No. CC.2 (Title)

Provide factual information that supports the Performance Evaluation Summary

1. The protection of permanent equipment such as pumps, NCC's, Cable pans, pipe covering instrumentation, etc. was observed and revealed the following:

Locations: El. +401 in Turbine Room

a. At Column 4-K a live MCC had an indicated protection area marked on the floor. Inside this marked area was a cable reel #13Y30, a homemade device for cable work and a work cart containing tools and a welding machine.

b. A Cardox System Control Panel which was in operation is unprotected and not marked " Alive". It is in a high traffic area at a stairway. The area was further restricted by a pressure tank lying on its side waiting for installation.

c. Piping insulation in all areas showed damage due to use as scaffolding or from general work or traffic.

d. At a live Sa jling Gauge Board there was no marked protective clearance area and if there had been, there was a large valve almost touching the Board.

e. At Col. 22-K, there is an accumulation of helmets, tool boxes and miscellaneous construction materials underneath the air dryer and inside the reservoir area under the dryer.

f. The couplings for the vacuum pumps were not made up and the shafts and couplings were not protected.

! g. The junction box cover was hanging loose exposing the wiring for the Vacuum Priming Pump. The immediate area was being used for fabrication of sections of the separation wall between Units 1 and

! 2. There was no protection of the pumps, resulting in damaged control tubing. The entire area was cluttered.

h. The live 250v DC Distribution Center is near an exit door. This is a high traffic area and the Distribution Center is unprotected'for this traffic and also from overhead work.

56Q/0955Q

l PERFORMA"CE EVALUATION DETAILS Construction Project BYRON Control ot Construction Parformance Area Facilities and Equipment Obj ective No.

(Title) CC.2 Provide summary factual information that supports the Performance Evaluation i.

The fire riser valves at Col. H-1 was obstructed by metal scaffold and could threads onnot-be operated and there was danger of damaging the the valve.

the valve thread. Ironically, the hn.ce thread did not match 2.

In an interview with the Field Construction Engineer responsible for cable pan protection, he stated that there was a system for approval end tracking of scaffolds to be installed using cable pans or electrical equipment as a support. Even with the system there are numerous scaffold. occurrences where workmen are using the cable pan as a They were seen standing inside the pans on top of cables and using the cable pan for tool storage and a work place. These occurrences are noted in observations by other team members.

l 1

l l

3/0966Q

T PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD

, )

Construction Facilities Parformance Area and Equipment Objective No. CC.2 Evaluntor(s) John P. Woods Performance Objective ,

Construction facilities and equipment should be planned for, acquired, installed, and maintained consistent with project needs to support quality construction.

Scope of Evaluation Approximately 25 manhours were expended in the evaluation of this performance objective. These manhours were spent conducting interviews, plant and storage area walkthroughs, observations, preparation, analysis and write-up. Records and maintenance programs were reviewed in addition to inspection of areas as reflected in the section titled " Control of Construction Facilities and Equipment".

J l

l l

l L Conclusion l The activities evaluated under this performance objective are satisfactory.

)Q0995Q l - . . - - - _ _ - . . ._ _ ._ _

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD Construction Facilities Terformance Area and Equipment Objective No. CC.2 Ev:1uctor(s) John P. Woods Aracs of weakness and corrective action; Good Practices No Findings identified. (See Details) e l

i 1

l

'Q/0995Qpg. 2 1

..e PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Construction Facilities Parformance Area and Equipment Objective No. CC.2 (Title)

Provide factual information that supports the Performance Evaluation Summary Outdoor Storage

1. There is ample outdoor storage area.

2. The outdoor storage is sandy and easily drained.

3. Roads leading to and dividing storage area are wide and will be maintained for access.

4. Equipment, piping, structural steel, etc. is stored above ground on cribbing.

Indoor Storage

1. Main building is being used as a warehouse.

2. CECO and contractor warehouses are not overcrowded.

3. Warehouses are well lit and sprinkled.

4. Warehouses are cleaned and has a good inventory control.

l Construction Equipment

1. Operation of most mobile equipment is operated and maintained by one contractor.

2. Repair shop is large, well lit, heated, contains necessary tools, hoists, etc. and hand fire extinguishers.

3. Capable of making major repairs.

4. Contract.out some work.

5. Have inventory of small parts, normally all repair parts can be purchased locally or in a reasonable time.

l6. Gas island was away from repair shop and is fire protected.

7. Record of maintenances are kept.

8.

Specialty equipment is rented on an as needed basis.

19. Permanent building cranes used for construction are inrpected and I

repaired if necessary every 5 weeks.

1 10. Construction fire pumps, one diesel drives and one electric driven, are inside a fire resistant building which is well lit, clean and heated.

11. The equipmene for firefighting is adequate.

12. Small tools, under $2000, are under control of each contractor and has responsibility for repair & maintenance.

13. P.C. Lead Structural Engineer has control over use and repair of large I

mobile type equipment.

4.0995Q/pg. 3

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Construct [on Facilities Parformance Area and Equipment Objective No. CC.2 (Title)

Provide factual information that supports the Performance Evaluation Summary Compressed Air

1. There are three large compressors for central air.

2. Distribution of air throughout buildings is adequate.

3. Building housing air compressors is well ventilated and maintained.

First Aid

1. Fire brigade is comprised of 16 people.

2. Nurse on duty during all working hours.

3. Ambulance on site.

4. First aid station has basic first aid equipment.

Trmporary Power

'l. P.C. Electrical Field Engineer responsible for maintenance and cdditions.

2. Two sources of power.

3. Ample power for start-up and bumping of permanent equipment.

4. There is a surveillance program for temp. lighting.

5. In general main buildings are well lit.

6. Parmanent lighting 65% installed.

7. Hold Card System in use on permanent equipment that is being used for temporary power.

Sanitary Facilities ,

l1. An adequate number of " Satellites" and other temporary urinals are spread around job site.

krcftShopsandChangeHouses

1. Kept clean, ample in size, etc.

3. Some construction craft people use various locations in main buildings as reporting areas.

Eazardous Material Storage

p. Tanks of gases are stored away from buildings and are fenced in.

2. Central source for gas and are piped throughout main buildings.

4

}'?5

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON

&crformance Area Material Control Objective No. CC.3 Evalustor(s) H. P. Studtmann -

l Performance Objective Material and equipment should be inspected, controlled, and maintained to ensure the final as-built condition meets design and operational requirements.

Sc' ope of Evaluation This evaluation involved approximately 16 manhours in observing work ectivities, reviewing records, walkthrough storage areas and interviews with various levels of management which are noted in the Performance Evaluation. Details. .

Conclusion The activity evaluated under this performance objective was generally satisfactory.

6Q/0989Q

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON Parformance Area Material Control Objective No. CC.3 Evsluttor(s) H. P. Studtmann Areas of weakness and corrective action; Good Practices No findings were noted in this area. Finding will be covered under Parformance Objective QP.3.

6Q/0989Q

J PERFORMANCE EVALUATION DETAILS Construction Project BYRON Parformance Area Material Control Objective No. CC.3 (Title)

, Provide factual information that supports the Performance Evaluation Summary

1. Material Control was evaluated in the following areas: Receiving, Storage and Control of Material. Details are presented in an observation of Receiving Inspection.

2. During the receiving inspection the procedure was followed correctly.

3. Subsequent to the above observation a walkthrough was conducted at the

, main warehouse and satellites buildings.

a. ASME Section III and B.31.1 materials were segregated and locked up.

b. Each warehouse had a materials person present.

c. Materials generally were stored properly with the exception of the following. Storage of S.S. Weld type flanges were found l deficient. Flanges were stored face to face without protection.

l Corrective action was initiated immediately.

d. Outside storage lay down areas generally were acceptable. Clean up was in program.

4. Interviews were conducted with the Project Materials Coordinator, 1

Storekeeper and Receiving Inspector.

a. Material Coordinator was very knowledgeable in the whole Material Control Program.

I b. Storekeeper displayed an awareness of the ongoing work activities I

and his duties.

l c. Receiving Inspector was experienced and well versed in his area of l responsibilities.

3

!. Fire protection facilities 11s in working order in all warehouses; also noted portable equipment were available.

f. Generally, the warehouse was very clean.

k. Stored items were sampled for traceability to docucents.

l 6Q/0989Q

PERFORliANCE EVALUATION DETAILS Construction Project BYRON P:rformance Area Material Control Objective No. CC.3 (Title)

Provide factual information that supports the Performance Evaluation Summury

8. Documentation was reviewed against receiving reports. Found acceptable.

9. Deficient items are controlled.

10. A system is in use for control and issue of material.

11. Maintenance for special equipment is in use.

Most major equipment has been installed at the site.

6Q/0989Q

PERFORMANCE EVALUATION.

SUMMARY

Construction Project BRAIDWOOD Parformance Area Material Control' Obj ective No . CC.3 Evalustor(s) Team -

Performance Objective Material and equipment should be inspected, controlled, and maintained to ensure the final as-built condition meets design and operational requirements.

_S_c' ope of Evaluation The material and equipment and plant condition were evaluated to ensure that material control contributed to plant start-up was in agreement with the initial design and operational requirements. This area received the input from all team members. -

Conclusion The activity evaluated under this performance objective was generally satisfactory; however, the area of cleanliness needs improvement.

a0998Q

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD Parformance Area Material Control Obj ective No. CC.3 Evaluator (s) Team Ar:tes of weakness and corrective action; Good Practices Finding):

(CC.3-1 Thar is a need for improvement in cleanliness in the plant. Specifically, long term storage of value on the Turbine Room floor, pipe and cable pans covared with debris and installed equipment are not being covered to maintain cleanliness.

Corrnctive Action:

Project Construction Department will review and evaluate existing housekeeping procedures and revise them accordingly to meet current rnquirements by November 24, 1982.

SQ/0998Qpg. 2

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Performance Area Material Control Objective No. CC.3 (Title)

Provide factual information that supports the Performance Evaluation Summnry

1. The following observations were noted:

A) Welding and grinding near open switch gear.

B) Bringing pipes into the plant with several buckets of sand inside the pipe.

C) Pip'e caps missing on installed lines.

D) Stacking materials close to equipment.

. E) Materials being at red in open valves.

F) Long term storage of some valves on Ibrbine Room floor. MRR reviewed indicated release to construction in Feb. 82, no plans to install in the near future.

G) Some installed equipment not being covered to maintain cleanliness.

H) Some ducts, pipe and cable pans contain debris.

iQ/0998Qpg. 3

~

PERFORMANCE EVALUATION.

SUMMARY

Construction Project BYRON Parformance Area Control of Construction Processes Obj ective No . CC.4 Evaluctor(s)J. Woods, R. Vertovec, E. Wilmere, R. Curran, H. Studtmann, ---

M. Gorski, T. Didesch, R. Ferguson Parformance Objective .

Tha construction organization should monitor and control all construction processes to ensure the project is completed to design requirements and that a taigh level of quality is achieved.

Scope of Evaluation .

Tho evaluation of this area involved essentially the entire team, Approximately, 650 manhours were expended in observing work practices at various locations on the project. The evaluation involved interviews with various levels of supervision and management and craft personnel and reviews of associated documents.

l l

Conclusion The majority of activity eval 6ated under this performance objective was found satisfactory. How ever , improvements are needed in some areas of procedural controls.

6Q/0991Q

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON Performance Area Control of Construction Processes Objective No. CC.4 Evalustor(s) ,J. Woods , R. Vertovec, E. Wilmere , R. Curran , H. Studtmann, M. Gorski, T. Didesch, R. Ferguson --

Arats of weakness and cor'rective action; Good Practices Finding (CC .4 -1)

Craft Foremen.and Field personnel are not always knowledgeable of cpplicable procedures and design documents. A number of areas were noted where personnel did not adhere to site procedures and design documents.

Corrective Action:

The importance of adhering to work procedures will be reiterated and rc-emphasized to all contractor supervisors. This action will be completed by December 17, 1982. In addition, a monitoring program will be established to ensure adequate progress is being made in the coming months.

Finding (CC.4-2)

The following good practice was noted: On seismic qualified block walls there are bright yellow signs (approx.18" x 18") stating:

NOTICE THIS WALL HAS BEEN AS-BUILT NO ADDITIONAL ATTACHMENTS WITHOUT APPROVAL BY FIELD CHANGE REQUEST In addition, all attachments to these walls had a small as-built sticker attached.

1 oQ/0991Q l

PERFORMANCE EVALUATION DETAILS Construction Project i BYRON Performance Area Control of Construction Processes Objective No. CC.4 (Title)

Provide factual informatio'n that supports the Performance Evaluation ~

summary .

1. The performance of masonry work was observed to evaluate the quality of block wall support installation. The details were presented in observation of installation of block wall supports. Weaknesses were noted in the craft. knowledge of applicable procedures , use of substitute procedures and a lack of adherence to design drawings.

2. The performance of masonry work was observed t6 evaluate the quality of solid block wall installation. The details were presented in

' observation of masonry wall and column supports. Weaknesses were noted in the use of defective materials and inadequate installation of grout behind doorjambs. ,

3. The performance of masonry work was observed to evaluate the quality of enchor bolt installation. The details were presented in observation of grouting operation. Weaknesses were noted in craft knowledge of applicable procedures, adherence to procedures, and use of substitute procedures.

l

4. The performance of structural work was observed to evaluate the quality of structural steel insta.llation. The details were presented in observation or miscellaneous structural steel rework in auxiliary and containment building during this observation it was noted that production workmen'did not follow design drawing requiremento.

l5. The performance of electrical work was observed to evaluate 'the quality of electrical cable installation. The details were presented in observation - cable. pulling. Weaknesses were noted'in craf t foreman knowledge of applicable procedure requirements and craft adherence to good installation practices.

'6. The performance of mechanical work was observed to evaluate the quality l

of anchor bolt torquing. The details were presented in observation of HVAC System installation by Reliable Sheet Metal at Byron. During this observation it was noted that craftsmen were not adhering to approved

~

procedures.

l i

I 6Q/0991Q l

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD Performance Area Control of Construction Processes Objective No. CC.4 l

Ev21ustor(s) T. E. Didesch _

l l

l Parformance Objective The construction organization should monitor and control all construction processes to ensure the project is completed to design requirements and that a high level of quality is achieved.

Scope of Evaluation Tha evaluation of this area involved essentially the entire team.

Approximately 650 manhours were expended in observing work practices at various locations at the project. The evaluation involved discugsions with various levels of supervision and management, and craft personnel.

In cddition, a significant amount of associated documents were reviewed.

Conclusion The majority of the activities evaluated under his performance objective were found to be satisfactory, llowever, there is a weakness in consistency of procedure compliance, inadequate procedures and training in procedural requirements.

1/1001Q

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD Performance Area Control of Construction Processes Objective No. CC.4 Evalustor(s) T. E. Didesch

~

Areas of weakness and corrective action; Good Practices Finding)

(CC.4-1 A variety of procedures are not adequate and doPersonnel not provide sufficient datail for personnel to perform the activities. are not always knowledgeable of applicable procedure requirements. Some instances of failure to adhere to procedural requirements and for design documents was also observed.

Corrnctive Action:

The importance of adhering to work procedures will be reiterated and re-emphasized to all contractor supervisors. This action will be completed oy December 17, 1982. In addition, a monitoring program will be

~

established to ensure adequate progress is being made in the coming months.

t l

l 6Q/1001Qpg. 2

1 .-

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Performance Area Control of Construction Processes Objective No. CC.4 (Title)

Provide factual information that supports the Performance Evaluation _

Summary A. Performance of fabrication / installation activities were observed to evaluate the quality of small bore piping, electrical work, equipment setting, masonry work and structural work. The details were presented in the Observation of each of the activities. A weakness in the area of procedures was noted.

1. Designated QC hold points for fit up inspection were bypassed for Class B small bore piping welds. Foreman / welder did not contact the QC Inspector prior to welding of joints contrary to established procedures.

2. Liquid penetrant examination of four flange to pipe welds was not performed in accordance with approved procedure. Inspector did not provide for 100% coverage by failure to apply developer to- g' ,\ <

approximately 1 1/2" of each weld.

3. Electrical cable was inadequately cupported.4 Loope.d cable ',

( 110 ft. long) was supported at a' single location.

4. Area inside the yellow live around energized electrical equipment is not consistently being maintained clear of items as prescribed by project procedures.

t

5. At 69 KV Bus 157 and 158, with several breakers flagged as energized, there was no yellow tape on floor to designate operator clear areas.

6. Weld filler metal control in a contractor's fabricar. ion shop is not included in th applicable procedure.

7. Compliance with a procedural requirement to clean terminal lugs and wire insulation with solvent was not met by electrician during cable termination activity.

8. Masonry blocks were stacked.on a cable pan containing 14 cables.

There were eight 20 lb. blocks placed on a motor board on top of the cable pan contrary to, project procedures.

1 I Q/1001Qpg. 3

~~

=

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD t'

Performance Area Control of Construction Processes Objective No. CC.4

e (Title)

~

Provide' factual informatio'n that supports the Performance Evaluation Summary

9. 3Cno' struction foreman ~(electrical) was not aware of details for

, conduit separations. Foreman stated he was not trained on

[ revisions to procedures.

10. Pr'ccedure to set pump bases is 'not clearly established. Lack of

' , clear definitions of the installation procedure exists due to inconsistencies between the. contractor's procedure, A/E ecification and J.he manufacturer's installation requirements.

. Ob sp'cervations of r.on-safety related equipment revealed the following deficiencies:

, a) L Contractor /s grout; release form does not include provision to identify status of' shims or wedges.

i b) , Mechanical contractor release a pump for grouting w'ith drive

, s motor in place. This was contrary to manufacturer s requirements.

c) Concrete foundation was not roughened as required prior to setting.

d),Gr$utmaterial,differedfrommanufacturer'srequirement. .

e) . Shims are left in place after grouting.

(PCD) did not monitor f[) ',Phoject Conctruction contractor's performance. Department i , .

s 11. Procedurb for Control for Measuring and. Test Equipment of the st6 cturals. contractor is not adequate in' detail.

B. In addLt: ion to the Observation ten work packages were selected which covered the activities of the mechanical, electrical and structural contri.ctors. Highlights of the associated discussions and field -

inspections were:

1) Lead Engineers, Craft General Foreman and Foreman demonstrated a

_ good knowledge of weekly schedtle commitments and work currently in progress. ,

(

• s s

E.Q/1001Qpg.4 ,

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Performance Area Control of' Construction Processes Objective No. CC.4 (Title)

Provide factual information that supports the Performance Evaluation Summary

2) Contractor activities witnessed were performed in accordance with rocedures. However, there is a weakness in the area of p' procedures" as described in A above. Contractor procedures are consistently reviewed and approved by the Owner (Proj ect Construction and QA departments) and the Architect Engineer.

3) Two electrical QC Inspectors were each observed performing two separate inspections. Their task was well defined and requirements documents clearly established prior to leaving the office area.

They carried the appropriate drawings and procedures with them to the work site. Each inspector demonstrated good knowledge and were efficient in performing the inspection. In one of the inspections, a deficiency was identified, documented and appropriately processed. The attitude of the responsible construction foreman relative to the deficiency and the level of quality required was good. -

4) Control of weld filler metal was apparent at each contractor. At least six individual welders demonstrated a very good knowledge of the control methods. The two welders assigned to the fab shop of a contractor that did not have the necessary documentation (rod issue tickets) were found to very conscientious and knowledgeable with respect to weld filler metal control. The attitude of the welders, the limited access feature of the fab shop and the methods implemented by the welders themselves has established a good control of the weld filler metal was actually being implemented.

5) Valid drawings were found at each work location for use by construction crafts. QC personnel carried the applicable procedure to the work location, where necessary for reference. Procedures applicable to craft construction activitiec were not located at the work location, but were available for reference within reasonable proximity.

6) Each contractor has implemented a method whereby the details of the work to be performed are provided to crafts supervision and QC.

7) Various conditions and associated records were reviewed for identified nonconformances. Supervision and crafts personnel had a good knowledge of need for control, reporting and tagging methods required for deficiencies.

iQ/1001Qpg. 5

PER'ORMANCE F EVALUATION DETAILS Construction Project BRAIDWOOD Parformance Area Control of Construction Processes Objective No. CC.4 (Title)

Provide factual infcrmation that supports the Performance Evaluation Summ ry C. Interviews with first line supervision addressed the following:

1) Craft personnel received training relative to project-specific requirements.

2) Construction process procedures were complied with especially when such procedures have been revised.

G Q/1001Qpg. 6

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON Torformance Area Construction Quality Inspections Objective No. CC.5

Evnluctor(s) T. E. Didesch l

Parformance Objective Construction inspections should verify and document that the final product maets th( design and quality requirements.

Scope of Evaluation This evaluation involved the inspection activities of the following contractors:

A. Mechanical Piping B. Electrical C. Instrumentation Piping D. NDE and Testing ,

Interviews and discussions were held with management personnel as well as inspectors of each of the above contractors. Inspection activities were observed as performed in the field. Evaluation details are provided in the section titled Performance Evaluation Details.

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Conclusion It was found that inspection activities are generally satisfactory ralative to definition of work to be performed, reporting systems for i deficiencies, proceduralized requirements and integrated inspection

! planning, independency of inspection responsibilities, and the l docucentation of inspection results i'cluding review thereof.

6u; t , .t:

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON Performance Area Construction Quality Inspections Objective No. CC.5 Evaluator (s) T. E. Didesch Areas of weakness and corrective action; Good Practices No notable areas.of weakness were revealed in this evaluation of Quality Inspection of Construction Activities. Practices used are standard with nothing encountered that could be categorized as out of the ordinary.

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PERFORMANCE EVALUATION DETAILS Construction Project l BYRON Performance Area Construction Quality Inspections Objective No. CC.5 (Title)

Provide factual information that supports the Performance Evaluation Summary

1. The performance of small bore piping, cable ternination, and hanger installation inspections were witnessed in the field.

A. Inspection points during the fabrication / installation of small bore piping were well defined in the applicable travelers. Discussion with inspectors revealed their understanding of quality requirements and their responsibility in performing the required inspections.

B. Discussion with Foremen and Craftsmen established a good working relation with QC Inspectors. A welder stated he welcomed QC checking his work. He also stated he felt responsibility for the quality of his work, but "He was only human and QC might pick up something which is not acceptable."

C. Records established assigned inspectors which were duly qualified / certified for the functions performed. Included were NDE personnel performing liquid penetrant examinations.

D. Several inspectors (different contractors) stated they had what they thought was a good understanding of the total system and measures implemented to document and control discrepancies.

Discussion based on the applicable contractor's procedure and their actions documented in inspection records supported the statements made.

E. ectors understand the Contractor's interface withQA/QC and Supervisors the role ofandtheInsp/

NDE Test Contractor performing overcheck inspections on behalf of the owner.

F. Experienced crafts personnel are utilized and reassigned and trained as QC Inspectors. This practice is beneficial in cases of personnel actually observed performing inspections.

G. QA/QC personnel stated, without exception, that their efforts are fully supported by management. Each inspector stated he had no case where an identified rejection or discrepancy was overridden by management.

cQi e v u x

PERFORMANCE EVALUATION DETAILS Construction Project BYRON Performance Area Construction Quality Inspections Objective No. CC.5 (Title) l Provide factual information that supports the Performance Evaluation Summary H. A new-entry QC individual (no craft experience) stated he has been

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on site for eight months and was currently completing six months of on-the-j ob training . This was in preparation to taking an examination to qualify for certification as a Level I Inspector (Electrical). Another individual (Mechanical Contractor) that had eight years of craft experience was undergoing inspector training prior to certification. Each of these men, plus three others that were already certified as Level II, stated that their opinion of requirements for inspectors was stringent and assured that individuals would be qualified prior to being certified.

I. Pre-defined checklists are used by the QC organization of each contractor to conduct a final verification of documentation and physical item acceptability upon completion and prior to pre-operation testing for completeness and accuracy.

1 l J. Torquing of bolts is clearly defined, and review of activities and records established that identification of the calibrated wrench is consistently documented. Traceability of calibrated equipment used is possible from the documented record to verify proper type, range, and accuracy. Records of inspection maintained by the Mechanical and NDE/ Test contractors were reviewed and they evidenced proper scope of inspection, the inspection results/ status and the identification of the inspector and level of qualification.

l me=m~=="fM*

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD Performance Area Construction Quality Inspections Objective No. CC.5 Evaluctor(s) T. E. Didesch l

l Performance Objective Construction inspections should verify and document that the final product macts the design and quality requirements.

Scope of Evaluation This evaluation involved the inspection activities of the following contractors:

, A. Mechanical B. Electrical C. Structural Inspection activities performed by the QC groups were observed as l

performed in the field. Interviews, discussion and review of inspection I

records was performed at each contractor location. Details of this evaluation are provided in the Performance Evaluation Details section.

1 Conclusion l It was found that those QC Inspection activities actually witnessed were l generally satisfactory and that records of completed inspections indicated they were performed in the same satisfactory manner.

6Q/1004Q

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD Parformance Area Construction Quality Inspections Objective No. CC.5 Evaluctor(s) T. E. Didesch Arres of weakness and corrective action; Good Practices This evaluation establishe'd that areas of inspection weaknesses have been id:ntified and are currently receiving significant attention and action rslative to corrective actions. Therefore, this evaluation did not concern itsalf with such activities already identified and currently being subject to corrective actions.

9 SQ/1UO4Q

PERFORMANCE EVALUATIO.N DETAILS Construction Project BRAIDWOOD Parformance Area Construction Quality Inspections Obj ective No . CC.5 ' -

(Title)

Provide factual information that supports the Performance Evaluation Summary

1. The conduct of small bore piping, electrical 'and structural activities were witnessed as administered and performed in the field.

A. Inspection activities for QC inspections are well defined in preplanned travelers and/or checklists. The level of understanding relative to inspection requirements is determined as adequate based on the performance and discussion with inspectors from each contractor organization. The attitude of the inspectors is considered to be good.

B. Discussion with various foremen and craft personnel established, based on their statements, that they had no problem with interfacing with the QC inspection personnel. Actual witnessing of inspection activities in the field where the inspections resulted in both acceptance and rejection supported the statements made.

C. Personnel records being maintained established that QC Inspectors were duly qualified / certified for the functions performed or that could be performed. Folders for each individual were well arranged and easily understood.

D. There was a good understanding by all inspectors relative to the systems used by the contractors to identify, document, resolve and correct deficiencies. Records to log and track deficiencies were good and up to date.

E. QA/QC Supervision all had adequate experience and there was evidence that they control and have the respect of their group.

Each QC organization is independent of production and interfaces well with all organizations.

F. QC personnel, including inspectors, stated they had the full support of their management to carry out duties assigned to them.

Rejections resulting from inspections and examinations are rarely, if ever, reversed by supervision.

G. Records of results completed by field QC Inspectors received a higher level review for completeness , clarity and legibility.

aQ/100-0

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Parformance Area Construction Quality Inspections Obj ective No . CC.5 (Title)

Provide factual information that supports the Performance Evaluation Summary H. Good identification of calibrated equipment used during QC inspection functions is maintained. A review was conducted of several out-of-tolerance uses which were identified upon routine calibration of equipment. These reviews verified that an in-depth check and evaluation had been performed to ensure items previously inspected / tested were acceptable.

I. Training Programs for QC Inspectors have recently improved in scope and frequency. Inspectors have stated the sessions are worthwhile and necessary to help them with a better understanding of the requirements when performing their duties. The inspectors attitude reflects on the inadequacies of some procedures.

-Q/1004Q

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON Terformance Area Construction Corrective Actions Obj ective No . CC.6 Evaluator (s) E. Martin l

Performance Objective The construction organization should evaluate audits, inspections, and surveillances, process replies and follow-up, and take corrective action to prevent recurrence of similar problems.

Scope of Evaluation The evaluation of this area involved interviews with key CECO site personnel and review of corrective actiou records. Approximately 8 manhours were expended in observing site construction corrective action activities. Approximately 6 manhours were devoted to discussions with various levels of supervision and field personnel.

Conclusion The overall activity evaluated under this performance objective was satis factory . Additionally, one aspect of the activity appeared to be above average.

5Q/0993Q

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON Performance Area Construction Corrective Actions Obj ective No . CC.6 Evalustor(s) E. Martin Areas of weakness and corrective action; Good Practices Finding)

(CC.6-1 The following good practice was noted: The Project Construction Department has reinforced their involvement in corrective action activities with the installation of a Quality Control Supervisor to oversee quality related activities.

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PERFORMANCE EVALUATION DETAILS Construction Project BYRON Parformance Area Construction Corrective Actions Objective No. CC.6 (Title)

Provide factual information that supports the Performance Evaluation Summary The Project Construction Department was observed to evaluate their involvement in evaluating, processing and resolving deficiencies identified in audits, surveillances and nonconformance reports. Interviews were conducted with key Project Construction Dtrar*. ment and Site Quality Assurance Department personnel and various types of corrective action reports and analysis were reviewed. The highlights of the interviews and review were:

A. The Assistant Construction Department Superintendent displays an indepth knowledge of current and past site oriented deficiencies. In particular, he was asked to describe how he reviewed problems and identified their corrective action. It became apparent that he was reviewing deficiencies for both immediate casues and root causes.

B. Project Construction Department's installation of a Quality Control Supervisor to follow NRC activities, audit deficiencies and quality l ralated activities further demonstrates their involvement in quality related corrective action.

e a

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD Parformance Area Construction Corrective Actions Objective No. CC.6 Evaluator (s) E. Martin Performance Objective The construction organization should evaluate audits, inspections, and surveillances, process replies and follow-up, and take corrective action to prevent recurrence of similar problems.

Scope of Evaluation The evaluation of this area involved interviews with CECO site personnel and a review of corrective action reports and follow-up records.

Approximately, 8 manhours were expended in observing site construction corrective action activities. Approximately, 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> were devoted to discussions with various levels of supervision and field personnel.

Conclusion The overall activity evaluated under this performance objective was satisfactory.

6

PERFORMANCE EVALUATION SLM. MARY Construction Project BRAIDWOOD Parformance rea Construction Corrective Actions Objective No. CC.6 Evaluator (s) E. Martin Arnas of weakness and corrective action; Good Practices No Findings identified in this area. (See Details) 9 5

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PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Parformance Area Construction Corrective Action Objective No. CC.6 (Ticle)

I L Provide factual information that supports the Performance Evaluation

[ Summnry Tha Project Construction Department was observed to evaluate their involvement'in evaluating, processing and resolving deficiencies identified in audits, surveillances and nonconformance reports. Interviews were conducted with key Project Construction Department and site Quality Assurance Department personnel. Additionally, various types of corrective action reports and analyses were reviewed. The highlights of the interviews and reviews were:

A. The Project Construction Department Group Leaders (Mechanical and Structural) display a good knowledge of past and current site oriented deficiencies. They displayed a concern to determine the root cause of the identified deficiency.

B. Nonconformance Reports demonstrated the Project Construction Department Superintendent 's involvement in the resolution of deficiencies. His inputs into the corrective action were significant.

'C. Site Quality Assurance conducts trend analysis of both CECO and On-Site Contractor Nonconformance Reports. On-Site Contractor audit deficiencies are also trended by this site organization.

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e .d PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON Parformance Area Test Equipment Control Obj ec tive No . CC.7 Evaluator (s) T. E. Didesch _

__ Performance Objective M2asuring and test equipment should be controlled to support construction testing effectively.

Scope of Evaluation This evaluation included interviews and discussions with supervision of tha organizations responsible for control of measuring and test equipment, plus the individuals actually performing the function. Contractors included in the evaluation were:

1. Mechanical Piping

2. Electrical

3. Instrumentation Piping

4. NDE/ Test Review of records to support calibrations and the actual equipment and storage / issue facilities was performed at each of the contractors.

Conclusion Test equipment control is adequately administered and implemented in a manner that ensures inspection and test results are reliable and support project requirements. Practices were all determined to be adequate.

SQ/0994Q ,

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON Forformance Area Test Equipment Control Obj ective No . CC.7 Evaluator (s) T. E. Didesch Arcas of weakness and corrective action; Good Practices No specific weakness was identified.

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60/0994Q

PERFORMANCE EVALUATION DETAILS Construction Project BYRON .

Parformance Area Test Equipment Control Obj ective No . CC.7 (Title)

Provide factual information that supports the Performance Evaluation Summary A. Each contractor has implemented a method to uniquely identify measuring and test. equipment to facilitate control.

B. Equipment is maintained under limited access conditions coupled with issue control. Custodians assure that only equipment having a valid calibration are issued for use.

C. Card files which identify specific equipment by description and serial number are used to assure that equipment is removed from use prior to expiration of the valid calibration period.

D. Contractor's QC procedures contain guidance for action when equipment is suspected to be defective. There were examples at each contractor where equipment that had been dropped was returned to the source of issue for re-check or re-calibration.

E. Each has a system to effect an evaluation of items inspected or tested with equipment reported to have an as-found out of tolerance conditions. Past examples were reviewed and found to have been comprehensive and supported with good documentation.

F. Calibration frequencies are stated in each contractor's applicable procedure. Review of calibration records demonstrated that the specified frequencies were being maintained.

G. Torque wrenches are calibrated on site by the NDE/ Test Contractor for other site contractors. The secondary standards used for this purpose were supported with appropriate certification documents. Other equipment is sent off site for calibration. Review of certification records which were readily retrieved verified.that calibration standards used were- identified and traceable to the National Bureau of Standards.

6Q/0994Q

^

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD forforma'nce Area Test Equipment Control Objective No. CC.7 Evaluator (s) T. E. Didesch Parformance Objective M2asuring and test equipment should be controlled to support construction testing effectively.

Scope of Evaluation This evaluation included interviews and discussion with contractors' supervision responsible for control of measuring and test equipment plus the individuals actually performing the function.

Review of records to support calibrations and the actual equipment, storage facilities and issue methods was conducted at contractor facilities.

Conclusion Test equipment (M&TE) control is administered and implemented in a manner that ensures inspection and test results are reliable and that the item tested or inspected meets project requirements. Practices used were determined to be adequate.

6Q/1006Q

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD P rformance Area Test Equipment Control Objective No. CC.7 Evaluntor(s) T. E. Didesch Arcas of weakness and corrective action; Good Practices No areas of weakness were identified.

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PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD P:rformance Area Test Equipment Control Objective No. CC.7 (Title)

Provide factual information that supports the Performance Evaluation Summary A. Contractors evaluated each had a system and method to uniquely identify their measuring and test equipment. Review of actual equipment identification against logs and records verified good control.

B. Equipment is maintined under limited access control and issue is documented and records maintained. Custodians all had neat and orderly warehousing coupled with proper segregation (i '. e . , safety and non-safety related, current calibration vs. expired).

C. A similar card file is used by the contractors which identify specific equipment by description and serial number. This card file system is used to assure that equipment is removed from use prior to expiration of the valid calibration period. Status was current for each contractor.

D. Contractors have procedures that define action to be taken when l

equipment is suspected to be defective. Records veriffed that there ware occasions where when equipment was dropped it was returned for re-check or re-calibration.

E. The contractors have an effective system to evaluate items inspected or tested with equipment reported to have an as-found out-of-tolerance condition. One example was reviewed and found to be comprehensive and supported with good documentation.

F. Contractors have procedures specifically for the control of measuring i and test equipment, except the structural contractor. However, the

! structural contractor does have provisions in various activity procedures (i.e., Batch Plant, Expansion Anchor Work) for calibration control. A " Reminder Schedule" is posted in the QA/QC office for tracking calibration frequencies. Other contractors have calibration frequencies stated in a procedure dedicated to the Control of Measuring and Test Equipment.

$. Calibrations performed on site are performed in accordance with written procedures. Some equipment is sent off site for calibration. All calibration records / certifications identify standards used which are traceable to a recognized standard. Calibration records were maintained in an orderly fashion, legible and easily retrieved.

. . m;Q

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON Terformance Area Industrial Safety Obj e ctive No . PS.1 Evaluntor(s) B. Anderson -

Parformance Objective The construction site industrial safety program should achieve a high degree of personnel safety.

Scope of Evaluation Thn evaluation of this area involved the review of documents describing safoty procedures, fire protection policies, first aid log, crane inspections, and safety tagging procedures. Interviews were conducted with personnel concerned with safety, fire protection, and rigging and lifting. Walkthroughs were conducted with personnel with regard .to fire protection, safety, cutting and welding and the observation of a fire drill. Approximately 30 manhours were expended in walkthroughs, observing cnd interviewing personnel.

1 Conclusion The majority of activities evaluated under this performance objective were generally satisfactory; hoaever, there were some weaknesses identified that need attention.

0Q/09tbQ

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON forformance Iree Industrial Safety Objective No. PS.1 Ivaluator(s) B. Anderson Arnas of weakness and corrective action; Good Practices Finding)

(PS.1-1 The following good practice was noted. The contractor safety personnel mnet daily to correct safety problems at the early stages.

Finding)

(PS.1-2 ,

Thn Fire Protection Program and its implementation need to be improved.

Numnrous examples were noted that reflected procedural deficiencies and lack of complete awareness of the program.

Corrective Action The PCD-Administrative Assistant will review the fire protection program and its implementing elements using the examples provided as a basis to determine action and activities to be taken to enhance implementation. The review will be completed and documented by December 17, 1982; the specific corrective actions will be enacted by February 1,1983.-

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,6Q/0066Q/Page 2

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON Parformance Area Industrial Safety Obj ective No . PS.1 Evaluator (s)

B. Anderson

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Arnas of weakness and corrective action; Good Practices Finding)

(PS.1-3 The effectiveness of the Industrial Safety Program needs to be improved. A number of areas were noted where personnel did not adhere to established work procedures, especially involving eye protection, manual lifting and tripping problems, gas bottle storage, etc.

Utilizing trending of accidents, injuries and fire reports would also serve as a means to enhance-the program.

Corrective Action

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Trending is presently being performed on a minor scale by various contractors. Through the data base maintained by the Claims Department

- Workman's Compensation Program, a comprehensive' project trending of frequency, severity rate, and incident rate of accidents and injuries will be performed. This activity will be directed by the PCD-Administrative Assistant, and will be in implementation by February 1983.

The importance of adhering to safety procedures will be re-emphasized to contractor craft labor supervisors, and the safety personnel of the various contractors will be directed to increase the severity of their disciplinary actions when policing established lack of adherence to established procedures. This directive will be issued by November 29, 1982.

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6Q/0966Q/Page 3

PERFORMANCE EVALUATION DETAILS Construction Project BYRON Performance Area , Industrial Safety Objective No. PS.1 (Title) l Provide factual information that supports the Ferformance Evaluation Summary

' In the evaluation. of this area the following activities and items were noted:

1. A review of the Safety Tagging Program did not identify any weaknesses. Approximately four hours were devoted to walkthrough and interviews with four safety personnel concerning activities and policie's of tagging equipment for personnel and equipment safety.

Walkthroughs covered the auxiliary, containment, and turbine buildings.

2. The installation of various welding and cutting operations was observed. During this observation adequate fire protection was supplied; the area was cleaned of combustibles. Although the welders wore protective clothing, some helpers and craftsmen were working with the welders without protective clothing, eye protection, and hand protection in various areas , i.e. , 401 -Aux. , 426 '-Aux. and Turbine, 451'-Aux, and 364' containment 1.

l3. Discussions with Field Engineers focused on:

A. Hazardous Material, Purchasing, and Storage B. Crane Inspections (Electrical) l The Field Engineer displayed sufficient knowledge in this area to conform to procedurcl requirements.

4. Interviews' of Crane operators and safety personnel focused on:

l A. Lifting and Rigging B. Crane Inspections (Mechanical)

Operators and safety personnel stated that the Union provides qualified people in this area. Inspections and testing are done in accordance with procedures . The apprentice program'was reviewed and was found to be clear and the personnel knowledgeable.

6Q/0966Q/Page 4

PERFORMANCE EVALUATION DETAILS Conscruction Project BYRON Performance Area Industrial Safety Objective No. PS.1 (Title)

Provide Summary factual information that supports the Performance Evaluation 5.

A review of the first aid and safety records and procedures with the first aid and safety personnel was conducted. Highlights of the interview and discussion were as follows:

A. The First Aid personnel displayed very good awareness of the required activities.

B. It was apparent that all Contractor Safety personnel had a good working relationship with Safety personnel.

C.

The Safety with Construction Managers had a good working relationship personnel.

D. In review of accident reports, it was apparent that there '

was a large amount of eye injuries and back injuries. In the civil, structural contractors organization, the total number of injuries reported for six months of 1982 was 1519 of which over 30% (570) were eye injuries. Do ctors care was required in 208 of the 570 cases.

In review of the injury log, 50% of all injuries were related to eyes and the 30% of all injuries are related to back injuries. No trending or action has been taken in this area.

Month of October 193 injuries total; 112 eye, 51 doctor, 30 back injuries.

During a walkthrough and review of the fire protection and safety program, the Contractor's Safety Personnel described the effectiveness of the Safety Program. It was apparent that it met the minimum requirements and that it was effective in the safety area. Hoaever, several weaknesses were noted:

i A. Some Contractor persdnnel stated that they wera unaware of what the fire alarn' siren sounded like.

(TSC 401, 401 Turbine, in trailers)

B. In some areas of the plant the fire alarm siren is incapable of being heard due to location of sirens and operation of equipment.

(401-TSC, 451 Aux. Bldg . )

/09c6Q/Page 5

PERFORMANCE EVALUATION DETAILS Construction Project BYRON Performance Area Industrial Safety Objective No. PS.1 (Title)

Provide summary factual information that supports the Performance Evaluation C.

, Some areas were not equipped with adequate fire protection equipment.

(Welding areas, scaffold on polar crane, 451' aux. welding with no supply valve) hose reel in U-1 upper cable spreading room without a extinguisher, D.

Some confined space areas are not properly posted and procedures are not well defined.

only, Basement of containment 1 and 2)(Posted for Mechanical Contractor E. A safety tailgate =eetin personnel attend weekly.g was observed Safety material which wascraft distributed.

F. '

, Fire in theBrigade basics.Members stated that they only receive training G.

Several and ladders rungs cracked.were observed in which wood beams were split (401' & 426' Turbine L-20 column, 451' Turbine)

H.

Severalprotective proper craftsmenclothing were cutting, and eyegrinding and welding without protection. (401 -Radwaste 401'-Turbine L-20; 401'-Turbine L-20, 401'-Turbine Trsckway) ,

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Some welding cables were located on the floor in aisles -

Hatchway 383 to U-l Containment; 426' L-20 Turbine; 451' L-20 Turbine;

' containment-l&2.

J.

Some chained, gasand bottles were found improperly without safety caps and bottles not stored. (401 ' -Radwas te containment; Warehouse 4, 451 ' aux. , 426 ' aux. ) ; 364 ' U1 K.-

It was stated buildings by craftsmen is poor at times U-lthat air quality in containment Containment.

096tQ/Page 6

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD 1

Performance Area Industrial Safety Obj ective No . PS.1 Evalua tor (s)

B. Anderson Parformance Obj ective The construction site industrial safety program should achieve a high degree of personnel safety.

Scope of Evalua tion The evalua tion of this area involved the review of documents describing safety procedures, fire protection policies, first aid log, crane inspections, and safety tagging procedures. Interviews were conducted with personnel concerned with safety, fire protection, and rigging and lifting. Walkthroughs were conducted with personnel with regard to fire protection, safety, cutting and welding and the observation of a fire drill. Approximately, 30 manhours were expended in walkthroughs and observing and interviewing personnel.

Conclusion Tae r ajority of cctivitie s evclui ted under this perfor=ance objective were generally satisfactory. liovever, there were weaknesses identified that need attention.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD Performance Area Industria'l Safety Objective No. PS.1 Evalua tor (s) B. Anderson Areas of weakness and corrective action; Good Practices Finding)

(PS.1-1 The following good practice was noted; the accident followup activity by the Site Safety Supervisor points out repetitive accident cases to the respective contractor foreman for corrective action.

Fidding)

(PS.1-2 Fire Protection Program awareness and general housekeeping need to be improved.

Corrective Action PCD will review the fire protection program and its implementing elements using the examples provided as a basis to determine action and activities to be taken to enhance implementation. The reviaw will be completed and documented by December 17, 1982; the specific corrective actions will be enacted by February 1, 1983 Finding)

(PS.1-2 Implementation of the Industrial Safety Progrem related to storage of hazardous materials, crane signaling, etc., needs to be improved.

orrective Action Trending is presently being performed on a minor scale by various contractors. Through the data' base maintained by the Claims Department -

Workman's Compensation Program, a comprehensive project trending of frequency, severity rate, and incident rate of accidents and injuries will be performed. This activity will be directed by PCD and will be in imp 1trentation by February 1983.

6Q/lO27Q/Page 2

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PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD Performance Area Industrial Safety Obj e ctive No . PS.1 Evalua tor (s) B. Anderson Arecs of weakness and corrective action; Good Practices Finding)

(PS.1-2 Corrective Action (Continued)

The importance of adhering to safety procedures will be re-emphasized to contractor craft labor supervisors, and the safety personnel of the various" contractors will be directed to increase the severity of their disciplinary actions when policing established lack of adherence to established procedures. This directive will be issued by November 29, 1982.

SQ /102 7Q/Page 3

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Performance Area Industrial Safety Obj ective No . PS.1 (Title)

Provide factual information that supports the Performance Evaluation Summary

1. An interview and observation of Crane Operations, Inspections, and Crane Associated Equipment was conducted. Operators and safety personnel stated that the Union provides qualified people in this area. Inspections and testing are being done in accordance with procedures. The equipment was observed in working order. The mechanics were observed replacing a cable due to a small fray in the cable in a proper manner. Also, at this time preventative maintenance was being performed. The Operators stated (and this was also witnessed) that the craftsmen in charge of a lift do not give proper lifting signals to the operator.

2. In a review of Hazardous Material Storage the following items were noted:

A. Some warehouse material was stored improperly:

Electrical Contractor's Warehouse - Flammable liquids on shelf.

Edison Warehouse - Flammable liquids near heater, empty boxes stored in aisles of warehouses.

Flammable liquids such as thinner, mineral spirits, etc. were stored improperly in the warehouses and in several locations within the plant.

B. Several gas bottles were stored improperly:

Warehouse - storage of bottles without caps and chains.

Containment - Bottles stored without safety caps and on their side (able to roll).

C. Some flammable liquids improperly stored during use:

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In the control room paint thinner in open plastic 5 gallon can next to a grinding operation.

Flammable liquids stored in open 1 gallon paint cans in U-1 containuent basement.

iQ/1027(/Page 4

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PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Performance Area Industrial Safety Obj ective No . PS.1 (Title)  !

Provide factual information that supports the Performance Evalua tion Summary

3. The installation of welding and cutting operations were observed.

Althou vests)gh welders some wore helpers and proper protective craftsmen workingclothing (shields, in the area gloves, are without proper eye protection.

Elev. 451-T. E18 Welding Steam Line, five helpers without eye protection.

Elev. 451-T Heater Bay - Welding with helper holding material with no eye protection.

Elev. 426-T Grinding without proper eye and face protection.

Elev. 426 U-1 Containment - Grinding and cutting on a 30'. scaffold with no fire protection in the area.

Elev. 426 U-1 Containment - Cutting torch sparks falling on lunch table and coats below.

Elev. 401 U-1 Containment - Grinding on stairwell with no shield for people passing by.

Elev. 451 Control Room - Grinding with no eye protection and open can of paint thinner next to the grinding operation.

The cleanliness of some areas where welding cutting and grinding were being performed was poor.

6. A review of the first aid and safety records and procedures with the first aid and safety personnel was conducted. Highlights of the interview and discussion were as follows:

A. The first aid personnel displayed very good awareness of the required activich s.

B. It was apparent that the contractor and CECO safety personnel had a good working relationship.

C. Construction Managers have a good working relationship with safety personnel.

iQ'in27Q/Page 5

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Performance Area Industrial Safety Obj e ctive No . PS.1 (Title)

Provide factual informatio'n that supports the Performance Evalua tion Summary D. In review of the accident reports the trends on injurie s has follow-up action by the safety personnel in repetitive accidents.

E. Eye injuries on the average are the main injury area. An average of 35% per month are related to eye injuries approximately 50 per month in which 1/2 require doctor's care. October 1982: 165 total injuries, 60 eye injuries and 28 to the doctor.

5 During a walkthrough and review of the Fire Protection and Safety Program, the contractor's safety personnel described the effectiveness of the Safety and Fire Protection program. It was apparent that the program met the minimum requirements. However , several items were noted:

A. Some contractor personnel stated that they were unaware of what the fire alarm sounded like or what they should do in the event of a fire.

B. Some confined space areas are not properly posted and some contractors were unaware of any precautions (Containment Unit 1 and 2).

C. Flammable and combustible liquids are not being stored properly in the electrical contractor's warehouse:

30 one gallon cans of flammable thinner stored next to combustible paper structure.

1 box of flammable electrical material on shelf next to cardboard boxes and with cigarette butts on the floor nearby.

D. A safety tailgate meeting was observed in which craft personnel attend weekly which safety material is reviewed. (401 radwaste -

civil-structural contractor safety meeting minutes).

E. Some gas bottles were found without safety caps , not chained and improperly stored:

Edison Warehouse Electrical Contractor's Warehouse U-1 L U-2 364 Containment 401 - Turbine trackalleys.

426 - Aux. near U-l Cable Spreading Room iQ/1027Q/Page 6

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I PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Performance Area Industrial Safety Objective No. PS.1 (Title)

Provide Summary factual information that supports the Perfo mance Evaluation L.

Several areas were noted where yellow striping on floor near equipment: was missing or the area was being used to store switchgear The Switchgear Room in the Auxiliary Building has construction material equipmentinfrom the striped area making it unable to operate or remove these areas.

e i

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON .

Performance Area Project Planning & Project Control Objective No. PS.2&3 Evaluator (s) A. Kleinrath, J. Woods, N. Main, R. Ferguson ___

l Parformance Objective l

PS.2

-- Froject plans should ensure completion of the project to the highest industry standards by identifying, interrelating and sequencing the tasks of the project organizations.

?S.3

-- Froject scheduling and work planning and coordination should ensure that the objectives of the project plan are met through effective and efficient us'e of project resources.

Scope of Evaluation .

I The evaluation of these areas involved approximately 160 manhours at the i

General Office, and the Byron and Braidwood sites observing work going on and comparing various schedules at Byron and Braidwood. Interviews were held at various levels in the organization including Chairman, Vice Chairman, Manager of Projects, Assistant Manager of Projects / Byron Project Manager, and Manager of Quality Assurance down through the lead engineers involved in construction engineering and quality assurance. Contractor Superintendents were also included.

Conclusion All areas reviewed were generally satisfactory; however, the scheduling l activities on the projects are somewhat fragmented and not well understood

~

( by all of the people interviewed.

1Q/0968Q

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON

'orformance Area Project Planning & Project Control Obj e ctive No . PS . 2&3 Waluator(s) A. Kleinrath, J. Woods , N. Main , R. Ferguson Arcas of weakness and corrective action; Good Practices ,

Finding (PS.2 & 3-1)

The effectiveness of the Byron and Braidwood project scheduling system needs to be reviewed. Specifically, the various contractors do not have a composite schedule to work from.

Corrective Action The Manager of Projects will meet with the Project Managers together and separately to review present schedules and re-identify their needs and develop improvements by December 10, 1982. Engineering 's involvement, the report distribution and trending analysis will be reviewed as to their needs and benefits. A detailed plan will then be developed to imp ~ rove the effectiveness of the projects scheduling.

iQ/0965Q/Page 2

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PERFORMANCE EVALUATION DETAILS Construction Project BYRON Parformance Area Project Planning & Project Control Objective No. PS.2&3 (Ticle)

Provide factual information that supports the Performance Evaluation Summary In evaluating these performance objectives the following items were noted:

1. The Chairman, Vice-Chairman, Manager of Projects , Assistant Manager of Projects, project Engineering Manager, Manager of Quality Assurance were interviewed. All are familiar with schedule, and budgets. Project Engineering was not aware of schedule revisions to the Byron Project.

2. System for schedule .and budget information appears to be updated on a regular basis.

3. A master schedule was not immediately available for the Byron project , however, it was made available at a later date.

4. Project Engineering does not contribute scheduling information for the project.

5. Clear lines of authority do not exist for input to the schedule.

6. Trending, other than for bulk quantity measurements, to determine quality or cost improvements is not performed by the project.

7. There isn't uniformity in the method of reporting the quantity of material installed or system completion status.

8. A master schedule was not available at any level within PCD or the contractor's organization.

9. Items partially completed are given credit for completed item (i.e. , PSEN valve body installed and credit was given for complete installation; however, electrical cannot complete work because of missing top works.

10. Daily systems status meetings are held between operating and construction tc expedite system completion.

Q/0968Q/Page 3 n

PERFORMANCE EVALUATION DETAILS Construction Project BYRON Performance Area Project Planning & Project Control Objective No. PS.2&3 (Title)

Provida factual information that supports the Performance Evaluation Summary

11. Meetings are regularly held with responsible contractors to detemine the status of systems and identify problems that could affect. system completion.

12. The piping contractor does not have a schedule for systems in U-2.

13. The SYFA Computer system is well utilized.

'Q/0966Q/Page 4

, PERFORMANCE EVALUATION

SUMMARY

Construction Project

. BRAIDWOOD Performance Area Project Planning & Project Control Objective No. PS.2&3 Evaluator (s) A. Kleinrath, J. Woods, N. Main, R. Ferguson Performance Objective PS.2 Project plans should ensure completion of the project to the highest industry standards by identifying, interrelating and sequencing the tasks of the project organizations.

PS.3 Project scheduling and work planning and coordination should ensure that the objectives of the project plan are met through effective and efficient use of project resources.

Scope of Evaluation The evaluation of these areas involved approximately 160 manhours at the General Office, and the Byron & Braidwood sites observing work going on and comparing various schedules at Byron and Braidwood. Interviews were i

held at various levels in the organization including Chairman, Vice Chairman, Manager of Projects, Assistant Manager of Projects / Byron Project Manager, and Manager of Quality Assurance down through the lead engineers involved in construction engineering and Quality Assurance. Contractor superintendents were also included.

1 Conclusion All areas reviewed were generally satisfactory; however, the scheduling activities on the projects are somewhat fragmented and not well understood by all of the people interviewed.

1 9

4

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD Parformance Area Project Planning & Project Control Obj e ctive No . PS.2&3 Evaluator (s) A. Kleinrath, J. Woods, N. Main, R. Ferguson . . . _

Areas of weakness and corrective action; Good Practices Refer to Byron finding PS.2&3-1.

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, PERFORMANCE EVALUATION DETAILS Construction Project

, BRAIDWOOD Parformance Area Project Planning & Project Control Objective No. PS.2&3 (Title)

Provide factual information that supports the Performance Evaluation Summary In evaluating these performance objectives the following items were noted:

1. The Chairman , Vice Chairman , Manager of Projects , Assistant Manager of Projects, Project Engineering Manager, Manager of Quality Assurance were interviewed. All are familiar with schedule, budgets.

2. System for schedule and budget information appears to be updated on a regular basis.

3. A master schedule was not available for the or Braidwood projects.

4. Project Engineering does not contribute scheduling information for the project.

5. Clear lines of authority do not exist for input to the schedule.

6. Trending, other than for bulk quantity measurements , to determine quality or cost improvements is not performed by the project.

7. There isn't any uniformity on the method of reporting the quantity of material installed or system completion status.

8. The SYFA computer system is not being utilized to the came extent as on the Byron Project.

l l 9. The status of construction is being measured on an area and bulk

[ quantities basis. A percent of system completion was not available.

10. CECO PCD, and the Project Operating Department are not using a common schedule.

l l 11. Contractors are not responsible for supplying information to PCD on l the required time or manpower to complete systems.

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PERFOR}iANCE EVALUATION DETAILS Construction Project BRAIDWOOD Parformance Area Project Planning-L. Project Control (Title) Objective No. PS.2&3 f

Provide factual information that supports the Performance Evaluation Summary 11.

Contractors are not responsible for supplying information to PCD on the~ required time or manpower to complete systems.

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a PERFORMANCE EVALUATION SUMIARY Construction Project BYRON Performance Area. Project Procurecent Process Obj ec tive No . PS-4 Evaluator (s) H. P. Studtmann --

Performance Objective The project procurement process should ensure that equipment, materials, and services furnished by suppliers or contractors meet project requirements.

Scop of Evaluation This evaluation was performed by reviewing documents, personnel interviews and walkthrough of the procurement process . Four manhours were expended in this evaluation area.

Conclusion The Project Procurement Process evaluated under this performance objective was found acceptable.

0/0970Q

PERFOPMCE EVALUATION

SUMMARY

Construction Project BYRON P;rformance Area Project Procurement Process Objective No. PS.4 Evaluator (s) H. Studtmann Areas of weal: ness and corrective action; Good Practices No findings were noted in the Project Procurement Process Performance Area.

e 10/Li ( / PE- { G 4.

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PERFORMANCE EVALUATIO.N DETAILS Construction Project BYRON, Performance Area Project Procurement Process Objective No. PS.4 (Title)

Provide factual information that supports the Performance Evaluation' Summary

1. Project Procurement Process was evaluated by~ reviewing documents, personnel interviews and observance of the work procurement cycle.

4 2. Reviewed the site Procurement Procedure.

3. Followed a procurement request through the procurement cycle.

. A. Contractor initiates request. Contractor QA-reviews for requestor.

B. Lead Project Engineer - Electrical, Mechanical, or Structural reviews request for their specific areas of construction.

Required information for requesting material is verified by reviewing piping designs, specification, etc. Designation as to Code-ASME-Safety Related-Reliability or Non-Safety is checked. If all above is correct the request is sent to the CECO Buyer on site.

C.- Buyer uses an Approved Bidder's List for approved vendors where required.

D. Bids are requested when above $1,000.00 in value. Other procurements above the $1,000.00, i.e. , major equipment are handled through the GO-Company office.

E. Letters reviewed did verify the process is being used. Three bids are required. Five usually were attached to copy of P.O.

F. Site Quality Assurance reviews request for Purchase of all items and, if acceptable, approves. The Buyer then issues the Purchase Order.

4. . Interviews were conducted with the following personnel:

A. S'ite Senior Buyer UcIl experienced - approx. 10 yrs. in Purchasing. las had training in Quality Assurance Program - very knowledgeable in Procurement Procedures; changes made to P.O.; require original reviews.

3Q/0970Q/Page 3

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

PERFORMANCE EVALUATION DETAILS Construction Project BYRON Performance Area . Project Procurement Process Objective No. PS.4 (Title)

Provide factual information that supports the Performance Evaluation-Summary

4. B. Project Lead Engineer-Mechanical Knows his job well as to procurement requirements; uses Spec-Piping Design. Any changes to Designs-contacts Engineer and A-E.

C. Assistant Project Superintendent Very capable and knows and understands the procurement system.

5. Reviewed G.O. Quality Assurance Audit that noted procurement documents were not clear and did not contain accurate information for the vendor / contractor. Corrective action was completed and attachments to P.O. are required by QA. Purchase Orders reviewed contain these documents. .

6. Procurement from the site is usually for minor materials / services. All major procurements were completed through the General Office and Engineering Department.

4 EQ/0T/0Q/Page 4

k PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD forformanceArea Project Procurement Process Obj e ctive No . PS.4 Evaluator (s) H. Studtmann .

Parformance Objective The project procurement process should ensure that equipment, materials, cnd services furnished by suppliers or contractors meet project requirements.

l Scope of Evaluation This evaluation was performed by reviewing documents, personnel interviews end a walkthrough of the generating station. Approximately, 20 manhours wara expended in this area. ,

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l l Conclusion

! The majority of the activities in the project procurement process evaluated under the performance objective were generally satisfactory.

How ever , a system weakness was identified and indicate a need to l

strengthen certain areas in the procurecent process.

i jbQ/iO17Q l

PERFOPJfANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD Parformance Area Project Procurement Process Obj ective No. PS.4 Evaluator (s) H. Studtmann Areas of weakness and cor'rective action; Good Practices Finding)

(PS.4-1 Incorrect use of, and improper procurement of, cable grips.

Corrnctive Action En summary, we acknowledge the use of unapproved cable grips. Project

onstruction Department did identify the concern prior to the INPO avaluation. Therefore, Project Construction Department feels this is an Lsolcted instance where the systen of on-site purchase of material failed.

As corrective action to prevent recurrence, Project Construction Department, 2A and Purchasing will be instructed in the correct procedure of on-site

>u_ chasing review. This will be completed by December 17, 1982. ,

ly/10l?Q/Page 2

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Project Procurement Process Objective No. PS.4 Parformance Area (Title)

Provide factual information that supports the Performance Evaluation Summary

1. The project procurement process was evaluated by reviewing documents, personnel interviews and a walk through the construction area.

certain types of cable grips were

2. During the walkthrough of the plant,The types were noted and a review of the desi observed installed.

specification found certain types of cable grips that were installed were not approved for use in all areas of the plant.

3.

• The procurement doucments were reviewed and it was found that the original materials request only listed the approved cable grips for use on safety related systems.

4. A note in the specification delineated that other manufacturer At this time, cable a

grips that are equal to those listed may be used.

second type of Manufactured Cable Grips were added to the purchase

! document.

The

5. The lead Project Engineer approved the request the purchase.

Engineer stated he did not review the specification.

6. The Procurement for review Document and approval . was sent to the Quality Assurance Depa by QA.

7. Materials were bought, received and installed.

8. There isn't a cross matrix identifying the other manufacturer's approved types of cable grips Manufacturer's

, or approval from the AEdo catalogs fornot those list listed in the procurement document. Seismic and environmental equals to other manufacturer3 cable grips. qualifications are requ plant.

9. Several weeks prior to this INPO evaluation, the Project Construction Department Engineer following the installation of cable grips The stated ha had written a nonconformance report on this deficiency.

nonconformance report as of this date 11/5/82 did not have The an Project identification number, nor was it logged in the NCR log.

Engineer state l that he had contacted The the AE's Engineer on stated who this problem that heandhad was put waiting for their resolution.

46Q/1017Q/Page 3

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Performance Area Project Procuremen't Process Obj e ctive No . PS.4 (Title)

Provide factual information that supports the Performance Evaluation Summary

9. (Continued) a hold on the installation cable grips, and that the contractor was to count all the unused cable grips stored in the Turbine Building, so PCD would have an rough figure as to how many cable grips were installed.

An observation of the storage area revealed the only control of these cable grips was handwritten notices stating not to use a certain type of cable grip.

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9 PERFORMANCE EVALUATION SIRRfARY Construction Project BYRON Parformance Area Contract Administration Objective No. PS-5 Evaluator (s) R. Vertovec Performance Objective Methods for administering and controlling contractors and suppliers and for managing changes to their contracts should ensure effective control of parformance .

Scope of Evaluation The evaluation of contract aaministration involved approximately 35 manhours of preparation, reviews, interviews, write-ups and analyses.

Interviews were conducted with four Field Construction Engineers, two Office Managers , the Project Engineering manager, a Project Engineer and two Contractors Superintendents. A review was made of the utility and contractor procedures, change control records and cost estimates.

Conclusion The activities reviewed under this objective were 4atisfactory and, in general, fulfilled the established criteria and the requirements of the Utilities General Procedure #712 and no findings resulted.

Q/0971Q l

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON Performance-Area Contract Administration Objective No. PS.5 Evaluator (s) R. Vertovec_

~

Areas of weakness and corrective action; Good Practices No findings identified.

O O

Q/09/UQ f

5 PERFORMANCE EVALUATION DETAILS Construction Project BYRON P rformance Area Contract Administration Objective No. PS.5 (Title)

Provido factual information that supports the Performance Evaluation' Summ ry

1. The Lead Electrical Engineer stated that the Project Engineer handles all Codtract Administration.

2. Tracked change to lump sum contractor contract; found very detailed cost estimate made by a full-time estimator. Estimate $1,200; DDR listed cost as below $10,000. Final settlement $1,106.00.

3. Approval levels of change and DDR were in order.

6. Field Engineers check of contractor proposal check the total dollars and not quantities.

3.- At present verbal orders, telephone memo and speed letters are not being used. .

@. The Field has and utilizes the DDR Aging Report #620 from the Project Management System.

7. PCD har held up payment to ensure contractor performance to changed procedure.

8. In periods of extensive backlog of changes, they have gone to overtime to catch up.

. PCD keeps a very complete and detailed status and cost control log book.

10. Schedule impact review of changes is made by PCD - discussed with PED and A/E.

Ll. Field Design Changes go to A/E by FCR Procedure in accordance to QA Program Section 3.2.

L2. All design changes receive the same review as the original design.

l L3. Changes receive the same quality review as original design.

.4. All contract changes follow a General Company Procedure (GPI-712)

P

-Q/0971Q

PERFORMANCE EVALUATION DETAILS Construction Project BYRON

'erformance Area Contract Administration Obj ective No . PS.5 (Title)

~

'rovide factual information that supports the Performance Evaluation

,ummary

5. GPI-712 and GPI-141 identify the approvals required prior to release of DDR's by A/E.

6. GPI-712 requires a category estimate only.

7. GPI-712 allows release of DDR's under $50,000.

8. . Economic justification and evaluation of various options are made in some special cases.

9. PED meets frequently to resolve problems with A/E.

O. PED holds periodic status meetings with A/E.

1. PED controls A/E by adjusting amount of work they assign to them.

2. PED has A/E make estimates for changes to equipment-only Purchase Orders.

3. Some contractors tracked changes on their computer.

S. Status of changes is tracked by the Company Computer PIC System.

5. PCD proceeds without a signed DDR from PED.

Q/0971Q

. _ . . . _ _ _ _ _ _ _ _ _ _ _ J

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD Parformance Area Contract Administration Obj e ctive No . PS.5 Evaluator (s) R. Vertovec _

Parformance Objective Mathods for administering and controlling contractors and suppliers and for managing changes to their contracts should ensure effective control of parformance.

1 Scop 0 of Evaluation The evaluation of Contract Administration involved approximately ~35 l manhours of preparation, reviews, interviews , write-ups and analysis.

Interviews were conducted with four Field Construction Engineers, two Office Managers, the Project Engineering Manager, a Project Engineer and two contractor's Superintendents. A review was made of the Utility and Contractor Procedures, Change Control Records and cost estimates.

l Conclusion The activities reviewed under this objective were satisfactory and, in general, fulfilled the established criteria and the requirements of the Utilities General Procedure //712 and no findings resulted.

bruivQ

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWObD Terformance Area Contract Administration Obj e ctive No . PS.5 l

Evaluator (s) R. Vertovec ~

I Areas of weakness and corrective action; Good Practices No findings identified.

(See details) 9 e

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'AU19Q

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Parformance Area Contract Administration Obj e ctive No . PS.5 (Title)

Provide Summzry factual information that supports the Performance Evaluation

1. Approval levels of change and DDR were in order.

2. At present being used.verbal orders, telephone memo and speed letters are not

3. The field has and utilizes the DDR Aging Report #620 from the Project Management System.

4. PCD has held up payment to ensure contractor performance to changed procedures.

$. In periods of extensive backlog of changes, they have gone to overtime to catch up.

6. Schedule impact review of changes is made by PCD - discussed with PED l

end AE.

Field Design Changes go to AE by FCR procedure in accordance to QA Program Section 3.2.

All design changes receive the same review as the original design.

Changes receive the same quality review as original design.

,0 .

All contract changes follow a General Company Procedure (GPI 712).

1. GPI 712 and GPI 141 identifies the approvals required prior to release of DDR's by AE.

8. GPI 712 requires a category estimate only.

2. GPI 712 allows release of DDR's under $50,000.

f. Economic justification and evaluation of various options are made in some special cases.

5. PED meets frequently to resolve problems with AE.

5. PED controls AE by adjust'ing amount of work they assign to them.

7. PED has AE cake esticates for changes to equipment only purchase orders.

p r.'190

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Performance Area Contract Administration Objective No. PS.5 (Title)

Provide factual informatio'n that supports the Performance Evaluation-Summary 18 .. Some contractors (Mechanical Contractor) tracked changes on their computer.

19. Braidwood did not receive copies of Mechanical DDR's as per GP 712.

20. Braidwood has made evaluation of various options of purchased or field fabrication of pipe.

21. ' Braidwood does not have full time estimator. They use the Field Construction Engineers to prepare the required estimates and they do not have formal training as estimators.

22. Status of changes is tracked by the Company Computer PIC System.

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,13 . PCD proceeds without a signed DDR from PED.

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON Parformance Area Documentation Management Obj ective No . PS.6 Cyclustor(s) E. ' Martin 1 -

Parformance Obj ective Tha management of project documentation should support the effective control and coordination of project activities and provide a strong foundation for the documentation /information requirements of the plant's operational-phase.

Scopa of Evaluation Tha evaluation of this area involved interviews with the Site Electrical Contractor's Document Control Management and Field personnel. -

Approximately ten manhours were expended in observing control of the Electrical Contractor's Project Documentation. Approximately four manhours were devoted to discussions with various levels of supervision and field personnel. Document control receipt and distribution was observed in the field.

Conclusion Tha overall activity evaluated under this performance objective was satisfactory.

(/09 2Q

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON Parformance Area Documentation Management Objective No. PS.6

[ valuator (s) E. Martin Areas of weakness and corrective action; Good Practices No findings identified.

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PERFORMANCE EVALUATION DETAILS Construction Project BYRON Performance Area Documentation Management Objective.No. PS.6 (Title)

Provide factual information that supports the Performance Evaluation ~

Summary Thn Site Electrical Contractor was observed for the purpose of evaluating thair control and coordination of project documents. Interviews were conducted with supervision and management and field personnel. The highlights of _ the interviews were:

1. The Document Control Clerk displayed a very good knowledge of her required work. practices. Additionally, she periodically reviews the status of the drawing index with the Architect Engineer drawing status report to assure that drawings are current. This review is conducted in addition to the Quality Control Monthly Surveillance of Drawing and indicates a good individual effort.

2. The Mas'ter File Index lists all quality related documents to be retained. .

3 The storage area was found to be neat, organized and controlled for access.

4. The Document Distribution Clerk was accompanied on a walk through the proj ec t . Highlights of the discussion and project inspection were:

a. The clerk exhibited a good knowledge of the design change identification system.

b. Drawings are segregated after change out.

c. Document distribution routines have been established.

3. Specifications, procedures and standards appeared to be current and controlled.

p. Document control personnel received training on the latest D.C.

procedures.

Qf0972Q l

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD

>arformance Area Documentation Management Obj e ctive No . PS.6 haluntor(s) E. Martin . . _ _

Parformance Objective Tha management of project documentation should support the effective control and coordination of project activities and provide a strong foundation for the documentation /information requirements of the plant's operational phase.

Scope of Evaluation

~

Tho evaluation of this area involved interviews with the Site Electrical Contractor's Document Control management and field personnel .

Approximately,12 manhours were expended in observing control of the Electrical Contractor's project documentation. Approximately, 6 manhours were devoted to discussions with various levels of supervision and field personnel. Document control, receipt and distribution was observed in the field.

Conclusion The overall activity evaluated under this performance objective was found to be adequate.

>Q/1G1T4

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD

) rformance Area Documentation Management Obj e ctive No . PS.6 Cvaluator(s) E. Martin l

1 Arcas of weakness and coriective action; Good Practices No findings identified. (See details) l

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PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Performance Area Documentation Management Objective No. PS.6 (Title)

Provide factual informatio'n that supports the Performance ,; valuation-Summary The site Electrical Contractor was observed Jor the purpose of evaluating their controls and coordination of project documents, i .e . , drawings ,

procedures, specifications, standards and. design changes. Interviews were conducted with supervision, management and field personnel. The highlights of the interviews were:

1. The Document Control Supervisor displayed a good knowledge of the

, socument control system and the responsibilities of the individuals on her staff. Her input into resolution of document control deficiencies appeared extensive.

2. The document distribution system was orderly and current. However, the return of obsolete drawings appears to need additional control. This concern was identified on a corporate audit. conducted by the ,

contractor's Quality Assurance Department and corrective action is presently underway. -

3. The master drawing card file system does not require a review of the site construction drawings with the Architect Engineer's current drawing status list. During this assessment no obsolete drawings were observed as being used for construction.

6. The Quality Control Records List is being used as the Master Index List.

5. The storage area was found to be neat, organized and controlled for access.

1. Document control personnel do not receive formal training in the applicable procedures. Most training in the document control area is on the job type training.

F. The document distribution clerk was accompanied on a walk through the project. Highlights of the discussion and project inspection were:

A. Document distribution routings have been established.

B. The clerk exhibited a good knowledge of the Design Change Identifi cation System.

C. Drawings are segregated after change out.

6Q/102 Q l

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Parformance Area Documentation Management Obj e ctive No . PS.6 (Title)

Provide factual informatio'n that supports the Performance Evaluation-Summary

8. Procedures and drawings were examined in the field and found current and accessible.

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PERFORMANCE EVALUATION SUMMAPsY Construction Project BYRON Forformance Area Training Management Support Obj ective No . TN.1 Evaluator (s) E. Fitzpatrick/E. Wilmere -

Performance Objective Management should ensure that an effective program exists for indoctrination, training, and qualification of personnel involved in the proj ect .

Scope of Evaluation The evaluation of this area included discussions with supervision / management of five project / site organizations and five contractor organizations and a review of applicable procedurec and records. Approximately twelve manhours were devoted to this evaluation.

Con clusion The depth and approach of training programs for the project and contractor organizations vary widely from extensive to minimal which indicates that the project and contractor management have not taken formal steps to assess overall job related needs. Followup on the effectiveness of training of craft supervisors / foremen and subsequent dissemination of appropriate information to craf t personnel is weak. Mos t o f the instructors in all of the organizations are weak in instructional skills.

5Q/0982Q l

I

- j PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON Parformance rea Training Management Support Obj ective No . TN.1 Evaluator (s) E. Fitzpatrick, E. Wilmere Arecs of weakness and cor'rective action; Good Practices Finding)

(TN.1-1 Evidence was not available that CECO Project Management in three of the departments have documented the qualifications and training needs of the individuals with respect to their assigned tasks, or are obtaining /using feedback or trending information to improve the effectiveness of the training programs.

Mos't of the instructors in all of the organizations have not had training in instructional skills including the preparation of training objectives and lesson plans. This type of training would enhance training effectiveness.

Corrective Action .

Due to the condition that this finding relates to an issue of broad scope with complex details, the extent of this weakness will be examined in detail under the direction of the Assistant Manager of Projects. The results of this review will be determined by January 14, 1983. The implementation of the corrective actions established as a result of this review will begin by March 11, 1983.

Finding)

(TN.1-2 The structural, electrical and HVAC Sheet Metal Contractors' Training Programs for their craft supervisory personnel and foremen need improvement in that the programs need to be more completely defined, and a method needs to be established to assure that the appropriate information is completely and accurately disseminated to the craft personnel.

Most of the instructors in all of the organizations have not had training in instructional skills including the preparation of training objectives and lesson plans. This type of training would enhance training effectiveness.

iQ/0982Q/Page 2

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON Terformance Area Training Management Support Objective No. TN.1 Evcluator(s) E. Fitzpatrick, E. Wilmere Arcas of weakness and corrective action; Good Practices Corrective Action The PCD-Assistant Superintendent, in conjunction with the PCD-Quality Control Supervisor, the PCD-Structural Supervisor, the PCD-Electrical Supervisor, and the PCD-Mechanical Supervisor, will review the training programs and techniques employed by the structural contractor, electrical contractor, and HVAC contractor to determine what changes or additional activities are required to enhance training effectiveness. The review will be completed and documented by February 18, 1983; the specific corrective cctions will be enacted by April 15, 1983.

1

Q/0982Q/Page 3 1

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.w PERFORMANCE EVALUATION DETAILS Construction Project BYRON Performance Area Training Management Support Obj ective No . TN.1 (Title)

Provide factual information that supports the Performance Evaluation Summary

1. Discussions were held with Supervisors / Managers in Project Construction , Project Start-up Group , Project Operational Analysis ,

Site QA, Project Engineering, Mechanical Piping Contractor, Electrical Contractor, Structural Contractor, HVAC Sheet Metal Contractor, and Instrumentation Piping Contractor to evaluate management involvement and sup' port of training programs . Review of appropriate records were also conducted and weaknesses were noted in three of the Project Groups

, in that these groups have not documented overall training needs, have not provided training in a systematic manner to their personnel, do not have a method of collecting or utilizing feedback or trend information to improve the effectiveness of the training program. Three of the contractor groups had weaknesses in their programs for training craft supervision and foremen and in methods of disseminating to the crafts the changes to work activity requirements related to their tasks. All of the groups had weaknesses in instructors ' instructional skills.

. A. Discussions with the Assistant Construction Superintendent indicated that Project Construction does not have a structured training program. While there are many experienced people in the Department, it was, nevertheless stated by the Asst. Supt. that enhanced site specific training activities are needed. This is substantiated by several weaknesses observed by evaluation teal members in the conduct of surveillances.

Additionally, there isn't a structured indoctrination program for new personnel. There are attempts to place the new people with experienced people for familiarization. Some new PCD Mechanical personnel have attended parts of the Mechanical Piping Contractor's Training Program, but new PCD Electrical personnel have not attended any programs because of the recognized weaknesses in the Electrical Contractor's Program.

B. Discussions with the Project Engineering Manager and the Project Start-up Coordinator indicated that they do not have a formally structured training programs. Both indicated that such programs should be developed.

iQ/0982Q/Page 4

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PERFORMANCE EVALUATION DETAILS Construction Project BYRON Performance Area Training Management Support Obj ective No . TN.1 (Title)

~

Provide factual information that supports the Performance Evaluation Summary A need exists for Project Management in these groups to assess the qualifications and training needs of individuals with respect to their assigned tasks, in obtaining /using feedback information to improve the effectiveness of the training program, and in obtaining / reviewing training and qualification trends.

2. Discussions with the Electrical Contractor's site VP and Project Manager, the Structural Contractor's QA/QC Manager, and the HVAC Contractor's QA/QC Manager indicated that well defined training programs do not exist for their craft supervision and foremen, nor is there a formal method for disseminating appropriate job related information to craft personnel.

A. The Electrical Contractor only holds training sessions for craft supervision and foremen after problems arise. This is a reaction mode, training is more effective in an active mode based on those needs that can be identified as necessary to update knowledge of changes in work activity requirements related to the tasks to be accomplished.

B. The Structural Contractor takes a similar approach--training is based only on deficiencies as they'are identified despite the fact that Section 3.5 of the contractor s QA manual indicates a training program is required for all site personnel.

C. Discussions with the HVAC Contractor QA/QC Manager indicated a recognition of the need for a more fully defined and implemented training program. Enhanced training for craft supervision and foremen and a method of disseminating appropriate job related information to craft personnel need to be developed and implemented.

@. During discussions with all of the projects and contractor groups, it was noted that very few of the instructors involved in existing training programs have had training in instructional skills. Reviews of training materials revealed that outlines are used as lesson plans.

None of the outlines reviewed contain training objectives. Training in instructional skills would enhance the effectiveness of the training.

SQ/0982Q/Page 5

P PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD Training Management Support Objective No. TN-1 Tformance Area Glustor(s) E. Fitzpatrick, E. Wilmere _

Parformance Objective Management should ensure that an effective program exists for indoctrination, training, and qualification of personnel involved in the project.

Scopo of Evaluation The evaluation of this area included discussions with supervision / manage-m:nt of three project / site organizations and five contractor organizations end c review of applicable procedures and records. Project engineering was covered in the Byron portion of this evaluation. Approximately 18*

m:nhours were devoted to this objective.

Conclusion The depth and approach of training programs for the project and contractor organizations vary widely from extensive to minimal which indicates that the project and contractor management have not taken formal steps to assess overall j ob related needs . Follow-up on the effectiveness of training of craft supervisors / foremen and subsequent Most dissemination of the of appropriate information to craft personnel is weak. instructors in all of the 46Q/0965Q l

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PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD 3rformance Area Training Management Support Objective No. TN-1 valuator (s) E. Fitzpatrick, E. Wilmere Arnas of weakness and corr'ective action; Good Practices FINDING Evidence was not available that most of the project (TN.1-1) organizations have documented the training needs of individuals with respect to their assigned tasks, or in using feedback or trending information to improve the effectiveness of training programs.

Most of the instructors in all of the organizations have not had training in instructional skills, including the preparation of training objectives and lesson plans.

active Action:

Due to the condition that this finding relates to an

, issue of broad scope with complex details, the extent.

of this weakness will be examined in detail under the direction of the Assistant Manager of Projects. The results of this review will be determined by January 14, 1983. The corrective actions established as a result of this review will begin implementation by March 11, 1983.

FINDING The training programs of contractors with craft (TN.1-2) personnel need improvement in assessing the effectiveness of their craft supervisor and foremen training, and a method needs to be established to assure that the appropriate information is completely

. and accurately disseminated to the craft personnel.

Most of the instructors in all of the organizations have not had training in instructional skills, including the preparation of training objectives and lesson plans.-

ctive Action:

Due to the ' condition that' this finding relates to an issue of broad scope with complex details, the extent of this weakness will be examined in detail under the direction of tha Assistant Manager of Projects. The results of this review will be determined by January 14, 1983. The correct ve actions established as a result of this review will begin implementation by March 11, 1983.

460fo965Q/pg. 2

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PERFORMANCE EVALUATION DETAI S Construction Project BRAIDWOOD Training Management Support Objective No. TN-1

@rformance Area (Title) hovidefactualinformation*thatsupportsthePerformanceEvaluation

$mmary Discussions were held with supervisors / managers in project construction, project operational analysis, site QA, mechanical piping contractor, electrical contractor, structural contractor, HVAC sheet matal contractor and the testing contractor to evaluate nanagement involvement and support of training programs. Review of the appropriate records were also conducted. The depth of training programs and approaches to training varied widely among the organizations, most of these organizations Follow-up by have all contractornot documented groups overall with job related training needs.

craft personnel on the effectiveness of training programs for craft supervisors / foremen and subsequent dissemination of appropriate information to craft personnel is weak. All of the groups had weaknesses in instructors' instructional skills.

indicated A. Discussions with the project construction admin assist.

that training requirements relative to examination and inspection activities have been established for field engineers as required by The relationship procedure SCD-DOP-NC-1 " Training of Personnel."

between these requirements and training requirements needed for

=

certification to perform assigned tasks for inspections or Training needs for examinations under SCD-DOP-NC-9 is unclear.

certification purposes and training needs for otherItpurposes was also need noted to be systematically determined and documented.

that many of the training requirements specified under SCD-DOP-NC-1 are not being completed in a timely manner. Some field observations indicated weaknesses on the part of project construction field engineers in the use of surveillance forms and

in knowledge of specification requirements.

B. Discussions with the site QA Supervisor indicated that site indoctrination and receiving inspection training are not always being conducted within the time periods specified by Site Quality Instruction SQI #18, Rev. 2.

146Q/0965Q/pg. 3

l PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Mrformance Area Training Management Support Objective No. TN-1 GLtte)

~

'rovida factual information'that supports the Performance Evaluation iummary

>. Discussions with the electrical, HVAC sheet metal, and mechanical piping contractors' supervisors and managers indicated that these groups do not evaluate craft supervisors or foremen following training sessions, and either do not formally evaluate or do not have a follow-up method to determine the effectiveness of individual training sessions on craft workers. Without an effective evaluation system and/or method to determine whether the training has been successful there isn't any assurance that it has been successful'. None of the

' contractors have perpared lesson plans or training objectives for the training sessions, although the independent testing agency does have training outlines indicating topics to cover.

e During discussions with three project / site groups and five contractor i groups it was determined that few of the instructors involved in site training programs have had training in instructional skills, including preparation of lesson plans. These two items would enhance training offectiveness.

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PERFORMANCE EVALUATION

SUMMARY

, Construction Project BYRON '

Ttaining Organization

'@rformance Area and Administration Objective No. TN.2 valustor(s) E. Wilmere, E. Fitzpatrick Performance Objective The training organization and administration should ensure effective control and implementation of training activities. '

Scope of Evaluation The evaluation of this area involved a review of site Quality Assurance Programs and Procedures, also interviews with management personnel were ladministration.

conducted to discuss the training program organization and

!cvaluation of this performance objective.Approximately sixty manhours were invo l

l onclusion he majority of the activities evaluated under this performance ob ere satisfactory.

(

0983Q

\_. _ - - _ - _ -- - - - - - - - - - - - - -- ~~

L PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON Training Organization l3rformince Area and Administration Objective No. TN.2 valustor(s) E. Wilmere, E. Fitzpatrick l

Arecs of weakness and corrective action; Good Practices

~

No' Findings identified. (See Details)

,Q/0963Q/Page 2

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I PERFORMANCE EVALUATION DETAILS Construction Project BYRON Training organization Parformance Area and Administration Objective No.

(Title)

TN.2

@rovido summary factual information that supports the Performance Evaluation l.- UVAC Contractor A. The procedure for selection, training and certification of inspection, examination, testing and audit personnel establishes responsibility Supervisor for III.

Level implementation of procedure with the QA/QC B.

The site QA/QC Supervisor who conducts site training has a formal education in the training area.

C.

A training matrix has been established by the site QA/QC Supervisor to define training requirements for QA/QC personnel.

D. Records for training on procedures and design documents were l reviewed.

. Structural Contractor A. The Quality Assurance manual and QA/QC certification procedure requires training to be done.

B. Training records indicated, training for procedure revision on anchor bolt. installation was given to both Quality Assurance / Control personnel and the ironworkers.

Station Construction Department -

A. A formal training program or organization is not defined or consistently practiced with the exception of attendance periodically to Quality Assurance training of one engineer in the piping contractors program. See performance objective TN.1 for further details.

/0983Q/Page 3

e PERFORMANCE EVALUATION DETAILS Construction Project BYRON i

Training Organization Parformance Area and Administration Objective No. TN.2 (Title)

Provido Summ ry factual information that supports the Performance Evaluation

4. Mechanical Piping Contractor A. The organization has a designated training coordinator B.

The training following matrix defines management training needs for the departments: Production Welding Millwrights Warehouse (including rod issue employees)

C.

The site training procedure requires formal training for personnel responsible for inspection, examination and testing; and other technical affect thesupport qualitypersonnel or reliabilitywhoseof items,work can directly or indirectly i D.

l The Piping and Hanger Inspection Training Program is continuously I scheduled on alterating weeks to ensure availability to personnel, generally training is given on a pre-arranged schedule.

E.

Personnel requiring procedures and datestraining traininghave an individual sheet showing the was conducted.

F.

QC Inspectors for documentation checking and walkdowns have weekly training sessions documented. to cover procedure changes, but training is not Instrument Piping Contractor A.

Quality Control Qualification Procedure defines the qualification requirements which in turn dictate the training required for QA/QC personnel.

B.

The Quality Assurance Manager has developed a training matrix to define procedure training requirements.

C.

The training for documented, butProduction Foremen and QA/QC personnel was training details were nit given.

l (0963Q/Page 4

PERFORMANCE EVALUATIOI! DETAILS Construction Project BYRON Training Organization Parformance Area and Administration Objective No. TN.2 (Title)

Provida factual information that supports the Performance Evaluation Summary

5. Operation Analysis Department A. All site personnel are qualified in accordance with a department procedure following ANSI N45.2.6 guidelines.

B. Regdlar training is done to keep department personnel current to procedure and program changes. Classes are' held as a policy at least every two weeks.

C. Department personnel attend site Quality Assurance Training sessions on the Quality Assurance Program.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD Training Organization and Iformance Area and Administration Objective No. TN-2  !

31untor(s) E. F. Wilmere i

Parformance Objective i

The training organization and administration should ensure effective control and implementation of training activities.

Scope of Evaluation The evaluation of training and qualification goals and objectives involved a review of site quality assurance programs and training procedures. Also interviews with management personnel were conducted to discuss the training program organization and administration. Approximately sixty l msn-hours were involved in the evaluation of this performance' objective.

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Conclusion The majority of the activities evaluated under this performance . objective were satisfactory.

46Q/0962Q ,

f

Construction Project PERFORMANCE EVALUATION

SUMMARY

.. BRAIDWOOD Training Organization and Administration Objective No. TN-2 rform:nce Area

1ustor(s) E. F. Wilmere Arocs of weakness and corrective action; Good Practices There were no findings in this performance area.

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L PERFORMANCE EVALUATION DETAILS Construction Project ERAIDWOOD Training organization 3rformance Area and Administration Obj ective No. TN-2 (Title) rovida actual information that supports the Performance Evaluation ymma ;.

l Machanical Piping Contractor

1. Tne Quality Assurance Manual assigns the indoctrination and training of all Company personnel to the Quality Assurance manager. The site has a training coordinator who schedules training for both Production and Quality Control.

2. The site has procedures which define training and qualifications as follows:

a. Indoctrination and training

b. Quality Control Certification

c. Quality Control Weld Inspection ,

d. Quality Assurance Auditor

3. Two persons who perform site training have a training background but none of the other personnel have had any instructor training.

4. The Quality Assurance Manager has forty-two training areas listed and identified by job title, and who is to receive training in the following organizational areas:

a. Document control

b. Field Engineeers responsibilities

c. Quality Control

d. Document Control

e. Drafting

f. Material Control

g. Welding Department personnel responsibilities

h. Construction Management

5. Training is held regularly as evidenced by the number of sessions held as follows per training coordinator monthly report.

August 1982 - 14 sessions September 1982 - 39 sessions October 1982 - 38 sessions

.: -.-wp6 .

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD

- Training organization and Administration Objective No. TN-2 rform:nce Area (Title) ovide factual information that supports the Performance Evaluation amary o Operational Analysis Department

1. The site training is done by the Project Operational Analysis Supervising Engineer and one of the Level II Engineers ; however, the training responsibility is not formally designated.

2. Training and qualification goals and objectives are in part dictated by the manpower availability and relationship to work requirements. Also, the informal policy is to qualify personnel to the highest level qualifications they can meet and train in cll department procedures (24) within the three year certification period.

3. The qualification requirements are established in the Department Certification Procedure.

4. There isn't a formal training program for instructors to enchance their performance as instructors but training ineffectiveness is detected from performance evaluation of work done and this inturn is reviewed for instruction improvement.

5. The Department Certification Procedure defines three levels of skill for personnel to be qualified and to conduct their work activities

6. Technical requirements are specified in the Department Certification Procedure but non-technical training is not formally specified.

7. Training is conducted regularly as evidenced by a review of one engineer receiving training six times in the last ninety days.

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j6QivuozQ/pg.*

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Training organization eformance Area and Administration Objective No. TN-2 (Title) avida factual information that supports the Performance Evaluation amary Electrical Contractor

1. The site Quality Control Supervisor and the site Engineering

-Supervisor are responsible for their respective areas with the addition of Production to the Engineering Supervisor - to conduct the training as required. There isn't a formally defined training organization.

2. The training goal for quality control inspectors is established by the Procedure for Certification.

3. The training program for Production and Engineering is very active but there isn t a formal program established.

! 4. Training personnel are not provided training and cpportunities to l

enhance their performance as instructors.

The Engineering Supervisor was a natural and effective instructor but he did not have a formal instructor training. The Engineering Supervisor was observed conducting a class on an anchor bolt procedure revision.

5. The Training Program for Engineering and Production is active as previously noted with 15 sessions conducted recently in a 30-day period.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project

~

BYRON erformance Area General Training & Qualification Obj ective No . TN.3 raluctor(s) E. Wilmere, E. Fitzpatrick l

1 Parformance Objective Tha training program should ensure that all employees receive indoctrination and training required to perform effectively, and that employees are qualified as appropriate to their assigned responsibilities. ,

Scopo of Evaluation Tha ovaluation of this area involved input from almost the entire team.

I C1cssroom instruction and work practices were reviewed throughout the project site. Interviews with management personnel were conducted to discuss various aspects of the training programs. Also, records were reviewed to verify program compliance in some areas. Approximately, seventy manhours were involved in the evaluation of this performance objective.

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Conclusion The =ajority of activities evaluated under this performance objective were satisfactory.

,/0964Q Q

t

PERFORMANCE EVALUATION

SUMMARY

Construction Project l BYRON l

rformance Area General Training and Qualification Obj ective No . TN.3 valuetor(s) E. Wilmere, E. Fitzpatrick Arnes of weakness and corrective action; Good Practices No findings identified. (See Details) l l

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Q/0964Q/Page 2

1 PERFORMANCE EVALUATION DETAILS Construction Project BYRON 1 -

Parformance Area General Training and Qualification Objective No. TN.3 (Title)

Provida factual information that supports the Performance Evaluation Summnry

. HVAC Contractor A. The contractor's certification procedure defines responsibilities for Level I and II for the folloving employee classifications:

Documentation Receiving Ductwork Sheet Metal and Plate Work B. Requalification is required by procedure every 3 years.

. Structural Contractor i A. Beam bolting recently installed was found incorrectly installed.

A friction joint was installed instead of a slip. The latest design drawing was not consulted for the installation.

B. Quality Control Inspectors are qualified to designated areas such as anchor bolt and cadwelding.

C. Training is given to inspection and production personnel for procedure changes such as . anchor bolt installation procedure revision.

. M chanical Piping Contractor A. A review of the contractors pipe support fabrication and installation operation showed the craft people understood their jobs, workers were questioned concerning installation tolerances, weld sequences and support function.

B. Quality Control Inspectors are qualified separately for piping and component supports.

. Operational Analysis Department A. A Level I tester was interviewed for his knowledge of a motor test procedure which he was recently qualified to and he demonstrated that he thoroughly understood the process.

Q/0984Q/Page 3

PERFORMANCE EVALUATION DETAILS Construction Project

. BYRON Parformance Area General Training and Qualification Objective No. TN.3 (Title)

Provida factual information that supports the Performance Evaluation Summary

5. Instrument Piping Contractor A. During observation of contractor work on the feedwater flowmeter reservoir pots the welders, foremen, fitters and QC Inspector were found to have a good working knowledge of procedures applicable to the area they were working in.

B. The Quality Assurance training and qualification procedure allows qualification in different levels of skill in areas of job functions.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD Iformance Area General Training and Qualification Objective No. TN-3 aluator(s) E. F. Wilmere Parformance Objective The training program should ensure that all. employees receive indoctrination and training required to perform effectively, and that coployees are qualified as appropriate to their assigned responsibilities.

Scope of Evaluation The ovaluation of this area involved input from almost the entire SIE team. Classrocn instruction and work practices were reviewed throughout tha project site. Interviews with management personnel were conducted to discuss various aspects of the training programs. Also records were reviewed to vatify program compliance in some areas. Approximately seventy man-hours were involved in the evaluation of this performance objective.

Conclusion The majority of activities evaluated under this performance objective were satisfactory.

6Q/0964Q

PERFORMAliCE EVALUATION SUMriARY Construction Project BRAIDWOOD arformance Area General Training and Qualification Objective No. TN-3 raluator(s) E. Wilmere Arcas of weakness and corrective action; Good Practices None identified.

C Q / U ') C ,'n / P S . L

PERFORMANCE EVALUATION DETAILS ' Construction Project BRAIDWOOD Objective No. TN-3 eformance Area General Training and Qualification (Title) ovida factual information that supports the Performance Evaluation amary Mechanical Piping Contractor

1. Contractor personnel were observed in the plant performing assigned responsibilities as follows:

a. Field welding of a valve and fit-up of a spool piece were observed and it was concluded that the craft peopia and quality control inspectors understood their j obs.

b. A general foreman was interviewed in the steam tunnel and it was noted that he had a good knowledge of work being done, weld procedures and repair procedures.

c. A general foreman and a foreman in the auxiliary building were interviewed for their knowledge of work which was verified by detailed discussion.

d. Pipe fabrication was observed in the site shop and it was concluded that contractor personnel were knowledgeable of quality requirements and the general training and experience of personnel performing the work was adequate for the scope of the I

work being performed.

2. The Quality Control Certification Procedure has provisions for recertification of inspectors.

). Electrical Contractor

1. Contractor personnel were interviewed and observed in field i

j activities and the following were noted:

a. Craf tsmen using a hydraulic conduit bender and cutting saw were f

knowledgeable of the equipment's operation.

i

b. A foreman for conduit and hanger work stated that he did notAlso awarenes i receive training on reviions to procedures.

procedure revisions was further hampered by the revision being put into the procedure books with poor indication of what was changed.

(

p-eQ/C964Q/pg.3 i

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD

~

gformance Area General Training and Qualification Obj ective No . TN-3 (Title) ovida factual information that supports the Performance Evaluation mmery

c. Cable pulling was observed in the cable spreading room over the control room and the activities were conducted in a satisfactory manner.

. Operational Analysis Department

1. Personnel are performing assigned responsibilities effectively as evidenced by:

a.

Witness of undervoltage relay check concluded that the relay check went well and was done by a qualified engineer,

b. Witness of a megger test of the main generator excitor conducted by two Operational Analysis Department engineers concluded that the test was performed satisfactorily with no obvious problems.

2. The engineer, who transferred from another station had his experience verified for computer work and this was incorporated into the basis of qualification.

3. Engineers are qualified to procedures covering their areas of work; there are a maximum of twenty-four procedures.

4. Bi-weekly informal meetings are held to exchange information on work activities to provide employees with up-to-date information.

! Quality Assurance

1. It was noted that a utility site Qualty Assurance Engineer was very knowledgeable of the job, specification requirements and the drawings during an observation of the electrical contractor installing a conduit support in the auxiliary building.

2. Site Quality Assuance personnel are qualified to ANSI N45.2.6-1978 and also site personnel are to receive indoctrination training per Site Quality Instruction SOI-18. It was noted that six personnel ~

did not receive their indoctrination training within the prescribed 60-day period and six personnel did not complete their receiving inspector training within the prescribed six-month period.

a/0964Q/pg. 4

. I PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD trformance Area General Training and Qualification Objective No. TN-3 (Title) ovide mmary factual information that supports the Performance Evaluation

3. Continuing training is provided personnel to keep them up-to-date through training on each Quality Assurance Program Revision. An annual review of the Quality Assurance Program for a two-year recertification with a six-month review is performed for the Quality Assurance Department Inspector Qualifications.

Project Construction Department

1. During the observation of Project Construction Department field engineers doing field surveillance it was noted that:

a.

Project Construction engineers are not given formal training on the use of Project Construction Surveillance forms.

b.

Some Project Construction engineers are not knowledgeable of all the applicable specification requirements.

2. Department engineers are trained and qualified as inspectors in accordance with Station Construction Department Procedures SCD-DOP-NC-1 and SCD-DOP-NC-9. It was noted, however, that, designated additional NDE training was not being done for eight individuals.

Heating, Ventilation, Air Conditioning Contractor

1. Contractor personnel were interviewed while they were installing a hanger and it was determined the welder was knowledgeable of the procedure requirements.

g/0964Q/pg.5

P PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON Training Facilities ,

>arformance Area Equipment and- Material Objective N o. TN.4

[ valuator (s) E. Fitzpatrick/E. F. Wilmere .

Performance Objective The training facilities, equipment, and material should support and enhance training activities.

Scopa of Evaluation The evaluation of this area involved a tour of training facilities and a review of representative training equipment and materials for thqse l

organizations conducting on-site classroom training. Approximately, 4 manhours were expended touring the facilities and in discussion with various supervisors. Additionally, about 4 manhours were devoted to reviewing various training materials.

i Conclusion The majority of the elements under this performance objective were satisfactory. One weaknesses and a good practice were noted. Many of the organizations have limited training facilities, equipment and materials.

In some cases , this is indicative of more fundamental training deficiencies which are documented under the appropriate specific performance objective.

SQ/0985Q

L 1 .

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON l Training Facilities, brformance Area Equipment and Material Obj ective No. TN.4 l

F valuator (s) E. Fitzpatrick/E. Wilmere Arnas of weakness and corrective action; Good Practices Finding)

(TN.4-1 The following good practice was noted: The Mechanical Piping Contractor's selection of multiple media and use of actual equipment as visual aids enhance training sessions. Additionally, the use of pre-formed mock-ups during practical weld inspector examinations is an effective method of trainee evaluation.

Finding)

(TN.4-2 Thn Electrical Contractor needs to improve administrative controls over

cccass to its multiple purpose training area to avoid distractions and I interruptions while training sessions are in progress. Additionally, the

, Electrical Contractor needs to provide additional training equipment to permit alternative modes of prese 4tation to supplement the stand-up" mode.

Corrnctive Action Corrective action will be taken to provide more adequate training quarters by remodeling the present structure to provide a dedicated single purpose crea; this action will be complete by February 18, 1982. The PCD-Quality Control Supervisor, in conjunction with the PCD-Electrical Supervisor and the electrical contractor Project Manager, will perform a review to

. establish what additional training equipment, pre-formed mock-ups , and l multi-media equipment would enhance the training effectiveness. The review lwill be completed and documented by December 17, 1982; the additional l hardware will be in-place by March 4,1983.

l Q/0985Q/Page 2 l _

PERFORMANCE EVALUATION DETAILS Construction Project BYRON

. Training Facilities, Performance Area Equipment and Material Objective No. TN.4 (Title)

Provide factual information that' supports the Performance Evaluation Summary

,1. A tour of the applicable training areas revealed the following:

A. The Mechanical Contractor is using many pieces of actual equipment such as various snubbers and hangers as visual aids during training sessions. This makes the training sessions more interesting and permits the trainees to practice on, and ask questions concerning, the actual hardware encountered in the field.

The Mechanical Piping Contractor and the Instrumentation Piping l B.

Contractor are using pre-formed mock-ups during the weld inspector practical examinations. This practice enhances trainee evaluations.

^

. C. The Electrical Contractor's Training Programs are all stand-up live presentations. Over a period of time this approach will not hold i

the trainees' interest at a satisfactory level. Other media (such as overhead projection, video tape, audio / slide) need to be considered.

D. The Electrical Contractor's Training area is a multiple purpose area. Extraneous personnel were observed entering the area while training sessions were in progress, thereby causing distcactions

and interruptions. Administrative controls or rearrangements should be implemented to correct this problem.

E. A major reason given by the Mechanical Piping Contractor for the l

use of video tape as a training medium is to permit management to utilize the " instructor" in dual roles. While video tape is an excellent training medium, the above reason is an unsatisfactory one for its selection. Unsupervised classes in video tape are an invitation to inattentiveness and potentially frustrating to trainees should questions arise during the unsupervised session, F. The mechanical contractor is using multiple media including video tape and audio / slide ptesentations. 'This approach helps to keep student attention and adds to consistency, thereby enhancing the i training sessions.

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l PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD Training Facilities , Equipment Objective No. TN-4 erform:nce Area and Material alustor(s) E. Fitzpatrick, E. Wilmere -

Parformance Objective The training facilities, equipment, and material should support and enhance training activities.

Scopa of Evaluation Thn evaluation of this area involved a tour of training facilities and a r vicw of reprecentative training equipment and materials for those organizations conducting extensive on-site classroom training.

Approximately four hours were expended touring the facilities and in i discussion with various supervisors. Additionally about four hours were dr. voted to reviewing various training materials.

l l

l Conclusion The majority of the criteria considered under this performance objective ware satisfactory. One goad practice and one finding were noted. Many of the organizations have limited training facilities, equipment and caterials. In soce cases this is indicative of more fundamental training deficiencies which are documented under the appropriate specific pe rformance obj ective .

1

% "o907Q

1 -

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD Training arformance Area Facilities, Equipment and Materials Objective No. TN-4 raluator(s) E. Fitzpatrick, E. Wilmere Arcas of weakness and corrective action; Good Practices

' FINDING: The following good practice was noted:

(TN.4-1) The mechanical piping contractor has provided an excellent facility for conducting classroom training.

The selection and effective use of various training equipment, visual aids, and handouts, were observed to have a positive effect in the presentation of the material and in the attitude of th students toward training. Additionally, a piping mock-up, including various hangers and snubbers, constructed for training purposes is an effective training aid for installation and inspection demonstrations and for student evaluation.

l FINDING: The electrical contractor needs to provide some (TN.4-2) additional training equipment and training aids / materials to enhance the effectiveness of the training sessions.

Corrnctive Action:

The deficiencies in the training area are being evaluated. Training aids such as visual aids / samples, handouts, overhead projector will be reviewed and implemented as needed. A new training room is under construction and will contain adequate facilities for training the personnel. The review will be completed and.a course of action identified by November 24, 1982.

LcQ/0967Q/pg. 2 I

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PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Training drformance Area Facilities, Equipment and Material Objective No. TN-4 (Title) hovidafactualinformationthatsupportsthePerformanceEvaluation ammary

. A tour of the applicable training areas and observation of training sessions revealed the following:

a. The mechanical piping contractor's classroom is well equipped, well l

maintained and is utilized solely for training purposes. It represents an excellent environment for conducting training.

Equipment includes a white board, projection screen, overhead projector and slide projector. Various media, which effectively assist in maintaining student attention / interest and aid measurably in the learning process, are utilized in the training sessions.

Selected handout materials cre also available and used. A piping system mock-up to illustrate various weld fitups, snubbers, and hangers is available and used for both classroom demonstrations and l student evaluations. .

b. The electrical contractor's training equipment, training aids and materials are limited. During observation of a training session sheets from a procedure were held up to illustrate various points.

This was completely ineffective, in that the examples were not visible except in the first row. Handouts or transparencies would have been much more effective to make the points and to hold the students' interest. None of the necessary equipment or training aids are presently available, although the QA/QC Manager indicated that some training aids were being planned for the future.

cQ/0967Q/pg. 3

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.. I I

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON .

3rformance Area Quality Programs Objective No. QP-1 valustor(s) N. Main Performance Objective The quality assurance program scope, content, and applicability should be appropriate, defined clearly, and understood.

Scope of Evaluation The ovaluation of the performance area was based on observations of day-to-day QA activities and document reviews along with interviews of QA l personnel. In addition, observations, document reviews and interviews were conducted with two on site contractors to gain additional information l on the definition and understanding of the program. Approximately 20 i manhours were spent on the activities involved in evaluating this area.

Conclusion The majority of the areas evaluated under this performance objective were satisfactory. All of the performance criteria were met. The scope of the program appears to be adequate, well defined and clearly understood.

L

'/0974Q q

r

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON

'crformance Area Quality Programs Objective No. QP.1 valuator (s) N. Main Areas of weakness and corrective action; Good Practices Nona identified. (See Details)

F0974Q/Page 2

PERFORMANCE EVALUATION DETAILS Construction Project BYRON Parformance Area Quality Programs Obj ective No . QP.1 (Title)

Provide factual information that supports the Performance Evaluation Summary L. Functioning of the CECO QA organization was observed to determine if the program elements cover the scope of the work being performed and to evaluate the effectiveness of the program. Two on-site contractor's QA/QC programs were also reviewed and interviews were performed to evaluste the program. In addition, document reviews and interviews were conducted. The HVAC and the Civil Contractor were selected for this evaluation.

E. QA activities involved in the interface with contractor's programs were observed and discussed.

A. Audits and surveillances were reviewed. Schedules for these activities were also reviewed. Schedules are prepared on an annual basis, but are reviewed and changed periodically based on contractor performance. The overall program seems to be effective and adequate to maintain control.

B. Contractor procedures are submitted for review and approval. A sample of these procedures was examined to evaluate the scope of the review and the timeliness of response. No problems were noted.

l l C. NCR's and DR's prepared by the contractors also require review and approval by QA. These activities were reviewed and determined to be acceptable.

D. Overcheck inspections are performed as part of surveillances and l are also performed by an independent inspection ~ agency coordinated by the CECO QA Department.

E. Indoctrination and training of personnel is being performed for QA personnel. The program appears to be adequate. This program l

enhances the effectiveness of the newer Quality Assurance personnel.

F. Audits and surveillances are tracked and status reports issued to assure close out in a timely manner. Items open longer than 60 j

days are brought to the a,ttention of top management.

l G. Stop work authority is delegated to the site QA group and is and

! has been used when the need arises.

l lQ/0974Q/Page 3

PERFORMANCE EVALUATION DETAILS Construction Project

_ BYRON Performance Area Quality Programs Objective No. QP.1 (Title)

Provida factual information that supports the Performance Evaluation Summnry H. A trending program is used to identify significant quality problems for the site organizations. The program provides a large data base.

I. Application of the program is applied to the project based on safe *.y related or non-safety related classifications.

The overall program complies with the quality commitments and there appears to be a good understanding of the importance of the quality program by site personnel.

3. The QA/QC activities of two site contractors were observed and discussed to evaluate their understanding of quality commitments, and their interface with the CECO QA Department.

A. HVAC Contractor

a. Currently has a stop work order becuase of inadequacies identified in their program.

b. Program was reviewed and approved by CECO QA Department.

Implementation procedures were reviewed and approved by site construction, site QA and the AE.

(

c. Audits and surveillances are performed by CECO on a regular basis.

l d. NCR's and DR's are submitted to CECO QA for review and approval.

l

e. A new revision to the QA/QC program was dated 9/3/82. A new QA/QC Supervisor has been hired. He is in the process of revising the implementation procedures to meet the program commitments,

f. The interface with CECO QA seems to be well established and understood. Training and indoctrination of contractor QA/QC personnel are being upgraded to better support the quality commitments.

l l g. Completion of revisions and implementation of changes should l properly upgrade the contractor's program to enable them to satisfy the CECO Quality requirements which have been specified.

lQ/0974Q/Page 4 l

PERFORMANCE EVALUATION DETAILS Construction Projec BYRdN Parformance Area Quality Programs Objective No. QP.1 (Title)

Provide summary factual information that supports the Performance Evaluation h.

The program is subjected to an overcheck inspection by an independent inspection agency coordinated by CECO QA on site.

B. Civil Contractor a.

QA Implementing program was reviewed and approved by' CECO QA Department.

construction, procedures site QA andare S&L. reviewed and approved by site j b.

Audits and surveillances are performed by CECO on a regular basis.

c.

i NCR's and DR's are submitted to CECO QA for review and approval.

!. d.

The program is subjected to overcheck inspections by an independent inspection agency coordinated by CECO site QA.

e.

significant quality problems are identified.The QA/QC Super been exercised in isolated cases for specific tasks.The authority has Significant problems are identified using DR's and trend analyses.

f.

Regularly his program. scheduled audits are performed by the contractor on basis. Surveillances The auditand schedule first line is established on an annual performed by QA/QC personnel. inspections are also g.

The interface with CECO QA seems to be well understood and established.

Project Construction. They also have a significant interface with h.

Training and indoctrination of contractor QA/QC personnel appears commitments. to be adequate to support the programs quality 1.

Implementation procedures are the controlling documents and they (ECN's).

are revised based on changes to the AE specifications l

y974Q/Page 5

(. .. _ ___. _ _ . _ _ _ _ - - - - - - - - - --~ ~ ~~~~~~~ _ _ _ _ . _ . _

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD trformance Area Quality Programs Objective No. QP-1 reluator(s) N. Main Performance Objective The quality assurance program scope, content, and applicability should be appropriate, defined clearly, and understood.

Scope of Evaluation Observations of on-going QA activities, document reviews, and interviews of CECO QA personnel were performed. Observations, document reviews and interviews were a7 so conducted with QA personnel of two on-site contractors to gain additional information relative to the performance area. Approximately 12 manhours were spent in the activities involved in the evaluation of this performance area.

Conclusion The areas evaluated under this performance objective indicated satisfac-tory performance. All of the performance criteria were met. The scope of the program appears to be adequate, well defined and clearly understood.

46Q/0969Q P

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PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD rformance Area Quality Programs Objective No. QP-1 31ustor(s) N. Main Areas of weakness and corrective action; Good Practices No findings-identified.

bQ/0969Q/pg. 2

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Orformance Area Quality Programs Objective No. QP-1 (Title) rovida factual information tnat supports the Performance Evaluation ummary h3 CECO site QA organization was observed for the purpose of determining hat the program elements cover the scope of the work being performed and to valuate the effectivenes of the program. Two on-site contractors QA/QC rograms were also observed. In addition, document reviews and interviews are conducted. The mechanical contractor and the electrical contractor ere selected for this evaluation. The following items were noted:

a Tha CECO site QA activities were observed and discussed. The results of these activities are outlined below:

A. Audits and surveillances are conducted on all site contractors QA/QC activities. All of the applicable 18 Criteria of 10CFR50, Appendix B are reviewed on an annual basis, l

B. Receipt inspections, review of contractors procedures prior to implementation, and review of all site NCR's (both CECO and contractors) are performed.

C. Certification of all welders on site are witnessed.

D. Initiation of Unit Inspection Program. Started about six weeks ago, administered by CECO QA Department, performed by independent inspection agency.

j E. Independent Testing Agency Overview Group l - Reports to QA Engineers

- Sets-up surveillance schedules which the Independent Testing Agency people perform, CECO QA Engineers prepare checklists to be used.

F. Audits and surveillances were reviewed. Schedules for these

activities were also reviewed. Schedules are prepared on an annual ,

! basis but are reviewed and changed periodically based on contractor performance.

G. Application of the program is applied to the project based on Safety-Related or Nonsafety-Related classifications. Lists for these designations were available.

l bQ/09,69Q/pg. 3 L

PERFORMANCE EVALUATION DETAILS Construction Project

, BRAIDWOOD OrformanceIrea Quality Programs Obj ective No . QP-1 (Title)

Rovida factual information that supports the Performance Evaluation ummary H. Significant quality problems are identified through audits, surveil-lances, NCR's and overcheck inspections. Trending is done on audit deficiencies and NCR's. Stop work authority is delegated to Site QA Superintendent. Numerous stop work orders have been issued.

I. Contractor interface is maintained by review and approval of procedures, surveillances, audits, meetings, verbal discussions and weekly job progress meetings. Cognizant QA engineers are assigned to each individual contractor. This provides for good communications and relationships with the contractors.

The program supports the quality commitments and appears to be adequate to cover the scope of the work being performed.

c An interview was conducted with the CECO Manager of Quality Assurance.

I Tho results of the interview are outlined below:

A. Quality requirements are specified in contracts for individual contractors.

B. CECO QA has been established as an independent function. They are supported by an independent testing agency which reports directly to CECO QA.

C. Quality Program meets the criteria of 10CFR50, Appendix B, ANSI N45.2 and ASME Section 3, Division I and II. The program is documented in the Topical Report - Section 2 and' Blue section of QA Manual. The program incorporates both NRC and ASME requirements.

D. Program is reviewed on a periodic basis to incorporate changes to

! codes and standards. Revisions to the program are made as deficient areas are identified. The changes are reviewed by the CECO Manager of Quality Assurance.

I E. Changes in the program can be requested by various organizations within CECO.

The requests are reviewed by the Manager of Quality Assurance to determine if the change is necessary. The program is a live document.

No problems were identified in this area.

6Q/0969Q/pg. 4 l

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PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD

%rformtnce Area -Quality Programs -

Objective No. QP-1 TTitle)

'rovide factual information that supports the Performance Evaluation iummery

,. The QA , Programs of two site contractors were reviewed and discussed to ovaluate their understanding of quality commitments and their interface with the CECO QA Department.

A. Mechanical Contractor

a. Quality commitments are based on contract requirements, ASME Code and changes made by ECN's received from the AE.

b. Program changes are based on ECN's received from the AE and ASME Code addenda,

c. . Program is approved by CECO QA prior to contract award.

Activities are performed in accordance with implementing procedures approved by Ceco and the AE.

d. Program 1 effectiveness is based on audits. Audit schedules have been developed and the scheduled audits are being performed.

Trending is limited but is being done.

e. Audits and surveillances are performed by CECO on a regular basis.

f. All NCR's are submitted to CECO QA for review and approval.

g. Training and indoctrination of QC personnel is being performed.

l h. Stop work authority is delegoted and used by contractor.

No significant problem areas were identified in the program.

B. Electrical Contractor

a. Corporate QA/QC Manager is not located on-site. Only one QA Engineer on-site . Remainder of staff is QC.

b. QA Program approved by CECO QA Prior to contract award.

Implementing procedures are written by QC and reviewed by QA Engineer. Procedures are approved by CECO and the AE.

f6Q/0969Q/pg. $

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD

~

3rformance Area Quality Programs Objective No. QP-1 (Title) rovida factual information that supports the Performance Evaluation ummary

c. Original program commitments established by AE in Spec L-2790.

d. Revisions to procedures are based on results of audits, plant suggestions and AE changes (ECN's) . All revisions are also approved by CECO and the AE.

e. Audits and surveillances are performed on contractor's program '

by CECO on a regular basis.

f. NCR's are submitted to CECO QA for review and approval.

Inspection Erection Reports (IER's)-are used to handle minor items which are corrected without AE approval. Copies go to CECO QA for concurrence of corrective action.

g. Audit schedules and status reports are maintained.

h. Weekly Inspection Status Reports are prepared and maintained.

i. Trending is not performed but a log of problems identified by audits and NCR's is maintained.

! j. Surveillances are also performed by contractors QA Engineers.

k. Stop work authority is delegated to the site QC Manager but he i

must obtain concurrence of Corporate QA/QC Manager. prior to issue. .

1. Reviewed audits which have been performed, audit log and tracking system for assuring findings are closed out in a j timely manner.

m. Contractor's QA person understands the CECO QA interface and a good relationship appears to exist between contractor and CECO QA department.

n. Training and indoctrination of contractor QC personnel is being performed.

No significant quality program problem areas were identified.

bQ/0969Q/pg. 6

PERFORMANCE EVALUATION.

SUMMARY

Construction Project BYRON

'arform nce Area Program Implementation Objective No. QP.2

'valustor(s) R. Ferguson Parformance Objective Qurlity assurance and quality control functions should be performed in a m:nnor to support and control the quality of the project activities.

Scopa of Evaluation The evaluation of this area consisted of interviews, document reviews and input from several other team members as a result of their activities.

Approximately 30 manhours were expended in this effort.

Conclusion The activities evaluated under this performance objective were satisfactory.

h/0975Q

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON trform nce Area Program Implementation Obj ective No. QP.2

valu:: tor (s) R. Ferguson Ara s of weakness and corrective action; Good Practices No Finding identified. (See Details) 5Q/09/5Q/Page 2

PERFORMANCE EVALUATION DETAILS Construction Project BYRON, Parformance Area Program Implementation Objective No. QP.2 (Title)

Provida factual information that supports the Performance Evaluation Summxry

1. Interviews with QA and Project personnel indicated that:

A. The relationship between the on-site QA organization and construc-tion and the contractors is defined and in general appears to be cooperative. There wasn't any indication of harrassment or intimidation of QA/QC personnel. ,

B. There is a continual effort on the part of the General Office and the Site QA organizations to improve their effectiveness, i.e., they have just established what is called a " unit concept inspection" whose primary purpose is to evaluate.the total quality of selected portions of systems during each inspection opposed to just pieces of the systems.

D. The project organizations do utilize technical specialists exten-sively in the implementation of the quality requirements. These specialists are obtained from inside the Company, consultants and within the QA organization.

E. The contractor's and vendor's QA programs are reviewed and approved and audited on a continuing, scheduled basis by CECO and appear to be effective.

$. Analysis of the hours spent by the site QA group is as follows:

Assumptions ,

Hours /yr/ person available for work is 1888 Average site audit requires 50 MH/ audit Avarage site surveillance requires 4 MH/ surveillance The Site QA Supt. is not available for surveillance / audit Total Site QA staff consists of 18 people Facts 54 scheduled audits (12 mo.) = 3240 MH/

I 1,383 surveillances (12 mo.) = 5532 MH/yr yr l GO audits required 808 MH of Byron staff time in ten months. (Note:

This excludes 120 MH by. Site QA Supt.)

Byron QA staff will receive 2,114 MH training in 1982 p/09/5Q/Page3

PERFORMANCE EVALUATION DETAILS Construction Project BYRON Parformance Area Program Implementation Objective No. QP.2 (Title)

Provida factual information that supports the Performance Evaluation Summ3ry Analysis 17 people x 1888 = 32,096 MH total for the group 32,096 .3240 - 5532 - 970 (GO audits for 12 mo.) - 2114 = 11,856 MH for administrative duties, meetings, walkthroughs, sick leave, site training, answering outside audits, etc. This assumes that all 17 people were on-board for 12 mo. which is not true. Assuming one new parson was added each month for 9 months then the MH total for the group is 26 902, instead of 32,096, which allows 6,662 MH or an 8 hr./wk/perso,n for the above.

fQ/0975Q/Page4 l

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD 1rformence Area Program Implementation Objective No. QP.2 valuotor(s) R. Ferguson l

P:orformance Objective Qu lity Assurance and Quality Control functions should be performed in a manner to support and control the quality of the project activities.

Scop?> of Evaluation Tha evalu.ation of this area consisted of interviews, document reviews and input from several. other team members as a result of their activities.

Approximately 25 manhours were expended in this effort.

Conclusion The activities evaluated under this performance objective were satisfactory.

5./1015Q

PERFORMANCE EVALUATION

SUMMARY

Construction Project

~

BRAIDWOOD erformance Area Program Implementation Objective No. g .2 ralustor(s) R. Ferguson Areas of weakness and corrective action; Good Practices No findings identified. (See Details)

[/1015Q/pg. 2 l .. . . . - - -. . - . - --. _ -.

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Parformance Area Program Implementation Objective No. QP.2 (Title)

Provido factual information that supports the Performance Evaluation Summary Interviews with QA, Project and Contractor personnel and reviewed documents. indicate the following:

1. The relationship between QA and the on-site QA organization and construction and the contractors is defined and appears to be cooperative. There was not any indication of harrassment or intimidation of QA/QC personnel.

2. Reviewed the personnel qualifications of the CECO QA group. Of the 18 CECO personnel in the group 15 have college degrees which compares to 14 at Byron. This appears high compared to an industry average. Also, 4 of the 18 have been in the group for 9 months or le.ss which compares to eight people for Byron. The average QA experience level in the group is approximately two years. They have supplemented the group with five technical type people from the Independent Testing contractor.

3. It sas s'tated that the cleaniness zone requirements of ANSI N45.2.3 (1973) have not specifically been identified in the site procedures for housekeeping. Byron and LaSalle have done this.

4. It was stated by the CECO site QA Superintendent that he feels that overall corrective action response from contractors and PCD has been.better than the average.

5. Category II contractors are not on the audit schedule, however, QA does perform surveillances on them.

6. The working relationship between the mechanical contractor and the independent testing contractor was stated by the mechanical contractors QC Supervisor as being very good; this was also stated by the HVAC QA Supervisor. They also stated that their relationship with CECO QA was very good and for the most part the CECO QA people are knowledgeable.

7. The mechanical contractor performs 100% inspections on welds requiring RT or UT. It was also stated that CECO QA personnel witness 100% of the weld bend tests.

'/1015Q/pg. 3 l

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Parformance ' Area Program Implementation Obj ective No . QP.2 (Title)

Provida factual information that supports the Performance Evaluation Summary

7. Continued They have a surveillance and monitoring program which monitors approximately 65 procedures and 40 welding procedures. Line walks are about 1.5 years away and will probably include field engineer, QC and construction personnel. They plan on performing specific walkdowns for hangers.

8. The HVAC contractor QA supervisor stated that they are gathering data about other HVAC contractors who are presently having problems at other sites and using this data to try and improve their QA/QC system. When asked about the duct access doors being open around the plant it was stated that previously these were to be closed up and inspected at a later date but the decision was recently made to inspect for closure as the job progresses. This problem was identified by CECO QA. It was also stated that the HVAC inspectors perform a 10% sample receipt inspection. Damage to ducts by other contractors does not appear to be a problem. It was also stated that their system of tieing in QC with the duct and hanger instal-lation is in the process of revision and will assure that QC is involved in-process.

9. Analysis of the hours spent by the site QA group is as follows:

Assumptions Hours /yr/ person available for work is 1888. Average site audit requires a 60MH/ audit. Average site surveillance requires a 6MH/ surveillance. The site QA Superintendent is not available for surveillance / audit. Total site CECO QA staff consists of 18 people.

Facts 53 audits (12 Mo.) =3180 MH/yr 590 surveillance (12 Mo.) = 3540 MH/yr Byron QA staff will receive 1,742 MH training in 1982. G.O audits required 2032 MH of Braidwood staff time in 10 months time (this excludes 128 MH by site QA superintendent)

n m sr /nr /.

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Parformance Area Program Implementation Objective No. QP.2 (Title)

Provida factual information that supports the Performance Evaluation Summary  ;

Analysis' 17 people x 1888 = 32,096 MH total' for the group 32,096 - 3180 - 3540 - 1742 - 2538 (GO audits for 12 Mo.) = 10,900 MH for administrative duties, meetings, walkthroughs, sick leave, site training, answering outside audits etc. This is more than what was available for the Byron staff by approximatley 10%.

10. The project organizations utilize technical specialists extensively.

in the implementation of the quality requirements. These specialists are obtained from inside the company, consultants, and within the QA organization.

11. The contractors and vendors QA programs are reviewed and approved and audited on a continuing, scheduled basis by CECO and appear to be effective.

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l 2/1015Q/pg. 5 L .---- - -_._,-.-. - _ __,_., ,._. , - _ .-_ _ _ _____ _ _____

PERFORMANCE EVALUATION

SUMMARY

Construction Project

~

BYRON

rformance Area Independent Assesscents Objective No. QP.3 valuator (s) R. Ferguson, N. Main, E. Martin ---

Performance Objective M:negement should provide an effective, independent assessment of project cctivities affecting the quality of the project.

Scopa of Evaluation Tha evaluation of this area involved three people on the team.

Approximately 10 manhours were expended in observing work practices at vetrious locations on the project. As a follow-up to these observations, approximately 15 manhours were devoted to discussions and records review.

Conclusion The independent assessment activities on the project are extensive and generally satisfactory. How ever , there are'some areas that need to be strengthened.

'Q/0979Q

i PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON l

erformance Area Independent Assessments Objective No. QP.3 valustor(s) R. Ferguson , N. Main , E. Martin Arcas of weakness and corrective ' action; Good Practices Finding)

(QP .3 -1 The offectiveness of the PED field surveillance of storage activities needs improvement. The need for a written PCD procedure and training for this cctivity should be addressed.

Corrective Action An ovaluation of PCD field surveillance of storage activities will be conducted to ' establish written procedures which more definitively establish the objective and criteria associated with the checklists employed to document the activity. The evaluation will be completed, and procedures will be created by January 4,1983. Personnel will be instructed in the revised requirements by January 28, 1983. -

Finding)

(QP.3-2 CECO QA surveillances need improvement; specifically the newer personnel conducting these surveillances need to be better trained in order to achieve a more comprehensive surveillance program.

Corrective Action This OJT Program for Quality Assurance personnel is currently under geview. The program will be revised to set minimum criteria for training in the area of conduct of surveillances. A program will be established whereby new personnel will conduct surveillances with or under the firection of experienced individuals until such time as his supervisor feels he is proficient. This program should assure that new personnel have adecuate knowledge of surveillance requirements. This program will be gully implemented by December 17, 1982.

a/09/9Q/Page z I

e

. PERFORMANCE EVALUATION DETAILS Construction Project BYRON ,

l

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l Performance Area Independent Assessments Objective No. QP.3 (Title)

Provide factual informatio'n that supports the Performance Evaluation Summary

1. The performance of a PCD Field Engineer was observed in order to evaluate the quality of PCD Field Surveillances of storage activities.

Weaknesses were noted in the following areas:

A. The approval and control of PCD Field Surveillance checklists could not be demonstrated. ,

B. The PCD Field Surveillance Program has not been established by procedure.

C. A PCD Field Engineer performed a surveillance in a manner that was not representative of his surveillance checklist. He identified rust as being acceptable on his surveillance checklist; yet he stated during the surveillance that he did not review 'this item.

D. The PCD Field Engineer was not cognizant of all areas to be' reviewed during the surveillance. He did not review all rebar laydown areas nor did he review the masonry lintel storage area.

$. A walkthrough of the material storage area was performed to review the f inspection control and maintenance of stored materials. The storage l

areas were neat and orderly; however, the following items were noted:

A. Class I stainless steel pipe flanges of assorted sizes were' stacked -

on each other without protection of the flange faces.

! B. Flexitallic gaskets were stored in the General Stores walkway in an l uncontrolled and dirty state.

C. The PCD storage surveillance monthly schedule does not require surveillances to be conducted of the piping contractor's general warehouse. ,

fQ/0979Q/Page 3

l PERFORMANCE EVALUATION DETAILS Construction Project BYRON

^

Performance Area Independent Assessments Objective No. QP.3 (Title)

Provida factual informatio'n that supports the Performance Evaluation Summary

3. The performance of a CECO site QA person was observed performing a routine surveillance of a mechanical contractor's activities in hanger installation.

a. The QA Inspector could not answer questions relating to hanger requirements that should have been in the SLL spec or vendor data sheets such as: Requirements for j am nut torque, or use of washers. This inspector had been with the department seven months.

b. Upon' examination of the site QA Department, the approximate experience level in both QA and Nuclear is as follows:

Reporting to the Site QA Superintendent there are:

Two Supervisors , one with 3 years experience and one with.nine months experience.

The engineers & inspectors reporting to the supervisors have the following experience:

8 people have from 2 to 9 months experience 3 people have from 16 to 18 months experience 4 people have greater than 3 years experience In addition to the CECO people they have supplemented the group with six personnel from the independent testing contractor in order to offset the low experience level of CECO personnel.

c. The surveillance consisted of reviewing a randomly selected completed hanger package for completeness , then finding the installed hanger in the field and verifying some of the recorded as-built dimensions and then a surveillance report is written.

4. In an interview with the site QA Superintendent, the following statements were made:

a. It has been difficult to keep the experienced people at their normal function because of special projects (both site & non-site related) such as audits at other CECO sites and elsewhere.

'Q/09/9Q/Fage 4 l

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PERFORMANCE EVALUATION DETAILS Construction Project BYRON Performance Area Independent Assessments Obj e ctive No . QP.3 (Title)

Provide factual information that supports the Performance Evaluation-Summary

b. Because of the limited experience of the staff this places additional burdens on the supervision.

c. Nine new people have been brought into the group since the first of the year and four more have been requested from the independent testing contractors.

5. In an interview with the QA Managers of two of the site contractors,

' the following statements were made:

a. CECO QA personnel are enthusiastic; however, they sometimes switch people when they become experienced. The new people don't fully understand the goals and objectives of their own Company; there-fore, it is easier to work with the PCD personnel than QA,because of their knowledge,

b. They have contact with CECO QA on the average of 5-to-6 times / day.

c. They do' not have, nor are aware of, an interface document describing the interface between CECO and the independent l

testing contractor. ~However, they do appear to understand this l interface.

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$Q /09/9Q/Page 5

PERFORMANCE EVALUATION.

SUMMARY

Construction Project BRAIDWOOD erformance Area Independent Assessments Obj ective No . QP.3

~

valuntor(s) R. Ferguson, N. Main, E. Martin -

Performance Objective Msnagement should provide an effective, independent assessment of project activities affecting the quality of the project.

Scopo of Evaluation The evaluation of this area involved three people on the team.

Approximately, 15 manhours were expended in observing work practices at various locations on the project. As a follow-up to these observations, opproximately 20 manhours were devoted to discussions and records review.

t Conclusion i The independent assessment activities on the project are extensive and generally satisfactory.

l l

Q/lO25Q

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD arformance Area Independent Assessments Objective No. QP.3 valuttor(s)

R. Ferguson, N. Main, E. Martin Armas of weakness and cor'rective action; Good Practices Finding)

(QP.3-1 r The offectiveness of the PCD field surveillances need improvement. The need for a written PCD procedure addressing training for this activity should be considered.

Corrective Action:

An ovaluation of PCD field surveillance activities will be conducted to establish written procedures which more definitively establish the objective and criteria associated with the checklists employed to document the activity. The evaluation will be completed, and procedures will be created by January 4, 1983. Personnel will be instructed in the revised requirements by January 28, 1983. .

Finding

,(QP.3-2)

The following good practice was noted: CECO QA has initiated a program titled " Unit Concept" surveillance inspections. This program initiates independent inspection on all items in a given unit of a system using the

dosign documents as the criteria base. This is a positive departure from .

.the industry practice of inspecting items. Details are stated in the idateil sheets.

wm

PERFORMANCE EVALUATION DETAILS Construction Project t

BRAIDWOOD Psrformance Area Independent Assessments Objective No. QP.3 (Title)

Provide factual information that supports the Performance Evaluation Summary L. The performance of three PCD Field Engineers were observed for the purpose of evaluating the quality of PCD Field Surveillances of storage, block wall installation and welding. Details are as noted in the following areas:

A. Sto' rage

a. During the surveillance of the site electrical contractor's warehouse, two boxes marked " flammable material" were observed to be stored on a shelf on the upper level of the warehouse without adequate ventilation. The PCD surveillance checklist requires that flammable materials be stored in a well ventilated, marked area. This item was marked acceptable on ~

the checklist. .

b. The surveillance of the electrical storage areas for structural steel, unistrut and cable pans was conducted from a car. He stated that walkthroughs were part of his daily activities.

c. The cable storage area and equipment stored in the plant were i not reviewed during this surveillance.

l

d. The engineer stated that he did not receive formal training on PCD surveillances due to his past QA experience. .

e. The PCD/SCD procedure manual does not address training on PCD surveillances.

B. Block Wall

a. Tie bars were being stored in empty cable pans. The PCD Engineer stated that items could be stored in empty cable pans I only.

l l b. The Field Engineer stated that he did not receive formal l training in field surveillances.

c. The engineer knew'the reinforcing requirements of the spec.

Q/ loc 5Q

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Torformance Area Independent Assessments Objective No. QP.3 (Title)

Provida factual informatio'n that supports the Performance Evaluation Summtry C. Welding (HVAC)

a. The PCD Field Engineer stated that he did not receive formal training in field surveillances.

b. The engineer was knowledgeable in the spec. requirements.

c. The welder's qualifications were reviewed and found acceptable.

2. In evaluating this performance objective the following items were also noted:

A. The recently initiated " Unit Concept" of surveillance inspections by CECO QA on all nuclear construction sites expands the geope of the normal surveillances. The program is designed to provide a system to independently inspect all items in a given unit (i.e.,

omponent, equipment area) using the design documents as the criteria base. This is to assure that the various contractors take-off documents used during fabrication, construction and installation are properly translating the requirements of the design. It provides identification of specific condicions that are l prevalent throughout the activity of a given contractor due to a i

deficiency during the implementation of their quality program.

Such identification is intended to prompt the contractor to initiate their own evaluation /re-inspection to determine if other

" units" of their work contain the same discrepancies.

The activity is supervised by a CECO QA Engineer and most of the inspections are performed by Independent Testing Contractor l personnel.

Approximately eight unit concept surveillance inspection reports were reviewed and compared with other regular surveillance reports.

B. Accompanied a CECO QA Engineer on a routine surveillance of the electrical contractor's activities in installing conduit supports.

This was the continuation of a surveillance that had begun a day earlier. The particular support was FC-4 conduit hanger ar Elev.

414 in the Auxiliary Building between Columns S.7 & 12. The result was that the QA Engineer was knowledgeable and thorough.

r LQ/1025Q I -_. - - . .

PERFORMANCE EVALUATION DETAILS Construction Project l BRAIDWOOD Parformance Area Independent Assessments Objective N'o. QP.3 (Title)

Provido factual information that supports the Performance Evaluation Summary C. Upon completion of the observation seven Cat-1 and several Cat-2 surveillance reports of the electrical contractor were reviewed, and their scope and resulting corrective actions were well documented. Also, reviewed 21 housekeeping surveillance reports for 1982, anywhere from 3 to 20 items were identified and

~

corrective action (clean-up of the items identified) was prompt.

Eleven were for auxiliary building, one for fuel handling building,

, one for electrical contractor's warehouse, six for U-l containment, two for U-2 containment, and one for turbine building (safety-related only) . Also reviewed twenty-five 1982 surveillances of the mechanical centractor and they were satisfactory. Reviewed six CECO site audit reports of the mechanical contractor and they were satisfactory and corrective actions appeared in general to be reasonably prompt. -

D. Reviewed the QA handbook that is issued to each site QA person upon entering the department. It is an excellent compilation of items that should be looked for in performing surveillances and audits.

It could have had more information on hangers and whip restraints since that is currently an industry problem.

E. The 1982 site audit / surveillance schedules were reviewed and 50 audits have been conducted including six vendor audits off site and 492-surveillances have been conducted which is 50% over the schedule.

F. Interviewed several site contractor's (Mechanical, HVAC and Civil Structural) personnel, both QA/QC and Construction, and the general consensus is that the CECO audit / surveillance personnel are effective and qualified.

G. Reviewed two audit reports prepared by the HVAC contractor's i corporate QA Department. The reports only contained findings and no other information. It was stated that this was also identified by CECO QA and the backup information has been requested and should be received chortly.

H. The most significant reason for the good relationship with CECO QA as stated by the contractor's personnel was the fact that the CECO QA personnel on site have been here for several years and are knowledgeable in the work that the contractors are performing.

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON arformance Area Corrective Actions Objective No. QP.4 taluttor(s) E. Martin Parformance Objective Conditions requiring corrections or improvements should be resolved in an affective and timely manner.

Scopa of Evaluation Tha evaluation of this area involved interviews with key Quality Assurance cnd Quality Control personnel of the site Electrical Contractor and a ravicw of corrective action records. Approximately four manhours were exp:nded in observing the contractor's corrective action activities.

Conclusion The overall activity evaluated under this performance objective was satisfactory.

F iQ/0976Q l

PERFORMANCE EVALUATION SUMMAPY Construction Project BYRON erform:nce Area Corrective Action Objective No. QP.4 valuttor(s) E. Martin Arecs of weakness and corrective action; Good Practices No Findings identified. (See details)

>Q/0976Q/ Page 2

PERFORMANCE EVALUATION DETAILS Construction Project BYRON Parformance Area Corrective Action Objective No. QP.4 (Title)

>rovida factual information that supports the Performance Evaluation summary Run electrical contractor was observed to evaluate their involvement in resolving conditions requiring correction or improvement. The highlights of

ho review were:

L. The Site Quality Assurance Manager displayed a keen awareness of past and present deficiencies and associated corrective actions.

5. Trend Analyses are conducted of audits, surveillances, nonconformance reports and discrepancy reports on a quarterly basis.

. The audit schedule covered all quality related areas and was current.

). Audit Reports and Trend Analysis Reports are distributed to upper menagement.

Q/0976Q/Page 3

6 PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD rformance Area Corrective Actions Objective No. QP-4 alustor(s) E. Martin Parformance Objective Conditions requiring corrections or improvements should be resolved in an effective and timely manner.

Scope of Evaluation The evaluation of this area involved interviews with the site contractor Quality Assurance and Quality Control personnel and reviews of audits and nonconformance reports. Approximately five manhours were expended in observing site contractor corrective action activities.

Conclusion l

The overall activity evaluated under this Performance objective was

@atisfactory.

$Q/1024Q k

PERFORMANCE EVALUATION

SUMMARY

Construction Project

~

BRAIDWOOD cformance Area Corrective Action Objective No. QP.4 aluator(s) E. Martin Arcos of weakness and corrective action; Good Practices

~

No Findings identified. (See details)

IlO24Q/Page

/ 2

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD erformnnce Area Corrective Actions Objective No. QP-4 (Title) covida factual information that supports the Performance Evaluation ummnry The site electrical contractor was observed for the purpose of evaluating their system for resolving conditions which require corrections or improvements. Interviews with site Quality Control and Quality Assurance suparvision and field personnel were conducted. Current and past audit cnd nonconformance reports were reviewed for content and close-out. The highlights of the interviews and review were:

A. Site Quality Assurance has identified conditions adverse to quality and reported these conditions to upper management.

B. . Site Quality Assurance, Quality Control and Project Management cooperate in the resolution and close-out of deficient items.

C. Trend analysis are conducted on audit deficiencies and nonconformance reports. Trends have been identified and corrective action is underway.

D. Responses to audit reports are originated by the responsible organization and are reviewed by site Quality Control for completeness.

r C. ave ~Qibi* a

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON erformance Area

~

Test Program Obj e ctive No . TC.1 islustor(s) C. Schumann Parformance Objective The test program should verify the plant's full capability to operate as intended by testing the plant s systems functionally.

Scopa of Evaluation The evaluation of this area involved review of the Start-up Manual, FSAR Chapter 14, Pre-Operational Test procedures and discussions with

• responsible Project personnel assigned to start-up testing.

Conclusion The majority of activity evaluated under this performance objective was satisfactory. How ever , improvements could be made in the early

' identification of nonconforming conditions and discrepancies by Project Construction.

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,Q/v996Q l

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON.

Orformance Area Test Program Obj e ctive No . TC.1

valua tor (s) C. E. Schumann Areas of weakness and corrective action; Good Practices Finding)

(TC.1-1 The following good practice was noted: The station's portion of the system walkdown prior to turnover for Pre-Operational testing is well defined, exten'ive s and includes four independent station groups to ascertain system recdiness. Additionally, the recently initiated, " Shakedown Testing" prior to Pre-Operational Testing should provide additional assurance of system readiness.

Finding)

(TC.1-2

! Tha walkdown by Project Construction prior to Pre-Op turnover is in need of improvement to provide early identification of system deficiencies. In

' meny instances these deficiencLa s are left to be identifLed by the station walkdowns .

Corrective Action

, Guidance for construction personnel will be provided in a form similar to th t which is .in use by the station. That is, general guidance on types of items to look for during a system walkdown. The use of System Data Pack 2gos as a list of the needed equipment for each test will be

. continued. Implementation of this change will be completed by December 17,

!1982. ~

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,Q/0996Q/Page 2 l

PERFORMANCE EVALUATION DETAILS Construction Project BYRON Parformance Area Test Program Objective No. TC.1 (Title)

Provide factual informatiEn that supports the Performance Evaluation Summary

1. Interviews with Station Construction personnel responsible for system walkdowns indicates that:

a. Construction System Engineers do not consistently do complete system walkdowns rather they rely on their cumulative knowledge of system status based on working on the system daily.

b. No criteria is available for the Construction System Engineer defining system completeness,

c. In many cases, deficiency identification is left to the station to determine in their walkdowns.

8 Details on deficiencies found are presented in observations of System Walkdown. Numerous deficiencies are found during the system walkdowns by station personnel. Deficiencies found on walkdown of auxiliary feedwater were as follows:

Auxiliary Feedwater Walkdown Deficiencies Observed on 10/26/82 instruments:

1 PI - AF054 Loose Mounting on gauge 1 TI - AF126 1A Disch. Tmep. Close clearance between gauge and WS header 1 TJ - AFill AB Bearing Temp. No calibration.

Diesel Oil Pressure gauge on right angle gearbox on diesel has no instr. number Diesel Temperature sensing lines bent 1 PI - AF139 1 TI - AF140 Gauges not labeled 1 TI - AF148 1 FI - AF022 Capillary tubing loose L

JQ/09voQ/Page 3

. PERFORMANCE EVALUATION DETAILS Construction Project BYRON forformance Area Test Program Obj e ctive No . TC.1 (Title)

Provido factual informatio'n that supports the Performance Evaluation Summary Open IDR's requiring replacement of instruments 1-500-81 ITI-AF140 1-125-82 1PS-AF122 1-165-82 ITI-AF125 1-425-82 ITSH-AF147 1-467-82 1FI,-AF095 Auxiliary Feedwater Walkdown Findings 10/26/82 Electrical Broken sealite to 1TE-AF001D Tcmporary lighting for lA Pump Cubicle .

Machanical lAF027A, J - no packing bolts on packing gland Limit maitch not installed Water seal on I/B 1A Aux. Feedwater Pump r __

'Q/0990QiPage e

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD erformance Area Test Program Objective No. TC.1 valuator (s) Chuck Schumann Parformance Objective Tha test program should verify the plant's full capability to operate as intended by testing the plant s systems functionally.

Scope of Evaluation The evaluation of this area involved review of the Start-Up Manual, FSAR Chapter 14 and discussion with responsible. project personnel assigned to Start-Up testing.

Conclusion The status of construction at this time is such that Pre-Operation testing has not begun. Additionally a Start-Up Coordinator has not been assigned at this time. Pre-Operational tests have not yet been written and approved.

[9100ay

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD erformance rea Test Program Obj ective No . TC.1 valuator (s) Chuck Schumann Aracs of weakness and corrective action; Good Practices No findings identified.

.Uv.;Q/P6- 4

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD Parformance Area Test Program Obj ective No . TC.1 (Title)

Provida factual information that supports the Performance Evaluation Summ*;ry tha stcrt-up test program due to the status of plant construction is not tully implemented. The test' program is defined, but a meaningful start-up testing has not been started at this time.

)bservation was made of Operational Analysis Department calibration and calays checks along with Instrument Maintenance Department calibrations.

The Start-Up Coordinator position at the site has not presently been filled.

.vv3spg. a

PERFORMANCE EVALUATION.

SUMMARY

Construetion Project BYRON, Test Group Organization erformance Area and Staffing Objective No. TC.2 valuator (s) G. Abrell Parformance Objective Tha test group organization and staffing should ' ensure effective implementation of the test program.

Scope of Evaluation R viewed the Start-Up Manual, FSAR Chapter 14, and SNED Procedures concerned with Pre-Operational Test Review. Conducted interviews with members of the Pre-Op Test Group from the Assistant Superintendent for Administrative Service to a Start-Up Test Engineer . Also interviewed various members of Project Engineering. Observed Minor testing in the field. Reviewed approximately 1/3 of Tech Staff training records.

Conclusion The Parformance Objective is met. There are no findings with respect to the organization and staffing at Byron or PED to support the test program.

.Q/0997Q

l l .

1 PERFORMANCE EVALUATION

SUMMARY

Construction Project

, BYRON Test Group Organization

rformance Area and Staffing Objective No. TC.2 valuator (s) G. Abre11 Areas of weakness and corrective action; Good Practices No findings identified. (See details)

-Q/0997Q/Page 2

PERFORMANCE EVALUATION DETAILS Construction Project BYRO.N Test Group Organization Parformance Area and Staffing Objective No. TC.2 (Title)

Provide factual information that supports the Performance Evaluation Summary A. Test Group Organization at the site is clearly defined by the Start-Up Manual. The Project Engineer Group Organization is also defined.

Working relationships are defined by SNED procedures and the Start-Up Manual.

B. At the ' site discussed the organization for testing with Tech Staff Supervisor, Asst. Superintendent for Administration and Tech Services.

. There are about 40-50 Tech Staff people available for writing and conducting pre-operational tests at the site. At the present, only a small amount of overtime is being worked. The Plant staff is adequate.

At PED the staff is small, but they are able to conduct and coordinate test reviews. Overtime is worked consistently of about 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> per week, plus occasional Saturdays.

2. Based on observation, staff sizes are adequate.

). Permanent station people are used'for the most part to conduct the testing.

C. Test responsibilities are described in writing in the Start-Up Manual.

PED. position responsibilities are described in writing.

F. In PED, no qualifications are described in writing; however, all members have many years of experience and are qualified.

Station personnel are qualified in accordance with program for flushing and testing. Tests are given and records maintained. Reviewed training records for approximately 1/3 of Tech Staff. Flushing Systems training, Start-Up Manual training and Revision training is consistently given.' Other training such as Lubrication and Vibration Analysis is given.

i. Qualifications are maintained by continuous employment in the area of testing activity. The Tech Staff people receive documented training in the area of flushing and Start-up Manual Review.

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'Q/0997Q/Page 3

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD arformance Area Test Group Organization & Staffing Objective No. TC.2 raluetor(s) Abrell/Schumann -

Parformance Objective Test Group Organization and Staffing should ensure effective implementation of the test program.

Scopn of Evaluation R viewed Braidwood Start-Up Manual. Interviews were conducted with Assistant Superintendent for Administrative Services, Senior Operating Engineer, Operating Engineer, Tech Staff Supervisor, Testing Supervisor, Systems Supervisor, Rad Chem Supervisor, and Systems Test Engineer. The Organization, Staffing and experience level of the test organization were also reviewed.

Conclusion The Test Group Staffing is not adequate to support the flushing, testing, and procedure preparation needed for start-up.

/1007Q

}

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD arformance Area Test Group' Organization Obj ective No . TC.2 valuator (s) Abre11/Schumann

~

Areas of weakness and corrective action; Good Practices Finding)

(TC.2-1 The Test Group Staffing and experience is not adequate to support the flushing, testing, and surveillance procedure writing programs necessary for start-up . Additionally the absence of a training department at this time makes it difficult to compensate for the lack of experience.

Corrective Action:

The present technical staff has a cadre of 12 well-experienced supervisory personnel and 19 others, some of whom are experienced. The additional new personnel required for the future testing are being obtained according to the budgeted schedule. Much of the required training for these personnel is being requested from the Production Training Department. Efforts are being made to obtain additional personnel with commercial PWR experience.

The success of these efforts depends on the cooperation of the other Commonwealth Edison stations and departments.

~

The Braidwood procedure writing is aided by the use of Byron procedures as a starting point. Attempts are being made to strengthen the flow of information from Byron to Braidwood.

/1007Qpg. 2

PERFORMANCE EVALUATION DETAILS Constructio BRAIDWOOD

?arformance Area Test Group Organization & Staffing (Title) ~

Objective No. TC.2

'rovida rmmary factual information that supports the Performance Eval uation The Station Organization Charts are available,but filled. ual.

ons are not Start-Up Manual.

Relationship to interfacing organizations are defined in the Procedure and Schedule Preparation.The Staff Build-Up does n or Testing to support Tech Staff needs. There is not a training department Engineer identified is assigned, but not on site; filled, and .

Onefew Shift po hava an ave; rage of six months on site.and onlyEngineers Tech Staff eight NSO's a plant experience experience. but only three or four people have commercia On the Tech Staff, the Flushing Coordinator Pre-Op Health Physicist and Lead Chemist positions .

. Leadare not of training, Staff flush not appear adequate to support the impending size does r oad wo k and test execution, procedure and test procedure writi of the Rad Chem Group is not adequate to monitor water quality of systems prior to flush and the subsequent lay-up period.

Permanent personnel are used to the maximum extent possible .

Positions for Tech Staff are not described in writing .

Experience Documents. and qualification requirements are identified in Tech St aff tion sheets. These requirements are documented on individual qualifica-viewedLeaders.

appeared Thetopersonnel records reviewed and few persons inter-be well qualified.

Group These people were Tech Staff

' level of experience.The majority of the Tech Staff People have a very low not defined in a Tech Staff Procedure.The maintenance of qualificat Unofficially is good for three personnel is absent years and requalification will be r,ea qualification quired if a year. from job performance in the testing area for a b

07epg. 3

PERFORMANCE EVALUATION.

SUMMARY

Construction Project BYRON ,

arformance Area Test Program Objective No. TC.3 raluator(s) C. Schumann .

Performance Objective The test organization should prepare a plan and a schedule that describes the sequence of system or component testing to support major schedule milestones.

Scopa of ' Evaluation Thn evaluation of this area involved the review of documents describing the Test Plan, FSAR, Start-Up Manual and test schedule. Interviews were conducted with personnel responsible for stprt-up testing in each organization or department responsible for start-up testing.

Additionally, a review of the scheduled activities, past, present and future, were conducted.

Conclusion The test plan and schedule is' monitored by experienced qualified personnel. The test schedule describes the sequence of testing for start-up.

=

Q/0999Q m -

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON erformance Area Test Program Objective No. TC.3 valuator (s) C. Schumann Areas of weakness and corrective action; Good Practices No findings identified in this area. (See details) q.u?99Q/Page 2

PERFORMANCE EVALUATION DETAILS Construction Project BYR.ON Performance Area Test Plan Objective No. TC.3 (Title)

Provide factual information that supports the Performance Evaluation summary The Start-Up Group holds meetings the first thing each morning to track status and for problem resolution. This is factored into the schedule on a daily basis. Responsibilities for testing and start-up are defined.

bsponsible Test Engineers are aware of system status and work closely with Project Construction.

9 e

Q/0999Q/Page 3

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PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD 1

rformance Area Test Plan Objective No. TC.3 aluator(s) Chuck Schumann Parformance Obj ective Tha test organization should prepare a plan and a schedule that describes the sequence of system or component testing to support major schedule milestones.

Sc' ope of Evaluation The ovaluation of the area involved review of document describing the Test Plan, FSAR, and Start-Up Manual. Interviews were conducted with those few l personnel responsible for start-up testing.

I l

l Conclusion A start-up coordinator has not been named for the project. A rough approach to a start-up schedule is available in the Technical Staff, but due to the status of plant construction the start up organization is not complete.

iuvaq

PERFORMANCE EVALUATION

SUMMARY

Construction Project

. BRAIDWOOD rformance Area Test Plan Obj ective No . TC.3 sluator(s) Chuck Schumann Sreas of weakness and corrective action; Good Practices No waaknesses identified.

ivi, 1 6* **

i

~

PERFORMANCE EVALUATIsiN DETAILS Construction BRAIDWOOD 3rformance Area Test Plan -

(Title) Obj ec tive No . TC.3 covide ammary factual information that supports the Performance Evaluation inual is test . plan is in place and described as per the FSAR and the Start-U tchnical staff has developed a rough schedulStart-Up . Coordinat The station e for system start-up testing.

alu,ated.

s to the status of plant construction this area could not be completely l

l N'SiiPE 3 1

PERFORMANCE EVALUATION'

SUMMARY

Construction Project BYRON erformance Area System Turnover for Test dbjective No. TC.4 taluator(s) C. Schumann/G. Abrell Performance Objective The construction testing and turnover process should be controlled effectively to ensure that program objectives are met.

Scopn of Evaluation The cvaluation of this area involved the observation of testing in progress , review of the testing schedule, testing done to date, release rate of system for testing both planned and actual and interviews with construction and station personnel responsible for testing.

onclusion

he plan for turnover for systems for testing is well layed out.

he actual implementation of the plan indicates several areas whereHow ever ,

.mprovements can be made.

LOOOQ

, PERFORMANCE EVALUATION

SUMMARY

Construction Project

. BYRON erformance Area System 7trnover for Test Obj e ctive No . TC.4 (21uator(s) C. Schumann, G. Abrell Areas of weakness and corrective action; Good Practices Finding (TC.4-1)

The rate of turnover of equipment to operating can be improved to more -

cdaquately support the start-up schedule. The rate of turnover of equipment for testing should be re-evaluated to assure that it contributes to a balanced, consistent release rate that supports the fuel loading date. Additionally, every effort should be made to ensure that systems are rolcased in total versus in pieces.

Corrective Action:

The rate of Turnover for testing has decreased in the last six months.

Snvercl causes were identified. Those that could be dealt with were addressed as follows: -

1. A field engineer was added to the Startup staff to follow the need for materials , purchasing activities , expediting activities and receiving activities.

2. Sargent & Lundy electrical and mechanical personnel were added to the daily startup meeting to expedite design information. A Project Engineering engineer was added to improve the interface with Westinghouse and other vendors.

3. Consolidated punchlists of items remaining to be completed are being prepared for all systems. This will better identify remaining work, allow for earlier identification of missing materials and better identify remaining design problems.

The rate of turnover will be re-evaluated with respect to fuel load dates Every effort is made to turn over complete systems for test. How ever ,

almost every system will have some minor problems at the time of turnover for test. These problems are negotiated with the Technical Staff before turnover. In many cases months will pass before completion, due to delivery times . Waiting to begin testing until all such items are complete could cause considerable delay in fuel load. A re-evaluation of system

ondition at turnover will be made.

!/1000Q/Page 2

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1 PERFORMANCE EVALUATION DETAILS Construction Project BYRON, 3rformance Area System Turnover for Test Obj e ctive No . TC.4 (Title) govida factual information that supports the Performance Evaluation ~

.inm=ry

. System walkdowns were observed to observe the quality of the program in providing systems that were ready for testing. The schedule for the release of systems was reviewed which indicated weaknesses in the rate of release of systems and the release of only partial systems. Details of release rates follow:

a. As of August 1982, 51 tests scheduled to be started had not been

. released for testing,

b. As of September '82,103 systems had testing completed and none had been turned over to-the station for operations.

l. The details of systems walkdowns are presented in observations of system walkdowns . .

. The scheduling system was reviewed with the Manager of Projects, Supt.

of Construction and various levels of personnel involved. Weaknesses were noted in identification of problem areas and communication of these areas to responsible groups. A total of 12 manhours was spent reviewing inputs and verifying the information.

a. Some departments do not receive nor are they aware of the most recent schedule updates.

~

b. Items indicated as completed are not tracked accurately and credit is-taken for partial installation (TC.1).

c. All people interviewed who are involved in supplying schedule input are knowledgeable and understand the system requirements. How ever ,

they are supplying i'ncomplete information due to schedule pressures.

Q/1000Q/Page 3

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD gformance Area Syster Turnover for Test Objective No. TC.4 91uator(s) Abrell Performance Objective Tha Construction Testing and Turnover Process should be controlled offectively to ensure that program objectives are met.

Scope of Evaluation R;vinwed Braidwood Start-Up' Manual Examined an SSN for Component Cooling System Walked down portions of the Component Cooling System Interviewed the following personnel Project Construction Engineer STE Testing Supervisor (Braidwood Station)

Lead Mechanical QA Supervisor Phillips Getschow Management on Site l Reviewed Generic Procedure for flushing CFP-0 Rev. 2, Generic Procedure

' for initial pump run.

1 Reviewed Braidwood #6353 Letter of 8 April,1982, Quality Requirements for

' Construction Tests.

I Reviewed Braidwood #6490 letter of 10 May,1982, Completion of QP 11-1 for Construction Tests.of Pumps and IC Engines.

Conclusion

' Walkdown for turnover for initial pump run and flushing is not sufficiently structured to ensure the adequacy of the piping support

' system.

Boundaries are not clearly established by these procedures.

i No turnovers have been made for flushing and testing.

11010Q

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD arformance Area System Turnover for Test Obj ec tive No . TC.4 raluator(s) Abrell Araas of weakness and corrective action; Good Practices No' findings identified.

of inadequate proceduresThis issue of potential is identified in TC.5.equipment damage because viu(pi. 2

~

PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD 3rformance Area System Turnover for Test Objective No. TC.4 (Title) rovide factual information that supports the Performance Evaluation ummary he Start-Up Test Manual describes the Construction Testing and Turnover rocess. This is quite similar to the Byron Start-Up Manual which was bcoptable, o systems have been turned over for final flush or pre-operational testing.

turnover for initial Pump Run Construction Test was examined and appeared cceptable.

h Jurisdiction is delineated in the Start-Up Manual for organization l responsibilities.

No tests have been conducted but review of results is described in the f

r Start-Up Manual.

) Start-Up Manual addresses retesting requirements.

DJ System walkdowns are generally conducted by qualified personnel; however, the personnel have no particular expertise in the area of piping support. No guidance is established for evaluating the adequacy of Piping Support. Project Construction Engineer and System Test Engineer use intuition to determine the adequacy of the Piping Supports prior to filling the system'and operating the pumps. One line diagrams l are available for determining hanger location, but engineers are not l obliged to use them in their walkdown.

) Start-Up Manual identifies participants, duties, and I responsibilities. No testing is in progress to evacuate performance.

k No turnover for testing was available. However, turnover for initial pump run and flushing were examined. The system boundaries are not identified by the procedure. Turnover documents contained P& ids which showed the area of the system turned over. Affected lines were circled on the drawing but the boundaries are not clearly defined. P&ID's are marked "For Information Only" despite being an official document.

Procedures require site to use the latest drawing.

h Turnover exceptions were not examined because no systems are turned i over for flushing or testing.

h Integration of Project Resources was not evaluated because of the i absence of activity in this area.

h System cleanliness is a problem throughout the plant and is discussed in more detail in other performance objectives. No testing is in progress.

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T010ypg. 3 l

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PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON

rformance Area Test Procedures and Test Documents Objective No. TC.5 cluator(s) C. Schumann Parformance Objective Tast procedures and test documents should provide appropriate direction and should be used effectively to verify operational and design features of respective systems.

Scopa of Evaluation The evaluation of this area required the review of the FSAR, Test Plan, cnd Tast Procedures. Additionally, interviews were held with System Test Engineers, Construction, Operations and Maintenance personnel responsible for the testing program.

A Conclusion The test procedures and documents provide direction and can be used to verify operational and design features during start-up.

.Q/1902Q

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON irformance rea Test Procedures and Test Documents Objective No. TC.5 sluctor(s) C. Schumann Srcas of weakness and corrective action; Good Practices SSo findings were identified in this area. (See details) l l

l l

l Q/1002Q/Page 2

PERFORMANCE EVALUATION DETAILS Construction Project BYRON Srformance Area Test Procedures and Test Documents Obj ective No . TC.5 (Title)

>rovida factual information that supports the Performance Evaluation

,ummary aview of FSAR, Test Plan and Test Procedures reveal:

.. Necessary technical data is used in the test procedures.

. Test procedures are properly reviewed prior to test and contain the required prerequisites.

i. Tests are performed in accordance with approved procedures.

s. Retesting is cv. ducted when required.

.. The results of testing receive an independent review and approval.

Q/1002Q/Page 3

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD l

aformance Area Test Procedures and Test Documents Obj ective No. TC.5 31uator(s) Abrell/Schumann _

Performance Objective Test procedures ~and Test Documents should provide appropriate direction cnd should be used effectively to verify operational and design features of respective systems.

Scope of Evaluation l Reviewed: Generic Procedures for System Flushing CFP-0 Rev. 2 Initial Pump Run Procedure ClPR-0 Flushing Procedure CFP-CC-01 (Component Cooling)

Flushing Procedure CFP-WZ-01 (A Radwaste System) l Flushing Procedure Byron Steam Generator Blowdown System l@crviewed : Operating Engineer, Tech Staff Supervisor, Testing Supervisor, System Test Engineer, Project Construction Engineer, Rad Chem Supervisor.

Conclusion There are no Pre-Op Test Procedures presently written at this time. The Generic Flush Procedure does not require sufficient detail to preclude equiptent damage. The initial Fucp Run Procedure does not address water quality and water chemistry requirements specified by the Generic Flush Procedure.

f

,/1011Q r

PERFORMANCE EVALUATION S.UMMARY Construction Project BRAIDWOOD .

trformanceIrea Test Procedures and Test Documents _ Obj ective No . TC.5 reluator(s) Abre11/Schumann Armas of weakness and corrective action; Good Practices FINDING The Generic Flushing Procedure CFP-0 Rev. 2 does not (TC.5-1) require sufficient detail in the system specific flush procedures to preclude damage to equipment. Furthermore, initial Pump Run Procedures C1PR-0 permits systems to be filled for long periods of time without meeting the water quality requirements of CFP-0 Rev. 2.

Corrective Action:

The flushing performed to date was conducted by experienced personnel. New personnel are trained before they are certified to perform flushing activities. Because of the addition of many new personnel, the General Flushing l Procedure will be modified by January,1983, to provide l additional guidance. .

l The water chemistry control during and after final acceptance flushing is specified in the present General Flushing Procedure. The initial fill and rough flushing of dirty systems requires suitable but not necessarily high quality water. The Initial Pump Run Procedure will be changed by January, 1983, to include guidance on a suitable source of water for initial filling of the system and guidance on chemistry considerations should a period of wet layup occur prior to the final acceptance flush.

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l/1011Q/pg. 2

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s af p PERFORMANCE EVALUATION DETAILS Construction Project >.' ..' > s

%.- a BRAIDWOOD t

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'erformance Area Test Procedures and Test Documents Objective No. TC.5 ' LC - ' s (Title) [ ' * .. L.

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lrovide factual information that supports the Performance Evaluation ' p f ,. .

,ummary ,

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.. The necessary technical data are not necessarily used in the test procedure preparation.

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Reviewed Flush Procedure CFP-CC01 Component Cooling System. The f. ' . V -

flushing procedure provides for a suction filter ahead of the B .

Component Cooling Pump. The flushing procedure did not require the .-

differential pressure across the filter to be read. The procedure did  %, .. -

not identify differential pressure limit across the filter, the flow [ t -

limit on the filter, or the limiting pump suction pressure. The .' -

testing engineer who wrote the tests was aware of these limitations but "s:- '. E..f~ 1 he did not include them in the procedure because that level of detail ,g l

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was not required by the generic flushing procedure CFP-0 Rev. 2.  :

The limiting pump flow was designated as 4800 GPM, but all flow . ' 11. , ' '

instrumentation was removed prior to flushing the system. The - /, :

procedure did not identify how the system flow was to be estimated nor '.T'; ;N how the flow was to be adjusted. The Test Engineer indicated he would - l. .

use the pump curve to estimate system flow and would adjust pump curve a; < ". ,

x. c7 's

, .i to estimate system flow and would adjust heat exchanger outlet s alves and various drain valves to achieve the flow. This was not in the s- ": . P procedure because the generic procedure did not require the level of Vi,2 -

detail. g " 1 ., .

af ' ..

A limitation of 1050F was identified as the system temperature limit, DY:4 [i but no instrument was identified to determine system temperature. jg E u e The test procedure required the system to be filled and vented, but the 1.""

source of fill water and the location and number of the vent valves was - ;, ' -* f not identified in the procedure because the generic procedure did not  ? <, E q j require this detail. V. j - 2 7, #-

. ?.b The genert.c flush procedure required that boundaries be clearly " C.':.?,

identified. The flushing procedure did not identify system isolation  ;^.'; < .

valves at the flushing boundaries. " ; .G Additional procedures were reviewed and each had a similar level of detail. .@".- E.lc., Me ,y(.

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PERFORMANCE EVALUATION DETAILS Construction Project u : - ~

I, BRAIDWOOD

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g _ % ' ". -j c erformance Area Test Procedures and Test Documents Objective No. TC.5 T-(Title)  %- ,. I $ ' I 9, . .% i n .M . - - , ,

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rovide factual information that supports the Performance Evaluation , .',s..

ummary .] ,

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A test engineer said that fill and vent details of the flush procedure 'C.! .

were irrelevent because the system is filled and vented and operating ,-

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long befora the flush begins. The system is actually filled and vented ,. M;, '  ;

by the initial pump run procedure. When this procedure was reviewed -

. .gf the following aspects were noted. .; ; ?] .- 34

,; i < = ,4 No details of filling and venting is required in order to assure that 7 12.. ,$ .

system is adequately vented prior to pump start. ~ yy l - ?'

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The water quality of the initial fill is not specified making it } g, ,d.

possible to use water of a less quality than that specified for the y4 ~1Nij ..

system by the generic flush procedure. f;q J p,

>, .,o e There is not a requirement for the chemist to test the fill water for this system.

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There is no requirement to consult the station chemist for layup water chemistry recommendations. The Component Cooling System has been 34:.l_T'"'

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operated for over five months with no water chemistry limits d-*Y.- /

established. This system has very strict Westinghouse corrosion i 3..' ;- f p inhibitor requirements.

• tp' ;.1 .

. Flush procedures are available in advance of their intended use, but 1.$ i [;I the details are so limited that meaningful preparation and training is ' #1 g..' .$ '

precluded. (See details above) @.. . . , , ,

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. The flush procedure describes objectives, prerequisites, and acceptance '

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criteria; however, system boundaries are not defined by the procedures. .. . . .

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Flush procedures receive the prescribed review before approval; ~%

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p. .,' .

however, the approval levels required are only the Test Supervisor .

(below Tech Staff Supervisor) and the Project Construction Engineer

9 [r-(3rd level in Project Construction) ': <

-g _g3 L No formal flush procedures have been v.acuted. h.9 - c v -

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. The re-entry system provides for re-flush determination. No flush has ;f.,y. ; ., - t .b been done. No tests are written or performed. 3.f j.;;;&, l

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PERFORMANCE EVALUATION DETAILS Construction Project BRAIDWOOD erformance Area Test Procedures and Test Documents Objective No. TC.5 (Title) rovide factual information that supports the Performance Evaluation ummary

. The flush results are reviewed and approved by a higher level of management than that conducting the flush. The Pre-Op Test results are reviewed and approved by the same individuals approving the test procedure; however, these are independent of the personnel performing ' '

the test.

9 9

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E PERFORMANCE EVALUATION.

SUMMARY

Construction Project '

=

BYRON. 2 6

aim

_2 trformance Area System Status Controls Objective No. TC.6 raluator(s) G. Abre11 $

s=

Performance Objective -

a A method should exist to identify the status of each system or component ==

and the organization holding control or jurisdiction over that system or --

component to prevent interference and ensure equipment and personnel safety. _

_-iii ;

2

=

N Scope of Evaluation d

Reviewed System Status Control described in the Byron Start-Up Manual.

Interviewed Shift Engineer, and Tech Staff Engineer. Examined equipment g in the field. Reviewed System Status Notice (SSN) in the Shift Engineer's _-

office. 4

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Conclusion g I

Performance objectives are met. There are no findings in this area.

There have been violations of the re-entry system in the past, but much 3 effort is b:ing made to ensure that all parties associated with the g testing aware of tests. Violations of SSN could be minimized by iEE better cipline by the Project Construction Engineers and a better underscanding of the system by craft personnel. g

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Q/1003Q 3

PERFORMANCE EVALUATION

SUMMARY

Construction Project BYRON trformance Area System Status Controls Objective No. TC.6 raluator(s) G. Abrell

(

Areas of weakness and corrective action; Good Practices No findings identified in this area. (See details)

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'Q/ LOO 3Q/Page 2

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PERFORMANCE EVALUATION DETAILS Construction Project Y

~

BYRON

,=

'erformance Area System Status Controls Objective No. TC.6 -

(Title) _

^

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'rovide factual information that supports the Performance Evaluation -

,ummary ,_

t. Discussed policies and procedures for plant status controls during =.

testing with Pre-op Test Coordinator, System Test Engineer (SIE) and

• Shift Engineer. Reviewed status controls described in Start-up _

Manual. Based on interviews, the people understand the system and how m it should work. There are instances in which the control system has _

broken ~down and work has been done or. the system without authorization of the STE.

. The SSN system ensures current knowledge of the status of systems. A drawing in the file shows portions of the syste~s m in test and the Drawing is stamped and signed.

~

boundaries. Shift Engineer -

periodically checks SSN drawings to verify they are the latest.

By procedure, Construction must be authorized to work on a system by

~

the STE. Shift Engineer calls STE for any Construction Action Request -

(CAR) before taking any part of system out of service. STE and Shift Engineer said this was the case. -

1 System Status (i.e. , Construction Control, operated by Station and [

controlled by Construction, operated and controlled by the Station and '

turned over for operation by Station) are defined by the Start-Up Manual. Personnel involved with the Station understood the system.

_1

. A workable system is in place to handle temporary field modifications i through the CAR and SSN System. .

. Jurisidiction and control is clearly defined, but there are still -

instances of violations. There appears to be a need for training of -

the crafts to ensure they understand the indicators. This was the ,

opinion of a Shift Engineer that craft people do as they are told and __

few recognize system status indicators.  :

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Q/1003Q/Page 3

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD rformance Area System Status Indicators Objective No. TC.6 aluator(s) Abrell Performance Objective A method should exit to identify the Status of each system or component and the organization holding control or jurisdiction over that system or component to prevent interference and ensure equipment and pers. .

Scope of' Evaluation Reviewed Braidwood Start-Up Manual Walked through the plant Interviewed Project Construction Engineer, STE, Testing Supervisor, Lead Mechanical QA Engineer Examined various directives, and an SSN for Component Cooling Conclusion Few systems are turned over for flushing or testing. The system established appears to be adequate, but implementation could not be effectively evaluated at this time.

/

O h%

PERFORMANCE EVALUATION

SUMMARY

Construction Project BRAIDWOOD rformance rea System Status Controls Objective No. TC.6 aluator(s) Abrell Areas of weakness and corrective action; Good Practices No finding identified. (See details)

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7 PERFORMANCE EVALUATION DETAILS Construction Project -

BRAIDWOOD

'erformance Area System Status Controls Obj ective No. TC.6 (Title)

Tovide factual information that supports the Performance Evaluation

ummary

,e this point in time, few systems have been turned over to operating. For .

he most part, the only system with status controls indicated are operated .

.y station personnel at the direction of Project Construction.

.. No testing or flushing has taken place. Procedures appear to be implemented for those components operated at direction of Project Construction. 7 .

. The Start-Up Manual describes that system status conto 1. For plant observations, system is implemented.

. Start-Up Manual identifies authorized individuals controlling the SSN System.

. Portions of the system affected by SSN are identified by Project i

Construction Engineer. Operating personnel tag the system. -

[

. The flushing procedure identifies necessary additions and removals necessary for the flush. Jumpers and lifted leads etc. are to be handled in accordance with Braidwood Administrative Procedures s This procedure is not written for Braidwood.

. The SSN System defines construction controls after turnover. There are no systems affected at this time.

. No flushing or testing procedures have been executed at this time.

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_ _ _ _ _ . _ _ _ _ . . _ __