IR 05000456/1984012

SALP Board Repts 50-456/84-12 & 50-457/84-12 for Jan 1983 - June 1984

ML20204H374
Person / Time
Site:	Braidwood
Issue date:	11/06/1984
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20204H321	List: IR 05000456/1984012 ML20204H317
References
50-456-84-12, 50-457-84-12, NUDOCS 8411120272
Download: ML20204H374 (32)

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- SALP 4

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. SALP BOARD REPOR U. S. NUCLEAR REGULATORY COMMISSION

REGION III

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SYSTEMATIC ASSESSMENT-0F LICENSEE PERFORMANCE 50-456/84-12; 50-457/84-12 Cosmonwealth Edison Company Braidwood Nuclear Station Units 1 and 2-

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' January 1,1983 through June 30, l'384

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L INTRODUCTION fe ' The : Systematic- Assessment' of . Licensee Performance (SALP) program is an-integrated NRC staff effort to' collect available observations and data.on a periodic. basis:and to evaluate licensee performance based.upon this information. .SALP is supplemental to normal regulatory processes-Lused to ensure' compliance to NRC rules and regulation SALP is intended lto be-sufficiently diagnostic to provide a rational basis- for allocating 1 NRC resources ~ and to provide: meaningful guidance to the licensee's manage-ment to promote quality and safety: of plant construction and operatio LA.NRC;SALP. Board,' composed of staff members listed below, met on September 12, 1984, to review the collection of performance observations and data;to assess the licensee performance in accordance.with the guidance-in NRC Manual Chapter.0516, " Systematic Assessment of Licensee Performance."

A-summary'of the guidance and evaluation criteria is provided in Section II

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of this. repor This. report'is the SALP Board's assessment of the licensee's safety

performance at.Braidwood Nuclear Station for the period January 1, 1983

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through_ June 30, 198 SALP Board for Braidwood:

J. A. Hind, Director, Division of Radiological Safety and Safeguards (DRSS)

eC. E2 Norelius, Director, Division of Reactor Projects (DRP)

R. _ FJ Warnick, Chief,1 Reactor Projects Branch 1 Wi'L. Forney, Chief, Reactor I ojects Section lA

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L. ~ G. - McGregor, Senior. Resident _ Inspector, Braidwood R. D. Schulz, Senior. Resident Inspector, Braidwood

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J.= E. Foster, Compliance Specialist, TSS'

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E.:R. Schweibinz, Chief, Technical Support Staff _(TSS)

.F. C. Hawkins, Chief, Quality Assurance Programs Section,.DRS JR.' L. Spessard, Director,~ Division of Reactor Safety (DRS)

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L. R.L Greger,- Chief, Facilities Radiation Protection Section, DRSS

,L~.LA. Reyes,' Chief, Test-Programs Section, DRS

.- .J.-Stevens, Licensing Project Manager, NRR

H.:L. Thompson, Director, Division of Human Factors Safety, NRR L 'W. Gammill, Chief, METB,< Division of Systems Integration, NRR D.

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I CRITERIA

.The. licensee performance,is assessed in selected functional areas depending whether the facility is in a construction, pre-operational

-.or. operating phas Each functional area normally represents areas-significant:to nuclear safety and the environment, and are normal programmatic areas. _Some functional areas may not be assessed because

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of'little or no licensee activities' or lack of meaningful observation "Special" areas:may be added to highlight significant observation i One or.nore,0f the.following evaluation criteria were used to assess  ;

each functional are . Management involvement in assuring quality

Approach to resolution of technical issues from a safety standpoint Responsiveness to NRC initiatives

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- 4.' Enforcement history 5 ~.' Reporting and' analysis of reportable events

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, Staffing (including management)

- Training' effectiveness.and qualificatio : However, the SALP Board'is not limited to these criteria and others

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may have been used where' appropriat Based upon the-SALP Board assessment each functional area evaluated m is classified'into one of three performance categorie The definition of these performance categories is:

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LCategory-1: Reduced NRC attention may be appropriate. . Licensee manage-

' ment attentien and involvement are aggressive and oriented toward

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! nuclear _ safety;. licensee resources are ample and effectively used so

[ .that a high level of performance'with respect to operational safety or

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Econstruction.is being achieved.

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Category 2: lNRC attention should be maintained at normal level Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are: reasonably effective such that satisfactory performance with respect to operational safety or construction is being achieved.

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. Category 3: Both NRC and licensee attention should be increased.

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Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee sresources appear to be strained or not effectively used so that

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minimally satisfactory performance with respect to operational 1 safety or construction is being achieved.

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• Trend: The performance gradient over the course of the SALP assessment perio f c

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e III. SUMARY OF RESULTS -

Overall.the licensee's performance was found to be acceptable. During the

first part of the SALP. period the licensee's performance with. regard to

. implementing corrective actions to resolve known problems and nonconforming conditions was of significant concern to the NR Toward the end of the SALP period'the licensee's performance improved considerably and, in most cases,.the licensee's recent corrective actions have been responsive and

. adequat Trend Within Rating Last Rating This the Functional Area Period Period Period

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- Soils and Foundation NR* NR None Containment and Other Safety-Related Structures 2 2 Same

- . Piping Systems &

Supports .

2 3 Same Safety-Related Components 3 3 Same Support Systems 2 2 Same Electrical Power Supply and Distribution 2 2 Same . Instrumentation and Control Systems NR 2 Same Quality Assurance and Administrative Controls- 3 3 Improved Licensing Activities 1 2 Improved

' Construction and Preopera--

.. tional Testing NR 2 Same Health Physics NR 2 Same

• NRl= not rated because of lack of activity in the area.

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[IV.j PERFORMANCE ANALYSIS:

_ ' Soils and Foundations Analysis-No? inspections were performed in this area during this SAL . period. All major soils and foundatica work was completed i , 198 . Conclusion

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.The licensee is not rated in this are . Board' Recommendations Non ~ Containment and Other Safety-Related Structures- ' Analysis This . functional area.was examined during six inspection A portion of one inspection.was in response to allegation 'The other inspections were oftthe "as built" conditions and

.related record review for both welded and bolted structural steel connections, anchorage-verification of NSSS equipment, steam generator and reactor coolant pump. supports, actions

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related to 10 CFR 50.55(e) items and IE Bulletins, torque testing of high strength-bolting, and examination of quality assurance record i Three items of noncompliance were identified as follows:

, . Severity Level IV -Modifications to Braidwood support

- steel?"S" type connections were completed which lacked

' engineering reviews by the Architect Engineer and Commonwealth Edison Nuclear Engineering Division.

(Inspection Report Nos. 50-456/83-02; 50-457/83-02)

i Severity Level .IV - The installation contractor's Quality Assurance Program lacked required fit-up inspections for safety related structural steel members joined by weldin + (Inspection. Report Nos. 50-456/84-08; 50-457/84-08)

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~ : Severity Level ~IV . The licensee failed to take adequate corrective actions when it became known that the installation

contractor's welding activities were performed without docu-  ;

mented in process inspections for pre-heat, interpass tempera-ture, weld position, weld bead layering and interpass grindin (Inspection Report Nos. 50-456/84-08; 50-457/84-08)

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4 Although the three noncompliances.were identifled during the SALP 4 period, they concern violations that occurred prior to

'the'SALP 4 period. The licensee has since taken corrective

. actions and these violations are not-indicative of current work

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Lpractice .The inspectors also had concerns, identified in inspection report

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No. 50-456/84-08, with regard to the bolting torque values'of structural steel members. The licensee is performing some

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reinspections to assure that.all structural..high strength bolting'has acceptable. torque value ~

- As a result of NRC inspections conducted during the previous SALP reporting period (SALP 3) which -identified NSSS bolting defi-

- ciencies, a new contract agreement was issued by the licensee for

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zthe realignment, rework, and replacement of NSSS supports. To

- date, the licensee-has identified approximately 112. nonconforming

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conditions. The bolting contractor is doing an excellent job .and

, the' corrective =tions- initiated by.the licensee during this

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period appear-to be effective.

In general,f the three noncompliances' indicated a need for improve-ment in the licensee's monitoring of work activities. The licensee's

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documentation of 112.nonconformance reports indicate that while a number of nonconforming conditions existed, the licensee's involve-ment'in identifying existing problems has improved. The assignment

of-resources and the. resolution of problems have been satisfactory

during the last few months of the SALP perio An' allegation was received and has been substantiated regarding -

inadequate welding of structural steel columns supporting concrete

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-block walis. The licensee docuaiented the lack of structural Linspections for the structural steel columns in 50.55(e) reports

' dated November-19, 1982, May 7, 1984, and July 3, 198 The

, reports. failed to acknowledge.the existence of. actual weld defi-

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.. ~ciencies. _- Following discuss _ ions ~with the NRC,.the licensee y a . decided to' inspect the: structural steel column welds-(compared to P ..i the' originally proposed inspection of a sample) and make the is _ necessary repairs or,take other corrective actions as appropriat Although=the licensee's control of the original installation and the' handling of the nonconforming conditions were matters of a_ ,

concern, recent corrective action commitments are considered to ,

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be appropriat .~ Conclusion

- The-licensee 11s rated Category 2 in this. area. - This is the same rating:as was given in the previous assessment perio ". . .

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Licensee.perfornia'nce has remained the same during this assess-

- ment period.

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'3 . Board Recommendations

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.None;

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?? Piping Systems and Supports

' Analysis This-functional area was examined during portions of eight

' inspection The inspections examined design control for small and large bore piping, material control and identification, visual examinations, related record review for completed piping welds,

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review 'of completed documentation packages for pipe welds, obser-vation of pipe welding, actions related to 10 CFR 50.55(e) items,

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IE Bulletins, and an independent measurement inspection conducted

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-by the NRC Mobile Nondestructive Examination (NDE) Laborator Items of noncompliance identified during these inspections are

.as'follows: Severity Level IV - Six examples were identified of failure to control the site designed small bore (2" and under)

process and instrument piping systems. (Inspection Report Nos. 50-456/83-09; 50-457/83-09)

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= Severity Level IV - Adequate measures had not been established to control field changes to drawings being made during the installation of ASME Boiler and Pressure i Vessel. Code, Section.III, Class 2 and 3, Small Bore Piping (2" and under). (Inspection Report No /83-09; 50-457/83-09) Severity Level IV - The licensee failed to control a shipment of " S/80, SA-312 Type 304, ASME Boiler and Pressure Vessel Code,Section III Class 1 pipe, as the pipe was installed without material test reports or records of receiving and receipt inspectio (Inspection Report Nos. 50-456/83-09;.50-457/83-09)

- Severity Level IV - The licensee failed to prescribe in-documented instructions', procedures, or drawings a clearance criteria for safety-related-large bore pipe in relation to other items such as HVAC components, electrical conduit, cable trays, equipment or other pipin (Inspection Report Nos. 50-456/83-09; 50-457/83-09)

'Severit'y Level.lv - The licensee failed to properly identify,

' through inspection and required documentation, that the required ASTM A572 Grade 50 plate material was actually installed in pipe whip restraints. The material installed was ASME SA-516 Grade 60. (Inspection Report Nos. 50-456/84-09; 50-457/84-09) Norcompliance - Inspection records verifying correct piping material installation for all piping components did not exis The severity level of this noncompliance will be determined

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after the NRC receives information regarding the number of incorrect or indeterminate installed components. (Inspection Report Nos. 50-456/83-09; 50-457/83-09) Severity Level IV - Pipe weld radiographs disclosed that

. pipe welds were identified as containing rejectable base metal indications but were not reported on nonconformance report (Inspection Report Nos. 50-456/84-05; 50-457/84-05) _ Severity Level IV'- Two examples of nonconforming condi-tions in radiographs were identifie (1) Radiographs containing zones of welds with incomplete fusion and cracks were not rejecte (2) An area of weld drop through, which exceeded the density requirements, was not rejected. (Inspection Report Nos. 50-456/84-05; 50-457/84-05) Severity Level IV - Radiographs disclosed:

(1) Three welds contained penetrameters improperly placed in the area of interes (2) Mechanical or chemical blemishes that could obscure discontinuitie (3) Degenerated film quality from inadequate fixer removal which destroyed archival quality standard '(Inspection Report Nos. 50-456/84-05; 50-457/84-05)

Noncompliances a, b, and d. identified that some QA Program requirements were being bypassed and prevented the timely identi-fication of nonconforming condition Craft personnel had been permitted to " field run" small bore. pipe without adequate engi-neering and quality controls. As a result, design engineers would have a difficult time determining the adequacy of field installations. In addition, errors in the hanger design calcu-lations indicated inadequacies in the piping hanger progra After the NRC inspection, the licensee contractor imposed a stop work. order on the pipe support installation work. All Class 2 and 3 small bore piping is being examined by the licensee to determine the adequacy of the "as-built" condition in relation to design requirement Noncompliance c. identified that material of unknown quality had been released and installed in safety-related piping system After NRC identification, the licensee committed to identify the location of the pipe installed in safety-related systems and will inspect'the pipe, including performing wall thickness measurement ,

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! Noncompliance e. was considered to be an isolated case and

. material substitutions for whip rastraints are being adequately controlle Noncompliance f. revealed a lack of records assuring that the correct piping components were installed in safety-related systems for the majority of piping components. This. item was considered ~significant since numerous pieces of pressure boundary

. piping were of indeterminate quality and this condition was not identified by the licensee or contracto Enforcement conferences were held on August 16, 1983, December. 20, 1983, and March 7, 1984, and a Management Meeting was held on October 24, 1983 to discuss violations in the' piping and HVAC areas identified in Inspection Report Number 83-09. Based on these meetings, the licensee committed to perform a 100% inspection program to assure that critical pressure boundary piping systems contain.only material that meets design requirements. The 100% inspection effort has ,

identified numerous items which do not meet ASME Code requirements, including minimum wall violation Noncompliances g., h., and i. were identified by an independent verification inspection conducted by the NRC Mobile Nondestructive Examination Laboratory. Sixty-five complete sets of field weld radiographs were reviewed and compared with the corresponding reader sheets. This comparison reveals several significant deficiencies including rejectable welds that had been accepted by the licensee. The NRC also performed nondestructive examinations (146 weldments, 23 pipe welds, and 26 anchor bolts) in whicn no-significant problems were identifie '

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The licensee organization apparently lacked experienced personnel to identify the deficiencies in this are In June 1984 the

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licensee transferred experienced personnel from other sites and assigned key personnelEto piping management positions. These changes have been instrumental in upgrading the piping contractor

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and have resulted in major revisions to the piping progra However, the experienced personnel have had to spend a considerable amount of time in corrective action programs with regard to past installation and quality assurance deficiencie The corrective actions by the licensee, if properly implemented,

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should assure that critical pressure boundary piping systems contain~only materials that meet design' requirements and that the small bore piping has been routed in accordance with acceptable design criteri The Braidwood Construction Assessment Program (BCAP), which

' involves considerable licensee resources, has been developed to resolve program deficiencies (reference Section H.). One objective of the BCAP is to verify, where past construction problems have been identified which resulted in significant corrections, that such corrective actions have been adequately implemented and docu-mente . - -. .- - . . _ . . - . - _ . , - . --.

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' Conclusion The licensee -is rated Category 3 in this area. This is a lower rating than was given in the previous assessment period and is reflective of the enforcement history in this area and the failure of the licensee to identify and provide adequate and timely resolu-tion of significant deficient condition Although the rating is lower, the licensee's performance at the end of the assessment period was the same as at the beginnin . Board Recommendations

'It'is recommended that NRC and CECO closely follow the BCAP effort and overview the corrective action program Safety Related Components Analysis This functional area was examined during portions of nine inspec-tions. These inspections included examinations of the records related to the installation and quality of the steam generators, reactor coolant pumps, pressurizers, RHR pumps, a major back-fit inspection program, design reviews, protection and cleanliness of safety-related equipment. control of welding filler metal, bolting of safety-related equi;' ment, post weld heat treatment, preventive maintenance, spent fuel storage racks, review of potential missile sources near the auxiliary feedwater pumps, and the adequacy of the auxiliary feedwater pump lubricating oil systeni. Five items of noncompliance identified during these inspections are as follows: Severity Level IV - The licensee failed to perform a design "as built" review or an Engineering Change Notice (ECN) to assure that the field modifications completed during ii'tial placement of the Safety Injection System Accumulator tanks were consistent with the original design requirement (Inspection Report Nos. 50-456/83-02; 50-457/83-02) Severity Level V - An informal speed letter issued on

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February 16, 1979 became the only document involved in

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the field-modification for bolting the steam generator lateral frame support columns in plac (Inspection Report Nos. 50-456/83-02; 50-457/83-02) Severity Level V-- The licensee failed to conduct inspections or surveillances of work efforts assigned to contractors to assure adequate protection of safety-related equipmen (Inspection Report Nos. 50-456/83-08; 50-457/83-08)

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6 - Severity Level IV - Nine filler metal withdrawal authoriza-tion-forms documented the release of E7018 weld rod for electrical cable pan welding when specifications required the use of E60 series weld rod. (Inspection Report No /84-13; 50-457/84-13) Severity Level IV - The licensee failed to report noncor) forming conditions identified in the "back fit" inspection progra (Inspection Report Nos'. 50-456/83-07; 50-457/83-07)

Noncompliances a. and b. related to the licensee's failure to properly review, approve and document design changes which affected the installation of the low pressure safety injection system (accumulators) and the support columns for the steam generator lateral support Noncompliance c. gives three examples of the licensee's failure to protect equipment. One of the examples was the lack of quality inspections on the Unit 1 accumulator tanks over a period of six year Five other inspection reports document NRC concerns of the licensees' failure to prevent or report damage to the spent fuel racks, containment air coolers, and safety-related battery banks for' Units 1 and 2. A lack of internal cleanliness inspec-tions for safety-related components and the lack of procedures to

. protect equipment after the system had been turned over to plant operations were also identified. The failure to adequately protect installed equipment was also identified in the previous SALP

+ . perio As'a result of meetings with the Resident Inspectors, the licensee began a reinspection program to ensure that the internals of safety-related equipment have not been damaged and do not contain foreign materia Another area of concern involved the proper maintenance of elec-trical and mechanical equipment. Mechanical equipment quality control field inspections were not extensive enough to assure that mechanical equipment was being properly maintained. Reviews were not performed to substantiate that electrical equipment was being properly maintained in accordance with manufacturer's recommendations.

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Noncompliance d. and Inspection Report No. 50-456/84-08 identified weld rod control problems and NRC concerns that the licensee failed to adequately monitor.the type of weld filler metal used to install safety-related cable pan Noncompliance e. resulted from an NRC follow-up inspection which documented additional discrepancies in the licensee's "back fit inspection program". The "back fit inspection program" was committed to by the licensee during the previous SALP period because of past construction deficiencies in the installation,

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documentation and protection of safety-related equipmen These

, .past deficiencies had resulted-in a Civil Penalt In response to.the Civil Penalty, Commonwealth Edison Company stated on April 4,

-1983, that comprehensive reviews of contractor performance had been '

a conducted. All site contractors were reviewed and substantive changes were made in several contractors-organizations and proce-dures. A major site QALaudit was advanced in time and increased lin scope.

-The new' installation procedures contain appropriate inspection forms :to document all necessary nomenclature, engineering and

.constructioni information (such as bolt torquing), and a variable zlist of quality control points. These entries required construc-

' tion _ inspection and sign off, quality ' control inspection and sign

- off,'and an optional hold point for the. licensee's Quality Assurance Eto witness and. sign. The NRC. inspector examined one element

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(thread engagement) on some safety-related equipment which-had been completed by the "back fit inspection program",and found several discrepancies. Additional problems were identified'

relating .to -inadequate hold-down bolting of four 25,000 gallon

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and two 50,000 gallon emergency diesel fuel oil storage tank These tanks were installed in 1976 and 1977 without installation

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procedures or records.

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Even though the licensee had completed substantive changes in site

. contractors organizations and procedures, the involvement of CECO

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management.and the implementation of their corrective action J program did not achieve fully satisfactory result The' deficient reviews and inadequate approvals and verification .

of design changes -indicate repetitive weaknesses in management implementation of 10 CFR 50, Appendix B. The corrective action responses Eto items of noncompliance were generally lacking in

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thoroughness and depth and often required repeated written communi- ~

catio'n and working level . meetings to obtain acceptable resolution The licensee's approach to resoluticn of technical issues or items

'of noncompliance was often inadequate.

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-Within the last few months of the SALP period, site management has taken steps to provide timely corrective actions and to s .

. recognize. existing problems.

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w Conclusion The licensee is' rated Category 3 in this area, which is the same

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rating as_the previous assessment period. This rating was assigned after considerable discussion of the mixed level of

< - performance during.this assessment period. For the first ten

< months of this SALP period the licensee's major work effort was

'in corrective actions associated with the "back fit inspection program" .~ During the latter portion of this SALP period significant improvements were achieved in the area of protec-tion of safety-related equipment. Licensee performance has

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remained the same during this assessment period.

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. Board ~ Recommendations

.The Board recommends that licensee and NRC attention. continue at

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Pa high. level in this area with goals of completing the corrective

. actions, reducing nonconforming conditions, and providing resolu-tion of.NRC concern 'The Board notes that subsequent to the end of the SALP period, the-

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l licensee-identified.other examples of safety-related components containing!

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foreign materia Support' Systems-

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1 ' Analysis 1This functiona1Larea was examined in portions of four inspection The inspections included reviews of the Heating, Ventilation, and

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-Air Conditioning.(HVAC) Systems, Fire Protection and Detection Systems, undersized anchor-bolts, and allegations. These inspec-um- ,

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tions revealed onefitem of noncompliance and one deviation as

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follows: Severity Level IV - The licensee failed to adequately control

- the installation of HVAC components in the areas of fit-up,

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. welding,'and use of the correct welding filler. material'.

(Inspection. Report Nos. 50-456/83-09; 50-457/83-09)-

b.- A deviation from-Appendix R of 10 CFR 50 was identified (Inspection Report No. 50-456/84-06) in that safety-related class L1E DC control cables from both redundant power supplies were positioned within fifteen feet of each other in the lower

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cable spreading room without the required fire protection

~ features. In addition, a number of other items which were in disagreement with the Braidwood Fire Protection Report were brought'to the attention of the licensee. These discrepancies indicate the licensee was'not thorough in' assuring plant-design was:in agreement'with their Fire Protection Repor With regard to noncompliance a, prior to NRC inspection 83-09 the

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licensee identified numerous hardware deficiencies which occurred

.during installation including configuration deficiencies and over

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6,000 welding' defects in the HVAC area, resulting in a 100%

P inspection program, and a major repair program. The lack of early

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inspections of hardware resulted in the delayed identification of-i these repetitive nonconforming conditions. Licensee corrective actions to the item of noncompliance included stopping the wor A-subsequent NRC' inspection was conducted to address allegations

' 'regarding deficiencies'in'the design and installation of the Braidwood HVAC syste Nonconformance reports and discussions

.with personnel indicated that much of the welding on the HVAC system did not meet specifications or code requirements, that i

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welding symbols on the drawings were misinterpreted, and that

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inspections were not performed in a timely manner if at al ~ The inspection into the alleged deficiencies resulted in seven

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of the nine allegations being substantiated;.however, the licensee has taken adequate corrective action and these condi-tions no longer exis The observations and findings in this functional area indicate that although initial control of HVAC installation (prior to

'this SALP period) failed to provide prompt identification of program weaknesses, the overall performance of the licensee during this assessment period was satisfactory. Management has been involved and has implemented a revised HVAC welding program, resources appear to be adequate, personnel have been trained, and records and record control systems are in place, which should ensure tnat installed components meet code and design specifica-tions. The licensee has generally been responsive to NRC concerns identified during inspection . Conclusion The licensee is rated Category 2 in this area, which is the same as the previous assessment period. Licensee performance has remained the same during this assessment perio . Board Recommendations Non F. Electrical Power Supply and Distribution . Analysis Licensee activities were observed in this area during three inspections and portions of seven other inspections. The areas inspected include: equipment installation activities, equipment receipt reports, storage and maintenance records, equipment and protective' relay settings, equipment seismic requirements, cable

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receipt reports, cable installations, terminations, review of procedures and inspection and test record Five items of noncom-

- pliance were' identified as follows:

_ _ Severity ~ Level IV - The licensee failed to assure that criteria for tightening electrical connections were incor-porated into Electrical Specifications F/L 2790 and the contractors' work and inspection procedures. (Inspection Report No. -50-456/83-18) Severity Level IV - Six examples, with subparts, were identified where the contractor failed to establish adequate procedures or instructions for the installation and inspec-tion activities affecting safety-related electrical equipmen (Inspection Report No. 50-456/83-18)

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'c'. ; Severity Level _I'V .- Five examples,- with subparts, were

' identified where the contractor failed to perform adequate b ,

-inspections. (Inspection Report No. 50-456/83-18)

. .'d . Severity. Level V - Two examples were identified where the licensee failed to establish measures to control the storage

"

and preservation of electrical material and equipmen ..(Inspection-Report No.~ 50-456/83-18)

'

- ' Severity Level IV - The licensee ~ failed to provide the NRC with documentation to establish the basis for the design

. change to the 125 volt D.C. Safety-related battery room walls. (Inspection Report No. 50-456/84-06)

i - These noncompliances contained numerous examples of procedure deficiencies, lack of timely quality control inspections on

- installed electrical items, and lack of timely closeout of inspec-

-

,

-

tion correction reports (ICRs) and nonconformance reports (NCRs).

, On May 5,1984, a working meeting between Regional Staff-and -

Commonwealth Edison Company (CECO) was conducted-in the Region III Offic The purpose of this meeting was to review the status of

. the licensee's commitments'regarding these noncompliances and to establish schedules for the closeout of the outstanding ICRs and

. - NCRs, and for the reduction of the backlog of quality control inspections. Cable pulling activities were suspended from May 10-18,

. 1984, after the licensee was informed of their failure to meet

. corrective action commitment .

< As a result of both NRC and CECO concerns, the contractor's engineering and document control staff under the Project Engineer was increased from 33 to 61 personnel. -Also, the contractor's

, ; quality control staff was increased from 25 to 87 personnel. This-increase of the quality control staff included the replacement of

- the QC Manager.and the hiring of additional supervisory personnel, including an Assistant QC Manager. To increase the contractor's

,

. self-audit capabilities, the number of Quality Assurance Engineers was increased from 1 to As a result'of concerns with L. K. Comstock QC records system (missing reports, incomplete reports, reports misfiled, etc.),

-

the licensee instituted a QC. records re-verification program.-

<m s

- The lack of adequate and timely corrective actions to resolve

.

'

identified problems reflects on the performance and thoroughness

-

.of: licensee management and supervision during the early and middle

- part of the SALP period. At the end of the SALP period licensee

.

'

corrective actions were more timely and more comprehensiv . 16

<;

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. ,.

.

,

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' Conclusion

The licenseeLis rated' Category 2 in-this are This is the 1- ..same rating as the-previous SALP period. Improvement was

'

- noted-at the end of the SALP period. - Licensee performance has remained.the-same during this assessment perio . ! Board Recommendations Non The' Board notes-that subsequent to this SALP period, an electrical ateam_ inspection was conducted at the Braidwood Station and i ' appeared that the licensee was making adequate progress in reducing their: inspection backlog and closing outstanding NCRs and ICR s

. ' In'strumentatio'n and '.rol Systems

'

. . Analysis Licensee activities in this area were observed during two inspec-tions,and portions of three other NRC inspections. .The areas inspected include: reviews of the installation and terminations of. instrumentation cables including associated procedures and records;. review of the installation of instrument sensing lines,

..

instruments, and instrument racks and panels, including associated

!' ' ' procedures 'and records; review of instrument calibration; and a reviewLof CECO audits of the mechanical. instrumentation contractor and electricallinstrumentationLcontracto OneLitem of noncompliance was. identified'in this area as follows:

Severity Level V - Instrument sensing equipment was being installed

-

per design drawings; however,1 instrument sensing lines, as installed,

- were not consistent with the design requirements. (Inspection

. Report'No. 50-456/83-13)

'

Since the contractor utilizes the same procedures for all elec-trical and instrumentation cable installation and terminations, the' item of noncompliance identified in Paragraph F.1.b.lof this de - -

report also: applies, in part, to this section. The enforcement

^

history in this area is good and not indicative of major problem !

As a result of NRC concerns-expressed during inspection 50-456/

< 83-10, the licensee's mechanical instrumentation contractor has

' -

-developed a special reinspection procedure to verify instrument sensing line slope, identification, separation, and material traceability for all safety-related lines installed prior to

' February 1984.

'

Management has been responsive to NRC concerns and their involve-1 ment in assuring quality has been acceptable. Staffing and

' training appear to be acceptabl '

.

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f_ . - .. _

~ LC onclusion The licensee is rated a Category 2 in this are The licensee was not rated in this functional area during the previous assessment perio Licensee performance has remained the same during this assessment perio . Board Recommendations Non The Board' notes that subsequent to this SALP period, a mechanical instrumentation inspection was conducted at the Braidwood Station and it appeared that the licensee was making adequate progress in their reinspection of instrument sensing line Quality Assurance and Administrative Controls Analysis-This functional area was examined during two major inspections and during portions of twelve other NRC inspections conducted during this SALP period. Major areas reviewed include (1) the quality assurance programs of the piping contractor, the electrical contractor, and the HVAC contractor; and (2) the certification process of Quality Control (QC) inspectors of the electrical and civil-site contractor Thirteen items of noncompliance were identified as follows: Severity Level IV - Discrepancies were found between piping field drawings used for construction of the Chemical Volume Control, Boron Thermal Regeneration, Boric Acid Processing, and the Component Cooling Water Systems and copies of the same drawings located at the licensee's construction offic (Inspection Report Nos. 50-456/83-07; 50-457/83-07)

' Severity Level IV - Installation contractors (piping and

.e , electrical) were performing safety-related welding without assurance that welding materials were being properly controlle _

" '

(Inspection Report Nos. 50-456/83-08; 50-457/33-08)

. Severity Level IV - Five examples were identified regarding piping activities that were not in accordance with documented instructions, procedures or drawings, including failure to maintain adequate pipe bend records and failure to perform piping dimensional inspections. (Inspection Report No /83-09; 50-457/83-09)

u

s' _

,

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_

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~

! . Severity Level IV - The HVAC contractor had not established a corrective action system to provide assurance that-defi-

,

_ ciencies-and deviations were analyzed. A second example wa ' identified in which corrective action was not taken concerning-

~

~

-

nonconforming HVAC' welds, which were completed by unknown welders'and " accepted-as-is". (Inspection Report No /83-09; 50-457/83-09)^

~

' Severity Level IV - Four exarples were identified where

'

- all the major installation contractors and the licensee did

^

not establish and execute a comprehensive plan for auditing, or the audits did not conform to the annual audit schedul '

(Inspection Report Nos. 50-456/83-09; 50-457/83-09)

- u f.- Severity Level IV The licensee failed to adequatel document and. implement a quality assurance program to comply with the requirements of 10 CFR 50, Appendix B,.

-  : including citations against Criteria V, X, XIII, XV,' XVII,

,

,

and XVIII. -(Inspection Report Nos. 50-456/83-17; 50-457/83-16) Severity Level:V - The li:ensee failed to establish measures

'to contro11 storage and preservation of safety-related equip-ment (two' examples). (Ir.spectio.1 Report Nos. 50-456/83-18; 50-457/83-17) . Severity Level.IV - The licensee's_s_ite Quality Assurance

. department was using a drawing file which did not reflect

,

'

current revisions or Engineering Change Notices. These i idrawings were being used in the field to verify quality ;

.related activities (Inspection Report Nos. 50-456/84-05; 50-457/84-05)

^ Severity Level'V - The licensee's Quality A m urance Program

~

. ~ failed to. require-indcctrination and train.ng of personnel

-

in written nolicies, procedures, or instructions. Three

, examples, involving two installation contracting companies (electrical and structural), were .' identifie (Inspection Report Nos. 50-456/84.-07; 50-457/84-07)

- Severity Level IV - $lectrical welding inspectors were not proficient in the structural welding code with regard to repair of weld cracts and fit-up inspections. (Inspection

'

Report Nos. 50-456/84,07; 50-457/84-07)

- . Severity Level IV - The electrical contractor's quality

'

assurance program failed to identify. nonconforming condi-tions due to inadequate training and allowed craft personnel to repair / rework wold defects thereby circumventing the nonconformance reparting system. (Inspection Report No ^

50-456/84-07; 50-457/84-07)

f

m '

f -

W -

>

s

• V4 [ Severity Level V - Licensee corrective action in assessing

the certification of quality control inspectors for Napoleon

.

- A Steel. Company was inadequate. '(Inspection Report No /84-07; 50-457/84-07)

'

- ' ; Severity Level V'- Six procurement documents did not contain

, statements requiring the reporting of defects and noncompliance

-

as required in 10 CFR 21.31. (Inspection Report No :50-456/84-13;:50-457/84-13)

'

'

These NRCfidentified noncompliancesfrequired further analysis by

-

'the licensee _to determine.whether or not they resulted in hardware

-

- - -deficiencies. These noncompliances indicate problems in certifi-cation and training of quality control inspectors, document control,

'

>

procurement,) welding, inspections,: storage, nonconformances,

^

,

,

corrective action, auditing, and maintenance of record '

In the SALP 3 report-the Board recommended that licensee effort

' -

.be focused on the development and implementation of a program to verify the quality of installed equipment to ensure that similar deficiencies identified during the SALP'3 period do-not exist in

,

other areas. Notwithstanding this' recommendation, the licensee approved deficient contractor quality. assurance programs. The piping contractor's implementing procedures did not require quality

. control verification of correct material installation, and the inadequate procedures were approved by Commonwealth Edison Company

- (noncompliance discussed in Section C.). The HVAC contractor's

implementing procedures, which were also approved by Commonwealth

'

, .

Edison, did not previde adequate quality measures prior to or iduring. installation activities,'a factor which contributed to numerous' hardware deficiencies-(noncompliance discussed in Section

.C}. The' procedures'used by-the electrical contractor were inade-quate in.certain-areas, such as. verification of correct cable type,

~

correct routing, or-adequate cable tray suppor Instrumentation piping.is undergoing a retrofit inspection program as procedures approved by CECO did not contain adequate criteria.to assure _that the items inspected were acceptable. Audits

,

>

perfctmed by Commonwealth Edison and the' piping, electrical, and

. -HVAC contractors were inadequate in both scope and depth and failed

,( to identify subsequent NRC' findings. As a result of NRC findings the licensee issued a stop work order for all safety-related HVAC activities and a stop work order for safety-related cable pullin Enforcement Conferences were held on December 20, 1983 and March 7, 1984, to discuss the violations identified in NRC Inspec-tion Report 50-456/83-09. The licensee was' informed that the deficiencies : identified by the NRC in the_ piping, HVAC, and electrical ~ areas were largely the result of inadequate contractor

. programs, inadequate' licensee reviews of the programs, and inade-

'

-quate licensee audits. It was stressed that a program must be

,

developed to assure that a11' safety-related activities performed

. n

,

e . ~~~- ;

.

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'

_

w t

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" _

_

- by contractor personnel are.in accordance with and inspected

against.the regulations, codes, standards, and licensee commit-

'

'

ments. . As a result of the enforcement conferences and Ceco

- initiatives, the licensee instituted the following corrective action measures:

_ , ,

,

" The-licensee substantially increased the number of Commonwealth A'A' , , Edison Site QA personae ,

!

- .A-new position of Assistant Manager'of Quality Assurance was established and the-Assistant Manager has been instru- i-mental in. increasing QA presence on sit '

l The Commonwealth Edison Site QA Superintendent was replace Commonwealth' Edison site audits were improved in technique,

'

, depth, and scop ' '

- The piping contractor's project management were replace ' Major revisions to the piping and HVAC quality control programs have resulted in an overall upgrading of the '

,

program g. ' - The reporting level'of the "anager of Quality Assurance was changed from the Vice Chairman to the Chairman and Presiden Overinspections by_the Independent Testing Agency at-Braidwood have been increased from approximately 10% to

'25%. The independent testing agency has performed in accordance with recognized standard . JCommunications between the site and the Corporate QA Manager have improve Communications between Project Management and the Ser.ior Resident Inspectors have improved, The licensee has. established the Braidwood Construction-Assessment Program, a significant reinspection and reverifi- '

cation program which will be implemented during the.SALP 5-period. 'The objectives of the program are to assure that

.

(1) there are no significant problems in programmatic design,

"

- (2) onsite contractors procedures address all applicable

,

design and regulatory requirements, and (3) past identified

.

problems-are adequately corrected.

,

,

,

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'

'

'

? Licensee management's recent selection of personnel and the

. increased attention given to site activities have resulted.in

'significant improvement'in~ Ceco and contractor organization ~

.

-

-

<  : More importantly,x licensee management is providing a clear and

'

~

concise course:to assure that all retro-fit work'and future-construction work meets regulatory requirements and licensee- ,

commitments. It:is essentia1'that both corporate and site

, management attention and involvement in site activities continu c ,

1- f. Conclusion

'

The. licensee'is' rated Category 3 in this area. This is the same rating as.the previous assessment period. License? performance-in this functional' area improved during the assessment perio The licensee's initiation of the Braidwood Construction Assess-

~

,

'

ment ~Progvam.and the numerous organizational changes made are

. indications of substantial management involvement to resolv Braidwood concern '

' Board Recommendations

'

It is recommended that management personnel from NRC and CECO

-

closely follow the BCAP effor , , Licensing Activities-

,

. Analysis s

. Evaluation and monitoring of-licensing activities included routine contact between the~NRC.and CECO, as well as conference calls, site' visits,~public meetings, and audits as require The major. licensing activities during this assessment period involved the issuance'of.the draft and final. safety evaluation reports (SERs)'and the draft and final environmental-statements

~

'

'

n (ESs). During this period the applicant also concentrated its

. licensing efforts.on resolving' duplicate plant issues, as-identified _in both the Byron and Braidwood SERs.

. m The' applicant's management involvement in assuring ' quality tech-

% nical. responses to safety and environmental issues was apparent b '- throughout the review period. Management's involvew nt and attention to details was aggressive and concerned with nuclear

'

' safety. Resources were generally adequate and effective in all licensing areas, although delays were experienced during the Braidwood safety review due to the amount of resources the applicant devoted to the Byron OL hearin The applicant demonstrated a clear understanding of the various

< technical issues and reviews were generally timely, thorough and technically sound.- Conservatism'was generally exhibited by the applicant in the resolution of technical issues from a safety i standpoint, u

'

4

m

. -

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'

-

g '

3C i 1An exceptional effort was expended by the applicant during the 4 course ofcthe environmental ~ revie ~

The applicant's management attention'to the details of;.the environmental review ensured that'

R "'

the reviews:were' consistently thorough and timely. Above average

, assistance was provided to the NRC staff in obtaining information

-

required for the_ environmental reviews. -_However, some delays

~

-

lwere experienced during the course of the' safety review due to the applicant's involvement in the Byron OL hearing. Responses 4 to requests for. additional information, which were required for-

.the preparation of the.SER, as well as information required for the resolution _of certain duplicate plant issues, were delaye The last SALP report stated: " Changes to the FSAR initiated

by CECO are not always well distinguished. These changes should be delineated =in a separate attachment or cover letter included'

with thel amendment,and proper color coded FSAR pages rhould

'

_ always be used for these changes."- The applicant has satisfactorily corrected this deficienc ' Conclusion An overall rating of-Category 2 is assigned. Although this rating of Category 2 is.less than given for the prior SALP report,-it does not appear to represent a significant decline

~in the applicant's capability or performance. It reflects the delays experienced during the course of the safety review

^

"due to the applicant's involvement in the Byron OL hearin <Although significant delays occurred in responding to request for additional information early in the assessment period, the licensee's performance did improve as the assessment period progresse The applicant's performance in the environmental

,

review area- ould have been rated a Category 1 had it been rated separatel . Board Recommendations 5 Non Construction and Preoperational Testina

,

. Analysis

xe >~

Four inspections were conducted in this functional area. The inspections performed on Unit 1 consisted ~of observations of test activities, reviews of selected construction or preoperational

-

test' procedures, verification of preoperational test procedures, and monitoring administrative controls implemented by the license No itemsTof noncompliance were identifie r i

23

-

-

, <

.s ez 1

-

-

c '

'

_

-

f Thelinspectors identified that Commonwealth Edison had waived the 1 internal cleanliness inspections- for numerous pieces of equipment,

,

'

~ because they ' felt that _" flushing it' clean" satisfied the cleanli-

ness requirements. :In addition,~a review of the licensee's radio-graph records determined that foreign material.had been identified sin Lsafety-related piping.~ The licensee's initial solution to this foreign material problem wasito flush the system clean. Subse-Jquently, the licensee established.a program to review the components which were-waived or " flushed through" and to perform visual-examinations to determine the condition of the equipment. This program'is believed to be responsive to the potential proble The licensee has established the practice of using Byron proce-

'

- dures for instrument maintenance and calibration. Although this

+ practice is beneficial in providing experience gained during the implementation of this procedureLat Byron, the licensee has not implemented measures to verify that the procedure being used is-the latest approved revision. It should also be noted that the Llicensee's' program to review and approve these procedures in order to= satisfy Braidwood' administrative procedures has not been-effectively implemente Ceco Senior management has implemented significant managerial

~ changes to the start up organization to address NRC concerns in this area. These changes include the assignment of a project

- suparintendent.with an.immediate staff to review the necessary i test functions'and an-appropriate increase.of personnel to '

successfully accomplish the testing phase. Before these changes

- were made, the startup group was a section of station technical ,

staff.' .The individuals assigned to these management positions have extensive preoperational and startup testing experience at

the Byron Station. CECO appears to be placing adequate attention and resources to this~ are : Conclusion The licensee is rated Category 2 in this are This rating is

- based upon.a minimal amount of preoperational testing performe This is the:first rating' received in'this functional are Licensee performance remained the same during this assessment r perio a-~

-

,

,

"" ^ ' Board Recommendations ,

' #

Non %

i P

4

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.

.

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~

i K.~ : Health Physics Program-5 Analysis c -

'Four preoperational inspections were conducted during the assess-ment period. These inspections included radiation protection, environmental monitoring, and chemistry / radiochemistry. - The

resident. inspectors also reviewed this area during routine inspections. No violations were identifie The' radiation protection and radiochemistry programs are in the middle stages of development with staffing, training, and procedure development well underway. Early in the SALD period, inere was concern regarding staffing levels and training in the radiation

. protection area. In addition, NRR's review of the qualifications of the Station Health Physicist to hold the position of Radiation i

Protection Manager concluded that the individual needed additional training and experience. -The-licensee has made adequate progress

~

_

.L towards resolving these concerns. . The radiation protection organization is following their schedule for staffing, trairaing,

,

and providing equipment relative to the schedule for fuel load and plant operatio ~

The preoperational environmental monitoring program is performed by the same contractor used at the licensee's other nuclear plant Although overall sample collection and laboratory-performance has been satisfactory,1 field performance was found flawed and required

-

more management oversight. The inspectors observed leakage around the charcoal adsorbers on two of four air samplers, and the air' pump exhausts were directed toward the air sample intake The plant environmental coordinator was familiar with sample station locations but seldom inspected the equipment insid The-licensee's locks on the stations visited were too rusty

'.

'

to open with a key and had to be broken open for inspectio In ac'dition, an error was 'found in-a map showing the location of air samplers. The licensee agreed to resolve these problems as-quickly as possibl :The licensee is making satisfactory progress in the development of the chemistry / radiochemistry program. ' A QA program for non-

- radiological samples is under development but a'similar program

=- ^

for radioloaical samples has yet to be established. The licensee

""'""~ ~

Lis not yet ready to 'eceive'r'adioactive samples for the' independent

~

r measurements program as their hot laboratory and counting room are'still under constructio .- Conclusion

- * The licensee is rated Category 2 in this ' are This is the first rating received in this functional are Licensee performance remained the same during this assessment period.

.

i

..

,

.

r p-3. Board Recommendations Non t __ . - -. _ _ _ _ _ _ _ _ _ . - _ _ _ .

. _. _ .- - - .

E.-

'

. SUPPORTING DATA AND SU M RIES

- Licensee Activities-The main construction activities which occurred during the assessment period were the installation of piping, snubbers, cable trays, con-duits, electrical equipment, instruments, cables, and HVAC. Small and-large-bore piping and HVAC reinspection programs were initiated. The rebolting of the NSSS components aid repositioning of steam generator and reactor. coolant pump support calumns are essentially complete Preoperational testing was conduc',ed on safety-related and non-safety related systems,. including the completion of plant cold hydro testin In the safety-related system testing area,18 of 82 tests have been approved and 6 have been complete Units 1 and 2 were reported by the licensee to be 80% and 54% complete, respectively, as of June 30, 1984._ Fuel load dates are estimated by the licensee to be August 30, 1985 for Unit 1 and August 30, 1986 for Unit 2. These dates are under review by the license B.. . Inspection Activities Noncompliance Data Facility Name: Braidwood Unit 1 Docket No. 50-456 Braidwood Unit 2 Docket No. 50-457 Inspections: No. 83-01 through 84-15 Noncompliances and Deviations Severity Levels Functional Areas Assessment I II III IV V De Soils and Foundations Containment and Other (3)

Safety-Related Structures C. -Piping Systems and Supports (8)* Safety-Related Components (3) (2) Support Systems (4) (1) Electrical Power Supply (1) (1)

and Distribution Instrumentation and (1)

Control Systems

~ H. -Quality Assurance (9) (4) Licensing Activities Construction and Preoperational Testing K .' Health Physics TOTALS 28* 8 1

• 0ne additional item of noncompliance has not yet been categorized as to its Severity Leve (See Section C.)

'

( ) Indicates items common to both units.

'

.

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.

" Activities The composite inspection effort by the NRC consisted of 28

' inspections of Unit 1 and 26 inspections of Unit 2 during the assessment perio The NRC Mobile Nondestructive Examination Laboratory completed a-two-week inspection effort to support Region-III requests to assess the welding programs at Braidwoo A team inspection of the. design process called the Integrated Design Inspection (IDI) was-conducted at the Byron Station. The results of the Byron IDI inspection have applicability to and will be resolved for Braidwoo In January 1984, the previous Senior Resident Inspector (Con-struction), wr.s assigned Senior Resident Inspector (Operation)

and a new inspector was assigned in March 1984 as Senior Resident Inspector (Construction).

- Investioations and Allegations Review Allegations were received from five individuals during the SALP perio The allegations of two individuals remain open. The open allegations relate to piping concerns including unqualified welders. The allega-tions are being evaluated by Region III and inspections are being performed. Inspection findings will be documented and followed to resolution. Closed allegations are discussed in preceding section . D. Escalated Enforcement Actions Civil Penalties Non . Orders Non E. Management Conferences Conferences The following meetings were conducted during this period:

~'

January 26, 1983 Management meeting to discuss CECO proposed guidelines for use by CECO personnel in dealing with information requests from NRC inspectors (Inspection Report Nos. 456/83-01 and 457/83-01).

.

.

. .

,

February 17, 1983 Management meeting to discuss the increased number of events at CECO operating and construction sites which have lead to consideration or issuance of civil penalties (Inspection Report Nos. 456/83-04 and 457/83-04).

June 13, 1983 Management meeting to present and discuss the results of the SALP 3 assessment (Inspection Report Nos. 456/83-06 and 457/83-06).

July 26, 1983 First management meeting aimed at improving licensee regulatory performance and enhancing communi-cations between the NRC and CECO (Inspection Report Nos. 456/83-12 and 457/83-12).

August 16, 1983 Enforcement conference to discuss inspection findings in the piping and HVAC area (Inspection Report Nos. 456/83-09 and 457/83-09)

September 9, 1983 Second in a series of management meetings aimed at improving licensee regulatory performance and enhancing communications between the NRC and CECO (Inspection Report Nos. 456/83-14 and 457/83-13).

October _ 19, 1983 Third in a series of management meetings aimed at improving licensee regula':ory performance and enhancing communications between the NRC and Ceco (Inspection Report Nos. 456/83-15 and 457/83-14).

October 24, 198 Management meeting to discuss NRC inspection findings in the

_

piping and HVAC areas. (Inspection

• ~

Neport Nos. 456/83-09 and 457/83-09)

December 20, 1983 Second enforcement conference to discuss NRC inspection findings with regard to piping and HVA (Inspection Report Nos. 456/83-09 and 457/83-09)

L_

__

- - -

, - - _

.

'

.,

~

March 7, 1984 Third enforcement conference regarding NRC inspection findings with regard

'to piping and HVAC. (Inspection Report Nos. 456/83-09 and 457/83-09)

June 6, 1984 Management meeting for the licensee to present details of the BCAP program to the NR . Confirmatory Action Letters Non F. Review of Construction Deficiency Reports and 10 CFR 21 Reports l'. Construction Deficiency Reports (CDR)

'During this SALP period 26 CDRs were submitted by the licensee under-the. requirements of 10 CFR 50.55(e). The contents of these reports were generally acceptable. Submitted reports were as follows: Safety related HVAC installation oy Pullman Sheet Metal was not in accordance with dimensional tolerances and details.on drawings. (83-01)

- Westinghouse gate valve operators indicate that they are closed prior to the valve disc. fully isolating flo (83-02)' Reactor coolant pump and steam generator support columns were not installed within specified tolerance (83-03) Design requirements failed to provide for the burring of structural steel bolt threads. (83-04)

- Design discrepancy reported in Westinghouse Model DS-416 reactor trip breakers. (83-05)

< Certain spring hangers supplied by Elcan Metal Products have welded high carbon steel r.uts with a carbon content

. .

in excess of Code limits. (83-06) There was lack of documentation that QC verifications were performed at Braidwoo (83-07) Duct fittings were fabricated without approved design document (83-08) Westinghouse protection system printed circuit card adhesive failed. (83-09)

b

~

,.

'j. ' Power Conversion Products battery chargers had the wrong type of shunt trip coi (83-10)

-

< Anchor bolt installation on Diesel Oil Storage Tank was not in accordance with design drawings. (83-11) Anaconda flexible conduit split open on several instal-L 1ation (83-12) Westinghouse motor starters overload trips were not accurately calibrated. (83-13) Safety-related battery cells were cracke (83-14) Pacific Scientific snubber capstan springs failed dynamic tes (83-15) Electrical contractor QC documentation deficiencies were identified. (84-01) Distribution panel 1DC05E was incorrectly wire (84-02) Linear. torque converters in HVAC damper actuators faile (84-03) Radiographic film densities at Braidwood had questionable tolerance. (84-04) Inconsistencies in documentation of structural steel fabrication were identified. (84-05) Recycle holdup tank leakage problems were identifie (84-06) Concrete expansion anchors were installed through finished floor (84-07) Auxiliary building ventilation' exhaust filter housings were not installed in accordance with design drawings. (84-08) Westinghouse Motor Control Centers with 5 star series breakers have potential wire connection problem. (84-09)

n;; - Wall Liiickiie>> iiiadequacies for sniall bore AshiE Class II

~ piping at Braidwood were identified. (84-10) Steam Generator snubber faile (84-11)

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The number of construction deficiency reports (CDRs) has increased ofrom-13 (SALP period 3) to 26 for this assessment period. During SALP period 2 there were four construction deficiencies reported-to.the NRC. The increase in CDRs is believed to be attributable to the increased number of design problems and nonconforming conditions identified, and to the licensee's lower and more appropriate. threshold for reporting construction deficiencie . Part 21 Reports No 10 CFR Part 21 reports were submitted by the licensee during this assessment period. No situations were identified where the licensee should have submitted a repor .

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32