IR 05000456/1985030

Insp Repts 50-456/85-30 & 50-457/85-29 on 850603-28.No Noncompliance or Deviation Noted.Major Areas Inspected:Const Assessment Program Re Licensee Action on Previously Identified Items & Const Sample Reinsp

ML20132C891
Person / Time
Site:	Braidwood
Issue date:	07/10/1985
From:	Gardner R, Little W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20132C895	List: IR 05000456/1985030 ML20132C897
References
50-456-85-30, 50-457-85-29, NUDOCS 8507310051
Download: ML20132C891 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-456/85030(DRP); 50-457/85029(DRP)

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Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Nuclear Power Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, Illinois Inspection Conducted: June 3 through June 28, 1985 Inspector: .' de 7 hI Date M

Approved By: . rec r 7 Brai wood Project pat Inspection Summary Inspection on June 3 through June 28, 1985 (Report No. 50-456/85030(DRP);

50-457/85029(DRP))

Areas Inspected: Special, announced safety inspection of the Braidwood Construction Assessment Program (BCAP) in regards to licensee action on previously identified items, Construction Sample Reinspection (CSR)

reinspection activities, review of BCAP observations / discrepancies, review of BCAP procedures, and review of Reverification of Procedures to Specification

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Requirements (RPSR) activities. The inspection consisted of 127 inspector-hours onsite by one NRC inspecto Results: No items of noncompliance or deviations were identifie PDR A hh56 PDR O

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DETAILS Persons Contacted Commonwealth Edison Company (CECO)

L. DelGeorge, Assistant Vice President 1'2 Maiman, Manager of Projects y M. Wallace, Project Manager

W. Shewski, Quality Assurance Manager G

y'2 E.. Marcus, Fitzpatrick,Special AssistantAssistant to Manager Quality Assurance of Projects Manager y'2 D. Shamblin, Project Construction Superintendent 1,2N. Kaushal, BCAP Director N.-Smith, General Supervisor of Quality Assurance

B. Shelton, Projects Engineering Manager

W. Vahle, Field Engineering Manager 1,2G. Orlov, BCAP Assistant Director R. Byers, BCAP Assistant Director y M. Dougherty, BCAP Engineer M. Frankel, Statistician

1 R. Williams, BCAP Quality Assurance

., R. Cannon, BCAP Quality Assurance I. Johnson, Nuclear Communications Coordinator

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{ L. Weiss, BCAP Taskforce

2L. Kline, Licensing and Compliance pC. Schroeder, Licensing and Compliance D. Patel, CSR Lead Electrical Daniel Construction Company E. Shevlin, BCAP Lead Inspector

, L. Shea, BCAP Lead Inspector Stone and Webster Engineering Company (S&W)

P. Dunlop, Manager Sargent and Lundy Engineers (S&L)

K. Kostal, Project Director D. Fischer,-Project Manager

y G. Jones, Project Manager B. Pardunn, BCAP Evaluation Coordinator Illinois Department of Nuclear Safety

R. Minue, Nuclear Engineer

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Evaluation Research Corporation (ERC)

J. Hansel, Project Manager B. Ham, Deputy Project Manager

W. Chase, Consultant Isham, Lincoln and Beale

V. Copeland, Attorney The inspector also contacted and interviewed other licensee and contractor personnel during the course of this inspectio Denotes those present at the June 25, 1985 public meeting on BCA Denotes those present at the exit intervie . Licensee Action on Previously Identified Items (Closed) Open Item (50-456/84-32-01; 50-457/84-30-01): BCAP inspectors were determining the acceptability of the elevation and location of installed components by utilizing chalk-marks which were written on plant structures. As stated in NRC inspection report Nos. 50-456/85002 and 50-457/85002, the inspector attended a training session which was held to provide BCAP inspectors with direction in the use of approved survey marks for BCAP reinspections. During this report period, the inspector determined that all but one of the reinspection attributes previously documented as N/A due to the lack of adequate survey marks had been reinspected. Missing survey marks had been provided by the site contractors. The one remaining electrical reinspection which contained an attribute which was designated as N/A due to a missing survey mark was in the process of being reinspected. This item is close (Closed) Unresolved Item (50-456/85002-02; 50-457/85002-02): The invalidation of certain discrepancies by S&L did not support the invalidation. The inspector reviewed the final status of the three discrepancies which were the basis of this unresolved item. Each of the three discrepancies was reprocessed as valid items. In addition, S&L had concluded that all three discrepancies were not design-significan On March 22, 1985, BCAP QA instituted Mandatory Hold Points during the processing of invalid observations to allow QA to substantiate specific justification for the invalidation of the observation The Mandatory Hold Points apply to each of the three BCAP element This item is close . .

3. CSR Reinspection Activities On June 13, 1985, the inspector witnessed the overinspection of a large bore rigid pipe support located in the Unit 1 auxiliary buildin The overinspection was performed by ERC inspectors. The CSR reinspection package number was CSR-I-M-2-114. The pipe support had previously been reinspected by the BCAP taskforce. During the overinspection, the ERC inspector determined that one heat number had not been recorded on the reinspection package. The ERC inspector stated that this matter would be discussed with the BCAP taskforce. With the exception of the unrecorded heat number, the reinspection performed by the BCAP taskforce accurately documented the acceptability of the pipe suppor BCAP CSR reinspection activities and CSR documentation review activities are essentially complete. The only continuing CSR reinspection activities are those which pertain to the gathering of additional data to support the S&L review of previously identified BCAP deficiencies. As a result of the completion of CSR reinspection activities, the BCAP taskforce has begun to release BCAP inspectors from the Braidwood sit During the course of the NRC overview of BCAP CSR activities, the inspector has reviewed CSR procedures, checklists, and checklist instructions. In addition, the inspector has reviewed the experience and qualifications of numerous BCAP taskforce personnel including BCAP taskforce engineering and inspection personnel. Finally, the inspector has observed the reinspection of a number of BCAP sample items and has witnessed the overview of numerous BCAP items previously reinspected by the BCAP taskforce. While the results of the BCAP QA evaluation of BCAP inspector performance have not been released to the NRC, the overall assessment of the BCAP CSR element is satisfactor No violations or deviations were identifie . Review of BCAP Observations / Discrepancies During the course of the NRC overview of BCAP activities, the inspector reviewed the evaluations associated with approximately 500 BCAP observations / discrepancies. While the majority of the observation /

discrepancy evaluations reviewed were well written with backup calculations, a number of the discrepancies were determined to require a more detailed technical review so as to ascertain the acceptability of the evaluations. Technical reviews by Regional personnel have been initiate During this inspection period the inspector performed a detailed review of 123 BCAP CSR electrical observations / discrepancies. The following is a list of the observation / discrepancies reviewed:

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Electrical Cable CSR-I-E-CBL-004-2 CSR-I-E-CBL-999-29

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Cable Pan CSR-I-E-CBP-008-1 CSR-I-E-CBP-013-1 CSR-I-E-CBP-019-1 CSR-I-E-CBP-030-1 CSR-I-E-CBP-035-2 CSR-I-E-CBP-044-1 CSR-I-E-CBP-050-1 CSR-I-E-CBP-059-1 CSR-I-E-CBP-102-1 CSR-I-E-CBP-118-2 CSR-I-E-CBP-129-1 CSR-I-E-CBP-129-3 CSR-I-E-CBP-130-2 CSR-I-E-CBP-999-77 Conduit CSR-I-E-CND-001-1 CSR-I-E-CND-003-1 CSR-I-E-CND-004-1 CSR-I-E-CND-004-2 CSR-I-E-CND-004-3 CSR-I-E-CND-004-4 CSR-I-E-CND-004-5 CSR-I-E-CND-007-1 CSR-I-E-CND-009-1 CSR-I-E-CND-009-4 CSR-I-E-CND-010-1 CSR-I-E-CND-011-2 CSR-I-E-CND-014-1 CSR-I-E-CND-015-1 CSR-I-E-CND-015-4 CSR-I-E-CND-016-1 CSR-I-E-CND-016-2 CSR-I-E-CND-018-1 ( CSR-I-E-CND-018-2 CSR-I-E-CND-018-3 CSR-I-E-CND-020-1 CSR-I-E-CND-020-3 CSR-I-E-CND-021-3 '

CSR-I-E-CND-022-1 CSR-I-E-CND-023-1 CSR-I-E-CND-024-2 CSR-I-E-CND-025-1 2 CSR-I-E-CND-025-3

G I Conduit CSR-I-E-CND-029-1 CSR-I-E-CND-029-2 CSR-I-E-CND-032-3 CSR-I-E-CND-033-1 CSR-I-E-CND-038-1 CSR-I-E-CND-041-4 CSR-I-E-CND-042-2 CSR-I-E-CND-044-2 CSR-I-E-CND-045-1 CSR-I-E-CND-046-1 CSR-I-E-CND-047-1 CSR-I-E-CND-052-1 CSR-I-E-CND-052-2 CSR-I-E-CND-053-1 CSR-I-E-CND-054-1 CSR-I-E-CND-057-2 CSR-I-E-CND-057-3 CSR-I-E-CND-057-5 CSR-I-E-CND-058-1 CSR-I-E-CND-058-2 CSR-I-E-CND-060-2 CSR-I-E-CND-063-1 CSR-I-E-CND-063-2 CSR-I-E-CND-066-1 CSR-I-E-CND-067-1 CSR-I-E-CND-069-1 CSR-I-E-CND-069-2 CSR-I-E-CND-070-2 CSR-I-E-CND-072-1 CSR-I-E-CND-072-2 CSR-I-E-CND-077-2 CSR-I-E-CND-078-1 CSR-I-E-CND-081-1 CSR-I-E-CND-082-2 CSR-I-E-CND-085-1 CSR-I-E-CND-086-1 CSR-I-E-CND-087-2 CSR-I-E-CND-087-3 CSR-I-E-CND-088-1 CSR-I-E-CND-089-1 CSR-I-E-CND-093-4 CSR-I-E-CND-094-2 CSR-I-E-CND-095-2 CSR-I-E-CND-096-1 CSR-I-E-CND-102-2 CSR-I-E-CND-109-1 CSR-I-E-CND-109-2 CSR-I-E-CND-111-1 CSR-I-E-CND-112-1 CSR-I-E-CND-114-1 l

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Conduit CSR-I-E-CND-116-1 CSR-I-E-CND-119-3 CSR-I-E-CND-119-4 CSR-I-E-CND-120-2 CSR-I-E-CND-123-1 CSR-I-E-CND-123-2 CSR-I-E-CND-999-20 CSR-I-E-CND-999-26 CSR-I-E-CND-999-36 CSR-I-E-CND-999-60

~ Conduit Hangers CSR-I-E-C0H-001-2 CSR-I-E-C0H-018-1-CSR-I-E-C0H-020-1 CSR-I-E-C0H-021-l'

CSR-I-E-C0H-046-1 CSR-I-E-C0H-047-3 CSR-I-E-C0H-049-2 CSR-I-E-C0H-050-2 CSR-I-E-C0H-059-1 CSR-I-E-C0H-060-1 CSR-I-E-C0H-106-3 CSR-I-E-C0H-109-1 CSR-I-E-C0H-111-2 CSR-I-E-C0H-114-1 CSR-I-E-C0H-115-3 CSR-I-E-C0H-119-3 CSR-I-E-C0H-120-3 CSR-I-E-C0H-120-4 CSR-I-E-C0H-121-1 With the exception of one observation and one discrepancy, the evaluations adequately supported the classification of the observation / discrepancy (i.e., valid, invalid, or out of BCAP scope).

BCAP observation CSR-I-E-CND-007-1 was invalidated by the BCAP taskforce as a result of a Technical Information Request (TIR) response from S& The observation identified a flexible conduit which exceeded the six foot length requirement specified on the BCAP checklist and in specification EB-146. The TIR response stated that this instance was a special desig While the inspector disagrees with the invalidation of the observation, there is no safety concern with the as-built installation of the flexible conduit. BCAP discrepancy CSR-I-E-CND-015-4 was classified as being outside of the BCAP scope due to the S&L evaluation which concluded that the deficiency was the result of construction damage. The discrepancy dealt with a cross-threaded fitting and a loose coupling. In discussions

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with the Level III BCAP electrical inspector, the inspector was informed that BCAP inspection personnel did not consider this discrepancy to be the result of construction damage, but rather the result of uncontrolled removal / rework by person or persons unknown. Since the proper classification of this discrepancy was dependent on the cause of the identified deficiencies in the conduit installation, this matter was discussed with BCAP engineering and S& The BCAP Director stated that this discrepancy would be reviewed so as to resolve the apparent conflict between BCAP inspectors and S& No violations or deviations were identifie . Review of BCAP Procedures During this review period the inspector reviewed the following BCAP procedures:

BCAP-01 Revision 3 BCAP Program Indoctrination for Employees BCAP-02 Revision 3 Organization and Responsibility BCAP-03 Revision 3 Records Management BCAP-06 Revision 9 Observation and Discrepancy / Concern Processing BCAP-08 Revision 2 Qualification and Certification of Reinspection Personnel BCAP-20 Revision 2 CSR - Establish Populations BCAP-21 Revision 6 CSR - Sample Selection BCAP-22 Revision 2 CSR - Preparation of Instructions and Checklists BCAP-23 Revision 2 CSR - Preparation of Reinspection and Document Review Packages BCAP-24 Revision 3 CSR - Performance of Reinspection and Document Review BCAP-25 Revision 1 CSR - Evaluation of Results BCAP-41 Revision 2 RPSR - Identification of Specifications and Contractor Procedures BCAP-42 Revision 4 RPSR - Preparation of Checklists BCAP-43 Revision 2 RPSR - Review of Contractor Procedures BCAP-60 Pevision 2 RSCAP - Review Methods

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No violations or deviations were identifie . Review of RPSR Activities The inspectors reviewed the results of the RPSR review of procedures utilized by Pittsburgh Testing Laboratory (PTL). Included in the RPSR documents reviewed were the PTL procedure checklist and 1,he observations written during the procedure review The checklist consisted of an itemized listing of specification requirements, a determination as to whether the requirements were considered to be essential, and a corresponding determination as to whether the PTL procedures were in compliance with the procedure The inspector observed that the checklist provided an acceptable verification of the PTL procedures. Also, the inspector observed that observations were written by BCAP to document the instances in which the PTL procedures were not in compliance with specification requirement During the review of the PTL procedures, the inspector observed that there was no apparent vehicle in place by which RPSR reviewers could document any identified concerns regarding site specifications. This matter was discussed with the licensee. During this discussion, the licensee stated that each RPSR engineer would be afforded the opportunity to document any concerns with site specifications on a memo which would be forwarded to both engineering and Q No violations or deviations were identifie . Public Meeting to Discuss BCAP The June public BCAP status meeting was held on June 25, 1985, at the Region III offic Participants in the meeting included Messrs. Keppler, W. Little, and R. Gardner of the NRC staff; T. Maiman, Wallace, N. Kaushal, and N. Smith of CECO; and J. Hansel of ER Subjects addressed during the meeting included a presentation on the status of BCAP activities, a summary of the S&L review of discrepancies identified to date, the BCAP QA overinspection program, and the status of ERC reviews and observations identified to dat . Exit Interview The inspector met with licensee and contractor representatives denoted in Paragraph 1 during and at the conclusion of the inspection on June 28, 1985. The inspector summarized the scope and results of the inspection and discussed the likely content of this inspection report. The licensee acknowledged the information and did not indicate that any of the information disclosed during the inspection could be considered

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proprietary in natur Attachment: Memo from C. E. Norelius to James G. Keppler dtd 6/27/85 l

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