IR 05000456/1986001
| ML20214E286 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 02/28/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20214E272 | List: |
| References | |
| 50-456-86-01, 50-456-86-1, 50-457-86-01, 50-457-86-1, NUDOCS 8603070244 | |
| Download: ML20214E286 (42) | |
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SALP 5-SALP BOARD REPORT U.S. NUCLEAR REGULATORY COP 911SSION
REGION III
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 50-456/86001; 50-457/86001 Inspection Report Nos.
Commonwealth Edison Company Name of licensee Braidwood Station, Units 1 & 2 Name of Facility July 1, 1984 through November 30, 1985 Assessment Period
l 8603070244 860228 PDR ADOCK 05000456 G
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I.
INTRODUCTION 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.
The SALP program is supplemental to normal regulatory
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processes used to ensure compliance to NRC rules and regulations.
The SALP program is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to the licensee's management to promote quality and safety of plant construction and operation.
An NRC SALP Board, composed of staff members listed below, met on January 22, 1986, to review the collection of performance observations and data to assess 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 of this report.
This report is the SALP Board's assessment of the licensee's safety performance at Braidwood Station, Units 1 and 2, for the period July 1, 1984 through November 30, 1985.
The following personnel attended the SALP Board for Braidwood Station, Units 1 and 2 Name Title James G. Keppler Regional Administrator A. B. Davis Deputy Regional Administrator J. A. Hind Director, DRSS E. G. Greenman Deputy Director, DRP C. J. Paperiello Director, DRS L. A. Reyes Branch Chief, DRS W. D. Shafer Branch Chief, DRSS W. S. Little Director, Braidwood Project W. L. Forney Section Chief, DRP M. A. Ring Section Chief, DRS M. P. Phillips Section Chief, DRSS L. R. Greger Section Chief, DRSS
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R. N. Gardner Acting Section Chief, DRP E. R. Schweibinz Section Chief, DRP C. C. Williams Section Chief, DRS P. R. Pelke Project Inspector, DRP M. J. Farber Project Inspector, DRP W. B. Grant Radiation Specialist, DRSS L. G. McGregor Senior Resident Inspector, DRP W. J. Kropp Resident Inspector, DRP T. M. Tongue Senior Resident Inspector, DRP D. L. Williams Reactor Inspector, DRS J. L. Belanger Physical Security Inspector, DRSS R. D. Schulz Senior Resident Inspector, DRP R. Mendez Reactor Inspector, DRS C. M. Trammell Senior Project Manager, NRR J. A. Stevens Project Manager, NRR i
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II. CRITERIA The licensee's performance is assessed in selected functional areas,,,
depending upon whether the facility is in a construction, preoperational, or operating phase.
Functional areas normally represent areas significant to nuclear safety and the environment.
Some functional areas may rot be assessed because of little or no licensee activities, or lack of meaningfnl observations.
Special areas may be added to highlight significant observations.
One or more of the following evaluation criteria were used to assess each functional area.
1.
Management involvement and control in assuring quality 2.
Approach to the resolution of technical issues Yrom a safety standpoint 3.
Responsiveness to NRC initiatives 4.
Enforcement history 5.
Operational and Construction events (including response to, analyses of, and corrective actions for)
6.
Staffing (including management)
7.
Training effectiveness and qualification However, the SALP Board is not limited to these criteria and others may have been used where appropriate.
Based upon the SALP Board assessment, each functional area evaluated is classified into one of three performance categories.
The definitions of these performance categories are:
Category 1:
Reduced NRC attention may be' appropriate.
Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so that a.high level of
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performance with respect to operational safety and construction quality is being achieved.
Category 2:
NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reascrably effective such that satisfactory performance with respect to operational safety and construction quality is being achieved.
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Category 3:
Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to
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be strained or not effectively used so that minimally satisfactory performance with respect to operational safety and construction is being achieved.
Trend: The SALP Board has also categorized the performance trend in each functional area rated over the course of the SALP assessment period.
The categorization describes the general or prevailing tendency (the performance gradient) during the SALP period.
The performance trends are defined as follows:
Improved:
Licensee performance has generally improved over the course of the SALP assessment period.
Same:
Licensee performance has remained essentially constant over the course of the SALP assessment period.
Declined:
Licensee performance has generally declined over the course of the SALP assessment period.
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III. SUMMARY OF RESULTS Rating Last Rating This Functional Areas Period Period Trend A.
Plant Operations X
NR
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B.
Radiological Controls
2 Improved C.
Preoperational Testing
2 Same D.
Fire Protection X
NR
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Security X
NR
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G.
Quality Programs and
2 Improved Administrative Controls Affecting Quality H.
Licensing Activities
2 Same
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Containment, Safety-
2 Same Related Structures, and Major Steel Supports i
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Piping Systems
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Improved and Supports
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Safety-Related
2 Improved Components - Mechanical L.
Auxiliary Systems
2 Same M.
Electrical Equipment
2 Same and Cables N.
Instrumentation
2 Improved O.
Braidwood Construction X
Improved Assessment Program P.
Housekeeping and X
Same Equipment Protection X = Not Rated Last Report NR = Not Rated because of lack of activity in the area.
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IV.
PERFORMANCE ANALYSIS A.
Plant Operations 1.
Analysis Examination of this functional area consisted of two inspections by the resident inspection staff.
Areas examined included preparation for new fuel receipt, Technical Specification review, operational preparedness, and station involvement in preoperational testing.
No violations were identified.
During preparations for receipt of new fuel, management involvement was evident through good planning with adequate procedures, equipment, training, and area preparation.
This was further evidenced in the Quality Control inspections of the new fuel after the SALP 5 period ended, when discrepancies in the fuel were identified by the licensee that were missed by the fuel supplier.
These discrepancies were:
foreign material in a fuel assembly, a dented fuel pin, and questionable orientation of the components of another fuel assembly.
A weakness in the coordination of station activities was evident in that some tests were conducted and equipment was energized by test personnel without the control room being informed.
Recent work on the reactor coolant pump seals is an example of gcod coordination between the quality control and maintenance departments; however, weakness was identified during the testing of a pressurizer safety relief valve when interface between station groups was not properly coordinated.
Although the final test results were acceptable, the first test was unacceptable and had to be repeated.
The station is not presently fully manned and a large portion of personnel are on other assignments or in training; however, manpower has been sufficient for the ongoing activities.
An effort is underway to meet future manning requirements as the station continues toward operation.
This also includes changes in management personnel, such as the recent appointment of the Station Manager and Services Superintendent which should result in improved communications.
The station currently has or is developing programs for improved licensing exam results, radiation awareness, elimination of personnel errors in operations, meeting surveillance require-ments, housekeeping, communications, and security.
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2.
Conclusion Due to limited activity in this area, the licensee is not rated.
The licensee was not rated in the previous assessment period.
Due to limited activity, no trend during this assessment period can be determined.
3.
Board Recommendations The board notes that the licensee should continue to aggressively pursue the programs discussed in the analysis to ensure an orderly transition from construction to operations.
8.
Radiological Controls 1.
Analysis Four preoperational radiation protection inspections were conducted during the assessment period by regional specialists.
Additionally, the resident inspector reviewed health physics activities related to the receipt of new fuel and a radiography incident.
No violations were identified.
Inspections of the radiochemistry and radiological environmental monitoring programs were not conducted during this assessment period.
Continued management involvement in the staffing and development of the radiation protection program has resulted in significant progress in those areas.
Management involvement is also evident in other related areas.
The initial licensee rad / chem program audit, which was conducted during the assessment period, appeared thorough.
Licensee corrective actions for this audit were adequate and timely.
The licensee made excellent use of the first Radiation Occurrence Report (ROR) as a learning exercise for the entire station.
Training and qualification of personnel is progressing according to schedule.
Staffing of the rad / chem department is over 90%
complete.
It is expected that a sufficient number of rad / chem personnel for shift staffing will receive required training and be shift qualified by fuel load.
General Employee Training (N-GET) for all employees and contractors has Neen developed and initial training is being conducted.
The radiation protection manager (RPM) has made significant progress toward completing licensee commitments for additional training and experience.
The only commitment reraaining is for the RPM to participate in the Byron refueling which is scheduled for 1986.
A training and qualification weakness evidenced when three recently trained radiation protection technicians violated a radiographer's
" Radiation Area" posting was addressed satisfactorily by the licensee.
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The licensee's responsiveness to NRC initiatives has been good.
Early NRC concerns about the RPM's training and experience, and rad / chem department staffing and training inadequacies resulted in licensee commitments to resolve those concerns.
Proposed schedules for staffing and training have been followed and improvements are evident.
Several health physics weaknesses related to the receipt of new fuel, identified by the resident inspector, were resolved prior to the receipt of the first shipment of fuel.
The licensee's resolution of technical issues is generally sound and timely.
Some design weaknesses remain in the area designated for access control activities.
The allotted space appears insufficient and will likely result in congestion during startup and refueling activities.
Improvements are being evaluated by the licensee.
Inadequacies with the respirator issue and decontamination facility due to its inaccessibility have been identified by the licensee.
A new location has been selected and construction will commence soon.
Construction modifications in the counting room and the high level chemistry lab are delaying installation, calibration, and testing of equipment in those rooms. The licensee is aware of these problems and is working on solutions.
Installation of the NUREG-0737 mandated post-accident effluent monitors, sampling systems and radiation monitors is generally adequate.
The modified Sentry high range radiation sampling system, the containment high range radiation monitors, and the General Atomic Wide Range Gas Monitors are inplace and power and sample lines are being installed.
2.
Conclusions The license is rated Category 2 in this area. This is the same rating as the previous assessment period.
Licensee performance has improved during this assessment period.
3.
Board Recommendation None.
C.
Preoperational Testing 1.
Analysis Examination of this functional area consisted of eight inspections by regional office staff members and portions of ten inspections conducted by the resident staff.
Areas examined included (1) licensee action on previous inspection findings; (2) review of preoperational test procedures; (3) witnessing of preoperational test performance; (4) preoperational test procedure verification; (5) evaluation of preoperational test results; (6) verification of preoperational test results; and (7) implementation of the preoperational test program.
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Two violations were identified:
a.
Severity Level'V - Adequate testing and acceptance criteria to verify that pump temperatures and vibrations were within design limits and the pump room cubicles do not exceed environmental qualification limits were not included in the Auxiliary Feedwater System test procedure (456/85026).
b.
Severity Level V - Inadequate implementation of the test deficiency program; (1) failure to initiate a test deficiency when required by the implementing procedures; (2) inadequate description of deficient conditions; and (3) inadequate corrective action to resolve deficient conditions (456/85026).
Violation a. identified a failure to include adequate testing and acceptance criteria in a preoperational test.
Licensee corrective action involved rescinding approval of the test and issuing a revised versi_on which included the missing acceptance criteria.
Since these acceptance criteria were included in the Byron test, to preclude further occurrences the licensee has re-emphasized the need for review and comparison of Braidwood tests with the corresponding Byron 1 test under their example test program.
Violation b. involved failure to adequately implement the existing procedures for deficiency reporting.
Corrective action by the licensee was thorough and involved retraining of personnel and a comprehensive review of previously completed test documents to correct any occurrences of similar errors.
In response to inspector concerns on both technical and procedural issues the licensee has occasionally required repeated discussions of the issue to assure clear understanding.
As a result, responses and corrective actions, while generally acceptable and thorough, are sometimes delayed and require extensions of time.
This is evidenced by the following issues:
a.
The NRC requested identification of the guidelines (ANSI 18.7 or N45.2) used to control the quality assurance program for preoperational testing.
As of January 1, 1986, approximately eleven months since the issue was identified,
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the licensee has yet to formally document their selection of quality assurance program guidelines.
b.
The technical adequacy of the containment sump testing with respect to the demonstration of vortex control was first identified in March of 1985, and was the subject of a subsequent inspection in July.
As of January 1, 1986, the licensee has not proposed a resolution of the issue.
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In March of 1985, the licensee presented a comprehensive action plan designed to improve preoperational testing performance.
Follow-up inspections have shown that the licensee has adequately
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implemented a majority of the program elements.
The notable exception is the development, review approval, and issue of parallel Byron /Braidwood Startup Manuals.
As of January 1,1986, this effort had not proceeded beyond the review and comment phase.
Two 10 CFR 50.55(e) reports were submitted relating to this area regarding (1) failure of the diesel generators to sustain adequate fuel prime and (2) faulty diesel generator tachometers.
Preoperational testing activities have been restricted for the past eight months by Human Factors modifications to the control room.
Prior to commencement of the control room modifications the licensee had conducted Engineered Safety Features (ESF)
testing involving the Diesel Generators and the Emergency Core Cooling Systems.
As of January 1,1986, the results of these tests had not been accepted by the Project Engineering Department (PED).
The potential impact on the test program schedule of possible retesting and resolution of issues resulting from the PED review is considered significant.
NRC inspection efforts have been confined to the programmatic aspects of the organization and monitoring of action plan implementation.
Review of certification training and personnel qualifications coupled with limited observation of testing activities indicate that staffing levels are adequate and personnel are adequately qualified and properly certified to conduct the preoperational test program.
2.
Conclusion The licensee is rated Category 2 in this functional area.
This is the same rating as the previous assessment period.
Due to limited testing activities, no trend during this assessment period can be determined.
3.
Board Recommendations None.
D.
Fire Protection 1.
Analysis During this assessment period, one special inspection was conducted by Region III personnel to assess the licensee's conformance to fire protection requirements for receipt and
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storage of new fuel onsite.
No violations or deviations were identified.
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The scope of this inspection was limited to the new fuel storage area and certain specific fire protection features.
For the areas assessed, the licensee's plans for making the required fire protection features operational prior to receipt of fuel onsite were determined to be satisfactory.
An assessment of the Appendix R requirements of the licensee's fire protection program implementation was not made during this assessment period.
There-fore, a comprehensive evaluation of the licensee's performance in this functional area is not being made.
2.
Conclusion The licensee is not rated in this area due to the limited scope of the one inspection that was conducted.
The licensee was not rated in the previous assessment period.
Due to the limited inspection activity, no trend during this assessment period can be determined.
3.
Board Recommendations None.
E.
Analysis Two inspections were conducted during the period.
The purpose of the first inspection was to determine an appropriate period for conducting the preoperational Emergency Preparedness Implementa-tion Appraisal.
Based on the licensee's current schedule for completing training of all members of the onsite emergency organization, a two-week period beginning in late March or April 1986 was tentatively scheduled for conducting this appraisal.
The second inspection was the observation of the licensee's first emergency preparedness exercise.
The exercise's scope and objectives and a complete scenario package were submitted by the deadlines set in NRC guidance.
The licensee provided timely, technically sound responses to most of the staff's questions on the scenario information.
However, the final scenario contained several errors which resulted in some confusion during the exercise.
Revision 1 of the Braidwood Annex to the generic Generating Stations Emergency Plan (GSEP) had not been made available for staff review as early as had been anticipated.
During preparation of Chapter 13.3 of the Braidwood SER, the staff noted some inconsistencies between statements contained in the GSEP and Revision 0 to the Braidwood Annex.
The licensee's proposed changes to eliminate these inconsistencies were acceptable.
However, Revision 1 to the Annex, which the licensee had stated would be issued about October 1985, was not received by the staff during the assessment period.
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The licensee has adequate numbers of personnel to fill well-defined, key positions in the emergency organization.
All emergency preparedness training for all members of the onsite emergency organization is scheduled to be completed by April 30, 1986.
All emergency preparedness training had already been completed by those Station personnel who had been designated as exercise participants.
With very few exceptions, exercise participants successfully demonstrated their abilities to adequately perform their emergency responsibilities, despite the fact that the Station's GSEP Coordinator had conducted the bulk of the specialized emergency preparedness training in addition to her other duties.
The over reliance on the GSEP Coordinator to personally conduct so much of the specialized training was due, in part, to a turnover in Training Department staff and a delay in the issuance of standardized lesson plans from the licensee's Production Training Center.
The Coordinator's efforts were also hampered by the time demands placed on proposed members of the onsite emergency organization to complete other duties.
2.
Conclusion The licensee is rated Category 2 in this area.
The licensee was not rated in the previous assessment period.
Due to limited inspection activity, no trend during this assessment period can be determined.
3.
Board Recommendation None.
F.
Security 1.
Analysis One routine preoperational inspection was conducted by a regional inspector during the early part of the assessment period.
This initial inspection concentrated on the adequacy of the licensee's planning and scheduling for program implementation.
The licensee's security requirements become effective upon issuance of an operating license; therefore, no violations were identified in the assessment period.
Major elements of the security program were identified and included in a program implementation schedule which was found to be acceptable.
The Physical Security Plan, the Security Personnel Training and Qualification Plan, the Safeguards Contingency Plan, and the Security Plan for Special Nuclear Material were approved by NHSS during the assessment period.
There was evidence of prior planning by licensee (usually including corporate level)
management.
Responses regarding safeguards matters were technically sound and consistent, demonstrating the existence
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of policies and procedures for control of security related activities.
Solutions to technical safeguards issues were sound, timely, and conservative, indicating an understanding of the issues.
Resolutions were submitted promptly, and in most cases, were acceptable the first time.
Security organization management positions and responsibilities were well defined.
The security staff is considered to be more than ample to implement the facility physical protection program.
2.
Conclusion Due to limited inspection activity in this area, the licensee is not rated.
The licensee was not rated in the previous assessment period.
Due to limited inspection activity, no trend during this assessment period caa be determined.
3.
Board Recommendations None.
G.
Quality Programs and Administrative Controls Affecting Quality 1.
Analysis Examination of this functional area consisted of nine inspections by the resident inspection staff, seven inspections by the regional based staff, and a portion of the CAT inspection.
Areas examined included (1) cleanliness inspections of piping and safety-related components; (2) allegations; (3) Quality First Program; (4) alcohol and drug policies; (5) hydrogen recombiner power and control cabinet; (6) disposition of nonconformances; (7) material traceability; (8) design change control; (9) corrective action systems; (10) project management; (11) Quality Control Inspector Reinspection Program; (12) 10 CFR 50.55(e) reporting; (13) preoperational and operational quality assurance program; (14) procurement; (15) licensee auditing of contractor a'ctivities; and (16) trending.
Seven violations were identified:
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a.
Severity Level IV - Ceco placed purchase orders for pipe cleaning with an unapproved bidder that did not have a quality assurance program.
Furthermore, the purchase orders were not reviewed and accepted by the Ceco Quality Assurance Department (456/84017; 457/84017).
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b.
Severity Level IV - 337,350 feet of pipe which was rejected due to rust, scale, and failure to cap the pipe ends was not placed ur. hold to prevent installation in safety related systet..i.
In addition, the rejected pipe was not properly dispos.itioned in that only 206,744 feet of pipe was chemically
cleaned (456/84017; 457/84017).
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c.
Severity Level IV - Quality control inspe:tions of internal cleanliness had not been formulated during the installation process to assure the absence of corrosion, pitting, and contaminants including foreign objects (456/84021; 457/84020).
d.
Severity Level V - A hydrogen recombiner power and control cabinet was received without required documentation and was subsequently released for installation (456/84034).
e.
Severity Level IV - Sargent and Lundy calculations which provided the original justification for the 9 factor design methodology and magnitude were not retrievable (456/84043; 457/84039).
f.
Severity Level V - CECO employed designs for safety-related HVAC duct supports which did not limit the slenderness ratio for ceiling mounted duct supports (456/84043; 457/84042).
g.
Severity Level IV - The licensee's QA organization inappropriately closed a nonconformance report (456/85015).
Violations a. and b. related to the pipe corrosion problem which was reported to the NRC prior to the assessment period per 10 CFR 50.55(e) (84-10).
The purchase orders referenced in Violation a. were placed in mid-1981.
Additionally, the deficiencies related to Violation b. occurred prior to the assessment period.
The licensee's final report on the corrosion problem was issued subsequent to the assessment period.
Violation c. resulted from deficiencies which existed prior to the assessment period and the licensee has implemented a system flushing program to resolve this item.
The equipment referenced in Violation d. was received in mid-1981.
Violations e. and f.
are discussed below.
Violation g. was an isolated case involving one NCR; however, NRC review of the licensee's corrective actions had not been completed at the end of the assessment period.
During the assessment period, the licensee implemented the Quality First program as a mechanism for employees to report safety concerns to the licensee.
Interviews are conducted with employees on a scheduled basis and exit interviews are conducted with all persons terminating employment.
The Quality Control Inspector Reinspection program is designed to confirm, through reinspection, the effectiveness of contractors'
certification programs for quality control inspectors for the period prior to late 1982.
The reinspections are performed by qualified inspectors, other than those who did the original inspection.
BCAP determined that when implemented, the program can be expected to provide the desired confidence in the adequacy of the inspector certification method which was used in the period of interest.
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Several allegations were reviewed which did not result in violations relating to (1) deficiencies in the design calculations for the primary shield wall; (2) 1/4" expansion anchor bolts holding electrical, HVAC, instrumentation and mechanical panels to floors and walls being underdesigned; (3) use of salt in parking lots; (4) construction equipment damage and thefts; and (5) abuse / dealing of alcohol and drugs.
One allegation reviewed concerning inadequate piping wall thickness was previously idei.tified by Violations a. and b.
One inspection reviewed concerns expressed by the expert witness for the Intervenors during the remanded ASLB hearing for the Byron Station related to Sargent and Lundy design criteria and calculations, computer programs, and several other areas.
Two of the concerns resulted in violations e. and f.
The licensee's response and corrective actions related to these violations were reviewed and found to be acceptable.
In addition to the violations, a number of design practices were found to be in need of improvement.
During the inspection, appropriate corrective actions were taken by the architect engineer to implement the needed improvements in the design process.
Two 10 CFR 50.55(e) reports were submitted in this area regarding (1) containment sump isolation valves were determined to not be seismically qualified in their installed configuration and (2) certain postulated high energy line breaks in the auxiliary building were evaluated for potential environmental effects on safety related equipment using information which has been shown to be inaccurate.
On March 15, 1985, the licensee discussed actions which were taken to improve performance in this functional area.
These included improvements in the CECO QA organization, staff size and experience, site audit program, and improved interface with operations QA.
The actions taken appear to be effective.
Additionally, the licensee implemented the Braidwood Construction Assessment Program which is discussed under Section 0.
The CAT inspection concluded that there was no pervasive breakdown in meeting construction requirements in the samples of installed hardware inspected by the team or in the applicant's project construction controls for managing the Braidwood project.
2.
Conclusion The licensee is rated Category 2 in this area.
The licensee was rated Category 3 in the previous assessment period.
Licensee performance has improved during the assessment period.
3.
Board Recommendations
None.
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H.
Licensing Activities 1.
Analysis During the evaluation period there was a significant level of activity.
Substantial effort was expended in preparing for the Braidwood OL hearing, which commenced on October 29, 1985. The low power license for Byron 1 was issued on October 31, 1984 and the full power license was issued on February 14, 1985.
Consequently, many issues common to both Byron and Braidwood were addressed during this evaluation period.
A number of site-specific issues concerning Braidwood were also addressed.
The first draft of the Braidwood Technical Specifications was issued on October 7, 1985 for review and comment; the second draft was subsequently issued on January 13, 1986.
The licensee's decision making is usually at a level that ensures adequate management review.
The submittals needed to support licensing were generally timely, thorough and technically sound.
Upper management was available to resolve concerns and took an active role on certain actions, such as the action concerning pipe whip restraints using energy absorbing material and safety-related D. C. systems.
The licensee demonstrated a good understanding of the technical issues under review. Their approach to the resolution of technical issues was generally sound and thorough; conservatism was exhibited and approaches were viable.
In several instances, j
the licensee challenged staff positions, but only when it believed safety would not be compromised.
In the weeks prior to issuance of the low power and full power licenses for Byron Unit 1, the licensee had to respond to many NRC initiatives common to both Byron and Braidwood in a short period of time.
The licensee responses were generally timely, sound and thorough.
I Key positions are clearly identified and responsibilities and authorities are well defined for both the plant staff and the licensing department.
The security organization positions and responsibilities are well defined; the security staff is considered to be more than ample to implement the facility physical protection program.
The licensee has developed a comprehensive Shift Experience Program for Braidwood Station.
The program is designed to give senior operators on shift additional supervisory training at an operating PWR (Zion Station) such that they can satisfy the hot
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participation requirements of Generic Letter 84-16.
This program is scheduled to be completed by June 1986.
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2.
Conclusion The licensee is rated Category 2 in this area.
This is the same rating as the previous assessment period.
Licensee performance has remained the same during the assessment period.
3.
Board Recommendations None.
I.
Containment, Safety-Related Structures, and Major Steel Supports 1.
Analysis Examination of this functional area consisted of nine inspections by the resident inspection staff, four inspections by the regional based staff, and a portion of the CAT inspection.
Areas examined included (1) previous inspection findings and reportable items; (2) structural steel and supports; (3) allegations regarding defective block wall columns; (4) design change to a reactor coolant pump lateral support; (5) concrete drilling and coring; (6) IE Bulletin 79-02; (7) concrete; (8) masonry walls; (9) concrete expansion anchor bolts; (10) reinforcing steel configuration; (11) cadwelds; (12) allegation concerning undocumented removal of welds from structural steel;
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(13) modifications to beams; (14) battery room walls;
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(15) installed bolts for the steam generator inner frame support columns; (16) containment coatings; (17) apparent concrete
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deficiencies in the Unit 1 refueling water tunnel and its attachment to the refueling tank slab; (18) polar crane bolting; (19) structural bolting and welding; (20) grout testing; j
(21) trending; and (22) containment tendons.
i Four violations and one example were identified:
a.
Severity Level V - One example involving a welding procedure which was not approved by the architect engineer, but was released for use, and was used for cover plate welds (456/84017; 457/84017).
b.
Severity Level IV - One hundred and twenty structural steel fillet welds were painted prior to acceptance of the work and the welds were subsequently visually inspected for acceptance, with 79 accepted in the painted condition; and visual weld inspections were not performed on full penetration welds (456/84021; 456/84020).
c.
Severity Level IV - A reactor coolant pump lateral support anchorage was Installed without certain records (456/84021; 457/84020).
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d.
Severity Level V - Three safety-related structural beams had openings cut into them to allow the routing of 4" diameter nonsafety-related drain pipe through the web of the beam (456/85015; 457/85016).
e.
Severity Level V - Repairs to containment coatings were A
performed utilizing an unqualified coating system (456/85015; 456/85016).
The inadequate welding controls in Violation a. resulted in additional inspections by the licensee.
As a result of the licensee's inspection a stop work order was issued for structural
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welding and a 10 CFR 50.55(e) report was submitted early in the assessment period.
After the licensee completed the necessary corrective actions, including the retraining of engineering and craft personnel, the stop work order was lifted.
The
deficiencies did not result in defective hardware.
One
additional 10 CFR 50.55(e) report regarding concrete expansion anchor inspection deficiencies was submitted during this assessment period.
The inspection of pa*1ted welds in Violation b. was an isolated occurrence in that the deficient practice was limited to a one week period in 1980.
The paint was removed and reinspections a
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were performed.
The licensee took prompt corrective actions to resolve the concern regarding lack of visual inspection of full penetration welds.
The installation in Violation c. occurred in 1980 and the contractor is no longer on site.
Violation d.
resulted in a complete licensee inspection of the nonsafety-related drain piping system which identified 49 beams with j
unauthorized holes.
The drain piping system was installed prior to the assessment period.
None of the holes were determined to l
be design significant; however, two were reinforced to increase j
their design margin.
The repairs identified in Violation e, occurred in 1978 and 1979.
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An allegation regarding defective welding on block wall columns
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was substantiated; however, the licensee had previously
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identified and reported this deficiency to the NRC in 1982.
A l
second allegation regarding the undocumented removal of welds from structural steel was substantiated and the contractor took appropriate corrective actions to resolve the concern.
A third
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allegation concerning holes burned in steel was' substantiated; however, the deficiencies were previously identified by the I
contractor on nonconformance reports.
Two corrective action programs in this area, the Quality Control j
Structural Steel Review and NSSS Component Supports Verification, j
were determined to be adequately implemented by BCAP.
l The inspectors determined that significant deficiencies were reported in a timely manner, were accurately described, and the i
resulting reviews were effective and technically sound.
j Activities in this functional area were controlled through the l
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l use of well stated and defined procedures.
Installation and inspection records were found to be generally complete, well
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maintained and available.
Licensee resources appeared to be appropriate for the activities performed in the area.
The number of structural QC personnel was increased from 14 to 39 during the assessment period.
Licensee management aggressively addressed the NRC identified violations, open items, and unresolved items.
2.
Conclusion The licensee is rated Category 2 in this area.
This is the same l
rating as the previous assessment period.
Licensee performance l
has remained the same during the assessment period.
3.
Board Recommendations None.
J.
Pipina Systems and Supports 1.
Analysis Examination of this functional area consisted of eleven inspections by the resident inspection staff, eight inspections by the regional based staff, and a portion of the CAT inspection.
Areas examined included (1) activities as they relate to preservice inspection including review of equipment and material certifications, personnel qualifications and selected records of t
nondestructive examinations, and observation of the ultrasonic l
examination of several reactor coolant pump bolts; (2) a meeting
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with the National Board of Boiler and Pressure Vessel Inspectors to discuss NRC concerns about ASME work; (3) review questions concerning two radiographs of welds on ESW piping; (4) observation of piping system installations, visual examination of completed welds and review of installation records, radiographs, and associated documentation for reactor coolant pressure boundary and other safety-related piping; (5) examination of the installation and inspection of piping supports / restraints including a review of procedures and instructions, and selected installation records and associated documentation; (6) Material Traceability Verification (MTV) program and inspection of a i
randomly selected sample of " Stores Request" and associated documentation to verify the licensee actions concerning the MTV Program; (7) independent measurements of piping components; (8) followup on licensee actions related to previous inspection findings and IE Bulletins; (9) inservice inspection drawing control; (10) bolted connections; (11) 10 CFR 21 reportability procedure review; and (12) hydrostatic test review.
Four violations and two examples were identified:
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J a.
Severity Level IV - A piece of pipe was-found to violate minimum wall requirements and was not reported to the owner in accordance with 10 CFR 21.21 (456/84021; 457/84020).
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b.
Severity Level V - For AISC steel welds, not under the jurisdiction of the ASME Boiler and Pressure Vessel Code,Section III, the piping contractor did not have an AWS visual weld examination procedure (456/84034; 457/84032).
c.
Severity Level IV - Inadequate control of diesel fuel oil piping which contained rust and scale (456/84042; 457/84038).
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d.
Severity Level IV - An example in which the licensee's inspection program did not identify some areas where weld sizes in structural pipe support / restraints did not have i
the weld configuration required by design (456/84044;
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457/84040).
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I c.
Severity Level V - One example concerning failure to have a l
procedure that stipulates the method for producing an
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accurate inservice inspection drawing (456/85007; 457/85007).
t f.
Severity Level IV - The piping contractor performed a design
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function by modifying several riser clamps without being
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directed by or receiving approval of the responsible design l
organization (456/85041; 457/85040).
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Corrective actions for violation a. were completed and the issue was satisfactorily resolved.
Violations b.,
d., and f. are currently being evaluated by the NRC for the acceptability of the
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corrective actions.
Violations a., b., ar.d d. required supplemental training of personnel to preclude additional deficiencies.
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Three 10 CFR 50.55(e) reports were submitted in this area l
regarding (1) ASME NPT symbol nameplates were removed from piping
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subassemblies without proper controls and documentation and
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nondestructive examinations required by ASME Section III of the nameplate removal areas were.not subsequently performed; (2) a
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sample review of records of past site procured ASME material has indicated that the records do not always indicate that the j
material was supplied in accordance with the ASME Material
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I Manufacturers and Material Suppliers Quality System Program
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Requirements; and (3) during testing of energy absorbing material, it was discovered that some material used in pipe whip restraints i
had a lower than specified crush strength.
Several allegations were inspected during this assessment period
including (1) pipefitters and supervisors of the mechanical
contractor were unqualified; (2) pipe being improperly installed
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with a "come along," pipes were mishandled causing the pipe bevels j
to be banged and pipes were installed backwards; (3) a person who
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j was a poor worker was working as a quality control inspector; i
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(4) an improperly terminated employee; (5) a pipe support was not producing a clamping force on the valve being supported and the support was unstable in compression; and (6) a piping thickness measuring technique was altered so that deficiencies were no longer apparent.
None of these allegations were substantiated or resulted in violations.
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The Material Traceability Verification Program (MTV) was established to provide 100% verification of ASME Section III large bore piping installed prior to January 1, 1983 and ASME Section III small bore piping installed prior to September 6, 1983.
This program was completed and the final report was submitted during the assessment period.
Subsequent to the assessment period, the NRC review of the licensee's final MTV report was completed.
The review determined that the MTV program was acceptable, the unresolved items were adequately addressed, and the program established traceability for the items in question.
The approach used to evaluate LiTV discrepancies and findings was generally conservative, technically sound and thorough.
BCAP determined that this program was adequately implemented.
Additionally, the safety-related Pipe Supports Program was reviewed by BCAP and determined to be adequately implemented.
Both in 1983 and 1984, the NRC identified concerns with piping clearance deficiencies.
Not until September 1984 were there adequate provisions for contractor verification of clearances between piping and other components or structures.
A final walkdown program is planned by the licensee to resolve these deficiencies.
During the first half of the assessment period, the Construction Appraisal Team and resident staff noted numerous cases of poor construction practices, such as scaffolding supported by piping lines or piping lines supported by other piping lines instead of by temporary supports.
During the last half of the assessment period management involvement has been evident and the resident
staff has noticed only isolated cases of unauthorized supports for piping lines or piping supporting scaffolding.
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On March 15, 1985, the licensee discussed actions which were
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taken to improve performance in this functional area.
The actions taken appear to be effective.
The piping contractor has added a significant number of experienced personnel to their quality control department, which has resulted in an overall trend of self identification of nonconforming conditions for corrective action.
The number of piping QC personnel ir. creased from 147 to 305 during the assessment period.
The new personnel are experienced in regulatory requirements and industry practices.
This has resulted in a significant upgrading in the piping contractor's performance.
Training of craftsmen and quality
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control personnel has increased during the assessment period, resulting in added awareness of quality practices both in the installation and inspection disciplines.
The actions taken indicate that management is responsive to NRC concerns and is committed to quality.
In the area of preservice inspection, inspection equipment was found to be appropriately certified and personnel performing the inspection's were trained and certified.
The NRC performed independent measurements of a selected sample of piping in resolving the allegation concerning the piping thickness measuring technique.
The independent measurements were in agreement with the licensee's measurements.
In general, work activities in this functional area were adequately controlled through the use of well stated and defined procedures.
The management control systems were effective in that activities had received prior planning and priorities had been assigned.
Installation, inspection, and certification records were found to be generally complete, well maintained, and available.
Observations indicate that personnel have an adequate understanding of work practices.
Review of construction deficiency reports and IE Bulletin actions indicated that the licensee understood the issues and their reviews were generally timely, thorough, and technically sound.
The licensee requested the National Board of Boiler and Pressure Vessel Inspectors to conduct an independent audit to address
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specific NRC concerns regarding ASME work.
No significant deficiencies have been identified by the National Board.
2.
Conclusion The licensee is rated Category 2 in this area.
The licensee was rated Category 3 in the previous assessment period.
Licensee performance has improved during this assessment period.
l 3.
Board Recommendations t
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None.
K.
Safety-Related Components - Mechanical 1.
Analysis Examination of this functional area consisted of seven inspections by the resident inspection staff, three inspections by the regional based staff, and a portion of the CAT inspection.
Areas examined included (1) eddy current examination of steam generator tubes; (2) review of reactor vessel fabrication documentation and
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radiographs; (3) licensee actions on IE Bulletins; (4) mechanical l
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equipment installations; (5) environmental qualification of containment spray pumps; (6) previous inspection findings; (7) preventative maintenance; (8) reactor vessel internals; and (9) welding of tanks and heat exchangers.
One violation and one example were identified:
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a.
Severity Level IV - Welding on a number of vendor procured tanks and heat exchangers was not in accordance with the vendor drawings, and a number of vendor supplied radiographs did not have the film quality required by the vendor specifications (456/84044; 457/84040).
b.
Severity Level V - One example regarding the inadequate l
installation of the Containment Spray pump support and anchor bolt hold down plates (456/85007; 457/85007).
Violation a. resulted in a 10 CFR 50.55(e) report and the licensee's corrective actions have not yet been reviewed.
The base supports for the Containment Spray pumps, identified in Violation b., are being modified to conform to drawing requirements.
One other reportable deficiency was identified in this area concerning preservice nondestructive examination which identified one rejectable indication in the Loop 2 inlet nozzic-to-vessel shell weld on the Unit 2 reactor vessel.
l Prior to September 1982, the piping contractor had installed safety-related mechanical equipment without adequate procedures.
The piping contractor wrote new equipment installation procedures which contained rr. ore detailed installation and inspection criteria specified by the design drawings and specifications.
Tna piping contractor used these new procedures to inspect all safety related mechanical equipment installations performed prior to September 1982.
These inspections have been completed.
Installations are being reworked where necessary to conform to drawing and specirication requirements, including replacement of anchor bolts due to deficiencies in either the original l
Installation or documentation.
The Reinspection of l
Safety-Related Equipment program is proceciurally controlled and l
is staffed with experienced personnel.
This program was in the process of being upgraded at the. time of the BCAP review; however,
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a followup review by BCAP indicated that as a result of the upgrading, the program will be offective.
l Nondestructive examinations were controlled through the use of well stated and defined procedures.
Installation and inspection records were found to be generally complete, well maintained, and available.
Ncndestructive examination equipment certifications were current and complete and the perscanel performing these examinations were trained and certified.
Licenste resources appeared to be appropriate for the activities performed in this
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area.
Deficiencies, when identified, were promptly reported and the analyses of these reported deficiencies were consistently found to be adequate.
Management showed aggressive involvement in the resolution of identified deficiencies.
On March 15, 1985, the licensee discussed actions which were taken to improve performance in this functional area.
These actions are discussed further in Section J., Piping Systems and Supports..The actions taken appear to be effective.
2.
Conclusion The licensee is rated Category 2 in this area.
The licensee was rated Category 3 in the previous assessment period.
Licensee performance has improved during the asscssment period.
3.
Board Recommendations None.
L.
Auxiliary Systems 1.
Analysis Examination of this functional area (HVAC) consisted of four inspections by the resident inspection staff, two inspections by the regional based staff, and a portion of the CAT inspection.
Areas examined included (1) the HVAC contractor's QA program; (2) procedures; (3) welding activities; (4) previous inspection findings; (5) documentation packages; (6) hardware installations; and (7) nonconformance reports and corrective action requests.
Two violations were identified.
a.
Severity Level V - Several companion angle to duct welds were completely cracked resulting in no bonding (456/84034; 457/84032).
b.
Severity Level V - Failure to follow procedures in that two Corrective Action Requests were closed by Pullman QA prior to verifying that the corrective action was implemented; and the Pullman nonconformance procedure does not require potentially reportable deficiencies to be submitted to the licensee (456/85038; 457/85037).
In response to Violation a., the licensee has established a reinspection and testing program to address the structural adequacy of the HVAC duct supports.
In response to Violation b.,
the licensee promptly performed surveillances and revised the applicable procedure.
Three HVAC 10 CFR 50.55(e) reports and NRC inspection findings identified prior to the assessment period, have been combined into the HVAC Retrofit program.
BCAP determined that this program was effectively implemented and documented.
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The HVAC contractor has upgraded their quality control program in the area of welding controls and inspections.
The number of HVAC QC personnel increased from 21 to 32 during the assessment period.
HVAC supports / restraints generally conformed to design and procedural requirements.
Inspected welding activities were found to comply with the requirements and were controlled through the use of well stated and defined procedures.
Records were found to be generally complete, well maintained, and available.
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The records also indicate that welders were trained and certified.
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2.
Conclusion The licensee is rated Category.2 in this area.
This is the same rating as the previous assessment period.
Licensee performance has remained the same during the assessment period.
3.
Board Recommendations None.
I M.
Electrical Equipment and Cables 1.
Analysis (
Examination of this functional area consisted of eight inspections by the resident inspection staff, thirteen inspections by the regional based staff, and a portion of the CAT inspection.
Areas examined included (1) review of previous inspection findings; i
j (2) welder qualifications; (3) observation of work activities, review of records, and QC personnel qualifications; (4) cable
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pulling, routing, and terminations; (5) raceway and conduit i
installations, (6) welding procedures; (7) electrical equipment i
installations; (8) welding; (9) reinspection programs and inspection backlog; (10) allegations; (11) corrective action
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programs; (12) electrical separation; (13) independent design review; (14) calibration and control of electrical test and
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measuring equipment; (15) motor operator valve (MOV) torque
switch settings; (16) equipment protective relay settings; (17) DC distribution panel breaker testing; and (18) control room i
chillers.
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Eleven violations and one example were identified:
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a.
Severity Level V - Two cables were not routed per the pull
cards, and the quality c.ontrol inspector accepted the cable
pulls (457/84029).
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b.
Severity Level V - No corrective action documents were written for loose crimps at penetration terminal blocks; cables were not terminated and were tagged with uncontrolled tags (457/84036).
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c.
Severity Level IV - Wire had been installed without qualification; Class 1E seismic cable tray hangers did not utilize ASTM A307 fasteners in some cases; and Class 1E battery racks were found to have bolting material that did not meet the requirements of ASTM A307 (456/84044; 457/84040).
d.
Severity Level IV - An example in which the licensee's inspection program did not provide sufficient electrical separation acceptance criteria to verify that design requirements had been met (456/84044; 457/84040).
e.
Severity Level IV - The electrical contractor's corrective actions for two NCRs were inadequate (456/84044; 457/84040).
f.
Severity Level V - Failure to follow procedures in that a welder qualification record was signed and dated prior to testing of the welder's coupons and welder qualification records exhibited numerous clerical errors and omissions (456/85009; 457/85009).
g.
Severity Level V - The electrical contractor inspected and accepted a junction box which was later determined to have deficiencies in the location of the anchors (456/85015).
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Severity Level V - Failure to qualify personnel in
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accordance with procedures (456/85021; 457/85022).
i 1.
Severity Level V - The licensee could not provide documented
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evidence that rejected hanger welds were appropriately dispositioned (456/85021; 457/85022).
j.
Severity Level IV - Failure to set MOV torque switch settings in accordance with engineering or vendor required set point values (456/85048; 457/85047).
k.
Severity Level IV - Several instances were identified where a reinspection program failed to identify replacement of i
butt splices in control panels and replacement of unqualified internal wiring inside MOV limit switch compartments (456/85048; 457/85047).
1.
Severity Level IV - Soveral wiring discrepancies wara identified between connection diagrams and field installations (456/85048; 457/85047).
Violation a. was an isolated occurrence, the cable routings have been corrected, reinspection was performed, and retraining was conducted.
Violation b. was an isolated occurrence and the contractor promptly issued documents to track the deficiencies.
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The first example of Violation c. resulted in the licensee removing all unqualified switchboard wire inside containment (harsh environment); however, the licensee has stated that they i
will not replace the wire in the auxiliary building.
Acceptability of this position is under review by NRR.
The i
second example of Violation c. resulted in the issuance of two nonconformance reports.
One of the nonconformance reports has been dispositioned.
Licensee identification and resolution of the electrical separation violations related to Violation d. is an ongoing
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program.
Resolution of all separation violations will be
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completed by fuel load.
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Violations e. and f. occurred prior to the assessment period and were determined to be isolated.
Violation g. occurred during the assessment period but was determined to be isolated after the licensee reinspected all junction boxes which were accepted by the involved inspector.
Violation h. was determined to be isolated after the contractor QC Manager performed a review of inspector certifications.
Violation i, occurred prior to the assessment period and the contractor issued documentation to repair the deficiencies.
The corrective actions for Violations j.,
k., and 1. have not been reviewed since the inspection report was issued after the assessment period.
As noted in the previous assessment period, numerous problems were identified with QC inspections, drawings, installation of hardware and missing or incomplete QC records.
The previous report documented an increase in licensee and contractor QC
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personnel.
The increase in staff was necessary to maintain pace with the numerous and comprehensive electrical reinspection programs.
During this assessment period QC personnel staffing was further increased from 83 to 122.
The reinspection and corrective action programs are briefly described below:
LKC Records Review - During previou:, NRC inspections, CECO
QA Audits and LKC QA audits, it was identified the the LKC quality records were incomplete, missing or misfiled.
LKC determined that the total number of documents to be reviewed was 105,708.
The contractor completed their review of all quality documents in December 1985.
The scheduled completion date for the reconciliation of those documents found unsatisfactory is planned by March 1986.
The BCAP review of this program determined that it is being properly implemented.
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Electrical Butt Splices - The licensee and the NRC
identified that LKC procedures did not include the manufacturer's installation instructions or inspection criteria for conductor butt splices.
The licensee is approximately 90% complete in the butt splice corrective action program.
This 1.em was reported per 10 CFR 50.55(e)
during the assessment period.
Hanger Configuration Inspection - Prior to November 1982,
LKC QC was only inspecting 35% of the installed electrical raceway hangers for proper configuration.
Presently, S&L personnel and LKC QC inspectors are walking down all the electrical raceway hangers in the plant and documenting the as-built configuration.
Avoid Verbal Orders (AVO) Inspection Program - The licensee
identified that work activities were being directed by AV0's with no subsequent QC inspection to verify that work had been accomplished.
The licensee identified approximately 4400 AV0's that had been prepared to direct work.
The licensee estimated an expected completion date of March 1986.
Interaction Analysis - During previous inspections it was
observed that the licensee did not have an interaction analysis program to address Regulatory Guide 1.29 " Seismic Design Classification." Sargent and Lundy's final walkdown is planned to start six months prior to fuel load.
Drawing Review Program - The electrical contractor has had
difficulties in the past assuring that all installations have been accomplished in accordance with the latest revision of the drawing.
This program is being developed to assure that installations and inspections were done to the current drawing revision.
Two 10 CFR 50.55(e) reports were issued in this area (1) electrical butt splices were not installed per the manufac-turer's installation instructions; and (2) certain breakers supplied with Westinghouse motor control centers did not meet the specification.
One inspection was conducted early in the assessment period to review 10 allegations from an electrical QC inspector who was terminating employment.
Eight of these were substantiated.
The allegations related to reports being misfiled; multiple inspection reports on hangers; corroded hangers, cable pan, conduit ground straps, and junction boxes; hangers mislabeled or misplaced and conduits installed on wrong hangers; housekeeping; weld rod control; in process welding; stud welding; document control; cracks in floors and walls; and drug and alcohol abuse.
No viciations were identified.
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One inspection was conducted to review 27 allegations concerning electrical contractor welding activities.
Some of these allegations were substantiated.
Two of the allegations resulted in Violation f.
l Other allegations reviewed and substantiated include a QC supervisor who was not certified as a Level II inspector in
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certain areas; two QC inspectors who were selected as lead inspectors were not qualified (this resulted in Violation h);
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some QC inspectors are being qualified and certified in the areas of welding and configuration in one week; a QC supervisor was constantly intimidating and harassing the electrical l
inspectors to sign off documents (the supervisor was subsequently
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dismissed and a supervisor training program was implemented); and
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Quality First had not addressed the electrical inspectors'
concerns (it was determined that Quality First had not finished their review at the time the allegations were made).
Other allegations reviewed and not substantfated include the electrical rework program was full of loopholes, documentation I
flow through QC was not clear in the procedure, and basemetal inspections were not done; recently certified inspectors were rushed through the training program; QC was under production pressure; QC inspectors were not properly trained in conduit specifications; numerous inspections involving 1100-1200 welds were signed off in one day (Violation 1. was identified during the review); a QA engineer was assigned to the records vault for the sole purpose of closing nonconformance reports; hangers were not inspected; a QC inspector was constantly watched and was transferred to the record vault after visiting the NRC office; a QC inspector cannot remain proficient in all areas without a decrease in the quality of inspections; the electrical contractor promised more money to inspectors who were certified in multiple areas; lead inspectors were picked as leads based on who was signing off the most documents; NCRs have been dispositioned as
" retrain inspectors"; some NCRs had been dispositioned by Field Engineering without involvement of QC inspectors; overtime was not paid to inspectors who did not meet quotas; the inspectors l
were going to walk out if three inspectors were terminated; two NCRs were inappropriately dispositioned; a QC supervisor continually violated procedures during inspector certifications; there were no certified calibration inspectors; a QC supervisor
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lied to get a QC inspector fired; and inadequate Hylar and ECN controls.
In general, most of the allegations reviewed did not result in I
violations for one or more of the following reasons:
(1) the licensee was in the process of taking corrective action; (2) the
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alleger was not knowledgeable in procedures or specifications; or (3) the concern did not violate a commitment or regulatory requirement.
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Procedure controls for electrical work activities appear to be adequate.
A comprehensive, documented craft training program was established and implemented during the assessment period.
The program was reviewed by the NRC and was found to be satisfactory.
The above reinspection and corrective action programs indicate multiple discrepancies pertaining to electrical construction activities due to ineffective quality programs in previous assessment periods.
However, licensee management has taken
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aggressive steps to resolve these quality issues.
Many of the violations issued during the assessment period were for deficiencies which existed in previous assessment periods and have been corrected or were isolated occurrences.
The licensee generally takes adequate corrective action on technical issues l
and has been responsive to NRC initiatives.
Personnel staffing l
appears to be adequate to complete the corrective action and l
reinspection programs without degrading the quality of ongoing j
work activities.
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2.
Conclusion The licensee is rated Category 2 in this area.
This is the same rating as the previous assessment period.
Licensee performance has remained the same during the assessment period.
3.
Bocrd Recommendations None.
N.
Instrumentation 1.
Analysis Examination of this functional area consisted of eight inspections by the resident inspection staff, seven inspections by the regional based staff, and a portion of the CAT inspection.
Areas examined included (1) instrument piping and tubing; (2) previous inspection findings; (3) licensee audits; (4) procedure reviews; (5) Instru-l i
mentation Installation Verification Program; (6) instrument l
supports and racks; (7) transmitter installations; (8) procurement; I
(9) instrument cables and terminations; (10) instrument loop l
testing; (11) procurement and receipt inspection; and (12) an l
allegation concerning the nonsafety-related portion of the instrument air system.
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One violation and one example were identified.
a.
Severity Level V - One example regarding two completed socket weld joints which did not have records identifying the welder or weld filler metal (456/84017; 457/840.*.7).
l b.
Severity Level V - Two flexible metal hoses which were installed with traps (456/85032).
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The piping contractor has developed an approved final document review program which should identify any record deficiencies which are similar to Violation a.
Violation b. was identified late in the assessment period; therefore, the adequacy of the licensee's corrective actions has not yet been reviewed.
Licensee management attention was evident during the implementation of the Instrumentation Installation Verific6cion Program initiated as a result of deficiencies in the piping contractor's installation / inspection program identified in the previous assessment period.
The program is procedurally controlled, has been reviewed by the NRC, and was found to be acceptable.
The program as implemented should correct past deficiencies and assure that installations meet all specification and regulatory requirements such as pitch, clearances, color
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coding, and separation criteria.
The BCAP review of this program I
determined that it was adequately implemented.
Present staffing levels and licensee responsiveness to NRC initiatives appear to be adequate as evidenced by the minor significance of the identified violations and the licensee's implementation of timely corrective actions.
2.
Conclusions The licensee is rated Category 2 in this area.
This is the same rating as the previous assessment period.
Licensee performance has improved during the assessment period.
3.
Board Recommendation None.
O.
Braidwood Construction Assessment Program (BCAP)
1.
Analysis Examination of this functional area consisted of ten inspections by a full time inspector assigned to the BCAP program.
Areas examined included (1) the review of BCAP plans and procedures; (2) personnel training and qualifications; (3) hardware and documentation reinspections; (4) procedure reverifications; (5) corrective action prcgram reviews; and (6) the identification
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and review of deficiencies.
Additionally, two inspections were performed by the regional based. staff to evaluate the licensee's disposition of BCAP discrepancies in the str/Jctural, mechanical, electrical, and instrumentation areas.
An a!!Lgation concerning the qualifications of a BCAP civil QC inspector was not substantiated.
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The basis for this assessment was the licensee's performance in implementing the three elements of the BCAP program.
These elements are summarized as follows:
Construction Sample Reinspection - This element consisted
of a visual reinspection of a sample of safety-related construction work completed and QC accepted through l
June 30, 1984.
Reverification of Procedures to Specification
i Requirements - This element consisted of a review of i
on-site contractor's installation, inspection, and
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personnel qualification and certification procedures for ongoing and future safety-related construction activities j
as of June 30, 1984.
Review of Significant Corrective Action Programs - This
element consisted of a review of methodologies, implementa-tion, and resulting docunentation associated with nine significant corrective action programs.
Two violations were identified:
a.
Severity Level V - Reviews and approvals of BCAP procedures and instructions were performed by BCAP QA personnel who had not completed required site orientation (456/84025; 457/84024).
b.
Severity Level IV - Thirty-seven BCAP observations were improperly invalidated (456/85006; 457/85006).
Violation a. was identified during the initial review of the BCAP QA organization and appeared to be of minor significance.
Corrective actions were prompt and thorough.
Subsequent review of BCAP QA revealed that organization to be staffed with qualified individuals who performed in a highly satisfactory manner.
Violation b. was considered significant because of the improper invalidation of observations.
Corrective actions included a 100%
review of all invalidated observations by BCAP QA.
The BCAP organization was adequately staffed with qualified and experienced personnel.
Morale was consistently high with evidence that the BCAP staf f had confidence in the quality of the BCAP effort.
Training programs for BCAP personnel were well defined and Implemented.
Experience and educational requirements for personnel entry into the BCAP organization were maintained at a high standard.
Management involvement in the BCAP program was evident in day-to-day BCAP activities.
BCAP implementing procedures, instructions, and checklists were comprehensive, well organized
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and adequately addressed all areas of the BCAP program.
Procedures and policies were adhered to with BCAP records being complete, well maintained, and readily available.
A conservative approach was routinely exhibited in resolving NRC concerns.
In response to adverse findings by the NRC Construction Appraisal Team and the assigned NRC inspector, the licensee conducted reinspections of items previously reinspected, revision of checklists, and additional training of BCAP personnel.
The approach used to evaluate BCAP discrepancies and findings was generally conservative, technically sound and thorough.
2.
Conclusion The licensee is rated Category 1 in this area. The licensee was not rated in the previous assessment period.
Licensee performance has improved during the assessment period.
3.
Board Recommendations None.
P.
Housekeeping and Equipment Protection 1.
Analysis Examination of this functional area consisted of portions of eight inspections by the resident inspection staff, portions of four inspections by regio 9al based inspectors, and a portion of the CAT inspection.
Four violations were identified:
a.
Severity Level V - Failure to maintain cleanliness and equipment protection in that there was (1) excess accumula-tion of trash in a charging pump room; (2) inadequate or nonexistent protective covers for permanent spool pieces; and (3) failure to maintain cleanliness requirements for containment sumps during testing activities (456/85008),
b.
Severity Level IV - Failure to control storage and preservation of material (456/85023; 457/85024).
c.
Severity Level V - Failure to control the cleaning and preservation of electrical equipment (456/85036; 457/85035).
d.
Severity Level IV - Failure,to take timely corrective action to protect safety-related equipment (456/85045; 457/85044).
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Violation a. contained three examples of inadequate housekeeping / equipment protection practices.
Licensee corrective action included retraining of personnel, issuing memos to contractor foremen, and issuing a letter discussing the violation to a contractor.
Violation b. also contained three examples of improper conditions.
Licensee corrective action included issuing letters on cleanliness to site contractors and assigning additional surveillances. Violation c. identified bolts, screws, debris, and rust in diesel generator junction boxes.
The licensee immediately cleaned the junction boxes.
Violation d. involved failure by the licensee to take timely corrective action on equipment protection discrepancies identified by NRC inspectors and the failure of previous corrective actions to prevent the intrusion of large quantities of masonry dust into safety-related electrical cabinets and panels.
Licensee corrective action consisted of a program to protect electrical equipment from dust created by ongoing masonry work in and adjoining the control room.
The specific deficiencies identified by the inspectors were corrected.
In addition to the violations discussed above, the following houskeeping/ equipment concerns were identified:
a.
Five ASME Section III, Class I valve bonnets and discs were stored in an undesignated storage area (cargo box)
and two of the discs were not readily traceable to their respective valves (456/85052; 457/85050).
b.
The room containing safety injection pump ISIO1PA contained bags of sand, soda pop cans, nuts and bolts, angle iron, tube steel, pieces of concrete, and fittings (456/85038; 457/85037).
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c.
The pressurizer code safety relief valves, 1RY8010A, 1RY80108, and 1RY8010C, were removed from the pressurizer in preparation for the primary hydrostatic test and left in a high traffic area without adequate protection (456/85032; 457/85031).
d.
The CAT concluded that there were an excessive number of incidents of damage to installed equipment caused by ongoing construction activities (456/84044; 457/84040).
The licensee has demonstrated the ability to significantly improve plant conditions as evidenced by the high state of cleanliness that was achieved just prior to the site visit by the Chinese delegation.
Subsequent to the Chinese visit the licensee did not maintain plant conditions but allowed them to deteriorate back to the previously existing state.
Housekeeping and equipment protection have been an ongoing problem during the construction and preoperational test phases.
Corrective action in response to violations and
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concerns has not been effective, as evidenced by the repetitive nature of the deficiencies.
These corrective actions addressed specific examples identified by NRC inspectors and were apparently narrow in scope and application.
Shortly after the conclusion of the assessment period the licensee presented a comprehensive action plan to improve plant conditions in preparation for operation.
The plan includes a thorough cleaning from top to bottom and a "Model Areas Program" which will prepare three specific plant areas for operation and then use them as examples for plant personnel.
2.
Conclusion The licensee is rated Category 3 in this area.
The licensee was not rated in the previous assessment period.
Licensee performance has remained the same during the period; however, during the transition from construction to operations more
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stringent housekeeping and equipment protection standards are required.
3.
Board Recommendations Increased attention by licensee management is recommended to improve housekeeping / equipment protection performance.
The action plan presented by the licensee appears to be an adequate first step; however, attention should be given to programs for i
maintaining plant conditions and equipment protection after satisfactory conditions are achieved.
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V.
SUPPORTING DATA AND SUMMARIES A.
Licensee Activities i
Units 1 and 2 were reported by the licensee to be 90% and 59% complete, respectively, at the end of the assessment period.
Fuel load dates are estimated by the licensee to be September 30, 1986 for Unit 1 and January 31, 1988 for Unit 2.
Preoperational testing of Unit 1 is estimated to be 62% complete.
The human factors control room upgrade essentially stopped testing for a six month period during the spring and summer of 1985. Major milestones / activities which occurred during the assessment period included:
Quality First was implemented in December 1984, to investigate
l quality concerns by site employees.
ACRS Subcommittee - January 29, 1985.
- ACRS Full Committee - February 8, 1985.
February 11, 1985.
ECCS full flow test (Unit 1) - March 1985.
- Secondary hydro (Unit 1) - September 1985.
- i ASLB hearings commenced on October 29, 1985.
- Gene Fitzpatrick filled the position of Station Manager in
November 1985.
The emergency plan exercise was conducted on November 6, 1985.
- BCAP was developed, staffed, implemented, and completed with the
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final report submitted to the NRC.
i The Material Traceability Verification Program was implemented
and completed, with the final report submitted to the NRC.
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B.
Inspection Activities 1.
Inspection Data Facility Name:
Braidwood Station, Docket No. 50-456 Unit 1 Inspections:
50-456/84016 through 50-456/84044 50-456/85001 through 50-456/85054 Number of Violations in each Severity Level *
Functional Area I
II III IV V
Total A.
Plant Operations B.
Radiological Controls C.
Preoperational Testing
2 D.
Fire Protection E.
Security G.
Quality Programs and
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Administrative Controls Affecting Quality H.
Licensing Activities
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2.5 4.5 I.
Containment, Safety-
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Related Structures, and Major Steel Supports J.
Piping Systems and 3.5 1.5
Supports K.
Safety-Related
0.5 1. 5
Components-Mechanical L.
Auxiliary Systems
2 M.
Electrical Equipment 5.5
9.5 and Cables N.
Instrumentation 1.5 1. 5
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Braidwood Construction
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l Assessment Program P.
Housekeeping and Equipment
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Protection Totals
19
- A value of 0.5 was assigned to violation examples which were separated between functional areas.
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Inspection Data Facility Name:
Braidwood Station, Docket No. 50-457 Unit 2 v
Inspections:
50-457/84016 through 50-457/84040 50-457/85001 through 50-457/85052 tiumber of Violations in each Severity Level *
Functional Area I
II III IV V
Total A.
Plant Operations B.
Radiological Controls C.
Preoperational Testing D.
Fire Protection E.
Security l
G.
Quality Programs and
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Administrative Controls Affecting Quality H.
Licensing Activities I.
Containment, Safety-
2. 5 4.5 Related Structures, and Major Steel Supports J.
Piping Systems and 3.5 1.5
Supports
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K.
Safety-Related
~1 0.5 1.5 Components-Mechanical L.
Auxiliary Systems
2 M.
Electrical Equipment 5.5
10.5
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and Cables N.
Instrumentation 0.5 0.5 0.
Braidwood Construction
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Assessment Program P.
Housekeeping and Equipment
1
Protection Totals
15
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- A value of 0.5 was assigned to violation examples which were separated between functional areas.
2.
Inspection Summary The inspectinns at Braidwood were conducted by the resident inspection staff, regional based staff, RCAP inspector, and the Construction Appraisal Team.
Eighty-two inspection reports were issued during this assessment period representing 12,465 hours0.00538 days <br />0.129 hours <br />7.688492e-4 weeks <br />1.769325e-4 months <br /> of direct inspection effort.
The CAT inspection was conducted on December 10-20, 1984 and January 7-18, 1985, and is documented in Inspection Reports No. 456/84044; 547/84040.
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Investigations and Allegations Review Twenty-nine allegation files were opened during this assessment period.
Seventeen of these were closed at the end of the assessment period.
The allegations reviewed during the assessment period are discussed in the individual functional areas.
The majority of the allegations were in the electrical area.
D.
Escalated Enforcement Actions 1.
Civil Penalties None.
2.
Orders None.
E.
Licensee Conferences Held During Appraisal Period The following meetings were conducted during this assessment period:
September 6, 1984 Public meeting to discuss BCAP.
September 7, 1984 Meeting to discuss the status of the Regulatory Performance Improvement Program.
October 4,1984 Public meeting to discuss BCAP.
November 8, 1984 Public meeting to discuss BCAP.
November 26, 1984 Meeting to discuss the results of the SALP 4 assessment.
December 6, 1984 Public meeting to discuss BCAP.
January 3, 1985 Public meeting to discuss BCAP.
January 18, 1985 Meeting to discuss various items l
related to emergency preparedness at all CECO sites.
February 14, 1985 Public meeting to discuss BCAP.
March 14, 1985 Public meeting to discuss BCAP.
March 15, 1985 Meeting to discuss actions which CECO has taken and/or initiated in three SALP 4 areas which were rated Category 3.
April 11, 1985 Public meeting to discuss BCAP.
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June 25, 1985 Public meeting to discuss BCAP.
June 25, 1985 The licensee presented the results
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of the Material Traceability Verification Program.
October 15, 1985 Public meeting to discuss the final results and conclusions of BCAP.
F.
Confirmation of Action Letters None.
G.
Construction Deficiency Reports and 10 CFR 21 Reports Submitted by the Licensee i
1.
Construction Deficiency Reports (CDRs)
During this SALP period 15 CDRs were submitted by the licensee under the requirements of 10 CFR 50.55(e).
The contents of these reports were acceptable.
Submitted reports were as follows:
a.
ASME NPT symbol nameplates were removed from piping subassemblies without proper controls and documentation.
Nondestructive examinations required by ASME Section III of the nameplate removal areas were not subsequently performed (84-12).
b.
Electrical butt splices were not installed per the manufacturer's installation instructions (84-13).
c.
Boeing steam generator snubber defects (84-14).
d.
G. K. Newberg Welding Program Deficiencies (84-15).
e.
A sample review of records of past site procured ASME material has indicated that the records do not always indicate that the material was supplied in accordance with the ASME Material Manufacturers and Material Suppliers Quality System Program Requirements (84-16).
f.
Concrete expansion anchor inspection deficiencies (84-17).
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Preservice nondestructive examination identified one rejectable indication in the Loop 2 inlet nozzle-to-vessel shell weld on the Unit 2 reactor pressure vessel (84-18).
h.
During testing of energy absorbing material (EAM), it was discovered that some material used in pipe whip restraints had a lower than specified crush strength (84-19).
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The 480 volt, 10 amp breakers supplied with the Westinghouse Motor Control Centers did not meet the specification (85-01).
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Welding on certain safety-related ASME Section III tanks and heat exchangers did not meet drawing, specification and in some cases code requirements (85-02).
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Instrumentation Installation Reverification Program -
instrumentation deficiencies were identified which involved criteria for line separation, segregation color coding, and the performance of inspections which were not thoroughly documented nor complete as to. design significant attributes-(85-03).
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Containment sump isolation valves were determined to not be seismically qualified in their presently installed configuration (85-04).
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Certain postulated high energy line breaks in the auxiliary building were evaluated for potential environmental effects on safety-related equipment using information which has been shown to be inaccurate (85-05).
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Failure of the diesel generators to sustain adequate prime (85-06).
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The diesel generator tachometers have, at times, indicated an rpm reading while the engines were in a standby mode (85-07).
The number of CORs has decreased from 26 (SALP 4) to 15 for this assessment period.
2.
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 report.
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