IR 05000456/1986031

Safety Insp Repts 50-456/86-31 & 50-457/86-24 on 860601- 0802.No Violation or Deviation Noted.Major Areas Inspected: Plant Procedures,Headquarters & Regional Requests, NUREG-0737,Tech Spec Review & Plant Tours

ML20212N368
Person / Time
Site:	Braidwood
Issue date:	08/20/1986
From:	Gardner R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20212N360	List: IR 05000456/1986031 ML20212N356
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.2, TASK-1.A.1.3, TASK-1.A.2.1, TASK-1.B.1.2, TASK-1.C.2, TASK-1.C.3, TASK-1.C.4, TASK-1.C.5, TASK-1.C.6, TASK-2.D.3, TASK-2.E.1.2, TASK-TM 50-456-86-31, 50-457-86-24, IEB-81-03, IEB-81-3, IEIN-86-003, IEIN-86-3, NUDOCS 8608280200
Download: ML20212N368 (30)

Text

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. , . NUCLEAR REGULATORY COMMISSION

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REGION III

I Reports No. 50-456/86031(DRP); 50-457/86024(DRP)

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Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: Commonwealth Edisen Company Post Office Box 767

Chicago, IL 60690

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Facility Name: Braidwood Station, Units 1 and 2

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Inspection At: Braidwood Site, Braidwood, Illinois

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Inspection Conducted: June 1 through August 2, 1986 Inspectors: T. M. Tongue .

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W. J. Kropp i

1. E. Taylor *

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Approved By: R. N. Gardner, Chief W %f 2* / 8 b'

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Braidwood Project Section Date -

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! Inspection Summary f

i Inspection on June I through August 2, 1986 (Report No. 50-456/86031(DRP):

j No. 50-457/86024(DRP)) i

, Areas Inspected: Routine, unannounced safety inspection of licensee action [

on previously identified items; headquarters request; regional requests; plant i procedures; NUREG-0737; events occurring during the inspection; concerned l citizen / contractor; technical specification review; procurement; plant' tours i

! and independent assessmen i

! Results: ' No violations or deviations were identified. Housekeeping j continues to be a' concern (Paragraph 11).  ;

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i 8608280200 860820 .

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DETAILS 1. Persons Contacted Commonwealth Edison Company (CECO)

Corporate Personnel *

A. Miosi, Nuclear Licensing Administrator Braidwood Personnel

• M. J. Wallace, Project Manager

• C. W. Schroeder, Station Services Superintendent

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• D. L. Shamblin, Project Construction Superintendent

! *P. L. Barnes, Regulatory Assurance Supervisor

• G. E. Groth, Assistant Construction Superintendent M. E. Lohmann, Assistant Construction Superintendent

• E. E. Fitypatrick, Station Manager L. M. Kline, Regulatory Assurance Group Leader

• C. J. Tomashek, Project Startup Superintendent H. Zimmerman, Project Startup Testing Supervisor

• D. d. Paquette, Maintenance Assistant Superintendent D. E. O'Brien, Operations Assistant Superintendent S. C. Hunsader, Quality Assurance Supervisor R. Legner, Senior Operating Engineer

! G. Masters, Operating Engineer R. Ungren, Operating Engineer

F. Willaford, Security Administrator M. Andrews, Station Chemist R. Lemke, Technical Staff Supervisor

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• G. Nelson, Assistant Technical Staff Supervisor

• R. E. Aker, Radiation-Chemistry Supervisor -

T. Keith, Lead Health Physicist

• T. W. Simpkin, Regulatory Assurance R. Mertogul, Assistant Technical Staff Supervisor

• T. E. Quaka, Site Quality Assurance Superintendent

• R. D. Kyrouac, Station Quality Assurance Supervisor T. Meyer, Station Fire Marshall '

D. A. Boone, Construction Field Engineer

• G. F. Marcus, Assistant to Manager Quality Assurance

• L. E. Davis, Assistant Superintendent - Technical Services

• D. L. Cecchett, Regulatory Assurance

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• A. J. D' Antonio, Regulatory Assurance L *J. K. Jasnosz, Regulatory Assurance E. Wendorf, Project Field Engineer M. R. Dougherty, Project Field Engineer D. J. Skoza, Project Field Engineer B. M. Peacock, Integrated Leak Rate Test Coordinator

• S. H. Stapp, Quality Assurance (0perations)

• L. Literski, GSEP Coordinator

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Braidwood Personnel (cont'd)

• E. R. Netzel, Quality _ Assurance Supervisor

• M. Takaki, Quality Control Supervisor

, *J. F. Phelan, Project Field Engineer - Electrical Supervisor

• T. VanDeVoort, Quality Assurance - Operating Nuclear Installation Services Company (NISCo)

B. Allen, Lead Engineer The inspectors also talked with and interviewed other licensee employees,

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including members of the technical and engineering staffs, startup engineers, reactor and aux liary operators, shift engineers and foremen, i

electrical, mechanical ana instrument personnel, contract security i

personnel, and construction personne * Denotes those attending one or more exit interviewr. conducted on June 4, 5, 13, 26,, July 10, 17, 25, and 31, 1986, and informally

at various times throughout the inspection perio . Licensee Action on Previously Identified Items Violations

(Closed) 456/84021-07(DRP);457/84020-07(DRP): Failure to implement a Quality Assurance Program to assure internal cleanliness of mechanical equipment. On several occasions, the licensee contacted the resident inspectors for an opportunity to witness the condition of system internal cleanliness in accordance with their corrective action plan. In those cases witnessed, the inspectors found no foreign material and did observe some expected minor corrosio During the inspection period, the following were witnessed by the resident inspectors with licensee and/or contractor Quality Control / Quality Assurance personnel:

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1SX01PB Pump Suction 0AB01PA Evaporator Recycle Feed Pump 2SX01PB Pump Suction i 0AB02DB Stripper Column Upper Hand Hole ,

, 2CC01PB Pump Internals, Drain, Vent, and Discharge The licensee action has proven to be effective on those items reviewed. This item is considered close ,

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i b. Open Item _s (Closed) 456/85007-03; 457/85007-03: The review of documentation relating to the installations of the four containment spray pumps identified several deficiencies. Also, as a result of a licensee audit finding in June 1984 the mechanical contractor, in September 1984, committed to reviewing all equipment installation records packages for compliance with the current vendor instruction manual Current revisions of the vendor instruction manuals were obtained and kept current. These vendor manuals are stored in a locked library and the mechanical site contractor is on distribution from Sargent & Lundy for the vendor manual updates. During the inspection period documented in Inspection Report 456/86009; 457/86008, Region III inspectors reviewed the licensee's reinspection program for safety-related mechanical equipment and identified no discrepancies. This inspection included the review of documentation packages associated with the four containment spray pumps. This item is considered to be close (Closed) 456/85015-03; 457/85016-03: Specific minimum wall violations were identified on Phillips Getschow (PGCo) NCRs 1611, 1294, 2558, and 263 These NCRs were closed based on the licensee's plan to take sufficient sanples of all small bore pipe heat numbers identified in NRC Inspection Report 456/84017; 457/84017, and Open Item 456/84017-0 However, the sampling plan did not specify that the items previously identified on NCRs 1611, 1294, 2558, and 2633 would be included in the sample and analyzed by Sargent & Lund The site mechanical contractor (PGCo) issued NCRs to address those minimum wall deficiencies previously identified on PGCo NCRs which were closed based on the proposed sampling pla The inspector reviewed PGCo NCR 6193 and selected for review the disposition of those minimum wall deficiencies previously identified on PGCo NCR 1294. The disposition included performing digital thickness measurement (DTM) of the affected pipe and measuring the piping pits with a dial depth gaug One minimum wall deficiency was noted. The disposition was-Use-As-Is based on Sargent & Lundy calculation ISD05-PNCR 6193. The DTM results were recorded on reports U1246, U569, U1036, U1038, U1037, and U1035. This item is considered to be closed, c. Unresolved Items (0 pen)456/85004-01(DRP);457/85004-01(DRP): Inspection of Vertical Containment Tendons for Presence of Water and Grease Leakage. The licensee completed a reinspection in May 1986 of those tendons that showed a presence of water during the November 1985 re-examinatio The resident inspector received copies of the licensee correspondence, dated June 19, 1986, from Sargent & Lundy on this matte .

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On June 10, 1986, a conference telecon was made between the licensee, Sargent & Lundy, and the NRC involving personnel at the Station, at CECO General Office, Region III, and Headquarter During that call, the licensee and Sargent & Lundy provided information that the water monitored thus far was apparently construction water, the grease had not shown a breakdown, that the tendon wires were not galvanized (plated with zinc as identified in the failure at the Farley plant), and the water chemistry results are not in the range where wire corrosion would be highly susceptible. The licensee will continue to monitor those vertical tendons where water was detected on a biannual surveillance. The licensee presentation was found acceptable by all NRC participant This matter will remain open until a final resolution on this issue is determine CFR 21 Reports (Closed) 456/84005-PP: Potential for Overpressurization of the Component Cooling Water (CCW) System. The CCW surge tank relief valves have been removed and replaced with a loop seal. The work was performed in accordance with Sargent & Lundy Engineering Change Notice 23837. The inspector verified the removal of the relief valve and the installation of the loop sea This item is considered to be close (Closed) 456/85001-PP; 457/85001-PP: Inryco Furnishad 170 Wire system for Containment Tendons in the Post Stressed Containmen The licensee has a program to monitor the tendons and this issue will be followed under Unresolved Item 456/85004-01(DRP); 457/85004-01(DRP). Safety Evaluation Report (Closed) 456/86000-03: Containment Isolation Valves Added to the Redundant Hydrogen Recombiner Supply and Return Linas Outside Containment. The inspector reviewed Sargent & Lundy Drawing M47, Sheet 2, Revision P, and verified the design included the commitments in the SER. The commitments verified included:

(1) isolation on a Phase A isolation signal; (2) positive position indication; (3) remote-manual control switches in the main control room; and (4) the valves powered from the same Class 1E cmergency power source. The inspector verified valves 10G082 and 10G084 were installed in accordance with Drawing M47, Sheet 2. The inspector also verified that remote-manual control switches were installed in

, the main control room. This item is considered to be close (Closed) 456/86000-04: Containment Isolation Added to the Chilled Water Return Lines Inside Containment. The inspector reviewed Sargent & Lundy Drawing M118, Sheet 5, Revision U, and verified the design included the commitments in the SER. The commitments verified included: (1) isolation on a Phase A isolation signal; (2) positive position indication; (3) remote-manual control switches in the main control room; and (4) the valves powered from a different Class 1E

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emergency power source than the outside containment isolation valv The inspector verified valves 1W0056A and 1 WOOS 6B were installed in accordance with Drawing M118, Sheet 5. This_ item is considered to be close (Closed) 456/86000-13; 457/86000-13: Plant Procedures Need to Address-the Periodic Sampling of-Instrument Air Quality. The inspector reviewed station Procedure BwVS 800-2, Revision 0,

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" Instrument Air Sampling Requirements for Refueling Outages." The procedure requires that once per 18 months, the Instrument Air i System to be checked to determine if it provides dry and oil free j air. The procedure requires determination of particulate content and moisture content, flushing of the instrument air risers, and

a check for water or oil. The maximum particle size in the air stream at the instrument is defined in the procedure as three micrometers. This item is considered to be close : (Closed) 456/86000-19: Verify that Steam Generator Power Operated i Relief Valves (PORV) have hydraulic operators installed. The 1'

inspector reviewed Sargent & Lundy Drawing M-35, Sheets 1 and 2, and determined that these drawings required the PORVs to have hydraulic

, operators. The inspector verified that the hydraulic operators were

!. installed for PORVs 1MS018B and 1MS018C. This item is considered to be close (Closed) 456/86000-15; 457/86000-15: Verify that the Auxiliary

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Feedwater (AFW) system valves will be independently verified upon

restoration to service after periodic testing.or maintenance. The

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inspector reviewed the following procedures for incorporation of independent verification:

i Bw05 7.1.2.1.a-1, Revision 51, "1A Train Auxiliary Feedwater

Monthly Surveillance" Bw05 7.1.2.1.a-2, Revision 0, "1B Train Auxiliary Feedwater Monthly Surveillance" ,

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Bw05 7.1.2.2-1, Revision 51, " Train A Auxiliary Feedwater ;

Flowpath Operability Surveillance Following' Cold Shutdown" j

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Bw0S 7.1.2.2-2, Revision 51, " Train B Auxiliary Feedwater

. Flowpath Operability Surveillance Following Cold Shutdown" ;

1 . t BwVS 7.1.2.1.a-1, Revision 0, " Motor Driven Auxiliary Feedwater Pump Monthly Surveillance"  :

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i BwVS 7.1.2.1.a-2, Feedwater Revision Pump Monthly Survel0'llance"" Diesel Driven Auxiliary

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4 BwVS 7.1.2.1.b.1-1, Revision 0, "AFW Valve Emergency Actuation ;

l Signal Verification Test"

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BwVS 7.1.2.1.b.2-1, Revision 0, " Auxiliary Feedwater Pump Emergency Actuation Signal Verification Test" BwVS 7.2.2.3.c-1, Revision 0, " Auxiliary Feedwater Diesel Prime Mover Inspection" BwAP 300-1, Revisien 0, " Conduct of Operations" BwAP 330-1, Revision 2, "Braidwood Equipment Cut of Service Procedure" As a result of this review, two concerns were identifie These concerns were addressed by the licensee in a manner that allowed the closure of this ite The concerns were:

• Procedure Bw0S 7.1.2.2-2, Step 16, identified opening "B" train AFW test valve 1AF0048. There was no requirement in the procedure to have an independent ve*ification that this valve was ope This is the last step of the procedur * Procedure BwVS 7.1.2.1.b.2-1 did not have the data sheets referenced in the procedure attached to the procedure. The inspector determined that these data sheets were inadvertently omitted in the distribution of the procedure. The inspector reviewed the data sheets and determined the independent verification was adequately addresse This item is considered to be close Allegation Followup (Closed) RIII-86-A-0920: On February 5, 1986, the NRC received the following allegations concerning the HVAC site contractor (Pullman):

• Numerous audit findings have identified cases where procedures were not properly implemented. In most cases the procedures were revised to reflect the actual practices, thus resolving the audit findings. The alleger expressed a concern that there ,

were too many procedure changes to resolve audit findings rather than taking corrective action to ensure the procedures are followe * The close out of deficiencies are inadequate or shaky. An example given by the alleger was Corrective Action Report (CAR) 001. This CAR identified that installed HVAC hangers with skewed tee fillet welds were not inspected in accordance with the American Welding Society (AWS) Code D The corrective actions for CAR 001 consisted of identifying any installed hangers that could have skewed tee fillet welds. These hangers were then inspected to identify those having skewed tee fillet welds and a list was then compiled identifying which hangers had and did not have skewed tee

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fillet welds. Those hangers identified to have skewed tee fillet welds were then inspected by Pullman's quality control inspectors to tha requirements specified in Sargent & Lundy Engineering Change Notice (ECN) 25598 and AWS D1.1, Appendix The alleger stated that during a QA surveillance (QA-5-86-004)

to close out CAR 001, it was identified that hanger S-1581, identified on the list of hangers as not having a skewed tee fillet weld, was inspected instead of hanger S-1583. Hanger 5-1583 was identified on the list as having a skewed tee fillet weld. The alleger stated that the QA individual who identified this problem during the surveillance was told to

" forget it."

• The review process for documentation does not verify that the document reviewed complies with procedural requirements. The alleger was concerned that document deficiencies were resolved without considering if there was.an impact on hardwar To determine whether or not these cliegations could be substantiated, the inspector conducted a detailed inspection consisting of the following:

(1) The inspector reviewed all the Pullman audit findings that have been issued during 1985 and 198 .

(2) The inspector reviewed Pullman CAR 001 and selected several Pullman Nonconformance Reports (NCRs).

(3) The inspector reviewed selected Pullman Document Deficiency Notice The results are as follows:

The inspector reviewed all the Pullman audit findings issued in 1985 and those issued to date in 1986. This review revealed that there were several audit findings which identified improper procedure implementation. In some cases, training was part of the corrective actions to avoid future procedure noncompliance However, there were audit findings which were resolved by changing procedural requirements to reflect actual practice The inspector reviewed these audit findings and determined that the procedural changes were justified and can be categorized as " fine tuning" Pullman's QA progra This part of the allegation could not be substantiate * The inspector reviewed 30 Pullman nonconformances (NCRs) and determined that the closures of these NCRs were adequate, justified and properly documented. In addition, the inspector reviewed the closure of CAR 001. This review revealed the

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(1) Surveillance QA-S-86-004 which evaluated the corrective action for CAR 001 stated that hanger S-1581 was inspected for skewed tee fillet welds even though it was on the list as not having a skewed weld.

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(2) Hanger S-1583, which was identified on the list as having a skewed weld, was not inspected. However, an attachment

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to Surveillance QA-S-86-004 identified hanger S-1583 as having no skewed tee fillet welds.

, (3) Surveillance QA-S-86-004 was conducted on January 14, 1986. The inspector reviewed Sargent & Lundy Drawings

M-1305-01-1583, Sheets 1 and 2, Revision A, for hanger S-1583 and determined that no skewed welds were part of the hanger configuration. These drawings were last

, revised on August 16, 1985, which was approximately six

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months prior to the allegation and five months prior to

. the surveillance which evaluated the corrective action for CAR 00 '

Based on the results of reviewing the closure of CAR 001, the inspector could not substantiate this part of the allegation since:

(1) The drawings for hanger S-1583'were revised in August of 1985 to delete the requirement for the skewed weld. This revision occurred approximately five months prior to Surveillance QA-S-86-004 and the closure of CAR 001 (January 14,1986).

. (2) Documentation attached to Surveillance QA-S-86-004 clearly identified that hanger S-1583 had no skewed tee fillet welds.

• The inspector reviewed approxinately 20 Document Deficiency Notices (DDNs) and determined that the review and resolution -

process did consider impact on hardware. In fact, several of the DDNs that were reviewed required inspections to be performed by Pullman QC to verify the quality cf the installed

, hardware. The specific-DDN identified by the alleger was reviewed by the inspector. This DDN was number 106. This DDN identified that a Weld Process Sheet (WPS) D-5562 did not

, identify the page number of the weld procedure utilized for the welding process. The WPS indicates that wel.d procedure BS-11F was used, but not what page of BS-11F. This WPS was completed on November 27, 1985. The DDN was issued on December 6, 198 The resolution of the DDN was to contact the production personnel who performed the weld to determine what page of the welding procedure was utilized. The WPS was corrected to

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reflect-the page of Procedure BS-11F utilized in the welding process. Since the time between issuing the DDN and the actual date of the WPS was short (approximately 20 days), the

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resolution to determine what page of procedure BS-11F was utilized in the welding process was deemed acceptable by the inspector. This part of the allegation could not be substantiate ,

(Closed) RIII-86-A-0031: On February 26, 1986, the NRC received an allegation concerning warpage of a plate welded to a cable pan hanger installed by G. K. Newberg. The alleger discussed the warpage with his supervisor. He stated his supervisor told him to accept the warpage so that production can continue. The alleger stated that there was no clear criteria for the amount of warpage i

allowed in an assembly. The alleger stated that he did accept the cable pan hanger with the warpage. The inspector, accompanied by a Region III welding inspector, ins)ected the cable pan hanger with the warped plate and determined t1e hanger connection did not violate the AWS D1.1 Code. The alleger was present during this inspection. The inspector and the regional welding ins with G. K. Newberg's Project Manager, welding engineer,pector andQA met Manage During this meeting the G. K. Newberg personnel explained

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the steps taken to prevent or limit the amount of warpage being experienced in the welding of some cable pan hangers. The '

Region III welding inspector had no problems with the steps taken to minimize warpage. Further discussions revealed that there were no inspection guidelines. The AWS D1.1 welding code does not identify specific crite'ria for warpag However, G. K. Newberg personnel agreed to issue a Technical Bulletin to address warpag Technical Bulletin (TB) No. 9, which was ap3 roved February 27, 1986, addresses the distortion of members caused )y heat generated during the welding process. This technical bulletin stated that provisions shall be made during the welding process to minimize and control such distortions. It further stated that distortions deemed to be excessive shall be forwarded to G. K. Newberg Engineering for evaluation. After the issuance of TB No. 9, the inspector interviewed four G. K. Newberg electrical QC inspectors to determine; 1) if production was attempting to get QC inspectors to accept unacceptable warpage or other deficiencies, and 2) if there was'a continuing problem with QC determining acceptable or unacceptable warpag All the inspectors interviewed stated that warpage was no longer a problem and that there was no undue pressure by production personnel to accept unacceptable hardware. In conclusion, the inspector substantiated part of the allegation pertaining to the lack of guidelines for inspecting warpage. The site contractor initiated immediate action by issuing a technical bulletin and discussing this technical bulletin with the QC inspectors. The inspector could not substantiate the part of the allegation pertaining to production attempting to get QC inspectors to accept discrepant items. This allegation is considered to be close No violations or deviations were identifie '

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. Headquarters Request (Closed) TI 2515/77

Survey of Licensees Response to Selected Issues.

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This Temporary Instruction is a survey to determine licensee actions on a sampling of IE Bulletins, Circulars, Information Notices, and Institute of Nuclear Power Operations (INPO) Significant Operating F. vent Reports t

(50ERs). The portion of this TI that is applicaM e to Braidwood is I

related to biofouling of cooling water heat exchangers. It is to

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determine whether equipment has been installed, surveillances are being performed, and training and procedures are being provided. This was addressed in the licensee's response to IE Bulletin 81-03 and closed in Inspection Report 456/81-13; 457/81-13. It was further reviewed and

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remained closed in Inspection Report 456/84-17(DRP); 457/84-17(DRP).

I It should be noted that the licensee's annual survey has shown no j detected genus of the corbicula in the Braidwood cooling lak Region III environmental inspectors will continue to do followup inspections to monitor the' licensees program with regard to

identification and control of biofoulin The licensee's response to INPJ SOER 84-1 recommendations 1, 2, 4 and 5 were based on the NRC acceptance of their program. No additional followup should be necessary on this matter.

l No violations or deviations were identified.

. Regional Request Bymemorandum,datedMay6,1986,RegionIIIrequestedinformatio related to the licensee s plans to build onsite storage for low-level

radioactive waste. The questions were related to performance of j 10 CFR 50.59 evaluations for the proposed facilities, what the

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proposed construction would be, and calculations of increased off-site radiation exposures from these facilities. Through

! interviews with licensee personnel, the inspector found that the

{ licensee has no immediate plans for such a facility at Braidwood.

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Presently, the only storage and processing facility at Braidwood is as described in the FSA (0 pen) TI 2515/75: Inspection of Limitorque Motor Valve Operator Wiring to Determine if Wiring is Environmentally Qualified. The

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resident inspectors were requested to gather specific information

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related to this issue and forward it to Region III, Division of i

Reactor Safety for compilation. This issue was first raised at

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Braidwood in February 1981, with the issuance of NCR 277 for terminal blocks rated for 300 volts when 600 volts was specifie Subsequent resolution of the NCR resulted in the licensee

! identificationofsomeimproperwireinjumpersandimproper i terminationoftheinternaljumpers. The licensee then expanded l the scope of MCR 277 and issued 10 CFR 50.55(e) Report 81-01.

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The licensee has also included in their records, the followup cn IE Information Notice 86-03, " Potential Deficiencies on Environmental Qualifications of Limitorque Motor Valve Operator Wiring," and followup on related Zion LER 50-304/85018-0 Through discussions with licensee personnel, the inspector found that the data requested by Region III related to the different types cf wires found, and the number of motor operators found with inadequate wires is not available. The work was performed by construction contractors and they only recorded each motor operator a: it was inspected and the replacement of required parts as they were completed. This information was forwarded to Region III via memorandum, dated July 11, 198 As a result of a request by Regional personnel, the inspector obtained information concerning a pipefitter's work activities at Braidwood. There was a concern that the pipefitter's work could be questionable. The resident inspector obtained the following information from the licensee:

Emaloyment Date Termination Date Reason for Termination August 16, 1984 August 17, 1984 Failed Weld Test June 5, 1985 July 15, 1985 Unexcused Absence December 12, 1985 December 12, 1985 Voluntary Quit April 2, 1986 May 1, 1986 Voluntary Quit The licensee performed a review to determine if the pipefitter worked on any safety related system:,. Discussion with the pipefitter's employer revealed that he did not work on any safety-related or ASME system No violations or deviations were identifie . Plant Procedures During the inspection period the review of station procedures was continued; refer to the previous Inspection Report 456/86016(DRP);

457/86014(DRP), Paragraph 9, for general consideration * Maintenance Procedures The inspector reviewed the index of plant maintenance procedures for completeness. The inspector also reviewed a significant sample

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ofprocedures(inpartorintheirentirety)onthesubjectsof l

control of measuring and test equipment, performing maintenance and, performing surveillances. The inspector verified that the sampled prnceduras ware in the format specified in the station administrative

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procedures and were technically adequate to accomplish their stated l purpos This included listing proper reference documents, that l

checklists have QC hold points at reasonable locations, requirements exist for proper removal and returning equipment to service, that Technical Specification LCOs are considered, and appropriate

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approvals are required.

This review did not necessarily constitute a step-by-step review and l approval, but was a repre'sentative sample of the procedures in place l during the inspectio The inspector reviewed procedures under the titles of electrical maintenance (HP), electrical maintenance surveillance (HS),

mechanical maintenance (MP), instrument (IP), and instrument surveillance (IS). The following is a list of those procedures sampled:

Revision Procedure Title N BwHP 300-003 Inspection / Test / Repair of Station Fixed 0 Instruments and Relays by Southern Division Operational Analysis Department (5.0. 0.A.D.)

BwHP 300-004 Control of Electrical Maintenance 1 Certified Maintenance BwHP 300-004-S1 Certified Tool Tracking Form 2 BwHP 800-001 Megger Test of Stored Rotating Equipment 0 BwHP 800-001-T1 Megger of Stored Rotating Equipment Data 1 Sheet BwHP 1300-002 Control of Station Procedures Used 1 by the Electrical Maintenance Department BwHP 1300-001-51 Procedure Check-Out Form 1 BwHP 4002-005 Inspection and Testing of Portable 1 Electric Tools and Generators BwHP 4002-009 Inspection / Certification of AMP 1 Crimp Tools BwHP 4002-00951 Amp Crimp Tool Inspection / Certification 0 Data Sheet BwHP 4006-003 480 Volt Motor Control Center 1 Determination - Termination

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Revision Procedure Title No.

, BwHP 4006-004 Replacement / Repair of Control Switch 1 BwHP 4006-011 Electrical Maintenance 3 Troubleshooting Work Sheet BwHP 4009-003 Periodic Relay Testing Procedures 0-Southern Division 0AD at Braidwood Station BwHP 4009-003-S1 Voltage Relays 0 BwHP 4009-003-52 Underfrequency Relays 0 BwHP 4009-003-S3 Overcurrent Relays 0 BwHP 4009-003-S4 Reverse Power Relays 0 BwHP 4009-003-55 Differential Relays 'O BwHP 4009-003-56 Impedance Relays 0 BwHS 4002-010 48 Volt Station Battery 18 Month 0 Surveillance BwMP 3100-008 Reactor Head Installation 2 BwMP 3100-009 Reactor Head Removal 0 BwMP 3100-010 Reactor Head 0-Ring Replacement 0 BwMP 3100-026 Replacement of Mechanical Seals in the O Component Cooling Pumps ,

BwMP 3100-026Al Attachment A1 0 EwMP 3100-026A2 Attachment A2 0 BwMP 3100-026A3 Attachment A3 0 RwMP 3100-026A4 Attachment A4 0 BwMP 3100-041 Inspection, Installation and Removal 1 of the Reactor Cavity Boot BwMP 3200-001 Disassembly and Inspection of Limitorque 3 Operator BwMP 3200-001A1 Attachment 1 0 BwMP 3300-005 Removal and Installation of Primary 1 Containment Equipment Hatch

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Revision Procedure Title N BwMP 3300-038 Removal and Insta11at'on of the Primary 0 Manway Cover on the i.eam Generators BwMP 3300-038A1 Removal and Installation of the Primary 0 Manway Cover on the Steam Generators BwMP 3305-02 Inspection / Repairs For the Pressurizer 0 Spray Valves BwMP 3305-08 Disassembly / Reassembly of Copes-vulcan 0 Motor-0perated angle Globe Valve BwMP 3305-08A1 Disassembly / Reassembly of Copes-vulcan 0 Motor-0perated angle Globe Valve BwMP 3305-08A2 Disassembly / Reassembly of Copts-vulcan 0 Motor-0perated angle Globe Va./e BwMP 3305-014 Disassembly - Reconditioning - Reassembly 0 of Target Rock Solenoid Operated Valves BwMP 3305-014A1 Disassembly - Reconditinning - Reassembly 0 of Target Rock Solenoid Operated Valves BwMP 3305-014A2 Disassembly - Reconditioning - Reassembly 0 of Target Rock Solenoid Operated Valves BwMP 3305-014A3 Disassembly - Reconditioning - Reassembly 0 of Target Rock Solenoid Operated Valves BwMP 3305-014A4 Disassembiy - Reconditioning - Reassembly 0 of Target Rock Solenoid Operated Valves BwMP 3305-014A5 Disassembly - Reconditioning - Reassembly 0 of Target Rock Solenoid Operated Valves BwMP 3305-023 Disassembly - Reassembly of Jamesbury 0 24" - 48" Wafer-Sphere Butterfly Valves Model IM0-P3 BwMP 3305-023Al Disassembly - Reassembly of Jamesbury 0 24" - 48" Wafer-Sphere Butterfly Valves Model IMO-P3 BwMP 3305-023A2 Disassembly - Reassembly of Jamesbury 0 24" - 48" Wafer-Sphere Butterfly Valves Model IM0-P3

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Revision Procedure Title N .

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BwMP 330E-023A3 Disassembly - Reassembly of Jamesbury 0

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24" - 48" Wafer-Sphere Butterfly Valves

! Model IM0-P3

BwMP 3305-024 Disassembly - Reassembly of ITT Grinnell 0 Ball Valves

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t BwMP 3305-024A1 Attachment 1 0 1 .

{ BwMP 3305-028 Bench Testing / Setting of Safety / Relief 0 BwMP 3305-029 Inspection / Repair of Safety / Relief 0 Valves I BwMP 3305-029Al Inspection / Repair of Safety / Relief 0

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Valves

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BwMP 3400-001 Certification of Distance / Torque 2

Measuring Equipment

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BwMP 3400-T02 Micrometer Check Sheet 1 DwMP 3400-T03 Dial Indicator Check sheet 1 l

BwMP 3400-T04 Vernier Caliper Check Sheet 1

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BwMP 3400-T05 Certified Tool Log 1 BwMP 3400-T06 Torque Wrench Check Sheet 1

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BwIP 2100-001 Frequency of Calibrat!on of Plant 0

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Instrumentation BwlP 2400-017 Calibration of Displacement / Float level 0 Switch BwIP 2401-002 Bench Calibration of Westinghouse 7300 3 RTD A:aplifier Card NRA G01 and G03 BwlP 2401-002A1 RTD Amplifier 1 BwIP 2500-004 Calibration of a Pressure / Flow / Level 1 Inticating Single Alarm Loop with Computer Input BwlP 2500-017 Procedure for Proper Wire 2

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Wrapping /Termi-Point

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Revision Procedure Title N BwlS 3.1.1-008 Analog Operational Test and Channel 0 Verification / Calibration for Loop F-0425 Reactor Coolant Flow Loop B Channel II, Cabinet 2 BwIS 3.2.2-008A1 Appendix 1 Troubleshooting Guide Block 0 Diagram Reactor Coolant Flow Loop _F-0425, Prot. Cab. 2

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The inspector found that the plant procedures for maintenance were prepared to adequately control maintenance of safety-related systems within applicable regulatory requirement No violations or deviations were identifie . Status of Licensee Procrams for Compliance With Specific Sections of NUREG-0737, " Clarification of TMI Action Plan Requirements" Subsequent to the Three Mile Island Unit 2 accident certain NRC  ;

requirements were developed, from review of the incident, to reduce the possibility of any reoccurrence of such an accident. Thase requirements are delineatedThein NUREG-0737,s" Clarification of TMI

Action Plan Requirements." inspector review of activities '

relative to compliance with NUREG-0737 are as follows:

I.A.1.2 and I.C.3 Shift Supervisor Responsibilities Responsibilities of the Shift Supervisor are delineated in >

Administrative Procedure No. BwAP 300-100, " Conduct of Operations !

Prior to Fuel Load," and annually issued management directive NSDD-A09, " Conduct of Operations." The administrative procedures meet the requirements of NUREG-0737. Upon o erating license issuance BwAP 300-1 " Conduct of Operations,p' will be implemente It also contains Shlf t Supervisor duties. This section remains open pending implementation of BwAP 300- I.A.1.3 Shift Manning The inspector determined that the licensee's overtime and minimum shift crew activities are controlled by Braidwood Administrative Procedures BwAP 100-7, " Overtime Guidelines for Personnel that ,

Perform Safety Related Functions," and BwAP 320-1, "Shif t Manning."

The minimum shift coverage and overtime limitations delineated in l the BwAPs meet the requirements of NUREG-073 The BwAPs also l administer the shift manning and overtime requirements of Technical Specification Section 6.2.2 and Tables 6.2.1 and 6.2.la. This section remains open pending implementation of RwAPs 320-1 and 100- .

I.A.2.1 Immediate U) grading of Reactor Operator (RO) and Senior -

Reactor Operator (510) Training and Qualification In Section 13.2.1.2 of NUREG-0876, the staff concluded that the training program established by the licensee meets the requirements of this item. Technical Specification Sections 6.3 and 6.4 also specify the requirements for R0 and SR0 training required by NUREG-073 The inspector has determined that approximately 33 individuals will be licensed as SR0s and 14 individuals will be licensed as R0s for fuel load. This section remains open pending completion of licensee personnel training and licensin I.B.1.2 Evaluation of Grganization and Management Improvements of OL Applications The inspector reviewed the Organization and Administration Manual for the licensee's Nuclear Safety Department which describes the functioning of the Onsite Nuclear Safety Engineering Group (ONSEG).

The manual, dated June 1986, does not address the Braidwood ONSE This section remains open pending revision of the administration manual to identify group members for the Braidwood facilit I.C.2 Shift and Relief Turnover Procedures Braidwood Administrative Procedure BwAP 335-1, " Operating Shift Turnover and Relief," delineates the controls for operating staff shift turnover and relief. The inspectors review of BwAP 335-1 identified concerns relative to procedure adequacy. The procedure appears to be lacking some of NUREG-0578 requirements, NUREG-0578 requirements are referenced by FSAR and NUREG-0737 commitments, relative to checklists identifying acceptable plant parameter limits and recording of LC0 duration times on turnover checklist This item remains open pending further inspector revie I.C.4 Control Room Access The inspector reviewed Braidwood Administrative Procedures (BwAP)

900-10, " Control Room Access," and BwAP 300-1, " Conduct of Operations." These procedures assign responsibilities for access control during normal and emergency conditions. Routine access is limited to designated essential management and operating personne BwAP 900-10 appears to be inconsistent with NUREG-0737 requirements relative to personnel qualification for Control Room access control, NS0 having access authority - NUREG-0737 requires an SR0 license for this authority. Pending further inspector review and implementation of BwAPs this item remains ope I.C.5 Feedback of Operating Experience The licensee's controls for the Operating Experience Feedback system are contained in Braidwood Administrative Procedure BwAP 1260-1,

" Operating Experience Review Program," and Section V of the

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Organization and Administration Manual for the licensee's Nuclear Safety Department (NSD). BwAP 1260-1 is in the approval c'ycle and the NSD manual does not address the Braidwood facilities Onsite l Nuclear Safety Group (0NSG). Pending inspectors review of BwAP 1260-1 and formation cf the onsite Nuclear Safety Group,.this item

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remains ope ,

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I.C.6VerifyCorrectPerformanceofOperatidg' Activities <

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4 The inspector reviewed the licensee's prog am for compliance'with '

i this ite BwAP 330-1, "Braidwood Equipment Out-0f-Service m

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Procedure," BwAP 330-2, " Temporary Alterations," and BwAP 346 2

' "Use of Mechanical and Electrical Lineups," are the administrative i procedures which delineate the requirements of NUREG-0737 for, this '

item. The procedures are written and meet the NUREG requirement '

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The station I&M Department is in the process of revising

surveillance procedures to include an independent verification for

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required activities. Pending implementation'af;BwAPs 330-1 and

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340-2, this item remains ope : II.D.3 Valve Position Indication .

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In Section 7.5.2.3 of NUREG-0876, the staf'f found that the Braidwood

, design conformed to the requirements of this item. The inspector i

reviewed the installed safety grade environmentally qualified a positive valve position indication for.the primary safety valve PORVs and PORV block valves configurat, ion.' This item'ls consideres

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closed, i II.E.1.2 Auxiliary Feedwater System Initiat'on i and Flow

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In Section 7.3.2.8 of NUREG-0'376, the staff determined that the

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AFWS design conformed to requirements of NUREG-0737. The incpector

! reviewed the control board ~ configuration an-d witnessed pteoperatior,al

! testing of the system. In addition, the Byron AFWS system  !

installation, which is a duplicate of the Braidwood system was ! -

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, inspected by the NRC Office of Inspection and Enforcement IE) J j and found to be acceptable. Based on Braidwood resident inspector'! '

! and NRC Office IE reviews, this item is considered close /

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No violations or deviations were identifie l , /, ,

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7. Events Occurring During the Inspection '

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, On June 4, 1986, while conducting system testing, the Un:t 1 prissure relief tank (PRT) rupture disc burst relieving water to the repctor

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i containmen Initial re (rupture disc bursting) ports were that an explosion had occurrefand several co 1 injuries. The event was caused by miscommunications between tetting g and operations personnel which resulted in the inadvertent filling and

, pressurization of the PRT with pure water. There wasino radioactive 1

material involved. The evt.nt drew interest from local and Chicago news i medi ,

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l No violations or deviations were identifie . Concerned Citizen / Contractor On June 5, 1986, a construction worker at Braidwood approached the resident inspectors to express his concern about the safety of nuclear power plants. He stated that he lived in sight of the LaSalle County Station and was concerned about the safety of his home and family in light of the recent publicity on the near ATWS event at LaSalle and the news relationship to the Soviet Chernobyl accident. He further stated thathewouldprobablyleavetheBraidwoodStationjobafterthelicense was issue The senior res'ident inspector (operations) discussed reactor safety and the overall plans for public notification and safety with the individua The individual felt more comfortable about living near LaSalle, but still felthewouldleavetheBraidwoodjo No violations or deviations were identifie . Technical Specification Review The Braidwood Units 1 and 2 Technical Specifications for proof and review

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were received from NRR by memorandum dated June 10, 1986. The resident inspectors conducted the proof and review inspection on the assigned portions. The main thrust of this inspection was focused on clarity and enforceability of the specifications, action statements, and surveillance

requirements; ard in some cases, the technical accuracy of the document.

It should be noted that the Byron Technical Specifications were

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duplicated verbatim for the maiority of the Braidwood documen Since the plants are nearly identica for those duplicate portions of the Technical Specifications, the two volumes were compared for accurac Where differences exist between the two stations, Braidwood specific issues were reviewed against the FSAR, Standard Technical Specifications, and applicable regulatory document During the review, the inspector was able to resolve all questions through review of other documents, system walkdowns and/or interviews with licensee r personnel. The most prominent inconsistency was in Section 6, where the i new Station / Corporate management structure and titles are not correct, e.g., the Station Manager with two Superintendents and the Cor) orate

! Division Vice President. The inspector found that a change su)mittal is being processed on this issu The following is a list of those Technical Specifications by number and title that were reviewed by the resident inspector:

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1. 0 DEFINITIONS ACTION 1.14 FREQUENCYNOTATkON 1.15 IDENTIFIED LEAKAGE 1.19 OPERABLE - OPERABILITY 1.20 OPERATIOliAL MODE - MODE 1.22 PRESSURE BOUNDARY LEAKAGE 1.24 PURGE - PURGING 1.28 ;<EPORTABLE EVENT 1.34 STAGGERED TEST BASIS 1.37 UNIDENTIFIED LEAKAGE 1.40 VENTING TABLE FREQUENCY NOTATIO;4

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TABLE OPERATIONAL MODES

! 2.1 SAFETY LIMITS 2. REACTOR CORE 2. REACTOR COOLANT SYSTEM PRESSURE FIGURE 2.1-1 REACTOR CORE SAFETY LIllIT - FOUR LOOPS IN

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OPERATION 2.1 SAFETY _ LIMITS BASES 2. REACTOR CORE 2.1,2 REACTOR COOLANT SYSTEM PRESSURE l 3/4.0 APPLICABILITY l

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3/4.1 REACTIVITY CONTROL SYSTEMS 3/4. B0 RATION CONTROL Shutdown Margin - Tavg > 200 p Shutdown Margin - T avg 5 200 p Moderator Temperature Coefficient Minimum Temperature for Criticality

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3/4. B0 RATION SYSTEMS Flow Path - Shutdown Flow Paths - Operating Charging Pump - Shutdown Ch&rging Pumps - Operating Borated Water Source - Shutdown Borated Water Sources - Operating

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3/4.1'. 3 MOVABLE CONTROL ASSEMBLIES Group Height Position Indication Systems - Operating Position Indication System - Shutdown Rod Drop Time Shutdown Rod Insertion Limit Control Rod Insertion Limits

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FIGURE 3.1-1 R0D BANK INSERTION LIMITS VERSUS THERMAL POWER FOUR LOOP OPERATION 3/4.3 INSTRUMENTATION 3/4. MONITORING INSTRUMENTATION Movable Incore Detectors Seismic Instrumentation Loose-Part Detection System Chlorine Detection Systems 3/4. TURBINE OVERSPEE0 PROTECTION 3/4.4 REACTOR COOLANT SYSTEM 3/4. REACTOR COOLANT LOOPS AND COOLANT CIRCULATION Startup and Power Operation Hot Standby Hot Shutdown Cold Shutdown - Loops Filled Cold shutdown - Loops Not Filled Loop Isolation Valves-0peration Loop Isolation Valves-Shutdown

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3/4.4.2' SAFETY VALVES -

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Shutdown *

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Operating ,

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3/4. PRESSURIZER 3/4. RELIEF VALVES

3/4. STEAM GENERATORS'

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3/4. REACTOR COOLANT SYSTEM LEAKAGE

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Leakage Detection Systems Operational Leakage i

! TABLE 3.4-1 REACTOR COOLANT SYSTEM PRESSURE ISOLATION VALVES  :

'i i j Pressurizer  :

Overpressure Protection Systems l 3/4.4.11 REACTOR COOLANT SYSTEM VENTS 3/4.5 EMERGENCY CORE COOLING SYSTEMS

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3/4. ACCUMULATORS 3/4. ECCS SUBSYSTEMS - T,yg >_ 350*p 3/4. ECCS SUBSYSTEMS - T,yg < 350' t 3/4. REFUELING WATER STORAGE TANK

3/4.6 CONTAINMENT SYSTEMS

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3/4. DEPRESSURIZATION AND COOLING SYSTEMS ,

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Containment Spray System

Spray Additive System  ;

Containment Cooling System-

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. 3/4. COMBUSTIBLE GAS CONTROL-Hydrogen Monitors -

Electric Hydrogen Recombiners 3/4.7 PLANT SYSTEMS

, 3/4. TURBINE CYCLE'

Safety Valves

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.,----,,y~,- . - --<,,-,.-y , - #- ... _ .., ,.,...o - .. , . , ' , , .- . . , , s. ., . - - - ,,

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TABLE 3.7-2 STEAM LINE SAFETY VALVES PER LOOP Auxiliary Feedwater System Condensate Storage Tank-Main Steam Line Isolation Valves 3/4. STEAM GENERATOR PRESSURE / TEMPERATURE LIMITATION 3/4. COMPONENT COOLING WATER SYSTEM 3/4. ESSENTIAL SERVICE WATER SYSTEM 3/4. ULTIMATE HEAT SINK 3/4. CONTROL ROOM VENTILATION SYSTEM 3/4. NON-ACCESSIBLE AREA EXHAUST FILTER PLENUM VENTILATION SYSTEM

, 3/4.7.10 FIRE SUPPRESSION SYSTEMS 3/4.7.12 AREA TEMPERATURE MONITORING TABLE 3.7-6 AREA TEMPERATURE MONITORING 3/4.10 SPECIAL TEST EXCEPTIONS 3/4.10.1 SHUTDOWN MARGIN 3/4.10.2 GROUP HEIGHT, INSERTION, AND POWER DISTRIBUTION LIMITS 3/4.10.4 REACTOR COOLANT LOOPS 3/4.10.5 POSITION INDICATION'SYSTEML -SHUTDOWN 3/4.0 APPLICABILITY 3/4.1 REACTIVITY CONTROL SYSTEMS

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3/4. RATION CONTROL 3/4. B0 RATION SYSTEMS 3/4. M0VABLE CONTROL ASSEMBLIES

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3/4.4 REACTOR COOLANT SYSTEM 3/4. REACTOR COOLANT LOOPS AND C0OLANT CIRCULATION 3/4. SAFETY VALVES 3/4. PRESSURIZER 3/4. RELIEF VALVES 3/4. STEAM GENERATORS 3/4.4.G, REACTOR COOLANT SYSTEM LEAKAGE 3/4.4.11 REACTOR VESSEL HEAD VENTS 3/4.5 EMERGENCY CORE COOLING SYSTEMS ,

3/4. ACCUMULATORS 3/4. ECCS SUBSYSTEMS 3/4. ECCS SUBSYSTEMS 3/4. REFUELING WATER STORAGE TANK 3/4.7 PLANT SYSTEMS 3/4. ' TURBINE CYCLE 3/4. STEAM GENERATOR PRESSURE / TEMPERATURE LIMITATION 3/4. COMPONENT COOLING WATER SYSTEM 3/4. ESSENTIAL SERVICE WATER SYSTEM 3/4. ULTIMATE HEAT SINK 3/4. CONTROL ROOM VENTILATION SYSTEM 3/4. NON-ACCESSIBLE AREA EXHAUST FILTER PLENUM VENTILATION SYSTEM 3/4.7.12 AREA TEMPERATURE MONITORING 3/4.10 SPECIAL TEST EXCEPTIONS 3/4.10.1 SHUTDOWN MARGIN 3/4.10.2 GROUP HEIGHT, INSERTION, AND POWER DISTRIBUTION LIMITS 25 ,

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3/4.10.4 REACTOR COOLANT LOOPS 3/4.10.5 POSITION INDICATION SYSTEM - SHUTDOWN 5.1 SITE 5. EXCLUSION AREA 5. LOW POPULATION ZONE FIGURE 5.1-2 LOW POPULATION ZONE 5.3 REACTOR CORE 5. FUEL ASSEMBLI . CONTROL R00 ASSEMBLIES 5.4 REACTOR COOLANT SYSTEM 5. DESIGN PRESSURE AND TEMPERATURE 5. VOLUME 5.7 COMPONENT CYCLIC OR TRANSIENT LIMIT TABLE 5.7-1 COMPONENT CYCLIC OR TRANSIENT LIMIT 6.1 RESPONSIBILITY 6.2 ORGANIZATION FIGURE 6.2-1 0FFSITE ORGANIZATION FIGURE 5.2-2 UNIT ORGANIZATION TABLE 6.2-1 MINIMUM SHIFT CREW C0!1 POSITION TABLE 6.2-la MINIMUM SHIFT CREW COMPOSITION 6.3 UNIT STAFF QUALIFICATIONS 6.4 TRAINING 6.5 REVIEW INVESTIGATION AND AUDIT 6. FFSITE Offsite Review and Investigative Function Audit Function Authority-Records Procedures Personnel

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6. ONSITE Onsite Review and Investigative Functions Responsibility Authority Records

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Procedures Personnel 6.6 REPORTABLE EVENT ACTION 6.7 SAFETY LIMIT VIOLATION 6.8 PROCEDURES AND PROGRAMS 6.9 REPORTING REQUIREMENTS 6. ROUTINE REPORTS Startup Report Annual Reports Monthly Operating Report Radial Peaking Factor Limit Report 6. SPECIAL REPORTS 6.10 RECORD RETENTION No violations or deviations were identifie . Procurement While reviewing the licensee's Nonconformance (NCR) Log, the inspector noted that NCR 821, issued on May 30, 1986, identified a problem with some American Society of Mechanical Engineers (ASME),Section III, Class 2, studs manufactured by Cardinal Industrial Products Corporation (CIPC). Investigation by the inspector revealed that CIPC was removed from the licensee's Approved Bidders List (ABL) on July 17, 1984 and was ,

reinstated October 25, 1985. The inspector determined that the studs -;

identified on NCR 821 were su accordance with the licensee'pplied by Order s Purchase a material supplier, 29730 Hub, Inc., in This purchase order was issued to Hub, Inc. on April 8,1985. Even though Hub, Inc., l was on the ABL, the studs were manufactured by CIPC and were received I when CIPC was not on the AB After discussing this issue with the i licensee's QA Department, the licensee conducted an extensive review of purchase orders issued to Hub, Inc. This review identified other ASME Section III material (studs, nuts, rods, etc.) received from CIPC during the time CIPC was not on the ABL. This material was procured by the licensee through Hub, Inc. There were no purchase orders issued to CIPC

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, by the licensee. A significant amount of this material procured through Hub, Inc. was shipped directly to the Braidwood site from Cardinal. The purchase orders issued to Hub, Inc. in which material was manufactured by CIPC were:

P.O. Number Date of Issuance 289974 8/20/84 291079 8/22/84 297305 4/08/85 298094 6/24/85 748050 1/29/85 749901 4/04/85 749445 3/08/85 The inspector reviewed the licensee's Quality Assurance Manual, Revision 103, to determine what programmatic controls the licensee had established for vendors removed from the ABL. This review determined that Quality Requirement (QR) 4.0, " Procurement Document Control," and Quality Requirement 7.0, " Control of Purchased Material, Equipment and Services,"

do not address the removal of a vendor from the ABL for quality assurance or technical performance reasons. These Quality Requirements are the upper tier documents of the licensee's Quality Assurance Manual which establishes the Qa programmatic requirements. However, QR 7.0 does address those cases where spare parts or replacement parts can be procured from an Original _ Equipment manufacturer who no longer can be retained on the ABL because of an inadequate QA program document. However, such a procurement requires that a joint technical and QA documented evaluation be conducted to establish requirements and control The inspector also reviewed Attachment A to Quality Procedure 4.2,

" Review, Approval, and Maintenance of Vendor Quality Assurance Programs and Certificates." This attachment requires that a vendor be removed from the ABL for lack of QA or technical performance. For those vendors removed from the ABL, change orders to the original procurement order shall not be issued which add to the original procurement order. This attachment also states that deliveries of work, materials, or services for procurement orders issued prior to the date of removal may be completed provided the work, materials, or services is accepted with a documented evaluation of the qualit Receiving and istuing material manufactured by a vendor removed from the ABL is considered an unresolved item (456/86031-01(DRP); 457/86024-01(DRP)).

The licensee has initiated the following corrective actions:

• A review to their 0A manual to precluded recurrence of a similar violatio * Issued NCR 679, Revision 1, to identify and address the potential hardware problem of receiving material from the unapproved vendor, CIP __ __ _ _ - _

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• Reviewing the procurement process to determine if there are other similar cases where material was manufactured by an unapproved vendor and supplied by a vendor on the ABL. The results of this review will be documented in QA Surveillance Report 622 No violations or deviations were identifie . Plant Tours and Independent Assessments The inspectors conducted routine plant tours during the inspection period to make an independent assessment of equipment conditions, plant conditions, construction activities, security, fire protection, general personnel safety, housekeeping, and adherence to applicable regulatory requirements. During the tours, the inspector reviewed various logs, daily orders, interviewed personnel, attended shift briefings, witnessed various construction work activities, and independently determined equipment status. During the shift changes, the-inspector observed operator and shift engineer turnovers and panel walkdown As a result of these tours, the inspectors noted that housekeeping of the Unit 1 Auxiliary Building and Containment Building had deteriorated to an unacceptable leve This unacceptable housekeeping was partially caused :

by the licensee's intensified work activities to ready Unit 1 for fuel loa Examples of poor housekeeping included:

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• debris in Unit 1 recirculation sum * cover off the motor operator for valve 1W0056 * fasteners removed from a flange and left in work are * debris such as soda cans, rags, and excessive dirt in several areas of the plan The licensee took immediate acceptable corrective action when informed of the inspectors' concerns. The inspectors were aware of the licensee's approach of area turnovers and the requirement of a clean area at time of turnover. However, the inspectors stressed to the licensee that the plant must be maintained at an acceptable housekeeping level regardless if the area has or has not been turned over to operations. Housekeeping will continue to be monitored by the inspectors to evaluate the licensee's corrective actio No violations or deviations were identifie . Meetings, Training and Other Activities On June 17, 18, and 19, 1986, the resident inspectors attended a Region III Resident Inspector Seminar at the Dillon Inn in Downers Grove, Illinoi f

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13. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviation An unresolved item disclosed during the inspection is discussed in Paragraph 1 . Exit Interview The inspector met with licensee and contractor representatives denoted in Paragraph 1 during and at the conclusion of the inspection on August 1, 1986. The inspectors summarized the scope and results of the inspection and discussed the likely content of this inspection report- .The licensee acknowledged the information and did not indicate that any of the information disclosed during the inspection could be considered proprietary in natur a 30