IR 05000456/1986038
| ML20215J588 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/17/1986 |
| From: | Choules N, Jablonski F, Sutphin R, Vandel T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20215J583 | List: |
| References | |
| 50-456-86-38, NUDOCS 8610270100 | |
| Download: ML20215J588 (17) | |
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U.S. NUCLEAR REGULATORY COMMISSION i
REGION III
Report No. 50-456/86038(DRS)
Docket No. 50-456 Construction Permit No. CPPR-132 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Station, Unit 1 Inspection At: Braidwood Site, Braidwood, IL Inspection Conducted: August 18, 19, 21, 25-27 and September 8-11, 16, 18, 1986 GSln f
/d/n/85
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Inspectors:
T. E.
andel
Da'te /
,dbSt N. C.
houles
/#/H/85 Da'te '
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R. N. Sutphin
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Dats ah(nS
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Approved By:
F.
lonski, Chief
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Quality Assurance Programs Date /
Sections Inspection Summary Inspection on August 18, 19, 21, 25-27 and September 8-11, 16, 18, 1986 (Report No. 50-456/86038(DRS))
Areas Inspected:
Routine safety inspection to conduct:
(1) a pre-operations review of the plant operations program procedures for; Document Control (35742),
Receipt Storage and Handling of Equipment (35747), Records (35748), Tests and Experiments (35749), Test and Measuring Equipment (35750), Safety Committee Activity (40301), Operating Staff Training (41301); and (2) an inspection of Preop Test Program Records (39301).
Results: Violations or deviations were not identified in the eight areas inspected; however, one unresolved matter was identified that requires additional NRC review.
8610270100 861017 PDR ADOCK 05000456 G
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DETAILS i
1.
Persons Contacted Commonwealth Edison Company (CECO)
R. E. Aker, Rad / Chem Supervisor
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- P. L. Barnes, Regulatory Assurance Supervisor K. Bartes, Training Supervisor
- D. L. Cecchett, Regulatory Assurance
- A. Chomacke, Regulatory Assurance
- A. J. D' Antonio, Regulatory Assurance
- L. E. Davis, Assistant Superintendent Technical Services M. Eubanks, IC Training Coordinator
- E. E. Fitzpatrick, Station Manager J. Giuffre, MM Training Coordinator D. Graves, Central Files Supervisor
- G. E. Groth, Assistant Construction Manager
- P. Holland, Regulatory Assurance J. L. Huffman, Master Mechanic
- J. K. Jasnosz, Regulatory Assurance B. H. Kulik, Senior Quality Assurance (QA) Inspector
- R. D. Kyrouac, Station QA Supervisor R. Lemke, Technical Staff Supervisor
- T. J. Lewis, Station Startup G. W. Nelson, Assistant Technical Staff Supervisor
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E. R. Netzel, Site QA Supervisor D. E. Paquette, Assistant Superintendent Maintenance
- C, W. Schroeder, Services Superintendent
- B. B. Stephenson, Manager Nuclear Safety
- Mc L. Takaki, Quality Control Supervisor M. Wall, EM Training Coordinator and Acting Foreman R. Wright, Program Training Center Training Superintendent U.S. Nuclear Regulatory Commission (NRC)
- W. J. Kropp, Senior Resident Inspector (Construction)
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- T. E. Taylor, Resident Inspector (Operations)
- T. M. Tongue, Senior Resident Inspector (Operations)
- B. N. Kulieke, KS Associates Consultant
- R. J. Siewert, KS Associates Consultant
- Denotes those in attendance at one or both the September 4 and September 11 exit meetings.
Other licensee project personnel were contacted during the course of the inspection.
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2.
Measuring and Test Equipment (M&TE) Program (35750)
The inspector reviewed the licensee's M&TE program to ascertain whether the QA program relating to test and measuring equipment had been
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established in accordance with the Quality Assurance Program and 10 CFR 50, Appendix B requirements. The following items were considered during this review: equipment inventory lists, calibration frequencies, and calibration procedures had been established; requirements for calibration status marking recall system for calibration and out of calibration controls had been establ.ished; controls for adding new equipment to inventory lists had been established, and requirements that standards used for calibration are traceable to the National Bureau of Standards.
Implementation of the program was also reviewed.
a.
Documents Reviewed (1) Braidwood Administrative Procedures
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(a) BwAP 400-4, " Control of Portable Measurement and Test Equipment," Revision No. 3.
(b) BwAP 300-004, " Control of Electrical Maintenance Certified Instruments," Revision No. 1.
(c) BwIP 2400-26, " Certification of a Pressure / Vacuum Gage,"
Revision No. O.
t (d) BwIP 2400-029, " Certification of Portable Manometers,"
Revision 0.
(e) BwIP 2400-030, " Certification of a Precision Mercurial Manometers Type FA-173," Revision 1.
(f) BwMP 3400-001, " Certification of Distance / Torque Measuring Equipment," Revision 2.
(2) Quality Assurance Manual Quality Requirement (Q.R.) and Quality Procedures (Q.P.)
(a) Q.R.12:0, " Control of Measuring and Test Equipment."
(b)
Q.P. 12-1, " Calibration Control of Commonwealth Edison
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Test and Measurement Equipment."
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(c)
Q.P. 12-51, " Control of Measuring and Test Equipment for Operations - Portable Test and Measurement Equipment."
(d)
Q.P. 15-52, Attachment A:
" Deviation Report Review Checklist."
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(3) Calibration Records for Selective M&TE Equipment.
(4) Selected deviations Reports (DR) for "Out of Tolerance" M&TE.
b.
Results of Inspection (1) The licensee's procedures for the control of measuring and test equipment was BwAP 400-4, Revision 3.
Review of this procedure revealed the following:
(a) The procedure did not address actions be taken for lost or stolen instruments.
(b) There were no instructions descricing action taken when an instrument is deleted from use.
(c) The procedure required a Discrepancy Record (DR) to be initiated when equipment was deficient. The procedure did not indicate that a review of prior calibrations be performed and appropriate corrective action be taken; however review of completed DRs indicated that reviews had been performed.
(d)
In Section 3.c.3.d of Procedure BwAP 400-4 the require-ment for hanging a QA hold tag to deficient equipment is described.
There was no specific requirement restricting use of the deficient equipment until it is recalibrated.
The licensee committed to review the inspector's comments and revise BwAP 400-4 as appropriate.
This is considered an open item pending review of the revised procedure (456/86038-01).
(2) The maintenance department consists of three groups; electrical, mechanical, and instrument and control.
(I&C) BwAP 300-004, Revision 1, was the electrical group's procedure for local control of measuring and test equipment (M&TE).
Review of the mechanical, and instrument and control group's control of M&TE revealed the following:
(a) The mechanical group did not have a procedure like BwAP 300-004 for local control of M&TE. Unlike the electrical group, the M&TE checkout log did not require listing the device on which the M&TE was used.
(b) Similarly, the I&C group did not have a local procedure for the control of M&TE like BWAP 300-004. The I&C group schedules and calibrates instruments with calibration frequencies less than six months. All other M&TE are scheduled and calibrated offsite by the company's system Operational Analysis Department. The I&C group did not have instructions for the local control of instruments calibrated at less than six month intervals.
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The licensee consnitted to review the inspectors coninents and either prepare new procedures for the mechanical and I&C groups or write one procedure for all three groups. This is considered an open item pending review of the new procedure or procedures (456/86038-02).
(3) The inspector reviewed implementation of the M&TE program.
Calibration records for selected equipment were reviewed to verify that instruments were being calibrated at the required frequencies, that DRs were being prepared and properly dispositioned for "out of tolerance equipment," and that equipment was being properly tagged to indicate calibration status. No problems were identified.
During the inspector's review of calibration records for weights used to calibrate the licensee's torque wrench tester, the inspector noted that the original calibration of the weights by the vendor in July 1985 had been rejected by the licensee's system Operational Analysis Department (0AD).
The calibration was rejected because the weights were calibrated to National Bureau of Standards (NBS) acceptance Class F instead of Class C which is a tighter tolerance than Class F.
0AD sent the weights to a metrological service for calibration.
The results of this calibration performed in January 1986, indicated that five weights out of twelve did not meet Class C requirements and varied considerably from the vendor calibration.
The vendor performed a recalibration of the five weights and determined that they met Class C requirements. The vendor had the calibration of the weights verified by the State of Illinois Bureau of Laboratories in March 1986. The recalibrations of the two 'ifty pound weights indicated they were overweight but met Class C require-ments. The recalibration by the vendor identified that the other three weights were substantially different from the metrological service calibrations.
After reviewing the calibration data, the inspector questioned how the licensee could accept the calibrations performed on the seven weights performed by the metrological service that were not returned to the vendor when it appeared that the metrological service calibrations were not accurate. The licensee agreed with the inspectors concern and sent all twelve weights to the state of Illinois Bureau of Laboratories for recalibration. This item appeared to be an isolated incident and does not necessarily have impact on the overall M&TE Program. The affect on calibration of torque wrenches will be evaluated by the inspector after the weights have been recalibrated. This item is considered unresolved pending review of the recalibration data (456/86038-03).
No violations or deviations were identified; however, two open items and one unresolved item were identified.
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3.
Receipt Storage and Handling of Equipment and Materials (35747)
The licensee's QA program for the receipt, storage and handling of equip-ment and materials was reviewed.
The review included verifications that the program was in conformance with regulatory requirements, commitments in the application, and industry guides and standards.
a.
Documents Reviewed (1) Braidwood Administrative Procedures (a) BwWP 800-1, " Levels and Conditions of Storage,"
Revision No. 1.
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(b) BwWP 800-2, " Receiving Handling and Packaging,"
Revision No. 1.
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(c) BwWP 800-03, " Handling and Storage of Welding Materials," Revision No. O.
(d) -BwWP 800-04, " Receiving and Storage of Solution
Standards and Technical Specification Related Chemicals," Revision No. O.
(e) BwWP 800-5, " Control of Items with Shelf-Life and/or Preventive Maintenance Requirements,"
Revision No. 1.
(f) BwMP 1200-001, " Inspection of Maintenance Department
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Rigging Equipment," Revision No. 1.
(g) BwMP 1200-T01, " Annual Rigging Inspection Record Checklist," Revision No. O.
(h) BwMP 122-002, " Monthly / Yearly Crane Inspection,"
Revision No. O.
t (i) BwMP 1200-T02, " Daily Visual Crane Inspection Checklist," Revision No. O.
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(j) BwMP 1200-003, " Load Test of Cranes," Revision No. O.
(k) BwMP 1200-T03, " Monthly Crane Inspection Checklist," Revision No.1.
I (1) BwMP 1200-004, " General Surveillance Procedure
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Specific to Mechanical Maintenance," Revision No. O.
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(m) BwMP 1200-T04, " Yearly Crane Inspection Checklist,"
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Revision No. 0.
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(n) BwMP 1200-T05, " Load Test of Crane Checklist,"
Revision No. O.
l (o) BwMP 3100-003, " Inspection and Repairs of Split
Casing Pumps," Revision No. 2.
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l b.
Results of Inspection l
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(1) The inspector verified that administrative controls, for
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receipt of safety-related items, had been established in
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accordance with commitments to provide for the following:
(a) Written requirements for conducting receipt inspections of
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all incoming safety related materials and suppliers.
(b) Receipt inspection for shipping damage.
i (c) Examination of materials and supplies for conformance
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with requirements specified on original procurement
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documents.
(d) Documentation and retention of record of receipt i
inspections performed.
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(e) Assignment of responsibilities for these functions.
(f) Controls for the disposition of items received including both acceptable and nonconforming items.
(g) Marking and segregating of nonconforming items.
(h) Requirements to prohibit the use of equipment or material in nonconforming status.
(1) Evaluation of suppliers of nonconforming items.
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(j) Policies for conditional releases.
(2) The inspector verified that controls for the storage of safety-related items had been established in accordance with
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commitments to provide for the following:
(a) Written requirements providing for levels of storage and j
appropriate environmental conditions.
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(b)
Storage controls including access controls, identification of items, coverings, and preservatives.
(c) Periodic inspections and audits of storage areas.
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(d) Shelf-life controls.
(e) Maintenance of items in storage, i
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(3) American National Standard ANSI N 18.7-1976 (ANSI-3.2)
Section 5.2.13.4 requires that measures be provided to control handling, storage and shipping, including cleaning, packaging and preservation of material and equipment in accordance with established instructions, procedures or drawings, to prevent damage, deterioration and loss.
In the area of loss control, the licensee has established an inventory of safety-related items on a two year cycle.
This is a rather long period of time between planned reviews of the inventory and determination of loss. This policy will be reviewed by the licensee to determine if it meets their need for a timely response to this requirement.
Pending the results of this review it will be considered an open item (456/86038-04).
(4) On the subject of shelf-life control the licensee has established a policy that provides for a review of status of items under shelf life control every four months. This is not considered a timely response to this requirement. Some saftey-related items have a procurement lead time of several months, which may not be initiated until shelf-life has expired if their review only includes present status every four months. The licensee indicated that they had previously decided to review the area of spare parts control and will consider including this shelf-life aspect in their review. This is considered an open item pending the results of the review (456/86038-05).
(5) The licensee has established a Level "A" storage area in accordance with their program commitments; however, nothing is stored there. A Level "A" area should be used for items that require special controlled conditions of temperature, humidity and cleanliness in accordance with manufacture's
recommendations or industry practices.
Items classified to Level A storage are those that are exceptionally sensitive to environmental conditions and require special measures for protection from one or more of the following effects:
temperatures outside required limits, sudden temperature changes, humidity and vapors, gravitational (g) forces, physical damage, and airborne contamination (e.g. rain, snow, dust, dirt, salt spray, and fumes).
This classification usually includes special electronic equipment and instrumentation
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or parts such as printed circuit boards. The licensee presently has these items stored in Level "B" storage which has a wider range of temperature controls, humidity control and exposure
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to more dust, dirt, fumes, etc., than Level "A" storage.
Pending a licensee review of their policies in this area it will be considered an open item (456/86038-06).
(6) The inspector verified that controls had been established for routine and special handling of safefty-related items including rigs, cranes and hoisting equipment.
No violations or deviations were identified; however, three open items were identified.
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4.
Tests and Experiments (35749)
The licensee's program for planned tests and exoeriments was reviewed.
The review included verification that the program was in conformance with regulatory requirements, commitments in the license application, and industry guides and standards.
a.
Documents reviewed (1) Braidwood Administrative Procedures (a) BwAP 1205-3, "On-Site Review and Investigation Function." Revision No. 3.
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(b) BwAp 1205-2, "On-Site Review of Procedures,"
Revision No. 4.
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(c) BwAp 1205-6, " Conduct of 10 CFR 50.59 Safety Evaluations," Revision No. O.
(d) BwAp 1205-6TI, "10 CFR 50.59 Format for Safety Evaluations," Revision No. O.
(e) BwAp 1205-6T2, "10 CFR 50.59 Checklist for Facility Changes," Revision No. O.
(f) BwAP 1205-7, " Procedures for the Delegation of Authority Assigned by the Q.A. Manual," Revision No. O.
(g) BwAP 1300-2, " Permanent procedure Preparation, Revision and Approval," Revision No. 6.
(h) BwAP 1300-2T2, " Procedure Development and Approval Log," Revision No.1.
(1) BwAP 1300-3, " Preparation and Approval of Temporary Procedures and Temporary Changes to the Permanent Procedures," Revision No. 2.
(j) BwAP 1205-3T1, "Braidwood On-Site Review and Investigation Report," Revision No. 1.
(k) BwAP 1300-2T4, " Safety Evaluation," Revision No. O.
b.
Results of Inspection (1) The inspector verified that administrative controls contained methods for the handling of requests and proposals for conducting plant tests and experiments involving safety related components, systems or structures, or modes of operation different from those specified in the FSAR.
Responsibilities
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and methods had been established to assure that written safety evaluations pursuant to 10 CFR 50.59 will be developed for each test or experiment not described in the FSAR to assure it does not involve an unreviewed safety question or a change in the Technical Specifications.
(2)
10 CFR 50.59 specifies that annually, or at such shorter intervals as may be specified in the license, the licensee shall submit to the NRC a report containing a brief description of such changes, tests, and experiments, including a summary of the safety evaluation of each. The licensee's Technical Specification, Section 6.9.1.4, did not include the regulatory requirement nor was it in any of the administrative procedures presented to the inspector for review during the inspection.
Pending a review by the licensee of the way they will identify and communicate this requirement to the operating staff this is an open item (456/86038-07).
5.
Safety Committee Activity (40301)
The licensee's planned safety committee activity was reviewed to verify that the on-site and off-site safety review committees, or
their equivalents, had been established and would be able to functioi in conformance with technical specifications requirements and any other related commitments in the license application. This inspection did not include a review of the independent safety engineering group required by NUREG-0737. The off-site safety review activities were reviewed at corporate headquarters.
a.
Documents Reviewed (1) Braidwood Administrative Procedures (a) BwAP 1205-1, " Selection and Authority of On-Site Review Committee," Revision No. 2.
(b) BwAP 1205-3, "On-Site Review and Investigative Function," Revision No. 4.
(c) BwAP 1205-2, "On-Site Review of Procedures,"
Revision No. 4.
(d) BwAP 1205-2T2, "On-Site Review Requirements,"
Revision No. 6.
(e) BwAP 1205-1T2, " Disciplines Authorized for Qualified Members of the Braidwood Station On-Site Review Committee," Revision No. 3.
(f) BwAP 1205-4, "Use of the Certification of Participants to ANSI - Recognized Requirements," Revision No. O.
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(g) BwAP 1205-4T1, " Certification of rarticipants to ANSI - Recognized Requirements," Revision No. 2.
(h) BwAP 1205-1T1, " Disciplines for On-Site Review,"
Revision No. 2.
(i) BwAP 1205-5, " Signature Alternates for Procedure Content and Technical Review," Revision No. 1.
(j) BwAP 1205-6, " Conduct of 10 CFR 50.59 Safety Evaluations," Revision No. O.
(k) Department of Nuclear Safety Organization Charts.
(1) Department of Nuclear Safety-Requirements for Manager of Nuclear Safety.
b.
Results of Inspection (1) The inspector reviewed the licensee's program for Safety Committee Activity with reference to requirements in Section 6.5.2 of the Technical Specifications (TS)
for the onsite review and investigative functions.
The following observations were made by the inspector regarding the compatibility of the program, organization and commitments for onsite reviews:
(a) The present organization established the position of station manager, however, the TS refers to the position as a station superintendent.
(b) The TS in Section 6.5.2.a(2) states that the station (manager) superintendent shall approve participants for this (onsite review and investigative) function; however, Administrative Procedure BwAP 1205-1, Revision No. 2, does not provide for approval of participants by the station manager, as a position responsibility.
(c) The TS in Section 6.5.2.f(2) states that " Personnel performing the onsite review and investigative furection shall meet minimum accept-ble levels as described in ANSI N18.1-1971, Sections 4.2 and 4.4; however, neither BwAP 1205-2 nor BwAP 1205-4 include this requirement as an objective or responsibility.
(d) The TS in Section 6.5.2.c states that the technical staff supervisor (who has been appointed as the senior participant for the onsite review and investigative function) make recommendations to the station (manager)
superintendent and have the authority to request the action necessary to ensure compliance with rules, regulations, and procedures when in his opinion such
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action is necessary. The station (manager) superintendent shall follow such recommendations, or select a course of action that is more conservative, regarding safe operation of the facility. The administrative procedures reviewed by the inspector do not include this responsibility of the station manager to take the action recommended by the technical staff supervisor acting as the senior participant of the~onsite review and investigative function.
(e) Section 6.5.2.c of the TS also states that "All such disagreements shall be reported immediately to the Division Vice President and General Manager - Nuclear Stations and the Supervisor of the Offsite Review and Investigative Function." The inspector was unable to determine who was actually assigned this responsibility
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by administrative procedure.
It also appears that the title " Division Vice President and General Manager -
Nuclear Station" is an obsolete title and needs to be corrected.
(f) Administrative Procedure BwAP 1205-3, Revision No. 4, in Section c.2.f does not accurately reflect the equivalent statement in the T.S. which is item 6.5.2.b(10); " Review of unit operations to detect potential hazards to nuclear safety."
(g) Administrative Procedure BwAP 1205-3, Revision No. 4, in Section c.2.k does not accurately reflect the equivalent statement in the TS which is item 6.5.2.b(11); " Review of any accidental, unplanned, or uncontrolled radioactive release...". The procedure also does not state who has
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the responsibility to make necessary reports to the offsite review and investigative function.
(h) Administrative Procedure BwAP 1205-1, Revision No. 2, and attachment BwAP-1T1, Revision No. 2, " Disciplines for On-Site Review," Item "E", uses the term " Radiation Protection" as referenced in ANSI Standard N18.1; however, the TS uses the term " Radiological Controls" for disciplines required for personnel performing onsite review.
This may be an editorial error but it should be reviewed for consistency by the licensee to national standards (ANSI N18.1).
(1) The above items collectively are considered an open item pending review and resolution by the licensee (456/86038-08).
(2) The inspector reviewed the licensee's offsite review program with reference to the requirements in Section 6.5.1 of the TS for offsite review and investigation program. Minor concerns were identified; however, the licensee corrected all but one prior to the exit meeting at the conclusion of the inspection.
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The exception was the revision control process for the procedure manual used by the offsite review and investigative function.
This is an open item pending review by the NRC of the adopted review control process (456/86038-09).
6.
Document Control (35742)
The document control program to be used during operations at Braidwood was assessed by review of the applicable governing procedures and instructions, by discussions with licensee personnel and by observation of documents and activities relating to the governing procedures and instructions.
This review was conducted to verify that the licensee had established and implemented the necessary administrative controls governing, handling, and distributing of documents for safety related equipment and systems.
a.
Documents Reviewed (1) Braidwood Administrative Procedures (a) BwAP 1340-1, " Drawings Issued Procedure," Revision No. 7.
(b) BwAP 1340-7, " Controlled Documents," Revision No. 2.
(c) BwAP 1340-15, " Station Drawing Change Control,"
Revision No. O.
(d) "Mastea Records Retention Schedule List" per BwAP 1340-3
" Document Retehtion" (2) Commonwealth Edison Co. (CECO) Quality Assurance Manual (a) Quality Requirement Q.R.6.0 " Document Control" (b) Quality Procedure Q.P. 6-51 " Document Control For Operations - Transfer of Records" (c) Quality Procedure Q.P. 6-52 " Document Control For Operations - Distribution and Control of Engineering Documents and Drawing Change Control" b.
Results of Inspection (1) The inspector observed that distribution of aperture cards and/or hard copies of controlled documents is handled by central files personnel responsive to the procedural requirements.
(2) Control of information only copies is accomplished by use of pink paper for ready identification while a "For'Information Only" stamp is also available to stamp white copies when pink paper is unavailable.
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(3) The recipient of issued drawings for work requests or modifications is responsible for controlling and discarding the obsolete copies when work is completed.
(4) A computer printout of the master revision listing is readily available to all employees for verification of the latest revision.
(5) The inspector reviewed selected QA audit reports regarding adequacy of program controls. Although obsolete drawing control assessment was not directly audited, no lack of control problems were identified.
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(6) Document controls met requirements to the extent that drawings, including changes, were distributed to the location where the prescribed activity was to occur.
In discussions with licensee personnel and at the exit meeting, the inspector expressed concern regarding the lack of positive controls for obsolete documents and suggested serious consideration of a more positive disposition system.
7.
Oge_ra_tig Staff Training (41301)
This inspection was performed to verify that a documented training program had been established and implemented for the operating plant principal staff and personnel. The inspection consisted of review of applicable procedures and instructions, observation of training facilities, instruction sessions in progress, lesson plans utilized, individual training records reflecting actual training received, and discussions with training personnel, training coordinators and personnel receiving and/or having received training.
a.
Documents Reviewed (1) Braidwood Administrative Procedures (a) BwAP 600-2, " Training Department Organization,"
Revision No. O.
(b) BwAP 600-3, " Personnel Training Records," Revision No. 1.
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(c) BwAP 600-6, " Training Department Fonns," Revision No. 4.
(d) BwAP 600-7, " Equipment Operator Training," Revision No. O.
(e) BwAP 600-8, " Equipment Attendant Initial Training Program Procedure," Revision No. O.
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(f) BwAP 600-9, " Operations and Training Reviews Board,"
Revision No. O.
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(g) BwAP 600-11, " Nuclear-General Employee Training (N-GET),"
Revision No. 2.
(h) BwAP 600-12, "New Employee Orientation," Revision No. O.
(1) BwAP 600-13, "QA Training for Management Training,"
Revision No. 3.
(j) BwAP 600-14, " Instructor Evaluation Program,"
Revision No. 1.
(k) BwAP 600-17, " Training Program Evaluation,"
Revision No. 1.
(1) BwAP 600-23, "Non-Licensed Operator Retraining Program,"
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Revision No. 2.
(2) Unnumbered Lesson Plans (a) Emergency Core Cooling System, Revision No. 1.
(b) Residual Heat Removal System, Revision No. 1.
b.
Results of Inspections (1) The inspector observed the Production Training Center (PTC)
which was located off-site but adjacent to the Braidwood Site, as well as the training center located onsite.
Both training facilities were equipped with very good classrooms, visual aids, and instruction materials which are all positive contributors to good classroom instruction.
(2) Training sessions attended by the inspector were observed to be
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well prepared, presented well, and received positive class response and questions. Classroom utilization of aids and instruction materials supported student confidence in learning ability.
(3) The inspector reviewed training records of six students from various assigned site responsibilities. The records were up-to-date and indicated qualification status.
(4) During discussions with training personnel the inspector learned that a training program for maintenance personnel had not been developed.
Even though maintenance personnel do receive the N-GET & PWR Indoctrinations basics, a complete program for training, qualification, and certification has not been developed.
This matter is an open item (456/86038-10).
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During discussions with the Assistant Superintendent of Maintenance, the inspector was introduced to the three maintenance training coordinators who explained the various in-house instruction ano on-the-job training being developed and currently utilized.
It appeared to the inspector that each of the training coordinators was independently pursuing unspecified training goals.
It also appeared that coordination and communication between the coordinators and training center personnel was poor or nonexistent.
The inspector and Assistant Superintendent of Maintenance discussed the possibility of assigning overall training responsibility to a manager who can develop and implement a coordinated overall maintenance training program. This is an open item (456/86038-11).
No violations or deviations were identified; however, two open items were identified.
8.
Records Control (35748)
The licensee's developed records control system was reviewed to verify that a program was in conformance with regulatory requirements, industry guides and standards and application commitments. The inspector reviewed applicable program documents, related procedures and instructions, along with other documents that establish record handling and retention acceptance criteria. The inspector also reviewed selected documents and interviewed cognizant personnel.
a.
Documents Reviewed (1) Quality Assurance Manual, Quality Procedure QP No. 17-51
" Control of Station Records," and QP No. 17-51 Attachment A, Revision 1, " Retention Times for Safety Related Lifetime and Non-Permanent Records."
(2) BwAP Administrative Procedures.
(a) BwAP 1340-2, " Quality Records Turnover," Revision No. 2.
(b) BwAP 1340-3, " Document Retention," Revision No. 2.
(c) BwAP.1340-10, " Records Storage System Survey,"
Revision No. Q.
(3) The Master Index System (Computer System) and Master Records Retention Schedule
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b.
Results of Inspection (1) A sample of 10 records was selected from the master index by the inspector who verified that the proper revision of the records was suitably stored and readily retrievable.
(2) Three QA audits were reviewed to determine that auditing coverage of records control was scheduled and performed at least annually.
No violations or deviations were identified.
9.
Open Items Open items are matters that have been discussed with the licensee, which will be reviewed further by the inspector, and involves some action on the part of the NRC or licensee or both. Open items disclosed during this inspection are discussed in Paragraphs 2, 3, 4, 5, and 7.
10.
Unresolved Items An unresolved item is a matter about which more information is required in order to ascertain whether it is an acceptable item, a deviation, or a violation. An unresolved item disclosed during this inspection is discussed in Paragraph No. 2.
11.
Exit Meeting The Region III inspectors met with licensee representatives (denoted in Paragraph No. 1) at the conclusion of their inspection and summarized the purpose, scope and findings of the inspection. The inspector also discussed the likely informational content of this inspection report with regard to documents or processes reviewed by the inspector. The licensee did not identify any such documents or crocesses as proprietary.
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