IR 05000456/1986049

Insp Repts 50-456/86-49 & 50-457/86-36 on 860902-15.No Violations or Deviations Noted.Major Areas Inspected: Allegations & Followup on Previous Insp Items

ML20215F259
Person / Time
Site:	Braidwood
Issue date:	10/09/1986
From:	Muffett J, Neisler J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20215F233	List: IR 05000456/1986049 ML20215F228
References
50-456-86-49, 50-457-86-36, NUDOCS 8610160135
Download: ML20215F259 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION III

Reports No. 50-456/86049(DRS); 50-457/86036(DRS)

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Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 76 Chicago, IL 60690 Facility Nare: Braidwood Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, IL Inspection Conducted: September 2-15, 1986-Inspector: H.- Neisler Z /8 S dam wo d Approved By: J. Muffett, Chief 10 f 9 !8(0 Plant Systems Section Date Inspection Summary Inspection on September 2-15, 1986 (Reports No. 50-456/86049(DRS);

No. 50-457/86039(DRS))

Areas Inspected: Unannounced special inspection of allegation Followup on previous inspection items (99014, 92702, 92701, 92700).

Results: No violations or deviations were identifie DR 861009 ADOCK 05000456 PDR

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DETAILS 1. Persons Contacted Commonwealth Edison T. Quaka, Superintendent Quality Assurance

• P. Barnes, Regulatory Assurance Supervisor

• J. Groth, Assistant Construction Superintendent

• A. D' Antonio,' Regulatory Assurance

• D. Cecchett, Regulatory Assurance

• S. Hunsader, QA Supervisor

• R. Sacco, QA Inspector M. Dougherty, Consultant L. Shelton, QA Inspector-G. K. Newberg Electrical S. Milano, Quality Assurance Manager G. New, Quality Control Inspector R. Smith, Quality Control Inspector L. McCalip, Quality Control Inspector K. Dunn, Quality Control Manager D. Halley, Quality Control Inspector J. Merritt, Quality Control Supervisor R. Gallick, Quality Control Inspector J. Lloyd, QA Engineer R. Hill, QA Engineer L. K. Comstock Company C. Hart, Quality Control Supervisor Johnson Controls Incorporated (Bensenville Plant)

J. Basham, Project Manager General Electric Company T. Cartelli, Superintendent, MCIS

• Denotes those personnel attending the exit intervie . Allegations (Closed) Allegation RIII-86-A-132: An electrical quality control inspector expressed several concerns relative to G. K. Newberg Electrical's quality control activities and his employer's, MCIS, personnel practices at Braidwood Unit .

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. His employer, MSIC, a General Electric Company subsidiary, required him to sign a form, " Release of Information and Release and Hold Harmless Agreement," which he refused to sign. His refusal to sign resulted.in his termination. He believes the use of this form was

.: excessive and was a form of intimidatio NRC Review The NRC inspector reviewed the agreement that the individual was required to sign. The agreement is a. form letter authorizing organizations and individuals to release information necessary for an employer to conduct the screening of the employees background in order for the employee to have unescorted access within a nuclear power plant. The personnel background screening is required by the Braidwood approved security plan and ANSI 3.3. The requirement for QC inspectors, or other plant personnel, to sign release of information agreements is not a form of intimidation but is a necessary requirement to facilitate background screening for persons requiring unescorted access to nuclear power plant Conclusion This allegation was not substantiated since security screenings are required by the Security plan and ANSI 3.3 198 The individual stated that a meeting was held by construction concerning bypassed hold points. The meeting was held with both craft and QC inspectors present. The cra^ were told at this meeting that individuals' bypassing hold ;_ .ints would be fired. The individual believes that since the QC inspectors were at this meeting the QC inspectors would be afraid to write up a craft person bypassing a hold point since he would know the person would be fired.

NRC Review The NRC inspector interviewed five QC inspectors or 25% of those currently employed by GKNE who stated that they had attended the meeting. Each individual also stated that although they were aware

, that a craft worker or foreman who bypassed a hold point would lose his job, they would still write a deficiency against the craft worker who bypassed that hold point. None of the interviewees had first hand knowledge that anyone had been discharged for bypassing a hold point, but they had heard rumors that some craft persons had

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been discharge They also stated that the craft was more attentive I to hold points since the meeting. Interviews with the GKNE QA manager i revealed that the meeting had been conducted by both the QA manager i and the construction manager because of a recent increase in i nonconformances involving bypassed hold points. He further stated l

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that since the meeting that there had been a noticeable decrease in hold point violations. The inspector's review of the NRC log showed that although hold point violations had decreased, there were NCRs written in_the last two months that indicated the QC inspectors were continuing to write NCRs when hold points were bypasse Conclusion This allegation was not substantiated. Of the QC inspectors interviewed, they all stated that they had no first hand knowledge e that a worker would be fired for bypassing hold points, nor was there evidence that the inspectors were not writing nonconformances when hold points were bypasse The individual stated that, in some instances, the same QA individual

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has initiated, dispositioned and closed out IDR NRC Review The NRC inspector interviewed other QC inspectors, QA Engineers, and the GK Newberg Electrical (GKNE) QA manager, none was aware of a QA individual who had initiated, dispositioned and closed out IDR The inspector's review of 25 randomly selected IDRs revealed that no IDRs had been initiated, dispositioned and closed by the same QA individua The QC personnel stated that under their program in some instances during in process inspections, a QC inspector may initiate and close an IDR on a deficiency when the deficiency is corrected before the QC inspector leaves the are Although no improper handling of IDRs was identified, GKNE quality assurance personnel informed the NRC inspector that Surveillance Report No. 208 had been verified, reviewed and closed by the individual who had dispositioned Report No. 208. This item was identified in Audit Finding Report No. 3 to QA Audit No. E-86-0 The corrective action was to train personnel on the proper closure of surveillance reports. This training was completed on July 14, 1986,

! approximately two' weeks before the allegation was received by the NR Conclusion This allegation was not substantiated. No evidence was identified to substantiate that the same QA individual initiated, dispositioned, and closed out an ID The individual stated that QA was doing first line inspection He stated that the QA manager told him that not everything in a procedure needs to be inspected by QC, that QA can inspect on a surveillance basis and the craft can do inspections unless the procedure specifically says QC.

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NRC Review The NRC inspector reviewed 12 randomly selected traveler packages; none contained records of inspections performed by QA personne The inspector also interviewd five QC inspectors, all five stated that QA did not perform inspections. One QC inspector did recall

~an instance where QA had inspected some bolts in a junction box, but that QA did not prepare an inspaction checklists and that QC performed their required inspection when the job reached the QC inspection point. Each QC inspector and the Quality manager stated that the QC union would file a grievance should someone other than QC perform inspections. NRC regulations do not prohibit qualified QA personnel or others from performing inspections providing they are qualified to ANSI N45.2.6 or NQA-1 as appropriat Conclusion Based on interviews with Newberg quality personnel and the review of traveler packages, this allegation was not substantiated.

' The individual stated a number of inspectors believed that deficiencies identified on IDRs should be on NRCs, and that there was no current IDR log for traceabilit NRC Review The NRC inspector interviewed approximately one-fourth of the GKNE QC inspectors, all stated that they were free to write NRCs at anytime when they determined that an NCR was warranted under the GKNE quality progra The NRC inspector reviewed the IDR log. The log contained a numerical listing of IDRs written by the GKNE QC inspectors since late 1985 when GKNE began work at Braidwoo IDRs were included in traveler packages reviewed by the inspecto The specific example provided by the individual concerned a traveler for work that had been partially inspected by one QC inspecto This QC inspector returned the traveler to engineering for corrections while retaining his inspection checklist and an IDR that he had drafted. The traveler was misrouted from engineering to another QC inspector. This second inspector then returned the traveler to the original inspecto All the required inspections were then performed and the traveler was closed,~ subsequently reviewed and placed in the records vaul The individual made other statements relative to weld details, inspection and training. The NRC inspector reviewed the individual's inspections that he had performed during his time on site, NCRs and DDRs and training records. Also, all cognizant individuals in these areas were interviewed. Neither the document reviews nor the interviews provided information to substantiate the individual's statement _, - _ _ _ _ _ . . _ _ _ _ - _ __ _ _ _ _ ._- . .

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Conclusion All QC inspectors interviewed stated that they were not restricted in issuing NCRs. Also there was an IDR log for issuing and tracking the IDRs and the IDRs were. included in the traveler package This allegation was not substantiate f. The individual stated that , junction box 2JB479R on 396 elevation in Unit 2 containment wat ioct,ted in a bad spot. One day, he almost walked into it. He contacted the " Safety" personnel. A couple hours later he noticed the lid was off the box and on some scaffolding. The corners were turned up. He believes somebody had almost walked into-it and out of anger ripped off the lid. He told

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his lead. To date, no tag is on the bo NRC Review The NRC inspector reviewed the reinspection performed on the junction box. The junction box is located according to the design drawing Visual inspections of the junction box revealed no indications that it had been vandalized. No unacceptable bends or dents or other damage were identifie Conclusion This allegation was not substantiated. The junction box is acceptable as to location and physical conditio g. A QC inspector had been given a traveler to do an inspection, since the traveler contained no documentation on a core drill, he wrote an NC The NCR was voided by the QC manager because they found the inspector that originally inspected the core drill and the documentation was generated after the fac ,

NRC Review The NRC inspector interviewed the inspector who wrote the NCR and the core drill inspecto Both stated that documentation had not been completed when the conduit inspector wrote the NCR but that QC -

inspections had been performed and checklists completed and that the core drill inspector was wai. ting for construction to complete their cut rebar report. Each of the inspectors stated that the core drill inspection was not documented after the fact, but that the inspection was performed and documented in accordance with the required procedure The documentation problems were due to delays by construction in completing their installation documentations. The NRC inspector's review of the traveler package revealed that all required documentation is in the package and was acceptabl _-- _

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Conclusion Interviews with the individuals involved with the core drills and a review of the documentation package did not reveal any information to substantiate this allegatio The individual stated Technical Bulletins (TB) have been issued which may not have been validated by S&L. These tbs have criteria which should be reviewed by S&L prior to implementing the tb NRC Review Discussions with the NRC Senior Resident Inspector (SRI) for construction at Braidwood revealed that the use of Technical Bulletins has been discontinued. All tbs have been reviewed and incorporated into procedures where appropriate. Four old Technical Bulletins reviewed by the NRC inspector were clarifications of existing procedures and did not add or delete acceptance criteria

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from the procedure. Since the tbs did not change approved procedures, there was no deleterious effect on plant safet Conclusion The SRI had previously inspected this item; the tbs have been incorporated into approved procedures, this allegation was not substantiate Weld preheat and interpass temperature 3 are required to be maintained according to Procedure 11.2. The individual states that there was no objective evidence that the procedure was being followed throughout the weld process. he states that the welders were given temp sticks at his request but he was concerned about the welds made prior to the welders receiving temp sticks and the documenting of QA surveillances for monitoring temperature NRC Review The inspector interviewed the QA manager, the QC manager, and selecting welding inspectors. They all stated that the welders have used temperature indicating crayons (temp sticks) on welds that required preheating since GKNE had started work on site. The QC manager stated that the alleger has suggested a QC inspector be present throughout the preheat / welding process. The procedure requires welders to maintain pre-heat and interpass temperatures within procedural limits as required by AWS D.1.1. AWS D. requires no the preheat on materials used by the electrical contractor in thickness below 3/4 inches and 50 F for material less than 1 1/2 inches thick. Materials used by the electrical contractor usually normally require no preheat and seldom more than 50 Ambient temperatures are above 50 ,-. .-- . - _ - - _ . _ _

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Conclusion

.This allegation was not substantiated. Interviews and documentation indicate that procedures were being followed in this area. There was no impact on the welding process by following these preheat and interpass' requirements since the procedures and their implementation meet the. governing cod The individual states that QC is understaffe NRC Review The NRC inspector interviewed 25 percent of the QC inspectors who all stated that they did not believe that QC was understaffed. They stated that inspection activity was cyclic in that the inspection requirements were dependent upon construction progress for their in process inspections. The GKNE craft to inspector ratio is approximately 7.3: Conclusion This allegation was not substantiated. The GKNE QC department was not understaffed, but in fact was better than the averag . Construction Deficiency Reports (10 CFR 50.55(e))

(Closed) 10 CFR 50.55(e) item (456/83013-EE, 457/83013-EE): Deficient overload blocks on Westinghouse A200 series Motor Control Centers. The licensee issued NCR 538 to track the deficiency. Westinghouse supplied new overload blocks. The new blocks were installed and NCR 538 was subsequently closed. No further action is required on this ite (Closed) 10 CFR 50.55(e) item (456/84001-EE, 457/84001-EE): Inadequacies in LK comstock documentations. The inspector reviewed LKC audits I-115-085 and I-131-086, CECO audit QA-20-85-522, NCR 6076 and Surveillance Reports No. 5980, 4688, 4735, Revision 1. These documents provide evidence that the documentation received two 100% reviews and that deficiencies were correcte No further action is require (Closed) 10 CFR 50.55(e) item (456/83009-EE): Westinghouse 7300 process protection system deficiency. Contact bounce experienced in mercury relay during seismic testing of temperature channel test (NTC) car The inspector reviewed completed engineering change notice (ECN) CCEM 10692A for the installation of seismically qualified NTC relay retrofit cards, Part No. 7380A7760 The replacement card was installed and the ECN closed for Unit (Closed) 10 CFR 50.55(e) item (456/84013-EE): Inadequate installation and inspection of electrical butt splice Butt splices were not installed according to manufacturers recommendations. The contractor's inspection procedure did not include appropriate acceptance criteri _ _ _ _ - _ _ . - _ . . _ . - _ _ ,

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L Installation procedures have been revised to include. manufacturers-

! recommendations. -Inspection procedures have been revised to include

, acceptance criteria as recommended by the manufacturer. NCR 598 was

issued to require safety related butt splices to be identified and  ;

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! ' Butt. splices that were rejected during-the reinspection have been replaced

[ and inspected to manufacturer's acceptance criteria and NCR 598 has been  ;

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_ subsequently closed. -This item,is considered to be closed.

I (Closed).10 CFR 50.55(e) item (456/86003-EE, 457/86003-EE): Defective spot welds on Unistrut P-1004A material used in cable pan supports fabricated by Systems Controls Corporation. The manufacturer's investi-gation revealed that the material consisted of.580 feet of P-1004A strut material that had been fabricated during a test run on a new automatic

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welding machine. The material was rejected and tagged for rework but was inadvertently shipped with an order to Systems Control. A walk-down of ,

P-1004 hanger.-identified 61 hangers in Unit 2 and none in: Unit 1 with

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rejectable spot welds. Of the 61 hangers, 54 were replaced, 6 repaired and one dispositioned "use-as-is." The inspector also reviewed independent metallurgy-laboratory test results on the spot welds and the inspection

. reports. All defective material in safety related applications has been satisfactorily accounted for in both Braidwood Units 1 and .

(Closed) 10 CFR 50.55(e) item (456/83014-EE, 457/83014-EE): Cracked l battery cell jars. The licensee's and manufacturer's investigation

determined.that the cracking was caused by the use of improper cleaning

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battery maintenance procedure was revised to prohibit the use of all

solvents in the battery rooms. The cracked cell jars have been replaced

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and new intercell spacers installed per manufacturer's recommendations.

i This item is closed.

. Open Items From Previous Inspections j

il .(Closed) Violation (456/82006-04): Cables in free air are routed closer ,

than the.12-inch limit allowed by procedure. The inspector reviewed the .i i S&L analysis of the free air separation violation. The non safety-related '

, cable is rated at 600 volts. The operating voltage is 24 volts supplied by

a signal converter with a maximum output of 20 ma at 26 volts. The

! circuit is protected by a one ampere rated fuse. The cable size is 14 L AWG and is capable of safely carrying a 20 ampere load. The cable does

not come in contact with a redundant division at any part of its length.

i Both cables are qualified to IEEE 323-1974. The inspector agrees with  :

j the S&L position that less than 12-inch separation is adequate for these

particular cables.

I (Closed) Unresolved (456/85007-07): Whether GE "Vulkene" switchboard wire is qualified to IEEE 388-1974 for use is motor control centers (MCC) and *

HVAC control panels located in harsh environments. The inspector, by

! review of documentation generated during that inspection and associated j-corrective action determined that the Vulkene wire in equipment located

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in harsh environments has been replaced with IEEE 383-1974 tested Rockbestos SIS switchboard wire. Additionally, the acceptability of the switchboard wire was discussed with NRR on February 19, 1986, and was deemed to be acceptabl (Closed) Violation (456/85048-04, 457/85047-04): Failure to verify installation of correct " SIS" wire in valve limit switch compartments as required by NCR 277. The inspector reviewed documentation showing the valves to have been reinspected. All other valves inspected by the QC inspector who accepted the SIS wire were reinspected. The incorrect SIS wires were replaced with Rockbestos SIS wires. This item is close (Closed) Violation (456/83018-05A): Safety-related conduit used as a temporary pipe support. Protection of installed equipment. The inspector ascertained that the pipe is no longer supported by the safet related conduit. The licensee has established an inspection program by its inspection contractor to perform routine housekeeping and equipment inspections. The licensee issued instruction No. BR/PCD 85-586 to its contractors delineating equipment protection standards for Braidwood contractors. This item is close (Closed) SER item (456/86000-18): Test jacks for P-4 interlocks. The inspector verified that the licensee has installed permanent voltmeters for P-4 interlock testing. This item was previously closed in SSER- (Closed) SER item (456/86000-21): Add fourth protection channel for steam generator protection and modify logic so that protective action is initiated on a 2/4 logic. The inspector verified by review of revised drawingsandlogicdiagramsthattheworkhadbeenaccomplishedaccording to the licensee s commitment. This item is close (Closed) SER item (456/86000-25) PORV actuation: The inspector verified by review of documentation and revised drawings that the cross connection between PORVs that used the signal from an auctioneer to provide a permissive signal to the logic train of the other valve has been removed as recommended by Westinghous Manual arming of the channels is now employed to meet the single failure criterio This item is close (Closed) SER item (456/86000-26): Class 1E indication of loss of

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component cooling water flow to the reactor coolant pumps. The inspector verified that the Class 1E component cooling water flow to the reactor coolant pump oil coolers indication has been installed. This item is close (Closed) SER item (456/86000-27): Non-Class 1E loads powered from Class 1E buses. The inspector verified that the licensee had adhered to his commitment to provide two circuit breakers in series to protect the Class 1E buses from possible faults on the Non-1E circuits. The verification was accomplished by review of revised drawings showing that the breakers were in place. This item is close . _ . - _ __ . . . - - _

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(Closed) Unresolved item (456/83018-02, 457/83-17-02): Adequacy of battery rack inspection checklists. The inspector reviewed the revised inspection checklists and inspection results. The inspections are considered to be adequat (Closed) Open item.(456/85036-01, 457/85035-01): Cables with same

. functions at Byron and Braidwood are classified differently as to power or control designation, at Braidwood, contrary to FSAR designation. The cables in question do not perform the same function at Braidwood as at Byron. At Byron the cables provide control power to switch gear at the essential service water cooling tower. Braidwood does not have an essential service water cooling tower. These cables provide control power to 125 VOC loads. The FSAR states that #6 AWG cables and larger are

. typically classified as power cables. These cables are #2 AW Cable 1DC095 feeds the ESF division 11 DC fuse pane The FSAR states that generally all-600 volt insulation class cables feeding 120 VAC or 125 VDC distribution circuits sized with #10 to #14 AWG conductors are considered to be control cable Cable 10C141 serves ad DC control power feed for 6.9 KV bus 15 This is consistent with the FSAR in that the cable provides electrical energy fo'r control power and is larger than #6 AWG. The cable is classified according to the FSA (Closed). Violation (456/85048-05, 457/85047-05): Failure to adequately implement requirements to inspect, identify and document safety-related butt splices during its corrective action program established to identify these splices. The NRC inspector reviewed the corrective action which included the reinspection of 90 pieces of equipment-that had been inspected.by the QC inspector whose job it was to identify the butt splices. The reinspection identified 15 additional conductor splices in the 90 pieces of equipment that had not been previously identified. The QC inspector's certification as a terminations inspector were revoke The corrective action required to close this violation is adequat (Closed) Open item (456/85056-07): Certain construction testing activities were performed with general usage T&ME. Determine acceptability of data taken with non-certified equipment. The testing in question was the use of clamp-on ammeters to check the running current on electric motors. The inspectors verified that certified ammeters were used in 4.16KV and 6.9KV motors and that all insulation resistance testers are certified. The running current on 480 volt and smaller  !

motors were measured with clamp-on ammeters. The meters were used to check phase loadings, indications of bearing failure, or shaft binding in the motors or driven machine The data was not used to determine relay or  ;

overload settings or in calculation of motor efficiencie The use of these measuring devices was acceptable in this applicatio ,

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(Closed) IDI Team item (456/85060-02, 457/85056-02): For situations where actual cable lengths (pulled lengths) are different than those used for voltage drop calculations, the NRC team found that S&L had generated an Electrical Department Instruction ESI-253, dated August 6, 1985, for reviewing the final calculations using the as-built cable lengths as noted on the cable pull cards of the contractor. The team finds the newly generated instruction provides a reasonable solution. This item will be considered open pending the completion of implementation prior to fuel load. The inspector reviewed S&L documentation on site and determined that this instruction has been implemented. The review of cable pull cards identified eleven cases where voltage drop calculations based on actual cable lengths as installed in the field. The implementation of this instruction has been effective and this item is close (Closed) Unresolved item (456/85021-02, 457/85022-02): Acceptability of QC inspector's welding certification. The NRC inspector reviewed the QC inspector's training and qualification record He had an associate degree in applied science, three years as an electro-mechanical inspector, and had received 126 hours0.00146 days <br />0.035 hours <br />2.083333e-4 weeks <br />4.7943e-5 months <br /> on-the-job training in visual weld inspectio His examination scores were, 100% for the practical and 100% on the written examinations for a Level I LK Comstock Procedure No. 4.1.3, Section 3.2, states " personnel not meeting the minimum education and experience requirements, the minimum 0JT must be exceeded top the extent acceptable to the Level III and withholding signatures on Form No. 56 until CECO QA's written formal acceptance is received." The licensee's Quality Assurance auditors issued a finding against this criteria when the contractor certified the QC inspector as a Level II weld inspector prior to receipt of Ceco QA's formal written acceptance of the QC inspector's qualification. The NRC inspector finds the QC inspector's welding certifcation acceptable based on his receiving 86 hours9.953704e-4 days <br />0.0239 hours <br />1.421958e-4 weeks <br />3.2723e-5 months <br /> of additional training, perfect scores on examinations and three years previous inspection experience as an electro-mechanical inspecto (Closed) IDI Team Open item (456/85060-03, 457/85056-03): The original calculation used the assumed value of motor efficiency as 95% instead of the actual value of 94% shown on vendor supplied data. The calculation, No. 19AQ-18, is used to determine the approximate heat load from equipment and components within a room or area for the sizing of HVAC in that room or area. This includes heat from motors, pump, pipes, cables and structures. Review and discussions with S&L reveals that their practice is to assume 95% efficiency for large motors and 85% for small motors. The HVAC design at Braidwood was stated to be oversized at least 25% to provide needed conservation in each are . Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1) -

at the conclusion of the inspection and summarized the scope and results of the inspection . The licensee acknowledged the inspector's comrrent The inspector also discussed the likely informational content of the inspection report wit regard to documents or processes reviewed by the inspector during the inspections. The licensee did not identify any such documents / processes as proprietar . - - . _ .-. - -- - - - . - - _ - - - _ . -.