IR 05000456/1986056

Safety Insp Rept 50-456/86-56 on 861007-09,14-16 & 21-23. No Violation or Deviation Noted.Major Areas Inspected: Previous Insp Findings,Preoperations Review of Plant Operations Program Procedure for Design Change & Mod

ML20213H039
Person / Time
Site:	Braidwood
Issue date:	11/13/1986
From:	Jablonski F, Vandel T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20213H035	List: IR 05000456/1986056 ML20213H034
References
50-456-86-56, NUDOCS 8611190045
Download: ML20213H039 (5)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-456/86056(DRS)

Docket No. 50-456 NRC Operating License No. NPF-59 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, Illinois Inspection Conducted: October 7-9, 14-16 and 21-23, 1986

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Approved By: F. J.,Jablonski, Chief //-/34 Qualify Assurance Programs Section Date Inspection Summary Inspection on October 7-9, 14-16 and 21-23, 1986 (Report No. 50-456/86056(DRS))

Areas. Inspected: Routine safety inspection of previous inspection findings (92701 and 92702), pre-operations review of the plant operations program procedures for design changes and modifications (35744), and procurement control (35746).

Results: No violations or deviations were identified during this inspectio i l

8611190045 861113 PDR ADOCK 05000456 g PDR

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DETAILS Persons Contacted

• Barnes, Regulatory Assurance Supervisor

• Boyle, Regulatory Assurance Staff

" Cecchett, Regulatory Assurance Staff

• Fitzpatrick, Station Manager

• J. Giuffre, MM Training Coordinator

• G. Groth, Assistant Construction Manager N. Hottel, Startup Technical Specialist

• J. Huffman, Master Mechanic M. Inserra, Startup Staff Supervisor

• K. Kofron, Production Superintendent

• J. Leiden, Site Project Engineering. Department T. Lewis, Startup Staff D. Paquette, Assistant Superintendent Maintenance

• L. Raney, Nuclear Safety D. Ruppert, Operations Technical Staff D. Ruehlmann, Operations Analysis Department

• C. Schroeder, Services Superintendent

• T. Simpkin, Regulatory Assurance

• C. Tomashek, Startup Superintendent T. Troutman, Mechanical Maintenance

• Wallace, Project Manager

• J. Zych, Site QA Supervisor U.S. Nuclear Regulatory Commission (NRC)

• A. Dunlop, Reactor Inspector

• D opp, Senior Resident Inspector (Construction)

• T. Taylor, Resident Inspector (0perations)

• T. Tongue, Senior Resident Inspector (0perations)

• Denotes those in attendance at the exit meeting October 23, 1986. Other licensee personnel were contacted during the course of the inspectio . Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (456/86038-03): Questionable calibration of weights used to calibrate the torque wrench tester. The apparent l requirement for calibration of the weights at the time of inspection 456/86038 was to meet National Bureau of Standard (NBS) Class C. A re-evaluation by the licensee's Operations Analysis Department (0AD)

determined that NBS acceptance Class F was acceptable. The weights were re-calibrated by the State of Illinois, Bureau of Laboratories to l Class F acceptance tolerance As a result, all calibrations of torque

! wrenches with the torque wrench tester are acceptable. This item is i close l l

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(Closed) Violation (456/85025-01(DRS)): Lack of review of Startup Deficiency Reports (SDRs) for identification, disposition, and control of nonconformance The resolution and handling of SDRs described in the licensee's response letter dated September 12, 1986, indicated controls generally prescribed by a nonconformance control system. The response letter stated that engineering reviews of the SDRs and dispositions for corrective action would meet the Commonwealth Edison Company (CECO) Quality Assurance Program Manual, Section QP No. 15-1. The letter additionally stated that "A nonconformance report was not required to obtain an engineering review of the problem." The CECO Quality Assurance Manual states in Q.P.15-1 that CECO initiated nonconformance reports (NCRs) are the responsibility of the Project Construction Superintendent while the Project Engineering Department is responsible for final review and approval of recommendations for corrective actions of nonconformanc The Braidwood Startup Manual provides the direction for testing activities while meeting the intent of the basic requirements of the QA manua In this case, an SDR is used as the vehicle to obtain Project Engineering review and disposition with a minimum loss of time. The inspector concluded that the intent of 10 CFR 50, Appendix B, Criterion XV has been met, that i::,, measures are in place to control nonconformances to prevent inadvertent use while providing identification, documentation, and dispositio The inspector reviewed the details of Site Quality Assurance Surveillance Report No. 5866, for 35 SDRs that possibly warranted an NCR. Of the 35 SDRs, the following details appear to support CECO's conclusion that the SDRs had been properly handle * five NCRs were issued replacing the SDR

• three FC0's (contractor field change orders) were issued to resolve the nonconformance

• three were otherwise dispositioned and resolved

• four were non-safety related and were not subject to the requirement Based on the above review, the inspector concluded that the QA requirement was being met for the Project Construction Superintendent to be responsible for issuance of NCR The inspector evaluated the licensee's proposed corrective action and the results achieved. The inspector reviewed documentation that supported the actions taken, and interviewed cognizant personnel. The results are as follow Project Construction Corrective Action: The inspector reviewed a project training attendance sheet for a training session entitled

" Implementation of QP 15-1 in relation to System Deficiencies" held on August 13, 1986, and another entitled " Implementation of QP 15-1, review of System Deficiencies for NCR conditions including design discrepancies" held on August 25, 1986. Both sessions were conducted

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by the Assistant Construction Manage During an interview with the Assistant Construction Manager the inspector learned that all Field Engineers attended both sessions and the second session was held to expand the training to include handling design discrepancies in addition to routine hardware nonconformances. It was also learned that the computer Training Record Matrix had been expanded to include a yearly retraining session for this subjec Project Startup Corrective Action: The inspector reviewed results of reviews by the Test Review Board of SDR Results of the inspectors findings are summarized belo * 14 safety-related system test packages had no SDRs identified as potential NCR * 29 safety-related system test packages contained one or more SDRs considered to be potential NCR * Approximately 100 SDRs were identified as potentially being NCRs; 27 remained ope The inspector was satisfied that the review for potential NCRs was well done; however, the SDRs needed to be evaluated and dispositioned for appropriate close out. During an interview with the Startup Superintendent, the inspector was informed that the review package had been sent to him for review and forwarding to the Project Engineer for review as require Based on the above review this matter is close . Pre-Operations Review of Operations Program Procedures The inspector reviewed the licensee's programs for design changes and modifications, and for procurement control to ascertain whether the QA program relating to design and procurement activities had been established in accordance with the CECO QA Program and 10 CFR 50, Appendix B requirements. The review was limited to the in place program procedures and instructions, and interviews with personnel involved in procedure development and eventual implementatio Documents Reviewed (1) Quality Assurance Manual Quality Requirements (QRs) and Quality Procedures (QPs)

(a) QR 2.0 " Quality Assurance Program" (b) QR 3.0 " Design Centrol" (c) QR 4.0 " Procurement Document Control" (d) QR 7.0 " Control of Purchased Material Equipment and Services"

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(e) QP 3-51 " Design Control for Operations Plant Modifications" (f) QP 3-52 " Design Control for Operations Plant Maintenance (g) QP 8-51 " Identification and Control of Materials, Parts and Components for Operations - Identification, Inventory Control Disbursal and Use" (2) Braidwood Administrative Procedures (a) BwAP 800-1 " Classification of Parts of Safety Related Components,"

Revision No. 4 (b) BwAP 800-2 " Control of Requests for Purchase," Revision No. 1 (c) BwAP 1600-2 " Plant Modification Procedure,"

Revision No. 2 (d) BwAP 1610-3 " Field Change Requests,"

Revision No. O Results of Review During discussions with Tech Staff personnel, the inspector became aware that the design change and modification program previously prepared is now being replaced by a company wide revised progra In response to questions, the inspector learned that a new series of Braidwood procedures is being developed in line with the new company wide progra The Braidwood procedures would include:

(1) BwAP 1610-1 " Plant Modification Procedure" (2) BwAP 1610-2 " Construction Phase" (3) BwAP 1610-3 " Field Change Requests" (4) BwAP 1610-4 " Set Point Changes" (5) BwAP 1610-5 " Modification Procurement Testing" The inspector also learned that the new program will provide for off-site design of safety-related modifications. At the time of this inspection, only one procedure (BwAP 1610-3) was available for review. The inspector concluded that further inspection should be delayed until the new program is available for revie No violations or deviations were identifie . Exit Meeting The inspector met with licensee representatives (denoted in Paragraph No. 1) at the conclusion of the inspection and summarized the purpose, scope and results 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 processes as proprietar l- _ .

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