IR 05000456/1986063

Insp Repts 50-456/86-63 & 50-457/86-44 on 861024-1218. Violation Noted:Inadequate Surveillances & Procurement Process

ML20212E286
Person / Time
Site:	Braidwood
Issue date:	12/29/1986
From:	Little W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20212E162	List: IR 05000456/1986063 ML20212E158 ML20212E191
References
50-456-86-63, 50-457-86-44, NUDOCS 8701050289
Download: ML20212E286 (24)

Text

{{#Wiki_filter:, . U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-456/86063(DRP); 50-457/86044(DRP) Docket Nos. 50-456; 50-457 Licenses No. NPF-59; CPPR-133 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 24 through December 18, 1986 Inspectors: T. M. Tongue l W. J. Kropp i T. E. Taylor M. J. Farber Approved By:

 ?.R.P& Ar W. S. Little, Director  l 2.l Zi . gL 3raidwoodProject   Date Inspection Summary Inspection on October 24 through December 18, 1986 (Reports No. 50-456/86063(DRP);

No. 50-457/86044(DRP)) Areas Inspected: Routine, unannoinced safety inspection of activities with regard to licensee action on previously identified items; allegations; licensee event reports review; Conmissioner Carr visit; plant tours as,d independent assessment; initial fu9l loading; surveillances; reactor coolant system hydrostatic test - Unit 2; p ocurement; pipe supports; and meetings, training, and other activitie Results: Of the eleven areas inspected, no violations were found in nine areas, two violations were identified in two areas (inadequate surveillances - Paragraph 8; procurement process - Paragraph 10).

0701050289 861229 6 DR ADOCK 0500

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L DETAILS 1. Persons Contacted Commenwealth Edison Company (Ceco) Corporate Personnel B. Thomas, Executive Vice President C. Reed, Vice President, Nuclear Operations T. J. Maiman, Vice President, Projects D. Galie, Assistant Vice President and General Manager K. Graesser, Division Vice President D. J. Scott, Operations Manager, NSD D. Farrar, Director, Nuclear Licensing W. Shewski, Quality Assurance Manager B. M. Saunders, Nuclear Security Administrator Braidwood Personnel

 *M. J. Wallace, Project Manager
 *E. E. Fitzpatrick, Station Manager
 *C. W. Schroeder, Station Services Superintendent
 *K. L. Kofron, Production Superintendent
 *D. L. Shamblin, Project Construction Superintendent
 *C. J. Tomashek, Project Startup Superintendent
 *G. E. Groth, Assistant Superintendent, Construction
 *D. E.0'Brien, Assistant Superintendent, Operations
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*L. E. Davis, Assistant Superintendent, Technical Services

 *D. E. Paquette, Assistant Superintendent, Maintenance P. Cretens, Assistant Superintendent, Station Startup
 *G. F. Marcus, Assistant to Manager Quality Assurance
 *T. E. Quaka, Site Quality Assurance Superintendent
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 *R. D. Kyrouac, Station Quality Assurance Supervisor
 *P. L. Barnes, Regulatory Assurance Supervisor

, R. M. Preston, Quality First Director ' T. F. Ha11aren, Administrative Services Director

 *M. Takaki, Quality Control Supervisor
 *L. W. Raney, Supervisor Nuclear Safety Group
 *R. Legner, Senior Operating Engineer R. J. Ungeran, Operating Engineer
 *G. Masters, Operating Engineer R. Yungk, Operations Engineer  i F. D. Willaford, Security Administrator  l T. C. Meyer, Station Fire Marshall
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 *H. D. Pontius, Regulatory Assurance
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 *J. F. Phelan, Project Field Engineer Saraent & Lundy (S&L) ,
 *M. Bielman, Engineering Analyst

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Westinghouse W. Poirier, Project Manager The inspectors also talked with and interviewed other licensee employees, including members of the technical and engineering staffs, startup engineers, reactor and auxiliary operators, shift engineers and foremen, electrical, mechanical and instrument personnel, contract security personnel, and construction personne * Denotes those attending one or more exit interviews conducted on October 30, November 6 and 20, and December 1, 1986, and informally at various times throughout the inspection perio . Licensee Action on Previously Identified Items Unresolved Item (Closed) 456/84008-03; 457/84008-03: There did not appear to be a quality documentation system established, assuring that all the structural steel welds, which Napolean completed, had all the required examinations performed. The inspector reviewed Napolean QA records which identified by welds, the examinations performed to verify the acceptability of the welds. The welds were inspected either visually or if they were full penetration welds, by magnetic particle examinatio These inspections and/or examinations were required by the specification governing Napolean's work activities. No problems were noted with this documentation system. This item is close CFR 21 Report (Closed) 456/86001-PP: Valcor Engineering Report on Solenoid Valve Spring Failure. This report was reviewed for applicability to Braidwood by the resident inspector as directed by a regional request dated October 28, 1986. It was found that the licensee had not received the report at the station, but was following the issue through their response to IE Information Notice 86-72. The inspector provided a copy of the 10 CFR 21 notification to the station personnel and also found that the Station Nuclear Engineering Department (SNED) had received and evaluated the report for Byron and Braidwood. The analysis showed that several Valcor valves were supplied to CECO and were installed in the reactor vessel head vent lines; however, the installed valves were not the same as those identified in the 10 CFR 21 report. The licensee also has surveillance tests in place to test the valves for operation and timing, and there is also temperature detection instrumentation in the vent lines to detect seat Icakage. The IEIN 86-72 issue is being incorporated into the Itcensco's procedure for alarm response if high temperature is detected in the reactor vessel head vent line. This item is considered close ' , 3. Allegation (Closed) AMS-RIII-85-A-0145: In August of 1985, the NRC received allegations from a former contractor employee concerning the following areas:

* harassment, threats, and intimidation;
* operating procedures cannot be correct since the Piping and Instrumentation Drawings (P&ID) are wrong;
* documents to be sent to the NRC were changed from " Byron" to
"Braidwood" in an attempt to deceive inspectors;
* the employee was not offered the opportunity to see Quality First before leaving the site;
* the reactor coolant system hydrostatic test conducted in June 1983 was falsified
* 5000 undesignated valves were in a warehouse to be used at will;
* diesel generator valves were dismantled without proper documentation; and
* Commonwealth Edison stopped the P&ID verification program because the work group was identifying too many deficiencie The NRC Staff met with the alleger on August 29, 1985, and with two members of the alleger's work group during the mon +hs of September and October, 1985, to clarify the allegations. To determine whether or not these allegations could be substantiated, the inspector conducted a detailed inspection consisting of the following: The inspector reviewed operating procedures, reviewed the station's procedure validation program, and walked down some safety-related systems which were identified by the alleger as being affected by the erroneous drawings, TheinspectorresearchedsubmittalsforBraidwhSfromCommonwealth Edison to the NRC to identify what the alleged 4Rered documents might b The inspector reviewed Quality First files to determine whether or not an effort had been made to contact the alleger, The inspector selected a sample of those valves which were specifically alleged to be among the 5000 undesignated valves and examined them for identification and traceabilit The inspector conducted frequent random surveillances of work in the diesel generator room, interviewed the diosol generator startup test engineer and his assigned technicians, and examined records of diesel generator maintenance and testin , -
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! The inspector interviewed members of the operations staff to determine l if the alleger was involved in a licensee program to verify the ! ' accuracy of P& ids and if there presently were programs in place to verify the accuracy of P& ids and generate corrections where errors are identified.

i The results are as follows: Concern (1) The contract supervisor harassed, threatened, and intimidated the i alleger's work group by routinely threatening them with firing, using abusive, obscene language, and altering the work schedule in a deliberate attempt to disrupt the work group.

l l NRC Review During the interviews with the alleger and two other members of the work group these individuals clearly stated that they were never told by any Commonwealth Edison employee that they were not to identify (Nblems if they found them during the courso of their assig iment.

! Conclusion The allegation of harassment and intimidation to prevent identification of safety concerns cennot be substantiated.

j No further action i* *equire Concern (2) l l Braidwood Piping and Instrumentation Diagrams (P&lD) are inaccurat This results in inaccurate operating and surveillance procedures since the P& ids are being used as references in writing these procedures. The inaccuracy of the P& ids has resulted in plant operators using hand-drawn single-line diagrams for plant evolution NRC Review The alleger stated that when comparing the P& ids te the plant, the alleger's work group found discharges of pumps drawn incorrectly, flows bypassing flow meters, missing vents and drains, flows drawn incorrectly, valves shown on the drawings that were not in the system, and valves in the system that were not on the drawing During the interview the alleger provided the staff with a stack of computer print-outs which contained the numbers of P& ids which contained discrepancies. Review of these print-outs showed that the majority of the systems addressed were nonsafety-relate There were some safety-related system drawings listed; these l systems are listed below: l l I

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. AF - Auxiliary Feedwater CC - Component Cooling Water CV - Chemical and Volume Control RC - Reactor Coolant RH - Residual Heat Removal RY - Pressurizer SI - Safety Injection The inspector walked-down the following drawings: M-37, Revision AH, Auxiliary Feedwater M-50, Sheet 1, Diesel Fuel Oil M-60, Sheet 2, Revision AG, Reactor Coolant Loop 2 M-61, Sheet IA, Revision AK, Safety Injection M-61, Sheet IB, Revision AK, Safety Injection M-61, Sheet 2, Revision AA, Safety Injection M-61, Sheet 3, Revision AB, Safety Injection M-61, Sheet 4, Revision AC, Safety Injection M-61, Sheet 5, Revision P, Safety Injection M-61, Sheet 6, Revision AD, Safety Injection M-62, Revision AN, Residual Heat Removal , M-64, Sheet 3A, Revision AR, Chemical and Volume Control and Boron Thermal Regeneration M-64, Sheet 6, Revision AE, Chemical and Volume Control and Baron Thermal Regeneration M-66, Sheet 3, Revision AE, Component Cooling The Diesel fuel Oil drawing was not listed on the computer print-outs. It was selected for walkdown by the inspector because of the allegations regirding undocumented maintenance. Some deficiencies were noted during these walkdowns; the majority were minor and were turned over to the operations staff for resolution. More significant deficiencies were noted with the Safety Injection P& ids and these were identified in NRC Inspection Reports No. 456/85053; No. 457/85051. To determine if poor P& ids resulted in poor quality operating procedures the inspector reviewed the procedure validation program as stated in BwAP-360-101, Revision 0, " Operating Department Procedure Validation." The inspector also reviewed the following procedure validations completed during Integrated Hot Functionals: Bw0P AF-1, Revision 0, " Fill and Vent of Auxiliary Feedwater System Bw0P AF-2, Revision 0, " Alignment for Standby Operation of Auxiliary Feedwater System" Bw0P AF-5, Revision 0, " Placing the Diesel Driven Auxiliary Feedwater Pump Battery Chargers in Operation" Bw0P AF-6, Revision 0, " Removing the Diesel Driven Auxiliary Feedwater Pump Battery Charger from Operation"

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l l Bw0P AF-E1, Revision 0, " Unit 1 Prestart Electrical Lineup" , Bw0P AF-M1, Revision 0, " Unit 1 Prestart Mechanical Lineup" l l Bw0P CC-1, Revision 0, " Component Cooling System Filling and Venting" Bw0P CC-2, Revision 0, " Component Cooling System Startup and Operation" j Bw0P CC-5, Revision 0, " Alignment of Common Heat Exchanger l to a Unit" l l Bw0P CC-11, Revision 0, " Chemical Addition to the Component Cooling System" Bw0P CC-El, Revision 0, " Unit 1 Electrical Prestart Lineup" Bw0P CC-E3, Revision 0, " Common Unit Electrical Prestart Lineup" Bw0P CC-M1, Revision 0, " Unit 1 Mechanical Prestart Lineup" Bw0P CC-M3, Revision 0, " Common Unit Mechanical Prestart Lineup" Bw0P CV-1, Revision 0, " Fill and Vent of the CV System" Bw0P CV-2, Revision 0, " Initiating RCP Seal Injection and Charging Pump Operation" Bw0P CV-3, Revision 0, " Shutdown of the CV System" Bw0P CV-5, Revision 0, " Auto Makeup" Bw0P CV-6, Revision 0, " Dilution" l Bw0P CV-7, Revision 0, "Boration" Bw0P CV-8, Revision 0, " Alternate Dilution" Bw0P CV-9, Revision 0, " Manual Makeup" l Bw0P CV-10, Revision 0, " Chemical Addition to the Reactor l Coolant System" t Bw0P CV-13. Revision 0, " Degassing the Reactor Coolant System" Bw0P CV-14, Revision 0, " Swapping Charging Pumps" Bw0P CV-16, Revision 0, " Securing Auxiliary Spray Flow" Bw0P CV-17, Revision 0, "Estabitshing Letdown Flow from the RH System"

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Bw0P CV-18, Revision 0, " Securing Letdown Flow from the RH System" Bw0P CV-19, Revision 0, " Establishing Excess Letdown" Bw0P CV-20, Revision 0, " Securing Excess Letdown" Bw0P CV-23, Revision 0, " Establishing Normal Charging Flow" Bw0P CV-25, Revision 0, " Placing Mixed Bed Demineralizer in Service" Bw0P CV-27, Revision 0, " Removing Mixed Bed Demineralizer from Service" Bw0P CV-28, Revision 0, " Placing Cation Bed Demineralizer in Service" Bw0P CV-29, Revision 0, " Removing Cation Bed Demineralizer from Service" Bw0P CV-32, Revision 0, " Swapping Seal Injection Filters" Bw0P CV-El, Revision 0, " Unit 1 Electrical Prestart Lineup" ,, Bw0P CV-M1, Revision 0, " Unit 1 Mechanical Prestart Lineup" Bw0P RC-1, Revision 0, " Filling and Venting the Reactor Coolant System" Bw0P RC-2, Revision 0, "Startup of a Reactor Coolant Pump" Bw0P RC-3, Revision 0, " Shutdown of a Reactor Coolant Pump" Bw0P RC-4, Revision 0, " Draining the Reactor Coolant System" Bw0P RC-5, Revision 0, " Placing RVLIS/HJTC/CETC in Service" Bw0P RC-6, Revision 0, " Removing RVLIS/HJTC/CETC from Service" Bw0P RC-El, Revision 0, " Unit 1 Electrical Operating Lineup" Bw0P RC-M1, Revision 0, " Unit 1 Mechanical Prestart Lineup" Bw0P Idi-1, Revision 0, " Filling and Venting the Residual Heat Removal System" Bw0P RH-2, Revision 0, " Alignment of the Residual Heat Removal System for Cold Leg Injection" Bw0P RH-6, Revision 1, " Operation of the Residual Heat Removal System for Plant Cooldown

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The allegation that poor P& ids have resulted in poor quality operating procedures cannot be substantiated. During the Integrated Hot Functional (IHF) Test program the licensee conducted their procedure validation program as discussed abov The inspector reviewed the completed procedure validation forms for all sixty-seven procedures, usel during IHF, associated with safety-related systems alleged to have inaccurate P& ids. No occurrences were identified where an error or problem with a P&ID resulted in a problem with an operating procedur Concern Altered documents were submitted to NR All operating and surveillance procedures that were to be submitted to the NRC were actually Byron Station procedures with Byron removed and Braidwood substituted. The contract supervisor is alleged to have called the process "Byronizing" and said that the NRC would not know the difference and anyway by the time they (NRC) got them they (Ceco-Braidwood) would have their ow NRC Review To determine if altered documents had been improperly submitted to NRC, the inspector contacted the Office of Inspection and Enforcement, Nuclear Reactor Regulation, and other sections within Region III to identify any procedures which might have been submitted during the time frame in which the alleged alteration of the procedures took place. The inspector determined that annunciator response procedures had been submitted to the Operator Licensing Section in Region III in preparation for operator examinations. The operating license examiners were aware that these were Byron Station procedures adopted by Braidwood since they were for identical annunciator The examiners were aware of the name change and the reason that it was done, i.e., to take advantage of the fact that the procedures for both plants are identical in order to perform the operator licensing examinations in a more efficient manne No attempt was made to mislead the NRC and the procedures were submitted and received as duplicates of the Byron procedure Conclusion The allegation of false submission of documents is not substantiate Concern (4) The alleger and other terminated members of the alleger's work group , were not given the opportunity to visit Quality First before their departure from the sit NRC Review The inspector interviewed members of the operations staff who were involved with the alleger's work group. None could remember whether

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o or not the individuals who were terminated were offered the opportunity to visit Quality First before their departure from the site. Inspection of Quality First files showed that a letter, requesting that a Concern Disclosure Statement be completed and returred, was sent to the allegers place of residence within one week of their departure from the site. The file showed that no response was received. During the interview the alleger confirmed that the request for the Concern Disclosure Statement was received but that they did not answer the request. The reason for not answering the request was that the alleger did not feel that anything would be done about the situation and that Quality First had no credibilit < Conclusion That a Concern Disclosure Statement was not completed before tt alleger's departure is an indication that the alleger did not exit with Quality First prior to leaving the site. There is no evidence available to show whether or not Quality First offered an exit interview to the alleger at the time of termination; therefore, this allegation can neither be substantiated nor specifically disproved. An attempt was made by Quality First to contact the alleger and members of the work group subsequent to their termination; however, the requests were admittedly ignore Concern (5) Documents related to the primary hydrostatic test were falsifie During P&ID walkdowns of the reactor coolant system in June and July of 1985, the alleger's work group noted that piping and components necessary to conduct a cold hydro were not installe NRC Review During an interview with an individual of the alleger's work group, the inspector learned that the individual was aware of " cut-outs" from the primary system and was concerned that the previously conducted hydrostatic test had been invalidated. The alleger did not correctly understand this individual's concern. When the inspector informed the individual that Commonwealth Edison was l aware of the situation and that another primary hydrostatic test i was scheduled he stated that he had no further concerns in that are Conclusion , The individual's concern was alleviated when he was informed by the l inspector that another hydrostatic test was scheduled. The primary l ' hydrostatic test was satisfactorily completed in December 198 This allegation is resolve . _ . . _ _ . _ _ _ . _ . '

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Concern (6) Five thousand undesignated valves were purchased and stored in a warehous These valves are indiscriminately used in systems, primarily as vents and drains. Valves which come from this lot have a "zz" in their number on the computer print out and on the P&ID. These valves have no identification on the NRC Review During the interview the alleger was unable to provide specific information as to how the valves were purchased, when the valves were purchased, whether they were purchased as safety related or nonsafety, or where the valves were stored. The inspector reviewed all the computer print-outs for the seven safety systems and the drawings which were to be walked down and verified that only vents and drains were numbered with a "zz". During the walkdowns the inspector looked specifically at vents and drains with "zz" numbers and verified that all these valves had ASME nameplates and other forms of identification. Through interviews with the operations staff and the construction superintendent the inspector determined that vents and drains were often " field run" and were not numbered on the P& ids by the architect engineer until after the installation and documentation were completed. The "z;" numbers were temporarily assigned by the operations department until permanent numbers were assigned. The inspector selected a small sample of the valves identified by the alleger as part of the 5000 undesignated valves stored in the warehouse. The resident inspector verified that three (3) high point vent valves and one drain valve were properly identified with an ASME nameplate. The valves verified were: Valve Description Drawing N ZZ288W Volume Control Tank (VCT) M-64 Sheet 4 Inlet High Point Vent 1ZZ288J VCT Outlet Header to Charging M-64 Sheet 4 Pump Suction High Point Vent 15I085 Safety Injection Pump Discharge M-61 Sheet 3 to Hot Leg High Point Vent 15I086 Safety Injection Pump Discharge M-61 Sheet 3 to Hot Leg Low Point Drain All valves were required to be fabricated to ASME, Section III, Subsection NC (Class 2). The nameplates attached to these valves did identify them as Class 2 valves. The valves were manufactured by Borg-Warner to the requirements of S&L specification L-2794-1,

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Conclusions The "zz" valves were vents and drains as claimed by the alleger and were identified as such on the P& ids used by the inspector and on i the tags attached to the valves themse'ves. All of the vents and drains inspected during the system walk 6 ns had ASME nameplates and , other forms of identification. Tracing of the nameplate data from l four of the vents and drains revealed that the valves were properly L purchased under the correct specification for their intended use.

. This allegation is unsubstantiate Concern (7) _ _ _ Diesel generator fuel oil valves were being dismantled without documentatio NRC Review The inspector conducted frequent, random surveillances of the diesel generator rooms to determine if undocumented maintenance was being conducted. In all cases, when maintenance was in progress on any of the diesel generator components, a proper work package was available for review. The inspector interviewed the diesel generator startup test engineer, technicians, and operators in an attempt to determine what maintenance was being performed on the diesel generator These interviews revealed that from February through July of 1985, the licensee was troubleshooting a problem with loss of priming of the diesel fuel oil system. The problem arose during preoperational testing in February and appeared to be a faulty check valve and lack of a loop seal to prevent draining the fuel racks back to the day tank. During the troubleshooting, the check valve and other portions of the system were dismantled or modified. The inspector was already aware of these efforts because he was actively involved in monitoring of the licensee's attempts to correct the fuel priming problem. The troubleshooting efforts were being conducted under the following Startup Deficiency Reports (SDR): SDR-DG-10-91, 03/08/85, Investigate and correct slow response of diesel SDR-DG-10-102, 05/17/85, Investigate and repair 1DG01KA, problem making 10 second start time SDR-DG-11-092, 05/17/85, Investigate and repair 1DG01KB, problem making 10 second start time The licensee also filed a potential 10 CFR 50.55(e) notification with Region III on July 23, 1985, regarding the inability of the diesel generators to sustain fuel oil prim , i

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. Conclusions None of the inspector's random visits to the diesel generator rooms identified undocumented mainternance taking place. The alleger's presence on site coincides with the licensee's attempts to resolve the problems with the diesel fuel oil system. This effort was documented by the preoperational testing and by the documents listed above. This allegation is not substantiate Concern (8) Commonwealth Edison stopped the P&ID verification program after the i work group began to identify discrepancies on primary system drawings. The contract supervisor ordered the verification and discrepancy identification activities stopped and told the group that their only job was to locate components and hang tags on the The alleger believes that the program was stopped because the group was discovering too many discrepancie NRC Review The inspector interviewed the Assistant Superintendent for Operations, the Senior Operating Engineer, an Operating Engineer, and other members of the operations staff. All of these individuals were familiar with the work being done by the alleger's work group and all indicated that the work group's assignment was to walkdown the systems, locate and identify components, and put tags on the At no time was the group instructed to specifically look for discrepancies although it is understood that walking down a system, using a P&ID to locate and identify components, will reveal any existing discrepancies. The work group's contract with the licensee did not specify their job assignments. The computer print-outs, which the alleger gave to the inspector, turned out to be the system mechanical checklists from the Braidwood Operating Procedures (Bw0P).

The checklists contained spaces for component identification and location. The inspector noted during his review of the checklists that many of the spaces had been blank and then were filled in by-han From the interviews with the Operations staff, the inspector also determined that a formal P&ID verification and correction program had been developed and was scheduled to take place during Release to Operations (RTO). The program is controlled by the following procedures: PSU-01, Revision 5, Instructions for System Turnover to Operation PSS-02, Revision 1, Construction Work Record (CWR) Program PCD-03, Revision 2, Field Change Request (FCR) BwAP 1205-11, Revision 1, System Turnover for Operation QP 3-2, Revision 20, Design Change Control

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The inspector also determined that following issue of the operating license, changes and corrections to P& ids will be controlled by the following procedures: BwAP 1340-15, Revision 0, Station Drawing Change Control QP 6-52, Revision 8, Document Control for Operations - Distribution and Control of Engineering Documents and Drawing Change Control Conclusions There is a clear difference between what the alleger's work group perceived as their assignment and what the licensee expecte Neither the alleger nor the licensee could present any documentation which specified the work group's exact a.asignment. The system mechanical checklists (computer print-outs), which had information apparently filled in by the alleger's work group, tend to support the licensee's position that the group's assignment was to locate, identify, and hang tags on equipment. Due to lack of any other evidence to support the allegation, it cannot be substantiated. The inspector reviewed the procedures listed above and determined that they provided an adequate program for identification and correction of drawing discrepancie . Licensee Event Reports (LER) Review Through direct observations, discussions with licensee personnel, and review of reccrds, the fallowing event report was reviewed to determine that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with technical specifications:

 * (0 pen) 456/86001-00-L:  Inoperable Fire Protection Systems and Equipmen The licensee implemented and will maintain compensatory measures until the deficient systenis reach operable status, construction completed. This LER will remain open until the supplemental report is receive The preceding LER has been reviewed against the criteria of 10 CFR 2, Appendix C, and when the incidents described meet all of the following requirements, no Notice of Violation is normally issued for that ite The event was identified by the license The event was an incident that, according to the current enforcement policy, met the criteria for Severity levels IV or V violation The event was appropriately reporte The event was or will be corrected (including measures to prevent recurrence within a reasonable amount of time).

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1 The event was not a violation that could have been prevented by the , licensee's corrective actions for a previous violation.

! In addition to the.fo'regoing,_the inspector reviewed all of_the 4 -licensee's Deviation Reports (DVRs) generated during the inspection , period. This was done in an effort to monitor the conditions related to plant or personnel performance, potential trends, etc. They were also reviewed.for assurance that DVRs were generated appfopriately and

dispositioned in a manner consistent with the applicable procedures

and the QA manual.

Reactor Trips

       .

i Reactor Trip signals were generated on Unit 1 on November 28, 1986 at ! 6:38 p.m. and November 29, 1986 at 2:48 a.m. from LoLo steam generator levels. The first trip was caused by a leaking blowdown valve and the second apparently resulted froc filling steam generator reference legs in

followup actions from the first trip. In both cases, the unit was in

cold shutdown (Mode 5), scram breakers were already open, thus no control rod movement occurred. The inspector reviewed the events and verified that operator and system responses were appropriate for the situatio The licensee event reports will be reviewed upon receipt.

! Events _0n November 18, 1986, the licensee reported to the resident inspectors that they._had identified about 25 hard rubber fire hoses that apparently had no _ record of a timely hydrostatic test. -The hoses were at a number of locations throughout the plant and were identified by a routine fire i protection equipment surveillance. The licer.see took prompt compensatory measures and commenced a record search for dates of.the tests. When no records of the tests could be found, they. commenced testing the hoses and ,. found a number of failures. This was compensated by replacing the , affected hoses with new hoses with appropriate certification. The licensee made an ENS phone notification to the_.NRC upon finding the - failures and is conducting a separate investigation into the_ cause. The investigation results will be reviewed when the Licensee Event-Report ,

 (LER)-is submitted to the NRC.

i j: Commissioner Carr - Onsite , ! On October 27, 1986, Commissioner Kenneth Carr was onsite for a plant * l tour; meetings with the resident inspectors and regional staff, meetings l with station and corporate staffs; a simulator demonstration; and a > walkdown of selected emergency core cooling systems.

The topics discussed in the meeting covered Byron /Braidwood replication; ! overall project status; station organization; operating experience / personnel ' qualifications, training, and licensed operator exam results; lessons ' learned; management of regulatory interfaces; and the planned error free j startup plan.

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In his closing remarks, Commissioner Carr stated that he was impressed with the formality of the program and the cleanliness program (Model Spaces). He commented that it would be necessary to get people to follow through and keep it up. He also expressed approval of the Lessons Learned program and the Zero Error program, but cautioned about getting caught by the unexpecte He also commented on having communications going in the right direction and expressed some concern that personnel performing maintenance and surveillance should be receiving the equivalent training of an operator. He also felt that the weekly meeting with the resident inspectors was favorabl . Plant Tours and Independent Assessment 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 inspectors reviewed various logs, daily orders, interviewed personnel, attended shift briefings and plan of the day meetings, 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 During routine plant tours, the inspectors noted a number of weaknesses needing attention or matters that could result in potential reportable items and/or violations if the plant were in a different status, e.g., higher mode. The licensee has implemented a system for followup to assure that the inspectors concerns are properly addressed. The following is a list of those concerns and the related corrective actions if applicable: Communications - on several occasions communications were insufficient for operators to understand what activities were , occurring in the plant; such as construction work on primary instruments, cngoing test activities, maintenance, and construction personnel working in control room back panels. The licensee has implemented and strengthened the access control program in addition to improving notification of operations personnel of plant activitie There have been minimal reoccurrences of these problem Operator awareness of system status - on several occasions, operators or SCRE's were not aware of the status of specific control board items relative to ongoing plant s tivities, such as an out-of-service tag on the centrifugal charging pump, reactor coolant pump space heaters, 18 diesel generator, fuel oil storage tank alarm; and operating activities such as how to align the boric acid pump to the safety-related emergency power supply, consequences of a loss of diesel generator while in Mode 6, the effect of a loss of "A" train power supply on "B" train instruments control room indications, how to reset boron dilution prevention system to allow operation of volume control tank, and the alignment of the refueling water storage

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tank suction valves to the charging pumps. The licensee is taking efforts to make shift personnel more inquisitive about their areas of responsibility and management personnel are quizzing personnel on shift to create a greater awareness by operating personne Review Process - The inspectors noted weaknesses in licensee review of procedures and completed surveillances such as 50.57(c) boration procedures, which contained an improperly aligned valve and omitted a required valve for samplings, the licensee corrected these items prior to procedure use; completed surveillances marked satisfactory, , which contained unsatisfactory acceptance criteria, acceptance criteria in Section G of procedure different than noted in the body of the procedure for the same parameter. The licensee is sampling 150 to 200 surveillance packages for similar error Programs - The control room critical drawing system was reviewe Tt appeared that drawings were not properly updated (i.e. , unauthorized changes) and the operators' use of them was not apparent in all case This was addressed in the daily order after the inspector's inquir The inspector also reviewed the licensee's quality assurance audits concerning the operator aids program, da ly orders, and logs. The i audits noted a number of observations and findings in these areas such as' operators not reviewing daily orders and logs and problems with use of operator aid Near the end of the inspection period, the licensee implemented their approved "Braidwood Plan for Achieving and Maintaining Error Free Start-Up and Operation of Unit 1." This plan offers a number of_ actions that can be helpfu In general, they include special reviews and corpnrate overview, shift augmentation, shift operations, and administration which involves personnel from all levels of the station organizatio The inspector observed work activities in progress, completed work and plant conditions during general inspections in Unit 2 work area Observation of work included cable trays, junction boxes, pipe support welding, and mechanical equipmen Particalar attention was given to material identification, nonconforming material identification and housekeeping. During a tour of the Unit 2 containment the following items were noted:

* High strength studs and nuts were found on top of an orifice. This material was not tagged for construction status and the inspector did not notice any craft working in.the area. Also, the inspector could not identify any component in the immediate area that had missing studs or nuts. The inspector noted high strength nuts on the Pressurizer Relief Tank (PRT) without the appropriate '

construction status. The high strength bolting noted by the orifice or the PRT was not being stored in a material stagin0 are i e

 . . .  . -  .. - - - - . -.-- . . - -   . - .- - .
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 * The following instrument racks were not covered:

I 2PL75J 2PL50J 2PL53J (partially uncovered) I- *- Valve 2RY8031.was being stored under the PR The valve was not on . dunnage,' covered for protection, nor were the cable connections fo the limit switches capped to prevent dirt or debris from entering the limit switches.

i

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While touring'the turbine building, it was noted that a Unit 2 spare RHR

motor frame consisting of a stator was not being properly stored. This motor was being stored in the Unit 2 track alley on the 401' elevation

, near an overhead door. This motor was stored covered, but without space heaters energized or another source of heat to prevent moisture on the stator windings. The licensee was informed of this condition and took i corrective action which consisted.of, placing a lighted bulb inside the motor frame.

l .In summary, the housekeeping in the Unit 2 containment and auxiliary building has deteriorated to a level that.is not acceptable. .Besides the concerns noted with the hardware items identified above, there was excessive dirt and debris. The lack of offective housekeeping measures is considered an unresolved item (457/86044-01(DRP)). The inspector has established a weekly tour of the Unit 2 work areas with the Construction i Superintendent to continually monitor the progress of housekeepin ' No violations or deviations were identified.

I: Initial Fuel Load

The licensee completed the initial fuel load in Unit 1 on November 2, 1986. The fuel loading was completed without incident, including followup activities, such'as latching control rods and reactor vessel

.,

head placement and tensioning. The inspectors continued the inspection of activities as described in the previous report (456/86050(DRP);

 '457/86037(DRP)).

I No violations or deviations were identified.

i

Surveillances

The inspectors reviewed the licensee's implementation of the surveillance

program. The review identified instances in which the licensee was not

performing surveillance activities in the manner described by the

' procedures controlling surveillance activities. Technical Specification, l Section 6.8.1, endorses Regulatory Guide 1.33, Appendix A, which identifies procedures required for administration of surveillance activitie Also, the licensee's quality assurance manual requires that the procedures controlling these activities be adhered to. The following i examples of inadequate surveillances were identified: !

i

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4 .

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' The licensee's program for engineering safety feature (ESF) undervoltage, grid degraded voltage, and reactor coolant pump undervoltage relay testing was improperly conducted in that:

(1) Two of the relays tested (Work Request Nos. A06545 and 48) did not identify or meet the Technical Specification acceptance criteria for these relays. Technical staff personnel reviewed the completed test and failed to note the discrepancies. BwAP 1400-1, Sections 10 and 11, General Surveillance Program requirements for unsatisfactory acceptance criteria was not followed. The two relays identified will require a retest to be performe (2) BwHP 300-003 requires that the technical staff supply a list of relays to be inspected / tested to the electrical maintenance (EM) department. Discussions with technical staff and electrical department personnel identified that the required list had not been generated by technical staff nor supplied to the ems from the technical staf (3) The requirements of BwAP 1400-7, " Surveillance Procedure Format," relative to required surveillance procedure content were not follow; The procedure used to perform the relay surveillances Bw4P 4009-003 did not contain the information required by BwAP 1400-7, Sections 3.a, b, and d., concerning procedures sections for prerequisites, limitations and actions, and technical specification acceptance criteri The monthly surveillance for the 1B Diesel Generator, described by surveillance procedure 18w0S 8.1.1.2a-2, contained unsatisfactory acceptance criteria, but the surveillance was identified to be satisfactory by the shift engineer and the surveillance computer data base. As written, the surveillance required both air banks for the diesel to be at 240 psi. The A bank was at 240 psi and the B bank was at 117 psi. This surveillance should have been identified as unsatisfactory and the requirements of 8wAP 1400-1, Sections 10 and 11, imp;omente A Mode 4 monchly surveillance (18w0S 7.4.A-1) for essential service water (SX) system was utilized for cocumenting the current valve lineup for the SX system while in Modes 5 and 6. The surveillance contained data which was indicated to be unsatisfactory for Mode Even though the surveillance contained the unsatisfactory data the surveillance was documented as satisfactory by the shift engineer and noted as satisfactory for Mode 4 in the computer data bas The method used for this surveillance to document Mode 5 and 6 valve positions is contrary to the requirements of BwAP 1400-1, Sections 10 and 1 The discrepancies noted in the above examples are considered to be in violation of the requirements of the Technical Specification, Section 6.8.1, and the Licensee's Quality Assurance Manual, Section 5-51 (456/86063-01(DRP)).

     . .

. , * Reactor Coolant System (RCS) Hydrostatic Test - Unit 2 The inspector witnessed the Unit 2 RCS hydrostatic test on November 30, 1986. The test procedure used was BwSD-RC-64. The test engineers and operators involved with the test appeared to be knowledgeable about the test procedure, required conditions, and the plant status. The inspector asked several questions pertaining to plant status which were answered correctly. The portion of the test witnessed by the inspector included the activities pertaining to pressurizing the RCS from 1500 psi to the hydrostatic test pressure (3113-3177 psi). The hydrostatic test pressure was maintained for ten minutes, after which the RCS pressure was decreased to approximately 2500 psi. The RCS was then walked down by licensee personnel to inspect for leaks. The inspector also made a tour of the Unit 2 containment and noted no leaks attributed to a compromise in the RCS boundary. Prior to obtaining the hydrostatic test pressure, the power operated relief valve (PORV) block valves, 2RY8000A and B, had to be closed due to excessive leakage. The closure of these valves did not allow the hydrostatic testing of the RCS boundary between the PORV block valves and the PORVs. The lack of a hydrostatic test on this portion of the RCS is considered an open item (457/86044-02(DRP)). No violations or deviations were identifie . Procurement The procurement process utilized to replace the Unit 1 and Unit 2 Nickel Cadmium (NiCad) batteries for the diesel Auxiliary Feedwater (AFW) pump was reviewed by the inspector. The following procurement documents were reviewed:

* Purchase Order 307238, dated July 14, 198 * Material and Equipment Receiving and Inspection Report (MRR), dated October 1, 198 * Site Contractor Material / Services Request 2194 * Certificate of Compliance, dated September 18, 198 The original batteries were supplied by the manufacturer of the diesel drive used for the AFW pump. The applicable procurement specification was Sargent & Lundy Specification L-2891. This specification required all electrical equipment, instrumentation and controls to be seismically qualified in accordance with IEEE-344-1975, "IEEE Standard for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations." The review of the procurement documents revealed that the NiCad batteries were procured as a commercial grade item and dedicated for a safety-related application by utilizing a receipt inspection and a Certificate of Conformance from the vendor. There was no objective evidence that a technical evaluation was performed prior to releasing the batteries for installation to determine if the batteries were qualified IEEE-34 . , . _ . _ _ _ _ _ _ _

, 4 .

The licensee's Quality Assurance Manual, Quality Procedure, 4-1, Section 4.7.2, allows commercial grade items to be upgraded (dedication) to a safety-related application by utilizing a receipt inspectio However, this dedication using solely a receipt inspection is not allowed if the commercial grade item being upgraded is not relatively simple and standard in design. For those commercial grade items which are not standard in design, the dedication process must also consist of a documented technical evaluation. The lack of perforn.ing a technical evaluation to upgrade the batteries to a safety related classification is considered a violation of 10 CFR 50, Appendix B, Criterion II

(456/86063-02(DRP); 457/86044-03(DRP)). The licensee immediately initiated corrective action to resolve this violation and to preclude recurrenc . Pipe Supports The inspector reviewed the installation of three American Society of Mechanical Engineers (ASME), Class I pipe support The installations were verified to be in compliance with the applicable design requirement The pipe supports inspected and the applicable documents utilized were:

Pipe Support Documents 2RH02004R Drawing M-2RH02004R, Revision * Engineering Change Notice (ECN) 0-09004 2RH02050R Drawing M-2RH02050R, Revision * 1 ECN 0-09006 2SIO9010R Drawing M-2SIO9010R, Revision A The attributes inspected were weld configuration, weld quality, support configuration, welder symbol and dimensions. These attributes were sampled for each support with no problems noted in those attributes selected. The inspector also verified that there was identification markings on various parts of the pipe supports for traceability to QA records, such as certified material test reports. The parts verified for traceability to QA records were: Pipe Support Part Markings for Traceability 2SIO9010R Size 3 restraint Material Receiving Report end tee (MRR) 15292 Size 3 microstrut MRR 15266 assembly Tube steel MRR 14040 - Heat Number D28720 2RH02050R Tube steel MRR 14830 - Heat Number 803X71010 Size 3 restraint MRR 15292 end tee

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!
..e Pipe Support Part  Markings for Traceability Size 3 microstrut MRR 15144 assembly Size 3 restraint MRR 15299 assembly bracket 1" rod steel MRR 16581 washer plate 2RH02004R 1" X 12" U-bolt MRR 16490 Tube steel MRR 14830 - Heat Number 803X71010 Size 3 restraint MRR 15292 end tee Size 3 restraint MRR 15827 end bracket No violations or deviations were identifie . Meetings, Training, and Other Activities Plant Status Meeting A meeting was held on November 18, 1986, between the CECO Project Manager, the Region III Project Director, and members of each of their staffs. The purpose of the meeting was for the licensee to provide an update on the status of Units 1 and The meeting was also an opportunity to discuss the licensee's list of items that must be dispositioned prior to a mode change in Unit . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed by the inspector and which involve some action on the part of the NRC or licensee or both. An open item disclosed during the inspection is discussed in Paragraph 9.

, 14. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. An unresolved item disclosed during the inspection is discussed in Paragraph 6.

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. . . to 15. Exit Interview The inspector met with licensee and contractor representatives denoted in Paragraph 1.during and at the conclusion of the inspection on December 18, 1986. The inspector 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 }}