IR 05000456/1987030

Insp Repts 50-456/87-30 & 50-457/87-29 on 870825-0904. Violations Noted.Major Areas Inspected:Qa Program Implementation in Preparation for Operation in Specific Areas of Procurement,Receipt & Storage & Records Control

ML20235N406
Person / Time
Site:	Braidwood
Issue date:	09/30/1987
From:	Reynolds S, Sutphin R, Telela T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20235N363	List: IR 05000456/1987030 ML20235N359 ML20235N385
References
50-456-87-30, 50-457-87-29, NUDOCS 8710060510
Download: ML20235N406 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-456/87030(DRS); 50-457/87029(DRS)

Docket Nos.' 50-456; 50-457 Licenses'No. NPF-72; 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: August 25 through September 4, 1987 Inspectors: Me 4 dbt s 1/3c/#7

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S. A. Reynolds Dat e

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& .Stif 9/30/t1 Date '

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R. $ gtphin h /drda/v Ocfq 9/30/97 T. Tella Date Approved By: '

bh ' 30[h 7 F. 'd. (ajilonski, Th f Ddte /

Quality Assurance Programs Section Inspection Summary J

Inspection on August 25 through September 4, 1987 (Reports No. 50-456/87030(DRS); )

50-457/87029(DRS)) I Areas Inspected: Routine, unannounced inspection of licensee's QA Program l implementation in preparation for operation in the specific areas of procurement,

' receipt and storage, records control, committee activities, audits, tests and experiments, control of test equipment, and surveillance testing. This l inspection was conducted utilizing portions of Inspection Procedures 35741, .

35745, 35746, 35747, 35748, 35749, 35750, 39301, and 4030 J Results: Two violations were identified: (1) material control, Paragraph 2.a.(2); (2) measuring and testing equipment, Paragraph )

8710060510 870930 PDR I G ADOCK 05000456'

PDR, l

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DETAILS i

1. Persons Contacted Commonwealth Edison Company (CECO)

• C. Schroeder, Services Superintendent

• P. Barnes, Regulatory Assurance Supervisor A. Chomacke, Senior Participant, Offsite Review, Braidwood D. Cline, Stores Supervisor

• A. D' Antonio, Quality Control

• J. Gosnell, Quality Control Supervisor

• G. Nelson,. Assistant Technical Staff Supervisor D. Paquette, Assistant Superintendent, Maintenance

• S. Stapp, Quality Assurance Inspector

• J. Woldridge, Technical Staff

• Indicates those attending the September 4, 1987, exit meetin Other individuals were contacted as a matter of course during the inspectio . Areas Inspected The purposes of this inspection were to verify that the QA Program had been properly implemented for Braidwood, Units 1 and 2 in specific programmatic areas and to evaluate the QA Program for Braidwood, Unit Braidwood, Units 1 and 2 share a common Ceco QA Program, and in most cases, the same procedures. This inspection included QA Program implementation in the areas of procurement, material handling, committee activities, tests and experiments, document control, audits, preoperational te. Sting, test equipment and surveillance testing. This inspection evaluated licensee management involvement and control in assuring quality in these areas and attempted to determine the effectiveness of training and qualification Verification of the above, as well as compliance with regulatory requirements and QA Program commitments, was accomplished by review of applicable procedures and records, and interviews with personne Procurement Control (1) Reference Documents (a) QR 4.0 " Procurement Document Control" (b) QR 7.0 " Control of Purchased Material Equipment and Services" (c) BwAP 800-2, " Control of Requests for Purchase,"

Revision No. (d) Q.P. No. 17-51, " Quality Assurance Records for Operations - Control of Station Records."

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(2) Results The inspectors selected 11 different safe'ty-related items in the storeroom to use as a basis for verification of procurement program implementation. The items included those identified on purchase orders (P0s) 303838, 296089, 312757, 502207, 312254, T02324, MDC BR 116-861, 756225, Eval 86-081, 290999, and 50208 .

Records pertaining to the procurement of the items were retrieved and reviewed for compliance with requirements. The inspector observed that the licensee experienced some difficulty in the timely retrieval of the records and in some instances extensive explanations were required to furnish facts and information relative to the records, and the basis for acceptance of the item The records for P0 296089 were considered by the licensee to have been. complete and were in the permanent microfilm fil Item 16 on the P0 specified Stores Item (SI) 763002, Plate, Valve, Metal Seat, 36 in, for a Cat 1 Valve, DW/NO 4-2535-500, Anderson Greenwood and Co. P/N N0 4-2457-010, Code No. A605 ASME Section III, Class III, 1974, Agenda W 1975, to be made of SA.515-70 material. Records indicated that the item was furnished with SA 516-70 material, a lower grade material than that specifie The tag on the item in the storeroom identified the material as SA 515-70 which was incorrec In accordance with licensee procedures, upon receipt, this condition should have been declared nonconforming and a Nonconformance or Discrepancy Report issued to control the items, pending disposition. In addition, hold tags should have been applied to the. parts. The licensee could not retrieve those type items or otherwise show that the activities had taken place, nor that an engineering evaluation had been mad It should be noted that internal audits of the procurement area failed to identify the documentation or hardware problem Criterion VII of Appendix B to 10 CFR 50, requires that material and equipment conform to procurement requirements and that documentary evidence be available prior to installation or us Criterion VII also requires that this documentary evidence be sufficient to identify the specific requirements, such as codes, standards, or specifications, which were me Failure to provide complete and adequate documentation including engineering evaluations or dispositions, to verify that the l purchased item met specific material requirements is considered 1 a violation of 10 CFR 50, Appendix B, Criterion VII (456/87030-01; 457/87029-01).

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At the conclusion of the inspection, the licensee issued Discrepancy Record (DR) No. DR 20-No. 87-H365 to document this nonconforming condition. The DR also included a discrepancy with Item 14 of the P0 that the licensee found after a complete review of PO 296089. Hold tags were issued and applied to the nonconforming items and an engineering evaluation was requeste One item, P.O. 501784, BR 1043, for Diesel Fuel, was selected for a review of current activities associated with procurement of consumable The inspector observed the actual receipt and

. sampling of this item for acceptanc No problems were identifie One violation was identifie b. Material Handling (1) Reference Documents (a) Q.P. No. 13-51, " Handling, Storage, and Shipping for Operations - Control of Equipment, Materials, and Nuclear Fuel."

(b) BwAP 800-1, " Classification of Parts of Safety-Related Components," Revision No. (c) Audit Report No. QAA-20-86-46, "ISI Activities /

Documentation and Crane Inspections."

(d) Audit Report No. QAA-20-87-21, " Material Control."

(e) Audit Report No. QAA-20-87-59, " Storage of Material."

(f) Audit Report No. QAA-20-87-08, " Inspection and Tests - Crane Inspections."

(2) Results The inspector verified that administrative controls for receipt of safety-related items had been established and were generally implemented in accordance with commitments. Controls for storage and handling had also been established and were implemente Audit reports of activities in this area were reviewed for ,

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effectiveness and followup of items identified by the QA staf The audits appeared to be effective in assessing licensee performance to commitments and requirement In the four audit reports reviewed, the licensee had identified 12 items that required attentio The licensee responded to those audit items in an appropriate manner and had adequate plans to resolve the The inspector had no concern for the licensee's responsiveness in this are l No violations were identified.

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c. Safety Committee Activities (1) Reference Documents (a) Nuclear Safety Office Manual for Offsite Revie (b) Discipline Qualifications for the Braidwood Senior Participan (c) Policies on Record Retentio (d) Organization Chart for the Department of Nuclear Safet (e) Braidwood Administrative Procedures for Onsite Review (f) Offsite Review Discipline Qualification Checkshee (g) Braidwood Onsite Review and Investigation Reports87-113 through 87-11 (2) Results Onsite review activities were reviewed with the Assistant Technical Staff Supervisor and included a review of all of the recent changes in the Braidwood Administrative Procedures that applied to onsite review Qualifications and assignments of reviewers were checked, and minutes or reports of meetings and onsite reviews were reviewed for compliance with requirements, Offsite Safety Review Activities were reviewed with the Senior Participant at the site. The current revision of the Nuclear Safety Office Manual for Offsite Review was reviewed and was found acceptabl No violations were identifie d. Tests and Experiments (1) Reference Documents (a) Braidwood Administrative Procedures:

• BwAP 1205-3, "Onsite Review and Investigation Function," Revision * BwAP 1205-6, " Conduct of 10 CFR 50.59 Safety Evaluations," Revision * BwAP 1300-3, " Preparation and Approval of Temporary Procedures and Temporary Changes to the Permanent Procedures," Revision .

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(b) Braidwood Project Startup Manual, Units 1 and 2, Revision 2 .

(c) Nuclear Stations Division Directive A01, " Nuclear Stations Division FSAR Update Directive," Revision (2) Results The inspector reviewed the administrative controls for handling plant tests and experiments that involve safety-related components, systems,'or structures, or modes of operation different from those specified in the FSA Applicable portions of the above listed procedures were reviewed and determined to ,

provide adequate control of tests and experiments. No Unit 2 tests and experiments had been performe No violations were~ identifie Quality Assurance Records Control (1) Reference Documents (a) Braidwood Administrative Procedures:

• BwAP 1340-2, " Quality Records Turnover," i Revision * BwAP 1304-3, " Document Retention,"

Revision * BwAP 1340-10, " Records Storage System Survey,"

Revision (b) Braidwood Master Retention Schedule Revision (c) Commonwealth Edison Company QA Manual Quality Procedure 17-51, " Quality Assurance Records for Operations - Control of Station Records."

(d) CECO QA Manual Quality Procedure 17-51, Attachment " Retention Times for Safety-Related Lifetime and i Nonpermanent Records," Revision (2) Results j

The inspector determined that administrative controls for ]

QA records appeared adequate; however, implementation of those controls was not reviewed or evaluate ;

E During the above review, the inspector noted that the record i

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retention times specified for QA Records in Attachment A of j QP 17-51 differed, for certain types of records, from the '

licensee's current commitments to ANSI N45.2.9 - 1974, j

!- " Requirements for Collection, Storage, and Maintenance i

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of Quality' Assurance' Records for Nuclear Power Plants" and Section 6.10 of the Braidwood Technical Specificatio After the inspector discussed this matter with licensee QA personnel, the licensee committed to revise Attachment A of

.QP 17-51~to resolve the concerns. Pending' review, this will be_ tracked as an Open Item (456/87030-02; 457/87029-02).

f. Audits (1) Reference Documents (a) Braidwood Technical Specification, Section 6.5. (b) Braidwood Quality Assurance Audits:

• QAA 20-87-05, " Calibration of Portable Test and Measuring Equipment."

• QAA 20-87-10, " Radioactive Waste."

• QAA 20-87-12, " Staffing and Training."

• QAA 20-87-66,_" Technical Staff Corrective Actions."

(2) Results The inspector reviewed the above listed audits and determined that the licensee's performance and documentation were adequat The inspector observed a few minor omissions and incomplete notations on audit checklists, reports, and followups; however, those concerns were quickly and adequately resolved by the license The inspector reviewed station QA qualification records for lead auditors involved with the above audit and determined that those five auditors met requirements of ANSI N45.2.23,

" Qualification of QA Program Audit Personnel for Nuclear Power Plants." Training records for those five auditors were reviewed and appeared to be adequat Backup documents provided with the-records generally provided sufficient objective evidence to support the auditor qualification No violations were identifie g. Preoperational Test Program Reccrds  !

(1) Reference Documents (a) Braidwood Administrative Procedures:

• BwAP 1340-2, " Quality Records Turnover,"

Revision 3.

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• BwAP 1340-3, " Document Retention,"

Revision (b) Braidwood Master Retention Schedule, Revision (c) Braidwood Nuclear Station Project Procedure PSU-05,

" Maintenance and Control of Startup Department Documentation," Revision (2) Results The inspector reviewed the administrative controls for maintaining preoperational test program records and reviewed I the retention periods for those record The administrative i controls appeared adequate and the retention times specified on the Master Retention Schedule appeared to be in accordance with the Technical Specificatio Two station QA audits of this area were reviewed by the inspector. The audits were adequate in scope and coverag The inspector reviewed the records of several preoperational tests and personnel qualifications for five individuals involved with preoperational test program The records were adequately maintained and controlle No violations were identifie Measuring and Test Equipment (M&TE)

(1) Reference Documents (a) BwAP No. 400-4, " Control of Portable Measuring and Test Equipment," Revision (b) QP No. 2, " Calibration and Control of Station Instrumentation and Control Equipment," Revision (c) QR No. 12.0, " Control of Measuring and Test Equipment," !

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(d) QP No. 12-1, " Calibration Control of Commonwealth Edison Test and Measuring Equipment," Revision 1 (e) QP No. 12-51, " Control of Measuring and Test Equipment ,

for Operations - Portable Test and Measuring Equipment," )

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The inspector reviewed a random sample of 10 M&TE items in the Instrument and Control Department, 9 items in the Electrical Department, and 13 items in the Mechanical Departmen The inspector observed that when a M&TE item was determined to be out of calibration, a Discrepancy Record (DR) or equivalent

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F was issued by the concerned department; The DR form required that the cause of. discrepancy and effect on the system be documente The inspector was informed that in all three departments, the use of the out of calibration equipment on the last day of usage was verifie If that use was in order, no' further verification of prior use was mad The licensee's Topical Report, CE-1-A Revision 45, commits the licensee to Regulatory Guide 1.33, Revision 2, which endorses ANSI N18.7. ANSI N18.7 - 1976, Paragraph 5.2.16. requires.that

"When calibration testing, or other measuring devices are found out of calibration, an evaluation'shall be made and documented concerning the validity of previous tests,and the acceptability of devices previously tested from the time of previous calibration."

In several instances, when M&TE was found out of calibration, the {

licensee only evaluated the last acceptable usage of the M&TE, (

'instead of evaluating all instances where the out of calibration M&TE was used since the previous acceptable calibratio The licensee had not evaluated the failure mode of out of calibration q M&TE nor, in most. cases, the effect of using the M&TE on all previous occasions;.therefore, the test results obtained by use of such M&TE are of indeterminate qualit Criterion 111 of Appendix B to 10 CFR 50, requires that measures be established to control M&T Failure to have controls to evaluate the past use of out of calibration equipment affects many systems in the plant and is considered a violation' of 10 CFR 50, Appendix B, Criterion XII (456/87030-03' ;

457/87029-03).

One violation was identifie Surveillance Testing (1) Reference Documents (a) BwVS 800-8, " Main Steam Isolation Valve Instrument Air Check Valve Leakage Test," Revision (b) BwVS 7.1.1-1, " Testing of Main Steam System Safety i

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Valves," Revision (c) 2 Bw0S 8.2.1.2. 9-1, "125V DC ESF Battery Bank and Charger 211 Operability Weekly Surveillance,"

Revision 5 (2) Results The licensee maintains a computerized log of all station surveillance. The station surveillance coordinator indicated

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that about eight percent of_the Unit 2 system surveillance were complete The inspector reviewed completed test-reports of a few surveillance tests. The necessary program and procedures required for surveillance program were in plac Implementation of those procedures will be verified in a subsequent inspectio No violations were identifie . Conclusion After completing the evaluation of QA Program implementation in the areas described in Section 2, it was concluded that:

• Management involvement and control was apparent'in the areas of performing audits, following up and correcting audit findings, and providing qualified and trained auditors, preoperational testing personnel and safety committee member * Management was generally responsive to NRC concerns especially in the areas of procurement and records control discussed in Section 2a and The violation pertaining to M&TE discussed in Section 2h will'

require aggressive management involvement to ensure adequate review of the potential impact of the proble . Open Items Open items are matters that have been discussed with the licensee, which will be reviewed further by the inspector, and involve some action on the part of the NRC or licensee or both. An open item disclosed during this inspection is included in Paragraph 2.e.(2). Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)

on September 4, 1987, at the Braidwood Station and summarized the purpose, scope, and findings of the inspection. The inspectors discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspectio The licensee did not identify any such documents or processes as proprietar l I

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