ML17199F696
| ML17199F696 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle, 05000000 |
| Issue date: | 03/20/1986 |
| From: | Dupont S, Eng P, Falevits Z, Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17199F694 | List: |
| References | |
| 50-237-85-38, 50-249-85-34, 50-254-85-31, 50-265-85-33, 50-295-85-43, 50-304-85-44, 50-373-85-40, 50-374-85-41, 50-454-85-52, 50-455-85-46, 50-456-85-56, NUDOCS 8603270362 | |
| Download: ML17199F696 (23) | |
See also: IR 05000237/1985038
Text
Reports No.
Docket Nos.
Licensee:
U. S. NUCLEAR REGULATORY COMMISSION
REGION I II
50-237/85038(DRS), 50-249/85034(DRS);
50-373/85040(DRS), 50-374/8504l(DRS);
50-254/8503l(DRS), 50-265/85033(DRS);
50-295/85043(DRS), 50-304/85044(DRS)
50-454/85052(DRS), 50-455/85046(DRS);
50-456/85056(DRS);
50-237, 50-249;
Licenses
50-373, 50-374;
50-254, 50-265;
50-295, 50-304
50-454, 50-455;
50-456;
Commonwealth Edison Company
P. 0. Box 767
Chicago, IL
60690
NPF-37, CPPR-131;
CPPR-132
Facility Names:
Byron Station, Units 1 and 2; Braidwood Station, Unit 1
Dresden Nuclear Power Station, Units 2 and 3; ; LaSalle County
Station, Units 1 and 2; Quad-Cities Nuclear Power Station,
Units 1 and 2; Zion Nuclear Power Station, Units 1 and 2
Inspection At:
Byron Site, Byron, IL; Braidwood Site, Braidwood, IL;
Dresden Site, Morris, IL; LaSalle Site, Marseilles, IL;
Quad-Cities Site, Cordova, IL; Zion Site, Zion, IL
Inspection Conducted: De~~~p~~~§? through January 24,
~---<l ~ r;;;? k
Inspecto~ s: G:" Du~
P.-f<fg ~
z~,~~
z.~levits
~
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c/'?1.:v .. ~:/(f<{~
Approved By:
M. fl... Ring, Chi.¢
Test Programs Section
8603270362 860324
ADOCK 05000237
Q
1986 and March 18, 1986
D tet
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Areas Inspected:
Actions on previous inspection findings (92701); training
and certification (41400); Operational Analysis Department (OAD) procedures
(61700); drawing and document control(61700 and 37701); test and measuring
equipment control (63700 and 61700); setpoint and tolerance control (61700
and 62700); and interface between OAD and plant organizations.
Results:
Of the seven areas inspected, no violations or deviations were
identified in six areas. Within the remaining area, three violations were
identified (failure to use approved procedures - Paragraphs 5.b and 5.d;
qualitative data was not recorded - Paragraph 5.d; post maintenance procedures
had not received onsite review and approval - Paragraph 5.d) .
2
DETAILS
1.
Persons Contacted
a.
Zion Nuclear Power Station
- T. Rieck, Services Superintendent
- E. Fuerst, Production Superintendent
- J. Ballard, Quality Control Supervisor
- K. Kofron, Assistant Superintendent, Maintenance
- R. Budowle, Assistant Superintendent, Technical Services
- D. Armington, Operational Analysis Department
The inspectors also interviewed other licensee employees, including
members of the quality assurance, quality control, and operational
analysis groups.
- Denotes those personnel in attendance at the December 10, 1985
exit meeting at Zion.
b.
Braidwood Nuclear Power Station
- P. J. Bingen, Southern Division, Operational Analysis Engineer
- A. A. Jaras, Rock River Division, Operational Analysis Engineer
- C. W. Schroeder, Project Licensing and Compliance Superintendent
- M. J. Wallace, Project Manager
- E. D. Eenigenburg, Maintenance Manager, NSD
- K. Faber, Braidwood Operational Analysis
- R. D. Kyrouac, Station Quality Assurance Supervisor
- E. R. Netzel, Quality Assurance Supervisor
- T. E. Quaka, Site Quality Assurance Superintendent
- C. J. Tomashek, Startup Superintendent
- N. Tomis, Braidwood Project Operational Analysis
Supervising Engineer
- R. D. Vine, Quality Assurance Audit Coordinator
The inspectors also interviewed other licensee employees, including
members of the quality assurance, quality control, and operational
analysis groups.
- Denotes those personnel in attendance at the December 20, 1985
exit meeting at Braidwood.
c.
Byron Nuclear Power Station
- R. E. Querio, Station Manager
- V. Schlosser, Project Manager
- R. M. Hennigan, Operational Analysis Manager
- J. J. Glowinski, Project Operational Analysis Supervisor
- A. J. Chernick, Compliance Supervisor
3
- R. B. Klingler, Quality Control Supervisor
- D. Robinson, Safety Engineer
- E. Briette, Quality Assurance Engineer
- R. Gruber, Quality Assurance Engineer
The inspectors also interviewed other licensee employees, including
members of the quality assurance, technical staff, and operational
analysis groups.
- Denotes those personnel in attendance at the January 8, 1986 exit
meeting at Byron.
ct.
Quad-Cities Nuclear Power Station
- T. Tamlyn, Services Superintendent
- R. Bax, Production Superintendent
- A. A. Jaras, Rock River Division, Operational Analysis Engineer
- H. Lihon, Technical Staff Supervisor
- C. Smith, Quality Control Supervisor
- D. Gibson, Quality Assurance Supervisor
- R. B. Strub, Compliance Coordinator
- P. Lasko, Operational Analysis Engineer
The inspectors also interviewed other licensee employees, including
members of the quality assurance, quality control, and operational
analysis departments.
- Denotes those personnel in attendance at the January 10, 1986 exit
meeting at Quad-Cities.
e.
Dresden Nuclear Power Station
- D. J. Scott, Station Manager
- R. M. Hennigan, Operational Analysis Manager
- J. D. Brunner, Assistant Superintendent
- P. J. Bingen, Southern Division Operational Analysis Engineer
- P. A. Lau, Quality Assurance Supervisor
- D. A. Adam, Regulatory Assurance Supervisor
- G. J. Wirth, Operational Analysis Engineer
- J. R. Williams, Quality Assurance Senior Inspector
The inspectors also interviewed other licensee employees, including
members of the quality assurance, quality control, and operational
analysis departments.
- Denotes those personnel in attendance at the January 14, 1986
exit meeting at Dresden.
f.
LaSalle County Nuclear Station
- R. Bishop, Services Superintendent
- R. M. Hennigan, Operational Analysis Manager
- W. E. Sheldon, Assistant Superintendent, Maintenance
- T. J. Meno, Southern Division, Operational Analysis Engineer
4
- R. M. Jeisy, Quality Assurance Supervisor
- P. F. Manning, Technical Staff Supervisor
- G. Morey, Electrical Maintenance Foreman
- J. R. Kodinick, Maintenance Staff Engineer
- T. K. Vancina, Operational Analysis Engineer
The inspector also interviewed other licensee employees, including
members of the maintenance, quality assurance, quality control, and
operational analysis departments.
- Denotes those personnel in attendance at the January 17, 1986 exit
meeting at LaSalle.
g.
Final Operational Analysis Department Corporate Exit
- R. M. Hennigan, Operational Analysis Manager
- W. J. Shewski, Quality Assurance Manager
- L. F. Gerner, Regulatory Assurance Superintendent
- K. J. Hansing, Quality Assurance (Engineering/Construction) Director
- H. P. Studtmann, Quality Assurance (Maintenance) Director
- A. A. Jaras, Operational Analysis Engineer, Rock River Division
- A. B. Cushman, Operational Analysis Engineer, Northern Division
- T. J. Meno, Operational Analysis Engineer, *southern Division
- T. Jesionowski, System Operational Analysis, Quality Control
Coordinator
- T. E. Wiedman, System Planning
- M. S. Turbak, Nuclear Licensing
- J. R. Wojnarowski, Nuclear Licensing
- L. R. Seen, System Operational Analysis Department
- J. W. Coon, System Operational Analysis Department
- C. J. Polito, Technical Center, Operational Analysis
- D.
Lamken~ Station Nuclear Engineering Department
- R. E. Grams, Station Nuclear Engineering Department Engineer
- N. P. Tomis, Braidwood Project Operational Analysis, Supervisor
Engineer
- J. J. Glowinski, Byron Project Operational Analysis, Supervisor
Engineer
- D. A. Adam, Dresden Regulatory Assurance
- P. E. Hull, Station Nuclear Engineering Department
- S. Zunijic, Station Nuclear Engineering Department
- Denotes those personnel in attendance at the January 24, 1986>exit
meeting.
- Denotes those personnel in attendance at both the January 24, 1986,
and March 18, 1986, exit meetings.
- Denotes those personnel in attendance at the March 18, 1986, exit
meeting .
5
..
2.
Actions on Previous Inspection Findings
(Closed) Open Item (374/83039-02):
Review generic DAD construction
procedures used by DAD at LaSalle.
This item is closed with the inspection
effort and current inspection findings documented in Paragraph 4 of this
report.
Specific concerns regarding OAD procedures will be tracked by the
inspection findings documented in Paragraph 5 of this report.
(Closed) Unresolved Item (374/85020-03):
Procedure LES-GM-119 utilized
OAD Procedure 3.2,
11 Periodic Relay Testing of Voltage Relays,
11 for
determining acceptance to Technical Specification requirements; however,
the OAD procedure appeared to be inadequate in providing the detail
required to verify surveillances' acceptance and compliance to the Technical
Specifications.
The procedure was subsequently revised.
The inspector
reviewed the revised procedure and found it adequate.
3.
Operational Analysis Department (OAD)
a.
Scope and Objectives of the Inspection
The objective of the inspection was to determine the function of DAD
at the various Commonwealth Edison nuclear stations and their
interfacing with the station administrative requirements and the
requirements of various Institute of Electrical and Electronics
Engineers (IEEE) standards, stations\\ Technical Specifications,
Regulatory Guides, and 10 CFR 50, Appendix B .
b.
Brief Summary of DAD Functions and Organizations
The two main organizations of OAD applicable to nuclear stations are
System OAD and Project OAD.
System OAD is the overall corporate
organization which oversees Technical Specification activities
performed at CECo nuclear stations by three separate OAD divisions:
the Northern Division, responsible for Zion station; the Rock River
Division, responsible for Quad Cities station and Unit 1 of Byron
station; and the Southern Division, responsible for LaSalle and
Dresden stations.
The functions of Division OAD include testing and
maintenance of electrical protective relays on the 4160 and 480
voltage busses, assisting station staff on electrical work requests
and modifications, and electrical troubleshooting.
Project OAD is a separate organization to System OAD at the Braidwood
station and Unit 2 of Byron station.
The separation is provided to
allow utilization of OAD personnel by these Project sites to perform
certain activities, such as electrical construction testing under the
supervision and management of Projects.
c.
Inspection Summary
The inspectors reviewed OAD activities at all CECo nuclear stations.
Findings varied from one station to another.
DAD activities were
clearly defined and controlled by station administrative procedures
at Zion and Quad Cities.
OAD activities were not as clearly controlled
at.LaSalle, Dresden and Braidwood.
However, the inspection revealed
one deficiency common to all CECo nuclear stations, i.e. training
6
documentation for all OAD personnel did not include the specifics of
training subject matter.
It should be noted that the inspectors found
in most cases, that station Quality Assurance also identified training
documentation as a weakness.
The inspector's findings included several violations and a number of
unresolved and open inspection findings.
Findings are summarized
below:
Station
(1)
Dresden
Dresden
Braidwood
(2)
Dresden
Dresden
(3)
Dresden
Dresden
(4)
Dresden
Dresden
LaSalle
LaSalle
(5)
Dresden
Dresden
LaSalle
LaSalle
Quad Cities
Quad Cities
Zion
Zion
Byron
Byron
Braidwood
(6)
Dresden
Dresden
Finding' Number Comments
237/85038-01
249/85034-01
456/85056-01
237/85038-02
249/85034-02
237/85038-08
249/85034-08
237/85038-05
249/85034-05
373/85040-03
374/85041-03
237/85038-03
249/85034-03
373/85040-01
374/85041-01
254/85031-01
265/85033-01
295/85043-01
304/85044-01
454/85052-01
455/85046-01
456/85056-02
237/85038-04
249/85034-04
7
Approved procedures were not used at
the location where the activities were
performed.
This is a violation of
10 CFR 50, Appendix B, Criterion VI and
is discussed in Paragraph 5.b. and 5.d.
of this report.
As-found test result data was not
recorded.
This is a violation o~
10 CFR 50, Appendix B, Criterion V and
is discussed in Paragraph 5.d. of this
report.
Electrical Construction Test Procedures
(ECTPs) used for construction and
modification testing have not received
an onsite review.
This is in
violation of 10 CFR 50, Appendix B,
Criterion III and CECo Quality
Assurance procedure, QP 3-51.
This
item is discussed in detail in
Paragraph 5.d. of this report.
It was not apparent that OAD personnel
had received training on applicable
station administrative procedures and
revisions.
This is an unresolved item,
and is discussed in Paragraph 4.c. of
this report.
Documentation of OAD training does not
contain supportive evidence of training
subject matter in sufficient detail to
determine training adequacy.
The
licensee's Quality Assurance (QA) group
also identified this weakness at the
Zion, Quad Cities, Braidwood, and
Byron stations.
This is an unresolved
inspection finding and is discussed in
detail in Paragraph 4.b. and 4.c. of
this report.
The inspector was unable to determine
the hierarchy of procedures utilized by
LaSalle
LaSalle
Byron
Byron
Braidwood
(7)
Byron
Byron
Braidwood
(8)
Dresden
Dresden
(9)
LaSalle
LaSalle
(10) LaSa 11 e
LaSalle
(ll) LaSa 11 e
LaSalle
373/85040-02
374/85041-02
454/85052-02
455/85046-02
456/85056-03
454/85052-03
455/85046-03
456/85056-04
237/85038-06
249/85034-06
373/85040-04
374/85041-04
373/85040-06
374/85041-06
373/85040-07
374/85041-07
OAD.
These procedures include System
OAD, Division/Project OAD, CECo QA
Manual, and station administrative
procedures.
This is an unresolved
inspection finding to determine which
procedure takes precedence for
controlling prescribed activities.
This item is discussed in Paragraph
5.b, 5.d and 5.e of this report.
Project OAD at Braidwood and Byron
were not on controlled distribution
for pertinent station administrative
procedures.
This is an unresolved
item, and is discussed in Paragraph
5.b. and 5.c. of this report.
Dresden OAD personnel utilized an
informal hand drawn flow chart as a
supplement to the approved Quality
Assurance procedure for drawing
control.
This is an unresolved
inspection finding until OAD formalizes
the guidance and verifies the adequacy.
This item is discussed in Paragraph 5.d.
of this report.
The inspectors noted that OAD does not
initiate FCRs.
However, OAD
modifications frequently involve
conditions where FCRs may be warranted.
Review of several modifications
performed by OAD to verify that
deficiencies are properly documented
will be performed in subsequent
inspections.
This is an open
inspection item and is discussed in
Paragraph 5.e. of this report.
8
LaSalle is to determine which approved
and reviewed procedure accomplishes
electrical motor meggering.
This is an
unresolved inspection finding and is
discussed in Paragraph 6.c. of this
report.
The inspector was unable to resolve the
requirements for review and approval
signatures on schematic diagrams
utilized by ECN ED-71 prior to completion
of the inspection.
This is an unresolved
inspection finding and is discussed in
Paragraph 6.c. of this report.
(12) Braidwood
(13a) LaSa 11 e
LaSalle
(13b)Dresden
Dresden
(13c)Byron
Byron
Braidwood
(14) Braidwood
456/85056-07
373/85040-05
374/85041-05
237/85038-07
249/85034-07
454/85052-04
455/85046-04
456/85056-05
Certain construction testing activities
were performed with general usage Test
and Measuring Equipment (T&ME).
This
is an open inspection finding and is
discussed in Paragraph 7.b of this
report.
The LaSalle station has committed to
conduct an onsite review of all relay
setting changes to verify adequacy.
Dresden OAD will incorporate original
- re 1 ay settings from the Sargent and
Lundy letter into the current established
method for documenting relay settings
and changes.
System OAD will review relay tolerance
control and define the program for all
stations.
Items 13.a, 13.b and 13.c are unresolved
inspection findings and are discussed
in Paragraphs 8.a, 8.b and 8.c of this
report.
456/85056-06
The Braidwood station had not established
a program delineating the method to
insure that Technical Specifications
requiring protective relay surveillances
will be conducted prior to fuel load.
This is an unresolved inspection
finding until a program is developed.
This finding is discussed in Paragraph
8.d. of this report.
The details of the inspection are contained in the following
paragraphs:
Paragraph 4,
11Training and Certification
11
- Paragraph 5,
11 Procedures 11 ; Paragraph 6,
11 Drawing Control
11
- Paragraph 7,
11Test and
Measuring Equipment Control
11 ; Paragraph 8,
11Setpoint and Tolerance
Control 11 ; Paragraph 9,
11 Interface Between OAD and Plant Organizations.
11
No other violations, deviations, open or unresolved items were
i dent ifi ed.
9
4.
Training and Certification
a.
Summary
Divisional and Project OAD groups at all sites rely on System OAD to
certify OAD personnel.
Certification is accomplished by interviews
and on-the-job (OJT) training with the OAD Lead Engineer.
Certifica-
tion recommendations are submitted by the Lead Engineer to System OAD
for approval.
The Commonwealth Edison Company Operational Analysis
Department's "Electrical Construction Test Procedures" (ECTP), Edition
III, contain the following requirements for the certification levels:
Level III qualifications include:
graduation from a four year
college plus five years of related experience in equivalent
inspection, examination, or testing activities with at least two
years of this experience associated with nuclear facilities or at
least sufficient training to be acquainted with the relevant
quality assurance aspects of a nuclear facility.
Level II qualifications include:
(1) One year satisfactory
performance as a Level I, or (2) High School graduate plus
three years of related testing experience, or (3) An associate
degree in a related discipline plus one-year related testing
experience, or (4) Four year college graduate plus six months
of related testing experience.
Level I qualifications include:
(1) Two years of related
experience in equivalent inspection, examination, or testing
activities, or (2) High School graduation and six months of
related testing experience, or (3) An associate degree in a
related discipline plus three months of related testing
experience.
In addition to certification, OAD personnel are subject to physical
qualification and experience requirements within the specific ECTPs.
OAD personnel receive training, either formal or OJT, on specific ECTP
procedures and are verified to be capable of performing these
procedures by the OAD Lead Engineer by completion of the "Individual
Qualification Table." This table is utilized by OAD to determine
whether an individual OAD engineer can conduct a specific ECTP, such
as No. 9, "Batteries and Chargers," No. 12, "Diesel Generators~' or
No. 17, "Lighting Systems."
The inspectors reviewed the certification and training programs of
onsite OAD organizations to determine compliance with CECo Quality
Assurance Manual, QR 1.0, Paragraph 1.4.6; ANSI 18.7, and
The findings are documented as follows:
b.
Braidwood, Project OAD
The inspectors reviewed several individuals' qualification and
training records _and determined that the certification levels were
as defined in ANSI N45.2.6-1978; however, several findings
regarding training were identified.
10
OAD engineers (OADEs) undergo
11 formal
11 documented training.
This
training consists of a general familiarization with the System OAD
generated Electrical Construction Test Procedures (ECTPs) and the
overall OAD organization.
OADEs are required to read assigned ECTPs
and initial a checklist as having done so.
Training of OADEs is tracked
and documented via station procedure PSU-701, "Qualification and
Training Procedure for Project OAD Personnel at Braidwood,
11 which
contains a matrix of training subjects.
Training documentation, as
required by PSU-701, is periodically reviewed by Braidwood Quality
Assurance and comments regarding any inconsistencies are followed up
per SQI-36; however, review of recent QA findings revealed that
trending of QA identified findings is inconsistent and responses to
QA findings are not timely.
Project OAD at Braidwood, in response to
several QA findings, uses Training Instructions (Tis) which define
some of the duties and methods to be used by OADEs; however, no
evidence that Tis are required reading for OADEs could be found.
This is part of an unresolved inspection finding (456/85056-02) in
that the training documentation does not contain supportive evidence
in sufficient detail to determine the scope of OAD personnel training.
The documentation contains only the subject title and does not address
procedure revisions, implementation, precautions or OJT pertaining to
the subject.
Braidwood Quality Assurance noted this deficiency in
several audits.
Audit QA-20-84-533 conducted between June 5 and 8,
1984, noted that training records produced by Project OAD indicated
that they had received training on the Quality Assurance Manual;
however, the QA audit stated,
11Although it was not clear on the
documented evidence as to what had been covered it was established
in conversations with the QA and Project OAD Supervisors that all
sections were covered.
11
In this case, the detail and scope of the
training was verified not by the documentation alone but was
substantiated only after conversations with supervision.
In addition, the inspectors determined that Tis are considered as
training aids and that should a TI affect work done per an ECTP,
OJT would address the content of the TI.
However, as stated above,
the content and extent of OJT can only be substantiated by conversations
with supervision.
In general, specific guidelines and learning
objectives for OJT are not established and formal training lacks
documented supportive evidence.
These deficiencies are important
since credit is taken for these training activities to determine the
capability of personnel for performing given tasks, such as a
specific ECTP.
Another deficiency was identified by Braidwood Quality Assurance
in Surveillance reports 4470, dated May 14, 1985, and 4856, dated
August 26, 1985.
Both of these surveillances identified several DAD
personnel who had not received training on certain subjects.
Surveillance 4470 noted that ECTP Manual and PSU-701 training had
not been received by all DADEs.
In addition, Surveillance 4856
identified that four new engineers had not received training in the
use of the Test and Measurement Equipment Addendum.
This is an
indication that DAD can not readily track and identify personnel
training status on a specific subject.
Conversations with Project
11
OAD supervision revealed that there was not an established matrix to
track personnel training.
This deficiency is part of the identified
unresolved finding (456/85056-02).
c.
Findings at Byron, Dresden, LaSalle, Quad Cities and Zion
The inspectors reviewed the OAD training and certification records
at stations other than Braidwood and found similar deficiencies in
documentation as discussed in Paragraph 4.b.
At Byron, Quad Cities,
and Zion stations, the Quality Assurance department identified training
documentation weaknesses regarding training subject and scope.
This
was verified by the inspectors.
Similar inadequacies were also
identified at the Dresden and LaSalle stations.
This is an unresolved
inspection finding at LaSalle (373/85040-01 and 374/85041-01), Dresden
(237/85038-03 and 249/85034-03), Quad Cities (254/85031-01 and
265/85033-01), Zion (295/85043-01 and 304/85044-01), and Byron
(454/85052-01 and 455/85046-01).
In addition to the above unresolved inspection finding, the inspectors
noted that a number of OAD personnel had not received training on
applicable station administrative procedures and procedure changes at
the Dresden and LaSalle stations.
The inspectors found that formal periodic training regarding station
administrative procedures or their changes had not been conducted
for either the Dresden or LaSalle onsite OAD personnel.
OAD was not
able to provide objective evidence demonstrating that the appropriate
training had been conducted.
This is an unresolved inspection finding for
Dresden (237/85038-05 and 249/85034-05) and LaSalle (373/85040-03
and 374/85041-03) until a training program is initiated to include
the applicable station administrative procedures.
During the review of OAD training records, the inspectors found that
the majority of onsite OAD organizations had difficulty determining
whether an individual had received training on a given subject.
It
should be noted that this difficulty is attributable to the method
by which OAD retains training documentation without a matrix of
individuals and training subjects.
In most cases, the training
documentation. consists of copies -of the attendance of a given
training session maintained in the individual personnel training file.
However, the inspector found that the Rock River Division OAD had an
effective computer program that identified which OAD personnel at
Quad Cities and Byron had received which training.
The inspector found that this program was effective for determining
which individuals require annual retraining.
The inspector also
noted that the Rock River Division OAD was actively pursuing
improvements in training documentation detail and content in
cooperation with the stations* Quality Assurance and onsite OAD
organizations.
These improvements are commendable and good examples
of organizations cooperating to improve the quality of the program .
No other violations, deviations, unresolved or open items were identified.
12
5.
Procedures
a.
Summary
In general, OAD personnel use several different procedures to
accomplish their assigned tasks.
Construction activities are
conducted using either System OAD generated ECTPs or site specific
ECTPs.
OAD activities at an operational station can be conducted
using onsite OAD specific procedures, OAD Division generated
procedures, station administrative procedures or individual station
departmental procedures, i.e. Maintenance, Operations, etc.
In
addition, the CECo Quality Assurance Manual authorizes the use of QA
procedures.
Because of the lack of a clear hierarchy of procedures,
the inspectors were unable to identify the controlling or governing
procedure to be used by OAD personnel to perform assigned tasks.
This
resulted in unresolved inspection findings at Dresden (237/85038-04
and 249/85034-04), LaSalle (373/85040-02 and 374/85041-02), Byron
(454/85052-02 and 455/85046-02) and Braidwood (456/85056-03). The
inspectors also noted that:
(1) Approved procedures were not used at the locations where the
activities were performed - resulting in violations at Dresden
(237/85038-01 and 249/85034-01, addressed in Paragraph 5.d) and
Braidwood (456/85056-01, addressed in Paragraph 5.b.).
(2)
Required
11 as-found
11 test result data was not recorded by
Dresden OAD personnel, resulting in a violation (237/85038-02
and 249/85034-02, addressed in Paragraph 5.d.).
(3)
Various applicable station administrative procedures were not
available to Project OAD personnei and resulted in an
unresolved inspection item at Braidwood (456/85056-04 discussed
in detail in Paragraph 5.b.) and Byron (454/85052-03 and
455/85046-03 as discussed in detail in Paragraph 5.c.).
(4)
Dresden .OAD personnel utilized an informal hand drawn flow
chart for guidance in following the approved Quality Assurance
Manual Procedure.
This unresolved inspection finding
(237/85038-06 and 249/85034-06) is discussed in detail in
Paragraph 5. d.
b.
Braidwood
CECo OAD Electrical Construction Test procedures (ECTPs), Edition III,
issued to the Braidwood Project OAD (POAD) Engineer, consist of a
number of preliminary and construction tests used to inspect and
test specific electrical equipment prior to preoperational testing.
Test results are documented on the specific ECTP forms.
The
inspector reviewed ECTP 1,
11Motors
11 , in depth.
ECTP 1 is used to assure that electrical motors have been properly
installed and are ready for preoperational testing.
ECTP 1 was
reviewed for appropriate acceptance criteria, test data records and
requirements; Quality Assurance and Quality Control review; and
deficiency documentation.
Some of the parameters recorded per the
13
ECTP are:
insulation *resistance, continuity, grounding, and motor
rotation.
The OAD engineer is also responsible for determining the
breaker trip setting and overload sizing.
The ECTPs, in general,
have no associated acceptance criteria, therefore, recorded
parameters are used as baseline or information only data.
It was
noted that construction test data is handled differently at
Braidwood than at Byron.
Byron POAD attaches all of the electrical
test data to the turnover package for transmittal to the appropriate
Startup engineer.
Braidwood POAD includes only a test summary with
the turnover package; however, electrical test data is available
to the startup engineer on a request only basis.
Although it is not
clear why electrical test data transmittals are handled differently
by the two POAD organizations, the use of such data at Braidwood
appeared to be consistent with the station administrative procedures
governing turnover packages.
The inspector noted that difficulties
encountered during testing are not routinely communicated to the
appropriate startup engineer.
Discussions with the POAD Engineer
indicated some confusion regarding the hierarchy of procedures
associated with electrical construction testing.
Braidwood POAD has both System OAD generated ECTPs and Braidwood
Specific Construction Test Procedures.
Use of the appropriate
procedure is assured by placing copies of those procedures to be used
in a locked file cabinet; that is for a given test, if a Braidwood
specific test procedure is to be used, a copy of the Braidwood test
procedure, instead of the System OAD ECTP, is kept in the file.
OADEs
are instructed to obtain test data forms from the file cabinet and
the lead OADE is responsible for ensuring that only the appropriate
form is kept in the file.
This procedure and delineation of
responsibilities are not described in any administrative procedure or
guideline generated by either Braidwood station or POAD.
In addition,
due to the confusion regarding the governing procedure, guidance for
use of general use instruments for equipment testing as opposed to
certified instruments is not clear.
The inspector noted that certified
instruments are routinely used for OAD testing at operational sites,
primarily due to requirements of both station administrative procedures
and the Quality Assurance Manual.
Determination of procedure hierarchy and clarification of the
relationship between Quality Assurance Manual requirements and OAD
testing requirements is considered to be an unresolved item
(456/85056-03).
.
During the review of applicable procedures utilized at Braidwood the
following additional findings were also identified:
(1)
Project OAD uses unique approved Braidwood specific procedures
which include instructions for Test and Measurement Equipment
(T&ME) usage.
T&ME discrepancies are also addressed.
OAD
personnel had received training on the procedures on January 11,
1985.
Although a Braidwood specific procedure exists for the
purpose of handling test instrument discrepancies with clear
requirements to perform an evaluation of test data taken with a
14
failed instrument, the inspector found that Project OAD
personnel were using a handwritten, unapproved and uncontrolled
guideline instead of the approved procedure at the location
where the activities were performed.
This is a violation
(456/85056-01) of 10 CFR 50, Appendix B, Criterion V.
(2)
Braidwood OAD is required to process work activities in accordance
with station administrative procedures; however, Project OAD is
not on controlled distribution for administrative procedures
c.
Byron
and is not routinely made aware of all the administrative
requirements or changes that are imposed upon OAD.
Review of
training records revealed that OAD had continued to train
personnel on BWAP 300-5,
11 Electrical Jumpers, Relay Blocks and
Lifted Lead Tags,
11 for over a year after the procedure had been
deleted.
Review of Braidwood administrative procedure
requirements against DAD practices did not reveal any major
violations of updated administrative requirements; however,
Project DAD acknowledged that they were unaware of the updated
requirements.
This is an unresolved inspection finding
(456/85D56-04) until Project DAD is on a controlled distribution
for station administrative procedures and all applicable station
administrative procedures are determined.
The inspector's review of onsite DAD revealed two findings as
follows:
Byron onsite DAD has initiated, but not completed, appropriate
corrective actions in reaction to the Braidwood unresolved inspection
finding (456/85D56-D4).
This finding addressed the concern that
Project DAD was not on controlled distribution for applicable station
administrative procedures.
Currently Byron Projects has jurisdiction
over activities at Byron Unit 2, while Byron Unit 1 activities are
controlled by Byron Plant Staff.
Project DAD currently performs
certain Divisional DAD activities, such as Technical Specification
surveillances, per station procedures and control at Byron Unit 1
while construction activities at Unit 2 are performed under Project's
- jurisdiction.
Because each unit is controlled differently, it is
important that Project DAD fully understand and implement the most
recent appli~ab]e station administrative procedures and requirements.
This can easily be accomplished by placing DAD on controlled
distribution for all applicable procedures.
Until this activity is
completed, this is an unresolved inspection finding (454/85D52-D3
and 455/85D46-D3).
Because of the similarity of this item to the
Braidwood finding (456/85D56-04), these unresolved items are grouped
together.
In addition, the inspector also experienced difficulty in determining
the hierarchy of procedures used by Byron Project DAD to perform
assigned tasks.
This finding is similar to that identified at
Braidwood (456/85056-D3) and therefore ~s an unresolved finding
(454/85052-02 and 455/85D46-D2).
15
, ..
d.
Dresden
Dresden OAD is on controlled distribution for administrative
procedures; however, no retraining on revised station procedures is
conducted, as discussed in Paragraph 4.c of this report.
OAD is
required to perform work within the bounds established by Dresden
procedures OAP 15-1,
11Work Requests,
11 and OAP 5-1,
11 Plant Modifica-
tion Program,
11 as well as the CECo Quality Assurance Manual.
Unlike
Braidwood, Dresden does not have Dresden specific test procedures or
office guidelines; however, additional guidance and supplemental
test procedures are provided by Southern Division OAD (SDOAD).
Station OAD stated that the SDOAD manual is used as a reference and
not considered a requirement.
No specific guidance could be found
regarding actions to be taken should test data fall outside given
tolerances.
In addition, no hierarchy of procedures was defined.
This is also part of the unresolved finding to determine the hierarchy
of procedures utilized by OAD (237/85038-04 and 249/85034-04).
Review of Dresden OAD practices indicated that an informal, hand
drawn flow chart was being used to delineate the method used for
drawing update and control by OADEs.
DAD personnel indicated that
this flow chart was considered as guidance; however, a correlation
against the requirements delineated in the CECo Quality Assurance
Manual had not been performed.
OAD personnel indicated that the
guidance provided in the flow chart and the requirements of the
Quality Assurance Manual would be compared for consistency, and will
either delete or formalize the guidance given in the flow chart
based on the results of the comparison.
Determination of the
adequacy of the guidelines delineated in the flow chart when compared
to the CECo Quality Assurance Manual is considered to be an
unresolved item (237/85038-06 and 249/85034-06).
Review of completed work request package D-38044 revealed that OAD
had used protective relay test procedures which predate the test
procedures found in the SDOAD manual.
Members of SDOAD stated that
the SDOAD test procedures were the ones to be used for all protective
relay testing within the SDOAD.
This is a violation of 10 CFR 50,
Appendix B, Criterion VI (237/85038-01 and 249/85034-01) in that the
approved procedures contained within the SDOAD Manual were not used
at the location where the prescribed activity was performed.
Instead,
an outdated revision was used.
Additionally, the inspector
1 s review of work request D-27654 which
addresses the ongoing effort to install the new bus duct for the
Unit 2/3 diesel generator revealed that although referenced in the
Maintenance/Modification Procedure (MMP) and on the work traveler,
there is no objective evidence that the ECTPs used for construction/
modification testing have received an onsite review.
Quality
Procedure 3-51, pages 12 and 13, state that test procedures associated
with safety-related work must be reviewed by the onsite review
committee prior to MMP approval .
16
.. *
e.
CECo Quality Procedure 3-51, states that Maintenance/Modification
Procedures (MMP) for safety-related work shall be approved only if
procedures referenced in the MMP have been approved by an onsite
review.
Discussions with members of plant management revealed that
no onsite review of the Electrical Construction Test Procedures had
ever been performed.
In addition, OAD personnel indicated that they
were unaware of the review requirements for procedures associated
with Maintenance/Modification work packages delineated in the
Quality Assurance Manual.
Failure to perform maintenance and
modification activities with appropriately reviewed and approved
procedures is considered to be a violation (237/85038-08 and
249/85034-08) of 10 CFR 50, Appendix B, Criterion III as implemented
by the licensee's Quality Procedure 3-51.
Review of Dresden OAD test data for periodic testing of protective
relays revealed that OAD did not record as-found relay data.
The
inspector noted that due to the lack of as-found data, trending or
identification of those relays which repeatedly drifted away from
their required settings was impossible.
Failure to record the
as-found data was primarily due to the fact that Dresden OAD was not
using the SDOAD approved procedures which required recording the
as-found data.
Discussions with plant management indicated that
they assumed that OAD was responsible for trending relay test data.
Further investigation revealed that trending of relay test data was
not performed by either Dresden OAD or SDOAD.
10 CFR 50, Appendix
B, Criterion XVI, requires that measures be established to promptly
identify malfunctions and deficiencies which are adverse to
quality.
Trending of test data is one method used to identify
recurring deficiencies which although not significant for a single
instance, may be indicative of equipment deterioration.
Failure to
record as-found relay testing data and trend test results is
considered to be a violation (237/85038-02 and 249/85034-02) of
10 CFR 50, Appendix B, Criterion V in that no quantitative or
qualitative as-found data was recorded and, hence, the requirements
of 10 CFR 50, Appendix B, Criterion XVI could not be met either.
LaSalle
Discussions with the LaSalle OAD lead engineer indicated that routine
maintenance testing was performed using a copy of the Dresden Routine
Electrical Test Procedures, which were generated by Southern Division
OAD.
Construction and modification testing; however, was performed
using the System OAD generated ECTPs and applicable station procedures.
As stated earlier in this report, acceptance criteria for test data
are not established in the ECTPs.
Deficiencies noted during testing are
documented by Field Change Requests (FCR) which are typically generated
by station Technical Staff engineers.
Information obtained during OAD
testing is transmitted verbally to a member of the Technical Staff who,
in turn, initiates an FCR.
It is not clear that the method of
notifying the Technical Staff of test deficiencies and anomalies
ensures that identification of all deficiencies or deviations and
appropriate evaluations of specific electrical problems are addressed .
The adequacy of this method of tracking identified discrepancies is
17
considered an open item pending further review by the inspector
(373/85040-04 and 374/85041-04).
In addition, no hierarchy of
procedures was defined.
This is also part of the unresolved finding
to determine the hierarchy of procedures utilized by OAD
(373/85040-02 and 374/85041-02).
f.
Quad Cities and Zion
The inspector found the procedures and procedure control at
both the Quad Cities and Zion stations to be adequate and no
findings were identified.
Both stations either incorporated OAD
procedures into the station administrative procedures (QAPs and
ZAPs) or controlled their review and approval under applicable QAPs
and ZAPs or both.
The procedures used by OAD at both stations are
onsite reviewed and approved.
The inspector found that at both
stations these controls were initiated by Quality Assurance and
station management and were effectively implemented by both the onsite
OAD, and Rock River and Northern Division OAD.
No other violations, deviations, unresolved or open items were identified.
6.
Drawing and Document Control
a.
Summary
The inspector reviewed OAD drawing and document control practices
for compliance with the CECo Quality Assurance Manual and 10 CFR 50,
Appendix B.
Two unresolved items were identified as noted below.
A
detailed discussion of these items is found in Paragraph 6.c.
1.
The inspector was unable to identify a procedure at LaSalle
addressing the methods used to accomplish meggering test
activities required by ECTP 1.
(373/85040-06 and 374/85041-06)
2.
The requirements and responsibilities for the review and
approval of ~chematic diagrams at LaSalle per ECN ED-71 are not
clearly defined.
(373/85040-07 and 374/85041-07)
In general, drawing and document controls appeared adequate.
Additional concerns are discussed by site below.
b.
Braidwood
As previously stated, electrical construction testing is performed
via either system OAD generated ECTPs or Braidwood specific OAD test
procedures.
For those cases where the specific equipment does not
perform as indicated on the schematic, verbal direction to manipulate
the wiring as necessary to agree with the schematic is given by the
OADE to the electrician.
Wiring changes are then noted by the OADE
on the drawings kept in the POAD office and transmitted to the
appropriate engineering group by onsite Sargent and Lundy personnel.
Sargent and Lundy is responsible for initiating, tracking, reviewing,
approving, and updating any wiring drawing changes.
Although review
18
'.
indicated that each OADE notes pending drawing changes and system
test status in a different manner, no major deviations were identified
during the inspection.
c.
LaSalle
The inspector noted that the ECTPs utilized for post modification
testing by onsite OAD do not receive onsite review and approval.
The
inspector was informed that routine maintenance testing performed by
OAD using ECTPs is not the final test and as such, ECTPs do not require
approval.
The licensee stated that the Technical Staff performed tests
using approved procedures to reverify the parameters measured by the
OAD tests; therefore, the OAD tests are not final or a quality
activity requiring approval and review.
The inspector noted that the
meggering test performed on electrical motors by ECTP 1 does not appear
to be reperformed by an approved quality station procedure.
The
meggering test performed by ECTP 1 verifies the quality of installation
of an electrical motor, and since no other procedure apparently tests
this parameter, this issue will be considered an unresolved inspection
finding (373/85040-06 and 374/85041-06) until the licensee can
determine that an approved and reviewed procedure accomplishes this
activity.
The inspector also reviewed work request 20782 and associated
modifications 1-0-82-132 and 1-0-83-026.
In addition, the inspector
reviewed the Engineering Change Notice (ECN) ED-71.
The inspector
noted that the schematic diagrams used by the OAD engineer to perform
post modification testing as indicated on diagrams 1E-0-4412AS,
Revision Al, and 1E-l-4681AB, Revision Al did not contain the
appropriate engineering review and approval signatures.
The inspector
was unable to resolve the requirements for the review and approval
prior to the completion of the inspection.
This issue will be an
unresolved inspection finding (373/85040-07 and 374/85041-07) until
the inspector can complete the review during subsequent inspections.
No other violations, deviations, unresolved or open items, were
i dent i fi ed.
7.
Test and Measuring Equipment Control
a.
Summary
The inspectors reviewed the control and use of test and measuring
equipment (T&ME) by onsite OAD for compliance with the CECo Quality
Assurance Manual and applicable station administrative procedures.
Noted below are the inspector 1s findings at the Braidwood and LaSalle
stations.
These findings were similar to the results of inspections
at the other stations.
In general, it appears that at most of the
stations, T&ME is adequately controlled by procedures or effective
Quality Assurance audits or both.
One example of an effective audit,
is audit QAA-01-85-68 at the LaSalle Station.
The audit identified
several deficiencies including:
19
- '
"
..
(1)
Instruments were identified where the Instrument Checkout Log
noted usage against.a work request, but the instrument was not
recorded on the work request as being used.
(2) Several instruments were documented on a work request without
the associated documentation in the Instrument Checkout Log.
These deficiencies identified conditions where tracing an out of
tolerance instrument may be difficult because of the inconsistency
of documenting instrument usage.
The corrective actions to resolve
these Quality Assurance findings had not been completed by the
completion of this inspection and consequently, not verified by the
inspector.
However, this audit is considered an effective audit and
demonstrates intent to comply with the requirements.
b.
Braidwood
Control of portable test and measurement equipment is delineated in
Braidwood administrative procedure BWAP 400-2, Revision 2.
Review of
the Braidwood OAD Test and Measurement Equipment file indicated that
Test Instrument Discrepancy Reports have been used to evaluate the
impact of out of tolerance instruments appropriately.
During a previous inspection, the inspector reviewed LaSalle Station
Quality Assurance audit QAA-01-85-68, dated December 9, 1985, which
addressed calibrated instrument control.
The audit findings indicated
that calibrated instruments used for safety work were verified
acceptably tagged, and calibrated; however, the use of these instru-
ments could not always be tracked to the Work Requests indicated by
the OAD Instrument Checkout Log.
The inspector reviewed the LaSalle Station Instrument Checkout Log and
noted that at LaSalle, OAD engineers use certified instruments to
measure motor running amps, whereas at Braidwood, general use
instruments are used to monitor this function.
However, at Braidwood
this function may not have involved acceptance or permanent data and
hence would be acceptable.
This issue needs further investigation and
is considered an open item (456/85056-07) for Braidwood.
No other violations, deviations, unresolved or open items were identified.
8.
Setpoint and Tolerance Control
The inspectors reviewed the.practices and methods used for periodic
required testing of protective relays, specifically setpoint and tolerance
control for compliance with applicable IEEE standaras, Technical
Specifications and the requirements of 10 CFR 50, Appendix B.
It was
discovered that guidelines regarding tolerances for specific relays were
located in as many as four different sources.
At Dresden, tolerances,
regardless of the source, had not been verified to agree with original
settings.
Relay tolerance guidelines were found in individual vendor
manuals, station procedures for Technical Specification required relays,
the System OAD generated Field Reference Manual, and guidelines issued from
20
the SDOAD office.
Although the tolerances were not widely divergent,
they were in several cases different.
The findings identified in this
area are discussed by responsible organization:
a.
System OAD
For all stations with the exception of Quad Cities and Zion, the
inspectors were unable to determine the governing document for
determining the correct tolerances for given protective relays.
Definition of specific allowable tolerances for relays are necessary
to facilitate trend analysis and relay setting consistency.
Determination of one relay tolerance governing document is considered
an unresolved item for the following stations:
LaSalle
Dresden
Byron
Braidwood
b.
LaSalle
(373/85040-05; 374/85041-05)
(237/85038-07; 249/85034-07)
(454/85052-04; 455/85046-04)
(456/85056-05)
Station OAD committed to conduct an onsite review to verify the
adequacy of all protective relay setting changes.
This is an
unresolved item (373/85040-05 and 374/85041-05) pending completion
of the review and subsequent inspection.
c.
Dresden
Station OAD will define and establish the original relay settings
contained in a 1969 letter from Sargent and Lundy and factor these
settings into the established method for documenting and tracking
protective relay settings.
This is an unresolved item (237/85038-07
and 249/85034-07).
d.
Braidwood Project
Review of the prospective relay testing conducted by Braidwood POAD
indicated that Braidwood Project had not established a program to
ensure that initial protective relay testing required by Technical
Specifications would be accomplished in an organized and timely manner
prior to fuel load.
It was not clear to the inspectors, whether
initial testing of such relays would be accomplished by the preopera-
tional testing program and to what extent the test results would be
reviewed and approved.
Establishing a method to insure the timely
performance of protective relay testing and definition of review
requirements at Braidwood is considered to be an unresolved item
(456/85056-06).
No other violations, deviations, unresolved or open items were identified.
21
9.
Interface Between OAD and Plant Organizations
The inspectors reviewed the stations
1 administrative, Quality Control and
CECo Quality Assurance programs for required interfacing with onsite OAD
to ensure that OAD personnel were required to receive onsite training,
and respond to Quality Assurance audits and Quality Control surveillances.
In general, the inspectors found that OAD personnel at the Quad Cities
and Zion stations were fully responsive to station administrative
requirements.
Also, the inspectors found that Quality Assurance and Quality
Control departments had performed numerous audits and surveillances with
various findings that had resulted in changes in OAD programs at Braidwood,
Byron, Quad Cities, and Zion.
This indicates an effective quality program
and responsive OAD organizations.
However, some of the Braidwood responses
appeared to be untimely, such as the example discussed in Paragraph 4.b of
this report.
Interfacing between Quality Assurance and DAD has been extremely effective
at the Quad Cities and Zion stations where the DAD organizations are fully
responsive to the station
1s administrative programs and are participants
in the station 1s planning meetings, including the daily operating and
outage status meetings.
In contrast, the Braidwood Project DAD personnel do not routinely
participate in all of the status and planning meetings conducted by
Projects, which are utilized for scheduling, planning, and status of
testing activities at Braidwood.
After the completion of the inspection,
however, the NRC Senior Resident Inspector notified the inspectors that
Project DAD was now routinely participating at these meetings.
The
inspectors find this to be an improvement and adequate correction for the
deficiency.
No violation, deviations, open or unresolved items were identified.
10.
Open Items
Open items are matters which have been discussed with the licensee, which
will be reviewed further by the inspector, and which involve some action
.on the part of the NRC or licensee or both.
Open items disclosed during
the inspection are discussed in Paragraphs 5.e, and 7.b.
11.
Unresolved Items
Unresolved items are matters about which more information is required in
order to ascertain whether they are acceptable items, items of violation,
or deviations.
Unresolved items disclosed during the inspection are
discussed in Paragraphs 4.b, 4.c, 5.b, 5.c, 5.d, 5.e, 6.c, 8.a, 8.b, 8.c,
and 8.d.
22
r--
1
I
...
.. . '
"7.
12.
Exit Interview
The inspectors met with licensee representatives (denoted in Paragraph 1)
for a final exit on March 18, 1986.
The inspectors summarized the scope
and findings of the inspection.
The licensee acknowledged the statements
made by the inspectors with respect to the open and unresolved items and
the violations denoted in paragraphs 5.b. and 5.d.
The inspectors also
discussed the likely informational content of the inspection report with
regard to documents or processes reviewed by the inspectors during the
inspection.
The licensee did not identify any such documents/processes as
proprietary.
The licensee acknowledged the statements made by the
inspectors with respect to the findings.
23