ML20090M766

Responds to NRC Re Violations Noted in IE Insp Repts 50-456/83-17 & 50-457/83-16.Corrective actions:safety- Related Battery Banks Turned Over to Station Operations for Maint & Surveillance Activities

ML20090M766
Person / Time
Site:	Braidwood
Issue date:	04/09/1984
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20090M746	List: ML20090M753 ML20090M766
References
8420N, NUDOCS 8405290171
Download: ML20090M766 (14)

Text

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j Commonwealth Edison 1 One First National Plan. Chic;go. Hhnois j-Address Reply to. Post Office Box 767 g4 Chicago, Illinois 60690 April 9, 1984 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Braidwood Station Units 1 and 2 s

Response to IE Inspection Report 50-456/83-17 and 50-457/83-16 NRC Docket Nos. 50-456/457 References (a):

R. C. Knop letter to Cordell Reed dated February 3, 1984 (b):

E. D. Swartz letter to J. G. Keppler dated February 28, 1984

Dear Mr. Keppler:

Reference (a) provided the Commonwealth Edison Company with the results of an inspection conducted by Mr. L. G. McGregor of your of fice during the period of October 3 through December 16, 1983, of activities at our Braidwood Station.

During that inspection, certain activities appeared to be in non-compliance with NRC requirements.

The Attachment to this letter provides the Commonwealth Edison Company response to the Notice of Violation as appended to Reference (a).

Our delay in submittal of this thirty day response was discussed cith Messrs. R. C. Knop and D. W. Hayes of your office on separate occasions, and we appreciate having been given additional time to respond in this matter.

Our response to the item of non-compliance addresses each of the six examples cited in Reference (a).

Our review of each of the Region's concerns did not reveal any adverse impact on the safety-related battery installations at Braidwood Station.

Additionally, as requested in Reference (a), Reference (b) provided the Commonwealth Edison Company response to the woven wire fence issue for both Byron and Braidwood Stations.

It is our belief that cxisting designs adequately address ventilation, hydrogen control, and fire protection requirements as accepted by NRR.

0405290171 840522 PDR ADOCK 05000456 0

PDH

.a J. G. Keppler 2-April 9, 1984 Please address any questions that you or your staff may have concerning this matter to this office.

Very truly yours,

- ::_mp Dennis L. Farrar Director of Nuclear Licensing EOS/lm Attachment cc:

RIII Inspector - Braidwood

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JATTACHMENT 4

COMMONWEALTH EDISON COMPANY RESPONSE TO NOTICE OF VIOLATION i

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VIOLATION i

10 CFR 50, Appendix B, Criterion II requires holders of construction 4

permits for nuclear power plants to document by. written. policies, procedures, or instructions, a quality assurance program which complies j

with the requirements of. Appendix B for all activities affecting the quality of safety-related structures, ith those documents. systems, and components and to i

implement that program in accordance w l'

I Contrary to the above, Commonwealth Edison Company did not adequately document and implement a quality a?surance program to comply with the i

requirements of Appendix 8 as evidenced by the following examples:

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EXAMPLE 1 i

10 CFR 50, Appendix B, Criterion.V requires in part:

" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the. circumstances, and j

shall be accomplished in accordance.with these instructions, procedures or drawings."

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Commonwealth Edison Company.(CECO) Quality Assurance Manual,-Quality 1

Requirement No. 5.0 (QR 5.0) states in part:

"The quality assurance actions carried out for design, construction, testing'and operation i

activities will be described in documented. instructions, procedures, i

drawings, specifications, or checklists...".

The CECO Quality Assurance Manual, Quality Procedure No. 5-1 (QP-5.1) implements'this requirement.-

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Contrary to the above, Station approved-procedures for the installation, maintenance and surveillance of the station safety related battery banks (No.'s 111, 112,.211 and 212) did not exist.until October.1981, when Station Procedure BWOS-PC-02 was approved.

This procedure was not implemented until January 1982, however the station batteries were

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" turned.over" to the Stations Operations Department"on May 14, 1981.-

i Further,.no maintenance or surveillance procedures.were' developed by the t

' installation contractor,;L.!K.'Comstock.

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Procedures for battery maintenance and surveillance were indeterminate i

until March 17, 1983 when an internel memorandum was written to L. K.

I Comstock Qual'ity. Assurance Department stating:

"The following battery

. groups are under the direction of OAD" (Operational Analysis' Department, a CECO Electrical Construction-test lsection), "and have been relieved from L. K. Comstock Quality. Control maintenance inspection since the j

associated dates, Battery 111, 112,-211 and 212 sinceLDecember, 1979."=

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. RESPONSE TO EXAMPLE 1 The Commonwealth Edison Company agrees that inconsistencies existed in the station development, approval, and implementation dates for procedures concerning the safety-related battery banks.

While instal-lation procedures existed and were used, maintenance and surveillance procedures were not organized and approved in a systematic manner.

However, it should be noted that certain maintenance and surveillance activities were performed, and that no actual hardware problems were identified in the field as a result of the inconsistencies.

Battery installation was the responsibility of the L. K. Comstock Company, and they developed installation procedures in accordance with the manufacturer's approved drawings (DC Storage Battery and Battery Installation, Procedure 4.3.4).

These procedures were reviewed and approved by the Commonwealth Edison Company and were used by L. K.

Comstock to install and verify the battery banks.

Since 1979 when the batteries first arrived on site, the Commonwealth Edison Company Operational Analysis Department had responsibility for the battery maintenance and surveillance.

These activities, performed in the field by L. K.

Comstock electricians under the direction of OAD, were accomplished pursuant to OAD Procedure No. 9 (Electric Construction Test Procedure DC Battery and Battery Charger).

As noted in our discussion of other Examples cited under this violation, this procedure was not always followed in a consistent manner.

However, OAD documentation exists to demonstrate that the procedure was employed.

As such, it was not the L. K.

Comstock responsibility to develop maintenance and surveillance procedures.

In addition to our Operational Analysis Department maintenance and surveillance inspections, the Commonwealth Edison Company Station Operating Department and the battery manufacturer (Gould Incorporated) performed maintenance and surveillance inspections.

Station Operating began battery inspections as carly as August 1981, even though the station procedure was not yet approved.

As early as October 1979, a representative from Gould Incorporated performed inspections on the batteries.

A recent inspection report from Gould Incorporated states, in part, that the battery cells are in good l

condition.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED, AND CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER NONCOMPLIANCE The Commonwealth Edison Company Project Construction Department has turned all safety related battery banks over to Station Operating for maintenance and surveillance activities.

Station Procedure BWOS-PC-02 was approved in October 1981, and is currently in effect to provide direction when performing battery maintenance.

Assurance of procedure implementation will be documented on an ongoing basis through audits and surveillances performed by Station Quality Assurance.

DATE OF FULL COMPLIANCE Full compliance has been achieved.

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EXAMPLE 2 j

"A program for i

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10.CFR 50, Appendix B, Criterion X requires in part:

F inspection of activities affecting quality shall be established and

.oxecuted by or for the organization. performing the activities to verify conformance-with the documented instructions, procedures, and drawings for accomplishing the activity."

The Commonwealth Edison Company Quality Assurance Manual, QR No. 10.0, paragraph 10.2 states.in part:

" Inspection and test plans shall be prepared'by respective contractors, vendors or organizations having responsibility for the. item (s) involved, either as a separate docu.nent identified ~with the parts', components or assemblies; or as an integral j

part of work instruction and procedure' documents.. Inspection and test plans shall consist of a flow chart, diagram or narrative description of the sequence of procurement, fabrication, processing, assembly, inspection and test activities and shall specify the inspection points.

l The inspection and test plan shall provide testing requirements, the i

characteristic to be measured, the inspection and test procedure and the applicable acceptance criteria."

.The Commonwealth Edison Company Quality Assurance Manual, QP 10-1 implements this requirement.

l Contrary to the above, a battery inspection program was not develured to j

verify the proper surveillance and installation of the battery banks.

No records exist indicating that process sheets or other documentation were i

used or reviewed by Commonwealth Edison Company Quality Assurance or the contractors quality control department during the movement, surveillance, l

maintenance and installation of the safety-related battery banks for Units 1 and 2.

However, OAD did perform monthly and quarterly surveil -

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lance on the batteries during'the period of December, 1979 through May.14, j

1982.

The procedure used during this period, Surveillance. Procedure 4.0, l

was not approved by Site Quality Assurance.

Further.the procedure was not adequate to perform the surveillance and requirements, as stated by j

the bettery manufacturer.

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h RESPONSE TO EXAMPLE ' 2 j

Commonwealth Edison had established a program for the. installation snd surveillance of battery banks but:as.the Example points out, the 4

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program did not at~all times adequately record all the aspects of j

battery surveillance.

As the discussion in our response to Example 1 indicates, there was i

an approved installation procedure pursuant to which the batteries i

'were installed. 'This L. K.'Comstock-installation Procedure 4.3.4 was supplemented'by a variety'of approved construction procedures involving'among other things, welding, concrete expansion anchor

' installation, and the use of calibrated: wrenches.

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-4 The surveillance program was accomplished pursuant to Operational Analysis Department Procedure No. 9 (Section 4.0 of which relates to surveillance procedures).

Because this is an OAD procedure, under Company practice it had to be approved by Commonwealth Edison Corporate Quality Assurance, and in fact was.

Braidwood Site Quality Assurance does not have the responsibility for review and approval of OAD procedures.

Commonwealth Edison believes that all the activities necessary to ascertain that the batteries would properly function were performed.

However, Commonwealth Edison acknowledges thet the procedure was inadequate in that it did not require the recording of certain information as recommended by the battery manufacturer.

Documentation exists for the installation, surveillance and maintenance activities performed with regard to the battery banks.

Commonwealth Edison agrees that the movement of the battery banks was not documented.

However, the movement was witnessed and accomplished pursuant to L. K. Comstock Procedure 4.10.1.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED, AND CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER NONCOMPLIANCE The Commonwealth Edison Company Project Construction Department has turned all safety related battery banks over to Station Operating for maintenance and surveillance activities.

Station Procedure BWOS-PC-02 was approved in October 1981 and is currently in effect to provide direction when performing battery maintenance.

Assurance of procedure implementation will be documented on an ongoing basir through audits and surveillances performed by Station Quality Assurance.

DATE OF FULL COMPLIANCE Full compliance has been achieved.

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, EXAMPLE 3 10 CFR 50, Appendix B, Criterion XIII requires in part:

" Measures shall be established to control the handling, storage, shipping, cleaning and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration."

Commonwealth Edison Company Quality Assurance Manual, QR No. 13-1, paragraph 4.2 states in part:

"On-site contractors will perform the caterial and equipment unloading based on approved procedures (Ref. QP 5-1) or instructions.

On-site contractors are required to provide approved facilities, handling equipment, procedures and personnel to receive, store, inspect, document and control the material and equipment chen it arrives on site.

On-site contractor procedures shall provide:

a.

Methods for identifying and marking material and equipment.

b.

Control of records and documentation.

c.

Type of storage provided, d.

Maintenance or adherence to manufacturer's special instructions for equipment in storage or equipment stored in place.

e.

Controls to assure that material is used only as specified or intended.

f.

Periodic inspections and surveillance for stored equipment.

Contrary to the above, a program for handling, storage, cleaning and preservation of safety-related station battery banks in accordance with inspection instructions, procedures, maintenance and surveillance requirements was not established or implemented.

RESPONSE TO EXAMPLE 3 As acknowledged in our response to Example 2, the Commonwealth Edison Company program for the surveillance and maintenance of the batteries did not completely address all the measures necessary for the maintenance of the betteries, although Commonwealth Edison does believe that the program for handling and storage was adequate under its procedures.

L. K. Comstock was the on-site contractor responsible for the handling (movement) and the storage (receipt) of the batteries and approved procedures (L. K. Comstock Procedures A.10.1 and 4.10.2) were developed to control these activities.

Batteries were received in accordance with the requirements of Commonwealth Edison Company Quality Assurance Manual Q.P. No. 7-1, and a check for shipping damage was performed.

. l The results of this check were documented on Commonwealth Edison l

Company MRR Numbers 5281 and 5285.

L. K. Comstock Procedure 4.10.2 (Receiving and Storage) Paragraphs 3.1.2 and 3 1.3 describe their responsibilities with respect to Receipt Inspections.

In addition to the L.K. Comstock Procedure 4.10.2, the Commonwealth Edison Company Project Construction Department Procedure BG-3 (Receipt and Inspection) describes a program to assure items (a) through (f) listed in the Example are provided for.

The Commonwealth Edison Company Operational Analysis Department had

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responsibility for the maintenance (storage and cleaning) activities.

These Operational Analysis Department activities were directed by their Electrical Construction Test Procedure No. 9.

Upon battery receipt, it was determined that certain manufacturer's recommendations were to be monitored.

The following are examples of I

these considerations which were included. in the procedure:

Manufacturer recommends:

Indoor storage, in a cool (600F - 900F) clean, dry location.

Commonwealth Edison Company provided:

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Storage in an unused electrical switching building that is provided with heat and ventilation.

Manufacturer recommends:

An initial charge within six (6) months of the date of shipment; repeat this charge once every six (6) months.

Commonwealth Edison Company provided:

An initial charge ninety (90) days after delivery; I

connection to a-constant voltage charger; monthly surveillances of pilot cell voltage and specific gravity; battery terminal cleaning per manufacturer recommendations.

However, as noted in our response to Example 2, the surveillance measures were inadequate in that they did not provide for the recording of the amount of water added to the pilot cell l'n accordance with the manufacturer's recommendations.

Performance testing has shown that no adverse effects have resulted.

. i CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED, AND CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE-The Commonwealth _ Edison Company Project Construction Department has turned all safety related battery banks over to Station Operating for maintenance and surveillance activities.

Station Procedure BWOS-PC-02 was approved in October 1981, and is currently in effect to provide direction when performing battery maintenance.

Assurance of procedure implementation will be documented on an ongoing basis through audits and surveillances performed by Station Quality i

Assurance.

DATE OF FULL COMPLIANCE Full compliance has been achieved.

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EXAMPLE 4-

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10 CFR 50, Appendix B, Criterion XV requires.in part:

" Measures shall be established to control materials, parts or components which do not

conform to requirements in order to prevent their inadvertent use or installation.

These measures shall include, as appropriate, procedures for identification, documentation, segregation, disposition, and notification to affected organizations."

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The CECO Quality Assurance Manual, "' No. 15.0, paragraph 15.3 states in part:

" Items which are found to be nonconforming to design and i

specification requirements or workmanship standards will be positively identified and uniquely segregated or handled as nonconforming to prevent their inadvertent use."

l Commonwealth Edison Company Quality Assurance Manual, QP No. 15-1, implements the above requirements and states in Paragraph 5.2:

"On-site contractor nonconformances will be documented in accordance with the contractor's approved Quality Assurance Program and Procedures."

l Contrary to the above requirements the Licensee did not implement the j

requirements of its Quality Assurance Program or insure the contractor had implemented a quality assurance program to control material, parts or components which do not conform to design requirements.

Non-conformance reports were not issued on at least three occasions,(November 4, 1982;

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November 11, 1982 and December 20, 1982), when it was necessary to

-purchase replacement cells which were damaged or broken.

RESPONSE TO EXAMPLE 4 The Commonwealth F.dison Company agrees that nonconformance reports i

were not issued to document three broken cells.

When the damaged cells were discovered on November 4, 1982, November 11, 1982, and December 20, 1982, respectively, they were subsequently. replaced with good cells.

l CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED. AND CORRECTIVE ACTION i

TAKEN TO AVOID FURTHER NONCOMPLIANCE i

The Commonwealth. Edison Company Operational Analysis Department and Project Construction Department personnel were informally I

reinstructed'in the requirements of issuing Non-Conformance Reports

.when damage.is found on safety-related equipment on December 16, 1983.

I DATE OF FULL COMPLIANCE j

The Commonwealth Edison Company Project. Construction Department l

_ issued.a letter of reinstruction to Operational Analysis Department and Project Construction Department personnel on-April 6, 1984.

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EXAMPLE 5 I-I 10 CFR 50, Appendix B, Criterion XVII requires in part:

" Sufficient i

records shall be maintained to furnish evidence of activities affecting i

quality.

The records shall include at least the following:

....results of reviews, inspections, test audits, monitoring of work performances, j

end materials analysis.... Records shall be identifiable and retrievable."

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Commonwealth Edison Company. Quality Assurance Manual, QR No. 17.0, j

Paragraph 17.1-states in part:

" Quality Assurance records sill ~be maintained either by Edison or'by an agent of Edison,:under Edison's control.... Records are retained and maintained in accordance with a i

j Quality ~ Procedure to furnish evidence of activities affecting quality."

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Commonwealth Edison Company Quality Assurance Manual, QR No. 10.0, I

Paragraph 10.5 states in part:

" Inspection and test records will provide objective evidence that inspections and tests were performed in 1

compliance with instructions and procedures to verify design and code j

requirements.

Inspection and test results will be recorded to show conformance sith acceptance criteria and/or record and identify the cause i

j of rejected items."

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i Contrary to the above requirement, with few exceptions, sufficient

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official records were not generated or maintained relative to the responsibility, movement, maintenance, surveillance, installation, repair

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and cleanliness of the safety rtlated battery banks at the Braidwood site l

j by either Commonwealth Edison Company or their installation contractor.

No records exist to' establish the frequency or necessary data recorded" l

for battery surveillance during the period from May 14, 1981 until January 1, 1982.

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RESPONSE TO EXAMPLE 5 1

j The various activities involving the safety-related battery banks at i

Braidwood Station concerning responsibility, movement, maintenance,

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surveillance, installation, repair and cleanliness have been

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item of non-compliance.

Commonwealth Edison Company acknowledges-that.the existence, location and quality of certain-of the documen-tation of these activities varies as-to acceptability.

No battery-l surveillance records could be located from the period of May 14, 1981 to~ August, 1981.

However, records for surveillance activities i

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both before May 14, 1981 and after August 1981 to the present are i

e available for review.

Although there were documentation-deficiencies, the-records are adequate to demonstrate that surveillance activities were performed and' inspections of the batteries'show that.they are presently functional.

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CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED, AND CORRECTIVE ACTIGNS TAKEN TO AVOID FURTHER NONCOMPLIANCE i

The Commonwealth Edison Company Project Construction Department has

- turned all safety related battery banks over to Station Operating for maintenance and surveillance activities.

Station Procedure BWOS-PC-02 was approved in October 1981, end is currently in effect to provide direction when performing battery maintenance.

Assurance of procedure implementation will be documented on an ongoing basis

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through audits and surveillances performed by Station Quality

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Assurance.

i DATE OF FULL COMPLIANCE Full compliance has been achieved.

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. EXAMPLE 6 10 CFR 50, Appendix 0, Criterion XVIII requires in part:

"A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the ef fectiveness of the program.... Followup action, including re-audit of deficient areas, shall be taken where indicated."

Commonwealth Edison Company Quality Assurance Manual, QR No. 18.0, Paragraph 18.1 states in part:

" Audits will be performed by Commonwealth Edison Company and/or its contractors, subcontractors and vendors to verify the implementation and effectiveness of quality programs under their cognizance."

Paragraph 5.1 of Commonwealth Edison Company Quality Assurance Manual, QP 18-1 states in part:

" Audits of on-site contractors will be performed, as a minimum on an annual basis....The selection of contractor on-site activities to be audited and the frequency of audits will be based on site Quality Assurance and Commonwealth Edison Company Construction Surveillance Reports or findings from previous audit reports....The frequency will be based on the nature and safety significance of the work being performed."

Contrary to the above requirements only two audits were performed by Site Quality Assurance, on activities being performed by Operational Analysis Department relative to the safety related batteries.

These audits, No.

20-79-36, dated June 15, 1979 and No. 20-81-44, dated November 24, 1981 were not sufficient in depth or scope to verify the implementation or ef fectiveness of the quality program with relation to the maintenance, repair and surveillance requirements of the station safety-related battery banks, nor were the audits performed "as a minimum on an annual basis."

RESPONSE TO EXAMPLE 6 The Operational Analysis Department was added to the Site Quality Assurance audit schedule in December 1978.

The Operational Analysis Department was scheduled to be audited twice during 1979.

The first audit was performed.

However, the second audit scheduled for October was not performed due to the site shutdown.

The Site Quality Assurance audit schedule was revised in October 1979, to require monthly audits of the Commonwealth Edison Project Construction Department.

These audits examined the storage and preservation of safety related equipment independent of who was actually assigned responsibility for performing the required activities.

This practice continued until the shutdown ended.

With the exception of the disruption caused by the shutdown, the Commonwealth Edison Quality Assurance Department performed annual audits of our Operational Analysis Department in addition to surveillances to verify programmatic compliance with the Commonwealth Edison Company Quality Assurance Manual and Operational Analysis Department Electrical Construction Test Procedures.

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. Following the resumption of construction activities, auditing of the Operational Analysis Department was performed as part of the annual General Office Quality Assurance audits of the site (normally at least twice per year).

The scope of these audits was not geared to specific electrical components, but rather to verifying compliance and effectiveness of the OAD procedures and adherence to the Commonwealth Edison Company Quality Assurance Manual.

These audits were augmented by surveillances which more specifically addressed the OAD testing activities.

These included in-process inspections of OAD work.

They were scheduled for times wherein OAD would be performing the essential elements of its activities.

In addition to these scheduled surveillances, if Site Quality Assurance identified a problem with OAD's implementation of its procedures or the lack of procedures, the area would be addressed by either a special Site Quality Assurance audit or a detailed surveillance to determine the extent of the problem.

The Operational Analysis Department's compliance with the Commonwealth Edison Quality Assurance Program was evaluated by the audits discussed above.

CORRECTIVE ACTION TAKEN AND ACTION TAKEN TO AVOID FURTHER CONCERN Braidwood Site Quality Assurance has currently scheduled Commonwealth Edison Company Operational Analysis Department to be audited quarterly.

While realizing that currently there remains only one battery bank (non-safety related) for which Operational Analysis Department still has maintenance jurisdiction, Site Quality Assurance will perform surveillances of this specific maintenance activity to verify compliance with their existing procedure.

Also, Braidwood Operating Station Quality Assurance is performing audits and surveillances of battery banks which are under station control.

A review of our inspection records indicates that the more detailed Quality Assurance surveillances and audits described above concentrated on OAD's testing, rather than maintenance activitiese Commonwealth Edison Site Quality Assurance will review records to identify any other maintenance activities OAD might have had responsibility for at the site and will evaluate these activities to determine whether OAD specific practices in the area were properly carried out.

DATE OF FULL COMPLIANCE Regular audits will be performed as scheduled.

The Site Quality Assurance review of OAD's maintenance activities will start as soon as practicable.

Region III will be provided with a schedule of any activities which will have to be conducted as a result of these reviews.

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