ML20138R858
| ML20138R858 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 11/13/1985 |
| From: | Farber M, Little W, Tongue T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20138R852 | List: |
| References | |
| 50-456-85-45, 50-457-85-44, NUDOCS 8511190151 | |
| Download: ML20138R858 (10) | |
See also: IR 05000456/1985045
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION III
Reports No. 50-456/85045(DRP);50-457/85044(DRP)
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Docket Nos. 50-456; 50-457
Licenses No. CPPR-132; CPPR-133
Licensee: Connonwealth Edison Company
Post Office Box 767
Chicago, IL 60690
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Facility Name: Braidwood Station, Units 1 and 2
Inspection At: Braidwood Site, Braidwood, Illinois
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Inspection Conducted: September 3 through November 1, 1985
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Inspector:
T. M. Tongue
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Date
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P. J. Farber'
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Date
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Approved By:
W.
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le, Director
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Bra dwood Project
Dater /
Inspection Summary
Inspection on September 3, through November 1, 1985 (Report No. 50-456/85045(DRP);
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50-457/85044(DRP))
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Areas Inspected: Routine, unannounced safety inspection of activities with
regard to licensee action on previous inspection findings, plant tours, fuel
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receipt preparations, technical specification reviews, operational preparedness,
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communications, administrative controls for Startup Deficiency Reports, steam
generator hydrostatic testing, piping and instrument diagram verification, fire
protection plug valves, and guard force picket activities. The inspection
consisted of 212 inspector-hours onsite by two NRC inspectors including 36
inspector-hours onsite during off-shifts.
Results: Of the eleven areas inspected, no violations were identified in ten
areas, one violation was identified in one area (inadequate corrective action
- Paragraph 3).
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8511190151 851114
ADOCM 05000456
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Details
1.
Persons Contacted
Commonwealth Edison Company (CECO)
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Corporate Personnel
A. Miosi, Nuclear Licensing Administrator
Braidwood Personnel
- M. J. Wallace, Project Manager
- C. W. Schroeder, Project Licensing and Compliance Superintendent
- D. L. Shamblin, Project Construction Superintendent
J. Gudac, Station Superintendent
- E. E. Fitzpatrick, Assistant Manager, Quality Assurance
- L. M. Kline, Project Licensing and Compliance Supervisor
N. Tomis, P0AD Supervising Engineer
H. Zimmerman, Project Startup Testing Supervisor
D. Paquette, Maintenance Assistant Superintendent
- D. O'Brien, Administrative and Support Services Assistant
Superintendent
R. Legner, Senior Operating Engineer
G. Masters, Operating Engineer
F. Willaford, Security Administrator
M. Andrews, Station Chemist
- G. Nelson, Assistant Technical Staff Supervisor
T. Keith, Lead Health Physicist
- T. W. Simpkin, Technical Staff-Licensing
- T. E. Quaka, Site Quality Assurance Superintendent
- R. Kyrouac, Quality Assurance Supervisor
- C. Tomashek, Startup Superintendent
NRC Personnel
J. Stevens, Braidwood Licensing Project Manager
G. Plumlee, Licensing Reviewer
NRC Contractor
D. McHuron, E.G.&G. Senior Engineer
The inspectors also talked with and interviewed several other licensee
employees, including members of the technical and engineering staffs,
reactor and auxiliary operators, shift engineers and foremen, electrical,
mechanical and instrument personnel, contract security personnel and
construction personnel.
- Denotes those attending one or more exit interviews conducted on
September 5, 12, 19, October 10, 17, 24, and 31, 1985 and informally at
various times throughout the inspection period.
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2.
Licensee Action on Previous Inspection Findings
The inspectors reviewed licensee corrective actions on the following items
and the results are as stated:
(Closed) Violation (456/85023-01(DRP);457/85024-01(DRP)):
Failure to keep
trash and debris out of safety related cable trays and control of high
strength bolting material (construction material). The licensee provided
instructions to contractors for control of trash, debris and safety related
material and this specific issue was closed in inspection report No.
456/85032(DRP);457/85031(DRP). However, plant tours by the inspectors
revealed that this is still a problem and corrective action has not been
effective.
(0 pen) Violation (456/85008-10(a),(b), and (c)(DRS); 457/85008-10(a),(b),
and(c)(DRS)):
Inadequate protection of installed safety related plant
equipment. Steps were taken to correct the specific items identified,
however, the actions were inadequate in that a number of new and ongoing
conditions remain uncorrected.
With regard to the adequacy of the corrective action on both of the
foregoing items, refer to Paragraph 3 of this report.
3.
Plent Tours
During this inspection period, the inspectors conducted tours of the
facility to make independent assessment of equipment, plant conditions,
security, fire hazards and fire protection, maintenance, communications,
work authorizations, and system controls during and after flushing,
testing, and maintenance.
The inspectors reviewed applicable logs, procedures, work packages, and
interviewed personrel involved in ongoing activities as part of the
inspection.
During plant tours the inspectors identified areas where equipment
protection was inadequate. Electrical panels in the auxiliary electrical
equipment room and the main control board in the control room were left
uncovered and/or open while masonry work was being conducted in the
immediate vicinity. This resulted in fine masonry dust settling out on
the control panels and internal components as well as leaving them
vulnerable to further intrusion of other contaminants such as moisture,
spray, or aerosols. Although there may not be an immediate problem with
the equipment, the intrusion of foreign matter can cause unpredictable
equipment failures in the future. The inspectors identified an open
electrical junction box for temperature element leads on centrifugal
charging pump ICV 01PA which contained an accumulation of oil such that
the cable insulation was submerged in the oil. Additionally, the oil
accumulation constitutes a potential fire hazard. The inspectors also
identified a number of flexible electrical conduits which were damaged
such that the cable supported the conduit and the cable insulation was
exposed to cuts and gashes from the sharp edges of the conduits. The
open junction box and the damaged flexible conduits were presented to
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licensee management representatives during an exit meeting on September 19,
1985. As of October 28, 1985, no evidence was available to show that
action had been taken to correct the conditions and that any evaluation
had been performed to determine the reason for the accumulation of oil in
the temperature element junction box.
The inspectors noted that in the past year there have been at least two
previous violations for inadequate housekeeping and equipment protection.
The lack of effective overall corrective action to protect safety related
equipment in response to NRC violations and failure to respond in a
timely manner to inspector findings is considered a violation of 10 CFR 50, Appendix B, Criterion XVI, " Corrective Action"
(456/85045-01(DRP);
457/85044-01(DRP)).
On October 29, 1985, subsequent to the inspector informing the licensee of
the issuance of the violation for inadequate corrective action on housekeep-
ing and equipment protection, the licensee issued an action plan. The plan
delineates specific steps and responsible individuals for cleaning electrical
panels and equipment in the Unit I and 2 control rooms auxiliary electrical
rcoms, and computer rooms on elevation 451'.
The plan is specific to those
areas and if effective, should prevent further intrusion of construction
dust, dirt and debris into those control and electrical components. The
actio.n, plan does not address other areas of the plant, e.g., safety related
equipuent areas of the turbine, auxiliary, and containment buildings, and
is specific to electrical equipment.
It does not address other systems
such as mechanical ventilation, diesel generator, etc.
The limited scope was discussed with licensee management personnel at the
exit meeting on October 31, 1985, and they stated that this was the
beginning to an overall program in preparation for shifting the plant to a
test / operational status. This will continue to be monitored as part of
the routine inspection.
One violation was identified.
4.
New Fuel Receipt Preparations
The inspectors reviewed the proposed Special Nuclear Materials License
(No. SNM-1938) in preparation for receipt and storage of new fuel, post
accident monitoring detectors, and a sealed plutonium calibration source.
The inspectors also monitored the status of preparation of the spent fuel
pool, new fuel storage area, and reviewed the status of required
preoperational testing for fuel handling systems, persorr.31 and training
requirements, security preparations, required fire protection systems,
and health physics programs. Subsequent to these reviews the license
(SNM-1938) was issued on October 8, 1985. The inspectors will continue
to monitor licensee preparations during forthcoming inspection periods.
No violations or deviations were identified.
5.
Technical Specification Review
During the inspection period, the inspectors conducted a review of the
draft lechnical Specifications, dated September 16, 1985. The review was
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for technical content, clarity, enforceability, typographical errors, and
any questions where interpretation was in question.
On October 29 and 30, 1985, the inspectors met with members of the NRR
Headquarters staff, an NRC contractor, and with licensee representatives
to discuss the results of their individual review findings. The results
of the meeting will be considered for resolution prior to the final
proposed Technical Specification proof and review.
No violations or deviations were identified.
6.
Operational Preparedness
Through interviews with personnel and observation of activities, the
inspector identified the following concerns during the inspection:
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a.
An apparent shortage of operations personnel when considering the
station is entering an intensive startup and testing program along
with a large portion of personnel on training. assignment for
licensing.
b.
The need for station maintenance personnel to get involved in as
much activity as possible for a better understanding of the plant
equipment prior to turnover for operation.
c.
An exceptional number of nonessential design changes and modifications
of systems during and after construction and testing.
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This can create unnecessary delays as well as making the station
vulnerable to unexpected equipment failure events later in plant life,
as evidenced by some of the recent occurrences at the LaSalle and
Byron stations.
These issues were discussed with project management personnel who were
knowledgeable on each of the items and could justify the condition or
show that corrective actions were being implemented. These concerns will
continue to be monitored routinely in future inspections.
No violations or deviations were identified.
7.
Communications
During the inspection period, the senior resident inspector (SRI) attended
a number of morning meetings in the control room to acquire a knowledge of
the daily ongoing activities.
It became evident that the CECO Operational
Analysis Department (0AD) was not represented, even though there were about
20 OAD crews conducting testing on site.
In addition, the inspector noted
that occasionally, a start-up engineer from the start-up group would miss
the meeting. The purpose of these meetings is for planning daily activities
and the very important function of keeping all appropriate plant operations
personnel apprised of activities in the plant that are related to control
room indications, alarms or controls.
Since the station is in a transition
process from construction to a testing / operational mode, the SRI suggested
that 0AD and all start-up engineers be represented at the meeting. The
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licensee acknowledged this and has provided representation as suggested.
Further evidence of communication breakdown was identified when two small
fires of suspicious origin occurred within a two week period. The
construction Fire Marshall was informed and assessed the incidents, however,
the station Fire Marshall or his assistant was unaware of the events. The
licensee has taken steps to assure better communication between these
individuals. The inspector expressed concern about adequate communications
between the start-up test group and the station personnel throughout the
start-up program to assure an adequate understanding of the equipment
performance history to assure efficient operation.
Communications will continue to be routinely monitored.
No violations or deviations were identified.
8.
Administrative Controls on Startup Deficiency Reports (SDR)
In response to concerns raised by Region III Test Program Section inspectors
and as a result of observations by the inspector during a review of Startup
Deficiency Reports, the inspector commenced an evaluation of the administra-
tive controls for Startup Deficiency Reports. This document identifies
broken, incomplete or improper installations, documentation, or testing
items. These deficiencies have the potential to be nonconforming items and
the Startup Deficiency Report may be the only record of a nonconformance
until a Nonconformance Report (NCR) is generated. As such, SDRs written on
safety related items are quality records.
The following documents were reviewed:
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Q.R. No. 15.0, Rev. 8, " Nonconforming Materials, Parts, or
Components and Operations"
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Q.P. No.15-1, Rev. 7, " Reporting Quality Nonconformances During
Construction and Test"
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Braidwood Project Startup Manual, Rev. 13, Section 4.1.4,
" Deficiencies"
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Braidwood Project Startup Manual, Rev.13, Section 4.6.3.9, " Test
Performance"
Following the review of these documents the inspector identified the
following concerns:
a.
The Braidwood Project Startup Manual, Section 4.1.4 provides the
procedural requirements for control of the Startup Deficiency Report
within the confines of the Startup organization.
It does not provide
instructions for the control of this document once it has been
transferred to other departments. The inspector was unable to identify
procedures in other site departments, Quality Assurance excepted, which
contained instructions for the control of SDRs.
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Evaluation of the requirement for organizations processing SDRs to
have procedures which control them is an open item (456/85045-02(DRP);
457/85044-02(DRP)) pending further discussions with the licensee staff.
b.
Review of the procedures controlling the deficiency reporting process
revealed that there is no requirement to identify on the SDR documents
such as work requests, NCRs, letters, and evaluations used in the
resolution of the deficiency. Without the identification of these
corrective action documents, the traceability of the corrective action
is indeterminate. The ability to audit SDRs and trace corrective
action from issue to closure is an open item (456/85045-03(DRP);
457/85044-03(DRP)) pending an audit of Startup Deficiency Reports
by the inspector.
c.
While attempting to identify procedures for control of SDRs the
inspector was unable to determine whether or not provisions in existing
Project Construction Department procedures would ensure that SDRs
received a review to identify nonconforming items. Without these
provisions it is not clear that Startup Deficiency Reports have been
properly reviewed for nonconformance and that Nonconformance Reports
have been written for all nonconforming items which were identified on
SDRs.
Review of Startup Deficiency Reports for nonconformance is an
open item (456/85045-04(DRP); 457/85044-04(DRP)) pending a review of
SDRs by the inspector to determine if there has been a consistent
failure to report nonconforming items which are identified on Startup
Deficiency Reports.
d.
While examining the project procedure index to identify PM or PCD
procedures related to SDRs the inspector noted that Procedure PM-05
"Nonconformance Reporting" was not issued. Since this procedure would
be expected to define the projects administration controls for the
issuing, handling, and tracking, of a quality record, the inspector is
concerned that NCRs are not adequately controlled. Evaluation of the
circumstances involved in the failure to issue this procedure is an
openitem(456/85045-05(DRP);457/85044-05(DRP)).
No violations or deviations were identified.
9.
Steam Generator Hydrostatic Testing
The licensee is currently scheduled to conduct a Reactor Coolant System
primary hydrostatic test. To gain familiarity with the licensee's methods
for conducting major hydrostatic tests, the inspector conducted a brief
review of the construction procedure used to conduct the Unit I steam
generator hydrostatic testing and witnessed portions of the test. The
inspector had the following comments regarding the procedure and the
evolution:
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a.
The procedure was very loosely constructed and was more of a set of
broad general guidelines for conducting the evolution.
Valve lineups
did not appear to be well-structured or formal.
b.
Secondary systems such as Condensate and Feed were used in support of
the test.
Personnel conducting the test used no procedures in the
operation of these systems relying instead on their knowledge of the
system to lineup valves and run the pumps.
c.
Very little instrumentation was available to the operators in the
control room to enable them to monitor the status of the plant.
They were forced to rely on radio and face-to-face reports from test
personnel to determine conditions in the plant.
During the filling
of the steam generators the only instrumentation which the inspector
could identify as functioning were Condensate Booster Pump Amps and a
Condenser Hotwell Level computer point.
Significant steam generator
parameters such as level, pressure, and temperature were not
available to operators nor was the valve position indication for the
Feedwater Regulating Bypass Valves which were used to control flow
to the steam generator.
The inspector met with the Startup Superintendent to discuss these comments.
It was noted by both the inspector and the Startup Superintendent that this
was a construction test on a secondary system and it was not subject to the
same requirements as a preoperational test on a safety-related primary
system.
However, the inspector pointed out that the primary hydrostatic
test is also a construction test but that a similar test procedure and test
performance would not be considered acceptable.
The inspector stated
further that the test procedure would be closely reviewed and witnessed.
No violations or deviations were identified.
10.
Allegation Review
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In response to an allegation concerning the accuracy of Piping and
Instrument Diagrams (P&ID) the inspector has commenced walkdowns of P& ids
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for selected safety systems and has interviewed members of the licensee's
operational staff to evaluate the effectiveness of the P&ID verification
and correction process.
A walkdown of M-37, Auxiliary Feedwater has been
completed and some minor deficiencies were noted.
These were turned over
to the licensee staff for resolution.
A walkdown of the Diesel Fuel Oil
system P&ID was started but will not be completed until the next reporting
period.
Further discussions with the operations staff regarding the P&ID
verification and correction process will be required to determine the
adequacy of the licensee's program.
Upon completion of the inspector's review of all issues involved in the
allegation a report will be issued which will detail all the issues and
address the resolution of each one.
No violations or deviations were identified.
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11. Fire Protection Isolation Valves
An issue which emerged from both the fuel receipt preparation inspections
and the allegation discussed in Paragraph 10 us the acceptability of the
ITT Grinnell plug valves used as header and standpipe isolation valves in
the fire protection system in the containment.
In discussions with regional
fire protection personnel a concern was raised as to whether or not these
valves were approved for use in fire protection systems by the Underwriters
Laboratory (UL) as required by the National Fire Protectun Association
(NFPA) Code, Section 14. The inspector met with the Project Construction
Department (PCD) engineer responsible for fire protection and during the
meeting was shown a letter dated May 17, 1985, from M&M Protection Con-
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sultants to Commonwealth Edison, which identified that the ITT Grinnell
valves were not UL listed. The letter stated that the valves were
seismically qualified but that a UL listing is not available for seismic
class valves. The recommended resolution was that since UL listing is not
available for seismic class, the valves are acceptable.
Further discussions
with regional fire protection specialists questioned this conclusion.
Acceptability of the ITT Grinnell plug valves for use in fire protection
applications is an open item (456/85045-06(DRP); 457/85044-06(DRP)) pending
review of the matter by Region III fire protection specialists.
No violations or deviations were identified.
12. Guard Force Pickets
On November 1,1985, the licensee implemented the services of Burns Security,
replacing Guards Mark. On that date, the terminated guards established
informational pickets at the north and south gates of the plant. Access to
the plant was delayed by up to thirty minutes due to traffic congestion,
however, the pickets dispersed by mid-morning. A number of contractor trades
personnel honored the picket, however, licensee personnel appeared to be
unaffected. There was some news media interest through an announcement over
a local radio station.
The inspector monitored the activities and relayed information to Region III
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as appropriate.
No violations or deviations were identified.
13. Meetings, Training, and other Activities
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On October 21 and 22, 1985, Mr. Yoshitaka Arakawa of the Japanese Ministry
of Internal Trade and Industry was on site for an information gathering
session as part of his three month tour of the United States. Mr. Arakawa's
agency is the Japanese equivalent of the NRC and he expressed interests in a
number of areas, such as the NRC Resident Inspector Program, Technical
Specifications, emergency diesel generators, certification of construction
work in accordance with construction codes, etc. Mr. Arakawa provided
enlightening discussion when comparing the two nations and expressed
gratitude for the time and information provided by the licensee personnel
and the inspectors involved.
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14.
Open Items
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Open items are matters which have been discussed with the licensee, which
will be reviewed by the inspector and which involve some action on the part
of the NRC or licensee or both.
Open items disclosed during the inspection
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are discussed in Paragraphs 8 and 11.
15.
Exit Interview
The inspectors met with licensee and contractor representatives denoted in
Paragraph I during and at the conclusion of the inspection on October 31,
1985.
The inspectors summarized the scope and results of the inspection and
discussed the likely content of this inspection report.
The licensee
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acknowledged the information and did not indicate that any of the
information disclosed during the inspection could be considered proprietary
in nature.
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