IR 05000456/1987045

Insp Repts 50-456/87-45 & 50-457/87-46 on 871210-22.No Violations or Deviation Noted.Major Areas Inspected:Qa Program Implementation in Preparation for Operation of Unit 2

ML20148F837
Person / Time
Site:	Braidwood
Issue date:	01/14/1988
From:	Jablonski F, Reynolds S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20148F822	List: IR 05000456/1987045 ML20148F818
References
50-456-87-45, 50-457-87-46, NUDOCS 8801260338
Download: ML20148F837 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION III -i Reports No. 50-456/87045; 50-457/87046'

Docket.Nos. 50-456; 50-457 Licenses No. NPF-72; NPF-75 i Licensee: Commonwealth Edison Company Post Office Box-767 i Chicago, IL 60690

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Facility Name: Braidwood Station, Units 1 & 2

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Inspection At: Braidwood Site, Braidwood, Illinois Inspection Conducted: December 10-22, 1987 Inspector: -

(tbbib d -/@ O O  :

S. M. 8eynolds // Date i Approved By: ) * \ glj b'AS /' /Y~[l 8 F.J.{ablonski Date Inspection Summary ,

Inspection on December 10-22, 1987 (Report No. 50-456/87045; 50-457/87046) ,

Areas Inspected: Routine, unannounced inspection of licensee's QA Program implementation in preparation for operation of Unit 2 in the specific areas of preoperational testing QA, QA program administration, document control, and maintenance. This inspection was conducted utilizing portions of Inspection Procedures 35301, 35740, 35742, and 3574 Results: No violations or deviations were identified.

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PDR ADOCK 05000456 4 G PDR

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DETAILS 1. ' Persons Contacted Commonwealth Edison Company-(Ceco)

• Fitzpatrick, Station Manager

• P. ' Barnes, Regulatory Assurance Supervisor

• R. Bedford, Regulatory Assurance Staff

• J. Gosnell,. Quality Control Supervisor S. Heddon, Instrument and Control Supervisor

• R. Kyrouac, Quality Assurance Superintendent

• D. Paquette, Assistant Superintendent, Maintenance K. Radke, Station Lubrication Coordinator

• J. Roth, Environmental-Qualification Coordinator, Technical Staff-

• M. Takaki, Regulatory Assurance Staff

• Indicates those attending the December 22, 1987, exit meetin Other individuals were contacted as a matter of course during the inspectio Licensee Action on Previous Inspection Findings

' (Closed) Open Item (456/87030-02; 457/87029-02): Retention times specified for QA records in procedure QP 17-51 were in conflict with licensee's current commitment to ANSI N45.2.9-1974 and Section 6.10 of Braidwood Technical Specificatio QP-17-51 was revised to correct the abov This item is closed, (0 pen) Violation (456/87030-03; 457/87029-03): Licensee did not l establish measures to adequately control the use of out of tolerance (00T) measuring and test equipment (M&TE) and evaluate the effects on l operating equipmen Corrective action described in the licensee's October 30, 1987 letter to the NRC was to revise procedure BwAP 400-4T2 to specify how j evaluations of M&TE were to be performed and documented. The '

inspector reviewed the revised procedure and noted a more defined evaluation process over the previous procedure; however, the inspector I was unable to review a sufficient number of evaluations to determine I if the revised procedure effectively corrected the problem. This item is open and will be reviewed during a subsequent inspr; tio The. inspector also noted that there was a substantial backlog of incomplete evaluations of 00T R&TE. One of the steps in the evaluation process required a determination of whether a Technical Specification (Tech. Spec.) violatica had occurred or Limiting Condition for Operation Action Requirement (LC0AR) entry was required. A11'of the incomplete evaluations reviewed by the inspector did not have this step completed. Failure to complete

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the evaluations, including the above step, prevents the determination of operability for applicable Tech. Spec related equipment and the determination of reportability per 10 CFR 50.73. Timely corrective actions were not taken; 70 evaluations were over 30 days old, 20 of these were over 180 days old. This indicated a significant breakdown in the evaluation process and appeared to be caused by lack of management attention and involvemen The inspector was aware that the this backlog was previously identified by the QA department. The QA department monitored the maintenance department's (Instrument and Control, Electrical, and Mechanical) commitments and issued a finding about untimely corrective action because of failure to meet commitments. As a result, additional manpower was provided; however, increased and aggressive management attention and involvement must continue to reduce the backlog to an acceptable level. The QC department did not identify the unacceptable backlog prior to QA even though the QC department maintained the official logbook for 00T M&TE evaluation This matter is unresolved. Corrective actions will be reviewed during a future inspection. (456/87045-01;457/87046-01).

3. Review of Allegations (Closed) Allegation (RIII-87-A-0100)

The NRC received an allegation during June 1987, about several concerns with the Out-0f-Service (00S) process. The concerns were reviewed by the inspector as discussed belo S is the process used to tag and administratively remove a piece a of equipment and necessary adjacent equipment from service to perform maintenance or surveillance activities. This process is used to protect personnel and operating equipmen Concern No. 1 Supervisors were not "walking down" systems, according to the 00S procedure, prior to crews commencing wor NRC Review Braidwood Administrative Procedure, BWAP 330-1, "Station Equipment Out-0f-Service Procedure," Revision 52, required that the supervisor in charge of the work had the responsibility to assure that an inspection had been made to determine that 00S cards had been correctly placed and

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that the equipment was safe for work. The inspector interviewed supervisors from mechanical, electrical, and I&C maintenance departments and operations (fuel handling) department. Those supervisors were well aware of BWAP 330-1 requirements and stated that in almost all cases they personally "walked down" the system with a member of the crew, or the lead workman "walked down" the system after the supervisor had completed his

"walkdown"; in some cases, the supervisors had the lead workman "walkdown"

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the system. The inspector discussed this issue with non-supervisory maintenance and operations personnel and reviewed several in-place and in-progress system walkdowns. The inspector did not note any instances where a system was not adequately "walked down" in accordance with BWAP 330- Results j The concern was not substantiated; out of service systema were '"walked down" prior to commencing work per procedure, and in almost all cases by the supervisors with a crew member to verify the supervisor's "walk downs."

Concern No. 2 Operations personnel verification of 00Ss was inadequate to identify errors (such as, use of boilerplate 00Ss and not verifying adequacy).

NRC Review The inspector discussed the 00S process with operations personnel. Those personnel were well aware of 00S requirements and necessary actions. The inspector reviewed several completed and in-place 00S and noted that all necessary forms were properly filled out and 00S cards were hung on the -

correct pieces of equipment with the correct position recorded. The inspector did not identify any instances where boilerplate 00Ss were used.

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Results The concern was not substantiated; operations personnel adequately verified 00Ss according to procedure. The inspector did not identify any problems associated with operations personnel's ability to identify errors through 00S verification Concern No. 3 Training of Maintenance Foremen on systems is inadequate for them to understand the systems and related 00S NRC Review The inspector determined that maintenance personnel, including foremen, were required to have systems training in order to meet position qualification requirements. Based on review and discussions with

, maintenance, QA, and regulatory assurance personnel, the inspector determined that maintenance foremen had completed a two week systems

training course. Based on discussions with several maintenance foremen, the inspector determined that maintenance foremen had considerable nuclear

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power plant experience. The maintenance foremen interviewed demonstrated

sufficient knowledge and understanding of systems and 00S requirements.

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q The concern was not substantiated; the inspector concluded that maintenance

foremen had an adequate understanding of systems and 005 requirements

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based on the foremen's knowledge, experience, and trainin .

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Concern No. 4 Training of maintenance personnel-(including mechanics) on 00S procedures is inadequate; that is, training is different from actual practice NRC Review The inspector was informed by maintenance personnel that _00S was . included -

as part of annual requalification training. The inspector noted that training included both site-specific and company-wide 00S requirement Maintenance personnel were generally aware 'of this fact. Maintenance personnel exhibited knowledge of the 00S requirements. The inspector did not identify any instances where the above mentioned _ training caused any problem Results The concern was not substantiated; training appeared adequate. Both site-specific and company-wide 00S requirements are discussed during trainin Conclusion  ;

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Review of the allegation received during June 1987, did not identify any instances of impropriety that would have impact on the radiological health !

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and safety of the public, nor were there any such instances made known to or identified by the inspector during~ the inspectio No violations or deviations were identified during the inspection of the i above concerns. This matter is close . QA Proaram The purpose of this inspection was to determine if the QA Program, in !

specific programmatic areas, had been properly implemented for Braidwood, Unit 2. Braidwood Units 1 and 2 share a common Ceco QA Program, and in ;

most cases, the same implementing procedures. This inspection included i

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review of QA Program implementation in the areas of preoperational testing, QA Program administration, document control, and maintenance. The inspector assessed licensee management involvement and control in assuring quality in these areas and attempted to determ?ne the effectiveness of staffing, training, and qualification Reference Documents

BwAP 370-1, "Station Lubrication Program," Revision *

BwAP 370-2, "Station Sampling Program," Revision BwAP 400-7, "Preventive Predictive Maintenance Program,"

Revision Inspection Resulti (1) The inspector reviewed implementation of preoperational testing

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QA through questioning, discussions, and observation of wor The inspector determined that the QA' department satisfactorily, understood basic responsibilities. The inspector reviewed :

, various audits and surveillances performed in 1987, that covered' .

preoperational testing activities which included tests of safety !

related systems and leak rate tests. Those audit and- 1 surveillances were adequately performed and documented, 1 performance-related and compliance deficiencies were identified, and adequate corrective actions were taken'to resolve th '

deficiencie The inspector reviewed qualification records for three QA engineers involved in preoperational testing, including one new engineer, and determined that the personnel met the requirements for the QA engineer position, as well as lead auditor / auditor.

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(2) The inspector reviewed the general administration of the QA 1 Program. The inspector verified by document review, discussions ,

with QA personnel, and by observation and review of various ,

audits, surveillances,-schedules, and auditor certifications-

, that the station QA department had established adequate controls ,

and mechanisms for performance and verification of the QA Program ,

requirement

The inspector noted that there was a staff of 14 QA engineers or inspectors in the QA department. Staffing level requirements :

were for 12 persons; the two extra persons were added to the QA staff to help during preoperational testing and startup for .

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Units 1 and >

(3) The inspector reviewed implementation of the administrative ,

controls for handling and distribution of documents for safety *

related applications. The inspector noted that distribution of controlled documents was handled by central files personnel responsive to procedural requirements. A computer printout of

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the master revision list was readily available for verification of the latest revision. A review of various maintenance work i requests indicated that current copies of drawings and procedures !

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were used. The inspector reviewed an October 1987 QA audit report about implementation of the document control program and noted

that no deficiencies were identified. The audit did'not include

) review of the control of critical drawings in the control-roo :

, In parallel with this inspection, a problem with the control of ;

critical drawings in the control room was identified as j s

documentedinanotherNRCinspection(50-456/87038;50-457/87036)),

where this issue will be followed u .

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(4) The inspector reviewed implementation of maintenance programs ,

and attempted to assess the material condition of Unit '

Several corrective maintenance work requests about diesel generator repair and relief valve setpoint' checks that were completed in April through November of 1987 were reviewed. It

, was determined that necessary information was included in the ;

work request packages, equipment, and materials used were

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identified, and work requests were adequately reviewed _and approved before and after the work. There was no sizeable corrective maintenance backlo ~

The inspector reviewed portions of the Preventive-Predictive Maintenance Program and deterrained it to be adequat Schenuling of preventive maintenance appeared satisfactory, except as noted below, and there was no apparent backlo Preventive predictive maintenance activities were generally performed when required and suitably documente During a review of preventive maintenance scheduling, th inspector noted that almost all environmental qualification (EQ) maintenance and surveillance requirements for Unit 2 were not scheduled and some Unit 1 EQ maintenance and surveillance requirements were not scheduled. The inspector also noted that the licensee did not start the "EQ clock" until unit criticality even though the licensee was required by 10 CFR 50.49 to have an EQ Program established by November 30, 1985. A CECO corporate engineer informed the inspector that radiation and high temperatures were not present until the reactor was critical; therefore, the

"EQ clock" was not required to be started until unit criticalit This issue is unresolved and will be reviewed during a future inspection (456/87045-02: 457/87046-02).

The inspector reviewed implementation of the Station Sampling Program and noted that the procedure, BwAP 370-2, was not strictly followe The Oil Sample Program Log, an attachment to BWAP 370-2, was not being completed, and another attachment, the Oil Sampling and Analysis Program, was extremely cumbersome ano difficult to use for accurate schedulin The Station Lubrication Coordinator was aware of the problems and in the process of revising the program. This issue is unresolved pending review of the revised program (456/87045-03; 457/87046-03).

c. Summa ry The inspector reviewed implementation of the QA Program for Unit 2 in the specific areas of preoperational testing QA, QA program administration, document control, and maintenance. Except for the items discussed above, the inspector did not identify any other Concern Based on reviews of program implementation, discussions with maintenarce personnel, review of QA audits of maintenance activities, Walkdowns of Unit 2, and documentation of work status and work performed, the inspector determined that the material condition of Unit 2 was satisfactor No violations were identified.

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5.- Conclusion The. inspector conclud'ed'that:

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• . Management involvement and control in assuring quality needed improvement in the maintenance area based >on the 00T M&TE evaluation backlog issue

• Management l involvement and control was satisfactory in the QA department based on evidence of effective planninge scheduling, and . ,

generally complete and timely audits. Management's approach to resolve the 00T M&TE evaluation backlog issue from a safety standpoint was lacking in that prompt resolutions were not sought; the attitude appeared to be "just satisfy minimum requirements".

• Staffing in the QA department was sufficient to meet current and future work load * Training and qualifications of the,QA staff contributed to ar adequate understanding of work and responsibilitie . bncesolved Items Unresolved items are matters about which more information is required in orde to ascertain whether they are acceptable items, violations, or devia. ions. Three unresolved items disclosed during this inspection'are incluc'd in Sections 2.b. and 4.b.(4). Exit Interview The inspector met with licensee representatives (denoted in Section 1)

on Cecember 22, 1987, at Braidwood Nuclear. Station, and summarized the purpose, scope, and findings of the inspection. The inspector discussed the likely content of the inspection report with regard to documents or-processes reviewed by the inspector. The licensee did not identify any such documents or processes as proprietar I

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