ML20203K251

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Insp Rept 50-456/86-25 on 860519-0711.Violation Noted: Failure to Control Nonconformances & Addl Unresolved Issues Re QA Programs for Preoperational Testing & Operational Readiness That Require Review
ML20203K251
Person / Time
Site: Braidwood Constellation icon.png
Issue date: 07/31/1986
From: Hawkins F, Thomas Taylor, Vandel T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20203K236 List:
References
50-456-86-25, NUDOCS 8608070132
Download: ML20203K251 (7)


See also: IR 05000456/1986025

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-456/86025(DRS)

Docket No. 50-456

Construction Permit No. CPPR-132

Licensee: Commonwealth Edison Company

Post Office Box 767

Chicago, IL 60690

Facility Name: Braidwood Nuclear Power Station, Unit 1

Inspection At: Braidwood Site, Braidwood, IL

Inspection Conducte : May 19-22, 27-30, June 2-13, and July 10-11, 1986

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Inspectors:

T. E. Vandel

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T. E. Taylor

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Approved By:

F. C. Hawkins, C

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Quality Assurance Programs

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Section

In_sp_ection Summary

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Inspection on May 19-22, 27-3_0_, June 2-13,~and July 10-11, 1986 Report

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No. 50-456/860B(Dh_3]T~

Areas Inspected: Routine safety inspection to followup previously identified

inspection findings; review the preoperational QA progran and activities in

progress; review the QA administration, auditing, maintenance, and surveillance

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program procedures for plant operations.

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Results: Of the seven areas inspected, one violation was identified regarding

failure to control nonconformances (Paragroph 3) and adoitional unresolved

issues were identified (Paragraphs 3 and 4) that require additional NRC review.

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DETAILS

1.

_ Persons Contacted

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CommonwealthEdison__CompanyJEC_oj

  • P. L. Barnes, Regulatory Assurance Supervisor

T. Bobic, Master Electrician

  • D. L. Ceccheti, Radiation Health Physics
  • L. Davis, Assistant Superintendent

T. Dehnert, Project Engineering Department

  • G. E. Groth, Assistant Construction Superintendent

S. Hedden, Master Instrument Mechanic

J. Huffman, Master Mechanic

  • S. C. Hunsader, Site QA Supervisor

M. Inserra, Chairman, Test Review Board

  • J. K. Jasnosz, Radiaticn Health Physics

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S. Johnson, Project Construction Mechanical Coordinator

  • R. D. Kryonac, Station QA Supervisor
  • G. F. Marcus, Assistant to QA Manager
  • E. R. Netzel, Site QA Supervisor
  • D. E. Paquette, Assistant Superintendent

M. Peterson, Surveillance Coordinator

T. Penddergast, Site QA Lead Auditor

J. Purrazzo, Project Construction Electrical Coordinator

T. E. Quaka, Site QA Superintendent

N. Schmitt, Startup Test Engineer

  • C. W. Schroeder, Services Superintendent
  • D. L. Shamblin, Project Construction Superintendent
  • D. J. Skoza, Project Field Engineering

S. Stapp, Station QA Lead Auditor

C. Tomashek, Project Startup Superintendent

J. Thunderstedt, Project Startup Staff Assistant

R. Ungeran, Operations Engineering Supervisor

P. Zolan, Site QA Audit Coordinator

J. A. Zych, Site QA Surveillance Coordinator

U. S. Nuclear Regulato_ry Commission (NRC)

  • W. Kropp, Senior Resident Inspector (Construction)
  • T. Taylor,ResidentInspector(0perations)

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  • T. Tongue, Senicr Resider.t Inspector (Operations)

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  • Denotes those in attendance at the exit meeting held on June 13, 1986.

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Other licensee project construction, startup and operations personnel-

were contacted during the course of the inspection.

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2.

Licensee Action on Prev,ious I_nsp_ec_ tion Finding

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(Closed) Open Item (456/85045-02(DRP); 457/85044-02(DRP)) - Instructions for

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control of Startup Deficiency Reports (SDRs). The inspector has determined

that instructions for control of SDRs is not adequate. This item is

addressed as part of Violation 456/86025-01 (Paragraph 3).

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(Closed) Open Item (456/85045-03(DRP); 457/85044-03(DRP)) - Review of the

procedures controlling the deficiency reporting process revealed there is

no requirement to identify on the SDR document items such as work requests,

NRCs, and evaluations used in the resolution of the deficiency. The

inspectors review of this ara determined that the licensee should evaluate

the traceability of the above mentioned documents. This item is addressed

as part of Violation 456/86025-01 (Paragraph 3).

(Closed) Open Item (456/85045-04(DRP); 457/85044-04(DRP)) - The inspector

was unable to determine whether or not provisions in existing Project

Construction Department procedures would ensure that SDRs receive a review

to identify nonconforming items identified on SDRs. This issue is

addressed as part of Violation 456/86025-01 (Paragraph 3).

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(Closed) Unresolved Item (456/85055-01(DRS) - The inspector is concerned

that the system does not contain the positive controls necessary to ensure

that all deficiencies are noted and properly addressed. The inspector has

determined that deficiencies are not always reviewed for nonconformances

and test deficiencies (alpha deficiencies) are not always tracked nor

addressed by administrative documents. This item is addressed as part of

Violation 456/86025-01 (Paragraph 3).

(Closed) Open Item (456/85055-02(DRS) - The Startup Manual which provides

the procedure for completing and processing the deficiency report does not

appear to be adequate. The inspectors review of this item is contained in

the details of Violation 456/86025-01 (Paragraph 3).

(Closed) Unresolved Item (456/85055-03(DRS); 457/85055-03(DRS)) - Procedural

control for determination of nonconformances from startup deficiencies.

There is no procedure for this item nor do startup personnel review SDRs

for nonconformances on a routine basis. This issue is addressed as part

of Violation 456/86025-01 (Paragraph 3).

3.

Quality __As_suranceAograms for Preoperations Testing

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This inspection was performed to ascertain that the licensee has a program

that will provide adequate controls over the conduct of preoperational

testing and related activities to assure that safety-related equipment and

systems will function as oesigned.

Program adequacy was assessed by review

of the QA program manual, the Braidwood startup manual, site quality

instructions, licensee procedures, selected audits and surveillances,

pre-op test related documents; by discussions with licensee personnel and

by observations of related activities.

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A history of concerns has been developed over the past year by the NRC

regarding SDRs described in Section 4.1.4 of the Braidwood Project Startup

Manual.

This history, including the inspection items detailed in

Paragraph 2 of this report, relates to the failure to review SDRs for

nonconformance and to the apparent inadequacy of instructions relating

to the handling, review and determination of nonconforming conditions.

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To assess this concern, the inspectors interviewed licensee personnel

-involved in startup activities regarding their understanding of what

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procedures are followed for SDR handling and if they are required to review

SDRs for possible nonconformances.

It was apparent from the responses that

SDRs are not reviewed for nonconformances by startup personnel and that

many of the activities involved with the handling of SDRs by startup

support groups are not administratively controlled.

Interviews with

project construction department (PCD) personnel along with review of

documents relating to construction activities in support of the pre-op

testing program established that SDRs may occasionally be reviewed for

nonconformances, but are not routinely done.

A list of 42 SDRs developed by NRC personnel from review of nine different

preoperational test deficiency logs, was reviewed by PCD personnel'for

possible nonconforming conditions. The same list was independently

reviewed by the NRC inspectors. While PCD determined that only one SDR

required identification as a nonconformance and the NRC inspectors believed

that six should be so identified, it was confirmed that a lack of adequate

review for nonconforming conditions exists.

The six SDRs considered to be nonconformances are:

Deficiency No.

Description

Date Issued

DG-10-091

Diesel Generator 1-A required

03-16-85

20.5 seconds to reach speed

and voltage after being at

rest for seven days.

DG-11-092

1DG01KB experiences problems

05-17-85

making 10 second start time

after two week shutdown.

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DG-10-102

1DG01XA experiences problems

05-17-85

making 10 second start time

after two week shutdown.

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DG-10-136

Frequency response plus blackout

12-17-85

safeguards loadings out of spec.

ECCS full flow pre-op, acceptance

Criteria 4.10 requires minimum

of 57 HZ during safeguards loading.

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For the "A" DG, the frequency

dropped to approximately 57 HZ

when the 1A A.F. pump was started.

AF-10-338

Crankabout switch S2, 1-4030AF12,

03-01-86

is not operating correctly. The

switch hangs up and does not show

the engine to start when all

indicators say it should. Switch

should be wired to ready to start

circuit or removed.

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CC-10-416

Valve ICC 94930 is installed

01-24-86

backwards, RCP-ID upper bearing

return isolation valve.

The inspectors felt that the lack of administrative guidelines relating

to handling and review of SDR's by licensee personnel was the major

contributing cause for the failure to identify nonconforming conditions

in SDR's.

Additionally, the NRC inspectors selected one closed deficiency for an

in-depth review. Deficiency No. SX-10-231, dated January 29, 1985, " Motor

Current Exceeds Full Load Running Allowable for ISX01PA," closed on

February 20, 1985, was selected. The Essential Service Water system (SX),

is a safety-related system with a Class 1E motor. The results of the

review included the following:

The NRC Inspectors reviewed the initial pump run (IPR) performed in

April 1962, and observed the following documented results of testing.

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Characteristic

Max./ Min.

Actual

Pump Flow

33,000/4,800

26,200 gpm

Current

157/70

171 amps.

Stator Temp.

70 C

The inspectors established that the design maximum flow is 24,000 gpm

and thus the current value of 171 amps. was, in fact, a nonconforming

overload condition.

It was further learned from the author that

Deficiency No. SX-10-231 was written for this condition on January 29,

1985. However, the deficiency was closed on February 20, 1985, by

attaching a note to the SDR regarding a service factor of 1.15 for the

motor, without evaluation of the nonconforming ccnditions. During

discussions with the author of the attached note he stated that he had

prepared the note in response to an unrelated verbal inquiry regarding

the service water pump motor being slightly in excess of full load

motor condition. He, in addition, stated that he was unaware of its

use to close this SDR.

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The inspectors reviewed the vendor motor manual provided by the motor

supplier Westinghouse Electric Company.

Item No. 6, under Operations

on Page 23, stated that the motor power supply voltage must be

maintained at 5% of the motor nameplate voltage (4,000 volts). This

item was discussed with the licensee and the inspectors expressed

concern that this constraint would impact the system voltage test

required by NUREG 0876 Item 8.2.4.

Later the inspector was infomed

that Westinghouse Electric Company personnel had authored a letter to

CECO's Station Nuclear Engineering Department dated June 17, 1986,

infoming them that the Instruction Leaflet IL-5500A (Vendor Motor

Manual) dated September 1,1978, will be fomally amended with regard

to Step 6 of the instructions given on Page 23, to a voltage variation

- 10% of motor nameplete voltage.

The lack of review of SDRs for identification, disposition, and control

of nonconformances is considered to be a violation of 10 CFR Part 50,

Appendix B, Criterion XV (456/86025-01(DRS)).

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Concerning t:1e new submittal to be sup) lied by Westinghouse Electric

Company, this matter is considered to )e unresolved pending further

review (456/86025-02(DRS)).

4.

Operational Readiness

This inspection was performed to verify that management controls and

procedures,lity, have been documented and implemented. including Quality Ass

of the faci

Operational

readiness was assessed by review of the applicable governing procedures and

instructions, by discussions with licensee personnel and by observation of

activities and documents relating to these procedures and instructions for

the following activities.

a.

QA/QC Administration and Audits

The inspectors verified by document review, discussions with auditors,

and by observation of a sampling of schedules, audits, and certifica-

tion files that the station QA department has established appropriate

controls and mechanisms for performing the operational functions, has

completed qualification and certification of auditors, and is

implementing scheduling and auditing activities.

b.

Maintenance

Through discussions with licensee personnel and review of maintenance

department procedures, the following concerns related to the admini-

stration of the maintenance program were identified.

(1) Administrative procedures describing the scope and program

responsibilities for the licensee's preventative maintenance

program are needed.

The licensee is in the process of addressing

this concern.

(2) Procedures for inservice inspection program administration,

surveillances, and corrective and preventative maintenance for

the electrical and instrument departments are incomplete.

The

licensee stated that the procedures required for fuel load will

be completed by fuel load.

(3) The maintenance history trending program is not structured

to trend on an equipment type basis.

The present system will

identify recurring maintenance by EID number only.

The licensee

should reevaluate the system to ensure all types of recurring

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maintenance activity is trended.

(4) Work request program Procedure 1600-1 instructions are lacking in

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detail for some of the steps noted.

The licensee is reviewing

1600-1 and is considering adding information to areas identified

such as for the Master Mechanics and Technical Staff Supervisor's

review, and disposition of the work package when an item fails

post-maintenance testing.

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Items (1) through (4) above are considered to be an unresolved item pending

further review (456/86025-03(DRS)).

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Surveillance

The surveillance program administrative guidelines were assessed by

review of procedures and discussions with licensee personnel.

The

surveillance program is a computerized system controlled by Procedure

No. BWAP 1400-1, " General Surveillance Program." This system

schedules-allperiodicsurveillancefunctions,includingthose

. required by the Technical Specifications.

The licensee s program

meets regulatory requirements except for the following items.

The licensee has a "GSIN" program which is used to control

calibration /surveillances on safety-related components, some of

which are used'as data points for technical specification required

surveillances.

The licensee has no administrative controls for

this program.

This item is considered to be unresolved pending

further review (456/86025-04(DRS)).

Licensee Procedure No. 1400-1, Section 10, requires that each

department using the general' surveillance program write a general

surveillance procedure specific to their department.

The Mechanical

Maintenance Group was the only department'that had such a procedure.

This item is considered to be unresolved pending further review

(456/86025-05(DRS)).

5.

Unresolved Items

Unresolved items are matters about which more information is required in

order to ascertain whether they are acceptable items, violations or

deviations.

Unresolved items disclosed during this inspection are

identified in Paragraphs 3 and 4 of this inspection report.

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6.

Exit Meeting

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The inspectors met with licensee representatives (denoted in Paragraph 1)

at the Braidwood Station at the conclusion of the inspection. The purpose,

scope and findings of the inspection were summarized.

The inspector also

discussed the likely informational content of this inspection report with

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regard to documents or processes reviewed by the inspector.

The licensee

did not identify any such documents or processes as proprietary.

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