IR 05000454/1987025

Insp Repts 50-454/87-25 & 50-455/87-23 on 870615-26.No Violations Noted.Major Areas Inspected:Audit Program/ Implementation & Onsite Review Function,Corrective Action Program & Surveillance Testing Program

ML20236D053
Person / Time
Site:	Byron
Issue date:	07/21/1987
From:	Ted Carter, Jablonski F, Maclean P, Sutphin R, Vandel T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236D012	List: IR 05000454/1987025 ML20236D009
References
50-454-87-25, 50-455-87-23, NUDOCS 8707300284
Download: ML20236D053 (9)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

i Reports No. 50-454/87025(DRS); No. 50-455/87023(DRS) i Docket Nos. 50-454; 50-455 Licenses No. NPF-37; No. NPF-66 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Byron Station, Units 1 and 2 Inspection At: Byron Site, Byron, Illinois Inspection Conducted: June 15- 6, 1987  ;

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Inspectors: . ,, a n Date 7/3M7

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MA&T. H. Carter ,p/ o47 '

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?.' 6l"S ,hih 7

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ggdag T. E. Vandel 7 -J/-[7 Date / -/

Approved By: .J on k ie Quality Assurance Programs ___Date 7/

Section l Inspection Summary Inspection on June 15-26, 1987 (Reports No. 50-454/87025(DRS);

No. 50-455.87023(DRS))

Areas Inspected: Routine announced inspection for QA program annual ,

review including audit program / implementation and onsite review function; corrective action program; surveillance testing program; maintenance program /

implementation; and training in accordance with selected sections of 1 inspection procedures 35701, 40702, 40704, 40700, 92720, 63725, 62700, 62702 and 4140 Results: Two unresolved items were identified: one in the area of onsite review function and one in the area of maintenance trainin )

PDR ADOCK 05000454 G PDR

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DETAILS 1. Persons Contacted Commonwealth Edison Company (CECO)

• R. Querio, Station Manager W. Burkamper, QA Superintendent

• S Campbell, Office Supervisor

• F. Hornbeak, Technical Staff Supervisor

• T. Joyce, Assistant Superintendent, Technical Services

• R. Pleniewicz, Production Superintendent

• R. Rhoads, Stores Supervisor

• G. Schwartz, Assistant Superintendent Ma cntenance

• M. Snow, Regulatory Assurance Suparvisor

• E. Zittle, Regulatory Assurance Staff

• Denotes those attending the exit meeting on June 26, 1987. Other station technical and administrative personnel were contacted during the course of the inspection and/or were present at the exit meetin . Licensee Action on Previous Inspection Findings (Closed) Open Item (454/84036-01): Turnaver of construction QA records to station records department was incomplete. The transfer of construction QA records was verified as acceptable and complete for Units 1 and 2 by the licensee's QA department on June 18, 198 The inspectors selected examples of construction records including hard copies, microfilmed copies, and radiographs for review. All records were retrieved by the station records department from acceptable storage locations'in a timely manner. No deficiencies were identifie This item is closed, Goen)UnresolvedItem(455/86036-03): Possible improper evaluation of shelf lif Pending completion of licensee review of non metallic items designated as having "non-limited" shelf life, this item remains ope (Closed) Open Item (455/86036-04): Possible use of less than a four to one accuracy ratio in calibration of M&TE without evaluation of acceptabilit Byron Maintenance Memo 87-05, issued June 26, 1987, defines the station's policy on documentation of the evaluation of acceptability where a minimum accuracy ratio of four to one cannot be maintained. The memo was issued to all Byron Maintenance department heads and states that as of the memo issue date, no instances exist at Byron Station where the minimum four to one ratio was not achieve This item is close __ .

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.QA Program R'e view H

The purpose of this portion'of-the inspection was to evaluate th licensee's QA program and its implementation in the areas of auditing,

.and.onsite review. The inspectors reviewed records, interviewed station and corporate personnel, and observed work activities. . Licensee i management involvement and staff. qualifications were' included in the J evaluatio Audit Program / Implementation The inspectors reviewed thirty-one audit reports from 1986 and 1987 ;

in'the areas of technical. specification' adherence, maintenance, corrective action, onsite review, calibration, and staffing and training. The inspectors also reviewed the licensee's 1986 and 1987 audit schedule, auditor qualification records, and accompanied a QA auditor during an ongoing' audit. Inspection results were as follows:

• Audit' reports defined the scope and results of the audit l Checklist questions were typically general but were used by QA auditors as a " doorway" into an activity area. -This technique was profitably used by a QA auditors, and several 1 responses, findings, or observat ns were noted which went 1 beyond the actual checklist quesu.ons. - Questions on areas wit j previously closed findings or observations were frequently t included in the scope of the audi * Unique audit plans and checklists for "non product" audits were prepared and approved prior to performance of the audi Audits were timely and'in accordance with the required ,

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• A controlled computer program was used to track auditing of Technical Specification (TS) line items to ensure complete coverage within five years. The program was also used by the j; QA auditors to coordinate audits of in process TS surveillance 'l performance in addition to record '

• Audit findings and observations were significant and corrective action followup was thorough and well documente * Report distribution routinely included corporate Vice President and general manager Additional followup documentation was provided to corporate project and QA management by bi-monthly and quarterly reports that identified open items which' required management attention for expeditious closure.

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Qualification records reviewed for five lead QA auditors l were up to date and met the licensee's progra l (- _ _ . a

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• The audit observed was performed in a thorough manner and l potential concerns were pursued and resolved by the auditors 1 and QA management. A post audit meeting was held with station management personnel of an appropriate level to ensure timely l completion of required corrective action !

• " Product" audits were used for maintenance activitie Unlike all other audits, the same checklist questions were used for each of the product audits in a particular maintenance area. The inspectors were concerned that complete auditing coverage of'the maintenance program may not have been accomplished by this method. In response to questions, the inspectors were informed that a " maintenance activities"  :

audit recently added to the schedule will be performed in  !

October 1987 and will have unique checklist questions i addressing maintenance program activitie l No violations were identifie Onsite Review Function The inspectors reviewed 14 Onsite Review (OSR) reports in the areas of procedure revisions, FSAR and TS changes, tests and experiments, plant modifications, plant operations and station securit The inspectors also reviewed Byron Aciministrative Procedure (BAP) 1210-1,

" Conduct of Onsite Reviews and Investigations", Revision 5, and associated BAPs in relation to TS Section 6.5.2; reviewed qualification requirements and records for licensee personnel participating in OSRs, and attended an OSR meeting that addressed a proposed Technical Specification change. Inspection results were as i follows: e

• BAP 1210-1 defined the administrative methods for meeting requirements of TS Section 6.5.2. Reviews were accomplished by using different methods and procedures, depending on the review subject. The inspectors noted that the programs requiring review per TS Section 6.5.2 as defined in TS Section 6.8.4, ;

were not included in BAP 1210-1 as requiring OSR. The  !

inspectors were informed that the programs were established, l implemented, and maintained through station procedures, and,

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that since all station procedures and changes thereto receive an OSR per BAP 1210-1 the requireu nt was met. Further review by the inspectors determined that each individual program was established, implemented, and maintained by multiple station

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procedures, some which also covered aspects of other program The inspectors were unable to determine if the review of individual procedures, when new or revised, met the requirement i-for review of total program The inspectors were also unable to determine where the total scope of the programs and associated procedures was defined. This matter is open (454/87025-01; 455/87023-01).

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• The inspector's review of BAPs used to meet the OSR for items-not covered by the main body of BAP 1210-1, such as LERs, station procedures and plant modifications, determined that review / signature requirements were, as'a minimum, equivalent to those defined in BAp 1210-1 and TS Section 6.5.2; distribution requirements were also me * Personnel qualification records for participants in OSRs were reviewe The qualification and selection of participating personnel in the OSR reports reviewed met the licensee's procedural requirement, ANSI N18.7, 1976, and ANSI N18.1, 197 j

• The OSR meeting observed by the inspectors was conducted in accordance with station procedural requirements and adequately i addressed the issue under review, including discussions '

about 50.59 reviews and applicability to Braidwood Statio The report and request for offsite review were issued to the appropriate corporate management levels in a timely manne No violations were identifie .

4. Corrective Action The purpose of this portion of the inspection was to evaluate the licensee's corrective action program, its comprehensiveness, and ability to identify, followup, and correct safety-related problem The inspectors reviewed corrective actions associated with other areas covered by this inspection. Management involvement in timely resolution and completion of corrective actions was also evaluated. The inspection results were as follows:

• The Action Item Record (AIR) program, as defined in BAP 1840-1,  !

Revision 3, provides for assignment, tracking, and closure ,

of corrective action items as a result of LERs, DVRs, DRs,  !

NRC commitments / findings, QA audits and other items identified by  !

station or offsite organization * Determination of corrective actions and trending activities was accomplished by the group assigned for each ite * Status meetings about open AIRS were held monthly between appropriate station management personnel, and monthly status reports were issued to' station management. Due to the lack of a generic station wide corrective action trending process, the inspectors were concerned that the status reports and meatings were potentially unable to a address generic negative trends. In response to questions on this matter the inspectors were informed that required trending is handled through separate programs,

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• Specific ~corre'ctive' actions for various LERs, QA audits and NRC

' commitments'were reviewe Typically, actions were appropriate t ,

the issue and' carried'out in a timely manner. Where necessary, ,

n' ' : management involvement'had'been initiated to expedite closur '

No violations were' identifie " Surveillance Tes' ting

.The purpose of this p'ortion of.the inspection was to determine if the su'rveillance~ testing of' safety-related systems'and components was adequately controlled and scheduled to meet the requirements of the 1 TS and other applicable documents / program The inspectors reviewed BAP 1400-1, " Byron Station Surveillarme Program," ,

Revision.4, and associated procedures; the surveillance matrix computer l programs; surveillance test reports; monitored the status of ongoing surveillance activities; and interviewed the station surveillance i coordinator. The inspection results were as follows:

BAP 1400-1-assigned the responsibility for the surveillance program

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to the station and individual department steveillance coordinator The station surveillance coordinator maintains, updates, and distributes the computer generated surveillance' schedul * Two~ data bases were maintained; one for the procedure /TS.line item matrix, and one' for scheduling and '..istory tracking; both i were' effectively used to ensure complete and timely ccmpliance l with surveillance requirements. The computer automatically l determined the conservative due date based on calculations of 125% i and 325% period * -The scheduling program was used to track numerous other routine activities.and was consequently a cohesive, single source record for use by all applicable group *- Ongoing surveillance were accomplished in accordance with  !

the schedule and a review of the history data for various j TS surveillance indicated the schedule was consistently me .i l

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• Surveillance reports were completed in a timely manner and adequately addressed the requirements, performance, and results  ;

of the surveillanc I

• The station surveillance coordinator was knowledgeable of the requirements, applicability, and mechanics'of the surveillance program and the role and responsibility relative to the control of surveillance activitie No violations were identifie i

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6. Maintenance Program / Implementation i l

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The purpose of this portion of the inspection was to evaluate the i effectiveness of the licensee's maintenance program and implementation in- l 1 the mechanical and electrical areas. Training of personnel who performed maintenance activities was also evaluate Training The inspectors reviewed training records for the mechanical, electrical, and technical staff, and interviewed training and j maintenance personne The inspection results were as follows:

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• All scheduled training in mechanical maintenance was approaching completio * Electrical maintenance training was behind schedule in some categories despite use of the same planning and scheduling j methods used for mechanical training. The inspectors were informed that untrained individuals performed work under the direct supervision of a foreman or the master electrician, as require * Technical staff engineers, who routinely perform vibration analysis on primary plant equipment, were required to be trained and qualified in accordance with BAP 500-4, " Technical Personnel Qualifications", Revision The inspectors reviewed the technical staff surveillance qualification matrix and compared it to training department records for personnel who had completed required training to become qualified Type A and 8 tester The matrix was not a controlled document and could be in error. The licensee was unable to correlate the two lists and could not determine if all personnel used to conduct vibration tests were qualified to do s This matter is unresolved (454/87025-02; 455/87023-02).

No violations were identified, however, one unresolved item was identifie Maintenance Activities The inspectors reviewed applicable maintenance procedures, instructions, and request documentation; observed ongoing work activities; attended daily and monthly maintenance meetings; and interviewed station personnel. The inspection results were as follows:

• Procedures and instructions adequately covered use of work requests, use of approved, current procedures, designation of

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hold points, and overall preventive maintenance activitie _ _ _ _____________________ . _ _ _ _

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• Completed work requests adequately documented work scope and  !

special instructions, replacement parts qualifications, acceptance criteria, and approvals and reviews by appropriate station personne i

• Discussions with job foremen, planners, and technical staff personnel concerning preparation of work instructions, determination of acceptance criteria, and replacement part acceptability established that the issues were adequately understood and satisfactorily resolve J

• Documentation for ongoing work activities was appropriate for the job statu * Interaction cf personnet and division of responsibility between maintenance, the technical staff, and operation analysis departments was acceptably established and appeared to function smoothl No violations were identifie . Conclusions

• QA audits effectively identified significant issues, followed up on corrective actions, met the schedule, and were conducted by well qualified individuals including licensed operator Management involvement, where required was apparen * The onsite review activities met the requirements except in the area of program review. Reviews were carried out by qualified individuals in accordance with approved procedures and addressed technical issues with attention to plant and personnel safet * Corrective actions were adequate for the problems identified and typically completed in a timely manner. When necessary, management involvement expedited completion. Item status was effectively tracked. The tracking system had the potential to be effectively used to trend generic problems in overall plant operations, personnel training, and preventive maintenanc * The surveillance testing program was effectively controlled testing and ensured compliance with requirement * Training was acceptable for mechanical maintenance but behind for electrical; however, no resultant concerns were identifie Technical staff qualifications for Type A and B vibration testing could not be clearly determined in all case * Maintenance activities were performed in accordance with approved procedures, were adequately coordinated between applicable groups, and were well documented. Personnel were typically knowledgeable of job requirements and responsibilities and staff levels appeared sufficient for timely task completio ,

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8. Unresolved Items An unresolved item is a matter about which more information'is required in order to ascertain whether it is.an acceptable item, an-open item, a deviation, or a violation. An unresolved item disclosed during the inspection is discussed in Paragraph 6 . Exit Interview The inspectors met with licensee representatives denoted in Paragraph 1, on June 26, 1987. The purpose and findings of the i inspection were summarized, and the likely informational content of the inspection report with regard to documents or processes was reviewed during the inspection was discussed. The licensee did not identify 'any such documents or processes as proprietar l-1 l

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