IR 05000456/1986016

Safety Insp Repts 50-456/86-16 & 50-457/86-14 on 860330- 0531.No Violation or Deviation Noted.Major Areas Inspected: Meetings,Training & Other Activities.One Area of Concern Re Quality of Release to Operations Process Identified

ML20203D816
Person / Time
Site:	Braidwood
Issue date:	07/01/1986
From:	Gardner R, Garedner R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20203D792	List: IR 05000456/1986016 ML20203D788
References
50-456-86-16, 50-457-86-14, GL-85-15, IEB-75-03, IEB-75-3, IEB-80-06, IEB-80-6, IEB-86-3, IEIN-84-52, IEIN-86-003, IEIN-86-3, NUDOCS 8607210310
Download: ML20203D816 (23)

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION III

Reports No. 50-456/86016(DRP); 50-457/86014(DRP)

Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, IL Inspection Conducted: March 30 through May 31, 1986 Inspectors: T. M. Tongue W. J. Kropp T. E. Taylor M. J. Farber P. R. Pelke Approved By: F,.

$. h e N. Gardner, Chief 7[l![d ReactorProjects Date Section 3A Inspection Summary Inspection on March 30 through May 31, 1986 (Report No.50-456/86016(DRP);

50-457/86014(DRP))

Areas Inspected: Routine, unannounced safety inspection of licensee action on previously identified items; regional request; in process deficiencies; events occurring during the inspection; preoperational testing; integrated hot functional test; plant tours and independent assessments; plant procedures; release to operations; meetings, training and other activities; and INP0 near term operating license audi Results: No violations or deviations were identified. One area of potential concern was identified relating to the quality of the Release to Operations (RTO) process (Para;raph 10).

8607210310 860702 PDR ADOCK 05000456-G PDR

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DETAILS

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Persons Contacted

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Commonwealth Edison Company (CECO)

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Corporate Personnel

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r 4 *A. Miosi, Nuclear Licensing Administrator Braidwood Personnel

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! *M..J. Wallace- Project Manager

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• C. W. Schroeder, Station Services Superintendent

• D. L. Shamblin, Project Construction-Superintendent

• P. L. Barnes, Regulatory Assurance Supervisor

• G. E. Groth, Assistant Construction Superintendent M. E. Lohmann, Assistant Construction Superintendent'

• E. E. Fitzpatrick, Station Manager

! *L. M. Kline, Regulatory Assurance Group Leader

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• C. J. Tomashek, Project Startup Superintendent i H. Zimmerman, Project.Startup Testing Supervisor..

j *D. E. Paquette, Maintenance Assistant Superintendent j' *D. E. O'Brien, Operations Assistant Superintendent

• S. C. Hunsader, Quality Assurance Supervisor

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R. Legner, Senior Operating Engineer G. Masters, Operating Engineer R. Ungren, Operating Engineer F. Willaford, Security Administrator M. Andrews, Station Chemist

R. Lemke, Technical Staff Supervisor l G. Nelson, Assistant Technical Staff Supervisor l

R. E. Aker, Radiation-Chemistry Supervisor i j T. Keith, Lead Health Physicist

*T. W. Simpkin, Regulatory Assurance

! R. Mertogul, Assistant Technical Staff Supervisor

T. E. Quaka, Site Quality Assurance Superintendent  !

• R. D. Kyrouac, Station Quality Assurance Supervisor i T. Meyer, Station Fire Marshall

! *D. A. Boone, Construction _ Field Engineer 1 *G. F. Marcus, Assistant to Manager Quality Assurance j *L. E. Davis, Assistant Superintendent'- Technical Services

! *D. L. Cecchett, Regulatory Assurance

• A. J. D' Antonio, Regulatory Assuranc *J. K. Jasnosz, Regulatory Assurance

, *E.-Wendorf, Project Field Engineer l *M. R. Dougherty, Project Field Engineer-

) . *D.~J. Skoza, Project Field Engineer i *B. M. Peacock, Integrated Leak Rate Test Coordinator .

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• S. H. Stapp, Quality Assurance (Operations)

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Nuclear Installation Services Company (NISCO)

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B. Allen, Lead Engineer r

The inspectors also talked with and interviewed other licensee employees, including members of the-technical and engineering staffs, startup engineers, reactor and auxiliary operators, shift engineers'and foremen, electrical, mechanical and instrument personnel, contract security personnel, and construction personne ~

• Denotes those attending one or more exit interviews conducted on April 17, *

May 8, 22, and 29, 1986, and informally at various times throughout the inspection perio . Licensee Action on Previously Identified ~ Items The inspector reviewed the licensee actions on the following items and the results are as stated: Violations (Closed) 456/84042-11; 457/84038-11: Failure to control activities pertaining to the cleaning of the diesel fuel oil piping. Several documents were issued to resolve the licensee's failure to clean the diesel fuel oil piping in accordance with the requirements of Sargent & Lundy (S&L) Specification L-2739. The following is a-summary of these documents which includes a description of their disposition:

• NCR 720 (Unit 1 only) - This Nonconformance Report (NCR) was issued by the licensee to identify that the Unit 1 diesel fuel '

oil piping was sandblasted instead of being cleaned by acid pickling as required by Specification L-2739. The disposition included revising Specification 1.-2739 (Field Change Request (FCR) No. 17028) to allow sandblasting as an acceptable method of cleaning the diesel fuel oil piping. The justification for revising the specification to allow sandblasting. included:

(1) sandblasting is acceptable to the diesel manufacturer, (2) the design of the system is such that the diesel oil piping in question is in line with four transfer suction-filters whicn are capable of filtering out particles to five microns in size, (3) the diesel generator sets also '

are equipped with fuel filters, and (4) the Unit 1 diesels have completed'over 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of run time without a failure due to plugged fuel filters. This NCR was closed March 5, 198 * FCR No. 17028 (Units 1 and 2) - this FCR was issued to revise '

Specification L-2739 to allow diesel fuel and lube oil piping to be cleaned by one of the following methods:

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(1) Sandblasting followed by blowing out the pipe with compressed ai However, digital thickness measurements i shall be recorded at elbows and curvatures to verify that

. minimum wall thickness requirements have been maintaine .

(2) Interior surface rust in fuel oil piping systems may be cleaned by brushing followed by high pressure water

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flushing, hot oil flushing, or blowing out with compressed ai This FCR was dispositioned by S&L on April 4, 1985, with the above revision incorporated into Specification L-2739 by Amendment No. 9, dated October 18, 198 *- Phillips Getschow (PGCo) NCR No. '6213.(Unit 1) - As a result of the digital thickness measurements performed at the elbows of installed Unit 1 diesel fuel oil piping which had been sand-blasted, PGCo identified three minimum wall violation These violations were identified on PGCo NCR No. 621 These violations were dispositioned "USE-AS-IS" based on S&L calculations 1SA64-PNCR6213, 10026-PNCR6213, and 1SA06-PNCR621 This NCR was closed February 20, 198 The inspector reviewed the supporting documentation pertaining to the closure of the above documents and noted no problems. This item is considered to be close (Closed) 456/84044-04; 457/84040-04: Fasteners utilized in Class 1E seismic cable tray hangers and battery racks did not always meet the requirements of ASTM A307 in regard to the manufacturer's identifica-tion marking. Some of the corrective ~ actions were previously reviewed in Inspection Reports No. 456/85032; 457/85031 and No. 456/85058; 457/85054. The only remaining corrective action to be reviewed was the closure of NCR No. 783. This NCR was issued by the licensee to identify unmarked A307 bolting in vendor supplied equipment. The resident inspector, assisted by a regional specialist, reviewed the-disposition of NCR No. 783 and noted no problems. The disposition was "USE-AS-IS" based on engineering review and testing. This item is considered to be close (Closed) 456/85038-07; 457/85037-05: . Documented instructions did not exist at Pullman to assure that NCRs identified as potentially reportable (50.55(e)) are submitted to the licensee. The licensee's corrective action consisted of Pullman' reviewing all their NCRs issued after December 5, 1984 to determine if the licensee had been notified of all NCRs that were considered potentially reportabl Pullman NCRs issued prior to December 6,.1984 were not reviewed by Pullman since, due to an unrelated issue, these NCRs had previously been' reviewed by the licensee for reportability'.

The review of these Pullman NCRs by the licensee resulted in no NCRs that had not been previously reported being considered reportabl The inspector evaluated Pullman's results of their review of NCRs issued after December 5, 1984 and noted no problems. The corrective action to avoid further violations consisted of revising Pullman Procedure B16.1.F,?Nonconformance," to include a requirement to notify the licensee of'any NCR deemed ~potentially reportable. The inspector reviewed Revision 8 of Procedure B16.1.F and verified that i

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Paragraph 6.6.4 required the notification of the licensee in writing of an NCR that is deemed potentially reportable. _The effective date

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of this procedure was October 21, 1985. The inspector selected several NCR issued after October 21, 1985, and noted_no problem This item is considered to be close (Closed) 456/85038-08; 457/85037-06: -Pullman CAR 002 and CAR 005 were closed without verifying that the corrective action was implemented and effective. The licensee's corrective action consisted of Pullman's Quality Assurance organization performing surveillances to verify that all corrective actions required by CAR's 002 and 005 were properly implemented and effectiv The inspector reviewed Pullman Surveillances QA-S-85-111, QA-S-85-092, and QA-S-85-09 These surveillances addressed the implementation and effectiveness of the corrective actions associated with CARS 002 and 005. The licensee's corrective action to avoid further violations consisted of revising Pullman Procedure B16.2.F, " Corrective Action," to enhance the requirements for verifying the completion and effectiveness of corrective actions prior to closure.of a CAR. The inspector reviewed Revision 2 of Procedure B16.2.F and verified that the procedure was enhanced. This enhancement included the requirement of attaching to the CAR copies of documentation that supports the verification of_the implementation and effectiveness of completed corrective action The effective date for Procedure B16.2.F, Revision 2, was January 10, 1986. The inspector reviewed the closure of CARS 001 and 006 and determined that the documentation of the closures were in accordance with Procedure B16.2.F, Revision 2. This item is considered to be close (Closed) 456/85048-03; 457/85047-03: Wiring in compartment C3 of -

Motor Control Center-(MCC) 131X2 was not in accordance with Drawings No. 20E-1-4663C and 20E-1-4663F. In addition, a jumper not shown on Drawing No. 20E-1-4663C, Revision M was found terminated in the field between Points 3 and 3 The inspector reviewed the licensee's response dated March 11, 198 The licensee determined that the jumper between Points 3 and 3A was correct. The inspector verified that this jumper was in accordance with Internal Wiring Diagram No. 20E-1-4659A, Revision G, Figure 2, which is referenced on No. 20E-1-4663C. L. K. Comstock (LKC) issued ICR No. 12,253 on October 4, 1985, to document no terminations at Points 1, 3A, X2, 9, 15, 16, 17, and'1 LKC Rework Requests (RWRs)-

No. 11596 andfl1597 were issued on February 25, 1986, to complete the internal wiring. The work was completed and QC inspected on February 28, 1986. The ICR was subsequently closed on March 5, 198 The inspector reviewed the revisions of LKC Procedure 4.3.16, which controls RWR' activities, from October 1980 to present and determined that'the procedure has been significantly enhanced since the deficient installation occurred in August 198 This item is considered to be closed, i

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b. Open Items

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(Closed) 456/84042-03; 457/84038-03: Instrumentation Retrofit-Verification (IRV) Program identified numerous deficiencies in the three inch clearance requirement. A review of several IRV packages revealed that deficiencies.in the three inch clearance requirement were properly noted on the IRV drawing The inspector reviewed IRV packages for instruments 1FT-AF011-1,1FT-AF015-1 and 1FT-CS011- The IRV drawings were submitted to S&L on FCRs. The FCRs associated with these instruments were FCR 20248 (1FT-AF011-1), FCR 19405 (1FT-AF015-1), and FCR 18893 (1FT-CS011-2). This item is considered to be close (0 pen) 456/85008-11(DRS): Verification of proper installation of containment spray pump impeller The inspector _ reviewed Field Change Orders (FCO) 1CS-20891 and 1CS-20024 where measurements showed that the A pump impeller was smaller than the B pump, as required. The inspector also reviewed a November 5, 1985 memorandum which outlined three action items to ensure that the impellers are not switched in the future. The items are as follows:

(1) A letter, identifying the A pump as having a smaller impeller and cautioning against switching impellers, was to be entered in the pump instruction manual (2) A similar caution was to be entered in the pumps' Maintenance History file (3) Identification tags were to be affixed to 'each pum Upon review the inspector determined that Item (3) had not been completed. This item will remain open pending' completion of Item (3).

(Closed) 456/85015-02: While inspecting the shims on the steam generator inner frame support connections, identified on Drawings No. S-1102, the inspector noticed that the nuts on the threaded rod that held the shims in place were not tight. Subsequent review of the documentation, including process Control Checklist No. 3009-CCE-126, identified that the required tightness or torque value for the half inch diameter nuts had not-been establishe During Inspection No. 456/85032,- the inspector stated that the nuts were loose because the shimming would be completed during Hot Functional Testing. S&L determined that there'is no design requirement to tighten the bolts in that the shims cannot fall out whether or not the nuts are tight. However, S&L recommended that once shimming operations are complete, the contractor.should tighten the nuts snug tight. Hot Functional Testing was completed for Unit 1 on April 21, 1986. During this inspection, the inspector observed that the half inch nuts were tight on the four Unit 1 steam generator The inspector reviewed the NISCO Process Control Sheets for the steam generator inner to outer frame hot shimming. As an example, Process Control Sheet No. 3009-CCE-461 documents that the Loop 4 1/2" nuts were snug tightened, which QC had verified on April 9,_1986. This item is considered to be closed for Unit .

(Closed) 456/85032-04; 457/85031-04: IE Information Notice No. 84-52, Supplement 1, dated May 8, 1985, identified two vendors, Phoenix Steel

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and LTV Steel Company, which had hardware deficiencies. The hardware deficiencies pertained to the production and shipment of seamless carbon steel pipe. Portions of this pipe did not meet the required minimum wall thickness because of inadequate manufacturing process controls and inadequate inspection methods. To assure that piping received at Braidwood which was furnished by the two vendors identi-fied in Supplement 1 of Information Notice No. 84-52 was acceptable, the licensee directed PGCo to perform thickness examinations on this piping. A review of material traceability computer logs and receipt records revealed that 174 pieces of pipe (approximately 3100 feet)

were received at Braidwood from Phoenix Steel and LTV. PGCo measured the wall thickness at four intervals (every 90* on each end of each section of pipe). The inspector reviewed the results of these measurements and no problems were noted. This item is considered to be close (Closed) 456/85038-02; 457/85037-02: PGCo NCR No. 5337 identified Essential Service Water (ESW) spools with base metal weld repairs which were not subsequently radiographed as required by ASME Section III. The portion of NCR No. 5337 which pertained to this open item was dispositioned "USE-AS-IS" by S&L. The justification for the disposition was documented on S&L Design Information Transmittal (DIT) No. BR-EMD-0060-0. The DIT identified that the Summer 1975 Addenda of ASME Section III, Subsection ND, required radiography for final inspection of base metal weld repairs whose repair cavity exceeded 10% of the wall thickness. However, the DIT further stated that the Winter 1976 Addenda and later editions of ASME Section III Subsection ND allowed magnetic particle examination for these types of weld repairs provided: (a) the welded joints did not require radiography, and (b) the welded repair does not exceed 10 square inches of surface area. S&L issued ECN No. 30317 to adopt the Winter 1976 Addenda of ASME Section III. The weld repairs in question had a magnetic particle examination. This item is considered to be close (Closed) 456/85053-01: The FSAR requires a white monitor light on the Main Control Board (MCB) to alert the operator that the ESW suction valves are not fully open. The inspector reviewed proposed Amendment No. 47 to the Braidwood FSA This amendment deletes Item b. under FSAR Section 10.4.9.2.2.2, which identifies the white monitor light on the MCB. The deletion of this white monitor light does not diminish the operator's ability to determine that the ESW suction valves (1AF06 A&B, 1AF017 A&B) are not fully open. There are colored indicating lights to show that the valves are closed and cther indicating lights to indicate the valves are open. Both lights will be energized when a valve is in a intermediate positio i This item is considered to be close I 7 1

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(Closed) 456/85053-02: Procedure Bw0P--AF-4,'" Draining.the AFW'

System," requires unlocking and closing valve SX205 (Recirculation

. Return to SX for the_AFW pumps). 1This procedure did not address reopening and locking valve SX205 after draining the AFW system Procedure Bw0P AF-1, " Fill and Vent of the Auxiliary FeedwaterL System," Revision 1, was reviewed by the inspector.' The inspector verified that a step was added to verify. valve SX205 was locked ope Also, the inspector verified that Bw0P SX-M1 and SX-M2,." Essential Service Water System Mechanical Lineups," have proposed revisions to identify valve SX205 as " locked open" instead of "open." .This-item is considered to be close (0 pen) 456/85053-04: The procedures reviewed for lining up the AFW system for standby operation and for emergency operation does not address the diesel AFW pump battery selector switch. The~ inspector- ,

verified that Bw0P AF2, Alignment for Standby Operation of-Auxiliary- '

Feedwater Systems," Revision 0, Step C.2 requires.that Bw0P AF-1 be

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completed.as a prerequisite. Bw0P.AF-1, " Fill and Vent ofcthe Auxiliary Feedwater System," Revision 1, Step C.2 requires that the AFW system to be aligned in accordance with Bw0P E1/E2. Bw0P E1/E2,

" Auxiliary Feedwater System Electrical Lineup," lists the position 1 required for the battery selector switch as No. 1/No. 2 (Position No. 1 or Position No. 2). These procedural controls adequately address the battery switch for the standby operation of the AFW systems. The inspector reviewed the procedures for,the emergency i operation of the AFW sy" ste Procedure 18w0A PRI-5, " Control Room Inaccessibility Unit 1, Revision 1, Step 8.a.6 did address selecting the other battery bank and repeating the start sequence if the diesel AFW pump fails to crank during a local start. However, Procedure BwCA-0.0, Revision 1, " Loss of AC Power - Unit 1,"

Step 3.a.1, does not address the steps for locally starting the diesel AFW pump in the same detail as Procedure 18w0A PRI- It states that if the diesel AFW pump is not running, then manually or locally start the diesel AFW pump. There is no requirement for selecting the other battery bank if the diesel AFW pump does not crank.' Discussions with the licensee revealed that a procedure will be written that will address the steps for locally starting the diesel AFW pump. Until this procedure is written and issued, this item will remain ope (0 pen) 456/85053-09(DRP); 457/85051-04(DRP): Discrepancies with Safety Injection drawings and procedures. The inipector was informed by the licensee staff that at the time of inspection 1A0VSI-0943 had'

been removed to allow other maintenance in the area and that it had

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been inadvertently deleted from the drawing. The inspector verified that the valve was reinstalled and that it was now shown on th ,'

current revision of the correct Safety Injection drawin Deficiencies SI-12-227 and SI-12-228 were written to add missing val _ves to the appropriate drawings'and valves missing from the '

Prestart Mechanical Lineup will appear on Revision 1 to the lineup, Bw0P-SI-M1. This item will' remain open pending closure of the deficiencies and issuance of the revised prestart mechanical lineu L

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(Closed) 456/85057(DRP); 457/85053(DRP) Paragraph 14 - Fire Protection:

A Potential Failure of Hoses on a Number of Fire Extinguishers. On ' '

April 16, 1986, the station Fire Marshall informed the Senior Resident Inspector - Operations that all of the affected hoses had been

! replaced and the removed hoses had been' destroyed. This item is

. considered closed.

. -(Closed) 456/84023-02: Termination of instrument 1FT-0657 (Reactor

. Coolant Pump 1C Bearing CCW Flow). The inspector reviewed wiring L

Diagram No. 20E-1-4109N, Revision K which provides for a splice between Cable No. 1CC300 and 1FT-0657. Note 80 to 4109N requires a

} Raychem NPKV-2-14 splice kit at the termination. The termination was j- made on February 9, 198 The inspector reviewed the LKC QC  :

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Inspection Checklist for the termination which did not document the

, use of the splice kit. However, the in process inspection of the

splice was documented on the termination card. The inspector reviewed the LKC QC Inspection Checklist for similar transmitter 1FT-0660 which correctly documented the use of the_ splice kit (inspection of the

} 1FT-0660 and 1FT-0657 terminations was performed by the same

! inspector). The QC inspector stated that the checklist for 1FT-0657

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was in error and he committed to field verify and correct the ,

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i inspection checklist. The inspector reviewed the revised checklist

and it was found to be acceptable. This item is considered to be i closed.

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! (Closed) 456/83009-03; 457/83009-03: PGCo records did not indicate

that bends were made in accordance with the ASME Code or PGCo i

Procedure PGCP-11, " Cold Bending of two inch and Under Pipe and Tube."

! To evaluate the bending process, a total of 64 pipe bends were checked

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for ovality and wall thickness. Two instances of minor wall thinning

were reported and both cases were deemed acceptable by S& These t wall reductions were not specifically due to.the pipe bending process

! because the reductions extended into straight portions of the pipe.

i Six instances of slightly excess ovality were reported. Three of the

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six were just over the ASME Sec. tion III eight percent criteria. Based '

i on a reasonable field measurement accuracy of plus or minus 1/64", these j three quality valves were considered to be in compliance with the ASME ,

i code requirement. The other three ovality values ranged from 9.6% to 10.36%. S&L calculations have confirmed ovality values up to 16% are j'

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acceptable. Based on the 100' bends sampled in the Braidwood <

j ' Construction. Assessment Program (BCAP) and the 64 bends specifically l' sampled for this unresolved item, S&L concluded that the results of l both samples clearly demonstrated that: (1) the degree of ovality ,

problems were only slightly above the ASME criteria, and (2) the ' t

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number of bends with excess ovality is reasonably low (approximately ,

l five percent) and consistent with expected measurement accuracie Based on these conclusions, S&L determined that the quality of pipe bending' activities was adequate to meet system design requircaent ,

j ' The inspector reviewed S&L's evaluation, which was documented in

, DIT No. BR-PM0F-0212-0, and noted no problem This item is considered to be closed.

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(Closed) 456/84006-03; 457/84006-03: MTV program included a i requirement that installed quantities be reviewed in relacion to i

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requisitioned quantities for safety-related pip The inspector i reviewed the PGCo Procedure QCP B31, Revision 2, " Material Trace-j ability Verification," and determined that Paragraph 10.4 required a material usage check. This check consisted of a comparison petween

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the quantity or footage of material requested on the^PGCo Stores-

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Request and the quantity of footage of material identified in the l PGCo installation drawing. -The MTV program implementation was

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L evaluated by Regional Specialists with the'results documented in Inspection Reports No. 456/85061; 457/85057. This item is considered to be closed.

! (Closed) 456/84009-11(DRP); 457/84009-11(DRP):. Auxiliary Feed Minimum j Flow Lines. The inspector reviewed the licensee's file for this item-i which contained a memorandum which explained that the flow restricting .

j orifices in the minimum flow lines would prevent the diversion of flow j from the steam generators. These orifices are located such that a j potential missile from the diesel would not damage them. During pump i operation these orifices control recirculation flow to the condensate i storage tank which is at atmospheric pressure. In the event that the i minimum flow recirculation lines were to be damaged, the flow orifices j would limit the flow to the same amount as to the condensate storage

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considered closed.

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j (Closed) 456/84041-01 (DRS): Clarification of ANSI 19.7 Controls for i Preoperational Activities. A meeting was held on January 23, 1986, in i which those activities controlled by either ANSI 18.7 or N45.2 were j identified. This meeting was followed up by an A. Miosi' letter to

] J. G. Keppler dated January 23, 1986, which clearly identified those j preoperational activities which are controlled by ANSI 18.7 and those

}. which are controlled by N45.2. This item is considered to be closed.

i l (Closed) 456/85052-01; 457/85050-01: A pneumatic controller was 1 stored by the Unit 1 motor driven Auxiliary Feedwater Pump without i the necessary identification to determine its construction status 1 and five ASME Section III, Class I valve bonnet and discs were i stored in an undesignated storage area. The licensee revised

{ . Procedure PGCP-1, " Control of FCOs," to require when practical,

all valve internal parts to be bagged and tagged'when valves are i disassembled for an extended period of time. .The revision also

! required parts to be stored in a manner which will preclude damage and provide ready access for reassembly. These requirements'were ,

incorporated into Revision 15 of PGCP-1 and the inspector verified -

that the appropriate training of PGCo personnel was conducted. The I inspector has not identified any further-instances where parts of valves have been improperly. stored. This item is considered to be

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(Closed) 456/85028-05: It was previously identified that conduits of redundant divisions were observed to be routed next to each other with

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less than one inch separation. Instrument ESF cables 1AR227 and 1AR228 in Division I conduit CIA 5334 violated the cable separation criteria with' cables 1AR229, 1AR230, 1AR231, and 1AR232 in Division II conduit CIA 5351.. The above configuration had been installed per S&L Drawing No. 20E-1-3353, D01, Revision P, which required that the two conduits C1A5334 and CIA 5351 enter a junction box from the to Revision R of Drawing No. 20E-1-3353, D01 revised the routing of the Division II conduit. On' June 29, 1985, LKC RWR No. 2243 was issued-and required that conduit CIA 5351 be installed per the new desig The inspector observed the as-built installation of conduit CIA 5351'

and noted that it enters the junction box from the bottom in accordance with Drawing No. 20E-13353, D01, Revision In addition, it was observed that the separation criteria between redundant divisions was met in the junction box. This item is considered to be close ,

d. 10 CFR 50.55(e) Reports The inspector reviewed the following reports and the findings are as stated:

(Closed) 456/83-11-EE; 457/83-11-EE: On July 29, 1983, the licensee reported a deficiency per 10 CFR 50.55(e) regarding anchor bolt installations for the Diesel Oil Storage and Recycle Holdup tank The tanks involved were 1001TA, B, C, D; 20001TA, B; and 0AB01T The licensee issued NCR No. 555 to track this deficiency. CECO QA conducted Surveillances No. 4538 and 4548 to verify that NCR No. 555 was properly resolved. This deficiency is the same as Unresolved Item No. 456/83008-01; 457/83008-01 which was closed in Inspection Report No. 456/85017; 457/85018. This item is considered to be close (Closed) 456/85-03-EE; 457/85-03-EE: Deficiencies identified during the conduct of the Instrumentation Installation Reverification (IRV)

Program. The initial scope of the IRV program was judged by the licensee as not reportable in August 1983. As a result of subsequent licensee audits and NRC inspections, deficiencies in the PGCo QC inspections of instrumentation installations were identifie Therefore, the scope of the IRV program was expanded such that upon reevaluation by the licensee, it was deemed reportable per 10 CFR 50.55(e). In January 1984, PGCo's instrumentation installation and inspection procedures were revised to include the required specification criteri Previously installed instrumentation was reinspected and the associated documentation was reviewed to ensure that-these installations were in accordance with the specified requirements (design and revised procedures). The inspector selected four instruments reinspected under of the IRV program to verify that the installation and documentation _are acceptabl This item is considered to be close .-

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(0 pen)~456/85-05-EE: High Energy Line Breaks.in the Auxiliary Building. The licensee has developed modifications which require

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installation of temperature detectors in the affected spaces that will cause automatic isolation of the steam generator blowdown and auxiliary steam systems. This will include installation of some additional valves and controls. This will also require development of associated procedures as committed. Design. change submittals have been sent to Office of the Nuclear Reactor Regulation (NRR) for review and are waiting approval pending answers to some additional questions. This item will remain open until the modificat:ons are installed and tested; and the procedures are developed,~ approved, and implemente (Closed) 456/85007-EE; 457/85007-EE: . Degradation of diesel'

generators, faulty rpm reading. The inspector reviewed completed LKC RWR Travelers No. 11436, 11445, and 11738, written to install the DC/DC Converter identified as the solution to the problem.in-Ceco's final 10 CFR 50.55(e) report. The inspector verified that-the DC/DC Converters were installed as stated,'that the Material Requisition Request (MRR) on the converters was the same as that on the RWR, and that the diesel-generator tachometer indicated zero when the diesel was secured. This item is considered close (Closed) 456/86-01-EE; 457/86-01-EE: Misoriented Burnable Poison Assembly. Through receipt inspections, the licensee identified a new fuel assembly with the burnable poison rodlets misoriented by 90* rotation as viewed from the top of the fuel assembly. The licensee, with Westinghouse, conducted a safety analysis and found that if the assembly had been used, peaking factors would have been less than technical specification limits even if it had been moved closer to the center of the core in a later fuel cycle. The licensee also conducted a reinspection of all asymmetric burnable poison assemblies onsite and found no further deficiencies. The affected burnable poison assembly was returned to the fuel supplier for repai Subsequently, the assembly was assembled correctly and returned to the site. The licensee has committed to continue inspecting new fuel for similar discrepancies. In addition, the fuel supplier, Westinghouse,

.has committed to institute changes in their manufacturing and inspection practices to prevent recurrence. This item is considered to be close IE Bulletin Followup The following IE Bulletin was reviewed by the inspector to determine if: (1) the licensee's written respomie was submitted within the time limitations stated in the bulletin,-(2) the written response included ~

all'information required to be' reported (3) the written response included adequate corrective action commitments based on information presented in the bulletin and the licensee's response,-(4) licensee management forwarded copies of the written response to the required-onsite management representatives, (5) information d kcussed in the licensee's response was accurate, and (6) the corrective action taken was as described in the respens L_

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(Closed) Bulletin 75-03:. Abnormal occurrences-in which safety-related solenoid air pilot valves manufactured by Automatic Switch Company

(ASCo) failed to operate properly due to an incorrect lower disc spring and/or improper lever to lower disc stem clearance. The .

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licensee has determined that there are no ASCo valves of the affected model number presently installed in' safety-related systems as of January 28, 198 The Primary Process Sampling (PS) system has valves that are not yet installed. These valves will be inspected after installation. Braidwood Commitment 20-85-010 has been issued to verify the model numbers of the ASCo valves in the PS system. The PS system is not classified as a safety-related system. This item is .

considered to be closed, Allegation Followup (Closed) RIII-86-A-0008: On January 7,.1986, two individuals contacted the resident inspector and provided concerns they had with-the S&L disposition of Midway NCRs Nos. 31 and 32. Midway is the site coatings contractor. The NCRs documented that the coatings in the Units 1 and 2 containments were reworked in 1978 using a coating system not qualified to a Design Basis Accident (DBA) in accordance with ANSI N101.2. S&L's disposition was "USE-AS-IS." This disposition was based on a test program using pull tests which are described in ANSI N5.1 The two individuals did not believe that there is a correlation between pull tests and the actual testing of the' coating system to DBA standards. The two individuals had previously discussed their concerns with S&L, Ceco, Midway and Quality First personne An interim review of this allegation is documented in Paragraph 7 of Inspection Report 456/85058; 457/85054 dated February 10, 198 t On January 23, 1986, a meeting was held by the licensee to discuss the disposition of the NCRs. =The licensee' presented their position as to why pull tests, used as a basis for dispositioning the NCRs, was acceptable in lieu of performing DBA testing in accordance with ANSI 101.2. As a result of this meeting the licensee committed to submit data which supports their position to NRR for review. In a ,

letter dated January 31, 1986 from Charles E. Norelius to'T. M. Novak, i Region III transferred lead responsibility for the concerns to NR Ceco provided technical data to NRR in a letter from D. H. Smith to H.~ R. Denton dated January 28, 1986, and a letter from A. D. Miosi to H. R. Denton dated February 10, 1986.. On February 4, 1986, a meeting was held in Bethesda, Maryland between. members of the NRC staff, Ceco, S&L, and Carboline Company (paint coatings' manufacturer). This meeting is documented by J. A. Stevens (NRR) in a Meeting-Summary dated April 4, 198 The Braidwood containment liner coating system consists of a prime coat of Carbo Zinc 11 (3 to 6 mils dry film thickness (DFT)) over the entire surface and a finish coat of Phenoline 305 (4 to 6 mils DFT)

from Elevation 377'-0" to 436'-0". The prime coat was applied in the shop with the exception of plate edges which were coated after the-liner seam welding was complete ,

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The prime coat of Carbo Zinc 11 had become aged and weathered; therefore, it was restored prior to applying the finish coat of

- Phenoline 305. The restoration consisted of light sand blasting the criginal coat of Carbo Zinc 11, which reduced the DFT by approximately 50%, and applying a second coat of Carbo Zinc 11 to restore the original thickness of the prime coa During a review of coating records, an inspector identified a concern regarding the interpretation of the coating manufacturer's application instruction relative to the field application of Carbo Zinc 1 Note (a) of the instructions recommends that to recoat Carbo Zinc 11 -

thin 50%. The field application was performed at normal thinning of 0 to 12%, as described in the manufacturer's application instruction Midway NCRs Nos. 31 and 32 and CECO NCR No. 748 were written to address this concern. Various adhesion tests were performed which demonstrated that Carbo Zinc 11 behaves monolithically, regardless of the thinning ratio used for the second application. Carboline has reviewed the application method and adhesion test results. They concluded that the 50% thinning recommendation provided in their application instruction does not apply, but rather the normal thinning provisions of their instructions do apply to the conditions of the Braidwood Station containment line In a memorandum from T. M. Novak to Charles E. Norelius dated April 14, 1986, NRR concluded that the original protective coating system at Braidwood was qualified for the postulated design basis accident conditions. In subsequent recoating operations at Braidwood, the Carbo Zinc 11 was thinned up to 12%. Laboratory tests conducted at Oak Ridge National Laboratory have shown that Carbo Zinc 11 coating systems, when recoated with 12.5% and 30% thinning, successfully withstood the DBA condition tests. Furthermore, adhesion tests on Carbo Zinc 11 recoating systems, with thinning of up to 50%, indicate that multiple coatings act as a monolithic layer. Consequently, the staff has concluded that differing thinning ratios for Carbo Zinc 11 recoating do not adversely influence its behavioral characteristic The existing containment liner coating system at Braidwood Station, Units 1 and 2, should provide protection essentially equivalent to that of the original coating system, and is, therefore, acceptabl Based on the above, the inspector concluded that the alleger's concern that the Braidwood coating system is not qualified is not substantiated and this allegation is considered to be close Closed (RIII-86-A-0057): In a deposition of an LKC QC inspector before the Atomic Safety & Licensing Board on February 25, 1986, he alleged that he had overheard an LKC supervisor direct a document reviewer to alter a drawing revision on an inspection record. The QC inspector perceived this action as possible intimidatio The inspector interviewed the document reviewer identified by the QC inspector and asked him if he was intimidated into revising l inspection records. He stated that there were discussions between

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himself and LKC supervision concerning inspection record However, he stated tnat these discussions were not intimidating but rather

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were discussions that would have been expected during document review He knew of no document reviewers who had been intimidated into revising inspection records. Subsequent to the deposition, the QC inspector submitted a letter listing his concerns to the licensee's Quality First organization. The letter did not identify the intimidation of document reviewers to alter records as one of his concerns. Additionally, the licensee's investigation of his concerns did not identify any examples of reviewers being intimidated to alter record Based on the above, this allegation is not substantiated and is considered to be close No violations or deviations were identifie . Regional Request By memorandum, dated March 27, 1986, Region III requested that the resident inspector gather pertinent information related to the licensee's action on

IE Information Notice No. 86-03, " Potential Deficiencies in Environmental

Qualification of Limitorque Motor Valve Operator Wiring," and Generic l Letter 85-15, " Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants." The information in the licensee review packages and a related 10 CFR 50.55(e) report (81-01) were forwarded to Region III on April 10, 198 No violations or deviations were identifie . In process Deficiencies The inspector reviewed over 50 deficiency documents issued by the site

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mechanical contractor, PGCo. The documents (9006's) reviewed were issued by PGCo QC for deficiencies identified during in process inspections. The 9006's selected pertained to deficiencies in concrete expansion anchors (CEA). The inspector reviewed approximately ten 9006's to verify proper close out. These 9006's identified deficiencies such as: no torque, slippage, improper depth, etc. In all cases, there were inspection records traceable to the appropriate 9006 substantiating that these deficiencies were properly repaired and reinspected. There was no evidence that CEA deficiencies identified on a 9006 were being dispositioned "USE-AS-IS" without proper review by the appropriate organization ; No violations or deviations were identifie . Events Occurring During the Inspection

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Security Events On May 20, 1986, the licensee informed the resident inspectors of an event where a security post was improperly attended. The resident inspectors and

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the licensee contacted the Region III Chief, Safeguards Section and the licensee submitted a written report. This matter will be reviewed by a

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Region III security specialist during a future inspectio No violations or deviations were identifie . Preoperational Testing During the inspection period, the inspector observed portions of preoperational tests. The observation included verification that properly approved procedures were available and being followed, that data was properly recorded and within the allowable band specified in the procedure, that out-of-service tags were properly applied as necessary, procedure entries and exits were properly executed, instruments were properly calibrated, deficiencies identified were properly resolved and/or recorded for resolution, and that applicable regulatory requirements were met. The inspector also reviewed applicable portions of the FSAR and draft technical specifications for compariso During the inspection, the inspector observed portions of the following tests:

BwPT-DG-10, " Diesel Generators" BwPT-RY-17, " Pressurizer" BwPT-VP-12, " Containment Ventilation" BwPT-EF-12, "EF Logic and Time Response" BwPT-PC-11, " Integrated Leak Rate Test (ILRT)"

BwPT-EF-11, "ECCS Full Flow" While conducting the ECCS full flow tests, the licensee encountered some difficulties with leakage past the boot seal (reactor vessel to reactor cavity seal) and the cover gaskets for the nuclear instrument wells. The licensee conducted an evaluation of the problem and has come up with several corrective actions, such as using a new boot seal (less than or equal to the age recommended by the manufacturer) for each outage plus redesign of the NIS cover gaskets and machining the seal surfaces. The licensee has agreed to keep the resident inspectors informed of any )

further developments on this matte i No violations or deviations were identifie I 7. Integrated Hot Functional Test (IHF)

On April 19, 1986, the licensee completed the IHF testing on Unit Through observations of records, witnessing tests, and interviews with l licensee personnel, the inspectors evaluated the conduct of the tests, ,

acceptability of results, and performance of personnel. The inspectors l observed shift crew personnel and management control, verified that properly approved procedures were available and used, crew requirements were met, test prerequisites were met, proper plant systems were in service, special test equipment was calibrated and in service as needed, crew actions were timely and correct, that deficiencies and test problems

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were documented, test changes were processed in an approved manner, and data was collected for final analysis by proper personnel. Test results

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indicated that acceptance criteria were met. These inspections were done concurrently with regional inspectors from the Division of Reactor Safety -

Test Programs Section (TPS).

The inspectors noted that the licensee had taken extra effort to assure proper access control in the control room and other affected spaces in the plant. In addition, special attention and actions were taken to ccntrol the chemistry of water used in the testin On April 1, 1986, the licensee conducted the first of a series of Main Turbine rolls up to the final roll and paralleling the generator to the grid on April 10, 1986. On several of the tests the inspectors observed activities including crew briefings prior to the tes The inspector also monitored the licensee's limiting parameters during the tests, e.g.,

pressurizer level and pressure, reactor coolant temperature, and steam generator level to verify that they did not exceed the predetermined

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administrative limits. The turbine rolls were well planned. The IHF testing was accomplished by well qualified personnel, the licensee stayed close to the planned schedule, and activities in general were accomplished in a professional manner.

! No violations or deviations were identifie . Plant Tours and Independent Assessments The inspectors conducted routine plant tours during the inspection period to make an independent assessment of equipment conditions, plant conditions, construction activities, security, fire protection, general personnel safety, housekeeping, and adherence to applicable regulatory requirement During the tours, the inspector reviewed various logs, daily orders, interviewed personnel, attended shift briefings, witnessed various construction work activities, and independently determined equipment status. During the shift changes, the inspector observed operator and shift engineer turnovers and panel walkdown While on a tour of the Unit 2 work areas, the inspectors noted various pieces of containment spray and residual heat removal (RHR) pipe which did not have their ends properly protected. In addition, carbon steel bolts were being stored in the RHR suction pipe. This situation was brought to the attention of the licensee's management personnel. The licensee took immediate action to resolve these conditions. The Unit 2 housekeeping will be closely monitored in the future by the inspectors to evaluate the effectiveness of the licenset's action No violations or deviations were identifie I

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9. Plant Procedures

General An inspection was conducted to confirm that the plant procedure system is adequate to control safety-related operations within applicable regulatory requirements and to determine the adequacy of management controls in implementing and maintaining a viable procedure syste The inspector verified that the licensee has or is developing administrative controls for review, approval, and periodic updating of all station procedures. The inspector verified that the licensee's system had responsibilities in writing to assure that procedures are reviewed, updated, and approved as required, including 10 CFR 50.59 consideration The inspector verified that the licensee had established controls in writing (administrative procedures) for preparation of procedures, including format and content, issuing new and revised procedures, control and disposal of outdated procedures, issuing and controlling temporary procedures and temporary procedure changes, that the onsite review of procedures is consistent and that there exists a means to assure training on the above. Regarding standing orders or Special orders, the licensee has administrative controls for Operating orders, Operating memcrandum, and Daily orders that are issued with appropriate reviews and approval The licensee's procedure system was compared to the requirements of the following documents and was found to be acceptable:

Reg. Guide 1.33, " Quality Assurance Program Requirements" ANSI N18.7, 1972 and 1976 as appropriate Commonwealth Edison Quality Assurance Manual, Quality Requirement No. 5 and Quality Procedure QP No. 5-51 Proposed Technical Specifications - Section 6, " Administrative Controls" FSAR Section 13.0 Conduct of Operations, Subsection 13.6, " Plant Procedure" The following Braidwood administrative procedures were reviewed as part of this inspection:

BwAP 300-1 Conduct of Operations Revision 0 BwAP 350-1 Operating Logs and Records Revision 0 BwAP 350-2 Daily Order Log Revision 1 BwAP 350-3 Special Operating Orders Revision 0 BwAP 360-101 Operating Department Procedure Validation Revision 0 BwAP 1205-1 Selection and Authority of Onsite Review Revision 2 Committee BwAP 1205-2 Onsite Review of Procedures Revision 3 BwAP 1205-3 Onsite Review and Investigation Function Revision 3 BwAP 1205-4 Onsite Review Notice Revision 0 BwAP 1205-5 Signature Alternatives for Procedure Revision 1 Content and Technical Review BwAP 1300-1 Station Procedure Manuals Revision 3

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BwAP 1300-3 Preparation and Approval of Temporary Revision 2 ~

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BwAP 1300-5 Station Procedure Distribution ' Revision 3

! BwAP 1300-6 Use of. Procedure Omissio'n Sheets Revision 2 Procedure for Using Request for

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BwAP 1300-7 Revision 0 Notification to Implement Procedures BwAP 1800-1 Byron /Braidwood Operating Commitment Revision 1

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Standardization Program Through an interview with the station training supervisor, the inspector l was informed that the licensee is developing and implementing a program-I whereby the training organization is made aware of new and modified procedures. The plan will provide for training appropriate personnel

i on new and modified procedures through required reading and licensing preparation classes. Since the first group of station personnel recently completed their licensing exams, the plan will ba uiiplemented such that there is continuity for those' peopl _ ,

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' The inspector randomly' selected the following recently issued procedures and verified that review, approval and updating were conducted in l accordance with the licensee's applicable administrative procedures; that the issue of the new procedures and control of superseded procedures were completed as prescribed in the licensee administrative procedures; and

that working copies of the' procedures in various plant locations were the 3 same as the current approved revision in the master file

BwAP 1600-1 Maintenance Work Request Revision 9- 4/11/86 l, Procedure

! BwAP 1205-10 Area Turnover for Operation Revision 3 3/24/86 i

BwAP 1300-2 Permanent Procecure Revision 5 2/27/86 Preparation, Revision, e and Approval l BwAP 1300-3 Preparation and Approval of Revision 2 2/7/86

Temporary Procedures and j Temporary Changes to the

Permanent Procedures

! BwAR 1-15 Annunciator Alarm Responses Revision 51 4/28/86 (55 Safety-Related Alarm-Responses) '

i BwHP 4002-06 Clean and Inspect Station Revision 0 4/24/86 Battery Chargers BwHP 4002-030 General Inspection and Revision 0 2/4/86

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Cleaning of Electrical l

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BwIP 2400-021 Repair of Instrumentation Revision 1 4/24/86 :

BwIS 3.2.1-201 Surveillance Calibration Revision 3 2/14/86 1

i of the Steam Generator I-Steam Flow / Feed Flow Mismatch Protection

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BwMP 3305-01.0 Dissaembly/ Reassembly of Revision 1 2/27/86 Codes-Vulcan Air Operated

Sampling Valves Hold Points Safety-Related/ Rebuilding Bw0P AF-1 Fill and Vent of Auxiliary Revision 1 2/19/86 Feedwater System 1Bw0S 2.1.1.a-1 Axial Flux Differences - Revision 52 3/17/86 Weekly Surveillance IBw0S 2.1.1.b-1 Axial Flux Difference AFD Revision 52 3/17/86 Monitor Alarm Inoperable Surveillance The inspector reviewed all of the temporary procedure changes and temporary procedures in effect (in excess of 30) during the inspection and verified that they were controlled and implemented as stated in BwAP 1300-3,

" Preparation and Approval of Temporary Procedures and Temporary Changes to Permanent Procedures," Revision 2. The inspector interviewed several shift supervisors and Shift Control Room Engineers / Shift Technical Advisors (SCRE/STA) and verified that they were aware of and understood the systems established for temporary procedure While conducting reviews of temporary procedures and temporary procedure changes, the inspector noticed several temporary procedures where the documentation of the 10 CFR 50.59 review gave the impression of a question-able review. Several examples are answers to the question: "Is the possibility of an accident or malfunction of a different type than any previously evaluated in the FSAR created?" Answers varied from, "No, because Tech Specs are not applicable to this procedure," or "Not addressed in-the FSAR." In each case, the answers could lead one to believe that the review was inadequate in that the change could raise an issue that was not addressed in the past. However, the inspector confirmed that the subject of these specific procedure changes was not affected by the 10 CFR 50.59 regulation. To assure more concise 10 CFR 50.59 reviews in the future, the inspector found through discussions with licensee personnel that CECO is developing a generic program at the corporate level for use at all Ceco nuclear stations. The program will be made up of EPRI, NSAC, and INP0 recommendations, and will provide guidance on what to look for in 10 CFR 50.59 reviews and related training. Followup on this program is considered an open inspection item (456/86016-02(DRP); 457/86014-01(DRP)).

The inspector reviewed all of the special operating orders in effect during ,

the inspection and verified that they were issued in accordance with the  !

controls stated in BwAP 350-3, "Special Operating Orders," Revision 0, and l that they were not being used in place of procedures which should undergo j appropriate reviews and approval l l

Byron /Braidwood Procedure Standardization During the inspection, the inspector reviewed the licensee's plan for developing and implementing a procedure standardization program for Byron

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I -and Braidwoo This will eventually result in almost all procedures'being l identical for both stations. Those procedures that have been properly [' ,

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approved and implemented for both stations are identified as Revision 51 *

and subsequent revisions will be numbered' sequentially from 51. Braidwood has implemented a specific procedure, BwAP 1800-1, " Byron /Braidwood

, Operating Commitment Standardization Program," and a number of procedures j have been implemented under the standardized. program using this plan. The

applicable Byron administrative procedure is

BAP 340-4, Byron /Braidwood

[ Operating Procedure Standardization Form, Revision 20, February 13, 1986.

j The inspector reviewed that procedure and found that it is compatible with

the Braidwood>facilityrand the Braidwood administrative procedure

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BwAP 1300-2, " Permanent Procedure Preparation, Revision and Approval,"

. Revision p The inspector reviewed a number of procedures designated as Revision 51 and

found them to be acceptabl /

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In generai, most of the technical procedures at Braidwood were developed using Byron-approved procedures as a guide or pattern. In a number of cases, the Byron procedures were duplicated verbatim. In consideration of this and the extensive NRC inspection of Byron procedures (reference

Inspection Reports No. 454/82015(DRP),454/83061(DRP),454/84015(DRP),

454/84019(DRP),454/84028(DRP),and 454/84055(DRP)), most of the procedures.

I at Braidwood have been pre-reviewed with the exception of site specific

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procedure In addition, this is the initial NRC procedure rev.iew at'

l Braidwood and is the first of.an ongoing process whereby future inspections

! will evaluate procedure development, availability, use, and undating.

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Emergency Procedures

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The inspector reviewed the index of plant emergency procedures for completeness. The inspector also reviewed a significant sample of

, Emergency Operating. Procedures / Event Sp,ecific, Contingency Actiont Procedures, Functional Restoration / Status Trees, Operating Abnormal

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Procedures, General Operating Procedures,:and ' numbers of Safety-Related

, Annunciator Response Procedures. The inspector verified that the procedures were in an appropriate format and technically adequate to

! accomplish their specific purpose. With regard to similar plant designs,

concerns have been raised where the operator could manually reset a safety

injection signal (SIS) prematurely and defeatithe loss of offsite power

protection. Through interviews with licensed operations personnel, the inspector found that the Braidwood design has a built in time delay relay

.that prevents the manual reset of the SIS for'several minutes to prevent

, defaulting the ECCS load pickup. Further questions on this subject have been raised through IE Bulletin 80-06, " Engineered Safety Feature (ESF)

Reset Controls," and will be addressed when the-licedsee response is appraise '

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L i .On April 9, 1986, the senior resident inspectors were afforded an .

L opportunity to use the Byron /Braidwood simulator in conjunction with NRC-

licensing examiners. The simulator was used.to exercise a number of

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abnormal and/or emergency conditions and use the present procedures for..

mitigation and recovery.

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The following is a partial list of the procedures reviewed by the inspector

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' and/or tested on the simulator:

BwAP 340-1 Use of Procedures for Operating Department 18wEP-0 Reactor Trip or Safety Injection (Several Variations)

1BwEP-ES- Rediagnosis 18wEP-ES- Reactor Trip Response 18wEP-1 Loss of Reactor or Secondary Coolant 1BwEP ES- Transfer to Hot Leg Recirculation 1BwEP-3 Steam Generator Tube Rupture 18wEP ES- Post SGTR Cooldown Using Backfull 1BwEP ES- Post SGTR Cooldown Using Steam Dump 18wCA- Loss Of All AC Power IBwCA- Loss of All AC Power Recovery With SI Required 1BwST-1 Subcriticality 1BwST-2 Core Cooling 18wST-3 Heat Sink 1BwST-4 Integrity 1BwST-5 Containment 1BwST-6 Inventory 18wFR- Response to Nuclear Power Generation /ATWS 18wFR- Response To High Containment Pressure 1BwFR- Response to Low Pressurizer Level In summary, the licensee's emergency procedure system and those procedures that were reviewed and tested were found to be acceptabl No violations or deviations were identifie . Release to Operations (RTO)

Prior to a system or component being considered acceptable for operation, it must be evaluated by a process referred to as RTO. The Braidwood Startup Manual states that the Project Turnover Group will review the following items for completeness; design changes FCRs, NCRs, Followup

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Engineering Items (FUEIs), open punch list items as appropriate, and that test results are accepted by Project Engineering and the Project Startup Superintenden The inspectors arc concerned about the potential quality of these RTO evaluations when considering the time and manpower required for the RTO, and the upcoming licensing date of Unit 1. In order to provide an opportunity for the inspectors to_ evaluate the RTO process, the licensee has agreed to inform the resident inspectors when each safety-related RTO package is complete. The licensee informing the inspectors of the availability of each completed RTO package is considered an open item (456/86016-03(DRP)).

1 Meetings, Training and Other Activities On April 8, 1986, the Senior Resident Inspector (Operations) was dispatched to the LaSalle County Generating Station to participate in the planned emergency exercis I L

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1 Institute on Nuclear Power Operations (INP0) Audit

' During the period of May 5 through May 16, 1986, a near term operating license (NT0L) audit was conducted at Braidwood by an INP0 team. The station manager discussed the findings with the resident and regional inspectors,.and the Braidwood Section Chief on May 22, 1986. INP0 identified nine good practices and 34 areas where improvement is suggeste Not all of the areas identified are safety-related and the station will respond internally to all of the finding The station manager will make the report available for NRC revie . Open Items 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 bot Open items disclosed during the inspection are discussed in Paragraphs 2, 9, and 1 . Exit Interview The inspector met with licensee and contractor representatives denoted in Paragraph 1 during and at the conclusien of the inspection on May 29, 1986. The inspectors summarized the scope and results of the inspection and discussed the likely content of this inspection report. The licensee acknowledged the information and did not indicate that any of the informa-tion disclosed during the inspection could be considered proprietary in natur l

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