IR 05000456/1985032

Insp Repts 50-456/85-32 & 50-457/85-31 on 850624-0906. Violation Noted:Failure to Follow Drawing Instructions for Installation of Instrument Flexible Hoses & Failure to Follow Procedural Requirement Re Component Pipe Support

ML20137Z953
Person / Time
Site:	Braidwood
Issue date:	10/04/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137Z914	List: IR 05000456/1985032 IR 05000624/2009006 ML20137Z909
References
50-456-85-32, 50-457-85-31, NUDOCS 8510080413
Download: ML20137Z953 (23)

Text

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report Nos. 50-456/85032(DRP); 50-457/85031(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: June 24 through September 6, 1985 Inspectors: R. D. Schulz W. J. Kropp  ;

10CT 0 41985 Approved By: W. S. Little, Director Braidwood Project Date Inspection Summary Inspection on June 24 through September 6, 1985 (Report Nos. 50-456/85032(DRP);

50-457/85031(DRP))

Areas Inspected: Routine, unannounced safety inspection of licensee action i on previously identified items, work activities observed during plant tours,

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procurement, instrumentation, reactor coolant piping, pipe supports, quality control supervision - electrical contractor, piping wall thickness, reactor vessel internals, electrical items, and mechanical equipment. The inspection consisted of 299 inspector hours onsite by two NRC inspectors including 43

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inspector hours onsite during off-shift Results: Of the nine areas inspected, no violations were identified in seven areas, one violation was identified with an example in each of the remaining

, areas (failure to follow drawing instructions with regard to the installation of instrument flexible' hoses - Paragraph 5; and failure to follow a procedural requirement with regard to the reinstallation of a component pipe support -

Paragraph 7),

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85100g0413 851004 R

G ADOCK 05000456 PDR

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l DETAILS

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1. Persons Contacted l

l Commonwealth Edison Company (Ceco)

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• L. De1 George, Assistant Vice President l

• • M. Wallace, Project Manager

• G. Fitzpatrick, Assistant Manager Quality Assurance Corporate

• C. Schreeder, Project Licensing and Compliance Superintendent l **D. Shamblin, Project Construction Superintendent j **T. Quaka, Quality Assurance Superintendent j * G. Groth, Assistant Project Construction Superintendent l S. Hunsader, Corrective Action Programs Supervisor l-

• E. Netzel, Electrical / Pre-op Supervisor l

• • P. Barnes, Project Licensing and Compliance l M. Gorski, Group Leader Corrective Action Programs j

• • W. Vahle, Project Field Engineering Manager

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• • L. Kline, Project Licensing and Compliance Supervisor G. Marcus, Project Management D. Hoffer, Electrical / Pre-op Quality Assurance D. Skoza, Project Field Engineering Special Project Supervisor M. Teras, Project Field Electrical Engineering

• • N. Kaushal, BCAP Director

• • C. Allen, Project Licensing and Compliance

• • D. Cecchett, Licensing and Compliance Engineer

• • T. Simpkin, Licensing Tech Staff

• • D. Windham, Licensing Tech Staff Phillips Getschow Company (PGCo)

T. G. O'Connor, Site Manager J. Carlson, Quality Control Supervisor L. J. Butler, Assistant Quality Control Supervisor

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G. Galloway, Assistant Project Engineer l R. Hamilton, Welding Supervisor

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M. Knaff, Engineering Group Instrument Supervisor K. Kranz, Quality Assurance Site Manager G. K. Newberg Company (GKN)

R. Donica, Quality Assurance Manager P. Struckholz, Engineer K.' Comstock and Company, Inc. (LKC)

I. Dewald, Quality Control Manager L. Seese, Assistant Quality Control Site Manager T. Simile, Welding Engineer R. Seltman, Quality Assurance Manager

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Pullman Sheet Metal (PSM)

D. Grant, Site Quality Assurance Manager Sargent & Lundy

• D. A. Gallagher, Field Project Manager

• • K. Fus, Assistant Over-Field Coordinator The inspectors also contacted other licensee and contractor personnel, including craftsmen, and technical and engineering staff member * Denotes those personnel present at the exit meeting on August 2, 1985.

• • Denotes those personnel present at the exit meeting on September 5, 198 . Licensee Action On Previously Identified Items Violations (0 pen) 456/84-44-04; 457/84-40-04: Fasteners utilized in Class 1E

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seismic cable tray hangers and battery racks did not always meet the requirement of ASTM A307 in regards to the manufacturer's identification marking. The licensee issued Nonconformance Report (NCR) 692 on December 27, 1984, to identify this deficiency and to obtain a disposition for the fasteners. The final disposition has not yet been approved by appropriate licensee personnel. The licensee has tested sixty (60) fasteners selected from the various site contractor storage areas to verify their compliance with the requirements of ASTM A307. The testing, which consisted of chemical analysis, tensile tests, hardness tests, and metallographic analysis, was performed by the licensee's System Materials Analysis Departmen The activities of this department were last audited in May 1985 (Audit Number TC85-03) by the licensee's corporate QA department with no major findings being issued. The inspector reviewed the results of this testing which have not yet been evaluated by the licensee's site personnel (QA, Project Engineering, etc.). The number of fasteners selected for testing is presently being discussed with licensee personnel and will be addressed in a future inspection report. The inspector did verify the implementa-tion of the licensee's corrective action to preclude recurrenc This corrective action consisted of:

• Revision of licensee procedure PCD-01, " Material and Equipment Receiving, Inspection, Storage, Removal and Inventory" to require identification of the manufacturer's mark on bolt heads as a receipt inspection attribut The inspector verified that Revision 1, dated May 29, 1985, to PCD-01 identifies the manufacturer's identification mark on bolt heads as a receipt inspection attribut _ - _ _ _ _ _ _ _ _ _ _ -

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• A directive (BR/PCD-85-381) issued by the licensee to all site contractors clarifying the procurement / receiving requirements for ASTM A307 bolts. This directive stated that future purchase documents should specifically state the manufacturer's marking as a requirement and that future receipt inspections should verify their presence. The inspector reviewed L. K. Comstock Procedure 4.10.2, Revision B, " Receiving and Storage" and Phillips Getschow Procedure QCP-84, Revision 6,

" Receipt Inspection" and determined that the attribute of verifying the manufacturer's mark on bolts was included. The inspector also verified that two recent receipt inspections of ASTM A307 bolts were properly performed by L. K. Comstock. The two inspections were documented on Material Equipment Receiving and Inspection Reports (MRR) 17767 and 17768. These MRRs documented that the attribute for the manufacturer's marking was verified and found satisfactory by the receipt inspecto The inspector verified that the bolting associated with these MRR's were marked with the manufacturer's identificatio This item will remain open pending a review of the final disposition of NCR 69 (Closed) 456/84-07-02c; 457/84-07-02c: Three G. K. Newberg general tests were found to be graded incorrectly resulting in one QC inspector receiving a failing score. The inspector reviewed the licensee's corrective action and the corrective action to preclude recurrence and found these actions to be acceptable. The corrective action consisted of:

• G. K. Newberg issued NCR (213-767) documenting the misgraded exams. The inspector verified the issuing of NCR (213-767)

which accurately described the deficiency and was properly closed by G. K. Newberg QA personne * A review performed by G. K. Newberg of all their personnel qualifications folders. The inspector verified that a review of all personnel qualification folders was performed by G. K. Newber The inspector selected three personnel qualification folders for review and noted no problem * Retesting of any individual who failed the general test which was originally misgraded with a passing scor The inspector verified that two individuals who failed the regraded general test were properly retested. Both individuals passed the retes * Performing a reinspection of the first ten (10) inspections conducted by the two individuals who did not pass the regraded tes The inspector verified that reinspections were performed by a Level II inspector. The reinspections pertained to SSIT packages 1736, 1789, 1738, 1749, 1760, 1765, 1766, 1771, 1811, and 1827 and Daily Masonry Inspection Reports 899 through 90 . .

• The licensee's QA department performed a surveillance to ensure

) roper grading of test The inspector reviewed Surveillance Report 3523 and noted no problem The corrective action to preclude recurrence consisted of G. K. Newberg initiating an informal internal review by a Quality Engineer of all personnel qualification packages prior to processing by a quality records clerk. The inspector verified through dis-cussions with G. K. Newberg Quality Engineers that this review is being accomplished. In addition, the G. K. Newberg Quality Assurance Manual, Section 37, Revision 7, requires the Quality Assurance Manager to review examination results. The inspector verified that the Quality Assurance Manager was reviewing the examination result This item is considered to be close (0 pen) 456/85015-06: The licensee's Quality Assurance Department inappropriately closed NCR 600 and as a result did not assure that conditions adverse to quality were corrected. The inspector reviewed the licensee's corrective action and the corrective action to preclude recurrence and deemed them adequate to resolve this violatio Although corrective action is scheduled to be fully implemented by December 1985, part of the corrective action was implemented and verifiable. The inspector verified that a special audit by Phillips Getschow concerning material traceability and installation of ASME Class 1 supports was conducted. This audit (85-BR6) was conducted on March 12, 1985 through April 24, 198 The audit was comprehensive and all concerns identified by the audit team were properly documented for resolution. The inspector verified that the licensee's corrective action to preclude recurrence was adequately implemented. This corrective action consisted of training sessions with site Quality Assurance personnel concerning the verification of corrective actions associated with NCRs. Training sessions were conducted on June 17 and 18, 198 This item will remain open pending verification of the implementation of the remaining corrective actions identified in the licensee's letter, dated June 21, 198 (0 pen) 456/84-44-03; 457/84-40-03: GE "Vulkene" wire was received at the Braidwood site and installed without appropriate qualification to IEEE 383-1974. The corrective action identified by the licensee has not been fully implemented. The scheduled date for implementation is prior to fuel loa The inspector was able to verify implementa-tion of part of the corrective action pertaining to the field review performed by the licensee and L. K. Comstock to identify and place on hold any GE Vulkene wire currently on site. Implementation appeared to be satisfactory. This verification was accomplished by inspection of L. K. Comstock storage and work areas. Approximately six hundred (600) feet of Vulkene wire was in a hold area in a L. K. Comstock warehouse (hold tag 2J-12a). The inspection also verified implementation of the corrective action to preclude recurrenc This corrective action required that the specification

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for switchboard wire (EM-30105) be revised to allow only the purchase of qualified wire. The specification was revised on l May 13, 1985, and identifies the switchboard wire which can be i

procured for nuclear plants. The GE vulkene wire is not one of the

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wires that can be purchased. The last switchboard wire received on site was Rockbestos Firewall on January 16, 1985. This wire is qualified for Nuclear Power Plants.

, This item will remain open pending verification of the implementation of the remaining corrective actions identified in the licensee's letter, dated May 16, 198 (Closed) 456/84-07-05; 457/84-07-05: L. K. Comstock weld inspectors allowed craft personnel to rework weld defects identified during final QC inspections, thereby circumventing the nonconformance reporting system. Three weld inspectors were interviewed to determine what type of weld defects were allowed to be reworked by the craft. All three weld inspectors stated that the craft were '

allowed to rework welds which had defects such as undercut, porosity, undersize, etc. The rework of the welds resulted in welds which complied with established requirements and the acceptance of the welds was documented on the Weld Inspection Repor The weld inspectors also stated that the present practice is to identify weld i defects by issuing an Inspection Correction Report in accordance l with procedural requirements. The inspector verified that a training

! class was conducted by the L. K. Comstock Assistant Q. C. Manager for L. K. Comstock quality control personne This training class was convened on March 29, 1984, and concerned the issuance of NCR's when weld deficiencies are found by Q. C. personnel during final inspections. The inspector also verified the licensee's corrective

action to preclude recurrence. This consisted of a licensee letter, BRD #10,937, sent to all site contractors which provided further

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clarification regarding deficiencies noted during in process or final inspections. The inspector verified this memo was sent to I

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each site contractor and that it clarified the requirement for issuing nonconforming documents when deficiencies are noted by l Q. C. personnel during final inspections. Based on the BCAP and~

L the Quality Control Inspector Reinspection Program and the fact that hardware deficiencies were not originally identified as a result of this violation, the inspector considers this item to be closed, i

(Closed) 456/84-07-02b; 457/84-07-02b: The practical examinations for weld inspectors utilized installed components which did not contain weld defects. Therefore, the prospective weld inspector's i

capability of identifying weld defects was not tested. The l

licensee's corrective action to preclude recurrence consisted of

! revising L. K. Comstock's procedure 4.1.3, " Qualification, 1 Classification and Training" to require that practical examinations, when feasible, should include the use of components with known I defects. The inspector reviewed Revision D of Procedure 4.1.3 and verified that it addressed the licensee's corrective action to E

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preclude recurrenc The inspector also verified the licensee's corrective action which consisted of issuing a letter to site contractors requiring that samples with known defects be included in practical examinations when feasible. The inspector verified letter BRD# 10,936 was issued by the licensee's QA department and ( that this letter addressed the use of weld coupons with known defects for practical examinations. The inspector reviewed a practical examination administered to a prospective weld inspector on August 29, 1985. The component utilized for this practical f

examination was an installed conduit hanger (CP-6) for conduit CIA 31A7. This component had weld defects consisting of insufficient weld size, slag inclusion, and no welder stamp . The prospective weld inspector correctly identified the weld defect The inspector also reviewed the qualification packages of four individuals recently certified as Level II weld inspectors and noted that the practical examination utilized installed items which had weld defects such as insufficient weld length, incorrect fillet size, lack of fusion, and arc strike This item is considered to be close (Closed) 456/85015-08: L. K. Comstock Quality Control inspector accepted junction box IJB217R which was later determined to have deficiencies in the location of the anchors used for the mounting of the junction box. The licensee's corrective action consisted of issuing NCR 4139 to identify that junction box 1JB217R was not 1 installed per Sargent & Lundy drawing 20E-1-3571, detail 9784. The inspector verified NCR 4139 was issued on April 30, 1985. In addition to issuing NCR 4139, the licensee's corrective action consisted of reinspecting junction boxes which had been inspected by the Quality Control inspector who had accepted junction box IJB217R. It was determined from a computer print out that this Quality Control inspector had inspected a total of seven (7) safety-related junction boxes. This reinspection was performed by another inspector certified as a Level I No problems were noted with these junction boxes and the dimensional discrepancies with junction box 1JB217R were considered to be an isolated cas The NRC inspector selected two (2) of these junction boxes and also noted no dimensional problem The results of the inspection of these two junction boxes are discussed in Paragraph 11 of this repor This item is considered to be close (Closed) 456/85023-01; 457/85024-01: Failure to maintain the cleanliness of cable trays and control of bolting material. The cable trays identified as containing miscellaneous items have been cleane Commonwealth Edison issued letters to site contractors emphasizing the need to maintain cable trays free of foreign objects. The electrical contractor has assigned additional cleanup personnel to cable tray cleanup. The NRC inspectors have verified, during plant tours, that the cleanliness of cable trays is now being adequately maintaine On June 17, 1985, Commonwealth Edison directed the site contractors to place special emphasis on the control of bolting materials, including directing the contractors to store all bolts and nuts in burlap bag Uncontrolled bolting

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material is being removed and scrapped by cleaning crew The NRC inspectors, in their plant tours, have not identified any additional uncontrolled bolting material. This deficiency appears to be correcte This item is considered to b3 closed.

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(0 pen) 456/83-09-08A; 457/83-09-08A: Phillips Getschow Company had not established and executed a plan for auditing the implementing procedures of the quality assurance program on a periodic basis to determine the effectiveness of the program in accordance with their QA Manual, Section 16. Phillips Getschow Company revised their audit schedule on August 21, 1983, to include audit %g all the implementing procedures annually. The inspector verified that audits are being performed in accordance with the audit schedul However, prior to August 21, 1983, the audit program was not adequate in that Phillips Getschow Co. did not audit all the implementing procedures on a periodic basis. This item will remain open pending the licensee's evaluation of the lack of auditing prior to August 21, 198 (0 pen) 456/83-09-08C; 457/83-09-08C: Pullman Construction Industries', Inc. audit program did not cover all the implementing procedure Pullman has implemented an audit schedule that provides for auditing the entire population of implementing procedure This item will remain open pending the licensee's evaluation of the previous lack of auditin (0 pen) 456/83-09-02A; 457/83-09-02A: Two drawings were not stamped with field change request document numbers. The field change request number on the drawing notifies the installer and quality control inspector of changes to the drawing. Subsequently, the piping contractor stamped the two drawings with the appropriate field change request numbers. However, an audit, performed by Commonwealth Edison on July 26 through August 31, 1983, identified numercus drawings that were not stamped with the appropriate field change requests or engineering change notices. As a result of this audit, No. 83-BR15, a review of all controlled drawings was completed, which included updating drawings to include appropriate engineering change notice or field change request stamps. However, since numerous drawings were identified by the licensee without appropriate stamping, the inspector requested that the licensee evaluate this deficiency with regard to hardware installations and inspections. The scope of work includes large bore and small bore piping, pipe supports, and instruments. This item will remain open pending further licensee review and evaluatio (Closed) 456/83-09-02D; 457/83-09-020: Field change orders were not written for two component supports as required by Phillips Getschow Co. Procedure PG-4, Revision 0, " Control of Rework of Component Supports". The actual installations were correct and the revisions will be reviewed by Sargent & Lundy for acceptabilit Procedure PG-4 was not the governing procedure and should have been deleted from use. Commonwealth Edison withdrew the procedure on June 25,

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198 QCP-B23, " Installation and Inspection of component Supports,"

is the governing procedure for support changes and is being complied with by the piping contracto (0 pen) 456/83-09-01; 457/83-09-01: The licensee did not have adequate engineering controls for field changes to small bore piping drawings. Procedure QCP-B21, " Installation and/or Field Routing of Two Inch and Under Process Piping Systems - ASME Classes 1, 2, and 3" was revised to require engineering department review of re-routes. Engineering is now involved in changes and approvals prior to installation in accordance with QCP-B21. A complete reverification (walk down) of previous piping installations has been completed that includes documentation of as-built installation Sargent & Lundy will review the as-built drawings for acceptabilit However, one aspect still remains open. Sargent & Lundy issued an engineering change notice, No. 22822, that defined installation clearance guidelines and reporting mechanisms. The guidelines included a current 3 inch clearance requirement for installed piping but did not require the clearance margin for past installation The engineering change notice, ECN, stated, "The requirements of this ECN are applicable upon the approval date of this ECN and are not retroactive." The approval date was September 18, 1984. The inspector requested that the licensee evaluate the clearance requirements specified in ECN No. 22822 for past as-built drawings, prior to the September 18, 1984 approval date. Whether field re-routed pipe was located with reasonable clearances to other items, taking into consideration such factors as thermal expansion, appears to be unknown since engineering was not involved in the re-routes to the extent necessar Pending licensee review of ECN No. 22822 for installations prior to September 18, 1984, this item will remain ope (0 pen) 456/85007-08; 457/85007-08: The piping contractor did not hava a procedure or documented instruction stipulating a systematic mdhod for producing an accurate Inservice Inspection drawing, including determination of the number and location of all field welds and shop welds. The corrective action consisted of revising Commonwealth Edison Procedure PCD-25, " Distribution And Control Of Site Preservice Inspection Drawings." The change was included in Section 4.1 and stated, "The PSI Isometric's drawings shall include all the attributes detailed on the ISI checklist (Attachment B)."

The corrective action did not address the following:

• The procedure does not require the checklist to be used and signed by the Phillips Getschow engineering personnel who produce the Inservice Inspection drawing * The checklist does not indicate which attributes on the checklist require field examinations and which require documentation review * The method used to assure the accuracy of the drawings produced was not addressed by the license .

Pending licensee review of these factors, this issue will remain ope b. Unresolved Items (0 pen) 456/84-42-04; 457/84-38-04 and 456/84-42-06; 457/84-38-06:

These concerns relate to the controls by the electrical and piping contractor for AWS welds added during the installation process that were not specified on the drawings. The lack of detailed documentation of the additional welds, identified on page 8 through page 10 of Inspection Report 456/84-42; 457/84-38 raised questions about programmatic controls. The inspector was also concerned that an unspecified weld might possibly be added within the ASME III, NF boundar Subsequent to the identification of the unresolved items in Inspection Report 456/84-42; 457/84-38, the licensee's quality assurance department performed quality assurance surveillance No. 4223 on February 20-27, 1985, with regard to this issu The surveillance expanded the issue to the HVAC contractor, Pullman

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Sheet Metal and the structural contractor, G. K. Newber The inspector informed the licensee that he was concerned about the surveillance conclusion, which did not require the recording of the specific added weld location for each installed componen A meeting was held between Region III, Sargent & Lundy and Commonwealth Edison Construction Management on July 29, 198 In this meeting the licensee stated why they believed the control and inspection of unspecified welds were adequate, meeting AWS code requirement The Region III inspectors have not found any examples of additional weld placement which appeared to have a detrimental effect on the component. Additionally, no unspecified welds have been identified with undercut or cracks. All of the information that the Senior Resident Inspector is aware of has been given to a Region III inspection specialist who will be responsible for resolution of this unresolved ite (Closed) 456/84-09-06; 457/84-09-06: Quality control inspectors had not been involved in verifying and documenting acceptable substitute, whip restraint material. A review of all whip restraint document packages and quality control field verifications by the piping contractor resulted in the issuance of nine nonconformance reports. The reports were identified by numbers: 1533, 1534, 1535, 1 1536, 1537, 1539, 1809, 1810, and 1811. Material is dispositioned i for replacement as necessary to meet specification requirement The piping contractor's review was thorough and the reinspection program documented correct material installation or the material i that was incorrect was dispositioned for removal and replacemen !

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(0 pen) 456/84-13-04; 457/84-13-04: Electrical preventive maintenance was not performed in accordance with manufacturers'

instructions. The licensee has determined the preventive maintenance required for each piece of equipment, and has reviewed records in an effort to determine the preventive maintenance that has been performe The licensee is in the process of determining the affect of not having performed the manufacturers' recommended preventive maintenance and has implemented a maintenance program in accordance with the manufacturers' recommendation Until the licensee has determined the effect of not having performed preventive maintenance on selected pieces of equipment in accordance with the manufacturers' instructions and has completed corrective actions, this item will remain ope c. Open Items (Closed) 456/84-09-04; 457/84-09-04: High strength bolting

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, documentation for whip restraints was not required. Corrective action included verification of tightening for all previously installed connections. Corrective actions have been completed and documentation is acceptable. Implementation was accomplished through construction procedure, PGCP-18, " Whip Restraint Installation." This item is considered to be close (0 pen) 456/85015-02; 457/85016-02: The nuts on the threaded rod that hold the shims for the steam generator, inner frame support corner connections were not tight. These nuts were loose because the shimming will be completed during hot functional testing. This item will remain open pending the inspector's inspection of the nuts after hot functional testin (Closed) 456/84-13-01; 457/84-13-01: Equipment was poorly covere Commonwealth Edison issued procedures PC-05, Project Housekeeping and PCD-14, Equipment Preventive Maintenance Procedure, which placed emphasis on equipment protection. The inspectors examined installed plant equipment and found the equipment properly covered for protection from construction activitie This item is considered to be closed.

, d. 10 CFR 50.55(e)'s (Closed) 456/81-04-EE; 457/81-04-EE: " Single random failure in Volume Control Tank (VCT) level control system could... lead to loss of redundancy in high head injection." The CECO letter, Tramm to Keppler, dated November 10, 1981, described the VCT level control system as incorporating information from two analog level instru-

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ments, provided tabulation of the various control and alarm functions together with W established setpoints, included the information provided to the operator in the event of failure of either level

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instrument, and indicated the amount of time which is available for protective action. CECO's response demonstrated that there is sufficient time for operator action in the event of a system malfunction to prevent loss of charging pump suction. No plant changes are required and required actions have been incorporated in plant procedure BWAR 1-9-A2. The operator action required by the procedure includes switching suction to the RWST to prevent loss of charging pump suction. This item is considered to be close (0 pen) 456/84-06-EE; 457/84-06-EE: Leak in the recycle holdup tanks. Corrective actions have included:

• replacing the sand bed with concrete fill, e replacing the tank floor utilizing butt welded joints rather than the existing lap joint fillet welds,

• hydrostatic test the tank All of the above corrective actions have been completed, however, the final documentation package is presently being reviewed by Sargent & Lundy for acceptability. After the Sargent & Lundy review is completed, the inspector will review the package for compliance 4 to the ASME Code, drawing M-1219, Sheet 3, and Specification F/L-2750, Amendment 3 and No violations or deviations were identifie . Plant Tours The inspectors observed work activities in progress, completed work, and plant status during general inspections of the plant. Observation of work included high strength bolting, nondestructive examination of steam generator tubing, safety related pipe welding, HVAC duct work, HVAC welding, liquid penetrant examination, housekeeping, reactor coolant pipe welding, structural welds, flange bolt-ups, cable trays, instrument pipe welding, and concrete expansion anchors in the containments and auxiliary buildin During one of the tours the inspector identified structural bolting deficiencies in the auxiliary buildin The components included numerous beams connected to embedment plates by means of an angle plat One end of the angle plate was welded to the embedment plate, while the other end of the angle plate was bolted to the beam. The beams were located at elevation 397', Area 5 of Unit 1 and Area 7 of Unit 2. Some of the bolts were missing, with exposed bolt holes, and some of the holes in the beams were torch cut. The inspector brought these deficiencies to the attention of the licensee and requested that the licensee evaluate both the welded and bolted plate connections for specification conformance and safety significance. The licensee stated that nonconformance reports may already exist for the beam - angle plate installations. Pending licensee evaluation and further information being provided to the inspector for review, this issue will remain unresolved (456/85032-01; 457/85031-01).

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During the tours of the plant, two valves, ZRY022 and ZRY023 were noted as not having their ends capped. These valves are located in Unit 2 Containment. The mechanical contractor, Phillips Getschow (PGCo) was notified and the valves were capped. The inspector also identified an uncapped pipe by the Unit 2 diesel driven auxiliary feed pump. The tape which had been used to cap the end of the pipe was pulled to one sid '

The PGCo Quality Control department was notified and the pipe was cappe Monitoring Report 11341 was issued to identify this discrepancy. The inspector did not find any foreign material in the valves or pipe and the valves were noted as being shu These uncapped items were noted early in the inspection report period and the inspector did not identify any other uncapped valves or pipe. The licensee took immediate action to correct the uncapped valves and pipe and no other items were noted as being uncappe No violations or deviations were identifie . Procurement The inspector reviewed the procurement activities associated with the nondestructive examination (NDE) of the steam generator tubes for Unit 1 and Unit 2. The procurement activities reviewed consisted of: (1)

verifying a purchase order was issued to the contractor performing the NDE; (2) the purchase order contained appropriate technical and quality assurance requirements; and (3) the procedures utilized in the NDE activities were approved for use by the appropriate personnel. The NDE performed was the eddy current testing of the steam generator tubes and was being performed in accordance with the requirements of Purchase Order 280957 issued February 3, 1984. The scope of this purchase order required the contractor to develop and provide procedures required to perform the preservice inspection eddy current testing of Units 1 and 2 steam generators. The purchase order further stated that these procedures shall comply with ASME Section XI, 1977 Edition through the Summer of 1978 Addenda. A change order to this purchase order, dated June 6, 1984, changed the Quality Assurance Manual from the Nuclear Energy Services Inservice Inspection Quality Assurance Manual to the Conam Inspection Quality Control Manual, 42QCM001, Revision 7, and Conam Quality Assurance Manual,99QAP001 hevision 7. Conam was the contractor who furnished the personnel to perform the eddy current testing. The inspector verified the following Conam procedures were either approved by the licensee's Quality Assurance department or were given interim approval by the licensee Corporate Level III and Sargent and Lundy's Level III:

• 42-EC-091, Revision 0, "Multifrequency Eddy Current Procedure for Westinghouse Series 01 and D5 Steam Generator Tubing Expansion -

M12.18 Digital Eddy Current System Braidwood Units 1 and 2."

• 42-EC-092, Revision 0, "Profilmetry Eddy Current Procedure for Westinghouse Series 04 and D5 Steam Generator Tubing Expansion -

M12.18 Digital Eddy Current System."

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• 42-EC-087, Revision 1, "Multifrequency Eddy Current Procedure for Westinghouse Series D4 and D5 Steam Generator Tubing - M12.18 Digital Eddy Current Systems."

No violations or deviations were identifie . Instrumentation Instrumentation lines detailed on the following drawings were examined:

• 1PT-545, Sheet 2, Main Steam Pressure Transmitter

• 1LT-501, Sheet 2H, Feedwater Level Transmitter

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• 1LT-501, Sheet 3H, Feedwater Level' Transmitter

• 1PT-457, Sheet 1, Reactor Coolant Pressure Transmitter

• OPS-FP165, Sheet 1, Fire Protection Pressure Switch

• ILT-529, Sheet 1, Feedwater Level Transmitter Installation and inspection documentation was also reviewe .

Attributes checked included:

• separation criteria

• line properly pitched

• installation clearance

• separation color code identification

• drawing conformance In addition, field change requests associated with the installation were reviewed for accuracy and completenes Main steam pressure transmitter drawing 1PT-545, Sheet 2, Revision B, required the installation of a flexible metal hos The drawing stated:

" Single pipe pressure instruments are recommended to have their sensing lines installed with a continuous slope (1/2" per foot recommended), however, it is acceptable to have horizontal runs without slope and a high point without high point vent valves provided no traps are formed."

The flexible metal hose was installed with a formed trap. The installation was accepted by a quality control inspector on February 14, 198 An identical finding was identified in Inspection Report 50-456/85015; 50-457/85016. This report stated on page 17:

"While inspecting the installation of instrument 1-PT-544, it was noted that a flex hose was installed in such a manner as to cause a trap to be forme The piping contractor issued a Nonconformance Report to identify this deficiency. Five other instruments were inspected to verify proper installations of flex hoses. No problems were noted. The improper installation of the flex hose for instrument 1-PT-544 is considered an isolated case at this time."

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The flex hose for instrument 1-PT-544, Sheet 2, Revision B, was accepted by a quality control inspector on March 1, 1985. The finding identified in Inspection Report 456/85015; 457/85016 is no longer an isolated case and may be indicative of a generic problem. Both flexible hoses, on drawings 1-PT-544 and 1-PT-545, appeared too long for their connection points and the length contributed to the traps being formed. The hoses were installed in a loop configuration to facilitate attachment to the two end connection point Since the drawings stated "....provided no traps are formed", the flexible metal hose installations on instrument drawings 1-PT-544 and 1-PT-545 are in violation of 10 CFR 50 Appendix B, Criterion V (456/85032-02).

The inspector also identified a pipe support for instrument line 1-PT-545 which was located incorrectl However, this item was previously identified by a piping contractor quality control inspector and documented on nonconformance report number 3970. The item is considered close . Reactor Coolant Piping The inspector selected two Inservice Inspection drawings of the reactor coolant system for review. The drawings selected were IRC-09, which delineated lines 1RC21AB-8" and IRC21BB-8"; and IRC-08, which delineated line IRC09-EA-3". The piping was classified as ASME Boiler and Pressure Vessel Code, Section III, Subsection NB, Class 1. The lines were then physically inspected for conformance to the as-built drawings. The inspection confirmed that the installations were accurately documented .

on the drawings. In addition, the drawings were compared with the piping contractor's corresponding as-built isometrics and with Southwest Fabricator's Code Data Sheets. The drawings were in agreement with the isometrics and Code Data Sheets. Changes to the drawings were properly documented on field change request Attributes checked in the field included quality of the welds, identifi-cation of the weld and welder, component identification, configuration, location, and material conformance with the design specificatio No violations or deviations were identifie . Pipe Supports The following pipe supports were inspected for configuration, traceability of structural steel, and the workmanship of the welding:

1RH022055 1SI010295 1CV020035 1SIO4016S

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These hangers were classified as Class A, ASME Section III, Subsection N The inspector verified that the configurations of these hangers were in agreement with the applicable Sargent & Lundy drawing The quality of the workmanship of the welding was also verified to be acceptable. The structural members, such as tube steel and plate, were verified to be traceable to Certified Material Test Reports (CMTR).

The following structural members were verified for traceability:

Pipe Support Material Heat Number MRR 1RH022055 Tube Steel S9425 13983 Tube Steel E69100 14092 ISIO10295 Tube Steel Y73226 13702, 13826, 14872 Tube Steel 32235 15535 Plate 22421 13796 1CV02003S Tube Steel T45967 13712 Plate B2886 13485 ISI04016S Tube Steel W2700 12776 Plate 89807 8846 Plate 88976 8809 I-Beam 1815677 8910 Ten pipe supports were examined for compliance to Sargent & Lundy Specification F/L-2739, drawings, and Phillips Getschow Co. Procedure, QCP-823, " Installation and Inspection of Component Supports." The supports inspected and their system identification are as follows:

Pipe Support System 2CC76001T Component Cooling 2SX36028R Essential Service Water 2SX15067R Essential Service Water 2SX17032R Essential Service Water 2SX17051R Essential Service Water 1SI18053R Safety Injection 1CC02154R Component Cooling ICV 47020X Chemical and Volume Control 2CC15046R Component Cooling 1SX17032R Essential Service Water The supports were installed in compliance with the specification, drawings, and procedure. Attributes examined included welding, location, dimensional tolerances, material identification, welder identification, and configuration. In addition, concrete expansion anchor installations were inspected for compliance with Sargent & Lundy Specification BY/BR-CE A portion of component support 2CC76001T was removed after installation as directed by field change order number 2CC-15817. The portion removed

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was a 2" x 2" x 3/8" x 9 1/2" long angle and a 3/8" x 3/4" pipe diameter U-bolt, however, a field change order was not written to control and provide for reinstallation of the angle and U-bolt which restrains the pipe.

i The 3/4" pipe was part of the component cooling system and classified as ASME Boiler and Pressure Vessel Code Section III, Subsection ND, Class Phillips Getschow Co. Construction Procedure, PGCP-1, Revision 14, November 1, 1984, " Control of Field Change Orders" states in part in Section 6.1.2 that the field change order shall control removal / reinstallation of a component suppor Adequate controls were not implemented to assure the reinstallation of the component support as required by procedure PGCP-1. Failure to issue a field change order for reinstallation is a violation of 10 CFR 50,

Appendix B, Criterion V (457/85031-02). Quality Control Supervision - Electrical Contractor L. K. Comstock procedure, 4.1.2, " Position Delineation", Revision B, was reviewe Paragraph 1.21 of the procedure states

"1.21 Quality Control (A) QC Supervisor of Inspectors - Reports to the Quality Control Manager / Designee Responsible for supervising Quality Control Inspectors assigned to his area of responsibility in implementing required inspection per the L. K. Comstock QA/QC Program and providing information related to those inspections when requested by the QC Manager / Designee He shall be trained and knowledgeable in the assigned areas of responsibility and certified to Level II capability in those area He shall be responsible to assure completed QC checklist and other documentation in his area of responsibility are reviewed prior to filing."

The inspector reviewed the resumes, qualifications, and certifications of four quality control supervisors. Of the four supervisors, three were not certified as Level II's in some of the specific areas they were supervising, and documentation was not available certifying the individuals as Level I' The three supervisors and the specific areas they were responsible for are detailed below:

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Supervisor #1 Supervisor #2 Supervisor #3 Racewa Receip Condui Cable Pul Calibratio Cable Pul Condui Concrete Expansion Terminations.

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Anchor Termination Equipmen Welding / configuration Racewa Level II capability was not accredited to Supervisor #1 for conduit and termination Level II capability was not accredited to Supervisor #2 for equipmen Level II capability was not accredited to Supervisor #3 for conduit, cable pull, and termination Subsequently, the inspector determined that Commonwealth Edison audit number 20-84-555, on November 14, 1984, had documented numerous cases of lack of certification for quality control supervisor In response to the Commonwealth Edison finding, which is still open, L. K. Comstock revised their procedure 4.1.2, under Revision C and changed the requirement for the quality control supervisor by stating:

"He shall be trained and knowledgeable in the assigned areas of responsibility and will obtain certification to Level II capability in those areas. He shall be responsible to assure completed QC checklist and other documentation in his area of responsibility are reviewed by a certified Level II prior to filing."

This change enables L. K. Comstock to place personnel without Level II capability in supervisory positions, under the assumption that Level II capability will be accomplished at some later point in tim The inspector asked the licensee if this procedural change was acceptable, taking into consideration the supervisors job responsibilities and decision making function It appeared, on the basis of the documentation reviews, that the three supervisors had limited experience in the specific areas for which they did not possess Level II capability certificatio The finding was originally identified in the licensee's audit, which is still open, and the inspector will review the licensee's resolution of the audit findin This is an open item (456/85032-03; 457/85031-03).

No violations or deviations were identifie . . Piping Wall Thickness The inspector reviewed two cases of potential piping minimum wall violations for pipe shipped to the Braidwood Statio . -. -. . .- - .

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. IE Information Notice No. 84-52 identified two vendors that had shipped pipe to another nuclear power plant in which 20% of the pipe shipped from one vendor and 40% of the pipe shipped ' rom the other vendor did not meet the minimum wall thickness requirement of the ASME Code. The worst case found was 5.3% below the required minimum wall thickness. The notice stated that this cannot be assumed to be a limiting worse case. Commonwealth Edison has identified the pipe they have received from the two vendors and is instituting a nondestructive examination program to ascertain if any reduced wall thickness pipe was received at Braidwood and if there is any safety significance. This is an open item (456/85032-04; 457/85031-04). (0 pen) Part 21 (456/85-03-PP; 457/85-03-PP) Guyon Alloys, Inc, notified the NRC Vendor Program Branch on February 14, 1985 that Commonwealth Edison procured 3/4" nominal pipe from one of their manufacturers for the Braidwood Station, and a small quantity of this pipe was discovered to have imperfections. The worst case found was .013 inches below minimum wall thickness. Mandrel extrusion gouges appear to be the cause of the deficiency and the licensee is evaluating the issue with regard to other heats of pipe furnished by the same manufacturer. The evaluation involves both visual inspections and eddy current examination. Stress calculations will be performed after examination as necessar No violations or deviations were identified."

10. Reactor Vessel Internals The inspection of the Unit 1 reactor's guide tubes by Westinghouse personnel was witnessed by the inspector. This inspection was supervised by a Westinghouse Level III Quality Assurance (QA) Engineer. A review of this individual's certification record revealed that he had two years experience in inspecting reactor vessel internals, five years experience as a QA Field Surveillance Engineer, and four years experience as a Nuclear Product QA Engineer. This inspection was performed in accordance with Westinghouse Specification 2464A20, Revision 1, " Reactor Internals Assembly Specification." This specification required an internal profile of the guide tube assemblies per Westinghouse Specification 2463A59, Revision 4, " Environmental Internals Profile Inspection Procedure." The inspector reviewed the inspection records for guide tubes CCE-43 and CCE-24. The calibration record for the recorder utilized in these guide tube inspections was also reviewed with no problems being note No violations or deviations were identifie . Electrical Items The inspector selected junction boxes 1JB1971 and 1JB1733A which were reinspected by an L. K. Comstock Level II Quality Control inspector as a result of violation 456/85015-08. The inspector verified that the following attributes were in compliance with established requirements:

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• junction box installed per latest drawings as to size, location and box type,

• -junction box identification is correct,

• junction box is free of any internal or external damage,

• junction box is clean, i.e. no debris, tools or foreign materials are stored in or on the junction box,

• clearances have been maintained or documented for engineering revie 'The following drawings were used in the inspection:

Junction Box Drawings 1JB1733A 20E-0-3373 20E-0-3393J 1JB1971A 20E-0-3361 20E-0-3393U The removal of two junction boxes, 2JB377R and 2JB011R, was reviewed to verify that the method for removing these items was in compliance with established requirements. The inspector reviewed Rework Report #1043 which documented the removal of these junction boxes on February 21, 1985. -No problems were noted with the removal proces The records for the installation of bars for the purpose of supporting kellums grips were reviewed and found acceptable. The installation of these bars were for cables routed to panels 1AN01J and 1CX05J. The records included a Weld Inspection Record (Form 19) and a Component Fabrication / Installation Traveler (Form 244). Detail G on drawing 20E-0-3393P was utilized for the installation of these bars. The inspector also reviewed the records for the installation of Radiation Monitor, 1RE-AR024 The records reviewed included a Concrete Expansion Anchor (CEA) Traveler 20418. The inspector also verified 1RE-AR029B was mounted per the requirements identified in drawing 20E-6-3391T, Detail 702 The inspector selected five conduits, which were recently inspected by L. K. Comstock (LKC) quality control inspectors, to verify the effective-ness of LKC's inspections. The conduits were inspected for:

• segregation code label

• size of conduit

• separation criteria

• the number of conduit supports

• correct hanger welding detail

• acceptable welding on. hangers

• correct bolting material

• flex conduit fittings

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The conduits inspected and their associated drawings are:

Conduit Drawings C1A52C1 20E-1-3352 20E-1-3352 C02 20E-1-3352 C05 l 20E-1-3342 l

'20E-1-3342 C04 20E-D-3393S C1R34A0 20E-1-3534 20E-1-3534 C01 20E-1-3534 C03 20E-0-3393C 20E-0-33935 C1R3382 20E-1-3533 20E-1-3533 C01 20E-1-3533 C02 20E-0-3393A 20E-0-33938 20E-0-3393R CIA 17N3 20E-1-3317 005 CIA 17T6 20E-1-3317 005 The inspector reviewed two Commonwealth Edison audits of LKC to verify the audits were comprehensive and properly documented. The audit reports reviewed were:

Audit N Dates Conducted Scope QA-20-85-52 April 22-26, 1985 Quality Control Qualification Welding / Weld Rod

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Contro Rewor Core Drillin Regulatory. Guide 1.5 Documentation Review Progra QA-20-85-503 January 30 - Cable Pulling /

February 5, 1985 Installatio Termination Electrical Penetration Q. A. Progra Q. A. Procedure . .

The inspector also reviewed LKC's program for trending nonconformance reports to verify proper implementation and resolution of any trends that were identified. The last quarterly trend report was issued by LKC to Commonwealth Edison on DKember 15, 1984. This trend report covered the period from September 1, 1984 to December 1, 1984. This trend report identified two trends pertaining to cable tray and junction boxe These trends were:

• Cable Tray - inadequate bolt torquing and missing side rail * Junction Boxes - lack of "0" rings, no welder identification, not installed per detai The trend report required LKC Engineering and Construction to respond by January 19, 1985, with their completed or planned corrective action. On January 21, 1985, the Assistant Project Engineer responded to LKC's QA department identifying the corrective action taken to eliminate the identified trends. The corrective action consisted of training the appropriate construction personne While the inspector was conducting his review of LKC's trending program, Commonwealth Edison also was conducting an audit (QA-20-85-540) of LKC. During this audit, Commonwealth Edison identified the fact that LKC had not issued any trend reports since December 15, 1984. An audit finding identifying this deficiency was discussed with LKC personnel during the audit exit meetin This audit finding also identified the lack of LKC follow up to verify the effectiveness of the corrective action taken to eliminate the trends noted in the December 15, 1984 trend report. The audit finding issued by Commonwealth Edison documenting the lack of trending by LKC will be monitored in the future by the inspecto No violations or deviations were identifie . Mechanical Equipment The removal process of the pressurizer safety relief valves, 1RY8010A, 1RY8010B, and 1RY8010C for preparation for cold hydrostatic testing of the primary was reviewed for adequacy. The valves were removed by means of the following Field Change Orders (FCO):

FC0 Valve 1RY-18892 1RY-8010A 1RY-18832 1RY-8010B 1RY-18906 1RY-8101C These FCOs authorized the removal of these valves and the installation of blind flanges for cold hydrostatic testing. The valves were removed and the blind flanges installed the week of August 26, 1985. The previous Mechanical Joint Checklists (MJC) which documented the bolt-up of the valves to the spool were voided and new MJCs were initiated for the reinstallation of the valves after the cold hydro. While the valves are removed from the system, the licensee's Mechanical Maintenance Department will calibrate them for the proper relief settin ._

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The inspector noted that the valves were located in a heavy traffic area without adequate protection for several days within the plants machine shop. The inspector discussed this situation with the maintenance department and the valves were moved to a room with 3 controlled acces This instance is considered to be an isolated cas The inspector verified that three (3) high point vent valves and one (1)

drain valve were properly identified with an ASME nameplat The valves verified were:

Valve Description S&L Drawing 1ZZ288W Volume Control Tank (VCT) M-64 Sheet 4 Inlet High Point Vent 1ZZ288J VCT Outlet Header to Charging M-64 Sheet 4 Pump Section High Point Vent 1SIO85 Safety Injection Pump Discharge M-61 Sheet 3 to Hot Leg High Point Vent ISIO86 Safety Injection Pump Discharge M-61 Sheet 3 to Hot Leg Low Point Drain All valves were required to be fabricated to ASME, Section III, Subsection NC_(Class 2). The nameplates attached to these valves did identify them as Class 2 valves. The valves were manufactured by Borg-Warner to the requirements of S&L specification L-2794- No violations or deviations were identified.

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13. 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 both. Open items disclosed during the inspection are discussed in Paragraphs 8 and . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. An unresolved item disclosed during the inspection is discussed in Paragraph . Exit Interview The inspector met with licensee and contractor representatives denoted in Paragraph 1 during the inspection on August 2 and at the conclusion of the inspection on September 5, 1985. The inspector 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 information disclosed during the inspection could be considered proprietary in natur __ - - - - - -

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