IR 05000456/1985044

Insp Repts 50-456/85-44 & 50-457/85-43 on 850822-0905.No Violation or Deviation Noted.Major Areas Inspected: Allegations & Licensee Action on Allegations

ML20133F446
Person / Time
Site:	Braidwood
Issue date:	09/26/1985
From:	Mendez R, Williams C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20133F428	List: IR 05000456/1985044 ML20133F426
References
50-456-85-44, 50-457-85-43, NUDOCS 8510110038
Download: ML20133F446 (5)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-456/85044(DRS); 50-457/85043(DRS)

Docket No. 50-456; 50-457 License 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: August 22, 23 and September 5, 1985 Inspector: R Me k#fdf h,mWLL9 b%

Approved By: C. C. Williams, Chief e7

/2 4 /IU Plant System Section '

Inspection Summary Inspection on August 22 through September 5, 1985 (Report No. 50-456/85044(DRS);

_50-457/85043(DRS))

Areas Inspected: Special, unannounced inspection of allegations; and licensee action on allegations. The inspection involved a total of 16 inspector-hours by one NRC inspecto Results: No violations or deviations were identifie %

PDH AM hh56 PDR O

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DETAILS 1. Persons Contacted Commonwealth Edison Company (CECO)

• L. M. Kline, Project Licensing and Compliance Supervisor R. M. Preston, Director, Quality First L. K. Comstock (LKC)

F. Rolan, QA Manager The inspector also contacted and interviewed other licensee and contractor personnel during this inspectio * Denotes those personnel attending the September 5, 1985 exit intervie . Review of Allegations (0 pen) Allegation (RIII-85-A-0032)

As part of an allegation received on February 15, 19M , the alleger advised the NRC that: (1) the S&L Mylar Department was not secure which allowed anyone to come into the department and remove mylars and Engineering Change Notices (ECNs); (2) mylars and ECN books were being taken from the room without proper sign-out; (3) the document control room has inadequate file cabinets and bookcases; and (4) she was not provided with adequate training. The individual had previously discussed her concerns with the Braidwood site Quality First Team on January 14, 1985, af ter being contacted by the team for an intervie Licensee Review The licensee review of this allegatio,was documented in its records as Concern Number QF-85-291 as follows:

(1) S&L and the licensee conducted audits of both the mylar and ECN document control systems during the period January 15 - August 7, 1985. The audit effort covered both past and current document control activities. The audit of the mylar control system identified approximately 2% administrative errors such as typing errors, timing of status posting, and misfiling of the mylar drawings. No deficiencies were identified during the ECN control system audit. The audits did not identify any instances where documents were improperly removed from the document control roo _

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(2) The licensee determined that the document control room is staffed during working hours (including two shifts) and at other times when special work schedules require the document room to be ope (3) The licensee determined the document control room to be adequately sized early in 1985 after it had been enlarged in November 1984. With the increase in document flow to approxi-mately 10,000 pieces of paper per month, the document control room was moved to a large trailer in April 198 NRC Review The NRC inspector determined through discussion with S&L personnel that the alleger was in charge of mechanical pipe support mylar Mylar drawings are translucent documents which are copied to produce blueprint (1) During a review by the NRC inspector of the original document control room (where the alleger worked during the-time that the allegation was made) it was determined that there was only one entrance into the room. Licensee personnel stated that the entrance to the room was blocked by a counter where drawings or ECNs could be signed-out. Licensee personnel also stated that it was the responsibility of the assigned clerk to keep unauthorized personnel out of the room. S&L management stated, however, that the clerk had allowed unauthorized personnel into the room on several occasion (2) Mechanical support mylars are required by S&L Procedure BFFI-5 to be controlled and anyone checking out a mylar drawing was required upon receipt to provide their signature for tracking and accountability purpose Based on discussions with S&L personnel and review of the reprimand the alleger received, it appeared that the assigned clerk (the alleger) had allowed mylar drawings to be checked out without receiving the required signatures. The inspector conducted a review of the control process for 50 randomly selected mylar drawings and all of the documents showed proper adherence to procedural requirement (3) It was determined by the NRC inspector that original ECN documents are not released from the document control room. A copy of the ECN is made for the individual requesting the EC This practice was in accordance with the approved procedure and was found to be acceptable to the NR (4) According to S&L management, the assigned clerk (the alleger)

had been given adequate verbal instructions for her task and was verbally warned about permitting unauthorized people into the room and the clerk was informed several times that she had complete control of access to the roo .

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(5) The present document control room appeared adequate and mylars

!. and ECN books were observed to be filed in an appropriate l manne Conclusion l

The allegation could not be substantiated. Based on the audit

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conducted by the licensee and the NRC inspection, no significant adverse conditions were noted regarding Mylar and ECN controls and facilitie It appears that adequate verbal instructions were given to the alleger to enable her to properly control activities at the document control room where she was assigned. This allegation

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remains open pending completion of Department of Labor action related to this matter, b. (Closed) Allegation (RIII-85-A-0005)

On January 14, 1985, an alleger telephoned Region III and provided the following allegation:

The alleger stated that Comstock Rework Program is " full of loopholes and that the documentation flow through QC is not clear in the procedure." As an example, the alleger stated that seldom is a basemetal inspection performed. The alleger stated that the basemetal inspection is required to be done after a defective part is removed and before the replacement is installe NRC Review The NRC inspector reviewed L. K. Comstock Procedure 4.3.2.4, Revision i B " Rework". The purpose of the procedure is to provide instructions to control and track rework. A review of the procedure indicated that it is clear and adequate in scope and applicability. The procedure requires that OC hold points be established and that the work described on the rework form be completed. For example, Comstock Engineering initiates a rework traveler (form No. 223) and rework tag which may establish a hold point. Form No. 223 requires

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that the licensee approve the traveler. The traveler is sent to the field along with the rework tag. A copy of the traveler is also sent to QC, When a designated hold point is reached, the craft foreman contacts the QC insocctor for inspection. When QC determines that all the work has been properly perfonned, they remove the rework tag. The completed traveler and QC inspection report is then sent through LKC Engineering and QC for final review. Discussions with five QC inspectors indicated they had no problems following the procedure and that they had not experienced any instances of harassment and intimidation associated with the performance of this activit With respect to the allegation that base metal inspections were not being performed, the NRC reviewed approximately two hundred rework travelers in various stages of completion. Travelers were reviewed in the records vault, in the LKC engineer's office and in the fiel Where applicable, it was noted that a hold point was established in

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o every situation requiring a base metal inspection. Additionally, L. K. Comstock weld inspection checklist form No. 19 requires that base metal be within the requirements described by L. K. Comstock Procedure 4.8.3, " Weld Inspection." All weld inspection checklists were ncted to be properly signed of On August 23, 1985, the NRC inspector witnessed a hanger being removed

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in the field. The rework traveler noted that a base metal inspection I was to be performed after removal of the hanger. The NRC inspector i observed that this work was proceeding in accordance with the instruction Conclusion The allegation could not be substantiated. Procedural requirements regarding rework and base metal inspections, including the associated procedures directing this element of the Comstock Rework

, Program, were found to be adequate and appropriately implemented.

3. Exit Interview The inspector met with the licensee representative (denoted in Paragraph

! I above) at the conclusion of the inspection on September 5, 1985. The l inspector summarized the scope and findings of the inspections noted in

! this report. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such document / processes as proprietary.

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