IR 05000329/2005010

Insp Rept 50-456/85-16 on 850329-0510.No Noncompliance or Deviation Noted.Major Areas Inspected:Actions on Previous Insp Items,Preoperational Test Program Implementation & Preoperational Test Procedures Review

ML20129A205
Person / Time
Site:	Braidwood, Midland
Issue date:	05/30/1985
From:	Dunlop A, Farber M, David Williams NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20129A201	List: IR 05000329/2005010 ML20129A197
References
50-456-85-16, NUDOCS 8506040501
Download: ML20129A205 (7)

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U.S. NUCLEAR REGULATORY COMMISSION l

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REGION III

Report No. 50-456/85016(DRS)

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Docket No. 50-456 License No. CPPR-132 Licensee: Cmmonwealth Edison Company , Post Office Box 767 1 Chicago, IL 60690 Facility Name: Braidwood Station, Unit 1 Inspection At: Braidwood Site, Braidwood, IL Inspection Conducted: March 29, through May 50,1985 Inspectors: D. L. Wi 11 5/%/f5

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M. J. Far e Date LY Approved By: M.A. Ring . 2. Licensee Actions On Previous Inspection Findings (Closed) Open Item (456/83-20-02(DE)): This item involved the applicability of administrative procedures prior to fuel load. The licensee has approved and issued BWAP-1300-7, " Procedure for using Request for Notification to Implement Procedures." - The inspector has reviewed the procedure and the current results. The action taken appears adequate and this item is considered closed.

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(Closed) Unresolved Item (456/84-41-02(DRS)): This involved a lack of independent verification for lifted leads and jumpers in approved preoperational test procedures. The inspector has reviewed Revision 11 of the Braidwood Startup Manual (BWSUM) and reviewed the documentation for training that addressed this concern. The inspector has no further comments and this item is considered close (Closed)UnresolvedItem(456/84-41-03(DRS)): This item involved the differences in documenting minor Test Change Requests (TCRs) from the method used for major TCRs. The licensee has revised the Braidwood Startup Manual to include a requiren<ent to initiate form BWSM 3-2 and has completed fermal training of System Test Engineers (STEs) in this requirement. The inspector has no further comments and considers this item close (0 pen) Open Item (456/84-41-04(DRS)): This item involved not requiring approval or concurrence for minor TCRs prior to implementation. The licensee has re-emphasized to involved participants that care should be exercised when initiating minor TCRs and the consequences if the guidance 2 _ __

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- as detailed in the BWSUM is not followed. The inspector has observed no apparent violations of the BWSUM reg,:rding this concern at the present time. .Since the .startup effort is .only 'just beginning the inspector will continue to monitor this concern. This item is still considered ope (Closed) Unresolved Item (456/84-41-05(DRS)): This item involved two examples of inadequate acceptance criteria. The first example concerned failure to provide numerical bounds for acceptance criteria and the second example . involved failure to. identify a preoperational test procedure step as acceptance criteria that had been committed to by Regulatory Guide 1.108. The inspector has reviewed major TCR No.- 39 for BWPT DG-10, " Diesel Generator" and considers this action adequat This item is considered close (Closed)OpenItem(456/84-41-06(DRS)). This item involved the commitment of the Project Startup group to implement a Final Safety Analysis Report-(FSAR) matrix review for preoperational test procedures and administrative procedures to assign responsibilities for this task. The inspector has reviewed PSU-07, " Procedure Review Against FSAR Matrix," and finds it acceptable. This item is considered close No items of noncompliance or d'eviations were identifie . Preoperational Test Program Implementation This review consisted of a determination if administrative controls had been developed and implemented to support FSAR commitments, and regulatory requirements. The inspector had the following coment:

The inspectors have been reviewing selected turnover for testing

. packages, the system files and System Status Notices (SSNs) for completeness. The review has not been completed at this time. This review will be documented in a-later inspection repor No items of noncompliance or deviations were identifie . Preoperational Test Procedure Review The inspectors reviewed the following preoperational test procedures against the FSAR, Safety Evaluation Report (SER), proposed Technical Specifications, and Regulatory Guides 1.68 and 1.139(AF-10):

BWPT WO-10, Revision 0, " Control Room Chilled Water System" BWPT RP-11, Revision 0, " Reactor Protection and Engineering Safeguards, Logic Test" BWPT AF-10, Revision 1, " Auxiliary Feedwater" The inspector has the following comments:

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.. BWPT RP-11, Revision 1, "Re' actor Protection and Engineering Safeguards Logic Test." The licensee has not issued an approved preoperational test procedure, .the inspectors cannot complete their review at this time. The review will be documented in a subsequent inspection report when an approved preoperational test procedure becomes availabl b.. 'BWPT AF-10, Revision:1, " Auxiliary Feedwater System."

(1) The; test procedure does not appear to incorporate all of the recommendations from NRC Question 10.53, Part.III, Section 2,

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NRC recommendation 2.2, concerning the 48 hour auxiliary feedwater (AFW) pump run followed by shutdown, cooldown and pump restart run of one hour. The recommendation states that " Test acceptance' criteria should include demonstrating that the pumps remain within design limits with respect to bearing / bearing oil temperatures and vibration and that pump room ambient conditions'

 (temperature, humidity) do not exceed environmental qualification-limits." Acceptance criteria 4.5 does not include all of the requirements as follows:
 (a) No vibration readings taken during 48 hour run for eithe AFW pum (b) No vibration readings taken during one hour restart for 1A AFW pum (c) A note in the procedure requires taking vibration readings on-1B AFW pump during the one hour restart run although no guidance is given as to where the readings are to be taken
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 (pump, speed changer, diesel) or recorded and what the maximum vibration limits ar (d) No acceptance criteria for bearing / bearing oil temperature during 48 hour run for both AFW pump (e) No data required for bearing / bearing oil temperature during the one hour restart run for IA AFW pump which is acceptance criteri (f) Step numbers given in acceptance criteria 4.5 for verifying bearing / bearing oil temperature during one hour restart run are incorrec (g) No pump room temperature and humidity taken during the one

> hour restart run for 1A AFW pump which should be acceptance criteri (h) No acceptance criteria for pump room temperature and humidity during one hour restart for 1B AFW pum This is considered an unresolved item (456/85016-01(DRS)) pending additional information from the license . ?

(2) The licensee response to NRC Question 10.53, Part III, Section 3, NRC recommendation GL-4, states that to prevent air binding of the AFW pumps, the pumps supply will switchover automatically from the condensate storage tank (CST) to the essential service water (ESW) system at~ a CST level of seven feet and secondly a CST level of four feet will cause the AWF Pumps to trip. This does not appear to be tested in the procedure and will be considered an unresolved item (456/85016-02(DRS)) pending additional information from the license (3) In Table 14.2-19 of the FSAR, the test summary section states that "all flow limiting devices will be verified by line flow checks and identification tab data." This does not appear to have been incorporated into the test procedure and will be considered an unresolved item (456/85016-03(DRS)) pending additional information from the license .(4) The licensee response to NRC Question 10.53, Part III, Section 1, NRC recommendation GS-4 states that the switchover from the CST to the ESW system will occur " automatically upon a low pressure at the suction of the AFW pumps in conjunction with a low-low steam generator level, loss of offsite power, or safeguards action signal." The test procedure states the switchover will occur on a " low-low pump suction pressure in coincidence..."

This will be The two statements considered appear an unresolved item to be conflicting (.DRS)) pending (456/85016-04 additional information from the license . Preoperational Test Procedure Verification The inspectors reviewed the following preoperational test procedure and verified that it was written, reviewed and approved by licensee management in accordance with the requirements of Regulatory Guide 1,68 and.the licensee's QA Manual: BWPT LD-10, Revision 0, " Leak Detection System." The inspector had commenced the review of LD-10 until informed that a major revision to_the procedure was in progress. Review of the procedure will continue after licensee approval of the revision and will be-documented in a subsequent inspection repor No items of noncompliance or deviations were identifie . Preoperational Test Performance The inspectors witnessed the performance of portions of the below listed-preoperational test procedures in order to verify that testing was conducted in accordance with approved procedures, independently verified the~ acceptability of test results, and evaluated the performance of licensee personnel conducting the test .

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-a BWPT WO-10, Revision 0, " Control _ Room Chilled Water System."

BWPT RY-10, Revision 0, " Pressurizer."

The inspector has no comments at this tim No items of noncompliance'or deviation were identif_ie . Preoperational Test Results Evaluation-The inspectors . reviewed the results of the below listed preoperational test procedures to verify all test changes were identified and approved in accordance with administrative procedures; all test deficiencies weie appropriately resolved, reviewed by management and retested as required; test results were evaluated by appropriate engineering personnel and specifically compared with acceptance criteria; data was properly recorded, signed, dated and documented as test deficiencies, as necessary; test packages were reviewed by QA for adequacy of contents;

'and test results were approved by appropriate personne '

BWPT RH-10, Revision 0, "R'esidual Heat Removal" BWPT SI-10, Revision 0, " Safety Injection BWPT SI-11, Revision 1, " Safety Injection-Accumulators" RH-10, SI-10 and SI-11 results reviews have been comenced but were not completed and will be documented in subsequent inspection repor No items of noncompliance or deviation were identifie . Preoperational Test Results Verification

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The inspectors reviewed the following peroperational test procedure and verified that results were reviewed against approved acceptance criteria and an evaluation of the test results had been performed in accordance with Regulatory Guide 1.68 and the licensee's Sta'rtup Manual: BWPT 00-12, Revision 0, " Diesel Fuel Oil Transfer System." The inspector has the following coments:

 -(1) Deficiency number D0-12-80 was initiated for Appendix C of the test procedure since the required operating and surveillance procedures which were to be verified in the appendix had not been written and approved. The deficiency was closed b ~

System Test Engineer (STE), Project Startup Groupand(PSG)y the Quality Assurance (QA) stating corrective action as " Procedures (operating) written and 'on-site-reviews' (0SR) 6pproved." The corrective action did not list which operating written or if they were verified (trial-tested) procedures were and surveillance procedures were not addressed in the deficiency. The_STE informed the inspector that the operating procedures had been verified per the deficiency. This appears to be inadequate documentation of corrective action to the deficiency. This will be considered _an unresolved item (456/85016-05(DRS)) pending additional licensee action and subsequent review by the

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 (2) The licensee has not approved the D0-12 completed test results-package. The inspector cannot complete the review until-licerisee resolution and approval of all~ identified concerns.-

This is considered an open item (456/85016-06(DRS)) pending review of an approved test results package by the inspecto . Open Items-Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some actio on the part of the NRC or licensee or both. Open items disclosed during the inspection are discussed in Paragraph Ba(2).

10 Unresolved Items

 ' Unresolved items are matters about which more information is required in orde'r to ascertain whether they are acceptable items, Items of of Noncompliance, or Deviations. Unresolved items disclosed during the inspection are . discussed in Paragraphs 4.b.(1), 4.b.(2), 4.b.(3), 4.b.(4)

and8.a.(1).

}' 11. Exit Interview > The. inspector met with the licensee and contractor representatives .

 (denoted in Paragraph 1).on May:10, 1985.- The inspector summarized the

. scope and findings of the inspection. The inspector also discussed the likely informational content of the inspection report with regard to , documents or processes reviewed by the inspector during the inspectio The licensee did not identify any such documents / processes as 1 proprietary.' The licensee acknowledged the statements by the inspectors _ with respect to open and unresolved item .

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