IR 05000456/1986027
| ML20206N299 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 08/18/1986 |
| From: | Dunlop A, Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20206N298 | List: |
| References | |
| 50-456-86-27, NUDOCS 8608260211 | |
| Download: ML20206N299 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-456/86027(DRS)
Docket Nos. 50-456 License No. CPPR-132 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Station, Unit 1 Inspection At: Braidwood Station, Braceville, Illinois Inspection Conducted: June 2 through August 7, 1986
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A. Dunlop Date 3'lD Approved By:
f Test Programs Section Date Inspection Summary Inspection on June 2 through Augu_sL7_,_198_6,JR_eport No. 5_0_-_4_56f86_027_(DR_SJ Areas Inspected: loutine, announced safety inspection to rev'lew actions on
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previous inspection items (92701, 70341, 70338, 70315); preoperational test program implementation (70302); preoperational test procedures review (70303, 70304,70305,70354,70334); preoperational test procedure verification (70311); preoperational test performances (70312, 70315, 70434, 70454, 70317);
preoperational test results evaluation (70325); and preoperational test results verification (70329).
Results: Of the seven areas inspected, no violations or deviations were
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identified.
8608260211 860819 DR ADOCK 0500
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DETAILS 1.
Persons Contacted Corrmonwealth Edison Comp _any_JCEcoj, M. J. Wallace, Project Manager C. W. Schroeder, Station Services Superintendent C. J. Tomashek, Project Startup Superintendent W. P. Poirier, Unit 1 Startup Supervisor
- P. L. Barnes, Regulatory Assurance Supervisor D. Paquette, Assistant Superintendent - Maintenance M. Takaki, Operations Quality Control Supervisor S. Hedden, Instrumentation Supervisor R. Hutchings, M&TE Supervisor - Instrumentation F. Peralez, M&TE - Electrical Maintenance T. Weis, Project Engineering Department
- P. A. Boyle, Regulatory Assurance
- J. K. Jasnosz, Regulatory Assurance l
- L. E. Davis, Assistant Superintendent, Technical Services T. W. Simpkin, Regulatory Assurance
- D. L. Cecchett, Regulatory Assurance
- T. J. Lewis, Startup Staff - NOVA S. Stapp, Operations Quality Assurance Additional station technical, operational, and administrative personnel were contacted by the inspector during the course of the inspection.
- Denotes those attending the exit meeting on August 7, 1986.
2.
Action on Previous Inspec, tion Items a.
(Closed) Open Item (456/85008-03(DRS)): This item concerned demonstrating the functional capability of the diesel generator (DG)
units at full-load temperature conditions as required by Regulatory Guide 1.108, Section C.2.a(5). An additional test procedure, DG-12
" Emergency Diesel Generator Test", has been issued to satisfy this l
requirement..DG-12 is performed subsequent to the DGs' 24-hour
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endurance test to ensure that the DGs start on a loss of all a.c.
l voltage and to demonstrate the proper operation of the
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design-accident-loading-sequence to design-load requirements. This item is considered closed.
I b.
(0 pen) Open Item (456/85008-05(DRS)):
This item concerned demonstrating that the diesel generator (DG) units ability to supply emergency power within the required time would not be impaired during periodic testing as required by Regulatory Guide 1.108, SectionC.2.a(8). The FSAR states in the example in section 8.3.1.1.1 that in the event of the simultaneous occurrence of:
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(1) DG undergoing full-load testing and being operated in parallel to its ESF bus, (2) loss of offsite power, (3) a design-basis accident, The DG breaker will trip, stripping the loads on the ESF bus and when the DG reaches rated speed and voltage the DG breaker will reclose.
The additional testing performed by the licensee only showed the DG breaker tripping under these conditions. Further conversations with the test engineer and Project Engineering Department (PED) has shown that the DG breaker is designed so as to not automatically reclose onto the ESF bus until the operator moves the breaker control switch from the
"after close" to the "after trip" position. This is due to the "STP" control switch contact in the breaker automatic closing control circuit.
The purpose of the "STP" contact is to prevent a breaker from automatically reclosing onto the bus (after it has automatically tripped)
without the operator first investigating the cause of the trip. The licensee's reasoning behind this design is to prevent unwarranted automatic reclosing and possible " pumping" under certain operating conditions.
The DG breaker design does not appear to meet the intent of the Regulatory Guide 1.108 or the licensee's comitment in the FSAR.
This item will remain open pending further review by the inspector.
c.
(Closed) Unresolved Item (456/85016-03(DRS)): This item concerned the verification of Auxiliary Feedwater (AFW) flow limiting devices by line flow checks and identification tab data as required by Table 14.2-19 in the FSAR. The identification tab data was added to AF-10, " Auxiliary Feedwater," in Appendix D.
The line flow checks were verified by establishing flow to each steam generator and through the recirculation lines. The inspector has no further concerns and considers this item closed.
d.
(Closed) Unresolved Item (456/85008-08(DRS)): This item concerned the validity of the 1A Diesel Generator start during EF-11. "ECCS Full Flow," due to a previously identified fuel oil priming concern.
(Unresolved Item 456/85008-07(DRS) remains open pending further licensee actions on the DG priming problem.) The licensee did not accept the results from EF-11 and the test was revised to include prerequisites to ensure that the DGs had not been operating for a 24-hour period prior to the test. Due to the actions taken by the licensee, this item is considered closed.
e.
(Closed)UnresolvedItem(456/85016-02(DRS)): This item concerned the apparent lack of testing from the Condensate Storage Tank (CST)
level instruments in the following two areas:
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(1) The AFW pumps suction supply will switch from the CST to the Essential Service Water system at a CST level of seven feet.
(2) The AFW pumps will trip with a CST level of four feet.
The above safety functions are accomplished by calibrating (through
. engineering calculations) the AFW pump suction pressure switches to coincide with the CST levels. This design allows the pressure switches to be located in the Category I supply piping for seismic considerations. The applicable testing was performed in AF-10 and this item is considered closed.
P_reope_ rational _ Test Program Implementation 3.
e This review consisted of a determination if administrative controls had
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been developed and implemented to support FSAR commitments, and regulatory requirements. The inspector had the following comment on measuring and test equipment (M&TE).
Test equipment or permanently installed instrumentation used for verifying preoperational test acceptance criteria must be calibrated. To determine how this assurance is provided at Braidwood, discussions with representatives from Startup, Instrurrent Maintenance, Electrical Maintenance, and Operating Quality Control were necessary.
The Instrument Maintenance Shop, which monitors a majority of the portable measuring and test equipment, has a program to calibrate M&TE, including tracking where the M&TE was used. Unfortunately, the tracking mechanism is designed for the operating staff and does not include M&TE used by Startup.
The Electrical Maintenance Shop, on the other hand, maintains an M&TE log which includes use by the contractor (Comstock) and by Startup. When an M&TE is reported out of calibration, a memo is sent to all users of that equipment including Startup. For example, Discrepancy Report 20-86H041 documented that a digital multimeter was found out of calibration. A memorandum was written to Startup on 2/13/86 with a second notice on 4/4/86.
A response from Startup on 4/15/86 indicated that Deficiency Reports EF-10-240, DG-10-149, and DC-10-42 were written to determine if any retesting was required based on the out of calibration meter.
i Because of the different programs being used, including split QA/QC responsibility between the Construction and Operating sides, the potential exists for an out of calibration instrument to not be traced back to the preoperational tests where it was used. This will be considered an open item (456/86027-01(DRS)) pending a further review of the program.
No violations or deviations were identified. However, a portion of this area requires further review and evaluation and is considered to be an open item.
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Pre _ opera _tional _ Test Procedure Review 4.
r The inspector reviewed the following preoperational test procedures against the FSAR, Safety Evaluation Report (SER), proposed Technical Specifications and Regulatory Guide 1.68:
BwPT RP-10, Revision 0, " Reactor Protection Time Response" BwPT RP-13, Revision 0, " Reactor Protection Logic Checks" BwPT EF-10, Revision 3, " Unit One Engineered Safety Features"-
EwPT NR-10, Revision 0, " Neutron Monitoring - Excores" The review of EF-10 has not been completed at this time and will be documented in a subsequent inspection report.
a.
With respect to RP-10, the inspector had the following concern:
The response times for the Reactor Protection System (RPS) and Engineered Safety Features Actuation System (ESFAS) instrumentation channels include the time for the sensor to detect the change in the monitored parameter. This is indicated in ISA-S67.06, " Response Time Testing of Nuclear Safety-Related Instrument Channels in Nuclear Power Plants," Regulatory Guide 1.68, the FSAR, and proposed Technical Specifications.
The test uses generic sensor response times obtained from Westinghouse (CVA-SU-2.7.1) in place of actual response timing. A justification for not satisfying the requirements for response time testing as defined in the above documents should be provided. This will be considered an open item (456/86027-02(DRS)) pending inspector's review of justification for use of generic sensor response times.
b.
With respect to RP-13, the inspector had the following comment:
The General Warning Alarm and Trip Function, Section 9.33, was not completely testing the logic since it did not include a loss of the 15 volt power supply. The licensee has incorporated Test Change Request (TCR) No.19 to verify this logic. The inspector has no further concerns.
No violations or deviations were identified. However, a portion of this area requires further licensee justification and is considered to be an open item.
5.
Preoperational _ Test Procedures Verification The inspector reviewed the following preoperational test procedure and verified that it was written, reviewcd, and approved by licensee management in accordance with the requirements of Regulatory Guide 1.68, BwSUM, and the licensee's QA Manual:
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BwPT FW-18, Revision 1, " Steam Generator Level Alarm & Setpoint Verification (IHF)"
No violations or deviations were identified 6.
Preoperatic_na_l Tes_t Performance The inspector witnessed the performance of portions of the below listed preoperaticnal 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 tests.
BwPT EF-10, Revision 3, " Unit One Engineered Safety Features" BwPT NR-10, Revision 0, " Neutron Monitoring - Excores" BwPT RP-10, Revision 0, " Reactor Protection Time Response" BwPT RP-13, Revision 0, " Reactor Protection Logic Checks" The inspector has the following consents:
a.
The tests were performed in a professional manner.
Personnel were knowledgeable of the equipment, procedures, and their specific responsibilities. Communications anong personnel involved with the testing was good, b.
During RP-10, Section 9.2, some minor confusion resulted from the need to convert values of temperature into resistance and voltage levels which had to be applied to the logic to simulate the temperature conditions.
In order to adequately review the test procedure, all the calculations should have been logged in the sequenceofeventslog(SEL).
In addition, a Startup Training Instruction, TI-19, has a pre-test checklist which requires independent verification of computations. This is not apparent in the procedure. This will be considered an open item (456/86027-03(DRS))
pending completion of the inspector's review.
c.
A concern conmon to all procedures is the lack of detail in the SEL.
The inspector informed the STE on several occasions that events should be logged.
In order to properly evaluate test results the SEL should address all test stoppages, problems, and similar events as required by the DwSUM. The inspector requested the Unit 1 Startup Supervisor to pass this concern on to all the test engineers. This will be accomplished in one of Startup's training sessions. The inspector will continue reviewing SELs to determine compliance with the BwSUM.
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No violations or deviations were identified. However, a portion of this area requires further review by the inspector and is considered to be an open item.
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Pre _ ope _ rational _ 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 were appropriately resolved, reviewed by management and retested as required; test results were evaluated by appropriate engineering personnel and specifically compared with acceptance criteria; data were 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 personnel.
BwPT RP-11, Revision 0, " Reactor Protection and Engineered Safeguards Logic Test" The review of RP-11 test results package has not been completed at this time, but the inspector had the following comments:
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Section 6.3 lists test equipment used to verify acceptance criteria with a notation to perform post test calibration. No post test calibrations were found to have been performed. The test engineer initiated Deficiency RP-11-05 to perform the calibrations.
b.
Deficiency RP-11-02 described a voltage measurement problem in-the RPS logic relays, but the test evaluation did not discuss its impact on the test even though the deficiency remained "open".
The test engineer has included an evaluation on this open deficiency.
The inspector has no further concerns in these areas.
No violations or deviations were identified.
8.
Preoperational Test Results Ver_if_icati_on The inspectors reviewed the following preoperational test procedures 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 Startup Manual:
BwPT FW-17, Revision 0, " Tempering Flow Test (IFF)"
BwPT FW-18, Revision 1, " Steam Generator Level Alarm & Setpoint Verification (IHF)"
BwPT LM-17, Revision 0, " Reactor Loose Parts Monitor for IHF" The inspector noted that several major TCRs used to incorporate PED comments did not have PED approval signatures as required by the BwSUM.
Instead the signature block had "see attached sheet," which would reference a PED letter that contained comrrents to the procedure. For TCR
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No. 1 of LM-17, the comments in the referenced letter did not match the change on the TCR. The inspector is concerned that the test engineers may not be appropriately following the intent of the BwSUM that requires PED approval of all major TCRs. The inspector will continue to review this issue. This will be considered an unresolved item (456/86027-04(DRS))
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pending completion of the inspector's review.
No violations or deviations were identified. However, a portion of this area requires further review by the inspector and is considered to be an unresolved item.
9.
Oyen 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 3, 4.a. and 6.b.
10. Unresolved Items _
Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. Unresolved items disclosed during the inspection are discussed in Section 8.
11. Exit Interview The inspector met with licensee and contractor representatives denoted in Paragraph 1 during and at the conclusion of the inspection on August 7, 1986. 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 nature.
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