IR 05000456/1986043

Insp Repts 50-456/86-43 & 50-457/86-38 on 860811-0912.No Violations or Deviations Noted.Major Areas Inspected: Previous Insp Items,Preoperational Test Procedures, Verification & Results & Startup Test Procedures

ML20210G523
Person / Time
Site:	Braidwood
Issue date:	09/22/1986
From:	Dunlop A, Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20210G484	List: IR 05000456/1986043 ML20210G481
References
50-456-86-43, 50-457-86-38, NUDOCS 8609250416
Download: ML20210G523 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-456/86043(DRS);50-457/86038(DRS)

Docket Nos. 50-456; 50-457 License Nos. 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, Illinois Inspection Conducted: August 11 through September 12, 1986 Inspector: A. Dunlop, J Date 4., LM b 1- 2 "4 Approved By: M. A. Ring, Chief NMLDate 7-2Mfi

Test Programs Section Inspection Summary Inspection on August 11 through September 12, 1986 (Report No. 50-456/86043(DRS);

No. 50-457/86038(DRS))

Areas inspected: Routine, announced safety inspection to review actions on previous inspection items (70302, 70305, 70314, 70322, 70326, 70338, 70341, 92701,92702);

preop)erational 70333, 70334, 70341 test test

preoperational procedures procedurereview (70304, verification 70305, 70308,-

(70311);

preoperational test performances (70315); preoperational test results evaluation (70320,70322,70324,70325,70326,70533,70534,70541);

preoperational test results verification (70329); startup test procedure review (72500); and startup test program implementation (72400).

Results: Of the eight areas inspected, no violations or deviations were identifie PDR ADOCK 05000456 G PDR-

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DETAILS- Persons' Contacted-Commonwealth Edison Company (CECO)

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 T. Weis, Project Engineering Department P. A. Boyle, Regulatory Assurance J. K. Jasnosz, Regulatory Assurance L. E. Davis,' Assistant Superintendent, Technical Services

• T. W. Simpkin, Regulatory Assurance

• D. L. Cecchett, Regulatory Assurance

• T. J. Lewis, Startup Staff - NOVA

• A. J. D' Antonio, Regulatory Assurance

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J.~P. Leider, Project Engineering Department D. Kapinis, Station Startup Test Supervisor

• M. Inserra, TRB Supervisor /PSG Additional station technical, operational, and administrative personnel were contacted by the inspector during the course of the inspectio * Denotes those attending the exit meeting on September 12, 1986. Action on Previous Inspection Items (Closed). Unresolved Item (456/84009-12; 457/84009-12): This item concerned the reliability of the auxiliary feedwater pump oil system. Specific items of concern were the condition of the filter

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(filter delta P),. correct oil pressure, overpressure protection, the temperature change (delta T) across the oil cooler, and no oil filter bypas The response to these concerns is as follows:

(1) The bearing lube oil system has pressure indicating gauges on both sides of the filter, while the gear lube oil system does no Both systems do have low pressure switches downstream of the filters which annunciate an alarm on the main control panel and which will start the motor driven pump on low oil pressure. In addition, the filter unit is equipped with a handle to rotate the strainer element against a stationary knife to remove accumulated material. This operation is performed once per shift per Bw0P 199-A6 .-

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The alarm response procedure, BwAR 1-3-67, "AF Pump Lube Oil Press Low'," did not include a clogged strainer as a probable cause for low pressure.. The.-licensee has agreed to include-this item in the next revision to the procedure and it is being tracked by Operating Department Problem File, Number 8340. The licensee will also perform normal maintenance procedures to ensure clean oil, piping, and filter (2) Overpressure protection has been provided with a relief valve l downstream of the main and auxiliary lube oil pumps to relieve

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pressure back into the lube oil reservoi .(3) Instrumentation has been installed to allow lube oil-temperatures to be determined at the outlet of the lube cil cooler and at the bearing (4) The licensee stated that the use of a bypass around the filter is undesirable because of possible bearing failures if foreign particles are in-the lube oil syste Due to the licensee's actions, as addressed in (1) above, the inspector agrees with this conclusio After evaluating all the . responses, the inspector considers that the licensee has adequately addressed the concerns with respect to the reliability of the AFW pump lube oil systems. These items are considered close (Closed) Open Item (456/84041-04(0RS)): This item concerned not requiring approval or concurrence for minor TCRs prior to implementation. As documented in Inspection Report 456/85016, the licensee has re-emphasized to the test engineers that care should be exercised when initiating minor TCRs. The inspectors and TRB reviews of completed test packages have uncovered only a few minor TCRs that should have been major TCR None of these TCRs affected test result The-inspector has no further concerns in this area-and considers this item close (Closed) Unresolved Item (456/85008-01(DRS)): This item concerned the licensee addressing the initial conditions of the diesel generator in order to determine if a~ hot or. cold start is being conducted. In DG-10 and DG-11, the licensee has-defined initial conditions for the 35 consecutive starts of a diesel generato These include: (1)gmbientconditionsforlubeoilandjacketwater temperature (120-130 F); (2) forced cooldown sequencing; and (3)

time interval between stopping and starting of the diesel generators (30 minutes). However, the licensee did not address the initial start conditions while performing four consecutive starts using a single air receiver. The Safety Evaluation Report (SER) states that these should be cold starts while the licensee-performed hot starts during testin ,

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t The actions taken by'the licensee for the 35 consecutive starts is adequate while a concern still exists for the starting conditions

.using a single air receiver. The later concern will be addressed in 3 an Unresolved Item (456/86010-01(DRS)) and as such,'this item is

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considered closed.

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- - (Closed) Open Item (456/85008-06(DRS)): This item concerned the

lack of _ independent verification.of jumpers and lifted leads-during

preoperational tests. The licensee held a training session (2-27-85) to re-emphasize to all System Test Engineers (STEs) the I requirement for jumpers and lifted leads to be independently i- verified. The inspectors have witnessed subsequent tests and have- l

seen no further evidence of the lack of independent verificatio This. item is considered closed.

' (Closed) Open Item (456/85026-07(DRS)): This item concerned the review of the test results package for-BwPT AP-14, " Aux. Power, 480V

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MCCs, Feedbreakers and Below."~ The licensee has approved the test

, results and the inspector has reviewed the completed package with no

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additional comments. This-item is considered closed.'

1 (Closed) Unresolved Item (456/85016-04(DRS)): This item concerned-

the automatic switchover of the Auxiliary Feedwater (AFW) pumps'

suction from the condensate storage tank (CST) to-the Essential Service Water (ESW) system. The statements in the Braidwood Final

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Safety Analysis Report (FSAR) and the preoperational test, BwPT AF-10,." Auxiliary Feedwater," appear to be in conflict.

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The system is designed to perform the following: (1) AFW pump low suction pressure alarm; (2) arm the AFW pump ESW suction valves

, (low-low pressure); and (3) trip the AFW pumps (low-low-low i pressure). Each of these three items were adequately tested in BwPT

AF-10 and are addressed on both the main control room alarm panel i and the significant events recorder. The inspector's concern in the

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testing and operational aspects have been resolved. The licensee has committed, per Memo: Klopp to Schroeder, to amend the statement

. in the FSAR in a future revision. This. item is considered closed.

j (Closed) Violation (456/85026-01(DRS)): This item concerned the

. insufficient acceptance criteria for the 48-hour Auxiliary Feedwater pump endurance run, as performed per BwPT AF-10, Revision 1,

{ " Auxiliary Feedwater System." The licensee has since revised AF-10

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to include the required acceptance criteri This item is considered close ' (Closed) Unresolved Item (456/85026-05(DRS)): This item concerned the rewriting of two test deficiencies and the subsequent discarding '.

of the original deficiencies. The licensee requested all System Test Engineers (STEs) to recall if similar situations occurred j during their test and to document their response. No similar

! situations were documented and as such, the licensee believes this i

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to be an isolated case. In addition, the. licensee held a training session' on January 20, 1986, to discuss the subject with all the STEs.__The inspector concurs with the licensee's actions and considers this item close . (Closed) Unresolved Item (456/86010-03(DRS)): .This item concerned instruments that were found to be piped in backwards during

' Integrated' Hot Functional (IHF) Testing. The licensee has provided the inspector with a list of ten instruments that belong in this category. All.of the instruments are classified as Class D (non-safety related) and were correctly repiped. Construction drawings were updated as required to reflect the "as built" condition. In addition, Phillip Getschow Company is trying to implement a program to label all of the crossed "Hi" and "Lo" instrument lines which should eliminate any confusion on reinstalling instruments during future maintenance / modification activities. .The actions taken by.the licensee appear adequate to'

correct the deficient conditions and, therefore, the inspector-considers this item close ' (0 pen) Unresolved Item (456/86010-01(DRS)): This item requested the licensee to_ provide an air receiver pressure below~which a diesel generator (DG) would be declared inoperable. The licensee stated that a DG would be declared inoperable when: (1) one air receiver was.less than 240 psig; and (2) the other air receiver was out-of-service. The inspector requested the DG status if both air receivers were less than 240 psig. _In addition, the concern about initial starting condition (cold starts) of the DG for performing the four consecutive starts using a single air receiver remains unresolved. These concerns will continue to ne monitored by the inspector and as such, this item remains ope . Preoperational Test Procedure Review The inspector reviewed the following preoperational test procedures against the FSAR, Safety Evaluation Report'(SER), proposed Technical Specifications and Regulatory Guide 1.68:

BwPT CV-11, Revision 0, " Chemical and Volume Control System" i

i BwPT CV-17, Revision 1, " Chemical and Volume Control System (IHF)"

BwPT DG-12 Revision 0, " Emergency Diesel Generator Test"

BwPT MS-12,.-Revision 0, " Main Steam - PORV's" l

l BwPT MS-17, Revision 1, " Main Steam (IHF)"

BwPT RP-11, Revision 0, " Reactor Protection and Engineered Safeguards Logic Test" ( BwPT RP-12, Revision 0, " Turbine Runback-RPS"

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BwPT'SX-10, Revision 0, " Essential Service Water" No violations or deviations were identifie . Preoperational Test Procedures Verification The inspector reviewed the following preoperational test procedures 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 AP-52, Revision 0, " Unit 2 Aux. Power - 480 Volt Unit Substation Buses and Above" BwPT AP-53, Revision 0, " Unit 2 Aux. Power - 480 Volt MCCs Feeder Breakers and Below"

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BwPT AR-15, Revision 0, " Area Radiation Monitoring (Loop 5)"

BwPT EM-10, Revision 2, " Thermal Expansion - Primary Side (EM)"

BwPT FH-12, Revision 1, " Spent Fuel Pool Bridge Crane" BwPT RC-11, Revision 0, " Reactor Coolant" BwPT RC-13, Revision 0, " Reactor Vessel Water Level - HJTC" BwPT RC-17, Revision 1, " Reactor Coolant Loop Stop Valve Timing and Line Flow Verification Test (IHF)"

No violations or deviations were identified 5. Preoperational Test Performance The inspector witnessed the performance of portions of the below listed preoperational test procedure 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 BwPT EF-10, Revision 3, " Unit One Engineered Safety Features" No violations or deviations were identifie . 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 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 l

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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 CV-11, Revision 0, " Chemical and Volume Control System" BwPT CV-17, Revision 1, " Chemical and Volume Control System (IHF)"

BwPT DG-12, Revision 0, " Emergency Diesel Generator Test" BwPT IP-10, Revision 1, " Instrument and Control Power" BwPT MS-12, Revision 0, " Main Steam - PORV's" BwPT MS-17, Revision 1, " Main Steam (IHF)"

BwPT RC-10, Revision 1, " Integrated Hot Functional" BwPT RP-11, Revision 0, " Reactor Protection and Engineered Safeguards Logic Test" BwPT RP-12, Revision 0, " Turbine Runback - RPS" BwPT SX-10, Revision 0, " Essential Service Water" With respect to RP-12 and CV-11, the inspector had the following comment:

The procedures did not include post-test calibration of Measuring and Test Equipment (M&TE) as required. This deficiency was also noted in VD-10. The STEs have written deficiencies or checked the M&TE calibrations to ensure data recorded will not be affected. The concern of the M&TE program is being reviewed per open item (456/86027-01(DRS)). With respect to SX-10, the inspector had the following concerns:

(1) The test procedure requires verification of a minimum flow of 24,000 gpm per Essential Service Water (ESW) pum The actual flows recorded to satisfy equipment loads are in excess of 24,000 gp The inspector's concern is whether the ESW pump '

could experience a runout conditio (2) The FSAR requires an ESW pump to provide 24,000 gpm at 180 feet Total Developed Head (TOH). TCR #3 allows a tolerance of + 10%

on the 180 feet. The test results are less than the 180 feet, but within the 10% tolerance. The inspectors concern is that

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Project Engineering Department (PED) will be providing information on these two items.- This will be considered an open item (456/86043-01(DRS)) pending receipt of the information and review by the inspecto (3) Table 9.2-1 of the FSAR does not list the charging pump coolers as an ESW load. The licensee agrees to incorporate this item and it is being tracked by deficiency SX-10-51 No violations or deviations were identified. However, a portion of this area requires further review and evaluation and is considered to be an open ite . Preoperational Test Results Verification 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 AP-52, Revision 0, " Unit 2 Aux. Power - 480 Volt Unit Substation Buses and Above" BwPT AP-53, Revision 0, " Unit 2 Aux. Power - 480 Volt MCCs Feeder Breakers and Below" BwPT AR-15, Revision 0, " Area Radiation Monitoring (Loop 5)"

BwPT EM-10, Revision 2, " Thermal Expansion - Primary Side (EM)"

BwPT FH-12, Revision 1, " Spent Fuel Pool Bridge Crane" BwPT RC-11, Revision 0, " Reactor Coolant" BwPT RC-13, Revision 0, " Reactor Vessel Water Level - HJTC" BwPT RC-17, Revision 1, " Reactor Coolant Loop Stop Valve Timing and Line Flow Verification Test (IHF)"

EwPT VD-10, Revision 0, " Emergency Diesel Generator Room Ventilation" With respect to RC-17, the inspector has the following ccmment:

Startup practice for bypassing a step (s) that cannot be performed is to write a Test Change Request (TCR). In two instances the STE bypassed steps by writing a deficiency and then performing a functional test per the deficiency without writing a TCR to correct the procedure error. There were no effects on test results; however, to ensure an item of this nature (procedure problem) is evaluated for incorporation into Unit 2, a TCR should have been

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r issued. The licensee has committed to the inspector that the Unit 2

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procedure will be corrected and as such, the inspector has no further concern No violations or deviations were identifie . Startup Test Procedure Review The inspectors reviewed the below listed startup test procedures against the Final Safety Analysis Report (FSAR), Safety Evaluation Report, applicable Regulatory Guides'and Standards, and portions of.10 CFR 5 BwSU CV-30, Revision 1, " Degassing the Reactor Coolant System" BwSU EM-30A', Revision 0, " Pipe Vibration (Pre-Critical)"

BwSU FH-30, Revision 0, " Initial Core Load Sequence"

-BwSU FH-31, Revision 0, " Post Core Loading Precritical Test Sequence" BwSU FH-33, Revision 0, " Initial Core Loading" BwSU FW-31, Revision 1, " Calibration of Steam and Feedwater Flow" BwSU FW-32A, Revision 1, " Thermal Expansion - Feedwater (Precritical)"

BwSU FW-33A, Revision 0, " Main Feedwater (Performance Verification

.of Water Hammer Prevention System - Upper Nozzle (Pre-Critical)"

EwSU IT-32A, Revision 0, " Thermal Power Measurement and Statepoint Data Collection (Pre-Critical)"

BwSU NR-30A, Revision 0, " Core Loading Instrumentation (High Voltage / Discriminator / Neutron Check)"

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BwSU NR-308, Revision 0, " Core Loading Instrumentation (Neutron Check During Core Loading" l

l BwSU NR-33, Revision 0, " Reactivity Computer Checkout" l

ll BwSU NR-34A, Revision 0, " Operational Alignment of Excore Nuclear

! Instrumentation (Prior to Core Load)"

BwSU NR-348, Revision 0, " Operational Alignment of Excore Nuclear

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Instrumentation (During Core Load)"

BwSU PS-30, Revision 0, " Reactor Systems Chemical Sampling for Core

Load"

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BwSU PS-31, Revision 1, " Radiation Surveys Prior to Core Loading" BwSU PS-32, Revision 0, " Chemistry Criteria for Monitoring Water Quality During Startup & Power Ascension" BwSU RC-30, Revision 1, "RTD Bypass Loop Flow Verification" BwSU RC-31A, Revision 1, " Reactor Coolant System Flow Measurement (Hot Standby)"

BwSU RC-32, Revision 1, "RC Flow Coastdown" BwSU RC-33, Revision 0, " Reactor Coolant System Leak Test" BwSU VD-30, Revision 1, " Heat Capacity Verification for Diesel -

Generator Ventilation" The inspector had the following comments to the above procedures: Procedures NR-308, NR-348, and NR-34A have a caution to ensure the Boron Dilution Protection System (BDPS) is blocked in order to prevent a trip signa The inspector's concern is since there is no required sign-off (i.e. prerequisite), there is a possibility that blocking both channels of BDPS may be overlooke Secondly, two procedures do not verify that the BDPS has been reset at the completion of the tes Procedure NR-34A 6in steps 9.1.13 and 9.2.13 lists the expected count rates to be 1 to 10 cps as the range for setting the pulse amplifier attenuator, discriminator, and high voltage power supply for Source Range channels N31 and N32. Notes at the beginning of each section state that to obtain optimum settings the count rate should be at least 100 cps. The inspector's concern is if the count rate is not high enough, the Source Range channels may not be adequately se Procedure NR-34B has acceptance criteria for the Reliability Factor (RF) listed as 0.64 to 1.21 in section 4 and steps 9.5.11 and 9.6.11, while data sheets 11.5 and 11.6 list RF as 0.5 to 1.4. The licensee needs to clarify which is the correct rang Procedure RC-31A does not list all the test equipment numbers, calibration dates, and due dates for the special equipment used in the tes This is required by BwSUM, Section 3.3.7.2, to ensure equipment used to take acceptance criteria data is in calibratio Procedure PS-32 did not indicate with a 4 sign which steps in the procedure are acceptance criteria, nor does section 4 list the steps which verify acceptance criteria. This is required by BwSUM, Section 3.3.9. In addition, the procedure reviewed by the inspector was not yet PED approve . . Procedure RC-33 performs Bw0S 4.6.2.1.d-1 for determining identifiable and unidentifiable leakage from the reactor coolant system.. The Bw05 allows the SE/SCRE an option on the length of the test (two to four hours). In order to insure the best results, the length of the leak test should be as long as possible (not greater

.than the maximum time stated in Bw0S) and governed by the startup tes These items will be considered an open item (456/86043-02(DRS)) pending incorporation into their respective procedure No violations or deviations were identifie . _ Initial Startup Test Program The inspectors reviewed administrative controls related to the initial startup program against the requirements of the FSAR, SER, applicable Regulatory Guides and Standards, and portions of 10 CFR 50 in order to verify that appropriate controls were in place in the areas of test organization, administration, document control, test and measuring equipment and performanc The inspectors utilized the following documents in the review:

Braidwood Startup Manual BwSU FH-30, Rev. 0, " Initial Core Load Sequence" BwSU FH-31, Rev. O, " Post Core Loading Precritical Test Sequence" BwSU FH-32, Rev. O, " Initial Criticality and Low Power Test Sequence" BwSU TG-30 Rev. O, " Test Sequence at 30% Power" BwSU TG-31, Rev. O, " Test Sequence at 50% Power" BwSU TG-32, Rev. O, " Test Sequence at 75% Power" BwSU TG-33, Rev. O, " Test Sequence at 90% Power" BwSU TG-34, Rev. O, " Test Sequence at 100% Power" Chapter 14 of the FSAR identifies those tests that the licensee has committed to perform during initial startup testing. The licensee's sequencing procedures (listed above) provide the order in which these tests will be performe Although the inspector has not completed the review in this area, it appears that all the tests committed to in the FSAR are included in the sequencing procedure The inspector had the following comment concerning the sequencing in RC-32, "RCS Flow Coastdown," which lists RC-31A, " Reactor Coolant system Flow Measurement (Hot Standby)," as a prerequisite. The sequencing procedure FH-31 allows these tests to be performed in parallel. This appears to be in conflict and needs to be correcte This item will be included as part of open item (456/86043-02(DRS))

pending procedure chang I No violations or deviations were identifie !

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10. 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 6.b.(2), 8, and . Exit Interview The inspector met with licensee and contractor representatives denoted in Paragraph 1 during and at the conclusion of the inspection on September 12, 1986. -Tne inspector summarized the scope and results of the inspection and discussed the likely content of this inspection repor The licensee acknowledged the infonnation and did not indicate that any of the information disclosed during the inspection could be considered proprietary in natur