IR 05000456/1986052

Insp Repts 50-456/86-52 & 50-457/86-40 on 860915-1023. Violation Noted:Inadequate Corrective Action for Deficiency Re Lack of Documentation to Support Review of EF-11-12

ML20213F650
Person / Time
Site:	Braidwood
Issue date:	11/12/1986
From:	Azab B, Dunlop A, Dupont S, Farber M, Maura F, Ring M, Vandenburgh C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20213F639	List: IR 05000456/1986052 ML20213F638 ML20213F647
References
50-456-86-52, 50-457-86-40, NUDOCS 8611140367
Download: ML20213F650 (22)

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1 1 U.S. NUCLEAR REGULATORY COPNISSION

REGION III

Report No. 50-456/86052(DRS);50-457/86040(DRS)

Docket Nos. 50-456; 50-457 License Nos. NPF-59; 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: September 15 through October 23, 1986 Inspector: A. Dunlop, Jr. [ME fMy/ / / - 7 -/4 S. dup /hohd

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Date CLAN C-

" "I" C. VanDenburgh

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Date F. Maura 3/to [I WA M. Farber ///o/r4

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i B. Azab // //d /cf6

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Approved By: M. A. Ring, Chief 9 //[/d'[Ss Test Programs Section ) Date

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1140367 861112 g ADOCK 05000456 PDR

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i Inspection Summary Inspection on_S_eptember 15 throu 23, 1986 (R_ep~ ort N /86052jD,RS);_[0~-14)RY61f40(gh October

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Areas Inspected: Routine, announced safety inspection to review actions on previous iWpWtion iterns (92701, 92702); preoperational test implementation (70302); preo

70337, 70341)perational

preoperationaltest testprocedures procedure verification review-(70304, 70306, 70336, 70333, (70311);

preoperational test results evaluation (70320, 70322, 70325, 70326, 70533,

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70534,70536,70537,70539,70541,70554); preoperational test results verification (70329); startup test procedure review (72300, 72564B, 72566B, 725708); startup test program implerrentation (72400B); and failures of diesel generators to start. Reactive, announced safety inspection to review actions on the independent technical review of preoperational test Results: Of the ten areas ins

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inadequate corrective action (pected, Paragraphs one andviolation 6.c.(1)). was identified concerning

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DETAILS 1. Persons Contacted Conno nwea l th Ed i_s o n_C_ompa ny_( CECol

• J. Wallace, Project Manager

• E. E. Fitzpatrick, Station Manager B. R. Shelton, Project Engineering Manager L. O. DelGeorge, Assistant Vice President J. D. Deress, Project Engineering Department

• 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. Smith, Licensing (G.0.)

D. Paquette, Assistant Superintendent - Maintenance T. D. Weis, On-Site 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

• G. E. Groth, Project Construction Departrnent

• J. Giuftre, Mechanical Maintenance Departrrent

• J. Huffman, Mechanical Maintenance Department

• L. Raney, Nuclear Safety

• J. A. Zych, Site Quality Assurance

• K. L. Kofron, Production Superintendent

• J. P. Leider, On-Site Project Engineering Department D. Kapinis, Station Startup Test Supervisor M. Inserra, TRB Supervisor /PSG J. E. Boardman, On-Site Project Engineering Department L. Johnson-Hester, Quality Assurance M. Paul, Technical Staff P. Oreshak, On-Site Project Engineering Departnient

! E. Nagy, Group Leader

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G. Barugh, System Test Engineer J. Basek, System Test Engineer

! Nuclea r Regla_torylcmmis_si_o_n l S. A. Varga, Project Director, PWR Licensing, NRR l J. A. Stevens, Licensing Project Manager (LPM) - Braidwood l L. N. Olshan, LPM - Byron S. C. Rhow, NRR R. J. Giardina, NRR F. H. Burrows, NRR l

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. R. L. Perch, NRR J. B. Hickman, NRR Additional station technical, operational, and administrative personnel were contacted by the inspectors during the course of the inspectio * Denotes those attending the exit meeting on October 23, 1986.

, Action on Previous Inspection Items _

(Closed) Unresolved Item (456/85008-09(DRS))

This item concerned safety injection (SI) pump instruments (discharge pressure and flow)

being powered from the opposite electrical system (e.g. "A'.' train pump instruments powered by "B" train electrical system). The licensee's corrective action was to evaluate the specific instruments in question for Unit 1 and identify any other instruments in the same instrument and control cabinets. The licensee concluded that since the instruments performed no safety-related function (only indication or non-safety-related function), no modification to the design was required. Due to statements in the FSAR and SER about the complete independency of electrical trains, the inspector

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requested technical assistance from NRR to determine if the as-built condition of the instruments' electrical power supply was acceptabl i Since these are non-safety-related instruments and that they are powered from an uninterruptible power supply, NRR concluded the design would be acceptable as-is.

j However, the licensee's corrective action does not appear to fully evaluate the deficiency (EF-11-12). In the corrective action there was no mention of actions to determine if drawings, operating and emergency procedures, and operator training needed changes, or if the design meets the conmitments in the FSAR and SER for complete independence between trains, or if this design is applicable to the other unit The inspectors review in this area identified the following. The SI l Control and Instrumentation Diagram (C&ID, M-2061) and Residual Heat i

Removal (RHR) C&ID (M-2062) have the power supplies for the instruments j in question labeled incorrectly. Emergency procedures require the

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operator to verify SI flow on the instruments in question, although loss of the opposite train's power supply will render them inoperabl The inspector was unable to determine if the reactor operators were

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aware of this deviation from normal design in order to properly rely 4 on their indications or if the simulator is modeled appropriatel In addition, this design is applicable not only to Unit 2, but also to the two units at Byron. The inspectors' review entailed only a small portion of the instruments in question and not in detai .

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Due to the inadequate documentation that the above items were addressed in the corrective action, this item will be closed to a

violation (456/86052-01a(DRS)) for inadequate corrective action.

Further examples of inadequate corrective action are addressed in j paragraph 6.c.(1).

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. , (Closed) Open Item (456/83-17-03; 457/83-16-03): This item concerned

- inadequacies of BwPT DC-10, "125 VDC Distribution" in that the procedure did not call for monitoring and recording of each battery

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cell for voltage. specific gravity water level and temperature upon completion of an equalizing charge; hydrogen monitoring during equalizing charge; and periodically monitoring each cell during a substantial discharge. TCRs 22, 23, 24, 26, 27, 28, 29, and 31 were incorporated into DC-10 to resolve the above concerns. BwPT DC-50,

"125 VDC Distribution," for Unit 2 was written with these concerns incorporated. The inspector was concerned that the hydrogen monitor-ing was deleted out of DC-10 (TCR#51) after the equalizing charge had

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been in progress for 6-8 hours due to zero percent hydrogen readings

even though the charge lasted for approximately 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />. It does not appear that the System Test Engineer (STE) was aware that hydrogen is more likely to be released when charging a fully charged battery and his reasoning in deleting the requirement was incorrect. Project

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Engineering Department (PED) review of DC-10 also noted the same conclusion. DC-50, TCR#4 also deleted the requirement to document hydrogen readings; however, hydrogen monitoring was still required to

be performed. Based on the incorporation of the inspection concerns, this item is considered close ' (Closed) Open Item (456/83020-04)

Verify implementation of

administrative controls for equipment maintenance after completion

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of preoperational testing. The inspector verified that the following i procedures were approved:

BwAP 1205-11, " Maintenance Department System Turnover" PCD-14, " Equipment Preventive Maintenance Procedure" BwAP 400-18, " Equipment Preventative Maintenance Turnover Procedure" BwAP 400-5, " Station Housekeeping and Equipment Preservation" BwAP 370-1, " Station Lubrication Program" i

BwAP 400-4, " Control of Portable Measurement and Test Equipment" I The inspector verified implementation of the procedures by reviewing inspection and surveillance data sheets. The inspector has no further concerns and considers this item close (Closed) Unresolved Items (456/85008-07(DRS); 456/85027-03(DRP);

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457/85027-02(DRP)) and 10 CFR 50.55(e) Item (456/85006-EE; 4 457/85006-EE): These items concerned the inability of the diesel generators to start in ten seconds due to loss of prime in the fuel i oil system and the reportability of this deficiency in accordance with 10 CFR 50.55(e).

The licensee presumed the cause of the problem was that the check valves located in the discharge of the fuel oil pump were leaking by l

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and draining back to the day tank. The check valves were disassembled and found to have minor damage on the seats and were improperly installed. Another possible cause was the fact that the

day tanks are not elevated with respect to the fuel oil injectors 1 as required by the manufacturer's installation manual In order to correct the priming problem, the licensee instituted Field Change Request (FCR) L-20120 which replaced the hard seat check valve with a soft seat check valve and installed a loop seal with a continuous

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vent on the fuel oil line. The Unit I diesel generators have since been tested (ir.cluding the 35 consecutive starts of Reg Guide 1.108)

with no priming problems noted. The 1A diesel generator started in 8.0 seconds on March 29, 1986, after being left idle for 18 days. The 1B diesel generator started in 7.5 seconds on August 4, 1986, after being lef t idle for 81 days. Due to the ability of the diesel gener-

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ators to start and reach rated speed and voltage in less than ten seconds, it appears that the fuel oil priming problem has been solved.

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The Unit 2 diesel generators starting ability will be monitored during subsequent preoperational and surveillance testin The licensee reported the inability of the diesel generators to sustain

. an adequate prime as a potential 10 CFR 50.55(e) item on July 23, 198 At that time, the licensee had not been able to complete their invest-i igation or repair the deficient condition in order to determine if the deficiency met the requirements of 10 CFR 50.55(e). After the licensee

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determined the root cause of the problem and installed the modification discussed in the previous paragraph on both units' diesel generators, the licensee concluded that the deficient condition did not meet the requirements of 10 CFR 50.55(e). Specifically, the evaluation, redesign, and repair was not considered extensive as required by Section 50.55(e)(1)(iv) of 10 CFR.

The inspector concludes that the licensee has apparently corrected

! the diesel generator fuel oil priming deficiency and that this deficient condition does not meet the requirements of 10 CFR 50.55(e).

Testing of the Unit 2 diesel generators will be monitored during ,"

Unit 2 preoperational test program. These items are considered closed.

' (Closed) Violation (456/85026-02a,b,c): This violation involved problems identified during the review of preoperational test deficiencies. These problems included: (a) failure to initiate a test deficiency in a timely manner; (b) test deficiency description i did not adequately describe the deficient condition; and (c) test

, deficiency corrective action was inadequate to resolve the deficient condition.

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The inspector's monitoring of deficiencies have produced some further

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problems with respect to inadequate corrective action. These items are discussed in Sections 2.a and 6.c.(1) of this report. The response

to this Notice of Violation apreared adequate and was documented in Inspection Report 456/85049. As such, this item is considered closed.

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0 . (Closed) Open Item (456/85016-06(DRS)): This item concerned the

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review of the test results package for BwPT D0-12, Revision 1, " Unit One Diesel Fuel Oil Emergency Diesels (Safety-Related)." The licensee

has approved the test results and the inspector has reviewed the completed package with no additional comments. This item is considered close (Closed) Open Item (456/85026-04(DRS))

This item concerned the review of the test results package for BwPT SI-11 " Safety Injection Accumulators." The licensee has approved the test results and the inspector has reviewed the completed packag Inspector comments are included in Section 6.e. of this report. This item is considered closed.

! (Closed)OpenItem(456/85026-06(DRS)): This item concerned the i

review of the test results package for BwPT AP-13, " Aux. Power, 480V

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Unit Sut, station Buses and Above." The licensee has approved the test results along with Retest 22 and the inspector has completed his review of the test package with no further coments. This item is considered close . (Closed) Unresolved Item (456/85027-01(DRP)) and SER Item (456/860007):

Containment Sump Vortex Control . The licensee performed an analysis of containment sump geometry, as discussed in the proposed revision to Regulatory Guide 1.82, to justify the acceptability of sump performanc The inspector reviewed the analysis and checked the calculation to ensure its accuracy. No discrepancies were noted. The calculation showed that sump geometry was within the parameters demonstrated in NRC studies to be indicative of a properly designed sump which is Cdpable of performing its intended function. This issue is considered close (Closed) Open Item (456/85049-01(DRS)): This item concerned the test

' methodology of BwPT LD-10. " Leak Detection System," for determining sump alarm flow rates. The inspector has reviewed the test results package and has verified that the alarm flow rates were obtained in an acceptable manner. The inspector has no further concerns in this area and considers this item close (Closed)UnresolvedItem(456/85056-02): Documentation of 0AD training does not contain supportive evidence of training subject matter in sufficient detail to determine training adequacy. The

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inspector reviewed the revised Project 0AD training attendance sheet 4 and determined that the documentation of the subject topic and duration of training is sufficient to assess the detail of training and adequac In addition, the inspector reviewed the training matrixes developed to track training of individuals to the QA manual

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chapters, station administrative procedures and revisions, and 0AD procedures. The inspector also verified that a qualification matrix

! was developed to track personnel certification. the inspector found these improvements to be adequate. This item is considered close l

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4 (Closed) Unresolved Item (456/85056-03): CECO to determine and define the hierarchy of procedures utilized by Operational Analysis Department (OAD) to perform prescribed activities at Braidwood Station. Braidwood defined the CECO Quality Assurance Manual as the governing document with all other procedures as implementing proce-dures as follows: The Electrical Construction Test Procedures (ECTPs)

are used for construction and modification. Site-specific ECTPs having Braidwood site requirements in addition to the ECTPs are utilized only at the appropriate site by approval. The inspector also verified that training of hierarchy of procedures was given to 0AD personnel . The inspector has no further concerns and considers this item close (Closed)UnresolvedItem(456/85056-04): Project 0AD at Braidwood was not on controlled distribution for station administrative procedures. As of March 18, 1986, Project 0AD has received a

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controlled copy of the Braidwood Station Administrative Procedure The inspector verified that Project 0AD is currently on the controlled distribution for changes and updates of the station administrative procedures and that training of the procedures and changes are being conducted. The inspector has no further concerns and considers this item close (Closed) Unresolved Items (456/85056-05 and 456/85056-06): System 0AD will review the relay tolerance control and define the program

' for Braidwood Station relay calibration. The inspector reviewed the Relay Tolerance Covering List, Revision 1, dated April 28, 1986, and verified that the initial Technical Specifications relays are scheduled to be calibrated prior to fuel load by an approved Braidwood Station Procedure, BwHP 4009-003, " Periodic Relay Testing Procedure Southern Division OAD Braidwood Station." The inspector reviewed procedure BwHP 4009-003 and verified that the prescribed relay tolerances were in agreement with the System OAD Tolerance List. This item is considered close (Closed) Unresolved Item (456/86010-01(DRS)): This item concerned the performance of four consecutive cold starts of the diesel generator (DG) using a single air receiver. This item contained the following concerns: (1) the lowest pressure allowed in the air receivers that the licensee will consider the DG operable; and (2)

the initial starting condition of the DG during the test as required by the SER (9.5.6).

The first concern was resolved when the Operating Department stated that a DG will be declared inoperable when: (a) one train of starting air is out-of-service and the remaining train's air receiver falls below 240 psi; or (b) both air receiver's fall below 240 psi. From this determination, the inspector concluded that the starting air pressure used in testing a single air receiver (240 psi) for four

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starts is adequat The second concern was resolved by requesting NRR to provide technical assistance in interpreting the SER's requirenent for four cold start NRR stated that the DG should be at ambient conditions (lube oil and

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Jacket water temperature 120-130 F as determined by the licensee)

between each start. The results of BwPT DG-11 for the IB DG did not meet these conditions. The above temperatures for 'B' air receiver test in twowere cases notabove recorded 130 Fand thg (132 F )' A' air receiver's

. Nevertheless, temperatures it was were concluded by NRR and Region III that a single air receiver can provide sufficient pressure to perform four cold starts of a DG as follows: the IB DG was able to start five times, instead of the required four, the IB DG receivers air pressure were consistent with the 1A DG receivers air pressure during its testing, and the temperatures were not signifi-cantly greater than those that should have been required by the test procedure With the resolution of these two items, the inspector has no further concerns in this area and considers this item closed, p. (Closed) Unresolved Item (456/86010-0?): This item concerned valve 1AF-005E being not properly restored when returned to service from an out-of-service (00S) due to the instrument air being isolated to the valve. The valve was restored to service by only repositioning the valves on the 00S and not by a functional test. Project Startup held a training session on June 13, 1986, to review the circumstances surrounding the event and to re-emphasize the importance of ensuring equipnient and systems are properly restored after an 00S, In addition, BwAP 330-1, Revision 51, " Station Equipment Out-of-Service Procedure" was revised to give the Shift Engineer or designee the responsibility for ensuring that equipment is properly restored upon clearing an 00S. After systems are turned over to operations, Nuclear Work Requests (NWR) are required to perform any work on equipment. NWR's require testing when applicable. This item is considered close q. (Closed)OpenItem(456/86027-03(DRS)): This item concerned converting temperature values into resistance and voltage levels which were applied to the reactor protection logic (RP-10) to simulate temperature conditions. The inspector witnessed some minor confusion in converting the values and noticed that the conversions were not being recorded in the Significant Events Log (SEL) all the

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time. In order for a reviewer to verify that conversions were done correctly, they should be documented in the test. The licensee held a training session on August 15, 1986, with the test engineers to inform them of the need for more detail in the SEL. This will allow the reviewers (Test Review Board (TRB), PED, NRC) to better evaluate the test results package. In addition, the requirement for inde-pendent verification of computations in the test procedures was deleted from the Training Instructions. Computations are reviewed during the post-test review cycle. This item is considered closed, (Closed) Unresolved Item (456/86027-04(DRS)): This item concerned major Test Change Requests (TCRs) that did not have a Project Engineering Department (PED) signature as required by BwSUM. The inspector's concern was that major TCRs were nct getting PED .aview and approval. The TCRs in question resulted from PED concents that were required to be incorporated into the test procedure per PED's

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conditional approval. The System Test Engineer (STE) was using PED's concent letter as their approval signatur In most cases that the inspector reviewed of this nature, the STE incorporated PED's comments correctly. TCR #1 of LM-17 was not written verbatim to the PED comments; however, the difference was an additional change that could have been classified as a minor TCR, but incorporated into this TC During the test results review, PED is required to review and evaluate all TCR In addition, the inspector reviewed startup tests that were conditionally approved by PED that had cor.raents to be incorporate The station would incorporate the concents, review the changes, and send PED a letter as to how the concents were resolve The licensee's action to ensure major TCRs and conditionally approved startup test appear adequate to ensure PED concurrence. The inspector has no further concerns in this area and considers this item close s. (Closed) Open Item (456/86043-02(DRS)): This item concerned inspector comments to startup tests. These cor.ments have been resolved as follows:

(1) Test procedure open items have been written to ensure the blocking and restoration of the Baron Dilution Protection System (BDPS) for procedures NR-30B, NR-34A, NR-34B, NR-34C, NR-34D, and NR-34 (2) In NR-34A, the licensee's reason for stating that 100 cps is necessary to obtain the optimum settings on Source Range Channels N31 ar.d N32 is due to time considerations and not for obtaining adequate setting (i.e., a lower count rate will require a longer period to set the channels). The inspector has no further concerns in this are (3) The inconsistency in the Reliability Factor (RF) listed in NR-34B was being tracked by Test Procedure Open Item NR-348- Further evaluation by the licensee determined that the RF values listed were correct. The less restrictive numbers on the data sheet are used to determine if the detector needs to be replaced (outside 0.5 to 1.4 range) or is out-of-calibration (within expected values). The more restrictive acceptance criteria (0.64 to 1.21) is the range that the licensee requires to be obtained. The inspector has no further concerns in this are (4) Test Procedure Open Item RC-31A-2 will require the listing of serial numbers and calibration data for all test equipment used during the tes (5) Revision 1 to PS-32, which was approved by PED, Septerrber 9, 1986, indicates steps that obtain acceptance criteria are marked with E signs and Section 4 lists the steps which verify the acceptance criteria. The inspector has no further concerns l

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(6) Test Procedure Open Item RC-33-2 will require the System Test Engineer to establish a minimum time for the leak rate test-perfonned by Bw0S 4.6.2.1.d-1.

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j (7) Test Procedure Open Item FH-31-2 will modify the flow diagram in FH-31 to require RC-31A to be perfonned prior to RC-3 The licensee's corrective actions of writing Test Procedure Open Items appears adequate to correct the inspector's concerns. The inspector will verify proper incorporation when reviewing the test results. These items are considered closed, t. (0 pen) 10 CFR Part 21 Report (456/85004-PP): Failure of Parker-Hannafin air line check valves to seat on slow bleedoff of supply air. The inspector reviewed the licensee's response and verified that the air line check valves were replaced with stainless i steel ~ valves of improved design. These valves have not been tested

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at this time. The licensee has approved BwVS 800-8, Revision 0,

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" Main Steam Isolation Valve Instrument Air Check Valve Leakage

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Test," which will be performed semi-annually until the valves are

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proven to be reliable. The inspector has reviewed the surveillance and has concluded that it is adequate. Testing should be completed prior to initial criticality and as such, this item will remain open pending the inspectors review of the completed surveillance, u. (0 pen)OpenItem(456/85008-05(DRS)): This item concerned an apparent design deficiency in the diesel generator (DG) breake During the periodic testing of the DG with it paralleled to the bus, i a LOCA signal coincident with Loss-of-Offsite power, will cause the

DG breaker to trip in order to shed the loads on the bus, but will

! not automatically reclose on the undervoltage. This does not meet

, the intent of the FSAR and Regulatory Guide 1.108, position C.1. The licensee's position was that the design is adequate due to an operator stationed at the electrical panel in the main control room during testing and the DG procedure states what needs to be performed in case of this event. Discussions have been held between CECO, Region III, and NRR. The licensee has agreed to modify the DG breaker to conform to the requirements of the Regulatory Guid This item will remain open pending completion of the modification, j v. (0 pen)OpenIten(456/86027-02(DRS)): This item concerns the use of generic sensor response times (Westinghouse CVA-SU-2.7.1) in place

of actual sensor response timing. Confusion arose in this area as i to what the licensee is required or consnitted to do. The FSAR,

Section 7.1.2.19.a states sensors will only be type tested and

' Table 14.2-6 states testing will be performed from the sensor output.

! However, Regulatory Guide 1.68 requires verification of response time

of each sensor which is coninitted to in Appendix A of the FSAR without

, an exception in this area. In the bases for Technical Specifications, l Section 3/4.3.1 and 3/4.3.2, it states, " Sensor response time verifi-

! cation may be demonstrated by either: (1) in place, onsite, or offsite test measurements, or (2) utilizing replacement sensors with certified response times." Supplemental SER /!1 also concluded that the licensee's

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use of process noise measurements will provide an acceptable means to fulfill the requirements for response time testing as specified in the Technical Specification. However, this system will not be used until the plant is greater than 50% power. Due to these inconsis-tencies, Region III requested technical assistance from NRR to resolve the above concer *

With respect to the commitments in the FSAR and the requirements of

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Regulatory Guide 1.68, NRR concluded that it was an apparent oversight in that an exception was not noted to Regulatory Guide 1.68 to not include individual sensor response time testing in the FSAR. Since individual sensor response time testing was not performed for all sensors, Region III requested a NRR interpretation of Technical Specification statement- (2) above. NRR stated that " certified response times" in this case could be a manufacturer's specification response time for each model of sensor used and not individual response times for all sensors of a given model. With this inter-pretation, the licensee has met the Technical Specification requirements prior to performing the process noise measurements

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mentioned in the SSER #1.

i The inspector has been able to verify that the licensee has performed

the following on all sensors required to have a response time: (1)

actual testing has been performed; or (2) the manufacturer's speci-fication for time response is less than the generic times provided by Westinghouse which makes the response times used conservativ In addition, the licensee has conmitted per a n.emo, Fitzpatrick to Wallace, dated October 16, 1986, to perform BwVS 3.1.2-3, " Engineered

Safeguards / Reactor Protection Sercor Time Response," prior to exceeding the 75% power plateau during initial startup.

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The preoperational testing performed by the licensee for response 4 time testing is acceptable. Nevertheless, this item will remain open pending completion of BwVS 3.1.2-3.

I One Violation was identified in this area.

1 Preoperatjenal_ Te_s_t_ Program o 3_I plementation

This review consisted of a deter ination if administrative controls had been developed and implemented to support FSAR conmitments, and l regulatory requirement The inspector reviewed revision 16 to the Braidwood Startup Manual (BwSUM).

This revision completed the Byron /Braidwood procedure review effort for the BwSUM. The inspector concludes that the licensee has developed and implemented adequate administrative controls for preoperational testing.

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No violations or deviations were identifie . Preoperational Test Pro _cedure Review The inspector reviewed the following preoperational test procedures

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against the FSAR, Safety Evaluation Report (SER), proposed Technical

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Specifications and Regulatory Guides 1.68 and 1.108:

BwPT CV-10, Revision 0, " Chemical Volume Control, VCT, and Charging Pumps" BwPT DG-10, Revision 1, " Diesel Generator 1A" BwPT DG-11, Revision 0, " Diesel Generator 1B" BwPT MS-10, Revision 1, " Main Steam Isolation Valves (Safety-Related)"

BwPT RH-10, Retest 15, Revision 1, " Residual Heat Removal" BwPT-SI-13, Revision 0, " Safety Injection Check Valve Operability and Leakage Test" No violations or deviations were identifie . Preoperational Test Procedures Verification The inspector reviewed the following preoperational test procedures and verified that they were written, reviewed, and approved by licensee management in accordance with the requirements of Regulatory Guide 1.68 and the licensee's QA Manual:

BwPT AR-10, Revision 0, " Area Radiation Monitoring - RM11 and Miscellaneous AR Testing" BwPT AR-11, Revision 1, " Area Radiation Monitoring (Loop 1)"

BwPT AR-12, Revision 1, " Area Radiation Monitoring (Loop 2)"

BwPT AR-13, Revision 0, " Area Radiation Monitoring (Loop 3)"

BwPT EM-12, Revision 1, " Pipe Vibration" BwPT FH-13, Revision 1, " Spent Fuel Storage Racks, Failed fuel Racks, and New Fuel Vault" BwPT HC-10, Revision 1, " Reactor Polar Crane" BwPT HC-11, Revision 0, " Fuel Building Crane" BwPT LM-10, Revision 1, " Reactor Loose Parts Monitoring" BwPT PR-13, Revision 2, " Process Radiation Monitoring (Loop 3)"

BwPT PR-15, Revision 1, " Process Radiation Monitoring (Loop 5)"

BwPT PS-10, Revision 1, " Process Sampling Primary" BwPT VP-12, Revision 2, " Containment Ventilation"

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BwPT VX-10, Revision 1, "Switchgear Heat Removal" No violations or deviations were identified 6. _ Pre _ opera _tional__T_e_s_t Resul ts 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 personne BwPT AP-13, Revision 0, " Aux. Power, 480V Unit Substations Buses &

Above" BwPT AP-16, Revision 1, " Bus Loading and Independency" BwPT CC-10, Revision 1, " Component Cooling" BwPT CS-10, Retest 02, Revision 1, " Containment Spray" BwPT CV-10, Revision 0, " Chemical Volune Control, VCT, and Charging Pumps" BwPT DG-10, Revision 1, " Diesel Generator IA" BwPT DG-11, Revision 0, " Diesel Generator 1B" BwPT EF-11, Revision 20, "ECCS Full Flow" BwPT MS-10, Revision 1, " Main Steam Isolation Valves (Safety-Related)"

BwPT NR-10, Revision 0, " Neutron Monitoring - Excores" BwPT RH-10, Retest 15, Revision 1, " Residual Heat Removal" BwPT RP-10, Revision 0, " Reactor Protection Time Response" BwPT RP-13, Revision 0, " Reactor Protection Logic Checks" BwPT SI-11, Revision 1, " Safety Injection Accumulators" BwPT SI-12, Retest 90, Revision 0, " Safety Injection" BwPT S1-13, Revision 0, " Safety Injection Check Valve Operability and Leakage Test" The inspector has not completed the review of the SI-12 test results package and this review will be documented in a subsequent repor . .

a. With respect to AP-16, the inspector had the following comment:

. Acceptance criteria 4.2 required the bus to be loaded to greater or equal to 30% of the startup load. This requirement is also stated in Table 14.2-11 and response to NRC Question 40.176-4 of the FSAR. The STE was unable to obtain this load, so a TCR was incorporated to reduce the load required. This change should have initiated a FSAR amendment to change the licensee commitment. This is considered an open item (456/86052-02(DRS)) pending a FSAR amendment, b. With respect to CS-10, retest 02, the inspector had the following connent:

. The methodology used in the test to verify that the containment spray nozzles are not obstructed was not the same as the licensee's commitment in Table 14.2-18 of the FSAR. This is considered an open item (456/86052-03(DRS)) pending approval of a FSAR amendmen c. With respect to EF-11, the inspectors had the following comments:

(1) Test deficiencies EF-11-K and EF-11-AI were incorrectly close The deficient condition was that the measured flow of 3663 GPM for containment spray (CS) pump 1B was below the expected value of 3795 GPM (acceptance criteria for deficiency EF-11-K). The corrective action was to add the educator flow to the measured flow to obtain the expected value. This was an incorrect assumption as the FSAR, Section 6.5.2.2, states that the IB CS pun'p flow will be 15 gpm per nozzle. Since there are 253 nozzles, the flow to the nozzles is 3795 gpm plus an educator flow of 130 gpm for a total flow of 3925 gpm. This is considered a further example of a violation (456/86052-Olb(DRS)) for inade-quate corrective actio (2) The inspectors requested the licensee to re-review the results of the test to ensure that CS pump degradation has not occurred due to the fact that the Total Developed Head (TDH) of the pump when taking a suction from the containment sump was different than the TDH when suction was taken from the Refueling Water Storage Tank (RWST). This is considered an open item (456/86052-04(DRS)) pending further information from the license (3) Test Deficiencies EF-11-P and EF-11-Q were written due to procedure errors. The BwSUM requires a TCR to be written to correct all procedure errors, but no TCRs were written in these cases. EF-11-P was written due to incorrect expected range of the auto-switchover from the RWST to the containment sum The value obtained during the test was not within the expected range in the test but was within the range that the test should have been changed to. EF-11-Q was written due to two valves that did not automatically close upon low-low level in the RWST. The procedure was in error as an ESF signal needed to be also

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present to cause the valve actuation. The STE per Significant Events Log (SEL) entry re-initiated an ESF signal and the valves closed as require Although, in both cases, TCRs should have been written, the actions taken to correct the deficient conditions were adequat Since the setpoint for the switchover was already obtained, the step required to have the expected range corrected per a TCR would not have been re-performed. Due to the action necessary to correct EF-11-Q, the STE needed to act quickly to prevent the RWST level from decreasing to a level which would cavitate the pumps in operation. Both TCRs would have been after the fact and did not have an outcome on the results of the test. Project Startup held a training session on October 17, 1986, to discuss these events and proper uses of deficiencies and TCRs. The inspector has no further concerns in this are d. With respect to NR-10, the inspector had the following consent:

. Deficiency NR-10-175 was initiated due to a problem obtained in testing the Upper and Lower Deviation Channels. The licensee requested and received technical assistance from Westinghouse, but has yet to perform any corrective action. This item is now being tracked by Construction Work Request (CWR) NR-10-0 This item will be considered an open item (456/86052-05(DRS))

pending adequate corrective action to the CW e. With respect to SI-11, the inspector had the following comn.ent:

. Five test deficiencies (SI-11-B, D, G, H, K) were not adequately closed out. PED's review of the procedure also addressed this concern. PED accepted the deficient condition of two deficiencies as-is, but requested additional action on the remaining three (SI-11-G,H,K). No action was taken by the STE. Quality Assurance (QA) reviewed the completed test results package (Surveillance No. 20-86-51-11-1), and also addressed the inade-quate response to the PED connents on the three deficiencie Project Startup's response to the QA findings stated that the instruments in question were recalibrated since the con.pletion of the test and that the instrument level taps and transmitters have been resurveyed to obtain more accurate location The inadequate closure of these deficiencies would have been a violation except that this test was completed prior to the corrective action of violation 456/86026-02C being implemente A violation in this area is addressed in paragraphs 2.a and 6.c.(1).

f. With respect to SI-13, the inspector had the following consents:

. Action Item Request (AIR) R20-86-008 lists ten check valves that did not pass their leak rate tests. The valves were reworked and are scheduled to be tested per BwVS 4.6.2.2-1,

" Reactor Coolant System Pressure Isolation Valve Leakage

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Surveillance." This will be considered an open item (456/86052-06(DRS)) pending completion of the surveillance and review by the inspecto The inspector had a generic concern with the test results packages in how TCRs, deficiencies, typos, and SEL entries were handled. The following is a list of examples upon which the inspector's concern is based. Further examples are listed in Section 7 along with the licensee's corrective actio (1) SI-13 incorporated TCR #16 which changed the order of certain steps. The TCR is referenced in the procedure at the applicable steps, but the steps are not reordered. Three TCRs were written on the same step (9.2.2) to change valve positions back and fort (2) EF-11 TCR deleted recording M&TE infonnation as a prerequisite, but stated to record in SEL. No SEL entries were made (information was found on strip chart recordings.) Independent verifications deleted as typo, signed by same person or marked N (3) DG-11 TCR changed valve numbers but TCR did not state what to change the valve number to, only to see change in the tes (4) Deficiency forms do not appear to be filled out correct in all cases. For exaaple, although followup corrective action was taken(retestedinprocedure,functionallytested),thetesting block was checked for None. The STEs should be more complete in their description, corrective action and followup action to ensure the deficient condition is properly resolve All the specific examples stated above have been properly addressed by the licensee. Corrective action taken to resolve the generic concern is listed in Section One violation was identified. Other portions of this area require further review and evaluation and are considered to be open item . Pyppppy_a_t i o n a l__Te_s_t_ R e_s_u l_t s_ Ve r i f i c a t i o n The inspectors reviewed the following preoperational 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 Startup Manual:

BwPT AR-10, Revision 0, " Area Radiation Monitoring - RM11 and Miscellanecus AR Testing" BwPT AR-11, Revision 1, " Area Radiation Monitoring (Loop 1)"

DwPT AR-12, Revision 1, " Area Radiation Monitoring (Loop 2)"

BwPT AR-13, Revision 0, " Area Radiation Monitoring (Loop 3)"

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BwPT 00-12, Revision 1, " Unit One Diesel Fuel Oil Emergency Diesels (Safety-Related)"

! BwPT EM-12, Revision 1, " Pipe Vibration" BwPT FW-10, Revision 2, " Main Feedwater Safety-Related" l BwPT FH-13, Revision 1, " Spent Fuel Storage Racks, Failed fuel Racks, and New Fuel Vault" BwPT HC-10, Revision 1, " Reactor Polar Crane" i BwPT HC-11, Revision 0, " Fuel Building Crane" BwPT LD-10, Revision 1, " Leak Detection System" BwPT LM-10, Revision 1, " Reactor Loose Parts Monitoring" DwPT PR-12, Revision 2, " Process Radiation Monitoring (Loop 2)"

BwPT PR-13, Revision 2, " Process Radiation Monitoring (Loop 3)"

BwPT PR-15, Revision 1, " Process Radiation Monitoring (Loop 5)"

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BwPT PS-10, Revision 1, " Process Sampling Primary" BwPT VP-12, Revision 2, " Containment Ventilation" BwPT VX-10, Revision 1, "Switchgear Heat Removal" During the review of these test results, the inspector noticed several ,

instances where the use of TCRs, deficiencies, typos, and the SEL need to be improved. TRB in some cases had similar concern Scrre examples are as follows:

I AR-11 had two typos that should have been TCRs. Data required to be recorded by a step was not (recorded in different step, should have been a TCR). Line throughs not marked as typos. Infonnation in SEL not complet EM-12 had TCRs incorporated into the test, but steps were not indicated as to which TCR was applicable. A typo that should have been a TCR. TCRs were not specific enough as to what steps they applied t No deficiency was written for a flow outside of its expected rang PR-15 had TCRs incorporated into the test, but steps were not indicated as to which TCR was applicable. Deficiencies were not annotated in the test to the applicable steps. Deficiency not written for valve outside of expected rang Appendix C (verify operating procedures) for VX-10 was not performed and no deficiency writte . .

The concerns listed above and those addressed in Section 6 are just some examples of problems that have been identified with the proper use and documentation of TCRs, deficiencies, typos and SEL entries. The specific concerns have been appropriately addressed and corrected. Project Startup held a training session on October 17, 1986 to discuss all the concerns identified. With the conclusion of Unit 1 preoperational testing, the inspector will continue reviewing this area with respect to the Unit 2 l preoperaticnal test program. In addition, the inspector requested that the Technical Staff be made aware of these concerns, such that the startup test program will not have similar problem No violations or deviations were identifie . S_ta_rtup Test Pr_ocedure 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 FH-32, Revision 0, " Initial Criticality and Low Power To t Sequence" BwSU NR-31, Revision 0, " Initial Criticality" BwSU RP-30, Revision 1, " Reactor Protection Logic" BwSU RY-30, Revision 0, " Pressurizer Sprays, Heaters and Bypass Flow Adjustments" With respect to RP-30, the inspector had the following coments:

(1) Prerequisite 6.3.1 did not have a signoff bloc (2) The alarm window listed in step 7.2.2 appears incorrec (3) Precaution 8.4 removes power from SI Accumulator Discharge valves unless they were already open. The procedure does not verify that power was restored to the valves if require (4) Sections 9.5 and 9.11 have eight steps each that require voltages to be checked, but no voltage is recorde (5) Data sheet 11.9 (sheet 10 cf 14) lists the Logic for the UV Diodes and Output as 1/3 when it appears this should be 1/4 The licensee is addressing these issues by Test Procedure Open Items to determine if the procedure needs to be updated. The inspector will review the corrective action to these open items during the results review, With respect to FH-32, the inspector had the following coment:

The title listed for LM-30 in steps 5.2.16 and 9.1.4 is incorrec A Test Procedure Open Item has been issued to correct the titl I

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Although most of the cour.ents the inspector has had on the startup test procedures have been minor in nature, the inspector is concerned that the review process may not be reviewing the test procedures in sufficient detail. The inspector will continue to evaluate the review process during subsequent test procedure review No violations or deviations were identifie . Initial Star _ tup 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 licensee has approved all the startup tests required to fulfill the FSAR, Chapter 14, commitment. The inspector will review individual tests for compliance during procedure reviews. The inspector has also reviewed revision 17 to the BwSUM to ensure proper administrative controls are in place for the startup program. The inspector has no concerns at this tirre and will verify proper implementation during the startup progra No violations or deviations were identifie . r _of_the_Diese_1 Genera Failures e _t_ ors _ to Start Since the completion of the diesel generator (DG) preoperational tests, there have been several failures associated with the DGs. All of the failures occurred following traintenance. A description of the failures is as follows: The IA DG failed to start when the starting air regulator was found set too low. It could not be determined if someone had readjusted the regulator or vibration had caused the setting to change. The regulator was readjusted and the lock nut tightened to prevent an inadvertent regulator adjustn'ent. The DG was then successfully sta rted, The IA DG failed to start due to a connecting rod high temperature alarm. It was determined that during maintenance, an explosive cover was dropped on one of the temperature trip levers which changed its setpoint. The trip lever was readjusted and the DG was successfully starte The IB DG failure came after maintenance was performed on the fuel oil lines. The STE was requested to assist the Technical Staff in determining the cause of the failure. First an orifice on the continuous vent line was found blocked, possibly due to bypassing the fuel oil filters when priming the DG. Secondly, the manner in which the DG was prined did not renove all the air from the fuel oil injector lines. After the orifice was cleaned and the DG primed correctly, a successful start was obtaine . .. p Licensee action to prevent reoccurrence of this problem was to revise maintenance procedure MP 3100-022, " Diesel Generator Annual Inspection," to include the proper priming sequence for the D The inspector also reviewed Bw0P DG-11T1, " Diesel Generator Start /Stop

, Log." In some cases it did not appear that the log was being filled out correctly as different pieces of information were missing (e.g. dates, time, reason for failure, valid start or failure). The inspector addressed this concern with the licensee to ensure that the log contains all the required informatio It appears that the failures of the DGs should be considered valid. The licensee is reviewing this issue to determine if the DG surveillance requirements are affected. The inspector addressed this concern to the Senior Resident Inspector for followu No violations or deviations were identifie . I,ndependent Technical Review of Preoperational Tests Due to a concern raised by the NRC on October 8, 1986, concerning the adequacy of the engineering evaluation associated with certain

, preoperational tests at Braidwood, the licensee initiated a review of

! a sample of those tests to re-confinn the integrity of the original engineering evaluation. The review was performed by Westinghouse testing personnel who were not involved in the original review of the tests used in the sample. The review was monitored by the CECO Manager of Nuclear Safet The review was to assure that discrepancies, if any, between accepted test results and the applicable acceptance criteria in the test were identified. In addition, the review compared the acceptance criteria in the test with the FSAR test abstract for inconsistencie The licensee reviewed 10 out of the 28 tests that were in questio These tests are as follows:

BwPT AF-10, Retest 75, " Auxiliary Feedwater"

1. BwPT AP-16, " Bus Loading and Independency"

1. BwPT AR-11. " Area Radiation Monitoring (Loop 1)"

1. BwPT CS-10, " Containment Spray"

1. BwPT EF-11. "ECCS Full Flow" BwPT FC-10 and Retest 37, " Fuel Pool Cooling and Cleanup" BwPT RC-11, Retest 78, " Reactor Coolant" eBwPT RH-10 " Residual Heat Removal"

1. BwPT SI-11. " Safety Injection Accumulators"

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1. BwPT SX-10, " Essential Service Water" The inspectors resiewed a sample of these tests (as noted by a #) to determine the adequacy of the independent review. Specific comments to the_ procedures are addressed in Section No violations or deviations were identifie . Open Items  ;

Open iteas are matters which have been discussed with the licensee, which will be reviewed by the inspector and which involve son.e action on the part of the NRC or licensee or both. Open items disclosed during the inspection are discussed in Paragraph 6.a. 6.b. 6.c.(2), 6.d., and .

1 Exit Int _erview

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The inspector met with licensee and contractor representatives denoted in Paragraph I during and at the conclusion of the inspection on October 23, 1986. The inspector sumarized 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 informa-tion disclosed during the inspection could be considered proprietary in natur ,

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