IR 05000456/1987016

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Insp Repts 50-456/87-16 & 50-457/87-16 on 870421-0604.No Violation or Deviation Noted.Major Areas Inspected: Preoperational Test Performance & Review,Initial Startup Test Program & Procedure Review & Startup Test Performance
ML20235G323
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 07/10/1987
From: Dunlop A, Vanderburgh C, Wright G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20235G293 List:
References
50-456-87-16, 50-457-87-16, IEB-80-06, IEB-80-6, NUDOCS 8707140203
Download: ML20235G323 (9)


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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-456/87016(DRS); 50-457/87016(DRS)

Docket Nos. 50-456; 50-457 Licenses No. NPF-70; 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:

April 21 through June 4, 1987

[O Inspector:

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Approved By:

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Test Programs Section Date

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Inspection Summary Inspection on April 21 through June 4, 1987 (Reports No. 50-456/87016(DRS);

No. 50-457/87016(DRS))

l Areas Inspected:

Routine, unannounced safety inspection to review actions on i

previous inspection items (92701, 92703); preoperational test performance (70315, 70316, 70441, 70312, 70439, 70434); preoperational test results review (70320, 70538); init.ial startup test progragi (72400); startup test procedure reviews,(72564, 72572, 72578, 72583, 72300); startup test performance (72592);

startup test resultt review (72596, 72301); startup test results verification j

(72596, 72301); and review of allegations (99014).

I Results:

Of the nine areas inspected, no violations or deviations were identified in the report.

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DETAILS

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1.

Persons' Contacted Commonwealth Edison Company (CECO)

  • P. L. Barnes, Regulatory Assurance Supervisor
  • T. W. Simpkin,. Regulatory Assurance

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  • T. J. Lewis, Startup Staff, NOVA q
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Inserra,-TP.B Supervisor /PSG

  • M. Takaki, Regulatory Assurance

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B.: Poirrer, Project Startup Test Supervisor

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  • B. Palowitch, Technical Staff.

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'*G.. Masters, U-2 Operating Engineer Addit'ional station technical, operational, and administrative personnel were contacted by the inspector during the course of.the inspection.

2.

Action on Previous Inspection Items

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a.

(Closed) IE Bulletin 80-06:

This item concerned Engineered Safety Feature (ESF) Reset Controls.

The inspector reviewed the remaining Test Procedure, BwPT EF-10, Retest 113, " Unit One Engineered Safety Features," and concluded the licensee has met the intent of the

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This item is considered closed.

b.

(Closed) Open Item (457/86050-01(DRS)):

This item was to ensure that Test Procedure Open Items EF-50-005, 006 007, 008, and 009 were incorporated into the Unit 2 preoperational test.

With the exception of Test Procedure Open Item No. EF-50-007, all items were properly incorporated into BwPT EF-50.

EF-50-007 required the addition of independent verification signoffs for the repositioning of perraanently installed jumpers.

These signoffs were not added, although the Test Procedure Open Item was signed off as being complete.

The inspector was informed that when the procedure was revised, the TCR, written to incorporate these changes, was not included in the revision.

The licensee has initiated Test Change

-# Request No. 17 to include the required independent verification signoffs.

This item is considered closed, c.

(Closed) Open Item (457/86050-02(DRS)):

This item was to ensure l

that Test Procedure Open Item No. EF-51-001 was incorporated into I.

the Unit 2 preoperational test to add acceptance criteria for the containment spray pumps during the injection phase.

The licensee added Acceptance Criteria 4.13 to BwPT EF-51 to resolve the issue.

This item is considered closed.

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(Closed) Open Item (457/86050-03(DRS)): This item was to ensure that Test Procedure Open Item No. VP-50-001 was incorporated in the Unit 2 preoperational test to correct the starting time of the Reactor Containment ran Coolers.

The licensee changed the start time to less than 30 seconds to resolve the issue.

This item is considered closed, e.

(Closed) Open Item (457/86050-04(DRS)):

This item was to ensure that Test Procedure Open Item No. VQ-50-002 was incorporated into

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the Unit 2 preoperational test to correct the hydrogen recombiners rcaction chambers gas temperature.

However, both hydrogen recombiners were. tested in the Unit 1 test, and as such, is not applicable to Unit 2.

This item is considered closed.

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(Closed) Violation (456/86052-01(DRS)):

This violation concerned inadequate corrective action to deficiencies.

The licensee has taken the following actions:

(1) training of System Test Ergineers

to accurately document corrective action; (2) training to increase the Test Review Boards sensitivity to deficiency completeness; (3)

instituted a second independent review of tests by Project Engineering.

The inspector will continue monitoring deficiencies when reviewing Unit 2 preoperational test results.

This item is considered closed.

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(Closed) Unresolved Item (456/86060-01(DRS)):

This item concerned the IB Containment Spray (CS) pump not meeting it's acceptance criteria of 3795 gpm during the injection phase.

Although the corrective action listed was incorrect, the pump was operating near it's pump curve.

If the temporary discharge valve had been opened

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further during the test, the proper flow rate would have been obtained.

The low flow rate was obtained from converting percent inches of water to gallons per minute.

This conversion was not performed until after the test was completed.

During the test, the System Test Engineer based that the CS flow was greater than 3795 gpm by a flow meter in the control room.

A small error in calibration or reading of the meter could easily have caused the flos discrepancy.

For the Ur;:i 2 test, the licensee will ensure that the flows obtained are in aeir expected ranges during the test.

This item is considered closed.

3.

,Preoperational Test performance

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The inspector witnessed the perfonnance of portions of the below listed preoperational test procedures in order to verify that testing was conducted in accordance with approved procedures independently varified the acceptability of test results, and evaluated the performance of licensee personnel conducting the tests.

BwPT CC-50, Revision 0, " Component Cooling" BwPT DG-50, Revision 0, "Diese'l Generator 2A"

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BwPT DG-51, Revision 0, " Diesel Generator 28" BwPT EF-50, Revision 1, " Unit 2 Engineered Safety Features"

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BwPT'EF-51, Revision 0, "ECCS Full Flow" BwPT SI-50,. Revision 0, " Safety Injection" BwPT SI-52, Revision 0, " Safety: Injection" a.

During the performance of the diesel generator (DG) tests, the 2A DG experienced severe voltage fluctuations.

The operator reduced the load and tripped.the DG output breaker so that the 2A DG could be secured.

Deficiency 0 was written which determined the' problem to be a defective relay in the engine governor controls which caused the governor to switch between droop and isochronous modes of

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The relay was replaced'and the DG tested satisfactory.

The' inspector also witnessed two operator errors.during die.sel generator testing.

In the first case, the operator, when attempting to close the DG output breaker, operated the wrong breaker switch (switch already'in the close position).

In the second case, the operator, when preparing to close.the DG output breaker, turned on the synchroscope for a different breaker.

In both cases, the errors

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were corrected prior to continuing the test.

Although these errors

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seem to be isolated occurrences, errors of this' nature could cause

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problems on an operating unit, which should be identified to the operators, b.

During the performance of BwPT CC-50, a TCR had to be incorporated during the Surge Tank Level Alarm test'to change the surge tank drain valve numbers.

The surge tank is divided into two sections, with separate level indications end drain valves.

The drain valves were reversed for the level alarms to be tested.

This was the same problem on'the Unit 1 test, which also required a TCR to correct the procedure.' The licensee's review of BwPT CC-50 should have found this error.-

The inspector reminded the licensee the need to review all the sources available TCRs, SELs, and deficiencies for Unit 1 tests, when preparing Unit 2 procedures to ensure a adequate procec'ures.

No violations or deviations were identified.

4.

Preoperational Test Procedure Review The inspector reviewed the following preoperational test procedure against the FSAR, Safety Evaluation Report (SER), Technical

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Specifications, and Regulatory Guide 1.68:

BwPT 00-51, Revision 0, " Diesel Fuel Oil - Aux. Feedwater Pump Fuel Oil Supply"

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BwPT 00 '2, Revision 0 and 1, " Unit One Diesel Fuel Oil-Emergency Diesels" The inspector reviewed a concern about the adequacy of the Unit One diesel fuel oil system by reviewing the three performances of BwPT D0-12.

The inspector has concluded that the performance of latest test, BwPT-00-12, Revision 1, was adequate to show that there are no safety concerns with the diesel fuel oil system.

This coupled with the reviews of other diesel generator testing, documented in the following reports, is sufficient to conclude that the diesel generators are acceptable:

Inspection Reports No. 456/83017; No. 456/84009; No. 456/84033; No. 456/84039; No. 456/84041; No. 456/85004; No. 456/85008; No. 456/85011; No. 456/85017; No. 456/86043; No. 456/86052.

No violations or deviations were identified.

5.

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 performance.

The licensee requested relief from the 60 day requirement to supply Unit 2 startup tests to the NRC prior to fuel load date as required by Regulatory Guide 1.68, Appendix B.

The reason behind this request is the proximity of the Unit 1 and Unit 2 startups.

Unit 1 tests may not have been performed or reviewed prior to the Unit 2 fuel load date.

The licensee uses the Unit 1 completed procedures in preparing Unit 2 procedures.

At this time, the licensee intends to meet the 60 day requirement.

The inspector informed the licensee to formally request the deviation from the FSAR commitment.

The inspector does not have a concern with this issue and recommends the following:

60 days prior to fuel load date, the licensee will provide the NRC with all the startup procedures required to be used through low power testing (5%).

60 days prior to issuance of a full power license, the licensee will provide the NRC with the remaining startup procedures.

No violations or deviations were identified.

6.

Startup Test Procedure Review The inspectors reviewed the below listed startup test procedures against the Final Safety Analysis Report (FSAR), Safety Evaluation Report, Technical Specifications, applicable Regulatory Guides and Standards, and portions of 10 CFR 50:

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BwSU IC-31, Revision 0, "Incore Flux Mapping at Low Power"

.BwSU IC-32C, Revision 0, "Incore Moveable Detector and Thermocouple Mapping at Power (Quarter Core)

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BwSU RC-35, Revision 0, " Shutdown from Outs.ide the Control Room" BwSU RD-33, Revision 0, " Rod Drop Timing" BwSU RD-34A, Revision 0, "Bankworth Measurement at Zero Power" BwSU RD-348, Revision 0, "Bankworth with Overlap Measurement at Zero Power" No violations or deviations were identified.

7.

Startup Test Results Evaluation The inspectors reviewed the results of the below listed startup 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;

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test results were evaluated by appropriate engineering personnel and specifically compared with acceptance criteria; data was properly recorded, signed, dated and documented as test deficiencies if out of tolerance, and test results were approved by appropriate personnel:

BwSU NR-348, Revision 0, " Operational Alignment of Excore Nuclear Instrumentation" BwSU NR-34A, Revision 0, " Operational Alignment of Excore Nuclear Instrumentation (Prior to Core Load)"

BwSU FH-33, Revision 0, " Initial Core Loading" BwSU FH-30, Revision 0, " Initial Core Load Sequency" BwSU FH-31, Revision 0, " Post Core Loading Precritical Test Sequence" The inspector has not completed the review of FH-31 and FH-30 at this time.

This review will be documented in a subsequent report.

The inspector had a general concern with the lack of information in the Sequence of Events Log (SEL).

This concern was also addressed in several Test Review Board (TRB) reviews.

To correct this concern, the licensee has given training to the System Test Engineers (STEs) on the subject.

In addition, they have restructured their startup organization so that

the TRB, System Test Directors, and STEs are all a part of the Technical Staff. This, along with the comprehensive reviews performed by TRB and PED, should ensure that the procedure results are adequately reviewed.

No violations or deviations were identified.

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Startup Test Results Verification The inspectors reviewed the following startup 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:

BwSU PS-31, Revision 1, " Radiation Surveys Prior to Core Loading" BwSU VD-30, Revision 1, Heat Capacity Verification for Diesel

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Generator Ventilation" No violations or deviations were identified.

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Startup Test Witnessing The inspector witnessed the below listed startup test procedures to verify the test was conducted in accordance with an approved procedure; all test equipment was properly installed; test data was collected and recorded properly; of personnel conducting the test were knowledgeable of the testing being performed; deficiencies and test problems were documented and that test changes were processed in an approved manner:

BwSU FH-32, Revision 0, " Initial Criticality & Low Power Test Sequence" BwSU NR-31, Revision 0, " Initial Criticality" The inspector reviewed a portion of the procedure's prerequisites for initial criticality.

No discrepancies were noted.

No violations or deviations were identified.

10.

Allegations a.

Allegation Safety Injection Puop Run Out.

A question was raised regarding the adequacy of the safety injection pump run out protection orifices.

NRC Review This item was previously identified and was being tracked by the NRC as Unresolved Item No. 456/85057-01.

The licensee wrote BwPT SI-12, i

Component Demo 89 to perform the required testing and approved the

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tests results on July 22, 1986.

NRC contractors from Idaho National Engineering Laboratory (INEL) closed the item in Inspection Report No. 456/86039 after reviewing the test.

The' inspector also reviewed the test and agreed that the item was resolved.

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Conclusion The concern as described by the individual was not substantiated.

The licensee performed the required testing which was reviewed by the' inspector to resolve the issue.

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Allegation AF-10 There appears to be an internal CECO dispute concerning the auxiliary feedwater preoperational test BwPT AF-10. A Notice of Violation related to this test, and based on the same concern was issued by the NRC in Inspection Report No. 456/85026.

It is unclear whether all safety concerns associated with this test were appropriately addressed and resolved.

NRC Review A review of internal CECO letters between the projects Engineering

Department and the startup group revealed a difference of opinion as to what information was required to be acceptance criteria in test BWPT AF-10.

This issue was first addressed by the NRC in Inspection Report No. 456/85016 and was designated as ' Unresolved Item No. 456/85016-01.

, Subsequent review of the item, documented in Inspection Report 456/85026, resulted in the item being upgraded to a violation.

The licensee's corrective action to Violation No. 456/85026-01 was to issue a Test Change Request, however, other p'.oblems resulted in

numerous changes and revisions to the procedur0, each time changing

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the acceptance criteria. The final version sf BWPT AF-10 was review and it was verified that all required data was recorded and that the acceptance criteria was appropriate and complied with.

(Reference Report No. 456/86043)

The licensee performed an independent review of the issue and reached the same conclusion as the inspector.

Conclusion This concern was substantiated in that CECO personnel did have an internal difference of opinion; however, the final actions taken by the licensee were to include all the required infonnation in the test procedures acceptance criteria and satisfactorily completed the test. As such, there is no further concerns about the adequacy of the testing in this area.

No violations or deviations were identified.

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11.

Exit Interview The inspector met with licensee and contractor representatives denoted in Paragraph 1 during and at the conclusion of the inspection on June 4, 1987.

The inspector summarized the scope and results of the inspection and discussed the likely content of this inspection report.

The licensee acknowledged ti.e information and did not indicate that any of the

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information disclosed during the inspection could be considered J

proprietary in nature.

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