IR 05000456/1987018

Insp Rept 50-456/87-18 on 870601-05.Major Areas Inspected: Operations,Surveillance & Testing,Maint,Lers,Radiation Controls,Chemistry Controls,Nuclear Engineer Activities & Training

ML20235H175
Person / Time
Site:	Braidwood
Issue date:	07/02/1987
From:	Hinds J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20235H157	List: IR 05000456/1987018 ML20235H154
References
50-456-87-18, NUDOCS 8707150040
Download: ML20235H175 (15)

Text

1

-

.c,

1

\\

'

.

.

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-456/87018(DRP)

Docket No. 50-456 License No. NPF-70 l

Licensee: Coninonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Station, Unit 1 Inspection At: Braidwood Site, Braidwood, Illinois Inspection Conducted: June 1 through 5, 1987 Inspectors:

J. M. Hinds B. H. Little H. A. Walker R. L. Nelson P. R. Pelke

)

R. M. Lerch T. H. Carter H. T. Sam

.

l

.L..

'

.

,

Approved B':

J. F. Hinds, Ac ing C ief 0% O2 B7 ojects Section Date

,

l l

Inspection Sunraary Inspection on June 1 through 5, 1987 (Report No. 50-456/87018(DRP))

Areas Inspected: Special announced team inspection by Region III supervision, senior resfdent, and region based inspectors to perform an operational readi-I ness inspection prior to full power licensing of the Braidwood 1 plant. Areas

!

reviewed included: operations, surveillance and testing, maintenance, LERs, radiation controls, chemistry controls, nuclear engineer activities, and training.

In addition to the above review, an inspection of the licensee's Operational Quality Assurance Program was conducted during March 1987, as documented in Inspection Report (50-456/87011(DRS)). The Operational Quality Assurance Program inspection is considered a part of this pre-full power license operational readiness inspection.

Resul ts : Of the 8 areas inspected, no violations or deviations were identified.

Wh O

- _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _

.

'.,

.

'

.

.,

DETAILS 1.

Persons Contacted

'

Commonwealth Edison Company (CECO)

i

• M. J. Wallace, Project Manager l

1. • E. E. Fitzpatrick, Station Manager

1. • C. W. Schroeder, Station Services Superintendent

1. • K. Kofron, Production Superintendent

1. • D. O'Brien, Operations Assistant Superintendent

1. • P. Cretens, Station Startup Assistant Superintendent

1. • F. Willaford, Security Administrator

• P. Barnes, Regulatory Assurance Supervisor

1. • M. Takaki, Quality Control Supervisor

1. • R. Aker, Radiation / Chemistry Supervisor l

1. • R. Lemke, Technical Staff Supervisor I

1. • L. Raney, Onsite Nuclear Safety Supervisor l

• P. Holland, Regulatory Assurance

1. • T. W. Simpkin, Operating Experience Group

• R. J. Legner, Senior Operating Engineer

1. • R. J. Ungeran, Operating Engineer, Unit 1

1. • R. Yungk, Operating Engineer, Unit 0

• G. R. Masters, Operating Engineer, Unit 2

)

• T. Trana, SNED Project Engineer j

l

1. P. Barnes, Regulatory Assurance Supervisor

1. L. M. Kline, Regulatory Assurance Supervisor

1. D. L. Shamblin, Assistant Project Manager i

1. S. C. Hunsader, Nuclear Licensing Administration

1. J. E. Smith, Electrical Maintenance

1. A. J. D'Antorio, Quality Control

!

1. J. R. Phillips, Instrument Maintenance Department j

1. D. Schavey, Training i

1. J. Bandjrski, Senior Financial Coordinator

1. D. J. Scott, Operations Manager

!

1. N. Coan, Office Supervisor

1. L. E. Davis, Assistant Superintendent Technical Services

1. R. D. Kyrouac, Station Quality Assurance Superintendent The inspectors also contacted and interviewed other licensee and contractor personnel.

!

J Nuclear Regulatory Commission - Region III

1. C. E. Norelius, Director, Division of Reactor Projects

1. • J. Hinds, Acting Chief, Reactor Projects Section lA, Region III

'

1. • T. Tongue,SeniorResidentInspector(Operations),Braidwood

1. • W. Kropp, Senior Resident Inspector (Construction), Braidwood

1. • T. Taylor, Resident Inspector, Braidwood

• R. Nelson, Senior Resident Inspector, Kewaunee l

l I

l

)

!

.......

,

..

.

.

.

-

1. • H. Walker, Reactor Inspector, Region III

)

1. • T. Carter, Reactor Inspector, Region III j

1. • P. Pelke, Project Inspector, Braidwood, Region III j

1. • R. Lerch, Technical Assistant, Reactor Projects, Branch 1, Region III

• H. Sam, Co-op Student, Region III

1. B. Little, SRI - Callaway

1. D. R. Muller, Project Director, Nuclear Reactor Regulation

• Denotes those attending the entrance meeting on June 1, 1987.

1. Denotes those attending the exit meeting on June 5, 1987.

j 2.

General The team inspection was conducted in order to help determine whether or j

not the Commonwealth Edison Company should receive a recommendation from

Region III to operate Braidwood Unit 1 beyond 5% reactor power. Licensee i

activities were closely monitored in order to ensure the facility was l

being operated safely and to ascertain the licensee's readiness to j

operate at power levels up to 100%. The inspection included examination j

of the interface between the operations department and other on-site l

,

l organizations to assess the effectiveness of the entire station organization.

i The team was comprised of, the leader, who was an Acting Section Chief in the Division of Reactor Projects; two Senior Resident Inspectors from other operating reactor facilities in Region III; the Braidwood Project Inspector; the Branch 1 Technical Assistant; two regional based inspectors; and a co-op inspector under instruction.

3.

Plant Operations (36700, 71707, 71881)

An inspection of plant operations was performed by observing the performance of the licensee's operating staff on all shifts with the following objectives:

Determine adequacy of shift turnovers, attentiveness to indications, communications between operators, awareness of plant status, procedural compliance, control room congestion, completeness and accuracy of logs, performance during abnormal conditions, communications with other departments, independent verification effectiveness, and the effectiveness and involvement of supervision and management.

Review workload of operating crew, especially staff assistants.

Detennine quality of prioritizing the work that goes through the

,

l operations group before scheduling.

l

'

Review followups to events, critiques of evcC,s, Lc0 Time Clocks (who tracks, how, effectiveness).

'

Evaluate communications between the Control Room personnel and others, particularly during off normal events.

i

.

.t.

.

.

,

,

The following observations were made:

a.

Adequacy of shift turnovers - Shift turnovers were observed on each q

shift including a pre-shift turnover meeting held with attendees i

from the maintenance, health physics, chemistry, operations, and j

technical services supervisory staff. Shift turnover meetings were found to be excellent overall, being comprehensive in detail, and open for discussion of problems while professionally conducted.

Turnovers between individuals were observed to be lengthly and i

methodical, implementing detailed checklists and performing panel l

walkdowns.

b.

Attentiveness to Indications - Operators were alert and attentive to panel instruments and alarms at all times. The plant was being held

)

at less than 1% power with few plant manipulations required to support low power physics testing.

Operation of the plant was observed to be very competent.

c.

Communications - Communications within the operations staff were

,

found to be good with information flowing smoothly from the shift engineer to licensed and non-licensed operators. Communications between departments appeared good through shift briefing discussions; however, in these discussions and interviews, there is apparent need for more discussion and agreement between the Rad / Chem department

'

and other staff regarding Radiological Work Permit requirements and specific job radiological practices.

In particular there seemed to be lack of prior agreement on what radiological protection steps would be taken during specific jobs and how they would be accomplished.

d.

Awareness of plant status - All shifts were found to be fully aware of plant status.

Interviews with operators found them knowledgeable of out-of-service control room indicators and the compensatory actions required.

e.

Control room congestion - The access to the control room was thoroughly controlled with clearly defined traffic patterns and barriers to random traffic into the main controi panels horseshoe area. The Unit 1 horseshoe area was observed to be free of distractions or interferences on all shifts in spite of the physics testing and Unit 2 activities in progress.

f.

Completeness and accuracy of logs - Operator logs were reviewed and sample entries verified. The logs were found accurate with no weaknesses.

g.

Performance during abnormal conditions - With the reactor at steady power the only abnormal occurrence observed was the loss of one 345 Kv power supply from offsite. Control room response was witnessed during which operators quickly began panel walkdowns for problems and the Shift Engineer gave assistance. This reinforced the inspectors' finding of operator responsiveness to plant indicators.

.

. '.,

\\

.

.

.

'

i h.

Effectiveness and involvement of supervision and management -

)

Inspectors attended daily meetings with all plant department upper j

management where plant status and the daily activities plan were discussed.

In addition, pre-shift turnover meetings are attended by supervisors from all departments. The licensee has a senior supervisor on shift who was observed in the control room as was the Plant Manager at least once per day.

Inspectors, in conversation j

with staff, received reports of back shift managers involvement in j

positive ways. Based on this, it is concluded that management i

involvement with plant operations is comprehensive and effective.

i.

Workload of operating crews - Inspectors viewed workload as normal, j

Some brief periods of hectic center desk activity were observed; however, business was conducted in an orderly fashion. Additional staff assigned to Unit 2 were found to be of great assistance.

Overall, the workload appeared well managed.

j.

Technical Specifications (TS) Limiting Conditions for Operations i

(LCOs) time clocks - Inspectors observed that LCOs were tracked and

}

reviewed at shift turnovers. Operators were kept aware of LC0

status, and referred to TS whenever requirements appeared to be affected, so that LCOs appeared to be appropriately entered and tracked. No weaknesses were noted.

i k.

Effectiveness of plant tours - Inspectors accompanied non-licensed

]

operators on their rounds to assess their performance and knowledge of plant conditions. The non-licensed operators were knowledgeable and effective in their areas of responsibility. A variety of functions were observed, such as startups of various equipment, which were well executed.

It was noted during rounds that some areas for which entry was not required, were not entered.

Plant management should consider a requirement that all accessible areas of the turbine and auxiliary building be entered once per shift for detection of off-normal conditions. The plant appearance was generally good with significant effort evident in upgrading its condition. Additional effort for controlling the accumulation of boric acid residue appears warranted.

1.

Tagout control and independent verification - The licensee's program for independent verification of equipment status was observed

being properly used. An on-shift licensed operator, not having the

!

" hands on" responsibility for manipulation of plant process

!

controls, was assigned to assist the Shift Control Room Engineer l

on tagout control. Staffing for this function seemed to be l

adequate. Documentation for the independent verification of i

correct adherence to the tag out order for safety-related equipment l

is required. Plant management should consider a requirement for j

independent verification of the tag-out order.

{

Plant operations at Braidwood Unit 1 were being conducted in a

!

competent and thorough manner.

Plant management involvement in day-to-day operations was evident. The knowledge and skill of l

i l

l

,

______

_-_

..i,,

• ..

.

operations personnel is reflective of a good training program.

Plant housekeeping was good considering the plant status. Operators

and supervisors were found to be attentive to plant conditions and responsive to changes in conditions.

4.

Surveillance and Testing Observation (72302)

Station surveillance activities of the safety-related systems and components listed below were observed / reviewed to ascertain that they were conducted in accordance with approved procedures and in conformance with Technical Specifications.

The following items were considered during this review:

the limiting l

conditions for operation were met while affected components or systems were removed from and restored to service; approvals were obtained prior i

to initiating the testing; testing was accomplished in accordance with approved procedures; test instrumentation was within its calibration interval; testing was accomplished by qualified personnel; test results confonned with Technical Specifications and procedural requirements and'

were reviewed by personnel other than the individual directing the test; and any deficiencies identified during the testing were properly documented, reviewed, and resolved by appropriate management personnel.

i The inspection focused on following areas:

Preparation; including adequacy of procedures, and equipment, and pre-task briefings and task knowledge.

p

Performance discipline; including supervision and control, procedure adherence, and communications.

I

Documentation and resolution of deficiencies.

Independent verification and review.

h

)

The following surveillance testing activities were observed / reviewed:

Surveillance Procedure No.

Ac tivity 18w0S 5.2.b-1 ECCS Vent and Valve Alignment 1Bw05 3.1.1 44.1 Power Range Drawer N-44 1Bw0P AF-7 Auxiliary Feedwater Pump (Diesel Startup on Recirculation)'

18wIs 3.2.1-007 Steam Flow Feed Flow Mismatch (S/G-10)

IBwIS 3.1.1-039 Pressurizer Pressure Protection Channel III 1Bwls 3.1.1-013 Reactor Coolant Flow Loop 1A Channel III 18w0S 0.1, 2, 3 Daily Operating Surveillance IBw0S 3.2.1-880 Engineered Safety Features Actuation 18w0S 3.2.1-811 (ESFAS) Instrumentation 18w05 3.2.1-812 Slave Relay Surveillance 18w0S 8.3.1-1 & 2 ESF Cn-site Power Distribution

,

.

.

.* *.,

• ..

Tests (Zero Power Physics)

Procedure No.

Activity FH 32 Section 9.25 Determination of Top and Bottom Limit Switches (incoredetectors)

RD 35 Section 9.1-9.3 Boron Endpoint Determination IT 30 Section 9.1 Isothermal Temperature Coefficient RD 34A Section 9.1-9.2 Rod Worth Measurement Dilution The inspectors determined that the licensee had implemented appropriately reviewed and approved procedures for the surveillance and testing

,

activities. Special test equipment functioned well and instruments were in current calibration. Personnel involved in supervision and performance of the tasks appeared well trained / knowledgeable of task objectives and equipment operation. Procedure review and pre-task briefings were routinely performed. The surveillance and test procedures were generally well written, containing appropriate precautions and notes. Test Procedure No. BwSU-34A contained only one Temporary Change Report (TCR), however, the TCR resulted in numerous " hand-written" changes in the body of the procedure. The inspector considered that

.

the procedure, as issued, presented an additional burden to personnel performing the task and an increased potential for performance errors.

This matter was discussed with the licensee and is undergoing their evaluation.

The inspectors determined that control room supervision and operators maintained adequate control over the surveillance and test activities.

Personnel performing the tasks demonstrated a high degree of performance discipline, procedures were followed in a step-by-step method, however, two exceptions were noted.

During performance of two surveillance, operating personnel took data and performed evaluations cut of the

.

sequence as permitted by the procedure.

In one case, when the sequences Was questioned, the partially performed surveillance was reperformed.

In these cases, personnel were taking a more efficient sequence to completing the work. The strict adherence to procedure sequence in these cases was being undermined by poor procedure sequencing. This matter was discussed with the licensee and is being evaluated.

Communications, involving approval, instruction ami status was conducted in a business-like manner.

No violations or deviations were identified.

5.

Maintenance Observation (62700, 62702, 62703)

Station maintenance activities of the safety-related systems and components listed below were observed / reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides, and industry codes or standards, and in conformance with Technical Specifications.

_ _ _ _.

.

8.,

I

'..

The station maintenance program, implementing documents and activities were reviewed to ascertain that approved procedures, regulatory require-ments and technical specifications were met. Both corrective and preventive maintenance procedures were reviewed.

The following items were considered during this review: approvals were obtained prior to initiating the work; activities were accomplished using approved procedures or instructions and were inspected as applicable; functional testing and/or calibrations were performed prior to returning components or systems to service; quality control was performed as needed and records maintained; activities were accomplished by qualified personnel; proper parts and materials were used; radiological and fire protection controls were implemented as needed.

The maintenance program and implementation were discussed with licensee i

l maintenance management / supervision. Maintenance was divided into three control (I&C))plines, (electrical, mechanical and instrumentation and separate disci

,

each headed by a supervisor who reports to the Assistant l

l Plant Manager - 11aintenance. Each discipline performs corrective main-tenance, preventive maintenance and technical specification surveillance in their respective disciplines. Corrective maintenance is performed l

using the Nuclear Work Request (NWR) as the controlling document.

NWRs l

will normally be used for preventive maintenance (PN) if the activity

'

involves a significant amount of work or if an operability test is required after completion.

Other PMs are performed using a computer originated form similar to those used for plant surveillance. Main-tenance priorities are assigned based on need with the "A" priority being the most urgent requiring immediate work. The inspectors were told that only 15

"A" priority NWR's were worked during Play 1987.

a.

In reviewing NWR logs and reports the inspectors noted the following:

1.

A total of 1605 NWRs were open on May 31, 1987.

2.

767 of these open NWRs were safety related.

3.

105 of these NWRs are required to be completed prior to Mode 1.

4.

717 of the open NWRs were available for work. The others had mode related, parts related, or other restraints.

The number of open NWRs had been reduced by approximately 200 during the past two months and the declining trend appeared to be continuing.

In addition, to the above, the inspectors observed or reviewed the following maintenance related documents or activities.

b.

The inspectors used the following maintenance related procedures for reference during the inspection.

1.

BwAP 1600-1, Revision 11, " Maintenance Work Request Procedure".

.

• I.,

,

2.

BwAP 1600-6, Revision 1, " Post Maintenance Review and Trending of Nuclear Work Requests".

'

3.

BwAP 1200-004, Revision 0, " General Surveillance Procedure Specific to Mechanical Maintenance".

,

i 4.

BwAP 400-7, Revision 0, " Preventative Predictive Maintenance P rog ram".

Based on the cursory review performed, as these procedures were used, the inspectors consider them acceptable in describing the necessary methods and controls for maintenance.

c.

The inspectors observed maintenance work in progress in each of the three disciplines. Work on the following NWRs was observed:

d 1.

NWR A11330 - This NWR was an I&C work request to repair one pressurizer channel which was reading more than 25 percent above the other channels.

In reviewing the package the inspectors noted that work instructions appeared to be adequate, that the NWR was properly approved and a release

,

for work had been obtained from the control room. A trcuble-shooting procedure was included in the package. Sign-off of steps were performed as the work was completed. Both technicians appeared to be knowledgeable of the job and appeared to be adequately qualified based on their education, experience and training.

Trouble-shooting was performed using the Micro Electronic Surveillance And Calibration (MESAC) panel.

Calibrated instruments in the panel were within the specified calibration period. The control room and electrical panels were determined i

to be operating properly and the problem was thought to be with the transmitter inside containment.

Prior to entering contain-ment to make necessary adjustments or repairs, the channel was

'

checked and found to be within tolerances and no further action was taken.

No problems were noted with this activity.

2.

NWR A13585 - This was an electrical work request to determine the reason fuses were blowing in one of the annunicator circuits and make the necessary repairs.

In reviewing the package, the inspectors noted that work instructions appeared to be adequate, that the NWR was properly approved and a release for work had been obtained from the control room.

A trouble-shooting procedure was included in the packages.

Sign-off of steps was performed as the work was completed.

Both technicians appeared to be knowledgeable of the job and appeared to be adequately qualified based on their education, experience and training.

,

___ _-

.

.

.

l Trouble-shooting was performed by isolating portions of the circuit to locate an existing ground. Lif ting and replacing of leads and verification were recorded on the maintenance alterations log.

The test instrument used was within the specified calibration period.

• he trouble was found to be located on a printed circuit card and the card and the fuse were replaced.

No problems were noted with this activity.

3.

NWR A12505 - This was a mechanical work request, associated with a modification, to install a vent line with an isolation valve in one of the piping systems.

In reviewing the package the inspectors noted that work instructions appeared to be adequate and the NWR was properly approved. Since the initial work was to fabricate the pipe spool piece in the shop, no release from the control room was required prior to the shop work. No sign-offs were in the package, other than obtaining the required material, since work was just beginning. The package contained several Quality Assurance (QA) and several Quality Control (QC) hold points. The welder assigned to fit up and weld the pipe spool piece had many years of experience and appeared to be qualified.

Certification was not checked since no welding actually occurred.

The initial welding fit-up had both QC and QA hold points. As the welder began the fit-up the QA inspector reviewed the work package against the material and noted that the valve obtained from stores for the job was the wrong valve. He immediately brought this to the attention of the mechanical maintenance foreman and the job was stopped.

In reviewing the stores requisition it was noted that the wrong valve was requested.

Since some delay was involved in obtaining the correct valve, no further review of this activity was performed by the NRC inspectors.

In discussions with licensee personnel, it was clear that they understood that the responsibility for ensuring that correct parts and material are used is the responsibility of the craftsman. Since the problem was noted by licensee personnel and immediate action was taken, the NRC inspectors are satis-fied that appropriate control systems are functioning in the maintenance area.

4.

In addition, inspectors observed a maintenance job in progress on primary sample line leaks and a surveillance in progress to vent emergency core cooling systems. Both jobs involved working with fluids from potentially contaminated systems.

The work was skillfully performed in accordance with procedures, however, from observation, it was evident that radiological practices were not appropriate for contaminated systems. Containment materials were not on the job and workers

. _-_ - _______ _

.

<l..

i

• ..

.

were unsure of how to deal with leakage. There is an apparent need for better job preplanning for radiological protection (RP) standardization of RP methods, establishing the station authority on RP practices, and improvement of RP awareness and skills. Due to the low powers of reactor operation prior to this inspection, there was no threat of significant contamination in these systems and workers were aware of this.

Worker awareness of the changes in radiological contamination, which will increase as the plant continues to operate, should be emphasized and reinforced.

The licensee was made aware of these concerns and is addressing them appropriately.

d.

The inspectors reviewed 14 recently completed NWR packages which were located at Central Files. The packages reviewed were A07767, A08313, A08503, A08516, A08836, A09001, A09906, A09576, A09724, A10107, A10201, A10681, A10719, and A13451.

Final review

,

of these packages had been performed by maintenance, QC and QA.

The following observations were made (1) All packages contained

'l adequate work instruction and the required sign-offs and approvals.

J (2) QC involvement was evidenced by hold points with appropriate

'

initials in the appropriate travelers and procedures.

(3)No significant problems were noted, however, several minor concerns were discussed with the licensee and will be resolved.

The inspectors have no further concerns in this area.

e.

The preventive maintenance (PM) program is implemented as a part of the surveillance program. When PMs and surveillance are due, a computer printout is provided indicating the due date. This printout also contains all past due items.

Most PMs are worked directly from a printed computer sheet. NWRs are written for those PMs requiring substantial work or those requiring an operability test after work is complete. The inspectors reviewed a computer print-out of due and over-due surveillance and PM items issued June 5, 1987. No long term over-due PMs and few short term overdue PMs were noted. The inspectors have no concerns in this area.

f.

In order to determine licensee verification of maintenance activities, the inspectors reviewed the computerized QA surveillance and audit logs for 1987.

It was noted that 29 maintenance related surveill-ances had been conducted in 1987.

Four audits conducted in 1987 appeared to involve maintenance activities. These were product (end result) type audits and it does not appear that all reintenance-areas have been appropriately audited. Based on previous NRC concerns the licenst has now scheduled an overall audit of maintenance which is to be conducted in the near future. With the completion of this audit, licensee verification of maintenance will be adequate. The inspectors have no further concerns in this area.

No violations or deviations were identified.

-

..

J

) \\.

i 6.

Licensee Event Reports (90712)

The inspector conducted a review of the 1987 LERs and the February and May 1987 DVRs. At the time of inspection, one LER had been submitted since the issuance of the Low Power License regarding a reactor trip on May 22 and one on May 27, which were both caused by a blown fuse.

)

There were a total of 25 LERs in 1987 at the time of inspection. A J

breakdown of the first 23 by cause code is as follows:

Cause Code No. of LERs Percent Personnel Error

43

)

Preservice Error

13 External Cause

4 i

Defective Procedure

13 Management Deficiency

17 Component Failure

_2_

TOTAL

100 Four of the personnel errors were caused by contractor personnel. One of the personnel errors was a fire detection zone being inoperable due to unauthorized removal of a detector by an unknown person.

In all cases, the licensee took appropriate corrective actions to reduce personnel errors in the future.

The licensee has prepared one DIR/LER trend report (87-001) in accordance with Procedure BwAP 1250-8. Trend Report 87-001 covers the period of October 1986 through March 1987.

Personnel errors represented 38% of the total for the period. A second trend report is in preparation.

,

LERs were found to be well written. An excellent tracking and cause coding system is being used.

Braidwood is using lessons learned from Byron LERs/DIRs and from Zion LERs.

A concern was identified regarding the determination, by the licensee, that DVR 87-177 is not reportable. A Technical Specification Firewatch was missed between 1630 and 1830 on May 17, 1987, when the Watchman assigned locked himself in the "B" Containment Spray pump room. The event exceeded the LC0; however, the licensee is taking credit for other personnel in the firewatch route area based on security computer access lists.

No violations or deviations were identified.

7.

RadiationProtection(71709,83524,83526)

The inspector met with the Station Health Physicist and witnessed Radiation Chemistry Technician (RCT) surveillance activities regarding process radiation monitors 1(2)RE-PR028 and 1RT-PR011.

A number of strengths were noted during this inspection including:

_ _ _ _ _ - _ _ _ _ -

- - -

- - - - - - - - - - _ - - - -

,

..,

t

RCTs appear to be knowledgeable of plant systems, procedures, and l

responsibilities.

Braidwood has brought in a contractor (PSCS) to provide additional

"

radiation protection support.

,

l The Station Health Physicist was Lead HP at LaSalle, the Rad / Chem

Supervisor has previous experience at Zion, and the Startup HP has approximately six years experience as the Byron Lead HP.

No Radiation Occurrence Reports have been issued in 1987.

Braidwood is utilizing the Byron Base Point Survey results

<

to compare against the Braidwood Base Point Surveys.

l l

!

Braidwood has onsite Thermoluminescence Dosimetry (TLD) processing.

Daily surveys of the plant are being conducted as a conservative

I measure.

• Additional radiation awareness training was provided to onsite personnel.

l l

ALARA meetings are conducted biweekly as a conservative measure during startup (the procedural requirement is quarterly).

'

Three observations were made during the inspection:

'

Audible speakers on GM survey meters used at the 401' Auxiliary Building to Turbine Building door and the 426' Containment entry way could not be heard by the surveyors because background noise level was too high. Low level contamination could be missed due to a delay in meter response or if the RCT is not watching the l

meter very closely. The licensee has issued a Request for Purchase Order to obtain headphones to be used with the GM survey meters.

'

l RCTs have been instructed to pay more attention to their meters in

'

high noise areas until the headphones are obtained.

• The Rad / Chem survey of the laundry room was performed with a " Cutie Pie."

Presently, based on operating history, no radiation can be detected; however, when low levels start building up, a more sensitive instrument with a lower range would detect low level contamination at lower contamination levels.

The licensee takes smears in the laundry area and will have the RCTs use GM survey meters in addition to the Cutie Pie.

• The inspector reviewed the time cards for all RCTs for the period of April 13, 1987 until June 3,1987.

Several RCTs had worked over 80 hour9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> weeks with one working a 104 hour0.0012 days <br />0.0289 hours <br />1.719577e-4 weeks <br />3.9572e-5 months <br /> week. Other examples of exceeding Generic Letter 82-12 working hour limitations were evident.

Technical Specification 6.2.2 states, "The unit organization shall be as shown in Figure 6.2-2 and:...e. Administrative procedures

l

..,

shall be developed and implemented to limit the working hours of unit staff who perform safety-related functions; e.g., licensed

.

Senior Operators, licensed Operators, health physics personnel, equipment operators, and key maintenance personnel. The amount of overtime worked by Unit staff members performing safety-related functions shall be limited in accordance with the NRC Policy Statement on working hours (Generic Letter No. 82-12)." The amount of overtime worked by the RCTs appears to be in violation of the licensee's overtime procedure (8wAP 100-7) and Technical Specification 6.2.2.e.

The licensee's position is that only the one Duty RCT is required to comply with the Generic Letter 82-12 working hour limitations. The inspector verified that the licensee implements the Generic Letter 82-12 requirements for the one Duty RCT.

No violations or deviations were identified.

8.

StationChemistry(79501)

The inspector met with the Station Chemist and conducted a tour of the Chemistry Laboratory facilities. General housekeeping was excellent and d11 equipment was operational. RWP 87-0013 covers activities in the hot laboratory and counting roon. Step off pads and friskers were located at the entrances. Additional chemists have been obtained to assist with the startup of Unit 1 concurrent with preoperational testing of Unit 2.

The Unit 1 Chemist has prior experience with startup activities at Dyron.

Lines of responsibility are defined and no interface / communication problems between Chemistry and other departments were identified. The Rad / Chem Supervisor attends the Plan of the Day (P00) meeting, and in his absence, either the Station Health Physicist or the Station Chemist attends. A Chemist attends each shift briefing.

Both the primary and secondary chemistries were within specifications during this inspection. The Chemistry Department recently implemented the Unit 1 Monthly Chemistry Report which is submitted to the Assistant Superintendent - Operations.

The inspector reviewed the April report, which includes plant performance from a chemistry standpoint, graphs of chemistry data, and areas of concern regarding chemistry. The April report indicated RCS daily boron concentration ranged between 2050 and 2080 ppm, which was greater than the Fuel Load and Precritical Testing License limit of 2000 ppm. RCS dissolved oxygen for April was well below the Technical Specification limit of.10 ppm.

Fluoride concentrations remained below detection limits throughout the period. Chloride concentrations were maintained in the 10 ppb range while in Mode 3, but increased to 30 ppb in Mode 4, which is below the Technical Specification limit of 0.15 ppm. Two concerns were identified in the report regarding periodic loss of steam generator pH control due to excessive steam dump operation and periodic appearance of trace concentrations of sulfates in the main condenser hotwell, which may be an indication of minor condenser tube leakage.

~ =,

I

1. a l

Region III has three open items regarding the chemistry program, none of i

which are required to be completed prior to issuance of a Full Power License. No LERs were submitted in 1987 as a result of chemistry program

,

deficiencies.

No violations or deviations were identified.

9.

Nuclear Engineers Activities (71715)

The inspectcrs determined that the Nuclear Engineers were directing the tests, were knowledgeable of testing in progress, utilized Byron experiences and conducted good pre-test briefings. The Nuclear Engineers ensured that the Nuclear Station Operators, Shift Test Engineers and l

Westinghouse used the approved and official procedures. Activities were well controlled and evolutions were conducted in a step-by-step manner.

l Interface bet' ween Nuclear Engineers with Westinghouse, Shift Test Engineers and Nuclear Station Operators was very good.

No violations or deviations were identified.

l 10. Training (41400)

The effectiveness of training programs for licensed and non-licensed personnel was observed by the inspectors during the witnessing of l

the licensee's performance of routine surveillance, maintenance, and i

operational activities.

Except for weaknesses in radiological protection

'

identified in the section on maintenance, the station staff performed in a highly trained and motivated fashion.

Licensed and non-licensed operators were knowledgeable of the plant equipment. Mechanical, electrical and instrumentation and control technicians were observed at their tasks and performed the duties with skill.

In other departments, l

employees also performed in such a way as to demonstrate effective training programs.

'

No violations or deviations were identified.

11. Exit Interview (30703)

The inspector met with licensee and contractor representatives denoted in Paragraph I during, and at the conclusion of, the inspection on June 5, 1987.

The inspectors summarized the scope and findings of the inspection activities. The inspectors highlighted the need for management attention in the areas discussed in previous paragraphs. The licensee acknowledged the inspection findings.

The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents / process as proprietary.

'

1