IR 05000456/1987022
| ML20238C127 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 09/02/1987 |
| From: | Dunlop A, Mendez R, Wright G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20238B437 | List: |
| References | |
| 50-456-87-22, 50-457-87-21, NUDOCS 8709090668 | |
| Download: ML20238C127 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION l
REGION III
Reports No. 50-456/87022(DRS); 50-457/87021(DRS)
Docket Nos. 50-456; 50-457 Licenses No. NPF-72; CPPR-133 Licensee:
Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 l
I Facility Name:
Braidwood Station, Units 1 and 2
Inspection At:
Braidwood Site, Braidwood, Illinois Inspection Conducted:
June 8 through August 20, 1987 bb 2f Inspectors:
A. Dunlop, <
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Jd ApprovedByfelse h2/f7 d
G. Wright, Chief Test Programs Section Date Inspection Summary Inspection on June 8 through August 20, 1987 (Reports No. 50-456/87022(DRS);
59-457/87021(DRS))
Areas Inspected:
Routine, unannounced safety inspection to review actions on previous inspection items (92701); preoperational test program implementation (70302); preoperational test performance (70315, 70314, 70312, 70439, 70438, 70435, 70437, 70448, 70433, 70449, 70447, 70450); preoperational test results review (70322, 70326); preoperational test results verification (70329); and startup test witnessing (72302).
Results:
Of the six areas inspected, one violation was identified in Paragraphs 4.a, 6.c, and 6.d.(1) of the report concerning performing procedural violations.
8709090660 070903 PDR ADDCK 0500
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DETAILS 1.
Persons Contacted
' Commonwealth Edison Company (CECO)
- E. E. Fitzpatrick, Station Manager
. *W. E.-Vahle, Construction Superintendent
- C. W. Schroeder, Station Services Superintendent
- K. L. Kofron,-Production Superintendent
- D. L. Shamblin, Project Manager
- R. D. Kyrouac, Station Quality A;sinance Superintendent
- L. E. Davis, Assistant Superinhndent, Technical Services
- D. E. O'Brien, Assistant Superintendent, Operating
- M. E. Lohmann, Startup Superintendent
- P. L. Barnes, Regulatary Assurance Supervisor
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- G. Orlov,' Staff Assistant to Project Manager
- W. R.-Betourne, Quality Assurance Supervisor
- R. E. Aker, Radiation / Chemistry Supervisor l
- T. W. Simpkin, Regulatory Assurance l
- A. J. D' Antonio, Quality Control
- R. J.-Legner, Senior Operating Engineer T. J. Lewis, Startup Staff, NOVA M. Inserra, TRB Supervisor /PSG
- M. Takaki, Regulatory Assurance
- G. Masters, U-2 Operating Engineer
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J. Rumsey, Project Test Director D. Ewan, Project Test Director M. Montes, Project Test Director
'F. Stultz, Project Test Director T. Skanes, Project Test Coordinator Additional station technical, operational, and administrative personnel were contacted by the inspector during the course of the inspection.
- Denotes those attending the exit meeting on August 20, 1987.
2.
Action on Previous Inspection Items
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(Closed) Open Item (456/87003-01(DRS)):
This item concerned the completion of the Auxiliary Feedwater test procedure results review.
The inspector has completed reviewing BwPT AF-10 and all the associated retests with no further comments.
This item is considered closed.
3.
Preoperational Test Program Implementation This review consisted of a determination if administrative controls had l
been developed and implemented to support FSAR commitments, and regulatory
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requirements.
The inspector had the following comment:
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The latest revision to the Braidwood Startup Manual (BwSUM), Revision 20, was reviewed by the inspector with no comments.
The inspector verified-implementation of the BwSUM during the test witnessing and test results review portion of the inspection.
Specific implementation concerns are stated in subsequent paragraphs of the report.
No violations or deviations were identified.
4.
Preoperational Test Performance The inspector witnessed the performance of portions of the following preoperational test procedures to verify that testing was conducted in accordance with approved procedures, to independently verify the acceptability.of test results, and to evaluate the performance of licensee personnel conducting the tests.
BwPT RC-50, Revision 0, " Integrated Hot Functional Unit 2" BwPT MS-50, Revision 0, " Main Steam Isolation Valves (Safety-Related)"
BwPT RY-50, Revision 0, " Reactor Coolant Pressurizer"
BwPT FW-50, Revision 0, " Main Feedwater (Safety-Related)"
.BwPT AF-50, Revision 1, " Auxiliary Feedwater" BwPT MS-52, Revision 0, " Main Steam PORV's (Safety-Related)"
BwPT IT-50, Revision 1, "RTD Cross Calibration (Safety-Related)"
BWPT LM-57, Revision 0, " Reactor Loose Parts Monitor for IHF" BwPT FW-57, Revision 0, " Tempering Flow Test (IHF)"
BwPT SI-53, Revision 0, " Safety Injection Check Valve Operability and Leakage Test (IHF)"
BwPT RC-52, Revision 0, " Reactor Coolant (Miscellaneous Controls)"
BwPT AP-56, Revision 0, " Bus Loading and Independence" BwPT RY-57, Revision 0, " Pressurizer (IHF)"
BwPT CV-57, Revision 0, " Chemical Volume Control System (IHF)"
BwPT FW-58, Revision 0, " Steam Generator Level Alarm and Setpoint Verification (IHF)"
l BwPT MS-57, Revision 0, " Main Steam, Safety-Related (IHF)"
BwPT PR-53, Revision 1, " Process Radiation Monitoring Loop 3" l
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Y BwPT LD-50, Revision 1 " Leak Detection System" BwSD TG-67, Revision 0, " Turbine Rolls and Generator Synchronization During Integrated Hot Functional (IHF)"
The following are comments and observations identified while witnessing the tests performance:
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a.
On July 16, 1987, the inspector noticed that the plant heatup from 350* to 450 F had begun (RC-50, Step 9.9.5).
While reviewing RC-50, the inspector identified that Steps 9.9.2 (performance of SI-53, Sections 9.1, 9.2, 9.5, and 9.6) and 9.9.4 (Safety Injection Accumulator Alignment) had not been completed prior to beginning Step 9.9.5.
RC-50 did not allow the performance of these steps concurrently. Section 4.6.3.3 of the BwSUM states:
"The steps within a section may not be reordered unless specifically authorized by the test procedure." This is considered to be an example of a procedural violation (457/87021-01a(DRS)). After reviewing the procedure, the Project Test Director (PTD) issued Test Change Request (TCR) No. 14 which allowed Steps 9.9.2, 9.9.4, and 9.9.5 to be performed concurrently. The inspector considered the TCR acceptable as the change did not affect the test.
Further examples of STEs failin to follow procedures are described in Paragraphs 6.c and 6.d.(1)gof this report.
These examples were identified by the licensee's Quality Assurance (QA) organization during routine audits and surveillance, Although none of the findings affected test results and actions were taken to correct the specific occurrence, the inspector is concerned with the apparent disregard of administrative procedures by the STEs.
The licensee needs to ensure that the STEs understand and comply with administrative procedures in order to prevent future occurrences.
Corrective actions should address the generic implementation of administrative procedures.
b.
On July 2,1987, an apparent lack of communications between STE and NSO resulted in the STE, in charge of clearing deficiencies to BwPT RY-50, depressurized the reactor coolant system (RCS) when he cycled one of the pressurizer PORVs. The STE was unaware that the PORVs block valve being open.
In response to the RCS depressurization, the NSO manually tripped the reactor coolant pumps in accordance with procedure to prevent damaging the pumps. The licensee is still investigating the circumstances that led to the depressurization and will issue a report on the subject. This will be considered anUnresolvedItem(457/87021-02(DRS))pendingissuanceofthe report by the licensee and review by the inspector.
c.
While the plant was at normal operating temperature and pressure (NOT/NOP) with the Main Steam Isolation Valves (MSIVs) shut, the 2A and 28 MSIVs drifted open.
The problem with the 2A MSIV was determined to be hydraulic fluid leaking by the 0-ring to the relief l
valve in the MSIVs hydraulic line. The 2B MSIV drifted opened due to the relief valve in the hydraulic line relieving back to the hydraulic fluid reservoir. Both of these occurrences reduced the
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I hydraulic pressure on the MS'IV closing piston and allowed the main
. steam line pressure to force the valve open.
The plant's. temperature and pressure were' reduced to replace the 0-ring on the 2A MSIV and gag shut the 28 MSIV (replacement parts not available).
The plant was thenireturned to NOT/N0P and hot functional testing continued.
The 28 MSIV was~ subsequently repaired and tested satisfactorily.
d.
The major evolutions witnessed by the inspectors included drawing a pressurizer bubble, plant heatup and cooldown, safety injection check valve testing, simultaneous start of-both auxiliary feedwater pumps, lifting main steam safety valves, initial turbine generator
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rolls., and operation from the remote shutdown panel, e.
A concern about the communication systems available in the plant was brought to the attention of the inspector by operators and STEs.
In some cases sound powered phone lines did not work or it was difficult to hear, headsets did not work, radio communications were being
" walked on" or garbled.
These conditions made it difficult to P " form some operations where communications are. vital.
Although tL: operators and STEs have used care in overcoming the problems with communications, this could cause significant' problems in the future.
The licensee has stated that they are investigating the concern and requested the inspector to meet with station management on the actions in progress during a subsequent inspection.
f.
The licensee implemented the "Braidwood Plan for Managing Unit 1/
Unit 2 Concurrent Activities," which established the necessary.
supervisory positions in the control room during Integrated Hot Functional (IHF) testing on Unit 2 and startup testing on Unit 1.
This program has been effective.
The STEs and Nuclear Station Operators (NS0s) have performed their functions in a professional manner.
The Project Test Directors (PTDs) and Control Room Test Supervisors (CRTs) controlled the IHF testing in a manner that kept personnel informed of evolutions in progress or scheduled, kept control room noise and personnel down to a minimum, did not allow the NS0s to become overloaded with simultaneous evolutions, and evaluated any problems or discrepancies that occurred.
The only
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' cases of poor communications were discussed in Paragraphs 4.a and 4.b.
One example of a violation was identified in Paragraph 4.a concerning a procedural violation.
5.
Preoperational Test Results Evaluation The inspectors reviewed the results of the following 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 was properly recorded,
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signed. dated and documented as test deficiencies, as necessary; test packages were reviewed by QA for adequacy of contents; and test results were approved by appropriate personnel.
BwPT SI-51, Revision 1, " Safety Injection Accumulators" BwPT EF-51, Revision 0, "ECCS Full Flow" BwPT SI-54, Revision 0, "SI Runout Protection Orifices" The' inspectors have the following comments with respect to these
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a.
The licensee has not approved the BwPT SI-51 completed test results.
package.
The inspector cannot-complete the review until licensee resolution and approval of a11' identified concerns.
This is considered an Open Item (457/87021-03(DRS)) pending review of an approved test results package by the inspector.
b.
The licensee has not approved the BwPT SI-54 completed test results package.
The. inspector cannot complete the review until licensee resolution and approval of all identified concerns..This-is
- considered an Open Item (457/87021-04(DRS)) pending review of-an approved test results package by the inspector.
c.
The licensee has not approved the BwPT EF-51 completed test results package.
The inspector cannot complete the review until licensee resolution and approval of all identified concerns.
This is considered-an Open Item (457/87021-05(DRS)) pending review of an approved test results package by the inspector, d.
BwPT EF-51, Acceptance Criteria 4.4, written to ensure that the 28 diesel-driven auxiliary feedwater (AFW) pump would start and obtain rated pressure in 60 seconds on a Safety Injection signal was not met due to the pump being unavailable for testing.
Action Item Record (AIR)'R20-87-095 was written by the licensee to track this deficiency.
The inspector will track this AIR as an Open Item (456/87021-06(DRS)) pending completion of the testing and review by the inspector.
No violations or deviations were identified.
6.
Preoperational Test Results Verification
'The inspectors reviewed the following preoperational test procedures and verified that results had been reviewed against approved acceptance criteria and that an evaluation of the test results had been performed
- in accorCance with Regulatory Guide 1.68 and the licensee's Startup manual:
BwPT.D0-52.2, Revision 0, " Diesel Fuel Oil - Emergency Diesel 2B (Safety-Related)"
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BwPT.VQ-51,' Revision 0, " Unit 2 Hydrogen Recombiner System" BwPT 00-52.1, Revision 0, " Diesel Fuel Oil Emergency Diesel 2A'and Lube Oil Drain Tank (Safety-Related)"
BwPT DG-52, Revision 0, " Emergency Diesel Generator Test" V
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p BwPT RH-50,-Revision 0, " Residual Heat Removal" l
The inspectors have the following comments with respect to these l
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procedures:
L a.
The licensee has not approved the BwPT DG-52 completed test results package.
The inspector cannot complete the' review until licensee resolution and approval of all identified concerns.
This is considered an Open Item (456/87021-07(DRS)) pending review of an approved test results package by the inspector.
b.
The licensee has not approved the BwPT RH-50 comp'leted tost results
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The inspector cannot complete the review untii licensee resolution and approval of all identified concerns.
This is considered an Open Item (456/87021-08(DRS)) pending review of-an approved test results package by the inspector, c.
For BwPT 00-52.1,.TCR No. 7 was a major change incorporated into the test on 10-20-86, but never approved.
The TCR was then deleted by TCR No. 11 on 10-25-86.. This does not appear to be in accordance
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with the BwSUM, which states in Section 3.5.2.2, " major changes shall be approved by the TRB and Project Engineering." This is an example of a procedura1' violation (457/87021-01b(DRS)).
TCR'No. 7 did not add or delete any testing, only added a statement concerning the possible effect on Unit 1.
As a result, the implementation of the TCR had no affect on the test results, and is only an administrative concern on implementing TCRs by administrative procedure. This item was identified by the licensee in QA Audit 20-86-D052.1-1.
d.
With respect to BwPT VQ-51, the inspector had the following comments:
(1) Initial Condition 7.2.2.1 was not signed off prior to the performance of Section 9.3'on 10-28-86, as required by the procedure.
TCR No. 8 was written, but not implemented until 10-30-86 to bypass Step 7.2.2.1.
This is not in accordance with the BwSUM, which states in Section 4.6.3.2, "... initial conditions are satisfied before the test starts," and "... may not be ignored unless specifically authorized by test procedure."
This is an example of a procedural violation (457/87021-01c(DRS)).
This item was identified by QA Audit 20-87-VQ51-1.
(2) Deficiency I was written to perform post test calibrations on certain instruments used tn collect acceptance criteria during the test.
This deficiency was closed to Nuclear Work Request (NWR) No. A11969 shich was then closed to a station blanket
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calibration work request.
By doing this, it would be difficult to track calibration records of instruments used in specific tests in order to determine if data recorded is acceptable.
This item was identified.in QA Surveillance 20-87-VQ51-1.
Project Startup concurred that this method of tracking was not acceptable and decided that deficiencies should only be closed to AIRS, whose corrective action must be approved by the originator.
This will ensure that specific work items cannot be closed by other personnel without Project Startup's concurrence.
This appears to be an adequate tracking method.
Two examples of a procedural violation were identified in Paragraphs 6.c and 6.d(1).
7.
Startup Test Witnessing The inspectors witnessed portions of the below listed startup test procedure to verify that the test was conducted in accordance with
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an approved procedure; that all test equipment was properly installed; that test data was collected and recorded properly; adequate ability of personnel conducting the test; that deficiencies and test problems were documented and that test changes were processed in an approved manner:
BwSU IC-31, Revision 0, "Incore Flux Mapping At Low Power" No violat:ons or deviations were identified.
8.
Open Items Open items are matters which have been discussed with the licensee, which will be reviewed by the inspector and which involve some action on the part of the NRC or licensee or both.
Open items disclosed during the inspection are discussed in Paragraphs 5 a, 5.b, 5.c, 5.d, 6.a, and 6.b.
9.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations.
An unresolved item disclosed during the inspection is discussed in Paragraph 4.b.
10.
Exit Interview The inspector met with licensee and contractor representatives denoted in Paragraph I during and at the conclusion of the inspection on August 20, 1987.
The inspector summarized the scope and results of the inspection and discussed the likely content of this inspection report.
The licensee acknowledged the information and did not indicate that any of the information disclosed during the inspection could be considered proprietary in nature, v..
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