IR 05000456/1987032
| ML20236K721 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 11/03/1987 |
| From: | Dunlop A, Lanksbury R, Stasek S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20236K717 | List: |
| References | |
| 50-456-87-32, 50-457-87-31, NUDOCS 8711090321 | |
| Download: ML20236K721 (11) | |
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lU'.S. REGULATORY COMMISSION
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REGION III
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Reports No. 50-456/87032(DRS); 50-457/87031(DRS)
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Docket Nos. 50-456; 50-457 Licenses No. NPF-72; CPPR-133-Licensee: Commonwealth Edison Company Post Office Box 767
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L Chicago, IL 60690-j
Facility Name: Braidwood Station, Units l'and 2 Inspection At: Braidwood Site, Braidwood, Illinois i
j Inspection Conducted:
September 9 through October 21, 1987
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W Y >" l Inspectors:
A. Dunlop, Jr.
M 8'O-l Date G Q,'
i S. Stasek I h3'W '
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Approved B[ R. Lan,sauury, Ading Chief
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Test Programs Section
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Inspection Summary Inspection on September 9 through October 21, 1987 (Reports No. 50-456/87032(DRS);
50-457/87031(DRS))
Areas Inspected: Routine,. unannounced safety inspection ~to review actions j
on previous inspection items (92701, 92702);- preoperational test-program;.
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-implementation (70302);preoperationaltestperformance(70312,.70317,70434);
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preoperational test results - review (70320, 70322, 70547, 70535,.' 70537,170548. -
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70324); preoperational test results verification (70329); startup test.
procedure review (72570, 72572, 72576, 72500, 72566, 72578); startupl test a
results review (72596,. 72600. 72301); and startup test results verification '
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l-(72301,72600).
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Results:. Of the eight areas inspected, no violations or deviations were i
identified in this report. However, two unresolved items ~and 15 open items i
(14 for tracking purposes only) were' identified.
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DETAILS.
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. Persons Contacted g' 3 3
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Commonwealth Edison Company (CECO)
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- L'. E.. Davis, Assistant' Superintendent, Technical. Services
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- D. E. O'Brien, Station. Service Superintendent
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- M. E. Lohmann,-Startup Superintendent
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- D. E. Paquette, Assistint' Superintendent,. Maintenance-l
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- P. L. Barnes, Regulatory Assurance Supervisor
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- E. W. Carroll, Regulatory Assurance.
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- T. W. Simpkin, Regulatory Assurance
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- J.;S. Gosnell, Quality Control Supervisor i
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- t*PJ J. Legner, Senior Operating Engineer-
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( *J. J. Lewis, StarVap Staff, NOVA
/,, *M.'Inserra, TRB Supervisor /PSG
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B. Pal'owitch, Startup Testing Supervisor..
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,*G. Masters, Assistant Superintendent, Operating
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,R. Ewan, System Test Engineer
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'f.sC.Bedford,RegulatoryAssurance
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3.' E. Aker; Radiation Chemistry Supervisor l
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- E! L,. Mart n,. Quality Assurence Supervisor i *L. hobnsonjliester, Quality Assurance
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h r, System. Test Engineer
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J. Lauer, TRB Coordinator j
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\\l Additional staticti technical, operational, and administrative personnel;
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j$ were, contacted by'the inspector during the course of the' inspection,j
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- Denotes those attendfhg the exit' meeting on October 21, 1987.
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ActiononPedous,InspectionItems
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(Close 4 Violation'(457/87021-01(DRS)): 1Thisfitem concerned.three:
violiRicnsoftheBraidwoodStartupManual's.administrativecontrols
's on ccnducting preoperational tests. LIn'each individual case, the 19;ensee corrected the deficient' condition in.an--' acceptable manner.
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The generic corrective acti6n implemented.by the licensee includes:
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training the system test engineers on adherence to administrative
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requirements, and the'. Test Review Board's (TRB): heightened s
responsibility to address and correct administrative concerns.
[6 Subsequently, the in?spector has reviewed several test result
packages and has noticed an ine eased'TRB awareness of 3-administrative reqMrkments. W such,- the' inspector's concerns in.
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this. area'have heed'tdequately u ddressed a'nd~ considers this' item'
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closed.
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(Closed) Open Item (457/87021-03(ORS)):
This item concerned:
preoperational-test BwPT SI-51 test results not.being approved at the time of.the' inspector's review. -Subsequently,;the results were approved byy the licensee :and reviewed by the Linspectoro with no further comments. This item;is considered closed.
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(Closed) Open Item (457/87021-04(DRS)): 'This item concerned preoperational-test BwPT SI-54 test results not-being approved at:
the time of the inspector's review.- : Subsequently, the result's were approved by the licensee 1 and reviewed by the inspector with no-further comments. This item is considered closed.'
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(Closed) Open Item (457/87021-05(DRS)J:. This item concerned j
preoperational test BwPT EF-51 test results not being approved.at
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the time:of'the inspector's review.. Subsequently, the.results were i
approved by the licensee and reviewed.by'the inspector with no further comments. This item is considered closed.
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(Closed) Open Item'(457/87021-07(DRS)):
This. item concerned preoperational test BwPT DG-52 test resulta not being. approved at-the time of the inspector's review.. Subsequently, the results were approved by the' licensee and reviewed'by the' inspector <with no further comments. This item is considered closed, f.
(0 pen) Open Item (456/87025-01(DRS)): This item concerned the.
licensee's need to complete the approval process-on the listed startup' test results.for' review'by the inspector < BwSU RC-31A, RC-33, and NR-34C. test results have been approved by the licensee -
and reviewed by the inspector with no further comments..This item j
will remain open pending approval of the remaining. startup test '
i results addressed in the,openLitem.
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{ Closed)SERItem(457/86000-07)):
Containment Sump Vortex Control.
The licensee has performed BwPT EF-51, "ECCS Full. Flow," which '
demonstrated containment sump design by verifying that-vortexing
will not occur during'the' recirculation phase and being able to-
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maintain an adequate net positive suction head for the residual l
heat removal pumps. The inspector has' reviewed the above test H
and considers this item closed.
No violations or deviations identified.
3.
Preoperational Test Program Implementation Thisreviewwastodeterminewhetheradministrativecontrols'had.been'
developed and implemented to support FSAR commitments, and regulatory requirements.
The inspector.had.the following comment:
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The inspector reviewed the licensee's administrative controls during-I I
witnessing of test performance and reviewing test results.
It appears that the licensee has adequately implemented these controls
in the preoperational test program.
The inspectors have not i
identified any major weaknesses in this area.
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No violations or deviations were identified.
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Preoperational Test Performance
The inspector witnessed the performance of portions of the following l
preoperational test procedures in order to verify that testing was
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'i conducted in accordance with approved procedures, independently verified
the acceptability of test results, and evaluated the performance of l
licensee personnel conducting the tests.
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.I BwPT EF-52, "EF Logic and Time Response" BwPT RP-53, " Reactor Protection Logic Checks" The inspectors had :,o concerns during the performance of the listed tests. The personnei involved followed the test procedure, documented deficient conditions, and correctly implemented test change requests.
l The inspector verified that the test results obtained were in accordance with the test procedure.
No violations or deviations were identified.
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preoperational Test Results Evaluation l
The inspectors reviewed the results of the following preoperational test j
procedures to verify:
all test changes were identified and approved in i
accordance with administrative procedures; all test deficiencies were l
appropriately resolved, reviewed by management and retested as required; I
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, as
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necessary; test packages were reviewed by QA for adequacy of contents; I
and test results were approved by appropriate personnel.
BwPT SI-50, Revision 0, " Safety Injection" BwPT FW-57, Revision 0, " Tempering Flow Test (IHF)"
BwPT FW-58, Revision 0, " Steam Generator Level and Setpoint Verification (IHF)"
BwPT MS-57, Revision 0, " Main Steam, Safety-Related (IHF)"
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BwPT SI-53, Revision 0, " Safety Injection Check Valve' Operability
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andLeckageTest(IHF)"
l BwPT RY-57, Revision 0, " Pressurizer (IHF)"
BwPT MS-50, Revision 0, " Main Steam Isolation Valves'
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BwPT MS-52, Revision 0, " Main Steam PORVs (Safety-Related)"
l The inspectors have the following comments with respect to these i
procedures:
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With respect to BwPT RY-57, acceptance criteria 4.4, which required i
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power relief valve (PORV) 2RY455A to open at 2335 psig, was not met.
The licensee is tracking this item with AIR-R20-87-170 and Retest RY-50-021 will be performed to demonstrate that.the valve is i
acceptable.
In addition, the test results have not been approved l
by the licensee. This will be considered an open item l
(457/87031-01(DRS)) pending completion of Retest RY-50-021 and
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approval of RY-57 test results.
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With respect to BwPT SI-53, check valves 2SI8905A, 2SI8905B, and'
2SI8905C, had leakage greater than the 1 gpm required by the test.
The licensee is reworking the valves and will perform station surveillance 4.6.2.2-1 prior to initial criticality to verify acceptable leakage rates. This item is being tracked by Action Item Record (AIR) R-20-87-171 and will be considered an open item
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(457/87031-02(DRS)) pending successful completion of the l
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In addition, the test results have not been
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approved by the licensee and will be considered an open item (457/87031-03(DRS)) pending licensee approval of SI-53 test results, c.
Braidwood Technical Specification 3.7.1.1 requires the steam line q
safety valves to lift with setpoints-that range from 1235 to 1175 psig, 1%. BwPT MS-57 required the safety valves to lift l
within 10 psig of their setpoint which is within the 1%
tolerance.
The procedures that were performed that verified l
Technical Specification setpoints and adjusted'the settings of the l
safety valves, BwVS 7.1.1.1-1 and BwMP 3305-T033, allowed for a (A-D)psig tolerance.(1190 psig) and MS017 (A-D)- (1175'psig); this tolerance
For the lower setting safety valves, MS016A slightly outside the 1% allowed by Technical Specifications. The
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l only valve on Unit 2 not meeting Technical. Specifications, but meetirg the surveillance, was 2MS017A (1187 psig).
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also reviewed the Uait.1 surveillance and found that all of the valves met the 1% tolerance.- The licensee has stated that the BwVS and BwMP setpoint tolerances will be changed to agree with Technical
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Specifications. This will be considered'a.n unresolved itsm.
o (456/87032-01(DRS); 457/87031-04(DRS)) pending licensee action
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on 2MS017A.and' approval.of procedure changes. Due to. procedure q
similarities, tho Byron Senior Resident Inspector _wa's notified.of
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this procedure error.
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With respect to BwPT MS-52, it was noted that Test. Deficiency MS-52-46 had been initiated to address instrument 2PK-MS0448 being a different model than thet specified.. Instruments 2PK-MSO448;isi q
a M/A station located on panel 2PLO4J on_the Remote Shutdown Panel.
MS-52-46-also specified further testing w s required for closure oft d
the deficiency once the correct M/A stction was installed. "Additi~nally, J
o at tha time of the inspector's review, the tast 'results' had not been approved. This is. considered an.open ' item (457/87031-05(DRS)):pending licensee approval of MS-52 and. inspector review of.the Test Deficiency:
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and its final resolution.
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The licensee has not approved the BwPT FW-58 completed; test results
package. The inspector cannot complete 3the review'until. licensee-o resolution and approval of all identified concerns.
This is considered an open item (457/87031-06(DRS)) pending review of an-approved test results package by.the' inspector, f.
The licensee has not approved the BwPT MS-57-completed test results a
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package. The inspector cannot comple'te the review unti1~1icensee
resolution and approval of all'identifled concerns. This is'
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considered an open item (457/87031-07(DRS)) pending review of an approved test results package by'the inspector..
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The licensee has not approved the BwPT MS-50 completed. test results
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l package. The inspector cannot complete the-review.until licensee resolution.and approva14of all identified concerns.,'This is
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considered an open item (457/87031-08(DRS)) pendin'g' review:of an,
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The licensee has not approved.the BwPT SI-50 completed test resultsL
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package. The inspector cannot complete-the. review until licensee i
resolution and approval of all identified concerns.' LThis is considered an_open item (457/87031-09(DRS)) pending review of an~
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approved test results package by:the inspector.
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The licensee has not approved the BwPT FW-57 completed' test results l
package. The inspector cannot complete the review until;1icensee-
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resolution and approval of all identified concerns. -This is-l considered an open item (457/87031-10(ORS))rpending' review of.an-approved test results package by tha inspector.
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n No violations or deviations were identified.
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Preoperational Test Results Verification The inspectors reviewed the following preoperational test procedures and
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verified that results were reviewed against approved acceptance criteria
and that an evaluation of the test results had been performed in
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accordance with Regulatory Gaide 1.68 and the licensee's Startup manual:
BwPT VD-50, Revision 1, " Diesel Generator Ventilation" BwPT DG-50, Revision 0, " Diesel Generator 2A" BwPT DG-51, Revision 0, " Diesel Generator 2B"
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BwPT LM-57, Revuton 0, " Reactor Loose Parts Monitor for IHF"'
BwPT SX-50, Revision 0, " Essential Service Water" q
BwPT VA-50, Revision 0, " Auxiliary Building Ventilation Cubicle l
Coolers"
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l BwPT IP-50, Revision 1, " Instrument & Control Power and' Retest
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BwPT CS-50, Revision 0, " Containment Spray" The inspectors have the following comments with respect to these l
procedures:
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With respect to BwPT VA-50, the cubicle cooler flow rates in many cases did not mest the expected value. The licensee intends to perform a Component Demo, Number 017, to retake the flows..In addition, at the time of the inspector's review, the test results had not been approved. This will be considered an'open item (457/87031-11(DRS)) pending final approval of the test r~asults and component demo, and review by the inspector, b.
With respect to BwPT SX-50, additional testing (retest 10).needs to be performed on measuring component flow using the weaker SX pump and on valves that were under construction at the time of the test.
This will be considered an open item (457/87031-12(ORS)) pending completion of this retest and review by the inspector, c.
The licensee has not approved the BwPTs VD-50, LM-57, IP-50, and CS-50 completed. test results packages.
1he inspector cannot-complete the review until licensee resolution and. approval of all identified concerr,s. This is considered an open item'
t (457/87031-13(DRS)) pending review of approved test results packages by the inspector.
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With respect to BwPT CS-50, the inspector noted that at steps 9.19.19 and 9.20.19, the " Indicated Spray Additive Flow Rate" was-corrected to an apparent actual f'ow rate value by multiplying the indicated values obtained from 2FI CS015 and 2FI-CS016 (for Trains A and B respectively) by 1.14.
The question as to the reason for this correction factor was addressed to the licensee's Project Startup Group (PSG). The PSG responded by stating that this correction factor was included to address the change in pressure drop across the flow orifice for each of the above instruments to account for
the difference between measuring demineralized water flow during i
testing and actual flow of 30% Na0H solution. 'The licensee was i
subsequently requested to provide the calculational basis and/or i
vendor information that supported this position. This is considered
an unresolved item (456/87032-02(DRS); 457/87031-14(DRS)) pending l
inspector review of the requested information.
i e.
With respect to BwPT DG-50 and BwPT DG-51, the inspector noted the following:
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l (1) Test Deficiencies DG-50-107 and DG-51-76 had been written to document that Component Demonstrations No. 151 and 152 had not been successfully completed to date. These tests are in place to properly demonstrate the operation of Diesel Generators 2A and 28 normal / isolation witches.
Retest requirements were l
specified ln both deficiencies.
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(2) Test Deficiencies DG-51-79 and DG-51-80 had been initiated to investigate and, if',;ecessary, repair certain gasket leaks on i
Diesel Generator 28. A retest requirement was specified in
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(3) Test Deficiency DG-51-83 had been initiated to check and l
replace defective lugs in panel 2PLO8J. A requirement for l
retest was specified.
After these Test Deficiencies are properly yesolved and closed by
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the licensee, the inspector will perform a subsequent acceptance review. Until that time, these will be tracked as an open item l
(457/87031-15(DRS)).
l No violations or deviations were identified.
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Startup Test Procedure Review l
l The inspectors reviewed the below listed startup test procedures against.
I the Final Safety Analysis Report (FSAR), Safety Evaluation Report, applicable Regulatory Guides and Standards, and portions of 10 CFR 50.
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BwSU FH 70, Revision 0, " Initial Core Load Sequence"
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BwSU NR-71, Revision 0, " Initial Criticality" BwSU IT-71, Revision 0, " Power. Coefficient Determination" BwSU RY-70, Revision 0, " Pressurizer. Sprays, Heaters, and Bypass Flow Adjustments" BwSU IT-70, Revision 0, " Isothermal Temperature Coefficient Measurement" BwSU FH-72, Revision 0, " Initial Criticality & Low Power Test
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Sequence" BwSU IC-71, Revision 0, "Incore Flux Mapping at. Low Power"
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a.
The test procedures have not been Project Engineering Department l
(PED) approved at the time of the inspectors review. The inspector will review any changes that occur to these procedures upon PED approval.
l b.
The inspectors review of the startup test procedures revealed j
several typographical errors and _ missing figures, but no _ major i
concerns.
In BwSU IT-70, the licensee changed a FSAR commitment in that the isothermal temperature coefficient will be determined from a three degree temperature change instead of the five degree change called for in Table 14.2-77.
The licensee stated Amendment 48 to the FSAR describes this change.
At this time, the. residence office l
does not have a copy of this amendment. The inspector has contacted NRR and determined that the change in the startup test program _had previously been requested by the. licensee and approved by NRR.
No violations or deviations were identified.
8.
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; test results were evaluated by appropriate engineering personnel and specifically compared with acceptance criteria; data was properly
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l recorded, signed, dated and documented as test deficiencies if out of tolerance, and test results were approved by appropriate personnel:
Post Core Load Pre-Critical
BwSU FH-31, " Post Core Loading Precritical Test Sequence"
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q Initial Criticality and Low Power T'st Sequence I
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BwSU NR-31, " Initial Criticality"
- BwSU FH-32, " Initial Criticality & Low Power Test Sequence"-
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- BwSU IT-30, " Isothermal. Temperature Coefficient Measurement" (All j
Rods Out), (Control Bank D In), (Control Banks.C & D
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BwSU NR-32, " Determination of Core Power Range for Low Power
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Physics Testing"
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30% Power Test Sequence l-
- BwSU IT-31, " Power Coefficient Determination" q
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- Denotes those procedures for which final Project Engineering.
l Department -(PED) approval has not been received.
This will be.
considered an open item (456/87032-03(DRS)) pending inspector'
receipt and evaluation.
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The inspectors review of the aoove listed procedures' produced no major l
concerns. All comments were adequately addressed by the licensee.
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No violations or deviations were identified.
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Startup Test Results Verification The inspectors reviewed the.following'startup test procedures and
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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 LStartup Manual:
Initial Core Load Test Sequence
.l BwSU PS-30,'" Reactor Systems Chemical Sampling for CoresLoad" Post Core Load Pre-Critical
- BwSU FW-33A, " Main Feedwater (Performance Verification of Water
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Hammer Prevention System Upper Nozzle)"
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- Denotes the procedures for which final PED approval has not been.
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received. This will be considered a portion of open. item 456/87032-03(DRS).
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With respect to BwSU PS-30, the inspector.noted that PED's memo, dated March 13, 1987, addressed a concern that a' requirement to sample boron concentration every four hours had been exceeded a number of times during
'the performance of the procedure.
The memo further stated that this sampling frequency was specified in the Final Safety Analysis Report (FSAR)
Table 14.2-62 and, as such, should be assessed if this was a change to the startup test program which is reportable in accordance with the operating license.
The licensee subsequently performed an evaluation into the ramifications of the late samples with the resolution documented in Section 12.0 of the procedure as part of the " Test Evaluation" review.
However, a Test Deficiency was not initiated to document that the required sampling interval was ' exceeded. Moreover, no documentation was made as,
to the determination (cr the basis) for not treating this issue as a change to the test program,.and therefore, resolve the question of
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deportability to the NRC.
This indicates an example of an apparent weakness in implementation of the Test Deficiency program as specified in the Braidwood Startup Manual.
Pursuant to this area of concern, a violation has already been written in j
50-457/87024(DRS))pection report (reference Report No. 50-456/87025(DRS);
a previous NRC ins
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l No violations or deviations were identified.
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10. Open Items
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l Open iteras are matters which have been discussed with the licensee, which l
l will be reviewed by the inspector and which involve some action on the
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part of the NRC or licensee or both.
Open items disclosed during the
inspection are discussed in Paragraphs 5.a, 5.b, 5.d, 5.e, 5,f, 5.g', 5.h,
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solv d I m Unresolved items are matters about which more information is required in
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order to ascertain whether they are acceptable items, violations, or deviations. Unresolved items disclosed during the inspection are discussed in Paragraphs 5.c and 6.d.
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12.
Exit Interview l
The inspectors met with licensee and contractor representatives denoted in-j Paragraph I during and at the conclusion of the inspection on October 21 j
1987. The inspector summarized the scope and results of the inspection j
and discussed the likely content of this inspection report.
The licensee
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acknowledged the information and did not indicate that any of the l
information disclosed during the inspection could be considered i
proprietary in nature.
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