IR 05000456/1987042

Safety Insp Repts 50-456/87-42 & 50-457/87-41 on 871025- 1201.Violations Noted.Major Areas Inspected:Util Action on Previously Identified Items,Operational Safety Verification, Radiological Protection,Esf Sys & Physical Security

ML20237C129
Person / Time
Site:	Braidwood
Issue date:	12/12/1987
From:	Hinds J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20237C119	List: IR 05000456/1987042 IR 07100025/2012001 ML20237C117
References
50-456-87-42, 50-457-87-41, NUDOCS 8712210052
Download: ML20237C129 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report Nos. 50-456/87042(DRP);50-457/87041(DRP)

Docket Nos. 50-456; 50-457 License Nos. NPF-72; CIPR-133 Licensee: Coninonwealth Edison Company Post Office Box 767 Chicago, IL 60690 l Facility Name: Braidwood Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, Illinois Inspection Conducted: October 25 through December 1, 1987 Inspectors: T. M. Tongue T. E. Taylor Approved B J . Hinds, Chief it iz.87 Reactor Projects Section 1A Date Inspection Sununary Inspection from October 25 through December 1, 1987 (Report No /87042(DRP); 50-457/87041(DRP))

Areas Inspected: Routine, unannounced safety inspection by the resident inspectors of licensee action on previously identified items; an event involving the manipulation of reactor controls by an unauthorized individual; Unit 2 fuel load preparation; Unit 2 fuel receipt, inspection, and storage; Unit 1 startup test observation; operational safety verification; radiological protection; engineered safety feature (ESF) system; physical security; monthly maintenance observation and modification installations; monthly surveillance observation; Unit 2 plant tour; operational staffing inspection; training effectiveness; report review; and meetings and other activitie Results: Of the 16 areas inspected, no violations were identified in 1 In the remaining area ene violation was identified regarding the manipulation of reactor controls by an unauthorized individual (Paragraph 3).

8712210052 871212 PDR ADOCK 05000456 0 DCD

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DETAILS

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1. Persons Contacted Commonwealth Edison Company T. J. Maiman, Vice President

• J. Wallace, Manager of Projects and Construction Services

• L. Shamblin, Project Manager

• E. E. Fitzpatrick, Station Manager

• E. Vahle, Construction Superintendent C. W. Schroeder, Station Services Superintendent

• K. L. Kofron, Production Superintendent L. E. Davis, Assistant Superintendent - Technical Services B. Byers, Assistant Construction Superintendent

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M. Lohman, Project Startup Superintendent P. Cretens, Station Startup Assistant Superintendent

• F. Willaford, Security Administrator

• B. M. Saunders, Corporate Nuclear Security Administrator

• D. E. Paquette, Maintenance Assistant Superintendent

• D. E. O'Brien, Services Superintendent E. L. Martin, Quality Assurance Superintendent

• S. C. Hunsader, Nuclear Licensing Administrator

• E. Lohmann, Project Startup Superintendent

• R. E. Benn,. Assistant Security Administrator G. E. Groth, Project Field Engineering Manager

• P. L. Barnes, Regulatory Assurance Supervisor

• M. Takaki, Regulatory Assurance J. Gosnell, Quality Control Supervisor R. E. Aker, Radiation / Chemistry Supervisor J. Jasnoz, Technical f taff AR/PR Coordinator R. Lemke, Technical Staff Supervisor

• G. R. Masters, Assistant Superintendent Operations

• G. W. Nelson, Assistant Technical Staff Supervisor

• E. R. Netzel, Quality Assurance Supervisor

• M. Orlov, Staff Assistant to Project Manager

• D. J. Skoza, Field Engineering Supervisor P. G. Holland, Regulatory Assurance

• T. W. Simpkin, Regulatory Assurance Operating Experience Group

• R. C. Bedford, Regulatory Assurance

• R. D. Kyrouac, Quality Assurance Superintendent L. Kline, Regulatory Assurance Industry Group

• L. W. Raney, Onsite Nuclear Safety Supervisor R. J. Ungeran, Operating Engineer Unit 1 R. Yungk, Operating Engineer R. J. Legner, Lead Operating Engineer R. Mertogul, Tech Staff T. O'Brien, Technical Staff S. Hedden, Master, Instrument Maintenance R. Hoffman, Master, Mechanical Maintenance

• J. E. Smith, Master, Electrical Maintenance

• W. McGee, Training Supervisor

• A. J. Iturrieta, Operational Analysis Department Supervisor l B. Tanouye, Project Construction Department

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A. J. D' Antonio, Quality Control D. H. Schavey, Training l E. Carroll, Regulatory Assurance

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• G. A. Schieberl, Maintenance Training Group Leader

• D. Huston, Lead Instructor

• R. Milne, Security Maintenance Coordinator

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• S. M. Jaquez, Nuclear Materials Custodian

• F. D. Bevington, Quality Assurance Inspector

• R. W. Jacobs, Electrical Maintenance Foreman

• T. M. Bandura, Quality Assurance Inspector i

l Westinghouse i

• W. P. Poirier, Site Project Manager NRC - RIII

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

• J. M. Hinds, Chief, Reactor Projects Section 1A

• R. M. Lerch, Reactor Engineer

• Denotes those attending the exit interview conducted on October 30, November 5, 13, 18, December 1, 1987 and at other times throughout the inspection period.

. The inspectors also talked with and interviewed several other licensee l employees, including members of the technical and engineering staffs,

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startup engineers, reactor and auxiliary operators, shift engineers and foremen, electrical, mechanical and instrument maintenance personnel, j

contract security personnel, and construction personne . Licensee Action on Previously Identified Items l

l Unresolved Item (Closed) Unresolved Item 457/83015-02: Reactor Containment Fan (RCFC) Cooling Fins. The cooling fins of the Unit 2 RCFCs were inspected for damage similar to that caused by construction scaffolding in Unit 1. The inspectors' review did not identify any cooling fin damage which appeared to be deleterious to operation of the Unit 2 RCFC units. This item is considered closed, CFR 50.55(e)

i (Closed) 457/85005-EE: High energy line breaks in the auxiliary l building. The licensee has completed the necessary Unit 2

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installations to automatically isolate the steam generator blowdown !

(SD) and auxiliary steam (AS) systems in the event of a pipe rupture.

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The inspector reviewed applicable installation drawings and verified that components are installed per the drawings. The inspector also

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verified that applicable surveillance have been generated for the I periodic calibration of the SD temperature switches. This item is

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considered closed.

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. Safety Evaluation Report (SER)

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(Closed) SER 457/86000-20: 125V DC Bus Tie Breakers. On October 15, 1987, the 125V DC bus tie breakers were inspected and found locked open as required. The access key "G2A" identified on the padlocks was also checked. The G2A key is controlled by the Shift Control Room Engineer (SCRE). Administrative procedures are in place which provide control of the key usag This item is considered closed, i

No violations or deviations were identifie . Manipulation of Reactor Controls by an Unauthorized Individual On October 19, 1987, the licensee's station management received evidence that an individual not licensed at Braidwood had manipulated the controls l of the Braidwood Unit i reactor on September 20, 1987, resulting in l reactivity changes. At the time, the reactor was in Mode 1 at 34%

power; however. the reactivity changes, a planned boron dilution and

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associated control rod movement, were small and did not change the indications of the power level meters. These actions were performed under the direct observation of two licensed operator The individual in question held a cold license, Senior Reactor Operator (SR0), on a similar facility (Commanche Peak) and was not part of an exempted training program (hot participation). He was one of a group of individuals from another utility who were working under contract as equipment attendants only during the Unit 2 preoperational testin Based on interviews with Braidwood personnel, contract individuals frequently observed Unit 1 activities as an implied truining exercis The operators interviewed at Braidwood knew that the individual held l an SRO license, and he had approached them on several occasions in an effort to perform any activities that might take plac During the same time frame, another individual from the same utility in an approved training program had come to Braidwood to perform his hot functional training as part of his SR0 licensing progra On September 20, 1987, the individual in question approached the licensed operators at Unit 1 and requested permission to perform any activities that might take place. One of the licensed Nuclear System Operators (NS0s)

stated that he had obtained permission from the SCRE; however, the SCRE could not recall the event. The individual then performed the activities with one NSO observing at his side and another observing from about 10 feet away. When the activities were completed, he filled out a training record fnrm that was signed by one of the NS0s. A copy was provided to the senior resident inspector in October. Discussions with the NS0s revealed that they were apparently misled by the previous trainee's

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activities and that no formal guidance was provided on how to adminis-tratively control this sort of activity.

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l, 4 + S-subsequently, the licensee published a memo listing the individuals who i' were exempted under 10 CFR 55.13 to manipulate the controls without a license. The licensee has also. committed to provide a mechanism to-update the memo periodicall The unauthorized manipulation of the reactor controls by an individual L not licensed at the facility is a violation of 10 CFR 50.54(1) when the individual is not part of an approved training program pursuant to 10 CFR 55.13. In addition, 10 CFR 55.53 limits each operator and senior operator license to the facility for which it is issued

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(456/87042-01(DRP)). '

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The Braidwood management was informed of the event on October 19, 1987, L via telecon and-fax from the contracting utility. The licensee conducted

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a partial investigation and then verbally informed the resident

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inspectors on October 27, 1987.

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A period of eight days to inform the resident inspectors appears excessive, especially when the issue has a potentially high profile or has the possibility of enforcement action. In addition, the SCRE could not recall the event and had not been interviewed as ) art of the licensee's _ investigation when he was interviewed by tie senior _ resident l- inspector on October 30, 1987. This information was relayed to the i senior station management during a routine informal exit meeting on November 5, 198 The individual in question and his-motives were not reviewed as part of

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this evaluation and will be pursued through other channels in the NR . Unit 2 Fuel Load Preparation

During the inspection period, the inspectors reviewed a number of items

'- in preparation for licensing (fuel load preparation). The inspection activities included inspection of various Unit 2 systems, components, and plant areas such as emergency core cooling systems, the reactor coolant system, the auxiliary building, containment, and the fuel building.

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The inspectors also reviewed several items pertaining to inspection modules, SERs, Three Mile Island action items, and other open items required to be completed or resolved for fuel load. The items that were completed during this report period are documented elsewhere in this report. The items that were in various states of readiness will be closed out in future reports as they are completed by the licensee and accepted by the assigned inspectors. The licensee fuel load check list is approximately 46% complete. Two deferral letters have been submitted to the NRC for the Unit 2 license. The licensee's projected window for '

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fuel load licensing is December 11 to December 18, 1987. The licensee's '

fuel load projection may be affected by Region III acceptance or i

rejection of the deferral letters, i l

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5. Unit 2 Fuel Receipt, Inspection, and Storage During the inspection period, the final shipments of new fuel for Unit 2 were received by the licensee. The inspector selected a sample of shipments ard verified that the licensee had appropriate documentation and record control, e.g. shipping documents, Department of Transportation and NRC required documents, and Quality Assurance document The inspectors also monitored the licensee's receipt of a sample of the fuel shipments for shipping container external damage, security integrity, shock indicator integrity, and loose material or part The inspectors also monitored the opening of some of the containers, initial fuel inspection, handling, radiation controls, cleanliness

control, and storage of the fue No violations or deviations were identifie . Unit 1 Startup Test Observation The inspectors witnessed performance of the following Unit 1 startup test procedures in order to verify that testing was conducted in accordance with the operating license and procedural requirements, that test data was properly recorded, and that performance of licensee personnel conducting the tests (amonstrated an understanding of assigned duties and responsibilities

BwSU TG 32, Test Sequence at 75% Power (portions observed)

BwSU IC 32C, Incore Moveable Detector and Thermocouple Mapping at Power (Quarter Core)

No violations or deviations were identifie . Operational Safety Verification The inspectors conducted routine plant tours during the inspection period to make an independent assessment of equipment conditions, plant conditions, construction activities, security, fire protection, general personnel safety, housekeeping, and adherence to applicable regulatory requirements. During the tours, the inspectors reviewed various logs and daily orders, interviewed personnel, attended shift briefings and plan of the day meetings, witnessed various construction work activities, and independently determined equipment status. During the shift changes, the inspectors observed operator, shift control room engineer, and shift engineer turnovers and panel walkdown These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under i technical specifications, 10 CFR, and administrative procedure No violations or deviations were identifie !

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. Radiological Protection The inspectors selected portions of the licensee's radiological program to verify conformance with facility policies, procedures, and regulatory requirements. Observed aspects included the health physics managers'

awareness of any unusual conditions or challenges, the impleinentation of the ALARA program, the use of Radiological Work Permits (RWPs), the control and monitoring of radiation exposures, including work in high radiation areas if applicable, and the control of radioactive materia No violations or deviations were identifie . Engineered Safety Feature (ESF) Systems During the inspection, the inspectors selected accessible portions of several ESF systems to verify their status. Consideration was given to the plant mode, applicable Technical Specification Limiting Conditions for Operating Action Requirements (LC0ARs), and other applicable requirement Various observations, where applicable, were made of hangers and supports; housekeeping; whether freeze protection, if required, was installed and operational; valve positions and conditions; potential ignition sources; major component labeling, lubrication, cooling, etc.;

interior conditions of electrical breakers and control panels; whether instrumentation was properly installed and functioning and significant process parameter valves were consistent with expected values; whether instrumentation was calibrated; whether necessary support systems were operational; and whether locally and remotely indicated breaker and valve positions agree During the inspection, the following ESF systems / components were walked down:

Unit 1 Remote Shutdown Panel and Associated Support Equipment Portions of 4160 and 480-Volt ESF Electrical Panels No violations or deviations were identifie . Physical Security At various times throughout the inspection period, tne inspectors i monitored ccmpliance with the Physical Security Plan (PSP). Observations were made of selections of manning levels and collateral duties of l assigned personnel; access control equipment and processes, such as x-ray

! machines, metal detectors, explosive detectors, and other search mechanisms; whether protected area (PA) and vital area (VA) barriers

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were properly maintained; whether procedures were properly followed; whether compensatory measures were appropriately used when required;

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k whether persons in the PA and VA were properly badged and escorted if required; whether various detection / assessment aids, such as fences a.V illumination of the PA, were operable; and whether TV monitors had sufficient clarity and resolutio No violations or deviations were identifie . Monthly Maintenance Observation and Modification Installations Station maintenance activities affecting 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 Specification The following items were considered during this review: the limiting conditions for operation were met while components or systems were removed from and restored to service; approvals were obtained prior to initiating the work; activities were accomplished using approved

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procedures and were inspected as applicable; functional testing and/or

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calibrations were performed prior to returning components or systems to l service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and fire prevention controls were implemented. Work requests were reviewed to determine the status of outstanding jobs and to assure that priority is assigned to safety-related equipment maintenance which may affect system performanc Maintenance activities on the following equipment were observed and reviewed:

Unit 1 1A Emergency Diesel Generator - Injector Replacement l Following completion of the maintenance, the inspector verified that the i diesel generator had been returned to service properl During the inspection period, the licensee determined that modifications were required for the following areas: ]

Process Radiation Monitor and Area Radiation Monitor Equipment Skids The inspectors monitored the licensee's work in progress and verified that it was being performed in accordance with proper procedures, approved work packages, that 10 CFR 50.59 and other applicable drawing updates were made and/or planned, and that operator training was conducted in a reasonable period of tim No violations or deviations were identified, f

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12. Monthly Surveillance Observation (

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The inspectors observed surveillance testing required by technt al y specifications for Unit I during the inspection periad and verified that . '

testing was performed in accordance with adequate procec:ures, that test <

instrumentation was calibrated, that limiting conditions for operat on - ,

were met, that removal and restoration of the affected components w,*e accomplished, that results conformed with technical specifications and t procedure requirements and were reviewed by personnel other than the /p individual directing the test, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate j management personne ,,

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l The inspectors witnessed portions of the following test activiths': \ f, i

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Bw0P IC3, Rev. 51, "Incore Moveabin Detectors Flux Mapping - t j Procedure" 'D \

l BwVS 3.2.1-16, " Analog Operational Test and Channel c Verification / Calibration for Loop P-054"

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No violations or deviations were identifie '

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13. Unit'2 Plant Tour #

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Theinspectorobservedworkactivitiesinprogress,completedwork'and'l,f \t plant conditions during general inspections in Unit 2 work area >

Observed items included cable trays, junction boxes, pipe support j welding, and mechanical equipment. Particuhr attention was given to material identification, nonconforming material,. identification, and ,f I{q housekeeping. The inspector reviewed work activities by reviewing ., ,

travelers while touring the plant. These travelers pertained to e electrical, piping, and hanger installatio No violations or deviations were identifie '

14. Operational Staffing Inspection ~o '

The Unit 2 " Operational Staffing Inspection" identified that the dnit's staffing is adequate in number and personnel qualifications. Braidwood e is a two-unit facility; therefore, most of the administrative and/s o technical personnel contribute to the operation and maintenance of <

both units. The similar Unit 1 inspect'on completed priort+o Unit I fuel load determined that staffing was adequate, as p cumented  !

in Inspection Report No. 456/86050. Fersonnel qualificatip s for individuals with Unit 2 only posit wns were reviewed and fu nd to be 3, acceptable relative to ANSI 18.1 requirements. Some positions previously v reviewed during the Unit 1 inspec'. ion have been vacated and restaffed f with competent, qualified personocl. The licensee continues to maintain a '

training program which assures that personnel receive the required 'l training applicable to their assigned positions. This itent b considerp  !

closed for Unit J s s

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10 violath P; or deviations were identifie ,i

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1 ;ihiningEffectiveness

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The effectiveness of training programs for licensed ano neWicensed

, personnel was reviewed by the inspectors during the witnessing of the licensee's p rformance of routine surveillance, maintenance, and operationa W tivities and during the review of the licensee's response to event 9 nb1ch ocep.irred during the inspection period. Personnel f

< appeared to br{ knowledgeable of tha tas b being performed, and nothing A , 'vas obs.irts vnkb indicated any ineffe.tiveness of trainin No violaticas or deviatitris were identified, li. ' Report B.O. e

During thed.:spect?on period, the inspector reviewed the licensee's Monthly Operating Report for October 1987. The inspector confirmed that ;

the information provided met the requirements of Technical Specification 6.9.1,3 and Regulatory Guide 1.1 The inspector also reviewed toe lkensee's Monthly Plant Status Report for Oc'tcher.198 \ No violations or deviations were identifie l 17. Meetings _and ther Activities l Plant Stc r.us Meeting

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A meeting was held on Novaber 11, 1987, at the Braidwood Station, I between the' $ cation ?dnager the licensec's Project Manager, the Region V/.1 Director of Reactor Projc: cts , anc members of each of their staff '$ Abe purpose of the meeting was for the licensee to provide an update on

/ the status of Unit 2 in preparation for licensing and a brief status J report on Unit '1 Exit Interview The inspectors met with the licensee and contractor representatives

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, denoted in paragraph I during the irspection period and at the conclusion

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of the nspection on December 1, 19E7. The inspectors summarized the i scope and results of the inspection and discussed the likely content of this inspection report. The licensee ad:nowledge? tLe information and did not indicate that any of the information disci ased during the

, inspection could be considen d prcgrietary in natur t t

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