IR 05000456/1987044

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Insp Repts 50-456/87-44 & 50-457/87-45 on 871202-31. Violations Noted.Major Areas Inspected:Operating & Emergency Procedures,Ser,Operational Safety Verification,Radiological Protection,Esf Sys,Physical Security & Mod Installations
ML20148S190
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 01/28/1988
From: Hinds J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20148S102 List:
References
50-456-87-44, 50-457-87-45, NUDOCS 8802020358
Download: ML20148S190 (18)


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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report Nos. 50-456/87044(DRP); 50-457/87045(DRP)

. Docket Nos. 50-456; 50-457 License Nos. NPF-72; CPPR-133/NPF-75 Licensee: Commonwealth Edison Company Post Office Box 767 Chict.go, IL 60690 Facility Name: Braidwood Station, Units 1 and 2 Inspection At:

Braidwood Site, Braidwood, Illinois Inspection Conducted:

December 2 through December 31, 1987

  • spectors:

T. M. Tongue n

T. E. Taylor J. M. Ulie T. J. Ploski M. M. Holzmer G. A. Van Sickle

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Approved By J

M. Hinds, Jr.,

ief ca.28 88 Reactor Projects Section 1A Date Inspection Summary Inspection from December 2 through December 31, 1987 (Report Nos.

50-456/87044(DRP); 50-457/87045(DRP))

Areas Inspected: Routine, unannounced safety inspection of licensee action on previously identified items; licensee event report (LER) review; Unit 2 operating license issuance; Unit 2 fuel load and core sequence; carbon dioxide suppression systems; operating procedures; emergency procedures; Title 10 l

requirements; safety evaluation report review and followup; sump screen evaluation; operational safety verification; radiological protection; engineered i

safety feature (ESF) systems; physical security; monthly maintenance observation and modification installations; monthly surveillance observation; Unit 2 plant t

tours; training effectiveness; report review; and plant status meeting.

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Results: Of the twenty areas inspected, no violations were identified in eighteen.

In the remaining areas, two violations were identified regarding failure to perform required preventive maintenance (Paragraph 2.b) and failure to provide instructions appropriate to circumstances for plant emergency operations (Paragraph 9).

8802020358 880128 PDR ADOCK 05000456 G

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DETAILS 1.

Persons Contacted Coninonwealth Edison Company (Ceco)

  1. + T. J. Maiman, Vice President

+ K. L. Graesser, General Manager of PWRs

  1. + M. J. Wallace, Manager of Projects

+ D. L. Shamblin, Project Manager

S. Hunsader, Nuclear Licensing Administrator

P. Laird, Director, Corporate Security

J. L. Roulo, Senior Nuclear Security Specialist

J. J. Galligan, Offsite Review, Nuclear Safety

+*E. E. Fitzpatrick, Station Manager

+ W. E. Vahle, Construction Superintendent

+*D. E. O'Brien, Services Superintendent

  1. + K. L. Kofron, Production Superintendent

+*L. E. Davis, Assistant Superintendent - Technical Services B. Byers, Assistant Construction Superintendent

+*M. W. Lohman, Project Construction and Startup Superintendent P. Cretens, Station Startup Assistant Superintendent

F. Willaford, Security Administrator

  • D. E. Paquette, Maintenance Assistant Superintendent E. L. Martin, Quality Assurance Superintendent R. Benn, Assistant Security Administrator G. E. Groth, Project Field Engineering Manager

+*G. R. Masters, Assistant Superintendent, Operations

  1. +*P. L. Barnes, Regulatory Assurance Supervisor
  • J. S. Gosnell, Quality Control Supervisor R. E. Aker, Radiation / Chemistry Supervisor J. Jasnoz, Technical Staff AR/PR Coordinator R. Lemke, Technical Staff Supervisor G. W. Nelson, Assistant Technical Staff Supervisor E. R. Netzel, Quality Assurance Supervisor

+ G. M. Orlov, Staff Assistant to Project Manager P. G. Holland, Regulatory Assurance

+*T. W. Simpkin, Regulatory Assurance Operating Experience Group

  • R. C. Bedford, Regulatory Assurance
  • M. Takaki, Regulatory Assurance

+*R. D. Kyrouac, Quality Assurance Supervisor

  • L. M. Kline, Regulatory Assurance Industry Group

+ L. W. Raney, Nuclear Safety

  • R. J. Ungeran, Operating Engineer, Unit 1
  • R. Yungk, Operating Engineer, Unit 1
  • R. J. Legner, Lead Operating Engineer
  • T. C. Meyer, Station Fire Marshal
  • W. B. McCue, Operating Engineer R. Hertogul, Tech Staff T. O'Brien, Tech Staff

S. Hedden, Master, Instrument Maintenance R. Hoffman, Master, Mechanical Maintenance

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J. Smith, Master, Electrical Maintenance W. McGee, Training Supervisor

+. A. Iturrieta, Project Operational Analysis Department (P0AD)

Field Supervisor B. Tanouye, Project Construction Department (PCD)

A. J. D' Antonio, Quality Control D. H. Schavey, Training

  • E. W.: Carroll, Regulatory Assurance
  • M. Teras, PCD Assistant Supervisor
  • E. Wendorf, PCD Electrical Supervisor
  • D. J. Skoza, Site Field Engineering (SFE) Supervisor
  • J. L. Woldridge, Tech Staff
  • J. Roth, Tech Staff
  • C. Boydstun, Tech Staff Viking-Fire Protection Company

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D. Crawley, Test Representative P. Crawley, Test Representative Westinghouse D. R. Wasson, Startup Engineer

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+ D. Muller, Project Director

+ S. Sands, Project Manager NRC - RIII

  1. + C. J. Paperiello, Deputy. Administrator
  1. + C. E. Norelius, Director, Division of Reactor Projects
  1. + W. Forney, Chief, Reactor Projects Branch 1
  1. + J. Hir.ds, Chief, Reactor Projects Section IA
  1. + R. Lerch, Reactor Engineer, Reactor Projects Branch 1

G. Van Sickle, Project inspector, Reactor Projects Section 1A

G. Pirtle, Physical Security Inspector

  • Denotes those attending the exit interviews conducted on December 10, 17, and 22, 1987, and January 5,1988, and at other times throughout

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the inspection period.

+ Denotes those attending the meetings and plant tours on December 2 and/or December 16, 1987.

  1. Denotes those attending the licensee meeting on December 14, 1987.

The inspectors also talked with and interviewed several other licensee employees, including members of the technical and engineering staffs, startup engineers, reactor and auxiliary operators, shif t engineers and foremen, electrical, mechanical and instrument maintenance personnel, contract security personnel, and construction personnel.

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2.

Licensee Action on Previously Identified Items a.

Open Items (92701)

(Closed) 457/85032-01:

Polar crane bolting discrepancies. The inspector reviewed licensee documents relative to verification of polar crane bolting and crane installation.

Records reviewed were the structural steel installation traveler, verification of materials, field testing of structural bolts, the bolting inspection request, and polar crane structural drawings.

The inspector's review identified no discrepancies or additional concerns. This item is considered closed.

(Closed) 456/86045-08: According to the Braidwood Safety Evaluation Report Stipplement (SSER) No. 2, the licensee committed to seal gaps and openings in the steel hatch covers with fire resistive caulk.

The inspector visually inspected the hatchways at elevation 426',

column Q-12, and elevation 364', column N-28.

No unsealed gaps or

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openings were observed.

As described in SSER No. 2, the sealing of the hatchways protects against the vertical spread of smoke and hot gases.

Discussions between the NRR fire protection reviewer and the inspector determined that Dow Corning Product No.96-081 RTV, which was used to caulk the small unsealed gaps and openings, was satisfactory for this purpose.

(Closed) 457/86033-04:

The licensee comitted to upgrade the wall between the redundant residual heat removal (RHR) pumps to one having a one and one-half hour fire rating.

According to discussions held during this inspection between the licensee's fire protection engineer and the NRC resident inspectors, the upgrading of the wall between the redundant RHR pumps specifically entailed sealing any unsealed penetration openings with fire rated barriers.

The inspectors' review of Fire Protection Report drawings and a visual observation of the wall at the 343' level between the RHR pumps (for Unit 2) along wall line

"W" between columns 21 and 23 concluded that the upgrading of the wall penetrations has been satisfactorily completed.

(Closed) 457/87042-01:

Prior to Unit 2 exceeding five percent power, the Unit 2 "A-Model" must be fully operational, including completion of model verification and validation tests.

Based on a review of licensee correspondence and discussions with cognizcnt personnel, the A-Model for Unit 2 became fully operational on December 9, 1987. The system was declared fully operational following successful completion of pre-operational field testing, including model verification and validation, system calibration tests, and input data validation tests. This item is closed.

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b.

Unresolved Items (92701)

(Closed) 457/84013-02: Quality Control in the area of equipment preventive maintenance.

In June of 1984, the NRC inspected the safety-related equipment maintenance procedures of Phillips, Getschow and. Company (PGCo). The NRC report indicated that an inspection program was needed to document that preventive maintenance activities had been properly performed.

Subsequent to the inspection, the licensee opened Non-conformance Report (NCR) No. 689, which. identified the lack of preventive maintenance on safety-related equipment under construction jurisdiction. As part of the corrective action for NCR 689, PGCo Procedure No. PGCP-39, Revision 7, and CECO Procedures No. PCD-14, "Preventive Maintenance," and No. PCD-29, "Instruction for Completing the Braidwood Equipment Preventive Maintenance Evaluation Form," were developed and/or revised by the licensee to address both past and future preventive maintenance requirements for plant safety-related equipment. These procedures were used to evaluate possible degradation related to the lack of preventive maintenance on safety-related equipment and to provide corresponding corrective actions where required.

From October 13 through 16, 1987, a followup inspection was performed.

The purpose of this inspection was to ascertain the effectiveness of the licensee's corrective actions concerning required preventive maintenance of Unit 2 safety-related equipment under construction control.

During this inspection, the NRC inspector identified a concern relative to space heater energization for several fan motors.

Subsequent investigation by the licensee revealed that in fact some 36 fan motors, for the auxiliary building ventilation (VA) and primary containment ventilation (VP) systems, had not been incorporated into the PM surveillance program to ensure space heater energization as required while under construction control. CECO NCR No. 954, dated November 25, 1987, was initiated to document this deficiency and associated corrective actions.

The failure to incorporate the fan motors inte the PM program for space heater energization is a violation of 10 CFR 50, Appendix B, Criterion XVI for failure to take sufficient corrective action to preclude repetition of the nonconformance identified in CECO NCR No.

689 (457/87045-01).

As corrective action the licensee verified that the fan motors had been meggered with satisfactory results prior to being put in service. Also, the list of 36 VA and VP fan motors was added to the PM surveillance for the fan motors under construction control.

These activities are documented in CECO NCR No. 954, dated November 25, 1987. The fan motors in question are now installed in Unit 2 and have been turned over to operations control.

Based on the corrective actions taken by the licensee, the inspector has no further concerns regarding this matter, and this item is considered closed; consequently, no reply to this violation is required.

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(Closed) 457/86044-01:

Lack of effective housekeeping measures in Unit 2 containment.

This issue was monitored during routine plant tours; the inspectors observed that the quality of the housekeeping in the Unit 2 containment has improved considerably.

The housekeeping in the Unit 2 containment will be monitored through the routine inspection program during the future. This item is considered closed.

(Closed) 456/86045-13; 457/86033-13: Refer to Paragraph 2.c. of this report.

(Closed)456/87007-07; 457/87006-04: Refer to Paragraph 2.c. of this report.

c.

10 CFR Part 21 Reports (92701)

(Closed) 456/84004-PP; 457/84004-PP: This Part 21 Report concerned the failure of Ruskin Manufacturing Company interlocking blade type fire damper (IBD) Models IBD-20, IBD-23, and NIBD-23 to close under nonnal duct pressure conditions. A past NRC review of this Part 21 Report provided the licensee with two previously acceptable alternatives to resolve this issue. The two alternatives involved the performance of an engineering analysis or incorporating into the plant operating procedures and/or pre-fire plans an instruction to shut off the ventilation system fan (s) during the fire emergency in a timely manner.

During this inspection, the inspector was provided an internal licensee letter from the CECO Station Nuclear Engineering Department (SNED) Fire Protection Group to the CECO Nuclear Station Managers.

SNED recommended that since fire dampers were not specified when purchased to be operated under air flow conditions, that for heating, ventilation, and air conditioning (HVAC) systems which are not interlocked for shutdown upon smoke detection, the station should review and modify the pre-fire plans for applicable areas to alert the fire brigade to infonn trained operators of the potential need to shutdown that particular HVAC system.

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an approved copy of the Braidwood Station pre-fire plans.

In Section 7, and as a cover page to the Unit 1 and 2 Fire Detection l

I and Fire Suppression System sections, a note has been inserted providing instructions, in part, to verify that the ventilation I

system is shut down to ensure that air flow has not prevented I

closure of the fire dampers.

Further instruction is given for i

areas where HVAC systems are not interlocked for shutdown upon

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smoke detection. This instruction requires evaluating the need

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for ventilation system shutdown on a case-by-case basis due to

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other potentially overriding plant safety considerations, such as the availability of critical equipment.

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In addition, the licensee had performed an engineering analysis which included fire damper drop tests under air flow conditions.

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During review of this analysis, certain inspector questions remained, but further review was determined to be unnecessary since the above-mentioned instructions in the plant pre-fire plans were sufficient to adequately resolve this issue.

Closure of this Part 21 Report also satisfactorily closes duplicated Unresolved Items 456/86045-13; 457/86033-13 and 456/87007-07; 457/87006-04.

d.

I. E. Bulletin (92703)

(0 pen) Bulletin 456/87002-BB; 457/87002-BB:

Fastener testing to determine conformance with applicable standards. The inspection of licensee activities on this Bulletin was completed in part per Temporary Instruction (TI) 2500/26.

During this inspection period, the Senior Resident Inspector directly observed licensee personnel select ten safety-related and ten non-safety-related fasteners from those available in the station storeroom and warehouse.

The inspector verified that the selection was a representative sample of those fasteners available, that the purchase order data was available, and that the samples were tagged and appropriately identified for testing.

Upon receipt of the laboratory test data, the remainder of the TI will be followed.

e.

Safety Evaluation Report (SER)

(92701)

(Closed) 457/86000-01:

Verify that an outer screen had been added to the containment recirculation sump. The inspector reviewed the structural drawing of the additional outer sump screen and verified that the installed configuration was as shown on the drawings.

During the review, the inspector conducted additional reviews related to design; these are discussed under "Sump Screen Evaluation."

(Closed) 457/86000-22:

The SER documented a comitment by the licensee to install an automatic system to ensure adequate minimum centrifugal charging (CV) pump flow to prevent deadheading that could damage the pump in the emergency core cooling system (ECCS)

mode of operation. The inspector reviewed calibration test report data (which verified valve opening and closing pressure setpoints),

and tests BwpT CV-50 (which tested valve stroke logic), BwPT EF-50 (which tested valve relay time response), and BwpT EF-52 (which tested relay actuation). The data reviewed identified that the miniflow isolation valves for the CV pumps would open and close, depending on reactor system pressure, to prevent CV pump deadheading.

This item is considered closed.

(Closed) 456/86000-29; 457/86000-29:

The SER documented a comitment to perfom a mounting-frame-pressure leak test for the comon auxiliary building ventilation (OVA) system high efficiency particulate air (HEPA) filters and adsorber mounting frames.

The inspector reviewed test data from the pressure decay leak test report foms. The OVA-A, B, and C non-accessible trains;

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OVA-A, B, C, and D accessible trains; and OVA fuel handling A and B ventilation trains were tested. The testing standard used was ANSI /ASME N510-80. The inspector's review of the test-results identified that test acceptance criteria were met for all the OVA mounting frames. This item is considered closed.

(Closed) 456/86000-30; 457/86000-30: The SER documented a comitment that all ESF system ductwork will be visually inspected and audibly checked for leaks and that all audible leaks will be sealed.

The inspector reviewed Procedure PSU-302, "Testing, Adjusting, and Balancing," which describes a method for conducting a ductwork leak test. Additionally, marked up drawings indicating the ESF ductwork which was tested and pre-balance checklists indicating that a check for audible leaks was required were also reviewed.

The data and procedure review identified no discrepancies and verified that the SER comitment had been implemented. This item is considered closed, f.

TI 2500/26 This Tl provided inspection guidance for the review associated with Bulletin 456/87002; 457/87002.

3.

Licensee Event Report Review (92700)

t Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine that reportability requirements were fulfilled, that immediate corrective action was accomplished, and that corrective action to prevent recurrence had been or would be accomplished in accordance with technical specifications:

(Closed) 456/87024-LL and L1: Loss of Primary and Backup Power Supply to Pressure Transmitter 1PT-505 (Turbine Impulse Pressure). On May 22, 1987, at 7:59 p.m., as operating personnel were removing the backup power supply to panel IPA 01J, the fuse for the primary power supply to card frame two blew. A turbine trip signal was present due to the turbine stop valves being closed.

This condition, in conjunction with the blown fuse, resulted in a reactor trip signal. There were no component operations.

The plant was in Mode 3 with the reactor trip breakers open.

On May 27, 1987, at 8:51 p.m., the fuse for the primary power supply to card frame two again blew, resulting in the same sequence of events as noted above.

In each case, the blown fuse was replaced, the instrumentation was returned to normal, and the reactor trip was cleared. The cause of the event is the design fuse size in card frame two of cabinet IPA 01J. A 25-ampere slow blow fuse will be temporarily installed in place of the current fuse until a modification has been implemented to reduce loading.

The licensee will use Action Item Request (AIR) item 456-200-87-29101 to track this item.

This item is considered closed.

(0 pen) 456/87031-L1: Control Room (CR) Ventilation Shift to the Emergency Makeup Mode as a Result of Spurious Actuation of a Radiation Monitor Due to inadvertent Radio Operation.

Two occurrences of this type have taken place (on June 13, 1987, and 6 gain on October 16,1987). The licensee is

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,e evaluating methods to further protect the CR ventilation radiation monitors against errant radio keys.

This LER will remain open while the comitted supplemental report is reviewed.

(Closed) 456/87055-LL:

Inadvertent Cortainment Ventilation Isolation.

On three separate occasions (September 27, 1987; September 28, 1987; and October 2, 1987) a containment ventilation isolation occurred due to a spike on radiation monitor 1AR12J.

Investigation of the events found the root causes to be a failed detector for the third event and possible envircnmental conditions and radio transmission for events one and two.

In all three instances the condition cleared immediately, radiation levels remained normal throughout the events, and the ventilation systems were reset. To prevent further occurrences the licensee replaced the detectors, enlarged the radio transmission exclusion area, and took action to resolve the environmental problems. Additionally, the licensee has formed a task force to investigate future occurrences of this type.

This item is considered closed.

(Closed) 456/87056-LL: ESF Actuation - Control Room Ventilation. At 9:46 a.m. on October 9,1987, control room ventilation radiation monitor OPR 33J spiked and returned to normal immediately.

The spike caused the Train B recirculation charcoal absorber to realign to the ESF mode.

Investigation of the event found a failed pressure switch on the monitor.

The ventilation system was reset, and the radiation monitor was repaired.

This item is considered closed.

(03en) 456/87057-LL: Reactor Trip Due to Turbine irip. On October 9, 1937, at 5:26 p.m., with the plant at 40% reactor power, during performance of IBw0S 3.4.2. A-1, "Turbine Throttle, Governor, Reheat and Intercept Valve Monthly Surveillance," while testing the No. 2 throttle (governor) valve, all four governor valves closed instead of opening to compensate for closure of the No. 2 valve during the test. The turbine tripped, which resulted in a reactor trip.

Immediate corrective action was taken to establish stable plant conditions. On October 16, 1987, the unit was brought back on line.

During the power ascension, testing was conducted per 1Bw05 3.4.2.A-1, and the valves performed in the correct manner.

The root cause of this event is being evaluated and a supplement to this LER will be issued if any additioral corrective actions are detennined. Westinghouse is testing the digital electro-hydraulic (DEH) system software for Braidwood on its simulator, and temporary instrumentation has been installed at Braidwood.

The temporary instrumentation will monitor the sensing line for impulse pressure being supplied to the DEH computer which controls the governor valves. This LER will remain open until the supplemental report is reviewed.

(Closed) 456/87060-LL: Manual Reactor Trip Due to Plugged Condensate Pump Suction Strainers. The root cause of the event is attributed to blockage of the condensate (CD) and condensate booster (CB) pump suction strainers. The blockage reduced feed flow, which caused the steam generator (SG) levels to decrease. When the SG levels were close to the reactor trip setpoint and still decreasing, the operators initiated the manual reactor trip.

Corrective action taken by the licensee included a walkdown of the affected feed and condensate lines for visible piping or

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support problems.

In addition, prior to reactor startup, all four CD pump suction strainers were manually cleaned and all four CB pump strainers

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were backwashed. While cleaning the CD suction strainers a 2-1/2 foot piece of reinforced plastic was found. The plastic apparently acted as a crud trap and released after a CD/CB pump swap, sending the crud and plastic into the suction strainers. The condenser hotwell will also be cleaned and inspected during the next scheduled outage. This item is considered closed.

(Closed) 456/87062-LL: Control Room and Auxiliary Building Ventilation Shift to Emergency Makeup Mode Due to loose Handle on the Unit 2 Switch.

The root cause of this event was insufficient torquing of the set screws on the plastic handle of the Input Error Inhibit Switch. This resulted in the operator acting on a false indication of the switch position. Because the switch was actually in the normal position, even though it indicated

"Inhibit," the low steamline pressure test signal for Unit 2 caused the SI signal to be generated, which actuated the comon ESF equipment for control room and auxiliary building ventilation.

To prevent reoccurrence the licensee checked all set screws for similar switches in both trains of the solid state protection system (SSPS) on Unit 2 to ensure that the handles were tight and indicated the correct switch positions. This item is considered closed.

In addition to the foregoing, the inspector reviewed the licensee's Deviation Reports (DVRs) generated during the inspection period. The purpose of this review was to monitor the conditions related to plant or personnel performance, potential trends, etc. DVRs were also reviewed for assurance that they were generated appropriately and dispositioned in a manner consistent with the applicable procedures and the quality assurance (QA) manual.

4.

Unit 2 Operating License Issuance

On December 18, 1987, NRC Operating License NPF-75 was signed by Dr. T. Murley in Bethesda, Maryland, for Braidwood Unit 2.

The license authorized Comonwealth Edison to load fuel and to conduct testing and low power operation (up to 5%).

No violations or deviations were identified.

5.

Unit 2 Fuel Load and Core Sequence (72524 and 72500)

From December 21 through 27, 1987, the entire load of fuel assemblies was placed in the Unit 2 reactor vessel.

This activity and the preparation for the fuel load were monitored by the resident inspectors and other Region III inspectors.

During the fuel load the inspectors verified that the applicable license, Technical Specifications, and fuel load procedures were adhered to.

Additionally, the inspectors verified the following:

all required surveillances were current; fuel load procedure prerequisites were met; shift manning as required for fuel load was satisfied; the inverse multiplication plots were maintained; proper boron concentration was c

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maintained; security access requirements were met; shift personnel understood their responsibilities; refueling status boards were properly

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updated; and the shift schedules were within administrative guidelines.

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As appropriate, during the fuel load activity the inspectors also reviewed procedure changes for technical adequacy and proper reviews, and reviewed data sheets and various logs routinely. One procedural discrepancy was encountered in which the N31 and N32 source range detectors were reversed in Section 9.2 of BwSU FH-73, for which Temporary

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Change Request No. 2 was properly initiated to correct the procedure error.

No violations or deviations were identified.

6.

Carbon Dioxide Suppression Systems During this inspection an inspector witnessed carbon dioxide (C0 )

demonstration (concentration) testing in several plant areas. Tbe inspector also reviewed other already completed C0 fire suppression

system demonstration test results.

As a result of the inspector review, four plant areas (upper cable spreading rooms 2 EE-1, 2 EE-3, and 2 EE-4, and lower cable spreading room 2 Z-1) were determined to have not met all the acceptance test criteria. This is considered an open item (457/87045-02(DRS)).

Consequently, a retest was conducted by the licensee in each of the upper cable spreading rooms; each subsequently passed the demonstration test criteria. The retest of these three plant area systems was witnessed by an NRC regional inspector.

According to a licensee letter regarding this subject, dated December 17, 1987, the remaining lower cable spreading room 2 Z-1 C0 system is scheduled to be retested prior to entering mode 4.

Als$accordingto this letter, compensatory measures have been and will be maintained until completion and approval of the demonstration test.

The NRC requested that it be notified in advance of the demonstration test so that an NRC inspector has the opportunity to witness the test.

Prior to the retest of three of these systems, the inspector confirmed, as agreed to by the licensee, that compensatory measures were maintained in accordance with Braidwood Station Procedures (formerly Technical Specifications). On December 18, 1987, at approximately 11:15 a.m.,

the inspector accompanied the Station Fire Protection Engineer on a tour of these three plant areas and observed that continuous fire watch personnel were in place and attentive. However, during questioning of one fire watch stander regarding his duties, he exhibited uncertainty as to the plant area he was monitoring and to the information (i.e., location)

he would provide to the control room for the fire brigade response. As a result, the inspector mentioned that future fire watch training should emphasize the duties of being a fire watch.

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No violations or deviations were identified.

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l 7.

Operating Procedures (42450)

l The inspector conducted a review of licensee operating procedures.

l The purpose of this inspection was to assure that the Unit 2 procedures

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include applicable operating limits, that they are consistent with applicable regulatory requirements, that they are of proper format as described by dpplicable administrative proceduret, and that surveillance procedures are adequate to insure the integrity of plant operations. The inspector reviewed Bw0Ps, "Operating Procedures"; BwGPs, "General Operating Procedures";

Bw0Ss, BwVSs, BwHSs, and BwlSs, "Departmental Surveillance Procedures"; and found all reviewed procedures to be in compliance with the above mentioned criteria. The BwAPs, "Administrative Procedures," were previously reviewed for Unit 1 and are applicable to both units.

No violations or deviations were identified.

8.

Emergency Procedures (42452)

The inspector conducted a review of the licensee's procedures which are used to comply with the regulatory requirements for emergency preparedness (EP). The purpose of this inspection was to ascertain whether plant emergency procedures are prepared to adequately control safety-related functions in the event of system or component malfunction indication.

The inspector's review of the procedures was also to insure that they are written in accordance with proper administrative guidelines, receive proper reviews, and are technically adequate in scope and content for their stated purpose.

The reviewed procedures included BwARs, "Annunciator Response Procedures"; BwEPs, "Emergency Procedures"; Bw0As, "Operating Abnormal Procedures"; BwFRs, "Functional Restoration Procedures"; BwlSs, BwHSs, BwvSs, "Departmental Surveillance Procedures"; and BwCAs, "Contingency Action Procedures." The inspector's review identified that with one exception the licensee's EP procedures met the above stated criteria.

The one exception involved a procedure error found in the BwEPs. The procedure error referenced a Unit 1 procedure for SI initiation actions in Unit 2.

Six BwEPs and a total of 105 pages contained this error; the procedures had received onsite review and approval. The licensee's failure to provide instructions of a type appropriate to the circumstances for plant energency operations is considered a violation of 10 CFR 50, Appendix B, Criterion V (457/87045-03(DRP)).

9.

Title 10 Requirements (91300)

This inspection activity was conducted to ascertain the licensee's conformance to selected Title 10 requirements applicable during the Unit 2 testing phase.

The following requirements were reviewed:

a.

10 CFR 19 (1) Posting Requirements - 10 CFR 19.11 (2) Instructions to Workers - 10 CFR 19.12

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10 CFR 20

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Storage of Licensed Material - 10 CFR 20.207 c.

10 CFR 50 (1) Construction Deficiency Reporting - 10 CFR 50.55(e)

(2) Changes, Tests, and Experiments - 10 CFR 50.59 (3) Codes and Standards in use correspond to the reviews required by 10 CFR 50.55a.

The review of Title 10 requirements has been an ongoing process during the testing phase. Applicable portions were reviewed when inspections were performed. Methods used to ensure compliance with 10 CFR requirements were reviews of test procedures and test data, and NGET training, specialist inspections, deficiency records, and general inspections. Notices of Violations were issued for noncompliar.ces following previous inspections, and tracked by the individual inspection reports.

No additional violations or deviations were identified.

10.

Safety Evaluation Report (SER) Review and Followup (92719)

The purpose of this inspection was to ascertain whether the licensee has satisfactorily implemented commitments documented in the SER. The inspectors reviewed the Byron /Braidwood SER and selected several of the commitments addressed in the SER for implementation verification. The inspectors then verified that the licensee's administrative controls and plant systems in use conform to the SER commitments.

The inspectors identified that the licensee has failed to meet its SER commitments relative to the Hydrogen Recombiner System.

Details of the Notice of Violation and Deviation are documented in Inspection Report No. 457/87036. This item is considered closed.

No additional violations were identified.

11. Sump Screen Evaluation During the review of SER Item 457/86000-01, the inspector used the criteria provided in the SER, Final Safety Analysis Report (FSAR), and Regulatory Guide 1.82, "Sumps for Emergency Core Cooling and Containment Spray Systems," December 1983, as committed to in the FSAR. With these criteria, the inspector calculated the area of sump screen needed to meet the required velocity of Emergency Core Cooling System (ECCS) and Containment Spray (CS) flows.

The criterion for flow velocity at the screen, as stated in Reg Guide 1.82, is 0.2 feet per second (fps), assuming 50% of the screen flow area is

blocked by debris, and the flow based on design, preop test acceptance criteria or as detected during the ECCS full flow test is 13,300

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t to 15,185 gallors per minute (gpm). Using the licensee's contractor's figure of 13,600 gpm, this would require a screen area of 192.46 square feet for both ECCS and CS trains at full flow. Confirmatory measurement of the installed screen showed 87.79 square feet of free area for the entire outer screen. This difference will result in a flow velocity of 0.345 fps at the screen. This increase of velocity by about 75% over the criterion is difficult to assess for safety significance, as the velocity criterion of 0.2 fps is based on allowing debris of 1.05 specific gravity to drop to the containment floor during the design basis accident and on a screen blockage of 50%, without causing the ECCS pumps or CS pumps to cavitate.

In a review of the design of the screens by Sargent & Lundy, the inspector found that the entire screen area was considered as a free flow area with no consideration for blockage due to support stanchions, brackets or the wire mesh. This was confirmed by a Region III engineering specialist.

Since this affects four licensed reactors, of which three are operational, the licensee was requested to verify that all four units (Byron and Braidwood) are identical, and to provide justification for acceptance of the present installations. The results were to be provided to the NRC by December 28, 1987. This matter is considered an Unresolved Item (456/87044-01(DRP);457/87045-04(DRP)1 No violations r-deviations were identified.

12. Operational Safety Verification (71707)

The inspectors conducted routine plant tours during the inspection period to make an independent assessment of equipment conditions, plant conditions, construction activicies, security, fire protection, general personnel safety, housekeeping, and adherence to applicable regulatory requirements. During the tours, th, 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 walkdowns.

These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under technical specifications,10 CFR,,and administrative procedures.

No violations or deviations were identified.

l 13. Radiological Protection (71709)

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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 implementation of the ALARA program, the use of Radiological Work Pennits (RWPs), the control and monitoring of radiation exposures,1".cluding work in high radiation areas if applicable, and the control of radioactive material.

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No violations or deviations were identified.

14.

Engineered Safety Feature (ESF) Systems (71710)

During the inspection, the inspectors selected accessible portions of several ESF systems to verify their status. Consideration was given to the plant mode, apolicable Technical Specifications, Limiting Conditions for Operating Action Requirements (LC0ARs), and other applicable requirements.

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 agreed.

During the inspection, the following ESF systems / components were walked down:

Unit 1 1A Emergency Diesel Generator Unit 1 2A Emergency Diesel Generator No violations or deviations were identified.

15.

Physical Security (71881)

At various times throughout the inspection period, the inspectors monitored compliance with the Physical Security Plan (PSP). Observations were made of selections of manning levels and collateral duties of 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 were proferly maintained; whether procedures were properly followed; whether compensatory meatures were appropriately used when required; whether persons in the PA and VA were properly badged and escorted if required; whether various detection / assessment aids such as fences and illumination of the PA, were operable; and whether TV monitors had sufficient clarity and resolution, u

No violations or deviations were identified.

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16. Monthly Maintenance Observation (62703)

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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 Specifications.

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 procedures and were inspected as applicable; functional testing and/or calibrations were performed prior to returning components or systems to 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 performance.

Maintenance activities on the following equipment were observed and reviewed:

Unit 1 Area Radiation Monitors / Process Radiation Monitors Unit 2 2A Dr.ergency Diesel Generator No violations or deviations were identified.

17. Monthly Surveillance Observation (61725)

The inspectors observed surveillance testing required by technical specifications for Unit i during the inspection period and verified that

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testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that limiting conditions for operation were met, that removal and restoration of the affected components were accomplished, that results conformed with technical specifications and procedure rcquirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personnel.

The inspectors also witnessed portions of the foll,owing test activities:

Unit 1

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1A Emergency Diesel Generator - Monthly Surveillance

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Unit 2 2B Emergency Diesel Generator - 24-Hour Test Run No violations or deviations were identified.

18. Unit 2 Plant Tours (71707)

-The inspectors observed work activities in progress, completed work and plant conditions during general inspections in Unit 2 work areas.

Observed items included cable trays, junction boxes, pipe support welding and mechanical equipment. Particular attention was given to material identification, nonconforming material identification and housekeeping.

The inspector reviewed work activities by reviewing travelers while touring the plant. These travelers pertained to electrical, piping, and hanger installation.

No violations or deviations were identified.

19. Training Effectiveness (41700)

The effectiveness of training programs for licensed and non-licensed personnel was reviewed by the inspectors during the witnessing of the licensee's performance of routine surveillance, maintenance, and operational activities and during the review of the licensee's response to events which occurred during the inspection period. Personnel Lppeared to be knowledgeable of the tasks being perfomed, and nothing was observed which indicated any ineffectiveness of training.

No violations or deviations were identified.

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20. Report Review During the inspection period, the inspector reviewed the licensec's Monthly Operating Report for November 1987. The inspector confirmed that the infonnation provided met the requirements of Technical Specification 6.9.1.8 and Regulatory Guide 1.16.

The inspector also reviewed the licensee's Monthly Plant Status Report for November 1987.

No violations or deviations were identified.

21. Plant Status and Licensee Meetings

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A meeting was held onsite on December 2, 1987, to discuss the Unit 2 readiness for licensing and to tour the Unit 2 containment and auxiliary building. The participants are identified in Paragraph 1.

A final plant status meeting prior to licensing was held onsite on December 16, 1987, between Region III and Ceco to discuss the issues and to conduct a plant tour. The Region III contingent was led by the Deputy Regional Administrator and the Chief of DRP Branch 1.

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contingent was led by the General Manager (PWRs) and the Station Manager.

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During the tours, nothing was identified that would affect the licensing of Unit 2.

Identified items were promptly corrected by the licensee, or provisions were made for their correction.

On December 14, 1987, C. J. Paperiello and Region 111 staff members met with T. Maiman, M. Wallace and Ceco personnel to discuss the implications of a contract employee who had tested positive for marijuana. The licensee presented the results of its review, which concluded that there were no safety-related concerns with this employee's work. The licensee's basis for this conclusion was acceptable; no violations or deviations were -identified.

22. 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. An open item disclosed during the inspection is discussed in Paragraph 6.

23. 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 11.

24. Exit Interview The inspectors met with the licensee and contractor representatives denoted in paragraph I during the inspection period and at the conclusion of the inspection on January 5, 1988. The inspectors 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.

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