IR 05000456/1989001
| ML20248E693 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 01/31/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20248E692 | List: |
| References | |
| 50-456-89-01, 50-456-89-1, 50-457-89-01, 50-457-89-1, NUDOCS 8904120336 | |
| Download: ML20248E693 (32) | |
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SALP 8
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, SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION
REGION III
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 456/89001; 457/89001 i Inspection Report No i Commonwealth Edison Company '
Name of Licensee Braidwood Station Name of Facility January 1, 1988, through January 31, 1989 Assessment Period l
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6904120336 PDR 890331ADOCK PDC 05000456 O
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~ TABLE OF. SUMMARY'0F RESULTS: Overview
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The' licensee'sperformancewasgoodinallfunctionalarhas,as indicated by-the ratings. However, performance was not'es good as anticipated in terms of events and unplanned trips, in light of corporate experience in nuclear power operations and lessons learned at Byron' Station.. It is recognized that this' assessment period covered the most demanding period of station activity to date, with
. Unit _1 achieving full power operation in-conjunction with the completion of Unit'2 startup testing and' ascension to full power.' ' '
Although unchanged, the ratings reflect . generally effective licensee efforts to maintain good performance in a more~ difficult operating environmen The performance ratings during the previous assessment' period'and this assessment period according to functional areas are given below:
Rating Last Rating.This Functional Area Perio Period Trend l P.lant Operation ' 2 l Radiological Controls !' Maintenance / Surveillance 2/2 2 Emergency Preparedness l' 1 Security- 2 2
/ Engineering / Technical Support 2 2 Safety Assessment / Quality l
, Verification NR- 2
Other Areas of Interest
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l III. CRITERIA Licensee performance is assessed in selected functional areas. Functional areas normally represent areas significant to nuclear safety and the environment. Some functional areas may not be assessed becatise of little or no licensee activities or lack of meaningful observations.k Special areas may be added to highlight significant observation .
l The following evaluation criteria were used to assess each functional j area: Assurance of quality, including management involvement and control; Approach to the resolution of technical issues from a safety standpoint; Responsiveness to NRC initiatives; Enforcement history; Operational events (including response to, analyses of, reporting of, and corrective actions for); Staffing (including management); and Effectiveness of training and qualification progra However, the NRC is not limited to these criteria and others may have been used where appropriat ]
On the basis of the NRC assessment, each functional area evaluated is rated according to three performance categories. The definitions of these performance categories are as follows:
Category 1: Licensee management attention and involvement are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially exceeding regulatory requirements. Licensee resources are ample and effectively used so that a high level of plant and personnel performance is being achieved. Reduced NRC attention may be appropriat I Category 2: I Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are good. The licensee has attained a level of performance above that needed to meet regulatory requirements. Licensee resources are adequate and reasonably allocated so that good plant and personnel performance is being achieved. NRC attention may be maintained at normal level Category 3: Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are not i sufficien The licensee's performance does not significantly exceed
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that needed to meet minimal regulatory requirements. Licensee resources appear to be strained or not effectively used. NRC attention should be increased above normal level ^
The SALP report may include an appraisal of the performance tynd in a functional area for use as a predictive indicator if near-terrL performance is of interes Licensee performance during the last quarter of the assessment period is examined to determine whether a trend exist Normally, this performance trend only is used if both a definite trend ( is discernable and continuation of the trend may result in a change in performance rating.
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The trend, if used, is defined as:
Improving: Licensee performance was determined to be improving near the
/ close of the assessmant perio Declining: Licensee performance was determined to be declining near the close of the assessment period, and the licensee had not taken meaningful steps to address this pattern.
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I PERFORMANCE ANALYSIS Plant Operations Analysis 'l
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This functional area was evaluated on the results of ten routine and four special inspections conducted by the resident inspectors, regional specialists, and inspection team >
The ' enforcement history declined during this assessment perio Six' Severity Level IV violations were issued, of which two were considered for escalated enforcement action. Three additional Severity Level IV violations, of which one was a repeat violation, were issued in the Emergency Preparedness section; however, in each case, the cause was directly attributable to the action of operations personnel. The two violations considered for. escalated enforcement action were the 2B safety injection pump being inoperable and inoperability of non-accessible area exhaust plenums. During the previous assessment period, three Severity Level IV, one Severity Level V, and one partial Severity Level IV violations were issued in this functional area, of which three were considered for escalated enforcement actio None of the violations issued represents a programmatic breakdow Unit I was declared commercial on July 29, 1988, and Unit 2 was declared commercial on October 17, 1988. Availability of the units was monitored from those dates through the end of the assessment perio Unit I had an availability of 85.9%, and Unit 2 had an availability of 86.9%.
The number of unplanned reactor trips was excessive. Unit I experienced a total of six, three with no control rod motion and three at greater than 15% power, of which, two were manual trips. This total was less than that af the previous assessment period for Unit 1, in which-18 unplanned trips occurred, including 3 at greater than 15% power. Unit 2 was not operational during the previous assessment period; however, it had a trip history during this period similar to that of Unit 1 during the previous perio During this period, Unit 2 experienced 17 reactor trips, which included 2 reactor trips with no control rod movement, 4 at less than 15% power, and 11 at greater than 15% power, of which 4 were manual scrams. Several of these involved the sensitivity of controlling water level in the Unit 2 D-5 steam generators. The number of unplanned trips was significantly higher than expected considering the licensee's operational experience gained at Byron Station and Braidwood ;
Unit 1. In addition, Unit 1 experienced 17 engineered safety feature (ESF) actuations (including 1 safety injection),
compared with 26 during the previous assessment perio Unit 2 I
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l experienced 22 ESF.actuation Seven of the trips and 13 of the L ESF actuations resulted from personnel errors. Twelve of the- ESF actuations were caused by spurious spiking.of or electronic-problems with installed radiation monitor The~1icensee pursued a modification program for the monitors, whlch included lessons learned at Byron. The problem, while signiiLicantly reduced by the end of the assessment period, persisted for an extended period of time before resolution was achieve Of the 59 licensee event reports (LERs) issued for both units during this period, 28 (47%) were attributed to the plant operations area. Of the operations events, 9 (32%) resulted from personnel errors, a significant decrease from the previous assessment period (15 personnel errors among 32 operations LERs, or 47%). The reduction in operations personnel errors accounts for the reduction in overall personnel errors discussed in the Safety Assessment / Quality Verification sectio Management involvement to assure quality is considered goo A high-level management involvement was evident in almost all activities, including operations, planning sessions, and plant walkdowns. Corporate management involvement was evident in the Braidwood Corporate Overview meetings, which are attended by managers from the licensee's corporate office and the Byron and-Zion stations, as well as representatives from all station work groups. These meetings promote the raising of issues to higher management levels and are an effective management tool in identifying and resolving problems at the sit The management positions at the station and in operations are filled with well qualified and dedicated personnel. The station manager has exhibited assertive managemen Vacancies have been filled promptly with well qualified personnel. As of January 1989, the station had 54 scnior reactor operators (SR0s) and 32 reactor operators (R0s), of which 38 SR0s and 31 R0s were assigned to the Operations Department. This total has been sufficient to man three shifts per day on a six-shift rotatio A large amount of overtime was worked during the concurrent Unit 1 power operation and Unit 2 startup test program and instances of exceeding NRC overtime policy guidelines occurre However, this was spread over a number of individuals, and none appeared excessive. In all cases, proper plant management
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authorization was granted. After Unit 2 achieved commercial status in October 1988, the occurrences of exceeding the overtime guidelines declined; none have been reported since mid-December 198 Twenty-four replacement examinations were administered during this assessment period, with a passing rate of 88%, a slight decline from the previous assessment perio The operator i training staff remains high in quality and has contributed !
to the high passing rate .
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Control' room professionalism was good and was acknowledged in
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the special operational readiness team inspection. . Operators
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were_ attentive to and cognizant of the status of equipment and normally attentive to detail.. Operator performance _was excellent during the startup test program and in response to pff-normal event *-
The' licensee has had an ongoing program to reduce the. number of illuminated annunciators in the control room. Routinely'each
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unit' operates with a minimal' number of illuminated annunciato alarms. However, on at least one occasion for each, the Unit 2 and-Unit 0 (common) panels' achieved the " black board" condition (no lit annunciators) for approximately one shift. A secondary chemistry excursion event could have been less significant if-the operators had had greater confidence in the alarm annunciator for the' secondary sample sink, rather than regarding it as a nuisance alar Communications were normally adequate'to achieve the.necessary activities. However, poor communication has been_ responsible-for the occurrence of several events. Examples _ include a secondary chemistry excursion, a safety injection pump discharge valve being locked shut, starting a diesel generator.at the wrong time.during a safety injection signal surveillance, and the loss of an ESF bus because the wrong fuses'were- pulled when removing'a station auxiliary transformer from service. Concern-was expressed about operator distractions and the number of people at shift briefings; station management has addressed
.this concer On occasion operating decisions were less than conservativ These were the decision to stay above 75% power when several incore neutron detector thimbles were clogged with lubricant, preventing the performance of a required surveillance, and the reluctance to shut down to identify the source of a primary leak when unidentified leakage was 90% of the allowable Technical Specification (TS) limit. In both cases, the licensee took conservative action after prompting by the NR Responses to NRC initiatives have been sound and thoroug In several cases, there was some delay in resolving issues; examples include modifications to the out-of-service system
, and changing the questionable oil in the 1A. auxiliary feedwater pump, which was NRC-identifie In most cases, resolutions have been acceptabl ;
Housekeeping has remained a strength at Braidwood. The licensee .
has continued with the model spaces concept and is pursuing '
the completion of that program. Additional effort was directed toward Unit 2 spaces for as-low-as-reasonably-achievable (ALARA)
consideration prior to completing the free access area While .
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Braidwood remains excellent in this area, it was not as good as during the lico. lng phase. It was noted that during this period housekeeping was declining as the licensee allocated fewer resources to this are ,
1-Outages were well execute There was excellent c6 ordination of Unit 1 power operation with Unit 2 testing, initial startup, and power ascension. These activities were conducted smoothly and with minimal conflic , Performance Rating The licensee's performance is rated Category 2 in this are The licensee's performance was rated Category 2 in the previous assessment perio . Recommendations (
Non B. Radiological Controls Analysis This functional area was evaluated on the results of three routine inspections by regional specialists and observations by resident inspector The enforcement history in this area is unchanged; one Severity Level IV violation was issued in both the current and previous assessment period .
Staffing in this functional area remains adequate. Turnover during the period was somewhat high, but the vacancies were filled in a timely. manner by experienced personnel. The Radiation / Chemistry Department was divided into separate radiation protection and chemistry groups, and each technician e has been assigned permanently to one of the two groups. The
- resulting specialization, together with more specific l certification requirements has been recommended by the NRC for several year Licensee responsiveness to NRC initiatives was mixe An intensive self-evaluation by the licensee of conformance with Regulatory Guide (RG) 1.97, Revision 3, concluded that all areas of access to instruments important to safety were properly covered by area radiation monitors (ARMS). One exception, the issue of compliance with Generic Letter 82-12, which dealt with ,
overtime worked by radiation protection and chemistry technicians and by maintenance personnel, remains unresolved pending licensee initiative .
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Manag'ement involvement in assuring quality was generally good, )
despite an error in. Judgment involving the use of expired radiation standards that resulted in the issuance of a violatio The implementation,: jointly.with Byron, of advanced radiation -
protection refresher training forLthe three maintenance groups (electrical,-mechanical, and' instrumentation) was;at% gnificant achievemen The licensee's approach to the identification and resolution of technical issues was adequate during the assessment period;-
however, radiological hazards have been minimal because of-the plant's short operating history. Significant effort was devoted into the development of the Radiation Evaluation Program (REP), which will provide extensive records of exposure information
.for use in job planning and dose tracking programs. .The total worker dose for 1988 was'approximately 75 person-rem, which represents average performance for a plant in the early' stages of operatio ,
The. licensee has a hot particle detection, control, and assessment program. Personnel contaminations were reasonably few during
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this period, which included short maintenance / surveillance outages. Gaseous and liquid radioactive releases have been well within TS limits. No solid radioactive waste or transportation problems occurred during this assessment period. Results of the radiological confirmatory measurements were good. The station achieved 68 agreements out of 72 comparisons during its first confirmatory measurements inspection with'the NR Concerns identified during this inspection were satisfactorily addressed before the conclusion of the inspectio . Performance Rating The licensee's performance is rated Category 2 in this are The licensee's performance was rated Category 2 in the previous assessment perio . Recommendations Non Maintenance / Surveillance
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This functional area was evaluated on the results of 14 routine and special inspections conducted by resident and regional inspectors.
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The enforcement history for the area of maintenance and surveillance did not change significantly from that.of the previous assessment-period. This assessment period included three Severity. Level IV violations in the surveillance area, compared with four Severity Level IV violations . issued during-the previous asss}sment period for the Maintenance and Surveillance areas (previout,1y. rated separately). One violation, issued for missed or improperly performed TS surveillance, received escalated enforcement consideratio Corrective actions for the violations identified this assessment period were generally prompt and effectiv The number of operational events attributed to the Maintenance /
Surveillance area did not change significantly from that of the previous assessment period. Of the 59 LERs issued during this assessment period, 29 (49%) were attributable to the Maintenance / Surveillance area, compared with 28 of 71 LERs (39%) in the previous assessment period. There were 16 LERs (55%) due to personnel error, compared with 16 (57%) during the
. previous assessment perio There were thirteen identified instances in which the critical
' dates for TS-required surveillance were exceeded because they were either not performed or improperly performed. The licensee has begun focusing more attention on completing required TS surveillance on or before the due dates and on the reduction of personnel errors. In general, the events for the assessment period were properly identified, analyzed, and reported in a -
timely manne Licensee management's involvement to assure quality in maintenance
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and surveillance activities was usually eviden In general, personnel involved in the supervision and performance of assigned tasks were adequately trained and knowledgeable of task objectives and equipment operation, procedures were adequate and contained appropriate precautions and notes, and records were complete and well-maintained. Management actions to assure quality included the continued use of the MESAC (Microelectronic Surveillance and Calibration) unit for instrumentation surveillance, which minimizes the potential for plant challenges during surveillance, and moving coordination of surveillance scheduling to the work planning group. The effectiveness of the work planning group was also noted during the Unit 2 initial startup and the Unit 1
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surveillance outage. CECO issued a corporate directive in March 1988 to all of its nuclear stations on the Conduct of Maintenance, !
which follows the Institute of Nuclear Power Operations (INPO) j guidelines. This document contains the specific means adopted '
by CECO for sound maintenance performance and defines activities and responsibilities. During the assessment period, the licensee was in the process of implementing a portion of the guidelines contained in this directive. There are various data bases used l
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M in the preventive maintenance (PM) program that are tracked b various licensee groups for performance monitoring of equipmen Approximately 50% of the licensee's maintenance work was preventive for the assessment period. One problem identified during the Unit 2' operational readiness inspection was that th$ program is segmented in such a~ manner that it is very difficulesto-assess the overall PM statu However, issues for which additional management involvement was needed included the Unit 1 trend toward the TS limit for unidentified reactor coolant system (RCS) leakage, missed or improperly performed surveillance, and the untimely completion of a quarterly incore-excore neutron detector calibration surveillance required above 75% reactor power. After many discussions with NRC personnel and the issuance of a violation concerning missed or improperly performed surveillance, the licensee started to increase emphasis on performing surveillance before the due date rather than before the critical date and on determining and correcting the causes of several missed or improperly performed surveillance. With regard to the incore-excore detector calibration issue, following an outage the licensee increased reactor power to above 75% and stabilized plant conditions for an extended period at this power level. An incore-excore detector calibration required by the TS was not performed. A violation was issued for failure to perform this surveillanc The licensee then shut down the unit to perform maintenance on the movable incore detectors to support the calibration and other activities. The unit was restarted and stabilized at povlar levels above 75% for reasons other than performing the surveillance. After continued prompting by the resident inspectors and Region III management, the licensee completed the incore-excore calibratio The licensee has an aggressive program for the reduction of illuminated alarm annunciators in the control room. The program continued throughout the evaluation period but appeared stalled for parts, modifications, etc. at the end of the assessment perio Over the assessment period, the backlog of corrective maintenance items remained relatively low and constan The high was approximately 920 and the low was approximately
. 700, which was the total at the end of the perio '
Management involvement in ensuring quality in the chemistry area was good. The water chemistry program required by corporate directive conformed to the Electric Dower Research Institute (EPRI) Steam Generator Owners Chemistry Guideline Licensee data on the secondary system water chemistry, showed that the
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snd conductivity. levels'were somewhat high (near the Action
'evel 1 guidelines), but these levels were decreasing toward the
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ind of the' assessment period and appeared to be related to-the cleanup of the relatively new reactor systems. Theilaboratorie were well-equipped with computer-controlled ion chrtmatographs (ICs) for low level trace material analyses. The plant also has an.in-line set of ICs for monitoring steam generator blowdow One operational event involved the contamination of both secondary systems when a' vendor-supplied portable demineralized became exhausted, failed to shut down, and injected impurities-into the makeup water. This problem was caused by lack of a management control of the vendor services. Further, poor communications between chemistry and operations personnel resulted in slow identification of the problem and slow implementation of the appropriate action level, for which a violation was issued (attributed to the Plant Operations.section).
Once the source was identified, the. corrective actions were both timely and appropriat The results of the nonradiological confirmatory measurements program were adequate; an initial 23 of 31 results were in agreement (74%). The disagreements appeared to be due mainly to deficiencies in the analytical procedures, which the licensee corrected in reanalyses. The licensee has been receptive to the i NRC nonradiological confirmatory measurements program and has developed and is improving the quality assurance / quality control (QA/QC) program in the laborator Although the station's ' inservice testing (IST) program is not in its final form, procedures to control activities are well-stated and defined. The implementation plan demonstrates excellent coordination and assignment of priorities. Test records and performance data were usually complete, well-maintained, and availabl The licensee's approach to the resolution of technical issues from a safety standpoint was generally sound and thoroug A number of surveillance and maintenance activities were performed this assessment period: a Unit I surveillance outage; two Unit 1 maintenance outages, one for clearing obstructions from movable incore detector thimbles, and one for pressurizer manway leak repair; three Unit 2 maintenance outages, one for L main condenser tube repairs, one for condensate pump suction
! strainer cleaning and condenser inspection and cleaning, and
! another for resistance temperature detector (RTD) bypass manifold l valve packing leak repairs. In general, the licensee exercised good control over work activities. During this assessment period, however, Confirmatory Action Letters were issued for
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Units 1' and 2 for licensee action on' environmental qualification'-
(EQ) issues.: The EQ concerns addressed some_ maintenance'and surveillance' activities relative to maintaining the EQ status of equipmen i~
'The:11censee's. responses to'NRC initiatives and conderns.were technically sound and thorough. When the.NRC raised concerns-relating to maintenance or surveillance activities, the licensee usually__ responded'in a_ timely and effective manner. However, when the NRC ' raised concerns relative ~to the missed 'or improperly performed surveillance,_the unidentified leak' rate surveillance data, and timely completion of the quarterly incore-excore calibration required above 75% reactor power, the licensee did'
not respond in an effective manner until after continued I prompting by the NR Staffing in the maintenance'and surveillance area was adequat '
During the assessment period, the licensee received INP0 l , accreditation for the Braidwood maintenance personnel trafaing I f programs and for the radiation / chemistry technician training
program. Also, a new chemistry supervisor was appointed.
l Although'he has limited chemistry experience, he' has good supervisory experience and heads an experienced group of chemists, who no longer rotate to radiological protection positions (the division of the Radiation / Chemistry Department is discussed in the Radiological Controls section). ~ Currently'13 of the 21 chemistry. technicians are qualified under ANSI N18.1-197 _ Performance Rating The licensee's performance is rated Category 2 in this are The licensec's performance was rated Category 2 in both the maintenance and surveillance functional areas in the previous assessment perio . Recommendations No n e' . Emergency Preparedness Analysis
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This functional area was evaluated on the results of three inspections conducted by regional inspectors. These inspections ,
consisted of an exercise observation, a routine inspection, and a j followup inspectio )
Enforcement history declined slightly. Three Severity Level IV violations were identified, compared to one during the previous
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assessment period. The violations did not represent a breakdown in j en'.argency. preparedness; they resulted from incorrect interpretations I of requirements by operations personnel. Two violations were issued for a single event regarding untimely Unusual Event declaration and a late NRC notification following initiation of a reactor 1 shutdown per a Technical Specification (TS) requirement. The short-5erm corrective )
action was the issuance of a memorandum containing an interpretation I of the relevant Emergency Action Level (EAL). This EAL was again misinterpreted several months later, resulting in a third violation for poor corrective actions in addressing the first two violation The longer-term corrective action, which was to reword the EAL to clearly state when the declaration is required, was subsequently completed and implemente i One Alert and four other Unusual Event declarations were timel i'
State and NRC officials were notified within the regulatory time limits following every emergency declarat'on. The licensee's I'
followup evaluations c' mergency plan activations were well don With the exception of the ineffective memorandum on the EAL for TS i shutdowns, the licensee's approach to resolution of technical issues has remained thorough and timely. This reworded EAL was part of an overall EAL upgrading project initiated by corporate and station staffs. The goal of this long-term project has been to standardize the organization and interpretation of the EALs in use at all six of the utility's nuclear stations. The upgraded EALs are consistent with current regulatory guidance and, where possible, with the upgraded and approved EALs for the Byron, Zion, and LaSalle Station The upgraded EALs for the Braidwood Station were submitted mid-October and approved in mid-December 198 Management support for the program has remained good, as evident by the conduct of nine creative tabletop drills involving control room or Technical Support Center staffs. These drills were performed in addition to annual training commitments and in response to self-identified concern Good management involvement in ensuring quality was also j demonstrated by the conduct of two independent audits and !
six surveillance of the progra Records of these activities,
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of periodic inventories, and of communications equipment tests j all indicated that appropriate corrective actions had been ;
promptly taken on the few identified problem The licensee's overall exercise performance was good. The exercise scenario conducted during this assessment period was creative and challenging. Scenario innovations included the use of role players !
portraying NRC site team representatives and the use of real-time I meteorological data. In contrast to the exercise conducted during the previous assessment period, the 1988 exercise scenario contained
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e no significant technical flaws and was well controlled. The only concern identified during the exercise was the untimely accounting for all onsite personnel. Very thorough corrective actions inefiuded four practice assembly drills, during which various training and equipment refinements were evaluated. The licensee succes'sfully demonstrated the capability to account for all 740 onsitbyersonnel in a timely manner during a remedial demonstration in December 198 The emergency response organization has remained well staffed, with no individuals holding multiple positions. Primary and support positions remained well defined. The licensee has continued the practice of conducting semiannual, off-hours drills to successfully demonstrate the capability of augmenting on-shift personnel in a timely manne The emergency preparedness training program has remained clearly defined for all positions. Training requirements, lesson plans, and examinations have been specified and approved for all onsite position Periodic drills and the nine tabletop drills were '
well documented, including corrective actions taken to address critique items. The training status of individuals was well tracked. Based on overall exercise performance and records checks, the onsite emergency response organization has been well traine . Performance Rating The licensee's performance is rated Category 1 in this are The licensee's performance was rated Category 1 in the previous assessment perio . Recommendations Non E. Security Analysi s This functional area was evaluated on the results of seven security inspections (three routine, four special) conducted by regional specialists and contractors and on routine observation of security activities by the resident inspector One special inspection was conducted as a result of an allegation regarding fitness-for-duty issues. The second special inspection was conducted as a result of a failure to adequately control access to a vital area. The third special inspection was conducted as a result of failure on two occasions to ensure adequate implementation of vital area compensatory measure The fourth special inspection conducted was the Regulatory I
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Effectiveness Review performed by headquarters and contractor
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personnel. No'significant vulnerabilities were identified
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! j The-enforcement-historyrepresentedadeclineinth}41censee's I performance. One Severity Level IV violation and ote, Severity s
l Level III violation with a $50,000 c1vil' penalty were identified, j compared with two Severity Level IV violations during the {
previous assessment period. These violations represent a' j performance decline, but not a-significant' programmatic
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breakdow Security events reported under 10 CFR 73.71 were properly identified, analyzed, and reported in a timely manne However, an open item concerning loggable events remains at the corporate level. The events reported were incidents for which the licensee received the two violation Management's role in ensuring the quality of the security program was adequate. Corporate and plant management was supportive of the security program, as evidenced by the allocation of resources needed to initiate upgrading of the plant's protected area intrusion alarm system. Also, the licensee hired a consultant to conduct an in-depth vulnerabilit test of the protected and vital area intrusion systems to prepare for a scheduled NRC headquarters regulatory effectiveness review. The Nuclear Security Administrator actively participates in resolving issues. A close liaison and good communications a e maintained between site security management, corporate security, and the NRC Region III safeguards sectio The licensee generally submits sound and thorcugh responses to NRC initiatives. An example of where management's approach and participation was less than satisfactory was the licensee's initial response to the concern for which the civil penalty was issued, involving the inattentiveness of two security guards. The licensee's approach to the incident was overly defensive; although it did take adequate corrective actio The licensee's approach to the resolution of technical issues !
was good. In reviewing the licensee's submittals regarding the Miscellaneous Amendment and Search Requirements revision to
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the Braidwood Physical Security Plan, the staff found that the responses relative to safeguards matters were technically sound and consistent, demonstrating the existence of well-developed policies and procedures for controlling security-related matter There was consistent evidence of planning by CECO (including corporate level) managemen !
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Staffing levcis are adequate. The security training and qualification program is adequate. Security personnel were knowledgeable and competent in the execution of their dutie . Performance Rating i .
Licensee's performance is rated Category 2 in this are The licensee's performance was rated Category 2 in the previou. I.:;:essment perio . Recommendations Non F. Engineering / Technical Support Analysis i This functional area was evaluated on the results of five routine inspections by regional inspectors, several inspections by the resident inspectors, and NRR evalua?. ion The enforcement history during this assessment period declined significantly. Two Severity Level III violations and three Severity Level IV violations were issued, compared with one Severity Level IV violation issued during the previous assessment period. Additionally, three Severity Level V violations and one Severity Level IV violation were discussed during the previous assessment period, however, the violations were issued during this assessment period. -The first Severity Level III violation (and associated civil penalty of $50,000) had its origins in the previous assessment period and dealt with a design error which resulted in the operation of the plant with the control room ventilation system (CRVS) in a degraded condition. The second Severity Level III violation (and associated civil penalty of $75,000) and the Severity Level IV violations dealt with the licensee's failure to perform adequate EQ reviews and to maintain EQ equipment in accordance with requirement Of the 59 LERs issued during the assessment period, 10 were related to this functional area. Eight involved procedural or programmatic deficiencies, and of these, 6 resulted in missed
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TS surveillance, which are discussed in the n'aintenance/
Surveillance section of this report. The runaining two LERs related to equipment problems and design deficiencies, and both involved pre-service wor Management involvement to ensure quality in this area was mixe !
Managemei.t attention was inadequate in the work associated with the EQ of components as evidenced by the failure to implement
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l~ necessary management and programmatic controls to ensure that EQ equipment was qualified for its intended service, and installed and maintained per the EQ requirements. Management involvement was weak regarding the identification af the design error associated with the CRVS and in resultant corie~ctive actions. Furthermore, the licensee only conducted b review to verify that there were no similar safety-related design change errors after the NRC raised concerns during an enforcement conference. The presence or influence of corporate engineering did not appear as evident as expected. The licensee's submittal of and participation in the review concerning a reactor coolant system flaw indicated that management did not have aggressive control over the priorities and procedures of the activit On the positive side, the licensee's implementation of Generic Letter 83-28 was good, and included a program for life cycle replacement of reactor trip breaker components that was more conservative than that recommended by the owners grou Once identified, the CRVS design errors were quickly correcte Systems engineers have been assigned to each plant system, thus providing a cognizant engineer who is responsible for tracking activities affecting each assigned system, including modifications, maintenance, and functional or post-maintenance testing. The operational readiness team identified the site nuclear engineering staff as a strength during observations of control room activitie The approach to resolution of technical issues from a safety standpoint was mixed. With regard to EQ concerns, there was an apparent lack of uriserstanding of the issues, as evidenced by incomplete and erroneous evaluations presented to inspectors and submittals made to NRR. Examples are inaccurate initial ev.aluations of J505 pressure switches, eval c tions of mixed grease in Limitorque valve motor operators, and the qualification of Bunker Ramo containment penetration assemblies. With regard to the CRVS design error, technical performance was weak in that some personnel showed inadequate understanding of the system, and personnel errors delayed identification of the erro From the time the design error was made in December 1986 until it was discovered by the licensee in November 1987, the licensee missed opportunities to identify the erro On the positive side, conservatism was demonstrated in the handling of the inconsistencies in preoperational testing of snubbers, of the technical aspects of the reactor coolant system flaw resolution, and of the retest of the carbon dioxide fire suppression systems protecting four plant areas to prove that they meet all acceptance criteri The licensee's onsite fire protection staff exhibited the necessary technical and regulatory expertise to manage the fire protection program effectively, as specified by NRC requirement _-
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L' 1 L .The licensee's responsiveness.to NRC. initiatives was mixe '
Although the licensee certified that its. simulator met the !
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requirements of ANSI /ANS 3.-5-1985 well ahead of the 1991.due-date, several~ simulator deficiencies, ~ such as. inopegable plant
= malfunctions',' inoperable indications and recorders, unexplained perturbations of the simulator, and inconsistent pavameter values for the conditions present, were identified by'the NRC while conducting operator licensing exams. This indicated a L less than rigorous certification effort.- The quality of- .
L submittals'to NRR was mixed. .One poor submittal dealt with the mixed' grease' issue'. Considerable staff effort and repeated.
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submittals were needed to resolve the-issue. The NRC staff '
expended resources reviewing' licensee positions that were )
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subsequently. changed. Test data that were provided were not
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credible for determining valve operability'after an' acciden However,' submittals associated with Generic Letter 83-28 demonstrated a' good understanding of the issues. Sound justification supporting the position was submitted in a Similarly, the licensee's
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-responsive and_ timely manne responsiveness to'NRC. initiatives involving the CRVS was .
generally adequate. However, the occurrence of this incident represented inadequate licensee responsiveness to previously identified problem . Staffing. appeared to be adequate. The onsite technical staff has:
considerable experience from other stations and the Navy, and.from preoperational testing at Braidwood. . This was also identified during the operational readiness inspectio Training .and qualification effectiveness in this functional area was adequat In general,Lpersonnel were knowledgeable of their assigned task Both contractor and CECO personnel involved in the snubber. performance evaluations were properly qualified in accordance with defined procedures and instructions. The licensee had implemented a formal EQ training program for new personnel; however, many of the appropriate staff had not received this trainin In many instances there.was evidence that technical expertise was not available in either corporate or site engineering to provide adequate technical oversight of engineering work performed by contractor ~ Performance Rating The licensee's performance is rated Category 2 in this are ,
The licensee's performance was rated Category 2 in the previous assessment perio i
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- Recommendations Non G. Safety Assessment / Quality Verification -1 . Analysis This functional area was evaluated on the results of' ten routine
. inspections conducted by the resident inspectors. In addition, the NRC staff's reviews of licensee submittals and requests for amendments to the Operating Licenses were considere l The enforcement history in this functional area was goo i
.Although four Severity level IV violations were issued, al l four were identified during the previous assessment perio Three of the violations involved deficiencies in verifying correct electrical and instrumentation system installation and line-ups. These violations were identified during an inspection )
which also identified a deviation from a saf;.tv evaluation report (SER) commitment concerning alignment t ., nydrogen recombiner isolation valve. The violations and deviation indicated a weakness in quality oversight of the station's as-built configuration. The fourth violation involved the inadequate review of six emergency procedures by the onsite review committee. The procedures were approved for issuance although they erroneously directed the use of a Unit 1 .
procedure in response to a safety injection initiation in l Unit 2. -The licensee was responsive to the NRC in addressing i the concerns associated with the violations. During the previous assessment period, four violations (one Severity Level IV and three Severity Level V) were issued in the functional area of Quality Programs and Administrative Controls Affecting Quality. Although the two functional areas do not have a one-for-one correlation, they are simila '
Management's involvement to assure quality was evident on both the corporate and site levels throughout the assessment perio Three self-assessment groups maintained by the licensee in accordance with the station's Technical Specifications (TS) were !
the onsite review committee, the offsite review committee, and the onsite nuclear safety group. These groups satisfactorily
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reviewed pertinent documents and activities as required by the TS, and were generally effective in identifying and tracking corrective actions. Also, the Braidwood Regulatory Assurance staff contributed strongly in this area by reviewing a variety of station, NRC, and industry documents and by identifying, tracking, and reporting performance trends. The Quality Assurance Department was generally effective in overseeing and reviewing licensee activitie In addition, the licensee's corporate management has regularly monitored selected parameters to
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determine functional area strengths and weaknesses, and corporate personnel and' personnel from other stations have conducted periodic audits of functional areas to identif improvement item Toward the end of the assessmen_t period, the licensee conducted a "M0CK SALP" evaluation of Braidwood's performance; the station has determined actions to,iddress identified weaknesse The effectiveness of the licensee's self-assessment efforts is reflected in the station's event history. Though.still high, the number of_LERs declined from 71 for Unit I during the previous period to 28 for Unit 1 and 31 for Unit 2 during this period. The number of Unit I reactor trips decreased from 18 to 6. Unit 2 had 17 reactor trips, a number of which could be associated with operating a newly-licensed unit, especially the difficulty of controlling water _ level in the. sensitive Westinghouse D-5 steam generators. Neither unit tripped in the last 2-1/2 months of the assessment period, indicating that the correction of operating problems has been effective. This improvement reflects in part the efforts of the station's trip prevention committee (replaced by the Event Frequency Reduction Program in December 1988) and the~" Partners in Performance" group. The latter group, composed of personnel from Westinghouse, Sargent &
Lundy, and CECO focused on improving feedwater control to !
minimize plant trips caused by high or low steam generator water i level .i Of particular concern was the number of personnel errors compiled during the previous assessment period. Although the percentage of personnel errors declined from 52% (37 of 71) to 42% (25 of 59), the number remains hig In general, the licensee's management demonstrated active I participation in all activities related to license amendment applications, generic letters, bulletins, requests for relief from the regulations, and other _ technical reviews that are required by the regulations. Except for the instances noted in the Engineering / Technical Support section, the submittals have been of good quality and have not required significant rework ,
to comply with NRC requirements. In one instance, a TS change '
request was returned to CECO because it contained insufficient information to conduct a technical review. The submittals since then have been of much better quality and have not required much phone contact to clarify information. Additionally, the
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licensee has been responsive to questions and comments on amendment / relief requests as well as to staff technical reviews and requests for additional information. In some cases, the licensee has provided information for studies and surveys, at NRR's request, which are not required by regulations. The licensee has been responsive to these requests and generally provided complete information in a very timely manne __ . .-. - _ _ - --
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The licensee assigns higher priority to issues'that have a h greater safety significance. The . technical.' resolutions - and the overall responsiveness are generally adequat The licensee's resolution of technical issues from i safety standpoint was good. The corrective actions for e.qkipment problems and operational concerns identified in LERs and DVRs ;
were generally sound and thorough. Recurrent problems, most
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. notably ESF actuations caused by spurious radiation monitor .,
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spikes and reactor trips resulting from difficulties controlling j steam generator water levels, were typically resolved so that 1 they no longer contributed to reportable events by the end of.'
the assessment period. One issue the licensee did not resolve promptly, however,. involved several missed or improperly performed TS surveillance from September 1987 to September-1988. A licensee assessment of the surveillance program was conducted only after the NRC spotlighted the concer Staffing of the QA Department, Regulatory Assurance staff, onsite' review committee, and onsite nuclear safety group was maintained at appropriate levels of technically qualified individuals capable of performing in depth technical audits and-evaluations. A major management change involved the-replacement of_the Station Manager with the former Station Manager at Byron ~
Station in March 1988. The changeover was smooth, and the new Station Manager has been effective in guiding Braidwood's
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transition to a fully operational plan . Performance Rating The licensee's performance is rated Categcry 2 in this are Because this is a new area, no rating is available for the previous assessment perio . Recommendations l
Non !
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' . SUPPORTING DATA AND SUMMARIES
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q Licensee Activities -
1 Unit 1- fl i .
Braidwood Unit 1 began the assessment period with a scheduled -
surveillance outage. The outage ended on March 20, 1988, !
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o but.the unit was shut down again on March 21 because of EQ deficiencies identified during an NRC_ inspection. .A Confirmatory.
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Action Letter (CAL) was issued on March 23 to document licensee activities taken to address lubricant deficiencies in motor-operated valves. The unit was returned to power on April 24, and the CA was closed on April 29. -Thereafter, the unit was operated at power levels up to 100%, with the exception of outages to correct equipment problems and trip recovery periods. Unit I was declared in commercial service on July 29,.1988. The unit was shut down at the close of the assessment period to repair the leaking. pressurizer manwa Unit 1 experienced 17 ESF actuations, including 1 safety injection with water injecte Six reactor trips occurred during this assessment perio Three reactor trips (one manually initiated) occurred when operating above 15% power and three (one manually initiated)
occurred without rod motion. Three trips were the result of personnel errors,'two trips were the result of equipment failures, and one trip was externally induce Significant outages and events that occurred during the assessment-period are summarized below:
Significant Outages and Events From January 1 through March 20, 1988, Unit I was shutdown for its 18-month surveillance outage, From March 21 through April 24, 1988, Unit I was shutdown because'of an EQ concern with the grease used in motor-operated valve . During June 10-14, 1988, Unit I was shutdown for the cleaning of movable incore detector thimble On July 29, 1988, Unit I was declared in commercial operatio During September 17-20, 1988, Unit I was shutdown because of out-of-specification secondary chemistry following a chemistry excursion even _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ - _ - _ _ _ _ _ _ _ _ _
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' During October 16-19, 1988, Unit I was shutdown following a trip on the loss of one reactor coolant pump. The power supply for the ' pump.'did not automatically transfer to a vital bus following an offsite transmission liqe faul '
-i During October 31 through November 1,1988, Unk-1.was brought to Mode'2 to repair a leak in the hydraulic '
actuator for the 1A main steam isolation valve (MSIV). On November 15, 1988, Unit I was manually tripped because of the loss of air pressure in the instrument air syste The unit remained shutdown through November 16 while repairs were made to the sheared instrument air lin From Jan;ary 19, 1989, through the end of the assessment-period, Unit I was shutdown for investigation of reactor-coolant system (RCS) leakage and subsequent repair of th leaki',g pressurizer manwa . Unit 2 Braidwcod Unit 2 began the assessment period in preparation for initiai reactor criticality, which occurred on March 8, 198 The unit completed all low power (<5%) testing on March 23, but was subsequently shut down for the resolution of environmental qualification issues similar to those of Unit A CAL for Unit 2 was issued on March 23 and closed on May 16. The unit was issued its full power license on May 20, 1988, and was synchronized to the grid for the first time on May 2 Thereafter, the unit was operated.at power levels up to 100%,
with the exception of outages to correct equipment problems and trip recovery periods. The unit was declared in commercial service on October 17, 198 Unit 2 experienced 22 ESF actuations and 17 reactor trip There were 11 trips (3 manually initiated) when operating above 15% power, 4 (1 manually initiated) at below 15% power, and 2 without rod motion ~. Of the 17 trips, 4 were the result of personnel / procedure errors, 10 were the result of equipment failures, 2 were the result of procedural inadequacies, and I was the result of a lighting strik Significant outages and events that occurred during the assessment period are summarized below: j j
Significant Outages and Events l 1 On March 8, 1988, Unit 2 achieved initial criticalit l
' From March 23 through May 16, 1988, Unit 2 was shutdown because of EQ concerns with the grease used in motor-operated valves.
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, On May 20, 1988, Unit 2 received its full power operatin l licens j
- d '. On May.'25, 1988, Unit 2 was synchronized to the' grid for !
, the first tim I
. s,- During June 7-9, 1988,-Unit 2 was shutdown to replace a'
motor operator for a safety injection isolation valve for which EQ documentation could not be locate ~ On September 15, 1988, Unit 2 was brought down to Mode 2
, because its secondary chemistry was out of specification
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following a chemistry excursio On September 23,-1988, Unit 2 was tripped from full power, i bringing its power ascension testing process to a close.
< From September 30 through October 5, 1988, Unit 2 was shutdown for secondary cleanup.following a condenser tube ruptur n October 17, 1988, Unit 2 was, declared in commercial operatio On October 17, 1988, Unit 2 tripped when a lightning strike caused overvoltage devices in the rod control cabinets to actuate, resulting in the insertion of control. rod During October 25-30., 1988, Unit 2 was shutdown for cleaning a of the condensate pump suction strainers and for inspection I and cleaning of the condense i On November 15, 1988, Unit 2 was manually tripped'because of the loss of air pressure in the instrument air syste The unit remained shutdown through November 17 for repairs ;
to the sheared instrument air lin During December 14-17, 1988, Unit 2 was shutdown for repair ,
of an RCS leak and other maintenance wor j 1 Inspection Activities j
. Forty-one inspection reports are discussed in this SALP report (January 1, 1988 through January 31,1989) and are listed in Paragraph 1 of this section, Inspection Data. Table 1 lists the violations per functional area and severity level. Significant inspection activities are listed in Paragraph 2 of this section, Special Inspection Summar . Inspection Data Unit 1 Docket No: 50-456
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, Inspection Report Nos.: 87038,;87041, 87044. through 87046, p 88002 though 88023, 88025 through 88033, and,89002 through 8900 < Unit 'i-Docket'No: , 5~0-.457 , i,. .
Inspection Report Nos.: 87036, 87039,-8/045 through'87047,.
88002 through 88023, 88025 through 88033,'and 89002 through 89004.
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Table-1 Number of Violations in Each Severity Level Unit 1 Unit 2 Both Functional Area III IV V III IV V III IV V- Plant Operatiens -
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3 - Radiological Control Maintenance / Surveillance -
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2 - Emergency Preparedness -
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. Security - - - - - -
1 1
- Engineering / Technical Support 1 -
1* -
2* 1* 1 2 1* Safety Assessment / Quality - - - -
2 - -
2 -
Verification Unit 1 Unit'2 Both TOTALS III IV V III IV V III IV V 1 3 - -
7 - 2 11 -
- Three Severity Level V's and one Severity Level IV were discussed during the previous SALP. However, these violations were issued during this assessment perio . Special Inspection Summary During February 29 through May 4, 1988, a special EQ inspection of electrical equipment within the scope of 10 CFR 50.49 was conducted (Inspection Report Nos. 456/88005;
, 457/88006). During March 1-17, 1988, a special inspection of licensee action to address operability problems with the control room ventilation systems was performed (Inspection Report No. 456/88007).
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m During. February 16 through March 7,_1988, a special operational readiness inspection was performed prior to full power licensing of Unit 2 (Inspection Report No. 457/88007),
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i di During March 14-25, 1988. aspecialsafetyinshectionwas-performed by the resident inspectors to address an event involving the inoperability of the 28 safety-injection pump (Inspection Report No.-457/88012). During March 14-25,'1988,'a special safety inspection was conducted by the resident inspectors to evaluate the inoperability of non-accessible area exhaust filter plenums'on two separate occasions (Inspection Report Nos. 456/88011; 457/88013). During April 20-21, 1988,~a special safeguards inspection H concerning an unprotected vital area barrier opening was-conducted (Inspection Report Nos. 456/88015; 457/88016). On June 20, 1988, a special security inspection was conducted to address the inattentiveness of two security officers (Inspection Report Nos. 456/88020; 457/88020). During October 15 through November 3, 1988, a special-inspection of several missed or improperly performed surveillance was conducte C. Escalated Enforcement Actions On May 6,1988, a Notice of Violation and proposed imposition of civil penalty for $50,000 were issued for three design control deficiencies which resulted in degradation of the control room ventilation system. The licensee paid the $50,000 Civil Penalty on November 18, 1988 (Enforcement Notice N EN-88-36, Enforcement Case No. EA-88-091, and Inspection Report No. 456/88007). On September 16, 1988, A Notice of Violation and proposed imposition of civil penalty in the amount of $50,000 were issued to the licensee. This action was based on two separate examples of inattentiveness on the part of security officers '
. assigned as compensatory measures for an unlocked and unalarmed vital area door. The licensee paid the $50,000 civil penalty on October 14, 1988 (Enforcement Notice No. EN-88-074, t Enforcement Case No. EA-88-174, and Inspection Report 1 Nos. 456/88020; 457/88020). ! On November 23, 1988, a Notice of Violation and proposed imposition j of civil penalty in the amount of $75,000 was issued to the licensee. This action was based on a number of failures to adequately implement the EQ requirements of 10 CFR 50.4 Because both units were licensed after November 30, 1985, this
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enforcement action was proposed under the guidance of 10 CFR Part'2, l Appendix C, rather than the " modified enforcement policy relating to 10 CFR 50.49." The licensee paid the $75,000 civil penalty on' November 23, 1988 (Enforcement Notice No. EN-88-101, Enforcement Case No. EA-88-198, Inspection Repo'rt Nos. 456/8800};457/88006).
. Confirmatory Action Letters Two separate confirmatory action. letters (CAL RIII-88-005 and CAL RIII-88-006) were issued for Braidwood Units'1 and 2 regarding mixed ~ lubricants in safety-related Limitorque valve operators. The two CALs required the licensee to sample the lubricant (grease) i all. safety-related Limitorque valve operators, to' complete a visual inspection and laboratory analysis of all samples,' and to completely
, relubricate the operators in which contaminated or mixed grease was found. The CALs were closed on April 29 and May 16, 1988, for Units 1 and 2, respectivel License Amendments Issued
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Amendment N Description Oate 5 Use of the dc crosstie with a 01/27/88 failed battery charge Addition of two radiation monitor /22/88 7- Elimination of setpoint 04/08/88 verification in the monthly or quarterly trip-actuating device operational' test for undervoltage and underfrequency relay Separation of the gaseous waste 04/15/88 j management system oxygen analyzer ;
into its two major component '
9 One-time extension of the 06/10/88 surveillance interval for the power range neutron flux high 4 setpoin '
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10 Six miscellaneous change /27/88 ,
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11 Modification of the liquid 08/05/88 i radwaste effluent line flow monito Removal of response time table /27/88 13 Amended Physical Security Pla /19/88 i
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~ Review of Licensee Events Reports Submitted by the License . Unit 1-LER Nos: 87061, 87063, and 88001~through 88026 Unit 2 LER Nos': 88001through88010,and88012thr'jugh8803 s. ~ .
Collectively, 59 LERs were issued 'in accordance'with NUREG-1022 guidelines during the assessment period, and are addressed in this report. There were'28 LERs reviewed for Unit 1, and 31 LERs were reviewed for Unit Table 2 shows a cause comparison-for the Braidwood unit Table 2
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Cause Areas Unit 1 Unit 2 j Personnel Errors 13 12 Design Deficiencies 0 2 t
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External 2 1 1 Procedure Inadequacies 5 3 Equipment / Component 7 12 Other/ Unknown 1 1 TOTAL 28 31 Table 3 shows a cause comparison of SALP 7 and SALP Table 3
1 (13 M0) (13 M0)
Cause Areas SALP 7 SALP 8 Personnel Errors 37 (52.0%) 25 (41.7%)
Design Deficiencies 3 ( 4.0%) 2 ( 3.3%) '
External Causes 0 ( 0.0%) 3 ( 5.0%)
Procedure Inadequacies 11 (15.5%) 8 (13.3%)
Equipment / Component 11 (15.5%) 19 (32.2%) j
. Other/ Unknown 9 (13.0%) 2 ( 3.3%) !
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TOTALS 71 59
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FREQUENCY (LERs/MO) .5 I
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NOTE: The above LER information was derived from a review of ;
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LERs performed by the NRC staff and may not completely coincide with P s licensee's cause assignment i
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