IR 05000456/1989005
| ML20248J733 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 03/29/1989 |
| From: | Hinds J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20248J732 | List: |
| References | |
| RTR-NUREG-0876, RTR-NUREG-876, TASK-2.K.2.13, TASK-TM 50-456-89-05, 50-456-89-5, 50-457-89-05, 50-457-89-5, GL-85-03, GL-85-3, IEB-87-002, IEB-87-2, IEIN-88-016, IEIN-88-16, NUDOCS 8904170027 | |
| Download: ML20248J733 (21) | |
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U.S. NUCLEAR REGULATORY. COMMISSION
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REGION.III
Docket Nos._50-456; 50-457 License Nos. NPF-72;.NPF-77-Licensee: Commonwealth Edison Compa y Post Office Box-767
.-Chicago, IL 60690 Facility Naiae: 'Braidwood Station, Units.1 and 2
' Inspection At: Braidwood Site,.Braidwood, Illinoi-
.i Inspection Conducted:
February 3 through March 18, 1989 Inspectors:
T. M. Tongue T. E. Taylor
.G. A. VanSickle W. J. Kropp R. M. Lerch
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J.MEHind's,Jr.,
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"5/z.9/69 Approved
actor Projects Section 1A Date '
Inspection Summary Inspection from February 3 through March 18,1989 (Report Nos. 50-456/89005 (ORP): 50-457/89005(DRP))
Areas Inspected:
Routine, unannounced' safety inspection by the resident inspectors of licensee action on previously identified items; licensee event report review; regional request; follow-up on TMI action item; operational safety verification; engineered safety. feature ' systems; monthly maintenance /
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modification observation; monthly sure/eillance observation; allegation followup; continued security guard strike; training effectiveness; report review; and meetings ana other activities.
-Results:
No violations or deviations were identified.
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DETAILS
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Persons Contacted Commonwealth Edison Company (CECO)
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- T.' J. Maiman, Vice President, PWR Operations
- R. E. Querio, Station' Manager-
- D. E. O'Brien, Technical Superintendent
- K. L. Kofron, Production Superintendent
- S. C. Hunsader, Nuclear Licensing Administrator G. R.. Masters, Assistant Superintendent'- Operations
- G. E. Groth, Assistant Superintendent - Maintenance
- R. J. Legner, Services Director M. Lohman, Assistant Superintendent - Work Planning and Startup P. Smith, Operating Engineer - Unit 1
- R. J. Ungeran, Operating Engineer R. Yungk, Operating Engineer - Unit 2
- W. B. McCue, Operating Engineer - Unit 0
- R. D. Kyrouac, Quality Assurance Supervisor
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- P. L. Barnes, Regulatory Assurance Supervisor R. Lemke, Technical Staff Supervisor J. Gosnell, Quality Control Supervisor-l
- R. E. Aker, Radiation / Chemistry Supervisor
'l F Willaford, Security Administrator R. Byers, Site Superintend:i. - H :iects and Construction Services Dept.
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W. McGee, Training Superu sor l
- G. 'J. Plim1, Quality Assurance Program Nnager i
- L. W. Raney, Nuclear Safety Supervisor S. Hedden, Master, Instrument Maintenance
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R. Hoffmra, Master, Mechanical Maintenance
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J. Smith, Master, Electrical Maintenance
- E. W. Carroll, Regulatory Assurance i
- P. G. Holland, Regulatory Assurance
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- H. Pontious, Operations Staff i
- Denotes those attending the exit interview conducted on March 17, 1989,
and at other times throughout the inspection period.
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The inspectors also talked with and interviewed several other licensee
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employees, including members of the technical and engineering staffs, i
reactor ar.d auxiliary operators, shift engineers and foremen, electrical, mechanical and instrument maintenance personnel, and contract security personnel.
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Licensee Action on Previously Identified Items I
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Open Items
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j (Closed) 456/86027-02, 456/86045-01; 457/86033-01, 456/87015-02, i
456/87025-01, 456/87025-02, 456/87025-03, 456/87025-10, 456/87041-02; 457/87039-04, 456/87041-06, 457/87039-08, 457/87039-10, 457/86033-02, 457/86033-03, 456/86033-06, and 457/86033-08:
These open items have been closed during this
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i inspection period, based on a-directive by the Division Direc' tor,
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Division of Reactor Safety, Region III. The decision to close these items is based on the length of time the item has been in-existence and the. recognition of limited ' safety significance.
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Unresolved Item (Closed) 456/86025-03: Administrative procedures needed for
' Inservice Testing (ISI)~ program-implementation. The licensee has
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now implemented administrative procedure BwVP 200-9, Nondestructive-Examination Requirements for Unit..This procedure, approved December 6, 1988, identifies in a matrix format.all of the ISI.
testing requirements identified for a specific unit. The inspector considers this sufficient to identify the unit testing requirements.
This item is considered closed.
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Violations (Closed) 456/87023-01:
Licensee personnel failed to properly implement requirements of BwAP 1400-1 resulting in a violation of.
the Technical Specification (TS) Section 4.0.2.
The examples noted-in.the violation occurred as a result of scheduling errors.related to partial surveillance, changes in test frequency, and personnel miscommunications. The licensee's corrective actions included:
revising the surveillance data cover sheet to indicate partial surveillance; revised procedures to ersure surveillance due dates are checked if the base frequency is changed;.and discussions with operations personnel with emphasis on-root cause and prevention of repeat discrepancies. The licensee's surveillance program has been and continues to be an area of concern for the NRC resident inspectors (RIs) at Braidwood. The RIs are monitoring the licensee's progress in this area.
Based on the licensee's corrective actions, this item'is considered closed.
(Closed) 456/88008-01; 457/88009-01:
Improper use of Measuring and Test Equipment (M&TE) by operations personnel. On February 7 and 9, operations personnel were using M&TE.for surveillance data
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acquisition. On one occasion improper use of the M&TE resulted in two unplanned auto starts of an auxiliary feedwater pump. A check of training records revealed that the operators received no training j
on the use of M&TE, for which a notice of violation was issued.'
Corrective actions implemented included:
tailgate training sessions for operations personnel with emphasis on proper use of the Volt-Ohm meter, inclusion of Volt-0hm meter operation instruction in the initial non-licensed operator training and in the licensed operator's training matrix, and Braidwood site specific training for licensed operators by Westinghouse Corporation on the Solid State Protection System with a simulation of the AFW auto start events.
The licensee's implementation of these corrective actions are considered adequate in scope and content.
This item is considered
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closed.
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L (Closed) 456/88008-02; 457/88009-02: Deficient control room logs in
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the areas of completeness of log entries, equipment status changes, and log entry legibility. The inspectors have continued monitoring the adequacy of the log keeping to determine if' recent improvements were sustained since report 456/88029 issuance.
The inspectors have concluded that recent. improvements were sustained relative to legibility, logging plant activities, and completeness of entries.
This area will be periodically monitored to assess continued licensee performance.
This item is considered closed based on j
recent licensee performance.
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I. E. Bulletin (Clesed) 456/87002-BB; 457/87002-88:
Fastener Testing to Determine Conformance with Applicable Standards. The inspection of licensee i
activities on this bulletin have been previously documented in NRC
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Inspection Report 456/87044; 457/87045.
During that inspection the inspector witnessed and verified that the required fastener sample selection was representative of available fasteners, purchase order data was available, and samples were properly tagged.
Since that inspection the licensee results of the fastener testing has shown satisfactory results concerning fastener material acceptability.
Also, in accordance with Bulletin 87002, Supplements 1 and 2, the licensee has submitted to the NRC the required vendor lists for safety-related and non-safety-related purchased fasteners.
TI-2500/26 has been deleted as its inspection requirements have i
been essentially completed.
NRC's Vendor Inspection Branch is preparing another TI that will address bolting material require-ments. Therefore, Bulletin 87002 is considered closed for Units 1 and 2.
If the new TI references Bulletin 87002, it will be i
reopened and re-evaluated at that time.
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Safety Evaluation Report (SER)
g (Closed) 457/86000-11:
Remote Shutdown Capability - Section 7.4.2.2.
This item has been closed during this inspection period based on a directive by the Division Director, Division of Reactor Safety, Region III. Our decision to close this item is based on the length of time the item has been in existence and the i
recognition of limited safety significance.
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Generic Letter (GL)
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(Closed) 456/85013-HH; 457/85013-HH: Transmittal of NUREG-1154 l
Regarding the Davis-Besse Loss of Main and Auxiliary Feedwater (AFW)
Event. GL 85013 concerned a Toledo Edison Company nuclear plant
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(Davis-Besse) that experienced a partial loss of feedwater while i
operating at 90% power.
Following a reactor trip, a loss of all feedwater occurred.
The potential of a similar event occurring at the Braidwood Station is very low due to the reliability and diversity of the AFW system at Braidwood.
The NRC inspector agrees with the licensee's evaluation of GL 85013 relative to Braidwood station.
The only GL 85013 issue that is relevant to Braidwood
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is the ove speed reset on the diesel driven AFW pump. The inspector's review identified that through training and administrative procedures, the licensee has taken adequate steps to i
preclude a surtained loss of the diesel driven AFW pump due to overspeed reset activities. The remainder of the Braidwood AFW system is sufficiently different to preclude a total loss of feedwater as experienced at the Davis-Besse facility. Therefore, this item is considered c19 sed for Units 1 and 2.
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No violations or deviations were identified.
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3.
!.icenseeEventReport(LER)__ Review (92702)
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Through direct observations, discussions with licensee' personnel, and review of records, the following event reports were reviewed to' determine that deportability 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 (TS):
(Closed) 456/88002-L1: Reactor Trip and Safety Injection Due to Cognitive Personnel Error. Tho trip and safety injection occurred when an instrument mechanic mistakenly applied a test pressure to an active containment pressure channel, instead of the one in test.
The corrective action of the LER has been updated to state that the analog test and channel calib.ation surveillance for each containment pressure channel is being revised so that an input insufficient to trip the channel will be applied first. This practice will permit verification that inputs are being applied to the channel in test without risking completion of the protection system logic which would result in a reactor trip. This item is considered closed.
(Closed) 456/88011-L1:
Reactor Shutdown Required as a Result of
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Valve 2SI8809B Declared Inoperable Due to Non-Environmentally-Qualified Motor. This LER originally documented a shutdown of Unit 2 based on the lack of environmental qualification (EQ)
documents for the motor operator of valve 2SI88098. Westinghouse has since confirmed that the motor operator was manufactured from the same material as that of the motor which underwent Limitorque qualification testing.
Based on this information, a Commonwealth Edison letter of February 17, 1989, has withdrawn the LER. The inspector has no further concerns. Tnis item is considered closed.
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(Closed) 456/88021-L1.and 457/88025-L1:
Each of these LERs discussed
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a missed axial flux difference surveillance.
The LERs have been
revised to update their corrective action sections, which state that
"O frequency surveillance (those that do not have specific time intervals for performance) are being reviewed to ensure that they l
are contained within the scope of other procedures or instructions.
This is consistent with corrective action being taken to address i
violation 456/88028-01; 457/88028-01.
These LERs are considered l
closed.
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(Closed) 456/89001-LL:
Reactor Trip Due to Spurious Loss of Output-Voltage on Instrument Inverter 112.
On February 6, 1989, at 1:22-l p.m. a reactor trip signal was generated due to a.211 second i
duration loss of output voltage on instrument inverter 112. The loss of output voltage from inverter 112 caused the intermediate range high flux bistable from N36 to revert to its ESF safe configuration which initiates a reactor trip signal.
Interviews I
with licensee personnel in the area of the 112 inverter indicated that their activities did not contribute to the inverter's loss of output voltage.
Due to the short duration of the loss of output voltage, the licensee has concluded that the event was not I
due to someone cycling the inverter's output breaker. There have l
not been any previous or subsequent reactor trip events caused by a i
spurious perturbation on the instrument inverters.
The root cause of this event is still under investigation. The Unit 1 instrument inverters are scheduled for an inspection during the next major i
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outage. This LER is considered closed.
If the license 2 determines a root cause as a result of the scheduled inspections, a supplement to this LER will be issued and subsequently reviewed by the NRC, In addition to the foregoing, the inspector reviewed the licensee's Deviation Reports (DVRs) generated during the inspection period.
This was done in an effort to monitor the conditions related to plant or personnel performance, potential trends, etc.
DVRs were also reviewed to ensure that they were generated appropriately and dispositioned in a manner consistent with the applicable procedures and the QA manual.
No violations or deviations were identified.
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Regional Requert (92705)
Control of Contractor Work By a memo, dated February 27, 1989, NRC Region III requested the resident inspectors.to determine what measures are in place to control contractor work at the Braidwood Station.
Control of contractor work is the responsibility of the Project and Construction Services (PACS) group.
In conjunction with the Maintenance Department, PACS decides the percentage of outage work to be performed by contractor personnel, based on the availability of and demands on the i
station work force. Jobs assigned to contractors are typically those
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which are particularly suited to contractor craft skills, such as valve l
repacking and pipe welding.
Witn the recent Unit 2 18-month surveillance outage, PACS nas initiated a program in which contractor supervisors receive formal training concerning station administrative procedures and other important information.
Supervisors, in turn, pass on the information to tradesmen.
Contractor personnel are thus thoroughly versed in station practices before work activities begin.
As part of this effort, contractor workers
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cre provided with pocket-sized handbooks containing important information l
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and phone numbers. Commonwealth Edison plans to continue this program
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for future Braidwood outages and to implement similar programs at its other nuclear stations.
With regard to actual work activities, all contractor produced work packages are reviewed by PACS and other station departments prior to
final approval by the Assistant Superintendent for Maintenance. The station's quality organizations are involved in the review process, and the Quality Control Department selects hold points. Where possible, i
contractors are instructed to use station procedures (necessary training l
is provided). Contractor activity associated with each work package is l
monitored, coordinated, and observed by a designated PACS engineer, who l
also reviews documentation of completed work.
The site and corporate
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Quality Assurance organizations periodically audit contractor work.
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Request for Information on DC Electrical Grounds By request, dated March 2, 1989, Region III Division of Reactor Projects, requested that the resident inspectors provide copies of the licensee's actions on DC electrical grounds in followup on enforcement actions at the Quad Cities station. Through assistance from Regulatory Assurance the resident inspectors provided copies of licensee internal memos on Information Notice'88-16, Temporary Procedure, "125 VDC ESF Bus Grounds,"
dated July 15, 1988, and Permanent Procedure, 2Bw05 DC-11 Rev. O, "AAR 125 VDC ESF Bus Grounds," dated January 24, 1989.
i No violations or deviations were identified.
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Follow-up on TMI Action Item
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II.K.2-13 - Thermal Mechanical Report - Effect of High-Pressure Injection on Vessel Integrity for Small-break Loss-of-Coolant Accident with no j
Section 15.5 of NUREG-0876 identifies that the a
licensee has submitted a generic program through the Westinghouse Owners i
group. This report, Topical Report WCAP-10019, addresses the II.K.2-13 l
issue. The NRC staff has concluded that the licensee's response is i
adequate. Additionally, Generic Letter 83-37 clarifies the requirements of this item and states that no additional licensee response is required.
Changes to the Technical Specifications for this item will be determined j
and issued as necessary.
Based on the NRC staff's review of this item
there are no further concerns.
This item is considered closed for
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Braidwood Units 1 and 2.
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No violations or deviations were identified.
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Operational Safety Verification (71707)
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was being operated in conformance with the licenses and regulatory l
requirements and that the licensee's management control system was
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effectively carrying out its responsibilities for safe operation.
This was done on a sampling basis through routine direct observation
of activities and equipment, tours of the facility, interviews and j
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discussions with licensee personnel, independent verification of safety system status and limiting conditions for operation action. requirements
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(LC0ARs), corrective action, and review of facility records.
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On a daily basis the inspectors verified proper control room staffing and access, operator behavior, and coordination of plant activities with ongoing control room operations; verified operator adherence with the latest revisions of procedures for ongoing activities; verified operation as required by Technical Specifications (TS); including
compliance with LC0ARs, with emphasis on engineered safety features (ESF) and ESF electrical alignment and valve positions; monitored.
instrumentation recorder traces and duplicate channels for abnormalities; verified status of various lit annunciators for operator understanding, off-normal condition, and corrective actions being taken; examined nuclear instrumentation (NI) and other protection channels for proper operability; reviewed radiation monitors and stack monitors for abnormal conditions; verified that onsite and offsite power was available as required; observed the frequency of plant / control room visits by the station manager, superintendents, assistant operations superintendent, and other managers; and observed the Safety Parameter Display System (SPDS) for operability.
During tours of accessible areas of the plant, the inspectors made note of general plant / equipment conditions, including control of activities in progress (maintenance / surveillance), observation of shift turnovers, general safety items, etc. The specific areas observed were:
Engineered Safety Features (ESF) Systems Accessible portions of ESF systems and components were inspected to verify:
valve position for proper flow path; proper alignment of power supply breakers or fuses (if visible) for proper actuation on an initiating signal; proper removal of power from components if required by TS or FSAR; and the operability of support systems essential to system actuation or performance through observation of j
instrumentation and/or proper valve alignment.
The inspectors also visually inspected components for leakage, proper lubrication, cooling water supply, etc.
Radiation Protection Controls i
The inspectors verified that workers were following health physics procedures for dosimetry, protective clothing, frisking, posting, etc., and randomly examined radiation protection instrumentation for use, operability, and calibration.
During observation of plant activities on February 17, 1989, the inspectors noted the egress of about thirty personnel from the
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Unit 2 containment.
The technique of removal of protective clothing (anti-Cs), hand frisking, whole body monitoring, conduct in the change area, and handling of potentially contaminated material were noted. A number of inconsistencies were noted, such as shaking coveralls rather than rolling them inside out during removal, variations
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in the use and non-use of gloves during clothing removal and frisking hands and dosimetry. An individual was noted in the change area in minimum anti-Cs (gloves, shoe covers, and head cover)
removing bags of used anti-Cs.
This individual was among the people in various stages of anti-Cs clothing remova?. This same individual inside the change area and the individual receiving and rebagging-
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the bags of anti-Cs on the clean side of the area were observed I
brushing their street clothing against the potentially contaminated l
bags of anti-Cs without performing a follow-up frisk.
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also appeared that a number of people were confused with respect to the exit path, change-out technique and survey procedures. Although this did not appear to result in a personal contamination, it has the potential for it as well as' transportation of contamination into non-contaminated areas.
It was also noted that several radiation technicians were attempting to control the activities, but due to the large number of people
exiting, had poor success. This was immediately brought to the
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attention of radiation protection and station management personnel.
They promptly responded by rearranging the step-off pad trea for
less confusion, better defined 'gress path, provided a continuous TV video tape on proper donning a;.. removal of anti-Cs in the dressing area, increasing the number of radiation technicians and foremen present for instructing workers in the change areas, increased radiation protection management surveillance of activities in these areas, and incorporating stricter protective apparel for personnel removing used anti-Cs from the change area.
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In the longer term, the licensee is considering or is planning to provide additional training to maintenance and operations foremen on radiation protection, work with the Production Training Center (PTC) on the effectiveness of NGET training, provide a letter to the construction ~ crafts through Projects and Construction Services (PACS) department on contamination control, and evaluate Personnel Contamination Events (PCEs) and Radiation Occurrence Reports (RORs)
for possible procedure changes and tailgate training sessions.
This subject area will continue to be monitored closely by the resident inspectors as part of the routine inspection program.
Security
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The inspectors, by sampling, verified that persons in the protected area (PA) displayed proper badges and had escorts if required; vital areas were kept locked and alarmed, or guards posted if required;
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and personnel and packages entering the PA received proper search j
and/or monitoring.
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Housekeeping and Plant Cleanliness J
The inspectors monitored the sta'.us of housekeeping and plant cleanliness for fire protection, protection of safety-related
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equipment from intrusion of foreign matter and general protection.
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On one occasion, the inspector noted that the postings on one bulletin board, per 10 CFR '9, were deficient in that the NRC Form 3 was missing. A review with regulatory assurance personnel was conducted and no further deficiencies were found with other posting locations in the plant. The deficient bulletin board was promptly corrected. This 4 not considered # programmatic problem.
The inspectors also monitored various records, such as tagouts, jumpers, shiftly togs and surveillance, de'1y orders, maintenance items, various
chemistry and radiological sampling and analysis, third party review
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results, ovettinu reccrds, QA and/or QC audit results and postings i
required per 10 CFR 19.11.
During plant tours, the intpectors made note that control panels had an excessive accumulation of dust. This is of concern because dust can migrate into control switch electrical contacts and result in equipment failures. The licensee prcmptly had the panels cleaned and is establishing a long term plan to prevent rectrrence.
No violations or deviations were identified.
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Engineered St.fety Feature (ESF) Systems _(71710)
'j During the inspection, the inspectors selected accessible portions of several ESF systems to verify their status. Consideration was given
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to the plant mode, applicable Technical Specifications, Limiting j
Conditions for Operation Action Requirements (LC0ARs), end other l
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 ccmponent labeling, lubrication, cooling, etc.;
I interior conditions of electrical breakers and control panels; whether j
instrumentation was properly installed and functioning and significant
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I process parameter values were consistent with expected values; whether instrumentation was calibrated; whether necessary support systems were operational; and whether locally and remotely indicated breaker and
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valve positions agreed.
During the inspection, the following ESF components were walked down:
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Unit 1 I
l Diesel Generators 1A, 1B l
111, 112 Batteries Unit 2 Diesel Generators 2A, 2B
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211, 212 Batteries j
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No violations or deviations were identified.
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8.
' Monthly Maintenance / Modification Observation (62703)
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Station maintenance activities affecting the safety-related systems and compenents 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 itens 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 auf were inspected as applicable; functional testing and/or calib' rations were performed prior to returning components or systems to service; quality control records were maintained; activities were I
accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and fire prevention controls were implerrented. Work requests were reviewed to determine the status of outstanding jobs and to assure that priority is assigned to safety-related equipn.ent maintenance which may affect system j
performance.
The following traintenance activities were observed and reviewed:
Unit 1 1A Main feedwater Purrp oil leak.
Pzr F.anway Gasket Leak Repair.
Unit 2 213 Inverter troubleshoot and repair.
2A RHR Pump seal repair.
2A Diesel Generator 18-month inspection.
Boron Dilution Prevention system troubleshooting / repair.
Component Cooling Surge Tank auto fill system modification.
i Unit 1 Pressurizer Manway Lea,k Repair In the first week of the inspection period, the licensee completed a Unit 1 cutage for the identification and repair of a leak in the pressurizer manway. The leak was detected when a higher than normal tritium concentration was discovercd in the condensation frcm the reactor compartment fen cooler for the fan which takes suction on the air space near the pressurizer head. The leak resulted from a protruding l
scre.w.used to position the manway cover insert, which prevented complete l
compression of the flexitalic gasket and allowed steam to escape and to erode the manway surface. The affected area was ground down, eroded cover bolts were replaced, and the cover was reinstalled properly, with
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l care taken to insert the positionir.g screws to the proper dcpth. The
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licensee plans to revise its maintenance procedure for manway cover installation to include more emphasis on positioning screw depth.
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During the' inspection period, the licensee installed modifications in the following areas:
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Mod M20-2-88-062-01 Pzr PORV Relay'PY455X rewire to safety related power-supply.
Mod M20-2-88-123-01 28 Diesel Generator relay replacement per ECN.
37513.
The inspectors monitored the licensee's work in progress and verified that it was being performed in accordance with proper procedures and approved work packages, T. hat 10 CFR 50.59 and other applicable drawing updates were made and/or planned, and that operator training was.
conducted in a reasonable period of time.
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No violations or deviations were identified.
9.
Monthly Surveillance Observation (61726)
The' inspectors observed surveillance testing required by Technical Specifications during the inspection period and verified that 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 requirements and were reviewed by personnel other than.the individual directing the test, and that'any deficiencies identified
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during the testing were properly reviewed and resolved by apprc,priate management personnel.
The inspectors also witnessed portions of the'following test activities:
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Unit 1 1A Auxiliary Feedwater Pump monthly surveillance.
N41 Analog Channel operational test.
1A Diesel Generator operability monthly surveillance.
ICwIS 3.2.1-003 Rev. 1, " Analog Operational Test and Channel Verification / Calibration for Loops IF-0520, 1F-0522, and 1P-0524 Steam Generator 1B Steam Flow / Feed Flow Mismatch Channel I Cabinet I."
Unit 2 28 Auxiliary Feedwater Pump 18-month surveillance.
k 2A Diesel Generator 18-month surveillance.
2A Component Cooling ASME pump run, j
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2B Component Cooling ASME pump run.
212 Battery Bank Operability battery service test.
2Bw0S 3.1.1-20 Rev. 1, " Unit 2 Train A Solid State Protection System Bi-Monthly Surveillance."
No violations or deviations were identified.
10. Allegation Followup (99014)
l (Closed) RIII-87-A-0019: On February 27, 1987, a former employee of the L. K. ComstocK Company (LKC) telephoned NRC Region III and provided the following concerns:
a.
The alleger identified a problem with the pulling of Cable IVA-019.
The cable jacket was damaged during the cable pulling process when the sidewall pressure was exceeded.
The alleger stated that a Nonconformance Report (NCR) was written on the cable pull.
b.
The alleger stated that he did not believe an Area Manager for LKC was qualified for his position since the individual did not know the procedures to follow in doing his job. The alleger stated that the LKC procedures require the Area Manager and the Quality Control Manager to jointly add Inspection Correction Reports (ICRs) to Cable Raceway Release Forms (CRRs).
However, the Area Manager was unaware of the requirement and had a cable engineer add the ICRs to CRRs.
The alleger gave no more specific information. The alleger also
stated that for a two-week period, the Area Manager did not prepare
any documentation on the installation of fire stops and that it took I
a month to straighten the problem out.
c.
The alleger stated that he brought to the Area Manager's attention i
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his failure to attach the ICRs to the CRRs as required by the LKC procedure.
The alleger stated he and the Area Manager got into an argument. The alleger stated he was laid off the following day.
However, five new employees were immediately hired.
i d.
The alleger stated that he was not permitted to contact the Braidwood Quality First Team at the time of his termination, as he was given five minutes to leave. The alleger further stated that
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it was not until two weeks after his terminatioti that Quality First
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contacted him. He gave Quality First his concerns, but never got
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an answer.
e.
The alleger stated that information concerning employee rights (10 CFR 50.7) was not posted onsite.
The inspector reviewed Braidwood's Quality First investigation of the above concerns. The results of the Quality First investigation i
are as follows:
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a.
The Quality First investigation determined that LKC NCRs 5470 and 5548 and CECO NCR 874 were issued to resolve the alleger's concern with the pulling of Cable JVA-019. The alleger's concern pertaining to the pulling of Cable 1VA-019 was reviewed by an NRC Region III specialist; the results are documented in Inspection Reports No. 456/87019 and No. 457/87017.
No problems were identified with the cable, b.
In regard to the alleger's concern that the Area Manager was not qualified since the individual did not know the procedures to follow to do his job, the Quality First Team interviewed nine LKC individuals. These individuals were witnesses to the alleger's confrontation with the Area Manager concerning the failure to attach ICRs to CRRs. They were identified to Quality First by the alleger.
They did not corroborate the alleger's claim concerning confronting the Area Manager about a procedural violation.
Rather, they independently corroborated the Area Manager's version of the event.
The individuals stated that there was no mention by the alleger of procedural requirements related to proper documentation completion.
Instead, the alleger began the confrontation with "Let me give you some advice." The Area Manager, noting that the alleger at that instant was spending time with his girlfriend (a cable engineer),
suggested'strongly that the alleger return to his work area.
The alleger had previously been repeatedly warned regarding his spending excessive time with his girlfriend at work. This behavior prompted the Area Manager to transfer the alleger from the second shift to the first shift.
c.
The Quality First investigation determined that the alleger was transferred from the second shift to the first shift.
This transfer was a result of the alleger spending too much time with his girlfriend. The alleger, who was also a day student at a local college, requested, through his union, that he be laid off rather than shifted to the first shift.
d The alleger stated that he was unable to contact Quality First at the time of his termination and that his complaints filed later with Quality First were never answered.
Since the alleger worked on the second shift and Quality First has office hours on the first shift, the allegar was contacted via a letter soliciting any potential concerns. The alleger then provided his concerns to quality First.
On December 2,1986, the alleger was contacted by Quality First, and he agreed that the actions taken by Quality First were sufficient to address his concerns.
e.
Quality First determined that the information concerning employee rights (10 CFR 50.7) was posted and that the quality assurance (QA)
department had been performing quarterly surveillance in this area.
This was verified by the inspector's ceview of the QA surveillance.
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The Braidwood' Quality First Team's investigation of the alleger's
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. concerns'did not substantiate the concerns which he expressed to the NRC on February 27, 1987.
The Quality First Team did not investigate the concern pertaining to fire stops, since the alleger had not identified this concern to Quality First.
However, to' measure the effectiveness of the Quality First investigation, the inspector reviewed LKC's procedures, work instructions and associated documentation that pertained to cable installations and fire stop activities. The procedures and work instructions reviewed are:
LKC Procedure 4.3.8, " Cable Installation," Revision I, October 30, 1987.
LKC Work Instruction, WI-4.3.1.01, " Plant Barrier Impairments,"
Revisior, C, April 2,1987.
The cable installation procedure requires the System Department to list the ICRs on the CRR which is forwarded to LKC QC. The procedure does not require the Area Manager to attach the ICRs to the CRRs, and since cable engineers were assigned to LKC's System Department, the inspector did not consider the area manager's request for the cable engineer to attach ICRs to CRRs as unreasonable.
If new ICRs are discovered-while performing a pre pull walkdown, the procedure requires the CRR to be evaluated and revised by the Area Manager and then forwarded to the QC department.
This is the only responsibility of the Area Manager in LKC Procedure 4.3.8.
New ICRs were identified as necessary by craft personnel during their pre pull inspections. The LKC QA/QC program also requires that prior to any safety-related cable pull a " pre pull" and "in progress" inspection.
by LKC Quality Control be performed. These inspections were performed in accordance with LKC Procedure 4.8.8, " Cable Installation Inspection."
Based on.this information, the inspector found the Area Manager's actions to be in. compliance with LKC Procedure 4.3.8, " Cable Installation."
s In regard to fire stop documentation, the inspector determined that LKC was not responsible for the installation of any fire stop materials, which was performed by another site contractor.
LKC Work Instruction WI-4.3.1.01, " Plant Barrier Impairment," delineates the instructions for completing and tracking Plant Barrier Impairment (PBI)
forms utilized in controlling the penetration of installed air, water, security, and radiation barriers.
PBI forms are to be completed when
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reworking,-installing, or removing a cable that requires breaking a plant barrier or seal.
This work instruction does not identify any specific responsibilities for an Area Manager.
The inspector reviewed documentation pertaining to 26 safety-related cable pulls performed by craft personnel under the control of the Area Manager identified by the alleger and 12 other cable pulls which did not involve that Area Manager.
The selected documentation was for cable pulls performed during the months of October, November, and December 1986.
No anomalies were identified by the inspector.
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In summary, the inspector considers concerns a, b, d, and e identified u
by the alleger on February 27, 1987, to be closed based on the following:
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a.
The NRC~ regional specialist's review found no problems with.the pulling of Cable IVA-019.
b.
The LKC area manager was'following LKC Procedure 4.3.8, " Cable Installation," when he requested a cable engineer to attach ICRs to a CRR.
c.
LKC Work Instruction, WI-4.3.1-01, " Plant Barrier Impairment,"
identifies'no specific responsibilities for the Area Manager.
As stated by the alleger,~his concern with the Area Manager not preparing any documentation over'a two-week period was'" straightened.
out in a month." Therefore, the inspector has no technical concerns with fire stop documentation.
d.
The licensee's Quality First investigation did not substantiate any of the alleger's concerns.
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The ' review of 38 cable pull documentation packages identified no deficiencies.
f.
Since the Area Manager was a craft supervisor, there were no regulatory requirements pertaining to his qualifications.
g.
Quality assurance auditors determined that information regarding
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employee rights (10 CFP. 50.7) was posted at LKC.
-On November 16, 1987, the inspector contacted tha alleger by telephone about his concerns. During this conversation, the alleger identified other concerns of a technical nature. However, he could not provide any specifics. The alleger did state that he had no safety concerns-affecting public health and safety. These technical concerns pertained to PBI forms and ICRs.
In regard to the PBI forms, the alleger stated that these forms were not' initiated until after the work was started.
The inspector reviewed LKC Work Instruction WI'4.3.1-01 and found requirements for initiation of a PBI form prior to the initiation of work on a plant barrier and for review of the form by LKC QC after the work is completed.
Since the alleger could not furnish any specifics, it was not possible for the inspector to determine if PBI forms were in fact initiated after the start of work.
However, since the work instruction required LKC QC to sign the PBI form after completion of the work to indicate that the work was acceptable, the inspector does not consider the potential failure to initiate a PBI prwr to starting work to be safety significant issue.
The new technical concern involving ICRs pertained to these documents not being attached to CRR forms.
This new concern was similar to the original concern pertaining to the Area Manager requesting a cable engineer to attach an ICR to a CRR. The alleger had stated that the applicable procedure requires the Area Manager to perform this activity instead of a cable engineer. During the inspection of this original concern, the inspector had randomly selected 38 cable pull documentation packages and identified no anomalies.
Since the alleger could not furnish specifics
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for his new ICR concern and no anomalies were identified during the previous review, no further inspection was warranted.
The alleger confirmed the Quality First finding that he requested the layoff instead of transfer to first shift to support his attendance at school. The alleger also stated that he and a cable engineer were threatened with bodily harm and were o_ffered money to forget their concerns.
The alleger left the site in the Fall of 1986 and first came to the NRC in February 1987; the cable engineer left the site in May of 1987.
The Quality First investigation stated that L. K. Comstock and the alleger had attempted to negotiate a monetary settlement in December 1986, and Comstock had offered a $7082 settlement to avoid the expense of a lawsuit; however, this offer was rejected by the alleger, and no money was paid.
L. K. Comstock officials stated that this offer was not intended as an admission on the part of Comstock.
In response to NRC questions regarding potential employment discrimination the licensee provided the following responses:
"The former employee alleged that he was transferred from evening shift to day shift because he had raised safety concerns" The preponderance of evidence, most convincingly the eyewitness accounts of two individuals identified by the alleger himself, points to no identification of quality of safety issues by the alleger prior to hit transfer from the second shift.
Rather, it appears that the basis of this transfer was the alleger's failure to heed repeated warnings regarding the excessive amount of time the alleger spent with his girl-friend in her office instead of supervising his work crew, combined with the alleger's address of the Area Manager in a potentially insubordinate tone.
At worst, even if the allegations are taken as true, the alleged discussion with the Area Manager revolved around an ambiguity involving an administrative aspect of documentation.
The alleged question involved whether the cable Engineer who initiated the document, or the Area Manager, who as a matter of expediency was given permission to make changes to the form in the field, should make changes to a document to annotate a reference to another document. The alleger insisted that the Area Manager must make the change.
A reading of the procedure would allow either the Area Manager or the originator, the Cable Engineer, to make the change.
This latter position was supported by the LKC QC Manager at the time of the alleged disagreement.
The matter did not involve safety concerns.
1. A. Were the actions of the Area Manager appropriate?
Under the circumstances, the Area Manager's actions were not inappropriate.
He could have terminated the alleger for insubordination.
l (For example, the alleger had been terminated previously by LKC for
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He had been found playing cards during working hours, i
and had refused to leave the site when so ordered by his supervision. He
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regarding his girlfriend, immediate termination would have been an.
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appropriate action.
Instead, the Area Manager no longer wanted to have
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the alleger working in his crews, and transferred him to the day shift.
1.B. Were the actions taken in accordance with L.K. Comstock's established disciplinary code?
i Disciplinary action up to and including termination would have been L
warranted for the alleger's repeated failure to heed. directives from his l
superiors.
1.C. On what basis did the Area Manager conclude that the alleger was i
spending too much time with his girlfriend?
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The Area Manager and others in the craft line supervision above the alleger often noticed that the crew for which the alleger had supervisory responsibility was unsupervised. The alleger at these times was observed in the cable engineer's office. The alleger's-immediate supervisor.
described this. issue as long-standing and widely known.
Even the cable engineer, the alleger's girlfriend, indicated that the alleger spent a greater percentage of his time in her office than the other foremen with
.similar responsibilities
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As previously described, the alleger had been repeatedly warned by his immediate supervisor based on that supervisor's own observations and a, the behest of his upper level supervisors.
1.D. Did the Area Manager ever mention a possible re-assignment to the alleger?
The reassignment of the a11eger was never discussed directly between the Area Manager and the alleger.
Rather, the alleger indicated he was told by the Area General Foreman. The General Foreman indicated he.-
discussed it with the alleger following direction from the Area Manager.
The Area Manager indicated that he gave direction to the General Foreman.
1.E. Was the Area Manager's immediate supervisor aware of the current problem and its possible resolution?
The Area Manager's immediate supervisor, the LKC Project Manager, was aware of the transfer of the alleger to day shift. He was also aware of the alleger's daytime school enrollment. When he was requested by the union business agent to document the alleger's voluntary termination as a layoff he agreed.
1.F. What remedial actions were taken prior to terminating the alleger?
The a11eger was not terminated. The alleger did not raise any safety or quality concerns to his management, his union representatives, or Edison at the time of his termination. Only several days later was a quality concern raised.
Thus, no remedial actions were taken at that time, or prior to the time of his transfer to the day shift. At the
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' time, it appeared to all involved to be a matter of not performing his work.as ' expected or at worst, insubordination.
2.A. Was the Area Manager aware of the alleger's a_t_tendance at collece during the day _??
At this time, it is not possible to determine whether the Area Manager knew about the alleger's school atter. dance at the time he made his initial decision to transfer the alleger to day shift. He most likely knew about it by the next day, when he was approached by the union steward regarding a potential layoff in lieu of the alleger's transfer. The Area Manager retired in 1986. LKC is no longer employed at Braidwood.
2.8. If so, what other alternatives were available_and why weren't they utilized?
As discussed above, this was considered to be disciplinary matter involving failure to heed repeated warnings about spending time with his girlfriend at work as well as. insubordination. He could have bew terminated.
2.C. Wo_uld the actions taken against the_ alleger preclude ot_her wontractor employees from_ raising safety concerns?
t No. At the time of the event, safety concerns were not raised.
No one, with the possible exception of the alleger, was aware that safety ccncerns were involved. Those interviewed understood the' issue to be a-simple matter of insubordination.
None who knew the alleger thought the actions were unwarranted.
Also, independent of those actions, the existence of Quality First provided an alternative avenue by which to express concerns regarding safety or quality. None were presented.
Based cn this review by the licensee, the NRC has concluded that there is no basis for a finding of employment discrimination and no chilling effort related to the actions taken by the licensee's contractor. This resolves the allegation concern c identified February 27, 1987, there-fore, this allegation is closed.
11. Continued Security Guard Strike (92711)
On. February 2,1989, at 5:00 a.m., the security guards of Local 228 of United Plant Guard Workers of America (UPGWA) commenced a strike against
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Burns Security (Braiowood security contractor).
Reference Inspection Report 50-456/89002(DRP);50-457/89002(DRP).
Throughout this inspection period, the resident inspectors verified i
that station security duties were adequately manned by Burns Security
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management personnel, fire watches were properly manned when required, i
access to the site was unhampered, and operations shift manning met the requirements of Technical Specifications.
Subsequent to the report
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period the resident inspectors received word that on March 18,'1989, the bargaining unit and Burns Security had reached a tentative settlement.
Followup and restoration of normal activities will be monitored by the resident inspectors and reported in the subsequent report period.
No violations or deviations were identified.
12. Training Effectiveness (41400, 41701)
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 appeared to be knowledgeable of the tasks being performed, and nothing'
I was observed which indicated any ineffectiveness of training.
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No violations or deviations were identified.
13.
Report Review During the inspection period, the inspector reviewed the licensee's Monthly Performance Report for January and February 1989, and the Braidwood Station Radioactive Effluent Report for June through December 1988. The inspector confirmed that the information 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 February 1989, and the minutes of the Braidwood Corporate Overview meeting held on February 22, 1989.
No violations or deviations were identified.
14. Meetings and Other Activities (30702)
Site Visits by NRC Staff On March 17, 1989, Mr. J. M. Hinds, Jr., Chief, Division of Reactor Projects, Section 1A, was onsite for meetings with the resident inspectors. He also monitored the inspection activities that day, attended the resident inspectors exit meeting with the licensee, and met briefly with the Station Manager. On March 18, 1989, he arrived onsite at about 5:30 a.m. to monitor the control room shift turnover and plant activities.
Management / Plant Status Meeting A routine monthly management meeting was held onsite on February 24, 1989. The representatives for the NRC present were Messrs. W. D. Shafer, Acting Deputy Director, Division of Reactor Safety, Region III; J. M. Hinds, Jr., Chief, Division of Reactor Projects, Section IA, Region III; and the resident inspectors.
The licensee representatives
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were Messrs. T. Maiman, Vice President for PWR Operations; S. Hunsader,-
Nuclear Licensing Administrator; R. E. Querto, Station Managdr; station senior management; and other station staff members.
The licensee staff provided presentations on the plant status, events and personrel errors relative to their occurrences and recent stabilizing trends, the Unit I reactor trip on February 6,1989, the loss of Unit 2 residual heat removal (RHR) on February 22, 1989, the status of the Unit 2 surveillance outage, the guard strike status, and the reorganization of Commonwealth Edison.
Mr. Shafer presented discussion of personnel changes in Region III, problems encountered with the first Clinton refueling outage,'and plans for upcoming activities, such as maintenance team inspections.
No violations or deviations were' identified.
15.
Exit Intervirw (30703)
The inspectors met with the licensee representatives denoted in paragraph I during the inspection period and at the conclusion of the inspection on March 17, 1989. 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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