IR 05000456/1989018

Safety Team Insp Rept 50-456/89-18 on 890612-0706.No Violations or Deviations Noted.Major Areas Inspected: Instrumentation Sys for Assessing Plant Conditions During & Following Accidents as Specified in Reg Guide 1.97,Rev 3

ML20247J250
Person / Time
Site:	Braidwood
Issue date:	07/24/1989
From:	Kopp M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20247J216	List: IR 05000456/1989018 ML20247J212
References
RTR-REGGD-01.097, RTR-REGGD-1.097 50-456-89-18, 50-457-89-18, GL-82-33, NUDOCS 8907310274
Download: ML20247J250 (12)

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'U.S.. NUCLEAR REGULATORY COMMISSION REGION.III j Reports No. 50-456/89018(DRS); 50-457/89018(DRS)

Docket Nos. 50-456; 50-457 Licenses No. NPF-72; NPF-77 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Nuclear Power Station, Units 1 and 2 Inspection At: Braidwood Site, Braceville, Illinois Inspection Conducted: June 12 through July 6, 1989 Inspectors: . J. Lopp & '1l81!($]

Date Also participating in the inspection and contributing to the report were:

B. Marcus, NRR M. Yost, EG&G R. Vanderbeek, EG&G A. Udy, EG&G

'O 7 , gb Approved By: Rona N. Gardner, Chief Plant Systems Section Date Inspection Summary Inspection on June 12 through eiuly 6, 1989 (Reports No. 50-456/09018(DRS); :

No. 50-457/89018(DR5))  ?

Areas Inspected: Special announced safety team inspection of the l instrumentation system for assessing plant conditions during and following an accident as specified in Regulatory Guide 1.97, Revision 3, licensee action on previously identified 10 CFR 50.49 related findings, and a Part 21 concerning melamine torque switches in Limitorque valve actuators (Modales 30703, 2515/087, and'62705); SIMS No. 67.3.3 (0 pen).

Results: Of the three areas inspected, no violations or deviations were identified. Two unresolved items were identified. The first unresolved item pertains to the use of terminal blocks located in junction boxes which are used in control circuit applications (Paragraph 5). The second unresolved item pertains to cables and splices located in pull boxes which are subject to being submerged (Paragraph 5). In addition, two open items were identified.

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The first open item' pertains to the license's need to submit a deviation.to !

Regulatory Guide 1.97 (RG 1.97) regarding the. lack of a recording device for .(

the spray additive tank level (Paragraph 3). Tt.a second open item pertains ;

.to additional reviews required by the licensee to ensure that all suspect melamine torque switches in Limitorque valve actuators have been replaced ;

(Paragraph 4). The inspection revealed that the licensee has implemented i a program to meet the requirements of RG 1.97 and has taken corrective action I

~to resolve previously identified 10 CFR 50.49 finding j i

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i DETAILS Persons Contacted Commonwealth Edison Company (CECc)

R. Querio, Station Manager

+ Groth, Project Manager

+K. Kofron, Production Superintendent

• +M. Lohmann, Assistant Superintendent, Maintenance

+R. Byers, Assistant Superintendent, Work Planning

+R. Lemke, Technical Staff Supervisor

• D. Cooper, Regulatory Assurance Supervisor W. McGee, Training Supervisor

• +C. Moerke, PWR Systems Design Supervisor '

+ Hedden, Maintenance Staff Supervisor

+ Smith, Master Electrician, Mainter snce

+ Woldridge, Technical Staff Group o.eader

• + Hunsader, Licensing Administrator

+ Kruger, EQ Coordinator

• + Roth, EQ Coordinator

• + Carroll, Regulatory Assurance

+ Lau, Regulatory Assurance

• +E. Adams, Engineer  !

+ Holland, Regulatory Assurance

+ Barnes, Nuclear Engineer

+ Naylor, Nuclear Engineer W. McCue, Operating engineer

• T. Bandura, Quality Assurance G. DeYoung, Nuclear Licensing

+ Phillips, Work Analyst

+ Eckert, Work Planning

+ Shields, Quality Assurance

+ Hillison, Quality Control

+ Raney, Nuclear Safety S. Eich, Electrical Technical Staff C. Bedford, Regulatory Assurance T. Kennedy, Instrument Maintenance T. Eubank, Instrument Maintenance T. Baltes, Electrical Maintenance Sargent and Lundy Engineers (S&L)

^+J. Meister, Project Manager

• Galanis, Senior Electrical Project Engineer

+ Kokesit, Senior Project Engineer

+ Hartel, Mechanical Engineer

+ Crumpacker, Control and Instrumentation Engineer

• Murskyj, Electrical Engineer

• +A. Behera, Consultant

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• 4 U. S. Nuclear Regulatory Commission (USNRC)

• T. Tcngue, Senior Resident Inspector, Braidwood

• +T. Taylor, Resident Inspector, Braidwood

• A. Gautam, Project Engineer, NRR

+ Gardner, Chief, Plant. Systems, Region III

+ Denotes those participating in interim site exit on June 16, 198 * Denotes those participating in final exit on July 6, 198 . Licensee's Actions Regarding Previously Identified NRC Findings A February 1988 NRC EQ inspection identified six Potentially Enforceable /

Unresolved Items (50-456/88005-01, 02, 04, 09,10,11(DRS);

50-457/88006-01,02,04,09,10,11(DRS)). Subsequent to the NRC findings, an Enforcement Conference was held with the licensee. The NRC determined that these items represented a Severity Level III violation (50-456/89018-05(DRS); 50-457/89018-05(DRS)). The Severity Level III violation with a $75,000.00 civil penalty was issued to the licensee in November 198 The six unresolved items noted above were characterized as examples of violations of NRC requirements in the Notice of Violation letter set to the licensee on November 23, 1988. The closure of the above six unresolved items in this report represents closure of the corresponding examples of violation, (Closed) Unresolved Item (456/87045-03(DRS); 457/87046-03(DRS)):

This item concerned the lack of scheduled environmental qualification (EQ) maintenance and surveillance requirements for Units 1 and The licensee informed the inspector that radiation and high temperatures were not present until the reactor was critical; therefore, EQ maintenance and surveillance requirements were not required to be started until initial criticalit In response to NRC concerns, the licensee performed an Onsite L Review (OSR) to determine if EQ equioment had been properly maintained. The licensee took corrective action and repaired or replaced EQ equipment found to be defective due to the lack of maintenance and surveillanc No further NRC concerns were identified and this item is close (Closed) Unresolved Item (456/88005-01(DRS); 457/88006-01(DRS)):

The licensee's EQ files did not demonstrate that certain Westinghouse components installed by Johnson Controls, Inc. (JCI) were similar or identical to the couponents tested by JCI. The licensee presented an engineering analysis to evaluate the Westinghouse OT-2 switches, EZC lights and AR relays used in various HVAC panels at Braidwood Station. This analysis concluded that (1) the subject components were installed in a relatively mild environment - radiation harsh only; (2) the only failure mode of concern was loss of dielectric strength of the insulating parts and the loss of mechanical properties of the moving parts and; (3) there was a 400% margin in the design electrical stress for these component {

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DuHng this: current' EQ follorJp inspection, the inspector reviewe '

the EQ binders to conf' 1 that the. components installed were similar or identical to!the et lents. tested. The-inspectors. reviewed the <

.' material analysis, Wesm aghouse calculation CCE-88-184, and found it u , to be acceptabl O L a i

No further NRC concerns were identified and this item is close l Q>

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' (Closed)IUnresolved Item (456/88005-02(DRS);.457/88006-02(DRS)):

This item addressed the licensee's failure to perform maintenance l

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on EQ solenoid valves, transmitters, motors, thermocouple and limit  ;

. switches. -The inspectors noted that EQ seals'were not replaced per 1 the EQ binders, wrong lubricants were used on motors, and that j certain insp'ection frequencies were extended without adequate-  ;

justification. As a result of'the NRC concerns, the licensee i

' implemented an Onsite Review (OSR) to ensure that EQ maintenance

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y and. surveillance requirements were met. The licensee either 1 provided adequate' justification'n or performed maintenance / i surveillance on. equipment fond to be defectiv :

During this inspection, the inspectors reviewed the licensee's

. response to the NRC findings'and verified that EQ maintenance and d surveillance requirements were performed and were properly reflected .j

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in the EQ binder ;

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No further NRC concerns were identified and this item is close !

I (Closed)-Open Item (456/88005-03(DRS); 457/88006-03(DRS)): This item addressed a concern that the licensee's quality assurance ,

involvement with EQ activities may not be adequate, and that the j EQ training program did not provide appropriate training for the  !

management, operations, and maintenance staff j i

During this inspection, the inspector reviewed the Braidwood Operating Quality Assurance Hold Point and Work Reviewed Log for 1988, and Quality Assurance Surveillance Reports QAS 20-88-214,

. QAS-20-88-064, . QAS-'20-88-060, ' QAS-20- 88-055, and QAS-88-052 to determine quality assurance (QA) involvement in EQ activitie In addition, QA Audits QAA-20-89-17, QAA-20-88-17, QAA-20-89-42, j and QAA-20-88-37 were reviewed. The inspectors determined wat j QA involvement in EQ activities was adequate. The inspectors also  !

reviewed the licensee's EQ training program, and concluded that ,

appropriate personnel are adequately trained regarding EQ requirement j i

No further NRC conceras were identified and this item is close (Closed) Unresolved Item (456/8M05-04(DRS); 457/88006-04(DRS)):

This item addressed the installation of Bunker Ramo instrument penetrations. The penetrations were EQ tested utilizing terminal blocks for electrical connections. However, the penetrations were installed in the plant utilizing splice Consequently, the inspectors concluded that the penetrations were unqualified due

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s to the differences between the test conf.iguration and the installed configuration. Subsequent to the NRC finding, the licensee

^ performed an EQ test that reflected the plant installed configuration.

o The' test results-were reviewed by the NRC, as documented inla letter 4 dated March 15, 1989 from'NRR to.the licensee, and were found to b acceptabl No further NRC concerns were identified and this item is close .1 (Closed) Open Item (456/88005-05(DRS); 457/88006-05(DRS)): During the February 1988 EQ inspection, the Joy / Reliance.EQ file stated that the motor bearings'were qualified for 40 years. The Reliance ~-

Report, NVC-12,. dated October.30, 1978,- stated that according to the Antifriction Beering Manufacturers Association (AFBMA), . standard no. 9 bearings of motors cannot have a specific ~ qualified life. .In addition, Reliance Electric recommended that the bearings be treated {

[ 'as a replaceable element. The licensee was requested to provide documentation ~ to support their claim that the motor bearings were .

qualified for 40 years. The licensee provided Sargent and Lundy ,

calculation CQD-010212 supporting a motor bearing qualified life i of 40 year !

During this EQ followup inspection, the inspectors reviewed the

.EQ calculation and confirmed that the above concerns were adequately addressed and incorporated into the licensee's EQ file No further NRC~ concerns were identified and this item is close (Clor,ed) Open Item (456/88005-06(DRS); 457/88006-06(DRS)): This a

' item t.uncerned the qualified life calculations for the solenoid valves in EQ Binder BB-HE10A which were bued on a normal maximum temperature of 122 F. The valves, however, are located in an environmental zone where the maximum temperature is expected-to reach 130 During this EQ followup inspection, the inspectors reviewed EQ Binder.EQ-BB-HE10A. The updated EQ binder included qualified life calculations using a temperature of 130 F. The EQ binder is considered to be acceptabl No further NRC concerns were identified and this item is close (Closed) Open Item (456/88005-07(DRS); 457/88006-07(DRS)): This item noted that the "auditable link" document for the qualification of the Barton transmitters provided by Westinghouse was not included in the EQ file. The inspectors also noted that no thermal aging analysis or radiation analysis had been provided in the binde The licensee stated that the radiation analysis is provided in Westinghouse WCAP-8587 and that this document has been reviewed and accepted by the NRC. The licensee agreed to include the auditable link document and the aging analysis in the EQ binde I l

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During this inspection, the inspectors reviewed EQ Binder ESE-4A and confirmed that the above commitments had been me The file contained the auditable link documents for Braidwood Units 1 and 2, and the thermal and radiation analysis documented in Sargent and Lundy Calculation No. CQD-04383 No further NRC concerns were identified and this item is close (Closed) Open I hm (456/88005-08(DRS); 457/88006-08(DRS)): The February 1988 NriC EQ inspection identified that documentation had not been provided for the qualification of the Tefzel insulation used on General Atomic Radiation monitor The referenced reports were not in the binder. The inspector concluded that the similarity between the detectcr wiring and tested wiring had not been establishe The licensee stated that the referenced documents would be included in the next revision of the binder to establish sinolarit Sufficient interim information was provided by the licepree to mitigate any immediate safety concerns. The inspectors slso observed that qualification documentation had not been provided for the connector interface in that the connector was not properly identified ;

or analyzed. The licensee agreed to identify the connector in the EQ '

binder During this inspection, the inspectors reviewed the EQ binder and determined that the items were adequately addressed by the licensee in calculation No. CQD-014700, Revision 3, of EQ binder EQ-BB-06 No further NRC concerns were identified and this item is close (Closed) Unresolved Item (456/88005-09(DRS); 457/88006-09(DRS)):

This item addressed Marathon terminal blocks used in control circuits inside the containment. The EQ test conducted at Wyle identified that terminal blocks located directly beneath top entry conduits experienced higher leakage currents than blocks not located below top entry conduits. To address this deficiency the licensee had required drip shields and weep holes be installed in junction boxes for Marathon terminal blocks located directly below top entry conduits. As a result of the licensee's OSR of EQ equipment, (16)

weep holes and (8) drip shields were found missing. The licensee took corrective action and installed the weep holes and drip shields, and reported that no other junction boxes were affecte During this current inspection, the inspector identified junction boxes, located in HELB areas, that contained terminal blocks located directly below top entry conduits. It was noted that drip shields were not installed above the terminal blocks to prevent possible water spray onte the blocks from the top entry conduits. In addition, the inspectors reviewed Wyle Test Report 17657 and noted that the tested configuration did not represent the installed configuration in the plent. The licensee committed to performing an engineering analysis to determine which circuits are affected and their functio i

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This item is closed,-however Section 5 of.this report documents the-

& A NRC's_ concern regarding control: circuit terminal blocks in~HELB' area , , '(Closed) Unresolved Item (456/88005-10(DRS); '457/88006-10(DRS)): . 4 This item addressed the use of GECO pressure switches, Model J505, installed in several EQ valves in the. plant. ..The licensee reported that they did not have' sufficient data to qualify-g" -the J505 GEC0 switch for'its EQ application in the plant. The

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licensee identified the.use of these switches in feedwater isolation p i ,

valves, containment purge isolation valves, and steam generator l' power operated relief valves. The licensee' replaced the switches for the feedwater isolation valves, and submitted an adequate '

operability analysis for the switches associated with the containment purge and steam generator power operated valve i During this current EQ followup inspection, the inspectors i determined that the licensee had replaced the J505 pressure. switches in Unit 2 and'all but nine J505 series. pressure switches in Unit The inspectors reviewed Wyle Test Reports 2142, 2132, and 2186 and determined that the licensee has established qualification of the remaining pressure switches in the plan No further NRC concerns were identified and this item is close . (Closed) Unresolved Item (456/88005-11(DRS); 457/88006-11(DRS)):

This item concerneGhricants contained in EQ Limitorque operators,

. The licenree perforced an OSR to examine the installed lubricants to determine if any. degradation had occurred since they were last replaced. Based on this review, the licensee reported mixed proportions'of a calcium based and a lithium based lubricants in several EQ actuators. The mixed proportions were reported a to' range =from 2% lithium /98% calcium to 50% lithium /50% calciu The licensee, however, could not present adequate EQ test data or an analysis based on test data.to demonstrate that.the mixed greases were qualified for the postulated ambient plus accident environment Tce licensee's corrective action consisted of sampling the grease in the potentially affected 10 CFR 50.49 Limitorque actuators. The grease samples underwent visual inspections for quality, and a . )

chemical analysis to identify mixed greases. In addition, penetration tests were conducted to determine the percentage of mixed proportion l During this inspection, the inspectors determined that the licensee has replaced mixed greases in Unit 2 and has scheduled replacement .

of mixed greases in Unit 1 found i? be contaminated with 2% to 5% l mixed proportion No further NRC concerns were identified and this item is close i (Closed) Unresolved Item (456/88005-12(DRS 457/88006-12(DRS)):  !

Dur'ing the February 2,1988 HRC EQ inspect) ion of the General Atom radiation monitor assembly, a split (crack) was noted on one Raychem heat shrink tube insulating a coaxial connector. The licensee issued

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NWRs A20667 (1RE-AR020), A20666(1RE-AR021), and A20577 (2RE-AR021) on j March 8, 1988, to inspect the splice In addition, NWR's A20576 <

(2RE-AR020), and A20577 (2RE-AR021) were issued on March 17 and 18, 1988, to replace the damaged heat shrink tubing, j The inspectors reviewed the licensee's corrective action and found ')

it to be acceptabl l i

No further NRC concerns were identified and this item is close ! Program Compliance to RG 1.97 (TI 2515/87; SIMS No. 67.3.3)

The purpose of this inspection was to compare the installed plant RG 1.97 instrumentation with the commitments contained in _ correspondence related to post-accident instrumentation and as described in the Byron /Braidwood ;

RG 1.97 Safety Evaluation Report (SER). References used to assess the '

licensee conformance to Regulatory Guide 1.97 were:

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Regulatory Guide 1.97, Revision 3, " Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Project and Environs Conditions During and Following an Accident."

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Safety Evaluation Report, NRC (S. P. Sands) to Commonwealth Ed'50n (T. J. Kovach), May 19, 1989, with Technical Evaluation Repor?

prepared for the NRC by EG&G Idaho Inc., "Conformance to Regulatory Guide 1.97: Bryon 1/2 and Braidwood 1/2, March 1989, EGG-NTA-764 eneric Letter 82-33 issued Supplement 1 to NURGE-0737 and specified requirements regarding emergency response capability approved by the NR The supplement also discusses, in part, the application of Regulatory Guide (RG) 1.97 to the emergency response facilities, including the Control Room-(CR), Technical Support Center (TSC), and Emergency Operations Facility (EOF) at power plants. The licensee's response to RG 1.97 was provided in letters dated February 27, 1987; September 1, 1987; De~cember 28, 1987; and July 27, 198 Technical Evaluation of RG 1.97 Instrumentation The inspector reviewed redundancy, physical and electrical separation, power sources, and interfaces for selected RG 1.97 instrumentation. The Q-list identified that the instruments had been evaluated and tested to the appropriate environmental qualification (EQ), quality assurance (QA),

and seismic qualification requirements. The inspectors also interviewed plant personnel, examined drawings and documentation, and performed a physical walkdown of RG 1.97 instrumentation in Units 1 and 2 control rooms to assess the implementation of the requirements delineated in Regulatory Guide 1.97, Revision ';

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For the RG 1.97 instruments' selected, the inspectors reviewed the frequency of calibration, the date last calibrated, the next calibration due date, and the procedure used to calibrate the instrument The RG 1.97 instruments inspected were found to be in calibration within normal time limits of the specified time interva The RG 1.97 variables selected for review included:

• Neutron Flux, Category I, Type B

• RCS Pressure - Wide Range, Category I, Type A

• RCS Hot Leg Water Temperature, Category I, Type A

• Steam Generator Level - Wide Range, Category I, Type A

• Steam Generator Level - Narrow Range, Category I, Type A

• Pressurizer Level, Category I, Type A

• Containment Pressure - Narrow Range, Category I, Type A

• Containment Pressure - Wide Range, Category I, Type A

• Main Steam (Steam Generator) Pressure, Category I, Type A

• Refueling Water Storage Tank Level, Category I, Type A

• Containment Water Level - Wide Range, Category I, Type A

• Containment Area Radiation Level - High Range, Category I, Type A

• Main Steam'he Radiation Level, Category I, Type A

• Core Exit Temperature, Category I, Type A

• Spray Additive Tank Level, Category I, Type A

• Status of Standby Power, Category 2 The inspection determined that the licensee has implemr:nted a program to meet the requirements of RG 1.97, Revision 3. Exceptions are noted below:

Spray Additive Tank Level Category I requirements include recording of the instrument signal on at least one channel. The instrumentation provided consists of tank low level indicator lights, however no recording has been provide This finding was not previously identified as an exception to RG 1.9 The licensee has committed to document this deviation. Pending further action by the licensee, this is considered an Open Item (50-456/89018-01(DRS); 50-457/89018-01(DRS)). Limitorque Part 21 Regarding Melamine Torque Switches In response to the Limitorque 10 CFR Part 21 concerning failure of white melamine torque switches in SMB-00 and SMB-000 actuators the licensee initiated an OSR and developed Investigation Report 89-048. The licensee identified suspect actuators; developed a schedule for replacement, and prepared a Justification for Continued Operation (JCO). However, in addition to the SMB-00 and SMB-000 actuators the licensee identified Limitorque actuator types SB and SBD as valve actuators that could contained white metamine torque switches. The licensee has comitted t.o performing a review of the Limitorque actuators and to replace the

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white melamine torque switches. Pending further review by the licensee, this is considered an Open Item (50-456/89018-02(DRS); 50-457/89018-02(DRS)).

q Plant Physical Inspection The inspectors performed a walkdown of selected EQ component The components were inspected for location, orientation,, physical condition, and identificatio The equipment appeared acceptable except as noted below: { During a walkdown of selected EQ components, it was noted that .

terminal blocks were installed inside junction boxes 2JB683A, 25B686A, j and 1JB797A which are located in High Energy Line Break areas (HELB)

with conduits installed directly above the terminal blocks. The ]

i tarminal blocks are used in control circuit applications utilizing j 132 VAC and 135 VD The inspectors were concerned that moisf,ure ]

would collect in the top entry conduits and in the event of a HELB, j spray directly onto the terminal blocks creating leakage currents l higher than acceptable. In addition, the inspectors reviewed Wyle )

Test Report 17657. This report was pra ented by the licensee as I evidence of qualification of the terminal blocks. The inspectors noted that the tested configuration varied from the plant installed configuration in that the conduits in the test setup did not )

represent a vertical run of conduit directly into the top of the '

box. The licensee submitted a circuit analysis of the terminal blocks, in HELB areas, to determine operability, and the affect of leakage currents on the circuit Pending further review by the NRC licensee, this is considered an Unresolved Item (50-456/89018-03(DRS); j 50-457/80018-03(DRS)). It was also identified, during the walkdown, that weep holes are not installed in pull boxes located in harsh environments. The inspectors were concerned that the contents of the pull boxes would, in the event of an accident, become submerge )

The inspectors requested the licensee to provide EQ test data to i substantiate qualification for submergence conditions. The licensee {

informed the inspectors that high voltage withstand tests and water -

absorption tests were conducted on the cables and splices contained i in the boxes. Tnis data, according to the licensee, provides evidence j of qualification for submergence. Pending further Region III and j N G review of the EQ test data, this is considered an Unresolved Item 1 (50-456/89018-04(DRS); 50-457/89018-04(DRS)). Open Items Open items are matters which have been discussed with the licensee, which I will be reviewed further by the inspector, and which involve some action

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on the part of the NRC or licensee or both. Open items disclosed during this ir:spection are discussed in Paragraphs 3 and l

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" Unresolved Items

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An' unresolved item is a matter about which more information,is required j in order to ascertain whether it is an acceptable item, an open item, a deviation, or a violatio Unresolved Items are discussed in Paragraph . Exit Interview The Region III inspectors' met with the licensee's representatives (denoted in Paragraph 1) during an interim exit on June 16, 1989, and i discussed their findings at the conclusion of the inspection on July 6, 1989. The inspectors discussed the likely content of the inspection report with regard to documents or processes reviewed by the inspector The licensce did not identify any such documents or processes as proprietar i l

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