IR 05000456/1989028

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Insp Repts 50-456/89-28 & 50-457/89-27 on 891101-1216. Violations Noted.Major Areas Inspected:Ler Review,Regional Request,Evaluation of Licensee Implementation of QA Program, Operational Safety Verification,Esf Sys & NRC Inquiries
ML20011D972
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 12/22/1989
From: Beverly Clayton
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20011D970 List:
References
50-456-89-28, 50-457-89-27, IEIN-89-051, IEIN-89-51, NUDOCS 9001030309
Download: ML20011D972 (15)


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U.S. NUCLEAR RECULATORY COHNISSION

REGION III

Reports No. 50-456/89028(DRP);50-457/89027(DRP)-

Docket Nos. 50-456; 50-457 Licenses No. NPF-72; NPF-77 Licensee: Commonwealth Edison Ccepany

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Post Office Box 767 Chicago, IL 60690 Facility Name:

Braidwood Station, Units 1 and 2 Inspection At:

Braidwood Site, Braidwood, Illinois s

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Inspection Conducted: Novener 1 through December 16, 1989 I

. Inspectors:

T. M. Tongue T. E. Taylor D. R. Calhoun

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Approved By: Brent Clayton, Chief l

/2/2 A[//

Reactor Proiects Section 1A Date s

inspection Sununary Inspection from November 1 through_ December 16, 1989 (Report: No.

50-456/89028(DRP); 50-457/89027(DRP))

Areas Inspected: Routine, unannounced safety inspection by the resident inspectors of licensee action on previously identified items; licensee event report review; regional request; evaluation of licensee implementation of quality assurance programs; operetional safety verification; NRC inquiries-(blue sheets); engineered safety feature systems; inonthly maintenance observation; installation and testing of modifications; monthly surveillance observation; self-assessment; training effectiveness; report review; and meetings and other activities.

Results: Of the fourteen areas inspected, no violations were identified in t.hi rteen.

In the remaining area one violation was identified (Paragraph 9).

The violation resulted from a failure to conduct an appropriate 10 CFR 50.59 review to changes in a test. This single event had minimal safety impact on that test and plant operations.

However, omission of the-10 CFR 50.59 review should be acknowledged to prevent similar occurrences with more safety

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19001030309 89.1222

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.PDR-ADOCK 05000456 O

PDC

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DETAILS i

1.

Persons Contacted Commonwealth Edisor, Company (CECO)

T. J. M6tmen, Vice President, PWR Operations

  • R. E. Querio, Station Manager

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D. E. O'Brien, Technical Superintendent l

  • K. L. Kofron, Production Superintendent S. C. Hunsader, Nuclear Licensing Administrator

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  • G. R. Masters, Assistant Superintendent - Operations
  • G. E. Groth, Braidwood Project Manager, PWR Projects Department I
  • R. J. Legner, Services Director

"M. E. Lohman, Assistant Superintendent - Maintenance P. Smith, Operating Engineer - Unit 1

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  • R. Yungk, Operating Engineer - Unit 2

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B. McCue, Operating Engineer - linit 0

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  • R. D. Kyrouac, Quality Assurance Supervisor
  • D. E. Cooper, Regulatory Assurance Supervisor R. C. Lemke, Technical Staff Supervisor-A. D' Antonio, Quality Control Supervisor A. Checca, Security Administrator

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l R. L. Byers, Assistant Superintendent - Work Planning and Startup.

  • L. W. Raney, Nuclear Safety Supervisor

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W. McGee, Training Supervisor l

D. Pierce, Assistant Technical Staff Supervisor

  • E. W. Carroll, Regulatory Assurance
  • P. G. Holland, Regulatory Assurance

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J. Smith, Master, Electrical Maintenance l

  • D. Miller, Regulatory Assurance Supervisor l
  • M. Takaki, Regulatory Assurance Supervisor

'J. Kuchenbecker, Assistant Supervisor - Technical Staff

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  • A. R. Haeger, Operations Staff
  • S. T. Shields, Quality Assurance l

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Illinois Department of Nuclear Safety (IDNS)

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D. R.. Benz, Nuclear Safety Engineer

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t M. Klebe, Assistant Chief, Division of Inspections and Operations-V. Muzzalupo, Nuclear Satety Inspector

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R. Hand, Nuclear Safety Inspector The resident inspectors also met with several other members of the IDNS staff.

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  • Denotes those attending the exit interview conducted on December 14 L

1989, and at other times throughout the inspection period.

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

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2.

Licensee Action on Previously Identified Items (9270k92702)

a.

10 CFR Part 21 Report (Closed) General Electric 1AV Relays:

The NRC received a 10 CFR 11 report f rom General Electric stating that 1AV electrical relays may not meet seismic qualifications. This was provided to the licensee and a survey was conducted to identify the IAV relays in safety-related applications. After an extensive search through computer records, surveillance date, etc., no General Electric 1AV relays were found to be used in sefety-related_ applications at

Braidwood.

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b.

(Closed)TI 2500/17(DRP):

Inspection Guidance for Heat Shrinkable Tubing (H5T). A followup inspection ~of Raychem Splices was i

performed to essess the licensee's compliance to the TI and the EQ-program. During the inspection, the inspector verified that the surface of the HST was smooth, there was good conformance to substrate, and that there was a visible flow of adhesive.

Observations were also made to determine if overheating or-

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underheating conditions had occurred. No deficiencies were toentified; therefore, this TI is considered closed.

No violations or deviations were identified.

3.

Licensee Event heport (LER) Review (92700)

Through direct observations, discussions with licensee personnel, and review of records, the.following event reports were reviewed to determine

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that reportability requirements were fulfilled, that'immediate corrective

action was accomplished, and that corrective action to prevent recurrence-L had been or would be accomplished in accordance with Technical Specifications (TS).

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a.

(Closed) 456/89007-LL: Dual Train Inoperability of Auxiliary.

Feedwater (AFW)_ System for Six Minutes Due to Procedural Deficiency.

-On November 10, 1989, while recalibrating instrument loops

2PSL-AF051 for the 2A AFW, and 2PSL-AF055~for the 2A-and 2B AFW i

trains, an Instrument Mechanic Technician (INT) inadvertently -

rendered both trains of Unit 2 AFW system incapable of. responding to an automatic initiation signal for approximately six minutes.

The cause of the event was a personnel error by the IMT. At 7:27-p.m., the IMT completed the 2A AFW pump instrument calibration and the pump was restored to an operable condition. At 8:49 p.m., the

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2B pump controller was placed in the " pull-to-lock" position in.

preparation for the 2PSL-AF055 instrument calibration. This step is

per the calibration procedure to prevent auto-starting of the pump during testing activities. The IMT should have started calibratica activities on the 2B pump, but crroneously started performing the instrument calibration in the cabinet for the 2A pump. At 9:37 p.m., the IMT placed the 2A AFW pump instrument loop in test, l

thus rendering the 2A pump incapable of operation in response to an auto-start signal. The unit Nuclear Station Operator (NS0) was

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alerted to the condition by control room instrumentation associated

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with the 2A pump. The NSO then questioned the INT to determine if he was en the correct loop.

The IMT recognized the error and

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informed the NSO that he was returning the 2A AFW instrument loop to normal.

At 9:43 p.m., the 2PSL-AF051 loop was returned to normal.

At 8:54 a.m., on November 11, 1989, the recalibration activity for

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the 2A and 2B pumps was completed.

The dual unavailability for auto-initiation, with the 2A pump--in test and the IB pump in

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pull-to-lock, lasted about six-minutes.

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Also, at 3:35 p.m., on November 11,1989,: during a review of the

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documentation for the recalibration activity, a shift foreman

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discovered that the Setpoint/ Scaling Change Requests (SSCR) and the

nuclear work request for 2FSL-AF055 (for the 2A AFW pump) did not have,all-the control room final sign off signatures for completion

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as required by their respective administrative procedures. At 4:47 p.m., the reviews and final sign offs were completed and the 2A AFW pump was declared. operable.

Corrective actions for this event were:

color coding of keys and.

work packages, procedure revisions to ensure IMTs initiate work in the correct instrument cabinets, and training tailgate sessions-will be conducted for appropriate operating department personnel detailing the administrative requirements of the SSCR program.

A review of the Technical Specification (TS) for the AFW system identified that the TS addresses dual inoperability. The licensee did not violate the 15 Limiting condition for Operation Rcquirement,

.a The resident inspectors have no further concerns. This LER is considered closed.

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b.

(Closed) 456/89010-LL: Reverse Operation of Hydrogen Analyzer containment Isolation Yalve Due to a Preservice Wire Labeling Error.

At 4:00 a.m. on September 15, 1989, the leakage rate surveillance i

Local Leak Rate Testing (LLRT) for IPS229B, OB hydrogen. analyzer

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containment isolation valve, was initiated. The measured leakrate l

was largest with the valve indicating closed.

Identification of the correct. valve stem travel could not be made by direct observation because the valve and coil assembly are encapsulated. 'Several additional LLRTs were performed on the valve, end each time the results indicated reverse operation, but were. inconclusive. The initial wiring check found the valve wiring to be correct. The valve was removed and bench tested. The leads from the encapsulated coil were subsequently found to be improperly labeled, which caused

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the coil to be-incorrectly wired.

The valve also drifted to mid-position when the closing coil was deenergized. The licensee's investigation identified one work activity which involved replacement of the valve terminal-block. The coil leads were determinated and re-landed for this activity. The; work package did not document any relabeling of the coil leads. The labels on the leads were compared to a new coil assembly and were determined to be

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similar, but had a plastic coating which IPS229B did not have. The failure of the valve to remain in the closed positien when the closing coil was deenergized made detection of the error virtually

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impossible during normal operation. The initial LLRT (October 1906)

for the valve was reviewed. The review show?d that IPS229B tested satisfactorily and was operating norn, ally at that time. Valve 1PS229B is being replaced with a different model valve which will be tested in accordance with the station LLRT and modification program.

This LER is considered closed.

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-(Closed)456/89013-LL:

Inadequate Incorporation of Isolation Requirements for the Steam Generator Blowdown System Due to a Preservice Design Deficiency.. On October 5,1989, a discrepancy with the design of the steam aenerator blowdown (SD) system was

identified.

The Updated Final Safety Analysis Report (UFSAR)

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specifies SD isolation on the initiation of the auxiliary feedwater

. ( AF). system. The currently. installed equipment design does not provide for automatic isolation on all AF initiations. The SD

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system was isolated and changes were made to the emergency procedures requiring SD isolation on all AF auto-initiations. After these changes SD operation was returned to normal.

The engineering department evaluated the affects on the Accident Analysis of~the

=UFSAR. TheimpactedscenarioswereLossofNormalFeedwater(LONF),

Loss of-Non-emergency AC Power (LOAC), and Feedwater System Pipe Break (FSPB). - Calculations were performed using actual plant data, and by taking credit for menual SD isolation within ten minutes for LONF and LOAC events or for credit for reaching a Phase "A" initiating setpoint within six minutes for FSPB events.

It was-determined that the UFSAR acceptance criteria was met. The affected i

BwEPs have been revised and the permanent hardware modifications are

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scheduled for Unit 2 during it's February rcrueling outage and the

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next Unit I refueling outage. The cause was a preservice design deficiency for unknown reasons. The UFSAR will be revised to reflect the changes.

This LER is considered closed, i

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In addition to the foregoing, the inspector reviewed the licensee's i

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

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for proper initiation and disposition-as required by the applicable procedures and the QA manual.

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a No violations or deviations were identified.

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Headquarters / Regional Request (92701)

j On November 8, 1989, the resident inspectors were requested to review the

licensee's response to Information Notice (IN) 69-51, " Potential Loss of i

Required Shutdown Margin During Refueling Operations." There was an j

urgency placed on the review in that Braidwood Unit 1.was in the process

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of being refueled at the time, and some recent insight provided to the NRC through a letter addressed to Chairman Carr. Specific-questions were I

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raised and all were answered through the licensee's administrative

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controls, plant or core design.

The following is a listing of the questions and their answers:

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Determine whether this plant uses intermediate refueling configurations before achieving the final core configuration or whether fuel is loaded only in its final core location, j

Braidwood uses some intermediate refueling configurations before.

achieving the final core configuration, which involve placement of fuel assemblies with sources to assure source range indication and

" boxing" for placing a bcwed assembly, j

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Determine whether or not sufficient telysis exists to support core loading procedures, j

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Based on this review and previous inspections, it appears that

l Braidwood has sufficient analysis to support their core loading

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procedures. This includes the in-house responses to IN 89-51 and the licensee's in-house memo of " Shutdown Margin Boron Concentration for the BRIC2 Reload Core," Braidwood linit 1 Core 2.

Each of these documents shows sufficient consideration for SDM during the'

refucling activities, c.

Determine who does the analysis of the' refueling configurations (fuelvendor, utility).

The utility (CECO) corporate Nuclear Fuel Services performed the

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analysis of the current refueling configuration. This was further reviewed by the onsite qualified nuclear engineering (QNE) staff.

d.

Determine whether or not adequate procedures-exist for refueling the Cure.

It appears that adequate procedures exist for refueling the core.-

These include, but may not be limited to:

(1) BwAP 370-3, " Administrative Controls During Refueling".

(2) DwAP 2000, series of procedures frcm Corporate Nuclear Procedures in station format..

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(3) BwVP 500-7,1/M plot procedure (used with each assembly. move).

(4) BwFP, series procedures used by fuel handlers.

Determine whether or not the licensee is aware of the potential e.

y concern in IN 89-51.

The station and utility are aware of the potential concern in IN 89-51. Their in-house response was reviewed.

It was also noted that some of the concerns in the-letter to Chairman'

Carr do not necessarily apply to Braidwood as it is a Westinghouse design. Examples are:

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The control rods are maintained in their respective fuel assemblies

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in the core during refueling, i.e. one control rod assembly is

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limited to one fuel assembly.

  • The licensee maintains a boron concentration in excess of 2000 ppm during refuel; however, their analysis was conducted for 1418 ppm.

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The foregoing, the licensee's response to IN 89-51 and a copy of the

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licensee's in-house memo, " Shutdown Margin Boron Concentration for the

BRIC2 Reload Core," were submitted to Region III on November 10, 1989.

l There have been no additional questions and the inquiry had no affect on the core reload schedule.

l No violations or deviations were identified.

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Evaluation of Licensee Implementation of Quality Assurance (QA) Programs

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(35502)

The purpose of this inspection was to evaluate the effectiveness of the

licensee's implementation of it's QA program. The inspection consisted-of a review of Systematic Appraisal of Licensee Performance -(SALP)

reports-for 1988 and 1989, inspection reports-for 1989, licensee corrective actions for NRC inspection findings, and 1989 Licensee Event Reports (LERs) for both units.

The objective of the review was to identify any negative trends in licensee performance that would indicate problems with implementation of the QA program. The inspectors review identified that in the past twelve months several Notices of Violations (NOVs) and LERs have been issued. The number of NOVs and LERs have reduced considerably compared-to those issued during the prior twelve months.

The licensee's corrective actions for the NOVs and LERs have been reviewed by the resident inspectors and the Region 711 staff and found to be adequate in most cases. The only issues of a recurring nature identified in this review were the secondar to make emergency notification system (ENS)y plant steam' leaks, failure notifications within, required time limits, and mispositioned safety-related valves. The most common cause of the mispositioned valves was related to implementatien of the equipment out-of-service (00S) program. The cause of the late ENS

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notifications appeared to be a licensee misinterpretation'of ENS ~

notification requirements.- Escalated enforcement action was pursued relative to the valve issue which resulted in one Severity Level IV violation. The 00S system should be evaluated during future maintenance inspections.

No violations or deviations were identified.

6.

Operational Safety Verification (71707)

l During the inspection period, the inspectors verified that the facility was being operated in conformance with the licenses and regulatory requirements and that the licensee's management control system was effectively carrying out its responsibilities for safe operation. This

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was done on a sampling basis through routine direct observation of I

I activities and equipment, tours of the facility, interviews and

discussions with licensee personnel, independent verification of safety l

system status and limiting conditions for operation action requirements l

(LC0ARs), corrective action, and review of facility records.-

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l On a sampling basis the inspectors daily verified proper control rcom

l staffing and access, operator behavior, and cooraination of plant

i activities with ongoing control room operations; verified operator adherence with the latest revisions of procedures for ongoing activities; i

- 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;

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monitored instrumentation recorder traces and duplicate channels for.

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abnormalities; verified status of < various' lit annunciators for operator

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examined nuc ear instrumentation (NI) arid corrective actions being taken; understandin, off-normal condition and other protection channels for

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proper operability; reviewed radiation monitors and stack monitors for-

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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,-

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'(SPDS) for operability.

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During tours of accessible areas of the plant, the inspectors made note

L ofgeneralp(lant/equipmentconditions},includingcontrolofactivities in progress maintenance / surveillance observation of shift turnovers, j

general safety items, etc. The specific areas observed were:

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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

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required by TS or FSAR; and.the operability of support systems essential to system actuation or performance through observation of

instrumentation and/or proper valve alignment. The inspectors also visually inspected components for leakage, proper lubrication, cooling water supply, etc.

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l Radiation Protection Controls

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l The inspectors verified that workers were following health physics j

procedures for dosimetry, protective clothing, frisking,' posting, l

l etc.,- and randomly' examined radiation protection instrumentation for use, operability, and calibration.

  • Security i

The-inspectors, by sampling, verified that persons in the protected l_

-area (PA) displayed proper badges and had escorts if required; vital l.

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 and/or monitoring.

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Housekeeping and Plant Cleanliness The inspectors monitored the status of housekeeping and plant l

cleanliness for fire protection, protection of safety-related equipment from intrusion of foreign matter and general protection.

The inspectors also monitored various records, such as tagouts, jumpers, shiftly logs and surveillances, daily orders, maintenance items, various

chemistry and radiological sampling and analysis, third party review

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results, overtime records, QA and/or QC audit results and postings

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required per 10 CFR 19.11.

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Unit 1 Refueling Outage During the inspection period, Unit I was-in its first refueling outage, which was effectively completed on December 15, 1989, at 7:10 p.m.,

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when the main generator was synchronized to-the grid. Throughout the

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inspection period, the inspectors monitored the activities through direct observation, attending _ planning meetings, and plant tours. During tours of the containment, turbine building and auxiliary building, the inspectors noted that cleanliness was above average.for the state of the-plant. Activities appeared well planned and coordinated.

It was-noted that there was several days delay in. returning to operation; however, activities were cautious and deliberate with safety in mind.

7.

NRCInquiries(BlueSheets)(71707)

During the inspection period, the inspectors raised a number of issues for response by the licensee. The following is a sunnary and the

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q evaluation of the licensee's responses

During NRC Operator and Senior Operator Licensing exams,-several L

issues were raised that would be followed by the resident l

inspectors. These were:

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Abnormal Operating procedure Bw0A ENV-5, did not adequately

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address abnormal low level in the Kankakee River (normal makeup for the Braidwood cooling lake). This issue has been assigned a tracking number of AIR 456-225-89-05300-for a procedure revision. This is expected to be in place by tne-second quarter of 1990.

During the use of BwAP 340-1, it was noted that the Equipment

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Status Display (ESD) was not being used. The licensee is developing a plan with Byron for use of the ESD.

It was noted that abnormal procedure Bw0A INST-2 does not

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address returning'the pressurizer power operated relief valve to automatic after finding an acceptable pressure channel. A procedure revision is being developed under AIR

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456-225-89-05200, In the interim, the licensee will put a-

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temporary procedure change in place by the second quarter of 1990.

In addition, it was noted that Technical Specification allows' manual or automatic operation and that the associated block valves can be shut for leakage control.

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During the use of abnormal procedure Bw0A 0.0, it was_noted

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that the auxiliary feedwater pump would not start automatically

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if the control switch is in the "after trip" position.

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The licensee is developing a procedure revision under AIR 456/123-89-00200 and has placed a caution card on the control

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switch as an interim measure on both units.

Several observations related to radiation protection were observed:.

Personnel in the containment were noted removing their Anti-C hoods

with their respiratory protection masks prior to exiting _ the containment..This was found to be an acceptable practice for personnel exiting the reactor cavity, provided it is done on the upper level and under the guidance ofla radiation protection technician.

  • Dosimeter chargers were found to be simultaneously unusable at the auxiliary building entrances on the 401' and 426' elevations.

This was reviewed by licensee health physics (HP) personnel and the

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chargers were found to be out-of-service:from normal use. There

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p was no apparent' tampering and the chargers were replaced.

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Concern was raised about the spread of contamination or creating airborne contamination =in the containment while starting reactor containmentfancoolers-(RCFC). The licensee has'several precautionary measures in. place; i.e. operations would notify HP prior to fan starts, HP technicians on the 377' elevation in

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containment were notified, air sample monitors were trended, separate air sam)1es were taken for each fan start, and personnel-working inside t1e missile barrier were either removed from the area or using respiratory protection for each fan start until air activity was trended.

In addition, the licensee had an extensive cleaning program inside the containment during this period.

l The inspector also raised a number of questions with regard to security

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processes, surveillance. sampling, and 10 CFR~21 issues. -All were of lesser importance or were addressed-elsewhere in;this report.

No violations or deviations were identified.

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Engineered Safety Feature (ESF) Systems (71710)

During the inspection, the inspectors selected accessible portions of:

several ESF systems to verify their status. Consideration was given-to the plant mode, applicable Technical Specifications, Limiting Conditions for Operation Action Requirements (LC0ARs), and other applicable requirements.

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Various observations, where applicable, were made of hangers and j

supports; housekeeping; whether freeze protection, if required, was installed and operational; valve positions-anc conditions; potential ignition sources; major component labeling, ILbrication, cooling, etc.;

interior conditions of electrical breakers and control panels; whether instrumentation was properly installed and functioning and significant 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 valve positions agreed.

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

Unit 1 1A, IB Residual Heat Removal System-IA Chargin0 System 1A, B, C, D Safety Injection Accumulators

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No violations or deviations were identified.

9.

Monthly Maintenance Observation (62703)

Station' maintenance activities affecting the safety-related systems and components listed below were observed / reviewed to ascertain that they were conducted in accordance with~ approved procedures, regulatory guides and industry codes or standards, and in conformance with Technical i

Specifications.

The following items were considered during.this review:

the limiting.

conditions for operation were met while components or systems were

removed frohr and restored to service; approvals were obtained prior to

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initiating the work; activities'were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibrations were performed prior to returning components or systems to service; quality codrol records were maintained; activities were

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accomplished by qualified personnel; parts and materials used were l

l properly certified; radiological controls were implemented; and fire prevention controls were implemented. Work requests were reviewed to determine the status of outstanding jobs and to assure that priority

.I is assigned to safety-related equipment maintenance which may affect system performance, j

The following maintenance activities were observed and reviewed:

Unit 0 NWR A 33105, Repack Hydrogen-Recombiner "B" Suction Isolation Valve 00G065.

NWR A 33106, Repack Hydrogen Recombiner "B" Discharge Isolation Vahe 00G066.

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Unit 1 Reactor cavity skimmer filter changeout.

l 1A065 Instrument air containment isolation valve repair, i

IB Residual heat removal pump: suction relief valve replacement.

L Residual heat removal suction relief valve No. 51 pressure test.

Unit 2 Repair / troubleshoot master pressurizer level controller.

I 2A AFW pump suction pressure switch setpoint change.

28 AFW pump suction pressure switch'setpoint change.

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l The inspectors monitored the licensee's work in progress and verified

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that it was being performed in accordance with proper procedures, and-approved work packages, that 10 CFR 50.59, with one exception, and other

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applicable ' drawing updates were made and/or planned, and that operator training was conducted in a reasonable period of time.

,P_ressurizer Safety Valve Testing During a meeting.with regulatory assurance.and technical. staff personnel on October 20,1989, concerning pressurizer.(PZR) safety valve testing, the resident inspector requested a copy of the 10 CFR 50 59. review for l

the PZR safety valve test performed on September 2,1989. The resident inspector and licensee personnel reviewed the safety valve test packages.

The test package review identified that'the safety evaluation per-l l

10 CFR 50,59 was not performed.

10 CFR 50.59 requires that test records must includo a written safety evaluation'which provides the basis for the determination that the change, test, or experiment does.not involve an unreviewed safety question. This failure to perform a proper safety.

evaluationisconsideredaviolationof10CFR.50.59L(No.

50-456/89028-01(DRP)).

FWO79 Feedwater Check Valve Problems During the Unit I refueling outage in late October'1989, licensee staff

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informed the resident inspectors of-a problem where the piston damper on L

the FWO79 check valves was apparently binding, causing the valves to hang open. Unsure of the purpose of these valves, the licensee committed to e

l provide that information to the resident inspectors (RIs) as well as an L

analysis of the binding problem. At the November 20, 1989 meeting, l.

licensee personnel provided information to the residents.that the valves

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provided protection against a-feed line break and that new shaft bushings were being manufactured. fhe cause 'of the' failure was apparently due to feedwater at less than 300 F, which usually occurs at less than 20% power -

for short periods. The colder feedwater causes the bushfng to contract--

and to bind on the shaft, whereas water greater than 300, expansion of

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the bronze bushing gives sufficient shaft clearance. - The licensee-provided information that there are only'16 Borg Warner valves like these and they are installed at Braidwood and Byron. Byron was informed of

' this problem by licensee personnel at Braidwood. The licensee conducted

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an onsite review and investigation, which was reviewed by the inspectors and found to be acceptable.

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One violation'was identified.

10.

Installation and Testing of Modifications (37828)

The purpose of this inspection was to complete the inspection for modifications in progress.

In a previous inspection (456/89019(DRP);

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457/89019(DRP)) completed modifications were inspected to evaluate compliance with the requirements of the Technical Specification, 10 CFR 50.59; and 10 CFR Part-50, Appendix B, Criterion III, Design Control.- This part of the inspection focused on modifications in-

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progress. -Modifications M-201-88-003, " Addition of Interposing Relay,"

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and 7-20-2-87-82, " Addition of Auto-Makeup System for Component Cooling

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Surge Tank," were reviewed. The modifications were reviewed to ensure

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. work was being performed by qualified workers and in accordance with approved instructions, procedures and drawings. The inspectors verified that modification walkdowns were performed to verify that the installation conformed to the es-built drawings. Also modification packages were reviewed as the modifications were being-installed to verify compliance with modification program requirements. During this inspection and the previous inspection period noted above, modification packages were reviewed to ensure pro)er and adequate documentation

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existed for initiation of required c1anges to. effected procedures and drawings.

l One area of concern identified was that some of the drawings used for walkdowns were very cluttered and marked up. Although this concern was-considered a weak area in the program, it did not appear to cause any problems associated with installation discrepancies or confusion for

engineers performing the modification walkdowns.

For the modifications

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l reviewed the licensee's program appears to be handled in a professional-

manner.

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No violations or deviations weriidentified.

11. Monthly Surveillance Observat4n (61726)

The inspectors observed surve111ance 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 liniting conditions for operation were net, 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 tL individual directing the test, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personnel.

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The inspectors also witnessed portions of the following test activities:

Unit 1 Bw!S 9.2.C-200, Mode 6, Analog Channel Operational Test of Nuclear Instrumentation System Source Range N31 and N32, Audio Count Rate N34 and Scaler-Timer N34A.

IB Auxiliary Feed Pump Battery Capacity Test.

I BwlS 3.1.1-233, Modes 1 thru 6. Analog Channel Operational Test of Nuclear ' Instrumentation System, Power Range N43.

Unit 2 BwlS 3.1-013, Analog Operational Test and channel Verification / Calibration for Loop 2F-0416 Reactor Coolant Flow Loop 2A Protection Channel III, Cabinet-3 (2PA03J).

BwVS 3.1.1-5, Incore-Excore Axial' Flux Quarterly Calibration.

No violations or deviations were identified..

12. Self-Assessment (40500)

Nuclear Safety Offsite Review On November 27, 1989, the resident inspectors attended the licensee Nuclear b "" Offsite Review quarterly meeting. The-subject matter of 10 CFR SC.

reviews, trending and reporting, personnel errors, and generating ueviation reports. These were appropriate topics'and generated lively discussions. Attendees were-of appropriate credentials from corporate ar.d station staffs.

No violations or deviations were identified.

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13. 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 was observed which indicated any ineffectiveness of training. During the inspection period, the inspector attended;a Technical Specification

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computer, matrix training session.

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No violations or deviations were identified.

14. Report Review During the inspection period, the inspector reviewed the licensee's Monthly Performance Report for September and October 1989. The inspector

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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 Plent Status Report'

for October 1989 and the Regulatory Assurance Department Trend / Concern Report, dated November 17, 1989.

No violations or deviations were identified.

15. MeetingsandOtherActivities(30703)

.1 Illinois Department of Nuclear Safety (IDNS) Activities The resident inspectors met with IDNS personnel on two occasions during

the report period.

i On November 8, 1989, the IDNS personnel provided a description, tour, and demonstration for the licensee and the resident inspectors of the gas effluent monitoring system (GEMS) installed at Braidwood.

On November 29, 1989,- a team of inspectors were onsite from IDNS to-monitor a shipment of radwaste under a memorandum of agreement with the NRC. This was the first inspection of that type and IDNS personnel-expected to perform similar inspections at other stations in the near

future.

J Zion Station Inspection During the period of November 14 through 17, 1989, the' senior resident inspector-conducted inspections at the Zion Station as part of the site-resident staff. The observations.and findings were submitted'to Region III via memorandum dated November 28, 1989. The inspection activities-

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will be documented in the routine resident inspectors report,

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50-295/89034(DRP);50-304/89029(DRP).

No violations or deviations were identified.

16.

ExitInterview(30703)

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The inspectors met with the licensee representatives' denoted in Paragraph I during the' inspection period and at the conclusion of the-inspection on December 14, 1989. The inspectors summarized.the'sco)e and results of the inspection and discussed the likely content of t11s

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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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