IR 05000456/1990014

Insp Repts 50-456/90-14 & 50-457/90-17 on 900618-22.No Violations or Deviations Noted.Major Areas Inspected: Implementation of 10CFR50.62 & ATWS Rule

ML20055D136
Person / Time
Site:	Braidwood
Issue date:	06/28/1990
From:	Gardner R, Westberg R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20055D135	List: IR 05000456/1990014 ML20055D134
References
50-456-90-14, 50-457-90-17, GL-85-06, GL-85-6, NUDOCS 9007030243
Download: ML20055D136 (8)

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U.S. NUCLEAR REGULATORY COMMISSION J

REGION Ill

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Report Number 50-456/90014; 50-457/90017 License No. NPF-72 ar.d NPF 77 Licensee: Commonwealth Edison Company 4 Post Office Box 767 ,

Chicago, Il 60690 1 l

Facility Name: Braidwood Nuclear Power Plant, Units 1 and 2, l Inspection Conducted: June 18 through 22, 199 l Inspector: % b* W ( 6 8 0 Ro Q A. Westberg M Date: q Approved by:

&% W Ronald N. Gardner (af*L. V Date:

Inspection Summary:

-Inspection on June 18 throuah 22. 1990. (Report No. 456/90014: 457/90017(DRS))

Areas Insoected: Special announced inspection of implementation of ,

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10 CFR 50.62, the ATWS Rule, per temporary inspection instruction (TI) 2500/20 (25020), (SIMS Number MPA-A-20).

Results: No Violations or deviations were identified. Temporary Instruction f

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(TI) 2500/20 and Generic Letter 85-06 were closed. One unresolved item was-identified relative to the acceptability of the licensee using the NRR SER as the safety review required by'10 CFR 50.59 (Paragraph 3.b (1)). Based on the inspection, the inspector reached the following conclusion:

o The quality assurance applied to the AMSAC installation generally exceeded the quidance given in Generic letter 85-06.

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l 9007030243 900628 PDR ADOCK 05000456

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DETAILS l Personnel Contacted ]

l Commonwealth Edison Comoany (CECO) j

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• R. E. Querio, Station Manager

• D. E. O'Brien, Technical Superintendent i

• M. J. Andrews, Operations Staff 1

• K. L. Kofron, Production Superintendent 1 D. E. Cooper, Technical Staff Supervisor

• E. W. Carroll, Regulatory Assurance W. B. McCue, Operating Engineer - Unit 0

• D. J. Skoza, Engineering Supervisor  ;

• A. M. Stogsdill, Technical -Staff

• S. D. Eich, Technical Staff

• T. W. Simpkin, Regulatory Assurance  !

• S. D. Notter, Quality Programs

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• D M. Kapinus, Technical Staff

U. S. Nuclear Reoulatory Commission (USNRC)

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• J. A. Hopkins, Acting Resident Inspector

• B. L. Jorgensen, Senior Resident Inspector

• Indicates those attending the exit meeting on June 22, 1990. Other ;

personnel were contacted during the inspectio ' (Closed) Generic Letter 85-06t Quality Assurance Guidance For ATWS Equipment That is Not Safety-Relate .

The inspector verified that the licensee generally met or exceeded the !

supplemental QA controls guidance given in GL 85-06 (See section 3 of !

this report.) GL 85-06 is considered close . (Closed) Temocrary Instruction (TI 2500/20) (SIMS Number MPA-A-20)

10 CFR 50.62, "The ATWS Rule", requires that each pressurized water reactor have equipment from sensor output to finai actuation device, that is diverse from the reactor trip system (RPS), to automatically initiate the auxiliary (or emergency) feedwater system and initiate a ';

turbine trip under conditions indicative of an ATWS. This equipment i must be designed to perform its function in a reliable manner and be independent (from sensor output to the final actuation device) from the existing reactor trip system.

l The Westinghouse Owner's Group (WOG) submitted a generic design for ATWS mitigation system actuation circuitry (AMSAC) in response to 10 CFR ll 50.62. This design, Topical WCAP-10858, "AMSAC Generic Design Package, "

l_ was approved by the NRC in a safety evaluation report (SER) dated September,1986. However, this SER required further approval of many

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plant specific detail .

The Braidwood Station plant specific design was approved by the NRC in ,

an SER dated July 18, 1989. This approval was conditional based on the successful completion of a human factors review relative to AMSAC indication in the control room. The completed human factors review ;

resulted in four revisions to the AMSAC design. These revisions were submitted to the NRC and were subsequently approved by letter dated September 12, 198 The Braidwood design which implemented the Logic 1 option from WCAP-10858-P-A, Revision 1 (AMSAC actuation based on monitoring the steam generator level and activating the AMSAC when the water level is below '

the low-low set point) was installed on Unit 2 and tested during the refueling outage completed May 28,1990. Installation of the Unit 1 AMSAC

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is currently scheduled for the Spring 1991 refueling outag The objective of this inspection was to determine whether ATWS !

mitigating systems comply with the 10 CFR 50.62 rule requirements and whether the effectiveness of the QA controls applied to the major activities (design, procurement, installation, and testing) complied with Generic Letter 85-06, "QA Guidance for ATWS Equipment That Is Not Safety-Related," or with 10 CFR 50, Appendix B. The inspection also assessed the operational adequacy and reliability of ATWS equipment, Documents Reviewed (1) letters ,

(a) P. C. LeBlond to NRC, "ATWS Protection -

10 CFR 50.62," March 8, 1988.

I- R. A. Chrzanowski to NRC, "ATWS Protection -

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10 CFR 50.62," July 6, 1988.

L (c) R. A. Chrzanowski to NRC, "ATWS Protection -

l 10 CFR 50.62," August 16, 198 (d) R. A. Chrzanowski to NRC, "ATWS Protection -

10 CFR 50.62," November 9, 198 (a) S. C. Hunsader to NRC, "ATWS Protection -

10 CFR 50.62," February 15, 198 (2) Safety Evaluation Reports (a) SER of Topical Report No. WCAP-10858-P-A, "AMSAC Generic Design Package."

(b) SER of site specific AMSAC Design including Revision 1 to WCAP-10858-P- p

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NRC letter approving the human factor modifications to

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the AMSAC design dated September 12, 198 (3)- Modification Package No. 2-88-064 (4) Procedures (a) No. 2BwGP 100-3, " Power Ascension 5% to 100%,"

Revision (b) No. 2BwGP 100-4, " Power Descension," Revision (c) No. 2Bw0S ATWS-sal, " Unit Two ATWS Mitigation System Semiannual Surveillance," Revision - Temp Procedure TPP No. 544 (d)- No. BwAR 2-18-Ell, Alarm No. 2-18-D3, (e) No. BwAR 2-18-D3, Alarm No. 2-18-03, Revision (f) No. BwAP 1400-9T1, " Turbine Impulse Chamber Pressure I 18 Month Channel Verification / Calibration Loop 2P-0505," Revision (g) No. Bwls 3.1.1-321, " Steam Generator 2A Narrow Range-Level Protection 18 Month Verification / Calibration loop 2L-0556," Revision (5) Drawinas (a) No. 20E-2-4030FW65, "ATWS Hitigation System Schemati Diagram," Revision A (b) No. E-14827N, Sheet 3, " Elevation Details For ATWS Panel 2PA54J," Revision (c) No. 20E-2-4008BS, "480v Aux. Building MCC 234X5 (2APA47E)," Revision N (d) No. 20E-2-4611Q, " Internal / External Wiring Diagram -

4160V ESF SWGR Bus 241 Cub. 15," Revision P (e) No. 20E-2-4030TG04, " Turbine Generator Trip Part 2, "

Revision M (f) No. 20E-2-4030AFDl, " Auxiliary Feedwater Pump 2A,"

Revision T (g) No. 20E-2-4030AN003, " Annunciator Window Engraving 2VL-AN025 at 2PM02J," Revision K i

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w (h) No. 20E-2-4030AN053, " Window Engraving Trip Status Lights and Bypass - Permissive Lights," Revision G ,

(i) No. 20E-2-4045M, " Main Control Board Turbine 2PM02J, PT.2 Demarcation & Guard Rail," Revision D (j) No. 875-L-001, Sheets 1 -5, "AMS System Logic."

Revision (k) No. 20E-2-4001A, " Station One Line Diagram,"

Revision (6) Post Modification Test for Modification No. M20-2-88-064 ,

(7) Receiot Insoection Packaaes (a) Material and Equipment Receiving Report (MR() N , "ATWS Mitigation System Cabinet IPA 5tJ."

l (b) MRR No. 24230, "ATWS Mitigation System Cabinet 2PA54J."

(8)- Training Lesson _ Plan No. P1-SP-XL-41, " Modification No. M20-l 2-88-064."

l (9) Training Records - Various, b. Inspection Results The inspector verified the following aspects of the Braidwood AMSAC installation.

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! (1) Desian Enaineerina l

l The inspector's review of the AMSAC wiring and schematic

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diagrams, the site specific design submittals, and selected l RPS wiring diagrams confirmed that the AMSAC did not I compromise the safety features of the existing safety L related RPS. Walkdown of selected portions of the Unit 2

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AMSAC installation also supported this conclusio Review of the AMSAC modification package indicated that the design endorsed by the NRR SER was properly implemented. The inspector had one concern relative to the modification documentation; the " Modification Approval Letter" from Engineering stated that no 50.59 ~ safety evaluation was performed since the modification was pre-approved by the SER. Discussions were held between the inspector and personnel from Engineering and Licensing as to the accept-tability of using the NRC's SER as the safety review required by 10 CFR 50.59. These discussions ended with both sides having different opinions. The inspector agreed to

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pursue this item with Headquarters. Pending review of this'

concern by NRR and their subsequent decision as to the acceptability of this practice, this item is considered e unresolved (456/90014-01(DRS); 457/90017-Ol(DRS)).-

(2) Procurement and Installation of the ATWS Mitiaatina Eautoment The inspector reviewed the AMSAC procurement packages and ,

verified that the technical requirements of the Braidwood site specific design were in compliance with the SER and the i ATWS rul Through review of the procurement package for the Unit .1 AMSAC equipment and inspection of the equipment in the warehouse, the inspector determined that the proper receipt inspection, identification, and storage controls were being employe During a walk-down of the AMSAC installation the inspector observed the following:

(a) The AMSAC equipment met the configuration specifie (b) The AMSAC cabinets were installed in the proper location and were oriented and supported as specified in the design package and the seismic qualificatio The internal components in the cabinets were also mounted in the configuration analyzed in the seismic analysi (c) The AMSAC installation met the plant physical i separation criteria for electrical independence between safety-related and nonsafety-related circuits and redundant channel (d) Review of the AMSAC installation work request packages indicated that the installers used the proper tools, that radiological and fire protection controls were' .

observed, and that QC performed inspections for such !

items as welding and termination (3) Confirmation of Completed Work l

l (a) The inspector verified that the AMSAC performed as I specified in the Braidwood site specific design .]

through a review of the modification package and the l functional tes (b) The inspector reviewed the AMSAC annunciator procedures and the AMSAC training lesson plan with acceptable result AMSAC training for all on-shift

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personnel was verified as having been performe (c) Braidwood has committed to a complete end to-end test i of the AMSAC during each refuling outage and periodic 1 testing of those portions of the AMSAC that can be tested at power. The inspector reviewed the surveillance procedures with acceptable result (e) The inspector verified the existence of.the permanently installed master bypass switch in the l

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AMSAC control panel and the related annunciator (AMS Trouble) in the control roo (f) The inspector verified through review of the AMSAC logic diagrams that once the mitigative action is >

initiated, the action is sealed in and subsequent '

return to normal operations can be accomplished by the operator by deliberate actions after the sytem times ou (g) The Braidwood AMSAC design does not include a manual initiation switch; however, the inspector verified that it was not required during a tour of the control room. During this tour and during discussions with a Nuclear Station Operator (NS0) on shift, the inspector verified that the operators can manually trip the turbine and start the AFW pumps by using their respective manual switches in a time span shorter than the time delays built-in to the automatic AMSAC initiatio (4) Quality Assurance and Oualifications The inspector verified that portions of the major activities such as design control, procurement, installation, and testing were accomplished as QA scope in accordance with the plant's established procedures. In addition, QC performed documented inspections of the AMSAC receipt and installatio During this inspection, the inspector observed that the licensee generally exceeded the supplemental QA controls quidance given by Generic Letter 85-0 Personnel contacted during the inspection such as the technical staff engineer, the nuclear station operator and the shift control room engineer were well trained and knowledgeable in the ATWS system $

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3. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. An unresolved item disclosed during this inspection is included in Paragraph 3.b.(1) of this repor !

4. Exit Interview (

The inspector met with licensee representatives denoted in Paragraph I during and at the conclusion of the inspection on June 22, 1990. The inspector summarized the scope and results of the inspection and discussed the likely content of the inspection report. The licensee i acknowledges the information and did not indicate that any of the !

information disclosed during the inspection could be considered i proprietary in natur ,

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