IR 05000456/1991013
| ML20024H103 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 05/09/1991 |
| From: | Farber M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20024H101 | List: |
| References | |
| 50-456-91-13, 50-457-91-11, NUDOCS 9105210389 | |
| Preceding documents: |
|
| Download: ML20024H103 (18) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION III
Reports No. 50-456/91013(DRP); 50-457/91011(DRP)
Docket Nos. 50-456; 50-457 Licenses No. NPF-72; NPF-77 Licensee: Commonwealth Edison Company Opus We n III 1400 Opus Place Downers Grove, IL 60515 Facility Name:
Braidwood Station, Units 1 and 2 Inspection At:
Braidwood Site, Braidwood, Illinois Inspection Conducted: March 10 through April 20, 1991 Inspectors:
S. G. DuPont R. A. Kopriva T. J. Kobetz D. R. Calhoun D. Shepard W. Kropp J. Monninger
- / A Approved By:
M. J7 Farber, Chief f f 9/
Reactor Projects Section 1A Dath
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Inspection Summary Inspection from March 10 through April 20, 1991 (Reports No. 50-456/91013(DRP);
No. 50-457/91011(DRP))
Areas Inspected:
Routine, unannounced safety inspection by the resident inspectors of licensee action on previously identified items; licensee event report review; spent fuel activities; preparation for refueling; refueling activities; license requalification program; operational safety verification; monthly maintenance observation; monthly surveillance observation; followup of regional requests; engineered safety feature system walkdown; safety assessment / quality verification; report review and meetings.
Results: One non-cited violation was identified in the area of License Requalification Program. One violation was identified in the area of operational safety verification.
A non-cited violation of 10 CFR 55.49 was identified for a possible compromise of the requalification examination.
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l 9105210389 910519
[DR ADOCK 05000456
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A violation occurred during this inspection period when an operator deviated from an approved procedure. Although the intentions of the deviation were based upon good operating practices, the operator actions did not satisfy administrative requirements by not obtaining a temporary change of the approved procedure. The inspector chose not to use the discretion of citing a violation allowed by 10 CFR 2, V.G.1, based upon previous problems related to following procedures and administrative systems (such as correcting procedures or using temporary changes) as
. noted in Inspection Report Nos. 50-456/90023 and 50-457/90012.
- Several events occurred during this inspection period due to inclement weather.
Inclement weather (icing conditions ana lightning strikes) on March 12 and 26, 1991, resulted in automatic shifting of control room ventilation from normal to emergency make up mode of operation.
Both of these were due to voltage spikes sensed by radiation monitors.
This is a recurring problem and the licensee is addressing the issue.
- During this inspection period, a large number of contaminated spills occurred. The licensee reviewed the events for root causes and to determine corrective actions. Although the licensee developed good corrective actions, these actions were not implemented in a timely fashion to have an effect on the current refueling outage. Additionally, the initial significance of these spills was not recognized by senior station management.
- The review of the Onsite Nuclear Safety Group (0NSG) and Nuclear Quality Programs (quality assurance) revealed that both groups continued to show improvements with an increased use of performance based audits.
- The review of licensee's self-assessment activities indicated that the
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self-assessment process was a good management tool; however, issues r
identified by audits and third party issues were not corrected in a timely manner.
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DETAILS 1.
Persons Contacted Commonwealth Edison Company (Ceco)
- K. L. Kofron, Station Manager G. E. Groth, Production Superintendent
- D. E. O'Brien, Technical Superintendent G. R. Masters, Assistant Superintendent, Operations R. J. Legner, Services Director
- A. D. Antonio, Nuclear Quality Program Superintendent
- D. E. Cooper, Technical Staff Supervisor S. Roth, Security Administrator K. G. Bartes, Nuclear Safety Supervisor
- C, Vanderheyden, Training Supervisor
- A. Haeger, Regulatory Assurance Supervisor
- P. Zolan, Regulatory Assurance Opex Administrator
- E. W. Carroll, Regulatory Assurance
- R. Yungk, Operating Engineer
- Denotes those attending the exit interview conducted on April 24, 1991, and at other times throughout the inspection period.
The inspectors also talked with and interviewed several other licensee employees.
2.
LicenseeActiononPreviouslyIdentifiedItems(92701)
(Closed)OpenItem 456/91004-01(DRP):
On February 28, 1991, the licensee found oil in the Unit 1 IC and IDllifety injection (SI) accumulators.
The details of this issue n re addressed in Inspection Report l
No. 50-456/91004, Paragr*
5.
The licensee's Justification for Continued Operations I was evaluated and found to be adequate by l
the NRC. The inspects so reviewed the occurrence for conformance to Technical Specificat,.as and regulatory requirements and found the-licensee's actions to be in compliance.
However, many of the licensee's i
l actions associated with the initial problem in December 1989 were found to be similar to the identified weaknesses associated with the October 4, 1990, loss of inventory event on Unit I documented in Inspection Report No. 50-456/90023.
The weaknesses included the lack of a questioning attitude by not inquiring where the displaced oil from the compressor had gone and the possible effect on any other components. This issue is considered closed since the corrective actions associated with the October 4,1990, event appear to be partially effective as demonstrated by corrective actions associated with conduct of operations by both the Technical Staff and Nuclear Quality Programs. Additionally, the system was determined to be operable by the NRC's evaluation of the JCO.
No violations or deviations were identified.
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3.
Licensee Event Report (LER) Review (92700)
Through review of records, the following LERs were reviewed to determine that reportability 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) 457/90002-L1 (Closed)- 456/90010-L1 (Closed) 456/91001-L1 (Closed) 457/91001-LL (Closed) 456/91002-LL (Closed) 456/91003-LL (Closed) 456/91004-LL No violations or deviations were identified.
4.
Operations (71707)
During the inspection period, the inspectors observed facility operation to determine 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 was done on a sampling basis through routine direct observation of activities and equipment, tours of the facility, interviews and discussions with licensee personnel, independent verification of safety system status and limiting conditions for operation action requirements (LC0ARs),
corrective action, and review of facility records.
On a sampling basis the inspectors routinely 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 iit 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:
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a.
Radiation Protection Controls The inspectors observed plant personnel to ensure that activities were accomplished according to health physics procedures and randomly examined radiation protection instrumentation for use, operability, and calibration.
During this' inspection period, eight contaminated spills occurred on Unit I during the refueling outage between February 19 and March 25, 1991.
The significance of the individual spills ranged from minor, resulting in a small area contaminated, to major, resulting in a large area with personnel contamination or ?otential for personnel contamination.
The significance of tiese spills also included an ALARA concern over personnel radiation exposure during the decontamination efforts.
Initially, the licensee's station management had failed to ascertain the significance of the spills until after the majority of the events had occurred.
The licensee formed an investigative team on March 26, 1991, to determine the root causes and corrective actions.
The licensee's initial investigative efforts were to review each event separate, then compare all events together for common root causes.
Based upon these results, a series of corrective actions were determined on April 10, 1991. These corrective actions were reviewed by the inspector and found to be adequate for the identified root causes. The inspector was in agreement, especially with the corrective actions associated with the licensee's Radiation Occurrence Reports (RORs).
To ensure that future s) ills receive appropriate investigation and corrective actions, t1e RORs will be tracked through the station administrative system,.similar to event /
deviation reports.
The inspector also reviewed the licensee's investigation efforts associated with these spills. Although the effort did result in aapropriate corrective actions, these actions were not timely in tlat station management failed to recognize initially that a problem existed until after eight spills.
Additionally, the licensee's plan to review each spill individually, then in aggregate, did not produce corrective actions in a timely manner.
The corrective actions associated with the RORs should provide a mechanism for management to recognize the existence of future problems associated with spills.
The NRC will enhance inspection efforts during the upcoming Unit 2 refueling outage to assess-the effectiveness of these corrective actions, b.
Security During the inspection period, the inspectors monitored the licensee's security program to ensure that observed actions were being implemented according to their approved security plan.
The inspector noted that persons within the protected area displayed
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proper photo-identification badges and those individuals requiring escorts were properly escorted.
The inspector also verified that checked vital areas were locked and alarmed. Additionally, the inspector also verified that observed personnel and packages entering the protected area were searched by appropriate equipment or by hand, c.
Housekeeping and_ Plant Cleanliness The inspectors monitored the status of housekeeping and plant cleanliness for fire protection, protection of safety-related equipment from intrusion of foreign matter and general protection.
The general plant cleanliness continued to be good.
The intpectors also monitored various records, such as tagouts, iumpers, shiftly logs and surveillances, daily orders, maintenance items, various chemistry and radiological sampling and analysis, third party review results, overtime records, QA and/or QC audit results and postings required per 10 CFR 19.11, d.
Events (1) On March 12, 1991, the control room received indication that switchyard line 0104 had tripped.
The cause of the line tripping was due t; inclement weather and icing conditions.
The loss of swit9 yard line 0104 resulted in the momentary spiking of the raciation monitors for the B train of the control room ventilation.
The spiking of the radiation monitors in turn caused the B train of the control room ventilation to automatically shift to the emergency makeup mode of operation.
The licensee made the proper NRC notification within the four hour time requirement, Once the cause of the spurious radiation monitor spiking was identified, the licensee returned the control room ventilation to its normal system lineup, (2) On March 13, 1991, the meteorological tower wind speed indicator failed to respond, The failure was due to a frozen wind speed indicator caused by inclement weather and icing conditions.
Due to.the loss of the normal and alternate means of offsite dose assessment capabilities, the licensee, per-their generating station emergency plan procedures declared an unusual event. The licensee made the required Emergency-Notification System (ENS) phone call and subsequently terminated the unusual event when the weather conditions had improved and the licensee was able to obtain wind speed measurements from one of their sources.
(3) On March 26, 1991, the licensee experienced a lightning strike on the electrical grid, This lightning strike caused tne control room radiation monitors to spike high momentarily.
The spiking of these radiation monitors caused the control room
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I ventilation to automatically shif t f rom normal to the emergency makeup rnode of operation. The licensee verified the cause of the control room ventilation transferring to the emergency make up mode and made the required notification.
The licensee subsequently restored the control room ventilation to its normal mode of operation.
(4) On April 17, 1991, a small radiological s>ill occurred in the auxiliary huilding due to a ruptured diapiragm in the 2A mixed-bed demineralizer (MB) inlet isolation valve. At the time of the spill, the Unit 2 Nuclear Station Operator (NS0)
was in the process of shifting the Unit 2 MB demineralizers.
This plant evolution required the use of operating procedure Bw0P CV-8, Revisioc 5, "CV System Mixed-Bed / Cation Demineralizer Operation." This tyoe of plant evolution was routine and had been successfully per'ormed in the past using Bw0P CV-8.
The diaphragm rupture occurred as a result of operator error while performing procedural step F.1.d which directed the NSO to open CV85220, the Letdown MB Demineralizer A Outlet valve.
The operator decided to deviate from the procedure and left the 2CV8522B in its closed position. The NSO's justification for this action was based upon suspected air entrainment in one of the demineralizers and the need to vent the demineralizer prior to placing it in service. Although the procedure did not contain any provisions for venting, the NSO reviewed the associated Piping and instrumentation Diagrams (P&ID) for the Chemical and Volume Control and Boron Thermal Regeneration system to determine if any adverse effects would occur as a result of maintaining 2CV8522B in a closed position. The NS0 concluded that the valve lineup was acceptable and proceeded through the procedure. The current plant configuration indicated that both demineralizers were bypassed with the inlet valves open and the outlet valves closed.
Several steps later, the NSO instructed the Equipment Operator (EO) to restore flow
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to the demineralizers. When this was performed, an increase in pressure of approximately 380 psi occurred, causing the normal letdown relief valve to lift and rupture the diaphragm.
The failed diaphragm caused borated water to spray through the valve stem and contaminate the E0. The licensee's corrective actions included initiating a deviation report and counseling the Unit 2 NSO and the Shift Engineer.
This is a violation in that the licensee did not correctly implement Procedure Bw0P CV-8, "CV System Mixed-Bed / Cation Demineralizer Operation,"
as required by Technical Specifications (No. 50-457/91011-01(DRP)).
One violation was identified.
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5.-
Monthly Maintenance Observation (62703)
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Station maintenance activities 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 items were considered during this review:
tne limiting conditions for operation were met while components or systems were removed from and restored to service; approvals were obtained prior
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to 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 control records were maintained; activities-were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and fire prevention controls were implemented.
The following maintenance activities were observed:
Unit 1 Reactor Coolant Pump seal replacement, Unit 2 Replacement of the 2A Essential Service Water pump check valve internals.
The inspector also reviewed the onsite
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review and investigation report which allowed the valve to be rotated 90 degrees when reinstalled.
No violations or deviations were identified, 6.
Monthly Surveillance Observation (61726}
The inspectors observed several of the surveillance tests 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 during'the testing were properly reviewed and resolved by appropriate management personnel, The following surveillance activities were observed anF reviewed:
Unit 1 Integrity tests of the hydrogen recombiner per BwVS 290-2 and l
SwVS-4,10-4,1, Unit 2 Reactor coolant pump bus undervoltage monthly surveillance per BwVS 3.1.1-7, No violations or deviations were identified,
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7, Follow Up - Regional Request (92701)
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During this inspection period, the res' dent inspectors reviewed the containment hydrogen recombiner and the eraergency diesel generator fuel oil systems per NRC regional requests.
In response to a memorandum from H. Miller, dated March 8, 1991, the inspector reviewed the containment hydrogen recombiner installation, openating procedures, and surveillance procedures.
The results of the inspection have been forwarded to the DRP technical support staff.
On_ April 18, 1991, the resident inspectors received a request from Region III Division of Reactor Projects pertaining to the seismic qualifications of the emergency diesel generator' fuel oil systems at Braidwood Station.
The following were the questions of concern:
Q1.
How many days of-fuel oil capacity are required by Technical Specifications (TS)?
A1 Seven days: TS 3.8.1.1.b requires 44,000 gallons per diesel, corresponding to consumption of 37,000 gallons per diesel in post loss of Coolant Accident (LOCA) condition (Updated Final Safety Analysis Review (UFSAR) 9.5.4.2).
92.
Does the licensee have a seismically qualified fuel oil supply tank?
If yes, how much is seismically qualified? (In days or gallons.)
A2.
Yes, 50,000 gallons per diesel (UFSAR 9.5.4).
93.
Is the fuel oil transfer system seismic? This includes the piping that ties the main storage tank (s) with the day tank.
If this system is non-seismic, where is the seismic to non-seismic transition point?
A3. Yes (UFSAR 9.5.4.1).
Nn violations or deviations were identified.
8.
Spent Fuel Pool Activities (86700)
The purpose o' this inspection was to ascertain that the licensee's spent fuel handling activities were in conformance with the requirements of the Technical spe;*fications (TS) and 16 CFR, The inspection evaluated'and determined the following:
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. Provisions for verifying that the spent fuel pit hoist and related spent fuel handling tools were checked for proper operation prior to and periodically during spent fuel handling.
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Proper limit switch actuation at the designated setpoints.
No mechanical interferences (i.e., air hoses, hydraulic lines, rope, ductwork, piping, pipe hangers, etc.) existed that could cause inadvertent interference with limit switch actuation.
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Proper mechanical adjustment of gripper elements of fuel handling
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tools, or proper source pressure for pneumatically or hydraulically operated handling tools.
- The spent fuel pool water level was higher than the minimum level
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established by. approved procedures, i
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The spent fuel pool vsntilation system maintained the building at the required negative pressure.
- Personnel handling fuel were properly qualified and supervised.
- Fuel handling activities received reviews required by approved procedures prior to authorization.
- An accurate record and map of fuel location changes was maintained.
During this inspection, the inspectors observed portions of the spent
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fuel handling operations.
The procedures were reviewed to verify that the corre:t revisions were being used. While observing the activities, discussions with the fuel handling personnel determined that satisfactory knowledge existed regarding operator actions for abnormal indications that may have been encountered while performing refueling activities.
No violations or deviations were identified.
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-Preparation for Refueling (60705)
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The purpose of this inspection was:
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To ascertain the adequacy of the licensee's procedures for the conduct of refueling operations, b.
To ascertain the adequacy of the licensee's administrative requireinents for control of refueling operations and plant conditions during refueling.
c.
To ascertain-the adequacy of the licensee's implementation of controls for items 1 and 2.
- To accomplish the objectives-of this inspection, the inspectors
' investigated and/or observed the following:
Fuel handling, transfer and core verification.
-Handling and. inspection of the core internals.
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Training and qualifications of key personnel.
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Communications.
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Observations of equipment checkout.
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Review of procedures.
- Surveillances required by Technical Specifications during the conduct of refueling activities.
Provisions for maintaining good housekeeping in the refueling and fuel storage areas and for control of loose parts.
The inspectors also observed portions of equipment checkouts and dry runs of:
Refueling machine.
- Upender/ trolley / fuel transfer tube,
Spent fuel bridge.
- Safety interlocks.
One of the concerns the inspectors encountered dealt with the control of tools / items in the fuel handling building, specifically while working over or around'the spent fuel pool, Observation of activities on the spent fuel bridge revealed the ft;;t that several small tools were not being controlled. These tools could have easily been dropped or kicked into the spent fuel pool.
This concern was discussed with the individuals on the spent fuel bridge and with the licensee's quality assurance (QA) department. The QA department indicated that they were already following this concern.
Based upon the responsiveness of the licensee's QA department, this concern is considered to be closed.
No violations or deviations were identified.
10.
Refueling Activities (60710)
The purpose of this inspection was to ascertain whether refueling activities are being controlled and conducted as required by Technical Specifications (TS) and approved procedures.
To accomplish the' inspection requirements,-th'e inspector observed and determined _the following:
Core monitoring during refueling operations was in accordance with TS.
Fuel accountability methods were in accordance with established procedures.
- Vessel and spent fuel storage pool water levels were at levels required by TS,
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The inspectors also witnessed fuel handling operations.
The inspectors
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verified that the correct revision of the applicable procedures were used and that personnel _ operating the manipulator crane, upender, and spent fuel bridge were qualified. Also, fuel movement activities were observed from the control room.
No violations or deviations were identified.
11.
License Requalification Examination A possible compromise of the requalification examination scheduled for the weeks of April 8 and 22, 1991 occurred on March 11, 1991.
Three instructors at Braidwood station inadvertently taught an operator who is scheduled to take the examination after they had obtained knowledge of the proposed examination. All three instructors'had signed a security agreement (Attachm:6i ES-601-1 of NUREG 1021) which stated in part, "I
[the instructor] am not to participate in any instruction involving those operators... scheduled to be administered the above requalification examination from this date [date of signing the agreement] until completion of examination administration."
The operator that attended the training was not scheduled to attend the classes.
The operator was a staff license involved in outage planning and attended the sessions with a crew other than his normal crew to meet the requirements of the requalification program.
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The instructors involved did not realize that the operator was scheduled to take the upcoming examination until after the training had occurred.
When the instructors realized that a possible compromise had occurred they informed their management and the NRC and caused an inspection of the proposed exam to see if any material covered was on the proposed examination. One JPM on temporary alterations was deleted and one question on logkeeping was deleted; however, one lesson taught was on Engineered Safety Features Actuation System (ESFAS), which is involved at least indirectly in several JPMs, simulator scenarios, and written questions.
An independent onsite_ review of the lesson plan used for the ESFAS session by an NRC examiner showed-that the lesson plan is for a general overview of'the ESFAS and that no JPM, scenarios, or questions are directly covered by the material in the lesson plan.
The facility's proposed corrective action to prevent recurrence of the event was that all instructors involved in the proposed examination were given a memo identifying the operators scheduled for the examination with instructions to walk out of the class prior to teaching those operators.
The NRC examiner verified that the instructors had been given the memo and the instructions.
The examiner verified that a memorandum was issued to Production Training Center instructors who will be teaching the requalification for the weeks prior to the examination stating the same.
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The above incident is considered a violation of 10 CFR 55.49, " Integrity
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of Examinations and Tests"; however, NRC review has determined that this is considered to be a non-cited violation (50-456/91013-01(DRP);
50-457/91011-02(DRP)) in accordance with 10 CFR 2, Appendix C, Part V.G.I., Rev. January 1,1990, and as such, a Notice of Violation will not be issued.
One Non-cited violation was identified.
12., Engineered Safety Feature System Walkdown (71710)
A detailed inspection was performed on a representative sample of the accessible portions of the Unit I component cooling (CC) system. A portion of the system lineup procedure was verified to match plant and instrument drawings and plant configuration.
Hangers and supports were inspected and found to be made up ard aligned properly.
A number of valves were inspected and were found to be installed correctly and did not exhibit gross packing leakage, bent stems, missing handwheels or improper labelling. They were found to be in the correct position per Bw0P CC-M1, A sample of the instrument calibration records were reviewed and found to be up to date. Major system components were properly labelled and showed no sign of leakage.
Housekeeping was adequate and appropriate levels of cleanliness were being maintained.
Valve ICC-9458
"CC pump 1A and IB crosstie" had a cocked stem limit switch.
This condition could cause an inaccurate indication during future valve operation. The inspector notified the licensee of the condition.
No violations or deviations were identified.
13.
Report Review Durin0 the inspection period, the inspector reviewed the licensee's Monthly Performance Report for February and March 1991.
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 March 1991.
No violations or deviations were identified.
14.
Safety Assessment / Quality Verification (40500)
The inspectors evaluated the ef fectiveness of the licensee's self-assessment programs, The inspectors focused on determining if the licensee's self assessment programs contributed to prevention of problems by assessing the licensee's audit program, Onsite Nuclear Safety Group, Corporato self-assessments, Regulatory Assurance Trends / Concerns Reports and the review of Byron LERs for possible impact on Braidwood.
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Audits.
- The inspectors reviewed several audits performed by the Onsite Nuclear Quality Program (ONQP) personnel and one audit oerformed by the licensee's corporate office.
The review evaluated the effectiveness of the audit program with particular attention to'the performance based aspects and the followup on audit findings. The inspectors reviewed the following audits:
Audit No.
Dates Subject 20-90-10 01/09/90 - 01/22/90
" Corrective Action #1" 20-90-11 07/07/90 - 07/12/90
" Corrective Action #2" 20-91-01 03/04/91 - 03/08/91
"On-Site Nuclear Safety (Off-site) Operations, Security, Emergency Preparedness Environ-mental Qualification" 20-91-03A 01/11/91 - 01/25/91
" Temporary Alterations and On-site Review" 20-91-10A 03/01/91 - 03/15/91
" Site Support" 20-90-18
.11/19/90 - 12/07/90
" Site Support" The inspectors noted continued improvement in the audit process, especially in the areas of trending of audit findings (corrective action reports) and the utilization of performance based audits.
Some of the strengths identified were:
The recently implemented Corrective Action Report (CAR) trending program that predicts trends-in performance. The licensee continues to fine tune the process.
- Progress towards assessing significant audit findings for root cause during the audit.
This practice assures timely identification and resolution of causal-factors that could cause problems in areas l
~other than the area audited. An example of an audit that accomplished this type of assessment was 20-91-03A, " Temporary
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Alterations and On-Site' Review", performed in. January, 1991.
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Daily meetings between all the licensee's NQP organizations at the nuclear stations' and the corporate NQP staf f via telephone. Each station's NQP personnel discusses any significant issues at the station with appropriate' input from the corporate NQP staff. The L
inspectors considered the daily phone calls as a useful tool in improving.the effectiveness of the NQP audit program as issues identified at other licensee facilities could be evaluated during
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audits.
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The inspectors did have observations that were not considered
weaknesses but were considered areas that needed further review by the licensee's management. The observations were:
TwoCARS(CAR 20-91-014 and 20-91-08) issued during audits identified
. conditions that were-contrary to - specific requirements.
However, the more significant issue was that the CARS identified issues which were not corrected in a timely manner. CAR 20-91-014 (January 1991)
identified that a continuous sampling connectior, was installed on the Units 1 and 2 Containment Air Sampling Monitors and not controlled as a Temporary Alteration.
The NQP auditor did require the station to address in the response to the CAR why the condition was not corrected in a timely manner.
Previous NQP surveillance, QAS-20-90-71, had identified the same issue in July 1990. _The other CAR, 20-91-08, identified an issue with high dissolved oxygen content in the Unit 1 main generator stator cooling water since unit startup.
High dissolved oxygen could cause the stator coil hollow copper strands to corrode through formation of copper oxides.
- The corporate audit of the 0NSG activities (20-91-01) assessed activities for compliance and was not performance based.
The licensee stated that other organizations assess ONSG activities;
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however, the licensee was not sure if those assessments were performance based.
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Review of the trend codes for CARS 20-91-08 and 20-91-14 did not identify the functional area of Safety Assessment / Quality Verification (SA/QV). The program for trending CARS identified SA/QV as the functional area for capturing untimely corrective actions.
- NQP audits of Licensee Event Reports (LERs) had not assessed the station's use of LERs issued at the licensee's Byron station.
- The trend codes for CARS were obtained from initial assessment of root cause instead of the final root cause determination.
The licensee plans to use the final root cause determination in the-future for trending CARS.
b.
Onsite Nuclear Safety Group (ONSG)
The inspectors reviewed the 0NSG activities to ascertain the effectiveness of_the ONSG. The inspectors selected several issues identified in ONSG monthly reports and determined that followup
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actions were timely and thorough.
The monthly ONSG reports reviewed were Bw0NS 90-05, 90-14 and 90-19.
The quality of the ONSG monthly L
reports improved in the area of the amount of information provided to station management. The more recent reports had sections for management action, highlight of ONSG activities, planned activities and appendixes that covered plant status and ONSG activities. The reports were distributed to other licensee station ONSG supervisors for possible lessons learned.
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In addition to monthly reports, the ONSG documented other activities
that were either requested by station management or were related to station events. Examples of these reports were reviewed by the inspector and pertained to:
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Review of main control room activities conducted by ONSG between January 28 - February 7, 1991.
Effectiveness review of the station's locked equipment program during the months of February and March 1991.
- Review of the Economic Generation Control (EGC) system transient that occurred on September 27, 1990.
The reports were comprehensive and provided good recommendations to station management.
The ONSG also participated in the periodic corporate overview meetings to discuss open recommendations and the status of recommendations.
The inspectors reviewed the status of open recommendations and noted no problems, c.
Self-Assessments The inspectors reviewed two corporate Self-Assessments that pertained to " Technical Support" (September 24-28,1990) and "Non-Routine Surveillances" (September 24-28,1990).
Since the Self-Assessments were performed by the licensee's corporate staff, the inspectors could not fully assess the effectiveness of the Self Assessment program as utilized at Braidwood. However, the Self-Assessments reviewed appeared to provide valuable input to the station for improving performance.
The inspectors did identify a concern with an issue identified during the " Technical Support" Self Assessment.
The report identified a Category I Improvement in that some third party-issues had not been resolved in a timely manner with two examples identified. The inspectors reviewed the station's response to the corporate self-assessment group. The response addressed the resolution of specific issues, but not the possible generic issue of' untimely resolution.
The inspectors reviewed the status of other third party issues and did not identify any other issues that had not been resolved in a timely manner. The inspectors concluded that
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there was not a generic issue associated with untimely resolution of third party issues.
d.
Regulatory Assurance The inspectors assessed the Regulatory Assurance Department's Trend /-
Concern Reports and reviewed Licensee Event Reports (LERs) issued at (
the Byron Station for possible impact on Braidwood.
Braidwood and l
Byron are essentially replicate plants.
The corrective actions l
identified in Byron LERs could have possible application to
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Braidwood. The Trend / Concern Reports were issued in April,-July,
October and November, 1990. The purpose of the reports was to advise management of trends identified as a result of operating
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The reports also identified the results of
.Braidwood and Byron common trends. The Braidwood Trend / Concern Reports were distributed to the Byron Regulatory Assurance
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Department, The inspectors identified a concern with the scheduled
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completion dates for'open Action Items.
The completion dates for several Action Items have been routinely changed.
For example:
Trend Subject Action Item Schedule Dates89-008 Procedural Permanent Rev.
April Report, deficiencies to 1/2 BwVS 6/1/90 resulting in violation of 3.2.2-2 July Rpt 8/19/90 Tech Spec.
Nov. Rpt 1/31/91 89-014 Residua'
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April Rpt 5/18/90 Removal j
differences-July Rpt 11/10/90 System tvent between Byron Oct. Rpt 11/10/90 and Braidwood Nov. Rpt 1/1/91 TS surveillance.
89-012-Bus Grounding Modification April Rpt 7/1/90 Events M20-0-87-048 July Rpt 9/1/90 for LSH Sump Oct. Rpt 10/5/90 level switches Nov. Rpt 11/30/90 Even though the above Action Items do not appear to have an immediate safety impact on plant operations, the continued postponement is not indicative of good planning. Overall, the inspectors considered the Trend / Concern Reports as a useful management tool.
The inspectors assessed the station's review of the following Byron LERs for possible impact at-Braidwood:
U_n_i t LER No.
Subleg 1-90-007 Failure to test Main Steam Isolation Valves,90-005 Auto-Start of Fuel Handling Fan 2--
-90-006 Safety Injection-Due to Procedurai Deficiency.90-007 Closed ECCS Throttle Valve.90-008 Dropped Fuel Assembly
90-009 ESF Oue to low-Low Steam Generator Level, The-licensee provided to the inspectors the assessment of the LERs except for LER 90-005, which had not yet been reviewed.
The other Byron LERs were adequately addressed by the Braidwood staff.
In conclusion, based on the ' review of the areas identified above, the inspectors overall considered the licensee's.self-assessment activities as a useful. tool and a positive contribution in the prevention of plant problems. The audit program and the Onsite Nuclear Safety Group continue to show improvement with an. increase use of performance based audits and DNSG activities.
The corporate self assessments also appeared to be a
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useful management tool.
However, since self-assessments were corporate
activities, the inspectors could not fully evaluate the self-assessment process.
The inspectors did identify a concern with the resolution of issues.- The following were examples:
The licensee's audit group had identified two issues that were not corrected in a timely manner.
- The inspectors identified several examples of routine postponements of Action Items in Trends / Concerns Reports.
- Corporate Self-Assessment identified two third party issues (1981 and 1984) that were_not resolved in a timely manner.
No violations or deviations were identified, 15, Meetings and Other Activities (30702)
Site Visits by NRC Staff On April 19, 1991, the Branch Chief for Branch 1 of the Division of Reactor Projects (DRP) and the DRP Section Chief for Braidwood were onsite for a plant tour / meeting with the residents and a brief plant status update presented by the licensee.
16.
Exit Interview The inspectors met with the licensee representatives denoted in Paragraph I during the inspection period and at the conclusion of the inspection on April 24, 1991, 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, 18