IR 05000456/1993023
| ML20059H095 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 01/19/1994 |
| From: | Jorgensen B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20059H088 | List: |
| References | |
| 50-456-93-23, 50-457-93-23, NUDOCS 9401260256 | |
| Download: ML20059H095 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-456/93023(DRP); 50-457/93023(DRP)
Dockets'No. 50-456; 50-457 Licenses No. NPF-72; NPF-77 Licensee:
Commonwealth Edison Company Opus West III 1400 Opus Place Downers Grove, IL 60515 Facility Name:
Braidwood' Station, Units 1 and 2 Inspection At:
Braidwood Site, Braceville, Illinois Inspection Conducted:
November 20, 1993, through January 7, 1994 Inspectors:
S. G. Du Pont E. R. Duncan G. M. Nejfelt Jsw.c d &19w W I- /> 94 Approved By:
Bruce L. Jorgsqden, Chief Date Reactor Projects Section IA Inspection Summary Inspection from November 20, 1993. through January 7. 1994 (Report Nos. 50-456/93023(DRP): 50-457/93023(DRP))
Areas inspected:
Routine, unannounced safety inspection by the resident
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inspectors of licensee action on previously identified items, operational safety, maintenance and surveillance, engineering and technical support, quality verification, and licensee reports.
Results:
No violations or deviations were identified. One non-cited vioiation was identified for the failure to follow quality control procedures (paragraph 4).
Operations Conduct of operations showed good teamwork, a nuclear safety focus, and a high degree of professionalism (paragraph 3).
Engineering A concern was identified with the suitability of the corporate procedure for making operability determinations (paragraph 6).
9401260256 940119 PDR ADOCK 050004561 G
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Good planning and teamwork were demonstrated during emergency diesel generator
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(EDG) maintenance; however, one new replacement part was issued out of stores
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without the required identification tags (paragraph 4).
Other
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The Regional Administrator from NRC Region III and other NRC managers toured the facility on December 8-9, 1993. A summary of their observations is
presented in paragraph 11.
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DETAILS 1.
Persons Contacted Commonwealth Edison Company (CECO)
-i S. Berg, Site Vice President J. Achterberg, Executive Assistant
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K. L. Kofron, Station Manager
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- R. Stols, Support Services Director i
- A. Haeger, Regulatory Assurance Supervisor
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- R. Kerr, Engineering and Construction Manager
- D. E. Cooper, Operations Manager
- G. E. Groth, Maintenance Superintendent R. Byers, Work Control Superintendent D. Miller, Technical Services Superintendent
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- R. Akers, SQV Director
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- K. Bartes, Quality Verification Superintendent
- A. Checca, System Engineering Supervisor i
S. Roth, Security Supervisor
- J. Lewand, Regulatory Assurance
- Denotes those attending the exit interview on January 7, 1994.
i The inspectors also interviewed several other licensee employees.
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2.
Licensee Action on Previously Identified Items (92701, 92702)
r (Closed) Violation 456/91023-01:
In February 1991, the licensee'
i neglected potentially excessive leakage paths which interfered with the
Unit 1 integrated leak' rate test (ILRT). As corrective action, the l
licensee provided additional monitoring and guidance to identify leakage
during containment pressurization. Also, the draft ILRT' procedure
included a data acquisition instrumentation corrective action used at -
i another CECO station.
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The inspector noted that the licensee's commitment to include a caution statement, restricting the use of service air during future ILRTs, was not in the draft procedure revision.
The next ILRT is scheduled for March 1994.
The licensee entered this commitment in their tracking system to ensure the procedure is properly revised. This violation.is
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closed.
3.
Operational Safety Verification (717071 i
The inspectors verified that the facility was being operated in accordance with the licenses and regulatory requirements, and that the licensee's management control system was effectively' carrying out its responsibilities for safe operation.
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During this inspection period, the conduct of operations and the
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emergency diesel generator (EDG) maintenance were specifically observed
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and evaluated.
Conduct of operations throughout this inspection period demonstrated good team work, a nuclear safety focus, and a high degree of r
professionalism. Operations maintained a safety focus during auxiliary feedwater (AFW) system operability determinations and significant maintenance involving the 2B EDG. Throughout these activities, operations maintained good awareness of all activities within the plant
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and conducted all of their processes with a clear objective for safety.
Operations provided good support to the maintenance on the 2B EDG, f
demonstrating excellent teamwork. The maintenance required detailed
coordination and support from several departments to ensure
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accomplishment within the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed by the Technical Specification (TS) Limiting Condition for Operation (LCO).
Operations also made efforts to improve certain administrative processes-
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during this inspection period.
They initiated computer-assisted log keeping and developed a comprehensive configuration control process.
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The configuration control process was developed in-house and
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incorporated a computer program to maintain the status of control-i services.
This process was instrumental in providing plant status for
shift turnovers.
No violations or deviations were identified.
4.
Monthly Maintenance Observation (62703)
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Routinely, station maintenance activities were observed and/or reviewed by the inspectors to ascertain whether they were conducted in accordance
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with approved procedures, regulatory guides and industry codes or
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standards, and in conformance with TSs.
The following items were also considered during this review:
approvals were obtained prior to initiating the work, functional testing and/or calibrations were performed prior to returning components or systems to service, quality control records were maintained, and activities were accomplished by qualified personnel.
Maintenance activities which were observed and/or reviewed included:
I 2B EDG Piston and Liner Replacement
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ISX252 Hot Tap
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IB Rod Drive Motor Generator Set Bearing Replacement
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During the inspection period, significant maintenance was performed on the 2B EDG.
Early in the inspection period, a mechanical noise was heard coming from the 2B EDG during a routine surveillance.
The system i
engineer, with the assistance of station engineering, analyzed the noise
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and determined several possible causes.
Since the TS LCO only allowed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for the diesel. to be inoperable and several different components could have caused the mechanical noise, a detailed plan was developed to inspect the machine and perform corrective maintenance. Work planning, maintenance, engineering, operations, stores, and quality control departments contributed to the planning.
The plan incorporated several parallel paths addressing each possible cause which required several meetings to ensure proper coordination.
During the inspection, one cylinder liner and piston were found to have
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severe scoring. This scoring appeared as noticeable grooves along the surface of both the liner and piston. The root cause of the scoring was determined to be " tinning"; an effect resulting from a reduction.in the lubricating oil layer on the liner.
Subsequently, a modification was incorporated to increase the oil layer on the cylinder liner by removing the oil scraper attached to the piston arm.
The oil scraper was originally manufactured to minimize oil consumption.
The coordination and control of activities associated with the diesels were good with one exception. As the different parallel paths were addressed and resolved, the planned schedule accelerated. As a result, some milestones were accomplished well in advance'of expectations.
This-resulted in the removal of a recently acquired cylinder liner from stores in violation of quality control procedures.
Quality control-procedures require that safety-related components are tagged and identified prior to their removal from stores for receipt inspection. The liner was discovered in the diesel room without the proper identification tags. A deviation was written and the proper receipt inspection was performed.
The licensee immediately initiated a root cause determination and generated corrective actions and lessons learned.
This was a violation of quality control procedures.
However, the violation was categorized at Severity Level V and is not being cited because the criteria specified in Section VII.B.1 of the " General Statement of Policy and Procedures for NRC Enforcement Action,"
(Enforcement Policy, 10 CFR Part 2, Appendix) were satisfied.
One non-cited violation was identified.
No deviations were identified.
5.
Monthly Surveillance Observation (61726)
The inspectors observed several surveillance tests required by TSs during the inspection period and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that results conformed with TSs and procedure requirements and were reviewed, and that any deficiencies identified during the testing were properly resolved.
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Surveillance activities which were observed and/or reviewed included:
lA EDG Monthly Surveillance
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Turbine Generator Governor Control Valve Testing
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Portions of a Unit 2 Reactor Protection System Surveillance
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No violations or deviations were identified.
6.
Engineering and Technical Support During this inspection period, system engineering identified an issue concerning the operability of the motor-driven (MD) AFW pumps.
An operability issue was raised by the system engineer re-examining a
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previously resolved operability question with the AFW system.
Since about 1987, several questions pertaining to the ability of the MD AJW
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pump to switch over to essential service water (SX), the alternate suction source, had been raised and resolved. The system engineer continued to review and analyze these issues.
During this process, the system enginear was not fully satisfied with one of the resolutions and again raised a concern. Operations, once notified by engineering, promptly classified the MD AFW pumps as inoperable.
Although the operability determination by Braidwood's operations cepartment demonstrated compliance with GL 91-18, the inspector identified a concern with the use of the licenseo's operability determination form, QE 40.1.
It was apparent through discussions that engineering intended to complete the QE 40.1 process.
This process involved performing analyses, collecting data, and performing safety evaluations.
Although these activities were appropriate and were prescribed by GL 91-18, QE 40.1 lacked provisions for making timely operability
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determinations commensurate with the safety significance of an issue if that issue is initiated within engineering.
If an issue is initiated by operations, their procedure has provisions for making a timely' initial operability determination.
QE 40.1 would then be initiated to provide the final operability determination. This final operability determination could take months or longer, depending upon the detail of analysis or amount of data required to be collected.
The potential exists for an untimely operability determination if only QE 40.1 is used. This is an unresolved item (50-456/93023-01(DRP); 50-457/93023-01(DRP)) pending the licensee's determination'of appropriate administrative controls for the use of QE 40.1.
Prior to the completion of this inspection, the licensee initiated the review of QE 40.1 and a resolution is expected to be completed during the next inspection period.
During the review of this issue, the inspectors identified that several previous modifications were initiated and completed at both Byron and Braidwood to address similar issues. A concern with adequacy of these
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modifications, their respective 10 CFR 50.59 safety evaluations,'and the timeliness of operability determinations was raised as a second unresolved item (50-456/93023-02(DRP); 50-457/93023-02(DRP)). A region'
based inspector from the Division of Reactor Safety began an inspection
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of this. matter on December 16, 1993.
No violations or deviations were identified. Two unresolved items were
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identified.
7.
Quality verification (35702)
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The Nuclear Quality Performance (NQP) staff demonstrated involvement with leak rate testing by performing a number of surveillances.
The inspector reviewed 10 NQP leak rate surveillances performed since February 1992. These surveillances documented NQP witnessing of local leak rate testing (LLRTs). Also, one NQP surveillance improved Type B leak rate testing methodology by incorporating industry information into station procedures.
No violations or deviations were identified.
8.
Report Review During the inspection period, the inspector reviewed the licensee's
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monthly performance report for November 1993. The inspector confirmed that t:.e information provided met the requirements of TS 6.9.1.8 and Regulatory Guide 1.16.
The inspector also reviewed the licensee's monthly plant status report for December 1993.
I No violations or deviations were identified.
9.
Violations for Which A " Notice of Violation" Will Not Be Issued The NRC uses the Notice of Violation as the usual method for formalizing the existence of a violation of a legally binding requirement. However, because the NRC wants to encourage and support licensee's initiatives i
for self-identification and correction of problems, the NRC will not
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generally issue a Notice of Violation for a Severity Level V violation that meets the tests of 10 CFR 2, Appendix C, Section VII.B.I. These-
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tests are:
1) the violation could not reasonably be expected to have been prevented by the licensee's corrective action for.a previous violation, 2) the violation was or will be corrected in a reasonable time, by specific corrective action committed to by the licensee by the-end of-the inspection, including immediate corrective action and comprehensive corrective action to prevent recurrence, and 3) the violation was not willful.
A violation of regulatory requirements identified.during this inspection for which a Notice of Violation will not be issued is discussed in paragraph 4.
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Unresolved Items
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a Unresolved items are matters about which more information is required in f
order to ascertain whether they are acceptable items, violations, or
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deviations. Unresolved items disclosed during'the inspection are discussed in paragraph 6.
11.
Meetings On December 8 and 9, 1993, Messrs. J. Martin, Regional Administrator, i
Region III; H. B. Clayton, DRP; G. Wright, DRS; and J. Dyer, NRR toured the Braidwood facility and interviewed various members of the licensee's
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staff.
i The following strengths and weaknesses were noted:
Engineering The system engineer certification process was positive. The process resulted in improved experience levels of most system.
l engineers and it appeared that the system engineer was not an entry level position.
The development and use of senior engineer positions was positive.
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An improvement was noted in system engineer and site engineer
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involvement in daily operational activities.
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Improvements were still needed in the areas of " ownership"'of the design basis and in the ability to provide in-house designs.
Some improvements were noted due to recent organizational changes and staff additions.
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The lack of a site specific probabilistic risk assessment (PRA)
and individual plant examination'(IPE) was evident. The IPE is currently being developed.
The role of system engineers was not well defined or understood by
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various departments. This was considered a weakness and was partly due to the licensee's desire to keep the development of system engineering dynamic to meet the station's changing demands.
Self Assessment
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The quality of SQV inspectors had improved. This was partly due-to recent staff additions and the improvements made in experience levels of the inspectors.
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Management receptiveness to identification of problems was considered to be positive.
Root cause determinations have improved and were found to be
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thorough.
The line organizations understood the need for self assessment,
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but did not, in all cases, understand how to perform these
assessments. This was considered to still need improvement.
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The SQV staff was found to be limited in size and could easily be-
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saddled with line duties.
Recent staff additions and continued improvements in the line organization's ability to perform self assessments should provide improvements in this area.
Other Communication and cooperation between departments were noted to
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have improved.
Senior man..,_ ment goals were clearly communicated.
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A willingness to change and a desire to do a good job were
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demonstrated by the individuals interviewed.
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i The radiological protection department demonstrated good support to other departments.
l Vertical communication was found to need improvement.
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Plant housekeeping needed improvement as indicated by a recent
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decline in appearance.
Safety Focus
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Although several examples existed that demonstrated good safety focus (paragraph 3), not all departments or levels of the staff demonstrated that the licensee's primary focus must be on safety.
12.
Exit Interview j
The inspectors met with the licensee representatives denoted in paragraph I during the inspection period and at the conclusion of the inspection on January 7, 1994. The inspectors summarized the scope and results of the inspection and discussed the likely content of this inspection report. The licensee acknowledged the information and did not indicate that any of the information disclosed during the inspection could be considered proprietary in nature.
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