IR 05000456/1997013

Insp Repts 50-456/97-13 & 50-457/97-13 on 970701-0811. Violations Noted.Major Areas Inspected:Operations, Maintenance,Engineering & Plant Support

ML20217C495
Person / Time
Site:	Braidwood
Issue date:	09/17/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20217C470	List: IR 05000456/1997013 ML20217C465 ML20217C484
References
50-456-97-13, 50-457-97-13, NUDOCS 9710010418
Download: ML20217C495 (24)

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U.S. NUCLEAR REGULATORY COMMISSION -

REGION 111 Docket Nos: 50-456, 50-457 Ucense Nos: NPF-72, NPF-77 Report No:

50-456/97013(DRP); 50-457/97013(DRP)

Ucensee:

Commonwealth Edison (Comed)

Facility: Braldwood Nuclear Plant, Units 1 and 2

Location: RR #1, Box 84 Braceville,IL 60407 Dates: July 1 through August 11,1997 Inspectors:

C, Phillips, Senior Resident inspetter J. Adams, Resident inspector T. Tongue, Project Engineer T, Esper, Illinois Department of Nuclear Safety Approved by: R. D. Lanksbury, Chief, Projects Branch 3 Division of Reactor Projects I

e 9710010418 970917 PDR ADOCK 05000456 G PDR

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EXECUTIVE SUMMARY l Braidwood Nuclear Plant, Units 1 & 2

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NRC Inspection Report 50-456/97013(DRP); 50-457/97013(DRP)

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i This inspection included aspects of licensee operations, maintenance, engineering, and plant i

support. The report covers a 6-week period of resident inspection from July 1 through August 11,1997.

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Operatlana i

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Operators failure to strictly follow procedures resulted in a Unit 1 reactor coolant system excess dilution event on May 31,1997. This event had minor safety consequence and the licensee's root cause investigation was accurate, thorough, and

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self-critical.' This non-repetitive, licensee-identified and corrected violation is being treated as a Non Cited Violation. (Section 01.2)

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Plant procedure changes and 10 CFR 50.59 safety evaluation screenings and safety evaluations were performed in accordance with administrative procedures.

(Section 03.1)

Maintenanca 4- -

The inspectors observed a surveillance test failure of the 18 essential service water pump on June 24,1997. The maintenance staff provided prompt support to identify j the problem and recalibrate the pump discharge pressure instrumentation to restore

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the pump to operable stetus. (Section M1.1)

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A scheduled corrective maintenance activity performed on a feedwater containment

isolation valve and an emergent corrective maintenance activity performed on a main j

steam isolation valve were well planned and executed and the personnel involved demonstrated excellent team work. (Sections M1.2 and M1.3) -

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The material condition of the component cooling water system was satisfactory and the system was aligned as required by plant procedures. (Section M2.1)

Enninmarinn

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During the performance of a surveillan test on the 2A safety injection pump, the system engineer failed to question a lower than expected pressure drop across the lubricating oil filter. The system engineer was not aware of the internal relief feature of the filter and did not consider the possible relationship between the relief feature and the lower than expected pressure drop across the filter. (Section E2.1)

During the performance of a diesel generator engine analysis test, the licensee was

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following work practices with the potential to introduce foreign material into the running engine. The system engineer and mechanic were not aware of the potential

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problems presented by the handling of loose parts over an opening in the diesel generator's cylinder head. (Section E2.2)

Mant R'apport

The control of portable radiation detectors was good. The detectors appeared to be properly calibrated and in good condition. (Section R2.1)

A primary alarm station operator did nut give full attention to his assigned duties, but was aware of the status of equipment and existing alarm condition (Section S1.1)

An unattended and energized welding machine located outside the 2A diesel generator room was identified Sy the inspectors. The failure to follow fire protection program procedures resulted in a potentially serious fire hazard and is an example of

a violation of Technical Specification 6.8.1.g. (Section F1.1)

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R nnrt Details Summary _of Nnt Mtatus Both Unit 1 and Unit 2 entered the period at or near 100% full power and operated routinely for the entire perio t 1. on...tin Conduct of Operations 01.1 r'antrni Ranm staff nh..rvatin In.n.etrnn nenn. (71707)

The inspectors observed contro; room activities during the period. The inspectors also reviewed procedure BwAP 300-1, " Conduct of Operations," Revision 19 E1, nh..,v tinn. an, rinan Communications between personnel in the control room and between control room personnel and operators in the field were clear. Three-way communication techniques were used. Alarm procedures were used when unexpected annunciator -

alarms were received. The control room was quiet and staff demeanor was professional. Control room access was well controlled by unit supervisors. Logs were maintained and updated as necessar Cnnclusions The inspectors concluded that, during the observed periods, the control room staff followed appropriate plant procedures and used good communication technique .2 Unit 1 R.artnr Ennlant sv.t.nt.jBCE) run eelv. Enntinunne Dilutinn inen.ctinn Renn. (71707)

The inspectors performed an independent review of an excessive continuous dilution of the RCS that occurred on May 31,1997; interviewed the nuclear station operator (NSO) that performed the excessive continuous dilut!on; and reviewed the results of the licensee's root cause investigation. The inspectors also reviewed procedures BwOP CV-5, " Operation of the Reactor Makeup System in the Dilute / Alternate Dilute Mode," Revision SE4; BwAR 1-14-D1, "Tave Control Deviation High," Revision 7; BwlP 2000-T3, " Calibration Test Report for IFC-0111," Revision 2; and BwCB-1, Figure 12, " Boron Dilution Rate Nomograph," Revision 12; and reviewed Braidwood Station Root Cause Report 456 200-97-SCA000053, Revision 0 l l

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e Ohmarvatiorin and Findinas On May 31,1997, following a reactor power increase, operators repeatedly diluted ,

the Unit 1 RCS in the batch mode to adjust reactor coolant average temperature (Tave) and to control nuclear instrument differential current (delta 1) following a reactor power increase. The dilutions were 50 gallons each and were performed at 20 minute intervals. In an attempt to minimize Tave fluctuations, the operation's crew decided to perform a continuous dilution in accordance with licensee procedure BwOP CV 5. At 6:20 p.m., a continuous dilution was attempted at an indicated rate of 2.5 gallons per minute (gpm).- The NSO monitoring the dilution observed that -

reactor power and Tave increased at a rate greater than expected and, at 6:37 p.m.,

the dilution was secured by the NSO, ' At 6:40 p.m., the Tave Control Deviation High alarm was received and operators took correctiva actions as specified in the annunciator response procedure (BwAR 1-14 D1). At 7:39 p.m., the Tave Control Deviation High alarm cleare The inspectors performed an independent review of the event concurrent with the licensee's investigation. The inspectors found that procedure BwOP CV 5, Step F 7.b, required the operator to set the primary water "predet" counter (1FY-0111) to the desired volume of prima / water to be added. The NSO did not set the counter to a conservatively predetermined value. Instead, the NSO set the counter at a high value, essentially removing the ability of the counter to terminate the dilution. Also, procedure BwOP CV 5, Steps F.1 through F.5, required the operator to determine and adjust the Primary Water / Total Flow Potentiometer *

(1FK-0111) set point to a value that corresponded to a flow rate determined fro the boron dilution rate nomograph. The inspectors determined that Steps through F.5 could not have been performed as written since the desired flow rate of 2.5 gpm was below the scale of the nomograp The inspectors reviewed the instrument calibration report fo- the primary water flow controller (1FC-0111) and discussed instrument performance with the system

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engineer. The inspectors found that the flow controlinstrument was accurate to -

within 3% of full scale (160gpm). The inspectors performed a simple calculation that confirmed a minimum accurate flow rate of 4.8 gpm. Post event reactivity calculations performed by the licensee indicated an actual dilution rate of about 5 gpm. The inspectors did not find any precaution or limitation in procedure BwOP

._CV-5 that provided guidance on a minimum dilution flow rat The inspectors reviewed the licensee's root cause investigation and compared the licensee's findings to the inspector's. The inspectors identified the lack of strict procedure compliance and the operation of the system outside its accurate range as root causes. The licensee also identified the same root causes as the inspector Additionally, the licensee identified three other contribut','g factors:

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an inadequate pre-job briefing that did not include a value of temperature increase nor a dilution volume at which the dilution should have been discontinued:

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failure to provide supervisory direction to expeditiously restore Tave; and

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failure of the unit supervisor to promptly notify the shift manager of the even The licensee's immediate corrective actions of stopping the dilution, increasing turbine load, and inserting control rods were correctly performed in accordance with procedures BwOP CV 5 and BwAR 1 14-D1. Additionally, the shift managers discussed the event in detail during shift briefings and the operating crews were directed not to perform continuous dilutions until the Investigation was completed and applicable procedures reviewed. Operators involved in the event were also removed from shift duties to assist with the event investigatio The licensee either implemented or planned to take the following corrective actions to prevent recurrence:

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the operations curriculum review committee will review the root cause report for lessons learned and applicability to future continuing training;

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necessary changes to procedures or expectations will be included in future training:

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initial license trbining material will be revised to include lessons learned;

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procedures BwOP CV 5," Operation of the Reactor Makeup System in the Dilute / Alternate Dilute Mode"; BwOP CV-6, " Operation of the Reactor Makeup System in the Borate Mode"; BwOP CV 7, " Operation of the Reactor Makeup System in the Auto Makeup or Manual Mode"; and BwAR 1-14-D1, "Tave Control Deviation High" will be reviewed for clarity and consistency;

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information will be included in the applicable procedures that prohibits performing continuous dilutions below a flow rate of 32 gpm or a boration below a flow rate of 8 gpm;

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to address the issue of procedure non-adherence, operators will be required to mark each step indicating that they have read, understood, and performed each step (formal placekeep);

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the shift manager will discuss the event at a peer group meeting of shift managers:

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the shift manager, unit supervisors, and NSOs were counseled concerning the proper use of procedures, the need to correct plant problems in a expeditious and safe manner, on keeping shift management informed of changing plant conditions, and on the importance of precise communications; and

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the shift manager and unit supervisor were counseled on the need to keep station management informed of plant problems and events, and the need to

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conduct prompt investigations as soon as possible after the event is

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identified.

The inspectors verified that the maximum Tave reached in this event did not exceed the limits contained in Technical Specification (TS) 3.2.5, T.S. safety limits, or the

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value of Tave used in Updated Final Safety Analysis Report (UFSAR), Chapter 15, safety analysis. Also, neither the overtemperature differential temperature or the

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overpower differential temperature setpoints were challenged by the event.

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The failure to perform the required actions of procedure BwOP CV-5 was an example j of a violation of TS 6.8.1.a which requires that written procedures be adhered to,

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This non-repetitive, licensee-identified and corrected violation is being treated as a j

Non Cited Violation, consistent with Section Vll.8.1 of the NRC Enforcement Policy

(50-456/97013-01(DRP)).

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A The licensee conducted an accurate, thorough, and self critical root cause investigation of the excess dilution of the Unit 1 reactor coolant system. This conclusion was based on the inspectors independent inspection findings in comt,! nation with a review of the licensee's root cause report. The magnitude of the Tave deviation had minor safety consequence since it was temporary and did not approach TS limits or UFSAR safety analysis limits.- However, the inspectors were concerned that this event resulted from the operators failure to strictly follow .'

procedure The proposed corrective actions appeared adequate to address the root causes of the event and should prevent recurrence. The licensee's prompt recognition and immediate corrective action were correct and effective in the restoration of Tave; although, the restoration of Tave could have been more timel Operations Procedures and Documentation 03.1 Plant Prneadora channa Praca==a= Inanactinn Renna (71707)

The inspectors reviewed the processes for changing procedures at the plant, including procedure revisions, procedure minor corrections, and temporary procedure changes (TPC). The inspectors interviewed plant procedure writers, clerks, and supervisory personnel. The inspectors also reviewed the following administrative procedures:

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BwAP 1205-2, "On Site Or Technical Review of Procedures," Revision 16;

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BwAP 13001, " Station Procedure Manuals," Revision 7; BwAP 1300-3, " Preparation and Approval of Temporary Procedures and

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Temporary Changes to Permanent Procedures," Revision 18E3; t

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BwAP 1300-8, " Minor Corrections of Approved Station Procedures," Revision 2E2;and 4- .

BwAP 1300-10, " Permanent Procedure Preparation, Revision, Deletion and

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Approval," Revision 2E3.

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l The inspectors reviewed the implementatloa of the procedure minor corrections i

process controlled by procedure BwAP 1300-8. Procedures changed under this

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process did not require an in-depth technical review. The inspectors reviewed the

, minor corrections log book and found that only six minor corrections were

implemented in the first 6 months of 1997. This appeared to be an improvement i over 1996, when a total of 173 minor corrections were implemented.

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The inspectors reviewed existing TPCs. On the day that the log was printed, only

seven TPCs were in use for the entire population of plant procedures (approximately

11,800 procedures). The inspectors reviewed the 10 CFR 50.59 safety evaluation

screening for each TPC in the log. All screenings were appropriately completed and,

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when required, full 10 CFR 50.59 Safety Evaluations were performed. The inspectors reviewed the 10 CFR 50.59 Safety Evaluation for TFC #7468 to.

j procedure BwFP FH 20T4, " Fuel Crane Heavy Load Lifts Using The Auxiliary Hook,"

l Revision 1. The safety evaluation was completed satisfactorily and licensee j personnel used sound engineering principles and reasoning.

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! Procedure revision processes were also reviewed. The inspectors reviewed revision

packages for p.ocedures BwFP FH-20, " Operation of Fuel Handling' Building Crane,"

i Revision 5; 18wEP-0, " Reactor Trip or Safety injection U1 " Revision 1 A; BwCP 323-L 30, "CW, WS, and Essential Service Water (SX) Systems Surveillance and Sampling,"

[ Revision 1E1; and BwAP 1600-1, " Action / Work Request Processing Procedure,"

j_ Revision 32. All revision paperwork was complete. All required reviews and 10 Cl R j 50.59 safety evaluation screenings were performed and 10 CFR 50.59 safety l evaluations appeared to be completed as required.

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The inspectors found procedure group personnel to be generally knowledgeable of revision and temporary change processes. However, the inspectors noted that procedures personnel were not very familiar with processes for implementing minor l corrections. This may have been due to the limited usage of the minor correction

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Minor plant procedure changes reviewed were performed in accordance with station i administrative procedures. Additionally,10 CFR 50.59 safety evaluation screenings

and safety evaluations were performed as required for procedure changes. The low -

i number of TPCs and minor corrections in place illustrated that the licensee was predominantly using the revision process to change procedures in ileu of just making 4 temporary changes.

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.- 1 08 Miscellaneous Operations issues (92700 and 92901)

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0 ar'in..d) vintattan tvioi Kn 4Ra/ nan 14.n1; " incorrect Procedure Revision Used While Performing a Monthly Test on the 1B Diesel Generator (DG)." This violation resulted from an administrative clerk replacing the existing procedure in the control

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file after the unit supervisor made a field copy to perform the test. The s!tuation was identified during the test by the inspectors and corrected by the licunsee. In

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. order to prevent recurrence, the licensee has changed the routing of an existing document " Passport Document / Drawing Transmittal" from the shift manager to the unit supervisors. The inspectors reviewed the process, interviewed unit foremen,

and verified the availability of the document to assure that the proper procedure

! revisions for documents or tests were used. in addition, the unit supervisors stated *

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that the station computer files can be used for the same purposes. The inspectors concluded that the corrective actions were acceptable and this, violation is close .2 inn n) vio sn.ansionnin.ni: " Failure to Have a Procedure or Guideline for i Bypassing CV 121." The inspectors reviewed the licensee corrective actions,

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f including revisions made to procedures; BwGP 100-5, " Plant Shutdown and

! Cooldown," Revision 14E1; procedures BwGP 100-1, " Plant Heatup," Revision 9E2;

and BwOP CV 27, "CV121 Bypass Operation," Revision O. Procedures BwGP 100-5

, and BwGP 100-1 had statements added to forewarn operators of problems related to

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bypassing CV-121 (charging system flow control valve) and steps to prevent j pressurizer overfill Procedure BwOP CV 27 specifically addressed the bypassing of i

valve CV-121 and provided appropriate guidance. These procedures and/or changes j were found to be acceptable. The licensee also added valve CV-121 to the j " Operator Work Around" list and the inspector reviewed the list of options available

for correction. At the time of the inspection, the licensee had not made a decision j on which option to pursue. This issue will remain open until the inspectors can

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review the decision made and the modification (s) implemente II. Maintenanea i

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M1 - Conduct of Maintenance

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M 1.1 RurvaiH-nca Tant Run nf 1R Feeantial Karvica Watar IRX) Pump s

{ in=nactinn scana (61726)

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On June 24,1997, the 18 SX pump was started as part of performing surveillance

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test procedure 1BwVS 0.5-3.SX.1-2, "ASME [American Society of Mechanical i

Engineers] Surveillance Requirements for 1B SX Pump," Revision OE1. The

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inspectors monitored the performance of the test at the 18 SX pump and interviewed

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the test director and the plant equipment operator stationed at the 18 SX pump during the test.

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. Ohnervatione nnri Findings During performance of the surveillance test, the inspectors observed the following:

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Operations department management provided a dedicated equipment operator for the test. The equipment operator used self checking when operating plant equipmen The equipment operator at the pump utilized three way communications techniques every time he talked with the unit NSO in the control roo The system engineer acted as the test director for the surveillance test and was present at the pump during performance of the entire test. The system engineer was knowledgeable of operation of the plant equipment and use of test equipmen Test equipment and instrumentation used in the test werc within calibration due dates and were insta!!ed as required by the procedure.

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The system engineer maintained a copy of the surveillance te ' procedure and all test data was logged in the p.acedure as the steps were tforme The first attempt to perform the surveillance test resulted in a failed tes Step F.1.21 of procedure 18wVS 0.5-3.SX.1-2 required that the pun differential pressure be calculated using the pressure values obtain from pressure gages 1PI-SX149 (pump inlet pressure) and 1PI-SX020 (pump discharge pressure). This calculation indicated that the pump differential pressure was outside of the acceptance criteria (actual reading was 70 pounds per square inch differential (psid)

with acceptance criteria of greater than 70.2 psid).

The system engineer recognized that the acceptance criteria had not been met and immediately notified operations personnel of the problem. Operations personnel declared the 18 SX pump inoperable and initiated actions in accordance with TS limiting condition for operation (LCO) Action Statement 3.7.4.a for an inoperable SX pump. Additionally, operations personnel generateu a problem identification form for the test failur The system engineer suspected calibration problems with the pump suction and discharge pressure gages. Instrument maintenance personnel checked both the pump suction and discharge pressure gages and determined that they were out of calibration. Both gages were subsequently recalibrated. After recalibrating the pump discharge pressure gage, procedure 18wVS 0.5-3.SX.1-2 was reperformed and the 1B SX pump was detarmined to be operable. The TS LCO action statement was then exite . J

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. Cngelucinns Operations and system engineering support for performance of the surveillance test on the 18 SX pump was good. The system engineer recognized the failure to satisfy acceptance criteria during the first test and immediately notified operations personnel. Operations personnel, upon notification of an inoperable SX pump, took prompt and appropriate action. Maintenance staff provided prompt support to recalibrate pressure instrumentation for the 1B SX pump in order to restore the pump to operable statu M1.2 Renntr nf ranelwater Contninment lenintinn Valva Nitrngan Accomplatnr Lina Flhnw trwonne Inenactinn hapa (62707)

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On July 11, the inspectors observed maintenance performed on a nitrogen accumulation line elbow for the Unit 1, C feedwater supply containment isolation valve,1FWOO9C: the pre-job briefing; the placement of the out-of service (OOS); and reviewed the contents of work packages WR# 970065433-01 and 970065433-0 On July 15, the inspectors interviewed the unit supervisor to assess the effectiveness of the maintenance activity, nhearvatinne nnri Finaings

. The inspectors attended the heightened level of awareness (HLA) briefing for the replacement of a leaking elbow on the nitrogen accumulator for 1FWOO9C. The shift manager led the briefing of operations, maintenance, system engineering, site quality

verificulon, and radiation protection personnel who were in attendance. The shift manager discussed contingency plans in great detail since the maintenance activity required entry into a 4-hour TS LCO. A unit shutdown plan and timetable had been developed in the event that the maintenance activity did not proceed as expecte The shift manager was instructed to commence an HLA briefing for the Unit 1 shutdown 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> into the TS LCO and commence the shutdown 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> into the TS LC The inspectors reviewed the work packages at the job location prior to the commencement of the actual work. The repair package (WR# 970065433-01) and a temporary alteration installation package (WR# 970065433-02) were well written, clear, complete, and provided explicit instructions and contingency step The inspectors observed the proper hanging of the OOS and verified that the LCO was properly entered. The field supervisor and an equipment operator provided continuous support for maintenance personnel and communications with the control roo The inspectors noted that maintenance personnel used the procedures contained in the work packages and that the work was expeditiously performed in a safe manne Maintenance personnel performed a final self-check prior to releasing the OO _ _ . _ _ . _ _ _ _. _ _ ... _ _. _ _ .._ .. _ .__ _ _ . _ ..._ _ _._ _ . _ -

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i L Following the clearance of the OOS, maintenance personnel were observed

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j performing leak checks on the new fittings and on nearby fittings that may have 1 been disturbed during the maintenance' activity. On completion of the work, the field.

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supervisor.and the maintenance foreman conducted a debrief with the system engineer, maintenance, and operations personnel to determine if anyone had j concerns with the maintenance activity performed or with the operable status of the

valve.- Maintenance personnel indicated that they had no concerns with the repair i

and had no reason to believe that the valve would not function properly if required.

i The field supervisor reported to the control room that the maintenance activity on J

1FWOO9C was complete.

i j On July 15, the inspectors interviewed the unit supervisor and reviewed the NSO -

logs to determine if the 1FWOO9C nitrogen accumulator still required frequent

charging. The unit supervisor indicated that the 1FWOO9C accumulator pressure i was stable. The inspectors found no record of the need to charge the 1FWOO9C accumulator following the completion of the maintenance activit canet"= lana

[ The preparation for and performance of the maintenance activity on the 1FWOO9C

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, - nitrogen accumulator line elbow was excellent. The maintenance activity.was well

planned and executed. The different functional groups demonstrated excellent team

work in the performance of the repairs. An excellent safety focus was demonstrated

with the inclusion of contingency plans for the unit shutdown should it have become

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necessary.' Procedures and instructions were well written and followed. A-i temporary alteration was approved and available in the event that the maintenance

}~ activity was not successful. Post-maintenance testing was thorough and carefully

{ performed. . The maintenance was effective and no re-work was required. .

i-l - M1.3 Rannir nf thm 9D Main Etamm lentatinn Valva (MRIV)

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[ Yhe inspectors observed the troubleshooting efforts and repair of the 2D MSIV;

interviewed the unit supervisor and the system engineering group leader for p secondary systems: and reviewed work package WR# 97007699 _

f nhearvatinns and Findinne j On July 15, the inspectors were informed by the licensee that the 2D MSIV failed to return to its full open position following a fast exercise test of the standby actuator, i The licensee declared the standby actuator inoperable and entered a l 48-hour TS LCO.

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engineering group leader. The group leader indicated that the active side actuator

.was available and had been successfully fast exercised prior to the standby

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i actuator's failure. Also, none of the three components identified as potential sources of the problem were common to both the active and standby actuators.

The inspectors observed a portion of the work package preparation and

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troubleshooting actMties. The troubleshooting steps in the work package provided -

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specific direction to test the limit switches first since they were the most probable cause of the problem. If the limit switches tested acceptably, direction was included to then check the four-way valve solenoids followed by the four way valve itsel The inspectors inquired about the availability of replacement parta and were told that

new limit switches, solenoids, and a rebuilt four-way valve were availabl The licensee's troubleshooting efforts revealed dirty limit switch contacts. The work

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package es written covered the cleaning of limit switch contacts. The maintenance

' personnel cleaned the limit switch contacts and the 20 MSIV was satisfactorily teste c.- ranni"=Inna I

System engineering promptly supported operation's request for assistance. Excellent

! direction, guidance, and leadership was provided by the secondary systems group t

leader in the prompt development of troubleshooting and contingency plan Excellent teamwork was also demonstrated by system engineering, maintenance, and i

operations in the identification of the problem, subsequent repair, and the satisfactorily testing of the 2D MSIV. The work package was well written and

contained , sufficient detail for the scope of the work being performe M1.4 Survaillmaca T..t. nh=.rvariane

• Innnactlan Reana (61726)

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The inspectors observed all or portions of the following surveillance tests:

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2BwVS 5.2.f 2-1, "ASME Surveillance Requirements for the 2A Safety injection Pump," Revision 4;

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2BwVS 8.1.1.2.a-1, "2A Diesel Generator Operability Monthly (Staggered),"

g Revision 12;

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BwVS 900-8, " Diesel Generator Engine Analysis," Revision 3:

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. OBwOS SY-W1, " Unit Common 345 Kilovolt Switchyard Weekly

} Surveillance," Revision 7; j and reviewed the surveillance test results.

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. Ohsarvations and Findings i-The inspectors observed pre-job briefings for each of the surveillance tests listed-l' above. The inspectors found that the briefings exceeded the requirements of i

procedure BwAP 10012, " Human Performance Awareness."

The inspectors observed and verified that all surveillance tests were performed in accordance with their applicable procedures, that equipment operation and performance parameters met acceptance criteria, that proper communications i

between the control room and personnel in the field occurred, and that all instruments used in the performance of the surveillance tests were in calibratio The inspectors reviewed applicable TSs and applicable sections of the UFSAR and j

found no discrepancies with the test acceptance criteria or scop Onndmeinna t

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accordance with procedures and all acceptance criteria were met. Pre-job briefings

s were thorough and exceeded minimum briefing requirements. The inspectors also concluded that the procedures were well written and (psured TS and UFSAR

, requirements were tested.

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M2 Maintenance and Material Condition of Facilities and Equipment

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M2.1 cnmpnnant canunn Watar fcci Kvntam inenketinn Renne (71707)

- The inspectors reviewed the CC system, including system design bases in the UFSAR i

and system lineups and drawings. The inspectors performed a walkdown of the CC i system outside containment. Portions of the CC system inside containment were not accessible due to unit operation and resultant radiation levels. The inspectors also -

l interviewed the system enginee ,

i Ohsarvatinns and Findings

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The inspectors performed a walkdown of the CC system and noted the following i items:

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l The condition of general areas containing the CC pumps,- CC heat exchangers

!~ and CC surge tanks was good. Tools and equipment were stored in

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designated locations and all CC components were accessible. The condition of CC system components was generally good.

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Action requests (AR) were generated and AR identification tags were in place

) for items requiring repai ,

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Except for minor leaks of 12 drops per minute on the 2B CC pump inboard and outboard seals, no CC water leaks to atmosphere were identified. There was a water leak in the Unit 0 (Common) CC heat exchanger tubes. This leak

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.was scheduled for repair in late 1997.

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Numerous minor oilleaks existed on the CC pump bearings. Discussion with

the system engineer indicated that a small amount of oilleakage may be

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acceptable for these bearings. However, ARs were outstanding for each oil leak. The system engineer was pursuing canceling the ARs and training plant personnel on this issue.

The CC system and associated components were aligned as required by procedure

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' BwoP CC-M1," Mechanical Alignment - Unit 1," BwCP CC-M2, " Mechanical Alignment - Unit 2," and BwOP CC-M3, " Mechanical Alignment - Unit 0."

, canel"=lann

Overall, material condition of the CC system appeared good. The CC system was l - aligned as required by the applicable plant procedures.

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M2.2 cantainmant Rarmy chaele Valva in=nactian i

- In=aaetian mean. (62707) -

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' The inspectors performed a routine inspection of maintenance activities in progress by review of work request 970074222 for the disassembly and inspection of the 2A i

containment spray pump discharge check valve (2CS003A) and procedore BwOP l CS-4," Draining The Containment Spray System (Water Side)," Revision 6. This is

also discussed in Section R4.1.

i chearvatione and Findinne

The inspectors reviewed the instructions for removal and inspection of the check valve and determined that they were clear and well written. The inspectors observed i that the maintenance workers followed the procedure and used good foreign material-

control work practices.

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The inspectors noted that the maintenance had to be completed over a shift turnover. -The oncoming maintenance crew was unaware that the bolts for the check valve had not been cleaned or inspected. A quality controlinspector came to the worksite with the oncoming crew and rejected the bolting because of their

physical condition. The workers were able to withdraw new bolts from storage and -

] complete the job. The inspectors also observed that the internals of the check valve d

were free of interaal corrosion and all mechanical parts moved freely without L

degradation.

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. Cnndusions The inspectors concluded the maintenance activity nn the 2A containment spray pump discharge check valve was conducted in accordance with appropriate instructions and procedure M8 Miscellaneous Maintenance issues (92902)

M8.1 ICineaa) vio R0-4Es/nsn19-nd This violation resulted from the licensee's preconditioning of a component (DG SX valve) that was regulred to function as part of the DG monthly and semiannual operability surveillance tests. The DG SX cooling water valve was cycled prior to the start of the DGs in order to test the alarm 'MCC Not Proper for Operation." The licensee modified the affected surveillance test procedures 18wOS 8.1.1.2.a 1, "1 A DG Operability Monthly (Staggered) and Semi-annual (Staggered) Surveillance"; Bw0P-11, "DG Startup"; and BwOP-12, "DG Shutdown" by placing the alarm test step at a later point in the procedures. This change in procedural test sequencing resulted in the SX valve no longer being preconditioned. This violation is close M8.2 (Cinead) vin so-4R8/nsn91-n?fDRPh 4R7/nsn91 n9fDRP) " improper Securing of Carts to Protect Safety-Related Equipment." This violation pertained to the failure to take timely action to secure unattended or unsecured carts that supported temporary shielding attached to safety related equipment. After the second notification by the inspectors, the carts were properly secured. in addition, on June 3,1997,in an address to all first line supervisors, the site Vice President emphasized the importance of identifying and properly correcting deficiencies. As of the end of this inspection, the resident inspectors have not identified any discrepancies regarding the securing of carts during routine inspections or other failures to take appropriate actions for identified problems. This violation is close ,

111. Engineadng E2 Engineering Support of Facilities and Equipment E Ohcarved Chnngas in the 9A Rnfaty injactinn (RU Pumn I nha Oil _Filtar niffarantini Pracenra The inspectors observed the performance of the 2A SI pump Arrerican Society of Mechanical Engineers (ASME) surveillance test, discussed their observations with the system engineers, and reviewed proceduros 2BwVS 5.2.f.2-1, "ASME Surveillance Requirements for the 2A Safety injection Pump," Revision 4; BwOP SI-1, " Safety injection System Startup," Revision 6E1; Pacific Pumps, Operating and Maintenance Manual, Manual Number 310 __________ _ ___ __

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. Ohmarvattaan and Findinne

On August 5, the inspectors observed the performance of test procedure 28wVS 5.2.f.21 on the 2A Si pump. Steps F.2.1.e through F.2.1.g of procedure 2BwVS 5.2.f.2-1 requirea the measurement and recording of the lobe oil filter inlet pressure and the tube oil filter outlet pressure from which the differential pressure was

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calculated and recorded. A note preceding Step F.2.1.g indicated a normal pressure drop'across the tube oil filter of 3 psid. The inspectors observed a maximum of 1 psid pressure drop during the operation of the pump and discussed the observation with the system engineer. The system engineer was not concerned with the lower than expected value since it was not indicative of restricted oil flo The inspectors reviewed the vendor manual for the Si pumps and found that the lube oil filter was equipped with an intomal relief that would bypass the filter element if a 10 psid pressure drop across the filter element occurred. The lispectors discussed the. filter bypass feature with the system engineer and questioned its relationship to the below normallube oil filter pressure drop observed during the test. The

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inspectors considered the failure of the filter bypass as a possible cause for the low pressure drop across the lube oil filter since the licensee had recently observed variations and higher than normal tube oil system pressures. The system engineer told the inspectors that he did not believe the below normal lube oil filter pressure drop was an operability concern, but admitted that he had not considered the failure of the filter bypass feature. The system engineer stated tnat the filter 'vould be inspected during an upcoming work window in September 199 The inspectors verified that the system lobe oil pressure met the vendor's minimum requirements, that bearing temperatures were within their acceptable range, and that neither the tube oil system pressure nor the lube oil filter pressure drop were acceptance criteria for test procedure 2BwVS 5.2.f.2 cancineinne The acceptance criteria for test procedure 2BwVS 5.f'2-1 were met but the system

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engineer did not question the below normal pressure drop across the lubricating oil filter. The systerr engineer was not aware of the bypass feature on the lubricating oil filter and had not considered it as a possible failure. The inspt:: tors agreed with the system engineer that bypassing of the filter does not necessarily constitute an operability concern since the flow of oil to the pump bearings would not be interrupte E2.2 Entaien untarial ruineinn trup) cnnearne noring niacan r:anarntnr parinrman Analynie Inenactinn Rcana (61726:

The inspectors observed the licensee perform procedure BwVS 900-8, " Diesel Generator Engine Analysis," Revision 3; reviewed procedure SMP-M-04, " Foreign Material Exclusion," Revision 0; and interviewed the system enginee .. ..

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, . Observations _andfindings On July 9, the inspectors observed the licensee perform procedure BwVS 900 8 on the 2A diesel generator. Section F.3 required the removal of the rocker arm inspsction covers, with the engine running, in order to take vibration measurements.

During the removal of the rocker arm inspection covers, the inspectors observed i

activities by the mechanic that could have resulted in the introduction of foreign materialinto the running engine. On several occaslons the mechanlc's hands, I holding bolts removed from the inspection covers, passed over the opening in the adjacent cylinder of the running engine. This provioed an opportunity for the introduction of foreign materialif the bolts were accidentally droppe The inspectors reviewed FME procedure SMP M-04 and rr.,ted that the licensee satifisfied the FME procedural requirements during the performance of the test. With '

the exception described above, personnel performing the work were observed taking actions to prevent the introduction of foreign material. The inspectors observed the licensee perform a thorough visual inspection then proraptly replace the access covers on each cylinde The inspectors discussed their observations with the system enginoir. The system engineer agreed with the Inspectors concerns and indicated that he would look for methods to increase maintenance personnel awareness of the potential for and the introduction of FME Into a running diesel engin Conclusions While FME controls were generally adequate, the system engineer and the mechanic removing the rocker arm access coverb were not aware of the potential FME problems that could result from the passing of loose parts over an open cylinder head on a running diesel engin IV._P1ANISUPEDRT R2 Status of Radiological Protection and Chemistry (RP&C) Facilities and Equipment R2.1 Radiation Monitors InspectionScope (71750)

The inspectors routinely inspected the status of radiation monitors located in the plan Observations.and Eindings Portable radiation detectors are placed throughout the plant to allow personnel to check for contamination and also for radiation protection (RP) department personnel to check general area radiation levels. The inspectors routinely checked the status of

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detectors stationed in the auxiliary building, fuel handling building, radweste building, .

! and technical support center. All detectors were found to be properly calibrated and  !

j in good operational conditio '

I l Enani"*I^an

l- The control of radiation detectors in the auxiliary building during this inspection  !

period was good. Radiation protection department personnel maintained the ,

instruments within calibn tlon and in good conditio R4 Staff Knowledge and Performance in RP&C

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R RP Ananart Far raa'alamant Aarmy chack Valva inana*+1aa laanaa'taa Raaaa (71750)

The inspectors performed routine inspection of the RP support for the internal inspection of the 2A containment spray pump discharge check valve (2CS003A).

The inspectors also reviewed the associated radiation work permit g73011. This is ,

also discussed in Section M ' Ohmarvallana and Finreinna The inspectors observed that personnel performing the work adhered to the requirements of the radiation work permit and were careful when working near the contaminated area boundary. The RP technician closely watched the work in

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progress and monitored for elevated dose rates and loose surface contaminatio ' Conclusions Personnel performing the work demonstrctad good radiological work practices and the radiological protection technician did a good job of monitoring radiological condition S1 Conduct of Security and Safeguards Activities S1.1 P_rimary Alarrn R'a'InrLOparaint Annsated Tn Ra inattantium Tn Bnelma Inmaan'lon Scopa (71750)

The inspectors performed routine inspections of security stations and facilities on July 27; reviewed security procedures BwSP 100 2T5, " Security Control Center Operators," Revision 0 and BwSP 300 4," Security Control Center Duties,"

Revision 0; and interviewed two members of the security department managemen .-%,.. - , -. . _ _ _ . . . - - - . -o.-------m_..m.~...m...J i _ ..-,- ---.,_.._ -. _- . . . . . . - - _

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e Observatinas andfindings On July 27, during an Inspection of the Central Alarm Station, the inspectors observed that the operator had a newspaper laid out in front of him on the consol The inspectors asked several questions of the operator about the status of security equipment and ex' sting alarms. The alarm station operator appeared to be aware of the status of equipment and alarms. The inspectors spoke to two members of security department management and both stated that reading material in the alarm station did not meet management expectations for proper conduct of the alarm station operator. As a result, the operator was counseled and Instructions regarding unacceptance reading material were placed in the post order Conclusions l The primary alarm station operator appeared to be aware of the status of equipment

) and existing conditions but was not giving full attention to the duties assigned.

l F1 Control of Fire Protection Activities F1.1 Unattanded_Energlzad_Walding_ Machina larpactlartScope (71750)

The inspectors performed a routine inspection tour of the turbine building; reviewed BwAP 110015, " Fire Prevention When Welding, Cutting, Grinding or Performing Open Flame Work (Hot Work)," Revision 7; and interviewed the work center supervisor, Observations.andlindings On July 2, while performtr;g a routine inspection of the Unit 2 turbine building, the inspectors observed an unattended and energized welding machine located outside the 2A DG room. The inspectors could not locate any maintenance personnel in the area and reported the energized welding machine to the work center supervisor. The field supervisor was immediately dispatched to de-energize the welder, immediately following notification, the licensee conducted a tailgate meeting with all welders to discuss the finding of an unattended and energized welding machine. On July 7, the inspectors identified what appeared to be another unattended welding machine that was left energized. The inspectors informed the maintenance work director of the finding. On July 7, a stop work order was issued for all welding work and a taligate session was conducted with maintenance and contract welders. The licansee determined that the second welding machine had been properly deenerged at the 480 volt breake The inspectors found that the requirements of administrative procedure BwAP 110015, " Fire Prevention When Welding, Cutting, Grinding or Perferming Open Flame Work (Hot Work)," Revision 7, Steps E.6 and F.2.c.12, were not met in that

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the welding machine was found energlied and unattended. The failure to perform the required actions of procedure SWAP 110015 was an example of a violation (50-457/97013 02(DRP)) of TS 6.8.1.g for failure to follow procedur C. cantinalan The failure of maintenance personnel to follow procedures resulted in an unattended and energlued w91 ding machine. This condition introduced a potentially serious fire haastd,in that an lenition source was left without a fire watch present. The licensee's prompt corrective action consisting of turning off the welding machine was effective in elimination of the hazard. Additionally, the licensee's tailgate meetings appeared to addresa the root cause for the event and reinforced the seriousness of leaving a welding machine energized and unattende V. Managamane "- * .y -

X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on August 11,1997. The licensee acknowledged the findings pre inted. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie E

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PARTIAL UST OF PERSONS CONTACTED Licensaa H. G. Stanley, Site Vice President T. Tulon, Station Manager A. Haeger, Chemistry / Health Physics Supervisor R. Byers, Maintenance Superintendent M. Graham, Work Control Superintendent

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'R. Dralle, l&C Superintandent

'T. Simpkin, Regulatory Assurance Supervisor 'C Dunn, System Engineering Supervisor

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- 'J. Meister, Engineering Manager

'8. Wegner, Operations Manager

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'K. Bartesi Quality and Safety Assessment Manager i

'J. Lewand, Licensing Operations

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'M. Cassidy, Regulatory Assurance NRC Coordinator j 'C. Herzog, Equipment Attendant i NBC

i R. Lanksbury, Chief, Reactor Projects Branch 3

, 'C. Phillips, Senior Resident inspector 1 'J. Adams, Resident inspector

T. Tongue, Pro}ect Engineer IDMS

'T. Esper

• - Denotes those who attended the exit interview conducted on August 11,1997,

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INSPECTION PROCEDURES USED IP 61726: Surveillance Observations IP 62707: Maintenance Observation IP 71707: Plant Operations IP 71750: Plant Support Activities IP 92700: Onsite Followup of Written Reports of Nonroutine Events at Power Reactor Facilities IP 92901 Followup Operations IP 92902: Followup Plant Maintenance ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-456/97013-01 NCV failure to follow procedures 50-457/97013 02 VIO failure to follow hot work procedure Closed 50 456/96014 01 VIO incorrect procedure rev. used while performing monthly tett on 1B DG 50-456/96012 04 VIO preconditioning of DG SX valve 50-456/96021-02; 50-457/96021-02 VIO improper securing of carts 50 456/97013 01 NCV failure to follow procedures lliscussed 50-456/96018-01 VIO failure to have procedures / guidelines for bypassing CV 121

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LIST OF ACRONYMS USED '

o AR Action Request ASME American Society of Mechanical Engineers CC Component Cooling Water CFR Code of Federal Regulations DG Diesel Generator FME Foreign Material Exclusion gpm Gallons per Minute PLA Heightened Level of Awareness LCO Limiting Condition for Operation MSIV Main Steam isolation Valve NRC Nuclear Regulatory Commission NRR Nuclear Reactor Regulations NSO Nuclear Station Operator OOS Out of Service psid Founds Per Square inch Differential RCS Reactor Coolant System RHR Residual Heat Removal RP Radiation Protection RP&C Radiological Protection & Chemistry l SI Safety injection SX Essential Service Water Tave Reactor Coolant Average Temperature TPC Temporary Procedure Change TS Technical Specification UFSAR Updated Fitial Safety Analysis Report VIO Violation

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