IR 05000456/1998005
| ML20248D119 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 05/19/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20248D069 | List: |
| References | |
| 50-456-98-05, 50-456-98-5, 50-457-98-05, 50-457-98-5, NUDOCS 9806020323 | |
| Download: ML20248D119 (27) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION 111 Docket Nos: 50-456;50-457 License Nos: NPF-72; NPF-77 Report No: 50-456/98005(DRP); 50-457/98005(DRP)
Licensee: Commonwealth Edison Company Facility: Braidwood Nuclear Plant, Units 1 and 2 Location: RR #1, Box 84 Braceville,IL 60407 Dates: March 10 through April 20,1998 Inspectors: C. Phillips, Senior Resident inspector l J. Adams, Resident inspector 4 D. Pelton, Resident inspector T. Esper, Illinois Department of Nuclear Safety Approved by: M. Jordan, Chief Reactor Projects Branch 3
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EXECUTIVE SUMMARY Braidwood Nuclear Plant, Units 1 & 2
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NRC Inspection Report No. 50-456/98005(DRP); 50-457/98005(DRP)
This inspection included aspects of licensee operations, maintenance, engineering, and plant support. The report covers a six-week period of resident inspection from March 10 through April 20,199 Operations
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The inspectors concluded that operators did not follow the procedure to install the spent fuel pool (SFP) skimmer filter during a filter replacement which resulted in improper filter installation. The operators did not verify the proper installation of the filter. The filter failure resulted in a pump down of the SFP to a level of 424 feet 3 inches (about 3 inches). Operators subsequently secared the SFP skimmer system. The inspectors concluded that the licensee's root cause analysis idenufied and station management adequately addressed the problems that contributed to the spill. The licensee-identified and corrected failure to follow procedures was a non-cited violation. (Section 01.1)
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The inspectors concluded that operations management exhibited an excellent safety focus following the loss of power from two offsite power transmission lines during winter storm conditions. The control room staff was augmented and in anticipation of problems, the control room staff reviewed abnormal operating procedures for a loss of offsite power, a reactor trip, a problem with non-essential service water, and a loss of instrument ai (Section 01.2)
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The inspectors concluded that the reactivity manipulations performed during the power ascension portion of a special process procedure to collect vibration data on the Unit 1 main generator were properly performed and supervised. (Section 01.3)
- The inspectors concluded that the Unit 2 control room operators correctly and promptly responded to a rod control urgent failure alarm. The inspectors concluded that the shift manager appropriately evaluated the potential effects of the troubleshooting on the operation of the unit. The shift manager also ensured that the system engineer and maintenance personnel clearly understood the scope of the troubleshooting that was authorized in the work package. (Section 04.1)
Maintenance
- The inspectors concluded that the five surveillance tests observed this inspection period were performed well and the data taken met all established acceptance criterie. The test procedures were clearly written and ensured that if followed, Technical Specification (TS) requirernents would be met and Updated Final Safety Arealysis Report design c-iteria satisfied. (Section M1.1)
- The inspectors conduded that poor planning in preparation for work on the essential service water supply valve to the suction of the 18 auxiliary feedwater pump resulted in unnecessarily entering the TS limiting condition for operation for about 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and a delay in starting work on the valve. Electricians were unable to perform the scheduled 2 j i
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maintenance when they ar,ived at the work site due to structural interference. The 18 auxiliary feedwater pump was actually available for use during the four hour period so the safety impact was minimal. (Section M1.2)
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The inspectors concluded that the licensee exhibited an excellent safety focus during the replacement of the Unit 1 instrument air regulator for the heater drain pump discharge Valve 1 AOV-HD0468 actuator, by classifying the work as a high risk activity, by developing a high risk activity plan, and by briefing personnel on the associated risk The inspectors concluded that Work Package 980021779-01 was clearly written and contained the necessary instructions and drawings for the successful completion of the maintenance activity. (Section M1.4)
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The inspectors concluded that the installation of the line stop on the essentid service water supply line and the subsequent inspection and repair of tube leaks in the common component cooling water heat exchanger were planned well. Personnel involved with the maintenance activities were well-briefed on the allowed completion times for each activity, the requirements of the TS, including the limiting conditions for operations, and the contingency plans if problems arose. Licensee personnel properly placed and walked down the out-of-service, obtained and posted transient fire load permits, obtained and posted plant boundary impairments on impaired fire and watertight doors, followed work package instructions, and maintcined oversight and control of contractor personnel during the installation and removal of the line stop. (Section M1.5)
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The licensee identified the failure to properly perform density corrections to instrumentation that measured containment spray additive flow rate as part of Braidwood Technical Staff Surveillance Procedure 6.2.2.d-1, " Containment Spray Additive Flow Rate Wrification." This resulted in the mispositioning of the Unit 1 and Unit 2 containment spray additive tank throttle valves resulting in a spray additive flow rate of 78 gallons per minute (as measured by primary water flow) exceeding the TS limit of 74 gallons per minute (as measured by primary water flow) from about April 1991, for Unit 1 and November 1991, for Unit 2. A non-cited violation was issued. (Section M4.1)
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The inspectors concluded that the licensee made a temporary alteration to the spent fuel pool (SFP) skimmer strainer level controllers but did not perform a review and docurrent the alteration as required by Braidwood Administrative Procedure 2321-18T11,
" Determination of Temporary Alterations (TALTs)." The inspectors also concluded that the absence of a syphon break on the SFP skimmer retum line and the broken SFP skimmer suction piping precluded the licensee from satisfying the requirements of TS Condition 5.6.2 for prevention of the inadvertent draining of the SFP below the 423 foot elevation. Two violations, of which one had two examples, were issued. (Section E1.1)
- Licensee personnel incorrectly determined in 1995 that the use of a tri-nuclear filtration system inside the SFP did not constitute a temporary alteration (TALT). The inspectors concluded that when licensee personnel later determined in September 1997, the use of the tri-nuclear system was a TALT, the discrepancy was not entered into the corrective action system by using a problem identification form and no corrective actions were completed as of April 20,1998. A violation was issued. (Section E1.2)
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The inspectors reviewed four 10 CFR 50.59 safety evaluations and concluded that they adequately met regulatory and procedural requirements. The inspectors found minor errors in two safety evaluations that had no impact on the outcome of the evaluatio The inspectors concluded that the minor errors were due to a lack of attention to detail by the engineers. Attention to detailin engineering work was previously discussed as a problem in inspection Report No. 50-456/97016(DRP); 50-457/97016(DRP). The other two safety evaluations were comprehensive and well-written. (Section E2.1)
Plant Sucoort
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The inspectors concluded that three vehicle searches observed during the week of April 6 were performed in accordance with the applicable Braidwood Security procedures. No problems were observed. (Section S1.1)
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Report Details Summary of Plant Status Unit 1 and Unit 2 were at full power on March 10, and remained at or near iull power through April 2 . Operations 01 Conduct of Operations O1.1 Spent Fuel Pool (SFP) Skimmer Filter Spill Recover Inspection Scope (71707)
On February 13,1998, the SFP skimmer filter failed which resulted in a spill of 500 gallons of contaminated water into the auxiliary building Unit 1 curved wall area on Elevation 364. The inspectors interviewed the involved operators and operations management personne!. The inspectors reviewed the following documents:
. Problem identification Form (PlF) A1998-00593;
. Braidwood Operating Procedure (BwCP) WX-197, " Changing Liquid Radwaste Filters," Revision 8;
. Braidwood Administrative Procedure (BwAP) 100-20, " Procedure Use and Adherence," Revision 8; and
. Braidwood Station Root Cause investigation Report 456-200-98-CAQS00006 Observations and Findinas On February 13,1998, 500 gallons of contaminated water spilled into the Unit 1 auxiliary building curved wall area on Elevation 364. The spill occurred after operators replaced the SFP filter (OFC01F). After the old filter was removed from the filter housing, the operator noted that the filter housing remained partially filled with water. The operator did not clean the filter housing or examine the filter housing lower mating surfaces as l . required by BwOP WX-197, Steps 16 and 17. Corrosion products on the lower filter l seating surface inteifered with the proper fit of the filter. Neither the operator nor the j radweste supervisor checked the filter vault for leakage once the filter was replaced and l l put back in servic j The corrosion products caused the filter to be misaligned which resulted in an O-ring on the upper seal filter becoming separated from the filter body during installation. This provided a flow path for SFP water to bypass the filter outlet, collect in the filter vault and j eventually flow from the vault to an adjacent pipe chase. This pipe chase drained to the !
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auxiliary building floor drain system. Approximately 2,400 gallons of SFP water drained to the auxiliary building floor drain (WF) system. Approximately 500 gallons of SFP water bypassed the auxiliary building floor drain due to slow drainage and spilled into the Unit 1
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curved wall area. This spill resulted in a smearable contamination level of 2000 disintegrations per minute per 100 centimeters squared over a 500 square foot area. No personnel were contaminated as a result of this spill. The SFP level decreased approximately 3 inches to about 424 feet 3 inches. The SFP low level alarm actuated at 424 feet 5 inches and actions were taken to investigate the cause of the alarm and refill the SF The inspectors reviewed the licensee's root cause investigation report concoming this spill. The licensee's event description, nuclear safety analysis, root cause analysis, and actions taken to prevent recurrence appeared to adequately identify the problems that contributed to the spil Licensee management took the following corrective actions. BwOP WX-197 was changed to require the vacuuming of water out of the filter vault prior to replacing a filter and checking for leakage immediately after placing the filter back in service. The operating crews were trained with respect to immediately reviewing the actions taken during an evolution and after the completion of the evolution. Finally, the filter system drain line was unplugged to prevent water from accumulating in the vaul The failu e of the operator and the radwaste supervisor to follow BwOP WX-197 was an example of a violation of Technical Specification (TS) 6.8.1.s which requires that written procedures be established, implemented, and maintained. This non-repetitive, licensee-identified and corrected violation is being treated as a non-cited violation, consistent with Section Vll.B.1 of NRC Enforcement Policy (50-456/98005-01(DRP);
50 457/98005-01(DRP)). Additional followup inspection activities are documented in Section E.1.1 of this repor Conclusions The inspectors concluded that operators did not follow the procedure to install the SFP !
skimmer filter during a filter replacement which resulted in improper filter installation. The j operators did not verify the proper installation of the filter. The filter failure resulted in a '
pump down of the SFP to a level of 424 feet 3 inches (about 3 inches). Operators subsequently secured the SFP skimmer system. The inspectors concluded that the licensee's root cause analysis identified and station management adequately addressed the problems that contributed to the spill. The licensee's identified and corrected failure to follow procedures was a no& cited violatio .2 Operation Response to Off-Site Transmission Line Problems l a; Inspection Scope (71707)
The inspectors reviewed the operations department management actions taken following the loss of power from the LaSalle 0104 and the East Frankfort 2003 high voltage transmission lines during winter storm conditions. The inspectors also reviewed Braidwood TS 3.8. _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ - _ - - _ . __
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, Observations and Findinas On March 9,1998, LaSalle 0104 and the East Frankfort 2003 high voltage transmission lines had stopped providing power due to problems caused by a winter storm. The LaSalle line provided one of the three offsite attemating current sources to Unit 1. The East Frankfort line provided one of the three off-site altemating current sources to Unit The inspectors reviewed Braidwood TS 3.8.1.1, "Altemating Current Sources," and determined that the limiting conditions for operations were met. The inspectors also verified that the licensee followed Unit 1 Braidwood Operating Surveillance Procedure 8.1.1.1.A-1, " Unit 1 Normal and Offsite Altemating Current Power Availability Weekly," and 2BwOS 8.1.1.1.A-1, " Unit 2 Normal and Offsite Altemating Current Power Availability Weekly," to demonstrate the operability of the remaining offsite power sources.
l The inspectors noted that the operations department management augmented the control room staff to address the increased potential for storm induced plant transient Operations department personnel also conducted a heightened level of awareness briefing with the control room operators and reviewed abnormal operating procedures for the loss of offsite power, reactor trip, non-essential service water problems, and the loss of instrument ai Conclusions The inspectors concluded that operations management exhibited an excellent safety focus following the loss of power from two offsite power transmission lines during winter storm conditions. The control room staff was augmented and abnormal operating procedures for a loss of offsite power, reactor trip, non-essential service water problems, and a loss of instrument air were reviewed by control room operators in anticipation of future problem .3 Reactivity Manipulation Observations Durina Main Generator Vibration Reduction Testino Inspection Scope (71707)
l The inspectors observed activities involving the power ascension portion of Special l
Process Precedure (SPP)98-012, " Unit 1 Main Generator End-Tum Data Collection,"
Revision 0. The inspectors also reviewed BwOP CV-5, " Operation Of The Reactor Makeup System In The Dilute / Batch Dilution Mode," Revision 9, Section F; and Braidwood General Operating Procedure BWGP 100-3, " Power Ascension,"
Revision 13E1, Section F.6 Observations and Findinas On March 29, the inspectors observed the operators performing reactivity manipulations during the power ascension portion of SPP 98-012. The licensee initiated the SPP to determine if the Unit 1 main generator's vibrations could be reduced by increasing the st ic,r water cooling inlet temperature. The SPP directed operators to reduce turbine load from 100 percent to 90 percent, increase Mator water cooling inlet temperature to 116 degrees Fahrenheit while monitoring main generator vibrations, and retum turbine load to 100 percent while monitoring main generator vibrations. The inspectors noted I j
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that all reactivity manipulations were performed under the direct supervision of the unit supervisor. The inspectors observed nuclear station operators using three-way communications, proper operating procedures, place keeping techniques during the execution of those procedures, and self-checking techniques prior to the man:pulation of the chemical and volume control system or the rod control system controls. The inspectors observed control room indicators for the reactor coolant average temperature and the reference temperature and noted that operators maintained less than a 1 degree Fahrenheit temperature deviation between them during the entire power ascensio Conclusions 1 The inspectors concluded that the reactivity manipulations performed during the power '
ascension portion of a special process procedure to collect vibration data on the Unit 1 main generator were properly perform 6d and supervise Operator Knowledge and Performance
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O4.1 Control of Rod Control System Troubleshooting Insoection Scope (71707)
The inspectors observed control room personnel's response to a Unit 2 rod control system urgent failure alarm. The inspectors also observed the shift manager's control of the subsequent troubleshooting efforts by instrument maintenance personnel, Observations and Findinas On March 29, a control rod drive system urgent failure alarm was received. Upon receipt of the alarm, inspectors observed a nuclear station operator promptly acknowledge the alarm, announce the alarm to the unit supervisor, refer to the annunciator response procedure, and take the action specified by the annunciator response procedure. The operators isolated the problem to the cabinet for shutdown banks C, D, and E. The unit supervisor entered the 72-hour limiting condition for operation associated with TS 3.1.3.1.c. The inspectors reviewed TS 3.1.3.1.c and determined the unit supervisor entered the appropriate limiting condition for operatio The shift manager called in the syster.1 engineer, instrument maintenance personnel, and maintenance work planners to develop a work package and perform troubleshooting activities. The shift manager led a heightened level of awareness briefing to discuss the initial troubleshooting activities. During the briefing, the shift manager placed significant emphasis on the scope of the work package and the effect that associated activities could have on the operation of the unit. Prior to concluding the briefing, the shift manager ensured that all the personnel involved in the troubleshooting activities understood the i limited scope of the work package and that activities that were not specified in the work i l package were not to be performed. The inspectors observed the troubleshooting activities authorized by the work package and verified that all activities performed were within the scope of the work package. The data obtained from the troubleshooting was used by the system engineer to identify a problem with the failure detection card. Work )
! planners subsequently developed a work package for the failure detection card j
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, replacement. The card was replaced, the urgent failure alarm cleared, and the limiting I condition for operation was exited, Concicsions The inspectors concluded that the Unit 2 control room operators correctly and promptly responded to a rod control urgent failure alarm. The inspectors concluded that the shift manager appropriately evaluated the potential effects of the troubleshooting on the operation of the unit and ensured that the system engineer and maintenance personnel clearly understood the scope of the troubleshooting that was authorized in the work packag Operations Organization and Administration O6.1 Overtime Insoection Scope (71707)
The inspectors reviewed station overtime control. The inspectors reviewed Procedure BwAP 100-7, " Overtime Guidelines for Station Personnel," Revision The inspectors also interviewed administrative time keeping personne Observations and Findinas The inspectors verified that Procedure BwAP 100-7, if properly followed, would ensure compliance with TS 6.2.2.e. Responsibilities for station personnel with respect to working hour limitations were appropriately detailed in SWAP 100-7. Actual working hour limitat!ons were also adequately listed in the procedur The licensee maintains report forms to track overtime usage. The inspectors reviewed random samples of BwAP 100-7A1," Overtime Deviation Authorization Form." All forms reviewed were filled out appropriately and all required approval signatures were included on the form The inspectors reviewed the most recent semi-annual overtime report for the 6 months ending December 31,1997. All overtime deviations were listed in the report. The report also presented the number of deviations that received approval after the actual deviation occurred due to emergent work requirements. Less than 5 percent of the deviation approvals were after the fact. The inspectors also reviewed a random sample of time records for 20-station employees for the weeks beginning January 26 and February 2,1998, and found no problems. The 2 weeks chosen coincided with a forced unit outage of Braidwood Unit Conclusions Station procedures and programs provided appropriate instructions for the control of personnel working hours and compliance with TS 6.2. '
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11. Maintenance M1 Conduct of Maintenance M1.1 Surveillance Observations a, inspection Scope (61726)
The inspectors observed all or portions of the following surveillance tests:
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Braidwood Operating Surveillance Procedure 2BwOG 3.1.1-20, " Unit Two Solid State Protection System, Reactor Trip Breaker, and Reactor Trip Bypass Breaker Bi-Monthly (Staggered) Surveillance (Train A)";
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Braidwood Technical Staff Surveillance Procedure (BwVS) 2BwVS 5.2.f.2-1,
"American Society of Mechanical Engineers (ASME) Surveillance Requirements For The 2A Pump," Revision 5;
Special Process Procedure (SPP)98-002, "Braidwood Special Test Procedure ASME,Section XI,10-Year Pressure Test of Class 1 Components, Verification of Unit 1 Class 1 Safety injection (GI) System Pressures (High Pressure Injection to Cold legs)," Revision 0;
Special Process Procedure 98-003, "Braidwood Special Test Procedure ASME,Section XI,10-Year Pressure Test of Class 1 Comportents, Verification of Unit 1 Class 1 SI System Pressures (Sl to Hot legs)," Revision 0; and
+ Braidwood Technical Staff Surveillance Procedure 2BwVS 8.1.1.2.a-2, "2B Diesel Generator Operability Monthly (Staggered)," Revision 1 In addition, to the above documents the inspectors reviend the following:
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Technical Specifications 4.3.1.1 and 4.3.2.1;
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Updated Final Safety Analysis Report (UFSAR), Sections 7.1 and 7.2;
+ Braidwood Administrative Procedure 100-18, "Braidwood Station Independent Verification Procedure," Revision 3;
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Braidwood Administrative Procedure 350-1," Operating Logs And Records,"
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Revision 10; and
+ The Unit 2 nuclear station operators control room lo Qbjervations and Findinos The operators observed followed the surveillance test procedures as writte Communications between operators in the field and operators in the control room were good. Operators used three-way communications at all times. The pre-job briefs for these surveillance tests were satisfactory. All data taken fell within the required range of
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l the acceptance criteria specified in the surveillance tests. The surveillance test procedures were clearly written, met the testing requirements of the appropriate TS, and tested the design as described in the appropriate UFSAR sectio Conclusions The inspectors concluded that the five surveillance tests observed this inspection period were performed well and the data taken met all established acceptance criteria. The test procedures were clear 1y written and ensured that if followed, TS requirements would be met and UFSAR design criteria satisfie M1.2 Unit 1B Auxiliary Feedwater Pumo Essential Service Water Suction Valve Toraue Switch Trouble Shootina Inspection Scope (62707)
The inspectors reviewed Work Package 980005256 and BwAP 1600-1, " Action / Work Request Processing Procedure," Revision 35, and observed electricians attempt to start work, Observations and Findinos The inspectors found that due to poor planning, the work could not be performed and the Limiting Condition for Operation TS 3.7.1.2.b was entered unnecessarily for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The High Risk Activities Form (BwAP 1600-lT2) was improperly filled out and the Unit 1B auxiliary feedwater pump es'sential service water suction valve was inaccessible due to structuralinterference. Electricians were unable to access the valve to perform the scheduled maintenance when they arrived at the work site. The 1B auxiliary feedwater pump was actually available for use during the 4-hour period so the safety impact was minimal. Engineering support was needed to resolve the interferenc Conclusions The inspectors concluded that poor planning in preparation for work on the essential service water supply valve to the suction of the 18 auxiliary feedwater pump resulted in unnecessarily entering the TS limiting condition for operation for about 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and a delay in starting work on the valve. Electricians were unable to access the valve to perform the scheduled maintenance when they arrived at the work site. The 1B auxiliary feedwater pump was actually available for use during the 4-hour period so the safety impact was minima ;
i M1.3 Preventive Maintenance ' Inspection Scope (61726)
The inspectors reviewed the preventative maintenance program and associated report i
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, Observations and Findinos The inspectors reviewed reports for past due and past critical (past due plus 25 percent of maintenance frequency) pre-defined maintenance items. The report generated on April 6 showed that r a pre-defined maintenance items were past critical. Ninety-six items were presented as past due. This number of past due items has steadily decreased (from approximately 800 items) since 1996. During the month of March 1998, the pre-defined maintenance backlog was reduced by 60 items. The inspectors also checked the status of pre-defined maintenance items on the containment spray (CS) system. On April 6, no items were past due or past critica c, Conclusions Pre-defined maintenance jobs are being performed on schedule, resulting in a reduction in the backlo M1.4 Replacement of the instrument Air Reaulator on the Heater Drain Pumo Discharoe Valve 1 AOV-HD046B Actuator Inspection Scope (62707)
The inspectors attended the heightened level of awareness briefing, discussed the maintenance activity with the unit supervisor, and observed the replacement of an instrument air regulator on the Unit 1 heater drain pump discharge valve (1 AOV-HD046B)
actuator. The inspectors also reviewed Work Package 980021779-01 and BwAP 100-12,
" Human Performance Awareness of Pre-Job Briefings / Meetings and Self-Checking,"
Revision J Observations and Findinas Licensee personnel identified air leaking from the regulator diaphragm of the 18 heater drain pump discharge valve (1 AOV-HD046B) actuator. The licensee was concemed that further degradation in the regulator diaphragm could result in a secondary plant transient, and therefore designated the work as a high risk activity, developing an associated risk activity plan. The inspectors observed the replacement of the instrument air regulator and determined that operations and maintenance personnel performed all aspects of the maintenant a activity in accordance with the instructions in Work Package 980021779-01 with appropriate emphasis on the activity's high ris Conclusions The inspectors concluded that the licensee exhibited an excellent safety focus during the replacement of the Unit 1 instrument air regulator for the heater drain pump discharge valve 1 AOV-HD046B, by classifying the work as a high risk activity, by developing a high j risk activity plan, and by briefing personnel on the associated risks. The inspectors concluded that Work Package 980021779-01 was clearly written and contained the ,
necessary instructions and drawings for the successful completion of the maintenance i l activit l
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M1.5 Pluaaina of Tubes On the Unit O Common Component Coolina Water Heat Exchanger J Inspection Scope (62707)
The inspectors observed maintenance activities associated with installing a line stop in the essential service water supply line to the common component cooling water heat exchanger. This also involved locating and repairing tube leaks in the common j component cooling water heat exchanger. The inspectors reviewed the following:
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Work Package 960111968-01, " Install Stop Valve For Component Cooling Water Heat Exchanger isolation";
Work Package 940066353-01, " Suspect Tube Leak Of Approximately 100 Gallons Per Day";
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" Control of Heavy Loads," Revision 4;
- Nuclear Station Work Procedure A-03, " Foreign Material Exclusion," Revision 0;
- Braidwood Administrative Procedure 1100-10," Control and Use of Flammable
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and Combustible Liquids and Aerosols," Revision 0;
+ Braidwood Administrative Procedure 1100-11, " Fire Prevention For Use of Lumber and Other Combustibles," Revision 7;
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Braidwood Administrative Procedure 1110-3, " Plant Barrier impairment Program,"
Revision 6E1; and
+ Braidwood Administrative Procedure 380-3, " Control of Watertight Doors and Flood Seal Openings / Barriers," Revision The inspectors discussed the planning of the maintenance activities with the project manager, maintenance scheduler, and the involved system enginee j Observations and Findinas On April 2, the inspectors discussed the insertion of a line stop in the essential service water supply line to the common component cooling water heat exchanger and the location and plugging of leaking tubes in the common component cooling water heat !
exchanger with the project manager, maintenance schedulers, and the system enginee The inspectors reviewed the work packages and determined that they were consistent with the description of the work provided by the project manager and were complete. On April 9, upon commencement of the work, the inspectors verified that the out-of-service was property placed and observed mechanical maintenance personnel performing the pre-job walk down. The inspectors also verified entry into the limiting condition for operation for TS 3.7.3.c and 3.7.4. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . __ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
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The inspectors observed that the installation of the line stop was performed in accordance with Work Package 960111968-01 instructions including mechanical ,
maintenance personnel oversight and control of contractor personnel at all times. The inspectors observed that heavy loads were moved in accordance with Braidwood
- Maintenance Procedure 3300-024 " Control of Heavy Load Equipment," Revision 4; the placement of transient fire load permits for the diesel-driven hydraulic pump fuel oil, hydraulic fluid, and wood used for temporary support of line stop equipment, was in accordance with BwAP 1100-10 snd BwAP 1100-11; and plant boundary impairments for fire and watertight doors to the B train essential service water pump room were installed in accordance with BwAP 1110-3 and BwAP 380-3. The installation of the line stop was
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performed without complication or delay and was completed ahead of schedul The inspectors also verified (on several occasions) that foreign material exclusion -
controls had been installed, and observed that tube plugging criteria were me Conclusions The inspectors concluded that the installation of the line stop on the essential service water supply line to the common component cooling water heat exchanger and the subsequent inspection and repair of tube leaks in the common component cooling water heat exchanger, were planned well. Allowed completion times for each activity,
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applicable TS and limiting conditions for operation, and contingency plans were understood by personnel involved with the maintenance activities. Licensee personnel properly placed and walked down the out-of-service, obtained and posted transient fire load permits, obtair.ed and posted plant boundary impairments on impaired fire and watertight doors, followed work package instructions, and maintained oversight and control of contractor personnel during the installation and removal of the line stop.-
M4 Maintenance Staff Knowledge and Performance M4.1 Containment Sorav (CS) Additive Flow Rate Settina Exceeded TS Limits Insoection Scope (61726)
On March 21,1996, the licensee identified that BwVS 6.2.2.d-1, " Containment Spray Additive Flow Rate Verification " failed to incorporate a density adjustment for water flowing through a flow cell calibrated for a sodium hydroxide solution. The inspectors originally documented this event as Unresolved item 50-456/96008-04; 50-457/96008-0 Observations and Findinas On March 21,1996, licensee personnel identified that Braidwood Technical Staff Surveillance Procedure 6.2.2.d-1, " Containment Spray Additive Flow Rate Verification,"
failed to incorporate a density adjustment for water flowing through a flow cell calibrated for a sodium hydroxide solution. This resulted in the mispositioning of the Unit 1 and Unit 2 CS additive tank throttle valves. The mispositioning resulted in a spray additive flow rate of 78 gal;ons per minute (as measured by primary water flow) exceeding the TS 4.6.2.2.d limit of 68 +6/-0 gallons per minute (as measured by primary water flow) from about April 1991 for Unit 1 and November 1991 for Unit 2. The engineering I
evaluation and safety consequence of this problem are discussed in Paragraph E8.5 of
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this report. The licensee changed BwVS 6.2.2.d-1 to include a density compensation for the use of primary water instead of sodium hydroxide and re-performed the test. The failure to properly position spray additive throttle valves for a spray additive flow rate of 68 +6/-0 gallons per minute is a violation of TS 4.6.2.2.d. The licensee determined that the root cause for not density compensating the containment spray additive flow rate was due to an inadequate procedure. The licensee corrected the procedure. This non-repetitive, licensee-identified and corrected violation is being treated as a non-cited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-456/98005-02(DRP); 50-457/98005 02(DRP)). See Section E8.5 for the followup and closure of Unresolved item 50-456/%008-04(DRP); 50-457/96008-0 Conclusions The inspectors concluded that the licensee failed to proper 1y perform density corrections of the spray additive flow rate as part of BwVS 6.2.2.d-1, "CS Additive Flow Rate Verification." This resulted in the mispositioning of the Unit 1 and Unit 2 CS additive tank throttle valves resulting in a spray additive flow rate of 78 gallons per minute (primary water flow) exceeding the TS limit of 74 gallons per minute (primary water flow) from about April 1991 for Unit 1 and November 1991 for Unit 2. A non-cited violation was issue M8 Miscellaneous Maintenance issues (92902)
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M8.1 (Closed) Violation 50 456/97002-01(DRP): 50-457/97002-01(DRP_l: Fai!ure to follow corrective actions specified in Licensee Event Report 50-456/96001-00. Licensee personnel did not control staging of materials on site roofs in order to prevent items from blowing off the roof. In response to the violation, licensee personnel performed daily unannounced inspections of roofs where work was ongoing. Meetings between licensee personnel and the contractor performing the re-roofing were held and requirements for control of materials were presented. The inspectors routinely monitored conditions of roofs, both during re-roofing activities and after completion of these activities. No additional problems with control of materials on the roofs have been identified by the inspectors. The inspectors had no additional concems. This item is close .
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E1 Conduct of Engineering E Spent Fuel Pool (SFP) Skimmer Desian and Modification l I Inspection Scope (37551)
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The inspectors performed a follow-up inspection of the SFP skimmer system and of a l licensee investigation into a repor1 of a spill which resulted from the improper installation
! of SFP Skimmer Filter OFC01F (Section 01.1) by walking down the fuel pool cooling system, interviewing the system engineer, and reviewing the following documents: i
+ Braidwood Design Drawing 583F015, "SFP Cooling System Skimmer Strainer Assembly Adjustable Mechanism," Revision 3;
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Braidwood Design Drawing 583F016," Spent Cooling Pool Assembly Skimmer
. Strainer Assembly Skimmer Head and Hose Assembly," Revision 3;
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Braidwood Design Drawing 583F017, "SFP Cooling System Skimmer Strainer Assembly Arrangement and Installation Assembly," Revision 3;
Braidwood Administrative Procedure 2321-18," Temporary Alterations,"
Revision 3E1;
- Braidwood Administrative Procedure 2321-18T11, " Determination of Temporary Alterations (TALTs)," Revision 3E1; I
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Problem Identification Form A1998-00854;
- Problem Identification Form A1998-01020;
- Operability Determination 98-021;
Technical Specification 5.6.2; and
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Updated Final Safety Analysis Report Chapter 9. Observations and Findinas On March 3,1998, the inspectors performed a followup inspection of the SFP skimmer suction strainers to determine the maximum amount that the SFP level could have been lowered as a result of the improperty installed SFP skimmer filter had no operator action been take The inspectors observed that the SFP had two skimmer suction strainers and that the strainers were attached to the side of the SFP using rope. The strainers were connected to the SFP skimmer system via hoses approximately eight feet long connected to a suction pipe which entered the SFP approximately one foot below the surface of the wate The original design of the SFP skimmer strainers utilized tee-handled adjustment assemblies attached to the side of the SFP which allowed the strainers to be positioned from the surface of the water in the SFP to approximately 22 inches below the surface of ,
the SFP. In 1992, set screws used to hold the strainers in the desired position became )
stripped with use and would no longer hold the strainer in position. The licensee
- disconnected the strainers from the tee-handle and tied the suction strainers to the side of the SFP using a rope to maintain the desired positio Braidwood Administrative Procedure (BwAP) 2321-18T11, Step C.1, defined a TALT as a change to the fit, form, or function of any operable system, structure, component, or circuit that does not conform to approved drawings or other approved design document BwAP 2321-18T11, Step E.1, required that if a system or component was retumed to service with a temporary change installed then the temporary change must be converted to a temporary alteration. Braidwood Design Drawing 583F017 indicated that the original design of the SFP skimmer strainers consisted of tee-handled adjustment assemb;ies
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attached to the side of the SFP to position the strainers within the SFP. The use of the rope to position the strainer suctions met the definition of a TALT in accordance with BwAP 2321-18T11 and licensee personnel did not apply the administrative controls required by BwAP 2321-18T11 to the change in the way the SFP suction strainer height was controlle The failure of the licensee to treat the temporary change made to the SFP skimmer i strainers as a TALT in accordance with BwAP 2321-18T11 is an example of a violation j (50-456/98005-03(DRP); 50-457/98005-03(DRP)) of TS 6.8.1 which requires that written .
procedures be established, implemented, and maintained covering activities listed in l
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Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978. Section 9.e of Regulatory Guide 1.33 recommends that general procedures be developed to control modification wor The inspectors noted that the SFP skimmer retum line entered the SFP about one foot below the surface of the SFP and made a ninety degree downward tum for approximately 5 feet. The inspectors verified that there was no syphon breaker in this retum lin Technical Specification 5.6.2 stated that the spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation 423 feet
- 0 inches. The inspectors determined that with no syphon breaker on the SFP skimmer retum line, the SFP could be inadvertently drained to approximately 418.5 fee The inspectors reviewed Problem Identification Form (PlF) A1998-1020 which reported that on March 17,1998, a SFP skimmer strainer hose was found broken. The broken hose was identified by licensee personnel while investigating problems noted with the attachment of the skimmer suction strainers. The hose was 95 percent detached from the SFt2skimmer suction line at approximately the 420 foot level. Since the break was approximately 3 feet below the location where the suction pipe enters the pool, the inspectors determined that this could have resulted in an inadvertent draining of the SFP to approximately 420 fee The failure of the licensee to include a syphon breaker in the design of the SFP skimmer retum line (50-456/98005-44a(DRP); 50 457/98005-04b(DRP)) and the failure to adequately maintain the SFP configuration such that it could not be drained belcw 423 feet (50-456/98005-44a(DRP); 50-457/98005-04b(DRP)) are examples of a violation of TS 5.6.2 which states that the spent fuel storage poolis designed and shall be maintained to prevent inadvertent draining of the pool below elevation 423 feet 0 inche Conclusions The inspectors concluded that the licensee made a TALT to the SFP skimmer strainers
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but did not perform a review nor document the alteration as required by BwAP-2321-l 18T11. The inspectors also concluded that the absence of a syphon breaker on the SFP
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skimmer retum line and the broken SFP skimmer suction hose precluded the licensee from satisfying the requirements of TS condition 5.6.2 for the prevention of the inadvertent draining of the SFP below the 423 foot elevation. Two violations were issue !
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E Use of Tri-Nuclear Underwater Filtration System Inspection Scope (37551)
The inspectors performed an inspection of the use and placement of tri-nuclear underwater filtration systems located within the SFP. The inspectors walked down the SFP and interviewed site engineers and the fuel handling system engineer and reviewed the following documents:
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Engineering Request ER9703068, "Use of Tri-Nuclear Filter Pumps inside SFP";
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Braidwood Administrative Procedure 370-3, " Administrative Control During Refueling," Revision 18;
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Braic' wood Fire Protection Procedure FH-31, " Fuel Handling Foreign Material Exclusion Area Requirements," Revision 5;
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Braidwood Administrative Procedure 2321-18, " TALTs," Revision 3E1;
Braidwood Administrative Procedure 2321-18T11," Determination of TALTs,"
Revision 3E1;
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Nuclear Station Work Procedure A-15, " Commonwealth Edison Nuclear Division integrated Reporting program," Revision 1; and
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Updated Final Safety Analysis Report, Chapter 9. Observations and Findinas The inspectors noted that there were two 600 gallon per minute (gpm) and one 260 gpm tri-nuclear filters located directly on top of empty spent fuel racks within the SFP. These filters were used primarily to supplement the SFP skimmer filters in maintaining the optical clarity of the SFP water surface during refueling operations. The 600 gpm filters weighed approximately 450 pounds each and the 260 gpm filter weighed approximately 250 pounds. The filters were approximately 84 inches tall and were attached to the side of the SFP using stainless steel chains and "C" clamps. Tri-nuclear filters have been located within the SFP continuously since 1996, although the filters have been used periodically during refueling operations by the licensee since initial start-u On October 4,1995, the licensee evaluated the use of the tri-nuclear filters within the
- SFP and determined that their use did not constitute a TALT in accordance with BwAP 2321-18. Licensee personnel later ra-evaluated the use of the tri-nuclear filters and concluded that their use in the SFP met the definition of a TALT. This was communicated in a memorandum from a Commonwealth Edison Nuclear Fuel Services engineer to Braidwood system engineering management on September 12,1997. The memorandum recommended that a TALT evaluation be completed for the tri-nuclear filters or that a procedure be approved to control their use and that a PlF be writte _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - . _ _ ]
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t On March 30,1998, the inspectors determined that the licensee had neither evaluated the use of the t? nuclear filters within the SFP as a TALT nor had issued a PIF. The inspectors did, however, note that the licensee had a procedure to control the use of the tri-nuclear filters in development but that it had not yet been approve The failure of the licensee to document and take prompt corrective actions addressing the need to evaluate the use of the tri-nuclear filters as a TALT is an example of a violation (50-456/98005-05(DRP); 50-457/98005-05(DRP)) of 10 CFR Part 50, Appendix B, Criterion XVI, which requires the licensee to establish measures to ensure that conditions ;
adverse to quality be promptly identified and correcte J l Conclusions I Licensee personnel incorrectly determined in 1995 that the use of a tri-nuclear filtration
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system inside the SFP did not constitute a TALT. The inspectors concluded that when J
licensee personnellater determined in September 1997, that the use of the tri-nuclear system was a TALT, the discrepancy was not entered into the corrective action system by using a PlF and no corrective actions were completed as of April 20,1998. One violation was issue E2 Engineering Support of Facilities and Equipment E2.1 Review of 10 CFR 50.59 Evaluations Inspection Scope (37551)
The inspectors reviewed safety evaluation BRW-SE-1997-1784, regarding the use of freeze plugs in the SFP skimmer system to repair valves in the filter suction and discharge lines; BRW-SE-1998-33, regarding the use of line stop equipment to isolate essential service water to the O component cooling water heat exchanger for maintenance; and BRW-SE-1998-175 and BRW-SE-1998-176, pertaining to two special surveillance test procedures for the Unit 1 St. The inspectors also reviewed Nuclear <
Station Work Procedure A-04, "10 CFR 50.59 Safety Evaluation Process," Revision ) Observations and Findinas The inspectors identified that BRW-SE-1997-1784 had minor errors. The safety evaluation form required the listing of all applicable TSs. The form did not list TS 5. which requires that the fuel pool be designed and maintained to prevent inadvertent draining below 423 feet. The evaluation stated that in case of a failure of the freeze plug, water would not drain below the minimum TS level. The lowest skimmer system discharge line entered the pool at 423 feet 7.5 inches. The line drops into the pool about 4 to 5 feet and was not equipped with a syphon breaker. Therefore, the failure of the freeze seal would not maintain fuel pool level above the minimum TS level. The inspectors determined that this error was minor and did not actually affect the outcome of
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the evaluation. Section 9.1.3.3 of the UFSAR describes a drain-down of the pool to a l level well below that of the skimmer discharge line. Therefore, the inspectors did not find any safety consequence to the erro l l
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.i The inspectors also noted that safety evaluation BRW-SE-1998-176 for Special Plant i Procedure (SPP) 98003, did not list TS 3/4.6.3, " Containment Isolation Valves," as having been reviewed to determine if a TS revision or other license amendment would be required to support the performance of SPP 98-003. Based on discussions with site engineering personnel, review of the TS, and review of the UFSAR, the inspectors determined that this problem did not change the licensee's conclusions documented in 4 the safety analysi The inspectors found no problems during the review of BRW-SE-1988-33 or BRW-SE-1998-175.' The safety evaluations were comprehensive and well-writte Conclusions The inspectors reviewed four 10 CFR 50.59 safety evaluations and concluded that they
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adequately met regulatory and procedural requirements. The inspectors found oversights in two safety evaluations that had no impact on the outcome of the evaluation. The inspectors concluded that the oversights were due to a lack of attention to detail by the l engineers. Attention to detail in engineering work was previously discussed as a problem l in inspection Report No. 50-456/97016(DRP); 50-457/97016(DRP). The other two safety evaluations were comprehensive and well-written.
j E8 Miscellaneous Engineering issues (92902)
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E. (Closed) Violation 50-456/96006-01afDRS): Problem identification forms were not t promptly initiated on February 16 and 17,1996, for problems identified during l replacement of the condensate pump 1CD05PB impeller. These included wrong impeller dimensions and damaged motor bearings.
f To address this concem, the licensee initiated the PlFs on February 29,1996, to identify ;
and correct the impeller and bearing issues. A PIF was also initiated to document the i
. failure to promptly initiate PlFs upon discovery of a nonconformance. The individuals l invcived were counseled. This part of the violation is close ;
(Closed) Violation 50-456/96006-01b(DRS): 50-457/96006-01b(DRS): As of !
February 28,1996, numerous rework PlFs were signed by a maintenance individual as j the "immediate supervisor" without having management signature authority. The
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individual was counaled on this issue and subsequent PIFs initiated on rework were approved by individuals with proper authority. This part of the violation is considered close (Closed) Violation 50-456/96006-01cfDRS): 50-457/96006 01c(DRS): As of March 1,1996, as required by BwAP 1400-2, "Predefine Parameter Change Procedure,"
the licensee did not complete BwAP 1400-2TI forms for all 400 overdue preventative maintenance tasks nor was the licensee able to provide engineering justification for the deferrals. As part of the corrective action, the licensee determined that personnel were
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not following BwAP 1400-2 because they were not familiar with the procedure form that is j to be completed when deferrals are made. The 'icensee developed a comprehensive I plan to ensure that appropriate actions were then, including engineering evaluations, to adequately address preventative maintenance activities when deferrals are mad Appropriate training was given on procedure BwAP 1400-2 requirements. The inspectors l
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noted that on April 7,1998, there were no past critical preventive maintenance activitie This part of the violation is considered close i (Open) Violation 50-456/96006-01d(DRS): 50 457/98006-01d(DRS): During the week of February 12,1996, several examples were identified where work had been either completed or canceled, but the deficiency tags associated with action requests had not been removed. The licensee attributed the tagging deficiencies to insufficient training and awareness as well as problems with deficiency tags being hung in the wrong location. Corrective steps taken included removing deficiency tags which were no longer valid and performing an audit of deficiency tags that are hanging in the field to verify that they have existing action requests or work requests in the electronic work control syste l
.On April 9,1998, the inspectors conducted a field inspection to verify that action ra quest
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tags were not inappropriately hanging on equipment. Out of 22 tags examined, two-tag numbers were omitted in the electronic work control system; however, the associated work requests were included in the electronic work control system for these two tags, in addition, the inspectors interviewed a quality and safety assessment inspector and an l
independent safety engineering group engineer. On April 8,1998, the quality and safety assessment inspector sampled 28-action request tags in the plant and identified that, for five hanging tags, work was either canceled or completed, but the tags had not been removed. Based on the inspectors' and quality and safety assessment inspector's recent findings, this part of the violation remains open pending more effective licensee corrective actions to address the tagging deficiencie E (Closed) Violation 50 456/97012-04(DRS): Unit 1 refueling water storage tank (RWST)
heater had not been mounted to the RWST tunnel floor in accordance with design
drawings. On July 22,1997, the NRC identified that since initial plant construction, the Unit i RWST heater had not been mounted to the RWST tunnel floor in accordance with design drawings. As a result, the probability of a seismic event challenging the integrity of the Unit 1 RWST heating system and draining the RWST was increase To address this concem, the licensee investigated the reason for the RWST heater not being proper 1y mounted and identified that the engineering change notice, ECN36722, dated June 10,1987, had not been implemented during plant construction to properly mount the Unit 1 RWST heater. Problem Identification Form A1997-03101 was issued on July 22,1997, to document this concem. The licensee also performed operability determination 97-058 dated July 24,1997, and Engineering Request (ER)9701952 dated December 5,1997, to determine equipment operability and demonstrate the piping integrity with the heater unbolted. The calculations concluded that the structural integrity of the heater, connected piping, and supports which were required to be seismically qualified, remained within design or operability limits for operating and faulted loading j conditions. The inspectors reviewed the design change and operability determination The inspectors questioned whether there could be other similar design changes that had not been implemented in the field. The licensee informed the inspectors that increased emphasis was provided to engineering, operations, and maintenance personnel to identify ,
any deviations from design drawings during plant walkdowns mainly in areas that are not readily accessible. On September 19,1997, the licensee bolted the RWST heater to the floor as required by the design drawings using WR970079774. This item is close i
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E8.3 (Closed) Violation 50457/97012-05(DRS): Licensee system engineer failec' to promptly inform the shift engineer when a problem regarding the 2A Safety injection (SI) pump lube oil filter inlet pressure was identified. On August 4,1997, the licensee performed Operability Assessment 97-096 and confirmed that the 2A SI pump was operable and capable of performing its design function during a design basis accident with the higher oil pressure condition. Licensee corrective actions included: re-emphasizing the requirements of the PIF procedure at an engineering department all hands meeting, counseling of the system engineer who failed to notify the shift of his concem in a timely manner, and repairing the malfunctioning relief valve which caused the higher oil pressure condition during Refueling Outage A2RO The inspectors detennined that the licensee's corrective actions addressed the system e..gineer's failure to promptly inform the shift engineer when an operability related issue was identified. This violation is close E Wosed) Unresolved item 50-456/96008-04(DRP): 50-457/96008-04(DRP): On March 21,1996, the licensee identified that BwVS 6.2.2.d-1 " Containment Spray Additive Flow Rate Verification," failed to incorporate a density adjustment for water flowing '
through a low cell calibrated for a sodium hydroxide solution. During the design basis reconstitution of the containment spray system and the spray additive systern, the licensee identified that the UFSAR description was incorrect and contained conflicting information. The licensee also determined proper flow settings for spray additive flow and eductor motive flow. The licensee made changes to the UFSAR to remove incorrect and/or conflicting information and changed the TS surveillance test procedures to reflect the proper spray additive tank level, spray additive flow rate, and eductor motive flow rat The inspectors observed the performance of BwVS 6.2.2.d-1 and verified that all acceptance criteria and TS and UFSAR requirements were me The licensee determined that during the early segment of the injection phase of a CS actuation, the pH of the spray additive solution injected into the containment atmosphere could sxceed the environmental qualification pH limits of certain equipment inside the containment for about 31 minutes. The licensee performed an operability determination and an evaluation of equipment environmental qualification at increased pH and concluded that there would be no negative effect. An analysis performed by the NRC staff also arrived at a similar conclusion. A non-cited violation was issued in this inspection report (see Section M4.1) for exceeding the TS limit for spray additive flo This item is close IV. Plant Support R8 Miscellaneous RP8,C Activities (97904)
R (Closed) Violation 50-457/97002-02a(DRP): Failure to follow contamination control procedures. A green hose was used in a radiologically posted area located in the Unit 2 turbine building and crossed the posted contaminated area boundary with no steps taken to prevent contamination of the clean area, as required by plant procedures. In response to the violation, the licensee provided training to operations and radiation protection personnel on the requirements for hose usage in radiologically posted area Additionally, the licensee revised the " Change Area / Step Off Pad Setup / Removal
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i Checklist" to check for any hoses that would cross the boundary or are prohibited in the area. The inspector reviewed the checklist and Radiation Protection Policy Memo #CCP-13, "Use of the Step Off Pad / Change Area Log Sheet and Checklist," and verified steps added adequately checked for items crossing the boundary. Additionally, the inspectors had routinely monitored radiologically posted areas for similar problems and had not identified any additional occurrences. The inspectors have no additional concems. This item is close R8.2 (Closed) Violation 50-457/97002-02b(DRP): Failure to follow procedures used for control of radiation protection instrumentation. An out-of-calibration radiation detector i was found stationed in the plant at a radiologically posted area. The detector was not l
segregated in order to prevent use, as required by plant procedures. In response to the ;
violation, the licensee revised processes used for signing out radiation protection I instrumentation to simplify methods. The licensee also developed a " Change Area / Step Off Pad Setup / Removal Checklist" to standardize radiologically protected area setup and removal activities. The inspectors reviewed the checklist and verified its us Additionally, the inspectors had routinely checked radiation protection instrumentation calibration and have not identified any additionalinstruments out-of-calibration. The ,
inspectors have no additional concerns. This item is close !
S1 Conduct of Security and Safeguards Activities j S Vehicle Search Inspection Scope (71750)
The inspectors observed the licensee's security personnel perform vehicle searches of three vehicles entering the protected area. The inspectors reviewed the applicable section of Braidwood Security Procedure 09, " Vehicle Entry / Exit Procedure," Revision Observations and Findinos During the week of April 6, the inspectors monitored the performance of three vehicle entry searches. All required areas of the vehicles were searched including the engine, passenger compartment, cargo compartment, and the undercarriage. No prohibited items were discovered, and no problems were noted by the inspectors. The inspectors monitored security personnel's control of the vehicle drivers and the main gates during the vehicle searches and noted that both were controlled in accordance with the applicable section of Braidwood Security Procedure 0 Conclusions The inspectors concluded that three vehicle searches observed during the week of ;
April 6, were performed in accordance with the applicable section of Braidwood Security Procedure 09. No problems were observe ,
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V. Manaaement Meetinas l
X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on April 20,1998. The licensee acknowledged the findings presented. However, the licensee took issue with the inspection characterization of the problems with the SFP skimmer design, as a violation (discussed in Paragraph E1.1). The licensee's view was that the basis for TS 5.6.2 related to the height of the anti-siphon device on the discharge of the SFP cooling system and had nothing to do with the SFP skimmer system. Licensee i management stated that the TS needed to be clarified, but that there was nothing wrong with the design of the SFP skimmer system and, therefore, a violation should not be issued. The licensee agreed that the current design of the SFP cooling system did not meet the requirements of i TS 5. The inspectors asked the licensee whether any matenals examined during the inspection should j be considered proprietary. No proprietary information was identifie l l
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PARTIAL LIST OF PERSONS CONTACTED Licensee T. Tulon, Site Vice President K. Schwartz, Station Manager
- R. Wegner, Operations Manager
- R. Byers, Maintenance Superintendent A. Haeger, Health Physics and Chemistry Supervisor R. Graham, Work Control Superintendent
- T. Simpkin, Regulatory Assurance Supervisor
- C. Dunn, System Engineering Supervisor
- J. Nalewajka, Assessment Supervisor
- B. Boyle, Fire Marshall
- J. Meister, Engineering Manager
- M. Riegel, Quality and Site Assessment Manager j
- L. Weber, Shift Operations Supervisor 1
- J. Browning, Unit Supervisor i
- M. Di Ponzio, Regulatory Performance Administrator
- S. Butler, Assessor i
- G. Norvil, Assessor
- M. Cassidy, Regulatory Assurance - NRC Coordinator NRC
- M. Jordan, Chief, Reactor Projects Branch 3
- C. Phillips, Senior Resident Inspector J. Adams, Resident inspector D Pelton, Resident inspector IDNS T. Esper
- Denotes those who attended the exit interview conducted on April 20,199 I l
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INSPECTION PROCEDURES USED IP 37551: Onsite Engineering
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IP 61726: Surveillance Observations l lP 62707: Maintenance Observation l IP 71707: Plant Operations
- IP 71750
- Plant Support Activities IP 92902: Followup - Plant Maintenance l IP 92903: Followup - Engineering IP 92904: Followup - Plant Support ,
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ITEMS OPENED, CLOSED, AND DISCUSSED
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Opened
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50-456/98005-01; 50-457/98005 -01 NCV failure to follow procedures 50-456/98005-02; 50-457/98005-02 NCV failure to maintain procedures 50-456/98005-03; 50-457/98005-03 VIO failure to maintain procedures l 50-456/98005-04; 50-457/98005-04 VIO failure to maintain skimmer suction hose ;
50-456/98005-05; 50-457/98005-05 VIO failure to take corrective actions
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Closed 50-456/96006-01a VIO l
50-456/96006-01b; 50-457/96006-01b VIO 50-456/96006-01c; 50-457/96006-01c VIO 50-456/96008-04; 50-457/96008-04 URI 50-456/97002-01; 50-457/97002-01 VIO
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50-457/97002-02a VIO 50-457/97002-02b VIO i
50-456/97012-04 VIO 50-457/97012-05 VIO 50-456/98005-01; 50-457/98005-01 NCV 50-456/98005-02; 50-457/98005-02 NCV Discussed 50-456/96006-01d; 50-457/96006-01d VIO
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LIST OF ACRONYMS USED ASME American Society of Mechanical Engineers BwAP Braidwood Administrative Procedure BwOP Braidwood Operating Procedure BwOS Braidwood Operating Surveillance BwVS Braidwood Technical Staff Surveillance Procedure CFR Code of Federal Regulations CS Containment Spray gpm Gallons per Minute NRC Nuclear Regulatory Commission NRR Nuclear Reactor Regulations PlF Problem identification Form RP&C Radiological Protection & Chemistry RWST Refueling Water Storage Tank SFP Spent Fuel Pool SI Safety injection SPP Special Process Procedure TALT Temporary Alteration TS Technical Specification UFSAR Updated Final Safety Analysis Report VIO Violation-1 l
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