IR 05000456/1998009

Insp Repts 50-456/98-09 & 50-457/98-09 on 980609-0727. Violations Noted.Major Areas Inspected:Licensee Operations, Maint,Engineering & Plant Support

ML20237F235
Person / Time
Site:	Braidwood
Issue date:	08/25/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20237F234	List: IR 05000456/1998009 ML20237F233
References
50-456-98-09, 50-456-98-9, 50-457-98-09, 50-457-98-9, NUDOCS 9809020146
Download: ML20237F235 (24)

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U.S. NUCLEAR REGULATORY COMMISSION REGIONlli Docket Nos: 50-456, 50-457 License Nos: NPF-72, NPF-77  !

Report No: 50-456/98000(DRP); 50-457/98009(DRP)

Licensee: Commonwealth Edison Company -

Facility: Braidwood Nuclear Plant, Units 1 and 2 Location: RR #1, Box 84 Braceville,IL 60407 Dates: June 9 tL.ough July 27,- 1998 Inspectors: C. Phillips, Senior Resident inspector J. Adams, Resident inspector D. Pelton, Resident inspector P. Lougheed, Reactor Engineer D. Chyu, Reactor Engineer 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 Braidwood inspection Report 50-456/98009(DRP); 50-457/98009(DRP)

l This inspection included aspects of licensee operations, maintenance, engineering, and plant support. The report covers a 7-week period of resident inspection from June 9 through July 27, 1998.

L Operations

• The inspectors concluded that a loss of control room command and control occurred for 42 seconds when there were no individuals in the control room who held a senior reactor operators license; a condition prohibited by TS 6.2.2.b. This issue, which may represent a violation of NRC requirements, will remain open pending receipt and analysis of the LER required to be submitted to the NRC per 10 CFR 50.73. The inspectors concluded, with the exception of the event discussed above, that the shift managers, unit supervisors, and nuclear station operators exercised good control room conduct, based on observations of shift tumover briefings, pre-job briefings, control board operations, .

control of evolutions, response to alarms, communications, direction of personnel, and control of work evolutions. (Section 01.1)

The inspectors concluded that the retum-to-service of the Unit 2 system Auxiliary Transformer 242-2 was planned and executed well. Operations personnel condurded a thorough heightened level of awareness briefing, operated control room and switchyard equipment safely, and followed applicable procedures. (Section 01.2)

The inspectors concluded that plant personnel were knowledgeable of fuel handling and fuel inspection msponsibilities and procedures. Fuel handling personnel demonstrated they were knowledgeable in the use of fuel handling equipment during recent receipts of new fuel. ' Fuel handling personnel followed procedures, implemented proper foreign material exclusion controls, and proper 1y maintained required documentation and status boards. (Section 01.3)

The inspectors concluded that compensatory actions required for the impairment of the

"B" essential service water flood door were poorly communicated between operations department management, the fire watch supervision, and fire watch personnel. The inspectors also determined that there were no post orders or written instructions concoming how to perform flood watch duties. The inspectors concluded that, in this case, the actions taken by fire watch personnel to check the position of the essential service water pump room flood door on an houriy basis without entering the room did constitute a satisfactory flood watch. (Section O2.1)

Maintenance

• The inspectors observed all or portions of various maintenance activities and concluded that activities were performed in accordance with the applicable procedures, that the procedures provided the requisite information necessary to perform the work, that

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maintenance personnel demonstrated good general work practices, and that maintenance personnel were knowledgeable of the associated limiting condition for operations and high-risk work activity requirements. (Section M1.1)

The inspectors observed the performance of five surveillance tests. The inspectors concluded that the surveillance tests adequately tested the system, the operators followed the procedures, and that the procedures included the required testing discussed in the Technical Specifications. (Section M1.2)

The inspectors concluded that the licensee has made improvement in outr Je work package preparation and outage schedule development for the upcoming Jnit 1 steam generator replacement and Refueling Outage A1R07. The inspectors concluded that the improvement is due to increased visibility of the outage planning process, improved communications, and the use of project teams. (Section M1.3)

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The inspectors concluded that the operability determinations regarding the Unit 1 safety

. injection pump minimum flow requirements, integrated leak rate testing piping lines, and Unit 2 intermediate range instrument electronic noise reflected good engineering judgement and safety focus. The inspectors also concluded that the necessary compensatory actions were well understood by operations personnel and that corrective actions were neing tracked by system engineering personnel. (Section E1.1)

• The inspectors concluded that the licensee properly performed the 10 CFR 50.59 safety evaluations for the isolation of the demineralized water makeup system to the diesel generator jacket water standpipes, the installation of temporary Alteration 98-1-010, and the removal of Unit 1'and 2 reactor containment fan cooler inlet and outlet dew point temperature indication. The inspectors concluded that the licensee's justifications were

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technically correct and made reference to applicable sections of the Updated Final Safety Analysis Report, Technical Specifications, American Society of Mechanical Engineers Boiler and Pressure Vessel Code, and Nuclear Regulatory Commission Regulatory Guides. (Section E1.2)

Plant Support

• The licensee identified that contract fire watch individuals had falsified fire watch documentation. The inspectors concluded that this failure constitutes a violation with low risk consequence because the fire areas were still being inspected, although at less than the required frequency; and in some cases the detection system remained operable to give early waming. Although the inappropriate action of the individual fire watches was willful, it was promptly brought to the NRC's attention by the licensee, it involved isolated acts of two individuals, and it was addressed by appropriate remedial action. Therefore, a Non-Cited Violation was issued. (Section F1.1)

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Report Details Summary of Plant Status Unit 1 entered the period at full power and remained at or near full power for the entire perio Unit 2 entered the period at full power and remained at or near full power for the entire perio . Operations I l 01 Conduct of Operations  !

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0 Control Room Staff Observations  ! Inspection Scope (71707) I

, The inspectors reviewed Braidwood Administrative Procedure (BwAP) 300-1, " Conduct of Operations," Revision 19E1; BwAP 320-1, " Shift Manning," Revision 9; BwAP 100-1,

" Main Control Room Access," Revision 0; BwAP 100-12, " Human Performance Awareness of Pre-Job Briefings / Meetings and Self Checking," Revision 5; and BwAP 335-1, " Operating Shift Tumover and Relief," Revision 14E1. The inspectors interviewed unit supervisors and nuclear station operators (NSOs), observed operations department shift tumover briefings, observed tumovers performed between unit supervisors and NSOs in the control room, and observed the general conduct of control room activities, Observations and Findinas The inspectors noted that the unit supervisors demonstrated good command and control with the exception of one event on July 19 when the licensee identified a 42-second time span where there were no individuals in the control room that held a senior reactor operators license; a condition prohibited by Technical Specification (TS) 6.2.2.b. In response to this event, the licensee has initiated a root cause investigt. tion and has implemented three corrective actions to prevent recurrence. First, the unit supervisor that left the control room was counseled by senior levels of station management conceming the inappropriate behavior. Second, the licensee attached a clip to the end of the unit supervisors identification badge that prevents the insertion of the identification badge into the control room egress card readers, an action required to leave the control roo Attached to the clip is a card to prompt the unit supervisor to ensure command and control requirements have been met prior to leaving the control room. Third, the licensee has implemented a computer software change that prevents the last individual holding a senior reactor operator license from exiting the control room. The inspectors determined that the licensee properly addressed the apparent causes of this event. This issue, which may represent a violation of NRC requirements, will remain open pending receipt and analysis of the Licensee Event Report (LER) required to be submitted to the NRC by 10 CFR 50.73. The resolution of this issue will be tracked by Unresolved item (URI)

(50 456/98009-01(DRP); 50-457/96009-01(DRP)).

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The inspectors attended the operations department shift tumover briefings. The inspectors noted that the shift managers conducting the briefings were knowledgeable of topics covered; that all licensed and non-licensed operators on-shift were in attendance; and that major work activities, limiting condition for operations (LCOs), and unit status were discussed. The inspectors observed frequent attendance by the operations manager and the shift operations supervisor who stressed safety, procedure adherence, and configuration contro The inspectors observed control room operators throughout the inspection period. The inspectors noted that the NSOs were attentive, property used operating procedures, utilized self-checks when manipulating equipment, and used three-way communication The inspectors observed the NSOs respond to expected and unexpected alarms. The NSOs promptly addressed alarms, referred to the annunciator response procedures for unexpected alarms, and promptly informed supervisors of unexpected alarm c., Conclusions i The inspectors concluded that a loss of control room command and control occurred for 42 seconds when there were no individuals in the control room who held a senior reactor operators license; a condition prohibited by TS 6.2.2.b. This issue, which may represent a violation of NRC requirements, will remain open pending receipt and analysis of the LER required to be submitted to the NRC per 10 CFR 50.73. The inspectors concluded, with the exception of the event discussed above, that the shift managers, unit supervisors, and nuclear station operators exercised good control room conduct, based on observations of shift tumover briefings, pre-job briefings, control board operations, j control of evolutions, response to alarms, communications, direction of personnel, and control of work evolution .2 System Auxiliary Transformer 242-2 Retum To Service Inspection Scope (71707)

The inspectors reviewed Braidwood System Operating Procedure (BwOP) AP-26,

" Restoring System Auxiliary Transformer 242-2 with Unit 2 Auxiliary Transformer Energized," Revision 7; BwOP AP-6, " Racking-in a 4160V [ Volt) or 6900V Air Circuit Breaker " Revision 8; BwOP AP-14, " Removing the Ground and Test Device from a 4160V or 6900V Cubicle," Revision 72; Braidwood Abnormal Operating Procedure

. (BwOA) Unit 2 ELEC-3, " Loss of 4 Kilovolt ESF [ Engineered Safety Feature) Bus Unit 2,"

Revision 55; and 2BwOA ELEC-4, " Loss of Offsite Power," Revision 4. The inspectors observed heightened level of awareness meetings, discussed plant parameters with operations personnel, reviewed the Unit 2 control room logs, and observed the performance of portions of BwOP AP-24 and BwOP AP-26 from both the control room and switchyar Observations and Findinas l

l Between June 19 and June 22, the inspectors attended heightened-level-of-awarenesa l L briefings and observed that all required participants were in attendance, applicable procedures were satisfactorily reviewed, individuals assigned specific tasks were made aware of their responsibilities, and briefing leaders sought feedback from all individuals

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present. The inspectors observed that BwOP AP-26, BwOP AP-6, BwoP AP-14,2BwOA ELEC-3,' and 2BwoA ELEC-4 were written well and contained sufficient direction to perform the respective evolutio The inspectors observed that procedural steps were followed in order, operators in the switchyard observed all electrical safety precautions, proper three-way communications were used between operators in the control room and operators in the field, pee ,

checking was used to verify proper equipment when operating breaker controls in the

control room, and the amount of supervision was appropriate. The inspectors also reviewed the control room logs and determined that the entrance into and exit from the associated LCO was logged as require The inspectors reviewed the retum-to-service portion of the station's system Auxiliary !

Transformer 242-2 schedule, including milestone start and completion times as well as planned entrance and exit times for the associated LCO. The inspectors determined that ,

the licensee closely adhered to the schedule and completed the retum-to-service well within the allowed outage time of the LC ] Conclusions

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i The inspectors concluded that the retum-to-service of the Unit 2 system Auxiliary I

,_ Transformer 242-2 was planned and executed well. Operations personnel conducted a I thorough heightened-level-of-awareness briefing, operated control room and switchyard equipment safely, and followed applicable procedure {

01.3 Unit 1 Refuelina Activities Inspection Scope (60710)

l The inspectors observed new fuel receipt in the fuel handling building. The inspectors also reviewed the following procedures:

a BwAP 370-3, " Administrative Control During Refueling," Revision 19;

Braidwood Fuel Handling Procedure (BwFP) FH-1, "New Fuel Receipt," Rey!sion 8;

.. BwFP FH-2, "New Fuel Inspection," Revision 5;

• BwFP FH-3, "New Fuel Transfer To/From Storage Vault," Revision 4; and a BwFP FH-20, " Operation of the Fuel Handling Building Crane," Revision SE Observations and Findinas The inspectors observed that plant personnel involved in activities with the new fuel receipt followed appropriate procedures The inspectors determined that fuel handling personnel were knowledgeable of procedural requirements and on use of the fuel handling equipmen _ - _ _ _ _ - _ - _ - _ _ _ _ _ _ _ _ _

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- The inspectors noted that radiation protection personnel were present during unpacking of new fuel assemblies and closely monitored the dose rates associated with the new fuel and checked for loose surface contamination. The inspectors observed that all radiation measuring instruments were within calibration due dates and were operating proped Surveys forms were maintained and updated by radiation protection personne Fuel handlers moved assemblies from transport containers only after radiation protection personnel verified conditions allowed movement. Fuel handlers were proficient in the use - i of fuel movement equipment. Nuclear engineering personnel were present to inspect the fuel assemblies as they were unpacked. Status boards and data sheets were maintained and updated by nuclear engineering and fuel handling personne During new fuel receipt, areas of the fuel building were well controlled. Foreign material exclusion areas were established around the new fuel vaults and in the area where new fuel was unpacked. Personnel entering the areas followed procedures to ensure material was not inadvertently introduced into the area. Personnel entering foreign material exclusion (FME) areas also removed items that could fall into the area from their person, taped pockets closed, and used lanyards to prevent items such as safety glasses from falling in the area. Access to the FME areas was controlled by the fuel handling supervisor, Conclusions The inspectors concluded that plant personnel were knowledgeable of fuel handling and fuel inspection responsibilities and procedures. Fuel handling personnel demonstrated they were knowledgeable in the use of fuel handling equipment during recent receipts of new fuel. Fuel handling personnel followed procedures, implemented proper foreign material exclusion controls, and propedy maintained required documentation and status board :02 Operational Status of Facilities and Equipment l 0 Essential Service Water Pumo Room Water Tiaht Door Inspection Scope (71707)

The inspectors examined water tight doors to the essential service water pump rooms; ;

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interviewed fire watch, operations, and supenrisory personnel; reviewed BwAP 380-3,

" Control of Watertight Doors and Flood Seal Openings / Barriers," Revision 4; mviewed the Updated Final Safety Analysis Report (UFSAR), Chapter 9.2.1.2; and reviewed {

l Braidwood Individual Plant Examination (IPE), Section 1.4.5, "Intemal Flooding Analysis." {

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) Observations and Findinas I

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On June 17, during the aftemoon shift, the inspectors observed that the watertight door to the "B" essential service water (SX) pump room was open and unattended, with no posted impairments. Maintenance activities had begun on the 1B SX pump on the day shift and were stillin progress. Braidwood Administrative Procedure 380-3, Step E.2.a.1, stated, "All safety-related system equipment rooms equipped with water tight doors will have the watertight door (s) closed and its closure mechanism aligned in its ' closed'

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position except during passage or when the room is occupied." . However, the procedure does allow the door to be open and impaired as long as compensatory actions are take The compensatory actions listed in BwAP 380-3, Step E.3.c.3, required an hourly flood watch if the water tight door for the "B" SX pump room was impaired. The procedure was not clear whether the door could be open and the room empty with the compensatory measures in place. The inspectors notified the on-shift operating field supervisor. The field supervisor stated he felt it was satisfactory to leave the water tight door open with the room vacant as long as the compensatory actions were in plac The operations crew management stated that the flood watch was being conducted by the local area fire watch. The inspectors interviewed the local area fire watch personnel I and the fire watch supervisor. Fire watch personnel stated that the flood watch consisted -

of observing and logging the position of the SX pump room water tight door once an hou The fire watch supervisor stated that to perform a satisfactory flood watch the SX pump room would have to be physically entered. The inspectors also determined that there were no post orders or written instructions concoming the conduct of flood watch dutie Operations management stated that the actions taken by fire watch personnel to check the position of the door on an hourly basis without entering the room were satisfactory to conduct the flood watch. Based on discussions with operations management, review of the UFSAR, and review of the Individual Plant Examination (IPE), the inspectors concluded that no regulatory requirements were violated; however, as a minimum a verification that water was not coming out the open door would be expecte Conclusions The inspectors concluded that compensatory actions required for the impairment of the !

• B" SX flood door were pooriy communicated between operations department management, fire watch supervision, and fire watch personnel. The inspectors also determined that there were no post orders or written instructions concoming how to perform flood watch duties. The inspectors concluded that, in this case, the actions taken by fire watch personnel to check the position of the SX pump room flood door on an hourly basis without entering the room did constitute a satisfactory flood watc .

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08.1 (Closed) Violation 50-456/457-96007-01(DRP): The licensee's corrective actions were ineffective in preventing recurrence of multiple problems. As a result of an inspection conducted from February 10 through March 22,1996, the inspectors identified multiple ,

issues that constituted a violation of requirements contained in 10 CFR Part 50, Appendix B, Criterion XVI. The issues identified included: i

- The inspectors identified a defective and ajar door to the 2A diesel generator exhaust :

muffler room, although corrective actions had been previously completed by the licensee to assure that the door would remain close + The inspectors identified that emergency light 1-121, in place to satisfy 10 CFR Part 50, Appendix R, was not functioning properly for an extended period of

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time, although the licensee had previously completed corrective actions on multiple occasions to retum the light to normal statu The inspectors identified that no corrective actions were taken by the licensee in

- response to increased leakage into the Unit 2 pressurizer relief tank.

i Corrective actions taken by the licensee to address the individual issues appear to have

been effective. The licensee also initiated actions to enhance its corrective actions

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program including adding additional personnel to root cause investigation teams and requiring more senior management involvement in dealing with identified problems. In

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- May 1997, the licensee further upg aded the corrective actions program and issued Nuclear Station Work Procedure (NSWP) A-15,." Commonwealth Edison Nuclear Division Integrated Reporting Program." This violation is close . Maintenance M1 Conduct of Maintenance M1.1 . Maintenance Activity Observations Insoection Scoce (62707)

The inspectors observed all or portions of the following maintenance activities:

Preventive maintenance cleaning of the 1B safety injection (SI) pump cubicle cooler in l accordance with Work Package 970029947-0 *

Repair of the Unit 2 containment atmospheric Monitor 2 PRO 11J in accordance with E Work Package 9800672-05.

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Replacement of the Unit 1 turbine oil system pressure Gauge 1Pl TO149 in accordance with Work Package 980064513-0 * Drain, fill, vent, and calibration of Unit 1 residual heat removal system differential )

pressure flow indicator flow transmitter indicating Switch 1 A in accordance with Work l Package 980070051-01, Observations and Findinos Between June 23 and July 2, the inspectors attended the heightened-level-of-awareness meetings; reviewed Work Packages 970029947-01, 9800672-05, 980064513-02, and 980070051-01; reviewed high-risk work check sheets, if applicable; walked down the work areas with maintenance personnel; questioned personnel concoming the scope of the work, including system status, and precautions for electrical safety; observed the establishment of required system conditions; observed the use of FME controls; and observed the use of quality control " hold points." The inspectors also reviewed the t associated LCO, if applicable, and reviewed the control room logs for LCO entry and exit

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log entries. The inspectors noted no problems during the above reviews, interviews and observation _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _

9 Conclusions The inspectors observed all or portions of various maintenance activities and concluded that activities were performed in accordance with the applicable procedures, that the procedures provided the requisite information necessary to perform the work, that maintenance personnel demonstrated good general work practices, and that maintenance personnel were knowledgeable of the associated LCO and high-risk work activity requirement M1.2 Observation of Miscellaneous Surveillance Activities Inspection Scope (61726)

l The inspectors observed all or portions of the following surveillance activities:

.- - Unit 1, Braidwood Operating Surveillance Procedure (BwOS) 8.1.1.2.a-1, "1 A Diesel Generator Operability Monthly (Staggered) and Semi-Annual (Staggered)

Surveillance," Revision 12E1; l .

Unit 1, Braidwood Engineering Surveillance Procedure (BwVS) 5.5.8.St.2, "American Society of Mechanical Engineers (ASME) Surveillance Requirements for the 1B Si Pump," Revision 0;

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Unit 2, SwVS 0.5-3.SX.1-2, "ASME Surveillance Requirements for 2B Essential Service Water Pump," Revision 1E1;

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Unit 2, Braidwood Engineering Surveillance Procedure (BwVSR) 5.5.8.CS.1, "ASME Surveillance Requirements for 2A Containment Spray Pump and Check Valves 2CS003A, 2CS011 A," Revision 0; and

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Unit 1, BwVSR 5.5.8.AF2, " Unit One Diesel Driven Auxiliary feedwater Pump ASME Quarterly Surveillance," Revision OE Observations and Findinos Between June 22 and July 2, the inspectors observed the performance of the above l listed surveillance tests. For each surveillance test, the inspectors observed the l establishment of initial conditions required for the surveillance test, the operation of equipment, the communications between the licensed operators in the control room and non-licensed operators in the auxiliary building, and the restoration of affected equipmen The inspectors determined that each of these activities were performed in accordance with the applicable procedure. The inspectors reviewed the data obtained during the

. surveillance tests and noted that it met the required acceptance criteria specified in the surveillance test procedures. The inspectors also reviewed the associated potiions of the UFSAR and the TSs and determined that the surveillance test procedures demonstrated the systems performed as designed.'

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. Conclusions

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The inspectors observed the performance of five surveillance tests. The inspectors concluded that the surveillance tests adequately tested the system, the operators followed the procedures, and that the procedures included the required testing discussed in the TS t

M1.3 Refuelino Outaae A1R07 Plannina Review Inspection Scope (62707)

The inspectors attended management meetings dealing with outage planning and ,

- interviewed plant management. The inspectors also discussed outage planning i indicators for recent Refueling Outages A1R06 and A2R06 and compared them to indicators for the upcoming steam generator replacement and Refueling Outage A1R07, Observations and Findinas i The inspectors discussed the preparations for the upcoming outage with outage planner '

The inspectors were told 100 percent of the radiation work permits had been prepared and were currently undergoing departmental review,100 percent of the out-of-services were prepared,94 percent of the work packages were complete,100 percent of the detailed outage schedule was complete and under review, and 90 percent of the parts were onsite. The inspectors noted that there has been improvement in work package preparation when compared to previous refueling outages. For example, during A1R06, 1800 work packages (94 percent of the total number of work packages) were prepared 6 weeks prior to the beginning of the outage. For the upcoming Outage A1R07, 3000 work packages (94 percent) were prepared 7 weeks in advance of the start of the outage. - Another area where inspectors noted improvement over previous outages was with the preparation of the detailed outage schedule. During A1R06 the detailed outage schedule was ready for review three to four weeks prior to the start of the outage. For A1R07, the detailed outage schedule was ready for review 12 weeks prior to the beginning of the outag The inspectors discussed the improvement in outage planning with station managemen j Station management credited improvements to increased visibility of the outage planning i process through the use of weekly meetings with senior levels of station management j and the use of project teams to optimize the scheduling and sequencing of outage I acGvities. These weekly reviews included the status of high profile projects, the review of the outage schedule, and a separate review of the steam generator replacement project, I

l' Conclusions I The inspectors concluded that the licensee has made improvement in outage work l ' package preparation and outage schedule development for the upcoming steam generator replacement and Refueling Outage A1R07. The inspectors concluded that the improvement is due to increased visibility of the outage p!anning process, improved communications, and the use of project team L J

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M8 Miscellaneous Maintenance issues (92902)

M8.1 (Closed) Unresolved item 50 456/457/9402043(DRP) Programmatic deficiency contributing to diesel generatorinoperability. During the close-out of Violation 50-456/457/94008-01, which concemed both Unit i diesel generators being declared inoperable due to a misinterpretation of surveillance data, the inspectors noted that the licensee determined that a secondary cause of that event was a programmatic deficiency. The mechanical / structural design group in the nuclear engineering and technology services department had recommended testing Braidwood station's diesel generators at a power factor of 0.8. This recommendation was adopted without adequate analysis and resulted in an increase in voltage to a value greater than the TS allowed maximum voltage. The inspectors closed Violation 50-456/457/94008-01 but characterized the licensee identified programmatic deficiency as an unrasolved item pending further NRC review. Since 1994, the licensee has taken action to establish guidance conceming the preparation and control of safety-related, regulatory related, and nonsafety-related nuclear design information transmittals both to and from Corporate Engineering (formerly the nuclear engineering and technology services department).

Proposed design changes are now tracked using a nuclear design information transmittal in accordance with Nuclear Engineering Procedure NEP-12-03, " Nuclear Design information Transmittals," Revision O. The nuclear design information transmittal provides a scrutable package for site engineering personnel to evaluate prior to I implementation. Nuclear Engineering Procedure NEP-13-02, " Nuclear Fuel Services-Site Design intefface Agreement," Revision 0, provides a similar tool to site engineering, specifically for fuel handling applications. The inspectors reviewed several recent nuclear design information transmittals and design interface agreements and determined that the process is used and should prevent recurrence of the programmatic deficiency which contributed to Violation 50-456/457/94008-01. This unresolved item is close M8.2 (Closed) LER 50-456/96006-00: The failure to control failed damper position results in the inability to satisfy TS acceptance criteria. On January 23,1996, the licensee identified that the 2B Safety injection (SI) pump room ventilation supply damper had failed open. Operations personnel responded and repositioned the damper to the closed position by closing the ' instrument air supply valve for the damper and opening the instrument air regulator bleed off valve. To track the abnormal position of the instrument air supply valve, operators attached a caution card. However, operators failed to attach a l

caution card to track the abnormal position of the regulator bleed off valve. On June 3, 1996, while performing a system inspection, the system engineer discovered the Si pump room ventilation supply damper in the open position. Operations personnel then closed l the damper and found that the instrument air regulator bleed off valve had been closed I l and the supply valve was still closed. The system engineer questioned whether the TS 3/4.7,7.d.3 requirement to maintain the SI room at a negative pressure of greater than or equal to 0.25 inches of water could be met with the damper open. Air leakage past the j instrurnent air supply valve had caused the Si pump room ventilation supply damper to reopen. On June 6,1996, the licensee performed a surveillance test per Braidwood Engineering Surveillance Procedure (BwVS) 7.7.d-1 and determined that TS acceptance criteria could not be met with the Si pump room ventilation supply damper open. This event was originally documented in NRC Inspection Report 50-457/96006 and characterized as URI 50-457/96009-06 pending further NRC evaluation. The URI was i subsequently evaluated cnd closed in NRC Inspection Report 50-456/457/96011(DRP) as

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i an additional example of a previous violation for failure to maintain prope controls and no violation was issued. This LER is close Unit 1 steam generator classified as Category f edC-3. The M (Cic::d) LER SO45Af9601240:

- licensee determined, following a Unit 1 steam generator in-service inspecti during mid-cycle Outage A1P02, that Steam Generators 1 A,18,1C, and required to be classified as Category C-3 per TS 4.4.5. All defecti

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repaired by sleeving or were removed from service by plugging. In d sleeving and plugging,23 tubes with circumferenti None of the tubes pressure tested burst and the measured i t leakage steam generator was less than the site allowable leakage of at 26.8 gallon ti The Unit i steam generators were scheduled t the end of the inspection period. This LER is close #

A failure to follow procedure during f

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installation Violation of Unit5045A196019-03fDRP):

1 "C" steam generator cold leg manway cover. As a d

inspection conducted from October 19 through N ..

the female threads were not lubricated as required by Braidwood Mecl Maintenance Procedure (BwMP) 3300-038," Removal and installati 9 Manway Cover on the Steam Generators," Revision li 7.e Immediate taken by the licensee to address the issue appear to have been effec has upgraded the self-check process through the issuance of Bw Performance Awareness of Pre-Job Briefings / Meetings and S The licensee considers procedure noncompliance i to be a signi quality and as such has assigned a team to perform a trend inv effectiveness review of previous corrective actions. This violation is c Unit 1 steam generator classified as Category d C-3. The (Closed) LER 50456/97002-00_:

M licensee determined, following a Unit i steam generator in-servic during Refueling Outage A1R06, that Steam Generators 1 A,18,1 required to be classified as Category C-3 per TSh 4.4.5.2.e. All d repaired by sleeving or were removed t from se tested and two tubes were removed Unit 1 steam per Ge t team was less than the site allowable leakage of 26.8 gallons per minute. Th generators were scheduled to be replaced in September d f this 1998 generators were delivered and were undergoing receipt inspecti inspection. This LER is close Preconditioning of charging and residual M (Closed)

heat removalViolation pumps 50-456/457/97005-03fDRPJ:

d'Jring surveillance testing. This violation d the invo preconditioning of the chemical and volume control de system (

fl residual heat removal system (RH) h CV pump to startpump strip S conditions to match the assumed accident conditions, shutdown th chart recorders for the measurement of pump response time, and r

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measure the response time. Braidwood Engineering Surveillance Procedure BwVS 0.5-2.RH.2-2 contained similar steps that resulted in the preconditioning of the RH pump response tim The licensee reviewed the CV and RH response time surveillance test procedures to assess the methodology. Additional data was obtained during the performance of the response time surveillance test procedures for the CV, RH, and Si pumps. The data was used to evaluate the effects that different system conditions have on response time results. The data demonstrated that there was no significant difference (0.1 second)

between the response times obtained under hot start conditions (preconditioned) and cold start condition (non-preconditioned). The licensee revised the surveillance test procedures used for the measurement of response times for the CV and RH system The revisions will permit the collection of pump start response times under flow

. conditions that approximate post-accident conditions. The inspectors determined that the licensee's corrective actions addressed the concem. This violation is close M8.7 (Closed) LER 50-457/98003-00: Failure to identify surveillance test data that did not meet TS acceptance criteria. On May 8,1998, a system engineer was reviewing the data collected during the December 23,1997, performance of surveillance test 2BwOS 8.2.1.2.b-1, "125 Volt Direct Current ESF Battery 211 Quarterly Surveillance,"

Revision 8. During this review, the system engineeridentified that non-licensed operators failed to identify that the specific gravity of Battery Cell No.1 (1.262) was less than the TS acceptance criteria (21.280), and that the specific gravity deviation from the average specific gravity of all connected cells for Battery Cell No. 58 (0.023) was greater than the TS acceptance criteria (s0.020). The non-licensed operators signed off the surveillance test procedure as complete and submitted the surveillance test procedure to the work center supervisor, a licensed senior reactor operator, for review.- The work center superviser also failed to detect the out-of-specification condition The licensee conducted a root cause investigation and identified cognitive personnel errors by the non-licensed operators and the work center supervisor involved in the performance and review of the surveillance test. The licensee identified two contributing causes. First, the surveillance test procedure data sheet did not list TS acceptance criteria for the specific gravity deviation from the average specific gravity of all connected cells. Second, the senior non-licensed operator (equipment operator) did not properly j monitor the performance of the junior non-licensed operator (equipment attendant). l The licensee reviewed the data obtained during the most recent surveillance test (March 16,1998) and the three previous tests conducted per 2BwOS 8.2.1.2.b-1. All acceptance criteria, with the exception of the examples identified in LER 50-457/98003-00, were met. The licensee provided counseling to the non-licensed operators and the work center supervisor involved in the event, revised the surveillance test procedure adding the TS acceptance criteria for the specific gravity deviation from

- the average specific gravity of all connected cells to the surveillance test procedure data sheet, and discussed the event during requalification training with all shift operator Technical Specification 4.8.2.1.2.b requires, in part, that at least once every 92 days the 125 voit DC battery specific gravity be verified to be 21.280 and the average specific

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gravity of all cells be verified to be so.020. Furthermore, Procedure 2BwOS 8.2.1.2.b-1,

"125 Volt Direct Current ESF Battery 211 Quarterly Surveillance," Revision 8, Step F.18 states, " Compare recorded values from the data sheet against the acceptance criteria and notify the shift manager or designee of any discrepancies." Contraiy to the above, the licensee failed to verify the specific gravity parameters of the 125 volt DC battery as specified in TS 4.8.2.1.2.b, and failed to accurately compare the recorded values from the data sheets against the acceptance criteria. 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 (50-457/98009-02(DRP)). This item is close Ill. Enaineerina E1 Conduct of Engineering E Operability Determination Reviews Inspection Scope (37551)

.l The inspectors reviewed the following document .

• Operability Evaluation 98-19, " Unit 1 Sl Pump 1Sl01PB Minimum Flow Requirements 1 of 45 gallons per minute. The 1B SI pump Currently 44.5"; j

- Operability Evaluation 98-034, " integrated Leak Rate Testing Piping Lines 1VQ108-6"(inch) and 2VQ10B-6"[ inch] Are Not Installed Per Design  !

Drawings";

• Operability Evaluation 98-036, " Unit 2 Intermediate Range N36 is Experiencing Intermittent, Extemally Induced, Electronic Noise";

= Braidwood Administrative Procedure 330-10, " Operability Determination,"

Revision 3E3;

+ Compensatory Action Associated with the Source Range High Flux Trip Block with Noise Present on Intermediate Range N-36;

• Braidwood Emergency Procedure 2BwEP-0, " Reactor Trip or SI Unit 2," Revision 1B;

• 2BwEP ES-0.1, " Reactor Trip Response," Revision 1D;

• - Unit 2 Braidwood General Operating Procedure (2BwGP) 100-5, " Plant Shutdown and Cooldown," Revision 14;

• Braidwood UFSAR Section 6.3.2.2; and

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The inspectors verified that the documentation of the operability evaluations met '

BwAP 330-10 requirements, that the licensee complied with TS requirements, and that the assumptions used to develop the operability determinations were vali The inspectors discussed listed compensatory actions with control room operations personnel and determined that operators were aware of, and understood the compensatory actions listed. The inspectors discussed the listed corrective actions with

system engineering personnel. The inspectors determined that necessary repair or replacement actions were being tracked using either the action request process or the nuclear tracking syste , Conclusions .

The inspectors concluded that the operability determinations regarding the Unit i safety injection pump minimum flow requirements, integrated leak rate testing piping lines, and Unit 2 intermediate range instrument electronic noise reflected good engineering judgement and safety focus. The inspectors also concluded that the necessary compensatory actions were well understood by operations personnel and that corrective actions were being tracked by system engineering personne E Review of Completed 10 CFR 50.59 Safety Evaluations Inspection Scope (37551)

The inspectors reviewed three 10 CFR 50.59 safety evaluations:

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BRW-SE-1997-858, the isolation of demineralized water makeup system from the jacket water standpipe of the four emergency diesel generators, dated June 17,1997;

BRW-SE-1998-1004, the installation of temporary Alteration 98-1-010, dated May 28, 1998 associated with the removal of the flow orifice plate from the 18 auxiliary feed water pump recirculation flow element; and

• BRW-SE-1998-534, exempt Change E20-1/2-97-265, removal of Unit 1 and 2 reactor containment fan cooler inlet and outlet dew point temperature indication, dated March 27,199 ' The inspectors reviewed NSWP-A-04, "10 CFR 50.59 Safety Evaluations Process,"

Revision ] Observations and Findinas l The inspectors reviewed three 10 CFR 50.59 safety evaluations recently completed by

the licensee. In each of the safety evaluations, the licensee determined that no L unreviewed safety question existed. The inspectors reviewed the safety evaluations and 4 l'

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agreed with the licensee's conclusions. The inspectors determined that the licensee's justifications were technically correct and were referenced to applicable sections of the UFSAR, TSs, ASME Boiler and Pressure Vessel Code, and Nuclear Regulato;y

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Commission ReQulatory Guides. The inspectors noted that each safety evaluation was completed in accordance with the requirements contained in NSWP-A-0 Conclusions The inspectors concluded that the licensee properly performed the 10 CFR 50.59 safety evaluations for the isolation of the demineralized water makeup system to the diesel generatorJacket water standpipes, the installation of temporary Alteration 98-1-010, and the removal of Unit 1 and 2 reactor containment fan cooler inlet and outlet dew point temperature indication. The inspectors concluded that the licensee's justifications were technically correct and made reference to applicable sections of the UFSAR, TSs, ASME

, Boiler and Pressure Vessel Code, and Nuclear Regulatory Commission Regulatory

[ ' Guide E8 Miscellaneous Engineering issues (92903)

E (Closed) LER 50-456/95005-00: Current design basis for the containment spray and spray additive systems were not supported by TSs. On April 18,1995, both trains of the spray additive system were rendered inoperable by an operator valving error for a period of 10 minutes.' Upon identification, the licensee entered a 7-day LCO per TS 3.6.2.2 for the spray additive system. The licensee did not enter an LCO for the containment spray

' system because TS 3.6.2.1 for the containment spray system did not require the spra . additive system to be operable. The inspectors pointed out to the licensee that since the spray additive system is a support system for the containment spray system if both trains of the spray additive system were inoperable then both trains of containment spray should also be considered inoperable requiring entry into TS 3.0.3. Immediate corrective action taken included a change to the Unit 1, Braidwood Operating Surveillance Procedure 1BwOS 6.2.2-1a, " Limiting Condition for Operation Action Requirements Containment Spray System TS LCO 3.6.2.1/' Revision 1E1, to address the potential for containment spray system inoperability if the spray additive system were to become inoperable. The inspectors verified that no violation of the TSs occurred during the event; that there have

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been no similar events since May 1995. The configuration control problems identified in this LER were previously addressed in Inspection Report 50-456/457/96005(DRP). This LER is close E8.2 (Closed) Inspection Followuo item 50 457/95017-03(DRP): Chemical and volume control system relief valve bellows failure following operation. On November 16,1995, a sudden increase in the differential pressure applied to the l

Unit i reactor coolant filter caused the lifting of CV relief valve 1CV8119 and l damage to the valve's intemal bellows. The inspectors were told by the licensee l that similar problems with the relief valve have occurred in the past and this inspection followup item was generated to track the licensee's resolution of the bellows failure problem. In November of 1997, SI system relief valves 2Sl8851, 2Sl8853A, and 2Sl8853B, lifted during surveillance testing and bellows failures were observed in 2Sl8851 and 2S18853B. The licensee declared both trains of the Si system inoperable and entered the LCO for TS 3.0.3. The licensee issued LER 50-457/97005 in accordance with 10 CFR 50.73. The licensee has

' determined that the CV and Si relief valves were similar in design and were made by the same manufacturer. The licensee's laboratory analysis of the failed  !

bellows indicated that the failure was due to excessive back pressure. The high  !

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back pressure problem was documented in Engineering Request #9703016 and

. was assigned to the site engineering organization for evaluation and resolutio The licensee's resolution of relief valve bellows failures on the CV and si relief valves will be reviewed by the inspectors as part of their followup to LER 50-457/97005. This item is close E8.3 (Closed) LER 50-456/96010-00 and 50-456/9601041: Boraflex shrinkage and gaps exceeded largest gap assumed in spent fuel pool criticality analysis. On September 20,

1996, the licensee identified in LER 50-456/96010-00 that spent fuel racks had boraflex shrinkage and gaps which exceeded the largest gap assumed in the licensee criticality -

!r analysis for the spent fuel pit. On March 3,1997, the licensee also identified in supplemental LER 50-456/96010-01 a modeling deficiency in the original spent fuel pit

! criticality analysis. The original analysis assumed boral poison plates were located on all four faces of a particular storage cell within the spent fuel pit which was not correc Some peripheral fuel storage cells do not have boral poison in the exterior plates. The licensee determined that with the fuel separation design of the fuel pool and administratively maintaining the fuel pool water at 22,000 ppm boron the Keff of the pool will be less than 0.95. The licensee requested and received a license amendment changing the TS to allow for soluble boron to be credited in maintaining the spent fuel pit Keff < 0.95. This license amendment has been incorporated into the current TS and implemented procedurally by the licensee. This LER and supplement is close E8.4 (Closed) Violation 50-456/457-97012-01(DRS): Preconditioning of electrical equipmen The violation addressed two examples where it appeared that the licensee was potentially preconditioning electrical equipment. The first instance involved a procedure which directed the operator to manually cycle a breaker before performing overcurrent protective device testing. The second instance involved inspecting and operationally checking time delay relays Just prior to performing a TS timed test of the relays. To j address this concem, the licensee revised the particular surveillance procedures to

ensure that true as-found readings were taken. The licensee also reviewed all other TS l surveillance to ensure that no other examples of preconditioning existed. The I operations department prepared a matrix to ensure proper sequencing of surveillance to

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' prevent inadvertent preconditioning in the future. Finally the licensee provided training on preconditioning to raise the station's overall awareness of the issue. The inspectors reviewed the licensee's corrective actions and had no further questions. This violation is closed.

L E8.5 (Closed) Violation 50-456/457-97012-03(DRS): Inadequate design control regarding feedwater line break analysis. The NRC identified that the flow resistance values used to calculate steam generator flows were non-conservatively low, inspection l' Report 50-456/457-97012 noted that the licensee had corrected the calculation at the time of the inspection and also had a pogram to validate calculations. Following issuance of the violation, using the low feedwater flows the licensee determined that the original design was not exceeded. The licensee performed a root cause af.alysis and provided training to engineering staff on why the error occurred. The inspectors determined that the licensee's corrective actions addressed the concem. This violation is close :

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IV. Plant SuDDort F1 Control of Fire Protection Activities F1.1 Falsified Fire Watch Documentation Inspection Scope (71750)

The inspectors reviewed the audit results that identified falsified fire watch activities. The inspectors reviewed the results of the licensee's intemalinvestigation and its remedial actions taken to address the cause of this even Observations and Findinas The licensee identified, during an audit of fire watch activities, that two contract fire watch individuals falsified fire watch documentation.. This finding was promptly communicated to the senior resident inspector onsite. The fire watch documentation showed a fire zone was being checked hourly; however, the security card reader records did not indicate entries into these areas by fire watch personnel. Specifically, on January 15 and 17, a fire watch individual did not inspect the upper cable spreading rooms hourly as required by procedure but documented the completion of the surveillance inspection. On January 19, another individual falsified fire watch documentation which indicated that the required areas were inspected. However, the security card reader records showed that the individual was at another locatio Braidwood Administrative Procedure 1100-13, " Fire Watch Inspection," Revision 6, a procedure required by TS 6.8.1.g, states, in part, " Inspectors shall observe specified single or multiple areas for the purpose of detecting and reporting any fires." Contrary to Braidwood Administrative Procedure 1100-13, the two fire watch personnel failed to observe the upper cable spreading rooms hourly, but did document that the required observations were performed houriy in the fire watch inspection lo This failure to follow procedure requirements constitutes a violation with low risk consequence because the tire zones were still being inspected although at less than the required frequency and in some cases the detection system remained operable to give earty waming. The licensee determined that the fire watch personnel involved in this event admittedly did not perfoe1 their duties and falsified documents to cover up the event. On February 6, their ert ployment was terminated. The licensee counseled all fire watch personnel on the details of the event, disciplinary actions taken, and disciplinary action to be taken in the event of repeat occurrences. Fire watch supervision also increased the frequency of their routine route checks. Although the inappropriate actions of the individual fire watches were willful, it was promptly brought to the NRC's attention by the licensee, it involved isolated acts of two individuals, and it was addressed by appropriate remedial action. Therefore, 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 (50 456/98009-02(DRP)).

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. Conclusions The licensee identified that contract fire watch individuals had falsified fire watch documentation. The inspectors concluded that this failure constitutes a violation with low risk consequence because the fire areas were still being inspected although at less than the required frequency and in some cases the detection system remained operable to give early waming. Although the inappropriate action of the individual fire watches was willful, it was promptly brought to the NRC's attention by the licensee, it involved isolated acts of two individuals, and it was addressed by appropriate remedial action. Therefore, a Non-Cited Violation was issue V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on July 27,1998. The licensee acknowledged the findings presented. The inspectors asked the !icensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie _ _ _ _ _

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i PARTIAL LIST OF PERSONS CONTACTED Licensee

• T. Tulon, Site Vice President'

• K. Schwartz, Station Manager

• C. Herzog, Executive Assistant

' R. Wegner, Operations Manager

• D. Hoots, Acting 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

• B. Schramer, Chemistry Manager J. Meister, Engineering Manager

• F. Lentine, Acting Engineering Manager

• 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 P. Lougheed, Reactor Engineer D. Chyu, Reactor Engineer T. Tongue, Project Engineer IDNS_

• T. Esper

• Denotes those who attended the exit interview conducted on July 27,199 !

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INSPECTION PROCEDURES USED IP,37551: Onsite Engineering

. IP 60710: Refueling Activities IP 61726: Surveillance Observations IP 62707: Maintenance Observation IP 71707: Plant Operations IP 71750: Plant Support Activities IP 92901: Followup - Plant Oporations IP 92902: Followup - Plant Maintenance IP 92903: Followup - Engineering ITEMS OPENED, CLOSED, AND DISCUSSED Opened

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50-456/457/98009-01 URI control room manning

'50-456/98009-02 NCV inadequate review of surveillance data 50-456/98009-03 NCV failure to follow procedure Closed 50-456/457/94020-03 URI failure to analyze rejection test 50-456/95005-00 LER failure to comply with design basis

'50-457/95017-03 IFl relief valve bellows failure 50-456/96006-00 LER failure to maintain TS requirement 50-456/457/96007-01 VIO failure to take corrective actions 50-456/96010-00 LER failure to comply with design basis 50-456/96010-01 LER failure to comply with design basis !

50-456/96012-00 LER fsilure to maintain TS requirement 50-456/96019-03 VIO failure to follow procedures 50-456/97002-00 LER failure in manufacture of SG tubes 50-457/98003-00 LER failure to maintain TS requirement i

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50-456/457/97005-03 VIO failure to have proper test controls 50-456/457/97012-01 VIO failure to maintain equipment -

50-456/457/97012-03 VIO failure to maintain design control 50-456/98009-01 NCV inadequate review of surveillance data 50-456/98009-02 NCV failure to follow procedure l  !

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I LIST CY ACRONYMS USED AF Auxiliary Feedwater ASME American Society of Mechanical Engineers i BwAP Braidwood Administrative Procedure BwEP Braidwood Emergency Procedure BwFP Braidwood Fuel Handling Procedure BwGP Braidwood General Operating Procedure BwMP Braidwood Mechanical Maintenance Procedure BwOA Braidwood Abnormal Operating Procedure BwOP Braidwood Operating Procedure BwOS Braidwood Operating Surveillance Procedure BwVS Braidwood Engineering Surveillance Procedure BwVSR Braidwood Engineering Surveillance Procedure CFR Code of Federal Regulations CV Chemical and Volume Control System EP Ernergency Preparedness ESF Engineered Safety Features FME Foreign Material Exclusion IFl Inspection Followup Item IPE Individual Plant Examination LCO Limiting Condition for Operation LER Licensee Event Report NR Nuclear Regulatory Commission NRR- Nuclear Reactor Regulations NSO Nuclear Station Operator NSWP Nuclear Station Work Permit RH Residual Heat Removal RP Radiation Protection RP&C Radiological Protection & Chemistry SI Safety injection SX Essential Service Water UFSAR Updated Final Safety Analysis Report URI Unresolved item VIO Violation j

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