IR 05000456/1998018

Insp Rept 50-456/98-18 on 981015-23 & 1109-10.No Violations Noted.Major Areas Inspected:Four Areas Associated with Licensee SG Replacement Project

ML20197H436
Person / Time
Site:	Braidwood
Issue date:	12/04/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20197H430	List: IR 05000456/1998018 ML20197H426
References
50-456-98-18, NUDOCS 9812140087
Download: ML20197H436 (14)

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U. S. NUCLEAR REGULATORY COMMISSION REGION 111 Docket No: 50-456 ,

License No: NPF-72 Report No: 50-456/98018(DRS)

Licensee: Commonwealth Edison Company Facility: Braidwood Nuclear Plant, Unit 1 Location: RR #1, Box 84 Braceville, IL 60407 Dates: October 15-23,1998; November 9-10,1998 Inspector: D. Muller, Reactor Engineer, Region ill l

l Approved by: Melvyn Leach, Chief, Operator Licensing Branch j Division of Reactor Safety i

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EXECUTIVE SUMMARY Braldwood Nuclear Plant, Unit 1 NRC Inspection Reoort 50-456/98018 l

This inspection included a review of the following four areas associated with the licensee's I steam generator replacement project: simulator modifications, plant procedure changes, l

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operator knowledge and performance, and operator trainin I Simulator Modifications 1

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Modifications to the simulator appeared to have been properly implemented. Simulator hardware and software changes appeared to accurately reflect the effects of the steam l generator replacement project (SGRP) for Unit 1. The process for modifying the simulator also appeared to be sound. Changes to the simulator were properly identified and tracked, and the simulator appeared to be adequately tested following the completion of the modifications. (Section O2.2)

Procedure Chanaes

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Procedure changes associated with the SGRP appeared to have been properly identified and implemented. The new proposed procedures appeared to accurately reflect the effects of the SGRP for Unit 1. The process for conducting the procedure changes also appeared to be sound. Changes to plant procedures were properly identified, tracked, and completed in a timely fashion. (Section O3.1)

Operator Knowledae and Performance

Operator performance and level of knowledge observed during this inspection were generally good, with one exception in the area of communications. During the simulator exercises most of the crew members occasionally did not refer to plant equipment by l the appropriate unit designator. (Section 04.1)

Operator Trainino

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Overall, the training associated with the SGRP was good. The overall content of the SGRP training program appeared appropriate. The instructors did a good job in presenting the training material, and the operating crew members actively participated in the training. However, two weaknesses with the training were observed. The first weakness was the use of all encompassing vice definitive learning objectives. The second weakness was the lack of a well-defined plan for evaluating student mastery of SGRP training material prior to the restart of Unit 1 with the new steam generators. The licensee, however, planned to administer a 15 question written exam, covering SGRP training material, to alllicensed operators. This exam was scheduled to be administered prior to the restart of Unit 1. (Section 05.1)

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Report Details Summary of Plant Status

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Unit 1 was shutdown for refueling and steam generator replacement during the entire

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inspection perio l. Operations 02 Operational Status of Facilities and Equipment O2.1 Overview of the imoacts of Steam Generator Reolacement

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Braidwood Station's Unit 1 steam generator replacement project (SGRP) outage began September 5,1998. The outage was expected to be completed in mid to late November 1998. Major changes associated with the SGRP are summarized as follows:

Unit 1 feedwater system changes. These changes included: removal of feedwater isolation valve bypass piping and bypass valves, removal of the water hammer prevention system and associated feedwater valve interlocks, and the removal of steam generator (SG) tempering flow lines. SG tempering flow is now directed through the main feed line *

Revised Unit i SG program levels and SG high/ low level alarms and actuation

set point * Changes associated with a two-degree lower Unit 1 100% power average

reactor coolant system temperature (RCS Tave). These effects included set l J point or programmed set point changes associated with reference temperature, steam dump actuation, over-temperature and over-pressure delta temperature .

protection, high/ low RCS Tave alarms, and changes in steam pressure.

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Changes associated with the thermal-hydraulic characteristics oi Unit 1's new

SGs. These effects included

improved heat transfer, an increase in RCS

volume (more SG tubes), and a decrease in SG secondary (steam) side volume.

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The addition of a wet layup system. This is a multipurpose system designed to i drain, add chemicals, and provide recirculation for Unit 1's SG In addition, as a part of the SGRP, licensee personnel have taken actions to modify main control room panels (and control room simulator panels), make revisions to 452 procedures, and conduct additional training for plant operators.

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I O2.2 Simulator Modifications Associated with the SGRP Inspection Scope (50001)

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The' inspector observed simulator performance during crew training exercises, which included low power feedwater manipulations, steam breaks, SG tube ruptures, and loss of coolant accidents. Additionally, walk downs of the Unit 1 panels in the station's main control room and in the simulator were conducted to compare panel configuration Finally, the inspector discussed simulator changes with licensee instructors, operating I

, crew members, and the simulator superviso I l

L Observations and Findinas i

I Hardware Chanaes Control room panel changes associated with the SGRP primarily occurred at the feedwater control station. These changes consisted primarily of:

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K Removal of control switches and indicators associated with the removed

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Deletion of flow alarms associated with the removed f eedwater isolation bypass

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piping.

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Deletion of tempering line and water hammer prevention system alarms. The

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tempering line and water hammer prevention system had both been remove Based on panel walk downs conducted at the simulator and at the station's main control l

room, no discrepancies with the simulator were noted. The simulator panels did j . correctly represent the SGRP control room panel configuration of Unit Software Chanaes j Numerous simulator software changes were made primarily to account for numerous set

point changes and changes associated with the thermal-hydraulic characteristics of the L new SGs. During panel walk downs and some of the observed simulator exercises, '.he j' inspector monitored a sample of the new set points. No discrepancies with the revised .l set points were observed. Iri addition, based on the observations during the simulator l exercises and on discussions with licensee instructors and operating crew members, the inspector noted the following differences in transient plant behavior

(1) Secondary side SG shrink and swell effects appeared to be more pronounce (2) . The RCS appeared to depressurize at a faster rate during steam break accidents.

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, (3) The'SG secondary side appeared to fill up quicker, and the associated SG

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power operated relief val'.e appeared to lift earlier during an SG tube rupture.

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l These above three observations appeared to be consistent with the increased heat transfer and smaller secondary side volume associated with the new SG Process Used for SGRP Simulator Chances Based on an interview conducted with the licensee's simulator supervisor, the inspector determined the overall process in which the simulator was modified during the SGR The process consisted of the following major steps:

(1) The simulator supervisor received copies of station work packages and set point changes from the station's configuration control grou (2) The simulator supervisor reviewed these work packages and set point changes, and developed simulator work requests to describe the necessary simulator l changes. In addition, the simulator supervisor also used information from Byron Station personnel to develop simulator work requests. Byron Station performed almost an identical SGRP in 199 (3) The simulator werk requests were then entered into a computer database for tracking purpocas and distributed to simulator technicians to perform the wor (4) Upon completion of all the modifications, the simulator was tested using approximately 320 different plant evolutions, including various malfunctions. In addition an initial license training class and their instructors were utilized to obtain further feedback on simulator performance, (5) The licensee planned to continue monitoring performance of the simulator, especially after more information about plant behavior becomes available during and after the restart of Unit 1, Conclusions Modifications to the simulator appeared to have been properly implemented. Simulator hardware and software changes appeared to accurately reflect the effects of the SGRP for Unit 1. The process for modifying the simulator also appeared to be sound.

l Changes to the simulator were properly identified and tracked, and the simuistor appeared to be adequately tested following the completion of the modification Operations Procedures and Documentation O3.1 Procedure Chanaes Associated with the SGRP Inspection Scope (50001)

The inspector reviewed a sampling of the station's current procedures (plant startup, plant shutdown, annunciator response, normal operating, off normal, and emergency),

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to assess the impact of the SGRP on plant procedures. The inspector additionally reviewed the licensee's proposed procedure changes associated with the SGRP, and

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observed some of the new procedures in use during simulator training exercise Finally, the inspector conducted interviews with licensee procedure group personnel who were involved with the SGRP procedure change Observations and Findinas Imoact of the SGRP on Plant Procedures The inspector determined thr.t the SGRP had the following major impacts on plant procedures:

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Deletion of annunciator response procedures associated with the removed feedwater isolation bypass p! ping, and the removed tempering line and water hammer prevention system alarm .

Changes to feedwater procedures and plant startup and shutdown procedure The major changes were associated with low power feedwater system operation .

A ' global" effect on a large number of prccedures, due to the changes in SG level set points, and the numerous set point changes associated with the two-degree lower Unit i 100% power RCS Tave. This required an update to the set point values used in these procedure Based on reviews of a sample of existing and proposed new Unit 1 procedures, and the observed simulator training exercises, the inspector determined that the licensee appeared to have properly identified and implemented procedure changes associated with the SGR Process Used for SGRP Procedure Chances As part of the SGRP, the licensee reviewed 9,040 procedures and identified that 452 procedures required revision. The inspector determined that tne following process was utilized to identify and implement procedure changes associated with the SGRP:

(1) Cognizant engineers reviewed the design change packages associated with the SGRP. Based on this review plus information from Byron Station personnel (who performed almost an identical SGRP in 1997), procedure changes were identifie (2) The identified procedure changes were then entered onto a computerized spreadsheet for tracking purposes. All procedure changes were identified approximately six months prior to the start of the SGRP outag (3) The identified procedure changes were then forwarded to the procedure owners / reviewers to markup the actual changes to the procedure l 6 1 L .

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(4) The marked up actual procedure changes were then forwarded to clerical personnel for typing of the new draft procedures. This step occurred approximately four months prior to the start of the SGRP outag (5) The new draft procedures were reviewed by the procedure owners / reviewer (6) A second technical /onsite review was then conducted. Following this review, the new procedures were placed in a hold status, until the SGRP outage was completed. All revised procedures were on hold awaiting the completion of the SGRP approximately one month prior to the start of the SGRP outag (7) Feedback on the new procedures has been gathered from !! censed operators and instructors during simulator training exercise Conclusions Procedure changes associated with the SGRP appeared to have been properly identified and implemented. The new proposed procedures appeared to accurately

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reflect the effects of the SGRP for Unit 1. The process for conducting the procedure changes also appeared to be sound. Changes to plant procedures were properly identified, tracked, and completed in a timely fashio Operator Knowledge and Performance 04.1 Operator Knowledoe and Performance Associated with the SGRP Insoection Scoce (50001)

The inspector observed the performance of four operating crews during the conduct of SGRP simulator training exercises. These exercises included low power feedwater manipulations, steam breaks, SG tube ruptures, and loss of coolant accidents. In addition, the inspector interviewed two licensed operators to assess their level of knowledge on a variety of SGRP topic Observations and Findinos Ooerator Performance Each operating crew consisted of the following five personnel: a Shift Manager, a Shift Technical Advisor, a Unit Supervisor, and two Nuclear Station Operators. The performance of each crew was observed during the conduct of SGRP simulator training, which consisted of the following four exercises per crew: (1) feedwater system operation at low power, (2) a steam line break, (3) an SG tube rupture, and (4) a small break loss of coolant accident. Based on the observed exercises, the inspector noted no major deficiencies in crew performance. In general, the observed crews demonstrated proper annunciator and alarm response, adequate diagnosis of off normal conditions, adequate plant and system knowledge, correct procedural use, accurate and timely control manipulations, and a questioning attitude toward new procedure steps and

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control board changes. However, one weakness was observed in the area of communications. The inspector observed that most of the observed crew members l occasionally did not refer to plant equipment by the appropriate unit designator. For l example, following a reactor scram on Unit 1, one Nuclear Station Operator directed a local operator to check on the diesel generators vice directing a check on the Unit 1 diesel generator i Ooerator Knowledae The inspector interviewed two licensed operators, who had already completed the l SGRP training associated with the current training cycle. One operator interviewed was i a licensed reactor operator, who typically performed control room duties. The other operator interviewed was a licensed senior reactor operator, who typically performed duties related to drafting out of services. During the course of each interview, the I inspector asked each operator the following six questions:

(1) Describe the piping and valve changes to the Unit 1 feedwater system l associated with the SGR l l

(2) Describe control board changes associated with the SGR (3) Describe the thermal-hydraulic changes associated with the new SG (4) How are transients affected by the new SGs? (steam break, shrink / swell, tube rupture)

(5) Describe the changes to plant heatup and startup as a result of the SGR (6) What is the major effect of the new SGs on the emergency operating procedures? ,

Both operators interviewed provided satisfactory responses to all six of the above questions. The inspector noted no deficiencie c. Conclusions Operator performance observed during the SGRP simulator training exercises was generally good. In general, the observed crews demonstrated proper annunciator and alarm response, adequate diagnosis of off normal conditions, adequate plant and system knowledge, correct procedural use, accurate and timely control manipulations, and a questioning attitude toward new procedure steps and control board changes. In addition, operator level knowledge concerning the impacts of the SGRP was also goo However, during the simulator exercises one weakness in operator performance was observed in the area of communications. The inspector observed that occasionally crew members did not refer to plant equipment by the appropriate unit designato . .-

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05 Operator Training and Qualification l

05.1 Ooerator Trainina Associated with the SGRP Insoection Scooe (50001)

The inspector interviewed licensee training staff personnel and reviewed licensee provided training cycle plans and lesson plans, to determine the content, development, implementation, and quality of training associated with the SGRP. The inspector also

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, interviewed licensed operators, who were the recipients of the SGRP training, to gain

additional insights on the content and quality of the training. Finally, the inspector l observed licensee training staff personnel and licensed operators during a portion of the l cycle 6 SGRP simulator training exercises and classroom instructio Observations and Findinas I

Content of SGRP Trainina Training for licensed operators concerning the SGRP was distributed over four training cycles: cycle 6 of 1997, and cycles 3,4, and 6 of 1998. Cycle 6 of 1998 was the first cycle which utilized the control room simulator configured with the SGRP simulator modification During cycle 6 of 1997 (October-November 1997), SGRP training consisted of the presentation of an approximately one hour videotape which documented the major steps involved in replacing SGs. This video was an overview of the SG replacement process

- and did not focus on the specific plant changes that would occu in cycle 3 of 1998 (April-May 1998) an approximately 1.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> classroom presentation was conducted conceming SG replacement unit differences. This presentation focused on changes associated with the Uniti SGRP in the following areas:- (1) SG configuration (number of SG tubes, feedwater entry point, etc.); (2) feedwater system configuration and operation; (3) SG water level span; (4) addition of the wet layup system; and (5) control panel configuration. The associated lesson plan, "SG Replacement Outage Unit Differences," was well written and contained an appropriate level of detail. However, one weakness observed with this lesson plan was the fact that

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it contained only one all encompassing learning objective " Review SG Replacement Outage Unit Differences." Such an all encompassing learning objective did not aid in focusing student attention and it made it difficult to determine the appropriateness and l' effectiveness of the trainin In cycle 4 of 1998 (June-July 1998) an approximately two-hour classroom presentation was conducted concerning the SGRP procedure changes. This presentation consisted of the following SGRP-related subjects: (1) a review of some of the subject matter-presented in cycle 3 of 1998; (2) a list and discussion of new set points; (3) a discussion of the changes to normal operating (plant startup, plant heatup, power ascension, plant shutdown, and feedwater system) procedures; and (4) a discussion of the changes to l emergency operating procedures (EOPs). The associated lesson plan,"SGRP j

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. 1 Procedure Changes," was well written and contained an appropriate level of detai However, similar to the previously discussed lesson plan, this lesson plan also contained the same weskness of utilizing only one all encompassing learning objective. For this lesson plan, its sole learning objective was to " discuss the changes to procedures affected by the SGRP." Such an all encompassing learning objective did not aid in focusing student attention and it made it difficult to determine the appropriateness and

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effectiveness of the trainin ;

I in cycle 6 of 1998 (October-November 1998) both classroom instruction and simulator '

exercises were utilized for training on the new SGs. Classroom instruction consisted of two separate lessons. The first lesson was an approximately two-hour presentation on the special testing that would be conducted following the SG replacement outage. The )

second lesson was an approximately 2.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> presentation on changes to EOPs. This second lesson was somewhat different from the cycle 4 presentation on EOPs, in that during this lesson the new EOPs were reviewed, and all new changes were discussed, I including those not associated with the SGRP. One cycle 6 EOP classroom session I was observed by the inspector. No major deficiencies with the presentation were identified. The instructor presented the material in a clear and logical manner, and the operating crew members asked many questions and actively participated in the presentation. The supporting lesson plans for both presentations were well written and i appeared to contain an appropriate amount of detail. However, similar to the previnus I I

finding, one weakness of the lesson plans was observed, in that they only contained all encompassing learning objectives. More definitive learning objectives would assbt in focusing student attention and in determining the appropriateness and effectiveness of ,

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SGRP simulator training for cycle 6 was divided into basically five different exercises:

(1) an introduction and walkthrough of the control panel changes, (2) low power feedwater system operations, (3) a steam line break, (4) an SG tube rupture, and (5) a small break loss'of coolant accident. During the observed simulator exercises no i deficiencies with the training were identified. The instructors presented the material in a clear and logical manner, and the operating crew members asked many questions and actively participated in the exercises. Post exercise critiques of operator performance were also effective. Charts and diagrams used to accompany the simulator training were clear and easy to read. Learning objectives for the simulator exercises appeared to be properly develope Process Used for Develooina and implementina SGRP Trainino Based on interviews with members of the licensee's training staff, the inspector identified that the following steps were utilized to develop and implement SGRP training:

(1) Training needs were identified by ihe training staff, utilizing inputs from the licensee's procedure, operations, and engineering groups. In addition, training needs were also identified using information from Byron Station personnel (who performed almost an identical SGRP in 1997).

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(2) Based on the identified training needs, training request forms were initiated and tracked via a computerized databas (3) Based on input from the licensee's operations staff, the SGRP training content was broken down into smaller parts (description of overall changes, procedure changes, set point changes, etc.) with some repetition between part (4) Lesson plans, simulator exercise guides, and learning objectives were then developed. Additionally, an implementation schedule was determine (5) SGRP training was then conducted, primarily in cycles 3,4 and 6 of 199 Two weaknesses in the above training process were identified by the inspector. The first weakness, which was previously discussed, was the use of all encompassing learning objectives, such as " describe SG differences" or " describe procedure changes associated with the SGRP." The second weakness was that the licensee's training staff did not initially have a plan in place to evaluate student mastery of the SGRP training material, prior to the operation of Unit 1 with the new SGs. Throughout the above l

mentioned training cycles, no written exam questions or evaluated simulator exercises ;

were used to evaluate the knowledge and ability of licensed plant operators concerning the subject matter of SGRP training. The licensee initially planned to conduct ,

evaluations, which would have included some SGRP training material, beginning in l 1999. It appeared to the inspector that since the SGRP was a highly significant and 1 complex modification, that some form of student evaluation shou!d be conducted prior to l the restart of Unit 1. The licenseo planned to administer a 15 question written exam, covering SGRP training material, to alllicensed operators. This exam was scheduled to be administered prior to the restart of Unit c. Concluslom Overall, the training associated with the SGRP was good. The overall content of the SGRP training program appeared appropriate. The instructors did a good job in presenting the training material, and the operating crew members actively participated in the training. Post execise critiques of operator performance in the simulator were also effective. The conclusion that the training was good was further supported by the good operator knowledge and performance concerning SGRP topics discussed in section 04.1. However, two weaknesses with the training were observed. The first weakness was the use of all encompassing vice definitive leaming objectives. The second weakness was the lack of a well-defined plan for evaluating student mastery of SGRP training material prior to the restart of Unit 1 with the new SG I1

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V. Mananoment Meetinas  ;

. X1 Exit Meeting Summary i

The inspector presented the inspection results to members of licensee management at the ,

conclusion of the inspection on November 10,1998. The licensee acknowledged the findings l presented. The inspector asked the licensee whether any materials examined during the '

inspection should be considered proprietary. No proppetary information was identifie )

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PARTIAL LIST OF PERSONS CONTACTED Licensee T. Tulon, Site Vice President K. Schwartz, Station Manager R. Wegner, Operations Manager T. Simpkin, Regulatory Assurance Supervisor J. Walkur, Training Manager F. Cerovac, Operations Training Superintendent M. Cassidy, Regulatory Assurance - NRC Coordinator NRC M. Jordan, Chief, Reactor Projects Branch 3 M. Leach, Chief, Operations Branch Region 111 C. Phillips, Senior Resident inspector D. Pelton, Resident inspector INSPECTION PROCEDURES USED IP 50001: Steam Generator Replacement inspection IP 41500: Training and Qualification Effectiveness IP 71001: Licensed Operator Requalification Program Evaluation ITEMS OPENED, CLOSED, AND DISCUSSED Opened NONE i GosgLd NONE I i

Discussed l NONE

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. LIST OF ACRONYMS USED EOP Emergency Operating Procedure RCS Reactor Coolant System RCS Tave Average Reactor Coolant System Temperature SG Steam Generator SGRP Steam Generator Replacement Project a

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