IR 05000456/1998019

Insp Repts 50-456/98-19 & 50-457/98-19 on 981027-30.No Violations Noted.Major Areas Inspected:Licensee Implementation of 10CFR50.65 Requirements for Monitoring Effectiveness of Maintenance at Nuclear Power Plants

ML20196C432
Person / Time
Site:	Braidwood
Issue date:	11/25/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20196C359	List: IR 05000456/1998019 ML20196C350
References
50-456-98-19, 50-457-98-19, NUDOCS 9812020050
Download: ML20196C432 (9)

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U.S. NUCLEAR REGULATORY COMMISSION I

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REGION lli l Docket Nos: 50-456;50-457 License Nos: NPF-72; NPF-77 i

Report Nos: 50-456/98019(DRS); 50-457/98019(DRS) I i

i Licensee: Commonwealth Edison (Comed)

I Facility: Braidwood Nuclear Power Station, Units 1 and 2 Location: RR #1, Box 79 I Braceville,IL 60407 Dates: October 27-30,1998 Inspector: Andrew Dunlop, Reactor Engineer Approved by: James A. Gavula, Chief Engineering Specialists Branch 1 Division of Reactor Safety

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EXECUTIVE SUMMARY '

Braidwood Nuclear Power Station, Units 1 and 2

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NRC Inspection Reports 50-456/98019(DRS); 50-457/98019(DRS)

This inspection included a follow-up review of the licensee's implementation of 10 CFR 50.65,

" Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." The report covers a 3-day on-site inspection by a regionalinspecto The program met the requirements of the maintenance rule (MR) and concerns and open issues identified during the baseline inspection were adequately resolve Maintenance

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The guidance procedures for performing periodic assessments met the requirements of the MR. The completed assessment was more oriented toward providing guidance on

how to perform the assessment versus evaluation of MR activities, such that it did not

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provide a good assessment of the effectiveness of maintenance activities. Although similar guidance was used, it was implemented significantly different at Byron and Braidwood. The assessment recommendations were broad based and identified areas where further actions or guidance were needed to improve the process. (Section M1.3)

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Performance criteria were properly established to resolve concerns with the auxiliary building floor drain system and the four systems that inappropriately used plant level performance criteria. (Section M8.2)

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Goals and corrective action plans for systems classified as (a)(1) were good. Actions taken to address the concern with monitoring system performance appeared to be effective. The structural monitoring program was effective in that the inspections adequately assessed the conditions of structures and corrective actions were initiated to correct deficiencies. (Section M1.6)

Quality Assurance

. The assessment provided independent insights into the MR program and identified severalissues to improve the MR process. (Section M7.1)

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B_eport Details Summarv of Plant Status Unit 1 remaine') in a steam generator replacement outage, while Unit 2 was operating at approximateY 100 percent power during the inspectio II. Maintenance M1 Conduct of Maintenance (62706)

M1.3 fa)D) Periodic Evaluations Insoection Scope Paragraph (a)(3) of the maintenance rule (MR) requires that performance and condition monitoring activities, associated goals, and preventive rnaintenance activities be evaluated, taking into account were practical, industry-wide operating experience. This evaluation was required to be performed at least one time during each refueling cycle, not to exceed 24 months between evaluations. The inspector reviewed the July 1996 through December 1997 periodic assessment and the procedural guidelines for this evaluatio Observations and Findinas The guidance for conducting the first periodic assessment was contained in procedure BwAP 2300-2, Attachment J," Periodic Assessment of the Maintenance Rule." The procedure provided adequate guidance for what needed to be addressed in a periodic assessment. Although the assessment followed the licensee's guidance in most cases and was considered acceptable, there was minimal discussion on evaluation results, but rather on the process used for performing the assessment. For example, the area on plant level performance criteria did not discuss if any criteria were exceeded and which structure, system, or component (SSC) contributed to the cause. The corporate assessment also indicated that the periodic assessment did not always follow the guidance and that information was not succinctly summarized. The number of significant changes to the program that occurred at the end of the assessment period added to the difficulties to document the effects of the MR program. One positive aspect of the assessment was he number and types of recommendations that were identified. These recommendations were broad based and identified areas where further actions or guidance were needed to improve the proces Subsequent to the licensee's assessment, Comed corporate issued a new procedure to provide guidance for performing assessments, NSP-ER-3011, " Maintenance Rule Periodic Effectiveness Assessments," for all operating facilities to follow. A review of the l procedure determined that it followed the same structure as Braidwood's completed l assessment. The guidance was flow chart based, which documented each area

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required to be assessed and who was the responsible individual. Corporate guidance will be used during the next periodic assessment. The corporate guidance, however, provided little guidance on how these areas should be assessed. For instance, although the Byron and Braidwood assessment guidance was very similar on areas to assess, how the stations met the procedural guidance was significantly different. The Corporate procedure was issued to provide consistent guidance to all Comed facilities on performing periodic assessments; however, additional guidance may be warranted on how areas should be assessed to produce consistent and meaningful result Conclusions The guidance procedures for performing periodic assessments met the requirements of the MR. The completed assessment was more oriented toward providing guidance on how to perform the assessment versus evaluation of MR activities, such that it did not provide a good assessment of the effectiveness of maintenance activities. Although similar guidance was used, it was implemented significantly different at Byron and Braidwood. The assessment recommendations were broad based and identified areas where further actions or guidance were needed to improve the proces l M1.4 (a)(3) Balancina Reliability and Unavailability l Insoection Scope i

Paragraph (a)(3) of the MR requires that adjustments be made where necessary to i

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ensure that the objective of preventing failures through the performance of preventive maintenance (PM) was appropriately balanced against the objective of minimizing unavailability due to monitoring or P ) Observations and Findinas l Balancing of reliability and availability was performed as part of the periodic assessmen Balancing was performed for (a)(1) systems by reviewing which criteria were exceede If unavailability was exceeded then the following was reviewed to determine what ar.tions I

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could be incorporated: the PM program evaluated to delete ineffective PMs, change PM frequency, or combine PM activities; use of non-intrusive maintenance activities that do not contribute to unavailability; PM or surveillance procedure changes to reduce unavailability; and evaluate increasing allowed functional failures (FFs). If reliability was I exceeded then the following was reviewed: the PM program evaluated to add PMs or l change PM frequency to address failures, determine if there were applicable PMs that may predict oncoming failures; and evaluate increasing allowed unavailability. For (a)(2)

systems, significant differences in actual unavailability from the performance criteria l

were reviewed for potential program changes. The periodic assessment diu not indicate if any performance criterion was determined to be unbalanced. A review of several (a)(1) action plans indicated that there were reviews to change certain maintenance activities, although they were not documented in the periodic assessmen '

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i Conclusions

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The guidance for balancing of availability and reliability was acceptable and performed as part of the periodic assessment and the goal establishment process, although evaluation documentation in the periodic assessment was minima M1.6 (a)(1) Goal Settina. SSC Monitorina and Structural Monitoring Insoection Scoce The inspectors reviewed program documents in order to evaluate the processes established to set goals and monitoring SSC performance under the MR. In addition, the results of structural baseline walkdowns were reviewed. The inspector also discussed the program with appropriate plant personne Observations and Findinas for Goals Established for (a)(1) SSCs:

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Appropriate goals and monitoring were established for the SSCs class!fied as (a)(1).

Corrective actions planned for (a)(1) SSCs appeared to be appropriate to improve performance and address the problems that led to the (a)(1) classification. The goals and action plans were well-documented and tracked through completion. In one case, the control room ventilation system, which had been classified as (a)(1), had been appropriately returned to (a)(2) status after corrective actions were completed and SSC i

performance met the established goal Observations and Findinas for Monitorina SSCs:

An issue from ine baseline inspection concerned the licensee's effort to effectively monitor system performance. Numerous examples were identified where FFs were not properly monitored for the applicable SSC. A similar concern was also identified during the recent corporate assessment, where potential FFs were included in the CAPSYS data base, but not in the MR data base. The licensee performed an extensive review of problem identification forms (PlFs), which revealed several FFs not previously identifie In addition, the program was revised to include reviews of action requests and work requests to identify FFs not captured by the PlF process. The licensee was also planning on interconnecting the CAPSYS data base, which included all PIFs, with the MR data base such that issues identified during the corporate assessment do not reoccur. The inspector reviewed the 1998 action requests, work requests, and PlFs for the control room ventHation system and the diesel fuel oil system. No missed FFs were identified. Although recent concerns were identified in this area, sufficient licensee actions have been taken to resolve the inspector's concern Observations and Findinas on Structure Monitorina A number of structural baseline walkdowns were completed since the baseline MR inspection, while the remaining baseline walkdowns were scheduled with completion l

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dates in 1999. The walkdowns performed were thorough and problems were adequately documented. Correctivo actions were implemented or planned to addressed the identified problem Conclusions Goals and corrective action plans for systems classified as (a)(1) were good. Actions taken to address the concern with monitoring system performance appeared to be effective. The structural monitoring program was effective in that the inspections adequately assessed the conditions of structures and corrective actions were initiated to correct deficiencie M7 Quality Assurance in Maintenance Activities (40500)

M7.1 Licensee Self-Assessments of the Maintenance Rule Proaram Insoection Scope The inspectors reviewed the Braidwood Maintenance Rule Baseline Follow-up Readiness Assessment performed by Comed corporate dated September 2,1998, and subsequent responses by the licensee to the assessment's finding Observations and Findinas The purpose of the assessment was to ensure adequate preparation for the MR follow-up inspecSon. The assessment identified several findings and recommendations, some of which were concerns also identified during this inspection. Corrective actions for the findings were implemented or planned, Conclusions The assessment provided independent insights into the MR program and identified several issues to improve the MR proces M8 Miscellaneous Maintenance issues M8.1 (Closed) Inspection Follow-uo item 50-456/457-97018-02(DRS1: This issue concerned not having completed a periodic assessment as required by (a)(3) of the MR prior to the baseline inspection. Based on the completion of an assessment as discussed in sections M1.3 and M1.4 of this report, this issue is close M8.2 (Closed) Violation 50-456/457-97018-03(DRS): This violation concerned the failure to establish appropriate reliability performance criteria for the auxiliary building floor drains system and the inappropriate use of plant level performance criteria for the following four systems: communications (Function CQ-01); turbine over-speed protection (Function EH-03); cathodic protection (Function GD-01); and digital rod position indication

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(Function PI-01). The licensee response to the violation was documented in a letter l

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dated February 27,1998. Based on the violation, the licensee revised the reliability performance criteria for the auxiliary building floor drains system and established specific i performance criteria for the other four systems. The inspector determined the revised !

- criteria to be acceptable. This issue is close l M8.3 (Closed) Insoection Follow-uo item 50-456/457-97018-04(DRS): This issue concerned functional failures not always properly monitored through the MR program. Based on the i discussion in section M1.6.b.2 of this report, this issue is close !

V. Manaaement Meetinos i

X1 Exit Meeting Summary i

L The inspector discussed the progress of the inspection with licensee representatives and )

presented the inspection results to members of licensee management at the conclusion of the .

inspection on October 30,1998. The licensee acknowledged the findings presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary; none was identifie l

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PARTIAL LIST OF PERSONS CONTACTED Licensee M. Cassidy, Regulatory Assurance - NRC Coordinator L. Guthrie, Maintenance l A. Javorick, Corporate Systems Engineering Chief J. Kuchenbecker, System Engineering Supervisor J. Nacewajica, Assessment Manager

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M. Riegel, Nuclear Oversight Manager A. Ronstadt, Station Maintenance Rule Coordinator l

M. Strait, Corporate Maintenance Rule Engineer T. Simpkin, Regulatory Assurance Manager R. Skowzgird, System Engineering l

, D. Skoza, System Engineering l l T. Tulon, Site Vice President LIST OF INSPECTION PROCEDURES USED IP 62706: Maintenance Rule LIST OF ITEMS OPENED, CLOSED AND DISCUSSED l

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50-456/457-97018-02(DRS) IFl Periodic Assessment Not Completed 50-456/457-97018-03(DRS) VIO Inappropriate use of Reliability and Plant Level Performance Criteria l 50-456/457-97018-04(DRS) IFl Functional Failures Not Always Properly Monitored l

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LIST OF ACRONYMS USED Comed Commonwealth Edison ,

CFR Code of Federal Regulations DRS Division of Reactor Safety

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FF Functional Failure '

IFl Inspection Follow-up Item '

IP inspection Procedure MR- Maintenance Rule NUMARC Nuclear Management Resource Council NRC Nuclear Regulatory Commission PIF Problem Identification Form PM Preventive Maintenance SSC Structure, System, or Component VIO Violation

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LIST OF DOCUMENTS REVIEWED i i

BwAP 2300-2, " Maintenance Rule," Revision 7, September 16,1998 COMED Procedure NSP-ER-3011," Maintenance Rule Periodic Effectiveness Assessments,"  ;

Revision 0, July 3,1998

Braidwood Maintenance Rule Baseline Follow-up Readiness Assessment, September 2,1998 Braidwood Maintenance Rule Database, October 26,1998 Braidwood Station Maintenance Rule Periodic Assessment, July 1,1996 - December 31,1997, March 16,1998 Reply to Notice of Violation Letter NRC Inspection Report No: 50-456(457)/97018, February 27,

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t internal Memorandum,"Braidwood Response to the Maintenance Rule Baseline Follow-up Readiness Assessment," September 21,1998

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l Problem Identification Form A1998-03089 l

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