IR 05000456/1998020
ML20198R085 | |
Person / Time | |
---|---|
Site: | Braidwood ![]() |
Issue date: | 12/30/1998 |
From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
To: | |
Shared Package | |
ML20198R078 | List: |
References | |
50-456-98-20, 50-457-98-20, NUDOCS 9901080083 | |
Download: ML20198R085 (24) | |
Text
E
.-
,-
i U.S. NUCLEAR REGULATORY COMMISSION REGIONlli l
P Dock'et Nos:
50-456,50-457 License Nos:
,
L Report No:
50-456/98020(DRP); 50-457/98020(DRP)
Licensee:
Commonwealth Edison Company
.
Facility:
Braidwood Nuclear Plant, Units 1 and 2 Location:
RR #1, Box 84
,
Bracoville,IL 60407
_
L-Dates:
October 20 through December 7,1998 l
Inspectors:
C. Phillips, Senior Resident Inspector l-J. Adams, Resident inspector D. Pelton, Resident inspector
'
J. Roman, Illinois Department of Nuclear Safety i
h Approved by:
Michael J. Jordan, Chief
-
. Reactor Projects Branch 3 i
l lo
.
k
.
9901000083 981230 f.
PDR ADOCK 05000456 I
.
G PDR.
L (.
-. _.
_ _ _
,
.
-
-
..
- -
--.
-
!
,
.
i l
l j
EXECUTIVE SUMMARY l
,
Braidwood Nuclear Plant, Units 1 and 2 t
'
NRC Inspection Report 50-456/98020(DRP); 50-457/98020(DRP)
l i
This inspection included aspects of licensee operations, maintenance, engineering, and plant support. The report covers a 7-week period of resident inspection from October 20 through December 7,1998.
Operations
'On November 12,13, and 14, the inspectors observed the startup of Unit 1 following
-
refueling and the replacement of steam generators. The inspectors concluded that the heightened level of awareness briefing for the Unit 1 startup was well performed. The inspectors concluded that the unit supervisor demonstrated good command and control i
and provided good oversight of the nuclear station operators in the Unit 1
"at-the-controls" area. However, the inspectors observed periods in the control room where the level of formality declined and were concerned that operations supervision l
failed to recognize and correct the decline until identified by the inspectors.
(Section 01.1)
On November 30, inspectors observed a shutdown of Unit 1 to repair a failed heater
drain tank rupture disc, and on December 3, the inspectors observed the Unit 1 startup following the completion of repairs. The inspectors concluded that the operators performed the power descension, shutdown, and startup well and in accordance with the applicable procedures. (Section O1.2)
The inspectors reviewed the licensce's preparations for cold weather operation and
concluded that station's safety-related equipment was configured !n accordance with the freezing weather protection surveillance procedure. The Braidwcod Operating Surveillance XFT-A1," Freezing Temperature Equipment Protection Annual Surveillance," appeared adequate to assure protection of safety-related equipmcat from cold weather. (Section O2.1)
The licensee identified at least five recent configuration control errors where four
breakers or switches were found in the incorrect position and one circuit card that was found improperly configured. The most significant was a mispcsitioned breaker for the 2A containment spray pump cubicle cooler fan 2D resulted in the inoperability of the 2A containment spray pump, a safety-related pump. The licensee was able to determine that the limiting condition for operation identified in the Technical Specifications was not exceeded, but was unable to determine a cause for any of these events. (Section 04.1)
The inspectors concluded that Nuclear Oversight personnel performed a thorough,
accurate, and critical assessment of the recent performance of the operating department. (Section O7.1)
!
i
l
.
.
Maintenance On November 8, the inspectors performed a closeout inspection of the Unit 1
-
l containment. The inspectors concluded containment cleanliness was excellent and had improved when compared to previous containment closecut inspections. The inspectors concluded that the problems identified during the inspection were few in number and
,
l had minor safety significance. (Section M1.1)
While reviewing surveillance testing, in response to Generic Letter 96-01, the licensee
-
identified a failure to perform testing required by Technical Specifications of safety-related contacts associated with the suction swap-over of emergency core cooling system and auxiliary feedwater pumps. The inspectors concluded that the licensee took appropriate actions by entering Technical Specification 4.0.3 and by testing the contacts within 24-hours. The inspectors also concluded that the subsequent prompt testing performed was appropriate to ensure the contacts were able to perform their safety-related functions. This issue will remain open pending receipt and analysis of Licensee Event Report 50-456/98006-00. (Section M1.2)
The inspectors performed an assessment of the performance of the Unit 1 steam
-
generator replacement project and concluded that the licensee effectively incorporated the lessons learned from the Byron steam generator replacement project, generally maintained excellent performance in all areas of the project, and demonstrated a strong safety focus throughout the project. (Section M1.3)
The inspectors concluded that the integrated leakage rate test performed on the Unit 1
-
containment was performed in accordance with 10 CFR Part 50, Appendix J, and that the results satisfied the Technical Specification acceptance criteria. The inspectors discovered errors with the acceptance criteria used in five Type B and C leak rate tests but concluded that these errors were of a minor nature. (Section M1.4)
The inspectors observed the performance of five surveillance tests. The imectors
-
concluded that the surveillance tests adequately tested the system, the opMors followed the procedures, and that the procedures included the required testmg discussed in the Technical Specifications. (Section M1.5)
The inspectors concluded that failure of the Unit 1 feedwater heater drain tank rupture
-
disc was due to an inadequate installation procedure and that the licensee's initial actions to determine and correct the cause of the event were cornmensurate with the significance of the event. (Section M1.6)
On October 24, the inspectors observed the movement of fuel from the fuel pool to the
-
containment building which was accomplished very well. The inspectors concluded that the fuel handling personnel complied with foreign material exclusion area requirements, established excellent fuel pool visibility, followed fuel handling procedures, updated status boards, established and maintained communications between the Unit 1 control room and the senior reactor operator in containment, used three-way communication l
techniques, performed triple independent verifications, and performed clear and concise turnovers to relieve fuel handlers. (Section M4.1)
,
l
.
.
Enaineerina The inspectors concluded that the operability determinations regarding the Unit 1
-
reactor containment fan cooler discharge check damper, Unit 1 safety injection check valves 1SI-8819A/B/C/D, and Unit 1 and 2 boron dilution prevention system reflected good engineering jddgement and safety focus. The compensatory actions were understood by operations personnel. (Section E1.1)
On November 11,1998, the licensee declared the Units 1 and 2 boron dilution
-
prevention systems inoperable due to an error discovered by the vendor in the computer code used to model the system's response during accident conditions. The inspectors concluded that the licensee took the appropriate and conservative actions to address the inoperability of the boron dilution prevention system. The inspectors concluded that the licensee properly implemented the Technical Specifications required compensatory actions for the boron dilution prevention system during a recent shutdown l
of Unit 1. This issue will remain open pending receipt and analysis of Licensee Event Report 50-456/98007-00. (Section E1.2)
Plant Support The inspectors concluded that radiation protection technicians promptly cleaned and
)
-
released contaminated areas in the auxiliary building following the Unit i refueling and j
steam generator replacement outage, A1R07. Solid radioactive wastes generated i
during the decontamination of equipment were promptly removed from decontamination areas and delivered to solid radioactive waste processing areas. Solid radioactive wastes were promptly processed and shipped to disposal sites. The wastes that remained on site were appropriately laoeled and properly stored. (Section R1.1)
-
.
_ _
. _.
, _ _ _
-
-
-.
.. --
--
.-
-
..
-
-.
.
.
Report Details Summary of Plant Status Unit 1 entered the period shutdown for refueling and for the replacement of steam generators.
Unit 1 started up and synchronized to the grid on November 14, reaching full power on November 24, where it operated until November 30 when a heater drain tank rupture disc failure required the unit to be shutdown for repair. On December 3, Unit 1 was restarted and synchronized to the grid reaching full power on December 4. Unit 1 ended the period operating at or near full power. Unit 2 operated at or near full power for the entire period.
l. Operation _s
Conduct of Operations O1.1 Unit 1 Startuo From Refuelina and Steam Generator Replacement Outcae A1R07 a.
Inspection Scoca (71707. 71711. 50001)
On November 12,13, and 14, the inspectors observed the startup of Unit 1 following refueling and the replacement of steam generators. The inspeciors observed the licensee's pre-evolution briefings and startup activities. The inspectors reviewed Unit 1 Braidwood General Operating Procedure (1BwGP) 100-1, " Plant Heatup," Revision 13; 18wGP 100-2," Plant Startup," Revision 12E1; and Braidwood Engineering Surveillance Procedure (BwVS) 500-6, " Low Power Physics Test Program with Dynamic Rod Worth Measurements," Revision 1E1.
b.
Observations and Findinas On November 12, the inspectors observed the heightened level of awareness briefing for the Unit 1 startup and noted that all necessary personnel were in attendance. The inspectors observed that the briefing contained a sufficient level of detail to properly perform the unit startup. The inspectors noted that the nuclear station operators had received just-in-time sirrulator training on the startup and physics testi.1g prior to the
' Unit 1 s'artup.
The inspectors observed the operators performing startup ectivities in the control room, noting that procedures were followed, proper three-way communication techniques were used, and peer and self-checks were performed. During the execution of the unit ctartup, operators wet t..ialienged by multiple digital rod position indication alarms, a leak in a flanged piping connection associated with the Unit 1 excess letdown heat exchsnger, an isolation of the Unit 1 component cooling water expansion tank head vent, and problems with the 1B feedwater pump speed control. The inspectors noted that the operators addressed these material condition problems in a conservative manner in accordance with established procedures.
I
!
l l
I
>
The inspectors noted that reactivity manipulations associated with reactor criticality, physics testing, and power ascension were precisely controlled, were directly supervised by a senior reactor operator, and were clearly communicated to the unit supervisor and i
nuclear engineers. However, a problem with the 1B feedwater pump required the need to swap feedwater pumps which resulted in a secondary plant transient of sufficient magnitude to affect the primary plant parameters. Prompt actions taken by the i
operatoJs limited the magnitude of the transient.
The insMetors noted that the Unit 1 unit supervisor demonstrated good command and control. The unit supervisor generally remained in the Unit 1 "at-the-controls" area of the control room and appeared to maintain an overall control room perspective.
Inspectors observed the presence of senior management in the control room during the performance of the startup.
The inspectors observed several examples of control room informality during startup activities. The inspectors observed operations personnel sitting on the control panel guard bars, personnel reaching across the control panels with full cups o,' coffee in-hand, and informal three-way communications between the control room and the field. During previous startup and shutdown activities, inspectors had noted exemplary conduct by operations personnel in the control room. The inspectors were particularly concerned with the failure of operations department supervisory personnel to recognized and promptly correct the decline in formality until identified by the inspectors, c.
Conclusions On November 12,13, and 14, the inspectors observed the startup of Unit 1 following refueling and the replacernent of steam generators. The inspectors concluded that the heightened level of awareness briefing for the Unit 1 startup was well performed. The inspectors concluded that the unit supervisor demonstrated good command and control and provided good oversight of the nuclear station operators in the Unit 1
"at-the-controls" area. However, the inspectors observed periods in the control room where the level of formality declined and were concerned that operations supervision failed to recognize and promptly correct the decline until identified by the inspectors.
01.2 Unit 1 Shutdown Due to Failed Heater Drain Tank Ruoture a.
Inspection Scope (71707)
On November 30, inspectors responded to the site to observe a shutdown of Unit 1 to repair e failed heater drain tank rupture disc. On December 3, the inspectors observed
,
the Unit 1 startup following the repair of the heater drain tank rupture disc. The l
inspectors reviewed 18wGP 100-2, " Plant Startup," Revision 12E1: 18wGP 100-4,
" Power Descension," Revision 12; and 18wGP 100-5, " Plant Shutdown and Cooldown,"
Revision 18.
r
!
_
.
b.
Observations and Findinos Oa November 30, inspectors observed a shutdown of Unit 1 to repair a failed heater drain tank ruptum disc (Section M1.6) and on December 3, the inspectors observed the Unit 1 startup following the completion of repairs. The inspectors attended the heightened level of awareness briefings for both the shutdown and the startup and determined that they met or exceeded management expectations and procedural requirements. The inspectors verified that the procedures were followed for the power descension, plant shutdown, and plant startup; three-way communications were used; peer and self-checks were performed; and reactivity manipulations were directly supervised.
c.
Conclusions On November 30, inspectors observed a sh'itdown of Unit 1 to repair a failed heater
'
drain tank rupture disc and on December 3, the inspectors observed the Unit i startup following the completion of repairs. The inspectors concluded that the operators performed the power descension, shutdown, and startup well and in accordance with the applicable procedures.
O2 Operational Status of Facilities and Equipment O2.1 Cold Weather Preoarations a.
Inspection Scoce (71714)
The inspectors verified the licensee actions taken to protect safety-related systems against cold weather. The inspectors reviewed Brcidwood Operating Surveillance (BwOS) XFT-A1, " Freezing Temperature Equipment Protection Annual Surveillance,"
Revision SE1.
b.
Observations and Findinas The inspectors reviewed the completed Surveillance Procedure OBwOS XFT-A1. The inspectors noted that the procedure adequately addressed safety-related equipment vulnerable to freezing conditions. The inspectors noted that the licensee verified equipment exposed to cold weather was protected from freezing. The licensee ensured that heat tracing and heating circuits were energized, and thermostats were properly set, c.
Conclusions The inspectors reviewed the licensee's preparations for cold weather operation and concluded that station's safety-related equipment was configured in accordance with the freezing weather protection surveillance procedure. Procedure BwOS XFT-A1,
" Freezing Temperature Equipment Protection Annual Surveillance," appeared adequate to assure protection of safety-related equipment from cold weather.
l l
. _.
_
_ __
_ _ _. -.
_
_
_
_
.
.-.
_ _ _ -
_
,
-
l
Operator Knowledge and Performance l
04.1 Continued Confiauration Control Problems a.
Inspection Scope (71707)
The inspectors interviewed station management and operators to evaluate the reasons behind and corrective actions for the most recent configuration control errors.
. b.
Observations and Findinas During this inspection period, configuration control problems continued to occur.
Between October 11,1998, and November 17,1998, the licensee identified four breakers or switches that were in the incorrect positions and one circuit card that was.
improperly configured. The Unit 2 station air compressor control switch was found in the
"off" position instead of the " standby" position; the 2B station heating pump control j
switch was found in the " pull-to-lock" position instead of the "on" position; the breaker for the motor actuator for extraction steam valve 2ES001 was found in the "off" position instead of the "on" position; the 2A containment spray pump room cooler fan 2D breaker
)
was found in the "off" position instead of the "on" position; and an improperly configured circuit card was discovered in the actuator for the Unit 1 charging flow control valve.
j The first three incidents were nonsafety-related. However, the 2A containment spray
'
pump was declared inoperable as a result of the improper breaker configuration and Unit 1 charging flow had to be controlled manually during startup due to the improperly configured circuit card. The licensee involved their security organization in the investigation of the mispositioned switches and breakers, but was unable to determine a cause for any of these events. The licensee determined that the length of time that the 2A containment spray pump remained inoperable did not exceed the Technical j
Specification allowed outage time of 7 days. The licensee also determined that the Unit 28 train of the containment spray system remained operable throughout this event.
c.
Conclusions The licensee identified at least five recent configuration control errors where four breakers or switches were found in the incorrect position and one circuit card that was found improperly configured. The most significant was a mispositioned breaker for the
- -
2A containment spray pump cubicle cooler fan 2D resulted in the inoperability of the 2A containment spray pump, a safety-related pump. The licensee was able to determine that the limiting condition for operation identified in the Technical Specifications was not exceeded, but was unable to determine a cause for any of these events.
,
I i
1.
.
-
,
A
_
_
-
_
_
_.
..
_
.. _. _ _ _ _ _ _
_.
_ _ __
Quality Assuranc3 in Operations 07.1 Nuclear Oversiaht Audit Of Operations a.
Inspection Scope (71707)
The inspectors intentiewed nuclear oversight auditors, attended the audit exit, and reviewed the audit report, b.
Observations and Findings The scope of the nuclear oversight audit of operations was thorough. The auditors
,
assessed performance rather than simply verifying compliance. Assessments of the j
areas audited were critical and accurate based on the information presented in the
report and at the exit meeting. A corporate senior vice president attended the exit meeting. The senior vice president challenged the auditors assessments and operations department management re.conses to the issues. This resulted in a better understanding of the issues and necessary corrective actions.
c.
Conclusions The inspectors concluded that Nuclear Oversight personnel perfbrmed a thorough, accurate, and critical assessment of the recent performance of the operating department.
'
Miscellaneous Operations issues (92901)
08.1 (Closed) Violation 50-456/97009-01(DRP): Inadequate procedure to drain the Unit 1 boric acid storage tank (BAST). An operator opened a drain valve for the Unit 1 BAST as directed by Braidwood Operating Procedure (BwOP) CV-24, " Draining the CV (chemical and volume control) System," and drained approximately 1900 gallons of borated water to the floor of the BAST room. The spilled water then leaked through a defective flood seal in the BAST room floor onto the Unit 2 diesel driven auxiliary feedwater pump rendering it inoperable. The BASTS were part of the CV system.
BwOP CV-24 was changed to include a reference to procedure Braidwood Administrative Procedure (BwAP) 340-9, " Venting and Draining of Components and Systems." Operators were also trained that the BASTS drain to the floor of the BAST rooms. In addition, the licensee repaired the flood seal in the BAST floor. The
,
j inspectors have no further concerns. This violation is closed.
l l
l
!
l e
I i
.
-
-
-
...
..-
-
._
.
.
lI. Maintenance M1 Conduct of Maintenance M1.1 Unit 1 Centainment Closeout a.
Inspection Scoce (61726. 60001)
The inspectors performed a closeout inspection of the Unit 1 containment and reviewed i
18wOS TRM 2.5.b.1, ' Unit 1 Containment Loose Debris inspection," Revision 0. The inspectors performed these activities after the licensee informed the inspectors that they i
had completed their close out inspection.
b.
Observation and Findinas On November 8, the inspectors performed a closecut inspection of the Unit 1 i
containment. The inspectors observed very little loose debris. However, four examples
)
of loose debris or equipment were identified during the inspection. Three small sections of sheet metal for pipe insulation were not properly banded and one small piece of steel l
'
plate was found taped to the floor on the 401 foot elevation. The inspectors determined that each of these examples had minor safety significance based on their location and small surface area relative to the surface area of the containment recirculation sump
)
screens.
The inspectors noted that the protective coating (paint) on the containment walls, equipment supports, reactor containment fan cooler ducting, and safety '.l mtion (SI)
accumulators was not peeling, flaking, or delaminating; the containmen......u.ation j
sump primary and secondary screens were free of debris; the modification to close gaps in the containment sump screen plates had been completed; and floor drains were free from debris and standing water.
The inspectors observed that scaffolding and temporary lighting had not been removed, sections of thermalinsulation had not been installed on the steam generators and j
reactor coolant pumps, and several deck plates in the steam generator coffins had not j
been installed. When questioned, the licensee informed the inspectors that the j
containment had been left in this condition to support hot gap measurements and the shtmming of the steam generatore nd reactor coolant pumps during the reactor coolant i
system heat up. The inspectors verified that the licensee had documented and tracked the removal of scaffolding and lighting, and the installation of thermalinsulation and
!
deck plates prior to entry into Mode 2 (startup).
L i
'
(
. c.
Conclusion
!
On November 8, the inspectors performed a closecut inspection of the Unit 1
containment. The inspectors concluded containment cleanliness was excellent and had improved when compared to previous containment closecuts inspections. The j
inspectors concluded that the problems identified during the inspection were few in number and had minor safety significance.
,
- l M1.2 Untested Safetv-Related Contacts on Unit 1 and Unit 2 a.
Insoection Scope (62707)
The inspectors reviewed:
Work Request (WR) 980121682-01, "1L-0930; Refueling Water Storage Tank
-
(RWST) Level Loop Verification of Lo-2 Contact";
j WR 980121683-01, "1L-0931; RWST Level Loop Verification of Lo-2 Contact";
-
WR 980121684-01, "1L-0933; RWST Level Loop Verification of Lo-2 Contact";
-
WR 980121685-01, "1L-0932 RWST Level Loop Verification of Lo-2 Contact";
-
WR 980121686-01, "2L-0930 RWST Level Loop Verification of Lo-2 Contact";
-
WR 980121687-01, "2L-0931 RWST Level Loop Verification of Lo-2 Contact";
i
-
WR 980121688-01, "2L-0932 RWST Level Loop Verification of Lo-2 Contact";
-
WR 980121689-01, "2L-0933 RWST Level Loop Verification of Lo-2 Contact";
-
Special test procedure (SPP)98-034, " Testing of the Unit 1 Auxiliary Feedwater
-
Train A and B Low Suction Pressure Relays PMF51X1 and PSAF55X"; and SPP 98-035, " Testing of the Unit 2 Auxiliary Feedwater Train A and B Low
-
Suction Pressure Relays PSAF51X1 and PSAF55X."
The inspectors interviewed system engineering, operations, and regulatory assurance personnel.
b.
Observations and Findinas
,
During a review of surveillance test procedures, in 'r,ponse to Generic Letter 96-01, the licensee identified safety-related electrical contacts that had not been tested as required by Technical Specifications Table 4.3-2, Functional Units 7.b and 6.g.
The contacts identified were associated with the automatic swap-over of emergency core cooling system pumps suction from the RWST to the containment sump due to low RWST level and the automatic swap-over of the auxiliary feed water pump suction from the condensate storage tank to the essential service water system due to low auxiliary feedwater suction pressure.
Once the licensee identified these untested contacts, Technical Specification 4.0.3 was
entered, testing procedures were developed, and the contacts were tested and determined to be operable within 24-hours. This issue will ren^in open pending receipt and analysis of Licensee Event Report 50-456/98006-00.
...._... _ ~ _. -. _ -. _ _._.~ _
. _.. _._. _
_ - _ _ _. _ _. _ _
m
.
c.
' Conclusions '
<
p
' While reviewing surveillance testing, in response to Generic Letter 96-01, the licensee identified a failure to perform tasting required by Technical Specifications of safety-related contacts associated with the suction swap-over of emergency core cooling system and auxiliary feedwater pumps. The inspectors concluded that the licensee took appropriate actions by entering Technical Specification 4.0.3 and by testing the contacts within 24-hours.; The inspectors also concluded that the subsequent prompt testing performed was appropriate to ensure the contacts were able to perform their i
safety-related functions. This issue will remain open pending receipt and analysis of
>
Licensee Event Report 50-456/98006-00.
M1.3 Assessment of the Unit 1 Steam Generator Replacement Project
a.
Inspection Scooe (50001)
The inspectors observed the performance of various steam generator replacement activities; interviewed system engineering, operations, radiation protection and contractor personnel; and reviewed station procedures and drawings.
- b.
~. Observations and Findinas
.
-
r The inspectors performed an assessment of the licensee's performance during the
. Unit i steam generator replacement and considered it to have been excellent, demonstrating good safety focus.
The inspectors observed effective control of contractor personnel including good use of -
mock-up' training, effective problem resolution with strong interface between the ~
contractor's and the licensee's corrective actions programs, effective controls used
~
- during tvelding and grinding operations, effective use and control of temporary services
.
L
~ (e.g., temporary power supplies, transformer installations, scaffolding, etc;) and the
> proper use of station procedures and drawings during work on steam generator j
i supports, restraints, piping, and instrumentation removal and reinstallation.
The inspectors observed the shutdown of Unit 1. The inspectors concluded that
,
shutdown was properly conducted. This had been previously documented in NRC l.
- Inspection Report 50-456/457/98012(DRP).
L l
1 The inspectors observed the foreign material exclusion (FME) controls employed while L
the reactor vessel, reactor coolant system,? main steam system, and feedwater system j
' were breached. The inspectors concluded that the licensee demonstrated good safety
<
.
(
' focus by identifying and taking action on a potential trend in the number of FME b
problems. The inspectors had previr,usly documented this in NRC Inspection -
[
Report 50-456/457/98014(DRP).
h The' inspector's observed effective coordination and communication during the
'
movement of the old and the replacement steam generators both inside and outside the
>
L s
. -
_..
p
',,
.
I'? I
..
.
>
-
-u
> e.;; '
_
.
.__,u.
-
,
-. -..
_,
__
_ _._._.
. _ _
_..,
. ~..
-.. -.. - _...
.-
.-.- -.-._ - -.- - -. - -.. - -
. -.
l
.
.
containment building. Project team personnel frequently briefed the residents office on rigging configuration and controlissues both from a platining perspective and when problems were encountered.
The inspectors observed the close-out of the Unit 1 containment, radiological clean-up
' efforts, performance of the integrated leakage rate testing, start-up of Unit 1, and testing of the replacement steam generators and considered these evolutions to have been well l
conducted. These areas are discussed in detail elsewhere in this report.
!:
. Conclusions -
.
i c.
l The inspectors performed an assessment of the performance of the Unit 1 steam l
L generator replacement project and concluded that the licensee effectively incorporated the lessons learned from the Byron steam generator replacement project, generally maintained excellent performance in all areas of the project, and demonstrated a strong l
safety focus throughout the project.-
M1.4 intearated Leakaae Rate Testino of the Unit 1 Containment Buildino a.
Insoection Scope (61715. 70307. 70313L 70323)
'The inspectors reviewed:
1BwVSR 3.6.1.1.lLRT," Unit 1 Primary Containment Type A Integrated Leakage
-
Rate Test (ILRT)," Revision 3;
= 1BwOSR 3.6.1.1-1, " Primary Containment Type B Local Leakage Rate Test
-
. (LLRT) of Zone 1 Electrical Penetrations," Revision 1; 1BwOSR 3.6.1.1-5, " Primary Containment Type B LLRT of Fuel Transfer Tube
-
Penetration and Fuel Transfer Tube Sleeve Bellows," Revision 1; I ~
l 18wOSR 3.6.1.1-9, " Primary Containment Type C LLRT of Chemical and
- -
l Volume Control System," Revision 1; l'
l 1BwOSR 3.6.1.1-13, " Primary Containment Type C LLRT of Fuel Pool Cooling
-
l System," Revision 0;
!
.
.
.
l
.18wOSR 3.6.1.1-17 " Primary Containment Type C LLRT of Make-up
~-
Demineralizer System," Revision 0; 18wOSR 3.6.1.1-5, " Primary Containment Type B LLRT of Fuel Trarver Tube
-
,
f Penetration and Fuel Transfer Tube Sleeve Bellows," Revision 1; 1BwVSR 3.6.1.1.25, " Summation of Type "B" & "C" Tests for Acceptance
-
o Criteria," Revision 0;
4 3-
-.
.
.-
-. -..
-.
-
!
18wOSR 3.6.2.1-2," Primary Containment Type B LLRT of Equipment Personnel
,
Hatch Airlock," Revision 1;
!
18wOSR 3.6.2.1-3," Primary Containment Type B LLRT of Emergency
Personnel Hatch Airlock," Revision 1; 1BwOSR 3.6.3.7-1, " Primary Containment Type C LLRT of Containment Purge
+
Supply Isolation Valves," Revision 2E1; 18wOSR 3.6.3.7-2, " Primary Containment Type C LLRT of Containment Purge
-
Exhaust isolation Valves," Revision 1E1; 18wOSR 6.1.7.4-1, " Primary Containment Type C LLRT of Containment Purge
Isolation Valves," Revision 2; BwVSR 3.6.1.1.0, " Visual Inspection of the Containment Surfaces Prior to the
-
Type A Leak Test," Revision 1; and 18wOSR 3.6.1.1-100, "lLRT Line Up and Restoration Data Sheets,"
a Revision OE2.
The inspectors also reviewed 10 CFR Part 50, Appendix J; Regulatory Guide 1.163; and Nuclear Energy Institute 94-01, " Industry Guideline for implementing Performance-Based Option of 10 CFR Part 50, Appendix J," Revision 0. The inspectors observed the pressurization of the Unit 1 containment building, and interviewed system engineering.
b.
Observations and Findings The inspectors reviewed 1BwVSR 3.6.1.1.lLRT and determined that the testing prescribed was in accordance with 10 CFR Part 50, Appendix J; Regulatory Guide 1.163; and Nuclear Energy Institute 94-01.
The inspectors performed a walkdown of ILRT test equipment and observed that the equipment was properly installed and that equipment calibrations were current. The inspectors walked down the Unit 1 containment and reviewed the results of BwVSR 3.6.1.1.0 and determined that the Unit 1 cc.?finment surfaces were in a condithn to support the ILRT. The inspectors observed the pressurization of the containi... nt and determined that temperature stabilization and pressurization rates were in accordance with 18wVSR 3.6.1.1.lLRT.
The inspectors reviewed the methodology used during the induced leak rate testing, l
'
including ensuring the proper stabilization period was observed, and determined that the j
induced leakage fell within the required acceptance criteria based on Pa being l
47.8 psig.
l The inspectors reviewed the results of the Type B and C leak rate tests and determined that the results fell within the Technical Specification acceptance criteria.
l
-
l l
l The inspectors determined that the acceptance criteria specified in procedures l
18wOSR 3.6.2.1-2,13wOSR 3.6.2.1-3,18wOSR 3.6.3.7-1,1BwOSR 3.6.3.7-2, and
'
1BwOSR 3.6.3.7-2 was based on an incorrect value of Pa. The Technical Specifications defines Pa as the maximum calculated primart containment pressure for the design basis loss of coolant accidant. Prior to Unit 1 outage A1R07, the value for Pa for the Unit 1 containment was 44.4 pounds per square inch gage (psig). Upon completion of the outage the value of Pa was changed to 47.8 psig. The above procedures were not l
updated to reflect the leak rate based on the new value cf Pa. The inspectors considered these errors to be minor. The acceptance criteria i.t.% rate was more conservative because it was a smaller value than required. Thus th system was tested at the new higher Pa value with a leak rate acceptance criteria lowe' than required.
This error was discussed with the licensee and a problem identification form (PIF) was issued. Although these errors were of a minor nature, they were further examples of inspector identified acceptance criteria errors as was previously discussed in NRC Inspection Report 50-456/457/98014(DRP).
The inspectors reviewed the overall results of 18wVSR 3.6.1.1.lLRT and determined that the results met Technical Specification required acceptance criteria. The inspectors
,
'
also observed the coniainment depressurization and system restoration and determined that these evolutions were performed in accordance with 1BwVSR 3.6.1.1 ILRT.
c.
Conclusions The inspectors concluded that the integrated leakage rate test performed on the Unit 1 containment was performed in accordance with 10 CFR Part 50, Appendix J and tnat the results satisfied the Technical Specification acceptance criteria. The inspectors discovered errors with the acceptance criteria used in five Type B and C leak rate tests but concluded that these errors were of a minor nature.
M1.5 Observation of Miscellaneous Surveillance Activities a.
Inspection Sco_pe (61726. 50001)
The inspectors observed all or portions of the following surveillance activities:
BwVSR 5.5.8.SI.3, "SI System Check Valve Stroke Testing," Revision 0;
,
l l
BwVSR 5.5.8.SI.4, "Si System Check Valve Stroke Testing," Revision 0;
-
BwVSR 3.4.14.1, " Reactor Coolant System Pressure isolation Valve Leakage l
Surveillance," Revision 0; i
'
SPP 98-049, "10 Percent Load Decrease," Revision 1; and
-
- .
!
SFP 98-048, "Large Load Reduction," Revision 1.
-
b.
Observations and Finding Between October 26 and November 25, the inspectors observed the performance of the above listed surveillance tests. For each surveillance test, the inspectors observed the 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 outside the control room, and the restoration of affected equipment. 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 i
specified in the surveillance test procedures. The inspectcrs also reviewed the associated portions of the Updated Final Safety Analysis Report and Technical Specifications and determined that the surveillance test procedures demonstrated the systems performed as designed, c.
Conclusions 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.
M1.6 Failure of the Unit 1 Heater Drain Tank Ruoture Disc a.
Inspection Scope (F2707)
The inspectors reviewed WR 970029581-01 and discussed the results of the licensee's investigation with maintenance personnel.
b.
Observations and Findinas The licensee's Wtial investigation identified improper torquing as the cause for the failure of the Unit 1 heater drain tank rupture disc on November 30,1998. The unit was subsequently shut down es discussed in Section 01.2 of this report. The licensee identified several contribut;ng causes for the improper torqulng. First, the manufacturer had verbally recommended a hot retorque once the plant was operating at normal operating temperature and pressure. However, written instructions that were supplied with the rupture disc did not mention a hot retorque. Second, the licensee observed evidence of galling between the flange stud nuts and the flange which may have caused an erroneous indication of the torque applied to the flange studs. Third, a silicone sealant was incorrectly applied to the mating surfaces between the rupture disc and the rupture disc holder. The licenses determined that the incorrectly applied sealant effected the torque applied to the fasteners and also allowed slippage of the rupture disc within the rupture disc holder.
The licensee reviewed the work package step that directed the application of the sealant and determined that it was not clear as to where the sealant should have been applied.
.
The inspectors reviewed the sty in questinn and agreed that the step could be stated more clearly.
The licensee took the following immediate actions: initiated a root cause investigation; quarantined the failed rupture disc; performed a detailed inspection during the remov.:l of rupture disc; provided the failed rupture disc to the system materials analysis department; discussed the failure with system analysis department and the manufacturer; verified the proper torque patterns and values with the manufacturer; used hardened steel washers on the reassembly to prevent galling between the flange stud nuts and the flange; and added the requirement for a hot retorque once the plant was operating at normal operating temperature and pressure.
c.
Conclusions The inspectors concluded that failure of the Unit 1 feedwater heater drain tank rupture disc was due to an inadequate installation procedure and that the licensee's initial actions to determine and correct the cause of the event were commensurate with the significance of the event.
M4 Maintenance Staff Knowledge and Performance M4.1 Unit 1 Refuelina Activities a.
Insoection Scope (627071 The inspectors observed the movement of fuel from the fuel pool to the containment building and interviewed fuel handling personnel who were either performing and/or supporting fuel movements. The inspectors also reviewed Braidwood Fuel Handling Procedure (BwFP) FH-12, " Operation of the Spent Fuel Pool Bridge Crane,"
Revision 6E1; BwFP FH-13. " Operation of the Fuel Transfer System," Revision 7; BwFP FH-14, " Operation of the Refueling Machine," Revision 7; and BwFP FH-31, " Fuel Handling FME Area Requirements," Revision 5.
b.
Qbservations and Findinas On October 24, the inspectors observed the movement of fuel from the fuel pool to the containment building and noted that the fuel pool lighting and clarity prcvided for excellent visibility. The inspectors verified that the fuel handling personnel complied with FME area requirements, followed fuel handling procedures, updated status boards, established and maintained communications between the Unit 1 control room and the senior reactor operator in containment, used three-way communication techniques, and performed clear and concise turnovers to relieving fuel handlers. The inspectors noted that fuel handling personnel were knowledgeable of their responsibility and were proficient in the use cf refueling equipment. All fuel movements were made in accordance with the nuclear component transfer lists. The inspectors observed independent verifications performed by three fuel handling personnel prior to lifting a fuel element from its fuel pool storage location and moving it to the opender.
.
l
_
_--
,
,
c(
Conclusiuis On' October 24, the inspectors observed the mcVement of fuel from the fuel pool to the containment building which was accomplished very well. The inspectors concluded that the fuel handling personnel complied with FME area requirements, established excellent fuel pool visibility, followed fuel handling procedures, updated status boards, established and maintained communications bet' ween the Unit 1 control room and the senior reactor operator in containment, used three-way communication techniques, performed triple independent verifications, and performed clear and concise turnovers to relieving fuel
- handlers.
M8 Miscellaneous Maintenance issues (92902)
M8.1 (Closed) Violation 60-456/457/97022-02(DRP): Failure to follow the procedure for the control of measurement and test equipment (M&TE). The inspectors determined that access to M&TE was not consis'ently controlled based on finding M&TE storage locations unlocked and unattended on five separate occasions, contrary to EwAP 400-4,
" Control of Portable M&TE," and a violation of Technical Specification 6.8.1.a. was issued. In response to the violation, the licensee performed a review of regulatory requirements, codes, and standards associated with the control of M&TE and concluded that the locking of M&TE was not required. The licensee revised BwAP 400-4. removing the requirement to lock M&TE. Plant personnel were trained on BwAP 400-4 requirements following its revision. The inspectors reviewed the licensee's corrective actions to prevent recurrence and determined that the corrective actions addressed the cause and should prevent recurrence. This violation is closed.
Ill. Enaineerina E1 Conduct of Engineering E1.1 Operability Determination Reviews a.
Inspection Scope (37551)
The inspectors reviewed the following documents:
Operability Evaluation 98-050, " Nonconforming Reactor Containment Fan Cooler
-
Discharge Check Damper";
Operability Evaluation 98-053, "Leakby of One or More of 1Sl8819A/B/C/D
-
Valvas Causing St Pump Discharge To Pressurize To SI Accumulator Pressure";
Operability Evaluation 98-054, " Boron Dilution Prevention System Inoperability";
-
and Nuclear Station Procedure CC-3001, " Operability Determination," Revision O.
-
P i....................
..
....
..
...
.
_ _ _ _ _ _ _ _ _ _
- - - - - -_ -
.-. - --. -.- -- -
.
,
b.
Observations and Findinos The inspectors verified that the documentation of operability evaluations met nuclear station Procedure NSP-CC-3001 requirements, the assumptions used to develop the
' operability determinations were valid, and the licensee complied with Technical Specification requirements. The inspectors discussed compensatory actions with control room operations personnel and determined that operators were aware of, and understood the compensatory actions listed. On November 30, operators performed a shutdown of Unit 1 to repair a failed rupture disc on the Unit 1 heater drain tank. The
.
inspectors verified that operators implemented compensatory actions identified in boron
'
dilution p.wention system operability evaluation,98-054, at the time the unit entered Mode 0 (Hot Standby). The inspectors also verified that corrective actions were being tracked.
.
c.
Conclusions-
'
-
The inspectors concluded that the operability determinations regarding the Unit 1 reactor containment fan cooler discharp check damper, Unit 1 Si check
,
valves 18!-8819A/B/C/D, and Unit 1 and 2 boron dilution prevention system reflected good engineering judgement and safety focus. The compensatory actions were l
understood by operations personnel.
E1.2 Boron Dilutien Preventio_n Systems for Unit 1 and Unit 2 Discovered to be Inocerable j-
.Due to Computer Modelina Errol
^
a.
Insocction Scope (37551)
The inspectors reviewed PIF A1998-04141, operability determination 98-054, and
applicable portions of the Technical Specifications and Updated Final Safety Analysis q
Report (UFSAR). The inspectors interviewed system engineering, operations, and
- ._
regulatory assurance personnel.
b.
Observations and Findinas l'
On November 11,1998, the licensee declared the Unit 1 and Unit 2 boron dilution pre fention system inoperable due to an error discovereo by the vendor in the computer j
code used to model the system's response during accident conditions.
~
The boron dilution prevention system was designed to actuate in response to an assumed boron dilution accident during shutdown conditions in Modes 3,4, and 5. The system 'used inputs from the source range nuclear instrumentation and would actuate should neutron flux rates increase by a factor of two or more in a 10-minute period.
When actuated, the system would automatically realign the appropriata valves to inject
,
borated water into the t eactor coolant system terminating the assumed dilution event and preventing an inadveQnt criticality.
,
- The inspectors observed that the licensee made a 4-hour notification to the NRC in
'
t
- accordance with 10 CFR 50.72. The inspectors verified that the problem was 19'
.
m a
n-
-
m
.
.
documented on a PIF, and that the licensee performed a system ooerability detem'ination. The inspecturs also verified that the Technical Specification required compensatory actions were thoroughiy understood by operations personnelin the control room. On Nove,nber 28, the licensee performed a shutdown of Unit 1, due to a failed heater drain tank ruptured disc, see Section 01.2. The inspectors observed the licensee take the Technical Specification required compensatory actions for the boron dilution prevention system being inoperable once Unit 1 had entered Mode 3 (Hot Standby).
The licensee determined that the errors discovered in the computer code were made by the vendor, although the cause of the error was not yet fully understood. This issue will remain open pending receipt and analysis of Licensee Event Report 50-456/98007-00.
c.
. Conclusion.s On November 11,1998, the licensee declared the Units 1 and Unit 2 boron dilution prevention systems inoperable due to an error discovered by the vendor in the computer code used to model the system's response during accident conditions. The inspectors concluded that the licensee took the appropriate and concervative actions to address the inoperability of the boron dilution prevention system. The inspectors concluded that the licensee properly implemented the Technical Specifications required compensatory actions for the boron dilution prevention system during a recent shutdown of Unit 1.
This issue will remain open pending receipt and analysis of Licensee Event Report 50-456/98007-00.
IV Plant Support i
R1 Radiological Protection and Chemistry (RP&C) Controls R 1.1 Clean Up of Contaminated Areas and Prncessina Solid Radioactive Waste a.
hLsp.ection Scope (71750. 50001)
l l
The inspectors inspected areas that the licensee posted as contaminated areas during l
the recent Unit i refueling and steam generator replacement outage, A1R07, and
!
interviewed radiation protection technicians. The inspectors inspected solid waste l-processing and decontamination areas of the plant and interviewed the radioactive
!
waste supervisor.
b.
Observations and Findinas
'
The inspectors performed inspections of the UnP.1 auxiliary building curved wall area, charging pump rooms, Si pump rooms, residual heat removal pump rooms, containment spray pump rooms, and valve isles and noted that the contaminated areas were cleaned up and released. The inspectors also inspected decontamination areas and noted that radioactive waste generated from the decontamination of equipment was not allowed to accumulate. The wastes generated in these areas were frequently removed and
.
b
.
_
.
__
_
____
_
_
_
_
._.
_.
.
transferred to solid radioactive waste processing areas. The inspectors performed an inspection of the solid radioactive waste processing areas and noted no large accumulations of wastes awaiting processing. The radioactive waste supervisor told the inspectors that there were minimal amounts of waste from the outage remaining on site since solid radioactive wastes were processed as they were delivered to the processing areas and shipped to disposal sites on several occasions during the outage. The j
wastes being stored were labeled and were neatly stored in the designated area.
c.
Conclusions The inspectors concluded that radiation protection technicians promptly cleaned and released contaminated areas in the auxiliary building following the Unit 1 refueling and steam generator replacement outage, A1R07. Solid radioactive wastes generated during the decontamination of equipment were promptly removed from decontamination areas and delivered to solid radioactive waste processing areas. Solid radioactive wastes were promptly processed and shipped to disposal sites. T. ' wastes that remained on site were appropriately labeled and properly stored.
F8 Miscellaneous Fire Protection issues (92904)
F8.1 (Closed) Violation 50-456/98002-03(DRP): Missed compensatory fire watches. The l
inspectors determined that on January 29,1998, the continuous fire watch requirement for the Unit 1 lower cable spreading room was not performed in accordance with BwAP 1110-13 on at least +hree occasions. The failure to establish a continuous fire i
watch in accordance with BwAP 1110-13 was determined to be a violation of Technical Specification 6.8.1.g. In response to this vio!ation, the licensee relieved the individual l
from fire watch duties and provided counseling, retrained all fire watch personnel on the use of three-way communications during turnovers, edded requirements to perform verbal turnovers as well as a review of post orders, added additional supervisors, and l
enhanced BwAP 1110-13, " Fire watch inspection," to simplify the process and provide
clearer work instructions for compensatory fire watch acions. The irispectors reviewed the licensee's corrective actions to prevent recurrence ani determined that the
'
L corrective actions addressed the cause and should preverit recurrence. This violation is
!L closed.
i
!
l V. Manaaement Meetinas
l l
X1.
Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conck.sion of the inspection on December 7,1998. The licensee acknowledged the findhgs presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
.
_
_
,
_
._
_.
._ _
..
_.. ~..
._
. _
_. -,
_
_... _.
.
.
)
,
PARTIAL LIST OF PERSONS CONTACTED Ucensee
.
- T. Tulon, Site Vice President K. Schwartz. Station Manager
.
,'*P. LeBlond, Corporate Regulatory Programs
- R. Wegner, Operations Manager R. Byers, Maintenance Superintendent -
A. Haeger, Health Physics and Chemistry Supervisor
.
' R. Graham, Work Control Superintendent 1*T. Simpkin, Regulatory Assurance Supervisor J. Kuchenbecker, System Engineering Supervisor L. Guthrie, Maintenance Director
'
T. Luke, Engineering Manager
- M. Rieger, Nuclear Oversight Manager
- .
- J. Stone, Byron Nuclear Oversight Manager
- F.. Lentine, Design Engineering Manager
'
'
_ R. Thacker, Lead Health Physics
. M. Cassidy, Regulatory Assurance - NRC Coordinator
l NRC
- M. Jordan, Chief, Reactor Projects Branch 3 -
'
- C. Phillips, Senior Resident inspector (via teleconference)
- J. Adams, Resident inspector
- D. Pelton, Resident inspector
,
l
'
IDNS-l J, Roman -
- Denotes those who attended the exit interview conducted on December 7,1998.
!
'
I l
l t
I
.
22
,
I
.
.
.
. _,.
.
.
.
.. ~
~
-. -..
-.
_.
.. -.. _ _. -
..
_
..
_
INSPECTION PROCEDURES USED
- IP 37551:
Onsite Engineering IP 50001:
Steam Generator Replacement inspection IP 61715:
. Verification of Containment Integrity IP 61726:
Surveillance Obs;,rvations IP 62707:
Maintenance Observation IP 70307:
Containment integrated Leak' Rate Test - Procedure Review IP 70313:
. Containment integrated Leak Rate Test IP 70323:
Containment Leak R.ite Test Results Evaluation IP 71707:
Plant Operations IP 71711:
' Plant Startup From Refueling IP 71714:
Cold Weather Preparations IP 71750:
Plant Support Activities
' iP 92901:
Followup - Plant Operations IP 92902:
Followup - Plant Maintenance IP 92904:
Followup - Plant Support ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed
,
50-456/97009-01 VIO Inadequate procedure to drain Unit 1 Boric Acid Storage Tank 50-456/457/97022-02 VIO Failure te follow procedure for Measurement and Testing Equipment 50-456/98002-03 VIO Missed compensatory fire watches Discussed LER 50-456/98006-00 LER 50-456/98007-00 l
NRC Inspection Report 50-456/457/98012(DRP)
NRC Inspection Report 50-456/457/98014(DRP)
!o
23
.
f
, _,
,.
_.
.
..
.-
.
..-.
- -.
..
.... -
..
. -,.... -. - _. -. -..
-.,
'
{'[,.
. s '{-
'
-
- ,
.,
'l
.-o
O
'
LIST OF ACRONYMS USED
'
o
'
q
,
- AR Action Request
.
','
- BAST /
- Boric Acid Storage Tank
'BwAP'
Braidwood Administrative Procedure
'BwFP
> Braidwood Fuel Handling Procedure -
LBwGP-
"Braidwood General Operating Procedure
,
' BwOP Braidwood Operating Procedure
'
' BwOS-Braidwood Operating Surveillance Procedure
- BwVS.
lBraidwood Engineering Surveillance ~ Procedure CFR4
. Code of Federal Regulations
'
_
CV.
Chemical and Volume Control
.
-FME Foreign Material Exclusion
.
"
'
' lLRT- -
- LLRT Local Leak Rate Test.
M&TE --
Measurement and Test Equipment.
' '
'NRC-Nuclear Regulatory Commission
,
Pa-
' Maximum Calculated Primary Containment Pressure for the Design Basis Loss
,
of Coolant Accident
,.,
C PlF,
' Problem identification Form.
, psig.
Radiological Protection & Chemistry Pnunds Per Square Inch Gage RP&C
-.RWST
~ Refueling Water Storage Tank SI Safety injection tL SPP:
Special Test Procedure
~ VIO
, Violation:
'
1WR '
Work Rcquest
..
.,
i
'
.
y p'
,
F j. 1
-
]-t
a
,
I 3,I
,
_
,
.
_ _, - -
,-
,. _.
, - _,.,
- ~ ~ - - -
..-