IR 05000456/1998021

Insp Repts 50-456/98-21 & 50-457/98-21 on 981110-24.No Violations Noted.Major Areas Inspected:Aspects of Corrective Actions & Engineering Involvement in Corrective Action Process

ML20197J693
Person / Time
Site:	Braidwood
Issue date:	12/10/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20197J687	List: IR 05000456/1998021 ML20197J683
References
50-456-98-21, 50-457-98-21, NUDOCS 9812150188
Download: ML20197J693 (11)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lil Docket Nos: 50-456; 50-457 License Nos: NPF-72; NPF-77

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Report Nos: 50-456/98021(DRS); 50-457/98021(DRS) l Licensee: Commonwealth Edison Company Facility: .

Braidwood Generating Station, Units 1 and 2 l

l' Location: RR #1, Box 84 Braceville,IL 60407 Dates: November 10,13,16-19, 24,1998 l~

l Inspector: D. Schrum, Reactor Engineer -

t Approved by: R. N. Gardner, Chief, Engineering Specialists Branch 2, Division of Reactor Safety l

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9812150188 981210 PDR G ADOCK 05000456

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EXECUTIVE SUMMARY Braidwood Nuclear Power Station, Units 1 & 2 NRC Inspection Reports 50-456/98021; 50-457/98021 This inspection reviewed aspects of licensee corrective actions and engineering involvement in the corrective action process. The inspector concluded that the licensee was effective in implementing corrective actions for the specific items reviewed. In addition, the engineering staff and fire protection staff were knowledgeable and involved in the correc'ive action process for the specific items in this repor Enaineerina Corrective actions were acceptable (All Sections).

Engineering involvement in the corrective action process was good for the specific items reviewed (All Sections).

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Report Details Ill. Enaineerina The inspection included a review of the licensee's corrective actions and engineering involvement in the corrective action process. The inspector determined that the licensee was effective in implementing corrective actions for the specific items reviewed. The engineering staff and fire protection staff were knowledgeable and involved in the corrective action process for the specific items in this repor E8 Miscellaneous Engineering issues (IP 92903, IP 92700)

E (Closed) Unresolved item 50-456/457/96016-02(DRS): Reactor Coolant Pump (RCP)

Oil Collection System not collecting oil from all potential RCP leakage site i l

This issue was identified as an Unresolved Item because the inspectors did not consider l

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this condition to be in full compliance with Appendix R Section 0; therefore, outside the design basis for the plant. The licensee disagreed that the condition was outside the plant's design basis and stated that the original drip pan configuration was previously approved by the NRC. Documentation was available to indicate that this condition was not a concern during previous NRC inspections of the RCP Oil Collection System. Th9 licensee stated that the modification was performed to enhance the existing oil collection system and to ensure that the adequacy of this system was never questioned by the NR The licensee performed a modification that added two additional drain pans and lengthened one drain pan for each RCP. The Unit 2 modification was completed in 1 1996. The Unit 1 modification was completed in 1997. The inspector had no additional l concerns, so this URI is close l l

E8.2 (Closed) Violation 50-456/457/96016-05(DRS): Failure to correctly implement Braidwood Station Hot Work Permit, Attachment A of Braidwood Administrative Procedure (BwAP) 1100-15, " Fire Prevention When Welding, Cutting, Grinding, or Performing Open Flame Work (Hot Work)."

l The licensee's corrective actions included a major revision to BwAP 1100-15 to simplify l and to clarify the requirements associated with using hot work permits. in addition, the hot work permit (BwAP 1100-15T1) was also revised to make it more user friendly. Also, worker responsibilities were more clearly identified in the procedure. Maintenance and Construction personnel were trained on the requirements associated with properly l completing hot work permits and management's expectations related to procedure l adherence.

l The inspector performed a review of completed hot work permits for the time period October 6 to November 6,1998. The inspector noted that applicable portions of the hot work permits had been accurately filled out prior to work. The inspector reviewed the

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changes to procedure BwAP 1100-15. The changes appeared to be acceptable. A review of hot work Problem Identification Forms (PIFs) indicated that there was only a limited number of hot work paperwork problems during the past year. The licensee's corrective actions were effective for hot work permit problems. This violation is close E8.3 (Qlpsed)

l E.I. 50-456/457/96016-03(DRS): Inadequate Separation of Cables Associated with Redundant Safe Shutdown Train This violation was issued as a result of the plant not meeting Appendix R design requirements. A fire could affect the ability to achieve and maintain safe shutdown conditions from the loss of following equipment: 1) Units 1 and 2 Miscellaneous Electric Equipment Room Supply Fans; 2) Loss of Unit 1 Emergency Diesel Generators; 3) Loss of Essential Service Water Pumps 1 A & 1B; 4) 18 Auxiliary Feedwater Pump; 5) Loss of Unit 1 Fire Hazard Panel; and 6) Loss of Unit 2 Fire Hazard Pane Enforcement action for these design problems led to a Severity Level 111 Violation with no Civil Penalty. The licensee completed the last modification to correct the above conditions in 1997. No further actions were required. This item is close E8.4 (Closed) E.I. 50-456/457/96016-04(DRS): Failure of Auxiliary Building roll-up doors to satisfy the Appandix R 3-hour rated fire barrier requiremen This violation was isswd for the failure of roll up doors, separating areas containing safety-related equiprnei to fully close under full ventilation conditions. The roll-up doors protected the following rooms from a Turbine Building fire: 1) 1 A&1B Diesel Generator Rooms; 2) 2A&2B Diesel Generator Rooms; 3) Unit 1 Division 11&12 i

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Essential Safety Function (ESF) Switchgear Rooms; 4) Unit 2 Division 21 & 22 ESF Switchgear Rooms; 5) Units 1 and 2 non-ESF Switchgear Rooms; 6) Unit 1 Miscellaneous Electric Equipment Room; and 7) Unit 2 Miscellaneous Electric Equipment Roo l The licensee's corrective action for this problem was to maintain the roll-up doors closed '

during plant operations to meet the 3-hour rated fire barrier requirement. Compensatory measures are taken if the doors are required to be open to move equipment in and out of the rooms. In addition, the Diesel Generator Room roll-up doors are maintained closed at all times during Modes 1 through 4 because these doors also serve as barriers against High Energy Line Breaks (HELB)in the Turbine Buildin A second problem was a structurai mounting problem in that in the event of a fire on either side of the doors the mounting frame and roller channel could thermally expand beyond the limits of the mounting slots rendering the doors inoperable. The licensee performed modifications to correct the mounting problem with the roll-up door The inspector verified that the roll-up doors were on a preventive maintenance schedul The preventive maintenance included a six month inspection and a 18 month inspection and drop test. The inspector had no additional concerns in this area. This item is close . _ _ __ _ . _ _ _ .__ -_____ _

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E8.5 (Closed) Violation 50-457/97021-01(DRS.): Failure to provide an adequate Unit 2D feedwater fill and vent procedur This violation was issued for a procedure that failed to provide adequate instructions to properly fill and vent air out of the feedwater system. The procedure refers to opening i and closing high point vent valves. However, these high point vent valves are not identified as part of the plant design for Unit 2. As a result, Unit 2 was not properly j i vented and a voided section of piping subsequently caused a water hammer that i damaged safety-related equipment.

J The licensee's corrective action included a revision to the station's start-up procedure (BwGP 100-2) to ensure minimal differential pressure across the preheater bypass ,

valves (2FWO39A-D) prior to stroking the valves. This procedure now directs the I operator to the revised operating procedure (BwOP FW-3) if the differential pressure is excessive. BwOP FW-3 was revised to provide proper direction for equalizing pressure l across the 2FWO39A-D valves and additionally gives specific direction for filling and

, venting the Unit 2 feedwater piping. The inspector verified that the procedure changes had been mad l

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The licensee reviewed the valve data base to identify vent and drain valves that had no 1 comparable valves on the other unit. There were 117 differences identified. Procedures l are being reviewed to ensure the valve differences have been addressed in the applicable procedures. The associated procedure reviews for these valves will be completed this mont The licensee reviewed three plant systems most at risk for a water hammer. These systems were the Auxiliary Feedwater System, Condensate and Condensate Booster System, and Gland Steani(GS) System. Accessible portions of these systems were walked down with an associated review of system procedures and piping and instumentation drawings (P&lDs). A potential for a serious water hammer was identified on the GS System. Engwring request (ER) 9801907 was approved for a . design for the addition of a drain valve on the GS system. This valve will be installed daring Unit 2 seventh refueling outag The inspector verified that the above corrective actions were taken. This item is close E8.6 (Closed) Violation 50-457/97021-02(DRS): Failure of licensee personnel to follow BwAP 100-20 and issue a procedure revision for an inadequate procedure (2BwGP 100-2).

The licensee's corrective actions to prevent recurrence included training the Operations Personnel to submit a procedure change request if a procedure enhancement is necessary, in addition, BWGP procedures were reviewed for adequacy. The inspector was satisfied with the licensee's corrective actions. This violation is close E8.7 (Closed) Violation 50-456/457/98008-03(DRP): This violation was issued for not having a welding machine de-energized and acety!ene hoses depressurized when they are not in use or when assigned workers are not in the work are . .

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The licensee's corrective actions included training contractor and site staff on the requirements of BWAP 1100-15 and to ensure the staff was aware of management's expectations for compliance with procedure requirements. In addition, a member of each work crew was assigned responsibility to ensure welding machines are properly turned off, cutting torch hoses are depressurized and bottles are isolated closed when the crew leaves the area. Supervisors performed periodic spot checks of hot work activities to verify compliance with requirements. An inspector review of PlFs indicated !

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that the licensee's corrective actions for this problem were adequate. Tnis violation is close E8.8 (Closed) Violation 50-456/457/97007-06b(DRP): This violation was issued for the failure to obtain a Plant Barrier impaimient Permit for a fire door held open with a hose passing i through the doo !

The licensee's corrective actions included removing the hose, closing the door, and counseling the employees involved. In addition, this event was discussed with Station personnel during a Human Performance Awareness Session. The licensee's corrective actions were adequate. This violation is close E8.9 (Closed) Violation 50-456/457/97007-06c(DRP): This violation was issued for not having a transient fire load permit for unattended combustible materials in the Auxiliary Buildin The licensee's corrective action included issuing a transient fire load permit and counseling the individuals involved. In addition, the licensee's corrective actions included removing combustible and flammable liquids from the Auxiliary Building, publishing articles in the Station's Daily Newsletter about controlling combustible materials, fire protection awareness training for first line supervisors, and routine monitonng of the plan However, the above actions were not effective to prevent recurrence as indicated by Violation 50-456/457/97016-07 (see item E.8.11 of this report). The additional corrective actions taken for the latest violation were effective. This item is close E8.10 (Closed) Violation 50-456/97007-06a(DRP): This violation was issued for a sleeping fire watc The licensee's corrective action included counseling and disciplinary action for the employee. To ensure that fire watches stay awake, they were not allowed to use chairs while performing fire watch activities. Training was given to contractor personnel for the importance of staying attentive to fire watch duties. The licensee's corrective actions were adequate. This violation is close E811 (Closed) Violation 50-456/457/97016-07(DRP): This violation was issued for the failure to take adequate corrective actions for fire protection issue The licensee's corrective actions included remo'.?l of uncontrolled combustible and flammable liquids from the Auxiliary Building. Bya were installed at the Radiation

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Protection tool drop-off areas tc prevent workers from leaving combustible and flammable liquids in these areas .

Articles were included in the Daily Newsletter to make people aware of fire protection requirements. Training was given for putting items in flammable storage cabinets when flammable and combustible liquids are not being used. Augmented inspections were performed of the plant to ensure compliance with fire protection requirements. In addition, a Task Force was initiated to evaluate current processes, procedures, and methods to promote personnel accountability with fire protection issues. This included an evaluation of the plant's cultural background, attitude of plant workers, procedural impact, training, future buy-in of the work force, worker accountability, and future changes in plant operations. Training was pe formed to refresh fire prevention knowledge. Performance reviews were performed to ensure effective corrective actions for this violatio The Resident inspectors performed routine inspections of plant areas to verify compliance with requirements for unattended combustible materials. The corrective actions for this violation were effective in significantly reducing the number of times that plant staff did not follow fire protection procedure requirements. This violation is close V. Manaaement Meetinas X1 Exit Meetina Summary The inspectors presented the inspection results to members of the licensee's management at the conclusion of the inspection on November 24,1998. The licensee acknowledged the findings presented. No proprietary information was identifie .

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. PARTIAL LIST OF PERSONS CONTACTED i

M. Anjum, Fire Protection System Engineer B. Boyle, Fire Marshall M. Cassidy, Regulatory Assurance B. Claveau, Operations Staff l L. McCoy, Operations Staff Assistant G. O'Donnel, Fire Protection Engineer l

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ITEMS OPEN, CLOSED, AND DISCUSSED l

Closed

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50-456/457/96016-02 URI Inadequate RCP Oil Collection Syste l 50-456/457/96016-03 VIO Inadequate Separation of Appendix R Cables i 50-456/457/96016-04 VIO Roll-up Doors Not 3-Hour Fire Barrier 50-456/457/96016-05 VIO Failure to Correctly implement Hot Work Permit /97021-01 VIO Inadequate Feedwater Fill and Vent Procedur /97021-02 VIO Failure to issue Procedure Revisio /97007-06a V:0 Sleeping Fire Watc /97007-06b VIO No PBI for an impaired Doo /97007-00c VIO No Transient Fire Load Permit 50-456/457/98008-03 VIO Welding Machine Energized / Oxygen Actelylene Charged when Unattende /457/97016-07 VIO Failure to Take Adequate Corrective Actions

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for Fire Problems.

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LIST OF ACRONYMS USED l

BwAP Braidwood Administrative Procedure

- BwGP Braidwood -Procedure I BwOP Braidwood Operations Procedure )

DRS Division of Reactor Safety I El Escalated Enforcement issue ESF Engineered Safety Feature FW Feedwater NRC Nuclear Regulatory Commission NSWP Nuclear Station Work Procedure NTS Nuclear Tracking System PIF Problem identification Form RCP Reactor Coolant Pump ,

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LIST OF DOCUMENTS REVIEWED

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NRC Inspection Report 50-456/457/96016

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NRC Inspection Report 50-457/97021

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NTS 456-100-97-02101.3," Evaluate 3 Systems for Vulnerability to Water Hammer Events"

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NTS 457-200-97-SCAQ0003518," Track investigation Modification for GS System"

BWOp FW-3, Revision ti," Filling and Venting the Feedwater System"

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Corrective Action Record 20-97-056," Operability Assessments"

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NTS 456-100-97-02101.2, " Review EWCS for Unit Designator Differences"

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NTS 456-100-97-02102, " Failure to implement a Procedure Change for an inadequate Startup Procedure"

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NTS 456-200-97-CAOS0010802, PlF A1997-05216," Corrective Action Tailgate" ,

• 2BWGP 100-2, Revision ll, " Plant Startup"  !

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1BWGP 100-1, Revision 10. " Plant Heatup"

- NTS 457-200-97-SCAQ0003501, "2D/FW Line Water Hammer - Corrective Actions"

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NTS 456-100-97-02101.1," Commitment for Ops to Review Unit Designators"

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NTS 457-200-97-SCAQ0003504, "2D Line Water Hammer - Corrective Actions - EWCS i Database Reviewed" l

- NTS 457-200-97-SCAQ0003520,"2D FW Line Water Hammer - Corrective Actions - 1 Review Procedures for Differing Vent and Drain Valves"

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NTS 456-100-97-02101.4," Commitment to Provide Formal Training on Event to Ops" l

+ NTS 456-100-97-02103.1, " Commitment to Review PlF initiation Guidance" l

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NTS 456-100-97-02103,"NRC Violation for Failure to initiate a PlF for Potentially I Damaged Snubbers"

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NSP-CC-3001, Revision O," Guidance on Degraded and Nonconforming Conditions"

• Memo, May 28,1998, " Reminder to Generate PlFs"

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Memo, December 16,1997," Supervisor Account Abilities for PlF Resolution and Review"

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Memo, September 9,1997, " Literal Compliance with Technical Specifications"

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NTS 456-100-96-01605, "NRC Violation for Failures to Properly Fill Out Hot Work Permits" l

. Braidwood Procedure (BWAP)-1100-15, Revision 6 and Revision 10," Fire Prevention l when Welding, Cutting, Grinding, or Performing Open Flame Work"

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Braidwood Root Cause Report,11/10/97," Water Hammer Caused by inadequate Venting While Opening 2FWO39D Valve"

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NTS 456-201-96-205800, " Structural Mounting Concern for a Three Hour Rated Roll Up Fire Doors"

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LER 50-456/96011-00

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LER 50-456/95013-00 & 01

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BWMS 3350-001, Revision 3," Fire and Security Doors Semi-Annual inspection

. Roll-up Door PM Schedules"

. Braidwood Station Response to Information Notice 92-18

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Notice of Violations for Inspection Report 50-456/457-9S016, EA 97-110

- BWAP 1100-9A1, Revision 2E1, Report of Fire: 4/1/97,9/23/98,9/25/98 and 10/22/98

- BWAP 1100 - 15T1, "Braidwood Station Hot Work Permit"

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PlF A1997-05183, " Hot Work Procedure - Potential Procedure Adherence Concern"

- PlF A1998-00180," Procedure Adherence for BWAP 1100-15"

- PlF A1998-01563," Revised Hot Work Procedure issue Problem"

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PlF A1998-02094," Energized Welding Machine and Oxygen / Acetylene Torch Unattended"

- PIF A1998-02180," Hot Work Permit Problem *

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Exempt Change No. E20-0-96-287, " Relocate Train B VC System Controls from 1PLO5D"

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Exempt Change No. E20-2-96-268 " Installation of Additional Reactor Coolant Pump l Motor Oil Drip Pans" )

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Exempt Change No. E20-1-96-268 " Installation of Additional Reactor Coolant Pump 1 Motor Oil Drip Pans" 1

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Operability Assessment 96-025, "Not all of the Extemal Oil Connections have Drip Collection Pans as Required by 10 CFR 50 Appendix R"

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NRC Inspection Report 456/86045; 457/86033

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NRC Inspection Report 50-456/88010; 50-457/88017

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NTS 456-100-86-04510 "URI Item to Analyze Unprotected Portion of High Pressure Screwed Connection on Discharge Side of Oil Lift Pump"

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Reply to Notice of Violation 50-456/457/98002

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NTS 456-100-97-01607.1, " Commitment for Established Task Force to Evaluate Current Processes, Procedures, and Methods in Fire Protection"

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NTS 456-100-97-01607.2, " Commitment for Fire Marshal to Review Training Provided to Contractors with Respect to Fire Protection"

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Reply to Notice of Violation for NRC Inspection Report 50-456/457/97016 j

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Reply to Notice of Violation NRC Inspection Report 50-456/457/98008  ;

- NTS 456-100-97-00706.1," Commitment to Evaluate the Transient Fire Load Procedure to Ensure Steps are Clear to the Procedure User"

- NTS 456-200-97-SCAQ0004906, " Transient Combustible Control *

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NTS 456-200-97-SCAQ0004907 " Site Aware of Transient combustible Control"

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Reply to Notice of Violation NRC Inspection Report 50-457/97021, March 11,1998 L

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