IR 05000456/2002005
| ML021160650 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 04/26/2002 |
| From: | Ann Marie Stone NRC/RGN-III/DRP/RPB3 |
| To: | Skolds J Exelon Generation Co |
| References | |
| IR-02-005 | |
| Download: ML021160650 (28) | |
Text
April 26, 2002
SUBJECT:
BRAIDWOOD STATION, UNITS 1 AND 2 NRC INSPECTION REPORT 50-456/02-05(DRP); 50-457/02-05(DRP)
Dear Mr. Skolds:
On March 31, 2002, the NRC completed an inspection at your Braidwood Station, Units 1 and 2. The enclosed report documents the inspection findings which were discussed on April 2, 2002, with Mr. K Schwartz and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and to compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. Specifically, this inspection focused on resident inspection and radiation protection activities.
Based on the results of this inspection, the inspectors identified three findings of very low safety significance (Green). These included failure to implement adequate corrective actions for incorrect instantaneous current trip setpoints for valve breakers, failure to follow a surveillance test procedure, and inadequate test controls to prevent pre-conditioning of equipment. All of the issues were determined to involve violations of NRC requirements. However, because of their very low safety significance and because they were entered into your corrective action program, the NRC is treating the issues as Non-Cited Violations, in accordance with Section V1.A.1 of the NRCs Enforcement Policy.
If you contest a Non-Cited Violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, Region III, Resident Inspectors and the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001. In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Ann Marie Stone, Chief Branch 3 Division of Reactor Projects Docket Nos. 50-456; 50-457 License Nos. NPF-72; NPF-77
Enclosure:
Inspection Report 50-456/02-05(DRP);
50-457/02-05(DRP)
REGION III==
Docket Nos:
50-456; 50-457 License Nos:
50-456/02-05(DRP); 50-457/02-05(DRP)
Licensee:
Exelon Generation Company, LLC Facility:
Braidwood Station, Units 1 and 2 Location:
35100 S. Route 53 Suite 84 Braceville, IL 60407-9617 Dates:
February 19 through March 31, 2002 Inspectors:
B. Dickson, Acting Senior Resident Inspector N. Shah, Resident Inspector D. Nelson, Radiation Specialist J. Roman, Illinois Department of Nuclear Safety Approved by:
Ann Marie Stone, Chief Branch 3 Division of Reactor Projects
SUMMARY OF FINDINGS IR 05000456-02-05(DRP), 05000457-02-05(DRP); on 02/19-03/31/02, Exelon Generation Company, LLC; Braidwood Station; Units 1 & 2. Post Maintenance Testing, and Surveillance Testing.
The report covered a 6-week period of resident inspection and an announced inspection by a regional radiation specialist. The inspection identified three Green findings. All of the findings involved Non-Cited Violations. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609 Significance Determination Process (SDP). The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described at its Reactor Oversight Process website at http://www.nrc.gov/NRR/OVERSIGHT/index.html.
A.
Inspector Identified Findings Cornerstone: Initiating Events and Mitigating Systems
Green. The licensee failed to incorporate the correct instantaneous current trip setpoint following maintenance and replacement of a safety-related, motor operated valves molded case circuit breaker. This issue was originally identified during the replacement of a similar molded case circuit breaker in September 2001. The inspectors identified a Non-Cited Violation for inadequate corrective actions.
This finding was of very low safety significance because the issue did not represent an actual loss of a safety function of the reactor containment fan coolers. (Section 1R19)
Green. The inspectors identified a Non-Cited Violation for an operator failing to follow surveillance test procedures during the performance of Unit 2 auxiliary feedwater system slave-relay testing.
This finding was of very low safety significance because the issue affected only one train of a safety-related system for less than the technical specification allowed outage time. (Section 1R22)
Green. The inspectors identified a Non-Cited Violation for inadequate test controls during a monthly surveillance testing of the 1B auxiliary feedwater system monthly surveillance test.
This finding was of very low safety significance because the inspectors determined that this preconditioning issue had not led to an actual decline in performance of the 1B auxiliary feedwater system. (Section 1R22)
Report Details Summary of Plant Status Both units operated at full power throughout the inspection period.
1.
REACTOR SAFETY Cornerstone:
Initiating Events and Mitigating Systems 1R04 Equipment Alignment (71111-04)
a.
Inspection Scope
The inspectors verified the alignment of the following systems while the alternate trains were out-of-service for planned maintenance:
1A auxiliary feedwater (AF) pump; and
2A safety injection pump.
The inspectors performed a partial walkdown of the accessible portions of these systems and observed the system (electrical and mechanical) lineup and selected system operating parameters (i.e., pump and bearing lube oil levels, room temperature, and electrical breaker position). The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), Technical Specifications, system drawings, condition reports (CRs) and station procedures, as applicable. As necessary, the inspectors also interviewed licensee engineering, maintenance and operations staff.
b.
Findings No findings of significance were identified.
1R05 Fire Protection (71111-05)
a.
Inspection Scope The inspectors evaluated the licensees fire protection controls for the following areas:
1B/2B essential service water (SX) pump room;
1B AF pump room; and
General areas of the 426' elevation of the turbine building.
The inspectors performed a walkdown of these areas to observe conditions related to the control of transient combustibles and ignition sources; the material condition, operational lineup and operational effectiveness of fire protection systems, equipment and features; and the material condition and operational status of fire barriers. The inspectors observed that the area (including associated fire protection and mitigation
equipment) was as described in the Braidwood Fire Protection Plan, dated December 1988.
b.
Findings No findings of significance were identified.
1R06 Flood Protection Measures (71111-06)
a.
Inspection Scope The inspectors evaluated the licensees controls for mitigating external and internal flooding. Specifically, the inspectors performed the following:
Reviewed the licensees design basis documents to identify the design basis for flood protection and to identify those areas susceptible to external or internal flooding;
Reviewed the licensees probabilistic risk assessment results for external and internal flooding. Based on the assessment results, the inspectors also reviewed selected maintenance records for the fire protection system, as it was considered a significant flooding source;
Reviewed selected abnormal operating procedures for identifying and mitigating flooding events;
Reviewed selected maintenance records and surveillances for watertight doors and flood seals. The inspectors also observed the licensees performance of the triennial flood seal inspection; and
Observed the licensees flood protection contingency actions during the removal of one of the SX room flood seals for routine work on March 21, 2002.
The inspectors also reviewed selected shift control room log entries and CRs to determine whether identified problems were being properly addressed via the licensees corrective actions program.
b.
Findings No findings of significance were identified.
1R12 Maintenance Rule Implementation (71111-12)
a.
Inspection Scope The inspectors reviewed the licensees implementation of the maintenance rule, 10 CFR 50.65, as it pertained to identified performance problems with the following system:
The inspectors evaluated the licensees monitoring and trending of performance data and the appropriateness of a(1) goals and corrective actions. Specifically, the inspectors determined whether performance criteria were established commensurate with safety and whether equipment problems were appropriately evaluated in accordance with the maintenance rule. The inspectors interviewed the stations maintenance rule coordinator and reviewed selective CRs to determine whether identified problems were being entered into the corrective action program with the appropriate characterization and significance.
b.
Findings No findings of significance were identified.
1R13 Maintenance Risk Assessments And Emergent Work Control (71111-13)
a.
Inspection Scope The inspectors reviewed the licensees assessment and management of plant risk for planned maintenance and/or surveillance activities on the following systems:
2B SX pump;
1B AF pump; and
2A containment spray pump The 1B AF pump work was an emergent risk activity due to the pump failing to start during a routine licensee surveillance. Specifically, the inspectors reviewed both the licensees management of plant risk (as described below), but also the licensees troubleshooting efforts to identify the cause of the pump failure.
The inspectors attended shift briefings and daily status meetings to verify that the licensee took actions to maintain a heightened-level-of-awareness of the plant risk status among plant personnel. The inspectors also evaluated the availability of redundant train equipment. In particular, the inspectors observed whether licensee operating and engineering staff were aware of the licensees revised probabilistic risk assessment model which was issued on June 28, 2000. The inspectors also reviewed Nuclear Station Procedure WC-AA-103, On-Line Maintenance, Revision 3, and evaluated licensee compliance with that procedure.
In addition, the inspectors reviewed selected issues that the licensee entered into its corrective action program to verify that identified problems were being entered into the program with the appropriate characterization and significance.
b.
Findings No findings of significance were identified.
1R14 Personnel Performance During Nonroutine Plant Evolutions And Events (71111-14)
a.
Inspection Scope On February 25, 2002, the 1B AF pump failed to start during a routine surveillance. This resulted in the licensee making an unplanned entry into Technical Specification 3.7.5, which allowed a 72-hour period for troubleshooting the problem before having to commence a unit shutdown. Because of the inoperability of a safety-related mitigating system and the possibility of a unit shutdown, the inspectors observed the licensees overall management of plant risk during this period.
On March 28, 2002, the 2B emergency diesel generator tripped on underfrequency during a planned 24-hour surveillance run. This resulted in the licensee making an unplanned entry into Technical Specification 3.8.1, which allowed a 14 day period for troubleshooting the diesel before restoring it to operability. This Technical Specification also required that the licensee verify the operability of the 2A emergency diesel generator within 24-hours. Because of the inoperability of a safety related mitigating system, the inspectors observed the licensees troubleshooting efforts to identify the failure cause and performed a walkdown of the 2A emergency diesel generator. The inspectors also observed the licensees overall management of plant risk during this period.
b.
Findings No findings of significance were identified.
1R15 Operability Evaluations (71111-15)
a.
Inspection Scope The inspectors reviewed and evaluated the following operability evaluations:
2A emergency diesel generator outside supply air dampers partially blocked by installed scaffolding (CR 91234);
Inadequate instantaneous current strip setpoint of safety-related motor operated valves (see Section 1R19); and
Seismic concerns with the replacement lube oil pump for the Unit 1B AF pp (CR 97834)
The inspectors also reviewed the technical adequacy of the evaluations against the Technical Specification, UFSAR, and other design information; determined whether compensatory measures, if needed, were taken; and determined whether the evaluations were consistent with the requirements of LS-AA-105, Operability Determination Process, Revision 0.
In addition, the inspectors reviewed selected issues that the licensee entered into its corrective action program to verify that identified problems were being entered into the program with the appropriate characterization and significance.
b.
Findings No findings of significance were identified.
1R16 Operator Workarounds (71111-16)
a.
Inspection Scope The inspectors reviewed the following documents during a semiannual cumulative review of operator work-arounds:
Open operator workaround and operator list;
Closed operator workaround report;
Operator burden review Quarterly Report; and
Nuclear station operator turnover checklists for Unit 1 and 2.
The inspectors evaluated the effects of the previously existing and new operator workarounds and operator challenges since the last semi-annual review. Inspectors toured plant areas, including the control room, to look for equipment that was degraded but not considered on the work-around list. Inspectors also reviewed CRs which referred to operator workarounds.
b.
Observations and Findings No findings of significance were identified.
1R19 Post Maintenance Testing (71111-19)
a.
Inspection Scope The inspectors reviewed the post-maintenance testing associated with the following components:
2B SX pump; and
1B AF pump.
For each activity, the inspectors reviewed the applicable sections of the Technical Specification and UFSAR, and observed portions of the maintenance work. The inspectors also evaluated the adequacy of work controls (including foreign material exclusion controls), reviewed post-maintenance test data, and conducted walkdowns to verify system restoration after the testing was completed.
In addition, the inspectors reviewed selected issues that the licensee entered into its corrective action program to verify that identified problems were being entered into the program with the appropriate characterization and significance.
b.
Findings The inspectors identified (self-disclosing) a Non-Cited Violation of very low safety significance (Green) for inadequate corrective actions following a failed post-maintenance test for motor-operated valve 2SX016B.
On February 25, 2002, the operators attempted to stroke motor-operated valve 2SX016B, following the replacement of its associated molded case circuit breaker. This valve is the service water inlet valve for the 2B and 2D reactor containment fan coolers.
The valve failed to stroke.
The licensee determined that the failure to stroke was due to the improper setting of the instantaneous current trip setpoint for the valves breaker. This setpoint was designed to trip the breaker if the in-rush current immediately following valve operation was too high (i.e., locked rotor). The in-rush current varied proportionately with the voltage on the associated electrical bus powering the valve. The licensee identified that the instantaneous trip setpoint error band overlapped into the expected in-rush current range experienced when the valve operated normally. On the day of the surveillance, the bus voltage was on the higher end of the expected range; therefore, the breaker tripped. The post maintenance test used to verify the operability of the valve following maintenance did not require the licensee to stroke the valve under a particular bus voltage condition; therefore, it was fortuitous that this discrepancy was identified.
Subsequently, the licensee corrected the 2SX016B setpoint and initiated CR 96945 to determine the corrective actions.
The inspectors noted that on September 10, 2001, the licensee experienced a similar problem (i.e., incorrect setpoint) with another, similar motor-operated valve. This issue was discussed in Section 1R15 of NRC Inspection Report 50-456/457-2001-010. After the September event, the licensee identified about 80 valves (including the 2SX016B) as having incorrect instantaneous current trip setpoints. However, no action was taken to correct these setpoints during preventative maintenance activities on the valve breakers.
As a result, the 2SX016B valve breaker was replaced with a like-for-like breaker having the same, incorrect setpoint.
This finding was considered more than minor because if left uncorrected this issue could potentially affect a large number of valves. Specifically, as stated above, the stroke test could not verify whether the instantaneous trip setpoint was correct when the valve was returned to service. In this case, only the 2B and 2D reactor containment fan coolers were potentially affected. The fan coolers were safety-related and designed to protect the containment barrier. Since only the containment barrier cornerstone was affected, the inspectors performed a Phase I analysis of the event using the significance determination process (SDP). The inspectors answered No to all three containment barrier questions in the Phase I analysis, indicating that the issue was of very low safety significance.
10 CFR Part 50, Appendix B, Criterion XVI, states that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly
identified and corrected. Contrary to the above, the licensee failed to use the correct instantaneous current trip setpoint for the 2SX016B valve, after identifying that the existing setpoint was incorrect. This is considered a violation. However, because this violation was of very low risk significance, was non-repetitive, and was captured in the licensees corrective action program, it is considered a Non-Cited Violation consistent with Section VI.A.1 of the NRC Enforcement Policy (50-456/457/02-05-01(DRP)).
1R22 Surveillance Testing (71111-22)
a.
Inspection Scope The inspectors reviewed the following surveillance test activities:
2B AF pump slave relay testing;
2A solid state protection system bimonthly surveillance test;
Unit 2 containment pressure accident monitoring loop calibration; and
1B AF pump monthly surveillance testing.
For each activity, the inspectors witnessed portions of the testing or reviewed the test data and determined if the associated structures, systems, and components met the American Society of Mechanical Engineers operating criteria, Technical Specification and UFSAR technical and design requirements. For selected activities, the inspectors also reviewed past test results to evaluate any adverse trends and to determine whether past testing was performed using consistent protocols.
In addition, the inspectors reviewed selected issues that the licensee had entered into its corrective action program to verify that identified problems were being entered into the program with the appropriate characterization and significance.
b.
Findings (1)
Auxiliary Feedwater System Slave Relay Testing The inspectors identified (self-disclosing event) a Non-Cited Violation of very low safety significance (Green), after a licensed nuclear operator mispositioned the control switch for the Unit 2 diesel driven AF pump during a routine surveillance.
On February 26, 2002, the operators performed 2BwOSR 3.3.2.7-632B, Unit 2 Emergency Safeguards Features Actuation System Instrumentation Slave Relay Surveillance for Auxiliary Feedwater System Actuation Relays K632 and K639, Revision 0. This procedure required that the Unit 2 diesel driven AF pump control switch be placed in the after trip position. As stated above, an operator incorrectly placed the switch in the pull-to-lock position. This resulted in the pump being unable to auto-start in response to an engineered safeguards system actuation. In addition, this issue resulted in the operators being unaware of the configuration of the Unit 2 AF system for about 43 minutes. The licensee initiated CR 96800 to document this event and determine the corrective actions.
This finding was more than minor, as it had an actual impact on safety by affecting the availability of one train (i.e., the Unit 2 diesel driven AF pump) of a safety-related, mitigating system. Because this finding only affected the mitigating systems cornerstone, the inspectors performed a Phase I analysis of the event using the SDP.
The inspectors answered No to all five questions in the Phase I analysis determining that the issue was of very low safety significance.
Technical Specification 5.4.1 states, in part, that written procedures shall be established implemented, and maintained covering the following activities: a. The applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Section 8(b)(1)(r) of this Regulatory Guide states, in part, that specific procedures for surveillance tests, inspections, and calibrations should be written for AF system tests. Contrary to the above, on February 26, 2001, an operator placed the control switch for the Unit 2 diesel driven AF pump in the pull-to-lock rather than the after trip position, as required by Step F1.3 of 2BwOSR 3.3.2.7-632B. This is considered a violation of Technical Specification 5.4.1. However, because this violation was of very low risk significance, was non-repetitive, and was captured in the licensees corrective action program, it is considered a Non-Cited Violation consistent with Section VI.A.1 of the NRC Enforcement Policy (50-456/457/02-05-02(DRP)).
(2)
Unit 1B AF System Monthly Testing Practices On February 28, 2002, operators performed 1BwOSR 3.7.5.3-2, Unit One Diesel Driven Auxiliary Feedwater Pump Monthly Surveillance. Prior to the start of the surveillance test, the inspectors walked down the Unit 1 diesel driven (1B) AF pump. During the walkdown, the inspectors noted that diesel components such as lubricating oil and jacket water piping, were warm-to-hot to the touch. The inspectors also noted that the diesels engine casing was very warm, indicating a significant amount of internal engine heat. Prior to the start of the monthly surveillance test, the AF pump was started three times. The starts took place within a two-and-a-half hour time frame of when the monthly surveillance test was to be started and lasted from 12-16 minutes each. The diesel runs were part of the licensees troubleshooting efforts from a system failure which occurred on February 25, 2002.
Shortly after noting the AF pumps physical condition, the inspectors observed operators in the 1B AF pump room gathering system data/indications as part of the pre-surveillance test checks. The inspectors questioned the operators regarding what system parameters were checked before the pump was started for the monthly surveillance test. Referencing the monthly surveillance test procedure, the operators stated that the systems alignment was checked and system parameters such as the diesel engines coolant level, pump suction pressure and battery charge were checked.
Diesel engine parameters such as lubricating oil temperature and jacket water temperature were not considered as part of the pre-start check and hence, not part of the prerequisites to prevent preconditioning of the diesel prior to surveillance activities.
As part of its safety function, the auxiliary feedwater pumps were expected to automatically start and run from their normal standby condition in a response to a number of adverse plant conditions. Both NRC Information Notice 97-16,
Preconditioning of Plant Structures, Systems, and Components Before American Society Mechanical Engineers Code In-Service-Testing or Technical Specification Surveillance Testing, and NRC Inspection Manual Chapter 9900 described certain unacceptable conditions of preconditioning. One of the unacceptable conditions mentioned included running major equipment prior to a surveillance test without adequate time to allow systems to settle to normal standby conditions. The inspectors found that the criteria used in the monthly surveillance test was not consistent with this preconditioning guidance. Additionally, several components such as fuel racks, relays, solenoid valves and other moving components were exercised and potentially lubricated prior to the start of the test. The inspectors reviewed 1Bw 5.5.8.AF.2 Unit 1 Auxiliary Feedwater System Quarterly ASME Surveillance Test and noted that preconditioning issue was addressed.
This issue was considered more than minor because if left uncorrected, preconditioning could result in an unrecognized degraded condition affecting the ability of the 1B AF pump to perform its required safety function. With respect to this specific example, the inspectors determined that this issue had not led to declining performance of the AF system. Therefore, this issue was considered to be of very low safety significance (Green).
Appendix B, Criterion XI, states in part, that test procedures shall include provisions for assuring that all prerequisites for a given test have been met. Failure to ensure that appropriate prerequisites were in place to prevent preconditioning of the diesel driven AF pump was a violation of Criterion XI. Because this violation was considered to be very low risk significance, non-repetitive, and was captured in the licensees corrective action program (CR 100618), it was considered a Non-Cited Violation (50-456/457/02-05-03(DRP)).
(3)
Diesel Driven AF Pump Monthly Surveillance Testing Frequency On October 3, 1995, in response to NRC Generic Letter 93-05 Line-Item Technical Specification Improvements to Reduce Surveillance Requirements for Testing During Power Operation, the licensee requested that the Technical Specification required surveillance testing frequency for the AF system be changed from 31 days to 92 days.
The NRC granted this testing frequency change in Amendment 74.
During a review of the 1B AF pumps maintenance and surveillance test history, the inspectors noted that the licensee continued performing the surveillance test every 31 days despite the technical specification change. Additionally, during a review of the Statement of Applicability section of the monthly surveillance test procedure 1BwOSR 3.7.5.3-2, the inspectors noted the following statement: This procedure SHALL be performed every 31 days, due to concerns with engine fuel pump prime.
This statement concerned the inspectors because 10 CFR Part 50.36 required the Technical Specifications to specify the lowest functional capability or performance level of equipment for the safe operation of the facility. Additionally, Section 10.4.9.5.1 of the UFSAR stated that under emergency start conditions, prelubrication is not required for either the motor-driven or direct diesel engine-driven pumps to start. Automatic starting
without prelubrication can be accomplished without bearing damage (due to retention of an oil film on the bearing) provided that the pumps, or their auxiliary lube oil pumps, are started at least monthly.
The inspectors concluded that if the ability of the diesel-driven AF pumps to maintain a fuel prime was the limiting variable for how long the system can remain in its normal standby condition then this issue should be corrected or the licensee should change the technical specification testing frequency to represent the lowest functional capability.
The inspectors also concluded that running the diesel driven AF system monthly to ensure that the system meets the 92-day technical specification requirement could be viewed as preconditioning.
The licensee documented the inspectors concerns in CR 100618. In this CR, the licensee took an action item to evaluate whether a technical specification change was required for the diesel-driven AF pumps to allow continuation of the monthly testing frequency without being considered a preconditioning activity. Pending completion of the licensee evaluation, this issue is considered an Unresolved Item (50-456/457/02-05-04(DRP)).
1R23 Temporary Plant Modifications (71111-23)
a.
Inspection Scope
The inspectors evaluated the licensees installation of the following temporary modifications:
Disabling of the high differential level pump trip for the 1B, 2A, and 2C circulating water pumps; and
A temporary test procedure for isolating and draining the Unit 1 component cooling water heat exchanger.
The inspectors also reviewed selected issues that the licensee entered into its corrective action program to verify that identified problems were being entered into the program with the appropriate characterization and significance.
b.
Findings No findings of significance were identified.
2.
OCCUPATIONAL RADIATION SAFETY Cornerstone: Occupational Radiation Safety 2OS1 Access Control to Radiologically Significant Areas (71121-01)
Plant Walkdowns and Radiological Boundary Verification a.
Inspection Scope The inspectors conducted walkdowns of selected radiologically controlled areas within the plant to verify the adequacy of radiological boundaries and postings. Specifically, the inspectors walked down several radiologically significant work area boundaries (high and locked high radiation areas) in the auxiliary and radwaste buildings and performed confirmatory radiation measurements to verify if these areas and selected radiation areas were properly posted and controlled in accordance with 10 CFR Part 20, licensee procedures, and Technical Specifications. The inspectors also reviewed the radiological conditions within those work areas walked down, to assess the radiological housekeeping and contamination controls.
b.
Findings No findings of significance were identified.
2PS2 Radioactive Material Processing and Transportation (71122.02)
.1 Walkdown of Radioactive Waste Systems a.
Inspection Scope The inspectors reviewed the liquid and solid radioactive waste system description in the UFSAR and the most recent information regarding the types and amounts of radioactive waste generated and disposed. The inspectors performed walkdowns of the liquid and solid radwaste processing systems to verify that the systems agreed with the descriptions in the UFSAR and the Process Control Program, and to assess the material condition and operability of the systems. The inspectors reviewed the current processes for transferring waste resins into shipping containers to determine if appropriate waste stream mixing and/or sampling procedures were utilized. The inspectors also reviewed the methodologies for waste concentration averaging to determine if representative samples of the waste product were provided for the purposes of waste classification in 10 CFR 61.55. During this inspection, the licensee did not conduct waste processing.
b.
Findings No findings of significance were identified.
.2 Waste Characterization and Classification a.
Inspection Scope The inspectors reviewed the licensees radiochemical sample analysis results for each of the licensees waste streams, including dry active waste, resins, and filters. The inspectors also reviewed the licensees use of scaling factors to quantify difficult-to-measure radionuclides (e.g., pure alpha or beta emitting radionuclides). The reviews were conducted to verify that the licensees program assured compliance with 10 CFR 61.55 and 10 CFR 61.56, as required by Appendix G of 10 CFR Part 20. The inspectors also reviewed the licensees waste characterization and classification program to ensure that the waste stream composition data accounted for changing operational parameters and thus remained valid between the annual sample analysis updates.
b.
Findings No findings of significance were identified.
.3 Shipment Preparation a.
Inspection Scope The inspectors observed the preparation of a radioactive spent resin shipment. The inspectors observed the packaging, surveying, labeling, marking, placarding, vehicle checks, emergency instructions, disposal manifest, shipping papers provided to the driver, and the licensees verification of shipment readiness for each shipment. The inspectors also observed the radiation worker practices of the workers preparing the package for shipment to verify that the workers had adequate skills to accomplish the task. The inspectors reviewed the records of training provided to personnel responsible for the conduct of radioactive waste processing and radioactive shipment preparation activities. The review was conducted to verify that the licensees training program provided training consistent with NRC and Department of Transportation requirements.
b.
Findings No findings of significance were identified.
.4 Shipping Records a.
Inspection Scope The inspectors reviewed five non-excepted package shipment documents completed in year 2001 and 2002, to verify compliance with NRC and Department of Transportation requirements (i.e., 10 CFR Parts 20 and 71 and 49 CFR Parts 172 and 173).
b.
Findings No findings of significance were identified.
.5 Identification and Resolution of Problems a.
Inspection Scope The inspectors reviewed a 2002 focus area self-assessment of the Radioactive Material Shipping Program to evaluate the effectiveness of the self-assessment process to identify, characterize, and prioritize problems. The inspectors also reviewed corrective action documentation to verify that previous radioactive waste and radioactive materials shipping related issues were adequately addressed. The inspectors also selectively reviewed years 2001 and 2002 CRs that addressed access control and radioactive waste and radioactive materials shipping program deficiencies to verify that the licensee had effectively implemented the corrective action program.
b.
Findings
No findings of significance were identified.
4.
OTHER ACTIVITIES 40A1 Performance Indicator Verification (71151)
a.
Inspection Scope
The inspectors reviewed whether the licensee was accurately reporting data for the following performance indicators:
Safety system unavailability for the emergency diesel generators; and
Safety system unavailability for the residual heat removal system.
The inspectors reviewed system operating logs and licensee monthly operating reports submitted to the NRC, and interviewed licensee engineering and operations staff to determine whether the performance indicator data was being collected and reported consistent with the guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 2.
b.
Findings
No findings of significance were identified.
4OA6 Meetings Exit Meeting The inspectors presented the inspection results to Mr. K. Schwartz and other members of licensee management at the conclusion of the inspection on April 2, 2002. The
licensee acknowledged the findings presented. No proprietary information was identified.
Interim Exit Meeting The results of the inspection were presented to Mr. Tom Joyce and other members of the licensee management at the conclusion of the inspection on March 5, 2002. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary.
No proprietary information was identified.
KEY POINTS OF CONTACT Licensee K. Schwartz, Plant Manager T. Joyce, Assistant Plant Manager J. Bailey, Regulatory Assurance - NRC Coordinator G. Baker, Security Manager R. Blaine, Radiation Protection Manager T. Coughlin, Radiation Protection Field Superintendent C. Dunn, Engineering Director A. Ferko, Regulatory Assurance Manager L. Guthrie, Maintenance Director F. Lentine, Design Engineering Manager C. Oshier, Radiation Protection Technical Supt Nuclear Regulatory Commission M. Chawla, Project Manager, NRR A. Stone, Chief, Reactor Projects Branch 3 LIST OF ITEMS OPENED, AND CLOSED Opened 50-456/457/02-05-01 NCV failure to use the correct instantaneous current trip setpoint 50-456/457/02-05-02 NCV failure to follow procedures 50-456/457/02-05-03 NCV failure to include appropriate prerequisites in monthly surveillance 50-456/457/02-05-04 URI diesel driven AF pump monthly surveillance testing frequency Closed 50-456/457/02-05-01 NCV failure to use the correct instantaneous current trip setpoint 50-456/457/02-05-02 NCV failure to follow procedures 50-456/457/02-05-03 NCV failure to include appropriate prerequisites in monthly surveillance
LIST OF ACRONYMS AND INITIALISMS USED ADAMS Agencywide Documents Access and Management System AF Auxiliary Feedwater BwOSR Braidwood Operability Surveillance Requirement CFR Code of Federal Regulations CR Condition Report NRC Nuclear Regulatory Commission NRR Nuclear Reactor Regulations PARS Publicly Available Records SDP Significant Determination Process SX Essential Service Water UFSAR Updated Final Safety Analysis Report VIO Violation
LIST OF DOCUMENTS REVIEWED 1R04 Equipment Alignment BwOP AF-E1 Electrical Lineup - Unit 1 Operating Revision 8 BwOP AF-M1 Operating Mechanical Lineup Unit 1 Revision 9 BwOP SI-1 Safety Injection System Startup Revision 13 BwOP SI-2 Safety Injection System Shutdown Revision 8 BwOP SI-M2 Operating Mechanical Lineup Unit 2 Revision 12 AR 00097914 Rework - Failed PMT 1B D/G JW Make Up AR 00098459 Packing and Gland Followers Lack Proper Thread Engagement March 11, 2002 MA-AA-MM-6-00007 Torquing and Tightening of Bolted Connections Revision 0 1R05 Fire Protection Drawing BR-E-05A CT Gypsum for Fire/Air Continuous Conduit End Seals Revision 3 Drawing. BR-E-26 Ceramic blanket Fire/Air/Flood Seal for Capped or Plugged Conduit Sleeves Revision A TR-161 Transco Products Test Report Re: Fire and Hose Stream Tests of TCO-001 Cement.
TCO-002 Medium Density Silicone, and TCO-007 Silicone Adhesive Used in Electrical Conduit and Blockout Penetrations November 20, 1984 TR-207 Transco Products Test Report Re: Fire and Hose Stream Test of Empty Embedded Steel Sleeve and Plugs September 12, 1985 Revision 1 1R06 Flood Protection Measures AR 00076416 Degraded Flood Barrier in RCFCs September 29, 2001 AR 00081432 Proposed DRP 9-049Needs Clarification September 29, 2001
AR 00093970 Watertight Door Found Open with no Personnel in Room February 5, 2002 CR A2001-01036 Degraded Watertight Doors April 6, 2001 WO 970053418 01 Flood Seal Visual Inspection November 2, 1998 WO 99269924 Fire Protection Valve Lubrication February 10, 2002 WO -376141 01 Quarterly Inspection of Watertight Doors January 22, 2002 Review of Shift Operator Logs from January 01, 2001 to March 18, 2002 (Both Units)
BwVS 220-1 Flood Seals Visual Inspection Revision 1 DRP 9-049 Revisions of the Byron and Braidwood Flood Level Calculations Revision 1 1R12 Maintenance Rule Implementation Expert Panel Meeting - Containment spray November 13, 2000 AR00078929 Elevated particulate in 2CS01PA Lower Motor Bearing September 28, 2001 AR 00091032 Concerns Raised During 1A CS Test March 6, 2002 AR 00092363 1B CS Add Tank Flowrate Verification Out of Tolerance February 4, 2002 CR A2001-01157 Work on 1CS009B Preventing Opening 1CS001B After Slave Relay Surv.
April 19, 2001 A2001-01198 1CS009B Limitorque Not Closing Properly in Manual Mode During Maintenance April 18, 2001 1R13 Maintenance Risk Assessments And Emergency Work Control Memo BR-023 Project summary 2/25/02 Work Window for 2AF01PB Revision 3 1BwOL 3.7.5 LCOAR AF System Tech Spec LCO 3.7.5 Revision 2 BwAP 335-1T1 Shift Manager and Unit 1 Supervisor Operator Turnover Log Entries From February 26-27, 2002 Revision 6E1 AR 00098107 1A SX Cubicle Flow 1F1-SX037 Flow Indication Anomaly
AR 00098265 2HD026C Positioned Failed, Bypass Switch Improperly Pinned 1R15 Operability Evaluations A 00091234 Unplanned LCOAR Entry for 2A Diesel Generator January 18, 2002 LS-AA-105-1001 CR 97834 Evaluation of Seismic Capability of Replacement Motor for 2B Diesel-driven AF Pump Gearbox Lube Oil Pump Motor 2AF01PB-C-M Revision 0 CR 89570 AF Diesel Shutdown Solenoid Inappropriate for Application August 2002 CR 96945 MOV Feed Breaker Setting Issues CR 97834 Aux. Lube Oil Motor Weight Discrepancy WO 97122512 01 Replace Motor Aux FW Pump 2B Gear Box Lube Oil Pump March 1, 2001 1R19 Post Maintenance Testing AR 00096945 Potential Rework of 2SX016B Molded Case Breaker Replacement February 25, 2002 WO 99222357 01 Trip Test MCC Breaker - MCC 232X4 Cub A1 2SX016B Molded Case Breaker RCFC 2B & 2D SX Inlet Valve February 25, 2002 DCP/EC 335668 Change the Instantaneous Setting of the Circuit Breaker for 2SX016B February 26, 2002 NEMA Stds Pub AB 4-1996 Guidelines for Inspection and Preventive Maintenance of Molded Case Circuit Breakers Used in Commercial and Industrial Applications 1996 1R22 Surveillance Testing WO 98021782 1S-AF8002: Aux. FW Pump 1B Diesel Eng Speed, Tighten/RPLC G October 20, 1998 WO 99093715 1AF01PB Failed to Start During Routine Surveillance October 6,1999 WO 99220006 01 2P-PC004 CAL of Cnmt Press Channel A March 11, 2002 WO 99220007 01 2P-PC005 Cal of Cnmt Press Electronic Cnmt Press channel B Power Supply March 11, 2002
WO 00385490 1b AFP Failed to Start During Surveillance 1BwOSR December 1, 2001 WO 00385722 01 U2 Train B Slave Relay Surv K632, 639 February 25, 2002 WO 00396391 01 Unit 2 SSPS, Reactor Trip Breaker, Reactor Trip B March 4, 2002 AR 00096800 Configuration Control Event During Slave Relay Testing February 26, 2002 BwAR 2-3-D4 Cnmt Press High Revision 41E1 BwISR 3.3.3.2-206 Surveillance Calibration of containment Pressure Accident Monitoring Loop Revision 1 1BwOSR 3.3.2.7-604B Unit One ESFAS Instrumentation Slave Relay Surveillance (B Train Automatic Safety Injection - K604)
Revision 0E1 1BwOSR 3.3.2.7-632A Unit One ESFAS Instrumentation Slave Relay Surveillance (Train A AF Actuation -
K632, K639)
Revision 0 1BwOSR 3.3.2.7-643A Unit One ESFAS Instrumentation Slave Relay Surveillance (Train A Automatic Containment Spray - K643)
Revision 0 2BwOSR 3.3.2.8-620B Unit Two Slave Relay Surveillance (B Train -
K620 and K633)
Revision 0 NED-I-EIC-0134 Containment Pressure Channel Error Analysis Revision 0 1R23 Temporary Plant Modifications EC 0000335828 001 Temporarily Defeat Traveling Screen High DP Trip for the 1B CW Pump March 7, 2002 AR 00100335 U1 CC Heat Exchanger Setup for Draindown Test Not completed March 25, 2002 AR 00101274 Local Valve Indication Plate for 1SX010 Missing for Excessive March 21, 2002 0Bw0A ORU-8 Auxiliary Building flooding Unit 0 Revision 1WC-AA-101 On-Line Work Control Process Revision 6 Shift Manager Log - Shift 2 March 21, 2002SPP-02-003 Isolation and Drain of the Unit 1 component cooling Heat Exchanger (1CC01A)
Revision 0
2PS2 Radioactive Material Processing and Transportation Focus Area Self-Assessment Report Radiation Protection, Radioactive Material Shipping February 15, 2002 RW-AA-100 Process Control Program for Radioactive Wastes Revision 2 BwRP 5600-13 10 CFR 61 Waste Stream Sampling and Analysis Revision 0 CC-AA-109 Abandoned Equipment Identification, Evaluation and Control Revision 0 RP-AA-600 Radioactive Material/Waste Shipments Revision 5 RP-AA-600-1001 Exclusive Use and Emergency Response Information Revision 0 RP-AA-600-1005 Radioactive Material and Non Disposal Site Waste Shipments Revision 0 RP-AA-601 Surveying Radioactive Waste Shipments Revision 2 RP-AA-602 Packaging of Radioactive Material Shipments Revision 5 Shipment RMS01-016 Rad Material, Y-II March 9, 2001 Shipment RWS01-001 LSA II, Y-II, Filters January 10, 2001 Shipment RWS01-031 LSA II, Y-III, Dewatered Resin May 29, 2001 Shipment RWS01-032 LSA II, Y-III, Dewatered Resin July 1, 2002 Shipment RWS02-001 LSA II, Y-III, Dewatered Resin March 5, 2002 NSP-CC-3011 UFSAR/FPR Change Request Form, Radioactive Waste Systems Revision 1 Training Administrative System Course Completion Report, Transportation February 2, 2002 BW010047 2000 Radioactive Effluent Release Report April 25, 2000 BwRP 5600-13T7 Scaling Factor Determination Cover Sheet (Quarterly)
May 4, 2001 BwRP 5600-13T7 Scaling Factor Determination Cover Sheet (Annual)
July 24, 2001 CR A2001-01233 Inappropriate Radwaste Operations April 26, 2001
CR A2001-01652 No Hard Copies of Radwaste Logs Being Kept June 3, 2001 CR A2001-00068 Radiation Protection Surveys Not Completed January 9, 2001 CR A2001-00480 Radioactive Waste Shipment Improperly Characterized February 13, 2001 CR A2001-01035 Rad Shipment Planned Without Notifying Rad Protection April 6, 2001 AR 00072465 NOS Identified Deficiency in RP Training Records August 16, 2001 40A1 Performance Indicator Verification Braidwood Nuclear Power Plant system Performance Monitoring Plan July 16, 2001 Shift Manager Logs (Unit 1)
March 13, 2001 Shift Manager Logs (Unit 2)
March 13, 2002 RS-AA-122-104 Performance Indicator SSV (HPSI, RHR, AFW/RCIC, EDG) March 1 - May 1, 2001 Revision 3 LS-AA-2040 Monthly PI Data Events for SSV - Emergency AC Power June 25, 2001