IR 05000456/2003009

IR 05000456-03-009(DRP); IR 05000457-03-009(DRP); on 9/22-10/15/2003; Braidwood Station; Units 1 & 2. Accelerated Identification and Resolution of Problems Inspection

ML033210617
Person / Time
Site:	Braidwood
Issue date:	11/14/2003
From:	Ann Marie Stone Division of Nuclear Materials Safety III
To:	Skolds J Exelon Generation Co
References
IR-03-009
Download: ML033210617 (25)

Text

ber 14, 2003

SUBJECT:

BRAIDWOOD STATION, UNITS 1 AND 2 NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 50-456/2003009(DRP); 50-457/2003009(DRP)

Dear Mr. Skolds:

On October 15, 2003, the U. S. Nuclear Regulatory Commission (NRC) completed a team inspection at the Braidwood Station, Units 1 and 2. The enclosed report documents the inspection findings which were discussed on October 15, 2003, with Mr. Thomas Joyce and other members of your staff.

This inspection was an examination of activities conducted under your license as they relate to identification and resolution of problems, and compliance with the Commissions rules and regulations and with the conditions of your operating license. Within these areas, the inspection involved selected examination of procedures and representative records, observations of activities, and interviews with personnel. No violations or findings were identified.

This inspection was conducted on an accelerated schedule because of past findings relating to failure to promptly identify and implement effective corrective action for significant equipment performance problems, which led to a degraded condition for the Mitigating Systems Cornerstone. As a result of this inspection, the team determined that substantial efforts had been made at the Braidwood Station to address the previously-identified issues and that these efforts appeared to be successful. On the basis of the samples selected for review, the team concluded that, in general, your corrective action program had adequately identified, evaluated, and resolved conditions adverse to quality. The team made several observations relating to timeliness and effectiveness of problem identification and resolution as detailed in the enclosed report. 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 50-456/2003009(DRP); 50-457/2003009(DRP)

w/Attachment: Supplemental Information

REGION III==

Docket Nos: 50-456; 50-457 License Nos: NPF-72; NPF-77 Report Nos: 50-456/2003009(DRP); 50-457/2003009(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: September 22 through October 15, 2003 Inspectors: T. Tongue, Project Engineer, Team Leader S. Ray, Senior Resident Inspector B. Jorgensen, Consultant Approved by: Ann Marie Stone, Chief Branch 3 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS IR 05000456/2003009(DRP), 05000457/2003009(DRP); on 09/22-10/15/03; Braidwood Station; Units 1 and 2. Accelerated Identification and Resolution of Problems inspection.

The inspection was conducted by a region-based reactor project engineer, a senior resident inspector and a consultant. No violations or findings of significance were identified.

Identification and Resolution of Problems Issues which were identified during the previous problem identification and resolution (PI&R)

inspection completed in February 2002 and for Supplemental Inspection 95002 Inspection For One Degraded Cornerstone or Any Three White Inputs In A Strategic Performance Area, completed in December 2002 were specifically re-examined. Significant actions had been taken to address these issues, which appeared to be effective.

The team concluded that the licensee adequately identified, evaluated, and resolved problems within the requirements of their corrective action program (CAP). The program was a large-volume, low threshold program, supported by a computerized data base and primarily administered by departmental CAP Coordinators. The significance threshold for entering issues into the corrective action program appeared to be appropriate.

The team developed a number of observations, including:

• The team noted three performance trends which had not been identified by the licensee in a timely manner. This resulted in delayed corrective actions.

• Assessments of numerous radiation protection (RP) problems from outage A1R10 found that many resulted, in part, from unanticipated conditions, which caused a significant mismatch of resources to workload within the fixed schedule. The licensee acted to improve future RP resource flexibility, but did not address workload adjustment.

• The licensee continued to experience minor but recurring problems in some of the areas identified during the previous PI&R inspection in February 2002. While not trending in a negative direction, examples of human performance problems continued to be noted with foreign material exclusion control, rework, and configuration control.

• Through interviews and observations, the team concluded that Braidwood had established a safety-conscious work environment where people were not reluctant to raise issues. Previously identified issues relating to staff unfamiliarity with the then-new processes for entering items into the computerized corrective action program, including ability to track and trend condition- report-related data, have been addressed in part by software improvements and by increased familiarity with the system.

• The team determined that the licensee had completed essentially all of the corrective actions identified in the degraded cornerstone root cause investigation.

2 Enclosure

Report Details OTHER ACTIVITIES (OA)

4OA2 Identification and Resolution of Problems (71152B)

.1 Effectiveness of Problem Identification a. Inspection Scope The team conducted a review and assessment of the licensees processes for identifying and correcting problems at the Braidwood Station. The team reviewed selected plant procedures and program description handbooks, interviewed plant and contractor personnel, and attended various station meetings to understand the stations processes for initiating the corrective action program (CAP) and related activities. The team also reviewed Nuclear Oversight (NOS) Assessments and Operating Experience (OPEX) Reports to determine if problems were identified at the proper threshold and entered into the CAP process.

The team selected a number of condition reports (CRs) and other corrective action documents, primarily generated since the last Problem Identification and Resolution (PI&R) inspection, for more in-depth review.

To assess equipment monitoring, evaluate maintenance rule implementation, and to identify if any issues were missed by the licensee, the team reviewed the past performance of three plant systems. The systems selected were containment spray (CS), station battery/125 volt D.C. system, and auxiliary building ventilation systems.

As part of this assessment, the team interviewed system engineers, reviewed system health reports and system monitoring programs, and performed partial system walkdowns.

From a list of station and departmental self-assessments and audits, the team conducted a review to determine whether the audit and self-assessment programs were effectively managed, and adequately covered the subject areas. In addition, the team interviewed licensee staff regarding the audit and self-assessment programs.

The specific documents reviewed are listed in an Attachment to this report.

b. Issues b.1 Identification Threshold In general, station personnel effectively identified issues at a low threshold and entered problems as CRs into the CAP. The licensee also encouraged the staff to use CRs to report suggested enhancements to station activities or equipment. Upon entry into the CAP, each CR received a priority classification (Priority 1 through 4) according to significance. Enhancements were addressed separately, effectively as category or 3 Enclosure

priority 5. Approximately 6,400 CRs were initiated, exclusive of enhancements since the previous NRC inspection of the problem identification and resolution programs in February, 2002.

Interviews with plant personnel indicated that some employees continued to routinely rely on their supervisors for entering items into the CAP. One concern, which was voiced by a number of interviewees, involved lack of status feedback on an issue to the individual who originally identified it. The licensee indicated that this concern would be addressed by a software enhancement under evaluation which would enable searches of the database by originator.

b.2 Operating Experience The team reviewed Operating Experience (OPEX) information and reports and discussed OPEX program activities during interviews with selected personnel. The team concluded that the process appeared to be functioning well, with one minor exception:

• An OPEX report concerning shelf-life issues with radio-iodine filter cartridges (activated charcoal type) was distributed from the corporate office to station radiation protection departments but was not forwarded to the emergency planning groups, which also utilized radio-iodine filter cartridges (silver zeolite type). The oversight was not identified for several months and was discovered coincidentally during preparations for an external audit.

b.3 Nuclear Oversight The team noted consistent involvement of the Braidwood Nuclear Oversight (NOS)

group in the CAP process. The group identified numerous technical issues and aggressively identified adverse trends in performance across the spectrum of areas they assessed. Further, NOS had developed a high-intensity field-observation-based approach to conducting oversight during the first few days of a station refueling outage.

This process was intended to promptly identify worker performance issues and, where possible, get the issues corrected on the spot. The team concluded that NOS appeared to have a positive influence in problem identification and resolution across a number of areas of station performance.

b.4 Selected System Review The team performed an indepth review of the: containment spray, auxiliary building ventilation, and the station batteries/125-volt DC systems, and concluded that the licensee appropriately placed conditions adverse to quality into the CAP. More information on observations is in Section 4OA2.2b.3 of the report.

4 Enclosure

.2 Review and Evaluation of Issues a. Inspection Scope The team reviewed previous inspection reports and corrective action documents generated since February, 2002. In selected cases, documents were reviewed which reflected activities in areas of interest over the past five-year period. The team reviewed selected Apparent Cause Evaluations (ACE), Root Cause Reports (RCR), prompt investigations, operability determinations and Common Cause Analyses (CCA) to independently verify that identified issues were appropriately prioritized and evaluated when entered into the licensees corrective action program. During this review, the team focused on the technical adequacy of the cause determinations, extent of condition reviews including evaluations of potential common cause or generic concerns, and the appropriateness of the corrective actions. In addition, the team also assessed the adequacy of the operability and reportability determinations.

The team selected several items to ensure proper implementation of the Maintenance Rule. This included verifying that the functional failures and unavailability time were properly counted and tracked.

Other attributes reviewed by the team included the quality of the licensees trending of conditions and the corresponding corrective actions. The team searched for items or issues which looked like potential trends and assessed whether the licensee had appropriately identified and captured these trends within the corrective action program.

The team also assessed licensee corrective actions stemming from previous Non-Cited Violations (NCVs) and Licensee Event Reports (LERs).

This review included the controlling procedures, selected records of activities, and observation of various licensee meetings. In addition, the team conducted several interviews with cognizant licensee personnel.

The specific documents reviewed are listed in an Attachment to this report.

b. Issues b.1 Overview of Prioritization and Evaluation Process Condition Reports and Assignment Reports were entered into the computerized data base by any member of the Braidwood Station staff. Daily, the reports from the previous day were collected for a morning review by a committee of Departmental CAP Coordinators. The CAP coordinators reviewed the items, focusing on their respective areas of specialization. Discussions addressed appropriate actions to recommend to management, including who should be assigned to complete those actions.

Reportability, repetitiveness, and trending were discussed as appropriate.

Management evaluation was essentially continuous with daily Management Review Committee (MRC) meetings which reviewed document packages accumulated since the previous meeting. This committee served to review and oversee the significance, classification, and disposition determination of CRs which may include further 5 Enclosure

assignments, and investigations such as; root cause analysis, apparent cause evaluations, or common cause analysis. In addition, the MRC ensured followup on NRC issues and the appropriateness of corrective actions.

As previously noted, the licensee utilized a graded process to prioritize CRs by perceived significance. This type of process was necessary with a large, low-threshold program so that resources were not over-invested in trivial events. The team noted that, of the approximate 6,400 events in the data base (excluding enhancements) since the last previous PI&R inspection in February 2002, only 29 events were classified as significant conditions adverse to quality for which Root Cause assessments were performed.

Inspection team members attended both CAP Coordinator and Management Review Committee meetings to observe processing of corrective action documents. The team did not identify instances of significant disagreement with the priority classification or disposition of the corrective action documents at those meetings.

b.2 Trending The licensee regularly performed analyses of CRs for adverse trends using the Station's Coding and Trending Manual as guidance. Although the licensee initiated 72 CRs relating to potential or actual adverse trends in performance of some activity, further evaluation showed no actual decline in performance in most cases. When genuine declines in performance were identified, the licensee initiated Apparent, Common or Root cause evaluations as appropriate to understand the adverse trend and to determine appropriate corrective actions. The team noted that since the last inspection, the licensee continued to monitor human performance and equipment performance trends. These issues were long-standing and are discussed in Section 4OA2.3.b.1.

The team independently reviewed a sample of condition reports, generated between February 2002 and September 2003, and identified one trend which was not previously identified by the licensee and two issues which were not identified by the licensee in a timely manner. These included:

• The team identified that, between February and November 2002, six failures and one out-of-tolerance for the same model pressure switch used on the diesel generators occurred. As each switch failed, it was replaced with a switch of a new model because the old one was obsolete. The team did not have an operability concern because trips initiated by the pressure switches were automatically overridden during an emergency start. However, the team noted that the licensee had not identified the multiple failures of the same model switch as an adverse trend. The team also noted that the corporate procedure EA-AA-520, Instrument Performance Trending, Revision 3, required that instruments found out-of-tolerance be trended, but did not require failed instruments to be trended.

• Prior to May 2003, a number of chemical control issues were entered in the CAP program; however, a performance trend was not identified by the department CAP coordinator. In May 2003, after overhearing a discussion between the Site 6 Enclosure

Vice President and chemistry department personnel, the station CAP Coordinator initiated a potential trend CR. Once confirmed that repetitive problems had occurred, the licensee initiated a Functional Area Self Assessment (FASA) and implemented corrective actions including staff training. The team noted this late recognition of the trend delayed the implementation of corrective action.

• In 2002 and 2003, the licensee initiated several CRs related to exceeding monthly station radiation exposure (dose) goals. In July 2003, the licensee performed Common Cause Analysis (CCA) and identified two significant common causes, including non-inclusion of emergent work in the development of the goals and the necessity to estimate doses for many jobs before final details on job staffing and work requirements were known. The team noted that Braidwood Station cumulative doses were not high; however, earlier recognition of this issue could have contributed to achieving even lower doses.

b3. Selected Systems Evaluation of Issues for the Selected Systems The team reviewed condition reports and work orders associated with the three systems listed below and concluded that the licensee adequately prioritized and evaluated the adverse conditions. Specifically:

• 125Vdc system. In January of 2002, the licensee included this system in the stations Chronic Problems program, due to a prolonged history of grounds. An assessment was performed, yielding several recommendations including collecting highly sensitive baseline data on all four trains and development of a procedure to assist operators in locating and isolating grounds. The team concluded that while chronic, the grounds had not adversely affected system availability to function. The team also noted that the procedure for locating and isolating grounds was completed September 3, 2003; however, use of this procedure was optional (a work request could be initiated instead). Despite numerous grounds on two different trains in mid-September 2003, operators were unable to use the procedure because the grounds were transient. The team concluded that the licensee appropriately evaluated the systems performance; however, the team could not assess the effectiveness of the corrective actions.

• Auxiliary building ventilation system: The licensee identified several problems with the system and noted that the system had not been operating as designed since original construction. Several effective corrective actions were implemented such as damper repairs and adjustments, and fan blade adjustments which has resulted in improved performance within the past 5 years.

The team did not identify any concerns with respect to the operability or evaluation of the system.

• Containment Spray: The team conducted a detailed followup of an issue involving the determination of the correct acceptance criteria for sodium hydroxide eductor flow to use during surveillance tests. No operability concerns 7 Enclosure

with the system were identified and the team determined that the CAP process was effectively used for the CS system.

b.4 Focused Area Self-Assessments Focused Area Self-Assessments (FASA) were a corrective action tool which the licensee was using in both a proactive and a reactive manner to gather information and evaluate it. On the reactive side, FASAs were regularly conducted to evaluate a perception that an adverse trend in performance had occurred or was occurring. These assessments were an important factor in segregating out any genuine declines in performance so that appropriate attention could be directed to corrective action. On the proactive side, FASAs were performed in a variety of areas in preparation for auditing or inspection at Braidwood by an outside organization, including this NRC inspection of PI&R. These assessments amounted cumulatively to a self-initiated PI&R by the licensee. They were typically performed by the CAP Coordinators. The team reviewed selected FASA reports, and some resultant CRs, and concluded the process was being effectively implemented and that the results were valuable in directing corrective action resources efficiently and effectively.

b.5 Scope of Evaluations The team examined corrective action documentation and conducted interviews with station personnel with a focus on whether the licensee was addressing issues in a comprehensive manner, such that they were clearly understood, and the team verified that a broad range of options was appropriately considered when determining corrective action(s) for identified problems. The licensees evaluations were found to be broadly-based and inclusive of diverse options, with the following exception:

• During the April 2003 refueling outage (A1R10), a large number and variety of radiological control problems including difficulties in control of contamination (personnel, equipment and areas), deteriorating rad-worker practices, and ineffective use of the corrective action program by radiation protection staff were identified. The licensee initiated two Root Cause Reports to address over 90 CRs and Common Cause reviews, staff and contractor interviews, and multiple outage planning and implementation documents. The licensee determined that failed leadership by the radiation protection management was a contributing cause. However, the team noted that the licensee did not consider addressing the resource/challenge mismatches by reducing the pace or content of the outage schedule.

.3 Effectiveness of Corrective Action a. Inspection Scope The team reviewed selected CRs and associated corrective actions to evaluate the effectiveness of corrective actions, verifying that corrective actions, commensurate with the safety significance of the issues, were identified and implemented in a timely manner, including corrective actions to address common cause or generic concerns.

The team also verified the implementation of a sample of corrective actions. In addition, 8 Enclosure

the team reviewed a sample of corrective action effectiveness reviews completed by the licensee. The samples were selected based on their importance in reducing operational risks and recurring problems. The team focused on information recorded since February 2002, but selected items were reviewed going back over a 5-year period.

The team also re-examined several previously-identified findings and issues to assess the effectiveness of the corrective actions. This included a sampling of NRC-identified issues that did not become findings, previously identified NCVs, and issues from the previous PI&R inspection. The teams review of the corrective actions to address the supplemental inspection for the degraded cornerstone is addressed in Section 4OA2.4 of this report.

The licensees CAP allowed corrective action tracking items to be closed once the work control process was initiated. Therefore, the team also reviewed the status of a number of work requests created as corrective actions for the period covered by the inspection, to ensure the work requests accurately reflected the item to be corrected and that they were not subsequently canceled or excessively postponed. In all cases, there was adequate documentation to demonstrate that corrective actions were completed, or valid justification for not performing the action(s) was provided when appropriate.

The specific documents reviewed are listed in an Attachment to this report.

b. Issues b.1 Previously-Identified Problems During the review, the team noted recurring problems associated with contractor control, foreign material exclusion (FME) control, and rework issues. These areas were identified as concerns in the previous NRC inspection of problem identification and resolution in February, 2002. Although the team noted some improvement in the overall trend, the licensee acknowledged the response was not as expected and planned additional corrective action to improve performance.

b.2 Corrective Actions to Address Previously-Identified Findings The team reviewed the licensees corrective actions associated with selected licensee event reports, previous non-cited violations, and NRC identified concerns and concluded that with one exception, the licensees proposed actions were completed in a timely manner and that the actions appeared appropriate as evidenced by the lack of repeat problems. The inspectors observed the following:

• The corrective actions for finding 50-456/02-03-02 for failure to properly set the trip setpoint for a circuit breaker were not effective, in that, two repeat occurrences were identified with two additional findings as documented in Inspection Reports 50-456/02-05; 50-457/02-05 and 50-456/03-02; 50-457/03-02.

9 Enclosure

b.2 Comprehensiveness The inspection team reviewed many licensee corrective actions through to completion, to ensure the actions identified and decided upon were actually implemented. This included a number of examples where one CR was closed to the actions of another, examples where multiple CRs were encompassed under a higher-level corrective action, and examples where CRs were closed to a Work Request (WR). The team concluded that corrective actions were complete and traceable to have been implemented as planned with the following exception:

• The actions for CR #00154546, which reported on premature (immediate) failure of new parts installed into a 125V D.C. charger, included a process change to ensure future new parts would be pre-tested on site prior to installation. The inspectors identified that the licensee had not established interim corrective actions to ensure that the testing would be complete prior to the formal process change. In fact, the inspectors noted that during this inspection period, new parts had been received. Testing was conducted only because an electrical maintenance individual recalled the long term corrective actions.

b.3 Timeliness The licensees CAP was intended to establish timeliness of corrective actions primarily on the basis of perceived safety significance and priority. The team determined that this process was normally functioning in an acceptable manner and achieving that objective.

For issues of lower priority, the team noted that some actions were delayed, or temporary fixes were left in effect over a prolonged period. For example:

• After a few events involving elevated levels of dissolved oxygen in the Unit 1 condensate and feedwater system, caused by in-leakage at a booster pump seal, the licensee processed an Engineering Change Notice (ECN) to put in place a temporary fixture to supply a nitrogen over-pressure on the seal. Seal replacement was not promptly scheduled. Thereafter, operations personnel twice failed to replenish the nitrogen supply in a timely manner, causing two additional dissolved oxygen excursions. The seal was scheduled to be replaced in December 2003.

b.4 Documentation The team noted several reports of licensee-identified examples of inappropriately closed CRs. These were mostly identified by CAP Coordinators, who were performing FASA reviews preparatory to the start of this PI&R inspection. The team reviewed selected examples and found the licensees review had been very challenging; the types of items identified as wanting in the documentation, while not literally in compliance with established expectations, were not significant. The team did not identify any additional examples of inappropriately closed CRs.

The team also noted instances of licensee-identified failures of documentation packages to contain complete, stand alone content. These were also selectively reviewed. The team found no significant issues in these examples.

10 Enclosure

.4 Corrective Actions for Mitigating Systems Degraded Cornerstone a. Inspection Scope As stated in Supplemental Inspection Report 50-456/02-10, the primary reason for the NRC conducting this PI&R inspection at earlier than the normal biennial frequency was to assess the mitigating systems degraded cornerstone corrective actions that were not yet complete at the time of the supplemental inspection.

The team reviewed progress on all corrective actions from the licensees degraded cornerstone root cause investigation (CR 113947) and conducted a more detailed review of 15 of those actions.

b. Issues The team determined that the licensee had completed essentially all of the corrective actions identified in the degraded cornerstone root cause investigation. This included numerous action items added when new issues were identified while completing the original actions. The only exceptions to having all actions complete were some long-term effectiveness reviews. In addition, recurring actions such as the periodic Mitigating Systems Readiness Reviews were continuing. Results worthy of comment from this inspection activity were as follows:

• ATIs 113947-06 and 113947-75 dealt with developing training to improve the quality of apparent cause evaluations (ACEs) and root cause reports (RCRs) and evaluating the effectiveness of that training. Those actions were considered a success based on the teams reviews of the trends in ACE and RCR rejection rates which had both improved significantly. The team interviewed the site CAPCO and reviewed procedures and documents to determine that the standards for rejecting an ACE or RCR had not declined, which could have led to a false indication of improvement.

• ATIs 113947-16 and 113947-87 dealt with an extent of condition review to determine if Engineering Change Requests (ECRs) that were canceled, had sufficient justification for cancellation. The licensee determined that 20 out of 403 ECRs they reviewed needed more followup or documentation to justify their cancellation. The team determined that two of those followups still had documentation shortcomings. The licensee initiated CR 177534 to address and correct this NRC-identified issue. The team reviewed a list of 134 ECRs canceled in 2003 to determine if documentation had improved since completion of the licensees corrective action. The team noted that, in general, documentation of the reason for cancellation was sufficient. However, the team identified 2 ECRs that contained no justification. The licensee determined that those 2 were ECR numbers that had been opened in error and no associated ECRs had ever actually existed. The team noted that a large number of ECRs were apparently opened in error, indicating a possible training issue.

11 Enclosure

• The team identified that ATI 113947-68 discussed opening a new ATI which was listed as ATI 113947-97. The correct new ATI number was 113947-96. The licensee initiated CR 177534 to address and correct this NRC-identified typographic error.

• ATIs 113947-30 and 113947-51 dealt with performing an initial and periodic aggregate review of risk significant systems to identify vulnerabilities to nuclear safety. The team reviewed the status of the 17 system vulnerabilities identified in the first aggregate review as part of the degraded cornerstone root cause investigation, and the first periodic review conducted in 2003. This program, conducted in accordance with engineering procedure BwVP 1700-1, Mitigating System Readiness Review, Revision 1, appeared to be a success. Of the original 17 vulnerabilities, 10 were adequately addressed and removed from the list. However, 8 new vulnerabilities were identified in the 2003 review and added to the list. This demonstrated that the program was robust and was adding value. The team understood that the program was being??

considered for incorporation by the rest of the nuclear stations in the company.

• The team identified one concern with the licensees action to address the vulnerabilities identified by the aggregate reviews. The hydraulic governors on the diesel generators had been identified as obsolete and difficult to repair or replace with the plant on line. Three of the four governors had been replaced with a newer model. However, the fourth governor, for the 2A diesel generator, had not been replaced and its scheduled replacement had been deferred through three consecutive refueling outages, including the upcoming one. The reason for the deferrals was stated as schedule and budget constraints. The team was concerned that the licensee gave no indication that schedule and budget issues would be any more conducive for the work in future outages.

However, the team was informed that consideration was being?? given to conducting the replacement with the plant on line. There were no immediate operability concerns because the governor was performing well and the licensee had an inventory of spare parts from the three governors removed from the other diesels.

Overall, the team concluded that the licensee was taking adequate and timely corrective actions to address the issues identified in its mitigating system degraded cornerstone root cause report.

12 Enclosure

4OA4 Cross Cutting Aspects of Findings Safety-Conscious Work Environment a. Inspection Scope The team interviewed numerous members of the plant staff, representing several different work groups at various levels, to assess the establishment of a safety conscious work environment.

During the interviews, document reviews, and observations of activities, the team looked for evidence that plant employees might be reluctant to raise safety concerns. The interviews typically included questions similar to those listed in Appendix 1 to NRC Inspection Procedure 71152, Suggested Questions for Use in Discussions with Licensee Individuals Concerning PI&R Issues. The team also reviewed the stations procedures related to the Employee Concerns Program, (ECP) and discussed the implementation of this program with the stations program investigator/coordinators.

The team also reviewed associated procedures and several case reports to verify compliance.

b. Issues No significant findings were identified. None of the plant staff members interviewed expressed concerns regarding a safety-conscious work environment. All staff members said individuals were encouraged by management to identify issues and bring them to managements attention or enter them into the CAP. For staff members who were not proficient at making CAP entries, management personnel entered the issue into CAP, or helped the staff members with the system. The team noted that the CAP program was used more than in the past and individuals were not avoiding entering issues into the CAP due to fear of being assigned actions to address them (boomerang effect)

especially during heavy work loads.

When questioned about their knowledge of the ECP, all staff members said they were aware of it and could name the ECP Coordinators. Staff members did not express any significant reluctance to use the ECP and no one stated that they knew anyone who had a negative experience using the ECP. When asked if they actually knew anyone who had brought a concern to the ECP, none of the staff members interviewed could name anyone. This indicated that the confidentiality of the ECP was rigorously maintained. In addition, everyone interviewed also knew of the availability of the NRC.

13 Enclosure

4OA6 Meetings Exit Meeting The team presented the inspection results to Mr. Thomas Joyce and other members of licensee management on October 15, 2003. The licensee acknowledged the findings presented. The team confirmed with the licensee that proprietary information was examined during the inspection; however, this was not specifically discussed in this report.

ATTACHMENT: SUPPLEMENTAL INFORMATION 14 Enclosure

SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensee M. Pacillio, Site Vice President T. Joyce, Plant Manager E. Stefan, Regulatory Assurance - NRC Coordinator G. Baker, Security Manager G. Dudek, Operations Manager C. Dunn, Engineering Director K. Root, Regulatory Assurance Manager C. Chovan, Work Management Director B. Stoffels, Maintenance Director F. Lentine, Design Engineering Manager R. Gilbert, Nuclear Oversight Manager J. Moser, Radiation Protection Manager Nuclear Regulatory Commission A. Stone, Chief, Reactor Projects Branch 3 LIST OF ITEMS OPENED, AND CLOSED Opened None Closed None 1 ATTACHMENT

LIST OF DOCUMENTS REVIEWED Action Requests (AR) and Condition Reports (CR)

1. 00091032 Concerns Raised During 1A CS Test 1/17/2002

1. 00032363 1B CS Additive Tank Flowrate Verification 1/25/2002 Out-of-tolerance

1. 00096132 B3 Trend Code: 1PSH-DG104B Out-of- 2/22/2002 tolerance

1. 00096140 B3 Trend Code: 1PS-DG110B Out-of- 2/21/2002 tolerance

1. 00096145 B3 Trend Code: 1PSH-DG100B Out-of- 2/21/2002 tolerance

1. 00096151 B4 Trend Code: 1PSH-DG099B Out-of- 2/21/2002 tolerance Low

1. 00096800 Configuration Control Event During Slave 2/26/2002 Relay Testing

1. 00100618 Preconditioning of 1B Auxiliary Feedwater 3/22/2002 Diesel Engine

1. 00112250 B3 Trend Code: 1PSH-DG101B Erratic 6/18/2002 and Required Replacement

1. 00113947 Mitigating Systems Cornerstone Degraded 7/1/2002

- Equipment Issues

1. 00126301 NRC Notes on Valve Lineup Missing Label 10/8/2002 and Incorrect Location

1. 00123878 Discrepancy Between the Updated Final 9/20/2002 Safety Analysis Report and the Auxiliary Building Flood Calculation

1. 00128631 Potential for Floor Drain Clogs (Rags 10/23/2002 Collecting Seepage)

1. 00131269 B3 Trend Code: 2PSH-DG100A Found 10/12/2002 Out-of-tolerance

1. 00132313 FASA - Quality of System Engineering 11/19/2002 Notebooks

1. 00133091 Potential Vulnerability - CRs During Work 11/25/2002 Package Closeout 2 ATTACHMENT

1. 00138825 Gap Under Door Does Not Match Flood 1/9/2003 Calculation Assumption

1. 00145697 NRC Question Regarding PR011J 2/21/2003 Particulate Filter Changeout

1. 00171644 Trending of CAP Data Not Consistently 8/14/2003 Performed Across Departments

1. 00175022 Train A CS Spray Additive Flow Rate Out 9/9/2003 of Specification High

1. 00177534 PI&R Inspection, ATI Closure 9/25/2003 Documentation Discrepancies [NRC-Identified]

164997-01 Revise BwHS TRM 3.8.c.4 See In progress 9/30/2003 Notes for Assignment Description

1. 00115772 Potential trend in Chemistry - 7/17/2002 missed/delayed samples

1. 00157839 Potential trend in Chemical Control issues 5/8/2003 (storage/permits)

1. 00165485 Chemical Control FASA: Deficiencies 6/30/2003 Noted

1. 00158929 Unsatisfactory Attendance - Chemical 5/15/2003 Control Monthly Meeting

1. 00152162 High failure rate on rad worker portion of 4/3/2003 GET exam

1. 00154291 Elevated Dose Rates noted during 4/16/2003 containment initial surveillance

1. 00156006 Lack of rad protection presence/oversight 4/27/2003 during outage

1. 00168893 Monthly Collective Radiation Exposure 7/24/2003 Exceeds Goals

1. 00169830 Exelon Sites Monthly Exposure Goals 7/31/2003 Routinely Exceeded

1. 00156195 Potential Trend - rad worker practices and 4/28/2003 housekeeping

1. 00156066 Management unwilling to write CRs for fear 4/28/2003 of action items

1. 00106704 EP PI for drill participation declining trend 5/3/2002 3 ATTACHMENT

1. 00119990 EP Improvement Items for ERO 8/22/2002 Performance

1. 00120015 EP Deficiencies Identified for ERO 8/20/2002 Performance

1. 00123560 NOS IDd ERO Performance Deficiencies 9/19/2002 During Pre-exercise

1. 00161586 Silver Zeolite cartridges past vendor 6/3/2003 recommended shelf life

1. 00162151 NOS IDd (EP) Potential Adverse Trend EP 6/5/2003 Equipment Readiness

1. 00167048 ERO Performance Issues from 2nd quarter 7/10/2003 EP mini-drill

1. 00131704 Declining Trend in Security Human 11/14/2002 Performance

1. 00166046 Security identified areas for improvement 7/2/2003 from LLEA drill

1. 00170879 Increased Number of Security Violations 8/8/2003 During 2nd Qtr. 2003

1. 00119097 Loss of FME Integrity for 111, 112, 211 8/13/2002 and 212 ESF Batteries

1. 00119539 Foreign Material in Battery 111 cell 24 8/16/2002 (1/4 inch material)

1. 00135759 Problems noted in Battery 211 Quarterly 12/13/2002 Surveillances

1. 00165384 DC Battery 211 temperature and voltage 6/28/2003 above admin limit

1. 00154546 Repeat Maint - Various Battery Charger 4/18/2003 112 Maint. Problems

1. 00155743 125 v dc Battery 112 surveillance failed - 4/25/2003 high float current

1. 00179195 Several events in Operations warrant 10/3/2003 Common Cause Analysis

1. 00095525 Elevated WS Strainer D/Ps due to lake 2/17/2002 control issues

1. 00129687 Mitigating Systems Review Vulnerabilities 10/31/2002 Tracking 4 ATTACHMENT

1. 00086970 Perform FASA On Clearance Orders in 9/30/2003 Operating Department

1. 00108783 Procedure Adherence Identified As 5/20/2002 Common Cause For Configuration Control

1. 00119319 Rework-2A turbo thrust bearing trip - 8/14/2002 unplanned LCO

1. 00122579 Late Technical Specification sample - 9/12/2002 Surveillance 3.4.18.2

1. 00141389 Manual lineup of VC in emergency mode 1/27/2003 (unplanned LCO entry)

1. 00157367 Entry into 1BwOA PRI-4 due to High RCS 5/5/2003 Activity on 1PR06J

1. 00166634 Elevated Unit 2 RCS Xe-133 due to a Fuel 7/8/2003 Leak Plant Procedures and Audits LS-AA-125 Corrective Action Program (CAP) Revision 5 Procedure LS-AA-125-1001 Root Cause Analysis Manual Revision 3 LS-AA-125-1002 Common Cause Analysis Manual Revision 2 LS-AA-125-1003 Apparent Cause Evaluation Manual Revision 2 LS-AA-125-1005 Coding and Trending Manual Revision 3 BR-40 Braidwood Station Policy Memorandum Revision 0 Expectations for Extending Condition May 22, 2003 Report Cause Investigations and Corrective Action Due Dates BwAr 1-21-D6 125V DC BUS 111 GROUND Revision 8 BwOP AN-5 GROUND ISOLATION FOR THE PLANT Revision 5E2 ANNUNCIATOR SYSTEM 1BwOS DC-1a AAR *125 VDC ESF BUS GROUND Revision 4 BwOP DC-23-212 125V DC BUS 212/214 GROUND Revision 0 DETECTION BwVP 1700-1 Mitigating System Readiness Reviews Revision 1 ER-AA-520 Instrument Performance Trending Revision 3 5 ATTACHMENT

EI-AA-101-1001 EMPLOYEE CONCERNS PROGRAM Revision 0 EI-AA-101-1002 EMPLOYEE CONCERNS PROGRAM Revision 0 TRENDING TOOL ECP CONCERNS TREND SUMMARYS 2002 and 2003 Instrument Performance Trending Report October 1, 2002 02/2002 to 07/2002 (Report 6)

Instrument Performance Trending Report October 2, 2003 08/2002 to 07/2003 (Report 7)

Focused Area Self-Assessment; Problem August 19, 2003 Identification and Resolution Braidwood Nuclear Oversight Biweekly August 23, 2003 Issues through September 5, 2003 NOSA-BRW-03-01 Corrective Actions Program Audit Report February 14, 2003 NOS Audit NOSA-BRW-03-05 NOS Engineering Design Control Audit August 1, 2003 Exit Report Completed Cause Evaluations and Reports RCR 154291 Elevated, Unanticipated Contamination 6/5/2003 Levels during A1R10 Due to Crud Loading on High Axial Offset Anomaly Demo. Fuel Assemblies CCAR 156195 Trend identified with Radiation Protection 5/12/2003 issues during A1R10 CCAR 168893 Potential Trend in Braidwood Failure to 9/17/2003 Meet Monthly Radiation Exposure Goals RCR 164043 Failure of Radiation Protection 9/2/2003 Management and Leadership to control radworker events during A1R10 because RP fundamentals were not communicated to and enforced upon the station workforce RCR 955925 Elevated WS Strainer D/Ps due to lake 4/9/2002 control issues ACIT 86970 Perform FASA on Clearance Orders in 9/30/2003 Operating Department 6 ATTACHMENT

CCA 161551 Configuration Control Events June 2002 to 6/30/2003 June 2003 CCA 152418 Configuration Control Events April 2002 to 4/4/2003 April 2003 CCA 143888 Configuration Control Events July 2002 to 3/10/2003 March 2003 RCR 108783 Procedure Adherence Identified as a 7/26/2002 Common Cause for Configuration Control ACE 119319 Rework-2A DG turbo thrust bearing trip - 9/27/2002 Unplanned LCO RCR 122579 Late TS sample for Surveillance 3.4.18.2 10/11/2002 RCR 141389 Manual lineup of VC in emergency mode 3/17/2003 (Unplanned LCO entry)

RCR 157367 Entry into 1BwOA PRI-4 due t High RCS 5/5/2003 Activity on 1PR06J RCR 166634 Elevated Unit 2 RCS Xe-133 due to a Fuel 8/26/2003 Leak ATI 164997-01 Revise BwHS TRM 3.8.c.4 See In 9/30/2003 progress Notes for Assignment Description 7 ATTACHMENT

LIST OF ACRONYMS USED ACE Apparent Cause Evaluation ATI Action Tracking Item CAP Corrective Action Program CAPCO Corrective Action Program Coordinator CCA Common Cause Analysis CR Condition Report CS Containment Spray System DRP Division of Reactor Projects ECP Employee Concerns Program ECR Engineering Change Request EP Emergency Planning FASA Focused Area Self Assessment FME Foreign Material Exclusion LER Licensee Event Report NCV Non-Cited Violation NOS Nuclear Oversight NRC Nuclear Regulatory Commission OPEX Operating Experience PI&R Problem Identification and Resolution RCR Root Cause Report VA Auxiliary Building Ventilation WR Work Request 8 ATTACHMENT