IR 05000456/2010006

IR 05000456-10-006, 05000457-10-006 on 08/30/2010 - 09/17/2010, Braidwood Station, Units 1 and 2, Identification and Resolution of Problems

ML103000130
Person / Time
Site:	Braidwood
Issue date:	10/27/2010
From:	Eric Duncan Region 3 Branch 3
To:	Pacilio M Exelon Generation Co, Exelon Nuclear
References
IR-10-006
Download: ML103000130 (37)

Text

October 27, 2010

SUBJECT:

BRAIDWOOD STATION, UNITS 1 AND 2, NRC BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000456/2010006; 0500457/2010006

Dear Mr. Pacilio:

On September 17, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Braidwood Station, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on September 17, 2010, with Mr. L. Coyle and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission=s rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

On the basis of the samples selected for review, the team concluded that in general, problems were properly identified, evaluated, and corrected. There were two NRC-identified findings of very low safety significance associated with the failure to evaluate auxiliary feedwater system operability and failure to take timely corrective actions to perform a necessary piping analysis.

The findings were determined to be violations of NRC requirements. However, because of their very low safety significance, and because the issues were entered into your corrective action program, the NRC is treating the issues as Non-Cited Violations (NCVs) in accordance with Section 2.3.2 of the NRC Enforcement Policy.

In addition, several examples of minor problems were identified, including untimely issue report evaluations, and untimely corrective actions.

If you contest the subject or severity of a NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U. S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Braidwood Station. In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at the Braidwood Station. The information you provide will be considered in accordance with Inspection Manual Chapter 0305.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC=s document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Eric R. Duncan, Chief Branch 3 Division of Reactor Projects Docket Nos. 50-456; 50-457 License Nos. NPF-72; NPF-77

Enclosure:

Inspection Report No. 05000456/2010006 and 05000457/2010006 w/Attachment: Supplemental Information

REGION III==

Docket Nos: 50-456; 50-457 License Nos: NPF-72; NPF-77 Report Nos: 05000456/2010006 and 05000457/2010006 Licensee: Exelon Generation Company, LLC Facility: Braidwood Station, Units 1 and 2 Location: Braceville, IL Dates: August 30, 2010, through September 17, 2010 Team Leader: R. Ng, Project Engineer Inspectors: J. Benjamin, Senior Resident Inspector, Braidwood J. Gilliam, Reactor Inspector L. Jones, Reactor Inspector A. Scarbeary, Reactor Engineer M. Perry, Resident Inspector, Illinois Emergency Management Agency Approved by: E. Duncan, Chief Branch 3 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000456/2010006; 05000457/2010006; 08/30/2010 - 09/17/2010; Braidwood Station,

Units 1 and 2; Identification and Resolution of Problems.

This inspection was conducted with region-based inspectors, the NRC Senior Resident Inspector at the Braidwood Station, and the onsite Illinois Emergency Management Agency inspector. The significance of most findings is indicated by their color (Green, White, Yellow,

Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,

Revision 4, dated December 2006.

Identification and Resolution of Problems The inspectors concluded that the licensees Corrective Action Program (CAP) in general was effective in identifying, evaluating, and correcting issues at the site. The licensee had a low threshold for identifying issues and entering them into the CAP. Overall, the issues were properly prioritized and evaluated based on plant risk and uncertainty. Corrective actions, when specified, were generally implemented in a timely manner, commensurate with their safety significances. The use of operating experience was integrated into daily activities and was found to be effective in preventing industry identified issues from occurring at the site. In addition, the licensees self-assessments, audits, and effectiveness reviews were thorough and effective in identifying site performance deficiencies, programmatic concerns, and improvement opportunities. On the basis of the interviews conducted, site personnel were free to raise safety concerns through the established processes.

There were two Green findings with the associated Non-Cited Violations (NCVs) identified by the team during this inspection. The findings were related to the licensees failure to perform an operability determination per procedure for a condition adverse to quality and to perform timely corrective actions for a previously identified violation.

NRC-Identified

and Self-Revealed Findings

Cornerstone: Mitigating Systems, Barrier Integrity

• Green: The inspectors identified a Green finding and an associated NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, when licensee personnel failed to adhere to Operability Determination Procedure OP-AA-108-115 after identifying a potential auxiliary feedwater (AFW)system design vulnerability. Specifically, since May 15, 2007, the licensee had questioned the motor-driven AFW systems capability to effectively transfer its water source from the Condensate Storage Tank (CST) to the essential service water system during a hypothetical catastrophic failure of the non-seismic CST. The lack of involvement in bringing this issue to the attention of the operating crew, lack of quality in evaluating the issue, and length of time the questions had been unanswered were not consistent with the Operability Determination process. The licensee entered this issue into their CAP as Issue Report (IR) 1114604. Corrective actions planned included performing an Operability Evaluation and a corrective action assignment to ensure a rigorous evaluation was performed on the motor-driven AFW pumps motor and breaker.

The inspectors determined that this issue was more than minor in accordance with IMC 0612, Appendix B, Issue Screening, because the issue was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the AFW pump operability was not fully evaluated by the licensee. The finding was of very low safety significance because the issue was not a confirmed loss of operability and did not represent a risk significant issue based on the plants design backup capability to remove decay heat via the primary feed and bleed method. This finding had a cross-cutting aspect in the area of Human Performance for Decision-Making (H.1(a)). Specifically, the licensee did not make a safety-significant or risk-significant decision using the Operability Evaluation systematic process, especially when faced with uncertain or unexpected plant conditions involving a potential design vulnerability to the plant to ensure safety was maintained. (Section 4OA2.1.b.2.c)

• Green: The inspectors identified a Green finding and an associated NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, when licensee personnel failed to promptly correct a previously identified NCV regarding the lack of analysis for water hammer loads on the Recycle Holdup Tank (RHUT) inlet piping induced by Residual Heat Removal (RHR) system relief valve discharges. Specifically, the licensee failed to complete the necessary piping analysis to address potential water hammer effects since the issue was initially identified in June 2007 and documented as a NCV in February 2009. The licensee entered this issue into the CAP as IR 1117296 and planned to accelerate the completion schedule for the analysis.

The finding was more than minor because it was associated with the design control attribute of the Barrier Integrity Cornerstone and affected the cornerstone objective of maintaining the radiological barrier function of the containment. The finding was of very low safety significance because it did not represent an actual open pathway from containment. This finding has a cross-cutting aspect in the area of Human Performance for Resources (H.2(a)) because the licensee failed to maintain long-term plant safety by completing the necessary piping load calculations in a timely manner. (Section 4OA2.1.b.3.b)

Licensee-Identified Violations

None.

REPORT DETAILS

4OA2 Problem Identification and Resolution

This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152. Documents reviewed are listed in the to this report.

.1 Assessment of Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the procedures and processes that described Exelons Corrective Action Program (CAP) at Braidwood Station to ensure, in part, that the station had an adequate program for meeting 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requirements. The inspectors observed and evaluated the effectiveness of CAP meetings such as Station Ownership Committee (SOC) and Management Review Committee (MRC) meetings. Selected licensee personnel were interviewed to determine their understanding and their involvement in the CAP.

The inspectors reviewed selected issue reports (IRs) across all seven cornerstones of safety to determine if problems were being properly identified and entered into the CAP.

A risk-informed sample of IRs, originated since the last NRC Biennial Problem Identification and Resolution (PI&R) inspection conducted in October of 2008, was reviewed by the inspectors. The inspectors also reviewed selected issues that were more than 5 years old.

The inspectors assessed the licensees characterization and evaluation of the issues and examined the assigned corrective actions. This review encompassed the full range of safety significances and evaluation classes such as root cause evaluations, apparent cause evaluations (ACEs), and workgroup evaluations. The inspectors assessed the scope and depth of the licensees evaluations. For significant conditions adverse to quality, the inspectors evaluated the licensees corrective actions to prevent recurrence and for lower safety significance issues, the inspectors reviewed the corrective actions to determine if they were implemented in a timely manner commensurate with their safety significances.

The inspectors reviewed the Technical Support Center (TSC) diesel generator in detail since the generator is nonsafety-related equipment that provides backup power to equipment for planned and emergency events. The inspectors also reviewed the maintenance issues associated with the Auxiliary Building ventilation fans as one of the exhaust fans was destroyed in a fire in early 2010 that resulted in a declaration of a Notice of Unusual Event. These reviews were performed to determine whether the licensee was properly monitoring and evaluating the performance of the system through effective implementation of station monitoring programs. The inspectors interviewed the system engineers of the applicable systems, reviewed numerous IRs, and reviewed evaluations. A 5-year review of the maintenance backlog was undertaken to assess the licensees efforts to address long-standing maintenance issues.

The inspectors reviewed the licensees CAP program and independently performed a 5-year review of the human performance trend to determine if issues were tracked to identify adverse trends or repetitive issues.

The inspectors examined the results of the two self-assessments of the CAP completed during the review period. The results of the self-assessments were compared to the self-revealed and NRC-identified findings. The inspectors also reviewed the corrective actions associated with previously identified NCVs and findings to determine whether the station properly evaluated and resolved those issues. The inspectors performed walkdowns to verify the resolution of the issues.

The inspectors also performed a review of the issues identified in the licensees corporate corrective action program to determine if issues were identified at the corporate level that could affect the Exelon sites, if those issues were prioritized and evaluated according to their safety significances and if corrective actions were assigned and carried out when appropriate.

b. Assessment

(1) Identification of Issues The inspectors concluded that, in general, the station continued to identify issues at a low threshold by entering them into the CAP. The inspectors determined that the station was appropriately screening issues from both NRC and industry operating experience (OE) at an appropriate level and entering them into the CAP when applicable to the station. The inspectors also noted that deficiencies were identified by external organizations (including the NRC) that had not been previously identified by licensee personnel. Issues were also identified at the corporate level at a low threshold and were entered into the CAP for actions.

The inspectors determined that the station was generally effective at trending low level issues to prevent larger issues from developing. The licensee also used the CAP to document instances where previous corrective actions were ineffective or were inappropriately closed.

Observations:

a. Human Performance Related Trend The inspectors reviewed the stations trend in human performance within the last 5 years. Overall, the inspectors did not identify any particular trend in Human Performance in any particular department or area, with the exception of the comprehensive improvements recognized in the NRCs conservative decision-making safety culture performance aspect documented in NRC Integrated Inspection Report 05000456/457/2010003. The inspectors determined, that in general, the programs that provided multiple barriers to potential human performance errors were adequate, if followed, and the stations CAP was generally good at identifying methods to enhance performance.

b. Procedural Compliance for the Condensate Polisher Spill Event On June 30, 2009, the Operations department was performing an evolution to rinse a Condensate Polisher (CP) demineralizer after a resin change. Once the rinse was initiated, the CP low conductivity sump level high annunciator alarmed. The operator verified the sump pump was running and the level in the sump was maintaining a steady level at approximately 3 feet below floor level. The operator discussed the condition with the field supervisor and left the area to perform other duties. About an hour later, the field supervisor went to the room to check on the evolution and discovered that the sump had overflowed and water was spilled outside to the ground. The field supervisor terminated the evolution and the sump level immediately began to drop.

Immediately actions were taken to contain the spread of water released offsite. The licensee later estimated that about 1000 to 3800 gallons of water were released to the storm sewer system. The tritium concentration of the water was sampled to be 270 picocurie per Liter (pCi/L), which was below the Environment Protection Agencys drinking water limit of 20000 pCi/L.

Although not required, the licensee notified members of the Illinois Emergency Management Agency, the Illinois Environment Protection Agency, several Will County Board members, and the Mayor of Braidwood and Godley as well as the NRC about the spill. The licensee performed a quick human performance investigation (QHPI) and ACE and identified several procedural and human performance issues including not requiring continuous monitoring of the evolution when an alarm condition existed. Corrective actions were taken to correct these issues.

The inspectors reviewed the corrective action documents and the annunciator response procedure in effect at the time and determined that the licensee did not perform all the required actions prescribed in the annunciator response procedure. Specifically, after the low conductivity sump high level alarm was actuated, the operator, per procedure, was supposed to stop the evolution if the sump level did not decrease. Based on the QHPI and the ACE, the operator only verified that the level was maintaining steady before attending other duties. Since the level was not decreasing, the evolution should have been stopped, which could have prevented the spill from occurring. This procedure violation was not identified in the licensees investigations. Because a regulatory limit was not exceeded for offsite release, this failure to comply with procedures constitutes a violation of minor significance that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

(2) Prioritization and Evaluation of Issues The inspectors concluded that the station was generally effective at prioritizing and evaluating issues commensurate with the safety significance of the identified problem.

The inspectors determined that the SOC and MRC CAP review meetings were generally thorough and maintained a high standard for approving action.

The inspectors determined that issues were tracked to identify adverse trends and actions assigned to correct repetitive issues when applicable. The inspectors reviewed selected issues in the maintenance backlog and the CAP. The inspectors determined that the licensee was generally effective at evaluating equipment functionality requirements after a degraded or non-conforming issue was identified and prioritized the corrective action commensurate with its safety significance. The inspectors also determined that issues in the corporate CAP were prioritized and evaluated per the established CAP process.

The inspectors noted that several issues related to the sequential unit reactor trip in August 2010 had problem identification and resolution implications. However, the inspectors did not review those issues because the licensee had not completed the evaluations and a NRC special inspection was ongoing at the time of this inspection.

Based on the samples selected for this inspection, the inspectors identified several issues that could be evaluated in a more timely manner.

Observation:

a. Technical Support Center Diesel Generator In April of 2010, Nuclear Oversight (NOS) identified that no evaluation was completed when the Technical Support Center (TSC) diesel generator failed its loaded run surveillance test (0BwOS-IS-Q1) in January 2010. Specifically, the diesel generator did not meet its acceptance criterion for the motor starting battery minimum voltage. An engineering evaluation was performed to investigate the origin of the minimum voltage acceptance criterion and evaluate if failing to meet the criterion would actually cause the diesel generator not to start when required. The licensee concluded that the criterion in the procedure was enveloped by industry and vendor standards, and as such, could be left as-is. However, the specific bases of the acceptance criterion were not known.

Since failing to meet the battery acceptance criterion would indicate potential degradation, a step was added to the procedure for an IR to be initiated if the voltage was too low so that engineering could evaluate the functional level of the diesel generator.

The inspectors performed an historical search into this issue and found that the diesel generator had failed its surveillance multiple times in the past 7 years for not meeting the minimum battery voltage acceptance criterion. The inspectors determined that the identification of these surveillance failures was not promptly entered into the CAP. Also, the evaluation of this issue identified by NOS did not contain the appropriate technical rigor of a typical engineering evaluation in that it did not thoroughly probe into the engineering design bases of the battery and did not illustrate an understanding of why the acceptance criterion was the value that was being used in the surveillance procedure. Since the TSC diesel generator was able to start and load onto the bus when it failed the surveillance, the diesel generator was considered functional.

The inspectors also discovered that there were no supporting design basis documents for the TSC diesel generator itself. The function of the diesel was to provide an uninterrupted back-up power supply for the 033W3 bus, which supplied the TSC and other nonsafety-related but regulatory required loads, under loss of normal power conditions. For example, the surveillance procedure provided a run-time criterion of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for the diesel generator. However, there was no supporting documentation that provided the basis for a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> run-time in a loss of power scenario. The inadequate documentation of the basis for the acceptance criterion and the design of the diesel generators called into question the long-term reliability of the diesel generator to perform its intended function. After NRC questions from this inspection, IR 1112604 was written to have engineering review the classification and design documentation for the TSC diesel generator. This issue was not a performance deficiency because there were no requirements to document the bases for the TSC diesel generator and the diesel generator was capable to start and provide power to the 033W3 bus.

b. Emergency Diesel Generator Temperature Switches Since January of 2009, there were multiple IRs written by engineering for the Emergency Diesel Generator Lube Oil Heater and Jacket Water Heater temperature switches not maintaining the desired temperature bands or functioning as intended. The purpose of these temperature switches was to maintain a temperature band of 120 to 130 degrees Fahrenheit for the oil in the lube oil system and water in the jacket water system of the emergency diesel generators. This maintained the emergency diesel generators in a condition that allows them to start within the Technical Specification (TS) required time and perform their intended safety function of providing power in case of an emergency.

These switches normally operated in automatic and are not needed when the diesel generator is running.

All these issues occurred after seven of the eight switches were replaced by a new model switch due to the old model becoming obsolete. While the issues were promptly identified, the CAP process of evaluating the issue and implementing effective corrective actions was not completed in a timely manner. Even though the issues were first identified in early 2009, Engineering was still evaluating the cause of the issues. In the meantime, the switches were being operated in manual mode, and controlled by operators in the field when they were completing their daily rounds. The licensee started these manual compensatory actions in September of 2009. An IR was written in June of 2010 to evaluate these manual compensatory actions as operator burdens.

The inspectors determined that the evaluations and corrective actions for these conditions adverse to quality were untimely and the licensee was not appropriately addressing the significance of these problems. The inspectors determined that the diesel generators could still perform their intended functions since the temperatures of the lube oil and jacket water were being maintained within the Updated Final Safety Analysis Report (UFSAR) limits. Therefore this issue constituted a minor violation of NRC requirements that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. The licensee acknowledged that the evaluation and corrective actions should have been completed in a more timely manner for this risk-significant system.

c. Failure to Follow the Operability Determination Process

Introduction:

The inspectors identified a Green finding and an associated Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, when licensee personnel failed to follow the stations Operability Determination procedure after identifying a potential Auxiliary Feedwarter (AFW) system design vulnerability. Specifically, since May 15, 2007, the licensee had questioned the motor-driven AFW pumps capability to effectively swap its water source from the condensate storage tank (CST) to the essential service water system during a hypothetical catastrophic failure of the non-seismic CST. The lack of involvement in bringing this issue to the attention of the operating crew, lack of quality in evaluating the issue, and length of time the questions had been unanswered were not consistent with the standards imposed in the stations Operability Determination process. The licensee entered this issue into their corrective action program (IR 1114604).

Description:

On May 15, 2007, the licensee identified and documented a concern regarding the Unit 1 and Unit 2 AFW system response time during a design basis loss of offsite power coupled with a hypothetical loss of the CST supply (IR 629903). During this scenario, the Unit 1 and Unit 2 motor-driven AFW pumps received an auto start signal but tripped within 2.5 seconds on low suction pressure provided the CST had failed. The pumps would start again after their breakers reset and supply water to their respective steam generators. The IR appropriately questioned if this delay in AFW response was accounted for in the licensing basis. Assignment #2 from this IR evaluated the issue and concluded that there was no deficient condition and the AFW pumps would deliver water to the steam generators within the period required by the analysis.

Assignment #3, from IR 629903, was initiated to evaluate the need to revise the AFW system description in Section 10.4.9 of the UFSAR to address the start of the AFW pump with the CST unavailable and to initiate additional actions if needed. The inspectors determined that this assignment was delayed multiple times from the original due date of August 30, 2007, until the final completion date of July 23, 2010. During this time, an additional concern was identified by the Exelon staff. The new concern was that the AFW motor might cycle on and off as many as four times based on the breakers 3-second closing spring recharge time. Although the inspectors could not determine the precise date that the new concern was identified, after reviewing the IRs in progress notes and talking with the licensee staff and managers, it was clear that this concern was recognized and discussed prior to April 6, 2010. This conclusion was based on an April 6, 2010, vendor response letter provided to Exelon extending an offer to study the effects of four successive starts of the AFW motor based on the recognized possibility that the motor would either trip on over current during one of the successive starts or could overheat due to starting four times in succession. This information was not provided to Operations management.

On July 7, 2010, the licensee initiated IR 1088364 that documented the concern for four successive trips of the motor-driven AFW pump during presumed CST failure due to a tornado generated missile. The IR stated that the repeated starts and trips were discussed with a corporate rotating equipment specialist who believed that the four starts could damage the motor windings through overheating. This individual also noted that he could not predict with certainty how the motor or breaker would respond and that vendor support would be needed for an analysis. Furthermore, the individual noted that the short time between trip and restart could result on excessive inrush currents that could cause a trip on overload. This IR documented the actions that the licensee had undertaken prior to the April 6, 2010, vendor response letter.

Exelon Procedure OP-AA-108-115, Operability Determinations (CM-1), Revision 9, was a 10 CFR 50, Appendix B, quality procedure. Per that procedure, operability should be determined immediately upon discovery that a structure, system, or component (SSC), subject to TS, was in a degraded or nonconforming condition. This procedure also stated that a prompt determination of SSC operability as a follow up to the immediate determination of SSC operability made by Operations management was warranted when additional information, such as a supporting analysis, was needed to confirm the immediate operability determination.

The IR 1088364 provided an immediate operability assessment for the AFW pump motor based on the vendors engineering judgment. However, it did not provide an immediate operability assessment for the motor-driven AFW pump breaker. For the motor, the IR stated that continued operability was supported based on the vendors preliminary evaluation that the motor would continue to operate and that any motor degradation would result in minor shortened motor life, but not an immediate failure.

The inspectors reviewed the history of the issue and discussed the issue with both Braidwood management and the engineering staff and identified an inadequate and untimely evaluation. Specifically, the evaluation was untimely from the perspective that from when the original issue was identified to the time provided to obtain a detailed analysis was over 3 years. The evaluation was also inadequate from the perspective that the operability evaluation for the motor was based on a vendors opinion and not documented engineering judgment that could be reviewed by the inspectors or that was understood by interviewed Braidwood staff. With respect to the breaker, the licensee simply had not assessed and documented its operability.

The inspectors identified that the licensee had not considered other credible scenarios in which offsite power would not be available and a CST failure could occur (i.e. a design basis earthquake), did not provide an explanation for why the motor-driven AFW pump versus the diesel-driven AFW pump was considered the credible single failure, and did not evaluate the potential risk to the plant in the case that the equipment was discovered to be inoperable.

Analysis:

The inspectors concluded that the licensees failure to adequate implement their operability determination process was a performance deficiency. The inspectors determined that this issue was more than minor in accordance with IMC 0612, Appendix B, Issue Screening, because, the issue was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the AFW pump operability was not fully evaluated by the licensee. The issue was determined to be Green because the issue was not a confirmed loss of operability and did not represent a risk-significant issue based on the plants design backup capability to remove decay heat via the primary feed and bleed method.

This finding has a cross-cutting aspect in the area of Human Performance for Decision-Making. Specifically, the licensee did not make a safety-significant or risk-significant decision using the Operability Evaluation systematic process, especially when faced with uncertain or unexpected plant conditions involving a potential design vulnerability to the plant to ensure safety was maintained (H.1(a)).

Enforcement:

10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to this, the inspectors identified three examples of a violation of this requirement for the licensees failure to follow Procedure OP-AA-108-115, Operability Determinations (CM-1), Revision 9:

• Step 4.1.2 requires that if the originator or supervisor identified any potential operability or reportability issues, then the originator or supervisor shall personally contact Operations management of the affected facility/unit and discuss the issue.

However, from April 6, 2010, (or prior) to July 7, 2010, Operations management was not notified of the issue while an engineering review was being conducted to evaluate system operability.

• Step 4.1.6 requires that operability be determined immediately from a detailed examination of the deficiency upon discovery that a SSC subject to TS is in a degraded or nonconforming condition. In most cases the decision can be made immediately and appropriately documented on the IR. In other cases, the decision shall be made within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> even though complete information may not may available. However, IR 1088364 did not provide an immediate operability determination with the documented concern for how the breaker would respond, as specified by Step 4.1.6. Specifically, the IR documented that a corporate rotating equipment specialist could not predict with certainty how the motor or breaker would respond to the hypothetical four successive starts. The IR further documented that based on preliminary vendor judgment, that the motor would continue to operate and that any motor degradation would result in minor shortened motor lift.

• Step 4.1.9 states that a prompt determination of SSC operability is a follow up to the immediate determination of SSC operability made by Operations management. The prompt determination is warranted when additional information, such as a supporting analysis, is needed to confirm the immediate determination. If there is a reasonable expectation that the SSC is operable, but a more rigorous evaluation is deemed warranted, then request the appropriate work group to initiate an action tracking item (IR action) to prepare an operability evaluation using the guidance provided in this procedure. From May 15, 2007, to September 24, 2010, the licensee recognized that an additional, supplemental analysis was needed to confirm operability; however, the licensee did not perform an Operability Evaluation using the guidance provided in this procedure when faced with a question that could affect the motor-driven AFW pumps licensed based function during a hypothetical CST failure.

The licensee entered this issue into their CAP as IR 1114604. Corrective actions included an assignment to perform an Operability Evaluation on both the AFW pump and breaker, and an assignment to ensure a detailed analysis was performed on the breaker, as was the case for the AFW motor.

Because this violation was of very low safety significance, was not repetitive or willful, and it was entered into the licensees corrective action program, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy.

(NCV 05000456/2010006-01; 05000457/2010006-01: Failure to Follow the Operability Determination Procedure)

(3) Effectiveness of Corrective Actions The inspectors concluded that corrective actions for identified deficiencies were generally timely and adequately implemented, commensurate with their safety significances. Problems identified using root or apparent cause methodologies were resolved in accordance with program and NRC requirements. The inspectors determined that the corporate CAP was generally effective in driving corrective actions to completion. When appropriate, corrective actions were assigned to the site for implementation.

The inspectors also determined that the stations corrective actions designed to prevent recurrence (CAPRs) were generally comprehensive, thorough, and timely. Although some of the CAPRs were over 500 days old, the inspectors determined that the corrective actions were considered timely as they required an outage for the implementation.

The inspectors also concluded that sampled corrective action assignments for selected NRC documented violations were generally effective and timely. However, the inspectors identified a number of untimely corrective actions as described below.

Observations:

a. Untimely Corrective Actions for Auxiliary Building Ventilation Exhaust Fan Failure On May 10, 2007, an IR was written because the Auxiliary Building Ventilation A Exhaust Fan (0VA02CA) had elevated vibration indicating degraded bearings. The fan was classified as a non-preferred machine and a work order was created to repair the fan. On July 3, 2008, before the fan could be repaired, it was run to failure and quarantined. The failure was considered by the licensee to be a Maintenance Rule Functional Failure and an Equipment ACE was generated. The licensee made the decision to investigate, disassemble, send out for repair, and reassemble the fan in the same work order with an initial due date of August 4, 2008. The work order due date was later moved to December 1, 2008 because the original due date was close to an outage and there were resource issues. The date was moved a total of six more times because of resource issues and had a due date of November 29, 2010, at the end of this inspection, which was 29 months after the failure.

Since the work order had not been completed, the licensee was in a situation where one of the safety-related exhaust fans had been inoperable for over 2 years and the mode of failure still had not been determined. Since the mode of failure had not been determined, the licensee could not complete the Equipment ACE, the extent of condition, or implement corrective actions.

On January 9, 2010, approximately 19 months after the A Exhaust Fan failed, the C Supply Fan also failed. The failure also caused the station to declare a Notice of Unusual Event for a small fire from the inboard bearing of the C Supply Fan. The licensee was required to have two of four trains available to complete TS surveillances.

At the end of this inspection, the licensee had two trains available. However, the B Exhaust Fan was degraded because of high vibrations.

The untimely repair of the safety-related Auxiliary Building A Exhaust Fan was considered to be a performance deficiency. Although these fans were required to complete TS surveillances, they were not required for train operability. Since the licensee met the TS requirements, this performance deficiency was considered minor.

b. Untimely Corrective Action for Lack of Water Hammer Analysis on the Recycle Holdup Tank

Introduction:

The inspections identified a Green finding and associated NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, when the licensee failed to promptly correct a previously identified NCV regarding the lack of analysis for water hammer loads on the Recycle Holdup Tank (RHUT) inlet piping induced by Residual Heat Removal (RHR) system relief valve discharges.

Description:

In February 2009, NCV 05000456/457/2008005-05 was issued when the licensee failed to evaluate and maintain the required water volume necessary to quench the RHR system relief valve discharges into the RHUT and incorporate appropriate minimum RHUT level requirements into the RHUT level control procedure and to evaluate the effect of dynamic water hammer loads on inlet piping from relief valve discharges to the RHUT. This issue was initially identified by the NRC in June 2007 (See NRC Integrated Inspection Report 05000456/457/2008005). The licensee entered this issue into their CAP as IRs 649581 and 677075. As part of the corrective actions, the licensee instituted administrative controls to provide an adequate quench volume for the RHUT and initiated an action to perform an analysis to investigate the magnitude of the potential water hammer loads on the inlet piping.

The action to obtain a proposal to perform the piping analysis was originally assigned a due date of July 31, 2008. The proposal was obtained and the action was closed. The actual piping analysis and a detailed evaluation for over-pressurization of the RHUT were tracked under another IR Assignment, IR 677075-09, to revise the accident analysis in the UFSAR for a ruptured RHUT with an initial due date of July 31, 2009.

This assignment was documented as a corrective action for a condition adverse to quality.

On February 9, 2009, the NRC issued an NCV related to this issue and the licensee wrote IR 883985 to track the actions to correct the NRC identified violation. The action was subsequently closed to IR 677075-09.

On July 30, 2009, the licensee extended the due date for this corrective action item to December 2009 due to coordination required from Byron Station and vendor support. In December 2009, the action was further extended to June 2010 and was downgraded from a corrective action to an action tracking item, which tracked minor problems that did not represent conditions adverse to quality. The reasons for the delay, as documented in the CAP, were emergent engineering priorities and corporate engineering staff re-organization.

In June 2010, the due date was again extended to September 2010 to perform a more detailed analysis due to a possible need for a system modification. At the end of this inspection, the action was scheduled to be completed in June of 2011. The licensee planned to accelerate the completion schedule of the analysis.

Analysis:

The inspectors determined that the licensees failure to timely perform the necessary piping analysis to investigate the magnitude of the potential water hammer loads on the inlet piping was a performance deficiency that warranted a significance determination. The inspectors determined the finding was more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, because the finding affected the Barrier Integrity Cornerstone objective for maintaining the Radiological Barrier Function of the Containment. The finding was also associated with the design control attribute of the Barrier Integrity Cornerstone.

Specifically, the licensee's existing design and piping configuration did not address water hammer effects when the RHR relief valves were lined up to discharge to the RHUT that could rupture the piping and potentially affect the offsite dose consequences.

The inspectors evaluated the finding using IMC 0609, Attachment 0609.04, Phase 1 Initial Screening and Characterizations of Findings. The inspectors determined in Tables 2 and 4a of the Attachment that the failure to analyze the RHUT inlet piping loads degraded the Radiological Barrier Function of the containment, but did not represent an actual open pathway from containment. Therefore, the finding was screened as having very low safety significance (Green).

This finding has a cross-cutting aspect in the area of Human Performance for Resources (H.2(a)) because the licensee failed to maintain long-term plant safety by completing the necessary piping load calculations in a timely manner.

Enforcement:

10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires in part that measures shall be established to ensure that conditions adverse to quality are promptly identified and corrected. Contrary to the above, as of September 17, 2010, the licensee failed to promptly correct a condition adverse to quality identified in February 2009. Specifically, the licensee failed to complete the piping analysis to address potential water hammer effects when the RHR relief valves were lined up to discharge to the RHUT. Because this violation was of very low safety significance and because it was entered into the licensees CAP as IR 1117296, this violation is being treated as a NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000456/2010006-02; 05000457/2010006-02: Untimely Corrective Action for Lack of Water Hammer Analysis on the Recycle Holdup Tank)

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed the licensees implementation of the facilitys OE program.

Specifically, the inspectors reviewed implementing OE program procedures and completed evaluations of OE issues and events. The inspectors also attended CAP meetings to observe the use of OE information. The inspectors review was to determine whether the licensee was effectively integrating OE experience into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, whether the licensees program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of OE experience, were effective and timely implemented.

b. Assessment The inspectors concluded that the station appropriately considered industry and NRC OE information for applicability, and used the information for corrective and preventative actions to identify and prevent similar issues. The inspectors assessed that OE was appropriately applied and lessons learned were communicated and incorporated into plant operations. In particular, OE information was discussed during Plan of the Day meetings and also incorporated into the work management process as part of the pre-job briefs. The inspectors also observed that Exelon fleet internal OE and industry OE were discussed by licensee staff to support review activities and CAP investigations.

Findings No findings of significance were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed selected focused area self-assessments, check-in self-assessments, root cause effectiveness reviews, and NOS audits. The inspectors evaluated whether these audits and self-assessments were being effectively managed, were adequately covering the subject areas, and were properly capturing identified issues in the CAP. In addition, the inspectors also interviewed licensee personnel regarding the implementation of the audit and self-assessment programs.

b. Assessment The inspectors concluded that self-assessments and audits were typically accurate, thorough, and effective at identifying issues and enhancement opportunities at an appropriate threshold level. The inspectors concluded that these audits and self-assessments were completed by personnel knowledgeable in the subject area. In many cases, these self-assessments and audits had identified numerous issues that were not previously recognized by the station. For example, NOS has identified that Operations had missed the TS Limiting Condition for Operation (LCO) entry for containment isolation valve 1SI8835 and 1SI8809A from a loss of power. Although power was restored before the LCO time ran out, Operations did not recognize the missed entry until the NOS review.

Findings No findings of significance were identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

The inspectors interviewed selected members of the Braidwood Station personnel to determine if there were any impediments to a Safety Conscious Work Environment (SCWE). In addition, the inspectors discussed the implementation of the Employee Concerns Program (ECP) with the ECP coordinators, and reviewed 2008 - 2010 ECP activities to identify any emergent issues or potential trends. In addition, the inspectors assessed the licensees SCWE through the reviews of the facilitys ECP implementing procedures, discussions with coordinators of the ECP, interviews with personnel from various departments, and reviews of IRs. The licensees programs to publicize the CAP and ECP programs were also reviewed.

b. Assessment The inspectors determined that the conditions at the Braidwood Station were conducive to identifying issues. Licensee staff was aware of and generally familiar with the CAP and other station processes, including the ECP, through which concerns could be raised.

A number of craft personnel indicated that they did not personally enter issues into the CAP. Instead, their preferred method was to notify supervisors of the issues and had the supervisors enter the issues into the CAP. The inspectors determined that this observation was not a significant concern since the personnel interviewed stated that they were willing to voice issues to their management and/or ask another employee to write the IR for them. Note that this issue had been identified in previous PI&R inspections and the licensee had not made significant progress in this area.

All employees interviewed noted that any safety issue could be freely communicated to supervision and that safety significance issues were being corrected. However, some employees interviewed stated that minor issues were not being addressed as many of those issues were closed to trending or closed to work orders that were not scheduled to be completed for extended periods. Several employees mentioned that they would like better feedback after writing IRs so they could understand the reasons for those delays.

The inspectors determined that although no related regulatory requirements exist, the station could strengthen this area of the CAP by ensuring all station personnel have an adequate working knowledge of entering issues into the CAP and receive feedback for issues raised.

In addition, a review of the types of issues in the ECP indicated that site personnel were appropriately using the CAP and ECP to identify issues and the issues in the ECP were being addressed accordingly.

Findings No findings of significance were identified.

4OA6 Management Meetings

Exit Meeting Summary

On September 17, 2010, the inspectors presented the inspection results to Mr. L. Coyle, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

L. Coyle, Plant Manager

M. Marchionda-Palmer, Operations Director

M. Smith, Engineering Director

R. Gaston, Regulatory Assurance Manager

P. Boyle, Maintenance Director

P. Daly, Radiation Protection Manager

B. Schipiour, Work Management Director

R. Radanovich, Nuclear Oversight

T. Schuster, Chemistry Manager

E. Johnston, Site Correction Action Program Manager

NRC

E. Duncan, Branch Chief

LIST OF ITEMS

Opened

05000456/2010006-01 NCV Failure to Follow the Operability Determination

05000457/2010006-01 Procedure

05000456/2010006-02 NCV Untimely Corrective Action for Lack of Water Hammer

05000457/2010006-02 Analysis on the Recycle Holdup Tank

Closed

05000456/2010006-01 NCV Failure to Follow the Operability Determination

05000457/2010006-01 Procedure

05000456/2010006-02 NCV Untimely Corrective Action for Lack of Water Hammer

05000457/2010006-02 Analysis on the Recycle Holdup Tank Attachment