ML20011F313
| ML20011F313 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 02/27/1990 |
| From: | Sands S Office of Nuclear Reactor Regulation |
| To: | Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 9003050095 | |
| Download: ML20011F313 (6) | |
Text
i February 27, 1990-
.w S
BUTION
.t4EMORANDUM FOR: Edward G.' Greenman, Director Division of Reactor Projects gtalF e
Region 111 JZwolinski LLuther THRU:
John W. Craig, Director-SSands ProjectDirectorate111-2 da Division of Reactor Projects - 111 IV, V and Special Projects (BRAIDWOOD SALP 9)
'FROM:
Stephen P. Sands, Project Manager-Project Directorate 111-2 Division of Reactor Projects
.III L
IV. Y and Special Projects
SUBJECT:
NRR SALP IX INPUT FOR BRAIDWOOD STATION In response to the Region III memorandum dated January 23, 1990, I am enclosing NtR's input for the SALP IX report covering the period from-February 1, 1989 through January 31, 1990. Our assessment of specific functional areas, as documented in this enclosure, was conducted in accordance-with the latest revision of NRC Manual Chapter 0516, Additionally, per the.
Region's request, a list of_aill Technical Specification amendments issued during the SALP period is atteched.
If you have any questions or require further information, please contact me at 482-1396.
l Sincerely, Original signed by Stephen'P. Sands, Projects Manager Project Directorate III-2 l
Division of Reactor Projects - III,
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bam IV, V and Special Projects Office of Nuclear Reactor Regulation p $g
Enclosures:
As stated heo
- M8' cc: J.'Partlow
- 88
.J. Zwo11nski
- So G. Holahan
- nx
-J. Craig l88 J. Roe oc W. Shafer, RIII 0FFICAL RECORD COPY I
B.: Clayton, RIII Document Name:
BRAIDWOOD SALP 9 8e R. Lerch, RIII O
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February 27, 1990 MEMORANDUM FOR: Edward G. Greenman, Director Division of Reactor Projects Region III THRU:
John W. Craig, Director Project Directorate III-2 Division of Reactor Projects - III IV, Y and Special Projects-FROM:
Stephen P. Sands, Project Manager
[
Project Directorate III-2 j
Division of Reactor Projects - III IV, Y and Special Projects
SUBJECT:
NRR SALP IX INPUT FOR BRAIDWOOD STATION In response to the Region III memorandum dated January 23, 1990, I am
[
enclosing NRR's input for the SALP IX report covering the period from l
February 1., 1989 through January 31, 1990. Our assessment of specific
. functional areas, as documented in this enclosure, was conducted in accordance i
l.
with the latest revision of HRC Manual Chapter 0516. Additionally, per the Region's request, a list of all Technical Specification amendments issued during the SALP period is attached.
If you have any questions or require further information, please contact me at 482-1396.
Sincerely,
.2kau Stephe P. Sands, Projects Manager Project Directorate III-2
'g" Division of Reactor Projects - III, IV, V and Special Projects Office of Nuclear Reactor Regulation
Enclosures:
As' stated t.c:
J. Partlow J. Zwolinski G. Holahan J. Craig J. Roe W. Shafer, RIII B. Clayton, RIII R. Lerch, RIII
t i
OFFICE OF NUCLEAR REACTOR REGULATION INPUT FOR THE SAlp 1X REPORT COMMONWEALTH EDISON COMPANY BRAIDWOOD NUCLEAR POWER STATION, UNITS 1 AND 2 l'
OPERATIONS j
L in this assessment period, NRR staff was present during several tours and inspections.
It was noted that station housekeeping was considered to be very good. Most station areas appeared to be well maintained in terms of clean 11-ness and general appearance. Control room activities were performed in a very professional manner with particular attention to control and order. All of the operators appearec ettentive and knowledgeable. This was especially noted during the refueling outage for Unit 1.
ENGINEERING /TECHNJ,CALSUPPORT From September 25 - September 28,1909, NPR(theprojectManagerandTechnical l=
Reviewer) conducted an inspection of Generic Letter (R) 88-17 modifications and proposed Techni:a1 Specification (T/S) changes relcted to the Ewrgeitey s
l Cere Coo 11op System (ECCS) Venting. 1hc review for the ECCS Venting T/S change was adequate *<y documented and denionstrated sound technical raticnale. The modi-fications for thc Generic Letter 8847 were in the procen of being installed.
The work being accomplished denoastrated a clear understanding of the technical issues. While it was undec!ced at the time of the inspection if Tygon Tubing I.
was to be used as a method of reactor vessel level indication, it was noted that' the system presently in place was inadequate and needed several modifi-cations to bring the system up to par.
It still remains unknown whether or not the licensee intends to use this system.
OnDecember2,1989,anAugmentedInspectionTeam(AIT)wasformedatBraidwood to investigate a rapid loss of reactor coolant from a stuck-open RHR relief valve. During this 3-4 day period, the station's technical staff exhibited a higk:!egree of professionalism and knowledgeability. The system engineers, which the staff interfaced with, were very familiar with the systems involved, the status of the respective systems and all aspects of the system design features.
SAFETY ASSESSMENT /00ALITY VER1FICAT10N A.
Assurance of Quality, including Management Involvement and Control Commonwealth Edison Company did not exhibit good performance in planning some of their high priority licensing actions.
Specifically, the Spent Fuel Pool i-Expansion was submitted on January 3,1989, with a requested date of March 15, 1989 to support the installation schedule. This practice will invariably cause an unnecessary and unreasonable expedited response by the NRC staff.
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2 Corporate management was generally involved in the licensing process. This was especially evident for some of the more sensitive or complicated issues.
However, management oversight seemed to be lacking in the case of the DC crosstic issue.
In this particular case, Ceco appeared to be more concerned with the semantics and the wording in the Technical Specifications, rather than the actual safety concern expressed by the staff in crosstying the DC busses for greater than the time allowed in the Technical Specifications which is 7 days.
In the area of safety corporate managenent was almost always involved and provideddirectandeffectiveleadership. On balance, the quality of the engineering evaluations and technical content of material submitted by Commonwealth Edison was adequate.
However, there were some submittals in which the quality from a licensing perspective and an administrative viewpoint was less than acceptable.
For example, in the Technical Specification amendment request for the use of continuous pressure testing of the containment airlock doors, che of the bases for the request was improvement of ALARA performance.
Hocever, no su pporting documer,tation er exposure history was provided to subttentiate tie dose rate estimates given in the submittol. Another example of poor qcelity, where the same approach of ALARA considerations was used as a bases in the proposed wendment recuett was the submittal to modify the surveil'ancerequirementsforventingcfECCSpiping. The initial submittal cortained no iaforration en exposure rates. The staff reauested actval c>posuve data for the areas of concerr. in order to substantiate the AI. ARA reductions propoted by the licensee in the submittal, iho additional information the staff rtceived., to supplement the amendment request, wat a page showing a range of estimated exposures at vericus levels and the estiriated exposure in average man-rem / year and did not address the staff's request.
On balance, the quality of the submittals was adequate, however, in some cases it was not apparent that any type of self assessment process was utilized by management in order to assure consistent quality.
B. Approach to the Resolution of Technical Issues from a Safety Standpoint Commonwealth Edison Company and its contractors demonstrated a clear understanding of the complex technical and safety issues associated with many of the licensing and regulatory requirements on a fairly consistent basis. The technical approach used was usually solid and exhibited sufficient conservatism from a safety perspective. However, in a limited number of submittals, the l
technical content was not comprehensive or thorough enough to support NRC staff evaluations without additional information requests and/or supplements to the initial submittal. A case in point is the amendment request to permit the use of VANTAGE 5 fuel. The NRC staff had to request that supplemental information be provided to address the licensee's finding of "No Significant Hazards" in their review. The licensee's resolution of NRC staff concerns that emerged from the technical evaluations were usually prompt. Most reviews were accomplished fairly well and demonstrated more than adequate technical capability which was in keeping with the implied safety significance.
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C.
Responsiveness to NRC Initiatives Commonwealth Edison responses to Generic Letters, Bulletins, and Information Notices were almost always on time and generally complete. However, on some responses, the turnaround was somewhat slow (e.g., B 88-04,10CFR50.61)andin the case of GL B3e28, the response contained insufficient information for staff review.
In contrast, Commonwealth Edison has not only demonstrated responsive-l ness, but cooperation and initiative with respect to resolving certain other safety and licensing issues of similar or greater complexity and importance (UFSAR, TM1 Action items, USIs, etc.).
One area that has always remained consistently high has been the communication channels between the NRC and Commonwealth Edison. The channels are always open between the staff and the licensing and station personnel. A proactive environment has always been maintained with respect to conference calls and meetings which provided an integral tool for discussing administrative and technical issues.
P D.
F.nforcement History Not reviewed / applicable E.
Staffing The staffing at the station in support of licensing and engineering has remaineo high. The technical and engineering support at the station continues to be of high quality with consistent control of almost all safety und technical itsues.
i The level of experience and quality in the licensing administration and corporate management continues to remain high. These areas continue to exhibit direction and efficacy over the many complex and varied licensing / technical issues.
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L.isted*below are all license amendments issued for Braidwood Nuclear Power
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Station Units 1 and 2, for the current SALP (IX) assessment period (2/1/89 -
l 1-31-90.
AMENDMENT NO.
DESCRIPTION DATE 14 Extend surveillance testing for Diesel 2-28-89 Generators to 38 mos, from 31 mos.
15 Fxy Limits 3-28-89 16 Organization Charts 4-24-89 17 Tables 3.3-1 & 4.3-1, Reactor Trip System 5-22-89 Automatic - shunt trip coil attachments 18 Cycle-specific limits of reload fuel 6-5-89 enrichnent 19 T/S 5.3.2 - use of Hafnium, or silver-7 17-89 indium-cadmium, as absorber material in rod control cluster assemblies.
20 Spent Fuel Pool Ainendment 7-20-89 l
21 Containment floor drain & reactor cavity 7-25-89 menitoring system 22 T/7 Figare 3.2 Narmeliz?d heat f*icx 10-4-89 tot channel frctor t
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