ML20135B501
| ML20135B501 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 02/18/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20135B470 | List: |
| References | |
| 50-456-96-21, 50-457-96-21, NUDOCS 9703030073 | |
| Download: ML20135B501 (23) | |
See also: IR 05000456/1996021
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U.S. NUCLEAR REGULATORY COMMISSION
REGION lli
Docket Nos: 50-456, 50-457
Report No: 50-456/96021;50-457/96021
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Licensee: Commonwealth Edison (Comed)
Facility: Braidwood Nuclear Plant, Units 1 and 2
Location: RR #1, Box 84
Braceville, IL 60407
Dates: November 30,1996 - January 10,1997
Inspectors: C. Phillips, Senior Resident inspector
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J. Adams, Resident inspector
D. Rich, Resident inspector
T. Esper, Illinois Department of Nuclear Safety
Approved by: R. D. Lanksbury, Chief
Reactor Projects Branch 3 l
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9703030073 970218
l PDR ADOCK 05000456
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EXECUTIVE SUMMARY
Braidwood Nuclear Plant, Units 1 & 2
NRC Inspection Report 50-456/96021; 50-457NG021
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This inspection included aspects of licensee operations, maintenance,
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engineering, and plant support. The report covers a 6-week period of resident inspection;
in addition, it includes the results of an announced inspection by a regional radiation
specialist.
Operations 1
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Inspectors observed operators add lubricating oil to the 28 diesel generator. The 1
operators were not aware that a procedure existed for adding oil to the diesel I
generators. The inspectors determined that the operators did not follow procedure
BwOP DG-5 and BwAP 100-20. This an example of a Violation of Technical
Specification (TS) 6.8.1.a. (Section 04.1).
Maintenance -
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Inspectors observed the replacement of high efficiency particulate filters in the C
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train of the auxiliary building ventilation inaccessible plenum. The inspectors
observed that no quality assuranco tag was attached to the replacement filter as
required by BwWP 800-6. This is an example of a Violation of TS 6.8.1.a.
(Section M1.1).
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Inspectors observed that while the conduct of the 2B RHR pump surveillance was
performed in a competent and well controlled manner that the licensee failed to
ensure that a required change to the surveillance procedure was made prior to use.
This is an example of a Violation of TS 6.8.1.a. (Section M3.1).
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Inspectors observed maintenance on the 1C heater drain pump. The work package
war, not present at the work site. The inspectors also observed that the foreman
could not explain the purpose of procedural steps. The inspectors determined that
maintenance personnel did not follow procedure BwAP 1600-1. This is an example
of a Violation of TS 6.8.1.a. (Section M4.1).
Inspectors reviewed a licensee finding that spent fuel assemblies were
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mispositioned in the fuel pool. The inspectors determined that the fue handlers did
not follow procedure BwFP FH-4 which required the triple verification of fuel moves.
This is an example of a Violation of TS 6.8.1.a. (Section M4.2).
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The inspectors identified that several carts were secured to safety-related
equipment in violation of BwAP 100-10 and, in one case, licensee personnel failed
to take corrective action after the problem was identified by the inspectors. These
represent an example of a Violation of TS 6.8.1.a for failure to follow procedures
and a violation of 10 CFR Part 50, Appendix B, Criterion XVI, for failure to take
corrective actions. (Section M4.3)
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The inspectors were notified of a leak on the 1 A essential service water backwash
line. The inspectors determined that the licensee was not in compliance with the
American Society of Mechanical Engineers (ASME) code in that a through wall flaw - '
had been identified and the component had not been removed from service nor had
any corrective action been taken. The inspectors concluded that the failure to
comply with the ASME Code,Section XI, was a violation of 10 CFR 50.55a(g)(4).
(Section E1.1)
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Plant Support
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The inspectors observed a posted radiation hot spot in the Unit 1 moderating heat
exchanger room outside of a posted radiation area. The inspectors determined that
the licensee had not complied with BwRP 5010-1. This is an example of a Violation
of TS 6.8.1.a. (Section R4.2)
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The inspectors observed security guards failing to follow plant procedure BwRP
5822-8 regarding conducting a whole body frisk when exiting the auxiliary building.
This is an example of a Violation of TS 6.8.1.a. (Section R4.3)
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Report Details
Summrv of Plant Status
Unit 1 entered the period out of service for a mid cycle Steam Generator tube inspection
' outage. The unit was removed from service on October 11,1996, and the scheduled
outage duration was initially planned for 29 days. Upon inspection of the Steam
Generators, the outage duration was changed to 50 days due to required repairs for all four
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Steam Generators. As a result of the Steam Generat6Ftube inspections, all four Steam
Generators were classified as Category C-3 per plant Technical Specification (TS)
4.4.5.2.e. Tube plugging and sleeving was required for the Steam Generators due to
defective tube indications. Unit 1 was returned to service on December 3,1996, and has l
operated at or near 100% full power since Dsdember 11,1996. !
Unit 2 entered the period at or near 100% full power and operated routinely for the entire
period,
l. Operations
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01 Conduct'of Operations 1
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01.1 General Comments (71707)
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Using inspection Procedure 71707, the inspectors conducted frequent reviews of !
ongoing plan: operations. The inspectors observed the following plant evolutions: !
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changing a chemical volume control system filter;
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clearing out-of-service tags and return to service of the Unit 1 sealinjection
filter;
portions of auxiliary building and turbine building operator rounds;
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and the Unit 1 startup from a maintenance shutdown.
During these evaluations, the operators were observed to follow operating and
radiation protection procedures. The inspectors observed the pre-job briefings and
found them to be acceptable for the tasks performed. In general, the conduct of
operations was performed in a safe, well controlled manner.
04 Operator Knowledge and Performance
04.1 Operators Unaware of Procedure for Addina Lube Oil to Diesel Generators
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a. jn.spection Scope (71707)
On December 19,1996, the inspectors observed the addition of lubricating oil to
the 28 Diesel Generator crankcase. Following the oil addition, the inspectors
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discussed the evolution with system engineer, field supervisor, and shift engineer.
The inspectors reviewed BwOP DG-5, " Diesel Generator Oil Addition," Revision 5,
and BwAP 100-20, " Procedure Use and Adherence " Revision 5.
b. Observations and Findinas - -
On December 19,1996, the inspectors did not observe equipment operators using a
procedure during the addition of lubricating oil to the 2B Diesel Generator
crankcase. The equipment operators told the inspectors that there was no
procedure for oil addition to the diesel generators. The operators added 55 gallons
of Mobil Delvac 1340 oil to the 28 diesel generator to a final crankcase oil level of -
1/2 inch.
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The inspectors later identified, obtained, and reviewed a copy of BwOP DG-5,
" Diesel Generator Oil Addition." The inspectors performed a comparison of the
observed operator actions with the procedural steps of BwOP DG-5 and identified
one discrepancy between the as-left condition of the 2B Diesel Generator and
procedure BwOP DG-5. Step F.4.a states that oil chould be adu'ed to the blue line
(0 inch) on the crankcase level sightglass. As mentioned above the inspectors .
observed a post addition crankcase level of -1/2 inch. The inspectors verified the '
acceptable range for crankcase oil level and found it to be -1 inch to + 1 inch.
BwAP 100-20, steps D.8.d.1 and D.8.d.2 required the user to review the procedure
prior to performance and have a copy available at the location. The inspectors
verified that at the time of the oil addition there was not a copy of BwOP DG-5 in
the 2A diesel generator room.
The inspector contacted the shif t engineer and field supervisor to inform them that
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the equipment operators were not aware of the procedure for oil addition to the
diesel generators. The field supervisor indicated that he had taken the following
corrective actions: counseled the operators involved with the oil addition, reviewed
the equipment operators action, and provided a reminder to the other operators of
the procedure's existence.
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The inspectors concluded that the equipment operators were not aware that a
, procedure for the addition of lubricating oil to the diesel generators existed. In
being unaware of BwOP DG-5 existence, the equipment operators did not comply
with procedure BwAP 100-20, Revision 5, steps D.8.d.1 and D.8.d.2. These steps
require the user to review the procedure prior to performance and have a copy
available at the location.
The inspectors concluded that the proper type of oil was added and the operator's
actions in adding oil to the 2B Diesel Generator were consistent with the procedural
steps of BwOP DG-5 with one exception. Step F.4.a states that oil should be added
to the blue line (0 inch) on the crankcase level sightglass and the inspectors i
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observed a post-addition crankcase level of -1/2 inch. The conditions .1 this step
were not met.
TS 6.8.la requires that written procedures be established, implemented, and
maintained covering activities recommended in Regulatory Guide 1.33, Revision 2,
Appendix A. TS 6.8.1a applies to BwOP DG-5 and to BwA 100-20 and therefore,
the failure to follow BwOP DG-5 and BwAP 100-20 was an example of an inspector
identified violation of TS 6.8.1a. (50-456/457/96021-01a(DRP)).
08 Miscellaneous Operations issues
08.1 Review of June 1996 Institute of Nuclear Power Operations (INPO) Evaluation
The inspectors reviewed the evaluation report and determined that the results were
generally consistent with the results of similar evaluations conducted by the NRC. '
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11. Maintenance
M1 Conduct of Maintenance
M 1.1 Safetv-Related Ventilation Filter Replacement
a. Inspection Scope (62703)
On December 5, the inspectors observed the replacement of a part of the HEPA
filter in the "C" train of the auxiliary building vcatilation non-accessible plenum. The
replacement was performed by non-licensed operators. The inspectors listened to
the pre-job brief and interviewed the operators and the operations field supervisor.
The inspectors also reviewed Action Request 960081934; BwWP 800-6,
" Withdrawal, Marking and Return of Safety, ASME Code, and Regulatory Related
items," Revision 6; BwAP 1600-10, " Minor Maintenance Procedure " Revision 3;
and BwAP 1600-1, " Action / Work Request Processing Procedure," Revision 30E2.
b. Observations and Findinas
The non-licensed operators were told by the field supervisor during the prejoo brief
that the replacement filter could be found on the 451 foot level of the auxiliary
building. The inspectors noted that when the operators arrived, there was no red
quality assurance tag attached to the filter. The licensee used a red tag system to
identify and provide traceability for safety-related parts and components. BwWP
800-6, Step F.2.c, stated in part that when a red tag was issued with a safety-
related item the tag was to remain with the item until installation. The inspectors
verified with the field supervisor after the evolution that the filters were in fact a
safety-related part. The field supervisor later found the red tag associated with the
installed filters. The tag had been removed by store room personnel before buing
issued to the operators.
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The inspectors Nn followed the operators to the trash sorting room after the filter 1
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was replaced where the damaged filter was to be disposed of. The inspectors
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noted that there were six apparently identica! filters in the trash sorting room that
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had no red tags attached to them. The inspectors discussed the additional filters
with the system engineer the next day. These filters had been stored on a cart on ;
the 477' level of the auxiliary building for about 6 months. The system engineer I
stated that he did not know why those filters were stored in that area. Licensee
personnel planned to dispose of the filters because they had lost their traceability.
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c. Conclusions
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The inspectors concluded that the licensee's control of safety-related ventilation
filters was poor'. TS 6.8.1a requires that written procedures be established,
implemented, and maintained covering activities recommended in Regulatory Guide
1.33, Revision 2, Appendix A. TS 6.8.la applies to BwWP 800-6 and therefore,
the failure to follow BwWP 800-6 was an example of an inspector identified
violation of TS 6.8.1a (50-456/457/96021-01b(DRP)).
M3 Maintenance Procedures and Docum,entation
M3.1 Residual Heat Removal Pumn ASME Surveillance
a. Inspection Scone (61726)
The inspectors reviewed 2BwVS 5.2.f.3 2, "ASME Surveillance Requirements For
Residual Heat Removal (RHR) Pump 2RH01PB," Revision 3E1, and observed the
quarterly ASME surveillance run of the 2B RHR pump.
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Observations and Findinas
The inspectors verified that the quarterly ASME surveillance run of the 2B RHR
pump on December 31, was conducted in accordance with 2BwVS 5.2.f.3-2 and
satisfied applicable TS and Updated Final Safety Analysis Report (UFSAR)
requirements. The inspectors observed pump operation and verified performance
parameters were within the required bands with no long term trends apparent when
compared to previous pump testing. The system engineer in charge of the
surveillance noted that the effective revision (3E1) of 2BwVS 5.2.f.3-2 specified the
wrong gage in Step F.2.6 in spite of a procedure change request approved on
October 10,1996.
The inspectors verified that the engineer's corrected copy corresponded to the
approved procedure change request and the surveillance was completed.
c. Conclusions
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The inspectors noted that while the 2B RHR pump surveillance was performed in a
competent, well controlled manner that the licensee was slow to make required
procedural changes. The licensee failed to comply with BwAp 1300-10,
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" Permanent Procedure Preparation, Revision, Deletion, and Approval," Revision 2E2,
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4 Step 4.h.1, following the approval of the requested changes on October 10,1996.
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T.S 6.8.1a requires that written procedures be established, implemented, and '
maintained covering activities recommended in Regulatory Guide 1.33, Revision 2,
' Appendix A. T.S. 6.8.1a applies to BwAP 1300-10 and therefore, the failure to ' ,
follow BwAP 1300-10 was an example of a violation of T.S. 6.8.1a (50-
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M3.2 Essential Service Water ASME Surveillance Observation i
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j a. Inspection Scooe (61726)
- On December 16, the inspectors observed the performance of 1BwVS ~
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0.5-3.sx.1-1, "ASME Surveillance Requirements for 1 A Essential Service Water !
Pump," Revision O. The inspectors also reviewed 1 BwVS 0.5-3.sx.1-1, the !
- UFSAR, and TS 3/4.7.4.
b. Observations and Findinos
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The inspector determined that the SX system engineer performed BwVS
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O.5-3.SX.1-1 in accordance with the procedure. The inspectors found that all the
data obtained met acceptance criteria. The surveillance procedure was well written
and provided the necessary guidance for procedure performance. The inspectors
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observed that independent verifications were properly performed.
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The inspectors reviewed Section 9.2.1.2 of the UFSAR and found that each SX
pump shall be capable of providing 24000 gpm at 180 feet of water head. The
inspectors observed that the surveillance acceptance criteria met the minimum
design performance specified in the UFSAR.
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c. Conclusions
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' The inspectors concluded that the system engineer performed the surveillance in
accordance with the procedure and that all data obtained met acceptance criteria
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The inspectors also concluded that the surveillance satisfied technical specification
and UFSAR requirements.
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. M3.3 Instrument Maintenance Surveillance Performance Observation
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On January 2, the inspectors observed the performance of BwlS 3.2,1-206,
" Analog Operational Test of Auxiliary Feedwater Suction Loop 2P AF055,"
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Revision 4. The inspectors also reviewed Bwls 3.2.1-206, UFSAR
Section 7.3.1.1.6, and TS 3/4.3.2.
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b. Observations and Findinas
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The inspector found that Instrument Maintenance Department (IMD) personnel
complied with all applicable sections of the procedure, that all data obtained met 4
established acceptance criteria, and that IMD personnel performed independent
verification of steps that changed the alignment of safety-related equipment. The
independent verification actions were found to be in compliance with BwAP
100-18, "Braidwood Station Independent Verification Procedure," Revision 18. The
inspectors also observed good communications by the IMD personnel with the
control room. I
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The inspectors reviewed UFSAR Section 7.3.1.1.6 and found that auxiliary l
feedwater (AFW) was provided with an alternate suction from SX. This suction
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path was designed to automatically align normally closed motor operated valves if
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an actuation of a safeguards initiation relay occurs coincident with a low pump
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' suction pressure. The scope of this surveillance tested the comparator circuit trip
and reset setpoints for the 2B auxiliary feedwater pump suction pressure.
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The inspectors reviewed TS 3/4.3.2 and determined that a minimum allowable
suction pressure of 2.00 inches of mercury vacuum (13.72 psia) was specified for !
the comparator setpoint. The inspectors observed that the actual comparator trip
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setpoint was above the minimum required by TS. '
c. Conclusion
The inspectors concluded that IMD personnel performed the surveillance in
accordance with the procedure and that all data obtained rnet acceptance criteria. !
The inspectors also concluded that the surveillance satisfied TS and UFSAR
requirements. {
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M3.4 Surveillance Run of 1B AFW Pump
a. Inspection Scope (61726)
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The inspectors monitored the performance of the test at the 1B AFW pump during
performance of procedure 1BwVS 0.5-3.AF.1-2, " Unit One Diesel Driven AFW
Pump ASME Quarterly Surveillance," Revision 4, on January 2. The inspectors
interviewed the system engineer acting as the test director and the plant equipment
operator stationed at the AFW pump during the test. The inspector also performed
a review of procedure 18wVS 0.5-3.AF.1-2 for compliance with UFSAR design
criteria and TS surveillance requirements.
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b. Observations and Findinas
The inspector observed the following:
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'he test results met the acceptance criteria. The acceptance criteria met the
TS and UFSAR requirements. l
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The equipment operator at the pump utilized three-way communications
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techniques every time he talked with the unit nuclear station operator in the
control room and used self-checking when operating plant equipment. i
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Control room personnel made plant-wide announcements prior to starting or ,, j
stopping the auxiliary feedwater p' ump.
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The system engineer acted as the test director for the surveillance and was
present at the pump during performance of the entire test. The system
engineer was knowledgeable on operation of the plant equipment and use of i
tert equipment. Test equipment and instrumentation used in the test were
within calibration due dates and were installed as requ. ired by the procedure.
c. Conclusions
The surveillance successfully tested TS and UFSAR requirements. Operations
personnel and the system engineer were knowledgeable of system operation,
testing setup, and testing methods.
M4 Maintenance Staff Knowledge and Performance
M4.1 1C Heater Drain Pumn Maintenance
a. Inspection Scone (62703)
The inspectors observed the performance of maintenance on the 1C heater drain
pump on January 2, interviewed the mechanical maintenance foreman in charge of
the work, and reviewed BwAP 1600-1, "ActionN/ork Request Processing
Procedure," Revision 30E2.
b. Observations and Findinas
The inspectors observed that the work package 950009398-07 was not present at
the work site. BwAP 1600-1, Step C.15.a.6, had a note that stated that a copy of
the procedures for work being performed was a part of the minimum requirements
for a work package field copy. A maintenance worker obtained the work package
at the request of the inspectors.
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The inspectors observed the following items.
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The work site foreman did not know the purpose of an unlabeled single sheet j
l of notebook paper containing what appeared to be several measured !
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dimensions that was slipped into the work package. ~ '
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A work package step, which called for recording suction and discharge I
piping deflection when the piping was unbolted from the pump, was marked
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as "not much" and signed off as complete. The foreman stated he did not
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The work package called for removal of the coupling adjustment nut, the !
coupling key, and the pump coupling, with care to be taken as no dents were
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allowed on the coupling. The inspectors observed the workers were
removing one of the pieces with a hammer and chisel. The foreman, when
questioned did not know what the procedure meant by no dents allowed and !
whether or not it applied to the piece that was removed with the hammer.
c. Conclusions
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The inspectors concluded from the fact that the work package was missing from
the job and the foreman was not knowledgeable about several steps of the :
procedure when questioned, that the work was poorly controlled. TS 6.8.la !
requires that written procedures be established, implemented, and maintained
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covering activities recommended in Regulatory Guide 1.33, Revision 2, Appendix A.
TS 6.8.1a applies to BwAP 1600-1 and therefore, the failure to follow BwAP 1600- l
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01 was an inspector identified violation of TS 6.8.1a. (50-456/457/96021 j
Old(DRP)). '
M4.2 Mispositioned Nuclear Fuel
a. inspection Scope (71707) {
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The inspectors reviewed a licensee finding of spent fuel assernblies being placed in
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the wrong location in the spent fuel pool. The Inspectors reviewed BwFP FH-4,
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" Fuel Movement in Spent Fuel Pool," Revision 4; BwAP 370-3, " Administrative '
Control During Refueling," Revision 15; Commonwealth Edison Nuclear Procedure
Form 86-2616, "PWR Station NCTL;" and BwAP 2364-9, " Controlling Movements
of Nuclear Fuel into the Spent Fuel Racks," Revision 2. The inspectors interviewed
a station nuclear engineer, a fuel handling supervisor and a fuel handler, and
observed fuel handling operations.
b. Observations and Findinas
During spent fuel movement operations within the spent fuel pool on December 1,
two fuel assemblies were placed in the wrong locations. Both moves were made on
the same shift by the same crew. The Nuclear Component Transfer List (NCTL)
required fuel assembly S31W to be moved to spent fuel pool location C3-J4 but it
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.was placed in C2-J4. The NCTL required fuel assembly T70X to be moved to spent
fuel pool location C4-111 but it was moved to C4-J11. S31W was discovered to be
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out of position on December 3 and T70X on December 11.
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Inspectors verified that shutdown margin of the spent fuel pool had been maintained
by reviewing BwAP 2364-9, Data Sheet 1, which indicated that fuel assemblies
S31W and T70X had more than the minimum burnout required for unrestricted
storage in the spent fuel pool.
BwFP FH-4 required triple verification for fuel moves which was defined as "the
process utilized to verify correct positioning of a fuel asserpbly compared to the
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NCTL, by a minimum of two fuel handlers and a qualified fuel handling supervisor,
all of whom have independently verifiecfsnd concur with the fuel assembly
position." Interviews by the inspectors with two of the qualified personnel on shift
the 1st of December indicated that contrary to BwFP FH-4, only the supervisor had
read the NCTL for every move. The personnel involved did not have a complete and
consistent understanding of the triple verification process.
The inspe,ctors interviewed a nuclear station engineer in order to verify the rest of
the fuel assemblies in the spent fuel pool were in the correct location and verified
that the licensee had performed a piece count of the spent fuel pool which verified
that spent fuel pool celllocations were filled or empty as required by the NCTL but
did not check fuel assembly serial numbers. Licensee personnel stated that
maintenance work on the refueling platform crane prevented the use of a camera to
perform a serial number check of the pool and that a complete inventory of the fuel
was planned for February 1997.
c. Conclusions
The inspector concluded that the fuel handlers and their supervisors had a poor j
understanding of the requirements for multiple verification of procedure steps.
TS 6.8.1a requires that written procedures be established, implemented, and
maintained covering activities recommended in Regulatory Guide 1.33, Revision 2,
Appendix A. TS 6.8.1a applies to BwFP FH-4 and the NCTL and therefore, the
failure to follow BwFP FH-4 and the NCTL was a violation of TS 6.8.1a
(50-456/457/96021-01e(DRP)).
M4.3 Imoroner Securina of Carts
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a. Inspection Scone (62703)
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During routine inspection of the auxiliary building the inspectors noted several ;
problems with the securing of movable carts. The inspectors reviewed BwAP !
100-10, " Conduct of Station Personnel," Revision 2: BwRP 6210-24, " Installation,
Removal, and Tracking of Temporary Shielding," Revision 1; and Braidwood Policy
Memo #65 which addressed the issue of unattended rolling carts and ,
equipment / tools in areas of the plant containing safety-related equipment. The l
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' inspector also interviewed operations and facilities maintenance, engineering,
radiation protection, and plant management personnel.
b. Observations and Findinas
BwAP 100-10, Steps c.4.d and c.4.e, list the requirements for securing moveable
carts and equipment. During the inspection period the inspectors found several
instances where carts and equipment were not secured in accordance with BwAP
100-10. Some examples of unsecured or improperly secured carts and equipment
included:
1. The inspectors observed two shield racks, each consisting of six 1-foot by 6-
foot lead blankets, tied off to safety-related duct w6rk in the Unit 1 curved
wall area of the auxiliary building on November 4,1996 and reported the
condition to operations personnel on that date. The inspectors observed the
racks again on December 9 and noted that no corrective actions appeared to
have been taken for the earlier concerns. One of the racks was very close to
(and possibly in contact with) safety-related lines 1Sl97AA and 1Sl97BA.
These are 3/4-inch lines supplying FTl 6A, safety injection (SI) Pump .
Minimum Flow, on the Si pump common minimum flow line. Additionally,
both carts were within 1 foot of safety-related ventilation ductwork for the
1B charging and 1B Si pump rooms exhaust.
The shielding cart labelled with tag "1 of 2" was found attached with small
diameter rope to support beams for ventilation exhaust ductwork from 1B
charging and 18 SI pump rooms. This ductwork was safety-related. As
stated in BwAP 100-10, Step c.4.d, unattended rolling carts are secured in
order to prevent rolling into safety-related equipment during a seismic event.
The shielding cart labelled with tag "2 of 2" was found with one wheel
locked with a clamp. Since all four wheels of the cart could pivot, the cart
had a full range of motion around the wheel with the clamp. Immobilizing
the cart with only one wheel locked was not in compliance with BwAP
100-10, Step c.4.e.2, which required a wheel brake on 50% of the wheels.
Additionally, the cart was found very close, and possibly in contact with
safety-related lines 1Sl97AA and 1Sl97BA. This cart was also within 1 foot
of safety-related ventilation ductwork.
The inspector verified the carts were removed from the Unit 1 curved wall
area on the afternoon of December 9,1996.
In addition, several problems with the temporary shield request
(BwRP 6210-24T1)96-104 paperwork and installation were notr.d:
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Step 4 required listing the work description and work requcst (WR)
number. Contrary to this, no WR number was listed for stcp 4.
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Step 8 signoff for temporary shield walkdown by field supervisor was
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marked "N/A unless within or over small size piping." One of the i
shield racks was found close to (and possibly in contact with) 3/4-
inch safety-related piping but were marked N/A. Additionally, both
carts were found within 1 foot of safety-related ventilation ductwork
for the 18 Si pump and 1B charging pump room exhaust.
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Step 16 of 96-104 and the Attachment to 96-104 stated that the
shielding was requested to shield workers from charging line
2CV01E-3. The shielding was placed in Unit 1 curved wall area.
Upon notification of this discrepancy, radiation protection personnel
._.
indicated that the correct line being shielded was 1CV01E-3.
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Attachment to 96104, Step 2, required that the carts be adequately
restrained to prevent sliding, rolling, or overturning. Both carts were
found on December 9,1996, without adequate restraints to prevent
rolling or overturning.
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Attachment to 96-104, Step 5, required that the racks be tracked and
removed when the shielding is no longer required. Contrary to this,
the Furmanite leak sealing work that the request was initially
generated to support was delayed during the summer of 1996 and no -
work has been performed since. The temporary shielding was not
removed when the Furmanite work was delayed and the shield racks
remained in place until the licensee was questioned by the inspectors
about the reasons for shielding in the area.
2. A work cart for instrument maintenance activities on the reactor containment
fan cooler 1 A & 1C SX outlet radiation monitor (OPR02J) was found
attached to a support for the safety-related essential service water return
header on December 17.
3. A frame / hoist used for floor plug removal was found attached to a safety-
related piping support for essential service water piping on December 17.
Movement of the frame was still possible.
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The inspector reported the unsecured carts to operatior :r facilities maintenance
personnel as the carts were discovered. The inspectors . oke with the facilities
maintenance individual in charge of the auxiliary building auout the causes for
recurring cart issues. He indicated that plant personnel sometimes do not
understand that it is not acceptable to tie carts to safety-related equipment. He also
indicated that there may be a general misunderstanding for the reasons that carts
and rolling equipment must be secured. l
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c. Conclusions
Requirements for securing moveable carts and equipment as stated in
BwAP 100-10, Conduct of Station Pe~rsonnel, and Station Policy Memo #65 were
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not satisfied on numerous occasions during the period. Carts and moveable
equipment were fe.ft unsecured or tied to safety-related equipment.
Temporary shielding installed under shielding request 96-104 was not properly
configuredy administratively controlled, or physically restrained to protect safety-
related equipment in the area of the shielding.
TS 6.8.1a requires that written procedures be established, implemented, and
maintained covering activities recommended in Regulatory Guide 1.33, Revision 2,
Appendix A. TS 6.8.1a applies to BwAP 100-10 and BwRP
6210-24 and therefore, the failure to follow BwAP 100-10 and BwRP
6210-24 was a violation of TS 6.8.1a (50-456/457/96021-01f(DRP)). .
The inspectors notified plant operating personnel of possible problems with the
installation of shielding covered under shielding request
96-104 on November 4,1996. No action was taken by plant personnel to
investigate or rectify the conditions until December 9,1996, when the inspector
notified radiation protection personnel. Failure to take corrective actions in a timely
manner is a violation of 10 CFR Part 50, Appendix B, Criteria XVI, (50-
,
456/457/96021-02(DRP)).
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M8 Miscellaneous Maintenance issuer. (92902), (92700)
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M8.1 (Closed) Inspection Followuo item (IFI) 50-456/96009-05): Unit 1 main turbine I
digital electro-hydraulic control (DEHC) software corruption caused a 42% load !
reduction during monthly testing of the turbine throttle and governor valves I
(TV/GV). The licensee had revised one parameter (as specified by the vendor) !
which controlled the rate of valve movement during the monthly TV/GV test. The
!
same revision had been performed on Unit 2 with no problem. Analysis of software j
downloaded from the Unit 1 main turbine DEHC after the event revealed that !
sections of memory used by the valve management program had been corrupted.
There was no pattern to the corrupt memory locations, which made it impossible to
determine the cause of the corruption. Human error was evaluated and, due to the
number of keystrokes required to cause a problem, was eliminated as a root cause.
The floppy drive which was used for software loading and transfer was verified
operational. The floppy drive check sum function was also verified operational.
The DEHC computer system was taken through extensive diagnostics and the
memory control modules were replaced as a precautionary measure. The removed
memory control modules were tested extensively with not problems found.
The licensee undertook several steps to prevent recurrence. Power supply
interruptions have caused the loss of automatic turbine control in the past. An ,
uninterruptible power supply was approved for installation on the DEHC power l
supply. To allow check and analysis of the actual software in the DEHC core
without downloading through a floppy drive, the licensee was designing a link
between the DEHC core and a portable computer.
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The inspector interviewed the Supervisor, Operations Analysis Department and
verified that reasonable steps were being taken to prevent recurrence. This item is
closed.
M8.2 (Closed) Licensee Event Report (LER) 457/96005-00: 2A AFW pump auto startbd
during a surveillance at the remote shutdown panel. The operator failed to
,
recognize that an AFW pump auto start would occur if the pump control switch was
' placed in local at the remote shutdown panel will6 an auto start signal present. Tha
event was included in NRC Integrated inspection Report 50-457/96009 as Non-
Cited Violation 50-457/96009-04. The inspectors verified that be governing
procedure, BwOS PL-R1, " Remote Shutdown Panel Control Power Checks," was
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revised to include a precaution that an auto start would result if the pump control
switch was taken to local on the remote shutdown panel and an auto start signal
j was present. The operators involved were counselled and the inadvertent AFW
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pump start event was covered during licensed operator requalification training. The
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inspectors considered that the licensee's corrective action was appropriate. This
item is closed.
1
M8.3 (Closed) LER 457/96006-00: The 2A Emergency Diesel Generator (DG) was
declared inoperable based on the time elapsed between satisfactory samples
a obtained from the 2A DG Fuel Oil Storage Tank. This event was documented on
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NRC Integrated Inspection Report 50-457/96009 as Non-Cited Violation 50-
! 457/96009-03. The licensee identified inadequate work practice as the primary
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cause in that no process existed to ensure the surveillance 31-day time limit was
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met. The inspector interviewed the maintenance staff supervisor and a fuel
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handling supervisor and reviewed 1986 diesel fuel sample records and verified that
procedures were in place and in use to track and record surveillance results and that
sample delivery and communications procedures with System Materials Analysis
Department were improved. The inspectors considered that the licensee's
corrective action was appropriate. This item is closed.
Ill. Enaineerina
E1 Conduct of Engineering
E1.1 Unit 1 Essential Service Water Leak
a. Inspection Scope (37551)
The inspectors were notified by the licensee that a small hole had developed in the
1 A SX strainer backwash line that was leaking about 2 gallons per minute. The
inspectors reviewed Generic Letter 91-18, Generic Letter 90-05, and American
Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section
XI,1983 Winter addendum, Subsections LWD-3000 and IWB-3000.
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b. Observations and Findinns
The inspectors identified that ASME Section XI, Sections IWB-3112 (c). Table IWB-
3410-1, IWB-3522, and IWB-3142 stated in part that a through wall flaw in Class C
piping was unacceptable for continued service and corrective action was required
prior to returning the component to service. Generic Letter 91-18 stated that an
ASME Class 1,2, or 3 component with a through wallleak must be considered
inoperable unless it was ASME Class 3 piping that contained a substance less than
,
200 psig and less that 275 degrees F and the flaw was evaluated in accordance
with Generic Letter 90-05. The inspectors verified that the leaking SX piping was
ASME Class 3 and that the fluid within was less than 200 psig and 275 degrees F.
,
The leak was identified by the licensee on December 23 and the system was initially
screened as operable by the shift engineer based on the amount of leakage. To
isolate the leaking component the 1 A SX pump would have to have been isolated '
which would have made the train inoperable. The inspectors identified that the
licensee was not in compliance with the ASME code, on December 30, in that a
- through wall flaw had been identified and the component had not been removed ,
from service nor had any corrective action been taken. The inspectors identified
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that the licensee had not declared the 1 A SX train inoperable and had not performed
an evaluation to demonstrate operability as discussed in Generic Letters 91-18 and
90-05 as of December 30.
Subsequent to several conference calls with the NRC the licensee completed an
operability evaluation and performed the Generic Letter 90-05 evaluation on
December 31. The licensee later determined that a code repair to the piping could
not be performed within the 72-hour TS limiting condition for operation and
submitted a relief request to the NRC on January 9.
c. Conclusions
)
The inspectors concluded that the licensee's understanding of the ASME code and
the applicable generic letter guidance for dealing witn the identified type of flow
was poor ni that NRC intervention was necessary to ensure the correct process
was follow rL The inspectors also concluded that the failure to comply with the
ASME Section XI code was a violation of 10 CFR 50.55a(g)(4) which required that
all components that are classified as ASME Code Class 3 must meet the
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requirements set forth in Section XI. (50-456/457/96021-03(DRP))
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IV. PLANT SUPPORT '
R4
Staff Knowledge and Performance in Radiological Protection and Chemistry Controls
R4.1 Reactor Coolant Filter Chanae -
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a. Inspection Scope (71750)
The inspectors observed the replacement of a reactor coolant filter of the chemical
and volume control system on December 6, reviewed BwOP CV-10, "CV Filters-
Isolation and Return to Service," Revision 8; BwOP WX-197, " Changing Plant Filters
With The Filter Removal Machine," Revision 6; Radiation Work Permit 963000; and
interviewed two operators and a radiation protection technician involved in the
evolution.
b. Observations and Findinas
On December 6, the inspectors observed that the radiation protection technician j
ensured that the workers and the inspectors were properly briefed.and were in
compliance with the radiation work permit and that they continuously monitored the
radiation levels of the filter as it was transported to radwaste storage. The
operators spread rags around the filter removal area to prevent any dripping fluid
from contaminating the floor.
c. Conclusions !
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The inspectors concluded that the radiological precautions taken during the
evolution were good.
R4.2 Unnosted Radiation Area
a. Insoection Scope (717501
The inspectors reviewed BwRP 5010-1, " Radiological Posting And Labelling
Requirements," Revision 5, and observed radiological postings in the auxiliary
building,
b. Observations and Findinas
On January 2 the inspectors observed a posted radiation hot spot in the Unit 1
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moderat ng heat exchanger room outside of a posted radiation area. The inspectors
checked local radiation levels and verified that several parts of the room exceeded
5 mrem per hour. The licensee stated that the radiation area surrounding the room
was de-posted when radiation levels decreased and that the technician had
subsequently failed to post the door to the room as a radiation area. BwRP 5010-1
states "if an area exists which is accessible to personnel, and for which radiation
levels exceed 5 mrem in any 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the source, then post
" CAUTION, RADIATION AREA * signs at any entrance to the area."
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A ,i.i- -b--- _ g J ,,ue s a- ,W Am - 44+4c-- & - * J -ak ek ..-.4_ - e < (.mic42.- ..d.i-
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c. Conclusions
The inspectors concluded that the failure to post the Unit 1 moderating heat
exchanger room as a radiation area was a personnel error. TS 6.8.1a requires that
written procedures be established, implemented, and maintained covering activities
recommended in Regulatory Guide 1.33, Revision 2, Appendix A. TS 6.8.1a applies
to BwRP 5010-1 and therefore, the failure to follow BwRP 5010-1 was a violation
of TS 6.8.1a (50-456/457/96021-01g(DRP)).
R4.3 Failure of Security Guard to Follow Whole Body Friskina Procedures
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a. Inspection Scope
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The inspector observed security personnel using installed whole body frisking
monitors contrary to requirements posted on the monitors. As a result of the
observation the inspector reviewed BwRP 5822-8, " Operation and Calibration of the
IPM-7/8 Whole Body Frisking Monitor," Revision 2. The inspectors also interviewed
radiation protection personnel and security management.
b. Observations and Findinas
On December 18, the inspectors observed a security guard not following posted
requirements for exiting the auxiliary building. A security guard entered a monitor
and caused an alarm condition. Upon receiving the alarm, the guard proceeded to
the next machine for frisking. The guard continued to alarm the IPM-7/8 machines
for a total of five times, two separate machines twice and a third machine once. At
the time of the fifth alarm, radiation protection personnel arrived at the area and the
guard reported the condition.
The guard was subsequently cleared by radiation protection personnel. The
alarming condition was caused by natura;ly occurring radioactivity (radon gas).
BwRP 5822-8, Step f.1.h.2, stated that upon causing an alarm condition, a second
frisk must be performed at the same monitor and that radiation protection personnel
must be contacted if the second frisk attempt results in an alarm condition. The
security guard did not attempt to contact a radiation protection technician after
alarming the monitor the second time.
c. Conclusion
The inspectors concluded from discussions with radiation protection and security
management that the procedural requirement for using the IPM-7/8 monitors were
not widely known and when radiation protection technicians were present they
frequently told workers to try another monitor.
TS 6.8.1a requires that written procedures be established, implemented, and
maintained covering activities recommended in Regulatory Guide 1.33, Revision 2,
Appendix A. TS 6.8.1a applies to BwRP 5822-8 and therefore, the failure to follow
BwRP 5822-8 was a violation of TS 6.8.1a (50-456/457/96021-01h (DRP)).
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- S1 Conduct of Security and Safeguards Activities
S 1.1 General Comments
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a. . Inspection Scone (71750)
The inspectors observed physical security measures for access control to protected
areas. The inspectors interviewed the security administrator and observed security
personnel controlling access to protected areas. The inspector reviewed procedure
BwAP 900-4, " Access Control," Revision 12.
b. Observations and Findinas
.
.
On December 30,1996, the inspector observed the searching of individuals
authorized for unescorted access to protected areas. This observation included
,
security personnel's monitoring of metal and explosive detectors, x-ray surveillance
of hand carried items, and occasionally pat-down searches. The inspector also
observed security personnel controlling access to the lake screen house which
included the escorting of individuals from the main plant site to the lake scraen
house, the admission of individuals to the lake screen house protected area, ed the
admission of a vehicle to the lake screen house protected area. The inspector found
the security administrator and security personnel knowledgeable of access control
requirements.
c. Conclusions
The inspector concluded from discussions with radiation protection and security
management that the procedural requirement for using the IPm-718 monitors were
The inspectors concluded that tha security personnel observed performed their
responsibilities in an expeditic9.e and professional manner consistent with the
requirements of BwAP 900-4 and the Station Security Plan. The inspector q
concluded that BwAP 900-4 was well written and provided clear instructions to the I
user.
V. Manaaement Meetinas
X1 I
Exit Meeting Summary i
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The inspectors presented the inspection results to members of licensee management !
on January 13,1997. The licensee acknowledged the findings presented. i
The inspectors asked the licensee whether any materials examined during the
inspection should be considered proprietary. No proprietary information was
identified.
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PARTIAL LIST OF PERSONS CONTACTED !
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Licensee -
H. G. Stanley. Site Vice President - -
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- T. Tulon, Station Manager !
W. McCue, Support Services Director >
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'R. Flessner, Site Quality Verification Director i
- R. Byers, Majidenance Superintendent
- D. Miller, Work Control Superintendent ;
- T. Simpkin, Regulatory Assurance Supervisor j
- H. Cybul, System Engineering ." nervisor ,.
- J. Meister, Engineering Manager ~ ~
- R. Wegner, Operations Manager
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- M. Cassidy, Regulatory Assurance - NRC Coordinator
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- Present at Exit Meeting.
NRC i
R. Lanksbury, Chief, Reactor Projects Branch 3
C. Phillips, Senior Resident inspector
J. Adams, Resident inspector '
D. Rich, Resident inspector !
IDNS
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INSPECTION PROCEDURES USED
1
IP 37551: Onsite Engineering !
IP 61726: Surveillance Observations
IP 62703: Maintenance Observation -
l IP 71707: Plant Operations
IP 71750: Plant Support Activities
IP 92700: Onsite Followup of Written Reports of Nonroutine Events at Power Reactor l
Facilities
IP 92902: Followup - Maintenance '
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ITEMS OPENED, CLOSED, AND DISCUSSED
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50-456/457/96021-01a VIO failure to follow procedure
50-456/457/96021-01b VIO failure to follow procedure
50-456/457/96021-01c VIO failure to follow procedure 1
50-456/457/96021-01d VIO failure to follow procedure
50-456/457/96021-01e VIO failure to follow procedure
50-456/457/96021-01f VIO failure to follow procedure
l 50-456/457/96021-01g VIO failure to follow procedure
50-456/457/96021-01h VIO failure to follow procedure
50-456/457/96021-02 VIO ineffective corrective actions
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50-456/457/96021-03 VIO failure to comply with ASME Code
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Closed ,
I 50-456/96009-05 IFl Unit 1 main turbine control software failure
! 50-457/96005-00 LER 2A AFW pump auto started during surveillance
50-457/96006-00 LER 2A DG declared inoperable due to missed oil sample
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- Discussed
50-457/96009-03 NCV exceeded TS 4.8.1.1.2 diesel fuel oil sample frequency
l. 50-457/96009-04 NCV inadequate procedule
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LIST OF ACRONYMS USED
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1
ASME American Society of Mechanical Engineers {
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CFR Code of Federal Regulations
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DEHC Digital Flictro-Hydraulic Control
DG Diesel 9.nerator {
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GL Generic Letter 1
HEPA High Efficiency Performance Air
IFl inspection Followup item
IMD instrument Maintenance Department
IR inspection Report "
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LER Licensee Event Report
mrem Millirem
NCTL Nuclear Component Transfer List
NCV Non-Cited Violation
NRC Nuclear Regulatory Commission
PDR Public Document Room ,
SI Safety injection
SX Essential Service Water System
TS Technical Specification
TV/GV Turbine Throttle and Governor Valves
UFSAR Updated Final Safety Analysis Report
VIO Violation