ML20135B645

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Insp Repts 50-456/96-19 & 50-457/96-19 on 961019-1129. Violations Noted.Major Areas Inspected:Aspects of Licensee Operations,Maint,Engineering & Plant Support
ML20135B645
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 02/18/1997
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20135B553 List:
References
50-456-96-19, 50-457-96-19, NUDOCS 9703030144
Download: ML20135B645 (22)


See also: IR 05000456/1996019

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U.S. NUCLEAR REGULATORY COMMISSION

REGION lli

Docket Nos:

50-456, 50-457

License Nos:

PF-72, NPF-77

Report No:

50-456/96019;50-457/96019

Licensee:

Commonwealth Edison (Comed)

Facility:

Braidwood Nuclear Plant, Units 1 and 2

Location:

RR #1, Box 84

Braceville, IL 60407

Dates:

October 19 - November 29,1996

Inspectors:

C. Phillips, Senior Resident inspector

J. Adams, Resident inspector

D. Rich, Resident inspector

T. Tongue, Reactor Engineer

T. Esper, Illinois Department of Nuclear Safety

Approved by:

Roger Lanksbury, Chief

Reactor Projects Branch 3

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9703030144 970218

PDR

ADOCK 05000456

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EXECUTIVE SUMMARY

Braidwood Nuclear Plant, Units 1 & 2

NRC Inspection Report 50-456/96019;50-457/96019

This inspection included aspects of licensee operations, maintenance, engineering, and

plant support. The report covers a 6-veek period of resident inspection.

Operations

The inspectors concluded, from discussions that occurred during the PORC meeting,

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that the importance of the pressurizer manway and tae reactor head vent pathways

were understood by management and the reduced inventory evolutions were well

planned. However, in the case of the first draining evolution the blockage of the

pressurizer manway vent path, the creation of a loop seal on the reactor head vent

pathway, and miscommunication that resulted in the exclusion of an additional

drainage verification method from the procedure indicated that this evolution was

not well executed. (Section 01.1)

The inspectors concluded that during the performance of a turbine valve exercise

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that the nuclear station operator (NSO) demonstrated poor control of reactivity,

failed to perform steps of the annunciator alarm procedure for the Average

Temperature (Tave)/ Reference Temperature (Tref) deviation alarm, and failed to

comply with the " Operating Logs and Records" procedure. The inspectors also

concluded that the unit supervisor failed to provide the proper oversight during the

event. This licensee identified and corrected event is being treated as a Non-Cited

Violation. (Section 04.1)

Maintenance

The inspectors observed the performance of low voltage closure testing and

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lubrication of a 480 volt DS series breaker. The inspectors concluded that the

maintenance was performed in accordance with the procedure and was closely

supervised. (Section M1.1)

The inspectors concluded that the surveillance activities observed during this

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inspection period were performed in a competent and well controlled manner.

(Section M1.2)

The inspectors concluded that BwAP 100-21 was inadequate in that it did not

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require a review of the surrounding area for the potential to introduce foreign

materialinto a safety-related system resulting in a piece of scaffolding being

dropped into the suction bay for the essential service water system. The inspectors

concluded that this procedural deficiency was a violation. (Section M1.3)

The inspectors observed the installation of Unit 1C Steam Generator manways and

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diaphragm plates and reviewed the associated procedure. The inspectors concluded

that the licensee failed to complete all steps of the installation procedure. The

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inspectors also concluded that specific management actions to ensure procedure

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compliance were ineffective in that an individual assigned to follow the work

procedure took no action when the procedure was not complied with. This event is

considered a violation of technical specifications. (Section M4.1)

The inspectors reviewed the licensee's response to an observed abnormal voltage

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control indication on the 1B Diesel Generator. The licensee determined that

125 volts direct current (VDC) leads were reversed on the instantaneous

prepositioning (IPP) board. The inspectors concluded that the maintenance was

performed without the necessary documentation. This licensee identified event is

being treated as a Non-Cited Violation. (Section M4.2)

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The inspectors concluded that not documenting a 10 CFR 50.59 safety evaluation

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for returning the unit to service with the Unit 1 cold leg reactor coolant stop valve

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degraded, demonstrated a lack of complete understanding of the 10 CFR 50.59

requirements. (Section E2.1)

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The licensee observed cooler than normal temperatures in the Unit 1 essential

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switchgear room. An investigation determined that control relay contacts were

configured incorrectly. The inspectors concluded that field documentation was

confusing and post modification testing was inadequate. This event is considered

an Unresolved item until the inspectors can assess the licensee's corrective actions

for previous instances of inadequate post maintenance testing. (Section E2.2)

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While a system engineer's identification during a review of disconnected power

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leads for two control room dampers of an inconsistency between the control and

instrumentation drawing and external wiring diagram was good and demonstrated a

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questioning attitude, the failure to update the appropriate drawings at the time the

power was removed was a violation of 10 CFR Part 50, Appendix B, Criterion VI.

This licensee identified event is being treated as a Non-Cited Violation.

(Section E2.3)

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The inspector concluded that the system engineer's detection of electronic noise

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effecting vibration readings on a diesel oil transfer pump was an excellent

observation since the vibration measurements initially obtained met the acceptance

criteria. The system engineer demonstrated an excellent knowledge of expected

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system performance and a questioning attitude. (Section E4.1)

Plant Suocort

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The inspectors performed a visual inspection of the high level spent resin tank

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room. The inspectors found the room and the equipment in the room to be in good

condition. (Section R2.1)

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The inspectors observed part of an emergency planning drill and concluded that it

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provided valuable and challenging training.

(Section PS.1)

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The inspectors reviewed physical security measures and procedures and conducted

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interviews with security personnel on duty. The inspectors found security facilities

in good condition and personnel knowledgeable and professional. (Section S1.1)

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Report Details

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Summary of Plant Status

Unit 1 entered the period in cold shutdown for a scheduled mid-cycle outage. The unit

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was shut down on October 12,1996, to perform inspections and maintenance.

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Contractors performed eddy current inspections and the necessary sleeving and plugging of

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degraded or defective steam generator tubes in all steam generators. The steam generator

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maintenance required the plant operators to perform two reduced inventory evolutions for

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the installation and subsequent removal of nozzle dams in the 1C Steam Generstor. This

was due to the inability to shut the C Loop Cold Leg Reactor Coolant Stop Valve. Unit 1

ended the period shutdown with plant operators making preparations for the unit's restart.

Unit 2 operated at or about 100% for the entire period.

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1. Operations

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Conduct of Operations

01.1 Reduced Inventorv Activities

a.

Insoection Scope

The licensee lowered the Unit 1 reactor vessel water level to mid-loop to install

steam generator nozzle dams in the "C" steam generator because of the inability to

shut the "C" reactor coolant loop cold leg isolation valve. The inspectors attended

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a preevolution plant operations review committee meeting and reviewed procedures

BwOP RC-4, " Reactor Coolant System Drain," Revisions 7 and 8, and 1BwOA

PRI-10, " Loss of RH Cooling Unit 1," Revision 56. These reviews were performed

using NRC Temporary Instruction 2515/113, " Reliable Decay Heat Removal During

Shutdown," Generic Letter 88-17, " Loss of Decay Heat Removal," technical

specifications, and the Updated Final Safety Analysis Report (UFSAR). The

inspectors also reviewed problem identifica. ion form (PlF) 456-201-96-2375 which

described problems with the reactor head "ert path during the drain down to the

reactor flange,

b.

Observations and Findinas

The inspectors observed the licensee drain the Unit 1 reactor water level to the

vessel flange level on October 19 and to the mid-loop region on Octob9r 21. The

inspectors verified that both shutdown cooling trains were verified to be operable

with only one train operating as required, redundant flow paths were available for

emergency inventory addition, and redundant vessel water levelinstruments and

core temperature monitoring instruments were operable and in service. The

inspectors also verified that there were no other outage activities ongoing that could

have affected shutdown cooling.

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The inspectors attended the plant operations review committee's (PORC) meeting to

evaluate the drain down procedure. Committee members recommended that holdup

tank level be monitored during the draining process. Since the water would be

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drained into the holdup tank, monitoring this tank's level would provide an

additional check on total volume drained from the reactor coolant system.

However, due to miscommunication, this recommendation was not incorporated

into the procedure. The inspectors discussed this issue with plant management and

administrative controls were subsequently implemented to monitor holdup tank level

prior to start of draining to a reduced inventory condition.

Prior to starting the drain down, a licensee inspector noticed that the pressurizer

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manway, which had been opened to provide a vent path, was inadvertently partially

capped with a foreign material exclusion cover. This information was promptly

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conveyed to the control room and the draining procedure was halted. The licensee

removed the cover and initiated an investigation of this event prior to recommencing

the draining procedure.

During the drain down to the reactor flange level licensee personnel noticed that

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reactor vessel indicated water level reached 400 feet before the anticipated time to

drain the volume of water. However, the reactor vessel level instrumentation

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system was still reading 100% in the upper head region on both level trains when it

should have been reading 100% in the vessel region. The licensee determined that

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the hose connecting the reactor head vent to a collection bottle had slumped and

filled with water resulting in a loop seal. When the loop seal condition was cleared

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reactor water levelindication rose about 4 feet. The licensee determined that non-

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licensed operators had moved the hose and collection bottle prior to drain down but

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had not secured the hose to prevent it from dropping below the vent valve level,

c.

Conclusions

The inspectors concluded, from discussions that occurred during the PORC meeting,

that the importance of the pressurizer manway and the reactor head vent pathways

were understood by management and the evolution was well planned. However,

the blockage of the pressurizer manway by maintenance personnel, the creation of

the loop sealin the reactor head vent pathway, and miscommunications that

resulted in a desired verification of reactor water level draindown not being

incorporated into the procedure indicated that this evolution was not well executed.

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04

Operator Knowledge and Performance

04.1 Poor Reactivity Control and Failure to Follow Procedures

a.

Inscection Scope (71707)

The inspectors reviewed a licensee finding of high average coolant temperature

(Tave) deviation. Tave deviation is the difference between the highest Tave channel

reading and what Tave should be for the existing power level, referred to as the

reference temperature (Tref). The Tave deviation annunciator alarm setpoint was

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3 degrees F. The inspectors interviewed 2 nuclear station operators (NSO), the unit

supervisor (US) and the Shift Operation Supervisor and reviewed procedures 2BwOS

3.4.2.a-1, " Turbine Overspeed Protection Systems Monthly Valve Stem Freedom

Checks," Revision 8E1; BwAP 350-1 " Operating Logs and Records," Revision 8;

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BwAP 300-1, " Conduct Of Operations," Revision 19; BwAR 2-14-D1 "Tave Control

Deviation High," Revision 7; licensee problem identification report 457-200-96-038;

NSO operating logs (Unit 2, Oct 1 - Nov 12,1996); and the annunciator alarm

summary print out (Unit 2, Oct 26,1996).

b.

Observations and Findinas

The inspectors reviewed unit operating logs that stated that on October 27,1996,

Unit 2 power was reduced from 100% to approximately 75% as a prerequisite to

2BwOS 3.4.2.a-1. Inspector interviews with the operators indicated that the NSO

and US became concerned that axial flux distribution (Delta 1) was too high when

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rods began automatically stepping out to compensate for xenon buildup, in

response the operators placed rod control in manual. The inspectors learned

through a review of plant data that the NSO made a series of dilutions to the reactor

coolant system in order to compensate for the continuing xenon buildup. However,

the inspectors determined through the data review and interviews with other

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operators that the NSO did not accurately predict the necessary dilution volume and

did not allow time between successive dilutions for the plant to stabilize. This

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resulted in an over dilution which caused Tave to rise above Tref and the Tave

deviation annunciator to then alarm. Tave deviation reached a maximum of about

6 degrees F and remained above the alarm setpoint for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 43 minutes. The

annunciator alarm procedure, BwAR 2-14-D1 required the operator to place rod

control in manual and match Tave with Tref. However, the alarm procedure was

not referenced or followed. The operators were concerned about Tave but took no

action to restore it to the normal range. The alarm condition did not clear until the

surveillance was completed and the ramp-up to full power was commenced.

Operator experience was a contributing factor to the occurrence. The inspectors

learned that the Unit NSO had about 10 months operating experience but had not

previously performed a significant load chance and the US had previously

supervised two similar load ramps. There v ere two experienced NSOs assisting in

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the control room but their experience was r.at utilized.

The inspectors verified NSO logs recorded the power ramp-down and ramp-up and

performance of 2BwOs 3.4.2.a-1 but did not record any reactivity changes as

required by BwAP 350-1. The NSO logs did not document any difficulty in

controlling reactivity and did not document reactor operation with Tave higher than

normal.

The inspectors conducted a follow up review of the Unit 2 NSO logs. The

inspectors selected four evolutions that had been performed between October 1 and

November 12,1996, that required NSO log entries per BwAP 350-1, and verified

the required log entries were made.

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The licensee performed the following corrective actions to prevent recurrence of the

event:

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Changed BwAP 350-1 to require shift engineer and unit supervisor's

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signatures indicating concurrence that log entries are appropriate for the

shift;

the NSO received additional training on performing reactor power changes:

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the unit supervisor was counseled regarding management expectations for

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maintaining operating parameters, utilizing the experience of the team,

informing the shift engineer of unusual conditions, and logkeeping;

management willidentify licensed operators needing additional training on

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performing reactor power changes and make arrangements for training:

review the event with alllicensed operators to increase operator sensitivity

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to reactivity control, to identify other evolutions that require additional

training or operator guidance, and to reinforce management expectations for

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operator logs.

c.

Conclusions

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The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR),

Technical Specifications, and the maximum Tave reached during the event and

concluded that the plant was not operated outside its design basis.

The event indicated a weakness in operator training in reactivity management and

performance of required actions for an alarming annunciator. The inspectors

concluded that both the operator and the supervisor were overly focused on a single

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plant parameter, Delta l, during the evolution and unnecessarily operated with Tave

different than Tref. The knowledge of experienced NSOs on shift was not utilized

and the shift engineer was not informed of the event which indicated a lack of

teamwork. The inspectors considered the lack of meaningful log entries describing

an unusual situation to be poor watchstanding practice.

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Technical Specification (TS) 6.8.1.a requires that written procedures be established,

implemented, and maintained covering activities recommended in Regulatory

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Guide 1.33, Revision 2, Appendix A. TS 6.8.1.a applies to BwAR 2-14-D1 and

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BwAP 350-1 and therefore, the failure to follow BwAR 2-14-D1 and BwAP 350-1

was a violation of TS 6.8.1.a. The inspectors concluded that the training and

counseling sessions and procedural change commitments made by the licensee

were adequate corrective actions. This licensee-identified and corrected violation is

being treated as a Non-Cited Violation consistent with Section Vll.B1 of the NRC

Enforcement Policy (50-457/96019-01 (DRP)).

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11. Maintenance

M1

Conduct of Maintenance

M 1.1 Inspection and Lubrication of A Westinohouse DS Series 480 volt Breaker

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a.

Inspection Scope (62703)

The inspectors observed the performance of low voltage closure testing and

lubrication of the 28 auxiliary feedwater pump cubicle cooler fan breaker (Work

Request 960106199-01). The inspectors also reviewed the work request package

and discussed the work in progress with the electrician performing the task and a

system engineer supervising the task.

b.

Observations and Findinas

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The inspectors observed the following:

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the operator assigned to remove the breaker from the cubicle checked the

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work package to ensure the correct cubicle location, called the control room

prior to removing the breaker, and wore appropriate safety equipment to

perform the task;

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the work package appeared to be adequate for the work performed;

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the electrician had appropriately calibrated test equipment;

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the voltage used for the closing test was in accordance with procedural

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requirements;

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the lubricants used were in accordance with the procedural requirements;

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the electrician followed the procedure closely and documented each step as

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performed;

the electrician was given clear guidance on how to apply the lubricant to the

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breaker internals by the component engineer,

c.

Conclusions

The inspectors concluded that the maintenance was performed in accordance with

the procedure and was closely supervised.

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M1.2 Surveillance Observations

a.

Inspection Scope (61726)

The inspectors observed all or portions of the following surveillance activities:

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BwVS 0.5-2.RH.2-2

Residual Heat Removal System Check Valve

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Stroke Test

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2BwOS 7.1.2.1.a.1-1

Motor Driven Auxiliary Feedwater Pump Monthly

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Surveillance

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2BwVS 0.5-3.AF.1-1

Motor Driven Auxiliary Feedwater Pump ASME

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Quarterly Surveillance

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2BwOS 3.2.1-940

ESFAS Instrumentation Slave Relay Surveillance

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2BwOS 8.1.1.2.a-1

2A Diesel Generator Operability Monthly and

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Semi Annual

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ASME Surveillance Requirements for 1 A

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Containment Spray Pump and Check Valves

1CSOO3A and 1CSO11 A."

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2BwVS 0.5-3.DO.1

Unit 2 ASME Requirements for Testing the Diesel

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Oil Transfer Systcm.

b.

Observations and Findinas

The inspectors noted that all surveillances observed were performed in accordance

with the procedure. Technicians were experienced and knowledgeable of their

assigned tasks. The inspectors observed equipment operation and verified

performance parameters were within allowable limits. The inspectors reviewed the

technical specifications and the Updated Final Safety Analysis Report for several of

these surveillances and found not discrepancies.

c.

Conclusions

The inspectors concluded that the surveillances listed above were performed in

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accordance with the procedures and all acceptance criteria were met. The

inspectors found allinstruments in calibration. Operations provided good support

and no communication problems were observed. The inspector also concluded that

the procedures were well written and provided clear guidance.

M1.3 Foreian Material Exclusion (FME)

a.

Insoection Scoce (71707)

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The inspectors reviewed a licensee identified event of a scaffold pole dropped in the

essential service water bay at the lake screen house. The inspectors reviewed

BwAP 100-21, " Foreign Material Exclusion (FME)," Revision 0.1.

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b.

Observations and Findinas

On November 7, workers were erecting scaffolding in front of the traveling screens

in the lake screen house. The structure surrounding each traveling screen

incorporates a slot about 8 feet long by about 6 inches wide inside the screens

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apron to the essential service water bay below. The workers dropped an 8 foot

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scaffold pole through the opening into the bay. The inspectors verified that there

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were no strainers or screens to prevent the introduction of FME into the essential

service water system pump suction.

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As an initial corrective action, the licensee installed temporary FME covers on the

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traveling screens near the scaffolding. On November 7 the inspectors verified that

FME covers were installed on the traveling screen openings. The inspectors noted

that BwAP 100-21 did not specifically require FME protection during the erection of

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scaffolding.

The inspectors reviewed the design of the essential service water bay and

associated piping and found that due to physiced constraints, an 8 foot pole would

not be able to damage essential service water components or restrict flow.

c.

Conclusions

The inspectors concluded that the opening in the traveling screen housing could

allow the admission of foreign materialinto the suction of the essential service

water system.10 CFR Part 50, Appendix B, Criterion V, requires that activities

affecting quality shal! be prescribed by documented procedures of a type

appropriate to the circumstances. The inspectors concluded that BwAP 100-21,

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" Foreign Material Exclusion," was inadequent in that it did not require a review of

the surrounding area for the potential to introduce foreign materialinto a safety

system during performed work. (50-456/96019-02(DRP)).

M4

Maintenance Staff Knowledge and Performance

M4.1 Installation of Steam Generator (SG) Manways

a.

Inspection Scope (62703)

On November 18,1996, The inspectors observed installation of Unit 1 Steam

Generator (SG) primary manway covers and diaphragm plates for the "C" SG and

reviewed BwMP 3300-038, " Removal and hstallation of the Primary Manway Cover

on the Steam Generators," Revision 7.

b.

Observations and Findinas

Due to radiation protection considerations, the inspectors observed the maintenance

work on a remote video display. A maintenance worker also observed the work on

video display and followed the work progress with a field copy of BwMP 3300-038.

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The maintenance worker was dedicated to ensuring that the procedure steps were

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followed. The inspector was informed by the maintenance worker that quality

control (OC) coverage was continuous and that the QC inspector was at the work

site. The manways, hardware, and special tools were in good condition and

installation went smoothly. The procedure required installation of 2 guide pins

followed by the manway and bolts. The inspectors observed that the craftsmen

failed to perform Step F.7.d.4(f) of BwMP 3300-038, which required lubrication of

the female threads after removal of the 2 guide pins and prior to installation of ths

last 2 manway bolts. Neither the maintenance worker dedicated to ensuring

procedural compliance nor the QC inspector noted that this procedural step was

missed.

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After the inspector informed the licensee of the missed step, a PIF was written.

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The licensee consulted Westinghouse and it was concluded that since, per the

original procedure: (1) the bolts were lubricated prior to installation, and (2) after

torquing to final torque, the bolts were removed one-by-one, lubricated and

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reinstalled. The procedure was changed to reflect that the female threads did not

need to be additionally lubricated.

c.

Conclusions

The inspectors cono uded that specific management actions to ensure procedural

compliance were ineffective in that an individual assigned to follow procedure steps

in the work package took no action when the procedure was no complied with.

TS 6.8.1.a required that written procedures be established, implemented, and

maintained covering activities recommended in Regulatory Guide 1.33, Revision 2,

Appendix A. TG 6.8.1.a applies to BwMP 3300-038 and therefore, the failure to

follow BwMP 3300-038 was a violation of TS 6.8.1.a (50-456/96019-03(DRP)).

The inspectors concluded that the licensee's immediete corrective action to remove

the procedure step was adequate.

M4.2 1B Diesel Generator Voltaae Reautator Terminal Board Lead Reversal

a.

Insoection Scoce (92902)

On October 14,1996, a licensee's investigation found two leads reversed on the 1B

diesel generator instantaneous prepositioning board (IPP). In response to the event,

the inspector reviewed the 1B diesel generator operability determination, the

licensee's event investigation (NTS Item #456-201-96-2254), corrective actions,

work packages 960095577 01 and 960057260 01, and pages 16 through 18 of

the Alternate Replacement Evaluation (ME-P7), Number M-94-0597-01.

b.

Observations and Findinas

The inspectors concurred with the licensee's determination of operability of the 18

diesel generator. Reversing the polarity of the 125 VDC to the IPP board

continuously input the 4160 VAC reference signal into the voltage regulator.

Normally, the 4160 VAC reference signal was applied only during isochronous mode

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operation. Since the diesel generators operated in the isochronous mode during

emergency operation, the voltage regulator circuitry would have responded exactly

as designed in the event of an emergency actuation.

The inspectors also concurred with the licensee's event investigation report that

identified two direct causes for the error. first, insufficient information was

provided in the work package. The inspectors found that the work package made

reference to evaluation M-94-0597-01 but the evaluation was not contained in the

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work package. This document contained imoortant information required to perform

the terminations. The inspectors also verified that the work package included

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design drawings that referenced terminations for the original IPP board and not the

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new IPP board. The work analyst issued the work package without complete

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instructions,

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Second, the electrician that performed the work in the field lacked a questioning

attitude. The configuration was different between the new and old boards with

respect to the termination points and required the electrician to make interpretations

as to the correct point of termination. The electrician failed to question the need for

a field interpretations and relied on hand written notes found on one of the

drawings. The inspectors verified that these notes were incorrect.

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The inspectors noted that the following corrective actions have been taken or

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identified:

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correction of the wiring error on the 18 diesel generator

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check IPP board installation on 2A diesel generator

review outstanding work request for the IPP board replacement

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on the 1 A and 2B diesel generators

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discuss the event with electrical maintenance personnel

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discuss the event with electrical maintenance work analysts

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revise drawing 20E-1-4021 A

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c.

Conclusions

The inspectors agreed with the licensee's conclusions that the 1B diesel generator

was operable with the incorrect termination of leads on the IPP board of the voltage

regulator circuit and would have been capable of performing its design function.

The inspectors also agreed with the licensee's conclusion that neither the work

analyst nor the electrician used a questioning attitude in the completion of the work

package. The inspectors concluded that the licensee performed a good root cause

analysis of the event.

The inspectors concluded that adequate documented instructions and drawings

were not available to accomplish the installation of the IPP board for the 1B DG.

This is a violation of 10 CFR Part 50, Appendix B, Criterion V requirements. The

training and counseling sessions and the document revision commitments made by

the licensee were adequate corrective action. This licensee-identified and corrected

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violation is being treated as a Non-Cited Violation consistent with Section Vll.B1 of

the NRC Enforcement Policy (50-456/96019-04(DRP)).

111. Enaineerina

E2

Engineering Support of Facilities and Equipment

E2.1

10 CFR 50.59 Evaluation For Unit 1 Cold Leo Reactor Coolant Stoo Valve

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a.

Inspection Scope (37551)

Repeated alarms occurred from the Unit 1 loose parts monitoring system on August

27,1996. The unit shut down to hot zero power on September 6,1996, to repair

two steam leaks in the containtnent and to try to identify the source of the loose

parts monitor alarms. The licensee identified at that time the source of the noise

was most likely the Unit 1 cold leg reactor coolant stop valve (1RC80b2% Unit 1

was restarted on September 9,1996. Unit 1 was again shutdown on October 12,

1996, for a mid-cycle outage to inspect steam generator tubes. During this outage

the licensee radiographed 1RC8002C and determined that one of the valve disc

guides had come loose and moved within the valve body. The inspectors reviewed

Safety Evaluation Check Lists (SECL)96-165 and SECL 96-165, Revision 1,

regarding the potential for a loose part in the Unit 1 reactor coolant system.

b.

Observations and Findinas

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The inspectors observed that SECL 96-165 discussed the possibility of a broken

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valve disc guide and stated that an inadvertent valve closure was not expected

because it would require the failure and dislodging of both valve disc guides. SECL

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96-165, Revision 1, was written after the radiograph had shown that only one guide

had come loose and moved into the valve body. SECL 96-165, Revision 1, stated

that the failure of both disc guides was not a consideration because the radiograph

showed only one guide to be failed. However, the inspectors verified that the

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licensee W not know what the failure mechanism of the valve disc guide was or

why a modification that had been installed to prevent the guide from moving into

the valve had also failed.

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The inspectors were concerned that since the failure mechanisms of the valve disc

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guide were not known how the licensee could be assured that the valve disc guides

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would not failin a way that could result in the valve disc falling into the flow path

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and result in a loss of coolant flow in the loop. SECL 96-165, Revit, ions O and 1

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had not answered the questions required by 10 CFR 50.59 from the point of view

of returning the unit to service with 1RC8002C degraded.

Based on the inspectors concerns the licensee generated a 10 CFR 50.59 safety

evaluation based on returning Unit 1 to service with 1RC8002C degraded. The 10 CFR 50.59 review specifically stated that in order to break the disc guide the valve

would have to be shut. The broken valve guide was applying a force to the disc to

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hold the other valve guide in place should it become loose. As long as the valve

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guide remained in place the valve disc would not fallinto the flow path. The

inspectors reviewed the safety evaluation and had no further concerns,

c.

Conclusions

The inspectors concluded that not documenting a 10 CFR 50.59 safety evaluation

for returning the unit to service with 1RC8002C degraded demonstrated a lack of

understanding of the 10 CFR 50.59 requirements. This was not a violation because

the 10 CFR 50.59 safety evaluation was completed prior to returning the valve to

service.

E2.2 Emeroency Safetv Feature (ESF) Switchaear Room Ventilation Fan MCC Relav

Confiauration Error

a.

Inspection Scope (92903)

On October 3,1996, operating department personnel observed cooler than normal

temperatures in the Unit 1 ESF Switchgear Room. The licensee determined

contacts on control relay CR1 had been installed incorrectly during a modification to

the ESF switchgear room ventilation system. This resulted in the ventilation

dampers not positioning properly as the room temperature decreased. The

inspectors reviewed the licensee's Problem Investigation Report #456-201-96-

2207, drawings 1-4683D and 1-4659M, Field Change Request (FCR) #960052,

NEP-04-05, Revision 0," Design Change Acceptance Testing Criteria," and BwAP

1610-5, Revision 3, " Development of Modification Test." The inspectors conducted

interviews with the Electrical Maintenance Master Electrician, Electrical Maintenance

Staff Supervisor, root cause team personnel, and with site engineering personnel.

b.

Observations and Findinas

The inspectors agreed with the licensee that the exact conditions that resulted in

contact reversal could not be determined. The inspectors also agreed with the

licensee's conclusion that inadequate post modification testing failed to identify the

incorrectly installed contact. The inspectors noted that this was the eighth

identified example of inadequate post modification testing in the last 2 years.

The inspectors reviewed the licensee's planned corrective actions of tailgating the

maintenance workers, work analysts, site construction workers, and site and

system engineers about this event.

c.

Conclusions

The licensee identified the inadequate post-modification testing. However, the

inspectors were unable to come to a conclusion concerning the appropriateness of

the licensee's corrective actions considering the number of related events in the last

2 years. The inspectors planned to review previous events and modifications

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recently completed or in progress to continue assessment of modification process

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for programmatic problems. The adequacy of the licensee's corrective actions was

an unresolved item (50-456/96019-05(DRP)).

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E2.3 Control Room Ventilation Damoer Hydromotor Had Disconnected Power Leads

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a.

Inspection Scope (37551)

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On November 11, licensee personnel observed that OVC075 and OVC073, the

hydromotors for control room ventilation dampers OVC140Y and OVC104Y

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respectively, had the power leads disconnected. The inspectors reviewed PIF #456-

201-96-2620 and interviewed site and system engineering personnel.

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b.

Observations and Findinos

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During discussions with the inspectors, the system engineer stated that he had

noticed that Control and instrumentation Drawing M-2096 showed that power was

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removed from OVC075 and OVC073 and that the schematic and external wiring

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diagrams still showed power supplied to the two hydromotors. The system

engineer also stated that a Byron Field Change Request (FCR-F-34067), generated in

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1984 during Byron station construction, removed the power to the damper

hydromotor and changed M-2096. M-2096 was a Byron /Braidwood common

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drawing. The dampers controlled by the hydromotors control air flow to the main

control room.

Licensee personnel stated that no documentation could be found that approved the

same change to the construction of Braidwood Station. Licensee personnel

generated engineering request 9602195 to evaluate the lack of power to the

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hydromotor. The licensee's evaluation was that power to OVC075 and OVC073

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was unnecessary and Engineering Change Notices 000950E and 000951E were

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issued to document the changes to the power supplies to the hydromotors and

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update the appropriate drawings.

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The inspectors reviewed UFSAR Sections 9.4.1,6.5.1, and 6.4.4 and concluded

that the system design as described in the UFSAR was unaffected. Section 9.4.1

stated that all automatic isolation and control dampers were driven by spring loaded

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electric powered operators which fail safe on the loss of electric power. The

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inspectors determined that the dampers were left in a fail safe condition.

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c.

Conclusions

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The inspectors concluded that by identifying the problem the performance of the

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system engineer was good. The inspectors determined that the licensee's

corrective actions were good. The inspectors also concluded that the failure to

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update all the appropriate drawings at the time the change was made was a

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violation of 10 CFR Part 50, Appendix B, Criterion VI. This licensee-identified and

corrected violation is being treated as a Non-Cited Violation consistent with

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Section Vll.Bl of the NRC Enforcement Policy (50-456/96019-06(DRP)).

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.E4

Engineering Staff Knowledge and Performance

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E4.1

Diesel Oil Transfer Pumo Vibration Measurements

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a.

Inspection Scope (61726)

The inspectors reviewed the procedure and observed the performance of 2BwVS

0.5-3.DO.1, " Unit 2 ASME Requirements For Testing The Diesel Oil Transfer

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System," Revision 1. The purpose of this procedure was to verify that the diesel oil

transfer pumps and discharge check valvas meet ASME Section XI operational

readiness pursuant to TS 4.0.5 (see Paragraph M1.2).

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b.

Observations and Findinas

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On November 14,1996, the inspector observed the performance of 2BwVS 0.5-

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3.DO.1, "ASME Requirements For Testing The Diesel Oil Transfer System,"

Revision 1. During the pump vibration measurements on the 2DOO1PB pump, the

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system engineer informed the inspector that the vibration measurements were

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within acceptance criteria but were greater than expected. The inspector observed

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all of the vibration measurements and noted that all the values obtained were within

the acceptable range. The system engineer informed the inspector that he

suspected the introduction of electronic noise and conducted an inspection of the

TEC-Smart Meter, cable, and vibration transducer. The system engineer noticed a

small break in the vibration transducer cable insulation near the amphenol

connector. The cable was replaced and the vibration measurements repeated. The

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repeated vibration measurements exhibited the expected levels and were within the

acceptable range.

c.

Conclusion

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The inspector concluded that the system engineer's detection of the introduced

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noise was an excellent observation since the vibration measurements initially

obtained met the acceptance criteria. The system engineer demonstrated an

excellent knowledge of expected system performance and a questioning attitude,

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IV. PLANT SUPPORT

R2

Status of RP&C Facilities and Equipment

R2.1 Inspection of the Hinh Level Spent Resin Tank Room

a.

Inspection Scope (71750)

The inspectors observed the licensee perform a visual material condition inspection

of the high level spent resin tank room. Licensee personnel had not entered or

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inspected the room in about 5 years.

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b.

Observations and Findinas

The inspectors observed the licensee perform the inspection using a video camera

inserted into the high level spent resin tank room through a floor plug in the Unit 2

lower cable spreading room. The camera provided a view of all areas of the room

except for a small area behind the tank. Licensee personnel stated the unobserved

area contained no equipment. The room was adequately illuminated and a high

quality picture of the room was obtained. The inspectors noted that this was the

first inspection of this room in the 5 years and questioned the elapsed time between

inspections. The licensee stated that there was no door to the room and that a

shield wall must be disassembled to gain access. However, the licensee indicated

that they would perform an annual video camera inspection of the room and would

enter the inspection into their surveillance data base for scheduling.

c.

Conclusions

The inspectors found the room and the equipment contained within to be in good

condition. The inspectors observed no indications of component or tank leakage.

P5

Staff Training and Qualification in Emergency Preparedness (EP)

P5.1

Ememency Preparedness Drill

a.

Inspection Scope (71750)

The inspectors observed an EP drill from the simulator and the Technical Support

Center (TSC).

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b.

Obsewations and Findinas

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On . November 20, inspectors observed the station response to an emergency

preparedness drill from the simulator and TSC and noted that it challenged the

participants. Response in the simulator was deliberate with teamwork characterized

by mutual backup, clear communications, and thorough use of procedures. Actual

problems, such as the failure of telephone equipment and real time sampling from

the high radiation sampling system added realism to the drill. Training value in the

simulator was also enhanced by simulated equipment malfunctions and out-of-

services, which greatly complicated operator action, but also by the delay of

exercise termination until the plant was in the final stage of cooldown.

c.

Conclusions

The inspectors concluded that the drill's scenario was well developed and

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challenged participants. The simulator operating crew's in-depth self-critique added

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greatly to the training value of the exercise.

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Conduct of Security and Safeguards Activities

S1.1 General Comments

a.

inspection Scope (71750)

The inspectors reviewed physical security measures and the " Security Control

Center Procedure," BSP-12, Revision 4 and observed security operations in

progress. The inspectors interviewed the security administrator, assistant security

administrator, and three security personnel on duty.

b.

Observations and Findinos

The inspectors observed operations and alarm response from the Main and

Secondary Security Control Centers (SCC). The monitoring, alarm, and

communications equipment was in satisfactory condition and security personnel

were proficient in the operation of the SCC. Administrative requirements (BSP-12)

such as shift briefing sheets and communications checks were adhered to.

Response to an interior door alarm was satisfactory. Security personnel were

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familiar with procedures for abnormal situations postulated by the inspectors.

Ths inspectors observed the expeditious removal of construction equipment from

fne lake screen house protected area and the prompt restoration of the security

barriers following equipment removal. The inspector observed that the security

statOng for the evolution was sufficient to maintain access control to the lake

screen house.

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c.

Conclusions

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Security facilities were in good condition and personnel interviewed were

knowledgeable and professional. Routine operations observed went smoothly,

V. Manaaement Meetinas

X1

Exit Meeting Summary

The inspectors presented the inspection results to members of licensee management

at the conclusion of the inspection on November 29,1996. The licensee

acknowledged the findings presented.

The inspectors asked the licensee whether any materials examined during the

inspection should be considered proprietary. No proprietary information was

identified.

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PARTIAL LIST OF PERSONS CONTACTED

Licensee

  • H. G. Stanley, Site Vice President
  • T. Tulon, Station Manager
  • H. Pontious, Nuclear Licensing Administrator

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W. McCue, Support Services Director

R. Flessner, Site Quality Verification Director

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R. Byers, Maintenance Superintendent

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D. Miller, Work Control Superintendent

  • T. Simpkin, Regulatory Assurance Supervisor

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H. Cybul, System Engineering Supervisor

  • J. Meister, Engineering Manager
  • D. Cooper, Operations Manager

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M. Turbak, independent Safety Engineering Group Supervisor

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  • M. Cassidy, Regulatory Assurance - NRC Coordinator

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NRC

R. Lanksbury, Chief, Reactor Projects Branch 3

  • C. Phillips, Senior Resident inspector
  • J. Adams, Resident inspector

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  • D. Rich, Resident inspector

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IDNS

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  • T. Esper

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  • Inoicates those attending the management meeting on November 29,1996,

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INSPECTION PROCEDURES USED

IP 37551:

Onsite Engineering

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IP 61726:

Surveillance Observations

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lP 62703:

Maintenance Observation

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IP 71707:

Plant Operations

IP 71750:

Plant Support Activities

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IP 92902:

Followup - Maintenance

IP 92903:

Followup - Engineering

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IP 92904:

Followup - Plant Support

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ITEMS OPENED AND CLOSED

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Opened

50-457/96019-01

NCV failure to follow procedures

50-456/96019-02

VIO

inadequate procedure

50-456/96019-03

VIO

failure to follow procedures

50-456/96019-04

NCV failure to provide adequate instructions

50-456/96019-05

URI

inadequate modification testing assessment

50-456/96019-06

NCV failure to update appropriate drawings

Closed

50-457/96019-01

NCV failure to follow procedures

50-456/96019-04

NCV failure to provide adequate instructions

50-456/96019-06

NCV failure to update appropriate drawing

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LIST OF ACRONYMS USED

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AR

Action Request

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CFR

Code of Federal Regulations

ESF

Engineered Safety Features

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ESFAS

Engineered Safety Features Actuation System

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FCR

Field Change Request

FME

Foreign Material Exclusion

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IDNS

lilinois Department of Nuclear Safety

IPP

instantaneous Prepositioning

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MCC

Motor Control Center

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NCV

Non-Cited Violation

NRC

Nuclear Regulatory Commission

NSO

Nuclear Station Operator

PDR

Public Document Room

PlF

Problem identification Form

QC

Quality Control

SCC

Security Control Center

SECL

Safety Evaluation Check List

1

SG

Steam Generator

]

Tave

Average Temperature

Tref

Reference Temperature

TS

Technical Specification

)

TSC

Technical Support Center

TSI

Thermal Sciences Incorporated

)

UFSAR

Updated Final Safety Analysis Report

URI

Unresolved item

US

Unit Supervisor

VAC

Volts Alternating Current

VDC

Volts Direct Current

VIO

Violation

22