IR 05000456/1985027

Insp Repts 50-456/85-27 & 50-457/85-27 on 850520-0607 & 0722-0801.No Violation or Deviation Noted.Major Areas Inspected:Eccs Sump Recirculation Testing & Significant Const Deficiency Reported Per 10CFR50.55(e)

ML20137F848
Person / Time
Site:	Braidwood
Issue date:	08/21/1985
From:	Farber M, Little W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137F821	List: IR 05000456/1985027 ML20137F814
References
50-456-85-27, 50-457-85-27, NUDOCS 8508270103
Download: ML20137F848 (8)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report Nos. 50-456/85027(DRP); 50-457/85027(DRP)

Docket Nos. 50-456; 50-457 License No. CPPR-132, CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, Illinois 60690

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Facility Name: Braidwood Station, Units ) and 2 Inspection At: Braidwood Site, Braidwood, Illinois Inspection Conducted: May 20 through June 7 and July 22 through August 1, 1985 Inspector J Far er 8/.I/ //-

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Date'

Approved By . ( tie, Director 842/ 8 5~

Braidwood Project D&te '

Inspection Summary Inspection of May 20 through June 7 and July 22 through August 1,1985 (Report Nos. 50-456/85027(DRP): 50-457/85027(DRP))

Areas Inspected: Routine announced inspection of Emergency Core Cooling System (ECCS) Sump Recirculation Testing and significant construction deficiency reporting in accordance with 10 CFR 50.55(e). This inspection involved 95 inspector-hours onsite and 40 inspector-hours in office by one NRC inspector, including 14 inspector-hours onsite during offshift Results: No violations or deviations were identifie .

f 8508270103 850821 PDR ADOCK 05000456 G PDR

DETAILS

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1. Persons Contacted

• J. Wallace, Project Manager

• C. W. Schroeder, Licensing and Compliance Superintendent L. M. Kline, Licensing and Compliance Engineer

• C. J. Tomashek, Project Startup Superintendent D. L. Shamblin, Project Construction Superintendent

• H. A. Zimmerman, Project Startup Testing Supervisor

• L. O. DelGeorge, Vice President, Licensing

• T. M. Maiman, Manager of Projects .

T. E. Quaka, Site Quality Assurance Superintendent

• L. J. Tappe11a, Project Construction Engineering

• J. W. Giesecker, Project Construction Engineering

• Denotes those personnel present at the exit intervie Additional licensee technical and administrative personnel were contacted by the inspector during the course of the inspectio . Action on Previous Inspection Findings (Closed) Open Item (50-456/85011-01(DRP): Verification of vortex control during the performance of BWPT-EF-11. This item has been upgraded to an Unresolved Item and is discussed fully in Paragraph ~ (Closed) Unresolved Items (50-456/85022-01(DRP) & 50-457-021-01(DRP)):

Review of 10 CFR 50.55(e) Construction Deficiency Evaluations to determine if the value $100,000 had resulted in failure 'to report a significant construction deficiency. This item is discussed in Paragraph . Emergency Core Cooling System Sump Recirculation Testing As follow-up to an open item (50-456/85011-01(DRP)) originated by the Senior Resident Inspector (Operations) the inspector conducted a detailed review of available documentation on the subject of ECCS sump testing, reviewed a video tape of the as-conducted test, contacted members of the NRR staff cognizant of sump testing, and met with members of the licensee staff involved with the test. The inspector reviewad the following documents:

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BWPT-EF-11 "ECCS Full-Flow Test"

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Regulatory Guide 1.79, Rev. 1, September 1975, "Preoperational

, Testing of Emergency Core Cooling Systems"

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Regulatory Guide 1.82, Rev. O, June 1974, " Sumps for Emergency Core Cooling and Containment Spray Systems"

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Regulatory Guide 1.82, Draft Revision 1, May 1983, " Sumps for Emergency Core Cooling and Containment Spray Systems"

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NUREG/CR-2761, "Results of Vortex Suppressor Tests, Single Outlet Sump Tests, and Miscellaneous Sensitivity Tests"

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NUREG/CR-2758, "A Parametric Study of Containment Emergency Sump Performance" Regulatory Guide 1.79 states that "A comprehensive preoperational test program on the Emergency Core Cooling System (ECCS) and its components should be performed to provide assurance that the ECCS will accomplish its intended function when required." Specifically, "the (preoperational) testing should include taking suction from the sump to verify vortex control ..."

There are two classes of vortices which occur at pump intakes, internal l vortices and air entraining vortices. Internal vortices form from solid

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boundaries such as sump floor or sidewalls and inevitably result in increased intake losses. Air entraining vortices form from a free surface and cause the same degrading effects as internal vortices. In addition, air entraining vortices cause air to be ingested into the pump which could result in decreased flo The licensee developed BWPT-EF-11, "ECCS Full Flow" to satisfy this requirement. The temporary piping and valves required for this test flow path are identified on Plan & Section Drawing M-195, " Recirculating Sump and Test Piping."

The inspector viewed a portion of a video tape which showed conditions in the sump during the conduct of the test as it was originally developed and approved. The inspector noted that the test method and configuration resulted in a phenomenon known as break flow jet impingement which resulted in high turbulence in the sump. In the Final Safety Analysis Report the licensee indicated that the expected approach velocity of flow

~to the sump was approximatley 0.5 feet per second, a value, which while

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greater than that recommended by Regulatory Guide 1.82, is low enough to avoid turbulence in the sump. This turbulence prevented the verification of vortex control as required by Regulatory Guide 1.7 . Control of internal vortices could not be verified due to the turbulence present in the sump. The froth and agitation prevented a clear view of the solid boundaries of the sump where internal vortices could for . The formation of an air entraining vortex occurs from a free surface. The turbulence in the sump created by the impinging break flow jet prevented the formation of a free surfac Conditions in the sump were such that any air entraining vortex which might have formed as a result of sump flow and geometry was effectiv'ely mitigated. Preventing the formation of a vortex in the sump during the test does not constitute a verification of vortex contro w

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The inspector viewed another portion of a video tape which showed conditions in the sump during a test run in which the method was modified to eliminate break. flow jet impingemen . The. inspector noted.some evidence of type 1 (incoherent surface swirl) and type 2 (surface dimple) vortex formatio . Visibility of the solid boundaries of the sump was not adequate to verify control of internal vortice ; -

Since vortex control was not demonstrated as required in Regulatory Guide 1.79, the ability of the ECCS to accomplish its intended function when required is indeterminate when judged against those criteria. Studies conducted by NRC and representatives of the industry have indicated that vortex formation is not a reliable indicator of sump performanc Performance parameters ... void fraction, swirl, and pressure' loss coefficent ... are not well correlated with observed vortex formation These studies resulted in the issuance of a proposed revision to Regulatory Guide 1.82 which provides methods for evaluation of sump

' performance based on sump geometry. The inspector provided references for these studies and the proposed Regulatory Guide 1.82 to the licensee staff for their use in evaluating the acceptability of the completed sump

' recirculation testin Since the test did not meet the requirements of

,; Regulato'ry Guide 1.79, verification of the ability of the ECCS sump to perform its intended function is an Unresolved Item (50-456/85027-01(DRP)

pending licensee evaluation of the EF-11 test result . Significant Construction Deficiency Reporting (10 CFR 50.55(e))

As follow-up to the unresolved items identified in inspection reports 50-456/85022 and 50-457/85023 an in-depth inspection of the licensee's procedures and practices for reporting of Significant Construction

' Deficiencies was conducted. This' inspection involved review of proce-

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dures for deficiency reporting /and 10 CFR 50.55(e) evaluations, reviews of Startup Deficiency Reports and Nonconformance Reports (NCR), and interviews with engineers who were responsible for the 10 CFR 50.55(e)

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evaluation of selected NCR The inspector reviewed the following procedures, related to deficiency reporting and 10 CFR 50.55(e) evaluations, from Commonwealth Edison

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I Company (CECO),' Gust K. Newberg (GKN), Phillips Getschow (PGCo), and K. Comstock (LKC).

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! 'CommonwealthEdisonCE.' QP 15-1, Rev. 7 Reporting Quality

Quality Assurance Manual,s~ Nonconformances

Quality Procedure During Construction

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and Test

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! , u QP 15-2, Rev. 3 Reporting Signifi-

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cant Deficiencies

that Occur During '

Construction and l Test

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Commonwealth Edison C SQI-03, Rev. 8 Processing of CECO Braidwood Station On-site NCRs Quality Assurance Braidwood Nuclear Station PM-04, Rev. 0 10 CFR 50.55(e)

. Project Procedure Determination and Reporting PCD-23, Rev. 1 Site Contractor Nonconformance Reports / Procedure Processing PCD-28, Rev. 1 Generic BCAP Nonconformance Reports SNED/PE Procedure Q.40 10 CFR Part 21 -

Reports to the NRC Concerning Defects and Noncompliances SNED Procedure Q.21 Incidents and Deficiencies Gust K. Newberg Section 52, Rev. 3 Nonconformance Re-

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ports L. K. Comstock 4.11.1, Rev. F Nonconforming Items QA Section 4.11.2, Rev. C Corrective Action 4.11.3, Rev. A Stop Work Philips, Getschow QAP 12.1, Rev. 5 Internal Audits Quality Assurance Procedures QAP 12.2, Rev. O Correction Action Requests i QAP 12.3, Rev. 0 Document Deficiency Report Procedure Philips, Getschow PGCP 1.1, Rev. 9 Control of Engineer-l Construction Procedure ing Change Notices (ECN), Field Change Notice (FCN), Field Change Requests i (FCR), and Field Problem Reports

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(FPR)

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Philips, Getschow QAP-12, Rev. 6 Control of Noncon-Advanced Revision formance Reports Supplement Quality Assurance Procedure With respect to Project Procedure PM-04, Rev. O, the inspector had the following concerns: The definition of a deficiency (section 3.1.1) is incomplete in that it limits applicability of reporting to safety-related items. This ignores non-safety items where a deficiency could contribute to the degredation of a safety system through interaction between the system ' CFR 50.55(e) contains a test for significance as follows:

"A significant breakdown in any portion of the quality assurance p ogram conducted in accordance with the requirements of Appendix B; Exhibit B of PM-04, " Construction Geficiency Evaluation" (CDE),

Section 2B substitutes the phrase 5100,000 in resources" for the term "significant". This is contrary to Appendix I, page 1 of 3, which states that significance primarily pertains to operational safety and not to the cost of the corrective actio . 10 CFR 50.55(e.iii) and (e.iv) both require consideration of the nature of evaluations, redesign, or repairs necessary to correct the deficiency in evaluating significance. The CDE does not contain any provision for the consideration of evaluations conducted to resolve the item The inspector presented these concerns to the licensee who indicated that they would be addressed but that corrective action would take some time since the same check list was empicyed at other sites and that changes would be evaluated at the corporate level. The concerns expressed by the inspector regarding PM-04 are an open item (456/85027-02(DRP) &

(457/85027-01(DRP)) pending licensee corrective actio ~

The inspector reviewed a computer print-out of Startup Deficiency Reports and selected approximately sixty reports for further review. Out of these reports three concerned failure of the diesel generator to start in the required period of time due to apparent loss of fuel system prim Discussions with preoperational test inspectors, the Senior Resident Inspector, and the licensee startup staff revealed that this problem had first emerged in January of this year but had been attributed to main-tenance on the fuel system. When the problem occurred on the other i diesel, maintenance was conducted on a fuel system check valve in an

! attempt to correct the situation. After these repairs both diesels i

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started successfully and then subsequently the "B" diesel agai'n failed to start properly. On May 17, 1985 deficiency reports were written for each

' diesel and special test apparatus installed to continue evaluation of the i

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problem. The licensee reported this condition as a potentially reportable deficiency on July 23, 1985. The inspector, after reviewing the events, considered that this deficiency should have been reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by phone and that a report should have been submitted by July 1,1985 (June 16 plus two weeks allowance for recongnizing the significance) at the latest. Tnis conclusion was based on recognized safety impact coupled with the amount of evaluation and effort which had already been expende Meetings with licensee staff revealed that the only consideration given up until July 23 was for extensiveness of rework or redesign. Since there is some question as to whether or not the amount of " evaluation" already conducted is extensive and the amount of rework or redesign required to correct the problem has not been defined, the inspector considers the reportability of the diesel generator problem to be an unresolved item (456/85027-03(DRP) and (457/85027-02(DRP)) pending definition of the amount of rework or redesign and the amount of further evaluation required to correct the proble The inspector reviewed computer listings of NCRs from Ceco, PGCo, GKN, and LKC for the period January 1, 1982 to May 18, 1985. After considera-tion of the requirements of PCD-23, the inspector reduced the scope of his review to Commonwealth Edison NCRs thus narrowing the sample from several thousand NCRs to approximately four hundred. The inspector selected approximately sixty of these NCRs for futher review. Of these sixty, approximately half of them appeared to have substantial elements of reportability. The inspector studied these NCRs and then interviewed the project engineer responsible for the 10 CFR 50.55(e) evaluation. In most cases the engineer was able to present additional information necessary to resolve the inspectors concerns. It must be noted that in the inspectors judgement as an engineer some of these items were in fact reportable however he chose to abide by the evaluator's assessment. The evaluating engineer was not able to resolve the inspectors's concern regarding NCR 614, which documented the failure of project construction personnel to obtain engineering concurrence for the waiver of internal cleanliness inspections during the retrofit program. Further discussions with licensee staff indicated that the licensee considered this to be a side issue emergent from the Civil Penalty action of report 456/82005 and 457/82005 and thus was not reportable. The inspector reviewed the Civil Penalty package and associated documentation and noted that the retrofit program was part of the corrective action for the violation. What was identified as a failure to obtain concurrence for a waiver appeared to also identify a failure of the corrective action program. The inspector presented this concern to the licensee who restated their position that this was emergent from the Civil Penalty and that additional information was available to support this position. The inspector considers the reportability of NCR 614 to be an unresolved item (456/85027-04(DRP) and (457/85027-03(DRP)) pending the inspector's evaluation of the additional information to be provided by the license . Open Items ,

Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC, tne licensee, or both. An open item disclosed during the inspection is discussed in paragraph _

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6. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether or not they are acceptable items, violations, or deviations. Unresolved items disclosed during the inspection are discussed in paragraphs 3 and . Exit Interview The inspector met with licensee representatives denoted in paragraph 1 at the conclusion of the inspection on August 1, 1985. The inspector summarized the scope and results of the inspection and discussed the likely informational content of this report. The licensee did not indicate that any of the information disclosed during the inspection could be considered proprietary in nature.

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