ML20148B789
| ML20148B789 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 03/17/1988 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20148B778 | List: |
| References | |
| 50-456-88-01, 50-456-88-1, 50-457-88-01, 50-457-88-1, NUDOCS 8803220135 | |
| Download: ML20148B789 (33) | |
See also: IR 05000456/1988001
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SALP BOARD REPORT
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~U.S. NUCLEAR REGULATORY COMMISSION
REGION III
S'-STEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
50-456/88001; 50-457/88001
Inspection Report No.
Commonwealth Edison Company ,
Name of Licensee
Braidwood Station
Name of Facility
December 1, 1986 through December 31, 1987
Assessment Period
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PDR ADOCK 05000456
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-8 - TABLE OF CONTENTS
Page No.
I. INTRODUCTION. . . . . . . .................. 1
II. CRITERIA. . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
I I I . . S U MMARY O F R E S U LT S . . . . . . . . . . . . . . . . . . . . . . . 4
IV. PERFORMANCE ANALYSIS. . . . . . . . . . . . . . . . . . . . . . 5
A. Plant Operations . . . . . . . . . . . . . . . . . . . . .- 5
B. Radiological Controls. . . . . . . . . . . . . . . . . . . 7
C. Maintenance. . . . . . . . . . . . . . . . . . . . . . . . 8
D. Surveillance . . . . . . . . . . . . . . . . . . . . . . . 10
E. Fire Protection. . . . . ................. 11
F. Emergency Preparedness . . . . . . . . . . . . . . . . . . 12
G. Security . . . . . . ................... 14
H. Oucages. . . . . . . . . . . . . . . . . . . . . . . . . . 15
I. Quality Programs and Administrative Controls
Affecting Quality . .................. 15 ,
J. Licensing Activities . . . . . . . . . . . . . . . . . . . 17
K. Training and Qualification Effectiveness . . . . . . . . . 19 .
L. Preoperational and Startup Testing . . . . . . . . . . . . 21 .
M. Construction . . . . . . . . . . . . . . . . . . . . . . . 22
N. Engineering / Technical Support .............. 23
V. SUPPORTING DATA AND SUMMARIES . . . . . . . . . . . . . . . . . 25
A. Licensee Activities. . . . . . . . . . . . . . . . . . . . 25
B. Inspection Activities. . . . . . . . . . . . . . . . . . 26
C. Investigations and Allegations Review. . . . . . . . . . . 28
D. Escalated Enforcement Actions. . . . . . . . . . . . . . . 29
E. Licensee Conferences Held Durirg Assessment Period . . . . 29
F. Confirmatory Action Letters (CALs) . . . . . . . . . . . . 30
G. Review of Licensee Event Reports, Construction Deficiency
Reports, and 10 CFR Part 21 Reports Submitted by the
Licensee . . . . . . . . . . . . . . . . . . . . . . . . 30
H. Licensing Actions. . . . ................. 31
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i I. INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect available observations and data
on a periodic basis and to evaluate licensee performance based upon this
information. The SALP program is supplemental to normal regulatory
processes used to ensure compliance with NRC rules and regulations. SALP
is intended to be sufficiently diagnostic to provide a rational basis for
allocating NRC resources and to provide meaningful guidance to the
licensee's management to promote quality and safety of plant construction
and operation.
An NRC SALP Board, composed of the staff members listed below, met on
on March 2, 1988, to review the collection of performance observations
and data to assess licensee performance in accordance with the guidance
l in NRC Manual Chapter 0516, "Systematic Assessment of Licensee
Performance." A summary of the guidance and evaluation criteria is
provided in Section 11 of this report.
, This report is the SALP Board's assessment of the licensee's safety
performance at the Braidwood Station for the period December 1, 1986
through December 31, 1987.
SALP Board for Braidwood Stc tion SALP 7 assessment:
Name Title
C. E. Norelius SALP Board Chairman, Director, Division of
Radiation Safety and Safeguards
E. G. Greenman Director, Division of Reactor Projects
H. J. Miller Director, Division of Reactor Safety
D. Muller Project Director, NRR
W. L. Forney Chief, Reactor Projects, Branch 1
S. Sands Braidwood Project Manager, NRR
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T. Tongue Senior Resident Inspector
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. II ' CRITERIA
The licensee performance is assessed in selected functional areas,
depending on whether the facility is in a construction, preoperational,
or operating phase. Each functional area represents an area significant
to nuclear safety and the environment and corresponds to a normal
programmatic area. Some functional areas may not be assessed because
of little or no licensee activities or lack of meaningful observations
in that area. Special areas may be added to highlight significant
observations.
The following evaluation criteria were used in assessing each functional
area:
A. Management involvement in ensuring quality.
B. Approach to resolution of technical issues from a safety standpoint.
C. Responsiveness to NRC initiatives.
D. Enforcement history.
E. Operational and construction events (including response to, analysis
of, and corrective actions for).
F. Staffing (including management).
However, the SALP Board is not limited to these criteria, and others may
have been used where appropriate.
Based upon the SALP Board assessment, each functional area evaluated is
classified into one of three performance categories. The definitions of
these performance categories are:
Catecory 1: Reduced NRC attention may be appropriate. Licensee
i management attention and involvement are aggressive and oriented toward
l nuclear safety; licensee resources are ample and effectively used so that
j a high level of performance with respect to operational safety and/or
construction quality is being achieved.
Category 2: NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are
concerned with nuclear safety; licensee resources are adequate and are
reasonably effective so that satisfactory performance with respect to
operational safety and/or construction quality is being achieved.
- Cateoory 3
- Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers
nuclear safety, but weaknesses are evident; licensee resources appear to
be strained or not effectively used, so that minimally satisfactory
performance with respect to operational safety or construction is being
achieved.
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_, Trend: The SALP Board may choose to include an assessment of the
performance trend of-a functional area. Normally, this performance
trend is only used where both a definite trend of performance is
discernible to the Board and the Board believes that continuation of
the trend may. result in a change of performance level.
The trend, if used, is defined as:
A. Improving
Licensee performance was determined to be improving near the close
of the assessment period.
B. Declinfng
Licensee _ performance was determined to be declining near the close
of the assessment period.
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III. SUMMARY OF RESULTS
The regulatory performance of Braidwood Station is acceptable. The ratings in 1
two functional areas improved, whilc two others declined. The differences in
facility activities assessed as "Operational Readiness and Initial Fuel
Loading" in SALP 6 and as "Plant Operations" in SALP 7 preclude a consistent
comparison.
Rating Last Rating This
Functional Area' Period (SALP 6) PeriodlSALP7)
A. Plant Operations 1* 2
B. Radiological Controls 2 2
-C. Maintenance *NR 2
.D. Surveillance NR 2
E. Fire Protection 2 2
F. Emergency Preparedness 2 1
G. Security 2 2
H. Outages *NR *NR
I. Quality Programs and 1 2
Administrative Controls
Affecting Quality
J. Licensing Activities 2 2
K. Training and Qualification 2 1
Effectiveness
L. Preoperational and Startup 1** 2
Testing
M. Construction 2 2
N. Engineering / Technical Support NR 2
- Actual area for this rating was "Operational Readiness and Initial Fuel
Loading."
- Actual area for this rating was "Preoperational Testing."
- NR = Not Rated
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IV. PERFORMANCE ANALYSIS
A. Plant Operations
1. Analysis
This functional area was evaluated on the basis of the results
of routine inspections conducted by resident and region-based
inspectors.
During this assessment period, Unit 1 achieved initial
criticality, and startup tests and the initial power ascension
to 100% power were completed. The initial fuel load for Unit 2
was completed just prior to the end of the assessment period.
The enforcement history was typical for a facility at this
stage of its operating life. Enforcement in this area
included three Severity Level IV violations and one Severity
Level V violation, as well as another Severity Level IV
violation which was partially attributable to this functional
area. Three of the violations initially warranted consideration
for escalated enforcement: (1) failure to identify an open
out-of-service main steam isolation valve (MSIV) after it had
opened during maintenance when its gagging device failed; (2)
violating emergency core cooling system operability requirements
by closing a residual heat removal system cross-connect valve;
and (3) allowing an unauthorized individual to manipulate the
controls of the Unit I reactor. While the safety significance
of each violation was not sufficient to warrant escalated
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enforcement, the overall effect of these violations and their
safety significance has raised concerns with regard to
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management control of operational activities.
With regard to operational events, although the number of Unit 1
, reactor trips and engineered safety feature (ESF) actuations
I indicates above average performance for a p' ant at this stage of
operating life, the licensee should strive to decrease protection
system actuations. Eighteen reactor trips (3 at greater than
, 15% power) and 26 ESF actuations occurred during this assessment
! period. Seven of the reactor scrams and 8 of the ESF actuations
were the result of personnel errors.
A total of 71 licensee event reports (LERs) were issued for
Unit 1 during this SALP period. Of those 71, 37 (52%) were
caused by personnel error. Also, 32 LERs were issued in the
operations area, of which 15 (47%) were caused by personnel
! error. Although there were no previous LER totals for
comparison, the numbers of events and personnel errors indicate
a need for station improvement.
l The number of operational events represents a weakness in
l management involvement to ensure quality. Many of the personnel
l errors were either failures to execute required actions or
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simply inadvertent mistakes. These types of events have
dem n strated that management efforts to promote attention to
detail and alertness to the consequences of activities were not
always effective.
Throughout the period, management involvement to ensure quality
was evident in plant staffing. Additional personnel were
assigned to the major activities during the Unit 1 startup and
power ascension at the management and worker levels. Senior
management personnel were placed on shift to monitor activities,
and additional personnel were utilized at the equipment attendant
level from another utility. Vacancies were filled promptly with
qualified personnel.
Responses to NRC initiatives were technically sound, with
acceptable timely resolutions in almost all cases. The NRC
expressed concern about the station's ability to manage
concurrent activities with Unit 1 in startup and power
ascension while Unit 2 was undergoing preoperational testing,
integrated hot functional testing, containment structural and
leak testing, and initial fuel loading. The licensee was
sensitive to this matter and these coordinated activities were
nianaged well, serious problems were not encountered, and
conflicts in scheduling were prevented.
The approach to safety issues ahaost always showed evidence of
careful planning. Shift briefings for major activities and
tests were thorough and extensively involved experienced
personnel. In addition, the professionalism of control room
operators was evident.
With regard to housekeeping, the licensee has continued the
successful "Model Spaces" program at Braidwood. This program
has not only improved the appearance of the plant, but has
made leaks easier to identify, made decontamination more
efficient, facilitated preservation of equipment, and had a
notable effect on the station personnel's pride in the plant.
It should be noted that throughout the SALP 7 period, the
licensee conducted activities in a startup and/or test mode
of operation. These activities were handled well with the
involvement of additional management and operating personnel
in their first challenge as a cohesive team. This stage of
operational history involved a level of activity demanding
extra attention on the part of both management and the working
force.
2. Conclusion
The licensee's performance is rated Category 2 in this area.
The licensee was rated Category 1 in the corresponding functional
area, Operational Readiness and Initial Fuel Loading, in the
previous assessment period. A comparison of performance during
the SALP 6 and SALP 7 periods is inappropriate, due to the
major differences in facility activities assessed during those
periods.
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' 3. Board Recommendations
None.
B. Radiological Controls
1. Analysis
This functional area was evaluated on the basis of routine
inspections conducted by resident and region-based inspectors.
The enforcement history did not indicate any significant
regulatory concerns in this area. One Severity Level IV
violation was partially attributable to the Radiation Chemistry
Department during this assessment. No violations were identified
during the previous assessment period. ,
Staffing was generally adequate during the period; only minimal
staff turnover occurred. The ALARA group was strengthened by
the addition of several personnel, more than doubling the
group's previous staffing. Due to the demands of the Unit I
startup and to the inexperience of the permanent staff, the
radiation protection staff was augmented by approximately 26
contractor radiation protection personnel. Also, several
additional permanent staff positions were recently authorized.
Even with the staff augmentation, a significant number of
members of the permanent staff has worked extensive overtime
hours. The chemistry group was extensively reorganized during
this assessment period; a new Station Chemist was appointed, and
other chemists were added to the staff. Overall, the Rad / Chem
group experience and expertise appear improved.
Licensee responsiveness to NRC tr.itiatives was generally good
during the assessment period. A positive locking procedure
requiring dual key issuance by the Plant Manager and the
Rad / Chem Supervisor for entry into the reactor cavity incore
area was implemented in response to NRC Information Notice
86-107. NRC concerns about the completion of testing and
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calibration of Unit 2 area radiation monitors (ARMS) and process
radiation monitors (PRMs) resulted in the expedited completion
of testing and calibration before fuel load. Significant
progress was also made in correcting weaknesses identified
during an inspection of chemistry confirmatory measurements
and discussed in a subsequent management meeting in the
regional office on April 3, 1987. The improvements included
accelerated implementation of a corporate program for water
quality control conforming to the Steam Generator Owners Group
guidelines, implementation of the Electric Power Research
Institute (EPRI) guidelines for primary vtater system chemistry,
and development of a quality control program to ensure the
adequacy of analytical measurements.
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Management involvement in ensuring quality was generally good
. during this period. Quality Assurance (QA) findings concerning
minor problems in radiation protection and radwaste record
keeping, procedural adherence, and attention to detail were
adequately handled. Management appears to be committed to
aggressively identifying and correcting weaknesses in the
radiation protection program. In the chemistry section,
well qualified staff personnel were brought in to maintain
and supervise the laboratory. The laboratory was well equipped
with state-of-the-art instrumentation for performing the required
chemistry analyses. Licensee management is well aware of the
loss of proficiency in laboratory analyses due to the rotation
of the Rad / Chem Technicians between the chemistry and health
physics sections, and is working to change this policy.
The licensee's approach to the resolution of radiological
technical issues was generally adequate during the assessment
period; however, due to the lack of operating history,
radiological hazards have been minimal. Installation, testing,
and calibration of NUREG-0737 mandated post-accident effluent
monitors, sampling systems, and radiation monitors for Unit 2
have been completed. ALARA awareness training has been
completed for current plant and contractor personnel; significant
challenges to the ALARA program have not been experienced to
date. Personnel doses and area and personnel contaminations have
been insignificant. There have been no shipments of solid
radwaste and no transportation incidents.
The results of the nonradiological confirmatory measurements
comparison were poor, with 15 agreements in 29 comparisons.
The disagreements revealed problems with laboratory analytical
measurements and resulted in the significant licensee
improvement noted above.
2. Conclusion
The licensee's performance is rated Category 2 in this area.
The licensee was rated Category 2 in the previous assessment
period.
3. Board Recommendations
None.
C. Maintenance
1. Analysis
This functional area was evaluated on the basis of routine
inspections conducted by resident and region-based inspectors.
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The enforcement history in this area included two Severity Level
IV violations. One involved the failure to follow an
administrative procedu.e and to provide adequate controls for
lubrication activities, the other concerned the failure to
evaluate out-of-calibration test and measuring equipment and
the associated effects on plant reliability and operability.
With regard to operational events, seven LERs were attributable
to maintenance activities, including five caused by personnel
error. Three of these errors resulted in reactor trips or
reactor trip signals during maintenance on reactor control and
protective systems. Another error, involving the failure to
remove hydraulic pressure from the actuator for and the
inadequate gagging of an MSIV, caused the MSIV to open and
contributed to one of the Technical Specification violations
discussed in the operations area.
Management involvement was usually evident. Records were
generally complete and well maintained, and there was little
evidence of procedure violations. Procurement generally appeared
to be well controlled and documented. However, management
involvement was weak in response to the issue involving
out-of-calibration test and measuring equipment. Resolution of
this issue was untimely and not completed at the end of the
assessment period.
In addition, the Operational Readiness Inspection (ORI) of
February 1988 confirmed concerns with the management control of
maintenance activities during the assessment period. The ORI
inspectors concluded that the control of the Braidwood
preventive maintenance program is fragmented among station
departments, making coordination difficult. In addition, the
ORI found that corrective maintenance items documented on
Construction Work Requests were not identified in the corrective
maintenance backlog of the plant's monthly status report. The
licensee is continuing to develop its preventive maintenance
program and has committed to actions to improve areas of
concern. A strength identified by the ORI is that the
licensee's threshold for entering equipment problems on work
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orders is sufficiently low to adequately maintain the material
I condition of equipment.
l A particularly significant ORI finding was that several
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recent equipment problems resulted from a lack of control
of out-of-service activities. The licensee's tracking of
temporary lifts of out-of-service tags was not sufficient
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to ensure operator awareness of plant status. Better
information to operators would have prevented those
instances where maintenance activities unexpectedly
affected equipment operability.
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Staffing in this area was adequate. -Key positions are filled
with qualified personnel.
2. Conclusion
The licensee's performance is rated Category 2 in this area.
This functional area was not rated during the previous
assessment period.
3. Board Recommendations
None.
D. Survelliance
1. Analysis
This functional area was evaluated on the basis of the.results
of several routine inspections conducted by resident and
region-based inspectors.
The enforcement history for this functional area included two
Severity Level IV violations. The first violation was
identified during the previous assessment period and discussed
in the SALP 6 Board Report. The second violation involved
three examples of exceeding the surveillance time interval
required by Technical Specifications. A backlog of surveillances
which had not yet been entered into the licensee's computerized
tracking system resulted in the missed surveillances. The
licensee has applied additional resources to correct this
situation.
With regard to operational events, of the 71 LERs issued during
the SALP period, 21 were attributable to surveillance activities,
including 11 caused by personnel error. Five of the personnel
i errors involved missed or incorrectly scheduled surveillances.
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Two others concerned mistakes made during the performance of
surveillances which resulted in a reactor trip and an ESF
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actuation. These instances of personnel error are evident of
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a lack of attention to detail.
Management involvement in ensuring the quality of surveillance
activities was generally evident. Surveillances were typically
conducted in a competent manner by properly qualified personnel.
Concern for conservatism and safety was apparent. The resolution
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of technical issues was generally sound and conservative.
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The licensee has demonstrated initiative in developing and
implementing the Microelectronic Surveillance and Calibration
(MESAC) system, which is unique to Braidwood. Use of the
system has resulted in more than a 95*.' reduction in the time
to conduct electronic surveillances and calibrations, as well
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as a significant reduction in trips and ESF actuations from
plants using conventional methods. None of the LERs in the
surveillance area were attributable to surveillances performed
by the MESAC system.
Staffing in this area was good; key positions are generally
filled by qualified personnel.
2. Conclusion
The licensee's performance is rated Category 2 in this area.
This functional area was not rated during the previous assessment
period.
3. Board Recommendations
None.
E. Fire Protection
1. Analysis
Evaluation of this functional area was based on two inspections
performed by region-based inspectors to review the licensee's
actions on previous inspection findings and Safety Evaluation
Report (SER) commitments and to witr.ess several gaseous fire
protection pre-operational tests, and on routine resident
inspector observations.
The enforcement history in this area declined slightly. One
Severity Level IV violation for failure to establish required
fire watches was issued. No violations were issued during the
previous assessment period.
The licensee's resolution of the NRC's concerns in the SER and
Region III inspection reports was generally sound and thorough.
For example, in the SER, the staff expressed concern that a
fire in the control room could result in the loss of power to
electronic card readers and door locks, preventing operators
from reaching locations necessary for achieving a safe
shutdown. To address this concern, the licensee modified the
"Control Room Inaccessibility Procedure" to require the
operators to take keys when evacuating the control room.
The licensee's responsiveness to NRC initiatives was mixed.
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In one case, an NRC inspector recommended that the licensee
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consider reducing the probability of head injury to shif t
j foremen or other personnel in transit to the remote shutdown
panel in the event of a disabling fire in the control room.
The licensee stated that it would remove structural steel to
reduce the potential for head injury. However, when discussing
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the Part 21 Report concerning Ruskin fire dampers (failure of
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. the fire damper'to close under air flow), an individual from
the licensee's management staff indicated that the licensee did
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not intend to investigate fire dampers other than Ruskin dampers.
This was an indication of lack of concern regarding whether fire
dampers other than Ruskin dampers would close under air flow
conditions in the event of a severe fire. This type of
attitude indicates that management support for the resolution
of technical issues was not always evident.
Staffing in the fire protection area was adequate. The plant's
fire protection staff was very professional and displayed a
good attitude when discussing concerns with the inspectors.
The liccnsee has done a good job of controlling flammable
materials and minimizing combustible debris. There were no
fire safety concerns in this area during the assessment
period.
2. Conclusion
The licensee is rated Category 2 in this functional area. The
licensee was rated Category 2 during the previous assessment
period.
3. Board Recommendations
None.
F. Emercency Preparedness
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1. Analysis
Evaluation of this functional area was based on five inspections
conducted by region-based inspectors. Two were followup
inspections of items identified during the 1986 Unit 1 emergency
preparedness (EP) implementation appraisal. Another was an
exercise observation. The remaining two inspections were a
routine inspection and an abbreviated Unit 2 EP implementation
appraisal, which together constituted a comprehensive evaluation
of the station's program prior to the Unit 2 fuel load.
The enforcement history declined slightly. One Severity Level
. IV violation was identified, compared to none during the previous
assessment period.
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The only viohtion related to the untimely
filing of controlled documents at the Emergency Operations
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Facility. The immediate and long-term corrective actions to
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address this violation were effective.
Management involvement in ensuring quality improved substantially
compared to the previous assessment period. Technically sound
corrective actions were completed on or ahead of schedule for
all appraisal findings. In contrast to the previous assessment
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period, additional management attention and resources were
devoted to completing these corrective actions, in addition to
implementing a number of other program improvements. No
emergency preparedness concerns have been identified which
could adversely affect a decision regarding full power licensing
for Unit 2. Several audits and multiple surveillances of the
program were thorough and well documented. Periodic drills,
communications tests, and emergency supply inventories were
completed as scheduled. Associated documentation indicated
that timely corrective action had been taken on identified
problems. Several systems were effectively utilized to track
corrective actions on NRC and licensee-identified items. No
items requiring corrective action were identified during
the 1987 exercise, compared to two items identified during the
previous exercise. However, several technical scenario flaws
and inadequate controller actions had to be overcome by
exercise particip:nts.
The licensee correctly classified and adequately reported all
situations that were classifiable emergencies. The Event
Notification Worksheet has been proceduralized to facilitate
conversations with NRC Duty Officers. Several emergency
declarations were conservative, pending resolution of an NRC
concern on the wording and interpretation of an identical
Emergency Action Level for the licensee's Byron Station. The
licensee's evaluations of records generated during emergency
plan activations were thorough and well documented.
The licensee has maintained adequate numbers of fully trained
personnel for well-defined key and support positions in the
onsite emergency organization. The licensee created an
additional staff level position in the Technical Support Center
to help the Health Physics staff deal more effectively with
plant chemistry issues.
The emergency preparedness training program was well defined.
Training requirements, lessor. plans, and examinations were
approved and specified for all onsite positions.
Corporate-developed lesson plans were refined by the Braidwood
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Station staff and later distributed as models to enhance the
onsite emergency organization training programs at the licensee's
other nuclear stations. The training status of individuals was
very well tracked and documented. Based on exercise performance,
records checks, and walk throughs with a large sample (about 50)
of key and support staff, it was determined that the onsite
emergency organization was well trained.
2. Conclusion
The licensee's performance is rated Category 1 in this area.
The licensee was rated Category 2 in the last assessment period.
The licensee's improved rating is based on the level of
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management attention and resources that have been devoted to
resolving all previous NRC concerns and to implementing
additional program improvements. The rating also reflects the
demonstrated high quality of the onsite emergency organization's
' training program.
3. Board Recommendations
None.
G. Security
1. Analysis
Evaluation of this functional area was based on the results of
six security inspections (two routine, two special, and two
preoperational) conducted by region-based physical security
inspectors, and on the results of the inspections conducted by
the resident inspectors to routinely observe security activities.
The enforcement history in this area was good. Two Severity
Level IV violations were identified. The two violations were
considered to be isolated occurrences (involving access control
of personnel and packages). The violations represented failures
by the licensee to follow ics approved security plan and did not
represent any major programmatic concerns. There were no
security violations cited in this area during the previous
assessment period, which primarily included preoperational
D pection activities. Additionally, security inspections
ie.ntified three areas in the security program which could be
strengthened. These areas included vital area portal control,
searchas, and the protection of safeguards information. Licensee
corrective actions to address violations and weaknesses were
timely and appropriate.
Management involvement in ensuring the quality of the security
program was generally adequate. However, an inspection of
equipment tampering events, conducted between March 5 and
May 5, 1987, showed that licensee management should initiate
comprehensive analyses and investigations to resolve tampering
matters in a more expeditious manner. Review action should be
taken at the first hint of a potential tampering incident to
determine the impact on the security status of the facility.
Required records and reports were generally complete, well
maintained, and available. The licensee had no reportable
security events during this assessment period.
Staffing was adequate. Positions within the licensee and
contractor security organizations were appropriately identified,
and responsibilities were adequately defined. Liaison between
the licensee security organi:ation and the other licensee
departments and the contract security organization was adequate.
14
.
c
,.
.
The contract security force was properly supervised and trained.
Procedural guidance was sufficient in detail to assure that
security personnel were knowledgeable of their responsibilities.
The security training and qualification program is acceptable
and satisfies commitments.
2. Conclusion
Licensee performance is rated Category 2 in this area. The
licensee was rated Category 2 during the previous assessment
period.
3. Board Recommendations
Note.
H- 9fh19e5
2. Ana 'ysi s
As B,*aidwood Unit 1 is early in its operating history, no
majoi outages had teen conducted prior to the con:lusion of
this assessment period. However, the licensee has staffed its
outtge administrat)on organization with qualified individuals.
To c: ate, this organization's activities have been primarily
confined to the scheduling and administration of preoperational
surv..illances for both units. The management of preoperational
surveillances has generally been effective in keeping startup
activities on track.
3
2. Conclusi,on
The licensee was not rated in this area due to limited
licensee activities and inspection effort during the assessment
period. This area was also not addressed during the previous '
assessment period.
3. Board Recommendations
None.
1. Quality programs and Administrative Controls Affecting Quality
1. Analysis
The evaluation of this area addresses two related but separate
functions. First, it assesses the licensee's management
activities aimed at achieving quality in overall plant
operations. This assessment in great measure is a reflection
of the quality of licensee activities in individual functional
areas addressed in other sections of this report. Secondly,
15
(
- - - ________ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _
.
. _ _ _ _ _ _ ___ -_ . _ _ ___ _ _ _ _ _ _ _ - _ .__ _ _ _ _ _ _ _ _ . - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _
L
.
t
~, this section addresses the licenswe's internal, independent
quality oversight activities, such as those performed by the
quality control / quality assurance (QA) organizations.
With respect to management's general effectiveness in achieving
high quality in facility operation, a chief concern involves
the large number of. personnel errors compiled during this
assessment period. The frequency of these errors indicates
that a high level of personnel alertness and sensitivity to
plant conditions and requirements is not always maintained.
This general relaxation of alertness and attention to detail
has not significantly impacted preoperational activities, but
could result in more serious consequences during future
operation.
An area of particular effectiveness was the licensee's
coordination of Unit I and Unit 2 activities. Unit 1 startup
testing and power ascension were conducted concurrently with
Unit 2 preoperational testing and initial fuel loading. .Despite
tFe heavy demands of these activities, both on the work force
and on management, they were managed well, and significant
problems were avoided.
Effective management control was also evident in the Unit 2 *
fuel loading activities. The fuel loading was conducted in an
efficient but unhurried manner. The coordination of activities ,
in the fuel handling building and in containrant was effectively
handled. The individuals involved were knowledgeable of their i
assignsd tasks. Procedural problems encountered during tne ,
fuel loading were resolved prior to resumption of the evolution.
The licensee's "Quality First" organization has proven to be an
effective management tool for resolving 'nternal employee ,
concerns.
A licensee strength was the performance of its regulatory
assurance organization. This group was well staffed with
energetic and professional personnel who were typically
effective in resolving regulatory issues.
The licensee's responses to nntices of violation were generally ;
adequate. However, there were several cases in which the
4 licensee took an argumentative position in its response. In
these instances the licensee focused on objecting to tne
- interpretation of the violated regulation instead of addressing
the safety aspects of che issue and providing assurance of
'
effective corrective actien.
With respect to the evaluation of the licensee's internal and
independent Quality oversight activities, results of routine
inspections conducted by resident and region-based inspectors
,
'
16
. . - . . - _ . - . . . .-
._
- _ _ _ _ _ _ _ _ _ - _ _ _
.-
were considered. Areas examined included QA record control,
implementation of the licensee's QA program for operational
activities, and QA inspections of startup activities.
The enforcement history was similar to that of the last
assessment period. Although four violations (one Severity
Level IV violation and three Severity Level V violations) were
issued, two of the Severity Level V violations were identified
during the previous period. These were discussed in-the SALP 6
Board Report. Two of the violations concerned QA activities of
a station contractor. None of the violations was of major
safety significance. One Severity Level IV violation and one
Severity Level V violation were issued during the previous
assessment period.
'
Management appeared to be involved in the control of quality in
the areas inspected. There was evidence that licensee
management was involved in assuring quality for the startup
test program. Administrative controls for QA records appeared
adequate.
Improvement was noted in that the auditing activities of the
licensee's quality oversight organizations are becoming more
performance and technically oriented. This change in focus
applies both to the QA department, particularly with the
incorporation of a senior reactor operator as a QA inspector,
and to the Onsite Nuclear Safety Group.
The approach used to resolve problems appeared to be generally
conservative and technically sound. The licensee's
responsiveness to questions and requests for information was
timely and complete. Proposed resolutions were acceptable.
! 2. Conclusion
The licensee's performance is rated Category 2 in this area.
The licensee was rated Category 1 in the previous assessment
period. The decline in rating reflects the overall adequacy of
programs and controls affecting the quality of operational
activities, as opposed to the aggressive resolution of
construction issues during the previous assessment period.
- 3. Board Recommendations
None.
, J. Licensing Activities
1. Analysis
i The basis for this assessment was the staff's evaluation of the
licensee's performance in support of licensing actions (issuance
'
of full power and low-power licenses, amendment requests,
17
__ __ _-_ _ _ _ _ _ _ .
.
. responses to generic letters, and other actions) during the
assessment period. These actions have resulted in three license
amendments to the Technical Specifications and one exemp?. ion
to 10 CFR 50, Appendix J. In addition, the Unit 1 full-power
and Unit 2 low-power licenses were issued during this assessment
period.
The most significant licensing activities for this SALP period
were the issuance of the full-power license for Unit I and the
low-power license for Unit 2. During these activities, there
was generally sufficient corporate management involvement to
ensure that the submittals needed to support licensing of both
units were timely, thorough, and technically sound. The quality
of the licensee's reviews and responses to NRC concerns was kept
at an adequate lavel. Corporate management usually maintained
close contact with the NPC staff in order to ensure that
licensing matters were kept on course and that problems were
resolved in a timely and satisfactory manner. However, certain
issues pertaining to fire protection and initial test programs
should have beer, resolved by the licensee earlier in the review
process. Therefore, management involvement could have been
improved in those two areas.
A clear understanding of the technical issues was evident.
Conservatism and a viable approach to resolution were generally
exhibited. In several instances, the licensee challenged the
staff position (such as the closing of the RHR cross-connect
valve while in Mode 1), but only when it believed safety would
, not have been compromised.
In the weeks prior to the issuance of the full-power license for
Unit 1 and the low-power license for Unit 2, the licensee's
responses in support of the NRC's reviews, initiatives, and
concerns were generally timely, technically sound, and thorough.
Both the station and the corporate office were willing to
accommodate NPC-initiated programs (i.e., special studies,
surveys, or evaluative programs being conducted by or for the
NRC). The licensee usually made efforts to establish a single
point of contact for activities which involved more than one
station (such at the Safety Issues Management System [SIMS]
report) in order to assist the NRC staff in its review.
!
There was open and effective communication between the NRC staff
and the licensee's staff. However, on occasion the licensee
did not properly coordinate activities with the Region.
Responses to NRC initiatives were timely ard technically sound,
largely due to the effective exchange between both staffs.
l
Established commitment dates were usually met, except where
'
written suomittals were provided to establish new finn dates and
to explain the reasons for the changes. Where applicable,
'
conference calls with the staff were established and generally
l
!
l
l
18
l
_
-
__ - ____
l
.
' included appropriate engineering, plant and/or contractor
personnel. The licensee's nuclear licensing administrator
and/or management in most cases worked very well with NRR to
coordinate resolutions of licensing and technical issues.
Key positions have been clearly identified and responsibilities
well defined for both plant staff and licensing personnel.
2. Conclusion
The licensee's performance is rated Category 2 in this area.
The licensee was rated Category 2 during the previous
assessment period.
3. Boards Recommendations
None.
K. Training and Qualification Effectiveness
1. Analysis
Evaluation of this functional area was based on a training
effectiveness inspection, observations by resident inspectors,
ar.d the results of licensed operator examinations and associated
observations.
Enforcement history in this area represented performance that
conformed to NRC regulations. No violations or deviations were
identified during this assessment period; none were identified
during the previous assessment period.
Management involvement in ensuring quality in this functional
area was very good. Seventeen senior reactor operator (SRO)
and ten reactor operator (RO) replacement exminations were
administered by the NRC during the assessment period; one SR0
candidate failed the examination. During this evaluation period,
the success rate (96%) for NRC administered examinations exceeded
- the success rate (85%) for the previous assessment period.
The candidates were well versed in Technical Specifications with
regard to understanding the action statements, limiting
conditions for operation, and surveillance requirements. The
candidates were strong in their overall plant knowledge, as
demonstrated in the walk-through portion of the operating
examination. The candidates exhibited good familiarity with
emergency procedures and abnormal procedures during the
operating examination. The candidates were strong in the
administrative areas, as demonstrated in the control room
portion of the operating examination. The candidates exhibited
a high degree of professionalism in the connunication, execution,
and implementation of applicable procedures during the simulator
portion of the examination.
19
- _ _ _ - _ - _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ - - _ _
.
.. The Braidwood Training Staff consistently demonstrated
immediate responsiveness to all NRC concerns relating to
licensed operator training and plant procedures during the
rating period.
From a safety point of view, the licensee's approach to resolving
technical issues was very good. The training program utilized a
review and analysis system to ensure that lessons learned from
events at Braidwood Station and other plants were factored into
the continuing _and initial training programs for licensed and j
non-licensed operators, technical staff, and technicians. During
the training effectiveness inspection, it was found that the
personnel contacted were very knowledgeable about their duties
and responsibilities, and operational events could seldom be '
traced to inadequate training as a contributing cause. An
effective requalification/ retraining program is in place for
all licensed and non-licensed personnel, including management. .
The onsite and offsite support staffs were qualified in
accordance with the licensee's commitments and requirements.
The licensee was fully prepared at the end of the assessment
oeriod for Institute of Nuclear Power Operations (INPO)
accreditation for the following training programs at Braidwood
Station: (1) Senior Reactor Operator; (2) Reactor Operator;
(3) Non-Licensed Operator; and (4) Shift Technical Advisor /
Station Control Room Engineer. Accreditation was received in
January 1988. The remaining training programs are scheduled
for self-evaluation er.d submittal to INP0 in March 1988.
Training records showed that quality assurance auditors who
inspected startup activities were qualified. Interviews with
quality assurance personnel indicated an adequate understanding
of basic responsibilities and testing activities. Observations
of audits and surveillances indicated that personnel performing
+ those activities were well trained and qualified.
The Rad / Chem technicians completed their training and were
qualified to collect samples from the high radiation sampling
system under both routine and accident conditions.
2. Conclusions
The licensee is rated Category 1 in this functional area. The
licensee was rated Category 2 in this area during the last
assessment period. The improved rating reflects the Iicensee's
excellent success rate in SRO and R0 examinations and the
ove~all strength of the licensee's training program.
3. Board Recommendations
None.
20
'
= - - - - ._____-_____-__ -
. - ._
.
-
L. Preoperational and Startup Testing
1. Analysis
Evaluation of this functional area was based on the results
of several routine inspections conducted by resident and
region-based inspectors.
The enforcement history in this area showed a decline in
performance during this assessment period. Four violations
(one Severity Level IV and three Severity Level V violations)
were issued during this assessment period, compared to one
violation (Severity Level V) during the last period. Four
additional violations (one Severity Level IV and three Severity
Level V violations) were identified during this assessment period
but issued after its conclusion. The violations involved the
failure to properly follow plant administrative procedures.
Management involvement to assure quality in this functional area
included the developement of several programs. A lessons-learned
program was implemented to incorporate past testing experiences
into test preparations, performance, and evaluation of results.
A program was developed for managing concurrent Unit 1 and
Unit 2 activities to assure safe operations. Of concern was
the desire to defer test completion reviews required prior to
licensing solely on the basis t the licensee had not had
time to review the adequacy ( .e test and associated
results.
The licensee was responsive to NRC concerns on technical issues.
Appropriate personnel, information, and documentation were
provided in a timely manner to resolve NRC cor.cerns.
The startup and preoperational testing groups were well staffed
and knowledgeable in testing matters. One inspector concern was
the timeliness of Project Engineering support in reviewing Unit 1
startup test results. The lateness of test reviews was primarily
due to coincident startup and preoperational test programs in
progress on both units. The personnel available were used to
facilitate the licensing of Unit 2, which was a higher priority
for the licensee. With the licensing of Unit 2, Project
Engineering should have sufficient personnel to perform the
required reviews in a timely manner. Another concern was
communications within the plant, including communications
equipment not functioning, personnel not being informed of
evolutions in progress, and problems with status keeping of
components and systems. The licensee has made progress in
improving in this area during the assessment period.
2. Conclusions
The licensee's performance is rated Category 2 in this area.
The licensee's performance was rated Category 1 in the
21
. - - - _ _ - - - - -
. .
. . . . .
. .
,
.
.
- corresponding functional area, Preoperational Testing, during
the previous SALP period. The decline in the rating is largely
due to the increase in violations in this area.
3. Board Recernendations
None.
M. Conticuction
1. Analysis
Evaluation of this functional area was based on the results of
nine inspections conducted by region-based inspectors and routine
inspections by the resident inspectors. Activities examined
during these inspections included the licensee's responses to
three IE Bulletins, one 10 CFR Part 21 report, and numerous
10 CFR 50.55(e) items. Also included were preservice inspection
activities, work and welding associated with safety-related
structures and safety-related components, seismic analyses for
as-built safety-related piping systems, the testing of
safety-related pipe support / restraint systems, work and welding
associated with reactor coolant pressure boundary piping, and
walkdowns of heating, ventilation, and air conditioning (HVAC)
and piping systems. In addition, two allegations relating to the
fabrication of piping and pipe supports were investigated.
The aforcement history indicated an improvement in performance.
Two Severity Level IV violations were issued as a result of
inadequate corrective actions for pipe support deficiencies,
one of which resulted from the investigation of an allegation.
These minor violations were not indicative of any programmatic
'
breakdown. The subsequent corrective actions were initiated in
a timely manner. Four Severity Level IV violations and one
Severity Level V violation were issued during the previous
assessment period.
All of the construction programs reviewed showed indications
of planning and the establishment of adequate priorities. The
programs were controlled through the use of well-stated and
defined procedures. All engineering documentation associated
with the safety-related ceismic analyses, structures, components,
and piping supports were found to be generally complete, well
maintained, and available. However, corrective actions
associated with several fabrication and construction deficiencies
on pipe FJpports were ineffective and did not adequately address
the root causes. Two violations were issued as a result of those
findings.
The approach used by the licensee to resolve the numercus design
and construction deficiencies was conservative and exhibited a
clear understanding of the issues. Generally, the issues were
resolved using technically sound and comprehensive approaches.
22
___
. I
- - - - - - _
..
, .. ,. . . .
.
The licensee's actions in response to IE Bulletins No. 79-14,
No. 81-01 and No. 83-05 were considered to be viable and
'
generally contained sound and thorough approaches. Responses
were received in a timely manner and were implemented within
an acceptable schedule.
Training and qualification records'for piping and pipe support
welders and personnel performing structural integrity tests,
piping thermal walkdowns and piping vibration measurements
indicated that the training program was well defined and well
implemented. The related procedures and instructions were
strictly followed.
2. Conclusions
The licensee's performance is rated Category 2 in this area.
The licensee was rated Category 2 in the previous assessment
period.
3. Board Recommendations
None.
N. Engineering / Technical Support
1. Analysis
This functional area was evaluated on the basis of the results
of several routine and special inspections conaucted by resident
and region-based inspectors. Areas examined included licensee
actions to address the diesel generator rocker arm failure, the
condensate discharge piping failure, and the reactor coolant
system pressure transient; electrical component installation
and design; and technical reviews of Emergency Operating
Procedures (EOPs).
This is a new area of performance evaluation and therefore has
no enforcement history for comparison to the current SALP
assessment period. One Severity Level IV violation was issued
in this area for errors in the final revisions of the E0Ps.
Management involvement in addressing the three events listed
above was demonstrated by the appropriate level of decision
making. Corporate management was involved in most of 'he
related site activities. Corrective actions focused on the
root causes of problems. Further evidence of management
involvement was the implementation of an engineering
verification program for installed electrical components.
However, management should have adopted a more conservative
approach when addressing program-identified deficiencies.
23
_ _ _ _ _ - - _ _ _ _ _ _ _ _ - . _ _ _ - - _ - - _ _ - - - _ _ - _ . . . .. .
. . - ..
.
. Inadequate management involvement in ensuring the quality of
E0Ps was evident during this rating period. The E0Ps issued
.for use contained numerous errors such as transfers to wrong
steps and erroneous equipment numbers. The errors could have
led to confusion during actual use. Further, the lack of an
adequate program to assure the quality of the E0Ps provided
the potential for errors of safety significance.
The licensee's approach to the resolution of the diesel
generator rocker arm failures, the condensate system pipe
cracks, and the reactor coolant' system pressure transient
demonstrated viable, generally sound, and conservative
engineering practice. An understanding of engineering issues
was generally apparent. Sufficiently thorough evaluations were
performed to evaluate the safety significance'of each event.
In general, the licensee's responsiveness to the NRC's
questions and requests for additional information were timely
and thorough. Of particular note was the licensee's commitment
to conduct a comprehensive review of the Critical Drawings in
the control room to resolve an inspector-identified concern.
In response to the NRC-identified deficiencies in the E0Ps,
the licensee performed additional E0P reviews and found more
deficiencies. All deficiencies were corrected in a timely
manner. Additional reviews have been added to the program
to prevent further deficiencies. The effectiveness of this
effort has not been evaluated.
Staffing in this area was adequate. Personnel were adequately
trained for assigned tasks. In addition, appropriate expertise
was applied to the evaluation of the operational problems
discussed in this section through the utilization of outside
consultants.
2. Conclusion
i
The licensee's performance is rated Category 2 in this area.
l
Since this is a new area, no rating is available for the
previous assessment period.
l 3. Board Recommendations
!
None.
I
l
24
- .. - ---_. . . . .
.
L
. V. SUPPORT _ING DATA AND SUMMARIES
A. Licensee Activities
1. Unit 1
Braidwood Unit 1 began this assessment period in cold shutdown
and was involvedcin precriticality tests in preparation,for
.
its power ascension for startup. After the unit achieved
initial criticality on May 29, 1987, the licensee continued
'
preoperational and startup testing. The unit engaged in periodic
power operation throughout tae assessment period, except for
'
various short outages for testing and maintenance. Significant
L outages and major events which occurred during the assessment ~
period are summarized below:
Significant Outages / Major Events
a. May 21, 1987 - The licensee was issued a low power (up
to 5%) operating license for Braidwood Unit 1.
b. May 29, 1987 - Unit 1 achieved initial criticality.
c. May 31 - June 1, 1987 -
Unit I was shut down due to a
faulty high/ low pressure alarm on a safety injectior
accumulator. The unit remained shutdown for evaluation
and repair of accumulator instrumentation.
d. July 1-2, 1987 - Unit I was shut down due to a control
rod urgent failure alarm. It remained shutdown for
investigation and repair of the problem,
e. July 2, 1987 -
The licensee was issued a full power
operating license for Braidwood Unit 1.
f. July 12-13, 1987 - Unit I was shut down for initial
turbine generator tests and repairs prior to synchronization
to the grid.
"
g. August 10-17, 1987 - Unit I was shut down for repair of a
header drain tank rupture disk and the 1A auxiliary
feedwater pump, and for turbine lubricating oil cleanup.
h. September 2-5, 1987 - Unit I was shut down for
modifications to the auxiliary feedwater system,
i. September 18-19, 1987 -
Unit I was shut down for repair
of the turbine electrohydraulic control system.
J. October 9-15, 1987 - Unit 1 was shut down after a turbine
trip during turbine control / governor valve testing. The
unit remained shutdown for investigation of why the turbine
impulse pressure signal became unstable.
25
- .-. -
. .- _. ___ . _ _ - _ _ _ _ _ __ --
_ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ __ __ __ .
-.
k. November 18-19, 1987 -
Unit I was shut down for~a short,
'
planned maintenance outage to realign the stator cooling
'
system.
1. December 18, 1987 -
Unit I reached approximately 90% power.
Unit 1 experienced 26 ESF actuations, including 1 safety
injection without water. and 18 reactor scrams (3 scrams at-
greater than or equal to 15% power, 6 scrams at less than
15% power, and 9 scrams without rod motion). Seven reactor
scrams and 8 ESF actuations were the result of personnel
errors.
2. Unit 2
Braidwood Unit 2 began the assessment period with its
construction phase essentially complete. The licensee performed
the required testing and preparations for initial power ascension,
and on December 18, 1987, the licensee was issued a low power
license permitting fuel loading and operation up to 5% power for
the unit. Precriticality testing and related maintenance
activities were conducted on schedule during the remainder of
the assessment period. Significant outages or major events which
occurred during the assessment period are summarized below:
Significant Outages / Major Events
a. July 27, 1987 - The licensee was issued an NRC material
license (No. SNM-1945) for Braidwood Unit 2.
b. December 18, 1987 - The licensee was issued a low power
license (No. NPF-75) authorizing initial fuel loading and
critical operation up to 5% power. This license replaces
construction permit No. CPPR-133.
c. December 21-27, 1987 - Unit 2 conducted its initial fuel
loading activities.
8. Inspection Activities
Fifty-eight inspection reports were issued during this assessment
period, December 1, 1986 through December 31, 1987. Significant
inspection activities are listed in Paragraph 2 of this section,
"Special Inspection Summary."
1. Inspection Data
Facility Name: Braidwood
Unit: 1
Docket No: 50-456
Inspection Report Nos: 86023, 86057*, 86060 through 86066*,
87001 through 87035, 87037, 87039, 87040, 87042, and 87043.
26
.
., ,
Facility Name: Braidwood
~
.
Unit: 2
Docket No: 50-457
Inspection Report Nos: 86044 through 86050*, 87001 through
87033, 87035, 87037, 87038, and 87040 through 87044.
The results of inspecti.n reports 86057, 86062, and 86063
for Unit l'and 86044, 86046, and 86047 for Unit 2 were
discussed in the SALP 6' Board Report. They are included here
because they were issued during the SALP 7 assessment period.
.
C
27
L..., .
- ..
.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
,
,
TABLE I
.
NUMBER OF VIOLATIONS IN EACH SEVERITY LEVEL
\
UNIT 1 UNIT 2 COMMON
Functional Areas IV V IV V IV V
A. Plant Operations 3.5 1
B. Radiological Controls -0.5
C. Maintenance 1 1
D. Surveillance 1 1**
E. Fire Protection 1
G. Security 2
H. Outages
I Quality Programs and 1** 1 2** =
Administrative Controls
Affecting Quality <
J. Licensing Activitiet
K. Training and Qualification
Effectiveness
L. Preoperational and Startup 1 2 2
Testing ,
M. Construction 1 1
N. Engineering / Technical. 1
Support
UNIT 1 UNIT 2 COMMON
TOTALS IV V .IV V IV V
12 4 1 1 4 2
- Each of these totals includes one violation which was also accounted for in
the SALP 6 Board Report. These violations were identified during the previous
assessment period but issued during this assessment period.
2. Special Inspection Summary
a. An emergency preparedness exercise was conducted on
March 30, 1987 (Inspection Report Nos. 456/87006,
457/87005),
b. During June 1 through 5, 1987, an operational readiness
team inspection was conducted prior to full power licensing
for Unit 1 (Inspection Report No. 456/87018).
C. Investigations and Allegations Review
Fifteen allegations were reported during this assessment period. Nine
of these 15 allegations and 4 previously reported allegations were
closed during this assessment period. Nine allegations remained
unresolved at the end of this assessment period.
28
t
.
, D. Escalated Enforcement Actions
No escalated enforcement actions were taken or civil penalties issued
during this assessment period.
E. Licensee Conferences Held Durino Assessment Period
1. December 16, 1986, Site - A management meeting was conducted with
licensee representatives to discuss the licensee's list of items
to be dispositioned prior to Unit 1 mode changes, and to review
the licensee's updates of the status of Braidwood's testing and
construction activities.
2. January 23, 1987, Site - A management meeting was conducted with
licensee representatives to discuss the licensee's list of items
to be dispositioned prior to mode changes in Unit 1, and to
review the licensee's updates on the status of Braidwood's ;
testing and construction activities.
3. February 5, 1987, Regional Office - A management meeting was
conducted with licensee representatives to discuss the immediate
notification requirements of 10 CFR 50.72(b)(2)(ii), with
emphasis on the NRC's expectations of reporting reactor
protection system and ESF actuations.
4. February 19, 1987, Site - Commissioner Zech toured the Braidwood
site and conducted a management meeting with licensee
representatives to discuss his findings and to encourage the
licensee to continue its quality performance.
5. March 6, 1987, Site - A management meeting was conducted with
licensee representatives to discuss a Part 21 report concerning
Ruskin Fire Dampers.
6. March 17, 1987, Regional Office - A management meeting was
conducted with licensee representatives to discuss the SALP 6
Board Report for the assessment period December 1, 1985 through
November 30, 1986.
7. March 24, 1987, Site - NRC Commissioner Asselstine toured the
Braidwood facility and observed several drills. A management
meeting was conducted with licensee representatives to discuss
Unit l's startup activities and Unit 2's preoperational testing.
8. April 6, 1987, Site - A management meeting was conducted with
licensee representatives to discuss the licensee's list of items
to be dispositioned prior to Unit l's initial startup.
9. June 27, 1987, Site - The Director of NRR and NRC staff toured
the Braidwood site and conducted a management meeting with
licensee representatives, in which the licensee provided an
update on the status of the station.
29
1
L..... . /
_ _ _ _ _ _ . _ _ _ _ _ - _ _ - _ _ _ _ _ _ - _ _ _ _ - __ ______ _ __-______ _ __-_ - __ ___-.
.
4
10. June 30,1987, ~ Headquarters - A management meeting was conducted
by licensee representatives, NRC staff, and NRC Commissioners to
discuss the licensee's request for a full power operational
license for Braidwood Unit 1. The Commission voted 4 to 1 in
favor of issuance.
11. August 18, 1987, Regional Office - A management meeting with
licensee representatives was conductea to discuss the guidance
they were preparing to issue to their nuclear power stations
regarding the proper interpretation of Technical Specification 3.0.3.
12. October 5, 1987, Regional Office - A management meeting was
conducted with licensee representatives to discuss the operating
performance and continued power ascension testing of Unit 1.
13. October 23, 1987, Site - A management meeting was conducted with
licensee representatives to discuss Unit 2's construction status,
testing program, personnel turnover, performance history, and
operational readiness to load fuel.
14. November 13, 1987, Regional Office - A management meeting was
conducted with licensee representatives to discuss Unit 2's
fuel loading and operational readiness.
15. December 2, 1987, Site - A management meeting was conducted
with licensee representatives to discuss Unit 2's readiness for
licensing.
16. December 14, 1987, Regional Office - A managemer,t meeting
was conducted with licensee representatives to discuss the
implications of a contract employee who had tested positive
for drugs.
17. December 16, 1987, Site - A final management meeting was
conducted with licensee representatives to discuss Unit 2's
status prior to licensing.
F. Confirmatory Action Letters (CALs)
No confirmatory action letters were issued during this SALP assessment
period.
l
i G. A Review of Licensee Event Reports, Construction Deficiency Reports,
l and 10 CFR Part 21 Reports Submitted by the Licensee
1. Construction Deficiency Reports (CORs),10 CFR Part 21 Reports
One CDR (diesel generator rocker arm failure) was submitted
by the licensee per 10 CFR 50.55(e).
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, _ _ _ _ _ _ _ - _ _ _-- - _ _________ ______- ___ ___ _
.
, No 10 CFR Part 21 reports were submitted by the licensee.
2, Licensee Event Reports (LERs)
Unit 1
Braidwood
Docket No: 50-456
LER Nos: 86002 through 86011, 87001 through 87060, and 87062.
Seventy-one LERs were issued for Unit I during this
assessment period; 52% (37 LERs) were the result of
personnel errors; 15.5*4(11 LERs) were the result of
procedure inadequacies; 15.5% (11 LERs) were the result of
component / equipment failures; 4% [3 LERs) were related
to design problems; and 13% (9 LERs) resulted from other
causes (i.e., external causes, unknown human, undetermined,
or investigating).
I
Unit 2
Braidwood
Docket No: 50-457
LER Nos: N/A
No LERs were issued during this SALP assessment period
for Unit 2.
The frequency of LER issuance during' this assessment period was
5.5 LERs per month. Only 1 LER was issued'during the last SALP
assessment period; therefore, no site comparisons will be made
at this time.
NOTE: The above information was derived from a review of LERs
performed by the NRC Region III Staff and may not completely
coincide with the licensee's proximate cause assignments.
.
H. Licensing Activities
1. NRR/ Licensee Meetings
! March 18, 1987 - Transfer of ownership of Braidwood Units 1
and 2
,
May 14, 1987 - General status of Braidwood and other CECO
l plants
l
June 29, 1987 - Further discussion on transfer of ownership
of Braidwood Units 1 and 2
October 21, 1987 - Meeting with ASLAB to hear oral arguments
on pending appeal of intervenors from
Board 870519 concluding partial initial
decision
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L J
_ _ _ _ _ _
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. .
,, .
.
.
Lo
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i
t 2. NRR Site Visits / Meetings
August 21, 1987 - Project Manager.(PM) site visit'and NGET
training for site access
October 5, 1987 - PM attended Braidwood management meeting at
RIII
October 12, 1987 - PM and Project Engineer (PE) site visit
November 9, 1987 - PM and Instrumentation and Control Systems
Branch (ICSB) reviewer site visit for
review of MESAC system
December 2, 1987 - PM and Project Director (PD) site visit to
discuss readiness for Unit 2 low power
license
3. Commission Meetings
June 30, 1987 Commission briefing on Braidwood Unit 1
full power license
4. Event Briefings - None
5. ACRS Meetings - None
6. Schedule Extensions Granted
Deferral of limited aspects of the Pre-Operational Test Program
Deferral of completion of specific areas of Fire Protection
7. Reliefs Granted
One-time exception granted for operator requalification program
topical report
Demonstration of control room envelope integrity deferred until
completion of the Unit I surveillance outage
8. Exemptions Granted
Appendix J exemption issued with Braidwood Unit 1 full power
license and Braidwood Unit 2 low power license
9. License Amendments Issued
October 30, 1987 - Amd. No. 1, Allow extension for surveillance
of diesel generators
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L - _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ --___
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, .-
,,
November 25, 1987 - Amd. No. 2, Allow a one-time extension to
32 months from 18 months for instrument
surveillance
December 8, 1987 -
Amd. No. 3, Allow deletion of reactor trip
on turbine trip below 30% power
10. Emergency Technical. Specifications Issued - None
11. Orders Issued - None
,
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