ML20150E970
| ML20150E970 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 03/29/1988 |
| From: | Phil Brochman, Grant W, Hare S, Kropp W, Lanksbury R, Little B, Phillips M, Sands S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20150E964 | List: |
| References | |
| 50-457-88-07, 50-457-88-7, GL-82-12, NUDOCS 8804040216 | |
| Download: ML20150E970 (20) | |
See also: IR 05000457/1988007
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION III
Report No. 50-457/88007(DRS)
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Docket No. 50-457
License No. NPF-75
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Licensee:
Commonwealth Edison Company
Post Office Box 767
Chicago, IL 60690
Facility Name:
Braidwood Station, Unit 2
Inspection At:
Braidwood Site, Braidwood, Illinois
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Inspection Conducted:
February 16 through March 7, 1988
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NRC Operational Readiness Inspection Team
1/b9/f7
Inspectors:
Team Leader:
R. D. Lanks ury
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Team Members:
P. G. Brochman 66
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B. H. Little F
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S. M. Hare
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S. P. Sands
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W. B. Grant
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W. J. Kro
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Approved By:
M. P. Phillips, Chief
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Operations Section
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8804040216 880329
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ADOCK 05000457
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Inspection Summary
Inspection on February 16 through March 7, 1988 (Report No. 50-457/88007(DRS))
Areas Inspected:
Special announced team inspection by Region 111, NRC
Headquarters, and senior resident based inspectors to perform an operational
readiness inspection prior to full power licensing of the Braidwood Unit 2
plant.
Areas reviewed included:
operations, surveillance and testing,
maintenance, radiation controls, chemistry controls, nuclear engineer
activities, and training.
Results:
Of the seven functional areas inspected, no violations or
deviations were identified in six of the seven areas.
However, one Open Item
(paragraph 5.f) was identified in one functional area (maintenance) to track
resolution of a perceived problem with the licensee's scheduling of periodic
lubrications, and one Unresolved Item (paragraph 6) was identified in another
functional area (radiation controls) to track resolution of a potential
noncompliance with Technical Specification requirements for control of Radiation
Control Technicians overtime.
Within the remaining functional area (operations)
two violations were identified.
One violation (paragraph 3.j) was identified
for failure to write a deviation report, as required, after the Boric Acid
Transfer Pumps recirculation line was identified as having become plugged.
The second violation (paragraph 3.k) involved multiple examples of a weak and
ineffective Out-of-Service program.
After returning to the Braidwood station
to followup on corrective actions instituted by the licensee as a result of
the initial inspection, the ORI was able to make a recommendation to Region III
management for issuance of a full power license for Braidwood Unit 2.
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DETAILS
1.
Persons Contacted
Commonwealth Edison Company (CECO)
+T. J. Maiman, Vice President PWR Operations
+K. L. Graesser, General Manager Nuclear Operations
+E. E. Fitzpatrick, Station Manager
@+K. Kofron, Production Superintendent
@+D. E. O'Brien, Services Superintendent
@+P. L. Barnes, Regulatory Assurance Supervisor
0+E. W. Carroll, Regulatory Assurance
@T. W. Simpkin, Regulatory Assurance
+L. M. Kline, Regulatory Assurance
+R. E. Acker, Radiation / Chemistry Supervisor
+G. R. Masters, Assistant Superintendent Operating
+D. E. Paquette, Assistant Superintendent Maintenance
+J. G. Marshall, Unit 2 Station Startup Assistant
+R. J. Ungeran, Operating Engineer, Unit 1
+R. Yungk, Operating Engineer, Unit 2
+R. A. Fussner, Staff Engineer, PWR Operations
+P. F. Hart, QA Engineer
+J. A. Jursenas, QA Engineer
+E, Steckhan, QA Engineer
+R. E. Benn, Assistant Security Administrator
+R. C. Herbert, Nuclear Safety
+S. C. Hunsader, Nuclear Licensing Administrator
@K. Boyle, Operations Staff
@R. Legner, Senior Operations Engineer
The inspectors also contacted and interviewed other licensee and
contractor personnel.
Nuclear Regulatory Commission
+E. G. Greenman, Director, Division of Reactor Projects, Region III
+W. L. Forney, Chief, Projects Branch 1, Region III
+J. M. Hinds, Jr., Chief, Projects Section 1A, Region III
@+T. M. Tongue, Senior Resident Inspector, Braidwood
- T. E. Taylor, Resident Inspector, Braidwood
@+R. D. Lanksbury, Operational Readiness Inspection Team Leader,
Region III
@+B. H. Little, Sennr Resident Inspector, Callaway
+P. G. Brochman, Sen!or Resident Inspector, Byron
+S. M. Hare, Reactor inspector, Region III
+5. P. Sands, Licensing Project Manager, Office of Nuclear Reactor
Regulation (NRR)
+W. B. Grant, Radiation Specialist, Region III
+W. J. Kropp, Reactor Inspector, Region III
+ Denotes those attending the interim exit meeting on February 19, 1988.
@ Denotes those attending the exit meeting on March 7, 1988.
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2.
General
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The Operational Readiness Inspection (0RI) was conducted in order to
help determine whether Commonwealth Edison Company should receive a
recommendation from Region III to operate Braidwood Unit 2 above 5%
reactor power.
Licensee activities were closely monitored in order to
ensure the facility was being operated safely and to ascertain the
licensee's readiness to operate at power levels up to 100%.
The
inspection included examination of the interface between the operations
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department and other on-site organizations to assess the effectiveness
of the entire station organization.
In June of 1987 an ORI was conducted for Braidwood Unit 1.
Because of
the broad scope of this ORI and the relatively short duration between it
and the Unit 2 ORI, certain areas, such as lines of responsibility, that
are common to both units and for which there was no indication of
significant changes, were not re-inspected.
The ORI team was comprised of the leader, a region based reactor
inspector; two Senior Resident Inspector (SRI's) from other operating
reactor facilities in Region III, the NRR licensing project manager for
Braidwood, two region based reactor inspectors, and one region based
radiation specialist.
3.
Plant Operations (36700, 71707, 71715)
An inspection of plant operations was performed by observing the
performance of the licensee's operating staff on all shifts with the
following objectives (it should be noted that during this inspection
neither Unit I nor Unit 2 was critical and therefore observation of
plant operation was constrained):
Determine adequacy of shift turnovers, attentiveness to indications,
communications between operators, awareness of plant status,
procedural compliance, control room congestion, completeness
and accuracy of logs, performance during abnormal conditions,
communications with other departments, independent verification
effectiveness, and the effectiveness and involvement of supervision
and management.
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Review workload of operating crew, especially staff assistants.
Determine quality of prioritizing the work that goes through the
operations group before scheduling.
Review folluwups to events, critiques of events, and LC0 Time Clocks
(who tracks, how, effectiveness).
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Evaluate communications between the Control Room personnel and
others, particularly during off normal events.
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The following observations were made:
a.
Adequacy of shift turnovers - The shift turnover process at
Braidwood may be subdivided into three distinct evolutions.
The
first part of the shift turnover was made possible by the oncoming
shift arriving an hour early, performing a panel walkdown, and
discussing with their individual counterparts the turnover checklist
and plant status.
The second part of shift turnover was the shift
briefing at which representatives from the oncoming operations,
maintenance, health physics, chemistry, and technical services staff
discuss plant status and planned activities for the upcoming shift.
The third and final portion of the shift turnover has the Shift
Engineer (SE), Shift Control Room Engineer (SCRE) and Center Desk
Operator brief the oncoming plant operators on plant status and
activities planned for the shift.
Shift turnover activities were monitored throughout the inspection
period for all of the day, swing and mid-shift turnovers.
The
inspector's noted that shift turnovers were professionally conducted
and sufficiently comprehensive in scope to ensure that the oncoming
shifts were aware of plant status and the activities planned for
that shift.
b.
Attentiveness to indications - Operators were alert and attentive
to panel instruments and alarms at all times.
All abnormal
instrumentation indication observed was adequately responded to,
with Work Requests (WR's) generated as appropriate,
c.
Awareness of plant status - With the exception of one instance,
all shifts appeared aware of plant status as demonstrated through
inspector observation and interviews with operators.
The inspectors
noted that when Unit 1 was in mode 4 and the Volume Control Tank (VCT)
was being "burped" to replace the nitrogen cover gas with hydrogen,
that the Unit 1 Nuclear Station Operator (NS0) appeared not to be
aware of the evolution.
The Unit NSO queryed the equipment attendant
who had just performed valve manipulations on a Reactor Coolant Pump
(RCP) filter / drain line as to whether he had left any valves open or
leaking.
The Unit NSO then directed the attendant to go back and
check the drain line for leakage.
The inspector questioned the
Unit NSO as to why he had urgently dispatched the attendant back
into the field.
The NSO indicated that the VCT had experienced a
rapid decrease in level which he believed was caused by a leak.
The inspector went to the VCT level / pressure strip chart recorder
and noted that the rapid VCT level decrease was caused by the
diversion of letdown to the Hold Up Tank.
The extra NSO on shift
who had been monitoring this evolution confirmed the inspector's
observations.
This event indicated the following:
(1) Shift management had not successfully communicated with the
Unit NSO.
(2) The Unit NSO was insuf ficiently aware of the plant's status to
know why the VCT level was dropping.
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(3) The extra NSO who was monitoring the process did not communicate
to the unit NSO why VCT level was dropping.
With the exception of this instance, all other shifts appeared aware
of plant status.
However, the ORI did note that interviews with
operations staff personnel indicated a general lack of confidence
in plant status do to the current system in place for Out-0f-Services
and Temporary Lif ts (these are further discussed in Section 3.k).
d.
Communications - Communications within the operating staff were
observed to be good with information flowing smoothly from the SE
and shift foremen (SF) to the SCRE to the licensed and non-licensed
operators.
Communications between departments during the shiftly
briefings also appeared to be good.
The only instance of poor
communication observed is described in paragraph C above.
e.
Control room congestion
The control room was not overly congested
during the inspection period even though Unit 2 was in mode three
while Unit 1 was attempting to come on line after an outage,
f.
Completeness and accuracy of logs - The SE, SF, SCRE, and NS0's logs
were reviewed for accuracy and thoroughness.
The following
deficiencies in log keeping were identified:
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(1) The NSO's log contained only infrequent notes (one) on when the
Boric Acid Transfer Pumps (BATPs) were run to recirculate the
Boric Acid Storage Tanks even thou0h the BATPs were run once
every several days.
(2) The NS0's logs did not identify that the Boric Acid recirculation
line was found plugged on February 18, 1988, which made
recirculation of boric acid from the tank impossible.
(3) The Unit 2 NSO log did not document the Unit 2 BATP failure of
a post-maintenance test even though the NS0 was contacted by the
personnel performing the test tn stop the pump due to it's
imminent failure.
(4) The Shif t Foreman who approved the temporary lif t to perform
the BATP post-maintenance test did not document the failure
which resulted in him not discussing pump failure during shift
turnover.
Additional deficiencies related to the accuracy and thoroughness of
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logs have also been identified by the Resident Inspectors. Additional
information pertaining to this item is contained in their inspection
report (456/88008(DRP); 457/88009(DRP)).
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g.
Performance during abnormal conditions - During this inspection
period two (2) instances were noted in which operator action was
taken in response to abnormal conditions.
(1) On February 18, 1988, on the mid shift, a Unit 2 source range
nuclear instrument, NI-31, was returned to service af ter
calibration per Bw!P 2504-003.
As a result of this instrument
being returned to service, a Boron Dilution Prevention System
actuation occurred due to several steps in the procedure being
out of order.
After diagnosis, the operators promptly took
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action to return the plant to its previous configuration which
required reestablishing normal letdown and switching the
suction of the charging pumps frem the Refueling Water Storage
The operators performance for this
event was good.
Actions were taken to generate a procedural
revision to reverse the subject procedural steps.
(2) On February 13, 1988, en the swing shift, an LC0 was entered
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on Unit 2 which required Unit 2 to reduce temperature and
change modes.
When normal makeup was initiated to maintain VCT
level, the operators noted no boric acid flow.
Per abnormal
procedure PRI-2, the operators attempted to establish normal
and emergency boric acid makeup. When this effort failed, the
NS0's dispatched plant operators to troubleshoot the problem.
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As a result of this troubleshooting effort, a boric acid flow
path was later established.
Operator action in response to
this event was considered good,
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b.
Workload of operating crews - Inspectors viewed workload as heavy
which is normal for a plant that is, in effect, starting up two
units at once.
While the workload was heavy, business was conducted
in an orderly fashion and, with the exception of the administrative
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aspects of the Temporary Lift program, the workload appeared well
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managed,
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Effectiveness and involvement of supervision and management -
Inspectors attended shif tly turnover meetings where plant status
and plans for the shift were discussed.
Management personr.el other
than the normal shif t complement were observed in the mid to day
shift and the day to swing shift turnovers.
Further, sentoc plant
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management was observed in the control room at least once during the
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day and swing shifts.
Conversations with shift personnel indicated
that station management was involved in plant operation in positive
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ways.
Based on inspector observations and personnel interviews, the
inspectors concluded that management involvement with plant operations
was comprehensive and effective,
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Event followup and evaluation - On February 18, 1988, at 1635 C$i,
the Unit 2 Nuclear Supervising Operator (NS0) attempted, but was
unable to initiate normal or emergency boration using the "0" Boric
Acid Transfer pump.
Subsequently, during a system walkdown, the
licensee found Valve 2AB8458 (miniflow recirculation valve) closed,
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Based on discussion with the Unit 2 NS0 and a review of the NSO
log, the inspector determined that the
"0" BATP pump had been
running in the recirculation mode when the NSO assumed the watch
(at approximately 1500 CST), and apparently had become steam bound.
There was no log entry on starting the "0" BATP in the recirculation
mode.
Additionally, after opening valve 2AB8458 and running the
"0" BATP pump, flow to the CVCS system was verified, but still no
recirculation flow was obtained.
The NSO expressed belief that the
recirculation line was plugged; however, the problem of the plugged
recirculation line was not entered in the NSO log, nor was a deviation
report initiated to document the deficient condition.
Administrative procedure BwAP 1250-2 (Deviation Reporting) defines a
deviation as:
"a departure from accepted equipment performance or a
failure to comply with administrative controls or NRC requirements
which results in, or could, if uncorrected, result in a failure of
an item to perform as required by Technical Specification or
approved procedures."
BwAP 1250-2 Paragraph 3 (Processing of Deviations) specifies that
the person identifying the deviation:
"Initiate a Deviation Report
(DVR) Form 15-52 1.
Enter as much applicable information as is
known on Part 1 of the DVR and forward the DVR to the Scpervisor
responsible for the equipment or activity."
The licensee's failure to initiate a deficiency report documenting
the plugged recirculation line is contrary to administrative
procedure BwAP 1250-2 and is a violation (457/88007-01/(ORS)) of
10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action,
k.
Equipment Control - The inspectors reviewed the licensee's equipment
control program to assess the overall system readiness for operation
and administrative controls associated with equipment / systems in an
"Out-Of-Service" (005) condition.
The licensee's 005 program was
described in procedure BwAP 330-1, Station Equipment Out-0f-Service
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Procedure, Revision 5 dated January 7, 1988.
In addition to reviewing
several 005 packages, a review of Temporary Lifts was also performed.
Temporary Litts are intended to allow testing of equipment following
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maintenance, but prior to clearing the 005.
As a result of this
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review, the inspectors determined that the licensee's 00S program
was not effective in that:
(1) Five of approximately 14 Temporary Lif t packages the were
in effect were reviewed and had been processed (005 tags removed)
without the specified documented authorization:
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(a) The Temporary Lift for the following 005 No.'s contained
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no documented authorization:
88-1-0048, 88-1-0049,
ILC-MS114 and MSXXX.
This was contrary to paragraph C.6.b.2.
of the subject procedure which required Shift Engineer
(or designee)/ Shift Foreman authorization on all Temporary
Lifts,
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(b) The Temporary Lif t for 00S No. 88-1-428, had been
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authorized by the Shift Foreman on February 9,1988,
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As of February 17, 1988, the specified Shif t Engineer's
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approval had not been documented.
This was contrary to
paragraph C.6 b.3. of the subject procedure which required
Shift Engineer approval on all Temporary Lifts which.
extend greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Subsequent to this, the inspectors reviewed completed Temporary
Lif t Forms for August, October, and December 1987.
Of the
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approximately 2000 forms reviewed, 20 (or approximately 1%)
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were missing the. required signatures.
The licensee's failure to follow the required approval
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requirements for the approval of Temporary Lift packages was
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an example of a Violation (457/88007-02A(DRS)) of 10 CFR Part 50,
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Appendix B, Criterion V requirements for following procedures.
(2) Of the 14 Temporary Lift records reviewed the following
examples were identified where Temporary Lif t instructions
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were not complied with:
(a) Temporary lift for 005 No. 88-1-42P specified that the
equipment was "To be returned to service on February 9,
1988." This action had not been performed as of
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February 17, 1988.
(b) Temporary Lift for 005 No. 88-2-0201 specified that:
"Leave
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Temp Lifted until RCS reaches 557*F, then rehang." Unit 2
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reactor coolant reached 557'F on February 16, 1988 and this
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action had not been peformed as of February 18, 1988,
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Procedure BwAP 330-1 was not appropriate to the circumstances
in that it failed to contain guidance describing the use of
instructions on Temporary Lifts.
The procedure also contained
no method to track instructions on Temporary Lif ts,
This was
considered an example of a Violation (457/88007-02B(DRS)) of
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10 CFR Part 50, Appendix B, Criterion V requirements for
appropriate procedures.
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(3) The status of mechanical and electrical equipment under
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Temporary Lift was not documented.
Unit I had approximately
100 Temporary Lift packages, each containing multiple tags,
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Unit 2 had 11 Temporary Lift packages.
Although several record
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sheets contained as left required component positions, most
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sheets did not.
The record sheets did not provide for the
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required component positions nor did the Temporary Lift
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procedure require such notations be entered.
The ORI team
noted that the absence of an as left required component
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position on the Temporary Lif t form was a weakness in the
licensees 00S program.
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(4) On January 10, 1988, 00S88-096 was completed and lifted.
This Equipment Outage identified valve 1AF009B as closed and
when the outage was liftad, valve 1AF009B was left in the closed
outage position.
When the Manual SI 18 month surveillance was
run on February 7, 1988, a valve lineup was not required by
procedure nor performed.
As a result, the Diesel Auxiliary
Feedwater AFW pump was operated with its recirculation valve
(1AF0098) closed.
The operation of the pump with its
recirculation valve closed resulted in failure of the pump.
This caused significant damage to the pump which required
extensive repair.
The restoration of the subject 005 was
inadequate to ensure the correct normal valve lineup.
Procedure BwAP 330-1, Section C.4.n., required that when
returning equipment to service, that all equipment listed on
the equipment outage form be returned to service.
The failure
to return valve 1AF0098 to service from its Out of Service
position was an example of a Violation (457/88007-02C(DRS))
of 10 CFR Part 50, Aopendix B, Criterion V requirements for
following procedures.
(5) A Temporary Lift was issued on February 17, 1988, for
00S 88-1-193 and 005 88-1-917 to test the repaired Diesel AFW
pump.
00S 88-1-193 removed the 4 control power fuses.
These
fuses were supposed to be replaced pet the Temporary Lift.
When a remote AFW pump start was atten.pted, the pump did not
start.
Licensee investigation revealed that 1 of the 4 control
power fuses installed was a "dummy fuse." This apparently had
been installed sometime after the original 00S was hung.
When
the 005 was temporarily lifted, the person who verified that
the fuses were installed, failed to recognize that the fuse
(which was not in the 00$ position) was a "dummy fuse."
Procedure BwAP 330-1, Section C.6.c., required that all equipment
listed on a Temporary Lif t be removed from its 00S position.
The failure to remove the "dummy fuse" and restore the fuse was
an example of a Violation (457/88007-020(DRS)) of 10 CFR Part 50,
Appendix B, Criterion V requirements for following procedures.
(6) 005 88-2-386 dated February 7, 1988, required the Unit 2 Boric
Acid Transfer Pump (BATP) recirculation, suction, and discharge
valves be closed to permit pump maintenance.
This 005 was
deficient in that it did not establish a recirculation flowpath
for the common BATP which served as a backup for the Unit 2 pump.
The following events occurred between the time the recirculation
valve was closed on February 7, 1988, to when it was discovered
closed on February 18, 1988.
(L) When the Unit 2 BATP was run on February 16th and again on
February 18th to recirculate the storage tank, there was no
flowpath.
On February 18th, the pump was discovered to be
inoperable (steam bound).
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(b) The normal and emergency boration flow paths from the
Boric Acid Storage Tank were inoperable when required on
February 18th.
(c) The miniflow recirculation line became clogged with boric
acid due to stagnant flow conditions.
(d) The Unit 2- BATP experienced mechanical seal failure on
February 17th, which could have been due, in.part, to the
recirculation flowpath being plugged and the resultant
lack of recirculation flow.
The failure of the licensee's 00S program to ensure the common
BATP nad a recirculation flowpath when the Unit 2 BATP was taken
005 for repair was an example of a Violation (457/88007-02E(DRS))
of 10 CFR Part 50, Appendix B, Criterion V requirements for
appropriate procedures.
The above implerrentation and program deficiencies were
discussed with the licensee during an interim exit meeting
on February 19, 1988.
The licensee acknowledged and was
responsive to the ORI team findings.
The licensee discussed
immediate action, taken and planned, to improve equipment
00S controls.
On March 7, 1988, a reinspection of the licensee's equipment
control program, procedures, and equipment was performed to
assess the overall effectiveness of corrective action in this
matter.
The inspection included the review of changes to plant
procedure BwAP-330-1 (Equipment Out of Service); a sampling of
four equipment 005 packages, a complete review of all active
Temporary Lift packages, and tracking reports for Degraded
Equipment and Limiting Conditions for Operation Action Report
(LOCAR).
In addition, a field inspection was porformed to
verify that plant valves and electrical controls were correctly
positioned as documented in the three safety-related Temporary
Lift packages in effect at the time of the inspection.
Revision 6, dated February 26, 1988, of procedure BwAP-330-1
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required double verification of breaker and valve position when
placing a system out of service and when restoring a system to
service.
The procedure and Temporary Lift record sheets provide
for "as left" positions of components in test.
The 00S and Temporary Lift packages reviewed contained
appropriate authorization.
After identification of the
instances of the licensee's failure to have the correct level
of authorization on a number of 005 Temporary Lif ts and th<s
failure to comply with instructions written on the 005 Temporary
Lifts, the licensee took immediate corrective actions.
This
included con * acting each of the Shift Engineers and reinforcing
their responsibility with regard to the 00S program.
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There had been a significant reduction in the number of active
Temporary Lift packages; e.g. Unit I was reduced to two (from
a previous level in excess of 100) and Unit 2 reduced to one
(from a previous level of 11).
There was one package for a
system common to both units.
The licensee's actions to improve
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equipment control appeared to be effective.
No deficiencies
were identified during reinspection in this area.
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1.
Effectiveness of plant tours - Inspectors accompanied non-licensed
J
operators on their rounds to assess their performance and knowledge
of plant conditions.
The non-licensed operators were knowledgeable
and effective in their areas of responsibility. A variety of
functions were observed, such as startup of various equipment. These
functions were well executed.
In general the quality of plant
walkthroughs was good,
m.
Procedure implementation and independent verification - The
implementation of portions of the following procedures were
witnessed in the control room and/or Shif t Engineer's office.
Bw0P-MS-5
MSIV Accumulator Operability Check
Bw0P-CD/CB
Condensate / Condensate Booster System
Checkout
BwSU-IC-70
Incore Flux Mapping System Checkout
BwlP 2504-003
Source Range Hi Flux at Shutdown Alarm
Calibration
Bw0P Wx-500-1.T.1
Liquid Release When Flowmeters are
Bw0P-199
Equipment Attendant Auxiliary Building
Logs
Bw0S 4.6.2.1.d-1
Reactor Coolant System Water Balance
BwAP 100-7
Overtime Guidelines for Personnel that
Perform Safety Related Functions
Procedure implementation and compliance by operations personnel
appeared good.
Independent verification was performed
satisfactorily when required,
n.
Technical Specification LC0's - The inspector reviewed the
documentation for all of the Technical Specification Limiting
Conditions for Operation which were in effect.
The Limiting
Condition for Operation Action Requirements (LOCAR) documents were
reviewed to verify that required signatures, notifications, and
compensatory surveillances had been completed.
The inspector
identified two discrepancies in the completion of LOCAR paperwork.
Licensed Senior Reactor Operator (SRO) reviews of compensatory
actions performed by the radiation / chemistry department were not
performed.
LOCAR Bw05 3.3.9-la required that with radiation monitor
ORE-PR010 inoperable, liquid releases could continue by monitoring
with grab samples and completing the log in Appendix A, data sheet 1.
The radiation / chemistry department had completed its portion of data
sheet 1, for the liquid effluent releases which had occurred since
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the monitor became inoperable on January 27, 1987; however, no SR0
review of these actions was indicated on the data sheet.
Similar
problems existed with LOCAR 18w05 3.3.10-la, data sheet 1, for oxygen
analyzer 0AT-GW004.
The review did not identify any instances where
required compensatory actions had not been performed, only that the
SRO reviews had not been completed.
However, the ORI considers that
the inconsistent supervisory review, by licensed SR0's, of the
adequacy and timeliness of compensatory actions taken in accordance
with Technical Specification action statements was a programmatic
weakness that should be addressed by the licensee.
Two violations were identified in this functional area
(paragraphs 3.j. and 3.k.).
No deviations were identified.
4.
Surveillance and Testing Observation (72302)
Station surveillance activities of the safety-related systems and
components listed below were observed / reviewed to ascertain that they
were conducted in accordance with approved procedures and in conformance
with Technical Specifications.
The following items were considered during this review:
the limiting
conditions for operation were met while affected components or systems
were removed from and restored to service; approvals were obtained prior
to initiating the testing; testing was accomplished in accordance with
approved procedures; test instrumentation was within its calibration
interval; testing was accomplished by qualified personnel; test results
conformed with Technical Specification and procedural requirements and
were reviewed by personnel other than the individual directing the test;
and any deficiencies identified during the testing were properly
documented, reviewed, and resolved by appropriate management personnel.
The inspection focused on the following areas:
Preparation; including adequacy of procedures, equipment,
pre-task briefings and task knowledge.
Performance discipline; including supervision and control, procedure
adherence, and communications.
Documentation and resolution of deficiencies.
Independent verification and review.
The following surveillance testing activities were observed / reviewed:
Procedure No,
Activity
Bw05 - 0.1, 2, 3
Daily Operating Surveillance.
Bwls - 3.1.1 - 303
AT/Tavg Analog Operational Test and Channel
Verification Calibration.
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BwIS - 3.3.6 - 205
Calibration of Reactor Vessel Level Indication
System RVLIS.
BwIS - 3.1.1 - 388
Pressurizer Pressure Protection Analog
Operational (P0-456).
Bw0S - 3.1.1 - 36.1
Intermediate Range NI Surveillance.
The inspectors determined that the licensee had implemented, appropriately
reviewed and approved procedures for the surveillance and testing
activities.
Special test equipment functioned well and instruments were
in current calibration.
Personnel involved in supervision and performance
of the tasks appeared well trained / knowledgeable of task objectives and
equipment operation.
Procedure review and pre-task briefings were
routinely performed.
The surveillance ano test procedures were generally
well written, containing appropriate precautions and notes.
The inspectors determined that control room supervision and operators
maintained adequate control over the surveillance and test activities.
Personnel performing the tasks demonstrated a high degree of performance
discipline and procedures were followed in a step-by-step method.
No violations or deviations were identified.
5.
Maintenance (62700,62703)
The inspectors reviewed selected maintenance activities to assess the
capabilities of the licensee's maintenance staff to maintain Unit 2
in an acceptable manner.
The areas assessed included:
Maintenance backlog
Maintenance testing
Completed Nuclear Work Requests (NWRs)
Staffing of the maintenance organization
Threshold for initiating NWRs
Preventive maintenance
Material condition
a.
With respect to backlog, the licensee reported corrective maintenance
backlog in the Braidwood Monthly Plant Status Report as those Nuclear
Work Requests (NWRs) outstanding, which were ready for work (outage
not required).
The inspector determined through discussion with the
licensee that there were also Construction Work Requests (CWRs)
outstanding pertaining to corrective maintenance.
These CWRs were
not being identified as backlog corrective maintenance in the
Braidwood Monthly Plant Status Report.
The licensee did not furnish
the number of corrective maintenance CWRs outstanding; however, the
inspector did ascertain that the backlog of corrective maintenance
documented on NWRs was 920.
These 920 NWRs were assigned ts follows:
175 - Unit 1
394 - Unit 2
351 - Unit 0
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The Preventive Maintenance (PM) backlog reported in the licensee's
Monthly Plant Status Report represented only those PMs pertaining to
the Technical Specifications.
Other backlog PMs, such as lubricatic-
and the calibration of plant instruments, were not reported in the
backlog population.
During this inspection the licensee furnished
the inspector with the PM backlog for these non-Technical
Specification PMs.
The PM backlog was as follows:
Instrument Calibration - 23 B0P past their critical due date.
Electrical Component inspection - 26 breakers or Motor Control
Centers.
Lubrication - 21 pieces of equipment past due.
The licensee had committed to furnish revised backlog information,
which would included those CWRs pertaining to corrective maintenance
and PMs, prior to the Unit 2 full power Commission meeting,
b.
The inspectors witnessed a maintenance test of the 18 Auxiliary
The diesel driven IB AFW pump failed to
start during this test.
Investigation by the licensee determined
that fuses in the 18 AFW local control panel were not re-installed
during the Temporary Left of the Out-of-Service.
This event is
further discussed in Paragraph 3 k.5 of this report.
c.
The inspectors reviewed twenty completed NWRs which were located in
the Central Files.
The packages reviewed were:
A11892, A11896,
A17102, A13004, A17244, A18764, A11903, A17185, A05524, A10717,
A17831, A17403, A19406, A17115, A16174, A12101, A12082, A18584,
A17116, and A12229.
Final review of these packages had been
performed by maintenance, QA and QC.
The appropriate review
signature was noted and the documentation associated with each
package appeared adequate.
No significant problems were noted
involving plant hardware.
d.
The inspectors reviewed the maintenance organization charts furnished
by the licensee.
The staffing levels apper. red adequate to perform
required maintenance activities.
The maintenance department was
divided into three disciplines:
electrical, mechanical and
instrumentation.
Each discipline was headed by a supervisor.
The
planning of maintenance activities was performed by the Station
Startup/ Work Planning organization.
This organization had work
planners for continuous work and outage work planners for the
planning of outage activities.
e.
The licensee threshold for placing equipment problems on NWRs was
evaluated for adequacy.
The inspector reviewed the control room
logs for Unit 1 and Unit 2 and selected three Unit 1 log entries
and seven Unit 2 log entries which fndicated potential equipment
problems.
In each case, the licensee had initiated an NWR to
resolve the problem or had addressed the problem in an acceptable
manner.
Therefore, the licensee's threshold for placing equipment
problems on NWRs appeared to be adequate to maintain the material
condit'on of the plant.
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f.
The inspectors reviewed the licensee's preventive maintenance (PM)
program.
The PM program consisted of various activities such as:
iubrications, vibrations analysis, instrument calibration, heat
exchanger nondestructive testing, etc.
These activities were
controlled by various computer programs which currently do not
interface with each other.
As a result, the inspector required
significant plant staff assistance in assessing the PM backlog.
The licensee stated action had already been initiated to allow
easier retrievability by computer of the status of PMs.
During the plant walkdown by the inspectors, the lower motor bearing
sightglass for both the 2A and 28 Residual Heat Removal (RHR) pump
motors had oil which appeared to need changing.
A review of the
computer printout for lubrications indicated that the initial entry
for the RHR pump motors was January 4,1988, with a due date of
January 4, 1989 (12 month frequency).
A review of construction
records determined that both the 2A and 2B RHR pumps had been run
since April 1987 at various times during Unit 2 preoperational
testing.
Therefore, it appears that the due date of January 4,1989,
was established based on the initial entry of the RHR pump motors
into the lubrication program and not based on a technical assessment.
It appears that the due date would more appropriately have been
April 1988, based on the run history of the RHR pumps.
The issue
of scheduling of the lubrication of equipment / components is considered
an open item pending further NRC review (453/88007-03(DRS)).
g.
The inspectors performed a walkdown of portions of Unit 2 to
evaluate the material condition of the plant.
With the exception
of several minor instances, the inspectors did not identify any
equipment problems that had not already been identified by the
licensee.
However, the inspectors did identify two cases were
maintenance activities resulted in the following:
A debris screen from the 28 diesel AFW pump fan intake had been
removed and stored against an instrument rack in the 28 AFW pump
room.
This action could have potentially resulted in damage to
the installed instrumentation and inadvertent mispositioning of
an instrument valve.
Since Unit 2 was in Mode 3 the 2B AFW
pump was required to be operable.
The licensee took immediate
corrective action to properly store the debris screen.
The 2A motor driven AFW pump had various materials, such as
coats, extension cords, and tools, laying on the motor.
At
the same time there were maintenance activities being performed
'
in the adjacent 1A AFW pump area.
The 2A AFW pump was required
to be operational.
The licensee took immediate corrective
action to remove this material.
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In summary, the inspectors concluded that the licensee's maintenance
activities were performed adequately to support a Unit 2 full power
1; cense.
However, the licensee needed to improve on their statusing
of maintenance backlog.
Also, the licensee should increase the
awareness of their equipment operators on the need to ensure
maintenance activities do not affect the operability of equipment
in areas where maintenance is being performed.
One open item was identified in this functional area (paragraph 5 f).
No violations or deviations were identified.
6.
Radiation Protection (83722, 83724, 83725, 83726, 83728)
The inspector met with various members of the radiation chemistry
(Rad / Chem) staff, including:
the Rad / Chem Supervisor, the lead Health
Physics Foreman, a staff Health Physicist (HP), and various Rad / Chem
technicians (RCTs).
A number of licensee strengths within this functional area were identified
during the inspection, including:
RCTs appeared to be knowledgeable of plant systems and procedures,
and of their responsibilities.
In order to support the simultaneous startup and startup testing of
Unit 1 and Unit 2, the licensee has contracted for the services of
32 RCTs in addition to their normal staff.
No significant Radiation Occurrence Reports (R0'S) were generated
for 1987 or January of 1988.
The inspector witnessed the changing of the reactor coolant filter for
Unit 1.
The reactor coolant filter had a contact reading of 300 Rad /hr.
Prior to the filter change several work group discussions were conducted
and an ALARA planning meeting was held.
The inspector observed that the
exchange of information during the course of these meetings appeared good.
The changing of the reactor coolant filter was completed without problem.
The ORI conducted in June 1987 for Unit 1 made three observations in this
functional area.
The inspector reviewed the licensee's actions for these
three observations.
Audible speakers on GM survey meters used at the 401' Auxiliary
Building to Turbine Building door and the 426' Containment entryway
could not be heard by the surveyors because the background noise level
was too high.
During this inspection the inspector verified that the
licensee had purchased kits for the installation of earphones on
several GM survey meters.
At the time of this ORI the installation
of these earphones was in process.
Rad / Chem surveys of the laundry room were done with a "Cutie Pie"
(a relatively high range instrument).
During the inspection the
inspector verified that the licensee was now using GM survey meters
(a lower range instrument than the "Cutie Pie") for performing
surveys of the laundry room.
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d
,e
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RCT workhours exceeded the guidelines of NRC Generic Letter 82-12
which limit the working hours of Unit Staff who perform safety-related
functions.
The inspector reviewed records of hours worked by RCTs
for the period of January 19 throagh February 1,1988, and found the
situation continuing; 15 RCTs (almost half of the total member of
licensee RCTs) appeared to have worked hours in excess of those
specified in Generic Letter 82-12.
This finding was consistent with
the previous ORI's finding. The licensee's position is that only the
one Duty RCT required as part of the Technical Specification for
minimum shift manning was required to comply with the Generic Letter 82-12 working-hour limitation.
This position does not appear
to meet the intent of Technical Specification 6.2.2.e. in that the
Generic Letter 82-12 working-hour restrictions are clearly applicable
to "the unit staff whc perform safety - related functions," not merely
the minimum shift manning.
An additional question is raised, however,
in that the Generic Letter 82-12 restrictions appear to apply only
to unit staff who perform safety-related functions, a distinction
which may exempt certain RCTs.
This matter has been submitted to
NRR for clarification; further action to resolve this matter will be
held in abeyance pending that clarification.
This issue is considered
to be an unresolved item (453/88007-04(DRS)).
One unresolved item was identified (paragraph 6).
No violations or
deviations were identified.
7.
Station Chemistry (79501)
The inspector met with the Station Chemist and conducted a tour of the
Chemistry Laboratory f acilities.
General housekeeping was excellent and
all equipment was operational.
RWP 88001 covers activities in the hot
laboratory and counting room.
Step off pads and friskers were located
at the entrances.
Lines of responsibility are defined and no interface /
communication problems between Chemistry and other departments were
identified.
The Rad / Chem Supervisor attends the Plan of the Day (P00)
reeting, and in his absence, either the Station Health Physicist or
the Station Chemist attends.
A Chemist attends each shift briefing.
Both the primary and secondary chemistry were within specifications during
this inspection.
The chemistry departnent implemented a monthly chemistry
report which was submitted to the assistant Superintendent, Operations.
The inspector reviewed the December 1988 monthly chemistry report, which
included Unit 2 chemistry and found the following:
Primary
During the month of December, the Unit 2 reactor coolant system was
borated to 32000 ppm boron for fuel load.
The RCS core load chemistry
test, PS-70, was performed successfully to ensure the RC, RH, CV, SI,
CS, AB, and FC systems contained the proper concentration of boron to
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support fuel load.
For December, the RCS boron and chloride average
concentrations were 2073 ppm and 20 ppb, respectively.
There was no
detectable fluoride concentration for the RCS during December.
The
28 CV mixed ' ed demineralizer was borated to 2000 ppm boron while
o
the 2A demineralizer ramained unborated.
Lithium hydroxide was
added and increased the RCS pH from 5.1 to 5.95 in order to reduce
the rate of corrosion.
Secondary
The Unit 2 steam generators were placed in dry lay up in December.
The main condenser was accidentally filled to 15 feet with CST water.
The water specific conductivity was 22 umhos/cm.
Two-thirds of the
water was drained to the wastewater treatment system and the final
third was being cleaned up via a temporary demineralizer (Ecolochem)
and will be utilized to fill, vent and flush the condensate and
feedwater systems.
Once the system flushes are completed and the
water is verified to meet initial condensate specifications, the
temporary demineralizers will be removed from service and hydrazine
and ammonium hydroxide will be added for lay up chemistry.
Region III has one open item regarding operability of the secondary
sampling panel for Unit 2.
The inspector verified the operation of
the sampling panel with a chemistry engineering assistant,
No problems
were noted.
This item will be closed in the resident inspectors monthly
report (456/88008; 457/88009).
No violations or deviations were identified.
8.
Nuclear Engineers Activities (71707, 72302)
The performance of startup test procedure BwSU IT-73, "Incore Thermocouple
(Core Exit Thermocouple (CET))," Revision 0, Section 9.4. was witnessed.
The inspector determined that the Nuclear Engineers who were directing
the test were knowledgeable of testing in progress and that their interface
with the operations staff was good.
Activities appeared well-controlled.
Special test equipment functioned well and instruments were in current
calibration.
Personnel involved in supervision and performance of the
test appeared well trained / knowledgeable of test objectives and equipment
operation.
Personnel performing the test demonstrated a high degree of
performance discipline and the procedures were followed in a step-by-step
method.
Communications involving approval, instruction, and status were
conducted in a business-like manner,
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No violations or deviation were identified.
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9.
Training (41400)
The effectiveness of training programs for licensed and non-licensed
personnel was observed by the inspectors during the witnessing of the
licensee's performance of routine surveillance, maintenance, and
operational activities.
Except for weaknesses in the implementation
of the Out of Service program identified in the section on operations,
the station staff performed in a highly trained and motivated fashion.
Licensed and non-licensed operators were knowledgeable of the plant
equipment.
Mechanical, electrical, and instrumentation and control
technicians were observed at their tasks and performed their duties with
skill.
In other departments, employees also performed in such a way as
to demonstrate effective training programs.
No violations or deviations were identified.
10.
Exit Interview (30703)
The ORI met with the licensee representatives denoted in Paragraph 1
during the inspection and again on February 19, 1988.
The ORI summarized
the scope and findings of the inspection activities and highlighted the
need for management attention in the areas discussed in the previous
paragraphs.
The ORI further noted that primarily because of the problem
observed with 005's and Temporary Lifts, and the fact that the operations
staff did not feel confident of plant status as a result of the current
system in these areas, that a recommendation for a full power license could
not be made at that time.
The licensee acknowledged the inspection findings
and stated that programmatic changes in the area of 005's and Temporary
Lifts were already being planned and would be implemented in the relatively
near future.
Members of the ORI again met with the licensee representatives denoted
in Paragraph 1 at the conclusion of the inspection on March 7, 1988.
The ORI summsrized the findings of the inspection activities since the
previous meeting on February 19, 1988.
The ORI noted that the licensee
had been very responsive in taking action to correct the previously
identified issues in the 005 area.
As a result, the opcrations staff
was no longer burdened with an excessive workload in the 00S area and
that they now felt confident about their knowledge of plant status.
As a
result of the above changes, the ORI indicated that they would recommend
to the region the issuance of a full power license.
The inspectors also discussed the likely informational content of the
inspection report with regard to documents or processes reviewed by the
inspectors during the inspection.
The licensee did not identify any such
documents / process as proprietary.
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