ML20195G373
| ML20195G373 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 11/17/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20195G364 | List: |
| References | |
| 50-456-98-14, 50-457-98-14, NUDOCS 9811200280 | |
| Download: ML20195G373 (20) | |
See also: IR 05000456/1998014
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U.S. NUCLEAR REGULATORY COMMISSION
REGIONlil l
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Docket Nos: 50-456, 50-457 I
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Report No: 50-456/98014(DRP); 50-457/98014(DRP)
uonsee: Commonwealth Edison Company
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Facility: Braidwood Nuclear Plant, Units 1 and 2
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' Location: RR #1, Box 84 l
Braceville,IL 60407 1
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- Dates
- September 9 through October 19,1998
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Inspectors:
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C. Phillips, Senior Resident inspector
J. Adams, Resident inspector
D. Pelton, Resident inspector ,
Approved by: Michael J. Jordan, Chief
Reactor Projects Branch 3
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9811200280 981117 s
, PDR ADOCK 05000456 &
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EXECUTIVE SUMMARY
Braidwood Nuclear Plant, Units 1 and 2
NRC Inspection Report 50-456/98014(DRP); 50-457/98014(DRP)
This inspection included aspects of licensee operations, maintenance, and engineering. The
report covers a 6-week period of resident inspection from September 9 through
October 19,1998.
Operations
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The shift managers, unit supervisors, and nuclear station operators routinely performed
good turnover briefings, pre-job briefings, control board operations, control of evolutions,
response to alarms, communications, direction of personnel, and control of work l
evolutions. However, unclear communications occurred between the control room
operators and a field operator during a pre-job brief, and control room operators failed to
recognize an illuminated annunciator alarm warning that the 18 emergency diesel
generator would not start. This resulted in preventing the automatic start of the
1B emergency diesel generator during sequencer surveillance test. (Section 01.1)
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The licensee identified at least eight recent configuration control errors consisting of ,
operator manipulation errors and inadequate OOS boundaries. Licensee corrective l
actions were extensive, but have not yet been effective. The majority of the problems
were the result of personnel errors. These errors had the potential to endanger
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personnel and equipment. The failure to arrest this trend has the potential to adversely
affect safety-related equipment in the future. A non-cited violation was issued for the
failure to follow procedures. (Section 04.1) i
Maintenance
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The prompt response by operators and maintenance personnel to a failure of a freeze
seal which isolated the 1 A auxiliary feedwater pump essential service water supply valve
limited flooding te, about 6000 gallons of water. The prompt response was attributed to
pre-planned licensee contingency actions and prevented additional equipment damage.
The licensee's root cause investigation identified several lessons-learned, which were
incorporated into the maintenance freeze seal procedure. The inspectors verified that
the licensee followed the previously existing maintenance freeze seal procedure.
(Section M1.1)
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The inspectors observed good Foreign Material Exclusion (FME) controls during
maintenance activities. During the inspection period, the licensee demonstrated a good
safety focus by identifying and taking appropriate corrective actions for a potential
increasing trend in the number of FME problems. (Section M1.2)
- The inspectors observed all or portions of 14 maintenance activities. The maintenance
activities were performed in accordance with the applicable procedures, which provided
the requisite information necessary to perform the work. Maintenance personnel
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demonstrated good general work practices and were knowledgeable of the associated
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Technical Specification limiting conditions for operation and high-risk work activity
requirements. '(Section M1.3)
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The inspectors observed the performance of all or portions of ten surveillance tests in
accordance with the Technical Specification and Updated Final Safety Analysis Report.
The surveillance tests adequately tested the systems. However, the inspectors
identified two minor administrative errors for the acceptance criteria in the emergency
diesel generator surveillance test procedures.- (Section M1.4)
Enaineerina
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Modifications were properly prepared, initiated, and documented on the Unit 1
condensate storage tank. Work was performed in a safe manner, and nondestructive ,
testing was properly performed and evaluated. (Section E1.1) -
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The inspectors identified the licensee did not test the control room ventilation system
design function to realign on the detection of smoke in the exhaust plenum as described
in UFSAR Section 6.4. The inspectors verified the testing of the control room ventilation
system met Technical Specification requirements. Licensee management stated the
control room ventilation system function to realign on the detection of smoke in the
exhaust plenum would be tested in the future. Currently, the control room operators 1
also have the ability to manually realign the control room ventilation system if necessary.
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Further review by the NRC is needed to determine if any enforcement is warranted on ,
this issue. An unresolved item was issued. (Section E1.2)
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The licensee failed to implement measures to determine the cause, and take
comprehensive and effective corrective action to preclude repetition of bolts being found
loose on two emergency diesel generator lubricating oil heat exchanger end bells
following the identification on July 10 and 12,1998. On August 18,1998, the inspectors
observed two similar problems with loose bolts on the 2A and 2B emergency diesel
generators lubricating oil heat exchanger end bells. Since August 18, the licensee's
efforts to identify and correct the causes for loose heat exchanger bolting were
aggressive and comprehensive. The inspectors concluded that identified corrective
actions should prevent recurrence of the problem with the loose bolts. A notice of
violation was issued for failure to initiate an investigation to determine the cause of a
condition adverse to quality until identified by the inspectors. (Section E2.1)
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Report Details
Summary of Plant Status
Unit 1 was shutdown for refueling outage A1R07 for the entire period. Unit 2 remained at or
near full power for the entire period,
l. Operations
- 01 - Conduct of Operations
01.1 Control Room Observation
a. Inspection Scooe (71707)
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The inspectors observed the conduct of operation during normal operating conditions,
shutdown conditions, refueling operations, and surveillance tests. The i, ;;;?ctors ,
interviewed nuclear station operators, unit supervisors, shift managers, and test i
directors,
b. ' Observations and Findinas
The inspectors observed control room operators throughout the inspection period. The
inspectors noted that the nuclear station operators were attentive, properly used
operating procedures, utilized self-checks when manipulating equipment, and used
three-way communications. The nuclear station operators promptly addressed alarms, -
referred to the annunciator response procedures, and promptly informed supervisors of
alarms. However, on October 10, while performing the 1B emergency diesel generator
emergency core cooling system sequencer surveillance test, the 1B emergency diesel
generator failed to start when bus 142 was de-energized. The licensee determined that
the diesel mode selector switch on the local control panel was not properly positioned
due to unclear communication between the control room operators and the field
operator during the pre-job brief. Additionally, an illuminated annunciator that indicated
the diesel mode selector switch was not correctly positioned for an automatic start was
not recognized by the control room operators. This is also discussed in setion O4.1 and
listed in Section M1.4.
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The inspectors attended the operations department shift turnover, pre-job briefings, and
heightened level of awareness briefings. The inspectors noted that the personnel
conducting the briefings were knowledgeable, major work activities were described,
limiting condition for operations (LCOs) were reviewed, communication methods were
discussed, contingency actions wem specified, and individual responsibilities were ]
. assigned. l
-The inspectors noted that the unit supervisors demonstrated good command and !
control. The inspectors observed unit supervisors perform tumovers with the other unit
supervisor and announce to control room personnel changes in control room command
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and control responsibilities prior to leaving the control room. The inspectors observed
that unit supervisors worked closely with test directors during the performance of
surveillance tests for which a test director had been assigned,
c. Conclusions
The shift managers, unit supervisors, and nuclear station operators routinely performed
i good turnover briefings, pre-job briefings, control board operations, control of evolutions,
response to alarms, communications, direction of personnel, and control of work
evolutions. However, unclear communications occurred between the control room
operators and a field operator during a pre-job brief, and control room operators failed to
recognize an illuminated annunciator alarm warning that the 1B emergency diesel
l generator would not start. This resulted in preventing the automatic start of the
l 1B emergency diesel generator during sequencer sunteillance test.
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04 Operator Knowledge and Performance
i 04.1 Continued Confiouration Control Problems
a. Inspection Scope (71707)
The inspectors interviewed station management and operators to evaluate the reasons
behind and corrective actions for the most recent configuration control errors.
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l b. Observations and Findinas
l During this inspection period there were numerous configuration control problems, most
j involving the out-of-service (OOS) process . The inspectors categorized the problems
j into two areas. The first was operator errors involving the manipulation of the
equipment. The second were errors involving failures to establish adequate boundaries
for the work to be performed.
Between August 17,1998, and October 10,1998, the licensee identified that non-
licensed operators made five errors manipulating plant equipaent. Three of thuse
j errors were OOS cards placed on the wrong equipment. In addition, there were three
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instances of inadequate OOS boundaries established. The inspectors interviewed
operators involved with several of the configuration control errors. The operators were
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aware of management expectations regarding placing OOS cards and performing
l procedural steps. The operators all made assumptions in the field that were incorrect
l without making the proper verifications. There was no procedural guidance on how to
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place an OOS card. The proper method for placing OOS cards was a management
expectation. The operators interviewed had an excellent understanding of the correct
method for hanging an OOS card. A maintenance verification of the OOS prior to the
start of work was part of the OOS procedure. The OOS errors were identified either
durMg the maintenance verification or by the non-licensed operators. Therefore, there
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were no procedure violations identified in the failure to properly place the OOS cards.
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The inadequate OOS boundaries were on non-safety related equipment or on
equipment not required operable for the existing mode of operations.
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l However, one of the operator errors occurred during the restoration from a localleak
rate test. The non-licensed operator directing the test gave direction to the control room
to open an isolation valve before the vent valves were closed in violation of the
procedure. This resulted in spilling about 100 gallons of water in the Unit 1 auxiliary
l building. In addition the control room operator did not have a copy of the local leak rate
l test procedure available which was in violation of a station administrative procedure.
Technical Specification 6.8.1.a states, in part, that written procedures shall be
established, implemented, and maintained covering the applicable procedures l
, recommended in Appendix A, of Regulatory Guide 1.33, Revision 2, February 1978. ,
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Regulatory Guide 1.33, Revision 2, Appendix A, Section 1.d, requires administrative
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procedures for procedure adherence; and Section 8.b.1.a requires procedures for
containment leak rate tests.
BwAP 100-20, " Procedure Use And Adherence," Revision 9, Step D.8.c.4, states, in
part, that each step of a continuous use procedure must be performed as written, in the
order written. Step D.8.a.4, states, in part, that when more than one individual is
performing steps in a procedure at different locations, individuals at each location should
i have a copy of the procedure to follow and refer to as the activity proceeds.
Contrary to the above, on October 8,1998, an operator in the control room failed to
l perform continuous use procedure 18wOSR 3.6.1.1-22, " Primary Containment Type C
! Local Leakage Rate Test Of Safety injection System," Revision 0, Steps 2.39 and 2.40,
in the order written. Step 2.40 was performed by operators in the control room before
l the completion of Step 2.39 by non-licensed operators in the Unit 1 auxiliary building
i curved wall area. In addition, the control room operator did not have a copy of
l 1BwOSR 3.6.1.1-22 available to follow and refer to while performing these steps.
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The licensee temporarily suspended all local leak rate tests and the non-licensed
operator directing the local leak rate test was temporarily relieved of all field work. The
local leak rate test supervisor and all operators assigned to the local leak rate team met
and discussed this incident and current Braidwood operating standards. The localleak
rate team supervisor was made responsible for ensuring that the control room operators
j have a copy of the local leak rate procedure before the start of the test.
This non-repetitive, licensee-identified and corrected violation is being treated as a
non-cited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy
(50-456/98014-01(DRP); 50-457/98014-01(DRP)).
The inspectors met with senior station management regarding the configuration control
errors. The licensee had initiated many corrective actions including procedure
guidance, training, second verification of all OOSs, and where necessary personnel
discipline. In addition, operations managers and supervisors were called in for a
l special meeting to discuss the problems with configuration control. Station
! management perspective was that the OOS process was sound and that current
- problems were related to personnel performance issues.
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- c. Conclusions
- The licensee identified at least eight recent configuratiori control errors consisting of 4
. operator manipulation errors and inadequate OOS boundaries. Licensee corrective
actions were extensive but have not yet been effective. The majority of the problems l
were the result of personnel errors. These errors had the potential to endanger
personnel and equipment. The failure to arrest this trend has the potential to adversely -i
affect safety-related equipment in the future. - A non-cited violation was issued for the 1
failure to follow procedures.
07 Quality Assurance.in Operations
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07.1 Strateoic Reform initiative Number 4 'Alian and intearate Resources" l
a. inspection Scoce'(71707)
The inspectors reviewed the implementation of the Nuclear Generation Group Strategic
Reform initiative Number 4 at Braidwood. The strategic reform initiatives were outlined
in a February 17,1998, letter from Comed (Kingsley) to the NRC (Callan). The
inspectors selected Action Step Number 4 to review, which dealt with incorporating peer
group initiatives into the Site Wide Integrated Operational Plan. '
b. Observations and Findinas
The inspectors reviewed the list of initiatives generated by the Peer Groups and
approved by the Nuclear Generating Group. The only items that were included in the
Site Wide Integrated Operational Plan were those considered by station management to
be resource intensive. Other items were tracked in the licensee's nuclear tracking ;
system data base. The licensee was making good progress toward completion of the .j
initiatives. j
c. Conclusions
Select, resource intensive, Peer Group initiatives approved by the Nuclear Generating j
Group were verified to be included into the Site Wide Integrated Operational Plan in
accordance with Strategic Reform Initiative Action Step Number 4. Other Peer Group i
initiatives were tracked in the licensee's nuclear tracking system with good progress
toward completion.
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11. Maintenance
M1 Conduct of Maintenance
M1.1 Lost Freeze Seal on the Essential Service Water Sucolv to the1 A Auxiliary Feedwater
Pumo
a. Inspection Scope (62707)
The inspectors responded to a loss of a freeze seal for the removal of the 1 A auxiliary !
feedwater pump essential service (SX) water supply valve 1 AF017A. The inspectors :
interviewed the maintenance personnel responsible for the freeze seal and the
ope;ators that responded to the event. The inspectors reviewed Problem Identification
Form (PlF) A1998-03316 and its associated prompt investigation report; Braidwood
Maintenance Procedure (BwMP) 3300-18, " Application of Liquid Nitrogen Freeze Seal to I
All Piping," Revisions 7 and 8; BwMP 3300-18, Attachment Two, " Freeze Seal Log"; and l
BwMP 3300-18, Attachment Three," Contingency Actions."
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b. Observations and Findinas !
On September 21, a freeze seal isolating the SX water to the 1 A auxiliary feedwater
pump SX water supply valve,1 AF017A, failed releasing approximately 6000 gallons of
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SX water to the auxiliary building. The Unit i nuclear station operator told the
inspectors that the control room operators were notified immediately of the loss of the
freeze seal. The unit supervisor directed equipment operators to implement
pre-planned contingency actions. The contingency actions were completed effectively
within five minutes of the start of the event. The inspectors were told that the
contingency actions were discussed in detail during the pre-job brief for the
maintenance activity and field operators had possession of the keys necessary to unlock
the valves identified for closure by the contingency actions.
The inspectors walked down the associated section of the piping following the event.
The inspectors noted that sufficient liquid nitrogen was available for the freeze seal, the
freeze seal tamperature log was maintained, the freeze seal jacket and temperature
monitors were properly installed on the pipe, and the freeze seal temperatures were
below the maximum allowable temperature. The inspectors verified that a copy of the
freeze seal procedure was at the work site, that the freeze seal procedure
BwMP 3300-18 was followed, that no spread of contamination occurred as a result of
the flooding, and that no equipment was rendered inoperable due to water intrusion.
The licensee performed a prompt investigation of the loss of the freeze seal and
identified an apparent cause and severallessons learned. The licensee suspects that
the silt and water mixture in the line may have affected the integrity of the seal. The
licensee identified several lessons learned from their review of the event which were
incorporated into the freeze seal procedure BwMP 3300-18. The inspectors attended a
subsequent pre-job brief for an SX water freeze seal and noted that the lessons-learned
were incorporated in the briefing.
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c. Conclusions l
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The prompt response by operators and maintenance personnel to a failure of a freeze
seal which isolated the 1A auxiliary feedwater pump SX water supply valve limited
flooding to about 6000 gallons of water. The prompt response was attributed to pre-
planned licensee contingency actions and prevented additional equipment damage.
The licensee's root cause investigation identified several lessons-learned which were
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incorporated into the maintenance freeze seal procedure. The inspectors verified that
the licensee followed the previously existing maintenance freeze seal procedure.
M1.2 Foreian Material Exclusion Problems,
a. Insoection Scope (62707)
The inspectors observed the foreign material exclusion (FME) controls implemented and
used during the performance of maintenance activities. The inspectors reviewed PIFs
issued to address FME issues and interviewed operations and maintenance personnel.
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b. Observations and Findinas
The inspectors observed good FME controls utilized throughout the plant. The
inspectors also noted that areas requiring heightened levels of FME controls such as the
spent fuel pit area or the refueling cavity were properly controlled. Between
. September 19 and October 4, the licensee identified eight FME issues. The licensee
initiated a PIF to investigate a potential trend in FME problems, but later determined
there was not a trend. However, communication sessions with both licensee and
contractor personnel were held to raise awareness concerning FME controls.
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c c. Conclusions
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The inspectors observed good FME controls during maintenance activities. During the
inspection period, the licensee demonstrated a good safety focus by identifying and
taking appropriate corrective action for a potential increasing trend in the number of
FME problems.
M1.3 Maintenance Activity Observations
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a.' inspection Scope (62707)
- . The inspectors observed all or portions of the following maintenance activities
- .1 A centrifugal charging pump gear drive unit oil spray valve replacement in
accordance with work request (WR) 970086904-01;
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- Installation of SX system line stop prior to/during A1RO7 in accordance with
e WR 980003392-01;
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Replacement of the 1A SX pumo discharge valve in accordance with I
- WR 980003298-01' I
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Electrical inspection of motor operated safety injection valve 1S18813 in l
accordance with WR 970133749-08;
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Reinstallation and torquing of the 1 A SX pump discharge check valve in
accordance with WR 980091882-02;
Troubleshooting of the Unit 2 rod control system in accordance with
WR 980000439-01;
18 month inspections of the 1 A emergency diesel generator in accordance with
WR 970051160-01;
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Installation of the 1A emergency diesel generator governor modification in
accordance with WR 960061285;
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Installation of the 1 A emergency diesel generator fuel oil filter / strainer
modification in accordance with WR 970011809; I
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Installation of the 1B emergency diesel generator fuel oil filter / strainer
modification in accordance with WR 970010950-01;
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Installation of the 1B emergency diesel generator governor modification in
accordance with WR 960061289;
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18 month inspections of the 1B emergency diesel generator in accordance with
WR 970030021-01;
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Replacement of the 125 volt DC 1E battery 111 in accordance with
WR 980002678-01; and
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Replacement of the 125 volt DC 1E battery 112 in accordance with
WR 980002680-01,
b. Observations and Findinas
The inspectors attended the heightened-level-of-awareness briefings; reviewed all or
portions of the above work packages; reviewed high-risk work check sheets, if
, applicable; walked down the work areas with maintenance personnel; questioned
personnel concerning the scope of the work, including system status, and precautions
for electrical safety; observed the establishment of required system conditions; observed
the use of FME controls; reviewed applicable welding procedures and " hot work"
permits; and observed the use of quality control" hold points." The inspectors also
l reviewed the associated Technical Specification LCO, if applicable, and reviewed the
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control room logs for LCO entries and exits. The inspectors noted no problems during
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the above reviews, interviews and observations.
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l c. Conclusions
The inspectors observed all or portions of 14 maintenance activities. The maintenance
activities were performed in accordance with the applicable procedures, which provided
the requisite information necessary to perform the work. Maintenance personnel
demonstrated good general work practices and were knowledgeable of the associated
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- Technical Specification limiting conditions for operation and high-risk work activity '
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requirements.
l M1.4 Miscellaneous Surveillance Test Observation
a. Insoection Scope (61726)
The inspectors observed all or portions of the following surveillance activities:
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Unit 1, Braidwood Engineering Surveillance Procedure (1BwVSR) 3.8.4.7-111,
" Unit One 125 Volt ESF (Engineered Safety Feature] Battery Bank 111 Service
Test," Revision 0;
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18wVSR 3.8.4.7-112, " Unit One 125 Volt ESF Battery Bank 112 Service Test," l
Revision 0; l
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1BwVSR 384-2, " Unit One 125 Volt ESF Battery Charger 112 Setpoint and
Alarm Test," Revision 0;
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1BwVSR 8.1.1.2.f-13, "1 A Emergency Diesel Generator ECCS [ Emergency Core
Cooling Systems] Sequencer Surveillance " Revision 10; I
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1BwVSR 8.1.1.2.f-15, "1 A Emergency Diesel Generator Loss of ESF Bus
Voltage With No SI [ Safety injection) Signal," Revision 8; '
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1BwVSR 8.1.1.2.f-21, "1 A Emergency Diesel Generator 24 Hour Endurance Run
and Hot Restart Test 18 Month," Revision 2;
- 18wVSR 8.1.1.2.f-14, "1B Emergency Diesel Generator ECCS Sequencer
Surveillance," Revision 10;
18wVSR 8.1.1.2.f-22, "1B Emergency Diesel Generator 24 Hour Endurance Run
and Hot Restart Test 18 Month," Revision 2;
1BwVSR 8.1.1.2.f-20, "1B Emergency Diesel Generator KW [ Kilowatt) Load
Rejection and Simulated Si in Conjunction With UV (Undervoltage] During Load
Testing," Revision 11; and
Braidwood Engineering Surveillance Procedure (BwVS) 900-8, " Emergency
Diesel Generator Engine Analysis," Revision d.
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b. Observations and Findinos
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For each surveillance test, the inspectors verified the establishment of initial conditions
required for the surveillance test and observed the operation of equipment, the ,
communications between the licensed operators in the control room and non-licensed
operators, and the restoration of affected equipment. The inspectors determined that
each of these activities were performed in accordance with the applicable procedure.
The inspectors verified the data obtained met the required acceptance criteria specified
in the surveillance test procedures. The inspectors also reviewed the associated i'
portions of the Updated Final Safety Analysis Report (UFSAR) and the Technical
Specifications and determined that the surveillance test procedures demonstrated the
systems performed as designed.
However, the inspectors did observe two examples where the acceptance criteria in the
surveillance test procedures were not consistent with the requirements of Technical i
Specifications. Surveillance test 2BwOS 8.1.1.2.a-1, "2A Emergency Diesel Generator .
Monthly (Staggered)," which verified that the emergency diesel generator can start from
ambient condition and accelerate to at least 600 revolutions per minute (rpm) in less
than or equal to 10 seconds meeting Technical Specification 4.8.1.1.2.a.4. The
inspectors noted that 2BwOS 8.1.1.2.a-1 indicated an rpm acceptance criteria as
l. "588 to 612" which was not consistent with the Technical Specification. This
l inconsistency was discussed with the system engineer who agreed that the acceptance
! criteria must match the Technical Specification requirement. The inspectors reviewed
nine previously completeJ emergency diesel generator mtnthly surveillance procedures
and determined that each time the recorded rpm value was greater than 600 rpm. The
l licensee revised all the monthly surveillance procedures to be consistent with the
Technical Specification. On September 26, the inspectors observed the performance of l
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18wVS 8.1.1.2.f-21. This surveillance procedure was used to demonstrate compliance
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with Technical Specification 4.8.1.1.2.f.7, which verified that the emergency diesel
l generator operate for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, stop and restart within five minutes accelerating to at
least 600 rpm in less than or equal to ten seconds. The inspectors noted that the
surveillance procedure did not include the 600 rpm acceptance criteria as specified in
the Technical Specification. This inconsistency was discussed with the system engineer
who had the procedure revised to reflect the Technical Specification rpm requirement.
The inspectors concluded that no operability concern existed.
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c. Conclusions
The inspectors observed the performance of all or portions of ten surveillance tests in
accordance with the Technical Specification and Updated Final Safety Analysis Report,
The surveillance tests adequately tested the systems. However, the inspectors
identified two minor administrative errors for the acceptance criteria in the emergency
diesel generator surveillance test procedures.
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Ill. Eno!neerina
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l E1 Conduct of Engineering
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E1.1 Modification to the Unit 1 Condensate Storaae Tank (CSTL
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! a. Inspection Scope (37551)
The inspectors reviewed Engineering Change Notice (ECN) 001157M, " Increase the
Height of the Unit 1 Condensate Storage Tank (CST) by 10 Feet, and Install
a 6" Butterfly Drain Valve (1CD260)"; Design Change M20-1-97-002-B, " Increase the
Height of the Unit 1 Condensate Storage Tank by 10 Feet"; Operability Evaluation
Form 93-029, " Failure to Arm the SX (water) Suction Swap-Over when the Control
Switch is in "after-close" and an Arming Signal is Present"; Application for Amendment
to Appendix A, Technical Specifications, to Facility Operating Licenses," Condensate
Storage Tank Level," dated December 30,1997; and Work Package 960022332-01,
l " Increase Height of CST by 10 Feet." The inspectors interviewed system engineering
l. and contractor personnel and performed a walk-down of the CST before, during, and
after the modification installation.
j b. Observations and Findinas
l The ECN, the design change package, the associated operability determination and
l proposed license amendment were properly documented. Worker safety practices,
l cutting, welding, and nondestructive testing were good and were properly documented.
l No problems were noted with the work performed or with the work and modification
packages.
c. Conclusions
(. Modifications were properly prepared, initiated, and documented on the Unit 1
l condensate storage tank.- Work was performed in a safe manner, and nondestructive
! testing was properly performed and evaluated.
E1.2 Failure to Test All of the Automatic Realianment Functions of the Control Room
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Ventilation System.
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l a. Inspection Scope (37551)
The inspectors reviewed 10 CFR 50, Appendix B; UFSAR Chapter 6.4; Braidwood
Technical Specification 4.7.6.e.2; NUREG-0800, " Standard Review Plan"; NUREG-
l 1002, " Safety Evaluation Report Related to the Operation of Braidwood Station, Units 1
l and 2"; Braidwood Operating Surveillance Procedure (BwOSR) 3.7.10.3, " Control Room
'
Ventilation System Emergency Makeup System 18 Month Surveillance," Revision 0;
i 1BwOSR 3.3.2.7-602A, " Unit One Quarterly Slave Relay Surveillance (Train A - K602
and K647); 1BwOSR 3.3.2.7-602B, " Unit One Quarterly Slave Relay Surveillance
(Train B - K602 and K647); 2BwOSR 3.3.2.7-602A, " Unit Two Quarterly Slave Relay
- Surveillance (Train A - K602 and K647); and 2BwOSR 3.3.2.7-602B, " Unit Two
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Quarterly Slave Relay Surveillance (Train B - K602 and K647). The inspectors
interviewed system engineering, operations, fire protection, and regulatory assurance
personnel.
b. Observations and Findinas
The inspectors performed a review of portions of the control room ventilation system
design bases including a comparison of the UFSAR described functions, UFSAR
described system testing, and Technical Specification required surveillance testing.
Specifically, the inspectors reviewed the control room ventilation system's UFSAR
described automatic realignment functions.
The UFSAR, Section 6.4, describes three possible automatic realignments of the control
room ventilation system. The system will automatically realign upon detection of high
radiation in the outside air intakes, upon receipt of a safety injection signal, or upon
detection of ionization products (smoke) in the return air duct or mixed air plenum. The
UFSAR, Section 6.4.5 states that the control room ventilation system and its
components are thoroughly tested in a program which includes periodic testing and that
written test procedures will establish minimum acceptance values for all tests. However,
the inspectors determined that the system's automatic realignment upon detection of
smoks in the return air duct or mixed air plenum was not periodically tested. The
licensee pointed out that there was no Technical Specification surveillance requirement
pertaining to the control room ventilation system's automatic realignment upon detection
of smoke. In addition, control room operators can manually realign the control room
ventilation if necessary. Based on questions raised by the inspectors, the licensee
planned to develop a periodic test of the control room ventilation system's automatic
realignment upon detection of smoke.
Since the test was not required by technical specifications, the licensee contested the
inspectors position that the failure to periodically test the control room ventilation
system's automatic realignment upon detection of smoke was a violation of 10 CFR 50,
Appendix B, Criterion Ill. Criterion lit requires that measures be established to assure
that applicable regulatory requirements and the design basis are correctly translated into
specifications, drawings, procedures, and instructions. Therefore, this matter is
unresolved and will be forwarded to NRC headquarters, NRR for resolution
(50-456/98014-02(DRP); 50 457/98014-02(DRP)).
c. Conclusions
The inspectors identified the licensee did not test the contrd room ventilation system
design function to realign on the detection of smoke in the exhaust penum as described
in UFSAR Section 6.4. The inspectors verified the testing of the control room ventilation
system met Technical Specification requirements. Licensee management stated the
control room ventilation system function to realign on the detection of smoke in the
exhaust plenum would be tested in the future. Currently the control room operators also
have the ability to manually realign the control room ventilation system if necessary.
Further review by the NRC is needed to determine if any enforcement is warranted on
this issue. An unresolved item was issued.
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E2 Engineering Support of Facilities and Equipment
E2.1 Loose Bolts on Emeraency Diesel Generator Lubricatina Oil Heat Exchanaers
a. Insoection Scope (37551)
l
Inspectors conducted inspections of all Unit 1 and 2 emergency diesel generators; '
discussed the observation of loose bolts with the shift manager, system engineer,
seismic engineer, and station management; reviewed machinery history documents for
the emergency diesel generators; and reviewed the licensee's corrective actions. The
inspectors reviewed the applicable sections of the Cooper Bessemer vendor's manual;
WR #960094684, " Upper Lube Oil Cooler Has Slight Oil Leak"; PlF #A1998-02783, i
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" Loose Bolts Found on 2A DG [ Emergency Diesel Generator] Lube Oil Heat
Exchanger"; PIF A1998-02783 Prompt investigation Report; Root Cause Report NTS
(Nuclear Tracking System) number 457-200-98-CAQS00008, " Loose Bolts Found on l
2A Emergency Diesel Generator Lube Oil Cooler Due to Not Using Industry Operating
Experience," Revision 0; PlF A1998-2400, " Loose Bolts Found on 2B DG [ Emergency
Diesel Generator) Lube Oil End Bell"; and PIF A1998-2406, Loose Bolts Found on
'
1B Emergency Diesel Generator Lube Oil Heat Exchanger."
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b. Observations and Findinas
On August 18,1998, the inspectors observed that ten of the sixteen bolts on the 2A and
one bolt on the 2B emergency diesel generator lubricating oil heat exchanger end bells
were loose. The licensee initiated an action request for the tightening of the bolts,
checked heat exchanger bolts on the all of the emergency diesel generator lubricating
oil heat exchangers, performed an operability assessment for the 2A emergency diesel
generator, conducted a prompt investigation, and initiated a root cause analysis of the
event. The inspectors verified the assumptions used in the operability assessment and
agreed with the licensee's determination of operability.
The inspectors reviewed the vendor's manual and WR#960094684 for the most recent
maintenance activity on the 2A emergency diesel generator lubricating oil heat
exchanger packed end. The inspectors noted that the installation instructions in the
work request were consistent with the instructions in the vendor's manual and that the
vendor's manual did not specify a torque value for the bolts.
The inspectors conducted a review of the maintenance history records for all of the
emergency diesel generators and noted ten similar problems, four of which were
identified this year. In February 1998, the licensee identified a oilleak from the
2A emergency diesel generator lubricating oil heat exchanger packed end bell but failed
to check the bolts for tightness. On July 10,1998, painters observed several loose
bolts on the 2B emergency diesel generator lubricating oil heat exchanger end bell and
documented the deficiency in PIF A1998-2400. The licensee responded by tightening
the loose bolts on the 2B emergency diesel generator lubricating oil heat exchanger and
inspecting the other emergency diesel generators lubricating oil heat exchangers.
Operators checked all of the other emergency diesel generator heat exchangers for
loose bolts and identified loose bolts on the 1B emergency diesel generator lubricating
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oil heat exchanger end bell. The additionalloose bolts identified were tightened and
were documented in PlF A1998-2406. However, following the identification of these
significant conditions adverse to quality on two of the four emergency diesel generators
(safety-related equipment identified as important in the licensee's risk analysis), the
licensee failed to implement measures to assure that the cause of the bolt loosening
was determined and corrective action taken to preclude repetition. The licensee initiated
such action on August 18,1998, after inspectors observed the same condition on the
2A and 23 emergency diesel generators.
i
10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Actions," requires, in part, that
measures be established to assure that conditions adverse to quality, such as failures,
malfunctions, deficiencies, deviations, defective material and equipment, and
nonconformances are promptly identified and corrected. In the case of significant
conditions adverse to quality, the measures shall assure that the cause of the condition
is determined and corrective action taken to preclude repetition. The licensee's failure
to implement measures to determine the cause and take comprehensive and effective
corrective action to preclude repetition of the loose bolts on the emergency diesel
( generator lubricating oil heat exchangers was a violation of 10 CFR Part 50,
Appendix B, Criterion XVI (50-456/98014-03(DRP); 50-457/98014-03(DRP)).
The licensee's investigation of the event determined that the lack of uniform tightening,
and " creep" (a phenomenon that will result in the loss of pre-load on the bolts due to the
partially plastic behavior of elattomeric gaskets) as causes or contributing factors.
Further information obtained by the licensee from the Electric Power Research Institute
Bolting Procedure Handbook discussed the periodic tightening of bolts as a common
way to address the loss of pre-load due to " creep." Additionalinformation obtained
through discussions with other members of the Cooper Bessemer Diesel Generator
Owners Group supported the need for periodic tightening of the lubricating oil heat
exchanger end bell bolts since the members with periodic requirements for tightening
reported no events. The licensee identified two root causes for this event. The first was
not establishing and using specific tightening values for the emergency diesel generator
lube oil cooler end bell fasteners. The second root cause was not performing periodic
'
hot re-tightening of the emergency diesel generator lube oil cooler end bell fasteners.
Based on the root causes, the licensee identified, documented, and initiated the
,
implementation of corrective actions to prevent recurrence.
c. Conclusions
The licensee failed to implement measures to determine the cause, and take
comprehensive and effective corrective action to preclude repetition of bolts being
found loose on two emergency diesel generator lubricating oil heat exchanger end bells
following the identification on July 10 and 12,1998. On August 18,1998, the inspectors
observed two similar problems with loose bolts on the 2A and 2B emergency diesel
generators lubricating oil heat exchanger end bells. Since August 18, the licensee's
efforts to identify and correct the causes for loose heat exchanger bolting were
aggressive and comprehensive. The inspectors concluded that identified corrective
actions should prevent recurrence of the problem with the loose bolts. A notice of
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l violation was issued for failure to initiate an investigation to determine the cause of a
condition adverse to quality until identified by the inspectors.
E8 Followup Engineering (92903)
E8.1 (Closed) Violation 50 457/97021-03: " Failure to initiate PIF as required by station ,
procedure." Inspectors identified on November 10,1997 that the licensee had failed to !
follow nuclear station work procedure NSWP-A-15, " Comed Nuclear Division Integrated
Reporting progmm," Revisioni and Braidwood administrative procedure BwAP 330-10,
" Operability Determinations," Revision 3E1 requirements to issue a PlF when problems
were recognized with a tempering feedwater line snubber and with various main feed
water line snubbers. The licensee counseled the involved engineering personnel about
the circumstances surrounding this violation including the need to follow station
procedures concerning the documentation of conditions adverse to quality. The
licensee also performed a review of NSWP-A-15 and BwAP 330-10 to determine if
changes were necessary to ensure a PlF would be generated when required. The
licensee determined that no changes to these procedures were required. Since this
review, the licensee replaced BwAP 33.0-10 with nuclear station
procedure NSP-CC-3001, " Operability Determination Process," Revision O. This
procedure was also reviewed by the licensee and found to contain appropriate
guidance. The inspectors reviewed NSWP-A-15 and NSP-CC-3001 and concur with the
licensee's conclusions. This item i:, closed.
V. Manaaement Meetinas
X1 Exit Meeting Summary
The inspectors presented the inspection results to members of licensee management at
the conclusion of the inspection on October 19,1998. The licensee acknowledged the
findings presented. The inspectors asked the licensee whether any materials examined
during the inspection should be considered proprietary. No proprietary information was
identified.
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PARTIAL LIST OF PERSONS CONTACTED
Licensee
I *T. Tulon, Site Vice President
l K. Schwartz, Station Manager
!
.R. Wegner, Operations Manager
R. Byers, Maintenance Superintendent
. A. Haeger, Health Physics and Chemistry Supervisor !
L *R. Graham, Work Control Superintendent
L T. Simpkin, Regulatory Assurance Supervisor
!
J. Kuchenbecker, System Engineering Supervisor l
l T. Luke, Engineering Manager i
- M. Cassidy, Regulatory Assurance - NRC Coordinator i
blB.G
L
' M. Jordan, Chief, Reactor Projects Branch 3
- C. Phillips, Senior Resident inspector
- J. Adams, Resident inspector
D. Pelton, Resident inspector
- Denotes those who attended the exit interview conducted on October 19,1998.
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. .
l INSPECTION PROCEDURES USED
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l lP 37551: Onsite Engineering
1- IP 61726: Surveillance Observations
IP 62707: Maintenance Observation
)
IP11707: Plant Operations
IP 92903: Followup - Engineering
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l ITEMS OPENED AND CLOSED
Opened
50-456-457/98014-01 NCV failure to follow procedures
l 50-456-457/98014-02 URI contested need to have a test procedure
j 50-456-457/98014-03 VIO failure to take timely corrective actions
,
Closed
50-457/97021-03 VIO failure to follow procedures
50-456-457/98014-01 NCV failure to follow procedures
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LIST OF ACRONYMS USED
'
CFR Code of Federal Regulations
ESF Engineered Safety Features
l FME Foreign Material Exclusion
LCO Limiting Condition for Operation
NRC Nuclear Regulatory Commission
NRR Nuclear Reactor Regulations
OOS Out-of-Service -
PlF Problem identification Form
SI Safety injection
SX Essential Service Water
UF3AR Updated Final Safety Analysis Report
VIO Violation
WR Work Request
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