Text

Insp Repts 50-456/97-16 & 50-457/97-16 on 970923-1103. Violations Noted.Major Areas Inspected:Operations, Maintenance,Engineering & Plant Support
	ML20199A578
Person / Time
Site:	Braidwood
Issue date:	12/17/1997
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	;
Shared Package
ML20199A562	List: ML20199A558; ML20199A568; ML20199A578;
References
	50-456-97-16, 50-457-97-16, NUDOCS 9801280028
	Download: ML20199A578 (29)
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U.S. NUCLEAR REGULATORY COMMISSION. l

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50-456, 50-457.

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. Docket Nos:

, License Nos: NPF 72, NPF-77

Report No: - 50-456/97016(DRP): 50-457/97016(DRP)

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Licensee: Commonwealth Edison (Comed)- ,

Facility: Braldwood Nuclear Plant, Units 1 and 2 '

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Location: RR #1, Box 84

Braceville, IL 60407

Dates: September 23 through November 3,1997

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inspectors: C. Phillips, Senior _ Resident inspector

J. Adams, Resident inspector -

D. Pelton, Resident inspector

T. Esper, Illinois Department of Nuclear Safety

Approved by: Michael J. Jordan, Chief

Reactor Projects Branch 3

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' EXECUTIVE SUMMARY

Braidwood Nuclear Plant, Units 1 and 2

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NRC Inspection Report No. 50-456/97016(DRP); 50-457/97016(DRP)

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

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

. September 23 through November 3,1997.

Operations

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The inspectors concluded that the Unit 2 shutdown for refueling outage A2R06,

conducted on September 26 and 27, was well planned and executed. The licensee

had a designated operator and supervisor to control reactivity changes. Senior plant

management was present to observe the shutdown and ensure the outage started

smoothly. Operators followed procedures and handled minor equipment problams

well, which prevented potential secondary plant transients (Section O1.1).

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The inspectors concluded that the corrective actions taken by the licensee to ensure

the correct positioning of equipment was not totally effective. The licensee identified

eleven mispositioned componens between September 2 and October 4,1997.

Problems with mispositioned components have been discussed in previous

inspection reports and this has been a recurring issue. The examples discussed in

this report were considered to be further examples of the violation issued in

Inspection Report No. 97015. It is too early to determine if the recent corrective

actions taken by licensee management have been effective in addressing this issue

(Section 01.2).

- The inspectors concluded that the licensee's "Reportability Manual" was incorrect for

reporting engineered safety feature actuations. The licensee failed to report a Unit 2

"A" train containment ventilation isolation. The inspectors informed the licensee that

the event was reportable and it took several days before the licensee agreed that the

event was reportable. A violation was issued (Section 03.1).

The inspectors reviewed the licensee's tracking system for human performance

errors resulting in licensee evant reports (LERs) and problem identification forms

(PlFs) conceming out-of-services. The inspectors concluded the licensee accurately

identified and correctly tracked human performance errors described in LERs and

PIFs conceming out-of-services (Sections 01.3 and O1.4).

The inspectors reviewed the licensee's tracking system for entries into unplanned

limiting condition for operations (LCOs) and operator work arounds. The inspectors

concluded the licensee accurately identified and correctly tracked unplanned LCO

entries and operator work arounds (Sections 01.5 and O2.1).

Maintenance

The inspectors concluded that contractor personnel demonstrated poor human

performa.'. e on October 28,1997, by failing to follow the procedure to establish a

- freeze seal prior to maintenance. The inspectors observed two subsequent

maintenance

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cctiviti;s th t r;quir2d frc:ze s;als, conduct;d by both lic3nse2 end contractor j

personn;l, which r;vaal:d none of the previously not;d probi;ms. A violation was ;

issu;d (S;ction M1.1).

The, inspectors concluded that the maintenance on valve 2CV-093A was performed

well by the maintenance crew. The inspectors observed that during the maintenance

work performed on 2CV-003A, the maintenance crew followed the procedure, noted

that the work would exceed the scope of the work packsge and had the package

changed, and used the proper materials for the job. However, the inspectors

observed a lack of concern demonstrated by mechanics after having dropped 2CV-

3121 and an associated test gauge on the floor (Section M1.2).

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The inspectors concluded that the construction, inspection, and tracking of

scaffolding was poor during the months of August and September 1997. The

inspectors and the licensee identified numerous examples (about 20) of the failure to

follow procedural requirements by maintenance personnel and operations

department supervisors regarding construction, inspection, and tracking of

scaffolding in areas affecting the operation of both units between August 24 and

September 17. The inspectors also concluded that the maintenance department

self assessment identified construction of scaffolding as an area that needed

improvement, but that future corrective actions were not made clear in the report. A

violation was issued (Section M2.1).

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The inspectors concluded that the six surveillance tests observed during this period

were performed in accordance with procedures and all acceptance criteria were met

or the proper actions were taken by the test directors when the acceptance criteria

were not met. Heightened level of awareness and pre-job briefings were thorough

and exceeded minimum briefing requirements. The surveillance test procedures

were well written and ensured Technical Specification and Updated Final Safety

Analysis Report requirements were tested (Section M4.1).

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The inspectors identified 17 examples where the licensee failed to take effective

corrective actions for the securing of movable carts in the auxiliary building. A

violation was previously issued for the licensee's failure to e, ' movable carts and

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equipment in NRC Inspection Report No. 50-456/96021(DR; ,, 50-457/96021(DRP).

A violation was issued (Section M8.1).

Ennineerina

The inspectors concluded that the licensee accurately maintained, tracked and

controlled temporary alterations (Section E2.1).

The inspectors conchded that the original revision of operability evaluation 97-015

for the 125 volt direct current battery charger was conducted poorly. After the

inspectors questioned the operability determination, the licensee reevaluated the

operability evaluation and determined that the sizing of the battery charger did meet

the design basis requirements. The inspectors concluded that the preparation and

superviscry review of the original operability evaluation 97-015 was poor, and that

the system engineer demonstrated a lack of knowledge of the 'esign basis

requirements of the 125 volt direct current battery chargers (Se.; tion E3.1).

The inspectors concluded that the licensee failed to perform a modification to the

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o m:in turbine control software in accord nce with station procedures. - The licensee

l * _ h:d modiftd the runb:ck t:rmin: tion setpoint for both units in 1990, h:d not

ch:nged the simul: tor, cnd h:d not tr;ined oper;t:rs en the ch:nge. Tha inspectors

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concluded that the licensee conducted an accurate and thorough apparent cause

evaluation of the undocumented change of the turbine runback termination setpoint.

-This failure to perform a modification to the main turbine control software in

accordance with station procedures was a licensee identified non cited violation

(Section E4.1).

Plant Support

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The inspectors concluded that licensee management did not cleariy communicato

restrictions on use of skull caps as protective clothing to workers. The licensee had

a policy memorandum restricting the use of skull caps as protective clothing if hair =

could not be protected from contamination. However, this policy memorandum

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restriction on the use of skull caps was not in the procedure that govemed protective

clothing, nor was it in the radiation work pemlit (Section R3.1).

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- The inspectors concluded that between September 26 and October 15, there was an

unusually high number of improper radiological postings. A large portion of these

appeared to have been caused by contractor personnel failing to comply with

licensee procedures. A violation was issued.

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The inspectors concluded that licensee management had not effectively

communicated and/or had not enforced the requirements for the control of

combustible material. Corrective action for a previous violation of combustible

material control was ineffective to prevent recurrence. The inspectors identified that

between September 16 and Octo'o er 20,1997, there were at least ten examples of

the failure to adhere to procedures goveming combustible liquid control. A violation

was issued (Section F1.1).

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RODort Details

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Summarv of Plant Status

Unit 1 entered the period at 100 percent power and operated at that power level for the

entire period.

Unit 2 entered the period at 100 percent power and shut down for refueling outage A2R06

on September 26 and remained shut down for the remainder of the inspection period.

LO_pprations

01 Conduct of Operations

01.1 Unit 2 Shutdown For Refuelina Outaoo A280J}--

a. Incoection Scone (71707)

The inspectors reviewed the following procedures, 2BwGP 100-5, " Plant Shutdown

and Cooldown," Revision 12E2 and 2BwGP 100-6, " Refueling Outage," Revision 8.

The inspectors also observed portions of the shutdown.

b. Observations and Findinas

The inspectors observed that the licensee had a designated reactor operator and

senior reactor operator to perform and monitor all re- +< changes. The inspectors

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observed that communications between these oper m tne cognizant nuclear

engineer were clear and frequent

The inspectors observed that in addition to the shift manager there were two other

senior station managers present to observe the shutdown and ensure the outaga

started smoothly.

The inspectors observed that the procedures used appeared to be adequate and

that the operators followed the procedures. The inspectors also observed that the

operators handled several minor equipment problems well and minimized plant

transients. These included control of the feedwater regulating valves which operated

sluggishly and the recovery from steam dump failures.

c. Conclusion

The inspectors concluded that the Unit 2 shutdown for refueling outage A2R06,

conducted on September 26 and 27, was well planned and executed. The licensee

had a designated operator and supervisor to control reactivity changes. Senior plant

management was present to abserved the shutdown and ensure the outage started

smoothly.

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01'2_ Qontinued Problems With Mispositioned Eaulomenj,

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- a. ' ' Insoection Scope (71707)

The inspectors reviewed the following licensee problem identification forms (PlFs),

1997-03218, A1997-03221, A1997-03595, A1997-03620, A1997-03771, A1997-

04061, A1997-04121- A1997-04115 A1997-04179, A1997-04186, A1997-04187,

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A1997-04172, A1997-04166, and A1997-04160. The inspectors also interviewed

operations department managers,

b. Observations and Findinas

The inspectors identified through the review of licensee PIFs that mispositioned

equipment continued to be a problem area. The licensee identified eleven

mispositioned components b3 tween September 2 and October 4,1997.

The improper positioning of components has been a ret.ing problem. This issue

was discussed in Inspection Reports Nos. 96005,96008,96009,96012, and 97015.

A violation was issued in inspection Report No. 97015 (50-457/97015-01(DRP)) for

the failure to take effective corrective action regarding the proper positioning of

components. The licensee identified mispc,sitioned components were considered to

be more examples of the violation issued in inspection Report No. 97015.

The inspectors observed that the proper positioning of plant equipment was stresseo

at several operating shift turnovers by operations department management.

Licensee personnel stated that the number of OOS's that were issued to an

ind'vidual at one time were reduced to one or possibly two if there were radiation

dose concems. Operations management personnel stated that the number of

" Scorecard" appraisals of rmn licensed operator performance increased to about six

per shift An operations field supervisor was moved to the non-licensed operator

ready room during the Unit 2 refueling outage te monitor the amount of work

assigned to operators near the end of the shift.

c. Conclusion

The inspectors concluded that the corrective actions taken by the licensee to ensure

the correct positioning of equipment was not totally effective. New corrective actions

taken by licensee management has not yet had time to demonstrate effectiveness.

The licensee identified eleven mispositioned components between September 2,

1997, and October 4,1997. Problems with mispositioned components were

discussed in previous inspection reports and this has been a recurring issue. The

examples discussed in this report were considered to be further examples of the

violation issued in Inspection Report No. 97015.

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01.3 ligman Performance Error Licensee Event Reports (LER) Review

a. -Inspection Scoce (92901)

The inspectors reviewed all 199/ LERs for both Units 1 and 2; and QVL 20-97-065,

' *Braidwood Station Quality & Safety Assessment, Braidwood Integrated Performance '

Report - Third Quarter 1997."

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. b. Observations and Findinas.

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Th3 inspect:rs revhwed Unit 1 cnd 2 LERs for 1997. The inspect:rs revtwed c:ch

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LER and found that the cause was accurately determined. The inspectors found '

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only one LER where the cause was attributed to a human performance error. The

inspectors findings were consis;ent with the number reported by the licensee in QVL ,

20-97-065, "Braidwood Station Quality & Safety Assessment. Braidwood Integrated

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Performance Report - Third Quarter 1997.*

c. Conclusions

The inspectors concluded that as of November 3, the licensee had accurately

tracked the number of human performance errors resulting in LERs, and has

accurately reported the number of human performance errors that resulted in LERs

in their self assessment reports.

01.4 Review of Out-Of-SeIyice (OOS) Errors

a. Inspection ScoDe (92901) -

The inspectors reviewed all PlF titles for the previous six months (April through

September 1997); NSWP-A-15, " Comed Nuclear Division Integrated Reporting

Provam," Revision 1; QVL 20-97-065, "Braidwood Station Quality & Safety

Assessment, Braidwood integrated Performance Report - Third Quarter 1997*; and

discussed the definition of an OOS error with operations management.

2 b.- Qkservations and Findjnal.

The inspectors conducted a review of PlF titles for the previous six months and

found 61'OOS related problems. Forty-three of the PlFs were due to errors in the

performance of the OOS process. The licensee screened the PIFs in accordance

with NSWP-A-15 and determined that none described a significant condition adverse

to quality and none of the PIFs were counted or tracked as an OOS error. The

inspectors found the licensee's definition of an OOS error to be subjective. The

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inspectors discussed the subjective definitions with licensee management. The

' licensee agreed with the inspectors that a more precise definition for an OOS error

was needed and has taken action within the operations peer group to develop a new

more precise definition for an OOS error. The inspectors observed that the licensee

has met their performance goals for the previous 6 months using the current

definitions for an OOS error and significant condition adverse to quality.

- c. Conclusions

The inspectors concluded that the licensee accurately identified OOS errors and

documented the errors in PIFs. The inspectors concluded that the licensee screened

the PlFs in accordance with NSWP-A-15, but were concemed with the degree of

subjectivity associated with the definition of significant condition adverse to quality. ,

The inspectors concluded that the licensee had met their performance goals for the

. previous 6 months using the current definitions for an OOS error.

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01.5 ' Review of Unolanned L%itino Condition for Operation (LCO) Entries

a. ' Insoection Scope (92901)

The inspectors reviewed a portion of the Limiting Condition for Operation Action

Requirements (LCOAR) database and QVL 20-97-065, 'Braidwood Station Quality &

Safety Assessment, Braldwood Integrated Performance Report - Third Quarter

1997." -

b. Observations and Findinos

The inspectors reviewed the method used for tracking unplanned LCO entries. The

inspectors found that the unit supervnors enter each LCO into the LCOAR database.

Each database entry is compared against the definition of an unplanned entry into a

LCO. If the LCO required a 7 day or less shutdown and was unplanned, then it was-

counted. Inspectors reviewed the LCOAR database input for the month of

September and found that the licensee has accurately counted unplanned LCO

entries. The inspectors findings were consistent with number reported by the

licensee in QVL 20 97-065, 'Braidwood Station Quality & Safety Assessment,

Braldwood integrated Performance Report - Third Quarter 1997.'

c. Conclusions

The inspectors concluded that the licensee has accuratel) identified, quantified,

tracked, and reported unplanned entries into LCOs.

O2 Operational Status of Facilities and Equipme. .

02.1 Operator Work Arounds Status Revievt

a. Inspection Scope (92901)

Tha inspectors reviewed the Operator Wnrk Around index; and QVL 20-97-065,

"Braidwood Station Quality & Safety Assessment, Braidwood Integrated Performance

Report - Third Quarter 1997." The inspectors also discussed efforts to eliminate

operator work arounds with a member of the operator work around committee.

b. Observations and Fi.n,dinas

lhe inspectors reviewed the onerator work around index and observed that there

were 53 operator work arounds identified. The inspectors performed control room

observations and panel walkdowns and found no operator work arounds that had not

been previously identified by the licensee. The inspectors findings were consistent

with number reported by the licensee in QVL 20-97 065, "Braidwood Station Quality

& Safety Assessment, Braidwood lntegrated Performance Report - Third Quarter

1997.'

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c. Conclusions

The inspectors conclud:d that the licenses h s accuratlly id2ntifcu cnd quantifsd

the operator work arounds, has accurately tracked the status of the operator work

arounds, and has accurately reported the numbers and status of the operator work

arounds in their self assessment reports. The inspectors concluded that licensee

- has met their operator work around work down goals.

03 Operations Procedures and Documentation

03.1 Licensee Failed To Report Enoineered Safety Feature Actuation In Accordance With

10 CFR 50.72

a. In}pfction Scope (71707)

The inspectors reviewed PIF A1997-04424 on Ochber 15,10 CFR 50.72, NUREG

1022, Revision 1, Second Draft, and the licenue's *Reportability Manual," Revision

4. The inspectors attended the licensee's r., vent screening committee meeting on

October 15 and interviewed members of licensee "anagement.

b. Observations and Findinas

On October 14, a licensee instrument technician made an error when changing

setpoints on the Unit 2 containment area radiation monitor 2AR11J. The error

resulted in a high radiation alarm and an "A" train containment ventilation isolation.

The initial conclJsion during the licensee management review of the event was that it

was not reportable in accordance with 10 CFR 50.72 based on information provided

in the licensee's 'Reportabliity Manual.' The 'Reportability Manual" provides

guidance to operators on which events are reportable to the NRC and which are not.

The inspectors reviewed the repor1 ability criteria for a 4-hour non-emergency call

from the licensee to the NRC under 10 CFR 50.72 (b)(2)(ii) which states:

(ii) Any event or condition that results in a manual or automatic actuation

of any engineered safety feature (ESF), including the reactor

protection system, except when;

, (A) The actuation results from and is part of a pre-planned

sequence during testing or reactor operation;

(b) The actuation is invalid and;

(1) Occurs while the system is propctly removed from

service;

(2) Occurs after the safety function has been already

completed; or

(3) involves only the following specific ESFs or their

equivalent systems;

(i) Reactor water clean-up system;

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.(11) Control room smergrney vsntilation syst:m;

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(ill) Rsactor building vsntilation systsm;

(iv) Fuel building ventilation system; or

(v) Auxiliary building ventilation system.

The inspectors informed licensee management that the event was reportable since it

was an automatic actuation of an ESF and did not meet the exclusion criteria. The

actuation was not part of a preplanned evolution and although the actuation was

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invalid, the system was not removed from service, the safety feature had not already

been completed, and containment ventilation was not one of the listed ESF systems

for exclusion.

The licensee never made the required notification of the NRC as required by

10 CFR 50.72, but agreed several days later to write a licensee event report. The

failure to make a report of the ESF actuation within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months as required was a ,

violation of 10 CFR 50.72 (50-457/97016-01(DP,P)).

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c. Conclusion

The inspectors concluded that the licensee's "Reportability Manual" was incorrect for

reporting engineered safety feature actuations. The licensee failed to report a Unit 2

"A" train containment ventilation isolation that was due to an error made by a

mechanic while adjusting the setpoint on a radiation monitor. The inspectors

informed the licensee that the event was reportable and it took several days before

the licensee agreed that the event was reportable. A violation was issued.

II. Maintenance

M1 Conduct of Maintenance

M1.1 Repair of Essential Service Water (SX) Valve 2SX-2102.

. a. Inspection Scope (61726)

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On October 1, the inspectors observed maintenance on the 2A auxiliary feedwater

pump oil cooler SX isolation valve 2SX 2102. The inspectors monitored the

establishment of the required system isolation including the establishment of a freeze

seal in accordance with OwMP 3300-018, " Application of Liquid Nitrogen Freeze Seal

to all Piping," Revision SE1; monitored the performance of the valve repair in

accordance with BwMP 3305-024, " Disassembly - Reassembly of ITT Grinnel Ball

Valves," Revision 1; and interviewed both contractor and licensee personnel at the

job site,

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b. Observations and Findinas

Th', work packrge css:ciat d with tha r: pair of valva 2SX-2102 r; quired tha

establishment of a freeze sealin accordance with BwMP 3300-018. Contractor

personnel were utilized to establish and monitor the freeze seal. The inspectors

observed several problems with the contractor personnel's use of BwMP 3300-018

during both the establishment and maintenance of the freeze seal. Problemc noted

included:

Contractor personnel did not complete freeze seal status signatures in

BwMP 3300-018 prior to breaching the SX system. These signatures

included obtaining shift supervisory permission to start the freeze, evaluating

the freeze plug to determine integrity draining the isolated portion of the

piping to ensure the sealis holding, and acknowledgment of established

contingence plans for loss of the freeze seal.

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Contractor personnel did not log 10 minute freeze seal temperature readings

in Attachment 2 of BwMP 3300-018 as required.

BwMP 3300-018 requires oxygen readings to be taken at the work site once

the freeze is started. Subsequent to initial oxygen readings taken by licensee

plant Radiation Protection (RP) personnel, contractor personnel did not

coritinue take periodic oxygen readings as required.

The inspectors also observed the actions taken by contractor personnel when they

encountered problems with the establishment of the freeze seal. Contractor

personnel did not contact the operation's field supervisor as was discussed in the

heightened level of awareness discussion held prior to the start of the job.

The inspectors immediately discussed the above problems with the operation's field

supervisor who took action to ensure contractor personnel followed the procedure.

The inspectors monitored the repair of SX valve 2SX-2102 which was also

performed by contractor personnel in accordance with BwMP 3305-024. New

material was properly identified; the correct lubricant was used; during valve

reassembly, foreign material exclusion protection was provided for the open valve

body when not being worked on; radiation protection personnel took surveys to

determine potential removable radiological contamination (none was found); and

when a " Quality Control hold point" was reached in the maintenance procedure,

quality control personnel were contacted and present as required.

Subsequent to the above valve repair, the inspectors observed the establishment of

two additional freeze seals by both contractor and licensee personnel. None of the

problems with the uso of BwMP 3300-018, noted above, were observed.

Discussions held between the licensee and contractor supervisors conceming

following licensee procedures appear to have been effective.

The failure of contractor personnel to follow BwMP 3300-018 was an example of a

violation of TS 6.8.1.a (50-457/97016-02(DRP)).

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c. Conclusions

Th] inspectors concluded that contr:ctor personn:l d:monstrat;d poor human

performance on October 28,1997, by failing to toilow the procedure to establish a

freeze seal prior to maintenance. The inspectors observed two subsequent

meintenance activities that required freeze seals, conducted by both licensee and

contractor personnel, which revealed none of the previously noted problems. A

violation was issued.

M1.2 Various Maintenance Activities Performed on Chemical and Volume Control (CV)

System Valves 2CV-093A and 2CV-8121

a. Irmoection Scoce (61726)

On October 28, the inspectors observed various maintenance activities on CV

system check valve 2CV-093A and relief valve 2CV-8121. The inspectors reviewed

the associated work packages; monitored the modification of 2CV-093A; monitored a

set point lift test of 2CV-8121 in accordance with BWMP 3305-028,

" Bench Testing / Setting of Safety / Relief Valves Used in Liquid Applications", Revision

6; monitored the removal of the defective 2CV-8121 from the CV system and

interviewed licensee personnel at thJ various job sites.

b. Observations and Findinas

The work package for valve 2CV-093A required the removal of an intemal spring

used to hold the valve clapper closed, inspectors monitored the cutting of the body-

to-bonnet seal weld, removal of the internal spring, performance of a contact surface

dye check of the seat, and re-welding of the body-to-bonnet joint. Once the. valve

was opened and the spring was removed, the mechanic noted an additional piece

with:n the valve, a spring seat, which appeared to also need to be removed but was

not addressed in the work package. This was reported to eng'aeering

, personnel

who performed a review and modified the work package to address the removal of

the spring seat. The inspectors verified that al1 materials used, including weld wire

a .d lubricant material was as specified in the work package. No problems were

noted.

Inspectors monitored the performance of the set-point test of relief valve 2CV-8121.

While en route to the auxiliary building, the inspectors noted that the cart used to

transport the valve and an associated calibrated test gauge tipped over and the relief

valve and test gauge fell to the floor. The mechanics picked up the equipment and

continued on to the hot room, they did not report h6ing dropped the valve and

gauge to their supervisor. Prior to testing, the inspectors looked over tne relief valve

i and test gauge. Although the valve appeared undamaged, the test gauge had its

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outer plastic casing broken. While the inspectors looked the gauge over, one of the

mechanics stated "the gauge was just calibrated four days ago; it should be okay."

The mechanics continued on with the lift set-point testing. The inspectors reported

these observations to the mechanics supervisor and discussed the potential for

having invalidated the calibration of the test gauge by dropping it. The supervisor

stated that a " post-calibration" check of the gauge would be required to be performed

prior to the valve being installed in the CV system. The inspectors reviewed the

completed work package. The valve passed the set-point test and the test gauge

passed the post-calibration check.

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Tha inspectors discussid the dropping of tha cquipmint with a s2nior m: Int;n:nce

m:nig2r, including ths fact that tha m;chanics did not qu3stion ths validity of tha l

' calibration of ths 12st gauga aftsr having dropped it on the floor. The maintsnance

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manager agreed with the inspectors concems and subsequently discussed his

expectations with the mechanics and the mechanics supervisor,

c. Conclusions

The inspectors concluded that the maintenance on valve 2CV093A was performed

well by the maintenance crew. The inspectors observed that during the maintenance

work performed on 2CV-093A the maintenance crew followed the procedure, noted

that the work would exceed the scope of the work package, had the package

changed, and used the proper materials for the job. However, the inspectors

observed a lack of concern on the validity of the test gauge calibration demonstrated

by mechanics after having dropped 2V-8121 and an associated test gauge on the

floor.

M2 Maintenance and Material Condition of Facilities and Equipment

M2.1 Failure to Follow Scaffold Procedure Results in Numerous Scaffold Deficiencies and

a TS Violation

a. Inspection Scope (62707)

The inspectors monitored the status of scaffolding erected in safety-related areas of

the plant. The inspectors interviewed site engineering, operations, and maintenance

personnel. The inspectors reviewed procedure BwMP 3300-025, " Erection,

,

inspection, use, and Dismantling of Scaffolding, Ladders and Temporary Barriers,"

Revision 3 and LER 50-457/97001 00. The inspectors also reviewed quality and

safety assessment field monitoring reports for July, August, and September 1997,

and the "Draidwood Integrated Performance Assessment Report - Third Quarter

1997,* dated October 24.

b. Observations and Findinas

Procedure BwMP 3300-025A2 lists requirements for scaffolding placed in safety-

related areas of the plant. This procedure requires that scaffolds in safety-related

structures (i.e., containment, auxiliary building, fuel handling building) be constructed

to catisfy seismic requirements. Completion of form BwAP 3300-025A1 documents

the engineering review for seismic scaffolding.

,

Step E.13 of BwMP ?300-025A2 requires that all scaffolds erected in seismic areas

have a Scaffold Request Form (BwMP 3300-025A1) posted on the scaffold prict to

placing the scaffold in use. Additionally, Step F.7 of BwMP 3300-025A2 requires all

seismic scaffolds to be logged in the scaffold tracking program. The inspectors

~ found several scaffolds in seismic areas of the plant, and close to safety-related

t

components, which did not satisfy the requirements of procedure BwMP 3300-

l 025A2. These scaffolds included:

!

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A scaffold was erected at auxiliary building elevation 364 at curved wall area

coordinates R-24 next to the Unit 2 containment spray additive tank

l

(2CS01T). Licensee personnel noted on August 8,1997, that this scaffold did

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n:t h:va the required BwMP 3300-025A1 f:rm cnd was not logged in th>

, ,

scaff:Id tracking progr:m. This was document:d on action requ:st tag

302006. On August 25,1997, th] inspectors n:t:d th] missing paperwork

and determined that no corrective actions were performed to address action

request tag 302006 in the 17 days since the action request tag was

generated.

-

On August 28,1997, the inspectors found three scaffolds erected in the

1A/C diesel oil storage tank room over the 1A diesel oil storage tank transfer

pump and next to the riiesel oil storage tanks. None of the scaffolds had the

required BwMP 3300-025A1 form and the scaffolds were not logged into the

tracking program. Initial investigation by the licensee indicated that the

scaffolds had been in place since March 1997.

-

On September 8,1997, the inspectors found that a scaffold was erected in

Unit 2 main steam pipe tunnel at elevation 367, column P-28. The scaffold

did not have the required liwMP 3300-025A1 form and was not logged into

the. tracking program.

On Septamber 16, the inspectors found a scaffold erected in the auxiliary

building at elev.ation 401, column S-24 and over the 28 containment chiller.

The scaffold did not have the required BwMP 330n-025A1 form attached.

During the period, the licensee also identified 17 additional scaffold-related problems.

One of the licensee identified p oblems resulted in LER 50-457/97001-00.

The LER also stated that on September 17, scaffolding appeared to be blocking the

travel of extraction steam non-return check valve 2ES0178 and the action statement

for TS 3.3.4 was entered until the scaffold was removed. The LER stated that the

scaffolding had been constructed long enough such that the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months limiting condition

for operation for TS 3.3.4 was exceeded. The licensee stated in the LER that one of

the causes for this problem was failure of operations supervisors to follow procedure

BwMP 3300-025A1. Step 1.c.1 of the procedure required the shift

manager / designee to review the scaffold for impact on plant operations and

equipment and to note any concerns or special instructions The LER stated that

discussions with operations supervisors revealed that it was not normal practice to

perform a physical inspection of the scaffold erection area if the supervisor was

familiar with the area.

The LER stated that the noperability of the extraction steam non-retum check valve

.

had no safety significance because no credit is taken for operability of these valves

in any safety analysis. The inspectors reviewed the Updated Final Safety Analysis

Report (UFSAR) Chapters 10 and 15. The inepectors agreed that the Chapter 15

safety analyses did not take crodit for operation of the extraction steam non-retum

check valves and Chapter 10, Section 10.2.2.5 specifically stated that the failure of

the extraction steam valves does not affect the safe shutdown capability of the plant.

This was a le'ss significant failure to comply with an actbn statement for a technical

specification limiting condition for operation where the appropriate action was not

taken within the time allowed

The licensee performed a separate root cause analysis (457-230-97-CAQS00001)

for the scaffolding deficiencies not discussed in LER 50-457/97001-00. The only

additional corrective action not already addressed in the LER was that the site

scaffold coordinator would develop a consistent process to track scaffolding to

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- -- . _- _ -. -- _ _ - . . _. . _ - . _ -. _- -

r2moval. This corr:ctiva action was due Ftbruary 18,1998.

,_

, Tha inspectors r:vi;wed qurlity and safsty cssissm:nt fi;ld monitoririg raports for

July, August, cnd Sgpt2mber 1997, and tha *Braidwood inttgratrd Pmform:nce

Assessment Report Third Quarter 1997," dated October 24. Quality and safety

assessment field monitoring reports indicated that licensee inspectors made several

observations of scaffold construction in the field. Deficiencies identified were

characterized as minor. The third quarter assessment did not indicate that there was

a problem with scaffold construction.

.

The inspectors reviewed the Maintenance department, "Self-Assessment Summary,"

for the Third Quarter of 1997. This assessment did identify the construction of

scaffolding as a problem area end that training sessio' Md continue to be held to

focus attention on the impact of the piant operations stason of the scaffold

procedure. However, the assessment did not say who would be trained or by when.

The failure to follow the scaffold construction procedure BwMP 3300-025, " Erection,

inspection, Use, and Dismantling of Scaffolding, Ladders and Temporary Barriers,"

4 Revision 3, was a violation of 10 CFR Part 50, Appendix B, Criterion V

(50-456/97016-03(DRP); 50-457/97016-03(DRP)).