ML20203D920
| ML20203D920 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 02/20/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20203D912 | List: |
| References | |
| 50-456-97-22, 50-457-97-22, NUDOCS 9802260199 | |
| Download: ML20203D920 (22) | |
See also: IR 05000456/1997022
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION lil
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i Docket Nos: 50-456,50-457
License Nos: NPF 72, NPF 77
'- Report Nos: 50-456/97022(DRP); 50-457/97022(DRP)
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- Licensee
- Commonwealth Edison (Comed)
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Facility: Braidwood Nuclear Plant, Units 1 and 2
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Location: RR #1, Box 84
Braceville,IL 60407
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Dates: - December 16,1997, through January 26,1998
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Inspectors: C, Phillips, Senior Resident inspector
J. Adams, Residert inspector
'D Pelton, Resident inspector
T. Esper, Illinois Department of Nuclear Safety
Approved by: M. Jordan, Chief
Reactor Projects Branct. 3 -
9902260199 900220
PDR ADOCK 05000456
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EXECUTIVE SUMMARY
Braidwood Nuclear Plant, Units 1 & 2
NRC Inspection Report No. 50-456/97022(DRP); 50-457/97022(DRP)
This inspection included aspects of licensee operations, maintenance, engineering, and plant
support. The report covers a six week period of resident inspection from December 10,1997,
through January 26,1998.
Operations
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The inspectors concluded that the infrequently performed activity briefing of shift
personnel for removal of the *N" annunciator train was conducted and attended by the
appropriate personnel. The inspectors concluded that the licensee demonstrated an
excellent safety focus by providing additional Nuclear Station Operators (NSOs) in the
control room and additional non-licensed operators in the field to allow for continuous
monitoring of critical plant equipment normally monitored by the unavailable annunciators.
The inspectors concluded that the Unit Supervisor (US) demonstrated good surervisory
presence by remaining in or near the at-the-controls area and provided continuous
reminders to the NSOs to remain focused on the control board indicators. The inspectors
concluded that the licensee's restoration and testing of the "N" train of control room
annunciators was properly performed in accordance with established procedures.
(Section 01.1)
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On January 6 and 7, inspectors observed operators perform rounds of the auxiliary
building and turbine building. The inspectors reviewed the day shift equipment operator,
I auxiliary building, and turbine building logs and concluded that readings required by
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Technical Specification (TS) or other commitments were obtained. (Section 04,1)
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The inspectors observed licensed operator requalification training and determined that
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operators promptly identified all of the off-normal and casualty events included in the
training scenarios, properly used the correct procedures to place the plant in a stable
condition, and correctly used self checking and communication techniques. Inspectors
concluded that supervisory personnel provided directions to operators, conducted
periodic crew briefings, effectively supervised reactivity manipulations, correctly identified
and entered the applicable TS action statements, properly classified the Generating
Station Emergency Plan (GSEP) events, appropriately upgraded and downgraded GSEP
events, and simulated the required notifications. The inspectors concluded that the
simulator accurately represented the actual control boards in the control room.
Maintenance
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The inspectors concluded that the maintenance activities observed were performed in
accordance with the applicable procedures, that the procedures provided the requisita
information for the assigned work, that maintenance personnel demonstrated safe work
practices, and that maintenance personnel were knowledgeable of the associated TS
limiting condition for operations. (Section M1.1)
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- The inspectors concluded that for observed surveillance activities acceptance criteria
were met, personnel correctly followed the test procedures, and that surveillance tests
verified the systems performed as required by the updated final safety analysis report and
TS. (Section M1.2)
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The licensee identified in 1989 that all four safety-related Unit 2 main feedwater check
valves (FWO79A, B, C, and D) had seized in an open position due to insufficient
clearances between critical components in the valve dampening mechanisms. The
inspectors identificd in December 1S97 that critical components in the Unit 1 FWO79A
and D check valve dampening mechanisms were replaced in May and April o.f 1997
respectively without being machined to the required clearances. The inspectors
concluded that the corrective actions taken for the seizing of the FWO79 check valve
piston rods in 1989 were not adequate to prevent recurrence. A violation was issued.
(Section M2.1)
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The inspectors concluded that the licensee accurately identified, quant;fied, tracked, and
reported the number of non-outage corrective work requests reported to the NRC as
committed to in the Braidwood Station March 28,1997, response to the NRC's request
for information pursuant to 10 CFR 50.54(f). (Section M7.2)
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The inspectors identified five examples where maintenance ar.d test equipment was not
stored in accordance with station procedures. The ir,spectors concluded that the
licensee was not appropriately controlling access to maintenance and test equipment. A
violation was issued. (Section M7.3)
Enaineerina
. The inspectors observed progress in reducing the total number of temporary alterations.
System and site engineering personnel were tracking open temporary alterations as listed
in the associated documentation. The inspectors concluded plant procedures related to
the temporary alteration process were followed for known plant alterations. However, the
inspectors identif!9d two unauthorized modifications that were in place for several years,
but were not identified in plant design documentation. A violation was issued.
(Section E2.1)
Plant Support
. The inspectors concluded that the licensee accurately identified, quantified, tracked, and
reported the percent of contaminated square footage reported to the NRC as committed
to in the Braidwood Station March 28,1997, response to the NRC's request for
information pursuant to 10 CFR 50.54(f). (Section R7.1)
. The inspectors observed that the station response to a fire drill conducted on
December 31 was prompt and thorough and concluded fire brigade members performed
(or simulated) all tasks well. (Section F4.1)
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Report Details
Summary of Plant Status
Unit i entered the inspection period at full power and remained at or near full power for the entire
period. Unit 2 entered the inspection period at full power and remained at or near full power until
the reactor tripped at 9:53 p.m. on January 26. The cause of the kip was not identified by the
end of the inspection period.
,1, Operations
01 Conduct of Operations
01.1 Control Room Observations Durina a Planned Loss of Control Room "N" Train
a. Inspection Scope (71707)
The inspectors attended the infrequently performed activities (IPA) briefing and observed
Unit 2 control room operators during the performance of a maintencnce activity to repair
relay PNLA30J in panel 2PA30J. The inspectors reviewed the IPA briefing requirements
contained in Braidwood Administrative Procedure (BwAP) 100-12, " Human Performance
Awareness of Pre-Job Briefings / Meetings and Self Checking," Revision 5.
b. Observations and Findinas
On January 6, inspectors attended an IPA briefing for a maintenance activity that would
deenergize the Unit 2 power supplies for the "N" train of control room annunciators. The
"N" train annunciator power supplies provided power to all Unit 2 annunciators except for
the safety-related "A" and "B" trains and some of the Unit 0 annunciators. The inspectors
verified the IPA met the requirements of BwAP 100-12. The shift operations supervisor
led the IPA and stressed the importance of vigilance in monitoring equipment indicators
for the plant systems normally served by the "N" train annunciators. The system engineer
described the maintenance activity to be performed. The inspectors observed all
necessary personnel involved in the maintenance activity were in attendance at the
briefing.
The inspectors observed that the licensee augmented the shift with four additional non-
licensed operators and four additional Nuclear Station Operators (NSOs). The non-
licensed operstors were stationed appropriately in the turbine and auxiliary buildings to
monitor equipment. The additional NSOs were each assigned a specific section of the
control boards for the purpose of continuously monitoring the indicators of equipment
effected by the annunciator outage. The communication links between field personnel -
and the control room were tested and operable annunciator windows were identified prior
to the commencement of the maintenance activity.
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The inspectors observed the NSOs performing continuous monitoring of the control
boards prior to the deenergization of the *N" train annunciator power supplies. The
continuous monitoring of the control boards continued throughout the duration of the
maintenance activity until testing had verified that the "N" train annunciators were again
operable, inspectors observed direct supervision of the NSOs by the Unit Supervisor
(US) from within the at-the-controls area of the control room. The US provided the NSOs
frequent reminders to maintain their focus on the control board indicators.
c. Conclusions
The inspectors concluded that the infrequently performed activity briefing of shift
personnel for removal of the "N" annunciator train was conducted and attended by the
appropriate personnel. The inspectors concluded that the licensee demonstrated an
excellent safety focus by providing additional NSOs in the control room and additional
non-licensed operators in the field to allow for continuous monitoring of ci;tical plant
equipment normally monitored by the unavailable annunciators. The inspectors
concluded that the US demonstrated good supervisory presence by remaining in or near
the at-the controls area and provided continuous reminders to the NSOs to remain
focused on the control board indicators. The inspectors concluded that the licensee's
restoration and testing of the "N" train of control room annt.nciators was properly
performed in accordance with established procedures. (Section O1.1)
04 Operator Knowledge and Performance
04.1 Observation of Operator Rounds
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a. Inspection Scope (71707)
The inspectors observed non-licensed operators during the performance of their rounds
in the turbine building and auxiliary building. The inspectors performed a review of
" Equipment Operator Weekly Logs Logsheet," Revisions 10 and 11; " Auxiliary Building
U-1 (Unit 1) Weekly Logs Logsheet," Revisions 9 and 10; " Auxiliary Building U-2 (Unit 2]
Weekly Logs Logsheet," Revisions 8 and 9;" Turbine Building U-1 Weekly Logs
Logsheet," Revisions 14 and 15; and " Turbine Building U-2 Weekly Logs Logsheet,"
Revisions 14 and 15. Inspectors discussed recent changes to the equipment operator
logs with members of the operations staff, and discussed management expectations of
field operator performance with the Shift Operations Supervisor (SOS).
b. Observations and Findinas
On January 6, the inspectors accompanied an equipment operator performing rounds of
the 1E and non-1E high voltage switchgear,1E batteries, diesel generators, turbines,
transformers, and the switchyard; and on January 7, the inspectors accompanied the
Unit 1 auxiliary building operator while performing rounds of the auxiliary building. The
inspectors made the following observations:
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the operators observed radiation protection, housekeeping, and fire protection
requirements;
the operators inspected lesser traveled areas of the plant as part of their rounds;
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the operators checked all standby, running, and safety-related equipment during
their rounds; and
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the operators accurately measured equipment parameters and recorded the
associated readings in their logs.
The inspectors were told by auxiliary building operators that the number of readings taken
for the day shift logs had been reduced in September 1997. The inspectors reviewed
new and old revisions of the equipment operator, auxiliary building, and turbine building
logs. The companson revealed that readings taken to satisfy Technical Specification
(TS) requirements were obtained. The inspectors observed that the readings that were
removed were associated with equipment that rarely experienced any significant change,
provided little useful informatiori to operators, or were associated with annunciated
equipment. Many of the readings were moved from the day shift logs to either the
midnight or the afternoon logs.
The inspectors discussed the abbreviation of the day shift logs with the operations staff
and were told the reason for the abbreviation was to increase the availability of field
operators for the support of plant activities and to respond to plant problems. The staff
told the inspectors that they conducted a review of the logs and determined that there
were many components with parameters that rcrely changed or were only measured
daily. The staff made the determination that these components could be adequately
monitored by recording the parameters on the other shift logs. The staff told the
inspectors that the changes to the logs were reviewed by all of the field supervisors prior
to implementation and no parameters that were required to be recorded to satisfy TS
requirements and othar commitments were removed from the logs.
The inspectors discussed management's expectations of operator performance of rounds
with the SOS, The SOS told the inspectors that the field operators were still expected to
visit all areas and to look at all the equipment on their rounds. The SOS told the
inspectors that several of the operators had expressed concerns with the abbreviation of
the day shift equipment operator, auxiliary building, and turbine building logs. A shift
manager was assigned to review the concerns raised by the operators but had not yet
completed the review.
The inspectors did not observe any behavior by operators that would indicate the
existence of operator workarounds. The inspectors noted that all areas visited as part of
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the rounds were accessible to operators and only a minimal number of contaminated
areas were encountered.
c. , Conclusion
'"5e inspectors observed operators while they performed their required rounds and
concluded that the operators properly checked the status of all the equipment; correctly
adhered to radiation protection, housekeeping, and fire protection requirements; and
accurately read and recorded the required equipment pcrameters. The inspectors
reviewed the abbreviated day shift logs and concluded that readings required by TS or
other commitments were obtained.
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05 Operator Training and Qualification
05.1 Observation of Licensed Operator Reaualification Simulator Trainina
a. Inspection Scope (71707)
The inspectors observed, in the plant simulator, the performance of licensed operators in
response to a loss of a condensate pump, a loss of a component cooling water pump,
steam generator tube rupture with a safety injection actuation, and a feedline break inside
containment.
b. Observations and Findinas
On January 14,1998, the inspectors observed licensed operators participating in the
licensee's licensed operator requalification program. The simulated scenarios observed
by the inspector included: a loss of a condensate pump, a loss of a component cooling
water pump, a steam generator tube rupture with a safety injection actuation, and a
feedline break inside containment. The inspectors observed that the operating crew q
promptly identified the problerns, properly used the correct procedures to stabilize the
plant, continuously self checked their actions prior to taking the actions, and effectively
used communication techniques. The US provided directions to operators, conducted
periodic crew briefings as permitted by plant conditions, and referred to TS and correctly
identified and entered the applicable action statements. The shift technical advisor
provided supervision over reactivity manipulations performed by the nuclear station
operators. The shift manager referred to the Generating Station Emergency Plan (GSEP)
and properly classified the events, upgraded and downgraded the events appropriately,
and made the required notifications.
The inspectors observed that the simulator accurately represented the actual control
boards in the control room. However, the inspectors observed that the existing problems
with the potential for some of the Unit 1 and 2 feedwater check valves (1/2FWO79A, B, C,
and D) to stick open were not included in the simulator's modeling. The instructors told
inspectors that they would discuss the issue at the next weekly operations training
meeting,
c. Conclusion
The inspectors observed licensed operator requalification training and determined that
operators promptly identified all of the off normal and casualty events included in the
training scenarios, properly used the correct procedures to place the plant in a stable
condition, and used proper self-checking and communication techniques, inspectors
concluded that supervisory personnel provided directions to operators, conducted
periodic crew briefings, effectively supervised reactivity manipulations, correctly identified
and entered the applicable TS action statements, property classified the GSEP events,
appropriately upgraded and lowngraded the GSEP events, and simulated the required
notifications. The inspectors concluded that the simulator accurately represented the
actual control boards in the control room.
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07 Quality Assurance in Operations
07.1 10 CFR 50.54m Letter Cormitment Review
a. Inspection Scope (92901)
The inspectors reviewed the status of commitments pertaining to the licensee's
March 28,1997, response to the NRC's request for information pursuant to
10 CFR 50.54(f). The commitment numbers correspond to those used by the licensee in
their March 28,1997, response.
b. Observations and Findinas
b.1 Commitment 1: "To reinforce these principles and ensure that per%fmance
results are achieved, the Chief Nuclear Operating Officer (CNOO) caiucts
Management Review Meetings (typically each month) at each site." ,m licensee
no longer has a management position entitled CNOO. This commitment was
fulfilled by the Vice President of Pressurized Water Reactors.
Commitment 75: "The CNOO conducts Management Review Meetings at each
site focused on safety performance and the effectiveness of improvement
initiatives. These meetings addcess trends of safety, performance, and cost
indicators; results of third party (NRC) inspections; results of site self-
assessments; status of material condition in the plant; outage planning and
performanco; and assessments of the quality of workforce product and training."
Commitment 100: "We have established the actions to be taken if the
performance criteria are not met. In order to assure that effective and timely
actions are taken, essessment of performance indicators and implementation of
actions based on this assessment will take place at the site, Nuclear Operating
Division and Board levels. Each of the perform?nce indicators described in
Sections 4.7.1 and 4.7.2 (of the Licensee's 10 CFR 50.54(f) response) above will
be monitored by the Site Vice Presidents, and will be reviewed during the periodic
Management Review Meeting for each station."
Commitment 271: "The CNOO (typically monthly) conducts Management Review
Meetings at each site, focusing on safety performance and the effectiveness of
improvement initiatives."
Commitment 322: "Each month the CNOO conducts Management Review
Meetings at all sites."
The inspectors observed one of the monthly Management Review Meetings
conducted on January 12. Licensee management briefed the Vice President of
Pressurized Water Reactors on the current status of performance indicators
reported to the NRC, as a response to the March 28,199~,10 CFR 50.54(f) letter
to the utility. The Vice President made several commen.s regarding expectations
of excellence from station management. The inspectors concluded that the
com nitments: to conduct a monthly Management Review Meeting and to
reinforce management expectations; to discuss performance indicators, trends,
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and the results of self essessments by third party inspectors; and to discuss the
effectiveness of improvement initiatives at Braidwood were satisfied.
Commitments 1,75,100,271, and 322 are closed.
b.2 Commitment 54: "Our CNOO, during his periodic visits (typically monthly) to the
sites, conducts open discussions with groups of 15 - 20 employees regarding our
plans, and steps that can be taken to improve."
Commitment 316: "Our CNOO, during his monthly Management Review meetings
at the sites, has discussions with groups of 15 - 20 employees regarding our
plans, issues of concern, and steps for improvement."
The inspectors observed the Vice President of Pressurized Water Reactors
discuss current station concerns with a group of 20 - 30 workers on J.,nuary 12.
The inspectors concluded that the commitment to meet with small groups of
employees on a periodic basis at Braidwood was satisfied and Commitments 54
and 316 are closed.
c. Conclusion
The inspectors concluded that the licensee met Commitments 1,54,75,100,271,316,
and 322 regarding periodic management meetings.
11. Maintenance
M1 Conouct of Maintenance
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M1.1 Miscellaneous Maintenance Activities
a. Inspection Scope (62707)
Between December 31,1997, and January 15,1998, the inspectors observed all or
portions of the following maintenance activities:
+ Repair of relay PNLA30J within electrical cabinet 2PR30J in accordance with
Work Request 970134937-01,
Replacoment of the process radiation monitor 1PR11J pump motor in accordance
with BwHP 4006-011, " Electrical Maintenance Troubleshooting Work Sheet," _
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Revision 9.
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Replacement of a mechanical seal on 2A residual heat removal system pump in
accordance with BwMP 3110-015, " Residual Heat Removal Pump Disassembly,
inspection, and Reassembly," Revision 0.
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b. Observations and Findinos
The inspectors attended the heightened level of awareness and Infrequently Performed
Activities (IPA) meetings. All maintenance related topics weru discussed at the
heightened level of awareness and IPA meetings including responsibilities, safety
requirements, tooling required, communications, and contingency plans. The inspectors
noted that maintenance personnel were knowledgeable about the scope of the work, the
requi J system status, and electrical safety. The inspectors also reviewed the
applicable portions of the Updated Final Safety Analysis Report (UFSAR) and the TS
limiting condit;ons for operations and noted no conflicts with the planned work.
c. Conclusiong
The inspectors concluded that the maintenance activities observed were performed in
accordance with the applicable procedures, the procedures provided the requisite
information for the assigned work, that maintenance personnel demonstrated safe work
practices, and maintenance personnel were knowledgeable of the associated TS limiting a
condition for operations.
M1.2 MJscellaneous Surveillance Activities
a. Inspection Scope (61726)
The inspectors observed all or portions of the tollowing surveillance tests:
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2BwOS 6.2.3.a 1, *Reacto, Containment Fan Coolar Monthly Surveillance,"
Revision 4E1.
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BwVS 7.6.h 1," Control Room Recirculation Cnarcoal Adsorber Bank operability,"
Revision SE1.
b. Observations and Findinas
Between December 31 and January 9, the inspectors observed the performance of the
above listed surveillance tests, both locally and from the control room. The inspectors
observed operations personnel establish initial plant conditions for the surveillance tests,
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operate plant equipment, communicate between the control room and the auxi'iary and
containment buildings, and restore effected equipment to service. Operators correctly
followed the surveillance test procedures, used proper three way communications, and
properly performed independent verifications during oquipment rettoration. The
inspectors observed that the acceptance criteria specified in the surveillance test
procedures were met. The inspectors reviewed applicable sections of the UFSAR and
the TS and determined that the survei!!ance tests verified that the systems performed as
required.
c. Conclusions
The inspectors concluded that for observed surveillance activities acceptance criteria
were met, personnel correctly followed the test procedures, and surveillance tests verified
the systems performed as req'2: red by the USFAR and TS.
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M2 Maintenance and Material Condition of Facilities and Equipment
M2.1 Unit 1 and Unit 2 Main Feedwater Check Valve FWO79 Maintenance
a. inspection Scope (62707)
The inspectors reviewed Problem identification Form (PIF) A1997 05245," Unable To
Maintain U-2 Feedwater Pump Speed Controller in Auto"; completed work package
970008530-01, " steam generator 2C feedwater flow check valvo disassemble and inspect
during A2R06"; completed work package 37000853101, " steam generator 2D feedwater
flow check valve disassemble and inspect during A2R06"; BwMP 3305-087,"Borg-
Wamer FWO79 Check Valve Disassembly, inspection, and Reassembly," Revisions 4
and 5; Operability Determinations97-156,97-157, and 97-163; and completed
documentation for surveillance test 2BwVS 0.5-2.FW.2-2, " Main Feedwater Header
(2FWO79A, B, C, D) Check Valve Fuli-Close Operability Exercise Test During Refuel
Outages," Revision O.
b. Observations and Findinos
On November 26,1997, the licensee identified that main feedwater check valves
2FWO79C and D were not completely open with Unit 2 at 97 percent power. The
inspectors reviewed the most recent complete work package documentation on the four
feedwater check valves in both units.
The 2FWO79A, B, C, ano O valves were 16 inch tilting disc, anti-slam check valves in the
main feedwater lines to all twr steam generators. Hydraulic pistons provided resistance
to prevent check valve slam. Testing of the check valves to verify closure was required
- by American Society of Mechanical Engineers Code,Section XI, Article IWV-3520 and by
- TS 4.0.S. Relief request VR-31 was granted by the NRC on August 18,1995, to allow
periodic inspection of the valves instead of quarterly flow checks.
The inspectors identified in the vendor manual a letter from Berg-Warner to Comed dated
June 26,1992, that stated valve sticking could occur if there was not enough clearance
(greater than .003 inches) between the outer diameter of the piston rod bushing and the
inner diameter of the valve bonnet bore due to thermal expansion of the bronze piston rod
bushing. The coefficient of thermal expansion for the bronze rod bushing w. : twice that -
of the steel of the valve bonnet. The bronze bushing would expand untilit twJe contact
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with the valve bonnet and then stress relieve. When the bushing cooled down to about
250 to 300 degrees Fahrenheit during plant shutdown, the bronze bushing would contract
to a diameter smaller than original. This would cause the piston rod bushing to collapse
onto the piston rod causing the valve to stick open. The letter recommended that the
licensee machine the bronze bushing outer diameter to a dimension of 3.992/3.993
inches. When questioned by the_ inspectors, the licensee provided documentation that
stated that all four Unit 2 FWO79 check valves were found stuck 100 percent open in
November of 1989. Operability Evaluation 89-128 documented that the root cause of the
sticking valves was insu'ficient clearance between the piston rod bushing outer diameter
The inspectors reviewed the most recent work package and identified that the piston rod
bushings for check valves 1FWO79A and D were replaced in April and May of 1997 with
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neither the inside nor the outside diameter of the bushing machined. The documentation
lacked sufficient data to determine the clearance between the piston rod bushing and the
piston rod. The licensee stated that check valves 1FWO79A and D would most probably
stick below 40 percent power based on predicted feedwater temperatures. The FWO79
check valves were relied upon in UFSAR, Chapter 15.2.8 *Feedwater System Pipe
Break," to provide immediate isolation of the steam generators to reduce the amount of
inventory loss prior to the closure of tha feedwater isolation valves. The licensee initiated
an Operability Evaluation 97163, which evaluated the three check valves sticking below
40 percent power. The licensee concluded that the feedwater sstem for both units was
operable based on the isolation capability of the feed isolation valve.
The inspectors reviewM BwMP 3305 087, Revision 5. The licensee included acceptance
criteria for the as found valve position but did not include steps to measure and record
the clearance between the piston rod bushing and the valve bonnet bore, and the
clsatance between the piston rod and the piston rod bushing.
DwAP 1250 2,' Deviation Reporting," Revision 2, Step C.1, defined a deviation as "a
departure from accepted equipment performance...which results in, or could, if
uncorrected, result in a failure of an item to perform as required by TS or approved
procedures." S%p C3.a.4 required that a person identifying a deviation initiate a deviation
report. Step C.3.d.1 b e equired that any additional corrective action required to
investigate, correct the condition, or to prevent the recurrence be determined and
specified. The licensee did not prepare a deviation report nor initiate corrective actions
thH would preclude recurrence of the condition wnere the Unit 2 main feed water check
v& *i stuck open.
As mentioned above, all four feedwater check val 9 on Unit 2 stuck open in 1989 due to
a valve design problem. The failure to take corrective actions to prevent recurrence of a
significant condition adverse to quality was a violat,on of 10 CFR Part 50, Appendix B,
Criterion XVi(50-456/97022 01(DRP); 50-457/97022 01(DRP)).
c. Conclugiqa
Ths licensee identified in 1989 that all four Unit 2 main feedwater check valves (FWO79A.
B, C, and D) had stized in an open position due to insufficient cleasances between critical
compnnents in the valve dampening mechanisms. The licensee did not change the
Maign of the valve, did not include work package instructions to machine the rod piston
bushing to the proper dimensions if replaced, did not include steps in the work package to
measure and record critical clearance parameters, and did not include as found
acceptance criteria in the work package instructions thct would identify a problem. The
inspectors identified in December 1997 that entical components in the Unit 1 FWO79A
and D check valve dampening mechanisms were replaced in May and April of 1997
respectively without being machined to th:, required clearances. The inspectors
concluded that the corrective actions taken because of the seizing of the FWO79 check
valve piston rods in 1989 were not adequate to prevent recurrence. A violation was
issued.
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M7 Quality Assurance in Malntenance Activities
M7.1 10 CFR 50.54ff) Letter Commitment Review
a. Inspection Scope (92902)
The inspectors reviewed the status of commitments pertaining to the Brr'1 wood Station
March 28,1997, response to the NRC's request for information purst a'. O
10 CFR 50.54(f). The following commitments related to work control were i aviewed by
the inspectors. The commitment numbers correspond to those used by the licensee in its
March 28,1997, response,
b. Observations and Findinal
b.1 Com_mitment 48: "A standard screening process has been put in place at all six
sitet w ensure maintenance *.vork is properly classified and prioritized."
The inspectors verified that a standard screening process was put in place at
Braidwood by interviewing the work control center supervisor, reviewing
NSWP.WM 08, " Action Request Screening Process," Revision 1, and attending a
daily screening meeting. The inspectors concluded that the commitment to
implement a standard screening process at Braidwood was satisfied and this item
is closed,
b.2 Commitment 49: " Work Planning n, being evaluated to identify inefficiencies in the
planning process that prevent work from being performed."
The inspectors verified that the evaluation of the work planning process was a
continuous process through an interview with the work control superintendent and
the work control center superviror. Braidwood station has a full time
representative assigned to the company's corporate office to evaluate the work
control process. The inspectors concluded that the commitment to evaluate the
work planning process at Braidwood was satisfied and this item is closed.
b.3 Commitment 50: *All sites are currently implemming a minimal work request
process which enhances job planning for minor work."
The inspectors venfied that a minimal work request process was implemented by
interviewing the work control superintendent and the work control center
supervisor, and by reviewing nuclear station work procedure NSWP WM-06,
" Minor Maintenance Process," Revision 1. The nuclear station work procedure
defined and established criteria for categorizing tool pouch and minor
maintenance. The inspectors concluded that the commitment to implement a
minimal work request process at Braldwood was satisfied and this item is closed,
b.4 Commitment 52: "The amount of emergent work completed by the Fix-It Now
(FIN) teams is measured to determine the effectiveness of the initiatives."
The inspectors reviewed the weekly report that compared emergent work tasks
performed by the FIN team versus the emergent work taska performed by the
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maintenance shops. The licensee used the information to determine the proper
size of the FIN team and also was able to determine that the amount of resource
loading for the regular maintenance crews was too high based on the amount of
amergent work that was performed by the shops. The inspectors concluded tb it
the commitment to measure the amount of emergent work completed by the Fl.
team to evaluate the effectiveness of work planning initiatives at Braidwood was
satisfied and this item is closed.
b.5 Commitment 225: "The Getting Work Done Plan used dedicated work teams (FIN
team and a work analyst team) to reduce the backlogs and improve sche %Ie
adherence on work tasks. The FIN team is estilized to protect execution of the
weekly schedule by assuming responsibility for all emergent work requirements
inat arise during the week."
The residents verified that a FIN team was implemented at Braidwood and work
request backlogs were significantly reduced. The percent completion of the
weekly schedule increased. However, the FIN team did not assume the
responsibility for all emergent work. The FIN team works the day shift only and
primarily performed jobs that could be completed in a single shift. Emergent work
that required multiple shifts to complete was performed by maintenance shop
personnel. The inspectoio concluded that the commitment to use dedicated work
teams to reduce work backlogs at Braidwood was satisfied and this item is closed.
c. Qpnclusion
The inspectors concluded that the licensee met Commitments 48,49,50,52, and 225
regarding work control initiatives.
M7.2 Non-Outaae Corrective Work Reauest Status Review
a. jntpection Scope (92902)
The inspectors reviewed the licensee's infermation on the non-outage corrective work
requect backlog and interviewed the work control superintendent and the work control
center supervisor.
b. Observations and Findinos
The number of non-outage corrective work requests was developed from the licensee's
electronic work control system, The licensee screened all action requests and assigned
each to a specific category. If the category data field was left blank, the computer
automatically assumed that the work was non outage corrective maintenance. Action
requests were not hand wr'. ten but entered into the computer by operations,
maintenance, or engineering personnel.
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, c. Conclusions
The inspectors concluded that the licensee accurately identified, quantified, tracked, and
reported the number of non outage corrective work requests reported to the NRC as
committed to in the Braidwood Station March 28,1997, response to the NRC's request
for information pursuant to 10 CFR 50.54(f).
M7.3 Mt.ejurement and Test Eouipment (M&TE)
a. Inspection Scope (62707)
The inspectors monitored the licensee's controls of M&TE. The inspectors reviewed
BwAP 400-4, * Control of Portable Measurement and Test Equipment," Revision 10E1.
, The inspectors monitored M&TE in use in the plant, as well as M&TE storage facilities.
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The inspectors also interviewed maintenance staff, system engineering, site engineering,
and operations personnel.
b. Observations and Findinal
BwAP 400 4, Step F.6.a.1.b stated that "The M&TE storage facility will be locked when
unmanned." The inspectors identified five occasions when this requirement was not
satisfied, including:
- On November 26,1997, the inspectors entered the hot tool room in the auxiliar;
building. The inspectors identified numerous calibrated torque wrenches.
- pressure gages and alignment tools that were left unlocked and unattended,
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con ary to the requirement of BwAP 400-4.
- On Cecen,oer 1,2, and 3, ih6 inspectors entered the hot tool room and observed
additional examples of M&TE left unlocked and unattended, contrary to the
requirements of BwAP 400-4
- On December 12, the inspector t.ntered the instrument maintenance department
tool room located in the turbine building. M&TE stored in this room was left
unlocked and unattended, contrary to regt'irements of BwAP 400-4.
The failure to follow Frocedure BwAP 400-4 is a violation of TS 6.8.1.a.
(50 456/97022 02(DRP); 50 457/07 22 02(DRP)) as described in the attached NOV.
c, Conclusions
The inspectors concluded that access to M&TE was not consistently controlled based on
finding M&TE storage locations unlocked and unattended, on five separate occasions,
which violated licensee M&l E storage control procedural requirements. A violation wcs
issued,
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111. Enalneerina
E2 Engineering Support of Facilities and Equipment
E2.1 Temporary Alterations
a. In1pection Scooe (37550)
The inspectors reviewed temporary alteration processes. The inspectors reviewed
documentation for several temporary alterations and performed plant walkdowns of
several temporary alterations. Temporary alterations were reviewed for compliance
with the UFSAR and TS requirements. The inspectors also reviewed Procedure
BwAP 2321 18. " Temporary Alterations," Revision 3E1.
b. Observations and Findinan
Review of the niorithly temporary altJration report issued on December 29,1997,
revealed that there were 19 documented temporary alterations in the plant. Eight
alterations had been in place for greater than 18 months. The report also showed that
plans were in place to remove all temporary alterations or to take necessary actions in
order to make the alteration a permanent modification. ('
The inspectors reviewed 10 CFR 50.59 safety evaluations for a sample of temporary
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alterations. The evaluations were performed correctly and referenced required licensing
and design documents. The inspectors performed a walkdown of temporary alterations
931010 and 93 2 019. The physicalinstallation of the alterations was in agreement with
the installation documentation.
The inspectors also looked for undocumented modifications to the plant while performing
routine plant walkdowns. Two unauthorized plant modifications were identified. Steel
buildings had been erected in the electrical penetration rooms for each unit. These
structures were called " Local Leak Rate Test shacks" because they were used to store
localleak rate test equipment. Although an exact date the steel buildings were installed
could not be determined, plant personnel stated they were built in the late 1980s.
Upon discovering the two steel buildings, the inspectors checked to see if the structures
were identified in plant documentation. UFSAR Section 1.2, Braidwood Fire Protection
Report Section 2.3.11.49, and Plant Drawings M 6, M 7, A 256, A 258, S 1298, and
S 1296 were reviewed. None of the documents included the structures. The inspectors
reported this to the licensee. Site engineering personnel determined that the structures
should not be in place. Since the buildings were installed close to numerous scfety-
related components, site engineering completed Operability Evaluation 98-002. The
inspectors reviewed the evaluation for both buildings and considered it acceptable.
Both buildin9s were removed as of January 22. Site engineering management stated that
site engineers were performing a review of plant facilities in order to identify any other
unauthorized modifications. The failure to perform design analysis and to document the
installation of the structures in the electrical penetration rooms for each unit is a violation
of 10 CFR Part 50, Appendix B, Criterion 111, Design Control (50-456/9702203(DRP);
- 50-45767022-03(DRP)).
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c. Conclusions
The inspectors concluded that the licensee made progress toward reducing the total
number of temporary alterations. System and site engineering personnel were tracking
open temporary alterations as listed in the associated documentation. The inspectors
conc!uded that plant procedures related to the temporary alteration process were followed
for known plant alterations. However, the inspectors identified two unauthorized
modification: that were in place for several years but were not identified in plant design
documentation. A violation was issued.
E7 Quality Assurance in Engineering Activities
E7.1 10 CFR 50.54fD t.etter Commitmed RdY.itW
a. Inspection Scope (9290.3_)
The inspectors reviewed the status of vommitments pertaining to the Braidwood Station
March 28,1997, response to the NRC's reqvsst for information pursuant to
10 CFR 50.54(f). The following commitments related to advanced engineering and
configuration management training were reviewed by the inspectors. The commitment
number corresponds to those used by the licensee in their March 28,1997, response.
b. Observations and Findinal
Commitment 24: ' Additional training will be conducted to address identified areas for
improvement such as design basis adherence, configuration management
implementation, operability determinations, and safety evaluation preparation."
The inspectors interviewed the supervisor of the corporate design basis programs
department to determine the scope of the training on safety evaluation preparation and
who would be trained. The supervisor stated that advance training in 10 CFR 50.59
safety evaluation preparation would be conducted. This training will be completed in the
- summer of 1998 and will inciude information on design basis definition and adherence,
and operability determination preparation. The primary target group for the training would
be engineers with at least two years experience. The strategy for the training was to
increase the knowledge level of about 30 to 40 engineers at each station and upgrade
( procedures at each station to include elements of the training. In mid 1998, the training
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for the rest of the engineering staff would include the 10 CFR 50.59 pret. aration
procedural changes. The inspectors reviewed a course book for the training.
The inspectors also interviewed the supervisor of the corporate configuration
management department to determine the scope of the training on configuration
management and who would be trained. The supervisor stated that the training was
targeted primarily for operators and maintenance workers that had the opportunity to
make plant changes through their normal course of work. The training was designed to
define what a plant change was, the importance of writing problem identification forms
when changes were identified, and what the roles of operators and maintenance workers
were in maintaining plant configuration control. The training was completed at Braidwood
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in September 1997 for about 133 operators and 247 maintenance workers. The
inspectors reviewed the training material and determined that the training given met the
commitment.
c. Conclusion
The inspectors concluded that Commitment 24 to conduct additional training on identified
areas for improvement such as design basis adherence, configuration management
implementation, operability determinations, and safety evaluation preparation at
Braidwood was satisfied and this item is closed.
IV. Plant Support
R7 Miscellaneous Radiation Protection and ControlIssuos
R7.1 Percent Contaminated Souare Footajle Review
a. Ingection Sggne f71750)
The inspectors reviewed the licensee's information on the percent contaminated square
footage and interviewed radiation protection personnel,
b. Observations and Findinal
The percent of contaminated square footage was calculated from a list of all auxiliary
building and fuel handling building rooms and the square footage of each room. The
contaminated areas in the plant were estimated and compared to the total amount of
square footage. Some areas, such as the containment, were exempted from the
computation. The inspectors reviewed the exempt areas and the basis for why they were
considered exempt and had no concerns. The inspectors also inspected the plant and
had no concerns with the amount of square footage the licensee considered
contaminated.
c. Conclusions
The inspectors concluded that the licensee accurately identified, quantified, trackad, and
reported the percent of contaminated square footage reported to the NRC as committed
to in the Braidwood Station March 28,1997, response to the NRC's request for
information pursuant to 10 CFR 50.54(f).
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F4 Fire Protection Staff Knowledge and Performance
F4.1 Fire Drill
a. Inspection Scope f71750)
The inspectors observed a fire dril! at the plant. The inspectors also attended the fire drill
critique session.
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b. Qt?servations and Findinas
At 11:05 a.m. on December 31, the licensee staged a fire drillin the turbine building
trackway. The drill scenario was a simulated forklift fire and an assumed out of service
fire sprinkler system for the affechd area.
The drill was announced on the plant page system at 11:06 a.m. The fire chief arrived on
the scene at 11:08 a.m. and the full fire brigade was on the scene at 11:12 a.m. All fire
brigade members reported to the scene wearing fire turn out gear. One fire brigade
member also reported with a self contained breathing apparatus (SCBA). Several
additional operators also reported to the scene in order to provide support for the fire
brigade members. Security personnel were at the scene to p ovide access control.
.
Actions simulated were appropriate in order to control the fire and to limit the effects of
the fire on plant equipment. The fire chief and operations supervisors assessed possible
problem areas. All equipment brought to the fire was observed to be in good condition
and all inspections (when required) were up to date. Fire personnel brought additional
hoses, SCBAs, fire extinguishers, and a foam unit to the scene. Following the drill, all
equipment was returned to storage.
Following the drill, the fire marshail presented a critique session for all personnel that
responded. Potential areas for improvement and the drill scenario were discussed. Fire
brigade members and operating personnel actively participated in the meeting.
c. Conclusioni
Plant personnel response to the fire drill was prompt and thorough. Fire brigade
members performed (or simulated) all tasks well with a positive attitude.
V. Manaaement Mettinas
X1 Exit Meetinry Summary
The inspectors presented the inspection results to members of licensee management at
the conclusion of the inspection on January 26,1998. 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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PART.AL LIST OF PERSONS CONTACTED
Licensee
T. Tulon, Site Vice President
- K. Schwartz, Station Manager
- R. Wegner, Operations Manager
- R. Byers, Maintenance Superintendent
A. Haeger, Health Physics and Chemistry Supervisor
- R. Graham, Work Control Superintendent
- T. Simpkin, Regulatory Assurance Supervisor
- C, Dunn, System Engineering Supervisor
l - 'J. Meister, Engineering Manager
j *B. Boyle, Fire Marshal .
'J. Nalewajka, Integrated Safety Engineering Group 1
- J. Neyhart, Shift Manager ,
- C. Herzog, Executive Assistant
- M. Cassidy, Regulatory Assurance . NRC Coordinator
NRC
- M. Jordan, Chief, Reactor Projects Branch 3
- C. Phillips, Senior Resident inspector
- J. Adams, Resident inspector
D. Pelton, Resident inspector
IDNS
- T. Esper
- Denotes those who attended the exit interview conducted on January 26,1998.
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INSPECTION PROCEDURES USED
IP 37550: Onsite Engineering
i IP 61726: Surveillance Observations
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IP 62707: Maintenance Observation
IP 71707: Plant Operations ,
l lP 71750: Plant Support Activities
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IP 92901: Followup Plant Operations
IP 92902: Followup Plant Maintenance ,
- IP 92903: Followup Engineering
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i ITEMS OPENED, CLOSED, AND DISCUSSED
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Opened ;
50-456/97022 01; 50 457/97022 01 VIO failure to take corrective actions
50-456/97022 02; 50 457/97022 02 VIO failure to follow procedure
50 456/97022 03; 50-457/97022 03 VIO failure to perform design analysis
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LIST OF ACRONYMS USED !
CNOO Chief Nuclear Operating Officer
CFR- Code of Federal Regulations
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FIN Flx It Now
GSEP Generating Station Emergency Plan !
IPA Infrequently Performed Activity - *
M&TE Measuring and Test Equipment
NRC Nuclear Regulatory Commission i
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NRR Nuclear Reactor Regulations
NSO Nuclear Station Operator .
PDR Public Document Room
PlF Problem Identification Form
RP&C Radiological Protection & Chemistry
SCBA Self contained Breathing Apparatus
SOS Shift Operations Supervisor
TS Technical Specification
UFSAR Updated Final Safety Analysis Report . ;
US Unit Supervisor
VIO Violation
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