ML20207N257
| ML20207N257 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 01/07/1987 |
| From: | Dunlop A, Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20207N215 | List: |
| References | |
| 50-456-86-60, 50-457-86-50, NUDOCS 8701140083 | |
| Download: ML20207N257 (7) | |
See also: IR 05000456/1986060
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-456/86060(DRS);50-457/86050(DRS)
Docket Nos. 50-456; 50-457
Licenses No. NPF-59; CPPR-133
Licensee: Commonwealth Edison Company
Post Office Box 767
Chicago, IL 60690
Facility Name: Braidwood Station, Units 1 and 2
Inspection At: Braidwood Site, Braidwood, Illinois
Inspection Conducted: October 27 through December 11, 1986
Inspector:
A. Dunlop, Jr. M Q[
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Date
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Approved By:
M. A. Ring, Chief
,Date
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Test Programs Section
J_nspe_c_t_ ion Summary
Inspection _on October 27 through December l 19861 _ Reports No. 50-456/_8_6060(DR_Sjl
No. 50-457/86050(DRS))
Areas Inspec_te_d: Routine, announced safety inspection to review actions on
previous inspection items (92701); preoperational test procedures review
(70304,70334); preoperational test procedure verification (70311);
preoperational test results evaluation (70322, 70534); and preoperational test
results verification (70329).
Results: Of the five areas inspected, no violations or deviations were
identified in the report. However, 5 open items and I unresolved item are
documented in the body of the report which require action by the licensee and
the NRC or both,
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DETAILS
1.
Persons Contacted
Commonwealth Edison Company (CECO)
M. J. Wallace, Project Manager
C. J. Tomashek, Project Startup Superintendent
- P. L. Barnes, Regulatory Assurance Supervisor
- T. W. Simpkin, Regulatory Assurance
- T. J. Lewis, Startup Staff, NOVA
M. Inserra, TRB Supervisor /PSG
E. Nagy, Group Leader
- H. D. Pontious, Regulatory Assurance
W. C. Mammoser, Project Engineering Department (PED)
J. Basek, System Test Engineer
Additional station technical, operational, and administrative personnel
were contacted by the inspector during the course of the inspection.
- Denotes those attending the exit meeting on December 11, 1986.
2.
Action on Previous Inspection Items
(Closed) Open Item (456/85026-03(DRS)):
This item concerned the review
of test results package for BwPT SI-10, " Safety Injection." The licensee
has approved the test results and the inspector has completed the review
with no further comments.
This item is considered closed.
No violations or deviations were identified.
3.
Preoperational Test Procedure Review
The inspector reviewed the following preoperational test procedures
against the FSAR, Safety Evaluation Report (SER), proposed Technical
Specifications, and Regulatory Guides 1.68.
BwPT EF-10, Revision 3, " Unit One Engineered Safety Features"
No violations or deviations were identified.
4.
Preoperational Test Procedure Verification
The inspector reviewed the following preoperational test procedures and
verified that they were written, reviewed, and approved by licensee
management in accordance with the requirements of Regulatory Guide 1.68
and the licensee's QA Manual:
BwPT AB-10, Revision 2 and Retest 52, " Boric Acid Processing System"
BwPT AR-14, Revision 0, " Area Radiation Monitoring (Loop 4)"
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BwPT EM-11, Revision 1, " Strong Motion Seismic Instrumentation System"
BwPT FC-10, Revision 0 and Retest 37, " Fuel Pool Cooling and Cleanup"
BwPT PR-10, Revision 0, " Process Radiation Monitoring Miscellaneous
Monitors (Safety-Related)"
BwPT PR-14, Revision 1 and Retest 129, " Process Radiation Monitoring
Loop 3"
BwPT PR-16, Revision 1, " Wide Range Gas Monitor (WRGM) Radiation Detector
Monitor"
BwPT PS-12, Revision 1, " Process Sampling - Hydrogen Monitors"
BwPT VD-15, Revision 2, "Intergrated Diesel Gen., Misc. Elect. and Switch
Gear Room Ventilation"
BwPT VP-10, Revision 2, " Containment Ventilation"
BwPT VP-11, Revision 2, " Containment Ventilation"
BwPT VQ-11, Revision 1, "Off Gas System Hydrogen Recombiners"
No violations or deviations were identified.
5.
Preoperational Test Results Evaluation
The inspector reviewed the results of the below listed preoperational
test procedures to verify all test changes were identified and approved
in accordance with administrative procedures; all test deficiencies were
appropriately resolved, reviewed by management and retested as required;
test results were evaluated by appropriate engineering personnel and
specifically compared with acceptance criteria; data was properly
recorded, signed, dated, and documented as test deficiencies, as
necessary; test packages were reviewed by QA for adequacy of contents;
and test results were approved by appropriate personnel.
BwPT EF-10, Revision 3, " Unit One D aineered Safety Features"
BwPT EF-11, Revision 2, "ECCS Full Flow"
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BwPT SI-10, Revision 0, " Safety Injection"
With respect to EF-10, the inspector has the following comments:
a.
(1) Test Change Request (TCR) No. 31 changed the required starting
time for the reactor containment fan coolers (RCFCs) from less
than 20 seconds to 20 - 40 seconds.
The licensee's
justification for the TCR was in response to deficiency
EF-10-239, which states that Technical Specification
Table 3.3-5 start time of 40 seconds is applicable. However,
the time stated in the table includes the time required to
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start and load the emergency diesel generator (10 seconds).
The timing in the test does not include a diesel generator
start and as such, the required starting time should be
30 seconds or less.
Since all the RCFCs did start in less
than 30 seconds in the test, this is not a concern of the fans
performance.
However, the corrective action for the deficiency
is not correct and the test procedcre is also in error.
The
licensee has written a Test Procedure Open Item (TPOI) EF-50-09
to correct the Unit 2 test procedure.
(2) TCR No. 25 repositioned the point of contact on two permanently
installed jumpers and then returned them to their original
location.
The procedure should have required an independent
verification when moving these jumpers.
In addition the
procedure should be made clearer in that there are two jumpers
that are being repositioned.
The licensee has initiated TPOI
EF-50-07 to correct the Unit 2 test procedure.
(3) The notes prior to steps 9.65.96 and 9.70.96 are not correct in
that they state that certain valves will be verified as not
repositioning after an ESF signal is reset in the following steps.
The repositioning of the valves had been verified in p evious
steps in the test procedure and not in the steps following the
notes.
The licensee has initiated TPOI EF-50-06 to correct
the Unit 2 test procedure.
(4) Sections 9.65 and 9.70 did not verify that valve 1AF057B would
remain open after the ESF signal was removed.
This function was
tested in BwPT AF-10.
The licensee has initiated TPOI EF-10-08
to correct the Unit 2 test procedure to ensure the feature is
checked in EF-50.
(5) It was noted that throughout the test there were numerous typos,
steps incorrectly marked as acceptance criteria, acceptance
criteria steps not listed in Section 4, and although Train A and
B tests are identical, their designated acceptance criteria steps
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were different.
Theseinconsistencieswherealsothesubjectof
a Quality Assurance Finding in audit QAA 20-86-EF10-1.
Even
though the test contained these errors, it appeared that the test
adequately tested the design features of the ESF System.
The
licensee has initiated AIR R20-86-054 to correct these
inconsistencies in the completed test package
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To ensure that the Unit 2 test procedure is updated for items (1),
(2), (3), and (4) above, they will be considered an open item
(457/86050-01(DRS)) pending incorporation of the TPOIs into the
Unit 2 preoperational test, EF-50.
b.
With respect to BwPT EF-11, the inspector has the following
comments:
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(1) Deficiency EF-11-AK stated that the IB Containment Spray (CS)
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pump's flow in the injection phase was less than 3795 gpm (i.e.
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3787 gpm).
The corrective action was to add the eductor flow
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of.141 gpm to obtain a flow greater than 3795 gpm. This is
incorrect as the FSAR, Section 6.5.2.2, requires the flow to
the spray rings to be greater than 3795 gpm (eductor flow does
.not go to the spray rings).
The second statement in the
-corrective action states that the note after acceptance Criteria
4.2 is applicable so the flow is acceptable.
This is incorrect
since the note pertains to the CS pumps in the recirculation
phase and not the injection phase.
This is considered an
unresolved item (456/86060-01(DRS)) pending license ev61uation
as to how the acceptance criteria was met.
(2)' Deficiency 'EF-11-24 stated that the eductor flow was greater
than the expected 140 gpm (i.e. 141 gpm).
The corrective action
states that.the acceptance criteria total flow should be greater.
than 3795 gpm. .This is incorrect as the flow for the injection
phase per the FSAR should be 3795 gpm to the spray rings and 130
gpm eductor flow for a total flow of 3925 gpm.
The second statement in the corrective action accepting the
eductor flow as-is is acceptable.
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(3) Step 9.5.55 has acceptance criteria signs for the CS pumps during
the injection phase although there is no acceptance criteria
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listed in Section 4.
.Since the test has been completed, the only
corrective action necessary will be to ensure that the Unit 2
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preoperational test contains applicable acceptance criteria.
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This will be considered an open item (50-457/86050-02(DRS))
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pending incorporation of the procedural deficiencies into the
Unit 2 test.
The incorrect corrective action to the deficiencies listed above are
further examples'of violation 86052-01 discussed in Inspection Report
No. 50-456/86052. It appears that the resolution to these deficiencies
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showed a lack of understanding of the Engineered Safety Features and
Containment Spray systems.
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No violations or deviations were identified.
However, a portion of this
area requires further licensee justification for CS pump flow rates and is
considered unresolved; portions require _. incorporation _ of TPOI's into Unit 2
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tests; and portions are further examples of inadequate corrective action
for violation 86052-01 in Report No. 50-456/86052.
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6.
Preoperational Test Results Verification
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The inspector reviewed the following preoperational test procedures and
verified that results were reviewed against approved acceptance criteria
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and an evaluation of the test results had been performed in accordance
with Regulatory Guide 1.68 and the licensee's Startup Manual.
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BwPT AB-10, Revision 2 and Retest 52, " Boric Acid Processing System"
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BwPT AR-14, Revision'0, " Area Radiation Monitoring (Loop 4)"
BwPT EM-11, Revision 1, " Strong Motion Seismic Instrumentation System"
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BwPT FC-10, Revision 0 and Retest 37, " Fuel Pool Cooling and Cleanup"
BwPT PR-10, Revision 0, " Process Radiation Monitoring Miscellaneous
Monitors (Safety-Related)"
BwPT PR-11, Revision 3 and Retest 120, " Process Radiation Monitoring
Loop 1"
BwPT PR-13, Revision 1 and Retest 124, " Process Radiation Monitoring
Loop 3"
BwPT PR-14, Revision 1 and Retest 129, " Process Radiation Monitoring
Loop 4"
BwPT PR-16, Revision 1, " Wide Range Gas Monitor (WRGM) Radiation Detector
Monitor"
BwPT PS-12, Revision 1, " Process Sampling - Hydrogen Monitors"
BwPT VD-15, Revision 2, "Intergrated Diesel Gen., Misc. Elect and Switch
Gear Room Ventilation"
BwPT VP-10, Revision 2, " Containment Ventilation"
BwPT VP-11, Revision 2, " Containment Ventilation"
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BwPT VQ-11, Revision 1, "Off Gas System Hydrogen Recombiners"
With respect to VP-10, the inspec' tor has the following comment:
a.
The test procedure stated that the RCFCs should start in 20-45
seconds.
In the PED approval letter dated May 1, 1986, PED stated
that the start time should have been less than 40 seconds per
Technical Specifications.
Since all fans did start in less than
30 seconds it was not a concern.
However, as discussed in
Paragraph 5.a.(1), the start time used as the acceptance criteria
should be less than 30 seconds and not less than 40 seconds.
The
licensee has initiated TPOI VP-50-01 to address this concern for
Unit 2.
This item will be considered an open item (457/86050-03(DRS))
pending incorporation of the TPOI into BwPT VP-50.
b.
With respect to VP-11, the inspector has the following concern:
Some of the fans (e.g. IVP01CA, 1VP02CA, and IVP02CB) in the test
did not meet their flow acceptance criteria.
Deficiencies VP-11-E,
L, and M were initiated in each case and closed stating that the
flow is acceptable because it agrees with the Braidwood Station
Testing, Adjusting, Balancing (TAB) Report.
The inspector's review
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determined that the flow data in the test had not been corrected for
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density.
This function is performed by the Project Engineering
Department, (PED); however, there is no mention in the test that the
flows have to be corrected for density, who will perform it, nor are
.the corrected values recorded in the test for the station to use as a
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reference. The inspector has requested that PED provide the corrected
flow data to the inspector for review. This will be considered an
open item (456/86060-02(DRS)) pending receipt of the corrected flow
data.
The closure of these deficiencies based on the TAB report appear to be
in error.
Since PED performs the calculations for corrected flow,
the~ deficiencies should have been closed to those calculations that
proved that the flows were adequate or to an evaluation as to why
the flows are acceptable. This inadequate corrective action for a
deficiency is a further example of violation 86052-01 discussed in
Inspection Report 50-456/86052.
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With respect to VQ-11, the inspector has the following comment:
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FSAR Table 6.2.59 lists the hydrogen recombiner reaction chamber gas
temperature as 1325 F maximum.
The acceptance criteria in the test
procedure requires the temperature to be between 1302 F and 1348* F
which is in conflict with the FSAR's maximum temperature requirement.
The data obtained during the test was at or below 1325* F and as such
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is not a concern.
The licensee has initiated TPOI VQ-51-002 to
address this conflict for Unit 2.
This will be considered an open
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item (457/86050-04(DRS)) pending incorporation of the TPOI into
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No violations or deviations were identified.
However, portions of this
area require additional information; portions require incorporation of
TP01s into Unit 2 test procedures; and portions contain further examples
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of inadequate corrective action for violation (50-456/86052-01) in
Inspection Report No.50-456/86052.
'7.
Open Items
Open items are matters which have been discussed with the licensee, which
will be reviewed further by the inspector, and which involve some action
on the part of NRC or licensee or both. Open items disclosed during the
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inspection are discussed in Paragraphs 5.a, 5.b.(3), 6.a, 6.b, and 6.c.
8.
Unresolved Items
An unresolved item is a matter about which more information is required
in order to ascer'ain whether it is an acceptable item, an open item, a
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deviation, or a v.olation.
Unresolved items disclosed in the inspection
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report are discussed in Paragraph 5.b.(1).
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Exit Interview
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The inspector met with licensee representatives (denoted in Paragraph 1)
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throughout and at the conclusion of the inspection and summarized the
scope and findings of the inspection activities.
The licensee acknowledged
the findings.
After discussions with the licensee, the inspectors have
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determined there is no proprietary data contained in this inspection report.
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