ML20236N094
| ML20236N094 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 07/06/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20236N089 | List: |
| References | |
| 50-456-98-08, 50-456-98-8, 50-457-98-08, 50-457-98-8, NUDOCS 9807150005 | |
| Download: ML20236N094 (17) | |
See also: IR 05000456/1998008
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U.S. NUCLEAR REGULATORY COMMISSION
REGIONlli
Docket Nos: 50-456,50-457
Report No: 50-456/98008(DRP); 50-457/98008(DRP)
Licensee: Commonwealth Edison Company
Facility: Braidwood Nuclear Plant, Units 1 and 2
Location: RR #1, Box 84
Braceville,IL 60407 j
Dates: April 21 through June 8,1998
Inspectors: C. Phillips, Senior Resident inspector
J. Adams, Resident inspector
D. Pelton, Resident inspector
- Z. Falevits, Lead Engineer
T. Esper, Illinois Department of Nuclear Safety
Approved by: M. Jordan, Chief
Reactor Projects Branch 3
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EXECUTIVE SUMMARY l
Braidwood Nuclear Plant, Units 1 & 2
NRC Inspection Repod 50-456/98008(DRP); 50-457/98008(DRP)
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This inspection included aspects of licensee operations, maintenance, engineering, and plant
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suppod. The report covers a 7-week period of resident inspection from April 21 through
June 8,1998.
Operations
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The inspectors concluded that the Unit 2 operators monitored pressurizer pressure poorly J
after securing backup heaters and did not re-energize the heaters in time to prevent
pressurizer pressure from going below the lower Technical Specification limit. The
operators secured the heaters to reduce the station electrical load to support electrical
grid needs during unseasonably hot weather. (Section O1.1)
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The inspectors were concemed about the frequency of mispositioned equipment events. '
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Six valves were mispositioned in the month of May. All of the valves were
non-safety-related and none of the mispositioning events resulted in a plant transient.
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The inspectors agreed with the licensee's conclusion that the number of equipment
mispositioning events that involved or affected safety-related equipment or that were
considered significant, declined from a year ago. However, the inspectors observed that
the number of equipment mispositioning events were increasing in 1998 which is
noteworthy and warrants consideration. (Section 01.2)
Maintenance
- The inspectors concluded that the replacement of the Unit 2 rod control negative 24 volt J
direct current power supplies in the shutdown Control Rod Banks B, C, and E cabinet was
planned and executed well. The instrument maintenance technicians demonstrated a
high level of proficiency as a result of excellent pre-job training and the careful validation
of the maintenance procedure. (Section M1.1)
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The inspectors concluded that the results obtained during four surveillance tests
observed during the inspection period met acceptance criteria. The inspectors also
concluded that the surveillance tests adequately tested the respective system to verify
that it would function per design. (Section M1.2)
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The ir'spectors concluded that the licensee was accurately counting and reporting the
number of Technical Specification surveillance pump and valve test failures in response
to commitments by Comed associated with the NRC's request for information pursuant to
10 CFR 50.54(f) regarding cyclical safety performance at Comed's nuclear stations.
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(Section M7.1)
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- The inspectors concluded that the licensee was accurately calcu!ating and reporting the
percent of corrective maintenance rework in response to commitments by Comed
associated with the NRC's request for information pursuant to 10 CFR 50.54(f) regarding
cyc!ical safety performance at Comed's nuclear stations. (Section M7.2) 1
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Enaineerina
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The inspectors concluded, following a review of three safety-related engineering
requests, that engineering personnel used appropriate technical evaluations and
engineering judgement to support their responses. The inspectors concluded that
engineering personnel documented their responses well and in accordance with
Braidwood Administrative Procedure 2320-2," Engineering Requests." (Section E2.1)
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The inspectors concluded that the licensee took inadequate corrective actions in
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response to a previous NRC violation regarding non-environmentally qualified safety-
- related equipment subject to a harsh environment in the event of an accident. No actions
! were taken to identify other non-environmentally qualified safety-related equipment
located in an area that could become a harsh environment until questioned by the j
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inspectors. The licensee later identified three more examples of non-environmentally ,
qualified safety-related equipment. A violation was issued. (Section E 8.1)
l Plant Support i
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The inspectors concluded that security personnel performed access control
responsibilities in an expeditious and professional manner in accordance with the i
requirements contained in applicable station procedures. The inspectors concluded that
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procedures.. (Section S1,1)
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' The inspectors concluded that contractor personnel performing work associated with the
Unit 1 steam generator replacement project failed to de-energize a welding machine and
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' failed to bleed off the pressure in the hoses of an oxygen-acetylene torch prior to leaving
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Administrative Procedure 1100-15, " Fire Prevention When Welding, Cutting, Grinding or
Performing Open Flame Work (Hot Work)." A violation was issued. (Section F4.1)
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Report Details
Summary of Plant Status
Unit 1 entered the period at full power and remained at or near full power for the entire period.
Unit 2 entered the period at full power and remained at or near full power for the entire period. I
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l. Operations
01 Conduct of Operations
O1.1 Unit 2 Pressurizer Pressure Reduction Below Technical Specification (TS) Limits
a. Inspection Scope (71707 )
The inspectors reviewed the shift manager's logbook for May 18 and Problem
Identification Form (PlF) A1998-01811.
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b. Observations and Findinas 1
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On May 18, Unit 2 operators secured the B group of pressurizer backup heaters. The
operators did not adequately monitor pressurizer pressure which dropped faster than
anticipated. Pressurizer pressure dropped from a nominal 2235 pounds per square inch
gauge (psig) to a minimum of 2219 psig before the group B pressurizer backup heaters
were re-energized. Both Units 1 and 2 normally operate with two of the three groups of
backup heaters energized and the pressurizer spray valves open. The operators entered
TS 3.2.5, which required that pressurizer pressure be restered to 2219 psig within
2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Pressurizer pressure was restored to 2219 psig in 7 minutes. l
The heaters were secured because operators were looking for a way to reduce station
electrical load. Electrical grid conditions in northem lilinois were such that electrical
demand exceeded the supply. Operations management addressed the problem at
operations shift tumovers by stating that securing pressurizer heaters was acceptable. ]
The licensee was investigating why the pressurizer pressure decreased more rapidly than
anticipated with one group of pressurizer heaters secured. The licensee completed
preventive maintenance on the pressurizer heater breakers the previous week and
verified that the correct number of heaters were functioning. The licensee scheduled
maintenance activities to check that the heaters were operating at the rated capacity, to
check the set points for the variable pressurizer heater controller, and to check the spray
flow rate through the attemate spray valve.
c. Conclusions
The inspectors concluded that the Unit 2 operators monitored pressurizer pressure poorly
after securing L ackup heaters and did not re-energize the heaters in time to prevent
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pressurizer pre ssure frcm ;;oing relow the lower Technical Specification limit. The
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operators secured the heaters to reduce the station electricalload to support electrical
grid needs during unseasonably hot weather.
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01.2 ' Configuration Control Problems Continue
a. InsDeClion Scong (71707)
The inspectors reviewed the sections of the Operations Department First Quarter 1998
Self-Assessment and additional self-assessments that addressed out-of-service and
configuration controlissues. The inspectors reviewed the following PlFs: A1998-01777,
A1998-01793, A1998-01708, A1998-01812, A1998-01875, and A1998-01684. The
inspectors also discussed the topic of configuration control with senior operations
management.
b. - Observations and Findinas
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The inspectors reviewed the sections of the Operations Department First Quarter 1998
Self-Assessment information that acciressed configuration control and equipment
mispositionings. The inspectors agreed with the licensee's conclusion that the number of
mispositionings that have affected safety-related equipment or resulted in a significant
event declined from a year ago. However, the total number of equipment mispositionings
averaged between three and four per month in 1998, with an increasing trend. The
inspectors also noted that between May 1 and May 26 the licensee identified six
mispositioned valves. The licensee was unable to identify the root cause of any of these
mispositionings by the end of the inspection period.
' The following corrective actions have been taken or planned to improve configuration
control and equipment mispositioning performance. Operations management conducted
and planned to continue to hold event review boards with operators involved with
equipment configuration problems. The purpose was to increase personal accountability.
Specific training on equipment control, independent verification, and equipment line-ups
was completed for non-licensed operators, and training for licensed operators was
planned. Operations management distributed a plant equipment control memorandum to '
designate equipment that could be operated by plant personnel other than operators. For
example, radiation protection technicians would be responsible for and have operational
authority over the analysis / sampling segments of the process radiation system.
Continued training on human performance error reduction techniques and quarierly
human performance sessions was planned. The licensee also initiated a trend
investigation into mispositioned equipment.
c. Conclusions
The inspectors were concemed about the frequency of mispositioned equipment events.
Six valves we** mispositioned in the month of May. All of the valves were non-safety-
related and * one of the mispositioning events resulted in a plant transient. The
inspectors agreed with the licensee's conclusion that the number of equipment
mispositioning events that involved or affected safety-related equipment or that were
considered significant, declined from a year ago. However, the inspectors observed that
the number of equipment mispositioning events were increasing in 1998 which is
noteworthy and warrants consideration.
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08 Miscellaneous Operations issues (92901)
08.1 (Closed) Violation 50 456/97005-01(DRP): 50-457/97005-01(DRP): The inspectors
observed that Unit 1 Braidwood Functional Recovery Procedure (18wFR)-S.1, " Response
l- to Nuclear Power Generation / Anticipated Transient Without Scram Unit 1," Revision 1 A,
Step 4a, had not been maintained in that it diracted operators to start the chemical and
volume control system positive displacement charging pump if neither of the centrifugal
charging pumps could be started. The positive displacement charging pump was out-of-
service and had not run for about 10 years. Licensee management was trying to decide l
l whether to abandon the positive displacement pump in place or maintain it. The licensee
changed 1BwFR-S,1, Step 4a, to read, " Start a centrifugal charging pump. If neither
l pump will start, then start the positive displacement pump if available. If no charging
pump can be started then go to Step 5." The inspectors had no further concems. This
violation is closed.
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08.2 (Closed) Violation 50-457/97016-01(DRP): The inspectors identified that licensee
personnel failed to make a required notification in accordance with 10 CFR 50.72(b)(2)(ii)
after an automatic isolation of the containment ventilation system. Operations personnel
use the licensee's " Deportability Manual" to determine the deportability of any event. The
licensee's manual specifically stated that the containment ventilation isolation was not
reportable. However, this was in conflict with regulatory requirements for reporting. The
licensee changed the " Deportability Manual" to specifically state that a containment
ventilation isolation was a reportable event. The event was reported in Licensee Event
Report (LER) 50-457/97004-00. The inspectors had no further concems. This violation is
clost*d.
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11. Maintenance
M1 Conduct of Maintenance
M1.1 Replacement of Unit 2 Rod Control Shutdown Banks B. C. and E Cabinet Power Supolies
a. Inspection Scope (62707)
The inspectors reviewed Work Request 980038329 for the replacement of the Unit 2 rod
control system shutdown bank power supply. The inspectors attended a licensee
management meeting and an infrequently performed activity briefing regarding the
replacement of the Unit 2 rod control system power supply,
b. Observations and Findinas
On April 25, the licensee identified that one of the two negative 24 volt direct current
power supplies in the shutdown Control Rod Banks B, C, and E power supply cabinet had
failed. On April 27, the inspectors observed portions of the replacement of the two
negative 24 volt direct current power supplies. Only 30 percent of previous industry
attempts to replace these power supplies with the reactor at power were successful.
Mistakes at several stations during power supply replacements at power resulted in
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The inspectors observed that licensee management clearly communicated the potential
operationalimpact of the maintenance activity to the maintenance technicians and to the
operators. Contingencies for a plant transient were also clearly communicated to the
maintenance technicians and to the operators.
Maintenance department management obtained a procedure from another utility that was
recently successful in replacing the power supplies with the reactor at power.
Maintenance department management also sent two instrument maintenance
technicians, a foreman, and the system engineer, to a Westinghouse facility in Pittsburgh,
Pennsylvania, to practice the replacement using the work package procedure on similar
equipment. The inspectors reviewed the power supply replacement procedure and
determined that it was written well. The inspectors observed that the work progressed
quickly and smoothly. The instrument maintenance technicians demonstrated a high
level of proficiency during the replacement of the power supplies and detailed knowledge
b of the procedure.
c. Conclusions
The inspectors concluded that the replacement of the Unit 2 rod control negative 24 volt
direct current power supplies in the shutdown Control Rod Banks B, C, and E cabinet was
planned and executed well. The instrument maintenance technicians demonstrated a
) high level of proficiency as a result of excellent pre-job training and the careful validation
} of the maintenance procedure.
M1.2 Surveillance Observations
a. Inspection Scope (61726)
The inspectors reviewed the following procedures and observed portions of the
associated surveillance tests:
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Unit 1 Braidwood Engineering Surveillance Procedure (1BwVS) 3.1.3.2,
" Moderator Temperature Coefficient At Power," Revisions 0 and OE1;
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2BwVS 5.2.f.3-2, "ASME [American Society of Mechanical Engineers)
Surveillance Requirements For Residual Heat Removal Pump 2RH01PB,"
Revision SE1;
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2BwVS 0.5-3.DO.1, "ASME Requirement For Testing The Diesel Oil Transfer
System," Revision 1; and
- 18wVS 1.2.3.1-1, "ASME Surveillance Requirements For The 1A Centrifugal
Charging Pump and Check Valve 1CV8480 A Stroke Test," Revision 1.
b. Observations and Findinas
The inspectors compared the surveillance test requirements against the TS requirements
and the Updated Final Safety Analysis Report (UFSAR) design descriptions and found no
discrepancies. The test results met the acceptance criteria for the surveillance
observed.
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c. Conclusions
The inspectors concluded that the results obtained during four surveillance tests
observed during the inspection period met acceptance criteria. The inspectors also
concluded that the surveillance tests adequately tested the respective system to verify
that it would function per design.
M2 Maintenance and Material Condition of Facilities and Equipment
M2.1 Untested Safeauards Actuation Relav Contacts
a. Inspection Scope (92902)
The inspectors interviewed licensee system engineers. The inspectors also reviewed
Electrical Drawing 20E-1-4030EF01 and a licensee prepared position paper, " Position
Regarding Testing of Engineered Safety Feature Circuitry and Application to K608 Slave
Relay Circuitry," dated May 11,1998.
b. Observations and Findinas
On May 7, the licensee identified that contacts associated with the safeguards actuation
relays were not tested. The purpose of the relays was to simultaneously (block) start the
emergency core cooling pumps in the event of a safety injection signal if offsite power is
available. The block start contacts are in parallel with the sequencing contacts used to
start the emergency core cooling pumps if a safety injection signal occurs simultaneously
with a loss of off-site power. The sequencing contacts would also start the emergency
core cooling pumps if off-site power were available, (redundant to the function of the
block start contacts). The licensee's position paper stated that the sequencing of the
loads was credited for in the UFSAR and that the block start capability was redundant
and not required to be tested by TS 4.3.1,4.3.2, or 4.8.1.
The inspectors planned to review the licensee's position paper and discuss the
appropriateness of testing the safeguards actuation relay contacts with the office of
Nuclear Reactor Regulation management. Whether TS require the testing of the
safeguards actuation relay contacts is an unresolved item (50-456/98008-01(DRS);
50-457/98008-01(DRS)).
M7 Quality Assurance in Maintenance Activities
M7.1 Failed TS Pump and Valve Surveillance Review
a. Inspection Scope (92702)
The inspectors interviewed the data steward for the failed TS pump and valve
surveillance performance indicator.
b. Observations and Findinas
The licensee committed in its March 28,1997, response to the NRC's request for
information pursuant to 10 CFR 50.54(f) regarding cyclical safety performance at Comed
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nuclear stations, to report to the NRC the number of failed pump and valve TS
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surveillance. In 1998, there were two failed surveillance. The inspectors verified that
I the two examples met the licensee's criteria for failed surveillance. The inspectors did
I not identify any other survei!!ance test results that should have been counted as a failure
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c. Conclusions
The inspectors concluded that the licensee was accurately counting and reporting the
number of TS surveillance pump and valve test failures in response to licensee
commitments by Comed associated with the NRC's request for information pursuant to
10 CFR 50.54(f) regarding cyclical safety performance at Comed's nuclear stations.
M7.2 Percent Rework Review
a. Inspection Scope (62707)
The inspectors interviewed the individual responsible for accumulating the data for the
percentage of maintenance rework.
b. Observations and Findinos
The licensee committed in its March 28,1997, response to the NRC's request for
information pursuant to 10 CFR 50.54(f) regarding cyclical safety performance at Comed
nuclear stations, to report to the NRC the percentage of reworked maintenance. The
inspectors verified that the licensee was reporting a 3-month rolling average of the
percent of reworked corrective maintenance. The licensee does not count a preventive
maintenance item that results in later rework in the percentage. The reason was that if
the number of preventive maintenance activities were added to the number of corrective
maintenance activities the percentage of rework would be very low and be a poor
indicator. The inspectors agreed with this conclusion.
c. Conclusions
The inspectors concluded that the licensee was accurately calculating and reporting the
percent of corrective maintenance rework in response to commitments associated with
the NRC's request for information pursuant to 10 CFR 50.54(f) regarding cyclical safety
performance at Comed's nuclear stations.
M8 Miscellaneous Maintenance issues (92902)
M8.1 ! Closed) Violation 50-456/96019-02fDRP): On November 7,1996, workers were
erecting scaffolding in front of the traveling screens in the lake screen house. The
workers dropped an 8-foot scaffold pole through a traveling screen opening into the bay.
The inspectors verified that there were no strainers or screens to prevent the introduction
of foreign materialinto the essential service water system pump suction. The licensee's
immediate corrective action was to install temporary covers over the traveling screen i
openings to prevent foreign materialintrusion into the bay. The licensee's long term
corrective action was to install permanent hinged covers over the openings of the
traveling screens. The inspectors have verified the installation of the permanent hinged
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covers on all but one of the traveling screens. The inspectors verified that the installation
of the remaining iraveling screen cover was in the maintenance schedule for June 1998.
This item is closed.
Ill. Enaineerina
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l E2 Engineering Support of Facilities and Equipment
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l E2.1 Review of Safetv-Related Enaineerina Reauests
a. Inspection Scope (37551)
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The inspectors reviewed safety-related Engineering Requests ER 9800743, " Evaluation
of the Use of the Spare Barton Gauges For Use as Residual Heat Removal Pump (
Minimum Flow Indicating Switch," ER 9800810, " Installation of North Battery
Rack 1DCO2EB Per M20-1-96-001," and ER9800800, " Erection of Barricade in Diesel
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Generator Exhaust Silencer and Rupture Disk Areas." The inspectors also reviewed
Braidwood Administrative Procedure (BwAP) 2320-2," Engineering Requests,"
Revision 5.
b. Observations and Findinas
The inspectors reviewed three safety-related engineering requests and concluded that
each provided a response that was based on appropriate technical evaluations and
engineering judgement. The inspectors noted that each of the engineering requests were
documented in accordance with BwAP 2320-2. The inspectors also noted that
BwAP 2320-2 clear 1y described the process by which engineering requests are submitted,
completed, and controlled.
c. Conclusions
The inspectors concluded, following a review of three safety-related engineering
requests, the engineering personnel used appropriate technical evaluations and
engineering judgement to support their responses. The inspectors concluded that
engineering personnel documented their responses well and in accordance with
Braidwood Administrative Procedure 2320-2," Engineering Requests."
E8 Miscellaneous Engineering issues (92903)
E8.1 (Closed) Violation 50-456/97012-(.5(DRS): The licensee failed to prevent the installation
of a non-environmentally qualified breaker subject to a harsh environment. Following
NRC questioning, the licensee identified that on February 18,1997, a
non-environmentally qualified circuit breaker was erroneously installed in the 1 A residual
heat removal pump minimum flow valve circuit breaker cubicle, which was subject to a
harsh environment in the event of an accident. The breaker was changed out under
Setpoint/ Scaling Change Request 95-049. An incorrect store item number (767C26) was
specified by the engineer for the replacement breaker. This store item number was for a
non-environmentally qualified breaker. This error was not identified by the work analyst
and the quality controlinspectors.
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To address this problem, the licensee generated Operability Determination 97-098, dated
i August 11,1997, to evaluate operability of the breaker. The licensee concluded that the
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installed breaker would be able to perform its safety function. In addition, the
non-environmentally qualified breaker was replaced on August 26,1997. Design
engineering personnel, work analysts, and maintenance personnel were informed of this
event and provided appropriate training.
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l prevent recurrence. On April 7,1998, the inspectors questioned the licensee as to
whether a generic review of work history records had been conducted to determine if
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any motor control center located in an area that could be subject to a harsh environment.
l Subsequently, on April 9,1998, the licensee issued PlF A1998-01350 to document the
discovery in Motor Control Centers 1/2AP21E of non-environmentally qualified
safety-related components including a breaker, some thermal overloads and a meter.
The licensee performed a preliminary review of the safety-related, non-environmentally
qualified items and determined that they were still operable. The licensee completed
Operability Determination 98-029 in which it was concluded that the safety-related
components were operable.
This violation is considered closed since the original non-qualified breaker was replaced.
However, the licensee's failure to implement comprehensive and effective corrective
action to prevent recurrence is considered a violation of 10 CFR Part 50, Appendix B,
Criterion XVI (50-456/98008-02(DRS); 50-457/98008-02(DRS)).
E8.2 (Closed) LER 50-456/96004-00: On March 21,1996, the licensee identified that
surveillance procedure BwVS 6.2.2.d-1 " Containment Spray Additive Flow Rate
Verification," failed to incorporate a density adjustment for water flowing through a flow
cell calibrated for a sodium hydroxide solution. During the design basis reconstitution of
the containment spray system and the spray additive system, the licensee identified that
the UFSAR description vras incorrect and contained conflicting information. The licensee
also determined proper f,ow set'ings for spray additive flow and eductor motive flow. The
licensee made changes tc., the UFSAR to remove incorrect and/or conflicting information
and changed the TS surveillance test procedures to reflect the proper spray additive tank
level, spray additive flow rate, and eductor motive flow rate. The inspectors observed the
performance of the surveillance test in accordance with BwVS 6.2.2.d-1 and verified that
all acceptance criteria, TS requirements and UFSAR commitments / conditions were met.
The licensee determined that during e.t early segment of the injection phase of a
containment spray actuation, the pH of the spray additive solution injected into the
containment atmosphere could exceed the environmental qualification pH limits of certain
equipment inside the containment for about 31 minutes. The licensee performed an
operability determination and an evaluation of equipment environmental qualification at
increased pH and concluded that there would be no adverse effect. An analysis
performed by the NRC staff also arrived at a similar conclusion. A non-cited violation was
issued in Inspection Report 50-456/98005 for exceeding the TS limit for spray additive
flow. The licensee's immediate and long-term corrective actions have been completed
and were considered appropriate. This item is closed.
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IV. PLANT SUPPORT
So Conduct of Security and Safeguards Activities
S1,1 Access Control to Site Protected Areas
a. Inspection Scope (71750)
The inspectors observed security personnel controlling access to site protected areas.
The inspectors reviewed Braidwood Administrative Procedure 900-4," Access Control,"
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Revision 15; Braidwood Security Procedure 03, " Personnel and Package Entry / Exit
Procedure," Revision 10; Corporate Nuclear Security Guideline Number 100, "X-Ray
Search," Revision 3; Corporate Nuclear Security Guideline Number 101,
" Package / Material Search," Revision 1; and Corporate Nuclear Security Guideline
Number 10, " Personnel Search / Ingress," Revision 3.
b. Observations and Findinas
On May 5, the inspectors observed security personnel conducting searches of individuals
authorized unescorted access to the main plant site and the lake screen house protected
areas. The inspectors observed security personnel monitor plant personnel as they
passed through metal and explosive detectors, perform x-ray inspection of hand carried
items, perform occasional pat-down searches of personnel entering the site, escort
individuals from the main plant site to the lake screen house, and admit personnel to the
lake screen house protected area. The inspectors discussed access control
requirements with security personnel and determined that they were knowledgeable of l
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c. Conclusions
The inspectors concluded that security personnel performed access control
responsibilities in an expeditious and professional manner in accordance with the
. requirements contained in applicable station procedures. The inspectors concluded that '
security personnel were knowledgeable of the requirements contained in those
procedures.
F. Fire Protection Staff Knowledge and Performance
F4.1 Failure to Follow Fire Protection Proaram Requirements
a. - Inspection Scope (71750)
The inspectors routinely monitored maintenance work areas. The inspectors reviewed
Procedures BwAP 1100-10," Control and Use of Flammable and Combustible Liquids and
Aerosols," Revision 2; BwAP 1100-11, " Fire Prevention for Use of Lumber and Other
Combustibles," Revision 7; and BwAP 1100-15, " Fire Prevention When Welding, Cutting,
Grinding or Performing Open Flame Work (Hot Work)," Revision 8. The inspectors also
interviewed operations, fire protection, and maintenance personnel.
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b. Observations and Findinas l
On April 24, the inspectors observed an unattended welding machine on the 411 foot
elevation of the fuel handling building that was energized. The inspectors reported the
energized welder to operations and fire protection personnel and the welding machine
was immediately de-energized by plant personnel.
Step C.2.8 of Procedure BwAP 1100-15 stetes, " Ensure welding machines are
de-energized, cylinder valves are isolated, and hoses are depressurized when the
assigned workers are not in the immediate area, or when these items are not in use
(i.e., during breaks, lunch, end of day, etc.)." Contrary to this step, the welding machine
was left energized and unattended. The failure to follow Plant Fire Protection Procedure )
BwAP 1100-15 was an example of a violation of TS 6.8.1.g, " Fire Protection Program
implementation," (50-456/98008-03a(DRP); 50-457/98008-03a(DRP)) as described in the
attached NOV.
On May 1, the inspectors observed a maintenance work area that was unattended while ,
the workers were on a scheduled break. The inspectors checked an oxygen-acetylene j
torch and observed that the cylinders'stop values were shut, however, the pressure !
regulator gauges indicated that the oxygen and acetylene hoses were pressurized. The
inspectors reported the conditions to operations and fire protection personnel and the
hoses were immediately de-pressurized by plant personnel. When the worker using the
oxygen-acetylene torch retumed to the work site, the inspectors questioned the worker on
the requirements for leaving the items unattended. The worker stated that he did not
know of any requirements for bleeding pressure off of gas lines.
Step C.2.8 of Procedure BwAP 1100-15 states, " Ensure welding machines are
de-energized, cylinder valves are isolated, and hoses are depressurized when the
assigned workers are not in the immediate area, or when these items are not in use
(i.e., during breaks, lunch, end of day, etc.)." Contrary to this step, the hoses of the
oxygen-acetylene torch were pressurized with oxygen and acetylene gas and left
unattended. The failure to follow Plant Fire Protection Procedure BwAP 1100-15 was an i
example of a violation of TS 6.8.1.g," Fire Protection Program implementation" j
(50-456/98008-03b(DRP); 50 457/98008-03b(DRP)) as described in the attached NOV. {
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c. Conclusions
The inspectors concluded that contractor personnel performing work associated with the !
!
Unit 1 steam generator replacement project failed to de-energize a welding machine and
failed to bleed off the pressure in the hoses of an oxygen-acetylene torch prior to leaving
them unattended which was contrary to the requirements contained in Braidwood
Administrative Procedure 1100-15, " Fire Prevention When Welding, Cutting, Grinding or
Performing Open Flame Work (Hot Work)."
F8 Miscellaneous Fire Protection issues (92904)
F8.1 (Closed) Inspection Followup ltem 50-456/96012-05fDRP): On August 14,1996, the
master selector valve (OCOO36) for the auxiliary building carbon dioxide system failed.
The licensee replaced the valve and sent the failed valve back to the manufacturer for
analysis. The manufacturer determined that the numerous opening and closing cycles
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experienced by the master selector valve during the performance of carbon dioxide fire
suppression system puff tests resulted in premature failure of the valve. The
manufacturer determined that the valve intemal materials were not adequate for the
number of times the valve was cycled and recommended installing valve intemal parts
made of upgraded materials. The valve failed again on April 3,1998, and was replaced
on April 4,1998, with a valve that had the upgraded parts installed (Work
Request 980034810). The inspectors had no further concems. This item is closed.
V. Manaaement Meetinas
X1 Exit Meeting Summary
.The inspectors presented the inspection results to members of licensee management and
staff at the conclusion of the inspection on June 8,1998. The licensee acknowledged the
findings presented. The inspectors asked the licensee whether any materials examined
during the inspection should be considered proprietary. No proprietary information was
identified.
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PARTIAL LIST OF PERSONS CONTACTED
Licensee
T. Tulon, Site Vice President
K. Schwartz, Station Manager
- R. Wegner, Operations Manager
- R. Byers, Maintenance Superintendent
A. Haeger, Health Ph/sics and Chemistry Supervisor
- R. Graham, Work Control Superintendent
- T. Simpkin, Regulatory Assurance Supervisor
C. Dunn, System Engineering Supervisor
J. Meister, Engineering Manager
- M. Cassidy, Regulatory Assurance - NRC Coordinator
NRC
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- M. Jordan, Chief, Reactor Projects Branch 3
C. Phillips, Senior Resident inspector
- J. Adams, Resident inspector
- D. Pelton, Resident inspector
T. Tongue, Project Engineer
IDNS
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T. Esper
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INSPECTION PROCEDURES USED
IP 37551: Onsite Engineering
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p IP 61726: Surveillance Observations
l IP 62707: Maintenance Observation
l- IP 71707: Plant Operations
IP 71750: Plant Support Activities
IP 92702: Followup on Corrective Actions For Violations and Deviations
- iP 92901: Followup - Plant Operations
IP 92902: Followup - Plant Maintenance
IP 92903: Followup - Engineering
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i IP 92904: Followup _- Plant Support
ITEMS OPENED AND CLOSED
Opened
! 50-456/98008-01; 50-457/98008-01 URI untested actuation relay contacts
- 50-456/98008-02; 50-457/98008-02 VIO failure to implement corrective action
50-456/98008-03; 50-457/98008-03 VIO failure to follow fire protection procedures
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50-456/96004-00 LER failure to density adjust CS flow rate
,
50-456/96012-05 IFl- failure of CO2 master selector valve
50-456/96019-02 VIO failure to maintain adequate procedures
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50-456/97005-01; 50-457/97005-01 VIO failure to maintain procedure
50-456/97012-06 VIO failure to prevent use of non-EQ breaker
failure to report ESF actuation )
50-457/97016-01 VIO
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LIST OF ACRONYMS USED
ASME American Society of Mechanical Engineers
BwAP Braidwood Administrative Procedure
BwFR Braldwood Functional Recovery Procedure
BwVS Braidwood Engineering Surveillance Procedure
CENT Centrifugal
CFR Code of Federal Regulations
DRP Division of Reactor Projects
DRS Division of Reactor Safety
IFl inspection Followup Item
LER Licensee Event Report
NRC Nuclear Regulatory Commission
NRR Nuclear Reactor Regulations
PlF Problem Identification Form
psig pounds per square inch
TS Technical Specification
UFSAR Updated Final Safety Analysis Report
URI Unresolved Item
VIO Violation
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