IR 05000456/1999002

Insp Repts 50-456/99-02 & 50-457/99-02 on 990120-0301.No Violations Noted.Major Areas Inspected:Aspects of Licensee Operations,Maint,Engineering & Plant Support

ML20204J922
Person / Time
Site:	Braidwood
Issue date:	03/23/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20204J904	List: IR 05000456/1999002 ML20204J900
References
50-456-99-02, 50-456-99-2, 50-457-99-02, 50-457-99-2, NUDOCS 9903300186
Download: ML20204J922 (23)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lli

Docket Nos: 50-456,50-457 License Nos: NPF-72, NPF-77 Report No: 50-456/99002(DRP), 50-457/99002(DRP)

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Licensee: Commonwealth Edison Company Facility: Braidwood Nuclear Plant, Units 1 and 2 l l

Location: RR #1, Box 84 Braceville,IL 60407 )

i Dates: January 20 through March 1,1999

Inspectors: J. Adams, Acting Senior Resident inspector D. Pelton, Resident inspector J. Neisler, Reactor inspector -

J. Roman, Illinois Department of Nuclear Safety I Approved by: Michael J. Jordan, Chief ,

Reactor Projects Branch 3 I I

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i 9903300186 990323 PDR ADOCK 05000456 G PDR

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EXECUTIVE SUMMARY Braidwood Nuclear Plant, Units 1 and 2 NRC Inspection Report 50-456/99002(DRP); 50-457/99002(DRP)

This inspection included aspects of licensee operations, maintenance, engineering, and plant support. The report covers a 6-week period of resident inspection from January 20 through i March 1,199 I Ooerrions The inspectors observed control room operators throughout the inspection period and concluded that operators routinely performed good turnover briefings, control board operations, response to alarms, and three-way communications. The unit supervisors demonstrated good performance in the minimization of control room distractions, in the direction of personnel, in the ccnduct of briefings, and in the control of evolutions. The inspectors concluded that the control room operators exhibited a heightened level of awareness to recent configuration control problems. (Section 01.1) .j The inspectors were notified and responded to the site on two occasions following the unusual event emergency declaration for the loss of Unit 1 annunciators. The inspectors concluded that the licensee properly classified the event, was timely in making the required notifications, and promptly implemented conservative I compensatory actions. The inspectors concluded that the operator aid containing instructions for the use of a temporary inverter was clearly written, and was understood by the operators. (Sectior. O4.1)

The inspectors responded to the control room following the plant notification for evacuation of the Unit 2 cable spreading room due to indication of the Halon fire suppression system initiation. The inspectors concluded that the Unit 2 unit supervisor demonstrated excellent command and control by providing timely direction to operators, by proparty prioritizing response efforts, and by promptly establishing compensatory fire watches. The control room operators promptly and accurately implemented supervisory direction by communicating with non-licensed operators, radiation protection, and security personnel. The inspectors concluded that the unit nuclear station operators were not distracted from monitoring of their respective control boards. No actual release of Halon occurred. (Section 04.2)

The inspectors reviewed six safety-related or risk significant apparent cause evaluations (ACES) and concluded that the ACES were completed within the required time, clearly stated the problem and the apparent causes, and proposed appropriate corrective actions to prevent recurrence. (Section 06.1)

Maintenance The inspectors observed all or portions of various maintenance activities and concluded that activities were performed in accordance with the applicable procedures and that the procedures provided the requisite information necessary to perform the work. The inspectors concluded that the licensee had effectively implemented maintenance rule

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requirements for the essential service water and the residual heat removal system (Section M1.1)

l The inspectors concluded that the five surveillance tests observed adequately tested the system, the operators followed the procedures, and that the procedures included the required sunieillance testing described in the Technical Specifications.(Section M1.2)

Enaineerina The inspectors concluded that the nine operability determinations reviewed reflected good engineering judgement and safety focus, compensatory actions were understood by operations personnel, and corrective actions were entered into the stations nuclear tracking system. (Section E1.1)

Based on a sample of four safety evaluations, the inspectors concluded that the safety evaluation program was implemented in accordance with 10 CFR 50.59 and the station procedures. (Section E1.2)

The inspector performed a walkdown of the auxiliary feedwater system and reviewed cystem design documentation and procedures. The inspectors concluded that the material condition of the auxiliary feedwater system was good and was aligned in accordance with plant procedures. (Section E2.1)

The inspectors concluded that the licensee made a significant effort to determine the root cause of failures in the Unit 1 annunciator system. The inspector concluded that the licensee's repairs and temporary modifications have placed the annunciator in an operable condition pending root cause determination and installation of permanent modifications or repairs. (Section E2.2)

Plant Support The inspectors observed the posting of radiation areas, the control of locked high radiation atuas, the application of ALARA principles, and the radiation work practices of station personnel. The inspectors concluded that radiologically controlled areas that were obsented were properly posted; that locked high radiation area doors observed were locked and properly controlled by radiation protection personnel; that ALARA controls, such as ALARA briefings, cameras, and remote reading dosimetry were used to minimize exposure to personnel; and that proper radiation work practices were demonstrated by the observed personnel. (Section R1.1)

The inspectors inspected eight floor plugs associated with rooms containing emergency core cooling equipment and concluded that each floor plug was properly installed and sealed. No barrier impairments existed on the inspected floor plugs and plug seals were free from degradation. (Section F2.1)

The inspectors inspected Appendix R emergency lights and concluded that the emergency lights were properly mounted, directed, and charged. Many of the lights had been recently updated. (Section F2.2)

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Report Details Summary of Plant Status

- Units 1 and 2 operated at or near full power for the entire period.

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l. Ooerations 0 Conduct of Operations  !

01.1 Control Room Observations -

$ Inspection Scope (71707)

. The inspectors observed the conduct of operation during normal operating conditions, during a maintenance activity to replace a rod controi relay, and during the performance of surveillance tests. The inspectors interviewed nuclear station operators, unit supervisors, and shift managers with regart to the ongoing activitie b Observations and Findinas The inspectors observed control room operators throughout the inspection period. The inspectors noted tnt the nuclear station operators were attentive, used operating procedures, used selMhecks when manipulating equipment, and used three-way communications. ' ,s operators promptly addressed alarms, referred to the annunciator response procedures, and informed supervisors of alarms. Additionally, the inspectors noted a heightened level of awareness among control room operators concerning

. configuration control. The inspectors noted that unit supervisors minimized control room distractions, clearly directed personnel, clearly communicated personnel assignments and plant status during shift briefings, and effectively controlled evolution Conclusions The inspectors observed control room operators throughout the inspection period and concluded that operators routinely performed good turnover briefings, control board operations, response to alarms, and three-way communications. The unit supervisors demonstrated good peiformance in the minimization of control room distractions, in the direction of personnel, in the conduct of briefings, and in the control of evolutions. The inspectors concluded that the control room operators exhibited a heightened level of awareness to recent configuration control problems.

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04 Operator Knowledge and Performance 04.1 Operator Pesponse To Unit 1 Annunciator Power Supolv Failures Insoection Scope (7170Z1 The inspectors responded to the control room and observed the performance of control room personnel following several failures of Unit 1 annunciator power supplies, two of which resulted in the declaration of an unusual event. The inspectors interviewed nuclear station operators, unit supervisors, and shift managers concerning the even Observations and Findinas

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On January 17,18,20, and 25, the licensee experienced failures of Unit 1 annunciator power supplies (see Section E2.2). The events on January 18 and 20, resulted in the failure of both the primary and backup power supplies with a significant loss of Unit 1 and Unit 0 annunciator lights, and the loss of the Unit 1 annunciator horn and bell features. The operators recognized the loss cf annunciators as a condition that required the declaration of an unusual event. The inspectors were notified and responded to the site for both the unusual events and observed the licensee's response. The inspectors determined that the licensee properly classified the event and was timely in making the requirad noufications. The inspectors observed the implementation of compensatory actions by contro: room operators. For example, the operating crew was augmented with additional nuclear station operators to monitor indications, operators promptly identifed inoperable annunciators, supervisors performed an annunciator-by-annunciator review of inoperable annunciatoi windows to identify available indications to monitor system status, and supervisors conducted shift briefingt 'ith the operating crews to discuss the event and the compensatory action On January 25, the licensee installed a temporary modification to add a redundant temporary inverter in parallel with the "C" inverter which provides power to the annunciator lights. In the event of a "C" inverter failure, the failed inverter can be isolated and its loads transferred to the temporary inverter. The licensee developed an operator aid to provide instructions to nuclear station operators on how to isolate the failed inverter and connect the temporary inverter. The inspectors reviewed the operator aid and walked through the actions with a nuclear station operator. The inspectors noted that the instructions on the operator aid were clearly written and were

. understood by the operator Conclusions The inspectors were notified and responded to the site on two occasions following the l unusual event emergency declaration for the loss of Unit 1 annunciators. The inspectors concluded that the licensee properly classified the event, was timely in ,

making the required notifications, and promptly implemented conservative  ;

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compensatory actions. The inspectors concluded that the operator aid containing instructions for the use of a temporary inverter was clearly written, and was understood by the operator L l

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04.2 Operator Response To An Unit 2 Upper Cable Soreadma Room Halon Fire Sucoression System Alarm Inspection Scop 6 (71707)

The inspectors proceeded to the control room following a plant page announcement concerning the evacuation of the Unit 2 cable spreading room. Upon arrivalin the

, control room the inspectors observed the performance of control room personnel to l , indications of a potential inadvertent initiation of the Unit 2 cable spreading room Halon fire suppression syste Observations and Findinas On February 25, oparators received control room alarms indicating a potential initiation of the Unit 2 cable spreading room Halon fire suppression system. The inspectors observed control room supervisors provide timely directions to operators, properly l prioritize response efforts, and promptly establish the required compensatory fire l watches. Control room operators promptly directed station personnel to evacuate the l Unit 2 upper cable spreading room, directed the search of the upper cable spreading '

rooms for fire and injured personnel, and directed radiation protection personnel to l perform environmental surveys for the presence of Halon. During the progression of the

! event, the unit nuclear station operators remained attentive to their respective control boards. It was later determined, by the analysis of environmental samples, that no Halon was released. The shift manager summoned electrical maintenance and system !

engineering personnel to the control room to plan the recovery and restoration of the !

Unit 2 cable spreading room Halon fire suppression syste Conclusions The inspectors responded to the control room following the plant notification for evacuation of the Unit 2 cable spreading room due to indication of the Halon fire suppression system initiation. The inspectors concluded that the Unit 2 unit supervisor demonstrated excellent command and control by providing timely direction to operators, ,

l by properly prioritizing response efforts, and by promptly establishing compensatory fire i watches. The control room operators promptly and accurately implemented supervisory direction by communicating with non-licensed operators, radiation protection, and ;

security personnel. The inspectors concluded that the unit nuclear station operators were not distracted from monitoring of their respective control boards. No actual release I

of Halon occurred.

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06 Operations Organization and Administration 06.1 Review of Apparent Cause Evaluations (ACES) Inspection Scope (71707)

The inspectors selected and reviewed six safety-related or risk significant ACE form Apparent cause evaluations for the following problem identification forms (PlFs) were reviewed:

PIF #A1998-04310, " Shutdown Margin Surveillance Problems";

PIF #A1998-04314, " Missed 1RE-PR28 Sample";

PlF #A1998-04328, " Appendix R Emergency Lighting GOCAR [ Gene O'Donnel Compensatory Action Requirement) Open > (greater than) 14 Days";

P1F #A1998-04342, "4KV Breaker Failure During Testing";

PlF #A1998-04345, " Seal Injection High Point Vent Valve Has Leakage Above Updated Final Jaety Analysis Report (UFSAR) Limits"; and PIF #A1998-04379, "AF004 Valves Not included In-Service Testing Program."

i The inspectors also reviewed Nuclear Station Procedure (NSP) AP-4004, " Corrective l Actions Program Procedure," Revision Observations a-d Findinas 1 The inspectors selected and reviewed the six ACES listed above and compared the completed ACES against the requirements contained in NSP-AP-4004. The inspectors noted that all ACES reviewed were properly documented, received the required reviews, and were completed within the required 15 days. The stated problem on each ACE was clearly described, the apparent causes were reasonable with respect to the stated problems, and the proposed corrective actions appeared to address the apparent causes. Conclusions The inspectors reviewed six safety-related or risk significant apparent cause evaluations (ACES) and concluded that the ACES were completed within the required time, clearly stated the problem and the apparent causes, and proposed appropriate corrective actions to prevent recurrenc I-II. Maintenance M1 Conduct of Maintenance M1.1 Maintenance Activity Observations

' Insoection Scope (62707)

The inspectors observed all or portions of the following maintenance activities:

l Cleaning of the Unit 1D circulating water system condenser water box in !

accordance with work request (WR) 990009780-01;

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Cleaning of the Unit 1C circulating water system condenser water box in accordance with WR 990000283-01; Non-intrusive cleaning and inspection of the Unit 2A essential service water (SX) ,

system pump room cubicle cooler in accordance with WR 970087842-01; '

Repair of an oil leak from the lower sight glass of the Unit 2A msidual heat removal system (RHR) pump in accordance with WR 980091786-01; and Troubleshooting and repair of the Unit 2 rod control system in accordance with WR 9900123479-0 Observations and Findinas The inspectors attended the heightened-level-of-awareness meetings; reviewed the above work packages; reviewed high-risk work check sheets, if applicable; walked down the work areas with maintenance personnel; questioned personnel concerning the scope of the work, including system status and precautions for electrical safety; observed the establishment of required system conditions; observed the use of foreign material exclusion (FME) controls; reviewed applicable welding procedures and " hot work" permits; and observed the use of quality control" hold points." The inspectors also reviewed the associated Technical Specifications (TS) li-miting conditions for operation, if applicable, and reviewed the control room logs for limiting conditions for operation entry and exit tog entries. The inspectors noted no problems during the above reviews, interviews and observation The inspectors verified t. .at the licensee had effectively implemented maintenance rule requirements for the SX and the RHR systems. The inspectors determined that the licensee had established appropriate goals and monitoring actions for the SX system, an (a)(1) system, to ensure timely transfer of the system to (a)(2) status. The inspectors also determined that the licensee had established appropriate performance criteria and monitoring methods to demonstrate continued performance of the RHR system, an l (a)(2) syste !

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For the first four WRs listed above, the inspectors reviewed the return-to-service packages. The inspectors determined that lessons-learned from previous configuration control events had been incorporated into the associated WRs and were successful in preventing recurrence of similar problems in these case c.- Conclusions The inspectors observed all or portions of various maintenance activities and concluded that activities were performed in accordance with the apolicable procedures and that the procedures provided the requisite information necessary to perform the work. The l

inspectors concluded that the licensee had effectively implemented maintenance rule requirements for the SX and the RHR system M1.2 Observation of Miscellaneous Surveillance Activities Inspection Scope (61726)

The inspectors observed all or portions of the following surveillance activities:

Unit 2 Braidwood Operating Surveillance Procedure (2BwOSR) 3.1.4.2, " Unit Two Movable Control Rod Assemblies Quarterly Surveillance," Revision 1; 2BwOSR 3.3.2.7-606A, " Unit Two ESFAS [ Engineered Safety Function Actuation System] Instrumentation Slave Relay Surveillance (Train A Containment isolation Phase A-K606)," Revision 0; 2BwOSR 3.3.2.7-646B,." Unit Two ESFAS Instrumentation S! ave Relay Surveillance (B Train Automatic Safety injection - K646)," Revision OE1; 2BwOS 8.1,1.2.a-2, "2B Diesel Generator operability monthly (Staggered) and Semi-Annual (Staggered) Surveillance," Revision 14; and Unit 1 Braidwood Engineering Surveillance Procedure (1BvVSR) 5.5.8.CS.1,

"ASME (American Society of Mechanical Engineering] Surveillance Requirements for 1 A Containment Spray Pump and Check Valves 1CS003A, 1CS011 A," Revision Observations and Findinas During this inspection period, the inspectors observed the performance of the above listed surveillance tests. For each surveillance test, the inspectors observed the establishment of initial conditions required for the surveillance test, the operation of equipment, the commuhications between the licensed operators in tne control room and non-licensed operators in the plant, and the restoration of affected equipment. The inspectors determined that each of these activities were performed in accordance with the applicable procedure. The inspectors reviewed the data obtained during the

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surveillance tests and noted that it met the required acceptance criteria specified in the surveillance test procedures. During the performance of 2BwOSR 3.1.4.2, the licensee

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determined that the step counters for the group rod position indication system for shutdown rod banks "C" and "D" did not function as expected. The inspectors observed the licensee take proper actions including stopping the test, notifying the unit supervisor and nuclear station operator, and entering the appropriate TS limiting condition for operation. The inspectors also reviewed the associated portions of the UFSAR and the TSs and determined that the surveillance test procedures demonstrated the systems performed as designed. Conclusions The inspectors concluded that the five surveillance tests observed adequately tested the system, the operators followed the procedures, and that the procedures included the required surveillance testing described in the TSs.

M8 Miscellaneous Maintenance issues (92700, and 92902)

M8.1 (Closed) Violation 50-456/97007-02a(DRP). " Failure to follow FME procedure." On April 21,1997, Nd again on April 25,1997, the inspectors observed that FME covers were missing on the 18 diesel generator while unattended contrary to the requirements of SMP-M-04. The licensee entered the problem in their corrective action program and subsequently provided additional FME training to mechanical maintenance personne The inspec' ors reviewed the licensee's corrective actions and observed maintenance activities requiring foreign material control and determined that the licensee's corrective actions to prevent recurrence were effective. This violation is closed.

M8.2 (Closed) Violation 50-456/97007-02b(DRP): " Failure to follow the safety injection system check valve stroke test surveillance procedure." During a review of BWVS 0.5-2.SI.2, the inspectors identified that the test director failed to complete Step F.4.24 of BwVS 0.5-2.SI.2 in that the sum of flow instruments FI 972 and FI 922 were not recorded. The licensee entered the problem in their corrective action program and subsequently conducted training with engineering test directors on the roles and responsibilities of test directors. Also, the licensee developed test director training program and established qualification requirements for personnel acting as a test director. The inspectors reviewed the licensee's corrective actions and observed the performance of surveillance testing during refueling outage A1R07, and determined that the licensee's corrective actions to prevent recurrence have been effective. This violation is closed.

M8.3 (Closed) Violation 50-456/97007-02c(DRP): " Failure to follow the high head injection (charging) system check valve stroke test surveillance procedure." The inspectors identified that the test director failed tr stop the test of the 1 A charging pump following observation of a indicated flow greater than 550 gallons per minute contrary to the requirements of BwVS 0.5-2.St.2-3. The licensee relieved the test director, entered the problem in their corrective action program, and subsequently conducted training with engineering test directors on the roles and responsibilities of test directors. Also, the licensee developed test d; rector training program and established qualification requirements for personnel acting as a test director. The inspectors reviewed the licensee's corrective actions and observed the performance of surveillance testing

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l during refueling outage A1R07, and determined that the licensee's corrective actions to prevent Ncurrence have been effective. This violation is close M8.4 (Closed) Licensee Event Report (LER) 456/97006-00 and Escalated Enforcement item (EEI) 456/457/97009-03(DRP): " Failure to vent emergency core cooling systems in accordance with TSs." On May 22,1997, while in Mode 3 (Hot Shutdown), the licensee entered TS 3.0.3 and initiated a cooldown of the Unit 1 reactor coolant system, following identification by inspectors that a TS surveillance requirement 4.5.2.b.1 to vent emergency core cooling systems (ECCS) pump casings and discharge piping high points outside of containment had not been met. Specifically, the Unit 1 and 2 chemical and volume control system (CV) pump casings and the high point vents had never been vented during Modes 1,2, and 3. The failure to vent the CV system in accordance with TS was documented as eel 50-456/97009-03(DRP); 50-457/97009-03(DRP), and resulted in the issuance of a Severity Level ill violation under separate correspondence dated October 3,1997. In response, the licensen verified that CV pump discharge piping up to the discharge check valve and the CV system high points were completely filled with water, reviewed and revised exioting Braidwood Operating Surveillance Procedures for the venting and alignment of ECCS, established a new ECCS surveillance procedure to perform ultrasonic testing on the CV pump discharge piping up to the discharge check valve and the CV system high points confirming the absence of air in the CV system, reviewed 18 additional TS surveillance procedures for literal compliance problems, and obtained a TS amendment. The inspectors reviewed the licensee's corrective actions, verified their implementation, and determined that the corrective actions taken should prevent recurrence of this problem. These items are close M8.5 (Closed) Violation 50+56/457/97016-04(DRP): " Failure to take effective corrective actions to control movable carts." The inspectors identified 17 examples where movable carts in the auxiliary building were improperly secured. The licensee immediately secured the carts and entered the problems into their corrective actions program. Since a violation was previously issued Inspection Report 96021 for a failure to control movable carts, the licensee initiated a root cause evaluation to determine the causes for the continued problems. The root cause identified that the corrective actions for the previous violation failed to raise the awareness of plant personnel to the requirements for securing movable equipment. In addition, the root cause evaluation determined that Policy Memo 65, was long, cumbersome, and complex requiring personnel to make determinations that they were not qualified to make. To address the findings of the root cause evaluation, the licensee provided additional instruction to operations, radiation protection, and maintenance personnel to raise awareness of the requirements; simplified governing procedures and memos, provided training on revised procedures and memos to all personnel; performed routine plant walkdowns for the purpose of assessing seismic housekeeping compliance; developed accountability guidelines; and l scheduled an effectiveness review of the completed corrective actions. These corrective actions have been completed and inspectors have determined that they were i effective based on routine seismic housekeeping observations in the plant. This violation is closed.

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l l M8.6 (Closed) Violation 50-456/457/98002-02(DRP): " Failure to follow procedure for I independent verifications." During a review of completed essential service water surveillance test procedures, the inspectors noted that independent verifications of proper system alignment were not required by the ASME pump surveillance test procedure in which va90s were repositioned. The failure to perform an independent verification was contrary to Braidwood Administrative Procedure (BwAP) 100-18,

"Braidwood Station Independent Verification Procedure." The licensee entered the problem in their corrective action program and revised ASME surveillance test procedures for the Unit 1 and 2 essential service water pumps; conducted training with engineering and the procedure writing group concerning the requirements of BWAP 100-18; and reviewed and revised (when necessary) approximately 650 procedures for compliance with BWAP 100-18 requirements. The inspectors reviewed the licensee's corrective actions and determined that the actions taken should prevent recurrence. This violation is close Ill. Enaineerina E1 Conduct of Engineering E Operability Determination Reviews Inspection Scope (37551)

The inspectors reviewed the following documents:

Nuclear Station Procedure NSP-CC-3001, " Operability Determination Process,"

Revision 0; Operability determination 98-055, "2A DG [ Diesel Generator) turbocharger Exhaust Outlet Gasket leak";

Operability determination 98-056, " Motor Operated Valves OSX063A and OSX063B";

Operability determination 98-057, " Westinghouse Calculation SEC-LIS-5317-0, Which Supports the Byron /Braidwood Post-Loss Of Cooling Accident Criticality Calculations has Potentially Non-Qualified Assumptions";

Operability determination 99-001, " Pressurizer Heaters",

Operability determination 99-002, " Component Cooling Pumps Coupling";

Operability determination 99-003, "2PR30J WRGM [ Wide Range Gamma j

Monitor)",

Opitability determination 99-004, "Radwaste Regeneration Skid Components l l (M-48-1)"; i

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Operability determination 99-005, "VA (Auxiliary Building Ventilation) HEPA (High Efficiency Particulate Air] and Charcoal Filter Testing Methodology"; and Operability determination 99-006, "1B,2A, 2B EDG [ Emergency Diesel Generator) Output Breaker Closing Circuit."

The inspectors interviewed system engineering, site engineering, operations, and regulatory assurance personne l Observations and Findinas

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The inspectors verified that the documentation of operability determinations met the requirements of NSP-CC-3001, that the assumptions used to develop the determinations were valid, and that individuals who prepared and reviewed operability determinations were properly trained and the licensee complied with TS Requirement The inspectors discussed compensatory actions with control room operations personnel and determined that operators were aware of, and understood the compensatory actions listed. The inspectors also determined that corrective actions listed had been entered into the licensees nuclear tracking syste Conclusions i The inspectors concluded that the nine operability determinations reviewed reflected good engineering judgement and safety focus, compensatory actions were understood by operations personnel, and corrective actions were entered into the stations nuclear tracking syste E1.2 10 CFR 50.59 Safety Evaluation Proaram Inspection Scoce (37551)

The inspector reviewed Nuclear Station Procedure NSP-CC-3005, "10 CFR 50.59 Safety Evaluation Process," Revision 0, and reviewed the following 10 CFR 50.59 l evaluations:

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"BRW-FCS-1999-52 - Routing of Hydrogen Recombiner Space Heater and

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Control Power Lines Properly";

"BRW-SESV-1999-63 - Implementation of NSP-RP-6102, Station Responsibility for Comed's Meteorology Program and Radioactive Effluent Monitoring Program";

"BRW-FCS-1999-71 - Replacement of the Auxiliary Building Ventilation Stack Flow Rate Transmitter With a Different Transmitter"; and

"BRW-SE-1999-85 - Revision to the UFSAR."

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. Observations and Findinas The inspectors noted that the licensee had recently implemented NSP-CC-3005, l- "10 CFR 50.59 Safety Evaluation Process," Revision 0. The inspectors noted that the new procedure appeared to implement the requirements of 10 CFR 50.59. The inspectors also reviewed the 10 CFR 50.59 safety evaluations listed above and determined that they had been performed in accordance with NSP-CC-300 Conclusions Based on a sample of four safety evaluations, the inspectors concluded that the safety evaluation program was implemented in accordance with 10 CFR 50.59 and the station procedure E2 Engineering Support of Facilities and Equipment E2.1 Auxiliary Feedwater System Inspection Scope (37551)

The inspector performed a walkdown of the auxiliary feedwater (AF) system and reviewed the AF system design bases in the UFSAR, the AF system lineups, and applicable drawing Observations and Findinas The inspector performed a walkdown of the AF system for proper configuration and to check system condition. All components were found in good condition and no AF system leaks were detected. The AF system and associated components were aligned as required by station procedure Conclusions The inspector performed a walkdown of the AF system and reviewed system design documentation and procedures. The inspectors concluded that the material condition of the AF system was good and was aligned in accordance with plant procedure E2.2 Unit 1 Annunciator Failures (92903) Inspection Scope The inspectors reviewed drawings, interviewed cognizant licensee personnel and attended licensee troubleshooting and repair planning sessions l

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n Observations and Findinas On October 28,1998, operators in the Unit 1 main control room observed that an annunciator window " flashed" without the expected audible alarm. The licensee determined that inverter "D," rectifier CR2, and the relay that automatically switches power for the horns and bells between inverters "C" and "D" had failed. The licensee replaced the failed components and the annunciator was returned to service. The licensee did not perform a root cause analysis at that tim 'On January 17,1999, operators in the Unit 1 main control room received a " System Power Supply Trouble" alarm. An initial investigation revealed that inverter "C" had failed and that the unit annunciators were being powered from the "D" inverte Inverter "C" was replaced and placed back into servic On January 18, Unit 1 experienced a loss of all audible alarm capability for the Unit 1 and Urct 0 annunciators as we!! as a loss of visual alarm capability for most Unit 1 annunciators (see Section 04.1). The licensee's investigation revealed that the "C" and

"D" inverters and the horn power chassis rectifiers CR1 and CR2 had failed. The licensee declared an Unusual Event upon discovering the extent of visual annunciation lost. The "C" and "D" inverters and the rectifiers were replaced, the system was returned to service, and the Unusual Event was terminate On January 20, an Unusual Event was again declared by the licensee when most of the Unit 1 annunciator visible alarms were again lost. Also, all Unit 1 audible alarms were lost. The loss occurred during routine main control room annunciator testing. The licensee's investigation revealed that the "C" and "D" inverters and a horn power chassis rectifier had failed. Investigation and troubleshooting focused on the audible alarm circuits downstream of the horn power chassis rectifier .

On January 21, the "C" and "D" inverters and the associated rectifiers were replace The licensee installed a temporary modification so that the horn power chassis was no longer powered by the "C" and "D" inverters. The modification provided redundant feeds for the horn circuits from panel IPA 19J and a local lighting panel. The bell circuits were provided with a separate direct current (DC) power feed. The Unusual Event declared on January 20,1999, was terminate On January 25, Unit i received a " System Power Supply Trouble" alarm. The licensee's investigation revealed that the "C" inverter had failed and that the "D" inverter was powering the annunciator windows. This inverter loss occurred during routine annunciator testing using the main control room annunciator. The failed inverter was replaced and returned to service. The licensee installed other temporary modifications to add an additional inverter in parallel with the "C" inverter. In the event of a "C" inverter failure, the "C" inverter could be isolated and its loads transferred to the additional inverte The licensee brought in two failure analysis companies to assist licensee engineers in determining the root cause of the annunciator failures. The licensee identified that the manufacturer had replaced military grade output transistors with commercial grade output transiers. Further investigation by the licensee determined that the substitution

of commercial grade components for military grade components may be a contributing factor to the failure. The licensee continues to monitor inverter performance and has not definitively 'dentified the root cause for the failure Conclusion The inspectors concluded inat the licensee made a significant effort to determine the root cause of failures in the Unit 1 annunciator system. The inspector concluded that the licensee's repairs and temporary modifications have placed the annunciator in an operable condition pending root cause determination and installation of permanent modifications or repair E8 Miscellaneous Engineering issues (92700, and 92903)

E8.1 (Closed) LER 50-456/97004-00: " Missed TS surveillance due to a clerical error and unclear management expectations." On May 23,1997, the licensee identified that BwOS 8.2.1.2.A-1, " Unit One Engineered Safety Features Battery Bank and Charger 111 Operability Weekly Surveillance," had not been performed within the TS required time interval of seven days. The specified surveillance interval plus 25 percent allowed by TS 4.0.2 had been exceeded by 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br />. Immediately upon recognizing the error, the licensee performed and successfully completed the required surveillance testing. The licensee determined that a clerical error had been made in the surveillance testing database which resulted in the mis-calculating of the next required performance date. The licensee reviewed a sample of completed surveillance tests as well as the entire TS surveillance database and determined that this was an isolated incident. Senior work control management briefed the clerical staff and supervisors on ,

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this issue including the need for daily reviews of the tracking system for early detection of inadvertent field changes. The inspectors concluded that the actions taken by the licensee were effective in prevem.ing recurrence of similar problems based on a review of problem identification forms and discussions with work control personnel. The inspectors considered this TS violation to be of minor significance and not subject to formal enforcement action. This conclusion was based on the fact that BwOS 8.2.1.2.A-1 testing performed immediately prior to and after the missed surveillance met the TS acceptance criteria and was satisfactonly completed. In addition, DC bes voltage indication was available in the control room and annunciators for DC bus low voltage or battery charger trouble would have alerted operators had any I degradation occurred. Also the Unit 1 DC bus 112 was operable throughout the event l and Unit 2 bus 211 was available to be cross-tied if necessary. This LER is close I l

E LClosedLLER 456/97005-00: " Untested P-11 interlock circuitry." During the review of an industry Operating Experience Report OE8435 which identified a lack of proper testing of the P-11 circuitry, the licencee determined that the same situation existed at Braidwood Station. Because of this deficiency, a valid test of the P-11 function had not been performed as required by TS 4.3.2.1. Technical Specification 4.3.2.1 states that each Engineered Safety Features Actuation System (ESFAS) instrumentation channel and interlock and the automatic actuation logic and relays shall be demonstrated operable by the performance of the ESFAS instrumentation surveillance requirements specified in Table 4.3-2. In response to this event, the licensee entered the applicable i

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limiting condition for operation, made the appropriate notification to the NRC, entered the problem in their corrective action program, revised the associated surveillance procedures, performed the revised surveillance procedures, reviewed all the other normally deenergized process protection system inputs for similar deficiencies, and performed an effectiveness review following the completion of the corrective actions.

l The inspectors reviewed the licensee's corrective actions and determined that the

actions taken should prevent recurrence. The inspectors considered this TS violation to l be of minor significance and not subject to formal enforcement action since the licensee identified this issue in a proactive response to an industry wide concern, and the P-11 contact was immediately tested satisfactorily. This LER is close E8.3 (Closed) LER 50-456/97008-00

" Projected steam generator leakrate combined with TS limit for dose equivalent (DE) iodine creates potential for operation outside design basis." The site allowable accident leakage limit is that total leskage value (including steam generat.or u-tube leakage) assumed in the licensee's accident analysis that would result in a dose corresponding to ten percent of the 10 CFR Part 100 !!mits assuming a maximum TS allowable reactor coolant system DE of lodine-131. Prior to refueling outage A1R06, the maximum site allowable leakage limit for Braidwood Unit 1 was based on an assumed accident leakage rate of 26.8 gallons per minute with a reactor coolant system DE of iodine-131 of 5 (less than or equal to ) 0.35 microcuries per gra Based on the results of Unit 1 steam generator tube inspections performed during refueling outage A1R06, the total predicted Unit 1 accident leakage rate was determined to be 87.7 gallons per minute. The licensee determined that calculations performed to support the accident analysis maximum leakage rates for Unit 1 utilized incorrect density corrections for projected leakage and non-conservative steam generator outer diameter stress corrosion crack propagation and resultant leakage rates. The licensee performed an operability determination and determined that the Unit 1 predicted total accident leakage of 87.7 gallons per minute would be acceptable given that the reactor coolant system DE of iodine-131 were reduced from 5 0.35 micro curies per gram to 5 0.1 microcuries per gram. A compensatory action was put in place to administratively control Unit 1 reactor coolant sp tem DE iodine-131 to 5 0.1 microcuries per gram. The licensee replaced the Unit 1 steam generators with steam generators tnat are not susceptible to outer diameter stress corrosion cracking during refueling outage A1R0 This LER is close E8.4 (Closed) LER 50-456/97010 00: " Solid State Protection System (SSPS) logic testing not performed due to inadequate testing design." The licensee was reviewing the testing of safety-related circuitry in response to NRC Generic Letter 96-01, " Testing of Safety-Related Logic Circuits." The Generic Letter discussed numerous documented instances involving industry-wide problems with logic testing of safety-related circuit During this review, the licensee discovered that certain functions of the SSPS memory logic circuits were not being tested. The effected circuits included the source range blocking scheme (P-10), and the safety injection and steam generator "HI-HI" level (P-14) functions. Upon discovery, the licensee immediately entered TS 4.0.3, upgraded the effected test procedures, successfully performed the required testing on both units, and exited TS 4.0.3. The inspectors reviewed the effected test procedures and verified that the required changes had been completed Also, the licensee had completed it's review of safety-related circuitry testing as documented in Comed letter *NRC Generic f

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Letter 96-01, ' Testing of Safety-Related Logic Circuits' Confirmation of Completion of '

Requested Actions," dated January 13,1999. The inspectors concluded that the licensee's review was thorough, was sufficient to identify additional problems, and that actions taken were commensurate with the safety-significance of the effected circuitr Although the licensee's testing of the SSPS circuitry was not previously in accordance with the TS, the inspectors concluded that the immediate and long term actions taken !

sufficiently demonstrated SSPS operability as well as a good safety focus. The inspectors considered this TS violation to be of minor significance and not subject to formal enforcement action. This LER is close IV. PLANT SUPPORT R1 Radiological Protection and Chemistry (RP&C) Controls a. Inspection Scope (71750)

Throughout the period, inspectors observed the posting of radiation areas the control of locked high radiation areas, the application of As-Low-As-Reasonably-Achievable I (ALARA) pnnciples, and the radiation work practices of station personnel. The i inspectors also reviewed radiation work permit 99-3023," Unit 2 Curved Wall Area Climbing."

! Observations and Findinos l The inspectors verified the postings of radiologically controlled areas and noted that these areas were poperly posted for the condition that existed in the areas. Rope boundaries, swing gates (where applicable) and signs were properly maintained. The i inspectors verified that locked high radiation area doors were locked and were properly j controlled by radiation protection personne l l

The inspectors reviewed the ALARA controls used on several potentially high dose activities. For example, the inspectors noted that prior to entry into the Unit 2 curved !

wall area (a locked high radiation area], radiation protection personnel briefed personnel on the dose rates in the curved wall area, identified areas to avoid, and identified the routes that resulted in the lowest dose, inspectors also observed ALARA controls in j use for maintenance activities on the fuel transfer canal. Radiation protection personnel set up cameras in the transfer canal and provided personnel entering the canal with remote reading dosimetry in order to reduce the dose received by radiation protection personnel without compromising their monitoring responsibilitie i The inspectors observed proper radiation worker practices by maintenance personne' ;

assigned to work in the fuel transfer canal. The workers properly donned and removea j anti-contamination clothing, properly performed frisking on exit from the contaminated area, and properly wore and monitored dosimetry. The inspectors did not observe any maintenance personnel loitering in radiation area l l

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' Conclusions The inspectors observed the posting of radiation areas, the control of locked high radiation areas, the application of ALARA principles, and the radiation work practices of station personnel The inspectors concluded that radiologically controlled areas that were observed were properly posted; that locked high radiation area doors observed were locked and properly controlled by radiation protection personnel; ALARA controls, such as ALARA briefings, cameras, and remote reading dosimetry were used to minimize exposure to personnel; and proper radiation work practices were demonstrated by the observed personne F2 Status of Fire Protection Facilities and Equipment l

F2.1 Survey of Auxiliary Bu..dina Floor Pluas I Inspection Scope (71750)

The inspectors inspected a representative sample of floor plugs located in the auxiliary '

building. The inspectors reviewed BwAP 1110-3, " Plant Barrier impairment Program,"

Revision 7E2; and Memo # 200-18, " Floor Plug Removal." Observations and Findinas The inspectors inspected eight floor plugs associated with rooms containing emergency core cooling equipment from Memo #200-18, Attachment A. The inspectors observed that the floor plugs were in their installed positions with no barrier impairment Inspectors noted no seal degradatio Conclusions The inspectors inspected eight floor plugs associated with rooms containing emergency core cooling equipment and concluded that each floor plug was properly installed and sealed. No barrier impairments existed on the inspected floor plugs and plug seals were free from degradatio F2.2 Condition of Appendix R Emeraency Liahtina

, Inspection Scope (71750)

The inspectors observed the physical condition of Appendix R emergency lights in areas needed for operation of safe shutdown equipment and in access routes to such l

equipmen Observations and Firfngji The inspectors inspected Appendix R emergency lights near emergency core cooling systems, remote shutdown panels, essential services water pumps, essential switchgear rooms,125 volt direct current batteries and switchgear rooms, access routes to that l

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equipment, and the control room. The inspector noted no problems with the mounting of the emergency lights, with the direction of the lamps, with the state of charge of the batteries, and with battery charger operation. The inspectors also noted that many of the Appendix R emergency lights had been recently update c. Conclusions The inspectors inspected Appendix R emergency lights and concluded that the emergency lights were properly mounted, directed, and charged. Many of tne lights had been recently update V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on March 1,1999. 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 identifie l l

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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 Manager l- A. Haeger, Radiation Protection Manager l R. Graham, Work Control Manager-l *T. Simpkin, Regulatory Assurance Manager

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• T. Luke, Engineering Manager l *J. Nalewajka, Assessment Manager

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• R. Pratt, Lead Radiation Protection Supervisor

• J. Chojnicki, Planning Supervisor l *T. O'Bert, Maintenance Assistant

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• 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 J. Neisler, Reactor inspector IDNS-J.' Roman

• Denotes those who attended the exit interview conducted on March 1,199 !

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j INSPECTION PROCEDURES USED l lP 37551: Onsite Engineering L

IP 61726: Surveillance Observations IP 62707: Maintenance Observation -

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IP 71707: Plant Operations IP 71750: Plant Support Activities'

IP 92700: Onsite Followup of Written Reports of Nonroutine Events at Power Reactor )

Facilities l iP 92902: Followup - Plant Maintenance '

IP 92903: Followup - Engineering ITEMS OPENED, CLOSED, AND DISCUSSED 1 Opened None Closed 50-456/97004-00 LER missed TS surveillance 50-456/97005-00 LER Untested P-11 interlock circuitry 50-456/97006-00 LER failure to vent CV system 50-456/97007-02a(DRP) VIO failure to follow procedure

' 50-456/97007-02b(DRP) VIO failure to follow procedure 50-456/97007-02c(DRP) VIO failure to follow procedure 50-456/97008-00 LER potential for operation outside design basis 50-456/457/97009-03(DRP) eel failure to vent CV system 50-456/97010-00 LER untested SSPS contacts 50-456/457/97016-04(DRP) VIO failure to take corrective actions ,

. 50-456/457/98002-02(DRP) VIO failure to follow procedure ]

- Discussed I None

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l LIST OF ACRONYMS USED l

ACE Apparent Cause Evaluation

! .AF Auxiliary Feedwater  ;

i ALARA As-Low-As-Reasonably-Achievable i

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ASME American Society of Mechanical Engineers BwAP Engineered Safety Function Actuation System l

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BwOSR Braidwood Operating Surveillance Procedure BwVSR Braidwood Engineering Surveillance Procedure l CFR Code of Federal Regulations CV Chemical and Volume Control System DC Direct Current DE Dose Equivalent ECCS Emergency Core Cooling System eel Escalated Enforcement item ESFAS Engineered Safety Function Actuation System I FME Foreign Material Exclusion GOCAR Gene O'Donnel Compensatory Action Requirement LER Licensee Event Report NRC Nuclear Regulatory Commission NSP Nuclear Station Procedure PlF Problem Identification Form RHR Residual Heat Removal RP Radiation Protection RP&C Radiological Protection & Chemistry SSPS Solid State Protection System SX Essential Service Water UFSAR Updated Fina; Safety Analysis Report ,

VIO Violation '

WR Work Request l

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