IR 05000456/2004003

IR 05000456-04-003, IR 05000457-04-003, on 01/01/04 - 03/31/04, for Braidwood Station, Units 1 and 2; Routine Integrated Inspection Report

ML041140543
Person / Time
Site:	Braidwood
Issue date:	04/23/2004
From:	Ann Marie Stone NRC/RGN-III/DRP/RPB3
To:	Crane C Exelon Generation Co, Exelon Nuclear
References
IR-04-003
Download: ML041140543 (43)

Text

ril 23, 2004

SUBJECT:

BRAIDWOOD STATION, UNITS 1 AND 2 NRC INTEGRATED INSPECTION REPORT 05000456/2004003; 05000457/2004003

Dear Mr. Crane:

On March 31, 2004, the U. S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Braidwood Station, Units 1 and 2. The enclosed report documents the inspection findings which were discussed on April 15, 2004, with Mr. T. Joyce and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and to compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, two licensee-identified violations are listed in Section 4OA7 of this report.

If you contest the subject or severity of the Non-Cited Violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission -

Region III, 2443 Warrenville Road, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Braidwood facility. In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Ann Marie Stone, Chief Branch 3 Division of Reactor Projects Docket Nos. 50-456; 50-457 License Nos. NPF-72; NPF-77

Enclosure:

Inspection Report 05000456/2004003 05000457/2004003 w/Attachment: Supplemental Information

REGION III==

Docket Nos: 50-456; 50-457 License Nos: NPF-72; NPF-77 Report No: 05000456/2004003; 05000457/2004003 Licensee: Exelon Generation Company, LLC Facility: Braidwood Station, Units 1 and 2 Location: 35100 S. Route 53 Suite 84 Braceville, IL 60407-9617 Dates: January 1 through March 31, 2004 Inspectors: S. Ray, Senior Resident Inspector N. Shah, Resident Inspector D. Nelson, Radiation Specialist C. Phillips, Senior Operator Licensing Examiner C. Roque-Cruz, Reactor Engineer D. Tharp, Reactor Engineer T. Tongue, Project Engineer Observers: P. Smith, Illinois Emergency Management Agency Approved by: Ann Marie Stone, Chief Branch 3 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000456/2004003, 05000457/2004003; 01/01/04 - 03/31/04; Braidwood Station,

Units 1 & 2; Routine Integrated Inspection Report.

This report covers a 3-month period of baseline resident inspection and an announced baseline inspection on radiation protection. The inspection was conducted by Region III inspectors and the resident inspectors. No findings of significance were identified.

A. Inspector-Identified and Self-Revealed Findings There were no inspector-identified or self-revealing findings during this inspection.

Licensee-Identified Violations

Violations of very low safety significance, which were identified by the licensee, have been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. These violations and the associated corrective action tracking numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Unit 1 started the inspection period at 29 percent of full power while conducting repair and testing of a feedwater isolation valve. The unit was restored to full power on January 3, 2004.

On February 4 through 6, 2004, Unit 1 was reduced to 90 percent of full power for testing of the ultrasonic feedwater flow instrumentation. Unit 1 operated at or near full power for the remainder of the inspection period.

Unit 2 was operated at or near full power for the entire inspection period except for the following power reductions: to 96 percent on January 21, 2004, due to a problem with a moisture separator reheater controller; to 95 percent on January 25, 2004, in order to swap feedwater pumps; to 90 percent on January 26 through 30, 2004 for testing of the ultrasonic feedwater flow instrumentation; and to 85 percent on February 8, 2004 for turbine valve testing.

1R04 Equipment Alignment

Partial Walkdowns

a. Inspection Scope

The inspectors performed partial walkdowns of the accessible portions of risk significant system trains during periods when the train was of increased importance due to redundant trains or other equipment being unavailable. The inspectors utilized the valve and electric breaker checklists, as well as other documents listed in the Attachment, to verify that the components were properly positioned and that support systems were lined up as needed. The inspectors also examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors reviewed outstanding work orders (WOs) and condition reports (CRs) associated with the train to verify that those documents did not reveal issues that could affect train function. The inspectors used the information in the appropriate sections of the Technical Specification (TS) and the Updated Final Safety Analysis Report (UFSAR) to determine the functional requirements of the system. The inspectors also reviewed the licensees identification of and the controls over the redundant risk related equipment required to remain in service. The inspectors completed three samples of this requirement by walkdowns of the following trains:

• 2A auxiliary feedwater (AF) pump in preparation for taking the 2A centrifugal charging (CV) pump out of service;

• 1B diesel generator (DG) in preparation for taking the 1A DG out of service; and

• 1A safety injection (SI) train and its associated cubicle and oil coolers in preparation for taking the 1B SI train out of service.

b. Findings

No findings of significance were identified.

1R05 Fire Protection

Quarterly Area Walkdowns

a. Inspection Scope

The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of fire fighting equipment, the control of transient combustibles and ignition sources, and on the condition and operating status of installed fire barriers. The inspectors selected fire areas for inspection based on their overall contribution to internal fire risk, as documented in the Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate a plant transient, or their impact on the plants ability to respond to a security event. The inspectors used the documents listed in the Attachment to verify that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and that fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors verified that minor issues identified during the inspection were entered into the licensees corrective action program.

The inspectors completed nine samples of this inspection requirements during the following walkdowns:

• 1A DG and day tank rooms (zones 9.2-2 and 9.3-1);

• 1A DG fuel oil storage tank room (zone 10.2-1);

• 2A DG and day tank rooms (zones 9.2-2 and 9.3-2);

• 2A DG fuel oil storage tank room (zone 10.2-2);

• 1B AF pump room (zone 11.4A-1);

• 2B AF pump room (zone 11.4-A-2);

• auxiliary building 383 foot elevation general area (zone 11.4-0);

• 1A SI pump room (zone 11.3A-1); and

• 2A SI pump room (zone 11.3A-2).

b. Findings

No findings of significance were identified.

1R06 Flood Protection Measures

Annual Inspection of External Flood Protection Barriers and Procedures

a. Inspection Scope

The inspectors conducted an annual review of external flooding vulnerabilities and protective measures. The inspection included a review of the external flooding design features described in the UFSAR and a walkdown of external plant areas, including roofs, to verify that water from significant rainfall would not encroach on safety related areas of the plant. The inspectors verified that there were not excessive amounts of debris that could block roof drains, storm drains, or runoff paths, and that there did not appear to be any major changes to the ground elevations such as buildups or sinkholes that could effect runoff. The inspectors also verified that the flood protection curb around the auxiliary building was intact. As part of this inspection, the inspectors reviewed the licensee documents listed in the Attachment. This inspection constituted one sample of this requirement.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program

Quarterly Review of Testing/Training Activity

a. Inspection Scope

The inspectors observed the operating crew performance during an evaluated simulator out-of-the-box scenario. The inspectors evaluated crew performance in the following areas:

• clarity and formality of communications;

• ability to take timely actions in the safe direction;

• prioritization, interpretation, and verification of alarms;

• procedure use;

• control board manipulations;

• oversight and direction from supervisors; and

• group dynamics.

Crew performance in these areas was compared to licensee management expectations and guidelines as presented in the Exelon procedures listed in the Attachment.

The inspectors verified that the crew completed the critical tasks listed in the simulator guide. The inspectors also compared simulator configurations with actual control board configurations. The inspectors verified that minor issues identified during the inspection were entered into the licensees corrective action program. For any weaknesses identified, the inspectors observed the licensee evaluators to verify that they also noted the issues and discussed them in the critique at the end of the session. This inspection constituted one sample.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

Routine Inspection

a. Inspection Scope

The inspectors reviewed the licensees overall maintenance effectiveness for risk-significant event initiating, mitigating, and barrier integrity systems. This evaluation consisted of the following specific activities:

• observing the conduct of planned and emergent maintenance activities where possible;

• reviewing selected CRs, open WOs, and control room log entries in order to identify system deficiencies;

• reviewing licensee system monitoring and trend reports;

• a partial walkdown of the selected system; and

• interviews with the appropriate system engineer.

The inspectors also reviewed whether the licensee properly implemented the Maintenance Rule, 10 CFR 50.65, for the system. Specifically, the inspectors determined whether:

• the system was scoped in accordance with 10 CFR 50.65;

• performance problems constituted maintenance rule functional failures;

• the system had been assigned the proper safety significance classification;

• the system was properly classified as (a)(1) or (a)(2); and

• the goals and corrective actions for the system were appropriate.

The above aspects were evaluated using the maintenance rule program and other documents listed in the Attachment. The inspectors also verified that the licensee was appropriately tracking reliability and/or unavailability for the systems.

As part of this inspection, the inspectors attended a periodic licensee Equipment Reliability Management Review Meeting where maintenance effectiveness was a principle subject. The inspectors also verified that minor issues identified in this inspection were entered into the licensees corrective action program.

The inspectors completed three samples in this inspection requirement by reviewing the following systems:

• direct current (DC);

• fuel pool cooling; and

• containment spray.

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the licensees management of plant risk during emergent maintenance activities or during activities where more than one significant system or train was unavailable. The activities were chosen based on their potential impact on increasing the probability of an initiating event or impacting the operation of safety-significant equipment. The inspections were conducted to verify that evaluation, planning, control, and performance of the work were done in a manner to reduce the risk and minimize the duration where practical, and that contingency plans were in place where appropriate.

The licensees daily configuration risk assessments records, observations of operator turnover and plan-of-the-day meetings, observations of work in progress, and the documents listed in the Attachment were used by the inspectors to verify that the equipment configurations were properly listed, that protected equipment were identified and were being controlled where appropriate, that work was being conducted properly, and that significant aspects of plant risk were being communicated to the necessary personnel. The inspectors verified that the licensee controlled emergent work in accordance with the expectations in the procedures listed in the Attachment.

In addition, the inspectors reviewed selected issues that the licensee entered into its corrective action program to verify that identified problems were being entered into the program with the appropriate characterization and significance.

The inspectors completed seven samples by reviewing the following activities:

• troubleshooting, replacement, and testing of Unit 1 DG load sequencing relay TSRA;

• online planned maintenance of instrument inverter 211;

• replacement and testing of Unit 2 K647 SI slave relay after it failed to remain latched when the SI signal was reset during a surveillance test;

• planning and preparation for a radioisotope tracer test on both units feedwater systems;

• response to calcium carbonate fouling of the 1B essential service water strainer and both trains of reactor containment fan coolers (RCFCs) in Unit 1;

• response to calcium carbonate fouling of the 2B essential service water strainer and 1D RCFC; and

• response to calcium carbonate fouling of the 2A train of RCFCs.

b. Findings

No findings of significance were identified.

1R14 Operator Performance During Non-Routine Evolutions and Events

a. Inspection Scope

The inspectors completed one sample by reviewing the control room operator response to an event involving unexpected isolation of the moisture separator reheaters (MSR)second stages on Unit 2, causing an automatic load reduction to 96 percent, followed by operators returning the MSRs to service and returning to full load conditions.

For this event, the inspectors observed control room activities, interviewed plant operators and other personnel, and reviewed plant records including control room logs, operator turnovers and condition reports. The inspectors verified that personnel errors did not contribute to the event, that the event was entered into the licensee corrective action program, and that the operator response to the event was in accordance with the applicable plant procedures. Documents reviewed as part of this inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors evaluated plant conditions and selected CRs for risk-significant components and systems in which operability issues were questioned. These conditions were evaluated to determine whether the operability of components was justified. The inspectors compared the operability and design criteria in the appropriate section of the UFSAR to the licensees evaluations presented in the CRs and documents listed in the Attachment to verify that the components or systems were operable. The inspectors also conducted interviews with the appropriate licensee system engineers to obtain further information regarding operability questions.

As part of this inspection, the inspectors attended a periodic licensee Plant Health Committee meeting and a periodic operational execution management review meeting where some of the operability concerns were discussed.

The inspectors completed six samples by reviewing the following operability evaluations and conditions:

• Operability Determination 03-004 (CR 164897) on elevated discharge pressures associated with the Unit 1 SI pumps;

• CR 199206 and its associated root cause investigation, as well as adverse condition monitoring plans in response to a large calcium carbonate precipitation event in the raw water systems;

• CR 199336 regarding broken lock washers discovered in the 1A DG;

• various condition reports describing fouling of several of the Units 1 and 2 emergency core cooling system pump lube and gear oil coolers due to a large calcium carbonate precipitation event in the raw water systems;

• CR 202627 regarding Unit 2 containment temperature approaching the TS limit of 120 degrees Fahrenheit including Engineering Change Request 347470 regarding using computer points rather than main control board indications for Unit 1 containment temperature; and

• CR 207044 regarding leakage from service water flange 2FE-SX031 during installation of a freeze seal on valve 0SX172.

b. Findings

No findings of significance were identified.

1R17 Permanent Plant Modifications

Annual Review

a. Inspection Scope

The inspectors evaluated the permanent plant modification installed under Engineering Change Request 42493 to install two new model DC-to-DC power supplies in the 1A DG control panel. This modification was chosen because it affected a risk-significant mitigating system.

Prior to the inspection, the inspectors reviewed the list of the top 40 proposed modifications, attended two readiness review meetings for the 1A DG work window, and reviewed the risk assessment and protected equipment for the work. During the inspection, the inspectors reviewed the design change package and associated WO for installation, observed the pre-job brief and actual installation of the modification, and reviewed the post-modification testing. The inspectors verified that the modification did not appear to introduce any new system vulnerabilities, did not create any new system interface problems, and that the testing verified that the system performed as designed with the most conservative initial conditions expected. Documents reviewed as part of this inspection are listed in the Attachment. The inspectors verified that minor issues identified during the inspection were entered into the licensees corrective action system.

This activity constituted one inspection sample of the annual requirement.

b. Findings

No findings of significance were identified.

1RST Post-Maintenance and Surveillance Testing - Pilot (71111.ST)

a. Inspection Scope

The inspectors reviewed post-maintenance and surveillance testing activities associated with important mitigating, barrier integrity, and support systems to ensure that the testing adequately verified system operability and functional capability. For post-maintenance testing, the inspectors used the appropriate sections of the TS and UFSAR, as well as the WOs for the work performed, to evaluate the scope of the maintenance and to verify that the post-maintenance testing was performed adequately, demonstrated that the maintenance was successful, and that operability was restored.

For surveillance testing, the inspectors verified that the testing met the TS, the UFSAR, and licensee procedural requirements, and demonstrated that the equipment was capable of performing its intended safety functions. The inspectors verified that the testing met the frequency requirements; that the tests were conducted in accordance with the procedures, including establishing the proper plant conditions and prerequisites; that the test acceptance criteria were met; and that the results of the tests were properly reviewed and recorded. The activities were selected based on their importance in verifying mitigating systems capability and barrier integrity. The inspectors verified that minor issues identified during the inspection were entered into the licensees corrective action system. Documents reviewed as part of this inspection are listed in the

.

Note that this inspection is a pilot for a proposed consolidated procedure combining the previous Post-Maintenance Testing (71111.19) and Surveillance Testing (71111.22)procedures.

Five samples were completed by observing post-maintenance testing after the following activities:

• work window on Unit 1 fuel pool cooling pump including rotating element and bearing replacement;

• work window on the 1A DG;

• work window on the 211 instrument inverter;

• 18-month preventive maintenance on the 0B diesel-driven fire pump; and

• work window on the 1A containment spray pump.

Six samples were completed by observing and evaluating the following surveillance tests:

• discharge testing of DC battery bus 223

• slave relay testing of the train A automatic SI relay K608;

• 1A AF pump quarterly American Society of Mechanical Engineers testing;

• 1B AF pump monthly testing;

• 2A DG bypass of automatic trips surveillance; and

• 2B DG monthly testing.

Although DC battery bus 223 was a nonsafety-related component, the associated testing was similar to that performed on the safety-related DC battery buses.

b. Findings

No findings of significance were identified.

1R23 Temporary Plant Modifications

a. Inspection Scope

The inspectors reviewed temporary modifications to verify that they did not have a unanalyzed affect on the safety functions of important safety systems. As part of this inspection, the inspectors reviewed the 10 CFR 50.59 screenings, appropriate UFSAR sections and TS to verify that system operability/availability were not affected. The inspectors verified that the installation was consistent with the design documents, that the installations were properly flagged, and that the appropriate post-installation testing was accomplished. Documents reviewed as part of this inspection are listed in the

. The inspectors verified that minor issues identified during this inspection were entered into the licensees corrective action program. This inspectors completed three samples of this inspection requirement by performing the following activities:

• walkdown of the auxiliary building looking for undocumented or unauthorized temporary modifications;

• review of Temporary Modification 344077 on the 1A and 1C SI accumulator power supplies; and

• installation of a freeze seal to facilitate maintenance on the Unit 2 component cooling water heat exchanger.

b. Findings

No findings of significance were identified.

1EP6 Drill Evaluation

a. Inspection Scope

The inspectors observed operator performance during an evaluated simulator drill. The inspectors observed event classification, NRC notifications, and other aspects of drill performance to identify weaknesses and ensured that the licensee evaluators had also noted the same weaknesses. The inspectors verified that deficiencies noted during the drill, by either the inspectors or licensee evaluators, were entered into the licensees corrective action program. The inspectors also attended the post drill critique for the simulator crew. Documents reviewed as part of this inspection are listed in the

. This activity constituted one inspection sample.

b. Findings

No findings of significance were identified.

RADIATION SAFETY

Cornerstone: Occupational Radiation Safety

2OS1 Access Control to Radiologically Significant Areas (71121.01)

.1 Review of Licensee Performance Indicators (PIs) for the Occupational Exposure

Cornerstone

a. Inspection Scope

The inspectors reviewed the licensees records to determine if any occupational exposure control cornerstone PIs had been identified during the previous five calender quarters. If PIs had been identified, the inspectors would have determined whether or not the conditions surrounding the PIs had been evaluated and identified problems had been entered into the corrective action program for resolution. This review represented one sample.

b. Findings

No findings of significance were identified.

.2 Plant Walkdowns and Radiation Work Permit Reviews

a. Inspection Scope

The inspectors walked down and surveyed (using an NRC survey meter) selected areas in the Units 1 and 2 auxiliary buildings to verify that the prescribed radiation work permit, procedure, and engineering controls were in place, that licensee surveys and postings were complete and accurate, and that air samplers were properly located. This review represented one sample.

b. Findings

No findings of significance were identified.

Cornerstone: Public Radiation Safety

2PS2 Radioactive Material Processing and Transportation (71122.02)

.1 Radioactive Waste System

a. Inspection Scope

The inspectors reviewed the liquid and solid radioactive waste system description in the UFSAR for information on the types and amounts of radioactive waste (radwaste)generated and disposed. The inspectors reviewed the scope of the licensees audit program with regard to radioactive material processing and transportation programs to verify that it met the requirements of 10 CFR 20.1101(c). This review represented one sample.

b. Findings

No findings of significance were identified.

.2 Radioactive Waste System Walkdowns

a. Inspection Scope

The inspectors performed walkdowns of the liquid and solid radwaste processing systems to verify that the systems agreed with the descriptions in the UFSAR and the Process Control Program, and to assess the material condition and operability of the systems. The inspectors reviewed the status of radioactive waste process equipment that was not operational and/or was abandoned in place. The inspectors reviewed the licensees administrative and physical controls to ensure that the equipment would not contribute to an unmonitored release path or be a source of unnecessary personnel exposure.

The inspectors reviewed changes to the waste processing system to verify the changes were reviewed and documented in accordance with 10 CFR 50.59 and to assess the impact of the changes on radiation dose to members of the public. The inspectors reviewed the current processes for transferring waste resin into shipping containers to determine if appropriate waste stream mixing and/or sampling procedures were utilized.

The inspectors also reviewed the methodologies for waste concentration averaging to determine if representative samples of the waste product were provided for the purposes of waste classification in 10 CFR 61.55. This review represented one sample.

b. Findings

No findings of significance were identified.

.3 Waste Characterization and Classification

a. Inspection Scope

The inspectors reviewed the licensees radiochemical sample analysis results for each of the licensees waste streams, including dry active waste, spent resins and filters. The inspectors also reviewed the licensees use of scaling factors to quantify difficult-to-measure radionuclides (e.g., pure alpha or beta emitting radionuclides). The reviews were conducted to verify that the licensees program assured compliance with 10 CFR 61.55 and 10 CFR 61.56, as required by Appendix G of 10 CFR Part 20. The inspectors also reviewed the licensees waste characterization and classification program to ensure that the waste stream composition data accounted for changing operational parameters and thus remained valid between the annual sample analysis updates. This review represented one sample.

b. Findings

No findings of significance were identified.

.4 Shipment Preparation

a. Inspection Scope

The inspectors observed surveying, placarding, vehicle checks, emergency instructions, disposal manifest, shipping papers provided to the driver, and licensee verification of shipment readiness for a shipment of radioactive dry active waste to a waste disposal site. The inspectors reviewed the training records provided to personnel responsible for the conduct of radioactive waste processing and radioactive shipment preparation activities. The review was conducted to verify that the licensees training program provided training consistent with NRC and Department of Transportation requirements.

b. Findings

No findings of significance were identified.

.5 Shipping Records

a. Inspection Scope

The inspectors reviewed five non-excepted package shipment manifests/documents completed in 2002/2003 to verify compliance with NRC and Department of Transportation requirements (i.e., 10 CFR Parts 20 and 71, and 49 CFR Parts 172 and 173). This review represented one sample.

b. Findings

No findings of significance were identified.

.6 Identification and Resolution of Problems

a. Inspection Scope

The inspectors reviewed condition reports and a self assessment that addressed radioactive waste and radioactive materials shipping program deficiencies since the last inspection, to verify that the licensee had effectively implemented the corrective action program and that problems were identified, characterized, prioritized and corrected.

The inspectors also verified that the licensee's self-assessment program was capable of identifying repetitive deficiencies or significant individual deficiencies in problem identification and resolution.

The inspectors also reviewed corrective action reports from the radioactive material and shipping programs since the previous inspection, interviewed staff and reviewed documents to determine if the corrective measures were being conducted in an effective and timely manner commensurate with their importance to safety and risk. This review represented one sample.

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator Verification

Cornerstones: Initiating Events and Mitigating Systems Reactor Safety Strategic Area

a. Inspection Scope

The inspectors reviewed documents listed in the Attachment to verify that the licensee had corrected reported PI data, in accordance with the criteria in Nuclear Energy Institute 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 2.

The data reported by the licensee was compared to a sampling of control room logs, CRs, and other sources of data generated since the last verification. The inspectors completed six samples by verifying the following PIs:

Unit 1

• unplanned scrams per 7000 critical hours for the period from October 1, 2002, to December 31, 2003;

• unplanned scrams with loss of normal heat removal for the period from October 1, 2002, to December 31, 2003; and

• safety system unavailability, pressurized water reactor residual heat removal system, from October 1, 2002, to December 31, 2003.

Unit 2

• unplanned scrams per 7000 critical hours for the period from October 1, 2002, to December 31, 2003;

• unplanned scrams with loss of normal heat removal for the period from October 1, 2002, to December 31, 2003; and

• safety system unavailability, pressurized water reactor residual heat removal system, from October 1, 2002, to December 31, 2003.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

.1 Routine Review of Identification and Resolution of Problems

a. Inspection Scope

As discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensees corrective action system at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Minor issues entered into the licensees corrective action system as a result of inspectors observations are generally denoted in the Attachment. These activities were part of normal inspection activities and were not considered separate samples.

b. Findings

No finding of significance were identified.

.2 Review of Licensee Focused Area Self Assessments (FASAs) (Annual Sample)

Introduction The licensee had instituted a practice of performing FASAs prior to major NRC inspections in order to determine its readiness for the inspection and correct any problems noted. The inspectors selected this area for review to assess the quality of those FASAs and the effectiveness and timeliness of any corrective actions taken as the result of deficiencies identified in the FASAs. The inspectors selected six FASAs performed in 2003. These FASAs were performed by the licensee in preparation for NRC inspections in the areas of safety system design inspection, fire protection, licensed operator requalification training program, inservice inspection activities, emergency preparedness, and radiological environmental monitoring program. As part of this inspection, the inspectors verified that minor issues identified were entered into the licensees corrective action program.

a. Effectiveness of Problem Identification

(1) Inspection Scope The inspectors reviewed the scope of the six FASAs and the deficiencies and recommendations identified. The inspectors compared the deficiencies to any NRC findings from the subsequent inspections.

(2) Issues Overall the licensee identified a total of 18 deficiencies in the six FASAs. In the associated NRC inspections, the NRC identified a total of three findings/violations. However, two of the findings were in areas that were outside the scope of the FASAs. One NRC finding, in the fire protection area, was associated with a design calculation specifically reviewed during the associated FASA. The inspectors determined that a more thorough licensee review of the status of that calculation might have identified the finding before the NRC inspection.

The inspectors determined that the licensee did not routinely go back and review the scope, depth, results, and corrective actions associated with the pre-NRC inspection FASAs after the NRC inspections were over. The licensee was missing opportunities to capture lessons learned to improve future FASAs.

The licensees Nuclear Oversight (NOS) group routinely reviewed completed FASAs for quality and compliance with the licensees procedural guidance. The inspectors noted that NOS had written 18 CRs in 2003 associated with its reviews of FASAs. The inspectors discussed the quality of FASAs with the NOS manager and were told that NOS considered the quality of FASAs as an area needing significant improvements.

b. Prioritization and Evaluation of Issues

(1) Inspection Scope The inspectors reviewed the action tracking items (ATIs) initiated as a result of the FASAs reviewed to determine if all deficiencies identified in the FASAs had associated ATIs, if the ATIs had been assigned reasonable due dates based on the significance of the issue, and if ATIs were being completed in a timely manner.

(2) Issues No significant issues were identified with the prioritization and evaluation of the issues identified in the FASAs. The inspectors reviewed a total of 54 ATIs initiated as a result of the six FASAs reviewed. The inspectors determined that 40 of those had been closed on their original schedule. Generally the items were closed prior to the associated NRC inspection. An additional eight ATIs had been closed, but only after due date extensions. The due date extensions were generally justified and reasonable. One ATI was canceled with the appropriate justification. Five ATIs were still open. None were overdue but two had due date extensions. The inspectors reviewed the open ATIs and determined that they were appropriately prioritized and scheduled.

c. Effectiveness of Corrective Actions

(1) Inspection Scope The inspectors reviewed ATIs initiated as a result of the FASAs to determine if they appeared to be effective in correcting the associated problem.

(2) Issues The inspectors determined that two of the 54 ATIs reviewed were closed without the action actually being accomplished. The fire protection FASA identified, among other observations and deficiencies, the need to update the pre-fire plan to eliminate duplication and to revise a reference. The licensee initiated ATIs 159022-03 and 159022-07, with due dates of September 26, 2003, for those issues. The ATIs were assigned to the operations department. Both ATIs were closed on their due dates with the notation that new ATIs had been initiated to re-assign the actions to the fire marshal with new due dates of February 27, 2004. However, the inspectors determined that the new ATIs had never been created. Even if the fire marshal knew about the expected actions, they would probably not have been completed, because the fire marshal had retired and been replaced subsequent to the action being assigned. After informing the fire protection engineer about this issue, the inspectors verified that new ATIs were initiated and entered the fact that the original ATIs had been improperly closed into the corrective action program.

4OA3 Event Followup

The inspectors completed four inspection samples in this area.

.1 (Closed) Licensee Event Report (LER) 05000457/2003-003-00: Inadvertent Auxiliary

Feedwater Engineering Safety Features Actuation Due to Placing a Clearance Order Ahead of the Outage Schedule.

This event was previously discussed in Inspection Report 05000456/2003008; 05000457/2003008, Section 4OA3.4. The inspectors reviewed the LER, related CRs, and other associated documents as listed in the Attachment. The inspectors verified that all corrective actions in the LER were in the licensees corrective action tracking process. As discussed in the previously mentioned report, this event was considered a minor issue with no adverse consequences.

.2 (Closed) LER 05000457/2003-004-00: Unit 2 Reactor Trip and Auxiliary Feedwater

Emergency Actuation Due to Cascading Feedwater Pump Trips Caused by Lack of Preventative Maintenance.

The inspectors reviewed the LER, related CRs, and other associated documents as listed in the Attachment. The inspectors also discussed the event with appropriate members of the licensees engineering and operating staff.

This issue was previously described in Sections 1R14 and 4OA3.5 of Inspection Report 05000456/2003006; 05000457/2003006. As stated in that report, the inspectors determined that a performance deficiency was not a significant contributor to this event and thus, no finding was involved.

The licensees corrective actions, as described in the LER, included inspections of control cabinets for foreign material, replacement of plastic tie-wraps with a more suitable type, replacement of the 2B feedwater pump speed control circuit card and improved procedures for monitoring and preventive maintenance of the speed control circuit cards.

The inspectors determined that no new significant safety issues were identified in the LER.

.3 (Closed) LER 05000457/2003-005-00: Setpoint Drift Causes Three of Three

Pressurizer Safety Valve Lift Tests to Exceed TS Tolerance.

The inspectors reviewed the LER, related CRs, and other associated documents as listed in the Attachment.

In the LER the licensee reported that all three of the pressurizer safety valves tested at an offsite facility after the fall 2003 Unit 2 refueling outage were found to be slightly outside of their TS + 1 percent tolerance. However, all three were within the + 3 percent tolerance specified by the American Society of Mechanical Engineers for that application. The vendor inspected the valves and identified no material condition issues.

The inspectors determined that a performance deficiency did not contribute to this event.

At the time of discovery, the licensee had already replaced the safety valves with refurbished valves having setpoints within the TS band. The licensees corrective actions, as described in the LER, included a revision of the safety analyses to support relaxation of the tolerance in the TSs for the lift setpoint and submission of a license amendment request to revise the TSs.

The enforcement aspects of this event are described in Section 4OA7 of this report.

.4 Potential Operation of Unit 1 Above the Licensed Thermal Power Limit

On March 1, 2004, the licensee reported via the Emergency Notification System that it had determined that Unit 1 had potentially exceeded its maximum licensed thermal power level of 3586.6 megawatts thermal, as stated in License Condition 2.C.(1), by up to 1.07 percent on at least one occasion between June 1999 and September 2003. The issue involved signal noise problems in the ultrasonic feedwater flow detectors. This was the same issue as previously reported and discussed in an Event Notification dated August 31, 2003, and updated on September 2, 2003, LER 05000457/2003-002-00, Inspection Report 05000456/2003006; 05000457/2003006, Section 4OA3.4, and Inspection Report 05000456/2003008; 05000457/2003008, Sections 4OA3.2 and 4OA7.

The new information in this notification was that Unit 1 may have been affected enough to have exceeded its licensed limit rather than only Unit 2 as previously reported. This was based on new testing at both the Braidwood and Byron stations that indicated that the feedwater flow error could have been greater than originally reported. Because of questions regarding the accuracy of the ultrasonic flow instrumentation, the licensee had removed them from service on both units in September 2003.

As previously discussed in Inspection Report 05000456/2003008; 05000457/2003008, Section 4OA3.2, the inspectors determined that the issue was not a licensee performance deficiency and was, therefore, not a finding. As discussed in that report, the inspectors determined that the potential overpower did not significantly challenge either the reactor coolant or fuel integrity barriers and was of very low safety significance. The potential overpower condition was within the bounds of the assumptions in the accident analysis in the UFSAR. The licensee entered the issue into its corrective action program as CR 205273 and intended to revise LER 05000457/2003-002 with the new information by March 31, 2004. The enforcement aspects of this issue are discussed in Section 4OA7 of this report.

4OA6 Meetings

.1 Exit Meeting

The inspectors presented the inspection results to Mr. T. Joyce and other members of licensee management at the conclusion of the inspection on April 15, 2004. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

.2 Interim Exit Meeting

An interim exit was conducted for:

• Radiation Protection inspection with Mr. M. Pacilio on January 9, 2004.

4OA7 Licensee-Identified Violations

The following violations of very low safety significance were identified by the licensee and are violations of NRC requirements which meet the criteria of Section VI of the NRC Enforcement Policy, NUREG 1600, for being dispositioned as Non-Cited Violations.

Cornerstone: Mitigating Systems

Technical Specification 3.4.10 required that three pressurizer safety valves shall be operable with lift settings greater or equal to 2460 pounds per square inch and less than or equal to 2510 pounds per square inch. With two or more pressurizer safety valves inoperable, the TS required that the plant be shutdown to Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 4 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Contrary to the above, as described in LER 05000457/2003-005-00 (see Section 4OA3.3), on December 10, 2003, the licensee discovered that three out of three pressurizer safety relief valves on Unit 2 had setpoints slightly outside of the TS limits.

The setpoints were measured after the valves had been removed during a refueling outage. However, based on engineering judgement, it is likely that the valves were outside the TS value during operation in excess of the time allowed for conducting a shutdown. This violation was of very low safety significance because the condition was bounded by the accident analysis in the UFSAR. The licensee entered this event into its corrective action program as CR 18994. Prior to measuring the setpoint, the licensee had already replaced the three valves with spare valves that had setpoints within the TS limits. In addition, the licensee had already submitted a TS amendment request to relax the relief valve lift tolerance.

Cornerstone: Barrier Integrity

Condition 2.C(1) of the Unit 1 Operating License required that reactor core power levels not exceed 3586.6 megawatts thermal (100 percent rated power). Contrary to the above, as discussed in Section 4OA3.4 of this report, on March 1, 2004, the licensee identified that Unit 1 may have exceeded its licensed power level by as much as 1.07 percent, owing to incorrectly measured feedwater flows using ultrasonic flow detectors. Based on the readings from the flow venturies and engineering judgement, the inspectors determined that it is likely that actual overpower conditions had existed between June 1999 and September 2003. The violation was of very low safety significance because the condition was bounded by the accident analysis in the UFSAR.

This item was entered into the licensees corrective action program as CR 205273. The licensee had suspended using the ultrasonic flow detectors in question in September 2003.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

T. Joyce, Site Vice President

K. Polsen, Plant Manager

G. Dudek, Operations Manager

C. Dunn, Site Engineering Director

R. Gilbert, Nuclear Oversight Manager

J. Moser, Radiation Protection Manager

K. Root, Regulatory Assurance Manager

E. Stefan, Regulatory Assurance - NRC Coordinator

B. Stoffels, Maintenance Manager

Nuclear Regulatory Commission

A. Stone, Chief, Reactor Projects Branch 3

LIST OF ITEMS

Opened

None.

Closed

05000457/2003-003-00 LER Inadvertent Auxiliary Feed Water Engineering Safety Feature Actuation Due to Placing a Clearance Order Ahead of the Outage Schedule (Section 4OA3.1)

05000457/2003-004-00 LER Unit 2 Reactor Trip and Auxiliary Feedwater Emergency Actuation Due to Cascading Feedwater Pump Trips Caused by Lack of Preventative Maintenance (Section 4OA3.2)

05000457/2003-005-00 LER Setpoint Drift Causes Three of Three Pressurizer Safety Valve Lift Tests to Exceed TS Tolerance (Sections 4OA3.3 and 4OA7)

Discussed

05000457/2003-002-00 LER Licensed Maximum Power Level Exceeded Due to Inaccuracies in Feedwater Ultrasonic Flow Measurements Caused by Signal Noise Contamination (Sections 4OA3.4 and 4OA7)

Attachment