ML20150E970

Operational Readiness Insp Rept 50-457/88-07 on 880216-0307. Violations Noted.Major Areas Inspected:Operations, Surveillance & Testing,Maint,Radiation Controls,Chemistry Controls,Nuclear Engineering Activities & Training

ML20150E970
Person / Time
Site:	Braidwood
Issue date:	03/29/1988
From:	Phil Brochman, Grant W, Hare S, Kropp W, Lanksbury R, Little B, Phillips M, Sands S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20150E964	List: ML20150E961 ML20150E967 ML20150E970
References
50-457-88-07, 50-457-88-7, GL-82-12, NUDOCS 8804040216
Download: ML20150E970 (20)

See also: IR 05000457/1988007

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U.S. NUCLEAR REGULATORY COMMISSION  !

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REGION III

, Report No. 50-457/88007(DRS)

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Docket No. 50-457 License No. NPF-75 ,

Licensee: Commonwealth Edison Company *

Post Office Box 767

Chicago, IL 60690

Facility Name: Braidwood Station, Unit 2

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Inspection At: Braidwood Site, Braidwood, Illinois

Inspection Conducted: February 16 through March 7, 1988

) NRC Operational Readiness Inspection Team

Inspectors

Team Leader: R. D. Lanks ury 1/b9/f7

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Team Members: P. G. Brochman 66 349/6S i

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W. B. Grant

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! Approved By: M. P. Phillips, Chief -

Operations Section Date l

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! 8804040216 880329  :

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Inspection Summary

Inspection on February 16 through March 7, 1988 (Report No. 50-457/88007(DRS))

Areas Inspected: Special announced team inspection by Region 111, NRC

Headquarters, and senior resident based inspectors to perform an operational

readiness inspection prior to full power licensing of the Braidwood Unit 2

plant. Areas reviewed included: operations, surveillance and testing,

maintenance, radiation controls, chemistry controls, nuclear engineer

activities, and training.

Results: Of the seven functional areas inspected, no violations or

deviations were identified in six of the seven areas. However, one Open Item

(paragraph 5.f) was identified in one functional area (maintenance) to track

resolution of a perceived problem with the licensee's scheduling of periodic

lubrications, and one Unresolved Item (paragraph 6) was identified in another

functional area (radiation controls) to track resolution of a potential

noncompliance with Technical Specification requirements for control of Radiation

Control Technicians overtime. Within the remaining functional area (operations)

two violations were identified. One violation (paragraph 3.j) was identified

for failure to write a deviation report, as required, after the Boric Acid

Transfer Pumps recirculation line was identified as having become plugged.

The second violation (paragraph 3.k) involved multiple examples of a weak and

ineffective Out-of-Service program. After returning to the Braidwood station

to followup on corrective actions instituted by the licensee as a result of

the initial inspection, the ORI was able to make a recommendation to Region III

management for issuance of a full power license for Braidwood Unit 2.

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DETAILS

1. Persons Contacted

Commonwealth Edison Company (CECO)

+T. J. Maiman, Vice President PWR Operations

+K. L. Graesser, General Manager Nuclear Operations

+E. E. Fitzpatrick, Station Manager

@+K. Kofron, Production Superintendent

@+D. E. O'Brien, Services Superintendent

@+P. L. Barnes, Regulatory Assurance Supervisor

0+E. W. Carroll, Regulatory Assurance

@T. W. Simpkin, Regulatory Assurance

+L. M. Kline, Regulatory Assurance

+R. E. Acker, Radiation / Chemistry Supervisor

+G. R. Masters, Assistant Superintendent Operating

+D. E. Paquette, Assistant Superintendent Maintenance

+J. G. Marshall, Unit 2 Station Startup Assistant

+R. J. Ungeran, Operating Engineer, Unit 1

+R. Yungk, Operating Engineer, Unit 2

+R. A. Fussner, Staff Engineer, PWR Operations

+P. F. Hart, QA Engineer

+J. A. Jursenas, QA Engineer

+E, Steckhan, QA Engineer

+R. E. Benn, Assistant Security Administrator

+R. C. Herbert, Nuclear Safety

+S. C. Hunsader, Nuclear Licensing Administrator

@K. Boyle, Operations Staff

@R. Legner, Senior Operations Engineer

The inspectors also contacted and interviewed other licensee and

contractor personnel.

Nuclear Regulatory Commission

+E. G. Greenman, Director, Division of Reactor Projects, Region III

+W. L. Forney, Chief, Projects Branch 1, Region III

+J. M. Hinds, Jr., Chief, Projects Section 1A, Region III

@+T. M. Tongue, Senior Resident Inspector, Braidwood

• T. E. Taylor, Resident Inspector, Braidwood

@+R. D. Lanksbury, Operational Readiness Inspection Team Leader,

Region III

@+B. H. Little, Sennr Resident Inspector, Callaway

+P. G. Brochman, Sen!or Resident Inspector, Byron

+S. M. Hare, Reactor inspector, Region III

+5. P. Sands, Licensing Project Manager, Office of Nuclear Reactor

Regulation (NRR)

+W. B. Grant, Radiation Specialist, Region III

+W. J. Kropp, Reactor Inspector, Region III

+ Denotes those attending the interim exit meeting on February 19, 1988.

@ Denotes those attending the exit meeting on March 7, 1988.

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2. General

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The Operational Readiness Inspection (0RI) was conducted in order to

help determine whether Commonwealth Edison Company should receive a

recommendation from Region III to operate Braidwood Unit 2 above 5%

reactor power. Licensee activities were closely monitored in order to

ensure the facility was being operated safely and to ascertain the

licensee's readiness to operate at power levels up to 100%. The

, inspection included examination of the interface between the operations

department and other on-site organizations to assess the effectiveness

of the entire station organization.

In June of 1987 an ORI was conducted for Braidwood Unit 1. Because of

the broad scope of this ORI and the relatively short duration between it

and the Unit 2 ORI, certain areas, such as lines of responsibility, that

are common to both units and for which there was no indication of

significant changes, were not re-inspected.

The ORI team was comprised of the leader, a region based reactor

inspector; two Senior Resident Inspector (SRI's) from other operating

reactor facilities in Region III, the NRR licensing project manager for

Braidwood, two region based reactor inspectors, and one region based

radiation specialist.

3. Plant Operations (36700, 71707, 71715)

An inspection of plant operations was performed by observing the

performance of the licensee's operating staff on all shifts with the

following objectives (it should be noted that during this inspection

neither Unit I nor Unit 2 was critical and therefore observation of

plant operation was constrained):

• Determine adequacy of shift turnovers, attentiveness to indications,

communications between operators, awareness of plant status,

procedural compliance, control room congestion, completeness

and accuracy of logs, performance during abnormal conditions,

communications with other departments, independent verification

effectiveness, and the effectiveness and involvement of supervision

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and management.

Review workload of operating crew, especially staff assistants.

Determine quality of prioritizing the work that goes through the

operations group before scheduling.

• Review folluwups to events, critiques of events, and LC0 Time Clocks

(who tracks, how, effectiveness).

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Evaluate communications between the Control Room personnel and

others, particularly during off normal events.

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The following observations were made:

a. Adequacy of shift turnovers - The shift turnover process at

Braidwood may be subdivided into three distinct evolutions. The

first part of the shift turnover was made possible by the oncoming

shift arriving an hour early, performing a panel walkdown, and

discussing with their individual counterparts the turnover checklist

and plant status. The second part of shift turnover was the shift

briefing at which representatives from the oncoming operations,

maintenance, health physics, chemistry, and technical services staff

discuss plant status and planned activities for the upcoming shift.

The third and final portion of the shift turnover has the Shift

Engineer (SE), Shift Control Room Engineer (SCRE) and Center Desk

Operator brief the oncoming plant operators on plant status and

activities planned for the shift.

Shift turnover activities were monitored throughout the inspection

period for all of the day, swing and mid-shift turnovers. The

inspector's noted that shift turnovers were professionally conducted

and sufficiently comprehensive in scope to ensure that the oncoming

shifts were aware of plant status and the activities planned for

that shift.

b. Attentiveness to indications - Operators were alert and attentive

to panel instruments and alarms at all times. All abnormal

instrumentation indication observed was adequately responded to,

with Work Requests (WR's) generated as appropriate,

c. Awareness of plant status - With the exception of one instance,

all shifts appeared aware of plant status as demonstrated through

inspector observation and interviews with operators. The inspectors

noted that when Unit 1 was in mode 4 and the Volume Control Tank (VCT)

was being "burped" to replace the nitrogen cover gas with hydrogen,

that the Unit 1 Nuclear Station Operator (NS0) appeared not to be

aware of the evolution. The Unit NSO queryed the equipment attendant

who had just performed valve manipulations on a Reactor Coolant Pump

(RCP) filter / drain line as to whether he had left any valves open or

leaking. The Unit NSO then directed the attendant to go back and

check the drain line for leakage. The inspector questioned the

Unit NSO as to why he had urgently dispatched the attendant back

into the field. The NSO indicated that the VCT had experienced a

rapid decrease in level which he believed was caused by a leak.

The inspector went to the VCT level / pressure strip chart recorder

and noted that the rapid VCT level decrease was caused by the

diversion of letdown to the Hold Up Tank. The extra NSO on shift

who had been monitoring this evolution confirmed the inspector's

observations. This event indicated the following:

(1) Shift management had not successfully communicated with the

Unit NSO.

(2) The Unit NSO was insuf ficiently aware of the plant's status to

know why the VCT level was dropping.

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(3) The extra NSO who was monitoring the process did not communicate

to the unit NSO why VCT level was dropping.

With the exception of this instance, all other shifts appeared aware

of plant status. However, the ORI did note that interviews with

operations staff personnel indicated a general lack of confidence

in plant status do to the current system in place for Out-0f-Services

and Temporary Lif ts (these are further discussed in Section 3.k).

d. Communications - Communications within the operating staff were

observed to be good with information flowing smoothly from the SE

and shift foremen (SF) to the SCRE to the licensed and non-licensed

operators. Communications between departments during the shiftly

briefings also appeared to be good. The only instance of poor

communication observed is described in paragraph C above.

e. Control room congestion The control room was not overly congested

during the inspection period even though Unit 2 was in mode three

while Unit 1 was attempting to come on line after an outage,

f. Completeness and accuracy of logs - The SE, SF, SCRE, and NS0's logs

were reviewed for accuracy and thoroughness. The following

deficiencies in log keeping were identified: ,

(1) The NSO's log contained only infrequent notes (one) on when the

Boric Acid Transfer Pumps (BATPs) were run to recirculate the

Boric Acid Storage Tanks even thou0h the BATPs were run once

every several days.

(2) The NS0's logs did not identify that the Boric Acid recirculation

line was found plugged on February 18, 1988, which made

recirculation of boric acid from the tank impossible.

(3) The Unit 2 NSO log did not document the Unit 2 BATP failure of

a post-maintenance test even though the NS0 was contacted by the

personnel performing the test tn stop the pump due to it's

imminent failure.

(4) The Shif t Foreman who approved the temporary lif t to perform

the BATP post-maintenance test did not document the failure

which resulted in him not discussing pump failure during shift

turnover.

Additional deficiencies related to the accuracy and thoroughness of

logs have also been identified by the Resident Inspectors. Additional '

information pertaining to this item is contained in their inspection

report (456/88008(DRP); 457/88009(DRP)).

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g. Performance during abnormal conditions - During this inspection

period two (2) instances were noted in which operator action was

taken in response to abnormal conditions.

(1) On February 18, 1988, on the mid shift, a Unit 2 source range

nuclear instrument, NI-31, was returned to service af ter

calibration per Bw!P 2504-003. As a result of this instrument

being returned to service, a Boron Dilution Prevention System

actuation occurred due to several steps in the procedure being

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out of order. After diagnosis, the operators promptly took

action to return the plant to its previous configuration which

required reestablishing normal letdown and switching the

suction of the charging pumps frem the Refueling Water Storage

Tank (RWST) to the VCT. The operators performance for this

event was good. Actions were taken to generate a procedural

revision to reverse the subject procedural steps.

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(2) On February 13, 1988, en the swing shift, an LC0 was entered

on Unit 2 which required Unit 2 to reduce temperature and

change modes. When normal makeup was initiated to maintain VCT

level, the operators noted no boric acid flow. Per abnormal

procedure PRI-2, the operators attempted to establish normal

and emergency boric acid makeup. When this effort failed, the

e NS0's dispatched plant operators to troubleshoot the problem.

As a result of this troubleshooting effort, a boric acid flow

path was later established. Operator action in response to

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this event was considered good,

b. Workload of operating crews - Inspectors viewed workload as heavy

which is normal for a plant that is, in effect, starting up two

units at once. While the workload was heavy, business was conducted

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in an orderly fashion and, with the exception of the administrative

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aspects of the Temporary Lift program, the workload appeared well

managed,

i. Effectiveness and involvement of supervision and management -

Inspectors attended shif tly turnover meetings where plant status

and plans for the shift were discussed. Management personr.el other

than the normal shif t complement were observed in the mid to day

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shift and the day to swing shift turnovers. Further, sentoc plant

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management was observed in the control room at least once during the

day and swing shifts. Conversations with shift personnel indicated

that station management was involved in plant operation in positive

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ways. Based on inspector observations and personnel interviews, the

inspectors concluded that management involvement with plant operations

was comprehensive and effective,

j. Event followup and evaluation - On February 18, 1988, at 1635 C$i,

the Unit 2 Nuclear Supervising Operator (NS0) attempted, but was

unable to initiate normal or emergency boration using the "0" Boric

Acid Transfer pump. Subsequently, during a system walkdown, the

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licensee found Valve 2AB8458 (miniflow recirculation valve) closed,

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Based on discussion with the Unit 2 NS0 and a review of the NSO

log, the inspector determined that the "0" BATP pump had been

running in the recirculation mode when the NSO assumed the watch

(at approximately 1500 CST), and apparently had become steam bound.

There was no log entry on starting the "0" BATP in the recirculation

mode. Additionally, after opening valve 2AB8458 and running the

"0" BATP pump, flow to the CVCS system was verified, but still no

recirculation flow was obtained. The NSO expressed belief that the

recirculation line was plugged; however, the problem of the plugged

recirculation line was not entered in the NSO log, nor was a deviation

report initiated to document the deficient condition.

Administrative procedure BwAP 1250-2 (Deviation Reporting) defines a

deviation as: "a departure from accepted equipment performance or a

failure to comply with administrative controls or NRC requirements

which results in, or could, if uncorrected, result in a failure of

an item to perform as required by Technical Specification or

approved procedures."

BwAP 1250-2 Paragraph 3 (Processing of Deviations) specifies that

the person identifying the deviation: "Initiate a Deviation Report

(DVR) Form 15-52 1. Enter as much applicable information as is

known on Part 1 of the DVR and forward the DVR to the Scpervisor

responsible for the equipment or activity."

The licensee's failure to initiate a deficiency report documenting

the plugged recirculation line is contrary to administrative

procedure BwAP 1250-2 and is a violation (457/88007-01/(ORS)) of

10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action,

k. Equipment Control - The inspectors reviewed the licensee's equipment

control program to assess the overall system readiness for operation

and administrative controls associated with equipment / systems in an

"Out-Of-Service" (005) condition. The licensee's 005 program was

i described in procedure BwAP 330-1, Station Equipment Out-0f-Service

Procedure, Revision 5 dated January 7, 1988. In addition to reviewing

several 005 packages, a review of Temporary Lifts was also performed.

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Temporary Litts are intended to allow testing of equipment following

) maintenance, but prior to clearing the 005. As a result of this

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review, the inspectors determined that the licensee's 00S program

was not effective in that:

(1) Five of approximately 14 Temporary Lif t packages the were

in effect were reviewed and had been processed (005 tags removed)

without the specified documented authorization:

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(a) The Temporary Lift for the following 005 No.'s contained

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no documented authorization: 88-1-0048, 88-1-0049,

ILC-MS114 and MSXXX. This was contrary to paragraph C.6.b.2.

of the subject procedure which required Shift Engineer

(or designee)/ Shift Foreman authorization on all Temporary

Lifts,

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(b) The Temporary Lif t for 00S No. 88-1-428, had been r

authorized by the Shift Foreman on February 9,1988, i

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As of February 17, 1988, the specified Shif t Engineer's

approval had not been documented. This was contrary to

paragraph C.6 b.3. of the subject procedure which required

Shift Engineer approval on all Temporary Lifts which.

extend greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Subsequent to this, the inspectors reviewed completed Temporary

, Lif t Forms for August, October, and December 1987. Of the

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approximately 2000 forms reviewed, 20 (or approximately 1%)  ;

were missing the. required signatures.  ;

The licensee's failure to follow the required approval _

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requirements for the approval of Temporary Lift packages was "

an example of a Violation (457/88007-02A(DRS)) of 10 CFR Part 50,

j Appendix B, Criterion V requirements for following procedures.

(2) Of the 14 Temporary Lift records reviewed the following

4 examples were identified where Temporary Lif t instructions

] were not complied with:

(a) Temporary lift for 005 No. 88-1-42P specified that the

equipment was "To be returned to service on February 9,

1988." This action had not been performed as of

February 17, 1988.

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(b) Temporary Lift for 005 No. 88-2-0201 specified that: "Leave

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Temp Lifted until RCS reaches 557*F, then rehang." Unit 2

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reactor coolant reached 557'F on February 16, 1988 and this

action had not been peformed as of February 18, 1988,

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Procedure BwAP 330-1 was not appropriate to the circumstances

in that it failed to contain guidance describing the use of

instructions on Temporary Lifts. The procedure also contained

no method to track instructions on Temporary Lif ts, This was

considered an example of a Violation (457/88007-02B(DRS)) of

1 10 CFR Part 50, Appendix B, Criterion V requirements for

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appropriate procedures.

l (3) The status of mechanical and electrical equipment under

l Temporary Lift was not documented. Unit I had approximately

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100 Temporary Lift packages, each containing multiple tags,

i Unit 2 had 11 Temporary Lift packages. Although several record

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sheets contained as left required component positions, most

sheets did not. The record sheets did not provide for the

l required component positions nor did the Temporary Lift

l procedure require such notations be entered. The ORI team

i noted that the absence of an as left required component

position on the Temporary Lif t form was a weakness in the

licensees 00S program.

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(4) On January 10, 1988, 00S88-096 was completed and lifted.

This Equipment Outage identified valve 1AF009B as closed and

when the outage was liftad, valve 1AF009B was left in the closed

outage position. When the Manual SI 18 month surveillance was

run on February 7, 1988, a valve lineup was not required by

procedure nor performed. As a result, the Diesel Auxiliary

Feedwater AFW pump was operated with its recirculation valve

(1AF0098) closed. The operation of the pump with its

recirculation valve closed resulted in failure of the pump.

This caused significant damage to the pump which required

extensive repair. The restoration of the subject 005 was

inadequate to ensure the correct normal valve lineup.

Procedure BwAP 330-1, Section C.4.n., required that when

returning equipment to service, that all equipment listed on

the equipment outage form be returned to service. The failure

to return valve 1AF0098 to service from its Out of Service

position was an example of a Violation (457/88007-02C(DRS))

of 10 CFR Part 50, Aopendix B, Criterion V requirements for

following procedures.

(5) A Temporary Lift was issued on February 17, 1988, for

00S 88-1-193 and 005 88-1-917 to test the repaired Diesel AFW

pump. 00S 88-1-193 removed the 4 control power fuses. These

fuses were supposed to be replaced pet the Temporary Lift.

When a remote AFW pump start was atten.pted, the pump did not

start. Licensee investigation revealed that 1 of the 4 control

power fuses installed was a "dummy fuse." This apparently had

been installed sometime after the original 00S was hung. When

the 005 was temporarily lifted, the person who verified that

the fuses were installed, failed to recognize that the fuse

(which was not in the 00$ position) was a "dummy fuse."

Procedure BwAP 330-1, Section C.6.c., required that all equipment

listed on a Temporary Lif t be removed from its 00S position.

The failure to remove the "dummy fuse" and restore the fuse was

an example of a Violation (457/88007-020(DRS)) of 10 CFR Part 50,

Appendix B, Criterion V requirements for following procedures.

(6) 005 88-2-386 dated February 7, 1988, required the Unit 2 Boric

Acid Transfer Pump (BATP) recirculation, suction, and discharge

valves be closed to permit pump maintenance. This 005 was

deficient in that it did not establish a recirculation flowpath

for the common BATP which served as a backup for the Unit 2 pump.

The following events occurred between the time the recirculation

valve was closed on February 7, 1988, to when it was discovered

closed on February 18, 1988.

(L) When the Unit 2 BATP was run on February 16th and again on

February 18th to recirculate the storage tank, there was no

flowpath. On February 18th, the pump was discovered to be

inoperable (steam bound).

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(b) The normal and emergency boration flow paths from the

Boric Acid Storage Tank were inoperable when required on

February 18th.

(c) The miniflow recirculation line became clogged with boric

acid due to stagnant flow conditions.

(d) The Unit 2- BATP experienced mechanical seal failure on

February 17th, which could have been due, in.part, to the

recirculation flowpath being plugged and the resultant

lack of recirculation flow.

The failure of the licensee's 00S program to ensure the common

BATP nad a recirculation flowpath when the Unit 2 BATP was taken

005 for repair was an example of a Violation (457/88007-02E(DRS))

of 10 CFR Part 50, Appendix B, Criterion V requirements for

appropriate procedures.

The above implerrentation and program deficiencies were

discussed with the licensee during an interim exit meeting

on February 19, 1988. The licensee acknowledged and was

responsive to the ORI team findings. The licensee discussed

immediate action, taken and planned, to improve equipment

00S controls.

On March 7, 1988, a reinspection of the licensee's equipment

control program, procedures, and equipment was performed to

assess the overall effectiveness of corrective action in this

matter. The inspection included the review of changes to plant

procedure BwAP-330-1 (Equipment Out of Service); a sampling of

four equipment 005 packages, a complete review of all active

Temporary Lift packages, and tracking reports for Degraded

Equipment and Limiting Conditions for Operation Action Report

(LOCAR). In addition, a field inspection was porformed to

verify that plant valves and electrical controls were correctly

positioned as documented in the three safety-related Temporary

Lift packages in effect at the time of the inspection.

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Revision 6, dated February 26, 1988, of procedure BwAP-330-1

l required double verification of breaker and valve position when

placing a system out of service and when restoring a system to

service. The procedure and Temporary Lift record sheets provide

for "as left" positions of components in test.

The 00S and Temporary Lift packages reviewed contained

appropriate authorization. After identification of the

instances of the licensee's failure to have the correct level

of authorization on a number of 005 Temporary Lif ts and th<s

failure to comply with instructions written on the 005 Temporary

Lifts, the licensee took immediate corrective actions. This

included con * acting each of the Shift Engineers and reinforcing

their responsibility with regard to the 00S program.

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There had been a significant reduction in the number of active

Temporary Lift packages; e.g. Unit I was reduced to two (from

a previous level in excess of 100) and Unit 2 reduced to one

(from a previous level of 11). There was one package for a

system common to both units. The licensee's actions to improve i

equipment control appeared to be effective. No deficiencies  ;

were identified during reinspection in this area. l

1. Effectiveness of plant tours - Inspectors accompanied non-licensed J

operators on their rounds to assess their performance and knowledge

of plant conditions. The non-licensed operators were knowledgeable

and effective in their areas of responsibility. A variety of

functions were observed, such as startup of various equipment. These

functions were well executed. In general the quality of plant

walkthroughs was good,

m. Procedure implementation and independent verification - The

implementation of portions of the following procedures were

witnessed in the control room and/or Shif t Engineer's office.

Bw0P-MS-5 MSIV Accumulator Operability Check

Bw0P-CD/CB Condensate / Condensate Booster System

Checkout

BwSU-IC-70 Incore Flux Mapping System Checkout

BwlP 2504-003 Source Range Hi Flux at Shutdown Alarm

Calibration

Bw0P Wx-500-1.T.1 Liquid Release When Flowmeters are

Inoperable

Bw0P-199 Equipment Attendant Auxiliary Building

Logs

Bw0S 4.6.2.1.d-1 Reactor Coolant System Water Balance

BwAP 100-7 Overtime Guidelines for Personnel that

Perform Safety Related Functions

Procedure implementation and compliance by operations personnel

appeared good. Independent verification was performed

satisfactorily when required,

n. Technical Specification LC0's - The inspector reviewed the

documentation for all of the Technical Specification Limiting

Conditions for Operation which were in effect. The Limiting

Condition for Operation Action Requirements (LOCAR) documents were

reviewed to verify that required signatures, notifications, and

compensatory surveillances had been completed. The inspector

identified two discrepancies in the completion of LOCAR paperwork.

Licensed Senior Reactor Operator (SRO) reviews of compensatory

actions performed by the radiation / chemistry department were not

performed. LOCAR Bw05 3.3.9-la required that with radiation monitor

ORE-PR010 inoperable, liquid releases could continue by monitoring

with grab samples and completing the log in Appendix A, data sheet 1.

The radiation / chemistry department had completed its portion of data

sheet 1, for the liquid effluent releases which had occurred since

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the monitor became inoperable on January 27, 1987; however, no SR0

review of these actions was indicated on the data sheet. Similar

problems existed with LOCAR 18w05 3.3.10-la, data sheet 1, for oxygen

analyzer 0AT-GW004. The review did not identify any instances where

required compensatory actions had not been performed, only that the

SRO reviews had not been completed. However, the ORI considers that

the inconsistent supervisory review, by licensed SR0's, of the

adequacy and timeliness of compensatory actions taken in accordance

with Technical Specification action statements was a programmatic

weakness that should be addressed by the licensee.

Two violations were identified in this functional area

(paragraphs 3.j. and 3.k.). No deviations were identified.

4. Surveillance and Testing Observation (72302)

Station surveillance activities of the safety-related systems and

components listed below were observed / reviewed to ascertain that they

were conducted in accordance with approved procedures and in conformance

with Technical Specifications.

The following items were considered during this review: the limiting

conditions for operation were met while affected components or systems

were removed from and restored to service; approvals were obtained prior

to initiating the testing; testing was accomplished in accordance with

approved procedures; test instrumentation was within its calibration

interval; testing was accomplished by qualified personnel; test results

conformed with Technical Specification and procedural requirements and

were reviewed by personnel other than the individual directing the test;

and any deficiencies identified during the testing were properly

documented, reviewed, and resolved by appropriate management personnel.

The inspection focused on the following areas:

• Preparation; including adequacy of procedures, equipment,

pre-task briefings and task knowledge.

• Performance discipline; including supervision and control, procedure

adherence, and communications.

• Documentation and resolution of deficiencies.

• Independent verification and review.

The following surveillance testing activities were observed / reviewed:

Procedure No, Activity

Bw05 - 0.1, 2, 3 Daily Operating Surveillance.

Bwls - 3.1.1 - 303 AT/Tavg Analog Operational Test and Channel

Verification Calibration.

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BwIS - 3.3.6 - 205 Calibration of Reactor Vessel Level Indication

System RVLIS.

BwIS - 3.1.1 - 388 Pressurizer Pressure Protection Analog

Operational (P0-456).

Bw0S - 3.1.1 - 36.1 Intermediate Range NI Surveillance.

The inspectors determined that the licensee had implemented, appropriately

reviewed and approved procedures for the surveillance and testing

activities. Special test equipment functioned well and instruments were

in current calibration. Personnel involved in supervision and performance

of the tasks appeared well trained / knowledgeable of task objectives and

equipment operation. Procedure review and pre-task briefings were

routinely performed. The surveillance ano test procedures were generally

well written, containing appropriate precautions and notes.

The inspectors determined that control room supervision and operators

maintained adequate control over the surveillance and test activities.

Personnel performing the tasks demonstrated a high degree of performance

discipline and procedures were followed in a step-by-step method.

No violations or deviations were identified.

5. Maintenance (62700,62703)

The inspectors reviewed selected maintenance activities to assess the

capabilities of the licensee's maintenance staff to maintain Unit 2

in an acceptable manner. The areas assessed included:

• Maintenance backlog

• Maintenance testing

• Completed Nuclear Work Requests (NWRs)

• Staffing of the maintenance organization

• Threshold for initiating NWRs

• Preventive maintenance

• Material condition

a. With respect to backlog, the licensee reported corrective maintenance

backlog in the Braidwood Monthly Plant Status Report as those Nuclear

Work Requests (NWRs) outstanding, which were ready for work (outage

not required). The inspector determined through discussion with the

licensee that there were also Construction Work Requests (CWRs)

outstanding pertaining to corrective maintenance. These CWRs were

not being identified as backlog corrective maintenance in the

Braidwood Monthly Plant Status Report. The licensee did not furnish

the number of corrective maintenance CWRs outstanding; however, the

inspector did ascertain that the backlog of corrective maintenance

documented on NWRs was 920. These 920 NWRs were assigned ts follows:

175 - Unit 1

394 - Unit 2

351 - Unit 0

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The Preventive Maintenance (PM) backlog reported in the licensee's

Monthly Plant Status Report represented only those PMs pertaining to

the Technical Specifications. Other backlog PMs, such as lubricatic-

and the calibration of plant instruments, were not reported in the

backlog population. During this inspection the licensee furnished

the inspector with the PM backlog for these non-Technical

Specification PMs. The PM backlog was as follows:

Instrument Calibration - 23 B0P past their critical due date.

Electrical Component inspection - 26 breakers or Motor Control

Centers.

Lubrication - 21 pieces of equipment past due.

The licensee had committed to furnish revised backlog information,

which would included those CWRs pertaining to corrective maintenance

and PMs, prior to the Unit 2 full power Commission meeting,

b. The inspectors witnessed a maintenance test of the 18 Auxiliary

Feedwater (AFW) pump. The diesel driven IB AFW pump failed to

start during this test. Investigation by the licensee determined

that fuses in the 18 AFW local control panel were not re-installed

during the Temporary Left of the Out-of-Service. This event is

further discussed in Paragraph 3 k.5 of this report.

c. The inspectors reviewed twenty completed NWRs which were located in

the Central Files. The packages reviewed were: A11892, A11896,

A17102, A13004, A17244, A18764, A11903, A17185, A05524, A10717,

A17831, A17403, A19406, A17115, A16174, A12101, A12082, A18584,

A17116, and A12229. Final review of these packages had been

performed by maintenance, QA and QC. The appropriate review

signature was noted and the documentation associated with each

package appeared adequate. No significant problems were noted

involving plant hardware.

d. The inspectors reviewed the maintenance organization charts furnished

by the licensee. The staffing levels apper. red adequate to perform

required maintenance activities. The maintenance department was

divided into three disciplines: electrical, mechanical and

instrumentation. Each discipline was headed by a supervisor. The

planning of maintenance activities was performed by the Station

Startup/ Work Planning organization. This organization had work

planners for continuous work and outage work planners for the

planning of outage activities.

e. The licensee threshold for placing equipment problems on NWRs was

evaluated for adequacy. The inspector reviewed the control room

logs for Unit 1 and Unit 2 and selected three Unit 1 log entries

and seven Unit 2 log entries which fndicated potential equipment

problems. In each case, the licensee had initiated an NWR to

resolve the problem or had addressed the problem in an acceptable

manner. Therefore, the licensee's threshold for placing equipment

problems on NWRs appeared to be adequate to maintain the material

condit'on of the plant.

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f. The inspectors reviewed the licensee's preventive maintenance (PM)

program. The PM program consisted of various activities such as:

iubrications, vibrations analysis, instrument calibration, heat

exchanger nondestructive testing, etc. These activities were

controlled by various computer programs which currently do not

interface with each other. As a result, the inspector required

significant plant staff assistance in assessing the PM backlog.

The licensee stated action had already been initiated to allow

easier retrievability by computer of the status of PMs.

During the plant walkdown by the inspectors, the lower motor bearing

sightglass for both the 2A and 28 Residual Heat Removal (RHR) pump

motors had oil which appeared to need changing. A review of the

computer printout for lubrications indicated that the initial entry

for the RHR pump motors was January 4,1988, with a due date of

January 4, 1989 (12 month frequency). A review of construction

records determined that both the 2A and 2B RHR pumps had been run

since April 1987 at various times during Unit 2 preoperational

testing. Therefore, it appears that the due date of January 4,1989,

was established based on the initial entry of the RHR pump motors

into the lubrication program and not based on a technical assessment.

It appears that the due date would more appropriately have been

April 1988, based on the run history of the RHR pumps. The issue

of scheduling of the lubrication of equipment / components is considered

an open item pending further NRC review (453/88007-03(DRS)).

g. The inspectors performed a walkdown of portions of Unit 2 to

evaluate the material condition of the plant. With the exception

of several minor instances, the inspectors did not identify any

equipment problems that had not already been identified by the

licensee. However, the inspectors did identify two cases were

maintenance activities resulted in the following:

• A debris screen from the 28 diesel AFW pump fan intake had been

removed and stored against an instrument rack in the 28 AFW pump

room. This action could have potentially resulted in damage to

the installed instrumentation and inadvertent mispositioning of

an instrument valve. Since Unit 2 was in Mode 3 the 2B AFW

pump was required to be operable. The licensee took immediate

corrective action to properly store the debris screen.

• The 2A motor driven AFW pump had various materials, such as

coats, extension cords, and tools, laying on the motor. At

' the same time there were maintenance activities being performed

in the adjacent 1A AFW pump area. The 2A AFW pump was required

to be operational. The licensee took immediate corrective

action to remove this material.

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In summary, the inspectors concluded that the licensee's maintenance

activities were performed adequately to support a Unit 2 full power

1; cense. However, the licensee needed to improve on their statusing

of maintenance backlog. Also, the licensee should increase the

awareness of their equipment operators on the need to ensure

maintenance activities do not affect the operability of equipment

in areas where maintenance is being performed.

One open item was identified in this functional area (paragraph 5 f).

No violations or deviations were identified.

6. Radiation Protection (83722, 83724, 83725, 83726, 83728)

The inspector met with various members of the radiation chemistry

(Rad / Chem) staff, including: the Rad / Chem Supervisor, the lead Health

Physics Foreman, a staff Health Physicist (HP), and various Rad / Chem

technicians (RCTs).

A number of licensee strengths within this functional area were identified

during the inspection, including:

• RCTs appeared to be knowledgeable of plant systems and procedures,

and of their responsibilities.

• In order to support the simultaneous startup and startup testing of

Unit 1 and Unit 2, the licensee has contracted for the services of

32 RCTs in addition to their normal staff.

• No significant Radiation Occurrence Reports (R0'S) were generated

for 1987 or January of 1988.

The inspector witnessed the changing of the reactor coolant filter for

Unit 1. The reactor coolant filter had a contact reading of 300 Rad /hr.

Prior to the filter change several work group discussions were conducted

and an ALARA planning meeting was held. The inspector observed that the

exchange of information during the course of these meetings appeared good.

The changing of the reactor coolant filter was completed without problem.

The ORI conducted in June 1987 for Unit 1 made three observations in this

functional area. The inspector reviewed the licensee's actions for these

three observations.

• Audible speakers on GM survey meters used at the 401' Auxiliary

Building to Turbine Building door and the 426' Containment entryway

could not be heard by the surveyors because the background noise level

was too high. During this inspection the inspector verified that the

licensee had purchased kits for the installation of earphones on

several GM survey meters. At the time of this ORI the installation

of these earphones was in process.

• Rad / Chem surveys of the laundry room were done with a "Cutie Pie"

(a relatively high range instrument). During the inspection the

inspector verified that the licensee was now using GM survey meters

(a lower range instrument than the "Cutie Pie") for performing

surveys of the laundry room.

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• RCT workhours exceeded the guidelines of NRC Generic Letter 82-12

which limit the working hours of Unit Staff who perform safety-related

functions. The inspector reviewed records of hours worked by RCTs

for the period of January 19 throagh February 1,1988, and found the

situation continuing; 15 RCTs (almost half of the total member of

licensee RCTs) appeared to have worked hours in excess of those

specified in Generic Letter 82-12. This finding was consistent with

the previous ORI's finding. The licensee's position is that only the

one Duty RCT required as part of the Technical Specification for

minimum shift manning was required to comply with the Generic

Letter 82-12 working-hour limitation. This position does not appear

to meet the intent of Technical Specification 6.2.2.e. in that the

Generic Letter 82-12 working-hour restrictions are clearly applicable

to "the unit staff whc perform safety - related functions," not merely

the minimum shift manning. An additional question is raised, however,

in that the Generic Letter 82-12 restrictions appear to apply only

to unit staff who perform safety-related functions, a distinction

which may exempt certain RCTs. This matter has been submitted to

NRR for clarification; further action to resolve this matter will be

held in abeyance pending that clarification. This issue is considered

to be an unresolved item (453/88007-04(DRS)).

One unresolved item was identified (paragraph 6). No violations or

deviations were identified.

7. Station Chemistry (79501)

The inspector met with the Station Chemist and conducted a tour of the

Chemistry Laboratory f acilities. General housekeeping was excellent and

all equipment was operational. RWP 88001 covers activities in the hot

laboratory and counting room. Step off pads and friskers were located

at the entrances. Lines of responsibility are defined and no interface /

communication problems between Chemistry and other departments were

identified. The Rad / Chem Supervisor attends the Plan of the Day (P00)

reeting, and in his absence, either the Station Health Physicist or

the Station Chemist attends. A Chemist attends each shift briefing.

Both the primary and secondary chemistry were within specifications during

this inspection. The chemistry departnent implemented a monthly chemistry

report which was submitted to the assistant Superintendent, Operations.

The inspector reviewed the December 1988 monthly chemistry report, which

included Unit 2 chemistry and found the following:

• Primary

During the month of December, the Unit 2 reactor coolant system was

borated to 32000 ppm boron for fuel load. The RCS core load chemistry

test, PS-70, was performed successfully to ensure the RC, RH, CV, SI,

CS, AB, and FC systems contained the proper concentration of boron to

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support fuel load. For December, the RCS boron and chloride average

concentrations were 2073 ppm and 20 ppb, respectively. There was no

detectable fluoride concentration for the RCS during December. The

28 CV mixedo' ed demineralizer was borated to 2000 ppm boron while

the 2A demineralizer ramained unborated. Lithium hydroxide was

added and increased the RCS pH from 5.1 to 5.95 in order to reduce

the rate of corrosion.

• Secondary

The Unit 2 steam generators were placed in dry lay up in December.

The main condenser was accidentally filled to 15 feet with CST water.

The water specific conductivity was 22 umhos/cm. Two-thirds of the

water was drained to the wastewater treatment system and the final

third was being cleaned up via a temporary demineralizer (Ecolochem)

and will be utilized to fill, vent and flush the condensate and

feedwater systems. Once the system flushes are completed and the

water is verified to meet initial condensate specifications, the

temporary demineralizers will be removed from service and hydrazine

and ammonium hydroxide will be added for lay up chemistry.

Region III has one open item regarding operability of the secondary

sampling panel for Unit 2. The inspector verified the operation of

the sampling panel with a chemistry engineering assistant, No problems

were noted. This item will be closed in the resident inspectors monthly

report (456/88008; 457/88009).

No violations or deviations were identified.

8. Nuclear Engineers Activities (71707, 72302)

The performance of startup test procedure BwSU IT-73, "Incore Thermocouple

(Core Exit Thermocouple (CET))," Revision 0, Section 9.4. was witnessed.

The inspector determined that the Nuclear Engineers who were directing

the test were knowledgeable of testing in progress and that their interface

with the operations staff was good. Activities appeared well-controlled.

Special test equipment functioned well and instruments were in current

calibration. Personnel involved in supervision and performance of the

test appeared well trained / knowledgeable of test objectives and equipment

operation. Personnel performing the test demonstrated a high degree of

performance discipline and the procedures were followed in a step-by-step

method. Communications involving approval, instruction, and status were

conducted in a business-like manner, ,

No violations or deviation were identified.

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9. Training (41400)

The effectiveness of training programs for licensed and non-licensed

personnel was observed by the inspectors during the witnessing of the

licensee's performance of routine surveillance, maintenance, and

operational activities. Except for weaknesses in the implementation

of the Out of Service program identified in the section on operations,

the station staff performed in a highly trained and motivated fashion.

Licensed and non-licensed operators were knowledgeable of the plant

equipment. Mechanical, electrical, and instrumentation and control

technicians were observed at their tasks and performed their duties with

skill. In other departments, employees also performed in such a way as

to demonstrate effective training programs.

No violations or deviations were identified.

10. Exit Interview (30703)

The ORI met with the licensee representatives denoted in Paragraph 1

during the inspection and again on February 19, 1988. The ORI summarized

the scope and findings of the inspection activities and highlighted the

need for management attention in the areas discussed in the previous

paragraphs. The ORI further noted that primarily because of the problem

observed with 005's and Temporary Lifts, and the fact that the operations

staff did not feel confident of plant status as a result of the current

system in these areas, that a recommendation for a full power license could

not be made at that time. The licensee acknowledged the inspection findings

and stated that programmatic changes in the area of 005's and Temporary

Lifts were already being planned and would be implemented in the relatively

near future.

Members of the ORI again met with the licensee representatives denoted

in Paragraph 1 at the conclusion of the inspection on March 7, 1988.

The ORI summsrized the findings of the inspection activities since the

previous meeting on February 19, 1988. The ORI noted that the licensee

had been very responsive in taking action to correct the previously

identified issues in the 005 area. As a result, the opcrations staff

was no longer burdened with an excessive workload in the 00S area and

that they now felt confident about their knowledge of plant status. As a

result of the above changes, the ORI indicated that they would recommend

to the region the issuance of a full power license.

The inspectors also discussed the likely informational content of the

inspection report with regard to documents or processes reviewed by the

inspectors during the inspection. The licensee did not identify any such

documents / process as proprietary.

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