IR 05000456/1997009

Insp Repts 50-456/97-09 & 50-457/97-09 on 970520-0630. Violations Noted.Major Areas Inspected:Licensee Operations, Engineering,Maint & Plant Support

ML20216D504
Person / Time
Site:	Braidwood
Issue date:	08/26/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20216D383	List: IR 05000456/1997009 ML20216D376 ML20216D475
References
50-456-97-09, 50-456-97-9, 50-457-97-09, 50-457-97-9, NUDOCS 9709090339
Download: ML20216D504 (30)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lli  !

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I Docket Nos: 50 456, 50 457 License Nos: NPF 72, NPF 77 i

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Report No: 50 456/97009; 50 457/97009 Licensee: Commonwealth Edison (Comed)

Facility: Braidwood Nuclear Plant, Units 1 and 2 Location: RR #1, Box 84 Braceville,IL 60407 Dates: May 20 through June 30,1997

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Inspectors: C. Phillips, Senior Resident inspector

- J. Adams, Resident inspector T. Esper, Illinois Department of Nuclear Safety Approved by: R. D. Lanksbury, Chief, Projects Branch 3 Division of Reactor Projects

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9709090339 970826 PDR ADOCK 05000456 g PDR ,_

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EXECUTIVE SUMMARY Braidwood Nuclear Plant, Units 1 & 2 NRC inspection Report 50 456/97009; 50-457/97009 This inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers a 6 week period of resident inspectio DoeratIDna

• The inspectors concluded, based on the documented observations in three inspection report periods, that during the most recent Unit 1 refueling outage (A1R06) operations personnel demonstrated excellent cornmand and control, communications, and safety focus. Of particular note waa the augmentation of the control room staff by two additional senior reactor operators (SROs). This was considered a strength and contributed to improved supervision of outage evolution (Section 01.1)

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The preparation for and the execution of the reactor startup from A1R06 was good and demonstrated an excellent safety focus and strong control room teamwor Communications in the control room observed during the startup were excellen (Section 01.2)

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On June 9, operators drained about 1900 gallons of water onto the floor of the boric acid storage tank (BAST) room. The water spilled through a failed flood seal onto the Unit 2B diesel driven auxiliary feedwater pump making it inoperable. The inspectors concluded that the performance of operations department personnelin attempting to drain the Unit 1 BAST without understanding the correct way to drain the system was weak. Good practices such as ensuring the drain line was clear and verifying proper drain flow were not obsarvod. Procedures to properly drain portions of the centrifugal charging (CV) system were improperly maintained resulting in a violation. (Section 01.3)

- Inspection Report 97005, Section 04.1, discussed the inspectors conclusion that control room operator panel attentiveness was weak. Operations management issued Special Operating Order S0-ST-0081 to address this issue. Based on several observations in April, May, and June of 1997, the inspectors concluded that licensee management was effective in improving control board panel attentivenes (Section 04.1)

- The inspectors observed a field supervisor and several equipment operators complete assigned tasks. The field supervisor provided the appropriate level of guidance and supervision and clearly communicated instructions to equipment operators. The equipment operators used approved procedures, used three way communications, performed self-checks, asked good questions, and expressed valid concerns. (Section 04.2)

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Maintenance

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The licensee's safety focus during refueling outage A1R06 was good as demonstrated by the outage plan from a shutdown risk perspective, the pre-job preparation and execution for work on the 1C reactor coolant system cold leg st0p valve 1RC8002C, and the preparation for and execution of fuel movement The licensee made significant progress in some areas. There were reductions in the powerblock nen outage corrective maintenance backlog and open operability evaluations durir.? the refueling outage. However, the execution of some significant maim.inance and ter, ting activities during the refueling out2ae was wea Although the maintenance on the 1 A diesel generator was performed well, during work on the 1B diesel generator, the inspectors identified two problems with foreign material excusion control and the licensee identified that the jacket water system was over pressurized. The inspectors also identified problems with test control during the performance of the safety injection and charging system check valve surveillance test. (Section M1.1)

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The licensee's post eve.it response to the Unit 1 BAST spill, such as identifying the scope of the prob l ems, identifying the work to be performed, and identifying required testing to verify operability, was well organized, timely, and demonstrated a good safety focus. However, the intpectors concluded that implementation of the fire protection program requirements to inspect plant fire seals was weak as evidenced by licensee identification that the fire seals between the BAST and the Unit 2 diesel driven auxiliary feed water pump were not in the data base of fire l seals to be inspected. The failure to properly maintain the CV system draining 1 procedure was considered a violation of Technical Specification 6. (Sections M1.2 and M1.3)

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The inspectors concludod that the licensee failed to perform an adequate historical review of post accident neutron monitor (PANM) performance during the 3 years prior to July 10,1996, that the performance of the PANM had not been effectively controlled through the performance of appropriate preventive maintenance, and that the Maintenance Rule was not correctly implemented for the PANM. These failures resulted in the licensee's improper categorization of the PANM as falling under 10 CFR 50.65(a)(2), the failure to establish appropriate goals per 10 CFR 50.65(a)(1), the failure to establish a corrective action program, and the failure to monitor PANM performance against appropriate goals. A Notice of Violation was issued for these failures. (Section M2.1)

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On May 22, during a review of TS surveillance requirements to vent the emergency core cooling systems (ECCS) pump casings and discharge pioing high points outside of containment, the inspectors identified that TS 4.5.2.b.1 had not been performed as required, in fact, the Unit 1 and 2 chemical and volume control CV (an ECCS subsystem) pump casings, and the CV high point vents had never been vented during Modes 1,2, and 3; a time period that exceeded the TS limit of venting at least once per 31 days. This was considered an apparent violation of TS 4.5.2. Of part:cular concem was the fact that the licensee identified in February 1996 that

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I the subject piping was not being vented in strict compliance with the TS and did not seek a TS change. (Section M3.1)

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Surveillance tests observed during this inspection period were performed in accordance with procedures and all acceptance criteria were met. Associated procedures were well written and ensured that TS and Updated Final Safety Analysis Report (UFSAR) requirements were met. (Section M4.1)

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Maintenance observed this period was performed in a safe manner using properly prepared work packages. Procedures, drawings, and out-of service boundaries were appropriate for the scope of the work. Personnel performing the maintenance observed safety precautions, followed procedures, and performed self-check (Sections M4.2 and E2.1)

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On October 4,1996, the licensee identified that the instrumont vent and drain valv6r. for pressure indicators 1(2)PI 929 were missing from surveillance test procedure 1(2)BwOS 6.1.1.a 1, " Unit One (Two) Primary Containment integrity Verification of Isolation Devices Outside Containment," Revision 7E2 and commenced a review to determine what the surveillance requirements were on the l valves in question. The licensee concluded that these valves were not subject to TS surveillance requirement 4.6.1.1.a. The inspectors referred this issue to the Office of Nuclear Ruactor Regulation's (NRR) Technical Specifications Branch for review. Based on the results of the NRR review, the inspectors concluded that the subject valves should have been tested per TS 4.6.1.1.a and a Notice of Violation was issued. (Section M8.1)

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System engineering performed a prompt operability evaluation for the 18,2A, and 2B charging pumps following the discovery of sealleakage in excess UFSAR assumed rates. Engineering support for corrective efforts was goo (Section E2.1)

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The inspectors reviewed five recent operability determinations and concluded that they were performed in a timely manner, were appropriately based on engineering analysis, were clear and logically presented, and were properly documente (Section E3.1)

Plant Suonort

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.The inspectors identified evidence of a poor radiation worker practice in the auxiliary building. Cigarette butts found in the auxiliary building ventilation system inlet plenum indicated that plant personnel smoked cigarettes in the radiologically controlled area at some time in the past. (Section R1.1)

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__ The radiation protection (RP) zone coverage technician provided good support for -

plant personnel performing a seal adjustment to the 2B charging pum (Section R4.1)

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Licensee performance in the Technical Support Center (TSC) during an emergency planning drill on June 11 was good. involved TSC staff were knowledgeable of their responsibilities and TSC staff conduct was professional during the drill and the critique session that followed. (Section PS.1)

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Report Details Summarv of Plant Status Unit 1 entered the period shut down for refueling. The unit was started up on May 25, 1997. Following physics testing, reactor power was gradually increased and full power was achieved on June 5. The unit operated at or near 100% power for the remainder of the perio Unit 2 operated at or near 100% power for the entire perio . Operations 01 Conduct of Operations 01.1 General Comments (71707) Insoection Scoce The inspectors made several observations during the course of the Unit 1 refueling outage (A1R06). Some of those observations were originally documented in Inspection Reports 97005,97007, and others are documented in this report. The purpose of this section was to summarize all of the observations and draw e conclusion regarding the performance of the operations department during the refueling outage.

I Observations and Findinas l The inspectors reviewed operating procedures for plant shutdown, cool-down, and refueling and concluded that the procedures were adequate. (Inspection Report 97005, Section 03.2)

The inspectors observed the preparation for and execution of the shutdown and cooldown of Unit 1. The licensee's preparation for and execution of the Unit 1 shutdown for refueling on March 29,1997, was excellent. Operations staff and management attention to shutdown operations was good Continuous discussion and short briefings prior to the conduct of procedure steps demonstrated good communications and strong team work. Plant systems needed for cooldown were verified by the inspectors to be available and in good working conditio (Inspection Report 97005, Section 01.2)

The inspectors observed good pre-evolution briefings prior to several evolution The briefings met or exceeded procedural requirements and were conducted in a manner that encouraged questions and participation. (Inspection Report 97005, Section 01.3)

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The inspectors observed good control room turnovers by both nucleer s'ation operators and unit supervisors. (Inspection Report 97005, Section A.i)

The inspectors concluded that the licensee's augmentation of the control room staff for the outage unit by the addition of two additional senior reactor operators (SROs)

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improved the supervision of evolutions and demonstrated a strong safety focus on shutdown operations. -The inspectors also observed that the operating staff in the control room demonstrated excellent team work and communications during observed evolutions. (Inspection Report 97007, Section 01.1)

The inspectors were concerned about the close-out inspection of the Unit 1 containment performed by the licensee. Although cleanliness was generally good, the inspectors independent close-out inspection identified a 2 foot long by 5 inch diameter metal cylinder laying on the floor. Debris was also found in floor drains that communicated with a technical specification leakage detection system. The inspectors were also concerned that standing water in the floor drain was not questioned by licensee personnel during their inspection. (Inspection Report 97007, Section 01.2)

The inspectors observed the preparation for and execution of the reactor startup l

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from refueling outage A1R06. The licentre's performance was good and demonstrated an excellent safety focus and strong control room teamwork.

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Communications in the control room during the start up were excellent. (Inspection Report 97007, Section 01.2) Conclusions The inspectors concluded that during the most'recent Unit 1 refueling outage A1R06 operations personnel demonstrated excellent command and control, communications, and safety focus. The augmentation of the control room staff by the addition of two SROs was considered a strength and contributed to improved

. supervision of outage evolution .2. Unit 1 Startuo From Refuelino Outaae A1R06 inspection Scoce (71707)

The inspectors reviewed licensee procedures 1BwGP 100 2, " Plant Startup,"

Revision 8E2 and BwVS 500-4, " Initial Criticality After Refueling and Nuclear Heating Level," Revision 11E1. The inspectors observed portions of the pre-evolution briefings and portions of the reactor startup on May 24 and 2 Observations and Findinos The inspectors concluded that the procedures used were adequate but in some instances unclear. For example, BwVS 500-4, Step 8, stated, " REQUEST that Operations NOTIFY Rad Protection to perform Vent Stack Sampling per Offsite Dose Calculation Manual (ODCM) RETS Table 12.4.1, Notation 3, prior to Mode 2."

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I The inspectors questioned a senior reactor operator (SRO) in the control room about whether the radiological protection department just had to be notified prior to Mode 2 or were actual sample results required. The SRO was unsure and had to review the ODCM to verify that radiological protection personnel only needed to be notifie The inspectors' observed the pre evolution briefing conducted on May 24. 'The briefing had the appropriate personnel present and the personnel conducting the briefing correctly addressed the sequence of events, assigned specific responsibilities for actions, and discussed contingency actions should the reactor appear to reach criticality at an unexpected point. The inspectors were informed that the operators on shift had ' attended a walk through of the startup on the simulator within a few days of the actual startu During the plant startup on May 24, rod control bank C stopped moving about 10 steps prior to that expected for a continuous rod pull. The operators stopped pulling control rods, held a shift briefing /and decided to open the reactor trip

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breakers and enter emergency procedure 1BwEP-0, " Reactor Trip or Safety injection," Revision 1 A. This was performed without further incident. The licensee subsequently identified the problem with rod control bank C as a stuck contact in the rod control overlap counter circuit. The contact was repaired and the reactor startup recommenced on May 2 .i The inspectors observed that while control room staffing exceeded minimum requirements the control room was not crowded. Control room staffing was augmented with one SRO assigned to handle all administrative matters and a second SRO at the reactor control panel directly supervising reactivity change There were also three nuclear engineers present. The inspectors observed that the reactor operators, the SROs, and the nuclear engineers, communicated often with each other and frequently referred to procedures. Short briefings were held in the ,

control room between significant procedure step I Conclusions The preparation for and the execution of the reactor startup from A1R06 was good and demonstrated an excellent safety focus and strong control room teamwor Communications in the control room among operators and between the operators -

and nuclear engineers were excellen .3 Drainina Unit 1 Boric Acid Storaae Tank (BAST) Results in Solil Of 1900 Gallons Insoection Scone (71707)

The i'nspectors leamed during a routine inspection of the control room that a large amount of water had been spilled onto the floor of the BAST room. The inspectors

- walked down affected areas of the auxiliary building; reviewed drawings M82 Sheet 9 and M65 Sheet 5B, interviewed operators and system engineers; and reviewed licensee procedures, BwOP CV-24, " Draining The CV System," - - -

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Revision OE1; BwAP 340-9, " Venting and Draining of Components and Systems,"

Revision 0; and BwAP 330-1, " Station Equipment Out Of Service Procedure,"

Revision 2 Observations and Findinas On June 9, after the inspectors learned of a spill in the BAST room, they inspected the area and noted that there were about 4 to 6 inches of water on the BAST room floor. The licensee estimated this to amount to about 1900 gallons of water. The inspectors also noted that the exhausts for both the Unit 1 and Unit 2 diesel driven auxiliary feed water pumps were routed through the Unit 2 diesel driven auxiliary feedwater pump room and then up through the floor of the BAST room. The water in the BAST room was leaking through the Unit 1 diesel driven auxiliary feedwater pump exhaust pipe flood sealinto the Unit 2 diesel driven auxiliary feedwater pump room and onto the diesel engine. The water had also leaked into cable trays, into common areas around the Unit 1 and 2 electrical auxiliarv feedwater pumps, and a small amount had leaked into the Unit 1 diesel driven aux:liary feedwater pump roor.: and onto the floo The licensee declared the Unit 2 diesel driven auxiliary feedwater pump inoperable based on the large amount of water that spilled directly onto the diesel. The inspectors observed that the Unit 1 diesel driven auxiliary feedwater pump and the Unit 1 and 2 electrical driven pumps appeared to be unaffected by the water and that the licenses ran the pumps and documented formal operability evaluations even

though no obvious problems existed.

l The inspectors interviewed the operations field supervisor that was on duty at the time the spill occurred. Operations personnel were draining the Unit 1 BAST in preparation for maintenance work on a leaking manway cover and an out-of-service (OOS) had been hung to support this maintenance. The BAST drain valve (1 AB8488) had an information OOS card hung on it that allowed the valve to be manipulated for draining. The OOS included drawing M65 Sheet 5B which was drawn such that the drain line directed the reader to another drawing (M82 Sheet 9) and included the words " Aux. Building Equipment Drain System."

However, drawing M82 Sheet 9, which was not attached to the OOS, clearly showed that the drain line went to a 1 cubic foot sump in the floor which had no drain connection. The drawing included the words "For Portable Sump Pump." Tho actual configuration was that the BAST drained to a small sump which should have been pumped down with a portable sump pum The inspectors verified that there was neither an established written procedure specifically for the draining of the BASTS nor written instructions in the OOS to drain the tank. There was a procedure (BwOP CV-24) for draining non-specific portions of the CV system BwOP CV-24. However, it consisted of six steps which said, in part, to isolate the section of the system with an OOS, contact radwaste, and open the drain and vent valves. Operations personnel followed this procedur The licensee also had a general procedure, BwAP 340-9, for draining components and systems without specific procedural guidance. Although this procedure did not

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specifically apply, had the licensee followed the general guidance of checking that the drain line was clear, both before and after the start of draining, the event would not have occurre The inspectors interviewed the unit supervisor that conducted Ahe pre job brief for the evolution who stated the following:

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a procedure for draining the BAST was looked for but not found;

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BwOP CV-24 was not reviewed or discussed at the pre-job brief;

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she was unaware of the existence of BwAP 340 9; and

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after the start of the draining the operator in the field told her he could not check drain flow because it was (he believed) hard piped to the equipment drain system.

i-l The inspectors interviewed the radwaste supervisor on shift at the time of the spill. -

The radwaste supervisor stated that he was made aware of the draining of the water and was told to expect about 500 to 1500 gallons to go to the equipment drain system. The radwaste supervisor also stated he was in the radwaste control room shortly after the draining evolution began and observed an increase in the equipment drain tank and thought that this was the input from the Unit 1 BAS Technical Specifications 6.8.1 states in part that procedures shall be established, implemented, and maintained covering the activities referenced in Appendix A, of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33,

' Appendix A, Section 3.n discussed the need for instructions to drain the CV system. Since the BASTS were part of the CV system and a submersible sump pump was necessary to drain the pit in the BAST room to the equipment drain system the inspectors concluded that the draining procedure 'or the CV system,

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BWOP CV 24, was improperly maintained and was in violation of TS 6. '

(50-456/97009-01(DRP)). Recovery from this event is addressed in Section M Conclusions The inspectors concluded that the performance of operations department personnel attempting to drain the Unit 1 BAST without understanding the correct way to drain the system was weak. Procedures to properly drain portions of the CV system were inadequate. Good practices such as ensuring the drain line was clear and

- verifying proper drain flow were not observed. The failure to properly maintain the CV system draining procedure is a violation of TS 6. . .

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l 04.1 Control Board Attentiveness Insnection Scone (71707)

The inspectors made several routine inspections of the control room during the rnonths of April, May, and June 199 Observations and Findinos inspection Report 97005, Section 04.1, documented several observations of the control room and the inspectors conclusion that control room operator panel attentiveness during late February and early March was weak, in response to this concern the licensee issued Special Operating Order SO-ST-0081 which became effective March 31,1997. The Special Operating Order gave direction regarding management expectations of control board panel awarenes The inspectors have subsequently observed improved control room operator panel attentiveness, including more frequent control panel walkdowns by control room operators. The inspectors have also not observed any equipment deficiencies in the last 3 months that control room operators were not already aware of.

I l Conclusions The inspectors concluded that operations department management was effective in-improving control room operator panel attentivenes .2 Observations of Field Ooerator Performance insoection Scone (71707)

The inspectors observed the field supervisor (FS) and equipment operators (EO)

during the performance of assigned dutie Observations and Findinos On June 13, the inspectors observed an EO support the performance of procedure BwOS 8.1.1.2.a-1, " Unit 2 2A Diesel Generator Operability Monthly Surveillance."

The EO established and tested communications with the control room, reviewed the procedure, verified all of the prerequisites were satisfied, and sequentially performed the steps of BwOP DG-11, " Diesel Generator Startup." The EO monitored the diesel generator's performance by making frequent inspections of the engine and accurately recording engine parameters. The EO used approved procedures and performed self check On June 15, the inspectors observed the FS review plant status by performing a walkdown of control room panels, discussing his observations with licensed operators, and reviewing logs and records, including equipment OOS and temporary

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l alterations. The inspectors also observed two examples where the FS addressed questions and concerns expressed by an E In the first instance, an EO assigned to depressurize a section of auxiliary building service air header became concerned and called the FS when the pressure appeared not to be decreasing after a significant period of venting. The FS reviewed the OOS, verified that the isolation valves were in the closed position, discussed the problem with the unit supervisor, outlined his plan for troubleshooting the problem, and provided troubleshooting instructions to the E In the second instance, an EO assigned to cross-tie the 250V direct current (DC)

systems indicated that he had questions concerning the procedure for performing the cross-tie of the systems. The FS met the EO in a low noise area near the job location, reviewed the procedure with the EO, answered the EO's questions, walked through the procedure with the EO, and directly supervised the performance of the evolution. The inspectors observed that the EO performed a proper self-check, used procedures, used three-way communications, and performed the evolution in accordance with licensee procedures BwOP DC-14, "250V DC Cross-Tie / Restoration," Revision 5 and BwOP DC-12 "250V DC Battery Charger Shutdown," Revision Conclusions The inspectors concluded that the FS performed a thorough assessment of the plant's status and provided the appropriate level of supervision of the EO for the observed evolutions. The FS clearly communicated instructions to the E The inspectors concluded that the EO asked appropriate questions and expressed valid concerns to the FS. The EO correctly performed all actions under the guidance of approved procedures. Three-way communications and self-checking were consistently performe Miscellaneous Operations issues (92700)

08.1 (Closed) Deviation 50-456:457/95015-04 Failure to Meet Commitment: On October 27,1994, in response to Generic Letter 89-13, the licensee committed to continuous injection of sodium hypochlorite into the essential service water (SX)

system for a 5-week period as the cooling lake transitioned through 65 degrees Fahrenheit. On October 12,1995, the licensee lined up the chemical feed system and commenced continuous hypochlorite injection into the SX system utilizing a temporary hypochlorite tank and an air-driven transfer pump. The continuous hypochlorite injection was interrupted on three occasions. The inspectors concluded that licensee personnel failed to maintain an adequate hypochlorite level in the supply tank and failed to maintain the necessary spare parts for the air-driven pump to ensure that the continuous hypochlorination commitment was met, and a Notice of Deviation was issue _ _ _ _ - - _ _ _ _ - - - - _ - -

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The licensee installed, and placed in service, a new blocide system designed with redundant injection pumps, a larger capacity chemical storage tank, and the '

capability to continuously inject year round into the SX system. The inspectors reviewed the licensee's corrective actions for this deviation and concluded that the licensee's response to this deviation was adequate. This deviation is closed, 11. Maintenance M1 Conduct of Maintenance M1.1 Unit 1 Refuelino Outaae Maintenance insoection Scone (62707)

The purpose of this section was to draw a conclusion regarding the observed performance of the maintenance department during refueling outage A1R06. Some of these observations were originally documented in inspection Reports 97005 and 97007, with the remainder and the final summary in this report, b. Observations and Findinos Maintenance training and pre job preparation for work on the Unit 1 "C" reactor coolant system cold leg stop valve,1RC8002C, demonstrated good safety focus and communications between maintenance, engineering, and radiation protection (RP) personnel. (Inspection Report 97005, Section MS.1)

The inspectors reviewed the licensee's outage schedule, shutdown risk analysis, and contingency action plans. The inspectors concluded that the licensee's outage plan and shutdown risk analysis were acceptable. (Inspection Report 97005, Section M1.1) -

The inspectors observed that outage maintenance on the 1 A diesel was goo However, on the 1B diesel, the inspectors observed two examples where foreign material exclusion control was lost and one example where the maximum Jacket water pressure allowed by the procedure was exceeded. (Inspection Report 97007, Section M1.1)

The inspectors observed that the preparation for and performance of fuel movements for refueling outage A1R06 was good. Fuel handlers and supervisors were knowledgeable of procedures, equipment, and of their responsibilitie (Inspection Report 97007, Section M4.1)

The inspectors observed several surveillance tests and concluded that the surveillance tests were properly performed and met the testing requirements of the UFSAR and the TS. However, the inspectors observed that check valve surveillance testing on the safety injection and centrifugal charging systems was poorly controlled by the responsible system engineers. The inspectors observed

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two instances where acceptance criteria were exceeded without the system engineer identifying a problem, and one instance of the system engineer failing to record required data. The inspectors also concluded that there were communication weaknesses between maintenance and engineering that resulted in the use of the wrong instrument range in flow calculations. (Inspection Report 97007, Sections M4.3 and 4.4)

The inspectors reviewed licensee information that indicated that during the refueling outage that the powerblock non-outage corrective maintenance backlog was reduced from about 2250 to about 1400 items. The progress in reducing the

, backlog of work requests is, at least in part, due to better resource management in working off many of the minor items in the backlog.

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The inspectors confirmed that during the refueling outage that the licensee closed 14 open operability assessments that required physical work to restore original

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conditions. Twenty-six were left open. Nine of the operability assessments left open needed some sort of physical work performed that required additional time to complete the design review process or to procure parts in order to close them. The other fifteen required administrative work to be completed. The inspectors' review concluded that none of the 26 operability assessments left open constituted

unreviewed safety questions.

, Conclusions The licensee's safety focus was good as demonstrated by the outage plan from a shutdown risk perspective, the pre-job preparation and execution of work on 1RC8002C, and the preparation for and execution of fuel movement The licensee made significant reductions in powerblock non-outage corrective maintenance backlog and open operability evaluations during refuling outage A1R06. While most observed maintenance was well performed, the execution of some significant maintenance and testing activities was weak. Although the maintenance on the 1 A diesel generator was performed well, during work on the 18

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diesel generator, the inspectors identified two problems with foreign material exclusion control and the licensee identified that the jacket water system was over pressurizated. The inspectors also identified problems with test control during the performance of the safety injection and charging system check valve surveillance a testin M1.2 Unit 1 BAST Soill Recoverv

. Insoection Scoce (62707)

l The inspectors attended recovery and plant operational review committee meetings; reviewed operability evaluation 97-060 on the seal between the BAST room and the Unit 2 diesel driven auxiliary feedwater pump room; reviewed problem identification forms (PIF) 456-201-94-23300 and A1997-02481; and reviewed licensee

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procedures BwAF 1110-1, " Fire Protection Program System Requirements,"

Revision 5; BwVS 7.11.1.A-3, " Fire Barrier Penetration Visual inspection,"

Revision 1; and BwVS 220-1, " Flood Seals Visual Inspection," Revision b. Observations and Findinos For details on how and when the event occurred see Paragraph 0 The inspectors attended the equipment recovery meetings where the licensee discussed the plans that were developed for cleanup and inspection t equipmen Responsible individuals were assigned and time tables were establisheo to investigate the extent of the problem caused by the water. Later meetings established the work to be performed, based on the equipment inspections, and the testing requirements based on the work performed. The inspectors reviewed the list of work performed, reviewed the licensee's operability testing plan, observed portions of the testing of the Unit 2 diesel driven auxiliary feedwater pump, and interviewed the system engineer about how specific components were tested. The inspectors had no concerns with the testing plan or the conduct of the testin The inspectors reviewed the licensee's operability evaluation on the seal between the BAST room and the Unit 2 diesel driven auxiliary feedwater pump room. The evaluation stated that the seal functioned as a fire, flood, radiation, and ventilation barrier. The seal consisted of a silicone elastomer, a cerabianket (the fire seal)

around the pipe, and a boot over the top to make it water tight. The operability evaluation also stated that the as-found condition of the seal was that the cerablanket was missing and the boot clamp attaching the boot to the pipe was not

, tightly secured. The system engineer later stated to the inspectors that the boot seal was worn through in spots due to movement of the exhaust piping. Drawing M-1033, Sheet 4, showed the BAST room floor as a flood barrie Technical Specifications 6.8.1.g. states,in part, that written procedures shall be established, implemented, and maintained covering the Fire Protection Program implementation. The Fire Protection Program was implemented through procedure BwAP 1110-1, " Fire Protection Program System Requirements," Revision 5. The inspectors reviewed procedure BwAP 1110-1. Step E.7 delineated the requirements for fire sealinspection. Ten percent of each type of fire seal were to be inspected every 18 months to ensure that every fire seal would be inspected in a 15-year period. Licensee procedure BwAP 1110-1 deliniated the required compensatory measures for a fire seal that was unavailable. These compensatory measures were to establish within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> a continuous fire watch on at least one side of the affected boundary, or verify the availability of the fire detectors on a least one side of the affected boundary and establish an hourly fire watch patro Through discussions with licensee fire protection personnel the inspectors learned there were fire detectors in the room and there had been an hourly fire watch patrol through the 28 diesel driven auxiliary feedwater pump room since 1989 for other reason o

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Subsequent to this event the licensee documented in PIF A1997-02481 that the

"BRIMPEN" data base used to track the periodic inspection of the station's fire and flood seals did not include the seals for the exhaust penetrations for the Unit 1 and 2 diesel driven auxiliary feedwater pumps from the Unit 2 diesel driven auxiliary feedwater pump room to the BAST room. The licensee's program for inspection of these types of seals requires that they only be inspected on a 15-year frequenc Because Braidwood has only been licensed about 10 years the licensee had not yet exceeded this inspection frequenc The inspectors reviewed procedure BwAP 2201. Step E.1 defined the requirements for inspection of flood seals as 10 percent of each kind of flood seal be inspected every 3 years with every seal to be inspected at least every 30 year The inspectors were unable to identify any regulatory requirement to inspect the -

station flood seal Conclusions Implementation of licensee procedure BwAP 11101, " Fire Protection Program System Requirements," Revision 5, Step E.7, which delineated the requirements for fire seal inspections, was weak, as evidenced by licensee identification that not all the fire seals required for inspection were identified in the surveillance data bas The inspectors also concluded that the post event response, such as identifying the scope of the problems, identifying the work to be performed, and identifying required testing to verify operability was well organized, timely, and demonstrated a good safety focus, M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Failure to Monitor Maintenance Rule Availability Criteria for the Post Accident Neutron Monitorino (PANM) System Insoection Scoos (62707)

The inspectors conducted a review of the licensee's implementation of the Maintenance Rule (10 CFR 50.65) as it applied to the PANMs. The inspectors conducted interviews with the system engineer, the site maintenance rule owner, and reviewed the following documents:

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18wAO PRI-5, Revision 57A, " Control Room inaccessibility;"

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BwAP 2300-2, Revision 0, " Maintenance Rule implementation Program;"

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BwAP 2300-2A1, Revision 0, "Braidwood Station Maintenance Rule Scoping and Risk Significance Determination Results;"

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BwAP 2300-2A2, Revision 0, "Braidwood Station Maintenance Criteria;"

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BwAp 2300-3, Revision 0, " Maintenance Rule Compliance Program;" and

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Component Maintenance History - Post Accident Neutron Monitoring System (January 1994 - December 1996).

b. Observations and Findinas On February 26,1997, the inspectors noted that licensee procedure BwAO PRI 5 referred to the use of the PANMs. The inspectors found that BwAO PRI 5 met the definition of an Emerge acy Operations Procedures as defined in BwAP 2300-2. The inspectors determined that the PANMs were required by 10 CFR 50.65(b)(2)(i) to be included in the scope of the licensee's monitoring program since BwAO PRI-5 specifically refers to the use of the PANM system. On February 27,1997, the inspectors asked the licensee if the Braidwood Maintenance Rule scope included the PANM system. The licensee indicated that the PANMs were included in the scope under " Neutron Monitors / Neutron Instrumentation System" section of BwAP 2300-2A1 and were classified per 10 CFR 50.65(a)(2).

The inspectors reviewed the availability criteria in BwAP 2300-2A2 and maintenance history records for the PANMs back to July 1993 to determine if the availability criteria had been met. The licensee established acceptable availability as not more than 4 days of unavailability per channel per fuel cycle. During the review of the maintenance history, the inspectors identified nine examples where a channel of the PANM system was unavailable for a period in excess of 4 days due to equipment failure. Three other examples also had occurred since July 1996. Based on the historical unavailability, the inspectors concluded that the licensee did not have an adequate technical basis for concluding that the performance of the PANMs were being controlled through effective preventive maintenanc The inspectors discussed the maintenance history findings and the current 10 CFR 50.65(a)(2) classification of the PANMs with the site maintenance rule owner (SMRO). The SMRO told the inspectors that the PANMs should have been classified por 10 CFR 50.65(a)(1) system based on availability. The licensee determined that their program monitored time in a limiting condition for operation as an indication of the PANM's availability. Since the PANMs were not required by technical specifications, no limiting condition for operation existed for the PANM Therefore, the source of availability data did not capture the unavailability of the PANM The inspectors found that Maintenance Rule was not correctly implemented for the PANM system in that; the licensee improperly categorized the PANM system as falling under 10 CFR 50.65(a)(2), failed to establish appropriate 10 CFR 50.65(a)(1)

goals, failed to establish a corrective action program, and failed to monitor PANM system performance against appropriate goals. This was considered a violation of 10 CFR 50.65(a)(2); (50-456/97009-02(DRP); 50-457/97009-02(DRP)). Conclusions The inspectors concluded that the licensee failed to perform an adequate historical review of the PANM system performance during the 3 years prior to July 10,1996,

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and that the performance of the PANM system had not been effectively controlled through the performance of appropriate preventive maintenance. These conclusions were based on the number of examples observed during that period where a portion of the PANM system was not available to perform its intended function. This is considered a violation of 10 CFR 50.65(a)(2).

M3 Maintenance Procedures and Documentation M3.1 CV System Pumo Casino and Discharae Pioina Ventina Insoection Scoce (61726)

The inspectors reviewed TS 4.5.2.b.1 and licensee procedure 2BwOS 5.2.b-1,

"ECCS Venting and Valve Alignment Status Surveillance," Revision Observations and Findinas On May 22, during a review of TS surveillance testing requirements for venting the ECCS pump casings and discharge piping high points outside of containment, the inspectors identified that TS 4.5.2.b.1 had not been performed as require Specifically, the Unit 1 and 2 CV (an ECCS subsystem) pump casings, and the CV high point vents had never been vented during Modes 1,2, and 3: a time period that exceeded the TS limit of venting at least once per 31 day The inspectors learned that on February 16,1996, a Braidwood system engineer '

had identified that both the Byron station and the Braidwood station did not vent the CV pump casings and high point vents as required by TS 4.5.2.b.1. The Braidwood licensee's operability }ustification stated that there was no technical concern with the lack of casing vents on the CV pumps or the lack of venting on the CV system every 31 days due to the intent of the TS being met. The licensee credited the dynamic venting action of the operating CV pump as meeting the TS requirement to ensure that the ECCS piping was full of water. For piping not directly in the flowpath, the licensee determined that gas accumulation was not credible due to the pressure inside the piping. The idle CV pump was considered to be self-venting due to CV system design and piping configuratio The inspectors at the Byron station noted that operating the CV pump appeared to constitute flushing the line versus venting the line and also noted that the CV high point vent valve was not subject to system flow. Although the Braidwood licensee considered all CV pumps to be operable, the licensee was not in literal compliance with the TS and both trains of CV were declared inoperable on Unit 2. The Unit 1 CV pumps were considered operable since they had been vented during their retum to service within the previous 31 day On May 23, the licensee requested a Notice of Enforcement Discretion (NOED) for Unit 2 and a TS amendment for Unit 1 to modify the wording of TS 4.5.2.b.1. In support of the requests, the licensee performed compensatory actions of ultrasonically testing the vulnerable areas in the CV system piping to verify that the

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piping was filled with water. The NRC staff approved the NOED on May 24 and intended to issue the license amendment after appropriate revie Technical Specification 4.5.2.b.1, Amendment No. 83, stated, "Each ECCS subsystem shall be demonstrated operable at least once per 31 days by venting the ECCS pump casings and discharge piping high points outside of containment." The failure to vent the CV pump casing and system discharge piping was an apparent violation of TS 4.5.2.b.1 (eel 50-456/97009-03(DRP); 50-457/97009-03(DRP)). Conclusions The inspectors were concerned that even though the licensee had identified in February 1996 that they were not in strict complacence with the TS, that no action

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was taken to have the TS changed. Rather, an engineering basis concluding that the TS intent had been met was considered acceptable. The inspectors concluded that the failure to vent the CV pumps in accordance with the TS is an apparent violatio M4 Maintenance Staff Knowledge and Performance M4.1 Surveillance Observations Inspection Scone (61726)

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

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1BwVS 6.2.2.d-1, " Containment Spray Additive Flow Rate Verification,"

Revision 8;

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BwVS 8.1.1.2.a-1, " Unit Two 2A Diesel Generator Operability Monthly (Staggered) and Semi Annual (Staggered) Surveillance," Revision 12;

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BwVS 4.5.2.f.1.a, "Surveillanco Requirement For 1 A Charging Pump Discharge Pressure," Revision 0;

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18wVS 1.2.3.1-1, "ASME Surveillance Requirements For 1 A Centrifugal Charging Pump and Check Valve 1CV8408A Stroke Test," Revision 0; and

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2BwVS 0.5-3.AF.1-2, " Unit Two Diesel Driven Auxiliary Feedwater Pump ASME Quarterly Surveillance," Revision Observations and Findinas The inspectors verified that all surveillance tests observed were performed in accordance with their applicable procedures, that equipment operation and performance parameters met acceptance criteria, that good communications between the control room and personnel in the field occurred, and that all

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instruments used were in calibration. The inspectors reviewed applicable TSs and sections or the UFSAR and found no discrepancie The 28 auxiliary feedwater pump surveillance test was performed in order to demonstrate that the 2B auxiliary feedwater pump was operable. The pump was declared inoperable on June 9 due to large amounts of water dripping into the 2B auxiliary pump room from the BAST room abov The system engineer acted as the test director for the surveillance test and was present at the pump during performance of the entire test. The inspectors observed that the system engineer was familiar with all components that were affected by water dripping from the BAST room and was knowledgeable about operation of plant and test equipmen Conclusions The surveillances tests listed above were performed in accordance with procedures and all acceptance criteria were met. Additionally, test procedures were well written and ensured that TS and UFSAR requirements were me M4.2 Observation of Station Auxiliary Transformer (SAT) Maintenance i Insoection Scone (62707)

The inspectors observed electrical maintenance department (EMD) personnel perform the following SAT maintenance:

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SAT ground fault protection relay modification, WR#960063106; f

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SAT neutral phase resistor bank insulator replacement, WR#950047317.

} Observations and Findinas On June 17 the inspectors observed the termination of cables to model CO-2 relays, located in panel 1PA23J, for the 141-1 SAT. The maintenance personnel had the work package available at the work location and followed the procedural steps. The work package contained tha correct drawings for the work being performed. Maintenance personnel checked the procedure's instruction against the schematic drawings before performing the termination of new cables, performed the termination, and then verified that the termination had been performed in accordance with the procedure. Electrical safety precautions were practiced and safety equipment use On June 17 the inspectors observed a briefing conducted by an EMD supervisor with the laborers assigned to build scaffolding for the resistor bank insulator replacement on the 141-1 SAT. The supervisor provided a detailed description of the work to be performed, walked down the out-of-service for the 141-1 SAT, explicitly identified energized buses in the area, and indicated areas that should not

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be obstructed by the scaffolding. The inspectors also performed a review c,f the out of service isolation points for the 1411 SAT outage and found them adequate for the work to be performe On June 19, the inspectors returned to look at the construction of the scaffolding and to observe the replacement of the 141-1 SAT neutral phase resistor bank insulators. The scaffolding had been erected per the instructions of the EMD supervisor. EMD personnel had disconnected the electrical connections and removed the old insulators. The work package was at the work site and was being used by the maintenance personnel, Conclusions Observed maintenance performed was considered good based on the following:

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EMD practiced applicable electrical safety precautions;

- work procedures were followed;

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procedures and drawings were adequate for the scope of the work;

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work packages contain the necessary drawings and instruction;

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the out of-service was adequate;

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EMD performed self-checking:

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adequate pre-job briefings were performe M8 Miscellaneous Maintenance Activities (92902)

M8.1 (Closed) Unresolved item 50-456/96014-04:50-457/96014-04: Missed Surveillance on Containment isolation Valves. The licensee identified on October 4, 1996, that the instrument vent and drain valves for pressure indicators 1(2)PI 929 were missing from licensee procedure 1(2)BwOS 6.1.1.a-1, " Unit One (Two)

Primary Containment Integrity Verification Of isolation Devices Outside Containment." The licensee verified that the vent and drain valves were closed and capped, hung administrative control tags on all valves, and submitted procedure revisions to include the valves in 1(2)BwOS 6.1.1.a-1. The licensee also conducted a review of all containment piping penetrations to ensure no other valves had been missed. The revier identified two localleak rate test (LLRT) test connections which were not being checked. The licensee took the same immediate corrective actions for the LLRT test valves as they did for the instrument vent and drains. The licensee also commenced a review to determine what the surveillance test requirements were on the valves in question since the Byron station's equivalent procedure did contain these valves for testing. After further review, the licensee concluded that these valves were not subject to TS surveillance test requirement 4.6.1.1.a. The inspectors, however, could not reach this same conclusion. As a 21 j I

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. result, Region ill requested the Office of Nuclear Reactor Regulations (NRR) review this conce NRR's Technical Specifications Branch reviewed the request and agreed that the subject valves should have been tested per TS 4.6.1.1.a. The inspectors concluded that the licensee was in violation of TS 4.6.1.1.a (50-456/97009 04(DRP);

50-457/97009-04(DRP)).

Ill. Enaineerina E2 Engineering Support of Facilities and Equipment E Charoina Pumo Seal Problems Insoection Scone (37551)

During the months of May and June, problems with excessive charging pump seal leakage occurred on both Unit 1 and Unit 2. The inspectors monitored the licensee's response and reviewed operability evaluations generated as a result of the seal problems. The inspector also interviewed system engineering, site engineering, and operations personne Observations and Findinas Problems with excessive charging pump seat leakage started with the 1B charging pump in May. On May 13,1997, maintenance personnel adjusted the seal on the 1B charging pump in order to reduce sealleakage. The leakage was acceptable j

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until June 8 when operating personnel discovered that seal leakage significantly increased after the pump was stopped. On June 9, the system engineer measured the leakage at approximately 420 cubic centimeters per minute (cc/ minute) from the pump motor end sea Table 15.0-12 of the UFSAR assumed the leakage for each charging pump was no more then 20 cubic centimeters per hour (cc/ hour). Additionally, the total assumed leakage outside containment was listed as 3910 cc/ hour. Therefore, the actual leakage from just the 1B charging pump inboard seal represented 7.4 times the total assumed leakage for all components outside containment. Since the leakage exceeded the UFSAR assumptions, engineering personnel at the station performed an operability evaluation of the condition. The operability evaluation stated that the leakage assumptions were established to satisfy dose limits in 10 CFR Part 50, General Design Criteria 19, for control room dose and for 10 CFR Part 100 dose criteri As part of the operability evaluation, actual dose to personnel in the control room and to personnelin the low population zone around the plant were calculated as a function of leakage from the charging pump seals. An acceptable leakage rate of 1 gallon per minute from the charging pump seals was established as a result of the

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s q evaluation. The operability evaluation also established a new monitoring frequency for the charging pump seals. The inspectors found the evaluation to be acceptabl On June 11, maintenance personnel once again adjusted the 1B charging pump motor end seal. The adjustment was successful, with leak rates within the UFSAR assumptions. No additional problems were identified with the 1B charging pump seal leakag On June 13 and June 14, plant personnel identified increased leakage on the 2A and 2B charging pump outer seals. Both pumps had increased sealleakage when the pumps were shutdown. The 2A pump leakage was about 80 cc/ minute and the 2B pump leakage was about 1000 cc/ minut On June 18, maintenance personnel adjusted the 2B charging pump outer seal. The inspector observed performance of the seal adjustment. Maintenance, engineering, RP, and operations personnel were present to support adjustment of the pump sea The operator maintained communications with the control room and performed local operations as required. Engineering personnel were present to provide technical assistance to maintenance personnel and to try to determine the cause of the problems. The licensee's adjustment of the 2B charging pump outer seal was successful and leakage from the seal decreased to approximately 5 drops per minute. The 2A charging pump outer seal was later adjusted to near zero leakag System engineering personnel have tried to determine the cause of the seal problems. Currently, the engineers believe that either weakening springs in the seal package or some other mechanical problem prevented the seals from performing as designe Conclusions

.The inspectors concluded that support provided by system and site engineering personnel in making a determination of operability and correcting the sealleakage was good.

E3 Engineering Support of Facilities and Equipment E Operability Evaluation Review insoection Scoce (37551)

The inspectors reviewed the following operability evaluations for conformance with the requirements of procedure BwAP 330-10, " Operability Determinations,"

Revision 3:

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Operability Determination 97-010, Containment Penetrations and Isolated Piping Systems Potentially Susceptible to Overpressurization During LOCA or MSLB Events:

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- Operability Determination 97 O'31, Containment Spray System Pump Head-Capacity Calculation:

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Operability Determination 97-055, Residual Heat Removal Heat Exchanger Maximum Design Flow Rate;-

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-Operability Determination 97 062,2A Charging Pump Leakage Outside Containment; and

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. Operability Determination 97-065, 2A Emergency Diesel Generator Circulating Oil Pump Suction Expansion Joint lateral Displacemen Observations and Findinas The inspectors found that the Shift Manager's initial operability _ determinations were promptly performed and Problem identification Forms (PIFs) submitted. Likewise, _

the system engineering staff's reviews were performed in a timely manner consistent with the safety significance of the issue The operability determinations reviewed by the inspectors used good engineering analysis as a basis for operability. Results of the analyses were clearly and logically

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presented. Compensatory measures and corrective actions taken were

documented.- Attachments B and C to BwAP 33010 were found properly

- completed, reviewed, and signed, Conclusions The inspectors concluded that the operability determinations were performed in'a timely manner, were appropriately based on engineering analysis, and were properly documented. Procedure BwAP 330-10 was well written and included Generic

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Letter 91-18 guidanc IV. PLANT SUPPORT R1- Radiological Protection and Chemistry (RP&C) Controls R1.1- - Evidence of Poor Radiation Worker Practices in Auxiliary Buildina Inlet Plenum

- Insoection Scooe (71750)

On June 4,1997, the inspectors identified an auxiliary building ventilation system inlet plenum door was open and unattended. As a result of this observationi the _ 1

inspectors conducted a walkdown inspection of the auxiliary building ventilation system with the system engineer. The inspectors also interviewed RP personne .

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4 Observations and Findinos The inspectors contacted plant personnel and determined that no plant barrier impairment had been prepared that could allow the door to be left in the open position. The inspectors notified licensee personnel of the condition and the door was close The inspectors questioned a system engineer if the open door could pose any plant operational problems. The system engineer indicated that the auxiliary building ventilation system fresh air supply would be reduced if the door was open and the main supply fans were running. The auxiliary building main supply and exhaust fans were not running when the door was found open because of maintenance on the system. The engineer also noted that if a fan on the train with the open door started, the door would likely be pulled closed by the differential pressure. The inspectors noted that the latching mechanisms on the door could have vibrated open with the fans secure The inspectors found numerous cigarette butts in the plenum. The plenum was located in a radiologically control area in the auxiliary building and smoking was prohibited in the area. The cigarette butts were reported to RP personnel who had them removed from the plenum, Conclusions The inspectors identified evidence of a poor radiation worker practice in the auxiliary building. Cigarette butts found in the auxiliary building ventilation system inlet plenum indicated that plant personnel smoked cigarettes in the radiologically }

controlled area at some time in the past. The inspectors were unable to conclude whether the door had come open due to a poor latching mechanism or was left open by someon R4 Staff Knowledge and Performance in RP&C R4.1 Good RP Suocort Durina Unit 2 CV Pumo Maintenance Insoection Scoce (71750)

The inspectors observed an RP technician during the performance of maintenance on the 2B CV pump on June 1 Observations andfindinas The RP technician maintained positive control of actions in the room that involved handling potentially contaminated materials. The RP technician gave instructions for contamination control and provided monitoring for contamination during the entire repair evolution. Overall, support from the RP technician was very goo ;

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c. Conclusions RP support for tho 2B charging pump seal adjustment performed on June 18 was good.

P5 Staff Training and Qualification in EP PS.1 Annual Emeraency Plan Trainina a. Insoection Scope (71750)

On June 11, the licensee provided training to personnel who staff the Technical Support Center (TSC) during emergency plan implementation. The training consisted of an emergency scenario drill. Training personnel, emergency planning personnel, and corporate evaluators were present to assist in the drill and to evaluate the performance of the TSC staff. The inspectors observed the annual emergency plan training presented in the TS b. Observations and Findinas Upon site-wide notification that the emergency plan drill was in progress, initial staffing of the TSC was prompt. The initial plant status update in the TSC was informative and the emergency was properly classified. When required, emergency plan classifications were upgrade Status boards were established and we'l maintained during the drill. Routine updates of plant status were presented wer th i course of the drill. Transfer of command and control, first from the centro' .com to the TSC and then from the TSC to the Emergency Operating Facihty, were orderly and well communicated to TSC staf Personnel stationed in the TSC were knowledgeable of their individual responsibilities and of the plant status. Demeanor in the TSC was professional during the entire training perio A site assembly was performed to demonstrate that plant personnel could be accounted for in the required period of time. Security personnelin the TSC were notified that site assembly was complete 27 minutes after the assembly was initiated. The emergency plan assumption of the ability to assemble plant personnel in 30 minutes was demonstrate Communications problems with off-site monitoring teams occurred during the drill due to a programming problem in the communications tower. TSC personnel responded appropriately to the communications problems, including ensuring that the TSC director was aware of the problems. After the drill, the tower programming was correcte '

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Eq Corporate emergency planning personnel were present to assist in evaluating TSC staff performance during the training, The corporate evaluators determined that TSC staff performance was satisfactory. As a result of the satisfactory performance of the emergency plan drill, the emergency plan drill originally scheduled for June 25 was canceled. Following the training drillin the TSC, a drill critique was performed for TSC personnel. Trainees were self critical when necessar c. Conclusions Overall performance of emergency planning training presented in the TSC on June 11 was good. Involved TSC staff were knowledgeable of their responsibilities and TSC staff conduct was professional during the training and the critique session that followed the drill. Station personnel were assembled in less than 30 minutes meeting emergency plan requirements.

X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on June 30,1997. The licensee acknowledged the findings presented. The inspectors a n.ed the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie l

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PARTIAL LIST OF PERSONS CONTACTED Licensee H. G. Stanley, Site Vice President

'T. Tulon, Station Manager -

H.- Pontious, Nuclear Licensing Administrator

'A. Haeger, Health Physics and Chemistry Supervisor

'R. Byers, Maintenance Superintendent

'R Graham, Work Control Superintendent

'T. Simpkin, Regulatory Assurance Supervisor

'C. Dunn, System Engineering Supervisor

• F. Lentine, Support Engineering Supervisor

'E. Hendrix, Operations Staff Supervisor

"J. Nalewajka, ISEG Supervisor J. Meister, Engineering Manager  :

'B. Wegner, Operations Manager

'C. Herzog, SVP Executive Assistant

'M. DiPonzio, Radiation Protection

• M. Cassidy, Regulatory Assurance - NRC Coordinator

. R. Lanksbury, Chief, Reactor Projects Branch 3

'C. Phillips, Senior Resident inspector

'J. Adams, Resident inspector IQfiS

'T. Esper, Resident Engineer

• Denotes those who attended the exit interview conducted on June 30i199 !

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INSPECTION PROCEDURES USED IP 37551:_ Onsite Erigineering IP 61726: - Surveillance Observations-IP 62707: Maintenance Observation IP 71707: Plant Operations IP 71750: Plant Support Activities IP 92700: Onsite Followup of Written Reports of Nonroutine Events at Power Reactor Facilities IP 92902: Followup - Plant Maintenance ITEMS OPENED, CLOSED, AND DISCUSSED Onened 50 456/97009-01 .VIO failure to maintain procedures 50-456/97009-02; 50 457/97009-02 VIO failure to monitor maintenance rule availability criteria for PANMs ,

50-456/97009 03; 50-457/97009 03 eel failure to vent CV pump 50-456/97009-04; 50-457/97009-04 VIO - missed surveillance on containment 1 isolation valve Closed 50-456/95015 04; 50-457/95015-04 DEV failure to meet commitment 50-456/96014-04; 50-457/96014 04 URI missed surveillance on containment isolation valve l

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a LIST.OF ACRONYMS USED

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BAST Boric Acid Storage Tank CC/ HOUR ' Cubic Centimeters per Hour LCC/ MINUTE Cubic Centimeters per Minute CFR_ Code of Federal Regulations -

Comed - Commonwealth Edison CV . Centrifugal Charging DC Direct Current ECCS Emergency Core Cooling System

~ EMD , Electrical Maintenance Department

'EO Equipment Operator FS; Field Supervisor LLRT Local Leak Rate Test NOED- Notice of Enforcement Discussion

' NRC- _ Nuclear Regulatory Commission

NRR Nuclear Reactor Regulations

, ODCM_ Offsite Dose Calculation Manual

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OOS Out-Of Service

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PANM . Post Accident Neutron Monitors -

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PD3 Public Document Room

-- PIF Problem identification Form RP Radiation Protection -

! .RP&C Radiological Protection & Chemistry SAT Station Auxiliary Transformer

!- SMRO Site Maintenance Rule Owner-SRO- Senior Reactor Operator SX- Essential Service Water-

TS Technical Specification

TSC -Technical Support Center y .UFSAR Updated Final Safety Analysis Report VIO -_ Violation

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