IR 05000456/1998002

Insp Repts 50-456/98-02 & 50-457/98-02 on 980127-0309. Violations Noted.Major Areas Inspected:Operations, Maintenance,Engineering & Plant Support

ML20216B076
Person / Time
Site:	Braidwood
Issue date:	04/08/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20216B037	List: ML20216B032 ML20216B061 ML20216B076
References
50-456-98-02, 50-456-98-2, 50-457-98-02, 50-457-98-2, NUDOCS 9804130362
Download: ML20216B076 (24)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lil Docket Nos: 50-456; 50-457 Licence Nes: NPF-72; NPF-77 Report No: 50-456/98002(DRP); 50-457/98002(DRP)

Licensee: Commonwealth Edison (Comed)

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Facility: Braidwood Nuclear Plant, Units 1 and 2

Location: RR #1, Box 84 Braceville,IL 60407 Dates: January 27,1997, through March 9,1998 Inspectors: C. Phillips, Senior Resident inspector l J. Adams, Resident inspector i D. Pelton, Resident inspector T. Esper, Illinois Department of Nuclear Safety Approved by: Michael Jordan, Chief Reactor Projects Branch 3 I

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1 EXECUTIVE SUMMARY Braidwood Nuclear Plant, Units 1 & 2 NRC Inspection Report No. 50-456/98002(DRP); 50-457/98002(DRP) -

This inspection included aspects of licensee operations, maintenance, engineering, and plant support. The report covers a six-week period of resident inspectio Operations

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The inspectors concluded that the quality of supervision declined during the Unit 2 startup from observed performance during previous reactor startups. This conclusion was based on operations supervision not identifying an error made by an operator during the review .

of a shutdown margin calculation; supervision's failure to direct the retum to service of the boron dilution prevention system after shutting down the reactor which is required by Technical Specification; and supervision not verifying the proper steam supply to the gland seal steam system. However, the inspectors did recognize the attempt by licensee management to improve operational performance by dedicating an operator and supervisor to monitor reactivity changes, and by developing a well prepared pre-evolution briefing. The problems with supervisory oversight were identified and corrected by the licensee and therefore, a non-cited violation was issued. (Section 01.1)

• The inspectors concluded that licensee management demonstrated a good safety focus during the paralleling of the steam-driven feedwater pumps during the Unit 2 reactor startup. The 28 steam-driven main feedwater pump would not respond to automatic or manual controls due to a failed low pressure govemor. The shift manager ensured procedural compliance and maintained excellent control of the troubleshooting evolution until the problem was resolved. (Section 01.2)

- The inspectors concluded that the as-found configuration of the Essential Service Water (SX) system was consistent with system drawings, Updated Final Safety Analysis Report '

system description, Technical Specifications, mechanical lineups, and electrical imoups with a few minor exceptions. The inspectors determined that the exceptions did not affect the operability of the Unit 2 SX system. The inspectors concluded that the SX .

- system procedures were well-written and contained sufficient guidance for personnel to complete the activity covered by the procedure. The material condition of the system was good. The heat exchanger inspections, heat exchanger performance tests, and blocide

' injection into the essential service water system were being scheduled, performed, and ,

documented to meet Generic Letter 89-13 commitments. (Section 02.1)

t Maintenance

- During surveillance testing, operations personnel and the involved system engineer were knowledgeable of system operation, testing setup, and testing methods. Operators identified and resolved potential problems between plant configuration and procedural l guidance prior to starting the test. Surveillance tests were performed in accordance with plant procedures and all acceptance criteria were met. (Section M1.1)

. Technical Specification and American Society of Mechanical Engineers surveillance requirements for the essential service water system were being met by the performance

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of surveillance tests. However, the inspectors identified that safety-related valves were manipulated during the performance of Unit 1 and Unit 2 Technical Staff Surveillance tests and independent verifications of proper system alignment were not subsequently conducted as required by Braidwood Administrative Procedure 100-18. A violation was issued. (Section M3.1)

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The inspectors concluded that licensee management demonstrated a good safety focus in addressing problems with the maintenance and test equipment program, originally identified by the inspectors in inspection Report No. g7022. The licensee established a team of station employees to address these problems, and the team took a broad look at the problem and was able to identify additional concems that needed to be resolve (Section M 8.1)

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The inspectors concluded that operability determinations regarding the reactor coolant system leakage calculations and the automatic operation of the pressurizer power operated relief valves reflected good engineering judgement and safety focu (Section E3.1)

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The inspectors performed a review of post-modification and surveillance testing procedures for a modification that installed a pressure control and fire damper assembly between the auxiliary and turbine buildings and concluded that all acceptance criteria associated with those procedures were met. The post-modification test procedure was well-written and verified that the modification performed as designed. The inspectors concluded that the pressure control and fire damper assembly properiy controlled the differential pressure between the auxiliary and turbine buildings. (Section E3.2)

• The inspectors concluded that the licensee was not aware of 134 engineering requests in its database that had not been prioritized. The inspectors also concluded that 253 high priority engineering requests had no due dates assigned. The 253 high prionty engineering requests without due dates assigned made up about 54 percent of the high pflority backlogs. With this high percentage, the inspectors concluded that the number of high priority overtiue engineering requests was not a good performance indicator of backlog reduction which was a performance indicator committed to in the licensee's March 28, igg 7 response to the NRC request for information pursuant to 10 CFR 50.54(f). (section E7.1)

Plant Support

- The inspectors concluded that the As-Low-As Reasonably-Achievable and Heightened Level of Awareness briefings for the transfer of resin were pr'speriy performed and documented. The inspectors concluded that the auxiliary building 383 foot elevation access points to the radwaste tunnel were properly posted and access was prohibited by locked doors. Post-transfer radiation surveys were completed and poste (Section R1.1)

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The radiation preiedien department's control of radiation monitoring devices and postings was good, instruments and postings were controlled in accordance with plant procedures. (Sections R2.1 and R2.2)

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The inspectors concluded that the continuous fire watch requirament for the Unit i lower cable spreading room was not met at least three times on January 29. The inspectors concluded that the fire watch was not adequately supervised because the instructions to the individual assigned to the fire watch were unclear, the stated post-order requirements were not enforced, and supervisory review of the watch documentation as well as observation of the fire watch did not identify these problems. A violation was issue (Section F1.1)

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Report Details Summary of Plant Status Unit 1 entered the inspection period at full power and remained at or near full power for the entire period Unit 2 entered the inspection period in a hot standby condition. While shut down, repairs were made to feedwater check valves and relief valves. Unit 2 was synchronized to the grid on February 4. Unit 2 remained at or near full power for the remainder of the perio I. Operations 01 Conduct of Operations 01.1 Unit 2 Restart From Forced Outane 4 Inspechon Scope (71707)

The i t:,pectors reviewed Unit 2 Braidwood General Operating Procedure (2BwGP) 100-2,

" Plant Startup," Revisions 10 and 10E1; Unit 2 Braidwood Operating Surveillance Procedure (2BwOS) 1.1.1.1.e-1, " Unit Two Shutdown Margin Daily Verification During Shutdown" Revision 11E1; and 2BwGP 100-3, " Power Ascension," Revision 13E1. The inspectors reviewed Onsite Review item 98-015, on the aborted startup at Unit 2 entitled,

"Startup of Unit 2 following forced outage A2F30 was aborted due to exceeding 500 percent millitho (pcm) difference between the estimated cntical condition and the entical condition predicted by the eight-fold methodology." The inspectors observed portions of the startu Observations and Findinas The inspectors observed that the communications between operators, nuclear engineers, .

and supervisors were clear both during the pre-evolution briefings and during the conduct d of the startup. A nuclear station operator and a senior reactor operator were assigned exclusively to monitor plant reactivity changes. In addition to the shift manager and the unit supervisor, senior operstm's department management was present for all portions of the startup observed by the inspectors. The inspectors observed portes of pro-evolution briefings given by licensee management prior to the startup. The quality of the briefings was excellent. Procedural steps and contingencies for potential problems with the startup were covered in detail. All necessary personnel were in attendanc During an attempt to pull control rods to achieve criticality on February 3, the nuclear engineers predicted that the unit would reach criticality greater than 500 pcm below the estimated condition for criticality. The withdrawal of control bank rods was stopped and control bank rods were reinserted as required by BwGP 100 2, Step F.24. The insertion of control rods resulted in the change of Unit 2 operational modes from Mode 2 (startup)

to Mode 3 (hot standby). During Mode 2, both trains of the boron dilution prevention systems were bypassed as required by plant procedure rendering them inoperabl Technical Specificate (TS) 3.1.2.7 stated that with the unit in Mode 3 and both boron dilution prevention subsystems inoperable, within one hour, and at least once every 12

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hours thereafter, verify the boron dilution prevente system valves are closed and secured in position and verify compliance with the shutdown margin requirements of TS 3.1.1.1 or 3.1.1.2 as applicable. The licensee identified that the unit was retumed to Mode 3 at 12:00 p.m., but the boron dilution prevention system was not retumed to service until 2:4g p .m., nor were the boron dilution prevention system isolation valves verified to be in the correct position The licensee reported the event in Licensee Event Report 50-457/98002. The inspectors reviewed the report and noted that the licensee identified personrMI error and an inadequate procedure as the causes of the event. The licensee identified the following corrective actions to prevent recurrence:

Operating personnel were briefed on this event, which included management expectations regarding conservative decision making, TS compliance, delayed startups, and the operation of the boron dilution prevention system; and

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Procedures 1/2BwGP 100-2 will be revised to clarify the requirements for the boron dilution prevention system when a delay in startup is encountered, to ensure the requirements are met before startup resumption following a delay, and to address restoration of the boron dilution prevention system when proceeding to shutdown per 1/2BwGP 100 5, " Plant Shutdown and Cooldown", due to a termination in the startu The inspectors noted that the licensee's corrective actions addressed the causes of the event. The inspectors had no further concom The licensee's nuclear fuel services organization performed a root cause analysis of why the estimated critical position was off by such a large margin. The inspectors reviewed the onsite review document and had no concems. The inspectors observed that the subsequent startup actual critical condition was within the 500 pcm band of the estimated critical conditio The licensee identified that shutdown margin calculation Surveillance 2BwoS 1.1.1.1.e-1, performed prior to withdrawal of the shutdown rod banks on February 3, was conducted incorrectly. The nuclear station operator made a sign convention error in the calculatio The senior reactor operator performed an independent verification of the calculation The senior reactor operator stated to the inspectors that he made the same error as the nuclear station operator. The licensee determined that adequate shutdown margin did axist at the time of the original error. The licensee also identified that the steam supply to the gland seal had not been transferred from the auxiliary boiler to the operating unit as required by 2BwGP 100-3, Step 31. The operations field supervisor had erroneously stated that the step was completed and the nuclear station operator had signed off the step in the startup procedur ' The failure to restore the boron dilution prevention system to service within an hour of retuming Unit 2 to Mode 3 was a violation of TS 3.1.2.7. This non-repetitive, licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-457/98002-01(DRP)).

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. Conclusion The inspectors concluded that the quality of supervision declined during the Unit 2 startup from observed performance during previous reactor startups. This conclusion was based on supervision not identifying an error made by an operator during the review of a shutdown margin calculation; supervision's failure to direct the retum to service of the boron dilution prevention system which is required by Technical Specification, after shutting down the reactor and supervision not verifying the proper steam supply to the gland seal steam system. However, the inspectors did recognize the attempt by licensee management to improve operational performance by dedicating an operator and supervisor to monitor reactivity changes, and by developing a well prepared pre-evolution briefing. The problems with supervisory oversight were identified and corrected by the licensee and therefore, a non-cited violation was issue .2 2B Feedwater Pump Control Failure Inspection Scope (71707)

The inspectors observed portions of the evolution involving the changing of main feedwater pumps during the Unit 2 reactor startup. The inspectors reviewed Temporary Procedure Change 7536 to Braidwood Operating Procedure (BwOP) FW-02, " Shutdown of A Turbine Driven Main Feedwater Pump," Revision gE Observations and Findinos The 2B main feedwater pump had a failed low pressure govemor that prevented load sharing between the 28 and 2C foodwater pumps, this in tum prevented power limreases above 60 percent. The inspectors observed that the shift manager maintained excellent step-by-:teo rt,ntrol of the trouble shooting and held several crew briefings discussing the status of efforts to identify the problem and to ensure all members of he crew were aware of their responsibilities. The operators identified the problem with the 2B feedwater pump. The procedure to secure a foodwater pump, SWOP FW-02, was changed appropriately to allow for a manual isolation of steam to the low pressure govemor, Conclusion The inspectors concluded that licensee management demonstrated good safety focus during the paralleling of the steam-driven feedwater pumps during the Unit 2 reactor startup. The shift manager ensured procedural compliance and maintained excellent control over the trouble shooting in the identification and resolution of a failed low pressure govemor for the 2B steam-driven feedwater pum .3 Out-of-Service Review Inspection Scope (71707)

The inspectors reviewed two safety-related out-of-services (OOSs) in effect and an OOS recently cleared. The inspectors also interviewed operations personnel in the work control conter about the administration of the OOS progra l

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~ Observations and Findinas )i The inspectors reviewnd safety-related OOSs 970000723 and 970000741 that were in effect. The OOSs woro ,Moperty prepared and authorized. All components listed on the OOSs were in positions required by the OOSs and OOS cards were affixed to the component i The inspectors reviewed recently cleared safety-related OOS 980001103. All l components were retumed to the required position listed or the 008. AM OOS tags were removed from components, i

- Conclusion The OOss on safety-related components were property placed and remove Documentation for the reviewed OOSs was complet .O2 Operational Status of Faollities and Equipment O2.1 Unit 2 Essential Service Water (SX) System Welkdown

hsDedion scope (71707)

The inspectors performed a detailed walkdown of the accessable portions of the Unit 2 SX system. As part of the walkdown, the inspectors reviewed the following documents:

Piping and Instrumentation Diagrams (P&lD) M-42, M-126, and M152;

BwOP SX-E2, " Electrical Lineup - Unit 2 Essential Service Water System,"

Revision SE2;

BwoP SX-M2, " Operating Mechanical Lineup - Unit 2 Essential Service Water System," Revision 13E2;

• BwoP SX-M2, " Operating Mechanical Lineup - Unit 2 Essential Service Water System," Revision 12 (Completed 12/19/97);

• - Braidwood Updated Final Safety Analysis Report (UFSAR), Section 9.2. * Braidwood TS, Section 3/4. * BwoP SX-1, " Essential Service Water Pump Startup," Revision 6;

• BwOP SX-2, " Essential Service Water Pump Shutdown," Revision 7;

• BwOP SX-3, " Essential Service Water System Fill and Verd," Revision 4;

• BwoP SX-3, " Essential Service Water System Drain," Revision 3; and

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BwAP 340-2, "Use of Mechanical and Electrical Lineups," Revision 15E Observations and Findmos i The inspectors performed a detailed walkdown of the accessable portions of the UnN 2 SX system. As part of this detailed inspection, the inspectors compared the as-found system configuration to the system drawings, UFSAR system description, TSs, and mechanical and electrical lineups. The inspectors determined that the system was

' aligned in accordance with the mechanical lineup of BwoP SX-M2, with a few minor exceptions. The inspectors evaluated the identified exceptions and determined that they had no affect on the operability of the Unit 2 essential service water system. The inspectors discussed each exception with operations personnel and were told that each ;

problem would be correcte i The inspectors performed a review of operating procedures for the startup, shutdown, system fill and vent, and system drain of the Unit 2 SX system. The inspectors determined that the procedures were well written and contained sufficient guidance for

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e personnel to complete the activity addressed by the procedure The inspectors examined the material condition of SX system components and reviewed a list of Unit 2 SX problems identified by the licensee. The material condition problems observed by the inspectors were few in number, minor, identified by the licensee, and entered in the licensee's corrective action progra The inspectors evaluated housekeeping and environmental condihons to assess their

' impact on Unit 2 SX system performance. The inspectors determined that the housekeeping efforts were effective since no accumulation of trash, debris, or combustibles was found during the walkdown. The SX system components were clean with no accumulation of dirt, grease, or oil. Motor cooling vents were clean and free from obstruction. The inspectors observed very little scaffolding in the vicinity of SX system components. The scaffolding that was present was property documented and did not interfere with the SX system operatio The inspectors reviewed the licensee's commitments to Genenc Letter 89-13, " Service Water Problems Affecting Safety-related Equipment," and the licensee's program to monitor the condition and performance of heat exchangers served by the SX syste The inspectors discussed the operation of the blocide injection system with the system engineer, examined documentation of safety-related heat exchanger inspections, and j verified that the Unit "0" component cooling water heat exchanger was aligned to biocide treated SX flow on a periodic basis. The inspectors did not find any heat exchanger inspection documentation that identified a significant amount of heat exchanger foulin I

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i c. Conclusion The inspectors concluded that the as-found configuration of the Essential Service Water (SX) system was consistent with system drawings, Updated Final Safety Analysis Report system description, Technical Specifications, mechanical lineups, and electrical lineups with a few minor exceptions. The inspectors determined that the exceptions did not affect the operability of the Unit 2 SX system. The inspectors concluded that the SX system procedures were well-written and contained sufficient guidance for personnel to complete the activity covered by the procedure. The matetial condition of the system was good. The heat exchanger inspections, heat exchanger performance tests, and blocide injection into the essential service water system were being scheduled, performed, and -

documented to meet Generic Letter 8g-13 commitment Follow up Plant Operations (92901)

07.1 10 CFR 50.54m Letter Commitment Review a. Inspection Scope The inspectors reviewed the status of commitments pertaining to the Braidwood Station March 28,1997, response to the NRC's request for information pursuant to 10 CFR 50.54(f). The following commitments related to periodic management review meetings were reviewed by the inspectors. The commitment numbers correspond to ,

those used by the licensee in their March 28, igg 7, respons ' b. Observations and Findinos Commitment 68 and 69 These commitments discussed the use of peer groups to address common problems between sites and to ensure a uniform method of addressing activities at the Comed station The inspectors interviewed the station manager and the regulatory assurance supervisor. Almost all sanior station managers were involved in peer groups and dedicate from one to two days per month working on peer group issues. Peer group efforts resulted in the development of 28 nuclear station procedures,10 of which have been implemente Commitment 95: "We are also taking special measures to assess and monitor our performance to ensure that areas of weakness indicated by the I.aSalle and Zion operational events are not present or are addressed at all of our nuclear stations."

The licensee's response stated there would be three methods used to monitor operations performance. The first was the use of performance indicators in addition to the ones reported to the NRC. Examples included wrong unit /wmng train events, control room caution tags, and lit annunciators. The second was an

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evaluation of the control room by the nuclear support group vice president. Third was an evaluation of the control room by a team of peers from Byron, Dresden, Quad Cities, and Braidwoo The inspectors reviewed the performance indicators, the visit report from the vice president, and the peer team report. The performance indicators demonstrated that Braidwood had a greater number of OOS errors and wrong unit / train / component events for 1997 than the other Comed stations. The licensee initiateo self-assessments in those areas because of these perfonnance indicators. The licensee, in addition to the single vice president visit, has had visits from other station and corporate vice presidents to observe control room performance. The shift operations supe visor stated that these visits occur on a near weekly frequency. An operations department policy memorandum to -

formalize how often control board panel walkdowns should occur was changed as a result of these visits. Licensee management took several actions based on the results of the peer visit comments. For example, all operations department personnel were required to watch a video tape of the NRC augmented inspection team exit and some operations department personnel attended training specifically on the Zion even Conclusion The inspector s concluded that the licensee met commitments regarding peer group implementation and actions to be taken to monitor operations performanc '

Commitments 68,69, and 95 are close ]

I 11. Maintenance M1 Conduct of Maintenance Mti Surveillance Observation (61726)

!' Inspection Scope The inspectors observed the performance of all or parts of the following surveillance tests. The inspectors also reviewed plant equipment and surveillance testing activities I against the UFSAR descriptions and the TS * 2BwVS 5.2.f.3-2, "ASME (American Society of Mechanical Engi:wers]

Surveillance Requirements for Residual Heat Removal Pump 2RH01PB,"

Revision 4E1;

• 2BwoS 3.2.1-3, " Unit Two Under voltage Simulated Start of the 2A Auxiliary Feedwater Pump Monthly Surveillance", Revision OE1; a BwOS 6.1.7.3-1, " Primary Contain fype C Local Leak Rate Tests of Containment Purge Supply isolation Va!ves (VG)," Revision OE1;

- 2BwOS3.2.1-941, " Unit Two Quartetty Slave Relay Surveillance (Train A - K520 and 633)", Revision 2E2;

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2BwoS 3.2.1-802, " Unit Two ESFAS (Emergency Safety Features Actuation System) Instrumentation Slave Relay Surveillance (Train A Automatic Safety injection - K804)", Revision E1; and

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BwAP 100-12," Human Performance Awareness of Pre-Job Briefing / Meetings and Self-Checking". Revision Observations and Findinos The inspectors observed pre-job briefings for the surveillance tests which included job scope, purpose, individual responsibilities, safety hazards, As-Low-As-Reasonabl Achievable (Al. ARA) standards, communication of expectations, contingency actions, human error traps, acceptance criteria, and lessons leamed from previous surveillance tests. Emphasis was placed on self-checkin Conclusion

During surveillance testing, operations personnel and the involved system engineer were l knowledgeable of system operation, testing setup, and testing methods. Operators identified and resolved potential problems between plant configuration and procedural guidance prior to starting the test. Surveil;ance tests were performed in accordance with plant procedures and all acceptance criteria were me M3 Maintenance Procedures and Documentation M3.1 Unit 2 Essential Service Water System Walkdown Inspection scope (61726)

As part of a detailed walkdown of the accessable portions of the Unit 2 SX system, the inspectors performed a review of the following completed surveillance test procedures:

• Braidwood Updated Final Safety Analysis Report (UFSAR), Section 9.2.1.2;

• 2BwOS 0.5.SX.1, "American Society of Mechanical Engineers (ASME)

Requirements for Essential Service Water Valves," Revision 2 (Completed 1/21/98);

• 2BuCS 0.5.SX.3, " Unit 2 Essential Service Water Valve Indication 18 Month Surveillance," Revision OE1 (Completed 11/22/97);

• 2BwCS SX - Q1, " Unit 2 Essential Service Water System Manual Ball Valve Cycle Quarterty Surveillance," Revision 1E1 (Completed 10/13/97 and 12/26/97); i

+ 2BwVS 0 5-3.SX.1-1, "ASME Surveillance Requirements for 2A Essential Service Water Pump," Revision 1E1 (Complete 10/10/97 and 12/19/97);

• 2BwVS 0.5 3.SX.1-2, "ASME Surveillance Requirements for 28 Essential Service g

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Water Pump," Revision 1E1 (Complete 10/21/97 and 1/5/98);

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ASME Pump Trending Data for the 2A and 2B Essential Service Water Pumps (4th Quarter 1995 Through 3rd Quarter 1997);

ASME Valve Trondmg Data for 2SX005,2SX016A and B,2SX027A and B, 2SX112A and B, 2SX114A and B,2SX169A and B,2SX173, and 2SX178 (1st Quarter 1996 Through 3rd Quarter 1997); and

. BwAP 100-18. " Braidwood Station Independent Verification Procedure,"

Revision b. Observations and Findinas The inspectors reviewed completed surveillance test procedures and ASME pump and valve performance data. The inspectors noted that all the surveillance test procedures reviewed were complete and were being performed at the proper frequency, and that the licensee was property documenting that the system acceptance criteria were being satisfied. Step E.1.d, of BwAP 100-18, Revision 3, states, in part, that independent verifications of proper system alignment shall be required during the performance of safety-related surveillance tests in which valves are repositioned. However, on February 26, the inspectors identified that Step F.1.4 of 2BwVS 0.5-3.SX.1-1 and 2BwVS 0.5-3.SX.1-2 directed operators to stroke 2SX2179NB, the isolation valves for the 2N2B SX pump lube oil cooler, and 2SX2180NB, the isolation valves to the cooling water inlet tc the 2NB SX pump lube oil heat exchanger; and that Step F.1.7 of 2BwVS 0.5-3.SX.1-1 and 2BwVS 0.5-3.SX.1-2 directed operators to close 2SXO46NB,2N2B SX room a lube oil cooler heat exchanger outlet valves; but failed to stirect operators to perform the required independent verificatio The licensee issued Problem identification Form # A-1998-00756 to document the  !

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problem and initiate corrective actions. As part of the detailed walkdown, the inspectors verified that the valves were in their correct positio Technical Specification 6.8.1.a states, in part, that written procedures shall be .

established, implemented, and maintained covering the applicable procedures )

recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 197 I Regulatory Guide 1.33, Appendix A, Section 1.c, states that thors shall be administrative procedures for equipment control of safety-related systems, the failure to follow BwAP 100-18, Revision 3, was a violation of TS 6.8.1.a. as described in the attached NOV (50-456/98002-02(DRP); 50-457/98002-02(DRP)).

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Technical Specific 4;on and American Society of Mechanical Engineers surveillance l requirements for the essential service water system were being met by the performance of surveillance tests. However, the inspectors identified that safety-related valves were manipulated during the performance of Unit 1 and Unit 2 Technical Staff Surveillance tests and independent verifications of proper system alignment were not subsequently conducted as required by Braidwood Administrative Procedure 10018. A violation was issue .

M8 Follow up Maintenance (92902)

M8.1 (Open) Violation 50-456/97022-02(DRP): 50-457/97022-02(DRP): This violation was issued in inspection Report No. 97022 for the failure to follow procedures regarding the ;

control of access to maintenance and test equipment. The inspectors reviewed problem identification form (PlF) A1998-00587 and interviewed the maintenance staff superviso i in response to the violation, the licensee formed a team of station employees to address i the licensee's need to better control maintenance and test equipment. Braidwood l Administrative Procedure (BwAP) 400-4, " Control of Portable Measurement and Test Equipment," Revision 10E1, requimd that when test equipment was sent offsite to be 1 calibrated and was found to be out-of-tolerance, an evaluation of the system or l equipment that was measured or tested with the out-of-tolerance test equipment, was to ,

be performed. In accordance with SWAP 400-4, the evaluation at the discretion of the i station maintenance and test equipment coordinator and had 90 days after that to i complete it. The team identified that there was a backlog of about 75 evaluations '

needing to be completed. The entire backlog of evaluations was addressed and i completed by February 13. Some field instruments had to be rechecked, but none were i found to be out-of-calibration. The licensee planned to change the evaluation process to shorten the time requirement for conducting the evaluation, but this had not been accomplished by the end of the inspection period. This violation will remain open pending completion oflicensee action ;

i M8.2 (Closed) Violation 50-456/95015-03: 457/95015-03(DRP): As a result of an inspection !

conducted from October 1 through November 14,1995, the inspectors identified a violation of requirements contained in BwAP 100-21, " Foreign Material Exclusion, (FME)" l Revision 1.0. the inspectors reviewed the corrective actions taken by the licensee in I response to this violation. The licensee implemented a new corporate procedure, l Nuclear Station Work Procedure (NSWP) A-03, " Foreign Material Exclusion," Revision 0, !

and increased the emphasis on proper FME controls during training. The inspectors also ;

reviewed the FME related problems documented since the licensee completed its l corrective actions for the violation. Although actions taken by the licensee have not !

completely eliminated FME problems, the total number and severity of FME related i problems has decreased and the inspectors have not noted FME problems during rece maintenance related inspections. This violation is close . Ennineerina E3 Engineering Procedures and Documentation  ;

l E Operability Determinations Inspection Scope (37551)  !

The inspectors reviewed the following documents: ,

• Operability Evaluation 97-159, "UFSAR assumes the pressurizer power operated relief valves are manually opened during an inadvertent safety injection";

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- Operability Evaluation 98-005, " reactor coolant svstem leak rate calculatk.a may be non-conservative due to crediting non-reactor coolant system leakage";

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BwAP 33040, " Operability Determinations," Revision SE1; j

19wOS 4.6.2.1.d-1, " Unit One Reactor Coolant System Water inventory l Balarce 72 Hour Surveillance," Revision 15;

Braidwood Updated Final Safety Ar.alysis Report Sections 5.2.5 and 15.5.1; and q

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Braidwood TSs 3.4.6.2 and 3. !

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l Observations and Findanas The inspectors verified that the documentation of the operability evaluations met BwAP 330-10 requirements, that the licensee complied with TSs, and that the assumptions used in the operability evaluations were valid. The inspectors had no l

concems with the licensee's determinations of operability or the proposed correcibe I

! action i Conclusion The inspectors concluded that the two operability determinations regarding the reactor i coolant system leakage calculations and the automatic operation of the pressurize r power operated relief valves reflected good engineering judgement and safety focus.

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E3.2 Review of Plant Modifications Inspection Scope (37551)

The inspectors reviewed the following documents:

E20-0-96-235-1 post-modification test procedure, " Addition of a Fire Damper / Pressure Control Damper Assembly at the Wall Between the Auxiliary j Building and Turbine Building," Revision 0;

• Preferred Metal Technologies, Inc., Test Procedure #1001-LT-1, "Operatienal 1 Testing of Pressure Relief / Fire Damper Assembly," Revision 1; j i

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• BwVS 7.7.d-1, " Auxiliary Building Non-accessible System Filter Plenum Tost," l l Revision 4; and  !

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= 10 CFR 50.59 Safety Evaluation BRW-SE-1998-5 !

The inspectors observed the physical installation of the pressure control and fire damper assembly, observed the operation of the pressure control damper, and obseived control !

room instrumentation measuring the differential pressure between the auxiliary and turbine building ,

I Observations and Findinas l The inspectors reviewed the post-modification test procedure that was used following the !

installation of the pressure control and fire damper assembly. The inspectors noted that 15 )

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the post-modification test procedure was well-written, identified criteria for acceptable performance, and contained a level of detail sufficient to ensure the modification performed as designed. The inspectors observed that all acceptance criteria of the post-modification test were me The inspectors reviewed the 10 CFR 50.5g safety evaluations for the pressure control and fire damper modification. The inspectors determined that the safety evaluation was well-wntion, complete, and prepared in accordance with Nuclear Station Work Procedure A-04, "10 CFR 50.59 Safety Evaluation Process," Revision The inspectors observed the physical installation of the pressure control and fire dampers and did not identify any obstructions or interforance that could prevent the proper operation of the dampers. The inspectors observed operation of the pressure control damper and noted that the damper responded smoothly to changes in air flow between the auxiliary and turbine buildings. The inspectors observed control room instrumentation measuring the differential pressure between the auxiliary and turbine buildings during daily inspections of the control room and noted that the indicated differential pressure

' was consistently maintained within its acceptable rang . Conclusion The inspectors performed a review of post-modification and surveillance testing procedures for a modification that installed a pressure control and fire damper assembly

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between the auxiliary and turbine buildings and concluded that all acceptance criteria

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associated with those procedures were met. The post-modification test procedure was well-wntion and verified that the modification performed as designed. The surveillance test procedure was well-written and verified that TS and Updated Final Safety Analysis l Report requirements for the non-accessible filter ventilation system were satisfied. The l physical installation of modification hardware was not obstructed by adjacent equipmen The inspectors concluded that the pressure control and fire damper assembly property controlled the differential pressure between the auxiliary and turt>ine buildings.

j E7 Follow up -Engineering (92903)

E Enoineerina Reauest and Enoineerina Reauest Overdue Review I

a inspection Scope (92703)

The inspectors reviewed the contents of the engineering request data base.

l l b Observations and Findinos The licensee committed in the March 28,1997, response to the NRC's request for information pursuant to 10 CFR 50.54(f) to report to the NRC the number of high pnority i (A or B and significant with respect to safety, risk or operability) engineering requests and l the number of high priority engineering requests outstanding past the assigned due dat l

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The inspectors reviewed the contents of the engineering request database and noted that there were 461 high pnority work requests. The inspectors observed that 253 of these high prionty engineering requests had no due dates assigned. The inspectors also, identified that there were 134 engineering requests in the database with no oriority j

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identified,37 of which were from 1997 or earlier. The inspectors brought this to licensee management attention and engineering requests were prioritized and due dates were assigned pending availability of resources. None of the engineering requests from 1997, or eartier were prioritized as hig Condusion The inspectors concluded that the licensee was not aware of the 134 engineering requests in its database that had not been prioritized. The inspectors alsc, concluded that 253 high priority engineering requests had no due dates assigned. The 253 high priority engineering requests without due dates assigned made up about 54 percent of the high .

priority bactiog. With this high percentage, the inspectors concluded that the number of high pnonty overdue engineering requests was not a good performance indicator of backlog reduction which was a performance indicator committed to in the licensee's March 28,1997, response to the NRC's request for information pursuant to 10 CFR 50.54(f).

IV, Plant Support R1 Radiological Protection and Chemistry (RP&C) Controla R Scent Rosin Transfers Inspection Scope (71750)

The inspectors attended the ALARA and the heightened level of awareness (HLA)

briefings for the transfer of resin from the boric acid system's boron recycle evaporator feed domineralizer OAB01DA, the chemical and volume control system's mixed bed domineralizer 1CV01DB, and the fuel pool cooling system's spent fuel pit domineralizer 1FC01D. The inspectors observed radweste tunnel access point radiation protection postings and access controls. The inspectors reviewod the following documentation:

• Braidwood Radiation Protection Procedure (BwRP) 6020 3T9, " Radioactive Spent Resin Transfers," Revision 1;

• BwRP 5310-2, " Control of Access To High Radiation Areas and Very High Radiation Areas," Revision 6;

= BwAP 100-12," Human Performance Awareness of Pre-Job Briefings / Meetings and Self-Checking," Revision 5;

- Radiation Survey of the 383 foot elevation redweste tunnel post-transfer survey map (dated Februry 19,1998); and

• Radiation Protection Policy Memo (RWP) # 16, "Al. ARA Pre-Job Requirements,"

Revision + 17

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. Observations and Findinos On February 19, the inspectors attended the ALARA and the HM briefings for the transfer of resin from three domineralization tanks. The inspectors verified that the ALARA briefing was performed and documented in accordance with Radiation Protection Policy Memo # 16. The inspectors verified that the HlA briefing was performed and documented in accordance with BwAP 100-12. The inspectors verified that the auxiliary building 393 foot elevation access points to the radweste tunnel were locked and posted in accordance with posting requirements specified in BwRP 5310- The inspectors verified that a post-transfer survey of the radweste tunnel was performed and posted. The post-transfer dose rates in the radweste tunnel were slightly elevated when compared to the pre-transfer dose rates at several locations. The inspectors determined that the posting requirements were correct for the radiation levels in the radweste tunnel. The radweste system engineer told the inspectors that plans were being prepared to conduct a more extensive flush of the affected lines to reduce the radwaste tunnel dose rates to pre-transfer level Conclusion The inspectors concluded that the ALARA and HLA briefings for the transfer of resin from three domineralization tanks were propedy performed and documented. All topics specified in Radiation Protection Policy Memo # 16 and BwAP 10012 were discusse The inspectors concluded that the auxiliary building 383 foot elevation access points to the redweste tunnel were property posted and access was prohibited by locked door The inspectors concluded that post-transfer surveys were completed and were poste R2 Status of RP&C Facilities and Equipment R2.1 Radiation Monitors Inspection Scope (71750)

The inspectors routinely monitored the status of radiation monitors stationed in the plan The inspectors also reviewed Procedure BwRP 5800-6, " Administrative Controls for Health Physics instrumentation," Revision 2, and Braidwood Updated Final Safety Analysis Report, Section 12.5, " Health Physics Program." Observations and Findinos The inspectors routinely checked the status of detectors stationed in the auxiliary I building, fuel handling building, radweste building, and technical support center. All I detectors were found to be property calibrated and in good operational conditio ]

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The inspectors also inspected the radiation department calibration facildy located in the l

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auxiliary building on the 401 foot elevation. All instruments in the facility were properly labeled and otherwise controlled. The facility was somewhat cluttered due to the large number of instruments stored there; however, calibrated and ready for use instruments were appropriately segregated from instruments requiring calibration or repai ,

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l l Procedure BwRP 5800 6 requirements for out-of-calibration and defective instruments were appropriatelyimplemente Conclusion l

The radiation protection department's control of radiation monitoring devices was good.

l_ instruments were controlled as required by plant procedure R2.2 Plant Radiation And Postina of Notices to Workers InspectK>n Scope (71750)

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The inspectors monitored posting and labeling of radiologically controlled areas. The I i inspectors also checked licensee postings required by 10 CFR 1g.11, " Posting of Notices L to Workers." The inspectors also reviewed Procedures BwRP 501G-1, " Radiological i Posting and Labeling Requirements," Revision 7E1; BwRP 6020-2, " Radiological Air

! Sampling Program," Revision 3E1; and BwRP 6020-3, " Radiological Surveys,"

Pevision 7, against the references of 10 CFR 2 l Conclusion

, The inspectors concluded that the radiation protection department's control of radiation !

l postings was good. Postings were controlled in accordance with plant procedures and

10 CFR 20. Survey maps for radiologically posted areas in the auxiliary building, fuel

! handling building, and radweste building were current. The inspectors conduded that the licensee was in compliance with 10 CFR ig.11 posting requirement l F1 Control of Fire Protection Activities F Messed Fire Watch Inspection Scope (71750)

The inspectors reviewed the compensatory measures in place for the unavailability of the l cart >on dioxide fire suppression system. The inspectors toured the areas and interviewed j the fire marshal and an individual posted as a fire watch. The inspectors reviewed i BwAP 1100-13, " Fire Watch inspection," Revision 6; BwAP 1100-1, " Fire Protection

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Program," Revision 3; and BwAP 1110-1 A4, " Carbon Dioxide Fire Suppression Systems,"

Revision Observations and Findanas The inspectors venfied continuous fire watches were posted in the Unit 1 and 2 lower cable spreading rooms and at the Unit 1 and 2 cable tunnels, and that houriy fire watches were established in the emergency diesel generator and the diesel-driven auxiliary feedwater pump rooms as required by BwAP 1110-1 A4 due to the unavailability of the carbon dioxide fire suppression syste The inspectors toured the Unit 1 lower cable spreading room area 1Z with the fire marshal. Area 1Z was divided into two separate rooms,1Z1 and 1Z2. The inspectors I

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observed that a continuous fire watch was seated in Room 1Z2 and that no one was posted in Room 1Z1. The inspectors later verified that one person can act as a continuous fire watch between two rooms as long as the rooms were easily accessible to one another and the other room was visited at least every 15 minutes with a margin of five minutes in accordance with BwAP 1100-13. However, the inspectors spoke with the fire marshalin Room 1Z1 for a period of about 40 minutes and observed that the fire watch did not enter the room. The individual assigned as the fire watch told the inspectors that he did not understand that he was supposed to also act as a fire watch in Room 1Z1 and did not enter Room 1Z1 for the entire hour he was posted in Room 1Z The inspectors noted that it was the third time that individual was assigned as the fire watch for that post on January 2 The inspectors reviewed the fire watch post orders. The post orders stated that the location of the continuous fire watch was the Unit i lower cable spreading room but did not specsfy that the lower cable spruding room was made up of Subzones 1Z1 and 1Z The post orders stated that the fire watches were to document the inspection by using a bar code scanner in the area to be inspected. If the scanner failed to work, the 15 minute inspection was to be documented in the fire watch log. The inspectors noted that fire watch supervisors had reviewed the fire watch log, but the fact that Room 1Z1 had not been entered could not be determined by reviewing the fire watch log because the inspections had not been documented. The inspectors questioned the lead fire watch supervisor about the post order requirement to log the inspections every 15 minutes. The supervisor stated that the documentation of the 15 minute inspection was no longer require The failure to follow Procedure BwAP 1110-13 to establish a continuous fire watch in the Unit i lower cable spreading room wits the station carbon dioxide suppression system OOS was a violation of TS 6.8.1.g as described in the attached NOV (456/98002-03(DRP)).

c Conclusion The inspectors concluded that the continuous fire watch requirement for the Unit i lower cable spreading room was not met at least three times on January 29. The inspectors concluded that the fire watch was not adequately supervised because the instructions to the individual assigned to the fire watch were unclear, the stated post-order requirements were not enforced, and supervisory review of the watch documentation as well as, observation of the fire watch did not identify,these problems. A violation was issue F8 Follow up Plant Support (Fire Protection) (92904)

F (Closed) Violation 50-456/93022-01a(DRS): 50-457/93022-01a(DRS): The licensee failed to take timely corrective actions for an impaired fire door between the auxiliary building and the turbine building. The door was a rated fire protection barrier between safety and 1 non-safety-related areas of the plant. When high differential pressure problems between the turbine building and the auxiliary building were experienced, plant staff blocked the door open to allow air to flow between the two areas to partially equalize the air pressur The licensee allowed this impairment to exist since March 1991. On January 20,1998, the licensee completed long-term corrective actions with the installation of a pressure control and fire damper assembly between the turbine and auxilistv buildin . . .

The inspectors reviewed the post-modification testing of the pressure control and fire damper assembly, observed operation of the pressure control damper, and verified the impaired fire door between the auxiliary building and the turbine building was close The inspectors had no further concems. This item is close F8.2 (Closed) Unresolved item 50-456/96016-06(DRS): 50 457/96016-06(DRS): The inspectors noted that the fire door between the auxiliary building and the turbine building was open (a condition documented in Violation 50-456/93022-1a; 50-457/93022-1a), but a permanent watch had been assigned to the blocked open door. The licensee stated that the watch was stationed as a compensatory measure for a licensee identified high energy line break concem. The watch was assigned to close the door during a high energy line break in the turbine building. The inspectors were excomed about the high energy line break watch's ability to close the impaired door during a high energy line break event. On January 20,1998, the licensee completed long-term corrective actions with the installation of a pressure control and fire dan per assembly between the turbine and auxiliary building. The inspectors reviewed the post-moddication testing of the pressure control and fire dampers, observed operation of the pressure control damper, and verified the impaired fire door between the auxiliary building and the turbine building was closed. The inspectors hed no further concems. This item is close V Mananoment Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on March 9,1998. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie .

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PARTlM. LIST OF PERSONS CONTACTED pcensee

• T. Tulon, Site Vice President K. Schwartz, Station Manager

• R. Wegner. Operations Manager

• R. Byers, Ma'.ntenance Superintendent l *A. Haeger, Heelth Physics and Chemistry Supervisor l R. Graham, Work Control Superintendent l *T. Simpkin, Regulatory Assurance Supervisor

• C. Dunn, System Engineering Supervisor

• J. Meister, Engineering Manager

• M. Riegel, Q&SA Manager

• M. Cassidy, Regulatory Assurance - NRC Coordinator d.RQ M. Jordan, Chief, Reactor Projects Branch 3 C. Phillips, Senior Resident inspector

• J. Adams, Resident inspector D. Pelton, Resident inspector IDI$E T. Esper

• Denotes those who attended the exit interview conducted on March 9,1998. ..

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INSPECTION PROCEDURES USED IP 37551: Onsite Engineering IP 61726: Surveillance Observations IP 62707: Maintenance Observation IP 71707: Plant Operations IP 71750: Plant Support Activities IP 92901: Follow up - Plant Operations IP 92902: Follow up- Plant Maintenance IP 92903: Follow up - Engineering l IP 92904: Follow up - Plant Support

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ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-457/98002-01 NCV Failure comply with TS 50-456/98002-02; 50-457/98002-02 VIO Failure to follow procedures l 50-456/98002-03 VIO Failure to follow procedures Closed 50-456/93022-01a; 50-457/93022-01a VIO Failure to take corrective actions i

50-456/95015-03; 50-457/95015-03 VIO Failure to follow procedures

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50-456/96016-06; 50-457/96016-06 URI High energy line break compensatory action concems Discussed l

50-456/97022-02; 50-457/97022-02 VIO Failure to follow procedures

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LIST OF ACRONYMS USED Al. ARA As Low As Reasonably Achievable ASME American Society of Mechanical Engineers BwAP Braidwood Administrative Control Procedure BwGP Braidwood General Operating Procedure BwOP Braidwood Operating Procedure BwOS Braidwood Operations Surveillance Procedure BwRP Braidwood Radiation Protection Proc * dure l BwVS Braidwood Technical Staff Surveillance Procedure CFR Code of Federal Regulations CV Chemical and Volume Control System ESFAS Emergency Safety Feature Actuation System FME Foreign Material Exclusion H Heightened Level of Awareness LCO Limiting Condition for Operation NCV Non-Cited Violation NRC Nuclear Regulatory Commission NRR Nuclear Reactor Regulations NSO Nuclear Station Operator l OOS Out-of-Service

! P&lD Piping and instrumentation Diagram

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pcm percent millirho PDR Public Document Room l PIF Problem Identification Form i RCS Reactor Coolant Sy., tem RHR Residual Heat Removal RP Radiation Protection RP&C Radiological Protection & Chemistry SX Essential Service Water ( TS Technical Specification l UFSAR Updated Final Safety Analysis Report

! URI Unresolved item l US Unit Supervisor VIO Violation l VQ Primary Containment Purge l

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