IR 05000456/2010006
| ML103000130 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/27/2010 |
| From: | Duncan E R Region 3 Branch 3 |
| To: | Pacilio M J Exelon Generation Co, Exelon Nuclear |
| References | |
| IR-10-006 | |
| Download: ML103000130 (37) | |
Text
October 27, 2010
Mr. Michael Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO), Exelon Nuclear
4300 Winfield Road
Warrenville IL 60555
SUBJECT: BRAIDWOOD STATION, UNITS 1 AND 2, NRC BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000456/2010006; 0500457/2010006
Dear Mr. Pacilio:
On September 17, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Braidwood Station, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on September 17, 2010, with Mr. L. Coyle and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission
=s rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
On the basis of the samples selected for review, the team concluded that in general, problems were properly identified, evaluated, and corrected. There were two NRC-identified findings of very low safety significance associated with the failure to evaluate auxiliary feedwater system operability and failure to take timely corrective actions to perform a necessary piping analysis.
The findings were determined to be violations of NRC requirements. However, because of their very low safety significance, and because the issues were entered into your corrective action program, the NRC is treating the issues as Non-Ci ted Violations (NCVs) in accordance with Section 2.3.2 of the NRC Enforcement Policy. In addition, several examples of minor problems were identified, including untimely issue report evaluations, and untimely corrective actions. If you contest the subject or severity of a NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U. S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Braidwood Station. In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at the Braidwood Station. The information you provide will be considered in accordance with Inspection Manual Chapter 0305.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC=s document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA/
Eric R. Duncan, Chief
Branch 3 Division of Reactor Projects Docket Nos. 50-456; 50-457 License Nos. NPF-72; NPF-77
Enclosure:
Inspection Report No. 05000456/2010006 and 05000457/2010006
w/Attachment:
Supplemental Information cc w/encl: Distribution via ListServ
Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION III Docket Nos: 50-456; 50-457 License Nos: NPF-72; NPF-77 Report Nos: 05000456/2010006 and 05000457/2010006 Licensee: Exelon Generation Company, LLC Facility: Braidwood Station, Units 1 and 2 Location: Braceville, IL Dates: August 30, 2010, through September 17, 2010 Team Leader: R. Ng, Project Engineer Inspectors: J. Benjamin, Senior Resident Inspector, Braidwood J. Gilliam, Reactor Inspector L. Jones, Reactor Inspector A. Scarbeary, Reactor Engineer M. Perry, Resident Inspector, Illinois Emergency Management Agency
Approved by: E. Duncan, Chief Branch 3 Division of Reactor Projects
Enclosure
SUMMARY OF FINDINGS
IR 05000456/2010006; 05000457/2010006; 08/30/2010 - 09/17/2010; Braidwood Station, Units 1 and 2; Identification and Resolution of Problems.
This inspection was conducted with region-based inspectors, the NRC Senior Resident Inspector at the Braidwood Station, and the onsite Illinois Emergency Management Agency inspector. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006. Identification and Resolution of Problems The inspectors concluded that the licensee's Corrective Action Program (CAP) in general was effective in identifying, evaluating, and correcting issues at the site. The licensee had a low threshold for identifying issues and entering them into the CAP. Overall, the issues were properly prioritized and evaluated based on plant risk and uncertainty. Corrective actions, when specified, were generally implemented in a timely manner, commensurate with their safety significances. The use of operating experience was integrated into daily activities and was found to be effective in preventing industry identified issues from occurring at the site. In addition, the licensee's self-assessments, audits, and effectiveness reviews were thorough and effective in identifying site performance deficiencies, programmatic concerns, and improvement opportunities. On the basis of the interviews conducted, site personnel were free to raise safety concerns through the established processes. There were two Green findings with the associated Non-Cited Violations (NCVs) identified by the team during this inspection. The findings were related to the licensee's failure to perform an operability determination per procedure for a condition adverse to quality and to perform timely corrective actions for a previously identified violation.
A. NRC-Identified
and Self-Revealed Findings
Cornerstone: Mitigating Systems, Barrier Integrity
Green: The inspectors identified a Green finding and an associated NCV of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," when licensee personnel failed to adhere to Operability Determination Procedure OP-AA-108-115 after identifying a potential auxiliary feedwater (AFW)system design vulnerability. Specifically, since May 15, 2007, the licensee had questioned the motor-driven AFW system's capability to effectively transfer its water source from the Condensate Storage Tank (CST) to the essential service water system during a hypothetical catastrophic failure of the non-seismic CST. The lack of involvement in bringing this issue to the attention of the operating crew, lack of quality in evaluating the issue, and length of time the questions had been unanswered were not consistent with the Operability Determination process. The licensee entered this issue into their CAP as Issue Report (IR) 1114604. Corrective actions planned included performing an Operability Evaluation and a corrective action assignment to ensure a rigorous evaluation was performed on the motor-driven AFW pump's motor and breaker.
The inspectors determined that this issue was more than minor in accordance with IMC 0612, Appendix B, "Issue Screening," because the issue was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the AFW pum p operability was not fully evaluated by the licensee. The finding was of very low safety significance because the issue was not a confirmed loss of operability and did not represent a risk significant issue based on the plant's design backup capability to remove decay heat via the primary feed and bleed method. This finding had a cross-cutting aspect in the area of Human Performance for Decision-Making (H.1(a)). Specifically, the licensee did not make a safety-significant or risk-significant decision using the Operability Evaluation systematic process, especially when faced with uncertain or unexpected plant conditions involving a potential design vulnerability to the plant to ensure safety was maintained. (Section 4OA2.1.b.2.c)
Green: The inspectors identified a Green finding and an associated NCV of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," when licensee personnel failed to promptly correct a previously identified NCV regarding the lack of analysis for water hammer loads on the Recycle Holdup Tank (RHUT) inlet piping induced by Residual Heat Removal (RHR) system relie f valve discharges. Specifically, the licensee failed to complete the necessary piping analysis to address potential water hammer effects since the issue was initially identified in June 2007 and documented as a NCV in February 2009. The licensee entered this issue into the CAP as IR 1117296 and planned to accelerate the completion schedule for the analysis. The finding was more than minor because it was associated with the design control attribute of the Barrier Integrity Cornerstone and affected the cornerstone objective of maintaining the radiological barrier function of the containment. The finding was of very low safety significance because it did not represent an actual open pathway from containment. This finding has a cross-cutting aspect in the area of Human Performance for Resources (H.2(a)) because the licensee failed to maintain long-term plant safety by completing the necessary piping load calculations in a timely manner. (Section 4OA2.1.b.3.b)
B. Licensee-Identified Violations
None.
REPORT DETAILS
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152. Documents reviewed are listed in the to this report.
.1 Assessment of Corrective Action Program Effectiveness
a. Inspection Scope
The inspectors reviewed the procedures and processes that described Exelon's Corrective Action Program (CAP) at Braidwood Station to ensure, in part, that the station had an adequate program for meeting 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," requirements. The inspectors observed and evaluated the effectiveness of CAP meetings such as Station Ownership Committee (SOC) and Management Review Committee (MRC) meetings. Selected licensee personnel were interviewed to determine their understanding and their involvement in the CAP. The inspectors reviewed selected issue reports (IRs) across all seven cornerstones of safety to determine if problems were being properly identified and entered into the CAP.
A risk-informed sample of IRs, originated since the last NRC Biennial Problem Identification and Resolution (PI&R) inspection conducted in October of 2008, was reviewed by the inspectors. The inspectors also reviewed selected issues that were
more than 5 years old. The inspectors assessed the licensee's characterization and evaluation of the issues and examined the assigned corrective actions. This review encompassed the full range of safety significances and evaluation classes such as root cause evaluations, apparent cause evaluations (ACEs), and workgroup evaluations. The inspectors assessed the scope and depth of the licensee's evaluations. For significant conditions adverse to quality, the inspectors evaluated the licensee's corrective actions to prevent recurrence and for lower safety significance issues, the inspectors reviewed the corrective actions to determine if they were implemented in a timely manner commensurate with their safety significances. The inspectors reviewed the Technical Support Center (TSC) diesel generator in detail since the generator is nonsafety-related equipment that provides backup power to equipment for planned and emergency events. The inspectors also reviewed the maintenance issues associated with the Auxiliary Building ventilation fans as one of the exhaust fans was destroyed in a fire in early 2010 that resulted in a declaration of a Notice of Unusual Event. These reviews were performed to determine whether the licensee was properly monitoring and evaluating the performance of the system through effective implementation of station monitoring programs. The inspectors interviewed the system engineers of the applicable systems, reviewed numerous IRs, and reviewed 4 Enclosure evaluations. A 5-year review of the maintenance backlog was undertaken to assess the licensee's efforts to address long-standing maintenance issues. The inspectors reviewed the licensee's CAP program and independently performed a 5-year review of the human performance trend to determine if issues were tracked to identify adverse trends or repetitive issues.
The inspectors examined the results of the two self-assessments of the CAP completed during the review period. The results of the self-assessments were compared to the self-revealed and NRC-identified findings. The inspectors also reviewed the corrective actions associated with previously identified NCVs and findings to determine whether the station properly evaluated and resolved those issues. The inspectors performed walkdowns to verify the resolution of the issues. The inspectors also performed a review of the issues identified in the licensee's corporate corrective action program to determine if issues were identified at the corporate level that could affect the Exelon sites, if those issues were prioritized and evaluated according to their safety significances and if corrective actions were assigned and carried out when appropriate. b. Assessment
- (1) Identification of Issues The inspectors concluded that, in general, the station continued to identify issues at a low threshold by entering them into the CAP. The inspectors determined that the station was appropriately screening issues from both NRC and industry operating experience (OE) at an appropriate level and entering them into the CAP when applicable to the station. The inspectors also noted that deficiencies were identified by external organizations (including the NRC) that had not been previously identified by licensee personnel. Issues were also identified at the corporate level at a low threshold and were entered into the CAP for actions. The inspectors determined that the station was generally effective at trending low level issues to prevent larger issues from developing. The licensee also used the CAP to document instances where previous correct ive actions were ineffective or were inappropriately closed.
Observations
- a. Human Performance Related Trend The inspectors reviewed the station's trend in human performance within the last 5 years. Overall, the inspectors did not identify any particular trend in Human Performance in any particular department or area, with the exception of the comprehensive improvements recognized in the NRC's "conservative decision-making" safety culture performance aspect documented in NRC Integrated Inspection Report 05000456/457/2010003. The inspectors determined, that in general, the programs that provided multiple barriers to potential human performance errors were 5 Enclosure adequate, if followed, and the station's CAP was generally good at identifying methods to enhance performance. b. Procedural Compliance for the Condensate Polisher Spill Event On June 30, 2009, the Operations department was performing an evolution to rinse a Condensate Polisher (CP) demineralizer after a resin change. Once the rinse was initiated, the CP low conductivity sump level high annunciator alarmed. The operator verified the sump pump was running and the level in the sump was maintaining a steady level at approximately 3 feet below floor level. The operator discussed the condition with the field supervisor and left the area to perform other duties. About an hour later, the field supervisor went to the room to check on the evolution and discovered that the sump had overflowed and water was spilled outside to the ground. The field supervisor terminated the evolution and the sump level immediately began to drop. Immediately actions were taken to contain the spread of water released offsite. The licensee later estimated that about 1000 to 3800 gallons of water were released to the storm sewer system. The tritium concentration of the water was sampled to be 270 picocurie per Liter (pCi/L), which was below the Environment Protection Agency's drinking water limit of 20000 pCi/L. Although not required, the licensee notified members of the Illinois Emergency Management Agency, the Illinois Environment Protection Agency, several Will County Board members, and the Mayor of Braidwood and Godley as well as the NRC about the spill. The licensee performed a quick human performance investigation (QHPI) and ACE and identified several procedural and human performance issues including not requiring continuous monitoring of the evolution when an alarm condition existed. Corrective actions were taken to correct these issues. The inspectors reviewed the corrective action documents and the annunciator response procedure in effect at the time and determined that the licensee did not perform all the required actions prescribed in the annunciator response procedure. Specifically, after the low conductivity sump high level alarm was actuated, the operator, per procedure, was supposed to stop the evolution if the sump level did not decrease. Based on the QHPI and the ACE, the operator only verified that the level was maintaining steady before attending other duties. Since the level was not decreasing, the evolution should have been stopped, which could have prevented the spill from occurring. This procedure violation was not identified in the licensee's investigations. Because a regulatory limit was not exceeded for offsite release, this failure to comply with procedures constitutes a violation of minor significance that is not subject to enforcement
action in accordance with the NRC's Enforcement Policy.
- (2) Prioritization and Evaluation of Issues The inspectors concluded that the station was generally effective at prioritizing and evaluating issues commensurate with the safety significance of the identified problem.
The inspectors determined that the SOC and MRC CAP review meetings were generally thorough and maintained a high standard for approving action.
6 Enclosure The inspectors determined that issues were tracked to identify adverse trends and actions assigned to correct repetitive issues when applicable. The inspectors reviewed selected issues in the maintenance backlog and the CAP. The inspectors determined that the licensee was generally effective at evaluating equipment functionality requirements after a degraded or non-conforming issue was identified and prioritized the corrective action commensurate with its safety significance. The inspectors also determined that issues in the corporate CAP were prioritized and evaluated per the established CAP process.
The inspectors noted that several issues related to the sequential unit reactor trip in August 2010 had problem identification and resolution implications. However, the inspectors did not review those issues because the licensee had not completed the evaluations and a NRC special inspection was ongoi ng at the time of this inspection.
Based on the samples selected for this inspection, the inspectors identified several issues that could be evaluated in a more timely manner.
Observation
- a. Technical Support Center Diesel Generator
In April of 2010, Nuclear Oversight (NOS) identified that no evaluation was completed when the Technical Support Center (TSC) diesel generator failed its loaded run surveillance test (0BwOS-IS-Q1) in January 2010. Specifically, the diesel generator did not meet its acceptance criterion for the motor starting battery minimum voltage. An engineering evaluation was performed to investigate the origin of the minimum voltage acceptance criterion and evaluate if failing to meet the criterion would actually cause the diesel generator not to start when required. The licensee concluded that the criterion in the procedure was enveloped by industry and vendor standards, and as such, could be left as-is. However, the specific bases of the acceptance criterion were not known. Since failing to meet the battery acceptance criterion would indicate potential degradation, a step was added to the procedure for an IR to be initiated if the voltage was too low so that engineering could evaluate the functional level of the diesel
generator.
The inspectors performed an historical search into this issue and found that the diesel generator had failed its surveillance multiple times in the past 7 years for not meeting the minimum battery voltage acceptance criterion. The inspectors determined that the identification of these surveillance failures was not promptly entered into the CAP. Also, the evaluation of this issue identified by NOS did not contain the appropriate technical rigor of a typical engineering evaluation in that it did not thoroughly probe into the engineering design bases of the battery and did not illustrate an understanding of why the acceptance criterion was the value that was being used in the surveillance procedure. Since the TSC diesel generator was able to start and load onto the bus when it failed the surveillance, the diesel generator was considered functional.
The inspectors also discovered that there were no supporting design basis documents for the TSC diesel generator itself. The function of the diesel was to provide an uninterrupted back-up power supply for the 033W3 bus, which supplied the TSC and other nonsafety-related but regulatory required loads, under loss of normal power 7 Enclosure conditions. For example, the surveillance procedure provided a run-time criterion of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for the diesel generator. However, there was no supporting documentation that provided the basis for a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> run-time in a loss of power scenario. The inadequate documentation of the basis for the acceptance criterion and the design of the diesel generators called into question the long-term reliability of the diesel generator to perform its intended function. After NRC questions from this inspection, IR 1112604 was written to have engineering review the classification and design documentation for the TSC diesel generator. This issue was not a performance deficiency because there were no requirements to document the bases for the TSC diesel generator and the diesel generator was capable to start and provide power to the 033W3 bus.
b. Emergency Diesel Generator Temperature Switches Since January of 2009, there were multiple IRs written by engineering for the Emergency Diesel Generator Lube Oil Heater and Jacket Water Heater temperature switches not maintaining the desired temperature bands or functioning as intended. The purpose of these temperature switches was to maintain a temperature band of 120 to 130 degrees Fahrenheit for the oil in the lube oil system and water in the jacket water system of the emergency diesel generators. This maintained the emergency diesel generators in a condition that allows them to start within the Technical Specification (TS) required time and perform their intended safety function of providing power in case of an emergency. These switches normally operated in automatic and are not needed when the diesel generator is running.
All these issues occurred after seven of the eight switches were replaced by a new model switch due to the old model becoming obsolete. While the issues were promptly identified, the CAP process of evaluating t he issue and implementing effective corrective actions was not completed in a timely manner. Even though the issues were first identified in early 2009, Engineering was still evaluating the cause of the issues. In the meantime, the switches were being operated in manual mode, and controlled by operators in the field when they were completing their daily rounds. The licensee started these manual compensatory actions in September of 2009. An IR was written in June of 2010 to evaluate these manual compensatory actions as operator burdens. The inspectors determined that the evaluations and corrective actions for these conditions adverse to quality were untimely and the licensee was not appropriately addressing the significance of these problems. The inspectors determined that the diesel generators could still perform their intended functions since the temperatures of the lube oil and jacket water were being maintained within the Updated Final Safety Analysis Report (UFSAR) limits. Therefore this issue constituted a minor violation of NRC requirements that is not subject to enf orcement action in accordance with the NRC's Enforcement Policy. The licensee acknowledged that the evaluation and
corrective actions should have been completed in a more timely manner for this risk-significant system. c. Failure to Follow the Operability Determination Process
Introduction:
The inspectors identified a Green finding and an associated Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," when licensee personnel failed to follow the station's Operability 8 Enclosure Determination procedure after identifying a potential Auxiliary Feedwarter (AFW) system design vulnerability. Specifically, since May 15, 2007, the licensee had questioned the motor-driven AFW pump's capability to effectively swap its water source from the condensate storage tank (CST) to the essential service water system during a hypothetical catastrophic failure of the non-seismic CST. The lack of involvement in bringing this issue to the attention of the operating crew, lack of quality in evaluating the issue, and length of time the questions had been unanswered were not consistent with the standards imposed in the station's Operability Determination process. The licensee entered this issue into their corrective action program (IR 1114604).
Description:
On May 15, 2007, the licensee identified and documented a concern regarding the Unit 1 and Unit 2 AFW system response time during a design basis loss of offsite power coupled with a hypothetical loss of the CST supply (IR 629903). During this scenario, the Unit 1 and Unit 2 motor-driven AFW pumps received an auto start signal but tripped within 2.5 seconds on low suction pressure provided the CST had failed. The pumps would start again after their breakers reset and supply water to their respective steam generators. The IR appropriately questioned if this delay in AFW response was accounted for in the licensing basis. Assignment #2 from this IR evaluated the issue and concluded that there was no deficient condition and the AFW pumps would deliver water to the steam generators within the period required by the analysis. Assignment #3, from IR 629903, was initiated to evaluate the need to revise the AFW system description in Section 10.4.9 of the UFSAR to address the start of the AFW pump with the CST unavailable and to initiate additional actions if needed. The inspectors determined that this assignment was delayed multiple times from the original due date of August 30, 2007, until the final completion date of July 23, 2010. During this time, an additional concern was identified by the Exelon staff. The new concern was that the AFW motor might cycle on and off as many as four times based on the breaker's 3-second closing spring recharge time. Although the inspectors could not determine the precise date that the new concern was identified, after reviewing the IR's "in progress notes" and talking with the licensee staff and managers, it was clear that this concern was recognized and discussed prior to April 6, 2010. This conclusion was based on an April 6, 2010, vendor response letter provided to Exelon extending an offer to study the effects of four successive starts of the AFW motor based on the recognized possibility that the motor would either trip on over current during one of the successive starts or could overheat due to starting four times in succession. This information was not provided to Operations management. On July 7, 2010, the licensee initiated IR 1088364 that documented the concern for four successive trips of the motor-driven AFW pump during presumed CST failure due to a tornado generated missile. The IR stated that the repeated starts and trips were discussed with a corporate rotating equipment specialist who believed that the four starts could damage the motor windings through overheating. This individual also noted that he could not predict with certainty how the motor or breaker would respond and that vendor support would be needed for an analysis. Furthermore, the individual noted that the short time between trip and restart could result on excessive inrush currents that could cause a trip on overload. This IR documented the actions that the licensee had undertaken prior to the April 6, 2010, vendor response letter.
Exelon Procedure OP-AA-108-115, "Operability Determinations (CM-1)", Revision 9, was a 10 CFR 50, Appendix B, quality procedure. Per that procedure, operability should be determined immediately upon discovery that a structure, system, or component (SSC), subject to TS, was in a degraded or nonconforming condition. This procedure also stated that a prompt determination of SSC operability as a follow up to the immediate determination of SSC operability made by Operations management was warranted when additional information, such as a supporting analysis, was needed to confirm the immediate operability determination. The IR 1088364 provided an immediate operability assessment for the AFW pump motor based on the vendor's engineering judgment. However, it did not provide an immediate operability assessment for the motor-driven AFW pump breaker. For the motor, the IR stated that continued operability was supported based on the vendor's preliminary evaluation that the motor would continue to operate and that any motor degradation would result in minor shortened motor life, but not an immediate failure.
The inspectors reviewed the history of the issue and discussed the issue with both Braidwood management and the engineering staff and identified an inadequate and untimely evaluation. Specifically, the evaluation was untimely from the perspective that from when the original issue was identified to the time provided to obtain a detailed analysis was over 3 years. The evaluation was also inadequate from the perspective that the operability evaluation for the motor was based on a vendor's opinion and not documented engineering judgment that could be reviewed by the inspectors or that was understood by interviewed Braidwood staff. With respect to the breaker, the licensee simply had not assessed and documented its operability. The inspectors identified that the licensee had not considered other credible scenarios in which offsite power would not be available and a CST failure could occur (i.e. a design basis earthquake), did not provide an explanation for why the motor-driven AFW pump versus the diesel-driven AFW pump was considered the credible single failure, and did not evaluate the potential risk to the plant in the case that the equipment was discovered to be inoperable.
Analysis:
The inspectors concluded that the licensee's failure to adequate implement their operability determination process was a performance deficiency. The inspectors determined that this issue was more than minor in accordance with IMC 0612, Appendix B, "Issue Screening", because, the issue was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the AFW pump operability was not fully evaluated by the licensee. The issue was determined to be Green because the issue was not a confirmed loss of operability and did not represent a risk-significant issue based on the plant's design backup capability to remove decay heat via the primary feed and bleed method. This finding has a cross-cutting aspect in the area of Human Performance for Decision-Making. Specifically, the licensee did not make a safety-significant or risk-significant decision using the Operability Evaluation systematic process, especially when faced with uncertain or unexpected plant conditions involving a potential design vulnerability to the plant to ensure safety was maintained (H.1(a)).
Enforcement:
10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," requires in part, that activiti es affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to this, the inspectors identified three examples of a violation of this requirement for the licensee's failure to follow Procedure OP-AA-108-115, "Operability Determinations (CM-1)," Revision 9: Step 4.1.2 requires that if the originator or supervisor identified any potential operability or reportability issues, then the originator or supervisor shall personally contact Operations management of the affected facility/unit and discuss the issue.
However, from April 6, 2010, (or prior) to July 7, 2010, Operations management was not notified of the issue while an engineering review was being conducted to evaluate system operability. Step 4.1.6 requires that operability be determined immediately from a detailed examination of the deficiency upon discovery that a SSC subject to TS is in a degraded or nonconforming condition. In most cases the decision can be made immediately and appropriately documented on the IR. In other cases, the decision shall be made within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> even though complete information may not may available. However, IR 1088364 did not provide an immediate operability determination with the documented concern for how the breaker would respond, as specified by Step 4.1.6. Specifically, the IR documented that a corporate rotating equipment specialist could not predict with certainty how the motor or breaker would respond to the hypothetical four successive starts. The IR further documented that based on preliminary vendor judgment, that the motor would continue to operate and that any motor degradation would result in minor shortened motor lift. Step 4.1.9 states that a prompt determination of SSC operability is a follow up to the immediate determination of SSC operability made by Operations management. The prompt determination is warranted when additional information, such as a supporting analysis, is needed to confirm the immediate determination. If there is a reasonable expectation that the SSC is operable, but a more rigorous evaluation is deemed warranted, then request the appropriate work group to initiate an action tracking item (IR action) to prepare an operability evaluation using the guidance provided in this procedure. From May 15, 2007, to September 24, 2010, the licensee recognized that an additional, supplemental analysis was needed to confirm operability; however, the licensee did not perform an Operability Evaluation using the guidance provided in this procedure when faced with a question that could affect the motor-driven AFW pump's licensed based function during a hypothetical CST failure. The licensee entered this issue into their CAP as IR 1114604. Corrective actions included an assignment to perform an Operability Evaluation on both the AFW pump and breaker, and an assignment to ensure a detailed analysis was performed on the breaker, as was the case for the AFW motor. Because this violation was of very low safety significance, was not repetitive or willful, and it was entered into the licensee's corrective action program, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy.
11 Enclosure (NCV 05000456/2010006-01; 05000457/2010006-01: Failure to Follow the Operability Determination Procedure)
- (3) Effectiveness of Corrective Actions The inspectors concluded that corrective actions for identified deficiencies were generally timely and adequately implemented, commensurate with their safety significances. Problems identified using root or apparent cause methodologies were resolved in accordance with program and NRC requirements. The inspectors determined that the corporate CAP was generally effective in driving corrective actions to completion. When appropriate, corrective actions were assigned to the site for implementation. The inspectors also determined that the station's corrective actions designed to prevent recurrence (CAPRs) were generally comprehensive, thorough, and timely. Although some of the CAPRs were over 500 days old, the inspectors determined that the corrective actions were considered timely as they required an outage for the implementation. The inspectors also concluded that sampled corrective action assignments for selected NRC documented violations were generally effective and timely. However, the inspectors identified a number of untimely corrective actions as described below.
Observations
- a. Untimely Corrective Actions for Auxiliary Building Ventilation Exhaust Fan Failure On May 10, 2007, an IR was written because the Auxiliary Building Ventilation "A" Exhaust Fan (0VA02CA) had elevated vibration indicating degraded bearings. The fan was classified as a non-preferred machine and a work order was created to repair the fan. On July 3, 2008, before the fan could be repaired, it was run to failure and quarantined. The failure was considered by the licensee to be a Maintenance Rule Functional Failure and an Equipment ACE was generated. The licensee made the decision to investigate, disassemble, send out for repair, and reassemble the fan in the same work order with an initial due date of August 4, 2008. The work order due date was later moved to December 1, 2008 because the original due date was close to an outage and there were resource issues. The date was moved a total of six more times because of resource issues and had a due date of November 29, 2010, at the end of this inspection, which was 29 months after the failure.
Since the work order had not been completed, the licensee was in a situation where one of the safety-related exhaust fans had been inoperable for over 2 years and the mode of failure still had not been determined. Since the mode of failure had not been determined, the licensee could not complete the Equipment ACE, the extent of condition, or implement corrective actions.
On January 9, 2010, approximately 19 months after the "A" Exhaust Fan failed, the "C" Supply Fan also failed. The failure also caused the station to declare a Notice of Unusual Event for a small fire from the inboard bearing of the "C" Supply Fan. The licensee was required to have two of four trains available to complete TS surveillances.
12 Enclosure At the end of this inspection, the licensee had two trains available. However, the "B" Exhaust Fan was degraded because of high vibrations.
The untimely repair of the safety-related Auxiliary Building "A" Exhaust Fan was considered to be a performance deficiency. Although these fans were required to complete TS surveillances, they were not required for train operability. Since the licensee met the TS requirements, this performance deficiency was considered minor.
b. Untimely Corrective Action for Lack of Water Hammer Analysis on the Recycle Holdup Tank
Introduction:
The inspections identified a Green finding and associated NCV of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," when the licensee failed to promptly correct a previously identified NCV regarding the lack of analysis for water hammer loads on the Recycle Holdup Tank (RHUT) inlet piping induced by Residual Heat Removal (RHR) system relief valve discharges.
Description:
In February 2009, NCV 05000456/457/2008005-05 was issued when the licensee failed to evaluate and maintain the required water volume necessary to quench the RHR system relief valve discharges into the RHUT and incorporate appropriate minimum RHUT level requirements into the RHUT level control procedure and to evaluate the effect of dynamic water hammer loads on inlet piping from relief valve discharges to the RHUT. This issue was initially identified by the NRC in June 2007 (See NRC Integrated Inspection Repor t 05000456/457/2008005). The licensee entered this issue into their CAP as IRs 649581 and 677075. As part of the corrective actions, the licensee instituted administrative controls to provide an adequate quench volume for the RHUT and initiated an action to perform an analysis to investigate the magnitude of the potential water hammer loads on the inlet piping. The action to obtain a proposal to perform the piping analysis was originally assigned a due date of July 31, 2008. The proposal was obtained and the action was closed. The
actual piping analysis and a detailed evaluation for over-pressurization of the RHUT were tracked under another IR Assignment, IR 677075-09, to revise the accident analysis in the UFSAR for a ruptured RHUT with an initial due date of July 31, 2009. This assignment was documented as a corrective action for a condition adverse to
quality. On February 9, 2009, the NRC issued an NCV related to this issue and the licensee wrote IR 883985 to track the actions to correct the NRC identified violation. The action was subsequently closed to IR 677075-09. On July 30, 2009, the licensee extended the due date for this corrective action item to December 2009 due to coordination required from Byron Station and vendor support. In December 2009, the action was further extended to June 2010 and was downgraded from a corrective action to an action tracking item, which tracked minor problems that did not represent conditions adverse to quality. The reasons for the delay, as documented in the CAP, were emergent engineering priorities and corporate engineering staff re-organization.
13 Enclosure In June 2010, the due date was again extended to September 2010 to perform a more detailed analysis due to a possible need for a system modification. At the end of this inspection, the action was scheduled to be completed in June of 2011. The licensee planned to accelerate the completion schedule of the analysis.
Analysis:
The inspectors determined that the licensee's failure to timely perform the necessary piping analysis to investigate the magnitude of the potential water hammer loads on the inlet piping was a performance deficiency that warranted a significance determination. The inspectors determined the finding was more than minor in accordance with IMC 0612, "Power Reactor Inspection Reports," Appendix B, "Issue Screening," because the finding affected the Barrier Integrity Cornerstone objective for maintaining the Radiological Barrier Function of the Containment. The finding was also associated with the design control attribute of the Barrier Integrity Cornerstone.
Specifically, the licensee's existing design and piping configuration did not address water hammer effects when the RHR relief valves were lined up to discharge to the RHUT that could rupture the piping and potentially affect the offsite dose consequences. The inspectors evaluated the finding using IMC 0609, Attachment 0609.04, "Phase 1 Initial Screening and Characterizations of Findings." The inspectors determined in Tables 2 and 4a of the Attachment that the failure to analyze the RHUT inlet piping loads degraded the Radiological Barrier Function of the containment, but did not represent an actual open pathway from containment. Therefore, the finding was screened as having very low safety significance (Green).
This finding has a cross-cutting aspect in the area of Human Performance for Resources (H.2(a)) because the licensee failed to maintain long-term plant safety by completing the necessary piping load calculations in a timely manner.
Enforcement:
10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," requires in part that measures shall be established to ensure that conditions adverse to quality are promptly identified and corrected. Contrary to the above, as of September 17, 2010, the licensee failed to promptly correct a condition adverse to quality identified in February 2009. Specifically, the licensee failed to complete the piping analysis to address potential water hammer effects when the RHR relief valves were lined up to discharge to the RHUT. Because this violati on was of very low safety significance and because it was entered into the licensee's CAP as IR 1117296, this violation is being treated as a NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000456/2010006-02; 05000457/2010006-02: Untimely Corrective Action for Lack of Water Hammer Analysis on the Recycle Holdup Tank)
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The inspectors reviewed the licensee's implementation of the facility's OE program. Specifically, the inspectors reviewed implementing OE program procedures and completed evaluations of OE issues and events. The inspectors also attended CAP meetings to observe the use of OE information. The inspectors' review was to determine whether the licensee was effectively integrating OE experience into the performance of daily activities, whether evaluations of issues were proper and 14 Enclosure conducted by qualified personnel, whether the licensee's program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of OE experience, were effective and timely implemented. b. Assessment The inspectors concluded that the station appropriately considered industry and NRC OE information for applicability, and used the information for corrective and preventative actions to identify and prevent similar issues. The inspectors assessed that OE was appropriately applied and lessons learned were communicated and incorporated into plant operations. In particular, OE information was discussed during Plan of the Day meetings and also incorporated into the work management process as part of the pre-job briefs. The inspectors also observed that Exelon fleet internal OE and industry OE were discussed by licensee staff to support review activities and CAP investigations.
Findings No findings of significance were identified.
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The inspectors reviewed selected focused area self-assessments, check-in self-assessments, root cause effectiveness reviews, and NOS audits. The inspectors evaluated whether these audits and self-assessments were being effectively managed, were adequately covering the subject areas, and were properly capturing identified issues in the CAP. In addition, the inspectors also interviewed licensee personnel regarding the implementation of the audit and self-assessment programs.
b. Assessment The inspectors concluded that self-assessments and audits were typically accurate, thorough, and effective at identifying issues and enhancement opportunities at an appropriate threshold level. The inspectors concluded that these audits and self-assessments were completed by personnel knowledgeable in the subject area. In many cases, these self-assessments and audits had identified numerous issues that were not previously recognized by the station. For example, NOS has identified that Operations had missed the TS Limiting Condition for Operation (LCO) entry for containment isolation valve 1SI8835 and 1SI8809A from a loss of power. Although power was restored before the LCO time ran out, Operations did not recognize the missed entry until the NOS review. Findings No findings of significance were identified.
15 Enclosure
.4 Assessment of Safety Conscious Work Environment
a. Inspection Scope
The inspectors interviewed selected members of the Braidwood Station personnel to determine if there were any impediments to a Safety Conscious Work Environment (SCWE). In addition, the inspectors discussed the implementation of the Employee
Concerns Program (ECP) with the ECP coordinators, and reviewed 2008 - 2010 ECP activities to identify any emergent issues or potential trends. In addition, the inspectors assessed the licensee's SCWE through the reviews of the facility's ECP implementing procedures, discussions with coordinators of the ECP, interviews with personnel from various departments, and reviews of IRs. The licensee's programs to publicize the CAP and ECP programs were also reviewed. b. Assessment The inspectors determined that the conditions at the Braidwood Station were conducive to identifying issues. Licensee staff was aware of and generally familiar with the CAP and other station processes, including the ECP, through which concerns could be raised.
A number of craft personnel indicated that they did not personally enter issues into the CAP. Instead, their preferred method was to notify supervisors of the issues and had the supervisors enter the issues into the CAP. The inspectors determined that this observation was not a significant concern since the personnel interviewed stated that they were willing to voice issues to their management and/or ask another employee to write the IR for them. Note that this issue had been identified in previous PI&R inspections and the licensee had not made significant progress in this area.
All employees interviewed noted that any safety issue could be freely communicated to supervision and that safety significance issues were being corrected. However, some employees interviewed stated that minor issues were not being addressed as many of those issues were closed to trending or closed to work orders that were not scheduled to be completed for extended periods. Several employees mentioned that they would like better feedback after writing IRs so they could understand the reasons for those delays.
The inspectors determined that although no related regulatory requirements exist, the station could strengthen this area of the CAP by ensuring all station personnel have an adequate working knowledge of entering issues into the CAP and receive feedback for issues raised.
In addition, a review of the types of issues in the ECP indicated that site personnel were appropriately using the CAP and ECP to identify issues and the issues in the ECP were being addressed accordingly.
Findings No findings of significance were identified.
16 Enclosure
4OA6 Management Meetings
Exit Meeting Summary
On September 17, 2010, the inspectors presented the inspection results to Mr. L. Coyle, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- L. Coyle, Plant Manager
- M. Marchionda-Palmer, Operations Director
- M. Smith, Engineering Director
- R. Gaston, Regulatory Assurance Manager
- P. Boyle, Maintenance Director
- P. Daly, Radiation Protection Manager
- B. Schipiour, Work Management Director
- R. Radanovich, Nuclear Oversight
- T. Schuster, Chemistry Manager
- E. Johnston, Site Correction Action Program Manager
NRC
- E. Duncan, Branch Chief
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened
- 05000457/2010006-01 NCV Failure to Follow the Operability Determination
Procedure
- 05000457/2010006-02 NCV Untimely Corrective Action for Lack of Water Hammer Analysis on the Recycle Holdup Tank
Closed
- 05000457/FIN-2010006-01 NCV Failure to Follow the Operability Determination
- Procedure
- 05000457/FIN-2010006-02 NCV Untimely Corrective Action for Lack of Water Hammer Analysis on the Recycle Holdup Tank
- Attachment
LIST OF DOCUMENTS REVIEWED
The following is a list of documents reviewed during the inspection.
- Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections or portions of the documents were evaluated as part of the overall inspection effort.
- Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.
- Issue Reports Number Description or Title Date or Revision
- IR 28260 A2000-02126 Degraded Voltage on Instrument Bus
- 214 May 4, 2000
- IR 114419 Weekly Circ Water Blowdown Composite Sample Misplaced July 1, 2002
- IR 116143 Additional Discrepancies Noted in Liquid Release Spreadsheet July 17, 2002
- IR 119714 1PA51J Inoperable - Affecting CETC's and RVLIS
- Unplanned LCO August 18, 2002
- IR 144454 Substantial Area of Boric Acid Found During Walkdown February 12, 2003
- IR 153139 Unable to Identify Valve Installed in Plant April 9, 2003
- IR 154057 Potential Adverse Condition with Underground Cables April 15, 2003
- IR 166861 Inability to Lower 1A D/G Load During the Performance of BwOP
- DG-12
- July 9, 2003
- IR 174026 0BwOS
- IS-Q1 Did not Meet Acceptance Criteria September 2, 2003
- IR 190118 Repeat Maint - 2PR11J Rad Monitor Failed After filter change December 11, 2003
- IR 212605 CO2 Tank Level Decreasing 15 to 20 % Per Month April 2, 2004
- IR 249040 0WX705C Took > 10 Minutes to Close - Needs Repair September 1, 2004
- IR 276095 Potential Adverse Trend for Loss of Sample Flow on
1PR0 8J November 23, 2004
- IR 282660
- AH-C-1B Insulation Problem December 15, 2004
- IR 292295 Actions Required from NRC Information Notice 2004-
- January 13, 2005
- IR 338480 ASME Pressure Test Frequency Not Met May 25, 2005
- IR 347451 Monitor Item 101 Not Used as Intended June 24, 2005
- IR 366352 SSDPC Inspection Press Test SX Pipe Follow-up to IR
- 364793 August 24, 2005
- IR 426852 0FP056B Seat/ Stem May Have Separated - Need work Request November 22, 2005
- IR 442540 Leak at Circ Water Blowdown Vacuum Breaker January 16, 2006
- IR 469323 Failure of U-2 Train A CETCs March 22, 2006
- Attachment
- IR 480489 Boric Acid Accumulation Bottom of PZR April 19, 2006
- IR 490486 Fuel Handling Predefines Need Updated May 16, 2006
- IR 514147 Operating Abnormal Procedures Need Upgrading July 27, 2006
- IR 518546 Training OPEX Review - Operator Response Time Questioned August 10, 2006
- IR 574048 0OR02J Went Into High Alarm During 0B GDT
- Release December 31, 2006
- IR 578666
- MW-13 Sample Results Contain Elevated Tritium November 10, 2006
- IR 578898 Evaluate Use of Excel Calculation Method for RCS Leakrate January 13, 2007
- IR 583152 50.59 Evaluation Should Have Been Performed October 17, 2006
- IR 586879 Line 1SX37AA Doesn't Meet Wall Thickness Screening Criteria February 1, 2007
- IR 608416 Re-occurring Issues with CW Vacuum Breakers March 24, 2007
- IR 619720 Station 5-year Exposure Reduction Plan Enhancement April 20, 2007
- IR 624518 OPXR Review Identified Issue with Operator EOP
- Response May 2, 2007
- IR 625625 Tritium Results from Sea Van #4 Leakage May 4, 2007
- IR 629903 Documenting 1/2 A AF Pumps Response Time in Loop May 15, 2007
- IR 632816 West Lagoon @ TR Splashing to Surrounding Gravel Due to Wind May 23, 2007
- IR 649581 Potential Vulnerability with RH Suction Relief Disch to HUT July 12, 2007
- IR 650477 Replace DG Temperature Switches with New Unit July 16, 2007
- IR 660065 NOS ID RP ANSI Qual Forms Aren't Being Maintained in Department August 13, 2007
- IR 660700 NOS ID SAC Has Not Reviewed the Dose Equalization per T&RM August 15, 2007
- IR 660807 NOS ID - Braidwood RP Is Not Implementing Req. Interim CAs August 15, 2007
- IR 660819 NOS ID RP DTSQA Database Not Kept Up to Date August 15, 2007
- IR 660834 NOS ID'D Catch Cpontainer Administration Deficiencies August 15, 2007
- IR 660891 NOS ID - RP Trip Tickets Not Utilized Per
- RP-AA-460-1003 August 15, 2007
- IR 661030 NOS IDS Procedure Revisions With No Plant Manager Authorization August 15, 2007
- IR 661055 NOS ID Approve Source Not Used for Response Checks of SAM August 15, 2007
- Attachment
- IR 661059 NOS IDS Radioactive Source Not Labeled with the Rad Symbol August 15, 2007
- IR 664692 OPS Needs to Create Procedure for Time Critical Actions August 26, 2007
- IR 677075 Recycle Hold Up Tank Level Administrative Controls September 28, 2007
- IR 692435 Yokogawa Test Recorders Are Not Being Time Checked October 31, 2007
- IR 705696 Create ATI for Visual Exam of 0SX165A/B Valves and Piping November 30, 2007
- IR 725513 Preconditioning Questions for 2B AF Pump Monthly Run January 22, 2008
- IR 726658 Transient Combustible Issues Across the Fleet January 25, 2008
- IR 767223 Procedure Enhancements for 0BwOA
- ENV-4 April 24, 2008
- IR 770446 Sampling of Shower Tanks for CAF Not Sampled Per TRM App. L May 1, 2008
- IR 773174
- PBI 11234 Section of Block Wall Missing Around Conduit May 8, 2008
- IR 773251 3/4" Hole in Fire Rated Block Wall May 8, 2008
- IR 782567 VA Fans in Degraded Status June 3, 2008
- IR 783866 Unit Common VA Fan Issues Identified June 6, 2008
- IR 785949 Radioactive Shipment from Vendor Was Not Recognized as RAD June 12, 2008
- IR 798341 1B EDG #2 Air Dryer High Temp When Running July 19, 2008
- Drill August 6, 2008
- IR 804575 Security Negligent Weapon Discharge (Level 2) August 6, 2008
- IR 806292 Response to ERO Call In Drill on 8/10/08 Less Than Desired August 12, 2008
- IR 810023 NOS ID'D Finding With RP Corrective Active August 22, 2008
- IR 814187 Water Leak from 2B MSIV Room Ceiling September 4, 2008
- IR 815967 Engineering Review Requested for SX System September 10, 2008
- IR 818067
- Unit 1 CAF Tank Over-Flowed September 15, 2008
- IR 819415 Regulatory Guide 1.97 Discrepancy with 1PI-405 September 18, 2008
- IR 819862 LCO 3.5.3. Bases Improvement Recommendation September 19, 2008
- IR 822036 PWR Half Scram September 23, 2008
- IR 825789 Inadequate MRule (A)(4) Risk Assessments October 2, 2008
- Attachment
- IR 827406 Entry Into 2BwOA Sec-1 for 2B MFW Pump Trip -
2FW0 1PB-A
- October 6, 2008
- IR 828673 Environmental Release HIT Team Actions October 9, 2008
- IR 829316 NRC to Issue Green Finding w/NCV for DOST Scaffold Issue October 10, 2008
- IR 829329 Review of Recently Published Rule Making
- October 10, 2008
- IR 829337 Fleet-wide Adverse Trend in Oil / Chemical Spills October 10, 2008
- IR 829955 Establishing Time Critical Actions Procedure &
- Database October 12, 2008
- IR 829955 Establishing Time Critical Actions Procedure and Data Base October 12, 2008
- IR 830723 SW Pipe Leaks Due to Inadequate Chem Treatment October 14, 2008
- IR 831511 B2R14 LL - Corporate Issues Related to Eddy Current Testing October 15, 2008
- IR 832975 Rising 1A SI Accumulator Level - 1SI04TA October 19, 2008
- IR 834448 Paint Overspray on 346' P-18 Sprinkler Head Fusible Link October 22, 2008
- IR 839535 Test EDG Fuel Oil for Bio-Diesel Before Delivery Acceptance November 3, 2008
- IR 845055 NOS ID Assessment Finding Associated with 1CS011A Removal November 14, 2008
- IR 849372 Facility and Equipment Issues from the NRC Graded Exercise November 20, 2008
- IR 849476 Question on Manual Actuation of CS to Reduce Offsite Dose November 19, 2008
- IR 852425 NRC - Potentially Inadequate Op Evel for AF Tunnel Hatches December 4, 2008
- IR 852953 Continuing Issues with Transient Combustibles December 5, 2008
- IR 855891 RP Fleet Focus Area - Human Performance December 13, 2008
- IR 860458 Unit 2 Reactor Trip December 27, 2008
- IR 864746-06 EFR for Security Large Volume of CFE FMS
- Observations July 28, 2009
- IR 867058 Ineffective Fire Prot. Prog. Oversight and Implementation January 15, 2009
- IR 867475 CCA:
- Weaknesses in OPEX Performance January 15, 2009
- IR 869417 2008 Cathodic Protection Survey Result Actions January 21, 2009
- IR 877502 Scheduled Work Delayed - Place VA
- CO 69222 (0VA02CA)
- February 6, 2009
- IR 880654 Design Vulnerability in CC Surge Tank Makeup February 13, 2009
- Attachment
- IR 883920 Radioactive Shipment Was Not Recognized as Rad Material February 23, 2009
- IR 883985 NRC Finding Documented in Inspection Report (HUT
- Quench Vol)
- February 23, 2009
- IR 885127 Water Intrusion into 1AF01J February 25, 2009
- IR 898690 NO IR Generated for Instrument in Hospital Inventory Kit March 27, 2009
- IR 898849 Review OE28233 for Fleet Recommendations March 27, 2009
- IR 902241 CV Full flow Testing Acceptance Criteria Issues (1CV01PA) April 3, 2009
- IR 902326 Corrective Action Assignment Closed to an ACIT April 3, 2009
- IR 904986 Missed Eddy Current Indication April 4, 2009
- IR 904986 A1R14 Steam Generator 1B Foreign Object Wear April 8, 2009
- IR 906002 Pump Cleanliness Requirements April 10, 2009
- IR 908495 1A AF Pmp Seal Leak at Outboard End Plus Oil Leak at Housing April 17, 2009
- IR 916875 Rescheduled
- WO 1029505- 0VA02CA Again May 7, 2009
- IR 925506 NOS ID Missed Tech Spec LCO Entry May 29, 2009
- IR 946512 Inadequate Approval for Changes to the Intent of CA Assign July 28, 2009
- IR 947274 NOS IDD CAPR Reference Not Documented July 29, 2009
- IR 948495 Call In Response for Unusual Event Less Than Desired August 1, 2009
- IR 950540 NOS ID Site Management Deficiencies in Dose Reduction August 6, 2009
- IR 952802 Choice of CST Leak for Off-Year Exercise Lessions Learned August 13, 2009
- IR 957600 BwOA Procedure Not Followed During 4/18/08 Seismic Event August 26, 2009
- IR 962492 TSC Performance Issues During Off-Year Exercise September 8, 2009
- IR 968376 NOS ID'D Review OPS IR's for Potential Adverse Trend September 22, 2009
- IR 979488 Water On the Floor of the 2B AUX Feed Pump Room October 14, 2009
- IR 992258 2SC178 Stroke Times Exceeds Alert Limit, Needs Evaluation November 12, 2009
- IR 992488 Security Breaker Tripped November 12, 2009
- Attachment
- IR 999440 2B DG Lube Oil Temperatures Steady, Not Cycling - 2TS-DG111B November 30, 2009
- IR 1013556 Security Diesel Min Batt Voltage on Startup Lower Than Limit January 7, 2010
- IR 1014513 Bad Bearing on 0VA01CC Causes Fire January 9, 2010
- IR 1014772 2SX178 Testing/Closeout Discrepancies January 1, 2010
- IR 1023138 0VA01CC Fan Shaft Damage Precludes Further Use January 29, 2010
- IR 1026633 Receipt of NRC Green Finding - Isolating VC Seismic Event February 5, 2010
- IR 1029694 2A DG Lube Oil Temp Controller Not Switching Heater On February 12, 2010
- IR 1035759 NRC Concern Regarding Deferral of U2 CC HX Flange Repair February 25, 2010
- IR 1038591 July 30, 2009 Unusual Event Declaration Reasoning March 5, 2010
- IR 1040066 Lack of Progress on 0VA01CD March 8, 2010
- IR 104659 K612 Failed to Remain Latch During 2PM06J Phase A Actuation April 20, 2002
- IR 1054668 TSC Performance Issues During NRC Evaluated Exercise April 9, 2010
- IR 1054933 2A DG Governor Response Is Not As Expected -
2DG0 1KA April 10, 2010
- IR 1057354 Rescreening of 3 Previous Security Reportable Events April 16, 2010
- IR 1060092 NOS ID:
- No Eval Done for Security EDG Surveillance Failure April 21, 2010
- IR 1060472 NOS ID Common Finding for Contract for EP Services April 23, 2010
- IR 1066847 High Levels in 1A & 1C SI Accumulator May 7, 2010
- IR 1067628 Receipt of NRC NCV CDBI - EDG Fuel Oil Consumption Calc May 10, 2010
- IR 1069892 Are Chem. Techs the Right Choice to Lower SI Accumulators May 16, 2010
- IR 1071070 Possible Summer Readiness Issues with 0VA02CA May 19, 2010
- IR 1072689 SI Accumulator Level Control Resource Issues May 24, 2010
- IR 1072807 SI Accumulator Sampling SR 3.5.1.5 Applicability May 25, 2010
- IR 1073637 Ineffective CAPR
- 739973-07 May 26, 2010
- IR 1075957 2B Jacket Water Temp Switch Not Controlling in Auto June 2, 2010
- IR 1078640 Evaluate D/G Temp Switch Failure Rate for Operator Challenge June 9, 2010
- IR 1080455 OIO BMRK DG JW and LO Temperature Switches - Byron
- IR 1047627 June 15, 2010
- IR 1083190 Failed Demonstration Criteria in TSC for June 3 PI Drill June 10, 2010
- IR 1083367 Continuing Temp Switch Issues on Emergency D/Gs June 23, 2010
- IR 1083797 OPS ID - 1TS-DG112A Not Operating Properly June 24, 2010
- IR 1084763 Battery Voltage Below Acceptance Criteria, 0BwOS
- IS-Q1 June 25, 2010
- Attachment
- IR 1086088 NOS ID:
- 1T2010 Emergency Preparedness Performance Yellow June 30, 2010
- IR 1088364 Potential Design Vulnerability on Auxiliary Feedwater System July 7, 2010
- IR 1089189 1C SI Accumulator (1SI04TC) Level Showing an Upward Trend July 9, 2010
- IR 1089299 PI&R FASA ID'D - No CA Tracking Closure of NCV in CAP July 9, 2010
- IR 1091006 Access to EP Portable Generations in Warehouse Again Blocked July 16, 2010
- IR 1093043 1B DG Lube Oil Temp Switch Not Controlling Properly July 21, 2010
- IR 1094537 TSC Demonstration Criteria Failure in July 14 PI Drill July 26, 2010
- IR 1099124 1CV8525A Valve Stem Not Attached August 7, 2010
- IR 1100587 OPS ID:
1DG0 1KA-B August 12, 2010
- IR 1106896 Unit 1 RCS Leakrate Exceeds Action Level 3 August 27, 2010
- IR 1109925 Momentary Unexpected Load Decrease During MPC
- Download September 4, 2010
- IR 1114604 Concern with Operability Determination September 17, 2010
- Root Cause/Apparent Cause/Common Cause Report Number Description or Title Date or Revision
- IR 782299-04 Auxiliary Building Exhaust Fan, 0VA02CA, Failure
- June 30, 2009
- IR 809659-02 Calibration of Raymond Hydraulic Wrench is not in Compliance with the Requirements of the Quality Assurance Topical Report (QATR) for Certified Measurement & Testing Equipment (M&TE)
- October 15, 2008
- IR 829337-02 Fleetwide Adverse Trend in Oil / Chemical Spills November 17, 2008
- IR 835045-07 The Reactor Coolant System (RCS) dissolved hydrogen analyzer was used to perform a sample analysis on 10/22/08 to satisfy a Technical Requirements Manual (TRM) surveillance requirement, while bearing a calibration sticker indicating the next calibration due was 10/15/08 December 15, 2008
- IR 852425-06 Delayed Actions to Address Low Margin Issue Associated with Latent Calculational Errors Resulting in a Non-Cited Violation of Appendix B Criterion III and
- XVI February 2, 2009
- IR 860458-04 Unit Two Reactor Trip on
- UAT 241-1 Sudden Pressure Relay Actuation due to 2C Heater Drain Motor Electrical Fault February 6, 2009
- IR 864746-02 Security Large Volume of CFE FMS Observations February 11, 2009
- IR 867475-03 Weaknesses in OPEX Performance February 13, 2009
- Attachment
- IR 871991-03 Pre-screening of Work Orders for Pre-Authorization, Production and Reactivity Risk March 3, 2009
- IR 882872-11 NOS ID: Security Drills and Exercises ARMA April 17, 2009
- IR 885913-02 Security Procedure Use and Adherence March 27, 2009
- IR 902241-19 CV Full Flow Testing Acceptance Criteria Issues (1CV01PA) May 12, 2009
- IR 908495-02 Multiple Leaks on Unit 1 "A" Auxiliary Feedwater Pump (1AF01PA) after Completion of Maintenance Activities
- During A1R14 May 21, 2009
- IR 994317-07 Maintenance Rule (A)(4) Compensatory Measures Not Fulfilled Resulting in an Unplanned On-Line Risk Status Change to Yellow Due to Procedure Prerequisite Step Not Followed
- November 16, 2009
- IR 1009172-05 Unplanned LCO Entry 1CC9412B Found Without Light Indication February 12, 2010
- IR 1014513-07 0VA01CC Fan Bearing Failed May 5, 2010
- IR 1028837-03 Lack of Adherence to Administrative Procedures within Maintenance Leads to NOS Identifying an Area Requiring Management Attention February 11, 2010
- IR 1035759-04 Deferral of Unit 2 Component Cooling Water Heat Exchanger Flange Repair from A2R14 to A2R15 April 16, 2010
- IR 1092920-04 Security Officer Discovers .223 Round is Missing From Contingency Weapon August 15, 2010
Operating Experience
- Number Description or Title Date or Revision
- IR 819932
- IR 860167 OPEX Evaluation of NRC
- IN 2008-21, "Impact of Non-Safety Electrical Support System Vulnerabilities on
- Safety Systems" June 19, 2009
- IR 864082-02 RAI for NRC Bulletin 2007-01 Assessment January 30, 2009
- IR 893946
- OE 28391 Review, Ensure Cal Instructions are Followed March 17, 2009
- IR 898494
- IN 2009-02 Biodiesel Impact on Diesel Engine Performance March 27, 2009
- IR 953426
- IN 2009-08 Rapid Notification Process for Physical Attacks August 14, 2009
- IR 959926 OPEX Evaluation of NRC
- IN 2009-22, "Recent Human Performance Issues at Nuclear Power Plants"
- IR 987761-01 Review of Diesel Generator OE January 13, 2010
- OE 31102 Security Review for Applicability to Braidwood March 11, 2010
- Attachment
- OE 4789 Lack of Documentation to Support Diesel Generator Tornado Design Basis August 27, 1991
- OE 28110 Unprotected Diesel Generator Fuel Oil Tank Vents (Catawba)
- January 20, 2009
- OE 28237 Underground Fuel Oil Storage Tank Vent Vulnerability to Tornado Missile Strike (North Anna)
- February 16, 2009
- Audits, Assessments, and Self-Assessments Number Description or Title Date or Revision
- IR 696206-02
- CHECK-IN Self Assessment - Clearance and Tagging, 1/2008 - 10/2008 December 1, 2008
- IR 794909-03 Braidwood Triennial Fire Protection Inspection Preparatory Self-Assessment December 12, 2008
- IR 826356-02 Security Safety Conscious Work Environment October 21, 2008
- IR 826775-03 Chemistry Records/ Chemistry Aids July 31, 2009
- IR 832367-02
- CHECK-IN Self Assessment - Clearance and Tagging, 10/2008 - 7/2009
- September 30, 2009
- IR 832370-02
- CHECK-IN Self Assessment - Evaluate Braidwood stations compliance with SOER 07-01
- August 28, 2009
- IR 837394-02
- CHECK-IN Self Assessment - Access to Rad Significant Areas March 17, 2009
- IR 837415-02
- CHECK-IN Self Assessment - ALARA Planning and Controls February 4, 2009
- IR 837416-02
- CHECK-IN Self Assessment - Occupational Exposure Control Effectiveness March 13, 2009
- IR 837418-02
- CHECK-IN Self Assessment - Access to Rad Significant Areas August 5, 2009
- IR 837421-02
- CHECK-IN Self Assessment - ALARA Planning and Controls August 5, 2009
- IR 838584-03 Pre-NRC Force-On-Force Inspection FASA July 8, 2010
- IR 864012-02 Technical Human Performance Gaps in Maintenance September 30, 2009
- IR 865569-02 Configuration Change Quality Annual Assessment February 6, 2009
- IR 902872-03 Gap in Planning Process September 8, 2009
- IR 907077-02 Braidwood Security Training Paperwork May 27, 2009
- IR 912155-02 Security Aid and Standing Order Check-In November 18, 2009
- IR 961524-03 Readiness Review for 2010 NRC Component Design Basis Inspection January 19, 2010
- IR 963260-02
- CHECK-IN Self Assessment - Pre-NRC EP
- Exercise and PI Inspection January 22, 2010
- IR 971944-03 FASA for Preparation of NRC Identification and Resolution (PI&R) Inspection July 28, 2010
- Attachment
- IR 1018707-02 Security Pre-NRC Inspection check Protections of Safeguards March 12, 2010
- NOSA-BRW-07-04 Emergency Preparedness Audit May 20, 2007
- NOSA-BRW-07-07 Operations Audit Report December 5, 2007
- NOSA-BRW-08-03 Emergency Preparedness Audit January 8, 2008
- NOSA-BRW-08-13 Radiation Protection Increased Frequency Audit Report January 8, 2008
- NOSA-BRW-09-01 Corrective Action Program Audit Report May 19, 2009
- NOSA-BRW-09-04 Emergency Preparedness Audit December 2, 2008
- NOSA-BRW-09-05 Engineering Design Control Audit August 31, 2009
- NOSA-BRW-09-06 Radiation Protection Audit Report
- September 14, 2009
- NOSA-BRW-09-07 Operations Audit November 12, 2009
- NOSA-BRW-10-01 Maintenance Audit Report March 25, 2010
- NOSA-BRW-10-02 Security Programs Audit Report February 3, 2010
- NOSA-BRW-10-03 Emergency Preparedness Audit Report December 8, 2009
- NOSA-BRW-10-04 Chemistry, Radwaste, Effluent and Environmental Monitoring Audit Report July 14, 2010
- NOSA-BRW-10-16 Corrective Action Program Increased Frequency Audit Report March 17, 2010
- NOSA-BRW-10-01 Maintenance Audit Repot February 19, 2010
- Nuclear Safety Culture Assessment March 2, 2010
- Semi-Annual Safety Culture Review - May 2010 July 13, 2010
- Semi-Annual Safety Culture Review - September
- 2009 March 1, 2010
- Semi-Annual Safety Culture Review - November
- 2008 November 20, 2008
Drawings
- Number Description or Title Date or Revision
- I&C-6 TSC Inverter Revision 2 M-66, Sheet 4B Diagram of Component Cooling July 23, 1975
- Attachment Others
- Number Description or Title Date or Revision
- CALC 19-D-6 Sizing the TSC/Security Computers UPS Revision 000E
- EC 344716 Provide the Security Diesel Loaded Frequency Requirement November 12, 2003
- IS-Q1 November 12, 2003
- Revision 0
- Revision 0
- EC 377473 Force on Force Readiness Project, Scope 10.1.9.3 -
- Five PTZ Rooftop Cameras Revision 10
- Revision 0
- Revision 0
- IR 992488-04 QHPI for Loss of Power to Security Equipment During Modification Work December 15, 2009 L-2719 Vendor's Manual - Sargent and Lundy Spec., Auxiliary feedwater pump motors
- LO-09-04 LORT Required Reading Package June 26, 2009
- WO 621198 125V Security & Technical Support Center Battery Performance Test March 1, 2005
- WO 626470 Replace Batteries for 0DG01EB January 12, 2005
- WO 690337-01 MM - Valve Leaks By April 26, 2010
- WO 941369 Security Diesel Generator Periodic Surveillance (Loaded Run) November 18, 2006
- WO 980964 Security Diesel Generator Periodic Surveillance (Loaded Run) June 21, 2007
- WO 990982-03 MM - Shaft Damage Discovered on 1B HD Pump February 18, 2009
- WO 1041980 Security Diesel Generator Periodic Surveillance (Loaded Run) December 26, 2007
- WO 1093021 Security Diesel Generator Periodic Surveillance (Loaded Run)
- July 11, 2008
- WO 1152081 Security Diesel Generator Periodic Surveillance (Loaded Run)
- January 8, 2009
- WO 1181465-01 MM - Replace Sprinkler Head fusible Link at
- 346/P/18 December 17, 2009
- WO 1200091-01 1HD01PB-M Extent of Condition Termination Inspection July 28, 2009
- WO 1201305 Security Diesel Generator Periodic Surveillance (Loaded Run) June 24, 2009
- WO 1219315 MM - Schedule Inspection of 1HD01PC Upper Shaft October 24, 2009
- Attachment
- WO 1228394-02 MM - Perm Repair - Oil Leak at Outboard B. Cover.
- Remove TCC April 12, 2010
- WO 1285664-01 Security Breaker Tripped in Power Dist Panel #PW2 November 17, 2009
- WO 1361122 U2 SX System Flow Balance August 12, 2010
- Contract
- 463696 Perform a study to support 4 successive starts of
- AF motor August 18, 2010
- Selected Chemistry Support Requests March 2009 to August 2009
- Non - Outage Backlog - Corrective Maintenance September 1, 2010
- Non - Outage Backlog - Elective Maintenance September 1, 2010
- Plant Procedures Number Description or Title Date or Revision
- 0BwCSR TRM
- App. L - CST
- Unit 1 and Unit 2 Condensate Storage / Containment Access Facility Tanks Once Per 7 Days Revision 4 0BwOA
- ENV-4 Earthquake Revision 106 0BwOA
- ENV-4 Earthquake Revision 108
- 0BwOA
- ENV-4 Earthquake Revision 109
- 0BwOS
- IS-Q1 Unit Common Security Diesel Generator Loaded Run Surveillance Revision 15 2BwOA-PRI-1 Excessive primary plant leakage Unit 2 Revision 103 BwAP 340-1 Use of Procedures for Operating Department Revision 24 BwAR 0CP01J-5-B1 Low Conductivity Sump Level High Revision 5
- BwCP 340-1 Chemical Additions to Plant Systems and Components Revision 13 BwHP 4006-008 Repairing, Determinating, Terminating, Splicing, Taping, Cable Jacket Repair and Application of Raychem Kit on Cable Revision 17 BwOP
- AP-47T1 Electrical Loads on 480V Switchgear Bus 033W Revision 4 BwOP
- DO-21 Filling the Security Diesel Generator Fuel Oil Day Tank Revision 15
- CY-AA-110-400 Chemistry Adjustment Revision 3
- CY-AA-130-100 Inline Instrument Quality Control Revision 2
- CY-AA-130-200 Quality Control Revision 9
- EI-AA-1 Safety Conscious Work Environment Revision 24
- EI-AA-101 Employee Concerns Program Revision 8
- EI-AA-101-1001 Employee Concerns Program Process Revision 9
- EI-AA-101-1002 Employee Concerns Program Trending and Reporting Tools Revision 5
- Attachment
- HU-AA-104-101 Procedure Use and Adherence Revision 4
- LS-AA-115 Operating Experience Program Revision 14
- LS-AA-115-1003 Processing of Significance Level 3 OPEX
- Evaluations Revision 0
- LS-AA-120 Issue Identification and Screening Process Revision 12
- MA-AA-716-025 Scaffold Installation, Modification, and Removal Request Process Revision 8
- MA-MW-726-022 Electrical Cable Termination and Inspection Revision 4
- OP-AA-108-115 Operability Determinations Revision 9
- OP-BR-108-101-
- 1002 Operations Department Standards and Expectations Revision 14
- RP-AA-460 Controls for High and Locked High Radiation Areas Revision 20
- RP-BR-654 Unit 1(2) Containment Access Facility Drain Collection Tanks Revision 8
- SY-AA-1020-F-02 Security Post Orders Revision 3
- WC-AA-111 Predefine Process Revision 3
- Issue Reports Generated During the Inspection Number Description or Title Date or Revision
- IR 1108069 PI&R ID'D - USFAR Update Completed to an MREQ/ACIT August 31, 2010
- IR 1112604 PI&R - Review Security Generator Class and Documentation September 13, 2010
- IR 1117317 Performance Deficiency for Security DG September 24, 2010
- IR 1117316 Performance Deficiency Exited for DG Temp Switches September 24, 2010
- IR 1117314 Performance Deficiency Exited During PI&R for VA Fan Repair September 24, 2010
- IR 1117312 NRC Exited Minor Violation for OPS QHPI Results September 24, 2010
- IR 1117308 NRC Exited Potential NCV for Loss of AF and OP Eval September 24, 2010
- IR 1117296 NRC Exited Green NCV for RHUT Analysis September 24, 2010
- Attachment
LIST OF ACRONYMS
UFSAR Updated Final Safety Analysis Report
M. Pacilio -2-
the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at the Braidwood Station. The information you provide will be considered in accordance with Inspection Manual Chapter 0305.
In accordance with
NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response (if any) will be available electronically for public inspection in the
PARS) component of the
NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Eric R. Duncan, Chief
Branch 3
Division of Reactor Projects Docket Nos. 50-456; 50-457
Enclosure: Inspection Report No. 05000456/2010006 and 05000457/2010006
w/Attachment: Supplemental Information cc w/encl: Distribution via ListServ
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DOCUMENT NAME: G:\DRPIII\BRAI\Braidwood PIR 2010 006.doc Publicly Available
Non-Publicly Available
Sensitive Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy
- OFFICE [[]]
- RIII [[]]
- RIII [[]]
- RIII [[]]
- NAME [[]]
RNg:dtp*MTK for
- RECORD [[]]
- AND [[]]
- RidsNrrDorlLpl3-2 Resource
Daniel Merzke RidsNrrPMBraidwood Resource
RidsNrrDirsIrib Resource
- DRPIII [[]]
DRSIII
Patricia Buckley