ML20149G102

Forwards NRR Input to SALP-7 for Dec 1986 - Dec 1987

ML20149G102
Person / Time
Site:	Braidwood
Issue date:	02/09/1988
From:	Sands S Office of Nuclear Reactor Regulation
To:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8802180114
Download: ML20149G102 (8)

Text

( l February 9, 1988 l

DISTRIBUTION:

4 Docket F11e NRC & Local PDRs ,

Docket Nos. STN 50-456 PDIII-2 r/f SSands I 1 and STN 50-457 LLuther MEMORANDUM FOR: Charles E. Norelius, Director Division of Reactor Projects  !

Region III THRU: Daniel R. Muller, Director l Project Directorate III-2 Division of Reactor Projects - III, IV, Y and Special Projects Office of Nuclear Reactor Regulation FROM: Stephen P. Sands, Project Manager Project Directorate III-2 Division of Reactor Projects - III, IV, Y and Special Projects i Office of Nuclear Reactor Regulation

SUBJECT:

NRR INPUT TO SALP LICENSING ACTIVITIES - BRAIDWOOD STATION I 1

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Enclosed is an assessment of Connenwealth Edison Company's (CECO) perfor- i mance in the functional area of '2 censing activities relating to Braidwood Station. This SALP-7 report covers the period December 1, 1986 through Decerter 31, 1987.

The enclosed report was prepared in accordance with NRR Office Letter No. 44, Revision 1, dated December 22, 1986, and NRC Manual Chapter 0516, and is based upon our observations as well as inputs received from staff personnel who have had substantial contact and involvement with CECO issues regarding Braidwood during the report period.

s/

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Stephen P. Sands, Project Manager Project Directorate III-2 Division of Reactor Projects - III, IV, V and Special Projects ,

Office of Nuclear Reactor Regulation l

Enclosure:

As stated 880218o114 880209 PDR l

P. Hiland, RIII ADOCK 050004S6 cc: O PDR CONTACT: S. Sands, NRR t 49-28298 PDIII- PDIII-2 PDII

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e, Docket Nos. STN 50-456 and STN 50-457 FACILITY: Braidwood Station, Units 1 and 2 LICENSEE: Comonwealth Edison Company EVALUATION PERIOD: December 1, 1986 to December 31, 1987 PROJECT MANAGER: Stephen P. Sands I. INTRODUCTION This report presents the results of an evaluation of the licensee, Comonwealth Edison Company (CECO), in the functional area of licensing activities and other relateo areas. It provides NRR's input to the SALP  !

review process as described in NRR Office Letter No. 44, Revision 1, dated 22  !

December 1986, and NRC Manual Chapter 0516 and is based upon our observations I as well as on inputs received from staff personnel who have had substantial  ;

contact and/or involvement with CECO issues regarding Braidwoti during this '

I period.

II.

SUMMARY

NRC Manual Chapter 0516 specifies that each functional area evaluated will be assigned a performance category (Category 1, 2, or 3) based on integrated inputs covering a range of attributes.

III. CRITERIA The evaluation criteria used for this assessment are given in NRC Manual Chapter 0516 Appendix, Table 1, Evaluation Criteria with Attributes for -

Assessment of Licensee Performance. i IV. PERFORMANCE ANALYSIS The evaluation presented here represents a composite of inputs from the Licensing Project Manager (LPM) and the technical review groups that expended a significant effort developing Safety Evaluation Reports (SER).

The basis of this appraisal was the licensee's performance in support of licensing actions that were either completed or had a significant level of activity during the rating period. These actions, consisting of amendment requests, extention requests, requests for deferral of specific requirements, responses to generic letters, TMI items, and other actions, included the following specific items:

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Plant Specific Action Items:

1 Braidwood 1 full power license Braidwood 2 low power license Transfer of ownership of Braidwood 1 and 2, Design of diesel generator breaker control scheme, j Review of FSAR Amendment 48, Station radiation protection aspects of fuel reconstitution, Revised T/S for elimination of setpoint verification for undervoltage relays, and Check valve testing V. ASSESSMENT OF PERFORMANCE ATTRIBUTES The licensee's performance evaluation is based on a consideration of seven attributes. These are the following:

A. Management involvement and control in assuring quality B. Approach to resolutien of technical issues from a safety standpoint C. Responsiveness to NRC initiatives 1

D. Staffing l l

E. Enforcement l l

F. Reporting and analysis of reportable events l G. Housekeeping A. Management Involvement and Control in Assuring Quality The major licensing activities for this SALP period were the issuance of the full power license for Unit 1 and the low power license for Unit 2.

During these activities there was always sufficient corporate management involvement to ensure that the submittals needed to support licensing of both units were timely, thorough, and technically sound. The quality of the licensee's reviews and responses to NRC concerns was kept at & l high level. However, certain issues pertaining to fire protection and i initial test programs should have been resolved by the licensee earlier in the review process. Therefore, management involvement could have been improved in these two areas.

Following the issuance of the Braidwood 1 full power license on July 2, 1987, the activities shifted to more routine matters such as licensing amendments and responding to NRC generic concerns for Unit 1. However, the Unit 2 low power license soon became the major focus and again management's involvement assured a high quality in the licensee's submittals. Corporate nunagement has maintained close contact with the NRC staff in order to ensure licensing niatters are kept on course and that any problems are being resolved in a timely and satisfactory manner.

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Open and effective coninunication channels exist between the NRC staff and  !

the licensee's staff. Responses to NRC initiatives have been timely and I technically sound due to effective exchange between both staffs. All i established commitnent dates were met or a written submittal provided  !

establishing a new firm date and an explanation of the circumstances l which led to the change. Where applicable, conference calls with the l staff were promptly established and always included appropriate engineering, plant and/or contractor personnel. The licensee's nuclear licensing administrator and/or management in almost all cases worked very well with NRR to coordinate a resolution of each licensing or technical issue.

B. Approach to Resolution of Technical Issues from a Safety Standpoint A clear understanding of the technical issues and responses which are generally sound and thorough are usually provided. Conservatism and a viable approach is generally exhibited. In several instances, the licensee challenged the staff position (such as the closing of the RHR crosstie valve while in Mode 1), but only when it believed safety would not have been compromised.

I C. Responsiveness to NRC Initiatives In the weeks prior to the issuance of the full power license for Unit 1 and the low power license for Unit 2, the licensee's response in supporting the NRC review and NRC initiatives and concerns was timely, technically sound, and thorough. Both the Station and the Corporate office have rarely failec to accommodate an NRC-initiated program (i.e.,

special study, survey, or evaluative program being conducted by or for NRC), even where there was no obligation to accommodate such a request.

The licensee has usually made a special effort 3 to establish a single point of contact for activities which involvhd nrore than one station (such as the SIMS report) in order to assist the NRC staff in its review.

D. Staffing I Key positions are clearly identified and responsibilities are well defined for both plant staff and licensing personnel. The security organization is well balanced from the aspect of positions and responsibilities, however, the quantity of the staff is more than adequate, and may even be somewhat in excess, to implement the facility's  ;

protection program. j E. Enforcement A sufficient bases for an NRR evaluation of this attribute is not available at this time.

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F. Training and Qualification Effectiveness The licensee has developed a corrprehensive training program for all its station personnel. In addition to the Shift Experience Program (for Braidwood Station), a program designed to provide senior operators on ,

shift the opportunity for additional supervisory training at an operating i articipated in an NRC administered requalification exam l PWR, the station p(4 SR0 and 8 RO). The exam contained a written, simulator, for 12 personnel and walk-through section. All 12 operators passed the exam. The licensee has an adequate number of experienced senior operators to provide on-shift operating experience which satisfies the requirements of Generic Letter 84-16.

G. Housekeeping l This attribute is covered in the section under "Fire Protection / Housekeeping",

however, NRR has continuing interest in this area since good housekeeping practices are an indication of management involvement and pride in the facili ty. During this period, the project manager has toured most areas of the plant more than once. The plant is usually clean, and a professional atmosphere is always present. Since Braidwcod introduced the "Model Spaces" concept, the overall appearance of the plant represents a standard of excellence significantly above the acceptable level. The plant has a plan developed for the systematic painting / upgrading of all plant areas.

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RECORD OF MEETINGS AND OFFICAL DOCUMENTS

1. NRR/ licensee Meetings 3/18/87 - Transfer of ownership of Braidwcod Units 1 and 2 l 5/14/87 - General status of Braidwood and other Comonwealth Edison )

plants 6/29/87 - Further discussion on transfer of ownership of Braidwood  ;

Units 1 and 2 1 10/21/87 - Meeting with ASLAP to hear oral arguments on pending appeal of intervenors from Board 870519 concluding  !

partial initial decision.  !

2. NRR Site Visits / Meetings  !

8/21/87 - PM site visit and NGET training for site access l 10/05/87 - PM attend Braidwood Management Meeting at R III l 10/12/87 - PM and PE site visit l 11/09/87 - PM and ICSB reviewer site visit for review of MESAC l system I 12/02/87 - PM and PD site visit to discuss readiness for Unit 2 low .

power license

3. Comission Meetings 6/30/87 - Commission briefing on Braidwood Unit 1 full power .

license l

4. Event Briefings

5. ACRS Meetings - None

6. Schedule Extension Granted Deferral of limited aspects of the Pre-Operational Test Program Deferral of completion of specific areas of Fire Protection

7. Reliefs Granted l One-time exception granted for operator requalification program l topical report. j Demonstration of control room envelope integrity deferred until completion of the Unit I surveillance outage.

8. Exemptions Granted i Appendix J exemption issued with Braidwood Unit I full power license and Braidwood Unit 2 low power license.

9. License Amendments Issued 10/30/87 - Amd. #1, Allow extension for surveillance of diesel generators 11/25/87 - Amd. f2, Allow a one-time extension to 32 mos. from 18 mos. on instrument surveillance 12/08/87 - Amd. f3, Allow deletion of reactor trip on turbine trip below 30 % power

10. Emergency Technical Specifications Issued -

None

11. Orders Issued -

None

i 'i SALP INPUTS .;

12/1/86 - 12/31/87_

DATE OF 1. MANAGEMENT 2. APPROACH TO ISSUE INVOLVEMENT RESOLUTION 3. RESPONSIVENESS SUPG4ARY BRANCH INPUT 2

i 2 2 Mann, PARS 2/17/87 Check Valve Test -

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' Trehan, SELB 10/5/87 D.G. Breaker N/A 1 2 2 .'

Kubicki, CMEB 12/7/87 Fire Protection 2 SPDS Isol. 2 1 2 2 f.

i Stewart, ICSB 10/1/87 2 2 2 2 h i Stewart, ICSB 10/15/87 Sury. Extensions 1 1 Stewart, ICSB 10/19/87 Setpt. Verif. 2 1 ,

3 3 - -}

Burrows, PAEI 1/20/87 HELB N/A 2 N/A 2 l I

Hayes, PSB 1/16/87 CR Habitability 2 E

2 2 1 2 Hayes, PSB 2/26/87 CR Chlorine Detect.

Minners, RSB II.K.3.31 - 1 1 l 1/30/87 2 3 2 [

Fire Protection 2 Singh, PSB 3/27/87 Setpt. Verif. N/A 1 l' 1 i Trehan, SELB 8/4/87 '

1 1 ORR, LHFB 10/2/87 NUREG-0737 1, 1 2 f 2" 2 N/A Hayes, PSB 12/22/86 II.F.1 ,

3 3 3 l Swift PRPB 6/25/87 Aux. Bldg. Vent. N/A N/A 1 Burrows, PAEI 3/2/87 HELB Isolation N/A 1 f 1 1 [

1 Lcsher, PAEI 1/7/87 GL - Item 4.5.2 N/A 2 2 -

e' Toalston, SELB 5/13/87 GL-83-28. Item 2.2 N/A 2 2 -

. Giardina, PSB 5/5/87 Diesel F/0 Refilling N/A 1 1 Materials Integrity 1 1 [

Elli:t, MTEB 5/1/87  :

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Previous SALP Cycle Ratings Functional Areas Rating SALP 4 Rating SALP 5 Rating SALP 6 A. Plant Operations X NR 1*

B. Radiological Controls 2 2 2 C. Preoperational Testing 2 2 1 D. Fire Protection X NR 2 E. Emergency Preparedness X 2 2 F. Security X NR 2 G. Quality Programs and 3 2 1 Administrative Controls Affecting Quality H. Licensing Activities 2 2 2 I. Containment, Safety- 2 2 X Related Structures, and '

Major Steel Supports -

J. Piping Systems and Supports 3 2 X K. Safety-Related 3 2 X Ccmponents - Mechanical L. Auxiliary Systems 2 2 X M. Electrical Equipment 2 2 X and Cables N. Instrumentation 2 2 X

0. Braidwood Construction X 1 X Assessment Program P. Housekeeping and X 3 Xf Equipment Protection X= Not Rated Last Report NR = Not Rated because of lack of activity in the area.

• = Functional Area was defined as Operational Readiness and_

Initial Fuel Loading, f= Housekeeping was included with Fire Protection l

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