IR 05000456/1990008

Insp Repts 50-456/90-08 & 50-457/90-08 on 900416-20 & 0430- 0504.Violations Noted.Major Areas Inspected:Fire Protection, Inservice Testing,Support of Maint & Related Mgt Activities

ML20055C758
Person / Time
Site:	Braidwood
Issue date:	06/14/1990
From:	Burgess S, Holmes J, Huber M, Jablonski F, Ron Kopriva, Michael Kunowski, Mendez R, Slover W, Walker H, Matt Young NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20055C755	List: IR 05000456/1990008 ML20055C754 ML20055C756
References
50-456-90-08, 50-456-90-8, 50-457-90-08, 50-457-90-8, NUDOCS 9006250059
Download: ML20055C758 (39)

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ds V. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-456/90008(DRS); 50-457/90008(DRS)

. Docket No. 50-456; 50-457 License No. NPF-72; NPF-77

' Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Nuclear Generating Station - Units 1 & 2 Inspection At: Braidwood Site, Braceville, Illinois Inspection Conducted: A ri 16 through 20, and April 30 through May 4, 1990 Inspectors: H. A. W eam Leader <>/IM" D urg '- '

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' Approved By:' J j onski, Chief Maintenance and Outage Section b!/Y!f0 I Date 3 L

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l-Inspection Summary, Inspection on April 16 through 20 and April 30 through May 4, 1990 (Report No. 50-456/90008(DR$); 50-457/90008(ORS)).

Areas Inspected: Special announced team inspection of maintenance, fire protection, inservice testing, support of maintenance, and related man 6 ement

activities. The inspection was conducted utilizing Temporary Instruction 2515/97, the attached Maintenance Inspection Tree, and selected portions of Inspection Modules 62700, 62702, 62704, 62705, and 64704, and 73755 to ascertain whether maintenance was effectively accomplished and assessed by the l icense Results: Based on the ite. ins inspected during the time frame that the inspection was conduct 5d overall performance in maintenance was considered good. Some of the more significant strengths were: (1) experienced management committed to good maintenance; (2) personnel committed to compliance with procedures that are well written; (3) very low accumulated-radiation dose; (4) excellent computer-based systems for trending and tracking; and (5) innovative and practical methods for improving maintenance such as a video mapping system-and a micro-electronic surveillance and calibration system (MESAC). There were no significant weaknesses identifie A synopsis of the overall implementation of the maintenance program is provided in Section 5.0 of the report. There was one violation noted in the area of failure to follow procedure l

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'q' 4 DETAILS Principal Persons Contacted Commonwealth Edison Company

• T. Maiman, Vice President (Pressurized Water Reactor Nuclear Operations)

0.-Ambler, Health Physics Supervisor

• D. Cline, Storeroom Supervisor

• K. Graesser, General Manager, Pressurized Water Reactor Stations

• L. Guthrie, Master Mechanic

• S. Hedden, Maintenance Staff Supervisor R. Kyrouac, Station Quality Assurance Superintendent

• M. Lohman, Assistant Superintendent, Maintenance

• D. Miller,- Regulatory Assurance Supervisor

• R. Querio, Station Manager

• E. Roche, Health Physics Group Leader, Operations J. Smith, Master Electrician R. Ungeran, Master Instrument Mechanic U. S. Nuclear Regulatory Commission

• T. Martin', Deputy Director, Division of Reactor Safety

- * Taylor, Resident Inspector

• Denotes whose present at the exit meeting on May 10, 1990.

Other Licensee personnel were contacted as a routine matter during the inspection, Review of Allegations (Closed) Allegation (AMS No RIII-90-A-0047): Inadequate radiation protectio measure The NRC resident inspector at the Braidwood Nuclear Generating Station received an allegation about the adequacy of radiation' protection activities during a job.in the Unit 2 containment spray pump room. The allegation was reviewed during the inspection through record and procedure review, discussions with licensee and contractor personnel, and observations at the job sit Concern #1: Lead blankets near the job site were improperly hun Discussion: .At the time of the inspection, the lead ble .ts, used for shielding a hot spot on a nearby pipe, had been remov .ecause work in the area had been completed. However, review of a shield .; placement record, and discussions with personnel responsible for hanging the shielding and surycying the area before and after shielding installation, and with the concerned individual's- co workers, did not indicate that the shielding was improperly hung. Survey records for the job site indicated general area dose rates were

. low, ranging f rom 1-35 mrem / hour. Dose totals for the workers involved with the job were also low, and were well within the radiation work permit (RWP)

daily limit of 100 mre !

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Findings: The allegation was not substantiated. Licensee records and ~

personnel indicated that the shielding was properly hun I Concern #2: Protective clothing was required in some areas of the containment '

spray (CS) and residual heat removal (RHR) pump rooms but was not required in 1 other areas with higher radiation level Discussion: Consistent with the concerned individual's issue, discussions i with several of the individual's co-workers revealed a misunderstanding that protective clothing affords protection from radiation. In addition, a contract health physics technician stated to the inspector that on one occasion the technician observed two individuals dressed in protective clothing while working in the 2B CS pump room where protective clothing was not require According to the technician, the workers stated that_ protective clothing was worn because of a nearby labelled hotspot. The technician explained that the-protective clothing was not effective against the radiation from the hotspot, but permitted the workers to finish the job because it was nearly complete. A review of survey records and contamination control procedures by the inspector ,

indicated that protective clothing was not necessary in the room at the time; however, it was necessary (and required by the RWP) in the adjacent 2B RHR pump room, where similar work was in progress. Later during the outage, when several contaminated process lines were opened, the 2B CS pump room was controlled as a contaminated are The concerned individual also stated that after completion of the job, a .

Braidwood health physics technician named " Bob" stated that a mistake had been '

made on the RWP and that it subsequently had been corrected to require protective clothing. The inspector interviewed the identified technician who did not remember stating that a mistake had beer made, but did remember discussing the RWP with some workers when on assignment to the RWP sign-in des earlier in the outage. A review of the RWPs for the CS and RHR pump rooms and a-discussion with the licensee indicated that changes to the RWPs had been made in accordance with procedures and were in response to changes in area work activities, not to discovery of a " mistake." However, the inspector did identify that survey maps for the 28 CS pump room were not included in RWPs written for work on two valves in that roo The RWPs contained only survey- 1 maps for the adjacent RHR pump rooms and the 2A CS pump room. The licensee'

promptly attached the correct maps to the RWP Findings: The allegation was not substantiated; however, a need was identified to_ reinforce _ worker training on the purpose and limitations for protective F clothing and the difference between radiation and contamination. Previous NRC y inspections have indicated that these topics are discussed in the station's helear General Employee Training (NGET) program. This matter was discussed at the exit meeting with the licensee, who agreed to highlight this area during future NGET sessions. The licensee's actions will be reviewed during a future inspectio No deviations or violations of NRC requirements were identifie .0 Review of Bulletins Is L

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{ Closed)-IEBulletin 8.5-03(456/85003-BB,457/85003-88)-

This item addressed the switch settings,-testing, and long-term operability of

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MOVs. .These areas were discussed in Section 4.8.5 of this report. This item is close .0 Introduction to the Evaluation and Assessment of Maintenance An announced NRC combined team inspection of maintenance, fire protection and inservice testing was conducted at the Braidwood Nuclear Generating Station from April 16 through 20, and April 30 through May 4, 1990, while Unit 1 was operating and Unit 2 was in a refueling outage. The inspection addressed fundamental issues in the areas of maintenance, engineering, and technical support. These issues included plant performance, management support, and program implementation. The team goal was to determine if maintenance, fire protection and inservice testing programs were adequate to assure the safe operation and reliability of plant structures, systems, and components to operate on demand. This inspection was based on the guidance provided in NRC Temporary Instruction 2515/97, " Maintenance Inspection," Revision 1, and Drawing 425767-C, " Maintenance Inspection Tree." The drawing, which is  !

attached to this report, was used as a visual aid during the exit meeting to depict the results of the inspection. Acronyms used in this report are defined 7 in Appendix The results of this inspection were derived from data obtained by observation of current plant conditions and work in progress, by review of completed work, and by evaluation of the licensee's self-assessment of maintenance and correction of weaknesses. Major areas of interest included electrical, mechanical, instrument and control (I&C) and the support areas of radiological ,

control, engineering, fire protection, inservice testing of pumps and valves, quality control, training, procurement, and operations. Problems identified by the inspectors were evaluated for effect on Technical Specification operability and technical or managerial weaknes '

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Performance Data and System Selection

' . Historic Data The' inspectors considered the latest Systematic Assessment of Licensee Performance (SALP) report and completed NRC inspection reports. Primarily, the inspectors were sensitive to technical and managerial problems that l- appeared to be maintenance related. Results of this review did not indicate j that any significant problems or weaknesses existed in the maintenance proces The inspectors also reviewed plant operations historic data since January 1989, including Licensee Event Reports (LERs). Only 28 LERs were issued for both units in 1989, which was considerably under the goal of 40 maximum. The 1989 equivalent availability goal of greater than 84% was not met for unit 1; however, this did not appear to be due to maintenance problem The goal was met for unit 2. The forced outage rate was 3.2% for unit I and 1.2% for unit

2; the plant goal was less than 6%. The goal not to exceed 5 unplanned reactor trips for the two units was exceeded by 2; however, three of these trips were due to lightning strikes and none appeared to be the result of improper L maintenance or maintenance personnel. The 1989 goal of 5 trips was established since both units were new plants; this goal has now been reduced to 3 for 1990.

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Eleven engineered safety feature actuation system actuations were encountered during 1989; there was no goal set in this are The average corrective -

maintenance backlog of nuclear work requests (NWRs) available for work for 1989 was 870 compared to a goal of 900. Braidwood's 1989 collective radiation exposure, which included one refueling outage, was 296 man rem. This was considerably.below the'1989 goal of 500 man-rom and the industry average of

.approximately 600 man-rem for a two unit pressurized water reactor (PWR) sit Overall plant performance appeared to be goo In no case were goals not met due to maintenance related problem . System Selection The systems and components selected for this inspection were based on a review of the Probabilistic Risk Assessment (PRA) study furnished to the team by the Reliability Applications Section of the Office of Nuclear Reactor Regulation and data from the Nuclear Plant Reliability Data System (NPRDS). As described throughout this report, emphasis was placed on inspection of specific electrical, mechanical, and I&C components of the ac/dc power, component cooling water (CCW), main feedwater (FW) and safety injection (SI) system Components from several other systems, including balance-of plant (BOP), were also inspecte .2 Description of Maintenance Philosophy The inspectors reviewed site policy statements, administrative procedures, ,

organization charts, established goals, and documents that described improvement programs for the maintenance process. The licensee had a 1 documented comprehensive maintenance plan that included milestones and completion dates for its improvement programs and goals. Discussions by the

. inspectors with selected managers indicated that goals had been establishe l and, in most casu , me The-inspectors determined that the maintenance program was balanced between l corrective maintenance (CM) and preventive maintenance (PM). The licensee appeared to adequately address PM require:.ients for. equipmen l In the area of predictive maintenance the maintenance program was at a level i commensurate with the rest of the industry. The inspectors reviewed the status l of' licensee programs that monitored component performance. Four programs were l identified: motor operated valves, check valves, vibration monitoring (exclusive of IST), and thermography. All programs were considered to be -

effectiv The-licensee's philosophy of maintenance included some aspects 'of the principles of Reliability Centered Maintenance (RCM). One system, FW, was being reviewed for full implementation of RCM, Maintenance history and vendor recommendations were used as a source of this information. The inspectors verified that vendor recommendations were included in the PM program or deviations were technically justifie Management support of maintenance was evident. The corporate maintenance policy, " Conduct of Maintenance at Nuclear Power Stations," when accompanied by implementing procedures, appeared to provide a good maintenance progra l 8 l

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The plan was issued in 1988 but was not scheduled to be fully implemented until 1992. However, most requirements of the policy had been implemented at Braidwood. A key feature of the policy was the use of scheduled system outages in'which surveillances, PMs, and non-critical cms were coordinated in order to improve safety system availability. Although the licensee had not yet implemented this feature, the availability of critical safety systems was considered to be satisfactor A daily conference call was conducted between plant, corporate, aad the other CECO PWR plant management to discuss equipment problems, generic issues, and

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other mutual concerns. Management had instituted a program to return selected ,

components to the respective supplier prior to failure for evaluation and analysis of wear, aging, and abnormal conditions. A new training facility was under construction to provide needed training space; in addition, this-facility was expected to free additional space for maintenance and maintenance support

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us .3 Observations of Current Plant Conditions & Ongoing Work l

l 4. Current Material Condition The inspectors performed general plant as well as selected system and component-

-walkdowns to assess the general and specific material conditiot of the plant, to verify that NWRs had.been initiated for identified equipment problems, and to evaluate housekeeping. The selected systems and components are identified in Section 4'1.2 of this repor .

Walkdowns included an assessment of the buildings, components, and systems for proper identification and tagging, accessibility, fire and security door s l- integrity, scaffolding, radiological controls, and unusual conditions. Unusual' '

l conditions included, but were not limited to water, oil or other indications of l leakage through ceilings, walls or floors; loose insulation; corrosion; excessive noise; unusual temperatures; and abnormal ventilation and lightin '

Unit I was operating and Unit 2 was in a refueling outage at the time of the

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. inspection. The inspectors assessed both the operating and outage material conditions of systems and components. Inspection results follow:

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Cognizant plant management was assigned responsibilities for specific areas and was required to perform periodic walkdowns of those assigned areas, t

Pictures were posted outside high radiation equipment rooms in the auxiliary building. These pictures provided equipment location and configuration to help plan maintenance and reduce radiation exposur *

The ink pen of the BOP chart recorder for the 125 volt ground detector 212 was dry. This condition had existed for three weeks and was indicative of electrical-operator inattention and/or failure to follow procedure BwAp 335-2, " Operator Watch Standing Practices," which required abnormal conditions to be corrected or reported to the shift enginee *

Numerous " hot pink" type ribbons identifying construction punch list items were hangi7 from components in the auxiliary building. Based on licensee

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information,-these items did not appear to be adequately tracked or timely

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Housekeeping was poor _in the unit 2 diesel. driven auxiliary feed pump

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room. Tools, a mop,_ mop bucket, extension cord, and debris were scattered'

in several areas of the room. Materia' storage in some warehouses was -

poor. Material was stored in aisles and on top of storage bins, and in some cases cardboard boxes were stacked so high that bottom boxes were crushe No-damaged material was found in the crushed boxes. The relay room in the 345'kV switchyard was extremely dusty and unkep *

The inspectors noted the absence of steam and water leaks along with a reduction of Tygon tubing from earlier inspections that directed water -

leaks to floor drains. The licensee had initiated a leak control program in January 1990 that had dramatically reduced the amount of leaks throughout the plant. This program included installation of a new type ,

valve packing material, daily walkdowns in the auxiliary and turbine buildings to make minor packing adjustments to non-safety related valves, and a system to track and trend catch basins. The inspectors considered ,

this~ program a-significant strengt *

There was in-leakage of ground water at several places in the basement of the auxiliary buildin'g. The licensee was aware of the problem which did not present a safety' concer *

Several leaks were noted on the Unit I feedwater pumps 1B and IC. The (

licensee stated that Unit I was scheduled for a derating in June for repairs of these leaks.

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• . -Indications of smoking around combustible materials were found in the unit-1 auxiliary building (but not the radiation control area) and unit .1

. turbine building. Similar indications were noted in the temporary storage l; of-treated wood used for scaffolding-outside on the west end of the turbine buildings. An open five gallon can was also found in the

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Westinghouse tool trailer which contained-less than a pint of mineral spirits. A contractor representative indicated that no smoking was allowed in the traile The inspector reviewed procedure BwAP 1100-1 !

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" Station Housekeeping / Material Condition Program," Revision 1, and determined that smoking was not specifically _ prohibited around com- ,

bustibles. The _ inspector also determined that a fire protection self-assessment had been completed February 6-8, 199 The self-assessment report indicated that there had been one fire in the turbine building in 1989 caused by a discarded cigarette. The report also

. pointed out that cigarette smoking introduced an unnecessary ignition

_ source into the plant. The inspector concluded that the licensee was not ,

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effectively controlling ignition sources due to smoking and that the potential for fires was increased. These conclusions were discussed with and acknowledged by the license The method for identifying equipment problems had been effectively implemented,

" Laundry tags" were used to identify items that required maintenance and were hung concurrently with the initiation of NWRs. The tags were color coded by 5 year, which allowed old tags to be easily recognized. In most cases, equipment problems identified by the inspectors during plant and system 10 I

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walkdowns had already been identified during management walkdown._ Of 48 laundry tags identified during the walkdown, 43 had open NWRs written against ,

them. Two examples of defective equipment were noted that were not documented !

by. laundry tags or NWRs. The inspectors considered this identification method good and we'll implemente l

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A " housekeeping and material condition tag," different from a laundry tag, was j used to identify minor discrepancies noted during walkdowns. The governing ;

procedure contained guidelines for identifying minor discrepancies. Action !

was required within three weeks from the date of the tag. NWRs were initiated when the required work was outside the scope of the procedur ,

The material condition of the plant was considered good and appeared to have 1 been effectively maintained to assure the operability of equipment and !

components at a level commensurate with the equipment or component's functio ,

4. Ongoing Work The inspectors observed ongoing work in electrical, mechanical, and I&C area The inspectors selected work activities from the daily working schedule, work assignments in individual maintenante shops and through discussions with individual foremen. Where possible, safety significant activities were chosen for direct observatio Maintenance activities were observed to determine if those activities were performed consistent with the effect on the safe operation and reliability of the licensee's facility. Work activities were assessed in the following areas: work control and planning; management presence, involvement, and knowledge; quality control (QC) presence and involvement; health physics (HP)

support and hazards: procedure availability, adequacy, use and general conformance to NUREG/CR-1369, " Procedures Evaluation Checklist for Maintenance, Test and Calibration Procedures Used in Nuclear Power Plants," Revision 1; personnel training' and qualification; materials availability,. adequacy, and use; measuring & test equipment (M&TE) application and calibration; post '

maintenance testing adequacy including proper acceptance criteri During the observation of ongoing work, the inspectors noted'that maintenance personnel appeared to be adequately trained and qualified for the work; support and interface between organizations appeared to be above average and team effort was evident. Work packages were well prepared and in some cases -

contained photos or diagrams of the work to be done. In most. cases, procedures were thorough, well written, and easy to use. A feedback sheet was provided in the package to provide information for procedure improvement. The NWR tracking-system provided an excellent method for determining the status and location of open-NWR In many cases, the work analyst walked down the equipment to be repaired while planning the work an' in some cases after work was complete. No L' system was in place, however, to d u rmine the efficiency of maintenance work.

l' Maintenance work that had to be redone was not considered rework unless the system or component had already been turned over to operations personnel at the time of failure.

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l~ 4.3. Ongoing Electrical Maintenance The inspectors observed portions of 11 electrical maintenance activities as discussed below:

A31211 Install recorder to take phase, voltage, & current readings A32701 Inspect MCC bucket and test molded case circuit breaker A35305 Replace instrument inverter 21 gating boards A35371 Inspect & pull cables for post accident neutron _ monitoring system A35981' Perform work on battery charger 2DC03E A38475 Replace 2MS001D hydraulic assembly sub-components A40346 Calibrate relay PR 14A-550/551 A40394 Remove / perform maintenance of valve 20C9415-A40484 Repair diesel generator governor dropping resistor A40757 Investigate dc ground on bus 111 BwHS 4002-066A1, " Periodic Protective Relay Calibration Procedures,"

Revision 0 The' inspectors concluded that electrical maintenance activities in the pertinent areas described in 4.3.2 were adequate and accomplished by skilled maintenance personnel, Personnel were knowledgeable and adequately trained in the work performed. Management and workers exhibited a teamwork philosoph The inspection and testing of 480 volt motor control centers and motor operated valve (MOV) limit switch compartments were considered strengths. Maintenance personnel meticulously documented acceptance criteria and obtained proper approval for performing the-required work. QC hold points were included in-many procedures and QC involvement in electrical activities was considered above average. However, weaknesses were identified in acceptance criteria, as low as reasonably achievable (ALARA) practices, and equipment qualification (EQ) as described below:

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A32701 - Thermal overloads were tested to trip at a maximum of 30 seconds; however, a minimum trip time acceptance criterion was not included. The Nuclear Engineering Department (NED) stated that national standards did not require minimum time criteri After discussions with station personnel, NED subsequently decided that inclusion of such criteria would enhance procedure *

A35371 - Post accident neutron monitoring cable 2NR13E was pulled back because of a failed pressure test to verify cable integrity. The licensee could not determine when the damage had taken place since the cable had not been pressure tested before pulling. Since this work was accomplished in containment, good ALARA practice should have been to pressure test the cable prior to pulling in order to avoid unnecessary repeat wor _ . . . . . . . _ . .

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A38475 - On April 30, 1990, the inspectors determined that control cable-to be attached to a hydraulic actuator control solenoid of main steam isolation valve 2MS0010 did not have all required environmental documentation and approvals. Also, the cable insulation material was not shown in the FSAR for control cable use.. Procedure ENC-QE-42 required that EQ documentation packages include a specific station evaluation and be approved by CECO Nuclear Station Engineering Department / Project Engineering (NSED/PE). The FSAR, paragraph 3.11.9, required that control cable. insulation be made of EPR. Contrary to these requirements, there was no specific station evaluation or approval by NSED/PE, e~i the insulation material was not EPR. The licensee quickly deten...ned that the cable had not been used elsewhere in a safety-related applicatio The inspectors concluded that this was an isolated instance of personnel error caused by a failure to read and understand ENC-QE-4 However, the failure to obtain the proper EQ reviews that could result in analyzed material being used in a harsh environment is an example of a violation of 10 CFR 50, Appendix B, Criterion V (457/90008-01).

The inspector witnessed an overspeed trip of the emergency diesel generator performed in accordance with BwVS 900-6, Revision 2. The test met the acceptance criteria. However, the inspector was concerned about the adequacy of the overspeed trip setpoint determinatio *

The overspeed trip was required to be set at 660 + 5 RPM. A chart recorder that'used chart paper with a resolution of 20 RPM was used to set and document the calibration On the chart paper 20 RPM spanned a distance of 1/25-inch. Therefore the test engineer was required to-verify visually that the trace was within an area of width 1/50-inc The licensee was aware of the problem from previous testing but had taken no action. The-' inspector concluded that the resolution precluded setting the. trip setpoint accuratel .3. Ongoing Mechanical Maintenance The inspectors observed portions of 15 mechanical maintenance activities as

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A29113, Modify Unit 2 reactor coolant drain line valves A29114-A33401 Perform EQ inspection on CVCS MOV 2CV1120 A33403 Inspect safety injection isolation valve 2SI8802A A34344 Repair packing leak blowing steam on valve 2ES062B A34496, Replace seal and seal injection hoses on reactor coolant pumps A34498 A35029 Perform 18 month teardown surveillance on 2A diesel gen (r A35439 Replace high pressure seals on seal table 2RC-01R

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A35568- Disassemblo/ inspect feedwater check valves 2FWO79A, B, C, and'D ,

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A38333 Perform signature trace on AFW discharge MOV 2AF013H A40322 Inspect / repair Limitorque on Unit 2 SRVC loop. isolation valve ;

The inspectors concluded that the mechanical maintenance activities in the pertinent-areas described in 4.3.2 were adequate and accomplished by skilled maintenance personnel. Parts removed were immediately identified and bagged for. protection. Maintenance personnel appeared to be knowledgeable and adequately trained in the work performed; however, weaknesses were identified in planning, coordination, and performance as described below:

A35029 - This surveillance on 2A diesel generator was in the post maintenance verification phase. The inspectors observed instances of poor planning, coordination, and performance indicated as follows. A dial .

indicator was not available when needed even though the work being done would require an indicator. The proper-cure time was not obtained for a gasket sealant used for the first time. Delays in testing occurred 1

because personnel were late and work was not completed by another grou Personnel failed to replace a gasket shown on equipment drawings. The licensee acknowledged the need for improvement in this are ,'

4.3. Ongoing Instrument and Control Maintenance The inspectors observed portions of six I&C maintenance activities as discussed below:

A25980 Troubleshoot 7300 NCB card A39494 Reca11brate (partial) RWST level-loop 2L-0930 BwlP 2400-026 Calibrate 0-100 psi test gauge serial BR258

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BwIS 3.1.1-214 Calibrate (surveillance) NIS power range N41 BwIS 3.1.1-327 Calibrate (surveillance) SG A level transmitter 2L-0519 BwIS 3.3.5-203 Calibrate (surveillance) RHR A heat exchanger thermometer The inspectors observed the use of the micro electronic surveillance and calibration system (MESAC). MESAC was designed and developed at Braidwood Station to dynamically test instrument systems. To accomplish this, MESAC '

injected continuous test signals that simulated design basis input Simultaneously, MESAC recorded the dynamic. response of the instrument system

. and compared the data with expected values to provide a basis for evaluation, ,

-The test equipment connections to the instrument system did not raqu1re lifting leads or using jumpers. The inspectors concluded that this mainod of testing t was suparior to the current industry method of discrete static testing, and substantially red d the risk of inadvertent reactor trips. MESAC was-considered a sig , cant strengt .

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j The inspectors concluded that I&C maintenance activities in the pertinent areas described in 3.3.2 were adequate and accomplished by skilled maintenance i personne The maintenance personnel appeared knowledgeable and well trained ,

for the work performed. However, a concern was identified relating to human l factors during the observation of work as described below:

A39494 - An I&C technician performed a partial recalibration of the RWST loop using BwIs 3.3.6-301, Revision 0. The procedure required the i technician to determine both the trip and reset setpoint acceptance l criteria (range) by mental calculation from a set of point values and '

tolerances. In particular the reset range was determined by first i mentally subtracting the reset margin point value from the as-left trip I setpoint and then applying the tolerance. The licensee indicated that the method was used in many I&C procedures, but the completed procedure received two review No examples of out-of-tolerance conditions were found that were attributed to this method. The inspector concluded, however, that this weakness might allow the instrument to be outside technical specification limits and was not consistent with the guidance presented in NUREG/CR-136 . Radiolotical Controls ,

The inspectors observed the major support functions provided by radiation protection (RP) personnel for maintenance. These functions included radiation work permit (RWP) preparation; ALARA reviews of modifications, procedures, and work packages; and field support of going work. The inspectors also performed independent reviews of documentation and discussed radiological controls with plant personne The results of these observa1. ions follo RP personnel actively supported the maintenance planning process. Both the RP scheduler and the ALARA analyst regularly attended the daily work scheduling meeting, and RP personnel frequently met with maintenance supervision to discuss on going and future work. The involvement of the ALARA analyst was particularly good. This highly experienced individual worked well with both licensee and contractor personnel to minimize radiation exposure. For the Unit 2 refueling outage, a containment coordinator was assigned to facilitate work in the containment and ensure that the area was returned to ncrmal after maintenance. RP personnel control of radioactive material and contamination in support of maintenance was generally good. RP personnel prioritized plant area decontamination efforts and tracked the percentage of contaminated floor are Contaminated areas were kept to a minimum by an ambitious clean-up progra Strippable ccatings were applied to the reactor cavity to facilitate

, decontaminatio Two weaknesses were identified:

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Several contamination incidents near the main containment step-off pad indicated a need for better surveys of highly contaminated or potentially highly contaminated materia *

The irgetors observed several minor problems with radiological control l- signs sucn as misuse of a step-off pad at an emergency exit, or improperly l worded signs on doors that controlled access to high radiation areas.

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The licensee used a recently acquired optical disc / video-mapping system for job planning. The system, the Video Information Management System, consisted of several thousand digitize 1 photographs of plant areas and equipment stored 4 on a laser disc that allowed both RP and maintenance personnel to view an area or equipment without entering the radiological controlled area. The inspectors considered this system a strengt Television monitors and radios were used in high radiation areas to monitor activities. This resulted in closer supervision of the areas with reduced exposur RP training and qualifications of maintenance and support personnel were adequate. There was no advanced radiation worker training program, but mockups and videotapes of work activities were used where needed. The RP technicians that monitored maintenance activities were knowledgeable of radiological conditions at the job site Workers observed during this inspection were aware of RWP requirement External and internal exposure control of maintenance personnel was good. The licensee maintained worker exposure ALARA through stringently controlled administrative exposure limits. For work in high radiation areas, electronic dosimetry with audible alarms was used in addition to conventional dosimetr t Hydrogen peroxide was added to the reactor coolant during plant shutdown to enhance radioactive cobalt removal before outage work commence This process helped the licensee to meet exposure limit goals. Respiratory protection equipment and portable high efficiency filter units were frequently used to limit internal exposur . Material Control and Control / Calibration of Measurino & Test Equipment 4,3. Material Control The inspectors reviewed the . methods used by maintenance and supporting organizations to control replacement parts and materials. This review included replacement parts and materials uted durfog observed maintenance activities as well as parts storage methoiis and a eas, in addition, the inspectors observed conditions in thu warehouses and material storage area Access to all storage warehouses was controlled, Safety related and nonsafety related parts and material were stored in the same warehouses, but the safety related material was segregated by locked entlosures. Material storage was as previously described in Section 4.3 1, Materials with limited shelf-lives wtre stored throughout the warehou.as. The materials were not identified as limited shelf ~ life or labeled with expiration dates; however, a computerized system was in place that tracked the expiration date. Material with expired shelf-life was placed on hold for disposition. No

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limited life material was found available for use that had c:ceeded the ,

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A computerized system was used for parts inventory and control. This system allowed a computer search for parts throughout all CECO warehouses and was expected to substantially reduce the number of spare parts required to be

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stocked at the plant. In addition, the system was designed to increase the availability of spare parts to support maintenance activitie The system prepared an order for stock parts when specified minimums were reache The plant did not have a system for tracking and control in this area, but maintenance work on hold for parts did not appear to be excessiv ,

Control of material in the fabrication shops was also reviewed and was acceptabl Locked " hold" areas were provided for nonconforming items and >

materia No weaknesses or concerns were noted in the control of replacement parts and materials and the inspectors concluded that control was satisfactor .3. C_ontrol and Calibration of Measuring and Test Equipment

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The inspectors reviewed the control and use of M&TE. All defective or

" calibration due" instruments were stored separately from those that were in calibration and acceptable for use. Procedures were used for the issue, return, and recall of M&TE. Technicians were trained on the proper use of the instruments and verified that test instrument calibrations were not past du Test equipment use traceability was accomplished by recording the equipment unique identification number on the NWR, and then transferring this number to the Total Job Management (TJM) data base at the completion of the job. If the piece of test equipment was later found to be out of tolerance, the TJM could be searched quickly for all NWRs affected and evaluations performed as appropriat The inspector verified the calibration of selected M&TE items and found no discrepancie Calibration status was maintained on a central computer using the unique identification number mentioned previously. Calibrations were traceable to national standard .4 Review and Evaluation of Maintenance Accomplished 4. Backlog Assessment and Evaluation The inspectors reviewed the amount of work accomplished compared te the-amount of work scheduled. Emphasis was placed on work that could affect the operability of safety-related equipment or equipment considered important to safety, which included some BOP components. Maintenance work item backlogs were evaluated for cause and impact on safet .4. Corrective Maintenance Backlog The average total backlog of non-outage NWRs available for work during 1989 was 870; the established goal for 1989 was 900. This goal was reduced to 850 for 1990. The average number of NWRs available for work for the first four months of 1990 was 987. This increase was apparently due to unit 2 outage work. The average number of NWRs completed per month during the past year was 320. Approximately three months were required to complete the current backlog of NWRs if no others were added. Although this appeared slightly high,

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a review of selected NWRs in the backlog did not indicate that any significant work had been unduly delaye Ninety-nine NWRs were on hold for part A selective review of these NWRs did not indicate any significant work on hold for part The NWR backlog was reviewed for each discipline and no specific problems were noted in any disciplin ,

Overall the corrective maintenance backlog did not appear to be excessiv No safety significant work appeared to be improperly delaye .4. Preventive Maintenance Backlog Station performed PM items were scheduled and controlled utilizing the same computer system used to control station surveillances. As a result, a list of past due surveillances contained both past due surveillances and past due PM Since most surveillances were required by the Technical Specifications, this-list appeared to provide added emphasis and priority to performing timely PM The number of.past due surveillances and PMs appeared to be low and most were delayed due to the plant being in the wrong mode for performanc PMs performed by off-site organizations, such as the Operations Analysis Department (OAD), were controlled by a system not directly under station control. Several PMs on important BOP equipment, such as 345 kV switchyard breakers, were found to be well past the scheduled completion dates. During discussions with licensee personnel, the inspectors were told that some coordination problems were involved in the failure to perform the breaker PMs in a timely manner. Licensee personnel stated that all 345 kV breaker PMs were scheduled to be completed before June 30, 199 Other than the above noted problem, the backlog of PM items appeared to be low. No significant work was inappropriately delayed, j

Review and Evalaation of Completed Maintenance

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4. The inspectors selected equipment and systems identified in Section j 4.1.2 of this report for further review. The purpose was to determine if I specified maintenance was accomplished or would be accomplished as require This review included: , Evaluation of completed CM and PM for use of qualified personnel, proper prioritization (based on risk), QC involvement, quality of documentation i l for machinery history, acceptance criteria, description of problems and i resolutions, and post maintenance testing.

, Evaluation of the extent that RCM was factored into the established !

l maintenance process and that vendor manual recommendations, NRC Bulletins, NRC Notices, Service Information Letters (SILs), Significant Operating j Experience Reports (SOERs), and other outside source information was j utilize i

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.s * Evaluation of procedures for completeness, necessary approvals, adequacy of work instructions, ease of use, inclusion of QC hold points, acceptance criteria, and general conformance to NUREG/CR-136 .4. Past Electrical Maintenance The inspectors reviewed the following 12 completed NWRs in the selected systems of Section 4.1.2 for the attributes included in section 4. A17464 Clean and inspect instrument bus on 214 transformer A17525 Perform valve signature trace A19423 Perform alignment and inspection per Tech. Bul. NSID-TB-87-11 A22663 Add interposing relay to containment sump isolation circuitry A26604 Calibrate bus 259 relays A29312 Troubleshoot / repair 211 battery charger A31682 Perform valve diagnostic test A31768 Perform MOV surveillance A31200 Locate ground and clean 250V DC battery 123 A33313 Clean and inspect instrument bus 111 inverter capacitors A35312 Replace bus 111 battery charger output gating board A35911 Repair bn 142 cubicle #14 puffer tubes The NWRs were satisfactory in scope and content. Prioritization was proper and QC involvement was excellent, Necessary procedures and the calibration status of M&TE were included in the work package Documentation of corrective action was sufficiently detailed for trend identification and root cause analysis when combined with other historical plant data. The licensee was very conservative when changing out parts or components that were near the end of useful lif Rather than extend the life of the components in harsh and mild environment by evaluation, parts were replaced. This was considered a strength. The following weakness with inadequate engineering review and evaluation of an LER was noted:

A33313 - The inspector reviewed the basis for this NW LER 456/89005, written to report the trip of Instrument Inverter 111 due to failure of electrolytic capacitors, contained a licensee commitment to change out all electrolytic and oil filled capacitors with a frequency of three years-starting with the September 1989 refueling outage. The inspector determined, through information provided by the licensee, that only 30% of the Unit I capacitors were replaced in the 1989 outage. In addition only 70% of the Unit 2 capacitors were replaced during the current outage. The licensee stated that unavailability of parts prevented personnel from replacing all capacitors. However, the licensee did not perform an

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engineering evaluation nor revise the LER to reflect this problem. While

! this delay did not appear to present an immediate safety concern, the

. inspectors concluded that the licenses had responded poorly to this issu The inspectors reviewed the following current procedures for the attributes in 4.4.2

BwHP 4002-008, " Inspection and Testing of 480V MCC Draw-out Units"

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BwHP 4002-023, " Cleaning, Inspection and Maintenance of Inverters" BwHS 4002-066A1, " Periodic Prntective Relay Calibration Procedures" BwHS 4002-071, " Inspection / Maintenance Type DAP Switchgear and Cubicles" BwHS 4002-074, " Inspection / Maintenance 480V Type DS Breaker and Cubicles" BwHS 4009-032, "MCC Thermal Overload Protection Surveillance" BwHS 4009-041, " Periodic Protective Relay Calibration Reactor Trip and ESFAS Instrumentation and Containment Penetration Conductor Overcurrent Protective Devices" Bw0P AP-5, " Racking Out 4160V/6900V Air Ckt Bkr to Disconnect Position" SPP-89-12, "24V Aux Feed Battery Bank 5 Year Capacity Test" "

2BwVS 8.2.1.2.c.4-1, " Unit 2 125V Battery Charger Operability" 2BwVS 8.2.1.2.d-1, " Unit 2125V Battery Bank Operability Battery Service Test The procedures were generally satisfactory. The responsiveness and corrective actions to Notices of Defect (10 CFR Part 21) and Westinghouse bulletins were considered excellen Post maintenance testing was properly identified and was satisfactory in scope. The following concern was identified:

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SPP-89-12 - The inspector was concerned with the adeouacy of the PMs performed on the AFW diesel engine. The licensee corndered compliance with Technical Specification 4.7.1.2.1, which required the AFW pump to achieve a flow greater than 85 gpm, sufficient to determine operability and to meet vendor recommendations. However, Technical Specification 4.7.1.2.3 required that the auxiliary pump diesel be demonstrated operable by subjecting the diesel to an inspection in accordance with its manufacturer's recommendations for the " class of service" at least once every 18 months during shutdown. Even though all Technical Specification requirements for operability were met, the inspector was concerned that the vendor manual recommended that valve and fuel injector adjustments in the operating mechanism be periodically checked. The licensee had not performed these checks during refueling nor during preoperational testing. The inspector was concerned with the apparent lack of an l

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engineering evaluation, for example, defining the actual class of service and showing why the " recommendations" were not considered necessary or that it would be checked in the future. Another weakness was the failure to confirm that the engine would come up to rated speed (1800 rpm) within 10 seconds as required by design specificatio Based on the review of completed cms and PMs, backlog, and procedures, the inspectors concluded that, in general, past performed maintenance had '

been accompitshed in a satisfactory manne .4. @ c Mechanical Maintenance The inspec', ors reviewed the following eight completed NWRs in the selected systems of Section 4.1.2 for the attributes included in Section 4. ,

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A30083 Repair hydraulic discharge valve on circulating water line A30235, Stop leakage from pneumatic solenoid valve on 1FWOO98,0 MFW A34538 isolation valve  !

A30640 Modify MFW regulating valve IFWOO6A A32092 Reprir seal in screen wash booster pump OCWO4PB A36065 Verify MSSV 2MS013C setpoint setting A37100 Repair seal in screen wash booster pump OCWO4PA A37719 Repair packing leak from MFW discharge valve IFWOO2B The NWRs were generally satisfactory in scope and content. The inspectors noted that safety-related work was consistently well documented, thorough, and easy to understand. However, B0P work was of ten difficult to follow and included very little discussion of the problem and repairs.mad The inspectors noted that in all cases, the NWRs received prior approvals for the described wor Hold points were noted and maintenance '

problems / resolutions were documented, The necessary procedures were included or referenced and calibration status of M&TE was recorded. The following ;

weakness with post maintenance test determination was observed:

NWRs A32092, A37100 - The maintenance involved pump seal work and

' reassembly. BwAP 1600-ITI, " Post Maintenance Checklist", Revision 0, was attached to the NWRs and indicated that the work performed could not affect vibration characteristics. The inspectors disagreed, since the work described often affected vibration characteristics, and requested the i licensee to reevaluate the post maintenance testing requirements. The licensee determined that vibration measurements were appropriate. The tests were immediately completed. One pump had excessive vibration and rework was initiated. The licensee also placed the pumps in the BOP IST vibration program.

l The following three procedures were reviewed for the attributes in section 4.4.2:

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g e BwHS 4002-063, "Limitorque MOV Degradation Inspection," Revision 0 BwHS 4002-064, "Limitorque MOV Age Degradation Inspection," Revision 0 BwMP 3305-045, "Limitorque Actuator SMB-000, SMB-00, and SBD-00 Overhaul,"

Revision 1 The procedures were thorough, well written, and easy to us In some cases, '

pictures or diagrams were included to provide clarity or detai Based on the review of completed cms and PMs, backlog, and procedures, the inspectors concluded that past maintenance had been accomplished in a satisfactory manne .4. Past Instrumentation and Control Maintenance The inspectors reviewed the following NWRs for the attributes in section 4.4.2:

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A22488 Reca11brate ILT-549 per Test / Measurement Evaluation 89-057 A22733 Verify calibration of 1FT-520 A22851 Repipe sensing lines to bottom of transmitter for proper venting A23660 Verify calibration of IFIS-610 A23749 Verify calibration of ILI-549 i A24924 Replace Barton transmitter with Rosemount A27867 Verify calibration of ILI-549 A29480 Recalibrate 1FT-520 per Test / Measurement Evaluation 89-031 A30515 Troubleshoot u.1 stable operation of IFW-520 A36729 Verify calibration of 1FIS-610 A37144 Troubleshoot cause of IFB-520 bistable trip A37293 Verify calibration of 1FIS-610 l- The NWRs were satisfactory in scope and content. Prioritization was proper and QC involvement adequate. Documentation of corrective action was sufficiently detailed for trend identification and root cause analysis when combined with other historical plant dat Post maintenance testing was properly identified i and was satisfactory in scop The following three procedures were reviewed for the attributes in section 4.4.2:

BwlP 2500-052, " Installation and Testing of Loose Parts Monitoring Accelerometers," Revision 0

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i BwlP 2500-058, " Calibration of Pressure Control Loop for Chiller Condenser," Revision 1 BwIP 2500-098, " Calibration of Hydrogen Recombiner H2 Analyzer," Revision 0 The procedures were well written and consistent with vendor instruction manuals. - Acceptance criteria were adequate and provided actions to be taken if not me The inspectors reviewed actions taken in response to the loss of fill fluid defect identified by the Rosemont 10 CFR Part 21 notification of February 7, 1989. The licensee had identified 42 Rosemont transmitters within the scope of the notification. Individual trend records were established that showed the results of all calibrations including as-found and as-left data. The inspector examined each record for unexplained deviations. Only one, also identified by the licensee, was questionable. The anomaly was not characteristic of the loss of fill fluid defect nor did it present a safety concer The inspector concluded that actions taken in response to the Part 21 defect notification were satisfactor The computerized system used for tracking and maintaining status of open items, such as Generic Letters, Bulletins and Notices, NRC commitments, and other documents was considered very goo Based on the review of completed cms and PMs, backlog, and procedures, the inspectors concluded that past performed maintenance had been accomplished in a satisfactory manne .5 Fire Protection The inspector observed various areas of the fire protection program to ascertain the effectiveness of the licensee's licensing commitments. The roll of maintenance was particularly examine . Fire protection Activities The inspector witnessed an unannounced fire drill to determine whether fire brigade personnel were properly trained and ready for fire suppression activities, and if ac'aquate fire fighting equipment was available. Particular attention was given to the fire brigade leader's direction of fire fighting efforts, donning of protective clothing, use of hose streams (actual flow),

use of portable radio communication equipment, brigade timeliness, and fire brigade leader interaction with the control roo The drill simulated a fire / explosion hazard that occurred due to a broken hydrogen tank gage that resulted in flame impingement on an adjacent hydrogen storage tank west of the turbine building. The drill was followed by a critique that included a discussion of alternatives and improvements in fire fighting. The inspector concluded that the fire brigade performed well and the fire drill was satisfactorily performe However, the following weakness with timeliness of action was identified:

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The fire brigade leader should have requested earlier outside assistance and evacuation of the turbine building. The off-site fire department was notified approximately six minutes after the brigade chief arrived on the scene. The evacuation alarm sounded approximately 12 minutes after the brigade chief arrived on the scen . Ongoing Fire Protection Maintenance Activities The inspector observed portions of the surveillance test associated with Procedure No. BwHS 4009-03151, " Semi-Annual Surveillance of the Fire Detection Instrument Trip Actuating Device and Supervised Circuits For Unit One Lower Cable Spreading Rooms Detection Zones ID-49 through 10-56," Revision 2. This surveillance tested the fire detector circuitry and verified receipt of the annunciated fire detector in the control room. The surveillance test dated April 18, 1990, was satisfactorily performed and satisfied applicable Technical Specification section . Past Fire Protection Maintenance Activities The inspector reviewet the following completed surveillances:

BwHS 4002-003 " Surveillance of Unit One H2 Seal Oil Area Suppression Zone 1S-19," Revision 0, 3 tests BwHS 4002-051 " Surveillance of Unit Two Detection Zones 20-9 And 2D-36," Revision 0, 3 tests BwHS 4009-006 " Surveillance of Unit One Detection Zones 10-38, 71 and 72 (U.V.)," Revision 0, 3 tests BwHS 4009-046 " Semi-Annual Surveillance of Unit Two D.G. And Suppression Zones 25-37 through 2S-42," Revision 0, 3 tests BwHS 4009-052 " Upper Cable Spreading Room Area 2EE1 Halon System Actuation 18 Month Surveillance," Revision 1, I test BwHS 4009-059 " Diesel Generator Room 2B And Day Tank koom 2B Low Pressure CO2 System Actuation 18 Month Surveillance,"

Revision 0 and Revision 1, 3 tests BwHS 4009-068 " Semi-Annual Surveillance of Unit Two UCSR Halon Suppression Zones 25-33 through 25-36," Revision 0, 3 tests BwHS 4009-038 " Upper Cable Spreading Room Halon System Solenoid Valve Position Monthly Surveillance," Revision 1, 3 tests OBw0S FP.2.1.W-1 " Motor Driven Fire Pump Weekly Surveillance Data Sheet,"

Revision 0, 3 tests OBw0S FP.2,2.W-1 " Diesel Driven Fire Pump Weekly Surseillance," Revision 0, 3 tests OBw05 FP.3.2.Q-1 " Sprinkler Systems Inspectors Test Q;arterly Surveillance," Revision 2, 7 tests

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o o OBw05 FP.3.2.Q-2 " Sprinkler System Main Orain Quarterly Surveillance,"

Revision 1 and Revision 2, 10 tests OBw05 FP.4.2.V-1 "CO2 Storage Tank Level & Pressure Verification Weekly Surveillance," Revision 0, 3 tests OBw0S FP.7.2.M-1 " Supervised Fire Door Monthly Surveillance," Revision 1 and Revision 2, 5 tests OBw05 FP.7.2.W-1 "Lc-ked Fire Door Weekly Surveillance," Revision 1, 3 tests l The surveillances were generally acceptable. In cases where the licensee !

identified deficiencies, the deficiencies were corrected or corrective ac', ion was taken. However, the following weakness in the timeliness of the performance of an engineering evaluation of fire pump test results was observed:

OBw05 FP.2.1.W, " Motor Driven Fire Pump Weekly Surveillance," Step specified a minimum of 40 amps for the motor current acceptance criteria. All tests indicated a motor current less than specified (38 amps, 38 amps, and 34 amps, respectively). In all three cases, the technical staff engineer was informed of the low motor current and verbally indicated to test personnel that the low motor current was acceptable. In further discussions, the inspector was iformed that in surveillances conducted since April 13, 1989, the recorded current was 1-2 amps below the 40 amps criteria. In none of these cases was a written engineering evaluation of the test results or acceptance criteria performed. On April 13, 1990, the licensee initiated a request to perform this evaluatio Since other acceptance criteria of the tests were met, the inspectors did not consider the motor condition or pump l'

operability to be a problem. However, the inspectors were concerned with the timeliness in the performance of an engineering evaluation to ensure the accuracy of a procedure required for fire pump operabilit The inspector reviewed the following administrative fire procedures for adequacy:

! BwAP 1100-11 " Fire Prevention for use of Lumber and Other Combustibles,"

Revision 1

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i BwAP 1100-10 % Control and Use of Flammable and Combustible Liquids l and Aerosols," Revision 0 l

l BwAP 1100-15 " Fire Prevention and Welding, Cutting, Grinding or Performing Open Flame Work (Hot Work)," Revision 2 The inspectors determined that the procedures were generally well written and intended to minimize the amount of combustibles in a safety-related and safe shutdown are . o Maintenance Work Control The inspectors reviewed several maintenance activities to evaluate the effectiveness of the maintenance work control process to assure that plant safety, operability, and reliability were maintained. Areas evaluated were control of maintenance work requests, equipment maintenance records, job planning, prioritization and scheduling of .vork, control of maintenance backlog, maintenance procedures, post maintenance testing, completed documentation, and review of work in progres The inspectors reviewed maintenance planning to determine if maintenance work '

activities were adequately controlled. Work planning meetings were conducted

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daily with inputs from all disciplines. Maintenance was planned and scheduled based on plant operations during the subsequent three week period. This was considered a strengt The inspectors reviewed the method used by the licensee to schedule and prioritize CM/PM maintenance work. The inspectors discussed the matter with work scheduling personnel and reviewed information used in this area. NWRs were routed to operations for prioritization based on the urgency of the work to be done and plant conditions. This information was used to schedule plahning activities as well as schedule work. Two of the schedulers were-licensed operators, which appeared to be an asset in communications between maintenance and operations. In addition, the inspectors reviewed the forced outage schedule of preplanned work that could be done in the event of a unit trip. This schedule was updated on a weekly basi During the review of completed NWRs, the inspectors noted good preparation of work packages. This was due, in part, to the utilization of computer programs that enabled the work analyst to write and prepare packages in a consistent manne Many maintenance tasks, such as valve packing replacements, used computer prepared work instructions. The work analyst was used effectively in walking down the work before writing the work instructions or revising the instructions if problems arose. Computers were used to electronically hold and order parts needed for maintenance. Pre and post work checklists were used and appeared to contribute to the consistent preparation of NWRs. A Master Operating Tracking System was used to track the status and location of all surveillance, lubrication, and out of service activities. The inspectors '

considered the use of .omputers as a significant strength in the preparation of the NWRs.

l l Engineering and Technical Support l The inspectors reviewed the activities of the engineering organizations related to the field activities of modification installation a..d testing, maintenance support, and material qualification. Support was provided by the plant Technical Staff and Engineering and Construction Departments, the latter-divided between an on-site and off-site organizatio <

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4. Technical Staf f/ System Engineering The Technical Staff provided system engineering support. Position descriptions were implemented for all members of the organization. The technical staff engineer monitored system performance, trended important system parameters, initiated corrective actions, performed surveillances, inve>tigated causes of deviations, and performed other duties associated with the usual responsi-bilities of a plant enginee System assignments considered the complexity.and importance of the system to safe, reliable operation of the plant appropriate to the level of experience of the individua The inspectors reviewed the implementation of the system engineer function through direct questioning of technical staff engineers and the quality of technical staff responses to issues raised during the inspection. Most engineers exhibited technical and administrative knowledge consistent with prior plant experience and length of system assignmen The inspectors concluded that the licensee had implemented the concept of system engineering adequately and that technical staff engineers performed in a manner compatible with safe and reliable plant operatio . Engineering and Construction Department The Engineering and Construction Department (ENC) maintained an on-site organization under a project manager. The engineering group provided support in the areas of plant modification and problem solution outside the capabilities of the Technical Staf The construction group supported maintenance by obtaining and coordinating contract support for such areas as welding and turbine overhaul. The inspectors observed that ENC provided correct and timely responses to plant problems and concluded that ENC support was consistent with safe and reliable plant operatio . Trend Analysis The inspectors evaluated the extent that maintenance histories, NPRDS information, LERs, negative trends, rework, extended time for outage, frequency of maintenance, and results of diagnostic examinations were analyzed for trends and root causes for modification of the PM process to preclude recurrence of equipment or component failures. The licensee used a single integrated trend identification, classification, and evaluation system to combine data from both internal and external source Equipment failure analysic was initiated by several methods including:

Deviation Report, Deficiency Report, or Problem Analysis Data Sheet (PADS). The method used depended on the type of failure, plant effect, and regulatory requirements. All reported problems were classified and placed on the Nuclear Tracking System (NTS) data base. Concurrently plant staff classified and added to NTS LERs and problems reported by outside source These outside sources included other licensee facilities, NRC, vendors, and Institute of Nuclear Power Operations. The Regulatory Assurance Department identified and evaluated trends. The individuals responsible for these activities were trained in root cause analysi ,

o The process of trend analysis was contro led by BwAP 1250-8, " Identification, l

Tracking and Resolution of Adverse Trend leviations", Revision 1. The procedure defined types of trends and basis for evaluation. Periodically, results of the evaluation were required to be coniled and published. The inspectors reviewed selected reports to evaluate program implementation, which had begun in September 1989. The reports identified the department head responsible for resolving the trend and a due date. Progress in trend resolution was readily apparent. The station manager was appri:ed weekly of current status by the "Braidwood NTS Overdue Items by Department" report. The inspectors concluded that this system was a significant strength and would provide the licensee with timely warning of significant conditions adverse to ;

qualit .8 Pump and Valve Inservice Testing Program The licensee's inservice testing program (IST) was developed to comply with 10 CFR 50.55a and Section XI of the ASME Boiler and Pressure Code. The NRC was reviewing the licensee's relief requests to determine acceptabilit The results of the review, when completed, would be detailed in a Safety Evaluation Report (SER).

The inspector reviewed the procedures that governed the conduct of IST, associated relief requests, and records of trends to assess the implementation of the IST plan. Additionally, completed IST surveillances and observation of testing of pumps and valves in progress were included in the assessmen . Establishing Component Inoperability Position eight of Attachment I to Generic Letter (GL) 89-04, " Guidance on j De cloping Acceptable IST Programs," indicated that a pump or valve shall be '

declard inoperable as soon as the data is recognized to be outside the IST acceptance criteria. Procedures indicated that components that did not meet the

appropriate acceptance criteria were immediately declared inoperable. This :

action conformea te the guidar.ce of GL 89-0 l 4. Trending of Inservice Testing )

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The inspector reviewed the system of trending IST results and discussed the appropriate procedures with cognizant personnel. IST surveillances were reviewed by several different groups including the IST coordinator. Any .

necessary action such as increased testing frequency for data that fell into '

the " alert range", or component inoperability and corrective actions for data ,

that fell into the " required action range" was accomplished and verified during i the revie '

The IST coordinator recorded the results of the tests in a tabular form for retention and trending. The inspector determined that the trending data were ;

accessible, coherently assembled, and current. Data were also computerized to l store and to calculate / plot trends. The IST coordinator could access the '

computerized data; however, the inspector noted that it was somewhat difficult to obtain. The inspector concluded that if the treriding data were tailored to meet the IST coordinators needs and was more readily available, the effectiveness of tl'e IST coordinator could be improve e . .

l The inspector also noted that the systems engineers received trending data; i however, it did not appear th.t the engineers had an in-depth knowledge of IST nor the ability to interpret tie data and evaluate the trends. This was not a widespread problem; however, it was the inspector's opinion that it was important if the engineers were partly responsible for evaluating data and trends in the performance e' IS . Observation.of Testine The inspector observed the surveillance tests associated with procedures BwVS 0.5-3.00.1, "ASME Requirement for Test of the Diesel Oil Transfer System "

Revision 5; BwVS 0.5-2.CC.3, " Component Cooling Isolation Valve Indication i Test," Revision 3; and BwVS 6.3.3-3, " Component Cooling Isolation Valve Stroke Test," Revision 2. These were routine tests done to meet Technical Specification and ASME Section XI surveillance requirements. The inspector observed the valve indication and stroke test from the control room, where most of the coordination and the actual testing was conducted. The Diesel Oil Transfer System (DOTS) Test was observed at the test location. The tests were well coordinated between the operations and engineering staffs, and the personnel that performed the tests were proficient and knowledgeable. Testing was conducted in a logical progression and efficient n.anne However. during the performance of the DOTS Test, the inspector observed that some steps of the procedure had been deleted as "Not Applicable" (N/A). After discussions with the personnel who performed the tests, the inspector concludcd that all of the steps that were deleted from the procedure should not have been. During earlier revisions of the surveillance procedure, the flow rate was measured by use of an ultrasonic flowmeter. The revisions of the surveillance procedure used by the test engineer included the option of running the surveillance test using the flow instrumentation installed in the syste The portions of the procedure where the use of the ultrasonic flowmeter was to be deleted were indicated as N/A when not using the ultrasonic device to measure flow. This requirement was indicated as a note in the main body of the testing procedure. Since the test engineer was unfamiliar with the surveillance procedure and the objective of IST, inappropriate portions of the procedure were delete The procedure was successfully completed when an experienced engineer was able correct the erro The note in the procedure contributed to the error in the performance of the testing; however, the lack of familiarity with the purpose of IST cannot be understated. The licensee revised the procedure to eliminate all reference to the u'trasonic flow measuring device. No other procedural problems or incomplete surveillance tests were noted for the DOTS surveillanc . Completed Surveillance Review The inspector reviewed several procedures and completed surveillances to further evaluate implementation of the licensee's program, its adequacy and effectivenes ,. .

The following surveillance packages were reviewed:

BwVS 0.5-2.SI.2-3 " Safety Injection System Check Valve Stroke Test-II,"

Revision BwVS 0.5-3SX.1 "ASME Surveillance Requirements for Essential Service Pumps," Revision 4 BwVS 0.5-3. AF.1-1 "ASME Surveillance Requirement for the Motor Dris en Auxiliary Feedwater Pump (AFP) and A Train Auxiliary -

Feedwater Valves," Revision 2 BwVS 0.5-3.00.1 "ASME Requirement for Test of the Diesel Oil Transfer System," Revision 4 ,

/ cceptance criteria were specified for the allowable range of test parameters and all surveillance data were within acceptable levels; however, minor procedural deficiencies were noted with the AFP procedure. The ASME Code Section XI, paragraph IWP-3100 requires that the IST shall be conducted with the pump operating at the required reference speed and that the resistance of the system be varied until either the measured flow rate or differential pressure equals the corresponding reference value. The established reference v61ue for the AFP was the flow rate. Although the flow rate was checked during the surveillance, it was not ye ified to be equal to its reference value prior to measuring and recording the other IST quantities. The procedure resulted in an adequate test but was not consistent with Code requirements. The licensee revised the procedure in order to avoid future confusio No other problems were note . IE Bulietin 85-03 (50-346/85003-89) (MOV Common Mode Failure During

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hlant Transients Due to Improper Switch Setting)

Action Item a. of IEB 85-03 requested a review and documentation of the design basis for the operation of each valve addressed, including an evalwtion of limiting differential pressure condition; Action Items through d. required actions to assure that the MOV switch settings were set,

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tested and properly maintained; and Action Item e, required a 180 day report of the results of Action Item a. and a program to accomplished Action Items through d.

l A detailed review of the licensee's action to address IEB 85-03 was not <

possible during this inspection; however, the inspector reviewed test records p and the process used by the licensee to address the bulletin and valve

. operability. The inspector also observed a valve test that used diagnostic L equipment. Valve specific design basis information, thrust, and torque mquirements were obtained from the valve and motor operator vendors. Once the i thmst values were provided, the licensee established limits for setting of the valve and performed verification tests to verify that valve thrusts met the desired thrusts. Diagnostic testing equipment was used at Braidwood during the verification testing process, i

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4.8. Undervoltace Capability i The inspector discussed the analysis performed to ensure that minimum torque requirements from the valve operator motor would be met for IEB 85-03 valve The inspector reviewed engineering calculations which indicated that adequate review of the undervoltage capabilities of the valve motor was conducte Valves were tested by the vendor for 80% of voltage. The licensee's calc %1ations were for valves sized for 90%. The records indicated that the minimum voltages had been analyzed to be available at the valve motor for both start and stall' conditions of the valves, which assured that minimum torque requirements from the motor would be me ;

Modifications, such as limiter plate modifications, or anything that affected .

bus loads, required a review of the design loads on the bus to ensure that any l load additions miei not be greate. than that allowed by the design. This '

also provided assurance that proper voltages would be availabl No problems with the testing program were noted. However, the licensee's philosophy to use the vendor recommended setting to verify valve operability was generally considered by the NRC to be the least effective method to determine taat a valve would perform its design function. The method used by-the vendor 1or calculating desired thrusts had been determined to be less conservative than expected and sometimes did not adequately predict the thrusts required for a valve to operate against differential pressur .

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The methodology was not as conservative as dynamic tuting against actual 1 differential pressures. This issue was expected to be resolved when the licensee adc ressed the requirement of GL 89-10, which mandated differential pressure te, ting for all safety related valve In light of the issuance of GL '

89-10, there items duplicate the issues covered in IEB 85-03 and GL 89-10, therefore, these items should be closed. Followup of the issues will be handled in accordance with follow-up to GL 89-1 .9 Review of Licensee's Assessment of Maintenance The. inspectors evaluated the licensee's quality verification process in the maintenance area by the teview of audit reports, surveillance reports, nonconforming activity reports, and QC inspections. The documents were reviewed to assess techni al adequacy, root cause analysis, timeliness of corrective action, and justification for close-out of corrective action document . Audit and Surve111a ce D.cpert:

l The inspectors reviewed the results of Audits QAA 20-63-14. 20-89-27, 20-89-42, and 20-90-38 on maintenance activities during the periods of March 1989 through January 1990. The licensee witnessed maintenance activities and the problems were assessed for root cause and possible maintenance program weaknesses. Audit 20-89-27, conducted in July 1989, largely addressed the maintenance program from a compliance aspect. For example, the maintenance PADS program was evaluated from the standpoint that the program was in place t

and governed by a memo as directed in N00-MA.2; however, effectiveness of the

' program and adequacy of the corrective action directed in the PADS were not assessed by the licensee. The inspectors were told that an audit of maintenance was scheduled for May 1990. The inspectors reviewed the audit

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checklists that were to be used during the audit. The checklists were greatly improved from the previous audit. The checklists were performance based and gave detailed guidance about the types of maintenance to witness, with particular emphasis on assessment of the effectiveness of the maintenance performed. The new audit checklists were considered a strengt The Quality Programs (QP) department had developed a new trending program that tracked audit and surveillance findings, weighted the significance of the findings and observations, and utilized the results in an equation. The results were used to determine weak areas that needed QP audit and surveillance attention. Since the program was recently implemented, sufficient data had not been included to determine if the trending was effectiv This program was considered innovative in determining and assessing performance related weaknesse . Review of Maintenance Self-Assessment The inspectors reviewed the results of a self assessment in the maintenance area performed in August 1989. The most significant finding was the excessive number of water and steam leaks throughout the plant from valve packing, and i that those valves were not on a PM schedule for repacking. The licensee had taken corrective action in both areas with a new leak detection system and an extensive valve repacking program. Both programs appeared effective as evidenced by the small number of steam and water leaks noted during this inspection. Based on reviews and comparisons with other industry self-assessments of maintenance and the results of this Maintenance Team Inspection, the inspectors concluded that the licensee's self-assessment was effectiv .10 Motor Operated Valve Maintenance The inspectors reviewed the maintenance history of MOVs in the selected systems identified in 4. No adverse trends or significant failures were foun The inspectors also reviewed the PM prcgram for scope and implementation *

progress. The program addressed safety related and some BOP valves. A comprehensive diagnostic testing prrgram was being developed. The inspectors observed the disassembly and testing of MOVs, reviewed the associated work documentation, and discussed the work with the MOV coordinator. The inspectors reviewed both draft and issued procedures used in the disassembly / reassembly of MOVs and considered the content and illustrations a strength. The draft procedures were to be issued within a few weeks. The inspectors concluded that

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the licensee's MOV maintenance program provided reasonable assurance of

! satisfactory MOV operation and early detection of significant failur .0 Synopsis This synopsis highlights the inspection findings in terms that are meant to be representative of the inspection tree that is attached to this report. A (+)

indicated that the area is good or has the potential to be so; A (-) indicates that the area is weak, needs improvement, or is not fully developed.

I 5.1- Overall plant Performance (Direct Measures)

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5. Historic Data (+) Overall, plant performance was good. In no case were goals not met because of maintenance related problems and there were no unplanned reactor trips due to maintenance, i (+) Radiation exposure for the plant was very low. The accumulated dose for 1989 was 296 man-rem and the goal was less than 500 man-re !

5. Plant Walkdown Inspection (+) Plant material condition and housekeeping were considered good. Management was sensitive to jeficiencies identified during walkdowns; was observant of ongoing work; and craft foreman / supervisors performed spot inspection Although a few is>1ated cases were noted where housekeeping was poor, overall the plant was con;.idered clean and well kept. The unit 2 outage was considered in the evaluation of material condition and housekeeping. No conditions were ,

noted which would have immediate adverse impact on the operability of plant systems or equipmen (+) Walkdowns were performed daily to look for leaks and make minor adjustments to correct the leak If safety related or extensive work was required, a " laundry tag" was written and an NWR initiated. Liquid leaks in this area have been greatly reduced from previous inspections. The laundry tags were color coded by year to easily allow visual recognition of tags issued in previous year (+) Plant areas were assigned to individuals for housekeeping and material condition responsibilitie The assigned individual periodically walked down the assigned area and nrted concerns or abnormal conditions. The " House-keeping / Material Condition Deficiency Tag" was used to identify minor conditions that required wor For safety related and significant non-safety related items an NWR was also initiate (-) Although overall housekeeping was good, a few isolated areas were noted where improvement was neede These areas were the 345 kV relay room, the

. unit 2 diesel driven auxiliary feed pump room, and some material warehouse area .2 Management Support of Maintenance

! . Management Commitment and Involvement '

(+) The computerized system used to track and maintain status of open items such as generic letters, I & E bulletins and notices, NRC commitments, and other documents was considered very goo (+) Management had instituted a program to return selected components to the respective supplier, prior to failure, for evaluation and an analysis of wear, age, and abnormal condition (+) Based on a known problem of water leaks in the balance of plant area, management had implemented a daily walkdown to review for leaks. As a result the number of leaks appeared to have significantly decrease '

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I 5. Manaaement Organization and Administration (+) The corporate maintenance policy, " Conduct of Maintenance at Nuclear Power ;

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Stations," when accompanied by implementing procedures, appeared to provide a '

good maintenance program. The plan was issued in 1988 but was not scheduled to ;

be fully implemented until 1992. However, most requirements of the policy had l been implemented at Braidwoo . Technical Support (+) Even thougF reliability centered maintenance (RCM) had not been implemented, the feedwater system had been selected as the first system on which to initiate RC (+) There was a scheduled daily telephone conference call discussion between plant management, corporate management and management of other CECO nuclear plants to discuss concerns and generic issue '

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(+) A computerized corporate spare parts program allowed a computer search for parts throughout the CECO system. This system substantially reduced the number of spare parts required to be stocked at the plant as well as increased the availability of spare parts to support maintenance activitie (+) The corrective action / trending program appeared to be superior to those found at most plants. A single integrated trend identification, classification, and evaluation tracking system was used to combine data from both internal and external source (+) Contaminated areas were kept to a minimum by an ambitious clean up *

program; extensive HP involvement in maintenance planning was apparent especially when high dose rates were involve (+) Television monitors and wireless radios were used in high rad areas to observe activities. This resulted in closer supervision in these areas with less radiation exposur (+) A video mapping system had been developed and photographs were posted outside of high radiation equipment rooms in the auxiliary building, which provided equipment location and configuration to help plan maintenance and reduce radiation exposure. Radiation exposure for the plant was very lo (+) QA had developed a trending program that appeared innovative and aggressive and was expected to be very effective, but sufficient information had not been included in the data base to determine if the trending was effectiv (+) The recently implemented audit concept appeared to be performance oriented. Recently prepared auditor checklists prepared by use of the new concept were very much improved over previous audits checklists. Although the current program appeared to require performance oriented audits, a performance oriented audit of maintenance had been completed.

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(-) Engineering evaluations were not made for nonqualified electrical cable ,

used in the electrical shop for connections to the MSIV hydraulic actuator i

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solenoids. Also, engineering evaluations were not performed for not replacing capacitors in the plant inverters as previously committe (-) Two inservice testing procedures were vague and poorly written. Due to one of the poor procedures, a new system engineer incorrectly deleted steps ;

from one of the test procedure '

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(-) Performance of an engineering evaluation of fire pump test results was not timel *

' Implementation of Maintenance t

5. Work Control (+) Corrective and preventive maintenance backlogs were lo (+) The maintenance order tracking system provided excellent control of and status of NWRs. The status and location of open NWRs could be easily determine ,

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(+) During the Unit 2 refueling outage, e containment coordinator was assigned to facilitate in the containment as well as ensure that the area was returned to normal af ter maintenanc (+) During the planning for many work packages, the work analyst walked down the area or system while planning the work; after maintenance work was completed, the cognizant work analyst walked down the work area to ensure the

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work was properly completed. Work packages were well prepared and sometimes '

contained photos and printouts of equipment to be repaire ;

(+) In most cases, main 12 procedures appeared to be thorough, well '

written, and easy to use, nny cases, pictures or diagrams were included to provide clarity and deta A feedback mechanism was used to improve maintenance procedures. Maintenance personnel appeared to be aware of procedure requirements and seemed to be committed to procedural complianc I (+) Parts were well controlled in maintenance areas; removed parts were immediately bagged for protection and-tagged for identificatio ,

(+) None of 5 unplanned reactor trips were the result of improper maintenance or maintenance' personne (+) ' Work planning meetings were conducted daily with inputs from all disciplines. Maintenance was planned and scheduled based on plant operations during the subsequent three week perio (-) The resolution of the instrument used to measure the overspeed trip of the DG was inadequate and did not allow speed to be controlled to required tolerance .I

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(-) Maintenance work performed on 2A DG was not performed in an efficient i

manner,.which was apparently caused by inadequate work instructions in the procedures as well as possible improper coordination of effor (-) There was no systematic method in place for periodic system outages for maintenanc (-) No system was in place to determine effectiveness of maintenance wor Maintenance work that had to be redone was not considered rework unless the

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system or component had already been turned over to operations personne (-) Weaknesses in electrical maintenance were identified in acceptance criteria determination, ALARA practices, EQ documentation, and engineering reviews and -

evaluation (-)- Appropriate post mechanical maintenance verification was not specified

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nor performed for two non-safety related pump (-) Some procedures used in I&C maintenance required mental calculations to determine acceptance criteri . P_lant Maintenance Organization

.(+) Programs for trending of maintenance as well as QA items appeared to be exceptional. Since the program was recently implemented, sufficient c information had not been included in the QA program to determine if the trending was effectiv (+) A single integrated trend identification, classification, and evaluation tracking system was used that combined data from both internal and external source (+) The' micro-electronic surveillance and calibration system (MESAC) was in place and provided a reliable, effective and efficient method of performing I&C surveillance and tests without lifting' leads or utilizing jumpers. This equipment greatly improved the speed and accuracy of surveillance and tests and substantially reduced the risk of inadvertent reactor trip (+) Support and interface between maintenance, engineering, and operations organizations appeared to be above average and team effort was eviden . Maintenance Facilities, Eouipment, and Material Control l (+) A new training facility was under construction. Af ter completion, this ;

facility was expected to free additional space for maintenance us !

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(+) A computerized ordering system was in place for the procurement of stocked .I parts. When stocked parts reached a specified minimum number, an order was automatically printed for the parts required to bring the stock back to pre-specified level I I

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I (+) A computerized corporate spare parts program allows a computer search for I parts throughout the Ceco ~ system. This system substantially reduced the number i level of spare parts required to stocked at the plant as well as increasing the 1 availability of spare parts to suppert maintenance activities, i i

(-) Throughout the warehouses, parts were stored in the aisle and in several 1 areas cardboard boxes were stored so high that bottom boxes were crushe i In some cases, as many as four different items were noted stored in the same bins.- Safety related items were noted to be. individually identified by tagging '

or were in bags or boxes with appropriate identification; however, non-safety

, related items were no . Personnel Control This area was not reviewed in enough detail to perform an effective '

assessment; however, on two occasions, inservice testing personnel were noted to be unfamiliar with testing and procedure requirements, and radiation protection training did not adequately cover the use and purpose of radiation protection clothin . Exit Meeting ,

The inspectors met with licensee representatives (denoted in Paragraph 1) on i May 10, 1990, at the Braidwood Nuclee- Generating Plant and summarized the *

purpose, scope, and findings of the inspection. The inspectors discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did i not identify any such documents or processes as proprietary, i

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i-Appendix A  !

/CRONYMS AFW Auxiliary Feed Water '

ALARA As Low As Reasonably Achievable ASME American Society of Mechanical Engineers BOP Balance of Plant i CCW Component Cooling Water (System) I CM Corrective Maintenance CRD Control Rod Drive (System) '

DR Deficiency Report DVR Deviation Report c i- ECCS Emergency Core Cooling System ,

EDG Emergency Diesel Generator (System)

EQ Environmental Qualification ESF Engineered Safety Feature .

FSAR Final Safety Analysis Report '

HP Health Physics HVAC Heating Ventilation and Air Conditioning I&C Instrument & Control IEB NRC Inspection and Enforcement Bulletin IEN NRC Inspection and enforcement Notice Institute for Nuclear Power Operations

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INPO ISI Inservice Inspection y IST Inservice Testing '

LCO Limiting Condition for Operation LER Licensee Event Report MCC Motor Control Center M&TE Measuring and Test Equipment MOV Motor Operated Valve MSIV Main Steam Isolation Valve NPRDS Nuclear Plant Reliability Data System NRC Nuclear Regulatory Commission  :

NWR Nuclear Work Request PM Preventive Maintenance l

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PMT Post Maintenance Testing PRA Probabilistic Risk Assessment PWR Pressurized Water Reartor QA Quality Assurance QC Quality Control RCA Radiological Controlled Area

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RCM Reliability Centered Maintenance RP Radiation Protection l

RWP Radiation Work Permit

SALP Systematic Assessment of Licensee Performance

SI Safety Injection (System)

SOER Significant Operating Experience Report SX Essential Service Water TS Technical Specification

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