IR 05000456/1997001
| ML20198L696 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/17/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20198L691 | List: |
| References | |
| 50-456-97-01, 50-456-97-1, 50-457-97-01, 50-457-97-1, NUDOCS 9710270128 | |
| Download: ML20198L696 (7) | |
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BRAIDWOOD STATION SALP 14 Report No. 50-456/9700t; 50-457/97001 INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) process is used to develop the Nuclear Regulatory Commission's (NRC) conclusions regardhg a licensee's safety pedormanc Four functional areas are assessed: Plant Operations, Maintenance, Engineerl.,g, und Plant Support. The SALP report documents the NRC's observations and insights on a licensee's performance and communicates the results to the licensee and the public, it provides a vehicle for clear communication with licensee management that focuses on plant performance relative to safety risk perspectives. The NRC utilizes SALP results when allocating NRC inspection resources at licensee facilitie This report is the NRC's assessmer,t of the safety performance at the Braldwood Station for the SALP 14 period from October 1,1995, through August 30,199 '
An NRC SALP Board, composed of the individuals listed below, met on September 10,1997, to review the observations and ' a an performance and to assess performance in accordance with the guidance in NRC Mant snt Directive 8.6," Systematic Assessment of Licensee Performance."
Board Chairmaa J. A. Grobe, Acting Director, Division of Reactor Safety, Rlli Board Members M.. L. Dapas, Acting Deputy Director, Division of Reactor Projects, Rlli T. J. Kozak, Acting Deputy Director, Division of Nuclear Materials Safety. Rill R. A. Capra, Director, Project Directorate Ill 2, NRR 1 PERFORMANCE ANALYSIS Plant Operations
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Performance in the plant operations functional area improved during the assessment period primarily in the areas of conduct of operations and response to non routine events. Close management involvement contributed to effective planning and coordination of work activities and improved oversight of infrequently performed evolutions. However, problems with configuration control need continued management attention.
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. improvements in the conduct of normal operations were noted in communications, control room access control, and reactivity management during the assessment period. Management implemented three way communication and other error reduction techniques which were routinely practiced by operators. The designated pre shift briefing room had a sound system i
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added to enhance communications which contributed to the overall improvement in shift turnovers, in response to concerns with operahr panet attentiveness, management clarified expectations regarding panel walkdowns. Administrative tasks and other distracting activities
,were eliminated from the control room by moving maintenance and out-of service activi6es to a work control center. All of these actions contributed to a reduction in human performance errors in the control room. Early in ihe assessment period, two reactivity events occurred. These two events, combined with a more serious reactivity event at another Comed station, prompted
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management to provide additional reactivity control training to operators, conduct frequent evaluations of operator performance daring reactivity manipuistions, and increase the
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supervision of evolutions involving reactivity changes. These corrective actions were effective in increasing operator sensitivity to the importance of teactivity managemen The conduct of operations in response to non-rcutine events was excellent. During the esassment period operators were challenged by a loss of offsite power on Unit 2, s 40 percent load r-jection on Unit 1, and two loss of feed water pump events on Unit 2. Prompt actions by y operatos : ombined with the improved material condition of plant equipment, resulted in y continueo afe operation of the plant.
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s he conduct of operations during outage periods also improved. Early in the assessment period, f the inadwertent draining of 500 gal:ons of reactor coolant after a localleak rate test and the placement of an out-of-service on the wrong diesel generator were xamples of outage
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(- evolutiont, that were not propedy controlled. During the 1997 UnF 1 refueling outag management augmented control room staffing with the addition of a senior reactor operato Tnis providea more direct supervision of infrequently performed evolutions. A second senior i reactor operator was also assigned to assist the shm enanager in handling outage related issue ,"
i Additionally, operators practiced infrequently performed evolutions, such as startups and
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shutdowns, on the simulator prior to actually conducting them in the plant. These corrective actions were effective in eliminating significant human performance errors during the Unit 1 -
refueling outag Early in the assessment pedd, configuration control and out-ci-service errLrs were frequen After the NPC proposed an escalated er,torcement action, corrective actions taken by managemeR in response to these errors were initially effective. However, near the end of the assessment period, some configuration control errors began to recur. For example, a fire protection sprinkler system for a safety-related transformer was iradvertently initiated during a surveillance test, spraying down the transformer; a safety-related containment spray system
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valve was found unlocked following maintenance; and a safety-related auxiliary feed water pump
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was inadvertontly sprayed with boric acid during the draining of a boric acid storage tan Continued management attention in this area is needed to ensure that the initial corrective actions remain effectiv With few exceptions, operations department personnelidentified equipment problems in a timely manner. Operations management focused attention on degraded equipment by discussing problems daily with engineering and maintenance management at the Braidwood Station leadership meetings. These discussions hivolved identifying responsible organizations and individuals and establishing expected maintenance start and completion dates, Self-assessments were thorough and self-critical. Bench marking trips to other utilities resulted in the implementation of the work control center and the scorecard system which provided for
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supervisory review of various operating tasks with immediate feedback to the operators. The Independent Safety Engineering Group conducted operations assessments resulting in the IJentification of a number of issues. Ano'e positive self assessment initiative involved site vice presidents from other Comed stations rou.mely observing control room activities and providing graded evaluations of operator performanc The performance rating in Operations is Category Maintenance Performance in the maintenance functional area was improved relative to the last SALP assessment. Sustained progress was made in several areas including: plant material condition, craft skill and supervision, conduct of survein,1ce testing a .tivities, and self assessmen However, continuing weaknesres were observed throughout ine SALP period in the 3rea of procedural adherenc Deteriorating plant material condition was considered a weakness during the last assessment period. An NRC inspection early in this penod identified that several hundred preventive maintenance items were overdue, rework was not being tracked, root causes for repetitive work were not being identified, and corrective maintenance backlogs were large and growin Subsequently, significant management attention was focused on raising standards and improving material condition. Overdue preventative maintenance items were evaluated and either completed or rescheduled, as appropriate. Rework was tracked and root cause evaluations were
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initiated. Management successfully implemented a new work planning schedule and reclassified some work as minor maintenance, resulting in improved schedule adherence End a reduction in
{.e the corrective maintenance backlog by more than 50 percent, in addition to maintaining effective
- N inservice inspection and motor-operated valve programs, longstanding equipment problems
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L involving charging, essential service water, safety injection, condensate, condensate booster, and feed water pumps were addressed. Complicated repairs were also successfully completed on non-essential service water pump discharge check valve Early :n the assessment period, a number of problems occurred during the conduct of maintenance activities due in large part to insufficient craft skill and supervision. For example, while removing a residual heat ramoval pump impeller, workers damaged the pump shaft and motor which led to the unscheduled replacement of these comporeents. The ability to plan, conduct and complete maintenance activities improved over the course of the SALP period. On-line maintenance was scheduled for, and genera!!y completed in, about half of the Technical Specification limiting condition for operation ellowed outage time, incpection and repair work on the Unit 1 system transformers, preparation for execution of repairs to the Unit 1 "C" loop reactor coolant cold 49 stop valve, post-event response to the Unit 1 boric acid tank spill, and planning for ard execution of the March 1997 Unit 1 refueling outage reflected careful planning and proper execution of maintenance activitie Surveillsnce tests were generally well written and properly performed and adequately tested system design. However, the NRC identified some instances where Technicai Specification requirements were not being complied with regarding the venting of the charging system discharge piping and pump casings and during check valve testing of the safety injection and charging system _ - _ - _ _ _ _ _ -
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While the majority of maintenance and surveillance activities were conducted well, the failure to adhere to procedural controls throughout the period resulted in a number of problems, including a misplaced fuel bundle in the spent fuel pool, inadequate foreign material exclusion control on an emergency diesel generator, and over-pressurization of an emergenci diesel generator jacket water system, in the previous ascessment period, self-assessment activities were not fully effective in identifying and resolving problems in the maintenance area. While the station is stillin the process of developing a formal process for performing self-assessments, some recent improvements were noted in this area. An assessment of maintenance activitiec performed by the Independent Safety Engineering Group was self critical and thorough in identifying problems in the stat;on's maintenance processes. Improvement in the effectiveness of recent departmental self-assessments was also observe The performance rating in Maintenance is Category Enaineerina Performance in the engineering functional area was improved relative to the last SALP assessment. Although several weaknesses were o served during this assessment period, most occurred early in the period. Steady progress was r ade in ssveral areas including day to day support to onsite organizations, resolution of equipn ent problems, support of major activities, and self-assessments. The engineering staff also developed an effective program for replacement of Unit i steam genera; ors. However, continued inattention to detail resulted in some NRC violations and licensee event report The engineering department provided excellent day-to-day support to operations, maintenance, and other onsite organizations. Active involveinent by the engineering staff in resolving equipment problems resulted in improved material condition of the essential service water, condensate, and feedwater pumps. However, some weaknesses were identified. For example, check valve surveillance testing on the safety injection and centrifugal charging systems was poorly controlled by system engineers. Also, engineering personnel failed to perform an adequate review of ASME Code requirements and applicable Generic Letter guidance when the staff identified a through wall flaw in the 1 A essential service water system. Finally, engineering personnel failed to perform a required safety evaluation when ther auxiliary building venti:ation system was placed in an abnormal configuratio Good engineering department support to operations resulted in the steady reduction of operator work arounds, open operability assessrnents, temporary alterations and drawing change notices. A number of timely and weh-written operabihty evalua' ions also reflected improvement ir' this area. However, a large backlog of engineering requests exists and continued to increase during most of the assessment period. In addition, although identi.1 cation of material condition deficiencies during system walkdowns in fr3quently accessed areas was good, the identification of material condition problems in infrequently accessed areas was poor as demonstrated by a refueling water storage tank heater mounting deficiency not being identified for an extended period of tim Engineering support of major activities was good. Rant and system design changes which were well thought out and implemented contributed to the improved material condition of
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systems and components. The engineering department recently initiated a design review to venfy that plant syste ns, components, and parameters meet the design basis. Engineering staff response to industry events was good, and an operating experience coordinator was assigned to monitor, track, and coordinata the distribution of industry experience dat ,
The engineering staff developed and implemented an effective program for replacement of the Unit 1 steam generators. The program included the use of a dedicated Comed engineering team to provide oversight of several contractors and incorporated lessons leamed from other steam generator replacemem projects. in-house engineering and engineering staff oversight of the steam generator repair effort for the Westinghouse D-4 steam generators was good. The engineering staff also took a leadership role in developing and proposing a plan to safely operate the cunent steam generators until they are replace Attention to detail problems detracted from the overall good performance observed with other aspects of engineering activities. For example, a modeling error in a vendor performed criticality analysis and the inadequate review of the analysis' input assumptions resulted in the failure to detect deficiencies in the fuel pool criticality analysis. In addition, nuclear component transfer lists which were prepared using unverified and uncontrolled information led to fuel storage in an area of the fuel pool that was outside the criticality analysis. Also, an unrealistic and non-conservative flow resistance constant was used in the auxiliary feedwater flow talculation in the feed line break analysis. Severalin service inspection relief requests initially lacked sufficient technical bases for approval of the relief requests.
Self-assessments of engineering department activit:ss provided a self-critical evaluation of the department's performance. The Independent Safety Engineering Group also provided assessments of the engineering department containing findings that were generally consistent with the engineering department's self assessments. Through the self assessment process, the system engineering staff identified drawing discrepancies in control room drawings that had existed since initial plant constructio The performance rating in Engineering is Category Plant Support Plant Support performance remained cer.sistent with the Category 1 rating from the previous assessment period. Management involvement resulted in strong performance in the radiation protection, security, and emergency preparedness program areas. Good teamwork and effective communications with other plar.t organizations were also evident in these program However, some weaknesses in :he fire protection area, which included problems with the adequacy of cable separation and with fire doors, were observed during this assessment perio Radiation protection program performance continued to be strong. Radiological work planning and overs:yht were effective in reducing personne! exposures. The resistance temperature detection modification was well planned and controlled, resulting in low personnel dose and in a significant reduction in radiological source term. In addition, worker exposures were reduced through the use of a mock-up for the repair of the Unit 1 loop stop isolation valve. The radiation protaction staff provided excellent support to station personnel and radiation worker practices were generally good. Decreases in the amount of contaminated area ensored
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l access to plant equipment was essentially unencumbered by radiologicalimpediments. The radioactive material shipping and radiological environmental monitoring programs were well implemente The chemistry program continued to focus on maintaining plant water quality. Effective control of chemicalintrusions and secondary system additives reduced the potential for system corrosion and decreased the radiologicai source term. The chemistry training program was interactive and thorough. Although the chemistry laboratory quality control program was acceptable, some problems were identified conceming the adequacy and the implementation of procedures in addition, the material condition of the post accident sampling system was in need of improvement C
Security performance continued to be good. The security plan was effectively implemented and performance of the security force was good. Implementation of a hand geometry access control system, installation of a vehicle barrier system and a new security computer system enhanced security operations. Security management fostered good departmental communications and teamwork. Effective and vitical self assessmer9s were performed by site quality verification and by the Comed Nuclear Assistance Team. Problem identification and resolution of technicalissues were strong as evidenced by the identification and assessment of a failure of the Biometrics access control system and by the investigation of an adverse trend in security foice human performance. Althougn maintenance support was general!y effective in ensuring operability of security equipment, the security staff was not aggressive in addressing maintenance needs for a security door and a perimeter alarm zone that required compensatory measures for several months. The security contingency response program was weak in the beginning of the assessment period but significant improvements occurred late in the assessment period during preparations for the Operational Safeguards Response Evaluatio Performance in emergency preparedness was excellent. Emergency response facilities, equipment, and supplies were in excellent material condition. Management support was clearly a factor in the program's improvement over the assessment period. Training initiatives, such as unannounced emergency response table-top drills, improved the readiness of the emergency response organization, and emergency response personnel demonstrated a thorough knowledge of emergency implementing procedures and responsibilities. Overall performance dunng the 1996 emergency preparedness exercise was very good. The exercise was a successful demonstration of the licensee's capabilities to implement its emergency plans and procedure In the area of fire protection, some strengths were Toted in the 10 CFR 50, Appendix R, Enhancement Plan, and the material condition of fire protection equipment was goo Hov/ever, problems were identified by the licensee conceming the adequacy of cable separation and roll-up fire doors. As a result of these deficiencies, areas of the plant containing redundant, safe shutdown equipment were vulnerable to fires which could cause damage and impairment of the required equipment. In addition, corrective actions for degraded fire barriers and impairments were sometimes not timely, and some procedure adherence problems were eviden The performance rating in Plant Support area is Category _ - - _ _ _ - - l
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T. Tulon 2 Excellent day to-day support to operatioris, maintenance, and other onsite organizations was evident in the engineering area and was in part, responsible for the improved matenal condition of plant equipment. However, occasional errors due to inattention to detail detracted from the excellent day-to-day engineering suppor Performance improvements in the radiation protection, security, and emergency preparedness program areas resulted from strong management support. Initiatives in radiological work planning and training reduced personnel exposures, and strong teamwork and effective communications between the radiation protection staff and other organizations were eviden Emergency preparedness training initiatives, strong teamwork, and effective communications ensured the effectiveness of the emergency response oiganization. However, weaknesses in fire protection were observed during this assessment period. The most significant problems involved the adequacy of cable separation and fire doors problems that resulted in potential increases in equipment vulnerabilitie In accordance with Section 2.790 of the NRC " Rules of Practice," Part 2, Title 10, Code cf Federal Regulations, a copy of this letter and the SALP report will be placed in the NRC's Public Document Roo Should you have any questions conceming the SALP Report, we would be pleased to discuss them with you. While no written response is requircd, you may provide wiitten comments within 30 days of the SALP meetin
Sincerely,
/s/A. Bill Beach A. Bill Beach Regionai Administrator Docket No. 50-456;50-457 Enclosure: SALP 14 Report No. 50-456/97001; 50-457/970001 See Attached Distribution See Previous Concurrence DOCUMENT NAME: G:\brai\bwd97001. sip To ree,4ve a copy of this geocumnt. Indicste in the box 'C' = Co, * without attachment / enclosure "E* = Cogey with attachment / enclosure
"N* = No copy OFFICE Rlli Rlli NRR Rlli Rlll
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NAME Lanksbury:dp Kozak Capra Dapas Grobe BM DATE 10//97 10/ /97 10/ /97 10/ /97 10/ /97 10/17/97 OFFICIAL RECORD COPY