IR 05000454/1985039

Safety Insp Rept 50-454/85-39 on 850904-1001.Violation Noted:Failure to Perform Tech Spec Surveillances for RCS Water Inventory Balance When Required

ML20133J643
Person / Time
Site:	Byron
Issue date:	10/15/1985
From:	Forney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20133J638	List: IR 05000454/1985039 IR 05000904/2010001 ML20133J635
References
50-454-85-39, NUDOCS 8510210013
Download: ML20133J643 (11)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

! Report No.: 50-454/85039(DRP)  ;

Docket No.: 50-454 License No.: NPF-37  :

Licensee: Commonwealth Edison Company Post Office Box 767

] Chicago, IL 60690 >

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Facility Name: Byron Station, Unit 1 i

d Inspection at: Byron Station, Byron, IL Inspection Conducted: September 4 - October 1,1985 Inspectors: J. M. Hinds, J P. G. Brochman R. M. L rch

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Approved By: L ' orn y, C ef Reactor Projects Section 1A YNJ '--

Date Inspection Summary Inspection on September 4 - October 1,1985 (Report No. 50-454/85039(DRP))

Areas Inspected: Routine, unannounced safety inspection by the resident i

inspectors and a regional inspector of licensee action on previous inspection findings; 10 CFR Part 21 reports; LERs; surveillance; maintenance; operational safety and ESF walkdowns; startup testing; event followup; commercial service; allegations; management meeting and other activities. The inspection consisted of 123 inspector-hours onsite by 3 NRC inspectors including 20

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inspector-hours during off-shift >

Results: Of the 11 areas inspected, no violations or deviations were identified in 10 areas; two violations were identified in the following orea (failure to perform Technical Specification surveillances when required -

Paragraphs 4.cand4.d). These violations concern the failure to perform Technical Specification surveillances when required; however, examination of the computer records and the leakrate test indicated that the parameters were maintained within their Technical Specification limits at all times; therefore, the public health and safety were not affected.

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DETAILS 1. Persons Contacted -

Connonwealth Edison Company i

• T. Maiman, Manager of Projects [

1. • R. E. Querio, Station Manager l

1. • R. Ward, Services Superintendent i

1. • R. Pleniewicz, Production Superintendent '

1. • L. Sues, Assistant Superintendent, Operations

1. G. Schwartz, Maintenance Assistant Superintendent i

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1. A. Chernick, Compliance Supervisor

• J. VanLaere, Rad-Chem Supervisor ,

1. F. Hornbeak, Technical Staff Supervisor

1. W. Burkamper, Quality Assurance Supervisor (0perations)

1. J. Langan, Compliance Group

1. K. Yates, Nuclear Safety  ;

l The inspectors also contacted and interviewed other, licensee and contractor personnel during the course of this inspectio i

• Denotes those present during the management meeting on September 11,

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1985.

l # Denotes those present during the exit interview on October 1, 198 . Action on Previous Inspection Findings (92701 & 92702) , (Closed) Unresolved Item (454/85002-05): An Action Item Requirement '

(AIR) is an inadequate administrative control over removal of Unit 2 NTC cards from the Unit I cabinets. The licensee's corrective  !

action to resolve the specific issue related to the use of the AIR ;

to control the removal of the Westinghouse 7300 Process Protection System NTC (Temperature Channel Test) cards and the generic {

application to the use of AIRS as adequate administrative controls '

for corrective actions involving safety-related systems was conducted in three parts. The first, short-term effort consisted of special briefings conducted by the Technical Staff Supervisor with the on-shift Startup Coordinators between February 2 and 6,1985, to discuss the inappropriate use of the AIR in the NTC case. A second, broader briefing was conducted by the Technical Staff Supervisor with the primary system Group Leaders on February 4,1985, to discuss the NTC issue and expand the application to include all other safety-related system components. Additionally, the third t thrust included revising Technical Staff memorandum TO 3.06 entitled

" Temporary Alterations (Prior Review and Approval) BAP 300-5". The revision to TO 3.06 provided specific instructions to resolve this l

issue for the NTC cards and prevent the recurrence in safety-related ,

systems during the Unit 2 Pre-operational and Startup Test Program : (Closed)OpenItem(454/85006-01): Licensee requirement to provide a report to the NRC staff upon achieving full power operation  !

detailing all recorded leakage and as a direct result of the .

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evaluation of this leakage, all preventive maintenance performe In Section 9.3.5.1 and 9.3.5.2 of Supplement 5 to the Byron SER the staff described the licensee's submittals pursuant to TMI Action ,

Items III.D.1.1 " Primary Coolant Sources Outside Containment" and i documented the staff's finding of acceptability. The staff did,  ;

however, require that the licensee provide a report to the NPC staff #

upon achieving full power operation detailing all recorded leakage and, as a direct result of the evaluation of this leakage, all i preventive maintenance performed. The report shall also identify general leakage criteria to be applied during the first fuel cycle as the basis for instituting corrective action in the form of-preventive maintenanc The inspector verified that licensee commitments relative to this item were reflected in approved Technical Specification 6.8.4.a,

" Reactor Coolant Sources Outside Containment", requirements. The inspector reviewed the licensee's August 1,1985, report fomarded

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to the NRC staff in the Ainger to Denton memorandum of September 17, 1985. The report cortained tabulated evaluation of primary leakage, details of preventative maintenance and the general leakage criteria

for the first fuel cycl (Closed)UnresolvedItem(454/85009-01): Contingency actions not established in advance for abnormal control systems response during initial testing. This concern developed from inspector onsite followup of events related to the initial automatic transfer of main turbine speed control from turbine throttles to turbine governors at 1700 RPM performed by the Digital Electrohydraulic Control System (DEHC). As a result of inadequate preliminary system grooming, consisting of software adjustment, valve position and control

, calibrations for the throttle and governor valves, the integrated i operation of the DEHC system operation resulted in a safety injection / reactor trip on low steamline pressure due to high steam flow and reduced steamline presssure. Based on his review of this

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event review the inspector expressed a generic concern to the licensee regarding contingency actions not being established prior to conduct of first time evolutions. The licensee's corrective action plan, in response to this concern, consisted of analyzing the subsequent startup tests, developing contingency' action plans for

complex first time evolutions and outlining these contingencies on an easel board in the control room for use by the licensed

, operators. The contingency action plans were also used by the l system test engineers in the detailed pre-shift briefings conducted

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prior to the performance of the remaining startup tests. By  :

personal observation, the inspector verified that contingency action i

plans were effectively developed and utilized for the following 100%

power sequence test Startup Tests:

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2.05.30 Loss of Offsite Power 2.51.45 Steam Generator Moisture Carryover 2.52.37 Load Swing Test 2.63.35 Shutdown from Outside Control Room

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2.64.39 Large Load Reduction  !

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The inspector has no further concerns related to this ite (Closed) Violation (454/85009-02): Failure to follow surveillance procedures - 2 examples. This concern dealt with the inappropriate ;

application and inadequate performance of operating and instrument surveillances which resulted in reactor trips on 2 occasions. The licensee's corrective actions to resolve this issue and prevent 3 recurrence included: ,

(1) Instruction by the Operating Engineer to the Shift Engineers, .

in a meeting held on March 7, 1985, on the necessity for 1 complete procedure compliance and methods for making temporary change (2) Placing these examples of violations and their responses in the ,

required reading file for all licensed operator !

Instruction by the Master Instrument Mechanic to the Control

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(3)

System Technicians (CSTs) in formal meetings of the importance and necessity for complete procedure compliance with emphasis '

on strictly following procedural steps in all instance (4) Refresher training given to the CSTs on the Reactor Trip System !

logi (5) Development and implementation of a high visibility cover sheet i to be incorporated on instrument surveillances which affect reactor trip system circuit input .

The inspector verified by personal observation and discussion with licensee personnel that the corrective actions in this matter have '

been taken. Observations included review of the required reading -

file verification signature package, the high visibility cover ,

sheets and their application, and the lesson plan and attendance t verification signature package for the CST refresher training course ,

on Reactor Protection Permissives Digital Logic. The inspector has i no further concerns in this matte !

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CFR Part 21 Report Followup (92716)

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(Closed) 10 CFR Part 21 Report (454/84001-PP): Environmental qualification of Viton seals used in post-LOCA hydrogen recombiners  :

manufactured by Rockwell International. The licensee has received and !

installed the qualified replacement seals specified by the vendo '

Installation of the seals was completed aft.er' receipt of all required

, certification documents. The inspector verified by review of material :

receipt reports, mechanical joint process sheets and job traveler  !

j packages that the affected Viton seals identified in this Part 21 report ;

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have been replace t Licensee Event Report (LER) Followup (90712 & 92700) i

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a. (Closed) LERs (454/84043-01-LL; 454/85011-01-LL; 454/85063-01-LL; 454/85074-LL;454/85076-LL;454/85077-LL): An in-office review was conducted for the following LERs to detemine that the reporting requirements were fulfilled, immediate corrective action was accomplished and corrective action to prevent recurrence had been accomplished in accordance with Technical Specification LER N Title 454/F4043-01 Failure to Perform ASME Section XI Testing 454/85011-01 Inoperability of Both SI Trains 454/85063-01 Reactor Trip Due to Turbine Trip Above P-7 454/85074 Automatic Actuation of Fuel Handling Building Charcoal Booster Fan 454/85076 .

Auto Start of QA VC M/V Fan 454/85077 Auto Start of 0B FH Booster Fan No violations or deviations were identifie b. (Closed) LERs (454/85075-LL; 454/85078-LL; 454/85085-LL): Through direct observation, discussions with licensee personnel, and review of records the following LERs were reviewed to detennine that the reporting requirements were fulfilled, imediate corrective action was accomplished and corrective action to prevent recurrence had been accomplished in accordance with Technical Specification LER N Title-454/85075 Failure of Leak Rate Surveillance on Containment Airlock 454/85078 Reactor Trip 454/85085 ASME Inspection Not Perfonned on Two SI Valve Welds The event described in LER 454/85078 was reviewed in Inspection Report 454/85036(DRP). The events described in LERs 454/85075 and

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454/85085 are discussed further in Paragraphs 9.b and No violations or deviations were identifie c. (Closed)LER(454/85079-LL): This LER described an event on August 9-10, 1985, while in Mode 1. Technical Specification 4.2.1.1.a(2)

required that the Axial Flux Deviation (AFD) be determined to be within its limits during power operation by monitoring the indicated AFD of each operable excore detector channel at least once per hour for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after restoring the AFD Monitor Alarm to

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operable status. The AFD Monitor Alarm was taken out-of-service at 1200 on August 9 and licensee personnel began monitoring AFD hourly as required by Techrical Specification 4.2.1.1.b. At 1515 the AFD Monitor Alarm was restored to service. Licensee personnel manually '

inputted the AFD data they had collected into the plant compute Licensee personnel believed that manually inputting the data obviated the requirement to monitor AFD hourly for the first 24 ,

hours following return to service. The failure to monitor AFD was '

discovered on the next shift by licensee personnel. The failure to monitor the AFD when required by Technical Specification 4.2.1.1.a(2) is a violation (454/85039-01(DRP)).

The licensee's reviewed the AFD data to verify that no AFD limits were exceeded and revised the surveillance procedure to extend its applicability for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after returning the monitor alarm to service. The inspector has reviewed the licensee's corrective actions and has no further concerns regarding this event and this violation is considered close (Closed)LER(454/85083-LL): This LER described an event on August 20, 1985, while in Mode 1. Technical Specification 4.4.6.2. required that a Reactor Coolant System water inventory balance be

performed at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Technical Specification 4.0.2

required that this surveillance shall be performed within the specified time interval (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) with a maximum allowable extensions not to exceed 25% of the surveillance interval (18 i hours). Byron Operating Surveillance IBOS 4.6.2.1.d-1, " Reactor ,

Coolant System Water Inventory Balance" was completed at 1214 on August 16, 1985. Licensee supervisory personnel deferred

, performance of the 80s due to interference from a startup test. The surveillance was completed at 0900 on August 20, 1985. Failure to perform 180S 4.6.2.1.d-1 within the required time interval is a violation (454/85039-02(DRP)).

The licensee's corrective action included disciplinary action I against the involved supervisors and to reiterate to licensed personnel the need to review the impact of planned evolutions on the '

surveillance schedule. The inspector has reviewed the licensee's

' corrective actions and has no further concerns regarding this event and this violation is considered closed.

5. MonthlySurveillanceObservation(61726)

The inspector observed Technical Specifications required surveillance testing on the RCS Leakage Detection Radiation Monitors and a Residual

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Heat Removal Pump and verified that testing was performed in accordance !

with adequate procedures, that test instrumentation was calibrated, that limiting conditions for operation were met, that removal and restoration

, of the affected components were accomplished, that test results conformed I with Technical Specifications and procedure requirements and were reviewed by personnel'other than the individual directing the test, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne :

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No violations or deviations were identifie . Monthly Maintenance Observation (62703)

Station maintenance activities of safety related systems and components listed below were observed / reviewed to ascertain that they were conducted in acccrdance with approved procedures, regulatory guides and industry codes or standards and in conformance with Technical Specification The following items were considered during this review: the limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and, fire prevention controls were implemented. Work requests were reviewed to determine status of outstanding jobs and to assure that priority is assigned to safety related equipment maintenance which may affect system perfonnanc The following maintenance activities were observed / reviewed:

Repair of limit switches on Valve ICV 110A Following completion of maintenance on the valve ICV 110A, the inspector verified that this system had been returned to service properl No violations or deviations were identifie . Operational Safety Verification and Engineered Safety Features System Walkdown (71707 & 71710)

The inspectors observed control room operation, reviewed applicable logs and conducted discussions with control room operators during the month of September. During these discussions and observations, the inspectors ascertained that the operators were alert, cognizant of plant conditions, attentive to changes in those conditions, and took prompt action when appropriate. The inspectors verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected components. Tours of the auxiliary, turbine and rad-waste buildings were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks and excessive vibration and to verify that maintenance requests had been initiated for equipment in-need of maintenance.-

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The inspectors verified by observation and direct interviews that the physical. security plan was being implemented in accordance with the station security pla The inspector observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection controls. During the months of August and Septenber, the inspectors walked down the accessible

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portions of the Diesel Generator, the Essential Service Water (SX) and the DC power systems to verify operability. During a walkdown of the SX system on August 29, 1985, the inspector identified that valve OSX298,

"0B SX Makeup Pump Discharge Valve" was out-of-position shut. Licensee personnel opened the valve and locked it in the open position. The Train A valve, OSX29A, was checked and verified to be in the open positio The licensee documented this event in Deviation Report (DVR) 06-1-85-26 On September 14, 1985, the 08 SX Makeup Pump failed to start on a valid signal. Licensee investigation determined that the diesel's airbox was tripped and that this prevented the diesel from starting. Two conditions ;

can trip the airbox: 1) diesel overspeed or 2) manual actuation. The '

licensee determined that the airbox could not have tripped on overspeed as the diesel never started. This event was documented in DVR r 06-1-85-290. The licensee is presently reviewing these DVRs for any commonality and pending completion of this review this matter will be treated as an unresolved item (454/85039-03(DRP). l The inspector also witnessed portions of the radioactive waste system controls associated with radwaste shipments and barrelin :

These reviews and observations were conducted to verify that facility operations were in accordance with the requirements established under technical specifications, 10 CFR and administrative procedure t

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8. Startup Test Witnessing and Observation (72302)

The inspectors witnessed performance of portions of the following startup !

test procedures in order to verify that testing was conducted in (

accordance with the operating license and procedural requirements, test i data was properly recorded and performance by licensee personnel i conducting the tests demonstrated an understanding of assigned duties and l responsibilities.

2.52.37 Load Swing Test

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No violations or deviations were identifie [

9. Onsite Followup of Events at Operating Reactors (93702) General i

The inspector performed onsite followup activities for events which t occurred during August and September 1985. This followup included !

reviews of operating logs, procedures, Deviation Reports, Licensee l Event Reports (where available) and interviews with licensee '

personnel. For each event, the inspector developed a chronology, reviewed the functioning of safety systems required by plant .

conditions, reviewed licensee actions to verify consistency with '

procedures, license conditions and the nature of the even Additionally the inspector verified that licensee investigation had identified root causes of equipment malfunctions and/or personnel

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error and had taken appropriate corrective actions prior to plant restart. Details of the events and licensee corrective actions developed through inspector followup are provided in Paragraphs b through e belo b. Unusual Event on August 1, 1985 (LER 454/85075)

While in Mode 2, with reactor power at 2%, the Containment Equipment Hatch Personnel Airlock failed its semi-annual Type B Local Leakage Rate Surveillance test at 1430. At 2030 the licensee declared an Unusual Event and began to shut down. At 2043 the unit entered Mode .

The licensee's investigation determined that the inner door gasket was crimped and that an insufficient number of tie-downs were installed to ensure a tight seal with a crimped gaske The licensee repaired the gasket and changed the surveillance procedure to increase the number of tie-downs instalied during performance of the leak test. The procedure was successfully reperformed and the Unusual Event was terminated at 0245 on August 2, 198 c. Unusual Event on August 29,1985(LER454/85085)

While in Mode 1, with reactor power at 15%, at 1600 the licensee determined that required pre-service inspection tests, required by the ASME Boiler and Pressure Vessel Code, had not been performed on welds for valves ISI8811A and ISI88118, " Containment Sump Outlet Isolation Valves" and consequently the valves were not operable. At 1657 the licensee declared an Unusual Event and began to shut dow At 2010 the NRC verbally granted 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> relief on the pre-service inspection tests. However, the Unusual Event was not terminated due to a problem with the Main Steam Isolation Valves (MSIVs) described in paragraph d below. The licensee has committed to inspect the subject welds at the next 10 day outage, which is presently scheduled to begin October 25, 1985, d. Unusual Event on August 29, 1985 While in Mode 1, with reactor power at 10%, the licensee determined that the electrical terminal blocks for the Main Steam Isolation Valves (MSIVs) were not environmentally qualified and consequently the valves were not operable. The Unusual Event which was initiated due to the Safety Injection valves inoperability was continued. The Unusual Event wes terninated at 0730 on August 30, 1985, when the unit entered Mode The licensee's corrective action included removal of the non-qualified terminal blocks and splicing the electrical wiring using environmentally qualified splice kit .

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This problem was first identified at the Wolf Creek power plant and on August 16, 1985 the inspector requested that the licensee evaluate its applicability to Byron's MSIV Unusual Event on September 16, 1985 While in Mode 1, with reactor power at 36%, the Auto Stop 011 function of the Solid State Protection System (SSPS) failed its ,

bi-monthly surveillance at 0226. At 0448 the licensee declared an Unusual Event and began a power reductio The licensee's corrective action included replacement of a defective card in SSPS and successfully reperformed the surveillance. The Unusual Event was terminated at 0704 and the unit was returned to powe . Byron Unit 1 - Coninercial Service on September 16, 1985 Byron Unit I was placed in commercial service on September 16, 1985. The startup testing program had been completed on September 10, 1985, for all plant performance testing specified in the FSAR; the NSSS acceptance tests have been completed and two proSlems identified which have resulted in the derating of the unit. Reactor power has been limited to 97.7% due to excessive feedwater flowrate to 2 of the steam generators' preheaters and to 92% due to excessive moisture carryover (greater than 0.25%). The ,

licensee and the NSSS supplier, Westinghouse, are preparing modifications to the steam generators to correct these problems and the licensee intends to perform these modifications during an outage which is presently scheduled to begin October 25, 198 . Allegation Concerning Suspected Drug Use (99014)

Allesation: On August 26, 1985, the licensee notified the Senior Resicent Inspector of an allegation received related to suspected drug use. This allegation was received in the form of an anonymous phone call from a concerned citizen to an Employee Assistance Program (EAP)

coordinator at the Rock River Division offices. The caller identified an employee at Byron Station whom the alleger had reason to believe may be using drugs. The employee named in this allegation was a non-management, non-licensed administrative employee whose duties and assignments do not involve safety related work. The caller agreed to supply additional information as required to support CECO's investigation of the '

allegatio Findings: In keeping with the licensee's drug awareness program on l August 26, 1985, the individual was relieved of all duties at the Byron l Station, the individual's photo identification security badge and access key-card were revoked and the individual was imediately removed from the payroll pending the outcome of chemical testing for drug On August 29, 1985, the individual was tested by observed specimen urinalysis for drug use by a Ceco physician at the licensee's Rockford ,

medical facilities. The results of this test were positive and the 1

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individual was maintained in a suspended status subject to further testin On September 4, 1985, the individual was again tested by observed sample urinalysis for drug use by a CECO physician at the licensee's Chicago medical facilities. The results of this test were negativ On September 5, 1985, the senior CECO physician reviewed this case and based on recomendations of a Chicago Office EAP supervisor and the negative urinalysis results declared the individual fit for dut On September 6, 1985, the individual was readmitted to the site, rebadged, and interviewed by a board consisting of station managers, supervisors, and union representatives. The individual was advised of a probationary status, required to participate in six months counseling with Rockford EAP personnel and is subject to random spot check urinalysis testing for drug us Failure on the part of the individual to complete the counseling program, pass the urinalysis tests or live up to other Ceco performance requirements would result in termination without further caus This allegation is considered close No violations or deviations were identifie . ManagementMeetings(30702)

On September 11, 1985, Messrs. R. F. Warnick, Chief, Reactor Projects Branch 1. W. D. Shafer, Chief. Emergency Preparedness and Radiological Protection Branch, W. L. Forney, Chief, Reactor Projects Section IA. and the NRC resident inspector staff met with licensee management and supervisory personnel denoted in Paragraph 1 of this report. These meetings were held to assess overall facility status, plant operations and to discuss agenda items which had developed since issuance of the operating licens . Unreselved Items Unresolved items are matters about which more information is required in ordar to ascertain whether they are acceptable items, violations, or deviations. An unresolved item disclosed during the inspection is discussed in Paragraph . Exit interview (30703)

The inspectors met with licensee representatives denoted in Paragraph 1 at the conclusion of the inspection on October 1, 1985. The inspectors sumarized the purpose and scope of the inspection and the findings. The inspectors also 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 not identify any such documents / processes as proprietar