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Insp Rept 50-454/86-05 on 860201-28.Violation Noted:Failure to Write Appropriate Procedures for Activity Affecting Quality & to Take Timely & Effective Corrective Action for Condition Adverse to Quality & Safety
	ML20210D816
Person / Time
Site:	Byron
Issue date:	03/20/1986
From:	Forney W; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	;
Shared Package
ML20210D790	List: IR 05000454/1986005; ML20210D786; ML20210D806;
References
	50-454-86-05, 50-454-86-5, NUDOCS 8603270063
	Download: ML20210D816 (11)
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U. S. NUCLEAR REGULATORY COMMISSION

! REGION III

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Report No. 50-454/86005(DRP)

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) ~ Docket No. 50-454 License NPF-37

1 Licensee: Commonwealth Edison Company

Post Office Box 767 Chicago, IL 60690~

j Facility Name: Byron Station, Unit 1 i Inspection At: Byron Station, Byron, IL

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I Inspection Conducted: Februa ry 1-28, 1986 I '

Inspectors: J. M. Hinds, J P. G. Brochman

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Approved By:

RF7DamW W. L. Forney, Chief i 2Pdro/M4 Reactor Projects Section IA 05te'

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j Inspection Summary i Inspection on February 1-28,1986 (Report No. 50-454/86005(DRP))

I Areas Inspected: Routine, unannounced, safety inspection by the resident inspectors of licensee action on previous inspection findings; operations summary; surveillance; maintenance; operational safety and ESF walkdown; l independent inspection; event followup; regional administrator's tour and

other activities. The inspection consisted of 95 inspector-hours onsite by i two NRC inspectors including 10 inspector-hours during off-shifts.

Results: Of the seven areas inspected, no violations or deviations were identified in five areas; two violations were identified in the following j areas: (failure to write appropriate procedures for an activity affecting quality and failure to take timely and effective corrective action for a

significant condition which was adverse to quality and safety - Paragraph 4.c; failure to establish adequate housekeeping controls for a safety related

component - Paragraph 7). The safety significance of Violation 1 is more than

minor and is indicative of licensee management's continuing failure to assure

! that the scope of corrective actions for significant conditions which are

! adverse to quality'and safety are broad enough to include associated systems

and components rather than being narrowly focused on the immediate problem area and has the potential to affect the public health and safety. Violation 2 had

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minor safety significance and minimal potential to affect the public health and

safety.

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DETAILS 1. Persons Contacted Commonwealth Edison Company

B. Thomas, Executive Vice President

C. Reed, Vice President, Nuclear Operations

T. Maiman, Manager of Projects

K. .Graesser, Division Vice President, Nuclear Division

R. Querio, ' Station Manager

1. R. Pleniewicz, Production Superintendent

1. R. Ward, Services Superintendent

R. Tuetken, Startup Superintendent

W. Shewski, Manager, Quality Assurance

1. L. Sues, Assistant Superintendent, Operating

1. G. Schwartz, Assistant Superintendent, Maintenance

T. Joyce, Assistant Superintendent, Technical Services

D. Farrar, Director of Nuclear Licensing

K. Ainger, Nuclear Licensing Administrator T. Tulon, Operating Engineer, Unit 1 D. Brindle, Operating Engineer, Unit 2

1. D. St. Clair, Operating Engineer, Rad-Waste

1. A. Chernick, Compliance Supervisor

1. F. Hornbeak, Technical Staff Supervisor

A. Britton, Quality Assurance Inspector

D. Robinson, On-site Nuclear Safety *

1. J. Langan, Compliance Staff Ogle County Sheriff M. Messer, Administrator S. Blanchard, Communications Supervisor The inspector also contacted and interviewed other licensee and contractor personnel during the course of this inspectio # Denotes those present during the SALP V presentation on February 3,198 * Denotes those present during the exit interview on February 28, 198 . Action on Previous Inspection Findings (92701 and 92702) (Closed) Unresolved Item (454/85053-02(DRP)): Performance of the annual Security Diesel (0DG01K) inspection. During a review of

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l Byron Operating Surveillance B0S-XFT-1, " Cold Weather Preparations" '

it was identified that the annual inspection of ODG01K had not yet been complete Licensee personnel subsequently inspected ODG01K per Byron Maintenante Procedure BMP 3128-1, " Annual Security Diesel

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Maintenance Inspection." The-inspection was completed on January 24, 1986 and no deficiencies ~were identified. Based on the satisfactory completion of BMP 3128-1 and BOS-XFT-1 the inspector has' no further concerns regarding this item and this item is considered closed, (0 pen) Violation (454/85056-01(DRP)): Failure to include Feedwater Tempering Line Flowrate in Calorimetric Surveillance. The inspector reviewed the licensee's response to this violation and verified that the procedure had been permanently revised to include the Tempering Line Flowrate in the total Feedwater Flowrate term. However, the inspector identified six other typographical errors in the procedur Following discussions, the licensee's staff committed to correct these errors in Revision 52 to the calorimetric procedure, 1805 3.1.1- In addition to revising the BOS the licensee developed a computer program to perform the calorimetric. This program was available for use as of December 31, 1985. On February 18, 1986 the licensee's staff identified an error in the source code listing of the software for the computer calorimetric. The error involved using a wrong variable in the thermal power calculation for loop This error is documented in Deviation Report (DVR) 6-1-86-040. The licensee is presently conducting an investigation to determine if any reactor core license power limits were exceeded. Pending the completion of the DVR investigation and the issuance of revision 52 to 180S 3.1.1-2 this violation will remain ope . Summary of Operations The unit operated at power levels up to 98% until 0809 on February 17, 1986, when the unit tripped on a generator / turbine trip due to excessive icing in the switchyard (see Paragraph 9.b). Following the trip a 16 day outage was started, which had been previously scheduled for Ma . Licenesee Event Report (LER) Followup (90712 and 92700) (Closed).LERs (454/85070-LL; 454/86002-LL): An in-office review was conducted for the following LERs to determine that the reportability 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 454/85070-01 Failure of the 1B RHR Pump due to High Vibration 454/86002 . Control Room Ventilation Actuation due to Radiation Monitor OPR31J Iodine Channel Spike No violations or deviations were identifie . . ._ _ _ _ .

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. (Closed) LER (454/86003-LL): Through direct observation, discussions with licensee personnel, and review of records the following LER was reviewed to determine that the reportability requirements were fulfilled, immediate corrective action was accomplished and corrective action to prevent recurrence had been accomplished in accordance with Technical

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i LER N Title i 454/86003 Reactor Trip Due to DC Grounds Which Caused

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a Main Steam Isolation Valve Closure This event was previously discussed in Inspection Report No. 454/8600 No violations or deviations were identifie (Closed) LER (454/86001-LL): This LER described an event on January 16, 1986, while in Mode 1, when Reactor Trip Breaker A (RTA) was inadvertently i

opened during the performance of a Byron Operating Surveilla.nce 180S 3.1.1-11. "Bi-monthly, Staggered Basis, Reactor Trip Breaker Shunt and Undervoltage Trip Independence Test-Train B".

At 0449 on January 16 a non-licensed operator was performing the BOS at the Reactor Trip Breaker Switchgear 1RD05E. 180S 3.1.1-11 had

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been modified by Temporary Procedure No. 85-1-925, and had been 2 performed satisfactorily before this event, though not by this individual. Paragraph F.10 states: . DEPRESS" and HOLD the Auto Shunt Trip - Trip Pushbutton for Train B at 1RD05E." Prior to this

step the' procedure had referred to 1RD05E, Cabinet 2. Consequently, when the operator depressed the Trip Pushbutton in Cabinet 2, as

there were no other instructions to specify the other cabinet,

Reactor Trip Breaker A (RTA) opened instead of RTB and caused a reactor trip. The licensee's investigation' determined that the

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cause of the event was that the temporary procedure was inadequate, in that it did not specify which Cabinet of 1RD05E, 1 or 2, the action was to be performed in. Additionally, the Shunt Trip Test panels in Cabinets 1 and 2 were not labeled to identify which Train they were; nor was IRD05E labeled to indicate which Cabinet was No. I and which was No. 2; nor were any locks installed on cabinets 1 and CFR 50, Appendix B, Criterion V, as implemented by the licensee's Quality Assurance Manual, Quality Requirement 5.0, requires that activities affecting quality shall be prescribed by documented instructions of a type appropriate to the circumstances. The failure of the licensee to provide an appropriate procedure by not specifying the location of the Trip Pushbuttons for Train A and j Train B is a violation of 10 CFR 50, Appendix B, Criterion V 1 (454/86005-01a(DRP)).

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On August 7, 1985, a reactor trip occurred when an individual disconnected a signal cable from the back of the wrong Power Range Nuclear Instrument (NI) cabinet. This event and corrective actions taken were documented in LER 454/85078. -The licensee's investigation of this event determined that it was caused by an inadequately descriptive procedure (the correct NI cabinet was not specified),

inadequate labeling of the signal cables and Nuclear Instrumentation cabinets, and having identical locks on cabinet doors. Corrective actions included revising the Nuclear Instrument Surveillance Procedures to specify the correct cabinet, to label the signal cables, to label the backs of the cabinets, and to place unique locks on each cabine CFR 50, Appendix B, Criterion XVI, as implemented by the licchsee's Quality Assurance Manual, Quality Requirement 16.0, requires that measures shall be established to assure that conditions adverse to quality, such as malfunctions, deficiencies, and deviations are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective actions shall be taken to preclude repetitio ANSI N18.7-1976/ANS-3.2, Section 5.2.11 requires that conditions adverse to plant safety, such as malfunctions, deficiencies, and deviations are promptly identified and correcte In the case of significant conditions adverse to safety, the measures shall assure that the cause of the condition is determined and corrective action action taken shall be documented and reported to appropriate levels of management. ANSI N18.7-1976/ANS-3.2, " Quality Assurance for the Operational Phase of Nuclear Power Plants" is endorsed by Regulatory Guide 1.33, Revision 2. Regulatory Guide 1.33, Revision 2 is committed to in Appendix A of the Byron FSA Licensee management failed to assure that the corrective actions described in LER 454/85078 were applied to all com'inents in the Reactor Protection System, not just the Nuclear Instrumentation System, in that: (1) the identical Shunt Trip test panels in cabinets 1 and 2 were not labeled to indicate whether they were for Train A or Train B; (2) the cabinets at 1RD05E were not labeled to indicate which one was Cabinet 1 or 2; (3) the temporary change to 180S 3.1.1-11 did not explicitly specify the correct cabinet location for functionally identical equipment in the Reactor Protection System where the selection of the wrong cabinet would cause a reactor trip; and (4)

different locks were not installed on the doors to Cabinets 1 and 2 of IRD05E, even though there was a capability to do this. The failure of licensee management to assure that a significant condition which was adverse to quality and safety was corrected in a timely and

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effective manner is a violation of 10 CFR 50, Appendix B, Criterion XVI and ANSI N18.7-1976/ANS-3.2, Section 5.2.11 (454/86005-01b(DRP)).

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The safety significance of this event is more _than minor and is indicative of licensee management's continuing. inability to assure that the scope of corrective actions for significant conditions which are adverse to quality and safety are broad enou3h to include associated systems and components rather than being narrowly focused on the immediate problem area.

' Monthly Surveillance Observation (61726)

i The inspector observed Technical Specifications required surveillance testing on Auxiliary Feedwater Pumps 1AF01PA and 1AF01PB and Component Cooling Pump 1CC01PA, ASME Quarterly Surveillance and Reactor Trip Breaker A, Shunt and Undervoltage Trip Independence Test 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 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 .

No violations or' deviations were identific . 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 accordance 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 t

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 I

control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; i radiological controls were implemented; and fire prevention controls were implemented. Work requests were reviewed to determine status of l

outstanding jobs and to assure that priority is assigned to safety related equipment maintenance which may affect system performanc The following. maintenance activities were observed / reviewed:

.1C RCP Breaker Protective Relay / Bistable Repair

~ Diesel Generator 2DG01KA Repai ,

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Radioactive Waste Evaporator (WX) OC Repair '

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Following. completion of maintenance on the protective relay, OC WX Evaporator and 2DG01KA, the inspectors verified that these systems had been returned to service properl No violations or deviations were identifie . Operational Safety Verification and Engineered Safety Features System Walkdown (71707 and71710)

The inspectors observed control room operation, reviewed applicable logs and conducted discussions with control room operators during the month of February 1986. 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 reauests had been initiated for equipment in need of maintenanc The inspectors, by observation and direct interviews, verified that the physical security plan was being implemented in accordance with the station security pla The inspectors observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection controls. During an inspection of the Bus 141 Vital Switchgear Room on February 6, 1986, the inspectors observed that the 4.16 KV, Class 1-E Circuit Breaker for Component Cooling Pump ICC01PA was removed from its associated safety related switchgear (Bus 141, Cubicle 12)

and was being stored next to the switchgear without any protective covering over the circuit breaker. This circuit breaker is required to actuate on an ESF signal to provide cooling to safety related components to mitigate the consequences of an accident. A review of records indicated that the circuit breaker was removed on February 4, 1986 by operations personnel to allow installation of a ground test device in cubicle 12. The circuit breaker was reinstalled on February'10, 198 ANSI N18.7-1976/ANS-3.2,'Section 5.2.10 requires that housekeeping-practices shall be utilized recognizing requirements for the control of work activities, conditions, and environments that can affect the quality of important parts of the nuclear plant. Housekeeping practices shall assure that only proper processes and procedures are utilized and that-the quality of items is not degraded as a result of housekeeping-practices or technique Particular attention should be given to housekeeping in work areas where important items are handled or stored

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to prevent damage. ANSI N18.7-1976/ANS-3.2 is endorsed by Regulatory-Guide 1.33, Revision Regulatory Guide 1.33, Revision 2 is committed to in Appendix.A of the Byron FSA The. failure by operating personnel to install a protective covering over the circuit breaker for pump ICC01PA, after it.was removed from its switchgear cubicle, created the potential to degrade the circuit breaker's quality.by permitting the entry of foreign material into the internal mechanism of the circuit breaker and is a violation of ANSI N18.7-1976/ANS-3.2, Section 5.2.10 (454/86005-02(DRP)). The inspectors have observed two previous instances of inadequate protective covering of 4.16 KV, Class 1-E Circuit Breakers in the.past 14 month During the month of February 1986, the inspectors walked down the accessible portions of the Safety Injection and Residual Heat Removal systems to verify operability. ,The inspectors also witnessed portions of the radioactive waste system controls associated with rad-waste shipments and barreling 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 . Independent Inspection (82203)-

The inspector toured the Dixon EOF (Emergency Operations Facility) and

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witnessed the performance of Byron Emergency Procedure BZP 500-1,

" Operation Checks of Communication System". This procedure verifies.the operability'of microwave, telephone and radio communication circuits between the Byron station, the EOF, the corporate command center, the NRC Operations Center, Region III, and local and state public officials. The inspector verified that the checks were completed satisfactorily and that any deficiencies observed were identified and work requests written to correct the problems. The inspector'also toured the Ogle County Sheriff's communications center and discussed operation of public notification and emergency communication systems with communications center and sheriff's department supervisory personne No violations or deviations were identifie . Onsite' Followup of Events at Operating Reactors (93702) General The inspector performed onsite followup activities for an event which occurred during February 1986. This followup included a review of operating logs, procedures, the Deviation Report, and interviews with licensee personnel. The. inspector developed a chronology, reviewed the functioning of safety systems required by

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plant conditions, reviewed licensee actions to verify consi~stency with i

procedures, license conditions and the nature of the event. Additionally

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the inspector verified that licensee in.vestigation had identified root causes of equipment malfunctions and/or personnel error and had taken appropriate corrective actions prior to plant restar Details i of the event and licensee corrective actions developed through inspector followup are provided in Paragraph b below.

! Reactor Trip on a Generator / Turbine Trip on February 17, 1986

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l 'While in Mode 1, with reactor power at 98% the reactor tripped due to a generator / turbine trip. A buildup of ice in the switchyard fell from the overhead lines and caused a fault to occur between the Phase A

! and Phase B potential transformers of. Bus'4 (345 KV). This damaged the

! Phase A potential transformer and caused it to fault to ground, causing

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a differential fault on Bus The differential fault tripped the main j power transformers and caused a generator trip. . The generator trip

caused a turbine trip and subsequent reactor trip. A spurious Phase

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A containment isolation occurred. All other ESF systems responded f normally during the trip. The licensee replaced the damaged potential transformer and inspected the potential transformers for the other phases. No other equipment damage was identified.

Following the trip the licensee placed the unit in Mode 5'and began a planned 16 day outage, which had been previously scheduled for Ma { Major work to be performed during the outage is completion of the

remaining.18; month surveillances (those not completed in.the November

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1985 outage), installation of bubble tight dampers in the Control Room Ventilation (VC) system, repair of the 2A Diesel Generator, and other mechanical and electrical maintenance wor This event will be reviewed further in a subsequent report after the LER is issued. No violations or deviations were identifie . Regional Administrator's Tour on February 3, 1986 Region III Administrator, James G. Keppler accompanied by E. G. Greenman, Deputy Director, Divis. ion of Reactor Projects, R. F. Warnick, Chief, Reactor :

Projects Branch 1, and the Resident Inspector Staff toured the Unit I control room and presented the SALP (Systematic. Assessment of Licensee Performance)

V Inspection Report Nos. 454/86001(DRP); 455/86001(DRP) to the licensee, at a public meeting. Licensee representatives present at the meeting are denoted in Paragraph 1. The meeting was also attended by members of the public and the local news medi . Exit Interview.(30703)

, The inspectors met with licensee representatives denoted in Paragraph I at the conclusion of the inspection on February 28, 1986. The inspectors

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summarized 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 i

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IR 05000454/1986005

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