IR 05000454/1986018

Insp Rept 50-454/86-18 on 860501-30.No Violation or Deviation Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings,Lers,Operations Summary,Surveillance, Maint & Operational Safety & ESF Walkdown

ML20199C580
Person / Time
Site:	Byron
Issue date:	06/13/1986
From:	Forney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20199C549	List: IR 05000454/1986018 ML20199C545
References
50-454-86-18, NUDOCS 8606180193
Download: ML20199C580 (9)

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U.S. NUCLEAR REGULATORY COMISSION

REGION III

Report No. 50-454/86018(DRP)

Docket No. 50-454 License No. NPF-37 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Byron Station, Unit 1 Inspection At: Byron Station, Byron, IL Inspection Conducted: May 1-30, 1986 Inspectors: J. M. Hinds, J P. G. Brochman J. A. Malloy Approved By: oYne , Chi f 6 //d/f fo Reactor Projects Section 1A Date Inspection Summary Inspection on May 1-30, 1986 (Report No. 50-454/86018(DRP))

Areas Inspected: Routine, unannounced safety inspection by the resident inspectors of licensee action on previous inspection findings; LERs; operations summary; surveillance; maintenance; operational safety and ESF walkdown; non-routine events and other activities.

Results

Of the six areas inspected, no violations or deviations were

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identified in five areas. One violation was identified; however, in accordance with 10 CFR Part 2, Appendix C, Section V.A a Notice of Violation was not issued. (See Paragraph 3).

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DETAILS 1. Persons Contacted Commonwealth Edison Company R. Querio, Station Manager

• R. Pleniewicz, Production Superintendent R. Ward, Services Superintendent

• L. Sues, Assistant Superintendent, Operating G. Schwartz, Assistant Superintendent, Maintenance

• T. Joyce, Assistant Superintendent, Technical Services

• St. Clair, Assistant Superintendent, Work Planning W. Blythe, Operating Engineer, Unit 0 T. Tulon, Operating Engineer, Unit 1 D. Brindle, Operating Engineer, Unit 2 J. Schrock, Operating Engineer, Rad-Waste

• A. Chernick, Compliance-Supervisor

• F. Hornbeak, Technical Staff Supervisor

• R. Flahive, Radiation / Chemistry Supervisor

• A. Javorik, Assistant Technical Staff Supervisor

• Kouba, Assistant Technical Staff Supervisor

• K. Yates, Nuclear Safety Group

• E. Zittle, Regulatory Assurance Staff The inspector also contacted and interviewed other licensee and contractor personnel during the course of this inspectio * Denotes those present during the exit interview on May 30, 198 . Action on Previous Inspection Findings (92701 and 92702) (Closed) Open Item (454/85025-01(DRP)): Installation of a temperature monitoring system to automatically isolate Steam

Generator blowdown (SD) and Auxiliary Steam (AS) piping in the l auxiliary building. On May 17, 1985 a letter from K. A. Ainger l to H. R. Denton discussed the licensee's reevaluation of the

- consequences of a High Energy Line Break (HELB) in the SD and AS l systems in the auxiliary building. HELBs in these systems were found to have a greater potential effect on auxiliary building environmental conditions than originally predicted. Additional

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correspondence on August 2, 1985; December 11, 1985; and April 29,

! 1986 detailed the licensee's corrective actions and their responses to NRC concerns regarding these corrective action These corrective actions consisted of installation of automatic isolation valves in the SD and AS system and temperature sensors located in selected areas of the auxiliary buildin The inspector evaluated the modification package for the AS and SD system:

M6-1-85-425, M6-0-85-451, M6-1-85-567, M6-1-85-7-1, M6-1-85-702 and M6-1-85-70 Included in this evaluation were: (1) a review

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cf post-iaodification test records, results evaluation, deviations and deviation resolution; (2) a verification that operating and surveillance procedure changes required by the design change /

modification were made and approved in accordance with Technical Specifications; (3) a verification that training programs were revised to reflect the design change / modification; and (4) a verification that as-built drawings were revised and that control room drawings were updated prior to system operatio Based on the completion of these modifications the inspector has no further concerns regarding the HELB issue, and this item is considered closed; however, during the review of the modification packages the inspector identified two concerns to the licensee's staf CFR 50, Appendix B, Criterion VI, as implemented by Commonwealth Edison Company's Quality Assurance Manual, Quality Requirement 6.0, requires that methods shall be established to control the issuance of documents, such as drawings, including changes thereto, which prescribe activities affecting qualit Quality Procedure (QP) 6-52,

" Document Control for Operations," implements this requirement and Section B.2.b requires that drawings which are utilized by Control Room staff to effectuate their job, such as determining the isolation necessary for maintenance personnel to safely repair a valve, be updated to reflect the as-built condition of the equipment and plant changes. To be able to perform these jobs the drawings must be updated before the modified equipment or plant changes are placed in operation. However, present licensee policy is to only require that drawings which are listed on Byron Administrative Procedure BAP 1340-A5, " Control Room Drawings Considered Critical

to Plant Operations," be updated prior to placing modified equipment l in operation. Drawings which are not listed on BAP 1340-A5 are l usually updated within six to nine months after the modification or l

plant change is installed and placed in operation. Many drawings for safety-related equipment are not included on this list, such as some containment isolation valves, main steam isolation valves, and main steam code safety valves. Additionally, discussions by the inspector with licensee's staff revealed that there is no written guidance, policies, or procedures, at either the corporate or station level, which prescribe which drawings should be listed on BAP 1340-A5, if or when periodic reviews of BAP 1340-A5 should be performed, or what defines a critical drawin The inspector's concerns were identified to the licensee's staff as follows: (1) can the control room operators effectively perform their duties without accurate and up-to-date drawings of all safety-related systems, these duties including isolation of equipment for maintenance, taking compensatory measures for damaged plant equipment, or isolating equipment to C tigate a casualty or to maintain employee safety, and (2) is it adverse to quality assurance to establish

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" critical control room drawings" without any guidance as to what constitutes " critical" or to require periodic review and evaluation of the inclusion of these drawings. These concerns will be followed as Unresolved Item (454/86018-01(DRP)).

ANSI N18.7-1976/ANS-3.2, " Quality Assurance for the Operational Phase of Nuclear Power Plants," Section 5.2.7 requires that modifications which may affect the functioning of safety-related structures, systems, or components shall be performed.in a manner to ensure quality at least equivalent to that specified in the original design bases and requirements. Section 5.2.19.3 requires that tests shall be performed following plant modifications to confirm that he modifications reasonably produce expected results and that the change does not reduce safety of operation Section 5.2.7 requires that design activities associated with modifications to safety-related structures, systems, or components shall be accomplished in accordance with ANSI N45.2.11-197 ANSI N45.2.11, " Quality Assurance Requirements for the Design of Nuclear Power Plants," Section 6.3.3 requires that qualification testing shall be performed in accordance with written test procedures which incorporate or reference the requirements or acceptance limits contained in applicable design documents and that the test results shall be documented and evaluated to assure that the test requirements _have been me The inspector's concerns were identified to the licensee's staff as follows: (1) why test procedures SPP 85-76, SPP 85-111, and SPP 86-18 do not specify any acceptance criteria for testing the ISD054 valves and 1TS-SD054 temperature switches installed by modification M6-1-85-425, M6-1-85-567, and M6-1-85-714; (2) since the 150054 valves are required to close automatically, why there is no minimum valve stroke time specified; (3) why in test procedure SPP 86-10 is the stroke time of valves 0AS013 and 0AS167 evaluated l as being satisfactory, when no stroke time acceptance criteria is specified; and (4) in test procedure SPP 86-18, why are no test results evaluations performed for Sections 1 through 4 of this

, test. These concerns will be followed as Unresolved Item j (454/86018-02(DRP)).

b. (Closed) Unresolved Item (454/85042-02(DRP)): Questions on previous similar events and the safety assessment for LER 454/85081. The

! inspector discussed LERs 454/85011, 454/85017, and 454/85040 with the licensee's staff and agreed with the licensee's position that

these.three LERs were not specifically similar to LER 454/85081 so l as to require that they be reported as " previous similar events" under 10 CFR 50.73. Subsequent to the issuance of LER 454/85081 the licensee developed and implemented a program to improve the quality and content of LERs and increased supervisory review of LERs

, prior to their issuance. Based on these corrective actions, the

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inspector has no further concerns regarding this matter and this item is considered close __ - . - - - - _ _ - - _ -

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. (Closed) Violation (454/86002-02(DRP)): Failure to follow a written surveillance procedure and failure to implement an independent inspection program. The inspector reviewed the licensee's response and verified that the corrective actions had been accomplished as stated. Based on these corrective actions, the inspector has no further concerns regarding this matter and this item is considered closed. The licensee's corrective actions included a review of operating surveillance procedures to identify other potential steps which may have an adverse safety significance if performed incorrectl This review will be completed by October 31, 1986 and is being tracked by the licensee by Action Item Record (AIR)

6-86-00 (Closed) Violation (454/86005-01(DRP)): Failure to implement corrective actions for a significant condition which was adverse to quality and safet The inspector reviewed the licensee's response and verified that the corrective actions had been accomplished as stated. These corrective actions included the installation of labels on the shunt trip panels, switchgear 1RDOSE, and the individual cabinets in 1RD05E. The surveillance procedure was revised to specify which cabinet / train was being operated. Based on these corrective actions, the inspector has no further concerns regarding this matter and this item is considered close . Licensee Event Report (LER) Followup (92700)

(Closed) LER (454/86013-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 Specification LER N Title 454/06013 Containment Air Lock Leakage Rate Surveillance performed lat This LER described an event in July 1985 when the six month time interval for the containment air lock surveillance was exceeded. Technical Specification (TS) 4.6.1.3.b requires that containment air lock leakage be verified within its limits at least once per six months. Additionally, the TS is annotated to state that the provisions of TS 4.0.2 are not applicable. TS 4.0.2 allows a 25% grace period in the time interval for a surveillance. Consequently, TS 4.6.1.3.b is required to be performed every six months, instead of six months + 25% (7.5 months).

On April 23, 1986 a review by licensee personnel of the computer scheduling system for surveillances revealed that TS 4.0.2 was listed as applicable to TS 4.6.1.3.b. A subsequent review of the surveillance records indicated that.the surveillance was performed on January 2,

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August 2, and December 11, 1985. Consequently, the 6 month time interval was exceeded on July 2. The surveillance was performed within the month time interval. The licensee's corrective actions included revising the computer schedule and a review to verify that no other surveillances had the 25% grace period for which they were not eligibl The failure to perform the containment air lock surveillance every six months is a violation of Technical Specifications 4.6.1.3.b and is considered a violation identified by the licensee. In accordance with 10 CFR Part 2, Appendix C, Section V.A no Notice of Violation will be issued and this matter is considered closed (454/86018-03(DRP)). Summary of Operations The unit operated at power levels up to 98% until May 17, 1986, when a discretionary load reduction was commenced to approximately 74% powe ThelicenseederatedtheunittogeducetheReactorCoolantSystemhot leg temperature to less than 600 F, which will reduce the stress corrosion cracking in the primary side of the steam generator hot leg U-tube The NSSS supplier, Westinghouse, is working on an analysis to allow the reactor to operate at a lower T-ave, with consequently lower

. temperature in the hot legs. Following testing of steam generator moisture carryover and turbine governor valve position, performed earlier this year at Byron, the licensee believes that the unit can be operated at power levels up to 85% without exceeding the 600 degree limit. To eliminate the stress corrosion cracking which will permit operation at power above 85% the steam generator tubes must be stress relieve The licensee intends to accomplish this during the Cycle I refueling outage, presently scheduled for February 1987. The unit operated at power levels up to 74% for the remainder of the mont . Monthly Surveillance Observation (61726)

The inspector observed Technical Specifications required surveillance testing on the Main Steam Containment Isolation Valves and Incore Nuclear Instruments 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 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 accordance with approved procedures, regulatory guides and industry codes or standards, and in conformance with. Technical Specification _ . __ _ _. ..

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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 performanc The following maintenance activities were observed / reviewed:

Repair of Pressurizer Variable Heaters 1RY01EC 18 Month Overhaul of Diesel Fire Pump 0FP01PB Following completion of maintenance on the Diesel Fire Pump 0FP01PB and Pressurizer Heaters 1RY01EC, 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 and 71710)

The inspectors observed control room operation, reviewed applicable logs and conducted discussions with control room operators during the month of May 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 requests 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 the month of May 1986, the inspectors walked down the accessible portions of the Diesel Generator, AC Power, and DC Power systems to verify operability. The inspectors also witnessed portions of the radioactive waste system controls associated with rad-waste shipments and barreling.

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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 No violations or deviations were identifie . Review of Non-Routine Events (90712)

The inspector reviewed a special report (letter from R. E. Querio to J. G. Keppler, dated May 19, 1986) which details a failure of the IB Diesel Generator (DG) to reach rated speed within the required time, (ten seconds). This report was submitted under the requirements of Technical Specification 4.8.1. On April 30, 1986 the IB DG was required to be started by a Technical Specification Limiting Condition for Operation. Technical Specification 4.8.1.1.2 requires that a DG reach rated speed, voltage, and frequency within ten seconds of the start signa The.1B DG reached rated conditions in 12.5 seconds and was declared inoperabl The intermediate cause for the slow start of the 1B DG was an inadequate prime in the fuel oil supply lin The root cause was a small fuel oil leak located at the union of the fuel oil supply line and the fuel oil filter. The union was tightened, and the leak was stopped.

t The 1B DG was restarted and reached rated conditions in 8.0 seconds and was declared operable. The IB DG was inoperable for four hour No violations or deviations were identifie . Violations Identified by the Licensee The NRC uses the Notice of Violation as a standard method for formalizing the existence of a violation of a legally binding requiremen However, because the NRC wants to encourage and support licensee's initiatives for self-identification and correction of problems, the NRC will not

, generally issue a Notice of Violation for a violation that meets the tests of 10 CFR 2, Appendix C, Section These tests are: (1) the violation was identified by the licensee; (2) the violation would be categorized as Severity Level IV or V; (3) the violation was reported to the NRC, as required; (4) the violation will be corrected, including measures to prevent recurrence, within a reasonat'a time period; and

(5) it was not a violation that could reasonably be expected to have been prevented by the licensee's corrective action for a previous violation. A violation of regulatory requirements identified by the licensee during the inspection for which no Notice of Violation will be issued is discussed in Paragraph . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptatle items, items of noncompliance, or deviations. Unresolved items disclosed during the inspection are discussed in Paragraph __

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e 11. Exit Interview (30703)

The inspectors met with licensee representatives denoted in Paragraph 1 at the conclusion of the inspection on May 30, 1986. The inspectors summarized the purpose and scope of the inspection and the finding The inspectors also discussed the likely informational content of the inspection report with regard to docur.ents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents / processes as proprietary.

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