IR 05000454/1986043
| ML20207J422 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 12/29/1986 |
| From: | Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20207J204 | List: |
| References | |
| 50-454-86-43, 50-455-86-34, NUDOCS 8701080438 | |
| Download: ML20207J422 (13) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No.'50-454/86043(DRS); 50-455/86034(DRS)
Docket Nos. 50-454; 50-455 Licenses No. NPR-37; CPPR-131 Licensee: Comonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Byron Station, Units 1 and 2 Inspection At: Byron Station, Byron, Illinois
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Inspection Conducted: September 29 through November 14, 1986 Inspectors:
M. L. McCormick-Barger B. Azab D. A. Beckman P. G. Brochman
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S. G. DuPont
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P. L. Eng
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J. M. Hinds
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W. E. Gunther
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R. M. Lerch J. A. Malloy J. H. Neisler P. R. Rescheske l
M. A. Ring W. Shier C. A. VanDenburgh
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Approved By:
M. A. Ring, Ch Test ProgramsSection I
Date
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i Inspection Sunnary Inspectio_n on September 29 through November _ 1_4_, 1986_ J Reports Areas liisip/B6DMj~DRS)D073D7435/86034(DRS))
No. 50-454 ectTd:
~ Routine, annou'nced safety inspection of licensee action on
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i previous inspection findings; evaluations of preoperational test results; preoperational test results verification; and startup test procedure review.
-Results: Of the four areas inspected, no violations or deviations were identified in three areas; one violation with three examples was identified in the remaining area:
(failure to document preoperational test deficiencies -
Paragraph 3.a, 3.b and 3.c).
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DETAILS 1.
Persons Contacted Commonwealth Edison Company
- R. Querio, Station Manager
- R. Pleniewicz, Production Superintendent
- R. Ward, Services Superintendent
- R. Tuetken, Startup Superintendent
- E. Martin, Quality Assurance Superintendent
- W. Burkamper, Quality Assurance Supervisor, Operations
- J. Woldridge, Quality Assurance Supervisor K. Ainger, Nuclear Licensing Administrator H. Campbell, Onsite Project Engineering Supervisor
- D. Peters, Onsite Project Engineering
- E. Falb, Unit 2 Testing Supervisor
- A. Rosenbach, Quality Assurance Supervisor
- R. Klingler, Project Quality Control Supervisor F. Hornbeak, Technical Staff Supervisor
- M. Snow, Assistant Regulatory Assurance Supervisor
- P. Devine, Unit 2 Assistant Technical Supervisor, Test Review Board S. Altmayer, Technical Staff, Nuclear Group
- E. Zittle, Regulatory Assurance Staff
- J. Langan, Regulatory Assurance Staff
- W. Pirnat, Regulatory Assurance Staff
- K. Yates, Nuclear Safety
- J. Snyder, Quality Assurance Inspector
- F. Willich, Quality Assurance Additional station technical and administrative personnel were contacted by the inspectors during the course of the inspection.
- Denotes those present during the exit interview on October 17, 1986.
- Denotes those present during the exit interview on November 14, 1986.
2.
Action on Previous Inspection Findings (92701)
a.
(Closed)UnresolvedItems(454/85052-01;455/85046-01): Operational Analysis Department (OAD) training documentation did not contain supportive evidence of subject matter in sufficient detail to determine training adequacy. The inspector reviewed various recent training on Quality Assurance Manual Chapter revisions, Byron Station Administrative Procedures, and 0AD procedures, and determined that training documentation contained sufficient detail as supportive evidence to allow assessment of the adequacy of training. The inspector had no further concerns.
b.
(Closed) Unresolved Items (454/85052-02; 455/85046-02): System 0AD to determine and identify the hierarchy of procedures used by 0AD.
The licensee identified by letter that the CECO Quality Assurance
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Manual is the governing document with Byron Station Administrative Procedures implementing the requirements of the QA Manual. The OAD procedures are departmental, implementing the requirements of the Byron Station procedures for specific activities conducted by 0AD.
Activities not specified by 0AD procedures are controlled by station procedures. The inspector finds this to be satisfactory, c.
(Closed) Unresolved Items (454/85052-03; 455/85046-03): 0AD was not on controlled distribution for station administrative procedures.
The inspector verified that 0AD was issued a controlled copy of station administrative procedures and as such, received controlled revisions to the procedures. The inspector has no further concerns.
d.
(Closed) Unresolved Items (454/85052-04; 455/85046-04): System 0AD needs to develop a program for defining the relay tolerances used at Byron Station.
The inspector reviewed the developed list of relay tolerances and verified that the appropriate tolerances have been incorporated in 0AD and static" procedures. The inspector has no further concerns.
3.
Preoperational Test Results Evaluation (70400)
The inspectors reviewed the results of the below listed preoperational test procedures to verify all test changes were identified and approved in accordance with administrative procedures; all test deficiencies were appropriately resolved, reviewed by management, and retested as required; test results were evaluated by appropriate engineering personnel and specifically compared with acceptance criteria; data were properly recorded, signed, dated and documented as test deficiencies if out of tolerance; test packages were reviewed t'y QA for adequacy of contents; and test results were approved by appropriate personnel:
AF 3.60, " Auxiliary Feedwater" FW 34.67, " Tempering Flow Test (IHF - Integrated Hot Functional)"
FW 34.68, " Steam Generator Level Alarm & Setpoint Verification" RC 63.60, " Integrated Hot Functional" l
RC 63.62, " Reactor Coolant Instrument and Component Check"
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RC 63.67, " Reactor Coolant Loop Stop Valve Timing, Reactor Coolant Pump (RCP) Starting and Relief Line Flow Verification Test" i
RP 68.61, " Reactor Protection and Engineered Safeguards Logic Test" RP 68.62, " Reactor Protection Turbine Runback" RP 68.63, " Reactor Protection Logic Check" LM 133.67, " Reactor Loose Parts Monitor for IHF" i
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- AP 5.61, " Bus Loading and Independency"
- CV 18.60, " Chemical and Volume Control, Volume Control Tank (VCT) and Charging Pumps"
- CV 18.61, " Chemical and Volume Control, Charging, Letdown and RCP Seal Injection Logic Test"
- EF 26.61, "ECCS Full Flow"
- DG 22.62, " Diesel Generator Load Test"
- IP 46.60, " Instrument and Control Power"
- MS 51.67, " Main Steam Safety Related (IHF)"
- RC 63.61, " Reactor Coolant"
- RC 63.63, " Reactor Vessel Level Indication System (Heated Junction Thermocouple System)"
- RH 67.60, " Residual Heat Removal System"
- RY 69.67, " Pressurizer (IHF)"
- With respect to the results evaluation of this preoperational test, the inspectors had not completed the review at the time of the inspection exit interview. With the exception of any comments noted below, this review will be documented in a subsequent inspection report.
a.
With respect to the results of CV 18.61, the inspector noted that the System Test Engineer (STE) did not initiate deficiency drafts when the valve timing results for several valves did not meet the requirements of Step 9.0.3.
Step 9.0.3 required that Local and Main Control Board (MCB) timed valve responses be within + or - 20% of each other. On November 11, 1985, at Step 9.10.12, STE recorded closing times for valve 2CV8160 of 2.4 seconds (MCB) and 3.5 seconds (Local). On November 20, 1985, on Data Sheet 11.1.27, the STE recorded closing times for valve 2CV0459 of 1.4 seconds (Remote Shutdown Panel - RSP) and 1.95 seconds (Local). On November 21, 1985, on Data Sheet 11.1.27, the STE recorded closing times for valve 2CV8149C of 4.4 seconds (RSP) and 5.8 seconds (Local).
In each of these three instances, the valve time responses exceeded 20% of each other. On December 19, 1985, the Test Review Board issued a letter recommending approval of the test results. This letter did not identify that deficiencies should have been written for the three valves. On January 16, 1986, and June 6, 1986, the Project Engineering Department issued letters documenting their test results review and approval. These letters did not identify that deficiencies should have been written for the three valves for which the timed responses exceeded 20% of each other.
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The inspector discussed these concerns with a Byron Test Review Board representative who stated that a letter would be written to indicate that deficiencies should have been written, and, in addition, that the valves which had not already been retested (2CV8160 and 2CV8149C) would be evaluated to determine whether or not they should be retested. At the time of this inspection, Valve 2CV0459 had been retested via Retest R-2019 in response to a valve opening time deficiency. The retest demonstrated that the difference between the closing times recorded for the remote (MCB) and local readings was less than 20%.
10 CFR 50, Appendix B, Criterion XI, as implemented by Commonwealth Edison Company's Quality Assurance Manual, Quality Requirement 11.0, requires that test results be documented and evaluated to assure that requirements have been met. Quality Procedure No. 11-2 requires that the documentation of pre-operational tests include a list of any apparent deficiencies. Byron Startup Manual Paragraph 4.7.3.7 requires that deficient conditions discovered during testing be recorded as deficiency drafts. Technical Staff Memorandum (TSM)
T03.03A implements these requirements and requires that when a System Test Engineer (STE) identifies a problem with a system during the performance of a test (i.e., data outside expected range, incorrect indication, etc.) the STE will document the problem in a deficiency draft. The failure of the STE to write deficiencies for CV 18.61 as required by TSM T03.03A is a violation of 10 CFR 50, Appendix B, Criterion XI (455/86034-01a(DRS)).
b.
Section 9.5 of RY 69.67 tests the Power Operated Relief Valves (PORVs) to determine valve stroke time and seat leakage after valve cycling. Leak integrity is verified by monitoring the decrease in discharge line temperatures at 30 minute intervals until temperatures stabilize.
During the review of RY 69.67 the inspector noted that the recorded discharge line temperature for valve 2RY455A indicated that a temperature spike had occurred 60 minutes after valve cycling. Although the Sequence of Events Log entry dated May 30, 1986, 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br /> states, " Temp recorded 0 + 30 minutes (230 F)
... apparently in error," no deficiency draft for this anomaly was found.
The inspector also noted that comparison of the last two recorded temperature measurements revealed that stabilization had not occurred.
Lack of stabilization was evidenced by a temperature decrease of 13 F between the last two temperature measurements taken between PORV 2RY455A and its associated block valve. Review of test results for PORV 2RY456 revealed that a deficiency had been written for a similar cccurrence, and that the temperature data had been taken until stabilization was evident. No deficiency for the 2RY455A valve data was found.
The System Test Engineer (STE) added appropriate notes to the test documentation package to acknowledge the lack of deficiencies for
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the above identified anomalies prior to the end of the inspection period; therefore, no additional actions on the part of the licensee for these items associated with RY 69.67 is necessary.
As previously noted in Paragraph 3.a of this report, Technical Staff Memorandum (TSM) T03.03A requires the STE to document problems identified during performance of a preoperational test by initiating a deficiency draft. Failure to draft deficiencies per TSM T03.03A for the problems encountered in Section 9.5 of RY 69.67 is a violation of 10 CFR 50, Appendix B, Criterion XI (455/86034-01b(DRS)).
c.
Section 13, Appendix C, of RH 67.60 deals with verification of operating procedures related to the use of the Residual Heat Removal (RHR) system for the refueling mode. Appendix C stated that the procedures listed in the appendix must be verified. However, as of Febrary 19, 1986, when the test results package was approved and therefore closed, none of the associated signature blocks were signed and no deficiencies were written.
10 CFR 50, Appendix B, Criterion XI, as implemented by the Commonwealth Edison Company's Quality Assurance Manual, Quality Requirement 11.0, requires that test results be documented and evaluated to assure that requirements have been met. Quality Procedure No. 11-2 requires that the documentation of preoperational tests include a list of any apparent deficiencies. Byron Startup Manual, Paragraph 4.1.4 defines deficiencies as incomplete or improper installation, documentation, design, or testing and states that individuals who identify deficient conditions will document them on a deficiency report form.
The failure to document a deficiency for RH 67.60 as required by Startup Manual Paragraph 4.1.4 is a violation of 10 CFR 50, Appendix B, Criterion XI (455/86034-01c(DRS)).
Final Safety Analysis Report (FSAR) Table 14.2-17, " Residual Heat Removal System (Preoperational Test)," states, "Use of the residual heat removal system for the refueling mode will be tested by verification of the following operating procedures during performance of the RHR preoperational testing: preparation for refueling, pumping from the refueling cavity to the refueling water storage tank, and pumping from the refueling cavity to the recycle holdup tanks." These operating procedures had been included in the l
list of operating procedures that were required to be verified based l
on RH 67.60, Section 13, Appendix C.
Since the verification had not j
taken place in accordance with RH 67.60, the inspector asked the
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licensee whether or not the FSAR commitment had been met. The licensee determined that, although these procedures were not verified in the preoperational program, plant operating staff had used the procedures in question in preparation for initial fuel
loading, but the operating logs did not specifically refer to the procedures used.
To ensure that the FSAR commitment had been met, the operating staff performed the required operating procedures on November 4, and 5, 1986, and documented the performance in the operating logs.
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Inspection Report Items 454/84007-06, 454/85008-04, and 454/85017-01 all discuss the failure to do an adequate test results evaluation by omitting deficiencies.
In the response to the violations identified in Paragraphs 3.a. 3.b, and 3.c above, the licensee is requested to review the adequacy of corrective actions previously taken and specifically address actions taken or planned to ensure that the lessons learned regarding deficiency documentation for the preoperational testing program are applied to the startup testing program, d.
With respect to the results of FW 34.68, the inspector noted that the System Test Engineer (STE) did not initiate deficiency drafts when the results for the steam generator HI-HI Level Turbine Trip Alert Alarm did not meet the acceptance criteria. Paragraphs 9.1.6, 9.1.24, 9.1.42, and 9.1.60 required that the Steam Generator (SG)
Level HI-HI Turbine Trip Alert Alarm for SGs 2A, B, C, and D be recorded in Tables 11.1.1,11.1.2,11.1.3, and 11.1.4, respectively.
Tables 11.1.1 - 11.1.4 specified an acceptable range of 78.1%
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for the Turbine Trip Alert Alarm. On May 26, 1986, the STE recorded a value of 75% for level channel 2LI-518 for SG 2A, and channels 2LI-547 and 2LI-548 for SG 2D. This exceeded the acceptable value range of 75.1% - 81.1%. On June 9, 1986, the licensee determined that level channels 2LI-518, 2LI-547, and several others had failed their post-testing accuracy checks and that portions of the test should be repeated. 2LI-518 and 2LI-547 were satisfactorily retested; however, 2LI-518 (which had not failed its post-test accuracy check)
was not retested nor was a deficiency draft related to exceeding the acceptable range for the HI-HI Level Turbine Trip Alert Alarm written.
On June 18, 1986, the Test Review Board (TRB) reconnended approval of the test results based on the negligible difference between 75.0%
and 75.1% and that this would not have an effect on the performance of the SGs; however, the TRB failed to recognize that a deficiency should have been written for level channel 2LI-548. The Project Engineering Department (PED) offsite review did identify that a deficiency should have been written; however, the onsite, final, PED review was vague and appeared to the inspector to imply that deficiencies need not have been written since the final PED review evaluation stated, in part, that "The original Hi-Hi Level Alert Alarm readings on Data Sheets 11.1.1 and 11.1.4 are acceptable."
During discussions between the inspector and the licensee, an individual from Onsite PED stated that their evaluation was not meant to imply that deficiencies should not have been written.
To provide clarification, a letter was written from Onsite PED to the Byron Station Manager. Based on this, the failure to write deficiencies as discussed above is not being included as an example of the violation discussed in Paragraphs 3.a, 3.b, and 3.c.
e.
With respect to the results review of RC 63.67, the inspector identified the following concerns:
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(1) Various testing deficiencies were inadequate in that Section III of the testing deficiency form, " Corrective Action Taken," did not provide justification or engineering basis for accepting the deficiency as is. The following are examples where the Test Review Board (TRB) and/or Project Engineering Department (PED) were requested to evaluate the deficiency for
"use as is" and did not provide justification for accepting the identified deficiency:
Deficiency TRB/ PED Resolution M, the running current of RCP
"use as is"
"C" was 30 amperes below the expected range of 490 to 660 amps.
P, the open stroke time for valve
"use as is" 2RC8002C (Loop C Stop Valve) was outside the test specified value of 220 seconds.
R, RCP "D" motor current indicates
"TRM recommends 50 amps less than the acceptable approve as is."
range of 490 to 660 amps.
T, RCP "B" motor current indicates
"TRB recommends 50 amps less than the acceptable approved as is."
range of 490 to 660 amps.
Y, AB, AD, Closing times for the
"TRB reconnends Loop Stop valves were outside the accept as is since test specified values.
no safety criteria is involved."
These issues are considered an unresolved item (455/86034-02(DRS))
until engineering can provide documented evaluations which identify the design basis of the deficient components and justification that the above identified components and systems will perform satisfactorily in service in accordance with the requirements and acceptance limits of the applicable design documents, including the FSAR as required by 10 CFR 50, Appendix B, Criterion XI.
(2) The test methodology used to obtain the flow setpoint data appeared to be unacceptable. The preoperational procedures required throttling of the flow instrument's equalizing valve until the flow permissive and alarm setpoints were reached.
The PED evaluation of Deficiency "V" also identified that the methodology appeared to be unacceptable.
In addition, throttling the equalizing valve dees not appear to agree with the station procedures used by the plant staff's instrument technicians to test and calibrate flow instruments. Because
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l these flow permissive and alarm setpoints are required for i
evaluation of Acceptance Criteria 4.1 and 4.2 of the.
preoperational test and the testing methodology appears to be unacceptable, this is considered an unresolved item
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(455/86034-03(DRS)) until the licensee can demonstrate that throttling the equalizer valve is an acceptable method of obtaining. flow data.
f.
Problems with output voltage regulation were identified for Vital Power. Inverter 212 during Preoperational Test IP 46.60 (on DC supply) and AP 05.61 (on AC supply).
Deficiency 61344 issued during IP 46.60 was resolved by the Station Electrical Engineering Department (SEED) and the Project Engineering i
Department (PED)onNovember 15, 1985, accepting test results as-is and recomending that the inverters be tested for transients on the 480 VAC input to ensure that the DC supply would not be required to supply bus loads under normal conditions.
During Retest R-2011 (for AP 05.61 and AP 05.60, " Auxiliary Power"),
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performed in February 1986, the inverter output on Instrument Bus 212 was 112 VAC, less than the procedure acceptance criterion of 116-120 VAC. Deficiency 64054 was issued December 16, 1985.
Deficiency 64054 was resolved by adjusting the inverter's frequency circuits to attain the acceptance criterion (adjustment of the voltage regulator circuit was contraindicated by the vendor
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resulting in an as-left AC output of 118.7 VAC (put of 500 VAC manual). This adjustment was made with an AC in 117.1 VAC at
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downstream panel 2PA45J).
The above adjustment was made at an input voltage in excess of the maximum nominal voltage (495 VAC) and resulted in only a i
nominally acceptable output. Subsequent to this adjustment, on
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September 16, 1986, a tap change was made on the Station Auxiliary Transfomers to correct higher than desired AC bus voltages.
The following aspects of the above issue are considered an unresolved item (455/86034-04(DRS)) pending additional infomation from the licensee and review by the NRC:
l (1) The performance of the inverter AC input transient testing (SEED / PED recomendation of November 15,1985) subsequent to
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the perfomance of IP 46.60 could not be verified. The licensee
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was requested to provide additional information regarding disposition of the recomendation.
(2) The corrective action and functional retest perfomed for Deficiency 64054 resulted in a " single point" verification of inverter output and bus loading effects under abnormal (high)
input conditions. Further, the retest was not consistent with
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the requirements of FSAR Table 14.2-12, " Instrument Power Preoperational Test," requirements for verification of proper voltage and frequency output under varying input and loading.
The licensee was requested to provide their bases for the
" acceptability of inverter tuning and performance.
(3)
In conjunction with (2) above, tre AC source transformer tap change will affect the inverter output as demonstrated during the preoperational testing. No evaluation of this effect on Inverter 212 was evident. The licensee was requested to provide information substantiating the acceptability of inverter performance.
One violation and two unresolved items were identified during the inspection of the program area.
4.
Preoperational Test Results_ Verificat_i_o_n__ _(7_0_329_)
The inspectors reviewed the following preoperational test procedures and verified that results were reviewed against approved acceptance criteria and an evaluation of the test results had been performed in accordance with Regulatory Guide 1.68 and the licensee's Startup Manual:
00 24.61, " Diesel Fuel 011"
- FH 32.62, " Fuel Handling Transfer"
- HC 39.60, " Polar Crane" MS 51.61, " Main Steam (Safety Related - PORV's)"
RF 66.60, " Containment Floor Drains" VA 84.60, " Auxiliary Building Ventilation Cubicle Coolers"
- VD 86.60, " Diesel - Generator Ventilation"
-**VD 86.61, " Integrated Diesel Generator, Miscellaneous Electrical, and Switchgear Room Ventilation"
- VP 93.62, " Containment Ventilation"
- VQ 94.60, " Containment Purge"
- VX 99.61, "Switchgear Heat Removal"
- VE 128.60, " Miscellaneous Electrical Equipment Room Ventilation"
- With respect to the results verification of this preoperational test, the inspectors had not completed the review at the time of the inspection exit interview. With the exception of any conments noted below, this review will be documented in a subsequent inspection report.
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Based on the preoperational test results verification review, the inspectors had the following comments:
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Eight of ten Preoperational. Test 10 CFR 50.59 evaluations reviewed by the
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inspectors did not provide a valid basis for the determination that an unreviewed safety question did' not exist.
T fann." questions" only repeated (paraphrased)ypical responses to evaluation i
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the question. Several included nonspecific or generalized statements, for example, "no impact
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on Unit 1," etc.
Further, the inspector observed that 10 CFR 50.59 evaluations were
inconsistent with BAP 1210-5, "10 CFR 50.59 Safety Evaluation Procedure,"
f which provides the basis for answering safety evaluation questions, in that typical responses were "none" or "N/A" in such areas as: affects on systems' functions, interactions with other systems, Final Safety Analysis
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Report (FSAR) impact, license condition impact, Technical Specification impact, etc.
Examples identified were for the period 1984 - early 1986 (Preoperational Tests 99.61, 128.60, 86.60, 84.60, 24.61, 51.61, 22.62, and 94.60).
A Byron Test Review Board representative indicated that the above deficiencies were previously identified by the licensee and were the subject of additional staff training during late 1985 and early 1986.
A limited re-sampling by the inspector (three examples after February, 1986) has indicated some improvement in this area. Although the inspectors did not identify. any unresolved safety issues in the 10 CFR 50.59 evaluations reviewed, the acceptability of current licensee
practices will remain an unresolved item (455/86034-05(DRS)) pending i
further review of additional safety evaluations post-dating the above
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One-issue in this program area requires further review and evaluation and is considered to be an unresolved item as discussed F
above.
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Startup Test Procedure Review (72500, 72570, 72572, 72578)
L The inspectors reviewed the following startup test procedures against the
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Final Safety Analysis Report (FSAR), Safety Evaluation Report, applicable Regulatory Guides and Standards, and portions of 10 CFR 50:
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- 2.47.80, " Isothermal Temperature Coefficient Measurement" i
2.32.82, " Initial Core Loading" 2.32.80, " Initial Core Load Sequence"
i 2.52.82, " Initial Criticality" 2.45.81, "Incore Flux Mapping at Low Power"
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2.47.82B, " Thermal Power Measurement and Statepoint Data Collection
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(For 40% and 98% Power Levels)"
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2.64.83, " Boron Endpoint Determination"
- With respect to the review of this startup test procedure, the
inspectors had not completed the review at the time of the inspection
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exit interview. This review will be documented in a subsequent inspection report.
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No violations or 'eviations were identified.
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Unresolved items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, open items, deviations, or violations. Unresolved items disclosed during the inspection are discussed in Paragraphs 3.e(1), 3.e(2), 3.f, and 4, 7.
Exit Interview The inspectors met with the licensee representatives denoted in Paragraph 1 on October 17, 1986 and at the conclusion of the inspection on November 14, 1986. The ir.spectors summarized the purpose and scope of the inspection and the findings including the violation denoted in Paragraph 3.
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 /processess as proprietary.
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