IR 05000454/1987023

Insp Repts 50-454/87-23 & 50-455/87-21 on 870602-30.No Violations or Deviations Noted.Major Areas Inspected: Licensee Implementation of Generic Ltr 83-28,including Vendor Interface & post-maint Testing

ML20235M172
Person / Time
Site:	Byron
Issue date:	07/08/1987
From:	Gardner R, Neisler J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20235M102	List: IR 05000454/1987023 ML20235M101
References
50-454-87-23, 50-455-87-21, GL-83-28, NUDOCS 8707170089
Download: ML20235M172 (6)

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' j U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-454/87023(DRS);50-455/87021(DRS)

i Docket Nos. 50-454; 50-455 Licenses No. NPF-37; No. NPF-66 l Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Byron Station, Units 1 and 2 Inspection At: Byron Site, Byron, Illinois Inspection Conducted: June 2-30, 1987 Inspector:

O.hduW J. H. Neisler >

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Date hb" Approved By: R. Gardner, Chief 7.8!83  :

Plant Systems Section Date Inspection Suninary

.i Inspection on June 2-30, 1987 (Reports No. 50-454/87023(DRS);

No. 50-455/87021(DRS))

Areas Inspected: Routine, announced inspection of the licensee's implementation i of Generic Letter 83-28 in the areas of equipment classification, vendor i interface, post maintenance testing, and reactor trip system reliabilit Closed TI 2500/64R (25564B)

Results: No violations or deviations were identifie .

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DETAILS Persons Contacted

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PrincipleILicensee Employees

• R. Pleniewicz, Production.' Superintendent W. Burkamper, Superintendent, Quality Assurance

• W.' Pirnot, Regulatory Assuranc *P. Johnson, Master Instrument Maintenance

• J. McLindsay, Instrument Maintenance ~  !

• T. Bardauskas, Technical Staff Engineer

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• G. Stauffer,. Technical. Staff Engineer

• M. . Snow, Regulatory Assurance ~ Supervisor  ;

• O'Neill, Quality Control Supervisor )

R. Klingler, Quality Assurance  ;

'*L. Larson, Technical Staff Engineer

• T. Joyce, Assistant' Superintendent, Technical Services

• D. Beng, Nuclear Safety

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B. Riedl, Quality Control

• E. Zittle, Regulatory Assurance-

'*B. Erickson, Maintenance Staff Assistant

• R. Crosby,--General Foremen, Electrical Maintenance f

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• Denotes those persons attending the exit intervie .' TI 2500/64RI (Closed) TI 2500/91 (Closed) Equipment' Classification The inspector selected four. components in the reactor trip system (RTS) and six components in the containment spray system for examination during this inspection. The components selected were:

RTS Containment Spray System Reactor trip breaker Valve SI8811A/B Manual trip switch Valve CS007A/B Isolator boards Flow element (orifice) FECS011 Control rod latch and gripper Flow element (orifice) FECS015 coil assembly . Level switch CSO46A/B Flow switch CS011 Flow switch CS015 For the selected components, the inspector performed the~followin ,

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reviews:

(1) The inspector reviewed'the Byron safety-related component list .

(Q list), maintenance and test procedures,-nuclear work requests, warehouse issue documents and applicable modifications; all the

. components were appropriately identified as safety-related except

' flow orifices FECS011 and FEC5015. These' flow orifices are the 2 .

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primary elements in instrumentation loops whose components are identified as safety-related on the safety-related component list. Orifice FECS011 is used in measuring containment l spray flow and FECS015 is used to measure flow from the spray additive tank to the containment spray system. Both systems are safety-related at Byron. The licensee representative j informed the inspector that containment spray flow and spray j additive flow instrumentation was not considered to be j safety-related by their architect / engineer, Sargent and Lund The inspector questioned how nonsafety-related instrumentation ]

for these safety-related flow systems met the requirements of i Regulatory Guide 1.97 to provide information to indicate whether j plant safety functions are being accomplished. This issue is unresolved (50-454/87023-01; 50-455/87021-01).

, (2) To determine the level of plant management oversight, the l inspector reviewed procedures controlling maintenance, modifications, procurement and issue, inspection and testing of safety-related items, quality assurance procedures, audits ]

and surveillance and corporate level procedures for activities ;

impacting safety-related structures, systems and component (3) The organization currently responsible for designating the safety classification of activities is the architech/ engineer, 3 Sargent and Lundy (S&L). Licensee personnel stated that i responsibility for classification would be assumed by th '

licensee in the near future. The licensee's personnel are '

working alongside S&L classification personnel to attain the training needed to accomplish the change in classification responsibilit (4) The inspector reviewed approved procedures for maintenance, modification, procurement, inspection, storage and testing of safety-related structures, systems and component (5) The inspector selected names of persons performing safety-related activities from work requests issued _to allow maintenance on safety-related equipment. Training and indoctrination records indicated that each person had received specialized training to qualify him to work on the equipment covered by the work request (6) The inspector reviewed seven audit reports and over 25 surveillance reports documenting Quality Assurance audits and surveillance involving safety-related activities. The l Quality Assurance organization maintains a schedule of planned l audits and surveillance for safety-related activities at the

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I l (7) The corrective action program for safety-related equipment is described in the licensee's Quality Assurance Manual. The inspector's review of corrective action for audit and surveillance findings revealed that corrective action for these

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. findings was timely ~and adequate. The Quality Assurance Department'also. schedules follow-up inspections'of correctiv actions.three months after corrective action is complete and a finding is. closed to determine whether the corrective action is adequate to prevent a recurrence of.the proble (8) Review and evaluation of information concerning malfunctioning <

of equipment is controlled by the licensee's nonconformance-

,(NCR) and deviation report-(DR) program. Both NCRs and DRs are reviewed by management and engineering and, when appropriate, b the architect / engineer and vendor to determine the' suitability  ;

of the equipment to perform its' design functio !

l (9) The inspector reviewed two safety-related and twoLnon j safety-related modifications on the-containment spray syste i The' modification packages, drawings, work requests, travelers,. --

and inspection reports were clearly identified a j safety-related for the safety-related modifications.> The- j documentation for the non safety-related modifications were i identified as non safety-relate )

b. Vendor Interface The inspector reviewed the licensee's Procedure BAP 1340-14 ,

"Ve'n dor Manual Control" that assures- that vendor. information for j safety related components is. current and complete. Vendor manuals -l

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for four components; manual trip switch, Valve CS0v/, RTS breaker .

l and CRDM were; reviewed for completeness and to determine whether the '

l manuals accurately reflected the installed equipment. Guidance' =

provided in the manuals has been included in the maintenance,' test, and inspection procedures used in the plan ]

The inspector did not identify any component that had been supplied by a vendor wi.3 had gone out of business. Vendors-for components I: selected for inspection were major suppliers to the industr The licensee's procedures for controlling'and replacing equipment and j vendor manuals were reviewed and determined to be' adequate to

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l control situations where the vendor goes out'of business or 1 situations in which a vendor will not supply information to the plan ;

l The inspector reviewed vendor recommended modifications on the RTS breakers. The modifications were the shunt trip' modifications, UVTA modification resulting from~ shallow retaining ring grooves and the l modification to provide on-line functional testin All three l' modifications were complet j No violations or deviations were identified.

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.. Reactor Trip System Reliability The inspector verified that the licensee has established a preventive maintenance and surveillance program.for the reactor trip breaker Procedure BAP 4200-15 " Preventative Maintenance. Inspection Reactor Trip Breakers" includes periodic maintenance, lubrication, housekeeping'and other items recommended by. Westinghouse. Trending ,

is required and parameters ~are' established by procedure BVP.600-1

" Reactor Trip Breaker Trending." The inspector reviewed' trend reports and determine'that the required' trending was being performe i The inspector.reviewedu. life cycle testing documentation for the reactor trip breaker and the shunt trip and undervoltage trip:

attachments to determine whether periodic replacement was consistent J with life cycle listing. Replacement'of parts is controlled by

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Procedure BHP 4200-59 " Life Cycle Replacement of UVTA and STA on Reactor Trip / Bypass Breakers."

No violations or deviations were identifie Post Maintenance Testing

The inspector selected two valves, one flow transmitter and one ;

pump for review to verify that the licensee was implementing a 1 post maintenance test progra !

For the selected components, the inspector determined the j following: l l

(1) Written post maintenance test procedures and checklists have been developed by the plant technical staff. -The inspector reviewed ten procedures and five completed tests to verify that

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' i post maintenance testing was being accomplished on the selected

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components in accordance with licensee. commitment (2) Criteria and' responsibilities for maintenance approval and for designating activities as safety-related and non safety-related have been established in Procedure BAP 1600-4 " Initiating and Processing a Nuclear Work Request" and for inspection of post-maintenance testing activities in BVP 1600-T11 " Post Maintenance Checklist."

, (3) Methods for performing functional' testing following maintenance for each safety-related component have been developed and are delineated in published technical staff procedures, operator surveillance procedures and preventive maintenance and- !

surveillance procedure a (4) The inspector reviewed completed Work Requests and' supporting

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l documentation retrieved from the document control records-storage. The documentation contained approvals of Wo_rk Requests, the identity of' persons who performed the activity and the individuals who performed the inspectio '

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(5) The inspector verified that the licensee was performing surveillance of the shunt trip attachment by review of completed surveillance procedures and trending reports for both trains of the RT (6) Verification that the licensee was independently testing the .

ability to manually trip the RTS breakers through the use of l either-the UVTA or STA was accomplished by reviewing completed Surveillance Procedures BOS 3.1.1-3 " Manual Reactor Trip"' and ,

BOS 3.1.1-10 " Bimonthly Staggered Basis, Reactor Trip Breaker {

Shunt and UV Trip Independence Test".

No violations or deviations were identifie . Exit Interview The inspector met with licensee representatives at the conclusion of the inspection and summarized the scope and findings of the.inspoctio The licensee acknowledged the inspector's comments. .The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed during the inspection. Th licensee did not identify any such documents or processes as proprietary, i

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