IR 05000454/1987041
| ML20237A591 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 12/09/1987 |
| From: | Hinds J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20237A575 | List: |
| References | |
| 50-454-87-41, 50-455-87-38, GL-87-06, GL-87-07, GL-87-6, GL-87-7, NUDOCS 8712150117 | |
| Download: ML20237A591 (12) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report Nos. 50-454/87041(DRP);50-455/87038(DRP)
Docket Nos. 50-454; 50-455 License Nos. NPF-37; NPF-66 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Byron Station, Units 1 and 2 Inspection At: Byron Station, Byron, Illinois j
Inspection Conducted: October 31 - November 30, 1987
Inspectors:
P. G. Brochman N. V. Gilles i
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L. N. Olshan
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Approved By:
M. H nds, Jr., lN4 1Z.o9 67
Rea r Projects Section 1A Date Inspection Summary Inspection from October 31 through November 30, 1987 (Report Nos.
50-454/87041(DRP); 50-455/87038(DRP)[d safety inspection by the resident Areas Inspected:
Routine, unannounce inspectors and a headquarters-based inspector of licensee action on previous J
inspection findings; LERs; generic letters; operations summary; training; surveillance; maintenance; operational safety; Part 21 reports; event i
followup; a meeting with local public officials; allegations; and management changes.
Results: Of the 11 areas inspected, no violations or deviations were identified in 9 areas; 2 violations were identified in the remaining areas (failure to perform post-maintenance testing - paragraph 3.b; failure to properly train and to establish a training program for technical staff '
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engineers - paragraph 6).
One additional violation was identified (failure i
to maintain a continuous fire watch in a required area - paragraph 3.a);
however, in accordance with 10 CFR 2, Appendix C, Section V.G.1, a Notice
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of Violation is not issued.
8712150117 973g99 PDR ADOCK 05000454
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DETAILS 1.
Persons Contacted Commonwealth Edison Company
- R. Querio, Station Manager
- R. Pleniewicz, Production Superintendent
- R. Ward, Services Superintendent
- W. Burkamper, Quality Assurance Superintendent
- L. Sues, Assistant Superintendent, Operating
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- G. Schwartz, Assistant Superintendent, Maintenance
- T. Joyce, Assistant Superintendent, Technical Services D. St. Clair, Assistant Superintendent, Work Planning T. Higgins, Operating Engineer, Unit 0
J. Schrock, Operating Engineer, Unit 1 D. Brindle, Operating Engineer, Unit 2 l
T. Didier, Operating Engineer, Rad-Waste I
- M. Snow, Regulatory Assurance Supervisor
- F. Hornbeak, Technical Staff Supervisor
- S. Barrett, Radiation / Chemistry Supervisor P. O'Neil, Quality Control Supervisor
- A. Chernick, Training Supervisor
- W. Pirnat, Regulatory Assurance Staff
- E. Zittle, Regulatory Assurance Staff
- A. Britton, Quality Assurance Inspector
- D. Berg, Nuclear Safety The inspectors also contacted and interviewed other licensee and contractor personnel during the course of this inspection.
- Denotes those present during the exit interview on November 30, 1987.
2.
Action on Previous Inspection Findings (92/01 & 92702)
(Closed) Open Item (454/87033-02(DRP); 455/87031-02(DRP)):
a.
Inspector concern over train separation for auxiliary feedwater pump diesel starting batteries.
The inspector reviewed the applicable portions of the Final Safety Analysis Report (FSAR) and could find no requirements to separate the batteries of different banks for the auxiliary feedwater pump diesel.
The only requirement is for batteries for different ESF trains to be separated.
It appears that the existing configuration is consistent with electrical separation criteria. This item is considered closed, b.
(Closed) Violation (454/87038-01(DRP)):
Failure to verify that an unreviewed safety question did not exist after a test manifold remained installed in a plant system after completion of the surveillance test. The inspector reviewed the licensee's response and verified that the test manifold in line IVQO2A4B was removed on October 9, 1987. The Byron architect / engineer subsequently
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completed a seismic analysis and determined that no safety concerns existed. The licensee's technical staff completed a 10 CFR 50.59 l
review and determined that no unreviewed safety questions existed.
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The licensee's technical staff and operating personnel have walked l
down accessible portions of plant systems and have not identified any test equipment which is installed in or on safety-related
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components, structures, or systems.
Revisions to administrative procedures which control the use of test equipment are under review, to prevent a repetition of this event.
Based on the actions taken, this item is considered closed.
3.
Licensee Event Report (LER) Followup (92700)
(Closed) LERs (454/87020-LL; 454/87021-LL; 454/87022-LL; 455/87001-1L; 455/87017-LL; 455/87018-LL; 455/87019-LL)):
Through direct observation, discussions with licensee personnel, and review of records, the following LERs were reviewed to determine that the deportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with Technical Specifications.
l LER No.
Ti tle Unit 1 l
454/87020 Temporary lack of continuous fire watch due to i
cognitive personnel error.
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454/87021 Control room ventilation actuation due to
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distribution system voltage transient when an offsite
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l line tripped.
454/87022 Containment ventilation isolation due to spike from containment building fuel handling incident area
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radiation monitor.
I Unit 2 455/87001-1 Reactar trip due to one channel of overtemperature delta-T failing because of a poor reactor coolant
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resistance temperature detector splice connection coincident with a second channel out of service.
455/87017 Main steam isolation bypass valve returned to service
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without completion of the required post maintenance l
testing.
455/87018 Reactor trip on low steam generator level when the 28 main feedwater pump tripped due to personnel error.
455/87019 Turbine trip / reactor trip on Hi-Hi steam generator level and subsequent loss of offsite power as a result of personnel error.
The events described in LERs 455/87018 and 455/87019 are also discussed in inspection report 454/8/039; 455/87036.
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a.
LER 454/87020 describes an event on September 2, 1987, in which a continuous fire watch was not maintained in the Unit 2 lower cable spreading room with the carbon dioxide fire suppression system out of service.
Technical Specification 3.7.10.3 requires that with the carbon dioxide fire suppression system for the lower cable spreading room inoperable, a continuous fire watch be maintained. At approximately 12:35 p.m. the assigned fire watch left his assigned area to report for a whole body count without a relief watch being present.
Subsequently, the station fire marshal discovered the missing fire watch. A fire watch was reestablished by 1:42 p.m. on the same day, 67 minutes later.
The licensee has revised procedures for fire watches to require that a post not be vacated without a qualified relief watch being present.
Supervisors were directed not to terminate a continuous fire watch, for any reason, without shift supervisor approval. The failure to
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maintain a continuous fire watch in the Unit 2 lower cable spreading room with the carbon dioxide fire suppression system inoperable is a violation of Technical Specification 3.7.10.3 (455/87038-01(DRP)).
However, this violation meets the tests of 10 CFR 2, Appendix C, Section V.G.1; consequently, no Notice of Violation will be issued, and this matter is considered closed.
b.
LER 455/87017 describes an event on September 3, 1987, in which containment isolation valve 2MS101C was returned to service following maintenance, without the performance of an isolation (stroke) time test.
Technical Specification 4.6.3.1 requires that valve 2MS101C shall be demonstrated operable, prior to its return to service after maintenance, by performance of a cycling test and verification of its isolation time.
The failure to perform the isolation time test i
was identified by the licensee's quality control department. The.
J valve was cycled to verify that it would operate prior to its return to service.
However, an isolation or stroke time test was not j
performed prior to the valve being returned to service. The stroke time test was successfully performed four hours after the valve was i
returned to service.
The failure to perform a stroke time test of valve 2MS101C prior to returning it to service after performing maintenance on it is a violation of Technical Specification 4.6.3.1(455/87038-02(DRP)).
Within the last year, there have been two other instances in which containment isolation valves were not properly tested prior to their return to service. As corrective action for the previous instances, the licensee implemented a plan to review and stamp work requests with the words " CONTAINMENT ISOLATION VALVE" in red ink.
The licensee also required a licensed Senior Reactor Operator (SR0)
to review the work package prior to performance of the work.
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Nuclear Work Request (NWR) B42878 was originally written to troubleshoot a ground on DC bus 211, Consequently, when the
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initial reviews of the NWR were performed, there was no indication j
that a containment isolation valve was to be worked on.
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course of the troubleshooting, maintenance personnel determined that the ground was located in the solenoid-operated air valve for containment isolation valve 2MS101C.
The licensee's procedures for processing work requests did not require that a troubleshooting NWR be stamped the same as a repair NWR, even though both covered an identical repair activity.
The inspector believes that the licensee should review the flowpaths and administrative controls for processing troubleshooting work requests.
No other violations or deviations were identified.
4.
Review of Generic Letters (GLs) (92703)
a.
(Closed) GL (454/86007-HH; 455/86007-HH): Transmittal of NUREG-1190 regarding the San Onofre Unit 1 loss of power and water hammer event.
GL 86007 enclosed NUREG-1190, the report prepared by the NRC Team investigating the San Onofre Unit 1 loss of power and water hammer event. The generic letter stated that, in the team's view, the most significant aspect of the event was that five safety-related
feedwater system check valves had degraded to the point of l
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inoperability within one year, without detection, and that their failure jeopardized the integrity of safety-related feedwater
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piping.
Initial conclusions indicated that the failures were the result of reduced flow, which caused excessive wear.
At Byron, most of the check valves in the feedwater system are not
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subject to reduced flow under certain operating conditions. The feedwater system check valves, whose failure could result in an event similar to the one at San Onofre, are of the fitting disc type. This type of valve has been recommended as a fix for the San Onofre problem because of its resistance to that type of failure.
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The GL requested that licensees ensure that the information in NUREG-1190 is in their training libraries.
Furthermore, the INP0 Significant Operating Event Report, which discusses the San Onofre event, is required reading for all licensed operators.
Therefore, the inspector concludes that the licensee has adequately addressed the concerns of the GL.
b.
(0 pen) Temp ~orary Instruction (TI) (2515/86):
Inspection of licensee's actions to implement GL 81021, " Natural Circulation Cooldown (MPA B0-66)."
Section 5.4.3 of the Byron Safety Evaluation Report (SER)
(NUREG-0876) states that the licensee had to perform the natural circulation cooldown test required by Branch Technical Position
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(BTP) RSB 5-1 prior to startup following the first refueling outage for Unit 1, if similar Diablo Canyon tests were not satisfactorily completed.
In FSAR Amendment 39, Question 212.154, the liccasee made a commitment to satisfy the NRC's concern.
However, by letter dated January 15, 1987, the licensee proposed to perform the natural circulation cooldown test prior to startup following the second refueling outage for Unit 1, rather than prior to the first refueling outage, if the Diablo Ca'1 yon tests were not completed satisfactorily.
By letter dated May 1, 1987, the NRC found the licensee's new commitment to be acceptable.
The letter stated that the Diablo Canyon results have been found to be acceptable, but that the staff is still reviewing the similarity of Byron to Diablo Canyon to determine if the results of the Diablo Canyon testing apply to Byron. Thus, the SER on this issue is not complete.
Closeout of TI 2515/86 is deferred until the SER is completed.
c.
(Closed) GL (454/87006-HH; 455/87006-HH):
Periodic verification of the leak-tight integrity of pressure isolation valves (PIVs).
GL 87006 required licensees to verify the method by which they assure the leak-tight integrity of all pressure isolation valves as independent barriers against abnormal leakage, rapidly propagating failure, and gross rupture of the reactor coolant pressure boundary.
The GL stated that if the correct plant Technical Specifications require leak rate testing of all the PIVs in the plant, a reply to that effect would be sufficient.
The licensee, in a June 11, 1987 letter, made such a reply.
The inspector verified that Byron Technical Specification 4.4.6.2.2 requires the leak rate testing of all PIVs and that they are listed in Technical Specification Section 4.4.6.2.2.
Therefore, i
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the licensee's response is sufficient, and GL 87006 is considered closed.
No violations or deviations were identified.
5.
Surmiary of Operations Unit 1 operated at power levels up to 98% for the entire report period.
Unit 2 operated at power levels up to 95% until 2:00 a.m. on November 26, 1987, when the unit was taken off line for a planned four-week outage.
The unit remained shutdown for the rest of the report period.
6.
Training (41400 & 41701)
The effectiveness of training programs for licensed and nonlicensed personnel was reviewed by the inspectors during witnessing of the licensee's performance of routine surveillance, maintenance, and operational activities and during reviews of the licensee's response to events which occurred during November 1967.
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During witnessing of a surveillance test on the 2A centrifugal charging pump on November 19, 1987, the inspector observed that the technical staff engineer who was performing the test did not record data trom an ultrasonic flowmeter properly (see also paragraph 7).
In October 1982, the NRC staff identified a concern relating to the use of ultrasonic flowmeters and the need to use the totalizer for five minutes to average out flowrate instabilities, to meet data accuracy requirements (0penItem 454/82021-05).
In response to this concern, the licensee j
provided training to test engineers involved in preoperational testing.
In August 1984, the NRC staff again identified a concern with ultrasonic
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flowmeters (0 pen Item 454/84038-06). The licensee's response to the second concern is discussed in Inspection Report 454/84070; although the licensee had originally stated that it would incorporate flowmeter instructions into its procedures, it opted to implement a training /
retraining program for technical staff personnel on how to use the l
f ultrasonic flowmeter. The licensee conducted training on August 21, 1985, to meet this commitment; however, the involved engineer missed that training session.
No other training has been given since that date. Consequently, the technical staff engineer was not trained in the use of the ultrasonic flowmeter.
10 CFR 50, Appendix B, Criterion II, as implemented by Commonwealth Edison Company's Quality Assurance Manual, Quality Requirement (QR)
2.0, requires that the licensee's quality assurance program provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained. QR 2.0, Section 2.3, requires that personnel engaged in testing activities will be assigned according to their formal education l
and on-the-joS training. Additionally, training programs will be developed to indoctrinate and qualify personnel in specific testing activities in which they will be engaged. The performance of testing on emergency core cooling system pumps, to verify the operability of the pumps as required by Technical Specifications, by meeting (ASME)
the requirements of the American Society of Mechanical Engineers
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Boiler and Pressure Vessel Code,Section XI, is an activity affecting
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quality. The discharge flowrate is one of several parameters which are measured to determine if there is any degradation in the pump's performance.
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engineer, who used an ultrasonic flowmeter to perform an ASME surveillance test on the 2A centrifugal charging pump, had been trained on the use of the flowmeter is a violation of 10 CFR 50, Appendix B, Criterion II (454/87041-01a(DRP); 455/87038-03a(DRP)).
The licensee has reviewed the test results for surveillance tests performed by this individual and determined that the test results are consistent with previously performed tests, and therefore, the pump has remained operable.
The inspector discussed the training program for the technical staff with the technical staff supervisor and the training department supervisor.
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The inspector was informed that a training matrix and training standards for technical activities performed by technical staff personnel did not
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exist. Training standards do exist for such activities as basic employee orientation, radiation protection, and processing work requests.
However, there are no training standards which describe the engineering or technical activities which are performed by the Byron technical staff.
Quality Procedure (QP) 2-52 implements the requirements of QR 2.0 and states that it applies to the administration of training programs for
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operations, maintenance, technical, management, and quality assurance
functions in the production area so that personnel achieve and maintain
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suitable proficiency in the performance of their assigned tasks and responsibilities.
QP 2-52 requires that the production training manager prepare training standards for applicable production area personnel.
A training standard is a document which identifies the training i
requirements for a given position.
Figure A of the Byron Station Addenda
to Commonwealth Edison Company's Quality Assurance Manual indicates that technical staff engineers are members of the station production department.
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The inspector reviewed the policy disseminated by the licensee's corporate
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office in Nuclear Stations Division Directive NSDD-Sil, dated May 1,
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Section 5.2.4.3 requires that an individual meet "the specific, pre-established qualifica' ions before performing each unique technical specification test and inspection." Section 5.2.5 requires that requalification is required if an individual has not performed the test or inspection in more than one year.
In this event, it appears that I
neither of these corporate policies was realized.
The failure of the licensee to develop a training matrix and training standards for technical activities performed by technical staff engineers (such as operation of an ultrasonic flowmeter) is a violation of 10 CFR
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50, Appendix B, Criterion II, as implemented b 2-52 (454/87041-01b(DRP)y Quality Requirement 2.0 l
and Quality Procedure
- 455/87038-03b(DRP)).
l The NRC considers this violation to be a programmatic deficiency in
the licensee's training program, which requires prompt attention and corrective action by licensee corporate and station management.
In subsequent discussions with the Byron training department head, the l
inspector was informed that the training department was developing a training matrix for the technical staff and also developing additional training standards.
7.
Monthly Surveillance Observation (61726)
Station surveillance activities of the safety-related systems and l
components listed below were observed or reviewed to ascertain that they were conducted in accordance with approved procedures and in conformance with Technical Specifications.
ASME surveillance of charging pump 2CV01PA 18-month manual phase A test 18-month manual safety injection test
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The following items were considered during this review:
the limiting conditions for operation were met while affected components or systems were removed from and restored to service; approvals were obtained prior to initiating the testing; testing was accomplished in accordance with approved procedures; test instrumentation was within its calibration interval; testing was accomplished by qualified personnel; test results conformed with Technical Specifications and procedural requirements and were reviewed by personnel other than the individual directing the test; and any deficiencies identified during the testing were properly documented, reviewed, and resolved by appropriate management personnel.
During performance of the testing of pump 2CV01PA, the inspector
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j witnessed that the test engineer was not using the ultrasonic flowmeter
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properly. The flowmeter is used to record the pump's discharge flowrate.
Subsequent investigation by the inspector has determined that the technical staff engineer had not been trained on the prop'r use of the ultrasonic flowmeter (this is discussed further in paragrap? 6).
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Monthly Maintenance Observation (62703)
Station maintenance activities of the safety-related systems and components listed below were observed or reviewed to ascertain that
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they were conducted in accordance with approved procedures, regulatory j
guides, and industry codes or standards, and in conformance with Technical Specifications.
18 Diesel Generator Tne following items were considered during this review:
the limiting conditions for operation were met while components or systems were removed from and restored to service; approvals were obtained prior to initiating the werk; activities were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibrations were performed prior to returning components or systems
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to service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were
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properly certified; radiological controls were implemented; and fire prevention controls were implemented.
Work requests were reviewed to determine the status of outstanding jobs and to assure that priority is assigned to safety-related equipment maintenance which may affect system performance.
No violations or deviations were identified.
9.
Operational Safety Verification (71707, 71709, & 71881)
The inspectors observed control room operation, reviewed applicable logs, and conducted discussions with control room operators during November 1987. During these discussions and observations, the inspectors ascertained that the operators were alert, cognizant of plant conditions, and attentive to changes in those conditions, and that they took prompt action when appropriate. The inspectors verified the operability of
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selected emergency systems, reviewed tagout records, and verified the proper re' urn to service of affected components. Tours of the auxiliary, fuel-handling, cad-waste, and turbine buildings were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive Hi rations, and to verify that maintenance requests had been initiated for equipment in need of maintenance.
The inspectors verified by observation and direct interviews that the j
physical security plan was being implemented in accordance with the j
station security plan, t
The inspectors obser ad plant housekeeping / cleanliness conditions and verified implementation of radiation protection controls.
The inspectors also witnessed portions of the radioactive waste system controls associated with rad-waste shipments and barreling.
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l The observed facility operations were verified to be in accordance with the requirements established under Technical Specifications, 10 CFR, and administrative procedures.
No violations or deviations were identified.
10. Review of 10 CFR Part 21 Reports (92700)
(Closed) 10 CFR 21 Report (454/86001-PP):
Nonseismically rualified s
components in diesel generator overspeed protection circuic.
The diesel
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generator vendor submitted a 10 CFR 21 report after the installation of l
the non-qualified devices was discovered at Byron on December 19, 1986.
l The licensee installed temporary jumpers to defeat the non-qualified l
devices.
Permanent jumpers were installed by modifications M6-1-86-292 i
for Unit 1 and M6-2-86-292 for Unit 2.
Based on this action this Part 21 I
report is considered closed.
11. Onsite Followup of Events at Operating Reactors (93702)
The inspectors performed on'ite followup activities for an event which occurred during November ILd7. This followup included reviews of operating logs, procedures, Deviation Reports, Licensee Event Reports (where available), and interviews with licensee personnel.
For the event, the inspector developed a chronology, reviewed the functioning of safety systems required by plant conditions, and reviewed licensee actions to verify consistency with procedures, license conditions, and the nature of the event. Additionally, the inspector verified that the licensee's investigation had identified the root cause of the equipment malfunctions and/or personnel errors and had taken appropriate corrective actions prior to plant restart.
Details of the event and the licensee's corrective actions developed through inspector foilowup is provided in paragraph a below:
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Unit 1 - Unusual Event Declared due to Inoperable Control Rods At 9:18 p.m. on November 2, 1987, with reactor power at 97%, a control rod urgent failure alarm was received. At 11:35 p.m.
maintenance personnel determined that the alarm was not spurious but due to a blown fuse. Technical Specification 3.1.3.1.b requires that with greater than one control rod inoperable, the unit be placed in hot standby (Mode 3) within the next six hours. The control rod urgent failure alarm prevents the control rods from moving; however, the rods are still capable of being tripped. At 11:35 p.m. an Unusual Event was declared and a power reduction was commenced. By 1:24 a.m. on November 3,1987, the blown fuse had been replaced, the urgent failure alarm reset, and the control rods exercised to verify their operability. At 1:42 a.m. the Unusual Event was terminated, and the unit was returned to rated power.
No violations or deviations were identified.
12. Meeting with Local Public Officials (94600)
On November 5, 1987, the senior resident inspector attended a meeting with local public officials from communities surrounding Byron Station.
l The meeting was held by the licensee as part of an annual program to l
meet with officials of agencies which are responsible for offsite I
emergency preparedness activities.
13. Allegation Followup (99014)
On October 27, 1987, the inspector was informed by licensee management that an individual had admitted to the use of controlled substances.
l The individual was not a supervisor and did not perform licensed or safety-related duties.
The individual's security access was suspended, pending a medical evaluation.
The individual subsequently tested
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positive for the use of controlled substances. The individual entered the licensee's Employee Assistance Program (EAP).
On November 18, 1987, the inspector was informed that following completion of a medical evaluation, the individual's security access was restored and the individual was returned to duty.
The individual is continuing to participate in the EAP, and the individual's performance will be monitored by supervisors and the resident inspectors.
No violations or deviations were idencified.
l 14. Management Changes l
On November 13, 1987, the inspector was informed of several personnel
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reassignments at Byron Station.
The Assistant Superintendent for I
Technical Services and the Assistant Superintendent for Operations were exchanging positions. The Technical Staff Supervisor was assigned as a Senior Staff Engineer, Administration. The Radiation-Chemistry a
l Supervisor was assigned as Technical Staff Supervisor.
The former j
l Station Chemist, having obtained a Senior Reactor Operator license, was l
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Manager position will continue to be fulfilled by the Station Health l
Physicist.
15.
Violations for which a " Notice of Violation" Will Not Be Issued l
The NRC uses the Notice of Violation as a standard method for formalizing l
the existence of a violation of a legally binding requirement. However, because the NRC wants to encourage and support a 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 V.G.I.
These tests are:
(1) the i
violation was identified by the licensee; (2) the violation would be
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categorized as Severity Level IV or V; (3) the violation was reported to the NRC, if required; (4) the violation will be corrected, including measures to prevent recurrence, within a reasonable time period; and (5)
it was not a violation that could reasonably be expected to have been
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prevented by the licensee's corrective action for a previous violation.
A violation of regulatory requirements identified during the inspection for which a Notice of Violation will not be issued is discussed in i
paragraph 3.a.
i 16. Exit Interview (30703)
The inspectors met with the licensee representatives denoted in paragraph i
1 at the conclusion of the inspection on November 30, 1987.
The inspectors summarized the purpose and scope of the inspection and the g
findings.
The inspectors also discussed the likely informational content t
of the inspection report, with regard to documents or processes reviewed by the inspectors during the inspection.
The licensee did not identify l
any such documents or processes as proprietary.
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