IR 05000454/1989007

Insp Repts 50-454/89-07 & 50-455/89-10 on 890313-17 & 22. Violation Noted.Major Areas Inspected:Implementation of Inservice Testing,Including Administrative & Technical Procedures,Performance of Testing & Retention of Records

ML20248G984
Person / Time
Site:	Byron
Issue date:	03/31/1989
From:	Danielson D, Huber M, James Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20248G979	List: IR 05000454/1989007 ML20248G975 ML20248G981
References
50-454-89-07, 50-454-89-7, 50-455-89-10, NUDOCS 8904140023
Download: ML20248G984 (9)

Text

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-454/89007(DRS); 50-455/89010(DRS)

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Docket Nos. 50-454; 50-455 Licenses No. NPF-37; NPF-66 '

Licensee: Coninonwealth 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: March 13-17, and 22, 1989 Jigd<J/4-Inspector: J. F. Smith 3'

Date ad71d[AM A'

,~,M. P. Huber 3)3//#7 Date M kt w >

Approved By: D. H. Danielson, Chief 3)3//I7 Materials and Processes Section Date J Inspection Summary Inspection on March 13-17, and 22,1989 (Reports No. 50-454/89007(DRS);

No. 455/89010(DRS))

Areas inspected: vaannounced inspection of implementation of Inservice -

Testing (IST) (73756) including administrative and technical procedures, performance of testing, retention of records, and recording of trend Resul ts: One apparent violation was identified -Paragraph 2.a(2). The inspectors also noted the following:

Within the areas reviewed, the implementation of IST generally follows the requirements of Section XI and the licensee's progra The licensee's IST staff is small. The majority of IST is performed by systems engineers who route procedures and test results through the IST staff. Scheduling is performed by the Scheduling Coordinator in the Work Planning Department. The IST Group administers, coordinates, and provides test analysis for the IST Progra PDR ADOCK 05000454 Q PDC

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The licensee's administration of the IST Program is not always rigorous

- in adherence to details of.the ASME. Code and IST Progra The licensee's staff is highly responsive to NRC initiatives. Corrective action was initiated for each NRC observation made during the inspection, including the apparent violatio .

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DETAILS

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1. Persons Contacted Commonwealth Edison Company (CECO), Byron

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• R. Pleniewicz, Station Manager

• J. J. Ewald, Technical Primary Group Leader

• R. A. Flahive, Technical Staff Supervisor .. .

• J. Harkness, Technical Staff, ISI Group Leader I

• A. L. Javorik, Regulatory Assurance Staff 1

• R. Kim, Technical Staff Engineer

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• J. A. Kudalis, Services Director

• G. K. Schwartz, Production Superintendent

• G. Stauffer, Regulatory Assurance

• D. A. Winchester, Quality Assurance Superintendent -

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• E. M. Zittle, Regulatory Assurance Staff -

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NRC Resident l *N. Gilles, Resident Inspector-

• Denotes those attending.the exit meeting on March 2E, 198 . ISTProkramReview The inspection was based on the Comonwea'lth Edison Company program submittal for Dyron Station, Units I and 2, Revision 6 for pumps and Revision 7 for valves, submitted August 21, 1987, and revised by letters dated May 16, 1988, and July 29, 1988. The IST program was found. to be acceptable for implementation provided the omissions and inconsistencies identified were addressed. This approval was granted by the Safety Evaluation Report (SER)issuedbyNRConSeptember15-, 198 The NRC inspectors reviewed the inconsistencies identified in the SER to ensure that actions taken were adequate and complete. Upon reviewing the actions taken to address the anomalies identified in the.SER, the NRC inspectors noted that IST program changes did not receive the necessary written approval for implementation as stated in the SER. The' licensee l did receive verbal approval for subsequent changes but noted that written approval after review by the NRC would be pursued for any future revisions.

t Ancmalies Identified in SER The NRC, with technical assistance from EG&G Idaho Incorporated, identified concerns with the licensee's IST program and noted them in the SER. The NRC inspectors reviewed the actions taken to address the concerns. Procedures and the IST program Relief Requests were also reviewed. The following problems were note '

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(1) Pum_p Records The licensee had not completely updated their pump records to correspond with the corrective actions taken to address the concerns in the SER. Pumps records, and corresponding parameters kept in accordance with IWV-6000, were recorded on BVP 200-T22 data sheets. The sheets were reviewed for completeness and'

accuracy for the Essential Service Water (SX) pumps, OSX02PA and B. The NRC inspector noted that the SX pump records were not correct. Relief Request PR-3 which was deleted was still being referenced. Additionally, the vibration locations were not specifically noted as required. The NRC inspectors had to use the actual surveillance procedure to determine all the test j requirements and code requirements were being met. Procedure i 2BVS 6.2.1.B-1, Revision 3, dated December 14, 1988, "ASME l Surveillance Requirements (2CS01PA) for 2A Containment Spray ,

Pump," was also reviewed and it was found that the locations - '

for taking vibration measurements were unclea The licensee had the procedures under revision at the time of this inspection. These proposed revisions were reviewed by the NRC inspector. Reference locations were more explicit in the

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procedures and were acceptable. The licensee committed to have the procedures revised by April 30, 1989, to incorporate the {

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specific vibration 1ccations and pressure measurement ]

(2) Accumulator, Outlet Check Valve; Testing g In valve relief rcquest VR-5 the licensec has proposed to full- .

stroke exercise the accumulator outlet check valves 1(2)SI6948A-D l and 1(2)S18956A-D at cold shutdcwns, if not performed in the previous nine racnths. These valves can be full-stroke exercised ;

by timing the rate of decrease of accumulator level and extra- !

pelating the flow rate throsgh the valve The NRC inspectors reviewed the surveillance tests to ensure the licensee adequately addressed the requirements to full-stroke !

these valve Procedure IBVS 0.5-2.SI.2.3, Revision 3, dated March 4, 1988,

" Accumulator Back-Up Check Valve Stroke Test," performed September 5, 1988, only exercised the check valves. The licensee '

revised their procedure in order to address the concerns identified in the SE Upon review of 2BVS 0.5-2.SI.2-3, Revision 3 dated January 7, i 1989, performed on March 2, 1989, the NRC inspector found the {

acceptance criteria to be inadequate to ensure a full-stroke i exercise of the valve, as required by ASME Code Section XI, i Subartical 1WV-3520, " Tests for Check Valves." The NRC inspectors discussed the concern that full-stroke testing of l

the valve might not have been completed due to the inadequate j acceptance criteria. This was not the case, however, and the

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licensee commenced a revisicr. cf the check valve testing j

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procedure to. include appropriate. acceptance criteria.~ 'The-failure to have the appropriate criteria in the procedure-is q considered an apparent violation of 10 CFR 50, Appendix B, a CriterionV(455/89010-01(DRS)).-Noreplytothisviolationis d required since action were taken to correct the violation and 1 to prevent recurrenc , ,j i Administrative Control of Inservice Testing

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l The NRC inspectors confirmed that administrative controls were in 1 place to satisfy.the requirements of the IST Program and that '

specific IST duties had been assigned to personnel. The licensee's approach to IST is to retain a small fonnal IST organization and to assign responsibility for the actual testing to the Systems-j

. personnel. -The System engineer provides1the. written procedure-for meeting the IST requirements in accordance with a standardized j

format. The procedure approval chain includes the IST group, which~

confirms adherence of the procedure to the requirements of the . ~~ j program. . Scheduling is organized by the Scheduling Coordinator in- 1 the I!ork Planning Department. The actual performance of the test is ~]

also coordinated with the Operations personnel by the Operations'and Maintenance Departments. Upon completion of the tests, the results are immediately reviewed for any results which fall into.the

" required Action" range or in any other way indicate a failure'of  ;

the' pump or valv In any case where the pump or valve.in question /

might, if inoperative, result. in an. LC0,~ the NRC inspectors .]

confirmed that the procedures required that the pump or valve be declared inoperative immediatel 'After completion of the IST, the test results are forwarded to the-ISI group for review and approval. The ISI group determines if any of the results fall into the " Alert Range." If so, they initiate action to place the equipment on increased surveillance. The results '

of the testing are entered into the trending books maintained by the-ISI Group and the test results.then continue through the approval chain to the records section for storag ,

3. Pump and Valve Inservice Testing Program Implementation (73756)

The licensee's IST Program was reviewed by the N P inspectors for information and for use as a standard to be met o Byron procedures for-implementation of the program. The-NRC inspectoi ' review of program implementation covered areas from the development - an organization and-administrative controls through~ the performance of testing, analysis of results, and trending of data, . Instrument, Storage and Calibration Each instrument formally used in'the IST program is maintained in accordance with the requirements of BAP400-4 ." Control of Station- -i

~ Measurement and Test Equipment." At the time it first enters into-  !'

the system, it is assigned one or niore unique identification numbers and a history file is initiated for it. This history contains a record of each significant event in which the instrument was involved,

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l such as calibrations, dama'ges, repairs, rebuilding, etc. -[All f -l calibrations were performed using standards traceable to the National- .

Bureau of Standa'rds (NBS) when the Bureau provides standards. 0ther- '

wise, standards traceable to other nationally ' recognized organizations are used. Calibration for most long-cycle calibrations were performed 1 at the licensee's Maywood Technical Center. = Shorter period calibrations

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were performed at the statio j I

All instruments were listed in a computer program which identifies ~

each instrument and its calibration period. Data from this program was accumulated each month and added to o'ther information concerning

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I previous calibrations which were not performed on schedule to~ form )

. the " Tech Center Instrument System Monthly Report." (This . program ]

could also be called up at any time by personnel at the station) i Stopwatches were calibrated using a high frequency signal generato The calibration-of quartz-controlled stopwatches were calibrated by- a -

direct comparison of the frequency of the quartz crystal with that 3 of the generator. Mechanical stopwatches using spring-operated I balance wheels were calibrated by comparing the number of cycles of )

the signal generator at a known frequency for the timed period of the stopwatch. Either method ~would yield an accuracy greater than

.that required for the timing of valve stroke time The NRC inspectors review of the instrument storage and calibration controls provided for IST equipment confirmed that it is adequate-to ensure the required accuracy for, this progra Remote Position Indication The performance of the Valve Position Indicator Verification required by IWV-3300 was done at every refueling outage for the position indicating lights at the Main Control Panel (MCP). In accordance with the licensees letter of December 14, 1988, to A. B. Davis, US NRC Regional Administrator, Region Ill. .a different procedure was proposed for other remote position indicators for which ,

the licensee deemed that further testing was prudent. For these '

position indicatorsi a one-time verification was performed to ensure that the position indicator functions properly. The licensee i implied by this proposal that once the position of the 'other remote indicators was confirmed, to conform with that of the MCP it would remain so. One design feature which supports this philosophy was <

that the lights from the Main Control Panel and the Remote Shutdown Panel were joined at the Motor Control Center. Only one' set-of wires for position indicating lights goes. to the M0V. Any transposition in position indicating wiring at the MOV would show up identically at both the Main Control and the Remote Shutdown Panel so it could be readily detected. In order to create a reversal of indications between the two panels (which might not be detectable at the MCP)

the error must occur at the MCP. ' Errors in wiring at the MCC were controlled by mandatory testing. Such-testing was performed after maintenance which could result in an affect on the performance of the valve. This testing was mandated by IWV-320 _ _ _ _ _ _ - _ _ - _ _ - _ - _ _ _ - _ _ _ _ _ - _ - _ _ _ _ _ - _ .

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The NRC inspectors indicated a concern that should any position indicating. light wiring from several remote areas be joined at'the MOV, the chances for wiring errors to occur would be increased for the following reasons:

M0V's are more likely to be worked on by contractor-per',onn.el than MCC's ar M0V's are not worked on' exclusively by the licensee electricians, as MCC's . are. (For example, for lubrication and *

mechanical problems).

NOV's are frequently located in inconvenient areas where accessibility and illumination are poor and. errors can occur easil In order to confirm that the light junctive occurred at the MCC's ~

rather than the M0V's, the NRC inspector and the licensee examined a sample of the wiring diagrams for the MOV's for which one-time position indicator confirmation was proposed. Included in the test sample were valves RY 8000A and B. These valves.were found to have position indication light connections made at the M0V. As a result, wiring diagrams for all remaining valves in the one-time confirmation .

group became suspect and were examine The RY 8000A and B were th only valves found with connections for both position indicating lights at the M0V. The position indicating lights for these valves were at both the MCP and the MCC. The licensee's management reviewed the situation, agreed that there was added potential for ' error in these valves and committed to adding appropriate corrective action to procedures involving maintenance of these valves. The NRC inspectors agreed that this would help alleviate ~ the potential proble c. Stroke Time Measurement By Position Indicating Lights The correlation of stroke-time with the stroke-time indicated by observation of position indicating lights at Byron does not provide the conflict present at other plants. The M0V's at Byron were of the 4-Rotor type. This presents separation of the position indicating light function from that of ~ the torque switch bypass. Ideally, rotors for the position indicating lights should be located close to the' limits of travel. The rotor for bypassing might be as'much as ?.0% of the stem travel off the "close" end of the stroke. 'When 2-rotor switches are used, extraordinary means are needed to ensure accurate stroke timing is accomplished, d. Trending of Insevice Testing Data Trending records are maintained by ISI Pump and Valve personnel. After performance of the inservice test, the IST information is transmitted to the ISI group, where'it is analyzed and. decisions are made in the area of increased (or reduced) surveillance frequency. '~After-the' data is analyzed, the appropriate information is extracted and entered into the trending books. Individual pumps and valves were identified in the trending books by their unique equipment identification number and -

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l periodic IST records were entered to allow comparisons with-posthST readings. Trending curves were not prepared from the available dat ]<

Check valves were included in the_ data and space was provided to. allow

' the addition of notes for test observation '

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i Supplementing the conventional trending record was a computerized I information source whin provides a record of the maintenance -

history of each pump ant) valve (as well as other items). This was i entitled, " Generating' Station Maintenance - Maintenance History -

Selective Retrievals." Thus it was possible to trace not only the variations in test criteria shown in the ' trending records but also to 4 determine the corrective action performed on the component in

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relation to the times at which the various test results were show The combination was effective in + Sat'neither document was burdened by i the bulk of the other until the information in the other was desired.

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' Completed Surveillance Review -

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, The NRC inspectors reviewed several procedures to ensure Code

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requirements were met and to evaluate the effectiveness of the progra The following surveillance packages were reviewed:

2BVS 0.5-2.MS.3, " Main Steam System Valve Indication Test,"

completed February 21, 1989.

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2BVS 0.5-2.MS.2, " Main Steam Isolation Valve Indication Test,"

completed February 27, 198 .!

2BVS 0.5-2.AF.3, " Auxiliary Feedwater Valves Indication Test,"

, completed February.24,198 BVS 6.1.2.d-1.22, Revision 2, dated July 21,1988, " Primary Containment Type C Local Leak Rate Test of the S. I. System,"

performed on September 26, 1988 for valves 151 8968, 8880, and 887 .

1BVS 6.1.2.d-1.8, Revision 2, dated May 27, 1988, " Primary Containment Type C Local Leakage Rate Tests of PS System," ,

performed on September 24, 1988, for the following valves; 1PS 9354 A and B, IPS 9355 A and B, and IPS 9357 A and B. and on September 22, 1988, for the following valves: IPS 228 A and B, IPS 229 A and B, and IPS 231 A and i'

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No problems were noted. Valves were tested in accordance with applicable code requirements, and were within acceptable limit Valves were then trended to detect degradation where first test failures were noted. The NRC inspector verified proper corrective action and retest as well as any required post maintenance testing (PMT). In cases where PMT was required the proper actions were taken and the stroke-times routed to the ISI coordination and trende ;

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.h l 4. Test Observation ~ --

The NRC inspectors witnessed the surveillance testing petformed on the 1 OA essential service water makeup pump (0SX02 PA). Vibration data was obtained using calibrated equipment and the points used for measurements were clearly marked on the pump, but not in the procedure (see Paragraph 2.a.(1)). Vibration data was obtained by members of the technical staff who had been trained in vibration measurement and data analysi . Overall Performance Evaluation .

Based on the review conducted by the NRC inspectors, it appears that the l licensee had a good working IST program. The observed pump test was well !

coordinated between the various departments responsible for the testing and performed professionally. The licensee needs to ensure that details are not overlooked, however, as evidenced by the problems noted in this repor __ . j 6. Exit Interview The Region III inspectors met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on March 22, 198 The inspectors summarized the purpose and findings of the inspectio The licensee representatives acknowledged this information. The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed during the inspection. The licensee representatives did not identify any such documents / processes as proprietar _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _- - - _ - _