IR 05000454/1990012

Insp Repts 50-454/90-12 & 50-455/90-11 on 900401-0512. Violations Noted.Major Areas Inspected:Previous Insp Findings,Operational Safety,Esf Sys,Onsite Event Followup, Radiological Controls & Security

ML20043C296
Person / Time
Site:	Byron
Issue date:	05/29/1990
From:	Farber M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20043C294	List: IR 05000454/1990012 ML20043C293 ML20043C295
References
50-454-90-12, 50-455-90-11, NUDOCS 9006050022
Download: ML20043C296 (16)

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y U.S. NUCLEAR REGULATORY COMMISSION

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REGION III

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Report Nos. 50-454/90012(DRP);50-455/90'011(DRP)

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Docket Nos. 50-454; 50-455--

License Nos. NPF-37; NPF-66.

g Licensee: Commonwealth Edison Company

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Post Office Box 767'

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Chicago, ILo 60690'

W Facility Name:

Byron Station, Units-I and 2 l

Inspection At: : Byron Site, Byron, Illinois

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Inspection Conducted: April 1 through May 12, 1990 e

. Inspectors:. W..J. Kropp

R. N. Sutphin j

T. E. Ploski;

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D. R. Calhoun

. Approved By:

3F ber, Chief f/2f[fo React'o Projects Section IA Date./

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l Inspection : Summary

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' Inspection-from April:1 through May 12, 1990 (Report.Nos. 50-454/90012(DRP);

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l 50-455/90011( DRP))

Areas = Inspected: cRoutine, unannounced safety inspection by'the resident j

_ inspectors-of action on previous inspection = findings, operational. safety, n

engineered safety feature systems, onsite event followup, current material

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- condition,iradiological controls, security, safety assessment / quality

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verification, maintenance. activities, surveillance activities, engineering-&

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technical support and emergency preparedness.

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v lResults:

In the area.of plant operations the licensee's performance continues-

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10 be go'od. 'Several plant' transients were controlled by the reactor operators '

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,in a' correct and responsive manner.

Shift briefings were enhanced by the

' addition of chemistry and radwaste personnel.

The enhancement was indicative

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of ~ station's management continued -initiative in maintaining teamwork at Byron.

i Management.has focused attention on the material condition of Unit-0 equipment

.to obtain.a level commensurate with the rest of the plant. The quality of

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LERs in the root cause' analysis and corrective actions continue to be good.

Thexlicensee's overall performance in maintenance was aggressive in the implementation of corrective action to the degraded resistors in the EDG.

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speed control circuit. The control of calibration activities in the area of

. repetitive out of tolerance fluke digital multimeters needs improvement.

The licensee's performance in the Onsite Review (0SR) process continues to be i

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. mixed. Theitechnicallsupport for the Lresolution of the -degraded' resistors in

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the.EDG speed control circuit was4 considered very good.. -One violation was.

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' ;; issued that-pertained to the OSRs performed for Battery 111 as described. in:.

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'Section:6.b of this report.and an.non-cited violation.was. identified in Section

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~7 that pertained to entering a Unusual Event two hours'1ater than required..

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- Anyopen item was identified with a request for a written response' from:the d

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licensee that oertains to the specific gravity and frequent equalizing charges

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of the: station'.sil25:Vdc batteries. This open item is discussed in~Section:

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'6.b of thisireport.

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DETAILS-m

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Persons-Cont' acted

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Commonwealth Edison Company (Ceco)

• R. Pleniewicz, Station Manager

• K.sSchwartz, Production Superintendent A

• R. Ward,' Technical Superintendent'

• J.- Kudalis, Service Director D. Brindle, Operating Engineer, Administration T. Didier, Operating Engineer, init 0

.T. Gierich, 0perating Engineer, Unit 2

• T. Higgins,' Assistant Superinte'ident, Operating

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J. Schrock, Operating Engineer, Unit'1

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M. : Snow,- Regulatory Assurance Supervisor

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D D. St.' Clair,- Assistant Superintendent,! Work Planning

T. Tulon,' Assistant -Superintendent, Maintena'nce r

D. Winchester, Quality Assurance Superintendent'

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• D. Wozniak,. ENC Project Manager aj

• E. Zittle, Regulatory _ Assurance Staff

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• Denotes those attending the exit interview conducted on May 11, 1990, i

and at other times throughout the inspection period.

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i The inspectors also had discussions.with other licensee employees, including. members.of the technical and engineering staffs, reactor and auxiliary. operators, shift engineers and foremen, electrical, mechanical-and~ instrument maintenance personnel, and contract security personnel.

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2.

Action on Previous Inspection Findings (92701 & 92702)

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(Closed)UnresolvedItem(454/89017-01;455/89019-01(0RP)).

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- Setpoint reference for the Auxiliary Feedwater (AFW) pump suction,

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' pressure transmitter. >For further. details see Section 6.a of

'this report.

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(Closed)Unresolveditem(454/90010-02-(DRP)): The=0n-Site Reviews

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(OSR) for the justification for Battery 111 operability with 57

cells. A working meeting was conducted in Region III with.the licensee and licensee-engineering representatives on April 24, 1990, to discuss the applicable OSRs. This Unresolved Item was closed based on'the issuance of a Violation.

For further details see

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Section 6.b of this report.

3.

Plant Operations Unit 1 com]leted a four day maintenance outage on April 2, 1990. The reactor ac11eved criticality at 8:48 p.m. and the unit was synchronized to the. grid at 2:00 a.m. on April 3, 1990.

Since April 3, 1990, the unit had operated up to-100% in the load following mode until a reactor trip occurred on May 3, 1990, at 6:31 a.m.

For further details see Section 3.c-(2). The unit was returned to service on May 4,1990, at 10:06 a.m.

and has since operated in the load following mode.

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Unit 2 operated :at power levels' up to 100% in the load following mode for the entire report period.

a.

Op'erational Safety (71707)

During the inspection period, the inspectors verified that-the:

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facility was being operated <in conformance with the licenses L

. and regulatory requirements and the licensee's management-1 responsibilities were effectively carried out for safe operation, i

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Verification was based on. routine direct observation of activities

and equipment performance, tours of the facility, interviews and

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discussions with licensee personnel, independent verification of safety system status and limiting conditions foi operation action

-requirements. (LC0ARs), corrective action, and review of facility

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records, i-On a sampling basis the inspectors daily verified proper control l

room staffing and access,_ operator behavior, and coordination of plant activities with ongoing control room operations; verified ~

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operator adherence with the latest revisions of procedures for

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ongoing activities; verified operation as required by Technical

Specifications (TS); including compliance with LC0ARs, with emphasis

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.onengineeredsafety. features (ESF)andESFelectricalalignment a

and valve. positions; monitored instrumentation recorder traces and

duplicate channels for abnormalities; verified status of.various lit

annunciators _for operator understanding, off-normal condition, and

compensatory actions; examined nuclear instrumentation (NI) and other protection channels for proper operability;. reviewed radiation monitors and stack monitors for abnormal conditions; verified that

.onsite and offsite power was available as required; observed the frequency. of plant / control room visits by the station manager, i

superintendents, assistant operations superintendent, and other

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'I managers; and observed-the Safety Parameter Display System (SPDS)

for operability.

No problems were noted.-

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The attendance in shift briefings in the control room has been-expanded to include personnel from the chemistry and radwaste organizations..During the shift briefings, both. individuals '

. discussed information pertinent to the chemistry and radwaste status of the plant requirements. Also, during the morning

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meetings the status of annunciators pertinent to chemistry panels and the material condition of chemistry equipment was discussed and tracked in the morning meeting minutes. The enhancement in the shift briefings and morning meetings was considered an example

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of good management initiative to improve and maintain the good

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teamwork exhibited by the Byron staff.

On a walkdown of the plant, the inspectors noted that battery)

exhaust fan, 2VE-020, for Battery 212 was out of service (005 with the control switch on the local control panel pulled to lock.

The battery exhaust fan function includes the removal of hydrogen from the battery rooms during battery charges. The inspectors r

ascertained tnat Battery 212 was not on an equalizing charge.

However, there were no controls in place to ensure that compensatory

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action,. such 'as portable fans,' would be utilized if Battery 212 was placed on an equalizing charge. The licensee immediately.

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'placed a caution tag 'on-the Battery 212 charger that identified-

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.the inoperable battery exhaust fan _ to operations personnel. The i,

' inspectors discussed this issue with station management.and in-

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the future will monitor for proper compensatory actions with 00S

e equipment.

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b.

Engineered Safety Feature (ESF) Systems (71710).

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-During the' inspection, the inspectors selected accessible. portions

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of several ESF systems to verify status.

Consideration was-given i

to the plant mode, applicable Technical Specifications, Limiting

I ConditionsforOperationActionRequirements.(LC0ARs),andother-t

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applicable requirements.

I Various observations, where applicable, were made.of hangers and supports; housekeeping; whether freeze protection,-if required, was

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installed and-operational; valve position and conditions; potential-(

ignition-sources;, major-component labeling, lubrication, cooling,

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etc.;- whether instrumentation was properly installed and functioning and significant process parameter values were consistent with.

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expected values; whether instrumentation was calibrated; whether~

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'necessary support systems were operational;.and whether locally and

> remotely indicated breaker and valve positions agreed.

During the inspection, the accessible portions of Unit 1 and Unit 2

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Essential' Service Water -(SX) systems were inspected.. The inspector -

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identified only two minor items that.were communicated to the station's staff. One item pertained-to a nameplate on a panel and the other item pertained to the color of an indicating light. The inspector ascertained that the material condition and the house-

keeping of.the SX areas were good.

c.

OnsiteEventFollow-up(93702)

i (1) On April UnusualEvent.(UE10,1990} at 9:17-p.m., the licensee declared an~

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for Unit 1.

The UE was declared when both emergency diesel generators (EDG) were declared inoperab_le.

EDG 1B had been taken out of service (00S) earlier on April 10, 1990 at 9:55 p.m. for planned maintenance to repair oil leaks.

The time to perform the repairs was longer than expected. The technical specifications-(TS) required verifying operability of the 1A EDG if the IB EDG could not be returned to service in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. When the 1A EDG was started for the operability test

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at 7:17 p.m., on April 11, 1990, the speed oscillated between

'280 and 600 rpm.

Further attempts to start the 1A EDG also resulted in speed oscillations. The licensee then had two

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hours in accordance with TS to return one of the EDGs to an operable status or place Unit 1 in hot standby in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.-

The licensee could not return either EDG to an operable status

within two hours and commenced a Unit I shutdown at 9:17 p.m.

on April 11, 1990.

The 1A EDG was repaired, ^

a post maintenance test completed.

The 1A EDG was e ciared operable

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at'1:21 a.m. on April 12, 1990, and.the UE was terminated..

-The cause of the 1A EDG speed oscillation was a failed resistor h'

in the speed control circuit.= The failure of this' resistor f

is further discussed in'Section 5.a of this report. The-

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inspectors reviewed the, licensee's emergency action levels i-(EAL) and-had questions about when the UE_should have been

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declared. - A regional specialist in emergency planning

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' reviewed the licensee's action during the UE and the results

- are discussed:in Section 7 of this report.

(2) -On Thursday May 3,'1990, at 6:31 a.m.,~ Unit I experienced an.

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unplanned reactor trip -and Engineered. Safety Features (ESF)

actuation. The resident inspector arrived at the site at 6:55 a.m. and observed the-licensee's actions in the main control

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room in response to the trip.

The licensee's action during

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the trip was' considered good.

The cause of the trip was a

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malfunction of-the Digital Electro-Hydraulic Control.(DEHC)

system for the Unit 1 Turbine.

The Unit 1 Turbine Throttle Valve / Governor. Valve (TV/GV) monthly surveillance was in process at the time of the trip.

A fuse had previously blown L

in the DEHC and was being replaced; when the fuse was replaced'

the.26 volt DEHC.powcr supply voltage spiked and the. turbine Steam Generator (plete _ load rejection that resulted in a 1A

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experienced a com SG) level below the reactor trip setpoint.

' All systems-responded as designed, including the Auxiliary j

Feedwater Pumps which auto-started on the 1A Lo-2 SG Level

as an ESF actuation. The inspectors will review the LER for j

appropriate root cause and corrective action.

d.

Current-MaterialCondition(71707)

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The inspectors performed general plant as well as selected system I

and component walkdowns to assess the general and specific material

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condition of the plant, to verify that Nuclear Work Requests (NWRs)-

had teen initiated for identified equipment problems,' and to

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evaluate housekeeping. Walkdowns included an assessment of the

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buildings, components, and systems for proper identification and

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tagging, accessibility, fire and security door integrity, e

scaffolding, radiological controls, and any unusual. conditions..

Unusual conditions included but were not limited to water, oil, or

other liquids on the floor or equipment; indications of leakage i

through ceiling, walls or floors; loose insulation; corrosion; excessive noise;, unusual temperatures; and abnormal ventilation and lighting. The material condition of Unit 1 and Unit 2 was

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considered above average. The material condition of the conmon

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equipment (Unit-0) remains average, however, increased management attention has been focused in this area.

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RadiologicalControls(71707)

The inspectors verified that personnel were following health physics

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procedures for dosimetry, protective clothing, frisking, posting, it etc. and randomly examined radiation protection instrumentation for

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use, operability, and calibration.

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Security ' (81064)I

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y Each week during activities or tours, the inspector monitored' the

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-licensee's security program to ensure that observed actions were

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implemented in accordance with-the approved security plan. The-

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inspector noted that persons within the protected area displayed'

7 proper _ photo-identification badges and those individuals requiring i

escorts were properly escorted.. The inspector also' verified that

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checked-vital areas were locked and alarmed. Additionally, the.

inspector also verified that observed personnel and packages entering-the protected area were searched by appropriate equipment

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or by-hand.-

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Assessment of Plant Operations L

The licensee's performance continues to be good.

Several plant

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transients-caused by spurious turbine runbacks prior to the May 3,

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1990, reactor. trip were controlled by the reactor operators in-a

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correct and responsive manner. The shift briefings were enhanced by the addition of chemistry and radwaste personnel. This enhancement J

was indicative of. station's management continual initiative in-j maintaining the teanwork atmosphere at Byron.

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No violations or deviations were identified.

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4.

Safety Assessment / Quality Verification (40500, 90712, 92700)

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LicenseeEventReport(LER) Follow-up(90712,92700)

i Through direct observations, discussions with licensee personnel,.

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and review of records, the following event reports were reviewed to-determine that reportability requirements were fulfilled, that

immediate corrective action was accomplished, and that corrective action to prevent recurrence had been or-would be accomplished in i

accordance with Technical Specifications (TS):

'(Closed) 454/90003-LL:

Cel'1 voltage for cell #53 was below the-

TechnicaT 5pecification limit of 2.13 volts during quarterly surveillance, l'BHS 8.2.1.2.b-1.

The condition was not identified

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by personnel that performed the surveillance nor by the operations'.

staff that reviewed the results. The previous inspection report (454/90010: 455/90009) identified a non-cited violation that percained to this review of the surveillance lresults.

(Closed) 455/90005-LL: The OA Fuel Handling Building Charcoal Booster Fan automatically. started and transferred the associated

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dampers to the Engineered Safety Feature (ESF) positions. The auto start was due to a false high radiation signal caused by a procedure deficiency and personnel error.

The inspectors identified a concern with LER 454/90003. The

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licensee had attempted to restore cell #53 by the placement of a

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single cell charger on the affected cell.

The review of NWR B74716'-

.and the temporary _ alteration log determined that the licensee had not done a 50.59 review prior to the use of the single cell-charger on cell #53. This matter is further discussed in Section 6.c of this report.

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Assessment of Safety / Quality Verification The quality of LERs in the root cause analysis :and corrective _.

actions. continue to be_ good. This is the only area assessed by-the inspectors.

• No violations or deviations were identified.

5.

Maintenance / Surveillance (62703&'61726)

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MaintenanceActivities(62703)

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Station maintenance activities that affected the safety-related; j

and associated systems and components were observed or reviewed -

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guides and industry -codes or standards, and conformance with -

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Technical Specifications.

The following items were considered during.this-review: ;the-l limiting conditions for operation were met while components or

systems were removed from and restored to service; approvals were i

obtained prior to initiating the work; activities were accomplished j

using approved' procedures and were inspected as applicable; i

functional testing and/or calibrations were-performed _ prior-to returning components or systems to service; quality control.

l records were: maintained; activities were accomplished by qualified L}

. personnel;_. parts and materials used were properly certified;

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cl radiological controls were implemented; and fire. prevention controls-

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were implemented. Work requests were reviewed to determine the

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status of' outstanding, jobs and to assure that priority _ is assigned

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to safety-related equipment maintenance which may ' affect' system e performance.

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y Portions.of the following maintenance activities were observed

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and/or reviewed:

NWR B 69735 Change Out Of Filter 2FC02F In Spent Fuel Pit.

a NWR B'73892 Repair Unit 2 Containment Penetration Equipment Hatch f

2PC103.

d NWR B 75512 Jumper Cell 21 Per Temporary Alteration 90-1-013

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NWR B 75746 Replace Power Supply Resistor Board For the 1A Emergency Diesel Generator (EDG).

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NWR B 75763 Replace Governor Power Voltage Dropping Resistor For

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the 2A EDG.

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NWR B 75908

. Remove 1 Temporary Alteration And Replace Battery Cells 19 and 21 for Battery 111. -

j NWR B 76060 Repair Of 0A Fire Pump.

I NWR 8 99430 Replace Both 300 Ohm 70 Watt Resistors (65 PR)'In Panel 1 PLO8J For IB EDG.

NWR B 99481-Replace Both 300 Ohm 70 Watt Resistors (65 PR) In Panel 2 PLO8J For 28 EDG L

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NWR B 99482 Install Twc New Resistors-Into Spare: Assembly 65 PR.

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The -inspectors periodically monitored 'the licensee's. work in progress j

and verified performance was-in accordance with proper procedures and

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approved work packages, that ~10 CFR 50.69 and other applicable drawing-updates were made and/or planned, and that operator training was conducted in'a reasonable period of time.

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The inspectors had the following observations:

i (1).0nApril 11, 1990, the Unit IA Emergency Diesel Generator _(EDG).

j experienced a failure of a resistor in the governor speed control'

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circuit that caused the speed to oscillate between 280 rpm and.600 f

rpm when the EDG was started. The failed. resistor-was replaced and

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the 1A EDG was returnad to service. The licensee had failures of'

i two identical resistors on the speed control circuits for-the 28 EDG

at the licensee's Braidwood facility approximately one week earlier.

The inspectors notified Byron management of the Braidwood failures.

on April: 12, 1990.

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-;.l The licensee subsequently inspected the Byron 2A EDG ~ speed control.

circuit and discovered that one of the resistors was also in an inoperable condition. When one of the resistors was pulled, the

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licensee noted that part of the resistor moved in the mounting frame

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which was utilized as a heat sink. The licensee then declared the 2A EDG inoperable and entered the applicable 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Technical'

Specification (TS) LCO.

Instead of pulling eny additional. leads that might further damage the resistors the licensee initiated a-daily check of voltages across' the resistors in the 18 and 2B EDG until spare parts arrived on site. The licensee replaced the

resistors for the 18, 2A and 2B EDG on April 12 (2A EDG) and l

April 13 (28 and 1B EDG), 1990. The licensee is pursuing a failure

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cause for the resistors with corporate engineering and'the vendor.

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The speed control circuit involved was supplied by Woodward and had j

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a part number of 8271-2301.

The resistors involved were manufactured L

by Pacific and were identified with the following nomenclature:

l 100 CH, 300 OHMS, 3 percent and 70 watts. The inspectors considered the station management's action on the failure of the resistors at Byron as very good.- The station aggressively pursued the issue and obtained the necessary spare parts to replace the degraded -

resistors in the 18, 2A and 28 EDG. The repairs were accomplished in a timely manner.

However, the inspectors have a concern that the Byron Station-did not know about the failure of the identical

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resistors at the Braidwood facility on April 4,1990. The inspectors expressed this concern to the station manager. The licensee has initiated actions to ensure timely exchanges of data on the EDGs between Byron and Braidwood. The effectiveness of the actions appear to be good, since other EDG problems at Braidwood pertaining to the starting air system have been communicated to the Byron staff.

The Byron station is presently-performing surveillances on all the EDGs to ensure that the starting air lines were connected properly to the distributor. -

(2) Battery cells,19 and 21, were replaced in Battery 111 during this inspection period. The licensee established a definite schedule for the replacements when the cell voltage dropped to 2.15 Vdc The Technical Specification (TS) limit was 2.13 Vdc. Cell 21 was replaced with a new wet cell on April 27,(00S) for the replacement 1990 at 10:27 a.m.

The time that Battery 111 was out-of-service was I hour and 10 minutes. The TS action requirement for a battery 00S is 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

Cell 19 was replaced with a new wet cell on May 1, 1990 at 10:00 a.m.

The time that Battery 111 was 00S for this replacement was 55 minutes, well below the TS limit.

TN inspector observed the staff briefing before the work was initiated and the preparations for the replacement work that included the set up of special tools, lifting devices, etc. The licensee's efforts, briefing, training, preparation of tools, etc. resulted in the

- completion of a critical job without a challenge to the TS limits for operation.

(3) Battery 111 individual cell voltage measurements were obtained daily during this inspection period.

The inspector witnessed the voltage measurement activities on several occasions and reviewed the final data.

The licensee used seven different " Fluke Digital Multimeters" (FDM) to obtain the cell voltages. The inspectors verified that all seven were within the calibration period and reviewed the calibration history of each of the seven, since 1934. One of the FDMs, #QA 127906BY, the one used most frequently for the Battery -

111 cell voltage measurements, was found during the annual recalibration, in an out-of-tolerance (00T) condition (AC mode only)

five times out of the last seven. Another instrument, FDM #1279298Y, was found to be 00T the last three years. The inspectors reviewed the licensee's 00T reports issued each time the FDMs were found 00T and verified that appropriate reviews of past usage were accomplished.

However, there were no changes initiated in the frequency schedule for calibrations of the FDMs, and none of the FDMs were scheduled'

to be retired or replaced.

The repetitive calibration deficiencies indicated a less than optimum performance in the control of the calibration of FDMs. This concern was discussed with the licensee and the licensee's response to this matter will be monitored by the inspectors during future inspections.

b.

Surveillance Activities (61726)

The inspectors observed or reviewed surveillance tests required by Technical Specifications during the inspection period and verified that' tests were performed in accordance with adequate procedures, l

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s test instrumentation was calibrated, limiting conditions for operation were met, removal and restoration of the affected components were accomplished, results conformed with Technical Specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and any

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b deficiencies identified during the tests were properly reviewed and resolved by appropriate management personnel.

The inspectors also witnessed or reviewed portions of the following activities:

1 BOS 1.1.1.1.e-1 Unit 1 Shutdown Normalization Factors.

1 BOS 3.4.2.a-1 Turbine Throttle,' Governor, Reheat, and Intercept Valve Monthly Surveillance.

1 BOS DC-M1 Unit 1 125V DC ESF Battery 111 Monthly Surveillance.

1 BVS 1.1.1.2-1 Monthly Core Reactivity Balance.

1 BVS 2.2.2-1 Heat Flux Hot Channel Factor Checkout Using Peaking Factors.

1 BVS 2.3.2-1 Monthly Nuclear Enthalpy Rise Hot Channel Factor and RCS Total Flow Rate Check.

1 BVS 3.1.1-4-Incore-Excore Axial Flux Single Point Comparison Monthly Surveillance.

1 BVS XPT-8 Unit 1 Thermocouple Normalization Factors.

2 BHS AF-1 Auxiliary Feedwater Diesel Unit 2 Nickel Cedmium Battery Quarterly Surveillance, c.

Assessment of Maintenance / Surveillance The-licensee's overall performance in this area continues to be good. Management was aggressive in the implementation of corrective action for the degraded resistors in the EDG speed control circuit.

However, communications between Byron and Braidwood were not effective, as the Byron station was unaware of the resistor problem-that was first identified at Braidwood. Communication appeared to improve late in the inspection period as evidenced by another potential EDG problem at Braidwood that was effectively communicated to the Byron staff. The licensee was very effective in the work planning for the replacement of the two battery cells in Battery 111.

The inspectors did identify a concern in the management of the calibration of fluke digital multimeter as discussed earlier.

A similar observation with a pressure transmitter calibration for a power operated relief valve (PORV) was noted during a recent maintenance team inspection.

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NoviolAtionslordeviationswereidentified.

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Engineering &TechnicalSupport-(37828).

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a.

The-inspectors identified an Unresolved Item (454/89017-01;

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455/89019-01)fthat pertained to the setpoint of an AFW suction j

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' pressure' transmitter. The licensee has issued LER 454/89008;

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L 455/89008 to address the setpoint errors'. The inspectors reviewed the licensee's corrective actions and the circumstances that

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resulted in the erroneous low suction pressure trip setpoint for

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.the AFW pumps. Even though the setpoint for the trip was in error,;

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, the net positive suction pressure requirements for the AFW pumps

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were satisfied. The inspectors also reviewed the licensee's-Setpoint Control Program that was initiated in early 1988. :The program should ensure that future modifications to plant systems-

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will address the need for any changes to instrument setpoints. -

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The inspectors have no.further concerns in this area.

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b.

On-April 24, 1990, a working group meeting with licensee i!

representatives, NRR, and NRC Region 111 personnel was convened in the Region III office to discuss the; technical aspects of the on-site. reviews (0SRs) for a jumpered cell on Unit 1 Battery 111.

P This matter was identified and discussed in detail in Inspection.

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Report 454/90010, in Section 5, and was identified as an Unresolved Item (454/90010-02).

Based on the information furnished by.the j

licensee, the following conclusions were reached by the inspectors:

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(1) -The Byron Station 125Vdc Batteries 111, 112 and 212.were not

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designed.for the proper size in a crosstie configuration.- (i.e.

Battery 111(112) crosstied to 211-(212). The actual margins

. based on a electrolyte temperature of 60 degrees F.,- a 1.0

' design margin, a 1.25 aging factor and the actual calculated

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Class IE DC load of the plant were less than 1.0 with the actual calculated as:.986' for Battery 111,.945 for Battery 112 and

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.978 'for Battery 212.

The licensee failed to identify. the incorrect temperature correction factor for the electrolyte

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during OSRs89-127 and 90-074, i

L(2) The Sargent & Lundy (S&L) calculation 19-D-15 utilized in OSR'89-127,' dated May 5, 1989, was not reviewed and approved-L by S&L until June 27, 1989. During the' April 24, 1990 meeting,

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s the licensee stated that

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• Discussions were held between:S&L, the licensee's engineering organization and the Byron Station regarding Battery 111 j

operation with 57 cells versus 58 cells.

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• Calculation 19-D-15 was also reviewed on May 4, 1989 but not i

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' discharge character curves for the purpose of documentation.

dated by S&L pending resolution of a conflict in battery L

• OSR 89-127 performed on May 5,1989 was based on an S&L letter that referenced calculation 19-D-15 and prior discussions held between on-site review members, engineering

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and S&L.

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F Even though the above information describingsthe interface between the Byron Station on-site review members, engineering and S&L was considered a.necessary function in the course of assessing the ' capability of Battery 111 to _ operate with 57 cells, the' requirement was still present to have a reviewed-and approved calculation to justify operability of Battery 111 with 57 cells versus 58 cells, prior to operating =in that configuration.

Engineering-judgement would not have sufficed since there was a definitive method to' ascertain the design.

capabilities of a 57 cell battery.

(3) 0SRs89-127, 90-074 and 90-076' performed-May 5,'.1989, March 13,

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l 1990 and March 16, 1990, respectively, did 'not adequately.

j address-the present condition of Battery 111 prior to jumpering a

cell #53.

The licensee stated that the OSR members did' discuss

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the Badery 111 condition but did not document the results.-

ASME NQA-1, " Quality Assurance Program Requirements-for Nuclear j

Facilities, Supplement 35-1", Section 4, states that the design j

verification process which utilizes design reviews include l

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consideration of operating. experience. The inspectors have r

concluded that the condition of Battery 111 was not adequately

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discussed by the OSR members since no actions were implemented

by the station 'to monitor other Battery 111 cell voltages..

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'After discussions with resident inspectors, the licensee D

initiated actions.to monitor other Battery 111 cell voltages

. based on the NRC's concern-with two cells (20 and 21),

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' identified in a review of the past eight Battery 111 quarterly surveillances. Subsequent to the replacement of cell #53, the l.

licensee also jumpered and replaced cells 19 (May 1, 1990) and j

21 (April-27,-1990).

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. Examples (1) and (?) are considered a violation of 10 CFR '50, Appendix j

B, Criterion III (454/9001?-01).

Since previous Inspection Reports H

50-454/89017; 50-455/89019~ identified an inadequate S&L calculation that i

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was utilized to ascertain the. minimum capacity of a Auxiliary Feedwater j

pump nickel-cadium battery, the response to the Violation should include

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the actions taken or to be taken to prevent future inadequate battery.

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calculations.

The failure to adequately consider the current condition

of. Battery 111 as described in paragraph (3) above, was considered a j

significant weakness in the onsite review process. Therefore, the

, licensee is also requested to address this weakness in the response to the violatic'n.

i The inspectors identified other concerns with the 125 Vdc station

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batteries that were not resolved either at the April 24, 1990 working

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meeting with the licensee or during this inspection period.

The fI

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f concerns were:

L (1) During the quarterly surveillances for the batteries the licensee corrects the specific gravity of the electrolyte to 60 degrees F. instead of 77 degrees F.

The discharge curves

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E for the batteries used in the design process for sizing the batteries was based on a pilot cell with a specific gravity

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'of'1.215 at 77 degrees F.

The licensee'at present does not

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' correct to 77 degrees F when verifying compliance with the-

Technical Specification. specific gravity requirements. - Also, it appears the. licensee utilizes a hydrometer that has been i

calibrated in a different manner than the hydrometer used by.

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the battery manufacturer during the data collection for the-l

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discharge curves from the pilot cell tests.

Resolution of this' issue has not yet been finalized by the licensee.

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(2). Equalizing charges have been performed on.the 125 Vdc batteries

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at a frequency that could have affected the life of the a

batteries.

The licensee is presently investigating the cause l

of the higher than normal frequency of equalizing charges:and-the overall effect on the batteries.

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r The two concerns identified above are considered open items pending further review by the licensee and the NRC (454/900012-02; 455/900011-01).

Considering the importance of the two issues,

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the licensee is requested to respond in writing with the written response accompanying the response to the Notice of Violation.

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LER 454/90003 identified that the licensee had used a single cell

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charger on cell #53 of Battery 111 in an attempt to' restore the

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'ctll'to above the Technical Specification limit of 2.13 volts. The c

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inspectors reviewed -the NWR, B74716, and the Temporary Alteration

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109. The inspectors ascertained that'the licensee had not performed

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a.10 CFR 50.59 review for the temporary alteration to Battery 111 i

when a Non-Class IE single charger was placed on cell #53.

The

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inspectors had ' identified another instance in a previous inspection.

j report (454/89019;.455/89021-Section 2.b) where plastic was placed.

over 'a emergency diesel generator room air inlet damper without a

Temporary Alteration. The plastic changed the failure mode from

" fail open" to " fail close".

Procedure BAP 330-2,-Revision 4,

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" Temporary Alterations", defines a temporary alteration as a

. temporary power feed or other electrical connection / device which bypasses or adds a' component within an electrical circuit, thus modifying the circuit design or configuration.

The inspectors considered the addition of a single charger to cell #53, when

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Battery 111 was still considered operable, as a Temporary Alteration

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that required compliance with procedure BAP 330-2. The requirements

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cf BAP 330-2 include a 10 CFR 50.59 review. The failure to follow procedure BAP 330-2 for the use of a single -cell charger on Battery -

111 is considered another example of a violation of 10 CFR 50,

Appendix B, Criteria III (454/90012-01).

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The technical support for the resolution of the failure of the =

i resistors in the EDG speed control circuit described in Section 5.a

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of this report was considered very good.

The system engineer was t

aggressive in obtaining spare resistors and in the development of

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maintenance instructions for the installation of the spare

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resistors.

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AssessmentofEngineering/TechnicalSuppoy

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The licensee's performance in the OSR process for assessing.

operability of Battery 111 was not effective. The licensee's past performance 'in OSRs has been mixed. The performance of-the technical staff in'the resolutions of the failed / degraded

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. resistors _in the EDG speed' control circuit was considered very i

good.

One violation and no deviations were identified..

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7.

Emergency Preparedness (92701)

j As_previously stated in Section 3.c (1), an Unusual Event was declared

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on April 11,1990.

Unit-1 was in Mode 1 with the IB Emergency Diesel

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Generator (EDG) out of m r. ice for preventive maintenance.

In accordance j

with the Unit's Technical Specifications,'a surveillance test was

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]a initiated on the 1A EDG to verify operability..At about 7:17 p.m., the 1ALEDG was shutdown and was declared inoperable due to large speed

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oscillations.

Technical Specification 3.8.1.1 required that either of

the Unit's diesels must be restored to operability in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or the unit-must _be in Hot Standby within the next six hours. At 9:17 p.m., Unit 1

power reduction commenced since neitner EDG could be returned to service within'the required time.

i The Shift Engineer (SE) declared an Unusual Event at 9:17 p.m. per

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Emergency Action Levels (EALs) 3a and 3e, which the SE incorrectly

'l concluded were equivalent in applicability for the existing situation.

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EAL 3a specified that an-Unusual Event must be declared when " equipment o

described in the Technical Specifications is degraded such that a

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Limiting condition for Operation requires a shutdown and power decrease or a. reactor shutdown has comenced." EAL 3e states that an Unusual

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Event must be declared for " loss of all diesel generators associated j

with the unit in Modes 1-4,'".

The SE considered EAL 3e equivalent to EAL-3a since Technical Specifications address'the operability of the L

EDGs and since an orderly Unit 1 power reduction was initiated to L

satisfy the Technical Specification.

Initial notifications of the-State of Illinois and NRC officials were completed in an accurately detailed and timely mar.ner following the Unusual Event declaration, j

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Hourly update messages to the-State were transmitted to sa'isfy an i

emergency plan commitment.

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The inspector discussed the circumstances of the emergency plan

activation, and the licensee's evaluation and corrective actions with the Assistant Superintendent for Operations, the Training Supervisor, and the Generating Stations Emergency Plan (GSEP) Coordinator.

The j

inspector reviewed the following records, many of which were already compiled and evaluated by the GSEP Coordinator:

Control Room Logs of the SE, Shift Foreman, and Station Control Room Engineer (SCRE); initial,

periodic update, and event termination messages to State officials; the proceduralized Event Notification Worksheet used to document the initial i

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notification message to the NRC Operations Officer; and a lessons

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learned training package for licensed personnel.

The GSEP Coordinator's evaluation, which involved some assistance from a Senior Reactor Operator, was documented on an Event Review Checklist.

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The SE's erroneous conclusion that EALs 3a and 3e were equivalent and became applicable at 9:17 p.m. resulted in an untimely Unusual Event declaration. The declaration should have been made per EAL 3e at the time that the 1A-EDG was declared inoperable.

Based on records review and discussions wit.h cognizant licensee personnel, the criteria of 10 CFR Part 2, Appendix C, Section V.G.1 were satisfied, and therefore the untimely Unusual Event declaration is identified as a non-cited violation (NCY 50-454/90012-03).

The licensee has developed required training Package No. 90-17 which accurately summarized the circumstances of the April 11 declaration and the error in interpreting EAL 3e.

The package also identified several other Unusual Event EALs which relate to equipment described in the Technical Specifications, but which would become applicable prior to commencement of a unit shutdown per Technical Specification requirements.

Four of six Control Room crews have received training on Package No.

90-17, with the remaining two crews scheduled for April 27, 1990.

The package of information will also be made available to the licensee's other nuclear stations through management teleconferences and the next quarterly GSEP Coordinators' counterpart meeting. As a longer-term corrective action, the licensee intends to revise appropriate Limiting Condition for Operation procedures to identify relevant EALs that would become applicable prior to commencement of a unit shutdown per a Technical Specification requirement. These corrective actions were thorough and timely.

One Non-Cited Violation and no deviations were identified.

8.

Open Items Open items are matters which have been discussed with the licensee, which will be reviewed by the inspector and which involve some actinn on the part of the NRC or licensee or both. An Open Item disclosed during the inspection is discussed in Paragraph 6.b..

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Meetings and Other Activities ExitInterview(30703)

The inspectors met with the licensee representatives denoted in paragraph I during the inspection period innd at the conclusion of the inspection on May 12, 1990. The inspectors summarized the scope and results of the inspection and discussed the likely content of this inspection report." The licensee acknowledged the information and did not indicate that any of the information disclosed during the, inspection could be considered proprietary in nature, i

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