IR 05000454/1993008
| ML20045C049 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 06/16/1993 |
| From: | Farber M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20045C046 | List: |
| References | |
| 50-454-93-08, 50-454-93-8, 50-455-93-08, 50-455-93-8, NUDOCS 9306220023 | |
| Download: ML20045C049 (12) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION III
r Report Nos. 50-454/93008(DRP); 50-455/93008(DRP)
Docket Nos. 50-454; 50-455 License Nos. NPF-37;NPF-66
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Licensee: Commonwealth Edison Company Opus West III 1400 Opus Place Downers Grove, IL 60515 Facility Name:
Byron Station, Units 1 and 2 Inspection At:
Byron Site, Byron, Illinois
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Inspection Conducted: May 1, 1993 through June 1, 1993 Inspectors:
H. Peterson C. H. Brown D. E. Jones Approved By:
4 4 3 MartinfFarber, Chief
' Date Reactor Projects Section lA Inspectinn Summary Insoection from May 1. 1993 throuah June 1. 1993 (Report Nos. 50-454/93008(DRP): 50-455/93008(DRP)).
Areas inspected:
Routine, unannounced safety inspection by the resident inspectors of operational safety verification, current material condition,
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housekeeping and plant cleanliness, radiological controls, security, safety assessment / quality verification, maintenance activities, surveillance activities, engineering and technical support, emergency preparedness, report review, and a regional request.
Result s:
In the twelve areas inspected, one non-cited violation was identified for tagging and isolating a valve in the wrong system train during
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a scheduled surveillance / maintenance activity (paragraph 2.a).
The following is a summary of the licensee's performance during this inspection period:
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t plant Operations
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The licensee's performance in this area continues to be very> good, including the involvement by the operating engineers contributing to good communications
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between station departments. However, three personnel errors occurred during
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this inspection period.
One of the errors resulted in a non-cited violation (paragraph 2.a).
The errors were adequately identified and corrected by the
licensee before they became safety issues; however, the inspectors expressed concerns over attention to detail. Station management acknowledged the
inspectors concerns, and expressed disappointment over these personnel errors.
The licensee held tailgate meetings and pep talks during operating shift
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briefings to relay management concerns. The Unit 2 turbine / reactor trip was handled without incident. The operators took timely and appropriate actions to mitigate the reactor trip.
Safety Assessment /0uality Verification
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The inspectors reviewed the licensee's Problem Identification Forms (pIF)
generated during the inspection period.
PIFs were reviewed to ensure that they were generated appropriately and dispositioned in a manner consistent with the applicable procedures.
Based on the review of the PIFs, the licensee's performance was considered good. However, the inspectors noted
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that errors by plant personnel, which may have potential safety significance, should be promptly identified to the resident staff, rather than relying on the PIF process. This comment was prompted by the valve mispositioning event on the Unit 2 containment spray system (paragraph 2.a).
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Maintenance and Surveillance
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The performance in this area was good, with the exception of the personnel
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errors associated with the performance of the Unit 2 containment spray
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preventive maintenance, 2BVS 6.2.1.B-2 (paragraph 2.a).
The maintenance
request backlog remains constant. The efforts of the maintenance department have adequately maintained the " dark board" concept on the control room annunciator panels.
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Enaineerina and Technical Support i
The engineering group has initiated talks with the Braidwood system engineers
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on the Boron Thermal Regeneration system (BTRS) in the attempt to reactivate this system. There was good interchange of information and ideas.
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The inspectors reviewed two On-Site Reviews -(OSR), one pertaining to a problem
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with the turbine / reactor trip, and the other associated with NRC Bulletin
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93-02.
Both OSRs were thorough and adequately addressed-the technical issues.
Root cause analysis was good,- as demonstrated by the final resolution of
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turbine / reactor trip power supply card problem. There continues to be good
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interface and support within the engineering organization on operability concerns. The licensee continues to show improvement in this area, t
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DEiAILS 1.
Persons Contacted e
Commonwealth Edison Company (Ceco)
- K. Schwartz, Station Manager
- M. Burgess, Technical Superintendent
- T. Tulon, 0perations Manager
- M. Snow, Support Services Director
- T. Gierich, Assistant Superintendent, Work Planning
- D. Brindle, Regulatory Assurance Supervisor P. Johnson, Maintenance Manager R. Colglazier, Compliance Engineer P. Enge, NRC Coordinator R. Wegner, Shift Operations Supervisor W. Dijstelbergen, Site Engineering Supervisor
- W. Grundman, On-Site Quality Verification Superintendent A. Javorik, Technical Staff Supervisor W. Koulou, Operating Engineer, Unit 2 E. Zittle, Security Administrator
- D. St. Clair, Security Manager
- S. Barrett, RP Supervisor
- Denotes those attending the exit interview conducted on June 1, 1993.
The inspectors also had discussions with other licensee employees, including members of the technical and engineering staffs, reactor and auxiliary operators, shift engiraers and foremen, and electrical, mechanical and instrument maintenance personnel, and contract security personnel.
2.
Plant Operations Unit I has operated at power levels up to 100% in the load following mode since April 19, 1993.
Unit 2 has operated at power levels up to 100% in the load following mode since the reactor trip on May 11, 1993. The trip was due to a turbine overspeed circuitry failure.
Prior to the reactor trip, the unit had operated for 290 days, a.
Operational Safety Verification '(71707)
The inspectors verified that the facility was being operated in i
conformance with the licenses and regulatory requirements, and that the licensee's management control system was effectively carrying out its responsibilities for safe operation.
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On a sampling basis, the inspectors verified proper control room staffing and coordination of plant activities; verified operator adherence with procedures and technical specifications; monitored control room indications for abnormalities; verified that electrical power was available; and observed the frequency of plant and control room visits by station management,
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During this inspection period, several personnel errors occurred.
While performing the Unit 1 Train B Solid State Protection System
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Bi-monthly surveillance, IBOS 3.1.1-21, the technician inadvertently depressed relay K601.
In accordance with the procedure, relay K602 was the correct relay which should have been
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depressed. The error was immediately recognized and relay K601 was reset. No safety system actuation was identified.
After investigating the error, it was identified that relay K601 was a.
spare relay and it would not have actuated anything. On the following day, while performing Unit 2 Engineered Safety Features Actuation System Instrumentation Slave Relay Surveillance, 2 BOS 3.2.1-802, the operator mistakenly closed valve IAF004A instead of the correct valve 2AF004A (AF Pump 2A Discharge Test Valve). The
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operator discovered that the wrong valve was closed and immediately reopened the valve.
The operator took the appropriate corrective actions, including entering and exiting the limiting condition for operation action requirement (LC0AR) for the auxiliary feedwater system.
In both instances, personnel failed to pay sufficient attention to procedural steps and equipment.
On another occasion, while preventive maintenance on the 2B containment spray system, 2BVS 6.2.1.B-2, was in progress, the
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Unit 2 Nuclear Station Operator identified that a wrong valve had been tagged closed.
Upon further investigation, the licensee identified that the A train containment spray additive system eductor isolation valve, 2CS046A, was incorrectly added to the out-of-service tagout.
The intention was to tag closed the B train isolation valve, 2CS046B. The erroneous tagout was written, verified, and issued the previous day. Both containment-spray additive systems were out of service for approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The technical specification LOCAR for the containment additive system had been entered for the planned containment spray preventive maintenance, and the wrong train isolation for the spray additive _ system did not detrimentally add to the LOCAR for either the containment spray or spray additive systems.
The Unit 2 train A containment spray system was determined to be
operational, and all appropriate LOCARs were initiated.
All three events are examples of personnel errors.
The first two
were simple mistakes; appropriate and timely corrective actions were taken.
However, the personnel errors associated with writing, verifying, and issuing the out-of-service tagout were a violation of station administrative procedures. After further review, the inspectors determined that the criteria specified in
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Section V11.8 of the " General Statement of Policy and Procedure
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for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1993),
were satisfied; therefore, a notice of violation was not issued.
The inspectors expressed concern to station management over the potential negative trend associated with the aspect of attention to detail in performing plant duties.
b.
0_n_ Site Event Follow-up (93702)
At 10:38 p.m., on May 11, 1993, Byron Unit 2 experienced a turbine / reactor trip from approximately 98% power. A Turbine Emergency Trip Oil Header Pressure Low alarm was received, which was immediately followed by a reactor trip initiated by turbine trip above P-8.
The licensee initiated a root cause investigation.
A review of the Digital Electro-Hydraulic Control computer data points revealed that the Electro-Hydraulic depressurization was very rapid.
This implied that the only possible cause of such rapid depressurization was the actuation of the 20/ET solenoid or the Diaphragm Interface Valve (DIV). The licensee initially investigated the DIV. The DIV will only open on a s 7ressurization of the Autostop Oil (AS0) header. Testing was conducted on the DIV and ASO systems, and anticipating that the
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cause of the trip would be identified, the licensee intended to restart the reactor on the afternoon of May 12, 1993. The inspector expressed concern over starting up the reactor without having a definite conclusion to the turbine trip. The licensee acknowledged the inspector's concerns, and after approximately a day and a half of extensive troubleshooting, the licensee had eliminated the DIV as the source of the problem and delayed 'the
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reactor startup.
Extensive testing on the 20/ET was conducted, but the licensee was unable to conclusively determine any root cause to the problem.
At 12:26 p.m., on May 13, 1993, the reactor was taken critical and power raised to approximately 5% to support rolling the turbine to
assist in the trouble shooting and root cause determination. The reactor was maintained well below P-8 at approximately 10%
throughout the evening with strip chart recorders installed to monitor contacts associated with turbine trip signals.
On May 14, 1993, while conducting further investigation of the turbine trip, the licensee again experienced the rapid EH depressurization and subsequent turbine trip. During this turbine
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trip, the licensee physically viewed the 20/ET solenoid actuate.
It was later identified to be a faulty power supply card to the turbine overspeed trip circuit, OST-2. This was one of several inputs to the 20/ET solenoid.
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The licensee identified that the power supply card was causing positive voltage spikes actuating the trip relay. The OST-2 power supply card and corresponding relay circuit cards were replaced.
The 20/ET trip circuit was satisfactorily calibrated and tested.
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The licensee concluded the root cause investigation and continued the reactor startup. The turbine was synchronized to the grid at 1:31 a.m. on May 17, 1993.
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c.
Current Material Condition (71707)
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The inspectors performed general plant, as well as, selected system and component walkdowns to assess the general and specific material condition of the plant, to verify that Nuclear Work Requests (NWRs) had been initiated for Mentified equipment problems, and to evaluate housekeeping.
'elkdowns included an
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assessment of the buildings, components, and systems for proper identification and tagging, accessibility, fire and security door
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integrity, 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 through ceiling, walls or floors; loose insulation; corrosion; excessive noise; unusual temperatures; and abnormal ventilation and lighting.
General plant condition was well maintained; however, numerous steam leaks in the secondary side of both units were noted by %e inspectors and regional management. This condition was identitied as more than usual and the inspector relayed concerns to licensee management. The licensee was aware of the increased steam luks and has initiated a steam leak task force to aggressively identify, trend, and repair the leaks. The licensee has effectively repaired major steam leaks, including the IC feedwater pump and the 268 LP feedwater heater drain line, utilizing
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Furmanite contractors.
d.
Housekeepina and Plant Cleanliness (71707)
The inspectors monitored the status of housekeeping and plant cleanliness for fire protection and protection of safety-related equipment from intrusion of foreign matter.
Housekeeping and plant cleanliness continues to be good; however, there were some exceptions to the standard in a few areas. The licensee was quick
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to respond to the cleanliness issue. The inspectors and regional management expressed concern regarding any negative trend.a housekeeping; although understanding, and taking into account, that the facility had recently finished a refueling outage.
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Radioloaical Controls (71707)
The inspectors verified that personnel were following health physics procedures for dosimetry, protective clothing, frisking, posting, etc., and randomly examined radiation protection instrumentation for use, operability, and calibration.
Radiological control practices continues to be excellent; however,
one incident did occur with a painter painting in an area with his legs inside a contaminated area without anti-contamination
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clothing.
This issue was relayed to Region III, Division of Radiation Safety and Safeguards for follow up.
On May 17, 1993, the Senior Resident Inspector attended the 2nd quarter 1993 Byron Station ALARA Committee Meeting. The meeting t
reported the status of the 1993 ALARA goals and the BIR05/BlF14 ALARA performance. The actual person-rem goal for BIR05 was 233 i
rem; however, the total rem received was 217. This was a good indication of the licensee's ALARA control effectiveness.
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Security Each week during routine activities or tours, the inspectors monitored the licensee's security program to ensure that observed actions were being implemented according to the approved security pl an.
The inspectors noted that persons within the protected area displayed proper photo-identification badges and those individuals requiring escorts were properly escorted. The inspectors also verified that checked vital areas were locked and alarmed.
Additionally, the inspectors also observed that personnel and packages entering the protected area were searched by appropriate equipment or by hand.
During this inspection period, the inspector observed several security drills concerning unauthorized personnel intrusion. The drills were conducted in a very professional manner, and the
performance by the members of the security department was
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excellent.
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One non-cited violation was identified.
3.
Reaional Reouest (92701): NRC BULLETIN 93-02. Debris Pluaaina of
Emeraency Core Coolina Suction Strainers i
On May 11, 1993, the Office of Nuclear Reactor Regulation (NRR) issued NRC Bulletin 93-02. This bulletin identified a potential loss of net positive suction head (NPSH) for the Emergency Core Cooling System (ECCS) during the recirculation phase of a loss-of-coolant accident
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(LOCA) due to a previously unrecognized contributor: the existence of
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fibrous air filters or other temporary sources of fibrous material not designed to withstand a LOCA, which are installed or stored in the
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The licensee conducted an on-site review to document the compliance with
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NRC Bulletin 93-02 prior.to the startup of Unit 2.
Unit 2 was shut down due to the turbine / reactor trip on May 11, 1993 (paragraph 2.b).
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licensee stated that all insulating material used in Unit 2 containment was of the metallic reflective type per Sargent & Lundy Design
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Specification F/L 2816, " Installation of Metallic Insulation," which was
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in accordance with NUREG 0897 Rev. 1, " Containment Emergency Sump Performance." Metallic insulation produces no fibrous debris of concern
to the ECCS suction strainers. Additionally, the licensee conducts
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periodic surveillances associated with cleanliness in the primary containment.
2BVS 5.2.d.2-1, Unit 2 Visual Inspection of the Containment Recirculation Sumps, and 2B05 5.2.c-1, Unit 2 Containment Loose Debris Inspection, are designed to verify cleanliness of the ECCS suction strainers and the remaining containment area.
In response to the NRC Bulletin, the licensee satisfactorily conducted 2BVS 5.2.d.2-1 on May 12, 1993.
The licensee identified that the only use of fibrous filter material r
inside the Unit 2 containment was the containment charcoal filters which are designed to be Seismic Category I and are not required during a LOCA. These filters are only used for habitability of personnel when necessary.
The prefilters in the containment charcoal filters contain fibrous filter material; however, it has a charcoal and high efficiency particulate air filter downstream to remove any fibrous material.during operation. Based on the above information, the licensee concluded that no compensatory or prompt removal actions were required prior to the restart of Unit 2.
The licensee was also in the process of drafting the required response to NRC Bulletin 93-02.
No violations or deviations were identified.
4.
Safety Assessment /0uality Verification (40500. 90712. 92700)
The inspectors reviewed the licensee's Problem Identification Forms (PIF) generated during the inspection period. This was done in an effort to monitor the conditions related to plant or personnel performance, potential trends, etc.
PIFs were also reviewed to ensure that they were generated appropriately and dispositioned in a manner consistent with the applicable procedures.
During this inspection period, the inspectors expressed some concerns to the station management regarding personnel errors, material condition, and housekeeping. The inspectors emphasized that errors by plant personnel, which may _have potential safety significance, should be promptly reported to the residents, rather than relying on the PIFs as a communication avenue. The inspectors normally receive the PIFs a day or so after the event has transpired. Also, the PIFs are usually written after the problem has occurred, been subsequently corrected, and sometimes closed.
This comment was prompted by the valve mispositioning event on the Unit 2 containment spray system (see paragraph 2.a).
The inspectors identified this problem during a plant tour, while observing the licensee's corrective action in realigning the affected system.
No violations or deviations were 16tified.
5.
Maintenance / Surveillance (62703 & 61726)
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Maintenance Activities (62703)
Routinely, station maintenance activities were observed and/or reviewed to ascertain that they were conducted in accordance with
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l approved procedures, regulatory guides and industry codes or standards, and in conformance with technical specifications.
The following items were also considered during this review:
approvals were obtained prior to initiating the work; functional testing and/or calibrations vere performed prior to returning components or systems to service; quality control records were maintained; and activities were accomplished by qualified personnel.
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Portions of the following maintenance activities were observed
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and/or reviewed:
- NWR 01215 Essential Service Water Make-up Pump OB
- NWR 880765 OB VA Chiller
- NWR 894917 1C Steam Generator PORV No violations or deviations were identified.
b.
Surveillance Activities (61726)
During the inspection period, the inspectors observed technical specification required surveillance testing and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that results conformed with technical specifications and procedure requirements and were reviewed, and that any deficiencies identified during the testing
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were properly resolved.
During the preventive maintenance on OB essential service water makeup pump, the inspectors noted an isolated case where the
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referenced maintenance procedure (BMP 3122-001) in OBVS 7.5.h-1, revision 2, was not current; however, the correct maintenance
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procedure (BMP 3222.2) was being used. No safety concern was identified. The inspectors will continue to monitor the administrative tracking of changes to existing procedures.
Portions of the following surveillance activities were observed
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and/or reviewed:
- 2BVS 0AD -2 2B Containment Spray Pump Relay Calibration
- 180S 8.1.1.2a-1 1A Diesel Generator Monthly Surveillance
- 2BVS 3.3.2-1 Unit 2 Moveable Incore Detectors' Operability Check
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- IBVS 7.1.2.1.A-2 IB Auxiliary Feedwater Pump Monthly Surveillance
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- OBOS 7.5.h-1 Essential Service Water Makeup Pump 18 Month Surveillance.
No violations or deviations were identified.
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Enaineerina & Technical Support (37700)
During this inspection period, the inspectors had several opportunities to observe the involvement in and contribution to major issues by the
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licensee's Engineering and Technical Support organization. On May-18, 1993, the inspector observed the initial meeting between Byron and Braidwood Baron Thermal Regeneration System (BTRS) system engineers.
This meeting was conducted to determine the scope of reestablishing the BTRS at the Byron station.
Braidwood was successful in reactivating the system. There was good interchange of information, new ideas, and insights during the meeting.
Engineering and technical support was good during the root cause analysis of the May 11 turbine / reactor trip.
Initially, the inspector was concerned with the pace and scope of the evaluation, and the
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licensee's apparent determination to restart the reactor without finding the actual cause of the turbine trip. However, after the initial assumption of the turbine trip, DIV was determined not to be the cause, the licensee elevated the investigation (see paragraph 2.b).
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Subsequently, the licensee's final analysis and determination of the
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root cause was good. There continues to be good interface and support within the engineering organization on operability concerns. The licensee continues to improve in all areas associated with. engineering and technical support.
No violations or deviations were identified.
7.
Emeraency Preparedness (82701)
A Generating Station Emergency Preparedness drill was conducted on May 12, 1993. The scenario involved several extensive plant malfunctions, including an anticipated transient without a scram, a fuel failure, loss of several ECCS pumps, steam generator tube rupture, and radioactive release. The Senior Resident Inspector participated in evaluating the control room simulator response. The control room simulator was well organized and adequately staffed throughout the exercise. The command and control by the shift engineer was good, and the operators were very familiar with the plant and the emergency operating procedures. The crew performed the mitigating actions to the plant casualties in an excellent manner.
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The inspector also observed the licensee's pre-exercise drill, and observed the actual station assembly and accountability. Accountability was conducted in a professional manner, and all plant personnel were accounted for within 26 minutes.
i No violations or deviations were identified.
8.
Report Review During this inspection period, the inspectors reviewed the licensee's Monthly Performance Reports for March and April, 1993. The inspectors confirmed that the information provided met the requirements of Technical Specification 6.9.1.8 and Regulatory Guide 1.16.
The inspectors also reviewed the licensee's Monthly Plant Status Report for April 1993.
No violations or deviations were identified.
9.
Non-cited Violation Non-cited violations are matters which have been discussed with the licensee, which are technically a violation of NRC requirements; however, it meets the criteria of 10 CFR Part 2, Appendix C, Section VII.B, " Mitigation of Enforcement Sanctions." The NRC may refrain from issuing a notice of violation for a violation if it meets the following
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criteria:
a.
It was identified by the licensee.
b.
It is normally classified at a severity Level IV or V.
c.
It was or will be corrected, including measures to prevent
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recurrence, within a reasonable time.
d.
It was not a willful violation.
e.
It was not a violation that could reasonably be expected to
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have been prevented by the licensee's corrective action for a previous violation.
A non-cited violation was disclosed during the inspection in Paragraph
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10.
Meetinos and Other Activities a.
Manaaement Meetinas (30702)
On May 18, 1993, Mr. H. J. Miller, Deputy Regional Administrator, and others -from the Reaion III office, toured the plant, met with
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licensee and the n:edia, and presented the Byron Systematic Assessment of Licensee Performance evaluation.
Region III management also discussed plant performance and material condition with licensee management.
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Exit Interview (30703)
The inspectors met with the licensee representatives denoted in paragraph I during the inspection period and at the conclusion of the inspection on June 1, 1993. 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
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nature.
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