IR 05000454/1993017

Insp Repts 50-454/93-17 & 50-455/93-17 on 931202-940110.No Violations Noted.Major Areas Inspected:Previous Insp Findings,Operational Safety,Matl Condition,Housekeeping & Plant Cleanliness,Radiological Controls & Security

ML20059K380
Person / Time
Site:	Byron
Issue date:	01/24/1994
From:	Jorgensen B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20059K379	List: IR 05000454/1993017 ML20059K377
References
50-454-93-17, 50-455-93-17, NUDOCS 9402020072
Download: ML20059K380 (11)

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V. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report Nos. 50-454/93017(DRP); 50-4S5/93017(DRP)

Docket Nos. 50-454; 50-455 License Nos. NPF-37; NPF-66 P

Licensee: Commonwealth Edison Company Opus West 111 1400 Opus Place Downers Grove, IL 60515 Facility Name: Byron Station, Units 1 and 2 Inspection At: Byron Site, Byron, Illinois inspection Conducted: December 2, 1993, through January 10, 1994 Inspectors: H. Peterson C. H. Brown P mm 3 Approved By: M Awst- 6($

NFuce L. Jo'rs(nskrj, Chief Date Reactor Projedts Section lA Inspection Summary

/ Inspection from December 2,1993, through January 10, 1994 (Reports No. 50-454/93017(DRP): 50-455/93017(DRP)).

Areas Inspected: Routir.e, unannounced safety inspection by the resident inspectors of previous inspection findings, operational safety, material condition, housekeeping and plant cleanliness, radiological controls, plant chemistry, security, safety assessment / quality verification, maintenance and surveillance activities, licensee reports, and engineering and technical suppor .,

Results: No violations or deviations were identified. . The following is a summary of performance during this inspection period:

Operations Performance in this area was goo During this insoection period, the licensee experienced se'/eral challenges and satisfactorily solved each problem, including a high seal leakoff from IB reactor coolant pump and an operability concern on the motor driven auxiliary feedwater (AFW) pumps. Both concerns were mitigated in a timely manner. The operability call on the AFW pumps was made satisfactorily and met the intent.of Generic Letter 91-18

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(paragraph 3a). Additionally, the operations department changed the operations shift rotation from 12 to 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shift The department has undertaken an optimistic 1994 " Perspectives" program, to endeavor to furthek'

& 4 improve plant operations (paragraph 3b). \g 9402020072 940125 '

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Safety Assessment /0uality Verification Performance in this area was good. Another major reorganization of the Site Quality Verification (SQV) group has been initiated, including changes in the reporting chain (paragraph 4). In addition, the SQV group also identified the

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concern related to the procedure revisions associated with the reactor coolant pump seal leakoff problem (paragraph 3a). ,

Maintenance and Surveillance [

Performance in this area was good. A summary of major work items are noted in paragraph Engineering and Technical Support ,

Performance in this area was good. Effective actions were taken to promptly resolve the immediate operability concerns related to the motor-driven AFW pumps (paragraph 6a). In addition, the second meeting of the Systems -

Readiness Review Board was observed (paragraph 6b).

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DETAILS ,

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1. Persons Contacted Commonwealth Edison Company (Ceco) i

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• K. Schwartz, Station Manager

• T. Tulon, Operations Manager L

• St. Clair, Site Engineering Construction Manager <

P. Johnson, Technical Service Superintendent  :

E. Campbell, Support Services Director M. Snow, Work Control Superintendent

• D. Brindle, Regulatory Assurance Supervisor  ;

• T. Gierich, Maintenance Superintendent  !

• T. Schuster, Site Quality Verification Director q W. Grundman, Site Quality Verification Superintendent '

• A. Javorik, . System Engineering Department Supervisor .

E. Zittle, Security Administrator

• P. Enge, NRC Coordinator <

R. Wegner, Shift Operations Supervisor W. Kouba, Long Range Work Control Superintendent B. Gossman, Chemistry Supervisor a

• R. Vivian, Construction Superintendent 'j

• Denotes those attending the exit interview conducted on January 10, 199 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, and electrical, ,

mechanical and instrument maintenance personnel, and contract security .'

personne . Action on Previous Inspection Findings (92701. 92702) ,

(Closed) Inspection Follow Up Item 454/455-93006-01 (DRS): Several fuse ,

control discrepancies, including incorrect fuses being installed in safety related equipment, were identified during.the Electrical

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Distribution System Functional Inspection (EDSFI). The licensee committed to perform a complete walkdown of safety related . fuses and to strengthen the fuse control procedure. During the walkdown of safety related systems, a few additional fuse control errors were identified >

and immediately corrected. The licensee initiated a fuse control team t to improve the fuse control program. ' On December 9,1993, the inspector attended one of the fuse control team meetings, where several aspects'of -

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procedural improvements were discussed. The licensee continues to perform fuse walkdowns associated with all systems. The program, including the fuse control procedure, appears to have been enhanced to ,

ensure adequate fuse control. This item is considered close ,

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3. Plant Operations

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Both units operated at power levels up to 100% in the load following ;

mode throughout the report perio I

' Operational Safety Verification (71707, 93702)

The inspectors verified that the facility was being operated in conformance with applicable licenses and regulatory requirement Additionally, the licensee's management control system continues to effectively carry out its responsibilities for safe operatio During this inspection period the following items, relating.to i operational events and issues, were evaluate J 18 Reactor Coolant Pump (RCP) Seal Leakoff Problem j During the spring 1993 refueling outage on Unit 1, the licensee .;

performed seal " package" replacement on three reactor coolant '

pumps (IA, IB, ID). Following the outage, the IB RCP seal leakoff was observed to be slightly higher than the other three RCPs. All other RCP parameters for pump 1B were normal. During the past ;

several months, the IB seal leakoff has been slowly increasin During this inspection period, the IB RCP seal leakoff flow. peaked to approximately 5.6 gpm (normal operating flow is 2-3 gpm). On December 3,1993, to ensure the other RCP seal leakoff high flow alarms were not masked, the IB RCP alarm was raised from 4.8 to -

5.6 gp ,

The seal inspection during the last outage revealed a fibrous !

material on the seal faces, which may have been'from a filter failure. Also,'the seal water contained small amounts of iron oxide, which may have caused the higher leakoff flow from the seal. During this inspection period, in an attempt to enhance -

filter performance, a 1.0 micron filter was replaced with a 0.45 micron fine filter in the seal water syste Additionally, the licensee obtained RCP operating experience guidance from Westinghouse, indicating that RCP operation may be continued with seal leakoff flow between 6.0 and 8.0 gpm, as long ,

as pump bearing and seal water temperatures are normal and not increasing. To allow the expanded operating limit, the flow transmitter for 1B RCP seal leakoff was replaced with a wide range (0-10 gpm) transmitter, and the chart recorder in the control room i was re-scaled to read 0-10 gpm. _ The licensee, in conjunction with the transmitter replacement, initiated actions to revise the i abnormal operating. procedure for RCP seal failure, RCP- The' inspectors reviewed the Westinghouse document and discussed some concerns about the procedure revisions with the license The original RCP seal failure procedure required immediate reactor and RCP trip at seal leakoff greater than 6 gpm. The Westinghouse document stated that, although RCP operations are acceptable above

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6 gpm, immediate shut down of.the RCP was required when. seal leakoff flow exceeded 8 gpm. The initial temporary procedure -

changes did not address the need to immediately shutdown the RCP

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if seal leakoff exceeded 8 gp The Site Quality Verification (SQV) group identified the same ,

concern as the inspectors. Subsequently, the licensee initiated a new revision to the abnormal operating procedure, enhancing the initial procedure change. The requirement was added that an immediate trip of the reactor and RCP 18 was to be initiated whenever the IB RCP seal leakoff increased above 8.0 gp In conclusion, the licensee's actions, including investigating.the problem and initiating hardware changes, were good. However, initial procedure revisions were inadequate in that they did not fully incorporate the Westinghouse guidance. These inadequacies were corrected after identification by the inspectors and the SQV :

group. Overall, there were no significant safety concerns pertaining to the initial temporary procedure change, and subsequent changes to the abnormal procedure were adequat Motor Driven Auxiliary Feedwater (AFW) Pumps Operability Concern

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On December 8, 1993, station management was notified by Braidwood Station of a design concern associated with the AFW pumps. The <

concern questioned the response of the motor driven AFW pumps during and after a sudden loss of the condensate storage tank (CST), for example, due to a seismic event. The specific design problem was with the time delay circuits. The pumps were evaluated to have the potential to defeat the pump suction switchover from the CST to the essential service water system. It was also determined that the pump would potentially cycle through the start and trip process until damage occurre The licensee performed an operability determination and declared the 1A and 2A AFW pumps inoperable on December 9,1993. This was a valid, conservative action.. Appropriate actions were taken to enter the technical specification 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> limiting condition for operation, and a temporary alteration and operator aid were installed on December 10, 1993. Further evaluation of the engineering aspects of the AFW pump concern is detailed in paragraph 6 b. Byron Station 1994 Perspectives The operating department has initiated actions to focus on several areas to further improve plant operations for 1994 in the following areas:

. Enhancing human performance by re-examining the independent verification process, re-examining the self-check program, and continuing to lower the problem identification form

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(PIF) threshold to identify and fix small problems; e Developing critical, meaningful self-assessments for the department; e Continuing to improve communications with the shifts; and e optimizing computer usage (EWCS, turnovers, caution card logs).

In addition to these focal areas, the operations department has initiated an ambitious list of projects and ideas, including procedure verification and improvements, material condition program enhancements, work practice initiatives, and support of PIF investigations and root cause determination, to get the operating personnel more involved in the operating fundamentals including teamwork, communications, procedure compliance, and sel f-checkin c. Material Condition The inspectors performed general plant walkdowns, as well as selected system and component walkdowns, to assess the general and specific material condition of the plan Systematic efforts to improve material condition throughout the plant were continued, including decontamination efforts, and some corroded valve repairs. It appeared that material condition associated with the fire protection system requires improvemen In particular, the number of impaired fire barrier doors throughout the plant has increased, and several corroded valves associated with the system were noted. The licensee has initiated action to focus greater attention on the fire protection syste d. Housekeeping and Plant Cleanliness The inspectors monitored the status of housekeeping and plant cleanliness for fire protection and protection of safety-related equipment from intrusion of foreign matter. The clean up and painting programs within the auxiliary building have been effective, as housekeeping and plant cleanliness continue to improv e. Radiological Controls The inspectors verified that personnel were following health physics procedures for dosimetry, protective clothing, frisking and posting; and they randomly examined radiation protection instrumentation for operability and calibratio Radiation protection personnel continue to be very responsive to the needs of the plant. Decontamination efforts have continued with the containment spray pump rooms now partially decontaminated to allow 6 )

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for easier access, Chemistry On December 1, 1993, the chemistry department initiated a program called Molar Ratio Control for Unit I steam generators (S/G).

This program involves the injection of Chloride into the secondary system in an attempt to create a neutral pH environment and possibly slow down the rate of S/G tube cracking. Unit I was selected as the initial test unit for Byron due to its high-rate of S/G tube problems. Once the results of the Molar Ratio Control program have been proved and verified, then the program may be initiated for Unit Security Each week during routine activities or tours, the inspectors monitored security practices to ensure that observed actions were being implemented according to the approved security plan. 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 vital areas were locked and alarmed. Additionally, the inspectors also observed that personnel and packages entering the protected area were properly searche No violations or deviations were identifie . Safety Assessment /0uality verification (40500, 90712, 92700)

The inspectors evaluated the scope and effectiveness of the station self assessment and quality assurance programs. The inspectors focused on determining if the licensee's self assessment programs contributed to prevention of problems by assessing the licensee's field monitoring, audit programs, and selective review of Licensee Event Report On January 10, 1994, management announced a reorganization of the Site Quality Verification (SQV) group. In an attempt to improve communications and operations associated with quality assurance, the SQV group will be incorporated within the' site management organization. The primary focus of this change will be the direct reporting of the SQV Director to the Site Vice President. The licensee believes that this course of action will enhance accountability and, on a long term basis, will strengthen the SQV role in promoting better self-assessment. The reorganization will take place starting at the end of the first quarter of 1994, and is expected to be completed by the end of the second quarte No violations or deviations were identifie b

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5. Maintenance / Surveillance-(62703. 61726) Maintenance Activities (62703)

Routinely, station maintenance activities were observed and/or '

reviewed to ascertain whether they were conducted in accordance with approved procedures, regulatory guides and industry codes or standards, and in conformance with technical specification '

Portions of the following maintenance activities were observed and/or reviewed:

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Circulating Water Box Tube Leakage Repair *

Feedwater Isolation Valve (2FWOO9C) Nitrogen Leak Repair Modification-on the Emergency Diesel Generator (EDG) Air Compressor - Excessive Vibration Surveillance Activities (61726) t

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During the inspection period, the inspectors observed technical specification required surveillance testing and verified that testing was performed in accordance with applicable procedures, that test instrumentation was calibrated, that results conformed with technical specifications and procedure requirements and wer ,

reviewed, and that any deficiencies identified during the testing ,

- were properly resolve The inspectors witnessed and/or reviewed portions of the following surveillances:

. 2A Safety Injection Pump Discharge Pressure Transmitter Calibration

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Charging Pump ASME surveillance Partial Stroke Test of Main Steam Isolation Valves lA EDG Monthly

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lA Motor Driven Auxiliary Feedwater (AFW) Pump Monthly 2B Diesel Driven AFW Pump Monthly No violations or deviations were identifie . Engineering & Technical Support (37700) ,

The inspectors evaluated the extent to which engineering principles and evaluations were integrated into daily plant activities. This was accomplished by asses:,ing the technical staff involvement in non-routine events, outage-related activities, and assigned technical specification surveillances. Further evaluation was conducted, as necessary, by observing technical staff involvement associated with on-going maintenance work and troubleshooting, and reviewing deviation investigations and root cause analysi .

a. Motor Driven Auxiliary Feedwater Pump Temporary Alteration ,

, On December 8, 1993, at approximately 2:30 p.m., the engineering I staff at the Braidwood station notified Byron station of a potential design modification problem associated with the two i motor driven auxiliary feedwater (AFW) pumps, lA and 2A. The inspector discussed Generic Letter 91-18 with the licensee, ,

emphasizing the need to focus on safety and make a timely operability determination. Management. acknowledged the inspector's concern and satisfactorily initiated actions to gather ;

technical information to make the necessary operability determinatio ,

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The motor-driven AFW pump has two time delays associated with the switchover from the condensate storage tank to essential service water (SX), the alternate water source, on low suction pressur As a result, on a rapid loss of suction pressure, the pump could trip before switching to SX due to these time delays. In -

addition, since the time delays are energized when the pump starts and reset when the pump is de-energized, the pump could theoretically restart with the low suction pressure, trip again after the time delay, and continue to repeat the cycle until the pump is damage Both motor-driven AFW pumps were declared inoperable on December 9 .;

and the technical specification 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> limiting condition for operation for the AFW system was entere Byron and Braidwood worked together to jointly develop a corrective action plan to address the operability issue. A temporary alteration was made to the AFW logic circuitry, whereby the time delay for the suction switchover was relocated such that the time delay would not be reset after the pump trip. This would then ensure suction switch-over to the SX syste This temporary alteration / modification was installed in a timely manner; however, complications were identified by the license It was determined that the position of the pump handswitch (after close) affected subsequent an automatic start or manual start of the motor driven AFW pump, because the auto SX switchover could be bypasse This was due to the configuration of the pump control switch contacts. It would then be necessary to manually align the SX valve. The licensee conducted additional training to inform the operators of the configuration problem, and placed an operator aid on the AFW pump control switch to ensure proper positionin The licensee satisfactorily performed an onsite review of all the corrective actions on December 11, and declared the system operabl ,

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The licensee's response following the identification of the AFW design problem was considered good; however, concerns were raised with the adequacy of the original design modification which installed the time delays. A combined Byron and Braidwood

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inspection by region-based specialists was initiated on December 16,-1993, to perform a detailed evaluation of the temporary modification, and review the history of all major AFW modifications. The results of that inspection will be documented in Report Nos. 50-454/455-94003(DRS).

In conclusion, once the concern was relayed to Byron, the handling of the AFW problem by the Byron staff was good. The overall operability determination of the AFW system was made in approximately 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />, and met the intent of Generic Letter 91-18. The corrective actions were timely implemented to restore the-system to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after inoperability declaration. The inspector will continue to monitor licensee's progress for a permanent modification on the motor driven AFW pump System Readiness Review Board In November 1993, the technical support group initiated a new program designed to consolidate system information and status, called the System Readiness Review Board (SRRB).

On December 7, 1993, the inspector attended the second meeting of the SRRB. This meeting covered four systems; auxiliary feedwater (AFW), residual heat removal (RHR), process radiation monitors, and service / instrument air. Management and operating staff initiated probing questions resulting in several follow up item The following issues were raised: diesel driven AFW pumps cleanliness and pump suction pressure and condensate storage tank level issue; RHR pump seal replacements and room decontamination; evaluation of the enhancement and replacement of radiation monitoring systems; and performance enhancements of the station air compressor In conclusion, the program continues to show the potential to be a significant tool in promoting and enhancing system readiness. The inspector discussed the need of the licensee to aggressive follow up on the issues in order for this program to be effective. The licensee has initiated a schedule to review and update existing-SRRB issues every fourth SRRB meetin !

No violations or deviations were identifie . Report Review

, Operating Reports During the inspection period, the inspector reviewed the licensee's Monthly Performance Report for November 1993. The inspector confirmed that the information provided met the i requirements of Technical Specification 6.9.1.8 and Regulatory Guide 1.1 .

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, The inspector also reviewed the licensee's Monthly Plant Status Report for November 199 Licensee Event Report (LER) Follow-up (90712, 92700)

s Through direct observations, discussions with licensee personnel, and review of records, the following event report was 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 accordance with Technical Specifications (TS): ,

(0 pen) LER 455/93-467 (LER No.93-008): Unit 2 reactor scram due to a Solid State Protection System (SSPS) circuit card proble The licensee continues its follow-up investigation, including the establishment of a simulated SSPS panel to further test the .

circuit cards. The licensee encountered some difficulty in -'

setting up the test panel in the simulator. This included the procurement of additional parts. The test panel has.been scheduled to be completed and the circuit cards tested by _the second week of January 1994. The inspectors will continue to monitor the licensee's progress associated with the circuit card testing and root cause investigations. This item is considered open, pending completion of licensee's testin .-

No violations or deviations were identifie :

8. Meetinas and Other Activities (30702, 30703)

, On December 23, 1993, two Illinois State Representatives, Mr Barb Giolitto and Mrs. Paula Lind, visited the Byron plant for an ;

informational tour. They also met with licensee management and ,

the senior resident inspecto t On January 5, 1994, Messrs J. J. O'Connor, Commonwealth Edison Chief Executive Officer and Chairman of the Board, and Mike Wallace, Senior Vice President and Chief Nuclear Officer, visited the Byron station to present an award for continued excellence in performance, the ' Eagle Award,' to the Byron staf , Exit Interview The inspectors met with the licensee representatives denoted in paragraph I during the inspection period and at the conclusion of the inspection on January 10, 1994. 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 natur l

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