IR 05000454/1997015
| ML20217K850 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 10/20/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20217K843 | List: |
| References | |
| 50-454-97-15, 50-455-97-15, NUDOCS 9710300011 | |
| Download: ML20217K850 (24) | |
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i i U. S. NUCLEAR REGULATORY COMMISSION REGION lil
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Docket Nos: 50-454,50-455
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Lloense Nos: NPF 37. NPF 46 Report No: 5H54/97015(DRP); 50-455/97015(DRP) Licensee: Commonwealth Edison Company Facility: Byron Generating Statbn, Units 1 & 2 Location: 4450 N. German Church Road Byron,IL 61010 Dates: July 25 through September 8,1997 Inspectors: S. Burgess, Senior Resident inspector N. Hilton, Resident inspector' P. Krohn, Reactor inspector, Rill C. Thompson, Illinois Department of Nuclear Safety
,; Approved by: Roger D. Lanksbury, Chief, Reactor Projects, Branch 3 9710300011 971020 i PDR ADOCK 05000454 G pg ;- - - - -. - . . . _ _ _ _ _ _ _ _ _ . - _ _ _
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EXECUTIVE SUMMARY Byron Generating Station, Units 1 & 2 NRC Inspection Report 50 454/g7015(DRP), 50-455/g7015(DRP) This inspection included aspects of licensee operations, maintenance, engineering, and plant support. The report covers a 6 week period of resident inspection. Additionally, this inspection included aspects of licensee operations, maintenance, engineering, and plant support pertaining to the Unit 1 auxiliary feedwater (AF) system. The AF portion of the report covers a 1 week period of inspection.
Operations
* The inspectors noted a decline in the operations department log keeping practices as evidenced by the lack of safety iriection accumulator level log entries, poor daily order requirements, and missing log entries from the official control roorr log (Section 01.2).
- The licensee identified that the limiting condition for operation action requirement was not entered while the pressurtzer heater feeder breaker was open while a small contact ooil 1 fire was extinguished (Section 01.3).
- Poor communications between operating crews resulted in confusion as to whether the pressurizer heater contact cabinet was or should have been quarantined after a small contact coil fire (Section 01.3).
Maintenance / Surveillance
* Routine maintenance and surveillance activities were well performed (Section M1.1 and M1.2).
- The inspectors considered the licensee's continued slit inspection efforts to be effective in identifying potential contributors to the increased sitting found in the essential service water (SX) cooling towers and tiie river screen house (Section M1.2).
- The inadvertent auto start of the OB essential service water make-up pump was an example of poor documentation of precautions for potential system response in work packages and was a violation of 10 CFR Part 50, Appendix B, Criterion XVI (Section M1.3).
- A breakdown in foreign material exclusion (FME) controls occurred during activities associated with n,aintenance in the spent fuel pool area. However, appropriate immediate action and planned additional corrective actions were taken. Tne Comed corporate FME procedure continued to be a oc,ncem in that it did not require stringent FME controls. The failure to follow Byron fuel handling procedure FH-31 was a violation of Technical Specification 6.8.1 (Section M1.4).
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Material condition items found by the inspectors on the Unit i AF system were not safety significant; however, the inspectors questioned why licensee system walkdowns failed to identify the same issues (Section M2.1).
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. _ - _ _. _ _ _ _ _ _ _ _ _ _ _ - ,? ,- * The inspectors concluded that the licensee failed to take timely corrective actions to revise Technical Specification Table 3.3 4 and procedure 1818 3.2.1421 when the setpoint for AF pump suction transfer from the condensate storage tank to 8X changes was made in December 1994. A violation was issued with two examples of inappropriate conective actions. (Section M3.1).
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* The procedure to reduce the pressure between the ECC8 check valves was well -
prepared and executed. - Howow, a missing ' safety evaluation, identified by the inspectors, demonstrated a need for continued emphasis on safety evaluations -
(Section E1.1).
* The inspectors identified that engineering personnel failed to address the effects of
' reactor coolant system check valve leakage on potential residual heat removal system i overpressurization (Section E1.2).
- Byron's design basis initiative program, implemented in response to the NRC's 10 CFR ;
50.54(f) letter, was clearty defined and well staffed (Section E2.1).
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REPORT DETAILS !
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Summary of Plant Status f . Unit 1 and Unit 2 operated at or near full power during this inspection period. l l
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$ l. Operationg ! 01 Conduet of Operations
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01.1 General Comments (71707) i Using inspection Procedure 71707, the inspectors conducted frequent reviews of ongoing plant ope,ations. In general, the conduct of operations was professional and - .
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safety conscious. Observations indicated that the operations staff was knowledgeable of
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plant conditions and responded promptly and appropriately to alarms; however, the ._ Inspectors noted a decline in log taking practices during the period. Specific events and . ! noteworthy observations are detailed in the sections below.
{ 01.2 incomplete Loa Entries With Safety inled!an Am=mhter Level Chanoes j s. Insoection Boone (71707)
- - During a routine log review, the inspectors noted that the run time for a safety injection
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(SI) pump was not documented. The inspectors also reviewed the Unit 2 log for 81 socumulatorlevel changes .
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- b. Observations and Findinas l (
\ The 2D Si accumulator check valve has been periodically leaking n small amount , (approximately 0.015 gpm) during the current cycle. The Technical Specification (TS)
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- allowed isakage was 1 gpm. The check valve leakage resulted in a slow increase in the 2D accumulator level and a corresponding reduction in accumulator boron concentration.
The licensee periodically borated the accumulator with refueling water storage tank i
- (RWST) water using a drain and fill procedure. An 81 pump was used to refill the
- accumulator.
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. The inspectors noted that TS 4.5.1.1.b required an accumulator to be demonstrated operable within 6 hours, after each solution volume increase of greater than or equal to 70 gallons, by verifying the boron concentration of the accumulator solution. The sample - , requirement was not applicable if the RWST was used to increase the volume and the ] : RWST boron concentration was greater than the accumulator boron concentration. The licensee determined that, based on the accumulator check valve leak rate, sampling
; every Monday, Wednesday, and Friday would meet the TS requirement.
The inspectors noted that periodically, usually on weekends, operators lowered accumulator level to maintain level within the TS required values. However, the
inspectors identified that the amount drained from the occumulator was not logged.
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. . Additionally, accumulator level was not included in point history on the process computer.
The inspectors questioned compliance with the T8 sample requirement and system engineer's awareness of the level reductions to ensure accurate leak rate calculations.
The licensee indicated that, given the existing leak rate, the sample frequency was sumcient, including a periodic drain, to ensure TS compliance. The inspectors agreed but determined that accumulator level changes should be logged.
The licensee agreed that additional logging detail was noosssary and issued a daily order with a supplemental log sheet for scoumulator level. However, the inspectors identified that the daily order only required the operators to log level once per shin and did not require a log entry for changing accumulator level as discussed by the inspectors. The licensee subsequently changed the daily order to require the logging of any accumulator level changes.
During a routine log review, the inspootors noted that the 81 pump start and stop times had not been logged during the accumulator boration the previous evening. Anor en investigation, the operators determined the start and stop times were included in the unofficial log existing in a computer. The correct log was reprinted from the computer and reviewed, signed, and incorporated into the omoial unit logs. At the end of the inspection period, the licensee had not determined the cause of the missing entries; however, the lloonsee believed that a late entry was made after the shift logs were pitnted and not identifled as a late entry. The inspectors were conoemed that although - Immediately retrieved, the pump run times were not part of the omoiallog.
c. Conclusions The inspectors concluded that the lack of accumulator level log entries, poor daily order requirements, and missing log entries from the omoial log indicated a decline in the operations department log keeping practices.
01.3 Unit 1 Pressurtzer Heater Conimet Coll Fire a. inspection 8 cope (71707) The inspectors reviewed the licensee's actions after a small fire in the Group B pressurizer heater breaker contact cabinet on July 27,1997. The inspectors reviewed T8 applicability, actions taken by the operators, and the investigation initiated by the
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b. Observations and Findings On July 27,1997, the Unit 1 Group B pressurtzer heater group contact coil overheated and Ignited. A fire watch initially reported the smoke. When operators opened Ge door, a small flame was noted on a contact coil which self-extinguished when the door was opened. Control room operators de-energized the contact cabinet by opening the feeder breaker to the B and C heater groups.
HRC Inspection Report g7012 documented that TS 3A 3 did not require redundant pressurizer heater capabilify'.~The insnectors determined, and the licensee agreed, that the intent of TS 3A.3 was to require redundant heater capability, Until a TS amendment
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was approved, the licensee's short-term corrective actions included the issuance of a daily order that provided operators directim to enter a limiting condition for operation action requirement (LCOAR) when redundant pressurtzer heater capability was not available. When the operators opened the feeder breaker to both groups of breakers to extinguish the fire, the redundant heater groups were removed. The operators did not enter the LCOAR while the feeder breeker was open as required by the daily order. The inspectors reviewed the daily order and noted that the administrative requirement to enter the LCOAR was not clear. The licensee suosequently prepared a new daily order that provided additional guidance on the LCOAR entry requ rements.
The inspectors asked the operators if the contact cabinet had been quarantined. A unit supervisor was not sure whether the cabinet had been quarantined, but thought that it should t,s. A shift manager did not believe it was quarantined and did not believe that the magnitude of the event required that the equipment be quarantined. The inspectors were subsequently informed that the contact ombinet had been quarantined.
The inspectors reviewed Nuclear Station Work Procedure (NSWP) . A 11. " Quarantine of Areas, Equipm9nt and Recoids," Revision 1, and noted that a form was required to be completed to identify all the equipment that was quarantined after an event. The --- operators had not complsted the form; however, the damaged contact was isolated with an out-of service, implementation of N8WPd 11 was at the shift manager's discretion.
The inspectors were concemed that the operators were not fully aware of the requirements of N8WP A 11. The NSWP series was a new corporatu wide series for all Commonwealth Edison stations. Several new NSWPs' had been issued and generally were similar to previous Byron procedures. However, the inspectors were conoemed that subtle differences between the Byron and corporate procedures had not been effectively communicated. The licensee stated that training had been completed on the NSWPs.
c. Conclusions The inspectors concluded that the LCOAR should have been entered while the feeder breaker was open as directed in the operations department daily order. Poor communications between operating crews resulted in confusion as to whether the pressurizer heater contact cabinet was or should have been quarantined after a small contact coil fire.
08 Miseellaneous Operations issues (92700,92901) 08,1 (Closed) URI 50-454/94022 03: Diesel generator (DG) Inoperability in Mode 5 due to misinterpretation of TS requirements.- This item is a duplicate of LER 50-454/g4014,
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which was closed and a violation was issued in NRC inspection Report 97008. This item is closed.
'08.2 (Closedi LER 50-455/95002. LER 60-455/95002-01: Extraction steam valve maintenance without LCOAR entry due to personnel error. Shift operating personnel failed to realize ' that the TS LCOAR was not entered for maintenance work on extraction steam non-retum check valve 2E8002. Technical Specification 3.3.4 required that if a valve associated with the turbine protection system was cons'dered inoperable, then the steam supply affected by the Iniperable valve must be isolated from the main turbine within
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L ! , 6 hours. Valve E8002 was one of several valves required to be opersble for turt>lne overspeed protection. The valve was inoperable for approximately 12 hours. The inspectors reviewed the licensee's corrective action for this LER and found them appropriate and acceptable to prevent similar occurrences. Failure to meet the requirements of a LCOAR as well as the necesaary actions within the 6 hour completion time is a violation of TS 3.3.4 b; however, this licensee identified and corrected violation is being treated as a non cited violation, consistent with Section Vil.B.1 of the NRC Enforcement Policy (50 455/97015-01(DRP)). This item is closed.
08.3 (Closed) URI 50-455/95004-01: Review of licensee's corrective actions and root cause of failure to enter LCOAR for extraction steam valve maintenance. This item is a duplicate of LER 50 455/95002, which has been closed as a non cited violation in Section 08.2 in this report. No further concems were noted. This item is closed.
08.4 (Closed)IFl 50 454/455-94027-01: Review of root cause evaluation regarding five missed or late T8 surveillances in a 4 month period due to poor test coordination and management oversight. The inspectors reviewed the licensee's root cause evaluation and also reviewed the number of late or missed T8 surveillances during the 1995 through 1997 time period. The inspectors noted fewer missed surveillances; specifloally, three during 1995 and one in 1996. Thus far in 1997, the licensee had missed four T8 surveillances; however, the root cause for these instances has been misinterpretation of T8 surveillance requirements since initial plant operation and not poor test coordination.
The inspectors considered the corrective actions to preclude missed or late T8 surveillances acceptable and had no further conoems. This item is closed.
08.5 (Closed) URI 50 454/455 95013-01: Review of the licensee's root investigation for why valve 2FWO278 position did not match the out of service (OOS) position. On February 8, 1996, while removing the 008 tag, the licensee discovered that the valve was already in the open position with the OOS card indicating a closed position. The inspectors reviewed the licensee's root cause determination, which could not identify when or whom changed the valve position. The inspectors determined that the licensee's efforts to identify a root cause were thorough. The inspectors reviewed other instances during the past 2 years where 008 tag positions were different than those found in the plant using the lictnsee's trending program and identified only one instance similar to this item. ,
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Based on the licensee's thorough effoits to identify the root cause and the lack of pervasive 008 tag / equipment discrepancies during the last 2 years, this item is closed, 08.6 (Closed) LER 50-454/96012: The T8 action statement was not entered for a tomado watch. The weather radio, located in the shift managers office, alarmed when no personnel were in the shift managers office. There were no safety consequencas impacting plant safety as a result of this event. The missed actions required by TS were to verify both deep well pumps were operable and to ve..y both essential service water (SX) cooling tower basin levels were greater than or equal to 82% However, plant records indicated that both deep well pumps were operable and the SX basin levels were greater than or equal to 82%, throughout the tomado watch. The inspectors verified that the licensee installed a weather radio in the control room and a weekly operational check was performed, This item is closed.
08.7 (Closed) IFl 50-454/455-94020-03: Review of the licensee's response to a Westinghouse analysis regarding emergency core cooling system actuation during translents while at
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power, initial actions performed by the licensee were charactedzed as a ',trength in NRC
- Report 94020. The inspectors verified that the licensee revised procedures 1/2DEP 0, i
" Reactor Trip or Safety IrSoction," to verify at least one flowpath was available through the i pressurizer power operated relief valves (PORVs). All licensed operators wee trained on i
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the revision and its basis. Also, the licensee revised the LCOAR procedure to address tha concem of two pressurtzer PORV block valves being closed simultaneously for excessive seat damage. The Inspectors considered the licensee's actions for this issue
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thorot.gh This item is closed.
08.8 (Closed) VIO 50 454/455 96003-01b: VIO 50 dM/455 eAnna-01: VIO 50 454/455-96012- i 9.3h: Failure to follow flood door!mpairment procedure for the SX pump room doors and r the auxiliary building floor dr,nin sump room doors. The inspectors reviewed revisions to ' Byron Administrative Procedure (BAP) 1100 3, " Fire Protection Systems, Fire Rated ! Assemblies, Ventilation Seals, Flood Seals, and Watertight Doors impairments," Revision i l, that the licensee had implemented to address this issue. Procedure changes included a requirement that water tight doors be closed and secured except during passage or for short stays within the room for less than 15 minutes. A barrier / fire ' protection system impairment permit was required if the water tight door needed to be open for more than 15 minutes Because violation 50-454/455-g6012-03b was identified by the inspectors after this procedure revision, the licensee installed video cameras in April 19g7, at each of the water tight doors to moniter and identify an open door before the allowed 15 minute ortteria was exceeded, The licensee also planned to install an alarm at the door that would sound when the door was opened for periods longer than
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15 minutes without a impairment tag issued. The inspectors determined that corrective actions to addreas open or unattended water tight doors were acceptable. There have ' been no instances of procedural violation since the video cameras were installed. This item is closed.
11. Maintenance , M1 Conduct of Maintenance
M1.1 Maintenance Observations (62707) i a. Inspection Scope The inspectors observed the performance of all of, or portions of, the following work requests (WR), When applicable, the inspectors also reviewed TS and the UFSAR for ' potentialissues,
. * WR 970086244 Troubleshoot 18 Auxiliary Feedwater (AF) diesel tachometer switch -* WR 97008651 Check freon charge for new DG 2A air dryer . - WR 960021245 01 Preventative maintenance for Unit 0 Component Cooling water 4 kV breaker + - WR 960021247 Inspect Unit 0 CC switchgear cubicles , * WR 970081058 Repair Unit 1 group B pressurizer heater supply Freaker * WR 970028824 Open and clean 1 A residual heat removal pump cubicle cooler
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WR 970020438 Repair Unit 2 boric acid transfer pump
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WR 970009122 01 Replace bushings and diaphragm . Unit I diesel oil storage tank fire protection foam tank b. Op_ttomlikrit_edEndings The inspectors observed that the maintenance activities were conducted in accordance wl'h appr est preaedums and were in conformance with TS. The inspectors observed m&.)swtN sgervisors and system engineers monitoring job progress. Quality control pomonet v. tro s!so present when required. When apnticable, appropriate radiation protection W.esures were in place.
c. Concrusions The inspectors determined that routine maintenance activities were well performed.
Mt? Surveillance Observations (61726) a. jnspection Sm,g The inspectors observed the performance of all of, or parts of, the following surveillance test procedures. The inspectors also reviewed plant equipment and surveillance testing activities against the UFSAR descriptions.
+ 2BOS 8.1.1.2.a-2 2B DG monthly surveillance test
. BIP 2500-099 Calibration of Tachometer and Engine Speed Switch . BVP 500-32 Testing Operational Procedure for the Movable incore Detector Systern . SPP 97-020 DG Starting System A!r Dryer Replacement Modification Test . 2BOS 8.1.1.2.a 1 2A DG Semi Annual Survelliance Test . 1BOS 7.1.2.1.b-2 1A Motor Driven AF Pump Monthly Surveillance Test . OBVS SX 5 Inspection of River Screen House (RSH) and SX Cooling Tower Basins . 1BVS 6.2.1.b.2 12 Containment Spray Pump ASME Quarteriy Survelliance Test . 2 BIS 3.2.1-022 Functional Test of Auxiliary Feedwater Pump Suction Pressure Loop . 2BVS 5.2.f.31 2B Residual Heat Removal Pump ASME Surveillance Test b. Ob=ervations and Findinas The inspectors noted that f' roper authorization was routinely obtained from the control room senior reactor operator (SRO) before the start of each surveillance test.
Comporents removed from service as part of the surveillance test were Identified prior to commencing the survell'ance test and the proper TS LCOAR was entered. At the comp!stion of the surveillance test and after independent verification of system restoration, the TS LCOAR was cicared. Test Instruments used were verified to be calibrated as applicable. The inspectors revlowed completcd surveillance tests and - verified the surveillarice tests met the acceptance criteria. Specific noteworthy observations are detailed in the following section.
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SX System Siltina inmeetions The inspectors noted that the alcensee continued to perform quarteriy RSH and SX cooling tower basin inspections for accumulated slit that could impact SX system performancs and operability. During a July RSH inepection, the licensee performed an , inspection of water vanes installed in the Rock River. The vanes were installed in 1993 to help direct the flow of debris and slit away from the RSH Intake. The licensee's sonar inspection revealed that a sandba had formed on a number of the vanes, in some instances, the vanes were almost completely buried in the sand. The licensee was working with the Army Corp of Engineers to remove the sandbar within the rext few months. The inspectors considered the licensee's continued sitting inspection efforts to be effective in identifving potential contributors to the increased sitting found in the SX cooling towers and the RSH.
M1.3 08 SX Make up Pumo inadvertent Start f62707) a. Inspection Scope During a routine control room inspection, the inspectors were notified of an inadvertent start of the OB SX make-up pump. The inspectors observed the initirl fact finding interviews and reviewed the work package, WR 960107829 02, which removed / installed an SX level switch, b. Observations and Findinog On September 2,1997, the lleensee was replacing the 08 SX cooling tower basin level switch as part of a modification. When the instmment mechanics (IMs) lifted the leads for the switch, the OB SX make up pump started because ope 7 tors had not placed the make-up pump la pull to lock. The woik package had bt.en reviewed by the unit supervisor and approved before starting work. The IMs did not discuss with the unit supervisor that the pump could auto start and the work package did not contain a step that ensured the make up pump was in pull to-lock before removing the level switch.
During the fact finding interviews, the licensee identified that the potential to auto-start the make-up pump had been discussed by the IMs during the previous planning meetings. At the end of the inspection period, the licensee was conducting an investigation of the event and determining the required corrective actions.
NRC Inspection Report 97002 discussed a violation that was issued for an event where a PORV was briefly opened due to an inadequate work procedure, in this instance, the PORV work package did not contain any precautions conceming PORV actuations, Thr, licensee's corrective actions to the violation included appropriate measures to address the specific event; however, tacause the hcen:ee considered the event unique to the spedfic instrument loop, no broad based corrective actions were implemented. The inspectors concluded that the auto start of the SX make-up pump, due to an inadequate work procedure, was an event that could have been prevented by corrective actions to the PORV actuation. Therefore, the inspectors concluded that the auto start of the 08 SX make-up pump was a violation of 10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Actions," (50-45497015-02(DRP); 455-97015-02(DRP)). i 10 l l
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c. Conclusions - The inspectors concluded that the auto start of the 8X make-up pump was due to poor documentation in woit packages of precautions for potential system response. The lack of broad-based corrr,ctive act;ons to address a similar issue raised in a previous NRC inspection report was considered a violation.
M1.4 Forelan Matedal Exclualon Proaram a. Inanection Scope During a routine auxiliary and fuel handling building inspection, the inspectors reviewed foreign material exclusion (FME) practices. The inspectors also reviewed NSWP A-03,
" Foreign Material Exclusion," Revision 0, procedure BFP FH 31, " Fuel Handling __
Cleanliness Zones and Requirements," Revision 4, and ANSI 45.2.3 1973,
" Housekeeping During the Construction Phase of Nuclear Power Plants."
b. Observations and Findinas On July 28,1997, while observing contract personnel performing modifications in the fuel transfer canal, the inspectors identified several discrepanoles in the FME zone (cleanliness zone ll) around the spent fuel pool (SFP) Untethered tools, including needlenose pliers, a hammer, and several other hand tools were on a floor cover _ approximately 4 feet from the 8FP edge. The inspectors noted that procedure BFP FH 31. Paragraph F.5.e, required tools to be tethered and logged. The inspectors considered the untethered tools an example of a failure to follow procedure BFP FH-31 and a violation of TS 6.8.1, which required procedures be implemented for the control of maintenance and modifications (50454/g7015-03a(DRP); 455 g7015-03a(DRP)). The inspectors also identified that a person logged into the area on June 23, igg 7, and had not logged out. The inspectors noted that BFP FH 31, Paragraph F.5.f required personnel accountability to be accomplished by logging in and out each individual at the e control point. The inspectors considered the person's failure to log out of the cleanliness zone an example of failuit to follow procedure BFP FH 31 and a violation of TS 6.8.1 (50 454g7015-03b(DRP); 455-g7015-03b(DRP)). The licensee reviewed the area and agreed with the inspector that a breakdown in FME contro', existed. The fuel handling supervisor became involved along with maintenance department management. Immediate coirective action included a work stoppage, the removal of equipment not required to be in the FME area, a complete inventory of all equipment in the FME area, additional briefingh for the contract personnel by the fuel handling supervisor, and the posting of fuel handling personnel as an FME entrance monitor. The inspector considered the licensee's corrective actions appropriate.
The licensee indicated that fuel handling personnel had manned the entrance to the cleanliness zone at the start of the modification work; however, contractor personnel eventually rolleved the fuel handlers, Additionally,- the contractors were using Comed corporate FME procedure NSWP-A-03 for FME controls. These FME controls were less restrictive than the requirements contained in procedure BFP FH 31,
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. Long term actions taken by'the licensee included a procedure revision to BFP FH 31 , which would allow modification to the 8FP FME area with solid barriers, and a procedure revision to NSWP A 03 which would reference BFP FH 31. The licensee also stated that l- an electronic log-in system was planned and special tethered hand tools were ordered. , 4 !
: The inspectors also identified that procedure BFP FH-31 did not contain any controls for l. transparent material. The licensee agreed that controls should exist and planned to ,
j include appropriate controls in the procedure revision pending at the end of the inspection , i period. i i i The inspectors noted that previous NRC Inspection Reports g6004, g6012, and g7002 j discussed FME issues, including one cited violation in 97002. Each report described i areas other than the SFP and reactor cavity; however, the inspectors noted that each ' ! report identified problems assoolated with procedure NSWP A 03 (previously SMP-M-04), i The licensee identified that the breakdown of FME controls near the 8FP was partially i due to the less stringent controls required in N8WP A-03. The inspectors continued to be !- concemed that NSWP A-03 did not require stringent FME controls.
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- The inspectors concluded that a breakdown in FME controls occurred; however, the i licensee took appropriate immediate action and planned additional corrective actions.
l The inspectors continued to be concemed that corporate Comed procedure N8WP-A 03 } did not require stringent FME contmis.
j M2 Maintenance and Material Condition of Facilities and Equipment , ! M2.1 . Unit 1 AF 8ystem Walkdown i ! a. Inspection Soone (71707) ! '
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l- The inspectors perfonned a walkdown of the Unit 1 AF system from the condensate ( storege tank (C8T) to the AF containment penetrations to assess material condition and j- vesify proper system lineup, i
b. Observations and Findinas [ l During the walkdown, the inspectors noted the following ms.terial condition discrepancies: l- C A local emergency lighting battery (0LL148E) in the 1B diesel driven AF pump room ' did not have an Appendix R label. The OLL148E emergency light illuminates the local l diesel control panel if normal lighting is lost.
- The inspectors noted instrument air blowing from the exhaust ports of the solenoids l-
>- for valves 1/2AF004A. The valves fall open on loss of the air supply to the valves so i the safety impact was minimal. The system engineer explained that Byron SED /SEC
- -were investigating the issue.
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The inspectors noted that am.. ugh instrument air had been isolated to AF flow control valve 1 AF005D, the local air gauge to the flow control valve actuator diaphragm read 7 ps!g.
. The inspectors noticed that two lock chains for rad waste processing valves (OABS557A and OAB05578) were secured around instrument air lines leading to the Unit 1 AF system flow control valves. The system engineer had the valves relocked in a way that did not use the instrument air lines.
+ The inspectors noted that the diesel oil retum line back to the diesel oil day tank had a flow a row on isolation valve 1DOO59 which was opposite to the labeled pipe flow direction. Subsequent investigation by the system engineer revealed an additional labeling problem where 1D0059 and 1D0096 were labeled incorrectly.
The above items and other minor housekeeping concems were brought to the attention o,' the system engineer, who initiated maintenance action requests. None of the items identified impacted safety or AF system operability, c. Conclusions None of the material condition items identified by the inspectors impacted safety or AF system operability. However, the inspectors were concemed that licensee walkdowns and system lineups performed on the AF system failed to identify the above issues.
M3 Maintenance /Suivelliance Proceduros and Documentation * M3.1 AF t.ow Sucilon Pressure Transfer SetJoint f61726) a. Inspection Scope The Inspectors reviewed the TS and UFSAR associated with the AF system. The inspectors also reviewed the following surveillance packages for adequacy of procedures, appropriate AF flow paths, and correct calibrations:
* BIS 3.2.1-205 Calibration of 1P AF051 Auxiliary Feedwater Pump Suction Pressure Low, Revision 1 +
1 BIS 3.2.1021 Functional Test of Auxillary Feedwater Pump Suction Pressure, Revision 8
+ BIS 3.3.5 201 Auxil:ary Feedwater to Steam Generator 1 A Flow Control Loop, Revision 2 +
1BOS 7.1.2.1.B 1 1A Motor Driven Auxiliary Feedwater Pump Monthly Surveillance, Revision 3 b. Observations and Findinas 1 BIS 3.2.1 021. Functional Test of AF Pqmo Suction Pressure During an AF design review in December 1994, the licensee identified that two sections of piping attached to the CST supply lines to the AF system were non seismic. AF pump suction would be normally supplied from tha CST, a non seismic tank. The safety related
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l,. ,. backup water supply for the AF suction was the 8X system, if the AF pump suction - pressure dropped to less than 14.1 psia, the isolation valves from the CST would shut and the SX supply valves would open, providing water for AF suction. The two sections of pipe identified as non seismic were located at an elevation lower than the bottom of a loop seal, if either of the two pipes ruptured, the loop seal could be siphoned and the AF suction header would then be exposed to atmospheric pressure (14.7 psla). This would have prevented the system from performing the switchover to SX since pressure would never reach the switchover pressure of 14.1 psia.
To address this design issue and ensure that the AF system performed as described in the UFSAR, the licensee changed the suction transfer setpoint to 18.1 psia (above atmospheric pressure) in December 1994. The setpoint change was controlled during instrumentation calibration using procedure 1B18 3.2.1021. The setpoint for AF pump transfer to the SX system and a"awable value setpoint values were listed in TS - Table 3.3-4, Functional Unit 6.g.
An operability assessment,' documeated in CHRON #0306210, was performed on February 10,1995. The assessment did not identify the need to revise the T8; therefore, the licensee failed to revise the setpoint and allowable values in the T8 Table. The table identified an AF pump low suction pressure transfer to 8X setpoint of 1.22 inches mercury (Hg) (14.1 pala) and an allowable limit of 2 inches Hg (13.7 psia). Failure to take timely corrective action to revise T8 Table 3.3 4, Functional Unit 6.g. to show the revised setpoint and allowable setpoint values for the AF pump low suction pressure transfer to 8X water is considered a violation of 10 CFR Part 50, Appendix B, Criterion XVI,
" Corrective Actions,"(50-45497015-04a(DRP); 455 97015-04a(DRP)).
The licensee also failed to revise procedure 1 BIS 3.2.1-021 to reflect the allowable transfer setpoint change. Though the setpoint had been set correctly following identification of the design issue, if the suction transfer setpoint had been left at 2 laches Hg as stated in the unchanged procedure, there would be no automatic transfer to SX water, Failure to take timely corrective action to revise procedure 1818 3.2.1021 to show the revised allownble value for the AF pump low suction pressure transfer to SX water is consiuered a violation of 10 CFR Par 150, Appendix B, Criterion XVI, " Corrective Actions,"
(50 45497015-04b(DRP); 455 97015-04b(DRP)).
BIS 3.3.5 201, 'Ayxillarv Foodwater to 8 team Generator 1 A Flow indication Control Loon" The inspectors reviewed completed calibration sheets of AF to steam generator 1 A flow control loop, and identified that the as-left value for the loop calibration had one point that was left out of tolerance. Although the calibration error had no effect on instrument loop operation and appeared to be an isolated incident, the inspectors noted that supervisory reviews of the package failed to detect the error.-
- The licensee documented the calibration error in problem identificat n form (PlF)
B1997 01655. The instrument loop was scheduled to be calibrated daring ts1R08.
c. Conclusions The inspectors concluded that the licensee failed to take timely corrective actions to revise TS Table 3.3-4 and procedure 1 BIS 3.2.1-021 when the setpoint for AF pump
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h suction transfer from CST to 8X changed in Decembor 1994. A violation was issued with
- two examples of inappropriate corrective actions. The inspectors also identified a calibration error for the AF to steam generator 1 A flow control loop. The inspectors considered this error to be isolated and to have no effect on instrument loop performance.
M8 Miscellaneous Maintenance /8urveillance issues (92902) M8.1 (Closed) VIO 50-454/455 96009 01: Procedure OBV8 8X 5, " inspection of River Screen House and 8X Cooling Tower Basins,' failed to have sufficient quantitative acceptance cdteria to determine SX system operability. The inspectors reviewed the licensee's corrective actions as documented in Byron letter 97-0132, dated June 13,1997. The inspectors verified that procedure OBV8 8X 5 was revised on April 1,1997, and that it included quantitative soceptance criteria on the soceptable level of sin accumulation, concrete degradatioi,, and trash rock degradation that ensured SX system operability.
The inspectors reviewed the calculations that suppoded the acceptance ortteria and agreed that they ensured 8X system operability. The inspector noted no further conoems. This item is closed. g M8.2 (Closed) VIO 50 454/455 96009-02: Failure to use adequate test instrumentation to measure the amount of slit in the 8X cooling tower basins during the performance of procedure 0BV8 8X 6.- The licensee's past praction was to measure the depth of slit - using the diver's arm or boot. The inspectors reviewed the licensee's corrective actions as documented in Byron letter 97 0132, dated June 13,1997. The inspectors verified - that procedure OBV8 8X 5 was revised on Apdl 1,1997, to require the use of a commercial grede ruler and obsented the use of the ruler dudng the performance of this surveillance on numerous occasions. This item is closed.
M8.3 (Closed) VIO 50-454/455 96009-03a: Failure to take appropriate corrective action to sitt accumulation in the SX cooling tower basins since July 26,1993. The inspectors reviewed the licensee's corrective actions as documented in Byron letter 97 0132, dated June 13,1997. The licensee took immediate corrective actions and removed accumulated slN from the SX cooling tower basins and RSH. The inspectors verified that procedure OBV8 8X 5 was revised to include quantitative acceptance cdteria on the - noceptable level of sitt accumulation. Also, the licensee increased the inspection frequency of the cooling tower basir.s and RSH to quarterty until sufficient data could be collected on an acceptable inspection interval. The inspectors observed several SX cooling tower surveillance inspections and the licensee's silt removal process when unacceptable silt accumulation was found and determined that the licensee's corrective actions had been pror.1pt and appropriate. No further concems have been noted. This
- item is closed.
M8.4 (Closed) VIO 50-454/455 96009-03b: Failure to take prompt corrective action to repair
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degraded SX cooling tower basin trash racks since 1993. The inspectors reviewed the licensee's corrective actions as documented in Byron letter v7-0132, dated June 13, 1997. The licensee took immediate corrective actions and repaired / modified the trash racks. The inspectors verified that the repairs / modifications were consistent with the L UFSAR and also verified that procedure OBVS SX 5 was revised to include quantitative acceptance criteria on trash rack degradation. The inspectors observed several SX cooling tower surveillance inspections and noted prompt and appropriate corrective
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. . actions to any unacceptable conditions. No further concems have been noted. This item is closed.
M8.5 {QL9.ged) IFl 50-454/455 97012-01: Review of 10 CFR 50.59 performed for TS falling to meet regulatory requirements for the pressudzor heaters. The inspectors identified that T8 3.4.3 did not meet the requirements for two redundant groups of pressurizer heaters to be operable as specified in the UFSAR. The inspectors reviewed the licensee's 10 CFR 60.59 screening evaluation and considered it thorough in addressing the administrative actions to be taken until the T8 were permanently changed. The inspectors also verified that the licensee submitted an amendment to the improved Technical Specifications and revised the appropriate procedures. This item is closed, lit. Enaineerina E1 Conduct of Engineering E1,1 MglL2 Ememency Core Coolina dvstem (ECCS) Ploina Dooressurization 8ately Evaluation a. Inspection Scope (37551) The inspectors reviewed Special Plant Procedure (8PP) 97-093, "2D ECCS Loop Piping Depressustration," Revision 0, the UFSAR, s.id TS. The inspectors also attended a plant operating review committee (PORC) meeting that discussed SPP 97 093.
b. Observations and Findinas The licensee prepared an SPP designed to reduce leakage through the reactor coolant system (RCS) ECCS check valve as described in Section 01.2 of this report. The intent of the procedure was to reduce the pressure between the RCS check valve and the indwidual ECC8 component check valves, thus raising the differential pressure across the RCS check valve and potentially reducing the leak rate. The inspectors reviewed the procedure and did not have any significant concems. The inspectors noted that the
- procedure did not have all initial calculation assumptions documented and also noted two editorial observations. The inspectors attended a PORC meeting that discussed the BPP and the PORC addressed each observation without the inspectors' input.
- The inspectors requested the safety evaluation for SPP 97-093; however, the licensee's safety evaluation screening determined ti.&: a safety evaluation was not required. The inspectors considered the SPP a test not dewibed in the UFSAR that should have a cafety evaluation completed. After the inspanors' questions, the licensee agreed that the procedure was a test and completed a safeq evaluation. The inspectors concluded that
. a violation of 10 CFR 50.59, " Changes, tes'4, and experiments," did not occur because the licensee completed the safety evaluation before the SPP was approved and implemented. The inspectors reviewed the completed safety evaluation and did not have any additional concems, The inspectors reviewed the SPPs prepared during 1997 to verify all test packages contained a safety evaluation. No discrepancies were noted.
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The inspectors observed the test on September 5,1997, with no deficiencies noted by the inspectors, c. Conclusions The inspectors concluded that the procedure to reduce the pressure between the ECCS check valves was well prepared end executed. However, the missing safety evaluation, identified by the inspectors, demonstrated a need for continued emphasis on safety evaluations by the licensee.
E1.3 Enalneerina Evaluation of ECCS Check Valve Lankane a. Inspection Sccse (37551) The inspectors reviewed PlF B1997 02401 regarding Unit 2 RC8 check valve leakage into the residual heat removal (RH) system. The inspectors also discussed the lasue with engineering personnel, b. Observations and Findings During the performance of the ASME 28 RH surveillance test, the system engineer experienced difficulties in obtaining accurate pump suction and discharge pressure
readings due to RC8 check valve leakage. The leakage caused the pump suction and discharge pressure to slowly increase during the test performance. As discussed in Section 01.2, this leakage also caused an increase in the 2D 81 accumulator level. Since the test could possibly last longer than the expected approximate 15 minutes length, the inspectors were concemed that pressure would continue to increase until the RH relief valve setpoint was reached. PIF Bigg7-02401 documented the issue with the ASME surveillance; however, the rasponse to the problem was narrowly focused on obtaining and evaluating ASME data and did not discuss the effect that the leaking check valves could have on ine RH system pressure.
The inspectors discussed 'he PlF's lack of RH system evaluation with system engineering personnel and the engineers agreed that the issue should have been addressed. Once performed, the inspectors reviewed the licensee's evaluation to the potential RH system overpressurization and agreed that the RH system would not reach the relief valve setpoint. The inspectors considered the lack of an engineering evaluation during the initial PlF documentation and evaluation to be a missed opportunity to evaluate the change in RH system performance based on the check valve leakage, c. Conclusiong The inspectors concluded that engineering personnel missed an opportunity to address
- the effects of RCS check valve leakage on potential RH system overpressurization during the PIF process Once an evaluation was performed, the inspectors agreed that RH system overpressurization would not occur due to the check valve leakage.
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- E2 . Engineering Support of Facilities and Equipment - E2.1 Deslan Basis initiative Peoaram - a. Inspection Scooe (37551)
The inspectors discussed the licensee's design basis initiative (dbl) program with _ _ engineering personnel. The program was implemented in response te an NRC issued 10 CFR 50.54(f)1etter regarding adequacy and availability of design basis information, b. Observations and Findinos The inspectors determined that the program coupled "line-by-line" UFSAR verification,- regulatory and design documents, calculations, and plant procedures to ensure that Eyron Station was configured and operated in a manner consistent with the design bases.
Although the dbl program was in the initial stages of implementation, the inspectors noted that the program was clear 1y defined and well staffedi The inspectors also noted that several PlFs t.ad identified a number of discrepancies during the initial UFSAR . s-reviews. The number of PlFs were expected to increase as the program devdoped.
c. . Conclusions The dbl program was clearly defined and well staffed.
E8 Miscellaneous Engineering issues (92903) E8.1 (Closed) VIO 50-454/455-95011-05: Calculation BYR95-086 did not adequctely determine the maximum differential pressure (dP) across the containment sump isolation valves. The inspectors reviewed the '.icensee's response to the violation documented in a letter to the NRC dated February 28,1996. The inspectors verified that calculation
. BYR95-086 was voided and new dP calculations for the containment isolation valves , were re-performed. The dP calculations were verified to be correct during an NRC motor operated valve inspection documented in inspection Report 96003, The inspectors abo reviewed an assessment of engineering calculations performed by the licensee that compared calculational errors made during 1995 against those made in 1996, The assessment noted that training given to engineers and increased management attention during the calculation review process were effective in decreasing calculational errors.
The inspectors had no further concems. . This item is closed.
E8.2 - (Closed) IFl 50-454/455-94022-04: Review operability assessment regarding potential increase in containment pressurei On August 30,1994, Byron engineering personnel received information from Nuclear Fuels Services (NFS) that a containment integrity.
computer analysis revealed a higher containment peak pressure than that specified in the TS. The inspectors reviewed the neensee's evaluation completed on September 23, 1994, and discussed the issue wtai site engineering personnel. The UFSAR analysis for L the containment pressure that was originally considered to be incorrect and nonconservative, was proven to be correct through detailed calculations that were re-reviewed. The licensee identified that NFS utilized a computer analysis that was not approved for use and some of the input assumptions for reactor containment fan cooler -
(RCFC) and containment spray (CS) actuation times were incorrect. The licensee
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demonstrated that the current UFSAR RCFC and CS actuation times, and the overallloss of coolant accident containment response, were correct. The inspectors had no further concems. This item is closed.
E8.3 - (Closed) IFl 50-454/455-95009-02: The DG Jacket water standpipe volume v'as less than described in the UFSAR. The inspectors reviewed the licensee's operability assessment, which determined that the lower volume was adequate for supplying water without makeup under design-basis conditions. The inspectors also determined thet appropricte procedures were revised to reflect the volume change and that the UFSAR changes were also made. The inspectoro concluded that the issue was thoroughly addressed and had no further concems. This item is closed, i IV. Plant Suonort F8 Miscellaneous Fire Protection issues (71750 and 92904) F8.1 (Closed) Vio 50 455/96009-06: Failure to follow fire door impairment procedure for containment spray fire door. The inspectors tsviewed the licensee's response to the violation in a letter to the NRC dated February 10,1997. In this particular case, a maintenance supervisor of one job, cleared the impairment tag without considering the
: other work in progress and assumed the other maintenance supervisor would initiate another impairment tag. When the first work task was completed, the impairment tag was removed. This programmatic deficiency was corrected by requiring alljobs to have individusiimpalement tags assigned. The inspectors als( ferified that the containment spray door was labeled as a fire door. The inspectors had no further concems. This item is closed.
V. Manaaement Meetinas X1 Exit Meeting Summary
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The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on September 8,1997. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information wss identified.
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PARTIAL LIST OF PERSONS CONTACTED Licensee K. Kofron, Byron Station Manager J Bauer, Health Physics Supervisor D. Brindle, Regulatory As:,urance Supervisor E. Campbell, Maintenance Super'1tendent J. Flemster, Mechanical Lead Engineering Supervisor R. Freldel, Primary Group System Engineering Lead T. Gierich, Operations Manager B, Israel, Site Quality Verification Supervisor B. Moravec, SGRP Lead T. Schuster, Manager of Quality & Safety Assessment M, Snow, Work Control Superintendent D. Wozniak, Engineering Manager INSPECTION PROCEDURES USED IP 37551: Onslie Engineering IP 61726: Surveillance Observations IP 62707: Maintenance Observations IP 71707: Plant Operations IP 71750: Plant Support IP 92700: Onslie Follow-up of Written Reports of Nonroutine Events at Power Reactor Facilities IP 92901: Followup - Plant Operations IP 92902: Followup - Maintenance IP 92903: Followup- Engineering IP 92904: Followup - Plant Support s
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ITEMS OPENED, CLOSED, AND DISCUSSED opened 50-455/97015-01 NCV Failure to meet LCOAR requirements of TS 3.3.4.b.
50-454/455-97015-02 VIO Ineffective corrective actions to prevent auto start of SX make-up pump 50 454/455 97015-03a - VIO Failure to follow BFP FH-31 for FME controls 50-454/455 97015-03b VIO Failure to follow BFP FH-31 for personnel accountability 50-454/455 97015-04a VIO Failure to update AF TS setpoint.
- 50-454/455-97015-04b VIO Failure to revise procedure 1 Bis 3.2.1-021.
Closed 5M55/95002 LER Extraction steam valve maintenance without LCOAR entry.
50 455/95002-01 LER Extraction steam valve maintenance without LCOAR entry, 50-454/96012 LER TS action statement not entered for tomado watch.
50 455/97015-02 NCV Failure to meet LCOAR requirements of TS 3.3.4.b.
50 454/94022-03 URI DG inoperability in Mode 5 due to misinterpretation of TS - requirements.
50-455/95004-01 - URI Review of licensee's corrective actions and root cause of failure to enter LCOAR for extraction steam valve maintenance.
50 454/455 95013-01 URI Review of the licensee's root investigation regarding OOS discrepancy.
50454/455-94020 03 IFi Review of the licensee's response to a Westinghouse analysis regarding ECCS actuation at power transients.
50-454/455 94022-04 IFl Review operability assessment regarding potential increase in containment pressure.
50-454/455-94027-01 'IFl Review of root cause evaluation regarding five missed or
' late TS surveillances in a four month period.
50 454/455-95009-02 IFl The DG Jacket water standpipe volume was less than described in the UFSAR.
-50-454/455-97012-01 IFl Review of 10 CFR 50.59 regarding incorrect TS for pressurizer heaters, 50 454/455-95011-05 VIO Calculation BYR95-086 did not adequately determine the maximum dP across the containment sump isolation . valves.
50-454/455-96003-01b VIO - Failure to follow flood seal impairment procedure for SX auxiliary building floor drain sump watertight door.
'504 54/455 96006-01 VIO . Failure to follow flood seal impairment procedure for watertight door.
50 454/455 96009 01 VIO Inadequate acceptance criteria in procedure OBVS SX-5.
50-454/455-96009-02 VIO Failure to use adequate test instrumentation during the
.. performance of procedure OBVS SX-5.
50-454/455-96009-03a VIO Failure to take appropriate corrective action to slit accumulation in the SX cooling tower basins since July 26, 1993.
50-454/455-96009-03b VIO Failure to take prompt corrective action to repair degraded SX cooling tower basin trash racks since 1993.
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50-455 96009-06 VIO Failure to follow fire door impairment procedure for CS fire door, 50-454/455-96012-03b VIO Failure to follow flood seal impairment procedure for SX watertight door.
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UST OF ACRONYMS USED AF Auxiliary Feedwater System-BAP Byron Administrative Proceduro BFP Byron Fuel Handling Procedure CS Containment Spray CST- Condensate Storage Tank D3l Design Basis initiative DG Diesel Generator dP Differential Pressure
.ECCS Emergency Core Cooling System FME Foreign Material Exclusior.
IM - Instrument Mechanic LCOAR Umiting Condition for Operation Action Requirement LER Ucensee Event Report NFS Nuclear Fuels Services NSWP Nuclear Station Work Procedure OOS Out of Service POR Public Document Room PlF Problem Identification Form PORC Plant Operating Review Committee PORV Power Operated Relief Valve RCFC Reactor Containment Fan Coolers RCS. Reactor Coolant System RH Residual Heat Removal System RSH River Screen House RWST Refueling Water Storage Tank SFP Spent Fuel Pool SI Safetyinjection SPP Special Plant Procedure SRO. Senior Reactor Operator SX Essential Service Water System TS Technical Specification UFSAR _ Updated Final Safety Analysis Report WR Work Request
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D) ton Generating Station -----O El.3 G I D N - y t 1%O North Griman Churth Ro.u! O hM#d ,
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October 6,1997 il ddist,__.
' "* S O! Y) LTR: BYRON 97-0227 - PeO OfMA Mr. John Acting Director, Division of Reactor Safety gy <g - U.S. Nuclear Regulatory Commission Region lll 801 Warrenville Road Lisle, IL 60532-4251 Reference: 1) Letter from John Grobe, U.S. N.R.C., to K. Graesser, Byron Station, Commonwealth Edison Company, dated June 11,1997.
2) Letter from K. Graesser, Byron Station, Commonwealth Edison Company, to John Grobe, U.S. N.R.C. dated July 25,1997.
Dear Mr. Grobe,
in Reference 1 you requested information on a matter raised with the NRC by an anonymous individual. Comed responded to your request for information in Reference 2. Reference 2 stated that the information in its attachment included sensitive, confidential information that should not be publicly disclosed.
Subsequently, in a telephone request by Mr Roger Lanksbury of your office to Don Brindle, Byron Station Regulatory Assurance Supervisor, on October 2, 1997 you requested that Comed remove the restriction on public disclosure in order to provide the information to a member of the public who desired to review it.
Byron Station will accommodate the request. Typically Empicyee Concerns Program investigations are kept confidential by Comed. We have reviewed the information in Reference 2 again and have determined that the information would , be acceptable to provide to the requesting individual. We would request that the } NRC provide a copy of the document only to the individual and will not make the document available for inspection and copying in the NRC Public Document Room.
If you have any questions related to this matter, please contact me at 815-234-3600.
/rj Sincerelly,
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K. i_.Gr es, er h ' Site Vice president Byron Nuclear Power Station lljggl]{{j{{][\]]l
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