IR 05000454/1998014
| ML20236W211 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 07/31/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20236W200 | List: |
| References | |
| 50-454-98-14, 50-455-98-14, NUDOCS 9808050155 | |
| Download: ML20236W211 (19) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION lli Docket Nos:
50-454: 50-455 Ucense Nos:
50-454/455-93014(DRP)
Licensee:
Commonwealth Edison Company Facility:
Byron Generating Station, Units 1 and 2 Location:
4450 N. German Church Road Byron,IL 61010 Dates:
May 31 - July 13,1998 Inspectors:
E. Cobey, Senior Resident inspector N. Hilton, Resident inspector
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B. Kemker, Resident inspector C. Thompson, Illinois Department of Nuclear Safety Approved by:
Michael J. Jordan, Chief Reactor Projects Branch 3 F
9800050155 980731 PDR ADOCK 05000454 G
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l EXECUTIVE SUMMARY Byron Generating Station Units 1 and 2 NRC Inspection Report 50-454/98014(DRP); 50-455/98014(DRP)
This inspection included aspects of licensee operations, maintenance, engineering, and plant support. The report covers a 6-week period of inspection activities by the resident staff.
Operations During the period from June 15 - 18,1998, three doors which formed a portion of the
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control room ventilation envelope were propped open on two occasions for approximately 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> each. Based on the failure to maintain a pocitive pressure in the main control room, the inspectors were concemed with the operability of the main control room ventilation system. The inspectors also believed that if the main control room ventilation envelope was operable, a safety evaluation should have been performed prior to propping open a main control room double-door vestibule. Furthermore, the inspectors concluded that corrective actions to a similar previous event were not adequate to prevent the recurrence. An unresolved item was issued. (Section O2.1)
On June 23,1998, an unexpected, minor reactor coolant system (RCS) temperature
transient (approximat6fy 1 degree Fahrenheit) occurred on Unit 2 due to operators misinterpreting Byron Operating Procedure (BOP) CV-6, " Operation of the Reactor Make-up System in the Borate Mode." The operators identified the unexpected response while monitoring plant parameters after performing a boration evolution. Appropriate operator response quickly restored the RCS temperature to normal. The inspectors concluded that the temperature transient was caused by an isolated knowledge weakness in accounting for the residual boric acid remaining in the make-up line combined with a misinterpretation of BOP CV-6. No violations were identified. (Section 04.1)
Maintenance / Surveillance The inspectors conduded that the observed maintenance activities were conducted well;
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specifically, procedures were followed; personnel were knowledgeable of work activities; and supervisors, system engineers, and quality control personnel were attentive to monitoring work iri progress. However, the inspectors concluded that the licensee did not control as a temporry alteration the installation of a portable pumping system in the nonsafety-related chemical feed system for the essential senrice water system. No violation of regu'atory requirements occurred. (Section M1.1)
The inspectors concluded that each of the observed surveillance tests were performed
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well. Specifically, the surveillance tests satisfied the requirements of Technical Specifications and each of the tested components met their respective acceptance criteria and remained operable. The inspectors noted very good material condition of the equipment in the plant, the exceptions being the OA control room ventilation make-up fan that tripped on low flow due to a discharger damper control circuit problem and the safety injection pump that had high discharge header pressure due to leakage past the reactor coolant system. (Section M1.2)
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l Enaineerina The inspectors concluded that neither the spent fuel pool cooling system suction piping
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nor the skimmer discharge piping contained a design feature to prevent inadvertent draining below 423 feet 2 inches, as required by Technical Specification 5.6.2. The spent fuel pool cooling suction connections were located at approximately 417 feet 9 inches and the skimmer discharge line discharged at approximately 418 feet. A violation was cited.
(Section E8.1)
Plant SuDDort The inspectors concluded that the operators were adversely impacted in performing
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rounds by the amount of contaminated area in the Auxiliary Building, most notably in the emergency core cooling system equipment rooms. The licensee initiated corrective action to reduce contaminated areas to allow for easier operator rounds. In addition, the inspectors noted two tygon hoses crossed a contaminated area barrier and were not fastened at the barrier to preclude the spread of contamination. Licensee verified that spread of contamination did not occur. (Section R1.1)
The inspectors concluded that the licensee's control of transient combustible material
was significantly improved from previous inspection. (Section F8.1)
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Report Details
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Summary of Plant Status The licensee operatad both Units 1 and 2 at or near full power for the duration of the inspection period.
1. Operations
Conduct of Operations I
O1.1 General Comments (71707)
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The inspectors routinely observed plant operations. In general, the conduct of operations from the control room were performed i. a professional manner. Specifically, operators maintained the control rovm decorum by effectively controlling the activity level and the number of personnelin each unit's operating area. Operators also responded i
appropriately to alarms by announcing the alarm and reviewing the annunciator response l
procedure if the alarm was unexpected. In addition, operators closely monitored main
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control room panels and were knowledgeable of plant conditions.
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Operational Status of Facilities and Equipment 02.1 Operability of Main Control Room Ventilation Envelope
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Inspection Scope (71707 and 37551)
The inspectors reviewed the licensee's process which allowed main control room doors to l
be propped open to supply cooling ventilation to adjacent spaces. The inspectors j
reviewed the following documents: Byron Adminis. stive Procedure (BAP) 1100-3, " Fire l
Protection Systems, Fire Rated Assemblies, Ventilation Seals, Flood Seals, and Water l
i Tight Doors impairments"; Barrier / Fire Protection impairment Permits 1231,1648, and l
1649; Technical Specifications (TS); the Updated Final Safety Analysis Report (UFSAR);
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Problem Identification Forms (PIFs) B1998-03007, B1998-03208, B1998-02991, and
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B1998-02988; the sequence of events recorder for June 15 through 18,1998; and an i
operations daily order titled " Main Control Room Door," dated June 16,1998. The l
inspectors also discussed the issues with operations and engineering department
personnel.
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Observations and Findinas On June 15,1998, the process computer room doors for Units 1 and 2 were propped opened to provide ventilation for the process computers while both trains of the miscellaneous auxiliary ventilation (VV) sy2 tem, which normally provided cooling for the process computers and control room office spaces, were out-of-service for maintenance.
The inspectors noted that the computer room doors were part of the control room envelope, which provided a boundary to maintain a positive pressure in the main control room. The inspectors reviewed the sequence of events recorder (SER) and noted that the " Main Control Room Pressure - Low" annunciator actuated at 9:21 a.m.,
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approximately the same time the operating logs indicated that the computer room doors I
were propped open. The next moming, at approximately 9:00 a.m. on June 16,1998, the door (SD171) between the main control room and the control room offices was also propped open to provide cooling to the control room offices. As a compensatory measure, an operations department daily order was prepared on June 16 which provided l
Instructions to shut the control room doors if a design basis accident occurred. At about 4:15 p.m. on June 16, after approximately 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, all three doors in the main control room envelope were shut and the main control room low pressure alarm cleared.
On June 17,1998, a main control room ventilation (VC) radiation monitor failed. The operators isolated the control room ventilation system as required by TS 3.3.3. As part of the isolation of the control room ventilation, the non-safety-related W system was shut down. Due to the loss of cooling for non-safety-related spaces, the operators again propped open the two computer room doors at 3:50 a.m. At 1:35 p.m., Door SD171 was also propped open to provide cooling to the control room offices. The inspectors noted that with the doors open, positive pressure was not maintained in the main control room as described in the UFSAR. At approximately 3:30 p.m. on June 18, after approximately 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br />, all three doors were shut and the control room envelope restored to a normal configuration.
A barrier / fire protection system impairment permit, BAP 1100-3T1, was not completed for a,ny of the three blocked open doors from June 15 through 16. The licensee completed barrier impairment permits on June 17, after the doors were propped open the second time. The inspectors noted during a review of PlF B1998-02988, dated June 16,1998, that one of the licensee identified issues was that barrier impairment permits for the doors had not been completed prior to the scheduled start of the work. However, the licensee's apparent cause evaluation and corrective actions failed to considJr the failure to complete the permits as required by BAP 1100-3. The actions were limited to other issues identified on the same PlF.
The inspectors were concemed that corrective actions taken by the licensee in response to a previous event conceming improper use of impairment permits, discussed in NRC inspection Report 50-454/98011; 50-455/98011 and Licensee Event Report tLER) 50-455/98005, had not been effective in preventing a recurrence. At the end of the inspection period, the licensee was reviewing the adequacy of previous corrective actions regarding implementation of the ventilation barrier permit program.
On July 10,1998, the Nuclear Oversight Manager issued a stop work order on any work activities that involved ventilation barriers or seals. The stop work order was issued due to inadequate provisions in BAP 1100-3 to properly evaluate the effect of work on the safety function of ventilation seals. The Nuclear Oversight Manager also concluded that BAP 1100-3 did not assure that adequate compensatory measures would be implemented when ventilation seals were degraded. The Nuclear Oversight Manager stated that there was no ventilation seal work in progress when the stop work order was issued.
The inspectors also questioned the operability of the VC system during both periods of time that the control room envelope doors were propped open. Two independent trains of control room ventilation systems were required to be operable by TS 3.7.6, " Control Room Ventilation System." Technical Specification Surveillance Requirement 4.7.6.e.3
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required that at least once per 18 months, a positive pressure greater than or equal to 0.125 inch water gauge relative to ambient pressure in areas adjacent to the control room
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be demonstrated with the VC system operating in make-up mode. In addition,
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Sections 6.4.2.3 and 9.4.1.1 of the UFSAR stated, in part, that the control room envelope l
was to be maintained at approximately 0.125 inches of water column positive pressure j
with respect to the surrounding areas. The inspectors noted that the main control room low pressure annunciator set point was 0.125 inches of water with a 30 second time
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delay. From approximately 1:00 p.m. until 3:00 p.m. on June 16,1998, VC was run in the make-up mode for an unrelated surveillance test and the main control room pressure low i
annunciator did not clear. Additionally, during the entire second period from June 17 j
though 18, the operating VC train was in make-up mode with the main control room low pressure annunciator locked-in. The licensee indicated that the VC system was operable based on the capability of the operators to take compensatory action and shut the control room envelope doors during a design basis accident.
The licensee believed that the ventilation barrier impairment permits were adequate administrative control as described in the UFSAR and therefore a safety evaluation was not required. However, the inspectors believed, after initial review, that if both trains of VC were actually operable, a safety evaluation should have been performed prior to propping open the double-door vestibule and allowing the positive pressure in the main control room to be removed.
This issue is considered an Unresolved item (50-454/455-98014-01(DRP)) pending additional NRC review of the operability of the VC system, the applicability of the safety evaluation process, and the licensee's implementation of the ventilation barrier
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impairment process.
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Conclusions i
During the period from June 15 - 18,1998, three doors which formed a portion of the control room ventilation envelope were propped open on two occasions for approximately 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> each. Based on the failure to maintain a positive pressure in the main control room, the inspectors were concemed with the operability of the main control room ventilation system. The inspectors also believed that if the main control room ventilation envelope was operable, a safety evaluation should have been performed prior to propping open a main control room double-door vestibule. Furthermore, the, inspectors concluded that corrective actions to a similar previous event were not adequate to prevent the recurrence. An unresolved item was issued.
Operator Knowledge and Performance 04.1 Unit 2 Reactor Coolant System Temperature Transient a.
Inspection Scope (71707)
The inspectors observed a minor Unit 2 temperature transient and subsequently reviewed l
Byron Operating Procedure (BOP) CV-6, " Operation of the Reactor Make-up System in j
the Borate Mode," Revision 9 and BOP CV-7, " Operation of the Reactor Make-up System in the Auto Make-up or Manual Mode," Revision 9. The inspectors also interviewed operators, and operations and system engineering management.
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Observations ar'd Findinas On June 23,1g98, the inspectors noted that the reactor coolant system (RCS) average temperature was approximately one degree higher than the reference temperature. The inspectors also noted that the temperature trend for the previous 15 minutes had been increasing. When questioned, both the nuclear station operator (NSO) and the unit supervisor (US) were aware of the temperature increase and were preparing to add boric acid to reduce the average temperature to normal. The inspectors observed the operators properly restore temperature to the reference temperature.
The operators noted that the shift tumover indicated that the boric acid line had m P@.
flushed with primary water following the previous boration, as allowed by BOP CV G.
Soon after shift tumover, and prior to the volume control tank (VCT) receiving an automatic make-up signal, the operators decided to manually add water to the VCT,,.
i accordance with BOP CV-7. An attempt was made to compensate for the residual boric acid. However, the operators assumed that 15 gallons of scid remained in the line based on BOP CV-6 guidance to flush 15 gallons of primary water if flushing was desired.
Based on the assumption of 15 gallons of boric acid, the operators determined that 85 gallons of primary water were required to compensate for the residual boric acid.
However. after the addition of the 85 gallons of water, an unexpected increase in RCS iempereture was observed by the operators.
The inspectors determined that there was actually approximately 3 gallons of residual boric acid remaining in the make-up line following the previous boration. The inspectors calculated, and the licensee agreed, that the plant RCS temperature response was as expected if 85 gallons of primary water and 3 gallons of boric acid were added to the RCS. Both the licensee and the inspectors concluded that both the NSO and US made an incorrect assumption conceming the amount of residual boric acid in the make-up line.
The inspectors questioned severu NSOs regarding ths volume of boric acid remaining in the make-up piping after borating the RCS. Each of the NSOs estimated between 3 and 7 gallons remained. Based on these interviews, the inspectors concluded that the knowledge weakness demonstrated by the involved operators was an isolated example.
The NSOs that were interviewed also noted the step in BOP CV-6 indicated that 15 gallons of primary water was to be flushed, if desired, and did not specifically identify the amount of boric acid that would remain in the make-up line if the flush was not performed. At the end of the inspection period, operations management planned to clarify the procedure step to ensure that an accurate estimate of boric acid would be provided.
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Conclusions On June 23,1998, an unexpected, minor reactor coolant system (RCS) temperature transient (approximately 1 degree Fahrenheit) occurred on Unit 2 due to operators misinterpreting Byron Operating Procedure (BOP) CV-6, " Operation of the Reactor Make-up System in the Borate Mode." The operators identified the unexpected response while monitoring plant parameters after performing a boration evolution. Appropriate operator response quickly restored the RCS temperature to normal. The inspectors concluded that the temperature transient was caused by an isolated knowledge weakness in
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accounting for the residual boric acid remaining in the make-up line combined with a misinterpretation of BOP CV-6. No violations were identified.
Miscellaneous Operations issues (92700,92901)
O8.1 (Closed) Violation 50-454/455-97002-01(DRP)): " Failure to Follow a Procedure for the Release Tank Transfer to 22,000 Gallon Regen Waste Drain Tank." On February 17, 1997, the inspectors identified that the radwaste operator did not monitor the release tank and the regenerative waste drain tank level recorders during the transfer of liquid radioactive waste from the release tank to the regenerative waste drain tank. The licensee confirmed that the procedure was not followed nor was completion of procedural steps verified to ensure that all steps were properly performed. Furthermore, the licensee recognized that lower standards existed for local panel monitoring than for main control room panel monitoring. Operators at the radwaste panel were allowed to rely on alarms to take actions rather than closely monitor indications and chart recorders.
The inspectors reviewed the licensee's corrective actions to check for any notable weaknesses. No weaknesses were identified and the corrective actions were found to be acceptable. This violation is closed.
08.2 (Closed) LER 50-454/96011-00 and 01: " Manual Reactor Trip due to Loss of Instrument Air to Feedwater Preheater Bypass isolation Valve." This event was discussed in NRC Inspection Report 50-454/96005(DRP); 50-455/96005(DRP). The licensee's original LER described the event. The supplement to the LER included additionalinformation regarding the failure mechanism of the instrument air tubing. The inspectors reviewed the licensee's corrective actions and noted that since this event no additional failures have occurred. This LER and the supplement are closed.
09.3 (Closed) LER 50-454/96010: " Manual Reactor Trip due to Failed Circuit Card in the Digital Rod Position Indication System." On June 25,1996, the licensee was conducting Surveillance Test 1BVS 1.3.3-1, " Digital Rod Position Indication (DRPI) Operability Checkout,"in preparation for a Unit 1 startup. Unit 1 was in Mode 4, Hot Shutdown.
During the test, operators noted that Control Rod F-06 in Control Bank C briefly indicated 150 steps withdrawn while the remainder of Control Bank C was at 143 step. Operators decided to insert the control bank. With Control Bank C at approximately 48 steps, rod F-06 briefly indicated " rod at bottom," then retumed to 48 steps. In accordance with the surveillance test procedure, operators manually trip,ned the reactor. The licensee's troubleshooting identified that an electronic card for Rod F-06 was defective. After replacing the card, the surveillance test was successfully completed. This LER is closed.
08.4 (Closed) LER 50-454/960.0_9: "Si (Safety injection 1 P :mp Exceeds Maximum Flow due to Change in Test Method to Better Model Post i Conditions." During a post
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maintenance test for emergency core cooling system flow verification on May 7,1996, the I
licensee identified that the 1B Si pump provided a maximum flow of 657.8 gallons per
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minute (gpm). Technical Specification 4.5.2.h.2(b) required a maximum flow for a single Si pump of 655 gpm. The licensee's investigation revealed that the cause of the event was an inadequate procedure that failed to anticipate an increase in pump flow when the l
test method was changed. The test change altered the SI system lineup such that the j
suction of the SI pumps was supplied from the operating residual heat (RH) removal pumps instead of directly from the reactor water storage tank. The system lineup change
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more accurately modeled expected accident parameters during the recirculation phase of an accident; however, the increased suction pressure supplied by the RH pumps also increased total flow approximately 4 gpm. Consequently the Si flow was greater than that allowed by TS 4.5.2.h.2(b).
The inspectors' review of the UFSAR and TS basis indicated that the maximum flow limit was to protect the SI pumps from runout conditions during the limiting condition of an accident. The limiting condition occurred when the minimum net positive suction head (NPSH) was supplied to the SI pumps, a condition that occurred when there was minimum level in the refueling water storage tank, at switchover from injection mode to recirculation mode. Therefore, when the RH pumps provided the suction pressure for the Si pumps, NPSH was significantly greater than the minimum NPSH and reduced the possibility of cavitation at high flow rates. The inspectors concluded that the event had minimal safety significance. The licensee corrected the procedure, performed a complete emergency core cooling system flow balance and retumed the maximum flow to within TS requirements. The inspectors concluded the licensee failed to maintain the maximum Si flow less than 655 gpm in accordance with TS 4.5.2.h.2(b). However, this failure constitutes a violation of. minor significance and is not subject to formal enforcement action. This LER is closed.
11. Maintenance M1 Conduct of Maintenance M1.1 Maintenance Observations a.
inspection Scope (62707)
The inspectors interviewed maintenance, operations, quality control, and engineering department personnel and observed selected portions of the following work requests (WR).
applicable, the inspectors also reviewed TS and the UFSAR.
WR 960C.
Replace Leaking 3/4 Inch Drain Line on the 1 A Component
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Cooling Water (CC) Pump Casing WR 970028806-01 Unit 0 Component Cooling Water Heat Exchanger Open
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and Clean Heat Exchanger WR 970028806-02 Essential Service Water (SX) Drain Temporary Piping
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Connection install Roger Mobil (Portable Pumping System]
to Support Heat Exchanger Work b.
Observations and Findinas Unit 0 CC Heat Exchanaer Maintenance On June 22,1998, the inspectors observed the temporary installation of a portable
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pumping system to facilitate draining the tube side of the CC heat exchanger to the SX l
system via the chemical feed (CF) system. A modification, M6-1-91-004, had been made to the CF system design in 1992. The modification added a tee connection with a valve and a blind flange downstream of the CF system isolation valve to the SX system
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The inspectors reviewed the licensee's procedural requirements for controlling temporary alterations to plant systems in Byron Administrative Procedure (BAP) 330-2, " Temporary l
l-l Alterations," Revision 15 and documentation associated with Modification M6-1-91-004.
The inspectors considered the temporary installation of the portable pumping system to be a temporary alteration of the system's configuration since it met the definition of BAP 330-2 and the portable pumping system was specifically excluded from the 1992 design modification description. The inspectors discussed the issue with licensee management. The licensee concluded that the connection of the portable pumping
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system did not constitute a temporary alteration to the system because the 1992 l
modifications which installed the permanent connections to the CF and SX systems were l
designed, installed, and tested specifically for the purpose of connecting the portable pumping system.
The temporary installation of the portable pumping system was installed in the l
non-safety-related portion of the CF and SX systems; therefore, no violation of regulatory l
requirements occurred. However, the inspectors were concemed since the same process and procedure were used for the installation of temporary alterations to.
safety-related systems. At the end of the inspection period, the licensee planned the following corrective actions: (1) complet,on of a design change request to change the applicable piping and instrumentation drawings to reflect the temporary installation of the portable pumping system; (2) creation of a new procedure to control the installation and removal of the portable pumping system to the CF and SX systems; and (3) revision of j
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BAP 330-2 which willidentify the portable pumping system connection as a specific
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exception to control as a temporary alteration.
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Conclusions L
The inspectors concluded that the observed maintenance activities were conducted well; I
specifically, procedures were followed; personnel were knowledgeable of work activities; l
and supervisors, system engineers, and quality control personnel were attentive to monitoring work in progress. However, the inspectors also concluded that the licensee did not control, as a temporary alteration, the installation of a portable pumping system in the nonsafety-related chemical feed system for the essential service water system, No
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violation of regulatory requirements occurred.
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M1.2 Surveillance Test Observations
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a.
Inspection Scope (61726)
The inspectors interviewed operations and engineering personnel, reviewed the completed test documentation, and observed the performance of selected portions of the j
following surveillance test procedures.
1BOS 7.1.2.1.b-1 Unit One Motor Driven Auxiliary Feedwater Pump Monthly
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Surveillance
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2BOS 3.2.1-870 Unit Two ESFAS [ Engineered Safety Feature Actuation
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Signal] instrumentation Slave Relay Surveillance (Train B Containment isolation Phase B - K618, K626)
2BOS 3.2.1-921 Unit Two ESFAS instrumentation Slave Relay Surveillance
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(Train A Turbine Trip - K640)
2BOS 3.2.1-931 Unit Two ESFAS Instrumentation Slave Relay Surveillance e
(Train B Turt>ine Trip - K640)
2BOS 7.1.2.1.b-2 Unit Two Diesel Driven Auxiliary Feedwater Pump Quarterly
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Surveillance 1BVS 5.2.f.2-1 Unit One ASME Surveillance for Safety injection Pump
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Conclusions The inspectors concluded that each of the observed surveillance tests were performed I
well. Specifically, the surveillance tests satisfied the requirements of TSs; and each of the tested components met their respective acceptan,e criteria and remained operable.
The inspectors noted very good material condition for the equipment in the plant, the exceptions being the OA control room ventilation make-up fan that tripped on low flow due to a discharger damper control circuit problem and the safety injection pump that had high y
discharge header pressure due to leakage past the reactor coolant system check valves.
J M8 Miscellaneous Maintenance issues M8.1 (Closed) Violation 50-454/455-97002-04(DRP): " Failure to Meet Action Statement for TS 3.5.2 Emergency Core Cooling System (ECCS) Inoperability." From December 1985 to February 1997, with Unit 1 in Modes 1,2, and 3, the 1 A residual heat removal pump l
was inoperable as a result of improper maintenance on the pump. The action statement i
. required that with one ECCS subsystem inoperable, the licensee must restore the
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inoperable subsystem to operable within 7 days or be in hot standby within the next l
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. During this time, action was not taken to restore the inoperable ECCS subsystem to operable within 7 days or be in hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
The inspectors reviewed the licensee's corrective actions to check for any notable weaknesses. No weaknesses were identified and the corrective actions were found to be acceptable. This violation is closed.
M8.2 (Closed) Violation 50-454/455-97002-05(DRP): " Failure to Meet Action Statement for Technical Specification 3.6.2.1 Containment Spray System inoperability." From 1986 to February 1997, with Unit 1 in Modes 1,2, 3, and 4, the 1B containment spray pump was inoperable as a result of improper maintenance on the pump. The action statement required that with one containment spray system inoperable, the licensee must restore
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the inoperable containment spray system to operable within 7 days or be in hot standby
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within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. During this time, action was not taken to restore the inoperable containment spray system to operable within 7 days or be in hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
The inspectors reviewed the licensee's corrective actions to check for any notable weaknesses. No weiknesses were identified and the corrective actions were found to be acceptable. This violation is closed.
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M8.3 (Closed) LER 50-455/95004-00: " inadequate Diesel Generator Post Maintenance Testing due to Management Deficiency." On August 15,1995, the licensee identified that the voltage regulator for the 2B diesel generator (DG) had been replaced on December 26, 1990, and December 19,1991, and the post maintenance testing did not verify that the voltage regulator would have performed satisfactorily under transient loading conditions in the emergency mode of operation. On March 24,1992, the voltage regulator for the 28 DG was satisfactorily tested by the performance of Byron Engineering Surveillance (BVS) 8.1.1.2.f-16, " Unit 2 2B Diesel Generator Safe Shutdown Sequencer and Singlo Load Rejection Test - 18-Month," Revision 4, and BVS 8.1.1.2.f-14, " Unit 2 2B Diesel Generator 24 Hour Load Run and Sequencer Test - 18 Month," Revision 3.
The licensee determined that the root cause of this issue was a management deficiency, in that, personnel failed to recognize the potential operability impact of voltage regulator adjustments, repairs, and replacements. As a result, the post maintenance testing l
inadequately verified the performance of the 2B DG in the emergency mode of operation.
10 CFR Part 50, Appendix B, Criteria XI, " Test Control," specifies, in part, that a test
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program shall be established to assure that all testing required to demonstrate that i
structures, systems, and components will perform satisfactorily in service is identified and l
performed in accordance with written test procedures which incorporate the requirements l
and acceptance limits contained in applicable design documents. The failure to perform post maintenance testing on the 2B DG, following replacement of the voltage regulator, to ensure that the diesel generetor would perform satisfactorily under transient loading conditions in the emergency mode of operation was a violation of 10 CFR Part 50, Appendix B, Criteria XI. This non-repetitive, licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforce. ment Policy (50-455/98014-02(DRP)).
The inspectors reviewed the licensee's corrective actions and found them to have been acceptable. This LER is closed.
Ill. Enaineerina E8 Miscellaneous Engineering issues (92903)
E8.1 (Closed) Unresolved item 50-454/455-93011-10: " Spent Fuel Pool Cooling Suction Lines and Skimmer Design." This issue involved the spent fuel pool design to prevent inadvertent draining below elevation 423 feet 2 inches and was documented in NRC Inspection Report 50-454/98011; 50-455/98011. Technical Specification 5.6.2 stated that the spent fuel storage pool was designed and shall be maintained to prevent inadvenient draining of the pool below elevation 423 feet 2 inches. The inspectors noted that both the l
cooling system suction piping and the skimmer discharge piping did not contain a design j
feature to prevent inadvertent draining below 423 feet 2 inches, typically an anti-siphon dsvice. The spent fuel pool cooling suction connections were located at approximately I
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417 feet 9 inches and the skimmer discharge line discharged at approximately 418 feet.
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referenced in TS 5.6.2 was a low level alarm that actuated at 424 feet 2 inches and various make-up sources that would be initiated by operators in response to the annunciator alarm procedure prior to reaching 423 feet 2 inches. The. inspectors did not
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agree with the licensee's conclusion that the alarm and operator action constituted a design feature. Therefore, the inspectors concluded that the failure to incorporate a design feature into the spent fuel pool cccling suction lines was an example of a violation of TS 5.6.2 (50-454/455-98014-03a(DRP)) and the failure to incorporate a design feature into the skimmer discharge line was an additional example of a violation of TS 5.6.2 (50-454/455-98014-03b(DRP)). This Unresolved item is closed.
E8.2 (Closed) LER 50-454/97023-00 and 01: "1B Diesel Generator Control Power Wiring Discrepancy due to a Modification Installation Error and Program Deficiencies." This issue was discussed in NRC inspection Report 50-454/98004(DRS); 50-455/98004(DRS)
and resulted in Violation 50-454/98004-04(DRS); 50-455/98004-04(DRS). The licensee's corrective actions will be evaluated during the inspectors review of the licensee's response to the violation. This LER and the supplement are closed.
E8.3 (Closed) LER 50-454/96019-05: " Ultimate Heat Sink Outside Design Basis due to Silt and Calculation Errors." This event was discussed in NRC inspection Repor150-454/96009(DRP); 50-455/96009(DRP) and resulted in several violations.
These violations were subsequently closed in NRC Inspection Reports 50-454/97015(DRP); 50-455/97015(DRP) and 50-454/98004(DRS);
50-455/98004(DRS). The supplemental LER provided additionalinformation regarding corrective action implementation, which did not change the description of the event nor would it affect the previously cited violations. This LER supplement is closed.
IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Radiological Conditions of the Auxiliary and Fuel Handlina Buildinas a.
inspection Scope (71750)
The inspectors routinely observed the status of radiologically controlled areas (e.g., radiologically posted areas, radiation areas, and radiologically contaminated areas)
in the Auxiliary and Fuel Handling Buildings. The inspectors interviewed operators and radiation protection personnel and reviewed the following procedures:
BRP 5000-7, " Unescorted Access to and Conduct in Radiologically Posted Areas,"
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Revision 7 BRP 5010-1, " Radiological Posting and Labeling Requirements," Revision 15
" Radiation Worker Handbook," Revision 1
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b.
Observations and Findinas During routine inspections in the Auxiliary and Fuel Handling Buildings, the inspectors noted that the cleanliness and housekeeping had improved since the completion of the refueling outage in May 1998. The licensee's plan for the cleanup and removal of rnaterial from the auxiliary building was scheduled to be completed by August 21,1998.
The inspectors also noted that most emergency core cooling system (ECCS) equipment rooms were contaminated. Consequently, the operators were adversely impacted by the
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necessity of having to repeatedly dress out in protective clothing during the performance of rounds, in response to the inspectors concems, the licensee provided additional focus on decontamination efforts which reduced the impact on the operators by the end of the inspection period. The decontamination of the ECCS equipment rooms wss scheduled to be completed by July 27,1998.
In addition, the inspectors identified that radiological postings and barriers were in place in accordance with procedural requirements. However, the inspectors identified one example of a radiological barrier that did not meet the standards and expectations delineated in the Radiation Worker Handbook, Revision 1. Specifically, two tygon hoses crossed a contantinated area barrier associated with a contaminated area in the Unit 2 Spray Additive T::nk Room and Pipe Penetration Area and were not fastened at the barrier. Consequently, the hoses were free to move across the barrier and created the potential for contamination to be spread from the contaminated area to the adjacent clean area. In response to the inspectors concems, the licensee secured the hoses at the barrier and verified that the spread of contamination had not occurred.
c.
Conclusions The inspectors concluded that the operators were adversely impacted in performing rounds by the amount of contaminated area in the Auxiliary Building, most notably in the emergency core cooling system equipment rooms. The licensee initiated corrective action to reduce the contaminated areas to allow for easier operator rounds. In addition, the inspectors noted two tygon hoses crossed a contaminated area barrier and were not fastened at the barrier to preclude the spread of contamination. Licensee verified that spread of contamination did not occur.
R8 Miscellaneous RP&C lssues R8.1 Postina of Notices to Workers (71750)
On June 26,1998, the inspectors reviewed the licensee's posting of required documents in accordance with 10 CFR 19.11, such as NRC Form 3, " Notice to Employees," the operating license, and notices of violation involving radiological working conditions.
10 CFR 19.11(d) required, in part, that documents, notices, or forms posted pursuant to this section shall appear in a sufficient number of places to permit individuals engaged in licensed activities to observe them on the way to or from any particular licensed activity location to which the document applied. The licensee identified to the inspectors three locations where NRC Form 3 was posted. The other required documents were posted in a single location; specifically the service building lobby. The inspectors and licensee concurred that these locations were not sufficient to permit all individuals engaged in
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licensed activities, specifically maintenance department personnel and visiting contractor personnel, to observe them on the way to or from their particular licensed activity.
The failure to post the required documents, such as NRC Form 3, the operating license, and notices of violation involving radiological working conditions in accordance with 10 CFR 19.11(d) constitutes a violation of minor significance and is not subject to formal enforcement action. At the end of this inspection period, the licensee had committed to i
i the following corrective actions: review and administratively control all required postings; l
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and, provide a central posting location in the gatehouse where all individuals engaged in licensed activities entering the protected area will be permitted to observe them.
F8 Miscellaneous Fire Protection issues (71750)
F8.1 (Open) Violations 50-454/455-98005-05a and 05b: " Failure to Control Transient Combustible Materials." During this inspection period, the inspectors did not identify any examples of a failure to comply with the transient combustible material control program.
On several occasions, additional flammable material storage cabinets and self-closing trash cans were noted throughout the plant. At the end of the inspection period, the licensee was continuing to implement corrective actions for these violations. Therefore, although the inspectors noted significant performance improvement, these violations will remain open pending the completion and review of the licensee's corrective actions.
l V. Manaaement Meetinos X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on July 13,1998. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
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PARTIAL LIST OF PERSONS CONTACTED Licensee K Graesser, Site Vice-President D. Wozniak, Acting Byron Station Manager J. Bauer, Health Physics Supervisor D. Brindle, Regulatory Assurance Supervisor E. Campbell, Maintenance Superintendent T. Gierich, Operations Manager T. Schuster, Site Nuclear Oversight Manager M. Snow, Work Control Superintendent B. Kouba, Engineering Manager
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INSPECTION PROCEDURES USED IP 37551:
Onsite Engineering IP 61726:
Surveillance Observations IP 62707:
Maintenance Observation IP 71707:
Plant Operations IP 71750:
Plant Support Activities IP 92700:
Onsite Follow-up of Written Reports of Nonroutine Events at Power Reactor Facilities IP 92901:
Follow-up Operations IP 92902:
Follow-up Maintenance IP 92903:
Follow-up Engineering ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-454/455-98014-01 URI main control room ventilation envelope operability 50-455-98014-02 NCV failure to perform post maintenance test on 2B DG 50-454/455-98014-03a VIO TS 5.6.2 failure to incorporate design feature into SFP cooling suction line 50-454/455-98014-03b VIO TS 5.6.2 failure to incorporate design feature into SFP skimmer discharge line Closed 50-455-98014-02 NCV failure to perform post maintenance test on 28 DG 50-454/455-97002-01 VIO Failure to Follow a Procedure for the Release Tank Transfer to 22,000 Gallon Regen Waste Drain Tank 50-454/96011-00 LER Manual Reactor Trip due to Loss of Instrument Air to Feedwater Preheater Bypass isolation Valve 50-454/96011-01 LER Manual Reactor Trip due to Loss of Instrument Air to Feedw.ater Preheater Bypass isolation Valve 50-454/96010 LER Manual Reactor Trip due to Failed Circuit Card in the Digital Rod Position Indication System 50-454/96009 LER St Pump Exceeds Maximum Flow due to Change in Test Method to Better Model Post Accident Conditions 50-454/455-97002-04 VIO Failure to Meet Action Statement for TS 3.5.2 ECCS Inoperability
50-454/455-97002-05 VIO Failure to Meet Action Statement for TS 3.6.2.1 l
Containment Spray System inoperability l
50-455/95004 LER Inadequate Dissel Generator Post Maintenance Testing
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50-454/455-98011-10 URI Spent Fuel Pool Cooling Suction Lines and Skimmer l
Design
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50-454/97023-00 LER 1B DG Control Power Wiring Discrepancy 50-454/97023-01 LER 1B DG Control Power Wiring Discrepancy 50454/96019-05 LER UHS Outside Dissign Basis due to Silt and Calculation Errors
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DSoussed 50-454/455-98005-05a VIO Failure to Control Transient Combustible Materials 50-454/455-98005-05b VIO Failure to Control Transient Combustible Materials
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LIST OF ACRONYMS USED BAP Byron Administrative Procedure BHP Byron Electrical Maintenance Procedure BMP Byron Mechanical Maintenance Procedure BOP Byron Operating Procedure BOS Byron Operating Surveillance BRP Byron Radiological Protection Procedure BVS Byron Engineering Surveillance CC Component Cooling Water l
CF Chemical Feed System i
CFR Code of Federal Regulations l
DG Diesel Generator DRP Division of Reactor Projects l
DRPl Digital Rod Position Indication DRS Division of Reactor Safety
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ECCS Emergency Core Cooling System
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GPM Gallons per Minute IFl inspector Follow-up item l
LCO Limiting Condition for Operation l
LCOAR Limiting Condition for Operation Action Requirement LER 1.icensee Event Report NCV Non-cited Violation
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NPSH Net Positive Suction Head l
NOD Nuclear Operating Division l
NRC Nuclear Regulatory Commission NSO Nuclear Station Operator PDR Public Document Room PIF Problem identification Form RCS Reactor Coolant System RH Residual Heat Removal j
l RP Radiological Protection l
l RP&C Radiological Protection and Chemistry
SER Sequence of Events Recorder
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SFP Spent Fuel Pool l
SI Safety injection i
SM Shift Manager.
l SRO Senior Reactor Operator SX Essential Service Water System j
TS Technical Specification l
UFSAR Updated Final Safety Analysis Report l
l US Unit Supervisor l
VC Main Control Room Ventilation i
VCT Volume Control Tank j
VIO Violation W
Miscellaneous Auxiliary Ventilation WR Work Request
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