IR 05000454/1998019
| ML20155D225 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 10/29/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20155D218 | List: |
| References | |
| 50-454-98-19, 50-455-98-19, NUDOCS 9811030161 | |
| Download: ML20155D225 (19) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION lli Docket Nos: 50-454;50-455 License Nos: NPF-37; NPF-66 Report No: 50-454/455-98019(DRP)
Licensee: Commonwealth Edison Company Facility: Byron Generating Station, Units 1 and 2
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Location: 4450 N. German Church Road Byron,IL 61010 Dates: August 25 - October 5,1998 inspectors: E. Cobey, Senior Resident inspector N. Hilton, Resident inspector B. Kemker, Resident inspector 4 T. Tongue, Project Engineer C. Thompson, Illinois Department of Nuclear Safety Approved by: Michael J. Jordan, Chief Reactor Projects Branch 3 9811030161 981029 PDR ADOCK 05000454 G PDR -
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l EXECUTIVE SUMMARY l Byron Generating Station Units 1 and 2 '
NRC inspection Report 50-454/98019(DRP); 50-455/98019(DRP)
This inspection included aspects of licensee ope.ations, maintenance, engineering, and plant I support. The report covers a 6-week period of inspection activities by the resident staff and region based inspector Operations
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The inspectors concluded that the operator performance during the isolation of System Auxiliary Transformer 142-1 was good. The heightened level of awareness briefings were generally good with some minor weaknesses noted. (Section 01.1) l
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The inspectors concluded that configuration control events continued to occur during this inspection period. The inspectors noted that the licensee was aggressively
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identifying configuration controlissues and planning numerous corrective actions to arrest the trend of configuration control events. While some corrective actions had been initiated and completed, the licensee had not yet approved and implemented a comprehensive corrective action plan. (Section O2.1)
- The inspectors concluded that during the performance of Byron Operating Surveillance 3.2.1-901," Unit Two ESFAS [ Engineered Safety Feature Actuation Signal)
Instrumentation Slave Relay Surveillance (Train A Steam Line Isolation - K623),"
Revision 2, a nuclear station operator (NSO) did not meet licensee management
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expectations for self-checking and peer-checking, which resulted in the NSO manipulating the wrong test switch during the surveillance test. Consequently, an unexpected engineered safety feature actuation of containment spray valves occurre A Non-Cited Violation was issued. (Section 04.1)
Maintenance / Surveillance
The inspectors concluded that observed maintenance activities were generally well conducted. However, the inspectors concluded that non-station Commonwealth Edison maintenance personnel had not been fully integrated into the licensee's maintenance department. Specifically, substation department personnel replaced a bushing on a Unit 1 system auxiliary transformer without a written procedure, contrary to the
! expectations of senior station management. No violations were identifie (Section M1.1)
- The inspectors concluded that the observed surveillance tests were performed wel Specifically, the surveillance tests met the requirements of Technical Specification (TS);
and each of the tested components met their respective acceptance criteria and l remained operabl (Section M1,2)
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- The inspectors concurred with the licensee's finding that on February 18,1997, the Unit 1 equipment hatch gallery was not seismically secured to the containment structure
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i-due to an inadequate maintenance procedure and a lack of a questioning attitude on the part of procedure writers and reviewers, work analysts, job supervisors, and workers performing the activity. A Non-Cited Violation was issued. (Section M8.2)
Plant Support
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Several uncontrolled radioactive material events involv,ing low contamination levels had been identified by the licensee and a root cau'se investigation of the adverse trend was l conducted, in addition to specific corrective actions for each event, the licensee
! identified several broad corrective actions for greater awareness and accountability that l were either implemented or planned to be implemented at the end of the inspection l period. The inspectors considered the corrective actions acceptable. (Section R1.1)
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Report Details l
Summary of Plant Status The licensee operated Unit 1 at or near full power for the duration of the inspection period.
i The licensee operated Unit 2 at or near full power until September 18,1998, when power level was reduced to approximately 22 percent for a repair to a feedwater regulating valve air actuator. On September 19,1998, the licensee returned Unit 2 to full power and operated at or near full power for the remainder of the inspection period, l. Operations 01 Conduct of Operations
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0 Isolation of System Auxiliary Transformer 142-1 for Planned Maintenance Inspection Scope (71707)
The inspectors observed the operating shift's preparations for isolation of System (
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Auxiliary Transformer (SAT) 142-1 and the subsequent electrical line-up switching activities, Observations and Findinas On September 19,1998, the licensee started a maintenance period for SAT 142-1. The inspectors observed the heightened level of awareness (HLA) briefing and noted that the briefing covered the overall action plan, the chain of command during the electrical line-up shift, contingency actions, and certain individual responsibilities. However, the inspectors also noted that the roles and responsibilities for all of the HLA participants were not covered as was generally done by the licensee. During the subsequent pre-job brief for each specific event, the individual roles and responsibilities for that event were discussed; therefore, the inspectors concluded that although the HLA was not complete, the content was appropriately discussed prior to execution of each evolutio The surveillance testing conducted prior to shifting the electrical line-up and the electrical switching activities between the diesel generators and the unit cross-ties were completed smoothly and effectively. The inspectors noted that initially, the operators did not plan to use phones during the cross-tie operation, contrary to licensee i management's expectations for the conduct of operations that involve communications
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between unit control rooms. Just before the cross-tie operation began, the on-coming shift non-licensed operators reported into the main control room to discuss upcoming evolutions with their respective unit operators, which caused a momentary, but significant, distraction. The operators recognized the distraction and immediately began I using phones.
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. , Conclusions The inspectors concluded that the operator performance during the isolation of SAT 142-1 was good. The heightened level of awareness briefings were generally good with some minor weaknesses note O2 Operational Status of Facilities and Equipment O2.1 Safety iniection Eaualization Valves Found Out of their Expected Position Inspection Scooe (71707)
The inspectors reviewed the circumstances surrounding the loss of control of the l configuration of the Unit 1 and 2 safety injection (SI) pressure equalization valves, !
l 1/2Sl122A and B and 1/2Sl123A and B. The inspectors interviewed operations i l' department personnel and reviewed Problem Identification Form (PlF) B1998-03827, j l '
"Si Equalization Valves Found Closed When They Should Have Been Open," and l l On-Site Review 96-015," Operability Assessment Attachment C for Pressure l
Locking / Thermal Binding Concems Raised by Generic Letter 95-07 Reviews."
l Observations and Findinas 1 l
On September 1,1998, while retuming the residual heat removal system to service l following post-maintenance testing, an operator determined that the pressure L equalization valves on the residual heat removal pump refueling water storage tank suction isolation valves,1/2Sl122A and B and 1/2Sl123A and B, were closed vice ope ,
. As a result, the operators restored the system configurafon and initiated a prompt investigatio The licensee's investigation revealed that these equalization valves had been installed as a modification during the last refueling outage on each unit to restore the system l design margin in response to the concerns raised in NRC Generic Letter 95-07,
" Pressure Locking and Thermal Binding of Safety-Related Power-Operated Gate Valves." As part of this modification, the master valve line-up for the system was l' updated; however, the three partial system valve line-ups had not been update Consequently, since partial system valve line-ups had been completed in lieu of the master valve line-up following originalinstallation and testing,1/2Sl122A and B and 1/2Sl123A and B had never been opened. The licensee also determined that since the system was operable prior to the installation of the modification, as documented in On-Site Review 96-015, and the modification was intended to restore the system design margin, the system remained operable with the pressure equalization valves closed vice open. The inspectors reviewed the licensee's corrective actions and concluded that they were acceptabl As documented in NRC Inspection F<eport 50-454/98017(DRP); 50-455/98017(DRP),
L the licensee was developing an action plan to address an adverse trend in configuration l control events. After reviewing approximately 70 configuration control related issues, the licensee determined that the apparent causes of the 70 events could be divided into
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- . seven apparent causes. The task force recommended approximately 50 different actions to cover those seven causes. Examples of actions recommend by the task force included:; numerous actions to improve communications with station employees emphasizing the importance of configuration control; development of clear departmental boundaries for authorization to operate equipment; improvement of tracking L mechanisms for components out of their normal position; and, reducing the operations L department procedure backlog. At the end of the inspection period, station
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management was reviewing the recommendations of the task force. The inspectors noted that some of the actions had been initiated and a few of the actions had been completed; however, a significant number of the actions had yet to be committed to by
- station managemen Conclusions l The inspectors concluded that configuration control events continued to occur during this inspection period. The inspectors noted that the licensee was aggressively
identifying configuration controlissues and planning numerous corrective actions to arrest the trend of configuration control events. While some corrective actions had been initiated and completed, the licensee had not yet approved and implemented a
- comprehensive corrective action plan.
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04 Operator Knowledge and Performance _
0 Inadvertent Enaineered Safety Feature (ESF) Actuation Due to Operator Error
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l Inspection Scooe (71707) !
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- The inspectors reviewed the circumstances surrounding the inadvertent ESF actuation of containment spray (CS) valves during the performance of Byron Operating Surveillance (BOS) 3.2.1-901, " Unit Two ESFAS (Engineered Safety Feature Actuation Signal] Instrumentation Slave Relay Gurveillance (Train A Steam Line Isolation - K623),"
Revision 2. The inspectors interviewed operators and reviewed Licensee Event Report (LER) 50-455/98007, i Observations and Findinas On August 21,1998, during the performance of BOS 3.2.1-901, Section F.1.4, the
- nuclear station operator (NSO) performing the surveillance test manipulated the wrong
! test switch, Test Switch S846 instead of Test Switch S845. Consequently, the Train A containment spray slave relay, K643, was actuated instead of the Train A steam line isolation slave relay, K623. As a result, the 2A CS pump discharge header isolation valve,2CS007A, and the 2A CS eductor spray additive valve,2CS019A, repositioned open and the 2A CS eductor suction valve,2CS010A, received a confirmatory open
- ' signal. However, since the 2A CS pump was started by a separate slave relay, no
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system flow occurred. The operating shift restored the system configuration, initiated a'
. prompt investigation, and made a 4-hour non-emergency report to the NP,C in accordance with 10 CFR 50.72(b)(2)(ii).
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The licensee's investigation revealed that the operator error occurred as a result of a
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lack of attention to detail and adherence to licensee management expectations for conduct of operations. Specifically, the NSO failed to self-check and peer-check during )
i the evolution. In addition, the pre-job brief did not cover lessons leamed and potential human error traps which could have prevented the subsequent operator error, l Corrective actions identified by the licensee included: (1) restoration of the system l
configuration; (2) issuance of a daily order requiring 100 percent peer-checks for slave relay surveillance tests; and (3) clarification of roles and expectations for all performance standards to establish consistency among the operating shifts. The inspectors concluded that the licensee's corrective actions were acceptabl )
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J Technical Specification (TS) 6.8.1.a states that written procedures shall be established, l
implemented and maintained for procedures recommended in Appendix A, of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, specifies that procedures are required for each surveillance test listed in TS. Byron Operating Surveillance 3.2.1-901 is the implementing procedure for the quarterly slave relay test of the Train A steam line
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Isolation Slave Relay K623 as required by TS 4 3.2.1. The NSO's operation of Test Switch S846 instead of Test Switch S845 during the performance BOS 3.2.1-901, !
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Section F.1.4, which resulted in an unexpected ESF actuation of CS valves, was a I violation of TS 6.8.1.a for failure to implement the procedure. This non-repetitive, l licensee-identified and corrected violation is being treated as a Non-Cited Violation, l consistent with Section Vil.B.1 of the NRC Enforcement Policy )
(50455/98019-01(DRP)). Conclusions
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The inspectors concluded that during the performance of Byron Operating l Surveillance 3.2.1-901, " Unit Two ESFAS (Engineered Safety Feature Actuation Signal]
instrumentation Slave Relay Surveillance (Train A Steam Line Isolation - K623),"
Revision 2, a nuclear station operator (NSO) failed to meet licensee management expectations for self-checking and peer-checking, which resulted in the NSO
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manipulating the wrong test switch during the surveillance test. Consequently, an J unexpected engineered safety feature actuation of containment spray valves occurre j A Non-Cited Violation was issue '
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08 Miscellaneous Operations issues (92700,92901)
- 0 CFR 50.54m Letter Commitment Review Inscection Scope l
The inspectors reviewed the status of commitments pertaining to Commonwealth j Edison Company's February 17,1998, response to the NRC's request for information pursuant to 10 CFR 50.54(f).
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.. Observations and Findinas Nuclear Generation Group 3. " Ensure Excellence in Plant Material Condition" Action Steo 2: " Implement the Work Control Planning Process to Further improve the Ability to Execute Work." On April 3,1998, the licensee approved and implemented Nuclear Station Procedure (NSP) WC-3005, " Maintenance Planning," Revision 0, which established a standard maintenance planning ~ process at all Commonwealth Edison Company nuclear stations.
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Action Steo 9: " Implement the On-line Maintenance Process." On June 30,1998, the ,
licensee approved and implemented NSP WC-3006, "On-Line Maintenance,"
Revision 0, which established standard administrative controls for performing on-line maintenance on structures, systems, and components important to safety at all Commonwealth Edison Company nuclear station Action Steo 10: " Implement the Performance Centered Maintenance Program at all
Sites." On August 30,1998, the licensee had implemented Nuclear Engineering Procedure 09-03, " Performance Centered Maintenance (PCM) Methodology,"
Revision 0, and Nuclear Engineering Standards G-08, " Performance Centered Maintenance (PCM) Templates Revision Process," Revision 0, for pumps, motors, batteries and battery chargers, check valves, motor operated valves, air operated valves, fans, instruments, transformers, and breakers. The licensee was developing
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PCM templates for heat exchangers, manual valves, relief valves, solenoid operated valves, and relay Nuclear Generation Group 10. " Enhance Communications" Action Steo 5: " Implement Annual Site Communication Plan." On March 28,1998, the licensee approved and implemented a communication plan which described a list of
- Byron site specific activities to be accomplished in conjunction with the actions delineated in the document, " Enhance Communication (NGG-10)," dated April 2,199 Conclusions The inspectors concluded that the licensee completed commitments of the Nuclear Generation Group Strategic Reform initiatives that were reviewe l 08.2 (Closed) LER 50-455/98007
- " inadvertent Actuation of ESF Signal to Containment Spray Valves Due to Operator Error During Slave Relay Surveillance." This LER is
]' discussed in Section 04.1 of this report. A Non-Cited Violation was issued. This LER is close .3 (Closed) LER 50-454/98017: "Line 0621 Trip and Subsequently, Loss of Unit 1 SATs Causing Loss of Offsite Power." On August 4,1998, Unit 1 experienced a loss of offsite
. power (LOOP). The event and the licensee's initial findings were documented in NRC Inspection Report 50-454/98017(DRP); 50-455/98017(DRP). The apparent cause was
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a relay in Line 0621 protection circuit that failed to reset after a fault cleared combined
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The licensee subsequently identified an additional procedural deficiency which was documented in the LER. After Line 0621 had tripped, the main control room annunciator remained lit. The operators believed that the annunciator indicated that Line 0621 was I de-energized. After referring to Byron Annunciator Response (BAR) Procedure 0-35-D1 )
- and discussing the line status with Commonwealth Edison's Electric Operations, the operator attempted to close oil cooled circuit breaker (OCB) 5-6. The licensee's investigation identified that the annunciator actually indicated a problem with the control circuit for Line 0621 rather than indicating that the line was de-energized. Therefore, the operator should not have attempted to shut OCB 5-6. However, BAR (0-35-01) did not identify the potential control circuit problem. Additionally, the LBB protection circuit
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activated sooner than designed, which when combined with the stuck relay, was the actual cause for the LOOP. If the LBB had operated properly, the operator's attempt to shut OCB 5-6 would have resulted in the breaker reopening, but would not have caused the LOOP. As a result, the licensee planned to revise the annunciator response procedures. The inspectors reviewed the licensee's corrective actions and found them to be acceptable. No violations were identified. This LER is close 0 {. Closed) Violation 50-454/455-97008-01: " Failure to Take Corrective Action Documented in LER 50-454/94014." The inspectors identified in NRC Inspection Report 50-454/97008(DRP); 50-455/97008(DRP) that the licensee had failed to take the corrective actions documented in LER 50-454/94014. The licensee's review indicated that the corrective actions had never been entered into the licensee's tracking system and therefore, the actions were never completed. Due to the period of time between the occurrence (1994) and discovery (1997), the licensee could not conclusively determine the root cause of the event. However, the licensee completed the corrective actions identified in LER 50-454/94014 and verified that the corrective actions documented in all the LERs placed on the docket since 1994 had been entered into the corrective action tracking system. Additionally, the licensee reviewed the existing procedural guidance to personnel responsible for entering actions into the tracking system and determined that the current guidance was sufficient. The inspectors concluded that the licensee's corrective actions were acceptable. This violation is close II. Maintenance M1 Conduct of Maintenance M1.1 Maintenance Observations Inspection Scope (62707)
The inspectors interviewed operations, engineering, and maintenance department personnel and observed the performance of all or portions of the following work requests (WR). When applicable, the inspectors also reviewed TS and the Updated
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Final Safety Analysis Report (UFSAR).
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WR 940014881-04 Excavate Install / Remove Line Stop and Backfill
WR 980090742-01 Troubleshoot Non-urgent Alarm in Rod Drive System j
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WR 940008703-01 Remove Furmanite Repair on Flange of North Cooling Bank [ Unit 1 System Auxiliary Transformer)
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WR 970069703-01 Install Suction Strainer on the 2B Essential Service Water
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. (SX) Pump Main Lube Oil Pump . WR 980065491 Inspect / Repair the 2B SX Discharge Straine WR 98002196 Repair Minor Oil Leak on the 28 SX Outboard Bearing Housin ~
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WR 960035956 Remove and Replace the 1B Reactor Containment Fan ;
Cooler High Speed Breaker, b. ' - Observations and Findinas
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Unit 1 SAT Bushina Reolacement
- During the restoration of SAT 142-1 following planned maintenance, the licensee l identified that an electrical connection bushing was leaking oil. The licensee decided to l replace the bushing due to the risk of damaging the offsite power supply and causing a _l
prolonged loss of offsite power. Potential consequences included a Unit 1 shut down I using natural circulation for cooldown if a significant error resulted in damage to both )
Unit 1 SATs and the damage could not be repaired within the 72-hour limiting condition for operation action requiremen l On September 28,1998, the licensee de-energized both Unit 1 SATs to minimize the I consequences of a crane accident and replaced the leaking bushing on SAT 142-1, ,
The inspectors observed the pre-job brief and noted that nuclear oversight personnel l attended and coached the crew on appropriate foreign material exclusion practice The inspectors noted appropriate crane control and foreign material exclusion practice l However, the inspectors observed that the procedure for replacing the bushing was .
contained in the temporary leak repair work package and simply stated repair / replace !
bushin During subsequent discussions with the inspectors, maintenance department j man 9gement agreed that even though the maintenance was conducted by non-station !
Commonwealth Edison personnel, a written procedure should have been used. In addition, due to the potential consequences of the evolution, the Plant Operations Review Committee (PORC) had reviewed the bushing replacement prior to conducting .
the evolution; and, the PORC also expected that a procedure would be used. Although j the inspectors did not identify a violation of regulatory requirements, the inspectors were l concerned that the control of maintenance activities involving non-station personnel did - ;
not meet the standards expected of station maintenance personne Conclusions l
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The inspectors concluded that observed maintenance activities were generally well I conducted. However, the inspectors concluded that non-station Commonwealth Edison
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maintenance personnel had not been fully integrated into the licensee's maintenance department. Specifically, substation department personnel replaced an electrical
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connector bushing on a Unit 1 system auxiliary transformer without a written procedure, contrary to the expectations of senior station management. No violations were identifie M1.2 Surveillance Test Observations Insoection ScoDe (61726)
The inspectors interviewed operations personnel, reviewed the completed test l
documentation and applicable portions of the UFSAR and TS, and observed the performance of selected portions of the following surveillance test procedure *
1BOS 3.2.1-804 Unit One ESFAS Instrumentation Slave Relay Surveillance !
(Train A Automatic Safety injection - K609) {
1BOS 3.2.1-805 Unit One ESFAS Instrumentation Slave Relay Surveillance !
(Train A Automatic Safety injection - K610)
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1BOS 3.2.1-846 Unit One ESFAS Instrumentation Slave Relay Surveillance
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(Train A Safeguards Actuation Relay (SARA) Parallel Path Test)
1BOS 3.2.1-856 Unit One ESFAS Instrumentation Slave Relay Surveillance (Train B Safeguards Actuation Relay (SARB) Parallel Path I Test)
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1BOS 3.2.1-860 Unit One ESFAS Instrumentation Slave Relay Surveillance (Train A Automatic Containment Isolation Phase B - K618, K626)
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2BOS 7.1.2.1.b-2 Unit 2 Diesel Driven Auxiliary Feedwater Pump Quarterly ,
Surveillance
, Conclusions The inspectors concluded that the observed surveillance tests were performed wel Specifically, the surveillance tests met the requirements of TS; and each of the tested components met their respective acceptance criteria and remained operable.
M8 Miscellaneous Maintenance issues (92700,92902)
M8.1 (Closed) Unresolved item (URI) 50-454/455-94025-03(DRP): "Okonite Taped Cable Splices." The environmental qualification of Okonite taped cable splices was originally
' identified as a concern at Braidwood Station. On November 13,1995, the NRC
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approved the use of Okonite taped cable splices at Braidwood. The licensee contended that the same analysis applied to Byron; however, the NRC safety evaluation report did not address Byron Station. Therefore, by letter dated July 30,1998, the licensee requested approval for the environmental qualification and use of Okonite taped cable splices at Byron based on the Braidwood analysis, which was subsequently approved by letter dated September 28,1998. This Unresolved item is closed.
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M8.2 (Closed) LER 50-454/97003: " Equipment Hatch Gallery Not Properly Attached to the Containment Structure." On February 18,1997, during the performance of a Unit 1 i 11
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i containment walkdown, the licensee identified that the equipment hatch gallery was not seismically secured to the containment structure. The licensee determined that the cause of the issue was an inadequate work package and maintenance procedure; and a lack of a questioning attitude on the part of procedure writers and reviewers, work analysts, job supervisors, and workers performing the activity. The licensee's corrective actions included: (1) revising Byron Maintenance Procedure (BMP) 3300-1,
" Containment Equipment Hatch Removal and Installation"; to include criteria that would
{ leave the gallery seismically qualified, (2) revising Byron Administrative Procedure (BAP) 400-19, " Maintenance Procedures Writers Guide"; and (3) providing
, training for maintenanco personnel to heighten their awareness of seismic design requirements. The inspectors reviewed the licensee's corrective actions and found them to be acceptabl CFR Part 50, Appendix B, Criteria V, " Instructions, Procedures, and Drawings,"
requires, in part, that activities affecting quality shall be prescribed by documented procedures of a type appropriate to the circumstances and shall be accomplished in
. accordance with these instructions, procedures, or drawings. The failure of
BMP 3300-1, " Containment Equipment Hatch Removal and Installation," to provide appropriate guidance to ensure that the equipment hatch gallery installation satisfied the seismic design requirements was a violation of 10 CFR Part 50, Appendix B, Criteria 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 Enforcement Policy (50-454/98019-02(DRP)). This LER is close M8.3 (Closed) LER 50-454/97009: " Missed Technical Specification Surveillance." This event was discussed in NRC Inspection Report 50-454/97009(DRP); 50-455/97009(DRP) and Violation 50-454/455-97009-01(DRP) was cited. The licensee determined that the cause of the issue was inadequate managerial methods, in that, the applicable surveillances and documentation did not receive adequate critique or technical revie The licensee's c6rrective actions included: (1) requesting and receiving an amendment to Technical Specifications; (2) performing ultrasonic testing to verify that the chemical and volume control (CV) system piping was vented; (3) revising BOS 5.2.b-1, "ECCS (Emergency Core Cooling Systems) Venting and Valve Alignment"; (4) reviewing selected TS surveillances to verify compliance; and (5) conducting system walkdowns
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! using isometric drawings to identify any additional high point vents. The inspectors reviewed the licensee's corrective actions and found them to be acceptable. This LER is closed.
M8.4 (Closed) LER 50-454/97010: " Faulty Review Causes Failure to Test Relays and Technical Specification 3.0.3 Entry." This event was discussed in NRC Inspection Report 50-454/97009(DRP); 50-455/97009(DRP) and Violation 50-454/455-97009-02
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was cited. The licensee determined that the cause of the issue was an inadequate onsite review, performed in 1990, that approved changing the test methodology for the CV system letdown isolation and letdown orifice isolation valves. The licensee's corrective actions included: (1) reviewing all TS slave relay surveillances to verify compliance; (2) evaluating a modification to resolve thermal transients caused by cycling of the letdown line containment isolation valves during testing; and (3) requiring the PORC to review all TS literal compliance issues raised at both Byron and Braidwood
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l Stations. The inspectors reviewed the licensee's corrective actions and found them to be acceptable. This LER is closed.
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M8.5 (Closed) LER 50-454/97013: " Valve Mistakenly Opened Causes Post LOCA [ Loss of Coolant Accident] Leakage to Exceed Limit." This event was discussed in NRC Inspection Report 50-454/97009(DRP); 50-455/97009(DRP) and I
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Violation 50-454/455-97009-03 was cited. The licensee concluded that the reason that
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the valve had been opened could not conclusively be determined; however, the licensee also concluded that BOS 5.2.b-1, "ECCS Venting and Valve Alignment;" was inadequate, in that, it did not identify all possible flow paths to vent the pump. The l i
licensee's corrective actions included reviewing all other ECCS pump venting flow path configurations and revising BOS 5.2.b-1. The inspectors reviewed the licensee's ;
corrective actions and found them to be acceptable. This LER is close I M8.6 (Closed) Violation 50-454/455-97009-01(DRP): " Failure to Vent the Chemical and I Volume Control (CV) System and the Unit 1 Residual Heat Removal (RH) Heat i
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Exchanger High Point Vent,1RH027, in Accordance with TS 4.5.2.b(1)." This violation is discussed in Section M8.3 of this repott This violation is close M8.7 (Closed) Violation 50-454/455-97009-02(DRP): " Failure to Perform a Continuity Test for the Slave Relays for the Chemical and Volume Control (CV) System Letdown isolation !
Valves, and the CV Letdown Orifice isolation Valves in Accordance with TS 4.3.2.1."
This violation is discussed in Section M8.4 of this report. This violation is close M8.8 (Closed) Violation 50-454/455-97009-03(DRP): " inadequate Procedure for Venting the Safety injection Pumps." This violation is discussed in Section M8.5 of this report. This violation is close Ill. Enaineerina E8 Miscellaneous Engineering issues (37551,92903)
E (Closed) IFl 50-454/455-98017-03: " Orientation of Anderson Greenwood Check Valves." The vendor technical manual specified that these valves be oriented in either the vertical position with flow upward or in a horizontal position with the hinge pin mounted vertically. The failure to properly orient these check valves could result in excessive wear and an increased failure rat In response to the inspectors questions, the licensee determined that 13 safety-related Anderson Greenwood check valves were mis-oriented, two of which have since been corrected. The licensee also determined that the orientation of an additional six valves was not able to be detennined due to existing plant conditions; however, the licensee planned to treat these valves as if they were mis-oriented until the orientation can be conclusively determined. The licensee revised Byron Engineering Surveillance (BVS) Xil-8, " Check Valve Visual Inspections," BMP 3100-35, " Anderson-Greenwood Type CV1B Wafer Check Valve Repair," and BMP 3300-9, " Auxiliary Feedwater Check Valve Periodic Inspection," to include specific guidance for the proper orientation of the
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i valves during reassembly and a hold point for an engineering inspection. Consequently, :
the orientation of each of there valves should be corrected during the completion of the next scheduled maintenance activity. This inspector Follow-up item is close E8.2 (Closed) URI 50-454/455-97022-04: " Potential Unreviewed Safety Question for Operation of a Material Handling System Adjacent to the Spent Fuel Pool." The inspectors questioned the use of a material handling system (MHS) that the licensee had installed in the fuel handling building during the steam generator replacement '
outage. The inspectors were concerned that the use of the MHS had created the possibility of an accident or malfunction of a different type than any evaluated in the l
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UFSAR, thus creating a potential unreviewed safety question. However, after further NRC review, the inspectors concluded that the licensee's actions were appropriate and the use of the MHS did not create a unreviewed safety question This unresolved item is close .
E8.3 (Closed) Violation 50-454/455-97002-07a(DRP): " Unauthorized Modification Found in i Unit 1 Containment Building." The inspectors identified an unauthorized modification
- 1 installed on the service air system in the Unit 1 containment building to supply service i air to the refueling machine. Although the service air system was not a safety-related system, the inspectors noted that the modification required a seismic evaluation because of its close proximity tc the reactor vessel. Since the design change was not controlled, the seismic evaluation was not performed. 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 '
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IV. Plant Support !
R1 Radiological Protection and Chemistry (RP&C) Controls R Radioactive Material Found Outside Radiolooically Posted Area i Insoection Scope (71750)
During routine inspection activities, the inspectors noted that several events had occurred where radioactive material (RAM) had been inadvertently released from a radiologically posted area (RPA). During interviews with radiological protection (RP) 1 management, the inspectors were informed that a root cause investigation for the adverse trend was being performed. The inspectors reviewed Root Cause Report 454-230-98-CAQS00034, " Radioactive Material (RAM) Found Outside RPA Due To Complacency in Handling and Control of Radioactive Material." Observations and Findinas The licensee identified 14 events between November 1997, and August 6,1998, where radioactive material was found outside of an RPA. With one exception, all 14 events l involved very low levels of contamination, ger,erally near the minimum detectable level l
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and generally fixed contamination. The one exception involved a mop bucket found uncontrolled in the turbine building after the bucket had been used to decontaminate '
portions of an RPA in the turbine building. The mop bucket had one spot identified to be 220,000 counts per minute. Poor communication between an RP technician and .
decontamination personnel was identified as the cause. Two events involved the !
shipment of unidentified RAM to Braidwood Station for use during the steam generator replacement project and were identified by Braidwood Station personnel. These two ;
events were discussed in NRC Inspection Report 50-454/98010(DRS); '
50-455/98010(DRS) and a violation was cite c. Conclusions Several uncontrolled radioactive material events involving low contamination levels had been identified by the licensee and a root cause investigation of the adverse trend was conducted. In addition to specific corrective actions for each event, the licensee j identified several broad corrective actions for greater awareness and accountability that !
were either implemented or planned to be implemented at the end of the inspection
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period. The inspectors considered the corrective actions acceptabl !
j V. Manaaement Meetinas
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X1 Exit Meeting Summary l
The inspectors presented the inspection results to members of licensee management at
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the conclusion of the inspection on October 5,1998. 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, i
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PARTIAL LIST OF PERSONS CONTACTED Licensee K. Graesser, Site Vice-President W. Levis, Station Manager B. Adams, Regulatory Assurance Manager J. Bauer, Radiation Protection Manager T. Gierich, Operations Manager B. Kouba, Engineering Manager T. Schuster, Work Control 7.1anager M. Snow, Maintenance Manager
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t INSPECTION PROCEDURES USED ,
IP 37551 Onsite Engineering .
~ IP 61726: Surveillance Observations IP 62707: Maintenance Observations IP 71707: Plant Operations '
IP 71750: Plant Support Activities
- IP 92700: Onsite Followup of Written Rekrts of Nonroutine Events at Power
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Reactor Facilities ;
IP 92901: Follow-up Operations '
IP 92902: - Follow-up Maintenance
. IP 92903: ' Follow-up Engineering
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ITEMS OPENED, CLOSED, AND DISCUSSED
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50-455/98019-01 NCV Unexpected ESF Actuation of CS Valves 50-454/98019-02 NCV inappropriate Mair.tenance Procedure Resulted in the ' 3 Equipment Hatch Gallery Not Meeting Seismic Design J
. Requirements
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50-455/98019-01 NCV Unexpected ESF Actuation of CS Valves '
50-455/98007- LER Inadvertent Actuation of ESF Signal to Containment Spray l Valves Due to Operator Error During Slave Relay Surveillance 50-454/98017 LER Line 0621 Trip and Subsequently, Loss of Unit 1 SATs Causing Loss of Offsite Power 50-454/455-97008-01- VIO - Failure to Take Corrective Action Documented in LER 50-454/94014 50-454/455-94025-03 URI ' Okonite Taped Cable Splices 50-454/97003 LER Equipment Hatch Gallery Not Properly Attached to the Containment Structur /98019-02 NCV Inappropriate Maintenance Procedure Resulted in the Equipment Hatch Gallery Not Meeting Seismic Design
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Requirements
,50-454/97009 LER Missed TS Surveillance 50-454/97010 LER Faulty Review Causes Failure to Test Relays and TS 3. l
, Entry l 50-454/97013 LER Valve Mistakenly Opened Caused Post LOCA Leakage to Exceed Limit 50-454/455-97009-01 VIO Failure to Vent the CV System and 1RH027 in Accordance with TS 4.5.2.b(1) .
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j 50-454/455-97009-02 VIO Failure to Perform a Continuity Test for the Slave Relays ;
for the CV Letdown Isolation Valves and CV Letdown l Orifice Isolation Valves in Accordance with TS 4.3. l I
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50-454/455-97009-03 VIO ' Inadequate Procedure for Venting S1 Pumps l 50-454/455-98017-03 IFl Orientation of Anderson Greenwood Check Valves 50-454/455-97022-04 - URI Potential Unreviewed Safety Question for Operation of a ]
Material Handling System Adjacent to the Spent Fuel Pool l 50-454/455-97002-07a VIO Unauthorized Modification Found in Unit 1 Containment !
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' LIST OF ACRONYMS USED l AF- Auxiliary Feedwater System ' '
BAP Byron Administrative Procedure BAR Byron Annunciator Response BMP Byron Maintenance Procedure BOS Byron Operating Surveillance l BVS ~ Byron Engineering Surveillance
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.CS Containment Spray System CV Chemical and Volume Control System 1-DRP Division of Reactor Projects DRS Division of Reactor Safety ECCS Emergency Core Cooling System ESF Engineered Safety Feature ESFAS Engineered Safety Feature Actuation Signal HLA Heightened Level of Awareness IFl Inspector Follow-up Item
- LBB Local Breaker Backup LER Licensee Event Report LOCA Loss of Coc! ant AccJdent LOOP Loss of Off site Power MHS Material Handling system NCV Nori-cited Violation NRC Nuclear Regulatory Commission NSO Nuclear Station Operator NSP Nuclear Station Procedure OCB Oil filled Circuit Breaker PCM Performance Centered Maintenance PDR Public Document Room PIF Problem Identification Form POR Plant Operations Review Committee RAM Radioactive Material RH Residual Heat Removal RP Radiological Protection RP&C Radiological Protection and Chemistry RPA Radiologically Posted Area SAT System Auxiliary Transformer SI Safety injection SX Essential Service Water System TS Techn'ical Specification UFSAR Updated Final Safety Analysis Report URI Unresolved item VIO Violation WR Work Request 19