IR 05000454/2017007

NRC Problem Identification and Resolution Inspection Report 05000454/2017007; 05000455/2017007

ML17276B174
Person / Time
Site:	Byron
Issue date:	10/03/2017
From:	Eric Duncan Region 3 Branch 3
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2017007
Download: ML17276B174 (40)

Text

UNITED STATES ber 3, 2017

SUBJECT:

BYRON STATION, UNITS 1 AND 2 NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000454/2017007; 05000455/2017007

Dear Mr. Hanson:

On August 25, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution (PI&R) inspection at your Byron Station, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed at an exit meeting on August 25, 2017, with Mr. P. Boyle and other members of your staff.

The inspectors examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

On the basis of the samples selected for review, the team concluded that the Corrective Action Program (CAP) at Byron Station, Units 1 and 2, was generally effective in identifying, evaluating and correcting issues. The licensee had a low threshold for identifying issues and entering them into the CAP. A risk based approach was used to determine the significance of the issues and priority for issue evaluation and resolution. Corrective actions were generally implemented in a timely manner, commensurate with their safety significance. Operating experience was entered into the CAP when appropriate and evaluated according to procedure. The use of operating experience was integrated into daily activities and found to be effective in preventing similar issues at the plant. In addition, self-assessments and audits were conducted at appropriate frequencies with sufficient depth for all departments based on the documents the team reviewed. The assessments were thorough and effective in identifying site performance deficiencies, programmatic concerns, and improvement opportunities. On the basis of the interviews conducted, the inspectors did not identify any chilling effect or any impediment to the establishment of a safety conscious work environment at Byron Station. Your staff was aware of and generally familiar with the CAP and other station processes, including the Employee Concerns Program, through which concerns could be raised. The team determined that your stations performance in each of these areas supported nuclear safety. Based on the results of this inspection, the NRC has identified two issues that were evaluated under the safety significance determination process as having very low safety significance (Green). The NRC has also determined that a violation is associated with each of these issues.

Because you have initiated corrective actions to address the issues, these violations are being treated as Non-Cited Violations (NCVs), consistent with Section 2.3.2 of the Enforcement Policy. These NCVs are described in the subject inspection report.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Eric Duncan, Chief Branch 3 Division of Reactor Projects Docket Nos. 50-454; 50-455 License Nos. NPF-37; NPF-66 Enclosure:

IR 05000454/2017007; 05000455/2017007 cc: Distribution via LISTSERV

SUMMARY

Inspection Report 05000454/2017007; 05000455/2017007; 08/07/2017-08/25/2017; Byron

Station; Identification and Resolution of Problems.

This inspection was performed by three region-based inspectors, the senior resident inspector at Duane Arnold Energy Center, the resident inspector from the Illinois Emergency Management Agency and the resident inspector at Byron Station. Two Green findings with associated Non-Cited Violations (NCVs) of U.S. Nuclear Regulatory Commission (NRC) regulations were identified. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process (SDP)," dated April 29, 2015. Cross-Cutting aspects are determined using IMC 0310, "Aspects within the Cross-Cutting Areas," dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated November 1, 2016. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," dated July 2016.

Identification and Resolution of Problems On the basis of the samples selected for review, the team concluded that the Corrective Action Program (CAP) at Byron Station was generally effective in identifying, evaluating and correcting issues. The licensee had a low threshold for identifying issues and entering them into the CAP.

A risk-based approach was used to determine the significance of the issues and priority for issue evaluation and resolution. Corrective actions were generally implemented in a timely manner, commensurate with their safety significance. Operating experience was entered into the CAP when appropriate and evaluated according to procedure. The use of operating experience was integrated into daily activities and found to be effective in preventing similar issues at the plant. In addition, self-assessments and audits were conducted at appropriate frequencies with sufficient depth for all departments based on the documents the team reviewed. The assessments were thorough and effective in identifying site performance deficiencies, programmatic concerns, and improvement opportunities. On the basis of the interviews conducted, the inspectors did not identify any chilling effect or any impediment to the establishment of a safety conscious work environment at Byron Station. Licensee staff was aware of and generally familiar with the CAP and other station processes, including the Employee Concerns Program, through which concerns could be raised. The team determined that Byron Stations performance in each of these areas supported nuclear safety.

Although implementation of the CAP was determined to be effective overall, the inspectors identified several issues that represented a potential weakness in the program.

NRC-Identified

and Self-Revealed Findings

Cornerstone: Mitigating Systems

Green.

The inspectors identified a finding of very low safety significance and an associated NCV of TS 5.4.1, Procedures, when licensee personnel failed to perform maintenance in accordance with written procedures as required by Regulatory Guide 1.33. Specifically, from February 3, 2014, through August 25, 2017, the licensee failed to develop and execute work instructions of sufficient scope to accomplish the preventive maintenance to replace flexible hoses on the essential service water (SX)makeup pumps and the diesel driven auxiliary feedwater (AFW) pumps and did not have a technical justification for a deviation from the Exelon Corporate Performance Centered Maintenance (PCM) template. The licensee entered this issue into their CAP as Action Request (AR) 03961955, AR 03971962, and AR 04045769 and planned to replace the flexible hoses at the next available opportunity.

The inspectors determined that failure to perform maintenance in accordance with written procedures as required by TS 5.4.1, Procedures, and Regulatory Guide 1.33 was a performance deficiency. The performance deficiency was more than minor because it was associated with the Mitigating Systems cornerstone attribute of Equipment Performance and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failing to replace flexible hoses on the SX makeup pumps and the Unit 1 and Unit 2 diesel-driven AFW pumps at a pre-established frequency could allow hose degradation to remain unidentified and lead to the unplanned inoperability of these safety-related systems. Since the finding is a deficiency affecting the design or qualification of mitigating systems, structures and components (SSCs) and the SSCs remained operable and functional, the finding screened as having very low safety significance. This finding affected the Cross-Cutting area of Human Performance in the aspect of Work Management because the licensee failed to perform required maintenance in accordance with their associated maintenance strategy as well as the corporate PCM template [H.5]. (Section 4OA2.1.b.3.ii)

Green.

The inspectors identified a finding of very low safety significance and an associated NCV of Title 10 of the Code of Federal Regulations (CFR), Part 50,

Appendix B, Criterion XVI, Corrective Action, when the licensee failed to promptly identify a condition adverse to quality resulting in a safety-related system becoming inoperable. Specifically, from May 5, 2017, to August 4, 2017, the licensee failed to trend available surveillance data in a timely manner and did not identify a degraded condition in the 1A reactor containment fan cooler (RCFC) time delay circuitry prior to the system becoming inoperable. The licensee entered this issue into their CAP as AR 04039037 and AR 04045767, replaced the failed relay, and planned to update the RCFC system monitoring plan to note abnormal changes in time delay relay actuation times and improve coordination between engineering and operations to reduce the time it takes engineering to obtain RCFC surveillance data for trending after surveillances are completed.

The inspectors determined that the failure to promptly identify a condition adverse to quality associated with the time delay relay circuitry in the 1A RCFC was a performance deficiency. The performance deficiency was more than minor because it was associated with the Mitigating Systems cornerstone attribute of Equipment Performance and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to identify a degraded condition in the time delay circuitry associated with the 1A RCFC resulted in a missed opportunity for the licensee to evaluate the cause and initiate prompt actions to respond to the degraded condition prior to the failure. The inspectors answered No to questions A.1 through A.4 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power,

Exhibit 2, Mitigating Systems Screening Questions; therefore, the finding screened as having very low safety significance. This finding affected the Cross-Cutting area of Problem Identification and Resolution in the aspect of Trending because information was available that indicated a degraded condition in the 1A RCFC time delay relay circuitry for three months prior its failure in August, but was not identified and evaluated by the licensee prior to failure [P.4]. (Section 4OA2.1.b.3.ii)

REPORT DETAILS

4OA2 Problem Identification and Resolution

This inspection constituted one biennial sample of problem identification and resolution (PI&R) inspection as defined by Inspection Procedure (IP) 71152, Problem Identification and Resolution. Documents reviewed are listed in the Attachment to this report. Note that the licensee tracks condition reports as Action Requests (ARs).

.1 Assessment of Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the procedures and processes that described the CAP at Byron Station to ensure, in part, that the requirements of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, were met. The inspectors observed and evaluated the effectiveness of meetings related to the CAP, such as Management Review Committee (MRC) meetings and the Station Ownership Committee (SOC) meetings. Selected licensee personnel were interviewed to assess their understanding of and their involvement in the CAP.

The inspectors reviewed selected ARs across all seven Reactor Oversight Process (ROP) cornerstones to determine if problems were being properly identified and entered into the licensees CAP. The majority of the risk-informed samples of ARs reviewed were issued since the last NRC biennial PI&R inspection completed in August of 2015. The inspectors also reviewed selected issues that were more than five years old.

The inspectors assessed the licensees characterization and evaluation of the issues and examined the assigned corrective actions. This review encompassed the full range of safety significance and evaluation classes, including root cause evaluations, apparent cause evaluations, corrective action program evaluations, and work group evaluations.

The inspectors assessed the scope and depth of the licensees evaluations. For issues that were characterized as high safety significance, the inspectors evaluated the licensees corrective actions to preclude repetition and for issues that were less significant, the inspectors reviewed the corrective actions to determine if they were implemented in a timely manner commensurate with their safety significance.

The inspectors performed a five-year review of the safety-related component cooling water system based on input from the resident staff. This system provides cooling water to remove heat from plant components of either unit that are required during normal operation, plant shutdown and post-accident conditions. The system also acts as an intermediate system between the potentially radioactive components being cooled and the essential service water system that is open to the environment. The primary purpose of this review was to determine whether the licensee was monitoring and addressing performance issues of the component cooling water system. The inspectors performed walkdowns, as needed, to verify the resolution of issues.

A five-year review of the radiation monitoring system was undertaken to assess the licensee staffs efforts in monitoring system performance. Although this system is non-safety related, it continuously measures, indicates, and trends the levels of radiation in general access and operational areas and thereby assists in avoiding unnecessary or inadvertent exposure. In addition, the system monitors and samples the process and effluent streams in order to control the release of radioactive materials generated as a result of normal operation, anticipated operational occurrences, and during postulated accidents. The inspectors review was to determine whether the licensee staff was properly monitoring and evaluating the performance of the system through effective implementation of station monitoring programs, such as the system health report. The inspectors performed walkdowns, as needed, to verify the resolution of issues.

The inspectors examined the results of self-assessments of the CAP completed during the review period. The results of the self-assessments were compared to self-revealed and NRC-identified findings. The inspectors also reviewed the corrective actions associated with previously identified NCVs and findings to determine whether the station properly evaluated and resolved those issues. The inspectors also performed walkdowns, as necessary, to verify the resolution of the issues.

b. Assessment

(1) Identification of Issues Based on the results of the inspection, the inspectors concluded that Byron Station was generally effective in identifying issues at a low threshold and entering them into the CAP. The inspectors determined that problems were normally identified and captured in a complete and accurate manner in the CAP. The station was appropriately screening issues from both NRC and industry operating experience at an appropriate level and entering them into the CAP when applicable to the station. The inspectors also noted that deficiencies were identified by external organizations (including the NRC) that had not been previously identified by licensee personnel. These deficiencies were subsequently entered into the CAP for resolution.

The inspectors determined that the licensee was generally effective at trending low level issues to prevent larger issues from developing. The licensee used the CAP to document instances where previous corrective actions were ineffective or were inappropriately closed.

The inspectors performed a five-year review on the component cooling water system.

As part of this review, the inspectors interviewed the current system engineer and reviewed ARs, critical equipment failure evaluations, and condition report evaluations. In addition, the inspectors performed a system walkdown to assess the material condition of the system and surrounding areas. The inspectors identified that a number of design issues had been effectively and adequately resolved during this five year period and that previously identified Issues with the component cooling water pump bearings were being properly monitored and trended. The inspectors concluded that component cooling water system-related concerns were identified and entered into the CAP at a low threshold, and concerns had been resolved in a timely manner commensurate with their safety significance.

i) Observation Change in Rate of Condition Report Generation The inspectors identified a declining trend in AR generation rate over the preceding five years. From mid-August 2012 to mid-August 2013, there were roughly 15,000 ARs generated at Byron Station. This number has declined steadily with just over 10,000 ARs generated during the same mid-August 2016 to mid-August 2017 period. The inspectors determined that a number of factors might have affected AR generation during this five-year period. For example, the 2013 period included two outages although the 2017 period did not. Also, the licensee implemented a number of actions to improve performance after 2013 and plant performance improved. Moreover, the licensee had recently implemented a change to the corrective action process to streamline and reduce administrative burdens.

Based on the samples reviewed, the inspectors determined that issues of both low and high safety significance were being identified in the CAP. The inspectors also confirmed with people interviewed that licensee staff were willing to write ARs. The inspectors concluded that there were no evidence that condition reports were not being generated.

The licensee acknowledged the decline in AR generation rates and planned to continue to monitor the generation rates and take action if necessary.

ii) Findings No findings were identified.

(2) Prioritization and Evaluation of Issues Based on the results of the inspection, the inspectors concluded that the station was effective at prioritizing and evaluating issues commensurate with the safety significance of the identified issue, including an appropriate consideration of risk.

The inspectors determined that the MRC and SOC meetings were generally thorough and maintained a high standard for evaluation quality. Members of the committees were engaged and discussed selected issues in sufficient detail and challenged each other regarding their conclusions and recommendations.

The inspectors determined that the licensee usually evaluated equipment functionality requirements adequately after a degraded or non-conforming condition was identified.

In general, appropriate actions were assigned to correct the degraded or non-conforming condition.

i) Observations Prioritization of Corrective Actions to Resolve Design-Related Issues The inspectors reviewed the list of open condition reports and noticed that a number of the issues had been open for more than ten years. The inspectors reviewed a sample of these condition reports and found that most of these were design-related non-conformances. For example, the licensee identified in 2003 that the 2B containment spray pump room cooler might have larger diameter and thinner tubes than what was described in design specifications. The licensee performed an engineering evaluation at the time to demonstrate that this discrepancy had no impact on its design functions.

Although some vendor drawings had been changed, actions to update the design calculations were never completed.

Another example was related to the Active Valve Table in the Updated Final Safety Analysis Report. The resident inspectors identified in 2003 that the auxiliary feedwater containment isolation valves were not listed in the Active Valve Table. The licensees extent of condition review discovered a number of other discrepancies in the table.

However, corrective actions to resolve these discrepancies were not being implemented.

In 2013, the licensee generated a condition report which identified that the actions to update the Active Valve Table were untimely. As a result, the licensee just recently completed updating the Active Valve Table in March of this year.

The licensee documented in condition reports that the delays were due to other higher priority problems taking precedent at different points in time. The inspectors determined that these issues were minor design non-conformances that did not meet the more than minor criteria in IMC 0612, Appendix B and therefore represented violations of minor significance that is not subject to enforcement action in accordance with the NRCs enforcement policy. The licensee acknowledged this issue and planned to resolve long-standing design non-conformance issues in a more timely manner.

ii) Findings No findings were identified.

(3) Effectiveness of Corrective Actions Based on the results of the inspection, the inspectors concluded that the licensee was generally effective in addressing identified issues and that assigned corrective actions were generally appropriate. The licensee implemented corrective actions in a timely manner, commensurate with their safety significance, including an appropriate consideration of risk.

Problems identified using root or apparent cause methodologies were resolved in accordance with the Corrective Action Program (CAP) procedure and regulatory requirements. Corrective actions designed to prevent recurrence were generally comprehensive, thorough, and timely. The inspectors sampled corrective action assignments for selected NRC-documented violations and determined that actions assigned were generally effective and timely.

The inspectors conducted a five year review of the radiation monitoring system. This system includes process radiation monitors, area radiation monitors, and containment radiation monitors. The inspectors interviewed the program owner and reviewed corrective action documents, inspection reports, inspection procedures, and system health reports. The inspectors evaluated in-progress and planned actions and performed a partial system walkdown.

The radiation monitoring system had experienced intermediate interruptions and failures over the past five years. The licensee attributed these failures to communication issues that were associated with the series orientation of the instrumentation in the radiation monitor system loops. The licensee had implemented corrective actions to address the issues on a long-term basis. The most recent corrective action was the replacement of the optical stimulator chips that each instrument contained. Following the replacement of these optical stimulator chips, performance from the radiation monitoring system improved. At the end of this inspection, the licensee planned to replace the power supply in each instrument to further the improvements in consistent communication in the radiation monitoring system loops. The inspectors verified the performance improvements through data review and smart sampling of the CAP.

i) Observations Corrective Action Program Vulnerability The inspectors identified a programmatic vulnerability in the licensees CAP process associated with inadvertently eliminating the ability to track corrective actions to address condition reports. The inspectors also identified that a completed corrective action was later removed without any involvement of the CAP.

Licensee procedure PI-AA-125, Corrective Action Program Procedure, allows items that are assigned as corrective actions to be closed to a WO task in the maintenance planning process where they will be tracked to completion. A priority designation of C2 is assigned to a corrective action that has been closed to a WO task versus a C priority which is assigned to a routine maintenance activity. The C2 designation provides an administrative control that allows the licensee to track corrective actions in the maintenance planning process through enhanced visibility in the work management system. Although not procedurally driven, the licensee stated that there is an expectation that prior to revising a work item from a C2 priority to a C priority, the work item should be reviewed by MRC.

During a review of open and closed corrective actions in the licensees CAP database, the inspectors identified several instances where a corrective action was closed to a WO with a C2 priority only to have that WO be closed or cancelled and the corresponding work rolled into a WO with the different priority of C. For example, as documented in AR 02657045, the licensee created a corrective action to perform a like-for-like replacement of the Unit 2 main generator reverse power relays during the upcoming B2R20 refueling outage. Once the applicable WOs were coded as C2, the corrective action was closed in the CAP database. Subsequently, the WOs created from the corrective action were cancelled and the relay work was rolled into a different WO with a C priority. Based on the inspectors inquiry, the licensee recoded the work as C2 and entered this issue into the CAP as AR 04042808 for evaluation. This issue represents a programmatic vulnerability that could eliminate the ability to track corrective actions in the work management process.

Additionally, the inspectors identified one instance of a completed corrective action that was subsequently removed without any involvement of the corrective action process.

Specifically, as documented in AR 01688846, the licensee created a corrective action to mark the engineered safeguards features (ESF) switchgear rooms and 6.9 Kilovolt (kV)switchgear rooms as No Radio Areas, to prevent spurious actuation of degraded protective relays due to radio interference. The corrective action was closed to WO 01832505, which was subsequently performed and annotated as complete.

However, during this inspection, the inspectors identified that none of the ESF switchgear rooms or 6.9 kV switchgear rooms were marked off as No Radio Areas.

The licensee later determined that the markings were most likely removed by repainting of the doors. The licensees CAP process does not contain any provision to evaluate any impact before undoing this type of corrective action. The licensee entered this issue into their CAP as AR 04044524. The inspectors determined that this issue was minor because the licensee performed quarterly visual inspections of the diesel generator protective relays in the switchgear room and did not identify any degradation of the relays.

ii) Findings Failure to Perform Maintenance in Accordance with Performance Centered Maintenance Template

Introduction:

The inspectors identified a finding of very low safety significance (Green)and an associated non-cited violation (NCV) of TS 5.4.1, Procedures, when licensee personnel failed to perform maintenance in accordance with written procedures as required by Regulatory Guide 1.33. Specifically, from November 2013 through March 2017, the licensee failed to develop and execute work instructions of sufficient scope to accomplish the preventive maintenance to replace flexible hoses on the essential service water (SX) makeup pumps and the diesel-driven auxiliary feedwater (AFW) pumps and did not have a technical justification for a deviation from the Exelon Corporate Performance Centered Maintenance (PCM) template.

Description:

During this inspection, the inspectors reviewed a sample of corrective actions to address prior NRC-identified violations. The licensee documented a NCV in the fourth quarter 2013 integrated inspection report that was issued on February 3, 2014, for the failure to have adequate procedures in place that incorporated preventive maintenance schedules for the replacement of SX makeup pump diesel engine flexible hoses in accordance with the vendor recommendations and Exelon Corporate PCM templates. Specifically, the licensee was only inspecting the flexible hoses on the SX makeup pump diesel engines instead of replacing them in accordance with the PCM template for small diesel engines.

The PCM template specified a 12-year replacement frequency for the flexible hoses that was based, in part, on industry operating experience that reflected a service life of 15 to 20 years for the flexible hoses. A technical evaluation performed by an external contractor also concluded that a 12-year replacement frequency was aligned with the manufacturers recommendation of 700 to 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> of operation between preventive maintenance replacements. At the time of the previous NRC inspection, the licensee was unable to provide flexible hose replacement documentation for 43 of the 52 SX makeup pump flexible hoses since Unit 1 and Unit 2 began commercial operation in 1985 and 1987, respectively. Additionally, the Unit 1 and Unit 2 AFW pump flexible hoses were being inspected instead of being replaced on a 12-year frequency.

The licensee documented the issue in their CAP as AR 01582656 and AR 01590368 and created corrective actions to track the implementation of service requests to ensure that the previously issued NRC violation was adequately addressed. These service requests were intended to establish a flexible hose replacement schedule frequency for the SX makeup pumps and diesel-driven AFW pumps of 12 years in accordance with the PCM template.

The inspectors noted that from November 2013 through March 2017, the licensee did not replace all of the applicable flexible hoses on each affected system despite five available work window opportunities associated with WOs 01649132, 01778793, 01847544, 01760098, and 01888896.

The licensee performed a work group evaluation concerning the issue and determined, in part, that the WOs that were written to replace the flexible hoses did not contain the proper scope to credit the maintenance. Licensee procedure MA-AA-716-010, Maintenance Planning, states, in part, that work packages should be developed with instructions to a level of detail appropriate for the circumstances, which address the aspects of the work package. Specifically, the scope of work should be addressed in either the work package or procedures used within the work package. On at least four different occasions, the work package scope as written in the work package, or procedures contained in the work package, were not sufficient to direct workers to replace vice inspect the flexible hoses, change out all the applicable flexible hoses, or allowed enough lead time for replacement flexible hoses to be ordered to accomplish the preventive maintenance.

Additionally, the service request for the diesel-driven AFW pumps was created on February 28, 2014, but was subsequently canceled on March 17, 2014. A new service request for the diesel-driven AFW pumps was created on August 25, 2015, and approved on December 1, 2015. After the original service request was canceled, but prior to the second service request being approved, WO 01649132 was performed on the Unit 2 diesel-driven AFW pump. At that time, the flexible hoses were only inspected in accordance with the WO instead of being replaced as required by the PCM template.

Licensee procedure ER-AA-200, Performance Centered Maintenance, states, in part, that all deviations from the PCM template shall have a technical basis documented by the site subject matter expert. No such technical basis was documented by the licensee for continuing to inspect the flexible hoses instead of replacing them after the NCV was issued in 2014.

The licensee entered this issue into their CAP as Action Requests (AR) 03961955, AR 03971962, and AR 04045769. The licensee planned to replace the flexible hoses for each affected diesel-driven AFW pump at the next available opportunity starting with the Unit 2 diesel-driven AFW pump during the Unit 2 fall 2017 refueling outage. This issue was not a current safety concern because the licensee has performed visual inspections of the hoses and verified that they were functional. The licensee planned to continue to monitor system performance during periodic testing.

Analysis:

The failure to perform maintenance in accordance with written procedures as required by TS 5.4.1, Procedures, and Regulatory Guide 1.33 was a performance deficiency.

Using guidance in Inspection Manual Chapter (IMC) 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012, the inspectors determined that the performance deficiency was more than minor because it was associated with the Mitigating Systems cornerstone attribute of Equipment Performance and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to replace flexible hoses on the SX makeup pumps and the Unit 1 and Unit 2 diesel-driven AFW pumps at a pre-established frequency as required by preventive maintenance procedures could allow hose degradation to remain unidentified and lead to the inoperability of these safety-related systems.

The inspectors evaluated the finding using the Significance Determination Process (SDP) in accordance with IMC 0609, Attachment 4, Initial Characterization of Findings, dated October 7, 2016, which directed the inspectors to IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, Exhibit 2, Mitigating Systems, dated June 19, 2012. The inspectors answered Yes to question A.1, If the finding is a deficiency affecting the design or qualification of a mitigating SSC, does the SSC maintain its operability or functionality, therefore the finding screened as having very low safety significance (Green).

The inspectors determined this finding affected the Cross-Cutting area of Human Performance in the aspect of Work Management where the organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. Specifically, since originally identified by the U.S. Nuclear Regulatory Commission (NRC) in 2013, the licensee failed to replace all of the applicable flexible hoses on each of the affected diesel engines in accordance with their associated maintenance strategy as well as the corporate PCM template [H.5].

Enforcement:

Technical Specification 5.4.1.a, Written Procedures, requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Appendix A, lists administrative procedures for performing maintenance and states, in part, that maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate for the circumstances.

The stated purpose of licensee procedure ER-AA-200, Preventive Maintenance Program, was to maintain plant structures, systems and components (SSCs) at an appropriate state of reliability based on the relative importance of the SSCs to safety, production and cost. The procedure stated, in part, that the site subject matter expert develops a maintenance strategy for a component using the Exelon Corporate PCM template as a guide and that all deviations from the PCM template shall have a technical basis documented by the site subject matter expert.

Additionally, the stated purpose of licensee procedure MA-AA-716-010, Maintenance Planning, was to provide guidance on the requirements and expectations of the maintenance planning process. The procedure stated, in part, that work packages should be developed with instructions to a level of detail appropriate for the circumstances, which address the aspects of the work package. Specifically, the scope of work should be addressed in either the work package or procedures used within the work package.

Contrary to the above, from February 3, 2014, through the end of this inspection on August 25, 2017, the licensee failed to document a technical basis for deviating from the PCM template for small diesel engines and failed to develop work instructions for the replacement of flexible hoses on the SX makeup pumps and the Unit 1 and Unit 2 diesel-driven AFW pumps to an appropriate level of detail such that the scope of work to be performed was understood and executed in accordance with the assigned preventive maintenance. As a result, each engine had flexible hoses that remained in service past the 12-year replacement frequency specified in the PCM template.

At the end of the inspection, the licensee planned to replace the flexible hoses in each of the four affected diesels at the next available opportunity. Because this violation was of very low safety significance and was entered into the licensees CAP as ARs 03961955, 03971962, and 04045769, this violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy. (NCV 05000454/2017007-01; 05000455/2017007-01, Failure to Perform Maintenance in Accordance with Performance Centered Maintenance Template)

Failure to Promptly Identify Degraded Reactor Containment Fan Cooler Circuitry

Introduction:

The inspectors identified a finding of very low safety significance (Green)and an associated NCV of Title 10 of the Code of Federal Regulations (CFR),Part 50, Appendix B, Criterion XVI, Corrective Action, when the licensee failed to promptly identify a condition adverse to quality resulting in a safety-related system becoming inoperable. Specifically, from May 5, 2017, to August 4, 2017, the licensee failed to trend available surveillance data in a timely manner and did not identify a degraded condition in the 1A Reactor Containment Fan Cooler (RCFC) time delay circuitry prior to the system becoming inoperable.

Description:

During this inspection, the inspectors reviewed a sample of corrective actions from the licensees CAP to assess their effectiveness.

The inspectors reviewed an apparent cause evaluation (ACE) documented in AR 02507247 concerning a 1D RCFC surveillance testing failure that occurred on May 29, 2015. Specifically, during the performance of surveillance procedure 1BOSR 3.2.8-610B, Unit One ESFAS [Engineered Safety Features Actuation System]

Instrumentation Slave Relay Surveillance And Automatic Actuation Test (Train B Automatic Safety Injection - K610), a time-delay relay failed to shift the 1D RCFC from high speed to low speed within the 33 second acceptance criterion, rendering the 1D RCFC inoperable. During an extent of condition evaluation, the licensee identified that the same type of relay was used in the same application in the other seven RCFCs.

While performing the ACE discussed above, the licensee discovered that a previous 1D RCFC surveillance test performed on October 31, 2014, identified that although the surveillance data obtained met the acceptance criterion, the recorded time-delay relay actuation time of 28.39 seconds was much longer than what had been previously recorded. Additionally, the time measured for the 1D RCFC to start from an initial stopped condition was only 3.41 seconds; much shorter than the expected time of 20 seconds. To address this issue, the licensee generated a WO for troubleshooting the abnormal start times; however the WO was not scheduled to be performed until March of 2016.

The ACE discussed above ultimately concluded that gaps in system performance monitoring prevented a degrading 1D RCFC time-delay relay from being properly addressed prior to failure. The licensee implemented a corrective action to add trending of the time-delay relays to the RCFC system monitoring plan.

On August 4, 2017, during the performance of 1BOSR 3.2.8-610A, Unit One ESFAS Instrumentation Slave Relay Surveillance and Automatic Actuation Test (Train A Automatic Safety InjectionK610), and as documented in AR 04039037, a time-delay relay failed to shift the 1A RCFC from high speed to low speed within the 33 second acceptance criteria, rendering the 1A RCFC inoperable. The inspectors reviewed the previous surveillance for the 1A RCFC that was performed on May 5, 2017, and identified that although the surveillance data obtained met the acceptance criteria, the recorded time-delay relay actuation time of 27.17 seconds was much longer than what had been previously measured. The inspectors also identified that the time recorded for the 1A RCFC to start from an initial stopped condition was 28.85 seconds; much longer than the expected time of 20 seconds. However, since both of these recorded values were within the acceptance criteria of 1BOSR 3.2.8-610A, no issue reports were generated.

Based on the corrective actions to add trending of time-delay relay surveillance data to the RCFC system monitoring plan to address the May 29, 2015, 1D RCFC surveillance failure, the inspectors questioned whether licensee staff had reviewed the trend data from the May 5, 2017, surveillance test of the 1A RCFC. The licensee stated that although the data was available from the 1A RCFC surveillance performed in May, it had not been captured and trended in the RCFC system monitoring plan prior to the 1A RCFC failure that occurred on August 4, 2017. Therefore, no condition report was generated and no assessment was made concerning the data. Additionally, the licensees RCFC system monitoring plan only specified that trending data be recorded during the 1BOSR 3.2.8-610A 18-month surveillance portion of the procedure, and did not require trending of data recorded during the 1BOSR 3.2.8-610A quarterly surveillance portion of the procedure. As such, only two data points had been recorded in the RCFC system monitoring plan for the 1A RCFC since 2015.

The licensee entered this issue into their Corrective Action Program (CAP) as AR 04039037 and AR 04045767 and performed a work group evaluation to determine additional corrective actions to address this issue. These actions include updating the RCFC system monitoring plan to identify large changes in time-delay relay actuation times and improving coordination between engineering and operations to reduce the time required for engineering to obtain RCFC surveillance data for trending after surveillances were completed. The licensee also discussed assessing whether more data could be collected for the relays by adding the time-delay relay actuation data from the quarterly surveillances to the data recorded during the 18-month surveillance.

Analysis:

The failure to promptly identify a condition adverse to quality associated with the time-delay relay circuitry in the 1A RCFC was a performance deficiency. Using the guidance in IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012, the inspectors determined that the performance deficiency was more than minor because it was associated with the Mitigating Systems cornerstone attribute of Equipment Performance and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to identify a degraded condition in the time-delay circuitry associated with the 1A RCFC resulted in a missed opportunity for the licensee to evaluate the cause and initiate prompt actions to respond to the degraded condition prior to failure.

The inspectors evaluated the finding using the SDP in accordance with IMC 0609, 4, Initial Characterization of Findings, dated October 7, 2016, which directed the inspectors to IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012. The inspectors answered No to questions A.1 through A.4 and therefore the finding screened as having very low safety significance (Green).

The inspectors determined that this finding affected the Cross-Cutting area of Problem Identification and Resolution in the aspect of Trending where the organization periodically analyzes information from the CAP and other assessments in the aggregate to identify programmatic and common cause issues. Specifically, information was available that indicated a degraded condition in the 1A RCFC time-delay relay circuitry for three months prior its failure, but was not identified and evaluated [P.4].

Enforcement:

Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that conditions adverse to quality, such as deficiencies, deviations, and defective material and equipment, are promptly identified.

Contrary to the above, from May 5, 2017, to August 4, 2017, the licensee failed to promptly identify a condition adverse to quality in the 1A RCFC time-delay circuitry.

Specifically, the licensee failed to trend surveillance data in a timely manner and did not identify a degraded condition in the 1A RCFC time-delay circuitry prior to the system becoming inoperable. Trending of the time-delay relays in the RCFC system monitoring plan was established as a corrective action from a previous failure of a similar relay in the 1D RCFC.

As an immediate action, the licensee planned to update the RCFC system monitoring plan to note abnormal changes in time-delay relay actuation times and improve coordination between engineering and operations to reduce the time required for engineering to obtain RCFC surveillance data for trending after surveillances were completed. Because this violation was of very low safety significance and was entered into the licensees CAP as AR 04039037 and AR 04045767, this violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy. (NCV 05000454/2017007-02; 05000455/2017007-02, Failure to Promptly Identify Degraded Reactor Containment Fan Cooler Circuitry)

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed the licensees implementation of the facilitys Operating Experience (OE) program. Specifically, the inspectors reviewed the OE program implementing procedures, attended CAP meetings to observe the use of OE information, and reviewed licensee evaluations of OE issues and events. The objective of the review was to determine whether the licensee was effectively integrating OE into the performance of daily activities, whether evaluations of issues were appropriate, whether the licensees program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of OE, were identified and implemented in an effective and timely manner.

b. Assessment The inspectors observed that operating experience was discussed as part of daily and pre-job briefings. Operating experience evaluations included NRC generic communications, significant industry issues, and Part 21 reported issues. Additional industry OE was disseminated across plant departments for their review and use, if needed. Specific equipment-related issues were distributed to appropriate engineers for evaluation and screening into the CAP. The inspectors also verified that the use of OE in formal CAP products such as root cause evaluations and equipment apparent cause evaluations was appropriate and adequately considered. Generally, OE that was applicable to Byron Station was thoroughly evaluated and actions were implemented in a timely manner to address any issues that resulted from the evaluations.

Based on the results of the inspection, the inspectors concluded that OE was effectively utilized at the station. No significant issues were identified during the inspectors review of selected licensee OE evaluations.

c. Findings

No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed department self-assessments and Nuclear Oversight audits, as well as the schedule of past and future assessments. The inspectors evaluated whether these audits and self-assessments were effectively managed, adequately covered the subject areas, and properly captured identified issues in the CAP. In addition, the inspectors interviewed licensee personnel regarding the implementation of the audit and self-assessment programs.

b. Assessment Based on the results of the inspection, the inspectors concluded that self-assessments and audits were typically accurate, thorough, and effective at identifying issues and enhancement opportunities at an appropriate threshold. The inspectors concluded that these audits and self-assessments were completed by personnel knowledgeable in the subject area. In many cases, these self-assessments and audits had identified numerous issues that were not previously recognized by the station. These issues were entered into the CAP as required by the licensees procedures. The inspectors also determined that findings from the CAP self-assessment were consistent with the inspectors assessment.

c. Findings

No findings were identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

The inspectors assessed the licensees safety conscious work environment (SCWE)through a review of the facilitys Employee Concerns Program (ECP), Safety Culture Monitoring Panel (SCMP), CAP, and Safety Culture Surveys. The inspectors reviewed these programs implementing procedures, ECP cases, SCMP condition reports, CAP documents and the results of licensee initiated safety culture surveys and pulses conducted in 2016 and 2017.

The inspectors interviewed eight individuals and conducted five focus group meetings. A total of 37 licensee staff and contractors participated in these discussions.

The interviews and focus groups included individual contributors, supervisors, and managers from the licensee and its contractor organizations. During the interviews and focus group meetings, the inspectors assessed the staffs willingness to raise nuclear safety issues. Additionally, the inspectors interviewed other personnel informally to ascertain their views on the effectiveness of the CAP and their willingness and freedom to raise issues.

The inspectors selected interviewees to include program owners, managers and individuals with knowledge of selected plant issues. The inspectors selected focus group participants to provide a distribution across various departments at the site as well as a top to bottom review of the engineering department. In addition to assessing individuals willingness to raise nuclear safety issues, the individual interviews and focus group meetings included discussion on any issues over the last 12 to 24 months that affected the SCWE at the plant. Items discussed included:

• knowledge and understanding of the CAP;

• effectiveness and efficiency of the CAP;

• willingness to use the CAP; and

• knowledge and understanding of the ECP.

The inspectors also discussed the functioning of the ECP with the program coordinator, reviewed program logs from 2015 through 2017, and reviewed selected case files to identify any emergent issues or potential trends.

b. Assessment The inspectors did not identify any issues of concern regarding the licensees SCWE, nor did the inspectors observe any evidence of a chilled environment at the Byron Station. Information obtained from interviews and focus groups indicated that an environment was established where licensee personnel felt free to raise nuclear safety issues without fear of retaliation. Licensee personnel were generally aware of and familiar with the CAP and other processes, including the ECP and the NRCs allegation process, through which concerns could be raised. In addition, a review of the types of issues in the ECP indicated that the licensee staff members were appropriately using the CAP and ECP to identify issues. The inspectors did not observe and were not provided any examples where there was retaliation for raising nuclear safety issues. Documents provided to the inspectors regarding surveys and monitoring of the safety culture and SCWE generally supported the conclusions from the interviews.

c. Findings

No findings were identified.

4OA6 Management Meetings

Exit Meeting On June 23, 2017, the inspectors presented the inspection results to Mr. P. Boyle and other members of the licensee staff. The licensee acknowledged the issues presented.

The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

T. Chalmers, Plant Manager

G. Armstrong, Organizational Effectiveness Manager

B. Barton, Radiation Protection Manager

P. Boyle, Work Management Director

G. Gugle, Maintenance Director

C. Keller, Engineering Director

D. Spitzer, Regulatory Assurance Manager

H. Welt, Operations Director

U.S. Nuclear Regulatory Commission

K. Stoedter, Branch Chief

J. McGhee, Senior Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Open

05000454/2017007-01 NCV Failure to Perform Maintenance in Accordance with Performance Centered Maintenance Template (Section 4OA2.1.b.3.ii)

05000454/2017007-02 NCV Failure to Promptly Identify Degraded Reactor Containment Fan Cooler Circuitry (Section 4OA2.1.b.3.ii)

Closed

05000454/2017007-01 NCV Failure to Perform Maintenance in Accordance with Performance Centered Maintenance Template (Section 4OA2.1.b.3.ii)

05000454/2017007-02 NCV Failure to Promptly Identify Degraded Reactor Containment Fan Cooler Circuitry (Section 4OA2.1.b.3.ii)

Discussed

None.