IR 05000455/1986024

Insp Rept 50-455/86-24 on 860716-0912.Violation Noted: Failure to Specify Adequate Containment Ventilation Test Criteria

ML20214U298
Person / Time
Site:	Byron
Issue date:	09/23/1986
From:	Forney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20214U284	List: IR 05000455/1986024 ML20214U280 ML20214U289
References
50-455-86-24, NUDOCS 8609300569
Download: ML20214U298 (11)

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x U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-455/86024(DRP)

Docket No. 50-455 License No. CPPR-131 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Byron Station, Unit 2 Inspection At:. Byron Station, Byron, IL Inspection Conducted: July 16 - September 12, 1986 Inspectors: J. M. Hinds, J P. G. Brochman R. M. Lerch J. A. Malloy M. L. McCormick-Barger RFidu W Approved By: W. L. Forney, Chief #43/p4 Reactor Projects Section IA Date '

Inspection Summary:

Inspection on July 16 - September 12, 1986 (Report No. 50-455/86024(DRP))

Areas Inspected: Routine, unannounced safety inspection by the res1 dent inspectors and two regional inspectors of licensee action on previous inspection findings; followup of vendor branch report; 10 CFR 50.55(e)

report; IEBs; Part 21 Report; Byron SER Items; pre-operational testing; operating procedures; maintenance procedures; emergency procedures; housekeeping; independent inspection; allegations; licensee actions following suspected drug use; management meetings; and other activitie Results: Of the 14 areas inspected, no violations or deviations were identified in 13 areas; one violation was identified in the remaining area:

(failuretospecifyadequatetestcriteria-Paragraph 8). This violation was of minor safety significance and did not affect the public health and safet PDR ADOCK 05000455 G PDR

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DETAILS Persons Contacted Coninonwealth Edison Company

$T. Maiman, Vice President and Manager of Projects

• $#R. Querio, Station Manager

$#V. Schlosser, Project Manager R. Pleniewicz, Production Superintendent

'*$#R. Ward, Services Superintendent

$#R. Tuetken, Startup Superintendent, Byron

$C. Tomashek, Startup Superintendent, Braidwood

$#E. Martin, Quality Assurance Superintendent

• $W. Burkamper, Quality Assurance Supervisor L. Sues, Assistant Superintendent, Operating G. Schwartz, Assistant Superintendent, Maintenance T. Joyce, Assistant Superintendent, Technical Services

• R. Moravec, Assistant Superintendent, Project Construction W. Blythe, Operating Engineer, Unit 0

1. D. Brindle, Operating Engineer, Unit 2

• A. Chernick, Regulatory Assurance Supervisor F. Hornbeak, Technical Staff Supervisor R. Flahive, Radiation / Chemistry Supervisor

1. E. Falb, Startup Supervisor, Unit 2

• Grabins, Assistant Startup Supervisor, Unit 2 SM. Snow, Assistant Regulatory Assurance Supervisor

1. D. Milroy, Startup Engineer

$#E. Zittle, Regulatory Assurance Staff

• 1. K. Yates, Nuclear Safety

$D. Berg, Nuclear Safety Engineer

$W. Bielasc, Station Health Physicist

• J. Pausche, Regulatory Assurance Group Leader The inspector also contacted and interviewed other licensee and contractor personnel during the course of this inspectio # Denotes those present during the management meeting on August 28, 198 $ Denotes those present during the management meeting on September 11, 198 * Denotes those present during the exit interview on September 12, 198 . ActiononPreviousInspectionFindings(92702) (Closed) Violation (455/84049-01(DRS)): Calculations which provided original justification for PHI factor were not retrievable. Based on discussions with the inspector responsible for this item, the licensee's corrective actions were acceptable and the issue was considered resolved for Byron at the time of issuance. Also, see Section I., Introduction to Inspection Report 455/84049. Therefore, no further inspection is required and this item is close _ _

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. (Closed) Violation 455/84049-02(DRS)): Failure to meet code requirements for slenderness ratio (KL/R) for HVAC duct support Based on discussions with the inspector responsible for this item, the licensee's corrective actions were acceptable at the time of issuance. Also see Section I, Introduction to Inspection Report 455/84049. Therefore, no further inspection is required and this item is close . Followup on Vendor Program Branch Report (92716)

(Closed) Vendor Program Branch (VPB) Generic Issue (455/84003-PP(DRP)):

Problems with excessive blowdown on Dresser Main Steam Code Safety Valves. Region III requested that the inspectors review the issue identified in VPB Inspection Report 99900054/84-01. In resposne to the inspectors questions the licensee issued Nuclear Work Request B27712 to require adjustment of blowdown rings on all 20 main steamline safety valves per instructions provided by the vendor, Dresser Industrie The specific adjustments will provide a blowdown of 6% i 3%, for any set pressure. The work was completed on April 17, 1986. This item is considered close . 10 CFR 50.55(e) Reports (92700)

(Closed)50.55(e) Report (455/85002-EE(DRP)): Containment Sump Valves not seismically qualifie The licensee's Engineering Department reported on May 15, 1985 that based on a report by the valve manufacturer, Xomox, containment isolation valves, 2RF026 and 2RF027, were not seismically qualified. Xomox supplied drawings for installation of brackets on the valves that would qualify them. The inspector verified that these brackets have been installed. Based on the installation of the brackets on the valves, this item is close . IE Bulletin (IEB) Followup (92703) (Closed) IEB (455/81002-88) and IEB Supplement (455/81002-18):

Failure of Gate Type Valves to close against differential pressur The inspector reviewed the applicant's response letters dated July 8, 1981, November 16, 1981 and March 25, 1982, which identified those valves requiring modification and the nature of planned modifications for each valve. The inspector reviewed Westinghouse Facility Change Notice (FCN) CBEM 10573A under which the required modifications for Byron, Unit 2, were accomplished. Based on a review of procurement documents, work instructions, completed quality control checklists and test reports contained in the FCN package the inspector verified that required modifications were successfully completed for Byron Unit 2. This item is considered close (Closed)IEB(455/85001-BB): Steam Binding of Auxiliary Feedwater Pumps. The inspector reviewed Byron Abnormal Operating Procedure 2 B0A Sec 7. " Auxiliary Feedwater Check Valve Leakage - Unit 2", and verified that instructions were provided for recovering from

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elevated temperatures in the auxiliary feedwater pumps or discharge piping. The inspector also reviewed Byron Operating Procedure B0P 199-AG1, "AF Readiness /U-2", and verified that periodic monitoring of piping temperature was performed and that corrective actions were specified if the temperature exceeded 130 F. Based on these actions this IEB is considered closed. Additionally, the requirements of Temporary Instruction (TI) 2515/69 have'been completed and this TI is also considered close (Closed) IEB (455/86002-BB): Problems with Differential Pressure switche For this IEB the inspector verified that the written response was within the time period stated in the bulletin, that the written response included the information required to be .

reported, that licensee management forwarded copies of the written response to the appropriate onsite management representatives and that infonnation discussed in the licensee's written response was accurat This IEB requested the licensee to identify any uses of Static "0" Ring (SOR) differential pressure switches, SOR Series 102 or 103, as electrical equipment important to safety, as defined by 10 CFR 50.49(b). The licensee's response stated that no SOR Series 102 or 103 differential pressure switches are installed at Byron as equipment important to safety. Based on this response this IEB is considered closed. Additionally, the requirements of Temporary Instruction (TI) 2515/81 have been completed and this TI is also considered close No violations or deviations were identifie . 10CFRPart21 Reports (92716)

(Closed)10CFRReport(455/85004-PP): Failure of Parker-Hannafin air line check valves to seat on slow bleedoff of supply air. The inspector reviewed the licensee's response and verified that the air line check valves were replaced with stainless steel valves of-improved desig The licensee had successfully tested the check valves in the Main Stea Preoperational Retest 2025. Based on the satisfactory test of the new design valves this item is considered close . Byron Safety Evaluation Report (SER) Items (92719)

(Closed)SERItem(455/83000-02): Addition of outer debris screen to containment recirculation sump. The inspector reviewed Byron Unit 2 Mechanical Drawing M-195, Revision AD, which illustrated the outer debris screens to be installed prior to Unit 2 operation. The inspectors determined by visual. observation that the debris screens were installed per desig .

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8. Preoperational Test Witnessing (70317, 70434, 70438, 70445)

The. inspectors witnessed portions of the below listed preoperational test procedures to verify that testing was conducted in accordance with approved procedures; that all test equipment was properly installed; that test data was collected and recorded properly; and that test deficiencies were documented and test changes were processed in an approved manne AF 2.03.60, " Auxiliary Feedwater" EF 2.26.62, "ESF Logic" EF 2.26.60, "ESF Safeguards" VP 2.93.62, "RCFC Testing" No concerns were identified during the performance of test procedures AF 2.03.60, EF 2.26.62, and EF 2.26.60. During the performance of procedure (VP)2.93.62, " Containment Ventilation", the inspector observed taking and recording of test data required by the procedure. The inspector also observed personnel recording containment air temperature and calculation of containment air density, although this was not required by the test procedure. This test verifies the operation of the Reactor Containment Fan Coolers (RCFC) at air densities approximately equivalent to the air densities which would be found in containment following a loss-of-coolant acciden The Byron FSAR Section 6.2.2.4.1.d requires that the RCFCs be tested at air densities approximately equivalent to the air densities which would be found in containment following a loss-of-coolant accident. The containment air density is dependant on the temperature and pressure of the air in containment. However, a review of test procedure VP 2.93.62 identified that, although the containment air pressure was specified, the procedure did not specify nor control the temperature or density of the air in containment. 10 CFR 50, Appendix B, Section XI, requires that all testing necessary to demonstrate that components will perform satisfactorily shall be accomplished in accordance with written test procedures appropriate to the circumstance By observation and discussion with the licensee, it was determined that the necessary data had been taken and that the necessary calculations had been performed for both Units 1 and 2. The licensee was able to satisfactorily perform this test because the engineers controlling the testing were knowledgeable in the design basis for the test. However, the failure to include test criteria in an approved test procedure, necessary to demonstrate that the RCFCs would perform satisfactorily, is a violation of 10 CFR 50, Appendix B, Section XI (455/86024-01(DRP)).

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program. A review of the PTL overinspection data, dated July 16, 1986, indicates each inspector and his total number of inspections including final rejects. It should be noted that an Independent 3rd party Level III reviewed all overinspection rejects of a subjective weld quality nature and in certain instances, overrode the initially rejected weld The subject summary reflects the performance of eleven (11) inspector Two (2) inspectors were excluded from the population due to insufficient inspection sample size. Additionally, the two (2) inspectors with the highest rejection percentage, and two (2) inspectors with the lowest percentage were excluded from the population to avoid influencing the summary with extremes. Listed below is the subject summary:

Inspector No. of Inspections Rejects Reject % 3rd Party Overrides fJ )( Jdf%/ 11 jgy,fW ._? #/,, d 65 ,,4' 25 . 163 3 . 1544 30 f ,L%)of 12 1 gg f _.1# 2 ,5' 17 ,.Y ,0 % )<l 1 JJ .E' W hV 7 .0 0 1 .0 0 1 .0 0 Total 6443 2IMJ' .146 < 'JE 1kr // 7 Average 586 g, y Md' .6 The NRC inspector also observed the office activities of the PTL overinspection group to see what the work assignment entailed. The individual was contacted and asked to review what he did as part of the overinspection. He related the closecut process required for field work completion and incorporation of the change onto drawings. Several FCR packages were reviewed step-by-step. The individual gave an articulate, thorough and knowledgeable description of his work activities, demonstrating an ability to read drawings and forms, and to select the 10% sample required for overinspection. The inspector found nothing to indicate that the individual was not qualified or was incapable of performing his work assignment _- - _ _ _ _ .

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. Operating Procedure Review (42450)

The inspector's reviewed general plant operating, system operating, chemistry surveillance, operating surveillance and technical specifica-tion surveillance procedures. Procedures were reviewed for compliance and consistency with proposed Technical Specifications, Regulatory Guide 1.33 and ANSI N18.7-1976/ANS- The following procedures were selected for review:

2 BGP 100-2, R-51, " Plant Startup" 2 BGP 100-5, R-0, " Plant Shutdown and Cooldown" 2 B0P AB-1, R-51, " Recycle Evaporator Startup" 2 BCS 1.2.5 A.1-1, R-0, " Unit 2 Borated Water Source at Shutdown-Weekly" 2 BOS 1.1.4.A-1, R-51, " Reactor Coolant System Minimum Temperature for Criticality Surveillance" 2 BVS 4.5.0-1, R-0, " Eddy Current Testing of Steam Generator U-Tubes" As a result of this review, the inspector identified items of concern and provided comments to the licensee for consideration. No regulatory concerns were identified and the inspector concerns were resolved satisfactoril No violations or deviations were identifie . Maintenance Procedure Review (42451)

A sample of Byron Maintenance Procedures (BMP) were reviewed for Units 1 and 2 and documented in Inspection Reports 454/85042 and 455/8402 Units 1 and 2 will use the same procedures. In addition, the following additional procedures: Administrative Procedures (BAP) and Operating Procedures (BGP), were reviewed to assure that they met the requirements of Regulatory Guide 1.33 and Section 13.5 of the Byron FSA BAP 400-3 "Setpoint/ Sealing Changes" BAP 400-4 " Control of Station Measurement and Test Equipment" BAP 400-5 " Preliminary Inspection of Equipment" BAP 400-6 " Procurement of Original Spare Parts" BAP 400-7 " Preventive Maintenance Program" BAP 400-9 " Maintenance Alterations" BAP 400-10 " Preparation of Station Traveler" BAP 400-11 " Preparation of Maintenance / Modification Procedures" BAP 400-14 " Maintenance and Surveillance of Environmentally Qualified Plant Equipment"

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4 BOP CV-3 '"Filling and Venting the CV System"

. B0P CV-4' " Draining the CV System" B0P RC-3 " Reactor Coolant System Fill and Vent"

B0P RC-4 " Reactor Coolant System Drain"

B0P FW-4b " Draining a Steam Generator Unit Two" The inspector provided comments to the licensee's staff for consideration i to improve the procedures, however, no regulatory concerns were identified. No violations or deviations were identified.

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. 11. Emergency Procedure Review (42452)

i' Byron Unit 2 Emergency Operating Procedures (E0P) have been written based i upon the Westinghouse-Owners Group (WOG) Emergency Response Guidelines,

! Revision 1. The inspector commenced a review of the E0Ps for compliance

and consistency with Technical Specifications, Regulatory Guide 1.33,

, ANSI N18.7-1976/ANS-3.2, and Byron Administrative Procedure 1310-A3, y

" Byron Emergency / Abnormal / Critical Safety. Function Procedures-Writers i

' Guide". -The inspector's review of these procedures is an ongoing effort-and will be documented in a. subsequent inspection report.

l j 12. Housekeeping /CareandPreservationofSafety-RelatedComponents(71302)

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i The inspectors' conducted plant tours of Unit 2 between July 16 through September 12,.1986. Areas of the Unit 2 plant observed durir.g the tours i' * included the containment, fuel handling and storage areas, auxiliary building areas including the Unit 2 portion of the control room, and the

turbine building. Areas were inspected for work in progress,. state of i cleanliness, overall housekeeping, state of fire protection equipment and methods being employed, and the care and preservation of safety-related

components and equipment. The inspectors were accompanied by licensee .

personnel on portions of the tours for the purpose of identifying areas  !

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where additional housekeeping efforts should be concentrated to improve the overall cleanliness'of Unit 2. Inspector concerns were related to ,

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Observations of work in progress included: Witnessing testing of Unit 2 containment tendons, installation of RTD wells in reactor coolant

[ system piping, and containment painting activities.

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No violations or deviations were identified.

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{ 1 IndependentInspection(71302)

On August 18, 1986 while performing a fuel pool cooling surveillance, the licensee inadvertently discharged approximately 500 gallons from the

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a leaking valv Fifty-one new fuel assemblies are stored dry in the spent fuel storage pool for the Unit 2 initial fuel loading. The inspectors observed the licensee's inspection of five fuel assemblies in the area of the discharge path. Results of the inspection indicated that no fuel assemblies were wetted, contaminated or otherwise damage . ' Followup of Allegation RIII-A-86-007 (99014)

The-NRC received additional correspondence enclosing, as documentation, a clinical psychologist report dated June 25, 1984 which described one P.ittsburg Testing Laboratory (PTL) inspector as having a normal IQ, however, due to weak reading skills, also described him as being

" functionally illiterate". The NRC inspector reviewed the certification package documenting the inspectors qualifications. The individual is certified as a Level II Inspector in 4 areas and the documentation shows that he passed six qualification exams froa, 1983 to 1986. A PTL employee who administered and graded one of the exams was questioned whether assistance was required by any employees being tested. His response was that no individuals he had given exams to required any

' help in reading, or required undue clarification of exams. In addition, he related that alrast all exams are given individually and thus other examinees would not be.present to give any such assistanc Licensee site QA management was aware of the individuals abilities and produced their own copy of the psychologist's report as soon as the inspector inquired about this individual. The QA manager. stated that comparisons could not be made with other individuals because such testing was not a Ceco policy but that this individual hr.d been singled out for

'this test by his supervisor'at the time. The individual had been made aware of the psychologist's report and the licensee produced a letter from an instructor at Sauk Valley College in Dixon, Illinois. The letter, dated December 10, 1984, stated that the individual had been enrolled in a reading course and that his reading test score had gone from 7.4 to 7.8 on the Iowa Level II, Fonn 7 Test. The test score indicates that the individual was reading at the seventh grade, fourth month level and improved to the seventh grade, eighth month leve The licensee stated that the individual's assignment was to perform overinspection reviews, and inspections of a sampic of inspections of previously inspected work. The licensee assembled comparative statistics of all the inspectors who had worked in the overinspection, showing the total number of inspections performed, the numbers of inspections agreed with, or rejected, and the number of overides of rejected inspections made by an independent Level III qualified inspector. The results of the work by the individual in question, falls in the middle of the results obtained by other inspectors. See the summary below and note the results of inspector No. Summary of PTL'0verinspection Rejection Rates Since the current PTL overinspection program was implemented in 1984, seventeen (17) certified PTL inspectors have participated in this

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program. . A review of the PTL overinspection data, dated July 16, 1986, indicates each inspector and his total number of inspections including final reject It should be noted that an Independent 3rd party Level i III reviewed all overinspection rejects of a subjective weld quality l nature and in certain instances, overrode the initially rejected weld The subject summary reflects the performance of eleven (11) inspector Two (2) inspectors were excluded from the population due to insufficient inspection sample' size. Additionally, the two (2) inspectors with the highest rejection percentage, and two (2) inspectors with the lowest I percentage were excluded from the population to avoid influencing the j summary with extremes. Listed below is the subject summary:

Inspector No. of Inspections Rejects Reject % 3rd Party Overrides .1 11 .0 65 .0 4 .8 0 .9 12 .8 17 .1 1 .4 7 .0 0 1 .0 0 1 .0 0 Total 6443 225 117 Average 586 2 .5% 1 The NRC inspector also observed the office activities of the PTL overinspection group to see what the work assignment entailed. The individual was contacted and asked to review what he did as part of the overinspection. He related the closecut process required for field work completion and incorporation of the change onto drawings. Several FCR packages were reviewed step-by-step. The individual gave an articulate, thorough and knowledgeable description of his work activities, demonstrating an ability to read drawings and forms, and to select the 10% sample required for overinspection. The inspector found nothing to indicate that the individual was not qualified or was incapable of performing his work assignment .

e This allegation was not substantiated and is considered close . Licensee Actions Concerning Suspected Drug Use (99014)

Concern: On July 17, 1986, the inspector was informed by the Byron Station Manager that the licensee had received an anonymous statement from an individual who identified an employee at the Byron Station whom the writer had reason to believe may be using drugs. The person named in this concern was a non-management employee, who performed safety related wor Findings: In keeping with the licensee's established drug awareness program, the employee was interviewed by Byron Supervisors and Managers and alieved of all duties at the Byron Station. The employee's photo identification security badge and access key-card were revoked and the individual's access was denied pending the outcome of an investigatio In keeping with the Commonwealth Edison established procedures, the employee provided an observed urine specimen to a licensee medical facility for analysis. The tests results of the urinalysis were negative. Additionally, a review of the employee's performance by station management did not identify any abnormal behavior prior to this accusation. Based on the negative test results, recommendations of Byron Management and endorsement by the company medical staff, the individual was restored to security status and returned to full dut This concern is considered close . Management Meetings (30702)

On August 28 and September 11, 1986, Messrs. C. E. Norelius, Director, Division of Reactor Projects (August 11 only), R. F. Warnick, Chief, Reactor Projects Branch 1 W. L. Forney, Chief, Reactor Projects Section 1A, R. M. Lerch, Byron Project Inspector, Ms. M. L. McCormick-Barger, Test Programs Inspector and the NRC resident inspector staff met with licensee management and supervisory personnel denoted in Paragraph 1 of this report. These meetings were held to assess overall facility status for licensin . Exit Interview (30703)

The inspectors met with licensee representatives denoted in Paragraph 1 at the conclusion of the inspection on September 16, 1986. The inspectors summarized the purpose and scope of the inspection and the findings. The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents / processes as proprietary.

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