IR 05000455/2002002

IR 05000455/2002-002, IR 05000455/2002-002 (Drp), on 12/30/2001-02/11/2002; Exelon Generation Company, LLC; Byron Station, Units 1 & 2. Post-Maintenance Testing. One Green Violation Identified

ML020710303
Person / Time
Site:	Byron
Issue date:	03/08/2002
From:	Ann Marie Stone NRC/RGN-III/DRP/RPB3
To:	Skolds J Exelon Generation Co, Exelon Nuclear
References
IR-02-002
Download: ML020710303 (26)

Text

rch 8, 2002

SUBJECT:

BYRON STATION, UNITS 1 AND 2 INSPECTION REPORT 50-454/02-002(DRP); 50-455/02-002(DRP)

Dear Mr. Skolds:

On February 11, 2002, the NRC completed an inspection at the Byron Station, Units 1 and 2.

The enclosed report documents the inspection findings which were discussed on February 19, 2002, with Mr. R. Lopriore and other members of your staff.

The inspection 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.

One issue of very low risk significance (Green) was identified by inspectors. The issue involved an inadequate post maintenance test and was determined to involve a violation of NRC requirements. However, because of its very low safety significance and because it was entered into your corrective action program, the NRC is treating the issue as a Non-Cited Violation in accordance with Section VI.A.1 of the NRCs Enforcement Policy. If you contest the Non-Cited Violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, Region III; Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Byron Station.

In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room). We will gladly discuss any questions you have concerning this inspection.

Sincerely,

/RA/

Ann Marie Stone, Chief Branch 3 Division of Reactor Projects Docket Nos. 50-454; 50-455 License Nos. NPF-37; NPF-66

Enclosure:

Inspection Report 50-454/02-002(DRP);

50-455/02-002(DRP)

REGION III==

Docket Nos: 50-454; 50-455 License Nos: NPF-37; NPF-66 Report No: 50-454/02-002(DRP); 50-455/02-002(DRP)

Licensee: Exelon Generation Company, LLC Facility: Byron Station, Units 1 and 2 Location: 4450 N. German Church Road Byron, IL 61010 Dates: January 1, 2002, through February 11, 2002 Inspectors: R. Skokowski, Senior Resident Inspector J. Adams, Senior Resident Inspector B. Kemker, Senior Resident Inspector P. Snyder, Resident Inspector D. Pelton, Senior Operations Inspector T. Tongue, Project Engineer R. Winter, Reactor Inspector R. Alexander, Radiation Specialist C. Thompson, Illinois Department of Nuclear Safety Approved by: Ann Marie Stone, Chief Branch 3 Division of Reactor Projects

SUMMARY OF FINDINGS IR 05000454-02-002(DRP), IR 05000455-02-002(DRP), on 12/30/2001-02/11/2002; Exelon Generation Company, LLC; Byron Station, Units 1 & 2. Post-Maintenance Testing.

The baseline inspection was conducted by resident and region based inspectors. The inspectors identified one Green finding associated with a Non-Cited Violation. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609, Significance Determination Process (SDP). The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described at its Reactor Oversight Process website at http://www.nrc.gov/NRR/OVERSIGHT/index.html. Findings for which the SDP does not apply are indicated by No Color or by the severity level of the applicable violation.

A. Inspector Identified Findings Cornerstone: Mitigating Systems

• Green. The inspectors identified that following the replacement of the 1B auxiliary feedwater pump control switch, the licensees post maintenance test failed to demonstrate that the pump auto-start feature would perform satisfactorily in service.

This finding was determined to be of very low safety significance, because the failure did not result in an actual loss of the safety function of the auxiliary feedwater system. A Non-Cited Violation of 10 CFR 50 Appendix B, Criteria XI, for the failure to perform an adequate post maintenance test was identified. (Section 1R19)

B. Licensee Identified Violations No violations of significance were identified.

Report Details Summary of Plant Status The licensee operated Unit 1 and Unit 2 at or near full power for the duration of the inspection period.

1. REACTOR SAFETY Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity 1R04 Equipment Alignment (71111.04)

a. Inspection Scope The inspectors verified the system alignment of the equipment listed below during maintenance activities affecting the availability of associated redundant equipment:

C 1B Residual Heat Removal (RH) System Train, and C 1B and 2B Essential Service Water (SX) Trains.

These safety related systems were selected because they were designed to mitigate the consequences of a potential accident. The inspectors performed a walkdown of the accessible portions of the systems and verified that the system lineup was in accordance with plant operating procedures and applicable system drawings. The inspectors also assessed the material condition of system equipment and verified that identified discrepancies were properly captured in the licensees corrective maintenance program.

The documents listed at the end of this report were also used by the inspectors to evaluate this area.

b. Findings No findings of significance were identified.

1R05 Fire Protection (71111.05)

a. Inspection Scope The inspectors examined the plant areas listed below to observe conditions related to fire protection:

C Unit 2 Upper Cable Spreading Room (Zone 3.3B-2);

• Unit 1, Division 11 Engineered Safety Feature Switchgear Room (Zone 5.2-1);

and

• Unit 2, Division 21 Engineered Safety Feature Switchgear Room (Zone 5.2-2).

These areas were selected for inspection because risk significant systems, structures and components were located in the areas. The inspectors reviewed applicable portions

of the Byron Station Fire Protection Report and assessed the licensees control of transient combustibles and ignition sources, material condition, and operational status of fire barriers and fire protection equipment. The inspectors also discussed a damaged seal installed on fire door 0DSD523 with the site fire marshall. The inspectors verified that the seal did have a fire protection function and that the damage to the seal did not affect the rating of the fire door. The documents listed at the end of this report were also used by the inspectors to evaluate this area.

b. Findings No findings of significance were identified.

1R11 Licensed Operator Requalification (71111.11)

a. Inspection Scope The inspectors assessed licensed operator performance and the training evaluators critique during a licensed operator training session in the Byron Station operations training simulator on January 15, 2002. The inspectors focused on alarm response, command and control of crew activities, communication practices, procedural adherence, and implementation of emergency plan requirements.

b. Findings No findings of significance were identified.

1R12 Maintenance Rule Implementation (71111.12)

a. Inspection Scope The inspectors evaluated the licensees implementation of the maintenance rule, 10 CFR 50.65, as it pertained to identified performance problems with the following equipment and systems:

C 2A Emergency Diesel Generator (DG);

• 1A Emergency Diesel Generator;

• Unit 2 Condensate (CD); and

• Control Room Ventilation (VC).

During this inspection, the inspectors evaluated the licensees monitoring and trending of performance data, verified that performance criteria were established commensurate with safety, and verified that equipment failures were appropriately evaluated in accordance with the maintenance rule. The documents listed at the end of this report were also used by the inspectors to evaluate this area. The inspectors interviewed system engineers and the stations maintenance rule coordinator.

In addition, the inspectors reviewed the issues that the licensee entered into its corrective action program to verify that identified problems were being entered into the program with the appropriate characterization and significance. The inspectors also

reviewed the licensees corrective actions for maintenance rule related issues documented in selected condition reports.

b. Findings No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Evaluation (71111.13)

a. Inspection Scope The inspectors reviewed the licensees evaluation of plant risk for maintenance activities on the following equipment:

C 1A Residual Heat Removal Train Work Window; C Simultaneous Out-of-Service of One Essential Service Water Pump from Each Unit;

• 1B Auxiliary Feedwater Train Work Window;

• 2A Emergency Diesel Generator Work Window; C Increase Trend in the Unit 2C Steam Generator Tube Leakage; and C Unit 2 Condensate Header Leak.

The inspectors selected these maintenance activities because they involved systems that were risk significant in the licensees risk analysis, or were considered significant as potential initiating events. During this inspection, the inspectors assessed the operability of redundant train equipment and verified that the licensees planning of the maintenance activities minimized the length of time that the plant was subject to increased risk. The inspectors interviewed operations, engineering, maintenance, and work control department personnel. The documents listed at the end of this report were also used by the inspectors to evaluate this area.

The inspectors also reviewed two emergent plant conditions with respect to on-line risk.

During the period, inspectors reviewed the circumstances associated with the Unit 2C steam generator tube leakage and the Unit 2 condensate header leak. The inspectors reviewed the licensees development and implementation of contingency actions to address risk associated with the emergent issues. The licensee had completed a temporary repair to the condensate leak, and has planned a permanent repair. With respect to the steam generator tube leak, the licensee continues to monitor the leakage in accordance with the current industry guidance.

b. Findings No findings of significance were identified.

1R15 Operability Evaluations (71111.15)

a. Inspection Scope The inspectors evaluated the licensees basis that the issues identified in the following operability determinations (OD) and condition reports did not render the involved equipment inoperable or result in an unrecognized increase in plant risk:

C OD 01-018, Reactor Coolant Pump Oil Viscosity; C OD 01-020, Auxiliary Building Ventilation Damper OVA 471Y Failure to Stroke; C OD 02-004, 0A Essential Service Water Makeup Pump Seal Housing Heating; C Condition Report (CR) 00087964, Main Control Habitability/Safety Category 1 Components Service Life Issues [due to Relative Humidity less the that Specified in the UFSAR]; and C CR 00089364, Possible Non-conservative PR11J [Containment Atmospheric Radiation Monitor] Setpoint.

The inspectors interviewed operations, engineering, maintenance and regulatory assurance department personnel and reviewed applicable portions of the Updated Final Safety Analysis Report (UFSAR) and Technical Specification (TS). The documents listed at the end of this report were also used by the inspectors to evaluate this area.

In addition, the inspectors reviewed the issues that the licensee entered into its corrective action program to verify that identified problems were being entered into the program with the appropriate characterization and significance. The inspectors also reviewed the licensees corrective actions for issues potentially affecting the operability of structures, systems, and components that were documented in selected condition reports.

b. Findings In CR 00089364, the licensee documented that during a review of the setpoint for containment atmosphere radiation monitors (1/2PR11J), a non-conservative error was found. The reactor coolant system (RCS) activities used to calculate the 1 gallon per minute (gpm) leak rate were substantially more than the existing RCS activities. This error affected the monitors ability to detect a 1 gpm leak from the RCS within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

For example, the assumed Xe-135 concentration was 1.26 curies per gram (Ci/gm) and the actual [concentration] was 1.30 E-3 Ci/gm which was roughly a factor of 1000 lower.

10 CFR Part 50, Appendix A, General Design Criterion 30 required licensees to develop means for detecting reactor coolant leakage. Regulatory Guide 1.45, "Reactor Coolant Pressure Boundary Leakage Detection Systems," described acceptable methods to ensure conformance with the General Design Criterion 30. Regulatory Guide 1.45 states that, "In analyzing the sensitivity of leak detection systems...a realistic primary coolant radioactivity concentration assumption should be used. The expected values used in the plant environmental report would be acceptable." As stated in the Updated Final Safety Analysis, Appendix A, the licensee was committed to Regulatory Guide 1.45, with the caveat that leak detector sensitivity was as low as practicable.

In addition, Technical Specification 3.4.15 required that, "The following RCS leakage detection instrumentation shall be operable: a. One containment sump monitor; and b. One containment atmosphere radioactivity monitor (gaseous or particulate). The bases for this Technical Specification states, in part, that radioactivity detection systems shall be operable to provide a high degree of confidence that extremely small leaks are detected in time to allow actions to place the unit in a safe condition, when RCS leakage indicated a possible reactor coolant pressure boundary degradation."

When the discrepancy with respect to assumed RCS activities was identified, the licensee determined that the containment radiation monitors were operable because the monitor could detect a 1gpm leakage within one hour at the reactor coolant activities specified in the plant environmental report. The licensee stated that the Technical Specification bases will be modified to reflect the actual capabilities of the monitors and will define other available means to detect leakage.

The inspectors questioned whether the 1/2PR11J containment atmosphere radiation monitors were technically operable because an informal licensee calculation showed that at current activity levels, a 1gpm RCS leakage would not be detected by the containment atmosphere radiation monitors for at least 12 days. This calculation did not take into account radioactive decay or that the containment was vented about every third day. It was unclear whether the current containment radiation monitors were sufficient to detect leakage defined in the licensees leak-before-break analysis. In addition, the inspectors noted that the licensees Technical Specification 3.4.15 required only two leakage detection instrumentation while Reg Guide 1.45 required three.

The operability of the containment radiation monitors is an Unresolved Item (50-454/455-02-02-02) pending resolution of questions associated with the licensing basis for the leak-before-break analysis.

1R16 Operator Work-Arounds (71111.16)

a. Inspection Scope The inspectors evaluated event described in the CR listed below to determine if an operator work-around (OWA) existed and if there was any potential affect on the functionality of mitigating systems or on the operators response to initiating events:

C CR 00089356, 0D Gaseous Decay Tank Inadvertent Release to Auxiliary Building Equipment Drains.

The inspectors interviewed operating and engineering department personnel and reviewed selected procedures and documents listed at the end of this report.

b. Findings No findings of significance were identified.

1R19 Post Maintenance Testing (71111.19)

a. Inspection Scope The inspectors evaluated the licensees post maintenance testing activities for maintenance conducted on the following equipment:

C 1A Residual Heat Removal Train; C 1B Auxiliary Feedwater Train; and C 2A Emergency Diesel Generator Jacket Water Pump Seal, Heat Exchanger, and Discharge Check Valve.

The inspectors selected these post maintenance activities because the systems were identified as risk significant in the licensees risk analysis. The inspectors reviewed the scope of the work performed and evaluated the adequacy of the specified post maintenance testing. The inspectors verified that the post maintenance testing was performed in accordance with approved procedures, the procedures stated acceptance criteria, and the acceptance criteria were met. During this inspection activity, the inspectors interviewed maintenance and engineering department personnel and reviewed the completed post maintenance testing documentation. The documents listed at the end of this report were also used by the inspectors to evaluate this area.

b. Findings The inspectors identified a finding of very low safety significance (Green). In particular, following the replacement of the 1B AFW pump control switch, the licensees post maintenance test failed to verify the auto start feature of the pump. The inspectors determined that this failure was a Non-Cited Violation of 10 CFR 50 Appendix B, Criteria XI, Test Control.

On January 15, 2002, the licensee replaced the control switch for the 1B auxiliary feedwater pump. This switch was located in the main control room, and allowed the operators to manually start and stop the pump. In addition, this switch made up part of the circuitry for the auto start feature of the pump. The licensee replaced the switch in accordance with the Procedure BHP 4200-46, Control Switch Replacement Appendix R and General Plant Non-Appendix R, Revision 5. This procedure directed the technicians to measure continuity across the various contacts within the switch. Upon completion of the work, plant operators performed a function test of the switch by using it to start and stop the pump. Subsequently, the operators declared the 1B AFW pump operable.

During the inspectors review of the post maintenance test for the control switch replacement, the inspectors focused on auto start feature of the pump to verify that this circuitry was adequately tested. Through discussions with the Electrical Maintenance Supervisory, the inspectors ascertained that the auto start function was verified though the continuity measurements made under the control switch replacement procedure.

The inspectors compared these continuity checks to the schematic of the 1B AFW control circuitry. Based on this comparison, the inspectors identified that these checks failed to verify continuity through the entire portion of auto start circuitry associated with

the switch replacement. Specifically, the checks failed to verify continuity through the amphenol connector. Furthermore, this portion of the auto start feature was not verified as part of the functional test that started and stopped the pump. The licensee agreed that the post maintenance test was inadequate and on January 24, 2002, the licensee completed additional continuity measurements to verify operability of the auto-start feature.

The inspectors determined that the failure to complete an adequate post maintenance test for the 1B AFW control switch replacement had a credible impact on safety. This is because the post maintenance test is the verification that the maintenance activity did not adversely impact the operability of the system. In this case, the ability of the AFW to auto-start in response to accident or transit conditions was not adequately verified. The inspectors evaluated this issue using the Significance Determination Process (SDP) and concluded that it was of very low safety significance (Green), because it did not result in an actual loss of the safety function of the AFW system.

10 CFR Part 50, Appendix B, Criteria XI, Test Control, requires, in part, that a test program shall be established to assure that all testing required to demonstrate structures, systems and components will perform satisfactorily in service is identified and performed. Contrary to this, following the January 15, 2002, maintenance activity that replaced the 1B AFW control switch, the licensees post maintenance test failed to demonstrate that the auto-start feature of the pump would perform satisfactorily in service. This is a violation of 10 CFR 50 Appendix B, Criteria XI, however, because this violation was of very low risk significance, was non-repetitive, and was captured in the licensees corrective action program (Condition Report 00091921), it is considered a Non-Cited Violation consistent with Section VI.A of the NRC Enforcement Policy (50-454-02-02-01).

1R22 Surveillance Testing (71111.22)

a. Inspection Scope The inspectors evaluated the surveillance testing activities listed below to verify that the testing demonstrated that the equipment was capable of performing its intended function:

C Unit 2, 2A Diesel Generator Relay Operation Verification;

• Unit 2, Engineered Safety Feature Actuation System Slave Relay (K-611)

Surveillance; C Unit 2, 2A Diesel Generator Operability Surveillance; and C Unit 1, Train A, ASME [American Society of Mechanical Engineers] Surveillance Requirements for the Centrifugal Charging Pump 1A and Chemical and Volume Control System Valve Stroke Test.

The inspectors selected these surveillance test activities because the system functions were identified as risk significant in the licensees risk assessment and the components were credited as operable in the licensees safety analysis to mitigate the consequences of a potential accident. The inspectors interviewed operations, maintenance, and engineering department personnel; reviewed the completed test documentation; and

observed the performance of all or portions of these surveillance testing activities. The documents listed at the end of this report were also used by the inspectors to evaluate this area.

In addition, the inspectors reviewed the issues that the licensee entered into its corrective action program to verify that identified problems were being entered into the program with the appropriate characterization and significance. The inspectors also reviewed the licensees corrective actions for surveillance testing issues documented in selected condition reports.

b. Findings No findings of significance were identified.

2. RADIATION SAFETY Cornerstone: Public Radiation Safety (PS)

2PS1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (71122.01)

.1 Liquid and Gaseous Release Systems Walkdowns a. Inspection Scope The regional radiation protection inspector performed walkdowns of the major components of the liquid and gaseous release systems (e.g., radiation and flow monitors), and observed ongoing activities related to the systems, to verify that the current system configuration was as described in the Updated Final Safety Analysis Report and the Offsite Dose Calculation Manual (ODCM), and to observe equipment material condition. In particular, the inspector reviewed the location, material condition, and activities related to the:

• Auxiliary Building Vent Stack Gaseous Effluent Monitors (1/2RE-PR028)

• Containment Atmosphere Purge Monitors (1/2RE-PR001)

• Auxiliary Building Vent Stack Wide Range Gas Monitors (1/2RE-PR030)

• Liquid Radioactive Waste Release Tank Monitor (0RE-PR001)

• Station Liquid Blowdown Monitor (0RE-PR010)

• Condensate Polisher Conductivity Sump Monitor (0RE-PR041)

• Control Room Outside Air Intake Monitor (0RE-PR031/32)

• Control Room Turbine Building Air Intake Monitor (0RE-PR035/36)

b. Findings No findings of significance were identified.

.2 Radioactive Effluent Release Data, Dose Calculations, and Changes to the ODCM a. Inspection Scope The regional radiation protection inspector reviewed the 2000 Annual Radioactive Effluent Release Report and selected radioactive effluent release data for January 2000 through January 2002, to verify that the radioactive effluent program was implemented as described in the UFSAR and ODCM and to ensure that any anomalies in the release data were adequately understood by the licensee. The inspector reviewed the licensees offsite dose calculations and independently assessed selected calculations using the NRC PC-DOSE computer code to ensure that the licensee had properly calculated the offsite dose from radiological effluent releases and to determine if any annual Radiological Effluent Technical Specification (RETS) or ODCM limits (i.e., Appendix I to 10 CFR Part 50 values) were exceeded. In addition, the inspector reviewed Revision 3 of the ODCM and the licensee's technical justifications for changes to the document to verify that changes were made in accordance with the requirements of the RETS.

b. Findings No findings of significance were identified.

.3 Liquid and Gaseous Effluent Releases a. Inspection Scope The regional radiation protection inspector reviewed the release packages for four liquid effluent batch releases completed in January 2000 through January 2002, to verify that the licensees processing and release procedures, including dose projections to members of the public, were conducted in accordance with ODCM and RETS requirements. Additionally, the inspector selectively reviewed grab sample results and licensee calculations for three containment purge radioactive gaseous releases and one waste gas decay tank release completed in January 2000 through January 2002, including the projected doses to members of the public, to verify that appropriate treatment equipment was used and that the radioactive gaseous effluents were processed and released in accordance with ODCM and RETS requirements. For all of the release packages reviewed, the inspector also examined the monitor alarm set points used and methodology employed, to verify that changes to the set points were made in accordance with the ODCM.

b. Findings No findings of significance were identified.

.4 Liquid and Gaseous Effluent Monitor Calibrations a. Inspection Scope The regional radiation protection inspector reviewed records for the two most recent instrument calibrations or maintenance completed for selected point-of-discharge effluent radiation monitors (including the associated flow rate instrumentation), to verify that these instruments had been calibrated consistent with industry standards and in accordance with station RETS and procedures. Specifically, the inspector reviewed the calibration records for:

• Auxiliary Building Vent Stack Gaseous Effluent Monitors (1/2RE-PR028)

• Containment Atmosphere Purge Monitors (1/2RE-PR001)

• Liquid Radioactive Waste Release Tank Monitor (0RE-PR001)

• Station Liquid Blowdown Monitor (0RE-PR010)

• Radwaste Area Vent Stack Effluent Radiation Monitor (0RE-PR026)

b. Findings No findings of significance were identified.

.5 Analytical Instrumentation Quality Control a. Inspection Scope The regional radiation protection inspector previously reviewed the Chemistry Departments quality control data and charts for the gamma spectroscopy instrument systems used to quantify effluent release samples during the inspectors last inspection at the station (refer to Section 2PS3.4 of Inspection Report 50-454/01-14(DRP);

50-455/01-14(DRP)). The systems and methods used to quantify effluent samples are the same used in measuring samples for release from the radiologically controlled areas of the station.

The inspector also reviewed the stations quality assurance reports and reviews of the vendor laboratory that provides radiochemical analysis of effluent samples, to verify that the vendor was capable of adequately preparing and analyzing effluent samples for difficult-to-detect radionuclides (pure beta- or alpha-decay isotopes).

b. Findings No findings of significance were identified.

.6 Identification and Resolution of Problems a. Inspection Scope The regional radiation protection inspector reviewed self-assessments, Nuclear Oversight field observations, and licensee condition reports (CRs) completed since January 2000, which focused on the ODCM and liquid and gaseous effluent release

programs. The inspector reviewed these documents to assess the licensees ability to identify repetitive problems, contributing causes, the extent of conditions, and implement corrective actions intended to achieve lasting results.

b. Findings No findings of significance were identified.

4OA6 Meetings

.1 Interim Exits The results of the Public Radiation Safety inspection were presented to Mr. R. Lopriore and other members of licensee management at the conclusion of the inspection on January 11, 2002. The licensee acknowledged the findings presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

.2 Resident Inspector Exit Meeting The inspectors presented the inspection results to Mr. R. Lopriore and other members of licensee management at the conclusion of the inspection on February 19, 2002. 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.

KEY POINTS OF CONTACT Licensee R. Lopriore, Site Vice President S. Kuczynski, Station Manager B. Adams, Engineering B. Altman, Maintenance Manager D. Goldsmith, Radiation Protection Director D. Combs, Site Security Manager D. Drawbaugh, Byron NRC Coordinator D. Goldsmith, Radiation Protection Manager B. Grundmann, Regulatory Assurance Manager K. Hansing, Site Nuclear Oversight Manager D. Hoots, Operations Manager S. Kerr, Chemistry Manager W. Kolo, Work Management Director T. Roberts, Engineering Director B. Sambito, Byron Radiation Protection D. Spoerry, Training Manager S. Stimac, Shift Operations Superintendent Nuclear Regulatory Commission J. Adams, NRC Byron Resident P. Snyder, NRC Byron Resident A. Stone, Chief, Projects Branch 3, Division of Reactor Projects LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-454/455-02-02-02 URI Non-conservative error PR11J setpoint analysis 50-454-02-02-01 NCV Inadequate post maintenance testing following the replacement of the 1B auxiliary feedwater pump control switch Closed 50-454-02-02-01 NCV Inadequate post maintenance testing following the replacement of the 1B auxiliary feedwater pump control switch

LIST OF ACRONYMS USED AFW Auxiliary Feedwater ASME American Society of Mechanical Engineers BAP Byron Administrative Procedure BCP Byron Chemistry Procedure BIP Byron Instrument Maintenance Procedure BISR Byron Instrument Maintenance Surveillance Requirement Procedure BOA Byron Abnormal Operating Procedure BOL Byron Limiting Condition for Operation Action Requirement Procedure BOP Byron Operating Procedure BOSR Byron Operating Surveillance Requirement Procedure BVSR Byron Technical Surveillance Requirement Procedure CB Condensate Booster CC Component Cooling CD Condensate CFR Code of Federal Regulations CR Condition Report CV Control Room Ventilation DG Diesel Generator DRP Division of Reactor Projects ECCS Emergency Core Cooling System LCOAR Limiting Condition for Operation Action Requirement LER Licensee Event Report NCV Non-Cited Violation NEI Nuclear Energy Institute NRC Nuclear Regulatory Commission NSP Nuclear Station Procedure OD Operability Determination ODCM Offsite Dose Calculation Manual OWA Operator Work-Around PARS Publically Available Records PR Process Radiation Monitor Radwaste Radioactive Waste RCS Reactor Coolant System RCPB Reactor Coolant Pressure Boundary RETS Radiological Effluent Technical Specifications RH Residual Heat Removal RP Release Package SDP Significance Determination Process SX Essential Service Water TS Technical Specification UFSAR Updated Final Safety Analysis Report URI Unresolved Item WO Work Order WR Work Request

LIST OF DOCUMENTS REVIEWED 1R04 Equipment Alignment Byron Station Technical Specifications (TS)

Byron/Braidwood Stations UFSAR Byron Operating Residual Heat Removal System Train B Revision 2 Procedure (BOP) Electrical Lineup RH-E1B BOP RH-M1B Train B Residual Heat Removal Valve Revision 7 Lineup Byron Administrative Initiation and Use of System Lineups Revision 11 Procedure (BAP) (Mechanical and Electrical)

340-2 BOP SX-1 Essential Service Water Pump Startup Revision 14 BOP SX-M1B Unit 1, Train B, Essential Service Water Revision 6 Valve Lineup BOP SX-M2B Unit 2, Train B, Essential Service Water Revision 6 Valve Lineup BOP SX E1B Unit 1, Train B, Essential Service Water Revision 2 Electrical Lineup BOP SX E2B Unit 2, Train B, Essential Service Water Revision 1 Electrical Lineup 1R05 Fire Protection Byron/Braidwood Stations Fire Protection Revision 19 Report Byron Station Pre-Fire Plans and Drawings Byron/Braidwood Stations Fire Hazards Amendment 18, Analysis, Sections2.3.3.17, 2.3.5.3 and December 1998 2.3.5.4 Work Order (WO) Repair door gasket on door 0DSD523 February 11, 2002 00036039 1R12 Maintenance Rule Implementation

CR 00082931 Chart Recorder Jumper Lead Caused Short November 14, 2001 on 2A Diesel Generator Circuit CR B2000-02968 1A Diesel Generator Sequence Test Failure October 5, 2000 CR B2000-01073 2D Condensate Pump Coupling Failure April 11, 2000 Maintenance Rule - Performance Monitoring CD/CB, VC, DG Maintenance Rule - Performance Criteria CD/CB, VC, and DG Expert Panel Scoping Determination System CD/CB, VC, and DG 1R13 Maintenance Risk Assessments and Emergent Work Evaluation Byron Operating On-Line Risk/Protected Equipment Revision 2 Department Policy 400-47 Nuclear Station On-Line Maintenance Revision 4 Procedure (NSP)

WC-AA-103 CR 00091861 Problems Encountered with 1AF004B Work January 23, 2002 Window CR 00090800 1B Auxiliary Feedwater Pump Work Window January 16, 2002 LCO Plan CR 00090901 No Lubricant Specified for Rebuild 1AF004B January 16, 2002 Actuator Unit 2 Byron Steam Generator Tube Leak - Unit 2 Rev. 102 Abnormal Operating Procedure (2BOA)

SEC-8 2BOA SEC-8 Contingency Quick Shutdown - Unit 2 Project Critique 1B Auxiliary Feed Pump Work Window NRC Inspection Steam Generator Tube Primary-to- October 11, 2001 Manual, Part 9900: Secondary Leakage Technical Guidance NRC Information Recent Incidents Involving Rapid Increases July 5, 1991 Notice 91-43 in Primary-to-Secondary Leak Rate

NRC Information Determination of Primary-to-Secondary June 10, 1994 Notice 94-43 Steam Generator Leak Rate Contingency Plan for Unit 2 Condensate Header Leakage Compensatory Measures from Revised February 7, 2002 Commitment 454-251-88-93700 for the Following Maintenance/Modification Work:

0A&0B SXCT Suction Box Hatch Mod, 0SX138A&B Actuator Replacement, 0SX138A&B Internal Inspection HLA/IPA Briefing Worksheet 1A and 2A SX February 4, 2002 Pumps OOS to Support Maintenance/Modification Activities at SXCT 0A Basin 1R15 Operability Evaluations Byron Station TS Byron/Braidwood Stations UFSAR Byron Station Technical Requirement Manual CR B2001-00534 Main Control Room Ventilation Steam February 04, 2001 Generators Not Performing as Designed CR 00087428 RCP Motor Oil Doesnt Meet Design December 19, 2001 Viscosity Requirements CR 00087847 BOP RH-6 R/21 50.59 Screening Needs December 21, 2001 Improvement CR 00087964 MCR Habitability/Safety Cat 1 Component December 23, 2001 Service Life Issues CR 00088429 Failed Test of VA/AF Damper Interlock December 29, 2001 CR 00089364 Possible Non-Conservative PR11J January 8, 2002

[Containment Atmospheric Radiation Monitor] Setpoint CR 00091088 Deviation between Byron/Braidwood RH January 17, 2002 Procedures CR 00091178 1 UFSAR and SER Dont Agree on Seismic January 17, 2002 Qualification of PR11J

OD 01-017 Potential Distortion of Stuffing Box Extension Revision 0 Wear Ring During Thermal Transients on the RH Pumps OD 01-018 Reactor Coolant Pump Oil Viscosity December 21, 2001 OD 01-020 Auxiliary Building Ventilation Damper OVA December 31, 2001 471Y Failure to Stroke 50.59 Screening Form Placing the RH System in Shutdown Cooling Revision 00 6D-01-0336 50.59 Screening Form Placing the RH System in Shutdown Cooling Revision 01 6D-01-0336 LS-AA-104 Exelon 50.59 Review Process Revision 20 LS-AA-104-1000 50.59 Resource Manual Revision 0 Nuclear Energy Guidelines for 10 CFR 50.59 Implementation Revision 1 Institute (NEI) 96-07 Regulatory Guide Reactor Coolant Pressure Boundary May 1973 1,45 Leakage Detection Systems Regulatory Guide Guidance for Implementation of 10 CFR November 2000 1.187 50.59, Changes, Tests, and Experiments NRC Information Dispositioning of Technical Specifications December 29, 1998 Notice 98-10 that are Insufficient to Assure Plant Safety NRC Task Interface Discrepancies of Containment Radiation June 24, 1998 Agreement 96-019 Monitor Sensitivities at St. Lucie Units 1 and 2, and Turkey Point Units 3 and 4 DC-VC-01-BB Design Criteria for Control Room HVAC December 28, 1979 System BOP RH-6 Placing the RH System in Shutdown Cooling Revision 21 CR 00092998 Heating Observed on 0A SX Makeup Pump January 29, 2002 OD 02-004 0A Essential Service Water Makeup Pump Revision 0 Seal Housing Heating 1R16 Operator Work-Arounds CR 00089356 OD GDT Inadvertent Release to WE January 07, 2002 WO 99281382 Sight glass Very Dirty January 08, 2002 OP-AA-101-303 Operator Work-Around Program Revision 0

1R19 Post Maintenance Testing Byron/Braidwood Stations UFSAR Byron Station TS Byron Station Technical Requirement Manual WO 99245637 1A RH PP Breaker PM BUS 141 CUB 4 WO 99037441 Rebuild Actuator, Replace Regulators, Replace Elastomers Unit 1 Limiting LOCAR [Limiting Condition for Operation Revision 2 Condition for Action Requirement] ECCS [Emergency Operation Action Core Cooling System] - Operating Tech Requirement Spec LCO # 3.5.2 Procedure (1BOL) 5.2 WO 99159880 Perform Inspection of Motor (1RH01PA-M)

Unit 1 Byron Unit 1 1CC9412A Position Indication Test Revision 2 Operating Surveillance Requirement Procedure (1BOSR)

0.5-2.CC.3-1 1BOL 7.7 LOCAR Component Cooling Water (CC)

System Tech Spec LCO # 3.7.7 Unit 2 Byron Unit 2, Nonroutine Visual Examination of Revision 3 Technical ASME Class 1, 2, and 3 Components at Surveillance Normal Operating Pressure of the 2A Procedure (2BVSR) Emergency Diesel Generator Jacket Water 4.f.2-11 Heat Exchangers WO 990021051 Inspection of the 2A Emergency Diesel Generator Jacket Water Heat Exchanger Essential Service Water Side.

WO 99263297-04 2A Emergency Diesel Generator Jacket Water Pump Check Valve Removal, Inspection, and Replacement Post Maintenance Test WO 99263297-02 2A Emergency Diesel Generator Jacket Water Pump Check Valve Removal, Inspection, and Replacement.

WO 99263297-03 2A Emergency Diesel Generator Jacket Water Pump Seal Replacement Post Maintenance Test WO 99263297-01 2A Emergency Diesel Generator Jacket Water Pump Seal Replacement BOP DG-11T22 Diesel Generator Operating Logs from Revision 11 January 30, 2002 CR 00092600 2A DG Crankcase Breather Studs January 28, 2002 Penetrated Through Casing CR 00092605 Corrosion/Pitting of Gasket Surface of the January 28, 2002 2A DG Jacket Water Channel Heads WO 99245683 03 Operations Verify Control Switch Starts- January 16, 2002 Stops Auxiliary Feedwater (AFW) Pump WO 00334247 02 Operations PMT 1B AFW Pump Right Angle January 16, 2002 Gear Box Pressure Gage WO 99168676 02 Operations Run Oil Pump and Check for January 16, 2002 Leaks WO 99203178 02 Operations Functional Test January 16, 2002 WO 99262768 02 Operations Verify Engine Starts January 16, 2002 WO 99245683 01 Replace Main Control Board (MCB) Control January 15, 2002 Switch (C/S) for 1AF01 WO 00401516 01 Perform Continuity Check of New MCB C/S January 24, 2002 for 1AF01 Drawing 6E-1- Schematic Diagram Auxiliary Feedwater Revision AA 4030AF02 Pump 1B (Diesel Driven) 1AF01PB CR 00091921 1 Deficient PMT Performed on 1B AFW Pump January 23, 2002 MCB C/S 1R22 Surveillance Testing Byron Station TS Byron/Braidwood Stations UFSAR 2BOSR DG-2 Unit 2, 2A Diesel Generator Relay Operation Revision 0 Verification 2BOSR 3.2.8-611A Unit 2, Engineered Safety Feature Actuation Revision 1 System Slave Relay (K-611) Surveillance

2BOSR 8.1.2-1 Unit 2, 2A Diesel Generator Operability Revision 11 Surveillance 1BVSR 5.2.4-5 Unit 1, Train A, ASME Surveillance Revision 5 Requirements for the Centrifugal Charging Pump 1A and Chemical and Volume Control System Valve Stroke Test CR 00093126 Wrong Procedure Revision Used to Test the January 30, 2002 2A diesel Generator CR 00093151 Operator Identified Procedure Problem January 30, 2002 2PS1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems 2000 Annual Radioactive Effluent Release April 26, 2001 Report Byron Offsite Dose Calculation Manual Revision 3 (January (ODCM) 2002)

Effluent/ODCM Calculations February, July, 2nd Quarter, & 3rd Quarter 2001 Focus Area Self-Assessment Report - December 12-13, 2001 Radiological Effluent Technical Standards and Offsite Dose Calculation Manual Nuclear Oversight Field Observations January - June 2001 Quality Assurance Reports - Eberline September -

Services, Richmond, CA December 2001 BAP 330-3 Locked Equipment Program, Byron Revision 3 Addendum BAP 330-5 Lock and Key Control Revision 15 Byron Chemistry Gaseous Effluent Release No. 10111 April 1, 2001 Procedure (BCP) 400- (Routine Unit 2 Containment Release)

TCNMT/ROUTINE BCP 400- Gaseous Effluent Release No. 10211 June 15, 2001 TCNMT/ROUTINE (Routine Unit 1 Containment Release)

BCP 400- Gaseous Effluent Release No. 20012 January 8, 2002 TCNMT/ROUTINE (Routine Unit 2 Containment Release)

BCP 400-TWASTE Gaseous Effluent Release No. 10015 January 19, 2001 GAS (Waste Gas Decay Tank 'F' Release)

BCP 400-TWX01 Liquid Radioactive Waste (Radwaste) April 9, 2001 Effluent Release No. 10123 (Release Tank 0WX01T)

BCP 400-TWX26 Liquid Radwaste Effluent Release No. January 6, 2000 00006 (Release Tank 0WX26T)

BCP 400-TWX26 Liquid Radwaste Effluent Release No. July 7, 2001 10235 (Release Tank 0WX26T)

BCP 400-TWX26 Liquid Radwaste Effluent Release No. January 5, 2002 20005 (Release Tank 0WX26T)

Byron Instrument Calibration of Radwaste Area Vent Stack Revision 4 Maintenance Effluent Radiation Monitor (PR)

Procedure (BIP)

2500-135 Byron Instrument Calibration of Containment Purge Effluent Revision 2 Maintenance Radiation Monitor (PR)

Surveillance Requirement Procedure (BISR)

3.7.3-200 BISR 11.a.4-200 Calibration of Station Blowdown Radiation Revision 3 Monitor (PR)

BISR 11.a.4-200 Calibration of Liquid Radwaste Effluent Revision 3 Radiation Monitor (PR)

BISR 11.b.4-200 Calibration of Auxiliary Building Vent Stack Revision 2 Effluent Radiation Monitor (PR)

CR 00075064 Unplanned LCOAR Entry 0BOL PR1 September 12, 2001 (Admin) on 2PR08J CR 00076945 Unplanned LCOAR Entry for 2PR0003J September 29, 2001 CR 00076951 Unplanned LCOAR Entry for 2PR28J September 29, 2001 CR 00078471 Unplanned LCOAR Entry - Loss of Sample October 10, 2001 Flow for 2PR08J CR 00089001 Effluent Vendor Reports Potential False January 4, 2002 Positive Results CR 00089356 0D GDT Inadvertent Release to WE January 7, 2002 CR 00090062 1 NRC Inspection - Attention to Detail Issues January 11, 2002 CR B2000-00064 EPN Out of Tolerance, Expanded January 4, 2000 Tolerance Exceeded

CR B2001-02191 Minor Transportation Error in Liquid Release May 10, 2001 Package (RP) 333 OP-AA-108-103 Locked Equipment Program Revision 0 Work Request (WR) Replace CPU Board and EPROMs May 11, 2001 Task 970135222 (1RE-PR001)

WR Task 980072782 Calibration of a General Atomics Radiation January 7, 2000 Monitoring Skid (0RE-PR001)

WR Task 980079894 Cal of Rad Monitor 1PR28J February 3, 2000 WR Task 980092375 Calibration of a General Atomics Radiation February 24, 2000 Monitoring Skid (0RE-PR010)

WR Task 980095947 Cal of Rad Monitor 2PR28J March 8, 2000 WR Task 980101618 Cal of General Atomics Radiation Monitoring March 21, 2000 Skid 2PR-01J WR Task 980125818 Radwaste Area Vent Stack Effluent Rad May 26, 2000 Monitor Loop 0PR-026 WR Task 990134439 Calibration of a General Atomics Radiation May 21, 2001 Monitoring Skid (0RE-PR001)

WR Task 990144074 Cal of Rad Monitor 1PR28J November 21, 2001 WR Task 99150462 Calibration of a General Atomics Radiation August 3, 2001 Monitoring Skid (0RE-PR010)

WR Task 99154788 Cal of Rad Monitor 2PR28J October 11, 2001

• 1 Condition Report written as a result of the inspection.

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