IR 05000483/1986020
| ML20211M658 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 12/12/1986 |
| From: | Forney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20211M636 | List: |
| References | |
| 50-483-86-20, IEB-86-001, IEB-86-002, IEB-86-003, IEB-86-004, IEB-86-1, IEB-86-2, IEB-86-3, IEB-86-4, IEIN-86-053, IEIN-86-072, IEIN-86-53, IEIN-86-72, NUDOCS 8612180016 | |
| Download: ML20211M658 (18) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-483/86020(DRP)
Docket No. 50-483 License No. NPF-30 Licensee: Union Electric Company Post Office Box 149 - Mail Code 400 St. Louis, M0 63166 Facility Name: Callaway Plant, Unit 1 Inspection At: Callaway Site, Steedman, M0 Inspection Conducted: October 5 through November 30, 1986 Inspectors:
B. H. Little C. H. Brown
@.L.Forney,JA L-Approved By:
f
/ S// *//6 Reactor Projects Section Date'
Inspection Summary Inspection on October 5 through November 30, 1986 (Report No. 50-483/86020(DRP))
Areas Inspected: A routine, unannounced safety inspection by the resident inspectors and a region based inspector of previous inspection findings, regional requests, IE Information Notices and IE Bulletins, Licensee Event Reports, cold weather preparations, maintenance, surveillance, operational safety, and thermal hydraulic anomaly.
Results:
No violations of NRC requirements were identified during the course of this inspection.
I 8612180016 861212 DR ADOCh 05000483 PDR
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DETAILS 1.
Persons Contacted D. F. Schnell, Vice President, Nuclear S. E. Miltenberger, General Manager, Nuclear Operations
- G. L. Randolph, Manager, Callaway Plant C. D. Naslund, Manager, Operations Support A. P. Neuhalfen, Manager, Quality Assurance
- J. D. Blosser, Assistant Manager, Operations & Maintenance J. R. Peevy, Assistant Manager, Technical Services P. T. Abbleby, Assistant Manager, Support Services W. F. Powell, Assistant Manager, Materials M. E. Taylor, Superintendent, Operations D. E. Young, Superintendent, Maintenance
- W. R. Robinson, Superintendent, 1&C R. R. Roselius, Superintendent, Health Physics V. J. Shanks, Superintendent, Chemistry J. A. Ridgel, Superintendent, Radwaste G. J. Czeschin, Superintendent, Planning & Scheduling W. H. Sheppard, Superintendent, Outages J. M. Price, Superintendent, Training G. R. Pendergraff, Superintendent, Security J. E. Davis, Superintendent, Compliance D. W. Capone, Manager, Nuclear Engineering W. R. Campbell, Assistant Manager, Nuclear Engineering A. C. Passwater, Superintendent, Licensing T. H. McFarland, Superintendent, Design Control R. D. Affolter, Superintendent, Systems Engineering J. V. Laux, Superintendent, Technical Support G. A. Hughes, Supervisor, Independent Safety Engineer Group
- J. C. Gerhart, Superintendent, QA Operations Support
- T. P. Sharkey, Supervisor, Compliance
- B. Y,. Stanfield, Quality Assurance Engineer
- Denotes those present at one or more exit interviews.
In addition, a number of equipment operators, reactor operators, senior reactor operators, and other members of the quality control, operations, maintenance, health physics and engineering staffs were contacted.
2.
Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (483/85007-01(DRS)): Closure testing of normally-closed check valves that perform a safety function in the closed position. This issue was originally raised in 1983 in Inspection Report No. 50-483/63027(DE).
It was recognized at that time that there was no preoperational testing or subsequent surveillance testing that would assure the closure capability of a significant number of safety-related, normally-closed check valves. The licensee has since agreed (in a March 18, 1986, letter to H. R. Denton from D. F. Schnell) that
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closure testing of these valves is appropriate if they have a safety function in the closed direction. The licensee indicated in the letter that testing would be accomplished in the Planned Maintenance Test Program (except for containment isolation and high/ low pressure system interface valves already included in the A3ME Code,Section XI, Subsection IWV, valve program).
The criterion used in determining whether or not a safety-related check valve must be tested in the closed position was whether or not the valve performs a safety-related function in the closed position.
In making this determination, each check valve was reviewed giving consideration to the following:
a.
Could closure of the valve constitute a safety-related function?
b.
If so, are any other valves in the flowpath, which prevent the same adverse backflow, tested in the closed position?
i.
In the case of valves in branch lines just off of the RCS, two (2) valves in each flowpath must be tested to ensure maintenance of the RCS pressure boundary, 11. Within systems other than the RCS, only one (1) tested check valve is required to prevent a given adverse backflow.
c.
Does the check valve prevent backflow from a higher to a lower pressure-rated line?
d.
If the check valve is located at a seimic/nonseismic boundary, is closure of the valve necessary following a seismic event?
Does the check valve, in the closed position, prevent significant e.
degradation in the ability of a system to perform its design safety-related functions?
During the inspection period, the licensee provided an evaluation of all safety-related check valves in the Callaway Plant using the above criteria. The evaluation indicated that of 212 safety-related check valves, 77 have a safety function in the closed direction and will be tested according to the March 1986 letter. While there may be additional testing requirements in the future, based on ongoing industry and NRC evaluations in this area, the inspector considers the licensee's response fully adequate to address this issue at this time; hence, this unresolved item is considered closed.
3.
Response to NRC/ Regional Office Requests (92701)
a.
Valcor Engineering Part 21/IE Information Notice (IN) No. 86-72 (Failure of 17-7 PH Stainless Steel Springs in Valcor Valves): An inspection in this matter was performed to determine applicability and operating history of the subject valves and to evaluate i
licensee's response to IN No. 86-72. The inspection included the review of applicable plant drawings, licensee correspondence, and interviews with licensee's engineering department personnel.
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Valcor valves are installed in Callaway's Nuclear Sampling (SJ)
System, with some of the valves providing a safety related
" containment isolation" function. The system provides redundant solenoid valve isolation as well as manual isolation valves.
The licensee was initially notified of Valcor solenoid valve spring failures by Valcor Corporation, letter dated April 16, 1986, and subsequently by IN No. 86-72.
Valcor advised the licensee of the availability of replacement springs and recommended that the licensee monitor valve operation for increases in seat leakage or valve transfer times. The licensee documented this matter on UENE Problem Notification Form PN No.86-007. An engineering evaluation of valve performance and maintenance history determined that Callaway has not experienced valve spring failures. However, the licensee has initiated a design change review, and plans to order new valves having the upgraded springs.
The inspector determined that the licensee has been responsive in this matter.
IN No. 86-72 is considered closed, b.
Raychem Heat Shrinkable Tubing (25017 and 92701)
IE Information Notice No. 86-53 (Improper Installation of Heat Shrinkable Tubing (HST):
Issued to alert licensees to a potentially generic safety problem involving improper installation of heat shrinkable tubing over electrical splices and terminations.
An inspection in this matter was performed to evaluate the licensee's response to IN No. 86-53 and to assess licensee's administrative controls relating to the installation of HST.
Inspection guidance provided in Temporary Instruction TI 2500/17 was utilized in the course of this inspection. The inspection included the review of selected quality assurance records, procedures and instructions, and interviews with licensee quality assurance (QA), and quality control (QC) personnel. The inspector also performed an inplant sample inspection of HST installed on electrical splices.
Quality Assurance (QA) Records The licensee has QA records which document the training and qualification of both HST installers and QC inspectors. This training was conducted onsite by Raychem, initially under the licensee's construction program and subsequently under the licensee's operating program.
During the construction phase, Daniel International Construction Procedure WP-304 specified that " terminators" be certified in accordance with WP-309 (Training and Certification of Electrical Cable Terminators). This procedure (WP-304) provides instructions and guidelines and incorporates the "Raychem In-line Splice Application Guide". Quality Control Procedure, QCP-304, " Inspection of Cable Termination and Testing" also references the Raychem
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application guide as acceptance criteria.
In addition to training and qualification requirements, the licensee's operational phase program specifies a 100% QC inspection (hold point) on all HST application. Operations QC Manual, Appendix I " Inspection Points and Acceptance Criteria for Electrical Activities" incorporates the Raychem application guide as acceptance criteria.
The inspector performed a sample review of completed Work Requests (WRs) involving HST installation and verified that the WRs referenced appropriate acceptance criteria and that the required QC inspections were documented. On November 13, 1986, the inspector performed an inspection of HST installations in the plant as follows:
Work Request No.
System / Component 47520(CMP-0508)
Main Steam Dump Valve Control Selenoid 55910 Train "B" Intermediate Range 57996 Steam Generator "A" Feedwater Flow Instru-ment No deficiencies were identified during the inspector's review / inspection in this matter.
The inspector determined that the licensee has received IN No. 86-53, and was responsive in this matter. Licensee's Compliance Department's review of construction and operation's HST installation activities determined that the licensee's programs (training, procedures, and QC inspections) provide reasonable assurance of proper installation of HST at Callaway. A special HST Surveillance was performed by licensee's Quality Assurance Department. No deficiencies were identified by QA.
No violations or deviations were identified. TI 2500/17 and IN No. 86-53 are considered closed.
c.
(Closed)
IE Bulletin (IEB) (483/86003-BB): Potential Failure of Multiple ECCS Pu-mps Due to Single Failure of Air-Operated Valve in Minimum Flow Recirculation Line.
IEB 86-03 informed licensees of design deficiencies concerning potential single-failures of emergency core cooling system (ECCS) pumps.
IEB 86-03 required that licensees evaluate this matter and provide a written report documenting whether or not a single-failure in the minimum flow recirculation line of any ECCS pump could cause a failure of more than one ECCS train.
Inspection in this matter included the review of Callaway ECCS design (plant drawings-P& ids and applicable FSAR sections) and the review of licensee's response to IEB 86-03.
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The Callaway ECCS design, in addition to the safety injection accumulators, provides two independent trains.
Each train includes one charging pump, one safety injection pump, and one residual heat removal pump. The flow isolation valves in the ECCS minimum flow lines are motor operated Class IE valves.
Licensee's response to IEB 86-03 is documented in a letter to NRC Region III (ULNRC-1405). The licensee determined that a single failure in the minimum flow recirculation line of any ECCS pump would not cause a failure of more than one ECCS train.
IE Bulletin 86-03 is considered closed.
d.
Periodic Inspection of Seismic Monitoring Instrumentation A regional request was received requesting a periodic inspection of seismic monitoring instrumentation be implemented at the Callaway Plant. The first phase of the program was completed and the data was provided as requested. This data included the following items:
(1) Description of Instrumentation (2) Applicable Technical Specification (3) Non-Technical Specifications Surveillance (4) Preventive Maintenance Performed (5) Failure Data for the Last 24 Months.
The required surveillance had been performed. Mainteriance was completed (replacement) on one instrument that suffered electronic component damage when the power supply was hit by lightning. A periodic inspection in this area has been developed and is implemented.
i e.
(Closed) IE Bulletin (483/86002-BB) Static "0" Rings (SR)
Differential Pressure Switches: A region request was received to review and evaluate the licensee's seven-day response to IEB 86-02.
The licensee's response to the Bulletin on July 25, 1986, stated that the review of all safety related systems and systems that are subject to limiting conditions for operation in the Technical Specifications have no SOR Model 102 or 103 differential pressure switches installed or any plans to install these switches.
The review of the defined systems appears to meet the intent of the bulletin's request for review of systems important to safety.
Therefore, the response is considered to be appropriate and IEB 86-02 is considered closed.
No violations or deviations were identified.
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4.
Followup of IE Information Notices (IN) and IE Bulletins (IEB) Sent For Information:
(97.701)
A selected sample of eight ins and two IEBs that have been sent to the licensee for information was reviewed. The review included verification of the following actions:
(1) The IN or IEB was reviewed for applicability.
(2) The documents were distributed to appropriate corporate and site personnel.
(3) And that any corrective action necessary was performed or scheduled.
The licensee's program establishes an engineer coordinator who reviews, distributes, and tracks responses for IEBs and ins.
If a response is required by an IEB or IN, the coordinator schedules and collects responses from the designated groups for the licensee's response.
The program was generated by the licensee's broad directive for the
" Operating Experience Review Program"; therefore, a copy of all these documents are routed to training for addition to training and requalification programs if appropriate.
(Closed) IE Bulletin (483/86001-BB): RHR pump minimum flow logic problems.
One of the selected documents for review was IEB 86-01. This IEB was applicable to BWRs and sent to Callaway for information. The licensee's review indicated no problem similar to the isolation of the minimum flow lines discussed in this IEB.
IEB 86-01 is considered closed.
(Closed) IE Bulletin (483/86004-BB): Defective Teletherapy Timer That May Not Terminate Treatment Dose.
IE Bulletin 86-04 was sent to the licensee for information and is also considered closed.
5.
Licensee Actions on Previous Inspection Findings (92701)
(Closed) Violations (483/86010-03(DRP) (483/86010-04(DRP) and (483/86017-01(DRP)); LERs (483/86009-01-LL) and 483/86018-00-LL): This matter relates to three violations of NRC requirements which resulted in a Notice of Violation and Proposed Civil Penalties issued to the licensee on September 9, 1986. The violations involved licensee's failure to; notify the NRC within four hours of having an inoperable Intermediate Head Safety Injection system (IHSIS), maintain the required IHSIS operable, and maintain the required Auxiliary Feedwater Pump Engineered Safety Features Actuation System Operable.
Licensee's response in this matter is documented in licensee's letter to NRC (ULNRC-1384) dated October 9, 1986.
The letter enclosed the payment of the Proposed Civil Penalty and included the corrective action taken to avoid further violations. Corrective action included the following:
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Progressive discipline was imposed on responsible personnel.
b.
Management briefings to appropriate plant personnel.
c.
Revisions of administrative and plant procedures.
d.
Revision of reporting requirements /requalification training courses.
The inspector has completed review of licensee's response in this matter. The inspector determined that the licensee has provided appropriate response and that the corrective measures taken to prevent recurrence have been implemented. There has been no recurrence of
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violations of this nature. Licensee Event Reports (LERs) 86009-01 and 86018-00 are considered closed.
(Closed) Open Item (483/86012-01(DRS)): Office of Nuclear Reactor Regulation (NRR) to review the term " annual" as it applies to the licensee's operator requalification program. The use of the term
" annual" has been applied differently for requalification program written exams and reactivity control manipulations.
The NRR staff accepts requalification programs with annual written exams that are conducted on a 12 month interval.
Extending the interval between written exams to greater than 12 months, would require specific authorization by the Commission pursuant to 10 CFR 50.54 (1-1). This will also apply to the two-year cycle of the requalification program specified in 10 CFR 55, Appendix A.1.
The NRR staff accepts annual reactivity control manipulations required in NUREG-0737 (Denton letter of March 28,1980) as completed once within a 12 month period. The licensee's interpretation of annual as once within a 12 month cycle is consistent with the Callaway Technical Specifications, and this will enable the licensee to obtain credit for on-facility manipulations as they occur.
6.
Independent Inspection (Radiation Monitoring System Filter Replacement During Containment Purge) (927 3)
a.
Background On October 21, 1986, the NRC resident inspector at the Wolf Creek (WC) Nuclear Station notified the Callaway resident inspector of a Technical Specification (T/S) violation at WC relating to operation of the containment purge during p-
'ods when the radioactivity monitors were inoperable (monitor piaced in bypass for filter replacement). The T/S violation resulted from Wolf Creek's decision to continue purge operation during filter replacement while in " refueling" with the containment equipment hatch removed.
WC considered this practice preferable as continuing purge operation assured an inflow of air into the containment.
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An inspection in this matter was performed to determine the procedure / method used for filter replacement at Callaway during the Cycle 1 refueling outage. The inspection included the review of the licensee's records / reports and associated procedures and interviews with plant management and health physics personnel, b.
Findings (Closed) Violation (483/86011-01(DRSS)) and LER (86016-01)
In response to the inspector's questions relating to filter replacement, health physics (HP) supervisory personnel stated that during the outage, (March-April,1986) the HP practice for filter replacement was to; stop the sample pump, change out the filter,
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and restart the sample pump. The sample flow to radioactivity monitors GT-RE-31 or GT-RE-32 would be stopped for approximately 1-2 minutes during each filter replacement. This change out activity was performed at various times during the outage while the containment purge valves remained open. HP procedure relating to containment purge, that was in effect during the outage (HTP-ZZ-02012, Revision 9), provided no guidance with regard to filter replacement. The replacement activity was performed in accordance with vendor instruction and was considered to be within the " skill of the craft". HP personnel had considered filter replacement as being incidental to radiation monitoring system operation and did not recognize the activity as having T/S
" operability" impact. Therefore, no incident / event reports were processed.
Technical Specifications 3.3.3.1 requires that both radiation monitors (GT-RE-31 and GT-RE-32) be operable at all times. Action 26 specifies that with less than the minimur channels operable, operation may continue provided the containment purge valves are maintained closed.
Operability of radioactivity monitors GT-RE-31 and GT-RE-32 is dependant on a continuous sample flow. The containment purge valves being open, during the time either radioactivity monitor was inoperable is an apparent violation of T/S 3.3.3.1.
The inspector determined that the prohibited condition existed for only brief periods but at various times during the outage, that the condition went unrecognized by the licensee, and resulted from inadequate procedural guidance associated with containment purge.
The inspector discussed this matter with the licensee on October 23, 1986. The licensee acknowledged the inspector's findings and documented the event in Incident Report (IR) No.86-218. The licensee also documented the event in Supplement 01 to Licensee Event Report (LER) No. 483/86-016.
LER 86-016 reported a similar but more recent event which occurred on May 21, 1986.
That event involved placing the radioactivity monitors GT-RE-31 and GT-RE-32 in " bypass" while containinent purge was in progress.
The licensee discussed the corrective action taken following the May 21, 1986, event and noted that there had been no recurrence.
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A followup inspection of the event reported in LER 86-016 is documented in NRC Inspection Report 50-483/86011(DRSS).. A Notice of Violation was. issued.for the event. The report noted previous similar events and requested that licensee response address the matter-of recurrence.
The inspector has completed-review of the licensee's corrective action reported in LER 86-016 and in the licensee's letter (ULNRC-1391) response to the Notice of Violation 50-483/86011-01.
In addition to administrative action and directives, the licensee
.has conducted special radiation monitoring training courses and has
' provided physical encumbering devices'for the ESFAS bypass switches. Procedure HTP-ZZ-02012 " Gaseous Radwaste Release (Containment Purge)" has been revised. The procedure now prohibits filter replacement while the containment purge is' operating and the containment purge checklist specifies use of the encumbering devices. To preclude similar problems during plant outages, as identified at Wolf Creek, the licensee is processing a T/S change, if approved, would permit containment purge with one containment radioactivity monitor inoperable.
A violation is identified in paragraph 4.b. above. The violation is considered to have only minor safety or environmental significance, as independent containment purge system monitors and one of the two containment atmospheric monitors were available to provide automatic purge isolation. The inspection showed that licensee's response to a subsequent recurrence of this violation, for which a Notice of Violation was issued, has been effective.
Therefore, a Notice of Violation is not being issued. Violation 50-483/86011-01' and LER 86-016-01 are considered closed.
7.
Licensee Event Report (LER) Followup (90712 and 92700)
An inspection of LERs was performed to determine that the reporting requirements were fulfilled, immediate corrective action was acc.omplished, and that events were evaluated for root cause and received appropriate corrective action to prevent recurrence.
In addition, each i
event was evaluated for previous events and generic applicability. The inspection included an in-office review, direct observations, the review of plant records and interviews with licensee personnel.
a.
(Closed) LERs 483/85-007-00 and 01, 483/85-011-00, 483/85-034-00, 483/85-038-00 & 01, 483/85-039-00, 483/85-044-00, 483/85-048-00,
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483/85-049-00,483/85-054-00,483/86-005-00,483/86-006-00, 483/86-013-00, and 483/86-033-00.
LER N0.
TITLE 483/85-007-00 & 01 Non Environmentally Qualified Tenninal Blocks
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483/85-011-00 Manual Reactor Trip (Loss of Startup
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483/85-034-00 Reactor Trip (Power Range Hi Negative Flux Rate)
l 483/85-038-00 & 01 Reactor Trip (Loss of Field to Main Generator)
483/85-039-00 Reactor Trip (Turbine Trip on Hi Moisture SeparatorLevel)
F 483/85-044-00 ESF Actuation (Hi Steam Generator Level)
483/85-048-00 Reactor Trip (Hi Negative Flux Rate)
483/85-049-00 Reactor Trip (Turbine Trip on Hi Stator Water Temp.)
483/85-054-00 Reactor Trip (Spurious OT Delta T Signal)
483/86-005-00 Ventilation System Isolation (Loss of Power to NB02)
483/86-006-00 ESF Actuation (Spurious Radiation Monitoring Signal)
483/86-013-00 Reactor Trip (Low Steam Generator Level)
483/86-033-00 ESF Actuation (Blown Fuse on CR Radiation Monitor)
The inspector determined that the events received a high level of management attention, and were thoroughly evaluated for cause and corrective action within licensee's Event and Trip Reduction Program. The licensee's performance shows that a favorable trend has been achieved in the frequency of both reportable events and trips. The above LERs are considered closed.
No violations or deviations were identified.
b.
The following LERs document the licensee's failure to meet Technical Specifications (T/S) Surveillance Requirement. An inspection of these events was performed to assess licensee's response, including the identification of root cause and corrective measures. The inspection included a review of licensee's overall surveillance program and independent review and audit functions.
(Closed) LERs 483/85-029-00, 483/85-053-00, 433/86-031-00, and 483/86-032-00.
LER N0.
TITLE 483/85-029-00 Failure to meet Surveillance Requirement (Emergency Access Hatch DSM51)
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483/85-053-00 Failure to Surveil a T/S Containment Penetration (P-98)
483/86-031-00 Baron Dilution Setpoint Not Properly Verified 483/86-032-00 Power Range Low Setpoint Not Verified Per Surveillance Requirements Findings LER 483/85-029-00: On June 7, 1985, an I&C Technician, in response to a scheduled surveillance for leak test of the Emergency Hatch (EAH) DSM51, inadvertently performed the surveillance on the Personnel Access Hatch (PAH) DSM50. The test results for DSM50 was attached to DSM51 Surveillance Task Sheet. The surveillance of DSM51 was required as the result of opening the hatch at approximately 4:00 p.m. on June 4,1985, while operating in Mode 1.
T/S 4.6.1.3 requires that each airlock (includes DSM51) be demonstrated operable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, (plus T/S 4.0.2 allowable extension of 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />), following each closing, thus requiring that hatch DSM51 be tested prior to 10:00 a.m. on June 8, 1985.
On June 11, 1985, the licensee discovered the error while performing a specified engineering package review.
Surveillance Task Sheet DSM51 was reissued and the required surveillance of DSM51 was satisfactorily completed at 9:30 p.m. on June 11, 1985.
Licensee's failure to perform the required surveillance within the specified time interval is a violation of T/S Surveillance 4.6.1.3.
The inspector determined that the event posed no significant threat to public/ plant safety, as the EAH inner door was operable during the time interval, in which the hatch DSM51 surveillance was delinquent. The violation was identified through the licensee review process and once identified was appropriately corrected, documented, and reported to NRC.
LER 483/85-053-00: On December 9, 1985, during a Quality Assurance audit walkdown, the licensee discovered that the specified monthly verification surveillance of containment penetration P-98 (associated with the Breathable Air System (KB) inner and outer isolation valves KB-V-On1 and KB-V-002) had not been performed as required by Technical Specifications. T/S 3/4.6.1.1 requires that containment integrity be demonstrated at least every 31 days by verifying that all penetrations are closed by valves, blind flanges, or deactivated automatic valves secured in their closed positions.
The licensee investigation determined that because of docunent control and review errors, penetration P-98 had not been ircluded in surveillance procedure OSP-GP-00001 (Containment Integrity Verification) and therefore not performed as required during the period August 10, 1984 (since entry into Mode 4) and December 9,
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1985. The. investigation' determined that primary containment integrity had been maintained during that period since the KB-system had not been made operable and was secured by closed valves and a blind flange. However,. licensee's failure to perform the specified monthly surveillances is a violation of T/S-3/4.6.1.1.
The inspector determined that the violation was an isolated event, which_was identified and reported by the licensee. A post event review of.su'rveillance procedures, using design documents, found no further omissions. The deficiencies / oversight associated with this event existed or occurred at the time of initial licensing. Since that time, licensee's administrative, configuration controls, and
. review program.have been strengthened. There has been no recurrence of this nature.
LER 483/86-031-00: On September 12, 1986, following an internal review of Licensee Event Report 86-015-00 submitted by Commonwealth Edison's Byron Unit 1, plant personnel discovered that erroneous input test voltages had been incorporated into the surveillance procedures (ISF-SE-00N31 and ISF-SE-00N32) which verify the Boron Dilution Setpoint of the Source Range Nuclear Instrumentation (SRNI) per note 9 of T/S Table 4.3-1, the monthly surveillance of the SRNI is to include verification that the Boron Dilution Setpoint is less than or equal to an increase of twice the count rate within a ten minute period (applies in Modes 2 (below P-6),
3, 4, and 5)..The erroneous input test voltages were such that a count rate increase factor of less than or equal to 2.11 was verified rather than an increase factor of less than or equal to 2.0.
The erroneous input test voltages resulted from incorrect information contained in Westinghouse Vendor Manual (M762-310).
In response to this matter, the licensee initiated appropriate document and procedure changes. A functional surveillance test performed on September 12, 1986, showed that the SRNI Boron Dilution modules were set for a flux doubling signal of 2.0 (without having been adjusted since initial installation), thus, would have performed their specified function.
However, licensee's failure to properly verify the Boron Dilution Alarm Setpoint during applicable Modes beginning with the initial entry into Mode 5 (June 28, 1984) in a violation of T/S 3/4.3.1.1.
The inspector determined that the event posed no significant threat to public/ plant safety and was an isolated event which received appropriate licensee response. There has been no recurrence of this nature.
LER 483/86-032-00: On September 18, 1986, during the licensee's review of Operating License Amendment No. 17, the licensee determined that at various times from November 1984 through September 1986, surveillance testing of the Power Range (PR)
Neutron Flux Low Setpoint (25% rated thermal power (RTP)) had not been completely performed as required by plant Technical
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Specifications. The review was performed to assess Amendment No. 17's impact on existing surveillance procedures.
Prior to Amendment 17, the Technical Specifications Table 4.3-1 specified that the Analog Channel Operational Test (ACOT) of the Power Range Neutron Flux Low Setpoint be performed " monthly" with applicable Modes specified as Mode 1 (below P-10) and Mode 2.
Amendment 17 did not change the surveillance requirement but changed " monthly" to "startup - if not performed in previous 31 days."
It was during the review of this change that the licensee realized that a complete PR low setpoint ACOT was not being performed within 31 days prior to each startup or load reduction / shutdown below 10% RTP.
ISF-SE-00N41, 42, 43, and 44 were written such that a complete ACOT which verified the PR low setpoint was only performed when power was below the PR low setpoint (25% RTP). When above 25% RTP, the procedures only verified the "0VERPOWER TRIP LOW RANGE" light to be on at the PR drawers and the "PR LOW SETPT" light to be on at the reactor partial trip status panel in the Main Control Room.
Licensee's evaluation of cause attributed the event to deficiencies in the initial procedure development and surveillance tracking which occurred prior to initial fuel loading. Their evaluation also found that other than the initial ACOTs after installation of the PR drawers, at least seven ACOTs have been performed for each PR low setpoint trip bistable since September 23, 1984. A review of these ACOTs determined that each surveillance had found the bistable set to trip at 25% RTP. The review also determined that no adjustments to the bistables were required to be made during the ACOTs.
Based on this, there is reasonable assurance that the PR low setpoint would have provided a reactor trip signal at 25% RTP during a reactivity transient during startup.
Additionally, a 25% RTP reactor trip setpoint is provided by the Intermediate Range Nuclear Instrumentation in Mode 2 and Mode 1 below 10% RTP. The ACOT for this setpoint had been performed prior to each startup. Therefore, an additional reactor trip signal at 25% RTP was available to protect against a reactivity transient.
In addition to correcting the deficiencies, Instrument & Controls (I&C) personnel performed a review of T/S related surveillance procedures. No deficiencies were identified during this review.
The licensee's Quality Assurance (QA) conducted a special surveillance, (Surveillance Report No. P8611-05) which focused on Reactor Trip Instrumentation Surveillance Requirements and also performed a QA audit (Audit Report No. G170.07-8609P) which included selected Technical Specifications and observation of surveillance testing.
Based on this effort, QA determined that the I&C program was adequately implemented and effective.
The inspector determined that the event posed no significant threat to public/ plant safety and that appropriate licensee action to
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prevent recurrence has been taken. However, licensee failure to perform the required ACOT surveillance as specified in T/S Table 4.3-1 is a violation of T/S 4.3.1.1.
Violations are identified in the above LERs which meet the criteria for 10 CFR Part 2, Appendix C for which a notice of violation will not generally be issued. These violations are of lesser severity which were identified, reported, and satisfactorily corrected by the licensee, and are not violations that could reasonably be expected to have been prevented by the licensee's corrective action for a previous violation. Therefore, no notice of violation is being issued and these LERs are considered closed.
8.
Cold Weather Preparations (71714)
Plant Administrative Procedure APA-ZZ-0032 (Plant Cold Weather Protection) provides licensee's program of protective measures for extreme cold weather. An inspection was performed to verify that the licensee has developed and implemented an effective cold weather protection program. The procedures for systems that are susceptible to freezing were reviewed and found to have procedures and checklists for preparations necessary for operations during cold weather. The fire protection systems were spot checked and revealed that preparations for cold weather had been implemented.
Selected thermostats, heat-tracing and space heaters were noted to be functional.
No violations or deviations were identified.
9.
Monthly Maintenance Observation (62703)
Station maintenance activities of safety related systems and components listed below were observed / reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides and industry codes or standards and in conformance with Technical Specifications.
The following items were considered during this review:
the limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; functiunal testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and fire prevention controls were implemented. Work requests were reviewed to determine status of outstanding. jobs and to assure that priority is assigned to safety related equipment maintenance which may affec >, system performance.
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The following maintenance activities were observed / reviewed:
Procedure No.
Activity MSE-SB-05001 Reactor Trip Switchgear - Clean, Inspect, and Lubricate WR 64155 Diesel Generator "A" Replacement of Lube 011 Inlet Bypass Temperature Control Valve 47520(CMP-0508)
Main' Steam Dump Valve Control Solenoid HST Electrical Connection 55910 Train "B" Intermediate Range HST Electrical Connection 57996 Steam Generator "A" Feedwater Flow Instrument HST Electrical Connection Following completion of maintenance, the inspectors verified that these systems had been returned to service properly.
No violations or deviations were identified.
10. Monthly Surveillance Observation (61726)
The inspector observed Technical Specifications required surveillance testing and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that limiting conditions for operation were met, that removal and restoration
~ f the affected components were accomplished, that test results conformed o
with Technical Specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and-that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personnel.
The inspector also witnessed portions of the following test activities:
Procedure No.
Activity ISF-EF-00P43, P44 Functional Pressure - ESW Flow to Air Compressor ISF-BB-0P455, 6, Functional Pressure - Pressurizer Pressure 7, and 8 Protection OSP-SB-00001 Reactor Trip Breaker Actuating Device Operational Test OSP-BG-V001B Stroke Tine - Valve EM-HV-8803B BIT Inlet.
ISL-GS-00A2B Loop-ANAL-Containment Hydrogen Analyzer - Tranin "B"
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ISF-AE-0L554 S/G "D" Narrow Range Level Functional Test No violations or deviations were identified.
11. Operational Safety Verification (71707)
The inspectors observed control room operations, reviewed applicable logs and conducted discussions with control room operators throughout the inspection period. The inspector verified the operability of selected safety related systems, reviewed tagout records, and verified proper return to service of affected components. Tours of the reactor, auxiliary, and turbine buildings were conducted. During these tours, observations were made relative to plant equipment conditions, fire hazards, fire protection, adherence to procedures, radiological control and conditions, housekeeping, security, tagging of equipment, ongoing maintenance and surveillance, containment integrity, and availability of safety related equipment.
No violations or deviations were identified.
12. Thermal Hydraulic Anomaly (93702)
On November 17, 1986, while operating at approximately 80% reactor power, periodic power range deviation alarms were received in the control room from power range channel 4 (PRN44 detector). Subsequent evaluation by the licensee's Instrument and Control (I&C) personnel, which included instrumenting the power supply to the nuclear instrument determined that the PRN44 detector was functioning (correctly.
On November 18, 1986, licensee's Nuclear Engineering NE) investigated the problem by collecting information from selected plant instrumentation including excore detectors, incore detectors, incore thermocouples, neutron noise, loop flows, loop temperatures, RVLIS vessel delta pressure, RCP amperage, and loose parts monitoring.
Investigation of the data determined the existence of a thermal hydraulic anomaly.
The anomaly is indicated as random decreases up to one percent (1%)
reactor power with temperature increases up to 1 degree F on incore thermocouples. Variations were also occurring in vessel delta pressure and reactor coolant system loop flow. The anomaly occurres irregularly every 3-4 minutes with typical duration of 20 to 30 seconds.
In response to the anomaly, the licensee obtained onsite review /
consultations from representatives of the vendor (Westinghouse) and Technical Energy Corporation (TEC). The licensee also performed a Nuclear Safety Evaluation (10 CFR 50.59 Review) which provided bases and justification of continued full power operation. The licensee concluded that the observed deviations in reactor coolant flow, temperature, and neutron flux are within the limits of the Technical Specification (T/S).
There is no evidence of any loose part flow blockage, or internal abnormality. Union Electric Nuclear Engineering finds no basis to support the existence of an unreviewed safety question. Concurrence with these conclusions has been obtained from Westinghouse Electric Corporation, Power Systems.
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The inspector was initially appraised of the power range deviation alarms on November 17, 1986, during a routine cor. trol room walkdown and subsequently maintained overview of the anomaly, and of licensee's response in this matter. The inspector performed frequent observations of plant instrumentation and stripchart recordings of selected parameters, held frequent discussions with members of licensee's Nuclear Engineering Department and plant management and verified that the variations were not divergent in nature and were within the limits of T/S.
The cause of the thermal hyoraulic anomaly has not been determined.
The licensee is continuing its investigation in this matter. This item is open pending further NRC review (0 pen Item No. 483/86020-01(DRP)).
13. Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. An open item disclosed during the inspection is discussed in Section 12.
14. Exit Interview (30703)
The inspector met with licensee representatives (denoted under Persons Contacted) at intervals during the inspection period. The inspector summarized the scope and findings of the inspection. The licensee representative acknowledged the findings as reported herein. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such documents / processes as proprietary.
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