ML20050M494

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IE Insp Rept 50-454/82-02 on 820125-29,0202-03 & 16-19. Noncompliance Noted:Failure to Adequately Specify Sys Status & Failure to Provide Adequate Measures to Protect safety-related Equipment
ML20050M494
Person / Time
Site: Byron 
Issue date: 03/10/1982
From: Jackiw I, Ring M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20050M169 List:
References
50-454-82-02, 50-454-82-2, NUDOCS 8204140311
Download: ML20050M494 (6)


See also: IR 05000454/1982002

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

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Report No. 50-454/82-02

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Docket No. 50-454

License No. CPPR-130

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Licensee: Commonwealth Edison Company

Post Office Box 767

Chicago, IL 60690

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Facility Name: Byron Station, Unit 1

Inspection At: Byron Site, Byron, IL

Inspection Conducted: January 25-27, 29 and February 2, 3, 16-19, 1982

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Inspector:

M. A. R g

J2Macb

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Approved By:

,T'.' N. Jlickiw, Chief

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' Test Program Section

Inspection Summary

Inspection on January 25-27, 29, and February 2, 3,

16-19, 1982 (Report No.

50-454/82-02(DETP))

Areas Inspected: Routine announced inspection to review preoperational

test procedures, witness the performance of preoperational testing, review

the evaluation of preoperational test results and review previous open

items. The inspection involved 65 inspector-hours onsite and 33 inspec-

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tor-hours in office by one NRC inspector including 0 inspector-hours onsite

during off shifts.

Results: Of the four areas inspected, two items of noncompliance were

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identified in one area (failure to adequately specify system status -

Paragraph 4b(1) and failure to provide adequate measures for the care and

preservation of safety-related equipment - Paragraph 4b(2)).

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8204140311 820330

DR ADOCK 05000454

PDR

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DETAILS

1.

Persons Contacted

  • C. Tomashek, Byron Startup Group
  • R. Ward, Assistant Superintendent, Administration and Support
  • D.

St. Clair, Tech Staff Supervisor

  • R.

Klingler, QC Supervisor, Project Construction

  • G.

Sorensen, Construction Superintendent

  • R.

Querio, Station Superintendent

  • L.

Sues, Assistant Superintendent, Maintenance

  • R. Tuetken, Assistant Construction Superintendent
  • J.

Binder, Project Electric Supervisor

  • F. Willich, Quality Assurance
  • A.

Jaras, Project 0AD Supervisor

  • F.

Hornbeak, Assistant Technical Staff Supervisor - Startup

  • A.

Chomacke, Assistant Technical Staff Supervisor

R. Grams, Master Instrument Mechanic

B. Milner, Technical Staff

W. Walter, Technical Staff

  • Denotes those attending the exit interview.

2.

Licensee Action on Previouc Inspection Findings

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a.

(Closed) Noncompliance (454/81-11-01): The item dealt with an

inadequate review of a Startup Manual Change. The inspector

reviewed the specific corrective action and subsequent revisions

5 and 6 to the Startup Manual and considers the item acceptable.

b.

(Closed) Noncompliance (454/81-11-02): The item consisted of

three parts, two of which dealt with verifying instrument cali-

bration while the third dealt with exceeding a test pressure

band. The inspector reviewed the corrective actions outlined

by the licensee response including a review of Byron Instrument

Procedures 2000-004, Frequency of In-Plant Instrument Calibration

and 2000-003, Frequency of Calibration of In-Plant Instrumentation

- FSAR Requirements.

In addition, the inspector reviewed test

procedures 2.67.10, Residual Heat Removal and 2.22.10, Diesel

Generator as examples of corrective action and considers the item

acceptable.

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3.

Preoperational Test Procedure Review

The inspector reviewed test procedures 2.67.10, Residual Heat Removal,

2.73.11, Safety Injection Accumulator System, 2.24.10, Diesel Fuel Oil

and 2.22.10, Diesel Generator against the FSAR and Regulatory Guide 1.68.

The following problem areas were noted:

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a.

Other than those values addressed as acceptance criteria in

the FSAR, the test procedures were not providing acceptance

values and tolerance ranges for data such as alarms and trip

points being checked by the test.

The inspector pointed out

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to the licensee that this practice may be preventing test

engineers from recognizing and documenting deficient conditions

as they occur during the performance of the test.

The licensee

acknowledged the potential problem and proposed providing expected

values and tolerance ranges for all safety related system alarms

and trip points. Any observed data falling outside these bounds

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would then be documented and resolved via the test procedure

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evaluation process or as a deficiency. This is an open item

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(454/82-02-01) pending the licensee formally documenting the pro-

posed method for handling the " secondary" class of acceptance

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values and inspector review of the implementation.

b.

The Diesel Generator Test, 2.22.10 was also reviewed against

Regulatory Guides 1.108 Revision 1, dated February 1977,

and 1.9 Revision 0, dated March 10, 1971 and IEEE Std 387-1972.

NUREG/CR-0660, Enhancement of On-site Emergency Diesel Generator

Reliability, was also utilized in the review. The inspector

discussed several comments with the licensee primarily dealing

with where and how the regulatory positions of the above

standards were satisfied. This is an open item (454/82-02-02)

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pending further discussion with the licensee.

No items of noncompliance or deviations were identified.

4.

Preoperational Test Witnessing

a.

The inspector witnessed portions of the performance of tests 2.67.10 Residual Heat Removal and 2.22.10 Diesel Generator.

The inspector verified the following aspects of the test

performance:

(1) Latest revision and chcnges incorporated into procedure

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(2) Minimum crew requirements satisfied

(3) Test preprequisites satisfied

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(4) Necessary briefings conducted

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(5) Test equipment properly installed

(6)

Instrumentation calibrated and inservice

(7) Personnel possessed adequate knowledge of the system and

the test procedure

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(8) Generally satisfactory conduct of test

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b.

While observing the performance of the above tests, the inspector

noted the following problem areas:

(1)

In the RHR and SI systems the instruments listed below were

found to not be " blue taped" indicating turnover for preoper-

ational test even though the System Status Notice in the

Control Room showed that the instruments were included in

the turnover. This observation was made on January 26, 1982.

(a) RHR flow switch indicator IFIS0610

(b) RHR flow transmitter 1FT0618

(c) RHR pressure transmitter IPT-614

(d) RHR suction pressure gauge 1PIO601

(e) RHR flow switch 1FS0611

(f) RHR suction pressure gauge 1PIO602

(g) SI pump 1A discharge pressure gauge 1PISIO44

In addition, the inspector observed blue tape of similar color

wrapped around piping to many instruments in the same panels.

During discussion with one of the Quality Assurance personnel,

the inspector was informed that this tape was used by the 11-

censee's instrument contractor, Power-Azco-Pope, as an aid in

establishing separation for ESF and RPS instrumentation and was

described in an internal memo, dated November 2, 1981, entitled,

" Color Codes for Instrument Pipes".

The operations and tech staff

personnel, including management, indicated that they were unaware

of the existence of this second use of colored tape. Use of the

instrument contractor's colored tape system served to further

confuse the determination of the test inspection status of the

system instruments. Failure to adequately establish and implement

measures to indicate the status of inspections and tests performed

upon items of the power plant is considered to be a violation of

10 CFR 50, Appendix B, Criterion XIV and the Byron Station Startup

Manual paragraphs 4.1.1 and 4.1.2 and is considered to be an item

of noncompliance (454/82-02-03).

(2) The inspector observed the following conditions potentially

damaging to safety related equipment:

(a) Level 346 - 2 in. x 12 in x 10 ft. board - laying across

instrument lines to panel 1PL93J.

(b) Level 346 - 4 ft. x 6 ft. plywood piece leaning against

instrument panel.

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(c) Level 346 - water dripping on IA containment spray

pump (drain plugged on 364 level).

(d) Area of RHR pump 1A - cubicle cooler being used as

storage platform or trashcan (rags, a valve, many

fittings, couple of boards on top), red air hose

draped around RH pump suction pressure, isolation

valve IRH8739A.

(e) Area of RHR Pump 1B - same problem as with 1A cubicle

cooler, 2 in. x 12 in. board wedged in behind suction

pressure instrument line.

(f)

In RHR Heat exchanger 1B room (a) 2 in. x 4 in. staging

resting on top of temperature instrument ITI-609 (b) one

saw blade, several cigarettes, piece of wood, much dirt

and grit, one blue taped valve hand wheel resting in

instrument air tray to air operated valve RH 607 (c)

half-crushed air tubing to air operated valve RH 607

(d) hi point vent line open to room (no cap or cover).

(g)

In RHR heat exchanger 1A room (a) high point vent

valve handwheel off (lying on staging); nut missing

(b) vent line open to room (i.e., no cap or dust cover).

(h)

In SI pump A room (a) 2 wooden signs, 1 2 in. x 4 in.

board, couple of pieces of cardboard, 1 in. nut lying

on top of pump motor (b) general housekeeping in room

poor - conduit, tubing, boards, cardboard, rags strewn

about room, tape, cigarettes, loose nut and bolts and

paper all over.

(1) Area of instrument manifold for 1P1-S1-044 - (SI Pump

1A Discharge Pressure) - step ladder chained to instru-

ment piping, several coats hung on valves and instru-

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ments, roll of cable draped over the manifold.

(j) Temperature instrument - 1 TICS 040 - missing glass face

(in CS pump 1B room).

(k)

In DG-1A room - on top of diesel generator control panel

1PLO75-DG1A.

Coke cans, bag of potato chips, 4 ft. x 4 ft.

piece of cardboard, loose tape, several loose connectors,

aluminum foil, loose scraps of wire, cigarette butts, dust,

dirt grit.

(1) Step ladder chained to same instrument piping as in item 9.

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1/8" piece of boilerplate approximately 2 1/2 ft. x 2 1/2 ft.

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1eaning against instrument isolation valve for refueling

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water purification pump OA discharge pressure gauge.

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(n) Welding lead run around each of the air gauges on air

operated valve RHR 607.

(o) In DG -1B room - chunks of debris (probably concrete or

insulation) behind screens on both air dryers.

Similar problems were identified in NRC Inspection Report No.

50-454/81-12-01 and followup Reports No. 50-454/81-18,

50-455/81-14, 50-454/82-03 and 50-455/82-02. The licensee

does not have an adequate program to ensure proper care and

preservation of safety related equipment as shown by the fact

that the same problems still exist to the same degree. Lack

of a program to ensure proper care and preservation of safety

related equipment as required by ANSI N45.2.2 is inconsistent

with the QA Manual and with 10 CFR 50, Appendix B, Criterion

XIII and is considered to be an item of noncompliance

(454/82-02-04).

5.

Preoperational Test Results Evaluation

The inspector commenced review of the results of preoperational test

2.73.11 Safety Injection Accumulators System and the review is still

in progress.

No items of noncompliance or deviations were identified.

6.

Exit Interview

The inspector met with licensee representatives (denoted in Paragraph

1) on February 19, 1982. The inspector summarized the scope and

findings of the inspection. The licensee acknowledged the statements

made by the inspector with respect to the open items and the items

of noncompliance (Paragraphs 4.b.1 and 2).

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