ML20129F130
| ML20129F130 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 09/24/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20129F047 | List: |
| References | |
| 50-454-96-06, 50-454-96-6, 50-455-96-06, 50-455-96-6, NUDOCS 9610010260 | |
| Download: ML20129F130 (24) | |
See also: IR 05000454/1996006
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U. S. NUCLEAR REGULATORY CONNISSION
REGION III
Docket Nos:
50-454, 50-455
License Nos:
Report No:
50-454/455/96006
Licensee:
Commonwealth Edison Company (Comed)
Facility:
Byron Generating Station, Units 1 & 2
Location:
Opus West III
1400 Opus Place
Downers Grove, IL 60515
Dates:
July 3 - August 17, 1996
Inspectors:
H. Peterson, Senior Resident Inspector
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N. Hilton, Resident Inspector
G. Pirtle, Regional Security Specialist
J. Foster, Senior Emergency Preparedness Analyst
R. Jickling, Emergency Preparedness Analyst
C. Thompson, Illinois Dept. of Nuclear Safety
Approved by:
Lewis F. Miller, Jr., Chief
Reactor Projects Branch 4
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9610010260 960924
ADOCK 05000454
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EXECUTIVE SUMARY
Byron Generating Station, Units 1 & 2
NRC Inspection Report 50-454/455/96006
This integrated inspection included aspects of licensee operations.
engineering, maintenance, and plant support.
This report covers
<-week
period of resident inspection; in addition, it includes the results of
announced inspections by a regional security specialist and two regional
emergency preparedness specialists.
Operatiofit
Corrective actions resulting from the discovery of an open watertight door
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on February 22, 1996, were ineffectivc in preventing a recurrence of an
open watertight door on July 15, 1996. This was considered a violation of
10 CFR 50, Appendix B, Criterion XVI (50-454/455-96006-01(DRP)).
The licensee shutdown Unit 2 due to a steam generator tube leak. The
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licensee set an administrative limit for shutdown at 120 gallons per day
(gpd). This limit was below the technical specification and abnormal
operating procedure limit of 150 gpd. Additionally, the inspectors
concluded that the operators and chemists performed well during the
initial identification, continued trending, and final resolution to
shutdown the unit (Section 01.3).
Maintenance
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Work controls for auxiliary feedwater system surveillances failed to
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prevent installation of the strip chart recorder on the B Auxiliary
Feedwater (AF) train while the A train was inoperable for a routine
surveillance. The installation resulted in both trains of Auxiliary
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Feedwater being inoperable (Section M1.1).
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Enc #neerino
The licensee's search for additional foreign objects in the Unit 2 steam
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generators was good.
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Plant Suonort
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The overall effectiveness of the licensee's emergency preparedness
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facilities, equipment, training, and organization was excellent (Sections
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P2.1, P3, and PS).
Audits and surveillances of the emergency preparedness program, including
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the Peer Review, were effective in evaluating the program and identifying
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program problems (Section P7.1).
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Security self-assessment and monitoring the use of security badges for
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contractor personnel were considered strengths (Section S7).
Unresolved items were noted pertaining to Medical Review Officer
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involvement in for cause fitness-for-duty testing (Section 58.1), and not
a:certaining activities for licensee personnel not under a behavior
observation program (Section S8.6).
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Report Details
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Summary of Plant Status
Unit I completed a refueling outage (BIR07) on July 3, 1996. The unit
operated at or near full power following startup and throughout this
inspection period with no significant problems.
Unit 2 remained at or near full power throughout the first part of the
inspection period. Unit 2 chemistry results indicated a small steam generator
tube leak in mid-July. The leak continued to increase slowly until August 7,
when the leak rate calculations indicated steam generator tube leakage was
greater than 120 gpd. A controlled shutdown was performed. After
approximately one week of forced outage due to the steam generator tube leak,
the licensee transitioned to a refueling outage, originally scheduled to start
September 7, 1996. Unit 2 remained in the refueling outage at the end of the
inspection period.
I.
Operations
01
Conduct of Operations
01.1
General Comments (71707)
Using Inspection Procedure 71707, the inspectors conducted frequent
inspections of plant operations.
Routine operations were conducted in a
safe, professional manner, Specifically, the operators performed well
during the unplanned Unit 2 shutdown discussed in Section 01.3 below.
One operations related event regarding control of watertight doors was
also discussed in Section 01.2.
01.2 Auxiliary Buildina Floor Drain Sumo Room Watertiaht Door Found Ooen
a.
Insoection Scone
On July 15, 1996, the inspector identified that the Unit 2 Auxiliary
Building Floor Drain Sump room door was open and unattended. The
inspector reviewed a previous related NRC violation, licensee corrective
actions to that related violation, and the station flooding analysis,
b.
Observations and Findinas
On July 15, 1996, the inspector identified that the Unit 2 Auxiliary
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Building Floor Drain Sump room door was open and unattended. The sump
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room door was a watertight door in the B train Essential Service Water
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(SX) pump room.
Byron Administrative Procedure (BAP) 1100-3 " Fire
Protection Systems, Fire Rated Assemblies, Ventilation Seals, and Flood
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Seal Impairments," required the door to be shut except during personnel
passage or when the room was occupied.
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-On February 22, 1996, the inspectors identified the same door for Unit 1
open without the proper impairment controls. The licensee was issued a
violation for failing to follow procedures in Inspection Report 96-03.
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The open, unattended watertight door was an example used for the
violation (50-454/455-96003-Olb(DRP)).
The licensee investigation of the February 22, 1996, event was
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inconclusive. The licensee did not identify anyone who remembered
either leaving or seeing the door open. The door had a sign stating the
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door must remain closed at all times except during passage or when the
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room was occupied.. Corrective actions for the February 22, 1996, event
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included: a briefing on the requirements for flood seals was provided to
radiation protection personnel and station laborers; and a refresher
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session covering watertight seals was added to all continuing and
initial training courses.
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The inspector considered the corrective actions resulting from the
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February 22, 1996, event were ineffective in preventing a recurrence on
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July 15, 1996. The NRC identification of the open watertight door on
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July 15, 1996, was considered a violation of 10 CFR 50, Appendix B,
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Criterion XVI (50-454/455-96006-01(DRP)). Criterion XVI, Corrective
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Action, requires, in part, that the cause of a condition adverse to
quality be determined and corrective action be taken to preclude
repetition. At the end of the inspection period, the licensee was
performing a formal root cause investigation to determine appropriate
corrective actions.
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The inspector determined that the safety consequence of each occurrence
was minimal due to the small design flow rate into the floor drain sump
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room.
The inspector reviewed the flooding analysis, which was completed
after the door was installed, and verified the door was not required as
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a flood seal. The design pipe rupture in the floor drain sump room was
smaller than the design pipe rupture in the SX pump room. However, the
door was considered by the licensee to be a required flood seal for
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procedural consistency and additional safety margin.
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c.
Conclusions
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The inspector concluded that the corrective actions resulting from the
discovery of an open watertight door on February 22, 1996 were
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ineffective in preventing a recurrence on July 15, 1996. The NRC
identification of a similar watertight door open on July 15, 1996, was
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considered a violation of 10 CFR 50, Appendix B, Criterion XVI (50-
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454/455-96006-01(DRP)).
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01.3 Unit 2 Primary-to-Secondary Steam Generator Tube leak
a.
Insoection Scope (93702)
The inspectors reviewed the unexpected indication of a primary-to-
secondary steam generator tube leak on Unit 2.
The inspectors reviewed
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the licensee's decision to shutdown the unit, and observed chemistry and
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operations staffs' planning and execution of the shutdown evolution.
b.
Observations and Findinas
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On August 7, 1996, the licensee initiated a Unit 2 reactor shutdown at
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about 9:00 p.m. (CDT), when a primary-to-secondary tube leak in steam
generator "A" exceeded an administrative limit of 120 gallons per day
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(gpd). The peak leakage measurement taken at the condenser steamjet air
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ejector, sampling for Xenon 133 activity, was approximately 143 gpd.
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The six-hour measured average leakage rate was slightly above 120-gpd.
Technical Specification 3.4.6.2.c required the reactor to be' shutdown if
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any one steam generator leakage exceeded 150 gpd. At approximately
11:30 a.m. (CDT) on August 8, Unit 2 was shutdown with all control rods
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inserted with the reactor trip breakers open.
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The inspectors observed that the licensee performed an orderly shutdown
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at a slow rate of one megawatt per minute. The inspectors determined
that the licensee took proper actions to brief the crew and shutdown the
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reactor at a slow rate to prevent undue degradation to the steam
generator tubes from the power transient.
The licensee first identified the steam generator tube leakage when the
chemistry department measured an activity increase in Xenon 133 on July
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9, 1996. The measured leakage rate was approximately 5 gpd and steadily
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increased to about 80 gpd by August 5.
The leakage rate rapidly
increased to above 100 gpd over the next two days, which led to the
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forced outage.
Unit 2 was in a coastdown mode going into a scheduled
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refueling outage on September 7, 1996. Due to the unknown enuse for the
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steam generator leakage, the licensee scheduled the forced outage for
approximately one week and made plans to start the refueling outage
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early on August 19, 1996.
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Conclusion
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The inspectors concluded that the licensee satisfactorily took
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precautionary measures to shutdown the unit. The inspectors were
concerned with the steadily increasing leakage rate, but the licensee
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conservatively set an administrative limit for shutdown at 120 gpd.
This limit was below the technical specification and abnormal operating
procedure limit of 150 gpd. Additionally, the inspectors concluded that
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the operators and chemists performed well during the initial
identification, continued trending, and final resolution to sautdown the
unit.
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08
Miscellaneous Operations Issues
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08.1
(Closed) Violation 50-454/455-94025-01:
Failure to obtain initial
approval of overtime deviations prior to the occurrence on at least 29
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separate occasions. The inspector verified the corrective actions
identified in the violation respor.se were completed. Additionally, the
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inspector reviewed overtime deviation documents for the first six months
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of 1996. The inspector did not identify any overtime deviations without
prior' approval. The. inspector concluded that the licensee's corrective
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actions had been appropriate. This item is closed.
08.2 (Closed) Violation 50-455/93012-01(DRP): No response violation.
Issues
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on documentation deficiencies concerning administrative procedures
(special ~ plant procedures, limiting condition for operation action
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requirement procedures), were identified by the licensee and corrective
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actions were performed by the licensee.
Improvements to formal
procedural guidance, written communication control, and supervisory
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reviews were incorporated into licensee's administrative procedures.
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These improvements were incorporated at the time the violation was
issued; therefore, no written response was required. Subsequently, in
view of the licensee's initial response and lack of similar problems
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associated with documentation deficiencies. This item is closed.
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II. Maintenance
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M1
Conduct of Maintenance
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M1.1 Two Trains of Auxiliary Feed Water Inocerable (Unit 1)
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a. Insoection Scope (71707 & 61726)
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The inspector observed portions of IBOS 7.1.2.1.b-1, " Motor Driven
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Auxiliary Feedwater (AF) Pump Monthly Surveillance."
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b.
Observations and Findinas
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The licensee's monthly AF surveillance procedure required the AF pump to
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be isolated from the steam generators. The inspector verified the
proper technical specification (TS) limiting condition for operation
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(LCO) action requirement was entered prior to starting the surveillance.
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The motor driven AF pump was part of the A AF train.
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In addition to the monthly surveillance, the licensee planned to connect
additional instrumentation to both trains of AF.
The instrumentation
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was to support baseline data collection for evaluation of AF flow
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parameters. Specifically, strip chart recorders were planned to be
connected to the AF pump suction pressure transmitter test connections
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on both A and B pumps.
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While the A train was inoperable (due to the surveillance), an
instrument mechanic connected a chart recorder to the B train suction
transmitter. The instrument mechanic was using an authorized work
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package, approved by shift operators. When the strip chart ~ecorder was
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connected, the annunciator, " low suction pressure trip" was received for
the B AF pump. The low suction pressure trip would have tripped the B
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AF pump following an automatic actuation, which made the B train
inoperable. The operators realized that both trains of AF were
inoperable and entered the appropriate TS action statement (TS 3.7.1.2).
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At the direction of the control room operators, the instrument mechanic
immediately disconnected the chart recorder from the B train suction
transmitter. The A train surveillance was stopped and the system
returned to an operable status. Both trains of AF were inoperable for
approximately 8 minutes.
Instrument mechanics (IMs) had discussed the planned connection of the
strip chart recorders with the shift operators prior to beginning work.
The operators understood that the IMs were going to route cables and
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stage the-strip chart recorders. The IMs believed they had
authorization to connect the strip chart recorders to the test
connections.
c.
Conclusions
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The inspector concluded that work controls failed to prevent
installation of the strip chart recorder on the B AF train while the A
train was inoperable for a routine surveillance. This is an unresolved
item pending further review of the licensee's work planning for these
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activities (50-454/455/96006-10). The inspector also concluded that the
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operators demonstrated good system knowledge for immediately recognizing
that both trains of AF were inoperable.
M8
Miscellaneous Maintenance Issues
M8.1
(Closed) LER 50-454/93-002:
Unit 1 containment purge isolation system
(VQ) valves failed to close as required during a surveillance test.
During the performance of core alterations (fuel movements), the
technical specification required the VQ valves to be tested 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />
prior to fuel movement and every 7 days thereafter. During a subsequent
performance of this surveillance, the licensee found that train A valves
actuated, but the train B valves did not. The licensee identified that
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a jumper, which was installed to maintain the VQ automatic function in
service while the solid state protection system (SSPS) was in test
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during Modes 5 and 6, was accidentally dislodged. The licensee
determined that the jumper was dislodged during the continuity test
switch wiring work in the SSPS cabinet (LER 93-001). The licensee
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determined that the approximate time that train B of the containment
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purge isolation train was inoperable with core alteration in progress
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was 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />.
During this time train A was operable for purge
isolation.
The licensee immediately corrected the dislodged jumper and
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initiated corrective actions to prevent future occurrence.
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licensee's procedure improvements to specify correct reuting, new jumper
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end clips, and length of jumpers (too long which made it easier for them
to become dislodged) were completed July 9,1993.
This event resulted
in the failure of one train of VQ valves to close automatically.
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licensee's corrective actions were appropriate. This licensee
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identified and corrected violation is being treated as a non-cited
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violation, consistent with Section VII.B.1 of the NRC Enforcement Policy
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(50-454/455-96006-02). This item is closed.
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M8.2
(Closed) LER 50-455/93-002: Unit 1 essential service water (SX) pump
availability to Unit 2 surveillance not performed as required. With
Unit 2 in mode 1 and Unit 1 in mode 6, the technical specification
required that one of the Unit 1 SX pumps must be verified available to
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support Unit 2 operations once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. On March 11, 1993, due
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to personnel error, the Unit 1 operator failed to note in the
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shiftly/ daily operating surveillance the verification of the one SX pump
designated for Unit 2 support as being available.
The following shift
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identified the error and immediately performed the SX availability
surveillance. The safety consequence of this error was minor since the
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designated SX pump for Unit 2 support was previously designated as
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protected from any work activities. The licensee initiated improvements
in the shiftly/ daily surveillance to clarify when the surveillance are
required to be performed.
In addition the licensee verified the
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effectiveness of the improvements on September 1, 1994, and determined
that there w re no similar occurrences. The licensee's corrective
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actions were appropriate. The failure to perform a surveillance was a
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violation; however, this licensee identified and corrected violation is
being treated as a non-cited violation, consistent with Section VII.B.1
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of the NRC Enforcement Policy (50-454/455-96006-03). This item is
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closed.
M8.3
(Closed) LER 50-455/93-004:
Inadvertent Unit 2 train B safety injection
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during surveillance testing in Mode 5 due to mispositioned switch. This
event was cited as one of three examples in a violation for failure to
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follow procedures in inspection report 50-454/455-93012-02. The
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violation was subsequently closed in inspection report 50-454/455-95005.
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This item is closed.
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M8.4
(Closed) LER 50-455/93-006: Unit 2 source range nuclear instrument
channel N32 surveillance was missed. With Unit 2 in Mode 6, the source
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range channel N32 surveillance was not performed as required.
The
surveillance was September 22, 1993, and it was overdue on September 23,
1993. The missed surveillance was identified on September 24 and was
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immediately performed. The licensee identified the cause was improper
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status input to the computer data entry system. A partially completed
surveillance was performed on September 18 and was incorrectly updated
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as being complete. The safety consequence of this event was minor,
since both source range instruments were subsequently found to be
operable and no core alterations had been conducted after the
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surveillance critical time.
However, the licensee failed to perform the
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surveillance within the critical time period. The duration of the
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missed surveillance was approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The licensee implemented
a new surveillance status verification coversheet to clearly indicate
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the statur of any surveillance. The new coversheet required the
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surveillance coordinator to clarify why the surveillance was being given
a complete /done status and assisted the surveillance clerk in
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determining if the correct update status had been given to the
surveillance package. This improvement was completed January 14, 1994.
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The licensee's corrective actions were appropriate. This licensee
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identified and corrected violation is being treated as a non-cited
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violation, consistent with Section VII.B.1 of the NRC Enforcement Policy
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(50-454/455-96006-04). This item is closed.
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III.
Enaineerina
E2
Engineering Support of Facilities and Equipment
E2.1 Unit 2 Steam Generator Insoection
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a.
Insoection Scone
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The inspector reviewed the licensee's inspection plan for the Unit 2
steam generators tube leak indications.
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b.
Observations and Findinas
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The licensee identified that the leakage appeared to have been caused by
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foreign material inside the steam generator. The licensee discovered a
long, thin triangular piece of material, approximately 1% inches long
and 1/6 inch thick. The material and origin of the object was unknown
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at the end of the inspection period.
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The licensee's eddy current inspection of the Unit 2 steam generators
included:
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100 percent full length bobbin coil inspection in each steam
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generator.
a random selection of 25 percent of the steam generator tubes for
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top of tubesheet rotating pancake coil (RPC) inspection.
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25 percent of the row I and row 2 u-bend areas were inspected
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using a Plus Point probe.
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After the foreign object location was identified, both bobbin coil and
RPC inspections were performed on two rings of adjacent tubes to bound
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the indications.
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Eddy current analysts were given briefings to heighten awareness during
the remainder of the steam generator inspections. 'One additional item
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was identified and retrieved, a piece of wire approximately 6 inches
long.
Additionally, the licensee conducted a foreign object search and
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retrieval program. The fiber-optic camera identified a few small pieces
of flexitalic gasket material. The material was retrieved.
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Conclusion
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The inspector concluded the licensee's search for additional foreign
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objects was good.
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E8
Miscellaneous Engineering Issues
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E8.1
(Closed) LER 50-455/93-001: Wiring error in solid state protection
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system (SSPS) test circuitry. On February 22, 1993, with Unit 1 in Mode
6, the licensee identified a wiring error on the continuity test switch
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for phase B containment isolation in the Unit 1 SSPS cabinet IPA 10J.
The licensee identified that the wiring error was a manufacturing error.
The vendor manual indicated the incorrect wiring also.
The manufacturer
relayed the correct wiring information to the licensee and the vendor
manual was also updated. The licensee appropriately entered Technical Specification 4.0.3, 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> exemption clause for a missed surveillance,
and adequately corrected the wiring errors in Unit 1 train A and B, and
Unit 2 train A within the time limit. Unit 2 train B wiring was found
to be correct. The safety consequences were minor.
The wiring error
only affect J the test switch and did not affect the actual containment
phase B isolation capabilities. However, the wiring error did result in
previous missed surveillance to test the continuity of the containment
isolation circuit. The licensee's corrective actions were appropriate.
This licensee identified and corrected violation is being treated as a
non-cited violation, consistent with Section VII.B.1 of the NRC
Enforcement Policy. This item is closed.
IV.
Plant Sucoort
P1
Conduct of Emergency Preparedness (EP) Activities
Pl.1
Loss of Offsite Power Emeraency Plan Activation
a.
Inspection Scope (82701)
The inspector reviewed emergency plan activations which had occurred
since the last routine inspection (July 11,1994).
b.
Findinas and Observations
An unusual Event was declared at 8:22 a.m. on May 23, 1996 when the Unit
1 Station Auxiliary Transformers tripped causing a loss of offsite
power.
Unit I was in Mode 5 (cold shutdown), and Unit 2 was manually
tripped due to loss of service water and station air compressors. The
station activated the Technical Support Center, even though activation
was not required for an Unusual Event. The Unusual Event was terminated
at 2:30 p.m. the next day when offsite power sources were restored and
determined to be stable.
The station reviewed the event in accordance with procedure BZP 510-1,
" Review of Actual Emergency Events." Records reviewed indicated that
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the classification and notifications had been made properly and in a
timely manner. The documentation package for the event was highly
detailed, complete, and technically correct.
The inspector noted that
the procedure did not require the conduct of an event response critique
or contacts with responders to solicit comments. The procedure also did
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not require evaluation of Emergency Response Data System (ERDS)
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activation if the event was classified as an Alert or higher.
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c.
Conclusions
The inspector concluded the licensee had properly implemented the
Generating Stations Emergency Plan during the May 23, 1995 Unusual
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Event. The licensee's review of actions taken during the event was
detailed and technically correct.
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Pl.2 Emeraency Preoaredness Exercise (82301)
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a.
Insoection Scone
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On July 24, 1996, the inspector observed portions of the licensee's 1996
announced, off-hours emergency preparedness exercise. The inspector
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observed the licensee's performance at the control room simulator,
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technical support center (TSC), and operational support center (OSC).
b.
Observations and Findinas
The inspector observed the operators in the control room simulator.
Crew communications were clear and professional.
The operators were
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effective in mitigating the exercise scenario.
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The inspector observed the TSC during portions of the exercise.
The
licensee reported minimum staffing was achieved in approximately 35
minutes. The TSC was fully staffed in approximately I hour and 15
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minutes. The inspector observed good briefings, effective
communications with the control room simulator and timely off-site
notifications.
The TSC identified that the corporate emergency operations facility
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(corporate E0F) declared a General Emergency prematurely based on
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calculations of off-site radiation levels.
Field monitoring teams were
reporting off-site radiation levels consistent with a Site Emergency
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declaration (and consistent with the exercise scenario). The TSC was
working with the corporate E0F to resolve the declaration error when the
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scenario ended.
The inspector observed that the OSC was well supervised and coordinated.
4
]
The OSC director provided clear briefings and updates.
Teams dispatched
from the OSC were briefed prior to leaving the OSC. The inspector also
d
noted the priorities in the OSC were consistent with priorities in the
TSC.
c.
Conclusions
The inspector concluded that the licensee demonstrated that the on-site
emergency plans were adequate and that the licensee was capable of
implementing the plans. The inspector also concluded that the off-hours
manning was successful.
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P2
Status of EP Facilities, Equipment, and Resources
P2.1 Material Condition of EP Facilities
1
a.
Insoection Scone (82701)
1
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The inspectors toured the Technical Support Center (TSC), Control Room,
Operational Support Center (OSC), and Emergency Operations Facility
(E0F), and assc:ded their material condition. The two Environs Team
i
monitoring vans were also inspected, as well as field monitoring kits
a
utilized for field teams.
j
b.
Findinas and Observations
Each EP facility was well maintained and in an operational state of
readiness.
Equipment and supplies were well maintained. Current copies
of the Emergency Plan, Emergency Plan loplementing Procedures and
{
appropriate forms were present in each facility.
Environs Team vehicles
and kits were in excellent condition. Minor enhancements were noted in
!
various facilities.
A revised status board was present in the Operations Support Center.
.
This board was intended to display available personnel by discipline,
and was a part of the ongoing "0SC benchmark" standardization of OSC
,
operations.
'
Minimum Staffing sign-in status boards were effectively designed and
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positioned in the facilities. Equipment verified operable included
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phone lines (FTS 2000 and plant dedicated lines), UNIX computers
(MES0 REM for dose assessment, Significant Events Log), environs team
vehicle gasoline generator, and radiation survey meters. All equipment
4
inspected was operable.
,
Several inventory procedures included an excellent pre-inventory
checklist, which indicated which items were to be exchanged or inspected
,
during that calendar quarter. Documents reviewed indicated that
i
emergency equipment inventories and maintenance were excellent, with
timely corrective actions taken where deficiencies were identified.
c.
Conclusions
I
Overall, the inspector concluded that the emergency response facilities
were in excellent material condition with no problems or concerns
identified.
P3
EP Procedures and Documentation
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a.
Insoection Scope (82701)
The inspector reviewed selected licensee emergency procedures and
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emergenev plan implementing procedures (EPIPs).
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b.
Findinas and observations
'
The inspector reviewed procedure BZP-600-2," Initiating Staff
Augmentation." This procedure provides guidance for implementing BZP-
'
600-A1, the "prioritized Call Listing for Staff," which also serves as
the "E:nergency Call List".
Procedure BZP 500-6, " Emergency Preparedness Activities and
Surveillances," contained an adequate overview of program commitments
and activities.
I
Selected EPIPS in the 100, 200, 300, and 500 series were reviewed. The
majority of the EPIPS had been revised in 1995 or 1996.
No problems
were identified.
c.
Conclusions.
No problems were identified with any of the reviewed procedures.
P5
. Staff Training and Qualification in EP
,
a.
Insoection Scone (82701)
'
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The inspectors reviewed the licensee's EP training program. This
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included review of critiques, comparing training records against the
roster of emergency response organization (ERO) personnel, and
interviews with selected individuals.
,
b.
Findinas and Observations
Records indicated that drills and exercises were formally critiqued,
training had been provided formal critiques, and significant critique
items were appropriately selected for corrective action.
i
Printouts from the training tracking systems were compared with the
.
" Emergency Call List," with no problems identified. The training record
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database of response personnel was reviewed and found to be
comprehensive. The licensee's system was able to provide printouts of
those requiring training in order to maintain their qualifications.
The licensee indicated during discussions with the inspector that
attempts were made to train individuals in the same quarter as their
last training. Review of EP training records and documentation revealed
that excellent training was provided to emergency response personnel.
The inspector's discussion with the EP trainer indicated that all EP
lesson plans had been recently revised.
A sample of lesson plans was reviewed and discussed including: The NRC
,
Incident Response module; Module S-3, " Emergency Teams"; Module S-10,
" Communicator / recorder"; and Module S-5, " Assessment, Classifications &
'
Notification."
l
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Key emergency response personnel records reviewed indicated personnel
were currently trained and qualified.
The inspectors interviewed key emergency response personnel which
included a Station Director, Acting Station Director and a Control Room
Communicator. The personnel interviewed were very knowledgeable of
emergency procedures and their responsibilities.
The inspectors identified during the interviews that the emergency
procedure BZP 320-9, " Emergency Response Data System Operation," and-
BZP-310-5, " Acting Station Director or Station Director" did not include
the 10 CFR 50.72 requirement for activation of the Emergency Response
Data System (ERDS) within one hour of an Alert classification or higher.
(The procedure only indicated the requirement to activate at the Alert
or higher).
Discussion indicated that a number of training improvements have been
ude or were in progress, including the tracking of corporate reading
ckages.
There were combined Operating Simulator /TSC table top drills
sing one quarter of each year. Each training course had a separate
!
course code, making tracking more effective.
c.
Conclusions
The inspector concluded that the overall EP training was very good with
challenging drills and training sessions. Critique documentation was
very good and problem areas were highlighted for further training. The
training records were excellent and interviewed individuals were very
knowledgeable about their emergency responsibilities.
P6
EP Organization and Administration (82701)
The overall organization and management control of the EP function was
unchanged from the last inspection with the EP staff reporting to the
Station Manager through the Health Physics Supervisor and Technical
Support Superintendent. An individual was assigned as EP Trainer,
reporting to the training organization.
I
The EP Coordinator still retained responsibilities for Radiological
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Environmental Monitoring Program (REMP) and the Radiological
'
Environmental Technical Specifications (RETS) program. The Assistant EP
Coordinator position had been eliminated. Discussion indicated that
.
!
responsibilities for REMP and RETS would be shifted to another
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individual in the near future, and the total resources applied to the EP
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program would remain the same as in prior reports.
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P7
Quality Assurance in EP Activities
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P7.1 Audits (82701)
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a.
Jnsoection Scone (82701)
The inspector reviewed the following Site Quality Verification audits of
,
emergency preparedness; QAA 06-95-05, performed during April 1995, QAA
06-96-06, performed during April 1996, and the 1996 Peer Review
performed during May 1996.
>
b.
Findinas and Observations
,
.
Audit QAA-95-05 was performed by four individuals.
The audit concluded
that the EP program was effectively implemented.
The audit was complete
i
and well detailed.
l
Audit QAA-96-06 was performed by four individuals.
The audit verified
implementation of the requirements of the Emergency Plan and
-
implementing procedures. Two audit findings (level III) were associated
with the audit. The audit was complete, insightful and very well
l;
detailed.
l
In addition to the audits, a number of Field Monitoring Reports had been
performed during 1995 and 1996. These reviews largely confirmed
3
I
acceptable performance, but identified several items, including software
maintenance, procedure adequacy and procedural adherence.
'
The 1995 and 1996 audits of the EP program satisfied the scope
requirements of 10 CFR 50.54(t). Discussion with the licensee also
indicated that the EP staff fulfilled the requirement to make relevant
audit results available to State and county officials.
i
The 1996 Peer Review identified several issues to station management and
corrective actions were taken.
Peer Reviews have shown merit at this
and other stations.
y
c.
Conclusion
The licensee's 1995 audit of EP activities was good and satisfied the
requirements of 10 CFR 50.54(t). The Peer Review process was effective
in identifying various program problems.
,
P8
Miscellaneous EP Issues
P.8.1 (Closed) Inspection Follow-up Item (454/94016-01(DRS)):
Training on NRC
and other federal agencies' incident response programs. A reading package
providing details of the NRC response program was developed by the corporate
emergency planning group and distributed to various personnel. The Site
developed a training module "NRC Incident Response," which was undergoing
review and revision at the time of the inspection. Records indicated that
j
twenty-two individuals received this training during November,1994. The
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Byron and LaSalle training modules were reviewed and found acceptable with
minor modifications. Discussion indicated that a standardized NRC incident
response training module would be considered for Comed sites. This item is
closed.
P.8.2 (0 pen) Inspection Follow-up Item (454/455/95011-06(DRS)): Review of the
process for tracking and directing emergency inplant teams. The licensee has
developed an "0SC benchmark" program for standardizing activities at each
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sites' OSC.
Implementation of this program was underway but not comp 11ted.
An additional status board had been developed to track available personnel in
the OSC as a part of this program, but other aspects remain to be completed.
This item will remain open.
52 Status of Security Facilities and Equipment
a.
Inspection Scone (81700)
The inspector reviewed the condition of security equipment and
facilities.
b.
Observation and Findinas
Most security components required limited compensatory measures and had
a very high inservice time. One exception to this observation was
'
noted. One secur ity component has required compensatory measures since
mid January 1996 l exact component, nature of failure, and compensatory
,
measures are const.iered safeguards information and exempt from public
!
disclosure). During this inspection, the cause for the component
failure had rot oeen confirmed.
Because of the extensive time that this
component has required compensatory measures, return to service will be
monitored during the next inspection. This issue was considered an
i
inspection follow-up item (50-454/455/96006-05 (DRS)).
,
Some data trended and monitored on a monthly basis was of limited value
because of system improvements. An example included monitoring security
badges lost outside of the protected area.
Recently implemented hand
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geometry technology reduced the significance of lost security badges
since the badges were no longer required to be kept within the protected
area,
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Implementation of a new security computer system was scheduled to be
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initiated by the end of July 1996.
c.
Conclusions
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Security facilities were generally well maintained and security
equipment functioned as designed. With one exception, security
equipment attained a high inservice time.
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$3
Security and Safeguards Procedures and Documentation
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a.
Inspection Scone (81700)
The inspector reviewed selected security procedures pertaining to the
4
areas inspected and also reviewed appropriate logs, records and other
'
documents pertaining to the activities inspected.
b.
Observation and Findinas
An inspection followup item was noted by the inspectors pertaining to
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the need to revise the security plan and procedures because of pending
]
security related projects. For example, the revisions to the security
,
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plan and security department procedures will be required following the
activation of the new security computer at the end of July 1996, and
i
when redundant capabilities of the existing computer system are
eliminated later in the year. The security plan changes must be
forwarded to the NRC within two months after implementation of the
changes as required by 10 CFR 50.54(P).
,
Some procedures such as BAP 900-18, " Reporting and Recording of Security
.
Events," may require revision. Badges outside of the protected area no
!
longer required logging or reporting since security badges can be
removed from the protected area if hand geometry technology is used.
.
Other procedures may also have been affected because of the hand
'
geometry system use.
Finally, the most recent revision to the security
'
plan appeared unacceptable in some aspects and needed to be resubmitted.
1
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This issue was considered an inspection follow-up item (50-
454/455/96006-06 (DRS)).
An unresolved item was noted pertaining to " ascertaining of activities"
i
for licansee employees when a person was away from a behavior
observation program for extended periods.
Section B.3 of Regulatory
.
Guide 5.66 " Access Authorization Program For Nuclear Power Plants" dated
i
June 1991, (which the licensee had committed to for implementation of
l
the access authorization program required by 10 CFR 73.56), requires a
'
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person's activities under certain circumstances to be " ascertained" or
i
evaluated when they are absent from a behavior observation program for
extended periods. The existing licensee program did this for contractor
personnel who did not use their security badge for 30 or more days.
However, no similar prr., gram existed for licensee personnel. The
Regulatory Guide makes no distinction between contractor and licensee
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personnel for evaluation purposes when absent from a behavior
observation program. The licensee corporate security staff position was
that a licensee employee never leaves the umbrella of their behavior
i
observation program even when absent because the licensee knew the
reason for the absence. This issue applies to all six of the licensee's
'
sites and will be forwarded to NRR for evaluation.
Resolution of this
unresolved item will be addressed by separate correspondence (50-
454/455-96006-07 (DRS)).
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c.
Conclusions
The inspectors concluded that the procedures reviewed were of good
quality and correctly described the tasks to be performed.
One
exception was identified by the inspector, this pertained to behavior
observation for licensee employees. The inspectors also found that the
security personnel interviewed on post were familiar with procedure
requirements applicable to their responsibilities.
!
S4
Security and Safeguards Staff Knowledge and Performance
a.
Inspection Scone (81700)
i
The inspector toured various security posts and observed work in
progress.
Interviews with security officers were conducted to determine
i
if the officers were knowledgeable of post requirements.
b.
Observation and Findinas
,
The inspectors noted no performance deficiencies during visits to the
security posts.
Personnel interviewed and observed were aware of post
responsibilities and procedures. No adverse trends for security force
performance were noted. Only three performance related security
i
deficiencies within the past seven months, identified by the licensee,
have resulted in loggable security events.
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!
Security performance trends monitored on a monthly basis, such as
1
security plan deviations, compensatory measures, loggable security
events, and security component inservice time have generally been very
good and consistent.
,
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c.
Conclusions
'
No deficiencies were noted pertaining to staff knowledge and
performance.
S7
Quality Assurance in Security and Safeguards Activities
a.
Inspection Scope (81700)
,
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The inspector reviewed the most recent Site Quality Verification (SQV)
audit of the security program, the most recent corporate security audit
'
of the security program (referred to as "A" team), the most recent audit
,
,
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performed by the contractor security company, and self assessment
,
efforts conducted by the security department.
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b.
Observation and Findinas
The licensee's self assessment efforts continued to be varied and
"
proactive.
Since the beginning of 1996, the contract security company
had been audited by their corporate security office, SQV had completed
an annual audit of the security program, corporate security had
.
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completed an audit of the security program, and the contract security
company had completed five security related surveillances of security
practices. The audit and self assessment findings were being
effectively tracked and monitored by the security staff. The audit and
self assessment efforts were well documented. The self assessment
efforts were noted as a program strength.
,
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An aggressive program had been implemented pertaining to search
functions. Over 100 drills and exercises pertaining to searches have
been conducted within the past year. The drills were conducted by
licensee and contract security personnel. Results of the drills were
satisfactory.
In spite of the aggressive evaluation program, search
techniques was identified as a concern during the most recent SQV audit
of the security program. SQV has assigned a high level of significance
to their concern (Level III B) to assure corrective actions are reviewed
by the Plant Manager. The security staff also requested that a root
cause analysis be completed. Actions to address this concern appear
aggressive.
c.
Conclusions
The inspectors concluded that the security program self assessment
efforts were a program strength. Multiple audits of the security
program have been completed within the past year and surveillance
results were well documented, tracked, and monitored. Also, the
!
licensee implemented aggressive actions to address weaknesses identified
through the self assessment effort.
S8
Miscellaneous Security and Safeguards Issues
S8.1
(Closed) Unresolved Item 50-454/455/91004-01: Tnis item pertained to
weaknesses in the fitness-for-duty (FFD) program concerning the testing
for drugs and alcohol. The unresolved item had three ilements.
The
elements included (1) testing for alcohol only if a for-cause test for
alcohol was suspected; (2) allowing individuals that warrant for-cause
testing to be taken home and not tested if the Medical Review Officer
(MRO) cannot be contacted; and (3) requiring the Medical Department to
be contacted if a licensee employee was observed to be impaired or
displayed aberrant behavior and have the MR0 determine if FFD testing
was required. An interview with the licensee's FFD Program
Administrator showed that elements 1 and 2 above have been corrected in
the licensee's FFD procedures.
Element 3 continues to be the licensee's
policy.
Since two of the three elements have been corrected, this issue
will be closed. A new unresolved item will be established to review
again the issue of MR0 concurrence before for-cause testing was
conducted (50-454/455-96006-08 (DRS)). This item is closed.
S8.2 (0 pen) Inspection Followuo Item 50-454/455/95013-09: This item
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pertained to the security plan not accurately describing some
capabilities for three security components. In most of the cases, the
existing capabilities were improvements over former commitments in the
security plan. The security plan had been revised to correctly describe
,
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the capabilities for the security components. The plan revision had
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completed onsite review and at the end of the inspection period had been
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sent to corporate security headquarters for review and formal submittal
'
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to the NRC. This item will remain open pending receipt of the revision
,
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by the NRC.
1
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S8.3
(Closed) Inspection Followuo Item 50-454/455/95013-10: This item
pertained to the serviceability of the filters for gas masks and the
1
availability of eye glass inserts for gas masks for personnel issued gas
!
masks as part of their response equipment. New gas masks have been
i
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acquired and the new masks do not require eye glass inserts.
Standard
i
type eye glasses can be worn with the new masks. The shelf life of the
j
gas mask filters was being monitored. This item is closed.
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S8.4
(Closed) Inspection Followuo Item 50-454/455/95007-08: This item
i
pertained to four procedure weaknesses. Two of the four needed changes
j
were corrected and closed during the previous inspection. The remaining
!
two items pertaining to submittal of fingerprint cards and certification
4
of physical examinations have been corrected and was to be addressed by
separate correspondence. This item is closed.
S8.5 (Closed) Security Event Report (SER) No. 96-S02-00:
This item was
1
submitted on June 14, 1996, and pertained to required compensatory
measures not being implemented during an adverse weather contingency.
During review of this issue, the inspector noted that guidance documents
!
pertaining to compensatory measures were very fragmented, in general.
1
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Guidance for compensatory measures existed in four different documents
j
(security plan, BSP procedure 400.1, CNSG procedure 4 and the post order
for the security shift supervisor). No single procedure contained the
compensatory measures for all of the contingencies that could require
such measures. The licensee satisfactorily implemented the corrective
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a
actions identified in the SER. This licensee identified and corrected
j
violation is being treated as a non-cited violation, consistent with
Section VII.B.1 of the NRC Enforcement Policy (50-454/455-96006-09
(DRS)).
This item is closed.
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V.
Manaaement Meetinas
X1
Exit Meeting Summary
,
On August 20, 1996, the inspectors presented the inspection results to
licensee management. The licensee acknowledged the findings presented.
i
The inspectors asked the licensee whether any materials examined during
.
,
the inspection should be considered proprietary. No proprietary
!
information was identified.
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PARTIAL LIST OF PERSONS CONTACTED
K. Graesser, Site Vice President
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K. Kofron, Station Manager
D. Wozniak, Site Engineering Manager
,
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T. Gierich, Operations Manager
P. Johnson, Technical Service Superintendent
E. Campbell, Maintenance Superintendent
M. Snow, Work Control Superintendent
D. Brindle, Regulatory Assurance Supervisor
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T. Schuster, Site Quality Verification Director
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INSPECTION PROCEDURES USED
.
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IP 37551:
Onsite Engineering
!
IP 62703:
Maintenance Observations
IP 61726:
Surveillance Observations
IP 71707:
Plant Operations
4
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IP 71750:
Plant Support Activities
IP 81700:
Physical Security Program for Power Reactors
IP 82301:
Evaluation of Exercises for Power Reactors
,
IP 82701:
Operational Status of the EP Program
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ITEMS OPENED, CLOSED, AND DISCUSSED
Ooened
50-454/455/96006-01
Inadequate corrective action concerning water
tight doors.
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50-454/455/96006-02
One train of containment purge isolation system
inoperable during core alteration.
i
50-454/455/96006-03
Failed to perform an essential service water
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availability surveillance.
~
50-454/455/96006-04
Failed to perform a surveillance on one train of
source range instrument.
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50-454/455/96006-05
IFI
Security component required compensatory
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measures for several months.
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50-454/455/96006-06
IFI
Need for security plan revision.
50-454/455/96006-07
Ascertaining of activities for personnel not
under a behavior observation program.
50-454/455/96006-08
Medical services personnel involvement needed
before fitness-for-duty for cause testing is
completed.
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50-454/455/96006-09
Missed security compensatory action during
adverse weather.
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50-454/455/96006-10
Work controls for auxiliary feedwater
surveillances.
Closed
50-454/93-002
LER
One train of containment purge isolation system
inoperable during core alteration.
50-455/93-002
LER
Failed to perform an essential service water
availability surveillance.
50-455/93-004
LER
Inadvertent Unit 2 train B safety injection
during surveillance testing in Mode 5.
50-455/93-006
LER
Failed to perform a surveillance on one train of
source range instrument.
50-454/96-S02-00
Missed security compensatory action during
adverse weather.
50-454/455/91004-01
Fitness-For-Duty procedure weaknesses.
50-454/455/95007-08
IFI
Four weaknesses noted with security related
procedures.
50-454/455/95013-10
IFI
Serviceability of gas mask filters and
availability of eye glass inserts.
454/94016-01
IFI
Emergency preparedness training on NRC Incident
response program.
50-454/455/96006-02
One train of containment purge isolation system
inoperable during core alteration.
50-454/455/96006-03
Failed to perform an essential service water
availability surveillance.
50-454/455/96006-04
Failed to perform a surveillance on one train of
source range instrument.
50-454/455/96006-09
NCY
Missed security compensatory action during
adverse weather.
Qiscussed
50-454/455/95013-09
IFI
Security plan not accurately describing some
security component capabilities.
454/455/95011-06
IFI
Review of process for tracking / directing
emergency inplant teams.
4
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LIST OF ACRONYMS
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BAP
Byron Administrative Procedure
BCP
Byron Chemistry Procedure
B0A
Byron Abnormal Operating Procedure
B0P
Byron Operating Procedure
BOS
Byron Operating Surveillance
Component Cooling
CFR
Code of Federal Regulations
Emergency Plan Implementing Procedure
Emergency Response Data System
Emergency Response Organization
Engineered Safeguard Feature
GPD
Gallons per Day
IM
Instrument Mechanic
LC0
Limiting Condition for Operation
Medical Review Officer
NSO
Nuclear Station Operator
Operational Support Center
Problem Identification Form
Power Operated Relief Valve
Parts per million
Radiation Protection
RP&C
Radiation Protection and Chemistry
SAC
Station Air Compressor
Station Auxiliary Transformer
SQV
Site Quality Verification
SR0
Senior Reactor Operator
SSPS
Solid State Protection System
Essential Service Water
TS
Technical Specification
Updated Final Safety Analysis Report
VQ
Containment Purge Isolation System
WS
24
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