ML20137K885
| ML20137K885 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 03/31/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20137J710 | List: |
| References | |
| 50-454-96-13, 50-455-96-13, NUDOCS 9704070118 | |
| Download: ML20137K885 (7) | |
See also: IR 05000454/1996013
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' U. S. NUCLEAR REGULATORY COMMISSION
REGION lil
Docket Nos.:
50-454; 50-455
License Nos.:
. Report No.:
50-454/96013(DRS); 50-455/96013(DRS)
Licensee:
Commonwealth Edison Company
Facility;
Byron Nuclear Generating Station, Units 1 & 2
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Location:
4448 North German Church Road
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Byron, Illinois 61010-9750
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Dates:
December 16-17,23, January 9,29 30,
February 4-5,20 and March 10,1997
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Inspectors:
J. H. Neisler, Reacter inspector
D. Schrum, Reactor inspector (January 29-30, 1997)
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Approved by:
R. N. Gardner, Chief
Engineering Specialists Branch 2
Division of Reactor Safety
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9704070118 970331
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ADOCK 05000454
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Report Details
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IV. Plant Suncort
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F1
Control of Fire Protection Activities
F1.1
General Comments
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Using inspection Procedure 40500, the inspector evaluated the effectiveness of the
iicensee's controls in identifying and correcting deficiencies in the plant's fire
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protection system. The evaluation included over 260 Problem Identification Forms
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(PlFs) associated with the Byron fire prctection system that had been initiated
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during 1995 and the first 11 months of 1996. The number of PlFs issued during
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this period was an indication of the plant staff's diligence in identifying deficiencies.
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The inspectors considered this a strength. However, the inspectors noted several
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instances where inadequate or lack of corrective actions resulted in repetitive PlFs
on the same type of issues.
F1.2 Confiauration Control
a.
Insoection Scooe (40500)
The inspectors reviewed PIFs relative to configuration control deficiencies that had
been documented during the past 22 months, in addition, the inspector
interviewed cognizant licensoo personnel.
b.
Observations and Findinas
During the review of fire protection PIFs, the inspectors noted that two PlFs had
identified mispositioned valves in the fire protection system.
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PlF 454-201-96-1973, November 23,1996: During performance of the monthly
fire protection valve line up, two valves, OFP248 and OFP033, were identified as
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not being in their required position. The valves had been closed in support of
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another surveillance that had been suspended for lack of manpower. The valves
had not been restored to their proper position when the original surveillance was
suspended. It was not known how long the valves had been in the incorrect
configuration.
PlF 454-201-96-1990. November 26,1Jjl: An operator found two fire protection
valvos that were not in their required position. It was subsequently determined that
the valves were part of a semi-annual surveillance that was suspended with the
valves lef t in the as-left surveillance position.
The inspectors' reviews of fire protection system drawings and discussions with
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the Byron Fire Marshal determined that no portion of the fire protection system was
inoperable as a result of mispositioned valves. The mispositioned valves and loss of
configuration appeared to be the result of the licensee's practice of suspending an
in-process surveillance procedure due to other priorities or lack of manpower while
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leaving the system in the as-left surveillance configuration, then beginning another
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surveillance before completing the original. The persons performing the second
surveillance then originated a PlF identifying the loss of system configuration.
Licensee persnnnel stated that this practice did not occur during safety-related
surveillances.
c.
Conclusions
The inspectors concluded that none of the above examples resulted in loss of
system operability. However, the licensee's established practice of allowing fire
protection valves to remain in the as-left surveillance position for indefinite periods
indicated a weakness in management's control of fire protection surveillances.
F1.3 Reactor Coolant Pumo (RCP) Oil Collection System
a.
Inspection Scone
The inspectors reviewed PlFs, operability assessments, fire analysis report, system
drawings, and interviewed licensee person' riel relative to the Byron Reactor Coolant
Pump Oil Collection System,
b.
Observations and Findinas
PiF 454 200-96-0032, dated June 24,1996, identified that all potential oil leaks on
the reactor coolant pumps did not have drip pans to collect and route the oil to a
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safe collection point as required by 10 CFR 50, Appendix R.
The inspectors reviewed Byron Operability Assessment 96-025, dated June 25,
1996, and Byron RCP Oil Collection System Fire Protection Evaluation, dated
June 24,1996. The licensee's evaluation states, " Contrary to Byron's Fire
Protection, Sections 3.7.G and AS.7.lli.0, all potential oil leakage points are not
provided with pans to collect drips and seepage. Specifically, there are two bolted
flanges and two drain plugs associated with the oil cooler on each RCP that were
not initially provided with drip pans." The licensee's evaluation also states,
" Appendix R to Part 50 of Title 10 of the Code of Federal Regulations requires the
installation of an oil collection system to collect oil front all potential pressurized
and unpressurized leakage sites." However, the licensee determined it was
acceptable to operate with this condition.
10 CFR 50, Appendix R, Section lil, O, requires that RCP lube oil collecting systems
shall be capable of collecting luba oil from all potential pressurized and
unpressurized leakage sites in the RCP lube oil systems.
NUREG-0876, Safety Evaluation Report, Supplerr at No. 5, pages 9-17, closed an
NRC unresolved issue identified in the Safety Evaluation Report regarding the
provision of an oil collection system for the RCPs. This was based on the
licensee's commitments in the fire protection report and letter dated August 20,
1984, to install an oil collection system capable of collecting oil from all potential
pressurized and unpressurized leakage sites.
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The Byron Fire Protection Report, pages 3.7-3 and A5.7-35,36, stated that the
RCP lube oilleakage collection system complied with NRC and Appendix R
requirements. PlF 454 200-96-0032 identified that the licensee was not in full
compliance.
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As corrective action to PlF 454-200-96-0032, the licensee installed additional drip
pans under the bolted flanges and drain plugs and lengthened one drain pan. Work
had been completed on both units.
.c.
Conclusions
The licensee identified this issue and took appropriate corrective action. An
Operability Assessment was completed on July 25,1996, that documented
continued operability of both units. However, the licensee was not in compliance
with 10 CFR 50, Appendix R, Section O requirements since plant construction in
addition, the licensee failed to notify the NRC, pursuant to 10 CFR 50.73, that this
condition was outside the Byron design basis. The licensee stated that the RCP oil
collection system was not outside the Byron design basis and therefore was not
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reportable. This issue is unresolved (50-454/455/96013-01(DRS)) pending review
of the licensce's requested response to this issue.
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F1.4 OC HoM Points
a.
Insoection Scope
The inspectors reviewed PlFs relating to work performed on the fire protection
system to ascertain whether quality controls were effective,
b.
Observations and Findinas
The inspectors reviewed six PlFs detailing missed quality control (OC) hold points.
Hold points are steps within a work procedure or work order past which the activity
cannot proceed until that step has been performed. The missed hold points were
mostly OC cleanliness inspections on components prior to maintenance closing the
component after work had been completed. The licensee's corrective action and
closure of each of the missed hold points appeared to be appropriate.
The licensee had developed a program to reduce or eliminate missed OC hold points
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during maintenance activities. The program tracks missed hold points and initiates
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appropriate corrective action,
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c.
Conclusions
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The inspectors concluded that the licensee had appropriately addressed the missed
QC hold points and that the program to eliminate or reduce the missed hold points
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reviewed during this inspection should be effective.
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F1.5 Recetitive Deficiencies identified by PIF
a.
Insoection Scoce
The inspectors reviewed PIFs that were repetitive in that they identified the same
type of deficiencies. The inspectors discussed these repetitive PlFs with licensee
representatives.
b.
Observations and Findinas
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The inspectors noted instances where action to correct a fire protection deficiency
identified by a PIF had not been effective in preventing the recurrence of the same
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type deficiency. Each deficiency identified was corrected without fully establishing
the reason for the deficient condition or providing effective measures to prevent
recurrence. All the repetitive deficiencies appeared to result from personnel errors
and inattention to detail.
c.
Conclusions
The licensee identified and promptly corrected each deficiency described in the
PlFs. However, the repetitive occurrences indicate a need for improvement in the
licensee's root cause determination and corrective action processes.
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F1.6 Freezina Pioes
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a.
Insnection Scone
The inspectors reviewed PlFs documenting frozen fire protection pipes and
discussed freeze protection for plant components with cognizant licensee
personnel.
b.
Observations and Findinas
During the review of PlFs documenting fire protection issues, the inspectors noted
four instances in the winter of 1995/1996 when fire protection system piping had
frozen as a result of open exterior doors or louvers which cxposed the pipes to
subfreezing outside temperatures. Two of the frozen pipe occurrences were due to
mechanical prcblems with closure equipment on the exterior openings. However,
the licensee did not apply compensatory measures to prevent pipe freezing. In
response to the inspectors' queries, licensee representatives stated that there were
no procedures or directives controlling the length of time an exterior opening could
remain open during cold weather.
On January 17,1997, an equipment attendant found the north entrance door to the
circulating water pump house propped open which resulted in all the fire protection
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instruments on panel OPL 52J freezing. In addition, this resulted in the loss of main
control board indication for the fire protection header pressure. Finally, it resulted
in fire pump OA and the jockey pump being inoperable. Corrective action, as stated
by the operations manager, was to fire the contractor worker who propped the door
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10 CFR 50, Appendix B, Criterion XVI, requires that in the case of significant
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conditions adverse to quality, measures shall be estab!ished to assure the cause of
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the conditions is determined and corrective action taken to preclude repetition.
c.
Conclusions
Licensee management was not effective in preventing repetitive freezing and loss of
equipment during cold weather. Failure to provide effective corrective action
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continued to result in frozen, inoperable fire protection cquipment. This is a
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violation of 10 CFR Part 50, Appendix B, Criterion XVI (50-454/455/96013-
02(DRS)).
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V. Manaaement Meetinas
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XI Exit Meeting Summary
The inspectors met with licensee representatives on January 9,30, February 20 and by
telephone March 10,1997, to discuss the scope and findings of the inspe'ction. During
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the exit meetings, the inspectors discussed the documents and processes reviewed by the
inspectors during the conduct of this inspection and the likely informational content of the -
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inspection report. The licensee representatives did not identify any such documents on
process as proprietary.
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PARTIAL LIST OF PERSONS CONTACTED
Licensee
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R. Colglazer, NRC Coordinator, Regulatory Assurance
J. Feinster, Lead System Engineer
T. Gierich, Operations Manager
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K. Kofron, Site Manager
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R. Linboom, Senior Inspector, SOV
F. Pollak, Fire Protection System Engineer.
D. Popkins, Administrator, Operations Engineering
D. Robinson, Project Engineer
R. Scheidecker, Fire Marsha!
M. Snow, Work Control Superintendent .
D. Wozniak, Site Engineering Manager
US NRC
' S. Burgess, Senior Resident inspector
N. Hilton, Resident inspector
LIST OF DOCUMENTS REVIFWED
OBVS 7.10.1.1.G 1, October 31,1995, Revision 6, Unit 0, Fire Suppression Water
Systems Fire Hydrant Flow Test
BAP 1100-1, February 14,1992, Revision 9, Fire Protection Program
OBOS 7.10.1.1.e-1, July 1,1996, Revision 10, Fire Protection Testable Valve Yearly
Cycte Surveillance
BAP 300-1, January 10,1995, Revision 3, Conduct of Operations
BAP 330-2. July 31,1996, Revision 13, Temporary Alterations
BAP 3301, September 26,1996, Revision 25, Station Equipment Out-of-Service
Procedure
OBVS 7.10.1.1.a-3, November 29,1995, Revision 3, Fire Protection Pumpf, Flow and
Pressure Test
LIST OF ACRONYMS
Site Ouality Verification
Fire Protection, Fire Pump
PlF
Problem identification Form
Corrective Action Request
EA.
Equipment Attendant
LCOAR
Limiting Condition for Operation Action Request
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Components Shared Between Unit
Reactor Coolant Pump
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