ML20140B803

Insp Repts 50-454/97-05 & 50-455/97-05 on 970314-0501. Violations Noted.Major Areas Inspected:Licensee Operations, Engineering,Maint,Plant Support & 1997 Emergency Preparedness Exercise & Safeguards Info Also Considered

ML20140B803
Person / Time
Site:	Byron
Issue date:	05/28/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20140B786	List: ML20140B779 ML20140B798 ML20140B803
References
50-454-97-05, 50-454-97-5, 50-455-97-05, 50-455-97-5, NUDOCS 9706060329
Download: ML20140B803 (20)

See also: IR 05000454/1997005

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U. S.' NUCLEAR REGULATORY COMMISSION )

REGION 111 I

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Docket Nos: 50-454, 50-455 i

License Nos: NPF-37, NPF-66

Report No: 50-454/97005(DRP); 455/97005(DRP)

Licensee: Commonwealth Edison Company

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Facility: Byron Generating Station, Units 1 & 2

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Location: 4450 N. German Church Road

Byron, IL 61010

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Dates: March 14 through May 1,1997

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Inspectors: S. D. Burgess, Senior Resident inspector i

N. D. Hilton, Resident inspector

T. M. Tongue, Project Engineer  ;

G. L. Pirtle, Security Specialist I

C. K. Thompson, Illinois Department of Nuclear Safety )

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Approved by: Roger D. Lanksbury, Chief, '

Reactor Projects, Branch 3

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9706060329 970528

PDR ADOCK 05000454

G PDR a

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EXECUTIVE SUMMARY

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Byron Generating Station, Units 1 & 2 '

j NRC Inspection Report 50-454/97005, 50-455/97005

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- This inspection included aspects of licensee operations, engineering,' maintenance, and

plant support. The report covers a 7-week period of resident inspection.

! Operations

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On March 14,1997, Unit 2 was shutdown. The inspectors concluded that  :

! excellent operator performance was demonstrated during the shutdown activities  !

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The Unit 2 startup and main generator synchronization to the grid was completed in ,

j a well controlled manner. The inspector noted judicious troubleshooting, l

evaluation, and repair of the main generator output circuit breaker control switches

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The licensee's handling of the containment leak detection system was considered

poor as exemplified by failure to control foreign material intrusion into the drain

system and failure to take thorough aggressive followup action on indications that

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the system was not functioning properly. The early leak detection of a small

reactor coolant leak in containment was significantly compromised. The only

seismically qualified leak detection system at Byron was inoperable. This condition

went unidentified by the licenses for over 5 months. Additionally, appropriate drain -

grates as described in the Updated Final Safety Analysis Report (UFSAR) had not  !

been installed since plant construction. Three apparent violations were identified i

(Section 02.2).

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The inspectors considered the questioning attitude of the operations staff regarding

the performance of a special test to be judicious and a strength. As a result the

procedure was enhanced with contingencies for roll-up door failure and weather

(Section 02.3).

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The licensee event report (LER) 50-455/97001, Unit 2 Containment Drain System

Clogged Due to Debris, was poor and marginally acceptable due to incomplete,

inaccurate, and late information. One apparent violation was identified regarding

the inaccurate information in the LER. (Section 08.1).

Maintenance

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Routine maintenance and surveillance activities were well performed

(Sections M1.1 and M1.2).

- The licensee and ths' inspectors noted that silt accumulation in the ultimate heat

sink was faster than had been previously observed (Section M1.2).

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The inspectors considered the suspension of a special test involving the auxiliary

building ventilation appropriate so as to not exceed technical specification (TS)

limitations (Section M1.2).

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The inspectors questioned the adequacy of the licensee's design control process

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i , without a detailed review. This issue was considered an unresolved item pending

further NRC review of the technical adequacy of the temporary alteration program

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The inspectors identified a non-functioning control room recorder that had been

inoperable since 1994. Although the recorder was not safety-related, the

.' recordings were described in the UFSAR. The inspector's review o* the licensee's

j UFSAR discrepancy identification program determined that the lia:nve would likely

, have identified the discrepancy (Section E2.2).

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LER 50-454/95006 documented a missed technical specification surveillance during

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steam generator (SG) tube inspection in 1995. The licensee identified and

1 corrected violation is considered a non-cited violation (Section E8.3).

Plant Sunoort

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The inspectors considered the 1997 emergency preparedness exercise to be good

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Review of an unresolved item identified a violation for the licensee's failure to mark l

and protect a memorandum that contained Safeguards information pertaining to the ,

l vehicular barrier system (Section S8,1).

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REPORT DETAILS

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Summarv of Plant Status

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l Unit 1 operated at power levels up to 97 percent during this inspection period.

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Unit 2 was shutdown on March 14,1997, to investigate and repair a small secondary 3

! steam leak on a 2A steam generator hand hole. The unit was restarted on March 19,  !

! 1997, and operated at power levels up to 100 percent throughout the rest of the j

, inspection period. '

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l 1. Operations i

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l. 01 Conduct of Operations

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01.1 General Comments (71707)

Using Inspection Procedure 71707, the ' inspectors conducted frequent reviews of

ongoing plant operations. In general, the conduct of operations was professional

and safety-conscious. Observations indicated that the operations staff was

knowledgeable of plant conditions, responded promptly and appropriately to alarms,  !

and performad thorough turnovers. Specific events and noteworthy observations

are detailed in the sections below.-

01.2 Unit 2 Shutdown Activities (71707)

On March 14,1997, the inspectors observed significant portions of the Unit 2

shutdown. The inspectors observed procedure adherence and noted that operators

were cognizant of system configuration apdpoglighle precautions. The operators

controlled equipme%;erats.iy4nd %Iiiciently. Operator communication and

annunciator resysrse was very good throughout the activities observed. The senior

reactor operator (SRO) exhibited strong command and control. The reactor was  !

tripped from low power to demonstrate control rod drop characteristics with no 'i

abnormalities idesntified. The inspectors concluded that the shutdown demonstrated

excellent operator oerformance.

01.3 Unit 2 Startuo Observations (71707) )

a. Inspection Scone  !

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The inspectors oliserved significant portions of the Unit 2 startup on March 19, l

1997. Observations included "Just-in-Time" train!ng, briefings for reactor startup i

and synchronizing the' generator to the grid, rod withdrawals and approach to

criticality, synchrcnizing the main generator to the grid, and increasing power

output.

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l b. Observations and Findinas

The inspectors observed the heightened level of awareness (HLA) briefings and

considered them thorough and timely with emphasis on safety, communications,

and minimizing operator distractions. One potential problem discussed and

reviewed was that source range neutron detection instrument N32 was

" experiencing small spikes. Contingencies were discussed if the spiking worsened,

including tripping the reactor if necessary. The inspector confirmed that only

necessary personnel were allowed access to the operating area of the control

panels and also observed use of alarm responsa procedures for unexpected alarms.

i Good command and control was observed, including three-way communications

and explicit chain-of-command as described in the HLAs.

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Several attempts were made to synchronize the main generator to the grid over a

period of about three shifts (see Section M1.1 for details). Operations staff

evaluated the situation, with assistance from representatives in the Operational

Analysis Department (OAD). The inspectors noted careful troubleshooting,

evaluation, and analysis. This process was well monitored and controlled by station

operations personnel. The main generator output circuit breaker control switches

were replaced, tested, and the main generator was synchronized to the grid.

c. Conclusions

The inspectors concluded the reactor startup and main generator synchronization to

the grid was completed in a well contro!!ed manner. The inspector noted judicious

troubleshooting, evaluation, and repair of the main generator output circuit breaker

control switches.

02 Operational Status of 9acilities and Equipment

O2.1 Unit 2 Containment Insoection Prior To Startuo (71707)

The inspectors conducted an independent close out inspection of the Unit 2

containment following the licensee's closeout inspections in preparation for the

reactor coolant system (RCS) heatup.

The containment appeared clean with an absence of boron crystals due to leaks.

The inspectors also noted three drains in the outer circumferential drain trench with

the strainers missing, damaged, or out of place as discussed further in

Section 02.2. The inspectors concluded that the Unit 2 containment appeared

clean and the general material condition of equipment observed appeared good.

02.2 Inocerable Unit 2 Containment Floor Drain System (71707)

a. Insoection Scoce

The inspectors reviewed the plugging of the Unit 2 containment floor drain (RF)

system. The inspectors discussed the event with engineers and operators. The

inspectors also reviewed the applicable sections of the UFSAR, Regulatory

Guide 1.45, technical specifications (TS), and the licensee event report (LER).

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.' b. Observations and Findinas

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- Pluaaed Containment Floor Drain Svstem

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!' On March 15,1997, while Unit 2 was shutdown for a maintenance outage, the

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licensee identified standing water in the containment building floor trench. The

containment floor drains merged and then entered a flow control box. After the

flow control box, water passed through the oil separator, the weir box, and finally

i . entered the sump. Water accumulated in the sump could be removed via sump

pumps. After troubleshooting the floor drain system, the licensee identified that the

i flow control box was clogged. A water hose was used to flush and clear the

j' blockage on March 17,1997.

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j, Flow detection instrumentation (2RFOO8) for the containment floor drain leak

l detection system was provided in the weir box. The licensee's investigation

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identified that with the flow control box plugged, water was prevented from.

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reaching the weir box. Sump pump run times indicated that the maximum capacity

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of the floor drain system had been approximately 0.1 gallons per minute (gpm).

Due to a known small secondary steam leak, the licensee was aware of input into

the floor drains. However, prior to the Unit 2 shutdown to repair the leak,

inspectors questioned inconsistencies between sump run times, actual chart

recorder indicated values, and annunciator alarm setpoints. The inconsistencies

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were not large and mostly resolved by calibrations. The licensee also inspected the

. weir box screen during the maintenance outage. Foreign material was discovered,

including a plastic foreign material exclusion (FME) pipe cap, a metal rod

approximately % inch diameter and G inches long, a large piece of tape, and several

large diameter (about 1 inch) pieces of scale or rust, which may or may not have

originated in the floor drain system.

- The licensee identified, and the inspectors agreed, that the flow control box was

most likely plugged during the previous Unit 2 outage, which ended October 4,

1996. Technical Specification 3/4.4.6, Reactor Coolant System Leakage Detection

Systems, action paragraph b. required the containment floor drain to be restored to

operable within 7 days or be in hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> if the

containment floor drain was inoperable. The inspectors concluded that the

containment floor drain system was inoperable from October 4,1996 to March 14,

1997, approximately.161 days, and therefore was an apparent violation of

TS 3/4.4.6 (eel 50-455/97005-01(DRP)).

The plugged drains were identified by the licensee. However, prior opportunity to

identify this condition appeared to exist. Historically, when the RCFCs were

shifted, condensation on the heat exchangers was removed via the containment

floor drains. Typically a " spike" of about 2 gpm was observed on main control

room chart recordings for 2RF008. The indicated leakage spike then trended back

to nominally zero during the next 15 minutes. This curve was observed on Unit 2

prior to the previous outage and after the flow control box was cleaned. However,

during the period from October 4,1996, until March 14,1997, the characteristic

curve was not observed.

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The inspectors noted that the chart recorder for 2RF008 was on a back panel and

that there 'was no procedural requirement to observe the RCFC response on the

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chart. The inspectors also noted that when an annunciator alarm for containment

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[ leakage (comes in at 1 gpm) was received, operators in the past responded to the

i alarm and verified the RCFC characteristic trace. Frequently during the period in

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question, the containment leakage alarm was locked in and as a result the licensee

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- was performing Byron Operations Surveillance (BOS) RF-1,'" Containment Floor I

Drain Monitoring System Non Routine Surveillance," Revision 0, which required I

! logging the actual strip chart indication every 30 minutes. Therefore, the inspectors  !

i concluded that operators had an opportunity to identify that after a shift of RCFCs '

the characteristic trace did not occur. The inspectors considered this a failure to

, identify a significant condition adverse to quality and an apparent violation of l

! 10 CFR Part 50, Appendix'B, Criterion XVI, " Corrective Action" '

i (eel 50-455/97005-02(DRP)).

Discreoant Floor Drain Grates

Byron UFSAR Section 5.2.5.1 discussed the RF system. Both inspectors and

licensee personnel noted that floor drain grates were not installed per design.

UFSAR Figure 5.2-3 indicated a particular vendor's bar grate; however, in many

cases either a different type grate or screen (usually carbon steel) was installed or

nothing covered the drain. The vendor's grates were approximately 5 inches in

diameter and the perimeter trench was approximately 4 inches wide. A semi-circle

shape should have been created in the concrete during construction for a proper fit,

but was not, which indicated the floor grate deficiency had existed since

construction. The licensee performed Operability Assessment 97-027, and

determined that the floor gratings were not required for operability of the RF

system. The inspectors agreed with the assessment; however, the inspectors

noted that while the grates may not be required for operability of the system, the  ;

lack of the grates was significant in that this was a contributing cause to the floor

drains being plugged. The inspectors considered the failure to perform a safety .{

evaluation for the various type of grates installed in lieu of the type specified in the

UFSAR prior to March 14,1997, an apparent violation of 10 CFR 50.59

(eel 50-455/97005-03(DRP)).

The inspector's review of operator loge determined that the containment gaseous

and particulate activity monitoring system was operable except for short periods of

filter changes and preventative maittenance (typically 30 to 40 minutes) during the

period that 2RF008 was inoperable. Therefore, although the licensee unknowingly

entered TS 3.0.3 daily (for filter changes) due to allleak detection systems being

inoperable, the time periods never exceeded TS 3.0.3 action requirements.

Corrective actions for the plugged containment floor drains discussed by the

licensee included clean out of the flow control box, drain cleaning, and increased

flow control box inspections. Installation of new grates was also planned. After

trending the performance of the new grates, the increased flow control box

inspections and cleaning may be reduced.'

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c. Conclusions

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The licensees handling of this issue was considered poor as exemplified by failure

to control foreign material intrusion into the drain system and failure to recognize  !

a indications that the system was not functioning properly. The inspectors concluded

that early leak detection of a smal.' faak was significantly compromised. The only

seismically qualified leak detection system at Byron was inoperable for over

5 months and went unidentified by the licensee during that time. Additionally,

appropriate drain grates as described in the UFSAR had not existed since ,

construction. The UFSAR provided apparently contradicting information regarding I

the leak detection systems seismic qualifications.

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02.3 Re-Evaluation of Soecial Test I

The inspectors noted that special test SPP 97-010, "ECCS Equipment Room

Negative Pressure Test," was delayed due to the questioning attitude of the

operations staff. The test was used to determine if the access planned to be cut in

Unit 1 containment for the replacement steam generators created a ventilation

problem in the auxiliary building, particularly in the emergency core cooling system

- (ECCS) component rooms. The licensee used the roll-up doors in the fuel handling

building to simulate the containment opening.

In discussing the test prior to performance, a unit supervisor stated that failure to

meet test requirements would require both units to shut down per TS 3.0.3

regul.s 7nts because all three charcoal booster fan subsystems of the auxiliary

buildin;; antilation system would be inoperable. Further discussion resulted in the

test delay to revise the test procedure to better discuss operator actions for test '

failure and contingency actions for roll-up door failure and outside weather

conditions. The inspectors considered the questioning attitude of the operations

staff to be judicious and a strength.

08 Miscellaneous Operations issues (92700 and 92901) l

08.1 (Closed) LER 50-455/97001: Unit 2 containment drain system clogged due to  !

debris. The circumstances surrounding the clogged containment floor drain are  !

documented in Section 02.2. The inspector reviewed the LER and noted two I

apparent violations and several weaknesses. The findings included: i

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The LER did not declare the containment floor drain system inoperable.  !

However, the LER did identify the flow control device was inoperable (clogged).  ;

The safety analysis section discussed the consequences of not having the

system operable.  !

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The LER was issued for Unit 2 being outside the design basis. With the floor

drains inoperable since October,1996, the licensee was also apparently in

violation of TS 3/4.4.6, which was reportable under 10 CFR 50.73(a)(2)(i). The

LER did not identify the TS violation. ,

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The LER indicated that it could not be determined when the flow control device

became clogged. However, the system engineer reported to the inspectors that

RCFC condensation could not be identified on the control room recorder for

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2RFOO8 since the startup after the Unit 2 outage, which ended October 4, l

l_- ~ 1996. The condensation trace was present prior to the outage; therefore, the J

} inspectors concluded the system was inoperable since the Unit 2 startup on

j- October 4,1996.

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-- An operability assessment was prepared to allow startup of Unit 2 without fixing

the floor grates. The LER stated that " debris could potentially impact the

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containment sump RCS leakage weir box.. However, any impact on the weir

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function would be in the conservative direction with respect to indicated RCS

j leakage and therefore not a concern." The inspectors noted that without the

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floor drain grates, the potential existed for the flow control device to become

clogged and not pass any water to the weir box. The inspectors discussed the

LER statement with engineering management. The licensee agreed with the

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inspector that the LER statement was incorrect as written. The inspectors

considered the incorrect statement an apparent violation of 10 CFR 50.9,

" Completeness and accuracy of information" (eel 50-455/97005-04(DRP)).

. . The inspectors considered portions of the LER safety analysis weak. The LER

stated that " floor drains would ultimately overflow to the RF sump after a period

of time before detecting leakage. The sump would then show an increase in

level on instrumentation in the control room." The inspectors noted that

overflow into the sump depended on the size of a potential leak. For a small

leak, this could be a very long period of time. The RF system design was to

identify a 1 gallon per minute leak within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Also, the LER indicated that i

radiation monitoring could be used as leak detection; however, the inspectors

noted that the radiation monitors were not as described in Regulatory Guide

1.45 (the radiation monitors were not seismic).

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The object (s) that caused the blockage in the flow control box were not found. ,

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The floor drain oil separator was checked as indicated in the LER corrective

action section; however, because the separator was not drained, only floating

objects could have been identified by the inspection documented in the LER. A

pump down of the separator was planned for the next refueling outage. The

inspectors viewed this as acceptable.

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The inspectors considered LER 50-455/97001 poor and marginally acceptable due i

to incomplete and inaccurate information. This LER is closed and will be tracked

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under apparent violation 50-455/97005-04(DRP).  !

08.2 (Closed) LER 50-454/94015 and 94015-01: SRO absent from control room. The  !

LER and LER supplement documented the event of October 14,1994, when the

enly SPO present left the main control room. The supplement identified additional  !

conective actions, including having two SROs in the control room. This event was

the subject of escalated enforcement and was documented in inspection Report ,

50-454/455/94026(DRS), EA 94-265. Inspection Report 95011 documented '

closure of the violations, including review of the corrective action. The inspectors

did not identify any additional issues during the LER review. This LER and the

supplement are closed.

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( Closed) VIO 50-454/455/95008-01, 50-454/455/95008-02. '

i- 50-454/455/95008-03. eel 50-454/455/95008-04. LER 50-454/95002: ' Hydrogen l

monitors inoperable due to failure to test the water purge cycle of the monitors and

! the monitors were occasionally not run for greater than the minimum required

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sample time. These issues were identified as violations in inspection Report 95008

and a written response was submitted by the licensee on November 22,1995.

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After review of the licensee's written response and the LER, an NOV was issued

l December 11,1995 (EA 95-197). The NOV cover letter documented a review of

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. the licensee's corrective actions and LER, and concluded that no further action was

required. Based on the letter dated December 11,1995, these items are closed.'

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} 08.4 (Closed) URI 50-454/455/96004-04. LER 50-454/96005: Operation of safety

j injection (SI) accumulators oute,ide design basis. Based on an industry identified

i. Issue, Byron identified that the plant licensing basis did not consider the effects of

having more than 2 Si accumulators cross-tied during a postulated loss of coolant

i accident. Byron Operating Procedure (BOP) SI-5, " Raising SI Accumulator Level

i With Si Pumps," allowed the cross-tying of Si accumulators. Although the

{ inspectors and licensee could not find any documentation that stated how many

accumulators were tied to the common headers at any one time, operator

l interviews indicated that more than 2 accumulators 'may have been cross-tied in the '

j past. As corrective actions, procedure BOP SI-5 was revised to limit filling or

draining processes to be performed on one accumulator at a time. Transferring of

! water from one accumulator to another or equalizing nitrogen pressure between

! accumulators was limited to modes when the accumulators were not required to be

j operable. The inspectors reviewed the revised procedure and verified that

j accumulator filling and draining had been performed one accumulator at a time. .

These items are closed. '

j 08.5 (Closed) LER 50-454/92020-01: On April 3,1992, the licensee identified that one

! of the two engineered safety feature (ESF) crossties to Unit 1 was not available. A

j' Unit 2 to Unit 1 crosstie breaker was removed from service for electrical

j- maintenance without considering the TS impact on Unit 1. Unit 1 was unable to

! - crosstie a 4kV ESF bus (bus 141) due to maintenance activities on the Unit 2

l crosstie breaker. TS limiting condition for operation (LCO) 3.8.1.1 was not entered

i and the associated action requirement not met. This event was discussed in

j inspection Report 454/92015. 'A non-cited violation was issued and no new issues

j, were revealed by the LER. The inspector reviewed the licensee's corrective actions

f and considered this issue closed,

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l 11. Maintenance

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!- M1 - Conduct of Maintenance

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l M1.1 Maintenance Observations (62707)

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) a. Insoection Scone

j The inspectors observed all or portions of the following work requests (WR). When

applicable, the inspectors also reviewed TS and the UFSAR for potential issues.

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{ WR 970023490 Inspect SX Side of Jacket Water Cooler

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+ WR 960109479 Install cover on Emergency Stop Pushbutton j

i . WR 960113654 Install Banana Jacks at DG Panel i

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+ WR 960111990 inspect the B air start receiver- I

* WR 960111988 Inspect the A air start receiver ,

. WR 970032763-01. Breaker OCB 10-11 Control Switch Replacement l

WR 970032763-02 Breaker OCB 11-12 Control Switch Replacement -!

l WR 960036379 Inspect OA SX cooling tower isolation valve MOV

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OSX163A

i WR 960020026 Bi-annual inspection of SX cooling tower fan motors

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i b. Observations and Findinas

The inspectors found that the maintenance activities were conducted in accordance

with approved procedures and were in conformance with TS. The inspectors

observed maintenance supervisors and system engineers monitoring job progress.

Quality control personnel were also present when required. When applicable,

appropriate radiation control measures were in place.

WR 970032763-01 and -02 involved troubleshooting, evaluation and replacement-

of the main generator output circuit breaker control switches. As discussed in

Section 01.3, the circuit breakers tripped on the first several attempts to

synchronize the main generator to the grid. The WR also involved validation of the

initial identification that the switches had bad contacts. This work was well

controlled and was conducted in accordance with the procedure. Followup testing

was completed satisfactorily and the main generator synchronized to the grid.'

M1.2 Surveillance Observations (61726)

a. Insoection Scone

The inspectors observed the performance of all or parts of the following

surveillance procedures. The inspectors also reviewed plant equipment and

surveillance activities against the UFSAR descriptions.

2BVS 1.1.1.2-1 Core Reactivity Balance l

2BVS 2.1.3-1 Quarterly Measurement of Target Axial Flux Differences '

~ 2BVS 2.2.2-1 Heat Flux Hot Channel Factor Checkout Using Peaking

Factors

2BVS 2.3.2-1 Nuclear Enthalpy Hot Channel Factor Check

2BVS 3.1.1-5 Incore-Excore Axial Flux Quarterly Calibration

2BVS 3.3.2-1 Moveable incore Detectors Operability Check j

+ 2BVS 4.6.2.2-1 Unit 2 Reactor Coolant System Pressure isolation Valve

and Cold Leg injection isolation Valve Leakage l

Surveillance

+ 2BOS MP-1 Unit 2 Main Power Transformer Cooling System -

Nonroutine Surveillance  :

OBVS SX 5 Inspection of River Screen House and Essential Service I

Water Cooling Tower Basins

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Motor Driven Auxiliary FeeJwater Pump Monthly ,

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Surveillance

l 2BVS 0.5-3.AF.1-1 ASME Surveillance Requirements for the Motor Driven

- Auxiliary Feedwater Pump

1BVS 5.2.f.2-1 {

. ASME Surveillance Requirements for Safety injection

Pump 1Sl01PA '

l ~. ' . SPP 97-010 ECCS Equipment Room Negative Pressure Test

,! .~ 2BOS 8.1.1.2.a-2 2B Diesel Generator Operability Monthly and Semi-

7 Annual Surveillance

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1 b. Observations and Findinos

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The inspectors routinely noted proper authorization from the control room SRO prior

l to the start of each surveillance. Components removed from service were identified

i prior to the surveillance and the proper TS LCO was entered. At the completion of

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the surveillance and after independent verification of system restoration, the TS

l LCO was cleared. Test instruments used were verified to be calibrated as

applicable. The inspectors reviewed completed surveillances and verified the

surveillances met the acceptance criteria, items of interest follow.

Essential Service Water System Siltina

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The licensee and the inspectors noted during the essential service water tower

3 basin, the ultimate heat sink (UHS), silt inspection performed under OBVS SX-5,

l that silt was accumulating in the UHS faster than had been previously observed.

j The silt amounts were within the amount analyzed for a design basis accident.' The

licensee was working with contractors to re-evaluate the river flow and silt control

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at the river screen house.

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[ ECCS Eauioment Room Pr' essure Test

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The inspectors reviewed special plant procedure, SPP 97-010, "ECCS Equipment

Room Negative Pressure Test," Revision 2, and related sections of the UFSAR and

j. TSs, 'As discussed in Section 02.3, the test simulated the containment opening

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necessary for SG replacement and its effect on the auxiliary building ventilation -

j system in maintaining the proper negative pressure in the ECCS equipment rooms.

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1 The inspectors observed test performance on April 23,1997, until the test was

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suspended due to the test limiting conditions being approached. The test data

j. obtained to that point indicated that the TS negative pressure requirements for the

[ ECCS equipment rooms most likely would have been exceeded had the test

! continued. The licensee planned to review the test data to evaluate potenti61

! alternatives for the containment configuration during SG replacement activities.

i The inspectors considered that the test procedure was written and performed

i conservatively so as to not approach any TS LCOs and that the test suspension

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was appropriate.

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M8 Miscellaneous Maintenance issues (92903)

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M8.1 (Closed) VIO 50-454/455/95007-03: Seismically inadequate scaffold over

safety-related equipment. The licensee erected scaffolding over the 2A diesel

generator in preparation for cable re-route activities. The scaffolding did not meet

all of the Byron Administrative Procedure (BAP) 499-3 requirements for seismic

scaffolding. The licensee determined that the root cause was that the plant

personnel were not fully cognizant of all the seismic requirements in BAP 499-3.

Additionally, the licensee determined that specific wording in BAP 499-3 allowed

for some misinterpretation of the requirements during installation of the scaffolding.

Corrective action included immediate improvement of the existing scaffolding,

- identification and correction of all other existing scaffolding, and training sessions

f;r operations.and maintenance department staffs on seismic scaffolding

requirements, The licensee also revised BAP 499-3 to provide clarification of the

requiremente and added an engineering review of all seismic scaffolds. The

inspectot observed the corrected scaffolding and verified BAP 499-3 was revised.

Additionallyc the inspectors have not identified any seismic scaffolding issues since

the vio'ation was cited. This item is closed.

Ill. Enaineering

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E2 Engineering Suppott of Facilities and Equipment

E2.1 Temoorary Alteration Prooram (37551)

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a. Insoection Scone

The inspectors reviewed the troubleshooting of the 125 Vdc bus 211 battery

charger. A temporary alteration program review was also conducted as a result of

a concern involving the strip chart recorder used f or troubleshooting the battery

charger. The inspectors reviewed Byron Administ rative Procedure (BAP) 330-2

" Temporary Alterations," Revision 13; and BAP 400-9, " Troubleshooting and

Maintenance Alterations," Revision 7. The inspectors also discussed the temporary

alteration program with engineering,' operations, and electrical maintenance i

management.

b. Observations and Findinas

On April 14,1997, the inspectors noted a strip chart recorder was electrically

connected to the 125 Vdc bus 211 betery charger. An operator had noticed a  :

momentary dip in bus voltage while completing rounds so a recorder was  !

connected in'an attempt to determine if a battery charger problem existed. The

licensee considered the battery charger operable with the chart recorder connected.

The strip chart recorder had been connected to the battery charger until April 29, i

1997.

The inspectors reviewed BAP 330-2 and considered the strip chart to meet the 4

definition of an " electrical jumper." Electrical jumper was defined as "a temporary

power feed or other electrical connection / device which bypasses or adds a

component within an electrical circuit, thus modifying the circuit design or

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configuration." The inyectors discussed the definition of electri:al jumper with the

j. licensea. The licensee stated that the strip chart recorder was not an alteration

i because it was a high impedance device and therefore did not modify the circuit

j design.

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The inspectors were concerned that a device that had the potential to affect an

i operable safety-related circuit had not received the reviews and evaluations that a

l' temporary alteration would have been subject to in accordance with the licensee's

temporary alteration program. The inspectors noted that there were no time

j. restrictions on troubleshooting activities; therefore, a strip chart recorder could be

connected indefinitely using a WR and troubleshooting guide as documentation.

, Additionally, the recorder connected to the battery charger was a multi-channel

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recorder with 14 leads connected to various points on various components within

p the battery charger. At the end of the inspection period, the inspectors continued

. to review the potential failure modes of the strip chart recorder and the licensee's

i position that a high impedance device did not affect the circuit.

i c. Conclusions

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' The inspectors were concerned that connecting strip chart recorders to operable

equipment without a detailed review did not maintain adequate design control. This

issue was considered an unresolved item pending further NRC review of the

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technical acceptability of having the strip chart recorder connected to operable

equipment and the adequacy of the licensee's tempow y alteration program

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(50-454/455-97005-05(DRP)).

E2.2 Untimely 10 CFR E0.59 Evaluation on Dearaded Control Fmom Recorder (37551)

a. Insoection Scooq

The inspectors noted that control room filter differential pressure (dP) chart

recorder, OPDR-VA030, was net operational. The inspectors discussed the issue

with operators and system engineering and reviewed applicable UFSAR sections to

verify compliance.

b. Obsentations and Findinas

On March 19,1997, the inspectors noted that control room filter dP chart recorder

OPDR-VA030 was not operational. The instrument recorded dP across the high

efficiency particulate (HEPA) filters in the accessible area exhaust plenums. It also

recorded dP across the upstream HEPA filters in the nonaccessible area exhaust

plenum and the fuel handling building exhaust plenum. The inspectors queationed

the operators and were told that the chart recorder had not functioned for years.

The inspectors noted that although the recorder was not safety-related, the

recording of the dPs on the main control panel was described in UFSAR

Section 9.4.5.1.2.h.5.

The inspectors discussed the degraded recorder with system engineering and were

told that WR 940025831 was written on July 5,1994, to replace the recorder

using design change package (DCP) 9400169. Since the recorder was inoperable

for an extensive p ud of time, the inspectors asked if a 10 CFR 50.59 evaluation

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l had been performed since the recorder was not functioning as stated in the UFSAR.

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The licensee had not performed one, but did in response to the inspector's i

concerns. The inspectors reviewed the 10 CFR 50.59 evaluation and had no  !

ll concerns.

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!- The inspectors noted that although the recorder was not functioning, the high dP

{- elarm for these areas were still available in the main control room, local dP I

indications were functioning, and the performance of monthly surveillance j

i OBVS-XDP-1, " Unit 0 Differential Pressure Measurement High Efficiency Particulate

{ (HEPA) Filters," Revision 3, verified dPs on the specific HEPA filters. )

c. Conclusions

The inspectors determined that the non-functioning recorder had no safety

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significance. The inspectors reviewed the licensee's program for identifying UFSAR

discrepancies as documented in Appendix Ill of a February 6,1997, Comed letter to

i the NRC. The licensee's review of old WRs, prior to the inspector's questions, had

[ already placed WR 940025831 on the material condition backlog and forecasted an

j engineering review of the recorder replacement for June 1997.

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E8 Miscellaneous Engineering issues (92700 and 92902)

. E8.1 (Closed) LER 455/94001: Six motor operated valves (MOVs) may not stroke under

a high dP conditions due to inadequate torque switch setting. Based on a MOV

j inspection documented in NRC report 96003, the inspectors determined that new

j torque switch settk.gs were provided for 2 of the valves, which enabled the valves

j to perform their safety-related function under worst case design-basis dP

1- conditions. To address the other 4 valves, the licensee developed special operating

f orders for the operators to minimize the dP across each valve to fully close the

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valves for flood control considerations. Because the 4 valves were normally open,

were not required to change position, were not active valves, and were not credited

in any UFSAR analysis, the four valves were not required to be in the licensee's

j MOV program. The inspectors did not have a concern with the licensee's

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corrective actions. This item is closed.

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E8.2 (Closed) LER 50-454/94012. LER 50-454/95011 LER 50-454/96003: Increased

I tube degradation in the Byron Unit 1 steam generators (SG). The licensee's

i inspection classified each of the 4 model D-4 SGs as category C-3 due to more i

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than 1% of the tubes inspected being defective. All defective tubes were removed  !

from service either by plugging the tube or sleeving the defective region in the tube. l

The inspectors determined that the licensee took appropriate corrective actions and

the safety consequences of this issue were minor. The licensee will replace all four

Unit 1 SGs during the next refueling outage, B1RO8.. These LERs are closed.

E8.3 (Closed) LER 50-454/95006: Missed surveillance during SG tube inspection. On

November _27,1995, the licensee identified that 1C SG tube 34-13 was placed

- back into service following refuel outage B1R06 without having had additional eddy

current inspections performed or being plugged / repaired. That tube was being

tracked as dented and required additional disposition. Without the additional

disposition, Technical Specification 4.4.5.2.d was missed for 1C SG tube 34-13.

In response, the licensee plugged the tube during the B1P02 cutage in

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November 1995. The licensee's corrective actions were appropriate and the safety '

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consequences were minor. This licensee identified and corrected violation is being

treated as a non-cited violation, consistent with Section Vll.B.1 of the NRC *

Enforcement Policy (50-454/97005-06(DRP)). This item is closed.  ;

E8.4- (Closed) IFl 50-454/96003-06: Overpressure protection device for the containment

spray chemical additive system found out of service due to a locked closed valve.  ;

The licensee's evaluation determined that per ASME Code, Section Ill,1974  ;

Edition, Summer 74, Article NC 7111, pressure relief devices were not required '

. where the service limits specif6d in the design specifications were not exceeded.

The licensee's evaluation determined that there was na credible mechanism for the

system to be pressurized where the service limit specified in the design .

specifications were exceeded.: The inspectors reviewed and agreed with the i

evaluation.' Byron opened the overpressure protection valve to the containment

spray additive tank to be consistent with Smidwood Generating Station for design .

reconstitution purposes. The inspectors determined that the licensee's corrective

actions were appropriate and the safety consequences of the closed valve were l

minor. This item is closed.

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IV. Plant Suncort

P1 Conduct of Emergency Preparedness (EP) Activities

P1.1 1997 EP Exercise (82301)

The resident inspectors observed portions of a practice exercise in preparation for 3

the annual site wide drill and the annual station assembly drill. The inspectors  !

observed performance of the Technical Support Center (TSC). Generally, the

licensees staff in the TSC was orderly and knowledgeable. The station assembly

was completed within 30 minutes. The licensee noted several minor areas for

improvement during the critique. The inspectors considered the critique self-critical

and very good overall.  ;

The inspectors also observed the 1997 exercise on April 16,1997. The inspectors

considered the exercise good overall. SpecialInspection Report 97006 contains

detailed documentation of the licensee's performance.

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S8 Miscellaneous Security and Safeguards issues (92904)

S8.1 (Closed) URI 50-454/455/96010-05: Protection of safeguards information. During

the inspector's review of records pertaining to the vehicle barrier system (VBS), the

inspector noted a memorandum from the Engineering Department dated March 7,

1996. : The memorandum contained several paragraphs that described

vulnerabilities with some components of the VBS, some of which were corrected

and some which were not corrected. The memorandum was not marked and

protected as safeguards information.

Further NRC review of the document contents showed that portions of the l

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memorandum were Safeguards information as described in 10 CFR 73.21.

Specifically, the stsceptibility of certain components to be severed and the

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vulnerabilities of some gate systems were considered Safeguards information.  !

. Failure to mark and protect the memorandum as Safeguards Informatior constituted

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a violation of 10 CFR 73.21 (50-454/455/97005 07(DRS)). This item is closed.

V. Manaaement Meetinos

X1 Exit Meeting Summary

The inspectors presented the inspection results to members of licensee

management at the conclusion of the inspection on May 1,1997.

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

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Licensee

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- K. Kofron, Station Manager

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D. Wozniak, Engineering Manager

T. Gierich, Operations Manager

P. Johnson, Engineering Superintendent

E. Campbell, Maintenance Superintendent l

M. Snow, Work Control Superintendent

D. Brindle, Regulatory Assurance Supervisor

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K. Passmore, Station Support & Engineering Supervisor

] P. Donavin, Site Engineering Mod Design Supervisor

i T. Schuster, Site Quality Verification Director

R. Colgiazier, NRC Coordinator

E. Bendis, Shift Operations Supervisor

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J. Heaton, U-0 Operating Engineer

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M. Rasmussen, U-1 Operating Engineer

W. Walter, U-2 Operating Engineer

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l lNSPECTION PROCEDURES USED

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lP 37551: Onsite Engineering

IP 61726: Surveillance Observations

IP 62707: Maintenance Observations

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IP 71707: Plant Operations

IP 82301: Annual EP Exercise

IP 92700: Onsite Follow-up of Written Reports of Nonroutine Events at Power Reactor

Facilities

IP 92901: Followup - Plant Operations

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IP 92902: Followup - Engineering

, IP 92903: Followup - Maintenance

l IP 92904: Followup - Plant Support

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ITEMS OPENED, CLOSED, AND DISCUSSED

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Opened

eel 50-455-97005-01 eel Inoperable containment floor drain system

eel 50-455-97005-02 eel Failure to identify a condition adverse to quality

eel 50-455-97005-03 eel Failure to perform a safety evaluation for various types

of grates in containment floor drain system

eel 50-455-97005-04 eel Failure to provide complete and accurate information in

LER 50-455/97001

50-454/455-97005-05 URI Connecting strip chart recorders to operable equipment  ;

without a detailed review I

50-454/97005-06 NCV Missed surveillance during SG tube inspection  ;

50-454/455-97005-07 VIO Failure to mark and protect Safeguards Information

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50-454/92020-01 LER One of the two ESF crossties to Unit 1 was not

available

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50-455/94001 LER Six valves may not stroke under dP conditions

50-454/94012 LER Increased tube degradation in Unit 1 SGs

50 454/94015 LER SRO absent from control room

50-454/94015-01 LER SRO absent from control room - supplement

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50-454/95002 LER U-1 train 8 hydrogen monitor found inoperable

50-454/95006 LER Missed surveillance during SG tube inspection

50-454/95011 LER Increased tube degradation in Unit 1 SGs

50-454/96003 LER Increased tube degradation in Unit 1 SGs

50-454/96005 LER Operation of Si accumulators outside design basis

50-455-97001 LER Unit 2 containment drain system clogged due to debris.

50-454/97005-07 NCV Missed surveillance during SG tube inspection

50-454/455/95007-03 VIO Seismically inadequate scaffolding over safety-related

equipment

50-454/455/95008-01 VIO 4 examples of TS 3.6.4.1 violations

50-454/455/95008-02 VIO Apparent violation of TS 6.8.1 and BAP 300-1

50-454/455/95008-03 VIO Apparent violation of TS 6.8.1 and BOS 0.1-1,2,3

50-454/455/95008-04 eel Apparent violation of 10 CFR 50

50-454/455/96010-05 URI Protection of safeguards information

50-454/455/96004-04 URI Cross-tied safety accumulators

50-454/96003-06 IFl Overpressure protection device found out of service

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LIST OF ACRONYMS USED

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BAP Byron Administrative Procedure

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BOP Byron Operating Procedure

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DCP Design Change Package

dP. Difforential Pressure

ECCS Emergency Core Cooling System

EP Emergency Preparedness

i- FME Foreign Material Exclusion

GPM Gallons per minute

HEPA High Efficiency Particulate

HLA Heightened Level of Awareness

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LCO Limiting Condition for Operation L

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LER Licensee Event Report

, NOV Notice of Violation

OAD Operational Analysis Department

PDR Public Document Room

RCFC Reactor Containment Fan Coolers

l. RCS Reactor Coolant System l

i RF. Containment Floor Drain System

SG Steam Generator

! SI Safety injection

I' SRO Senior Reactor Operator

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SSE Safe Shutdown Earthquake

TS Technical Specification

, TSC Technical Support Center

j UFSAR Updated Final Safety Analysis Report

. VBS Vehicle Barrier System  !

WR Work Request  !

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