ML20147H309
| ML20147H309 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 01/14/1988 |
| From: | Falevits Z, Gardner R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20147H179 | List: |
| References | |
| 50-454-87-27, 50-455-87-25, NUDOCS 8801220264 | |
| Download: ML20147H309 (6) | |
See also: IR 05000454/1987027
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
' Reports No. 50-454/87027(DRS); 50-455/87025(DRS)
Docket Nos. 50-454; 50-455-
Licensee:
Commonwealth Edison Company
Post Office Box 767
Chicago, IL 60690
Facility Name:
Byron Station, Units 1 and 2
Inspection At:
Byron Site, Byron, Illinois and
CECO Corporate Office
Inspection Conducted:
Ju
7-9, and August 20-21, 1987
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Inspector:
2. Falevits
Date
?-tsk%k-
Approved By:
Ronald N. Gardner, Chief
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88
Plant Systems Section
Dat'e
Inspection Summary
Inspection on July 7-9, and August 20-21, 1987 (Reports do. 50-454/87027(DRS);
No. 50-455/87025(DRS))
Areas Inspected:
Routine, unannounced safety inspection of licensee action on
previous inspection findings; followup review of non-seismically qualified
components in Emergency Diesel Generator (OG) control circuitry; observation of
maintenance surveillance activities, and training (62705, 92702, 92705, 41400).
Results:
Of the four areas inspected, no violations or deviations were
identified in three areas.
One violation was identified in one area (failure
to assure, via the design review process, that seismically qualified
electrical components were used in the DG control circuitry - Paragraph 3).
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8801220264 880114
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DETAILS
1.
Persons Contacted
C;mmonwealth Edison Company (CECO)
- R. E. Querio, Station Manager
- R. C. Ward, Services Superintendent
- G. K. Schwartz, Assistant Superintendent, Maintenance
- D. W. Berg, Nuclear Safety Engineer
- D. K. Johnson, General Foreman, I.M.
- W. D. Pirnat, Regulatory Assurance Engineer
- M. F. Blessing, Technical Staff Engineer
- R. J. Morvec, Assistant Construction Superintendent
- R. B. Klingler, Senior Quailty Assurance Engineer
- W. J. Walter, Assistant Technical Staff Supervisor
- H. Snow, Regulatory Assurance Supervisor
- E. Zittle, Regulatory Assurance Staff
B. Shelton, Engineering Manager, PWR
+0. Elias, Byron & Braidwood Engineering Superintendent
+W. J. Grosko, Project Engineering, PWR Engineer
K. Ainger, Nuclear Licensing Engineer
R. Gesior, QA Engineer
Sargent & Lundy Engineers (S&L)
+D. P. Galanis, Electrical Project Engineer
R. J. Moery, Component Qualification Engineer
+S. Malak, PMED Engineer
+M. Hassaballa, Component Qualification Supervisor
The inspector also contacted and interviewed other licensee and
contractor personnel during this inspection.
- Denotes persons attending the July 9, 1987, site exit interview.
+ Denotes persons attending the August 21, 1987, exit interview at the
CECO Corporate office.
2.
Licensee Action on Previous Inspection Items
a.
(Closed) Unresolved Item [454/87002-04(DRP); 455/87002-03(DRP)]
This item concerned an event described in LER 454/86035 in which
the licensee determined on December 17, 1986, that non-seismically
qualified parts were installed in the Emergency Diesel Generators
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(DG) for Units 1 and 2.
During the review of this item, the
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inspector determined that the licensee's design control measures
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failed to assure that only seismically qualified components were
used in the DG control circuitry.
As a result, this item is
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considered a violation of 10 CFR 50, Appendix B, Criterion III,
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as discussed in Section 3 of this report.
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b.
(Closed) Unresolved Item [454/87017-04(DRP); 455/87016-04(DRP)]
During a previous inspection, the resident inspector noted that the
time from the start of. decay of the voltage on bus 142 to the
actuation of the bus.undervoltage relay appeared to exceed the limit
of Technical Specification 3.3.2, Table 3.3-4, Functional Unit 8.a
-(2.2 verses 1.8 seconds).
However, bench testing of the undervoltage
relay, both before and after the test, indicated that the relay was
within the TS limit of 1.8 seconds and that its setpoint had not
changed.
The licensee believed that the inductive loading on the
4.16kv bus caused a slower voltage decay which caused the undervoltage
relay to energize at 2.2 seconds.
The licensee also believed that
this was acceptable and that the relays met the TS requirements.
The inspector reviewed this issue and discussed the findings with NRR.
NRR concluded that bench testing was an acceptable method for
calibrating and setting the undervoltage relays to the Technical
Specification requirements.
Based on this position, this item is
considered closed.
3.
Followup Review of Non-Seismically Qualified Components in' Emergency
Diesel Generator Control Circuitry
a.
The inspector conducted a followup review of the event described
in LER 454/86035.
This LER stated that on December 17, 1986,
with Unit 1 in Mode 1 and Unit 2 in Mode 3, the licensee's AE,
Sargent & Lundy (S&L), identified that non-seismically qualified
components were erroneously installed (wired) in the control
circuits of the Units 1 and 2 Emergency Diesel Generators (DGs).
The inspector conducted interviews with licensee and S&L personnel
and examined the applicable design and logic drawings and procedures
to determine the cause of the installation error.
(1) The review indicated that on December 4, 1986, the Byron
Architect Engineer, Sargent & Lundy (S&L), identified
four components (limit switches 12E01 and 12E02 and pressure
switches 33E02 and 33E01) which were not listed as
safety-related on the qualified parts list for the DGs.
These components were erroneously wired into the electrical
overspeed safety related trip circuitry of the DGs.
Failure
of either component in both diesel logic trains would have
caused a de-energization of the emergency master run relays
which would in turn de energize the fuel oil solenoids and
stop the DGs.
It was also determined that during a seismic
event these non qualified devices could actuate, preventing
the DGs from starting or cause them to stop.
The cause of
the design error was determined to be Cooper-Bessemer's (CB)
erroneous placement of non-seismicially qualified components
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into a safety-related circuit.
The original intent for the
components used in the overspeed circuitry was for alarm
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purposes only.
The inspector determined that the initial
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design review conducted by S&L failed to identify the design
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error.
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.(2)- During this followup- review, the inspector examined S&L'.s design
review methodology as it pertains to the seismic qualification
and technical adequacy of safety-related components and vendor
supplied design drawings.which had been reproduced onto S&L
. approved design drawings.
Sargent & Lundy Procedure GQ-3.09,
Revision 5, entitled "Foreign-Design Documents," states in
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Paragraph A.3 that "the Project Leader, Project Supervisor or
Supervising Design Engineer shall assign a qualified individual
to review foreign design drawings."
In addition, Paragraph B.1
states that "the Inter and/or Intra Department Commentators
shall review the design drawings, as. required within their area
of responsibility, for compliance with the requirements of the
procurement specification . . . latest design information
and/or Vendor.'s proposal data . . . ."
S&L Procedure GQ-3.09 further requires that the foreign design
drawings be forwarded to the client (CECO) and other external
interfacing organizations for design reviews and comments; that
the Engineer / Supervisor satisfactorily resolve those comments
within its area of responsibility; that the contractor's
technical data, such as design data, design specifications,
seismic reports, etc., be sent to the responsible engineer.for
review and processing; that the Project Manager establish
a system for monitoring receipt of contractor's technical data
documents to ensure that all required documents.have been
submitted for review; and that the responsible engineer
prepare a letter of reply to the vendor which will include
any comments and the action to be-taken by-the vendor.
The inspector reviewed Sargent & Lundy's Procedure GQ-3.07,
Revision 7, entitled, "Sargent & Lundy Drawings" which described
the quality assurance requirements for the preparation, comment,
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review, approval and distribution of S&L drawings that pertain
to safety-related structures, systems and components.
Paragraph 3.2.'3.1 of Procedure GQ-3.07, states "Provisions
shall be established for obtaining comments, as necessary, on
the technical adequacy of a drawing from interfacing departments
and divisions, and external sources such as clients".
In
addition, Paragraph 3.2.4 requires that provisions shall be
established to provide for a documented review and review
of the technical adequacy of a drawing.
A design review shall
be performed prior to release of the drawing for fabrication,
installation, construction, or release to another organization
for use in other design activities.
The drawing shall be
reviewed and commented upon, in accordance with a departmental
standard, for technical adequacy for the purpose of release.
When the drawing is technically adequate, the reviewer shall
sign the drawing on the drawing release record as reviewer.
Furthermore, the reviewer's signature on the drawing certifies
that the drawing is technically correct, that interfacing
conditions have been addressed, that all comments have been
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resolved and that the review was conducted in accordance'with
the' departmental standard.
The inspector determined that.S&L standard EDSI-73,
Revision 04-29-85, stated that,the vendor'is responsible for
the technical adequacy of the base design provided on the
drawing submitted, that S&L is only responsible for technically
reviewing any interface information added to the vendor produced
drawings.
However, the inspector concluded that this standard
did not apply to the DG drawings that have been reviewed and
issued prior to the issuance date of Standard EDSI-73.
Based on this review, the inspector determined that CECO, C8
and S&L engineers failed to identify the design _ error during the
initial design reviews that should have been conducted prior to
equipment installation.
Consequently, these switches existed
in the Diesel Generato'r circuitry since Byron's receipt of
operating license (October 31, 1984 for Unit 1 and November 6,
1986 for Unit 2), rendering _the Diesel Generators inoperable
and in violation of Technical Specification since the units
started operating.
The inspector informed the licensee that failure to identify design
errors during the design review process is considered a violation
of 10 CFR 50, Appendix B, Criterion III (454/87027-01(ORS);
455/87025-01(DRS)).
b.
The inspector reviewed QA audits which were conducted by CECO at
the Cooper Industries (CI) facilities during the period from 1979
to 1986.
The review indicated that Audit No. G-86-12 conducted in
August, 1986 identified serious problems with CI's QA program.
As a
result of these findings, CECO removed CI industries from the Quality
Approved Bidders List on May 1, 1987.
The inspector expressed the
concern that additional vendor design errors mi0ht exist in the
DG system possibly compromising safety.
The licensee informed the
inspector that during a recent system design description review and
spare parts review which was performed by S&L on Byron Units 1 and 2
all safety-related components were examined.
Several design problems
were identified and corrected in each unit.
No other deficiencies
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were noted.
Based on this review the licensee believes that all
safety-related components in Byron Units 1 and 2 are qualified.
4.
Observation of Maintenance Surveillance Activities
The inspector witnessed surveillance and calibration activities
conducted on Auxiliary Feed Pump 28 Crank Case Pressure Switch 2PSH-AF154.
The following items were considered during this review:
calibration was
accomplished in accordance with an approved procedure and test report;
appropriate authorization signatures were obtained prior to starting the
calibration; test instrumentation was within its calibration interval;
the task was accomplished by qualified personnel; test results conformed
with acceptance criteria and tolerances.
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The inspector reviewed the following associated documents:
Calibration of Auxiliary Feed Pump 2B Crank Case' Pressure Switch
(AF) Test Report Package BIP 2400-008, dated July 9,- 1987.
Calibration of Pressure Switch Procedure No. BIP 2400-008,
Revision 2.
Maintenance Alteration Log BAP 400-TS, Revision 8.
No violations or deviations were identified.
5.
Training
The effectiveness of the licensee's training program was' reviewed by'the
. inspector during the witnessing of the licensee's performance.of routine
surveillance and maintenance activities.. Personnel appeared to be
knowledgeable of the task being performed.
No violations or deviations were identified.
6.
Exit-Interview
The Region'III inspector met with licensee representatives (denoted
under Paragraph 1) at the conclusion of the inspection on July 9, and.
on August 21, 1987.
The inspector summarized the purpose and findings
of the inspection.
The licensee acknowledged this information.
The
inspector also discussed the likely informational content of the
inspection report with regard to documents or processes reviewed by the
inspector during the inspection.
The licensee did not identify any such
documents / processes as proprietary.
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