ML20151J960
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| ML20151J960 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 07/25/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20151J946 | List: |
| References | |
| 50-454-97-09, 50-454-97-9, 50-455-97-09, 50-455-97-9, NUDOCS 9708050295 | |
| Download: ML20151J960 (14) | |
See also: IR 05000454/1997009
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U. S. NUCLEAR REGULATORY COMMISSION
REGION lli
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Docket Nos: 50-454, 50-455
License Nos: NPF-37, NPF-66
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Report No: 50-454/97009(DRP); 455/97009(DRP)
Licensee: Commonwealth Edison Company
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Facility: Byron Generating Station, Units 1 & 2
Location: 4450 N. German Church Road
Byron, IL 61010
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Dates: May 27 through June 5,1997
! Inspectors: S. Burgess, Byron Senior Resident inspector
A. Vegel, Zion Senior Resident inspector
P. Lougheed, Region ill Inspector
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Approved by: Roger D. Lanksbury, Chief,
Reactor Projects, Branch 3
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!. EXECUTIVE SUMMARY
Byron Generating Station, Units 1 & 2
NRC Inspection Report 50-454/97009, 50-455/97009
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This inspection focused on the circumstances involving the failure to vent the chemical -
and volume control (CV) system in accordance with the technical specifications (TS). Also
inspected was Byron's performance of surveillances in general and the operability
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assessment process when surveillances identify problems / concerns.
Ooerations
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The inspectors identified s missing support bracket on the 18 Si pump lube oil
cooler which the licensee later datermined rendered the 18 Si pump inoperable due
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to not meeting proper seismic requirements. The inspectors considered the
licensee's operability assessment and wrrective actions prompt and appropriate 1
(Section O2.1). '
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Maintenance /Surveillotsg
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After the licensae identified in February 1996 th' at the CV pump ca' sings and
discharge piping high points were not e ' - ' as requir<3d by TS 4.5.2.b.1, they
f ailed to recognize the need is be in sti npliance with the TS. The inspectors
determined that the operability assessn ic formed by Byron engineering failed
to rccognize that TS requirements were .'._ "eing met and a TS change was
needed. After identification by the NRC of th - issue, the licensee appropriately
t'egan preparations and commenced reducing p twer prior to receiving relief from
'he TS shutdown requirements. The failure to vt nt the CV system in accordance
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with the TS it an apparent violation (Section M1.1).
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The insNetors concluded that the licensee had not vented one discharge piping
high point for train 1B of the RH system. This is an apparent violation. Uoon
identification, the licenses took appropriate corrective actions. The inspec tors
considered RH heat exchanger and the suction piping high points venting o good ;
practice (Section M1.2). '
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The licensee identified that TS requireo slave relay testing for 10 phase "A" !
containment isolation valves had not been r,erformed as required by the TS since
mid 1991. The inspectors considered the Ccensee's efforts in identifying additional
missed TS surveillance requirements as bcup proactive. The inspectors'
independent review determined that two sep; rate onsite reviews failed to identify
that TS requirements were not met with the : irveillance procedure revision alone.
Two examples of an appareri violation were identified (Section M1.3).
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The inspectors concluded that past auxiliary feedwater (AF) pump surveillance
testing was adequstely documented and that problems encountered during the tests
appeared to hav9 been identified and dispositioned in accordance with corrective
action procedures (Section M1.4).
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The inspectors identified that the surveillance procedures used to vent the Si pumps
were inadequate in that they provided no direction to the operator as to proper
valve line-up to ensure proper pump venting. This is considered an apparent
violation. Numerous opportunities existed to identify this inadequate procedure in ;
that operators routinely had to perform extra unapproved steps in order to vent the
Si system (Section M3.1). ;
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The inspectors observed a number of documentation weaknesses in problem
identification forms and operability assessments as evidenced in the limited written
information that supported operability assessment conclusions. However, in all'
cases, folicwup questioning by the inspectors found that the responsible individuals y
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had additional information to support the conclusion (Section M7.1). '
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REPORT DETAILS
1. Operations
02 Operational Status of Facilities and Equipment
02.1 Missino Suncort on 1B Safety Iniection (SI) Pumo Lube Oil Cooler
a. Insoection Scooe (71707)
The inspectors walked down accessible portions of the Si, auxiliary feedwater (AF),
and chemical and volume control (CV) systems for high point vents, evidence of
water hammer, and system material condition.
b. Observations and Findinas
On May 27,1997, the inspectors identified a missing support bracket on the 18 SI
pump lube oil cooler. Operations requested an operability assessment, which
determined that the 1B SI pump should be declared inoperable because the 1B Si
pump lube oil cooler did not meet the seismic design requirements due to the
missing support bracket under the cooler end bell. Operations entered the
appropriate limiting condition for operation (LCO) action requirement and a work
request was written to install the missing support bracket. The licensee initiated
efforts to determine the cause of the missing support bracket through past
maintenance work performance, but had not completed the review prior to the
inspection end date. This item will be followed with the review of the Licensee
Event Report (LER), which will document this issue. ,
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c. Conclusions
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The inspectors ider;tified a missing support bracket on the 1B SI pump lube oil
cooler, which the licensee later determined rendered the 1B Si pump inoperable due
to not meeting proper seismic requirements. The inspectors considered the
licensee's operability assessment and corrective actions prompt and appropriate.
II. Maintenance
M1 Conduct of Maintenance /Surveillances
M 1.1 Surveillance Observations (61726)
a. insoection Scoce
l The inspectors reviewed technical specification (TS) surveillance requirements to ! vent the emergency core cooling systems (ECCS) pump casings and discharge
piping high points outside of containment. The inspectors also reviewed the
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applicable surveillance procedures and discussed the issue with the licensee and the
NRC office of Nuclear Reactor Regulation, l
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b. Observations and Findinas
TS Surveillance Not Met For CV System Ventina
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On May 22,1997, during a review of TS surveillance requirements to vent the I
ECCS pump casings and discharge piping high points outside of containment, the
inspectors identified that TS surveillance 4.5.2.b.1 had not been performed as
required. Specifically, the Unit 1 and Unit 2 CV (an ECCS subsystem) pump
l casings and the CV high points had never been vented during Modes 1,2, and 3; a i l
time period that exceeded the TS requirement of venting at least once per 31 days.
! When questioned, the licensee informed the inspectors that on February 16,1996, l the Byron staff documented (through the problem identification form (PlF) process) l
that a Braidwood system engineer identified that the CV pump casings and high
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point vents were not vented as required by TS 4.5.2.b.1, partially due to the fact
that the CV pump casing design did not have vents. Byron operability assessment
96-007, dated February 16,1996, stated that there was no technical concern with
the lack of casing vents on the CV pumps or the lack of venting on the CV system
every 31 days due to the intent of the TS being met. The operability assessment
determined that the intent of TS 4.5.2.b.1 was to ensure that air entrapment did
not occur in systems or lines that were stagnant or idle, Byron engineering credited
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the dynamic venting action of the operating CV pump as meeting the TS
I requirement to ensure that the ECCS piping was full of water. For piping not l directly in the flowpath, the licensee determined that gas accumulation was not
credible due to the high pressure (approximately 2400 psi) inside the piping. The
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licensee considered the idle CV pump to be self venting due to CV system design
l and piping configuration. ! j The NRC determined that operating the CV pump constituted flushing the line l '
versus venting the line and also noted that the CV high point vent valve, outside of
containment (1/2S1045), was not subject to system flow and could be an area
susceptible to air / gas accumulation. Although Comed considered all CV pumps to
be operable, the licensee was not in strict compliance with the TS requirements to
vent the CV penp casing and discharge piping high points.
On May 22,1997, the licensee declared both trains of the CV system inoperable
following several conference calls held by Region 111 and NRR with the licensee.
TS 3.0.3 was entered for both units due to both trains of ECCS being inoperable
and TS 4.0.3 was entered due to the missed surveillances. Entering
TS 4.0.3 allowed the action requirements of TS 3.0.3 to be delayed for up to
24 hours to complete the surveillance testing. Failure to vent the CV system in
accordance with the TS once per 31 days since initial plant operation was
considered an example of an apparent violation of TS 4.5.2.b.1
(eel 50-454/455-97009-01a(DRP)).
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Because the CV pump casing design could not accommodate venting and because
the licensee considered the CV system piping venting inappropriate due to the
constant high pressure in the system, Comed requested a Notice of Enforcement
l Discretion (NOED) from the NRC on May 23,1997. A TS amendment request that
modified the wording of TS 4.5.2.b.1 was also submitted. In support of the
requests, on May 22-23, 1997, the licensee performed compensatory actions of
ultrasonically testing (UT) the vulnerable high point areas in the CV system piping
l and verified that the piping was filled with water.
On May 23,1997, the licensee began preparations to shut down both units if the
NOED was not approved within the 24-hour time clock initiated by TS 4.0.3. The
inspectors observed the shift begin to reduce power on Unit 1 until the NRC staff
approved the NOED on May 24,1997.~ After notification of NOED approval, the
unit was returned to full power. At the writing of this report, the NRC staff (NRR)
was reviewing the license TS amendment request.
c. Conclusions
After the licensee identified in February 1996 that the CV pump casings and
discharge piping high points were not vented as required by TS 4.5.2.b.1, they
failed to recognize the need to be in strict compliance with the TS. The inspectors
determined that tiv Jerability assessment performed by Byron engineering failed
to recognize that TS requirements were not being met and a TS change was
needed. The licensee appropriately began preparations and commenced reducing
power prior to receiving relief from the TS shutdown requirements.
M1.2 Missed Hiah Point Vent on the Residual Heat Removal (RH) System (61726)
a. Insoection Scone
The inspectors compared surveillance procedures 1/2 BOS 5.2.b-1 to the piping and
instrumentation diagrams (P&lD) for both units on the Si and RH systems. Specific
P&lD sheets reviewed were:
* M61 Safety injection Unit 1
* M62 Residual Heat Removal Unit 1
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M136 Safety injection Unit 2
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M137 Residual Heat Removal Unit 2
b. Observations and Findinas
' l The inspectors confirmed that the valves listed in the surveillance procedures for
the Si and RH systems were identified on the P&lDs as high-point vents. The
l inspectors noted that, for both the Si and RH systems, the licensee included l suction side high point vents as well as the required discharge piping high points, i
The licensee also vented the RH heat exchangers. The inclusion of the suction high
points and the RH lieat exchangers in the surveillance were considered good
practices.
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The inspectors identified that high point vent valve,1RH027, was not included in
the surveillance. This valve was located in the discharge piping from the 18 RH !
heat exchanger and was outside of containment. The inspectors did not identify :
similar high point vents for the 1 A RH heat exchanger or for either of the Unit 2 !
heat exchangers. The inspectors discussed with the licensee the failure to include i
valve 1RH027 within the surveillance. The licensee promptly agreed that 1RH027
was a high point valve, revised the surveillance procedures, and performed the {
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venting. The licensee also reviewed the isometrics for the other RH train on Unit 1
and both trains on Unit 2 and confirmed that high points did not exist in those lines
between the RH heat exchangers and the containment.
TS Surveillance 4.5.2.b(1) required the licensee to vent the ECCS pump casings
and discharge piping high points outside of containment every 31 days. This '
surveillance requirement was met through completion of surveillance procedures
1/2 BOS-5.2.b-1 every month. The failure to include RH discharge piping high point
vent 1RH027 in the surveillance procedures resulted in the high point not being ,
vented as required by the TS. This is an example of an apparent violation of
TS 4.5.2.b(1) (eel 50-454/455-97009-01b). l
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c. Conclusions ~
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The inspectors concluded that the licensee had not vented one discharge piping '
high point for train 18 of the RH system and is an apparent violation. Upon
identification, the licensee took appropriate corrective actions. The inspectors !
considered RH heat exchanger and the suction piping high points venting a good
practice.
M1.3 TS Surveillance Reauirements Not Met for Slave Relav Testina (61726)
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a. Insoection Scopa
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The licensee identified that TS required slave relay testing for 10 phase "A"
containment isolation valves had not been performed. The inspectors reviewed the
licensee's corrective actions to properly test the slave relays.
b. Observations and Findinas
Based on the issues raised by the NRC on the CV system, Byron reviewed TS
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operating surveillances and identified 6 (3 per unit) additional surveillances where
TS requirements were not met. Specifically, quarterly slave relay testing of the
automatic actuation logic and relays for 10 phase "A" containment isolation valves,
' had not been performed since mid-1991. This testing was required by TS 4.3.2.1,
Table 4.3-2, Functional Unit 3.a.2.
The inspectors reviewed a September 25,1990, Westinghouse letter which
informed Byron that performing quarterly slave relay containment isolation tests on
the CV charging line valves,1/2CV8105 and 1/2CV8106, and CV letdown line
valves,1/2CV8152 and 1/2CV8160, could result in unanalyzed thermal transients
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on the CV piping and nozzles and a high fatigue usage factor. To minimize further
thermal cycling, Westinghouse recommended that the "GO" testing in which the
valves were actually stroked be changed to "NO GO" testing in which the valves
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were not actually stroked but a visual verification and/or electrical continuity test of '
the slave relay contact actuation was performed. ;
in response to the concern, Byron reviewed applicable surveillance procedures and l
determined that the CV charging line valves were already tested with the "NO GO"
methodology. To address the CV letdown valves, Byron revised procedures 1/2
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BOS 3.2.1-840, "ESFAS instrumentation Slave Relay Surveillance (Train A
Containment isolation Phase A - K605)," and 1/2 BOS 3.2.1-850, "ESFAS
Instrumentation Slave Relay Surveillance (Train B Containment isolation Phase A -
K605)," on June 13,1991. The revision jumpered across the CV letdown line
valves contacts. The revisions successfully prevented valve actuation when
performing the TS quarterly surveillance; however, a visual verification and/or
electrical continuity test of the slave relay contact actuation was never performed
as recommended by the vendor and required by TS. Failure to perform the
continuity test for the slave relay contacts that actuate letdown isolation valves
1CV8152,1CV8160,2CV8152, and 2CV8160, on a quarterly basis since June 13,
1991,is considered to be an example of an apparent violation of TS 4.3.2.1
(eel 50-454/455-97009-02a(DRP)).
Although not specifically identified by the Westinghouse letter, Byron determined
that the CV letdown orifice isolation valve (1/2CV8149A/B/C) slave relay testing
should also be changed to a "NO GO" test for the same thermal transient concerns.
Although the 6 (3/ unit) letdown orifice isolation valves were not containment
isolation valves, the valves received a phase "A" containment isolation signal.
To address the CV letdown orifice isolation valves, the licensee revised procedures
1/2 BOS 3.2.1-853, "ESFAS Instrumentation Slave Relay Surveillance (Train A(B)
Containment isolation Phase A - K612)," on April 29,1991. The revision pulled
fuses on the letdown orifice isolation valves. The revisions successfully prevented
valve actuation when performing the TS required quarterly surveillance; however, a
visual verification and/or electrical continuity test of the slave relay contact
actuation was also never performed. Failure to perform the continuity test for the
slave relay contacts that actuate letdown orifice isolation valves 1CV8149A/B/C
and 2CV8149A/B/C on a quarterly basis since April 29,1991, is considered an
example of an apparent violation of TS 4.3.2.1 (eel 50-454/455-97009-02b(DRP)).
The inspectors reviewed On-Site Review (OSR) 90-257, dated August 18,1990,
which approved revision of the surveillance procedures. In 1992, the licensee
submitted a modification for the installation of test circuits that would provide a
permanent method of visually verifying the slave relay contact actuation testing the
relays at power. In parallel to the potential modification, Byron's regulatory
! assurance department was working with the Westinghouse Owner's Group to l investigate the possibility of a change to TS 3/4.3.2, which would reduce the
frequency of testing from quarterly to once every 18 months. This TS change
l would enable "GO" testing of the valves during refuel outages when the thermal
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transient concerns were minimized. The potential modification was put on hold i
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until approval or rejection of the proposed TS change. Neither the modification or i
the TS change had been approved. '
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The inspectors also reviewed OSR 93-057, dated July 18,1993, which ;
documented Byron's position for accepting the testing method used for the CV i
letdown isolation valves. The OSR referenced Byron UFSAR Section 7.1.2.6,
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which presented justification for altemate testing methods for ESFAS equipment '
which could not be tested at power. The UFSAR stated,in part, that alternate
testing methods were appropriate when there was no practicable means of testing
the equipment without adversely affecting the safety or operability of the plant and *
when adequate testing could be routinely performed while the reactor was shut !
down. The inspectors were informed that the OSR considered the associated -
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thermal transients adverse to the safety of the plant and therefore, "GO" testing of I
the CV letdown isolation valves should not be conducted at power. The OSR
documented that although the jumper preventod a positive means for verifying '
valve actuation, the surveillance still proved that the relay had energized in that
other equipment had been actuated by other relay contacts. The OSR also cited ,
, ' that the valves were "GO" tested every 18 months (every refuel outage) to satisfy '
other TS surveillance requirements. s
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The inspectors noted that the proposed modification would have provided a i
practical means of testing the valves at power without any adverse affect on the
plant. Modification installation would have also satisfied the TS surveillance
requirement.
c. Conclusions
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The inspector's considered the licensee's efforts in identifying the missed TS
surveillance requirements to be proactive. The inspectors independent review
determined that OSR 90-257 and 93-057 failed to identify that TS requirements
were not met with the surveillance procedure revision elone.
M1.4 Auxiliary Feedwater Pumo Surveillance Testino (61726)
a. Insoection Scope
The inspectors conducted a review of past monthly, quarterly, and outage
surveillance tests of the Unit 1 and 2 motor driven and diesel driven AF pumps, i
The inspectors interviewed licensee staff including operations and engineering
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1/2 BOS 7.1.2.1.B-2, " Diesel Driven Auxiliary Feedwater Pump Quarterly
! Surveillance"
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1/2 BOS 7.1.2.1.a 4, " Diesel Driven Auxiliary Feedwater Pump Monthly
j Surveillance" i *
1/2 BVS 7.1.2.1.b.2-1, " Auxiliary Feedwater Pump Emergency Actuation Signal
- Verification Test"
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b. Observations and Findinog
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The inspectors reviewed completed TS required surveillance procedures pertaining
to the AF pumps from October 1995 through the present. The inspectors noted
that the surveillances properly documented required data and initiated corrective
l actions such as PlFs and operability assessments when problems were noted. l
During the surveillance review, the inspectors noted that prior to the start of the
l testing, procedure 1/2 BVS 7.1.2.1.b.2-1 required the manual start of the pre- l lubrication pump 3 for the AF pumps. The inspectors were concerned that manually
starting the pre-lubJcation pumps preconditioned the AF pumps prior to
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performance of the surveillances. As documented in PIF B1997-01907, the
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licensee subsequently dvermined that based on pre-operational testing, which
included successful AF pump starts without pre-lubrication, and system design
documentation, the practice of pre-lubrication did not represent a concern for pump '
operability. The licensee concluded that the safety benefit of pre-lubrication prior to
surveillance testing outweighed the benefit of testing the pumps in the as-found
condition when considering the possibility of accelerated wear and premature
failure. The inspectors discussed this issue with NRR who agreed with the
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licensee's conclusion.
c. Conclusionan
The inspectors concluded that past AF pump surveillance testing was adequately
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documented and that problems encountered during the tests appeared to have been
identified and dispositioned in accordance with corrective action procedures.
M3 Maintenance / Surveillance Procedures and Documentation
M3.1 Inadeauate Surveillance Procedure (61726)
a. Inspection Scope
The inspectors reviewed surveillance procedures 1BOS 5.2.b-1, "ECCS Venting and
Valve Alignment Monthly Surveillance," Revision 5, and 2BOS 5.2.b-1, "ECCS
Venting and Valve Alignment Monthly Surveillance," Revision 4, for monthly
verification of proper ECCS venting of piping outside containment in Modes 1,2,
i and 3 per TS 4.5.2.b(1). The inspectors also discussed PIFs B1997-01746, i B1997-01792, and B1997-01805, which documented difficulties in venting the 2A l and 1B safety injection (SI) pumps.
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b. Observations and Findinas
P
St Pumo Casina Ventina
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. Oh May 15,1997, the licensee performed surveillance procedure 2BOS 5.2.b-1, for
monthly venting of the 2A Si pump. Step F.1 stated to vent the Si pumps and
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piping until a steady stream of water was evident. Step F.1.b required the operator
to open SI pump casing vent isolation valve 2Sl040 and vent the pump. The
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operator reported that only one drop per second came out of the drain piping when
he opened valve 2Sl040 and the filtered vent (VF) drain valve,2VF019. PlF
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B1997-01746 was written and documented that the piping would be checked for '
potential blockage due to dried boron build-up. The PlF also stated that other Si
pump vents have been found in the past to be blocked by dried boron. Operations
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determined that the 2A Si pump remained operable since the pump was adequately '
vented by running it periodically to fill the Si accumulators. The surveillance was
also determined to be satisfactorily performed since some water and no air came
out of the drain line.
On May 20,1997, the licensee performed surveillance procedure 1BOS 5.2.b-1, for .
venting the 1B SI pump. During the surveillance, the operator reported that no flow l
came from the vent line and wrote PlF B1997-01792 to document this concern. ]
The system engineer along with operations, reviewed the concern on May 21, l
1997, and reported that a steady stream of water was evident when the
surveillance steps were re-performed. The inspectors questioned how the VF line
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became unplugged with no maintenance performed. The system engineer stated
that because of known problems with the blocked VF system lines, operators relied I
on other valves in the VF system to perform the Si pump casing venting. SI pump '
venting was usually accomplished by opening VF drain valve lines that opened to a
floor drain. Although these valves were not mentioned in the surveillance
procedure, most operators knew how to perform the surveillance in this manner. In
this case, the operator who attempted to vent the 18 SI pump on March 20
apparently was not aware that valve 1VF017 had to be opened to vent the 1B SI
pump casing.
The inspectors reviewed procedures 1/2 BOS 5.2.b-1 and determined that the
procedure was inadequate to ensure that TS 4.5.2.b(1) requirements were met, in
both procedures the operator was directed to open 1/2Sl040 valve to vent the Si
pump casings. Although a sightglass was located downstream of the opened valve
to verify flow through the piping, no mention of the sightglass appeared in the
procedure. The inspectors noted that all of the Si pump sightglasses were dirty and
questioned whether any flow could be seen by an operator. Also, the sightglass for
the 18 Si pump was located approximately 15 feet above the pump where flow
could only be verified with the use of a ladder. The inspectors also noted a total of
5 action requests (ARs) on both trains of the SI pumps. Two ARs on the 1 A Si
pump documented that pump casing vent isolation valve 1S1040A, leaked by and
the sightglass needed to be cleaned. Two ARs on the 1B Si pump documented
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pump casing vent isolation valve 1Sl040B, leaked by and the vent line was plugged
with dried boron. One AR on the 2A SI pump documenteo a.4 t.'u pump casing
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vent drain line was also plugged. Since operators routinely had to perform
additional steps not included in the procedure in order to vent the SI system,
numerous opportunities existed for the inadequate procedure to be identified.
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The inspectors considered procedures 1/2 BOS 5.2.b-1 inadequate to ensure that l
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the SI pump casings were vented. Specifically, the procedure provided no specific
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direction to the operator as to what valves were to be open to vent the Si pumps. '
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Because Byron had documented problems with blockage of the filtered vent
system, venting the SI pumps had been performed with steps other than those
called out in the procedure. Failure to ensure that procedures 1/2 BOS 5.2.b-1
contain procedural steps for ensuring that the SI pump casings were vented is
considered to be an apparent violation (eel 50-454/455-97009-03(DRP)).
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<: . Conclusions
The inspectors identified that the surveillance procedures used to vent the Si pumps
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were inadequate in that they provided no direction to the operator as to proper
! ' valve line up to ensure proper pump venting. This is considered an apparent
violation. Numerous opportunities existed to identify this inadequate procedure in
that operators routinely had to perform extra unapproved steps in order to vent the
j Si system. I M7 Quality Assurance in Ma'ntenance/ Surveillance Activities !
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l M7.1 Review of Problem Identification Forms and Operability Assessments (37551)
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The inspectors reviewed a listing of all PlFs and operability assessments dealing l
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with surveillance issues over the last 2 years. The inspectors reviewed PIFs and
operability assessments determinations where problems occurred during a
surveillance or those affecting the Si, RH, and AF systems. The inspectors
observed a number of documentation weaknesses in that limited written
l ' information was available to support operability assessment conclusions. However, i
in all cases, the responsible individuals had additional information to support the
conclusions. The inspectors concluded that the licensee reached the correct
l operability decision in each PlF and operability assessment reviewed. The
inspectors had no further concems.
V. Maneaement Meetinos
l X1 Exit Meating Summary
The inspectors presented the inspection results to members of licensee
management at the conclusion of the inspection on June 5,1997.
The inspectors asked the licensee whether any materials examined during the
l 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, Byron Station Plant Manager
8. Adams, Site Engineer
D. Brindle, Regulatory Assurance Supervisor
R. Freidel, Primary Group Leader
i T. Gierich, Operations Manager l J. Horn, System Engineer
P. Johnson, Engineering Superintendent
B. Kouba, Business Manager
K. Passmore, Station Support & Engineering Supervisor
P. Reister, Assistant Engineering Supervisor
T. Schuster, Site Quality Verification Director
M. Snow, Work Control Superintendent
W. Walter, U-2 Operating Engineer
D. Wozniak, Engineering Manager
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lNSPECTION PROCEDURES USED
IP 37551: Onsite Engineering
IP 61726: Surveillance Observations
IP 71707: Plant Operations
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ITEMS OPENED, CLOSED. AND DISCUSSED
Opened
eel 50-454/455-97009-01a eel Failure to vent the CV pump casings and the CV
discharge piping per TS 4.5.2.b.1.
eel 50-454/455-97009-01 b eel Failure to vent CV discharge piping high point
vent 1RH027 per TS 4.5.2.b.1.
eel 50-454/455 97009-02a eel Failure to perform continuity test for the slave
relay contacts for the CV letdown isolation
valves per TS 4.3.2.1.
eel 50-454/455-97009-02b eel Failure to perform continuity test for the slave
relay contacts for the CV letdown orifice
isolation valves per TS 4.3.2.1.
eel 50-454/455-97009-03 eel Inadequate surveillance procedere for venting SI
pumps.
LIST OF ACRONYMS USED
AF Auxiliary Feedwater
AR Action Request
BOS Byron Operating Surveillance
BVS Byron System Engineering Surveillance
CV Chemical and Volume Control
ECCS Emergency Core Cooling System
LCO Limiting Condition for Operation
LER Licensee Event Report
NOED Notice of Enforcement Discretion
NOV Notice of Violation
OSR On-Site Review
P&lD Piping & Instrumentation Diagrams
PDR Public Document Room
PlF Problem identification Form
RH Residual Heat Removal
SI Safety injection
TS Technical Specification
UT Ultrasonic Testing
VF Filtered Vent
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