Text

Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000.Violations Noted:Neither RHR Pump Capable of Injecting Into All Four RCS Cold Legs & Main Steam Isolation Not Verified During Surveillance
	ML20197J575
Person / Time
Site:	Byron
Issue date:	05/06/1986
From:	James Keppler; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	;
Shared Package
ML20197J553	List: IR 05000454/1985042; IR 05000454/1985056; ML20197J575;
References
	EA-86-048, EA-86-48, NUDOCS 8605200077
	Download: ML20197J575 (5)
	v • d • e

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NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL F2NALTIES Commonwealth Edison Company Docket No. 50-454 Byron Nuclear Power Station License No. NPF-37 Unit 1 EA 86-48 During NRC inspections conducted during the periods August 12 through October 18, 1985, and October 2 through October 31, 1985, violations of NRC requirements were identified.

In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the Nuclear Regulatory Commission proposes to impose civil penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as amended, ("Act"), 42 U.S.C.

2282, PL 96-295, and 10 CFR 2.205. The particular violations and associated civil penalties are set forth below:

I.

Technical Specification (TS) 3.5.2 requires that two independent emergency core cooling system (ECCS) subsystems shall be operable with each subsystem comprised in part of one residual heat removal (RHR) pump and an operable flowpath when in Modes 1, 2, or 3.

Technical Specification 3.0.3, which applies when TS 3.5.2 is not met and if two RHR pumps are inoperable, requires that within I hour, the licensee shall initiate action to place the unit in a mode in which the specification does not apply by pl. acing it, as applicable, in at least' ""

hot standby within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , at least hot shutdown within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and at least cold shutdown within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The definition of operability for the injection path for the ECCS is e

discussed in the Byron Unit 1 FSAR, Section 6.3 where it states that each RHR subsystem injects into all four cold legs of the reactor coolant system.

Contrary to the above, on March 6, 1985 for approximately 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , March 7, 1985 for approximately 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , April 20, 1985 for approximately 31 hours3.587963e-4 days 0.00861 hours 5.125661e-5 weeks 1.17955e-5 months , April 23, 1985 for approximately 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , May 30, 1985 for approximately 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months , May 31, 1985 for approximately 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months and on July 24, 1985 for 3 separate periods of approximately 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months , 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months , while in Mode 1, both RHR subsystems of the ECCS were rendered inoperable during surveillance testing in that neither RHR pump was capable of injecting, as stated in the FSAR, into all four reactor coolant system cold legs due to the fact that valves IRH8716A and ISI8809A for RHR Pump A and valves IRH87168 and ISI88098 for RHR Pump B were closed while system performance was being measured.

This is a Severity Level III violation (Supplement I).

Civil Penalty - S50,000 II.A.

Procedure 18053.1.1-21, " Train B SSPS Bimonthly Surveillance," requires that whenever an operability surveillance test is performed on the subject system, certain functions including main steam isolation and auxiliary feedwater must be successfully tested before the train can be declared operable.

8605200077 860506 PDR A00CK 05000454 G

PDR

Notice of Violation 2

MAY 6 1986 Contrary to the above, after performing surveillance testing on July 15, 1985, the licensee improperly declared Train B of the solid state protection system operable even though the main steam isolation and auxiliary feedwater functions had not been verified during the surveillance as being operable.

B.

Technical Specification 3.3.2 requires that for Modes 1, 2, and 3, the engineered safety features actuation system (ESFAS) instrumentation channels and interlocks shown in Table 3.3-3 shall be operable.

It also states that with an ESFAS instrument channel inoperable, apply the applicable action statement requirements of Table 3.3-3 until the channel is restored to operable status.

Table 3.3-3 requires, in part, that Functional Units 4.b, " Steam Line Isolation, Automatic Actuation Logic and Actuation Relays" and 6.b,

" Auxiliary Feedwater, Isolation Automatic Logic and Actuation Relays,"

have a minimum of 2 operable channels when the plant is in Mode 1, 2, or 3.

If the minimum channel requirement is not satisfied, then Action Statement 21 shall be followed.

Table 3.3-3, Action Statement 21 requires for Functional Units 4.b and 6.b that with less than 2 operable channels be in at least. hot standby (Mode 3) within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in at least hot shutdown (Mode 4) within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

However, one channel may be bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing per Specification 4.3.2.1 provided the other channel is operable.

Contrary to the above, on July 14-15, 1985, while in Mode 3, Train B of the ESFAS was declared inoperable, which rendered both required Train B Channels for Functional Units 4.b and 6.b inoperable and the plant was not placed in hot shutdown (Mode 4) within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The plant was not put in Mode 4 until approximately 19 hours2.199074e-4 days 0.00528 hours 3.141534e-5 weeks 7.2295e-6 months after the ESFAS train was declared inoperable.

In addition, Train B of the ESFAS was placed in the bypass condition for 10.7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months , which exceeded the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months time limit allowed by technical specifications.

C.

Technical Specification 3.11.2.5, " Radioactive Effluents Explosive Gas Mixture," requires that the concentration of oxygen in the waste gas holdup system shall at all times be limited to less than or equal to 2's by volume whenever the hydrogen concentration exceeds 4*; by volume.

Technical Specification 3.11.2.5, Action Statement a.,

requires that with the concentration of oxygen in the waste gas holdup system greater than 2's by volume, but less than or equal to 4*e by volume, the licensee shall reduce the oxygen concentration to the above limits within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

o Notice of Violation 3

MAY 6 1986 Contrary to the above, even though Special Chemistry Data Sheet, BCP-400-T.60, Revision 0, which was completed at 11:40 a.m. on July 6, 1985 stated that the waste gas holdup system had a hydrogen concentration of 5.5% by volume and an oxygen concentration of 3.9% by volume, the licensee failed to reduce the oxygen concentration to less than or equal to 2% by volume within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . This condition existed for approximately 130 hours0.0015 days 0.0361 hours 2.149471e-4 weeks 4.9465e-5 months .

D.

Technical Specification 3.11.2.5, " Radioactive Effluents Explosive Gas Mixture," requires that the concentration of oxygen in the waste gas holdup system shall at all times be limited to less than or equal to 2% by volume whenever the hydrogen concentration exceeds 4% by volume.

Technical Specification 3.11.2.5 Action Statement b.,

requires that with the concentration of oxygen in the waste gas holdup system greater than 4% by volume, and the hydrogen concentration greater than 4% by volume, the licensee shall immediately suspend all additions of waste gases to the system and reduce the concentration of oxygen to less than or equal to 4% by volume; then take Action a. above.

Contrary to the above, even though Special Chemistry Data Sheet, BCP-400-T.60, Revision 0, which was completed at 9:20 p.m. on July 11, 1985, stated that the hydrogen concentration was 4.1% by volume and the oxygen concentration 10.8% by volume and the licensee did not immediately take action to reduce the concentration of oxygen to less than or equal to 4% by volume.

This condition existed for approximately 53 hours6.134259e-4 days 0.0147 hours 8.763227e-5 weeks 2.01665e-5 months .

E.

Technical Specification 3.3.3.10 requires that the radioactive gaseous 9

effluent monitoring instrumentation channels shown in Table 3.3-13 shall be operable as stated in the table.

Technical Specification 3.3.3.10, Action Statement b. requires that with less than the minimum number of radioactive gaseous effluent monitoring instrumentation channels operable, the licensee shall take the action shown in Table 3.3-13.

Table 3.3-13, Instrument 3.a, Hydrogen Analyzer 0AT-GW8000, requires a minimum of one channel to be operable during waste gas holdup system operation or Action Statement 38 shall be applied.

Table 3.3-13, Instrument 3.b, Oxygen Analyzers OAT-GW8003 and 0AT-GW8004, requires a minimum of 2 channels to be operable during waste gas holdup systen operation or Action Statement 38 shall be applied.

Table 3.3-13, Action Statement 38 requires that with the number of channels operable one less than required, operation of the waste gas holdup system may continue provided grab samples are taken from the system and analyzed at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Contrary to the above, from July 28 to August 4, 1985, with the waste gas holdup system operating and with all Hydrogen Analyzer 0AT-GW8000 and Oxygen Analyzer 0AT-GS8003 channels inoperable, grab samples were not taken and analyzed at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

UAY 6 1986 Notice of Violation 4

F.

10 CFR Part 50, Appendix B, Criterion V requires that activities affecting quality shall be prescribed by documented instructions, procedures or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings.

Instructions, procedures or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Permanent Facility Modification (PFM) #M6-0-84-242 was used by the licensee to install a blank-off plate in the control room ventilation Train 0A makeup ductwork.

Technical Specification (TS) 3.7.6 requires two independent control room ventilation systems to be operable for Modes 1, 2, 3, and 4.

With one of two independent control room ventilation systems inoperable, the system must be restored in 7 days or the plant must be in hot standby within the next 6 six hours and in cold shutdown within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

If two control room ventilation systems are inoperable, TS 3.0.3 applies, which requires that acticns be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit in a mode in which the specification does not apply by placing it as applicable in at least hot standby within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and at least hot shutdown within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Contrary to the above, on September 5, 1985, PFM #M6-0-94-242 did not contain appropriate quantitative or qualitative acceptance criteria for determining that the installation of the blank-off plate was satisfactorily accomplished. As a result, the blank-off plate was installed in the 9

wrong location. Plant personnel did not discover the error until September 13, 1985 when Train 0A was used and it could not maintain the required differential pressure.

Since one train had been inoperable from September 5-13, 1985, without the plant being put in the required mode, this was a violation of TS 3.7.6.

Train OB was also rendered inoperable by the licensee on September 12, 1985, at 6:20 p.m. to perform maintenance. As a result, both control room ventilation trains were simultaneously inoperable, in violation of TS 3.0.3, until Train OA was restored at 1:20 p.m. on September 13, 1986.

Collectively the above violations have been evaluated as a Severity Level III problem (Supplement I).

Cumulative Civil Penalty - 550,000 assessed equally among the violations.

Pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison Company is hereby required to submit to the Director, Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region III, within 30 days of the date of this Notice, a written statement or explanation, including for each alleged violation:

(1) admission or denial of the alleged violation,

/

o MAY 6 1986 Notice of Violation 5

(2) the reasons for the violation if admitted, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved.

If an adequate reply is not received within the time specified in this Notice, the Director, Office of Inspection and Enforcement, may issue an order to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.

Consideration may be given to extending the response time for good cause shown.

Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Within the same time as provided for the response required above under 10 CFR 2.201, Commonwealth Edison Company may pay the civil penalties by letter addressed to the Director, Office of Inspection and Enforcement, with a check,

~

draft, or money order payable to the Treasurer of the United States in the cumulative amount of One Hundred Thousand Dollars (S100,000) or may protest imposition of the civil penalties in whole or in part by a written answer addressed to the Director, Office of Inspection and Enforcement, will issue an order imposing the civil penalty in the amount proposed above.

Should Commonwealth Edison Company elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, such answer may: (1) deny the violation circumstances, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalties should not be imposed.

In addition to protesting the civil penalties in'whole or in part, such answer may request remission or mitigation of the penalties.

In requesting mitigation of the proposed penalties, the five factors addressed in Section V.B of 10 CFR Part 2, Appendix C should be addressed. Any written 9

answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of the 10 CFR 2.201 replys,by specific reference (e.g.,

citing page and paragraph numbers) to avoid repetition. Commonwealth Edison's attention is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalties.

Upon failure to pay any civil penalties due which has been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282.

FOR THE NUCLEAR REGULATORY COMMISSION S W h.

James G. Keppler Regional Administrator Dated al Glen Ellyn, Illinois this 6*tfay of May 1986.

U.S. NUCLEAR REGULATORY COMISSION REGION III Report No. 50-454/85042(DRP)

Docket No. 50-454 License No. NPF-37 Licensee:

Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name:

Byron Station, Unit 1 Inspection At:

Byron Station, Byron, IL Inspection Conducted:

August 12 through October 18, 1985 Enforcement Conference:

Scheduled for November 22, 1985 Inspectors:

W. L. Forney P. G. Brochman RFklaus.lck Approved By:

R. F. Warnick, Chief

////F/#f Reactor Projects Branch 1 Da'te '

9 Inspection Summary Inspection on August 12 through October 18, 1985 (Report No. 50-454/85042(DRP))

Areas Inspected:

Special unannounced safety inspection by a regional inspector and a resident inspector to review licensee performance in complying with the Facility License and Technical Specification requirements.

An Enforcement Conference is scheduled for November 22, 1985.

The inspection consisted of 69 inspector-hours onsite and at the Region III office by two NRC inspectors.

Results: This report identified three apparent violations of NRC requirements:

(1) operation of the ECCS system designed to mitigate serious safety events such that it could not have performed its intended safety function and failure to follow the applicable Technical Specification Action Requirements -

Paragraph 3; (2) failure of management controls necessary to assure compliance with the Technical Specifications, 3 examples - Paragraphs 4, 5, and 6; and (3) exceeding the reactor core licensed thermal power rating - Paragraph 7.

These violations are considered to be of safety significance with the potential to effect the public's health and safety.

DETAILS 1.

Persons Contacted Commonwealth Edison Company R. Querio, Station Manager R. Pleniewicz, Production Superintendent T. Tulon, Operating Engineer D. Brindle, Operating Engineer F. Hornbeak, Technical Staff Supervisor C. Kilbride, Technical Staff E. Wurtz, Technical Staff 2.

General This inspection was conducted as a result of Region III management's continuing concern regarding Unit I unplanned reactor trips, missed Technical Specification surveillances, failure to meet Technical Specification Limiting Conditions for Operation Action Statement requirements, and the large number of Licensee Event Reports (LER) issued to date.

The inspection which began on August 12, 1985 and concluded on October 18, 1985, included reviews of the LERs and the circumstances surrounding:

(1) operation of the unit in Mode I with both subsystems of the Emergency Core Cooling System (ECCS) inoperable; (2) operation of the unit in Mode 3 with Channel B of the Engineered Safety Features Actuation System (ESFAS) inoperable for a period of time in excess of that allowed 9

by the Technical Specification Action Requirement; (3) operation of the Radioactive Gaseous Effluent system with concentrations of Hydrogen (H )

2 and Oxygen (0 ) in excess of that allowed by Technical Specifications; 2

(4) failure to take grab samples when Radioactive Gaseous Effluent Monitors for H2 and 02 were inoperable; and (5) operation of the unit at reactor core thermal power levels in excess of that allowed by the Facility Operating License.

The inspector's evaluation of these 5 events consisted of a review of the circumstances surrounding each LER and interviews with licensee personnel.

For each LER the inspector developed a chronology; reviewed the functioning of safety systems required by plant conditions; reviewed licensee actions to verify consistency with the Facility Operating License, Technical Specifications, and implementing procedures; reviewed the licensee evaluation of the event; and reviewed previously identified problems of a similar nature.

Details of the events are provided in Paragraphs 3 through 7 below.

3.

Operatina With Both ECCS Subsystems Inoperable (Closed) LER (454/85081-LL):

This LER described events on March 6 through July 24, 1985, while in Mode 1 (power operations greater than 5% power),

involving inoperability of both ECCS subsystems and the failure to follow 2

_,,A L

Technical Specification Action Requirements. This event was discovered by licensee personnel following identification of a similar problem at the Callaway Nuclear Power Station by the NRC.

The low pressure injection portion of the ECCS consists of two Residual Heat Removal (RHR) pumps, two RHR Heat Exchangers, and suction and 4

discharge flowpaths (see Attachment 1). Technical Specification 3.5.2 states, in part:

"Two independent... ECCS subsystems shall be OPERABLE...." when in Modes 1, 2, or 3.

The Safety Analysis, contained in the Byron FSAR, for a large Break - Loss of Coolant Accident (LB-LOCA) assumes that each RHR pump is capable of injecting cold borated water into all four Reactor Coolant System (RC) cold legs during the " Injection Phase" of ECCS operation.

Both subsystems of the ECCS were rendered inoperable during the performance of Byron Technical Staff Surveillances 1BVS 5.2.f.3-1, "ASME Surveillance Requirements for Residual Heat Removal Pump 1RH01PA"

[A Subsystem] and IBVS 5.2.f.3-2, "ASME Surveillance Requirements for Residual Heat Removal Pump 1RH01PB" [B Subsystem] when valves 1RH8716A and ISI8809A (see Attachment 1) were shut during the performance of the RHR pump 1A surveillance and also when valves 1RH8716B and 15I8809B were shut during the perforrance of the RHR pump IB surveillance.

Byron FSAR, Figure 6.3-2 (see Attachment 1) and its notes define the position of valves 1RH8716A, IRH8716B, ISI8809A and 1518809B as open during the injection phase of the ECCS operation. With valves 1RH8716A or ISI8809A shut and RHR pump 1A isolated, the B subsystem would have only been capable of injecting water into a maximum of two RC cold legs (1 and 2).

Conversely, with valves 1RH8716B or ISI8809B shut and RHR pump 1B isolated, the A subsystem would have only been capable of injecting water into a raximum of two RC cold legs (3 and 4). Consequently, with this valve configuration both ECCS subsystems should have been considered inoperable.

Both ECCS subsystems were inoperable on nine separate instances during surveillance testing while in Mode 1.

The dates of these events and the approximate length of tine the valves were shut (both subsystems inoperable) is as follows:

l Date Tine Shut March 6, 1985 13.0 hours0 days 0 hours 0 weeks 0 months March 7,1985 13.0 hours0 days 0 hours 0 weeks 0 months April 20,1985 30.7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months April 23.*1985 6.3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months May 30, 1985 30.2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months May 31, 1985 5.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months July 24, 1985 3.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months l

July 24, 1985 1.9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months July 24, 1985 6.9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months i

3

r-With both ECCS subsystems inoperable, Technical Specification 3.0.3 required that within one hour action should have been initiated to place the unit in Hot Standby (Mode 3) within the next six hours and the unit should have been placed in Hot Shutdown (Mode 4) within the following six hours.

Licensee personnel failed:

(1)toinitiateactionwithinonehour on the following dates: March 6, 7, April 20, 23, May 30, 31 and July 24; (2) to place the unit in Mode 3 within the next six hours on the following dates: March, 6, 7 April 20, and May 30; (3) to place the unit in Mode 4 within the following six hours on the following dates:

April 20 and May 30.

With one RHR pump isolated and the other RHR pump capable of only injecting water into a maximum of two RC Cold Legs, both ECCS subsystems were rendered inoperable and thus a systein designed to mitigate serious safety events [LB-LOCA] would not have been able to perform its intended safety function. With both ECCS subsystems inoperable, the licensee failed to initiate the-required actions.

These failures are an apparent violation of Technical Specifications 3.5.2 and 3.0.3 (454/85042-01(DRP)).

If necessary, the licensed operators in the control room could have opened the valves, upon receipt of a Safety Injection signal, with the valves taking less than 10 seconds to open.

A previous violation of regulatory requirements in which both subsystems of ECCS were inoperable is described in Inspection Report No. 454/85002(DRP).

In that report the violation concerned the isolation of both Safety Injection pump flowpaths. The licensee's permanent corrective action in response to violation (454/85002-02(DRP)) was submitted to the NRC in a letter from D. L. Farrar to J. G. Keppler on July 10, 1985, and stated:

" Station personnel licensed at the Senior Reactor Operator level conducted o

a review of all operating procedures involving ECCS systems, even as a support system, to determine those procedures that could impact Technical Spec'ification LCO's. As a result of this review, affected operating procedures were revised." The licensee's corrective action for this violation does not appear to have been effective in that it failed to identify that both ECCS systems would be inoperable during the perfonnance of BVS 5.2.f.3-1 and 5.2.f.3-2.

A previously identified violation (2 examples) of regulatory requirements was described in Inspection Report No. 454/85016(DRP). Violation No.

454/85016-03(sDRP) related to the failure to follow Technical Specification Action Requirements within the specified time limits. This violation concerned the failure to shut and de-energize the Pressurizer Power Operated Relief Valve (PORV) block valves when the POP.Vs were inoperable 1

and the failure to place the Control Room Ventilation system in the makeup mode with an inoperable radiation monitor.

The inspector identified a concern to the licensee that LERs 454/85017 and 454/85040 documented the failure to follow Technical Specification Action requirements and LER 454/85011 documented the failure to maintain 4

two operable ECCS subsystems and questioned whether these LERs should have been listed on LER 454/85081 as " previous similar events" as required by 10 CFR 50.73(b)(2)(ii)(J)(5).

Additionally, the inspector questioned the LER's lack of an assessment of the safety consequences and implications of the event as required by 10 CFR 50.73(b)(2)(ii)(J)(3). These concerns will be followed as an Unresolved Item (454/85042-02(DRP)).

The inspector identified to the licensee that the valve identification numbers and valve positions described in the notes attached to Byron FSAR, Figure 6.3-2, Sheet 3 were not correct for the valves labeled as numbers "22," "23," "24," "25," and "26."

The licensee has committed to issuing an amendment to the FSAR to correct this problem and accomplish-ment of this action will be followed as an Open Item (454/85042-03(DRP)).

4.

Failure to Follow Technical Specifications With ESFAS Channel B Inoperable (Closed) LER (454/85069-LL):

This LER described an event on July 14-15, 1985, while in Mode 3, involving the failure to place the unit in the applicable mode when required by Technical Specification 3.3.2, Table 3.3-3, Action Statement 21.

At 1904 on July 14, 1985, an instrument mechanic shorted out the power supply for Channel B of ESFAS causing a Reactor Trip.

The channel was declared inoperable and licensee personnel erroneously began following the requirements of Table 3.3-3, Action Statement 14.

Action Statement 14 required that the unit be placed in Cold Shutdown (Mode 5) within the next 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Licensee personnel f ailed to realize that Table 3.3-3, Action Statement 21 was applicable and was more restrictive than Action Statement 14.

O Table 3.3-3, Action Statement 21 states:

"With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, be in at least HOT STANDBY [ Mode 3] within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in at least HOT SHUTDOWN l

[ Mode 4] within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; however, one channel may be bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing per Specification 4.3.2.1 provided the other channel is OPERABLE." Action Statement 21 was invoked by Technical Specification 3.3.2, Table 3.3-3, Function Units l

4.b, "Steamline Isolation, Automatic Actuation Logic and Actuation Relays" and 6.b, " Auxiliary Feedwater, Isolation Automatic Actuation Logic and I

Actuation Relays".

Each of these functional units required a minimum of two OPERABLE channels when in Mode 1, 2, and 3, or else follow Action Statement 21.

At 1910 on July 14, 1985 Channel B was placed in the test position

[ bypassed condition].

At 0104 on July 15, 1985, the unit should have been placed in Mode 4 due to the inoperability of the Steamline Isolation and Auxiliary Feedwater functions.

At 0320 on July 15 licensee personnel discovered that Action Statement 21 was applicable and by 0512 had begun a cocidown to place the unit in Mode 4.

i 5

At 2307 on July 14, following replacement of the damaged power supply a surveillance to verify Channel B operability was performed.

The Main Steam Isolation and Auxiliary Feedwater functions passed; however, several other functions failed to pass the surveillance.

At 0200 on July 15 licensee personnel voided the surveillance.

A voided surveillance is not an acceptable record to furnish evidence for activities affecting quality.

Licensee personnel failed to recognize that the voided surveillance could not be used as evidence of the operability of the Main Steam Isolation or Auxiliary Feedwater Functions.

At 0552 on July 15, ESFAS Channel B was placed in Normal (after having been in Test for 10.7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ) and the cooldown was terminated.

At 0612 on July 15 licensee personnel questioned the operability of the Auxiliary Feedwater Function and resumed the cooldown.

Mode 4 was entered at 1439 on July 15, 19.6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after Channel B was declared inoperable; Mode 5 was entered at 2048 on July 15.

The failure to place the unit in Mode 4 within six hours and placing ESFAS Channel B in Test for greater than two hours is an apparent violation of Technical Specification 3.3.2 and an example of the failure of management controls necessary to assure compliance with the Technical Specifications (454/85042-04a(DRP)).

ESFAS Channel A remained operable throughout the course of this event and manual initiation of these ESF components could have been performed by the licensed operators in the control room, if necessary.

This event is indicative of failure of corrective actions provided in response to previously identified violations of regulatory requirements as described in Inspection Report (454/85016(DRP)), to ensure that Technical Specification Action Requirements are correctly identified and followed.

?

(See Report Section 3)

The inspector identified a concern to the licensee that LERs 454/85017 and 454/85040 documented the failure to follow Technical Specification Action requirements and questioned whether these LERs should have been listed on LER 454/85069 as " previous similar events" as required by 10 CFR 50.73(b)(2)(ii)(J)(5).

This concern will be followed as an Unresolved Item (454/85042-05(DRP)).

An additional concern relating to use of voided documents to provide an acceptable record to furnish evidence of activities affecting quality will be followed as an Open Item (454/85042-06(DRP)).

5.

Explosive Gas Concentrations in the Radioactive Gaseous Effluent System (Closed) LER (454/85067-LL):

This LER described events on July 6-14, 1985, while in Mode 1, involving failure to follow Technical Specifications Action Requirements for Radioactive Gaseous Effluents relating to the Hydrogen (H ) and Oxygen (0 ) concentrations present in 2

2 the Waste Gas system.

I 6

On July 6, 1985, an Equipment Attendant recorded a H2 concentration of 5.5% and at 1140 a chemist recorded an 02 concentration of 3.9% on Special Chemistry Data Sheet, GCP-400-T.60, Revision 0.

Technical Specification 3.11.2.5, " Radioactive Effluents Explosive Gas Mixture,"

states:

"The concentration of oxygen in the WASTE GAS HOLDUP SYSTEM shall be limited to less than or equal to 2% by volume whenever the hydrogen concentration exceeds 4% by volume " Applicability of this specification is "at all times." Technical Specification 3.11.2.5.a states:

"With the concentration of oxygen in the WASTE GAS HOLDUP SYSTEM greater than 2%

by volume but less than or equal to 4% by volume, reduce the oxygen 1

concentration to the above limits within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ." The OD Waste Gas j

Decay tank was taken out of service on July 6,1985, and records indicate i

that the tank remained out of service, with concentration of 0 /H2 greater 2

than that allowed by Technical Specification 3.11.2.5.a until July 11, 1985.

There is no record to indicate that the licensee initiated any action to reduce the 0 concentration at any time prior t July 11, 1985, 2

in accordance with Byron Abnormal Operating Procedure OB0n PRI-8, "0 /H2 2

Explosive Mixture Units 0, 1, 2."

l Technical Specification 3.11.2.5.b states:

"With the concentration of oxygen in the WASTE GAS HOLDUP SYSTEM greater than 4% by volume, immediately suspend all additions of waste gases to the system and reduce the concentration of oxygen to less than or equal to 4% by volume then take ACTION a above." At 2120 on July 11, 1985, the 0 /H2 concentrations 2

of the OD tank were recorded as 10.8%/4.1% respectively and remained greater than that allowed by Technical Specification 3.11.2.5.b until 1348 on July 14, 1985.

i Review of the licensee records indicate that OBOA-PRI-8 was entered, for 9

tank 0D, on July 11, 1985, to reduce the explosive mixture of 0 /H -

2 2 Licensee personnel attempted to reduce the 02 concentration below the limit of Technical Specification 3.11.2.5.b by releasing the tank; however, the release was terminated when it was determined that Radiation Monitor OPR02J, which controls the Waste Gas discharge valve position, was inoperable due to insufficient amount of vacuum above the low limit alarm setpoint.

Subsequently, a temporary alteration was installed on July 12,1985, which would allow the release to be accomplished.

At 2100 on July 12, the release from the OD tank was recommenced; however, it was observed that the pressura in tank OA was also showing a decrease and the i

release was terminated once again. The reason the release was terminated l

was that Byron procedures do not allow for more than one Waste Gas Decay l

tank to be released at the same time.

A nuclear work request was initiated to repair the OA tank manual release valve, and after repairs were completed the OD tank release was recommenced and a nitrogen purge was initiated.

The release and the purge were terminated at 1348 on l

July 14, 1985, when the 0 /H2 concentrations were determined to be less 2

j than the limits of Technical Specification 3.11.2.5.a.

Failure cf the licenste's management systems to identify the high 1

concentrations of 0 /H2 on July 6,1985, resulted in no action being 2

taken by the licensee to reduce these concentrations below Technical i

7

m Specifications limits from July 6 until July 11, 1985.

After identifi-cation by the licensee on July 11, that the 0 /H2 concentration in the OD 2

tank exceeded the limits of Technical Specification 3.11.2.5.b, subsequent management decisions and management systems failed to reduce the 0 /H2 2

concentrations below Technical Specifications limits until July 14, 1985.

The inspector's review determined that the items listed below were contributing factors to this event:

a.

Incomplete / inaccurate Rad-Chem records.

b.

Incomplete Limiting Condition for Operation Action Requirement (LCOAR) data sheets.

c.

Inadequate tracking of LC0AR conditions by management / supervision.

d.

Inadequate review and assessment by management / supervision of appropriate corrective actions to be accomplished.

e.

Failure of management / supervision to ensure that corrective actions identified were accomplished in a timely manner.

f.

An apparent attitude of management / supervision to disregard Technical Specification Action Requirements that do not provide specific primary plant operational penalties.

The failure to reduce the explosive concentrations of 0 /H2 present in 2

the Waste Gas system is an apparent violation of Technical Specification 3.11.2.5 and an example of the failure of management controls necessary to assure compliance with the Technical Specifications (454/85042-04b(DRP)).

6.

Failure to Take Grab Samples With Inoperable Radioactive Gaseous Effluent Monitors (Closed) LER 454/85082 described events on July 28 through August 4,1985, while in Modes 1 - 4, relating to the failure to obtain and analyze grab samples from the Waste Gas system when two channels of Radioactive Effluent Monitoring Instrumentation were inoperable.

At 2200 on July 16, 1985, lechnical Specification 3.3.3.10, Table 3.3-13, Instrument 3.a, OAT-GW8000, " Hydrogen Analyzer" was taken out of service.

At 0720 on July 20,1985, Table 3.3-13, Instrument 3.b, OAT-GW8003,

" Oxygen Analyzer" was taken out of service.

Technical Specification 3.3.3.10, Table 3.3-13, Instrument 3.a required a minimum of one channel to be operable at all times, or else follow Action Statement 38.

Instrument 3.b required a minimum of two channels to be operable at all times, or else follow Action Statement 38.

Action Statement 38 states, in part:

"With the number of channels OPERABLE one less than required by the Minimum Channels ODERABLE requirement, operation of this system may continue provided grab samples are taken and analyzed at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ...."

With system operation continuing licensee personnel began taking and analyzing grab samples every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

This requirement was listed on a 8

status board in the Rad-Chem office. On July 27 this requirement was inadvertently erased from the status board by licensee personnel.

As a consequence, the licensee failed to take and analyze grab samples on the following dates:

a.

While in Mode 3:

July 28, 1985 b.

While in Mode 4:

July 29 - 31,1985 c.

While in Mode 2:

August 1, 1985 d.

While in Mode 1:

August 2 - 4, 1985.

The failure to obtain and analyze grab samples at least once every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is an apparent violation of Technical Specification 3.3.3.10 and an example of the failure of management controls necessary to assure compliance with the Technical Specifications (454/85042-04c(DRP)).

The failure to obtain samples required by Technical Specifications was previously described in Inspection Report 454/85021(DRP).

The licensee's permanent corrective action in response to violation 454/85021-Olb(DRP) was submitted to the NRC in a letter from D. L. Farrar to J. G. Keppler on July 19, 1985, and stated, in part:

"A file organizer has been placed in the Station counting room for initiated surveillance procedures.

Technicians are periodically instructed by the responsible foreman to review the file for initiated surveillances.

Initiated surveillances are also tracked on the counting room shift turnover sheet...." This violation is indicative of the licensee addressing the specific violation only, but no'. addressing the root cause of the problem.

Consequently, the action taken to avoid further violations was not effective.

These three examples (Paragraphs 4, 5, and 6) of apparent violations of Technical Specifications are indicative of the failure of Management /

t a

management systems and failure of corrective actions provided in response to previously identified violations of regulatory requirements, as described in Inspection Reports No. 454/85016(DRP) and No. 454/85021(DRP) to ensure that Byron's operations are conducted in accordance with regulatory requirements.

7.

Exceeding the Reactor Core Thermal Power Limit (Closed) LER (454/85080-LL):

This LER described events on August 6-7, 1985, while in Mode 1, involving exceeding the reactor core licensed themal power rating.

Licensee personnel monitor reactor core thermal power with 4 channels of Nuclear Instruments (NI).

These channels of " Power Range" NI are calibrated by the performance of a secondary heat balance.

Byron Technical Specification Surveillance 1B05 3.1.1-2, " Calorimetric Calculation Surveillance", accomplished this heat balance.

This procedure compares the heat transferred into the steam generators with the heat transferred out of the stear generators by calculating the enthalpy of the water going in and out times its flow rate.

Based on this heat balance the core thermal power is deterrined and the " Power Range" NI are adjusted so that 100% indicated power is equal to 3411 megawatts thermal (MW).

9

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~

Byron Station Facility Operating License NPF-37, License Condition 2.C(1) states, in part:

"The licensee is authorized to operate the facility at reactor core power levels not in excess of 3411 megawatts themal (100%

power)...."

A licensed operator perfoming the procedure identified that a portion of the feedwater flow rate was not being accounted for.

In Byron's Westinghouse Model "D-4" Steam Generators the feedwater flow is split into two paths. One of these paths, the tempering line feedwater flow rate was not accounted for in the surveillance procedure; consequently, a nonconservative error was introduced into the surveillance and the

" Power Range" NI were adjusted so that indicated power was lower than the actual reactor core power.

Subsequently, licensee personnel reviewed the plant computer records and determined that this error had caused the licensed themal power limit to be exceeded.

The NRC's policy regarding exceeding licensed power levels is that the average power level over any eight hour shift should not exceed the full steady-state licensed power level. While it is pemissible to briefly exceed the full steady-state licensed power level by as mch as 21 for as long as 15 minutes, in no case is it pemissible for 102% power to be exceeded.

Power excursions to less than 102% for periods longer than 15 minutes are pemissible (i.e.,101% for 30 minutes,100.5% for one hour, etc.) provided that the power level, averaged over an eight hour shift, does not exceed 100%.

Reactor core power (ET) was greater than 100% power, averaged over an eight hour shift, on the following three instances:

9 a.

1500 - 2259 on July 26, 1985 - 100.06f/3413 MWT b.

2300 - 0659 on July 27, 1985 - 100.181/3417 MWT

c., 0700 - 1459 ou July 27, 1985 - 100.30f/3421 WT.

Additionally, the average reactor core power equaled or exceeded 100.5%

for greater than one hour on two instances:

a.

2221 - 0013 on July 26, 1985 - 100.50f/3428 MWT b.

0924 - 1105 on July 27, 1985 - 100.681/3434 MWT.

The failure to maintain reactor core power less than or equal to 3411 MWT is an apparent violation of Facilit Condition 2.C(1) (454/85042-06(DRP)y Operating License NPF-37 License

).

Additionally, the licensee failed to submit a written report of this event within the 30 day time limit requirement of Facility Operating License NPF-37, License Condition 2.F.

Both this apparent violation and the apparent violation described in i

Paragraph 3 are examples of licensee personnel failing to correctly prepare surveillance procedures and licensee management failing to adequately review surveillance procedures to ensure that all applicable safety analysis conditions had been satisfied.

i 10

8.

Enforcement Conference Scheduled For November 22, 1985 An enforcement conference is scheduled for November 22, 1985, to be held at the Region III office.

The inspectors met with licensee representatives on October 28, 1985 and summarized the purpose and scope of the inspection and the apparent findings.

The inspectors discussed the likely informa-tional content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents / processes as proprietary.

9.

Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations.

Unresolved items disclosed during the inspection are discussed in Paragraphs 3 and 4.

~

10.

Open Iters Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspectors, and which involve some action on the part of the NRC or licensee or both.

Open items disclosed during the inspection are discussed in Paragraphs 3 and 4.

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U. S. NUCLEAR REGULATORY C0t941SSION REGION 111 Report No.: 50-454/85043(DRP)

Docket No.: 50-454 License No.: NPF-37 Licensee:

Comonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name:

Byron Station, Unit 1 Inspection at: Byron Station, Byron, IL Inspection Conducted:

October 2 - 31, 1985 Inspectors:

J. M. Hinds, Jr.

P. G. Brochman R. M. Lerch J. A. Malloy k k.

W N/

/

y/ yl/-[

Approved By:

W. L. Forney, Chief Reactor Projects Section IA Date Inspection Sumary 9

Inspection on October 2 - 31, 1985 (Report No. 50-454/85043(DRP))

Areas Inspected:

Routine, unannounced safety inspection by the resident inspectors and 2 regional inspectors of licensee action on previous inspection findings; 10 CFR Part 21 reports; operations sumary; LERs; surveillance; maintenance; operational safety and ESF walkdown; IENs; event followup; licensee actions concerning suspected drug use; licensee personnel changes; Comissioner's tour; management meetings and other activities. The inspection consisted of 111 inspector-hours onsite by 4 NRC inspectors including 16 inspector-hours during off-shifts.

Results: Of the 11 areas inspected, no violations or deviations were identified in 10 areas; one apparent violation was identified in the remaining area (failure to follow Technical Specification Action Requirements -

Paragraph 5.c) This apparent violation concerns the failure to place the unit in the required Mode when both trains of an ESF system [ Control Roon Ventilation (VC)]wereinoperable.

This apparent violation is considered to be of safety significance when viewed collectively with other examples of inadequate management controls addressed in NRC Inspection Report No. 50-454/

85042.

O

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DETAILS 1.

Persons Contacted Commonwealth Edison

T. Maiman, Manager of Projects t

'#K. Graesser, Division Vice President, Nuclear Stations

V. Schlosser, Project Manager

'#R. Querto, Station Manager

R. Ward, Services Superintendent

R. Tuetken, St,artup Superintendent

R. Pleniewicz, Production Superintendent

'#L. Sues, Assistant Superintendent, Operations

1. 3. Schwartz, Assistant Superintendent, Maintenance

1. T. Joyce, Assistant Superintendent, Technical Services

T. Tulon, Operating Engineer, Unit I

D. Brindle, Operating Engineer, Unit 2

D. St. Clair, Operating Engineer, Rad Waste

K. Ainger, Nuclear Licensing 1.dministrator

F. Palmer, Manager, Nuclear Safety

D. Berg, Nuclear Safety Staff R. Burkamper, Quality Assurance Supervisor, Operations

S. Nosko, Quality Assurance Engineer

1. A. Chernick, Compliance Supervisor

M. Snow, Assistant Compliance Supervisor

F. Hornbeak, Technical Staff Supervisor

R. Flahive, Assistant Technical Staff Supervisor

J. VanLaere, Rad-Chem Supervisor

D. Robinson, Onsite Nuclear Safety 9

'#J. Langan, Compliance Staff

E. Little, Compliance Staf f J. Cook, Licensing Staff The inspectors also contacted and interviewed other licensee and contractor personnel during the course of this inspection.

Denotes those present during the management meeting on October 10, 1985.

Denotes those present during the exit interview on October 31, 1985.

2.

Action on Previous Inspection Findings (92702)

(Closed) Violation (454/85021-01(DRP)):

Failure to perform Technical Specification Surve111ances when required.

The inspector reviewed the licensee's response and verified that an information management system had been implemented in the Radiation-Chemistry office to maintain the status of Radiation Monitors which are out-of-service and that the compensatory samples required by Technical Specifications were identified.

The inspector reviewed the " Operating Clarification" that was issued to identify when valves can be declared operable following maintenance. The inspector has no further questions regarding these corrective actions.

Corrective actions were completed by June 17, 1985.

2

7 3.

10 CFR Part 21 Reoort Followup (92716)

(Closed) 10 CFR Part 21 Report (454/84008-PP):

Problems with radiographs of branch connection welds which were covered by reinforcing pads in piping manufactured by Southwest Fabricating & Wel_dtng Company.

The inspector reviewed the licen'see's evaluation of the suspect, radiographs, which stated that there were no indications of " surface irregularities which could qsk weld defects".

Pased on the licensee's evaluation of this problem the inspector has no further concerns and this item is considered closed.

4.

Summary of W erations The unit operated at powt r levels up to 92% until 0352 on October 9, c 1985, when the reactor tripped on Reactor Coolant Loop ID Low Flow (see Paragraph 9.b).

The unit was.taken critical at 1618 and was tied to grid at 2130. The unit contin 0ed whe,to operate at power levels up to 92% until 2000 on October 25, 1985, n it was shutdown for a 51 day planned outage.

5.-

Licensee Ever.t Report (LER) Followup (90712 & 92700) a.

(Closed).LERs (454/85084-LL; 454/85088-LL): An in-office review was conducted for the following LERs to determine that the reporting req'ufreinents were fulfilled, immediate corrective action was accomplished and corrective action to prevent recurrence had been accomplished.in accordance with Technical Specifications.

LER No.

Title o

l:

454/85084 Delayed Fire Watch Due To Key Stuck In Vital Area Door Lock 454/85088 Auto Start Of OB VC M/U Fan

~

No violations or deviations were identified.

b.

(Closed) LERs (454/85086-LL; 454/85087-LL): Through direct observation, discussions with licensee personnel, and review of records the following LERs were reviewed:to determine that the reporting requirements were fulfilled, immediate corrective action was accomplished and corrective action to prevent recurrence had been accceplished in accordance with Technical Specifications.

LER No.

Title 454/85086 '

Environmentally Unqualified Terminal Strips l

In MSIVs 454/85087 irire Watches Nat Promptly Initia'ted On Surveillance Fntlure No violatiora or deviations were identified.

e 3

i

.s

c.

(Closed) LER (454/85089-LL):

This LER described an event on September 5 - 13, 1985, while in Mode 1, involving the failure to place the unit in the applicable Mode when Trains OA and/or DB of Control Room Ventilation (VC) were inoperable.

On September 5, 1985 licensee personnel from the Project Construction Department (PCD) installed a blank-off plate in the VC Train OA Make-up (M/U) unit ductwork. This plate was installed as part of a Permanent Facility Modification #M6-0-84-242 and was intended to replace Temporary Alteration # MAS 4-0-354.

The PCD personnel misinterpreted the drawings for the VC ductwork and installed the new blank-off plate in the wrong location. The blank-off plate installed in the correct location by the Temporary Alteration was then removed. As a result, Train OA was inoperable though this condition was not recognized by licensee operating personnel. Technical Specification 3.7.6 states, in part: "Two independent Control Room Ventilation Systems shall be OPERABLE.

While in Modes 1 - 4, with one Control Room Ventilation System inoperable, restore the inoperable system to OPERABLE status in 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ..."

The failure of the PCD personnel to install the blank-off plate correctly resulted in Train OA being inoperable for greater than 7 days and with this condition unknown action was not taken to place the unit in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The failure to place the unit in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is an apparent violation of Technical Specification 3.7.6 and an example of the failure of management controls necessary to assure compliance with the Technical Specifications (454/85043-01a(ORP)). Additionally, PCD personnel failed to follow required procedures by not notifying the Shif t Engineer when the Temporary Alteration was removed.

9 At 1820 on September 12, Train OB was shutdown for maintenance and Train OA started. The maintenance on Train OB required that the

power for damper OVC16Y be secured.

Licensee personnel failed to recognize that this also removed power to damper OVC172Y which then failed shut, making Train OB inoperable. At this point both Trains OA and OB were inoperable, though this condition was not recognized by licensee operating personnel.

Technical Specification 3.0.3 states, in part: "When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, I

within I hour action shall be initiated to place the unit in a M3DE l

in which the specification does not apply by placing it, as l

applicable, in:

a.

At least ll0T STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , b.

At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ...."

At 0700 on September 13, licensee personnel were unable to maintain the required positive 1/8 inch H O differential pressure for the 2

contrcl room and operaters began inspectine Train OA to identify the l

cause of the problem. At 1000, the incorrectly installed blank-of f plate was located and Train OA was declared inoperable. Operators then switched VC to Train 08. With Train OB also unable to maintain the required differential pressure, licensee personnel discovered 4

l

that damper OVC172Y was de-energized and Train OB was declared inoperable.

By 1052 damper OVC172Y was re-energized and Train OB was now operable.

By 1320 the blank-off plate had been relocated to its correct location and Train OA was now operable.

With Train OA inoperable due to PCD's installation of the blank-off plate in the wrong location and Train OB inoperable due to the failure of licensed operators to recognize that damper OVC172Y would fail shut when the power supply to damper OVC16Y was secured, Technical Specification 3.0.3 should have been entered and: 1) action should have been initiated in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit on HOT STANDBY; 2) the unit should have been placed in HOT STANDBY in the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; and 3) the unit should have been placed in HOT SHUTDOWN in the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Consequently, Trains OA and OB were both inoperable for 16.1 hours1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The failure to accomplish these actions within the required times is an apparent violation of Technical Specification 3.0.3 and an example of the failure of management controls necessary to assure compliance with the Technical Specifications (454/85043-01b(DRP)).

The licensee's review of records indicated that the VC system was never called upon to actuate during the time it was inoperable. As corrective action in response to previously identified problems, the licensee developed a list of components (pumps, valves, dampers, etc.) and their respective electrical isolation points (breakers, switches, fuses, etc.) and a corresponding list of all components powered from a common electrical isolation point. These lists were available to operators before this event occured. Following discussions with licensee personnel the inspector expressed a concern that these lists did not appear to contain all the necessary information for all Technical Specification related components.

a This concern will be followed as an Open Item (154/85043-02(DRP)).

This apparent violation is being considered as an additional example of the failure of management controls necessary to assure compliance with the Technical Specifications which is described in Inspection Report 454/85042-04(DRP); this additional example will be discussed at the Enforcement Conference on November 27, 1985, together with the 3 examples previously described in Inspection Report 454/85042(DRP).

6.

0)erational Safety Verification and Engineered Safety Features System

( ESF) Walkdown (71707 & 71710)

The inspectors observed control room operation, reviewed applicable logs and conducted discussions with control room operators during the month of October. During these discussions and observations, the inspectors ascertained that the operators were alert, cognizant of plant conditions <,

attentive to changes in those conditions, and took prompt action when appropriate. The inspectors verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected components. Tours of the auxiliary, turbine and rad-waste buildings were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks and excessive vibration and l

5

to verify that maintenance requests had been initiated for equipment in need of maintenance.

The inspectors verified by direct observation and interviews that the physical security plan was being implemented in accordance with the station security plan.

f The inspector observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection controls. During the month of October, the inspectors walked down the accessible portions of the Safety Injection and Chemical and Volume Control systems to verify operability. The inspector also witnessed portions of the radioactive waste system controls associated with radwaste shipments and barreling These reviews and observations were conducted to verify that facility operations were in accordance with the requirements established under l

technical specifications,10 CFR and administrative procedures.

~

No violations or deviations were identified.

7.

Monthly Maintenance Observation (62703)

Station maintenance activities of safety related systems and components listed below were observed / reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides and industry codes or standards and in confonnance with Technical Specifications.

The following items were considered during this review:

the limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the o

work; activities were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and, fire prevention controls were implemented. Work requests were reviewed to detennine status of outstanding jobs and to assure that priority is assigned to safety l

related equipment maintenance which may affect system performance.

l The following maintenance activities were observed / reviewed:

IB Diesel Generator 18-month inspection.

No violations or deviations were identified.

8.

Monthly Surveillance Observation (61726)

The inspector observed Technical Specifications required surveillance l

testing on a Pressurizer Pressure Controller Circuit and a Steam l

Generator Steam Flow /Feedwater Flow Mismatched Circuit and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that limiting conditions for operation were met, that removal and restoration of the affected components were l

6 L

accomplished, that test results conformed with Technical Specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personnel.

No violations or deviations were identified.

9.

Onsite Followup of Events at Operating Reactors (93702) a.

General The inspector performed onsite followup activities for events which occurred during October 1985. This followup included reviews of operating logs, procedures, Deviation Reports, Licensee Event Reports (where available) and interviews with licensee personnel.

For each event, the inspector developed a chronology, reviewed the functioning of safety systems required by plant conditions, reviewed licensee actions to verify consistency with procedures, license conditions and the nature of the event. Additionally the inspector verified that licensee investigation had identified root causes of equipment malfunctions and/or personnel error and had taken appropriate corrective actions prior to plant. restart. Details of the events and licensee corrective actions developed through inspector followup are provided in Paragraphs b and c below.

b.

Reactor Trip on Low Reactor Coolant Flow on October 9,1985 While in Mode 1, with reactor power at 92%, the reactor tripped on

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Low Flow (less than 90%) in Reactor Coolant (RC) loop 10. At 1221 on October 8,1985, RC loop ID flow channel IFI-444 was declared inoperable and placed in the tripped condition.

Instrument mechanics had installed a new transmitter and were venting the transmitter high pressure side vent per Byron Instrument Surveillance BIS 3.1.1-201, " Surveillance Calibration of a Reactor Coolant Flow Loop", Step F.19.1.

The flow in each RC loop is sensed I

by 3 separate transmitters. Each transmitter has a separate low pressure tap; however, all 3 transmitters share a' common high pressure tap. The venting of transmitter IFI-444 induced a pressure oscillation in the common high pressure tap. This caused RC loop 10 flow transmitter IFI-446 to trip and made up the 2 out of 3 coincidence logic for RC flow less than 90% for RC loop 10. With reactor power greater than permissive P-8 (30%) the low flow in 1 out of 4 RC loops resulted in a reactor trip.

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The licensee's investigation has not yet been completed.

Licensee will perform testing during the October 25 outage to determine if it is possible to vent a transmitter without tripping a second transritter.

The licensee has initiated an A: tion Item Record, AIR 6-85-361, to track this investigation.

As temporary corrective action the licensee has decided not to perform this surveillance at power, pending completion of the investigation. The licensee's permanent corrective action and 7

I

4 evaluation of this event will be reviewed in a subsequent report when the LER is issued.

c.

Unusual Event on October 23, 1985 While in Mode 1, with reactor power at 92%, an Unusual Event was declared when unidentified Reactor Coolant System (RCS) leakage exceeded 1 gpm. At 0600 unidentified RCS leakage was determined to be 1.74 gpm.

Operators were dispatched to measure the leakage of the ID Reactor Coolant Pump (RCP) Seal Injection Flow Transmitter, which was believed to be leaking. At 0712 the licensee declared an Unusual Event. By 0815 the ID RCP Seal Injection Flow Transmitter and the IB RCP Seal Injection Filter vent and drain valves had been isolated and a subsequent surveillance verified that unidentified RCS leakage was less than I gpm. The Unusual Event was terminated at 0950. This event will be reviewed in a subsequent report when the LER is issued.

No violations or deviations were identified.

10.

IE Inforretion Notice (IEN) Followup (92717)

The inspector reviewed the Byron Station program for the receipt, review, and corrective actions regarding IENs. Copies of all IENs are sent to licensee corporate offices and to the Byron Station. The Nuclear Licensing Administrator (NLA) office in the corporate headquarters is responsible for assigning responsibilities for IEN review. The station handling of IENs is governed by Byron Administrative Procedure BAP 1260-1, " Operating Experience Feedback". The station copy was on file for all IENs except 85-01 (85-01 applies to licensee's with irradiators

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that are not self-shielding).

In accordance with BAP 1260-1, IENs are normally routed through to the Assistant Superintendent level. The inspector reviewed the station files of IENs for numbers 85-01 through 85-45. The routing pages indicated appropriate review for inforvation and distribution of the IENs.

Each IEN file was examined for the assignment from NLA and the site response where appropriate. Of 45 IEN files, 29 were appropriate for site review and other organizations were assigned to review the remaining IENs. During the inspection, no site l

response could be found for IEN 85-27. The licensee indicated that the l

site was assigned review responsibility, however, the IEN could not be found. The inspector considers this an isolated occurrence. The site response was filed in the other 28 IENs. Overall the file responses appeared adequate. In addition, a recent draft report of a licensee audit l

of two selected IEN corrective actions was reviewed.

In both cases, corrective actions were implemented. The inspector concluded that, overall, the site review of IENs is adequate, and that appropriate corrective actions are being implemented.

No violations or deviations were identified.

11. Licensee Actions Concerning Suspected Drug Use (99014) a.

Concern:

On September 18, 1985, the licensee notified the Senior l

Resident Inspector of an concern received related to suspected drug l

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use. This concern was received in the fom of a phone call from a knowledgeable citizen to the Industrial Relations Supervisor at the Ceco Corporate Offices in Chicago. The caller identified an employee at Byron Station whom the citizen had reason to believe may be using drugs. The employee named in this concern was a non-management, non-licensed administrative employee W.ose duties and assignments do not involve safety related work. The caller agreed to supply additional infomation as required to support CECO's investigation of the concern.

i Findings:

In keeping with the licensee's drug awareness program on September 19, 1985, the individual was relieved of all duties at the Byron Station, the individual's photo identification security badge and access key-card were revoked and the individual was imediately removed from the payroll pending the outcome of an investigation, counseling and chemical testing for drugs. The individual was interviewed by senior Employee Assistance Program (EAP) and medical personnel. The individual initially refused to participate in the EAP.

Following a second interview and discussion with EAP personnel, the individual elected to join the EAP and participate in the Rockford Memorial Hospital (RMH) Addiction Treatment Education Program (ATEP).

A month later, an Employer Conference attended by Byron Station managers, supervisors, union representative, the individual's attorney and the individual, was held at RMH to review the individual's progress towards recovery and it was detemined that the individual should be returned to fit-for-duty status. The individual was also advised of a six month probationary status requiring participation in the RMH ATEP as an out-patient, counseling on a periodic basis o

with the Rock River Division EAP personnel and random spot check urinalysis testing for drugs.

Based on the individual's acceptance of the terms of the probationary status, on October 30, 1985, the individual was readmitted to the iite, rebadged and returned to full duty.

Failure on the part of the individual to complete the RMH ATEP participation counseling program or pass the urinalysis tests would result in termination without further cause. This concern is considered closed.

b.

Allegation Followup In response to alleged drug and alcohol use in the parking lots and areas of the power plant received by the licensee on June 13, 1985, the licensee developed and implemented an action plan to investigate and disposition these allegations. The details of the NRC inspectors' investigation of the alleged drug and alcohol use are documented in I&E Inspections Reports 454/85025(DRP)and 455/85021(DRP).

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A feature of the licensee's action plan included unannounced periodic random searches of the licensee's power plant property using narcotics detection trained dog teams. On October 3, 1985, a search of this nature was conducted by Byron Security personnel and three drug detector dog teams. The dog teams were accompanied by representatives from Byron Station, CECO Security, Wackenhut Security, Union Stewards and the Ogle County Sheriff's Departnent.

The three dog teams conducted searches including contractor offices and storage; CECO receiving warehouse and offices; radwaste and service building; and employee parking lots.

In all the areas searched, the dog teams did not discover any illegal drugs, substances, or paraphernalia. Therefore this allegation remains closed.

No violations or deviations were identified.

12. Personnel Changes On September 30, 1985 the licensee shifted the station organization to that of Commonwealth Edison's standard operating nuclear station and the following personnel were assigned to the positions indicated:

R. Querio, Station Manager R. Pleniewicz, Production Superintendent R. Ward, Services Superintendent L. Sues, Assistant Superintendent, Operations G. Schwartz, Assistant Superintendent, Maintenance T. Joyce, Assistant Superintendent, Technical Services T. Tulon, Operating Engineer, Unit 1 D. Brindle, Operating Engineer, Unit 2 Y

R. Blythe, Operating Engineer, Unit 0 D. St. Clair, Operating Engineer, Rad Waste F. Hornbeak, Technical Staff Supervisor 13.

Commissioner's Tour on October 16, 1985 NRC Commissioner Lando W. Zech and David Humenanski accompanied by Region III Administrator James G. Keppler, W. L. Forney, Chief, Reactor Projects Section 1A and the Resident Inspector staff toured Byron Unit 1 and met l

with licensee station and corporate renagement. The overall facility status and licensee performance in the areas of integrated plant operations, radiological controls and regulatory compliance were discussed during the meeting.

14. ManagementMeeting(30702)

On October 10, 1985, Mr. W. L. Forney, Chief, Reactor Projects Section IA, and the NRC resident inspector staff met with licensee nanagement and supervisory personnel denoted in Paragraph I of this report..These reetings were held to assess overall facility status, plant operations and to discuss agenda items which had developed since issuance of the operating license.

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15. Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. An open item disclosed during the inspection is discussed in Paragraph 5.c.

t 16.

Exit interview (30703)

The inspectors met with licensee representatives denoted in Paragraph 1 at the conclusion of the inspection on October 31, 1985. The inspectors summarized the purpose and scope of the inspection and the findings. The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents / processes as proprietary.

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ML20197J575

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