ML20198H642
| ML20198H642 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 01/27/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20198H597 | List: |
| References | |
| 50-454-86-01, 50-454-86-1, 50-455-86-01, 50-455-86-1, NUDOCS 8601310070 | |
| Download: ML20198H642 (52) | |
See also: IR 05000454/1986001
Text
SALP 5
SALP BOARD REPORT
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
50-454/86001; 50-455/86001
Inspection Report Nos.
Commonwealth Edison Company
Name of licensee
Byron Nuclear Station, Units 1 & 2
Name of Facility
May 1, 1984 through October 31, 1985
Assessment Period
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0601310070
PDH 060127ADOCK 05000404
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I. INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect available observations and data on
a periodic basis and to evaluate licensee performance based upon this
information. The SALP program is supplemental to normal regulatory
processes used to ensure compliance to NRC rules and regulations. The
SALP program is intended to be sufficiently diagnostic to provide a
rational basis for allocating NRC resources and to provide meaningful
guidance to the licensee's management to promote quality and safety of
plant construction and operation.
An NRC SALP Board, composed of staff members listed below, met on
December 11, 1985, to review the collection of performance observations
and data to assess licensee performance in accordance with the guidance
in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance."
A summary of the guidance and evaluation criteria is provided in Section II
of this report.
This report is the SALP Board's assessment of the licensee's safety
performance at Byron Nuclear Station, Units 1 and 2, for the period
May 1, 1984 through October 31, 1985. Licensee activities over the
assessment period include Unit 1 preoperational, startup, and operational
phases and also Unit 2 construction and preoperational phases. For the
purposes of evaluation, the functional areas fall into three general
categories. The first category addresses Unit 1 as an operating facility
and covers the period of October 31, 1984 through October 31, 1985.
Functional areas A., and C. through E. in Section III of this report
identify the areas evaluated in this category. The second category
addresses Unit 1 and Unit 2 preoperational and startup functional
areas which are common to both Unit 1 and Unit 2 and covers the entire
assessment period. Functional areas B. and F. through K. in Section III
of this report identify these areas. Unit 1 and Unit 2 functional areas
for construction are addressed in the third category identified by
functional areas L. through Q. in.Section III of this report. The
evaluations of these areas also spans the entire assessment period.
SALP Board for Byron Station, Units 1 and 2:
Name Title
C. E. Norelius Director, DRP
J. A. Hind Director, DRSS
L. A. Reyes Branch Chief, DRS '
W. D. Shafer Branch Chief, DRSS
W. L. Axelson Branch Chief, DRSS
R. F. Warnick Branch Chief, DRP !
W. L. Forney Section Chief, DRP l
M. A. Ring Section Chief, DRS !
L. R. Greger Section Chief, DRSS
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M. Schumacher Section Chief, DRSS
M. P. Phillips Section Chief, DRSS
I L. N. 01shan Project Manager, NRR
J. M. Hinds Jr. Senior Resident Inspector, DRP
P. G. Brochman Resident Inspector, DRP
R. M. Lerch Project Inspector, DRP
J. L. Belanger Reactor Inspector, DRSS
C. A. VanDenburgh Reactor Inspector, DRS
N. A. Nicholson Reactor Inspector, DRSS
T. J. Ploski Reactor Inspector, DRSS
K. R. Ridgway Reactor Inspector, DRP
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II. CRITERIA
The licensee's performance is assessed in selected functional areas,
depending upon whether the facility is in a construction, preoperational,
or operating phase. Functional areas normally represent areas significant
to nuclear safety and the environment. Some functional areas may not be
assessed because of little or no licensee activities, or lack of meaningful
observations. Special areas may be added to highlight significant
observations.
One or more of the following evaluation criteria were used to assess each
functional area.
1. Management involvement and control in assuring quality
2. Approach to the resolution of technical issues from a safety
standpoint
3. Responsiveness to NRC initiatives
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4. Enforcement history
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5. Operational and Construction events (including response to, analyses
of, and corrective actions for) '
6. Staffing (including management)
7. Training effectiveness and qualification
However, the SALP Board is not limited to these criteria and others may
have been used where appropriate.
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Based upon the SALP Board assessment, each functional area evaluated is
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classified into one of three performance categories. The definitions of
these performance categories are:
Category 1: Reduced NRC attention may be appropriate. Licensee management
i attention and involvement are aggressive and oriented toward nuclear safety;
licensee resources are ample and effectively used so that a high level of
performance with respect to operational safety and construction quality is l
being achieved.
Category 2: NRC attention should be maintained at normal levels. Licensee
management attention and involvement are evident and are concerned with
nuclear safety; licensee resources are adequate and are reasonably l
l effective such that satisfactory performance with respect to operational l
l safety and construction quality is being achieved.
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Category 3: Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers
nuclear safety, but weaknesses are evident; licensee resources appear to
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be strained or not effectively used so that minimally satisfactory
performance with respect to operational safety and construction is being
achieved.
Trend: The SALP Board has also categorized the performance trend in
each functional area rated over the course of the SALP assessment period.
The categorization describes the general or prevailing tendency (the
performance gradient) during the SALP period. The performance trends
are defined as follows:
Improved: Licensee performance has generally improved over the course of
the SALP assessment period.
Same: Licensee performance has remained essentially constant over the
course of the SALP assessment period.
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l Declined: Licensee performance has generally declined over the course of
l the SALP assessment period.
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III. SUMMARY OF RESULTS :
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Byron SALP 5 incompasses activities in 17 functional areas during all, or ,
part, of the 18 month assessment period. The licensee's performance was -
acceptable in the construction activities which continued from the previous
assessment period. However, performance in functional areas involving Unit 1
operations demonstrates significant weaknesses. Although the licensee
is considered capable, continued management action is needed in order
to assure acceptable performance.
Rating Last Rating This
Functional Areas _
Period Period Trend
A. Plant Operations NR 3 None*
B. Radiological Controls 2 3 Same
C. Maintenance NR 2 Same i
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D. Surveillance NR 3 Declined
E. Initial Fuel Loading NR 1 N/A i
F. Preoperational Testing 3 2 Same ;
and Startup Testing '
G. Fire Protection 3 2 Improved
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H. Emergency Preparedness 2 1 Improved
I. Security 2 3 Declined
J. Quality Programs and 2 2 Same
Administrative Controls
K. Licensing Activities 2 2 Same
L. Containment and 2 2 Same !
Other Safety-Related
Structures
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M. Piping Systems 2 2 Same i
and Supports
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N. Safety-Related 2 2 Same
Components !
0. Support Systems 2 NR N/A
P. Electrical Power Supply 2 2 Same
and Distribution
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Q. Instrumentation and 2 2 Same
l Control System
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NR = Not rated because of limited work or inspection activity.
- Discernable improvement was observed since the end of the
summer of 1985.
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IV. PERFORMANCE ANALYSIS
A. Plant Operations
1. Analysis
l Licensee activities in this functional area were observed in
33 inspections. Two inspections were conducted by region based
inspectors to determine the adequacy of the test and experiments
program. The test and experiments program was defined by
documented procedures for control of activities; however, no
work had been performed in this area at the time of these
inspections. Thirty-one inspections were conducted by resident
I inspectors. The inspectors observed control room operation;
! reviewed applicable logs; conducted discussions with control
room operators; ascertained that the operators were alert,
cognizant of plant conditions, attentive to changes in those
conditions, and took prompt action when appropriate; verified
the operability of selected emergency systems; reviewed tagout
records; verified proper return to service of components; toured
the plant to observe plant equipment conditions, including
potential fire hazards, fluid leaks, excessive vibration, and
to verify that maintenance requests had been initiated for
maintenance; verified by observation and interviews that the
physical security plan was being implemented; observed plant
housekeeping / cleanliness conditions; verified implementation
of radiation protection controls; and witnessed portions of the
radioactive waste system controls associated wit 1 radwaste
shipments and barreling. These reviews and observations were
conducted to verify that facility operations were in accordance
with the requirements established by Technical Specifications,
the Code of Federal Regulations and administrative procedures.
Nine violations were identified:
a. Severity Level IV - Both ECCS subsystems were rendered
inoperable as a result of a procedural violation involving
valvealignment(ReportNo. 454/85002).
b. Severity Level IV - Overtemperature Delta T and Overpower
Delta T channels inoperable in Mode 2 due to NTC circuit
cardsnotbeingseismicallyqualified(ReportNo. 454/85002).
c. Severity Level V - Failure to follow administrative
p(rocedures for controlling overtime (four examples)
Report No. 454/85009),
d. Severity Level IV - Failure to implement the required
procedures upon entry into a LCO and failure to de energize
the PORV block valves in the closed position within one
hour (ReportNo. 454/85016).
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e. Severity Level IV - Failure to follow operating and
administrative procedures iesulting in the Refueling
Water Storage Tank being inoperable for four hours
(ReportNo. 454/85030).
f. Severity Level IV - Failure to monitor the indicated Axial
Flux Difference (AFD) hourly for ten hours following the
restoration to OPERABLE status of the AFD Monitor Alarm
(ReportNo. 454/85039),
g. Severity Level III - Operation of the Emergency Core
Cooling System such that a portion could not have
performed its intended safety function and failure to
follow the applicable Technical Specification Action
Requirements (Report No. 454/85042),
h. Severity Level III - Failure of management controls
necessary to assure compliance with the Technical
Specifications (fourexamples)(ReportNos.454f85042
454/85043).
1. Severity Level IV - Inadequate procedure utilized for
calculating the reactor core thermal power (Report
Nos. 454/85042; 454/85056).
The above violations directly involved plant operation; however,
other violations which indicate direct or indirect involvement
by plant operations are discussed in other functional areas of
this report.
An enforcement conference was held after the closure of the
assessment period to discuss the facts and significance of
violations g., h., and 1. NRC enforcement action is presently
under review.
InreviewingtheLicenseeEventReports(LERs)issuedoverthe
assessment period it has been determined that plant operations
have been subject to numerous personnel errors, and other
Technical Specification violations. Over the period, the
licensee was involved in 137 events for which LERs were required,
resulting in a monthly average of approximately 11.5 which is
considered excessive.
An assessment of a sample of LERs found them to be generally of
acceptable quality based on the requirements of 10 CFR 50.73.
It appears, however, that the large number of personnel
involved in preparing LERs results in a wide diversity in
quality. The low quality in some LERs reduced the assessment
of LERs to an overall quality that was average.
! Anexcessivenumberofreactortrips(31)wasrecordedduring
l the assestment period. Of these, four were planned as part of
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the startup test program engineering tests, eight were attributed
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l to personnel errors, four were the result of procedural
deficiencies, seven were related to design / manufacturing /
installation, two were attributed to external / natural phenomena,
and for six, the cause was not identified.
Based on Region III management's concern with of the licensee's
performance immediately following issuance of the operating
license, Region III management began to meet with Byron Station
managers to review licensee performance and NRC findings and
observations of plant operations. The management meetings were
held on a monthly basis beginning in December 1984 and continued
through the end of the assessment period. These management
meetings centered on the licensee's performance and corrective
actions to reduce personnel errors, reactor trips, and missed or
unsatisfactory surveillances. Surveillances are discussed as a
functional area in Section IV.D of this report. A number of
violations listed in the functional area of Surveillance also
involve plant operations personnel and are also applicable to this
functional area.
In response to the NRC concerns expressed in the monthly
management meetings, the licensee developed and implemented the
" Conduct of 0)eration Improvement Program" for the Byron Station.
Features of t1e program include imnroved communication and
awareness of trends and problem areas thrcugh production of a
Monthly Plant Status Report; " Increased Shift Overview
Superintendent (505) Involvement." " Technical Staff System
Interaction with Operations," and " Increased Awareness Of
Personnel To Day-To-Day Activities;" actions to reduce the
number of LERs and DVRs; controls to eliminate missed surveill-
ances; and improved housekeeping. The NRC has noted licensee
management's increased responsiveness to this NRC initiative
(monthly meetings) and involvement, as the assessment period ,
progressed, in efforts to identify problem areas and secure
needed improvements in the Plant Operations functional area.
A review of the indicators of management involvement in assuring l
quality indicates that in the area of reportable events, as
documented in LERs the 1985 average stands at nine per month
and although the trend over the period
hasbeendownoverall(13,10,4,5 from July)through
respectively , continuedOctober l
nanagement attention in thir, area must )e maintained to ensure
that LERs reach minimum achievable levels. Personnel errors l
shcwn :
have been excessively high over the period and have only(9, 6, I '
an improving)
respectively trend over the
. Managenent August
attention must- October
continuetime frame
to be focuse:t ;
in this area to bring personnel errors to the level expected of -
a good performing plant. As discussed in Section IV.D. of this
report, missed or incorrectly performed surveillances involving l
plant operations and operating personnel continue to be a high
percentage of reportable events and will require continued
management attention to bring them under control.
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During the appraisal period, the licensee's administrative
controls over control room activities were challenged by the
increased testing activity, the complexity of activities being
added daily to the operator's shift routine, and the evolution
from piecemeal system / component testing to integrated plant
operation. The licensee's administrative controls for
, maintaining control room discipline have proven to be adequate
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to this point in plant operations. Personnel access controls
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were established for the control room, center desk, and unit .
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licensed operator control console area and have proven !
effective in minimizing licensed operator distraction. Station
management has thoroughly indoctrinated licensed operators
through implementation of corporate directives and plant
procedures which include NRC regulations and guidance on
maintaining order in the control room, the authority and
responsibility of licensed personnel, and the need for
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professional attitudes and conduct at all times. The
effectiveness of station management presence in the operations
control areas is demonstrated, for the most part, by the
absence of distracting or prohibited activity in the control
room or other watch stations. Another indicator of the
atmosphere of professionalism existing in Byron managers and
licensed operators is the willingness to employ a color coded
work uniform program from the station superintendent to the
equipment attendants. The uniforms project a professional air
and thus promote greater professional conduct of operations.
Although the licensed operators of the Byron Station plant
operations staff have been both directly and indirectly
involved in reportable events, the NRC recognizes the high
level of professionalism demonstrated by the conduct of control
room activities related to plant operations and considers the
licensed operator staff to be well trained, highly motivated,
and of the highest quality.
Staffing continues to be a licensee strength. The staff is
stable and well organized with no significant turnover to date,
other than internal promotions and transfers among departments.
Qualifications, education, and experience levels within the staff
are good and should improve with additional experience,
requalification activities, and continued operation. Staffing
levels are high by design to ensure a qualified and experienced
cadre in preparation for Unit 2 integrated plant operations.
During the assessment period, license examinations were
administered to two different groups of candidates. The July
1984 group consisted of 8 senior operator and 6 reactor
operator candidates. The overall pass rate for the group was
78%, which is comparable to the national average of 80% and
indicated an upward trend compared to previous examination
groups.
The Octobe" 1985 group of 8 senior operator and 10 reactor operator
candidates had an overall pass rate of 61%. This is below the
national average and is considered unsatisfactory, and indicated
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that improvement achieved early in the assessment period has not
continued. The licensee should focus more attention to the
screening of candidates to assure that marginal candidates are
not submitted to take the NRC examination.
The licensee generally exhibited a conservative approach to
technical safety issues penalizing unit production on some
occasions to assure compliance to a conservative interpretation
of Technical Specification requirements. Responsiveness to
issues and/or concerns raised by the NRC was, for the most
part, thorough and showed overall a cooperative attitude.
2. Conclusion
The licensee is rated Category 3 in this area based on inspection
findings of high numbers of reportable events, reactor trips,
missed and inadequate surveillances, and personnel errors in
plant operations. The licensee was not rated in this functional
area in the last assessment period.
3. Board Recommendations
NRC and licensee management should continue to focus attention
on the progress of the licensee's programs implemented
to improve regulatory performance and reactor operations.
B. Radiological Controls
1. Analysis
Nine inspections were conducted during this assessment period
by region based inspectors. These inspections included radiation
protection, radioactive waste management, TMI Action Plan Items,
environmental protection, chemistry and radiochemistry, and
confirmatory measurements. Six inspections were conducted while
Unit I was in the preoperational modes, and three operational
inspections were conducted subsequent to fuel load. Unit 2
remained in a preoperational status throughout the assessment
period. The resident inspectors also reviewed this area during
routine inspections.
Seven violations were identified as follows:
a. Severity Level IV - Failure to report air filtration
and absorption unit test nonconformances in accordance
withlicenseequalityassuranceprocedures(Report
No. 454/84066).
b. Severity Level (*) - Inadequate procedures or failure to
follow radiation protection procedures for: (1) restricting
personnel entry into containment while the incore detectors
were withdrawn, (2) providing continual radiation / chemistry
technician (RCT) atten# nce during an emergency containment
entry. (3) providing continual RCT attendance as specified
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on the radiation work permit, (4) exiting a high radiation
area when exceeding administrative doses (two occasions),
(5) adherence to general contamination controls and
personal decontamination methods by workers involved in
work on a contaminated CVCS valve, and (6) providing
positive controls to prevent personnel exiting the station
following activation of portal monitor. alarms (Report
No. 454/85022).
c. Severity Level (*) - Failure to provide adequate
instructions regarding radiological conditions and
precautions to two workers who entered containment for
work on a stuck incore detector (Report No. 454/85022).
d. Severity Level (*) - Failure to make an evaluation of
radiological hazards associated with work on a contaminated
CVCS valve (Report No. 454/85022).
e. Severity Level IV - Failure to have an authorized
procedure addressing a valve lineup to transfer diluted
reactor water from the recycle holdup tanks to the Unit 2
condensate sump. As a result, the sump overflowed (Report
No. 454/85022).
f. Severity Level IV - Failure to follow liquid radwaste
release procedures to positively verify that the required
dilution flow was available (Report No. 454/85038).
g. Severity Level IV - Failure to take timely action when the
Technical Specification Limiting Condition for Operation
(LC0) for liquid radioactive release was exceeded (Report
. No. 454/85038).
- Three violations (b., c., and d.) were classified collectively
These violations appear indicative of programmatic and managerial
failures in radiological evaluations, procedural controls,
training, and effluent release controls. A civil penalty of
$50,000 was proposed for violations, classified collectively as
a Severity Level III problem, involving three separate incidents
which included numerous failings concerning radiological procedure
adherence, procedure adequacy, and evaluation of working conditions.
The enforcement meetings for these incidents stressed a need for
improved supervisory adherence to the licensee's established
radiological control program and improved instructions to
radiation workers. Licensee corrective actions have generally
been timely.
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Inadequate management attention to and involvement in
radiological activities was evident during this assessment period
as indicated by: (1) management's untimely recognition of
potentially serious problems identified during the incore motor
drive repair and at power containment entry incidents,
(2) numerous examples of poor adherence to radiation protection
procedures and good health physics practices by first line
supervisors and professional / technical staff, and (3) management's
initially inadequate investigation into radiologically
significant incidents. Management weaknesses regarding
timeliness in identification and resolution of potential problems
with TMI action items were also evident' An improving trend of
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positive management involvement was observed subsequent to the
enforcement conferences, including higher priority given to
investigating poor performance reports, staff emphasis on
procedural adherence, and increased disciplinary action taken for
flagrant procedural violations. In addition, licensee management
requested an audit of the radiation protection program by
non-station CECO health physics representatives to identify
operational and functional weaknesses. Licensee representatives
began implementing corrective actions for these weaknesses late
in the assessment period. Corporate management involvement,
limited during initial operational phases, also improved during
the period as evidenced by a commitment to investigate
significant radiological occurrences.
Staffing has generally improved during this assessment period.
Startup and operational activities for Unit 1 increased the
workload for the RCT staff, resulting in significant overtime
to meet programmatic needs. In an attempt to supplement the
staff, licensee management directed an additional class of
seven RCTs be trained; this has helped ease the shortage. The
staff has been fairly stable during the assessment period, with
promotions and transfers being the principal reason for personnel
losses. Qualifications meet current industry standards; however,
, the radiation protection staff's operational experience levels
are low as is generally the case at new plants. In accordance
with a generic CECO plant organization change, two intermediate
management positions between the Radiation Protection Manager
(RPM) and Plant Manager were created toward the end of the
assessment period. This is generally considered a weakness
because of the communication barriers it creates between the
RPM and the plant manager.
The licensee has formal training / qualification programs for
RCTs, plant workers, and visitors. Improvements are needed in
the areas of plant systems training for RCTs and procedural
adherence for all plant workers. These weaknesses were clearly
indicated by the RCT staff's lack of awareness of radiological
hazards associated with reactor systems, such as the incore
detectors, and by the repeated procedural violations by the
plant staff during this assessment period.
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The licensee's responsiveness to NRC initiatives has been
inconsistent during this period. Licensee actions have been
acceptable in the areas of radiation seal qualification,
radiation monitor, and ventilation system concerns. The
licensee has resolved most of the TMI Action Item probiems
identified during this assessment period and has proposed
corrective actions for the remainder, although action to resolve
some of the issues was slow. The licensee's reporting of
incidents to the NRC exceeded requirements. Weaknesses
concerning the radiological environmental monitoring program
(REMP) problems which were identified during the previous
assessment period went uncorrected until a few weeks before fuel
load in August 1984. Licensee (corporate) responsiveness to
REMP issues improved considerably following a special NRC REMP
inspection in April 1985 of the licensee's corporate
environmental group. The corporate environmental group was
instructed to place more emphasis on REMP managerent to avoid
problems in the future. In response to NRC concerns regarding
low level licensed material shipped offsite to ncn-licensees,
timely action was taken to recover all material and implement
positive controls to prevent recurrence. The effectiveness of
licensee corrective actions for problems addressed in the civil
penalty could not be ascertained during this assessment period
due to their recent implementation.
The licensee's approach to resolution of radiological technical
issues has been adequate. Personal radiation exposures for the
first eight months operation were approximately 43 person-rems,
reflecting adequate exposure control program design and
implementation. Based on a design analysis, licensee
representatives plan to shield neutron streaming from the
cavity to minimize dose levels near the personnel hatch.
Interim shielding attempts during this assessment period
have not been successful.
Although the operational liquid and airborne effluent programs ,
were not specifically inspected this assessment period, five
unplanned or improper radioactive releases were reported. All
were quantitatively minor, but three were noteworthy because of
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the errors which contributed to the releases. Additional problems
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in this area include inoperability of both the boric acid and
radwaste evaporators and the resin cleanup system until sometime
about early September 1985 when the resin cleanup system became
fully operational and the evaporators became operational
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intermittently, resulting in significant reduction in liquid
, effluent activity. The licensee anticipates elimination of
remaining problems with the evaporators during the current
outage. Use of a vendor resin cleanup system hos been
discontinued but a vendor resin solidification system is still in
use. The licensee unintentionally released low level contaminated
,
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resins to two offsite vendors because the resins were not
adequately monitored before release from the site. All affected
resins were recovered by the licensee and returned to the site
after the problem was identified by the licensee.
Licensee's chemistry / radiochemistry performance was generally
satisfactory during the period. The licensee's policy of
rotating radiation-chemistry technicians (RCTs) between chemistry
and health physics, with resulting long intervals between
laboratory assignments, is a weakness that may limit technician
performance and will require strong management oversight to avoid
performance problems. A full complement of RCTs has satisfactorily
completed an on-the-job certification program in numerous areas
in chemistry and a formal training program, including a water
chemistry control training program. The licensee has issued a
comprehensive water chemistry control directive which directs
each station to develop site specific water chemistry control
parameters. The Chemistry Department is making good progress in
implementing this directive by preparing an extensive list of 54
administrative procedures (BAPs) describing all facets of water
chemistry control to avoid corrosion of the plant. The licensee,
however, had difficulty in maintaining desired secondary chemistry,
particularly during power transients, and has had to impose an
action described in BAP 599-39 requiring reduction in power to
30% within specified time periods. The licensee had developed
plans to make a number of modifications to the secondary system
during a plant outage to resolve some of the problems encountered
and has had to use excessive amounts of hydrazine to remove the
organics present in secondary water systems. Progress in
reducing organics in the secondary systems has been made.
The licensee also has established an adequate QA/QC program
providing RCTs with blind samples of nonradiological chemical
species but has not yet included a similar program for
radiochemistry as discussed in the previous SALP report. The
licensee analyzes radioactive samples from the Zion Nuclear
Plant; results reviewed appeared satisfactory.
2. Conclusion
The licensee is rated Category 3 in this area. This is a lower
rating than was given in the previous assessment period. This
rating is based primarily on the licensee's performance
subsequent to fuel load. During this period, the licensee's
performance in the areas of enforcement, management, radiological
controls, and training were primarily responsible for the
Category 3 rating. Improvements initiated by the licensee near
the completion of this assessment period should improve licensee
performance. Licensee performance has remained the same during
the assessment period.
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3. Board Recommendations
Increase inspection attention in this area.
C. Maintenance
1. Analysis
Activities in this functional area were examined by four
inspections conducted by region based inspectors and portions
of nine inspections by resident inspectors.
Activities covered included the program and implementation
review of maintenance and supporting activities including
calibration, control of test and measuring equipment, design
changes, and modifications. Station maintenance activities of
safety related systems and components were observed and
reviewed to ascertain that they were conducted in accordance
with approved procedures, regulatory guides, industry codes
and standards, and in conformance with technical specifications.
Several weaknesses were identified in the program review in
these areas. The licensee took prompt action to correct the
weaknesses. Activities were performed to approved documented
procedures and procedures were rarely violated. The limiting
conditions for operation were met while components or systems
were removed from service; approvals were obtained prior to
initiating the work; 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 determine the status of
outstanding jobs and to assure that priority is assigned to
safety-related equipment maintenance which may affect system
performance.
Two violations were identified:
a. Severity Level V - Failure to provide appropriate
acceptance limits in instructions, procedures, or drawings
utilized to accomplish battery cell-to-rack end stringer
gaps (Report No. 455/85006).
b. Severity Level IV - Failure to adequately document a
deviation in the operation of the Rod Control System
(Report No. 454/85033).
Work performed was generally technically sound, thorough and
timely. Records were generally complete, well maintained and
available. However, the NRC is concerned that appropriate
management attention and accurate, timely resolution of
maintenance items which have been identified as having minimal
16
safety significance may be a weakness. As evidenced by item b.
above, inadequate documentation and management review of an
operational problem on a nonsafety-related system subsequently
delayed the timely correction of an equipment deficiency which
resulted in the occurrence of multiple rod drops and contributed
to the dissemination of inaccurate information to the NRC.
Aggressive management attention and rigorous evaluation of all
technical issues is required to ensure acceptable equipment
performance.
Although there has been some cross-over between construction
incidents and operational reportable events, the number of LERs
and violations in this area have not been excessive and
management involvement in assuring quality in this area has
been adequate over the period. Upon identifying an area
requiring additional management oversight, the licensee har
provided technically sound resolution with good consideration
of the safety issues involved.
A review of the maintenance organization reveals adequate
manning in all positions with well-trained, moderately
experienced personnel who demonstrate a degree of pride in
their workmanship.
Inspections in the overall maintenance area have provided a
reasonable level of confidence in the administration of a sound
program with adequately documented procedures and records;
however, the effectiveness and timeliness of maintenance
activities could be improved by greater involvement in the
day-to-day inner departmental problems and delays by the upper
levels of managers at the shop head, general foreman, and
foreman levels, thereby enhancing the communication of maintenance
problems at the intra-departmental level. Examples of this
weakness are: (1) two identical cases of reactor trip due to
dropped rods on March 29, 1985 and April 10, 1985; (2) exceeding
the administrative radiation exposure limits for workers while
performing incore detector repairs; (3) reactor trip due to low
lube oil reservoir level; (4) three incidents of dropping the
identical control rod resulting in 2 reactor shutdowns during
startup and one reactor trip from power; and (5) an unusual
event resulting from both trains of control room ventilation
being inoperable.
2. Conclusion
The licensee is rated Category 2 in this area. The licensee
was not rated in this functional area in the previous
assessment period. Licensee performance has remained the
same during the assessment period.
17
3. Board Recommendations
None.
D. Surveillance
1. Analysis
This functional area was examined in two inspections conducted
by region based inspectors and portions of ten inspections
conducted by resident inspectors.
The inspections included a review of the program for the
control and evaluation of surveillance testing including
inservice inspections. Problems were identified in procedures
regarding independent verifications during surveillance
testing. Procedures were revised in an attempt to correct these
probl ems.- Implementation of the surveillance program was also
reviewed and inspectors verified that testing was performed in
accordance with approved procedures, that test instrumentation
was calibrated, that limiting conditions for operation were
met, that removal and restoration of the affected components
were 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 reviewed
and resolved by appropriate management personnel. Work was
generally timely, thorough, and technically sound. Records
were generally complete, well maintained, and available.
Six violations were identified:
a. Severity Level IV - Failure to perform inservice tests
of Unit 1 RHR pumps within the required surveillance
interval; inservice testing to establish pump and/or
system operability using inadequate instrumentation
(Report No. 454/84079).
b. Severity Level IV - Failure to follow surveillance
procedures (Report No. 454/85009).
c. Severity Level IV - Failure to perform a surveillance as
required prior to entry into the applicable operational
mode; failure to perform surveillances prior to returning
components to service; and failure to perform a surveillance
within the required time interval (Report No. 454/85016).
d. Severity Level IV - Failure to perform a surveillance ,
within the required time interval; failure to collect,and ,
analyze reactor coolant sample within the time rsquir?ments .
of Technical Specifications (Report No. 454/850Fh.). '
!
'
18
.-. .-.
e. Severity Level IV - Failure to perform surveillance within
the required time interval; failure to perform surveillance
as required (Report No. 454/85025).
f. Severity Level IV - The Reactor Coolant System water
inventory balance was not performed within the required
surveillance interval (Report No. 454/85039).
Violation "a" involved two discrepancies: (1) failure to i
ensure Residual Heat Removal (RHR) pump operability by
performance of inservice testing within the required
surveillance interval prior to entering Modes 6 and 5; and (2)
use of inadequate instrumentation which exceeded the maximum
allowable range requirements of the licensee's inservice test
program during inservice tests to establish operability prior
to entry into Modes 6 and 5. These two incidents resulted in
operation in Modes 6 and 5 without properly establishing the
OPERABILITY of the RHR pump.
Violation "b" involved two discrepancies: (1) failure to
follow prerequisite steps of a surveillance procedure based on
ad-hoc advice from Westinghouse personnel resulting in a
turbine trip and reactor trip at power; and (2) use of a
surveillance procedure to investigate a turbine impulse
pressure channel indication in a prohibited mode during a
reactor startup which resulted in an additional reactor trip.
These two incidents resulted in two unwarranted reactor trips
due to the failure to observe and follow the stated
prerequisite steps of approved surveillance procedures.
Violation "c" involved three discrepancies: (1) failure to
observe and implement the Technical Specification Action
Statement for six hours in Mode 5 while the emergency power
source for the operable Centrifugal Charging Pump was
out-of-service; (2) failure to de-energize the Pressurizer
Power Operated Relief Valve Block Valves in the closed position
for 1.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in Mode 3 as required by the Technical
Specifications; and (3) failure to place the main Control Room
Ventilation System Train in the makeup mode exceeding time
limits in Mode 5 upon taking radiation monitoring
instrumentation out-of-service for maintenance as required by
the Technical Specifications. These three incidents resulted
in systems / components not being placed in the Action Statement
s required conditions in excess of the time requirements of the
Technical Specifications as a result of failure to observe and
implement the Technical Specification Action Statements.
Violation "c" also involved eight discrepancies which included:
(1) failure to establish an hourly fire watch in Mode 6 from
October 1984 to December 1985, while a replacement ultraviolet
fire detector in the Fuel Handling Building remained untested
to atsure operability by surveillance performance; (2) failure
to perform inservice inspection visual examinations on seven
19
_ _
valves and components prior to returning them to service in
Mode 6; (3) failure to perform required surveillance position
indication testing on a safety injection valve prior to entry
into Mode 3 from January 10 to January 24, 1985; (4) failure to
demonstrate operability of remaining offsite electrical
circuits while one offsite electrical circuit was
out-of-service for maintenance by exceeding the specified time
limits for the initial and subsequent verification while in
Mode 3; (5) failure to demonstrate the capability of 2A Diesel
Generator to supply power to Bus 141 daily in excess of time
limits in Mode 3; (6) failure to perform the quarterly test on
a Containment Isolation Valve in excess of the time limits in
Mode 3; (7) failure to perform the required 31 day operability
test of the Lower Cable Spreading Room CO2 Systet in the months
of January and February, 1985 while in Modes 5 through 1;
(8) failure to perform a Turbine Emergency Trip Header Low
Pressure Reactor Trip Surveillance prior to entry into Mode 2.
These eight incidents resulted in equipment, components and/or
system operability not being certified for periods of time from a
few hours to a few months and resulted from failure to observe,
recognize and implement the Technical Specification Surveillance
requirements.
Violation "d" involved two discrepancies: (1) failure to
perform the isolation time surveillance on 1PR066 while in
Mode 1; and (2) failure tu sample the primary system in excess
of the time limitations following a power level change. These
two incidents resulted in operation in Mode 1 with the operability
of a containment isolation valve not ve. * fied and, exceeding the
time limitations to verify that no reactor coolant radio-chemistry
limits had been exceeded.
Violation "e" involved two discrepancies: (1) failure to
verify that Indicated Reactor Coolant System Average
Temperature and Indicated Pressurizer Pressure were within
specified limits at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from March 27 to
May 5,1985, while in Mode 1; and (2) failure to verify the
above parameters within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> prior to entry into Mode 1 on
5 occasions. These two variations of a.like problem resulted
in lengthy operation in Mode 1 during which time certain key
plant parameters were not being verified as being within the
specified limits as required by Technical Specifications and
were a result of failure to process, review and control a
revision to the applicable surveillance procedure coupled with
the failure to be aware of and implement the appropriate
Technical Specification surveillance requirements prior to
entry into and during operations in Mode 1.
20
- _ - .
"f" involved one discrepancy which resulted in the
~
Violation
failure to perform a Reactor Coolant System Water inventory
balance once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (+25%) from August 16 at 1214 to
August 20, 1985, at 0900. This incident resulted in operations
in Mode 1 for a period of time exceeding the Technical
Specification limits while reactor coolant system leakage went
unmonitored and was a result of a management decision to defer
performance of the surveillance due to interference with a
startup test.
During this assessment period the licensee reported 18 incidents
of missed or inadequately performed surveillances. Of these,
13 were attributed to personnel error, one to design,
manufacturing, construction / installation, and 4 to defective
procedures. Many of these reportable events have resulted in
violation of License Conditions, Technical Specifications, or
NRC Regulations. The NRC recognizes that the licensee's program
encompasses hundreds of surveillance procedure requirements.
Performance of this function has shown a significant increase in
total incident occurrences during the last three months of the
SALP period. Although the rate has been improving, the numbers
of surveillance incidents is considered excessive.
Management involvement in the surveillance function peaked
about two-thirds through the period when the licensee developed
and implemented the Conduct of Operations Improvement Program
(COIP). A feature of the COIP was designed to eliminate missed
surveillances. Based on the findings of NRC inspections over
the last three months of the assessment period it appears that,
although the program is technically sound and has provided
acceptable technical resolutions from a safety standpoint,
management involvement in reducing the numbers of surveillance
incidents, has demonstrated a low level of effectiveness.
The licensee has indicated a willingness to address this issme
in response to NRC concerns expressed in the monthly management
meetings discussed in Section V.E of this report and is devoting
resources to the resolution of the problem through efforts in
the areas of monitoring the surveillance system records,
increasing awareness of the operating staff in the area of
surveillance scheduling requirements, increasing surveillance
scheduling requirements, increasing technical staff awareness
and interaction with the operating staff, and continuing to
monitor and improve the corrective action items designed to
eliminate the problem. However, a review of the recent events
indicates that these changes are apparently slow in being
effective and this indicates a weakness in the program.
2. Conclusion
The licensee is rated Category 3 in this area. The licensee
was not rated in this functional area in the previous SALP.
A significant group of Violations occurred earlier in this
assessment period and another significant group occurred at the
21
__
_
'
1
I
end of this period, in each case demonstrating unacceptable
performance requiring corrective action. Licensee performance
has declined during the assessment period, despite several
Regulatory Performance Improvement Program activities which
were targeted to reducing procedural and personnel errors.
3. Board Recommendations
The licensee should continue to concentrate a high level of
management attention to this functional area to reduce the
number of missed and inadequately performed surveillances.
E. Initial Fuel Loading
1. Analysis
The initial Unit 1 core was loaded between November 2, 1984
and November 27, 1984. The core loading activities, conducted
between November 2 and November 5, 1984, were inspected on a
24 hour-a-day coverage basis by region based inspectors and
resident inspectors. Fuel loading activities between
November 6 and November 27, 1984, were inspected on a routine
basis.
The licensee's fuel loading crew demonstrated a high degree of
training and experience in the performance of their duties
resulting in few NRC observations related to documentation,
preparation, and execution of the fuel load procedures.
No violations or deviations were identif ed in this area.
Delays encountered in the fuel load sequence resulted from
equipment malfunctions including the fuel transfer cart drive
shear pin failures and source range nuclear instrument noise
spiking.
Management involvement in these two problems resulted in
technically sound and thorough resolutions in a timely
fashion employing a high degree of conservatism for the safety
significance in each case. Throughout the NRC inspection of
the fuel load activities, the licensee provided technically
sound and thorough responses to NRC observations resulting in
acceptable resolutions to technical issues brought to their
attention.
2. Conclusion
The licensee is rated Category 1 in this area based on the
overall quality of performance during the fuel loading
sequence. The licensee was not rated in this functional
area in the previous assessment period. Since initial fuel
load is a single evolution, no trend has been established.
22
_ _ _ _ -
3. Board Recommendations
None.
F. Preoperational Testing and Startup Testing
1. Analysis
The preoperational testing and startup testing inspection effort
for Unit 1 consisted of 13 inspections conducted by region based
inspectors, and a portion of 16 inspections by resident inspectors.
The inspections consisted of observations of licensee performance
in implementing administrative controls; in-depth procedure
review, verification, witnessing, and test results review and
verification for both preoperational and startup test procedures;
and observations of corrective actions for problems identified.
There were no violations identified for the Unit 2 preoperational
test program. The preoperational testing inspection effort for
Unit 2 consisted of four inspections by regional based inspectors
and portions of five inspections by resident inspectors. This
is considered very little inspection effort. The startup test
program for Unit 2 has not yet commenced.
Six violations on Unit 1 were identified as follows:
a. Severity Level IV - Failure to adequately test and
evaluate Emergency Core Cooling System (ECCS) remote
valve position indications in the preoperationai test
program (Report No. 454/84055).
b. Severity Level V - Failure to adequately evaluate
the leakage test results of Safety Injection-ECCS
check valves in the preoperational test program
(Report No. 454/84073).
c. Severity Level V - Failure to adequately evaluate
the pump curves of the Boric Acid transfer pumps in
the preoperational test program (Report No. 454/84073).
d. Severity Level V - Failure to adequately test the Diesel
Generator Fuel Oil System in the preoperational test
program (Report No. 454/84073).
e. Severity Level IV - Failure to adequately test the
Auxiliary Power System electrical distribution system
voltages in the preoperational test program (Report
No. 454/85002).
f. Severity Level IV - Failure to adequately evaluate and
document the test results of four separate tests in the
startup test program (Report No. 454/85008).
23
1
A concern with the preoperational test program results review
identified late in the SALP 4 rating period resulted in an
overall assessment of the licensee's performance as Category 3.
Although improvements from the previous SALP period were
initially noted, similar concerns on the adequacy of the
results evaluation of the test program were also noted in this
SALP period as evidenced by items a., b., c. and f. above. An
enforcement conference was held on April 29, 1985, to discuss,
in part, these concerns. Violations a. through f. above,
occurred prior to the enforcement conference. Subsequent to the
enforcement conference, licensee performance in the area of
startup test performance improved as evidenced by three full and
six partial inspections in the startup test area with no violations
noted. It should be noted, however, that subsequent to the
enforcement conference, the startup program was completed on
September 10, 1985 and the fewer violations are, in part, due to
the decreased level of activity in the development of the
preoperational and startup test programs. Continued high
priority and management attention are warranted to assure
attention to detail and rigorous analysis during the
preoperational and startup test programs for Unit 2.
In the SALP 3 rating period, 10 violations consisting of 7
Severity Level IV and 3 Severity Level V items t re identified
over a rating period of 12 months. In the SALP 4 rating
period,15 violations consisting of 4 Severity Level IV and
11 Severity Level V items were identified over a period of
16 months. In the SALP 5 rating period, 6 violations consisting
of 3 Severity Level IV and 3 Severity Level V items were
identified over a period of 18 months. Considering the longer
period for this SALP and the decrease in the number of
violations identified, the licensee's performance has improved.
Staffing (including management) appears to be adequate and the
licensee remains responsive to NRC concerns and initiatives.
Training effectiveness and the qualification of test personnel
was satisfactory and showed a marked improvement over the
previous SALP rating period. The effectiveness of staffing,
training and the qualification of personnel remains to be
demonstrated during the preoperational test program of Unit 2.
New personnel will be involved in this test program and the
effectiveness of the transfer of knowledge and experience must
be closely monitored to ensure continued satisfactory
performance in these areas.
The licensee's resolutions and management involvement in
technical issues identified in the course of the performance of
the startup program placed sufficient emphasis on the safety
significance of issues identified in the performance and review
of test results.
24
2. Conclusion
The licensee is rated Category 2 in this area. This is a
higher rating than was given in the previous rating period.
Although significant improvements were not noted in the
performance of test results evaluations, fewer violations were
identified following the enforcement conference of April 29,
1985. This is, in part, due to the decreased level of activity
in the development and performance of the preoperational and
startup test programs.
3. Board Recommendations
Continued licensee attention is warranted to insure the
transfer of expertise and experience in the upcoming
performance of the Unit 2 preoperational and startup test
programs.
G. Fire Protection
1. Analysis
During this assessment period, one routine and five special
team safety inspections were conducted by region based
inspectors to assess conformance of the as-built plant fire
protection features, fire protection program implementation
and post-fire safe shutdown capability. In addition, portions
of 31 inspections by resident inspectors were made to assess
housekeeping and the care and preservation of equipment.
Three violations were identified as follows:
a. Severity Level V - The licensee failed to implement
procedures to verify the quality of fire barrier
penetration seals (Report No. 454/84076).
b. Severity Level V - The licensee failed to provide
instructions, procedures or drawings which ensured
timely review of radiation seal substitutions
(Report No. 454/84076).
c. Severity Level V - The licensee failed to provide and
maintain three aspects of the fire protection program
(Report No. 454/84082).
Subsequent follow-up inspections and meetings with the licensee
resulted in the licensee taking appropriate corrective actions
for all of the identified violations. Most of the unresolved
and open items that were identified have been closed out.
25
During the previous assessment period, the licensee was rated
Category 3 in this functional area. As noted in the cover
letter which transmitted that assessment, the Category 3 rating
reflected the Region III view that there was a lack of concerted
management attention to the development and implementation of the
fire protection program. Further, there was no evidence that the
licensee had undertaken a comprehensive evaluation of their fire
protection program to establish their degree of conformance with
FSAR commitments. As noted in the assessment itself, these
problems were compounded by a lack of technical expertise by the
plant staff in fire protection.
In response to Region III's expressed concerns in this area,
the licensee brought additional technical expertise to bear in
fire protection, increased the level of management attention
devoted to fire protection and undertook a self-evaluation of
their degree of conformance to their commitments. 'The actions
resulted in a measurable improvement in performance in the fire
protection area.
While problems continue to be identified as noted above, they
are of a more isolated nature and are generally dispositioned
better than in the past.
Routine housekeeping inspection tours of Unit 1 indicate that the
licensee has developed and implemented programs to supplement
the on going effort in the areas of plant cleanliness and care
and preservation of safety-related equipment. In addition,
special cleaning / preservation teams were formed and employed on
a full time basis in the areas of component / pipe ending
coverings and a wide spread and growing problem of graffiti
cleanup. The licensee expended considerable resources in
upgrading plant cleanliness and care and preservation of
safety-related components during the transition period from
construction to operation. The most noticeable effects of this
effort were observed in the months immediately preceding
issuance of the operating license on October 31, 1984. Limited
work activities still in progress in plant-common and Unit 1
areas have afforded the cleaning teams opportunity to gain
control of the graffiti problem; however, additional management
attention is still required to maintain the cleanliness levels
achieved. Resident Inspector tours conducted since OL have not
discovered housekeeping problems detrimental to safety-related
equipment indicating management involvement is adequate.
Routine housekeeping tours of Unit 2 indicate that while the
licensee has developed and implemented houskeeping programs,
they have not been effective in maintaining an adequate level
of cleanliness for the level of construction activity.
Additional management attention is required to achieve and
maintain adequate cleanliness.
26
2. Conclusion
The licensee is rated a Category 2 in this area. This is a
higher rating than was given in the previous assessment period
and is based on appropriate corrective actions that have been
taken and generally adequate management responses to concerns
raised by the NRC. Noted improvements in this area provide
assurance that the quality of installed fire protection
features will be maintained to accommodate post-fire safe
shutdown given a fire in any area of the plant. Licensee
performance has remained the same during the assessment period.
3. Board Recommendations
None.
1. Analysis
Six inspections were conducted during the period by region
based inspectors to evaluate the following aspects of the
licensee's emergency preparedness program: (1) emergency
detection and classification, (2) protective action decision
making, (3) emergency notifications, (4) emergency communications,
(5) shift augmentation provisions, (6) emergency preparedness
training, (7) offsite dose assessment. (8) independent audits of
emergency preparedness, (9) implementat. ion of changes to the
program, and (10) followup on items identified during the
December 1983 Emergency Preparedness Implementation Appraisal.
Three inspections were appraisal followup inspections; another
involved an allegation regarding provisions for the assembly,
accountability, and evacuation of contractors; another was the
observation of the annual exercise; and the sixth was a routine
inspection of the emergency preparedness program.
One violation was identified:
Severity Level IV - During a five month period, the
licensee failed to complete quarterly inventories of
emergency supplies located in two emergency response
facilities (Report Nos. 454/85038; 455/85034).
Appropriate corrective actions for the violation were initiated
- prior to the end of the inspection. This violation is not
considered indicative of a programmatic breakdown in conducting
periodic inventories of emergency supplies.
Independent audits of the emergency preparedness program were
ad a nte in scope, depth, and frequency. Audit records were
complete and well maintained. Administrative procedures were
adhered to regarding the preparation, review, and distribution
of the emergency plan and its implementing procedures.
27
_ ___
.-
Revisions to the Byron Annex of the generic emergency plan,
and implementing procedure revisions were consistent and did
not degrade their effectiveness. An effective system had been
utilized to track and document corrective actions on items
identified during drills, audits, and NRC inspections.
As evident from the followup inspections on items identified
during the appraisal, the licensee had a clear understanding
of the staff's concerns. Initial corrective actions were
appropriate in almost all cases. Closure of the items was
generally timely, with few remaining open beyond August 1984.
These items were closed in December 1984. The licensee's
responsiveness to all items identified subsequent to the
appraisal followup inspections has been very good. Required
responses were received by the established deadlines. All
corrective actions were technically sound, thorough, promptly
initiated, and were either complete or were being completed
on schedule.
Records associated with six actual emergency plan activations
through August 1985 indicated that all situations had been
properly classified. The NRC and State of Illinois were
initially notified of these emergency declarations in a timely
manner. Detailed records of notification messages to the NRC
and State of Illinois were complete and readily available.
The licensee has maintained a prioritized roster of adequate
numbers of qualified personnel to fill well-defined, key
positions in the emergency organization. Semi-annual,
off-hours drills have been conducted to successfully
demonstrate the capability to augment on-shift personnel
in a timely manner.
Proficiency of persons assigned to the onsite emergency
organization has largely been maintained through annual
training on the generic emergency plan, Byron Annex, relevant
implementing procedures, and by participation in drills and
exercises. In addition, operating shift personnel have been
kept informed of emergency plan implementing procedure changes
through a periodic required reading program administered by
the Station's Training Department. Based on walkthroughs
and observations of participants in the annual exercise,
persons assigned to the emergency organization have adequately
demonstrated their capabilities to perform their emergency
duties.
2. Conclusion
The licensee is rated Category 1 in this area. This is a
higher rating than was given in the previous assessment
period. Licensee performance has improved during the
assessment period, particularly in regards to responsiveness
to NRC concerns. The rating is based on the following: the
28
strength of the emergency preparedness training program, as
evidenced during walkthroughs and exercises; the licensee's
ability to monitor its own activities and take timely,
appropriate corrective actions; and the timely and accurate
reporting of emergency plan activations to the NRC and State
agencies.
3. Board Recommendations
None.
I. Security
1. Analysis
During this assessment period, eight inspections were conducted
by region based inspectors. Three routine preoperational
inspections were conducted by regional based prior to license
issuance. Two routine and three special inspections were
conducted subsequent to license issuance. The assessment in
this functional area was divided into two phases - those issues
of the security program required to be completed prior to fuel
load, and the full implementation of the security plan after ,
license issuance.
Three violations, subsequent to the issuance of the license were
identified as follows:
Severity Level IV - Adequate protected and vital area
'
a.
access controls in the form of physical barriers were
not provided (Report No. 454/84085).
b. Severity Level III - The locked status of vital area
doors was not properly verified following a computer
outage, resulting in two unlocked doors for approximately
4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (Report No. 454/84085).
c. Severity Level IV - Failure to provide adequate access
controls to two vital areas because of inadequate physical
barriers (Report No. 454/85046).
Violation a. represented a significant breakdown in the
security system that occurred prior to initial reactor startup.
Due to the status of the plant, an act of radiological sabotage
was not possible; consequently, enforcement actions were not
escalated. Violation b. represented a personnel error that
led to the inadequacy of two of the three elements of access
control for the affected vital area. A proposed imposition of
civil penalty in the amount of $25,000 was issued. At the
close of the assessment period, the NRC was evaluating the
licensee's response to the Notice of Violation. Violation c.
represented a disregard for security procedures by both
station and contractor employees. These three violations were
29
_ _
_ __ _ . _ _ _ _ _ _ _ - _ .
l
!
indicative of a significant programmatic breakdown. Corrective
actions, although prompt, were not successful in preventing
recurrence. The continuation of similar types of problems
necessitated the formulation of a Performance Improvement !
Program with the goal of precluding recurrence. The results
of this program will be evaluated during the next assessment
period.
During the preoperational phase, in anticipation of initial
activation of the program needed at license issuance, the
corporate nuclear security office conducted an extensive audit
which established priorities for implementation and problem
areas. Th3 Quality Assurance audit program on the other hand,
is neither as comprehensive nor as effective in identifying
causes of problems.
Communications between the site and the corporate nuclear
security office were improved during the assessment period
through the establishment of the " Senior Nuclear Security
Administrator" position onsite. The licensee should consider
an increased oversight by the corporate organization in
the decision making and operation of the security system.
The licensee's approach to the resolution of technical issues
has been viable and generally sound, with the exception of the
security computer reliability issue which has involved both
software and hardware problems. The issue of security system
reliability has not been resolved to date.
Security event reports, under 10 CFR 73.71(c) were accurately
identified, but some analyses were marginal. For example, in
the initial event involving inadequately protected and vital
area access controls, the initial evaluation approach showed
a lack of understanding of the issue, resulting in incomplete
compensatory measures.
Staffing problems were noted in the security force contract
overview, both onsite and in the contractor's branch and
corporate offices. Personnel in key management positions
changed frequently, contributing to low morale and poor
administrative support. Only within the latter portion of
the assessment period did the licensee address this issue
and require the contract agency to maka necessary changes
to improve its performance.
The security training and qualification contributed to an
adequate understanding of work and fair adherence to
procedures with a modest number of personnel errors. However,
the Severity Level III violation, involving inadequately
implemented compensatory measures, was in large part due
to deficiencies in the guard and firewatch training programs.
Our review has shown that despite the identified individual
30
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--
,
areas of needed improvement, the security and guard force
organizations have made steady improvement. The continuing
vital area access control problems do not appear not to be caused
by major deficiencies in security organization performance.
The licensee has taken several actions to improve their
performance in the area of vital area access control. These
actions have been logical and efficiently implemented but did
not achieve the ultimate results of preventing continued similar
problems from occurring.
2. Conclusion
The licensee is rated Category 3 in this area. This is a
lower rating than was given in the previous assessment period.
This rating is based primarily on the licensee's performance
subsequent to the issuance of the license. Licensee's overall
performance in this functional area has not demonstrated an
adequate understanding of the fundamental security issue of
protected and vital area access controls and has declined
during the assessment period.
3. Board Recommendations
Licensee management should place major emphasis on implementation
of a corformance improvement program.
[ NOTE: In the first month following and conclusion of this
assessment period, another potential Severity Level III
violation, involving a degraded, unmonitored vital area
barrier for 26 consecutive days, was identified by the
licensee. Escalated enforcement action is pending.]
J. Quality Programs and Administrative Controls
1. Analysis
Ten inspections by region based inspectors and one inspection
by resident inspectors examined activities in this functional
area. Activities inspected included quality assurance program
review and administration; procurement control; receipt, storage
and handling of material; QA records program; document control;
the offsite review committee; audit program; offsite support
staff; followup of the licensee contracted Independent Design
Review (IDR); and review of Systems Control Corporation (SCC)
procurement activities. In addition, meetings were held monthly
between NRC staff and plant management to assess operation of
the plant.
Twelve violations were identified:
31
- _ --
l
I
!
a. Severity Level III - A material false statement regarding
SCC source inspections. (Report Nos. 454/84032; 455/84025).
b. Severity Level IV - Failure to maintain records of
nonconforming items (Report Nos. 454/84032; 455/84025),
c. Severity Level IV - Failure to include SCC on the Approved
Bidders List (Report Nos. 454/84032; 455/84025).
d. Severity Level IV - Failure to take timely and
effective corrective actions regarding SCC supplied
equipment (Report Nos. 454/84032; 455/84025).
.
'
e. Severity Level IV - Six examples of QA audit program and
implementation deficiencies (Report No. 454/84040).
f. Severity Level IV - Improper implementation of disposition
on nonconforming material (Report No. 454/84044).
g. Severity Level V - Two examples of improper material
storage (Report No. 454/84044).
h. Severity Level IV - Changes made to facility which
involved an unreviewed safety ~ question without prior
Commission approval (Report No. 454/85002).
i. Severity Level V - Failure to control design documents
to ensure use of latest revision (Report Nos. 454/85019;
455/85012).
j. Severity Level IV - Failure to translate regulatory
requirements and design basis into appropriate procedures
and design documents (three examples) (Report No. 455/85027).
k. Severity Level IV - Failure to assure that purchased
equipment and services conform to procurement documents
(numerous examples) (Report No. 455/85027).
1. Severity Level IV - Failure to establish and execute an
effective inspection program to verify conformance with
instructions, procedures, and drawings (three basic
examples) (Report No. 455/85027).
Four violations, a., b., c., and d. resulted from followup
inspections of SCC supplied equipment $ssues originally iden-
tified in Inspection Reports No. 454/80004; 455/80004. The
violations identified failures by the licensee in dealing with
deficient SCC products. The licensee's response was reviewed
and determined to be adequate. Followup inspections of the
licensee's corrective actions found them to be satisfactory.
.
32
_ . ,- .- .. - . - . ._ _ _ __
r
!
!
l Followup review of the Integrated Design Inspection (IDI)
findings was also completed in this assessment period. The
resolution of the remaining 29 of 96 issues was accomplished
with extensive NRC staff / licensee information exchange and
review. The complexity of the issues required significant
effort from the staff and licensee.
l
! Violations f., g., and i. resulted from QA program inspections
l and appeared to document isolated instances rather than program
! breakdowns. Items f. and g. were identified early in the
j assessment period and subsequent inspections indicated proper
i correction and acceptable performance. Action on item i. was
completed during the inspection and appeared to be an isolated
case.
Violation e. identified significant problems in the
documentation and implementation of the quality assurance
audit program. These problems along with several program
l weaknesses documented as open and unresolved items were
l
'
identified early in the assessment period. The licensee
took immediate action to address the identified problems
and weaknesses. Prompt and adequate action was taken and
subsequent inspections indicated acceptable performance in
this area.
Violation h. involved a failure of licensee administration to
identify and appropriately evaluate a temporary alteration of
a protection system, based on an interpretation of a justifi-
cation for interim operation that was less conservative than the
NRC staff interpretation. The licensee subsequently adopted the
staff interpretation and took prompt and thorough corrective
action.
Prior to licensing, an independent design review (IDR) of the
Byron Station was performed by the Bechtel Power Corporation
(Bechtel) to provide an assessment by an outside party of the
adequacy of the design activities performed by Sargent and
Lundy Engineers. One inspection was conducted by regional
based inspectors to evaluate the acceptability of Bechtel's
effort. Areas reviewed included a review of the program and
procedures, the indoctrination and training of engineering
personnel performing reviews, reviewing monitoring / audit
documents, and evaluating potential observations and Bechtel's
approach to resolving the safety significance of these
observations. For the areas of the IDR examined, the inspectors
determined that activities were controlled through the use of
well stated and defined procedures. Reviews were thorough,
technically sound and performed by experienced reviewers.
Records and evaluations were found to be generally complete,
well maintained, and available. The program procedures dealing
with the dispositioning of the observations were functioning
properly. No violations or deviations were identified.
,
33
The Construction Assessment Team (CAT) inspected a wide
spectrum of Unit 2 construction activities late in the
assessment period. Violations j., k., and 1. were identified in
the CAT inspection. These violations are not representative of
any programatic breakdown. The licensee's response and
corrective actions will be reviewed in subsequent inspections.
The examples cited in these violations are referenced in the
appropriate functional areas.
Programatic inspections noted problems early in the assessment
period. Actions taken to correct the problems were adequate
and program performance appeared to be consistently acceptable
for the balance of the period.
2. Conclusion
The licensee is rated a Category 2 in this area. This is
the same rating as was given in the previous assessment period.
Licensee performance has remained the same during the
assessment period.
3. Board Recommendations
None.
K. Licensing Activities
1. Analysis
During the evaluation period there was a significant level
of activity. The low power license for Byron 1 was issued
on October 31, 1984, and the full power license was issued
on February 14, 1985. Supplemental SERs were issued along
with each of these licenses. Technical Specifications for
Byron 1 were issued with the low power license. The Technical
Specifications issued with the full power license were made
applicable to both Units.
The licensee's decision making is usually at a level that
ensures adequate management review. The submittals needed to
support licensing were generally timely, thorough and
technically sound. Upper management was available to resolve
concerns and took an active role on certain actions, such as
the Technical Specifications and staffing for operation of the
volume reduction system. The licensee understands the
technical issues and responses are generally sound and
thorough. Conservatism is generally exhibited and approaches
are viable. In several instances, the licensee challenged
staff positions, but only when it believed safety would not
be compromised. In the weeks prior to issuance of the low
power and full power licenses, the licensee had to respond
to many NRC initiatives in a short time. The licensee
responses were generally timely, sound, and thorough. Events
34
i
__. _.. _ _ _ _ _ _ _ . _ _ _
at Byron 1 appear to have been reported promptly and
accurately. Key positions are clearly identified and
responsibilities and authorities are well defined. The need
for operators on shift with previous operating experience was
a relatively recent requirement at the time of our review to
support issuance of the low power license. The licensee
responded by selecting several qualified individuals to act as
Shift Advisors on those shift crews that did not meet the
requirement. The trainiiig of shift advisors is acceptable
and on a par with other recently licensed plants.
2. Conclusion
The licensee is rated Category 2 in this area. This is the
same rating as was given in the previous assessment period.
Licensee performance has remained the same during the
assessment period.
3. Board Recommendations
None.
L Containment and Other Safety-Related Structures
1. Analysis
The work activities in this area were essentially complete.
Consequently, examinations of this functional area were limited
to seven inspections by regional based inspectors and a portion
of the NRC CAT inspection observing completed work and
reviewing installation records and associated documentation.
An as-built walkdown and a document review were performed for i
selected areas of Unit 1 and 2 containment structural framing,
steam generator bolting and supports, main steam support ,
structures, reactor coolant pump support column modifications, t
and containment electrical penetrations. Other selected,
safety-related, structural welding records were also examined.
One inspection examined concrete drilling and coring activities, ,
containment structural integrity testing, modifications, and t
licensee action on a related IE Bulletin and IE Circular. The !
results of a statistical sampling plan, established to reinspect !
high strength bolted connections which were reported as a '
10 CFR 50.55(e) deficiency, and allegations were also examined. ;
'
For the areas examined, the inspectors determined that the
10 CFR 50.55(e) deficiency was reported in a timely manner, ,
and was accurately identified and that the resulting reviews
were effective and technically sound. The installation records l
and associated documentation were generally complete, well
maintained, and available. Observations during the walkdown
'
indicate personnel have an adequate understanding of work
practices and have adhered to drawings and procedures. A large .
/
a
35 f
- -_ _ - -
portion of inspection resources in this functional area and in
Piping Systems and Supports was used in six inspections by
regional based inspectors to conduct reviews of allegations and
concerns expressed by an expert witness who appeared on behalf
of the Intervenors during the remanded ASLB hearing for Byron.
Three violations were identified:
a. Severity Level V - Failure to assure welding was
performed in accordance with the applicable AWS
D1.1 Code (Report Nos. 454/84050; 455/84034).
b. Severity Level IV - Failure to maintain retrievable
design basis documents (Report Nos. 454/84071;
455/84049).
c. Severity Level V - Failure to specify appropriate
code provisions (Report Nos. 454/84071; 455/84049).
The licensee's response and corrective actions related to
these violations were reviewed and found to be acceptable.
One example in a violation identified by the CAT inspection
(see Section J.) concerns structural steel bolts with torque
tension below that specified. The licensee has initiated
corrective actions which will be inspected in a future
inspection. In addition to the violations, a number of design
practices were found to be in need of improvement. During the
inspection appropriata corrective actions were taken by the
architect engineer to effect the needed improvements in the
design process.
The licensee's actions in response to the concerns forwarded to
them for review were timely, thorough, and technically sound.
A positive attitude was exhibited by the licensee and its
architect / engineer toward the prompt resolution of all issues
and implementation of improvements in the design process.
2. Ccnclusion
The licensee is rated Category 2 in this area. This is the
same rating as was given in the previous assessment period.
Licensee performance has remained the same during the assessment
period.
3. Board Recommendations
- None.
36
l
,
M. Piping Systems and Supports
1. Analysis
l
The work activities in this area were essentially complete.
Examination of this functional area consisted of seven
inspections by regional based inspectors and a portion of
the NRC CAT inspection. Areas examined included: (1) attend
periodic exit meetings conducted by the National Board of Boiler
and Pressure Vessel Inspectors to present their findings and the
progress of their comprehensive independent audit of ASME Code
l construction and related activities; (2) examine activities
l as they relate to the preservice inspection (PSI) of piping
l and systems, including a review of the PSI program and
,
procedures, equipment and material certifications, personnel
l qualifications, selected records of nondestructive examinations,
and observation of several liquid peustrant examinations;
,
(3) observe completed work and review installation records
1 and associated documentation for reactor coolant pressure
l boundary and other safety-related piping, including welder
l qualifications, weld repairs, visual examination of completed
'
welds, and review of radiographs of field pipe welds;
(4) evaluate the design, fabrication, and installation of
energy absorbing material used for pipe whip restraints;
,
(5) examine IE Bulletin 79-14 as-built walkdown inspection
i and design review, including a review of procedures, inspection
criteria, inspection measurements, and engineering analyses and
evaluations; (6) followup on licensee actions related to previous
l
inspection findings, 10 CFR 50.55(e) deficiency reports and
other IE Bulletins; (7) examine allegations; and (8) conduct
reviews of concerns expressed by an expert witness who
appeared on behalf of the Intervenors during the remanded ASLB
l
hearing for Byron.
Four violations were identified:
l
a. Severity Level V - Failure to follow procedures
during inspection (Report Nos. 454/84051; 455/84035).
b. Severity Level IV - Four examples of failure to
control design activities (Report Nos. 454/84051;
455/84035).
c. Severity Level V - Two examples of failure to have
,
adequate procedures (Report Nos. 454/84051; 455/84035).
i d. Severity Level V - Failure to identify as-built
l
dimension deviations during inspection (Report
Nos. 454/84051; 455/84035).
l
l
37
-. ..
The licensee efforts to resolve these violations were reviewed
during the course of the inspection and found acceptable prior
to the issuance of the full power license. The above violations
are not repetitive of violations identified during the previous
assessment period and they do not appear to indicate a programmatic
breakdown. One example in a violation identified by the CAT
inspection (see section J.) concerns concrete expansion anchor
embedment depth. The licensee has initiated corrective actions
which will be reviewed in a future inspection.
For tne areas examined, the inspectors concluded that with the
exceptions noted above, activities were generally controlled
through the use of well stated and defined procedures that were
adhered to. The approach used to evaluate IE Bulletin 79-14
findings was generally conservative, technically sound, and
thorough. Records were found to be generally complete, well
maintained, and available. The records also indicate that
preservice inspection equipment and material certifications
were current and complete and the personnel performing
nondestructive examinations were trained and certified. Review
of deficiency reports and IE Bulletin actions indicates that the
licensee understood the issues and their reviews were generally
timely, thorough, and technically sound.
2. Conclusion
The licensee is rated Category 2 in this area. This is the
same rating as was given in the previous assessment period.
Licensee performance has remained the same during the
assessment period.
3. Board Recommendations
None.
N. Safety-Relatad Components
1. Analysis
The work activities in this area were essentially complete.
Examination of this functional area consisted of six
inspections by regional based inspectors and a portion of
the NRC CAT inspection. Areas examined included: (1) evaluate
the qualification testing performed to confirm the
functionability of the as received Boeing steam generator
snubbers; (2) evaluate the modified snubber design, installation,
and qualification testing of the Paul Monroe Hydraulic (PMH)
snubbers procured to replace the Boeing snubbers on the Byron
Unit 1 steam generators; (3) review installation procedures,
observe the installation, and review installation documentation
for the PMH steam generator snubbers; (4) evaluate the redesign,
modification, and qualification testing of the ITT-Grinnell
38
-
modified Boeing steam generator snubbers; (5) review records
and associated documentation related to the welding of the
internals installed in the reactor vessels for both Unit 1
and 2; (6) evaluate the dispositicn and repair of indications
identified during preservice inspection of the Unit 2 steam
generators ~and pressurizer; and (7) followup on licensee
actions related to previous inspection findings, 50.55(e)
deficiency reports and IE Bulletins.
One violation was identified:
Severity Level V - Failure to conduct steam generator
snubber testing in accordance with approved procedures
(Report No. 455/85004).
In addition, one example from violation c. of Section M. cited
a lack of approved procedures to conduct steam generator
snubber tests. The licensee's written response to these
violations and corrective actions were reviewed and found to be
acceptable. These violations are not repetitive of violations
identified during the previous assessment period, and they do not
appear to indicate a programatic breakdown. A violation
identified by the CAT inspection (cee Section J. violation k.)
related to deficiencies in vendor supplied components. The
licensee has initiated corrective actions which will be
examined in a future inspection.
For the areas examined, the inspectors determined that
activities were controlled through the use of well stated and
defined procedures. With the exceptions noted above, these
procedures were adhered to. The approach used to evaluate,
design, test, and install snubbers was generally conservative,
technically sound, and thorough. Records and test data were
found to be generally complete, well maintained, and available.
Review of the deficiency reports and IE Bulletin actions
indicate that the licensee understood the issues and their
reviews were generally timely, thorough, and technically sound.
2. Conclusion
The licensee is rated Category 2 in this area. This is the
same rating as was given in the previous assessment period.
Licensee performance has remained essentially constant over
the course of the SALP assessment period.
3. Board Recommendations
None.
39
_ - _ _ - _ __ _
_____ _ _ __ _ _ - _ _ _ _ _ _ _
0. Support Systems Heating, Ventilating and Air Conditioning (HVAC)
1. Analysis
The work activities in this area were essentially complete.
Examination of this functional area was limited to one
inspection by regional based inspectors to review numerous
allegations relating to the quality of HVAC construction.
Two violations were identified:
a. Severity Level IV - Failure to control special processes and
personnel qualifications (Inspection Report No. 454/85011).
b. Severity Level IV - Failure to promptly identify and
correct conditions adverse to quality (Inspection Report
No. 454/85011).
The licensee's written response to these violations has been
reviewed and found to be acceptable. An inspection of
corrective actions will be made in a subsequent inspection at
the site.
2. Conclusions
The licensee was not rated in this area due to the limited
nature of the inspection. This area was rated category 2 in
the previous assessment period.
3. Board Recommendations
None.
P. Electrical Power Supply and Distribution
1. Analysis
Examination of this functional area consisted of ten inspections
by region based inspectors, portions of seven resident inspections
and a portion of the NRC CAT inspection. Areac examined included:
(1) review of previous inspection findings; (2) observations of
raceway and equipment installations; (3) observations of electrical
cable installations and terminations; (4) equipment storage and
maintenance activities; (5) conductor butt splice reinspection
program; (6) as-built drawing walkdown; and (7) tr:ining and
qualification of personnel.
Three violations identified by the CAT inspection (see Section
J. violations j., k., and 1.) relate to this functional area and
also Section Q. Several of the examples of violations were
repetitive of violations identified during the previous SALP
assessment period, although they are not interpreted to be
serious programatic breakdowns. The licensee has initiated
40
_ . ._ . _ _ _ _ _ _ __ _
corrective actions on these violations and the actions taken
will be reviewed during subsequent inspections. In the first
violation, one of the three examples identified is electrical.
This example identifies that the licensee was splicing Class 1E
wire inside of panels contrary to the requirements of IEEE
Standard 420 which is an FSAR commitment. The second violation
identifies numerous equipment assembly / mounting bolts, for
certain electrical and mechanical equipment, that were found to
be unmarked thus making the quality of these bolts indeterminate.
In the third violation, example 1 identifies that 4160V switchgear
units 2AP05E and 2AP06E and 125V DC fuse panel 2DC11J were not
installed in accordance with the requireirents for seismic
mounting of Class 1E equipment in that the mounting weld
configuration did not match the details shown on approved design
drawings. With respect to the 4160V switchgear, similar
deficiencies were previously identified on Unit 1 equipment;
however, the impact on relevant Unit 2 equipment was not reviewed.
Example 2 identified that some Class IE electrical raceways have
not been installed in accordance with FSAR commitments for
separation. Separation violations were also identified in the
previous SALP assessment period. Example 3 identified that 5 of
7 motor operated valves inspected contained two or more termination
errors that had been accepted by first line QC inspectors. The
licensee was responsive to NRC concerns and took appropriate
corrective actions to resolve the specific issues from a technical
and safety standpoint. However, the licensee was not always
aggressive in assessing potential problem areas. The violations
identified above represent examples wherein the licensee's
management attention should have been more effective.
2. Conclusion
The licensee is rated Category 2 in this area. This is the
same rating as was given in the previous assessment period.
Licensee performance has remained the same during the
assessment period.
3. Board Recommendations
None.
Q. Instrument and Control Systems
1. Analysis
Examination of this functional area consisted of significant
portions of ten region based inspections, portions of
four resident inspections, and a portion of the NRC CAT
inspection. Areas examined included: (1) review of previous
inspection findings; (2) observation of raceway and equipment
installations; (3) observation of electrical cable installations
and terminations; (4) equipment storage and maintenance activities;
41
_ ._ . _ _ . _ . - -
. . . - . -. _ . . - -. . ._--
(5) observation of instrument sensing line installations; (6)
conductor butt splice reinspection program; (7) as-built drawing
2
walkdown; (8) training and qualification of personnel; and also,
for certain equipment supplied by Systems Control Corporation,
(9) observing reinspection of certain welds; (10) visually
examining discrepant hanger welds, (11) attending formal
j classroom training to certify walkdown personnel in the
inspection of welds; and (12) reviewing the engineering analysis
and evaluations performed to demonstrate the structural adequacy
- of the discrepant welds.
!
Due to the overlap between the this area and the electrical
area, Section P. of this report, the violations identified by
- the CAT inspection and discussed in the electrical area are also
applicable to this functional area.
For the areas examined the inspectors determined that
activities were controlled through the use of well stated and
defined procedures. The personnel performing the inspections
were trained and certified. Reviews were thorough, technically
sound, and performed by experienced reviewers. The procedures
dealing with the performance of these analyses were functioning
properly. The structural adequacy of the Systems Control
Corporation supplied components was demonstrated.
The licensee was responsive to NRC concerns and took appropriate
corrective actions to resolve the specific issues from a technical
and safety standpoint. However, as discussed in Section P, the
,
licensee was not always aggressive in assessing potential
problem areas.
2. Conclusion
The licensee is rated Category 2 in this area. This is the
same rating as was given in the previous assessment period.
Licensee performance has remained the same during the
assessment period.
- 3. Board Recommendations
,
None.
f
d
42
. . _ __ _ _ .._ . _ _ __ _ _ _ _ _ . _ . . _ _ _ . ___ _ _ . _ _ ,. _ _ _ _ . _ _ _ _ _
V. SUPPORTING DATA AND SUPMARIES
A. Licensee Activities
During this SALP period, the following activities of interest
occurred:
1. October 31, 1984 - Licensee was issued Low Power (five percent)
Operating License No. NFF-23.
2. November 2 through November 27, 1984 - Initial Fuel Loading.
3. February 2,1985 - Initial Criticality.
4. February 4,1985 - Licensee was issued Full Power Operating
License No. NPF-37.
5. February 24, 1985 - Mode 1 (commenced Power Ascension Testing).
6. June 10 through June 13, 1985 - Byron Nuclear Generating
Station's Emergency Preparedness exercise.
7. September 16, 1985 - Power Ascension Testing completed, unit
turned over to Load Dispatching.
8. October 25, 1985 - Scheduled maintenance outage.
B. hspectionActivities
1. Inspection Data
a. Facility Name: Byron Unit 1 Docket No.: 50-454
Inspection Report Nos.: 84025 and 84026
84028 through 84080
84082 and 84083
84085 through 84088
85001 through 85017
85019 through 85031
85033 through 85044
85046
b. Facility Name: Byron Unit 2 Docket No.: 50-455
Inspection Report Nos.: 84018
84020 through 84039
84041 through 84057
85001 through 85004
43
__
85006 through 85010
85012 through 85015
85017 through 85025
85027 through 85029
85038 and 85040
85042 and 85043
2. Inspection Summary
The inspection programs at Byron during the evaluation period
were conducted by the NRC using resident and region based
inspectors, inspection teams and consultants. An NRC
Construction Appraisal Team (CAT) inspection was conducted on
August 19-30 and September 9-20, 1985, and is documented in
Inspection Report No. (50-455/85027). In addition, a Region I
Non-destructive Examination (NDE) van team inspection was conducted
on Unit 2 from October 28 through November 8, 1985; the results
will be reviewed in the next SALP assessment.
TABLE 1
ENFORCEMENT ACTIVITY
,
No. of Violations in Each Severity Level
Functional Unit 1 Unit 2 Site
i Areas III IV V III IV V III IV V
l
A. Plant Operations 2 6 1
B. Radiological Controls 1* 3 1
C. Maintenance 1 1
D. Surveillance 6
E. Initial Fuel Loading
F. Preoperational Testing 3 3
and Startup Testing
i
G. Fire Protection 3
i
I. Security 1 2
J. Quality Programs and
Administrative 3 1 3 1 3 1
Controls Affecting
Quality
f 44
. _ _ _ _ _ _ _ _ _ _ - - - -, __ __ __ , _ _ __ __ _ _ _ . -
.- _. --.
l
Functional Unit 1 Unit 2 Site
Areas III IV V III IV V III IV V
K. Licensing Activities
L. Containment, and ,
Other Safety-Related 1 2
Structures
,
M. Piping Systems & 1 3
Supports
N. Safety-Related Components 1
0. Support Systems 2
P. Electrical Power Supply
and Distribution
Q. Instruments & Control
Systems
TOTALS
4 26 8 0 3 2 1 7 6
i
- Three violations were combined into one citation
C. Investigations and Allegation Review
There were 22 allegation cases initiated during this assessment
period. All have been reviewed; substantiated issues are documented
in inspection reports and followed to resolution. Violations
resulting from inspections of allegations are included in the
appropriate functional area section of this SALP report.
One, very extensive allegation case was initiated from the
concerns expressed by the expert witnesses for the Intervenors
which related to the QC Inspector Reinspection Program, Sargent
and Lundy Engineers' (the licensee's architect-engineer) design
criteria and calculations, computer programs, and several other
areas. Most of the concerns originated from the expert witness'
examination of documents during the discovery process for the
remanded hearing and from observations made by the expert
witnesses during a tour of the Byron facility with the Licensing
Board and hearing parties.
Region III arranged for other NRC offices to review some of the
concerns, forwarded many of them to the licensee for review, and
retained the remainder of Region III action, Although the concerns
were never expressed'to the NRC as allegations, the concerns were
nevertheless processed as allegations to assure a complete NRC review.
The Region III action of requiring the licensee to review many of the
- concerns was an action consistent with the Commission policy on review
of allegations received near the licensing decision date.
45
D. Escalated Enforceinent Action
1. Civil Penalties
There were three civil penalties assessed during the SALP period
and operational violations identified near the end of the SALP
period that may result in another civil penalty.
a. Inspection Report Nos. 454/84-32, 455/84-25 assessed a
Civil Penalty of $40,000 based on statements made by the
licensee regarding inspections of products from Systems
Control Corporation.
b. Inspection Report No. 454/85012 imposed a civil penalty of
$25,000 for inadequate control of access in a vital area.
c. Inspection Report Nos. 454/85022, 455/85020 assesses a
civil penalty of $50,000 for three radiological protection
problems collectively.
2. Orders
No orders relating to enforcement were issued to the licensee
during the assessment period.
E. Licensee Conferences Held During Appraisal Period
Meetings
1. June 6, 1984, an enforcement conference to discuss licensee
submittals to the NRC relating to Systems Control Corporation
equipment.
2. July 19, 1984, Management meeting with Vice President and other ,
CECO management representatives in the Lombard, Illinois Holiday
Inn to review the systematic assessment of the licensee performance
'SALP 4) of the Byron Nuclear Station.
3. August 14, 1984, a public meeting was held to discuss matters
related to the integrated design inspection (IE, RIII, NRSS,
and CECO attended).
4. September 7, 1984, Management meeting with Commonwealth Edison
Company corporate staff to discuss the status of their
regulatory performance improvement program.
5. March 7, 1985, Management meeting with representatives to Ceco
to discuss the licensee's regulatory improvement program status.
6. March 27, 1985, Management meeting to discuss the progress of
the Byron startup program.
46
_- ._ . .. - - _ __
7. April 2, 1985, an enforcement conference to discuss vital area
access control relating to the door alarm system.
8. April 29, 1985, an enforcement conference to discuss the
operation of Unit I with certain protection system components
not seismically qualified, and the adequacy of the technical
review of test results.
i
9. June 24, 1985, Management meeting aimed at improving licensee
regulatory performance and enhancing communications between the
NRC and CECO. Meeting included an update of actions initiated
.
by CECO as a result of past meetings and involved discussion
regarding the effectiveness of the program, particularly in the
area of individual plant improvements.
10. June 27, 1985, Enforcement Conference to discuss exposure of
personnel above administrative limits and other radiation
protection problems associated with a May 1, 1985 incore
detector incident.
11. July 22, 1985, Enforcement Conference to discuss continuing
radiation protection problems since the June 27, 1985,
Enforcement Conference.
12. November 22, 1985, an enforcement conference to discuss the
inoperable condition of both RHR trains of ECCS and other
failures to follow technical specifications.
In addition, meetings were held between NRC staff and licensee plant
management on a monthly basis to assess overall facility status
through the various phases of licensing. After issuance of the
license, the meetings were continued in order to assess plant
operations.
F. Confirmatory Action Letters
'
A Confirmatory Action Letter was issued on March 15, 1985, regarding
the failure of the 1A and 10 Main Steamline Isolation Valves (MSIVs)
to close and other plant responses during the loss of offsite power
test.
G. Review of Licensee Event Reports, Construction Deficiency Reports
and 10 CFR 21 Reports Submitted by the Licensee
1. Licensee Event Reports (LERs)
'
The licensee has held a full power license for Byron Unit 1
since February 14, 1985. Unit 2 is still under construction.
During this time the licensee reported 64 non-security events
to the NRC Operations Center. One of these events was considered
significant by the staff and was followed up and reviewed in
detail. This event involved air check valves leaking which
resulted in two MSIVs failing to close on March 14, 1985.
47
.
The licensee issued 91 LERs during the assessment period in
1985. Forty-three LERs were issued during 1984 from the date
the Byron plant received its low power license (October 31,
1984) until the end of the calendar year 1984.
The following is the number of LERs classified with each cause,
issued during the assessment period:
Number of LERs Cause
, 65 Personnel Error
26 Design, Manufacturing,
and Construction /
Installation
7
'
External Cause
15 Defective Procedure
2 Management / Quality
Assurance Deficiency
19 Other(cannotbe
identified or assigned
to another
classification)
- Cause is assigned by the licensee according to NUREG - 0161,
" Instructions for preparation of Data Entry Sheets for Licensee
Event Report (LER) File," nr NUREG - -1022, " Licensee Event
Report System."
Twenty-three of the events reported for 1985 have involved reactor
trips. This represents a rate which is significantly higher
than average for new plants (average about 12-15 trips per year)
and well above the rate for more mature facilities (about 5-6
trips per year).
Reviews of operating experience at Byron 1 for the fuel load /
low power license period (October 31, 1984 to February 14,
1985) indicate that Byron 1 had a higher frequency of reportable
events than other recently licensed plants for similar periods
of operation. This higher frequency was primarily the result
of two factors: recurring inadvertent actuations of the
control room ventilation isolation system; and actuations of
the baron dilution prevention system. Both of these problems
appear to have been substantially corrected before the end of
the SALP period.
The frequency of all events in the period is somewhat higher than
is typical for new plants. However, the frequency of reactor
trips is significantly higher than normal.
48
2. Construction Deficiency Reports (CDR)s: 10 CFR 50.55(e)s
During this SALP performance 9 CDRs were submitted by the
licensee under the requirements of 10 CFR 50.55(e). The
content of these reports was acceptable.
a. Containment spray pumps identification confused between
pumps with differing outlet pressure capacity.
b. Acceptability of electrical cable butt splices
indeterminate based on inspection results from other sites.
c. Spot weld connection on Westinghouse 480V breaker
connection found questionable,
d. Boeing steam generator snubbers failed to meet test
criteria.
e. Steam generator snubber under ultrasonic testing revealed
material lamination around the piston rod end,
f. Energy absorbing material had lower than specified crush
strength,
g. Westinghouse motor control centers circuit breakers AMP
fault current capability too low.
h. Seismic qualification of containment floor drain valves.
i. Environmental effects on High Energy Line Break (HELB) in
Auxiliary Building.
3. Part 21 Reports
Two 10 CFR Part 21 reports were submitted by the licensee during
this assessment period.
a. Airline check valves manufactured by Parker-Hannafin,
supplied by Anchor-Darling Valve Co. fail to reseat on slow
bleed off of supply side air pressure.
b. Degradation of diesel RPM reading giving indication in the
standby mode due to power supply noise
H. Licensing Actions-
1. NRR Site and Corporate Office Visits
August 23, 1984, Audit of river screenhouse analyses at Sargent
& Lundy
49
_. . . _ ._. . _ _ - . _ _ _ _ _ _ _ _ _ _ . -
October 2, ?984, Management site visit to determine readiness
for fLe1 load.
September 20, 1985, Site visit for CAT exit meeting.
2. Commission Briefing
February 12, 1985, Favorable' Commission vote to authorize full
power operation.
3. Schedular Extension Granted
None.
4. Relief Granted
October 1984, Supplement No. 5 to SER grants relief for preservice
inspection and inservice testing of pumps and valves.
February 1985, Supplement No. 6 to SER grants relief in
inservice testing of pumps and valves.
August 30, 1985, Emergency relief from preservice inspection
requirements granted.
September 24, 1985, Second relief granted (on August 30, 1985,
request) from preservice inspection requirements.
5. Exemption Granted
October 31, 1984, Exemptions to Appendices A and J granted with
low power license for Byron 1.
February 14, 1984, Exemptions to Appendices A, E and J granted
with full power license for Byron 1.
August 27, 1985, Exemption granted to Section 50.71(e)(3)(1) to
defer submittal of updated FSAR for Byron 1 and 2.
October 28, 1985, Schedular exemption from GDC 4 on
leak-before-break for Byron 2.
6. License Amendments Issued
Amendment No. 1 to Low Power License, issued January 28, 1985,
adds footnote to table of containment isolation valves that
allows certain valves to be opened on an intermittent basis
under administrative controls.
Amendment No. I to Full Power License, issued October 1, 1985,
i relates to administrative controls for access to high radiation
areas during certain emergencies.
'
50
7. Emergency / Exigent Technical Specification
January 18, 1985, Emergency Technical Specification authorized
by telephone call from Assistant Director for Licensing.
Formal change issued January 28, 1985 (see Item 6 above).
8. Orders Issued
None
9. NRR/ Licensee Management Conference
None.
51
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