ML20199J909
| ML20199J909 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 12/24/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20199J873 | List: |
| References | |
| 50-454-97-22, 50-455-97-22, NUDOCS 9802060062 | |
| Download: ML20199J909 (23) | |
See also: IR 05000454/1997022
Text
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U. S. NUCLEAR REGULATORY COMMISSION
REGION til
. Docket Nos: 50-454; 50-455
, License Nos: NPF.37; NPF 66
Report No: 50-454/97022(DRP); 50-455/97022(DPP)
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Licensee: Commonwealth Edison Company
Facility: Byron Generating Station, Units 1 and 2
Location: 4450 N. German Church Road
Byron, IL 61010
Dates: October 17 - December 1,1997
Inspectors: - N. Hilton, Resident inspector
T. Tongue, Region lli Project Engineer
C. Phillips, Braidwood Station Senior Resident inspector
J. Adams, Braidwood Station Resident inspector
D. Pelton, Braidwood Station Resident inspector
C, Thompson, lilinois Department of Nuclear Safety
Approved by: Michael J. Jordan, Chief
Reactor Projects Branch 3
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9802060062 971224
G ADOCK 05000454
EXECUTIVE SUMMARY
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Byron G:nerating St: tion, Units 1 and 2
NRC Inspection Report No. 50 454/97022(DRP); 50-455/97022(DRP) I
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This inspection included aspects of licensee operations, maintenance, engineering, and
plant support The report covers a 6-week period of resident inspection.
Operations
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- The Unit 2 startup on October 21,1997, demonstrated excellent operator
performance. Consistent three way communications between operators and formal
command and control by the unit supervisor and shift manager were observed. The
operators minimized the number of personnel in the control room, thus reducing
distractions. The qualified nuclear engineer reported directly to the unit supervisor
and made good recommendations and observations. The operators responded to
each annunciator alarm, reviewed the procedure and took appropriate action. The
approach to criticality was slow and controlled (Section 01.1).
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The Unit 1 shutdown on November 7,1997, was wall executed. Excellent command
and control, very good three-way communications, and good briefs and oversight by
management were observed (Section 01.2).
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Routine control room observations were very good. Control room personnel
conducted themselves professionally, unit supervisors and nuclear station operators
completed their duties without distraction, control room personnel were
knowledgeable of plant conditions, and operators practiced proper three way
communications while performing plant evolutions. The addition of a work execution
center outside the cont.ol room significantly reduced the number of personnel
requiring entry to the control room. Those personnel entering the control room
behaved professionally, observed the proper control room protocol, and entered for
the conduct of technical or administrative business with the unit supervisors or
nuclear station operators (Section 01.3).
- A review of the September 1997 2B chemical and volume control (CV) pump work
activity documentation identified severalissues. Procedure problems with filling and
venting the pump were identified by the licensee; however, no corrective actions
were taken or planned until questioned by the inspectors. Additionally, poor inter-
department communications existed as demonstrated by the fact that five individuals
involved in the CV pump maintenance did not know the status of the pump;
specifically, whether or not the pump had been drained during the maintenance
activities. A violation example for an inadequate procedure was issued (Section
O3.1).
- No corrective actions were taken for two problem identification forms (PIFs) written
during the 2B CV pump work. Issues identified in the PlFs included a lack of a CV
pump fill and vent procedure, an inadequate safety evaluation, and poor
communications between departments. The corrective action program failed to
capture the issues identified adequately and assign an appropriate investigation
(Section 08.2).
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Maintenance /Surveillange,
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. Obs:rv:d maint: nance and surveillance activities w:re w:ll conduct:d. Proc:dures
were used, personnelinvolved were knowledgeable, most foreign material exclusion
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(FME) controls were good, and issues were identified by maintenance personnel.
Additionally, based on proper authorization, procedure adherence, good
communication and coordination, and verification that the surveillance acceptance
criteria was met, the observed surveillance testing was well performed (Sections
M1.1 and M1.2).
- Foreign material control around the Unit 1 containment floor drain sump was pocr
and not in accordance with the station procedure governing foreign material control.
The sump was designated sa an FME area and holes in the floor drain sump cover
were not protected with FME covers. A violation for failure to follow the FME
procedure was issued (Section M1.3).
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On November 21,1997, during a system walkdowr., the inspectors noted boron
deposits on the sealinjection lines fittings and connections that had been previously
repaired in September 1997. The deposits had been identified by the licensee and
an action request had been written. The inspectors considered previous -
maintenance was not effective to prevent system leakage (Section M1.4).
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The material condition of the Unit 2 residual heat removal (RH) system prevented the
satisfactory conduct of the quarterly ASME surveillance as written due to leaking
reactor coolant system (RCS) cold leg check valves. The operability evaluation for
the condition was adequate, but did not address contingency actions for operators to
take to prevent a potential RH pump suction relief valve lift during a small break loss
of coolant accident (Section M2.1).
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After dropping a section of runway to be used during the steam generator
replacement, the licensee responded appropriately, quarantined the area and
promptly performed a formal investigation (Section M8.1).
Enaineerina
- System engineering identified that two vent valves were not included in the monthly
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Unit 1 emergency core cooling system (ECCS) venting surveillance test. The valves
were discovered during a modification review for system enhancements. The system
enhancements were part of actions taken following identification in May 1997 that a
residual heat removal vent valve was not being included in the monthly Unit 1 ECCS
venting surveillance test (Section E1.2).
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Plant Support
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- A worker struck contaminated stairs staged in the fuel handling building three times
with the uncontaminated handling equipment while using an overhead hoist.
Radiological response was appropriate; however, the repeated striking of
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contaminated equipment showed poor radiological work practices and a disregard for
contamination area postings by personnel (Section R1.1). i
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Report Details
Summary of Plant Status
Unit 1 operated at or near full power until November 7,1997, when the licensee began a
steam generator replacement and refueling outage. Unit i remained shutdown at the end
of the inspection period.
Unit 2 was synchronized to the grid on October 21,1997, after extraction steam bellows
repairs were completed. Unit 2 then operated at or near full power through the end of the
inspection period.
l. Operations
01 Conduct of Operations
01.1 _U_ nit 2 Startuo followina Extraction Steam Bellows Rooair (71707)
The inspectors observed significant portions of the Unit 2 startup on October 21,
1997. The inspectors observed consistent three way communications between
operators and formal command and control by the unit supervisor and shift manager.
The operators minimized the personnel in the control room, thus reducing
distractions. The qualified nuclear engineer reported directly to the unit supervisor
and made good recommend " ns and observations. The inspectors also noted that
the operators responded to i ch annunciator alarm, reviewed the procedure and
acted accordingly. The approach to criticality was slow and controlled. The
inspectors concluded that the Unit 2 startup demonstrated excellent operator
performance.
01.2 Unit i Shutdown for Refuelina and Steam Generator Reolacement (71707)
a. Inspection Scooe ~
The inspectors observed portions of the Unit i shutdown on November 7,1997.
Observations included licensee preparations, briefings, communications, command
and control, and the operators' performance during the unit shutdown.
b. Observations and Findinas
Several briefings were provided to the station staff involved in the actual shutdown
and outage preparations. The site vice president briefed all site personnel,
emphasizing clear communications, nuclear safety, minimizing radiation exposure,
personnel safety and the necessity for error free operations. A briefing from the
operations manager for the crew performing the shutdown emphasized the following:
safety first, if any abnormality or doubt existed don't hesitate to trip the unit, the
schedule was not a concern, use three way commurications, and formal command
and control. The inspectors also observed the heightened level of awareness (HLA)
briefing immediately prior to the shutdown and found it to be thorough and detailed.
in addition, several other briefings before each evolution during the shutdown were
conducted.
During the shutdown, the inspectors noted excellent comma.1d and control with very
good three-way communications. The process was well controlled and activities
were conducted with minimal congestion in the control room. Personnel involved
were knowledgeable of their duties and good management and supervisory oversight
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was obs;rv:d by th3 inspectors.
c. . Conclusion
The inspectors noted that the shutdown was executed as planned. This was
exemplified by excellent command and control, very good three way
communications, and oversight by management.
01.3 Observation of Control Room Conduct (71707)
a. Inspection Scooe
The inspectors conducted observations in the control room to assess the conduct of
control room personnel, control room communications, and control room access
coritrols. The inspectors reviewed Byron Administrative Procedure (BAP) 300-1,
' Conduct of Operations,' Revision 14.
b. Observations and Findinas
On November 12,1997, inspectors observed operators in the control room. The
inspectors found that control room personnel conducted themselves professionally.
For example, control room conversations were conducted in a way that minimized
control room distractions and maintained the professional atmosphere. The
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inspectors observed that the unit supervisors and nuclear station operators (NSOs)
l were attentive to their duties. The unit supervisors made frequent trips to the "at the-
! controls" area of the control room to supervise evolutions in progress, to directly
observe a reactivity addition, and to do general control board walkdowns. The unit
operators were observed performing frequent control board walkrlowns, monitoring
surveillance tests and plant evolutions, and closely monitoring reactor cora nuclear
parameters during and following the withdrawal of control rods (Unit 2).
The inspectors also observed the addition of boric acid solution to the Unit 1
refueling water storage tank and the performance of slave relay surveillance testing
on Unit 2. During each of these evolutions, the inspectors observed proper 3 way
communications between operators.
The inspectors observed that personnel entering the control room followed the
proper control room entry protocol and entered to conduct technical or administrative
business. For example, the work execution center NSO entered several times with
out of service documents that required the unit supervisor's approval. The
inspectors observed that the number of non shift personnel entering the control room
was minimal. The work execution center NSO told the inspectors that the recently
created work execution center had eliminated the necessity for personnel to enter
the control room to obtain approvals to begin work. Most of the work control function
was done outside the control room.
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c. QJ;tosjysions
. Bas:d on the obs:rvations in the control room on Nov:mber 12,1997, tha
inspectors concluded that the control room personnel conducted themselves
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professionally, unit supervisors and NSOs completed their duties without distraction,
control room personnel were knowledgeable of plant conditions, and operators
practiced proper three way communications while performing plant evolutions.
The inspectors also concluded that the number of personnel entering the control
room was significantly reduced by the addition of a work execution center outside the
control room. Those personnel entering the control room behaved professionally,
observed the proper control room protocol, and entered to conduct technical or
administrative business with the unit supervisors or NSOs.
03 Operations Procedures and Documentation
03.1 Chemical and Volume Control Pumo 28 Fill and Vent (71707)
n. Inspection Scope
The inspectors reviewed several aspects of the work on the 2B chemical and volume
control pump, conducted by the licensee in September 1997. The inspectors
re/iewed Byron Operating Procedure (BOP) CV 3, *Fillirig and venting the CV
system," Revision 5, the licensee's root cause investigation (see Section 08.2), out-
of service (OOS) 970008315, and work request (WR) 970006833, " Seal injection
lines need to be cleaned." The inspectors also discussed CV pump venting with the
system engineer, operators, and the operating manager,
b. Observations and Findinas
On September 8,1997, the licensee began performing several tasks on the 2B
chemical and volume control (CV) pump. One task was to clean the seal injection
lines to the 28 CV pump. The original task, first attempted in January 1997, was to
clean boron deposits off several connections near the pump casing. However, the
leaks were active and the boron deposits continued. During September 1997,
mechanical maintenance disassembled and reassembled several threaded
connections and a mechanical connection to correct the leaks.
Operatore questioned the decision to drain the pump on September 10,1997,and
documented the concern on a problem identification form (PlF). The shift manager
noted on the PIF that the CV pump was not drained for scheduled maintenance.
However, the inspectors noted that the 2B CV pump out-of service OOS included
2CV007B,2B CV PP 2CV01PB Casing Drain Valve, with a comment to use the
valve to drain the pump for mechanical maintenance work on the pump seal. The
inspectors noted that the sealinjection line cleaning was also covered by the same
OOS Additionally, the work package for the seal injection line cleaning required
removal of elbows and breaking 4-bolt flanges. The work request documented
completion of the disassembly and reassembly on September 9,1997. The
inspectors also observed the actuallocations of the elbow fittings and flanges and
noted that some of the connections were below the elevation of the upper portion of
the pump. All of the connections were several feet lower in elevation that the suction
and discharge isolation valves used to isolate the pump. The inspectors concluded
that, contrary to the shift manager's statement, the pump was actually partially
drained.
The inspectors requested the venting procedure for review and were informed by a
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i syst:m cnginrr that a v:nting proceduro for the CV pump did not exist for the
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oxisting plant conditions (Mode 1). The lack of a stand:rd operating proc: dure to fill
and v:nt ths CV pump was also noted by the nucisar station ep:rator (NSO) on the
September 10,1997, PlF Identified above. Discussions with the system engineer
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revealed that the pump suction and discharge gauges were typically vented to vent
j. air from the isolated portions of the system. The 2B CV pump also had a pipe stub
- w!th a cap near an isolation valve that could have been used, although the
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Inspectors noted no vent valve existed. The inspectors noted that the pipe stub and
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cap did not exist on all of the CV pumps.
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Discussions with operations management identified that a fill and vent procedure for
the CV system did exist. However, the inspectors reviewed BOP CV 3, " Filling and
-Venting the CV System," and determined that the procedure was inadequate in that
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the vent valves identified in the procedure were not within the isolation OOS
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boundary. The licensee stated that some operators considered removing a pipe cap
skill of the craft; however, the inspectors noted that to vent the CV pump, a pipe cap
was removed, instrument lines for two gauges were vented, and a temporary
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procedure change was written to vent the mini-flow line (see Section E1.1).
l Therefore, the inspectors considered the necessary venting steps significant and
] warranted an appropriate procedure. -
Title 10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings,"
i stated, in part, that activities affecting quality shall be prescribed by documented
l Instructions, procedures, or drawings, of a type appropriate to the circumstances.
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The inspectors concluded that a fill and vent of the 2B CV pump was an activity
I affecting quality and that the existing procedure was not appropriate to the
circumstance; therefore, the procedure to accomplish the fill and vent was an
i example of a violation of 10 CFR 50, Appendix B, Criterion V
(50-454/455-97022-01(DRP)).
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- The inspectors considered the non-cited violation criteria; however, the NSO's
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identification of the issue was not corrected without the inspectors' questioning. The
PIF was " issued closed" by the station event screening committee based on the shift
. manager's comments. Therefore, no corrective action was taken or planned after
j the completion of the licensee's root cause (see Section 08.2).
Discussions with the in plant shift supervisor (a senior reactor operator) indicated
that the operating crew did not know the status of the pump early on September 10,
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1997. The crew was initially unable to determine whether the pump had been
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drained. None of the following individuals were aware of whether or not the pump
had been drained; the project manager for the work, the work week manager, the
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system engineer, or the night shift mechanical maintenance supervisor. Through a
detailed review of the work packages, operators determined that the pump had been
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partially drained. The inspectors concluded that the lack of knowledge of the pump
i status was an example of poor communications between departments.
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c. Conclusions
Th] inspectors conclud:d that the 28 CV pump was partially drain;d during the work
conducted on September 1997. Although procedure problems with filling and
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venting the pump were identified by the licensee, no corrective actions were taken or
planned until questioned by the inspectors. Additionally, poor inter-department
communications existed as demonstrated by the fact that five individuals involved in
the CV pump maintenance did not know the status of the pump. A violation example
was issued.
08 Miscellaneous Operations lasues (92700,92901)
08.1 LClosed) Follow Up Item 50-455-97020-02(DRP): 2B CV Pump Maintenance
Window. This item was discussed in Sections O3.1,08.2, M1.4, and E1.1 of this
report. The inspectors noted several problems during the work window review.
However, the inspectors also noted that operators started a power reduction of Unit
2 when the allowed outage time was nearly exhausted. The power reduction was
begun according to company policy and the decision to start the reduction was
independent of the status of the 2B CV pump. The inspectors concluded that the
operators took conservative actions to begin placing Unit 2 in hot standby with ample
time remaining to perform a safe, orcerly, controlled shutdown. This item is closeo.
08.2 Root Cause Analysis of 2B CV Pump Work Window (717071
a. Inspection Scope
The inspectors reviewed root cause report 455 200-97-CAQS00026, Revision 0," Job
Removed from Schedule due to Delays in Providing a Technical Evaluation, Lack of
Parts and incomplete Package Preparation." The inspectors also reviewed PlFs
B1997-03144, "Non-conservative decision making," B1997-03103, " Challenges to
Shift Operatk ns Due to Questionable Work Window," and B1997-03085, " Job
removed from schedule due to Technical Evaluation, Parts and Package
Preparation." An On-site Review Report, OSR 97-121, "2B CV Pump Work
Window,' was also reviewed.
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b. Observations and Findinos
During the review of PIF B1997-03103, the inspectors noted that the PlF was issued
closed to PlF B1997-03085. The lack of a fill and vent procedure for the 28 CV
pump and the communications breakdown discussed in Section 03.1 was identified
on PIF 03103. The inspectors reviewed PlF 03085 and noted that engineering
support issues for the 2B CV pump work window were identified on the PIF.
On October 24,1997, the licensee issued root cause report
455 200-97-CAOS00026. The root cause report discussed the engineering support
issues and identified corrective actions applicable to the engineering support issues.
However, the inspectors identified that the issues identified in PIF 03103 were not
addressed in the root cause report.
Additionally, the inspectors noted that PlF 03144 was issued closed based on the
shift manager's recommendation. This PlF also identifies the lack of a fill and vent
procedure and identifies the safety evaluation concerns discussed in Section E1.1 of
this report. The inspectors were concerned that no corrective actions were taken for
either PlF 03103 or 03144. The inspectors noted the concerns to the operations
manager on October 28,1997. The operations manager agreed with the inspectors
that the root cause did not address all the issues and requested that the root cause
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organization r:open th]investig: tion and da a supplementil root caus].
. On Nov:mber 25,1997, the insp;ctors ask':d th] status of th] suppl;m:ntal root
cause investigation and were informed that the investigation had not been started.
The root cause organization discovered that the request had not been assigned a
due date, the assigned investigator had not been given the task, and the request had
not been entered into the licensee's tracking system. After the inspectors' questions,
the licensee immediately assigned a new investigator, assigned a due date, and
entered the action into the licensee's tracking system. The inspectors noted that the
task had not been lost, action had not been taken by the root cause organization to
initiate the supplemental investigation, almost a month after the initial decision to do
a supplemental investigation.
Due to the violation cited in Section 03.1, and an unresolved item discussed in
Section E1.1, the inspectors did not consider the missed corrective actions a
violation of 10 CFR 50, Appendix B, Criterion XVI, " Corrective Actions."
c. Conclusions
The inspectors concluded that no corrective actions were taken for two PlFs. Issues
identified in the PlFs included a luck of a CV pump fill and vent procedure, an
inadequate safety evaluation, and poor communications between departments. The
inspectors concluded that the licensee's correctiv s action program failed to capture
the issues identified adequately and assign an appropriate investigation.
D. Maintenance
M1 Conduct of Maintenance
M1.1 Maintenance Observations (62707)
a. Inspection Scope
The inspectors observed the performance of all or portions of the following work
requests (WR) When applicable, the inspectors also reviewed TS and the Updated
Final Safety Analysis Report (UFSAR) for potential issucc.
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WR 940014887-03 Remove / Replace Fill, Fan Blades anc. Drift Eliminator
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WR 960054553 01 Install DCP 9600017/9700469: New Fan Assembly with
Forged Blades.
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WR 97002159 Reactor Vessel Closure Head Removal
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WR 97002170 Reactor Vessel Closure Head Removal
WR 970028840-01 Clean and inspect the 1A CV Pump Cubicle Cooler
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WR 960054553-04 Remove / Install Discharge Check Damper to OD Auxiliary
Building Supply Fan, OVA 01CD
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b. Observations and Findinas
The inspectors observ3d that the maintsnanc3 activilits were conducttd according
to approved procedures and were in conformance with TS. The inspectors observed
maintenance supervisors and system engineers monitoring job progress. Quality
control personnel were also present when required. When applicable, appropriate
radiation control measures were taken.
Essential Service Water (SX) Towar Fill Reblacement
The inspectors noted that foreign material exclusion (FME) protection was good
within this project and extensive measures were established to continue operation of
the cooling tower to protect operating equipment while the project was being carried
out. In addition, after completion of each cell, the licensee planned to conduct a
diver inspection of the basin.
OD Auxiliary Buildino Ventilation Supolv Fan Blade Replacement
During the Inspection, the inspectors noted some small debs near the fan suction,
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The inspectors concluded that FME controls were weak initially. However, as the
prole continued, the work areas were acceptably cleaned. A problem was noted by
the neensee with the inadequate fit of a new protective screen installed on the fan
intake. At the end of the period, the issue was being resolved by the system
engineer,
c. Conclusions
During the inspectors observations, procedures were used, personnel were
knowledgeable, FME controls during the SX 'ower fill replacement were good, and
issues were identified by maintenance personnel. The inspectors concluded that
observed maintenance activities were well conducted,
M1.2 Surveillance Observations (61726)
a. Inspection Scooe
The inspectors observed the performance of all or parts of the following surveillance
test procedures. The inspectors also reviewed plant equipment and surveillance
testing activities against the UFSAR descriptions.
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1BOS 0.5 2.SI.2-2.1 Safety injection System and Spurious Valve Actuation
Group Valve Stroke test 'A' Train
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1BOS 0.5 2.SI.3-1 Safety injection Isolation Valve Indication Test "A" Train
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2BOS 7.1.2.1.b 1 Motor Driven Auxiliary Feedwater Pump Monthly
Surveillance.
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2BOS 8.1.1.2.a 1 2A Diesel Generator Operability Monthly,
b. Observations and Findinos
The inspectors noted that proper authorization was routinely obtained from the
control room senior reactor operator (SRO) before the start of each surveillance test.
At the comp:etion of the surveillance test and after independent verification of system
restoration, the TS action requirement was cleared. The inspectors observed the
communications between operators in the control room and the auxiliary building,
and observed the coordination between the nuclear station operators and non-
licensed operators. Test instruments used were verified to be calibrated as
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applic:ble. The inspectors r: view:d complet:d sury:llianc3 t:sts and v:rif;;d th]
surveillanco t:sts m t the acceptance crit:ria.
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c. Conclusions
The inspectors concluded that, based on proper authorization, procedure adherence,
good communication and coordination, and verification that the surveillance
acceptance criteria was met, the observed surveillance testing was well performed.
M1.3 Poor Foreian Material Exclusion (FME) Control Observed in Unit 1 Containment
(71707)
a. InsMction Scoce_
The inspectors made a general inspection of the Unit 1 containment on November
17,1997. The inspectors reviewed NSWP A-03, * Foreign Material Exclusion,"
Revision 0, and discussed the FME issue identified below with a member of station
management,
b. Observations and Findinas
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The inspectors observed that the Unit 1 containment floor drain sump, on the 377
foot levelinside the containment missile barrier, had been roped off and had signs
designating the area as a foreign material exclusion area. The inspectors observed
two holes in the floor drain sump cover, each about 6 inches square, that were not
protected with FME covers. Another hole in the floor drain sump cover had an FME
cover, but the cover was pulled back, exposing the hole. Inside tho designated FME
area was a washer and several pieces of debris, immediately outside the FME area
on the floor were more pieces of debris. No personnel were monitoring the FME
area and no work or testing was being done on the floor drain sump.
NSWP A-03, Step 6 4.1 states that all system breeches must be covered where
possible except whc : the opening is attended, and work, inspection, or testing is in
progress that requires removal of the FME ccver.
The licensee noted that af,er the identification of the issue, hard covers were
installed to adequately prevent foreign material from entering the system. The
licensee also noted that the sump was scheduled for a complete inspection at the
end of the outage; therefore, the sump was not required to be an FME area.
However, the licensee did agree that the area was posted as an FME area and
should have met the requirements of NSWP A-03.
TS 6.8.1, " Procedures and Programs," required that written procedures shall be
established, implemented, and maintained for the applicable procedures
recommended in Appendix A, of Regulatory Guide 1.33, Revision 2. Regulatory
Guide 1.33, Appendix A recommended general procedures for control of
maintenance activities. The inspectors concluded that the failure to follow NSWP-A-
03 was a violallon of TS 6.8.1 (50-454 97022-02(DRP)).
.c. Conclusion
The inspectors concluded the foreign material control around the Unit 1 containment
floor drain sump on November 17,1997, was poor and not in accordance with the
station procedure governing foreign material control. The inspectors observed that
the sump was designated as an FME area and that there were two holes in the floor
drain sump cover, each about six inchss square, that were not protected with FME
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cov;rs. A third hole in th3 floor drein sump cov:r that h:d an FME cov:r, but the
cov r was pull:d b:ck, exposing the hole. Inside the designat:d FME area was a
w:sn:r and sev:rci pi:ces of d:bris, imm:dlatlly outside the FME ar a on the floor
were more pieces of debris. A violation was issued.
M1.4 28 CV Pumo Seal inlection Line Cleanina
During a routine inspection of the auxiliary building on November 21,1997, the
-inspectors noted that the seat injection lines fittings and connections discussed in
Section 03.1 had boron deposits again. The inspectors did not identify any water
and concluded that the leaks were small. The inspectors also noted that the
deposits had been previously identified by the licensee and an action request had
been written. The inspectors concluded that the licensee had taken appropriate-
actions to identify the new leaks; however, the maintenance conducted on
September 9,1997, to repair the previous leaks had been ineffective.
M2 Maintenance and Material Condition of Facilities and Equlpment
M2.1 Leakina Reactor Coolant System (RCS) Check Valves Prevents Performance of
Residual Heat Removal (RH) Surveillance (61726)
a. Inspection Scope
The inspectors reviewed the following docun ents: 2BVS 5.2.f.31, 'ASME [American
Society of Mechanical Engineers) Su veillance Requirements for Residual Heat
Removal Pump 2RH01PA," Revision 17; Operability Evaluation 97 58; OMa 1988,
Pari 6, *lnservice Testing of Pumps in Light Water Reactor Power Plants;" Updated
Final Safety Analysis Report (UFSAR), Chapters 5 and 6; and TS 3.5.2. The
inspectors also interviewed the system engineer.
b. Observations and Findinas
The inspectors observed the start of the surveillance test. The test had to be halted
because about 10 minutes after the 2A RH pump was started the pump _ suction
pressure increased, reaching about 128 pounds per square inch gago (psig) after
about 17 minutes. The 2B RH pump suction pressure increased to about 317 psig
because it equalized to the 2A pump discharge pressure. A special suction pressure
gage Installed for this surveillance had a range of 100 psig and the surveillance
could not be completed. After the 2A RH pump was secured,2A RH suction
- pressure increased to 279 psig then dropped slowly for about 15 minutes, and then
started to increase at a rate of about 50 psig per hour. Suction pressure was then
dropped to about 50 psig when the suction lines were vented.
The increase in suction prreure was caused by check valve (s) leakage in the RCS
cold leg injection lines. Since the pump recirculates, the pump suction pressure also
increased.
Operability evaluation 97 58 stated that a concern existed that during a small break
loss of coolant accident, the RH pump suction pressure could increase to the point
where the RH suction relief valve would lift, at about 450 psig. The evaluation stated
that the pump would be secured before the suction pressure would reach 450 psig
based on previous history of how fast the pressure was increasing and how fast
operators would secure the pumps according to 2 BEP 1, " Loss of Reactor or
Secondary Coolant,* Revision 1. Operator response time was based on simulator
observations. The operability evaluation did not state that the pressure would
continue to rise after the pumps were secured until the suction line was vented. The
12
__ _ _ _ _ _ _ _ _ _ _ - _ _ _
suction lin;s for a small break loss of coolant accid:nt. The shift manag:r said th:re
w;re non].
The inspectors not:d, howev r,2BEP 1 St:p 13 dir: cts th] operating
crew to cooldown and depressurize the RCS if pressure is above 300 psig, in
addition, operatlJns management personnel stated that caution cards would be
placed on the Unit 2 RH pump control switches to discuss the need to vent the
suction lines if the pumps are operated.
The inspectors verified that the condition with the leaking check valve was listed as
an operator work arr. 9d and that the licensee was working on a plan to identify and
repair or replace the ieaking check valves during the next Unit 2 refueling outage.
c. Coriclusion
The inspectors concluded that the material condition of the residual heat removal
system prevented the satisfactory conduct of the quarterly ASME surveillance as
written due to leaking RCS cold leg check valves. The inspectors concluded that the
licensee's operability evaluation for this condition was adequate but did not address
contingency actions for operators to take to prevent RH pump suction relief valve lift
during a small break loss of coolant accident.
M8 Miscellaneous Maintenance issues (92700,92902)
M8,1 Lqad Drop Durina Assembly of Steam Generator Replacement (SGR) Eauipment
(50001)
a. Inspection ScoDe
The inspectors reviewed the circumstances surrounding a heavy load drop. The
inspectors attended the initial fact finding meeting after the incident, observed the
area around the dropped load for potential impact on safety related equipment,
reviewed the licensee's root cause report, and discussed the event with licensee
management,
,
13
1
.
_
b. Observas.ons and Findinas
On Nov mber 5,1997, the licens:e's SGR contr:ctor was ass:mbling the structures
outside the Unit 1 containment that would be used for moving the new and old SG's
in and out of the containment. A 57,000 pound runway section was dropped from
about 60 feet in the air. At the time of the drop, the runway was being lifted into
place. When the crane operator stopped lifting, the load fell approximately 15 feet. .
The crane operator took immed!ste actions to stop the load from dropping and !
'
brought the load to a sudden stop. The sudden stop caused all four nylon rigging
'
straps to fall, which allowed the runway section to fall to the ground. The platform
was about 46 feet long by 10 feet tvide and 2 3 feet high. The platform sustained
considerable damage plus some additional damage was inflicted on another support
structure lying on the ground No injuries were identified and there was no evidence
of damage to any safety related equipment. The licensee formed a root-cause team
and conducted an investigation with the contractor that identified that the actual root ,
cause was unknown; however, the most probable cause was crane operator error.
Five potential scenarios that involved misuse of the crane brake were identified by
the root cause team. The mechanical inspection of the crane did not identify any
material condition concerns.
,
The inspectors monitored the licensee response and noted that the proper
individuals were promptly contacted for investigation and that the entire area was
quickly quarantined for the investigation.
The licensee took several corrective actions to prevent recurrence. Actions included
the following: briefs of all craft personnel on the event and a special meeting with
crane operators discussing the circumstances and corrective actions resulting from
the load drop; a complete crane inspection, including a load test; a maintenance
program review; walkdowns of various rigging devices; and additional emphasis on
communications methods.
c. C_onclusions
The inspectors concluded that the licensee responded appropriately, quarantined the
'
area and promptly performed a formal investigation.
Ill. Enaineerina
E1 Conduct of Engineering
E1.1 2B CV Pumo Fill and Vent Safety Evaluation 137551)
a. insoection Scope
The inspectors reviewed several aspects of the 28 chemical and volume control (CV)
pump work conducted by the licensee in September 1997. The inspectors reviewed
the licensee's temporary procedure change to 2BVS 1.2.3.1-2, "ASME surveillance
requirements for centrifugal charging pump 2B," revision 15, the associated safety
evaluation screening, the UFSAR, and PIF B1997-03144.
b. Observations and Findinas
On September 10,1997, a nuclear station operator (NSO) identified that a Byron
Operating Procedure (BOP) to fill and vent the 2B CV pump did not exist (see
Section 03.1). Due to the work on the pump mini-flow check valve, system
14 ;
.- --- __ . _ _ _ - - -. - _ --
l
-
engin : ring h d mad) a 1:mporary change to th> routine CV pump ASME test to
v:nt the mini-flow lino. The ASME 1:st flow path was through the mini flow
. r: circulation lin]; th:r: fore, the liccnste conclud:d that p;rforming the ASME 1:st
would ensure that the mini flow line was filled and vented. A ternporary procedure
change was required to change the return flow path from the normal line up, which
was to the CV pump suction, to the top of the volume control tank (VCT).
System engineering performed a safety evaluation screening on September 10,
1997, for the proposed temporary procedure change and concluded that a safety
evaluation was not required. The screening stated that the reason for the
realignment of the retum path was "to avoid air that may possibly be in recirculation
line from being sent directly to suction of CV pumps. . . ." The screening noted that
the recirculation line would still be isolated on a safety injection signal and seal water
return would still have a flew path to the top of the VCT. The inspectors noted that
the recirculation line combined with the reactor coolant pump seal water return line
prior to entering the top of the VCT or the CV pump suction line. The inspectors
also noted that the Updated Final Safety Analysis Report (UFSAR) stated that the
seal water return lino was normally aligned to the suction of the CV pumps.
However, the NSO identified in a PlF that the screening did not consider the
, potential introduction of oxygen into the gaseous waste processing system (GWPS).
Section 11.3.2.1 of the UFSAR stated the following:
"The gaseous waste process'.ng system (GWPS) processes hydrogen stripped
from the reactor coolant and nitrogen from the closed cover gas system. The
components connected to the GWPS are limited to those which contain no air or
aerated liquids in order to prevent the accumulation of oxygen in the system.
Further, the GWPS is maintained at a pressure above atmospheric to avoid
intrusion of air. . . . Hence, the GWPS will normally not contain oxygen and
special design precautions are taken in order to avoid unintentional intrusion of
oxygen."
The NSO noted that the VCT was a component connected to the GWPS and the
inspectors noted during a piping and instrumentation drawing (P&lD) review that the
VCT was vented to the GWPS.
The shift manager noted that the system engineer, a chemist, the unit supervisor,
and the shift manager determined that the potential addition of oxygen would not
affect the VCT hydrogen concentration and therefore was not a significant concern.
Thus, the shift manager concluded that no safety evaluation was required. Chemists
sampled the VCT gas following the venting activities and the sample showed 0.02
percent oxygen in the gas space. The inspectors discussed the conversation with
the system engineer. The engineer confirmed that the conversation occurred and
that the conclusion was there was not a significant concem.
The inspectors discussed the issue with members of station management. Initially,
the licensee believed that since the activity was a maintenance activity and not
routinely performed, the potential ado, bon of oxygen to the GWPS did not require a
safety evaluation. The licensee noted that if a modification or change in operating
procedure was planned that added a per.1anent or continuous addition of oxygen to
the GWPS, taen a safety evaluation would be required. The inspectors believed that
the maintenar :e activity not routinely performed required a safety evaluation. Later,
during additional discussions with licensed management, the licensee indicated that
if there had bet n a question concerning how much oxygen would be vented to the
VCT, a safety e 'aluation would have been required. The inspectors noted that the
licensee had not evaluated the design or licensing basis allowable amount of oxygen
in the GWPS, noi did the licensee have an estimate of how much oxygen would be
15
-.
_. -
___ _ ___ _ __ _- - - - -
add:d prior to conducting the pump VInting.
Titb 10 CFR Pcrt 50.59, Chang:s, tests and experim2nts, r;quir:d that th]
licensee maintain records of changes in the facility and of changes in procedures
made pursuant to 10 CFR 50.59, to the extent that the changes constituted changes
in the facility described in the safety analysis report or to the extent that they
constituted changes in procedures as described in the safety analysis report. The
records must include a written safety evaluation which provided the bases for the
determination that the change, test, or experiment did not involve an unreviewed
safety question. The Inspectors concluded that the failure to perform a written safety
evaluation for the potential addition of oxygen to the gaseous waste processing
system may be a violation of 10 CFR 50.59. This is an unresolved item pending
further NRC review (50 454/455 97022 03(DRP)).
c. Conclusions
The inspectors concluded that the licensee had several opportunities to perform a
safety evalue" 7. An NSO identified the UFSAR section that referenced the GWPS
and requested a safety evaluation be performed. The inspectors noted that the
original safety evaluation screening was written to make a temporary procedure
change to avoid air that may possibly be in the recirculation line from being sent
directly to suction of CV pumps. The inspectors concluded that the screening failed
to evaluate allintegrated plant operations. Additionally, the temporary procedure
change was required to compensate for the lack of a standard operating procedure
to fill and vent the pump (see Section 03.1). This is an unresolved item pending
further NRC review.
E1.2 Ememency Core Coolina Vent Valve Not Vented (37551)
a. Inspection Scopjlt
The inspectors reviewed the licensee's identification of two safety injection (SI)
valves that wore not included in the monthly emergency core cooling system (ECCS)
venting surveillance test, included was a review of SI, chemical and volume control
(CV), and residual heat removal (RH) drawings and valve line ups. A comparison of
ECCS vent valves, identified by the inspectors, to the monthly venting procedure,
1BOS 5.2.b 1, Revision 6, was also performed. Licensee event reports (LERs)
454/97-009 and 454/97-018 were reviewed along with the corrective actions resulting
from a previously identified ECCS venting violation, documented in NRC Inspection
Report No. 50-454/455 97009.
16
'
.. - , - - _ .
b. Observations and Findinas
C t October 23,1997, the licens:e id:ntifi;d that two v:nt valv:s wero not includ:d
in he monthly Unit 1 ECCS venting surveillance test. The inspectors noted that the
valves,1S1051 and 1S1052 (Sl pump to 1A/1D and 1B/1C hot leg vents, for A and B
train respectively) were not identified during previous immediate corrective actions
for a missed TS surveillance, in May 1997, the inspectors identified that 1RH027, an
RH vent valve, was not vented as required by TS. A pre-decisional enforcement
- conference was held on September 11,1997, to discuss several TS compliance
issues, including the failure to vent the ECCS systems appropriately. One example
was the fa9ure to include 1RH027 In the monthly venting surveillance test.
Discussions with the licensee indicated that site engineering was preparing a
modification to add hard pipe to several ECCS vent valves. The modification was to
route vented water to the floor drain system, enhancing the verting capabilities of the
system. An ECCS system engineer was assisting in the review and noted valves on '
the list that he did not remember being included in the venting surveillance test.
Further research by the system engineer confirmed that 1S1051 and 1S1052 were not
in the venting procedure. TS 3.0.3 and 4.0.3 were entered for missed surveillance
testing and the venting completed after a temporary procedure change was
completed to 1BOS 5.2.b 1. No air or gas was identified. '
The inspectors' ECCS drawing review identified that the isometries and the piping
and instrumentation drawings (P&lDs) clearly identified tne vent valves. The Si
system valve line up also clearly identified 1Sl051 and 1Sl052 as vent valves.
c. Conclusions
The inspectors concluded system engineering identified that 1S1051 and 1S1052
were not included in the monthly venting surveillance during the corrective actions
following identification of 1RH027 not being included in tt > surveillance test.
E1.3 Material Handlina System in the Fuel Handlina Buildina (50001).
a, inspection Scooe
.During the inspection period, the inspectors noted that the licensee had removed
mechanical stops on the Fuel Handling Building (FHB) crane. The inspectors review
included the following: Special Plant Procedures (SPP) 97125 and 97-136; portions
of safety evaluation 6H 97-0048; portions of calculation SG BYR 96153, " Material
Handling System;" TSs ; the Updated Final Safety Analysis (UFSAR); and NUREG
0612. " Control of Heavy Loads at Nuclear Power Plants."
b. Observations and Findinas
The inspectors reviewed the licensee's plans for moving heavy loads (gre wer than
2,000 pounds) through the FHB into the Unit 1 containment. During the .uview, the
inspectors identified that the licensee designed and built a material handling system
. (MHS). The MHS consisted of existing rails that were next to one end of the spent
fuel pool (SFP), additional elevated rails for entering the containment buliding
through the equipment hatch, a cart, and a winch to pull the cart along the rails. The
cart included three significant features, rollers to move the cart along the rails
adjacent to the SFP, a_" lazy susan" to rotate the upper portion of the cart into
alignment with the equipment hatch, and an upper set of rollers that, when unpinned.
. allowed the load to be rolled along the elevated rails into containment.
17
-__ _ - - - - - - - - - - - - - - - - - - - - - -
The inspectors tsvi;w of the UFSAR indicat:d that two types of accid:nts in the FHB !
! w:ro analyz:d, a fu:1 handling accid:nt involving dropping a fuel cas:mbly, and a
I
sp:nt fu:1 cask drop accid:nt. The UFSAR succ:ssfully analyz:d the fu:1 handling
j accident. The inspectors noted that a fuel cask drop into the SFP was not analyzed.
4
Detailed explanation was provided in the UFSAR to demonstrate that a cask would
not drop into the SFP.
]
'
Heavy loads, as much as 20 to 30 tons, were scheduled to be moved along the
entire width of the spent fuel pool on the MHS cart The inspectors were concerned
that a new accident not previously analyzed in the UFSAR had been created,
specifically, either a seismic event or load handling accident potentially causing the 1
load on the cart to fallinto the SFP. The inspectors review of the safety evaluation
noted that the licensee planned to tether the heavy loads with the FHB crane while
- the load was moved along the width of the spent fuel pool. Based on the tether and
,
the safety margin of greater than 10:1 for the crane's wire rope, the licensee
determined that a creditable accident was not possible.
! Additional actions taken by the licensee included the construction of a large platform
that was placed over the end of the SFP, creating an additional barrier to the SFP ;
- and a walkway approximately 5 feet wide. Spent fuel was also removed from the
two storags racks in the SFP immediately adjacent to the wall that supported the
- MHS, The d.ensee also noted that, although the FHB crane was not seismically
4
qualified to rated capacity, it was seismically qualified to 20 percent of rated capacity,
i
,
The inspectors considered the licensee's actions compensatory measures for the ;
postulated seismic event or load handling accident. The inspectors considered the
.
issues a potential violation of 10 CFR 50.59, " Changes, tests, and experiments,"
!
which stated that a licensee may make changes to the facility as described in the
i UFSAR without prior NRC approval unless the change involves an unreviewed
i
safety question (USQ). An unreviewed safety question included the possibility that
j an accident or malfunction of a different type than any evaluated previously in the
f
UFSAR may be created. The inspectors concluded that a heavy load drop of this
'
type into the SFP was not previously evaluated in the UFSAR. The inspectors
! considered the potential for an MHS USQ an unresolved item pending further NRC
j review (50-454/455 97022 04(DRP)).
4
- c. Conclusions
e
i
The inspectors concluded that although the licensee's actions appeared appropriate,
the potential for a USQ existed; therefore, further NRC review was required and an
unresolved item opened to track the issue.
4
f
r
i
r
18
_ _ _ _ _ _ _ _ _ _ _ _ ._ _ _ _ __, - - _ _
E8 Misc:llane:us Engineering issu:s
E8.1 - (Closed) LER 50-454/97 018: Missed ECCS Vcnting Surveillance dua to In:ffective
Supervisory Methods. The inspectors reviewed the event and Section E1.2
documents the inspectors' findings. The inspectors concluded, after a review of the
corrective actions identified in the LER, that the actions were appropriate. This LER
is closed.
IV. Plant Supp_oA
R1 Radlological Protection and Chemistry (RP&C) Controls
R1.1 Radioloalcal Work Practices
a. inspection Scope (71750)
The inspectors routinely inspected the status and posting of radiologically controlled
areas,
b. Observatipns and Findinas
During an inspection in the spent fuel pool area of the fuel handling building
(elevation 420) on November 24,1997, the inspectors observed individuals moving
various pieces of equipment using an overhead hoist that could be trolleyed along an
overhead track. The equipment was trolleyed over a posted contamination area that
was directly below the path of the hoist. The inspectors noted that while the
individuals trolleyed the load over the contamination area, it contacted several pieces
of equipment stored within. Radiation protection personnel noted this, stopped the
movement, and took contamination surveys of both the load being trolleyed and the
equipment it had contacted. No loose contamination had been spread outside the
posted area. During subsequent movement of equipment over the same
contar-Mation area, the inspectors noted that the individuals allowed the hoist's
chainfalls to drag across the contamination area posting knocking it down Radiation
protection personnel responded immediately to re erect the posting. During the next
movement of equipment, the inspectors again noted that individuals allowed the
holsts chainfalls to drag across the contamination area posting knocking it down.
c. Conclusions
The inspectors concluded that problems observed with the movement of equipment
within the spent fuel pool area of the fuel handling building demonstrated poor
radiological work practices and a disregard for contamination area postings by
personnel conducting the work, An RP technician took prompt, appropriate actions.
)
19
V. Manaaement Meetinas
X1 Exit Coeting Summar)
The inspectors presented the inspection results to members of licensee management
at the conclusion of the inspection on December 1,1997. The licensee
acknowledged the findings presented. The inspectors asked the licensee whether
any materials examined during the inspection should be considered proprietary. No ,
proprietary information was identified,
,
9
R
!' 20
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-
. . . - - - - - - - . - - - - - - - - - -- - - - -
PARTIAL LIST OF PERSONS CONTACTED
Licensee '
K. Kofron, Byron Station Manager
J. Bauer, Health Physics Supervisor
D. Brindle, Regulatory Assurance Supervisor
E. Campbell, Maintenance Superintendent
T. Gierich, Operations Manager
B. Israel, Site Quality Verification Supervisor
T. Schuster, Manager of Quality & Safety Assessment
M. Snow, Work Control Superintendent
- D. Wozniak, Eng!neering Manager
= ,
21
INSPECTION PROCEDURES USED
IP 37551: Onsito Engin:cring
IP 50001: Steam Generator Replacement !nspection
IP 61726: Surveillance Observations
IP 62707: Maintenance Observations
IP 71707: Plant Operations
IP 71750: Plant Support
IP 81070: Access Control - Personnel
IP 92700: Onsite Follow up of Written Reports of Non routine Events at Power Reactor
Facilities
IP 92901: Follow up - Plant Operations
IP 92902f Follow-up - Maintenance
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
50-454/455-97022-01 VIO Inadequate procedure for CV pump fill and vent.
50-454-97022-02 VIO Failure to follow procedure NSWP-A-03
50-454/455 97022-03 URI Potential failure to perform a written safety evaluation for
the potential addition of oxygea to the gaseous waste
processing system.
50-454/455-97022-04 URI Potential unreviewed safety question for operation of a
material handling system adjacent to the spent fuel pool,
Closed
50-455 97020-02 IFl. 2B CV Pump Ma_intenance Window,
50-454 97-018 LER Missed ECCS Venting Surveillance due to ineffective
Supervisory Methods
.=_
22
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LIST OF ACRONYMS USED
ASMe Arderican S:c!:ty of ;, ..;hanical Engin rs
BAP Byron Administrative Procedure
4 BEP Byron Emergency Procedure
, BFP. Byron Fuel Handling Procedure
BMP Byron Mechanical Maintenance Procedure
BOP Byron Operating Procedure
'
BRP Byron Radiation Protection Procedure
CV Chemical and Volume Control
DG Diesel Generator
, DRo Division of Reactor Projects
DRS Division of Reactor Safety
ECN Equipment Component Number
4
'
FHB Fuel Handling Building
FME Foreign Material Exclusion
GWPS Gaseous Waste Processing System l
HLA Heightened Level of Awareness i
LCO Limiting Condition for Operation :
LCOAR Limiting Condition for Operation Action Requirement
'
-LER Licensee Event Report
! MHS Material Handling System
4 NSO Nuclear Station Operator
.
NSWP Nuclear Station Work Procedure
OOS Out-of-Service
) OSR Onsite Review
- PDR Public Document Room
P&lD Piping and Instrumentation Drawing
PIF Problem Identification Form
PSIG Pounds par Square Inch Gage
RH Res! dual Heat Removal
,
SER Security Event Report
.SFP Spent Fuel Pool
-
SGR Steam Generator Replacement
SI- Safety injection
SPP Special Plant Procedure
SRO Senior Reactor Operator
'SSPS Solid State Protection System
SX Essential Service Water System
TS Technical Specification
UFSAR Updated Final Safety Analysis Report
USQ Unreviewed. Safety Question
VCT Volume Control Tank '
WR Work Request
4
'
23
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