ML20211G118

Corrected NOV from Insp on 970314-0501.Rev to Reflect Proper Violation Number & Remove Clerical Error

ML20211G118
Person / Time
Site:	Byron
Issue date:	09/16/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20211G098	List: IR 05000454/1997005 ML20211G094 ML20211G118
References
50-454-97-05, 50-454-97-5, 50-455-97-05, 50-455-97-5, NUDOCS 9710020023
Download: ML20211G118 (8)

Text

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. NOTICE OF VIOLATION Commonwealth Edison Company Docket Nos. 50-454; 50-455 Byron Station, Units 1 and 2 License Nos. NPF-37: NPF-66 During an NRC inspection conducted from March 14 through May 1,1997, one violation of NRC requirements was identified. in accordance with NUREG 1600, " General Statemont of Policy and Procedure for NRC Enforcement Actions," the violation is listed below:

1. 10 CFR 73.21(b)(3)(i) describes safeguards information to include " portions of safeguards inspection reports, evaluations, audits, or investigations that disclose...

uncorrected defects, weaknesses, or vulnerabilities in the system."

~10 CFR 73.55(c)(9)(iii) requires licensees to protect as safeguards information, information required by the Commission pursuant to 10 CFR 73.55(c)(8)(Vehicle Control Measures) and (c)(9)(Bomb Blast Analysis).

10 CFR 73.21(e) states in part, "Each document... that contains Safeguards Information... shall be marked " Safeguards Information" in a conspicuous manner to indicate the presence of protected information...."

10 CFR 73.21(d)(2) states, in part, "While unattended, Safeguards Information shall be stored in a locked secunty storage container."

Contrary to the above, during the inspector's review of the records pertaining to the vehicle barrier system (VBS), a memorandum from the Engineering Department dated March 7,1996, was noted in the file system. The memorandum contained Safeguards information which described some uncorrected vulnerabilities with some components of the VBS. The memorandum was not marked and protected as Safeguards Informatien (50-454/455/97005-07(DRS)).

This is a Severity Level IV violation (Supplement Ill).

Pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region 111, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting the Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in the Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any pertonal privacy, proprietary, or safeguards 9710020023 970916 P DF, ADOCK 05000454 G PDR

EXECUTIVE

SUMMARY

Byron Generating Station, Unito 1 & 2 NRC Inspection Report 50 454/97005, 50-455/97005 This inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers a 7-week period of resident inspection.

Ooerations On March 14,1997, Unit 2 was shutdown. The inspectors concluded that excellerit operator performance was demonstrated during the shutdown activities (Section 01.2).

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The Unit 2 startup and main generator synchronization to the grid was completed in '

a well controlled manner. The inspector noted judicious troubleshooting, evaluation, and repair of the main generator output circuit breaker control switches (Section 01.3).

The licensee's handling of the containment leak detection system was considered poor as exemplified by failure to control foreign materialintrusion into the drain system and failure to take thorough aggressive followup action on indications. that the system was not functioning properly. The early leak detection of a small reactor coolant leak in containment was significantly compromised. The only seismically qualified leak detection system at Byron was inoperable. This condition w9nt unidentified by the licensee for over 5 months. Additionally, appropriate drain grates as described in the Updated Final Safety Analysis Report (UFSAR) had not been installed since plant construction. Three apparent violations were identified (Section O2.2).

The inspectors considered the questioning attitude of the operations staff regarding the performance of a special test to be judicious and a strength. As a result the procedure was enhanced with contingencies for roll-up door failure and weather (Section 02.3).

The licensee event report (LER) 50-455/97001, Unit 2 Containment Drain System Clogged Due to Debris, was poor and marginally acceptable due to incomplete information. One apparent violation was identified regarding the incomplete information in the LER. (Section 08.1).

Maintenance Routine maintenance and surveillance activities were well performed (Sections M1.1 and M1.2).

The licensee and the inspectors noted that sitt accumulation in the ultimate heat sink was faster than had been pieviously observed (Section M1.2).

The inspectors considered the suspension of a special test involving the auxiliary building ventilation appropriate so as to not exceed technical specification (TS) limitations (Section M1.2).

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c. Conclusions The licer. sees handling of this issue was considered poor as exemplified by failure to control foreign materialintrusion into the drain system and failure to recognize indications that the system was not functioning properly. The inspectors concluded that early leak detection of a smallleak was significantly compromised. The only seismically qualified leak detection system at Byron was inoperable for over 5 months and went unidentified by the licensee during that time. Additionally, appropriate drain grates as described in the UFSAR had not existed since construction. The UFSAR provided apparently contradicting information regarding the leak detection systems seismic qualificatM O2.3 Re-Evaluation of Soecial Test

' The inspectors noted that special test SPP 97-010, "ECCS Equipment Room Negative Pressure Test," was delayed due to the questioning attitude of the operations staff. The test was used to determine if the access planned to be cut in Unit 1 containment for the replacement steam generators created a ventilation problem in the auxiliary building, particularly in the emergency core cooling system (ECCS) component rooms. The licensee used the roll up doors in the fuel handling building to simulate the containment opening.

In discussing the test prior to performance, a unit supervisor stated that failure to meet te~t requirements would require both units to shut down per TS 3.0.3 requirements because all three charcoal booster fan subsystems of the auxiliary building ventilation system would be inoperable. Further discussion resulted in the 4

test delay to revise the test procedure to better discuss operator actions for test f ailure and contingency actions for roll-up door failure and outside weather conditions. The inspectors considered the questioning attitude of the operations staff to be judicious and a strength.

08 Miscellaneous Operations issues (92700 and 92901) 08.1 (Closed) LER 50-455/97001: Unit 2 containment drain system clogged due to debris. The circumstances surrounding the clogged containment floor drain are documented in Section 02.2. The inspector reviewed the LER and noted one apparent violation and several weaknesses. The findings included:

The LER did not declare the containment floor drain system inoperable.

However, the LER did identify the flow control device was inoperable (clogged).

The safety analysis section discussed the consequences of not having the system operable.

The LER was issued for Unit 2 being outside the design basis. With the floor drains inoperable since October.1996, the licensee was also apparently in violation of TS 3/4.4.6, which was reportable under 10 CFR 50.73(a)(2)(i). The LER did not identify the TS violation.

i The LER indicated that it could not be determined when the flow control device became clogged. However, the system engineer reported to the inspectors that ROFC condensation could not be identified on the control room recorder for 8

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• 2RF008 since the startup aftnr the Unit 2 outage, which ended October 4,

' 1996. The condensation trace was present prior to the outage; therefore, the inspectors concluded the system was inoperable since the Unit 2 startup on October 4,1996.

An operability assessment was prepared to allow startup of Unit 2 without fixing the floor grates. The LER stated that " debris could p6tentially impact the containment sump RCS leakage weir box. However, any impact on the weir function would be in the conservative directen with respect to indicated RCS leakage and therefore not a concern." The inspectors noted that without the floor drain grates, the potential existed for the flow control device to become clogged and not pass any water to the weir box. The inspectors discussed the LER statement with engineering management. The licensee agreed with the

. inspector that the LER statemunt was incomplete as written. The inspectors considered the incomplete statement an apparent violation of 10 CFR 50.9,

" Completeness and accuracy of information" (eel 50-455/97005-04(DRP)).

The inspectors considered portinns of the LER safety analysis weak. The LER stated that " floor drains would ultimately overflow to the RF sump after a period of time before detecting leakage. The sump would then show an increase in level on instrumentation in the control room." The inspectors noted that overflow into the sump depended on the size of a potentialleak. For a small leak, this could be a very long period of time. The RF system design was to identify a 1 gallon per minute leak within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Also, the LER indicated that radiation monitoring could be used as leak detection; however, the inspectors noted that the radiation monitors were not as described in Regulatory Guide 1.45 (the radiation monitors were not seismic).

The object (s) that caused the blockage in the flow control box were not found.

The floor drain oil separator was checked as indicated in the LER corrective action section; however, because the separator was not drained, only floating objects could have been identified by the inspection documented in the LER. A pump down of the separator was plantled for the next refueling outage. The inspectors viewed this as acceptable.

The inspectors considered LER 50 455/97001 poor and marginally acceptable due to incomplete information. This LER is closed and will be tracked under apparent violation 50-455/97005-04(DRP).

08.2 (Closed) LER 50-454/94015 and 94015-01: SRO absent from control room. The LER and LER supplement documented the event of October 14,1994, when the only SRO present left the main control room. The supplement identified additional corrective actions, including having two SROs in the control room. This event was the subject of escalated enforcement and was documented in Inspection Report 50-454/455/94026(DRS), EA 94-265, inspection Report 95011 documented closure of the violations, including review of the corrective action. The inspectors did not identify any additional issues during the LER review. This LER and the supplement are closed.

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0 08.3 (Closec') VIO 50-454/455/95008-01, 50-454/455/95008-02.

' 10 454/455/95008-03. eel 50-454/455/95008-04. LER 50-454/95002: Hydrogen monitors inoperable due to failure to test the water purge cycle of the monitors and the monitors were occasionally not run for greater than the minimum required sample time. These issues were identified as violations in Inspection Report 95008 and a written response was submitted by the licensee on November 22,1995.

After review of the licensee's written response and the LER, an NOV was issued December 11,1995 (EA 95197). The NOV cover letter documented a review of tha licensee's corrective actions and LER, and concluded that no further action was required. Based on the letter dated December 11,1995, these items are closed.

08.4 (Closed) URI 50-454/455/96004-04. LER 50-454/96005: Operation of safety injection (SI) accumulators outside design basis. Based on an industry identified issue, Byron identified that the plant licensing basis did not consider the effects of having more than 2 Si accumulators cross-tied during ajostulated loss of coolant accident. Byron Operating Procedure (BOP) SI-5, " Raising St Accumulator Level With St Pumps," allowed the cross-tying of Si accumulators. Although the inspectors and licensee could not find any documentation that stated how many accumulators were tied to the common headers at any one time, operator interviews indicated that more than 2 accumulators may have been cross-tied in the past. As corrective actions, procedure BOP SI 5 was revised to limit filling or draining processes to be p' erformed on one accumulator at a time. Transferring of water from one accumulstor to anoiner or equalizing nitrogen pressure between accumulators was limited to modes when the accumulators were not required to be operable. The inspectors reviewed the revised procedure and verified that accumulator filling and draining had been performed one accumulator at a time, These items are closed.

08.5 (Closed) LER 50-454/92002-01: On April 3,1992, the licensee identified that one of the two engineered safety feature (ESF) crossties to Unit 1 was not available. A Unit 2 to Unit 1 crosstie breaker was removed from service for electrical maintenance without considering the TS impact on Unit 1. Unit 1 was unable to crosstie a 4kV ESF bus (bus 141) due to maintenance activities on the Unit 2 crosstie breaker. TS limiting condition for operation (LCO) 3.8.1.1 was not entered and the associated action requirement not met. This event was discussed in

-Inspection Report 454/92015. A non-cited violation was issued and no new issues were revealed by the LER. The inspector reviewed the licensee's corrective actions and considered this issue closed, ll. Maintenance M1 Conduct of Maintenance M 1.1 Maintenance Observations (S2707) a, insoection Scoce The inspectors observed all or portions of the following work requests (WR). When applicable, the inspectors also reviewed TS and the UFSAR for potential issues.

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ITFMS OPENED, CLOSED, AND DISCUSSED QDftDftd eel 50 455 97005-01 eel Inoperable containment floor drain system eel 50-455 97005-02 eel Failure to identify a condition adverse to quality eel 50 455 97005 03 eel Failure to perform a safety evaluation for various types of grates in containment floor drain system eel 50-455-97005-04 eel Failure to provide complete and accurate information in LER 50-455/97001 50-454/455 97005-05 URI Connecting strip chart recorders to operable equipment without a detailed review 50-454/07005-06 NCV Missed surveillance during SG tube inspection 50-454/455 97005-07 VIO Failure to mark and protect Safeguards information Closed 50-454/92002-01 LER One of the two ESF crossties to Unit 1 was not available 50-455/94001 LER Six valves may not stroke under dP conditions 50-454/94012 LER increased tube degradation in Unit 1 SGs 50-454/94015 LER SRO absent from control room 50 454/94015-01. LER SRO absent from control room - supplement 50-454/95002 LER U-1 train B hydrogen monitor found inoperable 50 454/95006 LER Missed surveillance during SG tube inspection 50-454/95011 LER increased tube degradation in Unit 1 SGs 50-454/96003 LER increased tube degradation in Unit 1 SGs 50-454/96005 LER Operatic, of Si accumulators outside design basis 50-455/97001 LER Unit 2 containment drain system clogged due to debris, 50-454/97005-06 NCV Missed surveillance during SG tube inspection 50-454/455/95007-03 VIO Seismically inadequato scaffolding over safety-related equipment 50-454/455/95008 01 VIO 4 examples of TS 3.6.4.1 violations 50-454/455/95008-02 VIO Apparent violation of TS 6.8.1 and BAP 3001 50-454/455/95008-03 VIO Apparent violation of TS 6.8.1 and BOS 0.1-1,2,3 50-454/455/95008-04 eel Apparent violation of 10 CFR 50 454/455/96010-05 URI Protection of safeguards information 50-454/455/96004-04 URI Cross-tied safety accumulators 50-454/96003-06 IFl Overpressure protection device found out of service 19 l

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LIST OF ACRONYMS USED BAP Byron Administrative Procedure BOP Byron Operating Procedure DCP Design Change Package dP Dif ferential Pressure ECCS Emergency Core Cooling System -

EP Emergency Preparedness I

FME Foreign Material Exclusion GPM Gallons per minute HEPA High Efficiency Particulato Air HLA Heightened Level of Awareness LCO Limiting Condition for Operation LER Licensee Event Report NOV Notice of Violation OAD Operational Analysis Department PDR Public Document Room RCFC Reactar Containment Fan Coolers RCS Reactor Coolant System RF Containment Floor Drain System SG Steam Generator SI Safety injection ,

SRO Senior Reactor Operator SSE Safe Shutdown Earthquake TS Technical Specification TSC Technical Support Center UFSAR Updated Final Safety Analysis Report VBS Vehicle Barrier System WR Work Request 20

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