ML20212R359
| ML20212R359 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 01/21/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20212R346 | List: |
| References | |
| 50-454-87-01, 50-454-87-1, 50-455-87-01, 50-455-87-1, NUDOCS 8702020612 | |
| Download: ML20212R359 (35) | |
See also: IR 05000454/1987001
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SALP 6
SALP BOARD REPORT
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
!
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
50-454/87001; 50-455/87001
Inspection Report No.
Commonwealth Edison Company
Name of Licensee
Byron Station Units 1 and 2
Name of Facility
.,
November 1, 1985 through October 31, 1986
Assessment Period
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8702020612 870121
ADOCK 05000454
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BYRON STATION
TABLE OF CONTENTS
Page No.
I.
INTRODUCTION
1
II. CRITERIA
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III. SUMMARY OF RESULTS
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IV. PERFORMANCE ANALYSIS
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A.
Plant Operations
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B.
Radiological Controls
6
C.
Maintenance
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D.
Surveillance
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E.
Fire Protection
12
F.
13
G.
Security
15
H.
Outages
17
1.
Quality Programs;and Administrative Controls
Affecting Quality
18
J.
Licensing Activities
20
K.
Training and Qualification Effectiveness
22
L.
Preoperational Testing
23
M.
Construction
26
V.
SUPPORTING DATA AND SUMMARIES
28
A.
Licensee Activities
28
B.
Inspection Activities
28
C.
Investigations and Allegations Review
30
D.
Escalated Enforcement Actions
30
E.
Licensee Conferences Held During Assessment Period
31
F.
Confirmatory Action Letters (CALs)
31
G.
Review of Licensee Event Reports, Construction
Deficiency Reports, and 10 CFR 21 Defect Reports
Submitted by the Licensee
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H.
Licensing Activities
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1.
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. SALP is supplemental to normal regulatory processes used to
ensure compliance to NRC rules and regulations. SALP 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
January 8, 1987, to review the collection of performance observations
and data to assess the licensee's 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 Boards's assessment of the licensee's safety
performance at Byron Station Units 1 and 2 for the period November 1,
1985, through October 31, 1986.
SALP Board for Byron Station Units 1 and 2:
J. A. Hind, Director, Division of Radiation Safety and Safeguards
C. E. Norelius, Director, Division of Reactor Projects
C. J. Paperiello, Director, Division of Reactor Safety
R. F. Warnick, Chief, Reactor Projects Branch 1
,
J. M. Hinds, Jr., Senior Resident Inspector, Byron
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S. A. Varga, Project Director, NRR Division of PWR Licensing A
L. N. 01shan, Project Manager, NRR Division of PWR Licensing A
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II. CRITERIA
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The licensee performance is assessed in selected functional areas
depending whether the facility is in a construction, preoperational
or operating phase. Each functional area normally represents areas
significant to nuclear safety and the environment, and are normal
programmatic areas.
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 in assessing
each functional area.
1.
Management involvement in assuring quality
2.
Approach to resolution of technical issues from a safety standpoint
3.
Responsiveness to NRC initiatives
4.
Enforcement history
5.
Operational and Construction events (including response to analysis
of, and corrective actions for)
6.
Staffing (including management)
However, the SALP Board is not limited to these criteria and others may
be used where appropriate.
Based upon the SALP Board assessment each functional area evaluated is
classified into one of three performance categories. The definition
of these performance categories is:
Category 1:
Reduced NRC attention may be appropriate.
Licensee
management 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
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and/or construction quality is being achieved.
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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 effective so that satisfactory performance with respect
to operational safety and/or construction quality is being achieved.
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
be strained or not effectively used so that minimally satisfactory
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performance with . respect to operational safety and/or construction
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quality is being achieved.
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III. SUMMARY OF RESULTS
A total of 13 Functional Areas were rated in this SALP.
Licensee
performance in four areas improved from Category 3 to Category 2 so
that there were no Category 3's assigned in this SALP. Two Functional
Areas sustained Category 1 performance and five areas remained at
Category 2.
The Functional Area of Training and Qualification
Effectiveness had not been used in prior assessments and was rated a
Category 2.
As noted below, the Functional Area of Construction which
was also rated Category 2 is the combination of construction Functional
Areas used in prior assessments. These areas were combined due to
limited activity and inspection in this assessment period.
Rating Last
Rating This
Functional Area
Period
Period
Trend
A.
Plant Operations
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2
improving
B.
Radiological Controls
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2
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C.
Maintenance
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2
D.
Surveillance
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2
E.
Fire Protection
2
2
F.
1
1
G.
Security
3
2
improving
H.
Outages
1 (initial fuel load) 1
1.
Quality Programs and
Administrative Controls
Affecting Quality
2
2
J.
Licensing Activities
2
2
K.
Training and Qualification
2
Effectiveness
L.
Preoperational Testing
2
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M.
Construction
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Not rated as a separate functional area in previous SALPs.
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Construction during this assessment period includes the functional areas
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of Containment and Other Safety-Related Structures, Piping Systems and
Supports, Instrumentation and Control Systems, and Electrical Power Supply
and Distribution, which all received Category 2 ratings during the last
SALP assessment.
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IV. PERFORMANCE ANALYSIS
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A.
Plant Operations
1.
Analysis
Licensee activities in this functional area were observed in
portions of 14 inspections conducted by resident inspectors.
Due to the large amount of activity expected for Unit 1
startup and Unit 2 completion and licensing and due to the
Category 3 rating assigned in the last SALP, a third resident
inspector was assigned to the station. The operations
inspections focused on overall plant performance, operating
events, personnel errors, shift crew performance during normal
and off-normal conditions, shift relief and turnover activities,
control room discipline, and adherence to operating procedures.
The inspections included a review of logs and records, interviews
with plant personnel, and followup of significant operating events
to ascertain that the facility was operated in conformance with
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the Technical Specifications and administrative procedures.
The licensee's enforcement performance indicated minor and
isolated programmatic failures. One Severity Level V and four
Severity Level IV violations were identified.
In addition, the
licensee identified three violations of minor significance for
which, in accordance with 10 CFR Part 2, Appendix C, Notices
of Violation were not issued.
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From a review of the Licensee Event Reports (LERs) issued
during the assessment period, it was determined that the number
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of events involving personnel errors continues to represent
a significant portion of the total at 16 of 39. Licensed
operators were involved in 5 of the 16 personnel errors.
The Region has continuously reviewed the Unit 1 LERs and
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found them to be of an improved quality based on the 10 CFR
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50.73 requirements due primarily to a licensee LER improvement
program initiated in February 1986.
Features of the
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improvement program included additional training of all
personnel involved in LER preparation; increased supervisory
review,
i.e., supervisor listed as contact; designating
" Lead Reviewers"; format changes; LER writers guide and review
check list changes; and implementation of a diagnostic flow
chart to aid in root cause determination.
Improvement was also noted in the area of reactor trips.
During this period Unit 1 experienced six trips (two during
the last eight months of the assessment period) compared
with 31 during SALP 5.
Of these, two could be attributed to
operations; one was due to a personnel error, and the other
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to a defective procedure.
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Periodic management meetings between RIII and Byron Plant
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management, initiated during the previous SALP period by
Region III as a result of the high number of Unit 1 operating
events and personnel errors, continued through most of this
assessment period. As a result of concerns expressed by the
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NRC, the licensee developed and implemented an effective
improvement program in operations (and in other areas discussed
in later sections of this report).
The NRC has noted increased
licensee management involvement, increased responsiveness to
NRC concerns, and improvement in this functional area. Because
of improved plant performance and management involvement and
responsiveness, the periodic management meetings to review Unit
1 performance were terminated in mid-1986.
Examples of effective management involvement are: (1) a one
page daily status bulletin for all plant employees which
highlights the plant status, the critical work scheduled for
the day, and other significant information; (2) a monthly
report of performance indicators to measure performance trends,
and department goals; and (3) special attention to eliminate
nuisance alarm annunciators in the control room which resulted
in a " black board" at the beginning of 1986.
The effectiveness of station management's influence and
resulting operator implementation in the operations control
areas continues to be demonstrated by a high level of control
room discipline. Personnel access controls are enforced,
operators are cognizant and alert to plant conditions, and a
high level of professionalism is demonstrated at all times.
Although the activity level in the control areas has increased
with Unit 2 pre-operational testing and readiness for licensing
activity, the licensed operators and shift managers have met
the challenge and continue to maintain controlled areas free
from distracting or prohibited activity. However, one recently
noted control room distraction is the background noise caused
)
by the intercom speakers in the control room. The NRC
continues to view the licensed operators at Byron Station
as a highly professional, well trained, collectively motivated,
high quality operating team.
The Byron staff is stable and well organized and continues
to be a licensee strength with the only personnel turnovers
resulting from promotions and internal transfers, which have
added to management effectiveness. Qualifications and
experience levels within the staff have shown improvement
through the addition of licensed operators and continued
on-shift experience.
Staffing levels continue to be high
to ensure qualified and experienced operators are available
as Unit 2 approaches the Startup Test phase.
The licensee has continued to treat Technical Specification
interpretations with a conservative approach to technical
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safety issues.
Responsiveness to NRC concerns has been
thorough and overall the licensee was cooperative.
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2.
Conclusion
The licensee is rated Category 2 with an improving trend in
this area. The licensee was rated a Category 3 in this area
in the last SALP. The improved rating is based on significant
reduction in the number of events and in the overall improvement
of plant operations.
3.
Board Recommendation
None.
B.
Radiological Controls
1.
Analysis
Twelve inspections were conducted during this assessment period
by region based inspectors.
Inspection effort was increased
in response to poor licensee performance during the previous
assessment period. The resident inspector also reviewed this
area during routine inspections.
No violations were identified. This represents a significant
improvement over the previous assessment period when seven
violations were identified, including an aggregate of problems
cited in a Severity Level III violation which resulted in a
civil penalty.
Management involvement and control in assuring quality was
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much improved during this assessment period.
In response to
previously identified problems, licensee management committed
to aggressively identify and correct radiation protection
program weaknesses by developing a radiation protection.
improvement program. The positive effects of this strong
management involvement and support of the radiation protection
program resulted in significant improvements in that program.
An improving trend of positive management involvement was
observed during the assessment period, in particular concerning
staff emphasis on procedural adherence and increased
disciplinary action for procedural violations. Corporate
management involvement has also improved as evidenced by
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corporate investigation of several radiological occurrence
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reports. Chemistry group management provides satisfactory
oversight of laboratory operations and stays well aware of
plant chemistry conditions.
$taffing was generally adequate during the period.
Considerable
turnover was experienced with the replacement of the Radiation
Chemistry Supervisor (RCS) who was reassigned, the lead health
physicist, who transferred to the corporate offices, and two
staff health physicists who left. The RCS supervisor was
replaced by the Assistant Technical Staff Supervisor and the
lead health physicist was replaced by an experienced health
physicist with equivalent qualifications from another licensee
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nuclear plant. The Radiation Protection Manager (RPM) role
held by the former RCS was assumed by the new lead health
physicist. One staff health physicist was replaced and the
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other's duties have been assumed by contract professional
health physicists (five) hired to supplement the staff until
it acquires more experience. Staff qualifications in health
physics and chemistry meet current ANSI standards although
operational experience is low, which is not atypical for new
plants. The licensee's policy of rotation between chemistry
and health physics assignments limits radiological control
technician's (RCT) proficiency in the laboratory. RCT
experience is partially compensated by assignment of ANSI
qualified foreman to each shift. The weakness in the generic
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Ceco plant organization change (last assessment period) that
placed two intermediate management positions between the RPM
and the plant manager has been mitigated by regularly scheduled
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meetings between the two.
The licensee's responsiveness to NRC initiatives has generally
improved during this assessment period. Weaknesses concerning
radiological evaluations, airborne release calculations,
procedural adherence, RCT training, and radiation protection
awareness of workers were improved during this assessment
period. The licensee's reporting of incidents to the NRC was
better than required. However, the licensee has been slow to
determine the cause of anomalous readings of the monitor on
the waste gas decay tank effluent line.
The licensee's approach to resolution of radiological technical
issues has been adequate. Total personnel radiation exposure
for 1986 through August was approximately 45 person rems
reflecting good exposure control program design and
implementation during the early operation of the plant. The
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licensee's ALARA program is well organized but appears to
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require increased resource allocation to effectively complete
the work required prior to the Unit I refueling / maintenance
outage and the Unit 2 startup.
Several noteworthy ALARA
activities requiring further implementation include, ALARA
awareness sessions with each department, Unit 1 outage
preparations and discussions of planned jobs with each work
group, shielding and mock-ups for radiologically significant
outage jobs, and completion of the plant photo file. A design
change implemented during this assessment period to min %ize
neutron streaming near the personnel batch has not been as
successful as anticipated; further design analysis and
shielding attempts are planned. Solid radwaste shipments were
average for a PWR during the assessment period. There were
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no problems with transportation of radioactive material or
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radwaste during the assessment period.
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Licensee control of radioactive effluents has improved.
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One minor unplanned release occurred early in the assessment
period whereas five occurred during the previous period.
Gaseous effluents continued in the average range for U.S.
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pressurized water reactors.
Liquid effluents continued the
decline noted at tht end of the previous assessment period
and are also currently in the average range.
Licensee chemistry / radiochemistry performance has generally
improved. The chemistry group naintains very good awareness
of plant water chemistry through extensive sampling and
handling of key chemistry variables. Chemistry controls have
been generally satisfactory except for dissolved oxygen levels
in the primary water storage tank which consistently exceed
the Westinghouse 100 ppb guidelines. The licensee is
continuing to investigate the cause of the problem. Meanwhile
reactor coolant oxygen levels are being controlled within
limits by hydrogen addition.
The plant makes extensive use of in-line monitoring on the
secondary system including an ion chromatograph on the steam
generator blowdown.
Effective use is made of state-of-the-art
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instrumentation in the chemistry laboratory and counting
room. The station performed well in its first confirmatory
measurements split sample comparison with the NRC mobile
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laboratory by achieving 49 agreements in 50 comparisons.
Basic chemistry QA/QC programs have been established to
monitor instrument performance and technical performance
in the laboratory and counting room. Twice yearly testing
with unknown chemistry samples have indicated improving RCT
capabilities. Considerable improvement is needed in the
organization of QC data to make it more useful for routine QA
assessments and the scope of RCT testing needs to be expanded
to include more analyses. A corporate interlaboratory
comparison program currently under development for radiological
and nonradiological analyses is partially in place.
2.
Conclusion
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The licensee is rated Category 2 in this area. The licensee
was rated Category 3 in this area in the last SALP. The
improved rating in this area is attributed to strong management
involvement which continued throughout the SALP period.
3.
Board Recommendation
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None.
C.
Maintenance
1.
Analysis
Examination of this functional area consisted of two
inspections conducted by region based inspectors and portions
of thirteen inspections by resident inspectors.
Inspection
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effort by resident inspectors was increased with the assignment
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of a third resident inspector.
The inspections by resident
inspectors included a review and observation of the maintenance
programs, staffing, staff training, and records. Selected
preventative and corrective maintenance and system modifications
were observed to verify that these activities were completed
in accordance with Technical Specifications and the licensee's
quality assurance program requirements and administrative
procedures.
Followup inspections were performed on significant
equipment problems.
Discussions were held with craftsmen,
maintenance supervision, and plant management. One of the
Regional inspections was conducted to review the operational
maintenance program for Unit 1 and the other was conducted to
verify operational readiness in this area for Unit 2.
Four violations were identified, including two Severity Level
IV and one Severity Level V violations which represented
isolated failures by the licensee's programs. One Severity
Level III violation was issued after the SALP period for an
event that occurred within the period. This event was of
safety significance and was indicative of programmatic
failures of personnel to accomplish maintenance and quality
assurance programs as they were written.
In July 1986,
an inoperable Pressurizer Code Safety Valve was installed,
placed into service, and failed to function as required. The
violations resulted from inadequate administrative controls and
personnel errors in that after a Code Safety Valve was taken
out of service in 1985 for repair, the valve disc was removed
and only partial maintenance was performed. Subsequently,
because of improper segregation, identification, and test
documentation, the valve with the missing valve disc was
inadvertently placed back into service without being tested.
It was only after the valve actuated at a lower pressure than
intended that plant personnel became aware of problems with
the valve. The root cause of these violations was personnel
errors by a mechanical maintenance supervisor, a technician,
and a QC inspector. Also, after the July 1986 incident, the
replacement Pressurizer Code Safety Valves were tested and
accepted based on a lift setting of 2485 psig
3% rather than
1% as required by the Technical Specifications. One of the
replacement valves was actually set outside the i 1% Technical
Specifications limit. These violations are considered
significant and demonstrate weaknesses in the mainterance
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program. However, once licensee management became aware of
the Pressurizer Code Safety Valve problem, the licensee took
prompt and extensive corrective action at both the station and
corporate levels. The licensee's immediate corrective actions
included, among other things, meetings with appropriate
departments and stressing that test documentation must match
equipment being tested; revising test procedures to clearly
identify equipment; installing segregation cages for defective
components; and requiring Quality Assurance to independently
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verify proper disposition of nonconforming conditions. The
long term corrective actions included a broad look at all
maintenance activities by licensee management as well as an
evaluttion requested by the licensee of the Byron maintenance
program and activities by a team from the Institute of Nuclear
Power Operations (INPO). A licensee site task force performed
a review of the findings by INP0 and management and developed
a maintenance improvement program. The improvement progam has
been initiated and corrective actions are being implemented.
Overall, maintenance work performed was generally technically
sound, thorough, and timely. Records were generally complete,
well maintained, and available.
However, the NRC believes
that during the first part of the SALP assessment period,
appropriate management attention including accurate and timely
resolution of maintenance items was a weakness as evidenced
by the Code Safety Valve event discussed above. Subsequently,
management involvement in assuring quality in the maintenance
area has improved. Upon identifying areas requiring additional
management oversight, the licensee has generally provided
technically sound resolutions with good consideration of the
safety issues involved.
A review of cause codes for LERs shows 10 of 39 were
attributable to malfunctions. However, malfunctions include
the results of lightning and ice forming as well as radiation
monitor spurious signals causing ventilation realignments. No
maintenance program weaknesses were identified by LERs; however,
the licensee is including in the Maintenance Improvement
Program provisions for a preventative maintenance program which
assesses equipment failures.
The maintenance organization is adequately manned in all
positions with well-trained,* increasingly experienced personnel
who have demonstrated a growing measure of pride in their
workmanship.
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Inspections in the maintenance area have provided the NP.C with
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a reasonable level of confidence in the administration of an
overall sound program with adequately documented procedures
and records. The maintenance program (both corrective and
preventative) appeared to be adequate and properly implemented
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based on these inspections.
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2.
Conclusions
The licensee is rated Category 2 in this area. The licensee
was rated Category 2 in this area in the last SALP.
3.
Board Recommendation
None.
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D.
Surveillance
1.
Analysis
This functional area was examined in two inspections conducted
by region based inspectors and portions of thirteen inspections
conducted by resident inspectors.
Inspection effort by
resident inspectors was increased with the assignment of a
third resident inspector based, in part, on the Category 3
rating given this functional area in the last SALP.
Implementation of the surveillance program was 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.
Seven violations were identified for which Notices of Violation
were issued, five Severity Level IVs and two Severity Level Vs.
In addition, the licensee identified three violations for
which, in accordance with 10 CFR Part 2, Appendix C, Notices
of Violation were not issued. These violations represented
minor and isolated failures of the licensee's programs;
however, the total number indicates that there were areas
in need of program refinements and more attention to details.
Six Severity Level IV violations were identified in the last
SALP period.
During this assessment period the licensee reported 6 incidents
of missed or inadequately performed surveillances compared with
18 in the previous SALP. Of these, 5 were attributed to
personnel error, and 1 to defective procedures. Some of the
missed surveillances have resulted in violation of license
conditions, Technical Specifications, or NRC regulations;
however, performance in this functional area has shown a
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significant improvement in total incident occurrences when
considering the thousands of surveillances conducted.'
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Management involvement in this functional area was consistent
throughout the period. The licensee developed the Conduct
of Operations Improvement Program (COIP) during the last
assessment period and has continued to focus on implementation.
A feature of the COIP was to eliminate missed surveillances.
Based on NRC inspection findings over the current assessment
period it appeared that the program was technically sound and
has provided acceptable technical resolutions from a safety
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Management involvement in reducing the numbers of surveillance
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incidents has demonstrated a greater level of effectiveness
than the previous assessment period as the reduced number
indicates.
The licensee has demonstrated a willingness to
address this issue in response to NRC concerns expressed in
the monthly management meetings discussed in Section IV.A.,
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Operations. The licensee continues to devote 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 surveillance scheduling,
improving surveillance scheduling, increasing technical staff
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awareness and interaction with the operating staff, and
continuing to monitor and improve the corrective action items
designed to eliminate the problem. A review of the events
during this period indicated that these changes were effective
and resulted in improvements in this functional area.
2.
Conclusion
The licensee is rated Category 2 in this area. The licensee
was rated a Category 3 in this area in the last SALP. The
improved rating is based on the significant reduction in missed
or inadequately performed surveillance.
3.
Board Recomendation
None.
E.
Fire Protection
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1.
Analysis
During the assessment period, two inspections were conducted
by regional based inspectors. Areas reviewed included the
close out of open items from previous Appendix R inspections,
verification of the adequacy of the routine fire protection
program implementation, and continued NRC review of Unit 2
compliance with 10 CFR 50, Appendix R.
Portions of 19
inspections performed by resident inspectors observed fire
protection related activities in the plant. One Severity
Level IV violation was identified concerning two examples of
failure to properly control flammable materials in proximity
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to safety-related equipment (Inspection Report No. 455/86031).
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This violation indicated a reduction in licensee personnel's
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attention to fire protection precautions which merits
management attention.
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Housekeeping and the administration of fire protection programs
were generally found adequate through the assessment period.
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Increased management attention to housekeeping was necessitated
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during this assessment period by the construction activities
of Unit 2 in addition to Unit 1 startup test activities. While
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management was effective in maintaining high levels of
cleanliness, a significant number of shortcomings were
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highlighted to management by the NRC staff based on tours
of the plant. Housekeeping was at a greatly improved level
at the end of the assessment period and further improvements
in the painting of the plant were in progress.
During the Appendix R inspection, a review of the systems
required for safe shutdown including alternate shutdown
capability, a procedural review, and protection for associated
circuits was conducted. Within the majority of areas examined,
the licensee met Appendix R requirements; however, five new
items were identified.
Items such as areas with inadequate
emergency lighting and an Auxiliary Feedwater start switch
cable requiring relocation, although of some significance,
were not materially different from the types of items generally
discovered in Appendix R inspections. Subsequently, the
licensee initiated corrective action for certain of these
items prior to the departure of the inspectors from the site,
while the other items are currently being evaluated by the
licensee.
Management attention and the staffing of fire protection
activities were adequate. The training of fire protection
related individuals was appropriate and the overall level of
resources devoted to this area was sufficient to adequately
meet the needs.
2.
Conclusion
The licensee is rated Category 2 in this area. The licensee
was rated Category 2 in this area in the last SALP.
3.
Board Recommendation
None.
F.
Emeroency preparedness
1.
Analysis
Two inspections were conducted during the assessment period to
evaluate the following aspects of the licensee's emergency
preparedness program: actions on previously identified items;
emergency plan activations; emergency detection and
'
classification; protective action decision-making; notifich*, tons
and communications; shift staffing and augmentation; knowledge
and performance of duties (training); independent audits of
l
emergency preparedness; and changes to the emergency
preparedness program. One of the inspections was an evaluation
of the licensee's annual emergency preparedness exercise
and the other was a routine inspection of the emergency
preparedness program.
l
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"
No violations of NRC requirements were identified during the
inspections.
Management involvement and control in assuring quality in
the emergency preparedness program was demonstrated through
decision-making that has consistently been at a level that
ensures adequate management review and control. Corporate
management is frequently involved in site activities, audits,
and inspections and associated records are generally complete
and readily available. The licensee has provided timely and
sound resolutions to NRC concerns as evidenced by the closure
of all eight open items created during 1985.
Similarly, the
licensee implemented all eight of the improvement items
recommended during 1985, including one that required corporate
assistance.
The licensee demonstrated a high level of proficiency during
the emergency preparedness exercise. Emergency response
organization positions were well defined, authority and
responsibilities specified, and personnel were capable of
implementing their assigned tasks. Staffing to implement
routine daily operations was also well defined and adequate.
The licensee has maintained a prioritized roster of adequate
numbers of qualified personnel to fill the key positions in
the emergency organization. Semiannual off-hours drills have
successfully demonstrated the capability to augment on-shift
staff in a timely manner.
The training program is well defined and implemented with
dedicated resources and included the use of a simulator.
The adequacy of the training program was demonstrated by
individual performances during exercises and walkthrough
interviews.
!
Records of five actual emergency plan activations during this
assessment period indicated that all five had been properly
classified. The NRC and State of Illinois were notified of
these emergency declarations in a timely manner.
Followup
notifications were also completed within adequate time periods
after significant event changes or event termination.
2.
Conclusion
The licensee is rated Category 1 in this area. The licensee
was rated Category 1 in this area in the last SALP.
3.
Board Recommendation
Reduce inspection in this area to the minimum inspection
program.
14
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G.
Security
1.
Analysis
Three routine and three reactive security inspections and one
Material Control and Accountability inspection pertaining to
Unit I were conducted by regional based inspectors during this
assessment period; three preoperational inspections (two
security and one Material Control and Accountability) regarding
Unit 2 were also conducted by regional based inspectors. The
resident inspectors also made periodic inspections of security
activities assessing routine program implementation and
providing initial responses to security events.
Two violations were identified, a Severity Level III violation
for failure to control access into a vital area (Inspection
Report No. 454/85054) and a Severity Level IV violation for
failure to report a security incident to the NRC within the
time limits required by 10 CFR 73.71(c) (Inspection Report
.
No. 454/85054). The failure to control access led to 2 of
the 3 elements of access control for the affected vital area
being inadequate such that an individual could have gained
unauthorized, undetected access. A civil penalty in the amount
of $50,000 was issued.
In addition, the violation continued
for 26 days before identification by a member of the plant
security force. Once identified, the incident was not reported
to the NRC within the time limits required by 10 CFR 73.71(c).
The above Severity Level III violation, and prior poor
performance in the area of security during the previous SALP
period raised concerns regarding the effectiveness of the Byron
security program. To improve performance in the area of access
control to protected and vital areas, the licensee committed
to implementing a security Performance Improvement Program
,
!
(PIP) as part of the licensee's Conduct of Operations
Improvement Program, focusing on three major areas: (a)
upgrading security education to station personnel and
construction workers; (b) monitoring compliance with security
rules; and (c) actions to improve the effectiveness of security
equipment. The licensee's successful implementation of the
PIP in the first quarter of the assessment period resulted in
improved performance as shown by a significant decrease in
safeguard event reports and irregularity reports. The PIP
also resulted in improved communications between security and
plant operations, and heightened plant security awareness.
During the assessment period, the resident inspector at Byron
received allegations of security violation coverup, fitness
for duty concerns, and security staff shortages. Only the
latter allegation was substantiated; however, there were no
violations of NRC requirements identified.
i
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Management involvement in assuring quality increased
significantly during the assessment period. The licensee's
Senior Corporate Security Administrators developed and
conducted a training program for all CECO Quality Assurance
(QA) inspectors. The goal of the program was to provide
QA inspectors with an increased security knowledge to provide
improved program effectiveness. The licensee's security
contractor developed and implemented an internal audit
program. The audits conducted to date were thorough,
comprehensive, well documented, and effective in uncoverirg
weaknesses in the security system, procedures and practices.
Security management was responsive to NRC initiatives as
-
demonstrated by their full support of the PIP and the
i
successful implementation of Unit 2 security program. Senior
plant management became directly involved in the development
of an increased security awareness in the implementation of
the PIP. Corporate security continues its involvement in
site activities through the presence of the Senior Security
Administrator assigned to the site.
The violations identified during the previous assessment
period were indicative of a significant programmatic breakdown.
Corrective actions had not been successful in preventing
recurrence. The continuation of similar problems necessitated
the formulation of the PIP. The Severity Level III violation
identified during this assessment period occurred during the
developmental stage of the PIP. The results of the PIP
achieved the goals of preventing recurrence of access cortrol
problems and improving performance.
i
The licensee's approach to the resolution of technical issues
'
was viable and generally successful.
In the previous assessment
period, the licensee had not been successful in achieving results
in the security computer system reliability, which involved both
l
l
software and hardware problems. During this assessment period,
l
the computer redundancy problem was resolved; however, the
'
licensee continues to experience unplanned and planned outages.
The licensee is continuing their analysis of this problem.
l
The licensee's staffing levels are adequate to fulfill security
!
plan commitments; however, in June / July 1986, there existed a
I
temporary shortage of personnel because of the additional
l
compensatory posts caused by Unit 2 security construction
requirements necessitating excessive overtime. Positions
within the security organization are identified and authority
,
!
and responsib111 ties are well defined. Major progress was
achieved in stabilizing the contract security force. Contract
security management is providing consistent support and
oversight of the security force. Training policies and
procedures have ensured that all security personnel are trained
and qualified to perform assigned security related tasks or
duties.
~
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There were two security events reported to the NRC under
73.71(c) during the assessment period. These reports were
accurate; however, one of the two was late, resulting in a
Severity Level IV violation. The first event occurred in the
beginning of the assessment period and involved the vital area
access control problem which resulted in a Severity Level III
violation discussed above. The second event pertained to a
guard allegedly sleeping while performing compensatory measures.
The licensee properly analyzed the two events and initiated
appropriate corrective action.
2.
Conclusion
The licensee is rated Category 2 with an improving trend in
this area. The licensee was rated Category 3 in this area in
the last SALP. The improved rating is based on the licensee
security staff's effectiveness in reversing a trend of repeated
access control violations and in establishing an effective
security operation.
3.
Board Recommendation
None.
H.
Outages
1.
Analysis
Three major outages occurred during this assessment period;
there were no refueling outage activities. This functional
area was examined in portions of five inspections conducted
by resident inspectors. Activities covered included reviews
of outage management, including scheduling of parallel path
and non parallel path work.
One Severity Level IV violation was identified for failure to
perform surveillance testing on a containment isolation valve
following maintenance, due to the use of blanket out-of-services
during an outage (Inspection Report No. 454/85048). This
violation was identified by the licensee in an LER and
corrective actions were taken to prevent recurrence.
Management involvement has increased in this area with the
establishment of an Assistant Superintendent - Work Planning
position in the production department. This individual
coordinates the outage schedule and planning functions in
one location; monitors outage performance against planned
schedule; and identifies critical path areas for increased
management attention. A 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> outage schedule is continually
updated to take advantage of any unplanned outage.
17
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The licensee has increased staffing in this area and has
transferred personnel with operating experience to the outage
group in preparation for the Unit I refueling outage scheduled
for February 1987.
The licensee has taken conservative positions with regard to
scheduling to ensure that redundant trains of safety related
equipment are not worked on at the same time. No significant
initiatives were identified by the NRC in this area.
The licensee has developed computerized out-of-service lists,
by component, and has computerized lists of work surveillances
performed to assist operations department personnel in
determining that all activities are completed prior to
entering the next operational mode.
An additional indication of adequate outage performance is
plant performance during a return to operations. Unit 1
performed well in this regard providing increased assurance
in the licensee's ability to manage outages.
2.
Conclusion
The licensee is rated Category 1 in this area. The licensee
was rated Category 1 in the similar functional area of " Initial
Fuel Load," during the last SALP period.
3.
Board Recommendation
Inspection effort in this area should be maintained during
the approaching first refueling of Unit I which will include
extensive maintenance work,
i
I.
Quality programs and Administrative Controls Affecting Quality
1.
Analysis
Examination of this functional area consisted of four
inspections by regional based inspectors and, as part of
the routine inspection program, portions of 12 inspections
by the resident inspectors. One of these inspections was
conducted on the operational QA program for Unit I and two
were conducted to verify operational readiness in this area
for Unit 2.
Specific areas examined during the inspections
~
included quality assurance program implementation; organization
and administration; procedures; corrective action; document
control; design changes and modifications; equipment calibration
and control; receipt, storage and handling of material; audits;
and procurement. Another inspection was conducted to review
allegations received from QC inspectors for an electrical
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contractor.
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One Severity Level V violation was identified, an isolated
failure to protect plant equipment.
The Severity Level III violation involving a Code Safety
Valve discussed in Section IV.C., Maintenance, resulted from
significant failures in maintenance and quality assurance
programs. Management response to this event was prompt and
thorough and involvement in periodic meetings was good.
Management's approach to resolving technical issues was
conservative, sound, and responsive to NRC initiatives for
improving performance, reducing LERs, housekeeping, and
professionalism.
The inspection of allegations concerning deficiencies in the
Quality Assurance Program of the electrical contractor
commenced during this assessment period. Although the number
and severity level of potential violations identified during
t
the inspection have not been determined, meetings have been
'
held with the licensee on issues identified during this
'
inspection. Multiple examples of apparent violations of
i
10 CFR Part 21 and 10 CFR Part 50, Appendix B, were identified.
They demonstrated Commonwealth Edison Company's failure to
j
exercise adequate oversight and control of their electrical
1
!
contractor to whom they had delegated the establishment and
execution of a quality assurance program in the electrical
area. This occurred in spite of the fact that inspector
concerns had been brought to the attention of the Commonwealth
Edison Company Quality Assurance organization. Deficiencies
identified during this inspection were primarily caused by the
i
lack of performance by those involved with the construction
phase.
l
Two team inspections were conducted during this assessment
period, an inspection by the NRC Nondestructive Examination
(NDE) van team and an inspection by the NRC Office of
Inspection and Enforcement (including consultants) to ensure
that applicabla corrective actions from the Byron Unit 1
Integrated Design Inspection (IDI) and the Independent Design
Reviews (IDR) of Byron Unit I and Clinton Power Station were
being correctly implemented. Although specific items requiring
correction were identified by these inspections, no violations
were identified.
In addition, followup inspections were made
of the NRC Construction Assessment Team (CAT) findings
identified in the last SALP period and found that the licensee
had adequately resolved the issues involved in the three
>
l
violations that were cited by the CAT.
l
Meetings were held periodically between NRC staff and plant
l
management to assess operation of the plant.
Licensee
i
management involvement in the implementation of the quality
assurance program is evident. Audits and surveillances are
being conducted, deficiencies are being identified, and
corrective actions are solving the problems. Quality programs
and the administrative controls affecting quality appear to
be increasingly effective. Plant operation has improved and
19
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operating events have been reduced as evidenced by the number
of LERs declining from 135 to 39 in this assessment period
and the number of reactor trips dropping from 31 to 6.
Administrative programs for control of procedures, deviations,
modifications, and for response to events and NRC Bulletins
and Information Notices are established and functioning well
with few failures.
Areas in operations where controls
affecting quality were not adequate were identified by the
events involving the Code Safety Valve, and by NRC reviews of
preoperational test results acceptances by the licensee's
Project Engineering Department.
In spite of these,
administrative controls affecting quality have improved overall
4
including enhanced plant features for human factors and the
initiation at the end of the assessment period of a " Plan for
Error-Free Operation".
The " Byron Station Plan for Error-Free Operation of Unit 1
and 2" establishes a Corporate / Station Special Review Committee
to review station performance. The membership of the committee
encompasses corporate and Byron management as well as
bargaining union personnel. The committee is charged with
meeting monthly or more often as necessary and has a list of
topics to be addressed at least semi-annually. The list of
topics touches on all the major areas of plant operations.
The plant features instituted for " human factors" includes
the color codin'g of piping systems, electrical cables and
document cover sheets for Unit 1 and Unit 2.
The licensee has
also established a control board free of caution color lights
under normal plant conditions and has committed to maintaining
a " blackboard", that is a control panel free of nuisance
(repetitive and non-significant) alarms. The licensee has
added other improvements aimed at eliminating human error and
is showing initiative in this area.
2.
Conclusion
The licensee is rated Category 2 in this area. The licensee
was rated a Category 2 in this area in the last SALP.
3.
Board Recommendation
None.
I
J.
Licensing
1.
Analysis
During the assessment period there was a significant level of
licensing activity, especially toward the end of the period.
l
The low power license for Unit 2, and a supporting SER
supplement, were prepared for issuance on October 31, 1986.
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(Incompleteness of the plant delayed issuance of the license
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until November 6, 1986.)
Management involvement and control in assuring quality was
sati sfactory. The licensee's decision-making was usually at a
level that ensures adequate management review. The submittals
needed to support licensing of Unit 2 were almost always
timely, thorough, and technically sound. However, as a result
of the extensive effort involved in licensing Unit 2, some
of the more routine items were not submitted en a timely
basis.
The licensee's overall approach to resolution of technical
issues from a safety standpoint was satisfactory. The licensee
understood the technical issues and responses were generally
sound and thorough. Conservatism was generally exhibited.
Licensee responsiveness to NRC initiatives was good.
In the
weeks prior to the issuance of the Unit 2 low power license,
the licensee responded to many NRC initiatives in a timely
manner and proposed resolutions that were acceptable to the
staff.
In nearly all other instances throughout the rating
period, licensee responses to NRC initiatives were timely,
1
technically sound, thorough, and found acceptable by the NRC.
Plant staffing is amp?e. Key positions are identified and
responsibilities and authorities are well defined. The staff
that will startup Unit 2 has extensive experience on Unit 1;
'
shift advisors, which were needed on Unit 1, are not needed
on Unit 2.
It is anticipated that the well-trained and
experienced Unit 1 staff will provide a smooth startup of
Unit 2 and continued smooth operation of both units.
!
Both the Immediate Notifications and the Licensee Event Reports
suggest, for the most part, that the Licensee took appropriate
action with regard to the reported events.
It was noted,
however, that there were 3 Immediate Notifications of
inoperability of the process computer, with subsequent loss
of emergency assessment, over a 4 day period with no followup
,
report on causes or measures taken to correct deficiencies.
i
This and five late reports lead us to conclude that the
licensee's licensing activities need more management attention.
!
2.
Conclusion
The licensee is rated Category 2 in this area. The licensee
i
was rated a Category 2 in this area in the last SALP.
,
3.
Board Recommendation
1
None.
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K.
Training and Qualification Effectiveness
1.
Analysis
Operator licensing examiners have evaluated training and
qualification effectiveness on senior reactor operator (SRO)
and reactor operator (RO) licensing candidates during
examinations administered during this assessment period.
No violations were identified.
Examinations were administered to 25 SRO candidates and
29 RO candidates. Of these, 19 SR0 candidates and
22 RO candidates passed the examination. This pass rate
is comparable to the national average.
Generic concerns identified by the examiners included the
candidates reluctance to initiate entry into Byron Emergency
Operating Procedures during steam and feed line breaks that
did not cause automatic safety injection or reactor trip
signals. Candidates demonstrated unfamiliarity with xenon
poisoning affects during reactor startup following a trip.
During remote shutdown panel operation candidates were unable
to effectively make a transition to the Emergency Operating
Procedures for a steam line break. The candidates usage
and follow through with Technical Specifications and
administrative procedures was often superficial and incomplete.
As each generic concern was identified over this assessment
period, a discussion was held at length with the plant manager
i
and training staff. The results of which were evidenced in
l
later examinations. This indicated that the concerns
l
identified early in the examination process had been corrected
i
through enhanced training in this area.
l
l
Another identified concern was the partial adherence and
compliance with administrative procedures and Technical
Specifications. These difficulties were traced to the teaching
philosophies at the Production Training Center classrooms.
The instructors were not requiring the candidates to review
all of the Technical Specifications due to their understanding
that the NRC examinations did not cover the full spectrum of
understanding and adherence to the action statements, and as
,
a result, this philosophy manifested itself in the area of
Technical Specifications and administrative procedures during
the oral examination phase.
Candidates in general were
competent and sensitive to the Technical Specifications
procedures and action statements and addressed them promptly
during the simulator examinations, indicating that this concern
had been specifically addressed.
However, this indicates a
weakness in training in that candidates may be taught based
on the perceived content of the NRC licensing exam and not
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on the comprehensive tasks which should be included in the
task analysis of all duties required by a licensed individual
to accomplish his job.
The operational unfamiliarity regarding the use of the remote
shut down panel with malfunctions was exhibited during
examinations conducted at the end of this assessment period.
Discussions with the plant manager and training staff resulted
in the licensee's commitment that all candidates in the future
will undergo an enhanced training class to identify and
procedurally respond to malfunctions on the remote shut down
panel.
The generic concerns that were identified as training
weaknesses were in the most part corrected by the licensce.
The ongoing enhanced training program committed to by the
licensee should have a long term beneficial effect to all
candidates. The licensee had received INP0 accreditation
for their non-licensed operator, reactor operator, and senior
reactor operator programs.
Staffing (including management) appears to be adequate and
qualification of training personnel was satisfactory.
Management involvement is required to assure timely and full
INPO accreditation in the remaining seven areas.
The effectiveness of the training received by the Byron staff
is evident in the improved performance observed in the areas
of plant operations, radiological controls, surveillances,
security, and LER report content. Another indicator of the
effectiveness of training and qualification is the personnel
awareness that the plant staff has of their impact on plant
performance.
For example, the I&C technicians take pride in
the fact that they have not been responsible for a plant trip
since late 1985.
2.
Conclusions
,
The licensee is rated Category 2 in this function.1 area.
a
The licensee was not rated in this area in the last SALP.
3.
Board Recommendation
None.
L.
Preoperational Testing
1.
Analysis
This functional area was examined for Unit 2 in four
inspections conducted by region based inspectors and portions
of six inspections conducted by resident inspectors. The
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inspection effort included:
review of administrative controls,
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review of preoperational test procedures, witnessing of
preoperational test performance, detailed reviews of
preoperational test results, verifications of preoperational
test results and reviews of startup test procedures. At the
end of this assessment period, Unit 2 preoperational testing
was almost completed while Unit 2 fuel loading and startup
testing had not yet begun. Unit 1 preoperational and startup
testing were completed prior to this assessment period.
Early in the assessment period, an inspection was conducted
to determine the effectiveness of implementing in the Unit 2
preoperational test program the lessons learned during the
conduct of the Unit 1 preoperational tests.
It was determined
that the licensee had identified Unit 1 test shortcomings and
other lessons learned and was taking action to improve the Unit
2 tests.
In light of the licensee's improvement program and
based on the use of Unit 1 procedures to develop Unit 2
procedures, the NRC reduced inspections of the test procedures.
In the previous assessment period, 7 violations consisting
of 3 Severity Level IV, 3 Severity Level V items, and one item
for which a severity level is yet to be determined (pending
consideration for escalated enforcement action) were identified
over a rating period of 18 months.
In this assessment period,
8 violations consisting of 1 Severity Level IV item, 6 Severity
Level V items and one unresolved item for which a severity level
is yet to be determined (pending consideration for potential
escalated enforcement action) were identified over a rating
period of 12 months. This indicates that the enforcement
history has not changed significantly from the previous SALP
period.
The six Severity Level V violations were judged to have little
safety significance; however, three of the Severity Level V
violations appeared to be indicative of a weakness regarding
administrative aspects of the testing program and indicate
the need for licensee management to exercise more influence
to ensure that administrative requirements are appropriately
followed during the Unit 2 startup testing program. The
Severity Level IV violation concerns the Safety Injection Flow
Balance preoperational test which was written and approved
with inappropriate acceptance criteria in that the test required
several safety-related pumps to equal or exceed the head versus
flow performance curves from the vendor's shop tests (Inspection
Report No. 455/85045). The unresolved item concerns the
inadequate technical evaluation for a preoperational test
deficiency (Inspection Report No. 455/86041).
4
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Inspection Reports Nos. 455/86034 and 455/86041, which documented
three of the seven violations mentioned above and the unresolved
item, were issued subseauent to the assessment period. These
violations are addressed in this report because they reflect on
performance during this assessment period.
Failure to perform an adequate test results evaluation was
identified as a weakness in SALP Reports 4 and 5.
The
unresolved item discussed above represents a continuing
weakness in this area. The test deficiency was written for a
reactor containment fan cooler preoperational test because
the fan flows did not meet the minimum flow requirements of
the FSAR. The Project Engineering Department (PED) evaluated
the deficiency and, based on the evaluation, PED decided that
'
the flows were acceptable regarding low fan speed capacity.
An NRC review of the tu;hnical justification found that it
.
did not provide an adequate technical basis to support this
conclusion. At the end of the assessment period, it was unclear
whether or not the reactor containment fan coolers were capable
of performing the intended safety-related function. This
cannot be resolved until completion of further testing and/or
evaluation. Although preoperational testing is essentially
complete, strong management attention regarding adequate test
results evaluations for Unit 2 startup testing is needed as
evidenced by a weakness being identified in this area for three
,
successive SALP assessment periods.
,
An item which was originally identified during the SAlp 5
assessment period was not addressed in the SALP 5 report
because an investigation by the Office of Investigation (01)
was still in progress at that time. This item consisted of
,
PED approving the results of a Unit I startup test, Reactor
Coolant System Flow Coastdown, which did not meet FSAR
requirements since the measured core flow coastdown data decayed
faster than assumed in the FSAR. Westinghouse performed a new
,
safety analysis which provided revised flow coastdown acceptance
criteria. The flow coastdown test was approved based on the new
acceptance criteria; however, the Byron low power license
required that NRC approval be obtained prior to changing
acceptance criteria and NRC approval was not obtained. The OI
investigation has been completed and subsequent to this SALP
period, an Enforcement Conference was conducted and escalated
,
enforcement is under review regarding this item.
Based on inspector observation, conduct of Unit 2 preoperational
tests improved significantly over Unit I test performance.
Staffing (including management) appears to be adequate and
qualification of test personnel was satisfactory. Management
involvement in the development of the Unit 2 startup procedures
was evident based on the quality of the startup testing
procedures. The NRC's review of the Unit 2 startup test
procedures is complete and no violations or significant
25
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concerns were identified. Since four of the violations in
this functional area were conteined in reports issued after
the end of the assessment period, the licensee has not yet
responded to these; however, in general, the licensee is
responsive to specific violations and concerns.
j
2.
Conclusion
The licensee is rated Category 2 in this area. The licensee
was rated Category 2 in this area in the last SALP.
3.
Board Recommendation
There is one area, test results evaluations, that appears to
be a pervasive weakness in that it was identified during three
successive SALP periods. Based on this, the board recommends
additional management attention in the area of test results
evaluations for Unit 2 startup tests with special emphasis on
Project Engineering Department's involvement in the test
.
evaluation process.
M.
Construction
1.
Analysis
Construction work at the Byron Station was essentially complete
except in the electrical area; therefore, inspection activities
were limited. This section is a consolidation of several
areas that were addressed separately in previous SALP reports.
Examination of construction was based on the results of 10
inspections by region based inspectors. Areas examined
included: containment structural integrity testing -and welding;
verification of as-built conditions associated with structural
installations, piping systems and onsite design activities;
observation of completed work involved with heating,
ventilating and air conditioning (HVAC) systems and hangers;
observation and review of piping systems examination results;
walkdown inspections of electrical installations to compare
installed components with "as-built" drawings; observation
of electrical and instrumentation cable installation and cable
termination activities; review of electrical installation
procedures and quality assurance records; observation of
'
!
electrical equipment storage and maintenance activities;
walkdown inspections of instrument and control systems; review
of instrument and control quality assurance records; licensee
action on IE Bulletins, previous inspection findings, and
10 CFR 50.55(e) reports; and allegations.
One Severity Level V violation was identified in the construction
area. The violation did not represent a recurrence from the
l
previous assessment period nor were there generic or programmatic
implications.
!
26
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'
- - - . . -
-.
- -
-
-
. -. -. - - .-- . -
- - -
-
'
-
.
b
The licensee's responsiveness to NRC concerns and resolution
of technical issues were found to be acceptable. Minor
deficiencies identified by the NRC inspectors were immediately
corrected and action ~s taken by the licensee to address open
or unresolved items were found to be acceptable.
Concerns expressed in 4 allegations were reviewed including:
discrepancies in as-built piping drawings, hiring of unqualified
inspectors, and the performance of deficient engineering
calculations.
Review of these concerns was completed. One
concern, dealing with the performance of deficient engineering
calculations was substantiated; however, it was found that
there was no technical basis that resulted in the identification
of a violation of NRC requirements. Another concern dealing
with the same topic was not substantiated; however, the
architect engineer committed to review calculations in addition
to those reviewed by the NRC inspectors. A concern involving
the hiring of unqualified inspectors was found to be
unsubstantiated and a concern dealing with discrepancies in
as-built piping drawings was substantiated; however, no
significant safety problems were identified.
Since construction was essentially completed, licensee
performance in construction areas was collectively evaluated.
The licensee's involvement and control systems were adequate
for dealing with the areas examined.
In general, discussions
with licensee and contractor personnel indicated that they were
knowledgeable of their job duties. Observations indicated that
personnel had an adequate understanding of work practices and
adhered to procedures.
In addition, records were available,
complete, and well maintained. The licensee's responsiveness to
IE Bulletins, Construction Deficiency Reports, and previous NRC
findings was found to be timely, thorough, and technically sound.
Licensee management was very responsive to concerns expressed by
the NRC. For example, as construction came to an end, licensee
management was responsive to reducing the number of open
construction and other items when the NRC identified the high
number as a concern.
2.
Conclusion
The licensee is rated Category 2 in this area. The licensee
was not rated in " Construction during the previous assessment
period, but rather in individual construction functional areas.
In these construction areas which were Containment and Other
Safety-Related Structures, Safety-Related Components, Piping
Systems and Supports, Instrumentation and Control Systems, and
Electrical Power Supply and Distribution, the licensee
received Category 2 ratings.
3.
Board Recommendation
None.
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.
.
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.
V.
SUPPORTING DATA ANL_ SUMMARIES
A.
Licensee Activ'. ties
1.
Unit 1
During this assessment period, Unit 1 engaged in routine
power operation for extended periods. However, Unit 1
began the assessment period while in an extended
environmental qualification maintenance outage that lasted
until December 17, 1985. Subsequent to the maintenance
outage, Unit 1 experienced two forced outages.
The
average plant availability during the assessment period
was approximately 71%.
The Unit experienced two forced
outages resulting in an average force outage rate of 9%.
Additional Unit 1 outages are summarized below:
Forced outage to repair
July 3 - July 24,1986
-
primary system leaks.
Forced outage to repair
February 17 - March 4,1986
-
damaged transformer. The
plant remained down to
perform scheduled
maintenance outage
activities.
Unit 1 experienced a total of 6 reactor trips during this
assessment period, with 5 occurring above 15% rated power;
and 1 between 0 and 15% power. Three of these trips were
due to procedural inadequacies or personnel errors, 2 were
due to mechanical / equipment problems, and I was related to
an external cause.
In addition to the reactor trips, Unit i
experienced 21 Engineering Safety Feature (ESF) actuations.
i
'
2.
Unit 2
During this assessment period, Unit 2 was considered
'
to be in the construction /preoperational testing phases.
l
Six days subsequent to the end of the assessment period
Unit 2 received its Low Power License limiting the
licensee to fuel loading and initial testing activities up
l
to 5% power. Major milestones accomplished during this
assessment period included: Completion of essentially
100% of construction activities; completion of nearly all
pre-operational testing; activation of the plant security
systems; and close out of nearly all NRC open items and
issues required prior to issuing the low power license.
,
B.
Inspection Activities
There were 67 inspections conducted during this assessment
period, November 1,1986 through October 31, 1986. Major or
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-
_ __
__
_
.
..
- _ - _ .
--
_.
.
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.
4
.
significant inspection activities are listed in paragraph 2 of
this section, Special Inspection Summary.
1.
Inspection Data
Facility Name: Byron
Unit: 1
Docket No.: 50-454
Inspection Reports Nos.: 85037, 85047, 85048 thru 85056,
86001 thru 86020, 86022, 86023, 86025, 86029, 86030,
86032, 86039, 86041, and 86044.
Unit: 2
Docket No.: 50-455
Inspection Reports Nos.: 85028, 85031, 85033 thru 85037,
85041, 85044 thru 85047, 86001 thru 86006, 86008 thru
86014, 86016, 86018 thru 86029, 86031 thru 86033, 86035,
86037, and 86039 thru 86041.
TABLE 1
Number of Violations in Each Severity Level
Common
Unit 1
Unit 2
Both Units
Functional Areas
I II III IV V
I II III IV V
I II III IV V
4 1
'-
- -
A.
Plant Operations
-
B.
Radiological Controls
-
- -
-
- -
C.
Maintenance
1
2 1
-
- -
5 2
D.
Surveillance
-
- -
-
1
E.
Fire Protection
-
-
- -
-
F.
-
- -
-
- -
G.
Security
1
1
-
-
- -
1
H.
Outages
-
-
- -
-
1
I.
Quality Programs and
-
- -
-
-
Administrative Controls
Affecting Quality
J.
Licensing Activities
-
- -
-
- -
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K.
Training & Qualification
-
- -
-
- -
1 6
l
L.
Preoperational Testing
-
- -
-
1
'
M.
Construction
-
- -
-
-
I II III IV V
I II III IV V
I II III IV V
TOTALS
0 0 2 13 5
0 0 0
2 7
0 0 0
0 0
2.
Special Inspection Summary
A Special NRC Independent Measurement
November 7, 1985
-
Inspection and NDE Examinations were conducted (Ref:
455/85031).
29
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- . _ - _ . _ _ - .
. _ - _ . _ . - _
- - - . .
o
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.
a
-
.
A Team Inspection was conducted to
November 22, 1985
-
ensure that applicable corrective act' ions from the Byron 1
Integrated Design Inspection (IDI) and the Independent
Design Reviews (IDRs) were being correctly implemented on
Unit 2 (455/85047).
C.
Investigations and Allegations Review
Allegation Review
Eleven allegations relating to Byron consisting of 103 concerns
were received in Region III during this assessment period.
Three of the 11 allegations remained open at the end of the
assessment period and will be reviewed by Region III in the
near future.
Significant allegation findings are discussed in
-
Section IV under the appropriate functional area.
D.
Escalated Enforcement Actions
1.
A $25,000 Civil Penalty was issued on June 25, 1986. This
action was based on a Severity Level III v.iolation of
10 CFR 50.70 in which a subcontractor of Commonwealth Edison
Company, discharged an employee for reporting to NRC,
,
inadequate inspection procedures and the insta11atio.n of
non-radiation proof seals at the Byron Nuclear Power station.
This case was being handled by the U.S. Department of Labor
(DOL). The licensee has requested that NRC mitigate this
Civil Penalty. NRC is reviewing the licensee's request.
2.
A 550,000 Civil Penalty was issued March 5, 1986, because of
inadequate vital barriers (454/85054). The licensee has paid
this Civil Penalty.
3.
Escalated enforcement actions were initiated on August 12,
1985, (during the previous assessment period) based on the
conduct of Technical Specification surveillances which rendered
both ECCS systems inoperable, while in MODE 1; and failure of
management and management systems to ensure the unit was
operated in accordance with T.S. requirements. These eyents
were evaluated as two Severity Level III Violations. TWo
$50,000 Civil Penalties were assessed. The first one was
mitigated to $25,000 based on the licensee's response.
4.
A 525,000 Civil Penalty was issued November 18, 1986
'
(subsequent to this assessment period) for a Severity Level
III violation which was the aggregate of three problem areas
(i.e., management oversight of implementation of the QA and
Maintenance programs; failure to control identified
nonconforming material to prevent its inadvertent use; and
the use of a defective component as a fission p"roduct barrier
for the reactor coolant system pressure boundary).
30
.
_ _ - - _. - _ _ -
_ _ _ . _ _ _
. - . _ - -
_.
.. - _ _ - _
O
.
- -
e
E.
Licensee Conferences Held During Assessment Period
1.
November 20, 1985, January 16, Maren 25, April 22, and June 24,
1986, (Byron Site) - management meetings to discuss Unit 1
operational history and licensee managements efforts to improve
plant and staff performance.
2.
November 22 and 27, 1985, Enforcement Conferences to discuss
the inoperable condition of both RHR trains; operation of
Unit 1 at core thermal power levels in excess of that allowed
by the facility operating license; failure to follow Technical
Specifications (T.S.); and an apparent breakdown in management
controls manifested by T.S. violations.
3.
December 19, 1985, Enforcement Conference to discuss inadequate
plant security regarding removal of vital area barrier floor
plugs.
4.
December 23, 1985, (Regional Office) - a management
meeting was held with licensee representatives to discuss
it's response to the Notice of Violation regarding the
radiation protection inspection conducted May 6 - July 22,
1985.
5.
February 3, 1986, (Byron Site) - a management meeting with
licensee representatives to discuss the SAlp 5 results.
6.
April 21, 1986, Enforcement Conference to discuss a contractors
fiting of an employee performing protected activities.
7.
July 1,1986, (Byron Site) - e management meeting with
licensee representatives to discuss electrical issues at
the Byron station.
8.
August 25, 1986, Enforcement Conference to discuss the Licensee
performance regarding the installation and replacement of a
non-functional primary safety relief valve.
9.
September 11, 25, October 9, and 23, 1986, (Byron Site) -
management meetings to discuss Unit 2 readiness to receive a
low power license.
F.
Confirmatory Action Letters (CALs)
No Confirmatory Action Letters were issued during this assessment
period,
i
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.
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o
G.
A Review of Licensee Event Reports, Construction Deficiency
Reports, and 10 CFR 21 Reports Submitted by the Licensee
1.
Licensee Event Reports (LERs)
Byron Unit 1
Docket No. 50-454
LER Nos. 85090, 85092 thru 85102 and 86001 thru 86028
Thirty-nine LERs were issued during this assessment period;
16 LERs were the result of personnel errors; 5 LERs were
the results of procedure inadequacies; 7 LERs were the
result of component / equipment failures; 2 LERs were
related to design problems; and 9 LERs fell into the
others category (i .e., electrical / noise spikes, lightning,
ice). The total number of LERs was markedly reduced from 135
in SAlp 5.
However, personnel errors continue to represent a
significant percentage of the total at 43.6 percent. With
regard to Immediate Notifications, 32 were telephoned to the
NRC within the time limits of 10 CFR 50.72 and 5 were not.
Of
the 5 notifications that were not timely, two were associated
with reactor trips and two were associated with the
inoperability of the process computer and subsequent loss of
emergency assessment.
2.
Analysis and Evaluation of Operational Data (AE00)
The results of the Office of Analysis and Evaluation of
Operational Data (AEOD) assessment of Byron Unit 1 LERs for
this assessment period indicated a major improvement in the
quality of the licensee's issued LERs. AEOD sssessed an
average score of 9.4 out of a possible 10 points, compared
to their previous overall average score of 7.5 and a current
industrial average score of 8.1.
The licensee's current
average score of 9.4 is the highest overal average of all
units / stations that have been evaluated to date. AEOD
considered Byron LERs a model for the industry. Strong points
identified during the AEOD review included the licensee's
discussions concerning personnel errors, and the failure mode,
mechanism, and effect of failed components. AEOD indicated
that improvements in the discussion of corrective actions
in the LER text could be made.
3.
Construction Deficiency Reports (CDR)s:
During this assessment period, five CDRs were submitted by
the licensee to Region III for Unit 2 under the requirements
of 10 CFR 50.55(e). One report was closed and one was
subsequently withdrawn. Three remained open at the end of
the assessment period.
32
o
e
9
-
0
4.
10 CFR 21 Reports
No 10 CFR Part 21 Reports were submitted by the licensee
during this assessment period for Unit 1 or Unit 2.
H.
Licensing Activities
1.
NRR Site Visits / Meetings / Licensee Management Conferences
Management Readiness Visit for
October 9, 1986
-
Unit 2
Diesel Generator Testing
October 21, 1986
-
LC0 Relaxation Program
December 3, 1985
-
LC0 Relaxation Program
December 6, 1985
-
SALP 5 Presentation
February 3,1986
-
Inadequate Core Cooling Audit
March 25, 1986
-
ISI of Pumps and Valves
July 8, 1986
-
ISI of Pumps and Valves
July 9, 1986
-
Hot Leg Reduction Program
July 25, 1986
-
2.
Commission Meetings
None
3.
Schedule Extensions Granted
,
Construction Completion Date
April 24, 1986
-
Extension for Unit 2.
4.
Reliefs Granted
,
ASME Section XI Relief for
October 29, 1986
-
Unit 2.
5.
Exemptions Granted
None.
6.
Licensee Amendments Issued
Correct typographical and
(
February 13, 1986
-
-
grammatical errors. Amendment 2.
Acceptance criteria for RHR pump
June 6, 1986
-
Performance. Amendment 3.
Five changes (grid plan location,
October 29, 1986
-
weight of uranium, etc.).
Amendment 4.
7.
Other Activities
None.
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33
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_
_ _ - _ - _ _ _ _ _ _ _ - . - _ _ _
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--_