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Safety Insp Rept 50-454/87-16 on 870401-09.Violation Noted: Failure to Adhere to Surveillance Procedure.Lack of Control in Area of Housekeeping Also Noted
	ML20213G891
Person / Time
Site:	Byron
Issue date:	05/11/1987
From:	Azab B, Rescheske P, Wright G; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	;
Shared Package
ML20213G885	List: IR 05000454/1987016; ML20213G882; ML20213G888; ML20213G891;
References
	50-454-87-16, NUDOCS 8705190010
	Download: ML20213G891 (8)
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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-454/87016(DRS) !

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

. Licensee: Commonwealth Edison Company

{ Post Office Box 767 ;

Chicago, IL 60690 ;

Facility Name: Byron Station, Unit 1

Inspection At: Byron Site, Byron, Illinois

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Inspection Conducted: April 1-9,1987

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Inspectors: P.'R.ResclIeske

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B. A. Azab

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Inspection Sunrnary

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1 Inspection on April 1-9,1987 (Report No. 50-454/87016(DRS))

1 Areas Inspected: Routine unannounced, safety inspection of the preparations

i for refueling (60705), refueling activities (60710 and 86700), SFP and reactor

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4 cavity)

(71707 . water level detemination (60710), and general plant observations

Results: Of the four areas 1 spected, no violations or deviations were

identified in three areas, and one violation was identified in the remaining

area (failure to adhere to a surveillance procedure - Paragraph 4). The

violation is of minor safety significance. The observations discussed in

Paragraph 5 indicate a lack of control in the area of housekeeping. Licensee

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attention in this area should be increased.

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DETAILS

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i 1. Persons Contacted

i *P. Pleniewicz, Production Superintendent

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D. Berg, Nuclear Safety

B. Bielasco, Station Health Physicist

*A. Britton, Quality Assurance Inspector

W. Burkamper, Quality Assurance Superintendent

1 *R. Choinard, Nuclear Group Leader

< *F. Hornbeak, Technical Staff Superintendent

j *R. Linboom, Fire Marshal

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W. Pirnat, Regulatory Assurance

*J. Schroch, Operations Engineer

j *R. Williams, Primary Group Leader

, *E. Zittle, Regulatory Assurance Staff

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The inspectors also interviewed other licensee personnel during the

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course of the inspection including members of the operations staff

and the fuel handlers.

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Denotes persons attending the exit meeting on April 9,1987.

2. Preparations for Refueling

The inspectors performed a review of the completed surveillance testing

and equipment operability checks required in preparation for the Unit 1

core reload. The following activities were completed by the licensee

< prior to entry into Mode 6 on March 30, 1987:

IBOS 9.4-1, " Containment Building Penetration to Outside Atmosphere

Surveillance."

0BVS 9.4.2-1, " Fuel Handling Building Ventilation System Negative

Pressure Test."

BVS 9.9-1, " Containment Ventilation System Weekly Surveillance."

180S 9.3-1, " Decay Time Surveillance."

1B0S 9.6.1-1c, " Unit 1 Refueling Machine (100 Hours Prior) Operability

Surveillance."

1805 9.6.1-1b, " Unit 1 Refueling Machine (Load Test) Operability i

Surveillance."

OBOS 9.7-1, " Crane Travel Spent Fuel Storage Pool Surveillance." l

BFP FH-8-T1, " Portable RCC Change Tool Operational Checklist."

BFP FH-9-T1, "New Fuel Handling Tool Operational Checklist."

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BFP FH-10-T2, "New Fuel Elevator Outage Operational Checklist."

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BFP FH-11-T1 " Spent Fuel Handling Tool Operational Checklist."

BFP FH-12-T2, " Spent Fuel Pit Bridge Crane Outage Operational Checklist."

BFP FH-14-T2, " Refueling Machine Outage Operational Checklist."

BFP FH-15-T1, " Thimble Plug Handling Tool Operational Checklist."

BFP FH-17-T1, " Burnable Poison Rod Assembly Tool Operational Checklist."

The inspectors verified from the documentation that the applicable

Refueling Operations Technical Specifications, Section 3/4.9, were

satisfied by the licensee. The inspectors also verified that the

training and qualifications of the fuel handling personnel was

acceptable.

No violations or deviations were identified.

3. Refueling Activities

The inspectors observed portions of the fuel handling operations during

regular hours, shif t turnovers, and back shifts. The inspectors

witnessed fuel moves from the new fuel storage racks, in the spent fuel

pit (SFP), through the fuel transfer canal, and in the reactor cavity,

and also observed refueling operations from the Control Room. During

core reload, the following licensee activities were monitored by the

inspectors:

a. Administrative controls in accordance with BAP 370-3, " Administrative

Control During Refueling."

b. Shift turnovers in accordance with BAP 370-3T1, " Fuel Handling

Turnover Sheet."

c. Periodic surveillance testing in accordance with 1B05 0.1-6,

" Unit One Mode 6 Shiftly and Daily Operating Surveillance."

d. Documentation of fuel moves and deviations to Form 86-2616, the

Nuclear Component Transfer List. Since many of the fuel assemblies

were bowed, the licensee made changes in the sequence of fuel moves ,

to " box" the badly bowed assemblies in the reactor vessel. J

e. Control Room activities including updating the status boards, l

maintaining communications with the refueling stations, and

performance of 1/M plots.

f. Communications betwee. all refueling stations, licensee staffing, and I

responsibilities t i key personnel. On April 3,1987, while witnessing I

a fuel assembly being placed in the reactor vessel, the inspectors

observed that the assembly was not properly positioned on the pins

after the refueling machine gripper had been disengaged. The fuel

handling foreman had not recognized the apparent error, until the

inspectors brought it to his attention. The fuel assembly was

subsequently repositioned. The inspectors discussed this incident

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with the foreman's supervisor, and the foreman was advised of his

responsibilities in supervising the fuel handling activities. No

further occurrences were noted by the inspectors.

g. Housekeeping, cleanliness, and material and tool accountability

in the fuel handling controlled access areas.

h. Radiation /Chemisty Department coverage and fuel handling personnel

radiation protection practices. Due to the large volume of outage

work being performed in containment, Rad / Chem coverage in the fuel

handling areas was minimal. This was acceptable since dose rates

for the refueling appeared to be very low. The inspectors did

witness one example of poor radiation protection practices by

the fuel handlers. The incident involved pulling a light cord out

of the reactor cavity without proper radiation controls. The cloth

used to wipe down the cord as it lef t the water was not properly

disposed of, thereby, increasing the possibility for the spread of

contamination. The licensee acknowledged the inspectors' concern,

the fuel handlers were informed of the acceptable method of

disposing potentially contaminated waste, and proper controls

were established.

1. Fire protection practices in areas near the refueling activities.

The inspectors observed welding activities being performed in

containment above the refueling floor, allowing sparks from the

work to fall on the floor near the reactor cavity. At no time

were the refueling activities affected by this work. The inspectors

noted that the floor was covered witn combustible material, such as,

paper and plastics, and informed the station fire marshal. The

licensee stated that measures would be taken to provide a fire

retardant barrier between the welding activities and the floor

below. The NRC Resident Inspector followed up on this concern

and found that although a fire watch had been posted at the work

site, the fire extinguisher was not in the vicinity of the fire

watch, and the seal was broken. The Resident Inspector will

followup on this concern.

j. The fuel transfer system Work Requests No. 43629 and No. 43678,

written on April 1,1987, to replace the brake assembly.

The following surveillance tests and equipment operability checklists

were reviewed by the inspectors and found acceptable.

OBVS 9.4.2-1, " Fuel Handling Building Ventilation System Negative

Pressure Test."

1BCS 9.1.2-1, " Unit 1 Refueling Operations Boron Concentration Once Per

72 Hours."

180S 9.2.c-1, " Analog Channels Operational Test of Source Range

Channels N31 and N32 in Mode 6."

0BOS 9.7-1, " Crane Travel Spent Fuel Storage Pool Surveillance."

BFP FH-10-T1, "New Fuel Elevator Shift Operational Checklist."

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BFP FH-12-T1, " Spent Fuel Pit Bridge Crane Shift Operational Checklist."

BFP FH-13-T1, " Fuel Transfer System Shif t Operational Checklist Spent

Fuel Pit Console."

BFP FH-13-T2, " Fuel Transfer System Shift Operational Checklist

Containment Console."

BFP FH-14-T1, " Refueling Machine Shift Operational Checklist."

No violations or deviations were identified. Inspector concerns

were adequately addressed by the licensee.

4. SFP and Reactor Cavity Water Level Determination

During the inspection period, the inspectors monitored the SFP and

reactor cavity water levels by direct observation and by review of

the documented surveillances. The Byron Unit 1 Technical Specifications

(TS), Section 3/4.9.10, states that at least 23 feet of water shall

be maintained over the top of the reactor vessel flange during fuel

movement. TS Section 3/4.9.11 states that at least 23 feet of water

shall be maintained over the top of irradiated fuel assemblies in the

storage racks in the SFP. The method used to determine level is to

visually read the " rulers" bolted to the walls of the SFP and reactor

cavity (the cavity level indication in the Control Room is normally used;

however, during the refueling, it was unavailable due to modification

work). When the fuel transfer canal gates are open during refueling,

the cavity and SFP levels should be equal. The reference level (zero)

is different for each, therefore, the actual ruler measurement reads 4.4

inches higher in the SFP than the cavity, at equal water levels (i.e.,

23 feet in the cavity is equal to 23' 4.4" in the SFP). The SFP high

alarm setpoint is at about 25' 2.1" and the low level alarm is set at

about 24' 6.4". The low level alarm came in on March 25, 1987, and was

continually in during the refueling. Nomal SFP level would be kept at

about 24' 9"; however, apparently due to water leaking from the cavity,

the SFP level was lower than normal. Subsequent to the inspection, the

cause of the water leak was found to be due to a mispositioned pump casing

drain valve on the 1A RHR pump (Residual Heat Removal System). The

licensee stopped the leak (approximately 12 gpm) on April 13, 1987. The

incident is documented in Deviation Report (DVR) No. 06-01-87-48 and is

under investigation by the licensee. The Resident Inspector will followup

on the results of the licensee's closure of this DVR during the Resident

Inspector Office routine review of DVR processing. The licensee used

Procedure 1805 0.1-6, " Unit One Mode 6 Shiftly and Daily Operating Sur-

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veillance," Pages D-6 and D-7, to document the water level surveillances.

SFP level is determined once per day (Shift 1), and cavity level twice

per day (Shifts 1 and 2). Since cavity level could not be dctermined by

the Control Room indication, Temporary Change No. 87-1-283 was written to

require that cavity level be determined locally. Round Sheet B0P 199-A70

was to be used to document levels during shiftly rounds.

The inspectors noted that the round sheets were routinely not being

completed correctly. The SFP out of tolerance value is given as less

than 24.5 feet. Since the SFP level was always less than that during

refueling, the out of tolerance value was circled on the round sheet.

The procedure (80P 199-T6) requires that all out of tolerance readings

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must be resolved and that the " shift note" space at the bottom of the page

be used to explain the out of tolerance values. This was routinely not

done. Further, the cavity level determination was typically not documented

correctly on the round sheets. For example, NIS was circled, meaning that

the level indicator was not in service, and therefore, no value for level

was documented. After completing the round sheets, the licensee requires

that the values for the levels be transferred to the surveillance data

sheets in 180s 0.1-6. The inspectors noted numerous discrepancies in the

data; such as, differences between round sheet values and the values

recorded on the surveillance data sheets, and equal values for SFP and

cavity levels. SFP and cavity levels can not be equal due to the 4.4 inch

offset in the reference zero. Discussions with the licensee resulted in a

daily order, written cn April 8,1987, to advise the operating staff to be

aware of the offset and to ensure that the levels being recorded are accurate.

Additional information was obtained with regards to cavity and SFP levels

at the end of the inspection period. The Auxiliary Building Unit 1 Logs

levels written in at the bottom of

(B0P

the 199-T16)

page. included

Further, the Unitshiftly

2 Logs cavity (B0P 199-T17) included shiftly write-ins

for SFP water level. The inspectors noted, however, that discrepancies also

existed between the logs and the recorded values on the surveillance data

sheets.

From discussions with the licensee and review of the available documentation,

the inspectors concluded that the Technical Specifications were at no time

violated with regards to cavity and SFP water level requirements. All cavity

levels recorded were above 23 feet, therefore, SFP water level was also above

23 feet. Furthermore, since the refueling activities were performed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

per day, SFP and cavity levels were continuously observed by the fuel handling

personnel. Surveillance Procedure 180S 0.1-6, and the temporary change to the

procedure (No. 87-1-283) were not adhered to. The Rounds Sheet, 80P 199-A70,

was not properly completed in accordance with B0P 199-T6. Discrepancies

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existed in the level data recorded for both reactor cavity and SFP water

levels.

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Technical Specifications, Section 6.8.1, states that written precedures shall

be established, implemented, and maintained. Contrary to this, the licensee

failed to adhere to Procedure 1805 0.1-6, " Unit One Mode 6 Shiftly and Daily

Operating Surveillance," and Temporary Change No. 87-1-283, during the Byron

Unit 1 core reload. This is considered a violation (454/87016-01(DRS)).

The inspectors made a further observation with regards to SFP level. Due to

the fact that the low level SFP alarm was continuously in during the refueling,

the purpose for the alarm, to alert the operator of approaching the Technical l

Specification limit, was defeated. The low level alarm setpoint was at 24'6.4", l

which is normally conservative because the level required by Technical Specifi- '

cations is 23 feet. Therefore, this setpoint could have been lowered when

level was decreased, such that, the alarm would have cleared and performed its

intended function. The only other level indication during this time was a

ruler bolted to the SFP wall. The inspectors observed that the ruler was

bent inward toward the bottom, below the 23 foot level, thus affecting the

accuracy of the measuring device. These two issues are considered to be an

Open Item (454/87016-02(DRS)).

No additional violations or deviations were identified; hcwever, a portion

of this area requires further review.

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5. General Plant Observations

The inspectors conducted a number of plant tours during regular hours and

backshifts, to assess plant conditions and control of activities during

the refueling outage. Areas toured included the Turbine Building, Control

Room, Auxiliary Building, and other normally accessible areas. Three

observations were made by the inspectors:

a. Unit 2 was in the startup phase of operation. The inspectors observed

numerous uncontrolled water leaks in the Unit 2 side of the Turbine

Building. The concern was that water was collecting in major walkways,

and had not been mopped up or otherwise controlled for a number of

days. Steam leaks, specifically in the feedwater system, were also

observed by the inspectors,

b. During a tour of the Unit 2 Turbine Building on a backshift, the

inspectors observed dcbris, such as, nails, lumber, and equipment

parts, laying on the floor in major walkways. This is considered a

poor housekeeping practice and a lack of after-job cleanup.

c. The inspectors found three fire doors ajar or propped open; two in the

Turbine Building and one in the Auxiliary Building. The two fire doors

in the Turbine Building were observed to be open repeatedly. The

Control Room was notified on each occasion. The inspectors discussed

with the licensee the compensatory fire protection measures (fire

watch) established for degraded fire barriers in nonsafety-related

areas of the plant. The licensee stated that the fire watch patrol

would be notified and corrective actions would be taken. Operable

fire doors would be closed and maintenance would be performed on

inoperable fire doors.

The above mentioned concerns were discussed with the licensee who stated

i that the cause was related to the operational status of the two units.

Unit 2 was in the startup phase; the piping systems were being heated up.

Unit I was in an outage, and a large volume of work was being performed

involving both licensee and contractor personnel. The inspectors acknow-

ledged the explanations, however, the control during these activities is

considered inadequate and should receive increased licensee attention. The

inspectors will followup on these concerns during a subsequent inspection.

The Resident Inspectors will also be following up on these concerns.

No violations or deviations were identified; however, portions of this area

require further review.

6. Open items

Open items are matters which have been discussed with the licensee, which

will be reviewed further by the inspector, and which involve some action

on the part of the NRC or licensee or both. An open item disclosed during

the inspection is discussed in Paragraph 4.

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7. Exit Interview

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The inspectors met with the licensee representatives (denoted in Paragraph 1) !

on April 9, 1987. The inspectors suararized the scope and findings of the i

inspection. The licensee acknowledged the statements made by the inspectors

with respect to the violation and other noted concerns. The inspectors

also discussed the likely informational content of the inspection report l

with regard to documents or processes reviewed by the inspectors during the

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inspection. The licensee did not identify any such documents / processes

as proprietary.

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ML20213G891

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