IR 05000454/1987031

Insp Repts 50-454/87-31 & 50-455/87-29 on 870727-31. Violation Noted.Major Areas Inspected:Emergency Plan Activations,Equipment,Instrumentation & Supplies, Organization & Mgt Control,Training & Independent Reviews

ML20237K547
Person / Time
Site:	Byron
Issue date:	08/25/1987
From:	Christoffer G, Patterson J, Hironori Peterson, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20237K432	List: IR 05000454/1987031 ML20237K430 ML20237K456
References
50-454-87-31, 50-455-87-29, NUDOCS 8709040410
Download: ML20237K547 (12)

Text

____- - _ - - _ ____ - _ _

_

-

.

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-454/87031(DRSS); 50-455/87029(DRSS)

Docket Nos. 50-454; 50-455 Licenses No. NPF-37; NPF-66 l Licensee: Commonwealth Edison Company l Post Office Box 767 l Chicago, IL 60690 Facility Name: Byron Nuclear Generating Station, Units 1 and 2 Inspection At: Byron Site, Byron, Illinois Inspection Conducted: July 27-31, 1987 Inspectors: .

H. Peterson ph of/M Date

Team Leader

'

.

-

.

Lot / m1l L 5lg 7 Ld. P. Patterson Date M  % f,'?

lG.M.Christofferff

.

Date -

Approved By: //J $ $ ,o// aff/m W.~$nell, Chief Dat'e

'

Emergency Preparedness Section Inspection Summary Inspection on July 27-31, 1987 (Reports No. 50-454/87031(DRSS);

No 50-455/87029(DRSS))

Areas Inspected: Routine, unannounced inspection of the following areas of the emergency preparedness program; licensee action on previously identified items; emergency plan activations; emergency plan and implementing procedures; emergency facilities, equipment, instrumentation, and supplies; organization and management control; training; and independent reviews / audits. The inspection involved observations onsite by three NRC inspector Results: One violation was identified as a result of this inspection which relates to 10 CFR Part 50.54(q); following and maintaining in effect the emergency plan PDR ADOCK 05000454 O PDR

. .

.

DETAILS Persons Contacted Commonwealth Edison Company

• R. Pleniewicz, Production Superintendent

• R. Ward, Services Superintendent

• R. Flahive, Rad / Chem Supervisor

• W. Burkamper, QA Superintendent

• M. Snow., Reg. Assurance Superintendent-

• L. Sues, Asst. Superintendent, Operations

• T. Joyce, Asst. Superintendent, Tech Services

• D. Drawbaugh, GSEP Trainer

• M. Whitemore, GSEP Coordinator

• F. Hornbeak, Tech Staff Supervisor

• Flowers, ISI Coordinator

• Berg, Nuclear Safety

• A. Chernick, Training Supervisor

• Zittle, Reg. Assurance Staff

• Britton, QA Inspector W. Pirnat, Reg. Assurance Staff R. Chrzanowski, Reg. Assurance Staff J. Langan, Reg. Assurance Staff S. Sober, Health Physics Group Leader W. McNeill, Lead Rad / Chem Foreman R. Munson, Rad / Chem Foreman l R. Hopkins, Shift Engineer A. Kimbler, Shift Engineer

• Indicates those who attended the July 31, 1987 exit interview.

i Licensee Actions on Previously Identified Items There were no previously identified existing open items relating to Emergency Preparedness with the exception of one Exercise Weaknes This Exercise Weakness (454/86013-02; 455/86011-02) will be evaluated in the next Emergency Preparedness Exercise.

. Emergency Plan Activations l

l-Documentation related to activations of the Generating Station Emergency Plan (GSEP) were reviewed. Since the previous routine inspection on September 29 through October 3, 1986, six activations of the GSEP had occurred. Documentation related to each GSEP activation had been gathered into a file specific to the activatio Included were notification sheets, deviation reports, shift logs, notes or other documentation as appropriat E-___--_----_-__---_-----_----_-- - - . - - - - - -

.

.

..

.

On November 20, 1986, a loss of both Component Cooling Water systems was experienced in Unit 2, which resulted in an ALERT declaration based on EAL No. 1 On March 4,1987, the Shif t Engineer (SE) classified a Notification of Unusual Event (NUE) per EAL No. 14, due to Unit 2 exceeding 50% reactor power as specified in the Technical Specifications Limiting Condition for Operation (LCO) action requirements for ^I (Axial Flux Difference).

On March 6, 1987, Unit 2 experienced a loss of pressure in 28 Safety Injection Accumulator and initiated a Reactor Shutdown per Technical Specification LC0 action requirement. This incident was classified as a NUE per EAL No. 14 by the S }

On March 21, 1987, Unit 2, during a scheduled RCS leak rate surveillance, the leak rate was found to be 1.298 GPM. At 0300, it was found that the Technical Specification leakage limit of I gpm unidentified leakage was exceede At 0857, an NUE per EAL Nos. 14 and'16 was declare On April 4,1987, Unit 1 experienced a loss of Component Cooling Water Syste The Component Cooling Water pumps tripped on low surge tank level. An Alert classification was declared per EAL No. 12. Operators were sent to restore level and pumps were restarted after 17 minute i l On July 13, 1987, Unit 1 failed a surveillance, 1 BOS 3.1.1.20, l

'

Rev 51A, resulting in a Technical Specification required shutdown due to inoperable Train A SSPS (Solid State Protection System).

A NUE was declared per EAL No. 1 I i With the exception of one activation, each of the events were adequately 1 I

classified under the Emergency Action Levels. State and local agencies I and the NRC were properly notifie The one exception was the NUE on March 21, 1987, the " Exceeding of Reactor )

Coolant System Leak Rate as specified in the Technical Specifications,"

EAL No. 16. At 0300, it was found that Technical Specification leakage limit of 1 GPM unidentified leakage had been exceeded as calculated per Surveillance BOS 4.6.2-la, Rev 51. At 0529, reactor power was lowered to allow access to investigate the cause of the excess leakage. Per the l condition existing between 0300 and 0529, a NUE per EAL No. 16 should have l

been classified. Instead, the licensee delayed a classification while reactor power was lowered and an investigation of the leakage was ,

conducte At 0840, the source of the leak was identified and reactor ;

power continued to be ramped down to permit repair of the leaking valu l'

It was not until 0857 that a GSEP condition was declared and a NUE was classified per EAL Nos. 14 and 16. (EAL Nu. 14, " Equipment described in the Technical Specifications is degraded such that a limiting condition for operation requires a shutdown.")

The emergency condition was identified and existed for approximately five !

hours and 57 minutes before a decision was made to classify the emergency I condition per the GSEP. This was an undue delay in classifying and declaring a GSEP condition and failure to adequately implement t.he GSE ;

I

1 L

_ _ _ _ _ _ _ - _ _ _ _ - _ __ - _- -

.

.

Upon further investigation and additional information submitted by the licensee, it was determined that the root cause was the licensee's erroneous interpretation of the EAL and what it meant by exceeding LC0 limit It was found that the licensee interpreted EAL No. 16 as exceeding both the LC0 limits and the specified grace period in the LCO action requirement This meant the licensee, once exceeding the RCS leak rate limit as specified in the Technical Specification, gave themselves the four hour grace period to correct and reduce the leak rate before classifying an emergency conditio The licensee interpreted the Technical Specification LC0 as both the LC0 and its associated action requirements. Although, both the LC0 and the action requirements come under the same heading, they are considered separate items. This means, if you exceed the Technical Specification i

LC0 then you must follow the associated action requirements as necessar To exceed the LC0 does not mean you must also exceed the action requirement The Applicability Technical Specification 3.0.2 states, " Noncompliance with a specification shall exist when the requirements of the LC0 and associated Action requirements are not met within the specified time intervals." This statement strictly identifies the separation of LC0 and action requirements as being two separate items and not as one single item. Thus, to exceed both the LC0 and its associated action requirements constitutes a noncompliance to the Technical Specification. This is the basis for EAL No. 14. But, in EAL No.16, by referencing the leak rate as specified in the Technical Specification, it refers to the numeric limit for the leak rate (the LC0) and not the full noncompliance of the Technical Specification. Therefore, exceeding the RCS leak rate (the LCO)

a GSEP condition per EAL No.16 should have been declared prior to taking and completing the grace period as specified in the action requirement During the inspection, a review of 35 Licensee Event Reports (LERs)

generated since the last inspection was performed to determine if events had been properly classified under the Emergency Preparedness (EP) program. The following LERs were reviewed:

LERs86-028 through 87-016 for Unit 1 LERs86-001 through 87-008 for Unit 2 With the exception of one LER, all events were found to be properly classified as events (LERs86-001 [ Unit 2],87-012 [ Unit 1]) or as not falling under the EP progra The one exception was LER 86-028 (Unit 1), " Manual Rx Trip due to Rod l Drop Caused by Faulty Circuit Cards." At 0650 on October 2, 1986, during a reactor startup, with Control Bank "C" at 195 steps and Control Bank "D" at 80 steps, Alarm Window 1-10-C06, " Rod Control Urgent Failure,"

annunciate All rods were determined to be inoperable, but considered

_ _ _ - _____ _ _ - .

.

.

. . .

trippable. . Troubleshooting procedure, designated by Byron Station as LCO. Action Response (LC0AR), 1 BOS 1.3.1-la was entered. . Troubleshooting was performed and circuit cards in the ZAC rod drive power cabinet were being replaced by Instrument Maintenance when, at 1150, four rods in Control Bank "C" dropped, at which time the Shift Engineer (SE) ordered the reactor to be manually trippe The' reactor was manually tripped and ell remaining rods dropped. The reactor did not trip on a negative rate tri This was as expected, as'

the reactor power was only 3% power. The manual trip order was correct as the rods were inoperable _due to the urgent-alarm. Tne circuit cards responsible for the rod drop were replaced, the alarm cleared, and Control-Bank "C" was exercised. The trip recovery was normal, and the startup was resume Although-the corrective actions were correct and the reactor was' eventually placed in a safe condition, once the rods were found to be inoperable this er.ceeded the Technical Specification LCO and placed the plant in tue action requirement. In this case, the Technical Specifications LC0 action requirements does not give a grace period (a time interval to correct the problem). Therefore, once the rods are determined to be inoperable, the plant is to be shutdown within six hours as requi,ea per the Technical Specification action requirements This then constitutes an Emergency Classification of an NUE per EAL No. 1 The plant instead interpreted the six hours as time to troubleshoot the )

proble The SE did not classify the emergency condition per the GSEP, rather he continued the troubleshooting for five hours. After which 1 another problem caused four rods to drop. The SE cor'actly ordered a manual reactor trip. Once the reactor was tripped, the SE rationalized the plant's condition as not being applicable to the Control Rod Technical Specifications (3/4.1.3.1), therefore, it did not warrant an emergency classification. This reasoning is incorrec Once the rods were determined to be inoperable, a reactor shutdown was required by the action requirements. Knowing that the rods were inoperable, the only method to shutdown was to trip the rods. The SE  !

decided to troubleshoot and possibly correct the problem prior to the i need to inflict physical shock to the reactor by tripping, the reactor I was in fact tripped. This in effect satisfies the action requirement to shutdown the reactor, therefore, satisfying the condition in the GSEP .

EAL for a NU A NUE per EAL No. 14 should have been declare l The two aforementioned events relating to the untimeliness and failure to i adequately follow and implement the GSEP by classifying and declaring an emergency condition per EALs is considered to be a violation and will be i tracked as an Open Item (50-454/87031-01; 50-455/87029-01), i Based on the above findings, one violation was identifie _____ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ .

____ -_________-_ _ _ _ -

.

.. Operational Status of the Emergency Preparedness Program (82701) Eme m ncy Plan and Implementing Procedures

" a current, approved Generating Stations Emergency Plan (GSEP)

Revision 6, issued February 1987, is in effect. The Byron Annex, Revision 2, which was effective May 1986, was in the revision process at the time of this inspection. The proposed changes were in the station management review process and Corporate approval of the Annex changes was also pending. Revision 3 of the Byron Annex with the changes based on Revision 6 of the Generic GSEP, was not received by the NRC until after the inspectio '!here is ongoing work in incorporating the new generic EALs for PWR' This is similar to the change that was placed into effect at the Zion Station prior to the FFE-2. No other significant changes in the EP program at Byron have occurred since our inspection in September 198 A review of eleven "BZP", Emergency Plan Implementing Pro-cedures (EPIPs) changes was conducted. It was confirmed that each of these revised procedures were distributed within one week after being officially approve This complies with 10 CFR Part 50.54(q) and i

Appendix E, Paragraph V requirements, which state that changes must be sent to the NRC within 30 days. To assure that current EPIPs were being used onsite, a random selection of ten additional BZP procedures were checked with the copies used in the Shift Engineer's (SE) office and in the Control Room. Both locations had the current approved BZP procedures in their manual Based on the above findings, this portion of the licensee's program was acceptabl Emergency Facilities, Equipment, Instrumentation and Supplies Documentation was reviewed regarding testing of the GSEP communications system for the period October 1986 through July 1987. The documentation was adequate and in accordance with licensee commitments. There have been no major changes to ,

the emergency response facilities since the September 1986 inspectio l The Procedure BZP 500-T1, Revision 5 (Checklist - Emerger y Facilities Communication) was found to contain a word error, in ;

that, Section (1)(d) stated, "The Communicator in the EOF initiates j a call to NRC E0C from the ENS extension and after checking the l'

qualitv of voice communications request a call back to TSC . . . ."

The le t word should be, "E0F." This error made it necessary to submit a procedure change. The GSEP Coordinator submitted the procedure change into the system on July 30, 1987. Since it takes approximately one month for a procedure to be revised, the GSEP Coordinator will oencil in the changes on the necessary documents until the revision is approve _ _ _ - _ - _ _ _ _ _ _ _ _ _

. _ _ - - _ _ _ _ _ _ _ - -

-

.

• * ..

.

A random test of the communications equipment in the OSC, TSC and Control Room was conducte No problems were identified during this tes A requested inventory of the TSC, OSC, and Control Room supply cabinets was observed. No major problem were identified. Inventory recc.., of emergency supplies for the period October 1986 through June 1987 were reviewed and found to be adequate. Missing supplies noted in the inventory checklist were restocked in a timely manne The inspector determined that BZP 500-T6 (Checklict - Technical Support Center, Instruments / Dosimetry and Related Items) needed further clarification regarding the amount of Anti-Contamination clothing. The GSEP Coordinator submitted a procedure revision on July 30, 198 It was discussed with the GSEP Coordinator that an inventory list should be posted with or near emergency supplies to aid users in determining what supplies are available during an emergency. Such lists were already posted in the TSC, E0F and the hospital, but not in the Control Room or other areas with designated emergency supplies. On July 31, 1987, the GSEP Coordinator began posting inventory lists in the Control Room, assembly areas, and near the environs kit.

\

During a previous inspection (86030 and 86026), two improvement items were noted, regarding inventory checklists and procedure The licensee revised the procedures to clarify certain pcints and to improve the consistency of the checklist forma Based on the above findings, this portion of the licensee's program was acceptabl c. Organization and Management Control The assigned duties to the GSEP Coordinator were found to have remained the same. Following a discussion with the GSEP Coordinator and a review of pertinent documentation, it was determined that there had been no major changes to the licensee's emergency organiza-tion or management control systems. However, there were some staffing changes to the TSC Director position In the Operations Director position, one person was transferred to a new position and he was removed from the call list. Another person recently retired and will also be removed from the call lis Two new personnel are presently in training, scheduled to {

complete their training and be qualified by September 30, 198 Presently there are three fully qualified Operations Director In the Environs Director position, one person terminated employment in June and another has been transferred to a new position. Presently I there are only two qualified Environs Directors, with a third person in trainin _ _ - _ - _ - _ _ - _ - _ - - - _ _ _ _ _ _ _ _ _ -

_ _ - _- - -

.

.. .

In the Security Director position, one person was transferred to a new position and a newly qualified individual was added on July 27, 1987. Presently there are three qualified Security Director In the Administration Director position, one person has been transferred to a new job. Presently there are three qualified Administrative Director In the Stores Director position, one person transferred to a new position and one person recently retired. A new individual is in training and will be qualified by August 30. Presently there are only two qualified Store Director The most recent changes to the call list have not yet been incorporated, but will be updated in the new revision scheduled to be completed by the ena of Augus The Licensee's Letters of Agreement with local emergency support organizations were updated in 1987. The letter of agreement with the Training Contractor, RMC (Radiation Management Corporation), to provide training to offsite organizations was also updated. It was found that RMC did indeed offer training to offsite organizations, but in one case the Byron Fire Department refused the medical / hospital training on May 20, 1987. They felt that they were already receiving equivalent or better training through their own progra Based on the above findings, this portion of the licensee's program was acceptabl d. Training Training records of 14 individuals designated to fill key emergency response positions were examined to determine if they had received all the required training. Twelve of the 14 were current on their EP training. The other two individuals designated as OSC Supervisors had not received any required classroom training since April 198 Further review determined that one of the individuals had been designated as OSC Supervisor about six months earlier. A review of the Training Matrix for OSC Supervisors determined that five individuals listed for that position had no classroom training since April 1986. This classroom training includes three modules; Generic Emergency Plan Training, Operational Support Cet ter Director /

Supervisor and Communications Systems. These five individuals have participated in a drill or an annual exercise since April ,

1986; however, none had served as an OSC Supervisor in these i activitie To correct this training deficiency, the GSEP Coordinator scheduled all five individuals for OSC Supervisor Training en August 18 and 21, 198 It was verified that an internal letter was issued on July 31, 1987, with copies to the individual's supervisor and the Training Supervisor. Ic was determined that the time . interval between training of these individuals was a few days in excess of 15 month .

_ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

-

.

• * . 1

,

Clarification of the term annual as it applies to emergency response drills, exercise, tests and training should be considered. NRC has determined that the interpretation of " annual" pertaining to training and other facets with the exception of exercises is to mean_once every 12 month This training related item will be considered an Open Item until the i training records for this OSC position are examined in a subsequent I inspection (0 pen Item No. 50-454/87031-02; 50-455/87029-02).

l The GSEP Coordinator was informed.that classronc training should i not be delayed to coincide with an annual exercise even when the l exercise date was postponed. However, drills including table-top activities should be coordinated and planned to take place closer to the annual exercise as a meaningful preparation for the exercis One sigr,ificant change in EP training has occurred since the previous inspection. Monthly training sessions on various phases of GSEP are now required for all Station Director Thit, is a new approach and should prove beneficial by extending the format into 12 distinct areas of interes A walkthrough and interview was conducted with one team consisting of a Station Director and an Environs Director. Questions were_ asked about their duties and responsibilities, and three GSEP scenario situations were presented to them. Two scenarios required the use and demonstration of the dose assessmant computer and subsequent protective actions recommendations. Both the Station Director and {

i Environs Director exhibited knowledge and expertise in their j respective field of responsibilitie i l Interviews were also conducted with two Shift Engineers (SEs) and with two OSC Supervisor The SEs were presented with mini-scenarios leading to an EAL condition and subsequent emergency classificatio Each was able to classify the event; and when it escalated to a Ger.eral Emergency made the appropriate Protective Action Recommendations. Evacuation time studies were also discusse Both individuals demonstrated good comprehension of the emergency preparedness program. The two OSC Supervisors also performed well and both indicated a good understanding of their responsibilitie A table-top training for the TSC organization was observed on July 27, 1987. This training incorporated a mini-scenario which simulated a GSEP activation of an Alert due to a steam generator !

(S/G) tube rupture and a subsequent S/G relief valve opening which :

resulted in an escalation to a Site Area Emergency. The training i exercised the Director positions of the TSC Organization. The table- l top was an adequate practice in dose assessment, Protective Actio '

Recommendations, notifications and other corrective GSEP actions.

l l

!

i 9  ;

i I

l

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

. . .

To better integrate GSEP related activitics and other EP related information into the-training program, the GSEP Coordinator sends copies of GSEP ac.tivations and copies of NRC. Emergency Preparedness Inspection Reports from all Commonwealth Edison facilities to traitiing. This sharing of information was often used to enrich the course. content for EP training. Requalification training for the

-

Senior Reactor Operator's License now includes a complete scope of EP program requirement Based on the above findings, and with the exception of the Open Item regarding training for OSC Supervisors, this portion of the licensee's program was acceptable.

l e. Independent Reviews / Audits l The Quality Assurance (QA) Department records of audits and surveillance of the Byron emergency preparedness program, during ,

the period of October 1986 through July 1987 were reviewed. Through this record review, it was dete,' mined that the surveillance were of appropriate scope and adequately documente The annual onsite QA audit (No. 06-87-23) for emergency preparedness j l

was conducted on July 15-20, 1987 and no major findings were 4

!

identified. However, at the time of this NRC inspection, the report had not been approved by the corporate office and should be reviewed during the next.NRC emergency preparedness audit. The licensee's emergency preparedness program is scheduled to be audited by the offsite QA department during the week of August 16, 198 The QA program for followup on QA audit identified problems appeared adequate for assuring that corrective action is reported to the QA department within 30 day QA also conducts a followup to evaluate the corrective actions. If a deficiency is found during a surveillance, the corrective actions are usually taken immediately following their identificatio The QA department conducts an audit of these deficiencies, 60 days after closing the surveillance to assure that the deficiency does not recu It was determined through interviews and document review that there is a need for the corporate emergency preparedness department to improve communications with Byron Station. -In December 1986, the l corporate emergency preparedness department conducted an audit of-l the emergency preparedness program at Byron. A formal report was never issued to Byron Station. During this NRC audit, the Byron GSEP Coordinator informed the corporate office that the inspector had requested the December 1986 audit documentation for review purposes and on July 31, 1987, the corporate office faxed the report summary to Byro _ _ - - _ - _ _ _

___ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___________ _____ __-

.

,

.. .

Additionally, on April 8, 1987, the corporate emergency preparedness dapartment assisted Byron in' conducting the required annual GSEP Communications systems tes At the time of this inspection, the station had not received a complete copy of the test repor Corporate was notified by the GSEP Coordinator that the NRC wanted to review the test documentation and on July 31, 1987, a cover sheet summarizing the annual communications drill was taxed to Byro Based on the above findings, this portion of the licensee's program was acceptable. However, the following item should be considered for improvement.

i

! * The liceasee should take immediate action to assure that verbal l and writ' en communications between corporate and Byron Emergency l Preparedi ess department are improve . Exit Interview On July 31, 1987, the inspectors met with those licensee representatives listed in Section 1 to present the preliminary inspection finding The licensee was also asked if any of the information discussed during the exit was proprietary. The licensee indicated that none of the information discussed was proprietary in natur ss ] 3d 13 ) '. .~'

"

n ..

- _ _ _ _ - _ _ - - _ _ _ -

_ _ . . _ _ _ . _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ . . _ . _ _ _ _ _ _ _ . _ _ _ _

.

.

., .

USNRC'DS M 1 SEP '3 A 9 go l

l

l i

s i

i

'

i l

l

,

l A

O .

e w____--_--__ _ _ - _ _ - - _ _ . - _ _ _ _ - - _ _ _ _ _ _ - _ _ _ _ .- - _ _ _