IR 05000454/2007006: Difference between revisions

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| issue date = 09/14/2007
| issue date = 09/14/2007
| title = IR 05000454-07-006 and 05000455-07-006, on 07/16/2007-08/03/2007; Byron Station, Units 1 and 2; Identification and Resolution of Problems
| title = IR 05000454-07-006 and 05000455-07-006, on 07/16/2007-08/03/2007; Byron Station, Units 1 and 2; Identification and Resolution of Problems
| author name = Skokowski R A
| author name = Skokowski R
| author affiliation = NRC/RGN-III/DRP/RPB3
| author affiliation = NRC/RGN-III/DRP/RPB3
| addressee name = Crane C M
| addressee name = Crane C
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| docket = 05000454, 05000455
| docket = 05000454, 05000455
Line 19: Line 19:


=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:ber 14, 2007
[[Issue date::September 14, 2007]]


Mr. Christopher M. CranePresident and Chief Nuclear Officer Exelon Nuclear Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555
==SUBJECT:==
BYRON STATION, UNITS 1 AND 2 NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000454/2007006 AND 05000455/2007006


SUBJECT: BYRON STATION, UNITS 1 AND 2 NRC PROBLEM IDENTIFICATIONAND RESOLUTION INSPECTION REPORT 05000454/2007006 AND 05000455/2007006
==Dear Mr. Crane:==
On August 3, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed a team inspection of problem identification and resolution at your Byron Station, Units 1 and 2.


==Dear Mr. Crane:==
The enclosed inspection report documents the inspection findings which were discussed on August 3, 2007, with Ms. Snow and other members of your staff.
On August 3, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed a teaminspection of problem identification and resolution at your Byron Station, Units 1 and 2.


The enclosed inspection report documents the inspection findings which were discussed on August 3, 2007, with Ms. Snow and other members of your staff.This inspection was an examination of activities conducted under your license as theyrelate to the identification and resolution of problems, compliance with the Commission's rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved selected examination of procedures and representative records, observations of activities, and interviews with personnel. There were no findings of significance identified during this inspection. On the basis of thesample selected for review, the inspection team concluded that Byron was generally effective in the identification, evaluation, and resolution of problems. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter andits enclosure will be available electronically for public inspection in the NRC Public Document C. Crane-2-Room or from the Publicly Available Records (PARS) component of NRC's document system(ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html(the Public Electronic Reading Room).
This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, compliance with the Commissions rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved selected examination of procedures and representative records, observations of activities, and interviews with personnel.


Sincerely,/RA Mark A. Ring for/Richard A. Skokowski, ChiefBranch 3 Division of Reactor ProjectsDocket Nos. 50-454; 50-455License Nos. NPF-37; NPF-66
There were no findings of significance identified during this inspection. On the basis of the sample selected for review, the inspection team concluded that Byron was generally effective in the identification, evaluation, and resolution of problems.


===Enclosure:===
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Inspection Report No. 05000454/2007006 and 05000455/2007006


===w/Attachment:===
Sincerely,
Supplemental Informationcc w/encl:Site Vice President - Byron StationPlant Manager - Byron Station Regulatory Assurance Manager - Byron Station Chief Operating Officer Senior Vice President - Nuclear Services Vice President - Operations Support Vice President - Licensing and Regulatory Affairs Director Licensing Manager Licensing - Braidwood and Byron Senior Counsel, Nuclear Document Control Desk - Licensing Assistant Attorney General Illinois Emergency Management Agency State Liaison Officer, State of Illinois State Liaison Officer, State of Wisconsin Chairman, Illinois Commerce Commission B. Quigley, Byron Station
/RA Mark A. Ring for/
Richard A. Skokowski, Chief Branch 3 Division of Reactor Projects Docket Nos. 50-454; 50-455 License Nos. NPF-37; NPF-66 Enclosure: Inspection Report No. 05000454/2007006 and 05000455/2007006 w/Attachment: Supplemental Information cc w/encl: Site Vice President - Byron Station Plant Manager - Byron Station Regulatory Assurance Manager - Byron Station Chief Operating Officer Senior Vice President - Nuclear Services Vice President - Operations Support Vice President - Licensing and Regulatory Affairs Director Licensing Manager Licensing - Braidwood and Byron Senior Counsel, Nuclear Document Control Desk - Licensing Assistant Attorney General Illinois Emergency Management Agency State Liaison Officer, State of Illinois State Liaison Officer, State of Wisconsin Chairman, Illinois Commerce Commission B. Quigley, Byron Station


=SUMMARY OF FINDINGS=
=SUMMARY OF FINDINGS=
IR 05000454/2007006; 05000455/2007006; 07/16/2007-08/03/2007; Byron Station, Units 1and 2; Identification and Resolution of Problems.The inspection was conducted by a Senior Resident Inspector, two regional specialists, andan Illinois Emergency Management Agency inspector. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609,
IR 05000454/2007006; 05000455/2007006; 07/16/2007-08/03/2007; Byron Station, Units 1 and 2; Identification and Resolution of Problems.
"Significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated July 2006.Identification and Resolution of ProblemsOverall, the inspection team determined that the Corrective Action Program (CAP) was effectivein the identification, evaluation, and resolution of problems. The inspection team determined that the licensee typically identified problems and placed them in the CAP. The inspection team identified that operating experience was utilized and considered. The inspection team noted that the licensee was effective in conducting root cause and apparent cause evaluations and effectively resolved most problems categorized as more significant. Based on interviews, observations of plant activities, reviews of the CAP and the Employees Concerns Program, the inspection team determined that site personnel were willing to raise safety issues.A.
 
The inspection was conducted by a Senior Resident Inspector, two regional specialists, and an Illinois Emergency Management Agency inspector. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609,
Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated July 2006.
 
Identification and Resolution of Problems Overall, the inspection team determined that the Corrective Action Program (CAP) was effective in the identification, evaluation, and resolution of problems. The inspection team determined that the licensee typically identified problems and placed them in the CAP. The inspection team identified that operating experience was utilized and considered. The inspection team noted that the licensee was effective in conducting root cause and apparent cause evaluations and effectively resolved most problems categorized as more significant. Based on interviews, observations of plant activities, reviews of the CAP and the Employees Concerns Program, the inspection team determined that site personnel were willing to raise safety issues.


===NRC-Identified and Self-Revealing Findings===
===NRC-Identified and Self-Revealing Findings===
Line 47: Line 51:
None.
None.


===B.Licensee-Identified Violations===
===Licensee-Identified Violations===


None.
None.


3
=REPORT DETAILS=


=REPORT DETAILS=
{{a|4OA2}}
4OA2Problem Identification and Resolution (PI&R) (71152B)a.Assessment of the Corrective Action (CA) program (1)Inspection ScopeThe inspection team reviewed the procedures describing the licensee's CorrectiveAction Program (CAP). The licensee identified problems for evaluation and resolution by initiating issue reports (IRs) that were entered into the condition reporting system.
==4OA2 Problem Identification and Resolution (PI&R)==
{{IP sample|IP=IP 71152B}}
a.
 
Assessment of the Corrective Action (CA) program
: (1) Inspection Scope The inspection team reviewed the procedures describing the licensees Corrective Action Program (CAP). The licensee identified problems for evaluation and resolution by initiating issue reports (IRs) that were entered into the condition reporting system.
 
The IRs were subsequently screened for operability, categorized by significance, and assigned for further evaluation and resolution.
 
The inspection team evaluated the methods for assigning and tracking issues to ensure that issues were screened for operability and reportability, prioritized for evaluation and resolution in a timely manner commensurate with their safety significance, and tracked to identify adverse trends and repetitive issues. In addition, the inspection team interviewed plant staff and management to determine the staffs understanding of, and involvement with the CAP.
 
The inspection team reviewed IRs to assess whether the licensee adequately evaluated and prioritized identified problems. The issues reviewed encompassed the full range of evaluations, including root cause analyses, apparent cause evaluations, and common cause analyses. Samples of IRs that were assigned lower levels of significance were also reviewed by the inspection team to ensure they were appropriately classified. The review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. For significant conditions adverse to quality, the inspection team reviewed the licensees corrective actions to preclude recurrence. The inspection team observed selected daily Station Ownership Committee (SOC) IR screening meetings, in which station personnel reviewed new IRs for prioritization and assignment. The inspection team also reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected items.
 
The inspection team reviewed the corrective actions associated with selected IRs to determine whether the actions addressed the identified causes of the problems. The inspection team reviewed IRs for repetitive problems to determine whether previous corrective actions were effective. The inspection team also reviewed station timeliness in implementing corrective actions and their effectiveness in precluding recurrence for significant conditions adverse to quality. The inspection team reviewed corrective actions associated with selected non-cited violations (NCVs) and findings to determine whether the station properly evaluated and resolved these issues.
 
This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152.
: (2) Assessment No findings of significance were identified.
 
===.1 Identification of Issues===
 
The team concluded, in general, that the station identified issues and entered them into the CAP at the appropriate level. The teams review of operating experience reports identified that the licensee was appropriately including the issues into the CAP. The licensee also used the CAP to document instances where previous corrective actions were ineffective or were inappropriately closed. The inspection team noted that relatively few deficiencies were identified by external organizations (including the NRC)that had not been previously identified by licensee personnel.
 
The team selected three high risk systems, which included the non-essential service water, condensate system, and the 120 volt direct current electrical distribution system to review in detail. The teams review was to determine whether the licensee was properly monitoring and evaluating the performance of these systems through effective implementation of station monitoring programs. The team interviewed the system engineer of the applicable system, non-license operators, and performed partial system walk-downs of the systems. A five year review of the 480 volt Molded Case Circuit Breaker (MCCB) and fire protection issues was also undertaken to assess the licensees efforts in monitoring for system degradation due to aging aspects.
 
===.2 Prioritization and Evaluation of Issues===


The IRs were subsequently screened for operability, categorized by significance, and assigned for further evaluation and resolution.The inspection team evaluated the methods for assigning and tracking issues to ensurethat issues were screened for operability and reportability, prioritized for evaluation and resolution in a timely manner commensurate with their safety significance, and tracked to identify adverse trends and repetitive issues. In addition, the inspection team interviewed plant staff and management to determine the staff's understanding of, and involvement with the CAP.The inspection team reviewed IRs to assess whether the licensee adequately evaluatedand prioritized identified problems. The issues reviewed encompassed the full range of evaluations, including root cause analyses, apparent cause evaluations, and commoncause analyses. Samples of IRs that were assigned lower levels of significance were also reviewed by the inspection team to ensure they were appropriately classified. The review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. For significant conditions adverse to quality, the inspection team reviewed the licensee's corrective actions to preclude recurrence. The inspection team observed selected daily Station Ownership Committee (SOC) IR screening meetings, in which station personnel reviewed new IRs for prioritization and assignment. The inspection team also reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for
The team concluded that the licensee had properly prioritized issues based on their safety significance, and that issues were generally well evaluated. The team did not identify any issue reports that were not properly prioritized. In addition, the team observed several SOC and management review board committee (MRC) meetings, and concluded that both committees generally ensured the proper prioritization and appropriate investigation assignments for plant issues. Examples of SOC actions taken were to assign work requests, evaluations, and/or corrective action to specific departmental groups. The team observed the MRC function in an oversight role of the SOC. For example, the MRC changed the SOC recommended action of some issues based on committee dialogue and additional station awareness of the issue. The MRC performed grading of investigative CAP products to provide feedback on product quality to the sponsoring manager. The team concluded that issues were properly prioritized and generally well evaluated.


selected items.The inspection team reviewed the corrective actions associated with selected IRs todetermine whether the actions addressed the identified causes of the problems. The inspection team reviewed IRs for repetitive problems to determine whether previous corrective actions were effective. The inspection team also reviewed station timeliness in implementing corrective actions and their effectiveness in precluding recurrence for significant conditions adverse to quality. The inspection team reviewed corrective actions associated with selected non-cited violations (NCVs) and findings to determine whether the station properly evaluated and resolved these issues.This inspection constitutes one biennial sample of problem identification and resolutionas defined by Inspection Procedure 71152.
However, the team questioned the licensee regarding two IRs that had been through either the SOC or the SOC and MRC and warranted additional evaluation of prompt operability. In both cases observed, additional data gathering and assessments by the team determined that no actual operability concern existed. These IRs represented near misses in that there was information in the IRs that should have called into question the operability of plant equipment but the review committees failed to recognize.


4(2)AssessmentNo findings of significance were identified.
Observations Fire Protection There were a large number of issues being identified by licensee and NRC personnel in the area of fire protection. These issues dealt with hardware issues, surveillance issues, documentation, and corrective action. Many of these issues were NRC identified. Examples included: missing beam fire protection (three examples), failure to test remote shutdown panel switches, problems with the pre-fire plan and the fire protection report, fire dampers not installed, and CO2 operability with open doors. In addition, a large number of issues have been identified by licensee personnel, many of these issues have been legacy or long standing issues. The team observed significant effort to address the individual issues and observed significant effort addressing four groups of hardware issues by the Plant Health Committee; but there appeared to be little effort to perform an overall assessment of the fire protection related issues.


===.1 Identification of IssuesThe team concluded, in general, that the station identified issues and entered them intothe CAP at the appropriate level.===
===.3 Effectiveness of Corrective Action===
The team's review of operating experience reports identified that the licensee was appropriately including the issues into the CAP. The licensee also used the CAP to document instances where previous corrective actions were ineffective or were inappropriately closed. The inspection team noted that relatively few deficiencies were identified by external organizations (including the NRC)that had not been previously identified by licensee personnel.The team selected three high risk systems, which included the non-essential servicewater, condensate system, and the 120 volt direct current electrical distribution system to review in detail. The team's review was to determine whether the licensee was properly monitoring and evaluating the performance of these systems through effective implementation of station monitoring programs. The team interviewed the system engineer of the applicable system, non-license operators, and performed partial system walk-downs of the systems. A five year review of the 480 volt Molded Case Circuit Breaker (MCCB) and fire protection issues was also undertaken to assess the licensee's efforts in monitoring for system degradation due to aging aspects.


===.2 Prioritization and Evaluation of Issues The team concluded that the licensee had properly prioritized issues based ontheir safety significance, and that issues were generally well evaluated.===
The inspection team concluded that the licensee was generally effective in the resolution of problems and implementation of corrective actions. The problems identified using a root or apparent cause methodologies were resolved in accordance with program and NRC requirements. The inspection team concluded that corrective actions were generally completed in an appropriate time frame.
The team did not identify any issue reports that were not properly prioritized. In addition, the team observed several SOC and management review board committee (MRC) meetings, and concluded that both committees generally ensured the proper prioritization and appropriate investigation assignments for plant issues. Examples of SOC actions taken were to assign work requests, evaluations, and/or corrective action to specific departmental groups. The team observed the MRC function in an oversight role of the SOC. For example, the MRC changed the SOC recommended action of some issues based on committee dialogue and additional station awareness of the issue. The MRCperformed grading of investigative CAP products to provide feedback on product quality to the sponsoring manager. The team concluded that issues were properly prioritized and generally well evaluated.However, the team questioned the licensee regarding two IRs that had been througheither the SOC or the SOC and MRC and warranted additional evaluation of prompt operability. In both cases observed, additional data gathering and assessments by the team determined that no actual operability concern existed. These IRs represented near misses in that there was information in the IRs that should have called into question the operability of plant equipment but the review committees failed to recognize.


5ObservationsFire ProtectionThere were a large number of issues being identified by licensee and NRC personnelin the area of fire protection. These issues dealt with hardware issues, surveillance issues, documentation, and corrective action. Many of these issues were NRC identified. Examples included: missing beam fire protection (three examples), failure to test remote shutdown panel switches, problems with the pre-fire plan and the fire protection report, fire dampers not installed, and CO 2 operability with open doors. Inaddition, a large number of issues have been identified by licensee personnel, many of these issues have been legacy or long standing issues. The team observed significant effort to address the individual issues and observed significant effort addressing four groups of hardware issues by the Plant Health Committee; but there appeared to be little effort to perform an overall assessment of the fire protection related issues.
Observations 480 Volt Molded Case Circuit Breakers (MCCBs)
The inspection team performed a review of the high failure rate of Westinghouse 480 V MCCBs. The number of documented failures was: outage B2R12 - 44 of 120 tested (37 percent), outage B1R14 - 63 of 165 tested (38 percent), and outage B2R13 - 18 of 94 tested (19 percent). The team noted that based on failure laboratory analysis completed by a licensee contractor, all identified failures were attributed to breaker bar twisting. The lab also concluded that fixed magnetic breakers have not shown problems with tripping high out-of-tolerance (OOT). While there was much evidence to support breaker bar twisting as the cause of these failures, the inspection team also noted there was evidence of age-related degradation, such as dried and separated grease, that appeared to be dismissed by the licensee.


===.3 Effectiveness of Corrective ActionThe inspection team concluded that the licensee was generally effective in the resolutionof problems and implementation of corrective actions.===
Also during the inspection teams review of the MCCB failures, as documented in the licensees corrective action program, the team noted that the licensees practice was not to consider all problems as failures. For example, the licensee did not consider individual phases with as-found OOT or breakers that did not reset following testing as failures. The inspection team found at least one example in the licensees corrective action program (IR 446538) of MCCBs that did not reset following testing, and three cases with individual phases with as-found OOT. The inspection team ascertained that the three cases of OOT phase settings were analyzed by the licensees contractor, which determined that the failures were due to hardened grease.
The problems identified using a root or apparent cause methodologies were resolved in accordance with program and NRC requirements. The inspection team concluded that corrective actions were generally completed in an appropriate time frame.Observations480 Volt Molded Case Circuit Breakers (MCCBs)
The inspection team performed a review of the high failure rate of Westinghouse 480V MCCBs. The number of documented failures was:  outage B2R12 - 44 of 120 tested (37 percent), outage B1R14 - 63 of 165 tested (38 percent), and outage B2R13 - 18 of 94 tested (19 percent). The team noted that based on failure laboratory analysis completed by a licensee contractor, all identified failures were attributed to breaker bar twisting. The lab also concluded that fixed magnetic breakers have not shown problems with tripping high out-of-tolerance (OOT). While there was much evidence to support breaker bar twisting as the cause of these failures, the inspection team also noted there was evidence of age-related degradation, such as dried and separated grease, that appeared to be dismissed by the licensee.Also during the inspection team's review of the MCCB failures, as documented in thelicensee's corrective action program, the team noted that the licensee's practice was not to consider all problems as failures. For example, the licensee did not consider individual phases with as-found OOT or breakers that did not reset following testing as failures. The inspection team found at least one example in the licensee's corrective action program (IR 446538) of MCCBs that did not reset following testing, and three cases with individual phases with as-found OOT. The inspection team ascertained that the three cases of OOT phase settings were analyzed by the licensee's contractor, which determined that the failures were due to hardened grease.


6The inspection team compared the licensee's testing, and preventive maintenanceto Westinghouse Bulletins 04-13 (Replacement Solutions for Obsolete Classic Molded Case Circuit Breakers, UL Testing Issues, Breaker Design Life and Trip Band Adjustment) and 06-2 (Aging Issues and Subsequent Operating Issues for Breakers That are at Their 20 Year Design/Qualified Lives; UL Certification/Testing Issues Update) as well as Information Notice 93-64 (PERIODIC TESTING AND PREVENTATIVE MAINTENANCE OF MOLDED CASE CIRCUIT BREAKERS).
The inspection team compared the licensees testing, and preventive maintenance to Westinghouse Bulletins 04-13 (Replacement Solutions for Obsolete Classic Molded Case Circuit Breakers, UL Testing Issues, Breaker Design Life and Trip Band Adjustment) and 06-2 (Aging Issues and Subsequent Operating Issues for Breakers That are at Their 20 Year Design/Qualified Lives; UL Certification/Testing Issues Update) as well as Information Notice 93-64 (PERIODIC TESTING AND PREVENTATIVE MAINTENANCE OF MOLDED CASE CIRCUIT BREAKERS).


Both the Westinghouse Bulletins and the Information Notice described the aspects of age-related degradation, including dried and separated grease. Additionally, the OE recommended periodic cycling of the MCCBs, and/or breaker replacement after 20 years in mild environment applications. Most of the 480 Volt MCCBs have been in service for greater than twenty years, and some have shown indications of age-related degradation. Although the licensee had evaluated the OE, they determined not to implement the recommendations. Based on the questions from the inspection team, the licensee is reevaluating the MCCB preventive maintenance activities and frequency.
Both the Westinghouse Bulletins and the Information Notice described the aspects of age-related degradation, including dried and separated grease. Additionally, the OE recommended periodic cycling of the MCCBs, and/or breaker replacement after 20 years in mild environment applications. Most of the 480 Volt MCCBs have been in service for greater than twenty years, and some have shown indications of age-related degradation. Although the licensee had evaluated the OE, they determined not to implement the recommendations. Based on the questions from the inspection team, the licensee is reevaluating the MCCB preventive maintenance activities and frequency.


The licensee's decision not to implement the OE recommendations is not a violation of NRC requirements. Furthermore, the team assessed the MCCB failures as captured in the licensee's corrective action program, and there were no incidences severe enough to be considered a significant condition adverse to quality, therefore no violations of NRC requirements occurred.
The licensees decision not to implement the OE recommendations is not a violation of NRC requirements. Furthermore, the team assessed the MCCB failures as captured in the licensees corrective action program, and there were no incidences severe enough to be considered a significant condition adverse to quality, therefore no violations of NRC requirements occurred.


b.Assessment of the Use of Operating Experience (OE)(1)Inspection ScopeThe team reviewed the licensee's implementation of the station operating experienceprogram. Specifically, the team reviewed implementation of operating experience program procedures, attended CA program meetings to observe the use of OE information, completed evaluations of OE issues and events, and selected 2006 and 2007 monthly assessments of the OE composite performance indicators. The purpose of the team's review was to determine whether the licensee was effectively integrating OE experience in the performance of daily activities. Specifically that OE was used in the evaluation of issues, departmental assessments, Nuclear Oversight (NOS) audits,and the use of OE was effective in preventing repeats of previous industry events. The team also assessed if corrective actions, as a result of OE experience, were identified and effectively and timely implemented. (2)AssessmentThe team did not identify any findings of significance in this area. In general, with theexception of the MCCB issue described above, OE information was being well utilized at the station. The team observed that Exelon fleet internal OE and industry OE were discussed by licensee staff to support review activities and CAP investigations.
b. Assessment of the Use of Operating Experience (OE)
: (1) Inspection Scope The team reviewed the licensees implementation of the station operating experience program. Specifically, the team reviewed implementation of operating experience program procedures, attended CA program meetings to observe the use of OE information, completed evaluations of OE issues and events, and selected 2006 and 2007 monthly assessments of the OE composite performance indicators. The purpose of the teams review was to determine whether the licensee was effectively integrating OE experience in the performance of daily activities. Specifically that OE was used in the evaluation of issues, departmental assessments, Nuclear Oversight (NOS) audits, and the use of OE was effective in preventing repeats of previous industry events. The team also assessed if corrective actions, as a result of OE experience, were identified and effectively and timely implemented.
: (2) Assessment The team did not identify any findings of significance in this area. In general, with the exception of the MCCB issue described above, OE information was being well utilized at the station. The team observed that Exelon fleet internal OE and industry OE were discussed by licensee staff to support review activities and CAP investigations.


During licensee staff interviews, the team identified that the use of OE was being considered during daily activities.
During licensee staff interviews, the team identified that the use of OE was being considered during daily activities.


7 c.Assessment of Self-Assessments and Audits(1)Inspection ScopeThe team reviewed selected focused area self-assessments (FASA), check-inself-assessments, and Nuclear Oversight audits of the corrective action program, technical human performance, engineering design control and programs, maintenance, operations and system performance monitoring. The team evaluated whether these audits and self-assessments were being effectively managed, were adequately covering the subject areas, and were properly capturing identified issues in the CAP. In addition, the team also interviewed licensee staff regarding the implementation of the audit and self-assessment programs.(2)AssessmentNo findings of significance were identified.
c. Assessment of Self-Assessments and Audits
: (1) Inspection Scope The team reviewed selected focused area self-assessments (FASA), check-in self-assessments, and Nuclear Oversight audits of the corrective action program, technical human performance, engineering design control and programs, maintenance, operations and system performance monitoring. The team evaluated whether these audits and self-assessments were being effectively managed, were adequately covering the subject areas, and were properly capturing identified issues in the CAP. In addition, the team also interviewed licensee staff regarding the implementation of the audit and self-assessment programs.
: (2) Assessment No findings of significance were identified.
 
The team concluded that the licensees departmental assessments and nuclear oversight audits were effective at identifying plant deficiencies and enhancement opportunities at an appropriate threshold level. Assessments and audits were thorough and probing. The auditing and assessing teams were comprised of personnel with appropriate knowledge, skills, and abilities, which resulted in the identification of plant deficiencies, plant improvement recommendations, and plant strengths. Assessments and audits properly characterized issues, and identified issues were subsequently placed into the CAP. In addition, the team concluded that 2007 PI&R FASA was a very good effort that resulted in a quality product.
 
d. Assessment of Safety Conscious Work Environment
: (1) Inspection Scope The team interviewed selected members of the licensees staff to determine if there were any impediments to the establishment of a safety conscious work environment.
 
In addition, the team discussed the implementation of the Employee Concerns Program (ECP) with the ECP Coordinators, and reviewed their 2006/2007 activities to identify any emergent issues or potential trends. Licensee programs to publicize the CAP and ECP programs were also reviewed.
: (2) Assessment No findings of significance were identified.
 
The staff was aware of, and generally familiar with the CAP and other station processes, including the ECP, through which concerns could be raised. Staff interviews identified that issues could be freely communicated to supervision, and that several of the individuals interviewed had previously initiated IRs. In addition, a review of the types of issues in the ECP indicated that site personnel were appropriately using the corrective action and employee concerns programs to identify issues. The team interviewed the ECP Coordinators and concluded that they were focused on ensuring all site individuals were aware of the program, comprehensive in their review of individual concerns, and used the corrective action and employee concerns programs to appropriately resolve issues.


The team concluded that the licensee's departmental assessments and nuclearoversight audits were effective at identifying plant deficiencies and enhancement opportunities at an appropriate threshold level. Assessments and audits were thorough and probing. The auditing and assessing teams were comprised of personnel with appropriate knowledge, skills, and abilities, which resulted in the identification of plant deficiencies, plant improvement recommendations, and plant strengths. Assessments and audits properly characterized issues, and identified issues were subsequently placed into the CAP. In addition, the team concluded that 2007 PI&R FASA was a very good effort that resulted in a quality product.
{{a|4OA6}}
==4OA6 Meetings==


d.Assessment of Safety Conscious Work Environment(1)Inspection ScopeThe team interviewed selected members of the licensee's staff to determine if therewere any impediments to the establishment of a safety conscious work environment.
===.1 Exit Meeting===


In addition, the team discussed the implementation of the Employee Concerns Program (ECP) with the ECP Coordinators, and reviewed their 2006/2007 activities to identify any emergent issues or potential trends. Licensee programs to publicize the CAP and ECP programs were also reviewed.(2)AssessmentNo findings of significance were identified.
The team presented the inspection results to Ms. M. Snow and other members of licensee management at the conclusion of the inspection on August 3, 2007. The team asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.


The staff was aware of, and generally familiar with the CAP and other station processes,including the ECP, through which concerns could be raised. Staff interviews identified that issues could be freely communicated to supervision, and that several of the individuals interviewed had previously initiated IRs. In addition, a review of the types of issues in the ECP indicated that site personnel were appropriately using the corrective action and employee concerns programs to identify issues. The team interviewed the ECP Coordinators and concluded that they were focused on ensuring all site individuals 8were aware of the program, comprehensive in their review of individual concerns, andused the corrective action and employee concerns programs to appropriately resolve
{{a|4OA7}}
==4OA7 Licensee-Identified Violations==


issues.4OA6Meetings
No findings of significance were identified.


===.1 Exit MeetingThe team presented the inspection results to Ms. M. Snow and other members oflicensee management at the conclusion of the inspection on August 3, 2007.===
ATTACHMENT:  
The team asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.4OA7Licensee-Identified ViolationsNo findings of significance were identified.ATTACHMENT:


=SUPPLEMENTAL INFORMATION=
=SUPPLEMENTAL INFORMATION=
Line 113: Line 153:
: [[contact::W. Kouba]], Nuclear Oversight Manager
: [[contact::W. Kouba]], Nuclear Oversight Manager
: [[contact::J. Langon]], Regulatory Assurance
: [[contact::J. Langon]], Regulatory Assurance
: [[contact::S. Swanson]], Maintenance DirectorNuclear Regulatory Commission
: [[contact::S. Swanson]], Maintenance Director
Nuclear Regulatory Commission
: [[contact::R. Skokowski]], Chief, Reactor Projects Branch 3
: [[contact::R. Skokowski]], Chief, Reactor Projects Branch 3
2ITEMS OPENED AND CLOSEDOpened NoneOpened and Closed
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ITEMS OPENED AND CLOSED
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Opened and Closed
None
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None
Discussed
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3
==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==
ISSUE REPORTS GENERATED DUE TO THE INSPECTIONIR
 
: 656295; NRC Senior Resident Identified Debris in FME Zone 1 Around SFP; August 1, 2007IR
: 656855; Oil Usage Log Used Inconsistently; August 3, 2007
: IR 657030; Aggregate Review of Fire Protection Issues is Warranted; August 3, 2007
: IR 657070; Further Evaluation Needed for Molded Case Circuit Breakers; August 3, 2007
: IR 657546; Potential FME Concerns Spent Fuel Pool Area; August 6, 2007ISSUE REPORTS REVIEWED DURING INSPECTIONIR
: 374050; Security Fence Down; September 16, 2005IR
: 349478; Operations First Quarter CAP Trending - Outage Related Events; July 1, 2005
: IR 370681; NOS ID'd Root Cause Corrective Actions Deficiencies; September 6, 2005
: IR 373962; Potential Adverse Trend in Unplanned Non-Shutdown LCO Entries;
: September 15, 2005
: IR 375009; Fuel Oil Storage Tanks Cleaning Process; September 19, 2005
: IR 379616; Safety and Radiation Practices; September 9, 2005
: IR 387581; Unit 2 Reactor Trip On Loss Of CD/CB PP 2A; October 19, 2005
: IR 383201; No Fall Protection; October 7, 2005
: IR 383326; Below Standard Crane Observation; October 7, 2005
: IR 383706; Production over Safety; October 9, 2005
: IR 384780; Liquid Nitrogen Cylinders Not Secured, October 11, 2005
: IR 430826; 2A D/G Exhaust Screens Dirty; December 16, 2005
: IR 445208; U1 Pressurizer Sample Point Isolation Failure; January 23, 2006
: IR 446973; Un-insulated Battery Terminal Leads; January 28, 2006
: IR 458698; Safety Issue for the 2B SI Pump Room; February 25, 2006
: IR 463574; 2006 NRC Mod And 50.59 Inspection-Ops Rounds Not Updated; March 8, 2006
: IR 465905; Ladder Safety Posts; March 13, 2006
: IR 465952; Auxiliary Building Safety Concern, March 13, 2006
: IR 469894; Abandonment Of RSH FP Header And Hose Stations; March 23, 2006
: IR 472530; Check in Assessment of Clearance and Tagging; December 29, 2006
: IR 477497; RWST Level Operability Impacted by Transmitter Calibration; April 11, 2006
: IR 478456; Fire Dampers Not Installed in Fire Rated Barriers; April 13, 2006
: IR 497784; UCSR Confined Space; June 7, 2006
: IR 498672; 2CS019B Valve Stroke Not Performed due to Safety; June 10, 2006
: IR 507048; D/G Door Posting not Obeyed; July 7, 2006
: IR 509274; 10CFR Part 21 For ESF Batteries; July 14, 2006
: IR 524692; Cover for Light Fixture in Battery Room 211 broke; August 28, 2006
: IR 525011; Focused Area Self Assessment of Reactivity Management; December 20, 2006
: IR 527105; Potential Ignition Sources in the ESF Battery Rooms; September 4, 2006
: IR 529577; Refueling Machine Hazards; September 11, 2006
: IR 531453; Cable Tray Energized; September 15, 2006
: IR 534573; Good Catch; September 22, 2006
: IR 535213; ED Reset; September 19, 2006
: IR 536001; ED Reset; September 25, 2006
: IR 549324; Found Battery Room Door Unlocked; October 26, 2006
: IR 551404; Engineering - Potential Trend - Human Error Prevention; October 31, 2006
: 4IR
: 556440;
: CDBI-Problems With Calculation BYR2000-062/BRW-00-0111-E;
: November 10, 2006
: IR 560234; Focused Area Self Assessment of B2R13 Outage Readiness; January 31, 2007
: IR 562375; CDBI Calculation BYR04-016 Assumptions; November 22, 2006
: IR 569941; NOS ID'd Corrective Action Assignments Not Properly Closed; December 15, 2006
: IR 571955; Headache from D/G Exhaust; December 21, 2006
: IR 577680; Pressure Gage on Halon Bottle Reading Low; January 11, 2007
: IR 578710; Backlog of IR Closure Reviews and Trending; January 12, 2007
: IR 580189; Halon Bottle Pressure Low, Out of Specification; January 18, 2007
: IR 580456; Fear and Distraction - Submitted Anonymously; January 18, 2007
: IR 594142; Actions from NSRB Meeting Minutes from January 9 - 10, 2007; January 9, 2007
: IR 594524; Acid Leak; February 22, 2007
: IR 601107; NOS ID'd Corrective Action Program Processes Not Rigorous; March 8, 2007
: IR 613708; Containment Isolation Valve 2-CC-9518 Failed Leak Rate Test; April 5, 2007
: IR 615351; Minor Injury to Mechanic; April 10, 2007
: IR 617200; Fixed Ladder with Structural Defects; April 14, 2007
: IR 624042; Compressed Gas Cylinders Not Stored Properly; May 1, 2007
: IR 644020; PI&R Focus Area Self-Assessment Deficiency; June 25, 2007
: IR 649815; New PORV Controller Lessons Learned; July 12, 2007
: IR 649853; Pump is Turning the Wrong Way after Controller Modification; July 12, 2007
: IR 653305; 1D Steam Generator PORV Work Window Exceeded Estimate by more than plus or minus 10 percent; July 17, 2007
: IR 653669; NOS ID'd 2Q07 Yellow (Chronic) Rating for RP Department; July 25, 2007
: IR 654619; CAP Evaluations Overdue; July 27, 2007
: IR 655144; Maintenance Rule Action Conflicts with Regulatory Guide 1.160; July 30, 2007
: IR 655683; Inappropriate Closure of Incorrect ACITS; July 30, 2007Fire Protection IssuesIR
: 148945; Small Hole in AEER Wall Leads to LCOAR Entry; March 13, 2003IR
: 148903; Fire Seals in Unit 1 Aux Electrical Equipment Room; March 13, 2003
: IR 210467; Degraded Fire Hose; March 24, 2004
: IR 227598; NOS ID'd Adverse Trend Fire Protection Program Deficiencies; June 10, 2004
: IR 228104; Fire Truck Missing Two 5 inch Quick Lock Adapters as Found by Surveillance;
: June 13, 2004
: IR 276473; Conduit in 1A D/G Room; November 17, 2004
: IR 277138; Firehose Issues While Staging for Clearance Order; November 28, 2004
: IR 320569; Components on Fire Truck Inventory Missing; April 3, 2005
: IR 325192; Degraded Hoses on Foam Machines; April 15, 2005
: IR 336345; New Fire Seals not Being Added to Fire Seal Inspections; May 18, 2005
: IR 429839; FP Hose Station Found Without Nozzle; December 2, 2005
: IR 432581; 0BOSR
: FP-Q1 Fails to Meet Acceptance Criteria; December 10, 2005
: IR 465154; Fire Truck Missing Gated Wye; March 12, 2006
: IR 477513; Extent of Condition on Fire Piping; April 2006
: IR 504408; Fire Truck Hose Issues; June 28, 2006
: IR 504946; Fire Hose Testing Procedures Need Updating; June 29, 2006
: IR 506972; Work Order Identified Two Hoses Requiring Replacement; July 3, 2006
: IR 509629; Valve 0FP475 Could Not Be Flushed; July 13, 2006
: IR 509738; Unplanned LCOAR Entry on Hose Station 250; July 15, 2006
: IR 516253; Potential Document Issues with Fire Hoses; August 2, 2006
: 5IR
: 520780; Lessons Learned Fire Protection Foam System Maintenance; August 16, 2006IR
: 542454; Fire Protection Report Discrepancies; October 10, 2006
: IR 593370; Fire Proofing Removed without PBI Initiated; February 19, 2007
: IR 594075; Perform Common Cause Analysis on Piping Leaks in the Fire Protection System;
: February 21, 2007
: IR 598079; Fire Proofing Issue Identified; March 1, 2007
: IR 601728; Fireproof Thermafiber Insulation Impairment; March 9, 2007
: IR 601978; Steel Beam Missing Fire Protection Board; March 10, 2007
: IR 602010; Fire Truck Needs More Hose; March 10, 2007
: IR 602838; Steel Beam Missing Fire Protection Board Unit 2 Area 7; March 12, 2007
: IR 622255; Fire Barrier Walkdown; April 26, 2007
: IR 625999; Oil Storage Tank Room Fire Damper Dropped; May 6, 2007
: IR 630782; NRC Steel Beam Fireproofing Questions; May 17, 2007
: IR 638778; Fire Truck Inventory Comes Up Short; June 9, 2007
: IR 650463; Fire Pre-Plan Discrepancies Identified; July 16, 2007
: IR 652278; NRC Inspectors Identified that
: IR 577680 Lacked a Basis for Operability;
: July 20, 2007
: IR 654830; Full Scope of Fire Seal Repair Not Identified; July 28, 2007
: IR 655346; No CERA Blanket Found in Fire Seal; July 16, 2007
: IR 655788; BOL Needs Clarification; July 31, 2007
: 0BOSR
: FP-Q5, Revision 7, "Fire Response Truck and Backup Mobile Card Inspection"
: CC-AA-201; Plant Barrier Control Program, Revision 6
: Standing Order 07-035; Guidance for Fire Protection CO2 or Halon Zone Operability, July 30, 2007
: 0BOSR
: FP-Q5, "Fire Response Truck and Backup Mobile Cart Inspection," Revision 7
: NOSA-BYR-07-01; CAP Audit Byron Station; March 9, 2007
: Quick Human Performance Investigation Report
: 649952, "FP Hose Flow Verification not Performed per Surveillance," July 13, 2007
: REFERENCESIR
: 593317, Action Item 3; Results of the Safety Culture Survey Performed August 2006;
: April 3, 2007
: BAP 1100-3A3; "Pre-Evaluated Plant Barrier Matrix," Revision 21
: 594777-04; Self-Assessment for Preparation for NRC Problem Identification and Resolution
: PI&R) Inspection; June 2007
: Meeting Summary Byron Nuclear Safety Review Board July 12 and 13, 2005
: Meeting Summary Byron Nuclear Safety Review Board October 20 and 21, 2005
: Meeting Summary Byron Nuclear Safety Review Board January 23 and 24, 2006
: Meeting Summary Byron Nuclear Safety Review Board May 15 and 16, 2006
: Meeting Summary Byron Nuclear Safety Review Board August 23 and 24, 2006
: Meeting Summary Byron Nuclear Safety Review Board January 9 and 10, 2007
: Meeting Summary Byron Nuclear Safety Review Board May 7 and 8, 2007
: RP-BY-300-1005; RP Guidance for Water Transfers and System Flushing; Revision 0
: RP-BY-1081-2; RP Performance Program; Revision 4
: BAP-1100-3; Plant Impairment Program; Revision 18
: Work Order
: 994874; Halon Bottle Pressure Low, Out of Specification
: NOS CAP Audit
: NOS-BYR-07-01; March 30, 2007; IR 571154
: NOS Audit LCO Work Window Performance; December 2, 2005, IR 278945
: NOS audit LCO Work Window CAP Quality; August 2, 2006,
: IR 442751
: 6ACE and Exelon Corporate White Pater; December 12, 2006,
: IR 523038; ACE for Uncontrolled High Radiation Area,
: NCV 2006-04-03; September 9, 2006, IR 531013
: ACE for Tritium Release to the Environment,
: NCV 2006-04-02; February 14, 2006, IR 478372
: LS-AA-115; Operating Experience; Revision 10
: LS-AA-120; Issue Identification and Screening Process, Revision 7
: LS-AA-125; Corrective Action Program (CAP) Procedure, Revision 11
: LS-AA-125-1001; Root Cause Analysis Manual; Revision 6
: LS-AA-125-1002; Common Cause Analysis Manual; Revision 5
: LS-AA-125-1003; Apparent Cause Evaluation Manual; Revision 7
: LS-AA-125-1004; Effectiveness Review Manual; Revision 2
: LS-AA-125-1005; Coding and Analysis Manual, Revision 5
: LS-AA-126; Self-Assessment Program; Revision 5
: LS-AA-126-1001; Focused Area Self-Assessments; Revision 4
: LS-AA-126-1005; Check-In Self Assessments, Revision 3
: LS-AA-126-1006; Benchmarking Program, Revision 1
: NO-AA-200-002; Nuclear Oversight Regulatory Audit Procedure; Revision 10
: NO-AA-200-002-1001; Exelon Nuclear Audit Handbook; Revision 11
: OP-AA-102-103, Operator Work-Around Program; Revision 1
: EI-AA-1; Employee Issues; Revision 1
: EI-AA-101; Employee Concerns Program; Revision 6
: EI-AA-100-1003; Employee Issues Advisory Committee Notification; Revision 0
: EI-AA-101-1002; Employee Concerns Program Trending Tool; Revision 3
: LS-AA-1006; "NRC Cross-Cutting Analysis and Trending," Revision 1
: RP-AA-203-1002; Response to ED Reset Alarms; Revision 0
: WC-AA-101-1004; On-Line Maintenance for LCO Components; Revision 4
: Executive Review of Exelons Nuclear's Learning Programs, Monthly for July 2005 through June 2007
: Executive Review of Exelons Nuclear's Learning Programs for June 2007FME Reactor Vessel And Spent Fuel PoolIR
: 123845; Loose Paint Chip Fell Into Reactor Vessel-Retrieval Required; September 20, 2002IR
: 177721; Paint Chips Discovered In FME Zone 1; September 26, 2003
: IR 217076; Paint Chips In The Spent Fuel Pool; April 27, 2004
: IR 518222; Foreign Material Found In Spent Fuel Pool; August 9, 2006
: IR 519131; Loose Paint Contributing To SFP FME Issue; August 11, 2006
: IR 611673; B2R13-Paint Chips Noted On Staged Material In Crosstown; April 2, 2007
: IR 613143; FME Challenge, Paint Chips Need Scraped and Vacuumed; April 4, 2007Procedure PlacekeepingIR
: 601900; NOS ID Placekeeping not being performed in work package; March 10, 2007IR
: 603735; NOS ID Placekeeping not being performed in work package; March 14, 2007
: IR 612677; NOS ID Operations' Placekeeping deficiency; April 4, 2007
: IR 617878; NOS ID Poor Placekeeping in ECCS Flow Balance Test; April 16, 2007
: IR 618015; NOS ID Operations' Placekeeping deficiency; April 20, 2007
: IR 620343; NOS ID Cross Cutting Placekeeping Deficiencies in B2R13; April 22, 2007
: IR 624419; NOS ID Simulator Training Session without Set Placekeeping; May 1, 2007
: HU-AA-104-101; Procedure Use and Adherence NOS Site Status Report July 17, 2007
: Operations Policy 700-14
: 7480 Volt Molded Case Circuit BreakersIR
: 124871; Molded Case Circuit Breakers Test Out of Tolerance; September 27, 2002IR
: 211383; Molded Case Circuit Breakers Test Out of Tolerance; March 28, 2004
: IR 211384; Molded Case Circuit Breakers Test Out of Tolerance; March 28, 2004
: IR 211386; Molded Case Circuit Breakers Test Out of Tolerance; March 28, 2004
: IR 211390; Molded Case Circuit Breakers Test Out of Tolerance; March 28, 2004
: IR 311885; Molded Case Circuit Breakers Test Out of Tolerance; March 12, 2005
: IR 380420; Molded Case Circuit Breakers Test Out of Tolerance; September 30, 2005
: IR 380467; Molded Case Circuit Breakers Test Out of Tolerance; September 30, 2005
: IR 381472; MCCB Testing Repair Plan Incomplete; October 3, 2005
: IR 441548; Feed Breakers for Pressurizer Heaters Failed Surveillance; January 12, 2006
: IR 449192; Heat Degradation; February 2, 2006
: IR 477913; AP6 Maintenance Rule Unacceptable Trend; April 12, 2006
: IR 483813; MCCB Testing Failures; April 27, 2006
: IR 531766; Breaker Tripped Out of Tolerance High; September 15, 2006
: IR 531898; Out of Tolerance HFB Breaker 132X1 1AP23E; September 16, 2006
: IR 531909; Out of Tolerance HFB Breaker 132X1 1AP23E D4; September 16, 2006
: IR 532016; Molded Case Breaker 1AP92E-A4 Failed to Trip; September 16, 2006
: IR 532974; Aggregate Impact of Breaker Testing Failures; September 19, 2006
: IR 534855; B1R14 LL Molded Case Circuit Breaker (MCCB) Testing; September 22, 2006
: IR 560339; Breaker Failure Due to Lack of Lubrication; November 20, 2006
: IR 594463; Breaker Did Not Open When Trip Plate Depressed; February 22, 2007
: IR 633252; Breaker 1LL62JA-C Will Not Shut "Off"; May 24, 2007
: MA-AA-723-325 Westinghouse/Cutler-Hammer MCCB Trip Testing; Revision 6
: MA-AA-716-210-1001 Motor Control Centers/MCCBs Maintenance Test Template; Revision 8
: NEMA AB 4-2000; Guidelines for Inspection and Preventive Maintenance of Molded Case Circuit Breakers used in Commercial and Industrial Applications; 1996
: NRC Information Notice 93-64; Periodic Testing and Preventive Maintenance of Molded Case Circuit Breakers; August 12, 1993
: NRC Information Notice 92-51 Supplement 1; Misapplication and Inadequate Testing of Molded Case Circuit Breakers; April 11, 1994
: Westinghouse Technical Bulletin
: TB-04-13; Molded Case Circuit Breakers Westinghouse Technical Bulletin
: TB-06-2; Molded Case Circuit Breakers
: OPEX SME Review of Westinghouse TB-04-13
: OPEX SME Review of Westinghouse TB-06-2
: Power Labs Failure Analysis Project Number BYR-13720
: Power Labs Failure Analysis Project Number BYR-20989
: Power Labs Failure Analysis Project Number BYR-20990
: Power Labs Failure Analysis Project Number BYR-20991
: Power Labs Special Testing Project Number BYR-21599
: Power Labs Failure Analysis Project Number BYR-95259
: Power Labs Tech Services Work Request Project
: BYR-47998, WR #2241
: Power Labs Tech Services Work Request Project
: BYR-48218, WR #2252
: Byron Quarterly Ship System Report, Auxiliary Power LV1 120/208V
: Engineering Change 0000362663
: AT 532974-03
: 8SiltingIR
: 362882; Mud In WS Lines And Various Coolers On 2AS02PA/B; August 11, 2005IR
: 381523; 2B AF Diesel Cubicle Cooler Drain Pan Mud Caked; October 3, 2005
: IR 397453; No Flow to Upper Motor Cooler, Line Is Plugged; November 10, 2005
: IR 462587; 1C CW Pump Bowl Full Of Mud; March 6, 2006
: IR 469078; CW Blowdown Air Release Valves Found Plugged With Mud; March 21, 2006
: IR 469915; Line Plugged With Silt/Debris; March 23, 2006
: IR 471384; SX Blowdown Valve Apparently Plugged With Silt; March 27, 2006
: IR 607620; Piping Appears To Be Plugged; March 22, 2007
: IR 633689; VI Chiller:
: Pressure Indicator Piping Plugged; May 25, 2007
: IR 647995; OC WS Pump (Non-Running) Motor Cooling Flow Plugged; July 7, 2007Miscellaneous Operations IssuesIR
: 532290; Possible Operator Workaround Concerning CW Blowdown; September 17, 200IR
: 535346; 1HD046B Work Prior to Additional CO Isolation; September 24, 2006
: IR 542407; Extent of Condition Review From
: IR 538328; October 11, 2006
: IR 610812; Extent of Condition in CAP Investigations Needs Improvement; March 30, 2007
: IR 610826; NOS ID CAP Corrective Action Effectiveness Attribute DNME; March 30, 2007
: IR 622229; NOS ID Procedure Implementation Not Completed at Byron; April 26, 2007
: IR 629150; Valve Identified Out of Position; May 7, 2007
: IR 629361; MRC Directed Review of Steam Leaks Following B2R13; May 14, 2007
: IR 630883; NOS ID Trend in OPS Narrative Logkeeping; May 17, 2007
: Standing Order 07-039; Oil Addition Log Documentation; August 7, 2007MiscellaneousByron SOC Agenda for Tuesday, July 17, 2007Byron MRC Agenda for Wednesday, July 18, 2007
: Byron SOC Agenda for Thursday, July 19, 2007
: OE18517; Siemens Personal ED Resets; June 4, 2004
: 9
==LIST OF ACRONYMS==
USEDADAMSAgency-Wide Document Access and Management SystemCACorrective Action
CAPCorrective Action Program
CFRCode of Federal Regulation
ECPEmployee Concern Program
FASAFocused Area Self Assessment
DRPDivision of Reactor Projects
EOCExtent of Condition
IMCInspection Manual Chapter
IRIssue Report
MRCManagement Review Committee
MCCBMolded Case Circuit Breaker
NCVNon-Cited Violation
NOSNuclear Oversight
NRCUnited States Nuclear Regulatory Commission
OEOperating Experience
OOTOut of Tolerance
PI&RProblem Identification and Resolution
RCARoot Cause Analysis
SDPSignificance Determination Process
: [[SOCS]] [[tation Ownership Committee]]
}}
}}

Latest revision as of 02:39, 23 November 2019

IR 05000454-07-006 and 05000455-07-006, on 07/16/2007-08/03/2007; Byron Station, Units 1 and 2; Identification and Resolution of Problems
ML072570387
Person / Time
Site: Byron  Constellation icon.png
Issue date: 09/14/2007
From: Richard Skokowski
NRC/RGN-III/DRP/RPB3
To: Crane C
Exelon Generation Co, Exelon Nuclear
References
FOIA/PA-2010-0209 IR-07-006
Download: ML072570387 (21)
v • d • e


Text

ber 14, 2007

SUBJECT:

BYRON STATION, UNITS 1 AND 2 NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000454/2007006 AND 05000455/2007006

Dear Mr. Crane:

On August 3, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed a team inspection of problem identification and resolution at your Byron Station, Units 1 and 2.

The enclosed inspection report documents the inspection findings which were discussed on August 3, 2007, with Ms. Snow and other members of your staff.

This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, compliance with the Commissions rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved selected examination of procedures and representative records, observations of activities, and interviews with personnel.

There were no findings of significance identified during this inspection. On the basis of the sample selected for review, the inspection team concluded that Byron was generally effective in the identification, evaluation, and resolution of problems.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA Mark A. Ring for/

Richard A. Skokowski, Chief Branch 3 Division of Reactor Projects Docket Nos. 50-454; 50-455 License Nos. NPF-37; NPF-66 Enclosure: Inspection Report No. 05000454/2007006 and 05000455/2007006 w/Attachment: Supplemental Information cc w/encl: Site Vice President - Byron Station Plant Manager - Byron Station Regulatory Assurance Manager - Byron Station Chief Operating Officer Senior Vice President - Nuclear Services Vice President - Operations Support Vice President - Licensing and Regulatory Affairs Director Licensing Manager Licensing - Braidwood and Byron Senior Counsel, Nuclear Document Control Desk - Licensing Assistant Attorney General Illinois Emergency Management Agency State Liaison Officer, State of Illinois State Liaison Officer, State of Wisconsin Chairman, Illinois Commerce Commission B. Quigley, Byron Station

SUMMARY OF FINDINGS

IR 05000454/2007006; 05000455/2007006; 07/16/2007-08/03/2007; Byron Station, Units 1 and 2; Identification and Resolution of Problems.

The inspection was conducted by a Senior Resident Inspector, two regional specialists, and an Illinois Emergency Management Agency inspector. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609,

Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated July 2006.

Identification and Resolution of Problems Overall, the inspection team determined that the Corrective Action Program (CAP) was effective in the identification, evaluation, and resolution of problems. The inspection team determined that the licensee typically identified problems and placed them in the CAP. The inspection team identified that operating experience was utilized and considered. The inspection team noted that the licensee was effective in conducting root cause and apparent cause evaluations and effectively resolved most problems categorized as more significant. Based on interviews, observations of plant activities, reviews of the CAP and the Employees Concerns Program, the inspection team determined that site personnel were willing to raise safety issues.

NRC-Identified and Self-Revealing Findings

None.

Licensee-Identified Violations

None.

REPORT DETAILS

4OA2 Problem Identification and Resolution (PI&R)

Main article: IP 71152B

a.

Assessment of the Corrective Action (CA) program

(1) Inspection Scope The inspection team reviewed the procedures describing the licensees Corrective Action Program (CAP). The licensee identified problems for evaluation and resolution by initiating issue reports (IRs) that were entered into the condition reporting system.

The IRs were subsequently screened for operability, categorized by significance, and assigned for further evaluation and resolution.

The inspection team evaluated the methods for assigning and tracking issues to ensure that issues were screened for operability and reportability, prioritized for evaluation and resolution in a timely manner commensurate with their safety significance, and tracked to identify adverse trends and repetitive issues. In addition, the inspection team interviewed plant staff and management to determine the staffs understanding of, and involvement with the CAP.

The inspection team reviewed IRs to assess whether the licensee adequately evaluated and prioritized identified problems. The issues reviewed encompassed the full range of evaluations, including root cause analyses, apparent cause evaluations, and common cause analyses. Samples of IRs that were assigned lower levels of significance were also reviewed by the inspection team to ensure they were appropriately classified. The review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. For significant conditions adverse to quality, the inspection team reviewed the licensees corrective actions to preclude recurrence. The inspection team observed selected daily Station Ownership Committee (SOC) IR screening meetings, in which station personnel reviewed new IRs for prioritization and assignment. The inspection team also reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected items.

The inspection team reviewed the corrective actions associated with selected IRs to determine whether the actions addressed the identified causes of the problems. The inspection team reviewed IRs for repetitive problems to determine whether previous corrective actions were effective. The inspection team also reviewed station timeliness in implementing corrective actions and their effectiveness in precluding recurrence for significant conditions adverse to quality. The inspection team reviewed corrective actions associated with selected non-cited violations (NCVs) and findings to determine whether the station properly evaluated and resolved these issues.

This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152.

(2) Assessment No findings of significance were identified.

.1 Identification of Issues

The team concluded, in general, that the station identified issues and entered them into the CAP at the appropriate level. The teams review of operating experience reports identified that the licensee was appropriately including the issues into the CAP. The licensee also used the CAP to document instances where previous corrective actions were ineffective or were inappropriately closed. The inspection team noted that relatively few deficiencies were identified by external organizations (including the NRC)that had not been previously identified by licensee personnel.

The team selected three high risk systems, which included the non-essential service water, condensate system, and the 120 volt direct current electrical distribution system to review in detail. The teams review was to determine whether the licensee was properly monitoring and evaluating the performance of these systems through effective implementation of station monitoring programs. The team interviewed the system engineer of the applicable system, non-license operators, and performed partial system walk-downs of the systems. A five year review of the 480 volt Molded Case Circuit Breaker (MCCB) and fire protection issues was also undertaken to assess the licensees efforts in monitoring for system degradation due to aging aspects.

.2 Prioritization and Evaluation of Issues

The team concluded that the licensee had properly prioritized issues based on their safety significance, and that issues were generally well evaluated. The team did not identify any issue reports that were not properly prioritized. In addition, the team observed several SOC and management review board committee (MRC) meetings, and concluded that both committees generally ensured the proper prioritization and appropriate investigation assignments for plant issues. Examples of SOC actions taken were to assign work requests, evaluations, and/or corrective action to specific departmental groups. The team observed the MRC function in an oversight role of the SOC. For example, the MRC changed the SOC recommended action of some issues based on committee dialogue and additional station awareness of the issue. The MRC performed grading of investigative CAP products to provide feedback on product quality to the sponsoring manager. The team concluded that issues were properly prioritized and generally well evaluated.

However, the team questioned the licensee regarding two IRs that had been through either the SOC or the SOC and MRC and warranted additional evaluation of prompt operability. In both cases observed, additional data gathering and assessments by the team determined that no actual operability concern existed. These IRs represented near misses in that there was information in the IRs that should have called into question the operability of plant equipment but the review committees failed to recognize.

Observations Fire Protection There were a large number of issues being identified by licensee and NRC personnel in the area of fire protection. These issues dealt with hardware issues, surveillance issues, documentation, and corrective action. Many of these issues were NRC identified. Examples included: missing beam fire protection (three examples), failure to test remote shutdown panel switches, problems with the pre-fire plan and the fire protection report, fire dampers not installed, and CO2 operability with open doors. In addition, a large number of issues have been identified by licensee personnel, many of these issues have been legacy or long standing issues. The team observed significant effort to address the individual issues and observed significant effort addressing four groups of hardware issues by the Plant Health Committee; but there appeared to be little effort to perform an overall assessment of the fire protection related issues.

.3 Effectiveness of Corrective Action

The inspection team concluded that the licensee was generally effective in the resolution of problems and implementation of corrective actions. The problems identified using a root or apparent cause methodologies were resolved in accordance with program and NRC requirements. The inspection team concluded that corrective actions were generally completed in an appropriate time frame.

Observations 480 Volt Molded Case Circuit Breakers (MCCBs)

The inspection team performed a review of the high failure rate of Westinghouse 480 V MCCBs. The number of documented failures was: outage B2R12 - 44 of 120 tested (37 percent), outage B1R14 - 63 of 165 tested (38 percent), and outage B2R13 - 18 of 94 tested (19 percent). The team noted that based on failure laboratory analysis completed by a licensee contractor, all identified failures were attributed to breaker bar twisting. The lab also concluded that fixed magnetic breakers have not shown problems with tripping high out-of-tolerance (OOT). While there was much evidence to support breaker bar twisting as the cause of these failures, the inspection team also noted there was evidence of age-related degradation, such as dried and separated grease, that appeared to be dismissed by the licensee.

Also during the inspection teams review of the MCCB failures, as documented in the licensees corrective action program, the team noted that the licensees practice was not to consider all problems as failures. For example, the licensee did not consider individual phases with as-found OOT or breakers that did not reset following testing as failures. The inspection team found at least one example in the licensees corrective action program (IR 446538) of MCCBs that did not reset following testing, and three cases with individual phases with as-found OOT. The inspection team ascertained that the three cases of OOT phase settings were analyzed by the licensees contractor, which determined that the failures were due to hardened grease.

The inspection team compared the licensees testing, and preventive maintenance to Westinghouse Bulletins 04-13 (Replacement Solutions for Obsolete Classic Molded Case Circuit Breakers, UL Testing Issues, Breaker Design Life and Trip Band Adjustment) and 06-2 (Aging Issues and Subsequent Operating Issues for Breakers That are at Their 20 Year Design/Qualified Lives; UL Certification/Testing Issues Update) as well as Information Notice 93-64 (PERIODIC TESTING AND PREVENTATIVE MAINTENANCE OF MOLDED CASE CIRCUIT BREAKERS).

Both the Westinghouse Bulletins and the Information Notice described the aspects of age-related degradation, including dried and separated grease. Additionally, the OE recommended periodic cycling of the MCCBs, and/or breaker replacement after 20 years in mild environment applications. Most of the 480 Volt MCCBs have been in service for greater than twenty years, and some have shown indications of age-related degradation. Although the licensee had evaluated the OE, they determined not to implement the recommendations. Based on the questions from the inspection team, the licensee is reevaluating the MCCB preventive maintenance activities and frequency.

The licensees decision not to implement the OE recommendations is not a violation of NRC requirements. Furthermore, the team assessed the MCCB failures as captured in the licensees corrective action program, and there were no incidences severe enough to be considered a significant condition adverse to quality, therefore no violations of NRC requirements occurred.

b. Assessment of the Use of Operating Experience (OE)

(1) Inspection Scope The team reviewed the licensees implementation of the station operating experience program. Specifically, the team reviewed implementation of operating experience program procedures, attended CA program meetings to observe the use of OE information, completed evaluations of OE issues and events, and selected 2006 and 2007 monthly assessments of the OE composite performance indicators. The purpose of the teams review was to determine whether the licensee was effectively integrating OE experience in the performance of daily activities. Specifically that OE was used in the evaluation of issues, departmental assessments, Nuclear Oversight (NOS) audits, and the use of OE was effective in preventing repeats of previous industry events. The team also assessed if corrective actions, as a result of OE experience, were identified and effectively and timely implemented.
(2) Assessment The team did not identify any findings of significance in this area. In general, with the exception of the MCCB issue described above, OE information was being well utilized at the station. The team observed that Exelon fleet internal OE and industry OE were discussed by licensee staff to support review activities and CAP investigations.

During licensee staff interviews, the team identified that the use of OE was being considered during daily activities.

c. Assessment of Self-Assessments and Audits

(1) Inspection Scope The team reviewed selected focused area self-assessments (FASA), check-in self-assessments, and Nuclear Oversight audits of the corrective action program, technical human performance, engineering design control and programs, maintenance, operations and system performance monitoring. The team evaluated whether these audits and self-assessments were being effectively managed, were adequately covering the subject areas, and were properly capturing identified issues in the CAP. In addition, the team also interviewed licensee staff regarding the implementation of the audit and self-assessment programs.
(2) Assessment No findings of significance were identified.

The team concluded that the licensees departmental assessments and nuclear oversight audits were effective at identifying plant deficiencies and enhancement opportunities at an appropriate threshold level. Assessments and audits were thorough and probing. The auditing and assessing teams were comprised of personnel with appropriate knowledge, skills, and abilities, which resulted in the identification of plant deficiencies, plant improvement recommendations, and plant strengths. Assessments and audits properly characterized issues, and identified issues were subsequently placed into the CAP. In addition, the team concluded that 2007 PI&R FASA was a very good effort that resulted in a quality product.

d. Assessment of Safety Conscious Work Environment

(1) Inspection Scope The team interviewed selected members of the licensees staff to determine if there were any impediments to the establishment of a safety conscious work environment.

In addition, the team discussed the implementation of the Employee Concerns Program (ECP) with the ECP Coordinators, and reviewed their 2006/2007 activities to identify any emergent issues or potential trends. Licensee programs to publicize the CAP and ECP programs were also reviewed.

(2) Assessment No findings of significance were identified.

The staff was aware of, and generally familiar with the CAP and other station processes, including the ECP, through which concerns could be raised. Staff interviews identified that issues could be freely communicated to supervision, and that several of the individuals interviewed had previously initiated IRs. In addition, a review of the types of issues in the ECP indicated that site personnel were appropriately using the corrective action and employee concerns programs to identify issues. The team interviewed the ECP Coordinators and concluded that they were focused on ensuring all site individuals were aware of the program, comprehensive in their review of individual concerns, and used the corrective action and employee concerns programs to appropriately resolve issues.

4OA6 Meetings

.1 Exit Meeting

The team presented the inspection results to Ms. M. Snow and other members of licensee management at the conclusion of the inspection on August 3, 2007. The team asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

4OA7 Licensee-Identified Violations

No findings of significance were identified.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

M. Snow, Plant Manager
R. Chalifoux, Corrective Action Program Coordinator
S. Fruin, Acting Operations Director
C. Gayheart, Work Control Manager
A. Giancatarino, Engineering Director
W. Grundmann, Regulatory Assurance Manager
S. Kerr, Chemistry Manager
W. Kouba, Nuclear Oversight Manager
J. Langon, Regulatory Assurance
S. Swanson, Maintenance Director

Nuclear Regulatory Commission

R. Skokowski, Chief, Reactor Projects Branch 3

Attachment

ITEMS OPENED AND CLOSED

Opened

None

Opened and Closed

None

Closed

None

Discussed

None

Attachment

LIST OF DOCUMENTS REVIEWED

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