IR 05000454/2007006

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
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)

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)

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