IR 05000454/1997024: Difference between revisions

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{{Adams
{{Adams
| number = ML20202B993
| number = ML20248L529
| issue date = 02/03/1998
| issue date = 03/16/1998
| title = Insp Repts 50-454/97-24 & 50-455/97-24 on 971202-980112. Violations Noted.Major Areas Inspected:Operations Maint/Surveillance Engineering & Plant Support
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-454/97-24 & 50-455/97-24.Actions Will Be Examined During Future Insp
| author name =  
| author name = Jordan M
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
| addressee name =  
| addressee name = Kingsley O
| addressee affiliation =  
| addressee affiliation = COMMONWEALTH EDISON CO.
| docket = 05000454, 05000455
| docket = 05000454, 05000455
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-454-97-24, 50-455-97-24, NUDOCS 9802120137
| document report number = 50-454-97-24, 50-455-97-24, NUDOCS 9803230158
| package number = ML20202B965
| title reference date = 03-05-1998
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| page count = 16
| page count = 4
}}
}}


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{{#Wiki_filter:. 6" "' 80  UNITED STATES
U. 8. NUCLEAR REGULATORY COMMISSION REGION lll
/ %  NUCLEAR REGULATORY COMMISSION I $  REGION til g a  801 WARRENVILLE ROAD
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Docket Nos:  50-454;50-455 License Nos:  NPF 37; NPF 66    l J
a 8  LISLE, ILLINOIS 60532-4351  i
Report No:  50-454/97024(DRP); $0-455/97024(DRP)
Licensee:  Commonwealth Edison Compar'y


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l %...../  March 16, 1998
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l l Mr. Oliver i President, Nuclear Generation Group l Commonwealth Edison Company l ATTN: Regulatory Services      J Executive Towers West lll      l 1400 Opus Place, Suite 500 Downers Grove,IL 60515 i
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Facility: Byron Generating Station, Units 1 and 2 Location:  4450 N. German Church Road Byron,IL 61010 Dates:  December 2,1997 - January 12,1998 Inspectors:  N. Hilton, Resident inspector J. Adams, Braidwood Station Resident inspector C. Thompson, Illinois Department of Nuclear Safety approved by:  Michael J. Jordan, Chief Reactor Projects Branch 3
SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-454/97024(DRP);
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NO. 50-455/97024(DRP))     1
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EXECUTIVE SUMMARY Byron Generating Station, Unitt 1 and 2 NRC Inspection Report No. 50-454/g7024(DRP), 50 455/g7024(DRP)
This inspection included aspects ..isee operations, maintenance, engineering, and plant support. The report covers a six w. k period of resident inspectio Operations
  * Routine control room operations were conducted safely and conservatively Good annunciator alarm response was observed and the operators were knowledgeable of the states of all the annunciator alarras. Operators were aware of activities that could affect the safe operation of each unit. Good communication between the unit operators and good supervisory oversight by the unit supervisors were also noted (Section 01.1). .
  + The housekeeping for Unit 2 was very good. Unit 2 structures, systems, and components were easily accessible to operators. General area housekeeping was good given the amount of outage activities that were in progress during the inspection perio Equipment was staged app,opriately and carts property secured. The control of outage related material was good except for two failures to control transient combustible material (Section 01.1).
 
* The shutdown risk program and its implementation were excellent, A detailed licensee
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review of the outage schedule was conducted. The licensee deiermined the risk level fo each key safety function based on plant configuration and equipment Lvailability and used safety system functional assessment trees (SSFATs). A core damage frequency (CDF)
was included in the risk profile. The shutdown nsk review board (SRRB) approved all changes to the shutdown risk models. Shutdown risk was communicated to all station personnel. Contingency plans provided additional guidance for operators and existed for most higher risk conditions (Section 08.1).
 
* The Plan of the Day (POD) meeting was an effective communication tool and helped identify key performance measures at the site (Section 08.2).
 
Maintenance / Surveillance
  * Observed maintenance and surveillance activities were conducted well. Maintenance procedures were used and personnel were knowledgeable of the associated activitie Surveillance testing was performed well with prope* authorizations, good procedure adherence, and effective communications and coc.anation (Section M1.1 and M1.2).
 
* Based on procedure usage, supervisory oversight, and adequate protection of Unit 2 systems, the observed Unit i steam generator removal and replacement activities were conducted appropriately (Section M1.3).
 
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* The steam generator replacement crojec- (SGRP) lead civil engineer and civil engineering staff were actively l'.. olved it the oversight of contractor personnel and were knowledgeable of the evolutions il ey obs irved (Section E1.1).
 
* A process for the identification, traceung, and resolution of nonconformances for the SGRP was successfully implemented and appeared to be effective. A potential weakness existed in that operations personnel were not involved in the nonconformance repori review process (Section E7.1).
 
Plant Support
* During the transport of an old steam generator (SG) to the old SG storage facility, a moving radiological area existed. The radiologleal protection (RP) technicians controlled both the number of personnel near the old SG and the distance between nonessential personnel and the old SG. Radiation Protection Supervision also ensured that the transport evolution was properly controlled (Section R1.1).
 
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The inspectors concluded that the methods for controlling the use of a drinking water station in a high radiation / contaminated area on December 24,1997, created a potential problem. Although there had not been any known contamination events attributable to the manner in which the drinking water station was controlled, an individual could potentially be contaminated due to the lack of direct control by RP technicians, the general access to the water station, and the lack of personal survey * The security force properly controlled the fence penetration during the transport of an old SG on December 17,1997. Good access control of personnelleaving and retuming to the protected area through the fence penetration existed. Security supervisicn was present. The protected area penetration was well controlled (Section Si.1).
 
* The increased amount of transient combustibles during the refueling outage was not always aggressively controlled. Two instances of poorly controlled combustibles were identified. A 55-gallon barrel containing oil soaked rags and 13 containers of a flammable liquid were both identified by the inspectors. Two violations of a failure to follow Byron Administrative Procedure (BAP) 1100-9, " Control, Use, and Storage of Flammable and Combustible Liquids and Aerosols," were cited (Section F1.1).


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==Dear Mr. Kingsley:==


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This will acknowledge receipt of your letter dated March 5,1998, in response to our letter dated Februaray 3,1998, transmitting a Notice of Violation associated with inspection Report No. 50-454/97024(DRP); 50-455.97024(DRP). We have reviewed your corrective actions and I
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have no further questions at this time. These corrective actions will be examined during future l inspections.
Romort Details Summary of Plant Status Unit i remained shutdown for a steam generator replacement outage for the duration of the inspection period. During the pedod, all four old steam generators were removed, and all replacement steam generators were set in place. Welding the new steam generators in pison continued at the 6nd of the inspection period, and the containment hole was being restore Unit 2 operated at or near full power for the entire inspection perio _ l. Deerations 01 Conduct of Operations 01.1 General Comments (71707)
During the inspection period, the inspectors conducted several observations of control room activities.- The inspectors routinely observed good annunciator alarm response and the operators were knowledgeable of the status of all the annunciator alarms. Operators were aware of activities that could affect the safe operation of each unit. The inspectors also observed good communication between the unit opemtors and good supervisory oversight by the unit supervisors. The inspectors concluded that routine control room
  . operations were conducted safely and conservativel The inspectors also made routine inspections of the auxiliary and fuel handling buildings -
during the inspection period. Due to the steam generator replacement outage in progress on Unit 1, the inspectors focused on Unit 1 activities that potentially affected Unit 2. The inspectors considered the housekeeping for Unit 2 very good. Unit 2 structures, s, . ems, and components were easily accessible to operators. General area housekeeping was good given the amount of outage activities that were in progress during the inspection period. The inspectors routinely observed equipment staged appropriately and carts
  = properly secured. The inspectors considered the control of outage related material good except for two specific failures to control transient combustible material, discussed in Section F ' Miscellaneous Operations issues (71707)
0 Shutdown Risk Proaram Inspection Scope
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During the inspection eriod, the inspectors reviewed the licensee's shut down risk program. The review ncluded discussions with the shutdown risk coordinator, a review of BAP 1750-6, " Shutdown Risk Program Summary," Revision 3, and a review of the licensee's shutdown risk manual for refueling outage B1R08. The inspectors also routinely observed shutdown risk postings and discussions of shutdown risk at daily briefs and meeting =;=


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Sincerely,
. Observations and Findinat The licens .e's shutdown risk program provided control of components and systems important to safety during unit outages. The control was provided through heightened awareness of plant status during oute, ss, a committee review process for the scheduling of risk significant activities during an outage, and contingency plans for risk significant activitie The inspectors routinely observed a heightened awareness of plant risk status during outages. The licensee used posters, daily outage summaries, closed circuit television, and discussions during both the operating crew brief and plan of the day meeting to emphasize the shutdown risk associated with Unit i activities. The inspectors found that station personnel awareness of the shutdown risk status wab excellen The licensee used a computer p*ogram colled Outage Risk Assessment Models (ORAM)
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to assist in the review of risk significant activities. The shutdown risk coordinator reviewed the outage schedule, identified risk significant activities, and then used the risk significant outage schedule for the outage risk profile development. Both deterministic and probabilistic approaches were included in ORAM. The deterministic portion allowed the shutdown risk coordinator to include a defense in depth concept, Technical Specification (TS) requirements, Updated Final Safety Analysis Report (UFSAR)
Michael . J rdan, Chief Reactor Projects Branch 3 l
information and engineering judgement when safety system functional assessment trees (SSFATs) were created. The licensee determined the risk level for each of seven key safety functions based on plant configuration and equipment availability and risk level was identified by color coding. Since the original outage risk profile was developed from a schedule, the actual status of equipment was compared twice dally to the expected equipment status and any discrepancies resolved. A probabilistic approach was also included. The core damage frequency (CDF) profile was created for the outage and included as an indicator of ris The licensee used a Shutdown Risk Review Board (SRRB) to review and approve all changes to the shutdown risk models. The SRRB also reviewed and approved risk profiles before the licensee began an equipment outage. The SRRB consisted of the shutdown risk coordinator (either a licensed operator or a person having completed license certification), at least one currently licensed operator, an outage management representative, and a qualified nuclear engineer for reactivity issues. Senior station management conducted a final review and approval of the outage risk profile, Contingency plans were developed to mitigate challenges to key safety functions. A cuntingency plan was required for higher risk activities. The plans were written to use
Docket No.: 50-454; 50-455 See Attached Distriisution
. Installed or temporary equipment and procedures. Typically contingency plans also included increased monitoring of affected equipmen Conclusions The inspectors concluded that the licensee's shutdown risk program and its implementation were excellent. A detailed review of the outage schedule was conducte The licensee determined the risk level for each key safety function bas 3d on plant y configuration and equipment availability using SSFATs. A CDF was included in the risk profile. The SRRB approved all changes to the risk models. Shutdown risk was
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  . cc- M. Wallace, Senior Vice President i D. Helwig, Senior Vice President  j l G. Stanley, PWR Vice President J. Perry, BWR Vice President D. Farrar, Regulator  l Services Manager  i
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1. Johnson, Licensing Director DCD - Licensing K. Graesser, Site Vice President K. Kofron, Station Manager D. Brindle, Regulatory Assurance
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; Supervisor l Richard Hubbard Nathan Schloss, Economist Office of the Attomey General State Liaison Officer l State Liaison Officer, Wisconsin l Chairman, Illinois Commerce  !
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  ' Mr. Oliver President, Nuclear Generation Group Commonwealth Edison Company ATTN: Regulatory Services Executive Towers West 111 1400 Opus Place, Suite 500 Downers Grove, IL 60515 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-454/97024.DRP; NO. 50-455/97024(DRP))
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communicated to all station personnel using several methods. Contingency plans provided additional guidance for operators end existed for most yellow condition .2 1Q,pFR 50,54ff) Letter Commitment Review Inspection Scope The inspectors reviewed the status of selected commitments pertaining to the licensee's March 28,1997, response to the NRC's request for information pursuant to 10 CFR 50.54(f). The commitment numbers correspond to those used by the licensee in their response, Observations and Find: 31 Commitment 266: "The Plan of the Day meeting is being restructured to communicate and discuss key performance measuras and current issues at the site."


The inspectors periodically attended the Plan of the Day (POD) meeting. The POD was structured to communicate recent events, present plant status, and discuss planned work. Each day a presentation was made by different department representatives, discussing current issues, typically including performance measure ponclusions The inspectors concluded that the POD was an effective communication tool and helped identify performance measures at the site, ll. Maintenance M1 Conduct of Maintenance M Maintenance Obsgrvations (62707) Inspection Scope The inspectors observed all or portions of activities associated with the following work re quests (WR). When applicable, the inspectors also reviewed TS and the UFSAR for potential issue .
==Dear Mr. Kingsley:==
WR 9600117057 01 Preventive Maintenance on 1 A chemical and volume control (CV) pump lube oil cooler
This will acknowled9e receipt of your letter dated March 5,1998, in response to our letter dated Februeray 3,'1998, transmitting a Notice of Violation associated with inspection Report No. 50-454/97024(DRP); 50-455.97024(DRP). We have reviewed your corrective actions and have no further questions at this time. These corrective actions will be examined during future inspections.
  * WR 970009549 Replace rotating assembly on 1 A CV pump Observations and Findinas
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The inspectors observed that the maintenance activities were conducted according to approved procedures and in conformance with TS. The inspectors observed maintenance supervisors and system engineers monitoring job progress. When applicable, appropriate radiation control measures were taken by maintenance personne .
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Sincerely, l
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    /s Michael J. Jordan Michael J. Jordan, Chief Reactor Projects Branch 3  ;
. Conclusions During the inspectors observations, procedures were used and maintenance personnel were knowledgeable of the associated activities. The inspectors concluded that observed maintenance activities were conducted wel M1.2 Surveillance Observations (61726) Inspection ScoAt The inspectors observed the performance of all or parts of the following surveillance tests. The inspectors also reviewed plant equipment and surveillame testing activities against the UFSAR description * 2BOS 3.1.121 Unit 2 Train B Solid State Protection System Bi monthly Surveillance (Staggered)
Docket No.: 50-454; 50-455 See Attached Distribution
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2BVS 5.2.F.3-2 American Society of Mechanical Engineers (ASME) Surveillance Requirements for the Residual Heat Removtsi(RH) Pump
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* 2BVS 7.1.5 2 Main Steam Isolation Valves Partial Stroke Test
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* 2BOS 3.2.1810 Engineered Safety Feature (EST1 Instrumentation Slave Relay Surveillanca
* 1BVS 8.1.1.2f 8 1B Diesel Generator ESF Actuation Test and Non Emergency Trip Bypass Test, and Generator Differential Trip Test Qbservations and Findinos The inspectors noted that proper authorization was routinely obtained from the control room senior reactor operator (SRO) before the start of each surveillance test. At the completion of the surveillance test and after independent verification of system restoration, the TS action requirement was cleared. The inspectors observed the communications between operators in the control room and the auxiliary building, and observed the coordination between the nuclear station operators and nonlicensed operato+s Test instruments used were verified to be calibrated as applicable. The inspectors reviewed completed surveillance tests and verified the surveillance tests met the acceptance criteri ASME Surveillance Reauirements for the 2B Residual Heat Removal (RH) Pumo The inspectors observed the second attempt by the licensee to perform an ASME surveillance on the 2B RH pump. Due to over ranging the suction ressure gauge, the first attempt to perform the surveillance had been unsuccessful. The surveillance test required the suction gauge to read within 80 percent of full scale. During the first attempt, the gauge read greater then 80 percent of full scale cue to RH system check valve leakage (discussed in inspection Report No. 50-454/97022; 50-455/97022, Section M2.1).


The licensee performed a temporary procedure change and installed an additional suction pressure test gauge. The test was repeated and test data gathered with no further problems identifie I
DOCUMENT NAME: G:\byro\byo97024.ty    i v. e .- eene ,om.m.mm.w=v.co m  r cem - v no om OFFICE Rlli [
NAME Jorden:nmM h DATE 03/M/98 OFFICIAL RECORD COPY. i


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! cc: M. Wallace, Senior Vice President i D. Helwig, Senior Vice President l- G. Stanley, PWR Vice President J. Perry, BWR Vice President D. Farrar, Regulator Services Manager 1. Johnson, Licensing Director
. Cor.clusions The inspectors concluded that, based on proper authortzation, good procedure adherence, effective communication and coordination, and proper verification that the surveillance test acceptance cdteria were met, the observed surveillance testing was performed wel M1.3 Steam Generator Replacement Frolect (50001) Inspection Scope Steam generator removal and replacement activity observations were conducted in the Unit 1 containment and spent fuel pool area. The inspector observed the general activities and the following specific work activities:
  * A40232MM Containment / Equipment Hatch Removal for the Transfer of Equipment into the Containmen * B(A/D/B/C)SG0100 Holst SG Out of the Containment and Replace with New SG Observations and Findinos The inspectors observed construction activities during the SG replacement outage. The inspectors observed procedures in use during work activities. The new SGs were stored according to the manufacturers recommendations to prevent degradation during storag The installation of temporary services (welding equipment, power supplies, and lighting)
was completed as described in the procedures. The inspectors also frequently observed supervisors observing the work activit Work activities did not affect the operability of common systems required to support Unit 2 full power operation. During SG removal and replacement activities, the inspectors verified that safety related equipment and systems required to be operable per TS and the UFSAR wers not impaired by the activities, Conclusion Based on procedure usage, supervisory oversight, and adequate protection of Unit 2 systems, the inspectors concluded that the observed Unit i SG removal and replacement activities were completed appropriatel Ill. Enoineerina E1 Conduct of Engineering E Steam Generator Replacement Project (SGRP) Contrector Control and Oversio Inspection Scope (50001)
The inspectors observed SGRP civil engineering staff oversight of'he horizontal rotation of a new SG, the lowering of two old SGs, the operation of the outside lift system, and the
 
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Y transport of an old SG. The inspectors conducted interviews with the SGRP site project manager, the SG construction lead engineer, and the SGRP lead mechanical enginee The inspectors also accompanied the SGRP lead civil engineer and civil engineering staff on field inspection Observations and Findinas From December 17 through ig,1997, inspectors performed an assessment of licensee oversight of contractors involved in the SGRP The inspectors were told by the SG construction lead engir,eer that field engineers physically monitored all major evolutions associated with the SGRP. The field engineers typically verified that the contractors followed the approved work packages, that acceptance criteria were met, and that quality control requirements were satisfied. The SGRP lead engineers for each discipline (civil, electrical, and mechanical) were also involved with problem resolutio The inspectors accompanied the SGRP lead civil engineer and civil engineering staff on field inspections. The inspectors observed the horizonta, otation of a new SG, the lowering of two of the old SGs, the operation of the outside lift system, and the transport of an old SG During the rotation of the new SG, the inspectors observed the SGRP lead civil engineer review the work package. The engineer also verified that the work package ,
documentation reflected the physical condition of the SG, verified quality control requirements had been completed, and discussed the status of the job with the responsible forema The inspectors accompanied the SGRP lead civil engineer and civil engineering staff as they observed the lowering of the two old SGs. The lowering of each SG from the runway to the transport vehicle by the outside lift system was performed without problems. Prior to the transport of each SG to the old SG storage facility, the SGRP lead civil engineer verified that all prerequisites were completed. The transport of the SGs to the old SG storage facility also was performed without any problems, Conclujlons The Inspectors concluded that the licensee's oversight of contractors during the hotontal rotation of a new SG, the lowering of two old SGs, the operation of the outside lift system, and the transport of an old SG was effective. The SGRP lead civil engineer and civil engineering staff were actively involved in the oversight of contractor personnel and were knowledg6able of the evolution E7 Qualiti assurance in Engineering Activities E identificEion. Trackina. and Resolution of SGRP Nonconformances
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DCD - Licensing
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a, inspection Sgspa (50001)
K. Graesser, Site Vice President K. Kofron, Station Manager l D. Brindle, Regulatory Assurance Supervisor l Richard Hubbard -
The inspectors conducted interviews with the SG construction lead engineer and the s SGRP lead mechanical engineer to discuss the process for identification, tracking, and resolution of nonconformances. The inspectors reviewed NSWP A 15," Comed Nuclear Division Integrated Reporting Program," Revision 1; Construction Procedure CP 7,
l Nathan Schloss, Economist Office of the Attomey General State Liaison Officer
" Byron /Braidwood Power Stations SG Replacement Project Deviation Control,"
; State Liaison Officer, Wisconsin l Chairman, Illinois Commerce Commission l
 
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Revision 2; and "Bechtel Engineering Department Project instruction for Nonconformance Reports," Revision Observations and Findinas The inspectors discussed the Pacess for identifying, tracking, and resolving nonconformances with the SG construction lead enginear and the SGRP lead mechanical engineer. The inspectors were tesid that identification and the disposition of nonconformances were accomplished by a nonconformance report (NCR). The NCR was
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reviewed by the contractor's quality control personnel and project ugineering personnel with copies of the NCR pmvided to Comed SGRP site quality verification (SQV) and Comed SGRP engineering groups. The licensee's problem identification forms (PIFs)
were not used unless the nonconformance was outside the scope of the contiactor's wor Conclusions The inspectcis concluded that a process for the identification, tracking, and resolution of nonconformances for the SGRP was successfully implemented and appeared to be effective. A potential weakness existed in that operations personnel were not involved in the nonconformance report review proces IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls R Radiolooical Control of Old SG Durina Tra7 sport (71750. 50001)
The inspectors observed the removal of an old SG from the Unit 1 containment on December 17,1997. While the old SGs were lowered to the ground and during transport to the old SG storage faciiity, a moving radiological are : existed. The licensee ensured the entire SG was encapsulated with an extra coating to prevent any possible spread of con * amination. The radiological protection (RP) technicians also controlled both the number of personnel near the old SG and the distance between nonessential personnel and the old SG. Active participation by RP supervision was also noted by the inspector The inspectors concluded that the transport evolution was properly controlle R1 ? Control of Drinkina Water inside a Radioloaically Posted Area (71750. 50001) Inspection Scope On December 24,1997, during a routine inspection of th3 auxiliary and fuel handling buildings, the inspectors noted a 5-galloq water fountain inside the radiologically posted area (RPA). The inspectors reviewed Byron Radiation Protection Procedure (BRP) 5000-7," Unescorted Access to and Conduc,t in Radiologically Posted Areas,"
Revision 7, and Station Policy 12, " Drinking Water in the RPA," Revision ..
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- Observations and Findinas
~ The inspectors observed that the drinking fountain was placed such that a person coming out of the Unit 1 containment could obtain a drink of water while still in an area posted as a high radiation area (HRA) and corataminated area. A hole was cut in the plexiglass boundary of the HRA, and the water bottle was located in the RPA such that the spigot penetrated into the HRA and contaminated area. A procedure was posted on the bottle indicatir:g that to get a drink, a worker should remove an outer glove, take a paper cup, get a drink, and then crush the cup and place it in a potentially clean trash barrel. No personnel were in the HRA, and the inspectors did not identify any RP personnel in the immediate area of the water bottl The inspectors discussed the availability of drinking water in the RPA with the Radiation Protection Manager (RPM). The RPM stated that the purpose of having water s.vailable i was to prevent heat stress and that the water was controlled by RP personnel as stated in the station policy. On December 24,1997, the inspectors noted that the water station was not directly controlled. The inspectors also noted that no method to perform a hand contamination survey, cr frisk, before using the drinking water station existed; however, RP personnel routinely surveyed the area for contamination, and no personnel contamination events occurred related to drinking the wate Following the inspectors' observations, the licensee stated the controls for the use of the drinking water facility were improved. Changes included posting the water bottle for heat stress relief use only and requiring that RP personnel only dispense the water. The -
licensee also moved the water bottle such that it was under direct RP personnel contro The inspectors considered the improvements appropriat Conclusions The inspectors concluded that the methods for controlling the use of a drinking water
- station in a high radiation /cor,taminated area on December 24,1997, created a potential problem.' Althoug5 there had not been any known contamination events attributable to the manner in which the drinking water stations was controlled, an !ndividual could potentially be contaminated due to the lack of direct control by RP technicians, the general access to the water station, and the lack of personal survey Conduct of Security and Safeguards Activities (71750,50001)
S Removal of Old SG from Protected Area -.
The inspectors observed the removal of an old steam generator from the protected area on December 17,1997.- The inspectors observed the security control of the fence penetration and access control of personnelleaving and retuming to the protected area through the fence penetration. Security supervision was present. The inspectors considered the penetration well controlle .
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F1 Control of Fire Protection Activities (71750)
F Transient Comtstible Material Control Inspection Scope Curing routine inspections of the auxiliary building, the inspectors observed the licensee's control of comt ustible material. The inspectors also reviewed BAP 1100-9, " Control, Use, and Storage of Flammable and Combustible Liquids and Aerosals," Revision Observations and Findinas On December 3,1997, the inspectors observed mechanical maintenance personnel performing planned maintenance on the 1 A chemical and volume control (CV) pum The inspectors noted a 55-gallon barrellocated outside the CV pump room that contained oil soaked rags. The inspectors also observed the mechanics working on the 1 A CV pump using the SS-gallon barrel as storage for oil soaked rag During the review of BAP 1100-9, the inspectors noted that paragraph C.6.c stated that flammable / combustible liquid soaked rags , , . shall be disposed of by using an approved waste can with a self closing lid. The inspectors identified the discrepancy to the Fire Marshall and the SS-gallon barrel was removed and replaced with an appropriate self closing lid container. The Fire Marshall also stated that the 55 gallon barrelwas not an approved container. The inspectors concluded that the use of a 55-gallon barrel to store oil soaked rags was a failure to follow BAP 1100-9 and a violation of TS 6.8.1 as described in that attached Notice of Violation (50-454/455-97024-01(DRP)).
On December 8,1997, the inspectors identified 13 containers of Carboline staged near the Unit 2 fuel transfor canal control panel. The inspectors noted that the buckets were labeled as flammable.- The inspectors did not notice a Transient Fire Load tag and confirmed that a Transient Fire Load Permit had not been issued. After the inspectors identified the discrepancy to the operating crew, a Transient Fire Load Permit was prepare Byron Administrative Procedure 1100-9, paragraph C.2.a stated that all flammab!s and combustible liquid containers transported into plant areas which will be left unattended shall have prior authorization by the Station Fire Marshal / designee. Authorization shall be accomplished by completing a Transient Fire Load Permit and submitting it to the Station Fire Marshal / designee for approval. An approved Transient Fire Load tag will then be issued upon Fire Marshal approval. The inspectors concluded that the failure to obtain a Transient Fire Load Permit was a failu'e tv, follow BAP 1100-9 and a violation of TS 6. (50-454/455-97024-02(DRP)). Conclusions The inspectors concluded that the licensee did not always aggressively control the increased amount of transient combustibles during the refueling outage. Two independent cases of poorly controlled combustibles were iden'ified by the inspectors during the inspection period. On separate occasions, a 55-galk, i barrel of oil soaked
 
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e rags and 13 containers of a flammable liquid were observed. Two violations for failure to l
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follow a procedure were cite V. Mananoment Meetinos X1 Exit Meeting Summary The inspectors presented the inspection results 'o members of licensee management at the conclusion of the inspection on January 12,1998. The licenseo ncknowledged the findings presented. The inspec. ors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie .      _ _ _ _ _ _ _ _ _ _ _ _ -.-
!. PUBLIC IE-01  TSS l A. Beach  DRS (2)
 
Deputy RA  RlliPRR I. Rlli Enf. Coord. RAC1 (E-Mail)
.
l SRI Byron  IEO (E-Mail)
PARTIAL LIST OF PERSONS CONTACTED Licensee K. Kofron, Byron Station Manager -
Project Mgr., NRR DOCDESK (E-Mail)
  -J. Bauer, Health Physics Supervisor D. Brindle, Regulatory Assurance Supervisor E. Campbell, Maintenance Superintendent T. Gierich, Operations Manager B. Israel, Site Quality Verification Supervisor
l GREENS l
.
l l        i i.       1 i
- T. Schuster, Manager of Quality & Safety Assessment M. Snow, Work Control Superintendent B. Kouba, Engineering Manager s
_ - _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ -
 
14
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  -
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    -
 
.
.
INSPECTION PROCEDURES USED IP 50001: Steam Generator Replacement inspection IP 61726: Surveillance Observations IP 62707: Maintenance Observations IP 71707: Plant Operations -
IP 71750: Plant Suppo1 ITEMS OPENED, CLOSED, AND DISCUSSED Opened
        ,
50-454/455-97024-01  VIO Oil soaked rags found in a 55-gallon carrel without a self closing li /455-97024-02  VIO "ailure to obtain a Transient Fire Load Permi Closed None
 
_ - _ _ _ _ _ _ __
 
..
4'
LIST OF V.,MONYMS USED ASME Americati Society of Mechant;al Engineers  !'
BAP Syron Administrative Procedure BMP- Byron Mechanical Maintenance Procedure BOP Byron Operating Procedure BRP_ Byron Radiation Protection Procedure
- CDFT Core Damage Frequency -
CV Chemical and Volume Control DG Diesel Generator DRP- Division of Reactor Projects DP9 Division of Reactor Safety
- ECCS Emergency Core Cooling Syste ECN - Equipment Component Numbe ESF- Engineered Safety Feature FME - Foreign Material Exclusion
  - HLA Heightened Level of Awareness HRA_ .High Radiation Area LCO Limiting Condition for Operation LCOAR Limiting Condition for Operation Action Requirement -
LER Licensee Event Report h-  MHS Material Handling System
/  NCR Nonconformance Report -
  - NSO Nuclear Station Operator t_
NSWP Nuclear Station Work Procedure OOS Out-of-Service ORAM Outage Risk Assessment Models PDR Public Document Room
  - PlF' Problem Identification Form--
POD Plan of the Day .
  : PSIG . Pounds per Square Inch Gage RCS- Reactor Coolant System RH Residual Heat Removal
  '
RP Radiological Protection RPA: Radiologically Pcated Area RPM - Radiation Protection Manager
 
SFP- Spent Fuel Pool  '
SG- - Steam Generator SGT Steam Generator Replacement SGRP- Steam Generator Replacement Project SP Special Plant Procedure -
  - SQV:- Site Quality Verification -
y  _SRO Senior Reactor Operator SRRB- Shutdown Risk Review Board SSFAT _ Safety System Functional Assessment Trees-SSPS ' Solid State Protection System SX Essential Service Water System TS Technical Specification UFSAR Updated Final Safety Analysis Report WR Work Request
 
_ . .
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  . . .
      ..
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      .
}}
}}

Latest revision as of 20:46, 15 December 2021

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-454/97-24 & 50-455/97-24.Actions Will Be Examined During Future Insp
ML20248L529
Person / Time
Site: Byron  Constellation icon.png
Issue date: 03/16/1998
From: Jordan M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Kingsley O
COMMONWEALTH EDISON CO.
References
50-454-97-24, 50-455-97-24, NUDOCS 9803230158
Download: ML20248L529 (4)
v • d • e


Text

. 6" "' 80 UNITED STATES

/ % NUCLEAR REGULATORY COMMISSION I $ REGION til g a 801 WARRENVILLE ROAD

)

a 8 LISLE, ILLINOIS 60532-4351 i

l %...../ March 16, 1998

l l Mr. Oliver i President, Nuclear Generation Group l Commonwealth Edison Company l ATTN: Regulatory Services J Executive Towers West lll l 1400 Opus Place, Suite 500 Downers Grove,IL 60515 i

'

SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-454/97024(DRP);

NO. 50-455/97024(DRP)) 1

Dear Mr. Kingsley:

This will acknowledge receipt of your letter dated March 5,1998, in response to our letter dated Februaray 3,1998, transmitting a Notice of Violation associated with inspection Report No. 50-454/97024(DRP); 50-455.97024(DRP). We have reviewed your corrective actions and I

have no further questions at this time. These corrective actions will be examined during future l inspections.

l

Sincerely,

! b (

Michael . J rdan, Chief Reactor Projects Branch 3 l

Docket No.: 50-454; 50-455 See Attached Distriisution

! \

\

l t empoppi

! 9803230158 980316 I PDR ADOCK 05000454 G PDR fHhkC- - - - - - - - - - _

_ _ _ _ _ _ ___ __ _ _ _

. cc- M. Wallace, Senior Vice President i D. Helwig, Senior Vice President j l G. Stanley, PWR Vice President J. Perry, BWR Vice President D. Farrar, Regulator l Services Manager i

'

1. Johnson, Licensing Director DCD - Licensing K. Graesser, Site Vice President K. Kofron, Station Manager D. Brindle, Regulatory Assurance

Supervisor l Richard Hubbard Nathan Schloss, Economist Office of the Attomey General State Liaison Officer l State Liaison Officer, Wisconsin l Chairman, Illinois Commerce  !

Commission l l

l

!

I l

l l

r l l

l

e c

I I

' Mr. Oliver President, Nuclear Generation Group Commonwealth Edison Company ATTN: Regulatory Services Executive Towers West 111 1400 Opus Place, Suite 500 Downers Grove, IL 60515 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-454/97024.DRP; NO. 50-455/97024(DRP))

Dear Mr. Kingsley:

This will acknowled9e receipt of your letter dated March 5,1998, in response to our letter dated Februeray 3,'1998, transmitting a Notice of Violation associated with inspection Report No. 50-454/97024(DRP); 50-455.97024(DRP). We have reviewed your corrective actions and have no further questions at this time. These corrective actions will be examined during future inspections.

Sincerely, l

/s Michael J. Jordan Michael J. Jordan, Chief Reactor Projects Branch 3  ;

Docket No.: 50-454; 50-455 See Attached Distribution

'

l

!

DOCUMENT NAME: G:\byro\byo97024.ty i v. e .- eene ,om.m.mm.w=v.co m r cem - v no om OFFICE Rlli [

NAME Jorden:nmM h DATE 03/M/98 OFFICIAL RECORD COPY. i

.t !

! cc: M. Wallace, Senior Vice President i D. Helwig, Senior Vice President l- G. Stanley, PWR Vice President J. Perry, BWR Vice President D. Farrar, Regulator Services Manager 1. Johnson, Licensing Director

,

DCD - Licensing

'

K. Graesser, Site Vice President K. Kofron, Station Manager l D. Brindle, Regulatory Assurance Supervisor l Richard Hubbard -

l Nathan Schloss, Economist Office of the Attomey General State Liaison Officer

State Liaison Officer, Wisconsin l Chairman, Illinois Commerce Commission l

'

Distribution:

l Docket File DRP

!. PUBLIC IE-01 TSS l A. Beach DRS (2)

Deputy RA RlliPRR I. Rlli Enf. Coord. RAC1 (E-Mail)

l SRI Byron IEO (E-Mail)

Project Mgr., NRR DOCDESK (E-Mail)

l GREENS l

l l i i. 1 i

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