ML20199J909

Insp Repts 50-454/97-22 & 50-455/97-22 on 971017-1201. Violations Noted.Major Areas Inspected:Operations,Maint, Engineering & Plant Support

ML20199J909
Person / Time
Site:	Byron
Issue date:	12/24/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20199J873	List: IR 07100017/2012001 ML20199J866 ML20199J909
References
50-454-97-22, 50-455-97-22, NUDOCS 9802060062
Download: ML20199J909 (23)

See also: IR 05000454/1997022

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U. S. NUCLEAR REGULATORY COMMISSION

REGION til

. Docket Nos: 50-454; 50-455

License Nos: NPF.37; NPF 66

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Report No:

50-454/97022(DRP); 50-455/97022(DPP)

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Licensee:

Commonwealth Edison Company

Facility:

Byron Generating Station, Units 1 and 2

Location:

4450 N. German Church Road

Byron, IL 61010

Dates:

October 17 - December 1,1997

Inspectors:

- N. Hilton, Resident inspector

T. Tongue, Region lli Project Engineer

C. Phillips, Braidwood Station Senior Resident inspector

J. Adams, Braidwood Station Resident inspector

D. Pelton, Braidwood Station Resident inspector

C, Thompson, lilinois Department of Nuclear Safety

Approved by:

Michael J. Jordan, Chief

Reactor Projects Branch 3

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9802060062 971224

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PDR

ADOCK 05000454

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PDR

EXECUTIVE SUMMARY

Byron G:nerating St: tion, Units 1 and 2

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NRC Inspection Report No. 50 454/97022(DRP); 50-455/97022(DRP)

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This inspection included aspects of licensee operations, maintenance, engineering, and

plant support The report covers a 6-week period of resident inspection.

Operations

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The Unit 2 startup on October 21,1997, demonstrated excellent operator

performance. Consistent three way communications between operators and formal

command and control by the unit supervisor and shift manager were observed. The

operators minimized the number of personnel in the control room, thus reducing

distractions. The qualified nuclear engineer reported directly to the unit supervisor

and made good recommendations and observations. The operators responded to

each annunciator alarm, reviewed the procedure and took appropriate action. The

approach to criticality was slow and controlled (Section 01.1).

The Unit 1 shutdown on November 7,1997, was wall executed. Excellent command

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and control, very good three-way communications, and good briefs and oversight by

management were observed (Section 01.2).

Routine control room observations were very good. Control room personnel

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conducted themselves professionally, unit supervisors and nuclear station operators

completed their duties without distraction, control room personnel were

knowledgeable of plant conditions, and operators practiced proper three way

communications while performing plant evolutions. The addition of a work execution

center outside the cont.ol room significantly reduced the number of personnel

requiring entry to the control room. Those personnel entering the control room

behaved professionally, observed the proper control room protocol, and entered for

the conduct of technical or administrative business with the unit supervisors or

nuclear station operators (Section 01.3).

A review of the September 1997 2B chemical and volume control (CV) pump work

activity documentation identified severalissues. Procedure problems with filling and

venting the pump were identified by the licensee; however, no corrective actions

were taken or planned until questioned by the inspectors. Additionally, poor inter-

department communications existed as demonstrated by the fact that five individuals

involved in the CV pump maintenance did not know the status of the pump;

specifically, whether or not the pump had been drained during the maintenance

activities. A violation example for an inadequate procedure was issued (Section

O3.1).

No corrective actions were taken for two problem identification forms (PIFs) written

during the 2B CV pump work. Issues identified in the PlFs included a lack of a CV

pump fill and vent procedure, an inadequate safety evaluation, and poor

communications between departments. The corrective action program failed to

capture the issues identified adequately and assign an appropriate investigation

(Section 08.2).

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Maintenance /Surveillange,

. Obs:rv:d maint: nance and surveillance activities w:re w:ll conduct:d. Proc:dures

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were used, personnelinvolved were knowledgeable, most foreign material exclusion

(FME) controls were good, and issues were identified by maintenance personnel.

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Additionally, based on proper authorization, procedure adherence, good

communication and coordination, and verification that the surveillance acceptance

criteria was met, the observed surveillance testing was well performed (Sections

M1.1 and M1.2).

Foreign material control around the Unit 1 containment floor drain sump was pocr

and not in accordance with the station procedure governing foreign material control.

The sump was designated sa an FME area and holes in the floor drain sump cover

were not protected with FME covers. A violation for failure to follow the FME

procedure was issued (Section M1.3).

On November 21,1997, during a system walkdowr., the inspectors noted boron

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deposits on the sealinjection lines fittings and connections that had been previously

repaired in September 1997. The deposits had been identified by the licensee and

an action request had been written. The inspectors considered previous -

maintenance was not effective to prevent system leakage (Section M1.4).

The material condition of the Unit 2 residual heat removal (RH) system prevented the

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satisfactory conduct of the quarterly ASME surveillance as written due to leaking

reactor coolant system (RCS) cold leg check valves. The operability evaluation for

the condition was adequate, but did not address contingency actions for operators to

take to prevent a potential RH pump suction relief valve lift during a small break loss

of coolant accident (Section M2.1).

After dropping a section of runway to be used during the steam generator

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replacement, the licensee responded appropriately, quarantined the area and

promptly performed a formal investigation (Section M8.1).

Enaineerina

System engineering identified that two vent valves were not included in the monthly

Unit 1 emergency core cooling system (ECCS) venting surveillance test. The valves

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were discovered during a modification review for system enhancements. The system

enhancements were part of actions taken following identification in May 1997 that a

residual heat removal vent valve was not being included in the monthly Unit 1 ECCS

venting surveillance test (Section E1.2).

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Plant Support

A worker struck contaminated stairs staged in the fuel handling building three times

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with the uncontaminated handling equipment while using an overhead hoist.

Radiological response was appropriate; however, the repeated striking of

contaminated equipment showed poor radiological work practices and a disregard for

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contamination area postings by personnel (Section R1.1).

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Report Details

Summary of Plant Status

Unit 1 operated at or near full power until November 7,1997, when the licensee began a

steam generator replacement and refueling outage. Unit i remained shutdown at the end

of the inspection period.

Unit 2 was synchronized to the grid on October 21,1997, after extraction steam bellows

repairs were completed. Unit 2 then operated at or near full power through the end of the

inspection period.

l. Operations

01

Conduct of Operations

01.1

_U_ nit 2 Startuo followina Extraction Steam Bellows Rooair (71707)

The inspectors observed significant portions of the Unit 2 startup on October 21,

1997. The inspectors observed consistent three way communications between

operators and formal command and control by the unit supervisor and shift manager.

The operators minimized the personnel in the control room, thus reducing

distractions. The qualified nuclear engineer reported directly to the unit supervisor

and made good recommend " ns and observations. The inspectors also noted that

the operators responded to i ch annunciator alarm, reviewed the procedure and

acted accordingly. The approach to criticality was slow and controlled. The

inspectors concluded that the Unit 2 startup demonstrated excellent operator

performance.

01.2 Unit i Shutdown for Refuelina and Steam Generator Reolacement (71707)

a.

Inspection Scooe

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The inspectors observed portions of the Unit i shutdown on November 7,1997.

Observations included licensee preparations, briefings, communications, command

and control, and the operators' performance during the unit shutdown.

b.

Observations and Findinas

Several briefings were provided to the station staff involved in the actual shutdown

and outage preparations. The site vice president briefed all site personnel,

emphasizing clear communications, nuclear safety, minimizing radiation exposure,

personnel safety and the necessity for error free operations. A briefing from the

operations manager for the crew performing the shutdown emphasized the following:

safety first, if any abnormality or doubt existed don't hesitate to trip the unit, the

schedule was not a concern, use three way commurications, and formal command

and control. The inspectors also observed the heightened level of awareness (HLA)

briefing immediately prior to the shutdown and found it to be thorough and detailed.

in addition, several other briefings before each evolution during the shutdown were

conducted.

During the shutdown, the inspectors noted excellent comma.1d and control with very

good three-way communications. The process was well controlled and activities

were conducted with minimal congestion in the control room. Personnel involved

were knowledgeable of their duties and good management and supervisory oversight

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was obs;rv:d by th3 inspectors.

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. Conclusion

The inspectors noted that the shutdown was executed as planned. This was

exemplified by excellent command and control, very good three way

communications, and oversight by management.

01.3 Observation of Control Room Conduct (71707)

a.

Inspection Scooe

The inspectors conducted observations in the control room to assess the conduct of

control room personnel, control room communications, and control room access

coritrols. The inspectors reviewed Byron Administrative Procedure (BAP) 300-1,

' Conduct of Operations,' Revision 14.

b.

Observations and Findinas

On November 12,1997, inspectors observed operators in the control room. The

inspectors found that control room personnel conducted themselves professionally.

For example, control room conversations were conducted in a way that minimized

control room distractions and maintained the professional atmosphere. The

inspectors observed that the unit supervisors and nuclear station operators (NSOs)

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were attentive to their duties. The unit supervisors made frequent trips to the "at the-

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controls" area of the control room to supervise evolutions in progress, to directly

observe a reactivity addition, and to do general control board walkdowns. The unit

operators were observed performing frequent control board walkrlowns, monitoring

surveillance tests and plant evolutions, and closely monitoring reactor cora nuclear

parameters during and following the withdrawal of control rods (Unit 2).

The inspectors also observed the addition of boric acid solution to the Unit 1

refueling water storage tank and the performance of slave relay surveillance testing

on Unit 2. During each of these evolutions, the inspectors observed proper 3 way

communications between operators.

The inspectors observed that personnel entering the control room followed the

proper control room entry protocol and entered to conduct technical or administrative

business. For example, the work execution center NSO entered several times with

out of service documents that required the unit supervisor's approval. The

inspectors observed that the number of non shift personnel entering the control room

was minimal. The work execution center NSO told the inspectors that the recently

created work execution center had eliminated the necessity for personnel to enter

the control room to obtain approvals to begin work. Most of the work control function

was done outside the control room.

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QJ;tosjysions

. Bas:d on the obs:rvations in the control room on Nov:mber 12,1997, tha

inspectors concluded that the control room personnel conducted themselves

professionally, unit supervisors and NSOs completed their duties without distraction,

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control room personnel were knowledgeable of plant conditions, and operators

practiced proper three way communications while performing plant evolutions.

The inspectors also concluded that the number of personnel entering the control

room was significantly reduced by the addition of a work execution center outside the

control room. Those personnel entering the control room behaved professionally,

observed the proper control room protocol, and entered to conduct technical or

administrative business with the unit supervisors or NSOs.

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Operations Procedures and Documentation

03.1 Chemical and Volume Control Pumo 28 Fill and Vent (71707)

n.

Inspection Scope

The inspectors reviewed several aspects of the work on the 2B chemical and volume

control pump, conducted by the licensee in September 1997. The inspectors

re/iewed Byron Operating Procedure (BOP) CV 3, *Fillirig and venting the CV

system," Revision 5, the licensee's root cause investigation (see Section 08.2), out-

of service (OOS) 970008315, and work request (WR) 970006833, " Seal injection

lines need to be cleaned." The inspectors also discussed CV pump venting with the

system engineer, operators, and the operating manager,

b.

Observations and Findinas

On September 8,1997, the licensee began performing several tasks on the 2B

chemical and volume control (CV) pump. One task was to clean the seal injection

lines to the 28 CV pump. The original task, first attempted in January 1997, was to

clean boron deposits off several connections near the pump casing. However, the

leaks were active and the boron deposits continued. During September 1997,

mechanical maintenance disassembled and reassembled several threaded

connections and a mechanical connection to correct the leaks.

Operatore questioned the decision to drain the pump on September 10,1997,and

documented the concern on a problem identification form (PlF). The shift manager

noted on the PIF that the CV pump was not drained for scheduled maintenance.

However, the inspectors noted that the 2B CV pump out-of service OOS included

2CV007B,2B CV PP 2CV01PB Casing Drain Valve, with a comment to use the

valve to drain the pump for mechanical maintenance work on the pump seal. The

inspectors noted that the sealinjection line cleaning was also covered by the same

OOS Additionally, the work package for the seal injection line cleaning required

removal of elbows and breaking 4-bolt flanges. The work request documented

completion of the disassembly and reassembly on September 9,1997. The

inspectors also observed the actuallocations of the elbow fittings and flanges and

noted that some of the connections were below the elevation of the upper portion of

the pump. All of the connections were several feet lower in elevation that the suction

and discharge isolation valves used to isolate the pump. The inspectors concluded

that, contrary to the shift manager's statement, the pump was actually partially

drained.

The inspectors requested the venting procedure for review and were informed by a

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syst:m cnginrr that a v:nting proceduro for the CV pump did not exist for the

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oxisting plant conditions (Mode 1). The lack of a stand:rd operating proc: dure to fill

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and v:nt ths CV pump was also noted by the nucisar station ep:rator (NSO) on the

September 10,1997, PlF Identified above. Discussions with the system engineer

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revealed that the pump suction and discharge gauges were typically vented to vent

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air from the isolated portions of the system. The 2B CV pump also had a pipe stub

w!th a cap near an isolation valve that could have been used, although the

Inspectors noted no vent valve existed. The inspectors noted that the pipe stub and

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cap did not exist on all of the CV pumps.

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Discussions with operations management identified that a fill and vent procedure for

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the CV system did exist. However, the inspectors reviewed BOP CV 3, " Filling and

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-Venting the CV System," and determined that the procedure was inadequate in that

the vent valves identified in the procedure were not within the isolation OOS

boundary. The licensee stated that some operators considered removing a pipe cap

skill of the craft; however, the inspectors noted that to vent the CV pump, a pipe cap

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was removed, instrument lines for two gauges were vented, and a temporary

procedure change was written to vent the mini-flow line (see Section E1.1).

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Therefore, the inspectors considered the necessary venting steps significant and

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warranted an appropriate procedure.

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Title 10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings,"

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stated, in part, that activities affecting quality shall be prescribed by documented

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Instructions, procedures, or drawings, of a type appropriate to the circumstances.

The inspectors concluded that a fill and vent of the 2B CV pump was an activity

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affecting quality and that the existing procedure was not appropriate to the

circumstance; therefore, the procedure to accomplish the fill and vent was an

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example of a violation of 10 CFR 50, Appendix B, Criterion V

(50-454/455-97022-01(DRP)).

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The inspectors considered the non-cited violation criteria; however, the NSO's

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identification of the issue was not corrected without the inspectors' questioning. The

PIF was " issued closed" by the station event screening committee based on the shift

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manager's comments. Therefore, no corrective action was taken or planned after

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the completion of the licensee's root cause (see Section 08.2).

Discussions with the in plant shift supervisor (a senior reactor operator) indicated

that the operating crew did not know the status of the pump early on September 10,

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1997. The crew was initially unable to determine whether the pump had been

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drained. None of the following individuals were aware of whether or not the pump

had been drained; the project manager for the work, the work week manager, the

system engineer, or the night shift mechanical maintenance supervisor. Through a

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detailed review of the work packages, operators determined that the pump had been

partially drained. The inspectors concluded that the lack of knowledge of the pump

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status was an example of poor communications between departments.

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c.

Conclusions

Th] inspectors conclud:d that the 28 CV pump was partially drain;d during the work

conducted on September 1997. Although procedure problems with filling and

venting the pump were identified by the licensee, no corrective actions were taken or

planned until questioned by the inspectors. Additionally, poor inter-department

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communications existed as demonstrated by the fact that five individuals involved in

the CV pump maintenance did not know the status of the pump. A violation example

was issued.

08

Miscellaneous Operations lasues (92700,92901)

08.1 LClosed) Follow Up Item 50-455-97020-02(DRP): 2B CV Pump Maintenance

Window. This item was discussed in Sections O3.1,08.2, M1.4, and E1.1 of this

report. The inspectors noted several problems during the work window review.

However, the inspectors also noted that operators started a power reduction of Unit

2 when the allowed outage time was nearly exhausted. The power reduction was

begun according to company policy and the decision to start the reduction was

independent of the status of the 2B CV pump. The inspectors concluded that the

operators took conservative actions to begin placing Unit 2 in hot standby with ample

time remaining to perform a safe, orcerly, controlled shutdown. This item is closeo.

08.2 Root Cause Analysis of 2B CV Pump Work Window (717071

a.

Inspection Scope

The inspectors reviewed root cause report 455 200-97-CAQS00026, Revision 0," Job

Removed from Schedule due to Delays in Providing a Technical Evaluation, Lack of

Parts and incomplete Package Preparation." The inspectors also reviewed PlFs

B1997-03144, "Non-conservative decision making," B1997-03103, " Challenges to

Shift Operatk ns Due to Questionable Work Window," and B1997-03085, " Job

removed from schedule due to Technical Evaluation, Parts and Package

Preparation." An On-site Review Report, OSR 97-121, "2B CV Pump Work

Window,' was also reviewed.

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b.

Observations and Findinos

During the review of PIF B1997-03103, the inspectors noted that the PlF was issued

closed to PlF B1997-03085. The lack of a fill and vent procedure for the 28 CV

pump and the communications breakdown discussed in Section 03.1 was identified

on PIF 03103. The inspectors reviewed PlF 03085 and noted that engineering

support issues for the 2B CV pump work window were identified on the PIF.

On October 24,1997, the licensee issued root cause report

455 200-97-CAOS00026. The root cause report discussed the engineering support

issues and identified corrective actions applicable to the engineering support issues.

However, the inspectors identified that the issues identified in PIF 03103 were not

addressed in the root cause report.

Additionally, the inspectors noted that PlF 03144 was issued closed based on the

shift manager's recommendation. This PlF also identifies the lack of a fill and vent

procedure and identifies the safety evaluation concerns discussed in Section E1.1 of

this report. The inspectors were concerned that no corrective actions were taken for

either PlF 03103 or 03144. The inspectors noted the concerns to the operations

manager on October 28,1997. The operations manager agreed with the inspectors

that the root cause did not address all the issues and requested that the root cause

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organization r:open th]investig: tion and da a supplementil root caus].

. On Nov:mber 25,1997, the insp;ctors ask':d th] status of th] suppl;m:ntal root

cause investigation and were informed that the investigation had not been started.

The root cause organization discovered that the request had not been assigned a

due date, the assigned investigator had not been given the task, and the request had

not been entered into the licensee's tracking system. After the inspectors' questions,

the licensee immediately assigned a new investigator, assigned a due date, and

entered the action into the licensee's tracking system. The inspectors noted that the

task had not been lost, action had not been taken by the root cause organization to

initiate the supplemental investigation, almost a month after the initial decision to do

a supplemental investigation.

Due to the violation cited in Section 03.1, and an unresolved item discussed in

Section E1.1, the inspectors did not consider the missed corrective actions a

violation of 10 CFR 50, Appendix B, Criterion XVI, " Corrective Actions."

c.

Conclusions

The inspectors concluded that no corrective actions were taken for two PlFs. Issues

identified in the PlFs included a luck of a CV pump fill and vent procedure, an

inadequate safety evaluation, and poor communications between departments. The

inspectors concluded that the licensee's correctiv s action program failed to capture

the issues identified adequately and assign an appropriate investigation.

D. Maintenance

M1

Conduct of Maintenance

M1.1 Maintenance Observations (62707)

a.

Inspection Scope

The inspectors observed the performance of all or portions of the following work

requests (WR) When applicable, the inspectors also reviewed TS and the Updated

Final Safety Analysis Report (UFSAR) for potential issucc.

WR 940014887-03 Remove / Replace Fill, Fan Blades anc. Drift Eliminator

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WR 960054553 01

Install DCP 9600017/9700469: New Fan Assembly with

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Forged Blades.

WR 97002159

Reactor Vessel Closure Head Removal

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WR 97002170

Reactor Vessel Closure Head Removal

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WR 970028840-01

Clean and inspect the 1A CV Pump Cubicle Cooler

WR 960054553-04

Remove / Install Discharge Check Damper to OD Auxiliary

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Building Supply Fan, OVA 01CD

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b.

Observations and Findinas

The inspectors observ3d that the maintsnanc3 activilits were conducttd according

to approved procedures and were in conformance with TS. The inspectors observed

maintenance supervisors and system engineers monitoring job progress. Quality

control personnel were also present when required. When applicable, appropriate

radiation control measures were taken.

Essential Service Water (SX) Towar Fill Reblacement

The inspectors noted that foreign material exclusion (FME) protection was good

within this project and extensive measures were established to continue operation of

the cooling tower to protect operating equipment while the project was being carried

out. In addition, after completion of each cell, the licensee planned to conduct a

diver inspection of the basin.

OD Auxiliary Buildino Ventilation Supolv Fan Blade Replacement

During the Inspection, the inspectors noted some small debs near the fan suction,

The inspectors concluded that FME controls were weak initially. However, as the

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prole continued, the work areas were acceptably cleaned. A problem was noted by

the neensee with the inadequate fit of a new protective screen installed on the fan

intake. At the end of the period, the issue was being resolved by the system

engineer,

c.

Conclusions

During the inspectors observations, procedures were used, personnel were

knowledgeable, FME controls during the SX 'ower fill replacement were good, and

issues were identified by maintenance personnel. The inspectors concluded that

observed maintenance activities were well conducted,

M1.2 Surveillance Observations (61726)

a.

Inspection Scooe

The inspectors observed the performance of all or parts of the following surveillance

test procedures. The inspectors also reviewed plant equipment and surveillance

testing activities against the UFSAR descriptions.

1BOS 0.5 2.SI.2-2.1

Safety injection System and Spurious Valve Actuation

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Group Valve Stroke test 'A' Train

1BOS 0.5 2.SI.3-1

Safety injection Isolation Valve Indication Test "A" Train

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2BOS 7.1.2.1.b 1

Motor Driven Auxiliary Feedwater Pump Monthly

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Surveillance.

2BOS 8.1.1.2.a 1

2A Diesel Generator Operability Monthly,

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b.

Observations 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 comp:etion 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 non-

licensed operators. Test instruments used were verified to be calibrated as

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applic:ble. The inspectors r: view:d complet:d sury:llianc3 t:sts and v:rif;;d th]

surveillanco t:sts m t the acceptance crit:ria.

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c.

Conclusions

The inspectors concluded that, based on proper authorization, procedure adherence,

good communication and coordination, and verification that the surveillance

acceptance criteria was met, the observed surveillance testing was well performed.

M1.3 Poor Foreian Material Exclusion (FME) Control Observed in Unit 1 Containment

(71707)

a.

InsMction Scoce_

The inspectors made a general inspection of the Unit 1 containment on November

17,1997. The inspectors reviewed NSWP A-03, * Foreign Material Exclusion,"

Revision 0, and discussed the FME issue identified below with a member of station

management,

b.

Observations and Findinas

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The inspectors observed that the Unit 1 containment floor drain sump, on the 377

foot levelinside the containment missile barrier, had been roped off and had signs

designating the area as a foreign material exclusion area. The inspectors observed

two holes in the floor drain sump cover, each about 6 inches square, that were not

protected with FME covers. Another hole in the floor drain sump cover had an FME

cover, but the cover was pulled back, exposing the hole. Inside tho designated FME

area was a washer and several pieces of debris, immediately outside the FME area

on the floor were more pieces of debris. No personnel were monitoring the FME

area and no work or testing was being done on the floor drain sump.

NSWP A-03, Step 6 4.1 states that all system breeches must be covered where

possible except whc : the opening is attended, and work, inspection, or testing is in

progress that requires removal of the FME ccver.

The licensee noted that af,er the identification of the issue, hard covers were

installed to adequately prevent foreign material from entering the system. The

licensee also noted that the sump was scheduled for a complete inspection at the

end of the outage; therefore, the sump was not required to be an FME area.

However, the licensee did agree that the area was posted as an FME area and

should have met the requirements of NSWP A-03.

TS 6.8.1, " Procedures and Programs," required that written procedures shall be

established, implemented, and maintained for the applicable procedures

recommended in Appendix A, of Regulatory Guide 1.33, Revision 2. Regulatory

Guide 1.33, Appendix A recommended general procedures for control of

maintenance activities. The inspectors concluded that the failure to follow NSWP-A-

03 was a violallon of TS 6.8.1 (50-454 97022-02(DRP)).

.c.

Conclusion

The inspectors concluded the foreign material control around the Unit 1 containment

floor drain sump on November 17,1997, was poor and not in accordance with the

station procedure governing foreign material control. The inspectors observed that

the sump was designated as an FME area and that there were two holes in the floor

drain sump cover, each about six inchss square, that were not protected with FME

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cov;rs. A third hole in th3 floor drein sump cov:r that h:d an FME cov:r, but the

cov r was pull:d b:ck, exposing the hole. Inside the designat:d FME area was a

w:sn:r and sev:rci pi:ces of d:bris, imm:dlatlly outside the FME ar a on the floor

were more pieces of debris. A violation was issued.

M1.4 28 CV Pumo Seal inlection Line Cleanina

During a routine inspection of the auxiliary building on November 21,1997, the

-inspectors noted that the seat injection lines fittings and connections discussed in

Section 03.1 had boron deposits again. The inspectors did not identify any water

and concluded that the leaks were small. The inspectors also noted that the

deposits had been previously identified by the licensee and an action request had

been written. The inspectors concluded that the licensee had taken appropriate-

actions to identify the new leaks; however, the maintenance conducted on

September 9,1997, to repair the previous leaks had been ineffective.

M2

Maintenance and Material Condition of Facilities and Equlpment

M2.1 Leakina Reactor Coolant System (RCS) Check Valves Prevents Performance of

Residual Heat Removal (RH) Surveillance (61726)

a.

Inspection Scope

The inspectors reviewed the following docun ents: 2BVS 5.2.f.31, 'ASME [American

Society of Mechanical Engineers) Su veillance Requirements for Residual Heat

Removal Pump 2RH01PA," Revision 17; Operability Evaluation 97 58; OMa 1988,

Pari 6, *lnservice Testing of Pumps in Light Water Reactor Power Plants;" Updated

Final Safety Analysis Report (UFSAR), Chapters 5 and 6; and TS 3.5.2. The

inspectors also interviewed the system engineer.

b.

Observations and Findinas

The inspectors observed the start of the surveillance test. The test had to be halted

because about 10 minutes after the 2A RH pump was started the pump _ suction

pressure increased, reaching about 128 pounds per square inch gago (psig) after

about 17 minutes. The 2B RH pump suction pressure increased to about 317 psig

because it equalized to the 2A pump discharge pressure. A special suction pressure

gage Installed for this surveillance had a range of 100 psig and the surveillance

could not be completed. After the 2A RH pump was secured,2A RH suction

- pressure increased to 279 psig then dropped slowly for about 15 minutes, and then

started to increase at a rate of about 50 psig per hour. Suction pressure was then

dropped to about 50 psig when the suction lines were vented.

The increase in suction prreure was caused by check valve (s) leakage in the RCS

cold leg injection lines. Since the pump recirculates, the pump suction pressure also

increased.

Operability evaluation 97 58 stated that a concern existed that during a small break

loss of coolant accident, the RH pump suction pressure could increase to the point

where the RH suction relief valve would lift, at about 450 psig. The evaluation stated

that the pump would be secured before the suction pressure would reach 450 psig

based on previous history of how fast the pressure was increasing and how fast

operators would secure the pumps according to 2 BEP 1, " Loss of Reactor or

Secondary Coolant,* Revision 1. Operator response time was based on simulator

observations. The operability evaluation did not state that the pressure would

continue to rise after the pumps were secured until the suction line was vented. The

12

__ _ _ _ _

_ _ _ _ _ _

- _ _ _

suction lin;s for a small break loss of coolant accid:nt. The shift manag:r said th:re

The inspectors not:d, howev r,2BEP 1 St:p 13 dir: cts th] operating

w;re non].

crew to cooldown and depressurize the RCS if pressure is above 300 psig, in

addition, operatlJns management personnel stated that caution cards would be

placed on the Unit 2 RH pump control switches to discuss the need to vent the

suction lines if the pumps are operated.

The inspectors verified that the condition with the leaking check valve was listed as

an operator work arr. 9d and that the licensee was working on a plan to identify and

repair or replace the ieaking check valves during the next Unit 2 refueling outage.

c.

Coriclusion

The inspectors concluded that the material condition of the residual heat removal

system prevented the satisfactory conduct of the quarterly ASME surveillance as

written due to leaking RCS cold leg check valves. The inspectors concluded that the

licensee's operability evaluation for this condition was adequate but did not address

contingency actions for operators to take to prevent RH pump suction relief valve lift

during a small break loss of coolant accident.

M8

Miscellaneous Maintenance issues (92700,92902)

M8,1 Lqad Drop Durina Assembly of Steam Generator Replacement (SGR) Eauipment

(50001)

a.

Inspection ScoDe

The inspectors reviewed the circumstances surrounding a heavy load drop. The

inspectors attended the initial fact finding meeting after the incident, observed the

area around the dropped load for potential impact on safety related equipment,

reviewed the licensee's root cause report, and discussed the event with licensee

management,

,

13

1

.

_

b.

Observas.ons and Findinas

On Nov mber 5,1997, the licens:e's SGR contr:ctor was ass:mbling the structures

outside the Unit 1 containment that would be used for moving the new and old SG's

in and out of the containment. A 57,000 pound runway section was dropped from

about 60 feet in the air. At the time of the drop, the runway was being lifted into

place. When the crane operator stopped lifting, the load fell approximately 15 feet.

.

The crane operator took immed!ste actions to stop the load from dropping and

!

brought the load to a sudden stop. The sudden stop caused all four nylon rigging

'

straps to fall, which allowed the runway section to fall to the ground. The platform

'

was about 46 feet long by 10 feet tvide and 2 3 feet high. The platform sustained

considerable damage plus some additional damage was inflicted on another support

structure lying on the ground No injuries were identified and there was no evidence

of damage to any safety related equipment. The licensee formed a root-cause team

and conducted an investigation with the contractor that identified that the actual root

,

cause was unknown; however, the most probable cause was crane operator error.

Five potential scenarios that involved misuse of the crane brake were identified by

the root cause team. The mechanical inspection of the crane did not identify any

material condition concerns.

,

The inspectors monitored the licensee response and noted that the proper

individuals were promptly contacted for investigation and that the entire area was

quickly quarantined for the investigation.

The licensee took several corrective actions to prevent recurrence. Actions included

the following: briefs of all craft personnel on the event and a special meeting with

crane operators discussing the circumstances and corrective actions resulting from

the load drop; a complete crane inspection, including a load test; a maintenance

program review; walkdowns of various rigging devices; and additional emphasis on

communications methods.

c.

C_onclusions

The inspectors concluded that the licensee responded appropriately, quarantined the

'

area and promptly performed a formal investigation.

Ill. Enaineerina

E1

Conduct of Engineering

E1.1

2B CV Pumo Fill and Vent Safety Evaluation 137551)

a.

insoection Scope

The inspectors reviewed several aspects of the 28 chemical and volume control (CV)

pump work conducted by the licensee in September 1997. The inspectors reviewed

the licensee's temporary procedure change to 2BVS 1.2.3.1-2, "ASME surveillance

requirements for centrifugal charging pump 2B," revision 15, the associated safety

evaluation screening, the UFSAR, and PIF B1997-03144.

b.

Observations and Findinas

On September 10,1997, a nuclear station operator (NSO) identified that a Byron

Operating Procedure (BOP) to fill and vent the 2B CV pump did not exist (see

Section 03.1). Due to the work on the pump mini-flow check valve, system

14

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-

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l

engin : ring h d mad) a 1:mporary change to th> routine CV pump ASME test to

-

v:nt the mini-flow lino. The ASME 1:st flow path was through the mini flow

. r: circulation lin]; th:r: fore, the liccnste conclud:d that p;rforming the ASME 1:st

would ensure that the mini flow line was filled and vented. A ternporary procedure

change was required to change the return flow path from the normal line up, which

was to the CV pump suction, to the top of the volume control tank (VCT).

System engineering performed a safety evaluation screening on September 10,

1997, for the proposed temporary procedure change and concluded that a safety

evaluation was not required. The screening stated that the reason for the

realignment of the retum path was "to avoid air that may possibly be in recirculation

line from being sent directly to suction of CV pumps. . . ." The screening noted that

the recirculation line would still be isolated on a safety injection signal and seal water

return would still have a flew path to the top of the VCT. The inspectors noted that

the recirculation line combined with the reactor coolant pump seal water return line

prior to entering the top of the VCT or the CV pump suction line. The inspectors

also noted that the Updated Final Safety Analysis Report (UFSAR) stated that the

seal water return lino was normally aligned to the suction of the CV pumps.

However, the NSO identified in a PlF that the screening did not consider the

potential introduction of oxygen into the gaseous waste processing system (GWPS).

,

Section 11.3.2.1 of the UFSAR stated the following:

"The gaseous waste process'.ng system (GWPS) processes hydrogen stripped

from the reactor coolant and nitrogen from the closed cover gas system. The

components connected to the GWPS are limited to those which contain no air or

aerated liquids in order to prevent the accumulation of oxygen in the system.

Further, the GWPS is maintained at a pressure above atmospheric to avoid

intrusion of air. . . . Hence, the GWPS will normally not contain oxygen and

special design precautions are taken in order to avoid unintentional intrusion of

oxygen."

The NSO noted that the VCT was a component connected to the GWPS and the

inspectors noted during a piping and instrumentation drawing (P&lD) review that the

VCT was vented to the GWPS.

The shift manager noted that the system engineer, a chemist, the unit supervisor,

and the shift manager determined that the potential addition of oxygen would not

affect the VCT hydrogen concentration and therefore was not a significant concern.

Thus, the shift manager concluded that no safety evaluation was required. Chemists

sampled the VCT gas following the venting activities and the sample showed 0.02

percent oxygen in the gas space. The inspectors discussed the conversation with

the system engineer. The engineer confirmed that the conversation occurred and

that the conclusion was there was not a significant concem.

The inspectors discussed the issue with members of station management. Initially,

the licensee believed that since the activity was a maintenance activity and not

routinely performed, the potential ado, bon of oxygen to the GWPS did not require a

safety evaluation. The licensee noted that if a modification or change in operating

procedure was planned that added a per.1anent or continuous addition of oxygen to

the GWPS, taen a safety evaluation would be required. The inspectors believed that

the maintenar :e activity not routinely performed required a safety evaluation. Later,

during additional discussions with licensed management, the licensee indicated that

if there had bet n a question concerning how much oxygen would be vented to the

VCT, a safety e 'aluation would have been required. The inspectors noted that the

licensee had not evaluated the design or licensing basis allowable amount of oxygen

in the GWPS, noi did the licensee have an estimate of how much oxygen would be

15

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_

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- - -

-

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add:d prior to conducting the pump VInting.

Titb 10 CFR Pcrt 50.59, Chang:s, tests and experim2nts, r;quir:d that th]

licensee maintain records of changes in the facility and of changes in procedures

made pursuant to 10 CFR 50.59, to the extent that the changes constituted changes

in the facility described in the safety analysis report or to the extent that they

constituted changes in procedures as described in the safety analysis report. The

records must include a written safety evaluation which provided the bases for the

determination that the change, test, or experiment did not involve an unreviewed

safety question. The Inspectors concluded that the failure to perform a written safety

evaluation for the potential addition of oxygen to the gaseous waste processing

system may be a violation of 10 CFR 50.59. This is an unresolved item pending

further NRC review (50 454/455 97022 03(DRP)).

c.

Conclusions

The inspectors concluded that the licensee had several opportunities to perform a

safety evalue" 7. An NSO identified the UFSAR section that referenced the GWPS

and requested a safety evaluation be performed. The inspectors noted that the

original safety evaluation screening was written to make a temporary procedure

change to avoid air that may possibly be in the recirculation line from being sent

directly to suction of CV pumps. The inspectors concluded that the screening failed

to evaluate allintegrated plant operations. Additionally, the temporary procedure

change was required to compensate for the lack of a standard operating procedure

to fill and vent the pump (see Section 03.1). This is an unresolved item pending

further NRC review.

E1.2

Ememency Core Coolina Vent Valve Not Vented (37551)

a.

Inspection Scopjlt

The inspectors reviewed the licensee's identification of two safety injection (SI)

valves that wore not included in the monthly emergency core cooling system (ECCS)

venting surveillance test, included was a review of SI, chemical and volume control

(CV), and residual heat removal (RH) drawings and valve line ups. A comparison of

ECCS vent valves, identified by the inspectors, to the monthly venting procedure,

1BOS 5.2.b 1, Revision 6, was also performed. Licensee event reports (LERs)

454/97-009 and 454/97-018 were reviewed along with the corrective actions resulting

from a previously identified ECCS venting violation, documented in NRC Inspection

Report No. 50-454/455 97009.

16

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b.

Observations and Findinas

C t October 23,1997, the licens:e id:ntifi;d that two v:nt valv:s wero not includ:d

in he monthly Unit 1 ECCS venting surveillance test. The inspectors noted that the

valves,1S1051 and 1S1052 (Sl pump to 1A/1D and 1B/1C hot leg vents, for A and B

train respectively) were not identified during previous immediate corrective actions

for a missed TS surveillance, in May 1997, the inspectors identified that 1RH027, an

RH vent valve, was not vented as required by TS. A pre-decisional enforcement

- conference was held on September 11,1997, to discuss several TS compliance

issues, including the failure to vent the ECCS systems appropriately. One example

was the fa9ure to include 1RH027 In the monthly venting surveillance test.

Discussions with the licensee indicated that site engineering was preparing a

modification to add hard pipe to several ECCS vent valves. The modification was to

route vented water to the floor drain system, enhancing the verting capabilities of the

system. An ECCS system engineer was assisting in the review and noted valves on

'

the list that he did not remember being included in the venting surveillance test.

Further research by the system engineer confirmed that 1S1051 and 1S1052 were not

in the venting procedure. TS 3.0.3 and 4.0.3 were entered for missed surveillance

testing and the venting completed after a temporary procedure change was

completed to 1BOS 5.2.b 1. No air or gas was identified.

'

The inspectors' ECCS drawing review identified that the isometries and the piping

and instrumentation drawings (P&lDs) clearly identified tne vent valves. The Si

system valve line up also clearly identified 1Sl051 and 1Sl052 as vent valves.

c.

Conclusions

The inspectors concluded system engineering identified that 1S1051 and 1S1052

were not included in the monthly venting surveillance during the corrective actions

following identification of 1RH027 not being included in tt > surveillance test.

E1.3 Material Handlina System in the Fuel Handlina Buildina (50001).

a,

inspection Scooe

.During the inspection period, the inspectors noted that the licensee had removed

mechanical stops on the Fuel Handling Building (FHB) crane. The inspectors review

included the following: Special Plant Procedures (SPP) 97125 and 97-136; portions

of safety evaluation 6H 97-0048; portions of calculation SG BYR 96153, " Material

Handling System;" TSs ; the Updated Final Safety Analysis (UFSAR); and NUREG 0612. " Control of Heavy Loads at Nuclear Power Plants."

b.

Observations and Findinas

The inspectors reviewed the licensee's plans for moving heavy loads (gre wer than

2,000 pounds) through the FHB into the Unit 1 containment. During the .uview, the

inspectors identified that the licensee designed and built a material handling system

. (MHS). The MHS consisted of existing rails that were next to one end of the spent

fuel pool (SFP), additional elevated rails for entering the containment buliding

through the equipment hatch, a cart, and a winch to pull the cart along the rails. The

cart included three significant features, rollers to move the cart along the rails

adjacent to the SFP, a_" lazy susan" to rotate the upper portion of the cart into

alignment with the equipment hatch, and an upper set of rollers that, when unpinned.

. allowed the load to be rolled along the elevated rails into containment.

17

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

The inspectors tsvi;w of the UFSAR indicat:d that two types of accid:nts in the FHB

!

!

w:ro analyz:d, a fu:1 handling accid:nt involving dropping a fuel cas:mbly, and a

I

sp:nt fu:1 cask drop accid:nt. The UFSAR succ:ssfully analyz:d the fu:1 handling

j

accident. The inspectors noted that a fuel cask drop into the SFP was not analyzed.

4

Detailed explanation was provided in the UFSAR to demonstrate that a cask would

]

not drop into the SFP.

Heavy loads, as much as 20 to 30 tons, were scheduled to be moved along the

'

entire width of the spent fuel pool on the MHS cart The inspectors were concerned

that a new accident not previously analyzed in the UFSAR had been created,

specifically, either a seismic event or load handling accident potentially causing the

1

load on the cart to fallinto the SFP. The inspectors review of the safety evaluation

noted that the licensee planned to tether the heavy loads with the FHB crane while

the load was moved along the width of the spent fuel pool. Based on the tether and

the safety margin of greater than 10:1 for the crane's wire rope, the licensee

,

determined that a creditable accident was not possible.

!

Additional actions taken by the licensee included the construction of a large platform

that was placed over the end of the SFP, creating an additional barrier to the SFP

and a walkway approximately 5 feet wide. Spent fuel was also removed from the

two storags racks in the SFP immediately adjacent to the wall that supported the

MHS, The d.ensee also noted that, although the FHB crane was not seismically

4

qualified to rated capacity, it was seismically qualified to 20 percent of rated capacity,

i

The inspectors considered the licensee's actions compensatory measures for the

,

postulated seismic event or load handling accident. The inspectors considered the

issues a potential violation of 10 CFR 50.59, " Changes, tests, and experiments,"

.

which stated that a licensee may make changes to the facility as described in the

!

i

UFSAR without prior NRC approval unless the change involves an unreviewed

i

safety question (USQ). An unreviewed safety question included the possibility that

j

an accident or malfunction of a different type than any evaluated previously in the

f

UFSAR may be created. The inspectors concluded that a heavy load drop of this

type into the SFP was not previously evaluated in the UFSAR. The inspectors

'

!

considered the potential for an MHS USQ an unresolved item pending further NRC

j

review (50-454/455 97022 04(DRP)).

4

c.

Conclusions

e

i

The inspectors concluded that although the licensee's actions appeared appropriate,

the potential for a USQ existed; therefore, further NRC review was required and an

unresolved item opened to track the issue.

4

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E8

Misc:llane:us Engineering issu:s

E8.1 - (Closed) LER 50-454/97 018: Missed ECCS Vcnting Surveillance dua to In:ffective

Supervisory Methods. The inspectors reviewed the event and Section E1.2

documents the inspectors' findings. The inspectors concluded, after a review of the

corrective actions identified in the LER, that the actions were appropriate. This LER

is closed.

IV. Plant Supp_oA

R1

Radlological Protection and Chemistry (RP&C) Controls

R1.1

Radioloalcal Work Practices

a.

inspection Scope (71750)

The inspectors routinely inspected the status and posting of radiologically controlled

areas,

b.

Observatipns and Findinas

During an inspection in the spent fuel pool area of the fuel handling building

(elevation 420) on November 24,1997, the inspectors observed individuals moving

various pieces of equipment using an overhead hoist that could be trolleyed along an

overhead track. The equipment was trolleyed over a posted contamination area that

was directly below the path of the hoist. The inspectors noted that while the

individuals trolleyed the load over the contamination area, it contacted several pieces

of equipment stored within. Radiation protection personnel noted this, stopped the

movement, and took contamination surveys of both the load being trolleyed and the

equipment it had contacted. No loose contamination had been spread outside the

posted area. During subsequent movement of equipment over the same

contar-Mation area, the inspectors noted that the individuals allowed the hoist's

chainfalls to drag across the contamination area posting knocking it down Radiation

protection personnel responded immediately to re erect the posting. During the next

movement of equipment, the inspectors again noted that individuals allowed the

holsts chainfalls to drag across the contamination area posting knocking it down.

c.

Conclusions

The inspectors concluded that problems observed with the movement of equipment

within the spent fuel pool area of the fuel handling building demonstrated poor

radiological work practices and a disregard for contamination area postings by

personnel conducting the work, An RP technician took prompt, appropriate actions.

)

19

V. Manaaement Meetinas

X1

Exit Coeting Summar)

The inspectors presented the inspection results to members of licensee management

at the conclusion of the inspection on December 1,1997. The licensee

acknowledged the findings presented. The inspectors asked the licensee whether

any materials examined during the inspection should be considered proprietary. No

,

proprietary information was identified,

,

9

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PARTIAL LIST OF PERSONS CONTACTED

Licensee

'

K. Kofron, Byron Station Manager

J. Bauer, Health Physics Supervisor

D. Brindle, Regulatory Assurance Supervisor

E. Campbell, Maintenance Superintendent

T. Gierich, Operations Manager

B. Israel, Site Quality Verification Supervisor

T. Schuster, Manager of Quality & Safety Assessment

M. Snow, Work Control Superintendent

- D. Wozniak, Eng!neering Manager

=

,

21

INSPECTION PROCEDURES USED

IP 37551:

Onsito Engin:cring

IP 50001:

Steam Generator Replacement !nspection

IP 61726:

Surveillance Observations

IP 62707:

Maintenance Observations

IP 71707:

Plant Operations

IP 71750:

Plant Support

IP 81070:

Access Control - Personnel

IP 92700:

Onsite Follow up of Written Reports of Non routine Events at Power Reactor

Facilities

IP 92901:

Follow up - Plant Operations

IP 92902f

Follow-up - Maintenance

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

50-454/455-97022-01

VIO

Inadequate procedure for CV pump fill and vent.

50-454-97022-02

VIO

Failure to follow procedure NSWP-A-03

50-454/455 97022-03

URI

Potential failure to perform a written safety evaluation for

the potential addition of oxygea to the gaseous waste

processing system.

50-454/455-97022-04

URI

Potential unreviewed safety question for operation of a

material handling system adjacent to the spent fuel pool,

Closed

50-455 97020-02

IFl.

2B CV Pump Ma_intenance Window,

50-454 97-018

LER

Missed ECCS Venting Surveillance due to ineffective

Supervisory Methods

.=_

22

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LIST OF ACRONYMS USED

ASMe

Arderican S:c!:ty of ;, ..;hanical Engin rs

BAP

Byron Administrative Procedure

4

BEP

Byron Emergency Procedure

BFP.

Byron Fuel Handling Procedure

,

BMP

Byron Mechanical Maintenance Procedure

BOP

Byron Operating Procedure

BRP

Byron Radiation Protection Procedure

'

CV

Chemical and Volume Control

DG

Diesel Generator

DRo

Division of Reactor Projects

,

DRS

Division of Reactor Safety

ECCS

Emergency Core Cooling System

ECN

Equipment Component Number

FHB

Fuel Handling Building

4

'

FME

Foreign Material Exclusion

GWPS

Gaseous Waste Processing System

HLA

Heightened Level of Awareness

i

LCO

Limiting Condition for Operation

LCOAR Limiting Condition for Operation Action Requirement

-LER

Licensee Event Report

'

!

MHS

Material Handling System

NSO

Nuclear Station Operator

4

NSWP

Nuclear Station Work Procedure

.

OOS

Out-of-Service

)

OSR

Onsite Review

PDR

Public Document Room

P&lD

Piping and Instrumentation Drawing

PIF

Problem Identification Form

PSIG

Pounds par Square Inch Gage

RCS.

Reactor Coolant System

RH

Res! dual Heat Removal

SER

Security Event Report

,

.SFP

Spent Fuel Pool

SGR

Steam Generator Replacement

-

SI-

Safety injection

SPP

Special Plant Procedure

SRO

Senior Reactor Operator

'SSPS

Solid State Protection System

SX

Essential Service Water System

TS

Technical Specification

UFSAR Updated Final Safety Analysis Report

USQ

Unreviewed. Safety Question

VCT

Volume Control Tank

'

WR

Work Request

4

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