ML20024H204

LER 91-005-01:on 900817,preoutage Mod Work Initiated W/O Proper Operability Review Due to Programmatic Deficiencies. Daily Const Work Authorization Sheet formalized.W/910522 Ltr

ML20024H204
Person / Time
Site:	Byron
Issue date:	05/22/1991
From:	Bowers D, Gierich T, Pleniewicz R COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BYRON-91-0381, BYRON-91-381, LER-91-005-01, LER-91-5-1, NUDOCS 9105300124
Download: ML20024H204 (7)

Text

_ _ _ _ _

N C:mm:nw:alth Edis:n /

/ Byron Nuclear Station

, C- 4450 North German Church Road Byron,litinois 61010 4

May 22, 1991 Ltts BYRQ4 91-0381 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Dear Sir The enclosed supplemental Licensee Event Report from Byron Generating Station is being transmitted to you in accordance with the requirernents of 10CFR50.73(a)(2)(1)(B) and 10CFR50.73(a)(2)(11)(D).

This report is number 90-005 Docket No. 50-455.

Sincerely, sy '

& R.~ Plenlewicz

! (Ql???w J Station Manager Byron Nuclear Power ation RP/DK/mw Enclor.ure : Licencee Event Report No.90-005 cc A. Dert Davis, NRC Region III Administrator W. Kropp, NRC Senior Resident Inspector INPO Record Center CECO Distribution List (0753R/0088R) 9105300124 910522 0 gen noOcxOsOOgs g zt 0 , . . .

6 .

LICENSEE [ VENT REPORT (LER)

Fern Ret liq _ j e ' facility Name (1) Docket Number (2) _PageJ11 Byttn4_ Vail 2 JjJLOLOLOLal3L5 J_}_otl_0M_

T

• s' ( 4 ) pre-Outage Modification work initiated Without Proper Operability Review Due to Programatic Deficiencies 3enLDate_151 LL!L!fu!&erJtl __

_R eparL0 ate _11.L_. Other_tittiliticilnrnireLIBl__ l Month Day Year Year /// Sequential /// Revision Month Day Year __ fittility_1!allits_ _Datittlymberls i l jff u1Jiuder__ ul _14vmbet ___ _ _ _ _

NONE .

JLSLDLOLOLJ1 l LIL IJLLlL 9 10 DJJ.J5 OJ 1 OJJ_lLL91 1 DL1LOL.0LOLJ_J_

THIS REPORT !$ SUBMITTED PUR$UANT TO THE REQUIREMENi$ OF 10CFR OPRM

'# N E "U8 - -

MODE (9) 1 _._ 20.402(b) _ 20.405(c) _ 50.73(a)(2)(iv) __ 73.71(b)

POWER ___ 20.405(a)(1)(1) ___ 50.36(c)(1) ___. 50.7U s(2)(v) __ 73.71(c)

LEVEL 20.405(a)(1)(ii) 50.36(c)(2) 50.73(a)(2)(vii) Other (specif y l4 l9 i10) __ 20.405(a)(1)(tii) l_ 50.73(a)(2)(i) _ 50.73(a)(2)(viii)(A) in Abstract

_ 20.405(a)(1)(iv) _)L 50.73(a)(2)(ti) _ 50.73(a)(2)(vill)(B) below and in

___ 20.405(a)(1)(v) __ 50.73(a)(2)(iii) _ 50.73(a)(2)(x) Te=t)

L IC E!45 C LC ONI AC Lf 0Rltil LLI!Lllzl _.

Name D. Bowers, Maintenance Staff Ext. 2913 _lELEPJQNE 1NMBER _,_ _._

AREA CODE f Jier.ls1LJorLPlanairs_iuserriist_.___Lstul010_

t _JJ__LLi_ zJLtd._L-LSL4L4]J .

CQtLPLLILONLLilitl0JLEACtLLONONLtiLLA1LURLDISCRIELDJfL1H13_RLPQJti (13) l CAUSE SYSTEM COMPONENT MANUFAC- REPORTABLE CAUSE SYSTEM COMPONENT MANUFAC. REPORTABLE /

TURER _10__ttp1DL TURER. Jo NpRDS /

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1 i Ll_ .! I i 1 1 1I I LJ f I LL _L_ .I ! !

SVEELEMEfflALREPORT EXpfClLD_ila) Expected tktLL0eyJJeat Submission J.Y e LI LLy e s ulompl e t ellEECI EDJVDM13510L D Al[1 }JQ

' ' (' L__LtLL ABSTRACT (Limit to 1400 spar.es, i.e approximately fif teen single-space typewritten lines) (16)

On August 17, 1990 at approximately 1500, with Unit 2 in Mode I at 49% power, it was discovered that supports on the 2A Auxiliary Feedwater pump (AT)(BA) piping had been worked on without Operating Department concurrence.

Limiting Condition for Operation Action Requirement 2B05 4.10-ta was imediately entered and an Engineering Evaluation was initiated. The current condition of the system was found acceptable and the LCOAR was exited.

On 8-23-90, during a walkdown to verify assumptions made in detereining operability during the support work, l scaffolding was discovered supported by the AF line in question. The scaffolding was immediately removed. The load bearing nuts on one of the af fected supports were also found loose at this time. They were promptly tightened and tested.

The cause of the supports being affected was that a contrscted modification foreman did not request an out-of-service prior to performing work on entsting operational equipment. The scaf folding was improperly ottached to the system due to a lack of contractor awareness of the impact on the system. The loose fasteners are suspected to be a result of the work sequence. The root cause of these events was programmatic deficiencies in parts of the modification program.

I

As preventive action, the Daily Construction Work Authorization Sheet has been formallaed and will specif y the i scope of the work step by step during non-outage periods. The contractor scaffolding procedure has been revised to include Shift Engineer review. In addition, all erected scaffolding was inspected. The contractor has also instituted a new policy to walkdown all work performed for impact on other components.

Tho event is reportable per 10CFR50.73(a)(2)(1)(B) and 10CFR50.73(a)(2)(ii)(B) for exceeding the LC0AR for the 2A AF pump and exceeding design basis criteria during the work process.

(0753R/0088R-2) l

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L IC W5 L LD LNLECf0RL LL WLLf.ALCON 11NAll0M lormlevl0-FACILITY NAME (1) DOCKET NUMBER (2) _LELWMDLIL(6) ___

_ Jagt(3L Year /// Sequential /j/j

/ Revision f

• LlL, _.lN@e r /// t'J6tL

_ QrroaJ!aLL 2 _LljLjjLljLl_QJ_41_5L5JL1_0 -

ILLoJ_s_ ._ _0J_L aJL _0L DJL TEXT Energy Industry Identification System (E!!S) codes are identified in the text as (XK)

A. PLANLCOND11MSlR10L10_GINI:

Event Date/ lime .,l 90__/ _ JSQQ _ _

Unit 1 MODE 1 - lDutr_DP.tIAllDA_ _ 4x power _100L RCS (AB) Temperature / pressure JJorraLDptrating.

Uni c 2 MODE . L_ - torer_0peration Rx power _4J L RCS (AB) Temperature / pressure Narm4LQpetaling_.

B. DEEhlE110tLOLGINI:

On August 17, b90, at approximately 1500, the Nuclear Regulatory Comission Resident inspector made an inquiry to the Station concerning a removed strut from the Essential Service (SX)[BI) suction pipe to the 2A Auxiliary Feedwater (AF)[BA) pump. The Technical Staf f System Engineer (noh-licensed) determined during a walkdown that a support appeared to have been re/ *ced and notified the Shift Control Room Engineer (SCRE, Senior Reactor Operator). The SCRE determined that control room personnel were not aware of work in progress on the AF system and had therefore not entered a Technical Specification Limiting Condition for Operation Action kequirement (LCOM). lhe ensuing investigation discovered other concerns as detailed belcw.

Uith Unit 2's second refveling outage approaching (*o begin August 31, 1990), Engineering and Construction (ENC) and the Station's modifica' n contractor (William A. pope Company Joint '!enture) completed a 1.re-modification installers walk in f or modification M6-2-88-060. The scope of the modification was to install a flushing 1;ne with associ ted isolation valves and supports from the 2AF01pA SK suction line (2SX25AN 6") to the B train SX return header line. In addition, existing supports were to be modified to suppert the additional weight of the new pipe. On 8-6-90 the pope ,oreman received permission under Nuclear Work Request 073629 to inste!1 SX piping and supports, build scaffolds, and remove insulation" as described on a hand written, infsrmal Daily Work Authorization Sheet. The Description of Work to be Done" field clearly stated "no tie-in to existing piping until 02R02 out-of-service". The Shift foreman (5F, Senior Reactor Operator) questioned the Pope Foreman on the scope of the work, concerned that it was on a saf ety-related system. The pope Foreman stated that there would be no system interaction, only work on new piping and compcrent supports. Delieving that the scope of the werk was to begin installation of equipment to th point of interaction with the system, the SF granted permissio to begin the wura. The scaffolding was erected on the same day.

On 8-7-90, the workers edded stiffener plates te U-bolt support H-2AF03032G. U-bolt removal was not regulrtd to perform this change. On 8-8-90, the rod on the east end of trapeze support H-2AF03021R was increased in size from 5/8" diameter to 3/4" diameter. The support was tee.porarily removed to perform this change. On 8-9-90, support H-2AF03013R was increased in size from Grinnell B to C, and temporarily removed to support the activity. On each day, the pope Foreman signed in with the Shift Foreman using the same Daily Work Authorization Sheet since it still applied to the work in progress. The Shift Foreman still believed the work was not involving the operatienal systems. Each activity was started and completed on the af oremen'.ioned dates prior to comencin: the next activity.

10753R/0088R-3)

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FACIL!iY NAME (1) DOCKET NUMBER (2) _LER_ HUT ER J ) Pa.sel 31 Year Sequential Revision Hyder .

. Nymhet

_0nnJrdL2 _oJ 5J_oJ_0J_LLdisL5 _9J 3_.___010J_L - 0Ii 0Ju3L0A TEXT Energy Industry Identification Syste.n (E!IS) codes are identified in the text as [XX)

B. DE$ERIPJ10N 0f EYIHl: (continued):

s When the SCRE was notified that work had b 1 performed on the system, the pump was immediately dec'ared inoperable pending a review of the work completed to date. LC0AR 200$ 4.10-12 was entered at 1500 on 8-17-90. 2BvS 4.10-6.2, ' Post Maintenance Visual Examination (VT3/4) of Safety Related Component Supports " was satisf actorily completed for all three supports and reviewed at 1837 on 8-17 no Construction Quality Control verified installation and performed dimensional inspections on the supports after the work was Completed. An Engineering Evaluation and 10CFR50.59 Safety E aluation determintd that the current condition of the revised supports did not adversely af fect operability since the changes increased the load capacity of the supports and did not impose any loads not previously considered. An On-Site Review concluded that both the AF and SX systems sere operable and the LC0AR was exited at 2010 on 8-17-90.

The Architect / Engineer (Sargent & Lundy) began calculations to determine the operability of the system during the modification process. To verify assumptions made in tne calculations which were yielding suspect results, the Engineers performed a walkdown of the equipment. On 8-23-90 at 1420, it was discovered that the scaffolding that had been erected on 8-6-90 was being supported from safety related line 2AF03AA-6" and two pipe supports (2pSL AF051-H89E-3 and 2PSL-AF051-H89E-4). The scaffolding was immediately remosed. At 1500, the load bearing nuts on component support N2AF03021R were found loose.

LC0AR 2005 4.10-ta was entered. The support was promptly tightened and tested via NWR 878922, The LC0AR was exited at 2138 on 8-23-90.

On August 30, 1990, ENC re(elved the results of Sargent & Lundy's evaluation 04 the pipe upport installation sequence and scaffolding loads. The results indicated that the normal operating loads were within code allowable values. However, code allowable values were exceeded for design basi

• load combinations (seismic) during the time supports M-2AF03021R and M-2AF03019R were individually 3oved.

Therefore, this event is reportable pursuant to 10CFR50.73(a)(2)(1)(B) as a result of operation prohibited by Technical Specifications since the AF pump should have been declared inoperable on 6-8.90 and returned to an operable status within 72 hors. In addition, per 10CFR50.73(a)(2)(ii)(B) this event is reportable due to operation in a condition outside the design basis of the plant.

C. [AVSE_0LIYEtLT.:

The cause of the supports being removed was that the pope Foreman did not request an Out-of-Service prior to performing work on existing component supports of an operational system. Per BAP 330-1, " Station Equipment Out-oC Service Procedure," an operability review would have recognized the proper time restraints for rendering the AF system inoperable. The contractor foreman incorrectly assumed that the existing supports had no ef fect on the operating system pressure boundary and therefore did not require an Out-cf-Service.

The cause of the scaffolding being attac M to a safety related line and to pipe supports was due to a lark of contractor compliance with the pope scaffold procedure which prohloited attachment of scaffold to piping without prior authorization.

The cause of the loose load bearing outs on support N 2AF03021R is postulated to be due to the subsequent l replacement of support M.-2AF03019R. Tt a rod on M-2AF03021F was replaced and inspected on 8-8-90.

N2AF03019R was replaced and inspected on 8-9-90. Howevar, the effect of support M-2AF03019R replacement on the rest of the equipment on t',at line was not considered and therefore not inspected. It is postulated that during the expansion of H-2AF03019R's support pins during installation, the fasteners on N2AF03021R were de-tensioned.

(0753R/0088R-4)

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_.-_m_ - ._~__ LI C EN5 L LlYLN LlLPELI LL!O _l LALCOMi l tNAl lQ.N _ form.Rev L 0_

DOCKET NUMBER (2) _lLLtNtf LfL_(6) b ge _llL__

FACILITY NAME (1)

Year Sequential //p/ 7j Revision l __NVTktr LLL __Mvmber_

_Ennd!12 0 1 5 I Q _{ 0 1 0 1 4 LSL1 910 -

0 I JLL5. - 0Ii 0 14 _01_ .0 lt TEYT Energy Industry Identification System (Ells) codes are identified in the text as (XX)

C. CAUSE OF _LYLNJ: (continued)

The root cause of these events was programmatic deficiencies in parts of the modification program related to coordination of work.

D. 1&ELTI ANAL 1$11:

There were no adverse safety consequences from this event. Based on Sargent & Lundy's evaluation, the l calculated piping stresses and associated support, structural and equipment stresses resulting from the normal nperating loads due to the installation sequence were within code allowable values. However, based on the results of the piping stress analysis, design basis load combinations exceeded code allowable values when the two supports were removed. Since the situation was temporary and no seismic event occurred during that time, no over stresses occurred.

The 2A AF pump would have been capable of performing its intended function during a normal operating event based on Sargent & Lundy's evaluation.

Had a seismic event occurred in wh'ch the 2A AF pump was rendered inoperable due to over stresses in the pipe, the 20 AF pumn would have been available to supply the "equired As flo.4 to the steam generators, The 2P AF pump was available throughout this event.

E. (QRELCILYLACIl0HS:

The Daily Construction Work Authoritation sheet was formalized by Operating and ENC. This sheet requires cot pleting a Daily Work Description Sheet which provides detailed inf ormation to the Shif t Engineer concerning the scope and requirements necessary to perform the work during non-outage periods. This sheet, in conjunction with a ccpy of the Nuclear Work Request and the Road Map traveler (specifies what work is to be done step by step), allows the Shif t Engineer (or Designee) to address operability concerns.

Additionally, ENC concurrence is now obtained prior to shift review.

On August 20, 1990, the Unit 2 Operating Engineer informed the Operating Department of the new pre-outage work authorization policy.

The Maintenance Modification Contractor's Scaffold Procedure (JVSCAF-1) has been revised to include a requirement that Operating perform a pre-job review and sign final authorization f or scaf fold use.

An Awareness Day meeting between the Maintenance Modification Contractor, ENC, and Station personnel was held on August 25, 1990 Among the items discussed were the Station's approach to maintenance activities, operability concerns, safety, engineering interaction, and the need for enhanced communications with the Operating Department. All work activities in progress were inspected by a team consist.ing of representatives from ENC, Pope and Station Management (such as Technical Staff, Operating and/nr Maintenance). The teams had a current copy of the Pope Scaffold Log Book and used it to identify, inspect and retag all existing Pope scaffolds with the revised scaffold inspectior, tags, and a copy was given to the Shift Engincer's office. All discrepant items identified during the inspections hav- been torrected.

(0753R/0088R-5)

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. LICf35LLLYENT REPORT QLR) TEXL(9N111NAll0N FDrr_ Rey 2.JL FAElt!TY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PugW)

Year y/7 Sequential g

/ Revision

//L _liuTkt r_.-_ /{H Nu"btL

. Byrort,_urtitl_ _0_L51LL010_L4L5L1_9 L0- __ _0_ Lo. L1_ _- _0_ l_ L 0.J L .or ojb TEXT Energy Industry Identification System (Ells) codes are identified in the text as (XX]

E. COPS K ilV L ACiloNS (continued):

To prevent undetected adverse effects on other system components after work performed, Pope has instituted a new Production Supervisor Walkdown policy that now includes walkdown requirement of all work performed.

The Pope Quality Control Department is also required to participate in the walkdown of all safety related, code related, and regulatory related work in order to identify any loose, missing or damaged equipment associated with the project.

The following changes to the Modification Program are being tracked by AIR's 455-225-90-299, 455-225-90-300 and 455-225-90-301.

To facilitate initial modification work package review and approval, the work analyst, with input from both Tech Staf f and a licensed Operations person, will write a Sumary of Installation Steps worksheet, including any operational steps, i .e. , Take equipment Out-of-Service, enter LC0AR, etc. The level of detail contained in the summary will be sufficient to address operational and reliability concerns. This sumary worksheet will generall; be done prior to detailed work package development.

The installation sumary worksheet will be reviewed, comented on, and approved by an SRO and Tech Staf f.

This approved worksheet will be used by the Work Analyst as a tool to properly separate work packages and develop the initial work instructions. 1 F inal work package approval and subsequent revisions will be controlled by the Station's Maintenance / Modification f rocedure (MMP) process per BAP 400-11. This approval process will allow for Operations department verifica lon that all operation concerns outlined in the worksheets have been properly addressed.

On simple modliications the wcrksheet requirement may be waived by the applicable Operbting Engineer.

Whether or not the worksheet is used, final operational review will be accomplished via tt.e MMP approval process.

All modification work packages which have Pre Out-of-Service /LC0AR work will be broken dnwn into sub-packages clearly delineating Pre Out-of-Service /LC0AR work f rom Post Out-of-Service /LC0AR work.

All modification work packages will be reviewed and approved by an Operating Engineer or designee. The Operating Engineer will assure that Pre Out-of-Service /;C0AR work is clearly defined and segregated. In addition the Operating Engineer may at his discretion insert " Operating Hold Points" or request that work steps be added to the Road Map Traveler (step by step work instructions) to require operating concurrence prior to work proceeoing. This review and approval will be accomplished by the addition of an SR0 sigiature on the Maintenance / Modification Procedure (MMF) fc1 , prior to the quality reviews. These requirements will be specified in BAP 400-11.

Modification Work Packages which have Pre Out-of-Service /LC0AR work will be scheduled and statused on the routine or outage work schedule (as applicable) on a sub-package level.

(0753R/0088R-6)

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- LlCINS ELLY LNLB LP_0RLI LERLll&L10H11NVAIl0N DOCKET NUMBER (2) __LLLtfJtEER (6) pad d ll FACILITY NAME (1)

Year g Sequential dl _huTk tL_

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L{il Revision BumbtL

_.QJunjalL2 0 l_LLa_L9J_LL4LIL5W_0_ __LLO 1 s -

0_11 DJL_qr tit TEXT Energy Industry Identification System (E!!S) codes are identified in the text as [XX)

F. 11LY10V53CCVRRLitCLil There has been one previous similar occurrence of a contracted maintenance crew operating outside the scope of work authorization. The crew stroked a valve without clearly receiving permission from Operating.

Corrective actions did not apply to this event.

NVmbsr lillt 87-012 (Decket 454) Two trains of safety related component cooling inoperable due to loss of water inventory caused by personnel error.

G. COMPDNENLIAILVRLQAIA:

Component failure dlJ not initiate this event nor did component failure result from this event.

(0753R/0088R-7)

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