IR 05000454/1996013

Insp Repts 50-454/96-13 & 50-455/96-13 on 961216-970310. Violation Noted.Major Areas Inspected:Plant Support

ML20137K885
Person / Time
Site:	Byron
Issue date:	03/31/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137J710	List: ML20137J705 ML20137K846 ML20137K885
References
50-454-96-13, 50-455-96-13, NUDOCS 9704070118
Download: ML20137K885 (7)

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' U. S. NUCLEAR REGULATORY COMMISSION REGION lil Docket Nos.: 50-454; 50-455 License Nos.: NPF-37; NPF-66

. Report No.: 50-454/96013(DRS); 50-455/96013(DRS)

Licensee: Commonwealth Edison Company Facility; Byron Nuclear Generating Station, Units 1 & 2

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Location: 4448 North German Church Road i Byron, Illinois 61010-9750

Dates: December 16-17,23, January 9,29 30, February 4-5,20 and March 10,1997 4 Inspectors: J. H. Neisler, Reacter inspector

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D. Schrum, Reactor inspector (January 29-30, 1997)

Approved by: R. N. Gardner, Chief Engineering Specialists Branch 2 Division of Reactor Safety

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9704070118 970331 PDR ADOCK 05000454 0 PDR ,

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Report Details t

, IV. Plant Suncort F1 Control of Fire Protection Activities

F General Comments  !

Using inspection Procedure 40500, the inspector evaluated the effectiveness of the

- iicensee's controls in identifying and correcting deficiencies in the plant's fire protection system. The evaluation included over 260 Problem Identification Forms {

(PlFs) associated with the Byron fire prctection system that had been initiated ,

during 1995 and the first 11 months of 1996. The number of PlFs issued during ,

this period was an indication of the plant staff's diligence in identifying deficiencie l The inspectors considered this a strength. However, the inspectors noted several '

instances where inadequate or lack of corrective actions resulted in repetitive PlFs on the same type of issue F1.2 Confiauration Control Insoection Scooe (40500)

The inspectors reviewed PIFs relative to configuration control deficiencies that had been documented during the past 22 months, in addition, the inspector interviewed cognizant licensoo personne Observations and Findinas l

During the review of fire protection PIFs, the inspectors noted that two PlFs had I identified mispositioned valves in the fire protection syste j PlF 454-201-96-1973, November 23,1996: During performance of the monthly .

fire protection valve line up, two valves, OFP248 and OFP033, were identified as j not being in their required position. The valves had been closed in support of 1 another surveillance that had been suspended for lack of manpower. The valves had not been restored to their proper position when the original surveillance was suspended. It was not known how long the valves had been in the incorrect configuratio PlF 454-201-96-1990. November 26,1Jjl: An operator found two fire protection I valvos that were not in their required position. It was subsequently determined that the valves were part of a semi-annual surveillance that was suspended with the valves lef t in the as-left surveillance positio The inspectors' reviews of fire protection system drawings and discussions with j the Byron Fire Marshal determined that no portion of the fire protection system was inoperable as a result of mispositioned valves. The mispositioned valves and loss of configuration appeared to be the result of the licensee's practice of suspending an  ;

in-process surveillance procedure due to other priorities or lack of manpower while j leaving the system in the as-left surveillance configuration, then beginning another ,

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f surveillance before completing the original. The persons performing the second surveillance then originated a PlF identifying the loss of system configuratio Licensee persnnnel stated that this practice did not occur during safety-related surveillance Conclusions The inspectors concluded that none of the above examples resulted in loss of system operability. However, the licensee's established practice of allowing fire protection valves to remain in the as-left surveillance position for indefinite periods indicated a weakness in management's control of fire protection surveillance F1.3 Reactor Coolant Pumo (RCP) Oil Collection System Inspection Scone The inspectors reviewed PlFs, operability assessments, fire analysis report, system drawings, and interviewed licensee person' riel relative to the Byron Reactor Coolant Pump Oil Collection System, Observations and Findinas PiF 454 200-96-0032, dated June 24,1996, identified that all potential oil leaks on the reactor coolant pumps did not have drip pans to collect and route the oil to a (

safe collection point as required by 10 CFR 50, Appendix The inspectors reviewed Byron Operability Assessment 96-025, dated June 25, 1996, and Byron RCP Oil Collection System Fire Protection Evaluation, dated June 24,1996. The licensee's evaluation states, " Contrary to Byron's Fire Protection, Sections 3.7.G and AS.7.lli.0, all potential oil leakage points are not provided with pans to collect drips and seepage. Specifically, there are two bolted flanges and two drain plugs associated with the oil cooler on each RCP that were not initially provided with drip pans." The licensee's evaluation also states,

" Appendix R to Part 50 of Title 10 of the Code of Federal Regulations requires the installation of an oil collection system to collect oil front all potential pressurized and unpressurized leakage sites." However, the licensee determined it was acceptable to operate with this conditio CFR 50, Appendix R, Section lil, O, requires that RCP lube oil collecting systems shall be capable of collecting luba oil from all potential pressurized and unpressurized leakage sites in the RCP lube oil system NUREG-0876, Safety Evaluation Report, Supplerr at No. 5, pages 9-17, closed an NRC unresolved issue identified in the Safety Evaluation Report regarding the provision of an oil collection system for the RCPs. This was based on the licensee's commitments in the fire protection report and letter dated August 20, 1984, to install an oil collection system capable of collecting oil from all potential pressurized and unpressurized leakage site __ _ _ _ -

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The Byron Fire Protection Report, pages 3.7-3 and A5.7-35,36, stated that the RCP lube oilleakage collection system complied with NRC and Appendix R requirements. PlF 454 200-96-0032 identified that the licensee was not in full compliance.

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As corrective action to PlF 454-200-96-0032, the licensee installed additional drip pans under the bolted flanges and drain plugs and lengthened one drain pan. Work had been completed on both unit . Conclusions The licensee identified this issue and took appropriate corrective action. An Operability Assessment was completed on July 25,1996, that documented continued operability of both units. However, the licensee was not in compliance with 10 CFR 50, Appendix R, Section O requirements since plant construction in addition, the licensee failed to notify the NRC, pursuant to 10 CFR 50.73, that this condition was outside the Byron design basis. The licensee stated that the RCP oil collection system was not outside the Byron design basis and therefore was not i reportable. This issue is unresolved (50-454/455/96013-01(DRS)) pending review of the licensce's requested response to this issu '

F1.4 OC HoM Points Insoection Scope The inspectors reviewed PlFs relating to work performed on the fire protection system to ascertain whether quality controls were effective, Observations and Findinas The inspectors reviewed six PlFs detailing missed quality control (OC) hold point Hold points are steps within a work procedure or work order past which the activity cannot proceed until that step has been performed. The missed hold points were mostly OC cleanliness inspections on components prior to maintenance closing the !

component after work had been completed. The licensee's corrective action and closure of each of the missed hold points appeared to be appropriat l

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The licensee had developed a program to reduce or eliminate missed OC hold points during maintenance activities. The program tracks missed hold points and initiates

] appropriate corrective action, o Conclusions j

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The inspectors concluded that the licensee had appropriately addressed the missed ;

QC hold points and that the program to eliminate or reduce the missed hold points '

reviewed during this inspection should be effectiv I

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F1.5 Recetitive Deficiencies identified by PIF Insoection Scoce The inspectors reviewed PIFs that were repetitive in that they identified the same type of deficiencies. The inspectors discussed these repetitive PlFs with licensee representative Observations and Findinas ,

I The inspectors noted instances where action to correct a fire protection deficiency 1 identified by a PIF had not been effective in preventing the recurrence of the same l type deficiency. Each deficiency identified was corrected without fully establishing the reason for the deficient condition or providing effective measures to prevent recurrence. All the repetitive deficiencies appeared to result from personnel errors and inattention to detai I Conclusions The licensee identified and promptly corrected each deficiency described in the I PlFs. However, the repetitive occurrences indicate a need for improvement in the licensee's root cause determination and corrective action processe j F1.6 Freezina Pioes l J

1 Insnection Scone The inspectors reviewed PlFs documenting frozen fire protection pipes and discussed freeze protection for plant components with cognizant licensee personne Observations and Findinas During the review of PlFs documenting fire protection issues, the inspectors noted four instances in the winter of 1995/1996 when fire protection system piping had frozen as a result of open exterior doors or louvers which cxposed the pipes to subfreezing outside temperatures. Two of the frozen pipe occurrences were due to mechanical prcblems with closure equipment on the exterior openings. However, the licensee did not apply compensatory measures to prevent pipe freezing. In response to the inspectors' queries, licensee representatives stated that there were no procedures or directives controlling the length of time an exterior opening could remain open during cold weathe On January 17,1997, an equipment attendant found the north entrance door to the circulating water pump house propped open which resulted in all the fire protection '

instruments on panel OPL 52J freezing. In addition, this resulted in the loss of main control board indication for the fire protection header pressure. Finally, it resulted in fire pump OA and the jockey pump being inoperable. Corrective action, as stated by the operations manager, was to fire the contractor worker who propped the door

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, 10 CFR 50, Appendix B, Criterion XVI, requires that in the case of significant

conditions adverse to quality, measures shall be estab!ished to assure the cause of 1- the conditions is determined and corrective action taken to preclude repetitio Conclusions Licensee management was not effective in preventing repetitive freezing and loss of

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equipment during cold weather. Failure to provide effective corrective action

continued to result in frozen, inoperable fire protection cquipment. This is a i violation of 10 CFR Part 50, Appendix B, Criterion XVI (50-454/455/96013-

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02(DRS)).

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V. Manaaement Meetinas l XI Exit Meeting Summary

The inspectors met with licensee representatives on January 9,30, February 20 and by l

telephone March 10,1997, to discuss the scope and findings of the inspe'ction. During '

I the exit meetings, the inspectors discussed the documents and processes reviewed by the

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inspectors during the conduct of this inspection and the likely informational content of the -

1 inspection report. The licensee representatives did not identify any such documents on process as proprietar ;

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PARTIAL LIST OF PERSONS CONTACTED

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Licensee R. Colglazer, NRC Coordinator, Regulatory Assurance J. Feinster, Lead System Engineer T. Gierich, Operations Manager

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K. Kofron, Site Manager ,

R. Linboom, Senior Inspector, SOV F. Pollak, Fire Protection System Enginee D. Popkins, Administrator, Operations Engineering D. Robinson, Project Engineer R. Scheidecker, Fire Marsha!

M. Snow, Work Control Superintendent .

D. Wozniak, Site Engineering Manager US NRC

' S. Burgess, Senior Resident inspector N. Hilton, Resident inspector LIST OF DOCUMENTS REVIFWED OBVS 7.10.1.1.G 1, October 31,1995, Revision 6, Unit 0, Fire Suppression Water Systems Fire Hydrant Flow Test BAP 1100-1, February 14,1992, Revision 9, Fire Protection Program OBOS 7.10.1.1.e-1, July 1,1996, Revision 10, Fire Protection Testable Valve Yearly Cycte Surveillance BAP 300-1, January 10,1995, Revision 3, Conduct of Operations BAP 330-2. July 31,1996, Revision 13, Temporary Alterations BAP 3301, September 26,1996, Revision 25, Station Equipment Out-of-Service Procedure OBVS 7.10.1.1.a-3, November 29,1995, Revision 3, Fire Protection Pumpf, Flow and Pressure Test LIST OF ACRONYMS SOV Site Ouality Verification FP Fire Protection, Fire Pump PlF Problem identification Form CAR Corrective Action Request E Equipment Attendant LCOAR Limiting Condition for Operation Action Request O Components Shared Between Unit RCP Reactor Coolant Pump , i :. 6