IR 05000454/1985047

Insp Rept 50-454/85-47 on 851101-1203.Violation Noted: Failure to Perform Tech Spec Surveillance on 125-volt Dc Busses 111 & 112 within Required Time Interval & Failure to Follow Tech Spec Action Requirement

ML20138L093
Person / Time
Site:	Byron
Issue date:	12/13/1985
From:	Forney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20138L062	List: IR 05000454/1985047 ML20138L057 ML20138L075
References
50-454-85-47, NUDOCS 8512190164
Download: ML20138L093 (7)

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U.S. NUCLEAR REGULATORY COMISSION

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Report No. 50-454(85047(DRP)

2DocketiNo. 50-454 '

License Nb. NPF-37 Licensee: ;CommonwealthEdisonCompany

. Post Office Box 767L

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Chicago, IL 60690 H . Facility'Namei : Byron Station,' Unit 1

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Inspection At

:ByronStation? Byron,IL JInspection-Conducted: November 1 . December 3, 1985 L * JInspectors: M M. Hinds, J P.-G.'Brochman

.J. A.--Malloy l~ .

. RF/Damwk & /2//p/Rr-3' 1 Approved By: 'W.-L..Furney,' Chief Date '

Reactor Projects Section 1A

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UInspection Summary

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,l Areas Inspected: Routine, unannounced safety inspection by the resident -

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inspectors of licensee action on previous ; inspection findings; IEBs;

operations summary; LERs; containment local-leak rate tests;' surveillance; taaintenance; operational safety;~ regional administrators tour; management meetings and otherfactivities. 'The inspection consisted'of 145 inspector-hours /onsite'byzthree NRC inspectors including ~24 inspector-hours during

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off-shift E .

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Results': 'Of the seven areas inspected,' no' violations or deviations were identified in six areas; one violation was: identified in the. remaining area

~.(failure to perform a Technical: Specification Surveillance within the required time interval and the failure to follow a Technical Specification Action-

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' Requirement 1- Paragraph 5.c). - The violation cites the failure to perform

'fa Technical.-Specification Surveillance within the required' time interval and

with nofoperable.D.C. bus due to the~ missed surveillance a Technical-

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Specification' Action Requirement was not followed; however, the D.C. busses-

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Lwere subsequently found to be ' operable when the surveillance was performed;

' itherefore, the public health and safety'were not affecte .

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r: . 8512190164 851213 PDR ADOCK 05000454

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DETAILS'

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5 .' Persons Contacted-Q

' Commonwealth Edis'on"

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MC. Reed, Vice President Nuclear Operations,

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D.' Galle, Assistant Vice President.& General Manager, Nuclear Station

...*K..Graesser,' Division Vice President, Nuclear Division

#*R. Querio, Station Manager -

, .*V. Schlosser, Project Manager .

(#*R. Pleniewicz, Production Superintendent

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1. • R.4 Ward," Services-Superintendent

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• RATuetken,-Startup Superintendent

'#*L. Sues,: Assistant Superintendent, Operation .

1. • G.LSchwartz, Assistant Superintendent., Maintenance

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1. • T.cJoyce, Assistant-; Superintendent, Technical Services #W.nBurkamper,-Quality Assurance Supervisor,.0perations

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1. • F. - Hornbeak, Technical- Staff Supervisor

1. • A. Chernick,LComplianc~e3 Supervisor.' ,

=* T.1Higgins, Training Supervisor i: *J.~Langan, Compliance Group

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' #W. Pirnat,, Compliance Group-

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K.-Yates,

• Onsite Nuclear Safety q; r#D. Robinson,.Onsite Nuclear Safety

The:, inspectors lalso contacted and interviewed other. licensee and g .

contractor personnel during the-course of this inspectio m

• Denotes.those present during the management meeting on November 20, 198 _

1. Denotes those present~during the exit interview on December 3, 198 '

2.' Action on-Previous Inspection Findings (92701)

.(Closed) Unresolved Item (454/85025-03(DRP): Discrepancies in LER-

-454/85050. . The inspector reviewed Revision 1 to this LER and verified Ethat the 1e'ngth of time.the surveillance had not been. performed was revised. The LER was also' revised to reflect the' violations of TEchnicai-

/ -Specification 4.0.4 which' occurred when Mode 1 was entered without the

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surveillance being current. This LER is also discussed in-Paragraph . :IE Bulletin (IEB) Followup-(92703)

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-(Closed) IEB'(454/85002-BB): Problems with under voltage trip attachments on Westinghouse Type DB-50 Reactor Trip Breakers. The

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. y einspector reviewed the licensee's response which stated that this IEB was not applicable to Byron because Byron's Reactor Trip Breakers are

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LWestinghouse Type DS-416;.vice, Type DB-50.

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' 4. . Summary'of Operations

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LThe unit 1 remained shutdown for entire' month for a planned 51 day outage.-

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' Licensee Event Report (LER) Followup (90712) :(Closed).LERs (454/85050-LL;.454/85061-LL 454/85088-LL; 454/85092-LL):~ ' An in-office' review was conducted for the following

.LERs.to; determine that.the reporting requirements were fulfilled,

immediate corrective action was accomplished and corrective action (to. prevent recurrence had been~ accomplished in accordance with

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Technical Specification LER No.- Title

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~454/85050-01 ' Failure'to Comply With Technical

< Specification'3/4. /85061-01 Reactor Trip on Low Steam Generator Level Due to Inadvertent Feed Pump Trip e

454/85088-01 . Auto Start of 08 VC M/U Fan

,454/85092- Delayed Fire Watch Due to Key Stuck in Vital Area Door Lock No violations orideviations were identifie u . (Closed).LERs (454/85090-LL; 454/85091-LL; 454/85094-LL): Through-direct observation, discussions with. licensee personnel, and review of records the following LERs were reviewed to determine that the-reporting requirements were fulfilled immediate-corrective' action was accomplished and corrective action to prevent recurrence had sbeen' accomplished in accordance with. Technical Specification ~

LER N Title 454/85090 Reactor Trip.on Low loop Flow While

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Venting Flow Transmitte /85091 Automatic Actuation of Auxiliary Building Charcoal Booster Fan Due

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to Incorrectly Landed Rela '454/85094~ Automatic Actuation of VC Makeup Fan Due to Iodine Detector Failure on Radiation Monitor OPR31 No violations or deviations were identifie .

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ng :(Closed) LER (454/85093-LL): This LER described an event on

. October 27-28, 1985,;while in Mode 5, involving the failure to

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-perform. Technical Specification Surveillances within the required Linterval for D.C. Busses 111 and 112 and consequently, the failure to f.ollow the Technical' Specification Action Requirements with both Busses: inoperable.-

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The D.C. Busses consist of a. lead acid battery and a battery charge Technical Specification 4.8.2.~2 requires that one 125-volt D.C. Bus

.(111'or 112) fed from its battery and its associated charges shall be demonstrated OPERABLE'per Technical Specification 4.8.2.1.1 and

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~ l4.8.2.1.2. Technical Specification 4.8.2.1.1. states: "Each . bus shall beidetermined OPERABLE and energized from its battery at

least once per seven days by verifying correct breaker alignment."

• LTechnicalL Specification 4.8.2.1.2 ' states, in part: "Each 125 volt-battery bank and its associated charger shall be: demonstrated

. 0PERABLE. . .~.at least- oncelper'seven days by verifying that: (1) the

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Lparameters in_ Table 4.8-2 meet the Category A limits, and (2) the--

total battery terminal voltage is greater than or equal to 126 volts on float charge..." . Byron. Operating Surveillance 1BOS 8.2.1.2.a-1,

??l25 VDC Battery Bank and Charger Operability Weekly Surveillance",

implements these requirement * Permission to conduct'this surveillance was granted at 2230 on October 25, 1985; however, the surveillance was not performed at'

'that-time because Battery 112 was on an " Equalizing" charge; vice, a L" Float" charge. lThe-BOS does allow the' battery to be taken off an

" Equalizing" charge to perform the surveillance and then to be placed back on an " Equalizing" charge. The individual performing the -surveillance ' overlooked this fact and chose not to perform the surveillanc .

Sub'sequently,7 inadequate review of the' surveillance schedule by

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operating personnel allowed the " critical" date of 2359 on October l27, 1985, to be exceeded (by 13.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />). The'"due" date

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is defined as the' scheduled ~date by which the surveillance should

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_be' completed. .The'" critical" date'is' defined as the due date plus-a 255 margin ~by which the surveillance must be completed, or else

~ the Technical Specification will be exceede This fact was

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. discovered by licensee personnel at-1330 on October 28, 1985. The failure to perform 1BOS 8.2.1.2.a-1 within the required time n linterval is a' violation of Technical Specification 4.8. (454/85047-01a(DRP)).

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Technical- Specification 4.0.3 states, in part: " Failure to perform

a Surveillance Requirement within the specified time interval shall

constitute a failure to meet the OPERABILITY. requirements for a Limiting Condition for Operation...". Technical Specification 3.8.2.2 states, in part

"As a minimum, one 125 volt D.C. bus fed from its . battery and its associated full-capacity charger shall be OPERABLE, while in Modes 5 and 6. With the required battery bank and/or full-capacity charger inoperable, immediately suspend all

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operations involving CORE ALTERATIONS, positive reactivity changes or movement of irradiated fuel; initiate corrective action to

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restore the required battery bank and full-capacity charger to

~0PERABLE status as soon as possible, and within eight hours,

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depressurize and vent the Reactor Coolant System through at least a two square inch vent." With both Bus 111 and Bus 112 inoperable the Reactor Coolant System (RCS) should have been depressurized and

. vented via a two square. inch vent. Fortuitously, the RCS had been depressurized for planned maintenance, however, it had not been vented by a two square inch vent. The failure to vent the RCS with a.two square inch vent within eight hours-is a violation of Technical Specification'3.8.'2.2 (454/85047-01b(DRP)).

By 1354 on October 28, 1985, the surveillance had been completed successfully. The licensee's corrective actions included reviewing this' event with shift personnel, requiring that surveillances must be done by the "due" date; vice, the " critical" date, entering the

"due" date on the' surveillance form, notifying the shift engineer when a surveillance has not been completed by its "due" date, and revising the surveillance procedure to split Busses 111 and 112 into two separate procedures so that both Busses would not become inoperable if a surveillance was missed. Based on these corrective actions, this violation is considered closed and consequently no

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response is require . Containment Local Leak Rate Test (LLRT) Witnessing (61720)

The inspectors witnessed performance of portions of the LLRT procedures in order to verify that testing was conducted in accordance with the technical specifications and procedural requirements, test data was properly recorded, test equipment was properly calibrated and performance

.of licensee personnel conducting the tests demonstrated an understanding of_ assigned duties and responsibilities. Testing of the following valves was observed:

Containment Isolation Valves IS0002E ISD005C 1WM191 No items of noncompliance or deviations were identifle . Monthly Surveillance Observation (61726)

The inspector observed Technical Specifications required surveillance testing on Containment Penetration Overcurrent protective devices for valves 1RC8003A and IRC80030 and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that limiting conditions for operation were met, that removal and restoration of the affected components were accomplished, that test results conformed with Technical Specifications and procedure requirements ~and were reviewed by personnel other than the individual

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l directing the test,'and that~any' deficiencies identified during the

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testing were properly. reviewed and resolved by appropriate management personne No' violations or deviations were identifie . Monthly Maintenance Observation (62703)-

Station maintenance activities of safety related syst' ens and components listed below were observed / reviewed to ascertain that they were conducted in accordance with approved procedures,' regulatory' guides and-industry codes or standards and in conformance with Technical Specification The1following items were considered during this review: the limiting

- conditions-for operation were met while components or systems were cremoved from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as' applicable; functional. testing and/or calibrations were performed prior.to returning components os systems to service; quality l control records were maintained; activities were. accomplished.by qualified personnel; parts and materials used were properly certified;

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radiological controls were implemented; and, fire prevention controls were implemented.- Work requests were reviewed to determine' status'of outstanding jobs and to assure that priority is assigned to safety related equipment maintenance which may affect system performanc The following maintenance activities were observed / reviewed:

Diesel Generator 1DG01KA Modification to Steam Generator Chemical Feed System M6-1-85-677

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Following complei. ion of maintenance on the diesel generator and the

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chemical feed system' modification, the. inspector. verified that these systems had been returned to service properl .No violations or deviations were identifie , Operational Safety Verification (71707)

The' inspectors observed control room operation, reviewed applicable logs and conducted discussions with control room operators during the month of November. During these discussions and observations, the inspectors

. ascertained that the operators were alert, cognizant of plant conditions, attentive 'to changes in those conditions, and took prompt action when appropriate. The inspectors verified the operability of selected

' emergency systems, reviewed tagout records and verified proper return to service of affected components. Tours of the containment,' auxiliary,

' turbine and rad-waste buildings were conducted to observe plant equipment

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conditions, including potential fire hazards, fluid leaks and excessive vibration'and to verify that maintenance requests had been initiated for equipment in_need of maintenanc The inspectors verified by observation and direct interviews that the physical security plan was being implemented in accordance with the station security pla The inspector observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection control During the month of November, the inspector walked down the accessible portions of the vital AC power system to verify operability. The inspector also witnessed portions of the radioactive waste system controls associated with radwaste shipments and barrelin These reviews and observations were conducted to verify that facility operations were in accordance with the requirements established under technical specifications, 10 CFR and administrative procedure No violations or deviations were identifie . Regional Administrator's Tour on November 20, 1985 (92700)

NRC Region III Administrator James G. Keppler accompanied by

. R. F. Warnick, Chief, Reactor Projects Branch 1; L. A. Reyes, Chief, Operations Branch; W. L. forney, Chief Reactor Projects Section 1A; and the Resident Inspector staff toured Byron Units 1 and 2 and met with licensee station and corporate management and also attended the management meeting described in Paragraph 1 . Management Meetings (30702)

On November 20, 1985, Messrs. J. G. Keppler, Regional Administrator; R. F. Warnick, Chief, Reactor Projects Branch 1; L. A. Reyes, Chief, Operations Branch; W. L. Forney, Chief, Reactor Projects Section 1A; and the NRC resident inspector staff met with licensee management and supervisory personnel denoted in Paragraph 1 of this report. These meetings were held to assess overall facility status, plant operations and to discuss licensee actions to reduce LERs, improve communications and integrated plant operation . Exit Interview (30703)

The inspectors met with licensee representatives denoted in Paragraph 1 at the conclusion of the inspection on December 3, 1985. The inspectors summarized the purpose and scope of the inspection and the finding The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents / processes as proprietar