IR 05000454/1986001

SALP Repts 50-454/86-01 & 50-455/86-01 for May 1984 - Oct 1985

ML20198H642
Person / Time
Site:	Byron
Issue date:	01/27/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20198H597	List: ML20198H593 ML20198H642
References
50-454-86-01, 50-454-86-1, 50-455-86-01, 50-455-86-1, NUDOCS 8601310070
Download: ML20198H642 (52)

Text

SALP 5 SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION

REGION III

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 50-454/86001; 50-455/86001 Inspection Report No Commonwealth Edison Company Name of licensee Byron Nuclear Station, Units 1 & 2 Name of Facility May 1, 1984 through October 31, 1985 Assessment Period

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l 0601310070 PDH 060127ADOCK 05000404 PDR o

I. INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance based upon this information. The SALP program is supplemental to normal regulatory processes used to ensure compliance to NRC rules and regulations. The SALP program is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to the licensee's management to promote quality and safety of plant construction and operatio An NRC SALP Board, composed of staff members listed below, met on December 11, 1985, to review the collection of performance observations and data to assess licensee performance in accordance with the guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance."

A summary of the guidance and evaluation criteria is provided in Section II of this repor This report is the SALP Board's assessment of the licensee's safety performance at Byron Nuclear Station, Units 1 and 2, for the period May 1, 1984 through October 31, 1985. Licensee activities over the assessment period include Unit 1 preoperational, startup, and operational phases and also Unit 2 construction and preoperational phases. For the purposes of evaluation, the functional areas fall into three general categories. The first category addresses Unit 1 as an operating facility and covers the period of October 31, 1984 through October 31, 198 Functional areas A., and C. through E. in Section III of this report identify the areas evaluated in this category. The second category addresses Unit 1 and Unit 2 preoperational and startup functional areas which are common to both Unit 1 and Unit 2 and covers the entire assessment period. Functional areas B. and F. through K. in Section III of this report identify these area Unit 1 and Unit 2 functional areas for construction are addressed in the third category identified by functional areas L. through Q. in.Section III of this repor The evaluations of these areas also spans the entire assessment perio SALP Board for Byron Station, Units 1 and 2:

Name Title C. E. Norelius Director, DRP J. A. Hind Director, DRSS L. A. Reyes Branch Chief, DRS '

W. D. Shafer Branch Chief, DRSS W. L. Axelson Branch Chief, DRSS R. F. Warnick Branch Chief, DRP  !

W. L. Forney Section Chief, DRP l M. A. Ring Section Chief, DRS  !

L. R. Greger Section Chief, DRSS

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M. Schumacher Section Chief, DRSS M. P. Phillips Section Chief, DRSS I L. N. 01shan Project Manager, NRR J. M. Hinds J Senior Resident Inspector, DRP P. G. Brochman Resident Inspector, DRP R. M. Lerch Project Inspector, DRP J. L. Belanger Reactor Inspector, DRSS C. A. VanDenburgh Reactor Inspector, DRS N. A. Nicholson Reactor Inspector, DRSS T. J. Ploski Reactor Inspector, DRSS K. R. Ridgway Reactor Inspector, DRP

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L II. CRITERIA The licensee's performance is assessed in selected functional areas, depending upon whether the facility is in a construction, preoperational, or operating phase. Functional areas normally represent areas significant to nuclear safety and the environment. Some functional areas may not be assessed because of little or no licensee activities, or lack of meaningful observation Special areas may be added to highlight significant observation One or more of the following evaluation criteria were used to assess each functional are . Management involvement and control in assuring quality Approach to the resolution of technical issues from a safety standpoint Responsiveness to NRC initiatives l Enforcement history 1 Operational and Construction events (including response to, analyses of, and corrective actions for) ' Staffing (including management) Training effectiveness and qualification However, the SALP Board is not limited to these criteria and others may have been used where appropriat I Based upon the SALP Board assessment, each functional area evaluated is

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classified into one of three performance categorie The definitions of these performance categories are:

Category 1: Reduced NRC attention may be appropriat Licensee management i attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so that a high level of performance with respect to operational safety and construction quality is l being achieve Category 2: NRC attention should be maintained at normal levels. Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably l l effective such that satisfactory performance with respect to operational l l safety and construction quality is being achieve i Category 3: Both NRC and licensee attention should be increase Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to i

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l be strained or not effectively used so that minimally satisfactory performance with respect to operational safety and construction is being achieve Trend: The SALP Board has also categorized the performance trend in each functional area rated over the course of the SALP assessment perio The categorization describes the general or prevailing tendency (the performance gradient) during the SALP period. The performance trends are defined as follows:

Improved: Licensee performance has generally improved over the course of the SALP assessment perio Same: Licensee performance has remained essentially constant over the course of the SALP assessment period.

l l Declined: Licensee performance has generally declined over the course of l the SALP assessment period.

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III. SUMMARY OF RESULTS  :

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Byron SALP 5 incompasses activities in 17 functional areas during all, or ,

part, of the 18 month assessment period. The licensee's performance was -

acceptable in the construction activities which continued from the previous assessment period. However, performance in functional areas involving Unit 1 operations demonstrates significant weaknesses. Although the licensee is considered capable, continued management action is needed in order to assure acceptable performanc Rating Last Rating This Functional Areas _

Period Period Trend Plant Operations NR 3 None* Radiological Controls 2 3 Same Maintenance NR 2 Same i

' Surveillance NR 3 Declined Initial Fuel Loading NR 1 N/A i Preoperational Testing 3 2 Same ;

and Startup Testing ' Fire Protection 3 2 Improved

! Emergency Preparedness 2 1 Improved Security 2 3 Declined Quality Programs and 2 2 Same Administrative Controls Licensing Activities 2 2 Same Containment and 2 2 Same !

Other Safety-Related Structures l Piping Systems 2 2 Same i and Supports l Safety-Related 2 2 Same Components  ! Support Systems 2 NR N/A Electrical Power Supply 2 2 Same and Distribution

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Q. Instrumentation and 2 2 Same l Control System l

NR = Not rated because of limited work or inspection activit * Discernable improvement was observed since the end of the summer of 198 .

IV. PERFORMANCE ANALYSIS Plant Operations Analysis l Licensee activities in this functional area were observed in 33 inspections. Two inspections were conducted by region based inspectors to determine the adequacy of the test and experiments program. The test and experiments program was defined by documented procedures for control of activities; however, no work had been performed in this area at the time of these inspections. Thirty-one inspections were conducted by resident I inspectors. The inspectors observed control room operation;

! reviewed applicable logs; conducted discussions with control room operators; ascertained that the operators were alert, cognizant of plant conditions, attentive to changes in those conditions, and took prompt action when appropriate; verified the operability of selected emergency systems; reviewed tagout records; verified proper return to service of components; toured the plant to observe plant equipment conditions, including potential fire hazards, fluid leaks, excessive vibration, and to verify that maintenance requests had been initiated for maintenance; verified by observation and interviews that the physical security plan was being implemented; observed plant housekeeping / cleanliness conditions; verified implementation of radiation protection controls; and witnessed portions of the radioactive waste system controls associated wit 1 radwaste shipments and barreling. These reviews and observations were conducted to verify that facility operations were in accordance with the requirements established by Technical Specifications, the Code of Federal Regulations and administrative procedure Nine violations were identified: Severity Level IV - Both ECCS subsystems were rendered inoperable as a result of a procedural violation involving valvealignment(ReportNo. 454/85002). Severity Level IV - Overtemperature Delta T and Overpower Delta T channels inoperable in Mode 2 due to NTC circuit cardsnotbeingseismicallyqualified(ReportNo. 454/85002). Severity Level V - Failure to follow administrative p(rocedures for controlling overtime (four examples)

Report No. 454/85009), Severity Level IV - Failure to implement the required procedures upon entry into a LCO and failure to de energize the PORV block valves in the closed position within one hour (ReportNo. 454/85016).

7 Severity Level IV - Failure to follow operating and administrative procedures iesulting in the Refueling Water Storage Tank being inoperable for four hours (ReportNo. 454/85030). Severity Level IV - Failure to monitor the indicated Axial Flux Difference (AFD) hourly for ten hours following the restoration to OPERABLE status of the AFD Monitor Alarm (ReportNo. 454/85039), Severity Level III - Operation of the Emergency Core Cooling System such that a portion could not have performed its intended safety function and failure to follow the applicable Technical Specification Action Requirements (Report No. 454/85042), Severity Level III - Failure of management controls necessary to assure compliance with the Technical Specifications (fourexamples)(ReportNos.454f85042 454/85043). Severity Level IV - Inadequate procedure utilized for calculating the reactor core thermal power (Report Nos. 454/85042; 454/85056).

The above violations directly involved plant operation; however, other violations which indicate direct or indirect involvement by plant operations are discussed in other functional areas of this repor An enforcement conference was held after the closure of the assessment period to discuss the facts and significance of violations g., h., and 1. NRC enforcement action is presently under revie InreviewingtheLicenseeEventReports(LERs)issuedoverthe assessment period it has been determined that plant operations have been subject to numerous personnel errors, and other Technical Specification violations. Over the period, the licensee was involved in 137 events for which LERs were required, resulting in a monthly average of approximately 11.5 which is considered excessiv An assessment of a sample of LERs found them to be generally of acceptable quality based on the requirements of 10 CFR 50.7 It appears, however, that the large number of personnel involved in preparing LERs results in a wide diversity in quality. The low quality in some LERs reduced the assessment of LERs to an overall quality that was average.

! Anexcessivenumberofreactortrips(31)wasrecordedduring l the assestment period. Of these, four were planned as part of l

the startup test program engineering tests, eight were attributed

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l to personnel errors, four were the result of procedural deficiencies, seven were related to design / manufacturing /

installation, two were attributed to external / natural phenomena, and for six, the cause was not identifie Based on Region III management's concern with of the licensee's performance immediately following issuance of the operating license, Region III management began to meet with Byron Station managers to review licensee performance and NRC findings and observations of plant operations. The management meetings were held on a monthly basis beginning in December 1984 and continued through the end of the assessment period. These management meetings centered on the licensee's performance and corrective actions to reduce personnel errors, reactor trips, and missed or unsatisfactory surveillances. Surveillances are discussed as a functional area in Section IV.D of this report. A number of violations listed in the functional area of Surveillance also involve plant operations personnel and are also applicable to this functional are In response to the NRC concerns expressed in the monthly management meetings, the licensee developed and implemented the

" Conduct of 0)eration Improvement Program" for the Byron Statio Features of t1e program include imnroved communication and awareness of trends and problem areas thrcugh production of a Monthly Plant Status Report; " Increased Shift Overview Superintendent (505) Involvement." " Technical Staff System Interaction with Operations," and " Increased Awareness Of Personnel To Day-To-Day Activities;" actions to reduce the number of LERs and DVRs; controls to eliminate missed surveill-ances; and improved housekeepin The NRC has noted licensee management's increased responsiveness to this NRC initiative (monthly meetings) and involvement, as the assessment period ,

progressed, in efforts to identify problem areas and secure needed improvements in the Plant Operations functional are A review of the indicators of management involvement in assuring l quality indicates that in the area of reportable events, as documented in LERs the 1985 average stands at nine per month and although the trend over the period hasbeendownoverall(13,10,4,5 from July)through respectively , continuedOctober l nanagement attention in thir, area must )e maintained to ensure that LERs reach minimum achievable levels. Personnel errors l shcwn :

have been excessively high over the period and have only(9, 6, I '

an improving)

respectively trend over the

. Managenent August attention must- October continuetime frame to be focuse:t ;

in this area to bring personnel errors to the level expected of -

a good performing plant. As discussed in Section IV.D. of this report, missed or incorrectly performed surveillances involving l plant operations and operating personnel continue to be a high percentage of reportable events and will require continued management attention to bring them under contro During the appraisal period, the licensee's administrative controls over control room activities were challenged by the increased testing activity, the complexity of activities being added daily to the operator's shift routine, and the evolution from piecemeal system / component testing to integrated plant operation. The licensee's administrative controls for

, maintaining control room discipline have proven to be adequate

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to this point in plant operations. Personnel access controls

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were established for the control room, center desk, and unit .

I licensed operator control console area and have proven !

effective in minimizing licensed operator distraction. Station management has thoroughly indoctrinated licensed operators through implementation of corporate directives and plant procedures which include NRC regulations and guidance on maintaining order in the control room, the authority and responsibility of licensed personnel, and the need for

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professional attitudes and conduct at all times. The effectiveness of station management presence in the operations control areas is demonstrated, for the most part, by the absence of distracting or prohibited activity in the control room or other watch stations. Another indicator of the atmosphere of professionalism existing in Byron managers and licensed operators is the willingness to employ a color coded work uniform program from the station superintendent to the equipment attendants. The uniforms project a professional air and thus promote greater professional conduct of operation Although the licensed operators of the Byron Station plant operations staff have been both directly and indirectly involved in reportable events, the NRC recognizes the high level of professionalism demonstrated by the conduct of control room activities related to plant operations and considers the licensed operator staff to be well trained, highly motivated, and of the highest qualit Staffing continues to be a licensee strength. The staff is stable and well organized with no significant turnover to date, other than internal promotions and transfers among department Qualifications, education, and experience levels within the staff are good and should improve with additional experience, requalification activities, and continued operation. Staffing levels are high by design to ensure a qualified and experienced cadre in preparation for Unit 2 integrated plant operation During the assessment period, license examinations were administered to two different groups of candidates. The July 1984 group consisted of 8 senior operator and 6 reactor operator candidates. The overall pass rate for the group was 78%, which is comparable to the national average of 80% and indicated an upward trend compared to previous examination group The Octobe" 1985 group of 8 senior operator and 10 reactor operator candidates had an overall pass rate of 61%. This is below the national average and is considered unsatisfactory, and indicated

that improvement achieved early in the assessment period has not continued. The licensee should focus more attention to the screening of candidates to assure that marginal candidates are not submitted to take the NRC examinatio The licensee generally exhibited a conservative approach to technical safety issues penalizing unit production on some occasions to assure compliance to a conservative interpretation of Technical Specification requirements. Responsiveness to issues and/or concerns raised by the NRC was, for the most part, thorough and showed overall a cooperative attitud . Conclusion The licensee is rated Category 3 in this area based on inspection findings of high numbers of reportable events, reactor trips, missed and inadequate surveillances, and personnel errors in plant operations. The licensee was not rated in this functional area in the last assessment perio . Board Recommendations NRC and licensee management should continue to focus attention on the progress of the licensee's programs implemented to improve regulatory performance and reactor operations.

B. Radiological Controls Analysis Nine inspections were conducted during this assessment period by region based inspectors. These inspections included radiation protection, radioactive waste management, TMI Action Plan Items, environmental protection, chemistry and radiochemistry, and confirmatory measurements. Six inspections were conducted while Unit I was in the preoperational modes, and three operational inspections were conducted subsequent to fuel load. Unit 2 remained in a preoperational status throughout the assessment period. The resident inspectors also reviewed this area during routine inspection Seven violations were identified as follows: Severity Level IV - Failure to report air filtration and absorption unit test nonconformances in accordance withlicenseequalityassuranceprocedures(Report No. 454/84066). Severity Level (*) - Inadequate procedures or failure to follow radiation protection procedures for: (1) restricting personnel entry into containment while the incore detectors were withdrawn, (2) providing continual radiation / chemistry technician (RCT) atten# nce during an emergency containment entry. (3) providing continual RCT attendance as specified

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on the radiation work permit, (4) exiting a high radiation area when exceeding administrative doses (two occasions),

(5) adherence to general contamination controls and personal decontamination methods by workers involved in work on a contaminated CVCS valve, and (6) providing positive controls to prevent personnel exiting the station following activation of portal monitor. alarms (Report No. 454/85022). Severity Level (*) - Failure to provide adequate instructions regarding radiological conditions and precautions to two workers who entered containment for work on a stuck incore detector (Report No. 454/85022). Severity Level (*) - Failure to make an evaluation of radiological hazards associated with work on a contaminated CVCS valve (Report No. 454/85022). Severity Level IV - Failure to have an authorized procedure addressing a valve lineup to transfer diluted reactor water from the recycle holdup tanks to the Unit 2 condensate sump. As a result, the sump overflowed (Report No. 454/85022). Severity Level IV - Failure to follow liquid radwaste release procedures to positively verify that the required dilution flow was available (Report No. 454/85038). Severity Level IV - Failure to take timely action when the Technical Specification Limiting Condition for Operation (LC0) for liquid radioactive release was exceeded (Report

. No. 454/85038).

• Three violations (b., c., and d.) were classified collectively as Severity Level II These violations appear indicative of programmatic and managerial failures in radiological evaluations, procedural controls, training, and effluent release controls. A civil penalty of

$50,000 was proposed for violations, classified collectively as a Severity Level III problem, involving three separate incidents which included numerous failings concerning radiological procedure adherence, procedure adequacy, and evaluation of working condition The enforcement meetings for these incidents stressed a need for improved supervisory adherence to the licensee's established radiological control program and improved instructions to radiation workers. Licensee corrective actions have generally been timel _ _ _ _ __

Inadequate management attention to and involvement in radiological activities was evident during this assessment period as indicated by: (1) management's untimely recognition of potentially serious problems identified during the incore motor drive repair and at power containment entry incidents, (2) numerous examples of poor adherence to radiation protection procedures and good health physics practices by first line supervisors and professional / technical staff, and (3) management's initially inadequate investigation into radiologically significant incident Management weaknesses regarding timeliness in identification and resolution of potential problems with TMI action items were also evident' An improving trend of

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positive management involvement was observed subsequent to the enforcement conferences, including higher priority given to investigating poor performance reports, staff emphasis on procedural adherence, and increased disciplinary action taken for flagrant procedural violations. In addition, licensee management requested an audit of the radiation protection program by non-station CECO health physics representatives to identify operational and functional weaknesses. Licensee representatives began implementing corrective actions for these weaknesses late in the assessment period. Corporate management involvement, limited during initial operational phases, also improved during the period as evidenced by a commitment to investigate significant radiological occurrence Staffing has generally improved during this assessment perio Startup and operational activities for Unit 1 increased the workload for the RCT staff, resulting in significant overtime to meet programmatic need In an attempt to supplement the staff, licensee management directed an additional class of seven RCTs be trained; this has helped ease the shortage. The staff has been fairly stable during the assessment period, with promotions and transfers being the principal reason for personnel losses. Qualifications meet current industry standards; however,

, the radiation protection staff's operational experience levels are low as is generally the case at new plants. In accordance with a generic CECO plant organization change, two intermediate management positions between the Radiation Protection Manager (RPM) and Plant Manager were created toward the end of the assessment period. This is generally considered a weakness because of the communication barriers it creates between the RPM and the plant manage The licensee has formal training / qualification programs for RCTs, plant workers, and visitors. Improvements are needed in the areas of plant systems training for RCTs and procedural adherence for all plant worker These weaknesses were clearly indicated by the RCT staff's lack of awareness of radiological hazards associated with reactor systems, such as the incore detectors, and by the repeated procedural violations by the plant staff during this assessment perio i 13 l

The licensee's responsiveness to NRC initiatives has been inconsistent during this period. Licensee actions have been acceptable in the areas of radiation seal qualification, radiation monitor, and ventilation system concerns. The licensee has resolved most of the TMI Action Item probiems identified during this assessment period and has proposed corrective actions for the remainder, although action to resolve some of the issues was slow. The licensee's reporting of incidents to the NRC exceeded requirements. Weaknesses concerning the radiological environmental monitoring program (REMP) problems which were identified during the previous assessment period went uncorrected until a few weeks before fuel load in August 1984. Licensee (corporate) responsiveness to REMP issues improved considerably following a special NRC REMP inspection in April 1985 of the licensee's corporate environmental group. The corporate environmental group was instructed to place more emphasis on REMP managerent to avoid problems in the future. In response to NRC concerns regarding low level licensed material shipped offsite to ncn-licensees, timely action was taken to recover all material and implement positive controls to prevent recurrence. The effectiveness of licensee corrective actions for problems addressed in the civil penalty could not be ascertained during this assessment period due to their recent implementatio The licensee's approach to resolution of radiological technical issues has been adequate. Personal radiation exposures for the first eight months operation were approximately 43 person-rems, reflecting adequate exposure control program design and implementation. Based on a design analysis, licensee representatives plan to shield neutron streaming from the cavity to minimize dose levels near the personnel hatc Interim shielding attempts during this assessment period have not been successfu Although the operational liquid and airborne effluent programs ,

were not specifically inspected this assessment period, five unplanned or improper radioactive releases were reported. All were quantitatively minor, but three were noteworthy because of

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the errors which contributed to the releases. Additional problems

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in this area include inoperability of both the boric acid and radwaste evaporators and the resin cleanup system until sometime about early September 1985 when the resin cleanup system became fully operational and the evaporators became operational

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intermittently, resulting in significant reduction in liquid

, effluent activit The licensee anticipates elimination of remaining problems with the evaporators during the current outag Use of a vendor resin cleanup system hos been discontinued but a vendor resin solidification system is still in us The licensee unintentionally released low level contaminated

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resins to two offsite vendors because the resins were not adequately monitored before release from the site. All affected resins were recovered by the licensee and returned to the site after the problem was identified by the license Licensee's chemistry / radiochemistry performance was generally satisfactory during the perio The licensee's policy of rotating radiation-chemistry technicians (RCTs) between chemistry and health physics, with resulting long intervals between laboratory assignments, is a weakness that may limit technician performance and will require strong management oversight to avoid performance problems. A full complement of RCTs has satisfactorily completed an on-the-job certification program in numerous areas in chemistry and a formal training program, including a water chemistry control training program. The licensee has issued a comprehensive water chemistry control directive which directs each station to develop site specific water chemistry control parameters. The Chemistry Department is making good progress in implementing this directive by preparing an extensive list of 54 administrative procedures (BAPs) describing all facets of water chemistry control to avoid corrosion of the plant. The licensee, however, had difficulty in maintaining desired secondary chemistry, particularly during power transients, and has had to impose an action described in BAP 599-39 requiring reduction in power to 30% within specified time periods. The licensee had developed plans to make a number of modifications to the secondary system during a plant outage to resolve some of the problems encountered and has had to use excessive amounts of hydrazine to remove the organics present in secondary water systems. Progress in reducing organics in the secondary systems has been mad The licensee also has established an adequate QA/QC program providing RCTs with blind samples of nonradiological chemical species but has not yet included a similar program for radiochemistry as discussed in the previous SALP report. The licensee analyzes radioactive samples from the Zion Nuclear Plant; results reviewed appeared satisfactory.

2. Conclusion The licensee is rated Category 3 in this are This is a lower rating than was given in the previous assessment period. This rating is based primarily on the licensee's performance subsequent to fuel load. During this period, the licensee's performance in the areas of enforcement, management, radiological controls, and training were primarily responsible for the Category 3 rating. Improvements initiated by the licensee near the completion of this assessment period should improve licensee performanc Licensee performance has remained the same during the assessment perio . Board Recommendations Increase inspection attention in this area.

C. Maintenance Analysis Activities in this functional area were examined by four inspections conducted by region based inspectors and portions of nine inspections by resident inspector Activities covered included the program and implementation review of maintenance and supporting activities including calibration, control of test and measuring equipment, design changes, and modifications. Station maintenance activities of safety related systems and components were observed and reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides, industry codes and standards, and in conformance with technical specification Several weaknesses were identified in the program review in these areas. The licensee took prompt action to correct the weaknesses. Activities were performed to approved documented procedures and procedures were rarely violated. The limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; functional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and, fire prevention controls were implemente Work requests were reviewed to determine the status of outstanding jobs and to assure that priority is assigned to safety-related equipment maintenance which may affect system performanc Two violations were identified: Severity Level V - Failure to provide appropriate acceptance limits in instructions, procedures, or drawings utilized to accomplish battery cell-to-rack end stringer gaps (Report No. 455/85006). Severity Level IV - Failure to adequately document a deviation in the operation of the Rod Control System (Report No. 454/85033).

Work performed was generally technically sound, thorough and timely. Records were generally complete, well maintained and available. However, the NRC is concerned that appropriate management attention and accurate, timely resolution of maintenance items which have been identified as having minimal

safety significance may be a weakness. As evidenced by item above, inadequate documentation and management review of an operational problem on a nonsafety-related system subsequently delayed the timely correction of an equipment deficiency which resulted in the occurrence of multiple rod drops and contributed to the dissemination of inaccurate information to the NR Aggressive management attention and rigorous evaluation of all technical issues is required to ensure acceptable equipment performanc Although there has been some cross-over between construction incidents and operational reportable events, the number of LERs and violations in this area have not been excessive and management involvement in assuring quality in this area has been adequate over the period. Upon identifying an area requiring additional management oversight, the licensee har provided technically sound resolution with good consideration of the safety issues involve A review of the maintenance organization reveals adequate manning in all positions with well-trained, moderately experienced personnel who demonstrate a degree of pride in their workmanshi Inspections in the overall maintenance area have provided a reasonable level of confidence in the administration of a sound program with adequately documented procedures and records; however, the effectiveness and timeliness of maintenance activities could be improved by greater involvement in the day-to-day inner departmental problems and delays by the upper levels of managers at the shop head, general foreman, and foreman levels, thereby enhancing the communication of maintenance problems at the intra-departmental level. Examples of this weakness are: (1) two identical cases of reactor trip due to dropped rods on March 29, 1985 and April 10, 1985; (2) exceeding the administrative radiation exposure limits for workers while performing incore detector repairs; (3) reactor trip due to low lube oil reservoir level; (4) three incidents of dropping the identical control rod resulting in 2 reactor shutdowns during startup and one reactor trip from power; and (5) an unusual event resulting from both trains of control room ventilation being inoperable.

2. Conclusion The licensee is rated Category 2 in this are The licensee was not rated in this functional area in the previous assessment period. Licensee performance has remained the same during the assessment perio . Board Recommendations None.

D. Surveillance Analysis This functional area was examined in two inspections conducted by region based inspectors and portions of ten inspections conducted by resident inspector The inspections included a review of the program for the control and evaluation of surveillance testing including inservice inspections. Problems were identified in procedures regarding independent verifications during surveillance testin Procedures were revised in an attempt to correct these probl ems.- Implementation of the surveillance program was also reviewed and inspectors verified that testing was performed in accordance with approved 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 directing the test, and that any deficiencies identified during the testing were reviewed and resolved by appropriate management personnel. Work was generally timely, thorough, and technically sound. Records were generally complete, well maintained, and availabl Six violations were identified: Severity Level IV - Failure to perform inservice tests of Unit 1 RHR pumps within the required surveillance interval; inservice testing to establish pump and/or system operability using inadequate instrumentation (Report No. 454/84079). Severity Level IV - Failure to follow surveillance procedures (Report No. 454/85009). Severity Level IV - Failure to perform a surveillance as required prior to entry into the applicable operational mode; failure to perform surveillances prior to returning components to service; and failure to perform a surveillance within the required time interval (Report No. 454/85016). Severity Level IV - Failure to perform a surveillance ,

within the required time interval; failure to collect,and ,

analyze reactor coolant sample within the time rsquir?ments .

of Technical Specifications (Report No. 454/850Fh.). '

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.-. .-. Severity Level IV - Failure to perform surveillance within the required time interval; failure to perform surveillance as required (Report No. 454/85025). Severity Level IV - The Reactor Coolant System water inventory balance was not performed within the required surveillance interval (Report No. 454/85039).

Violation "a" involved two discrepancies: (1) failure to i ensure Residual Heat Removal (RHR) pump operability by performance of inservice testing within the required surveillance interval prior to entering Modes 6 and 5; and (2)

use of inadequate instrumentation which exceeded the maximum allowable range requirements of the licensee's inservice test program during inservice tests to establish operability prior to entry into Modes 6 and 5. These two incidents resulted in operation in Modes 6 and 5 without properly establishing the OPERABILITY of the RHR pum Violation "b" involved two discrepancies: (1) failure to follow prerequisite steps of a surveillance procedure based on ad-hoc advice from Westinghouse personnel resulting in a turbine trip and reactor trip at power; and (2) use of a surveillance procedure to investigate a turbine impulse pressure channel indication in a prohibited mode during a reactor startup which resulted in an additional reactor tri These two incidents resulted in two unwarranted reactor trips due to the failure to observe and follow the stated prerequisite steps of approved surveillance procedure Violation "c" involved three discrepancies: (1) failure to observe and implement the Technical Specification Action Statement for six hours in Mode 5 while the emergency power source for the operable Centrifugal Charging Pump was out-of-service; (2) failure to de-energize the Pressurizer Power Operated Relief Valve Block Valves in the closed position for 1.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in Mode 3 as required by the Technical Specifications; and (3) failure to place the main Control Room Ventilation System Train in the makeup mode exceeding time limits in Mode 5 upon taking radiation monitoring instrumentation out-of-service for maintenance as required by the Technical Specifications. These three incidents resulted in systems / components not being placed in the Action Statement s required conditions in excess of the time requirements of the Technical Specifications as a result of failure to observe and implement the Technical Specification Action Statement Violation "c" also involved eight discrepancies which included:

(1) failure to establish an hourly fire watch in Mode 6 from October 1984 to December 1985, while a replacement ultraviolet fire detector in the Fuel Handling Building remained untested to atsure operability by surveillance performance; (2) failure to perform inservice inspection visual examinations on seven

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valves and components prior to returning them to service in Mode 6; (3) failure to perform required surveillance position indication testing on a safety injection valve prior to entry into Mode 3 from January 10 to January 24, 1985; (4) failure to demonstrate operability of remaining offsite electrical circuits while one offsite electrical circuit was out-of-service for maintenance by exceeding the specified time limits for the initial and subsequent verification while in Mode 3; (5) failure to demonstrate the capability of 2A Diesel Generator to supply power to Bus 141 daily in excess of time limits in Mode 3; (6) failure to perform the quarterly test on a Containment Isolation Valve in excess of the time limits in Mode 3; (7) failure to perform the required 31 day operability test of the Lower Cable Spreading Room CO2 Systet in the months of January and February, 1985 while in Modes 5 through 1; (8) failure to perform a Turbine Emergency Trip Header Low Pressure Reactor Trip Surveillance prior to entry into Mode 2.

These eight incidents resulted in equipment, components and/or system operability not being certified for periods of time from a few hours to a few months and resulted from failure to observe, recognize and implement the Technical Specification Surveillance requirements.

Violation "d" involved two discrepancies: (1) failure to perform the isolation time surveillance on 1PR066 while in Mode 1; and (2) failure tu sample the primary system in excess of the time limitations following a power level chang These two incidents resulted in operation in Mode 1 with the operability of a containment isolation valve not ve. * fied and, exceeding the time limitations to verify that no reactor coolant radio-chemistry limits had been exceeded.

Violation "e" involved two discrepancies: (1) failure to verify that Indicated Reactor Coolant System Average Temperature and Indicated Pressurizer Pressure were within specified limits at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from March 27 to May 5,1985, while in Mode 1; and (2) failure to verify the above parameters within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> prior to entry into Mode 1 on 5 occasions. These two variations of a.like problem resulted in lengthy operation in Mode 1 during which time certain key plant parameters were not being verified as being within the specified limits as required by Technical Specifications and were a result of failure to process, review and control a revision to the applicable surveillance procedure coupled with the failure to be aware of and implement the appropriate Technical Specification surveillance requirements prior to entry into and during operations in Mode _ - .

"f" involved one discrepancy which resulted in the

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Violation failure to perform a Reactor Coolant System Water inventory balance once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (+25%) from August 16 at 1214 to August 20, 1985, at 0900. This incident resulted in operations in Mode 1 for a period of time exceeding the Technical Specification limits while reactor coolant system leakage went unmonitored and was a result of a management decision to defer performance of the surveillance due to interference with a startup tes During this assessment period the licensee reported 18 incidents of missed or inadequately performed surveillances. Of these, 13 were attributed to personnel error, one to design, manufacturing, construction / installation, and 4 to defective procedures. Many of these reportable events have resulted in violation of License Conditions, Technical Specifications, or NRC Regulations. The NRC recognizes that the licensee's program encompasses hundreds of surveillance procedure requirement Performance of this function has shown a significant increase in total incident occurrences during the last three months of the SALP period. Although the rate has been improving, the numbers of surveillance incidents is considered excessiv Management involvement in the surveillance function peaked about two-thirds through the period when the licensee developed and implemented the Conduct of Operations Improvement Program (COIP). A feature of the COIP was designed to eliminate missed surveillances. Based on the findings of NRC inspections over the last three months of the assessment period it appears that, although the program is technically sound and has provided acceptable technical resolutions from a safety standpoint, management involvement in reducing the numbers of surveillance incidents, has demonstrated a low level of effectivenes The licensee has indicated a willingness to address this issme in response to NRC concerns expressed in the monthly management meetings discussed in Section V.E of this report and is devoting resources to the resolution of the problem through efforts in the areas of monitoring the surveillance system records, increasing awareness of the operating staff in the area of surveillance scheduling requirements, increasing surveillance scheduling requirements, increasing technical staff awareness and interaction with the operating staff, and continuing to monitor and improve the corrective action items designed to eliminate the problem. However, a review of the recent events indicates that these changes are apparently slow in being effective and this indicates a weakness in the progra . Conclusion The licensee is rated Category 3 in this area. The licensee was not rated in this functional area in the previous SAL A significant group of Violations occurred earlier in this assessment period and another significant group occurred at the

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I end of this period, in each case demonstrating unacceptable performance requiring corrective action. Licensee performance has declined during the assessment period, despite several Regulatory Performance Improvement Program activities which were targeted to reducing procedural and personnel error . Board Recommendations The licensee should continue to concentrate a high level of management attention to this functional area to reduce the number of missed and inadequately performed surveillances.

E. Initial Fuel Loading Analysis The initial Unit 1 core was loaded between November 2, 1984 and November 27, 1984. The core loading activities, conducted between November 2 and November 5, 1984, were inspected on a 24 hour-a-day coverage basis by region based inspectors and resident inspectors. Fuel loading activities between November 6 and November 27, 1984, were inspected on a routine basi The licensee's fuel loading crew demonstrated a high degree of training and experience in the performance of their duties resulting in few NRC observations related to documentation, preparation, and execution of the fuel load procedure No violations or deviations were identif ed in this are Delays encountered in the fuel load sequence resulted from equipment malfunctions including the fuel transfer cart drive shear pin failures and source range nuclear instrument noise spikin Management involvement in these two problems resulted in technically sound and thorough resolutions in a timely fashion employing a high degree of conservatism for the safety significance in each case. Throughout the NRC inspection of the fuel load activities, the licensee provided technically sound and thorough responses to NRC observations resulting in acceptable resolutions to technical issues brought to their attentio . Conclusion The licensee is rated Category 1 in this area based on the overall quality of performance during the fuel loading sequence. The licensee was not rated in this functional area in the previous assessment period. Since initial fuel load is a single evolution, no trend has been establishe _ _ _ _ - Board Recommendations None.

F. Preoperational Testing and Startup Testing Analysis The preoperational testing and startup testing inspection effort for Unit 1 consisted of 13 inspections conducted by region based inspectors, and a portion of 16 inspections by resident inspector The inspections consisted of observations of licensee performance in implementing administrative controls; in-depth procedure review, verification, witnessing, and test results review and verification for both preoperational and startup test procedures; and observations of corrective actions for problems identifie There were no violations identified for the Unit 2 preoperational test program. The preoperational testing inspection effort for Unit 2 consisted of four inspections by regional based inspectors and portions of five inspections by resident inspectors. This is considered very little inspection effort. The startup test program for Unit 2 has not yet commence Six violations on Unit 1 were identified as follows: Severity Level IV - Failure to adequately test and evaluate Emergency Core Cooling System (ECCS) remote valve position indications in the preoperationai test program (Report No. 454/84055). Severity Level V - Failure to adequately evaluate the leakage test results of Safety Injection-ECCS check valves in the preoperational test program (Report No. 454/84073). Severity Level V - Failure to adequately evaluate the pump curves of the Boric Acid transfer pumps in the preoperational test program (Report No. 454/84073). Severity Level V - Failure to adequately test the Diesel Generator Fuel Oil System in the preoperational test program (Report No. 454/84073). Severity Level IV - Failure to adequately test the Auxiliary Power System electrical distribution system voltages in the preoperational test program (Report No. 454/85002). Severity Level IV - Failure to adequately evaluate and document the test results of four separate tests in the startup test program (Report No. 454/85008).

A concern with the preoperational test program results review identified late in the SALP 4 rating period resulted in an overall assessment of the licensee's performance as Category 3.

Although improvements from the previous SALP period were initially noted, similar concerns on the adequacy of the results evaluation of the test program were also noted in this SALP period as evidenced by items a., b., c. and f. above. An enforcement conference was held on April 29, 1985, to discuss, in part, these concerns. Violations a. through f. above, occurred prior to the enforcement conference. Subsequent to the enforcement conference, licensee performance in the area of startup test performance improved as evidenced by three full and six partial inspections in the startup test area with no violations noted. It should be noted, however, that subsequent to the enforcement conference, the startup program was completed on September 10, 1985 and the fewer violations are, in part, due to the decreased level of activity in the development of the preoperational and startup test programs. Continued high priority and management attention are warranted to assure attention to detail and rigorous analysis during the preoperational and startup test programs for Unit 2.

In the SALP 3 rating period, 10 violations consisting of 7 Severity Level IV and 3 Severity Level V items t re identified over a rating period of 12 months. In the SALP 4 rating period,15 violations consisting of 4 Severity Level IV and 11 Severity Level V items were identified over a period of 16 months. In the SALP 5 rating period, 6 violations consisting of 3 Severity Level IV and 3 Severity Level V items were identified over a period of 18 months. Considering the longer period for this SALP and the decrease in the number of violations identified, the licensee's performance has improved.

Staffing (including management) appears to be adequate and the licensee remains responsive to NRC concerns and initiatives.

Training effectiveness and the qualification of test personnel was satisfactory and showed a marked improvement over the previous SALP rating period. The effectiveness of staffing, training and the qualification of personnel remains to be demonstrated during the preoperational test program of Unit 2.

New personnel will be involved in this test program and the effectiveness of the transfer of knowledge and experience must be closely monitored to ensure continued satisfactory performance in these areas.

The licensee's resolutions and management involvement in technical issues identified in the course of the performance of the startup program placed sufficient emphasis on the safety significance of issues identified in the performance and review of test result . Conclusion The licensee is rated Category 2 in this area. This is a higher rating than was given in the previous rating perio Although significant improvements were not noted in the performance of test results evaluations, fewer violations were identified following the enforcement conference of April 29, 198 This is, in part, due to the decreased level of activity in the development and performance of the preoperational and startup test program . Board Recommendations Continued licensee attention is warranted to insure the transfer of expertise and experience in the upcoming performance of the Unit 2 preoperational and startup test programs.

G. Fire Protection Analysis During this assessment period, one routine and five special team safety inspections were conducted by region based inspectors to assess conformance of the as-built plant fire protection features, fire protection program implementation and post-fire safe shutdown capability. In addition, portions of 31 inspections by resident inspectors were made to assess housekeeping and the care and preservation of equipmen Three violations were identified as follows: Severity Level V - The licensee failed to implement procedures to verify the quality of fire barrier penetration seals (Report No. 454/84076). Severity Level V - The licensee failed to provide instructions, procedures or drawings which ensured timely review of radiation seal substitutions (Report No. 454/84076). Severity Level V - The licensee failed to provide and maintain three aspects of the fire protection program (Report No. 454/84082).

Subsequent follow-up inspections and meetings with the licensee resulted in the licensee taking appropriate corrective actions for all of the identified violations. Most of the unresolved and open items that were identified have been closed ou During the previous assessment period, the licensee was rated Category 3 in this functional are As noted in the cover letter which transmitted that assessment, the Category 3 rating reflected the Region III view that there was a lack of concerted management attention to the development and implementation of the fire protection program. Further, there was no evidence that the licensee had undertaken a comprehensive evaluation of their fire protection program to establish their degree of conformance with FSAR commitments. As noted in the assessment itself, these problems were compounded by a lack of technical expertise by the plant staff in fire protection.

In response to Region III's expressed concerns in this area, the licensee brought additional technical expertise to bear in fire protection, increased the level of management attention devoted to fire protection and undertook a self-evaluation of their degree of conformance to their commitments. 'The actions resulted in a measurable improvement in performance in the fire protection area.

While problems continue to be identified as noted above, they are of a more isolated nature and are generally dispositioned better than in the past.

Routine housekeeping inspection tours of Unit 1 indicate that the licensee has developed and implemented programs to supplement the on going effort in the areas of plant cleanliness and care and preservation of safety-related equipment. In addition, special cleaning / preservation teams were formed and employed on a full time basis in the areas of component / pipe ending coverings and a wide spread and growing problem of graffiti cleanup. The licensee expended considerable resources in upgrading plant cleanliness and care and preservation of safety-related components during the transition period from construction to operation. The most noticeable effects of this effort were observed in the months immediately preceding issuance of the operating license on October 31, 1984. Limited work activities still in progress in plant-common and Unit 1 areas have afforded the cleaning teams opportunity to gain control of the graffiti problem; however, additional management attention is still required to maintain the cleanliness levels achieve Resident Inspector tours conducted since OL have not discovered housekeeping problems detrimental to safety-related equipment indicating management involvement is adequate.

Routine housekeeping tours of Unit 2 indicate that while the licensee has developed and implemented houskeeping programs, they have not been effective in maintaining an adequate level of cleanliness for the level of construction activity.

Additional management attention is required to achieve and maintain adequate cleanlines . Conclusion The licensee is rated a Category 2 in this area. This is a higher rating than was given in the previous assessment period and is based on appropriate corrective actions that have been taken and generally adequate management responses to concerns raised by the NRC. Noted improvements in this area provide assurance that the quality of installed fire protection features will be maintained to accommodate post-fire safe shutdown given a fire in any area of the plant. Licensee performance has remained the same during the assessment perio . Board Recommendations Non H. Emergency Preparedness Analysis Six inspections were conducted during the period by region based inspectors to evaluate the following aspects of the licensee's emergency preparedness program: (1) emergency detection and classification, (2) protective action decision making, (3) emergency notifications, (4) emergency communications, (5) shift augmentation provisions, (6) emergency preparedness training, (7) offsite dose assessment. (8) independent audits of emergency preparedness, (9) implementat. ion of changes to the program, and (10) followup on items identified during the December 1983 Emergency Preparedness Implementation Appraisa Three inspections were appraisal followup inspections; another involved an allegation regarding provisions for the assembly, accountability, and evacuation of contractors; another was the observation of the annual exercise; and the sixth was a routine inspection of the emergency preparedness progra One violation was identified:

Severity Level IV - During a five month period, the licensee failed to complete quarterly inventories of emergency supplies located in two emergency response facilities (Report Nos. 454/85038; 455/85034).

Appropriate corrective actions for the violation were initiated

• prior to the end of the inspection. This violation is not considered indicative of a programmatic breakdown in conducting periodic inventories of emergency supplie Independent audits of the emergency preparedness program were ad a nte in scope, depth, and frequency. Audit records were complete and well maintained. Administrative procedures were adhered to regarding the preparation, review, and distribution of the emergency plan and its implementing procedure _ ___

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Revisions to the Byron Annex of the generic emergency plan, and implementing procedure revisions were consistent and did not degrade their effectivenes An effective system had been utilized to track and document corrective actions on items identified during drills, audits, and NRC inspection As evident from the followup inspections on items identified during the appraisal, the licensee had a clear understanding of the staff's concerns. Initial corrective actions were appropriate in almost all cases. Closure of the items was generally timely, with few remaining open beyond August 198 These items were closed in December 1984. The licensee's responsiveness to all items identified subsequent to the appraisal followup inspections has been very good. Required responses were received by the established deadlines. All corrective actions were technically sound, thorough, promptly initiated, and were either complete or were being completed on schedul Records associated with six actual emergency plan activations through August 1985 indicated that all situations had been properly classified. The NRC and State of Illinois were initially notified of these emergency declarations in a timely manne Detailed records of notification messages to the NRC and State of Illinois were complete and readily availabl The licensee has maintained a prioritized roster of adequate numbers of qualified personnel to fill well-defined, key positions in the emergency organization. Semi-annual, off-hours drills have been conducted to successfully demonstrate the capability to augment on-shift personnel in a timely manne Proficiency of persons assigned to the onsite emergency organization has largely been maintained through annual training on the generic emergency plan, Byron Annex, relevant implementing procedures, and by participation in drills and exercises. In addition, operating shift personnel have been kept informed of emergency plan implementing procedure changes through a periodic required reading program administered by the Station's Training Department. Based on walkthroughs and observations of participants in the annual exercise, persons assigned to the emergency organization have adequately demonstrated their capabilities to perform their emergency duties.

2. Conclusion The licensee is rated Category 1 in this area. This is a higher rating than was given in the previous assessment period. Licensee performance has improved during the assessment period, particularly in regards to responsiveness to NRC concern The rating is based on the following: the

strength of the emergency preparedness training program, as evidenced during walkthroughs and exercises; the licensee's ability to monitor its own activities and take timely, appropriate corrective actions; and the timely and accurate reporting of emergency plan activations to the NRC and State agencie . Board Recommendations None. Security Analysis During this assessment period, eight inspections were conducted by region based inspectors. Three routine preoperational inspections were conducted by regional based prior to license issuance. Two routine and three special inspections were conducted subsequent to license issuance. The assessment in this functional area was divided into two phases - those issues of the security program required to be completed prior to fuel load, and the full implementation of the security plan after ,

license issuanc Three violations, subsequent to the issuance of the license were identified as follows:

Severity Level IV - Adequate protected and vital area

' access controls in the form of physical barriers were not provided (Report No. 454/84085). Severity Level III - The locked status of vital area doors was not properly verified following a computer outage, resulting in two unlocked doors for approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (Report No. 454/84085). Severity Level IV - Failure to provide adequate access controls to two vital areas because of inadequate physical barriers (Report No. 454/85046).

Violation a. represented a significant breakdown in the security system that occurred prior to initial reactor startu Due to the status of the plant, an act of radiological sabotage was not possible; consequently, enforcement actions were not escalated. Violation b. represented a personnel error that led to the inadequacy of two of the three elements of access control for the affected vital are A proposed imposition of civil penalty in the amount of $25,000 was issued. At the close of the assessment period, the NRC was evaluating the licensee's response to the Notice of Violation. Violation represented a disregard for security procedures by both station and contractor employees. These three violations were

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indicative of a significant programmatic breakdown. Corrective actions, although prompt, were not successful in preventing recurrence. The continuation of similar types of problems necessitated the formulation of a Performance Improvement !

Program with the goal of precluding recurrence. The results of this program will be evaluated during the next assessment period.

During the preoperational phase, in anticipation of initial activation of the program needed at license issuance, the corporate nuclear security office conducted an extensive audit which established priorities for implementation and problem areas. Th3 Quality Assurance audit program on the other hand, is neither as comprehensive nor as effective in identifying causes of problems.

Communications between the site and the corporate nuclear security office were improved during the assessment period through the establishment of the " Senior Nuclear Security Administrator" position onsite. The licensee should consider an increased oversight by the corporate organization in the decision making and operation of the security system.

The licensee's approach to the resolution of technical issues has been viable and generally sound, with the exception of the security computer reliability issue which has involved both software and hardware problems. The issue of security system reliability has not been resolved to date.

Security event reports, under 10 CFR 73.71(c) were accurately identified, but some analyses were marginal. For example, in the initial event involving inadequately protected and vital area access controls, the initial evaluation approach showed a lack of understanding of the issue, resulting in incomplete compensatory measures.

Staffing problems were noted in the security force contract overview, both onsite and in the contractor's branch and corporate offices. Personnel in key management positions changed frequently, contributing to low morale and poor administrative support. Only within the latter portion of the assessment period did the licensee address this issue and require the contract agency to maka necessary changes to improve its performance.

The security training and qualification contributed to an adequate understanding of work and fair adherence to procedures with a modest number of personnel errors. However, the Severity Level III violation, involving inadequately implemented compensatory measures, was in large part due to deficiencies in the guard and firewatch training programs.

Our review has shown that despite the identified individual

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areas of needed improvement, the security and guard force organizations have made steady improvement. The continuing vital area access control problems do not appear not to be caused by major deficiencies in security organization performanc The licensee has taken several actions to improve their performance in the area of vital area access contro These actions have been logical and efficiently implemented but did not achieve the ultimate results of preventing continued similar problems from occurrin . Conclusion The licensee is rated Category 3 in this area. This is a lower rating than was given in the previous assessment perio This rating is based primarily on the licensee's performance subsequent to the issuance of the license. Licensee's overall performance in this functional area has not demonstrated an adequate understanding of the fundamental security issue of protected and vital area access controls and has declined during the assessment perio . Board Recommendations Licensee management should place major emphasis on implementation of a corformance improvement progra [ NOTE: In the first month following and conclusion of this assessment period, another potential Severity Level III violation, involving a degraded, unmonitored vital area barrier for 26 consecutive days, was identified by the licensee. Escalated enforcement action is pending.]

J. Quality Programs and Administrative Controls Analysis Ten inspections by region based inspectors and one inspection by resident inspectors examined activities in this functional area. Activities inspected included quality assurance program review and administration; procurement control; receipt, storage and handling of material; QA records program; document control; the offsite review committee; audit program; offsite support staff; followup of the licensee contracted Independent Design Review (IDR); and review of Systems Control Corporation (SCC)

procurement activitie In addition, meetings were held monthly between NRC staff and plant management to assess operation of the plan Twelve violations were identified:

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! Severity Level III - A material false statement regarding SCC source inspection (Report Nos. 454/84032; 455/84025). Severity Level IV - Failure to maintain records of nonconforming items (Report Nos. 454/84032; 455/84025), Severity Level IV - Failure to include SCC on the Approved Bidders List (Report Nos. 454/84032; 455/84025). Severity Level IV - Failure to take timely and effective corrective actions regarding SCC supplied equipment (Report Nos. 454/84032; 455/84025).

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' Severity Level IV - Six examples of QA audit program and implementation deficiencies (Report No. 454/84040). Severity Level IV - Improper implementation of disposition on nonconforming material (Report No. 454/84044). Severity Level V - Two examples of improper material storage (Report No. 454/84044). Severity Level IV - Changes made to facility which involved an unreviewed safety ~ question without prior Commission approval (Report No. 454/85002). Severity Level V - Failure to control design documents to ensure use of latest revision (Report Nos. 454/85019; 455/85012). Severity Level IV - Failure to translate regulatory requirements and design basis into appropriate procedures and design documents (three examples) (Report No. 455/85027). Severity Level IV - Failure to assure that purchased equipment and services conform to procurement documents (numerous examples) (Report No. 455/85027). Severity Level IV - Failure to establish and execute an effective inspection program to verify conformance with instructions, procedures, and drawings (three basic examples) (Report No. 455/85027).

Four violations, a., b., c., and d. resulted from followup inspections of SCC supplied equipment $ssues originally iden-tified in Inspection Reports No. 454/80004; 455/80004. The violations identified failures by the licensee in dealing with deficient SCC products. The licensee's response was reviewed and determined to be adequate. Followup inspections of the licensee's corrective actions found them to be satisfactor .

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l Followup review of the Integrated Design Inspection (IDI)

findings was also completed in this assessment period. The resolution of the remaining 29 of 96 issues was accomplished with extensive NRC staff / licensee information exchange and review. The complexity of the issues required significant effort from the staff and licensee.

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! Violations f., g., and i. resulted from QA program inspections l and appeared to document isolated instances rather than program

! breakdown Items f. and g. were identified early in the j assessment period and subsequent inspections indicated proper i correction and acceptable performance. Action on item i. was

completed during the inspection and appeared to be an isolated cas Violation e. identified significant problems in the documentation and implementation of the quality assurance audit program. These problems along with several program l weaknesses documented as open and unresolved items were l

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identified early in the assessment period. The licensee took immediate action to address the identified problems and weaknesse Prompt and adequate action was taken and subsequent inspections indicated acceptable performance in this are Violation h. involved a failure of licensee administration to identify and appropriately evaluate a temporary alteration of a protection system, based on an interpretation of a justifi-cation for interim operation that was less conservative than the NRC staff interpretation. The licensee subsequently adopted the staff interpretation and took prompt and thorough corrective actio Prior to licensing, an independent design review (IDR) of the Byron Station was performed by the Bechtel Power Corporation (Bechtel) to provide an assessment by an outside party of the adequacy of the design activities performed by Sargent and Lundy Engineers. One inspection was conducted by regional based inspectors to evaluate the acceptability of Bechtel's effor Areas reviewed included a review of the program and procedures, the indoctrination and training of engineering personnel performing reviews, reviewing monitoring / audit documents, and evaluating potential observations and Bechtel's approach to resolving the safety significance of these observations. For the areas of the IDR examined, the inspectors determined that activities were controlled through the use of well stated and defined procedures. Reviews were thorough, technically sound and performed by experienced reviewer Records and evaluations were found to be generally complete, well maintained, and available. The program procedures dealing with the dispositioning of the observations were functioning properly. No violations or deviations were identified.

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The Construction Assessment Team (CAT) inspected a wide spectrum of Unit 2 construction activities late in the assessment period. Violations j., k., and 1. were identified in the CAT inspection. These violations are not representative of any programatic breakdown. The licensee's response and corrective actions will be reviewed in subsequent inspection The examples cited in these violations are referenced in the appropriate functional area Programatic inspections noted problems early in the assessment period. Actions taken to correct the problems were adequate and program performance appeared to be consistently acceptable for the balance of the perio . Conclusion The licensee is rated a Category 2 in this are This is the same rating as was given in the previous assessment perio Licensee performance has remained the same during the assessment perio . Board Recommendations None.

K. Licensing Activities Analysis During the evaluation period there was a significant level of activit The low power license for Byron 1 was issued on October 31, 1984, and the full power license was issued on February 14, 198 Supplemental SERs were issued along with each of these licenses. Technical Specifications for Byron 1 were issued with the low power license. The Technical Specifications issued with the full power license were made applicable to both Unit The licensee's decision making is usually at a level that ensures adequate management revie The submittals needed to support licensing were generally timely, thorough and technically sound. Upper management was available to resolve concerns and took an active role on certain actions, such as the Technical Specifications and staffing for operation of the volume reduction system. The licensee understands the technical issues and responses are generally sound and thorough. Conservatism is generally exhibited and approaches are viable. In several instances, the licensee challenged staff positions, but only when it believed safety would not be compromise In the weeks prior to issuance of the low power and full power licenses, the licensee had to respond to many NRC initiatives in a short time. The licensee responses were generally timely, sound, and thoroug Events

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at Byron 1 appear to have been reported promptly and accurately. Key positions are clearly identified and responsibilities and authorities are well define The need for operators on shift with previous operating experience was a relatively recent requirement at the time of our review to support issuance of the low power license. The licensee responded by selecting several qualified individuals to act as Shift Advisors on those shift crews that did not meet the requirement. The trainiiig of shift advisors is acceptable and on a par with other recently licensed plant . Conclusion The licensee is rated Category 2 in this are This is the same rating as was given in the previous assessment perio Licensee performance has remained the same during the assessment perio . Board Recommendations Non L Containment and Other Safety-Related Structures Analysis The work activities in this area were essentially complet Consequently, examinations of this functional area were limited to seven inspections by regional based inspectors and a portion of the NRC CAT inspection observing completed work and reviewing installation records and associated documentatio An as-built walkdown and a document review were performed for i selected areas of Unit 1 and 2 containment structural framing, steam generator bolting and supports, main steam support ,

structures, reactor coolant pump support column modifications, t and containment electrical penetrations. Other selected, safety-related, structural welding records were also examine One inspection examined concrete drilling and coring activities, ,

containment structural integrity testing, modifications, and t licensee action on a related IE Bulletin and IE Circular. The  !

results of a statistical sampling plan, established to reinspect  !

high strength bolted connections which were reported as a '

10 CFR 50.55(e) deficiency, and allegations were also examine ;

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For the areas examined, the inspectors determined that the 10 CFR 50.55(e) deficiency was reported in a timely manner, ,

and was accurately identified and that the resulting reviews were effective and technically sound. The installation records l and associated documentation were generally complete, well maintained, and available. Observations during the walkdown

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indicate personnel have an adequate understanding of work practices and have adhered to drawings and procedures. A large .

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portion of inspection resources in this functional area and in Piping Systems and Supports was used in six inspections by regional based inspectors to conduct reviews of allegations and concerns expressed by an expert witness who appeared on behalf of the Intervenors during the remanded ASLB hearing for Byro Three violations were identified: Severity Level V - Failure to assure welding was performed in accordance with the applicable AWS D1.1 Code (Report Nos. 454/84050; 455/84034). Severity Level IV - Failure to maintain retrievable design basis documents (Report Nos. 454/84071; 455/84049). Severity Level V - Failure to specify appropriate code provisions (Report Nos. 454/84071; 455/84049).

The licensee's response and corrective actions related to these violations were reviewed and found to be acceptabl One example in a violation identified by the CAT inspection (see Section J.) concerns structural steel bolts with torque tension below that specified. The licensee has initiated corrective actions which will be inspected in a future inspection. In addition to the violations, a number of design practices were found to be in need of improvement. During the inspection appropriata corrective actions were taken by the architect engineer to effect the needed improvements in the design proces The licensee's actions in response to the concerns forwarded to them for review were timely, thorough, and technically soun A positive attitude was exhibited by the licensee and its architect / engineer toward the prompt resolution of all issues and implementation of improvements in the design proces . Ccnclusion The licensee is rated Category 2 in this are This is the same rating as was given in the previous assessment perio Licensee performance has remained the same during the assessment perio . Board Recommendations

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M. Piping Systems and Supports Analysis l

The work activities in this area were essentially complet Examination of this functional area consisted of seven inspections by regional based inspectors and a portion of the NRC CAT inspection. Areas examined included: (1) attend periodic exit meetings conducted by the National Board of Boiler and Pressure Vessel Inspectors to present their findings and the progress of their comprehensive independent audit of ASME Code l construction and related activities; (2) examine activities l as they relate to the preservice inspection (PSI) of piping l and systems, including a review of the PSI program and

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procedures, equipment and material certifications, personnel l qualifications, selected records of nondestructive examinations, and observation of several liquid peustrant examinations;

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(3) observe completed work and review installation records 1 and associated documentation for reactor coolant pressure l boundary and other safety-related piping, including welder l qualifications, weld repairs, visual examination of completed

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welds, and review of radiographs of field pipe welds; (4) evaluate the design, fabrication, and installation of energy absorbing material used for pipe whip restraints;

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(5) examine IE Bulletin 79-14 as-built walkdown inspection i and design review, including a review of procedures, inspection criteria, inspection measurements, and engineering analyses and evaluations; (6) followup on licensee actions related to previous l

inspection findings, 10 CFR 50.55(e) deficiency reports and other IE Bulletins; (7) examine allegations; and (8) conduct reviews of concerns expressed by an expert witness who appeared on behalf of the Intervenors during the remanded ASLB l

hearing for Byro Four violations were identified:

l Severity Level V - Failure to follow procedures during inspection (Report Nos. 454/84051; 455/84035). Severity Level IV - Four examples of failure to control design activities (Report Nos. 454/84051; 455/84035). Severity Level V - Two examples of failure to have

,

adequate procedures (Report Nos. 454/84051; 455/84035).

i Severity Level V - Failure to identify as-built l

dimension deviations during inspection (Report Nos. 454/84051; 455/84035).

l l

-. ..

The licensee efforts to resolve these violations were reviewed during the course of the inspection and found acceptable prior to the issuance of the full power licens The above violations are not repetitive of violations identified during the previous assessment period and they do not appear to indicate a programmatic breakdown. One example in a violation identified by the CAT inspection (see section J.) concerns concrete expansion anchor embedment dept The licensee has initiated corrective actions which will be reviewed in a future inspectio For tne areas examined, the inspectors concluded that with the exceptions noted above, activities were generally controlled through the use of well stated and defined procedures that were adhered to. The approach used to evaluate IE Bulletin 79-14 findings was generally conservative, technically sound, and thorough. Records were found to be generally complete, well maintained, and available. The records also indicate that preservice inspection equipment and material certifications were current and complete and the personnel performing nondestructive examinations were trained and certifie Review of deficiency reports and IE Bulletin actions indicates that the licensee understood the issues and their reviews were generally timely, thorough, and technically soun . Conclusion The licensee is rated Category 2 in this are This is the same rating as was given in the previous assessment perio Licensee performance has remained the same during the assessment perio . Board Recommendations None.

N. Safety-Relatad Components Analysis The work activities in this area were essentially complet Examination of this functional area consisted of six inspections by regional based inspectors and a portion of the NRC CAT inspection. Areas examined included: (1) evaluate the qualification testing performed to confirm the functionability of the as received Boeing steam generator snubbers; (2) evaluate the modified snubber design, installation, and qualification testing of the Paul Monroe Hydraulic (PMH)

snubbers procured to replace the Boeing snubbers on the Byron Unit 1 steam generators; (3) review installation procedures, observe the installation, and review installation documentation for the PMH steam generator snubbers; (4) evaluate the redesign, modification, and qualification testing of the ITT-Grinnell

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modified Boeing steam generator snubbers; (5) review records and associated documentation related to the welding of the internals installed in the reactor vessels for both Unit 1 and 2; (6) evaluate the dispositicn and repair of indications identified during preservice inspection of the Unit 2 steam generators ~and pressurizer; and (7) followup on licensee actions related to previous inspection findings, 50.55(e)

deficiency reports and IE Bulletin One violation was identified:

Severity Level V - Failure to conduct steam generator snubber testing in accordance with approved procedures (Report No. 455/85004).

In addition, one example from violation c. of Section M. cited a lack of approved procedures to conduct steam generator snubber tests. The licensee's written response to these violations and corrective actions were reviewed and found to be acceptable. These violations are not repetitive of violations identified during the previous assessment period, and they do not appear to indicate a programatic breakdown. A violation identified by the CAT inspection (cee Section J. violation k.)

related to deficiencies in vendor supplied components. The licensee has initiated corrective actions which will be examined in a future inspectio For the areas examined, the inspectors determined that activities were controlled through the use of well stated and defined procedures. With the exceptions noted above, these procedures were adhered t The approach used to evaluate, design, test, and install snubbers was generally conservative, technically sound, and thorough. Records and test data were found to be generally complete, well maintained, and availabl Review of the deficiency reports and IE Bulletin actions indicate that the licensee understood the issues and their reviews were generally timely, thorough, and technically soun . Conclusion The licensee is rated Category 2 in this are This is the same rating as was given in the previous assessment perio Licensee performance has remained essentially constant over the course of the SALP assessment perio . Board Recommendations Non _ - _ _ - _ __ _

_____ _ _ __ _ _ - _ _ _ _ _ _ _ Support Systems Heating, Ventilating and Air Conditioning (HVAC) Analysis The work activities in this area were essentially complet Examination of this functional area was limited to one inspection by regional based inspectors to review numerous allegations relating to the quality of HVAC constructio Two violations were identified: Severity Level IV - Failure to control special processes and personnel qualifications (Inspection Report No. 454/85011). Severity Level IV - Failure to promptly identify and correct conditions adverse to quality (Inspection Report No. 454/85011).

The licensee's written response to these violations has been reviewed and found to be acceptable. An inspection of corrective actions will be made in a subsequent inspection at the sit . Conclusions The licensee was not rated in this area due to the limited nature of the inspection. This area was rated category 2 in the previous assessment perio . Board Recommendations Non Electrical Power Supply and Distribution Analysis Examination of this functional area consisted of ten inspections by region based inspectors, portions of seven resident inspections and a portion of the NRC CAT inspection. Areac examined included:

(1) review of previous inspection findings; (2) observations of raceway and equipment installations; (3) observations of electrical cable installations and terminations; (4) equipment storage and maintenance activities; (5) conductor butt splice reinspection program; (6) as-built drawing walkdown; and (7) tr:ining and qualification of personne Three violations identified by the CAT inspection (see Section J. violations j., k., and 1.) relate to this functional area and also Section Q. Several of the examples of violations were repetitive of violations identified during the previous SALP assessment period, although they are not interpreted to be serious programatic breakdowns. The licensee has initiated

_ . ._ . _ _ _ _ _ _ __ _

corrective actions on these violations and the actions taken will be reviewed during subsequent inspections. In the first violation, one of the three examples identified is electrica This example identifies that the licensee was splicing Class 1E wire inside of panels contrary to the requirements of IEEE Standard 420 which is an FSAR commitmen The second violation identifies numerous equipment assembly / mounting bolts, for certain electrical and mechanical equipment, that were found to be unmarked thus making the quality of these bolts indeterminat In the third violation, example 1 identifies that 4160V switchgear units 2AP05E and 2AP06E and 125V DC fuse panel 2DC11J were not installed in accordance with the requireirents for seismic mounting of Class 1E equipment in that the mounting weld configuration did not match the details shown on approved design drawings. With respect to the 4160V switchgear, similar deficiencies were previously identified on Unit 1 equipment; however, the impact on relevant Unit 2 equipment was not reviewe Example 2 identified that some Class IE electrical raceways have not been installed in accordance with FSAR commitments for separation. Separation violations were also identified in the previous SALP assessment perio Example 3 identified that 5 of 7 motor operated valves inspected contained two or more termination errors that had been accepted by first line QC inspectors. The licensee was responsive to NRC concerns and took appropriate corrective actions to resolve the specific issues from a technical and safety standpoint. However, the licensee was not always aggressive in assessing potential problem areas. The violations identified above represent examples wherein the licensee's management attention should have been more effectiv . Conclusion The licensee is rated Category 2 in this are This is the same rating as was given in the previous assessment perio Licensee performance has remained the same during the assessment perio . Board Recommendations None. Instrument and Control Systems Analysis Examination of this functional area consisted of significant portions of ten region based inspections, portions of four resident inspections, and a portion of the NRC CAT inspection. Areas examined included: (1) review of previous inspection findings; (2) observation of raceway and equipment installations; (3) observation of electrical cable installations and terminations; (4) equipment storage and maintenance activities;

_ ._ . _ _ . _ . - -

. . . - . -. _ . . - -. . ._--

(5) observation of instrument sensing line installations; (6)

conductor butt splice reinspection program; (7) as-built drawing

walkdown; (8) training and qualification of personnel; and also, for certain equipment supplied by Systems Control Corporation, (9) observing reinspection of certain welds; (10) visually examining discrepant hanger welds, (11) attending formal j classroom training to certify walkdown personnel in the inspection of welds; and (12) reviewing the engineering analysis and evaluations performed to demonstrate the structural adequacy

of the discrepant weld !

Due to the overlap between the this area and the electrical area, Section P. of this report, the violations identified by

the CAT inspection and discussed in the electrical area are also applicable to this functional are For the areas examined the inspectors determined that activities were controlled through the use of well stated and defined procedures. The personnel performing the inspections were trained and certified. Reviews were thorough, technically sound, and performed by experienced reviewer The procedures dealing with the performance of these analyses were functioning properly. The structural adequacy of the Systems Control Corporation supplied components was demonstrate The licensee was responsive to NRC concerns and took appropriate corrective actions to resolve the specific issues from a technical and safety standpoint. However, as discussed in Section P, the

,

licensee was not always aggressive in assessing potential problem area . Conclusion The licensee is rated Category 2 in this are This is the same rating as was given in the previous assessment perio Licensee performance has remained the same during the assessment period.

3. Board Recommendations

,

None.

f d

. . _ __ _ _ .._ . _ _ __ _ _ _ _ _ . _ . . _ _ _ . ___ _ _ . _ _ ,. _ _ _ _ . _ _ _ _ _

V. SUPPORTING DATA AND SUPMARIES Licensee Activities During this SALP period, the following activities of interest occurred: October 31, 1984 - Licensee was issued Low Power (five percent)

Operating License No. NFF-2 . November 2 through November 27, 1984 - Initial Fuel Loadin . February 2,1985 - Initial Criticalit . February 4,1985 - Licensee was issued Full Power Operating License No. NPF-3 . February 24, 1985 - Mode 1 (commenced Power Ascension Testing). June 10 through June 13, 1985 - Byron Nuclear Generating Station's Emergency Preparedness exercis . September 16, 1985 - Power Ascension Testing completed, unit turned over to Load Dispatchin . October 25, 1985 - Scheduled maintenance outag hspectionActivities Inspection Data Facility Name: Byron Unit 1 Docket No.: 50-454 Inspection Report Nos.: 84025 and 84026 84028 through 84080 84082 and 84083 84085 through 84088 85001 through 85017 85019 through 85031 85033 through 85044 85046 Facility Name: Byron Unit 2 Docket No.: 50-455 Inspection Report Nos.: 84018 84020 through 84039 84041 through 84057 85001 through 85004

__

85006 through 85010 85012 through 85015 85017 through 85025 85027 through 85029 85038 and 85040 85042 and 85043 Inspection Summary The inspection programs at Byron during the evaluation period were conducted by the NRC using resident and region based inspectors, inspection teams and consultants. An NRC Construction Appraisal Team (CAT) inspection was conducted on August 19-30 and September 9-20, 1985, and is documented in Inspection Report No. (50-455/85027). In addition, a Region I Non-destructive Examination (NDE) van team inspection was conducted on Unit 2 from October 28 through November 8, 1985; the results will be reviewed in the next SALP assessmen TABLE 1 ENFORCEMENT ACTIVITY

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No. of Violations in Each Severity Level Functional Unit 1 Unit 2 Site i Areas III IV V III IV V III IV V l

A. Plant Operations 2 6 1 B. Radiological Controls 1* 3 1 C. Maintenance 1 1 D. Surveillance 6 E. Initial Fuel Loading F. Preoperational Testing 3 3 and Startup Testing i

G. Fire Protection 3 i

H. Emergency Preparedness 1 I. Security 1 2 J. Quality Programs and Administrative 3 1 3 1 3 1 Controls Affecting Quality f 44

. _ _ _ _ _ _ _ _ _ _ - - - -, __ __ __ , _ _ __ __ _ _ _ . -

.- .

l Functional Unit 1 Unit 2 Site Areas III IV V III IV V III IV V Licensing Activities Containment, and ,

Other Safety-Related 1 2 Structures

, Piping Systems & 1 3 Supports Safety-Related Components 1 Support Systems 2 Electrical Power Supply and Distribution Instruments & Control Systems TOTALS 4 26 8 0 3 2 1 7 6 i

• Three violations were combined into one citation Investigations and Allegation Review There were 22 allegation cases initiated during this assessment period. All have been reviewed; substantiated issues are documented in inspection reports and followed to resolution. Violations resulting from inspections of allegations are included in the appropriate functional area section of this SALP repor One, very extensive allegation case was initiated from the concerns expressed by the expert witnesses for the Intervenors which related to the QC Inspector Reinspection Program, Sargent and Lundy Engineers' (the licensee's architect-engineer) design criteria and calculations, computer programs, and several other areas. Most of the concerns originated from the expert witness'

examination of documents during the discovery process for the remanded hearing and from observations made by the expert witnesses during a tour of the Byron facility with the Licensing Board and hearing partie Region III arranged for other NRC offices to review some of the concerns, forwarded many of them to the licensee for review, and retained the remainder of Region III action, Although the concerns were never expressed'to the NRC as allegations, the concerns were nevertheless processed as allegations to assure a complete NRC review.

The Region III action of requiring the licensee to review many of the

concerns was an action consistent with the Commission policy on review of allegations received near the licensing decision dat D. Escalated Enforceinent Action Civil Penalties There were three civil penalties assessed during the SALP period and operational violations identified near the end of the SALP period that may result in another civil penalt Inspection Report Nos. 454/84-32, 455/84-25 assessed a Civil Penalty of $40,000 based on statements made by the licensee regarding inspections of products from Systems Control Corporatio Inspection Report No. 454/85012 imposed a civil penalty of

$25,000 for inadequate control of access in a vital are Inspection Report Nos. 454/85022, 455/85020 assesses a civil penalty of $50,000 for three radiological protection problems collectivel . Orders No orders relating to enforcement were issued to the licensee during the assessment period.

E. Licensee Conferences Held During Appraisal Period Meetings June 6, 1984, an enforcement conference to discuss licensee submittals to the NRC relating to Systems Control Corporation equipmen . July 19, 1984, Management meeting with Vice President and other ,

CECO management representatives in the Lombard, Illinois Holiday Inn to review the systematic assessment of the licensee performance

'SALP 4) of the Byron Nuclear Statio . August 14, 1984, a public meeting was held to discuss matters related to the integrated design inspection (IE, RIII, NRSS, and CECO attended). September 7, 1984, Management meeting with Commonwealth Edison Company corporate staff to discuss the status of their regulatory performance improvement progra . March 7, 1985, Management meeting with representatives to Ceco to discuss the licensee's regulatory improvement program statu . March 27, 1985, Management meeting to discuss the progress of the Byron startup progra _- ._ . .. - - _ __ April 2, 1985, an enforcement conference to discuss vital area access control relating to the door alarm syste . April 29, 1985, an enforcement conference to discuss the operation of Unit I with certain protection system components not seismically qualified, and the adequacy of the technical review of test result i June 24, 1985, Management meeting aimed at improving licensee regulatory performance and enhancing communications between the NRC and CEC Meeting included an update of actions initiated

.

by CECO as a result of past meetings and involved discussion regarding the effectiveness of the program, particularly in the area of individual plant improvement . June 27, 1985, Enforcement Conference to discuss exposure of personnel above administrative limits and other radiation protection problems associated with a May 1, 1985 incore detector inciden . July 22, 1985, Enforcement Conference to discuss continuing radiation protection problems since the June 27, 1985, Enforcement Conferenc . November 22, 1985, an enforcement conference to discuss the inoperable condition of both RHR trains of ECCS and other failures to follow technical specification In addition, meetings were held between NRC staff and licensee plant management on a monthly basis to assess overall facility status through the various phases of licensing. After issuance of the license, the meetings were continued in order to assess plant operation F. Confirmatory Action Letters

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A Confirmatory Action Letter was issued on March 15, 1985, regarding the failure of the 1A and 10 Main Steamline Isolation Valves (MSIVs)

to close and other plant responses during the loss of offsite power tes G. Review of Licensee Event Reports, Construction Deficiency Reports and 10 CFR 21 Reports Submitted by the Licensee Licensee Event Reports (LERs)

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The licensee has held a full power license for Byron Unit 1 since February 14, 198 Unit 2 is still under constructio During this time the licensee reported 64 non-security events to the NRC Operations Cente One of these events was considered significant by the staff and was followed up and reviewed in detail. This event involved air check valves leaking which resulted in two MSIVs failing to close on March 14, 198 .

The licensee issued 91 LERs during the assessment period in 1985. Forty-three LERs were issued during 1984 from the date the Byron plant received its low power license (October 31, 1984) until the end of the calendar year 1984.

The following is the number of LERs classified with each cause, issued during the assessment period:

Number of LERs Cause

, 65 Personnel Error 26 Design, Manufacturing, and Construction /

Installation

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External Cause 15 Defective Procedure 2 Management / Quality Assurance Deficiency 19 Other(cannotbe identified or assigned to another classification)

• Cause is assigned by the licensee according to NUREG - 0161,

" Instructions for preparation of Data Entry Sheets for Licensee Event Report (LER) File," nr NUREG - -1022, " Licensee Event Report System."

Twenty-three of the events reported for 1985 have involved reactor trips. This represents a rate which is significantly higher than average for new plants (average about 12-15 trips per year)

and well above the rate for more mature facilities (about 5-6 trips per year).

Reviews of operating experience at Byron 1 for the fuel load /

low power license period (October 31, 1984 to February 14, 1985) indicate that Byron 1 had a higher frequency of reportable events than other recently licensed plants for similar periods of operation. This higher frequency was primarily the result of two factors: recurring inadvertent actuations of the control room ventilation isolation system; and actuations of the baron dilution prevention system. Both of these problems appear to have been substantially corrected before the end of the SALP perio The frequency of all events in the period is somewhat higher than is typical for new plants. However, the frequency of reactor trips is significantly higher than norma . Construction Deficiency Reports (CDR)s: 10 CFR 50.55(e)s During this SALP performance 9 CDRs were submitted by the licensee under the requirements of 10 CFR 50.55(e). The content of these reports was acceptabl Containment spray pumps identification confused between pumps with differing outlet pressure capacit Acceptability of electrical cable butt splices indeterminate based on inspection results from other site Spot weld connection on Westinghouse 480V breaker connection found questionable, Boeing steam generator snubbers failed to meet test criteri Steam generator snubber under ultrasonic testing revealed material lamination around the piston rod end, Energy absorbing material had lower than specified crush strength, Westinghouse motor control centers circuit breakers AMP fault current capability too lo Seismic qualification of containment floor drain valve Environmental effects on High Energy Line Break (HELB) in Auxiliary Buildin . Part 21 Reports Two 10 CFR Part 21 reports were submitted by the licensee during this assessment perio Airline check valves manufactured by Parker-Hannafin, supplied by Anchor-Darling Valve Co. fail to reseat on slow bleed off of supply side air pressur Degradation of diesel RPM reading giving indication in the standby mode due to power supply noise H. Licensing Actions- NRR Site and Corporate Office Visits August 23, 1984, Audit of river screenhouse analyses at Sargent

& Lundy 49 . . _ . . _ _ - . _ _ _ _ _ _ _ _ _ _ . -

October 2, ?984, Management site visit to determine readiness for fLe1 loa September 20, 1985, Site visit for CAT exit meetin . Commission Briefing February 12, 1985, Favorable' Commission vote to authorize full power operatio . Schedular Extension Granted Non . Relief Granted October 1984, Supplement No. 5 to SER grants relief for preservice inspection and inservice testing of pumps and valve February 1985, Supplement No. 6 to SER grants relief in inservice testing of pumps and valve August 30, 1985, Emergency relief from preservice inspection requirements grante September 24, 1985, Second relief granted (on August 30, 1985, request) from preservice inspection requirement . Exemption Granted October 31, 1984, Exemptions to Appendices A and J granted with low power license for Byron February 14, 1984, Exemptions to Appendices A, E and J granted with full power license for Byron August 27, 1985, Exemption granted to Section 50.71(e)(3)(1) to defer submittal of updated FSAR for Byron 1 and October 28, 1985, Schedular exemption from GDC 4 on leak-before-break for Byron . License Amendments Issued Amendment No. 1 to Low Power License, issued January 28, 1985, adds footnote to table of containment isolation valves that allows certain valves to be opened on an intermittent basis under administrative control Amendment No. I to Full Power License, issued October 1, 1985, i relates to administrative controls for access to high radiation areas during certain emergencies.

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7. Emergency / Exigent Technical Specification January 18, 1985, Emergency Technical Specification authorized by telephone call from Assistant Director for Licensin Formal change issued January 28, 1985 (see Item 6 above).

8. Orders Issued None 9. NRR/ Licensee Management Conference Non . .

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