IR 05000454/1983012

IE Insp Repts 50-454/83-12 & 50-455/83-10 on 830224,25,28, 0301-04 & 07-09.Noncompliance Noted:Failure to Design Floor Drain Sys to Meet FSAR Commitments & Failure to Conform to Design Requirements in Preoperational Test

ML20204F214
Person / Time
Site:	Byron
Issue date:	04/12/1983
From:	Reyes L, Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20204F202	List: IR 05000454/1983012 ML20204F195 ML20204F208
References
50-454-83-12, 50-455-83-10, NUDOCS 8304290088
Download: ML20204F214 (5)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Repert No. 50-454/83-12(DE); 50-455/83-10(DE)

Docket No. 50-454; 50-455 License No. CPPR-130; CPPR-131 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Byron Stations, Units 1 and 2 Inspection At: Byron Site, Byron, IL Inspection Condu ted: F ruary 24, 25, 28, March 1-4, 7-9, 198 @ I Inspector * 1. A .

Approved By- L. A. Rey Chief J 3

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Test Pro am Section Inspection Summary Inspection on February 24, 25, 28, March 1-4, 7-9, 1983 (Report N /63-12(DE); 50-455/83-10(DE))

Areas Inspected: Routine announced inspection to review pre-operational test ,

procedures, witness the performance of pre-operational testing and review pre-vious open items. The inspection involved 63 inspector-hours onsite by one NRC inspector including 0 inspector-hours onsite during off-shift Results: Of the three areas inspected, two items of noncompliance were identi-fied in one area (failure to design system which meets FSAR commitments-Para-graph 2b and failure to confirm the design requirements in a pre-operational test-Paragraph 2b and 2c).

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8304290088 830413 l PDR ADOCK 05000454 l G PDR l

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DETAILS

, Persons Contacted

• T. Schuster, Technical Staff

• C. Lenth, Technical Staff

• R. Pleniewicz, Assistant Superintendent, Operating

• W. Burkamper, QA Supervisor, Operations

• D. St. Clair, Technical Staff Supervisor

• R. Ward, Assistant Superintendent, Administration & Support Services D. Peterson, Technical Staff T. Weiss, Project Engineering M. Graham, Technical Staff T. Joyce, Operating Engineer

• Denotes those attending the exit intervie Additional station technical and administrative personnel were contacted

by the inspector during the course of the inspectio . Licensee Action on Previous Inspection Findings (CLOSED) Open Item (82-12-04) This item dealt with the potential for over pressurizing the component cooling water (CCW) heat ex-changers or causing a reduction in heat removal capability due to valve misalignment since the system does not automatically align following an auto start signal to the CCW pump. The inspector re-viewed the Westinghouse equipment specifications for the heat ex-changer and noted that the heat exchanger is warranted capable of twice design flow without damage. In a worst case situation of 2 pumps aligning to I heat exchanger which would occur 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after shutdown, the resultant flow is predicted at 12,123 gpm which is less than twice design or 12,600 gpm. Since the hest exchanger has a 150 psig design pressure, over pressurization would require

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reaching CCW pump shutoff head of 158 psig. Since this would mean no components were being serviced by component cooling water it is not a meaningful example. As soon as the components for which CCW auto starts (RHR Heat Exchangers) are loaded onto the system, the pressure falls well within design. Based on the above discussion, the inspector considered the item close (CLOSED) Unresolved Item (82-21-02) This item has been upgraded to an item of noncompliance. This item dealt with FSAR paragraph 5.2.5.1.a stating the containment floor drain sump weir box design will allow the detection system to respond to a 1 gpm increase in leakage within I hour. However, all containment floor leakage must first pass through an oil separator box before reaching the contain-ment floor drain sump weir box. The oil separator measures 3 feet x 4 feet x 4.5 feet and is calculated to hold approximately 180 gallons below the bottom of the pipe which serves to transport water to the floor drain sump wei In a situation where the separator is

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initially dry and normal leakage is 0, a 1 gpm leak would require 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to fill the oil seaparator before water even started to fill the sump weir box. Since, as stated in the FSAR, no normal leakage is expected to the system and no Technical Specification Surveillances have been proposed (as of the date of finding the item) to ensure the separator stays full, it is reasonable to postulate the separator may be dry or not completely full. Failure to ensure that applicable regulatory requirements and the design basis as specified in the license application are correctly translated in to specifications drawings, procedures and instructions is considered an item of non-compliance (454/83-12-01; 455/83-10-01). Further, in the pre-opera-tional test 2.66.10, Containment Drains, a 1 gpm source of water was introduced directly to the containment floor drain sump veir box and the time to produce an alarm was monitored. This test method com-pletely by passes the oil separator and the drains portions of the

" system". As discussed above, with an initially dry oil separator, the time required to fill the oil separator alone could prevent the detection system from meeting its design requirement of responding to a 1 gpm increase in leakage within I hour. Failure to confirm the design requirements of the system in the pre-operational test is considered to be an example of an item of non-ccmpliance (454/83-12-02a). (CLOSED) Unresolved Item (82-14-02) This item has been upgraded to an item of noncompliance. The item dealt with the FSAR paragraph '

S.2.5.1.b which states, "The weir box design will allow the detec-tion system to respond to a 1 gpm increase in leakage within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />."

The reactor cavity sump weir box is an approximately 1 cubic foot box located at the extreme north end of the reactor cavity floo The reactor cavity floor is stated by the licensee to contain approximately 504 square feet. In a situation where the cavity floor was initially dry and a leak occurred at or near the far end of the cavity floor, the whole cavity floor area may have to be covered before the leak would reach the weir bo In this situation, it is not clear that with a 1 gpm leak, the water would reach the weir box to be detected and alarmed within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The pre-opera-tional test introduced a 1 gpm leak rate directly into the weir thus taking the least conservative approach by not accounting for the cavity floor at all. Failure to confirm the design requirements of the system in the pre-operational test is considered to be an example of an item of non-compliance (454/83-12-02b). Pre-Operational Test Procedure Review The inspector reviewed test procedure 2.3.10, Auxiliary Feedwater, against the FSAR, SER, Proposed Technical Specifications, Regulatory Guides 1.68 and 1.139. The inspector made several ccaments on the test procedure which the licensee agreed to review. This is an open item (454/83-12-03)

pending further discussion with the licensee. Several of these comments l were believed by the station to be most appropriately Project Engineering l responsibility. Accordingly, in order to facilitate addressing the items, the inspector participated in a telephone call with Mr. T. Weiss, CECO Project Engineering on March 11, 1983 on the following subjects:

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. Paragraphs 10.4.9.5.1 and 10.4.9.3.1 of the FSAR appear inconsis-tent as to whether overcranking, high water jacket temperature, and low lube oil press are automatic trips of the diesel-driven aux feed pump. These trips should be designated as acceptance criteria in i the pre-operational tes Vibration and pump room ambient conditions should be included as acceptance criteria in Section 4.5 of the test in accordance with NRC Recommendation 2.2 from page Q10.53-18a of the FSA < The automatic restart of the Auxiliary Feedwater Pumps on a return

) of suction pressure (following a loss) should be acceptance criteri In what test is the ability to, " manually transfer power to the

, essential motordriven AFSW pump from the corresponding emergency diesel generator power supply in the opposite unit," verified?

(From paragraph 10.4.9 of SER)

The inspector also raised a concern on the regulating valves failure position which was resolved by Mr. Weiss. These four comments described above constitute a second open item (454/83-12-04) pending additional

discussion with the license No items of noncompliance or deviations were identifie . Pre-Operational Test Performance The inspector witnessed the performance of portions of test procedures

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2.18.11 Chemical and Volume Control - Charging, Letdown and RCP Seal Injection Logic; and AF 2.3.10 Auxiliary Feedwater as well as prepara-tions for retesting the Safety Injection Accumulators. During the course of the Auxiliary Feed System testing, the inspector noted several examples of piping and system components for the Unit 2 Auxiliary Feed-water System which were not properly protected (with hard cover caps).

Since the Resident Inspector's Office report for this time frame (50-454/83-09 and 50-455/83-07) already included a non-compliance for

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this area, these examples ware added to that repor i

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No other items of noncompliance or deviations were identifie . Management Meeting The inspector attended a management meeting held on February 28, 1983 at the licensee's Byron facility. The minutes of the aceting are documented in Inspection Reports 50-454/83-10 and 50-455/83-0 ;

l 6. Exit Interview l The inspector met with licensee representatives denoted in Paragraph 1 at the conclusion of the inspection on March 9, 1983. The inspector

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i summarized the scope of the inspection and the findings. The licensee acknowledged the statements made by the inspector with respect to the items of noncompliance in paragraphs 2b and 2c. The inspector also participated in conference calls on these subjects on March 14, 1983 and March 18, 1983.

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