IR 05000454/1997020

Insp Repts 50-454/97-20 & 50-455/97-20 on 970909-1016. Violations Noted.Major Areas Inspected:Licensee Operations, Maint,Engineering & Plant Support & Security Event That Occurred on 970815

ML20203D256
Person / Time
Site:	Byron
Issue date:	12/04/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20203D191	List: IR 05000454/1997020 ML20203D186 ML20203D228
References
50-454-97-20, 50-455-97-20, NUDOCS 9712160147
Download: ML20203D256 (22)

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i U. S. NUCLEAR REGUI.ATORY COMMISSION  !

REGIONlli  !

Docket Nos: 50-454,50 455 Ucense Nos: NPF 37, NPF 86 i Report No: 50-454/97020(DRP); 50-455/97020(DRP) '

Uoensee: Commonwealth Edison Ce,Tser,i Facility: Byron Gere..ui.g Station, Units 1 and 2 .

Location: 4450 N. German Church Road Byron,IL 61010 Dates: September 9 October 16,1997

, inspectors: S. Burgess, Senior Residerd inspector N. Hilton, Realdent inspector J. Adams, Braidwood Station Resident inspector G. Pittle, Security inspector, Rill C. Thompson, Illinois Department of Nudear Safety Approved by: Michael J. Jordan, Chief, Reactor Projects, Branch 3

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9712160147 971204 PDR ADOCK 05000454 0 --

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EXECUTIVE SUMMARY q t

Lyron Generating station. Units 1 and 2  ;

NRC Inspection Report No. 60-454/97020(DRP)150 455/97020(DRP) j j This inspedion !nduded aspeds of licensee operations, maintenance, enginowing, and plant .

support. The report covers a 6 week period of residerd inspection. A4 Gor.ci, this inspection i included aspects of s security everd that oocurred on August 16,199 !

Operations i

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• During the Unit 1 technical g+:"ct: , (TS) shutdown on October g,1997, the crew focus was safe and conservative. Operator distractions did not exist. The operators l were attentive to the control boards and clear formal communications were observed by the inspectors. Operator pwfarmance du ing the shutdown was exc%,nt. Consistent exoollent performance was aise observed during the start-up after repairs to the check valve were completed on Odober 16,1997 (Sedion 01.2). ,

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• The operating crew response to the Unit 2 trip on October 10,1997, resulting from the failed rod drive power supplies, was excellerd (Section 01.3). This was demonstrated by good command and control, control of personnel allowed in the control room, team work ,

between the operating crew members, response to annunciators and refwence to procedures and procedural compliance.

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+ The plans to shutdown Unit 2 due to the degraded extraction steam bell.ms were conducted in a thorough and conservative manner. Because of the preexisting plans in place for the maintenance outage, transition from the unexpeded Unit 2 reactor trip into the maintenance outage was smooth. Excellent teamwork was displayed by au departments involved in the mairitonance outage. Decisions concoming scheduling the outages and the impact of each unit's status on the other unit were safe ard conservative '

(Section 01.4).

+ The format of the operations crew shift change brief was changed to condud a tumover at each watch station, then a crew brief was conducted outside the control room followed i by watch relief. At first, the crews appeared rushed to retum to the control room to relieve the watch and a concem existed that the time allowed for the brief may not always be sufficient for a thorough tumover. However, an excellent brief was observed in preparation for the Unit 1 cooldown on October 10,1997. Routine briefs appeared tir constrained; however, when required, the operators took the necessary time for a thorough brief (Section 01.5).

. The licensee had a controlled well managed process to track and trend overdue corrective s,ctions (Section 07.1). ,

• The licensee did not incorporate issued T8 amendments within the stated implementation time for each amendment. This resulted in not having current copies of TS available for 1 personnel involvd in licensed activities, i.e., contiel room operators. Without the current revisions available, the possibihty of not adhering to TS existed. A violation was issued

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i Maintenanon/Survedlance

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• Observed maintenance activities and survemance testing were conducted asocording to

! approved procedures, in socordance with TS, and had appropriate oversight by supervision, system engineer, and quality control personnes. One observed weakness in i procedure esequacy was the expected alarms were nu genwamy included in operations t departmwd survelitance test procedures (sections M1.1 and M1.2).  :

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i I * The inspectors identiflod a poor work practice where personnel signed for performing i steps in a work instrudion after aN work was done, in llou of signing for each step after .

each step was socomplished (Section M1.3)

l * The lloonsee identified several problems associated with the 28 CV charging pump i maintenance that prevented work %': :5, within the expected 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> and delayed

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the pump's retum to servios.- The delay caused operators to begin a TS required i

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shutdown; however, the pump was retumed to servios, tested and declared operable .

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! prior to a sigtWfloant power reduction. The inspector and the licensee determined many of

the problems should have been prevented, including: confusion about whether the pump had been drained or not, lack of a ful and vent procedure, and communloation problems i

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• The receipt of new fuel was property conducted in a safe and expeditious manner. Ptard i personnel were knowledgeable of their responsibilities as evidenced by referral to and

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use of the applicable procedures, their roer-:+=" "T:s, and the use of fuel movemord equipment inspection of the new fuel was thorough (Section M4.1). l Engineering  ;

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• During the shutdown and subsequent startup, the inspectors observed the qualified j

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nuclear engineer (QNE) perform shutdown margin calculations and dilution calculations.

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The QNE provided advice on control rod position to support control of flux distributio The QNE remained out of the immediate area of the reactor controls, only entering the .  !

l area to converse as necessary with the operators. Clear, formal communications

between the QNE and the operators were observed. QNE support was excellerd

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i e During the f ailed extraction steam bellows trending and I.Nning for Unit 2 outage, the i inspectors noted excellent system engineer knowledge loves Scs.us, uJ i

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communications with operators and station management. System engineering provided

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recommendations concoming continued unit operation and corrective actions. System

engineering support for the failed bellows event was excellent (Section E1.2).

i i *- The inspectors reviewed the temporary alterations program and determined that most of i the temporary alterations were due to preparation for the Unit 1 steam generator

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repisoement. The temporary alteration program was woM controlled and the number of temporary alterations was justified (Section E8.1).

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Plant Sucoort l

• Radation protection personnel property performed and documented surveys of the new fuel and shipping containers. The roosipt of new fuel was well supported by the redah  ;

protection personnel (Section R1.1).  :

• Observed worker contamination control practicos were good and the transition from a three stop off pad program to a single stop off pad program was successfully implemented (Section R2.1). .

. A nove6ponso violation was cited for failure to comply with eaoort requirements within the protected area. The incident demonstrated a lack of sufficient knowledge of escort ,

requirements by both a visitor and an escort (Section 88.1).

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I Resort Details l

I Summary of Plant Status t

UnN 1 operated at or near fun power dudng this inspection pedod untN October 9,1997, when a [

todmioal specincet!cn (TS) required shutdown was commenood due lo excesalve emergency  !

oore cooling system (ECC8) check valve leakaps Anor repaidng the leeking check valve, a stut up was completed on October 15,1997, and the unk was retumed to full powe ;

Unit 2 operated at or near full power untN October 10,1997, when a reactor trip occurred due to a !

degrading power supply in the rod drive control system. The unit remained shutdown for previoush planned repair of an extraction steam bellows on a low pressure turtaine.

I j L Oserat: ens

01 Conduct of Operations 01.1 General Comments (71707)

Using in-@i Procedure 71707, the inspectors ocnducted frequent reviews of ongoing plant operations. In general, the conduct of operations was professional and (

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safety conscious. Observations indicated that the operations staff was krc;id-;;:de of

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plant conditions and responded promptly and appropriately to alarms. Specific events and noteworthy observations are detailed in the sections belo l

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01.2 UnN 1 Outage Due to Excessivsf&QB_Qbeddabtgleghagg l r

On October 9,1997, during the performance of the monthly ECCS venting surveillance, gas was vented from the safety ir(ection (81) discharge piping. The licensee determined that the source of the gas was nitrogen saturated water leaking from an 81 accumulator through 31 cold leg check valve 1818d19C. The operators noted that the 1C 81 accumulator level decreased from 54 percent to 42 paroent duri,Q the test performanc The inspector calculated this to be about 80 gallons. Water in the ti! oiping was saturated w'th nitrogen from the 81 accumulator and then came out of solution when the setme wr4 recauxl downstream of the vent valve. Ultrasonic testing verified that the 81 piping was full of water. Check valve testing verifled that seat leakage through the check valve was approximately 5 ppm, which exceeded the T8 3.4.6.2 limit of 1 gpm. In  :

response, the plant commenced a power reduction and plant shutdown to repair the check valv The inspedors observed porticens of the shutdown. The crew focus was on shutting riown Unit 1 in a safe and conservat!ve, yet in a timely menner. Operator distractions did not exist. The operators were attentive to the control boards and clear formal communloations were ot.aerved by the inspectors. The inspectors observed the operators manually trip the teactor after taking the tutt>ine off-line and noted that all control rods inserted as expected. The inspectors concluded that operator performance during the shutdown was excellent. The inspectors also noted consistently excellent .

performance during observations of portions of the subsequent start-up after repairs to check valve 1818819C, on October 15,199 .

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01.3 Unit 2 Reactor Trio

inspection Scope (717,9Z)  ;

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The inspectors observed the operating crew's response s ' c:'f; following a UnN 2 i

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reactor trip. The inspectors also conduded a !="c;. up on the apparent cause of the tri Observations and Findinas  :

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On October 10,1997, an automatic reactor tdp occurred due to a degrading power supply

in the rod drive (RD) control system during maintenance troubleshooting. The inspectors '

observed the licensee stabilize the plant immediately fotowing the trip. Operator 1 manning was effective with a balance maintained between an adequate number of .

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operators and preventing congestion in the cont,al room. G3od command and control  !

existed as wen as team work between the shift technical advisor (STA), unN supervisor, 1 and rcscior operators. The inspectors observed that procedures were fotom t Annunciator response was appropriate with the sequence of events reoceder used and  ;

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the appropriate response procedure referenced. AN safety-folated equipment furictioned

- as expecte On the previous day, a Rod Control Non-Urgent Failure alarm cycled on and off in the control room, which precipitated the troubleshooting by maintenance personnel. The troubleshooting revealed that both redundant power supplies were failing. After i discussions with Westinghouse, the licensee decided to instsN an extemal power supply ,

to power the RD cabinet while the two degraded power supplies were changed ou Westinghouse indicated that this had been successfully completed at another facility.

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When the extemal power supply was connected to the 24 voit but, the reactor tripped on _

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high negative flux rate, due to one or more control rods falling. At that time, both power supplies were near the trip setpoint.

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The licensee's investigation revealed that the power supplies could fail in a manner that was not detectable on-line by the current system design. Westinghouse Technical Bulletin (TB) 8710 described the issue and proposed either a modification to inorosse the sensitivity of the power supply failure detection circuit by the installation of a shorting

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resister, or periodically testing the power supply output dunng shutdown. The licensee determined at the time that the failure appeared to be infrequent and chose to perform the periodic testing on the power supplies. -

On this occasion, the licensee checked au 20 power supplies for each unit and identified that a total of six power supplies had this undetected failure. The failed power supplies l were replaced. The current power supplies were aN installed around 1990 with i approximately one failure identifed por year since then. AN previous failures had been

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annunciated. The licensee continued to work with Westinghouse to determine if the failuies were age related. The inspectors considered the licensee's initial root cause -

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Investigation and short term corrective actions appropriate. At the end of the inspection period, the licensee was reviewing potential modifications on the RD system as a long term corrective action, Gnngluslops  !

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The inspectors concluded that the operating crew's response to the Unit 2 trip resulting from the failed rod drive power supplies was exce#en .

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01.4 Extreption Sim Bebows Deer 4Miguen Inspectiori Soone (71707) l

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TI. , inspectors reviewed the licensee's plans to shutdown Unit 2 to repair an extraction

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steam bellows on a low pressure turtnn '

! Observations go(8)tgggga

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In September, be lloonsee noted a decrease of w.._._-, 30..._m..___ electric due

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to a degradation of m extraction steam bellows on a low pressure tuttnne. The bellows are inside the main condenser. Tha licensee developed a plan for a maintenance outage :

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on october 11,1997, to repair the bdows. The inspectors reviewed and discussed the plan with system enginearing, plard operations, and site quality vert 6 cation personne !

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Based on those discussions, the inspectors concluded that the planned outage was wen

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organized with excellard teamwork displayed by au departments involved. Management's ,

decision to entw the meintenance outage prior to further bellows degradation was considered conservative and proactive.

The T8 required shutdown of Unit 1 (Section 01.2) during the earty moming of October 10,1997, caused the lloonses to pnstpone the Urdt 2 outage untN after Unit i 1- was repaired. The inspectors oor,sidered the delay prudent to minimize distractions and

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a potent!al loss of focus caused by outages on both unit '

After Unit 2 'rippe 8 on October 10,195#7, the licensee held Unit 2 stable and focused on

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the T8 required shutdown and cool down of Urd 1. The licensee then decided to enter 1

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the previously planned Unit 2 outage after Unit 1 was repaired. The outage was delayed >

a few days until sufficient information was obtained regarding the trip. The outage i

duration was rJeduled for approximately 14 days. The inspectors noted that the transition into the planned maintenance outepe ws smooth due to the proplanning that had already taken place fnr D- bellows maintenance outage.

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The inspectors concluded that plans tc shutdown Unit 2 due to the degraded bellows was i

conducted thoroughly and contarvatWely. Decause of the preexisting plans in place for the maintenance outage, transition from the unexpected Unit 2 reactor trip into the

' maintenance outage was smooth. Excellem teamwork was displayed by aN departments involved in the maintenance outage. The 'aspectors considered all of the licensee decisions concoming scheduling the outages and the impact of each unit's status u,) the

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vther unit safe and conservative.

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01.5 Shift Briefing Format Change On Septert,ber 2g,1997, the lies che thangeft she fnma* of the operations crew brief.

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Before September 2g, the operatom tumea uver ar'd ret'sved at each watch rtetion and then conducted the crew brief in the control room. The tumover process was changed to conduct a tumover at each watch station, then a crew brief was conducted outside the

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centrol room followe1 by watch relief. The licensee's expectation was for the brief to :

typically bs conducted within approFimately 15 minutos. On several occasions, the inspectors observed that the crews appeared rushed 'a retu n to the control room to relieve the watch. The inspecors were concemed that the time allowed for the brief may

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i not always be suf6aient for a thorough twief. However, the inspectors observed an !

excellent twief in preparation for the Unit 1 cool down on October 10,1997. The twief was thorough and focused. The shift manager focused on operations diteding M acuvities l

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and that the's were no priorities greater than condm 'ng a safe and expeditious cooldown. The inspectors conduded that although daily, routine briefs appeared time :

t constrained, when required, the operator staff would take the time necessary for a ;

thorough tumove Quality Assurance in Operations

07.1 Overdue Correcuve Actions Backlon and Trondina , Insoodion Scope (71707)  :

The inspectors revi+wed the licensee's overdue correcuve action bacidog and trend. The i review consisted primarily of discussions whh licensee persoane Observations and findinns

The licensee trended the overdue corrective actions for signi6 cant action item Correcuve actions from the following were trended; Lloensee Event Reports (LER), Notice of Violations (NOV), Security Event Reports (SER), Root Cause Reports Trond Reports, i

and Correcuve Action Records (CAR). The performance crHerlon was less than or equal

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to 15 over due corrective action items per calendar quarter. The licensee's total for the second quarter was 10. Thus, the overdue corrective actions wort well controlled and monHored. The inspectors noted that the reported number of overdue corrective scuons was actually those Hems that were more then 2 da/s late. The licensee allowed 1 day for a grace period and 1 dsy for computer update. The inspectors noted that an extension of the due date was granted by the cognizant superintendent or someone with that technical signature authorit , Conclusions

The inspectors concluded that the overdue correcuve ac6ons backlog and trending was acceptabl Miscellaneous Operations issues (92700,92901)

08.1 (Closed) LER 50-455/93006-01: Reactor trip / turbine trip due to a solid state protocuon system (SSPS) universal logic card intermittent failure, in response to the initial root cause findings, the licensee replaced numerous circuN cards in the SSP 8. The inspectors reviewed the results of a Westinghouse investigation of the event, which <

determined that the reactor trip was due to an intermittent failure of a circuit board. The inspectors had no further concems. This item is close .2 (Closed) LER 50-454/94007: 18 wide ran0e hot leg resistence temperature detector (RTD) indication spiked low and could not be restored within limiting condition for operation (LCO) time limit The licensee determined the problem was associated with the

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instrument splice connection inside containment within the bioshield. The location of the problem within containment made it difficult to perform repairs during power operatio Prior to exceeding the LCO time limh the licensee requested a notica of enforcement discretion (NOED). The NOED requested a relief from the TS for the remote shutdown J

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panel that required one operable hot leg temperature (Tw ) wide ren0e temperature

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channel for oed reactor cookt loop. The NOED was granted by the NRC on August 1, 1994, al.3 allowed t,%,1;oonsee to operate with the inoperable Tw wide range temperature channel on B loop until the September 1994 refueling outage. The licensee has subsequently removed the RTDs from the reactor coolant system during modifications. This item is closed.

08.3 (Cioned) LER 50455/96004: Source range detectors identitled as inoperable with reactor

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trip breakers closed due to poor communications during shiR tumover. As discussed in

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NRC inspedion repert 96007, source range detector (SR) N32 was placed in bypass due to spikin0 from electrical noise. This was not communica'ed during shiR tumover. Dudne

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the following shift, train 8 solid state p,tdoction system bimonthly surveillance was l performed, which rendered SR detector N31 inoperable. Once the operators realized that

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both SR detectors were inoperable, SR N32 detector was restored, thus restoring the ,

ability to trip open the roector trip breakers. There were minimal safety consequences

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because of this event. During the period in which the reactor trip breakers were closed, all control rodr, were fully inserted. The inspectors reviewed the licensee's root omse i '

and correc6ve acdons implemented to address the poor communloations and had no further concems. This item is closed.

08.4 (Closed)IFl 50-454/455 960PA1: Both source range monitors out of service with reactor tdp breakers closed. This item is a duplicate of LER 50455/96004, which has been closed in Section 08.3 of this report. This item is close .5 (Closed) LER 50454/95003: Containment leak detecuon systems inoperable and unintentional entry into TS 3.0.3. The TS LCO required that thres subsystems remain l

operable. On September 13,1997, the licensee allowed all three containment leak -

detection r.ubsystems to be removed from service at the same time. Each individual l

subsystem removed from service had a specific action requirement and that requirement

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was met. However, the licensee did not property evaluate the cumulative impact the I individual LCOs had on TS requirements. The LCO action requirements did not allow all three subsystems to be removed from service; therefore, TS 3.0.3 was applicabl TS 3.0.3 required the plant to commence a shutdown within one hour. The inspectors

, reviewed the licensee's corrective acdons, which included the issuance of an operations Daily Order to clari*/ the TG LCO requirements for the containment leak detection

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systems, training to communicate the correct interpretation of T8 requirements, and the revision of operations depa:tment procedures to prohibit entering multiple T8 acdon

statements. The inspector considered the corrective actions adequate to prevent a

recurrence of this problem. This LER is close .6 IBGbolGal Specification (TS) Amendment Distribution.CQ0kel Inspection Scoce (71707)

, On September 26,1997, during a routine control room inspection, the inspectors noted that the control room TS copies did not contain the most recent amendments. The inspectors discussed the !ssue with control room operators, determined the missing amendments subject and effective dates, and reviewed a sample of the amendments that required more restrictive actions for complianc '

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" Observations and Findings l The inspectors identified that the T8 (TS) did not contain amendment 86, which in, posed j requirements related to degrading Boraflex in the spent fuel pool. Further review by the !

operators identified that several amendments were not in the TS. The operators noted i that the existence of scme amendments had been identire d using a daily order. The t i daily order book did not ecoount for all of the amendments that were missing from the T i

Further review by the inspectors and the licensee identified Wd amendments 84 through I i 92 had not been placed in the TS books. The inspectors later noted that amendmords 65 and 92 were not T8 amendments and did not require changes to the T8. The -

licensee's implementation practice included a review of the amendment to ensure that the a,nondment was the same as requested by the licensee, changing procedures if the  !

amendment was less restrictive than currord requirements (more restrictive requirements t

were generally placed in procedures before requesting an amendment), and an on site

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review of the amendment M vertfy all appropriate actions had bu taken prior to inserting

the amendmord Irdo the T8 lcok ,

Amendment 84 was issued June 26,1996, with an implementation date stated on the amendment of 30 days after issue. Amendments 85 through 92 were alllasued in 1997; however, when the issue was identified by the inspectors, all of the issued amendments i had exceeded the implementation period allowed by the amendment.

operations management noted that the issue had been identified by operations personnel

approxir aately one month prior to the identifloation by the inspectors. Additionally, the Manager of Quality and Safety Assessment had identified the issue to station

management and documented the issue with a Site Quality Verification i.etter. Station i

management focused additional personnel on the task of implementing the amendments

. Immediatsly prior to the inspectors' independent ident;fication. However, when the

! Inspectors independently identified the issue, no signife, ant progress had been made imvard distributing the amendments for use in the T3 books.

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Title 10, code of Federal Regulations, Part 19, Section 11 (10 CFR 19.11), " Posting of i notices to workers," paragraph (a)(2) required each licenses to post current copies of the

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license, license condit!ons, or documents incorporated into a license by reference, and ,

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amendments thereto. The inspectors also noted that paragraph (b) of 10 CFR 19.11 allows that if a posting is not practicable, the licensee may post a notice which describes ;

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the document and states where it may be examined. License numbers NPF-37 and 66, Paragraph 2.C(2), stated, in part, that T8 were incorporated into each respective license as Appendix A. Byron station posting indicated that a copy of the current Unit 1 and

, Unit 2 licenses could be located in central files. The inspectors concluded that the failure c to place amendments 84 and 86 through 91 for each unit in the central file and control room copies of the TS and other locations for use by individuals engaged in licensed activities was eight examples of a violation of 10 CFR 19.11 (50 454/97020-01(DRP); 50-455/97020-01(DRP)). The eumples are as follows;-

' Amendment 84, issued June 26,1996, to be implemented within 30 days

Amendment 86, Issued April 2,1997, to be implemented within 45 days

, Amendment 87, issued April 15,1997, to be implemented within 30 days

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, Amendment 44, lasued April 18,1997, to be implemented within 30 days

! Amendment 89, issued May 8,1997, to be implemented within 30 days  !

i Amendment 90 (Unit 1), issued August 13,1997, to be implemented within [

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, Amendment 90 (Unit 2), lasued July 10,1997, to be implemented within 30 days

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3 Amendment 91 (Unit 2), issued August 13,1997, to be implemented within

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The inspedors sampled the amendments that contained more conservauve requirements and did not idenufy any examples of administrative controls and required actions not in Pl ac r the end of the inspection period, the amendments had noe been incorporated into T Approximately four were prepared to be incorporat6J: however, procedure revisions for - t amendment 84 were not complete and therefore the licensee had not incorporated all the required amendments into T Condualcos

i The inspectors concluded that the licensee was not ;e-des in inocrporoting the ,

lasued amendments into T8 and did not adhere to the stated implementation time on each amendment. Further, the inspedora were conoemed that the control room operators did not have the latest version of T8 available in the control room or other locations as appropriate. Without the current revisions, operators had the possibility existed of not adhering to TS,

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08,7 Unplanned Technical Specification Limitina Condition for Ooerailon Action Reautrement Entries The inspedors reviewed the licensee's recent unplanned entries into limiting condition for i operation (LCO) action requirement. The inspectors reviewed the trend and supporting i documentations for the unplanned entries. The inspectors noted that Byron had an 1 unplanned entry total Dreater than most other Commonwealth Edison (Comed) stations, i Discussions with the licensee indicated that there were several potential causes for unplanned LCO action requirement entries. - Potential causes irscluded: Byron /Braidwood have more TS related equipment than the other older Comed sites; the method of .

4- counting entries varied between stations (in May both Byron and Braidwood entered a requwod shutdown LCO. Byron counted the LCO as one for each train (four total) and .

- Braidwood counted the LCO aa one for each unit (two total)); and Byron had entries for ,

acts of nature (spedfically tomado wamings) that were not required at any of the other  ;

Comed station '

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The inspectors conduded that due to the variables in counting methodology, the fad that I i

Byron had several more LCO entries compared with other Comed stations was not a significant conoem. At the end of the inspection period, the licensee was working to resolve the variables between station c

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M1 Conduet et Maintenance l

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M1.1 Maintenance Observations (62707)

- Inspection Scope ,

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The inspedors observed the performance of aN or portions of the following work requests 4 (WR). When applicable, the inspectors also reviewed T8 and the Updated Final Safety - j Analysis Report (UFSAR) for potential laeue !

J e WR 97007524441 Troubleshoot and repair fuel Sandung building t'vitilation !

exhaust damper,0VA69YS +

• WR 96002126941 Chan0e the und 2 spent fuel pump coupling grease ,

• WR 970032439-01 Open and clean the Unit 2 spent fuel room cubicle cooler i 4 .* WR 970097510 01 Repair Unit 2 spent fuel (SFP) cubicie cooler

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1 essential servios water (8X) isoistion valve,28X2165A ,

• WR 970097554-01 Repair Unit 2 SFP oubic's coo'er SX inlet isoistion valve, 28X21658

• WR 970097569 01 Repair Unit 2 8FP cubicle cooler 8X outlet isolation valve, .

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• WR 970097575-01 Repair Unit 2 8FP oubicle cooler SX outlet isolation valve, ;

< 28X21848 ,

Observatiors and Findinos  !

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The inspectors observed that the maintenance activities were conducted socording to

. approved procedures ard were in conformance with T8. The inspectors observed

! maintenance supervisors and sysiom engineers monitoring job progress. Quality control

personnel were also present when required. Wiion applicable, appropriate radiation control measures were in place.

' Condusions Based on the inspectors observations, the laspectors concluded that most of the observed routine maintenance activities were wen performed. However, Section M1.3 i includes observations made duiing SFP oubicle cooler valve repair M1.2 Surveinance Observations (61726) i

inspection Scope The inspectors observed the performance of all or parts of the E"c;fr.g survomance test

_ procedures. The inspectors also reviewed plant equipment and surveillance testing activities against the UFSAR descriptions.

f * - 1808 8.1.1.2.a 1 1 A DG Operability Monthly SurveWance

• 08VS XLT-3 VOTES testing valve 18X034

+ 28V8 7.1.5-2 Main Steam loolation Valves Partial Stroke Test

• 08V8 WW-1 Biannual Deep Wou Pump Structure inspection i

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. OBV8 7.6.c.13 Unit 0 08 Control Room Make-ur 'fstem HEPt Filter f

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Performance Test  !

j * 28081.3.1.21 Moveable Cor: trol Assemblies Quarterty Survoittence

! Obsofvations and Findinos  ;

i The let spectors noted that proper authorization was r-Ad; ebtained from the control l t

room senior teactor operator (SRO) before the start of each survemance tes Components remove.i from servios as part of the surveillance test were identined prior to  ;

commencing the survolliance test and the proper Te limiting condi6on for opereuon action requirement (LCOAR) was entered. At the completion of the survemance test and after -

independent vertflomuon of system restoration, the TS LOOAR was cleared. Test t

- instruments used were vertfled to be calibrated as applicable. The inspectors reviewed completed survemance tests and venfled the surveillance tests met the soceptance critert ;

Mortalde_ConknManernhses ouarterty survemance Test  ;

on September 23,1997, the inspectors observed portions of the control rod quarterly ,

exeroise. During the surveillance test, two annunciators alarmed tiest the operators did not expect. The inspectors observed good com nunications and alarm response i procedure usage. During the operators review of the alarm response procedure, they  ;

realized that the alarms were adually expected. The inspedors questioned the operators if the surveillance test listed the seected alarms. Review of the test procedure indicated that expected alarms were act provided. The operators stated that operauons department surveillance test procedures frequently do not have expected alarms identified. The inspectors noted that instrument mechanics were required to brief ,

operato s on expected alarms during instrument maintenance. The licensee sgreed that listing expected alarms in operstkms test procedures would assist the operators and planned to begin including expected alarms during future routine procedure revision M1.3 ARpnt Fuel Pool Coolina Pumo Cubicle Cooler Isolation Valve Renair Inspection Soooe (6270M i On October 7,1997, the inspectors observed postions of the work required to repair ';

isolation valves for the spent fuel pool cubicle cooler isolation valve. The observation consisted primarily of a procedure review due to the job being nearty complete when the inspectors arrived at the job site. The inspectors reviewed WR's 970097510 01, ,

970097554-01,970097569-01, and 970097575-01, and discussed issues identifed during

. the procedure review with mechanical maintr. nance department managerten ; Obs.stygtions and Findinga

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During the inspectors review of the work instructions on October 7,1997, the inspectors

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noted that the informaGon required in several steps for one WR was not completed, although the freeze sealisolation was in the process of thawing. The inspectors noted that some procedure documentation was not completed, including a signature for l establishment of the freeze seal, documentation of whether or not oortain cornponents ,

l required replacement, and a quality control signature for cleanliness. The inspectors i noted that the same steps in the other WRs were property annotated and signe ;

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- Discussions with the licensee indicated that the management expedation was to l document any required information for the proc.edure step when the step was finishe '

The inspectors agreed that the =Wa% was reasonable and that it would help reduos procedure adherence issues. The i;oensee discussW procedure use expectations during periodic mechanical maintenance training, Conclualons The inspectors cancluded the predios of documenting information on a peocedure after l N work was complete was poor. The inspectors were concemed that, althou0ha failure to follow the procedure was not noted by the inspectors, a sis l. en.) be missed when '

documenting information in a procedure that was not completed W the time the procedure ,

was performe j M1.4 Unit 2 Chemical Volume and Contret System Pumo Mainteranos

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Oa September 8,19g7, the licensee started a number of planned work packages on the 28 chemical volume and control (CV) charging pump. Planned work wao scheduled for approximately 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> and the T8 allowed outage ne was 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Several problems .

prevented work completion within the expected 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> and delayed the retum to service. Several issues were identified by the licensee, including; confusion on wheth a i

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the water had been drained for the pump, lack of a CV pump fill and vont procedure for

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retuming t'w pump to service during normal operating conditions; comtrunications  ;

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problems between operators, mechanics, and system engineers; a leaking weld that required repair prior to the retum of the pump to service; and excessive leakage from the 4 pump outboard seal when the pump was initially started after the maintenance period in accordance with company policy, the operators began a T8 required shutdown

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approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to the end of the allowed outage time. The pump was

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retumed to service, tested, and declarad operable prior le a significant power reduction and Unit 2 retumed to full power. The inspector and the licensee determined several of these issues could have been prevented with proper plannin At the end of the inspection period, the licensee was compieting the root cause evaluation for the CV pump work window. The inspectors considered the 2B CV pump work window an open item pending review of the licensee's root cause and corrective i

actions (50-455 g7020-02(DRP)).

M4 Maintenance Staff Knowledge and Petformance ,

M4.1 New Fuel Recolot Activities Inanection Scoce (62707)

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The inspectors observed the receipt of new fuel, and interviewed fuel handling and radiation protection personnel. The inspectors also reviewed the following procedures:

Byron Administrative Procedure (BAP) 3703, " Administrative Control During Refueling,"

Revision 18; Byron Fuel Handling Procedure (BFP) FH 1, "New Fuel Receipt,"

Revision 10; BFP FH 2, *New Fuel inspedion," Revision 10; BFP FH-3, *New Fuel Transfer To/From Storage Vault," Revision 6; and BFP FH-31, * Fuel Handling Cleanliness Zones and Requirements,' Revision 4,

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. . Observations and Findinas The inspectors observed portions of the new fuel recolpt activities in the fuel handling building. Inspectors verified that plant personnel used and (ollowed the steps included in all procedures used in the movement of the new fuel. The inspectors found the pa>cedures to be well written and easily undersino Inspectors observed the fuel handling supervisor perform inspections of the tamper indicating devices, accelerometers, and the shipping containers. The fuel hand!ing supervisor found all tamper indi: sting devices intact, all accelerometers in the ur ?pped condition, and all shipping containers in good condition. The fuel handling supere or and nuclear eng!neering personnel ins 9ected each fuel assembly according to the requirements contained in BFP FW2 as it was removed from the shipping container. No dwficiencies in the condition o' D a new fuel were iderfifie The fuel handlers were proficient in the use of fuel movement equipi,wnt and radiation protection personnel closely monitored unpacking of now fuel assemblies for radiation and contamination (see also Section R1.1). The inspectors verified that the fuel handling arest of the fuel buliding were property identified as cleanliness zones and controlled according to procedure BFP Fh31, Conclusions The inspectors concluded that the receipt of new fuel was conducted property, safely and expeditiously. Plant personnel were knuwiedgeable of the applicable procedures, their responsibilities, and the use of fuel movement equipment. Cleanliness zones were established and BFP FS31 procedural requirements were observed by the personnel participating in the new fuel receipt. Inspection of the new fuel was thorough, property

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documented and status boards were maintained as required.

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M8 Miscellaneous Maintenance issues (92700,92902)

M8.1 (Closed) LER 50-455/97008: laadequate manufacturer breaker repair program allowed i

wrong parts to be installed. The konsee sent five Westinghouse DS-206 safety-related

! breakers off site for refurt>ishment e a Westinghouse repair facility. On April 30,1997, l the manufacturer issued a non-conformance report notifying the licensee that the five breakers had bee: ofurbished with the wrong closing springs. The wrong closing springs exert excessive force when closing due to increased spring strength. Westinghouse determined that the exc@t iosing force would cause cracking of the breaker pole

, basa after 10 to 15 cyca h c'the five breakers were installed and provided power to l the essential service water gd) cou.ing tower fans. The '3censee considered the fans to

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be inoperable from breaker installation to problem identification. During the time that the refurbished breakers were placed in service and when Westinghouse informed the licensee that the breakers were inoperable the station had unknowingly entered

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TS 3.7.5.b. Te6'nical Specification 3.7.5.b required a minimum of six of the eight high l speed fans to be operable or the licensee must perform compensatory actions. Three ;

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times the licensee had less than the six high speed fans and did not take the required l compensatory actions. The "censee determined that having three SX high speed fans !

out of service for short perUs of times did not have a significant impact on oversil plant safety. This evaluation was based on meteorological conditions and conservative assumptions in design. The inspector reviewed the licensee's safety evaluation, receipt inspection program, and use of qualified vendors for the repair of safety-related I

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= components, The inspector determined that the licensee had adequate procedures in place and had taken proper corrective action. This item is close ,

Ill. Ennineerina E1 Conduct of Engineering E Quahfied Nuclear Enoineer Sucoort Durina Unit 1 Shutdown and St.%upS155ii On October 10,1997, Unit 1 was shutdown due to seat leakage throug i a check valve (Section 01.2). During the shutdown and subsequent startup, the insr. actors observed the qualified nuclear engineer (QNE) support for the operators. The l'apectors observed the QNE perform shutdown margin calculations and dilution calculations. The QNE l provided advice on control rod position to support flux distribution control. The inspectors noted that the QNE remained out of the immediate area of the reactMty contrcls, only entering the area to converse with the operators. Clear, formal communications betwoon

- the QNE and the operators were observed. The inspectors concluded that the QNE support was excellent.

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E1.2 - Enoineerina Supoort for Unit 2 Bellows Dearadation Concems f37551)

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The inspectors discussed the Unit 2 extraction steam bellows degradation described in Section 01.4 with system engineering. During the discussions with the system engineer, the inspectors noted excellent knowledge level, trending, and communications with operators and station management. System engineering provided recommendations conce ming continued unit operation and corrective actions. The inspectors concluded

that sy. tem engineering support for the failed bellows was excellent.

E8 Miscellaneous Engineenng lasues E T;mptatyAlteration Proaram Tia i.wpectors reviewed portions of the temporary alteration program; specifically, the ,

the 2nd the content of the backlog, and the licensee's goals for reduction were reviewe ,

The backlog of temporary alterations primarily depended on the elapsed time since the previous outage. The station goal was to minimize the amount of temporary alteration The backlog received detailed periodic reviews by senior management which included a plan for removing each temporary alteration. Most temporary alterations were a result of planning and preparation for the Unit 1 SG !

The inspectors concluded that the temporary alteration program was well controlled and the number of temporary alterations was acceptabl ,

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fV. Plant Suonort

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R1 Radiological Protection and chemistry (RP&C) Controls R Radiation Protection Monitoring of New Fuel Receipt ,

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4 Jnspection Scope (71750)

The inspectors observed receipt of new fuel and interviewed radiation protection i

personnel.' The inspectors also reviewed the Byron Radiation Protection Procedure (BRP) 5160 6, .* Surveying Radioactive Material Shipments," Revision 6.

j Observations and Findings The inspectors observed radiation protection personnel survey new fuel and the shipping

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containers. The radiation protection technician performed both exposure rate and removable contamination surveys of each shipping container. Inspectors observed the surveys of the exterior and interior of the shipping container, dw fuel's protective plastic j oovering, and the new fuel. No contamination was found.

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The inspectors verified that the radiation de ection instruments were property used and i were in calibration. The results of the surveys were documented sceneg to

BRP 51604.

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! Concluslen

! The inspectors concluded that radiation protection personnel property performed and

- documented the surveys specified in BRP 5160-6. The receipt of new fuel was well

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supported by the radiation protection personnel.

R2 Status of RP&C Facilities and Equipment

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R Contamination Control Proaram l inspection Scort (71750)

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During the inspection period, the inspectors observed contamination control practices and

programs. The inspectors reviewed the implementation of a single step off pad progrant, and the contaminated floor space trending program.

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Observations and Findinas On October 1,1997, the hoensee implemented a single step off pad procedure. The licensee had used three step off pads prior to October 1. The inspectors observed portions of a resin vessel baroscope inspection, specifically observing radiological protection activities. A radiatbn protection technician was present at the job site, _

appropriate radiation surveys had been taken, workers stayed in low dose areas, and the j workers used the single step off pad appropriately. The inspectors did not identify any 1 concems with the new single step off pad procedure, l

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The inspectors also reviewed the licensee's contaminated floor space trend. The station 1 goal was 1.5 percent of the plant floor space excluding high radiation areas with infrequent access, inaccessible areas, vaults, pits, and areas used for contaminated work. During discussions with the licensee, the inspectors noted that the exemption removed some large areas, such as the filter pull area, the area around the spent fuel pool, the laundry, rad waste tunnel, and a roboucs work area from the calculation. The j inspectors' calculations indicated that the total floor space contaminated would ;

approximately triple if the exempted floor space was include l The licensee's definition of infrequent access was not oorisistent between Comed stations. At the end of the inspection period the licensee had resolved the definition of infrequent discrepancy between Comed station The inspector noted that the licensee's program was based heavily on historical dat The licensee had been trending contaminated floor space since the middle 1980's. The inspectors routinely observed radiological conditions during plant inspections. Operators were rarely required to use protective clothing during normal operation and equipment rounds. Although the actual amount of contaminated floor space was greater than the number used by the licensee for trending, the inspectors concluded that the amount of

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contaminated floor space was not a signifcant concem, Conclusions The inspectors concluded that the observed worker contamination control practices were good and the single step off pad program was successfully implemented. Although because of exemptions, the actual amount of contaminaisd floor space was greater than the number used by the licensee for trending, the inspectors concluded that the amount

. of contaminated floor space was not a significant conce S8 Miscellaneous Securtty and Safeguards issues S (Closed) Security Event Report 50-454/97-S01-00 Inspection Scope (81070)

The inspection consisted of an interview with the Station Security Administrator and review of a licensee's Security Event Report (SER) No. 97-S01-00, which documented that a contractor visitor was left unescorted within the protected area for about 30 minute Observation and Findinas On August 15,1997, an NRC inspector observed a contractor visitor (welder) within the protected area without an escort. The NRC inspector assumed respon:ibility for escorting the visitor and called the security department who responded and took apprc,priate actica The licensee's subsequent investigation (as documented In SER 97-S01-00) discovered that the visitor had been left unescorted within the protected area for about 30 minute The visitor had been escorted by the contractor supervisor upon initial entry into the protec;ed area and the supervisor turned the visitor over to another authorized contractor to continue escort responsibilities. During a subsequent relief break, the second escort

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i was assigned anotherjob and left the visitor unescorted. After the break, the visitor 1

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retumed to his work area unescorted. The escost did not arrange for the visitor to be

- escorted by another authorized individual, and the visitor did not take effective actions to

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assure that he was being escorted within the protected area. The inspedor concluded the unescorted visitor was a violation of the station security plan, Section 7.1.2, which

. required visitors to be escorted while within the protected and vital areas (50-454/455-97020-03(DRS)).

The licensee reported the incident by telephone to NRC Headquarters on August 15, .

1 1997, in accordance with 10 CFR 73.71 and the station security reporting requirements, i

A written SER was submitted to the NRC on September 15,1997. Corrective actions identified in the SER included: The visitor and escort were escorted offsite and their access placed on a temporary hold pending completion of the investigation; the escort was counseled and retrained on escort responsibilities; the contractor retrained all field craft personnel and supervisors on escort responsibilities; the contractor quality assurance department performed a sury)illance on all visitors under the contractor's escort responsibilities and determined that the incident was isolated; and the contractor is to perform a follow-up surveillance for escort responsibilities to determine if their personnel are complying with escort responsibilit!as within the protected and vital area Conclusions

, The visitor left unescorted within the protected area constituted a violation of Section 7.1.2 of the station security plan. The inspector concluded that the incident demonstrated a lack of sufficient knowledge of escort requirements by both the visitor and the escort. No written response to the violation was required because the corrective actions identified in the GER appeared adequate to prevent recurrence.

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V. Manaoement Meetinas

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i X1 Exit Meeting Summaiy The inspectors presented the inspection resulta to members of licensee management at l

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the conclusion of the inspection on October 16,1997. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary, 1 No proprietary information was identifie l l

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PARTIAL UST OF PERSONS CONTACTED Ucensee K. Kofron, Byron Station Manager J. Bauer, Healih Physics Supervisor D. Brindle, Regulatory Assurance Supervisor E. Campbell, Maintenance Superintendent D, Eder, System Engineer T Glorich, Operations Manager B. Israel, site Quality Verifcation Supervisor T. Schuster, Manager of Quality & Safety Assessment M. Snow, Work Control Superintendent D. Wozniak, Engineering Manager

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INSPECTION PROCEDURES USED IP 37551: Onsite Engineering i IP 61726: Surveillance Observations 1 IP 62707: Maintenance Observations  !

IP 71707: Plant Operations IP 71750: Plant Support IP 81070: Access Control- Personnel IP 92700: Onsite Follow-up of Written Reports of Nonroutine Events at Power Roador Facilities IP 92901: Follow-up - Plant Operations

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IP 92902: Follow up - Maintenance ITEMS OPENED, CLOSED, AND DISCUSSED Ooened 50-454/97020-01(DRP);

50-455/97020-01(DRP) VIO Failure to incorporate TS amendment 84, 86, 87, 88,89,90,91 50-455 97020-02(DRP) IFl Review licensee's root cause and corrective actions for 2B CV pump work window 50-454/455-97020-03(DRS) VIO A visitor was not adequately escorted within the protected are Closed 50-454/97-S01-00 SER Unescorted visMor in the protected are /93008-01 LER Reactor trip due to an SSPS unive. sal logic card failur /94007 LER RTD failum could not be repaired within LCO time limi bl96004 LER SR detectors inoperable with rea:: tor trip breakers close /455-96007-01 IFl Both SR detectors out of service with reactor trip breakers close /95003 LER Containment Leak detection systems inoperabl /97008 LER Inadequate manufacturer breaker repair program resulted in the installation of wrong parts.

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LIST OF ACRONYMS USED BAP Byron Administrative Procedure BFP Byron Fuel Handing Procedure BRP Byron Radiation Protection Procedure CAR Corrective Act;on Records Comed Commonwealth Edison

, CV Chemical Volume DG Diesel Generator DRP Division of Reactor Projects DRS Division of Reactor Safety

ECCS Emergency Core Cooling System i FME Foreign Material Exclusion gpm Gallons Per Minute LCO . Limiting Condition for Operation LCOAR Limitmg Condition for Operation Action Requirement LER Licensee Event Report NOED Notice of Enforcement Discretion NOV Notice of Violation-PDR Public Document Room QNE Qualified Nuclear Engineer RD Rod Drive System RTD Resistance Temperature Detector SER Secunty Event Report

_ SFP Spent Fuel Pool SGR- Steam Generator Replacement SI Safety injection i SPP Special Plant Procedure SQVL Site Quality Verification Letter

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SR Source Range SRO Senior Reactor Operator SSPS Solid State Protect on System STA Shift Technical Advisor SX Essential Service Water System

TB Technical Bulletin T,<n Hot Leg Temperature TS Technical Specification UFSAR Updated Final Safety Analysis Report WR Work Request

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