ML20059G316
| ML20059G316 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 10/25/1993 |
| From: | Farber M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20059G298 | List: |
| References | |
| 50-454-93-12, 50-455-93-12, NUDOCS 9311080065 | |
| Download: ML20059G316 (37) | |
See also: IR 05000454/1993012
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-454/93012(DRP); 50-455/93012(DRP)
Dockets No. 50-454; 50-455 Licenses No. NPF-37; NPF-66.
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Licensee: Commonwealth Edison Company
Executive Towers West III
1400 Opus Place
Downers Grove, IL 60515 '
facility Name: Byron Station, Units 1 and 2-
Inspection At: Byron Site, Byron, Illinois
Inspection Conducted: July 7 through September 30, 1993 __
Inspectors: H. Peterson
C. H. Brown
J. L. Hansen l
V. P. Lougheed
Approved By: Y h /0 f!93
MartinJ.ffarber, Chief '
Date
Reactor Wojects Section lA
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1_nspection Summary
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inspection from July 7 through September- 30. 1993 (Reports No. 50-
454/93012(DRP): 50-455/93012(DRP)).
Areas Inspected: Routine, unannounced safety inspection by the resident
inspectors of previous inspection findings, operational safety verification,
onsite event follow up, material condition, housekeeping and plant >
cleanliness, radiological controls, security, safety assessment / quality
verification, maintenance activities, surveillance activities, engineering and
technical support, and refueling activities.
Results: Of the twelve areas inspected, two violations, one. non-cited
violation, and two inspection followup items were identified. The violations >
pertained to failure to follow procedures (paragraph 3b). The non-cited :
violation pertained to minor security concerns-(paragraph 3f). The inspection l
followup items pertained to engineering and technical support. The following- i
is a summary of performance during this inspection period: l
93110B0065 931101
PDR ADOCK 05000454 l
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Plant Operations
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Overall, performance in this area continues to be good. During this
inspection period, several operational events occurred, including a. Generating
Station Emergency Plan (GSEP) Unusual Event associated with complete loss of
commercial and emergency telephone communications. The licensee's.re:ponse to
this event was excellent. <
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Three operational personnel errors occurred during this period. One
particular incident resulted in an inadvertent initiation of Safety Injection.
Another personnel error resulted in a significant safety hazard to personnel '
in the affected area. These incidents and one other example of a personnel-
error resulted in a violation of NRC requirements (paragraph 3b). '!
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Radiological controls continue to be good. In evaluating radiation protection
goals, the number of personnel contamination events and total personnel ;
exposure were below the projected values during this inspection period. !
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Security continues to be generally good; however, a non-cited violation was :
identified concerning minor incidents which violated the station's' returity i
plan (paragraph 3f).
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Safety Assessment /0uality Verification
Performance in this area remains good. The inspectors reviewed the On-Site .
Quality Verification (SQV) program during the refueling outage. The SQV '
department initiated 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage during the outage. Station management
continues to give high regard to the findings and recommendations identified
by the SQV organization. On the other hand, recurrence of administrative
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errors in the review, distribution, and control of documents, went
unidentified and uncorrected for several years.
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Maintenance and Surveillance
Performance in this area was satisfactory; however, personnel errors ,
pertaining to failure to follow procedures resulted in three operational -!
events (paragraph 3b).
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Enaineerina and Technical Succort
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Performance in this area was good. The inspectors observed portions of-the
Integrated Leak Rate Testing (ILRT) and the Erosion / Corrosion testing programs
-and considered both programs to be good. The licensee identified two
engineering concerns, specifically pressurizer anomalies and differences ,
between Technical Specifications and Westinghouse recommendations. The
inspectors are monitoring the engineering department's progress on these two
items as an inspection followup item (paragraph 7).
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note completion of one of the required test procedures and left
the item blank on the work request. Then, a Senior Reactor
Operator performed an inadequate review of the package and
incorrectly signed the package as complete.
The licensee initiated a root cause analysis on.the SPPs and
LC0ARs deficiencies. The indepth root cause analysis was
performed utilizing a multi-disciplined investigation team. The
results of the analysis indicated specific procedural problems.
These problems included no formal procedural guidance, a lack of
written communication control, and lack of supervisory methods for
controlling these types of documents. The root cause analysis
specifically outlined corrective actions for each causal. factor. _
This incident and the administrative control deficiencies related
to the SPPs and LC0ARs are examples of inadequate procedural
adherence to Byron Administrative Procedures (BAP 1210-1
Attachment A.3, " Review of Special Procedures / Tests / Experiments";
BAP 1310-8, "Special Procedures / Test / Experiments"; BAP 1400-6,
" Technical Specification Limiting Condition for Operatien Action
Requirements"; BAP 1600-IIA.1, "NWR Testing Requirements") and the
requirements of Technical Specification. (TS) Section 6.8,
" Procedures and Programs." Therefore, this is a violation
(454/455-93012-01(DRP)). In view of the licensee's corrective
actions, this violation does not require a written response. This
unresolved item is closed.
b. (Closed) Inspection Followup Item 454/455-93010-01 (DRP): This
item concerned an apparent non-conservative policy in making ,
emergency declarations, identified during the June 7, 1993,.
licensed operator requalification examination. .The inspectors
interviewed licensed operators and discussed the issue with the :
training department. Associated lesson plans were reviewed.
Overall, the station operating and training departments adequately ;
stressed that anytime any value is exceeded pertaining to an j
Emergency Action Level, the appropriate classification shall be
made. This item is considered closed. .
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c. (Closed) Violation 455-91022-01 (DRS): This item concerns the !
failure to adequately take data during the performance of the
Integrated Leak Rate. Testing (ILRT) on Unit 2 containment. During
the Unit 2 refueling outage on September 14, 1991, ILRT-hourly D
data was not recorded from 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> until 2114 hours0.0245 days <br />0.587 hours <br />0.0035 weeks <br />8.04377e-4 months <br />. The 1
reason for the problem was that power supply to the ILRT equipment- !
was inadvertently de-energized. During.the September 1993, Unit 2
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refueling outage, the inspectors reviewed and observed the
performance of the Unit 2 containment.ILRT. The licensee enhanced
the ILRT procedure; including new computer software, data
recording every 15 minutes, and ensuring operations awareness of
the test by enforcing a tagout protection on the power supply for
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the ILRT equipment. Overall, the ILRT. results were satisfactory, l'
and the test was conducted by the engineering personnel in an
excellent manner. This item is considered closed. #
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One violation was identified. l
3. Plant Operations .!
Unit 1 operated at power levels up to 100% in the load following mode-
throughout the report period.
Unit 2 operated at reduced power levels for plant end of life coastdown
in preparation for the refueling outage. On September 2, 1993, a .
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reactor shutdown commenced for the planned 60 day refueling outage. The
reactor was shutdown at 4:41 a.m. on September 3, 1993. e
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a. Operational Safety Verification (71707. 93702) ;
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The inspectors verified that the facility was being operated in
conformance with the licenses and regulatory requirements, and
that the licensee's management control system was effectively. .i
carrying out its responsibilities for safe operation. i
On a sampling basis, the inspectors verified proper control room .
staffing and coordination of plant activities; verified operator
adherence with procedures and TSs; monitored control room :{
indications for abnormalities; verified that electrical power was !
available; and observed the frequency of plant and control room ,
visits by station management. ,
Overall, the licensee's awareness of plant safety continues to be j
good. During this-inspection period, three personnel errors, due ' i
to the failure to follow procedures and lack of attention to "
detail, were identified during the performance of maintenance and '
surveillance activities. These errors are discussed in detail in ,
paragraph 3b. Extensive corrective actions and root cause 'i
analyses have been initiated to prevent recurrence of personnel
errors. ;
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The inspector observed a fire drill associated with a simulated !
warehouse fire in the protected area on August 5, 1993. This was !
a complete activation of fire' brigade personnel and equipment. ,
The fire brigade response was very quick. All personnel donned j
fire fighting gear and participated in actual pressurization and l
use of fire hoses. The drill was an excellent training aid and '
overall' performance was good. :l
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b. Onsite Event follow-up (93702)
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Inadvertent Safety In.iection Actuation i
On September 5, 1993, during the performance of 2BOS 3.2.1.1.a-1, .l
" Unit Two Train A Manual Safety Injection Initiation and Manual ,
Phase A Initiation Surveillance," an inadvertent safety injection I
(SI) occurred. It was identified that during the restoration of ;
train B solid state protection system, the nuclear station
operator (a licensed reactor operator) placed the train B !
multiplexer test switch in the inhibit position, instead of !
placing the input error inhibit switch in the inhibit position, as
required by the procedure. When the subsequent step was
performed, placing the train B mode selector switch to operate, a i
51 signal was initiated due to permissive P-11 signal not being ;
present. At the time of the event, the reactor was shutdown for
the refueling outage and reactor coolant system was at 140 F and j
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350 psig. As a result of this event, pressurizer level increased
approximately 10% (an indication of approximately 1200 gallons !
injected), and reactor coolant system pressure increaset j
approximately 50 psig (from 350 to 400 psig). During the event,
no relief valves were actuated and one train of residual heat i
removal in shutdown cooling remained operating. All systems !
responded as expected. :
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After further review, it was identified that the operator !
performing the surveillance test failed to follow the surveillance l
procedure. Step 1.58, parts a, b, and c of this procedure require l
an independent verification after each part. Had the proper '
independent verification been performed, the verifier could have
identified that the wrong switch was manipulated and could have l
prevented the event. l
Loss of Unit 2 Instrument Buses 211 and 213 ;
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On September 7, 1993, while performing electrical preventive !
maintenance'on inverter 211 for instrument bus voltage adjustment, ,
actions were taken to swap instrument bus 211 power supply. Buses ;
-211 and 213 were initially powered from their respective constant :
voltage transformer (CVT). When directed to shift instrument bus .
211 to its main power source (inverter), the operator incorrectly I
transferred bus 213 to its main feed inverter, which was out of !
service. Not realizing the mistake, the operators then de-
energiz9d bus 211 CVT. This caused the loss of both instrument ;
buses 211 and 213. Operators responded to the event, and _
identified that both source range nuclear instruments (NI) had de- l
energized. Appropriate actions were taken for source range LC0AR !
2BOS 3.1-la, and abnormal operating procedure for the loss of 1
instrument buses, ELEC-2. Buses 211, 213, and both source range !
NIs were re-energized. The licensee initiated an investigation i
encompassing personnel error, adherence to procedures, and human l
factor concerns. j
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Wrono C0. Fire Protection System Train Actuation
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On September 10, 1993, the Electrical Maintenance department was
performing fire protection test 2BHS 7.10.3.2.b.1-7,'" Low Pressure l
CO, System Actuating 18 Month Surveillance," in the . Unit '2 lower j
cable spreading room zone 2S-46. All precautionary. steps were
taken prior to actuation of CO,; however, due to-failure to follow
procedures and a lack of attention to details, the' wrong lower
cable spreading room zone (2S-45) CO, system was manually
actuated. The technicians attempted to terminate the injection, t
but CO, discharged into the room. A pot _ential personnel injury !
was associated with this event. There was a firewatch located. ~!
inside room 25-45! however, the warning alarm prior to CO, _ ;
injection allowed the individual to exit the room and no personnel 1
injury occurred. j
The three preceding incidents are examples of errors in failing to
adequately follow procedures. This is a violation of 10 CFR 50, !
Appendix B, Criterion V (50-454/455-93012-02 (DRP)). ;
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GSEP Unusual Event > l
On July 28, 1993, at 10:22 a.m., an Unusual Event -(UE) was l
declared based on Byron's Generating Station Emergency Plan !
(GSEP), Emergency Action Level 3C, " Loss of Commercial Telephone !
Communications, NARS, HPN, and ENS." The licensee made its ;
initial State, local, and NRC notifications utilizing the .l'
dedicated microwave communications link to the load dispatcher's
office. All notifications were made within the required ,
regulatory time limits. Subsequently, the licensee established a ,
continuous open communications link with the NRC Headquarters +
Operations Center utilizing the microwave communications system j
and tieing it to an outside long distance operator. An additional !
communication link was established by utilizing the Station '
Manager's cellular phone. l
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It was later identified that a fiber optic communications line at !
an outside telephone switching station had been accidentally cut. ;
After verifying that all phone communication systems were ]
permanently repaired and operating satisfactorily, the license j
terminated the emergency event at 2:47 a.m., on July-29, 1993. ;
Considering the uniqueness and difficulty associated with the lack .:
of normal communications, the control room licensed operators and 1'
emergency planning personnel performed their GSEP responsibilities
in an excellent manner.
Stuck Control Rod Durina Reactor Shutdown
At 3:20 a.m.,-on September 3, during the Unit 2 reactor shutdown, '
control rod C-5 of shutdown bank D failed to insert past the
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transition position indication, resulting in a rod misalignment
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with the other three rods of bank D. The licensee entered
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abnormal procedure 2 BOA ROD-3, " Dropped or Misaligned Rod " Blown
fuses for the lift coil of rod C-5. were identified and replaced.
Proper precautionary steps were taken prior to attempting to move ,
the affected rod. At 4:40 a.m., rod C-5 was satisfactorily ;
restored to operation and inserted to its rod bottom position, j,
The inspectors questioned the cause of the blown fuse and the fuse
replacement program for the control rod drive (CRD) system. The ;
inspectors determined that fuses associated with the CRD. :
stationary and moveable gripper circuits were replaced every other ,
refueling outage. Unit I fuses had been replaced in March 1993
during the last refueling outage. Unit 2 fuses had been replaced
during its last refueling outage in April 1992. The investigation .
as to the cause of the blown fuse was inconclusive; however, .the '
fuse control program for the CRD system appeared adequate.
Overall, the station operators responded quickly and performed the
required actions of the abnormal procedures in an excellent
manner,
c. Current Material Condition --
The inspectors performed general plant walkdowns, as well as,.
selected system and component walkdowns to assess the general and
specific material condition of the plant, to verify that Nuclear
Work Requests (NWRs) had been initiated for identified equipment
problems, and to evaluate housekeeping. Walkdowns -included an
assessment of the buildings, components, and systems for proper-
identification and tagging, accessibility, fire and security door
integrity, scaffolding, radiological controls, and any unusual
conditions. Unusual conditions included but were not limited to
water, oil, or other liquids on the floor or equipment;
indications of leakage through ceiling, walls or floors; loose
insulation; corrosion; excessive noise; unusual temperatures; and
abnormal ventilation and lighting.
Considering that Unit 2 was in a refueling outage, the general
material condition inside containment was considered satisfactory.
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Some areas of clutter, loose tools and equipment, and oil spilled
from the steam generator snubber maintenance were observed. The.
atmosphere and humidity within the containment were properly
regulated to ensure safe working conditions.
d. Housekeepina and Plant Cleanliness
The inspectors monitored the status of housekeeping-and plant
cleanliness for fire protection and protection _of safety-related-
equipment from intrusion of foreign matter. In general,
housekeeping and plant cleanliness has improved.
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In the' Unit 2 containment, even with the outage, the housekeeping
and cleanliness condition are satisfactory; however, there are
some. areas of clutter and foreign material which will require- .
extensive cleanup efforts at the conclusion of the outage,
e. Radioloaical Controls
The inspectors verified that personnel were following health
physics procedures for dosimetry, protective clothing, frisking, ,
posting, and randomly sxamined radiation protection ,
instrumentation for operability and calibration. ;
During a tour of the 346 feet elevation of.the auxiliary building, _
the inspectors discovered a gum wrapper, a piece of gum in the
waste gas decay valve aisle, and cigarette butts under the waste
gas decay tanks. These items were brought to the attention of the
radiation. protection personnel. The items were removed and plant .;
management re-emphasized proper radiological controls to all site !
personnel. ?
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Overall, radiological controls continue to be good. Radiation
protection personnel continue to be very responsive to the needs
of the plant. In evaluating radiation protection goals, the
number of personnel contamination events and total personnel -
exposure were below the projected value during the inspection '
period.
f. Security
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Each week during routine activities or tours, the inspectors I
monitored the licensee's activities to ensure that observed i
actions were being implemented according to the approved security i
plan. The inspectors noted that persons within the protected area '
displayed proper photo-identification badges and those individuals
requiring escorts were properly escorted except as discussed
below. . The inspectors also verified that vital areas were locked l
and alarmed. Additionally, the . inspectors also observed that '
personnel and packages entering the protected area were searched
by appropriate equipment or by hand, J
On Wednesday, September 15,-1993, the inspectors identified that a ;
visitor was not in immediate visual contact with-his escort. The
inspectors accompanied him until his escort was located. Followup
investigation by the security department found that the escort and ,
visitor had been separated for approximately two to three minutes ~ s
after a roll-up door was closed between them. ;
During a followup tour with a security officer and a contract crew
foreman the next day, the inspectors discovered an individual
within the protected area who was not wearing his security badge. 1
The individual had removed his shirt, with the badge attached, and
hung it off a piece of scaffolding in the area.
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On September 2,1993, an individual failed his Nuclear General l
Employee Training (NGET) requalification training. According to
Byron administrative procedures, his access to the plant should be
suspended. However, the training department did not communicate- i
the failure to the security department and on September 7, the ;
individual was allowed access into the station. The corrective i
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actions included formalizing communications between the training ;
and security department, and changing the appropriate procedures !
such that the training department will immediately call security l
and inform them of personnel failing NGET requalification. j
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During the month of September, two incidents of issuance of wrong
security badges were identified by the licensee. One incident was ..
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immediately corrected at the badge receipt window. On
September 15, another error in issuing a security badge took about l
two hours to identify. In both events, the administrative ;
security procedure, which required the positive identification of ,
badges prior to issuance, was not rigorously followed. The ;
licensee's security department took immediate and extensive
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corrective actions following the September 15 event, inciuding
individual disciplining.
The above four items are isolated events with little or no safety !
significance, and corrective actions were immediate and i
appropriate. Additionally, the security department has initiated i
the development of a training video concentrating on
administrative security issues, such as visitor escorting
practices and badge receipt responsibilities. It was determined
that these events meet the criteria outlined in 10 CFR part 2,
Appendix C,Section VII.B, and therefore are considered a non-
cited violation of station administrative security procedures.
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One violation and one non-cited violation were identified.
4. Reaional Reauest (92701)
Temporary Instruction 2500/028 " Employee Concerns Proaram" j
The inspectors verified the licensee had implemented an employee
concerns program to provide an alternate path from normal line
management to raise safety concerns. The specific characteristics of
this program and an evaluation of its effectiveness is described on the
attached form (Attachment 1). This temporary instruction is considered
closed.
NRC Technical Trainino Center (TTC) Information Reauest-
The NRC TTC requested updated information pertaining to Westinghouse 4-
loop plants. The request was in.the form of a questionnaire. The
inspectors requested the licensee. supply specific information associated
with the questionnaire. The licensee's response was timely and
thorough.
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Action Item neauest on Post-Fire Shutdown Procedures '
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NRC Headquarters Office of Nuclear Reactor Regulation (NRR) identified
cases where abnormal opera'ing crocedures for achieving and maintaining
safe shutdown from cutside che control room instructed the operators to
isolate both onsite and offsite electrical power sources. While power
to the station is isolated, operators reconfigure shutdown systems and .
isolate electrical circuits tnat could cause spurious signals and !
prevent safe shutdown capability. To conduct a detailed study to -
determine how many plants take this approach and assess the potential ,
risk, copies of plant post-fire shutdown procedures and management of '
onsite and offsite power sources were requested. The inspectors .
identified the following pertinent procedures at the Byron station: .
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- BCA-0.0, " Loss of All AC Power," )
- BOA-ELEC-1, " Loss of DC Buses,"
- BOA-ELEC-2, " Loss of Instrument Bus," and
a BOA-ELEC-4, " Loss of Offsite Power for Modes 3 or 4." '
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No violations or deviatic.ns were identified. -
5. Safety Assessment /0cality Verification (40500. 90712. 92700)
During this inspection period, the inspectors evaluated the scope and I
effectiveness of the On-Site Quality Verification (SQV) program during
the refueling outage. This included the review of the SQV Shutdown Risk .
Assessment Report for Byron Station Refuel Outage B2R04. This report. l
was an independent evaluation of shutdown risk for the planning and ;
scheduling portion of the refueling outage. ,
SQV made eleven recommendations to the station work planning department.
Three recommendations dealt with equipment availability, administrative ,
controls, and plant conditions tied to minimizing risk associated with !
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loss of decay heat removal. Two recommendations dealt with enhancements
to minimize risk associated with loss of reactor coolant system ;
inventory. Three recommendations dealt with issues associated with !
activities impacting loss of AC power. These items particularly l
enhanced the work activities associated with the diesel generator work !
and the system auxiliary transformer work. The remaining three !
recommendations dealt with administrative controls. All recommendations
were appropriately accepted and resolved.
In addition to the shutdown risk review, the inspectors periodically l'
monitored the SQV evaluators on daily field monitoring report (FMR)
inspections. During the month of August, SQV generated'66 FMRs. In the
month of September, the SQV department generated 251 FMRs by providing i
24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage of activities related to the refueling outage. The l
resident inspectors are evaluating a sample of these FMRs and their
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resolution to assess the effectiveness of the process.
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INP0 Assistance Visit
On August 9 through 13, 1993, an INP0 inspection team conducted an
evaluation of licensee's corrective actions associated with the June
1992 INP0 evaluation. This assistance visit was-requested by the
station management to conduct followup inspection, and to evaluate the
Byron excellence review team trending and the integrated reporting
programs. The team consisted of three INP0 evaluators, a peer evaluator
from Crystal River station., and a Byron in-house peer evaluator. No
major concerns were identified during this visit.
No violations or deviations were identified.
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6. Maintenance / Surveillance (62703. 617261
a. Maintenance Activities (62703)-
Station maintenance activities were routinely observed and/or.
reviewed to ascertain whether they were conducted in accordance
with approved procedures, regulatory guides and industry codes or
standards, and in conformance with technical specifications.
The following items were also considered during this review: ..
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; and activities were accomplished by qualified
personnel.
Portions of the following maintenance activities were observed and
reviewed:
- NWR-B04196 - Replace diodes on Unit- 2 Turbine Driven
Auxiliary Feedwater Pump,
- 2CV85238 - 28 CV MB Demin Resin Fill / Flush Gearbox Assembly
Repair,
- NWR-B03393- IPR 013J- Check Source Repair on RM-11,
- SPP 93-049 - Damaged Fuel Assembly Manipulation,
- NWR-803525 - Loading Damaged Fuel Assembly,
- BFP FH-21T2 - Shipping Container Inspection Checklist,
- NWR-B03822-1B Feed Pump low Pressure Governor Valve
Oscillation, ara
- Unit 2 Low Pressure Turbine Disassembly' and Inspection.
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During the last refueling outage in April '1993,'the' Unit 1 upper
internal and fuel assembly misalignment resulted in damage to one
new fuel assembly and guide pins. The inspectors observed the
coordination between operations, fuel handlers, maintenance, and
radiation protection personnel during the handling of the damaged
new fuel assembly in preparation for shipment to Westinghouse
Electric Corporation. Overall, the fuel handling and shipping
activities were well managed.
b. Surveillance Activities (61726)
During the inspection period, the inspectors observed TS required
surveillance testing and verified that testing was performed in .
accordance with applicable procedures, that test instrumentation
was calibrated, that results conformed with TSs and procedure
requirements and were reviewed, and that any deficiencies
identified during the testing were properly resolved.
The inspectors witnessed portions of the following surveillances:
2BHS-XLT-1 - Limitorque Valve Operator Signature on Valve
2SX007,-
- 1A Diesel Generator (DG) Monthly Operability Surveillance,
- New Fuel Receipt Inspection,
a 2BOS 9.4-1 - Unit 2 Containment Building Penetraticn to
Outside Atmosphere Weekly Surveillance, -and-
2A DG 18 Month Surveillance / Maintenance.
Review of 2BOS 9.4-1, performed during'the core refueling, showed
that the surveillance was performed as' required and that all-
requirements were met. Specifically, there were no paths to the
outside atmosphere and the fuel handling building ventilation
could maintain at least a negative 0.25 inches water pressure in-
the building.
During the 2A DG post surveillance / maintenance run, a problem was
identified with a ground fault trip calibration. Engineering
determined that the trip had been set non-conservatively; however,
this trip mechanism was not used or required during emergency
operation of the diesel. Following calibration, the diesel post-
maintenance run proceeded to go smoothly both in the control room
and in the diesel room. Adequate personnel were available to
ensure all necessary parameters were observed and adjustments
completed.
No violations or deviations were identified.
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7. Enoineerinq & Technical Support (37700)
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Information Notice 93-33. " Potential Deficiencies of Certain Class IE !
Instrumentation and Control Cables"
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Byron station performs systematic reviews of all industry operating ,
experience including information notices (IN), bulletins, lNPO I
information, and vendor information. The majority of the followup ;
responsibilities have been recently assigned to the individual sites. .
Issues of generic concerns are assigned to the corporate regulatory i
organization, while the individual sites perform parallel reviews. !
The inspectors performed a review of licensee's actions associated with _ !
IN 93-33. Site engineering, in conjunction with corporate, had reviewed
l- the EQ aspects of electrical cabling and had concluded that Byron's
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l cables were tested and installed per IEEE Std 323-1974, "IEEE Standard
for Qualifying Class lE Equipment for Nuclear Power Generating
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Stations." The corporate staff is participating in an industry group,
called the Nuclear Utility Group on Equipment Qualification (NUGEQ), i
associated with EQ. - '
Discrepancy on Scheduled Removal of Irradiated Reactor Vessel Samole
Capsules i
On September 3,1993, the inspectors became aware of a potential problem
associated with the TS scheduled removal of reactor vessel material
irradiation surveillance specimens.
In preparing for the removal of the irradiated surveillance specimen,-
the licensee discovered that the specimen capsule removal schedule in TS i
Table 4.4-5 was inconsistent with Westinghouse Commercial Atomic Power
(WCAP) documents. The WCAP document recommended a revised schedule for-
future capsule removals based on the latest specimen analyses. TS Table -
4.4-5 accurately reflected the original WCAP recommendations; however, i
after the first refueling outage, the TS table was not updated in
accordance with WCAP revised recommendations.
Westinghouse and site engineering have discussed the inconsistency in
the specimen removal for Unit 1. They determined that the specimen
which was removed in accordance with the TS table can be used to make
the necessary predictions required of the reactor vessel radiation
surveillance program. Therefore, there are no concerns involving Unit 1
reactor vessel operability.
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For Unit 2, Westinghouse has concluded that either the specimen required
by the IS table or the specimen recommended by the WCAP document could
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Although there are no immediate operability concerns on the reactor
vessels, the inspectors will follow the licensee's action to address the
necessary changes to the TS or the WCAP document. This item is
considered as an inspection followup item (454/455-93012-03 (DRP)).
Pressurizer Transients
Two pressurizer transients occurred during the Unit 2 shutdown, which
initiated followup activities by the engineering department.
On September 3,1993, while shutting down Unit 2, the Digital Electro-
Hydraulic Control (DEHC) system induced a main turbine transient causing
pressurizer pressure to decrease to less than 2219 psig, the departure _
from nucleate boiling (DNB)-limit. The operators-immediately~ entered-
the LC0AR 2BOS 2.5-la, "DNB Parameters," and within 5 minutes restored
pressurizer pressure to above 2219 psig. A mismatch in the DEHC
reference and reference demand caused a load increase from 160 to 180
megawatts. This secondary transient caused pressurizer pressure to
decrease. The thermal system engineering department is evaluating this
transient. --
On September 5,1993, wh'ile Unit 2 was in Mode 5 with reactor coolant
temperature at approximately 125 F, pressurizer vapor space temperature
at approximately 400 F, and pressurizer liquid space at approximately
128 F, the'2D reactor coolant pump was started. After the pump was
started, the pressurizer vapor space and liquid space temperatures
equalized at approximately 320 F. The-subsequent cooldown resulted in
rapid temperature decrease to approximately 128*F. 'No TS limit ~was-
violated and the pressurizer cooldown. limit of 200 per hour was not-
exceeded; however, questions exist on proper control of pressurizer
cooldown. The site engineering department was also tasked to. evaluate
this transient. These two items are considered an inspection followup
item (454/455-93012-04 (DRP)).
Erosion / Corrosion Prooram Observation (49001)
During the Unit 2 refueling outage, the inspectors discussed the
erosion / corrosion program with site engineering personnel and conducted
a walkdown of outage related program activities. Interviews with
engineers responsible for program implementation and field personnel
performing the testing indicated that personnel were qualified and
proper attention was being given to piping replacement-, The program
appeared to meet all requirements and was considered proactive in the
testing of small bore piping. The licensee continued to have an
aggressive erosion / corrosion investigation program.
Two inspection followup items were identified.
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8. Refuelina Activities (60710) '
During the refueling outage, the inspectors observed the licensee's fuel
handling operations, including the receipt and storage of new fuel; and
discussed refueling operations with plant operators and fuel handling
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personnel. The licensee used approved procedures for fuel
accountability and movements. Communications between the control room ,
and fuel handlers were effective. The inspectors witnessed fuel ;
handling operations from the control room, in the fuel building, and in ;
containment.
The refueling activities were initiated and are being completed on .
schedule, and are proceeding in accordance with the plan and _ !
requirements. The submerged cameras were a great help in ensuring rods
or assemblies were not attached to the upper internals. Activities i
prior to and during vessel internals removal were satisfactory. '
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During the core offload, a gear failed in the transfer mechanism of the
fuel transfer cart. The fuel transfer canal was required to be drained
to initiate repairs. All proper radiological precautions were taken and ,
only one minor personnel contamination occurred within this highly
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contaminated area. The licensee's response and repair activities were .
excellent. l
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No violations or deviations were identified.
9. Report Review
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During the inspection period, the inspector reviewed the licensee's
Monthly Performance Reports for July and August 1993. The inspectors :
confirmed that the information provided met the requirements of l
Technical Specification 6.9.1.8 and Regulatory Guide 1.16. .;
The inspector also reviewed the licensee's Monthly Plant Status Reports '
for July and August 1993.
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No violations or deviations were identified.
10. Inspection Followup Items
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Inspection followup items are matters which have been discussed with the
licensee, which will be reviewed by the inspector and which involve some 5
action on the part of the NRC, licensee or both. Two inspection
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followup items were identified during the inspection and are discussed
in paragraph 7. i
11. Non-Cited Violations 'l
Non-cited violations are violations for which a " Notice of Violation"
will not be issued. The NRC uses the " Notice of Violation" as a i
standard method of formalizing the existence of a violation of legally !
binding requirement. However, because the NRC wants to encourage and
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support licensee's'in'itiatives for selt-identification and correction lof
problems, the NRC will not generally issue a " Notice of Violation" for a
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violation that meets the tests of 10 CFR Part 2, Appendix C, Section i
VII.B. -A non-cited violation was identified during this inspection and
is discussed in paragraph 3. e
12. Meetinas and Other Activities -
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Management Meetinas (30702)
a.
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On July 29-30 and September 15, 1993, Mr. Martin J. Farber, NRC
Region Ill Section Chief, toured the Byron plant and met with
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licensee management to discuss plant performance, plant material !
condition, and recent personnel errors.
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On September 22-23, 1993, Mr.. Ramin Assa, NRR Licensing Project '
Manager for Braidwood Station, toured the Byron plant and met with !
licensee management for backup site coverage and observation. 1
b. Manaaement Visit by International Nuclear Industry Reoresentatives !
(30702)
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Representative from Hungarv !
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One Hungarian representative, from the Nuclear Power Plant (NPP) !
Paks, visited Byron station during the week of August 16, 1993. ;
He was in this country on an International Atomic Energy Agency- ,j
sponsored scientific information visit that included some labs and ',
other NPPs. The purpose of the visit was to review high- !
technology maintenance practices and methods. I
Representative from Great Britain
The Assistant Outage Manager for Sizewell B, a United _ Kingdom
Central Electricity Generating Board Power Plant, arrived at the .;
Byron station on September 4,1993, for approximately three weeks. i
The purpose of the visit was to observe outage planning and :
implementation during the refueling outage.
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c. Exit Interview (30703) I
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The inspectors met with the licensee representatives denoted in .j
paragraph I during the inspection period and at the conclusion of ;
the inspection on September 30, 1993. The inspectors summarized l
the scope and results of the inspection and discussed the likely l
content of this inspection report. The licensee acknowledged the ;
information and did not indicate that any of the information i
disclosed during the inspection could be considered proprietary in
nature.
Attachment: Employee Concerns Programs
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Attachment'l l
MPLOYEE' CONCERNS PROGRAMS !
PLANT NAME: LaSalle Licensee: CECO DOCKET #: 50-373/374 -
Dresden CECO 50-237/249 .
Quad Cities CECO 50-254/265 :
Byron CECO 50-454/455 i
Braidwood CECO 50-456/457-
Zion CL(Q 50-295/304 ;
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NOTE: Please underline yes or no if applicable and add comments in the space ,
provided. }
A. PROGRAM: ,
1. Does the licensee have an employee concerns- program?
(Yes or No/ Comments) c
The licensee conducts.a Quality First program to identify and j
address employee concerns. Other programs such as the vision
through quality (VQ) search for opportunity (SFO) exist. The VQ l
SF0 program is more oriented toward identifying and developing _ ;
improvement initiatives versus a_ formal program for raising
specific safety issues. Therefore, the completion of this form
will deal only with the QF program.
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2. Has NRC inspected the program? Report # !
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The NRC_had not recently inspected this program.
B. SCOPE: (Circle all that apply)
1. Is it for: I
a. Technical? (Yes. No/ Comments) ,
b. Administrative? (Yes. No/ Comments) l
c. Personnel issues? (Yes. No/ Comments)
The concerns are categorized as security, quality, and management :
but may, in fact, involve any of the above. '
2. Does it cover safety as well as non-safety issues?
(Yes or No/ Comments)
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3. Is;it designed for:
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a. Nuclear safety? (Yes. No/ Comments)
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b. Personal safety.? (Yes. No/ Comments) ;
c. Personnel issues - including union grievances?
(Yes or (Lo/ Comments)
Although it can involve personnel issues, it does not deal -:
with union grievances. ;
4. Does the program apply to all licensee employees? ,
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(Yes or No/ Comments) ;
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5. Contractors?
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(Yes or No/ Comments) L
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This program is not necessarily stressed to contract employees.the ;
licensee believes are not in a position to identify QuaHty First ;
issues such as parking lot pavers. ]
6. Does the licensee require its contractors and their subs to have a j
similar program? r
(Yes or tLq/ Comments)
Ceco administers the entire program.
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7. Does the licensee' conduct an exit interview upon terminating l
employees asking if they have any safety concerns? j
(Yes or No/ Comments) ;
Upon termination, employees are given concern disclosure ;
statements to complete. Exit interviews are given. .The- !
percentage of terminating employees receiving them is dra'stically.- -l
reduced due to a reduction in program manpower since the beginning ,
of the year. '
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C. INDEPENDENCE:
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1. What is the title of the person in charge? ;
Quality First Administrator (QFA)
2. Who do they report to?
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Director of Station Quality Verification
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3. Are they independent of line management? *
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Yes - Reports through offsite quality verification organization
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4. Does the ECP use third party consultants?
No - However, quality verification personnel have been utilized to
do interviews. The QFA determines the appropriate group to do:the
investigation.
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5. How is a concern about a manager or vice president followed up?J
This would be decided on a case by case basis.
D. RESOURCES:
1. What is the size of staff devoted to this program? _
Since the beginning of the year, staff has been cut to one
individual for all six Ceco plants.
2. What are ECP staff qualifications (technical training,
interviewing training, investigator training, other)?
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No specific qualifications exist for the QFA, who has been
involved in the program a number of years. Guidelines for
interviewers are available but there are no specific
qualifications.
E. REFERRALS:
1. Who has followup on concerns (ECP staff, line' management, other)?
The QFA may do the followup himself or assign it to .another group
including line management.
F. CONFIDENTIALITY:
1. Are the reports confidential?
(Yes or No/ Comments)
2. Who is the identity of the alleger made known to (senior
management, ECP staff, line management, other)?
Information on the alleger identity remains with QFA.
3. Can employees be:
a. Anonymous? (Yes/No Comments)
b. Report by phone? (les, No/ Comments)
A toll free. number is available.
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G. FEEDBACK:
1. Is feedback given to the ' alleger upon completion of the followup? :
(Yes-or No - If so, how?) .I
Feedback is given by mail or telephone.
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2. Does program reward good ideas? '
No !
3. Who, or at- what level, makes the final decision of resolution?
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This is determined by QFA in conjunction with line management. ,
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4. Are the resolutions of' anonymous concerns disseminated? ;
No .
5. Are resolutions of valid concerns publicized (newsletter, bulletin ,
board, all hands meeting, other)? l
No
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H. EFFECTIVENESS: l
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1. How does the licensee measure the effectiveness of the program?
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Not measured
2. Are concerns:
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a. Trended? (Yes or Lo/ Comments)
There are too few official " Records of Concern" (ROC) to
warrant trending. The QFA does informally look for common
concerns on items which do not warrant official ROCS.
b. Used? (Yes or No/ Comments) ;
Corrective actions are addressed in the program.
3. In the last.three years how many concerns were raised? '
Closed? What percentage were substantiated?
The QAF screens comments and identifies those to be handled as
official Records of Concern" (ROC).
The following data is for ROCS from 1990 through August 1993. No
formal ROCS have been initiated'thus far in 1993.
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- Closed % Substantiated ~f
LaSalle 2 100 ;
Byron 9- 22 l
Braidwood 6 33 i
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Quad Cities 3 33-
Dresden 4 25 1
Zion 1 0 1
Comments received during or after a refuel outage that the QAF l
determines do not warrant an official ROC are compiled and ;
transmitted to plant management for information.1 This occurs !
several months after the outage. ,
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4. How are followup techniques used to measure effectiveness (random [
survey, interviews, other)? j
No followup techniques utilized except perhaps for contractors !
they see multiple times at different Ceco sites. ,
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5. How frequently are internal audits of the ECP conducted and by- !
whom? .;
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There are no audits of this area. The onsite quality verification ;
superintendent is responsible _ for reviewing information copies of _ <
quality ROCS to determine if additional QA reviews are warranted.
I. ADMINISTRATIVE / TRAINING: 1
1. Is ECP prescribed by a procedure? (Yes or No/ Comments) ;
a
Nuclear Operations Directive (NOD)-0A.12, " Quality First Program j
Directive"
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2. How are employees, as well as contractors, made aware of this. 1
program (training, newsletter, bulletin. board; other)?
The program is briefly described-in Nuclear General Employee
Training (NGET). It may also be mentioned in . occasional safety ,
meetings or departmental tailgates. 'l
ADDITIONAL COMMENTS: (Including characteristics which make the program
especially effective or ineffective.)
In viewing the number of official " Records of Concerns (ROC)," that are- ;
formally tracked, investigated, and resolved, the effectiveness of the :
program is questionable. No ROCS have been generated thus far for 1993. H
This may be partially related to the staff reduction and availability of
personnel to conduct exit interviews. Due to the lack of resources, .
some concerns which would have been handled as official ROCS in previous "
years are now being handled more informally.
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The person completing this form please provide the following information to
.the Regional. Office Allegations . Coordinator and ' fax it 'to Richard Rosano at~ -
301-504-3431.
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NAME: TITLE:- PHONE #:
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David E. Hills / Senior Resident inspector'/ (815) 357-8611
DATE COMPLETED: 09-06-93 1
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