ML20137K363

Insp Repts 50-454/96-12 & 50-455/96-12 on 961218-970131. Violations Noted.Major Areas Inspected:Operations, Maintenance,Engineering & Plant Support

ML20137K363
Person / Time
Site:	Byron
Issue date:	03/13/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137K332	List: ML20137K329 ML20137K349 ML20137K363
References
50-454-96-12, 50-455-96-12, NUDOCS 9704070016
Download: ML20137K363 (20)

See also: IR 05000454/1996012

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l U. S. NUCLEAR REGULATORY COMMISSION.

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REGION lil

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Docket Nos: 50-454, 50-455  !

License Nos: NPF-37, NPF-66

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Report No: 50-454/96012(DRP); 50-455/96012(DRP) ,

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i Licensee: Commonwealth Edison Company

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Facility: Byron Generating Station, Units 1 & 2

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Location: 4450 N. German Church Road (

Byron, IL 61010

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, Dates: Decembar 18,1996, through January 31,1997 '

- Inspectors

S. D. Burgess, Senior Resident inspector

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N. D. Hilton, Resident inspector i

C. K. Thompson, Illinois Department of Nuclear Safety

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Approved by: R. D. Lanksbury. Chief,

Reactor Projects, Branch 3

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9704070016 970313  ;

PDR ADOCK 05000454

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, EXECUTIVE SUMMARY  !

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Byron Generating' Station, Units 1 & 2

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+ NRC inspection Report 50-454/96012, 50-455/96012 -

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This inspection included aspects of licensee operations, maintenance, engineering, and l

1 plant support. The report covers a resident inspection conducted from December 18, i

1996, through January 31,1997.

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Operations ~

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i The 2A main feedwater pump (MFP) was c'ainservatively shut down in

response to increasing vibration levels and reactor power reduced as i

necessary until the 2C MFP was returned to service (Section 01.2). ,

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The control room organization changed during the inspection period. The i

l inspectors noted the Unit Supervisors (US) (a new position) were fully aware )

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of activities in progress on their respective units and cognizant of activities

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supervisors (Section 01.3).

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SOV audits and assessments were positive contributors to oversight of i

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station operations (Section 08.1). l

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A 1995 unresolved item involving personnel errors resulting in work on the

wrong unit or train was closed with a Non-Cited Violation. The inspectors

l noted that the corrective actions to reduce personnel errors had been

j effective and that the number of personnel errors had been significantly

reduced since 1995 (Section 08.2).

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A July 1996 unresolved item involving one train of auxiliary feedwater being

inadvertently made inoperable for 8 minutes was closed with a Non-Cited

Violation. The Non-Cited Violation was for failing to follow an administrative

procedure (Section 08.3).

, Maintenance

Overall observed application of FME practices was acceptable; however, the

control of unattended areas was weak (Section M1.1).

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An operator demonstrated a good questioning attitude in the identification of

low flow in the IB essential service water cooler. However, the failure to -

properly use matchmarks for reassembly of components could have been

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' p(evented by reasonable corrective action to other events where safety-

' related oil coolers had not boon reassembled correctly. A violation was

issued. (Section M4.1)

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Operators failed to identify the degraded condition of tho' containment floor -

drain leak detection system when the alarm was locked-in due to a

secondary side steam leak. A violation was issued. (Section E2.2)

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A surveillance procedure was implemented to compensate for the loss of i

alarm function without declaring the system inoperable or performing a

safety evaluation. A violation was issued. (Section E2.2)

j Plant Suncort i

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Previous corrective actions to preclude unattended open water tight doors

were ineffective in keeping the doors closed. A violation was issued. l

(Section F1.1) .

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REPORT DETAILS ,

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Summarv of Plant Status i

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Unit 1 and Unit 2 operated at power levels up to full power during this inspection period.

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1. Operations

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.01 Conduct of Operations . l

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01.1 General Commenta (717071 l

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Using inspection Procedure 71707, the inspectors conducted frequent reviews of j

ongoing plant operations. In general, the conduct of operations was professional '

and safety-conscious., Specific events and noteworthy observations are detailed in i

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01.2 Unit 2 Power Reduction Due to Main Feed Pumo Vibration ,

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a .- Insoection Scone (71707) l

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On January 2,1997, the inspector observed ' portions of a significant reduction in .

electricalload on Unit 2.

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b. Observations and Findinos ,

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4 The licensee was running the 2A motor driven MFP due to maintenance that was  :

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being performed on the 2C turbine driven MFP. The 2A MFP had been running for  !

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approximately 1 week with higher than normal vibrations. System engineering I

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personnel had been monitoring the pump vibration frequently and identified a i

change in the vibration signature on January 2,1997. The system engineer  !

recommended shutting down the 2A MFP and the inspector observed operators ,

reduce power to approximately 50 percent. Full power was restored after the  !

maintenance on the 2C MFP was complete, j

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c. Conclusions 1

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The inspector concluded that the licensee conservatively shut down the 2A MFP

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and reduced power as necessary until the 2C MFP was retumed to service. 1

Operators in the control room carefully monitored and controlled reactivity during )

and after the power change. '

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01.3 Main Control Room Ornarhation Channe I

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The inspectors reviewed the licensee's change to the organization of the Main  :

Control Room (MCR) implemented on January 6,1997. The most significant

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change was the move to unit supervisors. The licensee was using two senior

reactor operators (SROs) in the MCR, but one was designated the Duty Shift

Control Room Engineer (SCRE) and the other the Administrative SCRE. The Duty

SCRE provided direct oversight for both units with minimalinvolvement in the

associated paper work. The Administrative SCRE performed the associated paper

woek for both units. The new organization placed an SRO in a supervisory position

for each unit, with the Unit 1 SRO prc* riding supervision for the common unit

equipment.

The insp6ctors were concemed that the division of duties between the SROs could

produce an area where each SRO thought the other was responsible or cognizant.

The inspectors observed the effects of the organizational change on several _

occasions during the inspection period. The irispectors noted the unit supervisors

were fully aware of activities in progress on their respective unit and cognizant of

activities on the other unit. Communication between the unit supervisors was good

and the inspectors did not observe any issues caused by a failure to communicate.

02 Operational Status of Facilities and Equipment

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02.1 Enoineered Safety Feature System Walkdown (71707)

The inspectors used inspection procedure 71707 and applicable UFSAR sections to

walkdown accessible portions of the residual heat removal system (RH), Division I

and il batteries, and the auxiliary feedwater system (AF). '

Equipment operability, material condition, and housekeeping were acceptable. The

inspectors noted a pipe support in the 2A RH pump room that appeared to be an

inappropriate size. The licensee investigated the concern and concluded that the

support was attached to a roof drain pipe. The licensee's documentation review

concluded that the support was temporary and remained from construction. The

licensee initiated an action request to remove the support and the inspectors had no

further concems. The inspectors identified no substantive concerns as a result of

any of the other walkdowns.

02.2 River Screen House (RSH) Ice issue

During January and February of 1996, the licensee experienced ice clogging at the

RSH. The clogging did not challenge safety-related equipment; however, the

circulating water make-up capability was lost for a period of approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

The licensee designed a two part modification to reduce or eliminate the ice

clogging. A floating boom was installed approximately 3 feet in front of the outer

trash screens. Late in 1996, a floating boom was installed in front of the outer

trash screens. Additionally, a warm water spray was planned to minimize the

needle ice between the ice boom and the intake bay. In January,1997, the

inspector observed the ice boom performance during formation of ice on the river.

The inspector noted that the ice boom was very effective at preventing large slabs

of ice from contacting the outer screens. However, the inspector also noted that

some needle ice was present in the intake bay and that the licensee was using a

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hose to help melt and distribute the needle ice. The inspector concluded that the

completion of the planned modifications, specifically the warm water spray, would

be required to prevent further ice buildup.

08 Miscellaneous Operations Activities

08.1 Site Quality Verification (SOV) Audits and Assessments

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The inspector discussed recent Site Quality Verification (SOV) activities with SOV

management and staff. The discussion covered several audits and assessments,

including chemistry performance, operations department performance, and

configuration controlissues. The inspectors considered the audits and assessments l

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well planned, probing, and insightful. The findings were detailed and critical. The

inspector observed that SOV personnel were frequently in the plant performing field

observations. The inspectors concluded that SOV audits and assessments were

positive contribtrtors to oversight of station operations. )

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08.2 (Closed) Unresolved item 50-454/455-95003-07(DHH: Wr ang Unit, Train, and f

Component Errors. Specifically, an auxiliary operator shut 1CV8483B, " Unit 1 CV

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Pump Discharge Flow Control Valve (1CV121) Downstream isolation Valve" instead j

of 2CV84838. Shutting 1CV8483B unexpectedly isolated charging flow to Unit 1.  !

Additionally, an operator incorrectly lined up for a liquid radwaste release, resulting

in the wrong tank being released to the environment. After the release, the tank

was sampled and found to meet the 10 CFR Part 20 release limits.

Based on these personnel errors, and several others that occurred during the  !

previous months, the licensee conducted a root cause investigation. The inspector

reviewed the licensee's investigation and operator performance since early 1995.

The inspectors noted that the Geensee's evaluation identified two primary areas for

improvement; information based errors and component labeling. Corrective actions

included training on methods of reducing information based errors. The inspectors

have observed frequent reminders to operators during pre-shift briefings to use the

tools provided during the training. Additicnally, the licensee continued to improve

labels in the plant.

The inspector noted that the number of personnel errors had been significantly

reduced since early 1995. The inspector concludod that the corrective actions have

been effective in reducing personnel errors. However, the inspector concluded that

both examples identified above were examples of a failure to follow a procedure.

Therefore, this licensee identified and currected violation is being treated as a

Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy ,

(50-454/455-96012-01(DRP)).

08.3 (Closed) Unresolved item 50-454/455-96006-10: Two Trains of Auxiliary

Feedwater inoperable (Unit 1). During the performance of 1BOS 7.1.2.1.a-3, "A

Train Motor Driven Auxiliary Feedwater (AF) Pump Monthly Surveillance " on  :

July 24,1996, the inspectors observed the operable train (B train) of AF

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inedvertently made inoperable. The B train was made inoperable for 8 minutes due

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• .to connecting a strip chart recorder that caused a low srtion pressure alarm.

Operators determined that both trains of AF were inoperable. The instrument'-  !

j mecharuc and the senior reector operator approving the work did not adequately -

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communicate the details of the planned work. Additional detail was described in

i IR 96006, paragraph M1.1.

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The inspectors observed the licensee immediately enter TS 3.7.1.2.b (both trains of ,

AF inoperable) and restore the 1B AF pump to' operable. The station manager l

j 'placed a stop work order on the work in progress until a special test procedure was 1

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written, reviewed, and approved. The Shift Operations Supervisor prepared a Daily

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Order for operators re-enforcing the necessity of using extreme scrutiny for dual

train evolutions, specifically usmg major briefings if necessary, to ensure complete .;

t underst.ending of the proposed evolution. Maintenance and Operations ,

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management held training sessions with mechanics to discuss the significence of j

the event and the need to clearly communicate with the operators.  !

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The inspectors noted that Byron Administrative Procedure (BAP) 300-1, " Conduct

of Operations", required the individual performing an activity to fully understand the '  !

4: consequences. The inspector concluded that the operator and the instrument -

mechanic did not sufficiently understand the consequences of their actions. This  ;

, licensee identified and corrected violation is being treated as a Non-Cited Violation, i

consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-454/455-

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96012-02(DRP)).-

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11. Maintenance l

, M1 Conduct of Maintenance  !

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l M1.1 Maintenance Observations (62703) y

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a. Insoection Scone

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The inspectors observed all or portions of the following work activities: j

WR 960119787 Eliminate Vibrations on 2A MFP -

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WR 950059181 Troubleshoot and Evaluate Pump Bearing Temperatures (2A

Main Feed Pump)

WR 960103386 PMNOTES testing on 1 A containment spray eductor spray

I additive valve,1CS019

WR 970000563 Inspect shear pin and potential debris on 1B SX pump i

discharge strainer

j WR 960116154 - Inspect and clean 18 diesel generator jacket water cooler

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b. Observations and Findinas

The inspectors found that the maintenance activities were conducted in accordance

with approved procedures and were in conformance with technical specifications.

The inspectors observed maintenance supervisors and system engineers m6nitoring

job progress. Quality control personnel were also present. When applicable,

appropriate radiation control measures were in place.

During the 2A Main Feedwater Pump troubleshooting and repair, the inspector

observed foreign material exclusion (FME) practices. The inspector observed good

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control while mechanics were actually working on the equipment. However, during '

periods of time when there were no mechanics at the job site, the areas for FME

control were not obvious. For example, an open thrust bearing was covered with a

rag without further identification of any FME areas. The inspector considered the

overall observed application of FME practices acceptable; however, the control of

unattended areas was weak.

M1.2 Essential Service Water (SX) Strainor Insoections I

On January 9,1997, the inspectors observed boroscope inspections of the 1B SX

strainer tubes. The inspections noted that several tubes appeared to be eroded to

the point where holes had developed. The erosion was located in the middle of the

strainer tubes at the same elevation as the SX discharge piping. Based on the  !

inspection results, the licensee removed and r3placed all 59 strainer tubes in the l

1B SX strainer. The degraded tubes were sent off-site for root cause analysis. The

licensee also inspected and replaced the 1 A SX strainer tubes. The licensee

planned to inspect and replace, if needed, the Unit 2 strainer tubes in

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February 1997.

M1.3 Surveillance Observations

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a. Ingngstion Scoce (617261 '

The inspectors observed all or parts of the following surveillance and special test

procedures. The inspectors also reviewed plant equipment and surveillance

activities against the UFSAR deccriptions.

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1 BVS 3.1.1-6 Unit 1 Reactor Coolant Pump Bus

Underfrequency Quarterly Surveillance

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1 BVS 3.1.1-7 Unit 1 Reactor Coolant Pump Bus Undervoltage

Quarterly Surveillance

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1BVS 3.2.1-1 Bus 141 Undervoltage Protection Mor.sm

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Surveillance

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2BVS 3.2.1-1 Bus 241 Undervoltage Protection Monthly

Surveillance

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2BVS 5.2.f.3-1 ASME Surveillance Requirements for Residual

Heat Removal Pump 2RH01PA

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1BOS 3.2.1840 Unit 1 ESFAS Instrument Slave Relay

Surveillance

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1BOS 3.2.1-850 Unit 1 ESFAS Instrument Slave Relay

Surveillance

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Surveillance

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Su veillance

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2BOS 3.2.1-821 Unit 2 ESFAS Instrument Slave Relay

Surveillance

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1BOS 0.5-3.SX.1-2 Unit 1 Test of 1B Essential Service Water

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Miscellaneous System Valves i

b. Observations and Findinas

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The inspectors routinely noted that proper authorization was obtained from the

control room senior reactor operator prior to the start of each surveillance. The

Nuclear Station Operator (NSO) performing each curveillance accurately conveyed

,to the NSO on duty the surveillance scope. Components removed from service

were identified prior to the surveillance and the proper technical specification (TS)

limiting coMition for operation (LCO) was entered. At the completion of the

surveillar.w and after independnt verification of system restoration, the TS LCO

was cleared. Test instruments used were verified to be in the licensee calibration

program and the calibration was current as applicable. The inspector reviewed

completed surveillance data to ensure the surveillances met their acceptance

criteria.

Surveillance 1 BOS 3.2.1-821 failed during the f;rst attempt due to an electrical

jumper that was improperly installed by an electncal mechanic. The jumper was

not secure;y connected. The surveillance was properly exited and system properly

retested. Tha inspectors verified that the improperly installed jumper did not place

the unit in an unanalyzed condition and did not cause the entry into a TS LCO.

They also found that the system being tested was already out of service and the

appropriate LCO had been entered. The retest recluired the sysPm to be out of

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service for about an additional 30 minutes.

M1.4 Conclusions on Conduct of Maintenanca

The inspectors concluded that the observed maintenance and surveillance activities

were generally completed thoroughly and professionally. Communication between

the maintenance personnel and control room personnel was good. Procedures were

present in the field, properly approved and used.

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M4 Maintenance Staff Knowledge and Performance

M4.1 Inspection of the Essential Service Water Pumo Room Cooler

a. Insoection Scooe (627071

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During a pre-shift brief the inspector noted that tne licensee had identified low flow

in an essential service water pump room cooler. The inspector reviewed the cause

of the low flow and the licensee's corrective actions.

b. Observation and Findinas

On December 30,1996, mechanical maintenance inspecte.d the 1B essential service

water (SX) pump room cooler. On December 31,1996, tho inspactor was

informed during a discussion with a mechanical maintenance supervisor that the

intermediate cooling water divider plates on both the upper and the lower room

coolers were installed incorrectly. The issue was identified after the completion of

maintenance including the required post maintenance test. The pump was still out

of service pending system realignment. An operator, after realigning the system,

questioned the indicated low flow. The flow verification was a good work practice,

not required by a procedure. Mechanical maintenance reopened the room cooler

and identified that the intermediate divider plates on both the upper and lower room

coolers were in9talled incorrectly. The original TS LCO had not been exited. The l

cooler was reassembled correctly and the system returned to service within the l

allowable time period. '

Both work packages used by the mechanics referenced Byron Mechanical Procedure

(BMP) 3100-8, " Mechanical Closure," Revision 8, for disasi,embly and assembly ,

instructions. The inspectors verified BMP 3100-8 required match marks to be l

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verified prior to disassembly. They found that for reassembly the procedure directs

proper orientation of matchmarks. The post maintenance test did not require the

verification of prope" flow.

Inspection report 95-09 issued a Non-Cited Violation for discovery of the 2A safety 1

injection (SI) pump oil cooler end bell being rotated 90 degrees. The inspector

considered the SX room cooler flow divider plates similar to the Si pump oil cooler. '

Both events involved orientation of flow dividers, either end bells or divider plates,

on safety-related equipment. The licensee's corrective action following the SI pump

end bell event included creating a separate procedure step to verify the match

marks and to initial the completion of the step for all of the safety-related pump oil

coolers. However, the licensee did not make the same procedure change to the

room coolers. The inspector concluded that reasonable corrective action from the

previous event could have prevented the dividor plate orientatico error. As of the

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end of the inspection period, the licensee had not made a formal determination of

what corrective action would be taken.

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c. . Conclusion i

The inspector concluded that the operator demonstrated a good questioning l

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attitude in the identification of the low flow. However, the inspector was  ;

concerned that the failure to properly use matchmarks for reassembly of '

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components could have been prevented by reasonable corrective action to other

events where the licensee had not reassembled safety-related oil coolers correctly.

Therefore, the inspectors considered the orientation error of the divider plates an

example of a violation of 10 CFR Part 50, Appendix B, Criterion XVI, " Corrective i

Action" (50-454/455-96012-03a(DRP)).

M8 Miscellaneous Maintenance issues I

M8.1 (Clonadl Follow-Un item 50-454/455-95013-07(DRP): Breaker Failure Trend ,

Potentially Due to Aging. During 1995 and early 1996, the licensee experienced l

l several breaker failures. Some failures were related to racking the breakers in and

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out of the cubicle. However, the licensee also identified that some components ,

were experiencing age related failures. The licensee refurbished 59 safety and . j

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nonsafety-related breakers during 1996. Prior to and during the refurbishments, the

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licensee identified motor cut-off switches as a common potential failure mechanism.

. Additional refurbishments were scheduled over the next 3 years. Recently there

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have been no breaker failures noted by the inspectors. The inspectors considered j

+he licensee's actions appropriate. This item is closed.

M8.2 (Closed) Follow-Un item 50-454/455-94025-02(DRP)

FME Contiols for Spnng

3 1995 Refueling Outage. The inspector reviewed the inspection report that covered i

j the spring refueling outage, IR 50-454/455-95003. The licensee's FME controls l

were specifically addressed as satisfactory. No events resulting from poor FME

controls were noted in the inspection report. This item is closed.

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111. Engineering

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E2 Engineering Support of Facilities and Equipment

E2.1 Review of Modification M6-1-88-060. Essential Service Water (SX) Suoolv to the

Auxiliary Feedwater (AF) Pumo - Flush Line (378281

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The inspector observed surveillance 1 BOS SX-M1, "1 A AF Pump SX Suction Line

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Monthly Flushing Surveillance," during the previous inspection period. This

surveillance was implemented after the completion of modification # M6-1-88-060.

The inspector continued to review the modification package during the current

inspection period.

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b. Observations and Findinas

The modification installed a 6 inch bypass line from the A train of the SX supply

line for AF suction to the return header of the B train of SX. The bypass line was

installed to allow performance of a periodic flush of the AF suction line in order to i

remove any accumulation of silt and ensure chemically treated water was

maintained in the pipe.

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The inspectors review of the safety evaluation worksheets in the modification

package found that the flushing operation would be performed while the A train of

SX and AF was in a TS limiting condition of operation (LCO) action requirement. - i

The procedure's original safety evaluation stated the system would be oper,ated per  ;

the system design requirements. '

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The inspectors review of the Updated Final Safety Analysis Report (UFSAR) found

that the AF system was automatically placed inservice within 92 seconds after the

totalloss of the normal feedwater system. The UFSAR also stated that no operator l

actions were required for 30 minutes after AF system actuation.  !

During the surveillance the inspector observ'ed that the bypass line was placed i

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inservice by opening two normally locked closed valves and flushed for greater then  ;

30 minutes. The operator performing the surveillance was required by the

surveillance to " continuously" monitor the valve and to shut the valves if the AF

system automatically initiated. The valves opened were physically about 7 feet

above the floor and the only access to them required climbing pipes and ductwork.

The operator performing the surveillance was the normal watchstander and after

opening both valves, the inspector observed the operator climb Jown and continue

with rounds until the control room directed him to secure the flush.

I The inspectors discussed the apparent discrepancies between the original safety

evaluation and the surveillance. The licensee was in the process of conducting an ,

investigation at the end of the inspection period. The inspector considered this an  !

unresolved item pending further NRC review of the licensee's investigation to

evaluate the need for an LCO entry (50-454/455-96012-04(DRP)).

c. Conclusion

The inspectors were concerned that the licensee may not have maintained design

control of the SX and AF systems. Additionally, the guidelines given to the

dedicated operator did not appear to be conservative.

E2.2 Unit One Containment Floor Drain Monitorino System

a. Insoection Scone

On December 30,1996, during a routine control room walkdown the inspectors

noted that the Containment Floor Drain Leak Detection System (1RFOO8) had i

alarmed. The inspectors reviewed the UFSAR, technical specifications (TS), NRC

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Regulatory Guide (RG) 1.45, and 1BOS RF-1 " Unit One Containment Floor Drain

Monitoring System Non Routine Surveillance," Revision O.  !

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, b. Mservations and cindinas I

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The inspectors reviewed Unit 1 logs and during discussions with operators

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determined that the Containment Drain Leak Detection Flow annunciator alarmed on  !

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, December 29,1996. Operators had initiated 1BOS RF-1 to trend leairage indicated  !

by 1RFOO8. The inspectors observed that containment sump flow wa; 1.1 gpm. j

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The RFOO8 alarm setpoint was 1 gallon per minute (gpm). The licensee had verified  !

i that the leakage into the sump was not reactor coolant. Several days later, the  !

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licensee determined that the leakage was from a steam generator secondary side .:

manway.

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The inspectors discussed the operability of 1RFOO8 with shift management. The l

4 inspectors were concerned that without the alarm function (the alarm was " locked  !

] in"), the system v;ould not provide its intended function. The system was designed l

1 to identify a 1 gpm reactor coolant system leak within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The SRO stated that i

the system was not declared inoperable because a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> response time is allowed  !

and operations had implemented procedure 1BOS RF-1. The approved procedure  !

required operators to log containment floor drain flow every 30 minutes when the  !

annunciator was alarmed.

[ The inspectors reviewed the UFSAR and noted that the containment floor drain

transmitter signals "are recorded and alarmed in the main control room." The '

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inspectors also noted that RG 1.45 stated " indicators and alarms for each leakage

detection system should be provided in the main control room." The inspector

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verified the licensee was committed to RG 1.45. '

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Inspection Manual Chapter 9900, " Resolution of Degraded and Nonconforming i

l' ' Conditions," defined degraded equipment as "any loss of quality or functional i

capability." Based on the review of the UFSAR and RG 1.45, the inspectors  !

concluded the leak detection system did not have full functional capability while in j

a continuous alarming condition. The leak detection system did not have the  !

! capability of alarming in the main control room in the event of a reactor coolant

system leak. BAP 390-13, " Degraded Equipment Program," Revision 4, required

entries into the degraded equipment log for " inoperable subsystems or components '

l of TS required equipment such that the function of the corresponding TS equipment

is not impaired but increased awareness is deemed appropriate at the (operators) l

l discretion." The inspectors concluded that the leak detection system alarm was

! not able to perform its function, even though the chart recorder was operable and

, the licensee implemented a procedure to provide increased awareness. Therefore,

the inspector concluded this was an example of a violation of 10 CFR Part 50,

Appendix B, Criterion V, " Procedures" for failure to follow procedure BAP 390-13

i_ (50-454/45F96012-05(DRP)).

A review of BAP 390-14A1, " Operability Screening Criteria," Revision 0, by the

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, inspectors indicated that an operability determination was also required. BAP 390-

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14A1 specified that.if the following conditions were met, an operability

determination was required: f

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degraded equipment is identified

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the equipment is required by TS

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the unit is in a mode where the equipment is required by TS i

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the equipment is to be considered operable  !

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condition was not previously evaluated as operable

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and the condition was neither preplanned nor preapproved

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The inspector corcluded that the leak detection system was degraded and also met i

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the additional requirements of BAP 390-14A1. Discussions between the inspector

and SROs indicated the leak detection system was considered operable based on i

implementation of IBOS RF-1. BOS RF-1 stated that the procedure "provides a  !

means to compensate for the loss of the automatic leak detection alarm function

when leakage to the containment floor drain exceeds the annunciator set point." i

The operators determined that 1RFOO8 was operable based on implementation of ,

1BOS RF-1.  :

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j The inspector reviewed the procedure package for 1BOS RF-1 and noted that a j

' safety evaluation had not been performed. A screening had been performed by l

Braidwood Station. Byron's screening reviewed and approved the Braidwood i

screening. The inspector reviewed 10 CFR 50.59 and noted that a safety I

evaluation is required for a change to the facility as describe in the UFSAR. A

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permanent procedure had been approved to comoensate for the loss of the alarm

i setpoint condition. Additionally, the operators did not enter a TS LCO action

requirement for the leak detection system based on the implementation of 1BOS

RF-1. The inspector considered that use of operator action implemented by RF-1

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instead of an alarm capability (as described in the UFSAR) for reactor coolant leak

identification constituted a change to the facility. Therefore, the inspector

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considered the approval of 1BOS RF-1 without performing a safety evaluation a

violation of 10 CFR 50.59 (50-454/455-96012-06(DRP)).

! After discussions with the inspector, the licensee performed a safety evaluation and

determined the practico of logging 1RFOO8 flow rate did not constitute an

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unreviewed safety question. The inspector reviewed with safety evaluation and

agreed that no unreviewed safety question existed.

The inspectors also reviewed unit logs and the sequence of events recorder and

, determined that 1RFOO8 alarmed periodically during a 2 week period; however, the

period the alarm was locked-in never exceeded the TS allowed action time of  ;

7 days, i

c. Conclusion

The inspector concluded that with the alarm locked-in,1RFOO8 was degraded

because it would not alarm again if a actual reactor coolant system leak developed.

The licensee's implementation of 1BOS RF-1 served as a compensatory measure

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during the 2 weeks that 1RF008 alarmed periodically. The inspector also concluded

that although an unreviewed safety question did not exist, the licensee

implemented a procedure to compensate for the loss of alarm function without

declaring the system inoperable or performing a safety evaluation.

IV. Plant Support

P1 Conduct of EP Activities

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P1.1 Unannounced Assembly Exercise .

The inspector observed an unannounced station assembly drill on December 26,

1996. All personnel on site (over 450) were accounted for in less than 30 minutes.

Initial notification was slow in saveral areas due to a low volume for both the alarm i

and announcement. The licensee searched for and found three individuals, all of

whom had not heard the alarm. As corrective action, the licensee had increased

the volume in the affected areas. A minor lesson learned was identified when two J

individuals used the wrong station key card at the assembly station. The card _

reader accepted the entry; however, the two individuals were not immediately l

accounted for by the computer program. The inspector concluded that the exercise j

was completed satisfactorily. j

F1 Control of Fire Protection Activities

j F1.1 B Train Essential Service Water Pumo Room Water Tiaht Door Left Ooen

a. Insoection Scone

During the observation of maintenance activities, the inspectors identified that the B

train SX pump room water tight door had been left open without an impairment tag.

b. Findinas and Observations

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j On January 9,1997, the inspectors found the B train SX pump room water tight I

door open, with no barrier / fire protection system impairment permit. The inspectors

noted the open door with no work being performed and tha door remained open for

approximately 50 minutes during maintenance of the 18 SX strainer. The

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inspectors also confirmed that no impairment permit was logged for the B train SX

pump room door, SD-157. The door was closed after being identified by the NRC.

The inspectors previously identified water tight doors open and unattended for the

A train auxiliary building floor drain (WF) sump pump room (February 22,1996) and

the B train reactor building floor drain (RF) sump pump room (July 15,1996). The

requirement at that time allowed the water tight doors to remain open when the

room was occupied. The licensee evaluated these and other open water tight door

instances with trend report 454-230-96-0027, " Trend 96-027 Doors Left Open at

SX Pump Rooms," dated September 20,1996. Corrective actions included a

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requirement that water tight doors be closed and secured except during passage or I

for short stays within the room for less than 15 minutes. A barrier / fire protection

system impairment permit was required if the water tight door neeced to be open

for more than 15 minutes. Changes to reflect the new requirements were

implemented in Byron Administrative Procedure (BAP) 1100-3, " Fire Protection j

Systems, Fire Rated Assemblies, Ventilation Seals, Flood Seals, and Water Tight i

Doors impairments," Revision 11, dated December 15,1996. The licensee also j

installed a sign on door SD-157 that referred to the requirements of BAP 1100-3. l

The maintenance workers stated that they were not aware of the new requirements I

as stated in BAP 1100-3. The inspectors concluded that the licensee had ample

time to implement and train personnel on the corrective actions to the unattended

water tight door issue. Failure to implement effective corrective actions to preclude

open, unattended water tight doors is a violation of 10 CFR Part 50, Appendix B,

Criterion XVI, " Corrective Action," (50-454/455/96012-03b(DRP)).  ;

The licensee held meetings with the maintenance and operations staff to reiterate

the new requirements in BAP 1100-3 and the need for the barrier / fire protection

system impairment permit when the door was open for more than 15 minutes,

c. Conclusions i

The inspectors concluded that the licensee's corrective actions from July 1996, to i

preclude open, unattended water tight doors were ineffective. I

F4 Fire Protection Staff Knowledge and Performance

FX.X Unannounced Fire Drill i

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The inspector observed an unannounced fire drill. The simulated fire was in the ,

Clean and Dirty Oil Storage Tank room. The inspector observed prompt response i

by control room operators and correct use of procedures. The fire brigade i

responded rapidly. The inspector noted the fire brigade was appropriately dressed I

and responded with sufficient equipment. Drill simulation was very good, including i

danse smoke in the room. The drill was conducted by the Fire Marshall and

observed by SQV and two contract fire protection engineers. The inspector

observed a good, self-critical critique following the drill. The inspector concluded

the drill was very good overall.

V. Manaaement Meetinas

X1 Exit Meeting Summary

The inspectors presented the inspection results to members of licensee

management on January 31,1997.

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The inspectors asked the licensee whether any materials examined during the

inspection should be considered proprietary. No proprietary information was

identified.

X2 Pre-Decisional Enforcement Conference Summary

On January 24,1997, a predecisional enforcement conference was held at the

NRC Region 111 office to discurs potential enforcement issues identified in Inspection

Report 50-454/96009; 50-455/96009(DRP). The issues related to the excessive

silt levels in the essential service water cooling tower basins. Handouts and notes

used in the licensee's presentation at the conference have been placed in the Public _

Document Room.

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PARTIAL LIST OF PERSONS CONTACTED  ;

Licensee

> T. Maiman, Executive Vice President " '

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K. Graesser, Byron Site Vice President

K. Kofron, Station Manager . ,

D. Wozniak. Site Engineering Manager

T. Gierich, Opurations Manager . .

P. Johnson, technical Service Superintendent ,

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E. Campbell, Maintenance Superintendent

M. Snow, Work Control Superintendent .

D. Brindle, Regulatory Assurance Supervisor

T. Schuster, Site Quality Verification Director

NBC

A. Beach, Regional Administrator

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J. Grobe, Deputy Director, Division of Reactor Projects

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INSPECTION PROCEDURES USED

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IP 37551: Onsite Engineering

IP 61726: ' Surveillance Observations

IP 62703: Maintenance Observations

IP 71707: Plant Operations

IP 71750: Plant Support Activities

IP 92901: Follow-up - P! ant Operations

IP 92902: Follow-up - Maintenance

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ITEMS OPENED, CLOSED, AND DISCUSSED

Opened  !

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50-454/455-96012-01 NCV Personnel errors due to failure to follow procedures

50-454/455-96012-02 NCV Failure to follow procedure j

50-454/455-96012-03a VIO Inadequate corrective action for heat exchanger f

assembly

50-454/455 96012-04 URI Design control: SX not placed in LCO during flush of  !

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AF suction line ~ *' .;

50-454/455-96012-05 VIO Failure to follow procedure, BAP 390-13 i

50-454/455-96012-06 VIO Failwe to perform a ety evaluation .

50-454/455-96012-03b

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VIO . Inadequate corrective action to preclude open, .)

unattended water tight doors -

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50-454/455-95003-07 URI Wrong unit, train, and component errors -

50-454/455-96012-02 NCV Personnel errors due to failure to follow procedures

50-454/455-96006-10 URI Two trains of auxiliary feedwater inoperable for 8 i

minutes

50-454/455-96012-03 NCV Failure to follow procedure

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'50-454/455-95013-07 IFl Breaker failure trend, potentially due to aging

50-454/455-94025-02 IFl FME controls for spring 1995 refueling outage

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-LIST OF ACRONYMS USED

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AF Auxiliary Feedwater System

ALARA

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As Low As Reasonably Achievable l

ASME American Society of Mechanical Engineers * *

BAP- Byrori administrative Procedure -

BMP Byron Mechanical Maintenance Procedure

BOS Byron Operating Procedure i

BVS Byron Surveillance Procedure

CFR- Code of Federal Regulations -

CS Containment Spray

CV Chemical and Volume Control System

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ORP Division of Reactor Projects

EO Environmental Qualification

ESFAS Engineered Safety Feature Actuation Signal

FBIP Fire Barrier impairment Permit

FME Foreign Material Exclusion

'GL Generic Letter

IM instrument Mechanic . j

LCO Limiting Condition for Operation i

MCC Motor Control Center

MCR Main Control Room l

MFP Main Feedwater Pump t

MOV Motor Operated Valve i

mR ' millirem

NSO Nuclear Station Operator

OOS Out of Service

RG Regulatory Guide i

RH Residual Heat Removal System

RSH River Screen House

SAT. Station Auxiliary Transformer

SCRE Shift Control Room Engineer

SFP- Spent Fuel Pool

SG Steam Generator

St Safety injection

SOV Site Quality Verification

SRO Senior Reactor Operator

SSPS Solid State Protection System

SX Esseniial Service Water

TS Technical Specification i

UFSAR Updated Final Safety Analysis Report

UHS Ultimate Heat Sink

US Unit Supervisor

WR Work Request

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