ML20129A730

Insp Rept 50-454/85-25 on 850604-0701.Violation Noted: Failure to Perform Required Tech Spec Surveillances Re RCS Average Temp

ML20129A730
Person / Time
Site:	Byron
Issue date:	07/09/1985
From:	Forney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20129A680	List: IR 05000454/1985025 IR 05000604/2007001 ML20129A676
References
50-454-85-25, NUDOCS 8507150374
Download: ML20129A730 (10)

See also: IR 05000604/2007001

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No.: 50-454/85025

Docket No.: 50-454 License No.: NPF-37

Licensee: Commonwealth ~ Edison Company

Post Office Box 767

Chicago, JL 60690

-Facility Name: Byron Station, Unit 1

Inspection at: Byron Station, Byron, IL

Inspection-Conducted: June 4.- July 1, 1985

Inspectors: J. M. Hinds, Jr.

K.'A. Connaughton

P. G. Brochman

Approved By: .' - - ---

Reactor Projects Section 1A Date

Inspection Summary

Inspection on June 4 - July 1, 1985 (Report No. 50-454/85025(DRP))

Areas Inspected: Routine, unannounced safety inspection by the resident

inspectors-of licensee action on previous ~ inspection findings; LERs;. location

of manual trip circuit in solid-state protection system; maintenance;

surveillance; operational safety; startup testing; Headquarters requests;

Region III requests; event followup; allegations; and other activities. The

~ inspection consisted of 137 inspector-hours onsite by 3 NRC inspectors

including 27 inspector-hours during off-shifts.

Results: Of the 11 areas inspected, no violations or deviations were

identified in 10 areas; one violation was identifed in the remaining area

(failure to perform Technical Specification Surveillances when reqired -

Paragraph 3.b). The violation' cites 2 instances of missed surveillances which

were required by Technical Specifications; however, examination of the strip

chart records indicated that the parameters were maintained within their

Technical-Specification limits at all times; therefore, the public health and

safety were not affected.

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8507150374 850709

PDR ADOCK 05000454

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DETAILS

1. Persons Contacted

Commonwealth Edison Company

• T. Maiman, Manager of Projects

• R. Querio, Station Superintendent

• R. Pleniewicz, Assistant Superintendent Operations

• D. St. Clair, Technical Staff Supervisor

R. Chrazanowski, Security Administrator, Byron

• A. Chernick, Compliance Supervisor

H. Erickson, Master Mechanic

P. Johnson, Master Instrument Mechanic

• F. Hornbeak, Unit 2 Testing Supervisor

• R. Gruber, Quality Assurance

• A. Britton, Quality Assurance

H. Krist, Security Assistant

G. Buettner, Security Assistant

C. Kilbride, Technical Staff

M. Snow, Technical Staff

• J. Langan, Technical Staff Compliance

The inspectors also contacted and interviewed other licensee and

contractor personnel during the course of this inspection.

• Denotes those present at the exit interview on July 1, 1985.

2. Action On Previous Inspection Findings (92702)

a. (Closed) Violation (454/85009-03(DRP)): Failure to implement

administrative controls on overtime work for individuals who perform

safety related functions. The inspector reviewed the licensee's

training session on the control of overtime and interviewed

maintenance supervisors to verify their understanding of the

requirements for control of overtime.

b. (Closed) Violation (454/85016-03(DRP)): Failure to follow Technical

Specification Action Requirements. The inspector reviewed the

licensee's response to the 3 examples of violation and interviewed

licensed operators and licensed supervisory operators to verify

their understanding of the intent of Technical Specification Action

requirements which were exceeded.

3. Licensee Event Report (LER) Followup (90712 & 92700)

a. (Closed) LEP.s (454/85051-LL; 454/85052-LL; 454/85053-LL;

454/85054-LL; 454/85055-LL; 454/85056-LL; 454/85057-LL;

454/85058-LL; 454/85059-LL): An in-office review was conducted for

the following LERs to determine that the reporting requirements were

fulfilled, immediate corrective action was accomplished and

corrective action to prevent recurrence had been accomplished in

accordance with Technical Specifications.

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'LER No.- Title

~454/85051 Reactor Trip From Turbine Trip During

Presynchronization Checks

454/85052 Reactor Trip From 345KV Fault

454/85053 Reactor Trip Due to Instrument Power

Inverter Failure

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454/85054 Reactor Trip Due to Low Lube Oil

Reservoir.

454/85055 Inoperability of Containment Isolation

Valves 1 RF026 and 1RF027

454/85056 Unanalyzed Condition Affecting Aux

Building Environment

454/85057 Missed Fire Watches Due to Aux Bldg

Airborne Activity

454/85058 Missed Hourly Fire Watch

454/85059 Hourly Fire Watch Delayed Due to

Security Computer Failure

Licensee installation of a temperature monitoring system to

automatically isolate the steam generator blowdown and auxiliiary

steam systens, per LER 85056, will be tracked as an open item

(454/85025-01(DRP)).

The events described in LERs 454/85051,454/85052,454/85053,and

454/85054 were reviewed in Inspection Report (454/85021(DRP)).

No violations or deviations were identified.

b. (Closed) LER (454/85050-LL): This LER described an qvent from

February 24 to May 5,1985, while in Mode 1. Technical

Specification 4.2.5 required that Indicated Reactor Coolant System

Average Temperature (T ) and Indicated Pressurizer Pressure (P

L be verified within theiE* limits of Table 3.2-1 at least once per P if)

hours. This is accomplished by performance of Byron Operating

Surveillance 1B0S 0.1-1,2,3, Step 6. The licensee identified in the

LER that this surveillance had not been performed since initial

entry into Mode 1 on February 24. During discussions with licensee

staff the inspector identified 2 discrepancies in the LER. The

cause of the surveillance not being performed was that the

verification was deleted when Revision 1 to IBOS 0.1-1,2,3 was

issued on March 28. Since the original version of IBOS 0.1-1,2,3

performed this sur~veillance, Technical Specification ' ,2.5 was only

exceeded after March 27.

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Failure to perform surveillances within the required time interval

is an example of a violation (454/85025-02a(DRP)).

Technical Specification 4.0.4 required that entry into Mode 1 should

not be made unless Technical Specification Surveillance 4.2.5 had

been performed within the last 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. T and P were not

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verified within their limits prior to entry l8to ModPS on March 29

and April 3, 13, 16 and 21. These instances were not explicitly

identified in the LER.

Failure to perform a surveillance as required prior to entry in Mode

1 is an example of a violation (454/85025-02b(DRP)).

Since this event occured before the licensee presented their Conduct

of Operations Improvement Program (COIP), described in Inspection

Report (454/85021(DRP)), and the licensee took immediate corrective

action upon discovery of this problem; the inspectors have no

further concerns regarding this violation and it is considered

closed. The inspectors will follow up the COIP as part of the

permanant corrective action. The licensee agreed to revise the LER

to correct the 2 discrepancies and this will be followed as'an

unresolved item (454/85025-03(DRP)).

4. Inspection of the Location of the Manual Trip Circuit in Westinghouse

Designed Plants With a Solid State Protection System (SSPS) (25014)

a. Background

The effects of short-circuit failures of the output transistors in

the UV output circuit of the Westinghouse SSPS were highlighted in

recently issued Information Notice No. 85-18. A short-7ircuit

failure of the type described in the notice would prevent the

automatic tripping of the associated reactor trip breaker (RTB) on a

valid reactor trip demand.

During NRC review of this matter, another potential deficiency

involving the SSPS was discovered. Namely, the use of erroneous

controlled schematic diagrams of the SSPS at an operating facility.

Except for the drawings being used by the I&C technicians, the

controlled schematic diagrams of the SSPS being used in this

facility erroneously depicted the manual trip circuit for the RTBs

as being upstream of two particular output transistors. If such

were the case, and if one of the output transistors was shorted as

described in Information Notice 83-18, then the manual trip action

associated with the UV portion of the trip circuit would also be

ineffective.

Temporary Instruction TI 2500/14 was therefore issued to require NRC

inspector verification that the SSPS normal trip circuits were

downstream of the undervoltage output transistors and tilus the

manual undervoltage trip functions were not vulnerable to shorting

of the output transistors.

b. Inspection

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The inspector reviewed electrical drawings 6E-1-4030EF29, " Schematic

Diagram, Reactor Protection, Part-2, Train A," Revision D, dated

January 2,1985, and 6E-1-4030EF73, " Schematic Diagram Reactor

Protection Part-2 Train B," Revision D, dated January 2,1985.

These drawings correctly specified that the manual undervoltage trip

circuits were downstream of output transistors Q3 and Q4 on the

undervoltage driver cards.

To further verify that the foregoing schematics accurately reflected

the as-installed SSPS equipment the inspector contacted licensee

technical staff personnel and was provided with: an identical

schematic (applicable to both trains) from the Byron Station SSPS

vendor manual; Westinghouse Electric Corporation Instrumentation and

Control Drawings 2379A59 Sheet 6, Revision D and 2374A56 Sheet 9,

Revision AC; Drawing 6E-1-4114F, " External Wiring Diagram, Solid

State (RX&ESF) Protection System Cabinet, Train A (Logic Section)

Part 3 (IPA 09J)", Revision J, dated March 5, 1984; Drawing

6E-1-4052AA, " Internal-External Wiring Diagram MCB Reactor and

Chemical Volume Control Section B2, Part 11 (1PM05J)," Revision D,

dated September 3, 1982; Drawing 6E-1-4054P, " Internal-External

Wiring Diagram MCB Engineered Safety Features Section A2, Part 6

(1PM06J)," Revision E, dated May 10, 1983; Drawing 6E-2-4054P,

" Internal-External Wiring Diagram MCB Engineered Safety Features

Section A2 Part 2 (1PM06J)," Revision V, dated January 3, 1985, and;

Drawing 6E-1-4208B, " Internal-External Wiring Diagram Reactor Trip

Switchgear Cabinet 1RD05E," Revision K dated June 21, 1984.

The above listed wiring diagrams and drawings traced wiring from the

Undervoltage Output Cards, Pins 29 and 30, through the manual reactor trip and manual safety injection control switches to the

termination points on the reactor trip switchgear cubical which were

connected to the undervoltage trip coil. Based upon review of the

foregoing " Approved for Use" design and construction drawings the

inspector concluded that the Byron Unit 1 SSPS was configured such

that shorting of output transistors Q3 and/or Q4 on the undervoltage

output card would not defeat the manual undervoltage reactor trip

function.

No violations or deviations were identified.

5. Monthly Surveillance Observation (61726)

The inspector observed technical specifications required surveillance

i testing on a Refueling Water Storage Tank Level Channel, the Reactor

Coolant Pump Bus Undervoltage Relays, and Component Cooling Pump 1CC01PA

and verified that testing was performed in accordance with adequate

procedures, that test instrumentation was calibrated, that limiting

conditions for operation were met, that removal and restoration of the

affected components were accomplished, that test results conformed with

technical specifications and procedure requirements and were reviewed by

personnel other than the individual directing the test, and that any

deficiencies identified during the testing were properly reviewed and

resolved by appropriate management personnel.

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No violations or deviations were identified.

6. Monthly Maintenance Observation (62703)

Station maintenance activities of safety related systems and components

listed below were observed / reviewed to ascertain that they were conducted

in acccordance with approved procedures, regulatory guides and industry

codes or standards and in conformance with technical specifications.

The following items were considered during this review: the limiting

conditions for operation were met while components or systems were

removed from service; approvals were obtained prior to initiating the

work; activities were accomplished'using approved procedures and were

inspected as applicable; functional testing and/or calibrations were

performed prior to returning components or systems to service; quality

controi records were maintained; activities were accomplished by

qualified personnel; parts and materials used were properly certified;

radiolooical controls were implemented; and, fire prevention controls

were implemented. Work' requests were reviewed to determine status of

outstanding jobs and to assure that priority is assigned to safety

related equipment maintenance which may affect system performance.

The following maintenance activities were observed / reviewed:

Replacement of Auxiliary Feedwater Flow Transmitter 1FT-AF016

Following completion of maintenance on the flow transmitter, the

inspector verified that these systems had been returned to service

properly.

No violations or deviations were identified.

7. Operational Safety Verification and Engineered Safety Features System

Walkdown (71707 & 71710)

The inspectors observed control room operation, reviewed applicable logs

and conducted discussions with control room operators during the month of

June 1985. During these discussions and observations, the inspectors

ascertained that the operators were alert, cognizant of plant conditions,

atttentive to changes in those conditions, and took prompt action when

appropriate. The inspectors verified the operability of selected

emergency systems, reviewed tagout records and verified proper return to

service of affected components. Tours of the auxiliary, turbine and

rad-waste buildings were conducted to observe plant equipment conditions,

including potential fire hazards, fluid leaks and excessive vibration and

to verify that maintenance requests had been initiated for equipment in

need of maintenance.

The inspectors observed plant housekeeping / cleanliness conditions and

verifed implementation of radiation protection controls. During the

mor.th of June 1985, the inspectors walked down the accessible portions of

the Diesel Generator and Safety Injection Systems to verify operability.

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These reviews and observations were conducted to verify that facility

operations were in accordance with the requirements established under

technical specifications, 10 CFR and administrative procedures.

No violations or deviations were identified.

8. Startup Test Witnessing and Observation (72302)

The inspectors witnessed performance of portions of the following startup

test procedures in order to verify that testing was conducted in

accordance with the operating license and procedural requirements, test

data was properly recorded and performance of licensee personnel

conducting the tests demonstrated an understanding of assigned duties and

responsibilities.

2.47.31 -Power Coeficient Determination

2.47.32 Thermal Power Measurement

2.52.37 Load Swing Test

2.64.34 Large Load Reduction

No violations or deviations were identified.

9. Response to Headquarters Requests (92704)

The inspectors reviewed the licensee's response to Information Notice

84-06 in accordance.with Temporary Instruction 2515/67, Item 03.02b and

forwarded this information to the Regional Office. Submission of this

information and that of Item 03.02a,_ covered in Inspection Report

454/85021(DRP), completes all action required by this instruction.

10. Response to Region III Requests (92705)

The inspectors reviewed licensee files to determine the amount of

experience for senior station personnel in the following areas:

professional, utility, and nuclear plants and forwarded this-information

to the Regional Office.

11. Onsite Followup of Events at Operating Reactors (93702)

a. General

The inspector performed onsite followup activities for an event

which occurred during June 1985. This followup included reviews of

operating logs, procedures, Deviation Reports, Licensee Event

Reports (where available) and interviews with licensee personnel.

For the event, the inspector developed a chronology, reviewed the

functioning of safety systems required by plant conditions, reviewed

licensee actions to verify consistency with procedures, license

conditions and the nature of the event. Additionally the inspector

verified that licensee investigation had identified root causes of

equipment malft1ctions and/or personnel error and had taken

appropriate corrective actions prior to plant restart. Details of

the event and licensee corrective actions developed through

inspector followup are provided in Paragraph b below.

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b. Reactor Trip on Low-Low Steam Generator Level on June 24, 1985

While in Mode 1 with reactor power at 98% the reactor tripped on

steam generator 1A low-low level when the 1C main feedwater pump

(MFP) (steam driven) was inadvertently tripped. Licensee personnel

manuallly ran back the turbine and started the 1A MFP (motor driven)

but were unable to maintain steam generator level.

Licensee's investigation determined that the 1C MFP trip was caused

by the microphone cord of an equipment operator's radio. This cord

became entangled with the MFP's overspeed test lever, causing the

test device to actuate.

Corrective action taken by the licensee included briefing operators

to exercise caution when working near the MFPs and the installation

of protective covers around the test levers. The licensee is also

evaluating other equipment for similar problems. Final review and

closure of this event will be accomplished in a subsequent

inspection after the LER is issued.

No violations or deviations were identified.

12. Allegations Provided by the Licensee Regarding Drug Use at Byron

a. Allegation 1: On June 17, 1985, the licensee' notified the inspector

of an allegation related to drug use. This allegation was verbally

received on June 16, 1985, by a corporate manager from a concerned

citizen at a social function. The citizen identified an employee at

the Byron Statin whom the alleger had reason to believe may be using

drugs off-site in a recreational manner. The corporate manager

relayed this information to the Byron Site Superintendent who

subsequently notified the inspector.

. Findings: In keeping with the licensee's drug awareness program, on

June 17, 1985, the individual was relieved of all duties at Byron

Station, his site security clearance was revoked and he was notified

of a review board to be convened on June 18, 1985. On June 18,

1985, a board consisting of Byron Station managers and union

representatives reviewed the allegation.with the individual. As a

result of the Board's evaluation and recommendations, the individual

was escorted to the Chicago General Office medical facility where

the individual was interviewed by a senior coordinator of the

Commonwealth Edison Employee Assistance Program (EAP). The

individual also submitted to an observed specimen urinalysis

following the interview. The test results of the urinalysis were

negative. Based on the negative test results, recommendations of

the EAP coordinator, and endorsement by the ccmpany physician, the

individual was restored to security status and returned to full duty

on June 20, 1985.

The licensee's management and supervisory personnel and the

inspectors have monitored the individual's performance and no

abnormal behavior during current work day observations have been

observed. This allegation is considered closed.

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b. Allegation 2: On June 13, 1985, the licensee notified the

inspectors of an allegation related to alcohol and drug use at Byron

Station in parking lots and areas of the plant. This allegation was

received in the form of a telephone call on June 12, 1985, at 2100

to the Byron Site Security Administrator at his home. The caller

identified himself as a long time contractor employee and provided

sufficient detailed information to the Security Administrator to

establish reasonable creditability. The caller also identified 10

individuals, including some badge numbers-and three contractor

shops, whom he had reason to believe were using drugs and/or alcohol

in the south parking lot during the lunch period and implied certain

other site areas and times. The caller further stated that he may,

in the future,; elect to become further involved by coming forth with

additional specific information and revealing his identity pending

his first hand observations of the licensee's corrective measures to

resolve this issue. The licensee has had no further contact from

this individual as of the closing date of this report.

Findings: Based on the information received from the alleger, the

licensee contacted the 10 individuals identified and arranged for

them to report to the station security gate house at 1000 on June

20, 1985. At the gate house the individuals, together with union

representatives, were met by security officers and escorted to an

isolation area inside the gate house. Inside the gate house four

teams consisting of two CECO security managers each, began

individual interviews of the identified individuals. The interview

teams used a battery of questions designed to gain information from

the individuals related to the Byron Drug and Alcohol Abuse Policy

awareness, personal information, including type of work and

location, and to specifically address the use or sale of drugs or

alcohol on and off CECO property including observations or rumors of

the use or sale of drugs or alcohol at Byron.

Simultaneously with the interviews the licensee conducted meetings

with Project Construction Department (PCD), contractor supervisors,

and station supervisors. The purpose of these meetings was to

reitcrate the CECO position-as related to the Ceco Drug and Alcohol

Abuse Policy and to disseminate information, of a general nature,

concerning the allegations and the Byron Station corrective measures

to resolve these issues.

In addition, while the interviews were in progress, a search of the

plant was made. Three teams, each consisting of a handler and a

narcotics detection trained dog, made searches of a number of work

site areas'inside the plant buildings and other contractor

controlled work site buildings on the grounds inside the security

fence. The search areas included tool, equipment and material

storage boxes, field desks and lockers, and lunch areas. During the

search procedure, each team demonstrated the effectiveness of the

animal by hiding a drug sample and proving the dog could find it in '

both previously unsearched and searched areas.

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The_ inspectors participated in the dog team searches, the policy

meetings and the interviews. During the dog team searches no drugs

were detected in any of the areas searched.

The CECO interview teams are preparing a report on the interviews

and will provide a copy of the report to the inspectors. This

allegation is an unresolved item pending the inspectors receipt and

review of-the interview team report (454/85025-04(DRP)).

13. Presentation of Licenses to Reactor Operators

On June 28, 1985, Messrs. E. Greenman, Deputy Director, Reactor Projects

Division; L. Reyes, Chief, Reactor Safety Operations Branch; R. Warnick,

Chief, Reactor Projects Branch 1; and J. Hinds, Senior Resident

Inspector, Byron, presented licenses to reactor operators for Byron Unit

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14. Open Items

Open items are matters which have been discussed with the licensee, which

vi D reviewed further by the inspector, and which involve some action

c part of the NRC or licensee or both. An open item disclosed

dui the_ inspection is discussed in Paragraph 3.a.

15. Unresolved Items

Unresolved items are matters about which more information is required in

order to ascertain whether they are acceptable items, violations or

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deviations. Unresolved items disclosed during the inspection are

discussed in Paragraphs 3.b and 12.b.

16. Exit interview (30703)

The inspectors met with licensee representatives denoted in Paragraph 1

at the conclusion of the inspection on July 1, 1985. The inspectors

summarized the purpose and scope of the inspection and the findings. The

inspectors also discussed the likely informational content of the

inspection report with regard to documents or processes reviewed by the

inspectors during the inspection. The licensee did not identify any such

documents / processes as proprietary.

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