IR 05000454/1988012
| ML20247B931 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 03/21/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20247B908 | List: |
| References | |
| 50-454-88-12, 50-455-88-12, NUDOCS 8903300078 | |
| Download: ML20247B931 (13) | |
Text
_ _ - - . . _ - _ _ . - - _ - _ _ -
-
. ,
c.
] .
'
,
g a'
Enclosure 1 l SALP 8 APPENDIX L
SALP BOARD REPORT
_. .. .
U. S. NUCLEAR REGULATORY COMISSION
REGION III
. . . . ... .
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 50-454/88012; 50-455/88012
~
Inspection Reports No.
Commonwealth Edison Company ifaliie of Licensee Byron Station Name of Facility November 12 1987, through October,31, 1988 Assessment Period _
gg3888?R8388Aga .
Q !
_ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - - _ - _ _ - _ _ - - _ - - _ _ _ - _
_ __
_ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _
. .
'
..
-
. .
i *
Enclosure 1 Byron Station I
A. Summary of Meeting with Commonwealth Edison Company on January 27,19p The findings and conclusions of the SALP Board are documented in Report No. 50-454/88012; No. 50-455/88012 and were discussed with the licensee on January 27, 1989, at the Byron Training Facility.
While the meeting was primarily a discussion between the licensee and NRC, it was open to members of the public as observers.
The following licensee and NRC personnel were in attendance, as well as the noted observers.
Co m onwe61th Edison Company B. Thomas, President C. Reed, Senior Vice President, Nuclear Operations L. O. DelGeorge, Assistant Vice President, Licensing and Plant Support T. J. Maiman, Vice President, PWR Operations K. L. Graesser, General Manager, PWR Operations R. Pleniewicz, Station Manager H. E. Bliss, Manager, Nuclear Licensing G. P. Wagner, Manager, Production Services D. Farrar, Manager, Technical Services R. Chrzanowski, Nuclear Licensing Administrator R. Ward, Services Superintendent T. P. Joyce, Production Superintendent D. Winchester, Quality Assuiance Superintendent D. Elias, PWR Engineering Superintendent G. K. Schwartz, Assistant Superintendent, Maintenance T. J. Tulon, Assistant Superintendent, Operations L. A. Sues, Assistant Superintendent, Technical Services M. Snow, Regulatory Assurance Supervisor G. Stauffer, Regulatory Assurance Staff W. Pirnat, Regulatory Assurance Staff E. Carrell, Regulatory Assurance Staff, Braidwood R. A. Flahive, Technical Staff Supervisor A. J. Chernick, Training Staff Supervisor P. J. O'Neill, Quality Control Supervisor D. Johnson, Instrument Maintenance Supervisor R. Rhoads, Storeroom Supervisor S. P. Barrett, Radiation / Chemistry Supervisor W. P. Dystelbergen, PWR Field Engineer Supervisor G. Toleski, Nuclear Security Administrator D. Goble, Assistant Security Administrator P. Cullighan, District Superintendent, Rockford R. Stobert, Director of Quality Assurance T. K. Higgens, Operating Engineer
!
_ _ _ _ _ _ _ _ - _ - _ _
_ - ____ - _- ___ __ _ _ ._
.
.
. .
.
, Commonwealth Edison Company (con't.)
L. Soth, PWR Operations Staff F. A. Hornbeak, Senior Staff Engineer 1 E. Clemens, Master Mechanic D. Berg, Onsite Nuclear Safety Group J. Kudnus, Senior Financial Coordinator S. Wilson, Chemist J. K. Heaton, Operations Training M. Hawks, Training Group Leader Burns Security B. Kindred, District Manager B. Rittmer, Project Manager Other L. Sage, Illinois Department of Nuclear Safety D. Chavez, Sinnissippi Alliance for the Environment
.J. Davis, Ogle Company Board B. Johnson, League of Women Voters of Rockford D. Gertz, Freport Journal-St;ndard P. Resler, Hometown Newspaper P. Gluntz, Dixon Telegraph B. Leaf, Rockford Register Star K. Wood, WR0K radio P. Nichols, WREX R. Nich, WIFR-TV Nuclear R,egulatory Commission A. B. Davis, Regional Administrator D. R. Muller, Project Director, NRR-B. Clayton, Acting Branch Chief l
J. M. Hinds, Section Chief P. G. Brochman, Senior Resident Inspector N. V. Gilles, Resident Inspector D. R. Calhoun, Project Inspector S. Forsberg, Swedish Inspector R. J. Marabito, Public Affairs Officer B. Coments Received from Licensee Commonwealth Edison Company's response to the Byron Station SALP 8 Board Report dated February 27, 1989, had two coments that were discussed by the Resident Inspector with your staff subsequent to the meetings.
With regard to the statements made in your response letter concerning the incorrect categorization of a failure to collect a compensatory sample as a missed surveillance, changes have been made to the SALP Report as indicated in the Appendix to this letter. With regard to the statements made in your response letter concerning environmental qualification (EQ)
f
- - - - - - - - - - -
__
. - . _ _-_ ._
_. . - - _ _ . .
___
-
L . .
-
.
.
. .
'
I l'~l concerns discussed in the SALP Report, and subsequent discussions clarifying H these statements, one change was made to the SALP Report as indicated in the Appendix. We feel that all of the items discussed in.the report were identified to you as EQ concerns during the SALP 8 assessment period. )
While we understand that you' have taken corrective actions to alleviate i some of these concerns, they were, nevertheless, indicative of weaknesses 0
'
in this area and, therefore, contributed to the sal.P assessmer,t. This :
)
Appendix.has incorporated these comments.into-the SALP Report.
Replace the pages in error listed in Enclosure (2) with the corrected pages attached in Enclosure (3) into your copy of the SALP Report..
C. Regional Administrator's Conclusions Based on Consideration of Licensee
_
Comments I have concluded .that the overall ratings in the affected areas have nct changed. -!
.
m ---.__-__.-.._-,--_x. _ _ _ _ . _ _ - _:-_-
___ _-_________ _ _
- _ ,
.
- .
.
.i
)
"
-Enclosure 2
ERRATA SHEET PAGE LINE _NOW READS .S_HOULD READ
,
3 12-14 Only one surveillance was No missed surveillance were missed during the assessment identified during the period and'it was identified assessment period.
-by a licensee supervisory review.
L Basis: ~A missed compensatory- sample was incorrectly categorized as a missed surveillance.
l12 15-20. Only one missed surveillance No missed surveillance were was identified during the identified during the assessment period; it was a assessment period.
personnel . error by an RCT'
who failed to collect a compensatory sample required by Technical Specifications.
'-
.This error was discovered by the-licensee during supervisory review of surveillance records.
Basis: .A missed compensatory sample was incorrectly categorized as a missed surveillance.
12 25-26 ...one missed surveillance, ...no missed surveillance, I
Basis: A missed compensatory sample was. incorrectly categorized as.a missed surveillance.
14. 23-24 ...only one missed surveillance, ...no missed surveillance, Basis: A missed' compensatory sample was incorrectly. categorized as a missed surveillance.
19 26 ...throughout the plant ...in the Unit 1 main feedwater system.
Basis: The solenoid valve coils in question were installed only in the Unit I main feedwater system.
___________
- .
,
.
'
Error
'
Page ;n
.
. SUMMARY OF RESULTS A. Overview The licensee has made substantial improvement in the performance of routine operations. Management has demonstrated a high degree f involvement in assuring the quality and safety of activities
-
Byron Station. Significant reductions in the number of reactor tr s, Es ations, LERs, significant events, safety system fai re d surveillance, and personnel errors occurred durin s ment period.
The SAL a n the area of Maintenance / Surveillance improved to SALP Cate r 1 this assessment period. This is primarily due to the g "
improvement in the surveillance area. Only one surveilli ce as missed during the assessment period and it was identified by licensee pervisory review. The attention-to-detail of the individu sp g surveillance and the improving quality of surveillance p s have made meaningful contributions to reducing the numbe o r trips and ESF actuations. Additionally, maintenance has cont u mprove in reducing the backlog of work requests and in imple n g eventative maintenance program.
However, weaknesses were 'deprified in the areas of plant operations, radiological controls, an a ce during the performance of non-routine events such as tag n the return to service
,,
following an outage. The sig an nts which occurred in each of these areas, during th as t period, primarily occurred during or immediately a er outages. Additional management attention needs to be focused on t vities to resolve these problems.
The performance rating during the prev us assessment period and this assessment period according to fun ional as are given below.
Rating Last Rat gT Functional Area Period Pe Trend f
Plant Operations 2 2 Radiological Controls 2 2 Maintenance / Surveillance 2/2 1 Emergency Preparedness 1 1 Security 1 1 Engineering / Technical q Support 2 2 i Safety Assessment / Quality j Verification NR 2 j i
B. Other Areas of Interest j l
None l
- _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _
_ - _ _ _ _ _ _ - _ _ _ _ _ _ _ . _ _ _ _ _ _ __ _
a
.
j
'
. *
,
'
II. SUMMARY OF RESULTS
A. Overview l l
The licensee has made substantial improvement in the performance !
of routine operations. Management has demonstrated a-high degree j of involvement in assuring the quality and safety of activities- :
at Byron Station. Significant reductions in the number of reactor ;
trips, ESF actuations, LERs, significant events, safety system j failures, missed surveillance, and personnel errors occ wred 1
'
during this assessment period.
The SALP rating in the area of Maintenance / Surveillance improved to SALP Category 1 during this assessment period. This is primarily due to the significant improvement in the surveillance area. No.
missed surveillance were identified during the assessment pericd. !
The attention-to-detail of the individuals performing surveillance i and the improving quality of surveillance procedures have made meaningful contributions to reducing the number of reactor trips and ESF actuations. Additionally, maintenance has continued to improve in reducing the backlog of work requests and in implementing a preventative-maintenance program.
However, weaknesses were identified in the areas of plant operations, radiological controls, and maintenance during the performance of non-routine' events such as outages and the return to. service following an outage. The significant events which occurred in each of these areas, during the assessment period, primarily occurred during or immediately after outages. Additional management attention needs to be focused on outage activities to resolve these problems.
The performance rating during the previous assessment period and this assessment period according to . functional areas are given below.
Rating Last Rating This Functional Area Period Period Trend Plant Operations 2 2 Radiological Controls 2 2 Maintenance / Surveillance 2/2 1 Emergency Preparedness 1 1 Security 1 1 Engineering / Technical Support 2 2 Safety Assessment / Quality Verification NR 2 B. Other Areas of Interest None
_ _ _ _ _ -
_ _ _ _ _ _ . _ _
_
- .
.
&w
'
Page in )
'
A nonreportable event did occur during the Unit I refueling j outage, however, which was the result of a personnel error during maintenance activities. The consequence of this error as t nadvertent transfer of approximately 10,000 gallons t om the refueling water storage tank (RWST) to the )
r coolant system (RCS). The majority of this water i ove o the refueling cavity through the reactor vess rea and resulted in additional work and cleanup activ 1 .
Another n ble event involving sulfate intrusion into the Unit s eam generators was well handled and showed close cooperatio between the chemistry and operations departments.
The events thi ssment period generally were properly identified an a promptly and completely reported, and acted on a r t' . Only one missed surveillance was identified duri t sment period; it was a personnel error by an RCT to collect a compensatory sample required by Techni 1 e ations. This error was discovered by the licensee dur ory review of surveillance records. This was a ig nt reduction from the five missed surveillance o e r us period.
Licensee management's in lve t< assure quality in maintenance and surveillan tiv- es improved and was evident during this period. Th demonstrated by minimal personnel errors in the main e/ surveillance area, one missed surveillance, and forc ates of 1.8% for Unit 1 and 2.0% for Unit 2 during the ri Performance improved significantly relative to that o t previous assessment period, in which the forced outag rates were 11% for Unit I and 18% for Unit 2. Over this peri , th censee reduced the backlog of corrective maintenance it hbout2000to about 900. Of those remaining at the n the assessment period, approximately 30% were safety- la A number of major maintenance and surveil a vities were performed this period during four major ou Unit 2 surveillance outage, two Unit 1 outages to eam generator tube leaks, and a Unit I refueling t he licensee exercised good control of work activi '
improved work planning and outage preparation d hs assessment period.
CECO issued a corporate directive in March 1988 to of ts nuclear stations on the Conduct of Maintenance; the rective follows the Institute of Nuclear Power Operations (INP guidelines. The directive contains the specific means opted by Ceco for sound maintenance performance and defines ac vities and responsibilities. During the assessment period, the 1 ensee was in the process of implementing this directive at Byron.
,
- _ _ . _ _ _ _ _ _ _ . _ _ . . _ _ _ _ _ . _ . _ . _ _ _ . _ . _ _ _ _
_ _ __. ____ _ _-_ _ ____ _ __
. _ _ .
- . , ,. 1
g ;
, -
.
.
A ncnreportable' event did occur during the Unit I refueling outage however, which was the result.of a personnel error during maintenance activities. -The consequence of this error was the inadvertent transfer.of.approximately 10,000 gallons'
of watercoolant reactor from the refueling)
system (RCS . water. storage tank
.The major.ity.of this. (RWST) water to the overflowed into the refueling cavity through' the reactor
- vessel flange area and resulted fr additional work and cleanup activities.
Another.nonreportable event' involving. sulfate intrusion into the Unit 2 steam generators was well handled and showed close cooperation between the chemistry and operations departments.
The events for this. assessment period generally were-prcperly identified;and. analyzed, promptly and completely repcrted, and acted:on appropriately. No missed surveillance were identified during the assessment period. . This was a significant reduction from the five missed surveillance of the previous period.
Licensee management's involvement to assure quality in maintenance and surveillance activities improved and.was evident during this period. This.was demonstrated by minimal
, personne1' errors in the maintenance / surveillance area, no missed-surveillance, and forced outage rates of 1.8% for Unit 1 and 2.0% for Unit 2 during.the period. Performance improved significar.tly relative to that of the previous.assessmer,t
. period,~in which the forced outage rates were.11% for Unit 1 and.18% for Unit 2. Over this period, the' licensee reduced the backlog of corrective maintenance items from about 2000 to '
about 900. Of those remaining at the end of the assessment period, approximately 30% were safety-related.
' A number of major maintenance and surveillance activities were performed this period during four major outages: a Unit 2 surveillance outage, two Unit 1 outages to repair steam generator tube leaks, and'a Unit I refueling outage. The licensee exercised good control of work activities and improved work planning and outage preparation during this assessment period.
CECO issued 6 corporate directive in March 1988 to all of its nuclear staticns on the Conduct of Maintenance; the directive follows the Institute of Nuclear Power Operations (INPO)
guidelines. The directive contains the specific means adopted by CECO for sound maintenance performance and defines activities and responsibilities. During the assessment period, the licensee was in the process of implementing this directive at Byron.
.
I
_ _ - - _
__ _ _ _ _ _ _ _ _
- .
. .
.
' '
O9e Yh $ff0f
..
l The licensee's responses to NRC initiatives and concerns were
!
technically sound and thorough. When the NRC raised concerns relating to maintenance or surveillance activities, the licensee respon in a timely and effective manner.
S the maintenance area, though adequate enough to pe quired work has improved during the assessment peri . 8, the maintenance staff was increased by appro.- e people. Overtime work by the maintenance staff a ly controlled and averaged about 6-7% in 1988. C affing remained satisfactory.
The effect1 ness of the training and qualification programs for personne performing maintenance, surveillance, and ISI activities wa evi the low personnel error rate. One of the violati s during this period was related to improper trainin at ical staff engineer, but this was considered an iso te 2. Performance Rating The licensee's perform ce ed Category.1 in this area.
The licensee's performan rat Category 2 in Maintenance and was rated Category 2 ance in the previous assessment period. The improved rati is t performance improvements which were demonstrated by a e rea the number of operational events and person 1 only one missed surveillance, improved forced tage rates, and a more focused PM program.
3. Recommendations F None D. Emergency Preparedness 1. Analysis Evaluation of this functional area was based o ection conducted by regional inspectors during this a e m t eriod.
Enforcement history improved in that no violatio identified compared with two Severity Level IV vio t n that were identified during the previous period.
Management involvement in assuring quality performance ne strong. The licensee's audit program involved two audi during the assessment period. One audit was conducted by the n ite QA staff, and the second audit was conducted by QA staff personnel from other licensee facilities. The use of QA st f from other licensee far.ilities was a new practice during thi
- .-_- _- . _ _ _
. .. . - - _ - _ _ _ -_ _
,
'. '"
.-
,
L 1
-
i
'
'The licensee's responses.to NRC initiatives and concerns were technically. sound and thorough...When the.NRC raised concerns relating to maintenance or surveillance activities..the licensee responded in a. timely and effective manner.
Staffinsi in the maintenance area, though adequate enough. to' -
'
)
perform all required work has improved during the' assessment period. In 1988,.the maintenance. staff was increased by approximately 10 people.1_ Overtime work;by the maintenance staff.was adequately controlled and averaged about 6-70in-1988. Chemistry' staffing. remained-satisfactory.
'
The effectiveness of the training and. qualification programs l for personnel performing. maintenance, surveillance, and ISI
. activities was evident in the . low personnel error rate.. One of the violations issued.during this period was'related to improper. training of.~a technical staff engineer, but this was-considered an isolated case.
2. Performance Rating-The licensee's performance is rated Category 1 in this area.
The licensee's performance was rated. Category 2 in Maintenance and was' rated Category 2 in Surveillance in the previous assessment
., period . The improved rating is due'to performance improvements-
.which were demonstrated by a decrease in.the number of operational events and' personnel errors, no missed surveillance, improved forced outage rates, and a more focused PM program.
3. Rec _ commendations None D. Emergency Pr_eparedness
_
1. Analysis .
Evaluation of this functional area was based on one inspection conducted by regional inspectors during this assessment period.
Enforcement history improved in that no violations were identified compared with two Severity L.evel IV violations that were identified during the previous period.
Management involvement in assuring quality performance remained strong. The licensee's audit program involved two audits during the assessment period. One audit was conducted by the ensite QA staff, and the second audit was conducted by QA staff personnel from other licensee facilities. The use of QA staff from other licensee facilities was a new practice during this
- _ _ _ _ _ _ _ - _ _ _
_ _ _ _
,
- .
I ;n Errx-l' Pn e l Other weaknesses involved the failure to perform adequate environmental qualification (EQ) reviews to ensure that 10 CFR 50.49 components were qualified, and the failure to resolve in a timely manner the question of similarity of eating, ventilation and air-conditioning (HVAC) components j stalle the plant to tested components.
The ro' )ch"to resolution of technical issues from a safety I stan . wa adequate. On the positive side, deficiencies in th sn % duction effort were effectively corrected, and j no prob w e encountered during reviews of these procedurcs.
Engineer e ons were technically accurate and the licensee' r tives demonstrated a clear understanding of the tech 1 ssues involved. Analytical approaches involved con: rvative methods tnd in most cases were technically s d and thorough. Records for the above evaluations wer well-ma tained and readily available. Third _
party technical y e performed by an outside consultant and provided addit 1 n idence in the technical adequacy of the work. In contr seve- examples were identified where poor EQ analyses had e rmed: failure to provide an adequate EQ test repo to ify Bunker Ramo penetrations installed in Unit 2, fa e onstrate that Whitman J505 pressure switches instal d ous systems were qualified for their intended applica io , and failure to demonstrate qualification of Borg Warne s valve coils installed -
throughout the plant.
The licensee's responsiveness t pr NRC-identified concerns or weaknesses was gener good; management attempted to address the entire spectrum of o issues, not just a narrowly identified problem, befo i ifying corrective actions. The licensee successfully s ved the long-standing problems with fire suppression system in the cable spreac'ing rooms. Corrective actions implemented a result of thr violations from the first phase effort o th s r reduction program were prompt and effective. The 1 e a equately addressed NRC-identified concerns with the tup test program.
The size of the engineering and technical suppo t st . the station remained constant, with approximately 2 o . aff comprised of contract personnel. Staffing at the a level remained a strength, with the technical staf u and three assistants all having SRO licenses. Howev , e licensee continued to rely almost exclusively on outs e consultants to provide technical expertise in all aspec of design and analysis of plant modifications. The lice ee compensated for this practice by participating in the sel tion of individual members of the consulting engineer's team.
Technical audits by third party reviewers were performed dur g
_ _ - _ _ _ _ -
_
- -_-_ _ - - - _ _ _ _ _ _ . _ _ _ _ - - _ _ _ _ _ - - _ _ - _ - _ .
.. .
'
..
.. .
Other weaknesses involved the failure to perform adequate environmental qualification (EQ) reviews to ensure that ] 4 10 CFR 50.49 components were qualified, and the failure to resolve in a timely manner the question of similarity of heating, ventilation and. air-conditioning- (HVAC) components installed in the plant to tested components. -l The approach to resolution of technical issues from a safety standpoint was adequate. On the positive side, deficiencies ;
in the snubber reduction effort were effectively corrected, and no problems were encountered during reviews of these procedures.
Engineering evaluations were technically accurate and the i licensee's representatives demonstrated a clear understanding l of the technical. issues involved. Analytical approaches involved conservative methods and in most cases were technically sound and thorough. Records for the above evaluations were well-maintained and readily available. Third party technical reviews were perfonned by an outside consultant .
and provided additional ccnfidence in the technical adequacy of the work. In contrast, several examples were identified where poor EQ analyses had been performed: failure to provide an adequate EQ test report to qualify Bunker Ramo penetrations installed in Unit 2, failure to demonstrate that Whitman J5CE pressure switches installed in various systems were qualified for their intended applications, and failure to demonstrate qualification of. Borg Warner solenoid valve coils installed in the Unit 1 main feedwater system.
The licensee's responsiveness to previous NRC~ identified concerns or weaknesses was. generally good; management attented to address the entire spectrum of potential issues, not just a narrowly identified problem, before identifying corrective actions. The licensee successfully resolved the inng-standing problems with fire suppression systems in the cable spreading rooms. Corrective actions implemented as a result of the violations from the first-phase effort of the snubber reduction program were prompt and e.ffective. The licensee adequately addressed NRC-identified concerns with the Unit 2 startup test program.
The size of the engineering and technical support staff at the station remained constant, with approximately 27% of the staff ;
comprised of contract personnel. Staffing at the management level remained a strength, with the technical staff supervisor and three assistants all having SR0 licenses. However, the licensee continued to rely almost exclusively on outside consultants to provide technical expertise in all aspects of design and analysis of plant modifications. The licensee compensated for this practice by participating in the selection of individual members of the consulting engineer's team.
Technical audits by third party reviewers were performed during
l-
<
l C__ _ _ _ _ _ __ _ _ _ _ _ _ _
,
_ _ _ _ _ _ _ _ __
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
- .
.
,
Commonwrith Edison One First Nationa! Plaza. Chicago, Ilknois Address Reply to Post Othee Box 767
. Chicago. Ilhnois 60690 - 0767 p [
nu x rtr February 27, 1989 tis x At
@5 24 M55 / TN -
NMU E . A Mr. A. Bert Davis ,
,
mm ,
Regional Administrator f1LE U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 Subjects Byron Stttaan Units 1 and 2
" Transmittal of Commonwealth Edison Comment on the SALP 8 Report" NRC Docket Nos. 50-454/455 Referencer December 30, 1989, letter from to Cordell Reed Transmitting the Byron SALP 8 Board Report No. 50-454/88012 and 50-455/88012.
Dear Mr. Davis:
With the above referenced letter, you transmitted to Commonwealth Edison a copy of the SALP 8 report for Byron Station for the period from November 1, 1987, through October 31, 1988.
On January 27, 1989, representatives of Commonwealth Edison met with you and members of your staff to discuss the SALP 8 Board Report for Byron Station.
Commonwealth Edison appreciates the NRC's recognition of the high level of performance in the functaonal areas of Emergency Preparedness, Security and Maintenance / Surveillance. We attribute Byron performance to quality programs, attention to detail and the overall professional attitude of the Byron Station personnel.
A concern was raised during the SALP meeting, and also within the SALP report, for Byron's decline in housekeeping. Byron Station )
acknowledges this concern and will continue efforts to improve this area. I There are two areas of the SALP report that should be clarified.
The first is in the functional area of Maintenance / Surveillance. In this j section a failure to collect a compensatory sample was categorized as a l missed surveillance. The sample was taken as a result of a Limiting l Condition for Operation required by Technical Specification and not a ]
surveillance requirement to determine operability. A discussion was held !
I with the Byron Senior Resident Inspector and he agrees that Byron did not I
miss a surveillance during this SALP period.
Secondly, in the Engineering / Technical Support functional area there were discussions of Environmental Qualification (EO) concerns. Some of the items mentioned are not currently identified as concerns for Byron Station. Discussions have taken place between Commonwealth Edison and Region III in an effort to clarify Byron's standing with regard to EQ 3ssues. It is expected that these communications will result in this area of the SALP report oeing modified.
n P A a dl M a nn_ n an~
_.
- ---
~ . j- ~,
..,
.
,
'
-2-V'
We' appreciate the efforts of the Commission and Resident-Inspectors of-Byron Station in preparing and presenting the SALP report. Commonwealth'
Edison is pleased with the acknowledgement by the SALP Board of Improvements in performance at Byron Station. Every effort'will be made to continue this
.high level of performance.
Please direct any questions regarding this transmittal to the Nuclear Licensing Department.
Very truly yours,
e .
L.O. De1 George Assistant Vice-President
'RC/scl 0045V:1-2 cc L. Olshan-NRR Project Manager D. Muller-NRR Directorate III-2 Resident Inspector-Byron
.
l
_ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _