IR 05000454/2008003

IR 05000454-08-003; 05000454-08-003, on April 01 2008 - June 30, 2008, Byron Station, Units 1 and 2; Fire Protection, Inservice Inspection Activities, Maintenance Effectiveness and Maintenance Risk Assessments and Emergent Work Control

ML082270712
Person / Time
Site:	Byron
Issue date:	08/14/2008
From:	Pederson C D Division Reactor Projects III
To:	Pardee C G Exelon Generation Co, Exelon Nuclear
References
EA-08-197 IR-08-003
Download: ML082270712 (76)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 August 14, 2008

EA-08-197 Mr. Charles Chief Nuclear Officer and Senior Vice President

Exelon Nuclear Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT: BYRON STATION, UNITS 1 AND 2 NRC INTEGRATED INSPECTION REPORT 05000454/2008-003 05000455/2008-003 PRELIMINARY

WHITE FINDING

Dear Mr. Pardee:

On June 30, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Byron Station, Units 1 and 2. The enclosed report documents the inspection findings, which were discussed on July 10, 2008, with Mr. D. Hoots and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed

personnel. The enclosed inspection report discusses a finding that appears to have low to moderate safety significance. As documented in Section 1R13 of this report, the licensee inadvertently entered an elevated risk condition for Unit 2 in April 2008. At that time, the two Unit 1 essential service water train cross-tie isolation valves were out of service for maintenance. These two valves were opened locally to support the Unit 1 Train A emergency diesel generator testing and could not to be closed from the main control room. The licensee later determined that this configuration represented an elevated risk condition for Unit 2 due to degraded internal flood mitigation capability.

This finding was assessed based on the best available information, including influential assumptions, using the applicable significance determination process (SDP) and was preliminarily determined to be of low to moderate safety significance (White) for Unit 2 and of very low safety significance (Green) for Unit 1. The safety significance of the finding was determined assuming a Unit 1 essential service water pipe break in the auxiliary building that is not isolated due to unavailability of the two Unit 1 train cross-tie isolation valves and an exposure time of 38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br />. The final resolution of this finding will convey the increment in the importance to safety by assigning the corresponding color i.e. (White), a finding with some increased importance to safety, which may require additional NRC inspection. This finding was not an immediate safety concern because upon identification Byron Station took immediate actions to assign a dedicated operator to locally close the valves when necessary and to restore the remote actuation capability from the main control room. You have also entered the issue into your corrective action program (CAP). Based on the results of this inspection, one apparent violation was identified for Unit 2 and is being considered for escalated enforcement action in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRC's Web site at http://www.nrc.gov/reading-rm/adams.html. In accordance with Inspection Manual Chapter (IMC) 0609, we intend to complete our evaluation using the best available information and issue our final determination of safety significance within 90 days of this letter.

The significant determination process encourages an open dialog between the staff and the licensee, however the dialogue should not impact the timeliness of the staff's final determination.

Before the NRC makes its enforcement decision, we are providing you an opportunity to either: (1) present to the NRC your perspectives on the facts and assumptions, used by the NRC to arrive at the finding and its significance at a Regulatory Conference or (2) submit your position on the finding to the NRC in writing. If you request a Regulatory Conference, it should be held within 30 days of the receipt of this letter and we encourage you to submit supporting documentation at least one week prior to the conference in an effort to make the conference more efficient and effective. If a conference is held, it will be open for public observation. The NRC will also issue a press release to announce the conference. If

you decide to submit only a written response, su ch submittal should be sent to the NRC within 30 days of the receipt of this letter. If you decline to request a Regulatory Conference or to submit a written response, your ability to appeal the final SDP determination can be affected, in that by not doing either you fail to meet the appeal requirements stated in the Prerequisite and Limitation sections of Attachment 2 of IMC 0609.

Please contact Richard Skokowski at 630-829-9620 within 10 days of the date of this letter to notify the NRC of your intended response. If an adequate response is not received within the time specified or an extension of time has not been granted by the NRC, the NRC will proceed with its enforcement decision and you will be advised by separate correspondence of the results of our deliberations on this matter. Since the NRC has not made a final determination in this matter, no Notice of Violation is being issued for these inspection findings at this time. Please be advised that the number and characterization of apparent violations described in the enclosed inspection report may change as a result of further NRC review. You will be advised by separate correspondence of the results of our deliberations on this matter. Since the finding for Unit 1 is of very low safety significance, it is being treated as a Licensee Identified Non-Cited Violation in this report.

In addition, three NRC-identified and one self-revealed findings of very low safety significance (Green) were also documented in the enclosed inspection report. All four findings were determined to involve violations of NRC requirements. However, because of their very low safety significance, and because the issues were entered into your CAP, the NRC is treating the issues as Non-Cited Violations in accordance with Section VI.A.1 of the NRC Enforcement Policy. Furthermore, three licensee identified violations are listed in Section 4OA7 of this report. If you contest the subject or severity of the Non-Cited Violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Byron Station. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). To the extent possible, you response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.

Sincerely,/RA/ Cynthia D. Pederson, Director Division of Reactor Projects Docket Nos. 50-454; 50-455 License Nos. NPF-37; NPF-66

Enclosure:

Inspection Report 05000454/2008-003; 05000455/2008-003

w/Attachment:

Supplemental Information cc w/encl: Site Vice President - Byron Station Plant Manager - Byron Station Regulatory Assurance Manager - Byron Station Chief Operating Officer and Senior Vice President Senior Vice President - Midwest Operations Senior Vice President - Operations Support Vice President - Licensing and Regulatory Affairs Director - Licensing and Regulatory Affairs Manager Licensing - Braidwood, Byron, and LaSalle Associate General Counsel Document Control Desk - Licensing Assistant Attorney General Illinois Emergency Management Agency J. Klinger, State Liaison Officer, Illinois Emergency Management Agency P. Schmidt, State Liaison Officer, State of Wisconsin Chairman, Illinois Commerce Commission B. Quigley, Byron Station